2015-02-05_REVISION - C1981014 - Laserfiche WebLink

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Southfield Vegetation Standards TR-45 January, 2015 The second year of Phase III final bond release sampling at the Southfield Mine was completed in the summer of 2014. The contribution of the two most dominant warm- season grass species from the four approved reference areas was as follows: Refuse Pile Reference Area 66.30 percent; New Portal Reference Area 15.56 percent; Old Portal Reference Area 5.79 percent and Loadout Reference Area 43.94 percent. This comparison documents that based upon the 2014 sampling data, only one of the four approved reference areas would satisfy the current species diversity revegetation success standard. These data clearly establish that the Permit warm season species diversity standard is grossly inappropriate for the Southfield Mine and cannot be achieved even on the undisturbed reference areas. The weighted average value of the two dominant warm season based upon the 2014 reference area sampling would be 38.60 percent meaning that none of these reference areas would satisfy this revegetation success standard. Not only is it impossible for three of the four currently approved undisturbed reference areas to satisfy this standard but it is clearly contrary to the CDRMS regulations and written guidance as well. Rule 4.15.8(2) Revegetation Success Criteria states: Vegetative cover and herbaceous production, species diversity and woody plant density on the reclaimed surface area shall be at least equal to (defined below) the vegetative cover and herbaceous production, species diversity and woody plant density of living plants on the approved reference area or to the standards established in 4.15.7(2)(d). In addition, the vegetation of the reclaimed area shall be of the same seasonal variety native to the area of disturbed land, or shall consist of species that support the approved postmining land use. Furthermore, examination of the Division's Guidelines for Compliance with Land Use and Vegetation Requirements of the Colorado Mined Land Reclamation Board for Coal Mining, issued in October 1988, states with respect to species diversity: D. Species Diversity The regulations require coal operators to establish a diverse vegetative cover on reclaimed lands and allow the use of ore- mining data as the basis for evaluating species diversity on revegetated areas. The Division recommends that a simple comparison of species composition, life form, and seasonality between ore -mine communities and the revegetated area be employed to demonstrate success in establishing a diversity vegetative cover. In general, for herbaceous vegetation, the number of perennial herbaceous species contributing greater than 3 percent relative production or cover in the ore -mine data for each affected community designates the number or species, the seasonality and the life forms of the species to be established on the reclaimed area. As with reference areas, success can be evaluated based upon a direct comparison between a particular pre -mine community and corresponding parcel of reclaimed land, or the evaluation can F)