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Southfield Vegetation Standards <br />TR-45 January, 2015 <br />entail a weighted average comparison based upon the relative acreage occupied by <br />various vegetation communities prior to disturbance of the reclaimed parcel in <br />question. [emphasis added] <br />Failure of all of the approved reference areas to satisfy the current warm season species diversity <br />revegetation success standard clearly documents that the Division imposed in the early 1980's <br />and has perpetuated a standard that is totally contrary to their regulations and written guidance <br />by requiring a standard that the undisturbed native vegetation will not satisfy. <br />Obviously the Division, never bothered to determine whether the species diversity standard they <br />mandated, complied with this guidance or not. Since the current species diversity standard found <br />in the Southfield Mine Permit is contrary to the regulations found at Rule 4.15.8(2), which <br />requires a comparison of the vegetation found on the reclaimed area with the reference areas and <br />the Vegetation Guideline which allow for a comparison of the reclaimed area with the pre -mine <br />data. It is imperative that this Permit revegetation success standard should be changed as it is <br />virtually unobtainable. <br />Historic vegetation monitoring data collected from the Southfield Mine site pose questions about <br />the suitability of setting a high warm season species diversity standard. Sampling of the Refuse <br />Pile Reference Area in 1987 was performed using the methodology in place at that time, wherein <br />plant cover and production data were all sampled by individual species. Plant cover data <br />document that total plant cover averaged 41.00 percent, with all warm season grasses <br />contributing 24.4 percent of the total plant cover or 59.12 percent of the relative plant cover and <br />cool season grasses contributed 2.20 percent of the total plant cover or only 5.36 percent of the <br />total relative plant cover on this site. <br />However, production sampling of this site by individual plant species resulted in cool season <br />grasses producing an average of 12.92 grams per square meter, or 40.99 percent of the total <br />relative production, while warm season grasses produced a total of 18.60 grams per square meter <br />or 59.01 percent of the total relative production on this site. When converted to a common <br />standard of the number of grams produced per square meter per one percent plant cover, cool <br />season grasses produced 5.87 grams of air dry forage per one percent plant cover while the warm <br />season grasses produced 0.76 grams of air dry forage per one percent plant cover. This sampling <br />confirmed that on a relative scale, cool season grasses are 7.72 times more productive than are <br />the warm season grasses. This comparison confirms the readily evident observations that the <br />warm season grasses, which are dominated largely by Blue Grama, which typically have leaves <br />which only grow one and one half inches to two inches in height and often forms a dense mat, <br />while the cool season grasses often grow well over a foot in height. These site specific data <br />confirm the trend established in over a century of research in the field of range management, and <br />which has been stated several times to EFCI by Ms. Janet Binns of the Division, that cool season <br />grasses are more productive than are warm season grasses. <br />Given the repeated declaration that the Vento Group Landowners have made in correspondence <br />to the Division, that they want to graze cattle on their lands, as well as the stated post- mining <br />land use in the Southfield Mine Permit that the post- mining land use is to consist of "open <br />rangeland" and "wildlife habitat," EFCI believes that the current warm season grass species <br />3 <br />