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and approved the use of these methods as a basis of comparison with the approval of Technical Revision <br />No 15 approved 12/1/93. EFCI is rewriting the standard so they can meet it. <br />In the 2008 Revegetation Inventory, Kent Crofts states that EFCI could not meet the requirement <br />for 50% warm and 50% cool season grasses. EFCI did not interseed nor did the Division require them <br />to do so. In that report shrub density also could not be met. Rabbit Brush and Sage Brush were the <br />dominant shrubs. Only 4 Wing Saltbush survived and only on the SW side of the refuse pile. Presently <br />there are large areas without any shrubs throughout the reclamation area and definitely a lack of diversity. <br />When Linda Saunders spoke with George Patterson in the summer 2012 at the time we were <br />meeting Janet to talk to her about revegetation since she was our Environmental Specialist after Kent <br />Gorham left, George said "Whatever the Division requires ". It seems that rarely does the Division require <br />or uphold their standards. And getting a Technical Revision denied has been very rare during our <br />observations. <br />Linda Saunders, Tena Gallagher and Paula Coulter asked Janet Binns and Dan Hernandez to enforce the <br />DRMS standards and to provide oversite in a meeting regarding vegetation and water issues in January <br />2013. EFCI has had fourteen years to remediate and meet the standards but they made no adaptations. <br />The Colorado Division of Wildlife states: " Pinion and juniper are becoming invasive" but if you look at our <br />property and the revegetation reports, you know that this is not the case. In order to have a successful <br />grazing program, we can not have the large majority of woody stemmed plants be rabbitbrush which can <br />be toxic to cattle and horses. Rule 4.15.8(2) states the vegetation on the reclaimed area shall consist of <br />species that support the approved postmining land use. Vegetation that can be toxic to cattle and horses <br />doesn't support our postmining use of grazing. <br />A 1999 report from U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station <br />states: "Rubber rabbitbrush is, in general, considered of little value to all classes of livestock although <br />some subspecies receive at least light use by livestock during the winter months. All subspecies are <br />considered to be slightly toxic to livestock. Rubber rabbitbrush provides good cover for several species of <br />nesting birds. Plants may provide very specific habitat for insects such as Acurina [80]. Rubber <br />rabbitbrush is of little importance to larger mammals. <br />http://www.fs.fed.us/database/feis/plants/shrub/chrnau/all.html <br />Could you confirm that page 5 of the 2010 revegetation monitoring report.pdf is the Vento Reclamation <br />and not the Corley Reclamation as it is titled? <br />From page 3 of 2010 Revegetation Report submitted on 6/28/2011: "As outlined in the Southfield Mine <br />Permit and in subsequent technical and minor revisions as approved by the Division the plant cover <br />standard at the Southfield Mine is based on a total herbaceous cover standard revised permit page 2.05.4- <br />27 which means that all plant cover including annual and biennial plant and listed noxious weeds are <br />sampled and counted toward the cover standard while the cover contributed by shrubs and trees is <br />excluded." (We think that noxious weeds were excluded later and could not be included in totals.) <br />Also on the same page it states: "According to the calculations found on revised permit page 2.05 4 -27 <br />submitted in connection with Minor Revision 48 the corresponding success standard is based upon a <br />weighted average approach wherein the weighting factor will reflect 79.8 percent grassland and 20 <br />percent ponderosa pinion juniper woodland ..." <br />From page 4: "As described on revised page 2.05.4 -27 of the Southfield Mine Permit submitted in <br />connection with Minor Revision 48 the species diversity standard requires that for all revegetated areas at <br />the Southfield Mine site the reclaimed plant community shall be composed of at least four dominant <br />species comprising no more than 80 percent of the total relative percent cover and that the warm season <br />