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grasses shall comprise at least 50 percent of the total plant cover composition." This standard has not <br />been met. The Species diversity standard should remain the same with 2 dominant warm season grass <br />species collectively comprise 50% of the total plan cover area. The two warm season species in the refuse <br />pile reference area are blue gramma and sand dropseed and the refuse pile is similar. In 1987 the Refuse <br />Pile Reference area was 47.8 percent warm season which is close to the 50% required by the DRMS <br />standard. EFCI says that it should have been changed 27 years ago. They want a much lower % and should <br />not be allowed to change it. The sampling was taken in September 2010 "near the end of the period of <br />optimum plant growth when the plant cover and production were near their peak." <br />Page 8 states: "Species Diversity: The percent relative composition or cover values in Table 3 Vento <br />Reclamation Plant Cover document that the four most dominant plant species growing on this reclaimed <br />site contributed a total of 63.35 percent of the total relative cover found on this site. This is well below the <br />maximum value of 80 percent required by the Permit. The two most dominant warm season grass species <br />contributed 10.11 percent of the relative cover on this site which is well below the 50 percent required by <br />the Permit. These revegetation monitoring data from this site confirm that the species diversity standards <br />for this reclaimed site in 2010 are satisfied with respect to the four most dominant species but are <br />deficient with respect to the warm season grass component." Again Energy Fuels did not interseed. <br />Page 15: Sample Adequacy was not achieved with respect to herbaceous production. Again no action on <br />Energy Fuels part was taken. <br />There seems that I should not need to go any further to explain the standards. Energy Fuels completely <br />ignored that there was a problem and knew that they were not going to be able to meet the standards <br />starting in 2008. If you'd like, I could go further in explaining where Energy Fuels has not met the DRMS <br />revegetation standards and regulations as written for the State of Colorado. Or how Energy Fuels is now <br />trying to change the percentage of areas. <br />On June 27, 2012 Jason Musick provided a 44 page cost estimate of what it would take to reseed and <br />replant the Vento property. We, the property owners, were excited hoping that maybe Energy Fuels would <br />consider some of the replanting suggestions. <br />If a company does not meet standards, it would make sense that they would adapt their strategy to meet <br />them. EFCI did not reseed to meet these standards. Because the Vento landowners requested trees and <br />shrubs, EFCI was required to put them in the seed mix and plant them to meet the revegetation standards <br />for woody plant density. The photos we have after the first year where the small shrubs were not properly <br />staked (3 sided) and were dead or mis- shapen because of the wildlife but not one shrub was replanted. In <br />areas where I have dealt with restoration in California, many companies are required to supplement water <br />by hand watering if there is a lack of water such as a drought. If the standards are not meet, they need to <br />replant. If there is a lack of rain, adjustments need to be made that water is brought in. <br />Some questions that we have and can't find the answers are: <br />How often have the revegetation standards been changed by a mining company in Colorado? <br />If other mining companies are expected to follow the standard, then how can EFCI change it for their <br />benefit only? <br />How often do mining companies rewrite the standards for the DRMS? <br />Why is EFCI trying to combine all of the reference areas into one average with all of them weighted <br />equally? This is not how we understand the standard reads. <br />Why is the loadout area included in the weighted average? It was our understanding that the loadout area <br />is not in the Southfield reclamation area. <br />EFCI needs to meet the DRMS standards for revegetation- 50% warm season grasses /50% cool season <br />grasses and shrub density- not rewrite them and set their own standards so they can meet them for the <br />Phase II and Phase III Bond Release. They should not be allowed to combine the Loadout area with the <br />