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Janet Binns <br />July 15, 2015 <br />Page 10 <br />evaluated by subdividing each of these areas with belt transects and by using a Trimble Model <br />GeoXH global positioning survey unit, which has a typical post -process data accurate of plus <br />of minus one meter, during each of the final two years of Phase III Final Bond Release. <br />Using this unit EFCI will sample every single woody plant contained within the boundaries of <br />these shrub transplant areas. Then based upon either the contribution of the transplanted <br />shrubs and trees, planted shrubs or invading shrubs and trees, a total of at least 1,843 woody <br />plants will be present during each sampling period at the time of final bond release sampling. <br />Meaning that EFCI will guarantee that at least 100 percent of the number of shrubs and trees <br />transplanted on these twelve sites will be present at the time of final bond release sampling. <br />Secondly, on all areas corresponding to the Refuse Pile Reclamation which correspond to the <br />Grassland Pre -Disturbance plant community, an average of at least 250 woody plant stems per <br />acre will be present on these reclaimed areas during each of the final two years of Phase III <br />Final Bond Release reclamation monitoring. <br />Thirdly, on all reclaimed areas corresponding to the Vento Portal Reclamation area, which <br />correspond largely to the Pinyon-Juniper/Ponderosa Pine Pre -Disturbance plant community <br />an average of at least 800 woody plant stems per acre will be present on these reclaimed areas <br />during each of the final two years of Phase III Final Bond Release reclamation monitoring. <br />As are approved in the current Southfield Mine Permit, there will be no woody plant density <br />revegetation success standard on the Corley Property. The currently approved woody plant <br />density for the Southfield Loadout reclamation will be identical to that found in the currently <br />approved Southfield Mine Permit. <br />Due to the fact that there is currently an excessive overabundance of woody plants, consisting <br />of shrubs and trees on and immediately adjacent to the Southfield Mine area which according <br />to the USDA NRCS soil survey as well as recently performed field studies by the NRCS and <br />the Colorado Division of Wildlife are expanding at an alarming rate with many of these <br />species becoming invasive, EFCI believes there is no specific need to transplant any more <br />woody plants on the reclaimed areas located at the Southfield Mine. The proposed standards <br />are reasonable and appropriate for the approved post -mining land uses at the Southfield Mine <br />and are in line with current state-of-the-art reclamation methods and the current policies and <br />practice of the Division. <br />