2015-07-22_REVISION - C1981014 - Laserfiche WebLink

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Janet Binns July 15, 2015 Page 3 EFCI Response The Division requests that EFCI please consider a woody plant density success standard that promotes both of the approved post -mining land uses for the site, rangeland and wildlife habitat. (Rule 4.15.1(1). The following narrative and technical review, prepared by Mr. Kent Crofts of I.M.E., Inc., addresses this issue in detail. Rule 4.15.1(1) states: "Each person who conducts surface coal mining operations shall establish on all affected land a diverse, effective and permanent vegetation cover of the same seasonal variety native to the area of disturbed land, or species that support the approved postmining land use." The designated postmining land uses for the Southfield Mine are rangeland and wildlife habitat. Rangeland is defined in Rule 1.04 (55)c as "land on which the plant cover is principally valuable for forage. Except for brush control, management is primarily achieved by regulating the intensity of grazing and season of use." Fish and Wildlife Habitat is defined in Rule 1.04 (55)(h) as "land used wholly or partially in the production, protection or management of species of fuh or wildlife. " Rangeland is the primary land use as this site and is the primary focus of management and wildlife habitat is the secondary land use because wildlife occur over this entire region. According to the CDRMS regulations, Rangeland is land which is `principally valuable for forage." In order to quantify the forage value of the potential woody plants that are the focus of TR -45, EFCI consulted with the USDA Plants website Database to determine the forage preference of the woody plants in question. Upon consulting this reference, four items were specifically researched. Firstly, for any given species, the Plant Characteristics section if present was consulted and the Suitability/Use subsection was examined specifically for the listed Palatable to Browse Animal as well as Palatable to Grazing Animal categories. Secondly, if a listed species had a Plant Fact Sheet, then that article was consulted. Thirdly, if a listed species had a Plant Guide then that article was also consulted. Fourthly, the Related Links tab was examined and the USDA Forest Service Fire Effects Information System was examined for the species being evaluated. Of the fourteen species encountered in the sampling of the three reference areas at the Southfield Mine as were identified in the previous EFCI response to the first CDRMS adequacy response letter, each of these shrubs or tree species will be evaluated in the following narrative for their forage value to both livestock and wildlife. Gambel Oak: The USDA Plants website, contains no Fact Sheet or Plant Guide for this species, but the Forest Service rates this species asfair for cattle and good for deer and elk in Colorado.