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Janet Binns July 15, 2015 Page 8 was the dominant plant contributing 70.4% of the woody plants. Golden Eagle Mine. (66.2 acres disturbed, 65 acres Phase III released) Examination of the Golden Eagle Mine permit (Permit Page 2.05-20) reveals that for the post - mining land use areas of rangeland and pastureland "shrub density will not be used to evaluate revegetation success ... " Contrary to the Division's regulations and Vegetation Guideline, this Permit text states that "Fringed sage is the only valuable shrub encountered." Unfortunately, their current woody plant density standard is based principally on a plant that is not even a shrub, nor is even currently considered by the CDRMS as being a woody plant. According to the baseline woody plant density sampling on this mine site by Uniscale in 1980 and 1981, on the Grassland vegetation type the woody plant density of this type was reported to equal 809.4 plants per acre. On the Pinyon/Juniper vegetation type, the woody plant density was reported to equal 7,397.9 plants per acre. Pinyon Pine was the dominant plant contributing 46.7 percent of the woody plants. Lorencito Mine. (155.6 acres disturbed, 27.2 acres Phase III released as industrial use) Examination of this Permit reveals that there are seven vegetation types within this mine permit area. There was a total of 870 acres of disturbance proposed at this site (Permit Page 2.05-80), which the Oak/Pinyon Pine/Juniper vegetation type corresponding to 756 acres or 86.90 percent of the total disturbance. Only 155.6 acres were actually disturbed and reclaimed. The mine is now approved for reclamation only with no further mining approved. According to the approved Reclamation Plan (Permit Pages 2.05-74-75), there are two vegetation types associated with the reclamation at this mine. The post -mining shrub density standard for the Pinyon -Juniper vegetation type and the north facing shrub establishment areas of the Grassland vegetation type is 500 steams per acre. There is no shrub density revegetation woody plant density standard for the Grassland vegetation type outside of the shrub establishment areas. At the landowners request, nearly all of Oak/Pinyon Pine/Juniper vegetation type is being reclaimed to a Grassland post -mining vegetation type. There is no woody plant density requirement for the Grassland Vegetation Type, however, Lorencito Coal Company committed to plant shrub establishment areas on the north facing slopes of this type. The final Phase III Revegetation Woody Plant Density for the shrub establishment areas is 500 stems per acre of the Pinyon -Juniper and Grassland shrub establishment areas. Baseline vegetation sampling of this mine was performed by Greystone Associates in July 1996. The baseline woody plant density of the Grassland vegetation type was reported to be 58.67 stems/ha or 23.74 stems per acre, however, winterfat was included as a shrub and accounted for 13.33 stems/ha (5.39/acre) or 22.72 % of the woody plants. The shrub density reported for the Oak/Pinyon Reference Area was 11,438.67 stems/ha or 4,629.15 stems per acre. The shrub density reported for the Oak/Pinyon Pre -Disturbance Area was 7,895.81 stems/ha or 3,073.98 stems per acre.