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Janet Binns July 15, 2015 Page 9 Raton Creek Mine. (30.7 acres disturbed, 30.7 acres Phase III released) Final bond release monitoring was performed by EFCI on the Raton Creek Mine in the summers of 2004 and 2005. The Permit final bond release woody plant density standards was initially 500 woody plants per acre. Examination of the original baseline vegetation shrub density data reveals that the undisturbed areas adjacent to the reclaimed areas being sampled for final bond release woody would not satisfy this revegetation success standard. EFCI submitted TR -22 which was approved by the CMLRB, which revised the Permit final bond release woody plant standard down to 167 woody plants per acre. This TR resulted in final bond release being granted for this site. According to Permit Pages 321 to 323, which correspond to the mine site and refuse pile disturbance areas, the pre -mining shrub density of these areas averaged 203.8 woody plants per acre. Proposed Southfield Mine Woody Plant Density Revegetation Success Standard. (106.3 acres disturbed, none Phase III released) Examination of the reported forage palatability rankings of the fourteen shrubs encountered during the sampling of the three reference areas located at the Southfield Mine and according to the shrub density results presented in EFCI's response to the first CDRMS adequacy response letter there are only two shrubs; Curl -leaf Mountain Mahogany and Yellow Rabbitbrush which possess livestock palatability rankings of good or better which could be considered for inclusion into the proposed Southfield Mine woody plant density revegetation success standard. During the 2013 and 2014 bond release vegetation sampling, wherein a total of 220 belt transects were evaluated a total of 183 Curl -leaf Mountain Mahogany plants and one Yellow Rabbitbrush were encountered. Overall, the approximate average of these two desirable woody plants would be 0.83 plants per 100 square meters or approximately 33.7 plants per acre. Upon comparing the current approved woody plant density revegetation success standards for the four mines located in the Purgatoire River Valley evaluated in this assessment, reveals the following trends. At the New Elk Mine, there is no woody plant density standard other than that for the six shrub clumps. For the Golden Eagle Mine, "shrub density will not be used to evaluate revegetation success." For the Lorencito Mine, there is a woody plant density revegetation success standard of 500 stems per acre for the Pinyon -Juniper vegetation type and shrub establishment areas located on the north facing slopes for the Grassland vegetation type. There is no woody plant density revegetation success standard for the general reclamation areas of the Grassland vegetation type. At the Raton Creek Mine, the woody plant density revegetation success standard was approved and bond release granted with a standard of 167 woody plants per acre. According to these current and previous approvals by the Division, EFCI proposes the following woody plant density revegetation success standards for the Southfield Mine. The final revegetation woody plant density standard for the reclaimed areas at the Southfield Mine site will consist of three aspects. Firstly, the twelve shrub transplant areas planted by the Colorado State Forest Service with a total of 1,843 shrubs and trees in May of 2004 containing an area totaling 6.23 acres will be