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EFCI met or exceeded the reclamation success standards for the reclaimed areas for 2013 <br />and 2014. Allowable cover, forage productivity, woody plant density and plant species <br />diversity were all found to meet or exceed the reclamation standards. <br />The Division has two adequacy concern regarding the reclamation success calculations: <br />• Technical Revision 45 was approved on July 31, 2015. TR45 provided corrected <br />surveyed acreage values for the reference areas. These values are found on permit <br />page 2.04.10-5a. The acreage values used in the 2013 and 2014 vegetation <br />reports vary slightly. Reclamation success standards are based on an acreage <br />weighted approach for both the reference areas and the reclaimed areas. EFCI <br />needs to use the approved acreage as shown in the permit for the reference area <br />calculations. <br />The Division ran the calculations using the approved reference area acreages and <br />found that the reclaimed areas still met or exceeded the success standards. <br />• In the 2013 vegetation report, two different values area reported for the woody <br />plant density on the Vento portal area. Table 2 reports 1025 woody stems per <br />acre. Tab G text states, "the average woody plant density for the Vento Portal <br />Reclamation area equals 923.3 woody plants per acre." Although both values <br />exceed the requirement of establishing a minimum of 800 stems per acre, the <br />value needs to be reported consistently. EFCI needs to correct the actual value of <br />woody stems per acre measured on the Vento property in 2013. <br />2 <br />