2016-06-17_REVISION - C1980007 (2)

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INTEROFFICE MEMORANDUM TO: LEIGH SIMMONS FROM: JANET BINNS WEST WEST ELK MINE, SL9, PHASE III RELEASE VEGETATION REVIEW DATE: 6/14/2016 CC: I have reviewed the West Elk Mine, C-1980-007, application for a partial Phase III bond release, SL - 9 for reclaimed vent hole pads and associated roads. The bond release block, BRB, consists of 22 parcels in 4 mining areas. The mining areas are: Deep Creek, Long Draw, Long Draw Saddle, and West Point Road. The combined acreage of the 22 parcels is 22.1 acres. Parcel size ranges from 0.1 acres to 8.5 acres. The parcels were reclaimed between 2002 and 2004. Mountain Coal Company, MCC, sampled the vegetation for bond release determination in 2014 and 2015. All the parcels included in the bond release application had a minimum of 10 years since the last seeding, in accordance with Rule 3.02.3(2)(b). Sampling of the reclaimed parcels was conducted in a manner similar to the method described in Section 2.04.10 of the permit. MCC utilized acreage allocated samples based upon the relative percentage of the acreage in each mining area described previously. Sample locations within each of the mining districts, Deep Creek, Long Draw, Long Draw Saddle, and West Point Road, were determined using a 50 foot by 50 foot grid and start locations determined using a random number table. The Division finds this approach acceptable. Additional description of the sampling methodology can be found in the bond release application. The reclamation success standards for the West Elk Mine were determined using historical data. This approach and the standards have been approved by the Division previously. The approved post -mining land use is rangeland with wildlife habitat. Live vegetative cover shall be a minimum of 90% of 53.04% with 90% statistical confidence. Total herbaceous production shall be a minimum of 90% of 180.38 g/M2 (1609.5 lbs./acre) with 90% statistical confidence. Noxious species as determined by the Colorado Department of Agriculture, are not included in the success values. In 2014, MCC sampled the bond release block and determined the live vegetative cover was 69.04%. The reclaimed area was sampled to statistical adequacy in accordance with Rule 4.15.11(2)(a). This value exceeds the success standard for live vegetative cover. In 2015 MCC sampled the bond release block and determined the live vegetative cover was 69.10%. The reclaimed area was sampled to statistical adequacy in accordance with Rule 4.15.11(2)(a). This value exceeds the success standard for live vegetative cover. MCC measured 226.8 g/M2 (2023.5 lbs./acre) on the reclaimed parcels in 2014. Sample adequacy was achieved. This value exceeds the standard for total herbaceous production. Productivity measured on the bond release block in 2015 was 239.3 g/M2 (2135.2 lbs./acre). Sample adequacy was achieved. This value exceeds the standard for total herbaceous production.