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MEMO <br />noting that there may be flexibility in the guidelines for the establishment of perennial forbs on reclaimed <br />areas. Indeed, there is past precedent for altering specific requirements for forb abundance given other <br />community characteristics. However, given that multiple components of the reclaimed site vegetation <br />community are currently insufficient for Phase III bond release (i.e. overall cover and production, in <br />addition to forb abundance), it is advisable to focus on decreasing the gap in overall vegetation cover <br />between the reference and reclaimed sites at this time. <br />One option for addressing the large vegetation cover differences between the reference and reclaimed <br />sites may be to adjust the location and type of reference site. In addition to a general decrease in overall <br />cover in the reclaimed area, there are notable differences in species composition and vegetation structure <br />between the reclaimed site and the Rangeland Reference Area currently being used for a baseline <br />comparison (see Attachment 1). Seeking out alternate reference sites within the defined allowable area <br />may help normalize the broad differences in vegetation community. Specifically, we recommend <br />evaluating sites that fall within the Pinyon -Juniper ecotype located on the Golden Eagle Mine property as a <br />possible alternative for comparison to the reclaimed area. An initial cursory evaluation of prospective sites <br />by an ecologist or botanist is recommended prior to an extensive field campaign. In choosing a reference <br />area, special attention should be made to select for similar landscape features to the reclaimed site, <br />particularly with regards to slope and aspect. <br />Furthermore, in the event that an additional field sampling campaign is undertaken, we recommend <br />considering adjusting the time of season in which sampling occurs. Sampling at full leaf bloom may result <br />in increased vegetation hits relative to bare ground, standing dead and litter. While this is likely true both <br />for reference and reclaimed areas, the greater proportion of overall vegetation hits may further normalize <br />some of the differences between the sites and give a more accurate representation of peak biomass and <br />abundance. <br />Attachments: <br />Figure 1 Rangeland Reference Area <br />Figure 2 NW Fan Shaft Reclaimed Area <br />Attachment 1 Data Sheets <br />arcadis.com Page: <br />T <br />