2016-11-29_GENERAL DOCUMENTS - C1981010

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Revegetation Success Sampling and Results TMI sampled vegetation in the summer of 2014 and the summer of 2015. The Operator hired IME consulting firm from Yampa, Colorado to assess the revegetation success. Two bond release blocks were sampled. One bond release block consisted of parcels reclaimed in the D, F, and Z pits that are within range site A and B. The second bond release block consists of parcels reclaimed in the A, D, and H pits that are within range site C. The bond release blocks were sampled for vegetative cover, productivity, species diversity, woody plant density and shrub clump survival. The range site A/B bond release block was compared to the approved success standard for range site A and the range site C bond release block was compared to the revegetation success standards for Range Site C as approved in section 4.4 of TMI's permit. Trapper achieved vegetative success for rangeland cover, productivity, diversity, woody plant density and shrub clump survival. Due to non -parametric data distribution of rangeland productivity and woody plant density data, TMI demonstrated reclamation success of these two parameters by using the reverse null hypothesis per rule 4.15.11(2)(c). Two revegetation monitoring reports were submitted with the SL -17 application for areas sampled in 2014 and 2015. These reports outline the methods used to measure vegetative cover, productivity, species diversity, and woody plant density/shrub clump survival. The sampling methods used meet the criteria outlined in Rule 4.15.1 1(1) and the permit application. Revegetation monitoring transects were randomly located throughout the bond release blocks. Each portion of the bond release block had an equal chance of being sampled. Plant cover was measured along a minimum of twenty 50 meter transects. Ten locations along each transect were sampled using a metal 10 -point frame resulting in 100 data points collected per transect. Plant cover data were used to measure and evaluate species diversity. To measure production, a minimum of thirty transects were sampled. Three randomly -located, one -quarter -meter clip plots were sampled along each transect. The plots were clipped by life forms of perennial grasses and perennial forbs. Annuals, biennials, noxious weeds and shrub production were not clipped. Following clipping, the harvested plant material was oven -dried and weighed to determine average production for the bond release blocks. Modified belt transects were conducted along the same thirty transects used to measure production to determine woody plant density for the range site A/B block. Also, two shrub clumps were located within the range site A/B bond release block. Each shrub clump contains 250 to 300 shrub pads. Half of each of the shrub pads was counted to quantify that at least 50% of the pads contained 10 living woody plant stems per pad. For range site A, the required herbaceous cover standard is 33% and 19% litter cover for a total 52% effective cover ("Allowable Cover"). For range site B, the required herbaceous cover standard is 29% and 23% litter cover for a total effective cover of 52%. For range site C, the required herbaceous cover standard is 25% and 22.0% litter cover for a total effective cover of 47%. These standards for each of the range sites are listed on Table 4.4-1 of the permit. For this release (SL -17), since the range site A/B bond release block consists of range site A and B types, the revegetation standard for range site A was used to evaluate revegetation success since it has the most conservative standard. According to the revegetation monitoring reports, the range site A/B block in 2014 had a total allowable cover average of 80.45% and a perennial plant cover average of 56.9%. For the 2014 data, perennial grasses Great Basin Wildrye (Elymus cinereus), Western Wheatgrass (Agropyron smithii), Kentucky Bluegrass (Poa pratensis) and Sheep Fescue (Festuca ovina) dominated the seeded vegetation on the Trapper Mine Page 8 November, 2016 Phase III Bond Release (SL -17)