2016-11-29_GENERAL DOCUMENTS - C1981010

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reclaimed site. Alfalfa (Medicago sativa) and Western Yarrow (Achillea millefolium) were the most commonly encountered perennial forbs. The 2015 report indicated the total allowable cover averaged 79.43% and perennial plant cover averaged 59.35%. For the 2015 data, perennial grasses Intermediate Wheatgrass (Agropyron intermedium), Great Basin Wildrye, Kentucky Bluegrass, Western Wheatgrass, and Sheep Fescue dominated the seeded vegetation on the reclaimed site. Alfalfa and Western Yarrow were the most commonly encountered perennial forbs. According to the revegetation monitoring reports, the range site C block in 2014 had a total allowable cover average of 77.38% and a perennial plant cover average of 50.68%. For the 2014 data, perennial grasses Intermediate Wheatgrass, Great Basin Wildrye, Western Wheatgrass, Smooth Brome (Bromus intermis) and Sheep Fescue dominated the seeded vegetation on the reclaimed site. Alfalfa and Cicer Milkvetch (Astragalus cicer) were the most commonly encountered perennial forbs. The 2015 report indicated the total allowable cover averaged 82.48% and perennial plant cover averaged 59.35%. For the 2015 data, perennial grasses Intermediate Wheatgrass, Great Basin Wildrye, Kentucky Bluegrass, Western Wheatgrass, and Sheep Fescue dominated the seeded vegetation on the reclaimed site. Alfalfa was the most commonly encountered perennial forb. The revegetation monitoring reports data allowed cover from Cheatgrass (Bromus tectorum) to contribute to the allowable cover percentage for some of the transects this species was found in. Cheatgrass is listed as a List C noxious weed. The Division is unable to allow plant species listed on the State Noxious Weed list (Department of Agriculture, Conservation Services Division, 8 CCR 1206-2: Rules Pertaining to the Administration and Enforcement of the Colorado Noxious Weed Act) to contribute to reclamation success. The Division's Guidelines, entitled "Guideline Regarding Selected Coal Mine Bond Release Issues, April 18, 1995", specifically states that, "under no condition will noxious weeds count towards the success standard." Based on the revegetation monitoring report data, cheatgrass had contributed a small amount to the relative cover for the site and an insignificant amount to the allowable cover percentage. The Division reviewed and modified the data submitted in the 2014 and 2015 revegetation monitoring report to remove the contribution of Cheatgrass to the allowable cover percentage. The differences between what the Division and TMI determined to count toward allowable cover was insignificant and did not preclude the Division from finding that the reclaimed sites met the required vegetation cover success standards. The range site A reclamation success standard for cover is 52% (effective/allowable cover). Based on a direct comparison, the average percent allowable cover for both 2014 and 2015 exceeded the success standard for range site A. Revegetation on the requested reclamation range site A/B blocks was sampled to statistical adequacy for vegetative cover for both years of sampling, 2014 and 2015. The revegetation productivity success standard is 62.39 grams per square meter or 15.60 g/1/4 m2 for the range site A/B reclamation block. As recommended in the Division's guidelines, annuals, biennials and shrub production were not included in the production success measurements. In 2014, the forage production on the site averaged 72.93 g/1/4 m2 or 291.72 g/m2 according to the revegetation monitoring report. In 2015, forage production averaged 86.07 g/1/4 m2 or 344.29 g/m2. Since the reclaimed area production value exceeds the revegetation success standards, as allowed in the Division's existing regulations (Rule 4.15.11(2)), and applying the reverse null statistical approach, it can be concluded that the requested reclaimed range site A/B block satisfies the requirements with respect to production. Trapper Mine Page 9 November, 2016 Phase III Bond Release (SL -17)