2016-10-28_PERMIT FILE - C2010089A (3)

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would instead be a forage quality diversity standard. Therefore, the following forage quality diversity standard was proposed and approved for the NH2 Mine and is proposed for the NHN Mine as well: Production on all Irrigated Pasture reclaimed areas will consist of "desirable plant species, as defined below, which will contribute at least 75% of the relative production and will be comprised of seeded species or species of comparable quality as livestock forage as compared to the Irrigated Pasture Reference Area standard. As are recommended on page 7 of the Bond Release Guideline, the production of all annuals and biennials will not be sampled in either the Irrigated Pasture reclaimed areas or Irrigated Pasture Reference Area. In addition, all Montrose County or San Miguel County listed noxious weed species will not be counted toward the revegetation success standard for cover or production in any reclaimed or reference areas. For the purposes of this demonstration, a statistically adequate production sample will be taken, or with a minimum of 15 cover samples and at least 30 production samples. As are recommended on page 7 of the Vegetation Guideline and as directed by Mr. Dan Mathews in an e-mail send to Mr. Ross Gubka, on 7 July 2010, the production plots on all of the Irrigated Pasture Reference Area will involve the sampling of perennial herbaceous plants which will be clipped by life forms which will include perennial grasses and perennial forbs. While on the Irrigated Pasture reclaimed sites, the plants will be clipped by the categories of. seeded grasses, seeded forbs, non -seeded desirable grasses, non -seeded desirable forbs. Annuals, and biennials, undesirable grasses, undesirable forbs and noxious species will not normally be clipped. Our careful review of this for the NH2 Mine permit section and in the previous reclamation monitoring reports resulted in our finding no specific definition of what constitutes a "desirable species" although this term is used extensively in the NH2 permit and in previous reclamation monitoring reports. Therefore, as used in the NHN Permit Application and correspondingly for revegetation success of this area a "desirable species" is determined using the following criteria as developed after consulting the following sources. Firstly, all species listed in the Office of Surface Mining Reclamation and Enforcement - Plant Materials Handbook issued in May 1988 for Colorado that includes the 54 species of plants recommended by the NRCS for the subsection entitled Colorado - Standards and Specifications - Pasture and Hayland Planting guideline and which contain Table 1, Perennial Grasses and Legumes for Pasture and Hayland plantings in Colorado will be considered as "desirable species" within the context of forage quality for purposes of final bond release. Secondly, for all species that are not included in the OSM reference cited above, which includes nearly all of the non -agronomic or pasture species. then the USDA NRCS Plants database, found at http: Hplants.usda.pov website will be used. For example, Quackgrass (Agropyron or Elyrigia repens) is not listed on the 1988 OSM list, and thus upon consulting this website and typing in Section 2.05.4(2)(e) Page 14 May 2015