2018-02-13_REVISION - C1981038 (20)

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sampling data, but forb species exhibiting greater than 3% relative cover tend to be introduced species. In the 2013 sampling effort, four (4) native forb species were encountered; Showy goldeneye, Hairy false golden aster, Lewis flax, and Rocky mountain penstemon. None of these native forb species exceeded 3% relative cover in 2013 at the West Mine or Run -of -mine areas. However, during this sampling event four perennial introduces forb were encountered; Cicer milkvetch with 21.58% relative cover (ROM), Alfalfa with 30.49% relative cover (West Mine), Small burnet with 11.96% relative cover (ROM), and Crown vetch with 1.56% relative cover (West Mine). These introduced forbs are beneficial forage species in a mixed grass rangeland community. The East Mine was sampled in 2016. Four native perennial forb species, and six introduced perennial forb species were encountered during the 2016 sampling. Of the four native non -noxious perennial forb species, none were encountered with greater than 3% relative cover. Of the six perennial non -noxious introduced forb species, two were present at greater than 3% relative cover, Cicer milkvetch and Alfafa. Both of these introduced perennial forbs in the 2016 sampling effort are beneficial forage and support the approved post -mining land use. The Division concurs that allowing perennial native or introduced (non -noxious) forb species to count towards a reclamation success standard, and allowing inclusion of species contributing greater than or equal to 0.5% relative cover, but less than 60% relative cover, is appropriate for the post -mining Rangeland land use. 2. The operator proposes to revise the forb standard to, "Establish >/= 2 native or introduced herbaceous forb species: each contributing 0.5%<X<60%." In accordance with Rule 4.15.1(1) and 4.15.8(6), the Division does not consider that annual and biennial species meet the definition of "permanent" vegetation cover, therefore the Division asks Bowie Resources to include "perennial" in the proposed standard. "Establish >/= 2 native or introduced perennial herbaceous forb species: each contributing 0.5%<X<60%." 3. The Division also finds that the word "perennial" needs to be inserted into the proposed standard "Species Diversity: establish >/= 3 native cool season grass species each contributing 0.5%<X<60%." The Division concurs with the proposed change to the shrub /subshrub diversity requirement. The operator is not proposing to revise cover or productivity standards.