2018-03-20_PERMIT FILE - C1981019A (3)

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RULE 4 PERFORMANCE STANDARDS a 90% statistical confidence utilizing a standard students statistical t-test comparison of the means. If necessary, a reverse -null hypothesis testing procedure may be utilized in accordance with procedures detailed in Rule 4.15.11 (2) (c). As inferred under Rule 4.15.8 (3) (ii), relaxation of the herbaceous production standard for areas targeting wildlife habitat post -mining land uses is designed to compensate for revegetation techniques (prescribed ecological reclamation approach) that must discourage grasses to encourage shrubs in the post-revegetated community. Justifications for reduction to 70% are identical to those presented for cover in the previous section. Woody Plant Density — Pre -2008 Reve etg ation Cedar Creek Associates, Inc.'s recent in-depth analysis of past "shrub conducive efforts" (report dated April, 2007) attempted by Colowyo on older (pre -2008) reclamation has resulted in the conclusion that such past efforts can largely be considered a failure and techniques such as bare -root or containerized plantings should no longer be attempted. It has become obvious to all parties concerned (including Colowyo, their consultants, the researchers at Colorado State University, the CDRMS, and the CDOW) that reclamation practices utilized historically were far more conducive to establishing herbaceous species at the expense of woody species. (It is for this reason that post -2008 reclamation, using different reclamation techniques will have a different success criterion.) Furthermore, the continued existence of herbaceous species at elevated densities, along with browsing by big game animals, continues to preclude opportunities for establishment and/or growth of woody species populations. In effect, historic (and expensive) attempts to establish shrub populations into these "dense herbaceous stands" using the best technology available at the time have met with nearly complete failure. Only a few remnant plants and "patches" of shrubs remain in the reclamation, and many of those surviving plants were established from seed in the mix as opposed to seedling planting. In this regard, all parties (including the CDOW) are in general agreement that older (pre -2008) revegetation at Colowyo's operations favors the livestock grazing aspect of the approved Rangeland Land Use, and that the woody plant density component of those areas is largely inconsequential for such use. However, it has been noted, that big game use, primarily by elk, of the pre -2008 revegetation has been at substantially elevated levels over the past several years, and occasionally has been shown to be problematic to area CDOW managers (as well as contributing to the impact on shrub establishment. (See Enclosed CDOW letter below, especially the 3`d paragraph.) Therefore, the woody plant density success criterion within pre -2008 reclamation at Colowyo's operations shall be 150 live stems per acre on approximately 3% (or more) of the reclaimed surface. Rule 4 Performance Standards 4-59 Revision Date: 1/31/18 Revision No.: TR -119