2018-06-05_PERMIT FILE - C1981019A (7)

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RULE 4 PERFORMANCE STANDARDS recruitment rate to the shrub population can be documented on Colowyo revegetation, there would be no need to achieve elevated densities within a modest time -frame such as the 10 -year responsibility period. Given these points, the following woody plant density success criteria will be applied to Post -2008 revegetation efforts: On grassland communities (approximately 60% to 80% of reclaimed acreage (>10% slope) targeting the post -mining land use of grazing -land), zero woody plant density will be required. However, if shrub communities evolve in these areas this acreage will count toward the wildlife habitat acreage and be subject to the appropriate standards. On manifested shrublands (approximately 20% or more of reclaimed acreage targeting the post -mining land use goal of wildlife habitat — sage grouse brooding habitat), the following criteria will be applied depending on shrubland classification. On "core areas" (areas of shrub concentration and comprising no less than one-half the minimum total shrubland acreage), the eventual desirable goal shall be 1000 plants per acre, but the standard shall be 375 live plants per acre. At least one-half of these totals shall be sagebrush species. In "ecotonal areas" the eventual desirable goal shall be 500 plants per acre, but the standard shall be 200 plants per acre. The 375 and 200 plants per acre standards translate to approximately one plant for each 10.4ft. x 10.4ft. or 14.8ft. x 14.8ft. area, respectively. Furthermore, Colowyo makes the commitment to establish sagebrush steppe (comprised of both core and ecotonal areas) on approximately 450 acres of the post -2008 reclamation for the original and South Taylor permit areas, or as otherwise agreed upon between Colowyo and CDRMS. This acreage is based on the following rationale: 1) delineation of all post -2008 post -mining acreage exhibiting slopes 10% or flatter; 2) elimination of all small, isolated, or impractical areas for targeting this community; 3) implementing "banding" (alternating strips of grassland versus shrubland) procedures on large units with long slopes that might otherwise lead to excessive "snowmelt" erosion; and 4) assuming 50% shrub establishment success on the acreage that actually receives shrub conducive metrics. Issues with the potential longterm longevity of fourwing saltbush will require that a maximum proportion of the countable shrubs used to demonstrate conformance with the applicable performance standards be limited to 20%. As an example, should an area demonstrate 375 live shrub plants per acre, 300 of those plants must be something other than fourwing saltbush. Colowyo believes that on-site research partially refutes the data collected at other locations with respect to fourwing saltbush longevity but has compromised in this case given the concerns raised by the Division. Diversity The initial Permit Application addressed Diversity by using the Shannon Weiner Index to measure the distribution of species within the existing premine vegetation community. Over the early years of SMCRA compliance, this procedure was determined to be problematic for this use as a means to evaluate diversity. Colowyo did not feel comfortable using such a complicated Index, but did so because it was the norm at the time to use this method. Since the initial Permit Application, CDRMS regulations have been revised to allow for the use of comparisons of species composition based on cover between the reclaimed area and the undisturbed vegetation. This method of analyzing diversity was applied to the weighted premine herbaceous vegetation cover data originally sampled and summarized in Section 2.04. 10 on Table 2, 1980 Herbaceous Cover by Species. A total of four species with a combined contribution to diversity of 43.4% have been chosen to characterize the premine vegetative community diversity standard. Rule 4 Performance Standards 4-64 Revision Date: 1/31/18 Revision No.: TR -119