2019-04-16_REVISION - C1981019 (3)

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RULE 4 PERFORMANCE STANDARDS Rule 4 Performance Standards 4-70 Revision Date: 4/16/19 Revision No.: MR-200 Woody Plant Density – Post-2008 Revegetation As alluded to under the cover and production success criteria, a new revegetation plan utilizing a “prescribed ecological reclamation approach” (PERA) has been adopted for the Colowyo operation that will facilitate the creation of wildlife habitat conducive vegetation communities (sagebrush steppe), hence Post-2008 revegetation will be subject to a different set of success criteria for bond release. In this regard, the following discussion lays some of the foundation of the underlying principles of this approach to provide a basis for development of the success standards. The post-2008 revegetation will specifically target livestock grazing and sage grouse brood rearing habitat. Both of these, in combination, are the two primary components of the Post-mining Rangeland Land Use. Post-2008 areas designed to target livestock grazing (and incidental / unavoidable grazing by elk) will comprise approximately 60% to 80% of the original and South Taylor reclaimed landscapes. These areas will principally occupy more steeply sloping ground (>10%) where the grassland community is necessary to preclude excessive erosion, especially from snowmelt. Based on evaluation of the post-mining topography, the remaining 20% to 40% (estimated) of the reclaimed landscape will afford flat or gently sloping surfaces (<10%) with reduced exposure to erosion. It is on these less exposed more gentle slopes whereby development of wildlife conducive habitats (sagebrush steppe) can be attempted (only on larger blocks of land - e.g., >5 acres) without overly compromising stability. In this regard, sagebrush communities targeting sage grouse brood-rearing habitat will be attempted in earnest on approximately 20% (or more) of the Post-2008 reclaimed landscape, with the goal of achieving success on at least one- half of this acreage or as otherwise agreed upon between Colowyo and CDRMS. The principal basis of PERA is to rebuild the foundation conditions of target vegetation communities taking into account the appropriate aspects, slopes, and topographic features of the reclaimed landscape. In this manner, targeted communities, as opposed to more simple grasslands will be more strongly encouraged. Potential reclamation techniques to be applied to facilitate the targeting of sagebrush communities include, but are not limited to: 1) taking advantage of site- specific opportunities for development of convex and concave surfaces to encourage snow entrapment; 2) development of small berms along the contour and somewhat perpendicular to prevailing winds, also to encourage snow entrapment; 3) use of native species; 4) severe reduction of grasses in the seed mix; 5) use of only bunch grasses for those taxa planted with sagebrush; 6) sharp increases in the amount of sagebrush seed to be used; 7) extra care to obtain the correct subspecies of sagebrush (vaseyana-pauciflora) with a seed source as close as possible to the Axial Basin; 8) extra care to place seed at the ideal time of year (immediately prior to the first major snowfall event; 9) placement of thin layers of topsoil over overburden; 10) possible placement of zero topsoil; 11) possible placement of thin layers of overburden over topsoil; 12) use of specialized seed placement equipment to obtain correct planting depths; 13) use of seedbed preparation equipment and techniques to encourage sagebrush emergence; and 14) interseeding of additional grasses and/or forbs (only where necessary) following a period of 2 – 3 years of growth by shrubs. All of these possible techniques / metrics are designed to diminish the competitive advantage of grasses, at least in the early stages of establishment and growth. The primary “foundation-building” element for this approach is the ability to replace variable topsoil depths and/or quality of soil materials depending on site-specific needs, the discretion of the field construction supervisor, and the capabilities (or lack thereof) of available materials and equipment.