2020-08-20_PERMIT FILE - C1980007A

• Permit No: C1980007A
• IBM Index Class Name: Permit File
• Doc Date: 8/20/2020
• Doc Name: 2.05-50 Thru 2.05-88
• Section_Exhibit Name: 2.05.4 Reclamation Plan
• Media Type: D
• Archive: Yes

Alsike Clover 1/2
Cicer Milkvetch 1
11
Shrub Species
Stems/Acre
Streambank Willow
250
Narrowleaf Cottonwood
200
River Birch
250
Hawthorn
50
Wood's Rose
250
1000
Grass and forbs species will be hand broadcast at twice the above rate and shrubs and trees will be hand
planted from container or cutting stock.
Evaluation of Reclamation Success
Reclaimed Area Revegetation Success
During the initial permitting of the West Elk Mine in 1980 and 1981, revegetation success was proposed
to be based on two reference areas established in Sylvester Gulch. Since two vegetation communities
were initially disturbed during the construction of surface facilities at the West Elk Mine, a dry meadow
reference area and an oakbrush reference area were established. The reference areas were to be used for
evaluation of total vegetation cover and herbaceous production during revegetation evaluations for bond
and liability release. Total vegetation cover and total herbaceous production from the reference areas
were to be compared with like mean parameter values from the reclaimed and revegetated areas.
Subsequent to the initial permitting of the mine, evaluation of the reference area concept occurred in the
regulatory, mining, and academic communities. Concerns arose with the long-term management and
maintenance of reference areas, as well as their comparability to the expected (and observed) post -mining
vegetation communities. Several options for development of revegetation success criteria existed in
addition to reference areas, but technical standard and historic record approaches had not been pursued by
industry or regulatory authorities, and involved unspecified commitments to data acquisition.
In 1996, Mountain Coal Company (MCC) initiated activities related to the expansion of long-term mine
facilities in the Sylvester Gulch drainage, which was the location of the dry meadow reference area. In
order to address regulatory performance standards related to revegetation success and minimize
expenditures related to identifying, sampling, and maintaining reference areas for each vegetation
community disturbed by mine activities, MCC pursued approval from CDRMS of alternative means of
establishing revegetation success criteria for the West Elk Mine. The alternative method selected was a
historic record methodology. During the summer of 1996, MCC and Savage and Savage, Inc.
developed this historic record approach to establishing revegetation success criteria specific to the West
Elk Mine and was approved by CDRMS, in Permit Revision No. 07.
The approved approach to establishing a historic record, and subsequent revegetation success criteria
involved identification and selection of a representative vegetation community which could be sampled
in a controlled manner during a range of environmental conditions, specifically, precipitation regimes.
After the selection of the historic record vegetation community in concert with CDRMS, the selected
2.05-65 Rev. 11/96- PR07,- 04/06- PR10:07/11- TR125