2020-12-09_REVISION - C1994082 ‎(11)‎

• Permit No: C1994082
• IBM Index Class Name: Revision
• Doc Date: 12/9/2020
• Doc Name: Proposed Decision and Findings of Compliance
• From: DRMS
• To: Moffat County Mining, LLC
• Type & Sequence: SL8
• Permit Index Doc Type: Findings
• Email Name: RAR
• Email Name: JLE
• Media Type: D
• Archive: No

Results
Cover
In 2016 for BRB-2a,native perennial cool season grasses made up the species consisting mainly of
Pascopyrum smithii (western wheatgrass),Leymus cinereus (basin wildrye), Elymus elymoides (bottle
brush squirrel tail), and Poa pratensis ssp. agassizensis (Agassiz bluegrass). Introduced perennial cool
season grasses and introduced perennial forbs were the next most abundant species comprising
Bromopsis inermis (smooth brome), and Phleum pretense (Timothy grass), and Medicago sativa
(alfalfa),respectively. Introduced annual and biennial forbs followed. Pocilla biloba (twolobe
speedwell)was the dominant species comprising this category. Weeds, listed on the B list and C list of
noxious weeds were observed at the site but did not contribute significant amounts of vegetative all-hit
cover.
Total average all-hit vegetation cover was 61.4%. Allowable all-hit herbaceous vegetation cover was
52.7% after removing excess annual/biennial cover and noxious weeds. Average species density was
24.4 species per 100m2.
In 2016 for BRB-3, native perennial cool season grasses made up the species consisting mainly of
Pascopyrum smithii (western wheatgrass),Elymus lanceolatus ssp. Lanceolatus (thickspike
wheatgrass),Festuca saximontana (Rocky Mountain fescue), and Leymus cinereus (basin wildrye).
Introduced perennial cool season grasses followed closely of which Bromopsis inermis (smooth brome),
and Thinopyrum intermedium represented the greatest contributors. Introduced perennial forbs
comprised the next most abundant life form with a majority species of Medicago sativa (alfalfa), a
species utilized for grazing. Noxious weeds were observed at the site but did not contribute significant
amounts of vegetative all hit cover. Total average all hit vegetation cover was 50.9%. Allowable all hit
herbaceous vegetation cover was 48.2%. Average species density was 20.3 species per 100m2.
For the ERA,the 90% success standard was found to be 44.7 for BRB-2a and 24.7 for BRB-3 in 2016.
The allowable all hit vegetation cover in both the BRB-2a and BRB-3 areas exceeded the success
standard. Sample adequacy was demonstrated for the reclaimed area therefore, in accordance with Rule
4.15.11(2)(a),revegetation success in term of vegetation cover has been achieved.
Species Diversity
Mandatory Test A requires that no single species comprise greater than 60%relative cover. For the two
bond release areas BRB2a and BRB3 the dominant species were Neicago sativa, commonly known as
Alfalfa (15.7%) and Pascopyron smithii 17.1% (western wheatgrass),respectively. Test A was passed
for the Phase II areas. For Alternative Test B probability adjusted density standard was exceeded in
both bond release blocks. The standard for BRB2A is 20.59 and the measured value was 22.85. For
BRB3 the standard was 14.6 and the measured value was 19.29. Both phase II areas passed the
Alternative Test B. Both bond release blocks greatly exceeded the similarity index between lifeform
species (Alternative Test Q. The standard for both BR132A and BRB3 was 63 and the measured index
was 66 and 98 respectively, passing Test C. For test D,the presence of native species the performance
standards were 23.3 and 12.6 for BRB2A and BRB3 respectively. The cumulative number of species
was 46 for BRB2a and 36 for BRB3,thereby passing Alternative Test D.
Permit Number C1994 082 Page 12 of 15