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RULE 2 PERMITS <br />reclamation planning for the disturbed South Taylor project area for two principal reasons. First, efforts <br />to establish Mountain Shrub and Aspen revegetated communities in Northwest Colorado within the <br />timeframe of the liability period have met with repeated and well-documented failures. Second, <br />replacement of habitats conducive to Sage Grouse is of far greater importance to the CPW than any other <br />wildlife species group. In this regard, the C -SRA provides a far better example of the long-term desirable <br />vegetation structure and composition that is more closely tied to the habitat requisites of Sage Grouse. <br />Given the mobility of most wildlife taxa (including Sage Grouse), there is sufficient Mountain Shrub <br />habitat within proximity to planned disturbances to meet a majority of perceived needs of other wildlife <br />populations including elk herds. <br />Eighth, a healthy stand of perennial grasses (with or without occasional stands of sagebrush) has been <br />shown to be the most effective erosion control on young reclaimed landscapes. With fast growing roots <br />to absorb moisture and large above -ground biomass to intercept precipitation, grasses are more effective <br />in stabilizing barren soil than the more slow-growing deciduous shrubs of the Mountain Shrub <br />community. A few deep-rooted and long-lived sagebrush plants provide diversity and long-term stability <br />to reclamation provided there is a healthy component of grasses and forbs in the understory to stabilize <br />the soil surfaces between individual shrubs. The shrub to perennial grass ratio on the C -SRA (27% <br />sagebrush to 50% perennial grass, forb and sub -shrub composition) is a reasonable target for long-term <br />mature reclamation with respect to erosional stability. (An ideal target for a mature community <br />conducive to Sage Grouse brooding habitat will have a lower component of sagebrush in the composition <br />— more in the range of 10%.) <br />MOUNTAIN SHRUB REFERENCE AREA <br />Colowyo will use the originally established Colowyo Mountain Shrub Reference Area (C-MSRA-1980) <br />for future determinations of revegetation success for the Lower Wilson disturbance areas as well as the <br />original permitted disturbances. Colowyo has determined to use this reference area instead of the "Harper <br />established" South Taylor Mountain Shrub Reference Area (ST-MSRA) for five reasons as follows. <br />First, the C-MSRA is readily accessible (located above Taylor Creek immediately west of Colowyo's <br />West Pit operations) and should remain accessible during the life -of -mining. The ST-MSRA is located <br />high in the rugged terrain even further south than the ST -SRA where access may be intermittently or <br />permanently interrupted by mine -related activity. <br />Second, the C-MSRA has been measured more frequently over the past several years and therefore, <br />presents a more extensive historic data -base. In addition, since the C-MSRA is currently used for bond <br />release success comparisons at the Colowyo Mine and for use as a reference area for the Collom Project, <br />it would simplify and streamline future bond release sampling efforts at all these projects if a single <br />mountain shrub reference area was used. <br />Third, based on statistical testing per current Divisionguidelines, the ST-MSRA is not comparable to the <br />South Taylor Study Area for ground cover (see Table 2.04.10-27) but is eligible as a reference area only <br />because values are higher than those found in the study area. The sampling adequacy and equivalency <br />procedures used by Harper in 1984 were more liberal for such evaluations. <br />Fourth, a review of data presented on Figures 2.04.10 — 9 and 10 indicate that Hamer's 1984 data for the <br />ST-MSRA is substantially elevated over all other comparable mountain shrub data sets from the area, but <br />most importantly, the values are 13% and 20% higher than the surrounding South Taylor Study Area <br />during the same year for cover and production, respectively. Some of this difference with data sets from <br />other years can be explained by an analysis of precipitation. However, the differences between the ST- <br />MSRA and the study area reduce the defensibility of this reference area as an appropriate comparator for <br />South Taylor/Lovver Wilson — Rule 2, Page 58 Revision Date: 4/7/17 <br />Revision No.: RN -07 <br />