2024-05-03_PERMIT FILE - C1980007 (2)

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2.05-70 Rev. 11/96- PR07; 04/06-PR10; 12/14- TR136, 04/24 – TR153 Vegetation monitoring at the West Elk Mine will encompass both interim and final revegetation monitoring. Interim revegetation monitoring will be conducted on the Lower Refuse Pile for the purposes of evaluating revegetation plan elements, including, but not limited to, seed mix components, application rates and methods, and mulching. Generally, newly revegetated areas exhibit annual "weed" dominance for the first one to three years after seeding. Since this occurrence is widely acknowledged as normal in revegetation scenarios, information obtained from sampling during this period is not particularly useful. Mountain Coal Company does not plan to undertake any interim monitoring while annual "weedy" species are dominant. For this reason, MCC proposes interim revegetation monitoring after the perennial revegetation species have become well established. Final reclamation monitoring of the revegetated mine site will commence in the second year following seeding, in accordance with the definition of the extended liability period. Monitoring will take place during years 2, 4, 6, 9, and 10 of the liability period. Sampling methods and statistical analysis will be consistent with those described in Section 2.05.4 of the MRP. Grazing Success During the last two years of the 10-year liability period, a grazing program using domestic livestock will be instituted. Grazing will occur at a capacity and management level consistent with that for adjacent properly managed non-mined lands. Although grazing with domestic livestock is preferred, grazing trials may preclude or interfere with post mining vegetation sampling or operational requirements. In this case, grazing studies will be substituted for the direct use of livestock. These substitute studies will involve clipping large plots during normal periods of grazing to simulate grazing by livestock. Regardless of which grazing method is used, herbaceous production and cover will be estimated on both affected and reference areas. Data from affected and reference areas will then be compared using t-tests. Agricultural Monitoring Plan When the West Elk Mine was originally permitted, an annual survey was used to conduct agricultural monitoring. After each growing season, landowners with agricultural lands in the North Fork Valley were surveyed. The survey consisted of interviewing each landowner orally. Results of this survey are contained in Exhibit 9. After the 1982 survey, OMLR and Mountain Coal Company determined the annual survey was no longer necessary. Both found mining practices and monitoring programs in effect at the West Elk Mine sufficient to ensure that the mining operation would not significantly degrade water quality or reduce water quantity in the North Fork of the Gunnison River. There is little, if any, chance the mine would affect the North Fork AVF. Based on these considerations, OMLR determined the yearly agricultural monitoring program was of little value and could be discontinued. Therefore, Mountain Coal Company ended the agricultural monitoring program after the 1982 survey.