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III. COMMENTS -COMPLIANCE Below are comments on the inspection. the comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and fhe facts or evidence supporting.the enforcement action. This was a joint inspection conducted with representatives of the U.S. Forest Service to evaluate revegetation efforts on the thermal event drill sites and methane degas wells. Representing the USFS were: Dave Bradford, Leane Matson, Justin McConnelly and Ryan Taylor. Henry Barbe of Mountain Coal Company participated in the entire inspection. This inspection was conducted because the Division and the USFS have been in discussion for a couple of years regazding the seed mix to be used on forest service lands. These lands aze managed rangeland and as such the USFS has specific seed mixes that they prefer to be used. The approved seed mix for activities on the USFS rangeland areas includes: Mountain Brome, Prairie junegrass, Slender wheatgrass, Bluebunch wheatgrass and Sandburg bluegrass. The Division is in agreement with all the grass species being planted however, the seed mixes do not include any forb species. The Division is concerned about whether the sites would achieve the reclamation success standards for species diversity. The diversity standard for rangeland at the West Elk Mine is: A minimum of 2 cool season grasses and 2 perennial forbs each with relative cover values lying between 3 and 63 percent. This standard was based on the baseline data that was included in the permit application, Exhibit 61. It is worth noting here that the standazd was developed using the baseline data for the facilities azeas from a dry meadow community and mixed-shrub wet community (Exhibits 32 and 33). These communities may not be directly compazable to the higher areas on USFS lands. We visited the main drill site and staging area for the thermal event activities, a couple of other thermal event drill sites and several reclaimed methane degas well-sites. Cattle were actively grazing at the large thermal event area. Overall, the revegetation efforts have been very successful. Dominant grasses aze: Mountain brome, bluebunch wheatgrass, slender wheatgrass, and Jlnegrass. Forb establishment is apparent on most sites including: coreopsis, peavine, lupine, American vetch, mint, Jacob's ladder, aster, arrowleaf balsamroot and penstemon. A number of other forbs that were not readily identified were also present. Several weedy species were also observed including Cheatgrass. Several weed patches of whitetop, bull thistle, and Canadian thistle were identified in the field that will need treatment this season. Where native vegetation was left in place there is considerable sprouting of the aative shrubs including: serviceberry, oakbrush, snowberry, and rose. Overall, forb presence is low, although the USFS felt it may be indicative of the native rangeland in the azea. They wondered whether any native forb species would contribute 3% relative cover. This is something that can be evaluated and revised in the permit. However, USFS agreed to allow the following forb species to be included in the seed mix: coreopsis lanceolata, Lupinus azgentus, Phlox dnunmondii, Thermopsis montana, Penstemon palmeri (or strictus), Vicia americanus, and Achilles millefoluim var. occidentalis (in very low rates). USFS said they may consider other species native to azea. A revised seed mix, including all or a combination of these forbs, will require a minor revision from the Division with concurrence from the USFS. It may also be worthwhile to reevaluate the species diversity standazd for the USFS lands. This could be done as a sepazate revision or in conjunction with a midterm or permit renewal.