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Preliminary Adequacy Review Bear Coal Co., Inc. - Bear Mine Page Nine 2. The inclusion of the statistical methods for determining revegetation success on page 73 is rather confusing, since these methods are used to analyze reference area and pre-mining data. The applicant has not established any reference areas, and no quantitative vegetation data has been collected. In order to use reference areas for the determination of revegetation success, a separate 2-3 acre area of undisturbed vegetation would have to be located that corresponds to each vegetation type disturbed by surface operations. Intensive sampling within the permit area would be required to show that the chosen reference areas are, indeed, representa- tive of vegetation that occurred on the site prior to disturbance. 3. Due to the existing disturbance, the relatively small area involved, and the lack of any pre-mine vegetation data, the applicant should consider using one of the approved methods under 4.15.7 instead of reference areas for demonstrating revegetation success. The applicant may either propose specific standards for the various parameters based on applicable SCS range site descriptions or other technical documents, or request that the Division set the success standards based on local environmental conditions and available data for similar sites. 4. The applicant must submit a discussion of the sampling methods to be used in the measurement of all applicable parameters as required by 9.15.7(1) and 4.15.7(2)(b). Specific information regarding the sampling scheme to be employed, such as length of transects, size of plots, etc., is required. The Division requires that individual sampling units be located randomly within the reclaimed area. A demonstration that sample adequacy has been achieved for each parameter is required. The Snedecor- Cochran sample adequacy formula is recommended. Parameters should include percent woody cover, percent herbaceous cover, herbaceous production, and woody plant density. Cover data should be taken by species, to allow a determination of species' composition and diversity. Production data can be Lumped by life form. 5. No specific monitoring plan has been proposed for the reclaimed area prior to the final two years of the 10-year liability period. Periodic monitoring prior to bond release is strongly recommended so that appropriate measures may be taken if it becomes apparent that the revegetation will not be able to meet the applicable success requirements. The applicant states that "no pest or disease control measures are anticipated." This is not sufficient. The applicant should propose a weed control plan that would be enacted contingent upon findings of revegetation monitoring. ~ 2.05.5 Post-Mining Land Uses 1. No documentation of alternative post-mining land uses was submitted. Therefore, all of the land in the existing permit area must be reclaimed to a post-mining land use of rangeland and wildlife habitat. 2. A copy of comments from the legal or equitable owners of record of the surface, ARCO, U.S. Steel and the Colorado State lfighway Department, must he submitted. The owners must be agreeable to the post-mining Land use of grazing or wildlife habitat. If the owners will not agree to total reclamation as stated, then an alternative reclamation plan and post-mining land use section must be provided to the Division.