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• INTRODUCTION Background in a previous report "Species Diversity Success Standard" dated October 25, 1982, Harner-White Ecological Consultants, Inc. (HWEC) reco~nmended that Colorado Westmoreland, Inc.'s (CWI) Orchard Valley Mine adopt a species diversity success standard which set forth the minimum relative composition of reclaimed vegetation. Specifically, that the 5 herbaceous species have a relative composition value of 3 percent or greater. No maximum value was set because it was felt that none was needed or warranted. This was then forwarded to the regulatory authority for approval and comment. On November 12, 1982, Sandy Emrich, Reclamation Specialist, Colorado Mined Land Reclamation Division (CMLRO) commented concerning the species diversity success standard prepared by HWEC for CWI's Orchard Valley Mine. Under item #3 of an interoffice memo, Ms. Emrich stated that to satisfy the requirements of the stipulation concerning the species diversity success standard, maximum values for • relative cover of the seeded species would be required. Specifically, that "the 5 herbaceous species combined will not exceed 75~ in relative cover or production and that anyone of the 5 species will not exceed 40% in relative importance." Ms. Emrich further stated that if CWI commits to these criteria, the stipulation would be satisfactorily resolved. In a telephone conversation with Ms. Emrich, Richard Harner, Senior Ecologist HWEC, expressed CWI's concerns regarding the criteria of item #3. These concerns involved the actions CWI would have to take if the criteria of item #3 were not met and the seeded species exceeded the relative composition amounts specified prior to bond release. Ms. Emrich stated that certain actions would have to be undertaken by CWI to alter the relative composition. It was pointed out that this action would act to modify the revegetation which under current law would restart the 10 year tine clock for bond release which in turn may not be desirable for CWI. The conversation concluded that CWI could present alternative approaches to the species coin position and that each would be considered on their own • merit. 1 a.