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information provided in the permit application and a review of this site, the Division <br />recommended the following criteria, which were agreed to by La Plata Coal Corporation. <br />• For all areas, except those south of La Plata County Road 120, the success criteria of <br />Rule 4.15.10 aze applicable. These azeas were disturbed prior to the enactment of the <br />law (C.R.S. 34-33-101 et seq), were abandoned by the previous coal operator <br />(Sunbelt Mining, Inc.), and were never reclaimed to current revegetation standards. <br />Therefore, the requirements of reclaiming previously mined azeas as presented in <br />Rule 4.15.10(1) were applicable. In the approved permit, a minimum cover standard <br />of 70 percent was established. <br />The permitting files and records are uncleaz as to how the 70% cover standard was <br />established. A cover standazd of 70 percent is unrealistic and out of the range of <br />revegetation capabilities of this particular area. The surrounding vegetation at the <br />reclaimed mine site is apinyon-juniper forest. The Division conducted additional <br />reseazch in an effort to find data describing pinyon juniper forests in terms of cover and <br />productivity. <br />The La Plata # I Mine had been in existence since the eazly 1900's. Consequently, the <br />mine facilities had been previously disturbed and no site-specific data was collected. The <br />reclaimed area sampled in 2003 is on asouth-facing slope, surrounded by a pinyon- <br />juniper forest. No topsoil was salvaged or replaced and soils are rocky. Slopes average <br />about 15-20%. <br />The most comparable range site is the Stony Foothills range site of the Southern Rocky <br />Mountain Land Resource Area. The site is a grassland plant community with small <br />amounts of shrubs, pinyon pine and Utah juniper. The optimum ground cover is 25%. <br />In favorable years the total annual production is 800 pounds per acre. <br />Baseline data from the Carbon Junction Mine describes two mature pinyon juniper <br />woodland communities. The pinyon-juniper woodland occurs on moderate to relatively <br />steep slopes on coarse and/or shallow substrates. The dominant species in this type are <br />pinyon pine and Utah juniper, which occur in moderately dense to open stands. The <br />understory includes numerous species of shrubs as well as forbs and grasses, although the <br />latter contribute little cover. Absolute cover averages 47.3%; trees contribute 60% of the <br />relative cover. The total average production was about 200 lbs/acre. The tree density is <br />275 trees/acre and shrub density is 770 shrubs/acre. The total stem density is 1045 <br />stemslacre. The second pinyon juniper woodland is called the caprock phase. The <br />caprock phase of the pinyon-juniper woodland, is differentiated by an extensive <br />sandstone caprock which varies from lazge azeas of bare, relatively unbroken rock to <br />areas of shallow rock fragments. Shrubs aze less important in the Caprock unit. <br />Herbaceous vegetation grows well in cracks and crevices of rock, where the runoff <br />collects. Total absolute cover is 33.2%; trees contribute 50% relative cover. The average <br />production was 205 lbslacre. Shrub density on this type is 235 shrubs/acre and tree <br />density on the caprock type is 175 trees/acre for a combined woody plant density of 410 <br />stems acre. <br />La Plata # 1 Mine Page 3 <br />2003 Vegetation Sampling <br />