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- 10 - <br />43. Rule 4.15.8(3)(b) identifies cover as being "... either canopy or basal <br />cover of living herbaceous or herbaceous and woody vegetation." Kerr <br />Coal is presently committed to a comparison of total plant cover between <br />reference and revegetated mine areas as a part of determining <br />re vegetation success. The herbaceous layer of the Kerr mine site <br />reference areas often provides only a small amount of cover. Woody plant <br />densities of revegetated areas can be expected to be replaced at levels <br />well below reference area totals. Tables 20, 22, 24, and 26 indicate <br />reference area shrub densities of 23472, 19021, 7689, and 33590 stems per <br />acre for the sagebrush-grass, sagebrush-gravel, treated sagebrush and <br />alkali sagebrush areas respectively. The present standard of 2000 stems <br />per acre does not allow for the replacement of cover on revegetated areas <br />which was provided formerly by shrub species. Furthermore, grasses and <br />fortis on the sagebrush-gravel and alkali sagebrush reference areas <br />provide absolute covers of only 10.4% and 10.5% respectively. <br />The Division believes that to comply with Rule 4.T5.T(2)(b), which states <br />"The vegetation cover shall be capable of stabilizing the soil surface to <br />achieve erosion control equal to pre-mining levels", the shrub layer of <br />reference areas, which provides an important percentage of cover, should <br />be represented in the revegetated areas. Thus, the Division believes <br />that Kerr should continue to commit to a comparison of total plant cover <br />between reference and revegetated areas. <br />44. Presently, Kerr is committed to biennial monitoring of revegetated <br />areas. According to this commitment, Kerr would sample reclaimed areas <br />in years 2, 4, 6 and 8 after seeding in addition to years 9 and 10 which <br />would be monitored in anticipation of potential bond release. The newly <br />submitted revision calls for a minimum of sampling once every 3 years, or <br />in years 3 and 6 in addition to 9 and 10. It is important that operators <br />commit to two monitoring periods prior to the fifth year following <br />seeding. Per Rule 4.15.7(5), the fifth year is the last year that <br />certain re vegetation repair practices may be applied without <br />automatically re-initiating the ten year liability period. Thus, the <br />Division strongly recommends that Kerr Coal commit to vegetation sampling <br />of cover and woody plant density in years 2, 4, and 7. <br />45. Page 2.05.4-30 contains a commitment to reseed live top soiled areas in <br />the ".... unlikely event that re-established vegetation communities in <br />those areas ... do not meet regulatory success standards, ....". The <br />Division requests that Kerr expand the narrative to address when <br />re vegetation success will be monitored on live topsoiled areas, what <br />methods will be used when monitoring, and what level of re vegetation <br />success Kerr will consider to be acceptable. <br />46. The use of living snow fences could possibly increase re vegetation <br />success as Kerr Coal suggests by increasing snow and native seed <br />deposition. Please clarify the following issues: <br />1. Will living snow fences be seeded on areas receiving live handled <br />topsoil? <br />