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Cathy Begej - 2 - May 16, 1990 ~~~~ ~ 7. "` Basically, WFC is stating on page 65 that no more revegetation monitoring ,~" will be undertaken until it is required as part of a Phase III bond release. To date they have sampled cover on the 1981 re vegetated area twice (9/22/83 - 3 transects; 9/21/89 - 5 transec ). They have also ~~ sampled the 1987 revegetated area twice (10/26/(i 9 transects ~~~~ .a-~? a 9/21-22/89 - 5 transects) and have sampled the reference area once (9/21-22/8 - 5 transects). This falls short of the biannual cover ~ u~„ sampling committed to in Addendum 2 ("... first cover transects will be ` run during September 1982 and in two year intervals thereafter"), the cover and production sampling in years 1, 3, and 5 committed to in the 8/19/81 letter from David Stout to Richard Daninque, and the program referenced in the newly submitted additions to Appendix F ("This assessment [carried out on 9/22/83] is part of our permit stipulation to do a biannual revegetation success evaluation at the Walden property"). Furthermore a letter to Rich Dominque dated 12/30/81 which is part of the ~ "Communications" section of the permit application commits to "two year 9 3 evaluation studies" of cover and diversity with submittal of a report as ~5 follows: .~ ~ " ~ Wy aping Fuel Company will report the results of our data collection to 4' } the Division within three (3) months after it has been collected. The ~~ , report will include data on relative cover and species composition and a ~ summary of how revegetation is proceeding in meeting the premining ~<<~ vegetative success standards. Furthermore, the report will emphasize those revegetation techniques which are proven to be successful and those ~~ ~~ which are unsuccessful. The general condition of this vegetation will also be reported, i.e. weed invasion and the necessity for weed control, ,; ' competition among species and indicators of the survival of species and species vigor." No such report has been submitted to my knowledge. I suggest that WFC be reminded of this commitment as they embark on preparing their first Annual Reclamation Report, due in 1991. Another hot topic which must be . ' addressed in this first Annual Report: How successful has woody plant UX establishment been, and if success is low as expected, how does WFC 0 propose to rectify the situation? Thus, mN recommendations summarize as follows: 1. Violation for not meeting the requirements of their monitoring commitment should be withheld if they commit to 4th year (1991) data collection on the 1987 reclaimed area. 2. Their description of monitoring reports included above should be followed as they prepare the 1990 ARR. Rule 2.04.13(2) states: "The permittee may provide additional monitoring information as required byihe approval permit." Thus, the information they previously committed to justifiably should be included in this first ARR. Additionally, they must address their lack of woody stems establishment success. With the acceptance of these two requirements, I consider their response adequate.