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~I ^ f <br />• <br />• <br />is a hypothetical scenario of best potential. In addition the <br />range description indicated that as you progress further south in <br />the state the warm season cover component increases. <br />With this in mind, the operator gave no prior indication that they <br />intended to reestablish a cool season range condition to more <br />closely resemble that community which may have existed prior to <br />overgrazing but in fact just the opposite would seem to be the <br />case. Their seed mix included a number of warm season species and <br />they agreed to reestablishing warm season species as evidenced by <br />their diversity standard. They also never contemplated an overall <br />range management scheme whereby they would provide some sort of <br />cool season alternative to all the warm season grasses that <br />surround the reclaimed area( ie; a cool season pasture would be <br />established to provide early season grazing for cattle). This is <br />allowed for in the regulations but it should be proposed during <br />development of the reclamation plan not after vegetative <br />establishment. The fact is that they seeded the area with every <br />intention of establishing warm season grasses but when they sampled <br />recently they discovered that they did not have the warm season <br />component they were required to have. Now they want to change <br />their diversity standard to match what is on the ground. The <br />appearance is that they have done absolutely nothing to enhance the <br />establishment of warm season grasses. <br />The revision as proposed should not be approved, however, we can <br />make changes to the standard that will more closely resemble the <br />reality of the reference area and the community that in all <br />likelihood existed prior to the mining disturbance. Therefore, I <br />propose the following diversity standard; Two perennial cool season <br />grasses and two perennial forbs with at least 3$ but less than 40~ <br />relative cover, any combination of perennial warm season grasses <br />with at least 6% relative cover and no upper limit, and an average <br />of 333 shrubs per acre consisting of at least two or more shrub <br />species. Any reference to the postmining land use being <br />pastureland should be deleted and rangeland reinserted. <br />In addition the operator should submit a plan to try and increase <br />the warm season component. This could include early season <br />grazing, interseedinq, or any combination of treatments that <br />demonstrate the ability to establish warm season grasses. If this <br />activity fails the Division would be open to revisiting this issue <br />in the future and working with the operator to develop a grazing <br />plan that incorporates the use of the cool season reclaimed area to <br />compliment the grazing practices of the landowner. However, until <br />a diligent effort has been made to establish what is proposed in <br />the approved reclamation plan no substantial changes should be made <br />to the diversity standard. <br />If you have any questions or require additional information, please <br />see me. I would also be available to meet with the operator to <br />discuss this revision in more detail. <br />AJW/ajw <br />