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MCKINLEY HINE: VEGETATION BOND RELEASE CRITERIA <br />BASED ON SOIL CONSERVATION SERVICE TECHNICAL GUIDE <br />RANGE SITE DESCRIPTI ONSI <br />Wayne R. Erickson2 <br />Revegetation success standards using locally ad- <br />justed Soil Con serva[ion Service Technical Guides (WP-1) <br />in conjunction with Order III Soil Surveys were esta- <br />blished during [echafcal review of a permanent program <br />permit application for The Pittsburg d Hidvay Coal Min- <br />ing Co.'s McKinley Hine. Regulatory acceptance of these <br />standards suggests that vege[a tlon baseline studies for <br />[he estab li shmen[ of revegetatlon success criteria may <br />be unnecessary if SCS Range Site Descriptions are avail- <br />a61e. <br />INTRODUCTION <br />Permit ing History <br />In 1980 The Pittsburg E Hidvay Coal Mining Co. <br />(P6M) submitted a permanent program permit applica- <br />tion to the Office of Surface Mining (OSM) and the <br />Nev Hexico Mining and Miners is Division (MMD) for <br />the McKinley Mlne, McKinley County, Nev Mexico. <br />Nhen vegetation baseline data vas collected for <br />this application, no published guidelines existed <br />for [he Sta [e of Nev Mexico. in the absence of <br />Nev Mexico guidelines, vegetation baseline data <br />for [he mine using reference areas vas collected <br />under a combination of guidelines drawn from [he <br />Wyoming Department of Envl ronmen[al Quality and <br />the Montana S[a [e Land Department programs. Sioce <br />technical review of [he 1980 permit application <br />vas never completed, the technical adequacy of <br />this information vas never determined. <br />P6M submitted a revised permit application [o <br />[he regulatory aut hor ides in July 1983 based on <br />the addition of a [ruck/shovel prestrlpp ing opera- <br />tion and changes in mining sequ en clog. During tech- <br />nical review of this permit application the vege- <br />1Peper presented at the 1985 Mnual Heating of <br />The American Society for Surface Mining and Recla- <br />matio2n, Denver, Colorado, October 7-l0, 1985. <br />Payne R. Erickson, Envi ronmen [al Specialist, <br />The Pittsburg 6 Hidvay Coal Mining Co., Gallup, <br />Nev Mexieo. <br />Cation baseline data collected in 1979 was found to <br />be inadequate. The OSM Indicated that vegetation <br />community types were too general. P6H could no[ <br />persuade the OSM to reconsider this position. <br />There were six commun i[y types in the original <br />baseline data which covered approximately 27,000 <br />acres of lease. The communities included Pinyon/ <br />Juniper Woodlands, Sagebrush, Rebbi[bruah, Crease- <br />wood, Carden Plots and Disturbed Lend. The OSM rea- <br />soned the[ since the community Lypes represented <br />such a large area, chat [he~productivf ty measure- <br />ments were not a true reflection of the areas pro- <br />ductive capacity, nor were [hey a valid indicator <br />of the richness of species diversity. This in turn <br />cast doubt on the validity of revegetatlon success <br />standards. <br />P6M then submitted in [he petmit application <br />package an Historical Data Monitoring pr oposel from <br />which revegetation success standards you ld be de- <br />veloped after the required 7 year mon It or ing period. <br />This method you ld eliminate the need for reference <br />areas and you ld take Sn to account the extreme varl- <br />a6111ty Sn precipitation quantity end distribution <br />[ha[ o[cu rs in [he McKinley Mine region. The M!ID <br />agreed with this approach, but the OSM indicated <br />that this vas oat acceptable. The OSM maintained <br />that success st anderda for revegetatlon must be <br />pert of a permit application package in order for <br />it to be complete. <br />It seemed that an impasse had been reached for <br />ongoing, timely review and approval of the permit <br />application package. A delay of six [o twelve mon [hs <br />for the collection end preparation of edditiooal <br />vegetation information seemed lnevltable. Hwever, <br />review of the permitting regulations (Marlow, Office <br />of Surface Mining 4981 and Nev Mexico Mining and <br />Minerals Div Seion 1980) revealed another poeeib le <br />-11'J- <br />