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(based on only 5 sample transects). Sun's 1994 study found 47.3% cover. Neither species <br />composition nor cover appear to have changed significantly during recent years, although <br />cover was probably unusually high during the 1995 bond release inspection, due to the <br />very wet spring. The summer of 1994, when Sun conducted their study, was an unusually <br />dry year. The Division observed a portion of Sun's sampling during an August, 1994 <br />inspection. Their sampling methodology agreed with what was reported in the bond <br />release application, and also appeared to be in accordance with methods suggested in the <br />Division's revegetation guidelines and the permit application package. <br />Site inspections during 1995 found the vegetation on the reclaimed area had responded <br />very favorably to the exceptionally wet spring and summer weather. Vegetative cover on <br />some of the northern portions of the mine and the former topsoil stockpile area was very <br />heavy. Several small and isolated areas with more sparse cover were also observed. <br />Cover on the remainder of the area was fairly uniform, as was the species composition. <br />The permit application package indicates vegetative cover on the Eiltses' reclaimed <br />property will be compared to vegetative cover in the Mountain Brush Reference Area, <br />minus the tree component. Sun Coal estimated vegetative cover on the Eiltses' property <br />to be 42.3%. Cover in the Mountain Brush reference area, minus trees was estimated <br />by Sun Coal to be 35.0%. However, the bond release application lists Amelanchier <br />alnifoGa (Serviceberry), Prunus virginiana (Chokecherry), and Quercus gambelli <br />(Gambel's oak) as trees. The Seneca II Revegetation Monitoring reports prepared by <br />ESCO and Associates (the source of the data in the bond release application), the Seneca <br />II permit vegetation baseline section, and the Meadows No. 1 Mine permit application <br />package (pp.126-27) all refer to these species as shrubs. The Division has historically <br />considered these species to be shrubs, not trees. <br />When cover from these species is included in the vegetative cover component for the <br />mountain shrub reference area, the vegetative cover success standard is 90 % of 63.4%, <br />or 57.1%. Vegetative cover on the Eiltses' property is less than 90 percent of the <br />applicable success standard at the 90 percent confidence level. Therefore, the portion <br />of the Meadows No. 1 Mine owned by the Eiltses does not currently qualify for Phase II <br />bond release. The bond release also estimated that bare ground accounted for 27% of <br />the Eiltses' property, whereas 21% of the Grassy Creek reclamation was bare ground. <br />Vegetative cover appears to be significantly lower on the portion of the Eiltses' property <br />north of the sediment ponds. This area would probably benefit from additional <br />husbandry practices, such as interseeding, to improve the vegetative cover and erosion <br />control. <br />Species diversity on the Eiltses' property meets the relevant standard, with one very slight <br />variance. The five most prevalent species on the Eiltses' property account for 80.2% of <br />relative cover while the permit indicates no five species shall account for more than 75% <br />cover. <br />Meadows Na 1 Mine 6 Phase 11 Bond Release <br />