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There is no woody plant standard on the Grassy Creek property. The standard on the <br />Eiltses' property is 500 stems/acre. Sun did not report woody plant results in the bond <br />release application data. Woody plants did not account for any of the cover encountered <br />in the sampling on the Eiltses' property. Very few woody plants were observed during <br />Division inspections of the reclaimed area, other than isolated occurrences of Wood's <br />Rose, serviceberry, snowberry, and chokecherry. <br />Erosion and Deposition <br />At the Meadows No. 1 Mine, there is no available baseline data regarding sediment <br />contribution. Adjacent nonmined areas are inordinately dissimilar in vegetative type. <br />Nonmined areas are characterized by a dense cover of shrubs, with sparse grass and forb <br />understory and thick ground litter. The pit area, at the request of the landowner and <br />with the approval of this Division and the Colorado Division of Wildlife, has been <br />reclaimed for use as rangeland with no shrub component. Vegetation on the reclaimed <br />azeas consists mainly of grasses, rendering comparisons of the two areas questionable. <br />Sun submitted a demonstration that, when compared to the approved reference azeas, <br />reclaimed areas would not contribute solids in excess of that estimated for the reference <br />areas. The demonstration used the Revised Universal Soil Loss Equation (RUBLE), and <br />information taken from quantitative data collected at the site. The Division questioned <br />some values Sun had used in the equation. Specifically, the Division questioned the <br />operator's assignation of values representing the vegetation type and cover of the sites. <br />After a discussion with the operator concerning these values, the Division found that the <br />equation itself was not effective in estimating erosion caused by sheetflow over the <br />reclaimed area. The equation is based on an assumption of concentrated flow features, <br />as opposed to the sheettlow that is evident at the site. The Division determined it would <br />be more appropriate to make a determination regarding sediment contribution by visiting <br />the site and making visual comparisons between the reclaimed area and adjacent, <br />nonmined areas. <br />On August 28, 1995, the Division conducted a site inspection for the purpose of <br />determining the soil stability of reclaimed areas. The Grassy Creek property, the <br />Sage/Grass Reference Area, and an adjacent non-mined area were inspected. The <br />Division's observations were that most of the reclaimed area had an adequate cover of <br />vegetation and litter to effectively preclude any significant loss of soil from the reclaimed <br />area. A considerable amount of erosion had occurred in the past on portions of the <br />reclaimed area with lesser vegetative cover, but there is little evidence of ongoing soil <br />movement in these areas at this time. Supporting this finding were the low frequency of <br />observed soil pedestals, with none found to be higher than 1 inch; the absence of gravel <br />deposition on soil pedestals, and the presence of a fairly uniform distribution of gravel <br />size particles on small areas with minimal vegetative cover; and the lack of headcutting <br />and the presence of vegetation in existing erosional features. <br />Meadows No. 1 Mine 7 Phax II Bond Rclcax <br />