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Woody-plant density was 4116 stems/acre in the Pinyon juniper and 5261 stems/acre bottomland (analyses included snakeweed as a woody plant species). Comparison with neazby mine (Rimrock) in similar plant community types and same post-mining Land-use. Reclamation success standards: Cover = 41 % vegetative cover Production = 514 lbs./acre herbaceous cover Diversity =Three species of perennial grasses each contributing a[ least 3% relative cover but no one species exceeding 60% relative cover. One species shall be a warm season grass and one species shall be a cool season grass. No woody plant density is required. The woody plant density requirement was reduced based on the landowners request in writing, and the Division's finding that grass dominated small azeas surrounded by the dense Pinyon-juniper undisturbed cotrtmunities aze beneficial. Review of the "pre-permit" sampling data and standards set for permitted mines in the general vicinity do not indicate that the cover standard should be lowered. Cover needs to be suitable to control erosion (Rule 4.15..1(2)(b)). Considering that the pre-mining area likely had at least 31% cover, based on the "pre-permit" data, the Division may have a difficult time reducing the cover standazd further and still be able to show erosion can be controlled. I suppose we could calculate out what the minimum required vegetative cover could be based upon erosion models, yet 90% of 25% allows for only a 22.5% vegetative cover. Initial vegetative sampling conducted by the operator three yeazs afrer seeding indicates that the operator has already exceeded the 25% vegetative cover on the reclaimed areas of the mine. The productivity standard is already considerably lower than the soil suitability estimates. The Raton Creek productivity standard is also considerably lower that the productivity standazd set for the neighboring mine. If we use the IvTRCS feeding rate of 1200 lbs. air dry forage per AUM, three hundred pounds herbaceous production per acre would allow for 1 AUM for every 4 acres of reclaimed land. Total reclaimed area of 30.6 acres (from database) would allow for a stocking rate of only 7.65 AUM. The Division would have a difficult time reducing the productivity standazd. The diversity standazd requires 5% of the vegetative cover to be attributed to shrub species. This may be a difficult standazd to achieve depending on how successful shrub establishment is. The woody plant density standard is 500 stems per acre. If any of the vegetation success standards are changed, this is the one the Division may want to reconsider. Due to the limited size of the disturbed azea, and the heavy pinyon-juniper community surrounding the mine site, maintaining a shrub establishment standazd may not be necessary. If the operator wishes to vary this standazd, a written agreement from the landowner would be necessary. At this point in time, unless the operator requests a reduction is success standards, it does not appeaz that the approved success standazds aze overly stringent. C:\jhb\team\raton creek\vegstds.doc