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$2,376,000, a total FW reduction of $6,205,500. <br />3.10 General Issue: Revegetation Failure Rates <br />DMG uses a 50 percent revegetation failure rate as a "one size fits all" standard in <br />FW calculations for operations under its jurisdiction. Henderson questions the <br />rationale for this figure at CMC operations. Past monitoring of both plots and <br />actual revegetated areas has found no evidence of a 50 percent failure rate. Even <br />long-term monitoring of the Urad site, reclaimed without maintenance for more <br />than 20 years, has revealed nothing even remotely close to 50 percent failure. <br />Urad was seeded by broadcast only once and maintenance fertilized by air once. <br />Vegetation monitoring at that site was revisited in 1989 by Dr. M.J. Trlica of <br />Colorado State University who found no indications of failures. Dr. Trlica stated, <br />"Seeded grasses are well established and produce more forage than in a nearby <br />burned-over spruce-fir community. Cover of vegetation on reclaimed tailings <br />equals or exceeds that of the native plant community.° (Exhibit I). <br />Likewise, when Henderson 2000 was completed, 33 acres along the conveyor <br />route were hydroseeded. Much of this acreage was along steep cuts and rocky <br />slopes. During the summer of 2000, this area was evaluated for success, and <br />only 3 acres had failed and required reseeding. This is a 9 percent failure rate. <br />Documentation is found in Exhibit I. <br />At Climax, Habitat Management, Inc. (vegetation monitoring consultants) is in the <br />process of preparing documentation for surety release for revegetation. Thus far, <br />their conclusions find no failure areas other than rill and gully erosion sites that <br />also have been noted in past DMG inspections and repaired by Climax. Even <br />extreme slope revegetation that was hydroseeded one time more than 20 years <br />ago along Climax's steep west interceptor system has not failed. <br />CMC and Henderson believe that each operation must be reviewed and evaluated <br />on its own merits regarding revegetation failure rates. Some sites may, indeed, be <br />near the 50 percent level, while others may be near 0 percent. The track record for <br />revegetation success at Henderson over its 25 year history is exceptional. <br />Henderson believes that a 10 percent failure rate is significantly more accurate <br />than DMG's 50 percent rate and is more than adequate to cover failure costs. <br />Changing from 50% to 10% on the 20 DMG spreadsheet task items regarding <br />revegetation results in a reduction in the total FW of $346,928. <br />73 <br />