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INTEROFFICE MEMORANDUM TO: BYRON W FROM: JANET BIN S SUBJECT: PROPOSED N ~ VEGETATION SAMPLING DATE: 6/1/2005 CC: DAN HERNANDEZ The Pittsburg and Midway Coal Mining Co. (P&M) submitted a proposed vegetation monitoring plan to the Division on April 20, 2005. The Vegetation sampling plan was prepazed by a consultant fox P&M, Habitat Management, Inc. Vegetation data collected in 2005 is planned fox use in final (Phase III) bond release application. There are four azeas proposed for sampling in this proposal These azeas and their associated acreage aze known as: West Ridge-Topsofled (22 acres); Moffat Area-Topsoiled (215 acres); West Ridge-Previously Disturbed (466 acres); and Moffat- Previously Disturbed (224 acres). The total area proposed for sampling under this plan is 928 aces. The Edna Mine began coal extraction prior to the permanent Colorado Act and Regulations fox Coal Mining and Reclamation was enacted in 1981. Those azeas that were active prior to the 1981 Colorado Coal Mining Regulation but not reclaimed until after 1981 are categorized as "Previously Disturbed". Due to the differences in the legal requirements in place at the initiation of disturbance of these areas Rule 4.15.10 applies on these azeas described as "Previously Disturbed" West Ridge-Previously Disturbed Area and Moffat-Previously Disturbed Area both have a reclamation success standazd of 47% live vegetative cover (Permit pages 4.4-1, 4.4-4). No productivity, woody stem density, or speaes diversity standards are required for xeclunation success determination on these two previously disturbed areas. The areas that will be included in the West Ridge and Moffat -Previously Disturbed azeas will include: West Ridge outside of the topsoIled azeas Middle Moffat Haulroad outside of the Out-of--Pit spoil azeas Reclaimed diversion ditch located South of the out-of -pit spoil azeas and Moffat Out-oE pit spoil azea. Vegetative cover will be determined using point-intercept methodology. Habitat Management will use a 10-point frame along 10.M transects. Randomly located transect start points will be detemvned prior to field data collection via a grid overlay on the parcel azeas. Habitat Management proposes to collect cover data to adequacy with a minimum of 15 transects and a maximum of 40 transects. This proposal meets the Colorado requirements and guidelines with one exception. Please note, the Division generally recommends a mitlimum transect length of 25M where pazcel size allows. The Edna permit (page 4.4-23) commits to using 100M long transects for measuring Diversity and Cover. Also Habitat Management needs to be sure to use the appropriate adequacy formula as outlines in the Division's "Guideline Regazding Selected Coal Mine Bond Release Issues" (April 18, 1995, pages 20 and 21). If the data show that the sampled parameter is less that the reclamation standazd, please use the adequary formula shown on page 20 of the referenced guideline. If the reclaimed azea sample data equal or exceed the reclamation success standazd, the adequary formula shown on page 21 of the referenced guideline is applicable. Reclamation pazcels that received topsoil replacement; West Ridge-Topsoiled and Moffat-Topsoiled will also be sampled for reclamation success. Reclamation success standards for these two azeas aze found on page 4.4-1 and page 4.4-22 of the PAP. Reclamation success standards for the West Ridge-Topsoiled azea include: Cover, Production, and Spedes Diversity compazed to reference azea comparisons. Moffat Area-Topsoiled reclamation success standazds consist of Cover, Production, and Spedes Diversity compazed to reference area comparisons, and woody stem density of 1000 stems per acre. Habitat Management, inc. proposes to include sub-shrub spedes in the woody plant density (WPD) values. The Division does not recognize sub-shrub spedes as counting towards the woody stem density standazd. Sub-shrubs may be counted in