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S ?~ HARNER & ASSOCIATES INCORPORATED (303) 794-5201 5721 S. SPOTSWOOD ST. LITTLETON, COLORADO 80120 September 29, 1986 Colorado Westmoreland Inc. Attn: Kathy Welt P.O. Box 1299 Paonia, CO 81428 III IIIIIIIIIIIIIIII ~~. . ; J... .. .._ .. .. 9S6t 0 ~ d3S ~'l". .~~.. .. ....._. .. ..__. . ~ ~ Dear Kathy, I have reviewed the previous information concerning the adoption of a vegetation cover success standard and can make the following recommendation. The state of Colorado, Mined Land Reclamation Division recommends that a cover standard be adopted that is equal to or exceeds the existing vegetation cover of the premining site. For the Orchard Valley Mine West site this would be 70 percent total vegetation cover. I cannot recommend to CWI that they commit to establishing a vegetation cover that has 70 percent ground cover because I believe that the possibility of establishing such a cover within the 10 year bond release time frame is highly improbable. Establishing a 60 percent ground cover within the 10 year period is more probable and establishing a 50 percent ground cover is possible. I offer the following as justification for my conclusions. The current vegetation consists of a triple canopy vegetation dominated by tall shrubs (principally oakbrush and serviceberry) forming the upper canopy, low shrubs (principally snowberry)forming the mid layer canopy and the herbaceous layer forming the lower canopy. This triple canopy has developed over many years to make maximum utilization of niche space. Reclamation of the area will consist of a partial two canopy community at the time of bond release. The herbaceous layer will be the dominant layer and a growing layer of shrubs will be clustered in limited areas forming the upper canopy. These shrubs will not mature for at least another 10 to 20 years. Besides it is the design of the revegetation to be a more open community making it more accessible to wildlife. In fact the Colorado Division of Wi]dlife is currently encouraging CWI to burn additional areas around the proposed mine site to open (ie. reduce the cover) the vegetation and improve wildlife habitat. Previous studies conducted at the Orchard Valley Mine indicate that total cover of revegetation on areas where the vegetation appeared to have a good establishment averaged slightly over 60 percent (Harper 1982). These areas were seeded in 1978 and studied in 1982. The majority of the sites were on fill slopes with favorable aspects.