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Discussion of ReasoningJor Old V~etation Standard <br />In 1981, the year that the mine was permitted, the main concern of the company was to <br />secure the permit and mine coal. No mines at that time were thinking about details of <br />the reclamation process; they and the Division were barely getting underway with the <br />new regulations. No mines had begun the reclamation process at that time. <br />Since the mine was started in the 1950's, many years prior to the reclamation act, the <br />site was entirely disturbed at the time of permitting and no baseline vegetation data <br />could be obtained from the actual permit area. SMC asked the Division to set a <br />standard for the site. <br />As stated in Old Discussion -Determining Revegetation Success, "Trout Creek appears <br />to have followed many channels throughout the valley.... thereby creating a swampy <br />and wet environment. Plants in the area adjacent to the Mine -cottonwoods, willows <br />and various sedges are all indicative of high moisture levels in the valley bottom." <br />It appears that the thinking that this site would be restored to a "valley bottom" was <br />important in selecting a cover standard for the restored valley bottom of 70%. This is <br />the highest cover standard for any coal mine in Colorado, not to mention pre-law sites <br />• that never salvaged any topsoil. <br />The baseline data in the permit on page 96 for range descriptions also describes the <br />pre-mine area as mountain meadow with deep soils, high moisture plants and an <br />optimal cover of 70%, which is equal to the vegetation standard. [n any case, it is clear <br />that the vegetation standard was based on conditions in the pre-mine valley bottom, but <br />did not take into account the changes in the to-be reclaimed minesite and this pre-mine <br />valley bottom. <br /> <br />DEC 2 1 1998 <br />Revised 6:10'98 184-11 <br />T2-!d <br />