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• Reasoning for New Standard <br />1) The mine is a pre-law mine and no topsoil was ever salvaged. Although the DMG <br />cannot force an operator to import soil, SMC committed to import 6" of soil for <br />reclaiming the site. This is better than nothing but is certainly much less than that which <br />existed prior to mining. According to the information in the baseline section of this <br />permit and site investigations upstream and downstream, the soil on the undisturbed <br />areas is 30-50 inches deep. <br />2) Although the site gets adequate winter moisture in the form of snow, summers at the <br />site have been very hot and dry and the poor rooting depth of only 6" of soil has <br />resulted in many plants dying. The material underlying the 6" of soil is the original <br />coaly yard material that was present during mine operation. Soil samples enclosed in <br />this section show a very high Organic Matter (OM%) in the subsoil samples; this <br />material is not good organic matter. It is coal. For anon-irrigated rangeland, this must <br />be considered a poor soil condition. <br />3) At the time the mine was started, there was no requirement to salvage topsoil. Coal <br />and shale from the portal areas was excavated from the outcrop and placed in the valley <br />bottom where the mine office remains. This is the reason why the terrain in the mine <br />yard area is approximately 6 feet higher than the surrounding area upstream and <br />• downstream of [he site. This area cannot be compared to the surrounding valley bottom, <br />where the water table is only 2 feet below the ground surface - as was found during <br />well drilling on the Baumgartel property in 1997. The reclaimed minesite is therefore 6 <br />feet higher (with lousy soil) which means it cannot (ap the shallow water needed to <br />overcome the dry summer conditions. The minesite is not a total disaster; it will grow <br />good perennial species, it simply cannot be expected to achieve a 70% cover under these <br />conditions. <br />4) It appears that the DMG in 1981 selected cover data for the mountain meadow range <br />site from baseline data from the existing permit and from the P&M Mt. Edna Mine <br />nearby. This rangesite is in deep soils with very moist conditions. The optimal cover <br />listed for this rangesite is 70% which is also the cover required for the mine <br />reclamation, although the two sites are not comparable. <br />5) The SCS rangesite cover data says that o to imal cover for the mountain meadow is <br />70%. When the SCS measures cover, they use a visual method which tends to be <br />considerably higher than that cover actually recorded with the optical point frame. The <br />optical point frame is unforgiving, especially with grasses which grow vertically and <br />provide much less vertical intercept than shrubs os forbs which are presenbt to a greater <br />extent in the pre-mine communities. Also, the SCS cover estimates do not take into <br />account that one plant lying over another does not count in the optimal point frame <br />studies done for DMG bond release. Also, annual plants do not count for the DMG but <br />they are considered for the SCS estimates. These items mean that, according to DMG <br />standards, the cover in the mountain meadow range site is less than 70%. The exact <br />amount is unknown. Pat Davey, the local Soil Conservation Service soil scientist, has <br />Mid-Term Review 3/21/01 184-12 <br />'L. <br />