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j, < ~ <br />• Carol Russell -2- July 27, 1982 <br />Stipulation No. 7 <br />P&M is proposing a diversity standard based on the Shannon-Weiner diversity <br />index. They have evaluated the species importance of all species in the <br />pre-mine vegetation data to develop weighted diversity values over the <br />permit area. For each species in the permit area, the percent contribution <br />to diversity was calculated. There are 19 species that make up 750 of the <br />total diversity. Of these, 43% are shrubs, 25a are forbs and 32o are <br />grasses. P&M proposes to reestablish approximately IS plant species in the <br />reclaimed area composed of 2% shrubs, So forbs and 93% grasses. <br />The reason for the shrub decrease is supported in the stipulation response <br />by a reduced shrub density standard. A reduction in stem density is <br />acceptable, but not down to the 500 stems/acre.P&ri has pro nosed. Therefore, <br />upon reevaluation of the shrub density standard, the 2"o shrub contribution <br />will need to be changed. P&Ff should also commit to establishing at least <br />2 shrub species. <br />The reduction in the forb contribution is based on the availability of seeds. <br />P&M maintains that native forb seeds are difficult to get, expensive, and <br />some are undesirable for grazers. The justification fnr ;:he large reduction <br />is unacceptable. Seeds for desirable native forbs arc available and do not <br />have to be planted in large quantities. <br />• The grass figure, 930, should be categorized and broken down to include <br />seasonality, growth form, and origin. For example: perennial natives, cool <br />season, perennial natives roarm season, introduced cool season, introduced <br />warm season and annuals. <br />To adequately answer Stipulation No. 7, P6M needs to: <br />1. Reevaluate the 2% shrub contribution; <br />2. Commit to establishing at least two shrub species; <br />3. Reevaluate the forb component; and <br />4. Categorize the grass component as discussed above. <br />P&M has chosen a complicated method for evaluating diveriity. They may <br />want to consider the species composition approach the Division is recommending <br />for many other mines. I would be happy to explain this to them. <br />Stipulation No. 8 <br />P&M is required to establish a success standard in the !:'est Ridge area <br />capable of preventing erosion. The West Ridge area is a previously mined <br />area that is being redisturbed to mine a lower seam of coal. <br />Vegetation studies on the old spoils indicate a 47o plant cover has been <br />achieved by three introduced species: smooth brome, intermediate wheat- <br />grass and crested wheatgrass, The 47~ cover is adequate to control erosion <br />. according to P6M. However, cover valued in the pre-mine areas are much <br />higher at P6Af. At an adjacent CYCC mine, some vegetative cover values are <br />in the 40's so 97% should be adequate to control erosion. The west Ridge <br />areas PS14 sampled should be checked to verify that there are no erosional <br />problems. <br />~: <br />