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Reasoning for New Standard (Includes 2002 Revision to Species Diversitr1 <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 reclaiming <br />the site. This is better than nothing but is certainly much less than that which existed prior <br />to mining. According to the information in the baseline section of this permit and site <br />investigations upstream and downstream, the soil on the undisturbed areas is 30-50 inches <br />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 resulted <br />in many plants dying. The material underlying the 6" of soil is the original coaly yard <br />material that was present during mine operation. Soil samples enclosed in this section show <br />a very high Organic Matter (OM%) in the subsoil samples; this material is not good <br />organic matter. It is coal. For anon-irrigated rangeland, this must be considered a poor soil <br />condition. <br />3) At the time the mine was started, there was no requirement to salvage topsoil. Coal and <br />shale from the portal areas was excavated from the outcrop and placed in the valley bottom <br />where the mine office remains. This is the reason why the terrain in the mine yard area is <br />approximately 6 feet higher than the surrounding area upstream and downstream of the site. <br />This area cannot be compared to the surrounding valley bottom, where the water table is <br />only 2 feet below the ground surface - as was found during well drilling on the Baumgartel <br />property in 1997. The reclaimed minesite is therefore 6 feet higher (with lousy soil) which <br />means it cannot tap the shallow water needed to overcome the dry summer conditions. The <br />minesite is not a total disaster; it will grow good perennial species, it simply cannot be <br />expected to achieve a 70% cover under these 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 nearby. <br />This rangesite is in deep soils with very moist conditions. The optimal cover listed for this <br />rangesite is 70% which is also the cover required for the mine reclamation, although the <br />two sites are not comparable. <br />5) The SCS rangesite cover data says that o tp imal cover for the mountain meadow is 70%. <br />When the SCS measures cover, they use a visual method which tends to be considerably <br />higher than that cover actually recorded with the optical point frame. The optical point <br />frame is unforgiving, especially with grasses which grow vertically and provide much less <br />vertical intercept than shrubs or forbs which are present to a greater extent in the pre-mine <br />communities. Also, the SCS cover estimates do not take into account that one plant lying <br />over another does not count in the optir~`tal point frame studies done for DMG bond release. <br />Also, annual plants do not count for the DMG but they are considered for the SCS <br />estimates. These items mean that, according to DMG standards, the cover in the mountain <br />meadow range site is less than 70%. The exact amount is unknown. Pat Davey, the local <br />Soil Conservation Service soil scientist, has been to the site three times and has been <br />present while soil cores were taken throughout the yard area. He was also demonstrated the <br />TR May 2002 184-12 <br />