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Mountain Shrub Habitat is between 400 stems per acre for Rangeland Reclamation Block C&D- <br />A/B and Rangeland Reclamation Block A&E-A/B and zero stems per acre for Rangeland <br />Reclamation Block AC&D-C. For the Edna Mine which is also highly critical Mountain Shrub <br />and Aspen Habitat, the approved shrub standard is zero and 1,000 stems per acre. The <br />predisturbance woody plant density on these two mines were between 8,000 and 16,000 stems <br />per acre. <br />Approval by the Division of a shrub density standard at the Raton Creek Mine of 500 stems per <br />acre which involves a value approximating 75 percent of the predisturbance shrub densities and <br />for the Trapper Mine where the approved Permit Shrub Density Standard (0 and 400 stems per <br />acre) approaches at the low end of the range zero and at the high end of the range only 4 percent <br />of the predisturbance values at the Edna Mine where the approved shrub density standazd <br />approaches at the low end of the range zero percent and at the high end of the range only 6 <br />percent of the baseline conditions is grossly inconsistent. <br />Species Diversity. The approved post mining vegetation type for the Raton Creek Mine (Permit <br />page 522) is as a "grassland." According to the baseline conditions wherein the "grassland" <br />vegetation type was called a "Bottomland Vegetation Type" the predisturbance shrub density <br />values on this vegetation type was only 5.2 stems per 100 squaze meters or 210 stems per acre. <br />These sampling represents the sampling of extremely poor condition grassland, where grazing <br />had significantly increased the shrub component of this site. For the Permit to designate the post <br />mining vegetation type as a "grassland" which possessed a shrub level of only 210 stems per acre <br />and they say that the shrub density standard was to be 500 stems per acre means that the <br />reclamation standard is for these sites to be reclaimed to an even poorer ecological condition <br />class than existing prior to disturbance. Our evaluation of these data is that at a maximum the <br />woody plant density on a "grassland" vegetation type should be no higher than 100 woody plant <br />stems per acre. Therefore, it is our recommendation that Energy Fuels submit these data•to the <br />Division formally requesring a change in the Permit woody plant density standard. <br />The Permit Species Diversity Standazds are also problematic. According to the original <br />Vegetation Baseline Report the Bottomland Vegetation Type which is described on Permit page <br />219 wherein it states that "this vegetation type appears to have been a grassland originally" is <br />totally ignored in the Permit Species Diversity Standazds. Permit Page 224 documents that the <br />predisturbance grass composition of this vegetation type was 12.43 percent for cover and 9.05 <br />percent for production. The Permit commitment to ensure that "gasses" contribute "at least 60 <br />percent of the total vegetative cover" on the Raton Creek Mine is between 4.8 and 6.6 times more <br />stringent that are justified by the baseline vegetation data. These data document that the <br />proposed 60 percent grass standazds is totally unrealistic for this site. <br />The Permit Species Diversity Standard for Shrub Cover, which states that "shrubs" are to <br />contribute "at ]east 5 percent of the total vegetation cover" of the reclaimed areas at the Raton <br />Creek Mine is likewise very problematic. According to the plant composition data found in <br />Table 2 of the original vegetation baseline report, true shrub cover on the Bottomland Vegetation <br />