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Type average only 3.92 percent prior to disturbance. We submit that the baseline data and <br />Division's regulations which require that the reclaimed areas be reclaimed to a higher and lower <br />ecological condition do not support the "5 percent" shrub standard. The approved standard is at a <br />minimum 1.28 times higher than the baseline shrub standard which grossly estimates the total <br />plant cover, since cover was collected by plant strata and does not actually represent type cover <br />nor would be accepted by the Division today. We submit that since the Division's requirements <br />for plant cover sampling methodologies have changed, the approved species diversity standards <br />should be changed also. <br />IME is unaware of any permitted coal mine in Northwest Colorado with any such Species <br />Diversity Standazds and our recommendation.isthat the total grass and total shrub cover <br />standards be changed. <br />Grazing. Concurrent with this sampling effort the Permittee stated that grazing is approved in <br />the Permit and asked that we provide recommendation on possible grazing levels based upon the <br />monitoring data collected from this revegetation sampling effort. According to Table 3, Raton <br />Creek Mine - 2004 Production the average forage production on the large reclaimed block was <br />found to average 1,204 pounds of air dry forage per acre. The area of this reclamation site was <br />calculated with our GPS unit to equa127.0683 acres. This means that on this block alone, there <br />are approximately 32,590 pounds of useable forage. Using the "50 Percent Rule" commonly <br />used in range management, wherein half of the forage is harvested and half is left to maintain the <br />vigor of the plant community this means that there is approximately 16,295 pounds of forage <br />which can be grazed at this site. Using the commonly accepted rule that one Animal Unit Month <br />(AUM) is the amount of forage a mature cow eats in one month and equals approximately 1,000 <br />pounds of air dry forage, there is the equivalent of approximately 16.3 AUM's available at this <br />site. The Landowner has indicated that he had three cow calf pairs and one bull. If all of these <br />animals where to graze the Raton Creek Mine reclamation it would equal -;~.2 AUM's per <br />month. This means that there is approximately 3.9 months worth of graz.:rs from the reclaimed <br />areas at the Raton Creek Mine. <br />These assumptions are very conservative in that they ignore the approximately equal azea or <br />undisturbed rangeland within the fenced area containing the Raton Creek Mine Reclamation. <br />Using the calculated forage production obtained from the original vegetation baseline sampling <br />of 29.74 grams per squaze meter which is equal to 265 pounds of air dry forage per acre. The <br />amount of usage forage on the undisturbed areas within the fenced enclosure is approximately <br />7,155 pounds of air dry forage. This translates into approximately 7.1 AUM's or 1.7 months <br />worth or grazing given the current livestock mix of the landowner. Including this area means <br />there is a total of approximately 41.3 AUM's of total grazing available at this location or <br />approximately 9.8 months worth of grazing. Our recommendation is that grazing be allowed on <br />this site over the winter and that the animals be removed prior to 1 April 2005. <br />8 <br />