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Woody-plant density was 4116 stems/acre in the Pinyon-juniper and 5261 stems/acre bottomland <br />(analyses included snakeweed as a woody plant species). <br />Compazison with nearby [nine (Rimrock) in similar plant community types and same post-mining <br />Land-use. Reclamation success standards: <br />^~`(~ Cover = 41 % vegetative cover Production = 514 lbs./acre herbaceous cover <br />`K' Diversity =Three species of perennial grasses each contributing at least 3% relative cover but no one <br />species exceeding 60% relative cover. One species shall be a warm season grass and one species ~ <br />Review of the "pre-permit" sampling data and standards set for permitted mines in the general <br />vicinity do not indicate that the cover standard should be lowered. Cover needs to be suitable to <br />control erosion (Rule 4.15..1(2)(6)). Considering that the pre-mining area likely had at least 31% <br />cover, based on the "pre-permit" data, the Division may have a difficult time reducing the cover <br />standard further and still be able to show erosion can be controlled. I suppose we could calculate out <br />what the minimum required vegetative cover could be based upon erosion models, yet 90% of 25% <br />allows for only a 22.5% vegetative cover. Initial vegetative sampling conducted by the operator three <br />years after seeding indicates that the operator has already exceeded the 25% vegetative cover on the <br />reclaimed areas of the mine. <br />shall be a cool season grass. <br />No woody plant density is required. The woody plant density requirement was reduced based on [he <br />landowners request in writing, and the Division's finding that grass dominated small areas surrounded <br />by the dense Pinyon-jtmiper undisturbed communities are beneficial _/ <br />The productivity standard is already considerably lower than the soil suitability estimates. The Raton <br />Creek productivity standard is also considerably lower that the productivity standard set for the <br />neighboring mine. If we use the NRCS feeding rate of 1200 lbs. air dry forage per AUM, three <br />hundred pounds herbaceous production per acre would allow for 1 AUM for every 4 acres of <br />reclaimed land. Total reclaimed area of 30.6 acres (from database) would allow for a stocking rate of <br />only 7.65 AUM. The Division would have a difficult time reducing the productivity standard. <br />The diversity standard requires 5% of the vegetative cover to be attributed to shrub species. This may <br />be a difficult standard to achieve depending on how successful shrub establishment is. The woody <br />plant density standard is 500 stems per acre. If any of the vegetation success standards are changed, <br />this is the one the Division may want to reconsider. Due to the limited size of the disturbed area, and <br />the heavy pinyon-juniper community surrounding the mine site, maintaining a shrub establishment <br />standard may not be necessary. If the operator wishes to vary this standard, a written agreement from <br />the landowner would be necessary. <br />At this point in time, unless the operator requests a reduction is success standards, it does no[ appear <br />that the approved success standards are overly stringent. <br />C:\jhb\teanr\raton creek\vegstds.doc <br />