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INTEROFFICE MEMORANDUM TO: KENT CORHAM FROM: JANET BINNS SUBJECT: ItA"rON CRF, . -1982-055 DATE: t/2[/2005 CC: DAN FIERNANllE"l. I have reviewed the 2004 Vegetation Monitoring Report for the Raton Creek Mine. IME conducted the vegetation sampling and prepazed the report for Energy Fuels Coal, Inc. for the first year of sampling for final bond release as per Rule 3.03.1(2) and Rule 4.15.7(5). The report was submitted to the Division for informal review. The mine was reclaimed in 1994 with initial seeding occurring in late fall 1995. Limited inter-seeding has occurred in February 1996, May 1996, November 1999, May 2000, and seeding of pond cleaning material occulted in May 2003. Vegetation sampling was conducted June 17-23, 2004 and September 4-6, 2004 to coincide with peak vegetative growth and vigor. Vegetation success standards aze found on Raton Mine Permit page 521 and 522. Sampling methodology is described on page 522 in the PAP. Approved seed mixes for re-establishing rangeland are found on pages 524 and 525 of the PAP. Cover, production and woody stem density data were all collected to sample adequacy with a 90% level of confidence. The approved reclamation standard for live vegetative cover is greater than or equal to 25%. Live vegetative cover of all species totaled 36.87%. Removal of cover value provided by noxious species, 3.87%, and annuals and biennials, 4.87%, finds "allowable" cover to be 28.13%. This value is still in excess of the 25% cover reclamation success standard. Live vegetative cover is successful for the Raton Creek Mine for the 2004 sampling event. IME included broom snakeweed (Guttierrezia sarothrae) cover as cover contributed by shrub species. Broom snakeweed is considered asub-shrub (see enclosed data sheet from USDA-NRCS Plants database). It has been the Division's practice not to count sub-shrub species as woody stems. Cover contributed by sub-shrub species can be included in the forb category. The approved productivity standazd for the Raton creek Mine is 300 Ibs/acre. IME collected three one-quarter of a squaze meter quadrats along 68 transects for productivity determination. The three quadrats were combined for each transect. IME sampled perennial grasses and forbs for inclusion in the productivity determination. Annual, biennial, and noxious species were not sampled for productivity evaluation. Woody plants were not sampled for inclusion in the productivity calculations either. Results of productivity sampling determined that the reclaimed community produced 33.78 g/'/a MZ. This value translates to 1,203.91bs air dry biomass per acre. The reclamation standard for productivity is 300 lbs air dry biomass per acre. The reclaimed azea exceeded the standard in 2004 fourfold. The reclaimed area was successful for biomass production in 2004.