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Species diversity standards aze found on permit page 522. The approved diversity standard for the Raton Creek Mine are: At least 60% of the total vegetative cover will be grass with no one grass species comprising more than 50% of the grass cover. • At least 5% of the total vegetative cover will be attributed to shrubs • At least 10% of the total vegetative cover will be comprised of forb species. Although the Energy Fuels Coal, Inc. has established a permanent, relatively diverse, grass dominated community, the data fall short of achieving the approved standard. The 2004 cover data recorded 14 perennial grass species, 3 perennial forb species, 1 sub-shrub species, 2 shrub species, and 12 annual or biennial species. One noxious weed species, field bindweed, was encountered with in 19 of the 30 transects during the sampling event. Perennial grasses achieved 52.6% relative cover. This value is just short of the approved 60% required in the permit. Of the perennial grass cover, no single grass species should comprise greater than 50%. Western wheatgrass made up 52% of the perennial grass species. The diversity requirement for grasses was not met in the 2004 sampling event. Two species of shrub species were encountered in the cover data; Rubber rabbitbush (Chrysothamnus nauseosus) and Fourwing saltbush (Atriplex canescens). Broom snakeweed is considered asub-shrub and is not counted in the shrub success standard. Relative cover of the two shrub species comprised 3.07% relative cover. This value is short of the 5% standard stated in the permit. The diversity requirement for shrubs was not met in the 2004 sampling event. Three perennial forb species contribute 21.1 % relative cover. Cover from sub-shrubs can be counted in the forb category, raising the forb relative cover to 21.2%. This 21.2% relative cover value is more than double the value of 10% required by the approved reclamation success standard. Annual and biennial fortis also contribute 12.66% (13.30 - 0.54 from bromus tectorum) relative cover. The diversity standard for the forb component has been achieved for the 2004 sampling event. Woody~lant density success standard for the mine is 500 stems per acre. IME collected 250 belt transects (100 M) fot woody plant density. Data was collected to adequacy in accordance with the adequacy formula outlined in the Division's Guideline Regazding Selected Coal Mine Bond Release Issues, dated April 18, 1995. Three shrub species and three tree species were encountered in the shrub belt transects; Rubber rabbitbrush, Yellow rabbitbrush, Fourwing saltbush, Boxelder, Rocky mountain juniper, and Gambel oak. IME included Winterfat (Krascheninnikovia Janata) in the woody stem counts. Winterfat is considered asub-shrub. Please refer to enclosed USDA-NRCS Plants datasheets. The Division does not include sub-shrubs in the woody stem density calculations. Subtraction of the Winterfat data from the woody stem data results in 5.464 woody stems per 100 MZ belt transect. This value calculates to 221 woody stems per acre. The reclaimed area does not achieve the woody plant success criteria for the 2004 sampling event. The 2004 data shows that the reclaimed vegetative community at the Raton Creek Mine is successful for cover and productivity. The data do not show reclaimed vegetation success for diversity as approved in the PAP. The data show that the reclaimed vegetative community is approaching the diversity success criteria. The 2004