Laserfiche WebLink
2. Herb vs Total Lover Comparison <br />Kerr Recommendation: <br />Recent regulatory changes involving changing the reveoetation <br />success criteria from total plant cover to herbaceous plant <br />cover should be applied to the reclamation plan for the Kerr <br />t4ine. These changes will allow for more flexibility than are <br />currently available. <br />This chance has not been otherwise addressed in Appendix A except <br />that the authors noted that they expect cover to be acceptable for <br />bond release should only herb cover be compared between reference <br />and reclaimed areas. Cover success criteria are addressed in <br />4.15.8(3). The present form of 4.15.8(3)(b) states, "For purposes <br />of 4.15.8, cover means either canopy or basal cover of living <br />herbaceous or herbaceous and woody vegetation." Thus, regulatory <br />changes have not resulted in the distinction of cover entailing <br />only that of the herbaceous layer. The rules do not provide a <br />reason to revise their present permit on this topic.' <br />3. Seed Plixture tdodifications <br />Kerr Recommendation: <br />The seed mixture should be modified based upon species <br />observations which suggest that several of the seeded species <br />contribute little if anything towards the desired level of <br />reveoetation success. Several invading species need to be <br />added, and species documented as negatively affecting the <br />shrub establishment goals should be changed. The <br />recommendations regarding changes in the seed mixture are <br />presented in Table 17, Kerr Coal Seed t4ixture Recommendations. <br />It appears that several species do contribute little towards <br />reveoetation. Kerr Coal may consider replacing these species. <br />However, no species have been "documented as negatively affecting <br />the shrub establishment goal". Proof for this statement rests on <br />the regression analyses which used woody plant and big sagebrush <br />density as dependent variables. Paragraphs A, B, C and E above in <br />this memo explain why these analyses are unacceptable as proof for <br />major changes in the seed mix. <br />Page 43 includes a suggestion that Kerr Coal Company obtain Bia <br />sagebrush seed from Wyoming rather than dryer, hot climates. This <br />is an excellent suggestion towards potentially higher woody plant <br />densities. <br />4. Utilization of Live Handled Topsoil <br />Kerr Recommendation: <br />The utilization of live handled topsoil should be encouraged <br />whenever operationally possible. Areas receiving live <br />handled topsoil should be regraded and prepared for seeding <br />as soon as possible after retopsoilino to assure that the <br />growth of the desired native vegetation is not destroyed at <br />the time of regrading. <br />-~- <br />