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~to• pso~ ed saes. With respect to grasses, neither site would satisfy the proposed revegetation success standard. F.oabsxco~t~ib~:e~9~ 24,0.3~p_erce„nt of the ~total,~~.eg~tation cover on the norms--topsoil_edasite`and 747~8~pel~cer~taofitF~e+totalFCO,uerrora~the~topsoilec~rsitesr iSh~ubs were or~Y~eg,cot~ered~ in the tcgy,,~r~sa7m~lifi'~' in the 15 transects o~~the.;non-, topsoiled~sitesland contributed only 0.77 percent of the total vegetation cover on the topsoiled sites. Shrub density was determined to equal 78.24 shrubs per acre on the non- topsoiled site and 94.43 shrubs per acre on the topsoiled reclaimed sites. This comparison suggests that neither the non-topsoiled nor topsoiled reclaimed sites would satisfy any of the approved revegetation success standards other than Total Plant Cover for this mine site and that ne:~4heF siteaa`ppearsxto havewar~ywad•uarttag~gwove,:r~,th•.;eAotttefy These vegetation monitoring data support the conclusions found in the September 1994 report entitled "Topsoil Substitute Suitability Report for Energy Fuels Mining Company's Raton Creek Mines" wherein it is reported that the overburden materials would have to be "considered to represent suitable topsoil substitute material." The second evaluation conducted in connection with this field investigation involved the stratification of the reclaimed areas to determine whether the non-topsoiled reclamation is equivalent to the topsoil reclaimed areas. The focus of this evaluation addresses concerns raised by the DMG, that the non-topsoiled revegetation sites are of poorer quality than the topsoiled sites and might need to be reseeded. In order to specifically address these concerns, all of the 1998 revegetation monitoring data were statistically compared. All corresponding values obtained from the sampling of the non-topsoiled reclaimed sites were compared with equivalent values obtained from the sampling of the topsoiled reclaimed sites. This comparison is presented in Table 6, t-test comparison of Topsoiled and Non-Topsoiled Sites. In this comparison, a total of 42 different ar~a e~tg~s were compared. A total of 3ti~~oue[,~irelateda~parame ~s.am.~ soy, _~6~enslt,• q~lat~d~ _paa,Famefer'sbluere+compal•`ed. ~ Analysis of this table indicates that st~t'stioa~~gnifca~t±ynea• 4~q~r~a,~etefs~compafed! No differences in shrub density cc topsoiled and non-topsoiled sites. All of the far, ameters for v_ measured w_ere.associated_with.cover,relate_~ parameters. Tgot V~heatgrass, Intermediate Wheatgrass, Blue Grama, Atli cheatgrass, Total Annual Grasses, Field Bindweed, White Sweetclover and Litter were #.oWrp_• to • e,,~g,I,~e~oA.Yt~e~atopsoil be found between the Sweetclover and .d• sites. T,kte~Tiot< The mete~act~thatrhigher~coveT+of~selectetl~Paramet"ets was~gr~ea. te1.o,~ytl~.erto,psoiiE~c~S test mapntol~necres_sparily~be~,viewed~as~po~sit~e~ The pry minanee„o,,,~,~gr,~ss cover on the topsoil-ed sites has been extensivelycriticized in numerous regulatory settings, as precluding, f" a 'zing.;goaTs'of achieving a c3iYerse`_ar~,d~sfi[ub: dominated.pl.aryt; Ge7:'rfi'fact, these data suggest that the pfarii: cover on the non-topsoiled sites is more uni#orm and diverse in certain respects than that found on the topsoiled sites. The greater cover of Cicer Milkvetch on the non-to soiled sites can be viewed as positive from the standpoint that this is a•s~rio• tGlived~'s'~i'eci~s that will significantly add soil nutrients to the soil. For the standpoint of plant succession the presence of this plant would have to be viewed as more desirable than the dominance of the weedy annual and biennial species found growing on the topsoiled sites. The presence of these annual and biennial species has long been expressed a concern in long term reclamation stability and when the Allowable 4