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• 7.2 Diversity <br />Based on the 2002 monitoring report, lt is Cedar Creek's understanding that Colowyo's diversity <br />standard fs to replace 3 perennial grasses and 1 perennial forb with between 3% and SOo~ relative cover <br />(composition) in each target reclamation unit. As indicated in the main document for the 2004 <br />evaluation, it appears that Colowyo's reclamation becomes more diverse with age (which is typical for <br />young reclamation). Cedar Creek observed that five of the six 7-year old units (83%) would pass this <br />test currently, one of the two 4-year old units (50%) would pass, and none of the 2-year old units would <br />pass. This level of success for such young reclamation is very encouraging for eventual bond release <br />with regard to this variable. <br />7.3 Wood~Plant Density <br />Based on the 2002 monitoring report, it is Cedar Creek's understanding that Colowyo's woody plant <br />density standard is 90ok of 1000 stems per acre, and lt is assumed that this standard appl"ies mine-wide <br />to all reclamation. Given these assumptions, perusal of the 2002 monitoring report as well as data <br />collected in 2003 and 2004 indicates that woody plant density is the single problematic vegetation <br />• variable at Colowyo. This condition is not unique as most mined-land reclamation targets grassland <br />communities that in tum show a strong tendency to competitively exclude shrubs. In fact, this problem <br />has been a source of signfipnt discussion among professionals in the recamaton field. <br />Given this situation, lt is Cedar Creek's recommendation to approach this problem from multiple <br />perspectives. First, a standard of 1000 stems per acre applied mine-wide appears to be an excessive, <br />unnecessary, and uniform expectation for the environmental circumstances extant about the mine area. <br />Therefore, it is recommended to open discussions with CDMG (and CDOW as necessary) for devebpment <br />of a technical permit revision to change the current standard to something that reFlects a more <br />reasonable and ecologiplly obtainable target within the ten-year time frame. <br />Several options are under various levels of scrutiny and aaeptance at other mining operations <br />around the West, and some of these proffered concepts would be applicable to Colowyo. For example, <br />the entirety of reclaimed surtaces should not be planted to encourage shrublands. It is a well accepted <br />tenet of ecology that diversity of habitat types improves the overall quality of the local ecosystem. In this <br />regard, a goal of redamaton would be to follow a new a "Prescribed Ecosystem Reclamation Approach" <br />(PERA) as introduced previously that would then allow revegetation manipulations to take advantage of <br />• topographic circumstances and through the use of variable topsoiling and seeding techniques, encourage <br />Kenra:rntr Energy / Colowyo Coal Company AA -8 Revegetadon Monirorlrg -zoos <br />