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young reclamation). Cedar Creek observed that two of the five 7-year old units (100%) would pass this <br />test currently, two of the five 4-year old units (40%) would pass, and no 2-year old units were measured <br />in 2006. This level of success for such young reclamation is reasonably encouraging for eventual bond <br />release with regard to this variable. <br />7.3 Woodv Plant Densiri <br />Based on the 2002 monitoring report, it is Cedar Creek's understanding that Colowyo's woody plant <br />density standard is 90% of 1000 stems per acre, and it is assumed that this standard applies mine-wide <br />to all reclamation. Given these assumptions, perusal of the 2002 monitoring report as well as data <br />collected in 2003 through 2006 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 turn show a strong tendency to competitively exclude shrubs. In fact, this problem <br />has been a source of significant discussion among professionals in the reclamation field. <br />Given this situation, it 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 CDRMS (and CDOW as necessary) for <br />development of a technical permit revision to change the current standard to something that reflects a <br />more reasonable and ewlogically obtainable target within the ten-year time frame. <br />Several options are under various levels of scrutiny and acceptance 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 reclamation 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 />natural vegetation communities to emerge and evolve. In this manner, reclamation and resultant <br />developing communities will be encouraged to follow a more natural path to maturation and successional <br />progression as opposed to the more historically and ubiquitously targeted grasslands. <br />However, since the mine occurs in an area that once exhibited extensive grasslands but is now <br />depauperate of such steppe types, replacing a majority of this type with shrublands interspersed <br />throughout would maximize the overall net effect on habitat value of the overall area. Furthermore, <br />shrublands do not exhibit uniform densities of woody plants, therefore, a possible target of heavier <br />AA-8 <br />