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2008-03-14_REVISION - C1981019
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2008-03-14_REVISION - C1981019
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Last modified
8/24/2016 3:25:14 PM
Creation date
5/29/2008 1:38:30 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
REVISION
Doc Date
3/14/2008
Doc Name
27 May 2008 TR-72 Responses and Response Letter (Rule 4 Revegetation Requirements 4.15))
From
Colowyo Coal Company
To
DRMS
Type & Sequence
TR72
Email Name
JRS
Media Type
D
Archive
No
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For demonstration of revegetation success, vegetation cover, herbaceous production, and <br />in certain circumstances woody plant density will be sampled to statistical adequacy <br />(where necessary), and compared to the approved standard or reference area mean. The <br />Division has completed a comprehensive bond release guideline (1995) that provides a <br />good overview of recommended sampling approaches, statistical adequacy formulas and <br />statistical tests. Furthermore, new regulations promulgated 9/14/05 under Section <br />4.15.11 detail new allowable approaches for vegetation sampling and testing. Colowyo <br />will utilize procedures recommended in the new regulations, guideline, or other <br />procedures that are as effective as the Division's recommendations. Before Colowyo <br />begins a vegetation sampling program for bond release, the Division will be consulted to <br />confirm sampling approaches and statistical testing. A base level or initial protocol is <br />detailed under Section 4.15.11 below. <br />As indicated in Rule 4.15.7 (5) the 10-year liability period will begin following the last <br />year of augmented seeding, fertilization, irrigation, or related revegetation work. To <br />facilitate bond release, revegetation success criteria must be met for two of the last four <br />years of the liability period excepting that sampling for final success determination <br />cannot occur prior to year 9 of this period (unless these rules are changed to be less <br />restrictive by the Division). The liability period will be re-initiated for augmentation <br />work excepting work associated with normal management activities as defined under <br />Rule 4.15.7 (5) (a-g). This allows the liability period to remain unchanged for such <br />revegetation metrics as "interseeding" (4.15.7 (5)(g)) of additional grasses and forbs into <br />a stand targeting shrubs to increase cover values of these life forms. <br />To summarize the use of reference areas in this testing process, the following will occur. <br />There are three reference areas (RAs) that will be utilized for testing against reclamation <br />on the original permit area and/or on the new South Taylor (PR-02) permit area. These <br />reference areas are: 1980 Mountain Shrub RA, 1981 Sagebrush RA, and 1984 Aspen RA. <br />All lands reclaimed prior to 2008 and grazinglands (grasslands) reclaimed post-2008 on <br />the original permit area shall be compared to weighted parameters from the 1980 <br />Mountain Shrub RA (55% weight) and the 1981 Sagebrush RA (45% weight) in <br />accordance with 4.15.7(4)(b). All post-2008 lands on the original permit area that evolve <br />into a Sagebrush Steppe community* will be directly compared to the 1981 Sagebrush <br />RA. <br />In the new South Taylor (PR-02) permit area all reclaimed post-2008 grazinglands <br />(grasslands) shall be compared to weighted parameters from the 1980 Mountain Shrub <br />RA (52% weight), the 1981 Sagebrush RA (25% weight), and the 1984 Aspen RA (23% <br />weight) in accordance with 4.15.7(4)(b). All post-2008 lands on the new South Taylor <br />(PR-02) permit area that evolve into a Sagebrush Steppe community* will be directly <br />compared to the 1981 Sagebrush RA. <br />* Areas that evolve into a sagebrush steppe community cannot be determined with certainty until several years <br />following seeding, emergence, and maturation of shrubs. Emergence of this community may occur in both areas where <br />sagebrush steppe is targeted as well as those grassland targeted areas that receive significant sagebrush seed. Any <br />sagebrush steppe that evolves in either of these areas will be delineated with GPS techniques, sampled accordingly, and <br />tested against the 1981 Sagebrush RA. <br />4.15-14 Revision Date: 3/14/08 <br />Revision No.: TR-72
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