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second group of patches appeared to be concentrated near this drainage. One patch of perennial <br />pepperweed (a noxious species), approximately 20 ft in diameter, was also encountered along this <br />drainage. A patch of Canada thistle, approximately 50 ft by 70 ft, was observed at the western extent <br />of the Moffat Down Drain 4, just upslope of the Moffat pond. The presence and control of the thistle <br />and pepperweed were discussed with Mr. Leach of Chevron during the inspection. Sagebrush, <br />chokecherries, and occasional Woods rose plants (all non-noxious species) were observed in the area <br />of the Moffat Down Drain 4 drainage, as were occasional rosettes of houndstongue. <br />The 258-acre bond release block that is identified as the "Support Facilities Area" is represented by the <br />permanent North Road, Lower Moffat Road, West Ridge Road and Skyline Drive, as well as areas <br />around the West Ridge Pond, Center Ridge Pond, and Moffat Pond. All permanent roads within the <br />bond release area displayed small, localized patches of non-noxious weeds and Canada thistle. As <br />mentioned above these areas were discussed with Mr. Leach during the inspection. The areas around <br />Center Ridge Pond and West Ridge Pond were inspected and displayed little evidence of weedy <br />patches. These areas displayed substantial vegetation cover throughout. <br />It should be noted that the bond release areas are not required to be 100% weed free in order to achieve <br />Phase III bond release. The ability to support the post mining land use, the absence of a weed <br />"infestation", and meeting the requirements in the approved weed management plan are criteria used to <br />determine the acceptable amount of noxious or invasive weeds throughout the bond release area. This <br />determination is based on our Division's weed management guideline entitled "Guideline for the <br />Management of Noxious Weeds on Coal Mine Permit Areas" referenced above. <br />Portions of the Moffat Area and the West Ridge Area were not reclaimed with topsoil. These portions <br />of these areas were disturbed prior to the initiation of the State of Colorado's Permanent Coal Program <br />on December 15, 1980 (45 FR 82173), and prior to the subsequent promulgation of the Board's <br />regulations (first effective August 30, 1981) requiring topsoil salvage, storage and redistribution. <br />Topsoil was thus not salvaged from, nor returned to, these areas. These areas were instead reclaimed <br />with a topsoil substitute (select overburden material) in accordance with Section 4.06.2(4) of the <br />Board's regulations. Due to the lack of topsoil, the ground surface at these areas was rocky and hard. <br />For the portions of the Edna mine that were disturbed by mining activities prior to the promulgation of <br />the Board's regulations and were then subsequently re-disturbed by mining activities after the <br />promulgation of the regulations (specifically, the non-topsoiled bond release blocks within the Moffat <br />Area and West Ridge Area), Section 4.15.10(1) of the regulations applies. Section 4.15.10(1) requires <br />permittees to establish in previously-mined areas not reclaimed to the requirements of the current <br />regulations a ground cover of living plants not less than can be supported by the best available topsoil <br />or other suitable material. This ground cover is required to be adequate to control erosion and required <br />to have a cover value no less than the ground cover value existing before re-disturbance. The approved <br />revegetation success criterion applicable to the re-disturbed, non-topsoiled bond release blocks within <br />the Moffat Area and the West Ridge Area at the Edna Mine is thus 47% vegetative cover. This value <br />is based upon vegetation monitoring of these areas prior to their being re-disturbed by mining. No <br />woody stem density value is applicable to these non-topsoiled bond release blocks. <br />With regard to your concerns regarding vegetation sampling methodology, Section 4.15.11 of the <br />Board's regulations describes acceptable sampling methodologies and statistical demonstrations for