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• SITE LOCATIONS, SITE CONDITIONS, AND SOIL THICKNESS <br />SPECIFICATIONS FOR EACH PROPOSED PLANTING AREA. SITE <br />LOCATIONS CAN BE TENTATIVE; DEPENDING ON SUITABLE <br />OVERBURDEN CHARACTERISTICS OR OTHER FACTORS, AS LONG AS <br />THE SPECIFIED MINIMUM ACREAGE OF THIN SOIL AND THICK SOIL <br />ESTABLISHMENT AREAS AND CONFORMANCE WITH ALL SPECIFIED <br />REQUIREMENTS IS ACHIEVED. <br />C. Mulching <br />In the original permit application, Colowyo proposed that mulch was not required on slopes less <br />than 4:1. This discussion is summarized in the original findings document and starts on page <br />2.05-55 of the Permit. The Division approved this proposal at that time with erosion control prior <br />to vegetative establishment to be provided by contour plowing. Monitoring of mulched versus <br />non-mulched areas was required as part of Colowyo's Annual Reclamation Report. In addition, a <br />stipulation was added to the permit requiring the use of mulching if excessive erosion does <br />develop. <br />Subsequent monitoring data showed that mulching was not necessary for erosion control or plant <br />establishment. As a result of the permit renewal process in 1987, both mulching and the <br />monitoring program were eliminated as requirements. The above-mentioned stipulation was at <br />that time incorporated into the Permit. <br />D. Revegetation Success Standards <br />Prior to initial disturbance at Colowyo, Colorado State University and the Soil Conservation <br />Service Upper Colorado Plant Materials Center conducted studies, in cooperation with Colowyo, <br />to determine appropriate seed sources, species composition and revegetation practices to ensure <br />reclamation success at the mine site. Results of the studies conducted by Colorado State <br />University are included in Exhibit 10, Volume IV, of the permit. No final report has been issued <br />from the SCS Plant Materials Center. <br />Methods for evaluating vegetative success are found in Section 4.15 of Permit Volume I, and in <br />Section 2.04.10 and 4.15 of Volume 12, submitted in association with Permit Revision 02. As <br />part of this process, two reference areas have been established for the determination of <br />reclamation success. One reference area represents the sagebrush community while the other <br />represents the mountain shrub community. Cover data was collected by measuring five random <br />points along 100-foot long transects. A ten-point frame was used to measure each of the five <br />points. Production values were measured by clipping 30cm x 30cm plots at each of the five <br />points along the transect used to measure cover. 1976 data reflects air dry weight while 1988 <br />data was measured with 60cm x 60cm plots with plant biomass being oven dried prior to <br />weighing. <br />Proposed Decision and Findings of Compliance 14 September 2009 <br />Permit Renewal 05 Page 60