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July 7, 2010 <br />Reclamation Success standards Rule 4.15.7(2)(d)(i) or (iii). If KCC proposes to revise the diversity <br />standard for the 1999 reclaimed area at the mine, KCC will need to document which comparison they <br />propose; reference areas (i), or pre-mining data (iii). <br />IME argues that the tipple diversity standard is different than the mine area diversity standard. The Division questions <br />why this is even an issue. This difference in diversity standard was not a concern when the majority of the mine area <br />reclamation received Phase III bond release during SL4. The mine site and the load out are located 12 miles apart from <br />one another; the tipple was previously disturbed prior to the permanent program and received minimal topsoil <br />replacement. The reclaimed parcels at the mine area are in a different vegetation community, received topsoil <br />replacement, and have a different slope and aspect. The Division believes that it is appropriate to have different diversity <br />success standards for the different areas, reclaimed mine parcels versus reclaimed Loadout area, due to the differences in <br />environment. <br />On page 13 of the 2009 Vegetation sampling report, IME presents the argument that the mine area species diversity <br />standard is unrealistic since each transect in the sampling of the reference area would not meet the standard. That is why <br />the Division requires statistically adequate sampling. The Alkali sagebrush reference area met the species diversity <br />standard based upon the 2009 sample data. This indicates to the Division that the approved species diversity standard is <br />still appropriate. <br />Alkali Sagebrush Reference Area 2009 sampling <br />% rel. <br />X cover cov <br />1.6 4.97977 Agropyron smithii Western wheatgrass NG <br />1.73 5.384376 Phlox hoodii Hooded phlox NF <br />12.6 39.21569 Artemesia tridentata WY Big Sagebrush NS <br />6.33 19.70121 Chrysothamnus Rabbitbrush NS <br /> 69.28105 <br />Reclamation success standards for the 1999 Mine reclamation parcel were met for the 2009 sampling event, with the <br />exception of species diversity. All reclamation success standards for the sampled tipple area were met based upon the <br />2009 vegetation sampling. <br />Rob, you may forward my comments to the operator. If you have questions regarding my concerns, please ask. <br />3