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f <br />Memorandum <br />To: Rob Zuber <br />From: Janet Binn; <br />Date; October 8, <br />Re: Marr 2009 <br />port and species diversity <br />The Division reviewed The 2009 Revegetation Monitoring Report for the Marr Mine. The report was prepared by IME, <br />and sampling'was conducted on the 1999 (reseeded 2000) reclamation areas at the mine site, consisting of 8.29 acres, the <br />tipple area, Alkali sagebrush reference area and the tipple reference area in 2009. <br />The data from the 2009 sampling event demonstrates that both the 1999 reclamation parcels at the mine and the reclaimed <br />load out area meet the reclamation success criteria with the exception of species diversity on the 1999 reclamation parcels <br />at the mine location. Representatives of Kerr Coal Company completed vegetation sampling of the reclaimed areas, and <br />reference areas in accordance with the approved sampling methodologies, and in accordance with Rule 4.15.7. Tile <br />operator indicated that the 2009 sampling event was conducted to satisfy the requirement to obtain two years of vegetation <br />data to demonstrate Phase III bond release reclamation success (Rule 4.15.7(5)). <br />The 2009 vegetation sampling of the 1999 reclamation parcels at the Mine site demonstrated reclamation success with all <br />parameters; cover, production, woody plant density, with the exception of the species diversity standard. <br />Revisiting this issue, I have been looking at what kind of a revision to the diversity standard we could accept from the <br />operator while still adhering to the requirements of Rule 4.15.7(2). Rule 4.15.7(2)(d) allows for establishment of <br />reclamation success standards based on pre-mining data. Review of the baseline vegetation sampling data in the Marr <br />Mine permit found that on the pre-mining alkali sagebrush community, four vegetation species contributed greater than <br />3% relative cover, with a combined total of 91.5% relative cover. One species, Alkali sagebrush, contributed greater than <br />40% relative cover (57.3% relative cover). Comparison with the premining Alkali Sagebrush reference area data yielded <br />similar results. In the premining reference area data the same four species each contributed greater than 3% relative <br />cover, and one species, Alkali sagebrush, contributed greater than 40% relative cover (42.89%), and these four species <br />contributed a combined total of 87.63% relative cover. The baseline data collected on both the Alkali sagebrush <br />communities, reference area and pre-mine area, would not meet the current approved diversity standard. <br />When the diversity standard was developed in late 1981 (Stipulation No. 9, terminated December 21, 1981) the mine was <br />projected to disturb 4 different vegetative community types: Alkali sagebrush, Sagebrush-grassland, Sagebrush-gravel, <br />and Treated Sagebrush. Reclamation success standards were approved using a weighted area average incorporating <br />results from reference areas of all the community types disturbed by the mining operation. Bond Release No.4 (SL4) <br />was approved' at the Marr Mine on November 17, 2008. SL4 approved final bond release on all areas of the mine site with <br />the exception of the 8.29 acres seeded in 2000, and the permanent access roads to the remaining 8.29 acres, as well as <br />approving Phase 1 and II bond release on a portion of the Marr Load Out. <br />The remaining reclaimed 8.29 acres at the mine site all fell within one premining vegetation community, that of the Alkali <br />sagebrush corinnunity. At the time vegetation sampling in 2009, the operator asked if just the Alkali sagebrush reference <br />could be sampled since the remaining reclamation would have been 100% alkali sagebrush community pre-law. The