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Table 2 in CEC's revegetation report shows that Bromus tectorum (cheatgrass) <br />contributed 8.3% to the live vegetation cover (L VC) on this Bond Release Block <br />(BRB), and this amount must be removed from the value of 60.98% for a sub- <br />total of 52.66% L VC. <br />Furthermore, in measuring reclamation success the allowable cover <br />contribution of annual and biennial species should not exceed 10 percent (based <br />on Division policy and the Division's 1995 guidelines). Of the 36 plant species <br />sampled on the 19981199912000 BRB, 14 species were determined to be annual <br />or biennial. The 14 species contributed 13.19% of the total cover and 28.67% <br />of the relative cover (from Table 2). To limit the relative cover of annual and <br />biennial species to exactly 10 percent, a portion of these species were removed <br />from a revised Table 2, and the resulting LVC is 44.07%. " <br />The assertion by the Division that neither "noxious" species nor annual or biennial <br />forbs should contribute to the total vegetation cover of reclaimed areas when <br />evaluating revegetation success is a concern. <br />The permittee is bound by the Colorado Surface Coal Mining Reclamation Act, and <br />Regulations of the Colorado Mined Land Reclamation Board for Coal Mining, as <br />well as the permit document for the Keenesburg Mine relative to the requirements <br />for judging revegetation success. These documents do not stipulate that a permittee <br />must remove "noxious" species or annual or biennial forbs from consideration in <br />judging revegetation success. <br />It is the permittee s position that it has met the permit, regulatory, and statutory <br />requirements for Phase III bond release for the areas described in this application. <br />Absent a clarification or ruling by the Colorado Mined Land Reclamation Board, <br />the application of Division's 1995 guidelines in judging the success of revegetation <br />for bond release should be considered contrary to Rule 1. 15.4(l) and 1.15.4(2). <br />Literature Cited <br />Barfield, Billy, J., R.C. Warner, C.T. Hahn. 1981. Applied Hydrology and Sedimentology <br />for Disturbed Areas. Department of Agricultural Engineering, Stillwater, OK. <br />U.S. Department of Agriculture. Soil Conservation Service. 1982. Agronomy Note # 50. <br />Universal Soil Loss Equation. <br />Coors Energy Company Keenesburg Mine Page 7 <br />Phase III Bond Release: Areas 2, 5, 6, 7, 9, 1 O, 15,16, 19