2011-05-05_PERMIT FILE - C1981041

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SNOWCAP MINE — TECHNICAL REVISION — REVEGETATION SUCCESS STANDARDS - 2010 Introduction The Snowcap Mine is located approximately five miles northeast of Palisade, Colorado in an and canyon ecosystem. Surrounding vegetation communities are dominated by greasewood (Sarcobatus vermicuiatus), shadscale (Atrip /ex confertifo/ia), and cheatgrass (Anisantha tectorum). Establishment and survival of forbs and perennial grasses (especially warm - season grasses) on reclaimed lands has been an exceedingly difficult challenge due to: 1) conditions highly favorable to cheatgrass, 2) the aggressiveness of cheatgrass, and 3) the elevated levels of cheatgrass seed in surrounding native areas as well as topsoil piles. Even established stands of native perennial grasses and forbs in undisturbed areas of the local ecosystem have been unable to withstand the onslaught of this invasive annual grass as populations continue to slowly dwindle. To the contrary, establishment of shrubs on revegetated areas has been reasonably successful. In 2010 in response to this situation, Snowcap Coal Co. (Snowcap) requested Cedar Creek Associates, Inc. (Cedar Creek) re- evaluate the vegetative cover, production, and species diversity attained following multiple remediation attempts to combat cheatgrass invasion of reclaimed areas, and to compare those values against the currently permitted success criteria and standards. Per Cedar Creek's recommendations based on that evaluation, modest revisions to success criteria and standards are being proposed to facilitate a reasonable solution to a problem that currently has no ecological resolution. Recommended criteria and standards are as follows (changes /clarifications are in boldface): • Achieve 90% of the perennial vegetation cover of the approved reference area. • Achieve 90% of the total herbaceous production of the approved reference area. • Achieve woody plant density of 800 live shrubs per acre. • Achieve total perennial cool- season grass species' relative cover of >_0.5% with at least two species present in the reclamation (observed). • Achieve total perennial warm - season grass species' relative cover of > -0.5% with at least two species present in the reclamation (observed). • Achieve total perennial forb and suffrutescent (sub- shrub) species' relative cover of >_0.5% with at least two species present in the reclamation (observed). • And, no reclaimed area shall have a single species that represents greater than 70% relative cover, with the exception of annual grasses. The annual grass component shall not exceed 70% relative cover unless the annual grass component in the corresponding reference area also exceeds 70 %. In such instances, the relative cover of the annual grass component of the reclaimed area shall not exceed the relative cover of the annual grass component in the reference area by more than 5 %. TR -60 A14 -11 -1 (New 01/11)