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DRAFT - PROPOSED SPECIES DIVERSITY STANDARD <br />FOR THE MARR MINE AND KERR TIPPLE AREAS <br />The current species diversity standard for the Marr Mine as found on Permit page 780-84a, <br />requires that the reclaimed plant community shall consist of a least four dominant species <br />comprising no more than 83 percent of the total relative cover and with no single species <br />contributing more than 40 percent of the total relative cover. At least one of the four dominant <br />plant species shall be either a shrub or a forb species. <br />At the Kerr Tipple area, the current species diversity standard requires that the three dominant <br />species must account of at least 54 percent and no more than 75 percent of the total relative cover <br />and at least one of the three dominant species must be a forb and none of the three dominant <br />species shall comprise less than three percent of the relative plant cover. <br />The submittal made by Kerr in spring of 2010 summarizing the 2009 vegetation sampling data as <br />well as the data collected in 2010, both fail to comply with these approved standards. Why the <br />1999 Reclamation located at the Marr Mine, as well as the Tipple Reclamation, are both adjacent <br />to undisturbed Sagebrush Areas, and are relatively similar in overall appearance, yet have such <br />different diversity standards is very confusing. As are documented in the 2009 Revegetation <br />Monitoring Report, not even the data from the undisturbed Alkali Sagebrush RA would comply <br />with the current species diversity standard for the 1999 reclamation at the Marr mine. Analysis of <br />the 2010 data has similar deficiencies. KCC recognizes that the data from the original reference <br />area could be used to document the same deficiencies, however, in this evaluation the data <br />collected from the 2009 and 2010 are readily available and usable in the format needed. <br />Therefore, the following discussion and accompanying proposed standard are presented. <br />Existing Minimum Species Diversity Value <br />Why the DRMS, in the Kerr Coal Permit imposed species diversity standards that contain both <br />minimum and maximum values that are so divergent from the characteristics of the adjacent <br />undisturbed vegetation plant communities is difficult to understand. For example, on the 1999 <br />Reclamation at the mine site, the approved permit maximum percent relative cover for a single <br />species is 40 percent. However, data from the 2009 and 2010 sampling of the ASRA document <br />that the percent maximum percent relative cover values for the dominant plant species are 39.00 <br />and 39.22 percent respectively, averaging 39.11 percent. This means that the current reclamation <br />species diversity maximum value for the Marr Mine is only 2.22 percent higher than the <br />undisturbed RA species diversity characteristics. <br />The current permit species diversity standard for the Tipple reclamation contains a minimum <br />value of 54 percent for the three most dominant species. Sampling of the Tipple RA in 2009 and <br />2010 yields values consisting of 38.31 and 57.64 percent and averaged 47.98 percent total <br />relative cover for the three most dominant plant species growing on the Tipple RA. Most <br />importantly, the 2010 sampling (57.64 %) of the Tipple RA would not satisfy the minimum <br />species diversity value (54 %) required for the Tipple Reclamation. A comparison of the average <br />percent relative cover values across both the 2009 and 2010 sampling periods, translates into a <br />species diversity standard (54 %) that is only 12.55 percent higher than the current species