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WEST ELK,NUNE, C1980-007, MAY 23, 2011 MEETING REGARDING HRSA SAMPLING <br />approved in the West Elk permit, the Division considers that the proposed vegetation success <br />standards will need to be submitted as a technical revision to the permit. The permit currently requires <br />that MCC conduct vegetation sampling in a wet year for the purpose of defining the cover and <br />production reclamation success criteria. The Division asked Mountain Coal if 2011 would qualify as a <br />wet year. Mountain Coal commented that data for the evaluation period, October 1, 2010-May 31, <br />2011, was not available at the time of the meeting. In the absence of a defined "wet" year in 2011, the <br />Division is in support of accepting the four years of data already collected by MCC and MCC's <br />standards for cover, productivity and diversity as proposed in the 2010 vegetation report. <br />Correspondence between the Coal Program and Mountain Coal during the review of PR3 for the West <br />Elk permit documents that the Division approved diversity and woody plant density standards as part <br />of PR3's approval (West Elk Permit, Table 41, Page 2.05-68). A proposed revision to the reclamation <br />success criteria would address cover and productivity success criteria. Savage and Savage had <br />proposed a new diversity standard in the 2010 vegetation report, which DRMS was not opposed to. <br />The Division informed Mountain Coal that if they wish to propose a new diversity standard as well as <br />new standards for cover and productivity, The Division would consider the proposal. <br />MCC and the Division also discussed the applicability of the currently approved woody plant density <br />standard of 1000 stems per acre in shrub clusters, and of Mountain Coal's thoughts on revising this <br />standard. The Division suggested MCC consult with US Forest Service and CDOW regarding <br />acceptable woody stem densities prior to submittal of a revision. The Division also suggested that <br />MCC research what the currently approved woody stem density standards are for the other coal mines <br />in the North Fork of the Gunnison River area. MCC agreed this would be a beneficial approach. <br />2 <br />