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2010 ARR REVIEW MEMO .DOC X <br />Long -term spoil remaining on site - per 2009 ARR 354,018 BCY <br />Spoil used for cover in 2010 — per 2010 ARR 13,123 BCY <br />Remainder 340,895 BCY <br />Long -term spoil remaining on site - per 2010 ARR 340,895 BCY <br />Mapping <br />The contours on the Reclamation Contour and Drainage Plan Map (Appendix Q -1) submitted with the 2010 ARR match <br />the contours from the previous contour map (Appendix Q -1 from the 2009 ARR). <br />Vegetation Monitoring <br />Description Value <br />2 7/11/2011 <br />Units <br />In 2010 CEC performed vegetation sampling on Reclamation Area 30 (RA 30). RA 30 was seeded with the approved <br />permanent seed mix in 2006, and vegetation sampling in 2010 represents the fourth growing year following seeding. CEC <br />measured the vegetative cover on RA 30 as 52.6 percent. However, the 2010 ARR states that Cheatgrass (Bromus <br />tectorum) was dominant in RA 30, contributing 23.8 percent cover (40.3 percent relative cover). The Division does not <br />consider noxious weeds (including Cheatgrass) as contributing to reclamation success. An accurate plant species cover on <br />RA 30 would remove the contribution of the noxious weed component, and the 2010 vegetative cover value should be <br />28.8 percent (52.6 percent minus 23.8 percent). <br />The calculated cover standard is 36.28 percent, based on the approved reclamation success formula and the measured <br />precipitation. Because 90 percent of the calculated standard cover equals 32.65 percent (0.9 x 36.28), and this value is <br />greater than 28.8 percent, RA 30 does not yet meet the cover standard for reclamation success. However, this area is <br />developing a permanent vegetative community. <br />Further points related to Cheatgrass: <br />• In the ARR, CEC makes the statement that "no pests, noxious weeds, or diseases were identified during the 2010 <br />inspections that negatively impact the revegetation efforts." Apparently CEC does not view Cheatgrass as a <br />noxious weed. However, the Weld County Weed Division of the Weld County Department of Public Works <br />identifies Cheatgrass as a List C noxious weed, and Cheatgrass is a List C species on the State of Colorado <br />Noxious weed list. <br />• Eradication of List C species is not required, but Weld County and the State of Colorado do recommend weed <br />control efforts and appropriate management to try to reduce these Class C noxious weed species. CEC should <br />continue to implement their approved weed management plan with regards to control of Cheatgrass. <br />No other concerns were identified with the vegetation portion of the 2010 ARR for the Keenesburg Strip Mine. <br />