2011-07-11_REPORT - C1981028 (3)

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