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Binns, Janet <br />From: Welt, Kathy [KWelt @archcoal.com] <br />Sent: Monday, August 15, 2011 3:45 PM <br />To: Binns, Janet; Hernandez, Daniel <br />Cc: Kaldenbach, Tom <br />Subject: FW: Reclamation Woody Plant Standard <br />Below is an e-mail that I sent to the CP &W, sharing the e-mails from the Forest Service stating that <br />they support the elimination of the woody plant density standard. There are no BLM surface lands <br />that are part of our current or future mine site facilities. Based on my discussions with the CP &W <br />before and after their letter was sent to the DRMS, I do not believe that they understand that the <br />Mountain Shrub community addressed in this standard covers only a very small part of our permit <br />area on our own private property on the main West Elk Mine site, or that the overall disturbance <br />(about 600+ ac) is very small compared to the entire permit area (about 17,000 ac) with the majority <br />being Forest Service lands. It appears that they still do not understand the difference in the amount <br />of disturbance required for an underground mine site as compared to a surface mine, or that the <br />reclamation standard only applies to the reclaimed disturbed areas and not "the mine permit for the <br />entire permit boundary", as stated in their letter. <br />I have tried to clarify in e-mails to them (sent to you previously) that this density standard is site <br />specific to the WEM site and does not apply to any other operation. I assume that they are <br />attempting to clarify /reiterate that point in their letter, not that they need more site - specific information <br />from WEM. All that being said, I agree with Janet that the 60:40 ratio is confusing. From our <br />perspective, the CPW only is addressing elk/deer winter habitat in this letter. Our observations <br />indicate that the mountain shrub habitat at the mine site is much more important to bird species than <br />deer or elk. CP &W also states that the "most productive for wintering elk when the oak shrub <br />diameters are less than 1" and 4 -5 ft in height." This is not the case in the oakbrush community at <br />West Elk Mine site. The oakbrush community is dominated by trees that average 4 -10" in diameter <br />and 10 -20' tall. Based on discussions with Mike Ward (our consulting forester), the oakbrush <br />communities at West Elk are likely to be between 75 and 150 years old. It is also disputable that <br />oakbrush often has the highest diversity when a young stand. We've observed that aspen stands, by <br />far, have the highest diversity. Lastly, we're also not sure how CPW is defining forage:cover ratio. If <br />forage equals herbaceous plant communities and open areas palatable to wildlife (grasses, forbs) <br />and cover equals woody /shrubby overstory communities; then West Elk's forage to cover ratio is <br />about 10:90, indicating that West Elk could use much more in the way of herbaceous open vegetation <br />communities (supporting re- establishment of herbaceous communities and eliminating the woody <br />plant standard). That being said, we do not want yet another reclamation success criterion where <br />MCC has to go and measure the percentage of open herbaceous areas to woody areas. One final <br />thought - If the Forest Service does not want woody species in the reclaimed areas, isn't that the end <br />of it since they are the majority land management agency in the overall permit area that the CP &W <br />refers to and defers to in their letter? <br />Also, please be aware that the CP &W have been confusing our request with (supposedly) similar <br />requests from Oxbow's Elk Creek Mine in regard to reclamation seed mixes, as well as Oxbow's oil <br />and gas reclamation and even sent the first response letter for MCC to Oxbow. <br />Kathy Welt, <br />Environmental Engineer III <br />Mountain Coal Company, LLC <br />West Elk Mine <br />1 <br />