2011-06-02_APPLICATION CORRESPONDENCE - C2010089 (16)

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revegetation success standard for cover or production in any reclaimed or reference areas. For the purposes of this demonstration, a statistically adequate production sample will be taken, or with a minimum of 15 cover samples and at least 30 production samples. As directed by Mr. Dan Mathews in an e -mail send to Mr. Gubka, on 7 July 2010, the production plots on all of the Irrigated Pasture Reference Area will be clipped by life forms which will include perennial grasses, perennial forbs, annuals and biennials and noxious weeds. While on the Irrigated Pasture reclaimed sites, the plants will be clipped by the categories of: seeded grasses, seeded forbs, non - seeded desirable grasses, non - seeded desirable forbs, annuals and biennials, undesirable grasses, undesirable forbs and noxious species. Our careful review of this for the NH2 Mine permit section and in the previous reclamation monitoring reports resulted in our finding no specific definition of what constitutes a "desirable species" although this term is used extensively in the NH2 permit and in previous reclamation monitoring reports. Therefore, as used in the NHN Permit Application and correspondingly for revegetation success of this area a "desirable species" is determined using the following criteria as developed after consulting the following sources. Firstly, all species listed in the Office of Surface Mining Reclamation and Enforcement - Plant Materials Handbook issued in May 1988 for Colorado that includes the 54 species of plants recommended by the NRCS for the subsection entitled Colorado - Standards and Specifications - Pasture and Hayland Planting guideline and which contain Table 1, Perennial Grasses and Legumes for Pasture and Hayland plantings in Colorado will be considered as "desirable species" within the context of forage quality for purposes of final bond release. Secondly, for all species that are not included in the OSM reference cited above, which includes nearly all of the non - agronomic or pastureland species, then the USDA NRCS Plants database, found at http: / /plants.usda.gov website will be used. For example, Quackgrass (Agropyron or Elyrigia repens) is not listed on the 1988 OSM list, and thus upon consulting this website and typing in the species name yields a Plant Profile. On this webpage page, there is a subsection entitled U.S. Weed Information which includes the species listed in the Weeds of the West. Species listed on this list are considered "undesirable" for purposes of forage quality in Section 2.05.4(2)(e) Page 18 April 2011