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2 C1981 -010; SL12 <br />November 28, 2011, <br />Revegetation; Cover and Composition <br />Vegetative cover was sampled in 2010 for all the parcels included in the SL12 release application. For <br />range site - A, the required - herbaceous cover standard is 33% and - 19 % titter a total % - - <br />effective cover. For range site B, the required herbaceous cover standard is 29% and 23% litter cover <br />for a total effective cover of 52%. For range site C, the required herbaceous cover standard is 23.6% <br />and 20.0% litter cover for a total effective cover of 43.6%. These standards for each of the range sites <br />are listed on Table 4.4 -1 of the permit. For this release, since the release block consists of all range A, <br />B and C sites, the revegetation standard for range site A was used to evaluate revegetation success <br />since it has the most conservative standard. <br />According to TMI's permit section 4.4.1.5; Bond Release Area Delineation, "Bond release blocks for <br />range site C reclaimed areas will always be comprised solely of range site C reclamation parcels. <br />Conversely, because of the similarity of their post- mining land uses, parcels from range site A and B <br />may be lumped together to form an individual bond release block. Moreover, contiguous areas of <br />range site A and B that were seeded in the same year and receive similar reclamation practices will in <br />many situations be considered a single reclamation parcel," page 4 -122. For SL12, A -C -05 was <br />included in the bond release block with the other parcels comprised of range site A and B parcels. <br />Given the language in the permit, parcel A -C -05 should not be included in the current bond release <br />block. <br />Also, in regard to parcel A -C -05, annual and biennial species consisted of the majority of the <br />vegetative cover found within the parcel. Only one transect was measured for this parcel; and the <br />relative cover of Annual and Biennial species was found to be 77% (Vegetation Transect Summary; <br />Parcel ACO5; SL12 application, Appendix 2). This percentage exceeds the allowable relative cover <br />contribution of annual and biennial species of 10% as discussed in the Guidelines Regarding Selected <br />Coal Mine Bond Release Issues; dated April 18, 1995. Annual or biennial cover in excess of the 10% <br />threshold should be deleted from the reclaimed area data prior to success comparison in accordance <br />with the guidelines discussed above. If annual and biennial species are removed from the data, the <br />cover estimated on this parcel would be below the success standards approved in the permit. <br />Additional sampling of the parcel may yield a different cover percentage. In regards to species <br />composition of this parcel, Agropyron spp., Bromus marginatus were the grasses found along the <br />transect. Given the data, it is unclear how many species of Agropyron were encountered. Only one <br />perennial forb was encountered. During the November 15, 2011 inspection parcel A -C -05 was <br />observed, and it appears the area affected by the operation has fairly sparse vegetation establishment. <br />Based on these findings; species composition and diversity may not meet the success criteria necessary <br />for future Phase III bond release. <br />Each of the parcels were seeded in either 2005 or 2006. Parcel A -C -05 was seeded in 2005, with the <br />range A/B seed mixture. While both the A/B seed mixtures are similar to the C mixture, they are not <br />the same. It is unclear why parcel A -C -05 was seeded with the range site A/B seed mixture. Parcel <br />F -AB -05 was seeded in 2005 with the range A/B mixture. Parcel F -AB -06 was seeded in 2006 with the <br />range A/B mixture. Parcel Z -AB -05 was seeded in 2005 with the range A/B mixture. Parcel Z -AB -06 <br />was seeded in 2006 with the range A/B mixture. <br />Vegetation cover was measured using systematically located transects using a point -hit technique with <br />an Optical Point Bar. The sampling method used, meets the criteria outlined in Rule 4.15.11 (1) and <br />the permit application. Based on the vegetation transect summary table submitted in Appendix 2 of <br />SL12 the required number of samples taken was adequate. The operator sampled 48 points throughout <br />