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sativa) and Cicer Milkvetch (Astragalus cicer) were the most commonly encountered <br />perennial forbs. The 2010 report indicated the total allowable cover averaged 76.22% and <br />perennial plant cover averaged 53.59 %. For the 2010 data, perennial grasses Great Basin <br />Wildrye, Western Wheatgrass, Bluebunch Wheatgrass (Agropyron spicatum) and Sheep <br />Fescue dominated the seeded vegetation on the reclaimed site. Alfalfa and Cicer Milkvetch <br />were the most commonly encountered perennial forbs. <br />The vegetation cover percentages reported included parcel F -AB -01 which was removed <br />from the bond release block during the adequacy review process. Using the data provided in <br />the revegetation monitoring reports, the Division was able to determine what the allowable <br />cover average and perennial cover average for the bond release block would be excluding the <br />transects located in Parcel F- AB -01. Two transects were located in parcel F -AB -01 <br />(Transect No. 1999 -05 and 1999 -19). The Division's findings are discussed below. <br />Also, the revegetation monitoring reports data allowed cover from Cheatgrass (Bromus <br />tectorum) to contribute to the allowable cover percentage for some of the transects this <br />species was found in. Cheatgrass is listed as a List C noxious weed. The Division is unable <br />to allow plant species listed on the State Noxious Weed list (Department of Agriculture, <br />Conservation Services Division, 8 CCR 1206 -2: Rules Pertaining to the Administration and <br />Enforcement of the Colorado Noxious Weed Act to contribute to reclamation success. The <br />Division Guidelines; Guideline Regarding Selected Coal Mine Bond Release issues, April <br />18, 1995, specifically state that, "under no condition will noxious weeds count towards the <br />success standard." Based on the revegetation monitoring report data, cheatgrass had <br />contributed a small amount to the relative cover for the site and an insignificant amount to <br />the allowable cover percentage. The Division modified the data submitted in the 2011 and <br />2010 revegetation monitoring report to remove the contribution of Cheatgrass to the <br />allowable cover percentage. <br />Based on the Division's findings after removing the transects from F -AB -01 and the <br />contribution of Cheatgrass, in 2011, the rangeland reclamation block had a total allowable <br />cover average of 83.6 %. In 2010 the total allowable cover averaged 76.4 %. The range site <br />A reclamation success standard for cover is 52% (effective /allowable cover). Based on a <br />direct comparison, the average percent allowable cover for both 2011 and 2010 exceeded the <br />success standard for range site A. Revegetation on the requested reclamation blocks was <br />sampled to statistical adequacy for both years of sampling, 2011 and 2010. <br />The revegetation productivity success standard is 62.39 grams per square meter or 15.60 <br />g/1 /4 m for the Rangeland Reclamation Block. As recommended in the Division's <br />guidelines; annuals, biennials and shrub production were not included in the production <br />success. In 2011, the forage production on the site averaged 95.06 g/1 /4 m according to the <br />revegetation monitoring report. In 2010, forage production averaged 56.6 g/1/4 m As with <br />the herbaceous cover, TMI removed parcel F -AB -01 from the release application. Using the <br />remaining data provided in the revegetation monitoring reports, the Division was able to <br />determine what the revegetation productivity average for the bond release block would be <br />excluding the transects located in Parcel F- AB -01. For 2011, the forage production on the <br />site averaged 91.8 g/1 /4 m and 58.3 g/1 /4 m for 2010. Since the reclaimed area production <br />value exceeds the revegetation success standards, as allowed in the Division's existing <br />Trapper Mine Page 8 March 27, 2012 <br />Phase III Bond Release (SL -13) <br />