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INTEROFFICE MEMORANDUM <br />TO: <br />ROB ZUBER <br />FROM: <br />JANET BINNS <br />SUBJECT: <br />AIARR MINE C1980 -006, TR25 <br />DATE: <br />5/29/2012 <br />CC: <br />DAN HERNANDEZ <br />KCC is proposing to evaluate reclamation success on the reclaimed area (8 acres) at the mine site and the <br />reclaimed Tipple area (11.7 acres) using a Forage Quality Index. The Forage Quality Index (FQI) will be used <br />to demonstrate that the vegetation on the reclaimed areas consist of species that support the approved post <br />mining land use (Rule 4.15.8(6). The approved post mining land use for the Marr mine and Tipple is <br />Rangeland and Wildlife Habitat (permit page 180 -127). The FQI would utilize comparison of Reclaimed area <br />cover ranked by forage utility to the reference area cover ranked by forage utility. This method of evaluation <br />meets the requirements of 4.15.7(2)(d). <br />Nothing in KCC's proposal of a Forage Quality Index for measuring suitability and utility of the reclaimed <br />area is counter to reclamation success regulations and Act. The proposed measure of forage quality suitability <br />is supportable by accepted industry references: NRCS Plants database and A Utah Flora by Welch. It is <br />repeatable and objective. <br />KCC will utilize the "suitability /use" characteristic of "palatable graze animal' as defined in the NRCS Plants <br />database ( http: / /plants.usda.gov to determine a "Forage Quality Ranking" A suitability rank of "high" <br />would be assigned a forage quality class (FQR) value of 5, medium equals a FQR value of 4, fair equals a <br />FQR value of 3, and low equals a FQR value of 2. Poor, indeterminate, or undefined would be assigned a <br />FQR value of 1. If no suitability /use value is defined in the NRCS Plants database, Welch's A Utah Flora <br />would be referenced as well. KCC will multiply the FQR value of each non - noxious plant species <br />encountered during vegetation sampling by the relative cover value of each species for both the reclaimed <br />area and the applicable reference area to determine a Forage Quality Value. The sum of each individual plant <br />species Forage Quality Value will result in a Forage Quality Index Value for the site. The resulting Forage <br />Index Quality Value for the reclaimed areas will then be compared to the Forage Quality Index Value for the <br />applicable reference area for each year of sampling. The reclaimed area Forage Quality Index Value for the <br />reclaimed areas would have to exceed the Forage Quality Index Value calculated on the applicable reference <br />area for the species diversity requirement to be satisfied. <br />The Division accepts the proposed method for determining reclaimed area success for species compatibility, <br />utility and diversity. The Division proposed to approve TR25 with the submittal of revised pages 780 -84a <br />and 780 -84b with the proposed text as provided in KCC's letter received by the Division on I\ fay 4, 2012. <br />