2012-07-10_REVISION - C1981041 (7)

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There is no steep slope variance request from SCC associated with Permit Revision No. 5. IX. Revegetation Vegetation information reviewed by the Division can be found in Section 2.04.10, Tab 10, Volume 3; Revegetation Plan information is in Section 2.05.4 (2)(e), Tab 14, of Volume 5 of the application. Due to the fact that the Roadside and Cameo Mines were existing prior to enactment of SMCRA and the Colorado Act, no baseline vegetation data was collected from areas already disturbed by surface operations and facilities. The permittee established reference areas and gathered the appropriate baseline vegetation information prior to initial issuance of the permit. The vegetation surrounding the disturbed area is a sparsely covered salt desert vegetation type, and along the Colorado River a riparian vegetation type exists. Common salt desert species include grasses such as galleta Hilaria 'a� mesii Indian ricegrass Qr3yopsis hymenoides and squirreltail Sitanian hysWx and shrubs such as winterfat (Ceratoides Janata shadscale saltbush Atri lex confertifolia and fourwing saltbush (Atriplex canescens The riparian vegetation type is characterized by species including willows Salix sop.), cottonwoods Po ulus spp.), salt cedar Tamarix parviflora and bluegrass Poa spp.). Greasewood (Sarcobatus vermiculatus occurs along the margins of the riparian zone, and along ephemeral and intermittent drainages and adjacent colluvial toe slopes. During 1982, the permittee selected three community study areas to represent communities present prior to disturbance by mining. These study areas encompassed a greasewood shrubland community, a shadscale shrubland community, and a mixed greasewood shadscale community. During the summer of 1982, the study areas were sampled for vegetative cover, herbaceous production, woody plant density, species diversity, and threatened and endangered species. After review of the community character, it was determined that these study areas would serve as reference areas for revegetation success criteria for cover and production for areas previously disturbed. Various issues of concern were identified by the Division during the mid -term review of 1995 and subsequent PR -02 review, including questions regarding the applicability of the original vegetation study areas to serve as reference areas for all current and proposed future disturbance sites. Modifications to revegetation success demonstrations, seedmixes, and various aspects of the revegetation plan were requested, along with an updated endangered plant survey covering areas of proposed future disturbance. All issues of concern raised by the Division during the PR -02 review were adequately addressed. The operator had committed within the PR -02 amendments to conduct additional vegetation studies in areas to be affected by disturbances associated with the proposed CRDA -3, but such studies were not conducted, due to the operator's subsequent decision to withdraw CRDA -3 from the permit. Less than 4 acres of additional disturbance did occur within soil borrow area CBA -2 in 2002, in association with CRDA -1 reclamation. An endangered species survey was conducted within this area prior to disturbance, but vegetation cover, production, and woody plant density sampling was not conducted within the CBA -2 borrow area. Based on visual evaluation, and given the small area of disturbance, it is the Division's determination that the greasewood vegetation type within the subject area, is Permit Revision No. 5 42 July 10, 2012