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would take place during August each year) provided an excellent correlation to both total <br />vegetation cover and total herbaceous production for reclaimed areas, and to a slightly <br />lesser degree, the Osgood Sand reference Area. <br />CDRMS required that CEC utilize the data set from the Osgood Sand Reference Area for <br />development of any predictive equations (resulting in revegetation success standards). <br />The original data set included data from the Osgood Sand Reference Area from 1994 to <br />2002 (when the concept of predictive equations was originally proposed to CDRMS). <br />During the ongoing review of TR37, additional data for vegetation cover and herbaceous <br />production was collected from 2003 -2005, and at the request of CDRMS, incorporated <br />into the Osgood Sand Reference Area data set. <br />Ongoing review and recalculation of the predictive equations by both CDRMS and CEC <br />revealed that the additional data from 2003 -2005 did not improve the correlation or <br />regression value of the predictive equations. Further, CDRMS and CEC observed that <br />several of the drought years included in the data set appeared to skew the data set. <br />Therefore, CDRMS and CEC agreed to utilize only the data sets from the Osgood Sand <br />Reference Area that included calendar years 1995, 1996, 1997, 1998, 2000, 2001, and <br />2002 in development of the predictive equations for vegetation cover and all the above <br />years except 1996 for herbaceous production (no herbaceous production data was <br />collected in 1996). The calendar year 1999 was excluded from the data set at the request <br />of CDRMS, as it was considered non - representative (too dry). <br />Additional review and negotiation resulted in finalized predictive equations for total <br />vegetation cover (y= 0.0173x - 0.8592x +14.562x- 47.015) and total herbaceous production <br />(y= 0.3749x 2 ' 2485 ), where "x" is the total cumulative precipitation from September to the <br />following July, and the calculated "y" value is the total vegetation cover or total <br />herbaceous production, respectively. <br />Revision of the Predictive Equations to Remove Prohibited Species <br />Data Set Revision <br />The added CDRMS requirement that all noxious listed species be removed from the total <br />vegetation cover and total herbaceous production data has been employed to revise the <br />original data set for vegetation cover and herbaceous production from the Osgood Sand <br />Reference Area for the calendar years 1995, 1996 (no herbaceous production data), 1997, <br />1998, 2000, 2001, and 2002. All other assumptions and negotiated agreements remain <br />the same for the revision of the predictive equations. The revised data used in <br />recalculation of the predictive equations sets are presented below. <br />Coors Energy Company Keenesburg Mine Page 2 <br />Response to CDRMS 2011 AHR Review: Revision of Revegetation Criteria <br />