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area that met the species diversity standard. The revegetation monitoring confirms that for <br />both sampling periods, the species diversity standard has been met. <br />Woody Stem Density <br />The areas subject to this bond release application are certain topsoiled portions of the Moffat <br />Area and West Ridge Area, certain non - topsoiled portions of these two areas, and the <br />Support Facilities Area. Of these, only the topsoiled portion of the Moffat Area has a woody <br />stem density (WSD) revegetation standard. This standard is 1000 stems per acre, and is <br />required to be achieved in only one year of the applicable ten -year liability period. <br />The 2005 sample data found that a WSD of 2119 woody stems per acre had been achieved in <br />the topsoiled portion of the Moffat Area. <br />The absence of certain woody stem species and the presence and use of rubber rabbitbrush <br />(Ericameria nauseosa) as a woody species was raised as a concern in the above mentioned <br />objection letter from the NRCS. Rubber rabbitbrush is a native species that was not included <br />in Chevron Mining Inc.'s approved seed mix for the Edna Mine. Woody species that were <br />included in the approved rangeland seed mix include Rosa Woodsii (Woods' rose), Prunus <br />virginiana (chokecherry), Cerocarpus montanus (mountain mahogany), Purshia tridentate <br />(antelope bitterbrush), Atriplex cansecens (fourwing saltbush), and Amelanchier alnifolia <br />(Saskatoon serviceberry). The presence of Woods' rose, chokecherry, antelope bitterbrush, <br />and serviceberry were observed during the July 20, 2009 bond release inspection. Although <br />rubber rabbitbrush may be a species with a somewhat high density within the areas requested <br />for bond release, other woody species are also prevalent. <br />Although rubber rabbitbrush has low forage value for cattle, according to USDA Forest <br />Service General Technical Report RMRS- GTR -136, Vol. 2, it is browsed on winter ranges <br />by mule deer, elk, and antelope, and provides cover for birds and small mammals. The <br />USDA General Technical Report also states that, "in most habitats, this species (rubber <br />rabbitbrush) is not overly competitive with herbaceous species, and on some sites, it does not <br />suppress grass. Production of herbaceous cover percentage have been notably greater when <br />rabbitbrush is present than when it is not present." The Division recognizes rubber <br />rabbitbrush as a successional species rather than one indicative of a climax community. <br />Since the Division is evaluating vegetation establishment at the end of a ten -year liability <br />period, one would not expect a climax community to be established by the end of the tenth <br />year. It should be noted that NRCS Plant Materials Technical Note No. 59 includes rubber <br />rabbitbrush as a suitable species for conservation plantings in Colorado. <br />Based upon the data submitted in the Phase III Bond Release Application and upon <br />observations made during the field inspection, the Division finds that the reclaimed bond <br />release areas for Edna Mine have met the WSD requirement approved in the permit. <br />Edna Mine Page 20 April 12, 2013 <br />Phase II. and III Bond Release <br />