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At the request of Snowcap, Cedar Creek evaluated the species diversity success standard during <br />2001. Per Cedar Creek's recommendations from that evaluation, and given consultations with the <br />Colorado Division of Minerals and Geology (CDMG), new species diversity success standards were <br />temporarily adopted in 2005. They were as follows: <br />• Total perennial cool- season grass species relative cover >0.5 %. <br />• Total perennial warm - season grass species relative cover >_2.0 %. <br />• Total perennial forb and suffrutescent (sub- shrub) species relative cover >_0.5 %. <br />• No reclaimed area shall have a single species that represents greater than 70% relative cover, <br />with the exception of annual grasses. The annual grass component shall not exceed 70% <br />relative cover unless the annual grass component in the corresponding reference area also <br />exceeds 70 %. In such instances, the relative cover of the annual grass component of the <br />reclaimed area shall not exceed the relative cover of the annual grass component in the <br />reference area by more than 5 %. <br />In 2010, Snowcap requested Cedar Creek re- evaluate the vegetative cover, production, species <br />diversity, and woody plant density attained following multiple remediation attempts to combat cheatgrass <br />invasion of reclaimed areas, and to compare those values against the currently permitted success criteria <br />and standards. Per Cedar Creek's recommendations based on that evaluation, modest revisions to <br />success criteria and standards were proposed to facilitate a reasonable solution to a problem that <br />currently has no ecological resolution. These changes are only a slight deviation to prior standards based <br />on the pervasiveness of cheatgrass and the corresponding ecological issues. Extensive discussion of <br />these revisions to the success criteria are presented in TR -60 in Snowcap's reclamation permit. As a <br />result, the following are the current success standards that have been adopted. Criteria and standards <br />from TR -60 are summarized as follows (changes /clarifications are in boldface): <br />Perennial Vegetation Average Ground Cover Success Standard - Achieve 90% of the perennial <br />vegetation cover of the approved reference area. Snowcap elects to use perennial cover instead <br />of total cover due to annual species exhibiting between 77% and 82% of the vegetation <br />composition of the reference areas in 2011 and 2012. This accepted alternative is stated under <br />Section IV.A.3 in the Guideline Regarding Selected Coal Mine Bond Release Issues (CDMG, <br />1995). <br />Perennial Herbaceous Production Success Standard - Achieve 90% of the perennial herbaceous <br />production of the approved reference area. Snowcap elects to use perennial herbaceous instead <br />of total herbaceous production due to annual species exhibiting between 76% and 89% of the <br />vegetation production of the reference areas in 2011 and 2012. This accepted alternative is <br />stated under Section IV.A.3 in the Guideline Regarding Selected Coal Mine Bond Release Issues <br />(CDMG, 1995). <br />• Woody Plant Density Success Standard - Achieve woody plant density of 800 live shrubs per acre. <br />• Total Perennial Cool- Season Grass Relative Cover Success Standard - Achieve total perennial <br />cool- season grass species' relative cover of >_0.5% with at least two species present in the <br />reclamation (observed). <br />CEDAR CREEK ASSOCIATES, Inc. Page 8 Snowcap - Phase III Bond Release <br />Evaluation - 2012 <br />