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Page 2 of 5 <br />July 1, 2013 <br />The Plot B reference area approved previously in the Southfield Mine permit was not based on <br />baseline sampling of the portal area prior to disturbance. Disturbance at the portal area predated the <br />Colorado Surface Coal Mining Reclamation Act and associated regulations, and the state <br />requirement to sample an area proposed for disturbance prior to any disturbance has occurred. <br />Page 2.04.10 -4 of the permit states, "Because all these areas had been disturbed prior to the initial <br />vegetation work conducted at the site, reference areas were selected based upon visual similarities <br />and proximity to the disturbed sites. Accordingly, no comparison was possible to determine pre - <br />mine and reference area vegetation data for statistical similarity. However, baseline data collected <br />from these sites along with similar data collected during revegetation success monitoring as <br />described under Rule 4.15.7 will be utilized for statistical comparison in evaluating revegetation <br />success." <br />The Keenan Report (Exhibit 11) also states that, "vegetation type is influenced primarily by slope, <br />exposure, soil type, and available moisture. The permit area has been extensively disturbed by <br />previous mining, ranching, and other development activities. Vegetation types of the previously <br />disturbed mine entrance were determined on the basis of vegetation found in undisturbed similar <br />topographic areas and noted on the vegetation map." (Southfield permit, exhibit 11, p. 2 -1 and 2 -2) <br />2) How can the DMRS count rabbit brush as a revegetation species when it is listed as Win the Weed <br />Status in Keenan's inventory. <br />Answer: The Keenan inventory was conducted in 1980. Classification of vegetative species was <br />conducted referencing Thornton, Harrington, and Zimdahl (c) 1974. The Colorado Noxious Weed Act <br />(8 CCR 1203 -19) was promulgated in 2003. The Colorado Noxious Weed Act is administered by <br />Colorado Department of Agriculture. The Division of Reclamation, Mining and Safety refers to the <br />Colorado Department of Agriculture for determination of noxious weed species. As of June 26, 2013, <br />none of the Chysothamnus species were included on the Department of Agriculture A, B, or C list of <br />noxious weed species. <br />The DRMS does not allow noxious species (as listed by the Colorado Department of Agriculture) to <br />count towards reclamation success criteria. Rule 4.15.8(2) states that vegetation on the reclaimed area <br />shall consist of species that support the approved postmining land use. <br />3) It [ Rabbitbrush] has no nutrient value according to the Range Plant Handbook. The post mining use <br />will be rangeland and wildlife habitat. <br />Answer: Rule 4.15.8(2) states that vegetation on the reclaimed area shall consist of species that support <br />the approved postmining land use. As you state, the approved post - mining land use is rangeland and <br />wildlife habitat. <br />Although a specific plant species may have limited forage value for livestock grazing, it may fill a <br />niche for wildlife species. North American Range Plants (Stubbendiek, Hatch and Butterfield (c) 1992 <br />notes that Chrysothamnus nauseousus (Rubber Rabbitbrush) [Syn. Ericameria nauseosa] provides <br />fair forage value for deer on winter range. <br />