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Page 3 of 5 <br />July 1, 2013 <br />Rabbitbrush was recommended for inclusion in the reclamation seed mix by Colorado Division of <br />Parks and Wildlife (formerly Colorado Division of Wildlife). The DRMS did not recommend that <br />Rabbitbrush be included in the seed mix. As such Rabbitbrush was not included in the approved <br />seed mix and the Rabbitbrush observed on the reclaimed areas established as volunteer species. <br />The Division previously provided a response regarding Rabbitbrush to the Vento Group. On July <br />21, 2011, I provided an e-mail to Linda Saunders with an attachment: Natural Resource <br />Conservation Service (MRCS) plant guide for Rubber Rabbitbrush. Once again, although it may <br />not be an ideal forage species, it is not considered a noxious species and therefore, the Division <br />does not require that mine operators control it. <br />4) Please explain why the DMRS would consider the change in reference area in Year 10 of a 10 year <br />reclamation period. <br />Answer: As discussed previously, during our meeting with the Vento Group on January 9, 2012, Rule <br />3.02.3(2)(b) defines the minimum period of reclamation liability. "In areas where annual average <br />precipitation is twenty -six (26) inches or less, the minimum period of liability shall continue for ten <br />years." The climatological section of the permit (2.04.8) defines the normal annual precipitation in the <br />Southfield Mine area as 12.9 inches. <br />Please understand that the permittee is not eligible to apply for final reclamation bond release until a <br />minimum of 10 years have passed since the last "augmented seeding, fertilizing, irrigation or other is <br />required or conducted on the site. However, Rule 4.15.7(5) allows for activities that may be <br />considered "normal husbandry practices" without re- initiating the 10 -year liability period. Limited <br />repair of rills and gullies, weed control, management of pasture land, and limited interseeding on <br />rangeland or wildlife habitat are all considered normal husbandry practices. <br />A reclaimed mine must still meet the required reclamation success criteria before the Division can <br />approved reclamation bond release. Even though a mine site may have achieved the minimum liability <br />time period, the operator must still provide sufficient data to demonstrate that the reclamation success <br />criteria have been met. <br />Janet Binns met with Linda Saunders at the mine site on Thursday August 4, 2011. The Division <br />answered this question to Linda at that time: <br />"Reference Area Change -How can the Division of Mining change a reference area in year 8 of a 10 <br />year revegetation period? The reference area is the standard of comparison. If you change the <br />reference area, how do you know where you are and if you meet the revegetation standard. Or do we <br />start over with Year 1." (Received: August 3, 2011, 10:29 pm via e -mail) <br />Answer: Reclamation success evaluations can be made using comparison to one or more reference <br />areas, Rule 4.15.7(2)(d)(i). Operators may also propose evaluation of revegetation success with <br />comparison to a standard. A revegetation standard may also be based on premining data, approved <br />technical documents, historic record. <br />An operator may propose a change to a reference area for several reasons. Degradation of the <br />approved reference area may result in the reference area becoming a poor candidate for success <br />comparison. A change in ownership and land use of the reference area may make it necessary to <br />establish a new reference area. Additional information may be provided regarding the pre - mining <br />