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Southfield Vegetation Standards <br />TR45 January, 2015 <br />added] <br />The deleterious tree and shrub species mentioned by the CDOW are Pinion Pine, Juniper and <br />Oak - brush. EFCI interprets their recommendations as meaning that these species should not be a <br />component of the woody plant density revgetation success standard for this site. The numerous <br />comments by the Vento Group Landowners regarding their intentions of putting livestock on <br />their property clearly confirms that they also are not interested in the reestablishment of <br />excessively high numbers of woody plants which would significantly reduce the amount of grass <br />available for livestock grazing. <br />According to the science of Range Management, which has been gathered over the past century <br />and which is very well summarized in the NRCS `s National Range and Pasture Handbook, <br />issued in December 2003, there is a direct inverse relationship between grass production and <br />woody plant densities or canopy cover. High woody plant densities always result in reduced <br />grass production. Highest grass production is always associated with no or very low woody <br />plant densities. <br />Therefore, based upon these written directives, EFCI is proposing to implement the written <br />desires of the CDOW, the NRCS and the landowners by revising the proposed permit woody <br />plant density revegetation success values by subtracting out the contribution of Juniper, Pinion <br />Pine and Oakbrush based upon the site specific collected in the 2013 and 2014 revegetation <br />monitoring efforts and by applying the weighting factors approved in connection with TR -39. <br />PROPOSED PERMIT CHANGES <br />The Permit statement found on Permit page 2.05.4 -27a in the last sentence of the second <br />complete paragraph which reads; <br />If the absolute value of woody plant density for the reclaimed areas is greater than or <br />equal to that of the reference area or revised woody plant density count (grassland type) <br />for the 90 percent confidence interval, then revegetation will be deemed adequate relative <br />to woody plant density. <br />Will be deleted and replaced with the following statement: <br />The final woody plant density revegetation success standard for the reclaimed areas at the <br />Southfield Mine will be based on a weighted average value calculated from the respective <br />areas of the three reference areas as were approved in TR -39 for plant cover and forage <br />production. Based upon the recommendations given by the CDOW, wherein they <br />reported that Pinion Pine, Juniper and Oakbrush should be considered to be "invasive <br />species," EFCI believes that these species should not be included in the reclamation plan <br />nor in the calculation of the woody plant density revegetation success standard. <br />Therefore, the final woody plant density success standard will be made based upon shrub <br />density counts made during the 2013 and 2014 bond release sampling efforts. <br />Based upon the weighted averaging methods approved in connection with TR -39, the <br />8 <br />