2015-05-12_REVISION - C1981014 - Laserfiche WebLink

Home Browse Search

Among the species of woody plants recommended by Monsen and others (2004) for planting in the Mountain Brush and associated Ponderosa Pine vegetation types, include among the species encountered or observed in the sampling performed at the Southfield Mine, they include: Mountain Mahogany, Rubber Rabbitbrush and Skunkbush Sumac. Species recommended for planting in the Pinyon- Juniper type receiving more than 15 inches of precipitation include: Fourwing saltbush, Mountain Mahogany, Rubber Rabbitbrush and Skunkbush Sumac. Totally absent from the planting recommendations of Wasser (1982), OSM (1988), Rutherford and Snyder (1983) of the Colorado Division of Wildlife, or of Monsen and others (2004) are there any recommendations to plant Oakbrush and One -seed Juniper which the CDRMS now says must be planted. Perhaps these all of these researchers as well as Mr. Casey Westbrook, who wrote the letter containing the CDOW recommendations regarding their reclamation recommendations at the Southfield Mine know something that the Vento landowners and CDRMS have not adequately considered, that these species have no benefit in the reclamation scheme in the West or at the Southfield Mine because they simply have too many deleterious efforts on other species. Perhaps these numerous individuals are among the "range scientists and ranches" identified by Engle and others (1983) who "continue viewing Gambel oak only as a noxious weed" or maybe they are not the ecological purest like some who pretend that all of these deleterious effects, which have been so consistently documented in the scientific literature regarding the dominant species of woody plants growing at this site do not apply to the Southfield Mine site. If these species are so important to the reclamation scheme at the Southfield Mine why has the CDRMS been silent on their inclusion into the reclamation plant for the past 35 years? Since all of the reclamation was finished in April 2004, with the transplanting of the tree and shrub transplants, now is not the time to require changes in the approved reclamation plan. Lastly, we conclude the discussion of "poisonous" plants with the comments of the landowners who said in their e -mail of 18 March 2015, that "vegetation that can be toxic to cattle or horse doesn't support our postmining use of grazing." Contrary to the opinions and statements of the landowners, a plant that the scientific literature documents only produces livestock poisoning only on a "rare" or "infrequent" basis (Rubber Rabbitbrush) is not the culprit but instead are those species ( Gambel Oak, Ponderosa Pine, Mountain Mahogany, Pinyon Pine, One -seed Juniper), which are well documented in the scientific literature as producing livestock poisoning on a "common," "frequent," or "occasional" basis are the real culprits, and these are the very plants that the landowners and the Division are saying now must be planted. Consistency of the Division's Previous Approved Woody Plant Density Revegetation Success Standards at Other Mines Having a High Pre - mining Density of Oak Brush and other Woody Plants. Aside from the fact that the Division appears to have essentially acquiesced to all of the landowners demands for the Southfield Mine, it is of great concern to EFCI that the Division has seemingly decided to change the rules at the end of the reclamation process at the Southfield Mine, and they seem to have ignored almost all of the previous permit approvals they have made within the State of Colorado with respect to the previous woody plant density revegetation success standards approved for other mine sites which have almost identical vegetation types as 0j