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2015-05-12_REVISION - C1981014
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2015-05-12_REVISION - C1981014
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Last modified
8/24/2016 6:00:14 PM
Creation date
5/13/2015 9:30:57 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981014
IBM Index Class Name
Revision
Doc Date
5/12/2015
Doc Name
Adequacy Review Responses
From
Energy Fuels Coal Inc
To
DRMS
Type & Sequence
TR45
Email Name
JHB
DIH
Media Type
D
Archive
No
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demonstrates an extremely poor understanding of their regulations and associated guidance <br />documents. <br />EFCI was unable to find any definition in the Division's regulations of what constitutes a <br />"poisonous species." Thus, the definition of "poisonous livestock plants" as used in this <br />evaluation comes from one of the most recent treatments on the subject. Pinter and others <br />(2011), who define a "poisonous" plant as one that results in "losses that result from death of <br />livestock, abortions, photosensitization, decreased production, emaciation, and birth defects." <br />The second concept with respect to "poisonous plants" deals with the ecological principal called <br />`allelopathy" which directly means (= harmful to the other) or chemical inhibition by one plant <br />over another. Accordingly, the definition of Pinter and others (2011), can also be applied to the <br />interactions of plants, which would mean that in the interspecific relations between one plant and <br />another plant, the plant that causes the death of another plant, or results in decreased production <br />or growth would also have to be considered as a "poisonous" plant. <br />Poisonous Livestock Plants <br />In this evaluation of poisonous livestock plants in Colorado, only the issue of woody plants will <br />be addressed, because the currently designed State of Colorado noxious weed list addresses all of <br />the herbaceous species found in the Southfield Mine site. In the two years of intensive <br />vegetation sampling performed on the three currently approved reference areas at the Southfield <br />Mine, in connection with Phase III final bond release, a total of fifteen different shrub or tree <br />species where encountered in the two hundred and twenty 100 square meter belt shrub density <br />transects and the number of plants encountered sampled in 2013 and 214, including: Gambel <br />Oak (Quercus gambelii - 3,358), Skunkbrush (Rhus trilobata - 398), One -seed Juniper <br />(Juniperus monosperma - 254), Pinyon pine (Pinus edulis 193), Alderleaf Mountain Mahogany <br />(Cercocarpus montanus - 183), Snowberry (Symphoricarpos rotundifolius - 166), Ponderosa pine <br />(Pinus ponderosa - 29), Wild Cherry (Prunus pensylvania 26), Singleleaf Ash (Fraxinus anomala <br />- 22), Rubber Rabbitbrush (Chrysothamnus nauseosus - 11), Hoptree (Ptelea trifoliata - 3), <br />Virgins Blower (Clematis columbiana - 2), Douglas Rabbitbrush (Chrysothamnus viscidiflorus - <br />1), Big Sagebrush (Artemisia tridentata -1). <br />The first poisonous plant reference consulted was DiTomaso (1994) who reported that of these <br />fifteen woody plants, six species have been documented as being poisonous to livestock. <br />Gambel Oak - poisonous to cattle and horses in the west with a reported occurrence of common. <br />Mountain Mahogany - poisonous to cattle and sheep in the west with a reported occurrence of <br />infrequent. Ponderosa pine - poisonous to all classes of livestock in the west with a reported <br />occurrence of occasional. Wild Cherry - poisonous to cattle in the west with a reported <br />occurrence of occasional. Rubber Rabbitbrush - poisonous to cattle, sheep and horses in the west <br />with a reported occurrence of rare. Big Sagebrush - poisonous to sheep and horses in the west <br />with a reported occurrence of rare. <br />The second poisonous plant reference consulted was Pinter and others (2011)) who reported that <br />of these fifteen woody plants, four species have been documented to be among the thirty most <br />common poisonous plants to livestock. Gambel Oak - poisonous to cattle when consumed in <br />fairly large amounts for a period of 2 to 3 weeks and death will result when more than 75 percent <br />rd <br />
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