Laserfiche WebLink
is composed of greater than 50% of the species of concern (NRCS Plants Fact Sheet). <br />Gambel's oak is an important plant species to wildlife species, particularly Mule deer, <br />Elk, and Black bear. "Oak brush provides cover and nesting habitat for many forms of <br />wildlife. Acorns produced by the larger stands of oak brush are critical for turkeys." <br />(CSU Extension Gambel's Oak Management fact sheet No 6.311). Gambel's oak is <br />naturally occurring in the reference area, and is an important component of the woodland <br />community for purposes other than grazing of domestic livestock. <br />EFCI states on page 9 of the PAR response that the CDRMS is directing EFCI to plant <br />Oakbrush and one -seeded juniper this late in the reclamation plan. DRMS believes this <br />statement is in error. The Division's Adequacy concern No. 3 notes, "Division does not <br />consider it appropriate to selectively exclude Juniper and Oak brush in the woody stem <br />success values." Apparently EFCI has incorrectly interpreted that the Division is <br />directing EFCI to plant Juniper and Oakbrush at this stage of the reclamation plan. The <br />Division has not suggested that EFCI revise the reclamation plan. The Division <br />questioned EFCI proposal to selectively exclude specific species from the woody plant <br />density sampling of the reference areas. The Division has not directed EFCI to plant <br />Gambel's Oak, nor remove it from the existing undisturbed areas. The Division refers to <br />Colorado Department of Agriculture for listings of noxious and restricted plant species. <br />Juniper (one -seeded or Rocky Mountain) or Gambel's oak are not listed as noxious <br />species. <br />EFCI approved shrub transplants (Page 2.05.4-23) included: One -seeded junipers (EFCI <br />transplanted Rocky Mountain Juniper MR53), Ponderosa pine, Skunkbrush sumac, <br />Pinyon pine, Red cedar, and Mountain mahogany. EFCI did not consider these species <br />undesirable prior to transplanting these shrub and tree transplants in 2004. <br />EFCI makes a point that other mines throughout the state have different technical <br />standards with regards to woody plant density success standards. The Division is in <br />agreement with this statement. Mine permittees throughout the state have evaluated <br />woody plant requirements based on site specific requirements, critical wildlife use, and <br />post -mining land uses. Sometimes theses standards were determined at the initial <br />permitting efforts. However, it is not unusual or unprecedented for permittees to provide <br />additional information, or propose innovative reclamation plans that result in a change to <br />the reclamation success standards. This process has been previously explained to the <br />landowners. The Division recognizes that EFCI's consultant has repeatedly voiced <br />concerns over what the consultant considered a high woody plant density standard. The <br />Division even identified this concern to the operator in 1997. EFCI has chosen not <br />submit a revision to the woody plant density success requirement until TR45. <br />EFCI provided examples of approved woody plant standards from mines in northwest <br />Colorado. Many of the cited examples were large surface mines located in considerably <br />different ecological site conditions than the Southfield mine. Mines in the Purgatory <br />River valley may be a more appropriate comparison for woody plant density <br />requirements. Please remember when citing these approved woody plant density <br />requirements for other mine sites, there may be more than one condition. One example <br />