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2015-07-22_REVISION - C1981014
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2015-07-22_REVISION - C1981014
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Entry Properties
Last modified
8/24/2016 6:09:18 PM
Creation date
7/27/2015 7:11:04 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981014
IBM Index Class Name
Revision
Doc Date
7/22/2015
Doc Name
Response to PAR Response Review (Second Adequacy Review)
From
Energy Fuels Coal, Inc
To
DRMS
Type & Sequence
TR45
Email Name
RDZ
Media Type
D
Archive
No
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Janet Binns <br />July 15, 2015 <br />Page 6 <br />Shrub and 84 percent in the Pinyon -Juniper vegetation types. Mule deer diets consisted of <br />approximately 89 percent shrubs in the Mountain Shrub and 95 percent in the Pinyon -Juniper <br />vegetation types. Gambel Oak was a dominant shrub in the Mountain Shrub vegetation types, <br />but was not present in the cattle diets. This study confirms the long accepted understanding in <br />the field of range management that cattle are grazers and eat primarily grass, while mule deer <br />are primarily browsers and eat primarily shrubs. <br />Working at the Central Plains Experimental Range on the short grass prairie in northeastern <br />Colorado, studying the grazing habits of cattle, Wallace and others (1977) obtained similar <br />results. In June cattle consumed diets consisting of approximately 86% grass and 14% fortis. <br />In July their diets consisting of approximately 90% grass and 10% forbs. In September their <br />diets consisting of approximately 96% grass and 4% forbs. In December their diets consisting <br />of approximately 99% grass and 1% forbs. <br />Working on the same site, Vavra and others (1977) reported similar findings. In June cattle <br />consumed a diet consisting of approximately 73.33 % grass, 20.00 % forbs and 6.67 percent <br />shrubs. In July their diets consisting of approximately 59.68 % grass, 33.24 % forbs and 7.08 <br />% shrubs. In August their diets consisting of approximately 63.66 % grass, 24.83 % forbs <br />and 11.51 % shrubs. In July their diets consisting of approximately 59.68 % grass, 33.24 % <br />forbs and 7.08 % shrubs. On lightly grazed pastures their diets consisted of approximately <br />63.43 % grass, 32.68 % forbs and 3.89 % shrubs. On heavily grazed pastures their diets <br />consisting of approximately 66.50 % grass, 22.40 % forbs and 11.10 % shrubs. <br />Working on the southern portion of the Great Plains at the Fort Stanton Experimental Ranch <br />in southcentral New Mexico on open grassland dominated largely by Blue Grama, <br />interspersed with Pinyon -Juniper on the slopes and at higher elevations, Pfister and others <br />(1984) reported that cattle diets over the two-year study consisted of approximately 60 <br />percent grasses, 30 percent forbs and 10 percent shrubs, consisting of Fourwing Saltbush and <br />Wavyleaf Oak. Their data were all presented in graphs so more refined estimates are not <br />available. These four representative grazing studies confirm that cattle and Mule deer do not <br />consume forage proportional to its abundance in the field, but rather in direct response to their <br />preference for those foods. <br />Changing Regulatory Definition of "Woody Plants." <br />One important point which needs to be pointed out is that the CDRMS (old CMLRB) has <br />changed the definition of shrubs since the original woody plant density requirement for the <br />Southfield Mine was originally developed in about 1980. <br />In the original federal OSM and state CMLRB regulations issued in 1977 and 1978 <br />respectively, all woody plants were initially included in the calculation of the woody plant <br />density revegetation success standard. Subsequent to this initial rule making, the OSM <br />revised their definition of woody plants and dropped half -shrubs or suffrutescent plants from <br />their definition of woody plants and the CMLRB did the same by changing Rule 4.15.8 to <br />read that the woody plant density includes the "number of countable tree and shrub stems per <br />unit area." <br />
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