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05.21.2018 Memo Pg.02 <br />4. Please correct "typo" on revised page 2.05-75. The first sentence following Table 2.05.4- <br />5, starts out, "In Phase ID". The Division believes that this should read, "In Phase III". <br />LCC is proposing to include Winterfat, (Krascheninnikovia Janata) in the woody stem counts. <br />Historically, the Division has considered Winterfat a sub -shrub. However, observations over the <br />past 20 years at the Lorencito Canyon Mine have noted that Winterfat performs like a shrub at <br />this site, and does not die back to the crowns during the winter. <br />LCC included Winterfat (Ceratoides lanata syn. Krascheninnikovia lanata) in the Shrub Seed Mix <br />for Grassland Habitat, Table 2.05.4-2a. Plants.usda.gov website considers this species either a <br />shrub or a sub -shrub. The Plant guide on this species notes that it is considered a superior <br />winter browse for livestock and wildlife. "It is one of the most valuable browse plants for <br />maintaining the weight of adult animals on winter grazing ranges ... Winterfat has excellent <br />tolerance to browsing during the winter." <br />Due to the perennial shrub nature of Winterfat in this region of the state, the Division will accept <br />including Winterfat in the woody stem density counts for the Lorencito Mine. <br />5. LCC is proposing a cover standard of 500 stems per acre on areas considered to be <br />shrub plots. On revised page 2.05-72, LCC commits to sampling a minimum of 3 shrub <br />plots. Please define how large these shrub plots are anticipated to be. The permit <br />system shows that 129.3 acres of disturbance remain in the Lorencito Mine Permit area. <br />Do the shrub plots represent a percentage of the reclaimed area? The Division suggests <br />that the shrub lots represent some percentage of the reclaimed area. Five percent of the <br />disturbed area would be 6.5 acres, ten percent of the disturbed area would be 12.9 <br />acres. LCC needs to state how much area will be considered within the shrub plots for <br />sampling purposes. <br />LCC also provided a copy of the proposed Arcadis Sampling Plan: May 2, 2018. <br />6. On page 2. The Division finds an error in Equation 1: The denominator should read <br />(d*Xmean)Z [my keyboard will not allow me to enter X with a bar for sample mean] Rule <br />4.15.10(2)(a). Please assure that Arcadis uses the correct formula as shown in Rule <br />4.15.10(2)(a) for determining sample adequacy. <br />Please let me know if you have any questions. <br />