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<br />XI Vegetation (2.04.10, 2.05.4(2)(e), 4.15)
<br />There were many concerns regarding vegetation sections of Kerr's permit appli-
<br />cation. The Zarge majority were dealt with satisfactorily, however there are
<br />several concerns which were not resolved and must be stipulated.
<br />The items of concern which have been satisfactorily resolved will be dealt with
<br />first.
<br />The Division requested the removal of several introduced species from the Kerr
<br />seed mix (October 9, 1980). Kerr incorporated the requested changes (November 6,
<br />1980 letter to MLR). OSM requested removal of additional species (ACR). The
<br />Division did not feel the additional removal is necessary but agreed with OSM
<br />that a monitoring program should be undertaken by Kerr to insure that certain
<br />plant species do not dominate in revegetated areas. Kerr agreed to this and set
<br />forth general procedures for this monitoring in the December 23, 1980 letter to
<br />MLRD.
<br />The Division requested a qualitative description of the saltflat vegetation type
<br />found at the Kerr site (October 9, 1980, Setter to Xerr). Kerr provided this
<br />(November 6, 1980, Zetter to MLR).
<br />The Division expressed concern over maintenance of riparian vegetation _*ound in the
<br />draws on the Kerr site and requested Kerr to develop a separate seed mix for these
<br />small areas (November 6, 1980). Kerr responded by stating that seeds for these
<br />species were not available, but transplants of the seven main riparian species
<br />would be undertaken to reestablish the community type in the draws (December 4,
<br />1980).
<br />MLR requested that the management practices such as utilizing pesticides or herbi-
<br />cides, or controlled burning be approved by this Division prior to implementation.
<br />Kerr agreed to this request in their November 21, 1980, letter to OSM and corres-
<br />pondence to this office (December 4, 1980).
<br />Concern over statistical formula was expressed by 17LR in their Cctober 9, 2980,
<br />and November 6, 1980, Zetters to Kerr. Kerr responded adequately in their Novem-
<br />ber 6, 1980, and December 4, 1980 letters to MLR.
<br />An ongoing Division concern has been the revegetation success at the Xerr Tipple.
<br />At a meeting between MLRD, OSM and Kerr on November I0, 1980, the issue was dis-'
<br />cussed and in their December 4, 1980, letter to MLR Kerr made an acceptable pro-
<br />posal for revegetation success. Data from the proposed reference area wiZ1 be
<br />submitted no later than September 30, 1981, for Division analysis and approval.
<br />The sample adequacy of certain parameters in given vegetation types has been of
<br />concern to d1LR, and was questioned in our ~']ovember 6, 1980, December 5, 1980,
<br />and December 23, 1980, letters to Kerr and OSM's apparent completeness review.
<br />Kerr has responded to all concerns.
<br />The Division had a concern over failure of stubble mulch and the criteria for
<br />success (F1LR's November 6, 1980, December 5, 1980, and December 23, 1980) letters.
<br />Kerr responded in their Gecember 23, 1980, letter and clarified their response
<br />in a meeting held December 31, 1980, between Kerr and MLR. The plan submitted bu
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