Laserfiche WebLink
<br /> <br />39 <br /> <br />applicable parameters with the exception that, where cropland is the approved <br />postmining land use, the permittee need only demonstrate that the proposed <br />rejerence area is comparable to the equivalent area to be disturbed in terms of <br />crop production. <br />LCC has failed to adequately make a valid statistical demonstration for Coniferous Forest <br />community disturbed vs. reference area, OaklPinyon community disturbed vs. reference <br />azea for woody plant density. Prior to any disturbance within these two community types, <br />LCC shall establish reference areas which comply with Rule 4.15.7(3). <br />191. "LCC proposes to establish a minimum density of 1000 stems per acre on revegetated <br />oak/pinyon pine communities." Permit application page 2.05-74. However, LCC proposes <br />to achieve this solely by inclusion of four species of shrub seed in the oak/pinyon seed <br />mix. With two decades of reclamation trials and successes throughout the state, the <br />Division has seen very limited success in establishing shrub species on reclaimed areas <br />by simple inclusion of shrub species in grass/forb seed mixes. The Division has observed <br />considerable successes in establishing shrub species through various additional methods. <br />A few methods that have achieved shrub establishment successes are; live haul transport, <br />strip seeding, concentrated shrub plantings, initial establishment irrigation. LCC needs to <br />provide further detail regarding woody plant establishment on the Oak/pinyon areas. An <br />additional comment, the oaklpinyon pine community is dominated by Gambel oak and <br />pinyon pine, permit application page 2.04-44, yet neither of these species aze proposed <br />to be replaced on the disturbed oak/pinyon areas. <br />192. Rule 4.15.7(2)(6) requires the operator to describe: <br />"Methods to be used in the measurement of all applicable parameters such as <br />vegetative cover and productivity, species diversity and woody plant density; " <br />LCC has not clearly defined how they counted woody plant density in the baseline or how <br />this will be collected during reclamation success sampling for shrubby species that are <br />prone to suckering. Please clazify how these species will be counted. <br />193. Permit application page no. 2.05-73 indicates that during sampling for revegetation <br />success, LCC will sample the disturbed grassland and the reference azea grassland for <br />woody plant density. The Division believes this statement to be in error. LCC has <br />proposed no woody plant density success standazd on the grassland communities. LCC <br />has proposed a woody plant density standard of 1000 stems per acre on the oak pinyon <br />pine community. Please revise this page appropriately. <br />194. The vegetation diversity standard for the grassland conununity proposed by LCC consist <br />of: <br />2 Cool Season Grass species @ > or = 5% and < or = to 30% of overall species diversity <br />1 Warm Season Grass specie @ > or = 5% and < or = to 30% of overall species diversity <br />