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Aside from the PIS rate the Division's only concerns with this diverse seedmix was <br />the weighting of 99% of the "lbs./acre PLS" to grass species, and the inadvertent <br />elimination of the legume component in the overall mix. The Division chooses not <br />to approve the October 2, 1996 proposed seedmix which would change the seedmix <br />makeup to: <br />seven (7) cool season perennial grasses (70%) <br />one (1) perennial forb (11%) <br />two (2) perennial legumes (19%) <br />eliminate the strip seeded shrub component <br />Although the proposed seed mix reduces the overall component of the grass species, <br />it also eliminates other components of the mix, 2 perennial forbs, 3 perennial warm <br />season grasses and all shrub seed, that are desirable and necessary to achieve the <br />annro~ed post-mining reclamation standards. The Division considers that the seed <br />mix components were already agreed upon during the original permitting process <br />and sees no reason to change them. The post-mining land-use has not changed over <br />the majority of the permit area. <br />The Division is in agreement with the relative seeding rate proposed in Table 5-6. <br />The proposed seeding rate reflects 37 PLS/sq.ft. as opposed to 350 pls/sq.ft. in the <br />r v seed mix. The proposed lifeform composition of Table 5-6 reclamation <br />seedmix is unacceptable to the Division. <br />11.6) In OEI's letter to DMG, dated June 18, 1996, OEI contends that "the species <br />composition standard set for the mine is inappropriate:' OE[ bases this statement on <br />comparison of the baseline communities. OEI alleges that, [no warm season grasses] <br />"were present in any of the pre-mining vegetation communities." <br />Review of Permit Appendix 4-6 "Baseline Vegetation Inventory" prepazed by <br />Western Resources Development Corporation, disputes this statement. Warm <br />season perennial grass species were indeed present in the Pinyon/Juniper Reference <br />area as represented by Bouteloua gracilis, Aristida longiseta, Nilaria jamesii, and <br />Bouteloua curtipendula. The Mountain Shrub reference azea had warm season <br />graminoid components of Aristides longiseta, Bouteloua cunipendula, and Bouteloua <br />gracilis. Affected azea Pinyon/Juniper Woodland also had a component of warm <br />season grasses represented by Bouteloua gracilis, Hilaria jamesii, and Bouteloua <br />curtipendula. The Division acknowledges that no one warm season graminoid <br />species comprised >3% of the relative vegetative cover. <br />However, both the ecological consultant preparing the report and the USDA Natural <br />Resource Conservation Service (formerly SCS) recognize warm season graminoids <br />as an important component of the Mountain shrub and Pinyon/Juniper Woodland <br />communities in Southwest Colorado. Western Resource Development Corporation <br />recommended a warm season graminoid component for the measure of reclamation <br />success in two of the three community types, permit appendix 4-6. USDA/SCS <br />Technical Guide 342, Critical Area Planting, recommends planting Hillaria jamesii, <br />Allwlai sacaton, and Sporabolus cyptand-us, on critical areas in this particular Land <br />