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<br />G92-0B0: TR-01. adeaua~v ~csoonsea: Hem Rannev 'l <br />Although the proposed seed mix reduces the overall component of the grass <br />species, it also eliminates other components of the mix, 2 perennial forbs, 3 <br />perennial warm season grasses and all shrub seed, that are desirable and <br />necessary to achieve the a rov post-mining reclamation standards. The <br />Division considers that the seed mix components were already agreed upon <br />during the original permitting process and sees no reason to change them. <br />The post-mining land-use has not changed over the majority of the permit <br />area. <br />The Division is i^ agreement with the relative seeding ~g proposed in Table <br />5-6. The proposed seeding ~tg reflects 37 PIS/sq.ft. as opposed to 350 <br />pls/sq.ft. in the r v seed mix. The proposed lifeform composition of <br />Table 5-6 reclamation seedmix is unacceptable to the Division. <br />ll.b) In OEI's letter to DMG, dated June 18, 1996, OEI contends that "the species <br />composition standard set for the mine is inappropriate:' OEI bases this <br />statement on comparison of the baseline communities. OEI alleges that, [no <br />warm season grasses] 'tivere present in any of the pre-mining vegetation <br />communities." <br />Review of Permit Appendix 4-6 "Baseline Vegetation Inventory" prepared by <br />Western Resources Development Corporation, disputes this statement. Warm <br />season perennial grass species were indeed present in the Pinyon/Juniper <br />Reference area as represented by Bouteloua gracilis, Aristida [ongiseta, Hilaria <br />jamesii, and Bouteloua curtipendula. The Mountain Shrub reference area had <br />warm season graminoid components of Anstida longisera, Bouteloua <br />curtipendula, and Bouteloua gracilis. Affected area Pinyon/Juniper Woodland <br />also had a component of warm season grasses represented by Bouteloua <br />gracilis, Hilaria jamesii, and Bouteloua curtipendula. The Division <br />acknowledges that no one warm season graminoid species comprised > 3% of <br />the relative vegetative cover. <br />However, both the ecological consultant preparing the report and the USDA <br />Natural Resource Conservation Service (formerly SCS) recognize warm <br />season graminoids as an important component of the Mountain shrub and <br />Pinyon/Juniper Woodland communities in Southwest Colorado. Western <br />Resource Development Corporation recommended a warm season graminoid <br />component for the measure of reclamation success in two of the three <br />community types, permit appendix 4-6. USDA/SCS Technical Guide 342, <br />Critical Area Planting, recommends planting Hillaria jamesii, Alkalai sacaton, <br />and Sporabolus cyptandncr, on critical areas in this particular Land Resource <br />Area i^ addition to cool season grasses and perennial forbs. The r ~~ n..;,..,~ t_4 Plo:Fe. <br />County Soil Survey also recognizes a warm season component present in the <br />Loamy Foothills Range site description that these native communities <br />