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w <br />approvable for CCMC. A plan for early spring grazing to make use <br />of the early green forage produced by the cool season species, and <br />periodic monitoring to determine if the relative contribution of <br />warm season grasses increases with time would be recommended as a <br />part of the Revision. The local Soil Conservation District would <br />be able to assist the operator in developing a grazing plan to most <br />effectively utilize the cool season pasture. <br />At CCMC, the species diversity standard specifies that two shrub <br />species provide at least 3% relative cover, in addition to a <br />density standard of 333 stems per acre. This is somewhat unusual <br />in that, due to the growth characteristics of woody plants, <br />specific relative cover requirements are generally not required for <br />shrubs. Prior to mining, the affected area was a grassland <br />dominated by blue grama, with widely scattered shrubs such as <br />cholla, rabbitbrush, and snakeweed. Unless woody plants are <br />necessary for specific wildlife requirements within the 60-70 acre <br />reclamation site, it is possible that the woody plant density <br />standard as well as the diversity standard for woody plants could <br />be reduced or eliminated. The Operator may wish to include such a <br />request, with appropriate justification, if they submit a revision <br />to the reclamation standards. Consultation with the Division of <br />Wildlife would be required to insure that the change would not <br />negatively impact wildlife populations in the area. <br />Please feel free to include this memo along with my memo of <br />September 7 with any review comments you forward to Kaiser. Let me <br />know if you want to discuss these issues further. <br />cc: Dan Hernandez, Larry Routten, Janet Binns, Tony Waldron, and <br />Steve Shuey <br />