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m <br />JUSTIFICATION FOR FORB SPECIES DIVERSITY: <br />ONE FORB SPECIES WITH A FREQUENCY OF 50 PERCENT <br />The justification for one established forb species is that the original permit called <br />for a single forb species to be established. The proposed change in the forb diversity <br />standard maintains the original requirement for one species to be established. <br />Changing the establishment evaluarion factor to frequency rather than cover <br />considers how a species is distributed throughout the reclaimed area rather than on how <br />much of it is present Frequency values of at least 50 percent would suggest that a forb <br />species is distributed over at ]east 50 percent of the area. Data from native grassland and <br />shrubland reference azeas suggest that 45 forb species have frequency values greater <br />than 50 percent (Table 1). Establishment of one forb species with a frequency value of 50 <br />percent on reclaimed areas would be consistent with the species diversity requirements <br />for other life form groups. <br />Frequency data collected over the last two years (Table 1), suggest that the <br />overall forb diversity on native reference areas is greater than that measured on <br />reclaimed areas. 1n native reference azeas, 11-13 forb species were encountered and on <br />reclaimed areas 5-10 species were encountered. The data show that native forb species <br />that were not included in the reclamation seed mix are becoming established on the <br />reclaimed areas. Also, two forb species that were included in the seed mix (Penstemon <br />strictus and Achillea Ianulosa) are commonly encountered throughout the reclaimed <br />areas. <br />