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V <br />14 r. Bill Balaz - 2 - January 9, 1989 <br />revised the proposed seed mixture to reduce the seeding rate <br />for Agropyron smithii (Western wheatgrass), Agropyron <br />trac ycli-auTum ($Te~r wheatgrass), and Oryzopsi ys~menoides <br />n ian ricegrass); Kaiser also increase~T see ina' g cafe <br />for shrubs (the increase in shrubs was only for drill rate <br />and needs to also be increased for the broadcast rate). <br />However, neither the seeding rate for the forb species nor <br />the number of species of shrubs to be seeded has been <br />increased. Kaiser should increase these rates. <br />Stipulation 9 pertaining to the submission of an acceptable seed mixture to <br />the Division does not appear to have been fulfilled. Its status should be <br />considered active. It will be present in the findings document that is being <br />prepared unless Kaiser responds adequately before February 28, 1989. <br />2. Woody Plant Density <br />Section 2.9.1 (Collection and Analysis of Data) of Appendix H of <br />the permit application states that revegetated areas "will be <br />compared to the reference areas established during the baseline <br />study to assess revegetation success". If this were true, a woody <br />plant density of about 6000 stems per acre would be the standard <br />that reclamation would attempt to achieve. The Division believes <br />that this standard is unreasonably high. If Kaiser does not wish <br />to address woody plant density standards by February 28, 1989, a <br />stipulation will be included in the upcoming findings document <br />which states: <br />"Within 120 days of the permit renewal, the operator will <br />submit a woody plant density standard for reclaimed areas <br />which is acceptable to the Division." <br />3. Comparison of Reference and Revegetated Areas. <br />Appendix H contains a discussion of how revegetation data will be <br />collected and what formula will be used to calculate sample <br />adequacy. However, no discussion is included in compliance with <br />Rule 2.05.4(2)(e)(vi) aside from the general statement that <br />reference areas and reclaimed areas will be compared. A <br />description of what is needed to comply with Rule 2.05.4(2)(e)(vi) <br />is given in Rule 4.15.7. (Some of the information required by Rule <br />4.15.7 is already included in Appendix H). Unless Y.aiser wishes to <br />address this topic by February 28, 1989, a stipulation will be <br />included in the upcoming findings document that states: <br />"Within 120 days of permit renewal, the operator will submit <br />a full description addressing how revegetation success will <br />be determined in accordance with Rule 4.15.7." <br />