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<br />Examination of these shrub species mentioned in the Divison's Vegetation <br />Guidelines with those at the Southfield Mine Grassland Reference Area, reveals <br />that excluding the half shrub species identified in the Division's Vegetation <br />Guidelines, the most dominate shrub growing on the Grassland Reference Area <br />is Plains Prickly pear. It is imperative that the issue of "woody plants" be clarified <br />before the any precise recommendations can be made to address this apparent <br />deficiency and before the Southfield Mine spends money to address this <br />problem. <br />Examination of the species diversity standard reveals that this standard <br />was proposed and approved with no apparent consideration to the site specific <br />conditions found at the Southfield Mine. It has been previously pointed out that <br />from the 1980 cover sampling, Blue grams, the dominate plant on the Grassland <br />Reference Area accounted for 51.83 percent of the total cover. This same <br />species accounted for 41.5 percent of the total cover from the 1987 sampling <br />of this site. Production sampling of this area conducted by the SCS in 1980 <br />revealed that this species accounted for between 57 to 62 percent of the total <br />production of this site. These comparisons amply document that this single <br />species diversity standard has absolutely no bearing on the conditions found a <br />this mine and was apparently proposed and approved without considering the <br />site specific vegetative conditions associated with this site. There is no evidence <br />that the natural conditions of this site would ever satisfy this standard, let alone <br />any of the reclaimed areas. In addition, this standard is inconsistent with the <br />present Vegetation Guidelines of the Division, which set the maximum single <br />species standard based upon the dominate plants growing on the reference <br />areas and thus clearly should be revised. At a minimum there should be no <br />species diversity standard more stringent that conditions associated with the <br />corresponding reference area. It is recommended that the issue of species <br />diversity be addressed to the Division in a technical revision based upon the <br />baseline data available for this site. This submittal should be prepared and <br />15 <br />