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Dan Mathews Aoril 4. 2007 <br />The report narrative on page 3 recommends modification of the standard, to <br />reflect the fact that cheatgrass (an annual grass) may exhibit relative cover <br />values surpassing 70% in some years, in reference areas as well as reclaimed <br />areas. We acknowledge this point, however the currently approved standard <br />includes an allowance to address this concern. As such, we do not believe the <br />modification recommended in the report is warranted. Please respond as to <br />whether you concur that the issue raised is adequately addressed by the <br />current standard. <br />SCC: The following is the comment we received from Cedar Creek Associates, <br />which Snowcap concurs. <br />"In retrospect, Cedar Creek concurs with CDRMS point and will make the <br />appropriate changes to the report so that when the next round of monitoring <br />occurs, the correct (and agreed upon) standards will be presented and compared <br />against. Specifically, we concur that the secondary allowance (within 5% of <br />reference area values if over 70% relative cover) adequately addresses the fact <br />that high levels of cheatgrass on the undisturbed lands surrounding the <br />revegetated units in bottomland areas will negatively impact the establishment of <br />desirable vegetation in the revegetation. Further, this diversity standard <br />addresses this problem in the most adequate manner possible at this time." <br />3. On Table 3 (Relative Cover Summary) for the various sampled areas, as well as <br />individual cover tables for specific reclaimed areas, intermediate wheatgrass <br />(Thinopyrum intermedium) is listed as a significant cover component for several <br />sites (North Decline Mine Dewatering System, Substation "B", CRDA-I Upper <br />Benches, and South Fan-West (Borrow Area). Intermediate wheatgrass has not <br />been included in the approved seed mixes for any of the Roadside Mine areas, <br />and it seems unlikely that it would have established at the rates indicated for <br />multiplesites seeded at different times, if it were inadvertently introduced as a <br />contaminant in the seedmix. We do not recall having observed any significant <br />presence of intermediate wheatgrass at the sampled locations. We will check for <br />the presence of the species during inspections over the course of the 2007 <br />growing season, and we will advise if our observations indicate that the listing of <br />intermediate wheatgrass may have been the result of mis-identification. <br />SCC: The following is the comment Snowcap received from Cedar Creek <br />Associates. <br />"We concur that intermediate wheatgrass was likely misidentified by our field <br />technicians during the site visit in 2006 and was not caught during data analysis <br />by Cedar Creek biologists. After reviewing the seed mixes used in the areas <br />listed above, it is likely that these grasses were actually the similar-appearing <br />streambank wheatgrass (Elymus lanceolatus ssp. psammophilus) or thickspike <br />wheatgrass (Elymus lanceolatus ssp, lanceolatus)." <br />4. We are in basic agreement with the summary findings and recommendations in <br />Section 4.0 of the report, regarding concern due to heavy annual grass <br />competition in various areas, as well as lack of particular vegetative components <br />(e.g. cool season grasses, warm season grasses, fortis/half shrubs) in various <br />locations. Herbicide treatment to suppress annual grasses, along with seeding of <br />