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~ i <br />Mr. Allen Weaver <br />Energy Fuels Coal, Inc. <br />-2- <br />September 28, 1992 <br />reclaimed cover. Alternatively, two warm season species could account for 50-plus <br />percent of the cover. In any case, Energy Fuels' species establishment is inadequate, as <br />both dominant grasses are cool season species. <br />The standard in place is actually fairly lenient and allows more flexibility than if the <br />Division were to go strictly by the baseline data. This standard is very achievable and will <br />provide for a good, permanent, diverse vegetative cover. The Division can accommodate a <br />modification of the diversity standard, but EFCI should anticipate that it will include a lot <br />more warm season species. <br />The woody plant density success standard is also brought into question in this report. The <br />current standard is a bit unclear in that a direct count of shrubs on the reclaimed area is to <br />be compared with a similar count on the reference area. The unclear part is that a "t-test" <br />would be utilized to evaluate data equivalence. This is not necessary if all shrubs are <br />being counted (essentially a censusl. This section should be revised to state that woody <br />plant density will be deemed successful if the woody plant density on the reclaimed area is <br />either 90 percent of the reference area or, if true sampling is conducted, 90 percent of the <br />reference area with 90 percent statistical confidence. <br />There should be no confusion about what is considered a woody plant. The Division's <br />vegetation guideline clearly states that subshrubs or half shrubs are not considered woody <br />plants. The guideline specifically identifies Artemisia frigida, Artemisia ludoviciana, <br />Ceratoides Janata, Xanthocephaluna sarothrae, and Yucca glauca as half shrubs or <br />suffruticose species. Cacti should also be included in this group. Because cacti, half <br />shrubs and subshrubs are not considered woody plants for the purpose of meeting woody <br />plant densities, it was not surprising that woody plants were rarely encountered during <br />sampling. This should not present a problem for revegetation determination, however, as <br />success is currently based on reference area comparisons. <br />Please respond to the question about the planting of woody stems within 30 days. If you <br />have any questions about the other observations, please do not hesitate to call. <br />Sincerely, <br />t' C2 P t~'I ~/~% l (J ~ ~~ <br />Catherine W. Begej <br />Reclamation Specialist <br />CW B/bjw <br />cc: Tony Waldron <br />M:\oss\bjwlcwb <br />