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Gary Isaac <br />CAM-Colorado, LLC <br />August 29, 2008 <br />Page 12 <br />32. Map-03 lists two sub-types of the Salt Desert Shrub vegetation community (DSN and <br />BR) in the key, but does not clarify what the designations signify, and the small <br />inclusions of these sub-types are not delineated on the map. This information is provided <br />in Exhibit 5 and the sub-type locations are delineated on Map E5-1. <br />For clarity, please delete the two sub-type listings from Map-03, or include the sub-type <br />delineations and explanation on the map. <br />33. Appendix "A" of Exhibit 5 includes a description of the field survey conducted for rare, <br />threatened, and endangered plant species. The Appendix A narrative states that a site <br />specific search for all sensitive plant taxa was conducted on potential disturbance areas, <br />and that over 400 acres of potential disturbance received 100% survey coverage. <br />However, in the Introduction to Exhibit 5, on page 2, narrative indicates that surveys <br />encompassed nearly 100% of the surface of several proposed facility footprints (loadout, <br />roads, conveyor corridors, portal), and over 75% of the surface of remaining facility <br />footprints (refuse disposal). It is not clear why over 400 acres received 100% survey <br />coverage, but a portion of the proposed 65 acre refuse area within the proposed 227 acre <br />disturbance area was not surveyed. <br />Please provide an additional map or revised Map-03 with proposed disturbance area <br />boundaries and area encompassed by the 100% coverage survey delineated. In addition, <br />unless an acceptable explanation is provided for why additional survey is not warranted, <br />please provide a commitment to have the remaining areas properly surveyed by a <br />qualified botanist in the spring of 2009, with report from such survey to be incorporated <br />into the application prior to issuance of the Division's proposed decision. <br />34. Aspects of the baseline vegetation study are summarized beginning on page 2.05-62, <br />Volume 1, of the application text. Narrative in the third paragraph on that page appears <br />to contain erroneous information regarding the cover sampling procedure employed <br />(described in detail in Exhibit 5). Specifically, the Volume 1 narrative states that <br />"reference areas were sampled for herbaceous cover...", and that "species diversity was <br />determined utilizing herbaceous cover data from the premining baseline inventories..." <br />Exhibit 5 procedural narrative clearly explains that total vegetation cover was sampled in <br />the reference areas and affected areas included in the baseline survey, not solely <br />herbaceous cover, and that species diversity was determined based on composition <br />relative to total vegetation cover, not solely herbaceous cover. <br />Related errors occur later in the Volume I narrative section addressing reference area <br />comparisons. On page 2.05-67, the Section heading "Herbaceous Cover" should be <br />"Vegetation Cover", and three references in the first sentence beneath the heading to <br />"herbaceous cover" should also be "vegetation cover", to correspond to methods <br />described in Exhibit 5.