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Gary Isaac <br />CAM-Colorado, LLC <br />August 29, 2008 <br />Page 13 <br />Please revise the cited Volume 1 narrative sections to clarify that the subject vegetation <br />parameter is "vegetation cover", not "herbaceous cover". <br />35. Treatment and identification of species identified as "sub-shrubs" in the Exhibit 5 <br />vegetation survey is a bit confusing. Sub-shrubs comprise a significant component of the <br />Current Annual Production by Lifeform for the various primary vegetation communities <br />(Chart E5-3), but curiously do not appear as a lifeform category in Chart E5-1, Average <br />Cover Summary by Lifeform. Apparently, these species were lumped in with shrubs or <br />fortis (or maybe some in one category and some in the other) in the cover sample. The <br />species Kochia americana is sometimes referred to as a sub-shrub, but is classified as a <br />forb in the cover data, while species such as Ceratoides lanata, Atriplex gardneri, <br />Atriplex corrugata, and Gutierrezia sarothrae are often considered sub-shrubs, but are <br />listed as shrubs in the cover data. C lanata, A gardneri, and A. corrugata were tallied in <br />the woody plant density sample, but G. sarothrae was not. The line between sub-shrub, <br />forb, and shrub is not a distinct one, but clarification is warranted, both to more fully <br />describe the baseline data collected, and to establish the approach for handling these <br />species for purposes of bond release determinations. <br />The Division's 1988 baseline vegetation guideline notes that, in general, half shrubs or <br />suffruticose species (low shrubby perennials with woody bases but herbaceous upper <br />stems) should be included in cover and production, but not woody plant density <br />sampling. Sub-shrub is a term often used interchangeably with half shrub. The guideline <br />lists fringed sage (Artemisia frigida), Louisiana sagewort (Artemisia ludoviciana), <br />winterfat (Ceratoides lanata), snakeweed (Gutierrezia sarothrae), and soapweed (Yucca <br />glauca), as examples of half shrubs. <br />Please amend appropriate sections of Exhibit 5 to describe the species included as sub- <br />shrubs in the production data, and amend appropriate sections of Exhibit 5 and Volume 1 <br />narrative to address how species that may be considered sub-shrubs would be quantified <br />for purposes of revegetation success demonstration (e.g. would they be included in the <br />woody plant density sample to count toward that standard, or would current year's <br />growth be included in the production data to count toward that standard?). Include <br />rationale and authority citation for inclusion of any of the above referenced low growing <br />shrubby species as "woody plants" for purposes of revegetation success demonstration. <br />Division of Wildlife may offer input regarding species that should "count" toward the <br />woody plant density standard, based on forage value or structural utility for wildlife <br />species of concern. <br />Rule 2.04.11 Fish and Wildlife Resources Information <br />An outline description addressing the requirements of Rules 2.04.11 (1) through (4) is presented <br />in Section 2.04.11 of Volume I. Detailed wildlife resource information including appropriate <br />maps documenting seasonal use of the permit area by big game, location of prairie dog towns,