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Please be aware that the DRMS does not mandate which woody plant species must be used by a <br />permittee, so long as those species are compatible with local plant and animal species, meet the <br />requirements of applicable State and Federal seeded or introduced species, and are neither poisonous <br />nor noxious. As mentioned above, evidence of antelope bitterbrush, serviceberry, chokecherry, <br />Woods' rose and sagebrush, as well as snowberry, was observed during the July 20, 2009 inspection <br />within the areas requested for bond release. Although rubber rabbitbrush may be a species with a <br />somewhat high density within the areas requested for bond release, other woody species are also <br />prevalent. On-site observations noted that seeded woody species occasionally could be found growing <br />under cover of the rabbitbrush, which could have caused them to be missed during sampling. <br />Although rubber rabbitbrush has low forage value for cattle, according to USDA Forest Service <br />General Technical Report RMRS-GTR-136, Vol. 2, it is browsed on winter ranges by mule deer, elk, <br />and antelope, and provides cover for birds and small mammals. The USDA General Technical Report <br />also states that, "in most habitats, this species (rubber rabbitbrush) is not overly competitive with <br />herbaceous species, and on some sites, it does not suppress grass. Production of herbaceous cover <br />percentage have been notably greater when rabbitbrush is present than when it is not present." The <br />Division recognizes rubber rabbitbrush as a successional species rather than one indicative of a climax <br />community. Since the Division is evaluating vegetation establishment at the end of a ten-year liability <br />period, one would not expect a climax community to be established by the end of the tenth year. It <br />should be noted that NRCS Plant Materials Technical Note No. 59 includes rubber rabbitbrush as a <br />suitable species for conservation plantings in Colorado. <br />The Division's review of the SL-10 and SL-11 bond release applications will seek to determine <br />whether Chevron has established a diverse, effective and permanent vegetation cover of the same <br />seasonal variety native to the area that supports the approved post-mining land uses of rangeland and <br />wildlife habitat, and whether that vegetation is in compliance with the reclamation plan submitted in <br />accordance with the Board's regulations and approved by the Division in the Edna mine permit. <br />Thank you again for bringing your concerns to our attention. Copies of our Proposed Decision <br />Findings Documents for the SL-10 and SL-11 bond release applications will be forwarded to you when <br />they have been completed. If you have any questions before then, feel free to contact me at (303) 866- <br />3567 ext 8134 or at iason.musick(a-,state.co.us , or Janet Binns at (303) 866-3567 ext 8107 or at <br />j anet.binns(acr),state. co.us <br />Sincerely, <br />Jason Musick <br />Environmental Protection Specialist <br />Protection Specialist <br />(Inspection Report)