2011-04-12_APPLICATION CORRESPONDENCE - C2010088

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Mike Boulay -18- April 11, 2011 woody plant density would not be warranted. However, the discussion in the subject paragraph related to OSM revised regulations regarding woody plant density standards and corresponding DRMS proposed rule changes is not correct, and should be omitted or amended. The referenced 2006 OSM rule change eliminated the rule that had required that 80% of woody plants used for success demonstration must have been in place for 60% of the liability period; it did not eliminate requirements for woody plant stocking or density. OSM rules have for many years required a woody plant stocking or density requirement for wildlife habitat and certain other postmining land uses, but not for grazing land postmining land use. The Division has submitted an informal program amendment to OSM and will initiate rulemaking this year, which includes changes to be consistent with the OSM rules in this respect. Please revise the narrative as appropriate. CAM: Please see the revised narrative, paragraph 5 on page 6 of Exhibit 5. 29. Table 2.04.10-3 "Greasewood Predisturbance Area-Plant Cover", referenced on page 8 of Exhibit 5, was not included in our copy of Exhibit 5. Please provide the subject table for inclusion in our copies of Exhibit 5. CAM: Please see Table 2.04.10-3 included as part of revised Exhibit 5. 30. In the third paragraph under "Plant Cover" on page 8, Exhibit 5, and various subsequent sections of the text and tables, gray molly (Kochia Americana) is identified as a dominant species in the greasewood affected and reference communities. The Vegetation section of the Wildlife Report (Exhibit 10), does not mention gray molly as an understory component, but does mention alkali seepweed (Suaeda moquini), which is not included in the Exhibit 5 data or species list. From our observations at the site, we believe the plant in question, a suffrutescent species (woody base and herbaceous stems) is likely alkali seepweed, based on the plant stature, with many individuals exceeding 20" in height (some as tall as 48" in favorable sites), and apparent lack of pubescence on leaves and stems. Please confirm the identification of the subject plant, and amend the exhibit as warranted. CAM: The Wildlife Report was changed to indicate Gray Molly is the dominant plant species on this site. Please see revised Exhibit 10 There is considerable evidence supporting our determination that the plant in question is actual Gray Molly and not Alkali Seepweed. The 1978 "Soil Survey of Mesa County Area, Colorado"found athttp://soils.usda.gov/survey/online Surveys/colorado / C0680/mesa pdf documents that the proposed Unit Train Loadout site is outside of the limits of this published soils survey. However, according to page 3 of the Wildlife Report, the dominant soil type on this site is the Skumpah silt loam. Mr. Dennis Grosett, soils scientist with the Grand Junction