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Mike Boulay -21- April 11, 2011 <br />in the Greasewood and Salt Desert Shrub plant communities. Neither Alkali <br />Seepweed (Suaeda moquirn) nor any of its synonyms are found on the list of plant <br />species found on the proposed Red Cliff Mine Site. In fact their photographic Plate <br />ES-4, clearly shows a photograph of this plant, identical in appearance to those <br />found on the proposed loadout site Greasewood Plant Community. <br />The two primary reasons given by the Division as to why they consider the plant <br />we identified as Kochia americana (Gray Molly) as Alkali Seepweed (Suaeda <br />moquini) appears to be plant height "based upon plant stature, with many <br />individuals exceeding 20" in height (some as tall as 48" in favorable sites), and <br />apparent lack of pubescence on leaves and stems." <br />With respect to the different characteristics between Gray Molly and Alkali <br />Seepweed, the following taxonomic discussion is presented. <br />Plant Heights. According to the taxonomic manuals, plants heights are reported by <br />Weber to be less than 30 dm, 10 to 40 cm by Harrington and 5 to 30 cm by Welsh <br />for Gray Molly and over 30 dm by Weber, 30 to 80 cm by Harrington and 1 to15 dm <br />by Welsh for Alkali Seepweed. Given the wide range in plant heights, this is a very <br />unreliable indicator relative for plant classification and there are numerous more <br />reliable traits which should be used. Most of the plants we observed in our field <br />sampling were typically less than 40 cm in height. Never did we encounter any <br />plants that we considered to be Gray Molly which were 48 inches (122 cm) in <br />height and most of the plants we encountered were less than 15-18 inches (38 to <br />46 cm) in height. Based upon the nearly two weeks of time spent in the field and <br />observations made while clipping hundreds of these plants, it is our professional <br />opinion that all of the plants we observed were Gray Molly and not Alkali <br />Seepweed. <br />Pubescence. Weber has no discussion of the regarding this characteristic. <br />Harrington, reports that leaves and stems of Gray Molly are "glabrous to <br />pubescent," while Seepweed is "glabrous." Welsh reports that the herbage is <br />46 villous-pilose to glabrous" and "glabrous or pubscent, sometimes glaucous," <br />respectively. The DRMS suggestion that given the "apparent lack of pubescence <br />on leaves and stems" this plant is "likely Alkali Seepweed." is not a relevant <br />factor in differentiating between these two species, since both can lack <br />pubescence. <br />Growth Form. Weber reports Gray Molly "branching from the base" with Alkali <br />Seepweed "woody and branched at the base ... " and "forming bushy growth ... ' <br />Harrington reports "stems erect from stout woody roots and branched woody base <br />... " and that the stems are "erect, branched" respectively. Welsh reports that the <br />stems of Gray Molly are "erect branches from a woody base. . . " and for <br />Seepweed, the stems are "slender ascending to spreading branches" with a <br />"suffrutescent or definitely shrubby" growth form. Examination of various detailed