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Production <br />With regard to the success criterion for production, the permit does not specify if the comparison for <br />success is total herbaceous production (all herbaceous vegetation lifeforms) or only herbaceous perennial <br />production. In comparison to cover, the variable of production exhibits lower utility regarding <br />"sustainability" of vegetation (over the foreseeable future) between reclaimed and native areas due to <br />the allowed omission of the shrub component during sampling. This is especially important at Snowcap <br />where shrubs account for between 35% and 85% of the adjacent, undisturbed perennial vegetation <br />cover and between 9% and 100% of the perennial composition of the revegetated areas in 2010. <br />Furthermore, a secondary role of production sampling is to provide a means for comparing the inherent <br />herbaceous productive capability of the soil and /or an exposition of any chemistry or texture adversities <br />that are long -term issues requiring mitigation. In this regard the best measure of the productive <br />capability of the soil is "total" herbaceous production that includes the annual grass and forb lifeforms <br />that are so ubiquitous to this ecosystem and climate. Using only the perennial herbaceous lifeform for <br />this comparison would only reveal the seeded perennial grass's and forbs'ability to establish and <br />compete with cheatgrass which is adequately addressed with the cover criterion. With this in mind, <br />Snowcap requests a technical revision of the production standard to read "90% of the total <br />herbaceous vegetation production of the approved reference area ". <br />Diversity <br />With regard to the diversity success standards, Snowcap is requesting two minor changes to those <br />that were formally adopted as of 2005. Snowcap is requesting that the total relative cover of warm - <br />season grass within a sampled unit be reduced to greater than or equal to 0.5 %. This change places this <br />lifeform on an equal par with those currently approved standards for cool- season grasses as well as the <br />forb and sub -shrub lifeforms. The original standard was set based on the "hope" that warm - season <br />grasses would be better able to compete with the annual brome infestation. However, given that the <br />moisture regime is only marginally favorable to warm- season species in the area of the mine and given <br />the total failure of several Best Management Practices to control cheatgrass through spraying and inter - <br />seeding over the recent past, a lower standard is apposite. The many difficulties created by annual <br />brome populations is well documented in the scientific literature. Furthermore, the deep loamy soils <br />extant in the area of the mine are conducive to shrub populations with an understory dominated by <br />cheatgrass and other annuals. Because of these conditions, attempts to achieve greater proportions of <br />perennial herbaceous species have most often proven futile. However, to compensate for this reduction <br />TR -60 A14 -11 -3 (New 01/11) <br />