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Corey Heaps <br />CAM Colorado LLC <br />June 21, 2011 Page 21 <br />28. The first paragraph on page 5 of Exhibit 5, under "Statistical Analysis of Data ", notes that <br />it was agreed that woody plant density would not be required to be sampled to statistical <br />adequacy, but rather would be sampled in association with each cover transect. This is <br />correct, as it was the Division's determination that a representative sample sufficient to <br />characterize woody plant density within the affected and reference area stands could be <br />obtained in this manner. Given the fact that disturbance to previously undisturbed habitat <br />would be limited to a very narrow disturbance corridor (the proposed rail spur) restricted <br />primarily to the greasewood vegetation type, it was concluded that more intensive sampling <br />of woody plant density would not be warranted. However, the discussion in the subject <br />paragraph related to OSM revised regulations regarding woody plant density standards and <br />corresponding DRMS proposed rule changes is not correct, and should be omitted or <br />amended. The referenced 2006 OSM rule change eliminated the rule that had required that <br />80% of woody plants used for success demonstration must have been in place for 60% of <br />the liability period; it did not eliminate requirements for woody plant stocking or density. <br />OSM rules have for many years required a woody plant stocking or density requirement for <br />wildlife habitat and certain other postmining land uses, but not for grazing land postmining <br />land use. The Division has submitted an informal program amendment to OSM and will <br />initiate rulemaking this year, which includes changes to be consistent with the OSM rules <br />in this respect. Please revise the narrative as appropriate. <br />CAM Response: Please see the revised narrative, paragraph 5 on page 6 of Exhibit 5. <br />Division Response: Response accepted. <br />29. Table 2.04.10 -3 " Greasewood Predisturbance Area -Plant Cover ", referenced on page 8 of <br />Exhibit 5, was not included in our copy of Exhibit 5. Please provide the subject table for <br />inclusion in our copies of Exhibit 5. <br />CAM Response: Please see Table 2.04.103 included as part of revised Exhibit 5. <br />Division Response: Response accepted. <br />30. In the third paragraph under "Plant Cover" on page 8, Exhibit 5, and various subsequent <br />sections of the text and tables, gray molly (Kochia Americana) is identified as a dominant <br />species in the greasewood affected and reference communities. The Vegetation section of <br />the Wildlife Report (Exhibit 10), does not mention gray molly as an understory component, <br />but does mention alkali seepweed (Suaeda moquini), which is not included in the Exhibit 5 <br />data or species list. From our observations at the site, we believe the plant in question, a <br />suffutescent species (woody base and herbaceous stems) is likely alkali seepweed, based <br />on the plant stature, with many individuals exceeding 20" in height (some as tall as 48" in <br />favorable sites), and apparent lack of pubescence on leaves and stems. Please confirm the <br />identification of the subject plant, and amend the exhibit as warranted. <br />