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Corey Heaps <br />CAM Colorado LLC <br />June 21, 2011 Page 24 <br />In a comprehensive vegetation study (CAM - Colorado LLC - Proposed Red Cliff Mine - <br />Exhibit 5 - Baseline Vegetation Survey) prepared in cooperation with the DRMS and the <br />BLM for the proposed Red Cliff Mine Draft Environmental Impact State, at a site located <br />approximately 12 miles to the north of this site, Kochia americana (Gray Molly) was <br />reported to be the most abundant perennial forb found in the Greasewood and Salt Desert <br />Shrub plant communities. Neither Alkali Scepweed (Suaeda moquini) nor any of its <br />synonyms are found on the list of plant species found on the proposed Red Cliff Mine Site. <br />In fact their photographic Plate ES -4, clearly shows a photograph of this plant, identical in <br />appearance to those found on the proposed Ioadout site Greasewood Plant Community. <br />The two primary reasons given by the Division as to why they consider the plant we <br />identified as Kochia americana (Gray Molly) as Alkali Seepweed (Suaeda moquini) <br />appears to be plant height "based upon plant stature, with many individuals exceeding 20" <br />in height (some as tall as 48" in favorable sites), and apparent lack of pubescence on leaves <br />and stems." <br />With respect to the different characteristics between Gray Molly and Alkali Seepweed, the <br />following taxonomic discussion is presented. <br />Plant Heights. According to the taxonomic manuals, plants heights are reported by Weber <br />to be less than 30 dm, 10 to 40 cm by Harrington and 5 to 30 cm by Welsh for Gray Molly <br />and over 30 dm by Weber, 30 to 80 cm by Harrington and 1 to15 dm by Welsh for Alkali <br />Seepweed. Given the wide range in plant heights, this is a very unreliable indicator relative <br />for plant classification and there are numerous more reliable traits which should be used. <br />Most of the plants we observed in our field sampling were typically less than 40 cm in <br />height. Never did we encounter any plants that we considered to be Gray Molly which <br />were 48 inches (122 cm) in height and most of the plants we encountered were less than <br />15- 18 inches (38 to 46 cm) in height. Based upon the nearly two weeks of time spent in <br />the field and observations made while clipping hundreds of these plants, it is our <br />professional 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. Harrington, <br />reports that leaves and stems of Gray Molly are "glabrous to pubescent," while Seepweed <br />is "glabrous." Welsh reports that the herbage is "villous- pilose to glabrous" and "glabrous <br />or pubscent, sometimes glaucous," respectively. The DRMS suggestion that given the <br />"apparent lack of pubescence on leaves and stems" this plant is "likely Alkali Seepweed." <br />is not a relevant 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 ... " and <br />that the stems are "erect, branched" respectively. Welsh reports that the stems of Gray <br />