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Corey Heaps
<br />CAM Colorado LLC
<br />June 21, 2011
<br />Page 25
<br />Molly are "erect branches from a woody base ... " and for Scepweed, the stems are
<br />"slender ascending to spreading branches" with a "suffrutescent or definitely shrubby"
<br />growth form. Examination of various detailed photographs of these two species on the
<br />Internet suggests that the "bushy growth" or "definitely shrubby" growth form and
<br />spreading branches of Alkali Seepweed are characteristic of this species and none of the
<br />plants we called Gray Molly possessed these characteristics. We believe that all of the
<br />plants we observed are more typical of the reported growth habit and on -line photographs
<br />of Gray Molly rather than Alkali Seepweed as suggested by the DRMS.
<br />Leaves. Weber makes no mention of the leaf characteristics of these two species.
<br />Harrington reports that the leaves of Gray Molly are "mostly simple, 5 -30 mm long,
<br />narrowly linear, erect or ascending, acute, fleshy sessile, glabrous to sericeous," while the
<br />leaves of Seepweed are "1.5 to 3 cm long, green, linear, strongly flattened, acute or
<br />acuminate ... " Welsh reports that for Gray Molly, the leaves are "5 -25 mm long, 1 -2 mm
<br />wide, linear, semiterete or cylindric or round in cross section and fleshy" while for
<br />Seepweed the leaves are "0.5 -3.5 cm long, 1 -3 mm thick, subterete to flattened, abruptly
<br />short- petiolate ... " In our opinion, this distinguishing difference is the greatest factor
<br />allowing for differentiation of these two species. Our examination of these plants revealed
<br />no leaves 1.5 to 3 cm long and none that were flattened or acute. In terms of leaf size, leaf
<br />shape and the size of the small, fleshy, rounded cylindrical leaves, it is clear that this
<br />species is Gray Molly and not Alkali Seepweed.
<br />Flowers and Fruits. Weber has no information on the flowers or fruits of these two
<br />species. Harrington reports that for Gray Molly, the flowers are often "solitary or in 2's or
<br />3's, hairy; perianth in fruit 2 mm across, the wings 1.5 -2 mm long, conspicuous ... "
<br />While for Seepweed the flowers are "slender and lax; perianth lobes obtuse, rounded on the
<br />back; seed vertical or horizontal, 1 -1.5 mm broad." Welch reports that for Gray Molly, the
<br />flowers are "solitary or 2 -5, sessile in axils of scarcely reduced leaves, inflorescence often
<br />more than half the branch length, perianth segments pubescent, at least apically, 1 -1.5 mm
<br />long, hooded above, somewhat enlarged in fruit, ultimately keeled and with a membranous,
<br />striate wing to 2 mm long and 3 mm wide." While for Seepweed the flowers are "1 -8 per
<br />axil, calyx lobes equal, ca 1.5 -2 mm long, the lobes mostly rounded dorsally, nor horned or
<br />tuberculate, fruit horizontal or vertical, seeds 0.8 to 1.2 mm wide, black, shiny."
<br />Examination of the detailed photographs of these two species on the Internet reveals that
<br />the fruits of Seepweed are clearly "winged utricles" smaller but almost identical to those of
<br />Fourwing Saltbush, while those of Gray Molly are clearly "keeled and with a membranous
<br />striate wing. . . " The markedly different characteristics of the flowers and fruits of these
<br />two plants are sufficient to permit a quick differentiation between these two species. The
<br />pronounced "hairy" and "pubescent" nature of the flowers and the marked differences in
<br />the fruits clearly confirm that all of the plants we observed were Gray Molly plants and not
<br />Alkali Seepweed plants as suggested by the DRMS.
<br />This detailed discussion confirms the correct identification of the plant we identified as
<br />being Gray Molly and not Alkali Seepweed. Therefore, it is not necessary to amend the
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