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Corey Heaps <br />CAM Colorado LLC <br />June 21, 2011 Page 44 <br />impacts must be determined on the basis of local and regional conditions after consultation <br />with and approval by the Colorado Division of Wildlife (DOW). CAM must provide a <br />basis for not reestablishing woody plants; and documentation that DOW has been consulted <br />and that DOW approves of no shrub standard must be provided. <br />CAM Response: Please see revised page 2.05.36. Revegetation success criteria for the <br />woody plant density for rangeland and fish/wildlife areas will be based upon the <br />greasewood reference area. <br />Division Response: The language used to describe the woody plant density standard is <br />confusing and it is not clear if a reference area or technical standard will be used for <br />comparison to show success. The Division suggests that CAM use only the approved <br />greasewood reference area as a standard which achieves 90% woody plant density of <br />the approved greasewood reference area sample mean at the 90% confidence level. <br />75. For the diversity success standard, the Division believes it would be appropriate to also <br />include a half -shrub and a perennial grass component. <br />CAM Response: Please see revised seed mixes SM -1 and SM -2 in Exhibit 4. <br />Division Response: In the baseline vegetation survey, inland saltgrass (Distichlis spicata) <br />was the only species of grass that contributed to plant cover. The Division suggests adding <br />inland saltgrass (Distichlis spicata) to the reclamation seed mix. For the diversity success <br />standard, the Division believes that it is appropriate to include a native perennial grass. <br />Please add to the diversity standard on page 2.05 -38 that one perennial grass will <br />contribute at least 3% relative cover. <br />76. CAM is not proposing to sample for woody stem density in the revegetation. This is based <br />on the as yet to be approved proposal to not include a woody plant density standard. Since <br />shrubs are a major component of the baseline vegetation community, it is likely that shrubs <br />will also be a major component in the reclamation and therefore, the shrub density should <br />be collected. Please include data collection for woody stem density in the reclamation. <br />CAM Response: Please see revised page 2.05 -36. <br />Division response: Response accepted. <br />Rule 2.05.4(2)(f) Disposal of Debris, Acid Forming and Toxic Forming-Materials <br />77. Narrative in this section states that there is no indication that any -acid forming or toxic <br />forming materials will be encountered on site. While data in Tab 6 appear to confirm the <br />absence of acid forming materials, the absence of toxic forming materials is not supported, <br />and the narrative will need to be revised. "Toxic Forming Materials" is defined in Rule <br />1.04 (139) as "...earth materials or wastes which, if acted upon by air, water, weathering, <br />