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Mike Boulay <br />-30- July 8, 2011 <br />plants per 100 square meters or 721.98 plants per acre. Since a total of 13 of the <br />25 density transects sampled had shrub density values of less than 500 plants per <br />acre or 12.35 plants per 100 square meters, CAM - Colorado LLC is proposing a <br />shrub density success standard of 500 stems per acre at the time of final bond <br />release. Permit page 2.05 -38 will thus be modified accordingly. <br />75. For the diversity success standard, the Division believes it would be appropriate to <br />also 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 <br />spicata) was the only species of grass that contributed to plant cover. The Division <br />suggests adding inland saltgrass (Distichlis spicata) to the reclamation seed mix. <br />For the diversity success standard, the Division believes that it is appropriate to <br />include a native perennial grass. Please add to the diversity standard on page <br />2.05 -38 that one perennial grass will contribute at least 3% relative cover. <br />CAM - Examination of the plant cover data collected from the Greasewood <br />Predisturbance Area in 2010 and from the Elam Borrow Area in 2011, documents <br />that of the 35 vegetation transects sampled for plant cover in these areas only four <br />of the transects had any cover represented by this plant. The overall average <br />cover of this plant across all of these areas was 0.17 percent. Furthermore, a <br />careful examination of the naturally revegetated areas associated with the old <br />refinery disturbances in the NE portion of the site and in the disturbance area of <br />the Elam Borrow Area reveal a complete absence of any perennial grasses, <br />especially Inland Saltgrass. A careful examination of the four transects in which <br />this plant was found reveals that in every instance it was only found in the <br />vegetation transition zone between the artificially irrigated areas or flooded <br />drainage ways and the areas mapped as correspond to the Greasewood <br />Vegetation type. Never once was this plant observed in habitats outside of these <br />areas. <br />The DRMS regulations found at Rule 4.15.8(3) and (4) require that cover on the <br />revegetated area be at least 90 percent of the reference area cover and <br />production. Rule 4.15.8(5) contains the species diversity success standard and <br />says that "adequate species diversity" must be achieved on the revegetated area, <br />without containing any specific standard. The suggestion now made by the <br />Division that the proposed species diversity standard be modified to include at <br />least one perennial grass which will contribute at least 3% relative cover appears <br />to have originated from the suggestion found on page 13 of the Vegetation <br />Guideline which states: "In general, for herbaceous vegetation, the number of <br />perennial herbaceous plants contributing greater than 3 percent relative production <br />or cover in the pre -mine data for each affected plant community designates the <br />number of species, the seasonality and the life forms of the species to be <br />established on the reclaimed area." As mentioned before of the 35 plant cover <br />