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Mike Boulay <br />-31- July 8, 2011 <br />and the 60 production transects sampled in the pre- disturbance area, only four <br />cover and production transects possessed any perennial plants. On a percentage <br />basis perennial grasses, consisting of Inland Saltgrass contributed 0.17 percent of <br />the total cover and 0.74 percent of the total herbaceous production found on this <br />site. <br />If the Applicant accepts the DRMS suggestion, it would be the equivalent of saying <br />that the reclaimed area at the time of final bond release must have a species <br />diversity standard 1,700 times more stringent than what existed prior to <br />disturbance or that plant cover and herbaceous forage production on this site, must <br />be 1,700 times more stringent than what existed prior to disturbance. Biologically it <br />is impossible to accept this recommendation. <br />The suggestion that the seed mixture be correspondingly modified to include <br />Inland Saltgrass is also biologically troublesome. Yes, this seed could be included <br />in the seed mixture, but studies by Cluff 1983 and 1988 as published in the <br />Journal of Range Management, clearly document that this species cannot <br />tolerate the high salinity levels, which according to the Soils Baseline Report <br />contain EC values which range from a low of 1.62 to a high of 60.2 and average <br />28.86 dS /cm. These soils are also particularly high in sodicity, with SAR values <br />ranging from a low of 7.23 to a high of 145 and average 59.51. The research by <br />Cluff, clearly documents that this plant will simply not grow under such saline and <br />highly sodic conditions as are associated with this site. Revegetation strategies of <br />this plant published by the Fire Rehabilitation Unit of the US Forest Service in Ft. <br />Collins, recommend that if this plant is seeded, it must be irrigated for at least the <br />first year to become established. Due to the absence of irrigation waters to the <br />Applicant, this is not a "reasonable" reclamation alternative. Furthermore, we are <br />unaware of a single instance where this species has been successfully seeded <br />under dryland conditions were the precipitation according to the permit text in <br />Section 2.04.8 averages only 9.24 inches per year and the soils so adverse. Yes, <br />this species could be added to the seed mixture, but it would be a total waste of <br />time and money with no realistic expectation that any would ever grow. For these <br />reasons, we have to decline the Division's suggestion. <br />76. Division response: Response accepted. <br />Rule 2.05.4(2)(f) Disposal of Debris, Acid Forming and Toxic Forming Materials <br />77. Division Response: Response accepted. <br />78. Division Response: Response accepted. <br />79. Division Response: Response accepted. <br />