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Mike Boulay <br />-16- August 19, 2011 <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 2% 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 />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 />