2011-08-22_APPLICATION CORRESPONDENCE - C2010088 (2)

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Mike Boulay -17- August 19, 2011 The suggestion that the seed mixture be correspondingly modified to include Inland Saltgrass is also biologically troublesome. Yes, this seed could be included in the seed mixture, but studies by Cluff 1983 and 1988 as published in the Journal of Range Management, clearly document that this species cannot tolerate the high salinity levels, which according to the Soils Baseline Report contain EC values which range from a low of 1.62 to a high of 60.2 and average 28.86 dS /cm. These soils are also particularly high in sodicity, with SAR values ranging from a low of 7.23 to a high of 145 and average 59.51. The research by Cluff, clearly documents that this plant will simply not grow under such saline and highly sodic conditions as are associated with this site. Revegetation strategies of this plant published by the Fire Rehabilitation Unit of the US Forest Service in Ft. Collins, recommend that if this plant is seeded, it must be irrigated for at least the first year to become established. Due to the absence of irrigation waters to the Applicant, this is not a "reasonable" reclamation alternative. Furthermore, we are unaware of a single instance where this species has been successfully seeded under dryland conditions were the precipitation according to the permit text in Section 2.04.8 averages only 9.24 inches per year and the soils so adverse. Yes, this species could be added to the seed mixture, but it would be a total waste of time and money with no realistic expectation that any would ever grow. For these reasons, we have to decline the Division's suggestion. Division Response: In CAM's response to the Division's suggestion to add inland saltgrass (Distichlis spicata) to the seedmix, it was explained that inland saltgrass was only present on the wet, irrigated fringes of the reference area. Based on this fact that was not self evident in the data provided, the Division agrees with CAM to not include it in the seedmix. The Division does believe that a 2% perennial grass cover should be included in the vegetation success criteria. It is noted that the only perennial grass to contribute to cover data was inland saltgrass, however, ten native perennial grasses are present on the site. Please include a 2% perennial relative grass cover in the vegetation success criteria. CAM - A 2% perennial relative grass cover was added to the success criteria on page 2.05 -38. 76. Item resolved. Rule 2.05.4(2)(f) Disposal of Debris, Acid Forming and Toxic Forming Materials 77 -79. Items resolved. Rule 2.05.4(2)(h) Other Permits 80. Item resolved.