2011-08-10_APPLICATION CORRESPONDENCE - C2010088 (2)

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Corey Heaps CAM Colorado LLC August 10, 2011 P age 16 disturbance area of the Elam Borrow Area reveal a complete absence of any perennial grasses, especially Inland Saltgrass. A careful examination of the four transects in which this plant was found reveals that in every instance it was only found in the vegetation transition zone between the artificially irrigated areas or flooded drainage ways and the areas mapped as correspond to the Greasewood Vegetation type. Never once was this plant observed in habitats outside of these areas. The DRMS regulations found at Rule 4.15.8(3) and (4) require that cover on the revegetated area be at least 90 percent of the reference area cover and production. Rule 4.15.8(5) contains the species diversity success standard and says that "adequate species diversity" must be achieved on the revegetated area, without containing any specific standard. The suggestion now made by the Division that the proposed species diversity standard be modified to include at least one perennial grass which will contribute at least 3% relative cover appears to have originated from the suggestion found on page 13 of the Vegetation Guideline which states: "In general, for herbaceous vegetation, the number of perennial herbaceous plants contributing greater than 3 percent relative production or cover in the pre -mine data for each affected plant community designates the number of species, the seasonality and the Iife forms of the species to be established on the reclaimed area." As mentioned before of the 35 plant cover and the 60 production transects sampled in the pre - disturbance area, only four cover and production transects possessed any perennial plants. On a percentage basis perennial grasses, consisting of Inland Saltgrass contributed 0.17 percent of the total cover and 0.74 percent of the total herbaceous production found on this site. If the Applicant accepts the DRMS suggestion, it would be the equivalent of saying that the reclaimed area at the time of final bond release must have a species diversity standard 1,700 times more stringent than what existed prior to disturbance or that plant cover and herbaceous forage production on this site, must be 1,700 times more stringent than what existed prior to disturbance. Biologically it is impossible to accept this recommendation. 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