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Colorado Hookless Cactus_ This species occupies habitats consisting of "rocky hills, mesa <br />slopes, and alluvial benches; in desert shrub communities. Elev. 4500 -6000 ft." According to the <br />distribution maps, the closest occurrence of this species to the proposed project site is <br />approximately 35 miles to the north in the extreme northern portion of Montrose County, where <br />it joints with Mesa and Delta Counties. Given the total absence of "rocky hills, mesa slopes, and <br />alluvial benches; in desert shrub communities," in the proposed NHN Mine permit area, it is <br />highly unlikely that this plant would occur on this site. <br />Examination of the Colorado Rare Plant Field Guide - 2002 supplement, addresses the potential <br />occurrence of three additional species of potential Rare or Endangered Plants which could <br />potentially occur on the proposed NHN Mine permit area are presented in the following <br />discussion. <br />Adobe thistle. This species is reported to occupy habitats consisting of "open areas and <br />disturbed sites in mixed shrublands and pinyon juniper woodlands. Elev. 5000 -8000 ft." <br />According to the distribution maps, the closest occurrence of this species to the proposed project <br />site is approximately 35 miles to the north in the extreme northern portion of Montrose County, <br />where it joints with Mesa and Delta Counties. Given the complete absence of "mixed shrublands <br />and pinyon juniper woodlands," in the proposed NHN Mine permit area, it is highly unlikely that <br />this plant would occur on this site. <br />Good - neighbor bladderpod. This species occurs in habitats between "Elev. 5800 -7500 ft." <br />According to the distribution maps, the closest occurrence of this species to the proposed project <br />site is approximately 50 miles to the east in the Uncompahgre Valley in the extreme southeastern <br />portion of Montrose County, where it joints with Ouray County. Given the great distance <br />between the proposed NHN Mine permit area and these sites, it is highly unlikely, if not <br />impossible, that this plant would occur on this site. <br />Aromatic Indian breadroot. This species occupies habitats consisting of "open pinyon juniper <br />woodlands, in sandy soils or adobe hills. Elev. 4800 -5700 ft." According to the distribution <br />maps, the closest occurrence of this species to the proposed project site is approximately 40 <br />miles to the west in the extreme western portions of Montrose County, where it joints with the <br />Utah line. Given the total absence of "open pinyon juniper woodlands, in sandy soils or adobe <br />hills," in the proposed NHN Mine permit area, it is highly unlikely that this plant would occur on <br />this site. <br />REVEGETATION SUCCESS <br />As required by Section 4.15.7, a suitable methodology must be developed to determine the <br />ultimate revegetation success standards for each vegetation type that will be disturbed. As <br />allowed by the Division's Guidelines for Compliance with Land Use and Vegetation <br />Requirements for Coal Mining, WFC is proposing two methods to quantify the successfulness <br />Section 2.04.10 Page 29 November 2011 <br />