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~ ~II ~I~~I~~I~~~~~ ~I~ <br /> :~ <br />~ 999 <br />MINED LAND RECLAMATION DIVISION <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />303 866-3567 <br />RA x: 303 832-8106 <br />STATE OF COLORADO <br />pF' Cp~O <br />tiE_ 9 <br />~P%x:18 <br />•• <br />ra 76 ~ <br />'~~ <br />Ray Ramer. <br />Governor <br />J anuary 17 , 1991 Divsion Da Bator <br />J.A. Stover and Associates <br />743 Horizon Ct., Ste. 205 <br />Grand Junction, Colorado 81506 <br />RE: Lillylands Baseline Vegetation Data <br />Dear Mr. Stover: <br />I reviewed the baseline vegetation information which you sent to the Division <br />with your letter of January 2, 1991. You requested comments from the <br />Division. The comments below are separated into two areas. The first set are <br />in regard to the format and content of what was submitted. The second set are <br />in regard to regulatory requirements which you will need to address with <br />additional submittals. <br />First, in regard to what was submitted: The vegetation inventory done by the <br />Soil Conservation Service is inadequate as a baseline study for several <br />reasons. Site specific data is required so, the information from Section 10 <br />cannot be used to characterize the proposed mine site. The Division would <br />also have a problem using 1G-year-old data to characterize a site. The 1987 <br />study of range site W-3 appears to be the only information from within the <br />permit area in recent years. <br />Herbaceous production data is provided for range site W-3. The permit <br />application needs to contain information indicating the means of collecting <br />this data. This would include sample weight from each clipped plot. These <br />numbers are necessary in order to ascertain the variance of the sample data so <br />that a determination can be made of whether an adequate number of samples were <br />collected. This is explained in detail in the Division's "Guidelines for <br />Compliance with Land Use and Vegetation Requirements" of which, I believe you <br />have a copy. <br />In addition, the permit application needs to include information regarding <br />vegetative cover, diversity and woody plant density. Field data for cover <br />needs to be submitted in the same manner as production data. The same is true <br />for woody plant density although, allowance may be made for sample adequacy <br />numbers in this instance, if there are large variations in the density of <br />woody plants. <br />The vegetation map submitted indicates two vegetative communities within the <br />permit area. These are identified as "Semidesert Sandy Loam Community" and <br />"Pinyon-Juniper Woodland" (communities should be identified based on visually <br />dominant species). The "semi desert sand loam" community may or may not be <br />