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p4` .i •. F u s. m..nru�r o� mr �wr�.ox <br />a� United States Department of the Interior {��u��.�W,M <br />BUREAU OF LAND MANAGEMENT <br />�4 $ UNCOMPAHGRE FIELD OFFICE <br />2465 South Townsend <br />Montrose, CO 81401 <br />www.blin.gov/co/st/en/fo/ufo.htinl <br />Delivered via email to taurine jestovera bresnan.net <br />Tamme Bishop, P.E. <br />J. E. Stover & Associates MAR 2 9 2018 <br />2352 North 7th St, Unit B <br />Grand Junction, CO 81501 <br />RE: Bowie Resources, LLC, Bowie No. 1 Mine — TR -63, Revised Revegetation Success Standard. <br />Dear Ms. Bishop: <br />This is to inform you that my staff has reviewed the Bowie application for TR -63. Our <br />recommendation is to approve both the requested changes to the revegetation success standards and <br />reduced diversity standard. <br />We have determined that: <br />1. The change in woody plant density is very reasonable. The original benchmark for success was <br />800-1000 woody shrubs or trees/acre which would be representative of a mature climax <br />vegetation community. Given the highly disturbed nature of some of the sites on the Bowie No. <br />1 mine this standard may not be achieved for many decades. The proposed benchmark of 100 <br />shrubs or trees/ acre has been demonstrated to be achievable and would set the reclaimed sites <br />on a successional pathway to achieve predisturbance shrub densities over time. <br />2. To achieve the current diversity standard would require reducing the amount and number of <br />native perennial grasses that offer good to excellent soil stabilization qualities which would <br />also reduce competition and allow for better forb diversity and greater relative cover. Given the <br />small footprint of most of the disturbances associated with the Bowie No. 1 and the steep <br />slopes where some of these disturbances are located it seems more prudent to achieve good site <br />stabilization with a competitive plant community that can resist weed invasion as well, rather <br />than achieving a more diverse community that could unravel due to erosion and or weed <br />invasion. <br />We agree with Janet Binns (CDRMS) that revised diversity standards include "perennial" in the <br />description of the success standard. Again, this is because perennial vegetation offers the best long <br />term soil stabilization and resistance to weed invasion. <br />