2018-09-04_PERMIT FILE - C1981019A

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RULE 4 PERFORMANCE STANDARDS trees in pre -2000 revegetation resulted in the following assessment by Cedar Creek Associates, Inc. (2006): "Given the assumptions presented, past and present shrub counts, as well as recent shrub mapping, it can be postulated that the planting of bare root shrubs and containerized trees from 1979 through 2000 can be considered a failure (<10% survival). Shrub populations or patches on an overwhelming majority of reclaimed surfaces [prior to 2000] are well below the [old] success standard of 1,000 woody plants per acre (except within fenced enclosures) and a majority of the surviving shrubs in open (unfenced) revegetation were not planted, but were apparently included in the seed mix (i.e. Big Sagebrush - Artemisia tridentata). There is no doubt that browsing by big game species, as well as competition from aggressive grass species such as smooth brome (Bromus inermis) and intermediate wheatgrass (Agropyron intermedium) have prevented germination and growth of shrub populations on pre -2000 revegetation. Therefore, future bare -root planting of shrubs on new and older reclamation is not recommended based on very poor performance in the past. Any effort to increase shrub densities on older (pre -2000) revegetation will prove to be very difficult and expensive with little or no chance for success given the present competition from established grass species and big game grazing pressures. Therefore, it is recommended that Colowyo continue discussions with the state agencies to alter, through technical revision, target land uses and bond release standards applicable to at least pre -2000 revegetation areas." In 2000, Colowyo Mine, along with the Seneca II and Trapper Mines, participated in a shrub establishment program identified as the "CSU/DMG Shrub Establishment Field Trials." This program is described below: CSU/DMG Shrub Establishment Field Trials Introduction and General Study Description Shrub establishment demonstration plots have been established at the Colowyo Mine, Seneca II Mine and Trapper Mine. The goal of the plots is to evaluate cost effective methods for establishing native shrubs on reclaimed lands. Native shrub establishment on reclaimed lands has been a challenge. Competition from herbaceous species and wildlife browsing present significant obstacles to establishment. Introduced cool season grass species in particular were frequently seeded in the recent past, and stands dominated by these aggressive grasses have suppressed establishment and growth of the slow growing native shrub species. The uniform replacement of topsoil, at depths ranging from 12-20 inches, may be another factor contributing to the homogenous grass community structure. Grasses thrive at the expense of forb and shrub species. The young shrub plants that do get established are highly desirable browse for deer and elk. Thus, heavy browse pressure creates another limitation for shrub establishment. Rule 4 Performance Standards 4-50 Revision Date: 5/25/18 Revision No.: RN -07