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RULE 4 PERFORMANCE STANDARDS <br />Woody Plant Density — Pre -2008 Reve etg ation <br />Cedar Creek Associates, Inc.'s recent in-depth analysis of past "shrub conducive efforts" (report <br />dated April, 2007) attempted by Colowyo on older (pre -2008) reclamation has resulted in the <br />conclusion that such past efforts can largely be considered a failure and techniques such as bare - <br />root or containerized plantings should no longer be attempted. It has become obvious to all parties <br />concerned (including Colowyo, their consultants, the researchers at Colorado State University, the <br />CDRMS, and the CDOW) that reclamation practices utilized historically were far more conducive <br />to establishing herbaceous species at the expense of woody species. (It is for this reason that post - <br />2008 reclamation, using different reclamation techniques will have a different success criterion.) <br />Furthermore, the continued existence of herbaceous species at elevated densities, along with <br />browsing by big game animals, continues to preclude opportunities for establishment and/or <br />growth of woody species populations. In effect, historic (and expensive) attempts to establish <br />shrub populations into these "dense herbaceous stands" using the best technology available at the <br />time have met with nearly complete failure. Only a few remnant plants and "patches" of shrubs <br />remain in the reclamation, and many of those surviving plants were established from seed in the <br />mix as opposed to seedling planting. <br />In this regard, all parties (including the CDOW) are in general agreement that older (pre -2008) <br />revegetation at Colowyo's operations favors the livestock grazing aspect of the approved <br />Rangeland Land Use, and that the woody plant density component of those areas is largely <br />inconsequential for such use. However, it has been noted, that big game use, primarily by elk, of <br />the pre -2008 revegetation has been at substantially elevated levels over the past several years, and <br />occasionally has been shown to be problematic to area CDOW managers (as well as contributing <br />to the impact on shrub establishment. (See Enclosed CDOW letter below, especially the 3rd <br />paragraph.) <br />Therefore, the woody plant density success criterion within pre -2008 reclamation at Colowyo's <br />operations shall be 150 live stems per acre on approximately 3% (or more) of the reclaimed <br />surface. <br />Rule 4 Performance Standards 4-66 Revision Date: 11/27/18 <br />Revision No.: TR -129 <br />