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• ~~~Jlt(i7 not hay z a :~~ood~~ stzri rc~. e__'eCa40^ reQ 111 re!Ilell[ Jtiler pl'OP~ISea QLSt[lrbanie alYa= <br />that ~wuld tali uuo -he ~?.Ikpuron ~eRztanon conununlnes ~yould oz prunar.lc limi[zd to <br />roads and the wtderground nottal areas. Due to the limited areal eaten[ of these pmooszd <br />disturbances in the oak-pin}'on community. the Division is nut cate,~oricall~ opposed to [his <br />reduction. ho«z~zr the only means of re-establishing sluubs that Lorencito Coal Compam <br />has proposed is by inclusion of shrub seed in the seed mix. <br />The Division. through past experience. has observed limited success of stuub establishtnzn[ <br />via inclusion of slli-ub send in a crass/forb seed mix. The Division continues to question the <br />po[emial sluub re-es[ablisiunent success possible at the Lorencito Udine ~~ithou[ <br />implementation of additional establistunent measures. <br />.As the Daly"pinyon reclaimed communities ~yill have ran~elandhvildlite as the post-minim <br />land use. the Division questions ~yhether the Colorado Division of R'ildl~fe is in a~rzzntznt <br />~yith the proposed reduction. <br />Response <br />LCC' proposed a reduced nuntbzr of shrubs in the surface none area due ro the primary <br />ST~Q intended post mini land use has livestock grazing. Ho~seczr. the CDO\V is interested in <br />establishins shrubs on the reclaimed area to provide habitat for wildlife. LCC requests <br />:~ additional time to develop appropriate plans for shrub establishment on the surface mini <br />area. Strip seeding and.'or plantins of mblin~s on bench areas and flatter slope arias ~yould <br />be utilized to achieve the shrub standard. .additional research would also be developed to <br />establish the methods to dztznnine rzyeeetation success for the shrlab standard. <br />191. .acquisition ano utilization of a ~"Iadge Rotoclear improves Lorencito Coal Compmtc~s <br />po[zntial for succzssfulh- re-establishing shrub species on the reclaimed site. .4s stated <br />previously. the Dig ision has obsen'ed numerous mine sites that have had caning stuub <br />zstablisiunent success throughout the state. Operations that have relied primarily on <br />~~\,p inclusion of shrub seed in a grass/forb seed mix as the soli method for sluub re- <br />l establishnttnt have had limited success. Obsen~ation of a mine site east of Trinidad with a <br />r~ similar habitat to the Lorencito propem~ included shrub seed in the gr:!ss/forb seed mix. <br />Tluee grov~ing seasons following seeding limited numbers of rabbitbrtr•It are found on the <br />~c~ j% site. no motm[ain mahogam hay z been noted. and occasional wintzrfat have been observed. <br />Thz Divisions observation has sho~~n that seedim~ the shrub seed separateh" ti'om a <br />~~rass/forb seed miz has a hiRhzr probability of stuub success. Thz Division continues to <br />question Lorencito~s proposal to seed shrubs direc[h with the grass/forb mix. [f Lorencito <br />Coal Company maintains that this seeding method ~yill achieve the proposed re~egetation <br />standard. the Division is ~cilfim~ to allo~~ a field trial initiated ~~ithin the first pe!n)it term that <br />could demonstrate that this seedim~ method is a viable method for achieyine successful <br />~~ood~ plant establislmten[ (Rule a. t ~.6(_ )). Should the Rotoclear be used or an alterna[ivz <br />. t~~ zsnthlishing shrub species be proposed. a field trial may not be necessary <br />,~ <br />