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' <br /> ~;:I. vegetation - r,,,l=_; .U4.1U, 2. U5.4;2)(ej ana ~.1: <br /> Tne following def is ien_ies nave been identified with respect LG <br />' VegetaLiOn 1ni0rmaL10n dntl ine reVegeLdtlOn plan d5 presented in the <br /> application. <br />' 1. iri the statistical analyses, proposed reference areas were <br /> included in the general population. Proposed reference areas were <br /> not co~pared to the oaseline population, reef erence area data <br /> should be removed from the affected area data and compared to the <br /> baseline data to oeter,oine equivalence. <br /> 2. Two reference areas have oeen identified and sampled for both the <br /> Aspen type and the Sagebrush type. Tne applicant should clarify <br /> how t~;d reference areas will be utilized for determination of <br />' revegetation success, and comparisons with affected area data. <br /> 3. The total acreage disturbed and proposed for disturbance in each <br />' vegetation type should be stated in the application. <br /> 4. kevegetation success criteria for species diversity and woody <br /> plant density are not addressed in the application. <br /> Since i~vestoc~, yraziny is Lne proposed primary post-mining lane <br /> use, and giver, the landowner request, shruo reestablishment ma; <br /> not be required. This determination will depend on resolution of <br />' the issues noted in Section XIII k'ildlife of this letter. r. <br /> proposal for evaluating species diversity and a species diversity <br /> standard, as required by Rule 4.15.&(5) must oe included in the <br />' application. <br /> 5, the primary seen mix, which includes a number of introduced forage <br /> grasses, including crested wheatgrass, may be appropriate given <br />' the land use considerations and landowner request. N concern <br /> expressed in the past with regard to crested wheatgrass is that, <br /> when used in a mix with native species it will tend to dominate <br /> the stand to the exclusion of other seeded species. This concern <br /> is based primarily on research in the northern great plains, but <br /> has not oeen documented in northwestern Colorado. The applicant <br /> should commit to a revegetation monitoring program which will <br />' document the competitive relationship among the various species. <br />' 6. During past site inspections, Division Reclamation Specialists <br />have noted evidence of sheep grazing on newly reclaimed areas. <br />Rule 4.15.5(2) specifies that grazing not be allowed on reclaimed <br />' areas until the Division has been satisfied that vegetation is <br />adequately established. Tne applicant should provide a plan for <br />excluding sheep from newly reclaimed areas. <br />' J. The applicant has stated that broadcast or hydroseeding rates will <br />be 1.5 times the drill seeding rates. The rate for hydroseeding <br />ar broadcast seeding should be twice that of drill seeding. This <br />correction should be made. <br />8. There is a contradiction between the text and Tables 4, 5, and 6 <br />' with regard to seeding rates. The text states (page IV-10) that <br />rates presented in the table "are suitable for hydroseeding; for <br />drill applications, the rates may be adjusted by a factor of .5". <br />The Tables state, "lo/acre drill; x 1.5 for braadcast or <br />hydroseed." This inconsistency should be corrected. <br />