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<br />Comparison with other surface coal mine permits in northwest Colorado indicate <br />higher overall woody stem density standards than 250 stems per acre. Woody stem <br />density monitoring data from 1994 indicates that on sites that have had 5 growing <br />seasons, live shrub densities of 300 per acre are achievable. Again the Division does <br />aot consider that reestablishment of somewhat higher than 2-4% of the pre-mine <br />woody stem densities is undue in an region that is dominated by woody plant <br />communities. <br />The Division requests that Seneca Coal Company propose either a higher overall <br />woody plant density success standard or propose a higher density within the <br />concentrated shrub areas. <br />79. The response for monitoring and mitigating possible failures on the concentrated <br />shrub establishment areas by Seneca Coal Company is acceptable. <br />80. Seneca Coal Company proposes to create two Aspen establishment sites on the <br />reclaimed area, encompassing approximately three acres, and will designate Eve <br />Aspen avoidance sites totaling 2.3 acres. The Division agrees with this proposal for <br />the first permit term disturbance area. <br />81. Seneca Coal Company's response and revision to eliminate the steep Mountain Brush <br />type from the weighing formula for determining successful revegetation in the <br />reclaimed mine area is acceptable. <br />82. The typographical errors on Exhibit 10-1 have been corrected. <br />The Division reviewed comments submitted by other State and Federal agencies regarding <br />the Yoast Mine. Please inform the Division the status of the letter submitted by USFWS <br />on January 3 and March 8, 1995. In the letter dated March 8, the Service recommends that <br />hawk nests be relocated or removed prior to nesting season. <br />If you have any questions, please do not hesitate to call. <br />Sincerely, <br />~~ ~. ~C <br />C~ <br />Erica S. Crosby <br />Environmental Protection Specialist <br />c:\misc\yoastpar3 <br />