Laserfiche WebLink
constitutes a change in land use as discussed under Section <br />816.133. <br />To this end, we believe that Peabody's reclamation should <br />better ensure replacement of existing wildlife habitat. In <br />particular, aspen stands (although limited on the permit <br />aera) provide an essential habitat component for a variety of <br />wildlife. According to map data provided in the permit <br />application (Exhibits 10-1 and 13-3), Peabody plans to restore <br />only about 40% of the aspen acreage that will be disturbed. <br />Furthermore, information obtained from USDA, Agricultural <br />Research Station personnel indicates that the proposed stocking <br />rate of one hundred aspen per acre is grossly inadequate for <br />stand re-establishment. Overall, we have found aspen <br />restoration to be extremely difficult. Because of the <br />difficulty in re-establishment and because of the potential <br />importance of aspen to wildlife, we recommend that the means by <br />which aspen reclamation take place be determined through <br />further, joint consultation with Peabody, USDA, USFWS, CDOW and <br />BLM. Development of sound aspen mitigation efforts should <br />consider more dense plantings, experimentation with live- <br />topsoiling, fencing and irrigation. <br />We strongly support Peabody's proposed use of live-topsoilinq <br />wherever possible and their reclamation design which provides <br />for greater topographic relief and diversity. We further <br />believe that the vegetation mixtures are adequate; and, in view <br />of Colorado Yampa Coal Company's success with live-topsoilinq, <br />we question the need for seeding properly treated live- <br />topsoiled acres. In addition, live-topsoilinq may provide <br />adequate densities and diversities of native shrubs. However, <br />if shrub establishment by this method proves to be ineffectual, <br />we believe that more extensive containerized plantings may be <br />warranted. In our view, the few islands of shrubs that Peabody <br />plans to re-establish are not adequate. <br />We appreciate the opportunity to provide comments on this permit <br />application. If you have any questions, please feel free to <br />contact either myself at 236-2675 or Mike Lockhart at FTS: 322- <br />0351. ~ / /'/ <br />~~~~~ <br />cc: FWS/HR, Grand Junction <br />CDOW, Grand Junction <br />BLM, Craig <br />MLRB, Denver <br />FWS/SE, Grand Junction <br />