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• <br />off-site habitat improvements to further mitigate for disturbance in that panel. <br />At a minimum, the panel-specific work plans will specify the following: <br />objectives <br />identification of mitigation types <br />locations <br />methods <br />timing <br />assessment of success relative to the vegetation objectives. <br />The work plans would be developed in consultation with the BLM and the <br />CDOW, subject to consensus among the parties. DMG is welcome to participate <br />in this consultation, at its discretion, either directly or through CDOW. It would <br />seem that DMG participation in development of these work plans for the <br />purpose of designating specific well pads for reclamation for mule deer browse, <br />as suggested in Item (ii) of this comment, or to accomplish other particular DMG <br />reclamation goals would be a logical extension of this consultation. <br />American Soda believes that the concept of periodic development of appropriate, <br />site-specific reclamation work plans adequately provides for addressing the <br />issues (described in Items (i) and Item (ii)) that DMG suggests should be <br />incorporated as an addendum to the Reclamation Plan. [t also allows for <br />experimentation with alternative cultural techniques in various settings and on <br />successive mining panels for the purpose of assessing their relative success, as <br />suggested in this comment, without preempting future reclamation decisions <br />and methods. This approach has been embraced by the BLM and the CDOW <br />through extensive consultation in the development of both the Wildlife <br />Mitigation Plan and the Reclamation Plan. <br />American Soda recognizes DMG's need to estimate reclamation costs for the <br />implementation of habitat restoration procedures and recommends the following <br />assumptions (for reclamation cost purposes only), as follows: <br />• 20 percent of the reclamation acreage to be planted with shrub tubelings, <br />that portion being planted at a rate of 1,500 shrubs per acre. <br />• shrub tubelings to be planted in a mesh (vexar) seedling protection tube <br />with a fertilizer pellet. <br />Assuming a 50 percent survival of shrubs planted and an average size at <br />maturity of 1 square yard (9 square feet), this planting rate would yield 15.5 <br />percent canopy cover. This cover value would be consistent with the stated goal <br />of American Soda's Wildlife Mitigation Plan to establish 15 to 20 percent canopy <br />11} Ayp14~.n.Wqu~y YnPn~ <br />1mMbukfi>dmm MUwlb 1'n~ b <br />Am,pn>da LLl' <br />