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Mr. Micheal Boulay Page 2 Personnel also toured several shrub revegetation areas to evaluate some of the different shrub planting techniques. The mine states that direct seeding has been found to be much more effective than tubling planting and recommends this method for their shrub reestablishment. The area planted with tublings did not exhibit much shrub growth while there did appear to be improved shrub growth in the direct seeded area. However, wild rose was the predominant species found growing in the direct seeded area. Areas of high densities of wild rose do not constitute good wildlife habitat and will not adequately replace the mountain shrub or sagebrush communities present before mining. Finally, the area with a live transplant of mature shrubs was preferable to both the tubling and direct seeding approaches because this area provided much more immediate structure for wildlife. Structure is known to be an important aspect of wildlife habitat. The Seneca II-W Permit Revision area will include disturbance of 18.7 acres of mountain brush, and -47.6-acres-of sagebrushLsnoxwberry. Therefore, the DOW recommends that at least_some azeas be~ __ _ __ revegetated using the live transplant of mature shrubs to provide some initial structure for wildlife while the direct seeded areas mature. Also, snowberry and serviceberry were found growing with the wild rose in the direct seeded area. As mentioned previously, high densities of wild rose are not desirable wildlife habitat. Thus, we recommend that the mine reduce or eliminate the percentage of wild rose in the seed mix to allow for the more desirable species to become established. Also, other mines in the azea have been successful with sagebrush revegetation (DMG, personal communication). Sagebrush communities are important habitat for several wildlife species including deer and sage grouse and have declined in Routt County. Therefore, the DOW recommends that the mine increase its efforts to reestablish sagebrush communities, perhaps through focusing sagebrush efforts on the drier sites. In summary, the DOW is concerned about the anticipated permanent loss of over 90 acres of aspen and the potential loss of neazly 50 acres of mountain shrub and sagebrush in the proposed Permit Revision azea. We recommend that the Colorado Department of Minerals and Geology (DMG) request that the mine complete some off-site mitigation to offset the loss of the aspen forest. Also, the DOW does not believe that reestablishing 20 acres (minimum) total of shrub communities is adequate to compensate for disturbing an estimated 248 acres of mountain brush, steep mountain brush, and sagebnxsh/snowberry in the entire II-W South Disturbance Area (Table 10-7). Therefore, we believe that DMG should require the mine to make a greater effort to insure shrub establishment. Again, thank you for the opportunity to tour, the proposed Seneca II-W Permit Revision site as well as other revegetation sites. The tour was very helpful when making these comments. Sincerely, ~- Ron D. Velarde West Regional Manager cc: Bruce McCloskey, Susan Werner, Jim Haskins, Liza Graham, Mike Grode, Dan Mathews (DMG), File