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i <br />Memo - Cathy Begej - 4 - November 3, 1989 <br />Marr Mine Site Seed Mix - Shrub Component <br />Page 780-77aa of the approved permit application states: "Douglas rabbitbrush <br />was not included in the seed mixture because it is considered to be a relatively <br />undesirable forage species for livestock and wildlife and is too low to be <br />considered as attractive nesting cover for sage grouse." However, Kerr has <br />chosen to include this species in their newly proposed seed mix. In light of the <br />above statement, the Division believes inclusion of this species warrants special <br />discussion. <br />The approved mine seed mix includes four species of shrubs. The proposed seed <br />mix only contains three species. The problems Kerr Coal is having in establishing <br />woody plants warrants the addition of one more shrub species. Furthermore, the <br />Division has not specified that Kerr Coal must only use the Wyoming subspecies of <br />big sagebrush. There are two reasons that justify Kerr's use of both the Wyoming <br />and the mountain subspecies in their seed mix. <br />1. Section 4.06.1 of the permit application bears out that Big sagebrush <br />populations in the mine location can be expected to be represented fairly <br />evenly by both subspecies. Thus, a logical extension of this hypothesis is <br />that inclusion of both subspecies in the seed mix could potentially increase <br />shrub establishment. <br />2. Mountain Big sagebrush was seeded at the Bourg Strip mine with excellent <br />success rates well in excess of density requirements. <br />Kerr Coal may wish to review some of the re vegetation techniques that were <br />undertaken at the Bourg mine. For instance, grasses and fortis were drill seeded <br />while shrub species were broadcast seeded. <br />Woody Plant Density <br />Several pages of the revised permit application, including pages 2.05.4-44 and <br />2.05.4-48 state that subshrubs will be included as a part of woody plant density <br />counts. The Division requires that Kerr Coal clarify what species are considered <br />to be classified as subshrubs. <br />Rule 1.04(55) specifically notes that "half-shrubs" do not qualify for the woody <br />plant density determination. Page 8 of the Division's Land Use and Revea_etation <br />Guidelines is more specific in its definition of a half-s ru and s ou d e <br />re erre o prior to responding to this adequacy issue. <br />Woody Species Transplants <br />Pages 780-78eee, 780-77aaa, and 780-78aa of the presently approved permit <br />application bear out the following plans for transplanting woody plants: <br />Kerr Tipple: The upland portions are to receive sagebrush and rabbitbrush <br />transplants at a rate of 6800 stems per acre. The flat lowland areas are <br />to receive willow transplants at a rate of 200 plants per acre. <br />Kerr Mine Site: Sagebrush and rabbitbrush individuals are to be transplanted <br />at a rate of 200 stems per acre. <br />