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be unwise to rely upon these species to satisfy the basic and critical purpose of <br />the core seedmix. <br />Rule 4.06.5 requires topsoil testing to determine the need for the application of <br />soil amendments prior to seeding. In the early years at Colowyo topsoil was <br />tested and instances occurred where the application of phosphorus to aid in root <br />development of new seedlings was deemed necessary. Poor quality soils were <br />encountered associated with some of the rockier soils and the less productive <br />sagebrush communities. Rather than continue the soil testing program Colowyo <br />simply committed to the current fertilization program described in the Permit. <br />The proposal to "optionally" apply phosphorus is problematic as it provides no <br />assurance that the nutrient needs of the topsoil are properly considered in the <br />decision to "not" fertilize. I suggest that under the proposed language, the <br />decision to "not" fertilize will not be related to successful revegetation. <br />Thank you for the opportunity to comment on the proposed TR-52. Please contact me if <br />you have any questions. <br />Sincerely, <br />~~~~ <br />J mes A. Kiger <br />3 Washington Street <br />raig, Co. 81625 <br />970-824-7421 <br />