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level of success in seeded versus planted aeeas, the seeding of concentrated shrub areas will become <br />the preferred shrub establishment method on upland sites". <br />In their response SCC referenced 1995 and 1996 ESCO studies, in which over-all woody plant density <br />was significantly higher in concentrated shrub seeding plots as compared totubeling planting plots. <br />On this basis, SCC stated that seeding would be the preferred method to establish shrub groupings. <br />Text at the top of page 22 originally referred to concentrated seeding of shrubs as an optional method <br />to be used in addition to seedling planting. On amended page 22, the text at the top of the page was <br />changed to state: The preferred shrub establishment technology will be concentrated seeding of <br />shrubs. This will be used for establishment of shrub islands or groupings. <br />Further evaluation of the referenced studies would appeaz to be warranted, and further text <br />clarifications may be necessary. The amended text is somewhat confusing. This is because, while the <br />revised first sentence of amended page 22 states thatconcentrated seeding will be the preferred <br />shrub establishment technology, text in the final sentence on amended page 22 states that <br />concentrated seeding will become the preferred shrub establishment method, if monitoring <br />indicates a greater level of success. <br />Rather than selection of only seeding or onlytubeling planting "as the preferred approach", some <br />combination oftubeling planting and concentrated seeding may be appropriate. This is because some <br />relatively consistent success has been achieved with seeding for species such as mountain big <br />sagebrush, bitterbrush, and snowberry, and seeding may be the favored approach for these species; <br />while less success from seeding has been observed with tall mountain shrub species such asgambel <br />oak, serviceberry, chokecherry, and current, for whichtubeling transplanting may be appropriate. <br />The operator is requested to commit to a mix oftubeling and concentrated seeding approaches, with a <br />specified minimum number of shrub establishment aeeas (at least 5) to employ a combination of <br />labeling transplants and seeding, and the remaining sites to employ concentrated seeding only. Due to <br />[he extent to which mountain shrubtubelings are typically impacted by browsing, it is recommended <br />that the labeling sites include provision for appropriate fencing or other protective measures. <br />Consideration should also be given to the use of some combination of intensive establishment <br />techniques [supplemental watering for establishment, weed barrier fabric, micro-site selection or <br />construction, substrate manipulation (soil thickness variation, soil roughening, etc.)]. <br />In addition, with respect [o shrub seeding, the operator should consider modification of the primary <br />upland site seeding mix (Mix No. 1). The grass component of [he mix contains over 50 seeds per <br />squaze foot for drill seeding, a relatively high rate. The shrub component includes chokecherry and <br />serviceberry, which are generally difficult to establish from seed, particulazly in the presence of <br />competition from grasses. The mix does not include mountain big sagebrush, which has shown more <br />consistent success from seeding than the tall shrub species. It is recommended that the operator <br />include mountain big sagebrush at a minimum of 0.25 pounds per acre in Mix No. 1, and consider <br />deletion of chokecherry and serviceberry from the mix, along with a reduction of the grass component <br />to approximately 30 seeds per square foot. <br />8. Operator complied with request to amend the acreage table on page 27 to correspond to amended <br />Exhibit 22-1A. Operator noted [hat legend on Exhibit 22-1A and text on page 22 indicates that areas <br />in question will be seeded either with Planting List 1 or 2 or with Seedmix 6 (not both). As we are <br />requesting in items above, the permit presentation needs to be clarified, to specify those aeeas that <br />would receive a combined planting/seeding heatment and those that would solely be seeded with Mix <br />6. <br />9. Original adequacy comment requested that operator address the extent to which mature transplanting <br />would be feasible within the South Mining Area, and if appropriate modify text... <br />Operator responded that they would commit to experimenting with live shrub transplanting, but that <br />"the permit text should not be modified at this time". Unless the permit is modified there is no <br />