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commitment. The operator should provide a plan for the experiment for inclusion in the permit, including location, timeframe, and experimental vaziables. Also, the operator is requested to address the extent to which live transplanting would be operationally feasible within the South Mine Area (e.g. new areas being cleazed in advance of mining in reasonable proximity toregraded spoil). 10. Original adequacy comment requested that the operator amend [he reclamation plan for the South Mining Area to address moce extensive efforts to reestablish aspen, and included a number of recommendations and suggested references. In response, the operator submitted (1) a discussion and generalized narrative plan for aspen establishment prepared by Dr. David Buckner, which might be termed the "mother plant" concept; and (2) a very brief, noncommital response to our suggestions regazding direct haul topsoiling, pre-salvage stimulation of suckering, and live clump transplanting. These responses aze addressed separately below. Mother Plant Concept The essence of the concept as outlined by Dr. Buckner would entail attempts to establish a small number of mother plants within a number of favorable site locations. The approach would employ intensive landscaping scale establishment techniques including relatively lazge diameter aspen, supplemental irrigation during the initial growing season, fabric and wood chips to control competition, and wire cages for browse protection. This concept was discussed with Dr. Wayne Shepperd of the U.S. Forest Service, Rocky Mountain Reseazch Station. Dc Shepperd is a recognized authority on aspen regeneration and management, and was author or co-author of the papers referenced in the initial adequacy letter. Dr. Shepperd stated that he felt the primary limiting factors with respect to establishing aspen plantings on mined areas were insufficient moisture for establishment and excessive browsing. He indicated that it was almost certainly the case that most native aspen clones were established during climatic periods cooler and wetter than present, which overlapped with periods of lower herbivore abundance. Dr. Shepperd expressed general concurrence with the mother plant concept, with several caveats. First, he felt that supplemental irrigation might need to be carried out for two or possibly more growing seasons. Second, he indicated that aspen does not root adventitiously asdoes cottonwood, and that the deep planting described might kill the trees. Third, he stated that if appreciable survival ofclonal sprouts from the mother trees were to be expected, it would be necessary to protect the sprouts from excessive browsing, probably by fencing areas of approximately an acre, with mother trees in the approximate center. Finally, he recommended that the mother trees should be top-pruned for a more balanced root/shoot ratio at the time of planting. We make the following request: Please amend revegetation plan text, tables, and map as appropriate, to incorporate the "mother plant" approach as a primary aspen reestablishment technique within the II-W South Area. The amended plan should address all aspects of planting, irrigation method and application rate, browse protection, and site selection, in light of the above discussion. Use.of topsoil obtained from aspen habitats, along with replacement of a thick soil layer (e.g. approximately 4 feet) in aspen planting azeas should be addressed. Approximate planting locations should be depicted, minimum number of "mother trees" per planting area should be specified, and minimum number of mother tree planting sites indicated. Planting List #3 site locations and species should be amended as appropriate to accommodate the mother plant approach. In addition to aspen, the mother tree approach withmodifications,raight have applicability togambel oak and other tall mountain shrub species. Please address the potential of the concept for species other