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Mx. Mike R~•ulay Division of :\linexals and Geology April 30, 200? Page 3 Resnonse• SCC has had good results in densely seeding shrubs verses planting tabling base on two studies by ESCO in 1995 and 1996. Ina 1995 report by ESCO for SCC on shrub monitoring the results were 3,642 stems per acres for seedling tublings plots and 33,185 stems per acres for seeded plots. And in a 1996 report by ESCO for SCC on shrub monitoring in the same general area as 1995 study there were 2,900 stems per acres for seedling tublings plots and 24,000 stems per acres for densely seeded shrub plots. Based on these results SCC will prefer dense seeding of shrubs. Text will be changed stating that densely seeding of shrubs areas as the preferred method to establish shrub groupings. 8. The acreage table on revised page 27 (I'ab 22) mar amended to reflect prepared inereared acreage to be needed with Seedmix 1 and planted with Planting Llrt 2 (Dry Upland). However, the table mar oat amended to indicate any increared acreage far Planting Litt 3 (Apen Planting) or Seedmix 6 (Concentrated Shrub Seeding), depite additional are of there methodr indicated on amended Exhibit 22-1A. Pleare amend the referenced acreage table ar appropriate to accurately reflect revegetation plan changer indicated on amended Exhibit 22-1A. Resnonse: The acreage table on page 27 has been revised to include proposed acreage for Planting Lists 1 and 3. With regazd to Seedmix 6, Seneca believes that the 20.0 acres (minimum) remains a reasonable estimate until future monitoring results aze evaluated and decisions reached. Also see response to Comment 7. The legend on Exhibit 22-1A, Postmining Vegetation Map, and the text on page 22 indicates that the areas in question will be seeded either with Planting List 1 ox 2 or with Seedmix 6 (not both). 9. Narrative on page 30 references are of mature shrub tranplant clumps "... in the virinily of concentrated planting lacationr shown an Exhibit 22-1 ". Operator it reguerted to addrers the extent to which mature tranplanting mould be feasible within the South Mining Area, and, if appropriate, mod text on p. 30 to mature tranplanting rites on disturbance arear depicted in Exhibit 22-1A. Resnonse: The sentence actual says...... "The live shrub clump transplant aeeas will vary from 1.0 to ].5 acres in size and mw be placed in the vicuaity of the concentrated planting locations shown on Exhibit 22-1." SCC will commit to experimenting with live shrub transplanting to determine if it is a feasible methodology, however the permit text should not be modified at this time. 10. The expanded disturbance proposed in PR-3 will consume an additiona194 acres of open farrrt, but only one small open planting rite it propared SCC it requested to undertake more extensive ~ortr to reertabluh open on the reclamation. In addition to planting individual tubelings mithin designated planting areas ar proposed, the following measurer are recommended • Elk proof fencing rhauld be used to protect young open that are planted in small clumps or `Yrlaudr'; Browning damage by deer and elk hat been observed at mart titer where open planting hat been attempted an reclaimed rifer in northwest Colorado, Shepperd (2001) concluder that undue browning damage can generally be avoided only by "satiating the demand for proutr" by managing for numerous large (G to 8 be~taref regeneration rites at one time on agiven landscape, or by directly protediregyoureg plants from browning. He mater that fencing is the only guaranteed meant of directly protecting grouts from browning animals. • Feasibility of direct haul tpsoiling from open habitat and live clump tranplanting of aspen clones should be addressed Consideration should be given to `preparing" salvage titer one or two years in advance of stripping or clump transplanting, by meant of dormant reason (eg. October/Navember~ rotoclear treatment, chain raw harvesting, or dozer clearing of mature open. The `preparation' treatment