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- 11 - <br />2. How far apart will the living snow fences be from each other? <br />3. The Division is concerned about the use of tall wheatgrass as a <br />living snow fence species. This species has been found to have <br />poor establishment rates at the mine site and as a result has been <br />deleted from the revised permanent seed mix. Is there another <br />species that would be more suitable that could be substituted for <br />tall wheatgrass? <br />47. Several pages of the revised permit application, including oages <br />2.05.4-44 and 2.05.4-48 state that subshrubs will be included as a part <br />of woody plant density counts. The Division requires that Kerr Coal <br />clarify what species are considered to be classified as subshrubs. <br />Rule 1.04(55) specifically notes that "half-shrubs" do not qualify for <br />the woody plant density determination. Page 8 of the Division's Land 'J se <br />and Revegetation Guidelines is more specific in its definition of a <br />a -s ru an sou a referred to prior to responding to this adequacy <br />issue. <br />48. Page 780-77aa of the approved permit application states: "Douglas <br />rabbitbrush was not included in the seed mixture because it is considered <br />to be a relatively undesirable forage species for livestock and wildlife <br />and is too low to be considered as attractive nesting cover for sage <br />grouse." However, Kerr has chosen to include this species in their newly <br />proposed seed mix. In light of the above statement, the Division <br />believes inclusion of this species warrants special discussion. <br />The approved mine seed mix includes four species of shrubs. The proposed <br />seed mix only contains three species. The problems Kerr Coal is having <br />in establishing woody plants warrants the addition of one more shrub <br />species. Furthermore, the Division has not specified that Kerr Coal must <br />only use the Wyoming subspecies of big sagebrush. There are two reasons <br />that justify Kerr's use of both the Wyoming and the mountain subspecies <br />in their seed mix. <br />1. Section 4.06.1 of the permit application bears out that Bia <br />sagebrush populations in the mine location can be expected to be <br />represented fairly evenly by both subspecies. Thus, a logical <br />extension of this hypothesis is that inclusion of both subspecies <br />in the seed mix could potentially increase shrub establishment. <br />2. Mountain Big sagebrush was seeded at the Bourg Strip mine with <br />excellent success rates well in excess of density requirements. <br />Kerr Coal may wish to review some of the reveaetation techniques <br />that were undertaken at the Bourg mine. For instance, grasses and <br />fortis were drill seeded while shrub species were broadcast seeded. <br />49. Pages 780-78eee, 780-77aaa, and 780-76aa of the presently approved permit <br />application bear out the following plans for transplanting woody plants: <br />