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September 17, 2002 <br />3. Colowyo proposes to add Mountain snowberry, Symphoricarpos rotundifolius, to the substitute list. <br />This species is already included on the approved Table 2.05-7 seed mix. Adding an already <br />approved species to the substitute list is redundant and unnecessazy. <br />4. Colowyo proposes to add a line to the footnote of table 2.05-8, stating, "Colowyo can also choose tc <br />increase a seeding rate of an approved species rather than choose a substitute from Table 2.05-8." <br />The Division does not approve of this statement. TR-52 established a list of appropriate substitution <br />species, Table 2.05-8, should Colowyo not be able to obtain the species included in the approved <br />Table 2.05-7 seed mix. Colowyo needs to follow the seed mix as approved, or use substitutions <br />from the approved list. Should species from the approved seed mixes, Table 2.05-7, 2.05-8, and <br />2.05-9 not be available or not available at the rates in the approved mix, then Colowyo needs to get <br />approval for alternate seed mix, or rates, from the Division, prior to implementation. <br />5. Colowyo proposes to eliminate Squaw apple, Peraphyllum ramossisimum, from Table 2.05-8 and <br />Table 2.05-9. The Division has not seen this species used at other mines and finds its elimination <br />from the seed mix acceptable. However, Colowyo needs to propose to replace Squaw apple with <br />another species or explain why a replacement species is unwarranted. <br />The Division understands the volatility of the rangeland and native seed industry. In situations such as we <br />have experienced in 2002, with widespread drought and fires through out the Western United States, <br />temporary changes to the reclamation seed mix are warranted for the 2002 seeding efforts only. Should <br />Colowyo experience seed supply constraints in future years, deviations from the approved seed mix will <br />need to be approved by the Division prior to seeding. <br />