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9. Revegetation success criteria (or species diversity and woody plant density ore not addressed in the application. Since livestock grazing is the proposed primnry post-mining Land use, and given the landowner request, shrub reestab- lishment may not be required. This determination u~il! depend on resolu[ron of the issues noted in Section X111 l4ildli(e of this letter. A proposnl jot evealuatinq species diversity artcl as species diversity standard, as required by Rule 4.I5.8(5) must be included in the applicatron. A species diversity success criterion is proposed based on the Colorado Mined Land Reclamation Division's Proposed Policy for Evaluating Species Diversity, as follows: Diversity will be based on cover data. Revegetation will be considered successful if the data demonstrate the presence of at least five peren- nia] species with relative importance of at least 3 percent, with al] of these species combined not exceeding 75 percent relative importance, nor any one of these species exceeding 40 percent relative importance. Criteria for woody plant density and diversity are not proposed at this timc. 5. The priman~ seed mix, which includes a number of introduced joroge grasses, including crested wheatgrass, may be appropriate given the land use considerations and iando caner request. A concern expressed in the past with regard to crested wheatgrass is that, when used in a mix with native species it will tend to dominate the stand to the exclusion of other seeded specres. This concern is based primarily on research in the northern great plains, but has not been datum cored in northwestern Colorado. The applicant should commit to a revegetation monitoring program which will document the com- petitive relationship among the various species. W e agree that not enough is knov,n about the behavior of crested wheatgrass when seeded in mixtures with natives. It is fairly well established that since the palatability of crested wheatgrass is io+ver than for many other grass species, grazing tends to favor crested wheatgrass establishment at the expense of more palatable specres which .are grazed more heavily. Proper grazing management can reduce this trend. Virtually all published research on seeding crested wheatgrass in mixtures deals with mixtures in which crested wheatgrass is a maior constituent of the mix. The mixture proposed in the permit apnlication includes crested wheatgrass as a relatively minor constituent. It is included for the following reasons: . It will help stabilize the soil surface and reduce erosion. . It is well adapted to the soils and climate of the area. Tt is a reliable terminator. . lts presence will add to the diversity of the reclaimed stand. . It is nutritious as summer forage. 2-G7 ll.,i-~~