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<br />DEPARTMENT Of NATURAL RESOURCES
<br />^. Moue Pascoe, EnecuVVe Direuor
<br />11{N {,U L:1NU REI:L:1~11t1T{ON
<br />423 Centennial Building, 1313~Sherman Street
<br />Denver, Colorado 80203 Tel. (303) 86G-1567
<br />David C. Shelton
<br />July 27, 1982 Director
<br />TO: Carol Russell
<br />FROhf: Sandy Emri~ ~'~
<br />RE: P&M Vegetation Stipulations 6, 7 and 8
<br />Stipulation No. 6
<br />P&0f is proposing to establish an average of 900 stems/acre on the Moffat
<br />Lease area. The response to .Stipulation b6 states that the main source of
<br />woody plant material will come from selectively placing live topsoil on
<br />the Moffat Lease. The stipulation response notes that approximately one-
<br />third of this area will be live topsoiled as shown on Exhibit 9.4-1. However,
<br />a review of Exhibit 4.9-1 only identifies transplant areas, not live topsoil
<br />areas. These are randomly placed throughout and appear to be more than
<br />one-third. There is no discussion in the application on selective live
<br />• topsoil areas, or transplant areas. The response, therefore, is unclear.
<br />in describing the establishment of woody plants with selective placement
<br />of live topsoil. The applicant is not proposing any other method of shrub
<br />establishment. I'm not sure live topsoiling alone will meet the standards.
<br />The conclusion is drawn in the stipulation response that 500 stems per
<br />acre on the average will have to be established on the Live topsoiled
<br />acreages, Since no detailed discussion of live topsoiling is provided and
<br />it is unclear what areas will be live topsoiled, this conclusion is
<br />difficult to understand and needs further explanation.
<br />Also, on what basis is the applicant justifying 500 stems/acre establishment
<br />of shrubs from live topsoil?
<br />The Colorado Division of Wildlife (DO[9) is recommending 1000 stems per
<br />acre in wildlife habitat. P&M cites several publications, but it does not
<br />appear that they have contacted the D,O.[d, D.O.W, should be contacted in
<br />the development of a shrub density standard for. wildlife habitat.
<br />To adequately answer this stipulation, the applicant must:
<br />1. Discuss live topsoil areas and show the Zive topsoil areas on a
<br />map;
<br />2. Provide documentation demonstrating that the shrub standard can
<br />be achieved solely by live topsoiling; and
<br />3. Contact D.O.[J. for their shrub density recommendations in the
<br />P&P7 permit area, and incorporate their recommendations into your
<br />• new submittal.
<br />~Z
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