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-5- • January 10, 1989 20. dative shrub transplanting with a front end loader is discussed on Pages 100 and 101 of the Renewal Application. Additional detail regarding areas which will receive shrub pad transplants as well as pad arrangement, number, spacing, depth, and size of transplant clumps on the reclaimed surface should be provided. The extent to which hand transplanted seedlings will be utilized to augment woody plant establishment should also be addressed. Even in areas v+hich receive shrub transplant clumps or seedling transplants, it is recommended that woody species be included in the seed mix as it is unlikely that the transplants alone will result in woody densities which meet the reclamation success standard. This is of particular concern given the substantial ac reage of topsoil transported to stockpiles and the inability to conduct contemporaneous reclamation during early pit development stages. VII 21. A statement at the top of Page 102 indicates that the "fill and pit will be seeded with the grass and shrub seed mix or mechanically transplanted tree seedlings, shrubs and shrub rootstock". This statement could give the impression that seedling or loader transplanting would be the only revegetation technique applied to major portions of the reclaimed area. We assume that transplants would be placed as shrub clumps or islands surrounded by larger "inter-clump" areas which would be topsoiled and seeded to the approved seed mix. The application should be revised to clarify this matter. 22. Item 19, Page 11 of the Midterm Review document set forth the Re vegetation Success Standards for the Carbon Junction Mine rangeland/wildlife habitat reclamation areas. Section 2.05.4(2)(e)(vi) on Page 103 of the Renewal Application should be amended by including the standards as stated in the midterm document. Statements on Pages 44, 100, and 101 regarding revegetation success standards for rangeland/wildlife habitat reclamation areas should also be appropriately amended. 23. Item 20 on Page 12 of the midterm document requested Pueblo Coal to describe how and when reference areas would be marked. The requested description has not yet been provided. =ish and Wildlife 24. On Page 45 of the Renewal Application, it is stated that Division of Wildlife personnel in Durango had indicated concern over critical deer and elk winter range within the permit area. The application should briefly summarize what the concerns were and how they were resolved.