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I 1 1 IJ IJ be buried beneath a roadbed, then the pipeline ROW should be prepared using brush-hogging, not blading. Brush-hogging reduces the surface disturbance needed to a small proportion of the ROW used by ditching machinery: This practice retains most ROW soils intact and allows for native vegetation resprouting from the rootstock, and reduces the opportunities for noxious weed invasion. 15. Potential Negative Impacts of Revegetation Must Be Considered Reseeding the project area without using native plant species and locally-collected seeds may have unintended negative effects on rare plants. On the other hand, leaving disturbed soils exposed may aid weed establishment. For this reason, surface disturbances should simply be avoided in rare plant habitats and kept to a minimum throughout the project azea. To reduce the likelihood that non-native species will not establish in the proposed project azea, the BLM must use native plant species for revegetation as well as locally-collected seeds to preserve local genotypes and species composition. Revegetation methods should entail more than simply scattering seed on the ground because this is unlikely to be ineffective. In the Zink et al. (1995) pipeline disturbance study cited above, similar methods were employed, and ten years later the pipeline was completely dominated by exotics: Initial reclamation procedures, based on 1972 regulations and techniques, concentrated on reestablishing above-ground biomass through direct seeding of the pipeline corridor. The highly compacted soil on the corridor was not prepared for direct seeding through imprinting or ripping, nor was any irrigation system established for initial seedling establishment. Native and exotic seeds were dispersed with no monitoring program in place to ensure that successful restoration occurred. Such procedures, emphasizing the rapid establishment of vegetation cover, have historically been the primary methods of restoration. In many cases, such as the Santa Margarita Ecological Reserve, these methods have been unsuccessful, (p. 309) The BLM must consider the environmental impacts of revegetation efforts in the project area, ' and the BLM must ensure that such efforts do not have negative effects on rare plant species and the overall native ecosystem. 16. Climate Change Will Likely Exacerbate All of the Threats and Impacts Aforementioned It is highly likely that climate change, and the associated natural earth systems that it will disrupt, will adversely affect these species. McCarty (2001) cautioned that "[o]ngoing climate change is ' an additional source of stress for species akeady threatened by local and global environmental changes, increasing the risk of extinction." In the last 100 years the average temperature in Fort Collins, Colorado has increased 4.1 °F, and precipitation has decreased by approximately 5 Center for Native Ecosystems Paget 5 of 24 Scoping Comments for the Proposed Red Cliff Coat Mine