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to physically remove subsurface stems of the dominant rhizomatous grasses <br />may be warranted. In treatment azeas with a component of cheatgrass, the <br />plan will need to include provisions for suppression of cheatgrass competition <br />to have much chance of success. The scalping might also be helpful in this <br />regazd, since most viable cheatgrass seed would be stored within the top few <br />inches of soil. The Division of Wildlife will need to be involved eazly on in <br />the process with respect to formulating revised standazds, planting <br />arrangements, etc. <br />The Division understands that CCC has completed a comprehensive inventory of shrub <br />densities. The Division also understands that Cedaz Creek Associates has written a shrub <br />reestablishment report. This is a good starting point fot any plan and discussion on the <br />issue. The Division would like to request a copy of this report. <br />The Division requests that CCC address the above referenced issues in the form of a <br />Technical Revision to the permit. Given the complex nature of the issues involved and <br />the urgent need to implement a workable plan before the 2007 field season, the Division <br />requests that this Technical Revision be submitted no later than 6 October 2006. <br />Please contact me at (303) 866-4929 if you have any questions or need any additional <br />information. <br />Sincerely, <br />James R <br />Environmental Protection Specialist <br />