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Memorandum To: Byron Walker From: Janet Binns Date: 6/19/02 Re: Colowyo 20 ARR Seed mix File: C:/jhb/team/Colowyo/2000 ARR seed mix.doc ICCC: Dan Hernandez This memo is in response to Dan Hernandez' note regarding my request for Colowyo to submit verification of the Reclamation seed mix that they actually planted on reclaimed areas in 2000. This was the first I had seen Colowyo's proof of 2000 reclamation seed mix. Colowyo's cover letter to the 2000 Annual Reclamation Report, dated March 9, 2001, states, "The seedmix, as approved in the Permit, was applied in September and October." Nowhere in the 2000 annual report does Colowyo indicate that the seed mix planted in 2000 varied from the approved Table 7 seed mix. The Colowyo Reclamation Seed mix, Table 7, was revised in spring 2002 during TR-52. I found a copy of the previously approved seed mix, approved August 1992 in TR-42, which represents the approved seed mix at the time of the 2000 reclamation season. I made an Excel speadsheet with the approved seed mix (at the time of the 2000 seeding) and with the species and amounts of seed applied based upon the copy of seed order provided by Colowyo on February 18, 2002. Although the Pure Live Seed (PLS) seeded per square foot is greater than the approved seed density, there aze some significant deviations from the approved seeding rates per species. Most notably is the overall reduction in the rate of seeded shrub species. Colowyo consistently notes the low shrub establishment success in the reclaimed areas. Reducing the amount of shrubs seeded without the approval of a revision does not convince the Division that Colowyo is following their reclamation plan. None of the seed reported as having been planted in 2000 are considered toxic or noxious, however some species considered "aggressive" were seeded at much higher rates than what was approved in the permit, while other desirable species were seeded at lower rates or left out altogether. The revised Reclamation Seed mix (approved in TR-52) makes provisions for species substitutions if approved species aze unavailable. Colowyo needs to make note of substitutions in the Annual Reclamation Report. Colowyo needs to follow the approved seed mix and seeding rates. Due to this apparent deviation from the approved seed mix, is suggest that Colowyo provide, to the Division, a copy of the seed mix to be planted prior to seeding to assure compliance with Rule 4.15.1(2). I am including a copy of my spreadsheet with this memo.