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Colowvo Response <br />Colowyo is currently evaluating this issue and has been in correspondence with both <br />the Division and the CDOW regarding potential changes to the Reclamation plan. <br />In the past, Colowyo has at significant expense made repeated efforts to establish <br />shrubs on the reclamation including broadcast seeding, conventional drilling, <br />containerized nurse plantings ($1.2 million), transplanting mature shrubs, shrub <br />only areas, fenced enclosures, etc., with limited success. Any discussions of future <br />strategies to increase shrub density should consider past efforts and their levels of <br />success or lack thereof. This issue will be addressed in a future permit revision, <br />which has previously been discussed with the division. <br />3. CCC needs to conduct a reassessment of woody plant density and species diversity <br />standard targets for recent and future reclamation, to more closely reflect current <br />~~reclarnation objectives and state of knowledge. _ _~ _ <br />Colowvo Response <br />This will be addressed as part of one of the previously noted revisions, please refer <br />to Colowyo's responses to item I and 2. <br />4. CCC needs to devise and incorporate a plan for management of annual brome, which has <br />become established in significant densities in some areas, and could significantly impact <br />revegetation efforts. <br />Colowvo Response <br />Colowyo has contracted Cedar Creek Associates, which is in the process of <br />formulating opinion on whether annual bromes are a long term problem or simply a <br />short-term nuisance. Unfortunately, cheatgrass has become not only a northwest <br />Colorado problem but a western United States problem. At this point in time, <br />Colowyo needs to evaluate the findings of Cedar Creek Associates once they are <br />finalized. This issue will be discussed and/or addressed during future revisions to <br />the permit. <br />5. CCC will need to assess the retreatment of "failed" shrub establishment azeas. Additional <br />treatments within lazge grass expanses with low shrub densities and few shrub patches <br />will also need to be addressed: In most cases, treatments could involve some <br />combination of herbicide treatment ("Round-up" or comparable broad spectrum <br />herbicide), and mechanical treatments to open up the stand and prepare a seedbed. <br />"Scalping" of the surface soil layer to physically remove subsurface stems of the <br />dominant rhizomatous grasses may be warranted. In treatment azeas with a component of <br />cheatgrass, the plan will need to include provisions for suppression of cheatgrass <br />competition to have much chance of success. The scalping might also be helpful in this <br />regard, since most viable cheatgrass seed would be stored within the top few inches of <br />soil. The Division of Wildlife will need to be involved eazly on in the process with <br />respect to formulating revised standards, planting arrangements, etc. <br />Colowvo Response <br />As mentioned earlier, this issue is a long term issue that will take a lot of time and <br />correspondence between Colowyo, DOW and the Division to come to a workable <br />resolution. Currently, Colowyo does not believe creating disturbance islands in the <br />