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Pastureland or Cropland postmining land use may be appropriate for disturbed areas <br />associated with the Gossard Loadout, and the section will need to be amended as <br />appropriate. <br />Fish and Wildlife Plan [2.05.6(2) and 4.181 <br />20. The introductory "Fish and Wildlife" paragraph on amended page 2.05-68 contains the <br />statement that "...after decades of experience, it has become obvious that reestablishment of <br />shrubs on the reclaimed area is not critical to encourage wildlife use such as by elk." It <br />would be appropriate to address the extent of use of grassland reclamation by elk, <br />pronghorn, and mule deer, which may not have been anticipated originally, and to note as <br />well as the difficulties experienced with shrub reestablishment. Continuing efforts to <br />improve reclamation methods to achieve better woody plant establishment and site diversity <br />to benefit a wide range of species, including sage grouse, which are dependent on sagebrush, <br />should be discussed. <br />Please update the section as appropriate. <br />21. The Sagegrouse Mitigation plan, beginning on page 2.05-71, is presented as a May 25, 1982 <br />response letter, but in fact there were at least some minor changes made in the recent <br />submittal. Given results achieved from the original 1982 reclamation plan in most areas, the <br />projection that "the density and structures of the shrub component within the post-mine <br />community should provide the diversity of cover and density suited to Sagegrouse nesting" <br />was obviously not borne out, and the narrative is somewhat dated. <br />Please provide an updated postscript to the Sagegrouse mitigation section to <br />acknowledge that the original reclamation plan methods did not result in a shrub <br />component consistent with original projections in most areas. In addition, include <br />discussion and reference to reclamation plan changes which have been made to <br />enhance the potential for successful establishment of sagebrush steppe vegetation, in <br />part to benefit Sagegrouse. <br />22. The last paragraph on page 2.05-73 should be updated to more clearly reflect current <br />wildlife concerns. The "increasing wildlife populations" and related management concerns <br />should more specifically be identified as "increasing big game populations, primarily elk". <br />The concern with respect to Sagegrouse and mining in the region, is still related to potential <br />negative impacts of mine development on populations, and on the reclamation of suitable <br />habitat for Sagegrouse. Please update the section as appropriate. <br />Rule 4.15 Reve~etation Performance Standards <br />23. The reference to use of introduced species for small area erosion control at the discretion of <br />Colowyo's reclamation coordinator in amended Section 4.15.2, should be qualified by the <br />statement that DRMS approval (via appropriate revision of the permit) would be obtained <br />prior to such use. Please amend the narrative as appropriate. <br />Colowyo Coal Company, C-1981-019 TR-72 <br />April 29, 2008 Page 11 <br />