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scoria rock or overburden zones dominated by sandstone, for replacement as surface or near <br />surface growth medium in certain locations. The rationale would be to provide conditions <br />favorable for the growth of shrub species such as mountain mahogany, bitterbrush, <br />serviceberry, and other species that are adapted to extremely rocky soils or thin soils over <br />fractured sandstone. <br />Please include this strategy in the reclamation plan, as an additional shrub/diversity <br />enhancement measure to be employed in select locations. <br />Revegetation [(2.05.4(2)(e and 4.151 <br />In Items 5 through 18 below, the Division identifies a number of concerns with specific sections of <br />Rule 2 application narrative. Portions of Rule 4 application narrative will likely need to be updated <br />to correspond to amended Rule 2 narrative sections, in the response submittal to this adequacy <br />review. The Division has identified additional adequacy concerns specific to Section 4.15 amended <br />sections in Items 23 through 30. <br />Supylemental Introduction in amended Section 2.05.4 <br />5. The Division concurs that the wildlife habitat/sagebrush steppe enhancement efforts should <br />be focused primarily on the more gentle terrain, estimated to comprise approximately 20% <br />to 40% of the post-2008 reclaimed landscape. However, the Division believes that the <br />woody plant density standards proposed, and the acreage to which such standards would <br />apply, are too low. This determination is based on consideration of the large acreage of <br />relatively low diversity grassland habitat that has been established at Colowyo in the past, <br />and the understanding that wildlife habitat would be strongly emphasized in the remaining <br />areas of the original permit and the South Taylor expansion. With use of the amended <br />seedmixes, it is expected that a modest sagebrush/snowberry component would become <br />established within the grassland/erosion control targeted slopes, as typically is the case with <br />use of similar native dominated seedmixes at other mines in northwest Colorado. Use of the <br />"banded seeding approach" with occasional strips of the "Sagebrush Steppe" mix included <br />within larger patches of the "Grassland" mix could be utilized to enhance diversity and <br />woody plant establishment on the slopes, without significantly increasing erosion potential, <br />if warranted. <br />Based on the plan presented, consideration of results that could reasonably be expected, and <br />following discussion with Jon Wangnild of CDOW, the Division requests the woody plant <br />density standard for post-2007 reclaimed areas at Colowyo be stated as follows: <br />• A standard of at least 500 live woody plant stems per acre and at least 250 live big <br />sagebrush plants per acre will apply on "Sagebrush Steppe/Wildlife Habitat Targeted <br />Areas". "Sagebrush Steppe/Wildlife Habitat Targeted Areas" will comprise a <br />minimum 20% of the acreage of post-2008 reclamation. <br />Colowyo Coal Company, C-1981-019 TR-72 <br />Apri129, 2008 Page 5 <br />