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b) The erosion concern regarding shrub establishment on the steeper slopes could be <br />addressed through some combination of more intensive use of contour furrows, chiseling, or <br />other such measures, construction of additional headwater tributary drainage channels to <br />shorten slope lengths, use of strip seeding (banding) with alternating sequence of the grass <br />mix and steppe mix, use of stubble mulch, weed-free straw or wood strand mulch to provide <br />ground cover prior to perennial establishment, etc. Please revise the plan to provide <br />substantial additional acreage of shrub steppe/wildlife habitat within the South Taylor <br />revision area. <br />Revegetation Plan in amended Section 2.05.4 <br />9. There is a formatting error at the top of page 2.05-50; the fragments of two sentences from <br />the top of the page down to the word "structural" in the middle of the first paragraph were <br />included on page 2.05-49, and then erroneously repeated. Please correct the error. <br />10. The Division appreciates the effort that went into species selection, rates, and life form <br />proportions, and particularly the specificity with respect to method of seed application for <br />small and large seeded species. Of course the Division does have a few comments and <br />requests: <br />a) Is Festuca saximontana a commercially available species? If not, there would seem to be <br />no point for including it within the primary mixes; rather, Festuca idahoensis should be <br />substituted. <br />b) The footnote on Table 2.05-7 regarding substitution of orchardgrass in certain situations <br />due to the preference exhibited by elk (a preference the Division too has observed on many <br />reclaimed sites), is overly vague with respect to how many and which species orchardgrass <br />might replace in the mix, and the maximum areal percentage such special use seedings <br />would make up, within any given year's grassland seeding). Additional specificity is <br />warranted. <br />c) American vetch is erroneously listed as Viola rather than Vicia, in table 2.05-8, and small <br />Burnet is erroneously listed as a native species (it is introduced). <br />d) Inclusion of cicer milkvetch in the Sagebrush Steppe seedmix (Table 2.05-9), and <br />fourwing saltbush in both the Grassland and Sagebrush Steppe seedmixes, is questionable. <br />The concern with cicer milkvetch is its potential for developing thick ground cover and <br />providing excessive competition to shrubs and less competitive forbs (observed in some <br />locations at Colowyo, and other mines in northwest Colorado). Lush growth of cicer <br />milkvetch might also tend to draw large grazers to the sagebrush steppe planting areas. It is <br />appropriate for inclusion in the grassland mix due to its forage quality, soil stabilization <br />characteristics, and value to sagegrouse, but it is surely the case that sagegrouse would <br />utilize grassland cicer milkvetch stands in close proximity to sagebrush patches, which <br />would eliminate the primary justification for inclusion of the species in the shrub steppe <br />planting areas. Fourwing saltbush may not be adapted long term to the mountain <br />Colowyo Coal Company, C-1981-019 TR-72 <br />April 29, 2008 Page 7 <br />