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shrub/aspen/mountain big sagebrush environments that are dominant within the subject area. <br />Elimination of fourwing saltbush from both seedmixes is requested, and substitution of <br />alternative forb species for cicer milkvetch in the sagebrush steppe seedmix is requested. <br />Forbs that should be considered for inclusion in the sagebrush steppe mix would include <br />those listed in the "contingency" mix, as well as lupine, arrowleaf balsamroot, fringed sage, <br />and pacific aster. <br />Please give consideration to these concerns and make appropriate revisions, or provide <br />reference to applicable data or relevant, current, technical literature to support <br />contrary position(s). <br />11. The 2"d and 3`d paragraphs on page 2.05-56, regarding the virtues of introduced species, are <br />dated and somewhat skewed. Left unsaid is that many of the introduced species used in the <br />past at Colowyo were overly competitive and persistent, and are not compatible with current <br />objectives to establish diverse, native dominated shrub/grassland communities. Please <br />delete the referenced paragraphs, or re-phrase them to provide the proper historical <br />context. <br />12. In the next to last paragraph on page 2.05-56, narrative describes two situations where <br />introduced species (not listed in current seedmixes) might be used. Please include <br />language to clarify that such use would be subject to submittal and approval of an <br />appropriate revision to the reclamation plan. <br />13. Colowyo asserts that the only technique holding any reasonable promise for successful <br />establishment of woody plants is direct seeding (p. 2.05-57, 2"a paragraph), and apparently <br />based on this rationale, the revised application includes no plans for seedling or sapling <br />transplanting of aspen or tall shrub species such as serviceberry, gambel oak, chokecherry, <br />mountain mahogany, etc. <br />The Division believes Colowyo's assertion does not take into account recent results from <br />small scale demonstration plots at other mines in northwest Colorado, which suggest that <br />successful establishment of aspen and various tall shrub species may be achieved by <br />transplanting, if a proper combination of measures is employed. Important considerations <br />include proper site selection for the species, proper soil type and thickness for the species, <br />use of fencing to exclude ungulate browsers during the establishment period, use of <br />appropriate measures to suppress herbaceous competition during the establishment period, <br />use of adapted planting stock, use of proper planting techniques, possible use of irrigation <br />during critical periods, etc. Establishment of aspen and tall shrub species by seeding has not <br />proven to be effective. <br />Aspen and tall shrub communities provide important wildlife habitat functions, even when <br />present as small patches within a landscape dominated by grassland or sagebrush steppe. <br />Given the potential for reestablishment of these components indicated by previous small <br />scale plantings, and in consideration of the significant acreage of these community types that <br />has been disturbed by Colowyo, and may be disturbed by future operations in the Danforth <br />Colowyo Coal Company, C-1981-019 TR-72 <br />April 29, 2008 Page 8 <br />