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As reclamation continues into the future, actual core and ecotonal areas of shrub <br />establishment will be mapped and reported in the 4nnual Reclamation Reports to show areas <br />of progress or lack of success through Interim Revegetation Monitoring. <br />Colowyo has agreed to an increased shrub establishment acreage of 250 acres that would <br />include a potential combination of core area and ecotonal area as long as the requirement <br />for a shrub density standard on the grazingland component is dropped. Should the area <br />actually mined for South Taylor decrease through changes in mine planning, Colowyo would <br />reasonably like to retain the right to negotiate the reduction of this total area should it be <br />problematic for the attainment of full bond release in the future. Colowyo does not <br />anticipate this will be a problem given the multiple level approach proposed and the <br />potential for additional acres qualifying for sagebrush steppe areas within the grazingland <br />component of the reclamation. Colowyo has proposed to massively increase the shrub seed <br />components in the grazingland mix which should ensure this occurs to some degree. <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 the top of the <br />page down to the word "structural" in the middle of the first paragraph were included on page 2.05-49, <br />and then erroneously repeated. Please correct the error. <br />Colowyo's Response: <br />Comment noted - corrections made as appropriate. <br />10. The Division appreciates the effort that went into species selection, rates, and life form proportions, and <br />particularly the specificity with respect to method of seed application for small and large seeded species. <br />Of course the Division does have a few comments and requests: <br />a) Is Festuca saximontana a commercially available species? If not, there would seem to be no point <br />for including it within the primary mixes; rather, Festuca idahoensis should be substituted. <br />b) The footnote on Table 2.05-7 regarding substitution of orchardgrass in certain situations due to the <br />preference exhibited by elk (a preference the Division too has observed on many reclaimed sites), is <br />overly vague with respect to how many and which species orchardgrass might replace in the mix, and <br />the maximum areal percentage such special use seedings would make up, within any given year's <br />grassland seeding). Additional specificity is warranted. <br />c) American vetch is erroneously listed as Viola rather than Vicia, in table 2.05-8, and small burnet is <br />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 fourwing saltbush <br />in both the Grassland and Sagebrush Steppe seedmixes, is questionable. The concern with cicer <br />milkvetch is its potential for developing thick ground cover and providing excessive competition to <br />shrubs and less competitive forbs (observed in some locations at Colowyo, and other mines in northwest <br />Colorado). Lush growth of cicer milkvetch might also tend to draw large grazers to the sagebrush <br />steppe planting areas. It is appropriate for inclusion in the grassland mix due to its forage quality, soil <br />stabilization characteristics, and value to sagegrouse, but it is surely the case that sagegrouse would