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2008-05-28_REVISION - C1981019
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2008-05-28_REVISION - C1981019
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Last modified
8/24/2016 3:32:07 PM
Creation date
5/28/2008 1:30:07 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
REVISION
Doc Date
5/28/2008
Doc Name
Adequacy Response
From
Colowyo Coal Company
To
DRMS
Type & Sequence
TR72
Email Name
JRS
Media Type
D
Archive
No
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utilize grassland cicer milkvetch stands in close proximity to sagebrush patches, which would eliminate <br />the primary justification for inclusion of the species in the shrub steppe planting areas. Fourwing <br />saltbush may not be adapted long term to the mountain shrub/aspen/mountain big sagebrush <br />environments that are dominant within the subject area. Elimination of fourwing saltbush from both <br />seedmixes is requested, and substitution of alternative forb species for cicer milkvetch in the sagebrush <br />steppe seedmix is requested. Forbs that should be considered for inclusion in the sagebrush steppe mix <br />would include those listed in the "contingency" mix, as well as lupine, arrowleaf balsamroot, fringed <br />sage, and pacific aster. <br />Please give consideration to these concerns and make appropriate revisions, or provide reference <br />to applicable data or relevant, current, technical literature to support contrary position(s). <br />Colowyo's Response: <br />Part a) Festuca saximontana is a commercially available species. Furthermore, at the present <br />time it is one-half the cost of F. idahoensis. <br />Part b) The footnote on Table 2.05-7 has been modified to be more specific and restrictive. <br />Furthermore, the amount of orchard grass to be planted has been reduced to 0.5 pounds PLS per acre to <br />maintain the 12 pounds PLS seed application rate. <br />Part c) Comment noted - corrections made as appropriate. <br />Part d) - Regarding cicer milkvetch. First, the amount of cicer milkvetch (0.3 pounds PLS) is <br />identical to the previously approved seed mix. Second, this amount comprises only 0.0067% of the seed <br />base (based on the number of seeds / square foot). Third, this amount of seed has not been found to be <br />problematic (overly aggressive) on recent reclamation. For example, ground cover monitoring in 2007 <br />indicates that this taxon comprised only 1.75% of the composition of 4 and 7 year-old monitored units. <br />Fourth, if this condition changes, the amount of seed can be adjusted. Continued careful monitoring of <br />resulting ground cover by planted taxa will be forthcoming and seed mix adjustments are highly <br />probable. Fifth, the risk that this taxon will draw large ungulates to the Sagebrush Steppe targeted <br />areas is overshadowed by the benefit provided with regard to sage grouse brood habitat. Young sage <br />grouse are heavily dependent on insects in their diet during their early months of life and cicer <br />milkvetch provides significant habitat for insect populations. Therefore, Colowyo proposes no change <br />to the current planting regime at this time. As indicated above, if excessive amounts of cicer milkvetch <br />are consistently observed in given circumstances, the amount of seed will be modified at that time (with <br />CDRMS approval). <br />Regarding Four-wing saltbush. Though Colowyo concurs that four-wing saltbush is not well <br />adapted for long-term existence in the environs of the mine (expected duration is 2-3 decades), Colowyo <br />is reluctant to remove it from the mix for a variety of reasons. First this taxon is on the currently <br />approved mix. Second, it is one shrub that has been repeatedly proven to grow reasonably well from <br />seed and help to achieve required levels of woody plant density (i. e., it would be imprudent to delete a <br />proven performer). Third, this shrub exhibits reasonable protein content and is therefore very useful as <br />livestock or wild ungulate forage. Fourth, four-wing saltbush serves well as a "nurse crop "for the <br />shrub component of reclamation until more adapted shrub populations emerge and mature. During <br />these first 20 to 30 years of reclamation, the structural diversity and micro-habitats afforded by this <br />taxon improves the overall value of habitat for certain wildlife species, especially song-bird populations. <br />Furthermore, the cover provided by this species improves habitat conditions for wildlife such as sharp-
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