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tailed grouse (which have been observed utilizing this taxon in this manner on multiple occasions at <br />multiple locations around the West). Fifth, Colowyo, as the landowner, has opted to target the <br />grazingland and wildlife habitat land uses for their reclamation, and four-wing saltbush meets the short- <br />term needs of both of these targeted uses and helps to expedite the maturation of more adapted <br />community components. <br />11. The 2nd and 3rd paragraphs on page 2.05-56, regarding the virtues of introduced species, are dated and <br />somewhat skewed. Left unsaid is that many of the introduced species used in the past at Colowyo were <br />overly competitive and persistent, and are not compatible with current objectives to establish diverse, <br />native dominated shrub/grassland communities. Please delete the referenced paragraphs, or re- <br />phrase them to provide the proper historical context. <br />Colowyo's Response: <br />Comment noted - deletions made as appropriate. <br />12. In the next to last paragraph on page 2.05-56, narrative describes two situations where introduced <br />species (not listed in current seedmixes) might be used. Please include language to clarify that such <br />use would be subject to submittal and approval of an appropriate revision to the reclamation plan. <br />Colowyo's Response: <br />Comment noted - corrections to text made as appropriate. <br />13. Colowyo asserts that the only technique holdinf any reasonable promise for successful establishment of <br />woody plants is direct seeding (p. 2.05-57, 2° paragraph), and apparently based on this rationale, the <br />revised application includes no plans for seedling or sapling transplanting of aspen or tall shrub species <br />such as serviceberry, gambel oak, chokecherry, mountain mahogany, etc. <br />The Division believes Colowyo's assertion does not take into account recent results from small scale <br />demonstration plots at other mines in northwest Colorado, which suggest that successful establishment <br />of aspen and various tall shrub species may be achieved by transplanting, if a proper combination of <br />measures is employed. Important considerations include proper site selection for the species, proper soil <br />type and thickness for the species, use of fencing to exclude ungulate browsers during the establishment <br />period, use of 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 during critical <br />periods, etc. Establishment of aspen and tall shrub species by seeding has not proven to be effective. <br />Aspen and tall shrub communities provide important wildlife habitat functions, even when present as <br />small patches within a landscape dominated by grassland or sagebrush steppe. Given the potential for <br />reestablishment of these components indicated by previous small scale plantings, and in consideration of <br />the significant acreage of these community types that has been disturbed by Colowyo, and may be <br />disturbed by future operations in the Danforth Hills, the Division believes it is important for Colowyo to <br />include plans for a limited number of aspen and tall shrub establishment areas in appropriate site <br />locations.