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Please revise the reclamation plan as appropriate to address this concern. <br />Colowyo's Response: <br />The Division is correct that Colowyo asserts: "the only technique holding any reasonable <br />promise for successful establishment of woody plants is direct seeding" and there are "no plans <br />for seedling or sapling transplanting of aspen or tall shrub species" in Colowyo's reclamation <br />plan. The primary rationale for this position is that sagebrush can be established (with <br />difficulty), but that aspen and tall shrub establishment has met with repeatedfailure (an opinion <br />also shared by the Division -as indicated during meetings with CDOW). Colowyo's position for <br />no longer attempting to establish tall shrubs using seedling or sapling transplanting techniques <br />is based on multiple points, as follows. <br />First, the response to Comment # S (last paragraph) addresses important key issues <br />related to the establishment of "aspen" and "mountain shrub" communities (but not the re- <br />establishment of sagebrush steppe). Principal among these key issues is whether there is any <br />wisdom in the attempt to re-establish disclimactic Mountain shrub communities just because they <br />existed immediately prior to mining, as opposed to the re-establishment of diverse habitat <br />components (including grasslands) that existed prior to the influence of European man. This is <br />especially pertinent given the commitments necessary in terms of both money and manpower, <br />when current techniques provide so little promise for success (as has been experienced on-site). <br />Furthermore, the attempt to achieve Mountain shrub stands reflects "restoration" as opposed to <br />"reclamation ", and reclamation is the intent of "mined-land reclamation laws ". <br />Second, as the land owner, Colowyo has chosen to target it's reclamation to directly <br />address the post-mining land use of rangeland, and to effect this process, has split this land use <br />into it's two primary sub-components of grazingland and wildlife habitat (specifically sage <br />grouse brood-rearing habitat at the request of the CDOW). The sage grouse brood-rearing <br />habitat has been targeted because this is the most critical wildlife habitat in the region <br />according to the Colorado Division of Wildlife. The Mountain shrub habitat is far less important <br />and this circumstance is readily evident given the CDOW's request for mitigation early in the <br />mine life, that was then implemented as part of the "Fish and Wildlife Plan ", "Range and <br />Wildlife Management Programs" and Habitat Improvement Program". The primary component <br />of this mitigation was the dozing and clearing of disclimactic stands of Mountain shrub to open <br />up the understory and improve forage production for resident big game populations. Following <br />this logic, it again makes little sense to target this community in the reclamation, especially when <br />there is such extensive use of the reclaimed grasslands by big game populations (see response to <br />Comment #20) and there are extensive stands of Mountain shrub within reasonable proximity of <br />the mine. <br />Third, the primary use of the Mountain shrub community by big game animals is for <br />thermal and escape cover. The establishment of small pockets of this type might benefit a single <br />animal, but would have no benefit for a large herd. Given the extensive experience on Colowyo <br />lands, big game populations are typically observed as moderate to large herds. Furthermore, <br />the surrounding area is replete with thermal and escape cover that is located sufficiently close <br />for large mobile animals (most big game animals are only one or two minutes distant if <br />adequately motivated). What is in short supply in the region is foraging habitat (grassland).