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Fourth, although one or two companies may have had some limited success in Northwest <br />Colorado with establishment of small, high-maintenance patches of aspen and/or Mountain <br />shrub, Colowyo has found that the results do not warrant the effort, especially for a less <br />important habitat type (see above). Over the years Colowyo has spent significant effort and <br />funds to attempt the establishment of these taxa with near total failure. Although there may be <br />additional procedures that could be used (given the modest successes elsewhere), Colowyo's <br />targeted land use is designed to concentrate on more important wildlife habitats and grazingland <br />that will be key to the post-mining land use of ranching as well as the value of the land. <br />Therefore, Colowyo respectfully declines to alter the reclamation plan to again attempt <br />difficult and expensive reclamation practices that have shown only limited success; to target <br />"restoration " as opposed to "reclamation "; and to target a lower value wildlife habitat that had <br />to be thinned in neighboring areas to improve habitat conditions. <br />14. Near the middle of page 2.05-57, there is reference to possible use of elk proof fencing in certain <br />locations, at the discretion of Colowyo's reclamation coordinator. Elk proof fencing is a necessity for <br />aspen and tall shrub plantings, and will need to be specified in the revised plan to be submitted in <br />response to Item 13, above. In addition, elk fencing has been observed to promote growth and density <br />of sagebrush stands and to allow for higher survival and growth of associated high palatability species, <br />particularly bitterbrush. <br />Please include commitment and detailed plans for provision of at least one elk fenced <br />sagebrush/bitter brush seeding area, one or more fenced "rocky soil" mountain shrub planting <br />areas, and two or more fenced "thick topsoil" aspen/tall shrub planting areas, within appropriate <br />locations in the post-2008 wildlife habitat emphasis areas. <br />Colowyo's Response: <br />Colowyo is fully aware of the positive impact that elk prooffencing has on both shrub <br />population density and on individual shrub size. This fact has already been well documented on <br />multiple occasions, especially at the CSU shrub test plots. Given this knowledge, it is Colowyo's <br />intent (and hope) that sufficient shrub densities will be established within the post-2008 <br />sagebrush steppe emphasis areas to preclude the need for any fencing (i. e. overwhelming <br />densities and acreage of success). However, if adequate density or acreage is not attained and <br />there is concern that success criteria may not be met, Colowyo will mitigate as appropriate, most <br />likely by erecting elk proof fencing. Any other call for fencing would be redundant with the <br />success standards. <br />The paragraph called out by the Division in this comment has been slightly modified to make it <br />more clear that fencing could be used to ensure that success criteria would be met. <br />15. In the 3rd paragraph of page 2.05-57, there is reference to reclamation of various facilities within the <br />Colowyo permit area. While revegetation techniques and standards for most facility sites would <br />logically be consistent with those applicable to adjacent pit reclamation areas, this would likely not be <br />the case for disturbed areas associated with the Gossard Loadout.