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On these steeper slope areas, it would be prudent to include the strip seeding technique as a standard <br />procedure. <br />Please amend the pertinent narrative sections on pages 2.05-58 and 2.05-59 to incorporate the <br />strip seeding technique as standard procedure on slopes steeper than 10%. <br />Colowyo's Response: <br />The concept of banding or strip seeding has been offered in the permit to provide a means for the <br />reclamation coordinator to interrupt the potential for erosion on long gentle slopes. It has not been <br />offered to force a reduction in acreage of sagebrush steppe community. In fact, it is expected that use of <br />this technique will be limited to only a few circumstances with most areas receiving sagebrush steppe <br />encouraging metrics. However, it is not possible to determine with certainty the location or extent of <br />such circumstances. Therefore, as indicated in the original submittal, the acreage exhibiting 10% or <br />flatter slopes was reduced by 50% to account for small, isolated, or impractical areas (bottom of <br />valleys). The remaining area was then reduced again by 50% to conservatively account for the <br />"grassland" strips in areas that might be band seeded (this amount of reduction may be pessimistic, but <br />is necessary to facilitate development of a minimally acceptable success criterion). Then, following the <br />same logic, the assumption was made that 50% of the acreage where sagebrush steppe reclamation will <br />be attempted would be successful. These three limitations are reasonable for the determination of a <br />minimally acceptable success criterion. <br />Realistically, however, it can be readily hypothesized that more than 50% of the acreage where <br />sagebrush steppe is attempted will in fact be successful, especially in the longer-term. Similarly, it is <br />unlikely that a full one-half of the acreage will be eliminated because of impracticalities and it is <br />unlikely that the entire remainder would be band seeded. Furthermore, approximately 60% - 80% of the <br />total reclamation (that which targets grazingland) will receive 25 times the amount of sagebrush seed as <br />has been sown in recent years and Colowyo is confident that this will result in several additional acres <br />of sagebrush steppe. (Recent reclamation at Colowyo has resulted in far greater success regarding <br />sagebrush populations - by example, revegetation that occurred between 1995 and 2005 resulted in <br />estimated shrub densities of 300 plants per acre across 15% of the reclaimed area.) As a result, the <br />acreage of sagebrush steppe community will very likely exceed the minimum acreages presented in the <br />permit by a substantial margin. In this regard, it is reasonable to hypothesize that between 500 and <br />1000 acres of sagebrush steppe will result. However, a success criterion must necessarily be a <br />minimally acceptable (pessimistic) number and not reflective of realistic or optimistic values. <br />Furthermore, this criterion must only apply to reclamation that has yet to occur and not intended to <br />compensate for past reclamation difficulties. <br />Therefore, as indicated in the response to Comment 418, Colowyo is more than confident that <br />sufficient acreage exhibiting a slope of 10% or flatter will be available to achieve a minimum of 250 <br />acres of Sagebrush Steppe community without forcing an extension of the slope limitation to a more <br />risky 15%. However, language has been modified in the appropriate section that would make <br />"banding" (strip-seeding) a standard practice if at the discretion of the reclamation coordinator any <br />areas between 10% and 15% slope are seeded with the sagebrush steppe seed mix.