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to obtain elevated shrub densities, they cannot be considered to be universally applicable, and must be <br />modified and adapted on a site-specific basis. However, one lesson regarding shrub establishment that <br />has been repeatedly learned across the reclamation industry is that large-scale success is largely limited <br />to seeding techniques, not transplanting techniques. This lesson has been repeatedly confirmed at <br />Colowyo. Similarly, the desire to re-establish Mountain shrub stands is laudatory, but the technology <br />for large-scale application is still beyond the science. In these circumstances, it is far better to apply <br />scarce resources in a more fiscally prudent manner and re-establish habitats that are beneficial on a <br />regional level. For example, prior to European man's influence over the West, pockets of grassland <br />within the stands of sagebrush and Mountain shrub were both common and large in areal extent. The <br />advent of occasional fires insured such a mosaic. It is within these habitat circumstances that species <br />such as the American elk and bison evolved, and it is largely for this reason that the elk herds <br />extensively utilize the grasslands of today's reclaimed areas. Furthermore, it makes little sense to <br />attempt to re-establish the disclimactic circumstances that were found immediately prior to mining when <br />it is possible to re-establish habitats and habitat diversity that were common to the West prior to 300 <br />years ago. <br />6. There are many excellent concepts enumerated (1-14) in the paragraph beginning at the bottom of <br />amended page 2.05-42 and continuing on page 2.05-43. Some of these concepts have been incorporated <br />as permit commitments, while others are included as optional measures. The Division has one question <br />regarding the enumerated items: <br />What measures will be taken to ensure that the correct subspecies of mountain big sagebrush (A. <br />vaseyana pauciflora), with a seed source as close as possible to the Axial Basin, will be utilized? <br />Please specify how this will be achieved and include the commitment within a footnote to the <br />seedmix tables. <br />Colowyo's Response: <br />Appropriate footnotes have been added to Tables 2.05-7 and 2.05-9. <br />7. A summary list of management practices that may be undertaken to encourage or protect positive <br />recruitment to shrub populations is listed on amended page 2.05-43. The Division encourages use of the <br />practices discussed, if properly implemented in accordance with all applicable statutes and agency <br />approvals. The Division requests that an additional practice be included; interseeding of shrubs as a <br />normal husbandry practice, if warranted. <br />Please clarify that management of elk or other wildlife by hunting would be conducted on the <br />permit area only in accordance with applicable statutes and approval of necessary authorities, <br />including MSHA and CDOW. Also, please include interseeding of shubs as a management <br />practice that would be applied as warranted, when shrub seeded parcels do not exhibit <br />satisfactory establishment or trend toward shrub component site objectives, and state that such <br />interseeding would be conducted in accordance with Rule 4.15.7(5)(8), with proper documentation <br />in the Annual Reclamation Report for that year. <br />Colowyo's Response: <br />Comment noted - additional text added as appropriate.