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resulted in the conclusion that such past efforts can largely be considered a failure and <br />techniques such as bare-root or containerized plantings should no longer be attempted. It <br />has become obvious to all parties concerned (including Colowyo, their consultants, the <br />researchers at Colorado State University, the CDRMS, and the CDOW) that reclamation <br />practices utilized historically were far more conducive to establishing herbaceous species <br />at the expense of woody species. (It is for this reason that post-2008 reclamation, using <br />different reclamation techniques will have a different success criterion.) <br />Furthermore, the continued existence of herbaceous species at elevated densities, along <br />with browsing by big game animals, continues to preclude opportunities for <br />establishment and/or growth of woody species populations. In effect, historic (and <br />expensive) attempts to establish shrub populations into these "dense herbaceous stands" <br />using the best technology available at the time have met with nearly complete failure. <br />Only a few remnant plants and "patches" of shrubs remain in the reclamation, and many <br />of those surviving plants were established from seed in the mix as opposed to seedling <br />planting. <br />In this regard, all parties (including the CDOW) are in general agreement that older (pre- <br />2008) revegetation at Colowyo's operations favors the livestock grazing aspect of the <br />approved Rangeland Land Use, and that the woody plant density component of those <br />areas is largely inconsequential for such use. However, it has been noted, that big game <br />use, primarily by elk, of the pre-2008 revegetation has been at substantially elevated <br />levels over the past several years, and occasionally has been shown to be problematic to <br />area CDOW managers (as well as contributing to the impact on shrub establishment. <br />(See Enclosed CDOW letter below, especially the 3rd paragraph.) <br />Therefore, the woody plant density success criterion within pre-2008 reclamation at <br />Colowyo's operations shall be 150 live stems per acre on approximately 3% (or more) of <br />the reclaimed surface. <br />4.15-20 Revision Date: 12/22/09 <br />Revision No.: TR-84