2010-04-15_REVISION - C1994082 (3)

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2. In the currently approved plan, a standard of 2000 woody plant stems per acre is specified for concentrated planting areas, with the exception of the concentrated aspen planting sites, where "the density standard was to be based on future test plot results and planting strategies based on those results". The intent was that a standard for aspen stem density would be established for the aspen planting sites, based on test plot results. The revision plan proposal of an 850 stem per acre standard is based on study results applicable to aspen, but it is not clearly stated in the narrative that the proposed standard for the "concentrated aspen/woody plant sites" is 850 aspen stems per acre. As the aspen planting sites are also planted with tall shrub species and seeded with a shrub mix that includes big sagebrush and snowberry, it is necessary that this point be clarified. The density standard for aspen planting areas needs to be clarified, and should include both a general woody plant standard and an aspen stem density standard for the concentrated aspen/shrub planting sites (similar to the approach approved for mesic drainage planting sites, which include a mined tree/shrub component). Please amend the density standard for "concentrated aspen/woody plant sites" to specify both a proposed woody stem density standard and an aspen stem density standard for such. sites, along with supporting rationale. 3. In the approved plan, there are numerous unfenced upland shrub planting areas and one ("to be fenced") mesic drainage planting site (on Armand Draw), as depicted on Exhibit 22-I. The current plan specifies a 2000 stems per acre woody plant standard for each of the concentrated planting areas, with at least 150 stems per acre being tree species, within the mesic drainage planting site. In the revision plan, the numerous upland planting sites and the mesic drainage site are not addressed. The currently approved standard for the sites is eliminated with no rationale or acknowledgement. Some revisions to the current plan are warranted and reasonable, to reflect minor changes in planting site locations and configurations, and to reflect performance and development of shrub patch areas over time. However, the wholesale change proposed, without justification, is not approvable. Please revise the plan to address concentrated planting area standards for the various concentrated planting sites depicted on Exhibit 22-1. Rationale for any proposed changes to the approved 2000 stem per acre standard for the concentrated planting areas, as well as any proposed elimination of concentrated planting areas or changes in location or extent of such areas will need to be fully described in the application narrative. In accordance with Rule 2.07.3(1), you have the opportunity to amend, review, or otherwise make your application complete. If you have any questions, please contact me. Sincerely, Daniel T. Ma the s Environmental Protection Specialist DTM/Ahd C-TR-01 CI982057 DTM 04152010081032.dx