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In previous review letters, both DOW (see attached 7 March 2008 DOW letter) and the <br />Division have requested reclamation plan amendments to address reestablishment of small <br />patches of aspen and tall shrub communities. These community types provide important <br />wildlife habitat functions, even when present as small patches within a landscape dominated by <br />grassland or sagebrush steppe. Previous small scale research and operational plantings have <br />indicated the potential for successful establishment, if appropriate measures are taken. In <br />consideration of the significant acreage of these community types that has been disturbed by <br />Colowyo, the Division believes it is important for Colowyo to include plans for a limited <br />number of aspen and tall shrub establishment areas in appropriate site locations. <br />Inclusion of aspen and tall shrub plantings in appropriate locations would be important from the <br />standpoint of providing habitat for various wildlife species as the stands mature, "islands" for <br />seed and vegetative dispersal in the future and demonstrating successful planting approaches <br />for use in the region. <br />Given the intensity of elk use at Colowyo, and results the Division has observed at Colowyo <br />and other mines in northwest Colorado, including recent and on-going research as well as <br />operational plantings, fencing to exclude elk appears to be necessary for successful <br />establishment of aspen and tall shrub species such as serviceberry and chokecherry. Proper <br />substrate and site conditions, appropriate planting stock, and use of weed barrier or other <br />intensive measures to control herbaceous competition also appear to be necessary <br />considerations. <br />Please review previous letters from the Division and DOW regarding this matter, and <br />provide detailed plans for the establishment of both thick soil <br />(aspen/chokecherry/serviceberry etc.) planting sites and thin/rocky soil (serviceberry, <br />bitterbrush, etc.) planting sites. In the Division's most recent meeting with DOW staff, <br />Jon Wangnild indicated a number of smaller tall shrub and aspen planting sites would be <br />acceptable, in lieu of the two relative large planting areas that DOW had requested in <br />their 7 March 2008 letter. These smaller tall shrub and aspen planting areas would need <br />to total 40 acres. For example, Colowyo could choose to plant four 5-acre aspen sites and <br />four 5-acre tall mountain shrub sites (in lieu of one 20 acre site for each). This approach <br />is also acceptable to the Division. <br />On 4 February 2010 the Division also received a letter from the DOW regarding TR-84 (attached). In <br />this letter the DOW states that the Colowyo Mine is "...located within areas classified as suitable for <br />Greater Sage Grouse habitat." The letter further states that "...tall shrub and aspen communities offers <br />the opportunity for Greater Sage Grouse and Elk to utilize these areas with success." This is the fourth <br />letter from DOW that requests the reestablishment of tall shrub and aspen planting areas at the <br />Colowyo Mine. Per Rule 4.15.8(7), the Division is continuing correspondence with the DOW on <br />shrub plantings. Consultation with and approval by the Division of Wildlife is necessary for stocking <br />levels, planting arrangements, and methods for wildlife mitigation. <br />In the South Taylor Pit and Fill area Colowyo will disturb approximately 852 acres of mountain shrub <br />communities and approximately 222 acres of aspen communities. In TR-84 Colowyo has proposed <br />doing 1 acre trials for reestablishing aspen and mountain shrub communities. Colowyo has proposed