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Please provide more detail regarding the planting practices, including planting depth, timing, <br />and use of properly trained personnel or professional planters. Measures to enhance planting <br />success such as strategically located and oriented snow fencing, surface mulching, and erosion <br />control measures should also be addressed. <br />Tall Mountain Shrub Planting Areas - Thick Topsoil <br />6. Colowyo has provided numerous commitments that will be implemented during the <br />construction of the tall mountain shrub test plots on thick topsoil. One of these commitments, <br />"c", states that Colowyo will replace topsoil to a depth of 8-16 inches. A minimum depth of 8 <br />inches more approximates the general premining conditions and is no different than the current <br />average topsoil replacement depth for the Colowyo Mine and is not considered thick topsoil. <br />Topsoil substantially thicker than 8 inches is warranted on the thick topsoil shrub planting area. <br />Please change the topsoil replacement depth commitment in item "c" to include topsoil <br />replacement at a depth of at least 48 inches to better replicate the conditions in the <br />undisturbed areas, and to incorporate the concept of significant variation in soil thickness <br />that would be applied within the South Taylor area. <br />7. In commitment "d" Colowyo states that "(t)he sagebrush steppe mix will be modified to reduce <br />the volume of "low shrubs" in favor of tall shrub components in the mix." In commitments 'T' <br />and "g", the operator describes a strip seeding approach to separate the tall shrub components <br />from the grassland components. The Division agrees with the general concept. However, more <br />detail is needed regarding the tall shrub seed mix components. Compared to the steppe seed <br />mix, the herbaceous component of the tall shrub seed mix would logically be severely reduced <br />or eliminated, fourwing saltbush would be removed, and sagebrush reduced. A significant <br />component of tall shrub species including an increase in snowberry, along with inclusion of <br />currant, serviceberry, chokecherry, Rocky Mountain maple, and other adapted shrub species <br />would be warranted. Please provide the Division with a table listing the proposed seed mix <br />for the tall mountain shrub component of the thick topsoil planting area. <br />7. In commitment "f' Colowyo is proposing to alternately drill seed the tall mountain shrub seed <br />mix and the grassland seed mix. The intent of this method is to reduce competition from the <br />grass species and to help control erosion on the reclaimed slopes. Colowyo has not indicated <br />whether they plan to substitute any species in the grassland mix or reduce any of the planting <br />rates to help reduce the competition to the shrub species. Please provide additional detail <br />regarding the grassland seed mix and any changes that are proposed for the mix that will <br />be seeded between the rows of tall mountain shrub planting. The Division would request <br />modifications similar or identical to those requested for the grassland component of the <br />aspen plot. <br />8. Please address measures that will be taken to ensure that the upper four feet of surface material <br />(spoil and/or topsoil) will be replaced to achieve a loose, rough surface, that is not compacted <br />by scrapers or other wheeled vehicles. <br />9. The Division has observed only limited success with respect to establishment of tall mountain <br />shrub species from seed. In the CSU study plots, the only significant success with tall shrub