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TR-48, Aspen/Woody Plant Density Standard <br />Page 2 <br />2. In the currently approved plan, a standard of 2000 woody plant stems per acre is specified for <br />concentrated planting sites, with the exception of the concentrated aspen planting sites, where <br />"the density standard was to be based on future test plot results and planting strategies based on <br />those results ". The intent was that a standard for aspen stem density would be established for the <br />aspen planting sites, based on test plot results. The revision plan proposal of an 850 stem per <br />acre standard is based on study results applicable to aspen, but is not clearly stated in the <br />narrative that the proposed standard for the "concentrated aspen/woody plant sites " is 850 aspen <br />stems per acre. As the aspen planting sites are also planted with tall shrub species and seeded <br />with a shrub mix that includes big sagebrush and snowberry, it is necessary that this point be <br />clarified. The density standard for aspen planting areas needs to be clarified, and should include <br />both a general woody plant standard and an aspen stem density standard for the concentrated <br />aspen/shrub planting sites (similar to the approach approved for mesic drainage planting sites, <br />which include a mixed tree/shrub component). Please amend the density standard for <br />"concentrated aspen/woody plant sites" to sped both a proposed woody stem density standard <br />and an aspen stem density standard for such sites, along with supporting rationale. <br />Response: Proposed density standards are presented in the revised text. <br />3. In the approved plan, there are numerous unfenced upland shrub planting areas and one ("to be <br />fenced') mesic drainage planting site (on Annand Draw), as depicted on Exhibit22-1. The <br />current plan specifies a 2000 stems per acre woody plant standard for each of the concentrated <br />planting areas, with at least 150 stems per acre being tree species, within the mesic drainage <br />planting site. <br />In the revision plan, numerous upland planting sites and the mesic drainage site are not <br />addressed. The currently approved standard for the sites is eliminated with no rationale or <br />acknowledgement. Some revisions to the current plan are warranted and reasonable, to reflect <br />minor changes in planting site locations and configurations, and to reflect performance and <br />development of shrub patch areas over time. However, the wholesale change proposed, without <br />justification, is not approvable. Please revise the plan to address concentrated planting area <br />standards for the various concentrated planting sites depicted on Exhibit 22-1. Rationale for <br />any proposed changes to the approved 2000 stem per acre standard for the concentrated <br />planting areas, as well as any proposed elimination of concentrated planting areas or changes <br />in location or extent of such areas will need to be fully described in the application narrative. <br />Response: The text narrative and Exhibit 22-1 have been revised. <br />• <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276-5219 • FAX (970) 276-5222