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the stands mature, "islands" for seed and vegetative dispersal in the future and <br />demonstrating successful planting approaches for use in the region. <br />Given the intensity of elk use at Colowyo, and results the Division has observed <br />at Colowyo and other mines in northwest Colorado, including recent and on-going <br />research as well as operational plantings, fencing to exclude elk appears to be <br />necessary for successful establishment of aspen and tall shrub species such as <br />serviceberry and chokecherry. Proper substrate and site conditions, appropriate <br />planting stock, and use of weed barrier or other intensive measures to control <br />herbaceous competition also appear to be necessary considerations. <br />Please review previous letters from the Division and DOW regarding this <br />matter, and provide detailed plans for the establishment of both thick soil <br />(aspen/chokecherry/serviceberry etc.) planting sites and thin/rocky soil <br />(serviceberry, bitterbrush, etc.) planting sites. In the Division's most recent <br />meeting with DOW staff, Jon Wangnild indicated a number of smaller tall <br />shrub and aspen planting sites would be acceptable, in lieu of the two relative <br />large planting areas that DOW had requested in their 7 March 2008 letter. <br />These smaller tall shrub and aspen planting areas would need to total 40 <br />acres. For example, Colowyo could choose to plant four 5-acre aspen sites <br />and four 5-acre tall mountain shrub sites (in lieu of one 20 acre site for each). <br />This approach is also acceptable to the Division. <br />On 4 February 2010 the Division also received a letter from the DOW regarding TR-84 <br />(attached). In this letter the DOW states that the Colowyo Mine is "...located within <br />areas classified as suitable for Greater Sage Grouse habitat." The letter further states that <br />"...tall shrub and aspen communities offers the opportunity for Greater Sage Grouse and <br />Elk to utilize these areas with success." This is the fourth letter from DOW that requests <br />the reestablishment of tall shrub and aspen planting areas at the Colowyo Mine. Per Rule <br />4.15.8(7), the Division is continuing correspondence with the DOW on shrub plantings. <br />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 <br />mountain shrub communities and approximately 222 acres of aspen communities. In TR- <br />84 Colowyo has proposed doing 1 acre trials for reestablishing aspen and mountain shrub <br />communities. Colowyo has proposed one, 1 acre aspen trial and two, 1 acre mountain <br />shrub trails. These trials amount to the reclamation of 0.45% of the aspen communities <br />that will be disturbed and 0.24% of the mountain shrub communities that will be <br />disturbed. These proposed trials are very little in the overall disturbance and minimize <br />the wildlife component of the reclamation as required. <br />In TR-84 Colowyo has proposed to initiate three 1-acre field trials for aspen and tall <br />mountain shrub communities. One of the areas will be an aspen community with thick <br />topsoil, one a tall mountain shrub community with thick topsoil and one a tall mountain <br />shrub community with thin topsoil. The Division agrees with these trials, but given the