2011-02-22_REVISION - C1981019 (4)

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erosion, an MR or TR will be obtained from CDRMS to address such circumstances." Aggressive is a subjective term that is not well defined as it applies to introduced or native species. For better clarification as to when the Division will be contacted with discretionary use of introduced species, change `aggressive taxa' to `introduced species.' 2. Page 29, first paragraph - As per Rule 4.15.8(2), Colowyo mine is required to have a woody plant density at least equal to that of an approved reference area. If best management practices are followed, such as installing fencing before elk browsing occurs, Colowyo will have a successful establishment of tall shrubs. Other mined land reclamation experiments at Seneca Yoast and Seneca IIW have shown this to be possible. Please remove the sentence in this paragraph describing the use of the information from these trials as "an avenue for relief of the tall shrub establishment area expectations" from the permit. 3. Pages 30 and 31, bullet h - Please include a timeline as to when the "elk proof' fencing will be erected around the perimeter of the trial area to protect it from ungulates. 4. Pages 30 and 31, bullet i - In the event of a stand failure in the field trial areas, the Division agrees with Colowyo that the area will revert back to sagebrush steppe for the purposes of Phase III bond release. The requirement that 50% of the 375 shrubs will be sagebrush needs to be maintained for wildlife and sage grouse habitat. The Division feels that this low standard is achievable due to the fact that sagebrush will be seeded between the planted rows. Please rephrase this sentence so this standard will be maintained rather than "dropped." 5. Page 31 - The diagram illustrates that the planting arrangements and density for containerized plant stock is 550 plants/acre. The planned area is shown to be 220 feet by 220 feet or 48,400 ft2. An acre is actually 43,560 ft2, -10% less than the diagram illustrates. This difference in square footage lowers the actual stem count per acre resulting in a perceived mortality rate. Please adjust the planting densities to 43,560 ft2 per acre to reflect this difference. 4.15.7 Determining Revegetation Success: General Requirements and Standards 1. Page 33, last paragraph - Please explain in greater detail the method used to determine the weighted reference areas and justify the results. 2. Page 33, footnote at bottom of page - The Division feels that it is not the best practice to wait several years for a seeded area to "evolve into a sagebrush steppe community" for the purposes of bond release, but rather to create a reclamation plan within a designated area (i.e. fencing, special seed mix etc.). To meet the standards of Rule 4.15.8(7) and the standards requested by the CDOW (letter dated February 15, 2011), the Division suggests that Colowyo commit designated areas at the time of reclamation to establishing sagebrush steppe to ensure successful shrub establishment. 3. Page 34, footnote at bottom of page - Many reasons have been given as rationale to lower the herbaceous cover of reclaimed areas from 90% to 70% of the sagebrush reference area's cover. Along with the given rationale, please provide additional documentation and/or data which support the proposal that a 90% cover of sagebrush reference area is not possible within the 10 year bond period. 4.15.8 Revegetation Success Criteria 5