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5. Page 4.15-13, bullet 1 e - It is stated "a number of (300) live aspen plants within the trial <br />during 2016 will be considered a successful demonstration..." Please reference CDOW or <br />DRMS literature that supports the standard of 300 stems/acre as being an adequate density. <br />Also include the area units being measured, i.e. stems/acre. Also make the appropriate <br />changes to page 4.15-14, bullet 2e and page 4.15-16, bullet 3e. <br />6. Page 4.15-13, bullet le - It is stated "Supplemental planting of aspen should be initiated in <br />year 2012 should survival of the 2011 plantings be very low." Please change first should to <br />will. Also, very low is a subjective phrase and needs clarification. Please reference CDOW <br />literature, applicable studies or DRMS rules documenting at what mortality rate <br />supplemental aspen planting will be initiated. Also make the appropriate changes to page <br />4.15-14, bullet 2e and page 4.15-16, bullet 3e. <br />7. Page 4.15-13, bullet 1 g - The planting configuration of one aspen row (five feet wide) <br />followed by a Sagebrush Steppe mix (17 feet wide) follows the format of aspen studies at <br />Seneca Coal Company Yoast and IIW mines. These studies examined the effects of <br />landscape fabric and irrigation in the survival of aspen and serviceberry but do not address <br />the goal of these field trials, which is creating wildlife habitat. Aspens tend to grow in <br />stands or groves rather than rows. The Division suggests that the planting interval be <br />changed to 4 rows of aspen plantings (4*5' band = 20' aspen band) followed by 4 bands of <br />Sagebrush Steppe mix (4* 17' band = 68' band Sagebrush Steppe mix). This new pattern <br />does not require additional materials or labor but can increase moisture retention in the <br />aspen band by having a larger contiguous surface area covered by Weedguard, reduce edge <br />effects of weed competition and better mimics the pattern of an actual aspen grove. The <br />weed barrier will need to be removed in the third year to allow the growth of aspen shoots. <br />After the Weedguard is removed, a seed mix containing native grasses and forbs (no <br />shrubs) needs to be planted to hinder the invasion of annual invasive species. This seed <br />mix needs to be designed and consist of species that are common to the understory of the <br />aspen grove reference areas. <br />8. Page 4.15-13, bullet li -It is stated "that the requirement for 50% of the required 375 <br />shrubs in this area be big sagebrush." Please reference where in the Colowyo permit (CO- <br />1981-019) that sets this standard. Also make the appropriate changes to Page 4.15-14, <br />bullet 2i and Page 4.15-17, bullet 3i. <br />9. Colowyo has provided numerous commitments that will be implemented during the <br />construction of the tall mountain shrub test plots on thick soil including the seeding of <br />serviceberry and chokecherry. The Aug 7, 2006 CDOW comment letter for PR-2 included <br />the following comment, " The proposed site is primarily composed of mountain shrub <br />communities consisting of mostly Gambel oak, serviceberry and sagebrush. There is also <br />one main stand of aspen in the upper reach of the east fork of Wilson Creek. The CDOW <br />does recognize this to be important wildlife habitat for elk, mule deer, mountain lions, black <br />bear, and wintering Columbian sharp-tailed grouse, as well as, other wildlife species." The <br />letter continues"... the chief vegetative component still missing from the site was a <br />consistent shrub community primarily consisting of Gambel's oak, serviceberry and <br />2