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Colowyo, C1981-019, PR3 adequacy 16 <br />February 25, 2011 <br />4. The S&W Study (Section 8.0, page 12) provides specific conclusions and recommendations <br />regarding construction of the excess spoil pile. Section 9.0 addresses S&W's Monitoring <br />recommendations. Language found in Rule 4 (pp. 22-23) does not clearly commit Colowyo to <br />following the S&W conclusions and recommendations. Please revise Rule 4 Section 4.09 to <br />clearly communicate CCC's intent. <br />4.15.1 Revegetation General Requirements <br />Page 27, Use of Introduced Species - In the second exception for use of introduced species, it <br />is stated "prior to the use of aggressive taxa to combat areas that are highly susceptible to <br />erosion, an MR or TR will be obtained from CDRMS to address such circumstances." <br />Aggressive is a subjective term that is not well defined as it applies to introduced or native <br />species. For better clarification as to when the Division will be contacted with discretionary <br />use of introduced species, change `aggressive taxa' to `introduced species.' <br />2. Pages 30 and 31, bullet h -Please include a timeline as to when the "elk proof' fencing will be <br />erected around the perimeter of the trial area to protect it from ungulates. <br />3. Pages 30 and 31, bullet i - In the event of a stand failure in the field trial areas, the Division <br />agrees with Colowyo that the area will revert back to sagebrush steppe for the purposes of <br />Phase III bond release. The requirement that 50% of the 375 shrubs will be sagebrush <br />however, needs to be maintained for wildlife and sage grouse habitat. The Division feels that <br />this low standard is achievable due to the fact that sagebrush will be seeded between the <br />planted rows. Please rephrase this sentence so this standard will be maintained rather than <br />"dropped." <br />4. Page 31 - The diagram illustrates that the planting arrangements and density for containerized <br />plant stock is 550 plants/acre. The planned area is shown to be 220 feet by 220 feet or 48,400 <br />ft2. An acre is actually 43,560 ft2, -10% less than the diagram illustrates. This difference in <br />square footage lowers the actual stem count per acre resulting in a perceived mortality rate. <br />Please adjust the planting densities to 43,560 ft2 per acre to reflect this difference. <br />4.15.7 Determining Revegetation Success: General Requirements and Standards <br />1. Page 33, last paragraph - Please explain in greater detail the method used to determine the <br />weighted reference areas and justify the results. <br />2. Page 33, footnote at bottom of page - The Division feels that it is not the best practice to wait <br />several years for a seeded area to "evolve into a sagebrush steppe community" for the purposes <br />of bond release, but rather to create a reclamation plan within a designated area (i.e. fencing, <br />special seed mix etc.). To meet the standards of Rule 4.15.8(7) and the standards requested by <br />the CDOW (letter dated February 15, 2011), the Division suggests that Colowyo commit now