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Colowyo, C1981-019, PR3 adequacy 9 February 25, 2011 <br />6. Please add text stating that the seeding rate of the drilled species will be doubled in the areas <br />which are inaccessible by the drill seeder and that these species will be exclusively broadcast <br />seeded in the areas inaccessible by the drill seeder. <br />7. Page 111, paragraph 2 - As per Rule 4.15.8(2), Colowyo mine is required to have a woody <br />plant density at least equal to that of an approved reference area. Therefore, Colowyo cannot <br />exempt itself from the woody plant density standard. Please remove this paragraph from the <br />permit. <br />8. Page 111, paragraph 2 - Colowyo Mine has had shrub establishment success with the direct <br />seeding method; however, some desired plant species that have a high wildlife value did not <br />respond to the direct seeding method in the field trials as reported in the 2008 report by <br />Paschke. Two species in particular Chokecherry (Prunus virginiana) and serviceberry <br />(Amelanchier alnifolia) are present in the Collom expansion area and should be included in the <br />tall shrub vegetation plan as containerized stock. Please include a plan to plant containerized <br />stock in wildlife exclosures that includes these two species. <br />9. Page 111, paragraph 3 - Please expand on the details as to when and which stabilization <br />method will be utilized on road cuts. Include the seed mix used and explain the use of species. <br />Also, this paragraph was written in the past tense as if the roads have been cut and stabilized. <br />Please re-write this paragraph in the present or future tense to prevent confusion as to what has <br />been accomplished and what will be performed. <br />10. Page 111, paragraph 5 - The use of elk proof fencing is to prevent the browsing and destruction <br />of planted shrubs (by large game animals) to ensure their establishment. The Division would <br />like to see a more proactive fencing plan to prevent the destruction of the shrubs rather than a <br />reactive approach after "excessive damage (severe hedging) to those populations is noted." <br />Please submit a comprehensive fencing plan which addresses: location of exclosure (include a <br />map), size of the exclosure and plant community in the exclosure. <br />11. Page 112, last paragraph - The use of the "banding" technique is not warranted on slopes with <br />a gradient less than 10%. The Division feels that the techniques of contour furrows, surface <br />roughening and seeding on the contour, already proposed by Colowyo, is adequate for erosion <br />control on these slopes. Please remove this paragraph from the text. <br />12. Page 113, last paragraph - The use of the word indication/indicated is unclear in this sentence. <br />Please revise. <br />13. Please address all of the items in the vegetation section of the attached CDOW letter dated Feb <br />15, 2011 in this section of the permit. <br />2.05.6(2) Fish and Wildlife Plan <br />1. During the Division's Adequacy Review for PR-3, the Division received comments from the <br />Division of Wildlife (attached letter Feb 15, 2011) pertaining to the mitigation of impacts to