2011-02-25_REVISION - C1981019 (3)

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C1981019, TR84 Adequacy No. 2 2 March 1, 2011 4. Page 4.15-13, bullet le- Colowyo has committed to planting commercially available 2-3 foot containerized aspen stock for planting purposes from the most similar source elevation available in the area. Research indicates that the larger the containerized aspen and native shrubs are the better their chances are for survival. The Division recommends that Colowyo use 1 gallon or larger containerized aspen, with at least 10% being 5 gallon containerized trees. 5. Page 4.15-13, bullet 1 e - It is stated "a number of (300) live aspen plants within the trial during 2016 will be considered a successful demonstration..." Please reference CDOW or DRMS literature that supports the standard of 300 stems/acre as being an adequate density. Also include the area units being measured, i.e. stems/acre. Also make the appropriate changes to page 4.15- 14, bullet 2e and page 4.15-16, bullet 3e. 6. Page 4.15-13, bullet 1 e - It is stated "Supplemental planting of aspen should be initiated in year 2012 should survival of the 2011 plantings be very low." Please change first should to will. Also, very low is a subjective phrase and needs clarification. Please reference CDOW literature, applicable studies or DRMS rules documenting at what mortality rate supplemental aspen planting will be initiated. Also make the appropriate changes to page 4.15-14, bullet 2e and page 4.15-16, bullet 3e. 7. Page 4.15-13, bullet 1 g - The planting configuration of one aspen row (five feet wide) followed by a Sagebrush Steppe mix (17 feet wide) follows the format of aspen studies at Seneca Coal Company Yoast and IIW mines. These studies examined the effects of landscape fabric and irrigation in the survival of aspen and serviceberry but do not address the goal of these field trials, which is creating wildlife habitat. Aspens tend to grow in stands or groves rather than rows. The Division suggests that the planting interval be changed to 4 rows of aspen plantings (4*5' band = 20' aspen band) followed by 4 bands of Sagebrush Steppe mix (4* 17' band = 68' band Sagebrush Steppe mix). This new pattern does not require additional materials or labor but can increase moisture retention in the aspen band by having a larger contiguous surface area covered by Weedguard, reduce edge effects of weed competition and better mimics the pattern of an actual aspen grove. The weed barrier will need to be removed in the third year to allow the growth of aspen shoots. After the Weedguard is removed, a seed mix containing native grasses and farbs (no shrubs) needs to be planted to hinder the invasion of annual invasive species. This seed mix needs to be designed and consist of species that are common to the understory of the aspen grove reference areas. 8. Page 4.15-13, bullet li -It is stated "that the requirement for 50% of the required 375 shrubs in this area be big sagebrush." Please reference where in the Colowyo permit (CO-1981-019) that sets this standard. Also make the appropriate changes to Page 4.15-14, bullet 2i and Page 4.15- 17, bullet 3i. 9. Colowyo has provided numerous commitments that will be implemented during the construction of the tall mountain shrub test plots on thick soil including the seeding of serviceberry and chokecherry. The Aug 7, 2006 CDOW comment letter for PR-2 included the following comment, "The proposed site is primarily composed of mountain shrub communities consisting of mostly Gambel oak, serviceberry and sagebrush. There is also one main stand of aspen in the upper reach of the east fork of Wilson Creek. The CDOW recognizes this community to be