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C1981019, TR84 Adequacy No <br />March 1, 2011 <br />important wildlife habitat for elk, mule deer, mountain lions, black bear, and wintering <br />Columbian sharp-tailed grouse, as well as, other wildlife species." The letter continues, "...the <br />chief vegetative component still missing from the site was a consistent shrub community <br />primarily consisting of Gambel's oak, serviceberry and sagebrush." In addition to the <br />serviceberry and sagebrush that Colowyo has proposed, the Division requests that Gambel oak <br />also be included in the planting plan. <br />10. In the letter dated November 5, 2010 from Colowyo Coal Company to DRMS regarding <br />Response to Preliminary Adequacy Review - TR-84, Colowyo stated in its response to item 14 <br />that the text has been amended to "include planting containerized shrubs including serviceberry <br />and mountain mahogany and recommended planting practices." It is not clear in the text where <br />mountain mahogany is being planted, size of container stock or if Weedguard is being used. <br />Please clarify location, planting procedures and stock size for the mountain mahogany being <br />planted. <br />11. Page 4.15-17, picture `Aspen/Tall Shrub Establishment General Location - This picture shows <br />the location of the proposed aspen/tall shrub trial area but does not give adequate reference to <br />location in the mine, topography, scale or cardinal directions. Please include a map of the <br />proposed area addressing these issues and the map standards of Rule 2.10. <br />12. Page 4.15-17, picture `Aspen/Tall Shrub Establishment General Location - This picture shows <br />the general location of the proposed aspen/tall shrub field trial area. The area appears to have a <br />north facing, shallow slope that is generally flat and has been disturbed by mining activity. The <br />area is also surrounded by sagebrush steppe habitat. A sagebrush steppe is characterized by low <br />annual precipitation and can be characterized a semi-arid grassland. These conditions are not <br />favorable to the establishment of an aspen community. Aspens tend to occupy sites that are <br />mesic with fine textured soils that are more fertile and they have a low drought tolerance. The <br />Division suggests that a more suitable site for the aspen trial areas be used, such as in the bottom <br />of a drainage. Please consider a relocation of the field trial area and discuss any possibilities. <br />Please show the proposed location of the field trial area on Map 28 or CCC's Reclamation Map. <br />13. Page 4.15-18, table `Aspen & Tall Shrub Field Trials Modified Sagebrush Steppe Mix' - The <br />sagebrush steppe seed mix has been modified to reduce the volume of " low shrubs" in favor of <br />the tall shrubs in the mix and the grasses were also reduced to minimize competition while still <br />providing soil stabilization. The tall shrubs that were added to the seed mix (i.e. Acer glabrum <br />and Prunus virginiana) are adapted to more mesic sites than the grasses and fortis in the same <br />seed mix. Please provide a separate seed mix designed for these field trials that contains a low <br />rate of grasses and fortis combined with tall shrubs that are adapted to mesic sites consistent with <br />the conditions associated with aspen groves. <br />14. Page 4.15-18, Illustration "Expected Field Implementation Plan for Aspen/Tall Shrub Field <br />Trials" - 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.