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C1981019, TR84 Adequacy No. 2 response <br />April 8, 2011 <br />sets this standard. Also make the appropriate changes to Page 4.15-14, bullet 2i and Page 4.15- <br />17, bullet 3i. <br />Colowyo's Response: <br />Colowyo has reduced the sagebrush component of the seed mix to 0.25 lbs/acre in the field trial <br />areas to reduce the influence of sagebrush in these areas. The approved woody plant density <br />standard was previously approved in TR-72 and can be found in Section 4.15.8. This section is <br />referenced in the text as requested. Colowyo is maintaining the 375 stems/acre shrub density <br />requirement for Phase III release of this area, but appropriately dropping the additional <br />sagebrush specific stipulation. <br />9. Colowyo has provided numerous commitments that will be implemented during the construction <br />of the tall mountain shrub test plots on thick soil including the seeding of serviceberry and <br />chokecherry. The Aug 7, 2006 CDOW comment letter for PR-2 included the following <br />comment, "The proposed site is primarily composed of mountain shrub communities consisting <br />of mostly Gambel oak, serviceberry and sagebrush. There is also one main stand of aspen in the <br />upper reach of the east fork of Wilson Creek. The CDOW recognizes this community to be <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 />Colowyo's Response: <br />For clarification, Gambel's oak was dropped from consideration in the field trials based on the <br />relative performance of this specie at other local operations that have attempted re- <br />establishment. Multiple meetings and communications with CDOW stating Gambel's oak would <br />not be pursued have been conducted since 2006, and DBMS staff have also supported not <br />including Gambel's oak in these efforts. Furthermore, Colowyo's consultant Cedar Creek, who <br />performs vegetation monitoring at dozens of mines around the Western US. has only seen <br />Gambel's oak establishment at a single operation, and that was in New Mexico under <br />significantly different environmental and edaphic conditions. Furthermore, the density of oak <br />establishment at this location ranged between I and 60 plants per acre, with an average of about <br />20 per acre after 12 years (average height was 15 centimeters). <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 />Colowyo's Response: