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Colowyo, C1981-019, PR3 adequacy No. 2 25 April 22, 2011 <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 />This item has been adequately resolved. <br />2. Page 33, footnote at bottom of page - The response provided by Colowyo does not address the <br />need for a comprehensive shrub establishment plan. The Division feels that it is not best <br />practice to wait several years for a seeded area to "evolve into a sagebrush steppe community" <br />or to let "Mother Nature... determine the plant community expressed..." as explained in <br />Colowyo's response to adequacy review. To meet the standards of Rule 4.15.8(7), the Division <br />suggests that Colowyo commit to fencing designated areas at the time of reclamation to <br />establishing a sagebrush steppe plant community to ensure successful shrub establishment. <br />Please submit a detailed shrub establishment plan (additional to the trial areas) that includes: <br />location of exclosures (include a map), size of the exclosure and plant community in the <br />exclosure. <br />3. Page 34, footnote at bottom of page - Many reasons have been given as rationale to lower the <br />herbaceous cover of reclaimed areas from 90% to 70% of the sagebrush reference area's cover. <br />Along with the given rationale, please provide additional documentation and/or data which <br />support the proposal that a 90% cover of sagebrush reference area is not acheivable within the <br />10 year bond period. <br />This item has been adequately resolved. <br />4.15.8 Revegetation Success Criteria <br />1. Page 38, last paragraph- Colowyo has proposed that the maximum proportion of countable <br />shrubs of fourwing saltbush be 20%. Please include an explanation in greater detail (including <br />documentation/data collected at Colowyo and other locations) that supports this proposed <br />standard. <br />This item has been adequately resolved. <br />2. Page 39, Diversity - The diversity standards proposed for the Collom Expansion Area are <br />different from the diversity standards in the Colowyo Mine. Please provide an explanation and <br />supporting evidence justifying the differences in diversity standards. <br />This item has been adequately resolved. <br />3. Page 29, in the discussion of Field Trials for tall shrub , please remove the sentence in this <br />paragraph describing the use of the information from these trials as "an avenue for relief of the <br />tall shrub establishment area expectations" from the permit. Should best management practices <br />demonstrate that establishment of tall shrubs is unobtainable when the approved techniques are