2011-05-23_REVISION - C1981019 (2)

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Colowyo Response - PR3 adequacy No. 2 14 May 6, 2011 not propose and does not expect to be successful establishing the sagebrush steppe plant community on 100% of the area being targeted for sagebrush steppe establishment. This concept was fully vetted and accepted as appropriate prior to the approval of TR-72 for the existing operation. Colowyo specifically defines minimum success with respect to the establishment of the sagebrush steppe plant community as follows: 3 350 total acres (combination of core and ecotonal, from targeted sagebrush steppe areas and evolved shrub areas that develop on areas receiving the grassland seed mix) a. Minimum of 175 acres must exhibit at least 375 stems/acre (can be from the "targeted" sagebrush steppe areas or from "evolved" areas, i. e. grassland targeted areas). b. Maximum of 175 acres of areas can be counted towards this 350 acre target if they are determined to display at least 200 stems/acre (can be from the "targeted" sagebrush steppe areas or from "evolved" areas, i. e. grassland targeted areas). c. Half of the shrub population in these areas must be sagebrush species. d. Colowyo will have to specifically designate the location of both grassland and sagebrush steppe areas prior to the initiation of Phase III Bond Release data collection after nature decides where these communities finally occur despite Colowyo 's best planning efforts. Map 46 serves as a Reclamation Plan map, not a Phase III bond release pre-as built map as discussed at length with the Division prior to providing updated slope information on Map 19D and updated plant community targeting information on Map 46 Descriptions in Section 2.05.4, 4.15.7 and 4.15.8 fully describe the reclamation plan strategy for the Collom Expansion Area, which are mirror images of the concepts previously evaluated and approved through TR-72, TR-82 and the pending TR-84 package. Colowyo met with CDOW on April 29, 2011 and discussed this issue and many others. Colowyo outlined the overall strategy for establishing shrubs across the entire reclamation landscape. They were supportive of Colowyo's approach and the rationale behind not applying the Phase III bond release requirements to all areas <10% slope currently targeted for sagebrush steppe establishment at the time of initial seeding. They further supported the concept of delineating successful establishment areas through Interim Revegetation Monitoring work conducted prior to the collection of Phase III Bond Release Data. It was conveyed to CDOW that the acreage difference between what has been proposed for required sagebrush steppe establishment and that which will be targeted for establishment of this plant community is built in insurance that Colowyo will be able to exceed this target. Colowyo subsequently drafted a letter to CDOW outlining the results of this meeting, common points of agreement and provided proposals for specific mitigation of impacts to wildlife species. CDOW was asked to provide a letter back to Colowyo documenting further agreement or further suggestions. CDOW in it's February 15, 2011 letter supported Colowyo's reclamation plan proposal to require sagebrush steppe establishment on 350 acres. Coloywo has also subsequently drafted a letter to USFWS providing additional detail regarding the focus and strategy of Colowyo's reclamation plan that should address USFWS's concerns about the area targeted for sagebrush steppe and overall shrub establishment across the entire reclamation surface. 0