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Colowyo, C1981 -019, PR3 adequacy No. 3 14 July 22, 2011 <br />standards required by the Colorado Mined Land Reclamation Board across many vegetation <br />communities. <br />CCC repeatedly states that sagebrush steppe establishment has presented challenges on the <br />existing reclaimed areas within the Colowyo Mine. CCC isnot proposing to re- establish 6 <br />major communities and 4 minor communities that were identified in the baseline sun -ey. Map <br />46 shows CCC is proposing to re- establish 2 major communities: Sagebrush steppe, and <br />Grassland. CCC commits to achieving species diversity requirements on all micro -sites using <br />one seed mix. The Division accepts CCC's reply. <br />5. The seed mix tables 2.05 -7, -8 & -9 in Volume 1 are difficult to read due to the small font size. <br />Please re- submit these and other proposed seed mix charts with a larger font size. <br />CCC provided legible seed mix tables. This item is acceptable. <br />6. Please add text stating that the seeding rate of the drilled species will be doubled in the areas <br />which are inaccessible by the drill seeder and that these species will be exclusively broadcast <br />seeded in the areas inaccessible by the drill seeder. <br />The Division is not familiar with the relationship between increased broadcast seeding rates <br />and lower plant diversity. Doubling the seeding rate for broadcast seeding to that of drill <br />seeding is to account for loss of seeds to predation, desiccation and wind and water erosion. <br />Please provide evidence, such as peer reviewed articles /studies, that demonstrates a relationship <br />between increased broadcast seeding rates and an increase in competitive grass species thereby <br />decreasing community diversity. Note: the proposed seed mix listed in Table 2.05 -7 for <br />Collom has a very high grass component and low shrub /forb diversity. Rather than lowering <br />the seeding rate to increase diversity, another approach may be to lower the number of grasses <br />in the mix and increase the number of shrubs /forbs. <br />The Division accepts CCC's response. CCC conmiits to achieving to proposed diversity <br />standard tor both grasses and torbs in areas using this method. <br />7. Page 111, paragraph 2 — As per Rule 4.15.8(2), Colowyo mine is required to have a woody <br />plant density at least equal to that of an approved reference area. Therefore, Colowyo cannot <br />exempt itself from the woody plant density standard. Please remove this paragraph from the <br />permit. <br />Page 113, last paragraph — The response provided by Colowyo does not address the concern <br />that the text clearly states "...all previous shrub- establishment metrics indicated for use at the <br />Colowyo mine are hereby remanded." Colowyo cannot exempt itself from the woody plant <br />density standard. Please remove this paragraph from the permit. <br />CCC has removed the statement than " shrub- cstahlishmeut metics... arc ho 6% romanded ". <br />The revised text on age I I i (Cer. i,10,2011) is acceptable. No huther response is needed. <br />