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Colowyo, C3981 -019, PR3 adequacy No. 3 16 July 22, 2011 <br />Page 114, paragraph 4 — Elk proof fencing is an effective way to prevent the browsing and <br />destruction of planted shrubs to ensure shrub establishment. Given the intensity of elk use at <br />Colowyo, and results we have observed at Colowyo and other mines in northwest Colorado, <br />including research as well as operational plantings, fencing to exclude elk appears to be <br />necessary for successful establishment of shrub species including serviceberry and <br />chokecherry. This technique has been used with great success at other mines and has proven to <br />increased shrub survival and density. The Division would like to see a more proactive fencing <br />plan to prevent the destruction of the shrubs rather than a reactive approach after "excessive <br />damage (severe hedging) to those populations is noted." Please submit a comprehensive <br />fencing plan which addresses: location of exclosure (include a map), size of the exclosure and <br />plant community in the exclosure. <br />this item Ienmins ineday aide. Please see the Dig isiim'e continent tier item number � .ibo\ e. <br />11. Page 112, last paragraph — The use of the "banding" technique is not warranted on slopes with <br />a gradient less than 10 %. The Division feels that the techniques of contour furrows, surface <br />roughening and seeding on the contour, already proposed by Colowyo, is adequate for erosion <br />control on these slopes. Please remove this paragraph from the text. <br />This item has been resolved. <br />12. Page 113, last paragraph — The use of the word indication/indicated is unclear in this sentence. <br />Please revise.bfb <br />CCC removed the word "indicated ". This item has been resolved. <br />13. Please address all of the items in the vegetation section of the attached CDOW letter dated Feb <br />15, 2011 in this section of the permit. <br />This item has been resolved. <br />14. CCC provided a copy to the Division of CDOW letter, dated May 17. 2011, term Bill <br />deVergie. CDOW makes very specific recommendations regarding successful establishment of <br />woody species on the reclaimed sagebrush steppe areas: <br />"Based on further discussion intenwlly and with DRMS, CDOW still recommends <br />Colowyo's efforts target 500 stems /acre on targeted sagebrush steppe core areas and <br />375 stems /acre in ccotonal areas- CDOW bulioves this is achievable with the variable <br />topsoil plan and recommended seeding mix" <br />Colowyo's proposed woody plant density success standard tails short of CDOW's <br />recommendation. Please bring section 2.05,4(2)(e) page 112 (rev. 5,20 1011) into agreement <br />with CDOW's reconunendation. Please specilicalh state the proposed woody stem density <br />success criteria in section 4.15.8 in agreement with CDOW's recouunendation. <br />