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Colowyo, 03981 -019, PR3 adequacy No. 3 34 July 22, 2011 <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 />CCC commits to conducting three, one ( I ) acre field trials: one sagebrush. one tall shrub thick <br />topsoil, one tall shrub thin topsoil. CCC's statement that 12 acres of tall shrub will be targeted <br />for re- establishment, only if the one acre field trials are successful does not address CDO W <br />recommendation for establishment of 150 acres of tall shrub community as noted in CDOW <br />letter to CCC dated May 17. 2011. If the 12 acres of tall shrub CCC commits to establishing <br />uses the approach of scattered small shrub plots o ithin the 150 acres. this needs to be clearly <br />stated in the test. Please address CDOW's recommendation. and address the Division's <br />amcern. <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 achievable within the <br />10 year bond period. <br />This item has been adequately resolved. <br />4.15.8 Reveeetation 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 <br />appropriately implemented, at that time CCC may discuss "an avenue for relief'. It is not <br />appropriate to assume failure during the initial permitting of the proposed field trials. <br />