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Colowyo, C1981 -019, PR3 adequacy No. 3 17 July 22, 2011 <br />4.15.7 Determinina Reveeetation Success: General Requirements and Standards <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 />C'CC commits to conducting three. one (I ) acre field trials: one sagebrush, one tall shrub thick <br />topsoih one tall shrub thin topsoil C'C'C 's statement that 12 acres of tslt shnih will he targeted <br />tilt re- establishment- only it the one acre Geld trials are successful does not address CDOW <br />recommendalion for esmblishnteot of 150 acre, of tall shrub connnwtity as noted in CDOW <br />Idtel in ('CC, dated ALN I'. _'01 1 If the I? aces of tall Shruh C'C'C Commits to estaMishin,, <br />uses ihC:gtprouCh A 1Caucral snmll Shrub plots within the I50 acres, this need, n> he clearly <br />.tared in the test. Plcaae address ( D(AA" I ecommendm ion. and addle.. the DIN ision" <br />C,mCCrn. <br />This item has been resolved. <br />4.15.8 Reveeetation Success Criteria <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 />CC'C has not addressed this item. phis item remains inadequate. <br />This item has been resolved. <br />4.18 Protection of Fish, Wildlife, and Related Environmental Values <br />1. At the time of the Adequacy Review for PR -3, the Division received comments from the <br />Division of Wildlife (attached letter Feb 15, 2011) pertaining to the mitigation of impacts to <br />wildlife. The Division will not make further comments about Rule 4.18 — Protection of Fish, <br />