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Colowyo, C1981 -019, PR3 adequacy No. 3 <br />July 22, 2011 <br />redefine what CCC means by incremental bond or provide additional information required for <br />cumulative bond schedule. <br />Rule 2.05.4(2)(e) Reclamation Plan <br />Page 111, paragraph 2 — Colowyo Mine has had shrub establishment success with the direct <br />seeding method; however, some desired plant species that have a high wildlife value did not <br />respond to the direct seeding method in the field trials as reported in the 2008 report by <br />Paschke. Two species in particular Chokecherry (Prams virginiana) and servicebeny <br />(Amelanchier alnifolia) are present in the Collom expansion area and should be included in the <br />tall shrub vegetation plan as containerized stock. Please include a plan to plant containerized <br />stock in wildlife exclosures that includes these two species. <br />Page 113, last paragraph — Chokecherry and serviceberry (highly desired plant species for <br />wildlife) did not respond to the direct seeding method in the field trials at the Colowyo Mine as <br />reported by Paschke ( "Establishing Shrubs to Achieve Bond Release on Colorado Coal Mines — <br />A Demonstration of Methods ", 2008. CSU, Fort Collins, CO). Please include a plan for <br />containerized stock in wildlife exclosures that includes these two species. <br />('(V prodded a copy of the Colorado Division of Wildlife's letter dated May 17, 201 I. [!oil) <br />Mr. Rill dcVcreic. Area Wildlife Manager, Meeker. The CDOW specifically states. <br />'VDOW also places a high value on tall shrub habitat for all species bill spcciliudly <br />sharp - tailed grouse and big game reproductive areas. CDOW is concetned that <br />continued loss of this specific habitat with no concrete plan for stand replacement will <br />begin to have noticeable impacts on wildlife in the Danforth Hills. <br />CDOW also recognizes Colowyo's reluctance to commit to 150 acres of tall shrub <br />establishment and sympathizes with this concern given the tell year bond release <br />deadline. With that in mind, CDOW proposes as alternative to a single 150 acre <br />enclosure being multiple small scale enclosed shrub plots at a density of approximately <br />five per acre randomly scattcrcd across 150 acres. Each plot would be approximately <br />36 square feet and planted with individual tublings. Simple snow fence and /or <br />hydration mats could be incorporated to enhance soil moisture tabling survival." <br />Please incorporate a tall shrub establishment plan in agreement with CDOW's suggestion. <br />This item has been resolved with the August 9, 2011 submittal. <br />10. Page 111, paragraph 5 — The use of elk proof fencing is to prevent the browsing and <br />destruction of planted shrubs (by large game animals) to ensure their establishment. The <br />Division would like to see a more proactive fencing plan to prevent the destruction of the <br />shrubs rather than a reactive approach after "excessive damage (severe hedging) to those <br />populations is noted." Please submit a comprehensive fencing plan which addresses: location <br />of exclosure (include a map), size of the exclosure and plant community in the exclosure. <br />