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Colowyo, C1981 -019, PR3 adequacy No. 3 <br />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 />I his item remains inadequate. Please sec the Division's conunntt Ibr item number 8 above. <br />This item has been resolved with the August 9, 2011 submittal. <br />Id. CC( provided a copy to the Division of CDOW letter, dated Mav 17. 2011, tone Bill <br />deVen,ie. CDOW makes very specific recommendations regarding successful establishment of <br />woody species on the reclaimed sagebrush steppe areas: <br />"Based on further discussion internally and with DRMS. ('DOW still recommends <br />C'uluwyo's el(urts target 500 stems iact c on targeted sagebrush steppe core areas and <br />375 stentsacre in ecotonal areas. CDOW believes this is achievable with the variable <br />lopsoil plan and recommended seeding mix" <br />C'olowyo's proposed woody plant density success standard falls short of ('DOW'S <br />recommendation. Please bring section 2.05.4(2)(c) page 112 (rev. 5,20/2011) into agreement <br />with C'DOW's rcavmnendation. Please specifically state the proposed woody stem density <br />success criteria in section 4.15.8 in agreement with CDOW's recommendation. <br />This item has been resolved with the August 9, 2011 submittal. <br />2.05.02) Fish and Wildlife Plan <br />11. During the Division's 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 CCC's wildlife mitigation plan <br />until Colowyo has had a chance to review this letter and make appropriate changes to PR -3. <br />CCC replied in the cover letter but did not change any permit text. Please document any new <br />meetings with CDOW. At the time of the Division's second Adequacy Review for PR -3 (April <br />2011), Colowyo was in the process of contacting the Colorado Division of Wildlife (CDOW) <br />to discuss the issues raised in CDOW letter dated Feb 15, 2011. The Division will not make <br />comments about Colowyo's wildlife mitigation plan until Colowyo submits a plan <br />incorporating the results of the meeting. <br />