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• <br />TR -48, Aspen /Woody Plant Density Standard <br />Page 3 <br />b. Two fenced riparian areas are described in the text but only one is shown on the map. <br />c. The text says there are three fenced upland woody plant sites and the map shows four. <br />d. The text says there are two unfenced upland woody plant sites but the map shows three. <br />Also, specifically reference these areas in the text by name or community type rather than <br />`remaining two upland woody plant sites ' for clarity. <br />Response: Exhibit 22 -1 and the text page 48 have been revised to address the above issues. <br />4. The text makes reference to Exhibit 22 -1A — Post - mining Vegetation Map for the locations <br />and designations of woody plant concentration sites. The map the Division received is called <br />Exhibit 22 -1 sheet 2 of 2. Please fix the map and /or text for consistency. Also please provide <br />an updated version of Exhibit 22 -1 — Post - mining Vegetation Map, sheet 1 of 2 that reflects <br />any previous revisions and those proposed in TR -48. <br />Response: The text reference has been corrected to reference Exhibit 22 -1 (sheet 2 of 2). There <br />is no reason to provide an updated version of Exhibit 22 -1 (sheet 1 of 2) because no changes <br />have been proposed to the entrance road corridor since originally submitted and approved. <br />S. Rule 4.15.8(7) requires that for areas with a wildlife postmining land use the minimum <br />stocking levels ...must be determined on the basis of local and regional conditions after <br />consultation with and approval by the Colorado Division of Wildlife (CDOW). Since Seneca <br />is proposing a reduction in the minimum stocking levels, the CDOW was consulted and <br />reviewed the proposal. CDOW's comments are in the attached letter. Please incorporate <br />these comments into TR -70 [sic]. <br />CDOW Comments <br />a. CDOW suggests that domestic livestock grazing be banned in reclamation areas to <br />encourage woody plant growth. While wildlife grazing may be difficult to control, we <br />can and should control livestock grazing in these areas. <br />Response: Experience and studies have shown that controlled grazing can actually promote <br />increases in woody stem density (see Tab 22, page 2 and Annual Revegetation Monitoring <br />Reports, 2008, 2009). Data indicates that woody stem density can readily increase when the <br />herbaceous component is reduced or eliminated. <br />SCC has a grazing plan in place. SCC does not allow grazing to begin prior to mid -July <br />(following annual revegetation monitoring) and ends around October 1 depending on the <br />pasture conditions and weather. SCC sets the number of animals and grazing days allowed for <br />each pasture or area based on past production results obtained from vegetation monitoring <br />results. This grazing plan has been accepted since inception and the details are presented in each <br />Annual Reclamation Report. <br />