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COAL <br />COMPANY <br />•PRODDC1 °°!• <br />promote shrub establishment success and create habitat suitable for <br />sagegrouse brood rearing activities. Based on over 30 years of site data, <br />Colowyo expects that environmental conditions alone will preclude successful <br />establishment of shrubs on a regular basis. On a less frequent time scale, <br />environmental conditions will also be encountered that support shrub <br />establishment pretty much wherever shrub seed is applied. Colowyo <br />developed the seed mix applied to the steeper areas across the reclaimed <br />surface to take advantage of favorable conditions for shrub establishment <br />during these years as well. The application of variable topsoil depths from <br />the top of slopes to the bottom of slopes provides additional opportunities for <br />shrub establishment across a wide regime of site and environmental <br />conditions. The entire update focused on the goal of improving shrub <br />establishment on all reclaimed areas, not just those targeted for sagebrush <br />steppe establishment. As such, Colowyo sought and was granted the right to <br />"take credit" for up to 225 acres of grassland targeted areas that exhibit at <br />least 200 stems /acre (shrubs) in order to meet the commitment of 450 total <br />acres of sagebrush steppe agreed to by all parties involved. The goal of the <br />reclamation plan is not to have regimented pieces of reclamation beneficial <br />for either livestock grazing or for wildlife habitat, but rather to establish a mix <br />of shrub concentrations, available for wildlife use that are also useful for <br />livestock. Annual interim revegetation monitoring is in place to track the <br />performance of individual reclamation blocks. This information will help us <br />identify over time how these areas are performing based on different <br />environmental, site, slope, and topsoil depth conditions to allow for continued <br />improvement in our implementation practices. The net result of Colowyo's <br />current reclamation plan should be a significant portion of the post -2008 <br />reclamation surface exhibiting a substantial shrub population that is <br />beneficial for wildlife use. Those areas targeted for sagebrush steppe <br />establishment that do not meet either the "core or ecotonal" criteria for <br />Phase Ill bond release will be identified in the bond release packages and will <br />have to meet the release criteria for the grassland areas. <br />d. Page 2.05 -6 states, "At the appropriate time post TR -72 approval (by August <br />2012, a re- evaluation will be conducted to resolve any issues involving pre <br />and post mining land uses, AVF status, reclamation plan, and AVF restoration <br />of the essential hydrologic functions for the Gossard Loadout area." (TR -82 <br />rev. 9/28/09) Has this re- evaluation occurred? If so, this statement needs to <br />be revised to reflect that these issues have been re- evaluated. If not, RN6 is <br />an appropriate time to re- evaluate these concerns. <br />Response: The pre /post mine land use and reclamation plan for the Gossard <br />Loadout area was re- evaluated and updates incorporated into the materials <br />included in TR -82 and TR -84. Re- evaluation of the AVF status of the Gossard <br />A Western Fuels - Colorado, LLC mining property <br />