2013-04-05_PERMIT FILE - C1981019 (10)

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RULE 2 PERMITS Because the amount of grasses (and all sod - formers) has been substantially reduced for this sagebrush steppe mix, it is possible that on occasion, grass emergence may not be satisfactory for erosion control or life form diversity. In such circumstances a supplemental "inter- seeding" with the grassland mix may be necessary to "bolster" the grass and forb component of the community. This activity is allowed under Rule 4.15.7 (5)(g). Such an inter - seeding would only occur if adequate sagebrush or other shrub seedlings have emerged from the initial seeding, otherwise a "reseeding" or "augmented seeding" would be mandated. Furthermore, such an inter - seeding must occur within the first four years from the date of the initial seeding to avoid circumstances that would "reset the bond release clock ". If "inter- seeding" is necessary on any units of land, CDRMS will be apprised in the Annual Reclamation Report. The high rate of seeds per square foot in the sagebrush steppe mix is simply a result of the small seed size for several taxa in the mixture (e.g., sagebrush at 2,500,000 seeds / pound). The individual species have been selected for their habitat forming characteristics for sage grouse during their brooding period. None of the individual seeding rates are excessive given the current state of knowledge, nor is the seeding rate per acre excessive for combination drill / broadcast seeding. However, this mix has not been designed to ensure quick erosion control for immediate stabilization of the topsoil and therefore, should not be used on slopes that exceed 10 %. Furthermore, it may need to be planted intermittently (banding) with the grassland mix on long, low- gradient slopes. For additional information regarding this planting technique, see the "Planting and Seeding Methods" section below. The introduced taxon that is included in the seed mixtures above, ( Cicer milkvetch), has been retained in the mix to provide forage for both wildlife (elk and sage grouse) and livestock. Furthermore, Cicer milkvetch is an excellent species for providing necessary habitat requisites for a variety of insects that in turn are especially important to sage grouse broods. It is a well- documented observation that insects comprise a very significant portion of young sage grouse diets. Similarly, the introduced species, small burnett, has been retained in the contingency species list (Table 2.05.8) owing to its well documented value to wildlife. Data on reclaimed areas at Colowyo, has indicated that orchard grass is an important grass species for controlling erosion and providing cover the first growing season, while decreasing subsequent growing seasons. Orchard grass comprised 0.13 plants per square foot the first growing season, while decreasing to less than 0.02 plants per square foot the second growing season. This indicates the effectiveness of orchard grass to provide erosion control early on revegetated areas, while not sustaining this vigor in later years due to increased competition and crowding by other species as well as targeted selection by elk (i.e. it has been repeatedly observed in Colowyo reclamation, that orchard grass plants have been selectively consumed by resident elk, and therefore, can be considered highly desirable forage). Also, data from Exhibit 10 indicates that Kentucky bluegrass is the most important grass species contributing to the pre -mine vegetative diversity. Given the aforementioned, it must be accepted that there is a place for certain introduced species in Colowyo reclamation. In 2008 and thereafter, occasional use of introduced species may occur, but will be limited (as indicated in the seed mixes) to specific circumstances. The only circumstances where limited use of introduced species will not be followed are instances where a unit of land is Rule 2 Permits 2.05 -30 Revision Date: 6/11/12 Revision No.: RN -06