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III IIIIIIIIIIIIIIII~ Memorandum To: Byron Walker From: Janet Binns- Date: 04/11/02 Re: TR-52 inclusion of Ponderosa Pine as a substitute species File: C:/jhb/team/Colowyo I looked at Colowyo's proposed seed mix for TR-52 again, at your request. You had expressed concem regazding Colowyo Coal Company (CCC) including Ponderosa Pine as a substitution species in the reclamation seed mix, Table 2.05-7. Your concem was based on not having observed this species in the azea of the mine or in the general vicinity of Southern Moffat, Northern Rio Blanco County. I consulted the NRCS Range Site descriptions, and Colowyo's baseline vegetation data, and NRCS Plants Database on the World-wide Web (http://plants.usda.gov). I did not have a distinct identification of the Range Site category that Colowyo is described by. I looked at the physical descriptions, [he soils found, and the counties the range sites are found in. The closest Range Sites Descriptions that would apply to the Colowyo Mine site include; Deep Loam # 292, Loamy Slopes # 303, Loamy Breaks #300, and Brushy Loam # 238. None of the Range site descriptions included Ponderosa Pine in the native vegetation description, nor in the percent composition. I would agree with you that Ponderosa Pine is not seen in this vicinity naturally. However, it is considered a native species to Colorado and is not a noxious invader species. CCC is not proposing to include this in the regular mix but as a substitution should other species on the approved list not be available. Ponderosa would only be used as a 3`d choice for substitution with Chokecherry and Skunkbrush sumac having a higher probability of being used. Of more concem is the fact that this species is reputed to be very difficult to establish from seed. Although a good seed crop may occur every 2-3 years, proper seedling establishment conditions may occur at much longer time intervals, like every 25 years. Ponderosa Pine are also susceptible to competition by grasses. 1 don't have a problem with CCC including this species in the mix. I suspect the probability of establishing this species from seed, without making a concerted attempt at reducing forb and grass competition, will result in very little if any success in establishing Ponderosa. The operator has proposed appropriate woody plant species in the regular seed mix.