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"- Discussions relating to achievable woody plant density levels have been previously held with the Division for the Seneca II and Seneca II-W Mines. These same arguments are presented in Tab 22 of the Yoast PAP. Similar arguments have been raised by other operators in Colorado. These arguments have centered on two regulatory opinions: high woody densities are necessary to return viable wildlife habitat for a variety of wildlife species, and 1000 or more stems per acre can easily be reestablished over extensive areas of reclamation in relatively short time frames. Wildlife will be affected by mining disturbances and some species will be displaced. Yet, the gradual return of these species will pattern on successional processes taking place in the reclaimed plant communities. The evidence at the Seneca II Mine and other northwest mining operations indicate many species of wildlife are attracted to reclaimed areas in the absence of well-developed woody plant communities. Mule deer and elk are common in reclaimed areas year-round and this has had, ironically, a negative impact on woody plant establishment efforts. These big game species are attracted to the herbaceous dominated reclamation because these lands offer what native lands often cannot - an abundance of nutritious forage (many times available even in winter months, as standing hay), earlier green-up than any native areas benefiting gestation/lactation requirements, and improved • foraging access with escape cover nearby. Small mammals are also commonly found in reclamation. Many birds, including mountain bluebirds, blue grouse, kestrels, vesper sparrows, golden eagles, marsh hawks, and various waterfowl can be found using reclaimed areas. The question becomes then, if these reclaimed areas are not adequate for wildlife because of "low" woody plant densities, then why are these and other wildlife species present? It should be expected that wildlife populations will go through the same successional processes as the vegetation communities, resulting in different kinds and numbers of species over time, not necessarily species associated with sub-climax or climax conditions. Please note the CDOW comments faxed to PWCC on February 15, 1995 did not identify any concerns or problems with the proposed woody plant establishment plan or the woody plant density Standards. In the Division's January 20, 1995 adequacy review package for the Yoast PAP, Comment 81 reflects the greatest deterrent to the quick (i.e., by the end of the liability period) establishment of moderate woody plant densities: cover adequate to control erosion (Rule 4.15.1(2)(b)). Corresponding to this is the requirement to meet production and diversity standards. The cover standard for the Seneca II, Seneca II-W, and Yoast Mines will be greater than 50 percent vegetative cover (reflecting reference area values) and comprised of primarily perennial species. The attainment • of the cover goal plus production and diversity requirements severely reduces any opportunity for establishment of even 21