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-7- Since livestock yrazing is the proposed primary post-mining land use, and given the landowner request, shrub reestablishment may not be required. This determination will depend on resolution of the issues noted in Section XIII Wildlife of this letter. A proposal for evaluating species diversity and a species diversity standard, as required by Rule 4.15.8(5) must oe included in the application. 5. The primary seed mix, which includes a number of introduced forage grasses, includiny crested wheatgrass, may be appropriate given the land use considerations and landowner request. N concern expressed in the past with regard to crested wheatgrass is that, when used in a mix with native species it will tend to dominate the stand to the exclusion of other seeded species. This concern is based primarily on research in the northern great plains, but has not been documented in northwestern Colorado. The applicant should commit to a revegetation monitoring program which will document the competitive relationship among the various species. 6. During past site inspections, Uivision Reclamation Specialists have noted evidence of sheep grazing on newly reclaimed areas. Rule 4.15.5(2) specifies that grazing not be allowed on reclaimed areas until the Division has been satisfied that vegetation is adequately established. The applicant should provide a plan for excluding sheep from newly reclaimed areas. 7. The applicant has stated that broadcast or liydroseediny rates will be 1.5 times the drill seeding rates. The rate for hydroseeding or broadcast seeding should be twice that of drill seeding. This correction should be made. 8. There is a contradiction between the text and Tables 4, 5, and 6 with regard to seeding rates. The text states (page IV-1U) that rates presented in the table "are suitable for hydroseeding; for drill applications, the rates may be adjusted by a factor of .5". The Tables state, "lb/acre drill; x 1.5 for broadcast or hydroseed." This inconsistency should be corrected. XIII. Fish and Wildlife - Rules ~.U4.11, 2.05.6(2) and 4.18 Two areas of deficiencies have been identified by the Uivision of fined Land Reclamation and the Division of Wildlife with respect to the Grassy Creek Fish and Wildlife Mitigation Plan. These deficiencies will need to be resolved before a permit can be issued for the operation.