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Snowmass Coal also does not agree with the Division's recommendation to remove alfalfa from the seed mixtures. At our elevations and pro- posed rates under dryland conditions, it is highly unlikely that stands would be produced which would be dominated by alfalfa. Also, it probably would fix nitrogen at much greater rates than native legumes. Like yellow sweetclover, it will not be a permanent component of the vegetation community. There are a number of problems with the native legumes at the current time. Snowmass intends to try some of these natives in small test areas around the site and will incorporate them into future seed mixes if they show promise. The main problem with the vetches is the lack of source-identified seed. Most of the natives are _ not widely adapted and importing seed from other regions may not produce very successful results. It may also be difficult, if not impossible, to get the right Rhizobium inaculum for these species. Snowmass Coal also strongly disagrees with the Division's recommendations regarding the use of crested wheatgrass. While it may be true that only two mine operations have been approved for reclamation with crested wheatgrass, we know of several others in the state for which approval is pending. We have spoken to Clem Parkin of the Colorado-Yampa Coal Co. in Steamboat Springs and we understand they are using it in their recla- mation work. Snowmass Coal believes the Division's reluctance to approve crested wheatgrass is arbitrary, capricious, and unjustified. If the approxi- mately sixty operating coal mines in Colorado were allowed to use but one grass species for reclamation, that species should undoubtly be crested wheatgrass. It is perhaps the most reliable and widely adapted species available for reclamation in the intermountain West. Certainly many more mining companies in Colorado and elsewhere would be using this species if they were not already brow-heated by the regulatory agencies' dogmatic policies on non-native species. The rates originally given for crested wheatgrass in Snowmass Coal's seed mixtures were not excessive when con- sidered on a PLS per square foot basis. As stated previously, for purposes of permitting expediency, Snowmass Coal will accede to all of the recommendations stated in the 1~larch 12, 1982 memo. Small areas along roadsides may be subject to test plantings on an occa- sional basis to try different species in seed mixes. It is Snowmass Coal's understanding that the Division will not be adverse to a company's trying new species. Thank you for your consideration. Sincerely, V ~~~ZF"_ _ _ `` Craig Sherwood Snowmass Coal Company CS:bt h