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191. Acquisition and utilization of a Madge Rotocleaz improves Lorencito Coal Company's potential for successfully re-establishing shrub species on the reclaimed site. As stated previously, the Division has observed numerous mine sites that have had varying shrub establishment success throughout the state. Operations that have relied primarily on inclusion of shrub seed in a grass/forb seed mix as the sole method for shrub re- establishment have had limited success. Observation of a mine site east of Trinidad with a similaz habitat to the Lorencito property included shrub seed in the grass/forb seed mix. Three growing seasons following seeding limited numbers of rabbitbrush aze found on the site, no mountain mahogany have been noted, and occasional winterfat have been observed. The Division's observation has shown that seeding the shrub seed sepazately from a grass/forb seed mix has a higher probability of shrub success. The Division continues to question Lorencito's proposal to seed shrubs directly with the grass/forb mix. If Lorencito Coal Company maintains that this seeding method will achieve the proposed revegetation standazd, the Division is willing to allow a field trial initiated within the first permit term that would demonstrate that this seeding method is a viable method for achieving successful woody plant establishment (Rule 4.15.6(3)). Should the Rotocleaz be used or an alternative to establishing shrub species be proposed, a field trial may not be necessary. 192. The Division requested that Lorencito Coal Company describe methods to be used in the measurement of vegetation sampling data, Rule 4.15.7(2)(b). One purpose of this description of methodology is to assure that baseline sampling is collected in similaz fashion to post-mining vegetation success sampling, and to clazify questions inherent to specifics in the sampling. Lorencito Coal Company provided the Division with a detailed description of woody plant density baseline sampling in the cover letter. However, to assure that this important information is not lost over the span of active mining and reclamation liability time frame (perhaps 15-20 yeazs duration), this description needs to be incorporated into the permit text. Page 2.05-73 needs additional detail to describe methodology of how baseline woody plant density information was collected and how this information will be collected for determination of revegetation success. 195. The Division reviewed Lorencito Coal Company's proposed seed mix and found that the proposed grassland seed mix, Table 2.05.4-2, contains a low proportion of warm season grass seed. The Division questioned Lorencito Coal Company as to how this seed mix will provide a suitable seed source for compliance with Rules 4.15.1(1), 4.15.3(2). Since portions of the reclaimed grassland will have rangeland wildlife as the post-mining land- use, compliance with Rule 4.18(5)(1), must be demonstrated. The Division believes that a higher proportion of warm season grasses should be included in the grassland seed mix. Lorencito Coal Company stated that the landowners have requested that fewer warm season grasses be re-established in the reclaimed azeas than were present in the pre-mining community. The Division reviewed Exhibit 17, (letter from the landowners), regarding disposition of roads, post-mining topography, land-use change, and reduction in shrubs to be re-established on the reclaimed grassland azeas. This letter does not address a