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Mr. Tom Wainwright -3- February 10, 1983 There are obvious advantages to this proposal, since it considers more than just herbaceous production and thus addresses one of the considerations in approving a reduced shrub density (how to adjust the production standard). The standard is also tailored to the primary post-mine land use (grazing) since both forage quantity and quality are incorporated. The major drawback is that, as presented, the standard would be based on pre-mine conditions and would not reflect the annual variation in production, which is the reasoning behind the reference area or historical record requirements of the regulations. The proposal may have to be modified somewhat for this reason. 4. The applicant proposes to rely primarily on natural reinvasion of woody plants from live topsoil and woody vegetation communities adjacent to disturbed areas to achieve acceptable post-mine woody densities. Shrub seeding and seedling plantings would be on a very limited basis. Studies and observations at a number of mines in northwestern Colorado have indicated that, under certain conditions, substantial volunteering of woody plants, particularly sagebrush ahd snowberry, does occur. Since this approach to shrub reestablishment is relatively new and not extensively docwnented, field trial documentation would seem to be appropriate. If re vegetation trials indicate that live topsoiling will not result in shrub reestablishment sufficient to meet the density standard and wildlife forage and cover needs, the plan would have to be modified. 5. Seeding rates should be expressed on a pure live seed per square foot basis, in addition to lb./acre. 6. The application indicates that most topsoiled areas will be cover cropped rather than mulched, and that, in same cases, a cover crop will be seeded in the fall, concurrent with seeding of the perennial mix. This added competition could potentially be detrimental to the seeded perennial species and would not provide significant benefits. Areas topsoiled in the fall should be seeded with only the permanent mix. A limited variance from the mulching requirement would be considered by the Division. Fish and Wildlife Plan - Rule 2,05.6 Based on DOW information referenced in the application, the permit area contains critical deer winter range, elk winter range and potential elk calving areas. A golden eagle nest, which was used last year, is located within approximately 200 yards of the mine area haul/access road in Hubberson Gulch. A number of concerns with regard to the reclamation plan and wildlife mitigation are discussed below. 1. The reclamation plan, as stated in the application, has been developed with livestock grazing emphasized over wildlife habitat. Shrub reestablishment is a reclamation consideration primarily due to the importance of shrubs in providing winter forage and cover for deer and elk. Shrub