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Jim Morris December 9, 1993 Page 2 Reclaimed area monitoring data for the Seneca II Mine have been collected since 1985. These data were used to determine shrub establishment and development patterns in areas where both extensive and intensive reclamation practices have been applied. Discussions with other operators in northwest Colorado were used to determine what additional practices should be employed, and what level of success these operators anticipate based on past and present practices. It does appear, however, that with the exception of areas receiving very intensive and costly shrub establishment procedures, the surface mines in northwest Colorado will probably not be able to meet a 1000 stem/acre average density. Based on the above, PWCC proposed a more realistic standard in revised Tab 13. An overall standard less than 1000 stems/acre does not necessarily reflect a lack of success in woody plant reestablishment. It reflects a combination of ecological principles, operational practices, and regulatory constraints. Monitoring data from the Seneca Mine indicates a 1000 stem/acre average density will be very difficult when a level of succession is considered for a 10, 15, or 20-year time frame. Significant changes in site conditions and other controlling factors affect succession. Very competitive herbaceous communities are established to stabilize the site, and these herbaceous communities may also reflect long-term mid- successional levels for woody plant communities. Reclaimed plant communities may not follow the same pathways and patterns of succession as in native communities. It is possible that reclaimed areas may follow divergent pathways to somewhat altered climax communities. Temporal factors must be an important consideration in establishing the standard. For a discussion on this subject, please refer to the recent publication "Evaluating Reclamation Success: The Ecological Consideration" - Proceedings of a Symposium. Chambers, J.C., G.L. Wade, eds. Gen. Tech Rep. NE-164. USDA-USFS, Northeastern Forest Exp. Station. The distribution of shrubs in reclaimed areas is generally highly variable and will result in large scale and costly sampling efforts. These data reflect populations which are not normally distributed. The contribution of high density areas to the average density will be quickly reduced when zero or low density plots are encountered. The average number of woody plants per acre may not be high, but the large diversity in stand density (reflected in large sample variances) creates the