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One of the purposes of the cooperative CSU/CDMG/Colowyo woody plant establishment study I established in 2000 was to determine the potential to use varying topsoil depths in the establishment of woody plants in a controlled manner. The study objectives did not consider using no topsoil throughout reclaimed areas in "rangeland" areas. I suggest it is premature to modify topsoil replacement depths until the results of the 3-year study are complete. • I suggest it would be more appropriate to place annual reclamation information in the Annual Reclamation Reports rather than the Annual Hydrology Reports. • Apparently there is a proposed new Shrub Establishment Plants/ Seed Mixture - Table 3. Unfortunately, the public review copy located in the Moffat County Courthouse did not include a copy of such a Table 3. Is there such a proposal to provide such a modified mix? Table 1 proposes to include such species as Canby Bluegrass and Northern Sweetvetch in what appears to be a "base" mix. These two species were formerly included in historic Colowyo seed mixes. Because of their failure to establish these species were subsequently removed. Other local mines (ie Trapper, et al) also removed such species from their mixes. I question the logic of putting such species back into a base mix when they were removed because of their failure to perform. The 2000 Phase II bond release revegetation data provides the documentation that titer milkvetch was the key perennial fort species enabling Colowyo to meet the 3% relative cover threshold to meet the Permit Diversity standard. Cicer milkvetch has been shown to be a key fort species at other northwest Colorado mines as well because of it's ability to withstand continuing grazing pressure by elk, it's drought tolerance and it's ability to compete with other herbaceous species. (There is some limited anecdotal evidence that it has dominated some limited sites, but not at the mines in northwest Colorado). In addition, CDOW officials (personal conversations with Rick Hoffman and Tony Apa) are adamant that cicer milkvetch is a key species in coal mined land reclamation for important upland bird species such as sagegrouse and sharp-tail grouse. These species rely on cicer milkvetch for important nesting and brood rearing activities because they provide cover, insects and succulent forage. Removal of cicer milkvetch from the core seedmix will result in the inability of the reclamation to meet future bond release diversity standards and will adversely effect the potential of the reclaimed lands for wildlife habitat. I question the logic behind removing perhaps the most important forb species at Colowyo and other local mines from Colowyo's core seed mix. The Table 2 Substitute species list contains a number of species of questionable merit. I am aware of little evidence to support the substitution of the core mix species which have proven to perform quite well in northwest Colorado with poor performing species such as Junegrass, Small Burnet, Sandberg Bluegrass, Idaho Fescue, Gamble's Oak, etc. To substitute proven, reliable species with less reliable species would appear to be nothing more than an academic roll of the dice and jeopardizes eventual reclamation success. Perhaps these species can be seedmix additions to satisfy the native plant purists among us but it would 2