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On page 5 paragraph 4, text states-that "the shrub planting program will be oriented towards enhancement of islands where shrub cover will develop in the larger open blocks". Comparison of current and proposed Post-Mining Vegetation Map Exhibit 22-1, indicates that, in addition to elimination of all 7 mature shrub transplant sites, several upland shrub planting sites and one aspen planting site have also been deleted. Please address the reasons for the proposed reduction in upland shrub and aspen planting sites. On page 7, it is stated that the haul road to the interior of the mine area will regraded to a 50 foot shoulder to shoulder width, and retained as a permanent light duty, limited access road. Under the current permit, a road width of 20 feet is specified. A 50 foot width would seem to be excessive for a light use ranch road. Please provide justification based on the post mine land use needs for the proposed increase in road width from 20 feet to 50 feet. Seedmixes and Planting Lists 5. We recommend consideration of certain modifications to the shrub component of the Shrub Grassland seedmix (Mix 1A). Experience has shown that a relatively few native shrub species can be expected to exhibit significant establishment from seed, when included in standard rangeland seed mixtures in northwest Colorado. Mountain big sagebrush, Seriphidium vaseyanum, is the one species that has exhibited the most consistent success. The Division of Wildlife has indicated that sagebrush grassland habitats are of high importance in the region due to their use by a wide variety of wildlife species, and impacts to the type from agriculture and development. For these reasons, we recommend that mountain big sagebrush be included in Mix 1A, at a rate of 0.25 pounds per acre. The tall shrub species such as serviceberry and chokecherry seldom exhibit a significant presence on reclaimed areas when included in grass dominated seedmixes. SCC may want to consider deleting these two species from Mix 1A, and including them only in Mix 5, for concentrated shrub seeding areas. 6. Various shrub establishment approaches are discussed beginning on page 18. Establishment of the tall shrub species included in the upland planting list, and the tree and tall shrubs included in the aspen and mesic site planting lists, has proven to be challenging on reclaimed sites. Primary limiting factors include moisture regime, herbaceous competition, and intensive browsing of seedlings by deer and elk. We request that SCC give consideration to the following recommendations, and provide an appropriately amended section addressing methods to be employed in the various shrub and tree establishment areas. 1 i Employ extensive surface roughening by dozer or track-hoe gouging; 2) Use a combination of seeding and planting in all concentrated tree and shrub establishment areas. Broadcast seed all upland planting areas and aspen planting areas with Seed Mix # 5. Consider inclusion of low-competitive native fortis in Mix #5 for enhanced diversity; 3) Use elk fencing for aspen sites, mesic planting sites, and a number of upland shrub planting sites;