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• <br />- Outdated requirements to reestablish <br />woody plants. <br />Reclamation standards established 10-15 years ago require <br />"1000 stems-per-acre" of woody plants along with grassland seed <br />mixtures. Based upon our observations it appears that the only <br />woody plant that can even come close to achieving this standard <br />is sagebrush. It appears that the elk, deer and antelope eat <br />everything else. They even eat the sagebrush seedlings unless <br />temporarily fenced away. <br />It would appear more pertinent to look at the reclaimed <br />sites together with the adjacent area habitat for wildlife. It <br />appears to us that adequate aspen and mountain shrubs exist in <br />the area and that it may be more beneficial for the reclaimed <br />areas to provide grassland forage. <br />We definitely question the need to plant more sagebrush in <br />our region. Federal and State agencies use controlled burns to <br />burn off mountain shrub and sagebrush elsewhere in our region to <br />provide more grass for wildlife. We believe it is time for the <br />regulatory agencies to re-eval~~ate *_he "1000 stems-per-acre" <br />standard and try to come up with a more innovative and realistic <br />standard. This should be done on a cooperative, not adversarial, <br />basis with the coal companies. <br />Perhaps offsite mitigation of public lands could be <br />utilized, rather than insisting on an out-of-date reclamation <br />standard that potentially reduces the productivity of the <br />reclaimed lands. <br />Site visit observations - Tra er Mine <br />Prior to the fie d visit o t e reclamation area, committee <br />representatives were provided with an overview of the coal mine <br />• permitting process required under the Federal Surface Mining <br />Control and Reclamation Act (SMCRA). The State Mine Land <br />Reclamation Board and Division has "primacy" to regulate this <br />program with Federal Office of Surface Mining oversight. <br />Each coal mine was required to provide extensive baseline <br />data regarding pre-mining conditions. This data covered soils, <br />vegetation, wildlife (primarily game animals, predators and <br />raptors), surface and ground water quality, air quality, and land <br />use patterns (primarily cropland, grazing and rangeland). <br />On the site visit we were immediately impressed with the <br />number of antelope grazing in the reclamation and mining areas. <br />Baseline data shows that prior to the mining operations this was <br />not a natural habitat for antelope. They have been attracted by <br />the improved forage available. <br />3 <br />