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The Company and Grand County are in agreement as Amendment one (1) is <br />proposed. <br />Amendment two (2) requests a general change of post mining land use from "Open <br />Forest" to "Rangeland". Recently, the Company submitted a proposed change via (technical <br />revision 12) in land use designation from "Open Forest" to "Rangeland." The Colorado Division <br />of Mineral and Geology (the "DMG") countered with a three (3) point proposal that the <br />Company declined for the present. The Company states that they aze not seeking to eliminate tree <br />planting completely. Rather they aze proposing to reduce tree planting significantly to a <br />documented level compatible with "Rangeland" on their property (i.e., Strata 12). Strata 12 is an <br />area near and azound the tailings pond area that has been heavily affected by commercial logging <br />and thinning operations and the area has a natural occumng stocking rate of 40-50 trees per acre. <br />If, promotion of a healthy rangeland is the reclamation prescription, said natwal stocking rates aze <br />acceptable and sustainable. On the other hand, the Company has a Forest Management Plan that <br />calls for a re-stocking rate of 400-435 trees per acre, which is more representative of a "Forested" <br />post-mining land use. It is recognized that there aze huge reclamation costs looming and that a <br />"Rangeland" designation would now, of cowse, better suit the Company's desire to greatly <br />reduce financial warranty. Certainly, economic reasonableness is a consideration for reclamation. <br />Reclamation is "designed to minin+i~e as much as practicable the disruption from the mining <br />operation and to provide for the establishment of plant cover, stabilization of soil, the protection <br />of water resowces, or other measures appropriate to the subsequent beneficial use of such <br />affected land (i.e, restoration to a sub-alpine/alpine ecosystem, forest management (health and <br />safety), commercial timber operations and grazing)." The proposed general change to <br />"Rangeland" is in principle saying that the value and the subsequent beneficial use of the affected <br />land is plant cover for forage. The reclamation would be native shrubs, grasses and forbs. Further, <br />it represents grazing to be the primary post-mining land use, which is not 100% indicative of the <br />land uses on this property and on adjacent public lands. Grazing is currently accommodated on <br />site and it is questionable whether the management of this use is yielding a particulazly healthy <br />rangeland. The Company by their own actions recognize that this landscape is much more than <br />"Rangeland" as they have conducted timber management, forest management and gazing <br />operations for more than 20 years, and they have done it with the assistance of the Colorado State <br />Forest Service, the U. S. Forest Service and the Soil Conservation Service. The "Open Forest" <br />post mining ]and use is most appropriate as it best represents the landscape, ecosystem and <br />multiple uses for this azea of Grand County (the upper Williams Fork Valley). In addition, the <br />current post mining designation is a "best fit" with the management prescription of the adjacent <br />public lands. The County does not support the requested change to "Rangeland", as it is not <br />acceptable from an overall ecosystem point of view. A re-definition of trees and shrubs stocking <br />rates could definitely analyzed as part of this amendment. It is the County's rewmmendation that <br />the stocking rate for trees and shrubs in the Reclamation Plan be re-defined to a rate of 400-435 <br />per acre, which is consistent with the Company's Forest Management Plan. <br />Page 3 of 9 <br />