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succession of shrubs can be accelerated. PWCC can agree with this up to a point, but it appears CDOW believes restoration on a moderate scale (1000 stems/acre) on extensive reclaimed areas is quite achievable. When one considers the level and extent of surface mine disturbance; successional time frames, processes, and patterns unique to reclaimed lands and disturbed premine communities; and the requirement to meet other regulatory requirements and parameters such as erosion protection and vegetative cover and production, the feasibility of this moderate scale quickly dwindles. Monitoring and ongoing observations in reclaimed areas show some areas can have densities of 1000 stems/acre or more; however, many of the areas have lower densities or no shrubs. Problems related to woody plant establishment have been discussed on Pages 39 and 40 in revised Tab 13. Ecological and successional processes were considered in the discussion. Reclaimed area monitoring data for the Seneca II Mine has been collected since 1985. This data was 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 determined what additional practices should be employed, and what level of success these operators anticipated based on past and present practices. It appears, with the exception of areas that have received intensive shrub establishment procedures, that surface mines in northwest Colorado will probably not be able to meet a 1000 stem/acre average density. Based on the above, PWCC proposed what it felt is a more realistic standard in revised Tab 13. An overall standard less than 1000 stems/acre should not necessarily reflect a lack of success in woody plant reestablishment. It reflects a combination of ecological, operational, and regulatory constraints. Monitoring data from the Seneca Mine indicates that a 1000 stem/acre average density will be very difficult when possible successional levels are considered for a 10, 15, or 20-year time frame. Significant changes in site conditions and other controlling factors affect succession. 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 5