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that the impacts associated with this action concentrates on the negative implications that might be expected and that the positive aspects of this action have not been given the consideration we feel they deserve. Pursuant to our discussions on October 9 and November z0, we have devoted considerable time and effort for examining the possibilities of modifying our reclamation program to promote aspen reestablishment. As we stated earlier, we believed that technologically, this option was possible, but the economic considerations of irrigation and fencing would have to be evaluated. Fencing costs of $35,000 per mile were supplied to us by the CDOW and irrigation costs were obtained from Slack Butte Coal and Utah International for their Navajo and San Juan Mines. The average annual cost of irrigation was found to be approximately $1,5U0 per acre per year. Over a three year period, this equals $4,500 in increased cost. The estimated cost of fencing is calculated to equal $656 per acre. These two additional costs total $5,156 per acre, and when added to our current reclamation cost which averages $8,100 per acre would result in a 64 percent cost increase. This added financial burden would pose very serious problems and would likely render this reserve non-competitive in today's coal market. Thus, if revegetation test plots are established, irrigation and fencing do not appear to be viable alternatives to compare. We feel that the use of the live-handled topsoil will result in reestablishment of vegetative types similar to types now present on the site. We do not believe concerns that the reclaimed community will constitute a "monoculture of grass" are justified in light of the data available from sites where the practice of live-handled topsoil nos been used. We have repeatedly stated that reclaimed vegetation communities obtained using live-handled topsoil