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Kent A. Gorham Page Eight February 1, 1993 but they are not the same species. Given this information, if the only measure of wildlife value is acre per acre diversity then all we should manage for is edge to the exclusion of grassland and even some forest dependent species. A broader perspective is obviously needed in order to promote true biodiversity especially in light of the fact that habitat fragmentation may be the major cause of decline for some migratory songbirds. 3.) Past reclamation success standards which have been properly changed and approved by the Division are no longer relevant and certainly are not pertinent to this permit revision. CYCC would remind the Division that the 1000 stem/acre woody plant standard was an evolutionary process that affected almost all of the mines in Colorado and that CYCC did not receive any preferential treatment. There are other large surface mines not far from CYCC that have been granted even lower overall shrub density success standards. Furthermore, the success of shrub establishment efforts is a bond release issue and even then is not applicable if this revision is approved. Finally the Division already has a number of reports submitted by CYCC over the years on shrub establishment success, i.e. on livehandled topsoil, etc. as well as a Masters Thesis on front end loader shrub transplant success Carlson 1982. 4.) The question regarding management measures which CYCC will use on pasturelands was asked and answered during approval of T.R. 17 (see DMG adequacy review dated 7/13/88 and CYCC response dated 7/26/88 also pages 780-204 and 780-206 (b) of the permit). The current condition of the reclamation is excellent from a livestock forage standpoint, therefore as previously described the only near term management that should be required is appropriate grazing management practices. However long term management may require any or all of those practices associated with pasturelands, i.e., seeding, fertilization, brush control and pest control. Due to the current condition of the reclamation CYCC does not believe that any of these long term practices will be necessary prior to bond release. 5.) CYCC does not dispute the fact that the LMCPR, TR-17, PR3 are all separate, independent actions which are not contingent upon one another. However, both the wildlife mitigation plan for the LMCPR and TR-17 were approved. Much of the LMCTPR wildlife mitigation plan was even implemented, i.e., songbird and raptor monitoring and aspen regeneration study and CYCC will now not benefit from it because the tract proved uneconomical to mine. If the true concern is loss of shrub and tree dominated habitats then consideration should be given to the fact that the LMCT will now not be mined, and as a result the associated shrub and tree dominated habitats are not lost. 6.) CYCC controls some but not all of the surface and minerals within the three and five mile radius mentioned in the correspondence dated 9/14/92. The portions which CYCC controls are shown on the surface and coal ownership maps in the permit. Using