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20. Concentrated shrub establishment areas in previously reclaimed portions of the original permit area were mapped and sampled by ESCO Associates, Inc., within a supplement to the 2004 Annual Revegetation Report. Comparison of Map 1 "Shrub Concentration Blocks" of the report supplement, with proposed PR-5 Permit Exhibit 22-1 "Post-Mine Vegetation Map Mine Area" indicates general agreement between the two maps, with respect to the older establishment areas that were investigated in the 2004 Revegetation Report supplement. Compared to the currently approved version of Exhibit 22-1, the PR-5 proposed map reflects a reduced number of upland shrub planting sites in the more recently reclaimed portions of the original permit area. The intention may have been to offset the reduced number of upland shrub planting areas by inclusion of the two large shrub establishment sites on the steep south facing slopes of the "D" Pit and "B" Pit, which were reclaimed in 2004. However, these two locations were not originally approved as shrub establishment areas, and the site conditions may not be conducive to shrub establishment. The "D" Pit steep slope area has been severely infested by noxious weeds, and the "B" Pit steep slope area less severely infested, as previously described. Necessary renovation of these two areas will require herbicide spraying and reseeding with perennial grasses, which will reduce the acreage of shrub establishment areas considerably. Please amend PR-5 Exhibit 22-1, to eliminate the "D" Pit south facing slope shrub area and to reduce or eliminate the "B" Pit south facing slope shrub area as appropriate. Please include additional, smaller shrub establishment areas in appropriate locations along recently reclaimed drainages and north facing slopes, to more closely correspond to shrub site locations as depicted on the currently approved version of Exhibit 22-1, for the original permit area. 21. The 2004 supplemental report documents very poor survival of desirable tall shrub species such as serviceberry, chokecherry, gambel oak, and mountain mahogany. Relatively high shrub densities within the shrub establishment areas are due largely to big sagebrush, Woods rose, and snowberry. Unless measures are taken to protect plantings of the highly palatable tall shrub species from browsing, the potential for successful establishment appears to be quite low. Please consider modification of PR-5 revegetation text to specify installation of elk fencing for a number of shrub establishment sites in the original permit area where tall shrub species will be or have recently been planted, similar to the approved plan for the South Extension Area.