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i. mature aspen, are extremely important, perhaps limiting habitats for a variety of non-game animals. Consequently, we submit that wildlife reclamation decisions must be based largely in consideration'of collective wildlife habitat value, not on impacts to a few economically or aesthetically significant species. The Service recognizes that such principles were not specified as original goals for wildlife reclamation at the Yampa mine', and therefore, do not oppose Yampa's request for land use modifications as outlined in the application. What we are concerned about is the regulatory definitions and processes surrounding land use determinations and implications for ultimate protection/mitigation of wildlife resource values ~n future applications. In the case of the Yampa mine, it is our understanding that overall post mining land use is designated for range and wildlife. Although management priority was given to select species of wildlife, habitat reclamation was originally designed to restore major wildlife habitats that were impacted (e.g. aspen). Indeed, we question whether Yampa's request for a land use revision would have been forwarded if habitat reclamation had proved more successful. We are very disappointed over the apparent lack of success for reclamation of mountain shrubs and aspen as I am sure you are. Even after a considerable number of growing seasons, Yampa has characterized the status of its own woody reclamation as "worst case" with a density of ori~ly about 750 stems/acre. Glen Crouch of the Rocky Mountain forest and Range E~tperiment Station recently told one of my staff that a density of five year oldlaspen alone of 1000 stems/acre was considered a commercial failure and that natural stands of mature aspen typically range between 500 and 700 stems/acre.) It now seems likely that aspen or mountain shrub will not be restored to reasonable aerial distribution or densities, at least not in the foreseeable future. The Service is highlighting this issue not to dampen the considerable effort and successes of Yampa's reclamation work, but to attempt to refocus some thought on practical wildlife reclamation needs First of all, we believe that current regulatory shrub density standards, 100D stems/acre, are clearly deficient. If aspen and shrub reclamation is to take place, perhaps more intensive planting and protection measures should be concentrated on smaller parcels of land. If it is not practical to res{ore substantial premining habitat conditions, perhaps we should concentrate on out-of-kind measures that would more direct}y benefit target species or guilds. Certainly we will have to more carefully scrutinize habitat tradeoffs in pre-mining decisions. For example, in consideration of our current knowletlge on aspen restoration, the Service submits that the Little Middle Creek Tract should be removed from mining consideration as long as other mining alternatives exist in the Twenty- mile Park. We believe that the large acreage of old grown aspen on the little Middle Creek Tract has wildlife resource values that far out-weigh public benefits that would be derived from mining. 2