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The methods utilized at Colowyo to establish woody plants include accepted, state-of-the-art methodologies for establishing woody plants on disturbed lands. The Divisions comments are misleading and, again, ignore the impact resulting from intensive browsing by resident elk populations. It is our belief that any discussions by the Division regarding woody plant establishment that fails to acknowledge that severe browsing of seedlings is limiting woody plant establishment at Colowyo is a misrepresentation of the facts. We further believe that regardless of the techniques utilized to re-establish woody plants, unless browsing by elk and deer can be controlled, re- establishment of an arbitrary woody stem density will be an extremely difficult endeavor. Colowyo believes that woody plant densities can be achieved on reclaimed lands if an elk proof enclosure is constructed around the reclaimed areas, but we believe this would be counterproductive and not in the best interest of the big game populations selecting the reclaimed areas for spring, fall, and winter range. In particular, Colowyo does not wish to exclude big game populations during the winter which have increased dramatically over populations encountered on the area prior to mining. Where big game populations previously wintered in Axial Basin prior to mining, their habits have changed and Colowyo reclaimed areas appear to be increasingly utilized for winter range. Colowyo would, however, like to express our appreciation to members of DMG and Jim Morris of the DOW for taking the time to visit the mines in northwest Colorado. We look forward to working with these two agencies to develop additional long term, effective wildlife mitigation measures which, as we discussed, will benefit wildlife on a regional basis, as well as specific to the minesite. Please contact me if you have any questions. Sincerely, G. ~-~ J es A. Kiger r. Environmental Specialist JAK/gdf cc: R. G. Atkinson Central Files