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1 <br />Mr. Rick Mills -2- October 7, 1993 <br />Colorado Yampa Coal Co. <br />which burned in Moffat County this summer. Although this proposal was creative and one <br />which deserved consideration, it appears it will not be necessary since BLM felt strongly <br />enough about the issue that they have secured the seed necessary to achieve their goals. <br />Therefore, this proposal cannot be considered at the present time. <br />In the report titled 'Report on the Northwest Colorado Coal Mine Reclamation Programs, A <br />Local Perspective,' recommendation number 3 encourages a cooperative review to be under- <br />taken between the coal companies and the MLRB, DMG, and the DOW. This review would <br />address a more innovative and flexible standard with regard to woody plants. One thing we <br />possibly all agree upon is that current knowledge with regard to reclamation and wildlife habitat <br />has advanced beyond simply a 1000 stem per acre standard. As evidenced by the reclamation <br />plans at numerous mines, including Trapper Mine and the Eckman Park Mine, additional <br />practices of shrub clump establishment, water tank development, and post-mining topographic <br />diversity are used in conjunction with a shrub standard for determination of success and <br />ultimate bond release. The DMG and the DOW are very interested in productive and serious <br />proposals with regard to shrub standards and wildlife habitat reestablishment. However, those <br />discussions should be conducted outside of the scope of this particular revision. In the interest <br />of resolving this issue, the Division of Wildlife would agree to reducing the shrub standard by <br />ten percent on rangeland areas to assist CYCC in meeting the required shrub density standard <br />for final bond release. <br />The remaining element of the current proposal from CYCC consists of the donation of the 'tree <br />beaver" equipment. This alone would not be considered appropriate at the present time due to <br />numerous factors (current condition, maintenance and operation costs, etc.). <br />I look forward to further discussion concerning these options at your convenience. Your <br />cooperation and diligence in the process is noted and appreciated. <br />Sincerely, <br />Kent A. Gorham <br />Reclamation Specialist <br />KAGlbjw <br />m:\ose\bjw\kep.pr <br />