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_33_ Colowyo requested a variance from the pze-mine shrub density requirement and proposed 450 woody plants per acre as the density standard. The Division requested that Colowyo provide documentation that the proposed density would support the post-mining land use of wildlife habitat. Colowyo, in cooperation with the Division, organized a meeting among several of the mining companies in Northwestern Colorado to discuss this issue. It was concluded that input should be solicited from a number of sources, including government land management agencies, the Division of Wildlife, shock growers and academians. It was agreed that an attempt would be made to develop local and regional shrub density standards, based on recommendations from the above mentioned parties arri further research carried out by MLR and a number of the mining companies in Northwestern Colorado. On August 5, 1981, MLR staff members met with representatives of the Bureau of Land Management, Forest Service, Soil Conservation Service, the Division of Wildlife, Colowyo, Energy Fu e1 s, and Utah International. Each of the parties present at the meeting agreed to submit written comments and recommendations. It was pointed out at the meeting that wildlife concerns are the primary reason for including woody plant density as a criteria for revegetation success. DOW's recommendations were to concentrate on size, spacing and arrangement of shrub clumps, as well as density within clumps necessary to meet various wildlife habitat requirements. It was stressed at the meeting that there are trade-offs between woody and herbaceous communities with respect to erosion protection, watershed functions and livestock grazing. The ultimate objective is to establish woody plant density standards that are reasonable and feasible, given current technology, and which will support the post- mining land use goals. The following stipulation is necessary: Stipulation No. 5 WITHIN ONE YEAR OF PERMIT ISSUANCE, THE PERMITTEE WILL PROPOSE TO THE DIVISION AN ACCEPTABLE STANDARD, BASED ON AVAILABLE DATA FOR THE MOUNTAIN SHRUB AND SAGEBRUSH TYPES, FOR THE DETERMINATION OF REVEGETATION SUCCESS FOR WOODY PLANT DENSSTY. THE STANDARD WILL REFLECT CONSIDERATION OF LOCRL AND REGIONAL RECOMMENDATIONS BY STOCK GROWERS, THE DIVISION OF WILDLIFE, AND APPROPRIATE LAND MANAGEMENT AGENCIES, AND WILL BE BASED ON THE NEEDS OF THE POST-MINING LAND USE. The Division expressed, in the Preliminary Adequacy Letter of April 9, 1981 that an upward adjustment in the herbaceous cover or production standard would be required .to compensate for the partial elimination of the woody component. Colowyo proposed that a statistical comparison of total cover (including woody plaihtrs) would be made between the reference areas and the reclaimed areas. The Division request, in a letter of July 9, 1981, that the sampling method proposes for measuring total cover be detail ad. This was provided in Colowyo's responses of August 21, 2981. Rev~eta ti on success criteria at Colowyo will entail total cover, rather than herbaceous cover, in addition to herbaceous production, woody plant density and species diversity.