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Southfield Vegetation Standards <br />TR-45 January, 2015 <br />Considering that the current woody plant density revegetation success on the areas of the Trapper <br />Mine near Craig, which the Colorado Division of Wildlife (CDOW) has determined be critical <br />elk and deer wintering range, is only 400 stems per acre. At the Marr Mine in North Park, near <br />Walden, where the CDOW determined was critical sage grouse winter range, the revgetation <br />success criteria was approved at 1,500 stems per acre. Also since the approved woody plant <br />density for the Newlin Creek Mine which is less than 100 yards from portions of the Vento <br />Portal Reclamation and 500 yards from the Refuse Pile Reclamation and for the Corley portion <br />of this mine bordering the Vento Portal Reclamation, were approved by the Division as zero. <br />EFCI believes that a woody plant density of 2,794.5 or 2,095.6 shrubs per acre for these areas is <br />an excessively high figure. <br />A careful examination of the CDRMS's Southfield Mine Laserfiche Database, reveals that the <br />Vento Landowners have written numerous letters to the Division complaining about the <br />reclamation efforts of Energy Fuels and the handling of this Permit by the CDRMS. They have <br />repeatedly expressed their desires to make their lands suitable for livestock grazing and are <br />especially critical of the Rabbitbrush plants that have been established and believe that these <br />plants are competing too much with the grass they want for the cattle they plan to graze on this <br />site. When the Division has replied with information relative to this species the Vento's have <br />essentially refused to accept the information and have even reported that they "don't care about <br />shrubs " and have said that they "want grass" on their property. <br />On December 2, 2002, the CDOW issued a formal "Wildlife Statement Evaluation" at the <br />request of the CDRMS, which is found on their website as Laserfiche file # REV 80108 which <br />was submitted to revise the shrub density standard on the Corley property portion of the <br />Southfield Mine relative to MR -49. Apparently, this letter was never directly copied to EFCI as <br />they were unaware of this letter until just a few months ago. This document states that: <br />the reclamation process should be directed to the reestablishment of Mountain <br />Mahogany, Rabbit Brush, and grassland species ... <br />The seed component of other woody stem plants is readily abundant in this area In <br />particular Pinion and Juniper are becoming an invasive species across much of this <br />area. The encroachment of Pinion and Juniper trees has reduced forage and nutrient <br />availability for wildlife and reduced much of the natural edge effect important for the <br />smaller wildlife species. <br />The CDOW recommended that the reclamation efforts in this area should place more emphasis <br />on "establishing traditional open parks and meadows by removal of trees in surrounding areas. <br />.. " They also reported that there is "a strong Oak -brush component successionally replacing <br />Mountain Mahogany, Rabbit Brush and grassland species." They say that: <br />"Fewer Pinion and Juniper cover would allow for more grass production and thus <br />more feed for Elk, Antelope, Roadrunner, Scaled -Quail and other species that rely <br />upon a mix of open grassland areas bounded by woodlands for their survival strategies. <br />Reestablishment of this mined area to grassland species with a Mountain Mahogany, <br />and Rabbit Brush component would be the greatest benefit to wildlife. " [Emphasis <br />i7 <br />