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Jim Morris December 9, 1993 Page 3 potential for more edge and greater heterogeneity in the patternof shrub distribution. Again, please refer to the enclosed Tables 19 to 26. The tables also show, with the exception of Gambel oak, all major shrub species occur in reclaimed areas. Over time, shrubs will expand into low density areas, resulting in greater variation in age class of the shrub stands. Wadge pasture sampling (Table 25) in 1992 showed 12 percent of the plots had 0 shrubs, 60 percent had 40 to 400 shrubs per acre, 16 percent had 400 to 800, 4 percent had 800 to 1000, and 8 percent had greater than 1000. Sampling for shrubs in reclaimed areas has historically resulted in standard deviations that equal or are greater than mean values. Therefore, the greater challenge may be to determine through adequate sampling what the true density and distribution of shrubs is on reclaimed lands. PWCC is also puzzled by CDOW's statement that they do not agree that reclaimed areas are beneficial to wildlife. Ironically, the attraction of reclaimed areas to deer and elk and in some cases marmots, rabbits, and porcupines, has been detrimental to shrub establishment programs. By CDOW's own admission, there is no longer a concern about big game and mining (specific critical habitat issues excepted). Contrast this to concerns in the late 1970's and early 1980's. Benefits of herbaceous dominated reclaimed areas to big game have been discussed in Tab 13. These areas provide good spring, summer, and fall range, especially when nutritional requirements for large ungulates is considered. As an example, alfalfa can provide similar digestible protein and energy, phosphorous, and carotene levels to Gambel oak at various times during the year. Many other species of wildlife are observed in reclaimed areas on a daily basis. Raptors, passerine birds, grouse, reptiles, and a variety of mammals are present. Ferruginous hawks have been sighted over reclaimed areas occasionally, while golden eagles nest and are active in the mine vicinity. It is true that species requiring tall shrub habitat or denser stands of shrubs may be displaced or otherwise affected. Just as reclaimed habitat cannot provide thermal cover or browse during winter months, native shrublands may fall short in providing forage benefits equal to reclaimed areas in spring and early summer. However, on a regional scale, tall shrub and sagebrush habitat is much greater in areal extent compared to reclaimed habitat. This also raises questions as to whether reclaimed areas fulfill a role in diversifying regional habitat? Fire as an environmental factor has been controlled; however, it is