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Kent Gorham May 7, 1993 Page Two satisfy the Division regarding CYCC's intent, CYCC would like to add the following details to its management plan for pasturelands. If the average production of adapted domesticated forage plants falls below 1500 lbs/acre investigations will be initiated to determine the cause of the lost production. The investigations will include soil nutrient analysis, assessment of lost production due to increased brush, assessment of lost production due to pests, and assessment of lost production due to increase of less desirable species. As soon as probable causes of lost production are identified appropriate pastureland management activities already identified will be implemented. 2. Pastureland as Wildlife Habitat - The goal of achieving wildlife habitat is based on the predictions of adverse impacts to wildlife populations. The Division, based upon recommendations from CDOW and USFWS, continues to support the assertions that this proposed alternate land use will adversely affect wildlife. These claims regarding adverse affects have not been documented or well substantiated. CYCC has repeatedly requested details on what species would be impacted and how they would be impacted. Currently, CYCC has not received sufficient information from the Division to understand the nature of their concern. Statements such as state-of-the-art and time-honored practices do not constitute evidence or documentation supporting these assertions of adverse impacts. The literature provided by CDOW (13 publications, 10 of which are dated 1976-81) is the same literature supplied prior to the start of CYCC's elk study and is not site specific to CYCC. These articles do not refute the conclusions in CYCC's site specific elk study which show no adverse impacts to elk. An example of unsupported claims is found in item 2 of CDOW's 2/10/93 letter and in CDOW's 11/10/92 letter. These letters assert that the subject reclaimed area is not as valuable to elk as it once was. They also claim that this area is winter range but is no longer critical habitat because of alterations due to mining. However, at the same time, they report that populations in this area have not declined and that elk use of reclaimed area is not disputed. CYCC's elk study and a significant amount of elk literature (Elk of North America Ecology & Management) and other evidence (USGS Snow Course Data) substantiate that the premine subject area was not elk winter range. CDOW has defined elk winter range in Data Analysis Unit E6 (DAU E6) as: That part of the home range of elk where 90% of the individuals are located from December 15 to April 30 during the average five winters out of ten winters. CYCC's elk study shows that from 1981 to 1987, during the period of mid-December through mid-April less than 2% of all radio collared elk locations (20 out of 1051 relocations) were in habitats and on aspects and elevations similar to the premine condition of the subject area.