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1 Kent Gorham May 7, 1993 Page Three This makes sense when one examines the USGS snow course data for Eckman Park on aspects and elevations similar to the subject area. Data from 1987 to 1992 show snow depths from January through April ranging from 24 to 44 inches and averaging 38 inches. Many elk researchers have documented that elk avoid snow depths greater than 18 inches and some consider 28 inches critical (see Elk of North America Ecology and Management pages 308, 379, and 380). There also appears to be a conflict in CDOW's statement regarding critical habitat. CDOW's definition of critical habitat states that the loss of this habitat would adversely affect that species, and yet they agree that the elk population has not declined in the area. It appears that CDOW is relying on predicted adverse impacts identified in the original NW Colorado Coal Environmental Impact Statements. These documents predicted that use by elk would be reduced 100$ within a quarter mile radius of mine facilities and active mining. These documents also predict that 21$ of the local populations would be displaced and eventually lost. The rationale for these losses is that the animals would be moving into areas already supporting populations in balance with their habitat, or in other words, already at carrying capacity. These adverse impacts have not materialized. First of all, elk were not displaced to the extent predicted. Second, these predictions do not take into consideration limiting factors. The affected area consists of summer and calving ranges which are not limiting to this elk population and are not at carrying capacity because winter range is the limiting factor. The Division (item 3 letter dated 10/30/92) and CDOW (letter dated 2/10/92) have both indicated that the loss of 1000 acres of elk• calving and summer habitat would have an adverse affect on the local elk population. As pointed out in CYCC's seven year elk study, these projected adverse impacts have not materialized. These predictions of adverse impacts fail to take into consideration limiting factors. If calving habitat was a limiting factor, one would expect that the loss of it would result in reduced reproductive success of elk. However, there has been no reduction in cow:calf ratios on the mine site. In contrast, if winter range is the limiting factor then it makes sense that calving habitat is not at carrying capacity. When one compares the amount of winter range to calving habitat and the forage quality, as well as evidence showing when most natural mortality occurs, it is easy to see that winter range is limiting, not calving range. With regard to Rule 4.18(5)(i)(i) the usefulness of pastureland plant species to wildlife such as elk has been well documented (see page 780-206(d) Revised 5/23/88 of Permit C-81-071).