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Kent Gorham May 7, 1993 Page Four 3. Use of past data collected to project future impacts (or lack thereofl - CYCC agrees that the applicability of any study from one site to another or one set of conditions to another should be closely examined. CYCC also believes that the conditions under which the elk study data was collected much more closely represents the future proposed conditions than any of the studies used by the Division, DOW, USFWS and BLM to project adverse impacts to elk. CYCC's elk study represents a site specific study. Most of the data was collected when mining disturbance was at its peak and what little rangeland had been reclaimed was very young (very little shrub biomass). These conditions represent a much more significant loss of habitat than the future proposed conditions represent. Thus, supporting CYCC's opinion that wildlife has not or will not be impacted by its mining and reclamation operation. In contrast, studies supplied by the Division, via CDOW, are studies conducted in Montana, California, Oregon and Washington. 4. Loss of edoe - The importance of vegetative edge to all species of wildlife which were identified in the permit area through baseline studies is not well documented. Even the original NW Colorado Coal EIS, which assumed most reclaimed mined lands would be converted to grasslands (5170 acres at CYCC) predicted that those species associated with grasslands would be beneficially impacted. It also predicted that this reclamation would support abnormally high rodent populations. "High rodent numbers are expected to attract and sustain larger than normal numbers of predators, mainly coyotes, fox, snakes and raptors." Site specific data provided by CYCC (see 2/1/93 Adequacy Response) supports some of these predictions. Lyon & Jensen (1980) (article provided by Division via CDOW) in their discussion of edge and clear cuts used by elk and deer state: "In view of the variability reported, it seems safe to conclude that big game use of clear cuts will not be predictably consistent in all locations and habitats." "Size of opening, in fact, may be less important than some other considerations, particularly for elk herds that normally spend at least part of the year on ranges with large natural openings." "Eastern Montana deer apparently were not influenced by opening size." These studies show that the importance and amount of edge required by wildlife populations varies significantly. This is why CYCC has requested specifics on what species would be impacted and how they would be impacted. Once this information is provided, further review can be completed to assess potential impacts. However, it is CYCC's understanding that the latest measurement of edge is 40$ of the premine edge (letter dated 2/10/93) as opposed to the 1$ presented previously (letters dated 10/30/92 and 11/10/92).