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<br />Kent Gorham <br />May 7, 1993 <br />Page Five <br />A review and analysis of rangeland reclamation success criteria <br />does not indicate that re-establishment of edge was a major goal. <br />Historically, rangeland has been largely grouped into large <br />segments, especially prior to the previous land use revision, not <br />interspersed with pastureland. Furthermore, rangeland is mostly <br />located adjacent to habitats already dominated by shrubs. <br />Even under the rangeland definition, brush control is allowed. <br />Given that the postmine land use is a livestock operation, it is <br />not practicable or economical to allow succession to occur which <br />would reduce available livestock forage by 100 to 300$. <br />The portion of the reclamation plan that does provide for some edge <br />is the establishment of shrub dominated islands by use of front-end <br />loader transplants. CYCC has established approximately 9.2 acres <br />of these islands (which represents 8.4 acres per 1000 acres of <br />rangeland reclamation) which support more than 10,000 stems/acre. <br />CYCC proposes to leave these islands for wildlife. CYCC does not <br />agree with CDOW's conclusion; (letter dated 2/10/93) that no credit <br />should be given for the edge associated with these clumps because <br />they have not evolved to the extent CDOW thinks necessary. <br />5. Concept of equal or better use - The concept of equal or <br />better certainly depends on what one's objectives are. Cyprus <br />believes that consideration should be given to the desires of the <br />landowner to utilize the reclaimed areas for pastureland. <br />Pastureland produces two to four times as much available forage for <br />livestock as the premine vegetation. As documented in CYCC's <br />grazing study, a 1000 acres of pastureland represents more <br />efficient use of the land. <br />6. Key species vs. overall wildlife resources - CYCC disagrees <br />with the Division regarding the applicability of the data CYCC has <br />collected on key species with regard to the proposed future <br />habitat. As previously pointed out, the conditions under which <br />most of the wildlife data was collected emulates the proposed <br />habitat more closely (in terms of total shrub, grass and forb <br />biomass and available habitat) than does the current situation. <br />This is because mining was at its peak and the amount of <br />disturbance was at its peak, and that rangeland reclamation <br />completed was very young. Therefore, the amount of habitat <br />available was even more limited than what is proposed. The <br />contribution from shrubs other than front-end loader transplants <br />was insignificant. Even now shrubs (other than front-end loader <br />transplants) do not contribute significantly to cover or edge. <br />Shrub contribution from a forage standpoint is even more limited. <br />Grazing has always been part of the reclamation plan. This is not <br />a new factor. Furthermore, well managed rest rotation grazing will <br />provide a substantial amount of forage which will be available for <br />