2003-03-11_REVISION - M1977342 (3)

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United States Forest Sutphnr 9 Ten Mile Drive bepartment of Service Ranger District P.O, Box 10 Agriculture Granby, CO 80446 'Voice: {970} 587-4100 TDD: (970) 887-4101 Web: wWw.fsfed.us/r2/arnf Fax: (970)887-4102 File Code: 2720-2-1 Date: March 10, 2003 Allen Sorenson Division of Minerals and Geology 1313 Sherman Street, Room 215 Denver, CO 80203 Dear Mr. Sorenson: Thank you for the opportunity to comment on the proposed amendment to the approved Reclamation Permit for operations by Climax Molybdenum Company, Henderson Mine and Mill. The Forest Service wishes to provide comments on two sections of the proposed amendment. Secrion 2.2-Change in General Pasr-mining Land Use. This section of the amendment would change the post-mining land use of a large react of land below the tailings impoundment from Open Forest to Rangeland, The affected areas were clear cut of lodgepole pine over the past ZO years, and insufficient stocking of 40-50 trees per acre has persisted since that time. The proposed change would perpetuate this understocked condition and allow for orange-type habitat in an area that was historically a fully stocked forest. Aerial photos taken in the yeaz 2000 of forested Climax land and adjacent National Forest System lands show surrounding stands of densely stocked mature lodgepole pine. Photos of the Climax land before logging show densely stocked mature lodgepole pine. Soil and ecological unit maps indicate that the site potential is for fully stocked lodgepole pine with understories containing russet buffaloberry, common juniper, and/or Rocky Mountain whortleberry. Both the photos and soil data suggests that the landscape is capable of supporting fully stocked stands of lodgepole pine as it did prior to harvesting 20 yeazs ago These sites provide important summer cover for upland big game species. In order to provide a continum of habitat between surrounding National Forest System lands and Henderson Mill land, and to reclaim the land to its pre-mining vegetative condition, stocking levels which mimic natural conditions should be required. Legally mandated National Forest minimum post-harvest stocking levels are 150 trees per acre, while Climax's own Forest Management Plan calls for a higher stocking rate of 400-435 trees per acre. Slow growth rates and low available nutrients and moisture may require additional mulching or cover for successful revegetation. Also the erosion potential is severe, even though the slopes are generally less than 4096. Loss of topsoil or compaction due to logging and/or livestock grazing may have affected site potential. If so mitigations such as tillage, additional soil cover, or other site preparation techniques, which, would enable seedlings to become established and flourish an the land, may be necessary to offset the impacts of grazing and timber harvest over the last 20 years. If this is truly a Caring for the Land and Serving People ~,~,c.e m naya,a Povn `~