REV97888

• Permit No: C1981071
• IBM Index Class Name: Revision
• Doc Date: 2/3/1993
• Doc Name: PR 03 ALTERNATE LAND USE ADEQUACY RESPONSE PN C-81-071
• From: CYPRUS EMPIRE CORP
• To: MLRD
• Type & Sequence: PR3
• Media Type: D
• Archive: No

Kent A. Gorham
Page Ten
February 1, 1993
the amount of edge due to Improved Lands is removed in order to
represent the amount of edge prior to man's influence there is only
81,500 ft. of edge premine (49 ft./acre). Using these figures the
existing edge is 51% of the historical premine edge. These figures
do not take into account any credit for mature shrub and tree
transplants. There are over 1000 clumps of mature shrub and tree
transplants (each consisting of multiple front end loader pads).
These clumps average greater than 225 ft' each with over 60 linear
feet of edge each. This contributes over 60,000 ft. of edge. When
these figures are added to the previous figures, this reclamation
has 102,000 feet (62 ft/acre) of edge, 87% of premine edge or 127%
of historical premine edge.
As previously pointed out the amount of edge and certainly the type
of edge needed depends on what species we are trying to promote.
Furthermore, vegetative edge as measured above is only on measure
of cover. The cover requirements of various species, i.e. security
requirements of big game, can be met by other types of cover such
as topographic cover which is present on the reclamation.
CYCC has not attempted in this response to reply directly to CDOW
or USFWS concerns but only to the Division's concerns. However,
CYCC appreciates receiving the Division's correspondence with these
agencies because it gives us a better perspective on the issues the
Division has raised. Because the USFWS correspondence was received
after the Division's adequacy review, CYCC would like to now
briefly respond to issues raised in it.
First of all, with regard to neotropical birds in general the
previous information and discussion needs to be taken into
consideration. With regard to MacGillavray's warbler specifically
I would like to point out that:
1) Terry Ireland (USFWS) indicated in a telephone
conversation that the Colorado Bird Observatory ranking had no
status because there had not been a peer review of this material.
2) A review of the Colorado Bird Observatory ranking (as
found in Carter & Barker's publication "An Interactive Database For
Setting Conservation Priorities For Western Neotropical Migrants")
indicates that the high ranking for MacGillavray's warbler is not
because of any known threat to this species but because of a lack
of knowledge concerning it.
3) Scott's (1986) study at CYCC shows that MacGillavray's
warbler is the fifth most abundant of 30 species nesting in
Mountain Shrub vegetation types, the eighth most abundant of 30
species nesting in Aspen Edge vegetation types, and 10th most
abundant of 30 species in Aspen vegetation types. Given that
Mountain Shrub is the single most abundant vegetation type at 25%
and Aspen second most abundant type at 20% in 650 mi' area
surrounding the mine it certainly does not appear that this species
should be of concern. This information is also pertinent with
regard to the Columbian sharp-tailed grouse. There appears to be
an ample supply of Mountain Shrub habitat to meet the wintering
needs of these birds. If there is any data which suggests that