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Kent A. Gorham Page Three February 1, 1993 elevation and aspects result in snow accumulation which preclude access to forage. CYCC's elk study confirms that the majority of their reclamation is not elk winter range. As previously pointed out the northerly aspects, i.e. CYCC reclamation, which support aspen are selected against during the winter. If the Division still questions whether the reclamation of concern is winter range more data is available to substantiate CYCC's claim that it is not (i.e., snow course information from USGS) but time has not permitted us to include it at present. The importance and contribution of these large grassland habitats to the health of local elk populations should not be overlooked. As previously cited, in CYCC's permit pages 780-206 (c) and (d), CDOW's own publication points out that the nutritional status of cow elk, particularly in the autumn, is probably the single most important factor affecting reproductive success. In that publication, Trainer is cited as concluding that the level of energy intake or demand during the fall was the most important factor determining conception rates of adult female elk. The importance of elk condition, i.e., fat reserves, as they enter winter has been documented in a number of studies as important to survival and reproductive success. (See "Elk of North America Ecology & Management). Bulls too have a very high energy demand following the rut when fat reserves have been depleted and prior to the full onset of winter. Given this, it should not be surprising that pasturelands with their abundant highly palatable domesticated forage are selected for during the fall. CYCC acknowledges that some elk calving and summer range may have been lost but believes that this has been more than compensated for by the value of the fall range inherent within the pastureland. The health of the local mining impacted elk populations is substantiated by the elk study. Table 8, 1985 report; Table 7, 1986 report; and Table 5, 1987 report; confirm that cow:calf ratios for elk populations impacted by mining are as high as those not impacted by mining. These tables also indicate that the elk populations have not decreased on the mining impacted sites and in fact may be higher than on non-mining impacted sites. Although population estimates are difficult to obtain and these helicopter surveys were designed to obtain cow:calf ratios not population estimates they do show some population trends. Combining the total number of elk classified for the mining impacted sites and the control sites by year reals the following. Number of Elk Classified During Helicopter Surveys 1982 1983 1984 1985 1986 1987 3 Mining Impacted Sites 456 626 447 368 654 626 3 Control Sites 347 477 453 319 639 490