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Kent A. Gorham Page Four February 1, 1993 It should be noted that roughly the same number of hours were spent and the same areas surveyed each year. It is also interesting to note that control areas had to be larger and more time expended on control areas during surveys than on mining impacted sites. Even some of CDOW's personnel, i.e, Tom Lines, former Area Manager Craig/Meeker area, acknowledged that they were way off on their original predictions regarding elk being displaced by mined lands and instead are attracted to mined lands. He also stated that CRP lands are really drawing elk. Some have argued that the main reason elk select mined lands is because they are protected from hunting on these lands. Although we would acknowledge that hunting pressure can influence elk distribution, the data does not support the above contention. First, the greatest degree of reclamation use follows the hunting season. Second, evaluation of harvest data from CYCC's elk study show that elk which have summer home ranges on mining impacted areas were harvested at the same rate as those summering on control areas. Although the sample size of harvested radio collared elk is small, it is an indicator. Third, CYCC has allowed its employees to hunt portions of its reclaimed lands for more than 13 years. CYCC has also increased those areas available for hunting by employees (as safety requirements have allowed) and has implemented a handicapped hunter program in response to CDOW requests that more elk be harvested on the mine. Although accurate records of harvest on the mine have not always been kept the past year is probably typical. During 1992, a minimum of 32 elk were harvested on the mine site; the majority on reclamation. The harvest was also well distributed throughout the various seasons; three archery, seven first rifle season, ten second rifle season and twelve third rifle season. This does not indicate any abandonment by elk. CYCC believes that the site specific data clearly shows that there are no negative impacts to elk from the alternate land use proposal. Even if the overall amount of time elk use center areas of the reclamation is reduced this is obviously not a limiting factor. The indicators measured show overall positive rather than negative impacts to elk reproduction and population size. It is also worth noting, that although deer have not been studied on site near to the extent elk have, deer observations indicate that their population densities are high on reclaimed sites at CYCC. These observations indicate that deer use is even higher than elk use. This is not surprising in light of the findings of other studies. Lyon (1980) states "many mule deer ranges have no significant component of forest cover" and "Elk apparently have much higher security requirements than deer." My observations (as a Professional Certified Wildlife Biologist) during early morning, evening and even a few spotlight surveys during the night, although not quantified, show high numbers of deer on CYCC's reclamation during the summer and fall but very few in the winter. I would suggest that the reason Division personnel have not observed more