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• s <br />Mr. Rick Mills - 2 - January 14, 1986 <br />as sagebrush or mountain shrub vegetation types, and rangeland rather than <br />pastureland was the designated land use. <br />I indicated that the vegetation and premine land use maps could probably be <br />revised through a technical revision to the permit. New information which is <br />the basis for the requested change should be included (if possible) or <br />referenced in the application. I suggested that post mine land use maps <br />should be included with the application, clearly delineating pastureland, <br />cropland and rangeland units. Postmine and premine acreages of the various <br />land use categories should be roughly equivalent to the premine acreages of <br />those land use types. The text should clarify how re vegetation success <br />determinations would be made for each land use type. <br />The second issue is CYCC's proposal to redesignate the major portion of the <br />affected land within the permit boundary as pastureland, rather than <br />rangeland. It is of concern that, under this proposal, application of <br />pastureland revegetation measures and success standards to expansive areas <br />which previously supported a mixture of sagebrush, mountain shrub and aspen <br />communities would reduce the overall habitat diversity and might negatively <br />impact important wildlife species. Wildlife habitat is an important land use <br />in the region. Classification of the majority of the permit area as <br />pastureland does constitute a land use change, given the premining use of the <br />interspersed aspen, shrub and pasture habitats by various wildlife species. <br />This issue is of greater significance and will need to be handled as a permit <br />revision due to the potential for significant alteration in permit <br />requirements, bonding level and the reclamation plan. <br />A specific request for an alternative land use would need to be included in <br />the permit revision application and the request would have to address the <br />criteria of Rule 4.16.3. In addition, the application should address the <br />requirement of Rule 4.15.8 which states"...where the reclamation plan calls <br />for replacement of predominantly woody vegetation with predominantly <br />herbaceous vegetation, potential impacts on fish, wildlife and related <br />environmental values must be evaluated". <br />Haul Road Retention <br />You indicated a desire on the part of CYCC to retain the haul road for the <br />postmine land use. Such an approval could be obtained through a technical <br />revision if the demonstrations as required by Rule 4.03 can be made and the <br />road is shown to be necessary for the postmine land use. Road width would <br />need to be appropriate for the intended use (i. e. a 60' wide road would not be <br />appropriate for cattle trailers and pickup trucks). It would seem logical to <br />include the road retention proposal with either the landuse clarification <br />technical revision or the landuse change permit revision, depending on your <br />needs. <br />1985 Annual Reclamation Report <br />As with the annual hydrology report, you indicated that submittal would be <br />somewhat delayed as compared to previous years, due to the incorporation of <br />vegetation data in this years report and computer problems you were <br />experiencing in that regard. In addition to the reclamation maps, acreage and <br />seedmix tables and text included in past years reports, postmine topographic <br />