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Dan Mathews <br />• Page 2 <br />December 10, 1981 <br />ti <br />without the appropriate vegetation, wildlife would find little value <br />in their winter ranges. I have discussed the shrub density question <br />with members of our staff who are familiar with the subject. Our <br />recommendations are as follows: <br />1. We should describe shrub performance standards in terms other <br />than just stems per acre. We recommend an additional descrip- <br />tion by relative height classes as an indication of relative <br />age classes, thus the health of the reclaimed shrub community. <br />2. On areas identified by <br />Cr3hiral winTOr ran a, <br />shrub vegetation (oak, <br />mountain mahogany, et <br />minimum of 1,000 stems <br />(~mphoricarpos sp.), <br />this agency as big game winter range or <br />which are further described as mountain <br />serviceberry, bitterbrush, chokecherry, <br />.) the performance standard should be a <br />per acre, not counting snowberry . <br />3. The 1,000 stems per acre described in 112 above, should be clumped <br />on between.20 percent and 35 percent of the affected acreage, <br />preferably on site conditions most conducive to shrub survival. <br />This could be expressed as an interspersion or edge index as <br />Kent Crofts described in his letter and with which I agree. <br />• ? 4. In sagebrush habitats, the standard should be 2,000 stems per <br />` acre minimum, stem to be at least eight inches tall. <br />5. On areas described by this agency as sae rg ouse winter range, <br />the performance standard should be 3,000 stems per acre, a <br />stem to be at least 12 inches tall. This may require a change <br />in the grass-multch seeding regulation to reduce competition with <br />sagebrush. Perhaps we should discuss this. <br />6. Operators should be encouraged to create "topographic cover" by <br />increasing the relief of an area over premine conditions. Such <br />"roughening" of the land surface creates a diversity in micro- <br />habitats and does afford wildlife topographic cover while the <br />vegetation recovers from mining. <br />7. In areas where aspen and other tree species are the premine <br />vegetation, the performance standard should be 1,000 stems/acre <br />planted on between 25 and 50 percent of the affected area. <br />8. We recommend that coal mine operators be encouraged to transplant <br />mature shrub plants onto reclaimed areas. These will serve as a <br />seed source for further shrub establishment and as cover for <br />wildlife. <br />• <br />