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• ! - Mr. Humphries - 3 - February 9, 1987 The publication also states that control of big sagebrush sagebrush should not be encouraged on areas designated as habitat. These species do occur on the site. Nearly all Permit Area is classified as critical writer range for ell the area are also classified as critical winter range for area is classified as winter range for deer. and Wyoming big critical wildlife of the Trapper Mine c. Some portions of deer and most of the c. In Appendix E of the permit application it is suggested that establishing more forbs and grasses on the reclaimed areas which would be available for spring, summer, fall and occasional winter wildlife use, might improve the ability of wintering deer herds to survive on nearby critical range. On Range Site C (28.8 of the permit area), there were originally 17, 685 shrub stems per acre, MLRD has agreed that no shrubs need to be reestablished on this range site. Therefore, adequate forbs and grasses will be available without further reduction of the shrubs on Range Sites A and B. d. Appendix E also attempts to demonstrate that the definition of critical winter range for deer excludes almost all areas affected by Trapper Mine and, therefore, by inference that the Division should not consider critical deer winter range as part of the approved post-mining land use. The demonstration did show that the Upper Pyeatt and Johnson Gulches had enough snow cover from February through April to exclude deer use. However, these areas would be accessible to deer prior to February, and lower portions of the mine area would be accessible throughout the winter, Therefore, the mine area is critical to winter deer survival. It should be noted that all areas of the Trapper Mine not classified as critical winter range for deer are classified as deer winter range. Also, nearly all of the Trapper Kline area is also classified as critical winter elk range. e. Section 4.15.8(7) requires that where a reclamation plan calls for the replacement of predominantly woody vegetation with predominantly herbaceous vegetation, potential adverse impacts on fish, wildlife and related environmental volumes must be evaluated. Methods for substantial mitigation of these adverse impacts approved by the Division in consultation with the U.S. Fish and Wildlife Service and Colorado Division of Wildlife must be included in the reclamation plan pursuant to 4.18. MLRD has consulted with the Colorado Division of Wildlife. DOW's recommendation is that "In areas identified by this agency as big game winter range or critical winter range which are further described as mountain shrub vegetation (oak, serviceberry, bitterbrush, chokecherry, mountain mahogany, etc.) the performance standard should be minimum of 1,000 stems er acre, not counting snowberr (Symphoricarpus sp.) (memo from Al Whitaker; WiTaTiti=e Frog ram peciiiTis~Co orT a~O Division of Wildlife to Dan Mathews, MLRD December 10, 1981).