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August 9, 2011 <br />To: Tom Kaldenbach <br />From: Janet Bi <br />Re: West Elk T <br />Memo <br />and Wildlife comments <br />On May 23, 201 , 1 '. S, Mountain Coal, and Mike Savage, of Savage & Savage <br />Environmental met to discuss permitting of the Historic Reference Study Area for reclamation <br />success comparison. The following paragraph summarizes the discussion regarding potential <br />changes /clarification to the woody plant density reclamation success standard. <br />MCC and the Division also discussed the applicability of the currently approved woody <br />plant density standard of 1000 stems per acre in shrub clusters, and of Mountain Coal's <br />thoughts on revising this standard. The Division suggested MCC consult with US Forest <br />Service and CDOW regarding acceptable woody stem densities prior to submittal of a <br />revision. The Division also suggested that MCC research what the currently approved <br />woody stem density standards are for the other coal mines in the North Fork of the <br />Gunnison River area. MCC agreed this would be a beneficial approach. <br />Mountain Coal submitted TR125 on July 15, 2011, requesting approval of the HSRA for <br />reclamation success determination. On July 29, 2011, the Division received a letter from <br />Colorado Parks and Wildlife (formerly Colorado Division of Wildlife) commenting on the <br />proposed revision. The Parks and Wildlife (P &W) letter states that, "MCC is specifically <br />seeking a modification of our [CDOW] December 10, 1981 Memorandum (MEMO) to DRMS <br />that sets the shrub density standard for reclamation at 1000 stems /acre." <br />The July 29, 2011 P &W letter continues on to note that establishment of mountain shrub and <br />sagebrush communities is valuable to Colorado wildlife throughout the year, especially winter <br />mule deer and elk populations. P &W contends that a ratio of 60:40 forage to cover ratio should <br />be maintained for optimal winter elk habitat. The P &W letter does not define how this ratio is <br />measured. The DRMS uses percent vegetative cover as a portion of total cover an a site, and <br />uses pounds of live vegetative biomass per acre for the forage or productivity measure. The <br />Division is unsure how P &W relates biomass (forage) to cover. However, P &W considers that a <br />modification of the required shrub standard needs to be evaluated on a site -by -site basis. If the <br />60:40 forage to cover ratio is being met within the mine permit boundary, P &W supports <br />modifying the recommended shrub density standard within the West Elk permit boundary. P &W <br />also recognizes that other federal agencies have inputs on the land use and management of the <br />area, and recommends coordination with the US Forest Service and US Bureau of Land <br />Management. <br />Has Mountain Coal Company provided statement from USFS and BLM regarding elimination of <br />a woody stem success requirement on the West Elk mine permit area? <br />