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acres of riparian habitat and 32 acres of upland wildlife habitat. Please refer to Map 15 <br />(attached separately). <br />In short, the reclamation plan calls for the revegetation of three types of post- mining <br />habitats; rangeland, upland wildlife habitat, and riparian wildlife habitat. The <br />reclamation seed mix for all areas is the same, and includes a native mix of grasses and <br />forbs and also includes the shrubs rubber rabbit brush and woods rose. For the upland <br />wildlife habitat, in addition to the seed mix, the revegetation plan currently calls for 1500 <br />tublings per acre to be planted, 250 each of true mountain mahogany, common <br />snowberry, skunk brush sumac, ponderosa pine, pinion pine, and juniper. The planting <br />density would be a tubling on about 5.5 foot centers over the entire 32 acres. This results <br />in a revegetation cost of about $6700 per acre including a 50% failure rate, or around <br />$216,000.00. For the riparian area, 1,742 tubling shrubs consisting of cottonwoods and <br />willow would be planted on 5 foot centers over 11 acres for a revegetation cost of <br />$87,000.00 or about $7,900.00 per acre. <br />This revegetation plan was developed in the mid 1980's by previous operators of the <br />mine. Since that time, much has been learned regarding the importance of shrubs for <br />wildlife habitat as well as improved techniques for re- establishing shrubs on reclaimed <br />areas. NECC believes that the current plan is to some extent, unnecessary and has little <br />chance of success for the following reasons. <br />1. The relatively small size and lateral extent of the disturbance minimizes the need <br />for shrubs with regard to benefits for wildlife needs. <br />The currently approved disturbance can be generally described as about 200 acres in a <br />long, narrow band stretching along 2 miles either side of the Purgatoire River. The <br />larger area of the RDA is located north of the river and Highway 12, with another <br />narrow strip of land to the south consisting of the access road and water tank bench <br />located in dense timber of the Bosque del Oso SWA. The mine disturbance and <br />eventual reclaimed area will create in excess of 4 miles of edge, resulting in <br />reclaimed grassland bordering undisturbed wooded areas. These edge areas are key <br />areas of wildlife usage. Turkeys, mule deer, and elk are considered edge species <br />(Hoover and Wills 1984). <br />2. The currently identified riparian areas are either already invaded with riparian <br />shrub species or were not riparian areas in the pre- mining condition. <br />Ponds 6 and 7 are located immediately east of the prep plant on a terrace bench <br />immediately adjacent to the river. The river in this area is flanked on both sides with <br />heavy willow growth and downstream, an extensive area of the river bottom is nearly <br />entirely covered with willows due to beaver dams and the subsequent natural wetland <br />development. The land area occupied by pond 6 and pond 7 is no more of a riparian <br />area than areas adjacent to the river east of this location that will be reclaimed to a <br />rangeland use. The prep plant area was created by moving the river slightly to the <br />north (under a permitted action through DRMS) and the new river channel was <br />