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3. Current and historic reclaimed areas of the mine are heavily used by wildlife <br />without a dense stand of existing shrubs. <br />The importance of grassland to many wildlife species in the regional area cannot be <br />overstated. Deer, elk, turkey, bears and many small game species heavily utilize any <br />grassland in the greater area, primarily because of the dearth of grassland in the <br />surrounding area. Deer, elk, and bears use grassland areas heavily for feeding areas <br />beginning in early spring through late fall. In the case of the New Elk mine, the <br />location of the reclaimed grassland flanking the heavily forested and wooded area and <br />also the proximity of these reclaimed lands immediately adjacent to the Purgatoire <br />River, results in year -round use of the grassland for grazing, feeding, and loafing as <br />wildlife species travel to and from the river to drink. The general river bottom area is <br />also used as a resting area as wildlife move in a north -south direction to other shrub - <br />dominated habitat types. As you know, game damage claims can and do occur, <br />primarily because of big game species seeking out privately owned grassland and hay <br />fields in the valley bottom. Of all habitat types within the greater mine area, <br />grassland is by far the smallest of any land cover type. <br />4. The current plan is not only cost prohibitive but is not technically sound. <br />The current plan includes no management practices to ensure successful shrub re- <br />establishment. The plan basically requires a shrub transplant for each 25 square feet <br />over 1.87 million square feet resulting in about 70,000 tublings transplanted. Shrubs <br />do poorly when competing directly with grasses and forbs. Small shrubs are heavily <br />grazed by wildlife and shrub mortality is high when grazing happens too soon <br />following transplant. Transplants typically need some sort of irrigation when young, <br />especially during dry years. Fencing or weed mats, or other practices are not <br />proposed or approved under the current plan. And for riparian areas, 1742 transplants <br />per acre are required and the current shrub standard for the riparian area is 1742 stems <br />per acre, which assumes 100% success of the transplants, which is clearly not <br />reasonable. <br />5. NECC completed <br />reclamation with <br />tublings included <br />shows limited <br />success. <br />Shown at right is the <br />lowest completed <br />bench outslope at the <br />RDA was reclaimed <br />and reseeded, <br />including tubling <br />plantings in 1988 as <br />required for the <br />