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y ' STATE OF COLORADO • Roy Romer, Governor DEPARTMENT OF NATURAL RESOURCES DIVISION OF WILDLIFE James B. Ruch, Director 8080 Broadway Denver, Colorado 80218 Telephone: (303) 297-1192 Mr:; Gregg Squire Colorado Mined Land Reclamation Division 423 Centennial Building 1313 Sherman St. Denver, CO 80203 Dear Gregg: • III IIIIIIIIIIIII III 999 REFER TO: N. Thompson Hobbs Wildlife Researcher Research Center 317 W. Prospect Ft. Collins, CO 80526 May 14, 1987 MAY 181987 MINED LAND RECLAMATION DIVISION I reviewed the Trapper P1ine shrub density standards. I believe their approach is basically sound. However, the standards are flawed by the assumption that target carrying capacity for reclaimed land depends on levels of "historic" use (I use quotes because seven years is not exactly history:). Their approach assumes that the value of habitat is measured solely by the number of animals that happen to be using it now or in the recent past. Let me propose an analogy to illustrate the pro- blem with this assumption. A rancher owns 10,000 acres. Is the value of his land determined by the number of cows he currently owns or the potential of the land to support cows? Any number of things could affect his current herd size (market prices, subsidies, etc.), but the value of his land is determined by the AUM's of forage produced, not by the number of animals he currently owns or the number he owned dur- ing the last seven years, for that matter. As one rancher told me once, "I sell crass. The cows just help me market it." The point is that habitat, be it for cattle or for elk, has a potential to support animals that is independent of the number of animals currently using it. Any reduction in that potential represents habitat loss. Thus, I believe that habitat impacted by Trapper should be restored to its full potential to support elk during winter. As I suggested to Bruce Humphries earlier, this target should be a topic of negotiation, but should probably fall in the range of 15-30 elk/sq. mi. Given this objective, the shrub standards proposed should be increased by a factor of about 2-4. This is the overriding issue. There are also minor technical points about which one could quibble, but they are small relative to the question of restoring habitat potential. I hope this is helpful. I also enclosed an example carrying capacity calculation. Sincerely, ~~ xc: Gill/Morris/Lines N. Thompson Hobbs Wildlife Researcher DEPARTMENT OF NATURAL RESOURCES, Clyde O. Martz, Executive Director • WILDLIFE COMMISSION, Rebecca L. Frank, Chairman George VanDenBerg, Vice Chairman • Roberf L Freidenberger, Secretary • Eldon W. Cooper, Member • William R. Hegberg, Member Dennis Luttrell, Member . Gene B. Peterson, Member . Larry M. Wright, Member