2016-12-23_PERMIT FILE - C1982056A (8)

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have been where major highways crossed traditional migration routes (e.g., Interstate 70 near Rifle) or where roads run through mule deer winter concentration areas or critical winter range (e.g., the Piceance Creek Road through .Piceance Basin or the Parachute Creek Road from Parachute (Grand Valley) to the Union Oil Shale Plant). The potential for big game road -kills associated with the Foidel Creek Mine would be expected to be much less than these situations due to differences in the total number of animals involved and in the locations of roads with respect to critical winter ranges. Several other factors tend to reduce the potential for road -kills associated with the Foidel Creek Mine operation. First and foremost, employee shift changes will not coincide with the time period when road -kill incidence is highest (sunset to four hours after). Secondly, the principal species of concern would be elk, which by virtue of its size and behavior appears to be less prone to vehicle collisions. And lastly, the posted speed limit for the haul road is 35 mph and will also be 35 mph for the Fish Creek Borehole /Shaft Area access road. These speed limits should significantly reduce the potential for big game /vehicle collisions. Aside from trying to assess the incidence of or potential for big game road - kills, the effectiveness of existing mass transit systems and the cost/benefit ratio of installing such a system should also be analyzed for determining the need for a mass transit system. There are few cases in the state where mass transit systems have been installed to these systems, in terms of reduced incidence of road - kills. Mass transit systems were installed for the Tract C -a and Tract C -b oil shale developments in Piceance Basin. The effectiveness of the mass transit system in reducing mule deer road -kills was not analyzed by Tract C -a (per. comm. Jack Clark, Tract C -a), but some preliminary analysis has been done by Tract C -b (per. comm. Tom Pysto, Occidental Oil Shale Company). Tract C -b has done some preliminary modeling using data collected for several years on variables such as weather conditions, number of road - killed deer, and traffic levels. The data collection period included the time span that their busing program was in operation. Their preliminary findings have, interestingly, indicated that the number of mule deer road -kills were relatively independent: of traffic levels and were more dependent on weather conditions and number of animals concentrated along the road (pers. comm. Tom Pysto, Occidental Oil Shale Company). In other words, they had a higher incidence of road - killed deer when snow levels forced deer to congregate along the road, and this increase occurred independently of traffic levels. These findings may apply only to the Piceance Creek Road, but they do pose some questions regarding the effectiveness of mass transit systems over other methods with respect to • reducing big -game road - kills. Information on cost/benefit analyses of mass transit systems used for reducing big -game road -kills is virtually nonexistent since data. on their effectiveness are not readily available. Reed et al. (1982) used information on vehicle repair costs, economic value of deer, the costs of establishment and maintenance of fencing, and incidence of road - killed mule deer (before and after fencing) to compute a cost - benefit ratio for deer -proof fencing installed along Interstate 70. In their paper, Reed et al. stressed that this type of analysis can only be conducted if before - and -after big -game mortality figures are available for the mitigation technique in question. They also stressed that the decision -maker should be especially cognizant of pre- existing mortality figures before expensive mitigation techniques are employed. In summary, factors such as posted speed limits and timing of peak traffic should considerably reduce the potential for big - game /vehicle collisions. TCC will employ these measures as part of its procedures to minimize road - kills. Since data on baseline levels and projected increases for road -kills are generally lacking, there is a need to have road -kill figures available in order to identify problem areas or address the need or effectiveness of mitigation measures. It is premature at this time to make a decision regarding the need for a mass transit system for the Foidel Creek Mine. It may be advisable to monitor big -game road -kills along the access and haul roads to determine if there is a need for a mass transit system or other mitigative measures. Details of a possible big -game road -kill monitoring program are provided in the response to Rule 2.05.6(2). Development of Road.-Kill Monitoring Plan for County Haulroad One concern expressed by the wildlife regulatory agencies was that increased haul truck traffic, from the main portal along the Country haulroad to the Fish Creek Tipple, may increase the incidence of mule deer or elk road- • kills. The literature was reviewed to evaluate the feasibility of various monitoring programs. The monitoring program was developed in consultation with the CDOW so that the most feasible and cost - effective program could be formulated. RN08 -05 2.04 -70 03/12/10