2025-10-07_PERMIT FILE - C1980007 (4)

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The reports completed by Adam Petry Western Biology, LLC in 2019, 2023, and 2024 summarize, “Routine road maintenance was performed in Spring 2024 and the SS1, E2-09, and E2-13 pads and access roads were reclaimed in Fall 2024. No activities led to major landscape- level destruction, modification, or curtailment of suitable habitat for listed species, nor did any reclamation activities destroy or adversely modify the overall size, extent, or quality of any potentially listed-species populations or habitats in the Project Area or known active nests protected under the ESA, MBTA, or BGEPA. Based on historical and current survey results for the Project Area, maintenance activities in 2024 did not contribute to the loss of viability of any federally threatened, endangered, proposed, or sensitive plant and animal species or contribute to a trend towards Federal listing under the Endangered Species Act.” The report further states that “In 2024, Western Biology and the U.S. Forest Service (USFS) Paonia Ranger District conducted separate but concurrent survey efforts for the butterfly’s host plant – the bog violet (Viola nephrophylla) – which primarily grows in open wet meadows between 5,200 to 8,300 feet. No bog violets were confirmed either in the Sunset Trail Mining Area (Western Biology) or Dry Fork Grazing Allotment (USFS) during limited surveys” indicating that no confirmed host plants for the Silverspot Butterfly have been confirmed in the permit area to date. Western Biology, LLC is continuing surveys in the area for 2025. The reports completed by Michael Ward Outdoors and Monarch and Associates summarize, “No Federally-listed or State-listed Threatened and Endangered Species that could potentially occur within this portion of the Gunnison National Forest would be adversely impacted by construction of drill site locations and access roads because little or no suitable habitat would be affected. The only management indicator species observed were red-napped sapsuckers and elk. Sapsuckers were commonly observed in aspen stands and elk, or evidence of their presence, was always observed throughout the project area.” The report further concludes, “There are no Endangered or Threatened plant species known to occur in the project area.” LAND USE The present land use of the proposed methane drainage project area consists of domestic grazing, wildlife habitat, watershed, recreational lands, and big game hunting. No agricultural areas exist within the area. Coal mining has a long history in the North Fork Valley. Mountain Coal Company has operated the West Elk Mine as a viable mine since 1981 with an underground longwall in operation since 1992. Currently there is one active mine in the North Fork Valley; the West Elk Mine. Other mines that have existed in the valley include Bear Mine Nos. 1, 2, and 3; Oliver Mine Nos. 1 and 2; Hawks Nest Mine; the Somerset Mine; the Edwards Mine; the Elk Creek Mine operated by Oxbow Mining, Inc.; and the Bowie No. 1 and No. 2 Mines operated by Bowie Resources Limited. CULTURAL RESOURCES Previous Class III cultural inventories were conducted in the methane project area. The results of the surveys were negative and were submitted to the USFS. Cultural inventories have been conducted on the adjoining Ravens Gulch Exploration Area (COC-60622; expired). The list of studies includes six Class III surveys and two Class II surveys (Metcalf Archeological Consultants,