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02/28/97 18:51 $ ~ 002 • • The Fish and Wildlife Plan 2.05.6(2) provides an adequate overview of impacts associated with the proposed mining activities. However, rho plan fails to provide any significant mitigation measures to reduce the impacts on fish and wildlife resources. A mitigation plan addressing the sequencing of efforts (avoidance, rninimization, mitigation of toss) to address impacts is lacking and should be included before a proper analysis of mitigation can be made. As an example, the impact amlysis projects the direct loss of approximately 1,9?A linear feet of fish habitat, increased sedimentation and decreased water quality, but fails to address a sequencing of measures to reduce impacts. Of particular concern to CDOW is the reduction in water quality resulting fmm increases in sulfates, TDS, iron, and manganese. The analysis does not mention whether an increase in cadmium and zinc levels are anticipated. It is also tmcleaz whether a decrease iu pH is anticipated resulting in increased toxicity of metals to aquatic life. It should be noted, however, that specific mitigation plans regarding aquatic habitats and hydrologic balance were not provided for our review. These specific plans need to be provided for an adequate review of the proposed application. Nevertheless, the application does provide some steps for reductions in sediment loads through the use of best management practices including appropriate road alignment, revegetation and sediment control ponds. In addition, the plan calls for locating all roads, except for crossings, out of the "chatmel" of any stream. These sups should help mitigate some of Ule impacts on the aquatic environment The application outlines a post surface mine land use change from rangeland/wildlife to rangeland exclusively. As stated in the fish and wildlife plan 2.05.06(2), the "conversion of the surface mine area from an oak/pinyon to a grassland community type will decrease mule deer, elk, black beaz, and turkey usage of the area." This conversion of habitat type, in light of its importance as critical winter range ,will result in a significant [ong term negative impact on wildlife. The mitigation plan fails to address mitigation remedies for such habitat loss. In addition, the operation plan 2.05.2(5) states that there will be a shortage of topsoil and subsoil for complete redistribution on all disturbed areas. If this is the case, it seems unlikely that restoration of habitat with compazable productivity can be achieved. With such impacts noted, the prescribed seeding mixtures do provide an excellent mix of cool/warm season native grasses in association with beneficial browse species. However, the revegetation prescription fails to provide needed mitigation for the quality of habitat lost. With the corollary that CROW has not reviewed the aquatic/hydrologicbnlance mitigation plan, CROW encourages the adoption of the following mitigation recommendations: -Maintain current surface mine land use status of wildlife habitat/rangelandnnd reclaim disturbed areas using woody species that aze comparable in composition and quantity as the high quality habitat (oak/pinyon) being destroyed. Replace oak/pinyon habitat with oak/pinyon habitat. -Maintain appropriate setbacks on all riparian habitats and reclaim/enhance all disturbed riparian habitats. -Monitor mining impacts on flathead chub populations and provide annual status report to CDOW for review, -Survey/monitor areas of disturbance for nesting raptors and provide CDOW an annual report on nesting status and subsequent mitigations measures !f nescescary.