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~n..~ October H, ~;~, III IIIIIIIIIIIIIIII rr~morandurn ~VIY TO •**~~~ Coal,Coordinator, ll.S. Fish and Wildlife, ')cover, f.q ~~o,E~. Review of ''unner Canyon and '1cClane Canyon 'line Permit /lnnlications, Sheridan Enterprises Inc. ~o, 11s. Shirley Lindsay, Dffice of Surface tiininq Reclamation and Enforcement, Denver, CD Please accent this letter as our official review of Sheridan Enterprises permit applications for both the 'lunger Canyon and '"cClane Canyon test mine projects. l•le are combining our resppnses on both applications since wildlife baseline data for each site were collected simultaneously and are reported in a similar manner. Rasically, we feel that the wildlife portions of the ahoy? annli- entions ore suffir.irnt., Ilnwevr.r, tvr do hove :rnnr• cnncrrnt thni. either were not adequatn.ly addressed nr, in fairness to thv com- ' nany, cannot be adequately addressed with baseline information alone. Tn begin with, tildlife survr'_v boundaries (in some cases survey methods and survey intensities) were not well descrihed and complicate our ahility to assess overall area imnnrtance to wildlife. For example, it is difficult to determine how thor- ough raptor inventories really were from the statement that "cliff faces were carefully examined." The existence of a golden eanle nest aoriroximately one-half mile from the ''unner Canyon permit area (SIT of SE!.;, S2Q, T7S, R1r17.11; RL'1 unpublished data) sugnests that raptor surveys were indeed incomplete. Since both permit areas lie only about one mile apart, the potential effects of the 'lunner Canyon and '1cf.lane Canyon mines on wildlife cannot be. viewed indenenrlently. 1lthnirnh surface, devnlnnrnnnt at both sites may be minimal, all surface related activities will occur within nr near bottnmlands that are likely to be very important to wlnterinn deer and other wildlife. The annlicant's reference to habitat/ecotpne imnnrtance to mule deer is confusing and further clouds this issue. Pellet group transects were used as general indicators of deer habitat use; yet, the annlicant discounts the importance of pinyon-,iunioer/sagehrush-hottomland . ecotone because of the uncertainty of pellet group goes. because no distinctions between pellet goes riere made for other habitat transects, judgement of hahitat importance can only he based on relative densities of all pellet groups found within each transect. 'de feel that the data presented depict very high value and use of the hottomland/woodland ectone by deer. Cons~•quently, we believe that protection of and enhancement for• hioh use habitats found within the oronosed mine areas should he given hioh priority throuohout the mine develooi°,ent process. ~+ Buy U.S. Savings Bonds Regularly on flee (~ayyrgllrySavi~fg6 Plan orT~or~.~rogr,r+o. i o.w r rren ui vwi io~.n , win-,~e h4INLD L^,"JU RECLAMATION Cn!o Dept. pt ~'aiuai P,es;i~ rc?s