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. _, <br />o.,[: <br />R[/LV TO <br />•TTN 01: <br />[us~[cr, <br />To. <br />III~IIIIII{IIIIIIII UNIILU SIAIES GUVCRfI~ NT <br />October R, ~R? 4 999 rri~morandum <br />Coal~Coordinator, U.S. Fish and Wildlife, Uenvrr, f.D <br />Review of 'gunner Canyon and '1cClane Canyon 'line Permit /Ipnlications, <br />Sheridan Enterprises Inc. <br />its, Shirley Lindsay, Office of Surface tilnlnq Reclamation and <br />Enforcement, Denver, CO <br />Please accept this letter as our official review of Sheridan <br />Enterprises permit applications for both the )1unger Canyon and <br />'1cC.lane Canyon test mine projects. 41e are combining our responses <br />on both applications since wildlife baseline data for each site <br />were collected simultaneously and are reported in a similar manner <br />Basically, we feel that the wildlife portions of the above annli- <br />cntions are suffir:irnt, Ilnwrvrr, wr dp h,ivr sn~rir cnnr.rrns flint. <br />either Caere not adequately addressed or, in fairn?ss to thr com- <br />- pony, cannot be adequl+tely addressed with baselinr. information <br />alone. To begin with, wildlife survey boundaries (in some cases <br />survey methods and survey intensities) were not well described <br />and complicate our ability to assess overall area importance <br />to wildlife. For example, 1t 1s difficult to determine how thor- <br />ough raptor inventories really were from the statement that "cliff <br />faces were carefully examined." The existence of a gold?n eagle <br />nest approximately one-half mile from the ''unaer Canyon permit <br />area (Sid, of SE!;, 52 g, T.7S, RIO2.1.1; RL!i unoubl i shed data) suggests <br />that raptor surveys were indeed incomplete. <br />Since both permit areas lie only about one mile apart, the potential <br />effects of the 'lunper Canyon and '1cf.lane fanyon mines on wildlife <br />cannot be viewed indrnrndently. Althnirgh surface drvrlnpm~nt <br />at both sites may be minimal, al] surface related activities <br />will occur within nr near bottomlands that are 11~e1y to be very <br />important to wintering drar and other wildlife. The applicant's <br />reference to habitat/ecotone imnprtance to mule deer is confusing <br />and further clouds this issue. Pellet group transects were used <br />as general indicators of deer habitat use; yet, the applicant <br />discounts the importance of pinyon-,iunioer/sagebrush-hottomland <br />ecotone because of the uncertainty of pellet group apes. 9ecause <br />no distinctions between pellet aces were made for other habitat <br />transects, judgement of habitat importance can only he based <br />on relative densities of all pellet groups found within each <br />transect. 'de feel that the data presented depict very high value <br />and use of the bottomland/woodland ectone by deer. r,onsequently, <br />we believe that protection of and enhancement for high use habitats <br />found within the proposed mine areas should he given hinh priority <br />throughout the mine develoor+ent process. <br />Buy U.S. Savings Bonds Regularly on the F~ayrrgll. SG v~i~Sg Plan QPTIONALfORM NO. <br />L IRCV. )-)[I <br />GSA IPMRI~I CI„I,G,-„I <br />f010.11i <br />MINED LAND RECLAMATION <br />Colo Dept. a1 ~latural Reso!Irces <br />