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----- <br />~II ~I~I~~~I~~~~~I~~ <br />United States Department of the Interior <br />OFFICE OF SURFACE MINING <br />Reclamation and Enforcement <br />BROOKS TOWERS <br />1020 15TH STREET <br />DENVER, COLORADO 80202 <br />August 30, 1982 <br />MEMORANDUM <br />TO <br />FROM <br />Ben Young, TPO, Blue Ribbon Mine <br />Don Henne, Ecologist , <br />~.e~: <br />L or'~5~nally <br />S~ t'h~; tM, <br />/t~l~B2. 1 <br />~~~PY a;da`k <br />,fl,;l yon .,p. <br />t~, arm <br />SUBJECT: Review of Colorado MLRD's Decision & Compliance document for Blue <br />Ribbon, protection of fish & wildlife resources <br />Since this was actually a findings document it provided no discussion of ~ <br />important fish and wildlife issues or the applicant's proposed mitigation. <br />With regard to threatened and endangered species, the state's findings are ~ <br />meaningless to OSM unless they are supported by the USFWS. Fortunately, for <br />this mine we have a memo from USFWS summarizing a "no effect" conclusion on <br />these species. Since this action is a minor one, this memo is probably <br />sufficient for our findings. <br />Although I am no expert on the fine points of the OSM-Colorado Cooperative <br />Agreement, I don't believe this document meets the criteria for a technical <br />analysis. The Agreement states that MLRD must provide 05M with a complete <br />technical analysis to serve as the base for any EA or EIS. For fish & <br />wildlife resources, this document provides-r19 ''^~y After checking the <br />mine plan, I agree with most of the state's conclusions regarding protection <br />of fish & wildlife resources. Even moderate impacts are doubtful since the <br />very small amount of disturbance has already taken place. The company has <br />consulted with responsible state and federal wildlife agencies and has <br />commited to several mitigation measures. These include: <br />1. Limiting activity during the sensitive deer and elk wintering period; <br />2. Employee orientation to minimize shooting of wildlife on the permit area; <br />3. Revegetation with plants useful to wildlife, and; <br />4. A promise to contact and work with CDOW if any new problems arise. <br />The only concern I have is for the safety of raptors around the power poles <br />and any electric transmission facilities. I could find nothin in the MRP or <br />deci ument that addressed this erforman n ess ne ~ <br />a his rformance standard has been met or ~) <br />dg~ ~~* _^^~~~ it must be stiQulated <br />