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In regards to potential impacts to Federally listed fishes, it is unclear whether the proposed project will involve additional water depletion from the Colorado River system. Although the proposed activity is not directly located in areas currently occupied by any of the above fishes, the Fish and Wildlife Service believes that any depletion of water from the Upper Colorado River Basin (UCRB) may have negative impacts on these endangered fishes. Simply put, water that leaves the UCRB before reaching habitat areas for listed fishes may actually cause cumulative deterioration of downstream, occupied habitat. In this way, depletions are thought to contribute to the fishes' decine. Consequently, OSM should determine whether a net depletion to the UCRB will occur by Seneca II W project development. In addition, whooping cranes have occasionally been observed with the sandhill cranes discussed in the mine plan. OSM should evaluate the impact that may occur to whooping cranes as a result of the construction and operation of the Seneca II mine access road. In summary, should a net depletion of water from the UCRB be confirmed, or impacts to whooping cranes be identified, a "may affect" determination would be expected and OSM should request formal Section 7 consultation from: Field Supervisor, Endangered Species Office, 1700 South 1745 West, Salt Lake City, Utah, 84104-5110. At this time OSM should provide our Endangered Species Office with a copy of the biological assessment and any other relevant information that assisted it in reaching its conclusion. Mivratory Birds: Due to increasing interest in determining impacts to passerine birds, particularly species with specific habitat requirements, we request that Peabody include annual or semi-annual avian monitoring studies as part of their Wildlife Monitoring program (Page 14-12). Such studies should utilize currently accepted methodology and should be designed in consultation with USFWS, CDOW, and BLM. BiQ Game: Because coal will be transported by truck and because an increase in traffic volume can be expected, big game/vehicle collisions should also be monitored as part of the wildlife monitoring program. If the number of big game road kills increase substantially, Peabody must consult with CDOW, U5FWS and BLM to develop appropriate means of reducing big game losses. Post-Mining Land Use/Reclamation: Although we believe that much of Peabody's reclamation plan will benefit wildlife, Peabody did not clearly justify the emphasis of livestock grazing reclamation over reclamation of wildlife habitats. We believe that post-mining wildlife use on the site is at least as important as livestock production and therefore request that reclamation efforts be designed to provide equal consideration for wildlife values. In our opinion, to do otherwise