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02/28/97 18:51 $ • • X002 The Fish and Wildlife Plan 2.05.6(2) provides an adequate overview of impacts associated with the proposed mining activities. However, the plan falls to provide any significant mitigation moasures to reduce the impacts oa fish and wildlife resources. A mitigation plan addressing the sequencing of efforts (avoidance, minimization, mitigation of loss) to address impacts i5 lacking and should be iaduded before a proper analysis of mitigation can be mach As an example, the impact analysis projects the direct loss of approximately 1,97A linear feet of fish habitat, increased sedimentation and decreased water quality, but fails [o address a sequencing of measures to reduce impacts Of particular concern to CROW is the reduction in water quality resulting from 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 unclear whether a decrease in 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 rue of best management practices including appropriate road alignment, revegetation and sediment control ponds hl addition, the plan rolls for locating all roads, except for crossings, out of the "charmel" of any stream. These steps should help mitigate some of the impacts on the aquatic eavironmeot The application outlines a post surface mine land ttse 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 azea room an oaklpinyon to a grassland community type will decrease mule deer, elk, black bear, 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 long urm 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 azeas.l£ this is the case, it seems tmlikely that restoration of habitat with comparable 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 revegcta[ion prescription fails to provide needed mitigation for dre quality of habitat lost. With the wrollary that CDOW has not reviewed the aquaticJftydrologichalance mitigation plan, CROW encourages the adoption of the following mitigation recommendations: -Maintain current surface mine land use status of wildlife habitat/rangeland and 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 disturhed riparian habitats. -Monitor mining impacts on flathead chub populations and provide annual status report to CDOW for review. -Survey/monitor areas oL disturbance for nesting raptors and provide CDOW an annual report on nesting status and subsequent mitigations measures if nesceccary.