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III IIIIIIIIIIIII III ~ <br />• <br />Egviroqr»eqt, Iqc. <br />LARRY E. 0' BRIAN <br />PR!lID ENT <br />April 17, 1981 <br />9989 WEST 80TH AVENUE <br />ARVADA,COLORADO 80004 <br />303-423-7297 <br />Mr. James B. McArdle <br />Reclamation Specialist <br />Mined Land Reclamation APr; Z G ~JJ~ <br />1313 Sherman Street, Room 423 <br />Denver, CO 80203 MINED LEND (?E;;LNIdHIIvN <br />Colo. Dept. of Natural Resources <br />Dear Mr. McArdle, <br />Re P,4obile Premix Company - Loesch Pit <br />Wildlife Statement - P.4LR File #81-68 <br />This letter responds to the Wildlife Statement recently prepared <br />by Michael Grode of the Division of Wildlife, a copy of which is <br />enclosed. <br />The assessment of impact describes a potential resting area for <br />bald eagles attd several hunting perches (presumably north of the <br />river) which may get high use by wintering eagles. The assess- <br />ment further indicates that intense activity near the river may <br />cause the bald eagles to abandon the area. We believe this is <br />questionable because only one tree of any size exists along the <br />river in the area of concern to the Wildlife Division. In any <br />case, the operator can follow most of the recommendations <br />suggested for the welfare of the eagles. In fact, the operator <br />has already considered and planned implementation of the recom- <br />mendations. <br />The assessment of impact speaks to a "reduced present habitat <br />diversity and subsequently wildlife species diversity" if the <br />overflow/wetland complex is eliminated. This may be true dur- <br />ing the mining stages, but we believe that this is basically <br />an incorrect statement. The lake area created, with its accom- <br />panying wetland condition, should improve the area for wildlife <br />and in fact create additional habitat for species not now in <br />residence. <br />The Wildlife Statement lists eight recommendations. We respond <br />to each, restating the recommendation and indicating the <br />operator's reply thereto. <br />1. "The pit should be mined and reclaimed in phases with <br />several small pits rather than a single large pit." Mining in <br />this manner minimizes the recovery of resource in place by <br />amounts varying from 25% to 40% of the reserve. Certainly this <br />is not conservation of the resource. A synthetic reduction of <br />recovery of material by poor mining practices will encourage the <br />disturbance of other areas that may not have been needed if <br />extraction had been maximized. Over an extended period of time, <br />