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<br />Although suggestions are being provided to you on potential <br />methods of determining wildlife impacts and wildlife mitigation, <br />it should be noted that it is Getty/CYCC's ultimate responsibi- <br />lity to prepare a committed wildlife management/mitigation plan. <br />Our agency and CDOW will assist BLM, MLRB, and OSM in determining <br />the merit of pour company's wildlife mitigation proposals. <br />Further thoughts on impact assessment and mitigation techniques <br />are as follows: <br />Habitat value loss - We have proposed two basic <br />methods of assessing_ relative-habitat value of the Little <br />Middle Creek Tract. One method, a species specific <br />habitat analysis (e.a. HEP), involves assessment of area <br />importance to key, indicator species of wildlife. As such, <br />known measurable factors of habitat suitability for given <br />species would be compared with habitat conditions on the <br />Little Middle Creek Tract. '' <br />The other method is to determine (bp mapping) refined <br />vegetative cover types on the Little Middle Creek tract and <br />compare relative availability of those vegetation types within <br />the local area (within, for example, a 3 to 5 mile radius of the <br />proposed lease). Comparative importance of habitats (cover <br />types) to wildlife, both within the tract and control areas. <br />could be evaluated through intensive wildlife baseline <br />inventories of pre-determined study plots. Study plots of <br />uniform size would be randomly selected but stratified by cover <br />type. Within each study plot avian and mammalian species <br />composition and abundance could be evaluated by standardized <br />methodology. Thus, the relative importance of the Little Middle <br />Creek Tract to the total wildlife community could be more <br />realistically depicted. <br />Both methods of assessment would require at least one full <br />field season and cannot be completed in a time frame that <br />would permit proper review and mitigation development prior <br />to your proposed construction schedule. Our concern is that <br />mining of the Little Middle Creek Tract will result in <br />permanent Loss of what we believe are structurally diverse <br />and extremely valuable wildlife habitats. You and Kent have <br />stated your interest in pursuing experimental reclamation <br />practices that you feel have high potential for re- <br />establishing habitat structures and densities similar to <br />those that now exist. Obviously, we would favor such <br />habitat reclamation if no long-term net loss of relative <br />habitat value occurs. Indeed, we would prefer such <br />mitigation over other alternatives. Therefore, we agree <br />that the feasibility of aspen revegetation should be <br />thoroughly examined and perhaps given greatest priority. <br />