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<br />However, we also wish to point out that aspen reclamation <br />may not negate the need for other forms of mitigation. We <br />believe, therefore, that some means of comparative habitat <br />assessment is needed. In addition to providing an <br />evaluation of initial impact levels, we believe that <br />baseline data would be useful in measurina_ reclamation <br />success. <br />EIk - We have previously discussed our respective positions <br />on whether elk studies performed to date by your company <br />constitute mitigation for development of the Little Middle <br />Creek tract. We believe it was clearly CDOW's original intent to <br />determine the impacts of the CYCC mining operation on local elk <br />numbers. As such, it would be a serious loss of data not to <br />continue these studies as long as surface mine development is <br />continuing in the immediate area. Clearly, there is a possibility <br />that loss of a large portion of remaining habitats on CYCC <br />properties map affect the local elk herd. Indeed, the remaining <br />habitat (which may be of better quality than that which has <br />already been mined) may be extremely important to elk. <br />We suggest then that <br />the extent possible. <br />level of effort that <br />past. Continuity of <br />we believe that radi <br />maintained. <br />elk monitoring efforts be continued to <br />We would prefer to continue the same <br />has been put into elk studies in the <br />data should be preserved and therefore <br />o-telemetry efforts should be <br />Raptors - Raptor inventories discussed in our August <br />30th letter should be incorporated into any wildlife <br />baseline studies on the Little Middle Creek tract. As <br />discussed, we believe that rotor-wing and ground surveys are <br />needed to determine both relative abundance and species <br />composition of all raptors inhabiting the proposed mine <br />permit area and immediately adjacent lands. Monitoring <br />efforts should be intensive enough to achieve desired data <br />(one helicopter survey, two to three ground surveys per <br />pear) and should continue throughout years in which surface <br />disturbances occur. We believe that data obtained throvgh <br />such surveys will not only provide information on raptor <br />populations and responses to mine activities, but could <br />reveal habitat use data which may be important to <br />development of appropriate mitigation measures. <br />