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a, The Trapper Mine permit currently does not contain.a study of non-threatened or non-endan- <br />gered. fish species, or their habitats, for the area within the permit boundary. This is: accept-. <br />able az this time, as there are no lakes or perennial streams within the current permit area. <br />Please revise:the permit to document this.. <br />Fish and wildlife use and habitats are discussed in Permit Section 1.4, Appendix E (Fish and <br />Wildlife) and Permit maps MI9 through M26. We feel the information presented is an accurate <br />presentation of the wildltfe resources within and adjacent to Trapper Mine. The species of <br />importance and areas of concern were derived from consultation with the Division of Wildltje <br />and CDMG (please see Appendix E). <br />We feel our baseline wildlife information and hydrologic information is sufficient background to <br />address the issue ofnon-threatened and non-endangered fish species within the permit area. No <br />additional work should be required. <br />b. The peintit also does not contain a study of non-threatened, ticju-endangered fish: species and <br />their habitats for .any area adjacent to the mine permit boundary. As portions of both the. <br />Yampa River and the. Williams Fork come.to within.one mile of.the:tnine's permit. boundary; <br />the Division requests Trapper Mining Inc. begin discussions..with the Division regarding such <br />a fish/fish habitat study.. <br />With regard to this fish study, Rules 2.04.11(1) and 2.04.11(3) require designazing those areas <br />to which: the study would apply, and.the level of detail of.the study. With regard to the areas <br />of the study, the Division believes there are three areas that should be considered... All of these <br />receive some element of treated disturbed azea runoff from the mine..All also may be.affected <br />by.the mine's practice of retaining water on the mine site in livestock and sedimentponds.: <br />'Yhe first of these areas would be a length of the Yampa River iietween the confluence of the <br />outlet of Deep Cut Ditch and the river tb a pointon the river somewhere in the north half.of <br />Section 30, T6N, R41W. The Second of these study areas would be the length of the Williams <br />Fork between the confluence of [he Fork and Deal Gulch to a point on the Fork somewhere in <br />the north half of Section 6, TSN, R91W. The third study area would encompass those sections <br />of the Yampa River between the north half of 5ection30, T65N, R91W and the north half of <br />Section.36, T6N; R92W, and:of the Williams Fork between the north half of Section 6, TSN, <br />R91W and the Williams Fork/Yatripa River confluence. The Division recommends this third <br />be considered an area separate from the first two as this third aiea is one that receives surface <br />water and discharged mine water from Cyprus-Empire's operations.in Sections 30.and 31 of <br />T6N: R91W: <br />Finally, the fsh and.fish habitats in these three areas.sliould be compared to areas l) on .the <br />Yampa River above the Deep Cut Dttch/Yampa.River confluence, 2) on the Williams Fork <br />above the Deal Gulch/Williams Fork confluence; and 3) on the Yampa River below..the point <br />where the Yampa River flows out of Section 356 of T6N, R92W: <br />The effects of Trapper Mine on the Yampa and Williams Fork Rivers are negligible. The closest <br />discharge to Yampa River is our West Buzzard (NPDES 006) drainage which is over 4000 feet <br />east. This drainage has sediment control structures that have a coca[ storage capacity of 10.1 <br />acre/feet of water. Our records indicate this drainage normally discharges less than two months <br />a year, only during the spring, usually at less than 10 gpm. The discharge, in most cases. does <br />