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. ~~ n SENT OF TN OWY ~ .~^ Pa=m N 9 ~ a ~9 M9RCH 3 ~sr. IN REPLY REFER TO ES/CO:CDMG MS 65412 GJ United States Department of the Interior FISH AND WILDLIFE SERVICE Ecologinl Swica IXrarern Colorado Office 7Gd Horizon Drive, South Mnea A Grand Junction, Colorado e150C-3946 RECEIVEp MAY 2 1994 Apri 1 29, 1994 Darisicn et rnrnerais ~ ~E~oicny Barbara Pavlik, Environmental Protection Specialist Colorado Division of Mineral and Geology 1313 Sherman St., Room 215 Denver, Colorado 80203 Subject: North Thompson Creek Mine (Permit No. C-81-025) Technical Revision No. 16 (Species Diversity Standard), Garfield and Pitkin Counties Dear Ms. Pavlik: The Fish and Wildlife Service (Service) has reviewed the proposed technical revision. The Service recommends that plant diversity, density, and composition mimic as closely as possible the vegetational structure that existed prior to mining. If there was a certain composition and density of gambel's oak ( uercus aambellii) prior to mining then reclamation efforts should approximate those previous estimates. The argument for changing the standard implies that since gambel's oak constituted 44.5% of species composition that the herbaceous component should also be 44.59'0. This argument is illogical. The Colorado Division of Minerals and Geology (CDMG) has apparently set 1500 stems/acre of gambel's oak as a minimum. Hayes Environmental Services said that there were actually 7801 stems/acre. The Service understands that a minimum required stem density must be set but recommends that a higher stem density be planted to approximate the density prior to mining. The stem density should be consistent with established articles documenting appropriate stem densities (and watering rates, etc.) which will provide the highest survival rate. CDMG has apparently set a minimum diversity standard of eight native plants to be reclaimed in the shrubland dry phase sites. The Service counts a minimum of 15 native species in this community. Reducing the diversity to six plants is not consistent with CDMG's standard and the Service recommends that more native species be planted to approximate the diversity prior to mining. The Service also recommends that CDMG consider replacing vegetational communities that make up a very small percentage of a mine site if that community is limited throughout its range. This will help ensure that the vegetational community and the wildlife that depend on it are not moved towards extinction. There are no federally threatened, endangered, or proposed species that impacted by the proposed change in reclamation standards or reclamation operations. However, we would like to bring to your attention species are candidates for official listing as threatened or endangered species may be which