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:: C~ 3/7/91 DEPARTMENT OF NATURAL RESOURCES MINED LAND RECLAMATION DIVISION 215 CENTENNIAL BUILDING 1313 $HERMAN STREET DENVER, COLORADO 80203 ATTN: BRUCE HUMPHRIES RECEIVED MAR 13 1991 Mined Land Reclamation Division RE: SMITH FIT N0. ZO PERMIT N0. M-78-085 RESPONSE TO WILDLIFE STATEMENT ITEM #5 ADDITIONAL RECOMMENDATIONS) DEAR BRUCE: THIS IS A RESPONSE TO THE DOW $TATEMENT ATTACHED) CONCERNING THE ADDITIONAL RECOMMENDATIONS IN ITEM No. 5. I KNOW THAT THE ABOVE REFERENCED RECOMMENDATIONS ARE WELL INTENDED, HOWEVER, THEY RAISE ISSUES THAT HAVE ALREADY BEEN SETTLED IN OTHER PERMIT APPLICATIONS AND, MORE IMPORTANTLY, THEY ARE IN CONFLICT WITH THE BLM - LITTLE SNAKE RIVER RESOURCE AREA MINING MANAGEMENT POLICY. I WILL ADDRESS THE ISSUES IN ORDER: 1. THE STOCKPILES OF ROADBASE, OVERBURDEN, TOPSOIL AND PIT-RUN MATERIALS ARE TO BE STORED IN A MANNER CONSISTENT WITH THE RECLAMATION OF A LONG, NARROW GRAVEL PIT DESIGN TO CONSERVE ENERGY, TIME AND MONEY IN THE RECLAMATION PHASE OF THE OPERATION. 2. EXPERIENCE HAS TAUGHT US THAT A FENCED ENCLOSURE IN A BIG GAME RANGE IS IMPOSSIBLE TO MAINTAIN. DEER, ELK AND ANTELOPE ARE, COLLECTIVELY, THE MOST DESTRUCTIVE FORCE TO A FENCELINE OF ANY DIMENSION. NOT ONLY ARE THE GAME ANIMALS SUBJECT TO THE HORRORS OF DEATH FROM ENTANGLEMENT IN THE FENCE, BUT WHEN DOMESTIC LIVESTOCK ENTER AN ENCLOSURE BY WAY OF A DAMAGED FENCE, THE ENCLOSURE BECOMES A DEATH TRAP FOR THOSE ANIMALS THAT CANNOT FIND WATER, OR A WAY OUT. 3. CONTRARY TO POPULAR BELIEF, THE TOPSOIL, WHEN REPLACED, WILL SOON BE AWASH WITH NATIVE PLANT SPECIES GENERATED FROM SEEDS STORED IN THE TOPSOIL AND FROM THE SEEDS FROM ADJACENT LAND GROUND COVER. IT IS THE BLM PREFERENCE TO INTRODUCE NEW PLANT SPECIES FOR GROUND COVER REPLACEMENT ON THESE GRAVEL PITS. ~0 ~ ~~ ~ III IIIIIIIIIIIIIIII