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as <br />~- t <br />15:05 $303 293 4611 <br />J \\ <br />' ~`C~ <br />~. ~ <br />\~~ti. <br />TO: <br />PROM: <br />RE: <br />WILDLIFL• N.W. <br />STATE OF COLORADO <br />DIVISION OF 4PILDLIFE <br />DATE: 1/10/95 <br />Bill Clark <br />Jim Haskins <br />Peabody Coal/Yoast Mine <br />I've reviewed the wildlife information contained in the Yoast Mine <br />plan submitted to MLB by Peabody Coal. A number of assumptions, <br />which I'm generally in agreement with, are made in regards to short <br />and/or long term impacts to wildlife. Following are some comments <br />about items I'm not entirely comfortable with. Non of my concerns <br />would qualify as fatal flaws in the collection or interpretation of <br />data that would affect the permitting process for this project. <br />3/ FISfi~H12 WzLALIPE Y <br />Page 3,: paragraph 1 - There is an insinuation that direct impacts <br />will be mitigated by incremental reclamation. This is misleading <br />since reclaimed areas will not approximate original conditions in <br />either vegetative or species composition or diversity <br />Page 3, paragraph 3 - The statement that no net loss of habitat <br />will occur is also misleading. A net loss of the pre-mining habitat <br />will certainly occur. The alteration to another habitat type might <br />have long term impiications to sensitive species like sharp-tailed <br />grouse. <br />Page 4, paragraph 4 - I find the statement that the loss of a lek <br />would not be a severe impact to be outrageous..We don't know what <br />mechanism drives lek selection but we do know that lek sites are <br />critical. This paragraph suggests that lek abandonment and <br />formation occurs on a regular basis and that the birds Will simply <br />move to a new location. If existing leks occur on the best sites <br />then relocation, for any reason, to less optimal sites could be <br />expected to result in long term negative effects. Suitable habitat <br />may appear to be in abundance in the Hayden area but we still <br />haven't solved the puzzle of why it's unoccupied. The birds sti21 <br />have the final word and we can't assume they'll just pick up, move <br />to a new area, and thrive. In the mines defense I will say that <br />there are instances of leks occurring adjacent to traveled roads <br />with few or no apparent negative effects. <br />f~002 <br />Page 5, paragraph 5 - With recent developments and concerns <br />regarding sage grouse i would elevate this specie to the same level <br />