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:{ y ~~ ~~~,~ RECEIVED Colorado Yampa Coal I 29588 Routt County Road #27, Oak Creek, CO 80467 • Tele~~ ~(~i~~~3800 MI ~ o OeNo oCC~M~iIIAaNiau calf December 19, 1984 Mr. L. Ronel Finley Energy Project Leader U.S. Fish & Wildlife Service 730 Simms Street, Room 292 Golden, CO 80401 RE: Wildlife Mitigation for Little Middle Creek Tract Dear Mr. Finley: Thank you for your letter of November 19 to Terrell Johnson which was received on December 10. We appreciate your willingness to meet our schedule for formulating an approved wildlife mitigation plan. We also appreciate your suggestions to the extent they have named the issues regarding the mining of the Little Middle Creek Tract. Attached to this letter is a position paper in response to your letter which briefly describes CYCC's position concerning your suggestions and which proposes a mitigation plan in conceptual form. In summary, we agree with your analysis on habitat value loss, elk studies, raptors, and we agree in general with all of your points expressed under mitigation (except No. 4), pending the outcome of new raptor surveys, although we believe that some of your suggestions as to livestock grazing control and off-site enhancement are unworkable. The attached position paper documents the view of CYCC that all pertinent data which you would require concerning habitat value loss and elk studies are currently available. We, therefore, believe that an approved mitigation plan can be formulated from the existing data without the need for an additional field season of data co]lection. To the extent that you have any additional concerns following review of the plan, you may specifically identify those concerns and any appropriate data could be gathered in the 1985 season prior to final permit approval. The attached paper also describes CYCC's position relative to any additional sensitive species and to suggestions on livestock grazing and off- site enhancement. Briefly, CYCC does not believe there are any additional sensitive species, and requests prompt identification of any which you may consider as such. CYCC believes that a mitigation plan can be approved now which could include consideration for any sensitive species identified in the 1985 season. CYCC further believes that there are much more practical and effective ways of enhancement than the grazing control and off-site methods you suggested.