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<br /> <br />In 1980, during the technical review of the Eckman Park Permit Application <br />which contained approximately 60 percent of area of the Little Middle Creek <br />Tract, the Office of Surface Mining, in their environmental assessment (page 17) <br />concluded: "If proposed reclamation and mitigation methods are employed, most <br />of the impacts to wildlife and their habitats should be short term...". On page <br />15, this document stated that the OSm staff believed that reestablishment of <br />shrub species onto the reclaimed aspen range site would be improved, due to <br />enhanced growth of deep rooted shrub species and the removal of the existent <br />sandstone bedrock. <br />The Craig District BLM Office in its Little Middle Creek Tract Site <br />Specific Analysis issued in November 1982, stated on page 85: "Eventually all <br />lands should be returned to pre-mining capacities with no long term (beyond <br />reclamation) impairment of productivity." The document also states on page 35 <br />that "after reclamation of the disturbed areas, initial productivity would be <br />expected to return.... It is estimated that productivity would reach former <br />levels within 10 years following reclamation activities." This document also <br />stated on pages 34-35: "Reclamation potential for this area would be good, as <br />evidenced by reclamation efforts of Colorado Yampa Coal Company on their <br />adjacent mines. This operator and its predecessor, Energy Fuels Corporation, <br />have reclaimed approximately 1,000 acres of similar soils and topography with <br />very good success." In the Little Middle Creek Tract Profile Report page 11) <br />the BLM stated that "successful reclamation is assumed to be 10 years after the <br />last cultural practice." In short, we believe that your statements in your most <br />recent letter regarding an irretrievable commitment and permanent loss of <br />wildlife habitat are contradictory to previous policy and findings regarding the <br />impacts of surface coal mining on wildlife and to any documentation on wildlife <br />and surface mining of which we have knowledge. <br />4 <br />;~~ .. ,~" _` .,~ .",max ~ '~, ! <br />