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<br /> <br />HABITAT VALUE LOSS <br />We concur with the concern over quantifying the wildlife value of the area <br />to be disturbed. We obviously differ in how we would approach the situation. <br />Our position is that virtually all of the data deficiencies identified by USFWS <br />have already been addressed and the need for additional baseline data to <br />characterize the existent habitat is unnecessary. Previous consultation between <br />the USFWS, CDOW and BLM are described in the Little Middle Creek Tract Profile <br />Report and Site Specific Analysis, both published by BLM in November of 1982. <br />This consultation process focused on "significant, important, or controversial" <br />topics (Profile, page 10). This document states on page 12 that the only <br />"important" issues regarding wildlife focused on "mule deer, elk, blue grouse, <br />sharp-tailed grouse and sage grouse reproduction areas...". <br />The Green River-Hams Fork Region Draft Environmental Impact Statement, <br />Coal, Round Two on Table 2-20a reports that the only significant impacts to <br />wildlife likely to be encounterea during the development of the Little Middle <br />Creek Tract were the loss of aquatic habitat of Fish and Trout Creeks and loss <br />of fisheries in Fish and Trout Creeks. In short, the wildlife concerns and <br />relevant key indicator species of wildlife which require mitigation for the <br />Little Middle Creek Tract have already been identified and additional habitat <br />characterization is unnecessary. <br />USFWS has stated that mining of the Little Middle Creek Tract will likely <br />have significant effects on a variety of wildlife, but the potential extent of <br />those impacts to sensitive species cannot be determined at this time. However, <br />although requested several times, the USFWS has not identifies any sensitive <br />species, but has requested that a species specific habitat analysis or an <br /> <br /> <br />5 <br />;, ~ - ems. <br />