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<br /> <br /> <br />intensive baseline data inventory of avian and mammalian species composition and <br />abundance be conducted. Apparently USFWS believes that some means of <br />comparative habitat assessment accompanied by one full year of additional <br />baseline data is needed prior to development of acceptable mitigation plans. <br />CYCC disagrees since it believes that all of the above requested information is <br />i <br />already available. Information is available for this specific area on both <br />species composition and abundance by vegetation or habitat type in our original <br />permit application. Comparisons between vegetation or habitats (in terms of <br />species richness, diversity and abundance) have already been made. In addition, <br />the Pittsburg Midway Coal Mining Company has collected and submitted even more <br />data of a similar type in the same vegetation types located within proposed <br />study area. USFWS has stated that the habitat types within the Little Middle <br />Creek Tract are not unique to the area. This is verified by comparison of the <br />data collected within similar habitat types at CYCC and P&M. CYCC believes that <br />the existing baseline data on avian and mammalian species composition and <br />abundance is more than adequate to determine "habitat value" and that additional <br />studies are unnecessary. <br />Examination of the existing data reveals that both aspen and mountain shrub <br />habitat types are important to small mammals and birds. Both of these two <br />habitats are very similar in terms of species richness, diversity and abundance. <br />Therefore, it can be expected that mining of these areas will result in the <br />temporary loss of small mammals and the displacement of avian species. However, <br />it can also be demonstrated that small mammals will quickly return to premine <br />densities following reclamation. In addition, small mammal diversity can be <br />expected to increase as succession occurs. Return of avian species to premine <br />densities and diversity may take longer because of their dependence on foliage <br /> <br />