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We are confused at the actions taken io date. Although in the September 11 letter, USFWS stated that the habitats in the Little Middle Creek Tract are "not unique to the area", we have been informed that our original data collection methods for avian and small mammals are not entirely satisfactory. Please note that we used in that data collection the procedures verbally recommended by USFWS and also in their publication entitled "An Environmental Guide to Western Surface Mining Part Two: Impact, Mitigation and Monitoring" we find on pages V- 22 and V-[3 procedures for passerine birds and small mammals. We were only informed after collecting the data that USFWS believes these methods are inadequate. However, the deficiencies cited by USFWS and the suggested additional studies proposed to make up these deficiencies are called by the USFWS report, "to be too costly and time-consuming to justify the need, in view of the effort that would be required to gain meaningful data." Of even greater concern is the fact that virtually all of the monitoring methods utilized were originally approved by the CDOW and USFWS in a consultation process to describe habitat and wildlife species on virtually the same lands that are now included in the Little Middle Creek Lease Tract. In presenting comments to OSM in Permit Application 79-177 in January 1980, USFWS stated: "This office has reviewed those segments of the subject application relevant to the fish and wildlife resources. From this aspect, we believe that the applicant should be commended on the resource information presented in addition to the organization of the subject matter". This letter concluded by stating: "Overall, we believe that the submitted plan is adequate and represents a sincere effort by Energy Fuels to comply with environmental concerns". Since the submittal of permit application 79-177, CYCC's commitment