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<br /> <br />to protect wildlife has continued to increase, its database has continued to <br />increase through five years of additional site specific monitoring, by a full- <br />time resident wildlife biologist, and there has been absolutely no corresponding <br />change in regulations. It is difficult for CYCC to see how your views of its <br />efforts could have changed from a commendation of its sincere efforts to <br />adequately comply with environmental concerns to a point where now the wildlife <br />habitat on the Little Middle Creek Tract cannot be "realistically depicted" due <br />to the absence of adequate baseline data. <br />CYCC believes that the data at the level of detail presented are in fact <br />very adequate and realistically depict the wildlife hatibat at the Little Middle <br />Creek Tract sufficiently to allow formulation of an acceptable mitigation plan. <br />CYCC requests specific identification of any preceived deficiencies in the <br />wildlife baseline incentives, and believes that if any exist, they can be <br />adequately addressed in the coming field season prior to permit approval in <br />October, 1985. <br />ELK <br />We do not accept the position that the elk studies performed to date apply <br />only as mitigation to previously mined areas. The July 1, 1980 letter from CDOW <br />to BLM on the original wildlife buffer zone concerns clearly states that the <br />five year elk survey/mitigation program appliea to the impacts or mining "the <br />existing lease and mining of the buffer zone...". The previous mining on the <br />existing lease (C-22644) has occurred, but the mining of the remainder of the <br />buffer zone lying within the original elk buffer zone including the Little <br />Middle Creek Tract has not yet occurred. The USFWS interpretation that the <br />scope of the elk study was done only as a mitigation measure for mining within <br />9 <br /> <br />