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<br /> <br /> <br />During all of our previous discussions, it has been mentioned repeatedly <br />that CYCC is operating under a wildlife management/mitigation plan in Permit 79- <br />177 that the USFWS acknowledged was "reasonable" and one for which they were to <br />be "commended". Since the majority of the Little Middle Creek Tract is located <br />within our current permit boundary and is comprised of virtually identical <br />habitat values and wildlife resources, we do not understand how this program <br />can be totally ignored as it relates to the Little Middle Creek Tract, and that <br />our data and activities apply only to previous mining. We are disturbed that <br />the merits of our proposals have not been given the consideration we feel they <br />deserve. You have stated, in your letter, that "these measures alone will not <br />adequately offset loss of high value habitats...". Unfortunately, outside of <br />concerns over elk and raptors, we have little intormation as to what these high <br />value habitats include. <br />Despite the repeated usage of the term mitigation, we are uncertain exactly <br />what the definition of mitigation entails. The USFWS publication, <br />"Rehabilitation of Western Wildlife Habitat: A Review FWS/DBS-78/86 on page 3 <br />contains the following pertinent statement: <br />"The various terms dealing with remedial action applied to land <br />following disturbance also need to be clarified. According to the <br />Study Committee on the Potential for Rehabilitation of Land Surface <br />Mined for Coal in the Western United States (1974), rehabilitation <br />implies that the land will be returned to a form of productivity that <br />conforms with a prior land use plan and leads to a stable ecological <br />condition. Reclamation implies that the site is to be habitable to <br />organisms that were originally present or others that approximate the <br /> <br />