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4 Mr. L. Ronel Finley December 19, 1984 Page - 2 - As you are aware, CYCC is operating on a critical timeframe and the development of this property is increasingly important to the survival of the surface coal mining operations at CYCC. Without the acquisition of this tract, we will exhaust our currently permitted reserves within three years. Upon revie~ding your letter, we were concerned about three items: (1) the time that has been devoted to the consultation process; and (2) the apparent lack of progress that is being made relative to resolving the specific items that need to be identified before an acceptable mitigation plan can be prepared. The fact that our initial meetings were held this past July and that six months have passed is cause for obvious concern. We are also concerned that your recent letter appeared to contain no new concerns or recommendations for mitigation over those identified in your letter of September 11. Lastly, (3) we are concerned about the preceived concerns of impact to wildlife that we feel have already been addressed by our existing database. As described in the attached proposal, in almost all instances where we have collected data, we have not been able to confirm that wildlife are adversely affected by mining. According to the Regulations of the Colorado Mined Land Reclamation Soard for Coal Mining, Rule 2.04.11, the applicant shall in a consultation process, present the existant wildlife information available for the area and using this information, the CMLRD and the various agencies "having responsibilities for fish and wildlife or their habitats, shall determine the level of detail and the areas of such studies...". In accordance with this requirement, we have met on four previous occasions to discuss concerns relating to this action, sent various packages of information, answered numerous questions over the telephone, but still do not know the "level of detail" the wildlife studies and mitigation plan must address. In the absence of this information, we have prepared these proposals in which we propose the level of detail and which we are hopeful will address the mitigation concerns which relate to this tract. In order to address the concerns you raised in your most recent letter, I have asked my staff to prepare the following response, position paper and our proposals for mitigation. It is our belief that the attached proposals for additional baseline data collection and mitigation address the wildlife concerns relevant to the Little Middle Creek Tract. Specifica]ly our proposals are as follows: EXISTING BASELINE STUDIES Continuation of the elk mitigation study for 5 years at the level of detail described in the attached proposal. a. Maintain 10 transmittered elk. b. Monthly aerial surveys. c. Yearly cow/calf helicopter surveys. tcros.__..- _ .. -„__ ..