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REV93082
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REV93082
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Entry Properties
Last modified
8/25/2016 3:14:26 AM
Creation date
11/21/2007 11:27:22 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981071
IBM Index Class Name
Revision
Doc Date
12/24/1984
Doc Name
Wildlife Mitigation Study
From
Colorado Yampa Coal
To
Fish and Wildlife Service
Type & Sequence
PR1
Media Type
D
Archive
No
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<br /> <br />original inhabitants. The most restrictive definition is restoration <br />which implies that conditions of the site at the time of disturbance <br />will be replicated or put back as they were before the action." <br />Your preferred mitigation alternative, the one you feel should be given <br />greatest priority, is to: "reestablishing habitat structures and densities <br />similar to those that now exist. Obviously, we would favor such habitat <br />reclamation...." Upon consideration of the USFWS statement, it is evident that <br />reclamation of the site "to be habitable to organisms that were originally <br />present or others that approximate the original inhabitants" is not the goal of <br />this mitigation program, but rather "that the conditions of the site at the time <br />of disturbance will be replicated or put back as they were before the actions." <br />Given the fact that no mine site we are aware of has ever been required to <br />reclaim the site to the premine "habitat structures and densities", it is no <br />wonder this recommendation poses several potentially serious problems. <br />Reclamation, not restoration is mandated by law and the mitigation plan <br />recommended clearly does not constitute reclamation; it can only be considered <br />as restoration. <br />Your reaction to our mitigation proposals has been mixed, although <br />considered as "positive mitigation steps", they were considered to inadequately <br />address the mitigation issue. The 108.2 acres of undisturbed aspen and 47.6 <br />acres of mountain shrub islands we agreed to work around were considered to be <br />too "small". We would disagree that leaving behind an undisturbed area of 156 <br />acres or C1 percent of the mine area which will create under worst case <br />conditions, 730 acres of disturbance is too "small" to be considered adequate <br />mitigation. Your statements that CYCC is leaving these islands simply because <br /> <br />
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