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<br />there is no mineable coal under them implies that we are committing to something <br />that requires no effort on our part. In fact, the commitment to leave these <br />islands has been made at a considerable, additional expense to this operation. <br />Our planning has emphasized that the construction of haulroads, access roads, <br />sedimentation control facilities, topsoil stockpiles, utility corridors and <br />various other mine support facilities will be relocated to operationally less <br />desirable and placed on more expensive sites simply to preserve these islands. <br />It is our impression that your comments do not adequately address the importance <br />of this commitment and its significance to an overall mitigation program. <br />REESTABLISHMtNI OF EXISTHNT VEGETATION <br />The habitat value of vegetation present on the Little Middle Creek Tract is <br />repeatedly called "important" and there almost appears to be an extreme <br />importance placed on the existent vegetation. We cannot address the value of <br />this habitat to unidentified species. However, we strongly question that all <br />impacts from mining to the natural vegetation will automatically adversely <br />affect elk or raptors. In a publication of the Colorado Division of Wildlife <br />entitled, "Guidelines for Habitat Modification to Benefit Wildlife" <br />recommendations are made about how alteration of oakbrush (page 78), sagebrush <br />(page 83 ), and aspen (page 85) habitats can be made to improve the value of such <br />areas for elk (pages 89-90) and raptors (pages 169-1/0). We cannot understand <br />how alteration of overmature and decadent stands of these species can be <br />considered as enhancement, while at the same time very similar alterations can <br />be accomplished by mining, only be considered as impacts that will cause an <br />"irretrievable" and "permanent loss" of wildlife habitat. It is our opinion <br />15 x. <br />._ :'_-~ . , :`~.: ,::ate <br />