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<br />i 4 <br /> <br />be determined that such studies will prove meaningful. However, we cannot agree <br />to commit time and resources to address unidentified impacts to wildlife species <br />that have not yet been designated as being of concern. <br />Historically, our experience and the data we have collected are often <br />contrary to impacts projected on wildlife as a result of mining. Too often, the <br />impacts projected by various agencies have never materialized. In the July 1, <br />1980 letter from CDOW to BLM, this statement was made: "our biologists feel <br />that there will be impacts to elk and other wildlife species..." as a result of <br />mining. On February 22, 1980, OSM in their Environmental Assessment of Permit <br />79-177 stated on page 16 that "OSM and the Colorado DOW have determined that <br />there will be an immediate, significant, and unquantifiable adverse impacts from <br />the proposed mining operation to the elk herd in the permit area". <br />Additionally, the Northwest Colorado Coal Final Environmental Statement Site <br />Specific Analysis for Energy rue is stateo on page EIlI-13 that the local elk <br />herd of 225 would experience a "permanent loss" of 50 animas. <br />To the contrary, after four years of full time study, our 1984 Annual <br />Progress Report, Elk Calving Behavior Study states on pages 11 and 12; "our data <br />indicates that mining and its associated forms of surface disturbance (at CYCC <br />and the surrounding surface coal mines) within documented elk calving home <br />ranges appears to have no measureable negative impact upon the local elk <br />population. Reproduction, calving home range size, fidelity to calving home <br />ranges, and habitat utilization patterns have apparently not been changed. <br />Blasting and other mine disturbance do not appear to have displaced elk. The <br />only impact mining appears to have is the temporary Toss of aspen habitats which <br />are actually disturbed." <br />22 <br />