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d <br />~ ~ <br />f <br />-2- <br />The Bureau of Land Management has two grazing allotments on Federal lands in <br />the Canadian Strip permit area. Larry Lichthardt, of the Kremmling BLM office <br />provided the following information. <br />Allotment 7138 includes all of the <br />Section 11 as well as other acreage <br />3,744 acre allotment with 224 acres <br />has 20 AUMs assigned to it. Water <br />been tabulated. <br />Section 2 lands and a portion of <br />within the permit area. It is a <br />of Federal land. The Federal land <br />resources in the allotment have not <br />Allotment 7010 includes all of Section 3 and a portion of Section 11, as <br />well as other acreage to the south and west. It includes 2,500 acres of <br />public land, 945 acres of State and 80 acres of private land in the 3,525 <br />acre allotment. The Federal land has 352 AUMs assigned to it. Water <br />resources 1n the entire allotment are composed of four springs, three <br />reservoirs and portions of two intermittent streams. There is no <br />developed water on the east side of the allotment near the Canadian Strip <br />permit area. <br />Enclosed is a letter from the Acting Area Manager of the Kremmling Resource <br />Area, David Harr, approving retention of Pond No. 2 to enhance the post-mining <br />land use. He was present during the September 6, 1990, Bond Release <br />Inspection, and he indicated at that time that the BLM probably would re-build <br />the pond if it was removed, following expiration of the bond liability period. <br />The State of Colorado typically verifies information submitted by an operator <br />in the permitting process. For example, pond designs are re-evaluated using <br />the computer models associated with TIPS. As appropriate, permit <br />modifications are checked during inspections prior to revision approval. In <br />this case, our inspector had made a qualitative assessment of the availability <br />of water on a regular basis during previous years. In 1988, water was present <br />between April and mid-October; 1n 1989, it was present between March and <br />September; and in 1990, it was present between May and October. Amore <br />quantitative evaluation of water persistence would not normally be made. <br />Nonetheless, this written documentation is considered adequate verification of <br />water stability. Persistence is a measure of stability and the ponds at <br />Canadian Strip show an historic persistence that suggests a stable water level. <br />In conclusion, stability of water level for rangeland ponds in the semiarid <br />west must be evaluated within the context of the local hydrologic cycle. <br />Water persistence throughout a substantial portion of the year is a measure of <br />stability under these circumstances. Further, it must be acknowledged that <br />this period of the year is the time when the pond would be utilized by grazing <br />animals. The Federal land management agency has indicated that watershed <br />conditions at Pond No. 2 are representative of those conditions for which they <br />would construct a pond and furthermore, that they would re-build the pond if <br />it had to be removed. Based upon the foregoing, we request that the AFO <br />reconsider its position on the Phase II release of Pond No. 2 at the Canadian <br />Strip Mine. <br />