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. - • • iii iiiiiiiiiiiiiiii~ <br /> <br />STATE OF COLORADO REFER TO <br />Roy Romer, Governor <br />DEPARTMENT OF NATURAL RESOURCES <br />`OWR9~ <br /> <br />DIVISION OF WILDLIFE O <br />o <br /> <br />AN EQUAL OPPOFTUMITY EMPLOYEq <br />P <br />r <br />D <br />Ol <br />n <br />Dir <br />t ~ <br />~ „ <br />"~ <br />ry <br />. <br />, <br />e <br />so <br />ec <br />or <br />6060 Broatlwa S ~ <br />f <br />V <br />y <br />Denver. Colorado eoz 1 s 0 <br />N OF <br />Telephone: (30~I 2977792 <br />For ~Idlije- <br /> ~ECEI'~~i~ For People <br />711 Independent Avenue <br />Grand Tunct ion. CO 81505 tE8 28 1gg4 <br />February 22, 1994 ,~..,~~,~r <br /> l <br />L Wlgrtrcq <br /> <br /> <br />Gary W. Wendt , a <br />l.ro.:: ~lr <br />Peabody Western Coal Company <br />1300 South Yale Street <br />Flagstaff, Arizona 86001 <br />Dear Mr. Wendt: <br />I have reviewed the materials provided by you concerning the <br />revised post mining land use plan, Tab 13, for Senica II Mine. I <br />disagree that the plan as proposed will meet the postmine <br />objectives for wildlife habitat. <br />In my letter to the Division of Minerals and Geology when I <br />talked about restoring "restoring woody plant density on a <br />moderate scale" I did not mean to imply that 1000 stems/acre is <br />moderate. When this standard was established it was considered an <br />absolute minimum and was very acceptable by industry. Now that <br />thousands of acres of prime mountain shrub habitat have been <br />destroyed and the coal resources extracted, companies are lining <br />up to back out on commitments that they made. I would agree that <br />maybe the standards needs to be re-written because I think other <br />criteria should also be included. We should be looking at the <br />relative height classes, relative age classes and percent cover <br />of the canopy. All that the current standard does is barely set <br />the stage for a disturbed site to begin to return to a healthy <br />shrub community. <br />In an effort to quantify the impacts to wildlife of removal <br />of mountain shrub habitats and conversion to a grassland I did a <br />query of the Iatilong wildata database. It indicates that there <br />is as much as a 35 fold increase of wildlife species that use the <br />complex aspen, mountain shrub, sagebrush habitats as use <br />grasslands. This does not surprise me as one of the basics that I <br />learned in "wildlife 101" is the complexity of habitats is <br />reflected in the diversity of wildlife. We were talking about <br />biodiversity when the regulations to reclaim mined lands were <br />written and we still are talking about this diversity. The , <br />terminology may have changed but our concerns have not. <br />If the effort to replace a fraction of the habitat is too <br />much of a cost then we had better revisit turning it upside down <br />in the first place. <br />We will object to reducing the current standard. We have no <br />DEPARTMENT OF NATURAL RESOURCES, Kenneth Salazar, Executive Director <br />WILDLIFE COMMISSION, William R. Hegberg, Member Eldon W. Cooper, Member Felix Chavez, Member Rebecca L. Frank, Membe <br />Louis F. Swift, Secretary George VanDenBerg, Chairman Arnold Salazar, Member Thomas M. Eve, Vice Chairman <br />