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- III Illlllllllllli United States Department of the Interior --.-999 _ Ms. Sandy Brown DECEIVED Colorado Division of Minerals and Geology 1313 Shennan Street, Room 215 JAN 25 1999 Denver, CO 80459 ',~vis c;. of Minerals 8 Geology Re: Marr Mine (Permit No. C-80-006) Technical Revision Application No. 19 Reduction of Woody Stem Density _k January 21, 1999 Dear Ms. Brown: The US Bureau of Land Management (BLM) has reviewed Technical Revision TR-19 submitted on behalf of the Ker Coal Company for the Mar Strip Mine. The BLM is the Federal land manage- ment agency responsible for management of 75% of the surface and mineral resources of Pit 1. BLM conmrents regardurg the main access road and seditnent ponds, were submitted to you on January 14, 1999. The following comment is in regard to Ker Coal Company's request to reduce the final shrub density at the Mar mine from 2,000 to 500 stems per acre: BLM recently held discussions with the State of Colorado, Division of Wildlife regarding Ker Coal Company's request to reduce the number of woody plant (primarily sagebrush) stems per acre from 2,000 to 500. The BLM recommends that this request no[ be granted until we have seen that a reasonable effort to meet this standard is unsuccessful. The Ker Coal Company should be required to make a reasonable attempt, using the various techniques available, [o establish woody vegetation in the disturbed areas on Federal land. The 2,000 woody plants per acre standard was established and agreed upon by Federal and State agencies and the Ker Coal Company during the reclamation planning phase of this mining project. The 2,000 woody stems per acre standard is far from pre-mining densities; however, this number of plants should provide a seed source for additional woody plant establishment over time. The wildlife species using the mine site prior to mining include sage grouse, pronghorn antelope, mule deer and numerous small birds and mammals. The mitre site lies in an area identified as critical winter habitat for sage grouse and tnule deer, each of which depends on sagebrush daring winter. The recent interest in the future of sage grouse in Jackson County, and the implication of possible listing of the species as threatened or endangered, require that the BLM and other concerned entities do BUREAU OF LAND MANAGEMENT Krenunling Field Office 1116 Park Ave. P.O. Bax 68 IN REPLY REFER TO: firemmling, Colorado 80459 C-??777 970-724-3437 h(tp://www.co.b I m.gov/kra/F:ra inde x. h mr