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/ ~ Measre. Crane and ~ta ,~ ~ _ August 29, 1980• • Page 2 The response of Energy Fuels in connection with the elk distribution and watering issue was initially addressed in our permit on page 816-155 dealing with the postmining grazing requirements of Section 816.115. We have carefully evaluated the response prepared by OSM, have con- versed with Mr. Ron Naten, your Wildlife Biologist, and have reviewed the Reichelt (1973) study sent to us my Mr. Ron Naten and can find no specific mention in that study relative [o the requirements of lactating elk to select calving areas in close proximity to water. We have written Mr. Naten asking for clarification on this matter and have yet received no reply. It is therefore our opinion, based upon information at our dispos- al and based upon conversation with Mr. Allen Whitaker of the Colorado Division of Wildlife, that the requirements to re-establish elk watering areas is unjustified at the present time. OSM has cited unreEerenced hydrologic studies to show that after mining the water available for wildlife will be sufficiently reduced. Unfortunately, we at Energy Fuels are unaware of any such studies that have been conducted at our mine or elsewhere in Northwest Colorado that indicate that either surface or groundwater will be reduced by mining. The few studies we are aware of that have been conducted in the Northern Great Plains cannot reasonably be compared to hydrologic conditions in North- west Colorado because the major water aquifers in Colorado lie below the coal seam being mined whereas in the Northern Great Plains the coal seams themselves are the predominate aquifers. Energy Fuels has appropriately documented in our permit in response to Section 780.21 (c) that mining will not negatively impact either surface or groundwater quantities or qualities that relate to either livestock or wildlife usage. Our own experience in dealing with reclamation of mined lands and hydrological impacts are that mining has actually resulted in an increase in water availability on mined areas due to the mining processes that render the overburden more porous. Examination of reclamation conducted at Mines 1 and 2 indicates that following reseeding it is often impossible to re-enter such areas for maintenance activities due to the numerous seeps that have Energy Fuels admits that two small stockponds located within the Eckman Park elk calving area will be disturbed as a result of mining. These two ponds, as well as all streams and ponds located in the Eckman Park elk calving - mining area, are found on the enclosed map entitled Eckman Park Hydrology - Elk Calving Map. Ponds, streams, and 1979 elk calving areas on this map were originally submitted to OSM in Permit 79-177 as Maps 14 and 22 (Eckman Park Hydrology and Eckman Park F.Lk Caly- ing Observations). The distribution of elk calving areas in 1980 were determined from data collected this year. Examination of the Eckman Park hydrology - Elk Calving Map reveals that within the boundrles of the elk calving areas identified in both 1979 and 1980 all free-standing supplies of water present before mining and associated disturbance will be protected by the current mining plan.