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Heasrs. Crane and Banta _ August 29, 198:• •• ~~~; Page 3 Specifically, all water supplies in the south tributary of Foidel Creek are protected by the requirements of 30 CFR 816.57 which stipulates that a 100 foot stream buffer zone will be maintained for perennial streams. Examination of the currently approved mine plan of Permit 79-177 and delineated on the enclosed map documents that no approval has been given to Energy Fuels to disturb any such water supplies within this area. Two small stockwater ponds are located adjacent to the excess spoil pile and elk calving acea but as is demonstrated these ponds are not scheduled for mining and hence will not be disturbed by mining. Energy Fuels has appro- priately marked both ponds with buffer zone signs to eliminate their . potential of being disturbed. Some small beaver ponds located east of these stockpunds will be lost as a result of mining. However, these ponds are old and have not been worked by beavers for quite a number of years. Their present value as water for livestock and elk is therefore negligible. Lose of these beaver ponds will therefore have no noticeable impact on elk. In connection with Energy Fuels Permit 79-177 and Special Stipluation Number Four, thirty elk calving beds in and adjacent to the Eckman Park elk calving area was located and the distance to water of those thirty calving beds were recorded. Average distance to water in Eckman Park was found to be 374 meters with a range of 76 to 876 meters, while the Rattle- snack Butte calving ground beds averaged 784 meters with a range of 533 to 1295 meters. Given this site-specific data, loss of the old beaver ponds outside the elk calving area will have no'adverse impact on water avail- ability to lactating elk since their travel distance to free-standing water will not be increased. Another important factor precludes the need to construct watering areas in the present elk calving grounds. As was reported by OSM lactat- ing cows are very careful to select forage having a high degree of succu- lence during the calving season. The need for water in animal nutrition is clearly demonstrated in the books by Vallentine (1971) and Stoddard and Smith (1955). The daily water requirement for a mature elk has been reported by the S.C.S. National Range Handbook to be 3 gallons of water a day. The forage consumption for a mature elk has been established to be 0.55 animal units. By using the commonly used figure of 1,000 pounds of air-dry Eorage as equaling an animal unit month and assuming that the moisture content of the cool season forage species being grazed during the calving period is 65 percent (S.C.S. National Range Handbook) a cow elk would have to consume 52 - 39 pounds of green forage for maintenance. Using the 65 percent moisture figure, which is lower that 75 percent mois- ture figure used by Vallentine (1971), a cow elk would consume 4.26 gal- lons of water per day through grazing. Vallentine (1971:403) reports that lactating antelope did not even drink water even when readily available if succulent fortis were present. Stoddard and Smith (1955:394) report that ewes with lambs can utilize spring and summer range without watering for upwards of three months without loss in weight gain. Another important factor involved in the water requirements of graz- ing animals is the availability of snow. Seidel (1977) has documented that elk calving is often found in areas of snowdrifts. This has also