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:: ~_ M N III IIIIIIIIIIIIIIII United States Department of the Interior OFFICE OF SURFACE MINING Reclamation and Enforcement t1ROOF:S TO~VI=RS 10'_ll ISTH S'fItLGT DLNVGR, COLORADO 8(1202 OF'F'ICE OF THE. RF.G[ONAI. UIRI?CTOit RECEIVED 1AN 3 0'::<;1 MINE) IAND R[CIAMAl10N-COAL CC!C) UEPI. Of NAIUML (tE5OU0.CE5 Ms. Carol Pahlke Reclamation Specialist Colorado Pfined Land Reclamation Section Colorado Department of Natural Resources 1313 Sherman Street Denver, Colorado 80202 Dear Carol: .l ~t~l 2 ~ 1J ~~ This responds to Energy Fuels Corporation's letter of September 11, 1980 regarding Permit 79-177, OSM Stipulation No. 4. We have reviewed the calving bed data collected during the 1980 season and believe this information is invaluable. We agree that elk calving did occur in habitat adjacent to proposed mining areas but we cannot discount the possible effects of increased mine related activities in the area in 1980. In other words, the presence of elk calving beds further southwest (than in 1979) may he a result of disturbances in habitat formerly utilized. After consulting members of your staff, ttte Colorado Division of Wildlife and the U.S. Fish and Wildlife Service, we propose the following course of action. Energy Fuels should monitor calving events in 1981 to determine the locations and numbers of calving beds as well as the habitat affinity for these observations. This study should be enhanced through the trapping, marking and monitoring pro;;ram currently underway. Location of calving beds should be accomplished using t1Je same methods as those used in 1980 to allow data comparisons. In the meantime, tlirongh consultations with the agencies mentioned, a set of criteria will be developed to determine if the loss of traditional calving habitat has had an adverse impact on herd production. if the 1481 data reveal calving behavior indicating a scarcity of suitable areas or movement out of the established grounds, then Energy Fuels must adopt practices to enhance calving, through habitat management. The location, size, shape and maintenance of these areas will he determined after the need for them is agreed upon. It is hoped that habitat management necessary would be accomplished in the fall of 1981 so that the 1982 calving data will document the value of these managed areas. This means that the 1981 data should be submitted by Suly 15 to allow proper review.