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2. RESPONSES TO PUBLIC COMMENTS during the growing seasons (i.e., Rio Blanco Oil Shale Company data, Aprd through September 1978-1980 (6.04 inches), 19841986 (12.01 inches}). In addition, Dow depletion calculations were found to be in ertor, being predicated both on former pumping rates and hydrologic assumptions. These figures have been revised acoordmgly. Response No. 6. We have tried to be more specific in this regard. Please see revised Section 4.9.6 in the TEXT CHANGES section of this document. Response No. 7. We have made impact assessments more specific in this regard. See corrections or revisions pertinent to Seniors 4,9.3, 4.9.4, and 4.9.6 in the 'PEXT CHANGES section of this doarment. Due to the complexity of ground and surface water interactions, it would be extremely difficult to isolate a cause and effect relationship between surface water depletions and wetland maintenance without an inordinate amount of effort expended or long-term monitoring of surface flows, precipitation, alluvial saturation, and vegetation. Based on our hydrologic amlyses, BLM believes there would be ro functional alteration of Yellow Creek's wetland habitats under the No Action, 50,000 TPY Altemative, and the Proposed Action (ace text revisions for Section 4.9.3 (page 419 of draft), Section 4.9.4 (page 420 of draft), and Section 4.9.6.1.1) and do not warrant mitigative stipulations. However, Bow depletions associated with the 500,000 TPY Alternative do pose an obvious threat to the continued maintemnce of Yellow Creek's wetlands (see revisal text for Section 4.9.3 (page 419 of draft), Section 4.9.4 (page 420 of drak), and Section 4.9.6.1.2). We feel the most efficient way of dealing with these problems is the following. Prior to BLM's approval of the 500,000 TPY Alternative, BLM would require additional hydrologic evaluations to be performed by the applicant as the basis for revisions to wetland impact assessment BLM would then attempt to develop en equitable means of determining wetland values foregone as a result of mining, and through stipulations attached to the mine plan, require the applicant to offset net losses of wetland values through project life and until mine-related impacts, which persist beyond mine life, reach negligible proportions. Ares of Critical Environmental Concern Response No. 8. It is not within the realm of this document to explain the reasons for The Nature Conser- vancy's nomination or BLM's dropping of this nominated area of critical environmental concern (ACEC) From designation consideration. For your information, The Nature Conservancy nominated the Yellow Creek Basin area for ACEC designation because they felt it contained significant ecological values (a number of stands of Arremesia rridentata app. wyomingensis/Agropyron srnithii pleat aasoaietior and a ~ area of Astrogalurlulosus habitaq. Based upon BLM's interdisciplinary analysis, this area failed W meet the required identification criteria of relevance and importance for a potential ACEC. The plant association is relatively oommor throughout the White River Resource Ares with extensive acreages throughout. At least eleven locations containing this plant acsociation, in comparable condition, have beau identified by BLM, varying in size Crom 40 to 1,200 sacs with most averaging 160 acres. Ir addition, by defutitior of its current ranking, this association is demottstrably secure globally. Asnagalus lutosus is much more common than initially thought; populations of this species are contained within five separate areas which have been designated as ACECs by BLM. For more detailed information, m information bulletin on the ACECs is available, upon request, from the BLM White River Resource Area office in Mceker, Colorado. Response No. 9. This sentence has been revised For clarifiartion (TEXT CHANGES section). Also refer to the draft EIS, page 2-30, Section 2.5, Baseline, Projects considered for cumulative analysis consist of pest, present, and reasonably foreseeable future projects oavrring in the same general area, including, for example: Federal Orl Shale Lease Tracts C-a and C-b, and the Union Shale Oil Project. CuMural/Paleontological Resources Response No. /0. It is known that any earth disturbing or extensive collecting activity on any cultural or paleontological resource would definitely result it the destruction of that resource. No change. Response No, /1, Final consultation with the Colorado State Historic Preservation Office was completed on February 9, 1987. Three known sites were identified for further work. Testing and/or mitigation measures for these sites was agreed on. In addition, stipulations regarding undiscovered resources were developed. Farmlands of Statewide Importance Response No. 11. The stream being referred m is Yellow Creek. The text has been changed or page 3-17, heading 3.5.1, paragraph 1, sentence 2 to clarify this. Response Na 13. Your statement that "it is not likely that any significant impact would occur" is correct and is qualified in the draft EIS, page 414, first column, first paragraph, second sentence. Although the chance of a spill from the piping or evaporation ponds is unlikely, it is still possible. If, as an example, one or more of the evaporation 2-44