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/, ,/ C.TC: October 8, I?8! memorandum S RCPLY TO s` •**~o• Coa) Coordinator, U.S. Fish and Wi1~11ife, Denver, CO SU4ICCT: Review of '~unger Canyon and 'icClane Canyon }line Permit Applications, Sheridan Enterprises Inc. TT„ 11s. Shirley Lindsay, Office of Surface 14ining Reclamation and Enforcement, Denver, CO Please accent this letter as our official review of Sheridan Enterprises permit applications for both the 'lunger Canyon and 'icClane Canyon test mine projects. 41e are combining our responses on both applications since wildlife baseline data for each site were collected simultaneously and are reported in a similar manner. Basicall we feel that the wildlife portions of the above anpli- ~e cations are sufficient. However, we do have some concerns tat either were not adequately addressed or, in fairness to the cor~- • pony, cannot be adequately addressed with baseline information alone. To begin with, wildlife survey boundaries (in some cases survey methods and survey intensities) were not well described and complicate our ability to assess overall area importance to wildlife. For example, it is difficult to determine how thor- ough raptor inventories really were from the statement that "cliff faces were carefully examined." The existence of a golden eagle nest approximately one-half mile from the 'tunger Canyon permit area (Sid; of SE;, S29, T7S, R1O21•1; BL!i unpublished data) suggests • that raptor surveys were indeed incomplete. Since both permit areas lie only about one mile apart, the potential effects of the 'tunaer Canyon and 'icClane Canyon mines on wildlife cannot be viewed independently. Although surface development at both sites may be minimal, all surface related activities will occur within or near bottomlands that are likely to be very important to wintering deer and other wildlife. The applicant's reference to habitat/ecotone importance to mule deer is confusing and further clouds this issue. Pellet group transects were used as general indicators of deer habitat use; yet, the applicant discounts the importance of pinyon-juniper/sagebrush-bottomland • ecotone because of the uncertainty of pellet group aces. Because • no distinctions between pellet ages were made for other habitat transects, judgement of habitat importance can only he based on relative densities of all pellet groups found within each transect. 'de feel that the data presented depict very high value and use of the bottomland/woodland ectone by deer. Consequently, we believe that protection of and enhancement for high use habitats .. found within the proposed mine areas should be given high priority throughout the mine development process. r1 Buy U.S. Savings Bonds Regularly on the Payroll Savings Plan OPTIOHI•L FORM ..o IREV. )-TI G S/• FPMR ~., CiRI 101- ~ b10.112