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2 The Service also concurs with your conclusion that the proposed action "may affect", but is "not likely to adversely affect" the Canada lynx. Tables 3 and 4 in the biological assessment provide • habitat statistics for the Mount Gunnison Lynx Analysis Unit. However, we do not believe that this information represents the true environmental baseline for the proposed action. In an attempt to determine the appropriate environmental baseline for the proposed action, we reviewed two previous actions, the Sylvester Gulch and Box Canyon projects (BO # ES/GJ-6- CO-04-F-008) ,and the Dry Fork coal lease project (BO # ES/GJ-6-CO-06-F-003), which occurred at the West Elk Mine. We detected some discrepancies related to the habitat statistics for the Mount Gunnison LAU. The detected discrepancies in the previous project documents for the West Elk Mine are in the total size of the Mount Gunnison LAU, the amount of lynx habitat within the LAU and the amount of habitat in an unsuitable condition within the LAU. The environmental baseline for the proposed action did not include lynx habitat disturbances that resulted from previous actions. We have concluded, through our review of the previous actions, that approximately 71 acres of habita[ disturbance have been addressed Through previous section 7 consultations. Therefore the environmental baseline statistics for the Mount Gunnison LAU should have reflected the previous habitat disturbances. The current proposed action anticipates approximately 54 acres of disturbance. When added to past actions, the total habitat converted to an unsuitable condition within the Mount Gunnison LAU is 125 acres. The BA states that the quantity of lynx habitat within the Mount Gunnison LAU totals approximately 23,586 acres. Therefore, the conversion of 125 acres to an unsuitable condition equates to 0.5% of the lynx habitat in this condition. The amount of lynx habitat in an unsuitable condition is within Lynx Conservation Assessment and Strategy (Ruediger et al. 2000) standards for providing sufficient foraging habitat for lynx. The effect of this conversion is considered insignificant and will not preclude the Mount Gunnison LAU from supporting a resident lynx. • The biological assessment stated that additional snow compaction, within lynx habitat, would result from the proposed action. However the BA concluded that minimal winter forage/denning habitat would be disturbed. The BA does not discuss increased snow compaction within "other" lynx habitat and therefore did not state the anticipated overall length of compacted routes resulting from the project. There is little question that the proposed action will result in increased snow compaction within the Mount Gunnison LAU. However, within the project area, the habitat appears to consist primarily of aspen forest with some small, isolated pockets of winter forage/denning habitat that are disjunct from larger contiguous blocks of habitat within the LAU. Also, the project area has several narrow stringers of winter forage/denning habitat that may be bisected by proposed roads or drill pads. These narrow stringers may extend to lower elevations due to the northerly aspect, which retain moisture and results in a more mesic vegetative condition. Aspen forests do not provide sufficient cover or forage for snowshoe hares (Lepus americanus) during winter months. Therefore, there is little likelihood that a resident lynx will be present within this vegetation type during the winter. The project area appears to be a transition area between low elevation dry vegetation types and higher elevation wetter vegetation more suitable for lynx and lynx prey. We believe that lynx may still use this area periodically (primarily during the snow free period), but The project area is unlikely to support snowshoe hare numbers that will support a resident lynx for any length of time. Additionally, the BA states that this area does not receive consistent deep snow and that there is little if any spatial segregation between lynx and other predators competing for prey. Therefore, based on •