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We request, therefore, that hich use habitats for deer found <br />within the mine area be protected and/or enhanced to reduce <br />construction and operation impacts on the deer. This <br />mitigation/enhancement for deer should be coordinated with the <br />CROW. The Munger permit areas are also showing an increase in <br />elk use; also in winter and early spring. Habitat <br />protection/enhancement efforts similar to those for deer, should <br />also be implemented to increase the ability of the permit area to <br />sustain elk use. <br />We believe that continued monitoring of deer and elk use in the <br />mine permit area, as described in the permit revision application, <br />would be the first step in determining critical use areas and what <br />type of mitigation would best compensate for any big name losses <br />during construction. <br />As we have stated before, we continue to be concerned about <br />coal transportation. The revised application states that a <br />conveyor system would be used to transport coal from the Munger <br />and McClain Mines to a central load out. These conveyors should <br />be constructed so as not to impede deer and elk migration. Of <br />greater concern is the transportation of coal from the mine <br />to a rail loadout. <br />We believe a rail system of coal transportation would have the <br />least impact on wildlife in the region. However, if a rail line <br />is constructed, it should be built to serve all entities in the <br />general area. In addition to Munger and McClain Mines, Dorchester <br />Coal Company and Chevron Shale Oil Company should utilize a common <br />rail system. In the meantime, if trucks are used to transport <br />the coal, big game road kills should be monitored. If problems <br />arise, those problem areas may require some remedial measures to <br />reduce or eliminate kills. Truck transportation during the <br />winter and early spring would be most critical. During these <br />periods, coal transportation should be restricted to daylight <br />hours and lowered speed limits imposed through the Bookcliff <br />canyon reach. <br />One important aspect of permitting is the assessment of any <br />effects of the proposed plan to threatened or endangered species. <br />At your request, our Salt Lake City EY:danaered Species Office <br />provided a species list on November 21, 1984. This list <br />included listed, proposed and candidate species which may be <br />present in the mine plan area. We assume that a biolocical <br />assessment is forthcoming and will precede any permitting <br />decision. <br />In view of the above, the FWS recommends that the following <br />stipulations be incorporated into the permitting process on the <br />Munger Canyon Mine: <br />