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~l~~ltiss`f'l [jilili~t;<i, ~~ 1_~?bi~ °"~(at1T. Center for Native Ecosystems'~`~'' ~~~~''`" September 21, 2006 Mr. David Lehmann 1536 Wynkoop, State 302 Denver, Colorado 80202 303.546.0214 fax: 303.825.2403 cne@nati veecosystems. org www.nativeecosystems.org Grand Junction Field Office Bureau of Land Management 2815 H Road Grand Junction, Colorado 81506 ZOQb SEP 25 P~ 2= 18 Re: Scoping Comments for the Proposed Red Cliff Coal Mine, Railroad Spur Line, and Other Associated Surface Facilities Dear Mr. David Lehmann: Center for Native Ecosystems ("CNE") is pleased to provide Scoping comments on the proposed red cliff coal mine, railroad spur line, coal mine waste disposal area, coal preparation plant, and other associated surface facilities. CNE is anon-profit advocacy organization dedicated to conserving and recovering native and naturally functioning ecosystems in the Greater Southern Rockies and Plains. We value the clean water, fresh air, healthy communities, sources of food and medicine, and recreational opportunities provided by native biological diversity. We also passionately believe that al] species and their natural communities have the right to exist and thrive. CNE uses the best available science to forward its mission through participation in policy, administrative processes, legal action, public outreach and organizing, and education. Of greatest concern to CNE is the crucial habitat contained within the proposed project area. This ' azea is home to an abundance of diverse and at-risk species. According to the Colorado Natural Heritage Program ("CNHP"), among the species that do occur in the project area are the white- tailedprairie dog, midget faded rattlesnake, and grand buckwheat. The white-tailed prairie dog (Cynomys leucurus) has lost 92% of its native range in North America and is ranked as a G4S4 by NatureServe, which tracks the conservation status of species across the world. The midget faded rattlesnake (Crotalus viridis concolor) is a Colorado Bureau of Land Management ' ("BLM") Sensitive Species, is listed as GST4S3, and is considered rare in the state. It is also considered a state Species of Concern by the Colorado Division of Wildlife. The grand buckwheat (Eriogonum contortum) is a Colorado BLM Sensitive Species, and is listed as a G3S2 ' by NatureServe, which means the species is considered imperiled in Colorado. Data collected by the CNHP also indicates that there are several other sensitive species that occur very near the project area including the bald eagle, kit fox, uinia basin hookless cactus, longnosed leopard Center for Native Ecosystems Page l of 24 Scoping Comments for the Proposed Red Cliff Coal Mine