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.' lizard, and the razorback sucker. The bald eagle (Flaliaeetus leucocephalus) is a federal and state listed threatened species, is listed as G4S2, and is considered critically imperiled in Colorado by ' NatureServe: The.kit fox (Vulpes macrons) is a state listed endangered species, a Colorado Division of Wildlife species of concern, and is listed as G4S1, which means the species is _ critically imperiled in Colorado (NatureServe 2006). The uinta basin hookless cactus , (Sclerocactus Glaucus) is a federally listed threatened species, is listed as G3S3, and is considered vulnerable in Colorado. The longnose leopard lizazd (Gambelia wislizenii) is a Colorado BLM Sensitive Species, Colorado Division of Wildlife Species of Concern, and is listed as GSS 1, which means the lizard is critically imperiled in the state. The razorback sucker (Xyrauchen texanus) is a federally and state listed endangered species, a Colorado Division of Wildlife Species of Concern, is listed as a GI Sl, and is considered critically imperiled in Colorado and throughout its range. 1. Sensitive Species in the Proposed Project Area ' a. The White-tailed prairie dog is a keystone species in the project area White-tailed prairie dogs have declined to 8% of their native range in North America, and the survival of remaining populations is threatened by habitat destmction and modification, sylvatic plague, recreational shooting, poisoning, oil, gas, mineral extraction, fire suppression, , overgrazing, off-road vehicle use, noxious weeds, and climate change (Center for Native Ecosystems et al. 2002). Due to the profound decline in population experienced by the white- tailedprairie dog, many species dependent on the prairie dog and its habitat have become imperiled as well. The imperilment experienced by these prairie dog-associated species is indicative that the white-tailed prairie dog is threatened with extinction. Many scientists consider the.prairie dog to be a keystone species (Kotliaz et al. 1999; Kotliar 2000), which is defined by Meffe and Carroll (1994) as "one that makes an unusually strong contribution to community structure or processes" (p.129). Miller et al. (1990), notes that "Ecologically, the prairie dog ecosystem is an oasis of species diversity on the grid plains" (p. 764). According to Clazk et al. (1982), "prairie dog colonies may constitute peaks in species diversity and biomass for small vertebrates found nowhere else in the prairie ecosystem" (p. , 581). In this same study, Clark also found that white-tailed colonies showed a greater number of associated vertebrate species (83 species) than either the black-tailed or Gunnison prairie dogs, and that lazger towns had greater species diversity than smaller towns. White-tailed prairie dog , colonies not only sustain ecosystems by creating suitable habitat for an abundance of species (Martin and Schroeder 1979, 1980; Campbell and Clazk 1981; Clazk et al. 1982), but the prairie dog is also an important food source for predator species. , Many rare and declining species are dependent on prairie dogs for their own survival, and adverse effects to this keystone species will likely be transmitted to listed and Special Status Species that rely on the prairie dog ecosystem in the project area. Because of its role as a ' keystone species, protecting and recovering the white-tailed prairie dog would be the most efficient approach to conserving this entire suite of species. The BLM must develop mitigation measures for white-tailed prairie dogs and their habitat in order to avoid the destruction of , individual white-tailed prairie dogs, occupied white-tailed prairie dog habitat, and the ecosystem Center for Native Ecos stems P 2 f 24 ' y age o Scoping Comments for [he Proposed Red Cliff Coal Mine