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<br /> <br />wildlife by destroying habitat, increasing road kills, frieghtening wildlife, and reducing air <br />quality by loosing dirt and dust and causing it to become airborne. Disruption associated with , <br />road construction degrades habitat on a large scale and fragments travel comdors needed by <br />wildlife species. Roads become conduits for non-native species that displace native species <br />resulting in significant mitigation costs for taxpayers. Roads increase sediment deposits in ' <br />streams resulting in reductions in fish habitat productivity. <br />Additionally, the BLM must consider the economic costs that are associated with road ' <br />construction. A few of these costs include increased ORV monitoring costs, increased frequency <br />and costs of stream restoration projects, increased noxious weed mitigation costs, increased costs <br />to develop and implement mitigation measures to minimize harm to Special Status Species, and , <br />increased road maintenance and closure costs for taxpayers. The agency also needs to analyze <br />the costs of road maintenance and restoration and compare these costs with the budgets available <br />to complete the work.lb The BLM must include a detailed analysis of these costs as part of the ' <br />NEPA analysis. <br />12. Strict and effective reclamation conditions must be implemented <br />Although reclamation is much less important in terms of reducing environmental impacts than ' <br />reducing the footprint of the project in the first place, it is imperative that reclamation procedures <br />allow the re-establishment of native vegetation cover as rapidly as possibly to minimize the <br />opportunity for the invasion of noxious weeds. Do not substitute post facto reclamation for <br />proactive conservation measures. <br />13. Powerline Infrastructure that May Be Required for the Project Must Be Considered <br />Powerlines serve as perches for raptors, and can therefore concentrate predation pressure around ' <br />powerline corridors. Thus, it is critically important that powerlines not be sited within one mile <br />of prairie dog colonies or within reasonable distances of other special status species that may <br />serve as prey for raptors species. Additionally, all powerline corridors required for and ' <br />associated with this project should be paired in the same right of way as pipeline, road and rail <br />line corridors in order to reduce the overall surface impacts of pipeline networks in the project <br />area. ' <br />14. Pipeline Configurations that May Be Required for the Project Must Be Considered , <br />All pipelines required for and associated with this project, including water-gathering and <br />distribution pipelines, should be paired in the same right of way in order to reduce the overall ' <br />surface impacts of pipeline networks in the project. Additionally, all pipelines should be buried <br />in road and rail line ROWS and powerline comdors, instead of being placed in separate ROWS. <br />This clustering of transportation corridors with pipelines will help reduce and minimize the ' <br />overall surface acreage disturbed by the project. If there is situation that requires a pipeline to not <br />16 For the Forest Service, the annual maintenance cost of one mile of road is approximately 51,500. ' <br />Center for Native Ecosystems Page 14 of 24 <br />Scoping Comments for the Proposed Red Cliff Coat Mine <br />