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~ S ~ Staff Recommendations i' B~ - SHB AGRA Project E92-7075 Page 6 STAFF COMMENT 7. The applicant shall institute a comprehensive monitoring plan that includes on-going wildlife and vegetation surveys, and field delineations of wetlands. The monitoring plan should also include performance standards for reclamation progress. Southdown agrees to: • annual study of winter raptor populations for the first five years of operations, • annual mapping of the extent of prairie dog towns in the permit area during the same period as the raptor study, • update and field delineate wetland mapping when mine operations will approach wetland areas within a three year period (the length of federal wetland permits), • annual mine and reclamation plan report as required by the CMLRB. The prairie reclamation plan, emphasizing prairie wildlife habitat, would reasonably include monitoring of raptor populations dependent upon prairie dog towns, and would not need other extensive wildlife monitoring. STAFF COMMENT 8. All archaeological resources, prehistoric and historic, terrestrial and buried, should be treated with utmost care and concern. These cultural resources represent a unique archive of past events and contain data unavailable from any other source. Properties owned by the applicant outside the permit area and have significant, identified cultural resources should be covered by a conservation easement of satisfaction to American Indians. Southdown has agreed to protect all currently known significant sites on the Dowe Flats parcel, and on the West Dowe Flats parcel. Additional field work on the West Valley, portions of the Northwest Dowe Flats parcel, and the silica quarry has been completed and a report will be completed early in 1994 and submitted to State Historical Preservation Office (SHPO) and Boulder County. Appropriate management of cultural resources on these properties may then be determined. Southdown has agreed to form the Dowe Flats American Indian Advisory Council to involve American Indians in the management of the cultural resources of interest to them. Southdown invites Boulder County to participate in the Council. STAFF COMMENT 9. A Cultural Resources Management Plan (CRMP) should be completed prior to issuance of any permits for ground disturbance or mining. It will establish the process and performance standards to be followed during the life of the mine for historic, archaeological, historic archaeological and paleontological resources. The following concerns should be included in the CRMP: L^ A G R A forth & Environments/Group