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during that study. The Beck (1999) paper listed as a reference in the report also notes <br />that fact. Fitzgerald recorded movements of 20 and 25 miles for radio-collared male <br />and female kit fox. The Redcliff Mine project area is located within that distance for <br />each of the Colorado River Valley capture sites. Because the design, timing and <br />intensity of survey efforts related to kit fox for this project was based on erroneous <br />information regarding past occurrence, we question its adequacy. <br />The Baseline Wildlife Report (Table 2.8-1) concludes that no suitable habitat is present <br />for the northern leopard frog, a Colorado Species of Special Concern (SC). We question <br />that conclusion, and note that northern leopard frogs occur in wetland areas of the <br />Grand Valley. We believe potential habitat does exist for this species in the wetlands <br />associated with Mack Wash and the wetlands located near the proposed railroad tie in <br />at Mack. <br />We do not feel that the statement that "the Baseline Wildlife report concludes there will <br />not be any impacts to rare and endangered animal species with the exception that <br />water depletions may impact the endangered fish specie.' (2.04. 11) is supported by <br />that document. The Baseline Report addresses species occurrence, and is not an <br />analysis of the potential impacts of this development on those species. We absolutely <br />do believe a thorough analysis of the anticipated impacts of this development on the <br />affected wildlife species should be in this section, however. <br />We note that the Mitigation of the Impacts of Mining Operations section (2.05.6) <br />appears to be based in large part on information provided by the DOW (05-08-06) in <br />response to a request for wildlife information in the project area. We believe that the <br />proposed mitigation measures are a good place to start, but that the section should <br />include much more detailed and specific information. Through the parallel BLM EIS <br />process we have become much more familiar with the scope of this development and <br />its anticipated impacts on wildlife species. Mitigation measures recommended by <br />CDOW for terrestrial species through that process include: <br />• Implementation of measures designed to reduce kit fox habitat fragmentation <br />related to construction of the rail spur, power transmission line, and associated <br />construction roads; <br />• Immediate reclamation of all construction-related roads and trails in the project <br />area; <br />• No human encroachment within 150' of nesting burrowing owls from March 15- <br />October 31; <br />Protection of white-tailed prairie dog colonies;