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consequences to the environment. We would appreciate more information on how the <br />proponent will ensure that escapement does not occur. <br />We recommend that the waste rock storage area be lined to reduce the potential of gob <br />leachate filtering into alluvial groundwater. Since the runoff from the gob pile is to be <br />routed to sedimentation ponds, those ponds also should be lined and fenced. The <br />sedimentation ponds should be designed to contain runoff from monsoonal weather <br />events related to intense thunderstorms. Assuming that ponds are lined, a mechanism <br />for escape should be included so that wildlife may exit. <br />With regard to impacts on aquatic habitat and its fauna, we note that Mack Wash and <br />Salt Creek are perennial waters supporting native fishes year round. We presume that <br />East Salt Creek is also fish bearing. Spawning of the flannelmouth sucker has been <br />documented by the CDOW in Salt Creek. Water depletion from Mack Wash will result in <br />the loss of instream habitat for native fishes, including the roundtail chub (SC). Water <br />diversion from Mack Wash during low flow months could completely de-water the wash. <br />Cumulative impacts of the proposed project to the aquatic communities of primarily <br />Mack Wash, as well as Salt Creek, and potentially the Colorado River could possibly <br />result in the reduction of native fishes utilizing the Salt Creek drainage. <br />Use of the Salt Creek drainage by Threatened and Endangered fish species is unknown. <br />These rare fishes could also be impacted by dewatering of Mack Wash, and by <br />reductions in water quality in Salt Creek due to depletion of the Mack Wash inflow. The <br />effects of water depletion upon the Threatened and Endangered fish will be mitigated <br />with payment to the USFWS Recovery Program. This action will not, however, mitigate <br />for loss of non-federally listed aquatic species and their habitat. We did not see any <br />mitigation measures proposed for impacts to these non-Federally listed native fishes. <br />We recommend that activities that could negatively impact native fish spawning should <br />be avoided from March 1 through July 31. Water depletion, as well as increased <br />sedimentation and selenium loading from construction activities related to the M.8 road <br />crossing, the water diversion structure in Mack Wash, the railroad spur, transmission <br />line and other mine facilities, would negatively impact fish species. Runoff from <br />construction activities should be minimized through the implementation of BMP's such <br />as the use of silt fences, berms, catch basins, seeding, mulching, and erosion-control <br />netting. <br />Wetland and riparian areas on public and private lands are considered critically <br />important habitats and should be protected. We would anticipate that wildlife including <br />the northern leopard frog (SC), could utilize wetland areas within the project area. <br />Impacts to wildlife species associated with both USACOE jurisdictional and non- <br />jurisdictional wetlands should be evaluated. Degradation of both jurisdictional and non- <br />jurisdictional wetland habitats should be mitigated.