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<br />placed underground, and all power lines associated with this project should conform to the <br />"USFWS Region 6 Draft Raptor Protection Guidelines" (attached), the "Suggested Practices for <br />Avian Protection on Power Lines, the State of the Art in 2006" and the "Avian Protection Plan <br />(APP) Guidelines" document published in 2005 (the latter two documents can be accessed at <br />www.aplic.org). Additional Endangered Species Act section 7 consultation may be required if <br />listed species are encountered during the biological survey. <br />In summary, the information provided in the DEIS by your office is insufficient to assess the <br />impacts associated with this project. It appears that biological surveys, water quality monitoring, <br />and minimization measure planning are incomplete at this time. We believe that the potential <br />effects to listed species have not been adequately addressed, and further ESA consultation may <br />be necessary. We recommend that another DEIS be released with more complete information, <br />for the review of all interested parties, prior to the release of a final EIS and Record of Decision. <br />We understand that the Colorado Division of Wildlife (CDOW) has been working as cooperating <br />agency for this project and has submitted very thorough comments. We reiterate concerns <br />expressed by the CDOW, and request that you address their comments as well as those provided <br />in this letter prior to the release of the next draft of the EIS. <br />Thank you for involving us in the planning process for this project. We trust that you will <br />require CAM to address the many inadequacies in the DEIS and look forward to reviewing the <br />next draft. If we can be of further assistance, please contact Collin Ewing of the Western <br />Colorado Field Office in Grand Junction at (970) 243-2778, extension 18. <br />Attachment: USFWS Region 6 Draft Raptor Protection Guidelines <br />cc: Michael P. Boulay <br />Division of Reclamation, Mining and Safety <br />Colorado Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />OSM, Denver (Allen D. Klein) with attachment <br />CEwing: BLMGJFORedC I iffMineExpansionProjectInfoRequest. doc:031609 <br />Literature Cited <br />Colorado Department of Public Health and Environment. 2008. Classifications and numeric <br />standards for the Lower Colorado Basin, 5 CCR 1002-37, Regulation No. 37: Denver, <br />Colo., Colorado Department of Public Health and Environment, Water Quality Control <br />Commission. 64 pages. <br />4