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included followed by Colowyo's comments or proposed alternative methods for addressing your <br />concerns. <br />MITIGATION TO WILDLIFE IMPACTS <br />GREATER SAGE GROUSE <br />Conversion of wheat fields. <br />o Colowyo has evaluated CDOW's suggestion that conversion of the wheat <br />fields in the lower portions of Morgan Gulch, Jubb Creek and Collom Gulch <br />would be a significant mechanism to offset impacts to local sage grouse <br />populations. CDOW also mentions that this could also be applied to the <br />wheat fields located in the general vicinity of the Gossard Loadout. For <br />several reasons, the wheat fields nearest the Gossard Loadout would be the <br />least problematic to convert to a CRP equivalent plant community. Colowyo <br />would also be able to ensure that these fields would remain in this modified <br />condition throughout the expected remaining life span of the Gossard Loadout <br />Facility (Beyond 2030 should Collom be developed). Potential conversion of <br />the wheat fields in the Morgan Gulch, Jubb Creek and Collom Gulch areas is <br />far more difficult to commit to because of their separation from identified coal <br />resources and as such are more likely to be divested as part of a future sales <br />process. Initial inquiries lead us to believe in the short term it is unlikely that <br />Rio Tinto/Colowyo Mine legal staff would support the addition of specific <br />deed encumbrances that would ensure mitigation work would be continued <br />after a sale of these properties. <br />¦ Given the current constraints as previously discussed above Colowyo <br />would like to offer the following proposal: <br />• Conversion of the approximately 274 acres of wheat fields <br />surrounding the Gossard Loadout facility to a CRP equivalent <br />plant community that would act as additional sage grouse/mule <br />deer/elk habitat. <br />• Re-evaluation of grazing leases in the Morgan Creek Ranching <br />for Wildlife Area to identify specifically targeted <br />improvements that would benefit local sage grouse <br />populations. <br />• Evaluation of livestock grazing utilization of specific riparian <br />locations in the Morgan Creek Ranching for Wildlife Area and <br />subsequent scheduling of possible water development, fencing <br />or other relevant management practices that would positively <br />impact local sage grouse populations. <br />• Evaluation of the CRM agreement and management practices <br />that could identify additional areas in the Axial Basin that <br />could be eligible candidates for habitat improvement <br />initiatives. <br />Maintain corridors and pockets of suitable habitat in permitted mine boundary. <br />o Only approximately 9% of the expansion area is targeted for disturbance. <br />Colowyo Mine C-1981-019 page 2 of 9 4 May 2011 <br />Permit Revision 03 - Collom Permit Expansion <br />