2012-03-07_PERMIT FILE - C2010088 (17)

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species occurring within the project area. We note that black bear have infrequently been seen at the McClane Coal Mine, and we have provided hazing materials to mine staff on at least 1 occasion to haze black bear attracted to the mine dumpster area. Incorporation of a bear -proof dumpster at the mine for all human food waste would eliminate that concern. As noted in the report, river otter utilize Reed Wash at various points during the year. We are aware of historic records of northern leopard frogs in Reed Wash, and suspect that they utilize most stretches of that wash. Spanning Reed Wash as proposed will reduce the potential for negative impacts on terrestrial and aquatic wildlife utilizing that tributary. Our aquatic staff was able to do a small amount of aquatic sampling in East Salt Creek this spring, and the information gained has improved our knowledge of the importance of that water to aquatic species. The CDOW and Bureau of Land Management (BLM) sampled East Salt Creek on April 14, 2010. The CDOW sampled again June 30 and July 1, 2010. Numerous small fishes were observed and collected in East Salt Creek approximately 3.5 miles downstream from the McClane Canyon mine during June /July. Juvenile fish were preserved for later identification by the Colorado State University Larval Fish Laboratory. Spawning tubercules were observed on male fathead minnows, and 3 age classes were detected. Hundreds of tadpoles were observed at that time. One adult Woodhouse toad was observed at a sampling site approximately 2 miles upstream of the mine. Water quality data was collected at both sites. We have no records of spottail shiner (referenced from the GEI study) occurring in East Salt Creek. The 2010 GEI study referenced in the reviewed reports, along with our sampling efforts, indicate that the aquatic habitat of East Salt Creek is biologically important. Native fishes make runs upstream during high water, and minnows appear to subsist in isolated pools during low water periods. The creek supplies essential water for toads and numerous terrestrial species. Activities that could potentially degrade water quality in East Salt Creek could prove detrimental to wildlife. Section 4.5.1 of the Waste Rock Disposal Site report states that the project will not affect flows in East Salt Creek, and that it is unlikely that seepage from an unlined pond would add significant amounts of selenium from soils to the creek. The report lacked documentation for those conclusions, and failed to address the addition of mine water and gob pile leachate to the wastewater stream. On the surface, it appears that the referenced study by Leib concerning selenium leaching would lead to a conclusion that since the waste rock site has not been previously irrigated, selenium leaching would In fact occur. It would also appear that discharges from the wastewater pit into East Salt Creek would inherently impact the hydrological cycle of the creek. We are unable to comment on potential wildlife impacts related to water discharged into East Salt Creek from the wastewater pit without knowledge of the specific components and anticipated amounts of both mine water and gob pile leachate in the wastewater stream. We recommend incorporation of recognized Best Management Practices at both the waste rock disposal site and the loadout site during construction to further ensure protection of the watershed. We also recommend that the waste rock disposal area be sloped such that it . drains away from East Salt Creek. We continue to advocate for lining of the water retention pit, and believe that the potential for separation of leachate and mine water from precipitation runoff coming out of the natural drainage troughs immediately east of the waste rock disposal site should be explored.