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,E.``rvisionDl Correspondence Only
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<br />• III IIII IIII IIII III •
<br />999
<br />STATE OF COLORADO
<br />DIVISION OF WILDLIFE
<br />ECOLOGICAL SERVICES
<br />•.F..
<br />U E C ~ 1981
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<br />' „~,=?:. •,;, , ~.. DEPARTMENT OF NATURAL RESOURCES
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<br />'"A~'••~,'"`~~'', DATE: 07 December 1981
<br />~i•yTOc , Allen Whitaker
<br />•FROM: Clait E. Braun and Len Carpenter
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<br />.~~ •~We have carefully reviewed the report entitled "Fertilization and Sage :~+:`~
<br />.:' : . ~ ~ ~ ~•Yv.: 2Y
<br />~'','t-. -,s~- Grouse Mitigation Measure" dated 28 October 1981 prepared by Kent A. •,,. •-, .{.+.
<br />`'npr?~~:"•~~'s,~:~' Crofts for Kerr Coal Company. We found the report shallow, misleading ~;:*t~,; 1~%?„(:•~`
<br />' •,i :•-~'': .'and not overly pertinent to the topic of the effects of nitrogen fern- ;.,.,,-:.
<br />' lizer on the sagebrush ecosystem and specifically sage grouse. We urge it+''~''
<br />',~i:',' ,.. you to send written notice to the Colorado Mined Land Reclamation Division
<br />and Office of Surface Mining Reclamation and Enforcement that the Colorado
<br />' Division of Wildlife does not accept the conclusions of the report (pages
<br />::y -, '.22 and 23). Further, we contend that Kerr Coal Company is trying to. avoid
<br />, ,,, ,, 'meaningful mitigation for the loss of sage grouse habitat in North Park, '
<br />.Jackson County, Colorado. We suggest that the concerned parties have a
<br />%~';~:F;';~ ,?.meeting to come to agreement on a meaningful mitigation plan.
<br />~r,=: ~. ,.r, .. ..
<br />"3`J%~~?~" -'-~' Our s ecific comments on the re ort
<br />p p prepared by Kerr Coal Company are:
<br />S?~•:':-" Page 1. The Colorado Division of Wildlife has provided data
<br />.;'c=f?;;~4~.~;;~.,.;_.. .. ~~~~to Kerr Coal Company based on T. Beck's M. S. Thesis
<br />v."`"~' ''• - and current studies by T. Schoenberg (1981) on the
<br />~.'~'%'C:~'F •~, -~, ~;.;~ value of the mining area to sage grouse. Ample evi-
<br />l"" -- Bence has beep prrv+s^~! h^ T. Schoenberg's work that
<br />"~ry•''= " ~ sage grouse in the area to be mined and otherwise '
<br />' affected by Kerr Coal Company will be adversely impacted
<br />•-~ ', ~ •`.',by the mining activities. The area disturbed will not
<br />' be sage grouse habitat on a year-round basis for many
<br />..~~';;?^~:.'-.;..;:,':,.;:;;.;,.: years (2-3 decades). The burden of proof is on Kerr
<br />'" Coal Company to demonstrate that their mining activities
<br />• will have no impact on sage grouse.
<br />. Pages 1 and 2. Kerr Coal Company's proposed experimental artuno-
<br />;,:; nium nitrate fertilization program (pages 780-52aaaa
<br />through 780-53bbbb of the Permit Application) was
<br />• spurious and was not designed to positively impact sage
<br />grouse or their environment off of the disturbed area.
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<br />Pages 3-7. We fail to see the relevance of spraying sagebrush
<br />with 2,4-D to reduce the density of sagebrush plants in
<br />a report where the main thrust is to discuss the effect
<br />' of fertilization on sagebrush. The sagebrush control
<br />programs in the Lake John area studied by Gill (1965),
<br />Carr (1967), Pfay (1970) and summarized by Braun and Beck
<br />~~.. (1976) in no way relate to fertilization of sagebrush
<br />ranges. The gist of the above studies was that block
<br />-~
<br />,spraying with 2,4-D was harmful to ,sage grouse while strip
<br />,~.~::,'. -_ -•'" spraying had no measurable detrimental effects. Beck's
<br />DOW-A-F-B
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