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Show /3 MITIGATION Except for mitigation of wildlife resources lost to the Flaming Gorge development, the Forest Service, the U.S. Fish & Wildlife Service, and the State Division of Wildlife Resources have been unable, to date, to obtain any mitigation at all or even to obtain any satisfactory basis for determining it, related to CUP developments, from the Bureau of Reclamation. From what I have read of interagency communications, the Bureau has been arrogant and obdurate about mitigation - except in trying to resolve Ute Indian Deferral Agreement issues. Subsequent to the fuss made, the Bureau now plans mitigation concurrent with developments*. However, I have pursued criteria being used for it, i.e., stream mile for stream mile, acre for acre, % productivity lost, etc. The Bureau proposals zero in on the numbers of huntable species to be lost by any one development: so many elk, so many deer, so many moose, or, in the case of grouse, area of habitat. This approach Ignores the fact that topography, soil, precipitation, and vegetation undergird the land's productivity and perpetuation. Biologic productivity of a land area is disregarded. I have had a number of discussions with wildlife specialists about mitigation criteria. None of the State or Federal Agencies are satisfied with the Bureau criteria. The criteria recommended by the former State Director of Wildlife Resources to me is what he calls EQUIVALENT PRODUCTIVITY. This would take into consideration the biologic productivity of an area of land being lost to productivity through Inundation. It could cover consequences of an 8 mile open canal crossing elk and deer migrating routes and feeding area. It could prevent a Bureau proposal to replace wetland or forest habitat with acreage of sagebrush with improvements for deer winter use on Indian land.** It could prevent Bureau proposals to mitigate 11 elk lost - when loss encompasses varieties of ordinary, non-threatened rare birds and mammals. In consideration of the unique features on the Uinta Range and their ultimate contribution to diversity of wildlife existence, I believe we have to press for mitigation criteria adequate for the resource. I believe that this issue ought not to be left up to the Bureau of Reclamation to determine. Any mitigation on any grounds less than equivalent productivity fails us in our obligations to protect and sustain the Uinta Range wildlife resources. *** For purposes of pressing for criteria such as equivalent productivity, however, we have to determine the productivity of a habitat area and/or a habitat type. * While this is good in most cases, it has adverse values when It comes to a situation where development on Utah Lake Is the end development in a process. ** Because of cost, the Bureau has rejected ranch holding within the Forest Service or adjacent. *** Note just released CRCUP newsletter, Page 10. |
