Comment regarding wildlife BMPS for HB 1298

Comment regarding wildlife BMPS for HB 1298 Feb 24, 2008 Western Colorado Congress, Colorado Trout Unlimited and West Slope Water Network appreciate the opportunity to participate in this process. The six weeks allocated for this process are gone and another two weeks were scheduled. The seventh meeting was held on Tuesday of last week. The DOW presented a revised version of the SOPs at this last meeting. The following comments are offered regarding the SOP draft dated 2/19/08. Specific Comments. The DOW SOP for reclamation is different than in a previous version of the manuscript. These changes are an improvement over the original proposal. The specific percentages of disturbed land that must have plant cover provide industry with a goal that can be measured. The idea of posting a bond equal to costs of performing appropriate revegetation is also an excellent concept. However the Page 8, part C. statement 2 of the 2/5/08 draft SOP indicated that the industry should “manage and conserve topsoil horizons, microbe health and viability using live top-soiling techniques and top-subsoil segregation. WCC, CTU and WSWN recommend this section be put back into the portion of the 2/19/08 draft SOP in the lines above “Timing Limitation Areas.” Soil conservation is an important part of reclamation and needs to be acknowledged by all companies agreeing the SOP in lieu of BMP negotiations. The 2/19/08 proposal has a single statement designed to ...