2017-12-27_PERMIT FILE - M2017049

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TheNature The Nature Conservancy in tel (303)444-2950 ConSerVanc Colorado fax (303)444-2985 Y 2424 Spruce Street Protecting nature.Preserving life" Boulder, CO 80302 nature.org/colorado RECEIVED DEC 2 7 2017 ®MSION OF RECL4MATION MINING AN,)SAFETY December 20, 2017 Ms. Amy Eschberger Colorado Division of Reclamation, Mining and Safety OW1313 Sherman Street, Room 215 Denver, CO 80203 Subject: Transit Mix Concrete Permit#M-2017-049 Dear Amy, The Nature Conservancy (TNC)would like to provide comments regarding Transit Mix Concrete's permit application (Permit#M-2017-049) in El Paso County. This response is based on our knowledge and interests related to the proposed quarry lease by Transit Mix Concrete on the Hitch Rack Ranch in El Paso County. We previously submitted comments in April of 2016 regarding Transit Mix Concrete's application for permit#M-2016-10. While the certain aspects of the proposed quarry have been revised, we still have the following concerns about the possible environmental impacts of the proposed quarry: The proposed quarry site is mapped by the US Fish and Wildlife Service as Critical Habitat for the Mexican Spotted Owl (Strix occidentalis lucida), a federally listed threatened species. The map can be found at the link below(SRM C 1): http://www.fws.gov/southwest/es/MSO_critical_habitat_archive.html#maps. It is TNC's understanding that Transit Mix Concrete is working with the US Fish and Wildlife Service, as well as conducting surveys for owls to determine whether the proposed quarry would impact the Mexican Spotted Owl, which we believe are essential steps to determining whether the project should go forward. The site is also part of the Aiken Canyon Potential Conservation Area and was identified by the Colorado Natural Heritage Program in 2001 as a 132 site—a site of very high conservation significance. This location provides high quality foothills plant communities that are rapidly being converted to development north and south of this area. These dry (xeric)tallgrass sites along the Front Range are also rarely found in high quality condition and support several rare species of butterflies. The site contains excellent to good examples of globally-imperiled(G2 S2) mountain mahogany/needlegrass community(Cercocarpus niontanus/Stipa comata), an excellent condition occurrence of a globally vulnerable (G3 S2)pinyon pine/Scribner needlegrass community(Pinus edulis/Stipa scribneri), as well as an excellent occurrence of