2019-08-15_PERMIT FILE - M2019034

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I COLORADO Parks and Wildlife " Department of Natural Resources RECEIVED Salida Service Center 7405 W Highway 50 AUG 15 2019 Salida, CO 81201 P 719.530.5520 1 F 719.530.5554 OIVlS10N OF RECLAMATION MINING AND SAFETY \ August 12, 2019 ypustin Czapla Division of Reclamation, Mining and Safety 1313 Sherman Street, Room 215 Denver, CO 80203 Dustin.czapta@state.co.us Re: Birdseye Pit, File No. M-2019-034 Dear Mr. Czapla, Colorado Parks and Wildlife (CPW) staff have reviewed your application to mine gravel at the Birdseye Pit in Lake County, and offer the following comments. The East Fork of the Arkansas River supports a community of fish primarily made up of self-sustaining populations of brown trout and brook trout. Brown trout tend to dominate the species composition, as they outnumber the brook trout roughly 20:1. Both brown and brook trout spawn in the fall season, and they each rely on the presence of gravel substrate (10 - 35mm in diameter) to lay and incubate their eggs. Any loss in this valuable substrate could cause an immediate negative impact to the health of the fishery, and the ability of the trout to reproduce. For this reason, CPW recommends that no gravel removal occur within the East Fork of the Arkansas River. Trout species depend on a variety of aquatic and terrestrial insects as a primary food source. These insect species rely on vegetation adjacent to waterways. As riparian plants die and/or shed their leaves for the season, the organics (leaves and sticks) that fall into the stream become a critical food source for aquatic invertebrates. Any significant loss to riparian vegetation can result in a loss of food for these insect species. Additionally, riparian vegetation provides the primary stability for riverbanks. A loss in riparian vegetation can result in increased erosion of the streambanks, and therefore increased sedimentation. Therefore, CPW recommends a 200' buffer distance from the river for any excavation processes in order to protect important reproductive habitat and associated riparian vegetation. CPW recommends that the mining operators implement best management practices (BMPs) to reduce or eliminate the risks of; excess sediment introduction to the stream, gas or oil spills/leaks into the waterway, and any loss of valuable wetland/riparian vegetation. Lake County supports some of the highest density of wetland habitat in the entire state. It is recommended that great care be taken to ensure that this critical habitat is protected. Several species of both big and small game can be found in or near the project area. Elk, deer, bear, moose and bighorn sheep use the area as a migration and movement corridor. Elk and moose utilize the area for calving and young rearing and deer for fawning and young rearing. Moose occupy the area year round. Small game species include coyote, red fox, beaver, marmot, snowshoe hare and lynx. According to CPW website, there is a greater than 703vo chance of lynx using the area. https: cpw.state.Co.us/Documents/Research/Mammals/Publications/CPWPredictiveLynxMapRel)ort.p df. Dan Prenzlow,Director,Colorado Parks and Wildlife•Parks and Wildlife Commission:Michelle Zimmerman,Chair•Marvin McDaniel,Vice-Chair NT ^; •o James Vigil,Secretary•Taishya Adams•Betsy Blecha•Robert W.Bray•Charles Garcia•Mane Haskett•Came Besnette Hauser•Luke B.Schafer•Eden Vardy : s`876 s/