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• <br /> STATE OF COLORADO • <br /> illJohn W.Hickenlooper,Governor .c'�� 0�. <br /> DEPARTMENT OF NATURAL RESOURCES b c <br /> DIVISION OF WILDLIFE �sf ,iP q' <br /> AN EQUAL OPPORTUNITY EMPLOYER OA, 'S' <br /> OF <br /> Thomas E. Remington, Director <br /> 6060 Broadway For Wildlife- <br /> Denver;Colorado 80216 • For People <br /> Telephone: (303)297-1192 <br /> wildlife.state.co.us <br /> May 5,2011 <br /> Glenn Williams <br /> Cotter Corporation • <br /> PO Box 700 <br /> Nucla,CO 81424 <br /> Re: JD-8 Mine,amending original 112 permit#M-1984-014 <br /> Dear Mr. Williams, • <br /> Thank you for the opportunity to comment on the proposed JD-8 Mine in Montrose County. <br /> We have reviewed the location of the proposed mine. The mine lies within mapped severe winter range for elk, <br /> and mapped winter range for mule deer. Small numbers of mule deer and elk are in the area throughout the year. <br /> The effects on these animals could be significant if new roads are established and habitat is destroyed. <br /> 110 <br /> Mule deer and elk are particularlysusceptible to disturbance duringwinter months,and the CDOW is concerned <br /> P <br /> that the direct loss of approximately 12 acres of severe winter range and winter range for mining operations,when <br /> added to the cumulative loss of severe winter range from other development activities in the area,could affect <br /> mule deer and elk populations. In order to maintain existing mule deer and elk populations,the CDOW is <br /> recommending that companies such as Cotter Corporation incorporate off-site habitat enhancement projects into <br /> their operations to compensate for the direct loss of severe big game winter range that is associated with their <br /> . projects. <br /> There also could be an indirect loss of severe winter range for mule deer and elk in areas surrounding the mine <br /> due to a decrease in the use of these habitats associated with a general increase in traffic and human activity. In <br /> order to maintain mule deer and elk winter use of the area surrounding the mine,the CDOW suggests <br /> implementing seasonal closures on mining activities between the months of December and April when the largest <br /> concentrations of wintering mule deer and elk are in the area. If seasonal traffic and mining operation closures are <br /> not possible, CDOW suggests performing additional off-site habitat enhancement projects to offset the added <br /> indirect impacts to wintering big game use of severe winter range. <br /> There are approximately 10 different species of bats that inhabit the area. One species in particular,the <br /> Thompsons Big Eared Bat, is considered a species of special concern in Colorado. Active mines have been <br /> shown to have little to no impact on bats due to continuous human activity in and around active mines. However, <br /> inactive mines are often used by bats as either winter roost sites or summer breeding areas. Many of these <br /> inactive mines have"bat gates"on them, allowing bats access and denying human disturbance. If bat gates are <br /> encountered on any mine shafts,the CDOW strongly suggests contacting our field personnel to determine the <br /> time of year bats inhabit the area, and potentially creating seasonal mining closures. <br /> di <br /> DEPARTMENT OF NATURAL RESOURCES,Mike King,Executive Director <br /> WILDLIFE COMMISSION,Tim Glenn,Chair•Robert Streeter,Vice Chair•Mark Smith,Secretary <br /> Members,David R.Brougham•Dorothea Farris•Allan Jones•Gaspar Perricone•John Singletary•Dean Wingfield <br /> Ex Officio Members,Mike King and John Salazar <br />