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<br />The site is also mapped as a fall concentration area for black bear and provides them the <br />nut and berry producing species that are critical to them for winter den survival and production <br />of young. Increased development activities in the surrounding area have resulted in a significant <br />increase in the conflicts experienced between humans and both black bear and mountain lion. <br />This area also is mapped as important habitat for local populations of Merriam's Turkey providing <br />valuable feeding, roosting, and poult rearing habitat. Finally, golden eagles are known to feed <br />and nest within the delineated boundary. <br />A comprehensive species list produced for this area using the Colorado Wildlife Species <br />Database is enclosed. The habitat supports a broad array of wildlife species including Federal <br />and State threatened, endangered, and candidate species. Of particular potential concern are <br />Bald Eagle and Mexican Spotted Owl. The bald eagle is known to winter along both the main <br />stem and south fork of the Purgatoire River. The combination of pinon juniper Canyonlands mixed <br />with adjoining riparian habitat provides valuable potential nesting, feeding, and roosting habitat <br />for the Mexican Spotted Owl. <br />Western Las Animas County is currently undergoing rapid development which further <br />exacerbates impacts to wildlife that could result from this proposal. The surrounding areas are <br />platted for development and this limits the extent to which wildlife can relocate if negative impacts <br />from this proposals aren't properly identified and mitigated. A recent study completed by the <br />Division of Wildlife for Las Animas County showed that 80% of the significant wildlife habitat and <br />65% of platted development occurs west of I-25. Additionally, 80% of the platted development <br />impacts high quality and critical wildlife habitat. The cumulative impacts experienced as a result <br />of this and other adjoining land practices greatly restricts the Division's management options and <br />the alternatives available for properly mitigating impacts. <br />The Division strongly recommends that a comprehensive biological assessment be initiated <br />and incorporated into the mining application. As part of this biological assessment the Division <br />should be provided detailed plans regarding surface operations and disturbance and should be <br />interactively involved, to the extent practical, with study design, facility design and placement, and <br />with development and implementation of mitigation prescriptions. The biological assessment <br />should consider both site specific impacts and potential cumulative impacts incorporating <br />information available regarding surrounding land use practices. The biological assessment <br />should also include the inventory of certain species of concern including, but not necessarily <br />limited to, the Mexican Spotted Owl. Finally, the biological assessment should comprehensively <br />identify impacts to significant local wildlife populations and propose definitive mitigation <br />mechanisms. <br />We appreciate this opportunity to address our concerns regarding the wildlife resource and <br />look forward to working together further on this project proposal. If you have any questions or <br />require additional information please feel free to call me at (719)473-2945 x227. <br />erely, <br />lL~~~ <br />David e <br />Wildlife Biologist <br />cc: Bob Holder, Ron Velarde, Barbara Pavlik, Kent Gorham <br />File: apcoal.let <br />