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a-18-1997 2:1dPM FROh~ <br />STATE OF COLORADO <br />Roy Romer, Governor <br />DEPARTMENT OF NATURAL RESOURCES <br />DIVISION OF WILDLIFE <br />/Jl EOUNL OPPOMVNITY EMPUT'ER <br />John W. Mumma, Direttar <br />6060 Broadway <br />Denver, Colorado 80216 <br />Telephone: (303) 297-1192 <br />17 April 97 <br />James C. Stevens <br />Senior Environmental Protection Specialist <br />Division of Minerals and Geology <br />1313 Sherman St., Rm 215 <br />Denver, CO 80203 <br />RE: File No. M-97-011 <br />Baculite Mesa 1'it <br />Dear Mr. Stevens: . <br />• P. 2 <br />REFER TO <br />Fvr Wildlife - <br />For People <br />The Colorado Division of Wildlife (CROW) has reviewed the above referenced application and <br />offers the following comments concernutg the proposed action. <br />The permit area is characterized as having Gilcrest series soils which currently support a diverse <br />shortgrass prairie ecosystem The conversion of this habitat type to a rangeland designation will <br />significantly reduce the habitat value of the 1900 acre permit area. The reclamation plan <br />improperly states, "there is no woody vegetation present on the site to be affected" The site does <br />contain woody vegetation. During a recent site visit, CDOW noted the presence of several woody <br />species includmg those species listed in Exlvbit J. We would encourage the applicant to :.'I- <br />evaluate the vegetation and provide for woody replacement of like species and quantity as is <br />presently on-site. <br />The current mining plan stipulates a maximum of 40 acres at any one time. However, the <br />application is unclear is describing a timaable for reclamation Exhbit D, section (e) of the <br />mining plan states that reclamation will occur 2-3 years a&er sufficient operating room is created. <br />Exhrbif D, section (e) subsection (L) states that 10-15 years ofn>ming is required before <br />reclamation can commence. In 6.4.5 Exhibit E -Reclamation P]an, section 2(ex~) states that <br />reclamation is estimated to begin within 1-3 years and be completed 5 years after mining is <br />complete- The lack of clarity in the application make it difficult to comment specifically, but <br />CDOW would recommend limiti[tg total disturbance to 40 acres and implementing <br />sequenttal/concurreat reclamation. <br />CDOW has serious concerns as to whether the current reclamation plan can achieve the :;riteria of <br />establishing a diverse, effective and long-lasting vegetative cover. On the contrary, CDGW <br />anticipates a severe degradation of ]and productivity resulting from the proposed action. The <br />DEPARTMENT OF NATURAL RESOURCES, James 5. Lochhead, Executive Director <br />WILDLIFE COMMISSION, Arnold Salazar, Chairman .Rebecca L. Frank, Vice Chair • Mark LeValley Secretary <br />Louie F. Swift. Member • Jesse Langston Boyd, Jr., Member <br />William R. Hogberg, Member • John Stulp, Member • James R. Long. Member <br />