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.- • <br />STATE OF COLORADO <br />Rfehard D. Lamm, Governor <br />DEPARTMENT OFNATURAL RESOURCES <br />DIVISION OF WILDLIFE <br />Jack R. Grieb, Director <br />6060 Broadway <br />Denver, Colorado 80216 (825-1192) <br />III IIIIIIIIIIIII III i <br />999 <br />February 26, 1980 <br />TO <br />FROM: <br />RE: <br />James B. McArdle <br />Mined Land Reclamation Staff <br />C.J. GrandPre <br />Senior Wildlife Biologist <br />SS .. rte;' , ~ _ 4 CAV ~ ~. <br />-~ ~ I:jJ <br />COIL. DCa1..^. '1''['Ci..! ;r ., - _. _.. ., <br />Three Bells Ranch Mining Application No. 79-191 <br />We have reviewed the above cited application and find that several items <br />need further consideration. <br />It is our opinion that the wildlife section (H) has been treated far to <br />lightly. Riparian ecosystems are the singular most important wildlife <br />habitat type in Colorado. It represents only 0.2% of all vegetative <br />types and yet supports approximately 50% of all avian wildlife species <br />and 1/3 of all mammalian species. We feel Chat a detailed site specific <br />wildlife inventory is necessary. <br />We disagree with the statements that "mining and reclamation will have <br />no significant negative impact upon Golorados' wildlife" and that <br />"reclamation will greatly improve and enrich the areas wildlife potential". <br />A critical review of the reclamation plan seems to indicate that just <br />the opposite may be true. <br />Of a more specific note, let me point out further areas of discrepancy <br />and deficiency. <br />First, the applicants state that they intend to fill all marshes, low <br />lying areas, seeps, etc. We feel this violates the intent of section 404 <br />of the Clean Water Act. An on-site wetland determination by the U.S. <br />Corps of Engineers should be required. These areas provide essential <br />wildlife habitats, reduce flood damage and aid in the purification of water. <br />We cannot approve the filling of any wetland or marshy area. <br />Second, it is unclear how many acres are actually involved in this operation. <br />Figures range from 240 to 360. <br />Third, it is stated that all topsoil not to be used for blending with road <br />gravel will be used for reclamation. The use of topsoil for road materials <br />should not dictate reclamation, but vice versa. <br />DEPARTMENT OF NATURAL RESOURCES, Harris Sherman, Executive Director • WILDLIFE COMMISSION, Michael Higbee, Chairman <br />Wilbur Redden, Vice Chairman • Sam Caudill, Secretary Jean K. Tool, Member Vernon C. Williams, Member <br />James Smith, Member • Donald Fernandez, Member Richard Divel biss, Member <br />