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STATE OF COLORADO Bill Owens, Governor DEPARTMENT OF NATURAL RESOURCES DIVISION OF WILDLIFE AN EQUAL OPPORTUNnY EMPLOYER RECEIVED JUL 0 8 2002 Divisron of Minerals d Geology For Wsddlafe- ForPeople Russell George, Director 6060 Broadway Denver, Colorado 8D216 Telephone: (303)297-1192 West Regional Service Center 711 Independent Avenue Grand Junction, CO 81505 970-255-6111 June 28, 2002 Mr, Micheal Boulay Division of Minerals and Geology Department of Natural Resources 1313 Sherman Street, Room 215 Denver, CO 80203 Dear Mr. Boulay: [~i~„ Thank you for the opportunity to provide comments on the Seneca II-W Mine Permit Revision Application No. 3 (PR-3). On May 20, Colorado Division of Wildlife (DOW) personnel met with you and two mine employees to tour the proposed expansion area of the Seneca II-W South azea. We appreciate very much the opportunity to conduct a site visit. Comparison of Table 10-7 in the Permit Revision application to the original Table 10.7 indicates that the mine expects that the Seneca II-W Permit Revision azea will disturb an additiona194.4 acres of aspen forest, 18.7 acres of mountain brush, and 47.6 acres of sagebrush/snowberry. All of these community types are important habitat for wildlife. Along with riparian areas, aspen communities are considered one of the most biologically diverse community types in the Intermountain West. The Division of Wildlife estimates that 111 species in Routt County utilize aspen stands. It is highly unlikely that the mine will be able to reclaim the mined area to a similar aspen forest. Aspen stands are largely dependent on the soil moisture conditions of a particular site. After discussion with the mine reclamation specialist, it is clear that surface mining of the area would completely alter the groundwater hydrology, thus making aspen growth difficult, In addition, personnel toured an aspen revegetation site where aspen tublings were planted several years ago (3-6 years). Most, if not all, of the tublings were less than 12 inches high. It was also interesting to note that the aspen stand immediately adjacent to the aspen revegetation area appeared to be decadent with several old and dying trees. The adjacent stand might benefit from a habitat treatment such as a prescribed burn in an attempt to regenerate the stand. The DOW believes that it is unreasonable to expect that the mine will be able to restore an aspen forest and that it thus constitutes a permanent loss of wildlife habitat. Therefore, we request that the mine mitigate this permanent loss through off-site mitigation. One possibility would be for the mine to conduct habitat treatments to improve similar aspen stands elsewhere on their property. The DOW would be happy to work with the mine to plan some of these treatments. DEPARTMENT OF NATURAL RESOURCES, Greg E. Walther, Executive Director WILDLIFE COMMISSION, Rick Enstrom, Chair • Robert Shoemaker, Uce-Chair • Marianna Raftopoulos, Secretary Members, Bernard Black • Tom Burke • Jeffrey Crawford • Philip James • Brad Phelps • Olive Valdez Ex-Officio Members, Greg E. Walther and Don Ament