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STATE OF COLORADO <br />Bill Ritter, Jr., Governor LO~~\ <br />DEPARTMENT OF NATURAL RESOURCES W <br />DIVISION OF WILDLIFE ~ -~ <br />AN EQUAL OPPORTUNITY EMPLOYER ~~~ OF ~~ <br />Thomas E. Remington, Director <br />6060 Broadway For ~ldlife- <br />Denver, Colorado 80216 For People <br />Telephone: (303) 297-1192 <br />wil dlife. state. co. us <br />December 7, 2007 <br />Linda Carter <br />Nuvemco, LLC <br />10771 3200 Road <br />Hotchkiss, CO.81419 <br />-- -----_ <br />-- - ~ e: - st ~ -ance ire, o aims" ari - ,-T8W; ec 1 ~ - "-- --- <br />Dear Ms. Carter, <br />Thank you for the opportunity to comment on the proposed Last Chance Mine in Montrose County. <br />We have reviewed the location of the proposed mine. The mine is in severe winter range for mule.deer and elk. <br />Mule deer and a small number of elk are in the area throughout the year. The proposed mine is also within the _ <br />range of a population of desert bighorn sheep which inhabit the area year round. The effects on these animals ' <br />could.be significant if new roans are established and habitat is destroyed. <br />Mule deer and elk are particularly susceptible to disturbance during winter months, -and the CDOW is concerned <br />that the direct loss of about 10 acres of severe winter range for mining operations, when added to the cumulative <br />loss of severe winter range from other development activities in the area, could affect mule deer and elk <br />populations. In order to maintain existing mule deer and elk populations, the CDOW is recommending that <br />companies such as Nuvemco, LLC incorporate off-site habitat enhancement projects into their operations to <br />compensate for the direct loss of severe big game winter range that is associated with their 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 shown <br />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; pn any mine shafts, the CDOW strongly suggests contacting our field personnel to determine the <br />time of year bits inhabit the area,.andpotentially creating seasonal mining closures <br />.. -: ~± _ _ <br />-... -. _, <br />DEPARTMENT OF NATURAL RESOURCES, Hams D. Sherman, Executive Director <br />WILDLIFE COMMISSION, Tom Burke, Chair • Gaire O'Neal, Vice Chair • Robert Bray, Secretary <br />Members, Dennis Buechler • Brad Coors • Jeffrey Crawford • Tim Glenn • Roy McAnally • Richard Ray <br />t_x Offiao Members, Harris Shemran and John Stuip <br />