2008-05-29_REVISION - M1980244 (3)

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?lA) STATE OF COLORADO r Bill Ritter, Jr., Governor DEPARTMENT OF NATURAL RESOURCES DIVISION OF WILDLIFE AN EQUAL OPPORTUNITY EMPLOYER Thomas E. Remington, Director 6060 Broadway Denver, Colorado 80216 Telephone: (303) 297-1192 wildlife. state. co. us May 16th, 2008 Mr. Berhan Keffelew Division of Reclamation, Mining and Safety anW RECEIVED AY 2 91008 Division of Reclamation, .?o Mining and Safety ?flM?9 C sr0?'OF44yq For Wildlife- For People 1313 Sherman St., Room 215 Denver, CO 80203 RE: Cripple Creek & Victor Gold, Cresson Project, Permit No. M-1980-244_ Dear Mr. Keffelew: The Colorado Division of Wildlife (DOW) appreciates the opportunity to comment on this proposed expansion by the mine. Considering the scope of this project, it is likely that the associated impacts to a variety of wildlife species will be severe during the actual earth-moving and mining process. In particular, large portions of habitat (i.e. dense conifer stands) that provide escape and thermal cover to mule deer and elk will be completely removed. Raptors, small mammals, and a variety of bird species will also be displaced. While these types of mining activities can displace wildlife, we have found that proper mitigation and reclamation measures made within disturbed areas can be beneficial. Surprisingly, healthy mule deer and elk herds reside on and near the existing mines in the Cripple Creek area, and are adapting quite well to the on-going mining activities. DOW staff are familiar with the proposed Cresson Project site and are encouraged by some of the past successes that the mine has had with other reclamation efforts, especially for mule deer and elk. DOW staff have reported large concentrations of elk congregating on reclaimed hill sides of the mine, especially during winter months. The Division recommends that Best Management Practices are incorporated into any mining operations, and offers the following site-specific comments: 1. The mine's environmental coordinators have suggested maintaining and/or improving areas on the mine to enhance deer and elk migration routes. The DOW encourages this idea and suggests that trees that are removed from the disturbed areas (as many aspens and evergreens as possible) be transplanted to other sites on the mine. Areas interspersed with trees can provide visual cover for migrating big game, and they could also be used for other reclamation efforts. The Division can provide on-site consultation for specific areas that provide the most likely migration corridors. Any efforts to avoid these corridors will help minimize impacts to big game. 2. Reclamation efforts should concentrate on plantings of native species recommended by the Natural Resource Conservation Service. Noxious weeds can take over areas that are not properly reclaimed and should be actively controlled. -continued- DEPARTMENT OF NATURAL RESOURCES, Harris D. Sherman, Executive Director WILDLIFE COMMISSION, Tom Burke, Chair • Claire O'Neal, Vice Chair • Robert Bray, Secretary Members, Dennis Buechler • Brad Coors • Jeffrey Crawford • Tim Glenn • Roy McAnally • Richard Ray Ex Officio Members, Harris Sherman and John Stulp