2009-01-02_REVISION - M1978222UG

Home Browse Search

STATE OF COLORADO 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 16, 2008 Linda "Sue" Carter Nuvemco, LLC 10771 3200 Road Hotchkiss, CO. 81419 Re: Monogram Mine and Monogram Jo Dandy Mine Dear Ms. Carter, sro? OF ?y4 For Wildlife- For People Thank you for the opportunity to comment on the proposed Monogram and Monogram Jo Dandy Mines in Montrose County. We have reviewed the location of the proposed mine. The mine is in severe winter range for mule deer and elk. Mule deer and a small number of elk are in the area throughout the year. The proposed mine is also within the range of a population of desert bighorn sheep which inhabit the area year round. The effects on these animals could be significant if new roads are established and habitat is destroyed. Mule deer and elk are particularly susceptible to disturbance during winter months, and the CDOW is concerned that the direct loss of about 10 acres for each of the mines of severe winter range for mining operations, when added to the cumulative loss of severe winter range from other development activities in the area, could affect mule deer and elk populations. In order to maintain existing mule deer and elk populations, the CDOW is recommending that companies such as Nuvemco, LLC incorporate off-site habitat enhancement projects into their operations to compensate for the direct loss of severe big game winter range that is associated with their projects. There also could be an indirect loss of severe winter range for mule deer and elk in areas surrounding the mine due to a decrease in the use of these habitats associated with a general increase in traffic and human activity. In order to maintain mule deer and elk winter use of the area surrounding the mine, the CDOW suggests implementing seasonal closures on mining activities between the months of December and April when the largest concentrations of wintering mule deer and elk are in the area. If seasonal traffic and mining operation closures are not possible, CDOW suggests performing additional off-site habitat enhancement projects to offset the added indirect impacts to wintering big game use of severe winter range. There are approximately 10 different species of bats that inhabit the area. One species in particular, the Thompsons Big Eared Bat is considered a species of special concern in Colorado. Active mines have been shown to have little to no impact on bats due to continuous human activity in and around active mines. However, inactive mines are often used by bats as either winter roost sites or summer breeding areas. Many of these inactive mines have "bat gates" on them, allowing bats access and denying human disturbance. If bat gates are encountered on any mine shafts, the CDOW strongly suggests contacting our field personnel to determine the best course of action. DEPARTMENT OF NATURAL RESOURCES, Hams D. Sherman, Executive Director WILDLIFE COMMISSION, Tom Burke, Chair • Claire O'Neal, Vice Chair • Robert Bray, Secretary Mamharc rlannie Ri iarrhlar • Rrnri r.nnre • - laffmv r.raw6nrri • Tim rlann • Rnv MrAnally a Rirharri Rav