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AMC <br />May 17, 2010 <br />To: <br />Division of Reclamation, Mining and Safety 3"VE <br />101 So. 3rd St., Suite 301 <br />Grand Junction, CO 81501 JUN 0 1 2010 <br />Attn: Dustin Czapla OtvAksa of RocWm#Aon, <br />LftV nd r <br />RCFMAY 1 2116 <br />- /986 (AM re4 ) <br />Response to Comments on the Lyons Pit No. 2, File No. M-1980-248. made by Bill <br />deVerizie, Area Wildlife Manager, Meeker Service Center, Division of Wildlife, dated <br />May 7, 2010 <br />Submitted by Marvin Moore (Consultant to the Moffat County Commissioners) <br />Dustin: <br />Thanks for sending the Division of Wildlife's comments on the above referenced Lyons <br />Pit Amendment No. 2. <br />I am a private contractor, and the records in your office will show that I have been doing <br />Moffat County's Mined Land Reclamation Permits for 22 years. The Lyons Pit No. 2 <br />(Permit M-80-248) was transferred to Moffat County by Revision No. SO-01 on April <br />18, 1989; we filed a Revision application for a 112 Permit in December of 1990; Moffat <br />County received a permit approval for Amendment No. 1 in January of 1998; and we <br />have received reclamation releases along the way. <br />Now, in our permit application for the Lyons Amendment No. 2, the Division of Wildlife <br />has provided a broad list of recommendations for approval of our permit, including a <br />recommendation for a seasonal closure on the gravel mining operation from January 1, to <br />March 31. I will make the following response. <br />The Division of Wildlife's list of comments contains eight paragraphs, the first of which <br />is the introduction paragraph. Paragraphs #2 thru #5, and #7 thru #8 are statements of <br />broad speculation and conjecture that do not apply specifically to the Lyons Pit No. 2 <br />Amendment operation. <br />Paragraph No. 6 states: "The gravel pit lies in an area where native vegetation provides <br />foraging, nesting, and cover habitats for numerous species of wildlife. The removal and <br />disturbance of native vegetation for the construction of the above gravel pit and <br />associated roads will negatively impact the native wildlife species associated with this <br />project area. Upon rehabilitation of gravel pit, negative impacts to native wildlife can be <br />offset by planting a suitable mixture of native grass/forb/shrub seed. Seed plantings on <br />disturbed soils will have greater germination and survival rates when the soil surface has <br />been prepared to hold moisture and runoffprecipitation. "