2011-02-15_REVISION - C1981041 - Laserfiche WebLink

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STATE OF COLORADO John W. Hickenlooper, 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 Division of Reclamation, Mining and Safety Attn: Michael P. Boulay, Environmental Protection Specialist 1313 Sherman St., Room 215 Denver, CO 80203 RE- CE IED FEB 15 2011 u1v1,,1_.. .. __jamaton, Mining and Safety r ?r y4 O OF `? For Wildlife- For People February 10, 2011 RE: Roadside Portals (Permit No. C-1981-041) Technical Revision Application No. 60 (TR7.60) Change to Revegetation Success Criteria. Dear Mr. Boulay: Thank you for the opportunity to comment on the Roadside Portals (Permit No. C-1981-041) Technical Revision Application No. 60 (TR-60) Change to Revegetation Success Criteria request. The Colorado Division of Wildlife (CDOW) has reviewed the change requested by the Snowcap Coal Company and offers the following comments. The CDOW believes that a blanket change to the revegetation reclamation standards is not appropriate and that there are -opportunities, when intensive site specific strategies are employed, that can result in reclamation that meets the original reclamation success criteria. The CDOW also believes that it would result in a better overall reclamation outcome if the project were revisited to identify site specific locations that will be highly likely to be unsuccessful and target proposed changes based on the specific site needs. The CDOW recognizes the invasive nature of cheatgrass and the harmful effect it can have on native vegetation communities especially those in arid, low elevation, south facing locations. CDOW has witnessed numerous industrial reclamation projects that have struggled to meet reclamation standards; however, CDOW has also observed projects with site specific emphasis prove reasonably successful. The wildlife habitat on the Snowcap Coal property and surrounding land is ideal for Rocky Mountain bighorn sheep; the west bank of the Colorado River, the bottoms and side walls of Main and Coal Canyon provide sheep with winter range, winter concentration areas, and production (lambing) areas. These habitats are both inside and outside of the Snowcap Coal Company permit boundary. The herd living in and using Main and Coal Canyons and the Colorado River Corridor is a recently reintroduced herd and its numbers are stable. The habitats in the area are used year round and maintaining or improving them is important for on-going and long term success. Also, this herd is significant because it is one of only a few low elevation Rocky Mountain Bighorn Sheep herds in Colorado. The CDOW has completed bighorn sheep, habitat improvement projects adjacent to the Snowcap Coal property: We intend to continue to improvement projects and have a specific interest in maintaining and improving habitat in Main Canyon and at'the mouth of the canyon at the C_ olorado River. ' ?. ` DEPARTMENT OF NATURAL RESOURCES, Mike King, Executive Director WILDLIFE COMMISSION, Tim Glenn, Chair • Robert Streeter, Vice Chair • Mark Smith, Secretary Members, David R. Brougham • Dennis Buechler* Dorothea Farris • Allan Jones • John Singletary • Dean Wingfield Ex Officio Members, Mike King and John Salazar