2011-03-01_REVISION - M1977493 (6)

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Mr. Eric Scott Climax Mine - Response to DRMS Adequacy Review Comments Permit M-1977-493; Amendment AM-06 March 1, 2011 Page 6 of 16 isolated a significant distance away from Carbonate Hill. This information is discussed in detail in the lynx section of Exhibit H - Wildlife Information. As discussed in detail within Exhibit H - Wildlife Information, the open area on Carbonate Hill (as illustrated on Figure AM-06-H-01) is identified as an elk rearing area rather than a calving area. The vast majority of calving (if not all) occurs at lower elevations either on the winter range or in transit to summer ranges at CIVIC. CIVIC has been in operation for nine decades, and during that time elk have been observed throughout the property under all operating scenarios including the present disturbances within McNulty Gulch. Through communications with Mr. Sean Shepherd, District Wildlife Manager, Summit County West, and Lyle Sidener, Area Wildlife Manager, at the Colorado Division of Wildlife, CIVIC understands that the primary concern is the timing of any development that may occur along the Clinton Ditch corridor, identified by the linear extension of the affected land boundary across the Carbonate Hill area. This affected area extension was included to allow CIVIC to maintain this ditch if it becomes necessary; however, no development activities are currently planned within this corridor. If and when activity is planned for this area, CIVIC will plan and schedule the work to occur outside of the sensitive time frame of April 15 to June 30. In the event of a situation requiring emergency maintenance during this time frame, CIVIC will notify the CDOW regarding the scope and timing of this work. 5. To the maximum extent possible, access to process water by wildlife, especially water with high or low pH or elevated concentrations of heavy metals, should be • minimized. Throughout decades of operation, CIVIC process water with high or low pH or elevated metals has not been identified as a problem for wildlife. Wildlife species, including large mammals, waterfowl, and shorebirds are commonly observed using the various water bodies throughout the property without apparent harm. There are ten open water bodies, not including the adjacent Clinton Reservoir and Eagle Park Reservoir, on the Climax property available to wildlife that contain both process and fresh water. It is assumed that there is a tendency for wildlife to use the fresh water bodies since mortalities have not been observed to be an issue. As described to DRMS (then DMG) in 2005, CIVIC has implemented a program to observe and report any wildlife related problems or concerns. Employees undergo annual refresher training which discusses observations of site water bodies on a daily basis, how to report concerns if observed, and the importance of reporting observations promptly. This program has been in place for many years and will continue through renewed operations. As part of this program, Climax has worked with local CDOW personnel as necessary. Ongoing reclamation activities decrease the area of process water that wildlife may access, and staged water treatment between the SDP, Tenmile TSF and Mayflower TSF improve water quality in downstream areas, further minimizing potential impacts. Present on-going reclamation activities at Robinson Lake and on Robinson TSF are reducing present process water areas significantly. Reclamation and reduction of those areas where wildlife may contact process water are continuing activities that serve to minimize potential impacts.