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STATE OF COLORADO <br />John W. Hickenlooper, Governor <br />DEPARTMENT OF NATURAL RESOURCES <br />DIVISION OF WILDLIFE <br />AN EQUAL OPPORTUNITY EMPLOYER <br />Thomas E. Remington, Director <br />RECEIVED For Wildlife- <br />6060 Broadway <br />Denver, Colorado 80216 For People <br />Telephone: (303) 297-1192 MAY j 3 2011 <br />wildlife. state. co. us <br />GRAND JUNG; i luir ritLi) OFFICE <br />May 5, 2011 DIVISION OF <br />RECLAMATION MINING & SAFETY <br />Glenn Williams <br />Cotter Corporation <br />PO Box 700 RECEIV <br />Nucla, CO 81424 <br />MAY 2 4 2071 <br />Re: JD-8 Mine, amending original 112 permit #M-1984-014 ?t P?? <br />? Division of Reclamation, <br />Alining and Safety <br />Dear Mr. Williams, <br />Thank you for the opportunity to comment on the proposed JD-8 Mine in Montrose County. <br />We have reviewed the location of the proposed mine. The mine lies within mapped severe winter range for elk, <br />and mapped winter range for mule deer. Small numbers of mule deer and elk are in the area throughout the year. <br />The effects on these animals could be significant if new roads are established and habitat is destroyed. <br />Mule deer and elk are particularly susceptible to disturbance during winter months, and the CDOW is concerned <br />that the direct loss of approximately 12 acres of severe winter range and winter range for mining operations, when. <br />added to the cumulative loss of severe winter range from other development activities in the area, could affect <br />mule deer and elk populations. In order to maintain existing mule deer and elk populations, the CDOW is <br />recommending that companies such as Cotter Corporation incorporate off-site habitat enhancement projects into <br />their operations to compensate for the direct loss of severe big game winter range that is associated with their <br />projects. <br />There also could be an indirect loss of severe winter range for mule deer and elk in areas surrounding the mine <br />due to a decrease in the use of these habitats associated with a general increase in traffic and human activity. In <br />- -order-to-maintain-mule deer and elk winter use of the area_surrounding_the_mine,_the_CDOW suggests _ _ <br />implementing seasonal closures on mining activities between the months of December and April when the largest <br />concentrations of wintering mule deer and elk are in the area. If seasonal traffic and mining operation closures are <br />not possible, CDOW suggests performing additional off-site habitat enhancement projects to offset the added <br />indirect impacts to wintering big game use of severe winter range. <br />There are approximately 10 different species of bats that inhabit the area. One species in particular, the <br />Thompsons Big Eared Bat, is considered a species of special concern in Colorado. Active mines have been <br />shown to have little to no impact on bats due to continuous human activity in and around active mines. However, <br />inactive mines are often used by bats as either winter roost sites or summer breeding areas. Many of these <br />inactive mines have "bat gates" on them, allowing bats access and denying human disturbance. If bat gates are <br />encountered on any mine shafts, the CDOW strongly suggests contacting our field personnel to determine the <br />time of year bats inhabit the area, and potentially creating seasonal mining closures. <br />DEPARTMENT OF NATURAL RESOURCES, Mike King, Executive Director <br />WILDLIFE COMMISSION, Tim Glenn, Chair • Robert Streeter, Vice Chair • Mark Smith, Secretary <br />Members, David R. Brougham • Dorothea Farris • Allan Jones • Gaspar Perricone • John Singletary • Dean Wingfield <br />Ex Officio Members, Mike King and John Salazar <br />GO??O ? <br />y <br />OF <br />sro? ?,y4 <br />-* 5 U C2