Laserfiche WebLink
CPW Gunnison Area Office <br />300 New York Avenue <br />Gunnison, CO 81230 <br />July 29, 2011 <br />Dear Mr. Kaldenbach, <br />COLORADO PARKS AND WILDLIFE <br />1313 Sherman Street, Room 618 • Denver, Colorado 80203 <br />Phone (303) 866 -3437 • FAX (303) 866 -3206 <br />wildlife.state.co.us • parks.state.co.us <br />Tom Kaldenbach <br />Colorado Division of Reclamation, Mining and Safety <br />Office of Mined Land Reclamation <br />1313 Sherman St. Room 215 <br />Denver, CO 80203 <br />JUL 2 9 2011 <br />Division or " C4amation, <br />Mining and Safety <br />Colorado Parks and Wildlife (CPW) appreciates the opportunity to provide comments on <br />the Mountain Coal Company West Elk Mine Technical Revision Application (TR125). <br />Parks and Wildlife staff have reviewed the Historical Record Study Area (HRSA) <br />vegetation and precipitation characterization (2010) West Elk Mine prepared by Savage <br />and Savage. It is our understanding the MCC intends to modify the success criteria for <br />reclamation standards in the mine permit for the entire mine permit boundary based in <br />part on the HRSA monitoring. Per conversations with Kathy Welt, our understanding is <br />that MCC is specifically seeking a modification of our December 10, 1981 Memorandum <br />(MEMO) to DMRS that sets the shrub density standard for reclamation at 1000 stems/ <br />acre. <br />In general, the justification and rational in the MEMO outlining the importance of <br />mountain shrubs to wildlife are still applicable today. Mountain shrub and sagebrush <br />habitat are very import to wildlife in Colorado throughout the year. However, they <br />become increasing important to wintering wildlife especially deer and elk. In the winter, <br />shrubs may compose up to 57% of an elk's diet. Mountain shrub communities are most <br />productive for wintering elk when the oak shrub diameters are less than 1" and 4 -5 ft in <br />height. This vegetation condition of oak brush often has the highest diversity of other <br />shrub species, grasses, and forbs, and is among the most productive wildlife habitat. <br />It is widely believed that the forage to cover ratio for wintering elk should be about 60:40 <br />to maintain optimal habitat conditions. If the 60:40 forage to cover ratio is currently <br />being met within the mine permit boundary, then CPW supports modifying the MEMO to <br />forgo the recommended shrub density standard within the West Elk Mine permit <br />boundaries. Note that we support a modification of this standard only on a site - specific <br />STATE OF COLORADO <br />John W. Hickenlooper, Governor • Mike King, Executive Director, Department of Natural Resources <br />Rick D. Cables, Director, Colorado Parts and Wildlife <br />Parks and Wildlife Board: David R. Brougham • Gary Butterworth, Vice -Chair • Chris Castilian <br />Dorothea Farris • Tim Glenn, Chair • Allan Jones • Bill Kane • Gaspar Perricone • Jim Pribyl • John Singletary <br />Mark Smith, Secretary • Robert Streeter • Lenna Watson • Dean Wingfield <br />Ex Officio Members: Mike King and John Salazar <br />