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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 />CPW Gunnison Area Office <br />300 New York Avenue <br />Gunnison, CO 81230 <br />Brock Bowles <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 />—August 15, 2011 – <br />a ecetveo <br />M3G 1 9 2.01 <br />F 16ng end Safck► <br />Colorado State Parks <br />Dear Mr. Bowles, <br />Colorado Parks and Wildlife (CPW) appreciates the opportunity to provide comments on <br />the Oxbow Mining LLC, Elk Creek Mine Technical Revision TR 71 and TR72 <br />Applications. Parks and Wildlife staff have reviewed the proposals from the link <br />provided in your letters. It is CPW understanding that the projects include additional <br />and /or a change in gob bore vent hole locations. TR 71 modifications are to occur on <br />private land while TR72 work occurs on USFS lands. The project occurs mostly on <br />existing crude mine work roads with a few new segments constructed into new locations. <br />Additionally, CPW believe that the projects have a relatively short life span of use prior <br />to being reclaimed. <br />The majority of the mine work area is mapped as severe winter range for elk and winter <br />range for deer in almost all of working area. The habitat consists of oak dominated <br />mountain shrub community. Mountain shrub and sagebrush habitats are very important <br />to wildlife in Colorado throughout the year. However, they become increasing important <br />to wintering wildlife especially deer and elk. In the winter, shrubs may compose up to <br />57% of an elk's diet. Mountain shrub communities are most productive for wintering elk <br />when the oak shrub diameters are less than 1" and 4 -5 ft in height. This vegetation <br />condition of oak brush often has the highest diversity of other shrub species, grasses, and <br />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. CPW provided CDRMS guidelines for shrub <br />density in the December 10, 1981 Memorandum (MEMO) to DMRS that sets the shrub <br />density standard for reclamation at 1000 stems/ acre. CPW supports the use of this <br />standard for the Elk Creek Mine permit boundary. <br />STATE OF COLORADO <br />John W. Hickenlooper, Govemor • Mike King, Executive Director, Department of Natural Resources <br />Rick D. Cables, Director, Colorado Parks and Wildfire <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 />