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November 8, 2011 <br />Shawn Conner, Ecologist <br />BIO- Logic, Inc. <br />635 E. Main St., Suite 100 <br />Montrose, CO 81401 <br />COLORADO PARKS & WILDLIFE <br />4255 Sinton Rd • Colorado Springs, Colorado 80907 <br />719- 227 -5200 <br />wildlife.state.co.us • parks.state.co.us <br />To: Shawn Conner, Ecologist, BIO -Logic Inc. <br />Re: Biological Resource Assessment for a new Refuse Disposal Area (RDA) being proposed <br />at the New Elk Coal Mine west of Trinidad <br />The Colorado Division of Parks and Wildlife (CPW) appreciates the chance to comment on the <br />proposed Refuse Disposal Area (RDA) at the New Elk Coal Mine west of Trinidad. CPW realizes <br />the importance of open communication between energy developers and wildlife managers if we <br />are to have success in both arenas. We will address a few concerns regarding details of the . <br />proposed project; however, we would like to first discuss the wildlife and habitat values of the land <br />that would be impacted by the RDA at the proposed site. - <br />The value of this area to wildlife cannot be understated. Mountain shrub habitat is very important <br />for wildlife in Colorado throughout the year, and in wini;er, may comprise up to 57% of an elk's <br />diet. This particular area serves as critical winter range and winter concentration area for deer <br />and elk and provides excellent food and cover resources for a variety of wildlife year -round <br />including black bear, wild turkey, raptors, songbirds and other wildlife. Due to a south - facing <br />aspect, a lack of dark timber and productive stands of oak brush and mountain mahogany, this <br />area can support large concentrations of elk in severe winter conditions. <br />This area west of Trinidad has seen an increase in habitat fragmentation due to methane and <br />subdivision development and this trend is expected to continue. Wildlife /human conflicts have <br />increased significantly and will be exacerbated by further fragmentation and displacement. In <br />addition to the habitat concerns, this area is a known wildlife migration corridor /highway crossing. <br />Given the high wildlife utilization of this and adjacent properties, consideration should be given to <br />both animal and human safety within the project area. <br />The potential impacts to wildlife associated with this proposed project need to be properly <br />investigated and analyzed for CPW to adequately review and comment on the proposed actions. <br />This review should include an assessment of the project's impacts to both terrestrial and aquatic <br />wildlife habitat, wildlife movement, and human wildlife interactions. Mitigation measures should <br />be included in this analysis and must address the sequencing of efforts (avoidance, minimization <br />and mitigation of loss) that will be implemented to reduce impacts on fish and wildlife resources. <br />Plans regarding mitigation for the Toss of winter range and reclamation of the site were not <br />included in the initial Request for Consultation and are necessary for CPW to adequately review <br />this proposed action. CPW is most interested in reviewing and providing input on these specific <br />elements of the plan. <br />STATE OF COLORADO <br />John W. Hickenlooper, Governor • Mike King, Executive Director, Department of Natural Resources <br />Rick D. Cables, Director, Colorado Parks and Wildlife <br />Parks and Wildlife Commission: 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: Mke King and John Salazar <br />