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Proper reclamation, from a wildlife perspective, involves not only stabilizing the soil and <br />establishing ground cover, but fostering plant communities with a diversity of species and plant <br />types (grasses, woody plants, and broadleaf forbs) that will fully serve the nutritional needs of <br />wildlife. It is our recommendation that the project proponent identify both short and long -term <br />goals for the implementation of its reclamation plan including the use of a phased or incremental <br />approach to reclamation instead of waiting for maximum build out. These goals should include <br />identifying properly executed construction practices, optimum scheduling, erosion and <br />sedimentation control, protection of water resources and soils, and a return to pre- existing and <br />uses and vegetative cover. A monitoring program during construction and operational phases will <br />ensure that goals are achieved. in light of the critical importance of this habitat to wildlife, <br />conversion to another habitat type is not desirable and would result in significant, long term, <br />negative effects. <br />Establishment of woody vegetation might be difficult due to a thin topsoil horizon and heavy elk <br />and deer use and measures to protect soil and plants during establishment will be needed. It is <br />imperative that the post - reclamation vegetation provide appropriate winter nutrition for elk as well <br />as year -round food and cover resources for all wildlife. Mountain shrub communities are most <br />productive for wintering elk when the oak shrub diameters are less than 1" and 4 -5 ft, in height. <br />This vegetation condition of oak brush often has the highest diversity of other shrub species, <br />grasses and forbs, and is among the most productive for wildlife. It is widely believed that the <br />forage to cover ratio for wintering elk should be about 60:40 to maintain optimal habitat <br />conditions. <br />CPW would like to work with BIO -Logic Inc. to ensure the proper native vegetative components <br />(i.e. grass, forb, shrub) are present and suitable species composition /proportion are the result. <br />CPW has developed native seed mixtures for western Las Animas County which have proven <br />successful. CPW respectfully requests more detail on the project's reclamation and revegetation <br />plan. All details are appreciated; however, our primary concerns are the following: ' <br />• Topsoil removal, storage, and protection <br />• Design of incremental approach to reclamation <br />• Seed mix for seeding efforts (forbs and grasses) <br />• Shrub component of revegetation <br />• Timing of revegetation activities <br />• Protection of vegetation <br />• Weed management plan <br />• Erosion control plan <br />• Post- construction monitoring plan <br />It is unclear if the project will require additional roads, power lines or fencing. Roads fragment <br />habitat and can increase runoff and erosion from a site. Power lines have the possibility of <br />electrocuting perching raptors. CPW recommends that you consult the US Fish and Wildlife <br />Service's Avian Protection Plan for best management practices regarding power lines. Fencing <br />also has the potential to harm wildlife and disrupt movement. Attached are wildlife - friendly fence <br />designs which will help minimize their impacts on wildlife. Please expand on the project's need <br />for new infrastructure and what efforts will be implemented to avoid, minimize and mitigate <br />negative impacts. <br />The proximity of this location to the Purgatoire River raises concerns about increased stream <br />sedimentation and declines in water quality that could result from erosion and runoff from the <br />RDA. The fishery and habitat resources on the river could be compromised should there be <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 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: Mike King and John Salazar <br />