2012-03-07_PERMIT FILE - C2010088 ‎(17)‎

• Permit No: C2010088
• IBM Index Class Name: Permit File
• Doc Date: 3/7/2012
• Doc Name: Letter
• Section_Exhibit Name: Exhibit 08
• Media Type: D
• Archive: No

STATE OF COLORADO
GOO
Bill Ritter, Jr., Governor
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF .WILDLIFE
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AN EQUAL OPPORTUNITY EMPLOYER
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Thomas E. Remington, Director
OF
6060 Broadway
For Wildlife -
Denver, Colorado 80216
For People
Telephone: [phone]
wildiffe.state.co.us
Northwest Region Service Center
711 Independent Avenue
Grand Junction, CO 81505
(970) 255 -6100
Wildlife West, LLC July 16, 2010
Attn.: Mr. Van K. Graham
3245 Applewood St.
Grand Junction, CO 81506
Dear Mr. Graham,
The Colorado Division of Wildlife has reviewed your draft baseline wildlife studies of the
McClane Canyon Coal Mine waste rock disposal site /storage area and of the coal loadout
facility. Since the reports did not address operational details of -the coal mine expansion, our
comments are limited to the evaluation of the biological data collected.
In. general, we feel that the wildlife occu&ence-data related to terrestrial wildlife was well
done. Your conclusions regarding the current state of the vegetative community are accurate.
We feel that the aquatic portion *of these reports should be updated to include more detail on
species occurrence and abundance, along with anticipated impacts related to water quality due
to expanded operations. The Division most recently addressed the water quality issue in
correspondence with the Colorado Division of Reclamation, Mining & Safety in August, 2008
related to the McClane Canyon coal mine TR -16 application. The concerns raised in that letter
remain valid.
We feel that the utilization by bats of an historic mine site within the proposed waste rock
disposal area needs further study. We suspect that the site could be a maternity roost. We
are unable to assess development impacts without knowing which species utilize the cave, and
the extent of that use. Utilization of that habitat feature by rare or sensitive bat species would
elevate our level of concern over disturbance of that site. We are aware of occurrence data
for Townsend's big -eared bats and big free - tailed bats, both BLM Sensitive Species, from
locations along the Bookcliffs. Those species were not observed. in the. Chung /Maccoubrey
study. Multiple species of bats use rock crevices for roosting, and we recommend minimizing
- disttrbance of that,habitat. Hoary bats and silver - haired bats utilize mature cottonwoods for
roosting, and we recommend protection of that habitat type.
The conclusions drawn in the report cohcerning-deer and:elk� use* z re"c- bnsistentwith our staff's
knowledge of the area. Chukar; rabbits, bobcat; and coyote are the most common small game
DEPARTMENT OF NATURAL RESOURCES, Mike ling, Executive Director
WILDLIFE COMMISSION, Tim Glenn, Chair • Robert Streeter, Vice Chair • Mark Smith, Secretary
Members, David R. Brougham • Dennis Buechler • Dorothea Farris • Allan Janes • John Singletary • Dean Wingfield
Ex Officio Members, Mike IGng and John Stulp