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April 6, 2012, Karen Fischer O'Connor Design Group 2350 G Road Grand Junction, CO 81505 COLORADO PARKS & WILDLIFE 2300 S. Townsend Avenue • Montrose, Colorado 81401 Phone 970 252 -6000 • FAX 970 252 -6053 wildlife.state.co.us • parks.state.co.us STATE OF COLORADO John W. Hidcenlooper, Governor • Mike King, Executive Director, Department of Natural Resources Rids D. Cables, Director, Colorado Parks and Wildlife Parks and Wildlife Commission: David R Brougham • Gary Butterworth, Vice -Chair • Chris Castilian Dorothea Farris • Tim Glenn, Chair • Allan Jones • Bill Kane • Gaspar Perrioone • Jim Pribyl • John Singletary Mark Smith, Secretary • Robert Streeter • Lenna Watson • Dean Wingfield Ex Officio Members: Mike King and John Salazar Re: SM -18 Mine, Cotter Corporation Dear Ms. Fischer Thank you for the opportunity to comment on the proposed SM -18 Mine in Montrose County. We have reviewed the location of the proposed mine. The mine lies within winter range and severe winter range for both mule deer and elk. Mule deer and elk are found in the area during the winter months, specifically December through April. Although the property owned by Cotter Corporation is already developed with roads, trailers, compressor shed, warehouse, fuel storage tank, and electrical utilities, the increased activity around the SM -18 Mine may cause an increased disturbance to wintering animals when they are particularly susceptible. As the mining plan states, when functioning at full capacity the mine will be capable of producing 50 -350 tons of material daily. This could cause a direct and indirect loss of severe winter range for both mule deer and elk in areas surrounding the mine due to a decrease in the use of these habitats associated with a general increase in traffic and human activity. In order to maintain mule deer and elk winter use of the area surrounding the mine, the Colorado Parks and Wildlife (CPW) suggests implementing daily timing restrictions on mining activities between the months of December and April when the largest concentrations of wintering mule deer and elk are in the area. Mule deer and elk are most active in the early morning and late evening, CPW recommends daily limiting traffic and activity to 10:00am- 3:OOpm. If seasonal traffic and mining operation restrictions are not possible, CPW suggests performing off -site habitat enhancement projects to offset the direct and indirect impacts to wintering big game use of severe winter range. There are approximately 10 different species of bats that inhabit the area. One species in particular, the Thompsons Big Eared Bat is considered a species of special concern in Colorado. Active mines have been shown to have little to no impact on bats due to continuous human activity in and around active mines. However, inactive mines are often used by bats as either winter roost sites or summer breeding areas. Many of these inactive mines have "bat gates" on them, allowing bats access and denying human disturbance. If bat gates are encountered on any mine shafts, the CPW strongly suggests contacting our field personnel to determine the time of year bats inhabit the area. There are several existing roads in the area, and the CPW recommends improving existing roads and using those to access the mine sites versus creating new roads. This would help to minimize habitat fragmentation as well as disturbance to existing wildlife.