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Karen Fischer <br />O'Connor Design Group <br />2350 G Road <br />Grand Junction, CO 81505 <br />June 19, 2012 <br />COLORADO PARKS & WILDLIFE <br />2300 S. Townsend Avenue • Montrose, Colorado 81401 <br />Phone 970 252 -6000 • FAX 970 252 -6053 <br />wildlife.state.co.us • parks.state.co.us <br />7 <br />Re: CM -25 Mine, Cotter Corporation <br />Dear Ms. Fischer <br />Thank you for the opportunity to comment on the proposed CM -25 Mine in Montrose County. <br />The Colorado Parks and Wildlife (CPW) has reviewed the location of the proposed mine. The <br />mine lies within winter range and severe winter range for both mule deer and elk. Mule deer and <br />elk are found in the area during the winter months, specifically December through April. 'With <br />the increased activity around the CM -25 Mine, activity may cause an increased disturbance to <br />wintering animals when they are particularly susceptible. As the mining plan states; "must <br />extract less than 70,000 tons of mineral, overburden or combination thereof per calendar year." <br />This could cause a direct and indirect loss of severe winter range for both mule deer and elk in <br />areas surrounding the mine due to a decrease in the use of these habitats associated with a general <br />increase in traffic and human activity. <br />In order to maintain mule deer and elk winter use of the area surrounding the mine, the CPW <br />suggests implementing daily timing restrictions on mining activities between the months of <br />December and April when the largest concentrations of wintering mule deer and elk are in the <br />area. Mule deer and elk are most active in the early morning and late evening, CPW recommends <br />limiting daily traffic and activity to 10:OOam- 3:OOpm. If seasonal traffic and mining operation <br />restrictions are not possible, CPW suggests performing off -site habitat enhancement projects to <br />offset the direct and indirect impacts to wintering big game use of severe winter range. <br />There are approximately 10 different species of bats that inhabit the area. One species in <br />particular, the Thompsons Big Eared Bat is considered a species of special concern in Colorado. <br />Active mines have been shown to have little to no impact on bats due to continuous human <br />activity in and around active mines. However, inactive mines are often used by bats as either <br />winter roost sites or summer breeding areas. Many of these inactive mines have "bat gates" on <br />them, allowing bats access and denying human disturbance. If bat gates are encountered on any <br />mine shafts, the CPW strongly suggests contacting our field personnel to determine the time of <br />year bats inhabit the area. <br />There are several existing roads in the area, and the CPW recommends improving existing roads <br />and using those to access the mine sites versus creating new roads. This would help to minimize <br />habitat fragmentation as well as disturbance to existing wildlife. <br />With the increased human activity at the CM -25 Mine, the spread and control of noxious weeds <br />becomes a concern for wildlife. Invasive plants endanger the ecosystem by disturbing natural <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: Mike King and John Salazar <br />