2013-04-15_PERMIT FILE - M2013007

• Permit No: M2013007
• IBM Index Class Name: PERMIT FILE
• Doc Date: 4/15/2013
• Doc Name: Comments
• From: Colorado Parks & Wildlife
• To: DRMS
• Email Name: WHE
• Media Type: D
• Archive: No

April 9, 2013
Mr. Erickson,
COLORADO PARKS & WILDLIFE
2300 S. Townsend Avenue • Montrose, Colorado 81401
Phone [phone] • FAX [phone]
wildlife.state.co.us • parks.state.co.us
Wallace H. Erickson
Environmental Protection Specialist
Colorado Division of Reclamation, Mining and Safety
1313 Sherman St, Room 215
Denver, Colorado 80203
Re: Uncompahgre Pit, Rocky Mountain Aggregate, Colona, Colorado
STATE OF COLORADO
John W. Hickenlooper, Governor • Mike King, Executive Director, Department of Natural Resources
Rick D. Cables, Director, Colorado Parks and Wildlife
Parks and Wildlife Commission: Robert W. Bray • Chris Castilian • Jeanne Horne
Bill Kane, Vice-Chair • Gaspar Perncone • James Pribyl • John Singletary, Chair
Mark Smith, Secretary • James Vigil • Dean Wingfield • Michelle Zimmerman
Ex Officio Members: Mike King and John Salazar
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RECEIVED
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Thank you for the opportunity to comment on the possible impacts the Uncompahgre Pit may have on
wildlife. Colorado Parks and Wildlife (CPW) has reviewed the plans and visited the site of the proposed
project. CPW does have concerns for certain wildlife issues that will be affected by the proposed
Uncompahgre Pit.
The area of the proposed Uncompaghre Pit consists primarily of sage -brush vegetation on the upper terrace,
with pinyon -pine and juniper trees on the surrounding slopes. The proposed site is significant winter range
for deer and elk,.. Cottontail rabbit, red fox, coyote, small rodents, raptors, and song birds also utilize the
sage brush and pinyon pine and juniper ecosystem. Small mammals and song birds rely on the sage brush
ecosystem as protected nesting and foraging sites. With the adjacent agriculture fields in the surrounding
valleys, many raptors, including bald and golden eagles will utilize the proposed site for foraging, as well
as perching in the pinyon and juniper on the slopes.
The proposed pit site is critical winter range for both mule deer and elk, being utilized every winter and
even greater use during severe winter conditions. Mule deer are browsers relying on the sagebrush flats for
foraging and the steep, treed slopes for foraging, cover and bedding areas. Mule deer will prefer to forage
on the sagebrush flats, as sagebrush is a winter staple to their diet, while forbs and grasses make up a
smaller portion of their diet. The proposed site lies within the largest mule deer concentration area in the
Uncompahgre valley, with animals that migrate from the Uncompahgre Plateau population to the west and
the Cimarron population to the east. Mule deer exhibit high site fidelity toward their selected home ranges
returning to the exact same area year after year. Disturbance to mule deer winter ranges can cause them to
select alternative areas that provide lower quality forage and cover, potentially increasing their risk of
conflicts with agricultural producers, predation, and decreased survival and fawning rates leading to
subsequent population declines.
Elk utilize the sage flats as bedding and foraging areas, as well as the treed slopes. Elk are not constantly
present in the area during winter, but do utilize the available food resources throughout the winter. Elk are
grazers, preferring to forage in the sagebrush flats on grasses and during heavy snow years on the
sagebrush as well. Elk show site fidelity to their selected home ranges, but are generally quicker to shift
habitat selection and home range use following disturbance, which can result in shifting their distribution
to areas that create greater conflict on the large agricultural fields below the mesa.
The proposed site with large sagebrush flats and the cover of the treed slope's, are used by both deer and
elk as a buffer between the higher pinyon juniper forests and the agriculture fields in the valley. Currently,
Moonlight Mesa experiences very little human activity, which is partially why the mule deer and elk utilize
it extensively throughout the winter. With increased disturbance, it is expected that both deer and elk will