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STATE OF COLORADO Bill Owens, Governor DEPARTMENT OF NATURAL RESOURCES DIVISION OF WILDLIFE AN EQUAL OPPORiUNfIY EMPLOYER John W. Mumma, Director Southeast Reafonal Office: 2726 N Weber Street coloraeo springs, co eoso7 Teleptane: (719)2275200 August 9, 1999 Mr. James Stevens Division of Minerals & Geology 1313 Sherman Street, Room 215 Denver, CO 80203 SUBJ: Main Pit, Permit No. M-77-197 Dear Mr. Stevens: ~~ ~?ECEIVED AUG 11 1999 '13;^ ~- ~. ~.~c The Division has reviewed the above referenced application and has visited the site. We offer the following comments and concerns for your consideration. As indicated in Section H and through personal communication with Ron Dobson, District Wildlife Manager, the wildlife questionnaire (dated 04/09/99) was completed based on the misunderstanding that this application was merely and extension of mining within the existing permit area. Once the application materials were received it became apparent that this was an expansion of the existing permit to include undisturbed BLM lands. The BLM lands are characterized as rolling hills covered with Pinon Pine, Ponderosa Pine, mountain mahogany, squaw current, rabbit brush, and scattered yucca and prickly pear callus. The area is used by mule deer for daytime resting, especially during the winter, which is a critical period during the life cycle of this species. Since it is apparent that legal right to enter and mine the BLM parcel has not yet been consummated the Division questions whether this parcel should be considered as part of this application. If this issue has been resolved then the Division recommends woody species be incorporated into the reclamation plan for at least the BLM parcel. Although the grass seed mix should be adequate from an herbaceous standpoint, replacement of woody shrubs such as the mountain mahogany, rabt>itbrush, and current will further enhance the parcel and replace values lost for mule deer due to impacts from mining. Since the BLM manages its lands for mukiple uses including management es wildlife habitat the Division feels these values impacted by mining should be replaced as part of the rangeland reclamation process. Finally, the Division recommends uniform use of a 3:1 slope throughout the permit area be incorporated into this permit. We make this recommendation based on the semi-arid conditions present and the nature in which precipitation is received in sudden and intense storm events. We believe 2:1 slopes too severe for proper revegetation and unnecessarily subject to erosion. File: M77197.LET DEPARTMENT OF NATURAL RESOURCES, Greg Wakher, Executive Dlreclor WILDLIFE COMMISSION, Chuck Lewis, Chairman • Mark LeValley, V'~ce-Chair • Bernard 91ack Secremry Marianna Raftopoubs, Member • Philip James, Member • Amald Salaar, Member • Robert Shoemaker, Member • Rick Enstrorn, Member