PERMFILE120656

• Permit No: M1997011
• IBM Index Class Name: Permit File
• Doc Date: 4/17/1997
• Doc Name: FN M-97-011 BACULITE MESA PIT
• From: DOW
• To: DMG
• Media Type: D
• Archive: No

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STATE OF COLORADO 999 REFER TO
Roy Romer, Governor
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF WILDLIFE oti01~

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AN EQUAL OPPO
UNITY EMPLOYER
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John W. Mumma, Director ~
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6060 Broadway ~
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Denver, Colorado 80216 O~,OF
Telephone: [phone]
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17 Apri197 \~ For People
James C. Stevens
Senior Environmental Protection Specialist
Division of Minerals and Geology
1313 Sherman St., Rm 215
Denver, CO 80203
RE: File No. M-97-O1 I
Baculite Mesa Pit
Dear Mr. Stevens:
The Colorado Division of Wildlife (CDOW) has reviewed the above referenced application and
offers the following comments concerning the proposed action.
The permit area is characterized as having Gilcrest series soils which currently support a diverse
shortgrass prairie ecosystem. The conversion ofthis habitat type to a rangeland designation will
significantly reduce the habitat value of the 1900 acre permit area. The reclamation plan
improperly states, "there is no woody vegetation present on the site to be affected." The site does
contain woody vegetation. During a recent site visit, CDOW noted the presence of several woody
species including those species listed in Exlu-bit J. We would encourage the applicant to re-
evaluate the vegetation and provide for woody replacement of like species and quantity as is
presently on-site.
The current mining plan stipulates a maximum of 40 acres at any one time. However, the
application is unclear in describing a timetable for reclamation. Exhibit D, section (e) of the
mining plan states that reclamation will occur 2-3 years after sufficieut operating room is created.
Exhibit D, section (e) subsection (L) states that 10-15 years of mining is required before
reclamation can commence. In 6.4.5 Exhibit E -Reclamation Plan, section 2(e)(f) states that
reclamation is estimated to begin within 1-3 years and be completed 5 years after mining is
complete. The lack of clarity in the application make it diffilcult to comment specifically, but
CDOW would recommend limiting total disturbance to 40 acres and implementing
sequentiaUconcurrent reclamation.
CDOW has serious concerns as to whether the current reclamation plan can achieve the criteria of
establishing a diverse, effective and long-lasting vegetative cover. On the contrary, CDOW
anticipates a severe degradation of land productivity resulting from the proposed action. The
DEPARTMENT OF NATURAL RESOURCES, James S. Lochhead, Executive Director
WILDLIFE COMMISSION, Arnold Salazar, Chairman • Rebecca L. Frank, Vice Chair • Mark LeValley, Secretary
Louis F Swift, Member • Jesse Langston Boyd, Jr., Member
William R. Hegberg, Member • John Stulp, Member • James R. Long, Member