CWF letter re proposed Douglas Mountain Mine permit app

December 20, 2018

 Colorado Wildlife Federation submitted its comment letter on December 18 re the Douglas Mountain Mine permit application.  The risk to the iconic Georgetown tier 1 bighorn sheep herd cannot be understated. We will be working hard on this during the analysis period and of course, at the eventual public hearing. 

 Here is the text of our letter. 

December 18, 2018

Peter Hays 

Minerals Specialist

Colorado Division of Reclamation, Mining and Safety 


Transmitted via email:


Re: Amendment to Permit Application by Empire Aggregates, Inc. – Douglas Mountain Mine


Dear Mr. Hays: 


The Colorado Wildlife Federation is a nonprofit organization, founded in 1953 who membership and supporters consist of sportsmen, wildlife viewers, and other outdoor recreationists and conservationists.  The bighorn sheep herd (the “Georgetown Herd”) is designated Tier I by Colorado Parks and Wildlife (CPW), and enjoyed by the public due to its high visibility. 


This iconic herd moves between Berthoud Pass and Golden, Colorado. Its movement and winter range includes areas of the proposed Douglas Mountain Mine’s total disturbed 77.5 acres. The permit application, Exhibit H, Wildlife Information, 7.1 Mitigation of Identified Significant Impacts – Bighorn Sheep herd, acknowledges, “A Tier 1 bighorn sheep herd passes through the site in its travels south to north.”  The written comments by numerous residents in the area, too, document the year-round movement by the herd that includes the designated acreage.  This very important herd’s population has trended slightly downward from an estimated population of 300 in 2014 to 250 in 2018. 


Our concerns are twofold. First, the heavy volume of daily gravel haul truck traffic 24 hours a day, 7 days a week to and from the proposed mine access road would constrain or block the herd’s usual movement. The sheep follow a route along the south face of Douglas Mountain and then wrap around the east side of the proposed mine. The outcome likely would become a formation of subherds, decreasing the current gene pool through isolation, and adversely impacting the overall herd population and its health.  


Second, the collision between vehicles and bighorn sheep would undoubtedly increase markedly as the sheep attempt to pursue their usual movement routes.  The herd crosses Highway 40 and walks along County Road 257. In fact, Exhibit H7.1 recognizes, …the greatest impacts to the sheep will be vehicle collisions on the access, ….”. 


In light of these two complex related issues, we strongly urge that the Division, CPW and the operator confer early on during the Division’s analysis period to resolve or substantially mitigation these problems.  If these issues cannot be addressed satisfactorily, then we request the Division to deny issuance of the permit. 


Thank you for full consideration of our comments.





Suzanne O’Neill

Executive Director, Colorado Wildlife Federation 

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