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AMERICAN SODA, L.L.P. WILDLIFE MITIGATION PLAN MULE DEER The Colorado Division of Wildlife (CDOW) and the U.S. Bureau of Land Management (BLM} have determined that reclamation of disturbed areas following mining operations at the American Soda, L.L.P. (American Soda) Yankee Gulch Sodium Minerals Project (Yankee Gulch Project) Piceance Site may not adequately mitigate for impacts to mule deer and mule deer habitat that will occur during the life of the project. This concern is based on the fact that the Piceance Site lies within designated critical mule deer wintering habitat and on the assumption that any loss of habitat will result in negative impacts to wintering deer. Therefore, there is a need to compensate for potential impacts to wintering mule deer, including habitat losses and potential displacement of mule deer from wintering habitat, throughout the 30-year life of the project. Consequently, American Soda will implement a habitat mitigation program that will minimize both direct and indirect impacts to deer from habitat loss and will increase forage and cover in areas away from active mining operations. Piceance Creek Basin deer populations have been declining for 30 or more years. There are indications that the reduction in deer populations is attributable primarily to modification of habitat characteristics over time, although losses to predators and competition for forage from elk, domestic livestock, and wild horses have likely added to the problem. There is a general feeling that deer numbers could continue to decline for an unknown period of time. [t is also felt that it will take an equally long time for habitat improvement programs to provide conditions that will result in a significant increase in deer numbers. Therefore, maintenance of existing mule deer populations and mule deer habitat is an important wildlife management issue in the Piceance Creek Basin. Because of the potential for the Yankee Gulch Project to adversely affect mule deer, the following mitigation measures have been designed in consultation with the BLM and the CDOW to minimize that potential. The primary objectives of this Mule Deer Mitigation Plan are 1) to retain the integrity of important mule deer habitats within the mining panels, specifically security and thermal cover associated with pinyon-juniper stands and sagebrush parks, and maintain their long-term utility as mule deer habitat 2) to accelerate reestablishment of desirable pinyon- juniper distribution unavoidably altered in the development of the mining panel, 3) to reclaim disturbed areas within the mining panels, with an emphasis on establishing woody forage as mule deer browse, and 4) to provide "off-site" mule deer habitat improvements on a timely basis and in sufficient quantity to compensate for loss or disuse of mule deer habitat. W i Idlife MittRation f Ian 1_ 1 Yankee Gulch Sodium Minerals Project American Soda, L.L.P.