PERMFILE57464 - Laserfiche WebLink

Home Browse Search

Mr. Larry Shults Page 2 -disturbance and displacement of nesting woodland raptors at the Piceance site. These impacts can be partially mitigated by timing restrictions and careful treatment of wooded areas during and after project development These impacts were identified within the DEIS and are as accurate as possible at this stage of project development. CDOW has been working with the proponent and BLM to develop an effective Wildlife Recovery and Replacement Plan/Mitigation and Monitoring Plan. Significant questions remain unresolved in the development of that plan. It is difficult to fully analyze the impacts of the project until wildlife mitigation standards aze developed. CDOW would prefer that a final W iidlife Recovery and Replacement Plan/Mitigation and Monitoring Plan be approved by the proponent, CDOW and BLM before a Record of Decision is issued by the BLM. The remainder of these comments concern specific CDOW impact analyses and mitigation recommendations. Mule Deer: CDOW expects significant impacts to mule deer winter range and severe winter range to be limited to the vicinity of the Piceance site. Impacts along the pipeline corridor are expected to be transitory. Mule deer are in the midst of a population decline in the Piceance Creek Basin and other portions of their range within Colorado and the inter-mountain west. Adequate and productive winter ranges aze critical to deer survival. In the Piceance Creek Basin, winter ranges are often dominated by well- established big sagebrush shrublands and pinyon/juniper woodlands. These vegetation types will be largely removed from affected areas during well field development as proposed in the DEIS and will require lengthy periods post-mining to revegetate to pre-treatment conditions. Mule deer winter range loss is expected to be most severe during the development of the first (0-5 year) and second (5- 10 year) mining panels because of woody species removal without revegation of previously mined areas to offset the loss. Off-site habitat improvement will be most important and most beneficial to mule deer during these early years of the project. The DEIS contains an internal inconsistency on this point. In several locations, the DEIS states that only one panel will be disturbed at a time and that revegetation of a completed panel will occur when the next panel is opened. However, the-DEIS_description of.the-most-likely~econd pass mining technique (pages 2-26 and 2-28) states that permanent revegetation of each panel will not likely begin until after all wells within a panel are retired. To maintain product flow to the processing plant, the next panel must be at least partially developed before the previous panel is completely retired. Therefore, at least 1.5 panels will likely experience large-scale woody vegetation removal before any permanent revegetation is attempted. The long time lag between the onset of revegetation and the growth of sufficient woody vegetation to support mule deer winter range expands the impacts yet again. If sagebrush stands take 10 to 15 years of development before they can adequately support wintering mule deer, then the first panel mined will not likely support wintering mule deer at pre- treatment levels before the fourth panel is opened (i.e. 5 years before revegetation commences plus l0 years of growth to reach useful stand development of sagebrush). By this line of reasoning, half of the total project area will be unable to provide suitable mule deer winter range at any one time once project development is in full swing. Mule deer use of active mining and revegetated areas may occur prior to full sagebrush stand development but winter range quality will be substantially reduced before stand development occurs.