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Mr. Larry Shults Page 3 Winter range impacts of disturbed pinyon/juniper stands will continue long after the current proposal is completed. Many pinyon/juniper stands near the American Soda site contain 200 year old and older trees. It is expected that a minimum of 75 to 100 years will be required after pinyon/juniper trees become re-established for stand closure to occur. Large, contiguous stands of pinyon/juniper woodland provide important thermal cover for wintering mule deer. CDOW recommends that the proponent minimize the fragmentation of large, contiguous stands of pinyonfjuniper during mine panel development by routing roads and pipe racks around these areas to the extent possible and minimize the size of clearings incases where these stands must be entered. Post-mining revegetation should include plantings of pinyon and juniper back into disturbed areas within the lazgest stands of pinyon/juniper woodland present on each mine panel. Winter range impacts can only be mitigated in the short term through the improvement of off-site habitats. Winter ranges improved through mitigation efforts require the establishment of woody vegetation to be effective. CDOW recommends off-site mitigation be required within an acreage range agreed to by the proponent, CDOW and BLM. That range should call for minimum off-site mitigation sufficient to support mule deer displaced from the site until revegetation on mined panels can adequately provide winter range values (perhaps the cumulative acreage total of the first three panels to be mined-541 acres). Nearby White River Nahcolite, a much smaller but similar project, mitigates disturbances at a rate of two acres developed off-site per acre treated on-site. Application of this standard to the American Soda site would result in minimum off-site mule deer habitat development of approximately 1100 acres. Maximum ofltsite mitigation should be set assuming that revegation efforts on mined panels are unsuccessful at restoring treated azeas to adequate mule deer winter range. It is the intent of CDOW by these recommendations to mitigate for deer habitat loss prior to the onset of revegetation but to encourage the proponent to develop effective on-site revegetation strategies through the incentive of reduced ofF site requirements if on-site revegetation is effective. Off-site treatments should be close enough to the project area to support deer displaced by mine development. Mule deer monitoring should be used by the proponent to identify prospective mitigation azeas in consultation with CDOW and BLM. Mitigation conducted on unmined portions of the Yankee Gulch lease should be replaced in addition to mitigation required for those acres should future mining occur in those areas as described in the Reasonably Forseeable Actions section of the DEIS (2.2.8). On-site revegetation should focus on restoring woody species to treated areas. Grasses, while valuable for soil stabilization and spring transitional forage for mule deer, do not provide for the needs of mule deer on winter ranges and severe winter ranges. Forbs aze of greater nutritional value to mule deer than grasses. Specific stem density requirements for browse species should be developed between the proponent , CDOW, BLM and the Division of Minerals and Geology for this project. CDOW recommends that shrubs and grasses not be planted together due to the competitive ability of grasses to exclude shrub seedlings when started from seed. Mule deer have been shown to habituate to industrial developments in some areas. It is possible that such habituation could occur on the Piceance site, but CDOW considers it unlikely to significantly reduce the impact of lost winter range prior to mine panel closure due to the extent and grid like pattern of roads and pipe racks within the mine panels. The height and width of pipe racks are expected to significantly reduce the ability of mule deer to move within active mine panels. Deer passes at road crossings and drainage's as described in the DEIS will help alleviate blockage of migration through the site but are not expected to encourage deer to live within the site during active mining operations.