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• <br />Mr. Larry Shults <br />Page 5 <br />M <br />simply disappear from sight into the pond, even with a regular and conscientious monitoring <br />program. CDOW recommends that all three ponds be netted or otherwise closed to migratory birds at <br />project outset to avoid the expected mortality. Project impacts to migratory birds are completely <br />avoidable with proactive exclusion. <br />Woodland Nesting Raptors: <br />The DEIS identifies specific disturbance and displacement impacts expected to occur to raptors <br />nesting within the Piceance site and mitigation efforts to minimize those impacts. Nest seazches <br />conducted before well development and timing restrictions around active nests as described in the <br />DEIS should minimize disturbance to active nests. Nest displacement is not so easily mitigated. <br />Recommendations above for mule deer in relation to maintenance of large stands ofpinyon/juniper <br />and revegetation efforts to close disturbed stands after mining are recommended for raptor mitigation <br />on the Piceance site also. <br />CDOW supports the recommended mining restrictions around the remnant ponderosa pine stands at the <br />north end of the project site. Ponderosa pines are very limited within the Piceance Basin. Ponderosa <br />pine stands have been shown to support a higher diversity of wildlife species than most other vegetative <br />associations. <br />CDOW recommends that American Soda develop an effective disciplinary policy for handling <br />intentional harassment of wildlife by American Soda employees, vendors, and contractors occurring on <br />or while travelling to or from the mine site. Intentional harassment of wildlife, particularly the <br />intentional striking of wildlife with vehicles, has developed during other large construction episodes in <br />the Piceance Basin. A strong company policy against such actions can significantly reduce the impacts <br />of construction and operations activities on wildlife. CDOW also recommends that American Soda <br />prohibit employees, vendors, and contractors from possessing firearms on the site. Such prohibitions by <br />other companies working in the Piceance Basin over the years, have significantly reduced the amount of <br />illegal hunting that has occurred on or in transit to or from their operations. <br />Thank you again for the opportunity to comment on this DEIS. CDOW looks forward to working with <br />the BLM and American Soda as this mine project moves forward. <br />Sincerely, <br />~"~ f <br />James R. Bennett <br />Acting West Region Manager <br />cc: Dan Prenzlow <br />Mike Grode <br />Bob Towry <br />Walt Graul <br />Steve Norris <br />Dan McAuliffe <br />Mike Long <br />