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1 <br />- • Ill llllllllllllllll i ~S <br />r - sss <br />STATE OF COLORADO <br />Bill Ciwens, Governor <br />DEPARTMENT OF NATURAL RESOURCES `~yORq~jo <br />> ;nr~n?~ DIVISION OF WILDLIFE ~~~~ <br />AN E UAL OPPORIlINr1Y ExiPLOYER <br />John W. Mumma, Director q <br />6060 Broadway h OF `~ <br />Deaver, Colorado 80216 <br />Telephone: (303) 297-1192 <br />7111ndepeodent Avenue r~ ry r~ <br />770 55 6 Oron, CO 81505 REC~~~r'L/ <br />March 23, 1999 ~/{~ 2 G ~, „7 <br />Division or rmnerals ~ ` `/ <br />Mr. Carl B. Mount 1v <br />Senior Environmental Protection Specialist <br />O ~• Divis'on of Minerals and Geolo <br />1313 Sherman t., Room ~ /~ ~/p~~ e ~Q W GO~-e^~`'vi ~/ ~` e`~' ~0.~'~~ <br />Denver, CO 80203 IJ~I.• I - <br />~ ~ ~'e- ~~ ~ i CC`-ZL ~ ov2 . <br />Deaz Mr. Mount, <br />The Colorado Division of Wildlife appreciates the opportunity to comment on American Soda's Section <br />112 Reclamation Permit, Applicarion Number M-99-002. CDOW has the following comments on the <br />application. <br />CDOW expects significant impacts to wildlife from the project in four categories: <br />-degradation of critical mule deer winter range and severe winter range on and around the Piceance site <br />and displacement of deer from those ranges. These impacts can be partially mitigated through a <br />combinatioa of effective on-site reclamation and revegetarion and off-site habitat improvement. <br />-disturbance of breeding and nesting sage grouse, destruction of sage grouse nests and degradation of <br />sage grouse habitat along the pipeline corridor. These impacu can be lazgely mitigated through timing <br />restrictions and habitat enhancement along the pipeline corridor. <br />-direct mortality of migratory birds from hypersaline waters at the Piceance and Parachute sites. These <br />impacts can be completely avoided by excluding migratory birds from these waters. <br />-disturbance and displacement of nesting woodland raptors at the Piceance site. These impacu can be <br />partially mitigated by tuning restrictions and careful treatment of wooded areas during and after project <br />development. <br />CDO W expects these impacts to be serious and long lasting, particulazly in the case of mule deer. <br />Personnel from CDOW, the Bureau of Land Management (BLM), and American Soda have been meeting <br />to resolve wildlife mitigation, reclamation and revegetation issues arising from these expected impacts. <br />Significant progress has been made within the last week on many of these issues. CDOW strongly believes <br />that effective reclamation and revegetation of disturbed sites can lessen the degree of habitat degradation <br />and loss. Wildlife habitat is featured as an importan[ post-mining land use. <br />The Piceance mine site lies in CDOW designated critical mule deer winter range and severe winter range. <br />Winter range values in the Piceance Basin frequently arise from well-established sagebrush stands and <br />large patches of dense pinyon-juniper woodland. These winter ranges provide thermal cover, hiding cover, <br />and forage for wintering mule deer. Both habitat types require significant time after revegetation before <br />they provide pre-disturbance winter rartge values. Sagebrush stands are expeacd to require a minimum of <br />10-IS years after sagebrush establishmen[ to begin to provide winter range values to those produced by <br />DEPARTMENT OF NATURAL RESOURCES. Greg Watcher, Execu[ive Direcmr <br />WILDLIFE COMMISSION, Chuck Lewis, Chairman ~ Mark LeValley, Vice Chairman -Bernard Black, Secretary <br />Rick Ensuom, Member ~ Philip James, Member ~ Marianna RaNopoulos, Member ~ Arnold Salaiar, Member ~ Roben Shoemaker, Member <br />