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MAR-24-99 10:18 FROM: DIV.WILDLI~WEST RG 970-255-6111 T0:~03B32(3106 PF7GE:003 <br />exisuag vegetation. Pinyanju¢iper woodlands on the Piceance site arc rxpected to need 75-100 years after <br />vee esmblishmeat to provide equivalent thermal cover to that produced by existing trees. <br />A majority of the American Soda mine site lies within the sagebrush and pinyon-juniper habitat typ~s- <br />Significant aaeage of both types will be disturbed or cleared by mine development. Widt the long <br />recovery ptriods expected of both habitat types, impacts to winter range vegetation, and the mule deer it <br />supports, are expected to exceed the life ofthe mice operation by many years. Reclamation based on the <br />return of woody species to disturbed areas wilt be critical in the long-term ability of mule deer to use dte <br />site during severe winters. CDOw recommends that a tlexible system be developed for reclamatia¢ of well <br />fields that allows for: <br />-pre-designation by BLM/CDOW/American Soda of significontpinyon-juniper stmrds in each mine <br />panel that provide large areas ofhigher-density canopy. These areas are estimated to equal <br />approximately 20°/. of each mine panel. American Soda should attempt to minimize disturbance to <br />these parcels to the extent possible. Where disturbance is unavoidable, reclamation should focus on <br />restoring pinyon-juniper in the dismrbed areas to a stem density equal to that i¢ adjacent mature stands. <br />-restoration of sagebntslr perks on designated abartdoned well pads by seed, tubelings, plug planting or <br />other methods b a stem density equivalent to that in adjacent mature stands. <br />-developmrnt of bitterbtus6 or other palatable browse stands on designated abandoned well pads. <br />-standard grassJforb based reclamatlan on other disturbed sites and az an understory below woody <br />reveeetatio¢ after establishment. <br />This reclamation proposal is predicated on BLM, CDOW, and American Soda developing a mutually <br />accepable reclamation plan for each mine panel by the time of abandortmant. American Soda's proposed <br />reclamatio¢ on the mine site is grass/fort based for all areas of the I'iceance site with four-wing sehbush <br />included as the only shmb. Reclamation to that standard will oot restore mule deer winter range within a <br />reasonable time period and will extend the impacu of mine development on wintering mule dev. <br />Experience in the Piceance Basin has shown that shrubs ate easily outeompeted by grasses in sced <br />mixrures. 'Ike best chance for success tray be to plant shrubs a¢d a cover crop i,r;tiauy and follow with <br />permanent grasses and forks after the shrubs are established. The cover aop would wntrol weed <br />infestation while allowing the shrubs to grow without the intense competition of perumiel gra~,scs. <br />Herbicide trcannent of cover and permanent vegeauion in the immediate vicinity of ¢ew shnilss may be <br />needed to allow the shrubs to establish. CDOW strongly enwurage5 lbe establishment of a woody shrub <br />stem density standard which must be met before American Soda's reclamation bond is released. Impacts to <br />mule deer along the pipeline are expected to be transitory. <br />Sage grouse impacts are limiud to the pipeline corridor. Direct impacts to grouse can be greatly reduced <br />by adhering to a March 1 to May 31 timing resttiction to avoid grouse breeding in close proximity to the <br />pipeline route and a lone l to July l5 timing restriction to avoid impacts to grouse nests and young broods <br />along the corridor. Indirect impacts to grouse are expected due to the potat[ial change in vegetative cover <br />on the reclaimed corridor. The American Soda pipeline will be the [bird parallel pipe along Barnes Ridge <br />and the adjacrnt ridge to the southeast. The fast two pipelines have been sprayed for weeds from the air <br />and have very little of the fort component and less of the brush component required by sage grouse for <br />successful nesting and brood rearing. As a result, the wmulative impacts of the existing pipelines have <br />been undeniably negative for sage grouse. This sirua[ion will worsen without aggressive reclamation of the <br />American Soda corridor. Reclamation emphasizing the establisbmrnt of forts palatable m sage grouse will <br />help grouse continue to use Barnes Ridge. Additional planting of sagebrush in the corridor, either in rows <br />or patches, will makt du: corridor more avaIIable to grouse as rt becomes established. As with the mine <br />sire, success in sagebrush establishmrnt should be enhanced if the shrubs are planted separately from <br />grasses aced forts. <br />