1999-12-15_GENERAL DOCUMENTS - M1999051

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• • that this portion of the site is used by deer during the worst two out of ten winters. The remainder of the lease is considered winter range. Winter range is considered to be used by deer during at least five of every ten winters. Winter use by deer concentrates around sites with mature stands of woody vegetation, both pinyon juniper woodland and Wyoming big sagebrush. Dense structural cover from the elements is at least as important to deer survival through the winter as good quality forage. This is particularly true during severe winter events. Mature stands of Wyoming big sagebrush and pinyon juniper woodlands take extended periods of growth after disturbance to begin to provide adequate winter range and severe winter range values. This period may exceed 10 -15 years in big sagebrush types and 75 -100 years in pinyon juniper types after the re- establishment of woody vegetation. This time lag contributes to the persistence of impacts to mule deer after mining. Most of the disturbance envisioned in the AmerAlia application occurs in these two vegetation types. Mule deer impacts from the AmerAlia experimental project can be reduced and partially mitigated by a combination of careful site selection, effective and targeted reclamation and off -site habitat development or improvement. Reclamation alone, because of the long recovery period of sagebrush and pinyon juniper communities, will not adequately support mule deer displaced as a result of mine development. The revegetation seed mix specified in AmerAlia's application will provide reasonably high quality forage for mule deer during light winter conditions and will provide an important nutritional boost to mule deer as they enter the spring. It needs to focus more directly on sagebrush re- establishment to directly mitigate loss of suitable winter range habitat, however. CDOW recommends the following practices to minimize and mitigate disturbances to mule deer. AmerAlia, CDOW, and the Bureau of Land Management (BLM) should visit the site prior to any construction activity and identify any pinyon juniper stands that are particularly old, dense or contiguous for special management. These stands, if any, should be avoided wherever possible by re- routing roads, pipe racks and other ground disturbances. Where these stands must be disturbed, AmerAlia should mitigate the disturbance by planting pinyon and juniper trees into those specific stands during reclamation to speed natural closure of those canopies. It has been estimated on other nearby mine sites that perhaps twenty percent of the pinyon juniper canopy falls into this category. The revegetation seed mix specified in AmerAlia's application is suitable for many of the reclaimed areas. CDOW would like to see sagebrush and/or bitterbrush stands established on a minimum of twenty percent of the total disturbed areas to allow the earliest possible return of mature shrubs to the mine site. Shrub species, including sagebrush, are difficult to establish in competition with the vigorous stands of grasses that often result from reclamation plantings. Sagebrush restoration areas will most likely need to be seeded separately or planted with tubelings or other established plant stock. It may be advantageous not to recontour some of the sage planting areas to allow more efficient water harvesting and better growth conditions. CDOW recommends that the specific reclamation plan be developed cooperatively between CDOW, BLM and AmerAlia as mine planning develops. CDOW expects mule deer to be displaced from the mine site and surrounding areas early in the project due to construction and mining activity. This displacement cannot be mitigated by post - mining reclamation. CDOW recommends that AmerAlia enhance mule deer habitat off the mine site at the rate of at least 2.5 acres for each acre physically disturbed on the mine site. This off -site mitigation should be planned cooperatively by AmerAlia, CDOW and BLM and should occur as early in mine development as possible to provide habitat for those deer displaced from the mine site. Woodland nesting raptors, including Cooper's hawks and occasional goshawks, nest in the pinyon juniper woodlands on and near the mine site. Impacts to woodland nesting raptors can be partially avoided by following surface occupancy and timing restrictions stipulated in the BLM's White River Resource Management Plan. Pinyon juniper planting in designated stands as described above will allow those stands to continue to provide suitable nesting habitat after the completion of mining.