1999-12-15_GENERAL DOCUMENTS - M1999051

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STATE OF COLORADO Bill Owens, Governor DEPARTMENT OF NATURAL RESOURCES DIVISION OF WILDLIFE AN EQUAL OPPORTUNITY EMPLOYER John W. Mumma, Director 6060 Broadway Denver, Colorado 80216 Telephone: (303) 297 -1192 West Region Service Center 711 Independent Avenue Grand Junction, CO 81505 970 - 255 -6100 June 16, 1999 Mr. Carl B. Mount Senior Environmental Specialist Division of Minerals and Geology 1313 Sherman St., Room 215 Denver, CO 80203 Dear Mr. Mount, RECEIVED JUN 21 1999 Division of Minerals & Geology RE: AmerAlia, Inc., Rock School Lease Experimental Nahcolite Mine Project, File No. M - 99 - 051 For Wildlife - For People The Colorado Division of Wildlife (CDOW) appreciates the opportunity to comment on the Section 112 Reclamation Permit Application filed by AmerAlia, Inc. to conduct experimental nahcolite solution mining on the Rock School Lease in the Yellow Creek Basin southwest of Meeker, CO. The application adequately describes the wildlife resource in the vicinity of the mine site.. CDOW wishes to provide the following comments on AmerAlia's permit application. The mining process and site design proposed by AmerAlia are similar in type to other mines recently permitted by the Division of Minerals and Geology. The scale of the project is limited in the current, experimental proposal but may be significantly expanded within a few years if the site proves to be commercially viable. CDOW is concerned about potentially negative impacts to wintering mule deer, woodland nesting raptors, migratory birds and other riparian and aquatic wildlife, including the four endangered fish species occurring in the White River. Some of these impacts can be greatly reduced or eliminated through careful project design and reclamation. Others, particularly those to mule deer, may linger many years after the end of active mining. Mule deer populations are in decline across the west slope of Colorado, including the Piceance Creek and Yellow Creek basins. Mule deer generally use the AmerAlia mine site during winter months. The eastern portion of the lease is classified as severe winter range by the Division of Wildlife, indicating that 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- DEPARTMENT OF NATURAL RESOURCES, Greg Watcher, Executive Director WILDLIFE COMMISSION, Chuck Lewis, Chairman • Mark LeValley, Vice - Chairman • Bernard Black, Secretary • Rick Enstrom, Member Philip James, Member • Marianna Raftopoulos, Member Arnold Salazar, Member • Robert Shoemaker, Member