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AmerAlia, Inc. <br />Page 2 <br />establishment of woody vegetation. This time lag contributes to the persistence of impacts to mule deer after <br />mining. Most of the disturbance envisioned in the AmerAlia application occurs in these two vegetation types. <br />Mule deer impacts from the AmerAlia experimental project can be reduced and partially mitigated by a <br />combination of careful site selection, effective and targeted reclamation and off -site habitat development or <br />improvement. Reclamation alone, because of the long recovery period of sagebrush and pinyon juniper <br />communities, will not adequately support mule deer displaced as a result of mine development. The revegetation <br />seed mix specified in AmerAlia's application will provide reasonably high quality forage for mule deer during <br />light winter conditions and will provide an important nutritional boost to mule deer as they enter the spring. It <br />needs to focus more directly on sagebrush re- establishment to directly mitigate loss of suitable winter range <br />habitat, however. CDOW recommends the following practices to minimize and mitigate disturbances to mule <br />deer. <br />AmerAlia, CDOW, and the Bureau of Land Management (BLM) should visit the site prior to any construction <br />activity and identify any pinyon juniper stands that are particularly old, dense or contiguous for special <br />management. These stands, if any, should be avoided wherever possible by re- routing roads, pipe racks and <br />other ground disturbances. Where these stands must be disturbed, AmerAlia should mitigate the disturbance by <br />planting pinyon and juniper trees into those specific stands during reclamation to speed natural closure of those <br />canopies. It has been estimated on other nearby mine sites that perhaps twenty percent of the pinyon juniper <br />canopy falls into this category. <br />The revegetation seed mix specified in AmerAlia's application is suitable for many of the reclaimed areas. <br />CDOW would like to see sagebrush and /or bitterbrush stands established on a minimum of twenty percent of the <br />total disturbed areas to allow the earliest possible return of mature shrubs to the mine site. Shrub species, <br />including sagebrush, are difficult to establish in competition with the vigorous stands of grasses that often result <br />from reclamation plantings. Sagebrush restoration areas will most likely need to be seeded separately or planted <br />with tubelings or other established plant stock. It may be advantageous not to recontour some of the sage <br />planting areas to allow more efficient water harvesting and better growth conditions. CDOW recommends that <br />the specific reclamation plan be developed cooperatively between CDOW, BLM and AmerAlia as mine planning <br />develops. <br />CDOW expects mule deer to be displaced from the mine site and surrounding areas early in the project due to <br />construction and mining activity. This displacement cannot be mitigated by post- mining reclamation. CDOW <br />recommends that AmerAlia enhance mule deer habitat off the mine site at the rate of at least 2.5 acres for each <br />acre physically disturbed on the mine site. This off -site mitigation should be planned cooperatively by <br />AmerAlia, CDOW and BLM and should occur as early in mine development as possible to provide habitat for <br />those deer displaced from the mine site. <br />Woodland nesting raptors, including Cooper's hawks and occasional goshawks, nest in the pinyon juniper <br />woodlands on and near the mine site. Impacts to woodland nesting raptors can be partially avoided by <br />following surface occupancy and timing restrictions stipulated in the BLM's White River Resource Management <br />Plan. Pinyon juniper planting in designated stands as described above will allow those stands to continue to <br />provide suitable nesting habitat after the completion of mining. <br />Impacts to migratory birds, including bald eagles, from saline waters in the evaporation ponds on the site are of <br />concern. AmerAlia's application does not mention the expected salinity level in such ponds, but recently <br />permitted operations using similar processes expect to develop hyper - saline water conditions within the life of <br />the project. Hyper - saline waters are a direct threat to migratory birds through contact or ingestion. Ponds in the <br />DEPARTMENT OF NATURAL RESOURCES, Greg Watcher, Executive Director <br />WILDLIFE COMMISSION, Chuck Lewis, Chairman • Mark LeValley, Vice - Chairman Bernard Black, Secretary Rick Enstrom, Member <br />Philip James, Member • Marianna Raftopoulos, Member • Arnold Salazar, Member • Robert Shoemaker, Member <br />