United States Department of the Interior Bureau of Land Management

Environmental Assessment DOI-BLM-UT-C030-2016-0049-EA

May 2017

Bull Valley Exploration Project Washington County, Utah

Pilot Goldstrike Inc. 1031 Railroad Street, Suite 110 Elko, Nevada 89801

U.S. Department of the Interior Bureau of Land Management St. George Field Office 345 East Riverside Drive St. George, UT 84790 Phone: 435-688-3200 FAX: 435-688-3252

MISSION STATEMENT

It is the mission of the Bureau of Land Management to sustain the health, diversity, and productivity of the public lands for the use and enjoyment of present and future generations.

BULL VALLEY EXPLORATION EA (DOI-BLM-UT-C030-2016-0049-EA)

TABLE OF CONTENTS

1.0 PURPOSE AND NEED ...... 1 1.1 INTRODUCTION ...... 1 1.2 BACKGROUND ...... 1 1.3 PURPOSE AND NEED FOR THE PROPOSED ACTION ...... 2 1.4 DECISION TO BE MADE ...... 3 1.5 CONFORMANCE WITH BLM LAND USE PLAN(S) ...... 3 1.6 RELATIONSHIP TO STATUES, REGULATIONS, AND OTHER PLANS ...... 3 1.7 IDENTIFICATION OF ISSUES ...... 4 1.7.1 Water Resources/Quality ...... 5 1.7.2 Areas of Critical Environmental Concern...... 5 1.7.3 Cultural Resources ...... 5 1.7.4 Paleontology ...... 5 1.7.5 Cave and Karst ...... 6 1.7.6 Socio-Economics ...... 6 1.7.7 Soils...... 6 1.7.8 Fish and Wildlife...... 6 1.7.9 Migratory Birds ...... 6 1.7.10 Vegetation ...... 6 1.7.11 Recreation ...... 6 1.7.12 Visual Resources ...... 6 1.7.13 Lands with Wilderness Characteristics...... 6

2.0 DESCRIPTION OF ALTERNATIVES, INCLUDING PROPOSED ACTION ...... 8 2.1 INTRODUCTION ...... 8 2.2 ALTERNATIVE A – PROPOSED ACTION ...... 8 2.2.1 Drill Sites and Drilling Procedures ...... 9 2.2.2 Road Construction and Access ...... 10 2.2.3 Equipment ...... 11 2.2.4 Water Needs and Use ...... 12 2.2.5 Work Force ...... 12 2.2.6 Surface Water and Groundwater Control ...... 12 2.2.7 Ancillary Facilities and Surface Occupancy ...... 13 2.2.8 Solid and Hazardous Materials Management ...... 13 2.2.9 Reclamation ...... 14 2.2.9.1 Schedule of Reclamation ...... 15 2.2.9.2 Drill Hole Plugging ...... 15 2.2.9.3 Regrading and Reshaping ...... 16 2.2.9.4 Revegetation ...... 16 2.2.9.5 Handling and Application of Topsoil ...... 17 2.2.9.6 Removal or Stabilization of Building, Structures, and Support Facilities ...... 17

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2.2.9.7 Previous Reclamation ...... 17 2.2.10 Environmental Protection Measures ...... 18 2.3 ALTERNATIVE B – NO ACTION ...... 21 2.4 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED ANALYSIS ...... 21

3.0 AFFECTED ENVIRONMENT ...... 22 3.1 INTRODUCTION ...... 22 3.2 RESOURCES/ISSUES BROUGHT FORWARD FOR ANALYSIS ...... 23 3.2.1 Water Resources ...... 24 3.2.2 Areas of Critical Environmental Concern...... 26 3.2.3 Cultural Resources ...... 26 3.2.4 Paleontology ...... 27 3.2.5 Cave and Karst ...... 27 3.2.6 Socio-Economics ...... 28 3.2.7 Soils...... 29 3.2.8 Fish and Wildlife...... 31 3.2.9 Migratory Birds ...... 31 3.2.10 Vegetation ...... 34 3.2.11 Recreation ...... 36 3.2.12 Visual Resources ...... 37 3.2.13 Lands with Wilderness Characteristics ...... 38

4.0 ENVIRONMENTAL CONSEQUENCES ...... 40 4.1 INTRODUCTION ...... 40 4.2 GENERAL ANALYSIS ASSUMPTIONS AND GUIDELINES ...... 40 4.3 DIRECT AND INDIRECT IMPACTS ...... 40 4.3.1 Alternative A – Proposed Action ...... 40 4.3.1.1 Water Resources ...... 40 4.3.1.2 Areas of Critical Environmental Concern...... 41 4.3.1.3 Cultural Resources ...... 41 4.3.1.4 Paleontology ...... 42 4.3.1.5 Cave and Karst ...... 42 4.3.1.6 Socio-Economics ...... 42 4.3.1.7 Soils...... 43 4.3.1.8 Fish and Wildlife...... 44 4.3.1.9 Migratory Birds ...... 44 4.3.1.10 Vegetation ...... 44 4.3.1.11 Recreation ...... 45 4.3.1.12 Visual Resources ...... 46 4.3.1.13 Lands with Wilderness Characteristics ...... 46 4.3.2 Alternative B – No Action ...... 47 4.3.2.1 Water Resources ...... 47 4.3.2.2 Areas of Critical Environmental Concern...... 47 4.3.2.3 Cultural Resources ...... 47 4.3.2.4 Paleontology ...... 47 4.3.2.5 Cave and Karst ...... 47 4.3.2.6 Socio-Economics ...... 47 4.3.2.7 Soils...... 47

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4.3.2.8 Fish and Wildlife...... 48 4.3.2.9 Migratory Birds ...... 48 4.3.2.10 Vegetation ...... 48 4.3.2.11 Recreation ...... 48 4.3.2.12 Visual Resources ...... 48 4.3.2.13 Lands with Wilderness Characteristics ...... 48 4.4 CUMULATIVE IMPACTS ...... 48 4.4.1 Water Resources ...... 49 4.4.1.1 Cumulative Impact Area (CIA) ...... 49 4.4.1.2 Past and Present Actions ...... 49 4.4.1.3 Reasonably Foreseeable Future Action Scenario (RFAS) ...... 50 4.4.1.4 Cumulative Impact Analysis ...... 50 4.4.2 Areas of Critical Environmental Concern...... 50 4.4.2.1 Cumulative Impact Area ...... 50 4.4.2.2 Past and Present Actions ...... 50 4.4.2.3 Reasonably Foreseeable Action Scenario (RFAS) ...... 50 4.4.2.4 Cumulative Impact Analysis ...... 51 4.4.3 Cultural Resources ...... 51 4.4.3.1 Cumulative Impact Area ...... 51 4.4.3.2 Past and Present Actions ...... 51 4.4.3.3 Reasonably Foreseeable Action Scenario (RFAS) ...... 51 4.4.3.4 Cumulative Impact Analysis ...... 51 4.4.4 Paleontology ...... 51 4.4.4.1 Cumulative Impact Area ...... 51 4.4.4.2 Past and Present Actions ...... 51 4.4.4.3 Reasonably Foreseeable Action Scenario (RFAS) ...... 52 4.4.4.4 Cumulative Impact Analysis ...... 52 4.4.5 Cave and Karst ...... 52 4.4.5.1 Cumulative Impact Area ...... 52 4.4.5.2 Past and Present Actions ...... 52 4.4.5.3 Reasonably Foreseeable Action Scenario (RFAS) ...... 52 4.4.5.4 Cumulative Impact Analysis ...... 52 4.4.6 Socio-Economics ...... 52 4.4.6.1 Cumulative Impact Area ...... 52 4.4.6.2 Past and Present Actions ...... 53 4.4.6.3 Reasonably Foreseeable Action Scenario (RFAS) ...... 53 4.4.6.4 Cumulative Impact Analysis ...... 53 4.4.7 Soils...... 53 4.4.7.1 Cumulative Impact Area ...... 53 4.4.7.2 Past and Present Actions ...... 53 4.4.7.3 Reasonably Foreseeable Action Scenario (RFAS) ...... 53 4.4.7.4 Cumulative Impact Analysis ...... 53 4.4.8 Fish and Wildlife...... 53 4.4.8.1 Cumulative Impact Area ...... 53 4.4.8.2 Past and Present Actions ...... 54 4.4.8.3 Reasonably Foreseeable Action Scenario (RFAS) ...... 54 4.4.8.4 Cumulative Impact Analysis ...... 54

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4.4.9 Migratory Birds ...... 54 4.4.9.1 Cumulative Impact Area ...... 54 4.4.9.2 Past and Present Actions ...... 54 4.4.9.3 Reasonably Foreseeable Action Scenario (RFAS) ...... 54 4.4.9.4 Cumulative Impact Analysis ...... 54 4.4.10 Vegetation ...... 55 4.4.10.1 Cumulative Impact Area ...... 55 4.4.10.2 Past and Present Actions ...... 55 4.4.10.3 Reasonably Foreseeable Action Scenario (RFAS) ...... 55 4.4.10.4 Cumulative Impact Analysis ...... 55 4.4.11 Recreation ...... 55 4.4.11.1 Cumulative Impact Area ...... 55 4.4.11.2 Past and Present Actions ...... 55 4.4.11.3 Reasonably Foreseeable Action Scenario (RFAS) ...... 55 4.4.11.4 Cumulative Impact Analysis ...... 55 4.4.12 Visual Resources ...... 56 4.4.12.1 Cumulative Impact Area ...... 56 4.4.12.2 Past and Present Actions ...... 56 4.4.12.3 Reasonably Foreseeable Action Scenario (RFAS) ...... 56 4.4.12.4 Cumulative Impact Analysis ...... 56 4.4.13 Lands with Wilderness Characteristics ...... 56 4.4.13.1 Cumulative Impact Area ...... 56 4.4.13.2 Past and Present Actions ...... 56 4.4.13.3 Reasonably Foreseeable Action Scenario (RFAS) ...... 56 4.4.13.4 Cumulative Impact Analysis ...... 56

5.0 CONSULTATION AND COORDINATION AND LIST OF PREPARERS ...... 58 5.1 PERSONS, GROUPS, AND AGENCIES CONSULTED ...... 58 5.2 SUMMARY OF PUBLIC PARTICIPATION ...... 58 5.3 LIST OF PREPARERS ...... 67

6.0 REFERENCES ...... 68

LIST OF TABLES

Table 2-1 Existing and Proposed Surface Disturbance Associated with the Project ...... 8 Table 2-2 Existing and Proposed Drill Sites by Land Status ...... 8 Table 2-3 Anticipated Exploration Reclamation Schedule ...... 15 Table 3-1 Resources Eliminated from Detailed Analysis in this Environmental Assessment ...... 22 Table 3-2 May 2016 East Fork of Beaver Dam Wash Water Quality Measurements ...... 25 Table 3-3 Migratory Bird Species Documented in Washington County, Utah, That Have Conservation Status and Their Primary and Secondary Breeding and Wintering Habitats ...... 32 Table 3-4 Vegetation Communities Present in the Project Area ...... 35

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LIST OF FIGURES

Figure 1-1 Project Location Figure 1-2 Existing in the Project Area Figure 2-1 Proposed Disturbance Figure 3-1 Soils in the Project Area Figure 3-2 Vegetation Communities in the Project Area Figure 3-3 Nevada Willow Herb Habitat in the Project Area Figure 4-1 CIA Boundaries

LIST OF APPENDICES

Appendix A Interdisciplinary Team Checklist

LIST OF ACRONYMS & ABBREVIATIONS

ACEC Area of Critical Environmental Concern ATV All-Terrain Vehicle BLM Bureau of Land Management BMPs Best Management Practices CEQ Council on Environmental Quality CFR Code of Federal Regulations CIA Cumulative Impact Analysis DOGM Utah Division of Oil, Gas, and Mining EA Environmental Assessment EIS Environmental Impact Statement EPMs Environmental Protection Measures FLPMA Federal Land Policy and Management Act FONSI Finding of No Significant Impact Mining Law General Mining Law of 1872, as amended NEPA National Environmental Policy Act NOI Notice of Intent NRHP National Register of Historic Places Pilot Goldstrike Pilot Goldstrike Inc. Plan Plan of Operations Project Bull Valley Exploration Project RMP Resource Management Plan SHPO State Historic Preservation Office SITLA State of Utah State Institutional Trust Lands Administration UAC Utah Administrative Code UDEQ Utah Department of Environmental Quality U.S.C. United States Code UTV Utility Terrain Vehicle T Township R Range RFA Reasonably Foreseeable Action

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1.0 PURPOSE AND NEED

1.1 INTRODUCTION This Environmental Assessment (EA) has been prepared to disclose and analyze the environmental consequences of the Bull Valley Exploration Project (Project) as proposed in the Plan of Operations (Plan) by Pilot Goldstrike Inc. (Pilot Goldstrike) accepted and deemed complete by the BLM in May 2016 (letter from BLM to Pilot Goldstrike dated May 3, 2016). The EA is a site- specific analysis of potential impacts that could result with the implementation of a Proposed Action or alternatives to the Proposed Action. The EA assists the Bureau of Land Management (BLM) in project planning and ensuring compliance with the National Environmental Policy Act (NEPA), and in making a determination as to whether any “significant” impacts could result from the analyzed actions. “Significance” is defined by the NEPA and is found in regulation 40 Code of Federal Regulations (CFR) 1508.27. An EA provides evidence for determining whether to prepare an Environmental Impact Statement (EIS) or a statement of “Finding of No Significant Impact” (FONSI). If the decision maker determines that this Project has “significant” impacts following the analysis in the EA, then an EIS would be prepared for the Project. If not, a Decision Record may be signed for the EA approving the selected alternative, whether the Proposed action or another alternative. A Decision Record, including a FONSI statement, documents the reasons why implementation of the selected alternative would not result in “significant” environmental impacts (effects) beyond those already addressed in the St. George Field Office Record of Decision and Resource Management Plan (RMP) (BLM, 1999).

1.2 BACKGROUND As described in the Plan, Pilot Goldstrike proposes to conduct surface exploration activities at the Project, which is located approximately 38 road miles northwest of St. George, Utah, in Washington County, in part or all of Sections 16 through 23, 26, and 30, Township (T) 39 South, Range (R) 18 West, Sections 13 through 16, 23 through 27, and 33 through 36, T39S, R19W, and Sections 1 and 2, T40S, R19W, Salt Lake Base and Meridian (Project Area). The Project encompasses only the proposed disturbance areas, which make up a relatively small portion of the area encompassed within the property boundary (Figure 1-1). The area is in the Bull Valley Mountains in the historic Goldstrike mining district and can be accessed from St. George by travelling northwest from St. George for 14 miles on Old Highway 91, then north on Gunlock Road to Motoqua Road. After turning on Motoqua Road and travelling for 13 miles, the Project Area can be reached by turning onto Goldstrike Road and travelling an additional seven miles. The location of and the access to the Project Area relative to St. George and surrounding roads are shown on Figure 1-1.

Pilot Goldstrike is currently performing exploration activities on public lands administered by the BLM Color County District Office, St. George Field Office and on private lands within the Project

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Area. The authorized surface disturbance on BLM-administered public lands is 3.66 acres, and authorized disturbance on private lands is 6.10 acres, for a total of 9.76 acres. Existing exploration activities on BLM-administered public lands were authorized under a BLM Notice of Intent (NOI) (UTU-91149). A NOI (E/053/0065) from the Utah Division of Oil, Gas, and Mining (DOGM) authorized the 6.10 acres of exploration-related surface disturbance on private land.

The proposed Project would expand the existing authorized exploration activities to include additional exploration activities within the 907-acre Project Area. The additional proposed exploration activities would be created incrementally and would include exploratory drilling; road, drill pad, and sump construction; and the maintenance of existing roads constructed prior to 1981. The proposed additional surface disturbance associated with these additional exploration activities would measure up to approximately 67.24 acres, for a total surface disturbance of up to 77.0 acres (authorized and proposed). The Project Area would include approximately 753 acres of BLM- administered public lands and approximately 148 acres would occur on private land. The remaining approximately 7 acres would occur on State of Utah lands that have been leased to Pilot Goldstrike. Figure 1-2 only shows the location of existing surface disturbance as well as land ownership and administration within a portion of the Project Area.

In accordance with 43 CFR 3809 and Utah Administrative Code (UAC) R647-2-109, Pilot Goldstrike submitted a revised Plan of Operations (BLM UTU-091579 and DOGM E/053/0069) Reclamation Permit (Plan) in February 2016 (revised April 2016) to the BLM and the Utah DOGM.

1.3 PURPOSE AND NEED FOR THE PROPOSED ACTION On lands open to location under the General Mining Law of 1872, as amended (Mining Law), the BLM administers the surface of public lands and federal subsurface mineral estate under the Mining Law and the Federal Land Policy and Management Act of 1976 (FLPMA). The FLPMA also governs BLM’s administration of public land not open to location under the Mining Law.

The purpose of the Proposed Action is to provide Pilot Goldstrike the opportunity to explore, locate, and delineate precious metal (gold) deposits on its mining claims on public lands, as provided for under the Mining Law. The need for the action is established by the BLM's responsibility under Section 302 of the FLPMA and the BLM Surface Management Regulations at 43 CFR 3809, to respond to a plan of operations and to allow an operator to prospect, explore, and assess locatable mineral resources on public lands, and take any action necessary to prevent unnecessary or undue degradation of the lands.

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1.4 DECISION TO BE MADE The decision the BLM will make based on the NEPA analysis is whether or not to approve the plan of operations to allow Pilot Goldstrike to conduct proposed exploration activities, and under what terms and conditions.

1.5 CONFORMANCE WITH BLM LAND USE PLAN(S) The Proposed Action described in this EA is in conformance with the RMP (BLM, 1999). Specifically, on page 2.7 in the RMP, under the heading “Energy and Mineral Resources” subtitled “Objectives”, the RMP states:

“…BLM’s objectives for energy and mineral resources will be to: b) provide continued opportunity for exploration and development under the mining and mineral leasing laws by leaving public lands open for such purposes consistent with and subject to reasonable measures allowed by law needed to protect the environment…”

On page 2.8 in the RMP, Objective MI-07 states that “public lands in Washington County will remain available to mining location under the General Mining Act of 1872…”

1.6 RELATIONSHIP TO STATUES, REGULATIONS, AND OTHER PLANS The Proposed Action is consistent with federal environmental laws and regulations, Executive Orders, and Department of Interior and the BLM policies, including the following:

• FLPMA and the associated regulations at 43 CFR, Part 2800; • NEPA and the associated Council on Environmental Quality (CEQ) regulations at 40 CFR §§ 1500 – 1508; • National Historic Preservation Act (1966), as amended and the associated regulations at 36 CFR Part 800; • Native American Graves Protection and Repatriation at 25 U.S.C. Chapter 32; • Bald and Golden Eagle Protection Act (1962); • Endangered Species Act (1973), as amended; • Migratory Bird Treaty Act (1918); and • BLM Manual 6840 – Special Status Species Management.

The Proposed Action would require notification or permits consistent with UAC R647-2, which address mineral exploration regulations for the State of Utah.

The Proposed Action is consistent with the objectives and management direction provided in the Washington County General Plan (Washington County, 2010). The Washington County General Plan states that roads needed for legitimate purposes should exist and be retained (page 27). The Washington County General Plan also identifies that there are minerals on public lands within the

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county, and when an application to develop these minerals is received, Washington County will work with the BLM (page 31). The use of public lands for mineral development is supported by the Washington County General Plan (page 31).

In 2009, Washington County developed the Washington County Resource Management Plan, which became a part of the Washington County General Plan. According to the Washington County Resource Management Plan (page 376 of the Washington County General Plan), the county is concerned that much of the land in the county is being closed to mineral exploration. The western part of the county has not been explored thoroughly to determine the full mineral potential for more large scale mineral developments. The county believes that minerals should be extracted with great care for the environment, but the good of the environment should not be used as a tool to close public lands to mineral extraction. Washington County supports multiple uses, sustained yield management of federal and state lands, including uses for mining and mineral exploration (page 382).

1.7 IDENTIFICATION OF ISSUES Scoping is a process for identifying issues related to a proposed project. An issue is defined as a point of disagreement, debate, or dispute with a proposed action based on some anticipated environmental effect. Issues point to environmental effects and may lead to identification of design features incorporated into the proposed action, mitigation measures, or other alternatives.

Public notification of the Proposed Action and forthcoming EA preparation were provided by the BLM early in the NEPA process. The Plan was made available to the public on August 15, 2016, and comments were requested by September 14, 2016. A public scoping meeting was held on August 22, 2016, at the Dixie Convention Center to discuss the proposed Project with interested members of the public. Notice of the public meeting was published on the BLM website on August 16, 2016, and also appeared in the St George News online publication on August 22, 2016 (https://www.stgeorgeutah.com/news/archive/2016/08/22/jla-goldtrike-mining-could-rise-again- public-meeting-tonight/#.V8x28fkrKUk). A total of seven public scoping letters were received during the public scoping period. Commenters raised resource and procedural issues of concern relative to:

• Impacts to the Area of Critical Environmental Concern (ACEC) and its management goals; • Impacts to water quality; • The need for cultural surveys and tribal consultations; • The costs of reclamation; • The need to provide continued public access; • The need to assess potential existing soil contamination; • Impacts to wildlife, including special status species and wildlife migration;

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• Impacts to hunting wildlife; • Impacts to recreation including hunting and ATV usages and trails; • Impacts to visual resources; • Impacts on air quality including fugitive dust, ozone, precursors, particulates, and greenhouse gases; and • Socioeconomic impacts include road access and economics of reclamation.

A summary of the scoping comments and the BLM responses is included in Section 6.0.

The BLM utilized an Interdisciplinary Team Checklist (IDT) and public scoping comments to identify issues. The resources and issues considered by the IDT are provided in the IDT Checklist (Appendix A). The IDT Checklist includes a discussion of resources and issues not present (NP) and a discussion of resources/issues where the resource would not be impacted to the degree that further analysis is needed (NI). The resources/issues identified as NP and NI are not analyzed further in this EA. In the checklist, BLM resource specialists also identified the resources and other issues (including supplemental authorities) that may be impacted by the Proposed Action. These are identified in the Checklist as resources/issues where a potential impact (PI) is anticipated. These PI issues are carried forward for further analysis and are analyzed in detail in this EA.

As a result of internal and external scoping, the issues carried forward for further analysis are summarized below.

1.7.1 Water Resources/Quality During operations and following reclamation until revegetation occurs it is possible that some sediment could reach the East Fork of the Beaver Dam Wash.

1.7.2 Areas of Critical Environmental Concern There are three proposed drill sites that are entirely within the Beaver Dam Wash ACEC and another ten sites that are within 200 meters of the ACEC boundary.

1.7.3 Cultural Resources A Class III cultural resource inventory will need to be completed in compliance with Section 106 of the National Historic Preservation Act and BLM will need to consult with the Utah State Historic Preservation Office (SHPO) regarding effects.

1.7.4 Paleontology There are two recorded paleontology sites within vicinity of the Project area and are in one of the predominate geologic layers where the drilling will occur. There are no direct impacts to either of the sites based on the proposed drilling sites, but as they are in the same geologic unit it is reasonable that other sites will exist.

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1.7.5 Cave and Karst The Project covers a karst terrain and the Project Area has not been inventoried for caves or karst features to date.

1.7.6 Socio-Economics Despite the small size of the operation, the economic impact could be significant to some local businesses, particularly those working to support and supply the operation.

1.7.7 Soils Some soil would be lost from the area during operations and following until re-vegetation is reestablished.

1.7.8 Fish and Wildlife Several BLM sensitive animals could occur in the Project Area.

1.7.9 Migratory Birds Migratory birds may be impacted. Greatest impacts would be during their nesting period (March to August).

1.7.10 Vegetation One BLM Sensitive plant may occur in the Project Area (Nevada willowherb).

1.7.11 Recreation There are three main recreation activities that could be impacted by the Proposed Action. Conversely, these activities could also have impacts on drilling operations. Those activities include: hunting; off-road vehicle recreation; and wilderness therapy.

1.7.12 Visual Resources The Proposed Action is entirely within Visual Resource Management Class III. Drilling operations for an exploratory operation like this one would likely meet VRM Class III objectives, but given the number of drill holes and miles of new and re-opened roads, cumulative impacts to the visual landscape should be examined.

1.7.13 Lands with Wilderness Characteristics. There are a total of 251 proposed drill sites located on public lands. Of those 251 sites, 91 are within areas that have wilderness characteristics. Wilderness characteristics on the disturbed acres will be lost for several years regardless of reclamation success. However, based on the appearance of other reclaimed roads and drill sites in the area, it is anticipated that wilderness characteristics would be re-established within ten years.

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Lands with wilderness characteristics are different from lands that have been designated as Wilderness Study Areas or Wilderness. Lands with wilderness characteristics refers to lands that met several criteria specified in BLM Manual 6310 (BLM, 2012a) when inventoried.

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2.0 DESCRIPTION OF ALTERNATIVES, INCLUDING PROPOSED ACTION

2.1 INTRODUCTION Pilot Goldstrike is currently authorized to conduct surface disturbance within the Project Area under an existing NOI, and is proposing to expand exploration activities up to 77.0 acres within the Project Area.

2.2 ALTERNATIVE A – PROPOSED ACTION Pilot Goldstrike’s authorized exploration activities under the existing NOI include construction of drill sites and roads. Pilot Goldstrike has also done concurrent reclamation on approximately two acres under the existing NOI. Authorized surface disturbance on public land is approximately 3.66 acres.

Proposed exploration activities include exploration drilling, road construction, drill pad construction, sump construction, maintenance of pre-1981 roads, and concurrent reclamation as appropriate. The proposed disturbance would create approximately 67.2 acres of new surface disturbance in addition to the existing disturbance for a total of up to 77.0 acres within the Project Area. The existing surface disturbance and general areas of the proposed Project disturbance are shown on Figures 1-2 and 2-1, respectively. Table 2-1 shows the total authorized and proposed surface disturbance acreage for the Project. Table 2-2 shows existing and proposed drill sites by land status for the Project.

Table 2-1 Existing and Proposed Surface Disturbance Associated with the Project Surface Ownership BLM State Private Total Existing Disturbance Constructed Roads 2.44 - 4.37 6.81 Constructed Sites (including sumps) 1.22 - 1.73 2.95 Subtotal Existing Disturbance 3.661 - 6.10 9.76 Proposed Disturbance Constructed Roads 52.42 0.36 2.96 55.74 Constructed Sites (including sumps) 8.92 0.14 2.44 11.50 Subtotal Proposed Disturbance 61.34 0.50 5.40 67.24 Total Project Disturbance 65.0 0.50 11.5 77.0 1 Up to 3.66 acres of exploration disturbance on public land is approved under the existing NOI.

Table 2-2 Existing and Proposed Drill Sites by Land Status Surface Ownership BLM State Private Total Authorized 38 0 48 86 Proposed 213 4 65 282 Total 251 4 113 368

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The Project consists of unpatented lode mining claims, private ground, and a State of Utah lease in the Bull Valley Mountains, western Washington County, Utah. The Project Area in total covers parts of three townships and is located within the area legally described as Sections 16, 17, 19-23, 26, 30, Township (T) 39 South (S), Range (R) 18 West (W), Sections 13-16, 23-27, 33-36, T39S, R18W, and Sections 1 and 2, T40S, R19W, Salt Lake Baseline and Meridian.

Surface Ownership The Project Area in total encompasses approximately 907 acres and is defined as the disturbance area from proposed drill pads and new access roads, plus a 150-foot buffer around each these areas, plus a 10-foot buffer on either side of all existing/reclaimed access roads to be used for exploration activities. Surface ownership within the Project Area is managed by the BLM, State of Utah State Institutional Trust Lands Administration (SITLA), or by private owners. The surface ownership is shown in Figure 2-1.

The following sections describe the general operating procedures, construction techniques, and equipment Pilot Goldstrike anticipates using for the Project.

2.2.1 Drill Sites and Drilling Procedures Pilot Goldstrike proposes to build approximately 368 drill sites over a period of 10 years. The approximate locations of the drill sites are illustrated on Figure 2-1; however, the exact locations of the drill sites may be adjusted as drilling results become available. Further, up to ten drill holes could be drilled from a single pad (depending on results) to maximize the drill coverage of an area while working to minimize additional disturbance. Drill sites would have working areas that measure approximately 30 feet wide by 70 feet long.

Sumps would be installed at each drill site to contain cuttings and manage drilling fluids. Sumps are included within the disturbance of each drill site and would measure approximately 14 feet long, 30 feet wide, and seven feet deep. Sumps would be designed to be zero-discharge facilities from surface discharge and would be constructed in the cut side of the slope instead of in the fill material. As a safety measure, sumps would be engineered to have egress for climbing out or fencing around the sump to prohibit wildlife or livestock access. Sumps are often built as multi- chambered pits to prevent surface overflow, but it is assumed that the water in a drill pad would naturally drain/percolate into the alluvium over time, leaving the drill cuttings behind in the sump. Sumps are filled in at the end of the year/drill program for safety reasons. Sumps would remain open until after all fluids have dried up and the drill pad would not likely be reoccupied (usually three to four weeks after drilling), or if there is winter shutdown of operations.

Drilling of exploration holes would be completed by utilizing track-mounted or truck-mounted reverse circulation or core drill rigs and support equipment. Up to five drill rigs would operate in the Project Area at a given time. Drill holes would be both angled and vertical with drill depths of

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up to 1,500 feet but on average would be 500 feet. Drill holes would range in diameter from three to six inches. If ground water is encountered, the hole would be plugged pursuant to UAC R647- 2-108. Up to three drill holes may remain open at any one time. All holes would be plugged within 30 days unless specifically approved to be open longer. Hole abandonment reports would be completed for each hole drilled, and would detail any water encountered, flows of said water, and the plugging materials used. They would be signed by the driller and be available for any agency to review.

Pilot Goldstrike would follow standard drilling procedures and require a company representative to be on site or on call throughout drilling activities. The company representative would monitor and coordinate the layout and construction of each drill site, the setup of the drill rig, drilling progress, demobilization, and cleanup of the drill site. A company geologist would also coordinate drilling activities, log each hole according to the geologic features encountered, determine the maximum depth of each hole, and advise the drill operator as needed.

2.2.2 Road Construction and Access Main Access Roads The Project Area would be accessed from Utah State Highway 8, which turns into Old Highway 91 north of Ivins (Figure 1-1). The primary access would be from the Motoqua Road, an improved, all-weather road one half mile past the Gunlock turnoff, which is taken for approximately seven miles to another gravel road, Goldstrike Road, which turns north to the Project Area. Once in the Project Area, a variety of existing roads also occur as shown on Figure 2-1 that would provide access to exploration areas.

Exploration Roads The running width for overland travel routes is estimated to be approximately six feet and for constructed roads is estimated to average 12 feet. Exploration roads that require earth-moving would be constructed using typical construction practices for temporary mineral exploration roads to minimize surface disturbance, erosion, and visual contrast, as well as to facilitate reclamation. Road construction would be implemented using a dozer, excavator, or equivalent equipment. An excavator would be used on roads on slopes greater than 30 percent. Road grades would be no steeper than 10 percent, except for short drill spurs, in order to be consistent with the BLM Roads Manual #MS 9113 (BLM, 2015).

Balanced cut-and-fill construction would also be used to the extent practicable to minimize the exposed cut slopes and the volume of fill material. Since the depth of the cut would be kept to a minimum, growth media removed during construction would be stockpiled as the fill slope to be used during reclamation.

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Road construction within drainages would be avoided where possible. When drainages must be crossed by a road, Best Management Practices (BMPs) established by the Utah Department of Environmental Quality (UDEQ) would be followed to minimize the surface disturbance and erosion potential. Culverts may also need to be installed as necessary in order to minimize erosion to roadways.

It is not anticipated that blasting would be necessary to construct roadbeds. If drilling and blasting of exploration drill roads should become necessary, prior to blasting the operator would submit an approved safety plan to the BLM and DOGM.

Road Maintenance Pilot Goldstrike may need to perform routine road maintenance. Maintenance activities would consist of smoothing ruts, filling holes with fill material, grading, and re-establishing water bars where necessary. In addition, Pilot Goldstrike may need to armor some existing pre-1981 roads and the exploration roads with gravel to minimize excess disturbance and control dust.

During peak drilling activity, 4,000-gallon water trucks could make up to 15 daily trips on the road to the D.I. Ranch or Bracken property. It is estimated that up to 200 drilling days per year could occur for the life of the Project. If undue degradation occurs to the road between the Project Area and the D.I. Ranch, Pilot Goldstrike would minimize the impacts by grading, applying gravel, or by utilizing other dust control measures. If required by BLM or local authorities, Pilot Goldstrike would bring in road repair equipment to restore the road to drivable conditions.

Newly re-opened or rehabilitated roads would be “bermed off” when drilling is completed to restrict access.

2.2.3 Equipment Project personnel would access the Project Area in four-wheel drive vehicles. One or more truck- mounted, track-mounted, or articulated buggy-mounted reverse circulation or core drill rigs would be used for drilling in the Project Area. The following vehicles and equipment could be used over the life of the Project:

• Three reverse circulation truck-mounted, track-mounted, or articulated buggy-mounted rotary drill rigs; • Two truck-mounted, track-mounted, or articulated buggy-mounted core rigs; • Two or more 2,000 to 4,000-gallon water trucks; • Four or more all-terrain vehicles; • Two or more pipe trucks; • Two or more booster trucks; • One or more excavators with hydraulic hammer;

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• Two or more auxiliary air compressors; and • Two or more portable light plant/generators.

Generally, a Cat D7 or D8H bulldozer or equivalent would be used to construct the roads and drill sites where needed. Roads and drill sites would be reclaimed using a bulldozer and/or a Cat 325 L or Cat 350 front-end excavator or equivalent.

2.2.4 Water Needs and Use Water would be used for dust suppression and during drilling to cool the drill bit and remove drill cuttings. Water would be utilized with or without nontoxic drilling additives.

Pilot Goldstrike would lease 6.0 acre-feet of water from the D.I. Ranch for drilling. Water would be trucked from a surface diversion point in T40S, R19W, Section 17, approximately 10 miles southwest of the Project Area. Pilot Goldstrike would also lease 1.0 acre-feet of water from the Claude Bracken Family Living Trust for drilling. Water would be trucked from a surface diversion point on private property in T39S, R18W, Section 17, approximately 0.5 mile northeast of the Project Area. Water trucks with a capacity of 4,000 gallons would be used to fill a 10,000-gallon water tank or bladder that would be located on the project laydown area. Smaller 1,500-gallon capacity water trucks would pull off this tank for their water needs, thus keeping the number of trips made to the water source by the smaller trucks to a minimum.

2.2.5 Work Force Standard drill rig crews would consist of a drill operator and one or two helpers. The helpers normally remove and box the recovered core samples, the cuttings from reverse circulation rigs, mix drilling fluids in the portable mud tank, operate the water truck, assist with drilling operations, and conduct maintenance as necessary. The crew would be transported to and from the drill site in up to three four-wheel drive vehicles per drill rig or a drilling company operated crew van. Drill crews would work a 12-hour day for up to 15 days and on occasion a second shift may be added to work 24 hours a day.

2.2.6 Surface Water and Groundwater Control BMPs for sediment control would be utilized during construction, operation, and reclamation to minimize sedimentation from disturbed areas. Proposed construction and drilling activities would avoid springs and seeps, if present. In order to facilitate proper drainage and prevent erosion, all bladed roads would have water bars, lead-off ditches, and culverts constructed, as needed, at BLM- recommended spacing.

Sediment control structures would include, but are not limited to, fabric or certified weed-free straw bale filter fences, siltation or filter berms, sumps, and down-gradient drainage channels in

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order to prevent unnecessary or undue degradation to the environment. Sediment traps (sumps), constructed, as necessary, within the drill pad disturbance, would be used to contain drill cuttings.

A Stormwater Construction Permit would also be required under the Utah Pollutant Discharge Elimination System program, as the proposed disturbance exceeds one acre. Pilot Goldstrike would prepare a Stormwater Pollution Prevention Plan as part of the permit. Drill sumps would also be engineered to be zero-discharge facilities.

2.2.7 Ancillary Facilities and Surface Occupancy Pilot Goldstrike anticipates establishing staging areas on flat terrain within the Project Area, on BLM, private, or state lands. A portable toilet facility would be placed at the staging area, as well as near active drill rigs. Equipment and facilities at the staging areas could include temporary trailers and storage containers. One of the trailers would be used as a core/chip logging facility. A portable diesel generator would also be used to supply electricity to this facility. Pilot Goldstrike would obtain all necessary permits for this facility including, however, not limited to, any air quality permits required by the State of Utah and any building permits required by Washington County.

Under 43 CFR 3715.0-5, occupancy means full-time or part-time residence on the public lands. It also means activities that involve residence; the construction, presence, or maintenance of temporary or permanent structures that may be used for such purposes; or the use of a watchman or caretaker to monitor activities. Residence or structures include and are not limited to, barriers to access, fences, tents, motor homes, trailers, cabins, houses, buildings, and storage of equipment or supplies. Pilot Goldstrike proposes to use up to two trailers for an office, core/chip logging, and core cutting; portable toilets, space for vehicle parking, and a materials laydown yard would be used at the Project. A materials laydown yard has been established in the NE¼NE¼ of Section 20, T39S, R18W (in the old Goldtown 1 Pit) on BLM land. The yard is approximately 70 feet by 80 feet in size. Workers would be on site overnight when drill rigs are operating 24 hours a day and working the night shift.

2.2.8 Solid and Hazardous Materials Management All refuse generated by the Project would be disposed of at an authorized landfill facility off site, consistent with applicable regulations. No refuse would be disposed of on site. Hazardous materials utilized at the Project Area would include diesel fuel, gasoline, and lubricating grease. Approximately 500 gallons of diesel fuel would be stored in fuel delivery systems on vehicles and drill rigs. It is anticipated that a 4,000-gallon diesel fuel storage tank would be utilized at the Project. The entire diesel fuel tank area would employ spill containment measures. Approximately 100 gallons of gasoline would be stored in fuel delivery systems for light vehicles. Approximately 100 pounds of lubricating grease would be stored on the drill rigs or transported by drill trucks.

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All containers of hazardous substances would be labeled and handled in accordance with Utah Department of Transportation and Mining Safety and Health Administration regulations. In the event that a reportable quantity of hazardous or regulated materials, such as diesel fuel, is spilled, measures would be taken to control the spill, and UDEQ, and the Emergency Response Hotline would be notified, as required. If any oil, hazardous material, or chemicals were spilled during operations, they would be cleaned up in a timely manner. After clean up, the oil, toxic fluids, or chemicals and any contaminated material would be removed and disposed of at an approved disposal facility.

2.2.9 Reclamation Reclamation would be completed to the standards described in 43 CFR 3809.420 and UAC R647- 2-109. Reclamation would meet the reclamation objectives as outlined in the United States Department of Interior Solid Minerals Reclamation Handbook #H-3042-1 (BLM, 1992), Surface Management of Mining Operations Handbook H-3809-1 (BLM, 2012b), and revegetation success standards per The Practical Guide to Reclamation in Utah (DOGM, Undated). Although much of the Project Area terrain is very steep, overland travel and existing roads would be utilized as much as possible, minimizing the need for road construction. All Pilot Goldstrike drill sites, sumps, overland travel, and road construction would be re-contoured and reseeded.

Reclamation would be designed to achieve post exploration land uses consistent with the BLM’s RMP (BLM, 1999). Reclamation is intended to return disturbed land to a level of productivity comparable to pre-exploration levels. Post-exploration land use includes wildlife habitat, livestock grazing, hunting, and dispersed recreation. The post-exploration land use is not expected to differ from pre-exploration land use.

During exploration activities, Pilot Goldstrike would manage drilling to contain cuttings and manage drilling fluids, monitor road conditions, and keep sites clean and safe. The BLM and DOGM would be notified prior to any periods of inactivity greater than 120 days.

After exploration activities are terminated, reclamation would involve regrading disturbed areas related to this Project to their approximate original contour. The Project would then be seeded using the approved reclamation seed mixture and application rates (see Section 2.2.9.4). Overland travel routes would be scarified and reseeded, if necessary. Yearly visits to the site would also be conducted to monitor the success of the revegetation for a period of at least three years or until revegetation success has been achieved per “The Practical Guide to Reclamation in Utah” (DOGM, Undated).

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2.2.9.1 Schedule of Reclamation Reclamation activities would be conducted concurrently with exploration activities when the disturbance is no longer needed. Reclamation would begin within exploration areas considered inactive, without potential, or completed, at the earliest practicable time. Earthwork and revegetation activities are limited by the time of year during which they can be effectively implemented. Table 2-3 outlines the anticipated reclamation schedule on a quarterly basis. Site conditions or yearly climatic variations may require that the proposed schedule be modified to achieve revegetation success. Reclamation activities would be coordinated with the BLM and DOGM when necessary. Revegetation is anticipated to take three years after the time of seeding to achieve success.

Table 2-3 Anticipated Exploration Reclamation Schedule Quarter 1st Techniques 2nd 3rd 4th Year(s) Jan- Apr-Jun Jul-Sep Oct-Dec Mar Regrading X X X Within one year of Project completion Seeding X Within one year of Project completion Monitoring X X Three years beyond regrading and seeding

2.2.9.2 Drill Hole Plugging All holes would be abandoned in accordance with the State of Utah Regulations for Exploration Hole Plugging Requirements (UAC R647-2-108) as well as BLM policies. For reverse-circulation holes, a bentonite slurry is poured down the hole at a rate of two minutes per bag. Periodically, the hole is probed to ensure that the top ten feet of each hole is not filled. The top ten feet of each hole is plugged with cement, which is batched in a mixer and poured down the hole.

For mud-rotary and core holes, the density of the mud slurry is measured at the completion of the hole and bentonite is added to bring the slurry density and viscosity to that specified in the regulation; which is:

• Increase mud viscosity by 20 seconds to at least 50 seconds; and • Ensure a mud weight of at least nine pounds per gallon.

After holes are filled to within 10 feet of the surface, the specified cement cap is poured. A wire tag designating the drill hole ID would be put in the cement cap for future reference. Most drill holes would be plugged immediately after drilling is completed and samples have been collected; only three drill holes may be left open at any time. All holes would be plugged within 30 days unless specifically approved to be open longer.

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2.2.9.3 Regrading and Reshaping Regrading and reshaping of all constructed drill sites and exploration roads would be completed to approximate the original topography. Fill material, enhanced with growth media, would be pulled onto the roadbeds to fill the road cuts and restore the slope to natural contours. Roads and drills sites would be regraded and reshaped with a frontend excavator or bulldozer. For overland travel roads, upgraded roads or pads that do not require replacement of sidecast material, reclamation would be accomplished with an excavator bucket/ripper or a dozer to knock down and smooth any berms and relieve road compaction. Tire tracks would be lightly scarified and left in a rough state as necessary to relieve compaction, inhibit soil loss from runoff, and prepare the seed bed.

Should any drainage be disturbed, they would be reshaped to approach the pre-construction contours. The resulting channels would be of the same capacity as up and downstream reaches and would be made non-erosive by use of surface stabilization techniques (rip-rap) where necessary, and ultimately revegetated. Following completion of earthwork, all disturbed areas would be broadcast seeded.

2.2.9.4 Revegetation Recontouring of drill pads, sumps and, if necessary, roads, would be the primary means by which seedbeds would be prepared. During seed placement, the ground surface would be roughened by dragging a chain harrow or other suitable implement. Leaving a roughened surface would provide greater opportunities for seed and moisture to be trapped and held. Additional benefits include slower runoff, increased infiltration, and in general, more favorable microclimates conducive to seed germination.

Seeding procedures would be dependent upon site characteristics. Recontoured pads, sumps, and roads with severe slopes would be seeded with hand-held broadcast seeders. An electric broadcast seeder mounted on an all-terrain vehicle (ATV) would be used on roads with gentle slopes. A chain drag mounted behind the ATV would be used to cover the seed. A reclamation seed mix for the proposed Project would be developed in coordination with the BLM and DOGM.

Noxious Weed Control To prevent and control the introduction and spread of noxious weeds within the Project Area during reclamation activities, Pilot Goldstrike would implement the following prevention and control practices:

• Growth media (soil and alluvium) disturbance would be minimized to the extent practicable, consistent with Project objectives. Growth media would be stockpiled and used in reclamation.

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• Disturbed sites would be revegetated as soon as practicable when exploration work is completed. Activities would include topsoil replacement, planting, and seeding.

• The seed mixture would be certified pure live seed and weed free. Straw bales used for erosion control would also be certified as weed free.

• Pilot Goldstrike would ensuring all equipment is “weed free” by power washing all trucks, trailers, and all other machinery to remove any vegetative material and soil before transporting equipment to the drill site to help minimize the threat of spreading noxious and invasive weeds.

Pilot Goldstrike would also ensure that noxious weeds are identified in the Project Area, exclude noxious weeds from disturbed areas until reclamation has been accepted and released, ensure all equipment is weed free before traveling to and from the Project Area, and create a noxious weed inventory. If noxious weeds or other invasive species deemed detrimental by the BLM are found, a BLM weed specialist would be consulted and an appropriate treatment plan developed and implemented. Control standards and measures would comply with applicable State and Federal regulations. Weed treatments would include the use of herbicides, and only those herbicides approved for use on public lands by the BLM would be evaluated for use.

2.2.9.5 Handling and Application of Topsoil Whenever possible, and primarily on reasonably level terrain, topsoil would be graded and stockpiled to the uphill margin of the pad and sump cut. On steeper slopes, topsoil would be stored as side-cast along the periphery of the pads. Although this would mix the limited existing quantities of topsoil with the sub-soils, experience from past exploration and subsequent reclamation activities in the area has shown that the resulting surface soils can support vegetation. The alternative option of pushing topsoil uphill prior to cutting pads on steep slopes would result in a significant increase in surface disturbance due to bulldozers working “back-and-forth” below the proposed disturbance.

2.2.9.6 Removal or Stabilization of Building, Structures, and Support Facilities All logging/office trailers, portable toilets, generators, equipment, and supplies would be removed following completion of the Project. These facilities would be removed by being transported off site with trucks and/or trailers. Materials, including scrap, trash, and unusable equipment, would be removed on a daily or weekly basis and disposed of in accordance with federal and state regulations and laws. Facilities removal would be completed within sixty to ninety days after operations conclude.

2.2.9.7 Previous Reclamation Previous operators have disturbed approximately 655 acres within the Project Area including: drill roads; open pits; mine dumps; mine roads; and other facilities. Approximately 519 acres were

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reclaimed in the 1990s, and approximately 136 acres are still open (such as access roads and pit highwalls). In addition, approximately 88 miles of exploration drill roads were built within the Project Area, of which approximately 41 miles have been reclaimed. The DOGM has confirmed that reclamation obligations for these disturbances have been fully met.

2.2.10 Environmental Protection Measures Pilot Goldstrike commits to the following environmental protection measures (EPMs) to prevent unnecessary or undue degradation during construction, operation, and reclamation of the Project. The measures are derived from the general requirements established in the BLM’s Surface Management Regulations at 43 CFR 3809 and DOGM mining reclamation regulations, as well as water, air quality, and other environmental protection regulations.

Air Quality Emissions of fugitive dust from disturbed surfaces would be minimized by the application of water from a water truck as a method of dust control. A Fugitive Dust Control Plan is not required by the State of Utah for this Project, but the Project would be required to comply with Fugitive Dust rules at R307-205-5 during construction activities.

Native American Religious Concerns Pursuant to 43 CFR 10.4(g), Pilot Goldstrike would notify the BLM authorized officer, by telephone, and with written confirmation, immediately upon the discovery of human remains, funerary objects, sacred objects, or objects of cultural patrimony (as defined in 43 CFR 10.2). Further pursuant to 43 CFR 10.4 (c) and (d), the operator would immediately stop all activities within a 100-foot buffer of the discovery and not commence again for 30 days or when notified to proceed by the BLM authorized officer.

Cultural Resources Any cultural resource discovered by Pilot Goldstrike, or any person working on their behalf, during the course of activities on federal land would be immediately reported to the authorized officer by telephone, with written confirmation. The permit holder would suspend all operations in the immediate area of such discovery and contact the BLM, the BLM would treat the discovery in accordance with 36 CFR 800.13. This evaluation would determine the significance of the discovery and what mitigation measures are necessary to allow activities to proceed. The holder is responsible for the cost of evaluation and mitigation. Operations may resume only upon written authorization to proceed from the authorized officer.

Paleontological Resources In the event that previously undiscovered paleontological resources are discovered in the performance of any surface disturbing activities, the item(s) or condition(s) would be left intact

BULL VALLEY EXPLORATION PROJECT ENVIRONMENTAL ASSESSMENT MAY 2017 PILOT GOLDSTRIKE INC. 18 and immediately brought to the attention of the authorized officer of the BLM. If significant paleontological resources are found, avoidance, recordation, and data recovery would be required.

Areas of Critical Environmental Concern Surface disturbance for any drill sites constructed within the Upper Beaver Dam Wash ACEC would be kept to the minimum needed for safe and effective exploration activities. Whenever possible, cross-country travel would be used in lieu of road construction.

Cave and Karst Pilot Goldstrike would inspect areas of higher potential karst forming units (Redwall Limestone, Callville Limestone, and Pakoon Dolomite) and coordinate with the BLM prior to disturbance of those areas.

Forestry and Fire Management Pilot Goldstrike would comply with all applicable state and federal fire laws and regulations and all reasonable measures would be taken to prevent and suppress fires in the Project Area. Pilot Goldstrike would take steps to prevent fires by ensuring that each field vehicle carries hand tools and a fire extinguisher. Water trucks used for the Project would also be used in the event of fire.

Although the majority of the Project Area has been burned during past wildland fires, any new road construction would attempt to avoid, if possible, unburned pinyon and juniper trees.

Noxious Weeds and Invasive, Non-Native Species Noxious weed surveys would be conducted prior to site use. If noxious weeds or other invasive species deemed detrimental by the BLM or DOGM are found, a BLM or DOGM weed specialist would be consulted and an appropriate treatment plan developed and implemented. Control standards and measures would comply with applicable State and federal regulations. Weed treatments may include the use of herbicides, and only those herbicides approved for use on public lands by the BLM would be evaluated for use.

Access and Safety Public safety would be maintained throughout the duration of the Project. All equipment and other facilities would be maintained in a safe and orderly manner. Signage would be placed warning the public that the area is an active exploration site and heavy equipment traffic may be present. Project activities would not block public access along roads in the Project Area. In addition, during hunting season, Pilot Goldstrike would be proactive in communicating with campers/hunters on Project activities and, if needed, could potentially modify drilling activities temporarily to avoid campsites in the area. Any survey monuments, witness corners, or reference monuments would be protected

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to the extent economically and technically feasible. Any identified public hazards such as open historic mine workings would be secured per DOGM standards.

Migratory Birds Land clearing or other surface disturbance associated with Project-related activities would be conducted outside of the avian breeding season, whenever feasible, to avoid potential destruction of active bird nests or young birds in the area. Areas to be surveyed are limited to vegetated zones where proposed surface disturbance (e.g. drill pads, sumps, associated access roads, etc.) would be located. Surveys would be completed every two weeks from April 1 through May 31, then every 30 days through August 15, or during periods determined by BLM. The area to be surveyed would include a 100-foot buffer around proposed surface disturbance, and would vary with each survey. If active nests are located, or if other evidence of nesting (i.e., mated pairs, territorial defense, carrying nesting material, transporting food) is observed, a protective buffer (the size depending on the habitat requirements of the species) would be delineated and the entire area avoided to prevent destruction or disturbance to nests until they are no longer active. If construction activities occur during the primary raptor nesting period (February 1 through April 1), a raptor nesting survey would need to be completed in areas proposed for disturbance prior to this time period. The start and end dates of the seasonal restriction may be based on site-specific information, such as elevation and winter weather patterns, which affect breeding chronology.

Wildlife and Range Resources Sumps would be engineered to have egress for climbing out or fencing around the sump to prohibit wildlife or livestock access.

Water Resources Exploration drill holes would be surveyed and plugged as an operational procedure immediately after completion of drilling in accordance with UAC R647-2-108. The drill holes would be plugged by placing bentonite grout or a neat cement plug into the top 10 feet of the hole, or if ground water is encountered, plugged as a well pursuant to UAC R647-2-108.

Stormwater BMPs would be used at construction sites to minimize erosion from stormwater. BMPs such as check dams (e.g., weed-free straw bales, coir rolls, placed on-site rock) would be used to slow and disseminate discharge water from pump tests to decrease erosion and sedimentation to surface waters.

Wastes Pursuant to 43 CFR 8365.1-1(b)(3), no sewage, petroleum products, or refuse would be dumped from any trailer or vehicle. All solid wastes would be disposed of in a state, Federal, or local designated site.

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Only non-toxic fluids would be used in the drilling process.

Drill cuttings would be contained and the fluids managed utilizing appropriate control measures. Sediment traps would be used as necessary and filled at the end of the drill program.

2.3 ALTERNATIVE B – NO ACTION The NEPA requires that an alternative of No Action be analyzed in an EA. Under the No Action Alternative, the Proposed Action would not be approved. Pilot Goldstrike could continue exploration activities under their approved NOI for approximately 3.66 acres of surface disturbance on public land. Activities associated with this total surface disturbance includes construction of drill sites and roads.

2.4 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED ANALYSIS The number of alternatives considered is limited by the location of the mineralized deposit. Pilot Goldstrike considered an alternate access route continuing north along the Gunlock Road to access the Project Area from the northeast. However, this road is a dirt and ungraveled road that would require more improvements than the proposed access route along the Motoqua Road and Goldstrike Road and result in many more acres of surface disturbance. This alternative was not considered financially or environmentally feasible and was, therefore, eliminated from detailed analysis.

Other alternatives considered included not conducting exploration activities in lands that have wilderness characteristics, limiting exploration activities to occur only within previously disturbed and/or reclaimed areas, and not conducting exploration activities in the Upper Beaver Dam Wash ACEC. However, each of these alternatives that would limit proposed exploration activities, would not meet the Purpose and Need of the Project as described in Section 1.3, since Pilot Goldstrike has the right to conduct exploration activities on their mining claims on public lands, as provided for under the Mining Law and the BLM's responsibility under Section 302 of the FLPMA and the BLM Surface Management Regulations at 43 CFR 3809. Thus, these alternatives were considered but eliminated from detailed analysis.

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3.0 AFFECTED ENVIRONMENT

3.1 INTRODUCTION This section describes the existing environment of the area that would be affected by the No Action Alternative or the Proposed Action, and Chapter 4 discloses the potential impacts of these alternatives. Resources associated with supplemental authorities are listed in Appendix 1 of the BLM NEPA Handbook H-1790-1 (BLM 2008). Resources that were determined to be unaffected by the Proposed Action are summarized in Table 3-1 and eliminated from further discussion in this EA. Table 3-1 is based on the results of the BLM’s ID team checklist, which can be found in Appendix A. The elimination of non-relevant resources is consistent with 40 CFR 1500.4. Resources or uses that may be affected by the Proposed Action are analyzed in the remainder of this chapter.

Table 3-1 Resources Eliminated from Detailed Analysis in this Environmental Assessment Resource Rationale/Reference Section Dust emissions levels have the potential to increase during operations, Air Quality however if BMPs described in the Plan of Operations are followed the impacts to air quality would be minimal. The Proposed Action is not expected to increase greenhouse gas Greenhouse Gas Emissions emissions. Wastes If BMPs identified in the Plan of Operations are followed the impacts (hazardous or solid) from any hazardous waste spills would be minimal. The Proposed Action is unlikely to limit access to, or interfere with ceremonial use of sacred sites; nor, would it adversely impact the Native American Religious Concerns integrity of such known sites. However, the BLM would consult with Tribes regarding the undertaking. Continued exploration and drilling would benefit geology and mineral resources by providing additional information increasing the Geology / Mineral Resources / understanding of those resources. The Project Area is identified as being Energy Production prospectively valuable for oil and gas. A records search in LR2000 shows there are no authorized or pending leases for oil and gas or other leasable minerals. According to the EPA Region VIII, State of Utah, Environmental Justice Map, the region has been categorized as a minority population area of 10 to 20 percent and a poverty population area of 10 to 20 percent. Five to ten percent of the population speaks English “Less than Well”. These data show that low income and high minority populations are generally located in the St. George/Santa Clara/Washington areas in locations not adjacent to BLM managed lands (see http://epamap14.epa.gov/ejmap/entry.html, 11/29/12). Environmental Justice

However, it is likely that a low income, minority population is also present in the housing area on the east side of the Shivwits Paiute Reservation, and a low income population exists in the Hildale/Colorado City area. These populations are not distinct on census data due to having been lumped in with higher income low-minority areas in Ivins, Apple Valley, and Springdale.

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Resource Rationale/Reference Section No minority or economically disadvantaged communities or populations are present within or near the Project Area which could be affected by the Proposed Action. Farmlands (Prime or Unique) No prime or unique Farmlands are found in the Project Area. Floodplains No floodplains would be affected by the Proposed Action. During operations it is possible that some sediment could reach the East Fork of the Beaver Dam Wash; however, if the BMPs are followed it is Wetlands/Riparian Zones likely that any impact to the East Fork of the Beaver Dam Wash and its associated riparian areas would be minimal. Threatened, Endangered or No threatened or endangered plants are known to occur in the Project Candidate Plant Species Area. Threatened, Endangered or No threatened or endangered animals are known to occur in the Project Candidate Animal Species Area. The majority of the area has already been burned during a wildland fire Woodland / Forestry event. However, new road construction that occurs would avoid, if possible, unburned pinyon and juniper trees. EPMs to be implemented as part of the Proposed Action would minimize Fuels/Fire Management the chance of uncontrolled fires. Implementation of the EPMs, as outlined through noxious weed surveys, Invasive Species/Noxious Weeds consultation, and development and implementation of a treatment plan, (EO 13112) should result in no lasting adverse impacts as a result of the Proposed Action. There are no authorized rights-of-way or any other land use authorizations within the Project Area that could be impacted by the Lands/Access Proposed Action. This area is not being considered in any land tenure adjustments. The Proposed Action is not expected to adversely affect livestock Livestock Grazing grazing. The approved reclamation seed mix is made up of species preferred by livestock as well as wildlife. The Proposed Action is not likely to adversely affect Rangeland Health Rangeland Health Standards Standards with implementation of the reclamation plan (Section 2.2.9). There are no National Conservation Areas within or affected by the National Conservation Areas Proposed Action. National Historic Trails (Old Spanish The Proposed Action is not in the vicinity of, and would not impact, the Trail) Old Spanish Trail. National Recreational Trails The Proposed Action is not in the vicinity of the Gooseberry Mesa (Gooseberry Mesa) National Recreation Trail. There are no eligible, suitable, or designated Wild and Scenic River Wild and Scenic Rivers segments affected by the Proposed Action. The Proposed Action is not within designated wilderness or wilderness Wilderness/WSA study areas. There are 13 proposed drill sites within 0.7 miles of the Docs Pass Wilderness, but the wilderness area would not be impacted.

3.2 RESOURCES/ISSUES BROUGHT FORWARD FOR ANALYSIS The BLM has used environmental data collected in the Project Area to describe the affected environment and to predict environmental effects that could result from the No Action Alternative or the Proposed Action. A level of uncertainty is associated with any dataset in terms of predicting outcomes, especially when natural systems are involved. The predictions described in this analysis are intended to allow comparison of alternatives, as well as provide a method to determine whether

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activities proposed by Pilot Goldstrike would be expected to comply with applicable Federal, state, and local regulations.

The following is a list of resources that were determined to be potentially affected by the Proposed Action and are analyzed in the remainder of this chapter: Water Resources/Quality (drinking/surface/ground); Areas of Critical Environmental Concern; Cultural Resources; Paleontology; Cave and Karst; Socio-Economics; Soils; Fish and Wildlife; Migratory Birds; Vegetation; Recreation; Visual Resources; and Lands with Wilderness Characteristics.

The Project is located approximately 38 miles northwest of St. George in Washington County, Utah. The Project is in the Bull Valley Mountains of the Tonoquints Volcanic physiographic subdivision of the Basin and Range – Colorado Plateau Physiographic Province. The site consists of steep hilly terrain dissected by ephemeral drainages. Elevations in the Project Area range from approximately 4,400 to 5,800 feet amsl.

Climate data for Veyo, Utah (approximately 29 aerial miles east of the Project Area), indicates that the average annual precipitation is 14.55 inches, with average temperatures ranging from a minimum of 27 degrees Fahrenheit (°F) in January to a maximum of 93 °F in July (http://www.usclimatedata.com/climate/veyo/utah/united-states/usut0263).

3.2.1 Water Resources Groundwater Most of the Project Area is in the Upper Beaver Dam Wash Watershed (Hydrologic Unit Code [HUC] 1501001001). A small portion of the Project Area is in the Lower Santa Clara River Watershed (HUC 1501000808).

Groundwater in the Beaver Dam Wash area is present in both consolidated rocks and basin-fill and alluvial channel-fill deposits. Groundwater in consolidated rocks in the higher-altitude mountainous areas provides the base flow of perennial reaches of streams and discharge to springs. Groundwater in the basin-fill deposits provides the base flow to perennial reaches of Beaver Dam Wash and discharge to springs in the lower-altitude areas. Most groundwater withdrawals from wells are from the unconsolidated basin-fill deposits (U.S. Geological Survey, 1997). According to the U.S. Geological Survey (1997), groundwater recharge to the consolidated rocks in the Beaver Dam Wash area is from infiltration of precipitation and streamflow, and subsurface inflow. Between 1970 and 1995, the average annual recharge to the alluvial channel fill deposits was approximately 18,000 acre-feet per year (U.S. Geological Survey 1997). The safe yield of this aquifer would be an unknown percentage of the average recharge.

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Reviews of the historic drilling from Pilot Goldstrike (personal communication with Peter Shabestari, Regional Geologist) indicate that groundwater was rarely encountered and Pilot Goldstrike drilling confirms this to depths of ~600’. Perched ground water (less than 5 gpm) is occasionally hit while drilling through known fault zones and the hole always dries out afterward.

Surface Water Surface waters near or within the Project Area include the East Fork of Beaver Dam Wash and Arsenic Gulch, a tributary to the East Fork of Beaver Dam Wash. The East Fork of Beaver Dam Wash is an intermittent drainage throughout much of its length and flows as a result of irrigation returns, thunderstorms, and snow melt. Springs also contribute flow along short reaches. Upstream of the Project Area, flow in the wash is perennial; however, irrigation depletes most flow in the channel before it reach the Project Area (JBR, 1993). Surface flows are believed to be seasonal, or intermittent, within Arsenic Gulch.

In early May 2016, Stantec Consulting Services Inc. initiated a water sampling program at two sites along the East Fork of Beaver Dam Wash (Stantec, 2016b). The purpose of this sampling was to characterize baseline water quality conditions in the East Fork of Beaver Dam Wash. One sampling site (EFBDW-1) is located at an accessible stream reach just outside of the northern property boundary, while the other (EFBDW-2) is approximately 2.5 miles further downstream, within the property boundary and immediately downstream of Arsenic Gulch (Figure 3-1). Results from the May 2016 sampling event are presented in Table 3-2.

Table 3-2 May 2016 East Fork of Beaver Dam Wash Water Quality Measurements Parameter Sampling Site Upstream of the Project Area Downstream of the Project Area (EFBDW-1) (EFBDW-2) Flow Rate (gallons/minute) 1.6 210 pH (Standard Units) 8.8 9.4 Temperature (°C) 12.5 16.1 Specific Conductance 576 564 (microsiemens/centimeter) Total Dissolved Solids (milligrams/liter) 370 350 Nitrate-Nitrite (as N) (milligrams/liter) Not Detected Not Detected Source: (Stantec Consulting Services Inc., 2016b)

As shown in Table 3-2, sampling indicated that streamflow was very low and barely measurable at the upstream site. Flow increased significantly at the downstream site, although it was still quite low relative to the apparent channel capacity. Water temperature and pH increased in a downstream direction, with pH relatively high (alkaline) at both sites. Conductivity was relatively low and similar between the two sites. Laboratory analyses reflected the general pH and conductivity values: some carbonate was present but bicarbonate was the primary alkalinity component, and total dissolved solids were low at 370 and 350 mg/L at the upstream and

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downstream sites, respectively. Neither nitrate nor nitrite was detected at the 0.1 mg/L reporting limit at either site. Similarly, trace metals and metal-like elements were not detected in their dissolved state at either site. Total aluminum and total iron were detected at EFBDW-2 at concentrations greater than the reporting limit but were still low. The ion chemistry and ionic strength at the two sites were generally fairly similar; however, the upstream site (EFBDW-1) had somewhat higher calcium and somewhat lower sulfate than the downstream site (EFBDW-2). This difference in cation proportion is relatively minor and future sampling may indicate whether or not this is a true difference. Overall, there were no noteworthy, remarkable, or unusual results reported by the lab (Stantec, 2016a).

3.2.2 Areas of Critical Environmental Concern The designation of an ACEC is to highlight areas where special management attention is needed to protect, and prevent irreparable damage to important historical, cultural, and scenic values, fish, or wildlife resources or other natural systems or processes, or to protect human life and safety from natural hazards (BLM, 1988).

Portions of the Project Area are located within the Upper Beaver Dam Wash ACEC. The Upper Beaver Dam Wash ACEC is approximately 33,063 acres in size. In its upper reaches, the West Fork of Beaver Dam Wash maintains good water quality where it flows through granitic bedrock. The stream supports both warm and cold water fisheries, maintains a quality riparian system, and constitutes potential habitat for the Virgin spinedace (Lepidomeda mollispinus) and the endangered Southwestern willow flycatcher (Empidonax traillii extimus). The Upper Beaver Dam Wash ACEC is managed to preserve watershed integrity and water quality and to maintain or improve riparian resources and potential habitats for the Virgin spinedace and Southwestern willow flycatcher (BLM, 2011). The water is also used for agricultural purposes near the community of Motoqua, as well as feeding groundwater aquifers that are under consideration for well-field development to provide culinary water for St. George and neighboring communities.

3.2.3 Cultural Resources The National Historic Preservation Act requires that federal agencies take into account the effects of their undertakings on sites that are eligible for the National Register of Historic Places (NRHP) (historic properties). The Project qualifies as an undertaking as defined in 36 CFR 800.16(y).

In May of 2016, WSA Inc. completed a survey to identify cultural resources in the Project Area. Areas surveyed more than 10 years ago were resurveyed and areas with recent mining disturbance (between 1988 and 1996) were excluded from the survey area.

WSA, Inc. identified and recorded 11 new cultural resource sites and revisited, and rerecorded seven previously recorded sites during the cultural resources inventory. Eight of the sites are

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prehistoric artifact scatters, nine are historic era, primarily associated with historic mining, and one site contains prehistoric artifacts as well as historic era mining features. The BLM determined that 10 of the sites are eligible for listing on the NRHP.

3.2.4 Paleontology A complex geologic setting underlies the Goldstrike area. Major lithologic groups include Micoene ash-flow sediments and interbedded volcanics of the Eocene Claron and Oligocene Isom formations and a Paleozoic section of Mississippian through Permian carbonates and sandstones (JBR, 1993).

There are two recorded paleontology sites within the vicinity of the Project Area. Both sites are listed as micro-fossil localities and are in one of the predominant geologic layers where the drilling activities would occur. It is likely the marine fossils occur within the limestone geologic units and some of the sandstone units within the Project Area (Appendix A). Much of the Project Area located east of the East Fork of Beaver Dam Wash is located on sandstone or other sedimentary geologic units (Hintze, 1980).

3.2.5 Cave and Karst The Project Area is located within a large and potentially significant karst terrain. Karst terrain can consist of caves, sink holes, blowholes, crevices, vugs, swallets and/or sinking streams. Any of these features can lead into a cave system that may contain unique cave adapted organisms or drain surface water directly into the water table or aquifer. There are no caves, shelters, or pits that have been identified in the Project Area. The Wooden Ladder Cave was discovered from a historic mine tunnel and this cave is located approximately 0.6 mile from the northwest corner of the Project Area, and the next closest caves are more than five miles south of the Project Area (Pilot Goldstrike, 2016). Many of these caves south of the Project Area have been listed as Significant under the Federal Cave Resource Protection Act (FCRPA) 16 USC Sec. 4301 Title 16 Chapter 63.

BLM karst data was reviewed to identify which sandstones and limestones are the dominant host rock of the known caves, pits, and shelters in southwestern Utah. The BLM data showed that the geological formations within the Project Area with the potential to form caves include the Navajo Sandstone (Jn), Queantoweap Sandstone (Pq), Pakoon Dolomite (Pp), Calville Limestone (IPc) and Redwall Limestones (Mr). Of these units, the Callville Limestone, Pakoon Dolomite, and Redwall Limestone are shown regionally to have the highest potential to host caves (Pilot Goldstrike, 2016).

In order to calculate the “potential” karst forming areas, the geology was simplified into Tertiary sediments, volcanics and intrusives, as well as Paleozoic sediments. The Paleozoic sediments were then categorized as higher potential to host karsts (Redwall Limestone) or lower potential to host

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karsts (Calville Limestone, Pakoon Dolomite, and the Queantoweap Sandstone). Paleozoic sediments that are not known to have caves are labelled simply as Paleozoic sediments. The acreage of each simplified geologic unit has been calculated within the immediate area of proposed disturbance, and it was determined that there is approximately 2.1 acres of higher potential karst forming units in the area.

3.2.6 Socio-Economics The Project Area is in a rural part of Washington County, Utah. The nearest urbanized and populous city to the Proposed Action is St. George, with a population of 72,897 in 2010 (U.S. Census Bureau, 2010a). The total population of Washington County at the time of the 2010 Census was reported as 138,115 (U.S. Census Bureau, 2010b). Thus, the population of St. George accounted for approximately 52.8 percent of the total population of Washington County. Other communities with smaller but expanding populations are also located within Washington County and include Ivins, Santa Clara, and Washington.

In 2014, the percentage of the population that was in the labor force and of the age 16 or older in the St. George Metro Area was measured at 57 percent (U.S. Census Bureau, 2014a). This was a slight decrease from five years earlier in 2009, when the U.S. Census Bureau measured the percentage of the population in the workforce as 58.5 percent. However, between March 2015 and March 2016, Washington County generated 3,400 new nonfarm jobs for a year-to-year growth rate of 6 percent (Utah Department of Workforce Services, 2016). Job growth within the mining industry during this same time period was reported at 9.1 percent. The Utah Department of Workforce Services reports (2016) that retail trade, health care, food services, and manufacturing constitute some of the largest employment industries in the county.

In 2014, the U.S. Census Bureau estimated that there were approximately 32,650 housing units in the St. George Metro Area (U.S. Census Bureau, 2014b). The majority of houses in the St. George Metro Area, approximately 78.6 percent, are single-family homes. Duplexes, apartments, mobile homes, campers, and vans make up a smaller percentage of the types of homes in the Metro Area. As of 2014, there were 6,914 vacant housing units in the St. George Metro Area (U.S. Census Bureau, 2014b). The rental vacancy rate was reported at 6.8 percent. For temporary, short-term living arrangements, there are at least 30 hotels or motels located in the St. George Metro Area.

Public safety in the St. George Metro area includes the St. George 911 Communications Center, St. George Police Department, and City of St. George Fire Department. The Fire Department is made up of 31 full-time staff and a reserve staff of 70 additional persons. The department includes eight stations located geographically throughout St. George (City of St. George, 2016).

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There are several health care providers in the St. George Metro Area. The primary hospital is Dixie Regional Medical Center. A tertiary-level hospital, Dixie Regional Medical Center offers advanced services like open-heart surgery, a cancer center, a health and performance center, and newborn intensive care. The facility can accommodate up to 245 patients.

3.2.7 Soils Soil types in the Project Area are identified in the Soil Survey of Washington County Area, Utah, prepared by the U.S. Department of Agriculture, Soil Conservation Service in 1977. The data from the 1977 soil survey has since been digitized into the Natural Resource Conservation Service’s (NRCS’s) Web Soil Survey (2016), an online application for viewing the mapped extent and attributes of soils. The Web Soil Survey was used to view the soils and soil complexes that have been mapped in the Project Area. As shown on Figure 3-1, there are four soils or soil complexes mapped in the Project Area. Descriptions of the soils and soil complexes found in the Project Area are provided below.

CEF – Cave very gravelly sandy loam, 7 to 30 percent slopes The CEF soil map unit is located on alluvial fans at elevations of 2,400 to 4,200 feet above mean sea level. The components of this soil type are Cave (90 percent) and other minor components (10 percent). The soil map unit is classified as well drained and does not experience ponding or flooding. The depth to a restrictive feature is 10 to 20 inches. Available water capacity in the soil profile is very low at approximately 0.9 inches. The typical profile is composed of very gravelly sandy loam underlain by gravelly sandy loam to 12 inches. Below 12 inches the soil profile becomes indurate, or compacted such that a restrictive layer is formed (NRCS, 2016). The hazard for erosion of this soil map unit is slight (U.S. Department of Agriculture, Soil Conservation Service, 1977).

DAG – Dagflat-Motoqua complex, 30 to 70 percent slopes The DAG soil map complex is located on mountain slopes and ridges at elevations of 4,700 to 6,700 feet above mean sea level. The components of this soil type are Dagflat (50 percent), Motoqua (30 percent), and other minor components (15 percent). Dagflat and Motoqua soils are classified as well drained and do not experience ponding or flooding. The depth to a restrictive feature in Dogflat soils is 21 to 40 inches. Available water capacity in the Dagflat soil profile is low at approximately 3.3 inches. The typical profile of Dogflat soils is composed of very cobbly coarse sandy loam underlain by sandy loam and sandy clay loam. The depth to a restrictive feature in Motoqua soils is 8 to 20 inches. Available water capacity in the soil profile is very low at approximately 1.5 inches. The typical profile is composed of very gravelly sandy loam underlain by very gravelly loam (NRCS, 2016). The hazard for erosion of Dagflat and Motoqua soils is moderate (U.S. Department of Agriculture, Soil Conservation Service, 1977).

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QMG – Quazo-Motoqua very gravelly sandy loams, 30 to 70 percent slopes The QMG soil map complex is located on mountain slopes at elevations of 3,700 to 6,700 feet above mean sea level. The components of this soil type are Quazo (40 percent), Motoqua (30 percent), and other minor components (20 percent). Quazo and Motoqua soils are classified as well drained and do not experience ponding or flooding. The depth to a restrictive feature in Quazo soils is 11 to 20 inches. The depth to a restrictive feature in Motoqua soils is 8 to 20 inches. The available water capacity in the Quazo soil profile is very low at approximately 1.9 inches. Available water capacity in the Motoqua soil profile is very low at approximately 1.5 inches. The typical profile of Quazo soils is composed of very gravelly sandy loam underlain by very gravelly sandy clay loam. The typical profile of Motoqua soils is composed of very gravelly sandy loam underlain by very gravelly loam (NRCS, 2016). The hazard for erosion of Quazo and Motoqua soils is moderate (U.S. Department of Agriculture, Soil Conservation Service, 1977).

WAG – Welring-Tortugas very gravelly loams, 20 to 70 percent slopes The WAG soil map complex is located on mountain slopes at elevations of 4,600 to 6,900 feet above mean sea level. The components of this soil type are Welring (40 percent), Tortugas (25 percent), and other minor components (15 percent). Welring and Tortugas soils are classified as well drained and do not experience ponding or flooding. The depth to a restrictive feature in Welring and Tortugas soils is 10 to 20 inches. The available water capacity in the Welring and Tortugas soil profiles is very low, at approximately 1.4 inches and 1.6 inches, respectively. The typical profile of Welring soils is composed of very gravelly loam underlain by extremely gravelly loam. The typical profile of Tortugas soils is composed of very gravelly loam underlain by extremely gravelly very fine sandy loam (NRCS, 2016). The hazard for erosion of Welring is severe (U.S. Department of Agriculture, Soil Conservation Service, 1977). The hazard for erosion of Tortugas soils is high (U.S. Department of Agriculture, Soil Conservation Service, 1977).

It should be noted that some portions of the Project Area have been disturbed and reclaimed from past mining activities. In these areas, soils have been altered and likely vary from the map units mapped in the Soil Survey of Washington County Area, Utah.

In early May 2016, Stantec Consulting Services (2016b) collected soil samples from selected sites within and near the Project Area. One representative location for each of the above-described soil complexes and one location within the disturbed/reclaimed area were chosen, for a total of five sites. Subsamples were collected at each site based upon the nature of the soil horizons. Samples were analyzed by a laboratory to assess the soil types’ suitability for use in reclamation. In general, they were found to be suitable, though additives may be recommended, and arsenic concentrations may need further evaluation.

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3.2.8 Fish and Wildlife The general wildlife survey conducted in late spring of 2016, and encountered 58 avian species, eight mammalian species, and six reptilian species within the Project Area (Stantec, 2016b). The wildlife encountered are common species encountered in the region. Migratory birds and raptors are discussed in Section 3.2.9. The Project Area is also designated as big game habitat by the BLM for mule deer (Odocoileus hemionus). Critical big game habitat is located north of the Project Area, and a deer migration corridor extends from the critical habitat to the Bull Valley Mountains (JBR, 1993).

An acoustic bat survey was conducted near a stream that provides foraging habitat and documented three bat species in the Project Area: California myotis (Myotis californicus); yuma myotis (Myotis yumanensis); and big brown bat (Eptesicus fuscus).

Vegetation cover within the Project Area represents potential habitat for many species of wildlife, migratory birds, and raptors. There are approximately 907 acres of vegetation cover within the Project Area, and thus, approximately 907 acres of potential habitat. A description of the vegetation communities present within the Project Area is provided in Section 3.2.10.1.

3.2.9 Migratory Birds Migratory bird species (e.g., raptors, songbirds, and shorebirds) are protected under the Migratory Bird Treaty Act (MBTA) of 1918, Executive Order 13186, and the Bald and Golden Eagle Protection Act (BGEPA). The MBTA protects species or families of birds that live, reproduce, or migrate within or across international borders during their life cycle. Under authority of the MBTA, it is unlawful to take, kill, or possess migratory birds, their parts, nests, or eggs—including the disturbance or destruction of a migratory bird nest that results in the loss of eggs or young. Executive Order 13186 was enacted, in part, to ensure that environmental analyses of federal actions evaluate the impacts of actions and agency plans on migratory birds. It also states that emphasis should be placed on species of concern, priority habitats, and key risk factors and it prohibits the take of any migratory bird without authorization from the USFWS. The BGEPA makes it illegal to take (e.g., disturb, molest), possess, sell, purchase, barter, or transport any bald or golden eagle, alive or dead, or any part, nest, or egg thereof.

The decline of Neotropical migratory birds (NTMBs; i.e., landbirds that breed north of Mexico and then migrate to Mexico, Central and South America, and the Caribbean) in North America is well documented (Rappole and McDonald, 1994). Partners in Flight (PIF) is a cooperative partnership program involving Federal and State Governmental agencies (e.g., BLM, USFWS, Utah Division of Wildlife Resources [UDWR]) that focuses on the conservation of migratory birds (e.g., NTMBs) and maintains a PIF High-Priority Bird Species list (Parrish et al., 2002). The USFWS maintains a list of Birds of Conservation Concern for each Bird Conservation Region in

BULL VALLEY EXPLORATION PROJECT ENVIRONMENTAL ASSESSMENT MAY 2017 PILOT GOLDSTRIKE INC. 31 the United States (USFWS, 2008). Washington County is in USFWS Bird Conservation Regions 6, the Mountain-Prairie Region. In cooperation with the UDWR, Utah-BLM maintains an avian Sensitive Species list (UDWR, 2015; http://dwrcdc.nr.utah.gov/ucdc/ ViewReports/SS_List.pdf).

A variety of migratory bird species (≥ 302 spp.) have been documented using habitats within Washington County, for breeding, nesting, foraging, and migratory habitats (Fridell and Comella, 2007, Parrish et al. 2002), including USFWS-BLM-PIF listed species of conservation concern (Table 3-3).

Table 3-3 lists the migratory bird species that have been documented within Washington County, Utah, that have conservation status (USFWS Birds of Conservation Concern, Utah-BLM Sensitive Species, Utah-PIF High-Priority Bird Species), and their primary-secondary breeding and wintering habitats.

Table 3-3 Migratory Bird Species Documented in Washington County, Utah, That Have Conservation Status and Their Primary and Secondary Breeding and Wintering Habitats Utah-PIF USFWS Utah-BLM High Common Scientific Birds of Sensitive Primary Secondary Winter Priority Name1, 2 Name1, 2 Conservation Bird Breeding, 4, 5 Breeding4, 5 Habitat4, 5 Bird Concern3 Species4 Species5 Podiceps Horned grebe X Marshes Ponds Migrant auritus American Pelecanus X X Lakes Marshes Migrant white pelican erythrorhynchos American Botaurus Freshwater Freshwater X Migrant bittern lentiginosus Marshes Marshes Ixobrychus Freshwater Brackish Least bittern X Accidental exilis Marshes Marshes Northern Accipiter Conifer Mixed X Forests goshawk gentilis Forests Forests Ferruginous Open Buteo regalis X X X Tree-Snag Cliff hawk Habitats Aquila Open Golden eagle X Cliff Tree-Snag chrysaetos Habitats Haliaeetus Bald eagle X X Tree-Snag Cliff Migrant leucocephalus Falco Open Prairie falcon X Cliff Bank mexicanus Habitats Peregrine Falco Open X Cliff Tree-Snag falcon peregrinus Habitats Gambel's Callipepla Lowland Desert X Desert Scrub quail gambelii riparian Scrub Charadrius Sand Alkaline Snowy plover X Migrant nivosus Beaches Flats Mountain Charadrius Shortgrass Sandy X X Migrant plover montanus Prairie Deserts

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Utah-PIF USFWS Utah-BLM High Common Scientific Birds of Sensitive Primary Secondary Winter Priority Name1, 2 Name1, 2 Conservation Bird Breeding, 4, 5 Breeding4, 5 Habitat4, 5 Bird Concern3 Species4 Species5 American Recurvirostra X Marshes Lake Edges Migrant avocet americana Black-necked Himantopus X Marshes Lake Edges Migrant stilt mexicanus Long-billed Numenius Agricultural X X X Grasslands Migrant curlew americanus Fields Marbled Shortgrass Limosa fedoa X Marshes Migrant godwit Prairie Short-billed Limnodromus X Marshes Lake Edges Migrant dowitcher griseus Yellow-billed Coccyzus Riparian X Marshes Migrant cuckoo americanus Woodlands Short-eared Open Asio flammeus X X Grasslands Wetlands owl Habitats Burrowing Athene High Desert X Grasslands Migrant owl cunicularia Scrub Flammulated Psiloscops Ponderosa Sub-Alpine X Migrant owl flammeolus Pine Conifer Cypseloides Mountain Mountain Black swift X X Migrant niger Cliffs Waterfalls Broad-tailed Selasphorus Mountain Mountain X Migrant hummingbird platycercus Conifer Riparian Red-headed Melanerpes Open X Orchards Accidental woodpecker erythrocephalus Woodlands Lewis's Melanerpes Pine/Oak Lowland Pine/Oak X X X woodpecker lewis Woodlands Riparian Woodlands American Sub- Picoides Sub-Alpine Lodgepole three-toed X Alpine dorsalis Conifer Pine woodpecker Conifer Willow Empidonax Riparian X Marshes Migrant flycatcher traillii Habitats Loggerhead Lanius High Desert Pinyon- Open X shrike ludovicianus Scrub Juniper Habitats Pinyon- Gray vireo Vireo vicinior X X Scrub Oak Migrant Juniper Riparian Bell's vireo Vireo bellii X X Scrublands Migrant Woodlands Gymnorhinus Pinyon- Pinyon jay X Pinyon Pine Juniper cyanocephalus Juniper Brush- Bewick's Thryomanes Lowland Pinyon- X Open wren bewickii Riparian Juniper Woodlands Oreoscoptes Pinyon- Sage thrasher X Sagebrush Migrant montanus Juniper Virginia’s Oreothlypis Pinyon- X Scrub Oak Migrant warbler virginiae Juniper Lucy’s Oreothlypis Cottonwood- Dry Desert X Migrant warbler luciae Mesquite Washes

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Utah-PIF USFWS Utah-BLM High Common Scientific Birds of Sensitive Primary Secondary Winter Priority Name1, 2 Name1, 2 Conservation Bird Breeding, 4, 5 Breeding4, 5 Habitat4, 5 Bird Concern3 Species4 Species5 Black- Setophaga Pinyon- throated gray X Dry Conifer Migrant nigrescens Juniper warbler Abert’s Riparian Shrub- Melozone aberti X Shrublands towhee Woodlands Riparian Sagebrush Artemisiospiza Desert X X Sagebrush Deserts sparrow nevadensis Scrub Brewer's Pinyon- Spizella breweri X Sagebrush Migrant sparrow Juniper Grasshopper Ammodramus X Grasslands Prairies Migrant sparrow savannarum McCown's Rhynchophanes Shortgrass X Grasslands Migrant longspur mccownii Prairie Chestnut- Calcarius Shortgrass collared X Grasslands Migrant ornatus Prairie longspur Dolichonyx Bobolink X Wet Meadow Prairie Migrant oryzivorus Black rosy- Leucosticte Alpine Mountain X X Alpine Cliffs finch atrata Habitats Valleys Haemorhous Mountain Pinyon- Mountain Cassin's finch X cassinii Conifer Juniper Conifer Source: 1Chesser et al., 2013; 2Fridell and Comella, 2007; 3USFWS, 2008; 4UDWR, 2015; 5Parrish et al., 2002.

Eleven active raptor nests, 26 inactive unknown raptor species nests, one active unknown raptor species nest, and four common raven nests were located during the golden eagle and raptor nest survey which encompassed a one-mile buffer around the property boundary. Of the 11 active raptor nests, three were active golden eagle (Aquila chrysaetos) nests. The remaining active nesting raptors observed during the aerial survey included: black hawk (Buteogallus anthracinus); Cooper’s hawk (Accipeter cooperii); peregrine falcon (Falco peregrinus); red-tailed hawk (Buteo jamaicensis); turkey vulture (Cathartes aura); and great horned owl (Bubo virginianus).

The golden eagle was the only BLM sensitive wildlife species identified with potential foraging and nesting habitat in the Project Area and vicinity.

3.2.10 Vegetation The majority of the Project Area burned from a wildland fire approximately 10 years ago. Prior to the wildland fire the Project Area was dominated with a pinyon/juniper forest community. Some areas in the south were a blackbrush shrub community. The regrowth after the wildland fire has resulted in different shrub communities dominating the area, with some unburned areas of forest and blackbrush scattered throughout. The differing shrub communities currently growing correspond to the different soil types in the Project Area. These vegetation communities are shown

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on Figure 3-2 and discussed below. Table 3-4 lists the vegetation communities, number of acres, and the percent of the Project Area.

Table 3-4 Vegetation Communities Present in the Project Area Vegetation Community Acres Percent of Total Blackbrush 41 5 Dixie Live Oak 19 2 Mountainbrush 235 26 Pinyon/Juniper 311 34 Reclaimed 150 16 Riparian 1 <1 Serviceberry 148 16 Total 907 100 Source: Stantec, 2016b

Blackbrush Vegetation Community Prior to the wildland fire, this vegetation type was dominated with mainly blackbrush (Coleogyne ramosissima). In the areas that burned, the vegetation community is now dominated by green rabbitbrush (Chrysothamnus viscidiflorus), yerba santa (Eriodictyon angustifolium), and desert almond (Prunus fasciculata). This community occurs on very dry, rocky, shallow soils.

Dixie Live Oak Vegetation Community The Dixie live oak vegetation community was a pinyon/juniper forest community prior to the wildland fire. This community is dominated by Dixie live oak (Quercus turbinella). Other abundant species include yerba santa, cliffrose (Purshia stansburiana), and desert almond. This community occurs on shallow and rocky soils with little shrub density.

Mountainbrush Vegetation Community The mountainbrush vegetation community was a pinyon/juniper forest community prior to the wildland fire. This community occurs in areas of deeper soils and is dominated by many species of shrubs and single leaf ash (Fraxinus anomala). The dominant shrubs include little leaf mahogany (Cercocarpus intricatus), mountain mahogany (Cercocarpus ledifolius), desert almond, skunk bush (Rhus trilobata), bitterbrush (Purshia tridentata), and cliffrose.

Pinyon/Juniper Vegetation Community The pinyon/juniper vegetation community is dominated by pinyon pine (Pinus edulis) and Utah juniper (Juniperus osteosperma), with an understory of blackbrush. This community exists as patches and stands within parts of the Project Area that did not burn during the past wildland fire. Prior to the wildland fire, this community would have been prevalent throughout the Project Area.

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Reclaimed Vegetation Community The reclaimed vegetation community occurs from past mining in the Project Area. Areas disturbed from mining were recontoured and seeded years ago. These areas are now dominated with fourwinged saltbush (Atriplex canescens), cliff-rose, and desert almond. Grasses also occur and are dense in some areas.

Riparian Vegetation Community The riparian vegetation community is limited to the portion of the East Fork of Beaver Dam Wash within the Project Area. Vegetation consists of rabbitbrush, sandbar willow (Salix exigua), velvet ash (Fraxinus velytina), cottonwood (Populus fremontii), and Gooding’s willow (Salix goodingii).

Serviceberry Vegetation Community This community is dominated by serviceberry (Amelanchier utahensis), mountain mahogany, bitterbrush, and cliffrose. The serviceberry community has the deepest soils and highest diversity of plants.

Sensitive Plants The BLM identified the Project Area as having potential to support Nevada willowherb (Epilobium nevadense), a species included on the BLM sensitive species list. Nevada willowherb is associated with habitat consisting of talus slopes and rock outcrops. In July 2016, a biologist from Stantec Consulting Services Inc. performed a survey for Nevada willowherb within the suitable habitat identified in the Project Area (Stantec, 2016b). The biologist surveyed the suitable habitat by walking meandering transects, visually investigating the ground for the species. During the survey, Nevada willowherb was not found within the Project Area; however, 22 areas (204 acres) were identified as potential habitat despite the species not occurring within these areas at the time the survey was conducted (Figure 3-3).

Noxious Weeds and Invasive Plants Tamarisk (Tamarix ramosissima) was the only species found within the Project Area during the vegetation community mapping and other survey work that is included on the State of Utah Noxious Weeds List. Numerous other invasive or introduced plant species that are not on the State of Utah Noxious Weeds List were observed within the Project Area. These species include: cheatgrass (Bromus tectorum); red brome (Bromus rubens); Maltese star-thistle (Centaurea melitensis); filaree (Erodium cicutarium); halogeton (Halogeton glomeratus); forage kochia (Kochia prostrata); and, Russian thistle (Salsola tragus).

3.2.11 Recreation Opportunities for recreation in the Project Area and vicinity include mainly dispersed hunting, off- road vehicle activity, camping, pine nut harvesting, and rockhounding. There are no developed

BULL VALLEY EXPLORATION PROJECT ENVIRONMENTAL ASSESSMENT MAY 2017 PILOT GOLDSTRIKE INC. 36 campsites or recreational facilities in the area. The three most common recreational activities occurring in the Project Area include hunting, off-road vehicle recreation, and wilderness therapy.

From two weeks prior, to the end of the rifle hunting season, many hunters camp and hunt within the Project Area in the fall. There are 15 commercial hunting guides who are authorized to operate in the Project Area and vicinity.

The Project Area is a popular location for all-terrain vehicles/utility-terrain vehicles (ATV/UTV) enthusiasts, although the somewhat remote location keeps the use numbers relatively low. There are five companies that are authorized to conduct ATV/UTV tours in the area, and the annual Tri- State ATV Jamboree passes directly through the Project Area as part of their annual event.

There are two companies permitted with the BLM to operate wilderness therapy programs in the Project Area and vicinity. These programs typically focus on at-risk/troubled youth and young adults, and prefer to operate in areas where visitor traffic is low and contact with outside groups or individuals is discouraged.

3.2.12 Visual Resources Scenic quality is a measure of the visual appeal of a parcel of land. Section 102 (a)(8) of FLPMA emphasizes protection of the quality of scenic resources on public lands. Section 101(b) of NEPA requires that measures be taken to ensure that aesthetically pleasing surroundings be retained for all Americans.

The Project Area is entirely within land classified as Visual Resource Management (VRM) Class III. The management objectives for this VRM Class are to partially retain the existing character of the landscape and include the following:

1. The level of change to the landscape can be moderate; 2. Management activities may attract attention, but should not dominate the view of the casual observer; and 3. Any changes should repeat the basic elements found in the natural landscape – form, line, color, and texture (BLM, 1986).

The Project is in the Bull Valley Mountains. The overall landscape is a combination of natural and human-made elements. Natural elements include hilly terrain and numerous intermittent and ephemeral drainages. The deep drainages consist of long steep slopes and narrow rocky ridges. Throughout the year, colors in the landscape are primarily brown hues dotted with green vegetation. Textures in the landscape include, rocks, shrubs, and trees. Human-made features in

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the area include existing mine disturbance in the form of open pits, roads, reclaimed heap leach pads, and drill pads.

3.2.13 Lands with Wilderness Characteristics Lands with wilderness characteristics provide a range of uses and benefits in addition to their value as settings for solitude or primitive and unconfined recreation. Section 201 of FLPMA requires the BLM to maintain an inventory of all public lands and their resources and other values, including wilderness characteristics.

In order for an area to qualify as lands with wilderness characteristics, the area must possess sufficient size, naturalness, and outstanding opportunities for either solitude or primitive and unconfined recreation. In addition, it may also possess supplemental values.

• Size - The area must be over 5,000 acres of roadless, contiguous BLM-managed lands. Areas smaller than 5,000 acres may qualify if it is practical to preserve and use them without damaging their current condition. In addition, roadless areas less than 5,000 acres that are contiguous with lands that have been formally determined to have wilderness or potential wilderness values, or any federal lands already managed for the protection of wilderness characteristics (e.g. Wilderness Areas or Wilderness Study Areas) may also qualify. • Naturalness - Must appear to have been affected primarily by the forces of nature and any work of human beings in the area must be substantially unnoticeable. Minor human impacts such as a water trough or fences may often be considered substantially unnoticeable. • Outstanding Opportunities for Solitude or Primitive, Unconfined Recreation - The area must offer a visitor the chance to avoid evidence of other people or provide for outstanding opportunities for primitive and an unconfined type of recreation activity like hiking, fishing, etc. Solitude or outstanding primitive recreation opportunities do not have to be available in all portions of the area. An area may possess outstanding opportunities through either the diversity of possible recreation opportunities in the area or the outstanding quality of one opportunity. • Supplemental Values - If size, naturalness, and outstanding opportunities criteria are met, then ecological, geological, or other features of scientific, educational, scenic, or historical values may be noted, but are not required to qualify as lands with wilderness characteristics.

The Project includes a total of 91 proposed drill sites located on public lands within areas that have wilderness characteristics. The entire Project Area was inventoried in 2011 for wilderness characteristics and the proposed drill sites are located within three separate inventory units: Square

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Top Mountain – UT-040-048A (33 proposed drill sites); Square Top Mountain – UT-040-048B (56 proposed drill sites); and Docs Pass – UT-040-124A (2 proposed drill sites).

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4.0 ENVIRONMENTAL CONSEQUENCES

4.1 INTRODUCTION The Proposed Action and No Action Alternative outlined in Chapter 2 may cause, directly or indirectly, changes in the human environment. This chapter assesses and analyzes these potential changes and discloses the effects. This process of disclosure is one of the fundamental aims of NEPA. Resources that were determined to be potentially affected by the Proposed Action and which were described in the affected environment section (Chapter 3) include the following: Water Resources/Quality (drinking/surface/ground); Areas of Critical Environmental Concern; Cultural Resources; Paleontology; Cave and Karst; Socio-Economics; Soils; Fish and Wildlife; Migratory Birds; Vegetation; Recreation; Visual Resources; and Lands with Wilderness Characteristics.

4.2 GENERAL ANALYSIS ASSUMPTIONS AND GUIDELINES In order to analyze the impacts of the Proposed Action and No Action Alternative both the intensity and context of impacts were considered. Intensity refers to the severity or level of magnitude of impact. Public health and safety, proximity to sensitive areas, level of controversy, unique risks, or potentially precedent-setting effects are all factors to be considered in determining intensity of effect. Context means that the effect(s) of an action must be analyzed within a framework, or within physical or conceptual limits. Resource disciplines; location, type, or size of area affected (e.g., local, regional, national); and affected interests are all elements of context that ultimately determine significance. Both long- and short-term effects are relevant.

4.3 DIRECT AND INDIRECT IMPACTS A direct effect, caused by the action, occurs at the same time and place as the action (40 CFR 1508.8(a)). Direct and indirect effects are discussed in combination under each affected resource. Indirect effects are reasonably foreseeable effects, also caused by the action, that occur later in time or are removed in distance from the action (40 CFR 1508.8(b)). Direct and indirect effects are discussed in combination under each affected resource.

4.3.1 Alternative A – Proposed Action 4.3.1.1 Water Resources Activities conducted under the Proposed Action would avoid direct effects to surface water resources including the East Fork of the Beaver Dam Wash. To minimize indirect effects to surface water, Pilot Goldstrike has committed to EPMs and BMPs during construction, operation, and reclamation that are expected to minimize sedimentation or erosion resulting from snowmelt or precipitation events (Section 2.2.10). Also, a Spill Prevention Plan is included in Appendix D of the Plan of Operations and would be implemented to control drilling fluids and petroleum products. All containers of hazardous substances would be labeled and handled in accordance with UDEQ,

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EPA, and MSHA regulations. Impacts would be minimal due to the use of non-toxic drilling fluids and adherence to NAC 534.4369 and 534.4371.

The Proposed Action would utilize water for exploration drilling, road construction, and dust suppression. During peak drilling activity, 4,000-gallon water trucks could make up to 15 trips daily to the Project Area. It is estimated that up to 200 drilling days per year could occur for the life of the Project. Although this could result in a maximum consumptive use of 60,000 gallons of water per day during peak drilling activity, Pilot Goldstrike anticipates that more realistically, approximately 6,000 gallons of water per day would be used on average. This results in approximately 3.7 acre feet per year.

Pilot Goldstrike would lease 6.0 acre-feet of water from the D.I. Ranch (located 10 miles southwest of the Project Area) and would lease 1.0 acre-feet of water from the Bracken family (located 0.5 mile northeast of the Project Area). These two water sites are in the Upper Beaver Dam Wash Watershed, which as stated in Section 3.2.1 has an average annual recharge rate of 18,000 acre- feet per year. Since all the Project-related water use would occur in this watershed, the Project, even at the maximum use (which is not anticipated), would consume approximately 0.4 percent of the average annual recharge in the basin and would occur through leases with existing water rights holders.

Drilling is not expected to encounter groundwater. However, as stated in Section 2.2.1, if groundwater is encountered during drilling, the borehole would be plugged pursuant to UAC R647-2-108. All drill holes would be plugged within 30 days unless specifically approved to be open longer. Overall, impacts to surface water and groundwater from the Project are expected to be minimal.

4.3.1.2 Areas of Critical Environmental Concern There are three proposed drill sites that are located within the Beaver Dam Wash ACEC and another ten sites that are within 200 meters of the ACEC boundary. Potential impacts could occur resulting in increased erosion or sedimentation in the ACEC. The EPMs outlined in Section 2.2.10 would minimize impacts from the Project to the ACEC. Section 4.1.1 describes how impacts to surface water would be minimized through implementation of BMPs and EPMs. Overall, impacts to the ACEC from the Project are expected to be minimal.

4.3.1.3 Cultural Resources The Project would result in up to 77 acres of ground disturbance. The proposed exploration drilling could impact prehistoric, historic, and multi-component sites directly as the result of damage incurred by construction activities. Indirect effects could result from constructing and improving roads within the Project Area near the cultural resource sites.

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The BLM worked with Pilot Goldstrike to reroute roads and move drill site location to minimize effects to these historic properties. The BLM submitted a finding of “no adverse effect” to historic properties to the Utah State Historic Preservation Officer (SHPO). The Utah SHPO concurred with the eligibility determinations and BLM’s finding of effect.

EPMs outlined in Section 2.2.10 would be implemented to avoid impacts if cultural resource sites that had not previously been identified are encountered during Project activities. Indirect impacts to cultural resource sites in the area would be lessened by reducing the amount of surface- disturbing activities overall and the reclamation of pads and access roads upon completion of exploratory activities. The Project would not result in the construction of permanent roads that often result in adverse effects to sites due to vandalism or illegal collection. Overall, impacts to cultural resources from the Project are expected to be minimal.

4.3.1.4 Paleontology There is no Project-related disturbance proposed at either of the two known micro-fossil localities in the Project Area. Project activities would occur in the geologic layer that is known to host fossils, and where previously unidentified fossils may occur. However, the fossils are marine micro-fossils and are not considered scientifically significant and effects to previously undiscovered paleontologically resources would be avoided by implementation of the EPM outlined in Section 2.2.10. Overall, impacts to paleontological resources are expected to be negligible.

4.3.1.5 Cave and Karst The Project could impact up to approximately 2.1 acres of higher potential karst forming units such as in the Redwall Limestone. Lower potential karst forming rocks such as the Pakoon Dolomite and Calville Limestone, cover a larger portion of the Project Area and these units are statistically half as likely to form caves. In order to avoid impacts in higher potential karst forming units, Pilot Goldstrike would implement BMPs as outlined in the Plan and the EPMs identified for water, wastes, and cave and karst features in Section 2.2.10. The EPMs for water and waste would manage fluids in sumps and minimize impacts from potential spills or erosion. Additionally, the EPM for cave and karst features states that Pilot Goldstrike would inspect areas of higher potential karst forming units. Since the Paleozoic sediments were categorized as higher potential to host karsts (Redwall Limestone), Pilot Goldstrike would inspect and coordinate with the BLM prior to disturbance of those areas.

4.3.1.6 Socio-Economics Project activities would include up to five active drill crews working concurrently. Drill crews would consist of three people, and there would be a project manager and geologist on site. With some possible support staff, it is anticipated that there would be approximately 20 to 25 individuals in the work area during peak activity. It is likely that the vehicles and machinery would require

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maintenance/repairs and that work would likely be performed in St. George, which is the closest population center with the necessary tools and equipment. It is also likely that St. George would be the supply point for the living and working needs of the drill crews. Although the size of this Project is small, the economic benefit to some local businesses could be relatively large, particularly those working to support and supply the operation. The overall impact to the local economy would likely be small to negligible.

4.3.1.7 Soils The Project would result in up to 77 acres of surface disturbance. Approximately 62.55 acres of this disturbance would occur during road construction and maintenance of existing roads, and 14.45 acres for drill pads and sumps which could result in soil disturbance and increased erosion and sedimentation.

Roads within the Project Area would be constructed to access drill site locations. To minimize effects from road construction and use, travel along the roads would be at low speeds. Routes would be constructed at an estimated 12 feet in width and follow the topography of land whenever possible to avoid steep slopes. Balanced cut and fill construction would be used to the extent practicable to minimize the exposed cut slopes and volume of fill material. Road grades would be no steeper than 10 percent, except for short drill spurs.

Establishing a natural plant cover, as part of reclamation, to an ecological site condition similar to what existed prior to soil disturbance is estimated to take several years. Whenever possible, and primarily on reasonably level terrain, topsoil would be graded and stockpiled to the uphill margin of the pad and sump cut. On steeper slopes, topsoil would be stored as side-case along the periphery of the pads. The salvaged growth media would be brought back over the top of the soil disturbance to approximate original contour. Contouring and seeding the disturbed areas as soon as they are no longer needed would minimize long-term impacts associated with the Project.

Fugitive dust is created by the erosion and breakdown of soil particles into very fine material that can be suspended in the air. These fine particles can be lifted into the air by wind and vehicle traffic. The soil properties that affect fugitive dust are the size of surface soil particles, rock fragment content, calcium carbonate equivalent, and aggregate stability. Emissions of fugitive dust from disturbed surfaces would be minimized by the application of water from a water truck as a method of dust control.

These BMPs and EPMs are expected to minimize effects from Project-related surface disturbance to soil resources. Additionally, Project-related disturbance would be phased, occur throughout the Project Area, and reclamation would occur in phases, thereby minimizing impacts to soils. Overall, impacts to soils from the Project are expected to be minimal.

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4.3.1.8 Fish and Wildlife The Project would result in impacts to a maximum of 77 acres of foraging, nesting, and roosting habitat for wildlife species over the life of the Project. Construction of roads and drill pads and the operation of drilling equipment could cause wildlife species to avoid the area or change their pattern of movement due to the presence of humans and activities that create noise and dust. However, available habitat for wildlife is limited as a result of a wildland fire that burned the majority of vegetation in the Project Area approximately 10 years ago. Wildlife species, nesting, roosting, and breeding within the Project Area could be affected during the life of the Project. EPMs and a Project design feature including constructing sumps with ramps for wildlife egress and fencing the sumps if inactive would minimize direct effects to wildlife.

Foraging activities and migratory movements could potentially be affected by the operation of up to five drill rigs operating at any one time. Impacts to wildlife species are expected from loss of habitat until reclamation is complete and vegetation is reestablished. Project-related disturbance would be phased, occur throughout the Project Area, and reclamation would occur in phases, thereby minimizing impacts to wildlife and their habitat. Overall, impacts from the Project to wildlife and their habitat are expected to be minimal.

4.3.1.9 Migratory Birds The Project would result in impacts to a maximum of 77 acres of foraging, nesting, and roosting habitat for migratory birds and raptors over the life of the Project. Construction of roads and drill pads and the operation of drilling equipment could cause avian species to avoid the area or change their pattern of movement due to the presence of humans and activities that create noise and dust. However, available nesting and foraging habitat for avian species has been diminished as a result of a wildland fire that burned the majority of vegetation in the Project Area approximately 10 years ago. Impacts from the Project to available habitat would continue until reclamation is complete and vegetation is reestablished. Additionally, Project-related disturbance would be phased, occur throughout the Project Area, and reclamation would occur in phases, thereby minimizing impacts to avian species and their habitat. The pre-construction survey EPM would minimize direct effects to nesting migratory birds. Overall, impacts to migratory birds and raptors from the Project are expected to be minimal.

4.3.1.10 Vegetation The Project would result in disturbance of 77 acres and would occur within all the vegetation types identified in the Project Area. Wildland fire has recently changed the composition of vegetation types in the Project Area from pinyon-juniper to a variety of shrub-dominated communities. Vegetation communities located in the Project Area are common, and the Project would not impact any unique vegetation community. Impacts from the Project to vegetation would continue until reclamation is complete and vegetation is reestablished. However, Project-related disturbance

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would be phased, occur throughout the Project Area, and reclamation would occur in phases, thereby improving reclamation success. Pilot Goldstrike would use a BLM-approved seed mix in reclamation and native species would move back into the disturbed areas. Approximately, 204 acres of potential habitat consisting of talus slopes and rock outcrops for Nevada willowherb were identified in the Project Area. However, no individuals were found. No drill sites are proposed within areas of potential habitat for the Nevada willowherb; therefore, no impacts to the species or its habitat are expected. Impacts to vegetation from the Proposed Action are expected to be minor.

4.3.1.11 Recreation The Project has the potential to have impacts to the recreational activities that occur in the Project Area. Conversely, these activities could also have impacts on drilling operations.

If drilling operations take place in the fall, the Project could have impacts to the annual deer hunt. Hunters could be displaced by drilling operations and drilling operations could in turn, be impacted by the proximity of a large number of hunters and their associated ATVs, UTVs, and full-size vehicles. In addition, there are 15 commercial hunting guides who are authorized to operate in the area and their operations could be impacted by the Proposed Action. If deer remain in the area during hunting season, safety could become a concern with so many firearms in the immediate vicinity of the drill rigs.

As outlined in Section 2.2.10, Pilot Goldstrike would be proactive in communicating with campers/hunters on Project activities and, if needed, could potentially modify drilling activities temporarily to avoid campsites in the area. Pilot Goldstrike would ensure public safety by installing signage warning the public that the area is an active exploration site and heavy equipment traffic may be present. To prevent impacts to recreational users, Project activities would not block public access along roads in the Project Area. Pilot Goldstrike would also coordinate with the BLM if Project activities could not be avoided during the hunting season, in order to minimize effects to hunters.

Off-road recreational users could be displaced during Project activities. This is also true for commercial and organized group activities. Pilot Goldstrike would notify the BLM on the schedule of activities, so that the BLM could ensure that all commercial and organized groups would be alerted.

There are two companies the BLM permits to operate wilderness therapy programs in the area which could be displaced by the Proposed Action. Pilot Goldstrike would notify the BLM on the schedule of activities, so that the BLM could notify these groups and they could move to other locations.

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4.3.1.12 Visual Resources Project activities including exploration drilling and road maintenance and use would likely meet VRM Class III objectives and be a very close fit for the first two management objectives for Class III.

A preliminary viewshed analysis from the main roads throughout the area was conducted using a 10-meter digital elevation model (DEM) to determine how many drill sites and miles of new/re- opened roads on public lands would be visible. From the analysis, approximately 15.6 miles of proposed roads would be visible while approximately 8 miles of proposed roads would not, and 176 drill sites would be visible while 64 drill sites would not. This assumes a worst case scenario and does not factor in vegetative cover, which would obscure some of the disturbance. This analysis also assumes that all the disturbance would occur at once, when in fact the disturbance would be created (and reclaimed) incrementally and all drill sites would not be disturbed at the same time. Also, depending on the results of drilling, the total 77 acres of disturbance may not be created. Certain areas may be determined not to meet the need and not further drilled. Also, this analysis assumes that all roads and drill sites would have a high visual contrast with the existing landscape. Since unpaved roads are common in the existing landscape, the addition of more unpaved roads would not result in much visual contrast. The additional roads would look very similar to features common in the existing landscape and thus the Project would be in compliance with the objectives of the VRM Class III area.

4.3.1.13 Lands with Wilderness Characteristics The Project includes 91 proposed drill sites in three separate areas that have wilderness characteristics including Square Top Mountain (UT-040-048A), Square Top Mountain (UT-040- 048B), and Docs Pass (UT-040-124A). Each drill site would measure approximately 70 feet by 30 feet depending on terrain, and access to each drill site is also terrain dependent. Road construction would be minimized when possible in these areas. Vegetation that is crushed flat would rebound within a year or two; however, reclaimed roads would take significantly longer to return to their previous condition. Where road construction and overland travel does occur, the average road width would be 12 feet for constructed roads and six feet for cross-country travel. The total surface disturbance on public lands within the three wilderness characteristics inventory units would include: 23.5 miles of proposed roads at 12 feet wide for 45.6 acres of disturbance; and each drill pad would measure 70 by 30 feet for 2,100 square-feet or 11.46 acres for 91 drill pads. Therefore, the total surface disturbance from the Project within lands with wilderness characteristics would be 57.06 acres.

Wilderness characteristics on the disturbed acres would be lost for several years regardless of reclamation success. However, based on the appearance of other reclaimed roads and drill sites in the area, it is anticipated that wilderness characteristics would be re-established within ten years.

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During operations, the surface disturbance would not be highly visible as it would be spread out over the entire Project Area which totals 907 acres. Total surface disturbance from the Project within lands with wilderness characteristics would represent approximately six percent of the total Project Area.

4.3.2 Alternative B – No Action 4.3.2.1 Water Resources Under the No Action Alternative, Notice-level exploration activities would continue to occur. The authorized disturbance would result in minimal impacts to water resources.

4.3.2.2 Areas of Critical Environmental Concern Under the No Action Alternative, Notice-level exploration activities would continue to occur. No Notice-level drill sites are located in the ACEC; therefore, there are no effects to the ACEC from this alternative.

4.3.2.3 Cultural Resources Under the No Action Alternative, Notice-level exploration activities would continue to occur. No impacts to cultural resources are anticipated because all impacts to NRHP eligible sites or their contributing elements would be avoided.

4.3.2.4 Paleontology Under the No Action Alternative, Notice-level exploration activities would continue to occur. No impacts to paleontological resources are anticipated under this alternative.

4.3.2.5 Cave and Karst Under the No Action Alternative, Notice-level exploration activities would continue to occur. No impacts to cave and karst features are anticipated under this alternative since none are located within the Notice-level activity areas.

4.3.2.6 Socio-Economics Under the No Action Alternative, Notice-level exploration activities would continue to occur. Social values and economics would remain the same as current conditions under the No Action Alternative.

4.3.2.7 Soils Under the No Action Alternative, Notice-level exploration activities would continue to occur. The authorized disturbance would result in minimal impacts to soil erosion and stability.

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4.3.2.8 Fish and Wildlife Under the No Action Alternative, ongoing Notice-level mineral exploration activities currently permitted in the area would continue to occur. The No Action Alternative would result in negligible impacts to wildlife habitat and individuals.

4.3.2.9 Migratory Birds Under the No Action Alternative, ongoing Notice-level mineral exploration activities currently permitted in the area would continue to occur. The No Action Alternative would result in negligible impacts to avian species and their habitat.

4.3.2.10 Vegetation Under the No Action Alternative, ongoing Notice-level mineral exploration activities currently permitted in the area would continue to occur. The No Action Alternative would result in negligible impacts to vegetation.

4.3.2.11 Recreation Under the No Action Alternative, ongoing Notice-level mineral exploration activities currently permitted in the area would continue to occur. The No Action Alternative would result in minimal impacts to recreation.

4.3.2.12 Visual Resources Under the No Action Alternative, ongoing Notice-level mineral exploration activities currently permitted in the area would continue to occur. The No Action Alternative would result in negligible impacts to visual resources.

4.3.2.13 Lands with Wilderness Characteristics Under the No Action Alternative, ongoing Notice-level mineral exploration activities currently permitted in the area would continue to occur. The No Action Alternative would not result in any disturbance in areas with wilderness characteristics.

4.4 CUMULATIVE IMPACTS Cumulative impacts are those impacts resulting from the incremental impact of an action when added to other past, present, and reasonably foreseeable actions (RFAs), regardless of which agency (federal or non-federal) or person undertakes such other actions.

Cumulative impacts organized by resource issue category are described below. The No Action would not contribute incrementally to the impacts of past, present, and RFAs because under the No Action Alternative, expansion of exploration activities would not be granted and the Project

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would not be implemented. As a result, no cumulative impacts analysis associated with the No Action Alternative is presented below.

4.4.1 Water Resources 4.4.1.1 Cumulative Impact Area (CIA) The four HUC 12 hydrographic basins (Jackson Wash, Tobin Wash-Santa Clara River, East Fork Beaver Dam Wash, and Bentley Wash-Beaver Dam Wash) that overlap with the property boundary were determined to be the boundary of the cumulative impact area (CIAs) for the resources carried through for cumulative impacts. The four basins, property boundary, and Project Area encompass a total of 111,815 acres and are shown in Figure 5-1. This area was chosen because it follows topographic features and encompasses water resources that biological and human resources rely upon.

4.4.1.2 Past and Present Actions Past and present actions in the CIA include past exploration and mining activities, recreation use, residential areas in Motoqua and Gunlock, livestock grazing, limited agricultural development around Gunlock and the Santa Clara River, power lines and their ROWs, and a communication site for the Civil Air Patrol as identified from the BLM’s e-planning website (BLM, 2016). Additionally, numerous roads associated with these various actions are also present in the CIA.

Within the CIA, there are lands managed by the Dixie National Forest, BLM (including a northern portion of Beaver Dam Wash National Conservation Area), the State of Utah (including a small portion of Gunlock State Park), and private lands.

The Goldstrike district was first discovered in the late 1800s with sporadic work and production peaking around 1910. The district then sat idle until the 1970s with renewed interested in the area by several different operators. Widespread exploration in the district led to about 1,500 drill holes being completed along with an extensive road network. By the late 1980s sufficient resources had been discovered to support building a mine. The former Goldstrike open-pit, heap-leach Gold mine was developed and mined by Tenneco Minerals Company (Tenneco) from 1988 to 1993 when it was sold to USMX of Utah Inc. (USMX), who closed the mine shortly thereafter and completed the reclamation in 1994-1996. Approximately 655 acres of past mining disturbance has occurred within the Project Area. Several roads were left open after reclamation and provide connections to other roads across public lands.

Within the remote and generally undeveloped CIA, there are two small unincorporated residential areas – Motoqua and Gunlock. Motoqua consists of several homes and ranches, but is not otherwise developed. Gunlock is slightly larger and has its own Post Office and zip code.

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Past and present recreational uses focus on hunting and four-wheel drive recreation. There are several jeep trails and pack trails in the CIA, including in the Dixie National Forest lands. There are also recreational facilities associated with Gunlock Reservoir State Park, which is used for boating and fishing. Although much of the Park is outside of CIA, the upper half of the reservoir itself is within the CIA and subject to those recreational uses.

As noted above, roads are associated with many of the specific activities (both mining and non- mining) past and present uses in the CIA. GIS and aerial photo data suggest that there are approximately 320 miles of roads within the CIA, all but about 5 miles of which are unpaved.

4.4.1.3 Reasonably Foreseeable Future Action Scenario (RFAS) RFASs are decisions, funding, or formal proposals that are either existing or are highly probable based on known opportunities or trends. RFASs within the CIA include ongoing exploration, recreation, and livestock grazing activities.

4.4.1.4 Cumulative Impact Analysis Past and present actions in the CIA mainly consist of mining and exploration disturbance, residential development, recreation, livestock grazing, and development and maintenance of utility corridors which constitutes minor disturbances in a relatively large area. These actions are likely to continue in the future. These past, present, and RFAs may have resulted in increased erosion from loss of vegetation with increased sedimentation in surface waters. Previous leaching and milling operations at the site have ceased and related facilities have been closed and reclaimed, within no remaining potential for water quality impacts. The Proposed Action would implement BMPs and Pilot Goldstrike has committed to EPMs during construction, operation, and reclamation to minimize sedimentation or erosion resulting from snowmelt or precipitation events. Groundwater is not expected to be affected by the Proposed Action. The incremental cumulative effect to water resources from the Proposed Action in combination with past, present, and RFAs is expected to be minimal.

4.4.2 Areas of Critical Environmental Concern 4.4.2.1 Cumulative Impact Area The CIA is the same as described in Section 4.4.1.1.

4.4.2.2 Past and Present Actions The past and present actions are the same as described in Section 4.4.1.2.

4.4.2.3 Reasonably Foreseeable Action Scenario (RFAS) The RFASs are the same as described in Section 4.4.1.3.

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4.4.2.4 Cumulative Impact Analysis Past and present actions in the CIA mainly consist of mining and exploration disturbance, residential development, livestock grazing, and development and maintenance of utility corridors which constitutes minor disturbances in a relatively large area. These actions are likely to continue in the future. Impacts to water resources in the Upper Beaver Dam Wash ACEC from these actions would be similar to those described above in Section 5.3.1. The Proposed Action would implement BMPs and Pilot Goldstrike has committed to EPMs during construction, operation, and reclamation to minimize sedimentation or erosion resulting from snowmelt or precipitation events. The incremental cumulative effect to water resources in the ACEC from the Proposed Action in combination with past, present, and RFAs is expected to be minimal.

4.4.3 Cultural Resources 4.4.3.1 Cumulative Impact Area The CIA is the same as described in Section 4.4.1.1.

4.4.3.2 Past and Present Actions The past and present actions are the same as described in Section 4.4.1.2.

4.4.3.3 Reasonably Foreseeable Action Scenario (RFAS) The RFASs are the same as described in Section 4.4.1.3.

4.4.3.4 Cumulative Impact Analysis Past and present actions in the CIA mainly consist of mining and exploration disturbance, residential development, livestock grazing, and development and maintenance of utility corridors which constitutes minor disturbances in a relatively large area. These actions are likely to continue in the future. Impacts to cultural resources from these actions may have included direct or indirect to eligible cultural sites. The Proposed Action would avoid impacts to known eligible cultural sites and would implement an EPM to avoid impacts to unknown cultural sites. The incremental cumulative effect to cultural resources from the Proposed Action in combination with past, present, and RFAs is expected to be minimal.

4.4.4 Paleontology 4.4.4.1 Cumulative Impact Area The CIA is the same as described in Section 4.4.1.1.

4.4.4.2 Past and Present Actions The past and present actions are the same as described in Section 4.4.1.2.

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4.4.4.3 Reasonably Foreseeable Action Scenario (RFAS) The RFASs are the same as described in Section 4.4.1.3.

4.4.4.4 Cumulative Impact Analysis Past and present actions in the CIA mainly consist of mining and exploration disturbance, residential development, livestock grazing, and development and maintenance of utility corridors which constitutes minor disturbances in a relatively large area. These actions are likely to continue in the future. Impacts to paleontological resources from these actions may have resulted in direct impacts to fossil bearing geologic units. The Proposed Action is not expected to impact known paleontological resources and through implementation of the EPM described in Section 2.2.10 would avoid impacts to unknown paleontological resources. There is no incremental cumulative effect to paleontological resources expected from the Proposed Action in combination with past, present, and RFAs.

4.4.5 Cave and Karst 4.4.5.1 Cumulative Impact Area The CIA is the same as described in Section 4.4.1.1.

4.4.5.2 Past and Present Actions The past and present actions are the same as described in Section 4.4.1.2.

4.4.5.3 Reasonably Foreseeable Action Scenario (RFAS) The RFASs are the same as described in Section 4.4.1.3.

4.4.5.4 Cumulative Impact Analysis Past and present actions in the CIA mainly consist of mining and exploration disturbance, residential development, livestock grazing, and development and maintenance of utility corridors which constitutes minor disturbances in a relatively large area. These actions are likely to continue in the future. Impacts to cave and karst resources from these actions may have resulted in direct impacts to higher potential karst forming geologic units. In order to minimize potential effects to higher potential karst forming units, the Proposed Action would implement BMPs and EPMs. There would potentially be a small incremental cumulative effect to cave and karst resources expected from the Proposed Action in combination with past, present, and RFAs.

4.4.6 Socio-Economics 4.4.6.1 Cumulative Impact Area The CIA is the same as described in Section 4.4.1.1.

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4.4.6.2 Past and Present Actions The past and present actions are the same as described in Section 4.4.1.2.

4.4.6.3 Reasonably Foreseeable Action Scenario (RFAS) The RFASs are the same as described in Section 4.4.1.3.

4.4.6.4 Cumulative Impact Analysis Past and present actions in the CIA mainly consist of mining and exploration disturbance, residential development, livestock grazing, and development and maintenance of utility corridors which constitutes minor disturbances in a relatively large area. These actions are likely to continue in the future. Impacts to socio-economics from these actions have resulted in long-term positive effects. The Proposed Action is expected to a short-term beneficial effect to the local economy. The incremental cumulative effect to socio-economics from the Proposed Action in combination with past, present, and RFAs is expected to be minimal.

4.4.7 Soils 4.4.7.1 Cumulative Impact Area The CIA is the same as described in Section 4.4.1.1.

4.4.7.2 Past and Present Actions The past and present actions are the same as described in Section 4.4.1.2.

4.4.7.3 Reasonably Foreseeable Action Scenario (RFAS) The RFASs are the same as described in Section 4.4.1.3.

4.4.7.4 Cumulative Impact Analysis Past and present actions in the CIA mainly consist of mining and exploration disturbance, residential development, livestock grazing, and development and maintenance of utility corridors which constitutes minor disturbances in a relatively large area. These actions are likely to continue in the future. Impacts to soils from these actions may include increased erosion. The Project would increase disturbance in the CIA by up to 77 acres, which could also increase erosion and sedimentation. Incremental disturbance, concurrent reclamation, and implementation of BMPs and EPMs would minimize impacts to soils from the Proposed Action and other actions in the CIA. The incremental cumulative effect from the Proposed Action in combination with past, present, and RFAs is expected to be minimal.

4.4.8 Fish and Wildlife 4.4.8.1 Cumulative Impact Area The CIA is the same as described in Section 4.4.1.1.

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4.4.8.2 Past and Present Actions The past and present actions are the same as described in Section 4.4.1.2.

4.4.8.3 Reasonably Foreseeable Action Scenario (RFAS) The RFASs are the same as described in Section 4.4.1.3.

4.4.8.4 Cumulative Impact Analysis Past and present actions in the CIA mainly consist of mining and exploration disturbance, residential development, livestock grazing, and development and maintenance of utility corridors which constitutes minor disturbances in a relatively large area. These actions are likely to continue in the future. These actions have likely had direct impacts to wildlife individuals and populations, as well as indirect impacts to habitat. The Project would increase disturbance in the CIA by up to 77 acres, which could also result in direct and indirect impacts to wildlife. Concurrent reclamation as well as implementation of BMPs and EPMs would minimize impacts from the Proposed Action. Forage has again become available to wildlife on many of the previously reclaimed mining disturbances. The incremental cumulative effect to wildlife from the Proposed Action in combination with past, present, and RFAs is expected to be minimal.

4.4.9 Migratory Birds 4.4.9.1 Cumulative Impact Area The CIA is the same as described in Section 4.4.1.1.

4.4.9.2 Past and Present Actions The past and present actions are the same as described in Section 4.4.1.2.

4.4.9.3 Reasonably Foreseeable Action Scenario (RFAS) The RFASs are the same as described in Section 4.4.1.3.

4.4.9.4 Cumulative Impact Analysis Past and present actions in the CIA mainly consist of mining and exploration disturbance, residential development, livestock grazing, and development and maintenance of utility corridors which constitutes minor disturbances in a relatively large area. These actions are likely to continue in the future. Direct and indirect impacts to migratory birds from these actions likely occurred. The Project would increase disturbance in the CIA by up to 77 acres, which could also result in direct and indirect impacts to migratory birds. Concurrent reclamation as well as implementation of BMPs and EPMs would minimize impacts to migratory birds from the Proposed Action. The incremental cumulative effect from the Proposed Action in combination with past, present, and RFAs is expected to be minimal.

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4.4.10 Vegetation 4.4.10.1 Cumulative Impact Area The CIA is the same as described in Section 4.4.1.1.

4.4.10.2 Past and Present Actions The past and present actions are the same as described in Section 4.4.1.2.

4.4.10.3 Reasonably Foreseeable Action Scenario (RFAS) The RFASs are the same as described in Section 4.4.1.3.

4.4.10.4 Cumulative Impact Analysis Past and present actions in the CIA mainly consist of mining and exploration disturbance, residential development, livestock grazing, and development and maintenance of utility corridors which constitutes minor disturbances in a relatively large area. These actions are likely to continue in the future. Direct effects from vegetation removal occurred as a result of these actions. The Project would increase disturbance in the CIA by up to 77 acres, which could also result in vegetation removal. Incremental disturbance, concurrent reclamation, and implementation of BMPs and EPMs would minimize impacts to vegetation from the Proposed Action and other actions in the CIA. The incremental cumulative effect from the Proposed Action in combination with past, present, and RFAs is expected to be minimal.

4.4.11 Recreation 4.4.11.1 Cumulative Impact Area The CIA is the same as described in Section 4.4.1.1.

4.4.11.2 Past and Present Actions The past and present actions are the same as described in Section 4.4.1.2.

4.4.11.3 Reasonably Foreseeable Action Scenario (RFAS) The RFASs are the same as described in Section 4.4.1.3.

4.4.11.4 Cumulative Impact Analysis Past and present actions in the CIA mainly consist of mining and exploration disturbance, residential development, livestock grazing, and development and maintenance of utility corridors which constitutes minor disturbances in a relatively large area. These actions are likely to continue in the future. Impacts to recreation may have included blocked access. The Proposed Action could impact recreational activities in the CIA. Implementation of EPMs would minimize impacts to recreation. The incremental cumulative effect from the Proposed Action in combination with past, present, and RFAs is expected to be minimal.

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4.4.12 Visual Resources 4.4.12.1 Cumulative Impact Area The CIA is the same as described in Section 4.4.1.1.

4.4.12.2 Past and Present Actions The past and present actions are the same as described in Section 4.4.1.2.

4.4.12.3 Reasonably Foreseeable Action Scenario (RFAS) The RFASs are the same as described in Section 4.4.1.3.

4.4.12.4 Cumulative Impact Analysis Past and present actions in the CIA mainly consist of mining and exploration disturbance, residential development, livestock grazing, and development and maintenance of utility corridors which constitutes minor disturbances in a relatively large area. These actions are likely to continue in the future. Impacts from these actions resulted in mostly minimal visual contrast due to their small size and due to the fact that many of the mining areas have been reclaimed (e.g., pits backfilled and surfaces revegetated). Surface disturbance associated with the Proposed Action is consistent with VRM Class III objectives and is expected to not create much visual contrast. The incremental cumulative effect from the Proposed Action in combination with past, present, and RFAs is expected to be minimal.

4.4.13 Lands with Wilderness Characteristics 4.4.13.1 Cumulative Impact Area The CIA is the same as described in Section 4.4.1.1.

4.4.13.2 Past and Present Actions The past and present actions are the same as described in Section 4.4.1.2.

4.4.13.3 Reasonably Foreseeable Action Scenario (RFAS) The RFASs are the same as described in Section 4.4.1.3.

4.4.13.4 Cumulative Impact Analysis Past and present actions in the CIA mainly consist of mining and exploration disturbance, residential development, livestock grazing, and development and maintenance of utility corridors which constitutes minor disturbances in a relatively large area. These actions are likely to continue in the future. Impacts to lands with wilderness characteristics from these actions were likely minimal consisting of impacts to vegetation and opportunities for solitude. The Project includes 91 proposed drill sites in lands with wilderness characteristics which would result in localized

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5.0 CONSULTATION AND COORDINATION AND LIST OF PREPARERS

5.1 PERSONS, GROUPS, AND AGENCIES CONSULTED Need input from the BLM.

5.2 SUMMARY OF PUBLIC PARTICIPATION The BLM conducted internal scoping on the Proposed Action and Completed an ID team checklist on June 1, 2016. Issues identified by the ID team were incorporated into this EA for analysis.

The Plan of Operations was made available to the public on August 15, 2016, and comments were requested by September 14, 2016. A public scoping meeting was held on August 22, 2016, at the Dixie Convention Center to discuss the proposed Project with interested members of the public. Notice of the public meeting was published on the BLM website on August 16, 2016, and also appeared in the St George News online publication on August 22, 2016 (https://www.stgeorgeutah.com/news/archive/2016/08/22/jla-goldtrike-mining-could-rise-again- public-meeting-tonight/#.V8x28fkrKUk). Additional information on public participation is summarized in Section 1.6, Identification of Issues.

As noted in Section 1.6, public scoping resulted in a total of seven public scoping letters. Some respondents have expressed support or concerns about the Proposed Action, and/or provided scoping comments dealing with procedures and legal issues, the range and description of alternatives to be addressed and specific resource issues for analysis.

A list of numbered comments under each topic is provided for quick reference, followed by summarized comments and responses.

Opposition to and Support for the Exploration Project (OS) OS-1 The State supports Pilot Goldstrike’s proposal to conduct mineral exploration activities in Washington County.

OS-2 Commenter believes the mining method will not damage the environment.

Procedural and Legal Issues (PL) PL-1 An EIS must be prepared to take a hard look at the proposed Project’s environmental impacts.

PL-2 BLM must consider and analyze a reasonable range of alternatives to the Proposed Action.

PL-3 The EA must analyze the cumulative and indirect impacts from nearby projects.

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PL-4 BLM should require an EIS, in part because an EIS would more adequately address cumulative impacts.

PL-5 Applicant promised measures and BLM required stipulations, responsibilities, accountability, and bond information should be provided.

PL-6 A phased-development alternative should be fully analyzed in the EA.

Comments on Issues and Analysis (AQ – Air Quality, CR – Cultural Resources, FW-1 Fish and Wildlife, RC – Recreation, SE – Socioeconomic, SR – Soil Resources, VG – Vegetation, VR – Visual Resources, WR – Water Resources)

AQ-1 The proposed project will be subject to R307-205-5 Fugitive Dust, of the Utah Air Quality Rules, and steps needed to be taken to minimize fugitive dust.

AQ-2 Exploration could degrade air quality from increased levels of ozone and particulates.

AQ-3 The air quality analysis should include nitrous oxides and volatile organic compounds.

AQ-4 Analyze the impact on Washington County’s air quality from the exploration for gold, in regard to fugitive dust.

AQ-5 Analyze air quality effects from proposed activities, including fugitive dust from extensive driving on unpaved roads.

AQ-6 Greenhouse gas emissions from proposed activities, including operation of gas-powered vehicles and machines should be analyzed.

CR-1 BLM must initiate consultation with the SHPO, relevant and affected Tribes, and other interested parties; must conduct a Class III cultural resource inventory; and seek ways to avoid, minimize, and mitigate any adverse effects.

FW-1 Potential effects of the project on mule deer.

FW-2 Noise and displacement would be detrimental to wildlife migration through the nearby migratory corridors.

FW-3 The roads will fragment habitat and disrupt movement patterns between summer and winter habitats and could lead to population declines.

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FW-4 Wildlife effects, including special status species and migratory bird species, both direct and indirect.

FW-5 Wildlife migration effects on deer, mountain lions, and other species.

FW-6 Wildlife is a concern because hunting is very popular in the region, including for local hunters.

RC-1 Recreation effects, including increased noise and disturbance from project operations and related increased road traffic, and reduced solitude for hiking and primitive camping.

RC-2 Access to High Desert ATV trail must be a priority.

SE-1 Reopening this previously reclaimed area would have large monetary and environmental costs.

SE-2 Public safety effects, including whether any dangerous conditions or contamination sources may be created on public lands.

SE-3 The Brackens need north and south road access along the East Fork Beaver Dam Wash to access private property.

SE-4 The Brackens support the mine but do not support waterlines above ground on the road, as were used by Tenneco.

SR-1 BLM should require current soil tests to confirm that past gold mining operations were properly reclaimed and are not Super Fund sites.

VG-1 Vegetation removal, disturbance, and restoration effects, invasive and noxious weed species, and how changes in vegetation may affect fuel loads and potential changes in fire patterns and effects.

VR-1 Visual resource effects in terms of how the existing landscape may be changed from the perspective of the visiting public.

WR-1 Potential impacts to watershed integrity and water quality and to riparian resources due to the presence within the Upper Beaver Dam Wash ACEC.

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WR-2 The project borders the Upper Beaver Dam Wash ACEC, which is should be managed to preserve watershed integrity and water quality and to riparian resources.

WR-3 Impacts to water quality and quantity effects, both surface and groundwater, from proposed activities, including any potential for leaks or spillage of hazardous substances as well as storm water runoff.

Comments and Responses Kathleen Clarke, Director, Public Lands Policy Coordinating Office, Office of the Governor, State of Utah

(OS-1) The State supports Pilot Goldstrike’s proposal to conduct mineral exploration activities in Washington County. Comment noted.

(AQ-1) The proposed Project will be subject to R307-205-5 Fugitive Dust, of the Utah Air Quality Rules, and steps needed to be taken to minimize fugitive dust. Response to AQ-1: Chapter 2 of the EA discusses measures for minimization of dust.

Luke Henry, Southern Utah Wilderness Alliance (PL-1) An EIS must be prepared to take a hard look at the proposed project’s environmental impacts. Response to PL-1: BLM disagrees that this exploration project constitutes as major federal action at this time. Proposed disturbance areas are small and dispersed, and disturbance would be created incrementally. No significant impacts from the Proposed Action have been identified. Should the EA analyses conclude otherwise, an EIS could become necessary in the future. Further, should the project evolve post-exploration to other activities, the BLM would consider the need for and EIS at the time that a Mine Plan of Operations is submitted.

(PL-2) BLM must consider and analyze a reasonable range of alternatives to the Proposed Action. This should include an alternative that requires the project proponent to narrowly focus on the highest probability mineral lands, which would minimize adverse surface-disturbing activities while still meeting the need of the project proponent. It should also include: an alternative that removes surface-disturbing activities in lands with wilderness characteristics; an alternative that requires use of existing, constructed, and maintained roads and prohibits new road construction or reconstruction of routes that BLM has identified as “reclaimed;” and an alternative that avoids surface-disturbing activities in the Upper Beaver Dam Wash ACEC and the proposed Bull Valley Mountains Multi-Species Management Area.

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Response to PL-2: As required by NEPA, this EA includes analysis of the No Action Alternative, under which the Proposed Action would not be approved. Section 2.4 discusses alternatives that were considered but eliminated from detailed analysis. This included consideration of alternate access. Further, other viable alternatives to exploration are limited by the location of the mineralized deposit.

(PL-3) The EA must analyze the cumulative and indirect impacts from nearby projects. Response to PL-3: Chapter 4 of the EA addresses cumulative impacts to all resources that are carried forward in the EA.

(WR-1) BLM must take a hard look at the potential impacts to watershed integrity and water quality and to riparian resources within the project area and, specifically, within the portion of the project located in the Upper Beaver Dam Wash ACEC, which is supposed to be managed to preserve those resources. Response to WR-1: The Upper Beaver Dam Wash ACEC management, including these subjects, is discussed in the EA (see Section 3.2.2).

(FW-1) The project is located on crucial habitat for mule deer, and partially within the proposed Bull Valley Mountains Multi-Species Management Area in the Proposed Resource Management Plans for the Beaver Dam Wash National Conservation Area and Red Cliffs National Conservation Area, so the BLM must take a hard look at the potential effects of the project on mule deer. Response to FW-1: Impacts to mule deer have been considered in the EA as part of the Wildlife Resources section (see Section 3.2.8) as one of the resources carried forward for detailed analysis.

(CR-1) BLM must initiate consultation with the SHPO, relevant and affected Tribes, and other interested parties. To ensure meaningful consultation, BLM must conduct a Class III cultural resource inventory of the area of potential effects of the proposed Bull Valley Project prior to issuing a decision and must seek ways to avoid, minimize, and mitigate any adverse effects on all cultural resources that it discovers. Response to CR-1: A Class III cultural resource inventory was conducted for the entire Project Area and results and potential impacts are discussed in the EA (see Section 3.2.3). Consultations with the SHPO are underway. The EA contains a discussion of environmental protection measures for cultural resources (see Section 2.2.10). The Proposed Action is not unlikely to limit access to, or interfere with ceremonial use of sacred sites; nor, would it adversely impact the integrity of such known sites. However, the BLM will continue to consult with Tribes regarding the undertaking.

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Chris Gorzalski for the SW Utah Broadband Great Old Broads for Wilderness (FW-2) Noise and displacement would be detrimental to wildlife migration through the nearby migratory corridors. Response to FW-2: Wildlife migration has been considered in the EA as part of the Wildlife Resources section (see Section 3.2.8) as one of the resources carried forward for detailed analysis.

(SE-1) Reopening this previously reclaimed area would have large monetary and environmental costs. Response to SE-1: The costs and benefits of reopening the mine have been considered in the EA as part of the Socioeconomics section (see Section 3.2.6) as one of the resources carried forward for detailed analysis.

Jane Whalen for Conserve Southwest Utah (PL-4) BLM should require an Environmental Impact Statement (EIS), in part because an EIS would more adequately address cumulative impacts. Response to PL-4: BLM disagrees that this exploration project requires an EIS. Proposed disturbance is small and dispersed, and would be occur incrementally. There is no indication at this time that there is the potential for significant impacts with the Proposed Action. Should the EA analyses conclude otherwise, an EIS could become necessary in the future. Further, should the Project evolve post-exploration to other activities, the BLM would consider the need for and EIS at the time that a Mine Plan of Operations is submitted. Cumulative effects are described in Chapter 4 of the EA.

(SR-1) BLM should require current soil tests to confirm that past gold mining operations were properly reclaimed and are not Super Fund sites. Response to SR-1: The success of past revegetation efforts provides evidence that the past operations were properly reclaimed. In addition, soil analysis was recently completed as described in Section 3.2.7.

(AQ-2) BLM should address how the exploration could degrade air quality from increased levels of ozone and particulates. Response to AQ-2: BLM disagrees that this Project requires an analysis of ozone. The EA discussed fugitive dust control to minimize particulates (see Chapter 2).

(AQ-3) The air quality analysis should include nitrous oxides and volatile organic compounds, as they are ozone precursors. Response to AQ-3: BLM disagrees that this Project requires an analysis of these ozone precursors.

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(AQ-4) What will be the impact on Washington County’s air quality from the exploration for gold, in regard to fugitive dust? Response to AQ-4: The EA discussed fugitive dust control to minimize particulates (see Chapter 2).

(WR-2) The project borders the Upper Beaver Dam Wash ACEC, which is should be managed to preserve watershed integrity and water quality and to riparian resources. Response to WR-2: The Upper Beaver Dam Wash ACEC management, including these subjects, is discussed in the EA (see Section 3.2.2).

(FW-3) The project area is a wildlife corridor from the Pine Valley Mountains to Beaver Dam Wash NCA. The roads will fragment habitat and disrupt movement patterns between summer and winter habitats. This could lead to population declines. BLM should consider limiting disruptive activities during the migration season. Response to FW-3: Wildlife migration has been considered in the EA as part of the Wildlife Resources section (see Section 3.2.8) as one of the resources carried forward for detailed analysis.

Carolyn Borg (AQ-5) Air quality effects from proposed activities, including fugitive dust from extensive driving on unpaved roads. Response to AQ-5: Chapter 2 of the EA discusses measures for minimization of dust.

(AQ-6) Greenhouse gas emissions from proposed activities, including operation of gas-powered vehicles and machines. The recent CEQ final guidance on climate change and NEPA compliance should be consulted in terms of developing the relevant calculations. Response to AQ-6: BLM does not anticipate that the Proposed Action has the potential to measurably increase greenhouse gas emissions because of the small amount of proposed surface disturbance and the short duration of the Project, thus they are not analyzed in the EA.

(WR-3) Water quality and quantity effects, both surface and groundwater, from proposed activities, including any potential for leaks or spillage of hazardous substances as well as storm water runoff. For example, heap leach mining uses highly dangerous chemicals that may pose serious contamination threats. Response to WR-3: The proponent would obtain a Stormwater Construction Permit and would implement BMPs to managed stormwater runoff and any spills (see Section 2.2.6).

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This project does not propose any heap leach mining or any other activity that uses “highly dangerous chemicals”.

(VG-1) Vegetation removal, disturbance, and restoration effects, including the potential to introduce or expand invasive and noxious weed species, and how changes in vegetation may affect fuel loads and potential changes in fire patterns and effects. Response to VG-1: The EA discusses vegetation, proposed disturbance, and reclamation, including invasive plants and noxious weeds (see Section 3.2.10). The proponent would comply with all applicable fire laws and regulations (see Section 2.2.10).

(FW-4) Wildlife effects, including special status species and migratory bird species, both direct (habitat loss and fragmentation, roadkills, open pits, etc.) and indirect (avoidance or reduced use due to human presence, increased vehicle traffic, noise, etc.) Response to FW-4: Wildlife, including special status species and migratory bird species, have been considered in the EA as part of the Wildlife Resources section (see Section 3.2.8) as one of the resources carried forward for detailed analysis.

(FW-5) Wildlife migration effects, given the acknowledgement by BLM in the DRMP/DEIS released last year, in Alternative C, that this area is a crucial movement corridor for deer, mountain lions, and other species. Response to FW-5: Wildlife migration has been considered in the EA as part of the Wildlife Resources section (see Section 3.2.8) as one of the resources carried forward for detailed analysis.

(RC-1) Recreation effects, including increased noise and disturbance from project operations and related increased road traffic, and reduced solitude for hiking and primitive camping. Response to RC-1: Recreation has been considered and analyzed in the EA in the Recreation section (see Section 3.2.11) as one of the resources carried forward for detailed analysis.

(SE-2) Public safety effects, including whether any dangerous conditions or contamination sources may be created on public lands. Response to SE-2: Public safety has been considered and addressed in the EA, within the description of the Proposed Action including Environmental Protection Measures (see Chapter 2, including Section 2.2.10).

(VR-1) Visual resource effects in terms of how the existing landscape may be changed from the perspective of the visiting public.

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Response to VR-1: Visual Resources have been considered and addressed in the EA (see Section 3.2.12).

(PL-5) Mitigation and monitoring, best management practices, and other applicant promised measures and BLM required stipulations, and who is responsible for each, how accountability for performance is ensured, what happens if a measure is not successful or is not performed, and what bond has been posted so that BLM has the ability to ensure adequate performance even if the applicant later goes bankrupt. Response to PL-5: As appropriate, some of these subjects have been addressed in Chapters 1 and 2 in the EA. Others, such as bond requirements, are handled outside of the NEPA process once a determination has been made.

(PL-6) In addition to the required no action alternative, I recommend that a phased-development alternative be fully analyzed in the EA given the long proposed timeframe. This alternative would minimize the project footprint at each stage and allow for phased vegetation rehabilitation and assurance that mitigation and monitoring requirements are being met. This alternative would also likely reduce many potential direct, indirect, and cumulative adverse impacts. Response to PL-6: As required by NEPA, this EA includes analysis of the No Action Alternative, under which the Proposed Action would not be approved. Section 2.4 discusses alternatives that were considered but eliminated from detailed analysis.

Anonymous (OS-2) Commenter believes the mining method will not damage the environment. Comment noted.

(FW-6) Wildlife is a concern because hunting is very popular in the region, including for local hunters. Response to FW-6: Wildlife, including large game, has been considered in the EA as part of the Wildlife Resources section (see Section 3.2.8) as one of the resources carried forward for detailed analysis.

Bryan Thiriot for Bracken Family Trust (SE-3) The Brackens need north and south road access along the East Fork Beaver Dam Wash to access private property. Response to SE-3: No public access roads would be blocked (see Section 2.2.10).

(SE-4) The Brackens support the mine but do not support waterlines above ground on the road, as were used by Tenneco.

BULL VALLEY EXPLORATION PROJECT ENVIRONMENTAL ASSESSMENT MAY 2017 PILOT GOLDSTRIKE INC. 66

Response to SE-4: Pilot Goldstrike is not planning to use any kind of piping for water supply and delivery and no public access roads would be blocked (see Section 2.2.10).

(RC-2) Access to High Desert ATV trail must be a priority. Response to RC-1: ATV usage has been considered and analyzed in the EA in the Recreation section (see Section 3.2.11) as one of the resources carried forward for detailed analysis.

5.3 LIST OF PREPARERS Below is a list of BLM staff and consultants who contributed to the preparation of the EA.

Bureau of Land Management, St George Field Office Rody Cox Project Lead John Kellam Environmental Coordinator David Corry Water Resources, Soils, Fish and Wildlife, Vegetation David Kiel ACEC, Socio-Economics, Recreation, Visual Resources, Lands with Wilderness Characteristics Lori Hunsaker Cultural Resources Kyle Voyles Paleontology, Cave and Karst Robert Douglas Fish and Wildlife, Migratory Birds, Vegetation R. Reese Livestock Grazing Teresa Burke Lands and Realty

Non-BLM Preparers - Stantec Consulting Services Inc. Greg Brown Project Manager Michele Lefebvre Assistant Project Manager, Lead Author George Dix Visual Resources Karla Knoop NEPA Assistance Kim Carter Administrative Assistance Jason Trook GIS/Figures

Pilot Goldstrike Pete Shabestari Gerald Heston

BULL VALLEY EXPLORATION PROJECT ENVIRONMENTAL ASSESSMENT MAY 2017 PILOT GOLDSTRIKE INC. 67

6.0 REFERENCES

Bureau of Land Management (BLM). 1986. Manual H-8410-1 – Visual Resource Inventory. http://www.blm.gov/style/medialib/blm/wo/Information_Resources_Management/policy/ blm_handbook.Par.31679.File.dat/H-8410.pdf (accessed October 3, 2016).

Bureau of Land Management (BLM). 1988. Areas of Critical Environmental Concern. BLM Manual 1613.

Bureau of Land Management (BLM). 1992. Solid Minerals Reclamation Handbook. BLM Manual Handbook H-3402-1. ftp://ftp.blm.gov/pub/blmlibrary/BLMpublications/BLM_ManualsAndHandbooks/3042_ 1_SolidMinerals Handbook_Part_1.pdf (Accessed June 3, 2012).

Bureau of Land Management (BLM). 1999. St. George Field Office Record of Decision and Resource Management Plan. Salt Lake City, Utah: United States Department of Interior, Bureau of Land Management.

Bureau of Land Management (BLM). 2011. Upper Beaver Dam Wash ACEC. Retrieved on September 12, 2016, from http://www.blm.gov/ut/st/en/fo/st__george/blm_special_areas/areas_of_critical/upper_be aver_dam_wash.html

Bureau of Land Management (BLM). 2012a. Manual 6310 – Considering Lands with Wilderness Characteristics in the BLM Land Use Process (Public). Release 6-130. Dated Mary 15, 2012.

Bureau of Land Management (BLM). 2012b. Surface Management of Mining Operations Handbook, H-3809-1.

Bureau of Land Management (BLM). 2015. BLM Roads Manual #MS 9113.

Bureau of Land Management (BLM). 2016. ePlanning website. https://eplanning.blm.gov/epl- front-office/eplanning/nepa/nepa_register.do. Accessed October 10, 2016.

Chesser, R. Terry; Banks, Richard C.; Barker, F. Keith; Cicero, Carla; Dunn, Jon L.; Kratter, Andrew W.; Lovette, Irby J.; Rasmussen, Pamela C.; Remsen, Jr., J. V.; Rising, James D.; Stotz, Douglas F.; Winker, Kevin (July 2013). "Fifty-Fourth Supplement to the American Ornithologists' Union Check-list of North American Birds". The Auk 130 (3): 558–572. doi:10.1525/auk.2013.130.3.558.

City of St. George. 2016. Public Safety: Fire Department. Retrieved on September 15, 2016, from https://www.sgcity.org/publicsafety/firedepartment

Desjean, Thomas and Robert Wilson. 1990. Vandalism Behavior in the Southeast National Parks Diagnosis and Treatment. In Coping with Site Looting, Southeastern Perspectives. Edited by John Ehrenhard.

BULL VALLEY EXPLORATION PROJECT ENVIRONMENTAL ASSESSMENT MAY 2017 PILOT GOLDSTRIKE INC. 68

Fridell, R., and K. Comella. 2007. Birds Protected By The Migratory Bird Treaty Act Occurring in Washington County, Utah. Utah Division of Wildlife Resources and Utah Division of Parks and Recreation, Unpublished Data.

Hintze, L.F. 1980. Geologic Map of Utah: Utah Geological and Mineral Survey, scale 1:500,000.

JBR Environmental Consultants, Inc. (JBR). 1993. Gold Strike Draft EA.

Lyneis, M., D. Weide, and E. Warren. 1980. Impacts Damage to Cultural Resources of the California Desert. Department of Anthropology, University of Nevada, Las Vegas.

Natural Resources Conservation Service (NRCS). (2016). Custom Soils Resource Report for Washington County Area, Utah. Accessed on September 8, 2016, from http://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm

Nickens, P.R., S.L. Larralde, and G. C. Tucker. 1981. A Survey of Vandalism to Archaeological Resources in Southwestern Colorado. Bureau of Land Management – Colorado Cultural Resources Series, No. 11, Denver.

Parrish, J. R., F. P. Howe, R. E. Norvell. 2002. Utah Partners in Flight Avian Conservation Strategy Version 2.0. Utah Partners in Flight Program, Utah Division of Wildlife Resources, Salt Lake City, UT.

Rappole, J. H., and M. V. McDonald. 1994. Cause and Effect in Population Declines of Migratory Birds. The Auk 111(3):652-660.

Stantec Consulting Services Inc. 2016a. 2016 Biological Baseline Survey Report: Bull Valley Exploration Project: Washington County, Utah. St. George, Utah: Stantec Consulting Services Inc.

Stantec Consulting Services Inc. 2016b. Pilot Gold Bull Valley Project, May 2016 Soil and Water Sampling Memo. Unpublished document.

U.S. Census Bureau. 2010a. 2010 Census Summary File 1: Total Population: St. George, Utah Metro Area. Retrieved on September 15, 2016, from http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_1 0_SF1_P1&prodType=table

U.S. Census Bureau. 2010b. 2010 Census Summary File 1: Total Population: Washington County, Utah. Retrieved on September 15, 2016, from http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_1 0_SF1_P1&prodType=table

BULL VALLEY EXPLORATION PROJECT ENVIRONMENTAL ASSESSMENT MAY 2017 PILOT GOLDSTRIKE INC. 69

U.S. Census Bureau. 2014a. 2010-2014 American Community Survey 5-Year Estimates: Employment Status: St. George, Utah Metro Area. Retrieved on September 15, 2016, from http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ACS_1 4_5YR_S2301&prodType=table

U.S. Census Bureau. 2014b. 2010-2014 American Community Survey 5-Year Estimates: Selected Housing Characteristics: St. George, Utah Metro Area. Retrieved on September 15, 2016, from http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ACS_1 4_5YR_DP04&prodType=table

U.S. Department of Agriculture, Soil Conservation Service. 1977. Soil Survey of Washington County Area, Utah. Utah: U.S. Department of Agriculture, Soil Conservation Service, Bureau of Land Management, and National Park Service.

U.S. Geological Survey. 1997. Hydrology and Water Quality of the Beaver Dam Wash Area, Washington County, Utah, Lincoln County, Nevada, and Mohave County, Arizona. Water- Resources Investigations Report 97-4193. Salt Lake City, Utah: U.S. Geological Survey.

Utah Division of Wildlife Resources (UDWR). 2015. UDWR-Utah BLM Avian Sensitive Species List. http://dwrcdc.nr.utah.gov/ucdc/ViewReports/SS_List.pdf).

Utah Department of Workforce Services. 2016. Economic Snapshot: Washington County. Retrieved on September 15, 2016, from http://jobs.utah.gov/wi/regions/county/washington.html

U.S. Fish and Wildlife Service. (USFWS). 2008. 2008. Birds of Conservation Concern 2008. United States Department of Interior, Fish and Wildlife Service, Division of Migratory Bird Management, Arlington, Virginia. 85 pp. [Online version available at ]

Utah Division of Oil, Gas, and Mining (DOGM). Undated. The Practical Guide to Reclamation in Utah. Mary Ann Wright, executive editor. https://fs.ogm.utah.gov/PUB/MINES/Coal_Related/RecMan/Reclamation_Manual.pdf (Accessed April 15, 2015.)

WSA, Inc. 2016. Cultural Resources Inventory Report: Bull Valley Exploration Project: Washington County, Utah. Cedar City, Utah: WSA, Inc.

Washington County. 2010. The General Plan of Washington County, Utah. Amended August 2012.

BULL VALLEY EXPLORATION PROJECT ENVIRONMENTAL ASSESSMENT MAY 2017 PILOT GOLDSTRIKE INC. 70

Williams, L.R. 1978. Vandalism to Cultural Resources of the Rocky Mountain West. Cultural Resources Report No. 21. U.S.D.A. Forest Service, Southwest Region, Albuquerque.

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FIGURES

«¬18 Goldstrike Road

Main Access Alternative Route Access Route Mo to qu a d

R a o ad o R

k

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O ld H i gh w a y 91

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St. George

Salt Lake City ^

St. George "

FIGURE 1-1 PROJECT LOCATION Legend PILOT GOLDSTRIKE INC. Access Road BULL VALLEY EXPLORATION PROJECT Property Boundary (as of September 2016)

NO WARRANTY IS MADE BY THE BUREAU OF LAND MANAGEMENT AS TO THE Project Area ACCURACY, RELIABILITY, OR COMPLETENESS OF THESE DATA FOR INDIVIDUAL USE OR AGGREGATE USE s WITH OTHER DATA. ORIGINAL DATA WERE 0 1 2 4 COMPILED FROM VARIOUS SOURCES. Miles 1 inch = 4 miles Hassayampa Mine Goldtown 1 "

Facilities Padre "

"

Goldtown 2

" "

" Main

" " "

Basin " Leach Covington Pad

" Hamburg Leach Pad

Moosehead " " Caribou

Beavertail "

FIGURE 1-2 EXISTING DISTURBANCE Legend PILOT GOLDSTRIKE INC. Drill Sites Regional Roads Dixie National Forest BULL VALLEY EXPLORATION PROJECT !. Notice of Intent - Permitted Open Mine Road Proposed Roads Reclaimed Mine Road NO WARRANTY IS MADE BY THE BUREAU OF LAND MANAGEMENT AS TO THE ACCURACY, RELIABILITY, OR COMPLETENESS OF THESE DATA FOR INDIVIDUAL USE NOI - permitted Surface Owner OR AGGREGATE USE WITH OTHER DATA. ORIGINAL 0 2,500 5,000 DATA WERE COMPILED FROM VARIOUS SOURCES. THIS Private Feet INFORMATION MAY NOT MEET NATIONAL MAP Old Facilities ACCURACY STANDARDS. THIS PRODUCT WAS s 1 inch = 2,500 feet DEVELOPED THROUGH DIGITAL MEANS AND MAY BE Existing Pit Outlines BLM Date: 10/11/2016 UPDATED WITHOUT NOTIFICATION. 08 09 10 11 12 07 08 09 10 R.19W R.18W 11 12

17 16 Dixie 15 14 13 18 National 17 16 15 14 Forest 13

20 21 22 23 24 19 20 21 22 23 24

29 28 27 26 25 30 29 28 27 26 25

32 33 34 35 36 31 32 33 34 35 36 T.39S T.40S T.39S T.40S 05 04 03 02 01 06 05 04 03 02 01

R.19W R.18W 08 09 10 11 Copyright:© 2013 National Geographic Society, i-cubed 12 07 08 09 FIGURE 2-1 PROPOSED DISTURBANCE Legend PILOT GOLDSTRIKE INC. Drill Sites Regional Roads Surface Owner BULL VALLEY EXPLORATION PROJECT !. Notice of Intent - Permitted Open Mine Road BLM

!. Plan of Operations Reclaimed Mine Road Private NO WARRANTY IS MADE BY THE BUREAU OF LAND MANAGEMENT AS TO THE ACCURACY, RELIABILITY, OR COMPLETENESS OF THESE DATA FOR INDIVIDUAL USE Drill Roads Project Area Utah SITLA OR AGGREGATE USE WITH OTHER DATA. ORIGINAL 0 3,500 7,000 DATA WERE COMPILED FROM VARIOUS SOURCES. THIS NOI - permitted Townships (BLM) Dixie National Forest Feet INFORMATION MAY NOT MEET NATIONAL MAP ACCURACY STANDARDS. THIS PRODUCT WAS s 1 inch = 3,500 feet DEVELOPED THROUGH DIGITAL MEANS AND MAY BE Plan of Operations Sections Date: 10/11/2016 UPDATED WITHOUT NOTIFICATION. Soil Map Units 28, LAKEBENCH-YAMPA COMPLEX 5 TO 30 PERCENT SLOPES VERY STONY CEF, CAVE VERY GRAVELLY SANDY LOAM 7 TO 30 PERCENT SLOPES DAG, DAGFLAT-MOTOQUA COMPLEX 30 TO 70 PERCENT SLOPES EA, ERODED LAND-SHALET COMPLEX QMG, QUAZO-MOTOQUA VERY GRAVELLY SANDY LOAMS 30 TO 70 PERCENT SLOPES RI, RIVERWASH

RU, ROUGH BROKEN LAND SY, STONY COLLUVIAL LAND TAG, TACAN VERY STONY SANDY LOAM 30 TO 70 PERCENT SLOPES WAG, WELRING- TORTUGAS VERY GRAVELLY LOAMS 20 TO 70 PERCENT SLOPES

Disturbed/Reclaimed

FIGURE 3-1 SOILS IN THE Legend PROJECT AREA .! Water Sampling Locations PILOT GOLDSTRIKE INC. S" Soil Sampling Locations BULL VALLEY EXPLORATION PROJECT Project Area NO WARRANTY IS MADE BY THE BUREAU OF LAND MANAGEMENT AS TO THE ACCURACY, RELIABILITY, OR COMPLETENESS OF THESE DATA FOR INDIVIDUAL USE Property Boundary (as of September 2016) OR AGGREGATE USE WITH OTHER DATA. ORIGINAL 0 4,000 8,000 DATA WERE COMPILED FROM VARIOUS SOURCES. THIS INFORMATION MAY NOT MEET NATIONAL MAP Feet ACCURACY STANDARDS. THIS PRODUCT WAS 1 inch = 4,000 feet DEVELOPED THROUGH DIGITAL MEANS AND MAY BE s Date: 10/11/2016 UPDATED WITHOUT NOTIFICATION. FIGURE 3-2 VEGETATION Legend COMMUNITIES IN THE PROJECT AREA Project Area Pinyon/Juniper PILOT GOLDSTRIKE INC. Property Boundary (as of September 2016) Reclaimed BULL VALLEY EXPLORATION PROJECT ReGAP Vegetation Type Riparian NO WARRANTY IS MADE BY THE BUREAU OF LAND MANAGEMENT AS TO THE ACCURACY, RELIABILITY, OR Blackbrush COMPLETENESS OF THESE DATA FOR INDIVIDUAL USE Serviceberry OR AGGREGATE USE WITH OTHER DATA. ORIGINAL 0 4,000 8,000 DATA WERE COMPILED FROM VARIOUS SOURCES. THIS Dixie Liveoak INFORMATION MAY NOT MEET NATIONAL MAP Feet ACCURACY STANDARDS. THIS PRODUCT WAS 1 inch = 4,000 feet DEVELOPED THROUGH DIGITAL MEANS AND MAY BE Mountainbrush s Date: 10/11/2016 UPDATED WITHOUT NOTIFICATION. FIGURE 3-3 NEVADA WILLOW HERB Legend HABITAT IN THE PROJECT AREA Property Boundary (as of September 2016) PILOT GOLDSTRIKE INC. Nevada Willowherb Habitat (204 acres) BULL VALLEY EXPLORATION PROJECT Project Area NO WARRANTY IS MADE BY THE BUREAU OF LAND MANAGEMENT AS TO THE ACCURACY, RELIABILITY, OR COMPLETENESS OF THESE DATA FOR INDIVIDUAL USE OR AGGREGATE USE WITH OTHER DATA. ORIGINAL 0 4,000 8,000 DATA WERE COMPILED FROM VARIOUS SOURCES. THIS INFORMATION MAY NOT MEET NATIONAL MAP Feet ACCURACY STANDARDS. THIS PRODUCT WAS 1 inch = 4,000 feet DEVELOPED THROUGH DIGITAL MEANS AND MAY BE s Date: 10/11/2016 UPDATED WITHOUT NOTIFICATION. 150100100106 East Fork Beaver Dam Wash

150100100108 Bentley Wash-Beaver Dam Wash

150100080802 Tobin Wash-Santa Clara River

150100100107 Jackson Wash

Copyright:© 2013 National Geographic Society, i-cubed

FIGURE 5-1 CIA BOUNDARIES Legend PILOT GOLDSTRIKE INC. Property Boundary (as of September 2016) BULL VALLEY EXPLORATION PROJECT Project Area HUC-12 Watersheds NO WARRANTY IS MADE BY THE BUREAU OF LAND MANAGEMENT AS TO THE ACCURACY, RELIABILITY, OR COMPLETENESS OF THESE DATA FOR INDIVIDUAL USE OR AGGREGATE USE WITH OTHER DATA. ORIGINAL 0 2.5 5 DATA WERE COMPILED FROM VARIOUS SOURCES. THIS INFORMATION MAY NOT MEET NATIONAL MAP Miles ACCURACY STANDARDS. THIS PRODUCT WAS s 1 inch = 2.5 miles DEVELOPED THROUGH DIGITAL MEANS AND MAY BE Date: 5/2/2017 UPDATED WITHOUT NOTIFICATION.

APPENDIX A

INTERDISCIPLINARY TEAM CHECKLIST

Project Title: Bull Valley Exploration Project, Goldstrike District

NEPA Log Number: DOI-BLM-UT-C030-2016-0049-EA

File/Serial Number: UTU-91579 (DOGM Permit No. E/053/0069)

Project Leader: Rody Cox

Projection Description: A complete Plan of Operations (Plan) for exploratory drilling in the Goldstrike Mining District was submitted to the St. George Field Office on April 19, 2016, by Cadillac South Explorations Inc. (Cadillac).

This Plan is submitted in accordance with BLM Surface Management Regulations 43 CFR 3809, as amended, and Utah reclamation regulations at Utah Administrative Code (UAC) Title R647-2 and Utah Code Section 40-8. Cadillac currently is exploring the project area under BLM Notice of Intent (NOI) (UTU-91149) and DOGM NOI (E/053/0065). The most recent amended NOI was approved on February 16, 2016 (BLM) and February 23, 2016 (DOGM). The authorized disturbance is currently 1.70 acres on land administered by the BLM, and 4.02 acres of private land, for a total of 5.72 acres.

The mineral exploration activities covered in this Plan consist of exploration drill pad and sump construction, drilling, road construction and the maintenance of pre-1981 roads. The total acreage proposed for disturbance under this plan is 65.0 on BLM, 0.50 on State and 11.50 on Private for a total of 77.0 acres.

Project personnel would access the Project Area in four-wheel drive vehicles. One or more truck- mounted, track-mounted, or articulated buggy-mounted reverse circulation or core drill rigs would be used for drilling in the project area. Generally, a Cat D7 or D8H bulldozer or equivalent would be used to construct the roads and drill sites where needed. Roads and drill sites would be reclaimed using a bulldozer and/or a Cat 325 L or Cat 350 front-end excavator or equivalent. A complete list of the proposed equipment, exploration activities, reclamation plan and Best Management Practices is included in the Plan along with maps of the proposed drill sites and roads.

Maps: A project location map is attached at the end of document. Determination of Staff:

NP = not present in the area impacted by the proposed or alternative actions NI = present, but not affected to a degree that detailed analysis is required PI = present with potential for relevant impact that need to be analyzed in detail in the EA NC = (DNAs only) actions and impacts not changed from those disclosed in the existing NEPA documents cited in Section D of the DNA form. The Rationale column may include NI and NP discussions.

Resources and Issues Considered (Includes Supplemental Authorities Appendix 1 H-1790-1)

Determi- Resource Rationale for Determination* Signature Date nation Dust emissions levels have the potential to increase during operations, however if BMP’s NI Air Quality D. Corry 5/16/16 described in the POO are followed the impacts to Air Quality would be minimal. Greenhouse Gas The proposed action is not expected to increase NI D. Corry 5/16/16 Emissions** Greenhouse Gas Emissions. Wastes If BMP’s identified in the POO are followed the NI (hazardous or impacts from any hazardous waste spills would D. Corry 5/16/16 solid) be minimal. During operations and following until revegetation occurs it is possible that some Water sediment could reach the East Fork of the Beaver Resources/Quality PI Dam Wash. The BMP’s identified in the POO D. Corry 5/16/16 (drinking/surface/ will likely lessen the impact however due to the ground) potential impact this resource should be addressed in the EA. There are three proposed drill sites that are entirely within the Beaver Dam Wash ACEC and another ten sites that are within 200 meters of the ACEC boundary. Surface disturbance for these sites should be kept to the minimum. If possible, cross-country travel should be used in lieu of road construction.

The West Fork of the Beaver Dam Wash maintains good water quality throughout its upper reaches where it flows through granitic bedrock. The stream supports both warm and Areas of Critical cold water fisheries, maintains a quality riparian PI Environmental D. Kiel 4/26/16 system, and constitutes potential habitat for the Concern Virgin spinedace and the endangered Southwestern willow flycatcher. Besides providing water for agricultural use near the community of Motoqua, it feeds groundwater aquifers being considered for potential well-field development to provide culinary water for St. George and neighboring communities. The ACEC is managed to preserve watershed integrity and water quality and to maintain or improve riparian resources and potential habitats for the Virgin spinedace and Southwestern Willow flycatcher. A Class III cultural resource inventory will need Cultural PI to be completed and BLM will need to consult L. Hunsaker 4/25/16 Resources with the USHPO regarding effects. Determi- Resource Rationale for Determination* Signature Date nation The proposed action is not unlikely to limit access to, or interfere with ceremonial use of Native American sacred sites; nor, will it adversely impact the NI Religious L. Hunsaker 4/25/16 integrity of such known sites. However, the BLM Concerns will consult with Tribes regarding the undertaking. There are two recorded paleo sites within vicinity of the project boundary. One is within the overall project area but within a small exclusion and located on private property. The second site is .23 miles SE of the nearest corner. Both sites are listed as micro fossil localities and are in one of the predominate geologic layers where the drilling will occure. There are no direct impacts to either of sites based on the proposed drilling sites, but as they PI Paleontology K. Voyles 5/12/16 are in the same geologic unite it is reasonable that other sites will exist. All of the limestone units and most of the sandstone units within the project area conatin marine and shallow marine fossils. Each drill site should be inventoried for paleontolocical resources. Fossil types need to be listed according to each geologic unit. Any significant discoveries will be reported to BLM immediately. This project covers a very large and potentially significant karst terrain. Karst terrain can consist of caves, sink holes, blowholes, crevices, vugs, swallets and/or sinking streams. Any of these features can lead into a cave system that may contain unique cave adapted orginisms or drain surface water directly into the water table or aquifer. The geologic setting of the project site is conducive to caves and karst. The project area has not been inventoried for caves or karst PI Cave and Karst features to date. K. Voyles 5/16/16

The nearest known cave is only .59 miles from the Plan Boundary and 1.1 miles from the Project Boundary. However, the continuation of these karst bearing geologic units to the south contain 119 more caves within 4 to 20 miles from the project site. Many of these caves have been listed as Significant under the Federal Cave Resource Protection Act (FCRPA) 16 USC Sec. 4301 Title 16 Chapter 63 Determi- Resource Rationale for Determination* Signature Date nation It is highly likely that there are caves in the limestone units inside the project boundary.

The plan of operation states a total of 65 acres will be disturbed for the entirety of the project. The entire 65 acres will be within the potential karst terrain. Certain measures need to be taken or implemented to conserve any cave or karst feature: • All bit drops, of any depth, while drilling will be recorded and reported to the BLM immediately.

• All ponds need to be lined with clay or plastic to ensure there is no leakage, as outlined in the plan of operations. Drill sludge can easily run off into a small karst feature and into a larger cave system.

• Any karst feature that is discovered, whether it be a cave, sinkhole, blow hole, crevice, sinking stream or vug with or without a natural entrance will be recorded and reported to the BLM immediately.

• Cross country travel routes will be inspected for karst features prior to travel and avoided and reported if encountered.

The BMPs in the POO will help to mitigate potential negative effects to cave and karst terrain, but it is advised that the POO be amended or stipulated to incorporate specific cave and karst resource protection measures. Continued exploration and drilling would benefit geology and mineral resources by providing additional information increasing the Geology / Mineral understanding of those resources. The project NI Resources / R. Cox 5/16/16 area is identified as being prospectively valuable Energy Production for oil and gas. A records search in LR2000 shows there are no authorized or pending leases for oil and gas or other leasable minerals. According to the EPA Region VIII, State of Environmental NP Utah, Environmental Justice Map, the region has D. Kiel 4/25/16 Justice been categorized as a minority population area of Determi- Resource Rationale for Determination* Signature Date nation 10-20% and a poverty population area of 10- 20%. 5-10% of the population speaks English “Less than Well”. This data shows that low income and high minority populations are generally located in the St. George/Santa Clara/Washington areas in locations not adjacent to BLM managed lands. (see http://epamap14.epa.gov/ejmap/entry.html, 11/29/12).

However, it is likely that a low income, minority population is also present in the housing area on the east side of the Shivwits Paiute Reservation, and a low income population exists in the Hildale/Colorado City area. These populations are not distinct on census data due to having been lumped in with higher income low-minority areas in Ivins, Apple Valley, and Springdale.

No minority or economically disadvantaged communities or populations are present which could be affected by the proposed action or alternatives. The project lists five active drill crews working concurrently. There are three persons per crew as well as a project manager and geologist. With some possible support staff, it is anticipated that there would be approximately 20-25 individuals in the work area at any given time. It is likely that the vehicles and machinery will require maintenance/repairs and that work will likely be performed in St. George, which is the closest PI Socio-Economics D. Kiel 4/25/16 population center with the necessary tools and equipment. It is also likely that St. George will be the supply point for the living and working needs of the drill crews. Despite the small size of the operation, the economic impact could be significant to some local businesses, particularly those working to support and supply the operation. However, the overall impact to the local economy will likely be small to negligible. Farmlands (Prime No prime or Unique Farmlands are found in the NP D. Corry 5/16/16 or Unique) project area. Determi- Resource Rationale for Determination* Signature Date nation Some soil will likely be lost from the area during operations and following until re-vegetation is reestablished. The BMP’s identified in the POO will help reduce this impact. However, due to PI Soils D. Corry 5/16/16 the potential impact this resource should be analyzed further in the EA. For soil identification and erosion potential refer to the Washington County Soil Survey. No Floodplains are project to be impact by this NP Floodplains D. Corry 5/16/16 proposed action. During operations it is possible that some sediment could reach the East Fork of the Beaver Wetlands/Riparian Dam Wash, however if the BMP’s identified in NI D. Corry 5/16/16 Zones the POO are followed it is likely that any impact to the East Fork of the Beaver Dam Wash and its associated riparian areas would be minimal. Fish and Wildlife Several BLM Sensitive animals occur in the Excluding USFW B. Douglas PI project site. These BLM Sensitive animals should 5/23/16 Designated D. Corry be addressed in the EA. Species Migratory birds may be impacted. Greatest impact would be during their nesting period PI Migratory Birds B. Douglas 5/23/16 (March to August). These migratory birds should be addressed in the EA. Threatened, Endangered or No threatened or endangered plants are known to NP B. Douglas 5/23/16 Candidate Plant occur in the project site. Species Threatened, Endangered or No threatened or endangered animals are known NP B. Douglas 5/23/16 Candidate Animal to occur in the project site. Species Vegetation One BLM Sensistve plant may occur in the Excluding USFW B. Douglas or PI project site. Nevada willowherb, should be 5/23/16 Designated D. Corry surveyed for, and addressed in the EA. Species The majority of the area has already been burned during a wildland fire event, however it it Woodland / NI recommend that any new road construction that D. Corry 5/16/16 Forestry occurs avoid if possible unburned Pinyon and Juniper trees. Fuels/Fire If the BMP’s identified in the POO area followed NI D. Corry 5/16/16 Management the chance of uncontrolled fires are minimal. Determi- Resource Rationale for Determination* Signature Date nation As long as ‘Cadillac South Explorations Inc. Bull Valley Exploration Project Plan of Operations’ Invasive are followed as outlined through noxious weed Species/Noxious NI surveys, consultation, and development and R. Reese 5/4/2016 Weeds (EO implementation of a treatment plan; no lasting 13112) adverse impacts are expected to occur as a result of the proposed action. There are no authorized rights-of-way or any other land use authorizations within the project NP Lands/Access area that could be impacted by the proposal. This T. Burke 4/27/2016 area is not being considered in any land tenure adjustments. The proposed action is not expected to adversely affect Livestock Grazing. The approved NI Livestock Grazing R. Reese 5/4/16 reclamation seed mix is made up of species preferred by livestock as well as wildlife. The proposed action is not likely to adversely Rangeland Health NI affect Rangeland Health Standards. As long as the R. Reese 5/4/16 Standards Plan of operations reclamation plan is carried out. There are three recreation activities that could be impacted by the proposed action. Conversely, these activities could also have impacts on drilling operations. Those activities are: hunting, off-road vehicle recreation, and wilderness therapy.

Hunting: If drilling operations take place in the fall, the annual deer hunt would likely absorb the largest impacts. From two weeks prior, to the end of the rifle hunting season, many hunters camp and hunt within the project area. Hunters could be displaced by drilling operations and drilling operations could in turn, be impacted by PI Recreation the proximity of a large number of hunters and D. Kiel 4/25/16 their associated ATV’s, UTV’s, and full-size vehicles. In addition, there are 15 commercial hunting guides who are authorized to operate in the Goldstrike area and their operations could be impacted by the proposed action. If deer remain in the area during hunting season, safety could become a concern with so many firearms in the immediate vicinity of the drill rigs. If operations are to be conducted during hunting season, an outreach campaign should be part of the strategy. The State of Utah DNR and the BLM SGFO could assist with efforts to educate hunters on the drilling operation.

Determi- Resource Rationale for Determination* Signature Date nation Off-road vehicles: This is a popular area with ATV/UTV enthusiasts, although the somewhat remote location keeps the use numbers relatively low. Off-road recreational users could be displaced during drilling operations. This is also true for commercial and organized group activities. There are five companies that are authorized to conduct ATV/UTV tours in the area, and the annual Tri-State ATV Jamboree passes directly through the Goldstrike area as part of their annual event. The BLM SGFO would need to know the operational dates in advance so all of the commercial and organized groups could be alerted.

Wilderness Therapy: There are two companies the BLM SGFO permits to operate wilderness therapy programs in the Goldstrike area. These programs typically focus on at-risk/troubled youth and young adults. They prefer to operate in areas where visitor traffic is low and contact with outside groups or individuals is discouraged. Because of strict state and federal regulations , their operations are quite expensive. These groups would be displaced by the proposed action. In order for these groups to move to other locations, the BLM SGFO would need significant lead time on when drilling operations would take place. The proposed action is entirely within Visual Resource Management Class III.

The management objectives for this VRM Class are:

Class III Objective: To partially retain the existing character of the landscape:

PI Visual Resources D. Kiel 4/25/16 1) The level of change to the landscape can be moderate. 2) Management activities may attract attention, but should not dominate the view of the casual observer. 3) Any changes should repeat the basic elements found in the natural landscape – form, line, color, and texture.

Determi- Resource Rationale for Determination* Signature Date nation Drilling operations for an exploratory operation like this one would likely meet VRM Class III objectives. In fact, the operation would be a very close fit for numbers 1) and 2), matching that criteria almost exactly. However, given the number of drill holes and miles of new and re- opened roads, the cumulative impacts to the visual landscape may be worth analyzing further. In anticipation of this, we ran a preliminary viewshed analysis from the main roads throught the area to see how many drill sites and miles of new/re-opened roads on public lands would be visible. Here are the numbers:

Proposed Roads Visible Miles = 15.6 Non-visible Miles = 8

Drill Sites Visible Sites = 176 Non-visible Sites = 64

I believe these numbers are higher than what would actually be visible from the main transporation routes in the area. The analysis was done using a 10 meter digital elevation model (DEM) and did not factor in vegetative cover. A more detailed DEM (5m) and a theorectical height for vegetative cover has the potential to eliminate over half of the road miles and drill sites currently listed as “visible.”

While there is a PI listed for this resource, a more detailed and thoughtful analysis has the potential to eliminate this resource from further consideration. NLCS National There are no National Conservation Areas within NP Conservation D. Kiel 4/25/16 or affected by the proposed action Areas National Historic The proposed action is not in the vicinity of, and NP Trails (Old D. Kiel 4/25/16 would not impact, the Old Spanish Trail. Spanish Trail) National Recreational The proposed action is not in the vicinity of the NP K. Voyles 4/25/16 Trails (Gooseberry Gooseberry Mesa National Recreation Trail Mesa) Determi- Resource Rationale for Determination* Signature Date nation There are no eligible, suitable, or designated Wild and Scenic NP Wild and Scenic River segments affected by the K. Voyles 4/25/16 Rivers proposed action The proposed action is not within designated wilderness or wilderness study areas. There are NP Wilderness/WSA 13 proposed drill sites within 0.7 miles of the K. Voyles 4/25/16 Docs Pass Wilderness, but the wilderness area would not be impacted. There are a total of 240 proposed drill sites located on public lands. Of those 238 sites, 91 are within areas that have wilderness characteristics. This entire area was inventoried in 2011, and those inventories have been included with this checklist. The 91 proposed drill sites are located within three separate inventory units:

Square Top Mountain – UT-040-048A 33 proposed drill sites

Square Top Mountain – UT-040-048B 56 proposed drill sites

Docs Pass – UT-040-124A 2 proposed drill sites

Each drill site would measure approximately 70’x30’depending on terrain. Access to each drill Lands with site is also terrain dependent. Wherever possible, PI Wilderness D. Kiel 4/25/16 cross-country travel is preferable to road Characteristics construction. Vegetation that is crushed flat can easily rebound within a year or two, but reclaimed roads take significantly longer. Given the terrain in the area, it is obvious that some roads will need to be constructed. The average road width in the POD is 12’ for constructed roads and a 6’ wide disturbance for cross-country travel. Using the numbers from the POD, the following calculations show the total surface disturbance on public lands within the three wilderness characteristics inventory units:

Miles of proposed roads: 23.5 x 12’ width = 45.6 acres

Drill Pads: 91 sites. Each site is 70’ x 30’ = 2,100 sq ft 91 x 2,100 sq ft = 11.46 acres

Determi- Resource Rationale for Determination* Signature Date nation Total Surface Disturbance within Lands with Wilderness Characteristics = 57.06 acres

Wilderness characteristics on the disturbed acres will be lost for several years regardless of reclamation success. However, based on the appearance of other reclaimed roads and drill sites in the area, it is anticipated that wilderness characteristics would be re-established within ten years.

During operations, the surface disturbance will not be highly visible as it will be spread out over the entire project area which totals16,090 acres. This puts the total surface disturbance at less than one half of one percent of the total project area.

Final Review: Reviewer Title Signature Date Comments

Environmental Coordinator

Authorized Officer