Environmental Assessment Record

United States Department of the Interior Bureau of Land Management Royal Gorge Field Office 3028 E. Main Street Cañon City, CO 81212

Environmental Assessment

Parkdale Area Mineral Materials Sampling

DOI-BLM-CO-F020-2016-0083 EA

December, 2017

TABLE OF CONTENTS

CHAPTER 1 - INTRODUCTION ...... 1 1.1 IDENTIFYING INFORMATION ...... 1 1.2 INTRODUCTION AND BACKGROUND ...... 1 1.3 PURPOSE AND NEED ...... 2 1.4 DECISION TO BE MADE ...... 2 1.5 PLAN CONFORMANCE REVIEW ...... 3 1.5.1 Plan Conformance Review ...... 3 1.5.2 Standards for Public Land Health ...... 3 1.5.3 RMP Preparation ...... 4 1.6 SCOPING, PUBLIC INVOLVEMENT AND ISSUES ...... 4 1.6.1 Scoping ...... 4 1.6.2 Issues Identified ...... 5 CHAPTER 2 - PROPOSED ACTION AND ALTERNATIVES ...... 6 2.1 INTRODUCTION ...... 6 2.2 ALTERNATIVES ANALYZED IN DETAIL ...... 6 2.2.1 PROPOSED ACTION – ACCESS BY GROUND ...... 6 2.2.2 ALTERNATIVE 1 – ACCESS BY AIR ...... 15 2.2.3 NO ACTION ALTERNATIVE ...... 18 2.3 ALTERNATIVES CONSIDERED BUT NOT ANALYZED IN DETAIL ...... 18 2.4 STANDARD STIPULATION AND DISCOVERY STATEMENTS (TERMS AND CONDITIONS) ...... 19 CHAPTER 3 - AFFECTED ENVIRONMENT AND EFFECTS ...... 19 3.1 INTRODUCTION ...... 19 3.1.1 INTERDISCIPLINARY TEAM REVIEW ...... 19 3.2 PHYSICAL RESOURCES ...... 22 3.2.1 AIR QUALITY ...... 22 3.2.2 SOILS (includes a finding on standard 1)...... 28 3.2.3 WATER (SURFACE AND GROUNDWATER, FLOODPLAINS) (includes a finding on standard 5) ...... 30 3.3 BIOLOGICAL RESOURCES ...... 33 3.3.1 INVASIVE PLANTS...... 33 3.3.2 VEGETATION (includes a finding on standard 3) ...... 33 3.3.3 WILDLIFE TERRESTRIAL (includes a finding on standard 3) ...... 34 3.3.4 MIGRATORY BIRDS ...... 41 3.4 HERITAGE RESOURCES AND HUMAN ENVIRONMENT ...... 44 3.4.1 PALEONTOLOGICAL RESOURCES ...... 44 3.4.2 VISUAL RESOURCES ...... 45 3.4.3 ENVIRONMENTAL JUSTICE ...... 46 3.5 LAND RESOURCES ...... 47 3.5.1 WILDERNESS CHARACTERISTICS ...... 47 3.6 CUMULATIVE IMPACTS SUMMARY ...... 50 3.6.1 Cumulative Impacts ...... 50 3.6.2 Reasonable and Forseeable ...... 53 CHAPTER 4 - CONSULTATION AND COORDINATION ...... 53

4.1 LIST OF PREPARERS AND PARTICIPANTS ...... 53 4.2 TRIBES, INDIVIDUALS, ORGANIZATIONS, OR AGENCIES CONSULTED 54 CHAPTER 5 – REFERENCES ...... 54 Appendix A ...... 63 6.1 BLM RESPONSES TO COMMENTS ...... 63 6.1.1 SCOPING PERIOD, 06/05/2017 – 06/20/2017...... 63 6.1.2 DRAFT EA COMMENT PERIOD, 12/13/2017 – 01/12/2018 ...... 64

CHAPTER 1 - INTRODUCTION 1.1 IDENTIFYING INFORMATION

CASEFILE/PROJECT NUMBER (optional): COC-078119

PROJECT TITLE: Parkdale Area Mineral Materials Sampling

PLANNING UNIT:

LEGAL DESCRIPTION: Sixth Principal Meridian, Fremont County, Colorado T. 18 S., R. 71 W., secs. 6 and 7.

T. 18 S., R. 72 W., secs. 1, 2, 11 and 12.

APLLICANT: Martin Marietta

1.2 INTRODUCTION AND BACKGROUND

BACKGROUND: In June 2016, BLM received an application from Martin Marietta to obtain mineral materials northwest of Canon City, CO. With this application, Martin Marietta also requested BLM approval to conduct some sampling efforts to better understand the rock formation characteristics before moving forward with any larger scale action. Therefore, BLM prepared this Environmental Assessment (EA) to analyze only the sampling of mineral materials on federally managed estate in Fremont County, Colorado.

The sampling efforts will be conducted utilizing a rotary drilling process that penetrates into the subsurface, in order to collect core samples at targeted depths below the ground surface. Core samples consist of a column of rock from the rock formation that is representative of the subsurface. These core samples are brought to the surface to be analyzed and tested. Collecting subsurface samples via this method is very common not only in the mining industry, but also in areas such as research and geotechnical testing.

If the results of the proposed sampling efforts are favorable and the applicant still proposes to move forward with mining efforts, then additional NEPA will be conducted at that time.

In order to meet future demands in Southern Colorado, and neighboring states that do not have readily accessible aggregate reserves, the applicant is focused on long term vision for maintaining uninterrupted supplies of construction aggregate and railroad ballast. Demand for these types of mineral resources is tied to population density, and the economic impacts associated with their extraction and use are generally most significant within approximately 50 miles of the extraction

site for sites served by truck transportation. However, that distance can increase to 250 or more miles for transportation utilizing rail.

The BLM parcel being considered for sampling efforts is ideal, as it is located adjacent to an existing operation on private property and is also serviced by an operational rail line.

1.3 PURPOSE AND NEED The purpose of the action is respond to a request by Martin Marietta to conduct exploratory sampling, prior to processing an application to purchase federal mineral materials, in an area located west of Canon City Colorado.

The need is based in BLMs multiple-use mission, set forth in the Federal Land Policy and Management Act of 1976, which mandates that we manage public land resources for a variety of uses. These uses include mining, and more specifically in this case, the sampling of mineral materials.

Per 30 USC Section 1602 (01/03/2012), the Congress declares that it is the continuing policy of the United States to promote an adequate and stable supply of materials necessary to maintain national security, economic well-being and industrial production with appropriate attention to a long-term balance between resource production, energy use, a healthy environment, natural resources conservation, and social needs. The Congress further declares that implementation of this policy requires that the President shall, through the Executive Office of the President, coordinate the responsible departments and agencies to, among other measures: (1) identify materials needs and assist in the pursuit of measures that would assure the availability of materials critical to commerce, the economy, and national security and (2) encourage Federal agencies to facilitate availability and development of domestic resources to meet critical materials needs.

It is BLM policy to make mineral materials available in accordance with the Mineral Materials Act, provided adequate measures are taken to protect public land resources and the environment and that damage to public health and safety is minimized (43 CFR 3601.6). Since disposal of mineral materials is discretionary on the part of BLM, no disposals will be made if it is determined by the Authorized Officer that the aggregate damage to public lands and resources would exceed the public benefits that BLM expects from the proposed disposal.

BLM will determine if the proposed project will result in no significant impacts (either because none exist or if they do exist, they can be adequately mitigated) during the EA process. Results and any mitigation developed through this environmental assessment and resulting decision document will be forwarded by BLM to CDRMS and Fremont County for inclusion into their permitting processes.

1.4 DECISION TO BE MADE The BLM will decide whether to approve the proposed “Parkdale Area Mineral Materials Sampling” effort based on the analysis contained in this EA. This EA will analyze the proposal to sample federal minerals that are adjacent to an existing, and privately owned and operated, sand and gravel operation. The subject parcel (including a 568 acre buffer area around the perimeter) consists of approximately 1,430-acres, with the proposed sample borings and temporary access routes consisting of approximately 12.5 acres of disturbance on BLM managed land and minerals and is located directly north and adjacent to a private quarry that is currently in operation northwest of Parkdale, Colorado.

The BLM may choose to: 2

1. Accept the project as proposed 2. Accept the project with modifications/mitigation 3. Accept an alternative to the proposed project, or 4. Not authorize the project at this time.

The finding associated with this EA may not constitute the final approval for the proposed action.

1.5 PLAN CONFORMANCE REVIEW

1.5.1 Plan Conformance Review The Proposed Action is subject to and has been reviewed for conformance with the following plan (43 CFR 1610.5, BLM 1617.3):

Name of Plan: Royal Gorge Resource Management Plan (RMP)

Date Approved: May 1996

Decision Number/Page: 1-40 and 6-35

Decision Language: Areas will be available for mineral materials development administered under existing regulations.

1.5.2 Standards for Public Land Health January 1997, the Colorado State Office of the BLM approved the Standards for Public Land Health and amended all RMPs in the State. Standards describe the conditions needed to sustain public land health and apply to all uses of public lands.

Standard 1: Upland soils exhibit infiltration and permeability rates that are appropriate to soil type, climate, land form, and geologic processes.

Standard 2: Riparian systems associated with both running and standing water function properly and have the ability to recover from major disturbance such as fire, severe grazing, or 100-year floods.

Standard 3: Healthy, productive plant and animal communities of native and other desirable species are maintained at viable population levels commensurate with the species and habitat’s potential.

Standard 4: Special status, threatened and endangered species (federal and state), and other plants and animals officially designated by the BLM, and their habitats are maintained or enhanced by sustaining healthy, native plant and animal communities.

Standard 5: The water quality of all water bodies, including ground water where applicable, located on or influenced by BLM lands will achieve or exceed the Water Quality Standards established by the State of Colorado.

Because standards exist for each of these five categories, a finding must be made for each of them in an environmental analysis. These findings are located in Chapter 3 of this document.

1.5.3 RMP Preparation BLM is in currently the process of preparing a new resource management plan and environmental impact statement to provide comprehensive management direction for all resources and uses within the Royal Gorge Field Office in eastern Colorado.

Although a new management plan is being prepared, BLMs decision regarding this proposal will be under the authority of the governing RMP, approved in May 1996. Under BLM policy, existing land use decisions remain in effect during the amendment and revision of RMPs unless decisions are specifically determined to violate federal law.

DOI NEPA Regulations at 43 CFR 46.10 state: During the preparation of a program of plan NEPA document, the Responsible Official may undertake any major Federal action in accordance with 40 CFR 1506.1 when that action is within the scope of, and analyzed in, an existing NEPA document supporting the current plan or program, so long as there is adequate NEPA documentations to support the individual action.

Additionally the BLM NEPA Handbook (h-1790-1 (January 30, 2008) pg. 3) states: You must not authorize any action that would limit the choice of alternatives being analyzed under the NEPA until the NEPA process is complete (40 CFR 1506.1) However, this requirement dos no apply to actions previously analyzed in a NEPA document that are proposed for implementation under an existing land use plan

In accordance with recent BLM Colorado guidance, BLM will release this NEPA document for formal public comment because it is analyzing a proposal that has potential to cause impacts to lands with wilderness characteristics that were not previously considered in an RMP analysis.

1.6 SCOPING, PUBLIC INVOLVEMENT AND ISSUES NEPA regulations (40 CFR §1500-1508) require that the BLM use a scoping process to identify potential significant issues in preparation for impact analysis. The principal goals of scoping are to allow public participation to identify issues, concerns, and potential impacts that require detailed analysis.

1.6.1 Scoping Persons/Public/Agencies Consulted: The primary mechanisms the BLM used to identify potential issues were (1) scoping by posting this project on the National ePlanning website, (2) issuing multiple press releases, (3) holding a 14-day scoping comment period, and (4) holding a 30-day comment period for the Draft EA document.

In addition to BLM’s scoping actions, the applicant has conducted extensive outreach efforts via email, phone, meetings, etc. Below is a summary of actual meetings/site visits that have been conducted to date:

Date Location Parties Involved Discussion Topics 04/27/2017 Canon City, AHRA (CPW), Martin General discussion on proposed project. Fremont County Marietta 06/28/2017 Spec Agg Quarry, Wild Sheep Foundation, Toured the quarry - discussed how what is Jefferson County Rocky Mountain Bighorn involved with operations at a typical Society, Martin Marietta hardrock quarry; potential collaboration opportunities at various sites 06/29/17 Spec Agg Quarry, The Wilderness Society, Toured the quarry - discussed how what is Jefferson County Wild Connections, Martin involved with operations at a typical Marietta hardrock quarry 07/27/17 Proposed Parkdale CPW, BLM, Martin Talked about existing conditions and current sampling area, Marietta, Wild Sheep quarry footprint. Looked at proposed Fremont County Foundation, Rocky sampling area and reclamation results from Mountain Bighorn Society 2015 drill pad and access routes.

Note that this Draft EA will also be put out for a 30-day public comment period, prior to being finalized.

1.6.2 Issues Identified The public scoping issues and comments identified through this process are summarized below. 1. Sampling and potential mining activities in this proposed area could: a. Threaten important tourist activities b. Destroy scenic beauty c. Damage trout habitat through erosion d. Affect Table Mountain, which is a proposed Wilderness designation by Central Colorado Wilderness Coalition that has been included in multiple legislative efforts since 2003. 2. As truck traffic from the existing quarry creates a danger on the road, additional heavy machinery traffic could compound the problem. 3. Commenters request that BLM: a. Thoroughly analyze potential impacts of proposed actions to the local bighorn sheep population. b. Coordinate with CPW, along with the applicant, to identify opportunities for bighorn sheep habitat enhancement on the proposed project site as well as off-site locations. c. Consider alternate locations for mineral materials sampling and sales, in conjunction with the applicant. d. Defer the project while the Eastern Colorado RMP revision is ongoing. e. Prepare an EIS, if project is not deferred. f. Utilize the full mitigation hierarchy in evaluating the proposed action. 4. Relationship with and potential conflicts with Lands with Wilderness Characteristics (LWC inventory. 5. Potential impacts with Visual Resource Management (VRM)

These issues have been evaluated and addressed within the EA, if BLM determined they helped to inform the development of the alternatives or were considered in addressing potentially significant effects.

CHAPTER 2 - PROPOSED ACTION AND ALTERNATIVES 2.1 INTRODUCTION Martin Marietta submitted a mineral materials application to BLM in June 2016 that includes a request to conduct exploration efforts on the BLM managed area to the north of their privately operated Parkdale aggregate operation (Figure 2-1). The company proposes to drill nine boreholes, which is now anticipated to take place in 2018 and last approximately eight to ten weeks.

Nine boreholes have been proposed by the applicant, in order to adequately cover the area that is to be analyzed. Rock formations are not consistently homogenous, so in order to obtain a high confidence in the formation qualities, it is necessary to look at different locations, both vertically and laterally. The sought after formation in this area is a pinkish-gray rock mapped as Precambrian Granodiorite that can be massive or foliated. Typically, exploration drilling programs incorporate a somewhat phased approach. Drilling will be initiated according to an initial plan that is formulated based on topography/accessibility, know geological structure constraints and ensuring a diverse coverage to obtain a consistent and adequate amount of data. However, if the downhole data does not meet expectations, then additional proposed boreholes in the area may not be drilled or could be re-located.

All proposed disturbance will be kept to that necessary for the exploration effort. Proposed borings and access routes within the BLM area of interest are shown in Figure 2-2. There is a buffer area noted on the map, which demonstrates an approximate 568 acre area within the application that is not proposed for any disturbance. BLM property will be accessed from the northern portion of the applicant’s adjoining private property on the south.

Results from this proposed exploration will help to inform the viability of moving forward in the future with the application for mineral materials that will involve a mining and reclamation plan.

2.2 ALTERNATIVES ANALYZED IN DETAIL

2.2.1 PROPOSED ACTION – ACCESS BY GROUND Exploration activities will disturb approximately 12.5 acres, which comprises approximately 29,300 feet of average 10-foot wide exploration access routes and nine approximate 20- foot by 50-foot drill pads. Disturbance area calculations reflect three general grading scenarios being anticipated for route construction. Though the average route width is 10 feet, the average anticipated disturbance width for the routes is approximately 18 feet due to grading on side slopes.

Drill pads would only be constructed in areas that necessitate leveling for the drill rig to safely access. It is anticipated that the average disturbance area per drill pad will be approximately 1,250 square feet. One drill pad location was deleted after submission of the original application due to access issues. Reclamation of pads and routes will be implanted immediately following the drilling activities and, consisting of re-contouring the surface, seeding, fertilizer application and mulching with weed-free straw.

1. Prior to exploration implementation, the applicant will: a. Coordinate with the Colorado Division of Reclamation, Mining and Safety regarding NOI requirements, as applicable. 6

2. Exploration operations: a. Access i. A dozer will be used to pioneer in temporary routes, as necessary, for access to drill sites. ii. The temporary routes and drilling pad locations shown on Figure 2-2 are approximate and will be adjusted, as needed, during the actual construction. iii. To the extent practical, routes will be located so as to take advantage of existing natural travel paths. iv. Grading and disturbance on these routes will be limited to the minimum necessary to allow vehicle passage, which in many areas will only require the relocation of surface objects such as boulders or downed logs. Thus, while some areas will require cut and fill, most areas will require only minor disturbance, and some areas will not be disturbed beyond that caused by the actual passage of wheeled or tracked equipment. v. The 18-foot average route disturbance width is based on a range of 6-ft to 30- ft widths, depending on the access location, as well as observed conditions and the operator’s experience operating on the adjacent Parkdale Quarry property. Figure 2-2 shows the anticipated approximate distribution of disturbance scenarios for the various route sections. Figure 2-3 includes three cross sections that illustrate the three general disturbance scenarios anticipated during route construction. vi. The ATV-mounted drill rig used to access sites will require the disturbance of an estimated 0.2 acres divided between the nine drill sites, plus the approximately 29,300 linear feet of temporary routes. b. Boreholes i. Drill approximately nine boreholes to an approximate depth of 300 feet each. Water will be used during the process. ii. Exploratory drilling will be performed using an all-terrain drill rig and NQ or HQ3 coring equipment. iii. The drilling and support equipment used to excavate the borings will be high- clearance all-wheel drive or track-mounted equipment. iv. The rubber tire ATV drill rig requires an approximate 20-foot by 50-foot working area. v. An advantage of using something like a rubber tire ATV-mounted drill rig is that it allows for the collection of the larger diameter core, which is preferred because it makes it easier to observe general rock properties, including fracturing and alteration, and it provides more material for testing of rock physical properties.

Figure 2-1 Location of Proposed Exploration

Figure 2-2 Proposed Exploration Location Details

Figure 2-3 Cross Sections Illustrating Three General Disturbance Scenarios

c. General i. Locally store any cuttings generated from borehole installation for use in borehole abandonment and pad reclamation. ii. Manage fugitive dust generation through similar methods used at the operating mine site on private land, primarily utilizing water application. iii. Utilize Stormwater management controls. iv. Since the project involves oil or fuel usage, transfer or storage, an adequate spill kit and shovels are required to be onsite during project implementation. The project proponent will be responsible for adhering to all applicable local, State and Federal regulations in the event of a spill, which includes following the proper notification procedures in BLM’s Spill Contingency Plan. v. Monitor temporary routes and pads to ensure minimal erosion. vi. Based on drilling performed in the same geologic unit and to similar depths on the adjacent Parkdale Quarry site, it is not anticipated that significant groundwater will be encountered during drilling operations. The approximate distance to the nearest stream from the proposed boring locations ranges from 800’ to 6700’. vii. The ATV-supported drilling, or ground access, will require an estimated 30 working days or 6 weeks to complete.

3. Reclamation: Reclamation of ATV-accessed drill pads and routes will be started as soon as drilling on a location is complete and use of the access is no longer required, and can be carried out while drilling is occurring on another drill site. Reclamation of rubber tire ATV rig drill pads generally consists of replacing top soil on an approximate 20-foot by 50-foot area immediately around the bore hole, raking out tire tracks and the areas where the leveling pads contact the ground, reseeding and application of mulch to the disturbed area, and redistribution of rocks and natural debris across the area, if such was removed.

This will be accomplished by regrading and/or backfilling routes and cuts to blend with the surrounding topography, as applicable. Areas of bare rock prior to route or pad construction will generally remain as bare rock and reclamation will be limited to that practical for minimizing obvious disturbance. Grading for temporary route and pad construction in areas 10

where soil is present will not generally extend deeper than the topsoil layer, and topsoil will not be removed from the immediate area of the access routes and drill pads, making it available for reclamation of disturbed areas and importation of additional reclamation fill or topsoil will not be necessary. a. Boreholes will be plugged and sealed in accordance with CDRMS Rule 5.4 in a timely manner. b. Topsoil Replacement and Regrading i. Heavily compacted surfaces will be ripped to depths varying from 6 to 12 inches, depending upon the degree of compaction prior to the replacement of topsoil. ii. Based on the adjacent Parkdale Quarry granite mining area, the existing topsoil depth in the area generally ranges from 0 inches to 18 inches. Replacement topsoil depths comparable to those prior to access route and pad construction, or an average of 9 inches evenly placed, will be used. iii. Prior to reseeding of disturbed areas, topsoil will be placed to achieve a generally uniform thickness; minimize compaction and erosion; and preserve biological, physical, and chemical properties. iv. Where practical, soil will be applied using a skip loader to minimize grading requirements and compaction from multiple equipment passes over the area being reclaimed. v. Final grading will generally be completed parallel to the topographic contour of the area, where safety conditions permit, to minimize erosion and maximize site stability. Ideally, soil will be applied on areas to be seeded less than 30 days prior to seeding. c. Fertilizer Application i. Prior to reseeding of disturbed areas, the applicant will contract with a laboratory proficient in the analysis of soils for agricultural purposes. Two composite samples from 0 to 6-inch and 6 to 20-inch depths will be taken from areas disturbed by the drilling activities in the exploration area. Samples will be taken with either a tile spade or soil auger free of foreign substances or rust. No galvanized tools will be used. About one quart of material will be collected for each composite sample. The sample locations will be noted on a project map. The laboratory will be briefed on the following items for each sample or appropriate set of samples: 1. Plant species to be established; 2. Type of seedbed preparation technique; 3. Type of mulching practices; 4. Approximate slope; 5. Problems or conditions; and 6. Past and future land use.

ii. All samples will be placed in clean polyethylene bags at the time of collection, sealed and delivered to the laboratory as soon as possible. When samples cannot be delivered within 24 hours of collection, they will be air-dried in a "dust free" environment for about 48 hours or as recommended by the laboratory. Samples will be analyzed for: 1. pH; 2. Potassium (ppm);

3. Texture; 4. Electrical conductivity (mmhos/cm); 5. Percent organic matter; 6. Lime estimate; 7. NH4-N and N03-N (ppm); 8. Sodium adsorption ratio; and if necessary 9. Phosphorus (ppm)

iii. The fertilizer application concentration will be based on recommendations from the laboratory sample analyses. Fertilizer will be broadcast over the seedbed using hand-operated "cyclone-type" seeders or rotary broadcast equipment attached to construction or revegetation machinery. Fertilizer broadcast equipment will be equipped with metering devices. iv. Fertilizer application will take place prior to final seedbed preparation treatment to ensure the incorporation of fertilizer into the seedbed. Fertilizer broadcasting operations will not be conducted when wind velocities would interfere with even fertilizer distribution. d. Seeding i. Within five days after the application of fertilizer, but prior to seeding, the topsoil will be prepared for seeding by utilizing a disk, harrow or chisel plow to roughen the surface, depending upon site conditions and availability. The topsoil surface will then be left in a roughened condition to inhibit erosion and provide a receptive surface for subsequent reclamation procedures. ii. Disturbed areas will be revegetated with the seed mix approved for the adjacent private Parkdale Quarry mining benches, which was previously agreed to by the Colorado State Division of Wildlife and Division of Reclamation, Mining and Safety (CDRMS). The Parkdale Quarry seed mix is detailed in Table 2-1. iii. Seed will be obtained in standard containers with seed name; lot number; net weight; and percentages of purity, germination, hard seed, and maximum weed seed content clearly marked for each seed type. Seed supplies will not contain the seeds of any state recognized noxious weed species. A certificate stating that each seed lot has been tested by a laboratory with respect to the above requirements will be delivered with the seed. Only certified seed of named varieties will be used where varieties are specified and can be obtained. Sources for "common" seed will be selected with comparable climatic and elevation characteristics similar to the project's climate and elevation. Legume seed will be inoculated with the correct rhizobium prior to shipping. All legume seed will be planted prior to the expiration date on the inoculum tag or re-inoculated within 24 hours prior to planting. iv. Seeds will be applied at a seeding rate of approximately 20 pounds of pure live seed (PLS) per acre which equates to approximately 210 seeds per square foot. Seed will be broadcast over the seedbed using hand-operated "cyclone-type" seeders or rotary broadcast equipment attached to construction or revegetation machinery.

Table 2-1 Parkdale Quarry Seed Mix

e. Mulching i. Mulching will be conducted immediately following seeding operations. ii. Straw mulch will be spread evenly by hand or mechanical blower. When mulching slopes, application will be initiated at the top of the slope, working down slope, where possible. Mulch will not be spread when wind velocities would prohibit even material distribution. iii. Straw Mulch will not be musty, moldy, caked, or decayed and will be free of noxious weeds or noxious weed seeds. It will be delivered in an air-dry condition. iv. The majority of stems will be 10 to 12 inches long or longer prior to application if the mulch is to be anchored by crimping. v. Approximately two tons of mulch per acre will be applied to all areas to be mulched.

The measures presented in the Reclamation Plan section above will be used for long-term stabilization of areas disturbed by sampling/exploration activities unless the Reclamation Plan above is superseded by an approved Mining and Reclamation Plan. If this occurs, it is anticipated that the temporary exploration access routes and drill pads not already reclaimed 13

will be covered by and reclaimed as part of the subsequent mining operation. If there is no subsequent mining operation, then the reclamation efforts will be monitored to ensure stability and adequate vegetation establishment.

Figure 2-4 Street view looking north at area of proposed borings

Figure 2-5 Ground view looking north at area of proposed borings

2.2.2 ALTERNATIVE 1 – ACCESS BY AIR The drilling equipment used for helicopter access is different from that used for temporary route access on the ground. Exploration activities will disturb approximately 1-2 acres, which comprises drill pads and helicopter landing/staging areas. One drill pad location was deleted after submission of the original application due to access issues. Reclamation will be implemented immediately following the drilling activities and will consist of re-contouring the surface, seeding, fertilizer application and mulching with weed-free straw as described in the Proposed Action.

A. Prior to exploration implementation, the applicant will: a. Coordinate with the Colorado Division of Reclamation, Mining and Safety regarding NOI requirements, as applicable.

b. Coordinate with Colorado Water Quality Division regarding stormwater management requirements, as applicable. c. Coordinate with Colorado Air Pollution Control Division regarding air permitting, as applicable. d. Coordinate with Fremont County regarding Conditional Use Permit requirements, as applicable. e. Obtain a utility locate prior to ground disturbance. f. Stake the boreholes on the ground g. Flights between the Parkdale Quarry and the Fremont County airport will be governed by standard Federal Aviation Administration (FAA) rules and regulations and will be coordinated with the airport. The helicopter operator will need to post an FAA Notice to Airmen to advise air traffic in the area of the ongoing operation.

B. Exploration operations: a. Access i. The helicopter proposed for the helicopter drilling is a Bell UH-1H/703 “Super Huey” capable of lifting over 2,000 pounds at the elevations and temperatures proposed for the drilling. ii. The helicopter rig requires four trips to fly in the components for the drill rig, two trips to fly in the support equipment and supplies, one trip to fly in a skid- steer for drill pad construction and reclamation, one trip to string water line, and two trips per day for the crew. iii. The helicopter used for the exploration would be based out of the Fremont County airport for the duration of the drilling project. iv. The helicopter would fly to the Parkdale Quarry at the beginning of each flight day. The personnel and equipment required for the day’s activities would be located at the Parkdale Quarry or a drill site on the adjacent BLM land. v. Suitable takeoff/landing areas located adjacent to the nine proposed boring locations, as shown on Figure 2-2. If a suitable takeoff/landing area was not available close to a drilling location, one would be cleared using hand tools packed into the site. vi. While equipment could be brought into drill sites by sling under the helicopter, the helicopter will need to be able to land at each site to drop off and pick up the drilling personnel. vii. Each drilling location will require an estimated nine trips to bring equipment to the drill site, two trips per day to drop off and pick up the drilling crew, and an estimated ten trips to remove equipment and core samples from each drill site. The anticipated maximum number of trips in a day is 12 and the minimum is two, with an estimated total of 225 trips through the project. viii. Equipment and personnel will not need to be flown over potentially populated areas during flight operations. ix. The drilling pad locations shown on Figure 2-2 are approximate and will be adjusted, as needed, during project implementation. x. The total anticipated area of disturbance for the helicopter accessed drilling is approximately 1.2 acres, divided between the nine drill sites, and consists only of drill pads and landing/staging areas. b. Boreholes i. Drill approximately nine boreholes to an approximate depth of 300 feet each 16

ii. Prior to drilling equipment being brought on site, a skid-steer loader will be flown into each helicopter-accessed site location to prepare a drilling pad and to construct a helicopter landing area, as needed. iii. Use of a helicopter-deployed drill rig would result in surface disturbance of approximately six times more area than a rubber tire ATV drill rig in order to accommodate the drill rig and the helicopter. The helicopter-deployed drill rig requires an approximate 20-foot by 40-foot working area, whereas the rubber tire ATV drill rig requires an approximate 20-foot by 50-foot working area. However, the working area for the rubber tire ATV drill rig requires minimal disturbance of soils because the rig has built-in leveling jacks that pick it up off of the ground for leveling. More grading and excavation is required to construct a pad to accommodate the helicopter-deployed drill rig because it requires a generally level and smooth drill pad. Helicopter-served sites may require an additional area of approximately 60-foot by 80-foot area cleared to allow the helicopter to safely land to drop off and pick up drilling personnel. iv. The total anticipated area of disturbance for the helicopter accessed drilling is approximately 1.2 acres divided between the nine drill sites. v. The rig used for the helicopter drilling would be an Acker Bushmaster, or equivalent. vi. The helicopter rig uses N-size coring equipment, which produces a 1-7/8 inch diameter core. This method will not allow for the larger diameter core, which is preferred because it makes it easier to observe general rock properties, including fracturing and alteration, and it provides more material for testing of rock physical properties. vii. Water will be provided to the drill sites by stringing high-pressure hose from the valley floor (private land) and pumping water to the site. viii. Prior to mobilizing the drill rig, a skid-steer loader will be flown into each site to grade and level a drilling pad. At the conclusion of drilling, the skid-steer will be used to complete reclamation of the pad before being flown to the next proposed drilling site. This will necessitate bringing the drilling equipment to a staging area on the Parkdale Quarry between borings so that the drill pad is ready to accept the equipment before the equipment is moved. ix. It is anticipated that each boring will take approximately three 10-hour drilling days to complete, and that drill site preparation, drill rig move-in, laying of water lines, equipment removal, and site restoration will take approximately three days per boring site. c. General i. Because of the added complexity of disassembling and reassembling the drill rig between borings, it will require an estimated 54 working days or 11 weeks to complete. ii. Locally store any cuttings generated from borehole installation for use in borehole abandonment and pad reclamation. iii. Manage fugitive dust generation through similar methods used at the operating mine site on private land. iv. Utilize stormwater management controls. v. Since the project involves oil or fuel usage, transfer or storage, an adequate spill kit and shovels are required to be onsite during project implementation. The project proponent will be responsible for adhering to all applicable local, 17

State and Federal regulations in the event of a spill, which includes following the proper notification procedures in BLM’s Spill Contingency Plan. vi. Monitor constructed pads and landing/staging areas to ensure minimal erosion. vii. Based on drilling performed in the same geologic unit and to similar depths on the adjacent Parkdale Quarry site, it is not anticipated that significant groundwater will be encountered during drilling operations. The approximate distance to the nearest stream from the proposed boring locations ranges from 800’ to 6700’. viii. Based on quotations received by the applicant for the helicopter-supported drilling, it will cost approximately four times more that the traditional ATV/ground based supported drilling costs. The helicopter-supported drilling will cost an estimated $733,000 to complete, whereas the ATV/ground based- supported drilling will cost an estimated $180,000 to complete.

4. Reclamation: While general reclamation means and methods will be substantially the same for a helicopter- deployed drill rig verses a rubber tire ATV drill rig (ground access in the Proposed Action), reclamation timing will change and the amount of disturbed area requiring regrading and the replacement of topsoil will be greater at the helicopter-accessed sites. This alternative would however eliminate the need for a majority of the access route reclamation.

In order to minimize flights and helicopter time, the skid-steer used to build the drill pad will remain on site during drilling, and will be used to complete reclamation of the disturbed areas before being flown to the next proposed drilling site. This will necessitate bringing the drilling equipment to a staging area on the Parkdale Quarry between borings so that the drill pad is ready to accept the equipment before the equipment is moved.

Reclamation of the helicopter-accessed drill pads and landing/staging areas generally consists of regrading areas that were leveled to blend in with the existing topography, replacing top across the regraded areas, reseeding and application of mulch to the disturbed area, and redistribution of rocks and natural debris across the area, if such was removed.

2.2.3 NO ACTION ALTERNATIVE The no action alternative would most likely constitute denial of the mineral materials application, such that the applicant would not be able to assess the full extent of characteristics of the formation without completing a drilling program. If BLM does not authorize this sampling effort, then the applicant would not be able to move forward confidently with the mining application for the BLM area north of the existing Parkdale Quarry.

2.3 ALTERNATIVES CONSIDERED BUT NOT ANALYZED IN DETAIL BLM considered waiting to analyze this proposal until the completion of the RMP process that the Field Office is currently undertaking. However, impacts associated with time delays and uncertainty of future business planning would preclude the ability for the applicant to move forward. Based on current material reserves available and decisions to be made about what type of processing equipment to order and purchase in the future, delaying this action for even just a short time will

cause a shutdown of current operations on the private land, which will cause a loss of customers, put this mining operation out of business and cause disruption to supply and distribution lines.

Because BLMs decision regarding this proposal will be under the authority of the governing RMP, approved in May 1996 and given the logistical circumstances of the operation, this alternative was not considered further.

2.4 STANDARD STIPULATION AND DISCOVERY STATEMENTS (TERMS AND CONDITIONS) Wastes, Hazardous or Solid: It is assumed that conditions associated with the proposed project site, both surface and subsurface, are currently clean and that there is no known contamination. Since the project involves oil or fuel usage, transfer or storage, an adequate spill kit and shovels are required to be onsite during project implementation. The project proponent will be responsible for adhering to all applicable local, State and Federal regulations in the event of a spill, which includes following the proper notification procedures in BLM’s Spill Contingency Plan. Any washout water associated with cement material used as part of the project needs to be contained and properly disposed of at a permitted offsite disposal facility.

CHAPTER 3 - AFFECTED ENVIRONMENT AND EFFECTS 3.1 INTRODUCTION

This section provides a description of the human and natural environmental resources that could be affected by the Proposed Action and presents comparative analyses of the direct, indirect and cumulative effects on the affected environment stemming from the implementation of the actions under the Proposed Action and other alternatives analyzed.

The resource sections below include analysis as it relates to direct and indirect impacts, as well as protective/mitigation measures. Mitigation is defined in the Council on Environmental Quality regulations under 43 CFR 1508.20 and include measures or procedures which could reduce or avoid adverse impacts and have not been incorporated into the proposed action or an alternative.

The Proposed Action and Other Alternative already include significant information regarding the reclamation of lands that would be disturbed by the proposed sampling activities. Therefore, these measures will not be included with any mitigation measures identified during the analysis.

3.1.1 INTERDISCIPLINARY TEAM REVIEW The following table is provided as a mechanism for resource staff review, to identify those resource values with issues or potential impacts from the proposed action and/or alternatives. Those resources identified in the table as impacted or potentially impacted will be brought forward for analysis.

Initial and Resource Comment or Reason for Dismissal from Analysis date

Air Quality CCM, See affected environment. Ty Webb, Chad Meister, Forrest Cook 6/23/17 Geology/Minerals SSC, Federal minerals in the subject area are subject to location, lease and sale Stephanie Carter, under Federal Law. However, as of August 2017, there are no active Melissa Smeins 8/23/17 actions other than the application associated with mineral materials. See affected environment Soils NHT Negussie Tedela 08/02/2017 Water Quality NHT See affected environment Surface and Ground Negussie Tedela 08/02/2017 See affected environment. Invasive Plants AR, Aaron Richter 5/8/2017 A sensitive plant inventory was conducted for all proposed disturbed areas T&E and Sensitive MR, in June of 2017. No sensitive plants were located. There are no other Species known BLM special status species in the project area (Bighorn sheep will Matt Rustand 6/15/17 be discussed in Terrestrial wildlife). Vegetation JW, See affected environment. Jeff Williams, Chris Cloninger, John 5/9/2017 Lamman There are no wetlands or riparian areas that receive direct impacts. Wetlands and Distance and elevation away from water from planned activity sustains Riparian DG, 6/1/17 these resources. See soils/water quality for indirect effects from changes to Dave Gilbert overland flow and watershed protection BMP discussion. Not present on BLM near the proposed bore holes, pads or routes under any Wildlife Aquatic alternative. Dave Gilbert DG, 6/1/17 See affected environment. Wildlife Terrestrial MR, Matt Rustand 10/13/17 See affected environment. Migratory Birds MR, Matt Rustand 6/15/17 Both prehistoric and historic sites and isolates are present in the vicinity of the area of potential effect (see Report CR-RG-17-101 P). Although four sites and two isolated finds (5FN3003-3008) were recorded, the area of Cultural Resources MMW, potential effect was changed to prevent impacts to the single site eligible Monica Weimer 5/25/17 for the National Register of Historic Places (5FN3005). Therefore, no historic properties will be affected by the proposed Parkdale Area Mineral Materials Sampling undertaking. Although aboriginal sites are present in the vicinity of the area of potential Native American MMW, effect, the area of potential effect was changed to avoid impacting any such Religious Concerns sites, and none will be affected. There is no other known evidence that Monica Weimer 8/14/17 suggests the project area holds special significance for Native Americans. Due to the limited nature of this action, even if drilling is contracted out Economics JMM, and supplies bought within this area, overall, the proposed sampling will Jessica Montag result in negligible impacts to the current social and economic conditions of 07/06/17 the area. Based upon the sampling there is the potential that Martin Marietta may want to expand the Parkdale Quarry onto BLM property in

Initial and Resource Comment or Reason for Dismissal from Analysis date order to continue operations after current permitted reserves are mined. Given the economic linkages Martin Marietta has to the local and regional economies through the Parkdale Quarry and the Rock and Rail Railroad, changes in their on-going operations could have a direct effect on employment and income in the area in addition to affecting end users overall costs for the purchase and transport of construction aggregate mineral materials. Paleontology MJS, See affected environment. Melissa Smeins, Stephanie Carter 8/24/2017

Visual Resources LS, See affected environment. Linda Skinner 5/31/17 Environmental JMM, See affected environment. Justice Jessica Montag 6/25/17 Wastes Hazardous See Section 2.2.1.1 - Standard Stipulation and Discovery Statements. or Solid SSC, Melissa Smeins, 8/21/17 Stephanie Carter Due to limited access and challenging terrain, recreation activity could Recreation consist of an occasional hunter or hiker. Because recreational activity is Linda Skinner LS, 5/5/17 extremely light, the action alternatives would have minimal impact. Farmlands Prime This resource is not present. and Unique JW, Jeff Williams, Chris Cloninger, John 10/3/16 Lamman There are no active or closed rights-of-way within the project area Lands and Realty therefore, realty has no issues. Jeff Brown JB 4-5-17 Wilderness, WSAs, ACECs, Wild & LS, 5/5/17 Not present Scenic Rivers Linda Skinner Wilderness LS, See affected environment. Characteristics Linda Skinner 5/31/17 Range Management Proposed Action occurs within an active grazing allotment identified as the Jeff Williams, Chris JW, Parkdale Allotment #00004. Grazing typically does not occur within the Cloninger, John 5/9/2017 proposed exploration area and impacts to grazing management are not Lamman anticipated. Any cuttings less than 4” in diameter (small branches and tops) shall be JLM, used for post-project reclamation, while any cuttings over 4” in diameter Forest Management (main stems, larger branches) will be cut into 4’ lengths and piled in a Jeremiah Moore 10/11/16 publicly accessible area (within 100’ of BLM designated road). RGFO Forester shall be notified upon project completion. Monuments and official bearing accessories shall be protected prior to Cadastral Survey SJH, constructing the roads or borings. Sean Hines 06/15/2017 Detailed analysis was deemed unnecessary as noise levels of machine Noise mw, operation with the Proposed Action and additionally helicopter noise with Martin Weimer 8/24/17 Alternative 1 would have minimal effect on human populations (lack of 21

Initial and Resource Comment or Reason for Dismissal from Analysis date nearby populations). It would have the temporary effect of displacing wildlife. This local effect would abate when operations were complete.

This action will not result in significant impacts to fire suppression Fire/Fuels TW, activities or increase the threat of human caused fires. Ty Webb 11/14/2016

The affected resources brought forward for analysis include:

• Air Quality • Soils • Water Quality • Invasive Plants • Vegetation • Wildlife Terrestrial • Migratory Birds • Visual Resources • Environmental Justice • Wilderness Characteristics

3.2 PHYSICAL RESOURCES

3.2.1 AIR QUALITY Affected Environment:

The Clean Air Act (CAA) and the Federal Land Policy and Management Act of 1976 (FLPMA) requires BLM and other federal agencies to ensure actions taken by the agency comply with federal, state, tribal, and local air quality standards and regulations. FLPMA further directs the Secretary of the Interior to take any action necessary to prevent unnecessary or undue degradation of the lands [Section 302 (b)], and to manage the public lands “in a manner that will protect the quality of scientific, scenic, historical, ecological, environmental, air and atmospheric, water resource, and archeological values” [Section 102 (a)(8)].

Criteria Air Pollutants

The U.S. Environmental Protection Agency (EPA) has established National Ambient Air Quality Standards (NAAQS) for criteria pollutants, which include carbon monoxide (CO), nitrogen dioxide

(NO2), ozone (O3), particulate matter (PM10 and PM2.5), sulfur dioxide (SO2), and lead (Pb). Exposure to air pollutant concentrations greater than the NAAQS has been shown to have a detrimental impact on human health and the environment, and thus ambient air quality standards must not be violated in areas where the general public has access. All of the criteria pollutants are directly 22

emitted from a variety of source types, with the exceptions being ground level ozone, and the secondary formation of condensable particulate matter (PM2.5). Ozone is chemically formed in the atmosphere via interactions of oxides of nitrogen (NOX) and volatile organic compounds (VOCs) in the presence of sunlight and under certain meteorological conditions (NOX and VOCs are ozone precursors). Secondary PM2.5 forms when certain products of combustion from a source stack cool sufficiently enough to condense and form a solid or aerosol that can then be measured via traditional monitoring methods.

The CAA established two types of NAAQS, primary and secondary. Primary standards set limits to protect public health, including the health of "sensitive" populations (such as asthmatics, children, and the elderly). Secondary standards set limits to protect public welfare, including protection against decreased visibility, and damage to animals, crops, vegetation, and buildings. The EPA regularly reviews the NAAQS (every five years) to ensure that the latest science on health effects, risk assessment, and observable data such as hospital admissions are evaluated, and can revise any NAAQS if the data supports a revision. The Colorado Air Pollution Control Commission can establish state ambient air quality standards for any criteria pollutant. Any state standard must be at least as stringent as the federal standards. Table I lists the Federal and Colorado ambient air quality standards.

Table 3.2.1 - 1, Ambient Air Quality Standards

Pollutant Standard Averaging Level Form Period

Carbon Primary 1-hour 35 ppm Not to be exceeded more than once per Monoxide (40,000 ug/m3) year

8-hour 9 ppm (10,000 ug/m3)

Lead Primary and Rolling 3-month 0.15 ug/m3 Not to be exceeded Secondary average

Nitrogen Primary 1-hour 100 ppb 98th percentile, averaged over 3 years Dioxide (189 ug/m3)

Primary and Annual 53 ppb Annual mean Secondary (100 ug/m3)

Ozone Primary and 8-hour 0.070 ppm Annual fourth-highest daily maximum 8- Secondary (140 ug/m3) hr concentration, averaged over 3 years

3 Particulate PM2.5 Primary 24-hour 35 ug/m 98th percentile, averaged over 3 years Matter and secondary

Primary Annual 12 ug/m3 Annual mean, averaged over 3 years

secondary Annual 15 ug/m3 Annual mean, averaged over 3 years

3 PM10 Primary Annual 150 ug/m Not to be exceeded more than once per and year on average over 3 years secondary

Sulfur Primary 1-hour 75 ppb 99th percentile of 1-hour daily maximum Dioxide (196 ug/m3) concentrations, averaged over 3 years

Secondary 3-hour 0.5 ppm Not to be exceeded more than once per (1,300 ug/m3) year

Source: 40 CFR 50, 5 CCR 1001-14, mg/m3 = milligrams per cubic meter, μg/m3 = micrograms per cubic meter, ppb = parts per 3 billion, ppm = parts per million, The Colorado Ambient Air Quality Standard for 3-hour SO2 is 0.267 ppm (700 ug/m )

Other common pollutants include Air toxics, otherwise known as hazardous air pollutants (HAPs), and greenhouse gases (GHGs). HAPs are chemicals or compounds that are known or suspected to cause cancer or other serious health effects, such as compromises to immune and reproductive systems, birth defects, developmental disorders, or adverse environmental effects and may result from either chronic (long-term) and/or acute (short-term) exposure. Ambient air quality standards do not exist for HAPs, however mass based emissions limits and risk based exposure thresholds have been established as significance criteria to require maximum achievable control technologies (MACT) under the EPA promulgated National Emissions Standards for Hazardous Air Pollutants (NESHAPs). HAPs are emitted from a variety of source types including most if not all conventional combustion sources, albeit in fractions far lower than the criteria pollutants. GHGs include carbon dioxide (CO2), methane (CH4), Nitrous Oxide (N2O), and several fluorinated species of gases such as hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. GHGs are also emitted by most conventional combustion sources. Like the HAPs, ambient air quality standards do not exist for GHGs.

Existing Regional Air Quality Air quality for any region is influenced by the amount of pollutants that are released within the vicinity and up wind of that area, and can be highly dependent upon the contaminants chemical and physical properties. Additionally, an area’s topography or terrain (such as mountains and valleys) and weather (such as wind speed and direction, temperature, air pressure (the resulting turbulence), rainfall, and cloud cover) can have a direct influence on how pollutants accumulate, form, or disperse in the local environment. The project area includes the areas around Canon City, Colorado. The area is currently designated as attaining the current NAAQS, however most the metropolitan area itself (see fig. 3.2.1-1) is designated as a PM10 maintenance area for previous violations to the PM10 NAAQS. The area was re-designated as attainment in 2000, and recent monitoring data for PM10 shows that the area is easily achieving compliance with current standards. There are no other nearby monitors to the project area, and no other designations made by CDPHE for any other air quality concerns.

Section 176(c) of the CAA, 42 U.S.C. § 7506, prohibits Federal entities from approving actions in nonattainment or maintenance areas that do not “conform” to the State Implementation Plan (SIP). The purpose of this conformity requirement is to ensure that Federal activities: (1) do not interfere with the budgets in the SIPs; (2) do not cause or contribute to new violations of the NAAQS; and (3) do not impede the ability of regulators to attain or maintain the NAAQS. To implement CAA Section 176(c), EPA issued the General Conformity Rule (40 C.F.R. Part 93, Subpart B), which applies to all Federal actions not funded under U.S.C. Title 23 or the Federal Transit Act (BLM actions are not funded by U.S.C. Title 23 or the Federal Transit Act). The General Conformity Rule established emissions thresholds (40 C.F.R. 93.153) for use in evaluating the conformity of a project (40 C.F.R. 93.153(b)(1)). If the reasonably foreseeable direct and indirect net emissions increase due to the project or action is less than these thresholds, no further conformity evaluation is required (40 C.F.R. 93.153(c)(1). If these emissions increases exceed any of these thresholds, a formal conformity determination would be required.

Figure 3.2.1 - 1, Canon City PM10 Maintenance Boundary

Figure 3.2.1 - 2, Canon City PM10 Monitoring Data

Environmental Effects

The potential air quality impacts / effects of concern for this project are mostly the result of ground disturbance activities, and as such the primary pollutant of concern is fugitive PM10 (and to a lesser extent fugitive PM2.5). Each alternative (other than the no action) will also generate tailpipe emissions associated with on road traffic and off road equipment use (including aircraft in the Other Alternative). In general, the effects to air resources are similar for each no action alternative in that fugitive dust is a short lived and highly localized nuisance more than anything. Tailpipe emissions will also be minor and highly dispersed such that they are not expected to cause any significant impacts. There are no close by sensitive receptors (residences, schools, hospitals, etc.) to the project area that would be a cause for concern based on any potential fugitive dust impacts. Therefore, the BLM is limiting its analysis to emissions disclosures for which inventories for each alternative were prepared as described below. Each no action alternative also has a potential for generating emissions within the PM10 maintenance area, and therefore the BLM is providing a general conformity applicability analysis to determine the need for a formal conformity determination. With the exception of the helicopter emissions in the Other Alternative, all estimates for on road and off road activities were generated using EMIT, the BLMs emissions inventory tool. The tool uses the activity data shown below along with emissions factors from EPA’s Nonroad and MOVES models to produce the emissions inventories.

Proposed Action The proposed action primarily consists of ground based disturbance activities. The following estimates / assumptions of these activities were used to produce emissions inventories. • 12.5 total acres of tracked area, with 60% disturbance • 10 weeks total time to complete • 1 ATV Rig 110 hp (12 hours / day, 3 days / well + 1 travel) (assumed model: CME-550X) • 1 250 hp D6 Dozer (8 hours / day, 25 days) • 1250 cuyd of total cut and fill

• 200 total crew trips (4 round trips / day, 20 miles 1 way) • maintenance area travel is 2 miles one way

Table 3.2.1 - 2, Proposed Action Emissions (tons) Description PM10 PM2.5 VOC NOX CO SO2 CO2 CH4 N2O HAPs Land Disturbance (fugitive dust & 5.691 3.648 0 0 0 0 0 0 0 0 travel) Dozer (exhaust) 0.024 0.023 0.029 0.273 0.113 0.009 45.801 0 0.001 0.003 Drill Rig (exhaust) 0.021 0.021 0.021 0.196 0.094 0.006 30.229 0 0.001 0.002 On Road (fugitive 0.023 0.006 0 0 0 0 0 0 0 0 dust) On Road (exhaust) 0 0 0.006 0.009 0.086 0 4.112 0 0 0 Totals: 5.759 3.698 0.056 0.478 0.293 0.015 80.142 0 0.002 0.005 Note: On Road exhaust emissions shown as 0 are less than one one-thousandth of a ton.

Any maintenance area PM10 emissions occurring from this alternative (approximately one tenth of the on-road exhaust emissions) would be clearly de minimis (i.e. less than 100 tpy) in accordance with the requirements of 40 C.F.R. 93.153(b)(2), and therefore this action conforms to the SIP. Emissions for this alternative are exceptionally low, and are far removed from other potentially significant sources of fugitive dust (including the existing quarry) such that no cumulative impacts to any nearby receptor would be expected. This alternative assumes that water is used to control fugitive dust to the maximum extent practical. For the purposes of the emissions inventory, all off- road activity was assumed to be controlled by approximately 25%. No additional mitigation is warranted for the protection of air resources.

Alternative 1 The alternative to the proposed action eliminates overland access to potential drilling sites such that no temporary access road construction would be authorized. Instead, off-road sources would be airlifted to and from the borehole locations in a sequential manner that would allow for site prep, drilling and reclamation in the most efficient way possible. The following estimates / assumptions of these activities were used to produce emissions inventories. • 1.2 total acres of disturbed area (100%) • 30 hours to bore a single hole (10 hours / day) • 30 hours of staging, clearing, reclaiming / borehole • 225 helicopter trips, with a total flight time of 30 minutes / trip • On road travel assumed to be the same as proposed for paved roads

Emissions from the “Super Huey” Bell UH-1H/703 helicopter were calculated using criteria pollutant emissions factors published in EPA’s Air Pollutant Emission Factors for Military and Civil Aircraft, 1978, specifically for the Lycoming T53-L-11D turbo shaft engine. The literature does not provide factors for particulate matter, so the BLM substitutes the factors from General Electric’s T58-GE-5 turbo shaft, which had similar fuel consumption characteristics for each published mode. EPA’s emissions factors for aviation gasoline were used to estimate the aircraft’s GHG emissions. To quantify emissions the BLM assumed on average the helicopter would idle for not more than 5 minutes, and the remainder of the time would be split between the climbout and approach flight modes (approx. 25 minutes total). Because the loaded helicopter will employ flight

routes away from potentially populated areas, the BLM assumes that the flight path will not intersect with the PM10 maintenance area.

Table 3.2.1 - 3, Alternative 1 Emissions (tons) Description PM10 PM2.5 VOC NOX CO SO2 CO2 CH4 N2O HAPs Land Disturbance 4.709 3.756 0 0 0 0 0 0 0 0 (fugitive dust) Skid Steer 0.016 0.015 0.014 0.104 0.108 0.003 15.311 0 0 0.001 (exhaust) Drill Rig (exhaust) 0.014 0.014 0.015 0.133 0.064 0.004 20.555 0 0.001 0.001 On Road (fugitive 0.023 0.006 0 0 0 0 0 0 0 0 dust) On Road (exhaust) 0 0 0.005 0.007 0.066 0 3.111 0 0 0 Helicopter 0.038 0.038 0.094 0.236 0.133 0.033 89.336 0.004 0.001 ND Totals: 4.800 3.829 0.128 0.480 0.371 0.040 128.313 0.004 0.002 0.002 Note: On Road exhaust emissions shown as 0 are less than one one-thousandth of a ton. ND = No data.

The criteria pollutant emissions from this alternative are almost equivalent emissions from this alternative are almost to the proposed action with the notable exception being the total GHG’s resulting from the helicopters operation. Any maintenance area PM10 emissions occurring from this alternative (approximately one tenth of the on-road exhaust emissions) would be clearly de minimis (i.e. less than 100 tpy) in accordance with the requirements of 40 C.F.R. 93.153(b)(2), and therefore this action conforms to the SIP. Emissions for this alternative are exceptionally low, and are far removed from other potentially significant sources of fugitive dust (including the existing quarry) such that no cumulative impacts to any nearby receptor would be expected. This alternative assumes that water is used to control fugitive dust to the maximum extent practical. For the purposes of the emissions inventory, all off-road activity was assumed to be controlled by approximately 25%. No additional mitigation is warranted for the protection of air resources.

Protective/Mitigation Measures: No additional mitigation is warranted for the protection of air resources.

No Action Alternative Under the no action alternative the exploration permit would not be granted, and no ground disturbance or exploration activities would take place. There would be no emissions of any pollutants of any kind, and therefore no potential for any impacts to air resources.

3.2.2 SOILS (includes a finding on standard 1) Affected Environment: The soil within the analysis area is described in the BLM GIS Soil Survey Geographic (SSURGO) Database. All exploration activities are located on Ustic Torriorthents, bouldery-Rock outcrop-complex on moderate to very steep gradient (35 to 90 percent slopes) and on Roygorge very gravelly sandy clay-loam soil types on moderate gradient (25 to 50 percent slopes). Most of the construction activity is located on Ustic Torriorthents, bouldery-Rock outcrop-complex soil type. Based on erosion factor-K, these soils have low susceptibility to sheet and rill erosion by water. The bases for derivation of the erosion factor - K is primarily on percentage of silt and sand, organic matter, soil structure, and saturated hydraulic conductivity. However, due to steep slope 28

gradient, the soils have high potential to erosion hazard for access roads, indicating significant erosion is expected and the roads would require frequent maintenance and erosion-control measures. In addition, the soils are poorly suited for natural surface roads. Wind Erodibility Group (WEG) consists of soils that have similar properties in relation to their susceptibility to wind erosion and classification for the two soils within the project area is WEG-six and seven. The soils within group-one are the most susceptible to wind erosion and group-eight are the least susceptible. Hydrologic Soil Group is D for the two soils, indicating very slow infiltration rate (high runoff potential) when thoroughly wet due to shallow soil over nearly impervious material. For the Ustic Torriorthents soil type, the parent material consists of colluvium derived from granite and gneiss and/or residuum weathered from granite and gneiss. Depth to a root restrictive layer, bedrock is 4 to 30 inches. The soil has a well-drained natural drainage class and water movement in the most restrictive layer is moderately low. Available water to a depth of 60 inches is very low. This soil is not flooded or ponded and there is no zone of water saturation within a depth of 72 inches. For the Roygorge very gravelly sandy clay-loam soil type, the parent material consists of residuum weathered from gneiss and/or residuum weathered from granite. Depth to a root restrictive layer, bedrock, or lithic is 8 to 20 inches. Available water to a depth of 60 inches (or restricted depth) is very low. Shrink-swell potential is low, the soil is not flooded or ponded, and there is no zone of water saturation within a depth of 72 inches. The existing condition of upland and riparian soil resources results from natural and anthropogenic impacts. Past actions include activities that have influenced and affected the current condition of the environment near the project area. Grazing, road and historical trails network, and OHV use influenced the analysis area. Roads and compacted soils have created an impervious surface that has reduced the infiltration rate and contributes to surface runoff and soil erosion. Erosion potential is higher on steep slopes and adjacent to less permeable surfaces such as rock outcrops or compacted areas, such as roads. Identification of the condition of soil resources determined based on the degree and extent of impacts such as erosion, compaction, soil vegetation cover, and soil productivity. Soil features such as rills, active gullies, pedestals, surface litter and plant cover are important indicators of Standard-1.

Environmental Effects

Proposed Action Direct and Indirect Impacts: Direct and Indirect Impacts: Under the proposed action, exploration activities will disturb approximately 12.5 acres of BLM land. The disturbance includes about 29,300–foot long and 18-foot wide exploration access routes and nine drill pads with average disturbance area of 1,250 square feet. Exploration activities would require drilling boreholes, grading, vegetation removal, and associated soil disturbance. The proposed action would result in soil erosion, compaction, and soil profile mixing. Soil contamination would also occur due to machinery involved with construction activities that may deposit small amounts of petro- hydrocarbons onto soils through equipment failure or normal operations. Exposed soil material during exploration activities would be susceptible to erosion until the proposed work completed and vegetation cover restored. Planned use of temporary erosion-control would reduce the potential for short-term erosion and soil loss during exploration. The impact on soils would be local, short-term, moderate, and adverse from mineral exploration disturbances. In general, adverse impacts on site soil resources would be minor with no substantial change in topography or impact on important soil features or processes. Protective/Mitigation Measures: Clean and inspect all construction equipment prior to use. If required, minimize clearing of vegetation to the greatest extent possible. Install erosion nets, 29

wattles, straw bales or other mechanical sediment control measures to provide surface soil stability where necessary. Remove any structure installed during exploration and construction activities to restore natural drainage during the cleanup and restoration phase of the project. Implement final erosion control and site restoration measures as soon as a particular area is no longer needed for construction, stockpiling, or access. Arrange clearing schedules to minimize exposure of soils. Cuts and fills for the new access roads will be sloped to facilitate revegetation. Do not place soil or rock stockpiles, excavated materials, or excess soil materials near sensitive habitats, including water channels, wetlands, riparian areas, and on native or naturally occurring vegetation. In addition, apply all mitigation and protective measures indicated under Section 2.2.1 to reduce soil disturbance and erosion.

Alternative 1 Direct and Indirect Impacts: Under Alternative 1, exploration activities will disturb approximately one to two acres of BLM land. The disturbances include drill pads and helicopter landing/staging areas. Disturbances related to helicopter landing/staging areas will replace the disturbance due to access roads construction at the project site and as a result, this alternative has smaller disturbance area (a maximum of two-acres) and associated impact compared to the proposed action that has a disturbance area of about 12.5 acres. The impact on soils would be local, short-term, minor, and adverse from mineral exploration disturbances under Alternative 1. In general, adverse impacts on site soil resources would be minor with no substantial change in topography or impact on important soil features or processes.

Protective/Mitigation Measures: Use the same Protective/Mitigation Measures indicated under the Proposed Action as needed.

No Action Alternative Direct and Indirect Impacts: Under the No Action Alternative, there will be no impacts from proposed activities. There will be continued erosion occurring on the watershed along the existing road system, particularly where the roads crosses drainages.

Protective/Mitigation Measures: No protective/Mitigation measures are required except the ongoing activities that require maintenance of existing road system and operations, which reduce impacts and protect soil resources from erosion.

Finding on the Public Land Health Standard for Upland Soils: Upland soils exhibit infiltration and permeability rates that are appropriate to soil type, climate, landform, and geologic processes. In general, upland soils achieved standard-1 and there would be a minimal anticipated impact due to the proposed action and no action alternatives.

3.2.3 WATER (SURFACE AND GROUNDWATER, FLOODPLAINS) (includes a finding on standard 5) Affected Environment: The project area is situated within a fifth level (Hydrologic Unit Cod, HUC: 1102000111) Tallahassee Creek-Currant Creek watershed of the Arkansas Headwaters sub-basin (11020001) (Figure 1). BLM managed lands within the watershed is about 29.0 percent of the watershed.

About 57.3 percent of the watershed is Private, 7.4 percent is State, and 6.3 percent USFS lands. Elevation within this watershed ranges from approximately 6,000 feet along the outlet of Tallahassee Creek to over 11,500 feet in the northern part of the watershed. Elevation within the project area ranges between 6,000 to 6,500 feet. Lower areas of the watershed receive about 13 inches and higher elevation areas receive about 19 inches of annual precipitation, with most of the rainfall events occurring in July and August. The amount of annual precipitation at the project site is about 17 inches. Within the watershed, there are perennial/intermittent/ephemeral streams and Lakes/ponds. Perennial streams located within the watershed are Currant Creek, Cottonwood Creek, North Tallahassee Creek, Tallahassee Creek, Thirtyone Mile Creek, Fear Creek, South Tallahassee Creek, Dicks Creek, North Waugh Creek, Paris Creek, Squaw Creek, Middle Tallahassee Creek, Kelly Creek, Freshwater Creek, Salt Creek, and West Waugh Creek. All Perennial/intermittent streams originating from this watershed drain into Tallahassee Creek. Tallahassee Creek is a tributary of Arkansas River. Current Creek (1.41 miles), Tallahassee Creek (0.27 mile), and few intermittent streams (7.67 miles) are located within the project boundary. There are several wells, diversions, canals, small lakes/ponds, and marsh areas within the watershed. No alluvial or principal bedrock aquifers are located under the watershed or project area. There are, however, shallow aquifers within the watershed. Construction of roads, surface- and ground-water use have modified the hydrology of the analysis area. There are several wells, ponds, and water diversions structures located in the watershed to pump and divert surface water and groundwater for domestic and agricultural activities. The Clean Water Act (CWA) requires that chemical, physical, and biological integrity of all waters of US be protected. In the 2016 Colorado list of impaired waters, all streams within the Tallahassee Creek-Currant Creek watershed are not currently in the 303 (d) listing.

Environmental Effects

Proposed Action Direct and Indirect Impacts: Under the proposed action, Exploration activities will disturb approximately 12.5 acres of BLM land. The disturbance includes about 29,300–foot long and 18- foot wide exploration routes and nine drill pads with average disturbance area of 1,250 square feet. The proposed action would involve ground clearing, grading, borehole drilling, compaction, and additional exposure of soil material that would temporarily increase the potential for erosion and sediment transport to streams until the end of disturbance activity and regrowth of vegetation. Soil and surface water and groundwater contamination could also occur due to machinery involved with project activities that may deposit and percolate small amounts of petro-hydrocarbons onto soils and water resources through equipment failure or normal operations. In addition, construction of access roads would create a direct impact, increasing the amount of impermeable surfaces that would increase runoff. The primary sources of potential water pollution from these activities are sediment-laden runoff from project site. Reduction of soil permeability due to compaction would lead to increase in runoff rate and amount on the ephemeral channels and accelerate sediment transport and hence affect water quality, if reaches to any perennial/intermittent streams. However, with the use of protective and mitigation measures sediment from the project area is not anticipated reaching perennial/intermittent streams within the watershed. Any sediment contribution to the drainage during project construction would be minor in relation to the supply of sediment and erosion that naturally occurs in this watershed. Local short-term minor adverse effects on surface water and groundwater quality and hydrologic process are possible during construction, but in the end, these 31

effects would be local and not long-term due to revegetation effort and application of conservation measures to reduce soil erosion and sediment transport.

Protective/Mitigation Measures: Minimize the amount of soil disturbance, use designated access roads, and leave vegetation on the ground as much as possible during construction of access road and other project activities. Maintain construction equipment according to the manufacturer’s specifications and contain and store other potentially hazardous materials appropriately. Construction personnel would follow appropriate procedures to protect against potential petroleum or hazardous material spills. Conduct good maintenance of equipment and containment of fuels and other potentially hazardous materials to minimize the potential for a release of these fluids into groundwater and surface water resources. Hazardous spill plan would be required and clean-up materials would be on-site at all times. These measures are designed to protect surface and groundwater and avoid/minimize the introduction of chemical contaminants associated with machinery (e.g., fuel, oil, and hydraulic fluid) used in project implementation. Complete the project when site conditions are mostly dry. In addition, apply mitigation measures indicated in the soils section and Section 2.2.1 to protect water resources.

Alternative 1 Direct and Indirect Impacts: Under Alternative 1, exploration activities will disturb approximately one to two acres of BLM land. Disturbances related to helicopter landing/staging areas will replace the disturbance due to access roads construction at the project site and as a result, this alternative has smaller disturbance area (a maximum of two-acres) and associated impact compared to the proposed action that has a disturbance area of about 12.5 acres. Under Alternative 1, disturbance and associated impacts on water quality are significantly reduced compared to the proposed action. The impact on water quality and hydrologic functioning would be local, short-term, minor, and adverse from mineral exploration disturbances under Alternative 1. In general, adverse impacts on water resources would be negligible with no substantial change in water quality and hydrologic processes.

Protective/Mitigation Measures: Use the same Protective/Mitigation Measures indicated under the Proposed Action, as needed.

No Action Alternative Direct and Indirect Impacts: Under the No Action Alternative, there will be no impacts from proposed activities. There will be continued erosion and sediment transport occurring on the watershed along the existing road system, particularly where the roads crosses drainages. Protective/Mitigation Measures: No protective/Mitigation measures are required except the ongoing activities that require maintenance of existing road system and operations, which reduce impacts and protect soil resources from erosion.

Finding on the Public Land Health Standard for Water Quality: The water quality of Nation’s water located on or influenced by BLM lands will achieve or exceed the Water Quality Standards established by the State of Colorado. As indicated above, none of the streams located in the watershed are in 303 (d) listing. A change to surface or ground water quality or quantity is negligible due to the proposed action or other alternatives and water bodies located within the watershed are meeting Standard 5.

3.3 BIOLOGICAL RESOURCES

3.3.1 INVASIVE PLANTS Affected Environment: The area around the proposed project has known infestations of noxious weeds, primarily leafy spurge, Canada thistle (and noxious biannual thistles), and salt cedar. There may be other invasive species in the area. The thistle species and salt cedar are mostly associated with the riparian areas along Currant Creek and Tallahassee Creek. Leafy spurge infestations have been located on the private land (including the area of the existing quarry) and the nearby BLM land in both riparian and upland settings.

Environmental Effects

Proposed Action: Direct and Indirect Impacts: The areas which will be disturbed as a result of the proposed action would be more susceptible to infestation by invasive species than lands which are not disturbed. Reclamation and revegetation of disturbed areas with desirable vegetation, as outlined in the proposed action, should decrease the susceptibility of these areas to invasive species establishment.

Protective/Mitigation Measures: In addition to the reclamation procedures proposed by the applicant and outlined in the proposed action, the applicant would be required to wash all equipment prior to moving into project area in order to remove any weed seeds that may remain on equipment from prior locations. In addition, applicant will be required to monitor project area for the presence of noxious weeds (invasive species) until reclamation is deemed successful by BLM staff. If any weeds are found, applicant would be required to effectively control weeds associated with the project until reclamation is successful. BLM chemical pest control policy must be followed when treating weeds (contact RGFO noxious weed coordinator).

Alternative 1 Direct and Indirect Impacts: The expected impacts with this alternative are expected to be similar to the proposed action, however since less land would be disturbed under this alternative, there may be less potential for establishment of invasive species under this alternative. Even though roads will not be constructed to drill pads, personnel would have to access these areas in order to monitor for and potentially treat any weeds that may invade these areas. Protective/Mitigation Measures: Same as proposed action.

No Action Alternative Direct and Indirect Impacts: None. Protective/Mitigation Measures: None.

3.3.2 VEGETATION (includes a finding on standard 3) Affected Environment: The elevation of the analysis area ranges from 6,000 to 7,000 feet and the growing season for native vegetation is generally between the months of late May through early September. Precipitation records indicate that July and August are the wettest months of the year as well as the warmest. The combination of available moisture and warm temperatures tend to provide July and August with the most favorable conditions for plant growth during the year. 33

The project area is dominated by a pinyon-juniper woodland plant community and the herbaceous understory is influenced by the slope, soil depth, and tree stand density. In areas where the slope is steep, soils shallow and rocky, the herbaceous component is very minor. Generally, deeper soils with moderate to gentle slopes and a low tree stand density contain more of the herbaceous component. In these areas the grasses may include Mountain Muhly, Needle and Thread, Indian Rice grass, Purple Three Awn, Pine Dropseed, Blue Grama, Sideoats Grama, and Prairie June grass. Shrubs include Mountain Mahogany, Current, and various cacti.

Environmental Effects

Proposed Action Direct and Indirect Impacts: Proposal is to conduct exploration activities consisting of access roads and drill pads resulting in 12.5 acres of direct impact to vegetation resources. The Proposed Action includes a thorough reclamation plan that would be implemented immediately following exploration activities that will offset most if not all negative impacts to vegetation.

Protective/Mitigation Measures: None.

Alternative 1 Direct and Indirect Impacts: Direct impacts to vegetation would be limited to 1-2 acres and would pose the least initial impacts to vegetation resources. As in the Proposed Action, any long term effects to vegetation are mitigated through the reclamation plan.

No Action Alternative Direct and Indirect Impacts: None Protective/Mitigation Measures: None

Finding on the Public Land Health Standard for Plant and Animal Communities: The project area is currently Meeting Standards for Public Land Health. It is unlikely the Proposed Action would influence any change to this determination in the long term as long as reclamation is followed and objectives achieved.

3.3.3 WILDLIFE TERRESTRIAL (includes a finding on standard 3) Affected Environment: See the Section 3.3.4 Migratory Birds for a description of habitat preset. Bighorn sheep use Bighorn Sheep Canyon, Cactus Mountain, and the Royal Gorge heavily as overall range and winter range. Mule deer also utilize the action area as severe winter range. Colorado Parks and Wildlife defines severe winter range in the feature class description as that part of the winter range where 90% of the individual animals are located when the annual snowpack is at its maximum and/or temperatures are at a minimum in the two worst winters out of ten. Not all populations exhibit migratory behavior during severe winters, many will stay within the defined winter range regardless of conditions. Thus, some populations may not have a mapped severe winter range distribution. Numerous studies have shown that most native forages available in winter are too low in nutritional value to meet maintenance needs of wild ungulates. Mackie et al. (1998:30) observed that deer survive primarily by supplementing energy reserves accumulated prior to winter with energy intake from sub-maintenance winter diets. This requires behavior that emphasizes energy 34

conservation. Skovlin (1982:379) credits Beall (1974) with the observation that cold-climate ungulates seek habitats with micro-climates that furnish the greatest comfort with the least expenditure of energy. Wood (1988 in Mackie et al. 1998:58) reported that foraging was energetically inefficient for mule deer during severe winter weather conditions. Bedding in protected sites was the favored strategy because it conserved energy. In general, most ungulates demonstrate behavioral adaptations related to energy conservation when winter survival is at stake. Environmental Effects Proposed Action Direct and Indirect Impacts: Although smaller in scale, impacts associated with this action could be similar to those seen during oil and gas drilling operations. Sawyer et al. (2006) demonstrated an avoidance response by mule deer of well pads and roads in the development of a natural gas field in western Wyoming. Northrup et al. (2015) indicate similar results in which mule deer avoided well pads with active drilling to a distance of at least 1000 meters in the Piceance Basin of Colorado with the strongest avoidance 0-600 meters. The response was immediate (i.e., year 1 of development) and no evidence of acclimation occurred during the course of the 3 year study of the Piceance Basin. However, they noted that indirect habitat loss caused by an avoidance response of mule deer could be reduced by 38-63% with the use of advanced technologies and proper planning that minimize the number of well pads and amount of human activity associated with them (Sawyer et al. 2006). Northrup et al. (2015) also suggested that measures aimed at mitigating impacts from oil and gas drilling (which may also be pertinent to the proposed project), such as seasonal drilling restrictions, sound and light barriers, and reductions in vehicle traffic, are likely to have greatest benefit to deer. In general, bighorn sheep avoided habitats disturbed by human activities [e.g. hiking in Arizona (Etchberger et al. 1989), roads and highway traffic in Rocky Mountain National Park (Keller and Bender 2007), construction activities in Nevada (Leslie and Douglas 1980), human activities including vehicles, mountain bikers and hikers in Canyonlands National Park (Papouchis et al. 2001) and to human hikers or humans with dogs in Alberta (MacArthur et al. 1982)]. Sheep in Canyonlands National Park avoided areas within ~500m of human development, a loss of access to 15% of high quality habitat. Dall sheep (Ovis dalli nelsonii) also showed responses to human activities, especially females, who rested less and foraged more when disturbed by humans. One of the most common forms of human disturbance investigated was the effects of aircraft overflights (helicopter, fixed-wing) on bighorn sheep. Studies on the effects of aircraft on bighorn sheep consistently show an impact at distances from 250-750 meters straight-line distance (Bleich 1990, Stockwell 1991, Frid 2003). Based on these studies, clear recommendations to avoid overflights on mountain sheep and goat habitat were presented by all authors. The project will physically disturb 12.5 acres. However, bighorn sheep and mule deer will avoid a much larger footprint while the project is being implanted. Assuming a 400-meter impact buffer from surface disturbing activities, 1,111 acres total will be impacted by the proposed action, though not all at the same time (Figures 3.3.3.1-3.3.3.4). Therefore, 921 acres of bighorn sheep severe winter range and 1,111 acres of mule deer severe winter range will be impacted. Bighorn sheep and mule deer will likely be displaced from the work areas while operations are being conducted. Animal flight responses to disturbance during the winter period will increase energy expenditures during an already fragile time. Timing limitations will mitigate project impacts by restricting human disturbance during the winter period when resources are scarce and animals are stressed. The action area will return to its original functional state quickly due to the short-term

duration of the action and the expected recovery of the site after the implementation of the proposed reclamation plan. Therefore, it is anticipated the long-term impact of the proposed action will be minimal to bighorn sheep and mule deer.

Figure 3.3.3.1. Overview of bighorn sheep severe winter range, as mapped by Colorado Parks and Wildlife (2016), affected by the Parkdale area mineral material sampling. Impact area is defined as 400-m from roads and other surface disturbing activities.

Figure 3.3.3.2. Overview of mule deer severe winter range, as mapped by Colorado Parks and Wildlife (2016), affected by the Parkdale area mineral material sampling. Impact area is defined as 400-m from roads and other surface disturbing activities.

Figure 3.3.3.3. Project view of bighorn sheep severe winter range, as mapped by Colorado Parks and Wildlife (2016), affected by the Parkdale area mineral material sampling. Impact area is defined as 400-m from roads and other surface disturbing activities.

Figure 3.3.3.4. Project view of mule deer severe winter range, as mapped by Colorado Parks and Wildlife (2016), affected by the Parkdale area mineral material sampling. Impact area is defined as 400-m from roads and other surface disturbing activities.

Protective/Mitigation Measures: The action is proposed in bighorn sheep and mule deer severe winter range. The 1996 Royal Gorge Resource Area Resource Management Plan states that within the Arkansas River Ecoregion big game critical winter habitat within the project area will be seasonally limited to mineral operations from December 1 to April 30. Colorado Parks and Wildlife has since revised the seasonal restriction dates for bighorn sheep winter range to November 1 to April 15 and for mule deer winter range to December 1 to April 15. The action does not serve the purpose of improving the site for wintering big game; therefore, a timing limitation from November 1 to April 15 should be enacted to eliminate disturbance to bighorn sheep and mule deer during this critical period to avoid an adverse impact. Alternative 1 Direct and Indirect Impacts: Impacts will be similar as the proposed alternative except that only 1-2 physical acres will be temporarily disturbed. However, helicopter flights will likely be as disruptive as or possibly more so than the use of terrestrial vehicles. The impact buffer is difficult to quantify, as flight paths are unknown. Bighorn sheep and mule deer will likely be displaced from the work areas while operations are being conducted. Flight responses during the winter period will increase energy expenditures during an already fragile time. Timing limitations may mitigate project impacts by restricting human disturbance during the winter period when resources are scarce and animals are stressed. However, the action area will return to its original functional state quickly due to the short-term duration of the action and the expected recovery of the site after the implementation of the proposed reclamation plan. Therefore, it is anticipated the long-term impact of the proposed action will be minimal to bighorn sheep and mule deer. Protective/Mitigation Measures: The action is proposed in bighorn sheep and mule deer severe winter range. The 1996 Royal Gorge Resource Area Resource Management Plan states that within the Arkansas River Ecoregion big game critical winter habitat within the project area will be seasonally limited to mineral operations from December 1 to April 30. Colorado Parks and Wildlife has since revised the seasonal restriction dates for bighorn sheep winter range to November 1 to April 15 and for mule deer winter range to December 1 to April 15. The action does not serve the purpose of improving the site for wintering big game; therefore, a timing limitation from November 1 to April 15 should be enacted to eliminate disturbance to bighorn sheep and mule deer during this critical period to avoid an adverse impact.

No Action Alternative Direct and Indirect Impacts: There would be no impact to terrestrial species. Protective/Mitigation Measures: None.

Finding on the Public Land Health Standard for Plant and Animal Communities: Authorizing this project will not affect the health standard for plant and animal communities.

3.3.4 MIGRATORY BIRDS Affected Environment: The assessment area is primarily pinyon-juniper. In addition, open areas of mountain grassland and shrubs such as currant and mountain mahogany are abundant.

Mountain shrubland habitat provides valuable food and cover for many wildlife species. Many shrub species produce edible fruits, and they provide a large selection of forage types. Often the soil moisture is enough for shrubs to grow densely. Gambel oak acorns are an important mast crop in many areas. Birds such as band-tailed pigeon, wild turkey, Lewis's woodpecker, Steller's jay, western scrub-jay, and green-tailed towhee feed on the acorns. Other birds such as the Virginia's warbler utilize mountain shrub habitat for resting, feeding, and nesting. Dusky flycatcher, Virginia's warbler, and green-tailed towhee are associated with Gambel oak and other shrub habitat. Pinyon-juniper habitat supports the largest nesting bird species list of any upland vegetation type in the West. The richness of the pinyon-juniper vegetation type is important due to its middle elevation. Several species are found in the pinyon-juniper habitat and include: black-chinned hummingbird, gray flycatcher, Cassin's kingbird, gray vireo, pinyon jay, juniper titmouse, black- throated gray warbler, Scott's oriole, ash-throated flycatcher, Bewick's wren, mountain chickadee, white-breasted nuthatch, and chipping sparrow. The following birds are listed on the U.S. Fish and Wildlife Service Birds of Conservation Concern – 2008 List for BCR 16-Southern Rockies/Colorado Plateau. These species have been identified as species that may be found in the project area, have declining populations and should be protected from habitat alterations. The golden eagle is a bird of grasslands, shrublands, pinyon-juniper woodlands, and ponderosa pine forests, but may occur in most other habitats occasionally, especially in winter. Nests are placed on cliffs and sometimes in trees in rugged areas, and breeding birds range widely over surrounding habitats. Peregrine falcons in Colorado breed on cliffs and rock outcrops from 4,500-9,000 feet in elevation. They most commonly choose cliffs located within pinyon-juniper and ponderosa pine zones. These falcons feed on smaller birds almost exclusively, with White-throated swifts and rock doves being among their favored prey. Prairie falcons nest in scattered locations throughout the state where they inhabit the grassland and cliff/rock habitat types. These falcons breed on cliffs and rock outcrops, and their diet during the breeding season is a mix of passerines and small mammals. Gray Vireos are pinyon-juniper woodland obligates. Gray Vireos usually inhabit stands dominated by juniper or thin stands of pure juniper. They construct nests of dry grasses, plant fibers, stems, and hair, often camouflaging them with sagebrush leaves. Piñon jays range the semiarid lands of the West. The Colorado Breeding Bird Atlas map shows them south of a diagonal line drawn from the northwest corner to the southeast corner of the state. Piñon jays are pinyon-juniper obligates in Colorado and nest commonly at the lower elevations of pinyon-juniper woodlands, often where junipers dominate. A few nest in ponderosa pine. They prefer extensive stands far from high human activity. Black-throated gray warblers are fairly common summer residents in pinyon-juniper woodlands across the southwestern half of Colorado. Some surveys show these warblers to be the most frequently encountered birds in the piñon-juniper woodland. Black-throated gray warblers, in Colorado, are pinyon-juniper obligates, preferring tall, dense piñon-juniper woodlands. Virginia's warblers in Colorado nest between 5,000-9,000 feet in elevation. They breed most abundantly in the western quarter of the state, along the eastern slope foothills, and in the upper Arkansas River drainage.

Virginia's warblers nest in dense shrublands and on scrub-adorned slopes of mesas, foothills, open ravines, and mountain valleys in semiarid country. They use scrubby brush, pinyon-juniper woodland with a well-developed shrubby understory, ravines covered with scrub oak and dense shrublands, especially Gambel oak. They also breed in open ponderosa pine savannahs that have a dense understory of tall shrubs. Environmental Effects Proposed Action Direct and Indirect Impacts: A total of 12.5 acres will be temporarily disturbed. Migratory birds will likely be displaced from the work areas while operations are being conducted. However, the action area will return to its original functional state quickly due to the short-term duration of the action and the expected recovery of the site after the implementation of the proposed reclamation plan. Therefore, it is anticipated the overall impact of the proposed action will be minimal to migratory birds. Protective/Mitigation Measures: To be in compliance with the Migratory Bird Treaty Act and the Memorandum of Understanding between BLM and USFWS required by Executive Order 13186, BLM must avoid actions, where possible, that result in a “take” of migratory birds. Pursuant to BLM Instruction Memorandum 2008-050, to reduce impacts to Birds of Conservation Concern, no habitat disturbance (removal of vegetation such as timber, brush, or grass) is allowed during the periods of May 15 - July 15, the breeding and brood rearing season for most Colorado migratory birds. The provision will not apply to completion activities in disturbed areas that were initiated prior to May 15 and continue into the 60-day period. An exception to this timing limitation will be granted if nesting surveys conducted no more than one week prior to vegetation-disturbing activities indicate no nesting within 30 meters (100 feet) of the area to be disturbed. Surveys shall be conducted by a qualified breeding bird surveyor between sunrise and 10:00 a.m. under favorable conditions. Alternative 1 Direct and Indirect Impacts: A total of 1-2 acres will be temporarily disturbed. Migratory birds will likely be displaced from the work areas while operations are being conducted. However, the action area will return to its original functional state quickly due to the short-term duration of the action and the expected recovery of the site after the implementation of the proposed reclamation plan. Therefore, it is anticipated the overall impact of the proposed action will be minimal to migratory birds. Protective/Mitigation Measures: To be in compliance with the Migratory Bird Treaty Act and the Memorandum of Understanding between BLM and USFWS required by Executive Order 13186, BLM must avoid actions, where possible, that result in a “take” of migratory birds. Pursuant to BLM Instruction Memorandum 2008-050, to reduce impacts to Birds of Conservation Concern, no habitat disturbance (removal of vegetation such as timber, brush, or grass) is allowed during the periods of May 15 - July 15, the breeding and brood rearing season for most Colorado migratory birds. The provision will not apply to completion activities in disturbed areas that were initiated prior to May 15 and continue into the 60-day period. An exception to this timing limitation will be granted if nesting surveys conducted no more than one week prior to vegetation-disturbing activities indicate no nesting within 30 meters (100 feet) of the area to be disturbed. Surveys shall be conducted by a qualified breeding bird surveyor between sunrise and 10:00 a.m. under favorable conditions. 43

No Action Alternative Direct and Indirect Impacts: None. Protective/Mitigation Measures: None.

3.4 HERITAGE RESOURCES AND HUMAN ENVIRONMENT

3.4.1 PALEONTOLOGICAL RESOURCES Affected Environment: The affected environment includes portions of the Morrison Formation that is considered a Class 5 paleontological resource that is famous for its prolific dinosaur fossils from the Jurassic Era. Class 5 Paleontological Resources are highly fossiliferous sedimentary rock units that consistently and predictably produce vertebrate fossils. Management concern for paleontological resources in Class 5 areas is very high. A field survey by a qualified paleontologist will be necessary prior to surface disturbing activity and mitigation may be required prior to or during the proposed action. Based on the results of the pre-work survey, on-site monitoring may be necessary during construction activities.

Environmental Effects

Proposed Action Direct and Indirect Impacts: The proposed action includes construction of temporary access routes through the Morrison Formation. Potential impacts to paleontologic resources would be both direct and indirect. Direct impacts to or destruction of paleontologic resources would occur from unmitigated activities conducted on formations with high potential for important scientific fossil resources. Indirect impacts would involve damage or loss of fossil resources due to the unauthorized collection of scientifically important fossils by workers or the public due to increased access to fossil localities in the project area. If unmitigated, adverse impacts to important fossil resources would be long-term and significant since fossils removed or destroyed would be lost to science. Adverse significant impacts to paleontological resources can be reduced to a negligible level through mitigation of ground disturbing activities. It is possible that the proposed project would have the beneficial impact that ground disturbance activities might result in the discovery of important fossil resources. A pre-work survey was conducted on August 30, 2017. The survey findings showed no paleontological resources that would be impacted.

Protective/Mitigation Measures: The operator will need to notify the BLM RGFO immediately if any vertebrate fossils or their traces are discovered during operations within the project area. Operations may continue as long as the fossil specimen would not be damaged or destroyed by the activity. Within 5 working days of notification, the BLM RGFO shall evaluate or have evaluated such discoveries and shall notify the operator what action shall be taken with respect to such discoveries.

Alternative 1 Direct and Indirect Impacts: Alternative 1 would not include the installation of a temporary route through the Morrison Formation, therefore Class 5 paleontologic resources would not be disturbed and would require no mitigation. Protective/Mitigation Measures: none

Cumulative Impacts: none

No Action Alternative With the no action alternative mining would not occur and class 5 paleontologic resources would not be impacted. Direct and Indirect Impacts: None Protective/Mitigation Measures: None

3.4.2 VISUAL RESOURCES Affected Environment: A visual resource inventory (VRI) was conducted for the office in 2015. The inventory revealed that visual resources along the Arkansas River corridor in Bighorn Sheep Canyon are dominated by the river as well as rocky outcrops and steep valley walls, a variety of vegetation and colors. The river canyon has high recreation visitation that is dependent upon intact landscapes and natural scenery. The public land in the canyon is highly visible from highway 50, a major travel corridor for residents and visitors. The inventory found that scenic quality is important for rural residents quality of life. Sensitivity to change is considered high. The inventory also identified the presence of contrasts with the natural environment such as ranches, homes, recreation facilities, power lines, and active mines. Despite the non-natural features the overall landscape was still found to have a VRI Class II.

The VRI was done at a coarse office wide scale. When looking at the specific project area, the existing quarry beyond the railroad line is evident with its conical shaped stockpiles, earthen berm, and horizontal quarry bench cuts. Rail cars are frequently parked on the tracks. The vegetation changes from sparse in the foreground to uniform pinon and juniper woodlands in the background. Structures in the mine are visible from the road. Besides the river corridor, which is immediately adjacent to the Highway, these elements tend to dominate the view in this area.

Visual Resource Management (VRM) classes along with the corresponding VRM Objectives were established in the Royal Gorge Field Office in 1996 with the approval of the Royal Gorge Resource Area Resource Management Plan (RMP). Visual Resource Management objectives corresponding to the various management classes provide standards for analyzing and evaluating proposed projects. Projects are evaluated using the Contrast Rating System to determine if it meets VRM objectives established by the RMP.

The VRM classes established for the project area is Class II. The objective for Class II is to retain the existing character of the landscape.

Environmental Effects

Proposed Action Direct and Indirect Impacts: Based on field visits it was determined that the project area is not visible from the Arkansas River or the Parkdale Recreation Site due to steep banks and the inferior viewing angle. It was determined the project would be visible from traveling along US Highway 50 in both directions and was therefore used as a key observation point when determining contrasts of the project.

A contrast rating form was developed for the project from Highway 50. The contrast rating form found that the project would introduce contrasts in line, color and vegetation associated with the road cuts and pads. These contrasts are anticipated to be weak given the distance from the key observation point (2 miles), the rugged topography of the area, and the existing disturbance in the foreground which tends to dominate the view. The project would not likely be noticeable to the casual observer both in the short term and following reclamation. As a result, the project would meet VRM Class II management objectives.

Protective/Mitigation Measures: None..

Alternative 1 The proposed project for mining exploration in this alternative would be similar to the proposed action in terms of contrasts from disturbances. The use of helicopters to transport equipment to the project site would result in less disturbances from road construction but necessitate larger pads for helicopter landing zones and staging. Impacts to visual resources would be similar to the proposed action but to a slightly lesser degree.

Protective/Mitigation Measures: None.

Cumulative Impacts: Same as proposed action.

No Action Alternative Direct and Indirect Impacts: With the no action alternative, the mining exploration would not occur, therefore not introducing any new visual contrasts. The visual resources would not change from its current state.

Protective/Mitigation Measures: None.

3.4.3 ENVIRONMENTAL JUSTICE Affected Environment: Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, states “each Federal agency shall make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations…” The purpose of EO 12898 is to identify and address, as appropriate, disproportionately high and adverse human health or environmental effects on low-income populations, minority populations, or Indian tribes that may experience common conditions of environmental exposure or effects associated with a plan or project.

Using U.S. Census Bureau 2015 population estimates for race and Hispanic origin (U.S. Census Bureau 2016a), no minority populations in Fremont County, Colorado met the criteria of being 50 percent or more of the population nor did Fremont County have a minority population five percentage points greater than the State of Colorado. Based upon U.S. Census Bureau Small Area Income and Poverty 2015 estimates, the percent of population (all ages) in Fremont County in poverty was five percentage points higher than for the State of Colorado indicating that Fremont County may be considered as having a low-income environmental justice population (U.S. Census

Bureau 2016b). Further examination indicates that the Parkdale Mineral Materials Sampling project area is located in Block Group 3, Census Tract 9790 of Fremont County, Colorado. Based upon U.S. Census Bureau 2011-2015 ACS five-year estimates, this block group does not have any populations identified as environmental justice populations (U.S. Census Bureau 2016c).

Environmental Effects

Proposed Action Direct and Indirect Impacts: Due to the limited nature of the proposed action and minimal use of this area by the public including environmental justice populations the proposed action will not have a disproportionately high and adverse human health or environmental effects on minority or low-income populations. Potential tribal concerns are addressed under the Cultural and Native American Religious Concerns resource sections. Protective/Mitigation Measures: None Cumulative Impacts: None

Alternative 1 Direct and Indirect Impacts: Due to the limited nature of the proposed action and minimal use of this area by the public including environmental justice populations the proposed action will not have a disproportionately high and adverse human health or environmental effects on minority or low-income populations. Potential tribal concerns are addressed under the Cultural and Native American Religious Concerns resource sections. Protective/Mitigation Measures: None Cumulative Impacts: None

No Action Alternative Direct and Indirect Impacts: None Protective/Mitigation Measures: None

3.5 LAND RESOURCES

3.5.1 WILDERNESS CHARACTERISTICS Affected Environment: BLM policy in Section 201 of Federal Lands Policy and Management Act of 1976 (FLPMA) requires the BLM to maintain, on a continuing basis, an inventory of all public lands and their resources and other values, including wilderness characteristics. The Royal Gorge Field Office 2015 inventory identified over 190,000 acres of lands having wilderness characteristics. The Echo Canyon unit consists of 31,660 total acres and contains the proposed mining exploration area, which lies on the eastern edge of the unit. See map below. Although there are many man-made features scattered throughout the Echo Canyon unit, the rugged naturalness dominates the landscape, given the overall size of the area. Due to the lack of public access to the interior of the area, opportunities for solitude and primitive and unconfined recreation also contributed to the areas’ wilderness characteristics. Echo Canyon in general has many mechanically constructed and maintained routes within the area. Evidence of past human activity such as mining tailing piles and prospecting pits, a water catchment, mechanical vegetation treatments, and wildlife exclosures are located within the unit. Motorized access into the area is for administrative access only, limiting use and contributing to the wilderness characteristics of the area.

Identifying land as having wilderness characteristics is an inventory finding. Determining whether that land should be managed to protect those characteristics is an administrative decision that the BLM makes through the land use planning process, which will not constitute a formal designation of any kind.

Environmental Effects 48

Proposed Action Direct and Indirect Impacts: New temporary access routes with approximately 12.5 acres of ground disturbance and temporary motorized use would be introduced into the Echo Canyon lands with wilderness characteristics area as part of the proposed action. This disturbance would temporarily impact naturalness with the addition of approximately 29,300 feet of average 10-foot wide exploration access routes and nine approximate 20- foot by 50-foot drill pads. The disturbance would introduce equipment for the construction activity, temporary access routes, and temporary exploration pads into a relatively unfrequented section of BLM public land.

The proposed action provides a reclamation plan in section 3 with the intent of encouraging natural vegetation growth to return within the project area. With the reclamation occurring immediately after the project completion, the naturalness and noticeable human impact would be temporarily impacted at limited levels. The disturbed sections effect 12.5 acres of the total 31,660 acres representing less than 0.04% of the total Echo Canyon unit identified as having lands with wilderness characteristics. The disturbed sections are even less considering it is 12.5 acres of the total 190,000 acres identified as having lands with wilderness characteristics within the entire RGFO. The disturbed sections are expected to recover in 3-5 years after the reclamation efforts are performed and reseeding has time to grow, therefore returning the area to natural conditions in the long term.

In addition to naturalness, outstanding opportunities for solitude are found in the Echo Canyon unit. The proposed project area within the unit shares a boundary with a private quarry that introduces equipment noise. While the exploration activity would contribute additional noise, it is unlikely that this noise could be discernable in most places separately from the noise associated with the existing quarry. Therefore any additional disruption to the outstanding opportunities for solitude offered by this area would be minimal. Additionally, the projected amount of disruption would require a relatively short time frame of 30 working days or 6 weeks and would introduce equipment noise and human activity in a relatively unfrequented BLM section. Actual visitation numbers are not collected for this unit however, due to the difficulty of public access, it is assumed that the area sees very little to no activity. Therefore, the number of visitors seeking solitude and exposed to the additional noise during the project would be minimal to none.

Protective/Mitigation Measures: None.

Alternative 1 Direct and Indirect Impacts: Alternative 1 uses helicopters to transport equipment to each borehole. The helicopter activity would introduce noise and human disturbance to affect the opportunities for solitude over a larger area of the Echo Canyon lands with wilderness characteristics unit. This alternative would result in an estimated 225 trips through the project area to transport equipment and personnel. Considering each of the nine boring sites will take approximately three 10-hour drilling days to complete, and that drill site preparation, drill rig move-in, laying of water lines, equipment removal, and site restoration will take approximately three days per boring site, the timeframe for completion is approximately 54 days, (24 days longer than the proposed action). Actual visitation numbers are not collected for this unit however, due to the difficulty of public access, it is assumed that the area sees very little to no activity. Therefore, the number of visitors seeking solitude and exposed to the additional noise during the project could be slightly more than the proposed action due to the longer timeframe for project completion. 49

The total anticipated area of ground disturbance for the helicopter accessed drilling is approximately 1.2 acres, divided between the nine drill sites, and consists only of drill pads and landing/staging areas. Equipment used would not require the routes to move from borehole to borehole although some over the ground movement of the equipment is anticipated. These impacts to naturalness would affect 1.2 acres of disturbance area versus the proposed action that would disturb 12.5 acres of lands with wilderness characteristics. Similar to the Proposed Action, the sections of disturbance is a small percentage when considering the total acres identified as having lands with wilderness characteristics is 190,000 acres. Alternative 1 provides a reclamation plan in section 3 with the intent of encouraging natural vegetation growth to return within the project area. With the reclamation occurring immediately after project completion, the naturalness and noticeable human impact would be temporarily impacted within a smaller ground surface area than the proposed action.

Protective/Mitigation Measures: None.

No Action Alternative Direct and Indirect Impacts: With no changes in the area, there would be no disturbance to lands with wilderness characteristics and no impacts to the resource. Protective/Mitigation Measures: None.

3.6 CUMULATIVE IMPACTS SUMMARY

3.6.1 Cumulative Impacts Cumulative impacts for each resource are summarized below. The impacts for a majority of these resources would most likely escalate if the mining operation were to go into development in the future.

1. Air Quality a. Proposed Action – The emissions generating activities associated with this alternative are not expected to contribute to cumulative area or regional air quality concerns. The primary pollutant of concern for the region is particulate matter, and these emissions are far below CDPHE permitting thresholds for land disturbance activities and are summarily dismissed as having any potential for significance. Although significance thresholds have not been established for GHG emissions the emissions for this alternative are exceptionally low (i.e. on the order of typical annual household emissions with Colorado), and we are dismissed as having a significant contribution to any climate change potential. b. Alternative 1 – Same as the proposed action.

2. Soils Past actions, such as grazing, existing road system, recreation, and OHV use, have affected soils resources within the watershed because of soil grading, compaction, erosion, and runoff. Future recreational activities, maintenance work, grazing, and other past activities would continue to impact soil resources in the watershed. The proposed new activities would contribute a minor increment to the total past, present and reasonably foreseeable future actions affecting soil resources

a. Proposed Action – The combined adverse effects of past, present, and reasonably foreseeable actions on soils resources would be minimal and local. b. Alternative 1 – Same as the proposed action. c. No Action – The overall cumulative effects on soils resources from the No Action Alternative, in combination with past, present, and reasonably foreseeable future actions would be local and negligible.

3. Water Cumulative effects on water resources and hydrologic functioning are discussed at the fifth- level field (HUC-10) watershed in order to capture the effects on streams and soils without focusing too specifically or too broadly as to overemphasis the impacts or miss them entirely. The cumulative effects are the sum of existing impacts, project related impacts and foreseeable future impacts. Past and present uses alter the watershed within the analysis area. Past measurable detrimental impacts to water quality, floodplain and hydrologic functioning are associated with roads and road maintenance, OHV use, livestock grazing, fuels reduction projects, agricultural activities, and water supply infrastructure (wells, diversions, etc.), which would still exist on the watershed. Roads are probably the largest contributor of sediment to ephemeral/intermittent streams on BLM administered lands. a. Proposed Action – This will have additional minor cumulative effect when added to the other stressors in this watershed. Application of mitigation measures would reduce cumulative impacts on the watershed. b. Alternative 1 – Same as the proposed action. c. No Action – Project related disturbances would no longer be included in the cumulative effects and the effects should lessen, compared to the Proposed Action and Alternative-1.

4. Invasive Plants The general area is modified due to the presence of a railroad, highway, nearby developed recreation site and existing private quarry. There are noxious weeds in the area on BLM and private lands. a. Proposed Action – It is not expected that this action will have any cumulative impacts related to invasive species if proposed reclamation procedure and above mitigation measures are followed. b. Alternative 1 – Same as the proposed action.

5. Vegetation The surrounding area is encumbered by an active quarry, railroad, highway and developed recreation. a. Proposed Action – Cumulative impacts related to this project would be negligible as long as the reclamation plan associated with the project is followed. b. Alternative 1 – Same as the proposed action.

6. Wildlife, Terrestrial The cumulative impacts of the proposed exploration are minimal.

If there is a potential for a future mining operation, based on favorable results from the proposed action, then there may be escalated impacts. Direct impacts resulting from a full scale mining effort may have additional impacts, but will be analyzed separately. 51

7. Migratory Birds The cumulative impacts of the proposed exploration are minimal.

8. Paleontological Resources Although the project area does not contain any known fossil resources, there is a possibility that ground disturbing work in the area may uncover fossil resources. Adverse significant impacts to paleontological resources can be reduced to a negligible level through mitigation of ground disturbing activities. It is possible that the proposed project would have the beneficial impact that ground disturbance activities might result in the discovery of important fossil resources.

9. Visual Resources Past actions including a quarry operation on private land, recreation site development, railroads and highway construction have all led to visual impacts and contrasts with the natural environment. The proposed action would have negligible contribution to cumulative visual resources.

10. Wilderness Characteristics a. Proposed Action – In the entire Echo Canyon unit identified as having lands with wilderness characteristics, evidence of past human activity such as mining tailing piles and prospecting pits, a water catchment, mechanical vegetation treatments, and wildlife exclosures is noticeable and dispersed throughout the unit. Past actions within the general proposed action area including a quarry operation on adjacent private land, recreation site development, adjacent railroad operations, and nearby highway construction have all led to some minor impacts to the naturalness and opportunities for solitude within the unit. The proposed exploration project introduces motorized equipment for the construction activity, temporary access routes, and temporary exploration pads that expands onto this remote section of BLM public land which may cumulatively further contribute to additional impacts. However, with the implementation of the proposed reclamation efforts after the project, it is anticipated the area would return to a natural state in approximately 3-5 years. Therefore, the actions related to the proposed action, when combined with past and future actions, would have a negligible contribution to overall impacts to the lands with wilderness characteristics in this area.

If there is a potential for a future mining operation, based on favorable results from the proposed action, then impacts to lands with wilderness characteristics would depend on the production plan. Structures, roads and changes to the contour of the surrounding landscape associated with this activity could be introduced at high or low levels, potentially creating impacts to naturalness so great that changes to the unit boundary may be necessary to exclude these impacts. An extensive production operation with high levels of impact could potentially exclude approximately 862 acres of the land identified as having wilderness characteristics. The size of any exclusion area however, will ultimately depend on the scale of a submitted final 52

production plan. As production in the project area would only extend to the buffer edge, the overall effect on the naturalness of the area is unknown at this time. Any potential effects from a possible future quarry expansion project would need to be evaluated through the appropriate NEPA process. b. Alternative 1 – Same as the proposed action.

3.6.2 Reasonable and Forseeable El Paso, Fremont, and Pueblo Counties supply over 80-percent of the construction aggregate mineral resources used in southeastern Colorado, a lot of which is found in hardrock resources located on BLM land.

1. If this proposal is approved: a. Favorable results of the sampling effort would possibly lead to the preparation of an area-specific mine and reclamation plan to extract these hardrock aggregate resources. Based on this scenario, local and regionally expected aggregate material supply chains dependent on this resource would continue or even be increased. The complete extent of the mine plan is unknown until the results of the sampling effort are known and a proposal is submitted by the applicant. Supplemental and into the future: i. Aggregate resources would continue to be transported by an existing rail line to reach end users. ii. Over the road transport from areas outside of the regional markets would be reduced, because the demand could be fed by this potential resource via rail instead. b. For the purpose of analysis, it is assumed that some level of aggregate mining is a possibility, and not directly connected to the action being considered. c. Submittal of a mine plan by the applicant is a possibility.

2. If this proposal is not approved: a. The inability to comprehensively characterize the rock formation will result in finite reserves being confined to the private property. Supplemental and into the future: i. Aggregate resources would still be needed and therefore additional aggregate supplies would be transported from areas outside of the regional markets via truck to meet demand. ii. Another resource area would need to be assessed and sampled for aggregate potential, in order to move forward with a potential mining and reclamation plan. Most likely, other possible sites that may be used to obtain aggregate would involve truck traffic and not an existing rail line.

CHAPTER 4 - CONSULTATION AND COORDINATION 4.1 LIST OF PREPARERS AND PARTICIPANTS

Please see Interdisciplinary Team Review list for BLM Participants

4.2 TRIBES, INDIVIDUALS, ORGANIZATIONS, OR AGENCIES CONSULTED

• Colorado Parks & Wildlife • Division of Reclamation, Mining and Safety • Fremont County • Rocky Mountain Bighorn Society • Wild Connections • Wild Sheep Foundation CHAPTER 5 – REFERENCES

Etchberger, R. C., P. R. Krausman, and R. Mazaika. 1989. Mountain sheep habitat characteristics in the Pusch Ridge Wilderness, Arizona. The Journal of Wildlife Management 53(4). 1- 14.

Keller, B.J. and L.C. Bender. 2007. Bighorn Sheep Response to Road-Related Disturbances in Rocky Mountain National Park, Colorado. Journal of Wildlife Management 71:2329-2337.

Leslie, D. and C. Douglas. 1980. Human disturbance at water sources of desert bighorn sheep. Wildlife Society Bulletin 8(4), 284-290. 1980.

MacArthur, R., V. Geist, and R. Johnston. 1892. Cardia and behavioral responses of mountain sheep to human disturbance. The Journal of Wildlife Management 46: 351-358.

Mackie, R. J., D. E. Pac, K. L. Hamlin, and G. L. Dusek. 1998. Ecology and management of mule deer and whitetailed deer in Montana. Montana Fish, Wildlife and Parks, Wildlife Division, Helena, Montana. 180pp.

Northrup J. M., C. R. Anderson, G. Wittemyer. 2015. Identifying spatial habitat loss from hydrocarbon development through assessing habitat selection patterns of mule deer. Global Change Biology 21: 3961–3970.

Papouchis, C.M., F.J. Singer, and W.B. Sloan . 2001. Responses of Desert Bighorn Sheep to Increased Human Recreation. Journal of Wildlife Management 65:573-582.

Sawyer, H., R.M. Nielson, F. Lindzey, and L.L. Mcdonald. 2006. Winter Habitat Selection of Mule Deer Before and During Development of a Natural Gas Field. Journal of Wildlife Management 70:396-403.

Skovlin, J. M. 1982. Habitat requirements and evaluations. Pages 369-413 in J. W. Thomas and D. E. Toweill, editors. Elk of North America. Stackpole Books, Harrisburg, Pennsylvania. 698pp.

U.S. Census Bureau, 2016a. Table PEPSR6H: Annual Estimates of the Resident Population by Sex, Race, and Hispanic Origin for the United States, States, and Counties: April 1, 2010 to July 1, 2015. 54

Release date June 2016. U.S. Census Bureau, Population Division. Accessed June 23, 2016 from: http://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml

U.S. Census Bureau, 2016b. 2015 Poverty and Median Household Income Estimates - Counties, States, and National. Release date December 2016. U.S. Census Bureau, Small Area Income and Poverty Estimates Program. Accessed 12-29-2016 from http://www.census.gov/did/www/saipe/data/statecounty/data/2015.html

U.S. Census Bureau, 2016c. 2011-2015 American Community Survey 5-Year Estimates, tables B02001: Race; B03002: Hispanic or Latino Origin by Race; B17021: Poverty Status of Individuals in the Past 12 Months by Living Arrangement. Release date December 2016. Accessed 6/28/2017 from: http://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml

Wood, A. K. 1988. Use of shelter by mule deer during winter. Prairie Naturalist 20:15-22.

Finding Of No Significant Impact (FONSI)

Parkdale Area Mineral Materials Sampling DOI-BLM-CO-F020-2016-0083 EA

Based on review of the EA and supporting documents, I determined that the project is not a major federal action and will not have a significant effect on the quality of the human environment, whether considered individually or cumulatively with other actions in the general area. No environmental effects from any alternative assessed or evaluated meet the definition of significance in context or intensity, as defined by 43 CFR 1508.27. Therefore, an environmental impact statement is not required. This finding is based on the context and intensity of the project as described below:

RATIONALE:

Context: The proposed action of conducting exploration activities via access by ground was selected. The proposed exploration would disturb approximately 12.5 acres and is located in Parkdale, just west of Canon City, in Fremont County. This parcel predominately consists of steep and rocky terrain, located within a dry, upland located in the Arkansas River watershed.

This action was initiated when BLM received an application in 2016 from Martin Marietta to obtain mineral materials in an area north of their active mine site in Parkdale. With this application, the company also requested BLM approval to conduct sampling efforts to better understand the rock formation characteristics before moving forward with any larger scale action. Therefore, BLM prepared an Environmental Assessment (EA) to analyze only the sampling of mineral materials on federally managed estate in Fremont County, Colorado.

The proposed action will have impacts on a local and regional scale, involving supply and demand of construction aggregate materials.

Intensity: I have considered the potential intensity/severity of the impacts anticipated from the Parkdale Area Mineral Materials Sampling decision relative to each of the ten areas suggested for consideration by the CEQ. With regard to each:

Impacts that may be beneficial and adverse: Through the environmental analysis, it has been shown that there is some potential for minimal impacts to air, soils, water, invasive plants and wildlife. However through implementation of the proposed project actions and identified mitigation measures, the action is not expected to result in an adverse impact to the human and natural environment.

A summary of beneficial impacts associated with the proposed action:

1. In order to meet future demands in Southern Colorado, and neighboring states that do not have readily accessible aggregate reserves, the applicant is focused on the long term vision for maintaining uninterrupted supplies of construction aggregate and railroad ballast. Demand for these mineral resources is tied to population density, and the economic impacts associated with their extraction and use are usually most significant within approximately 50 miles of the extraction site for sites served by truck transportation. However, that distance can increase to 250 or more miles for transportation utilizing rail. 2. If the sampling efforts are favorable and the applicant still wants to move forward with mining efforts, the BLM parcel being considered for sampling efforts is ideal, because it is located adjacent to an existing operation on private property and is serviced by an operational rail line.

Public health and safety: The proposed action will not have significant impacts to public health and safety, given the nature of the activity. In addition, these concerns are addressed during exploration operations through the administrative and engineered controls outlined with this EA and other permits/authorizations, such as the Division of Reclamation, Mining and Safety.

Unique characteristics of the geographic area: The EA evaluated the area of the Proposed Action and determined that no unique geographic characteristics such as wild and scenic rivers, prime or unique farmlands, areas of critical environmental concern or designated wilderness areas or wilderness study areas, were present.

Degree to which effects are likely to be highly controversial: The potential for controversy associated with the effects of the proposed action on resource values is low. There is no disagreement or controversy among ID team members or reviewers over the nature of the effects on the resource values on public land by the proposed action.

Degree to which effects are highly uncertain or involve unique or unknown risks: The exploration and extraction of mineral materials has occurred in this area throughout the past few decades and although the potential risks involved can be controversial, they are neither unique nor unknown. The proposed operation consists of industry standard practices, resulting in impacts that would normally be expected from an activity being accomplished in compliance with current standards and regulations and based on sound practices. Due to the nature of the proposed operation, there is low potential of unknown or unique risks associated with this project.

Consideration of whether the action may establish a precedent for future actions with significant impacts: There are no aspects of the current proposal that are precedent setting, as decisions such as this one have previously been made and will continue to be made by BLM officials regarding responsible minerals exploration on public lands. Implementation of the proposed project will be in accordance with standard practices that are consistent with other allowable operations involving BLM managed surface. The decision is within the scope of the governing Resource Management Plan and is not expected to establish a precedent for future actions. The decision does not represent a decision in principle about a future consideration.

Consideration of whether the action is related to other actions with cumulatively significant impacts: 1. Cumulative impacts for each resource are summarized below. The impacts for a majority of these resources would most likely escalate if the mining operation were to expand and go into development on the BLM in the future. a. With implementing mitigation measures, there will be minimal to no impact for air, soils, water, invasive plants, vegetation, terrestrial wildlife, migratory birds, paleontological resources and visual resources. b. The proposed exploration project introduces motorized equipment for the construction activity, temporary access routes, and temporary exploration pads that expands onto this remote section of BLM public land which may cumulatively further contribute to additional impacts. However, with the implementation of the proposed reclamation efforts after the project, it is anticipated the area would return to a natural state in approximately 3-5 years. Therefore, the actions related to the proposed action, when combined with past and future actions, would have a negligible contribution to overall impacts to the lands with wilderness characteristics in this area. 2. Reasonable and Foreseeable a. If this proposal is approved:: i. Favorable results of the sampling effort would possibly lead to the preparation of an area-specific mine and reclamation plan to extract these hard rock aggregate resources. Based on this scenario, local and regionally expected aggregate material supply chains dependent on this resource would continue or even be increased. The complete extent of the mine plan is unknown until the results of the sampling effort are known and a proposal is submitted by the applicant. Supplemental and into the future: 1. Aggregate resources would continue to be transported by an existing rail line to reach end users. 2. Over the road transport from areas outside of the regional markets would be reduced, because the demand could be fed by this potential resource via rail instead. ii. For the purpose of analysis, it is assumed that some level of aggregate mining is a possibility, and not directly connected to the action being considered. iii. Submittal of a mine plan by the applicant is a possibility.

b. If this proposal is not approved: i. The inability to comprehensively characterize the rock formation will result in finite reserves being confined to the private property. Supplemental and into the future: 1. Aggregate resources would still be needed and therefore additional aggregate supplies would be transported from areas outside of the regional markets via truck to meet demand. 2. Another resource area would need to be assessed and sampled for aggregate potential, in order to move forward with a potential mining and reclamation plan. Most likely, other possible sites that may be used to obtain aggregate would involve truck traffic and not an existing rail line.

UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF LAND MANAGEMENT ROYAL GORGE FIELD OFFICE

DECISION RECORD Parkdale Area Mineral Materials Sampling DOI-BLM-CO-F020-2016-0083 EA

DECISION: It is my decision to authorize the Proposed Action as described in the attached Environmental Assessment (EA).

The Proposed Action involves conducting sampling efforts, to better understand the rock formation characteristics, on BLM managed land and minerals in an area located directly north and adjacent to a private quarry that is currently in operation northwest of Parkdale, Colorado.

The subject parcel (including a 568 acre buffer area around the perimeter) consists of approximately 1,430-acres, with the proposed sample borings and ground access routes consisting of approximately 12.5 acres of disturbance.

This decision is contingent on meeting all mitigation measures and monitoring requirements listed in this decision.

The primary mechanisms the BLM used to identify potential issues were (1) scoping by posting this project on the National ePlanning website, (2) issuing multiple press releases, (3) holding a 14-day scoping comment period, and (4) holding a 30-day comment period for the Draft EA document. In addition to BLM’s scoping actions, the applicant has conducted extensive outreach efforts via email, phone, meetings, etc.

Comments were received during both the scoping and Draft EA public comment periods. The comments included general concerns regarding air quality, noise, animal well-being, water quality and socioeconomics. In addition, requests for close coordination during the entire process were also received.

BLM RGFO completed an Environmental Assessment and reached a Finding of No Significant Impact, as the selected alternative will have no significant effect. Therefore, an EIS will not be prepared.

RATIONALE: The mineral materials sampling effort is in an area that would be key in location, if the sampling results are favorable, for providing construction aggregate material in both local and regional markets.

BLM’s consideration included the need for local and regional business interests to characterize potential reserves that will assist with a broader understanding of aggregate supplies in the future and that this proposal will not have a significant effect on the quality of the human environment. 60

MITIGATION MEASURES\MONITORING:

1. Soils – a. Clean and inspect all construction equipment prior to use. b. If required, minimize clearing of vegetation to the greatest extent possible. c. Install erosion nets, wattles, straw bales or other mechanical sediment control measures to provide surface soil stability where necessary. d. Remove any structure installed during exploration and construction activities to restore natural drainage during the cleanup and restoration phase of the project. e. Implement final erosion control and site restoration measures as soon as a particular area is no longer needed for construction, stockpiling, or access. Arrange clearing schedules to minimize exposure of soils. f. Cuts and fills for the new access roads will be sloped to facilitate revegetation. g. Do not place soil or rock stockpiles, excavated materials, or excess soil materials near sensitive habitats, including water channels, wetlands, riparian areas, and on native or naturally occurring vegetation. h. In addition, apply all mitigation and protective measures indicated under Section 2.2.1 to reduce soil disturbance and erosion.

2. Water – a. Minimize the amount of soil disturbance, use designated access roads, and leave vegetation on the ground as much as possible during construction of access road and other project activities. b. Maintain construction equipment according to the manufacturer’s specifications and contain and store other potentially hazardous materials appropriately. c. Construction personnel would follow appropriate procedures to protect against potential petroleum or hazardous material spills. d. Conduct good maintenance of equipment and containment of fuels and other potentially hazardous materials to minimize the potential for a release of these fluids into groundwater and surface water resources. Hazardous spill plan would be required and clean-up materials would be on-site at all times. e. Complete the project when site conditions are mostly dry. f. Apply mitigation measures indicated in the soils section and Section 2.2.1 to protect water resources.

3. Invasive Plants – a. Wash all equipment prior to moving into project area in order to remove any weed seeds that may remain on equipment from prior locations. b. Monitor project area for the presence of noxious weeds (invasive species) until reclamation is deemed successful by BLM staff. If any weeds are found, applicant would be required to effectively control weeds associated with the project until reclamation is successful. BLM chemical pest control policy must be followed when treating weeds (contact RGFO noxious weed coordinator).

4. Wildlife, Terrestrial –

Appendix A

6.1 BLM RESPONSES TO COMMENTS

6.1.1 SCOPING PERIOD, 06/05/2017 – 06/20/2017

Scoping Comments Mineral Materials Exploration Sampling, Parkdale, CO DOI-BLM-CO-200-2016-0083 EA

# Comment

Both sampling and potential mining activities in this area threaten important tourist activities and the dollars that they bring in to our county. Mining in this area would destroy scenic beauty and any erosion could damage trout 1 habitat. Even if there is mitigation, such runoff could occur in the case of a cloudburst or heavy rainfall. Highway 50 is very heavily traveled. Truck traffic from the existing quarry creates a danger on the road. Additional 2 heavy machinery traffic would compound the problem. BLM is encouraged to analyze potential impacts AND habitat enhancement opportunities (on-site AND off-site) to 3 bighorn sheep habitat in/near the project area from exploratory and subsequent development activities. BLM is encouraged to closely coordinate with CO Parks & Wildlife (CPW) staff in evaluating potential impacts to bighorn sheep, while also identifying habitat enhancement opportunities (e.g., prescribed burning, P-J treatments, 4 noxious weed control, water development, etc.) on/near Cactus Mountain. The Wild Sheep Foundation (WSF) and their Colorado affiliate, the Rocky Mountain Bighorn Society (RMBS), are very interested in collaborating with the BLM, CPW, Martin Marietta Materials, and other stakeholders in 5 enhancing habitat conditions for bighorn sheep on/near this project site. It is requested that the BLM thoroughly analyze potential impacts of proposed actions to the local bighorn sheep 6 population in the Cactus Mountain area and nearby Bighorn Sheep Canyon. It is suggested that the BLM and Martin Marietta Materials coordinate closely with CPW to identify opportunities for bighorn sheep habitat enhancement both on the proposed project site as well as off-site locations. Importantly, CPW has identified a bighorn sheep travel corridor between Bighorn Sheep Canyon and Royal Gorge which 7 should be protected, and enhanced if possible. The RMBS is very interested in working with Martin Marietta Materials, BLM, and CPW to enhance bighorn 8 sheep habit in the project area and surrounding area. Table Mountain is a proposed Wilderness Area (Citizens proposed) - We therefore request that the developer and 9 BLM first and foremost consider alternate locations for mineral materials sampling and sales. BLM must defer the project while the Eastern Colorado RMP revision is ongoing - mineral materials exploration at this time would undermine the ongoing RMP revision by foreclosing management alternatives that might 10 otherwise protect the natural resource values of the area: See NEPA reference If BLM does not defer the project, preparation of an EIS for the exploration is required. These unique characteristics of the area make the proposed action controversial and therefore warrant thorough environmental 11 review and consideration of the full mitigation hierarchy through an EIS. BLM must utilize the full mitigation hierarchy in evaluating the proposed action, summarized as avoid, minimize and compensate. BLM must analyze and apply mitigation requirements to the proposed exploration activities, not defer mitigation to any larger scale action. We emphasize that onsite mitigation measures (minimization measures) cannot prevent loss of important resources, including particularly the wilderness values of the Table Mountain 12 area. Therefore, BLM must evaluate compensatory mitigation for this project.

6.1.2 DRAFT EA COMMENT PERIOD, 12/13/2017 – 01/12/2018

Draft EA Comments Mineral Materials Exploration Sampling, Parkdale, CO DOI-BLM-CO-200-2016-0083 EA

EA # Document Comment Response Edi ts This Draft Environmental Analysis was prepared to analyze a proposal to drill nine boreholes for sample collection, in order to better understand the formation characteristics. If the proponent 1 Sampling is obviously a preliminary to mining. determines that the results of the sampling effort are favorable, then they may submit a mining proposal at that time. This action would prompt a new Environmental Analysis to be prepared. None

This Draft Environmental Analysis was prepared to analyze a proposal to drill nine boreholes for sample collection, in order to Mining in the near vicinity threatens damage to both environmental and better understand the formation characteristics. If the proponent financial interests (This area is vitally close to the Arkansas River. A world- 2 determines that the results of the sampling effort are favorable, then class trout fishing area, prime recreational resource for Fremont County and a they may submit a mining proposal at that time. This action would major source of water for agricultural irrigation to multiple states.) prompt a new Environmental Analysis to be prepared. Please note that potential impacts to both environmental and financial interests are analyzed for the proposed action during the NEPA process. None We fear that the core drilling will lead to further expansion of the gravel pit. If 3 they are not planning on mining the mountain, there is no need for them to do core sampling on public lands. Comment noted. None Drilling and expansion of the gravel pit would greatly influence the peace and 4 tranquility that we have savored being adjacent to BLM. Comment noted. None This proposal has been thoroughly analyzed by multiple resource specialists. The operator will implement the resource specialist's recommendations and adhere to all applicable regulations and laws, therefore resulting in minimal impacts to the surrounding When you are drilling 300 feet deep you will possibly be hitting the aquifers 5 environment. Water will be used when drilling the boreholes. Once that supply our domestic water and thus killing our land values. the core samples have been collected and logged, the borehole will be abandoned in accordance with State regulations specific that process. Please see section 3.2.3 for additional details specific to water resources. None This Draft Environmental Analysis was prepared to analyze a proposal to drill nine boreholes for sample collection, in order to better understand the formation characteristics. If the proponent determines that the results of the sampling effort are favorable, then they may submit a mining proposal at that time. This action would Air quality is another concern as well as noise pollution, if the gravel pit 6 prompt a new Environmental Analysis to be prepared. Please note would expand onto public lands. that potential impacts to both air quality and noise pollution are analyzed for the proposed action during the NEPA process. For this proposal, these resources were analyzed and considered in the EA as not having potentially significant impacts as a result of the proposed action. None As stated in Section 3.3.3. of the EA, bighorn sheep and mule deer will likely be displaced from the work areas while operations are being conducted. However, the action area will return to its original Any consistent drilling and/or mining activity on the mountain will be a functional state quickly due to the short-term duration of the action 7 disruption of wildlife habitat is very much a worry for us in the Cactus and the expected recovery of the site after the implementation of the Mountain area. proposed reclamation plan. Therefore, it is anticipated the long- term impact of the proposed action will be minimal to bighorn sheep and mule deer. None This Draft EA was prepared to analyze a proposal to drill nine boreholes for sample collection, in order to better understand the Expansion of the gravel pit onto BLM for personal gain of a large corporation formation characteristics. If the proponent determines that the 8 is NOT acceptable. results of the sampling effort are favorable, then they may submit a mining proposal at that time. This action would prompt a new Environmental Analysis to be prepared. None

EA # Document Comment Response Edi ts This Draft Environmental Analysis was prepared to analyze a proposal to drill nine boreholes for sample collection, in order to better understand the formation characteristics. If the proponent determines that the results of the sampling effort are favorable, then they may submit a mining proposal at that time. This action would 9 prompt a new Environmental Analysis to be prepared. Through the later analysis process, the buffer size, and other operational elements, will be analyzed further. The buffer considerations for the I think the buffer area is too narrow to afford protection to those of us living exploration drilling are considered adequate, due to the short term in the Cactus Mountain Subdivision and in the Star Ranch area. length of the proposal. None CPW recommends the proposed Action - Access by Ground. This alternative 10 would be shorter in duration than Alternative 1 and reclamation of disturbed area would begin immediately. Comment noted. None CPW agrees with the finding that the impact area is within both bighorn sheep and deer winter range and recommends a timing limitation restriction 11 precluding all on-site exploration related activities from Nov. 01 to April 15 to lessen, minimize or eliminate disturbance to these species during this critical time period. Comment noted, as it pertains to analysis in section 3.3.3 of the EA. None

This proposal has been thoroughly analyzed by multiple resource specialists. The operator will implement the resource specialist's recommendations and adhere to all applicable regulations and laws, 12 therefore resulting in minimal impacts to the surrounding The proposal to sample Parkdale area hard rock minerals is a proposal that will environment. Due to the limited nature of this action, the proposed result in damage to the environment, tourist industry, and local population of operations will result in negligible impacts (either negative or citizens in Fremont County. positive) to the current social and economic conditions of the area. None This Draft Environmental Analysis was prepared to analyze a proposal to drill nine boreholes for sample collection, in order to better understand the formation characteristics. If the proponent determines that the results of the sampling effort are favorable, then they may submit a mining proposal at that time. This action would 13 prompt a new Environmental Analysis to be prepared. This The negative results of this type of sampling and mining outweigh the proposal has been thoroughly analyzed by multiple resource expected profitability and use of the minerals that have been targeted by the specialists. The operator will implement the resource specialist's proposal. For example, the environmental concerns include fresh water animal, recommendations and adhere to all applicable regulations and laws, fish, bird, and plant species in the area that would be negatively impacted by therefore resulting in minimal impacts to the surrounding soil erosion, machinery, etc. environment. None The local businesses in Fremont county who rely on fishing, boating, hiking, Due to the limited nature of this action, the proposed operations will 14 etc. tourism would be greatly affected by this type of unsightly and result in negligible impacts to the current social and economic environmentally damaging activity. conditions of the area. None This proposal has been thoroughly analyzed by multiple resource specialists. The operator will implement the resource specialist's The subterranean water will be disturbed and potentially cause polluted wells recommendations and adhere to all applicable regulations and laws, 15 which would be easy to monitor as there are well permits and laboratory water therefore resulting in minimal impacts to the surrounding tests that homeowners have on file to show that their wells have pollution free environment. Please see section 3.2.3 for additional details specific water sources. to water resources. None Comment noted. Due to the limited nature of this action, the proposed sampling will result in negligible impacts to the current The end result of this type of underground water and soil disturbance would social and economic conditions of the area. This portion of the 16 open up the BLM, the property owner of the site, and mineral right owner to socioeconomics resource was considered and dismissed in the EA potential lawsuits which would also include the loss of property value to as not having potentially significant impacts as a result of the nearby properties. proposed action. None There will not be issues related to air quality or chemicals as a result of this proposal. Due to the limited nature of this action, the proposed operations will result in negligible impacts to the current 17 There are also issues related to air quality, chemicals, and increased traffic to a social and economic conditions of the area. There will not be narrow highway 50 road area which would cause undue and terrible safety increased traffic and/or safety issues along Highway 50 as a result issues for local residents, emergency responders, and tourists in the area. of this proposal. None

The end result of this is that there are more negatives than positives in 18 relation to this proposal and potential lawsuits in relation to the environmental and property damage as illustrated in the above comment section. There is NOT ONE property owner or resident, or business owner who supports this. Comment noted. None

EA # Document Comment Response Edi ts

An adequate range of alternatives was analyzed with this EA. With regards to the commenter's proposed alternatives, BLM does not intend to directly incorporate them into the analysis. Please see the BLM should evaluate additional alternatives to reduce impacts to lands with following explanations: 1) As the operator proposed the location of wilderness characteristics. Rather than reduce the overall acreage of boreholes in order to adequately assess the deposit characteristics, 19 disturbance in LWC, our preference would be that the agency consider and this is well within the typical industry approach in this alternatives to reduce the extent of impacted acreage in order to preserve the situation, BLM does not intend to arbitrarily reduce the number of Updates largest possible intact LWC area. Specifically, we recommend BLM consider boreholes. 2) Typically, exploration drilling programs already have been alternatives that: 1) reduce the number of drill pads and limit them to the outer incorporate a somewhat phased approach. If the downhole data made to portions of the LWC, such as eliminating Boreholes 7-10; and/or 2) adopt a does not meet expectations, then additional proposed boreholes in Sections phased development approach that begins on the outer portions of the LWC, the area may not be drilled or may be relocated. It would not be 1.2, 2.1 such as only authorizing Boreholes 1 and 3 at this time. efficient or necessary to authorize the boreholes incrementally. and 3.5.1.

Updates have been 20 BLM must release the unsigned FONSI for public review. We believe the As the Draft EA document has already been released for public made to impacts from this exploratory may be significant and thus warrant preparation review and comment, and this isn't a legal requirement in the Section of an Environmental Impact Statement (EIS). process, BLM plans to only release the signed FONSI. 3.5.1.