Status and Habitat of the Dunes at the Proposed Site for the International Isotopes Fluorine Products Facility in Lea County, New Mexico

PREPARED FOR International Isotopes Fluorine Products, Inc.

PREPARED BY

Terry Scarafiotti, Wildlife Biologist

GL ENVIRONMENTAL, INC. P.O. BOX 1746 LAS VEGAS, NM 87701 (505) 454-0830 IIFP Dunes Sagebrush Lizard Survey

Table of Contents

INTRODUCTION ...... 3

M ETHODS ...... 3

R ESULTS ...... 3

S ite D e scrip tio n ...... 3

Dunes Sagebrush Lizard Habitat Description ...... 3

C ONCLUSION ...... 4

PHOTOS AND FIGURES ...... 5

Photo 1. Shortgrass prairie with interm ittent m esquite ...... 6

Photo 2. Shortgrass prairie with interm ittent m esquite ...... 6

Photo 3. Sandy-loam soil type ...... 7

Photo 4. Sandy-loam soil type ...... 7

Photo 5. Dunes sagebrush lizard ...... 8

Photo 6. Dunes sagebrush lizard habitat ...... 8

Figure 1. Expected range of Sceloporus arenicolus...... 9

R EFERENCES ...... 10

GL Environmental, Inc. 2 November 11,2010 IIFP Dunes Sagebrush Lizard Survey

Introduction The purpose of this report is to evaluate the proposed construction site for the International Isotopes Fluorine Products, Inc. (IIFP) facility for the possible presence of the dunes sagebrush lizard (Sceloporus arenicolus). The dunes sagebrush lizard (Sceloporus arenicolus),often called the sand dune lizard, occurs in Lea County, is listed on the State of New Mexico Endangered list, and is a candidate for the federal Endangered Species list (Photo 5). This report will evaluate proposed site's biological features and compare them to the habitat requirements of the dunes sagebrush lizard.

Methods

Field work for this study was conducted on November 1 0 th, 2010. GL Environmental staff conducted a visual walk-through of the proposed IIFP site. Observations were made for habitat comparison required for the sand dune lizard (Sceloporus arenicolus). Photographs of the vegetative type along with the soil type were taken for documentation of the habitat that occurs on the proposed site.

Results

Site Description The proposed site is located in Section 27, Township 18S, Range 36E. The approximate center of the IIFP Site is located approximately at 32"43'N and 103'20'W. The site is approximately 10 miles west of Hobbs, New Mexico on NM Highway 483 and 1 mile north of the Carlsbad Hobbs Highway (US 180).

The proposed site for the IIFP is comprised of a shortgrass prairie with intermittent mesquite (Photos 1 and 2). Shortgrass prairies are comprised of several herbaceous plant-soil associations including side-oats grama (Bouteloua curtipendula), blue grama (Bouteloua gracilis), and buffalograss (Biichloe dactyloides) on well drained soils or rocky slopes and blue grama/hairy grama and (Bouteloua hirsuta) on loamy or sandy soils. The IIFP site contains sandy loam soils (Photos 3 and 4).

Dunes Sagebrush Lizard HabitatDescription The Dunes Sagebrush lizard is endemic to the Shinnery Oak Dune Habitat (Photo 6) and sand blowout areas within the shinnery oak (Sais, 2003).

The dunes sagebrush lizard uses the shinnery oak roots for their burrows. The lizard retreats, to these burrows when threatened or for thermoregulation when the sand becomes too hot or too cold. Individuals predominantly occupy non-vegetated sand dune blowouts and utilize blowouts with particular physical characteristics due to thermoregulatory, reproduction, and foraging requirements (Chan, Fitzgerald, & Zamudio, 2009).

GL Environmental, Inc. 3 November 11, 2010 IIFP Dunes Sagebrush Lizard Survey

According to Charles Painter, herpetologist for New Mexico Game and Fish, the habitat requirements for the dunes sagebrush lizard are as follows:

Sceloporus arenicolus is *a small, terrestrial lizard restricted to sand dune formations inhabited by shinnery oak (). Shinnery oak dunes support dense patches of shinnery oak and scattered sand sage (Artemisiafilifolia) as co-dominant plant species and patches of open sand and wind-created sandy blowouts. Throughout the range in New Mexico and Texas elevation varies from ca. 780-1400 m (ca. 2550-4595 ft). There are significant differences in the composition of sand between sites occupied and unoccupied by S. arenicolus, with occupied sites having slightly coarser sand than unoccupied sites (Painter, 2005).

The habitat needed for S. arenicolus is further described in Amphibians & of New Mexico as "restricted to the vicinity of active and semi-stabilized sand dunes within the Mescalero Sands. These dunes occur to an elevation of 1190 m above sea level and support scattered strands of Quercus havardii and as co-dominant plant species" (Degenhardt, Painter and Price, 1996) . The median sand grain size of 0.201mm was found in these habitats occupied by S. arenicolus.

Photo 6, taken in southwestern Lea County, New Mexico, is an example of the habitat needed to support the dunes sagebrush lizard. Dense vegetation with open sand blowout sites provides the microhabitat needed for the survival of this lizard. Conclusion The lack of the shinnery oak on the proposed location leads to the conclusion that the dunes sagebrush lizard does not exist at this site. The site does not support shinnery oak or have the required sand blowouts which comprise the dune sagebrush lizard's primary habitat. In addition to the lack of appropriate soil types, there are not enough sand particles in the appropriate size range to meet the habitat needs of this species.

The habitat needed for this species is approximately 7 miles south of the proposed site. The lack of the shinnery oak and sand dunes on the proposed location makes it unlikely that the dunes sagebrush lizard exists at this location.

GL Environmental, Inc. 4 November 11, 2010 IIFP Dunes Sagebrush Lizard Survey

Photos and Figures

GL Environmental, Inc. 5 November 11, 2010 IIFP Dunes Sagebrush Lizard Survey

Photo 1. Shortgrass prairie with intermittent mesquite Photo by Terry Scarafiotti

Photo 2. Shortgrass prairie with intermittent mesquite Photo by Terry Scarafiotti

GL Environmental, Inc. 6 November 11, 2010 IIFP Dunes Sagebrush Lizard Survey

Photo 3. Sandy-loam soil type Photo by Terry Scarafiotti.

Photo 4. Sandy-loam soil type Photo by Terry Scarafiotti.

GL Environmental, Inc. 7 November 11, 2010 IIFP Dunes Sagebrush Lizard Survey

Photo 5. Dunes sagebrush lizard Photo by Michael T. Hill.

Photo 6. Dunes sagebrush lizard habitat Photo by Don Sias.

GL Environmental, Inc. 8 November 11, 20 10 IIFP Dunes Sagebrush Lizard Survey

Figure 1. Expected range of Sceloporus arenicolus

0 10 20 40 60 60 L--ý -IIMiles 0 125 25 so 75 Ion ,Ilometer•

Expected Range of the Sand Dune Lizard Sceloporus arenicolus

GL Environmental, Inc. 9 November 11,20 10 UlP Dunes Sagebrush Lizard Survey

References

Biota Information System of New Mexico (BISON). (2009, August 26). Retrieved from http://www.bison-m.org/reports.aspx?rtype= 13&status=%27201%27,%27202%27.

Degenhardt, W, Painter, C, & Price, A. (1996). Amphibians & Reptiles of New Mexico. Albuquerque: University of New Mexico Press. Chan, L, Fitzgerald, L, & Zamudio, K. (2009). The scale of genetic differentiation in the dunes sagebrush-I izard. Conservation Genetics, 10: 131-142. Retrieved from http://herpetology.tamu.edu/Fitzgerald/Fitzgeraldfi les/ChanFitzgeraldZamudio%2OSa renicolus%20ConsGen2009.pdf doi: DOI 10.1007/s 10592.

Painter, C. (2005). Conservation of the sand dune lizard. Retrieved from http://www.wildlife. state.nm. us/conservation/habitathandbook/documents/SandDuneLizardRecom mendatio ns.

Sias, D.S. 2003. The status of the sand dune lizard, Sceloporus arenicolus and its habitat in Eddy County, New Mexico on CBS Operating Corporation leases northeast of Loco Hills. Submitted to the Bureau of Land Management (Carlsbad office) andCBS Operating Corpration. CBS Operating Corp., 300 W Louisiana, STE.200, P.O. Box 2236, Midland, TX 79702.

GL Environmental, Inc. I0 November H, 20 10 November 29, 2010

Department of the Army Albuquerque District Corp of Engineers Las Cruces Regulatory Office Mr. Richard Gatewood 505 South Main Street, Suite 142 Las Cruces, NM 88001

Las Cruces, NM

RE: Waters of the U.S. Determination

Dear Mr. Gatewood:

The purpose of this letter is to request that the United States Army Corp of Engineers (USACE) determine whether "Waters of the United States" are present in Section 27, Range 18 S, Township 36 E in Lea County New Mexico. Section 27 is located at 654,538 E, 3,622,095 N (UTM, NAD 83, Zone 13) or approximately 10 miles west of Hobbs, NM (See Map I). A USACE Approved Jurisdictional Determination Form and 3 maps are attached to this letter.

International Isotopes Fluorine Products plans to construct and operate a facility on 40 acres of land within Section 27 (640 acre total). The facility will utilize depleted uranium hexafluoride to produce high purity inorganic fluorides, uranium oxides, and anhydrous hydrofluoric acid. The fluoride gas products and anhydrous hydrogen fluoride will be sold for various industrial applications.

Surface Drainage Two small intermittent drainages are located on the southwest quadrant of Section 27 (Map 2). Base flow conditions were not observed within the drainages during an October 23, 2010 site visit. Surface flows most likely occur in response to precipitation events. The drainages grade to the southeast and coalesce approximately 1,300 ft south of the section boundary. The western drainage is clearly defined on Section 27 due to a moderately incised channel and the presence of Honey Mesquite (Prosopis glandulosa) bushes along the banks. The drainage to the east is shallow and not easily delineated from the surrounding land surface.

The coalesced drainage continues to grade to the south / southeast toward Monument Draw. Monument Draw is a major surface drainage feature in southern Lea County and is clearly present in topographical maps approximately 14 miles southeast of the section boundary. Although the drainage present in Section 27 grades toward Monument Draw, a review of Page 2. IIFP USACE Jurisdictional Determination

topographic maps did not reveal a clear physical connection to Monument Draw. The drainage terminates in a playa approximately 8 miles southeast of the section (Map 3).

Surface Depressions Small surface depressions are located throughout Section 27. Several of the most substantial depressions are identified on Map.2. The depressions tend to be circular in shape and range from 50 ft to 300 ft in diameter and 3 ft to 5 ft in depth below the surrounding grade. The depressions occasionally fill with water in response to precipitation events. The depressions were dry during the October 23, 2010 site visit. The frequency and duration of sWrface water in the depressions is unknown, however, it is likely that water or saturated conditiions are present for less than 10% of the year. . ...:,... :..

A change from the surrounding vegetation comimunity occurs iidthin the surface depressions. Vegetation within the depressions is doniinar"&'d by the perennial grasses Burro grass (Scleropogon brevifohius) and Galleta Grass.i, P.euraphis jamesi). N&Fiher plant species are included in the National List of Vascular Plant S iesethat:Qccur in WetiWds." 1996 National Summary. Vine Mesquite (Panicumrnobtusum), Wegt"r;..•-,w&ieatgrass (Pascoyri~in smithii), and Blueweed (Helianthus cilaris) were pr&'nt .at low defisiýies (<5% of areal herbaceous cover). Each of these three species are describd'as 'eithir,,FAC or FAG- in the National List.

A soil core was collectOo.-tntwo of the'd"eeper dep, i~eons on Section 27. Each of the cores was approximately ): inches in depth. The s6ilcod4jsed of dark brown sandy to silty loam with some organic matter. N' iottlng,6:sulfidic myaftiýal was observed in the cores.

It is the bpinion of GL Enivironmental, Inc. that waters of the U.S are not present in Section 27. Surface draiiage flows are :infrequeint,' l:jow volume and short in duration. Additionally, the drainage is not"connected throiigh surface.*"channels to regional surface water features. Surface depressions are not:-'domimated by wetland plants, lack indicators of anoxic soil conditions, and most likely are notfaturated f;.,more than 10% of the year. The surface depressions lack the characteristics of a wetla'nds ais defined in the Corps of Engineers Wetlands Delineation Manual, January 1987. GL Envir6nmfental, Inc. seeks concurrence from the USACE that any water features on Section 27 are isolated and "Waters of the U.S." are not present within Section 27.

If you have any questions regarding this submittal or require further information please contact me at (505) 454-0830.

Sincerely,

Matthew Lane Page 2. IIFP USACE Jurisdictional Determination

GL Environmental, Inc.

Enclosures: Maps 1-3, USACE Approved Jurisdictional Determination Form

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UTM, NAD 83, Zone 13 International Isotopes Fluorine Products AN November 23, 2010 Section 27, Township 18 S, Range 36 E Map 1 0 25 50 100 Miles 1 I I I I I I I I 664400 " 654800'0"" 655200 •,' 655600"1") 656000

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UTM, NAD 83, Zone 13 International Isotopes Fluorine Products A November 23, 2010 Section 27, Township 18 S, Range 36 E Map 2

Section 27 Boundary IIFP Facility Boundary 0 500 1,000 2,000 Feet Surface water drainage feature Depressions I I I I I I I I I

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N UTM, NAD 83, Zone 13 International Isotopes Fluorine Products November 23, 2010 Section 27, Township 18 S, Range 36 E Map 3

- Section 27 Boundary E playa 0 1 2 4 Miles I i , I I i a I -Surface water drainage feature LI] IIFP Facility Boundary I I I I I I I I -- Monument Draw APPROVED JURISDICTIONAL DETERMINATION FORM U.S. Army Corps of Engineers

This form should be completed by following the instrctions provided in Section IV of the JD[Form Instructional Guidebook.

SECTION I: BACKGROUND INFORMATION A. REPORT COMPLETION DATE FOR APPROVED JURISDICTIONAL DETERMINATION (3iD):

November 29, 2010

B. DISTRICT OFFICE, FILE NAME, AND NUMBER:CESWF-PER-R,

International Isotopes Fluorine Products Facility

C. PROJECT LOCATION AND BACKGROUND INFORMATION: ######

State: New Mexico County/parish/borough: Lea City: 10 Miles west of Hobbs Center coordinates of site (lat/long in degree decimal format): Lat. 32.725820 N, Long: -103.35087' LW. Universal Transverse Mercator: 3,622,095 N, 654,538 E, (NAD 83, Zone 13) Name of nearest waterbody: Monument Draw Name of nearest Traditional Navigable Water (TNW) into which the aquatic resource flows: NA Name of watershed or Hydrologic Unit Code (HUC): 12080003 0 Check if map/diagram of'review area and/or potential jurisdictional areas is/are available upon request. O Check if'other sites (e.g., offsite mitigation sites, disposal sites, etc...) are associated with this action and are recorded on a different JD form.

D. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT APPLY): 10 Office (Desk) Detennination. Date: November 29, 2010 ID Field Determination. Date(s): October 16, 2010

SECTION II: SUMMARY OF FINDINGS A. RHA SECTION 10 DETERMINATION OF JURISDICTION.

There X.jný "navigahle waters of he U.S." within Rivers and Harbors Act (RI-IA) jurisdiction (as detined by 33 CFR part 329) in the review area. [Required] O Waters subject to the ebb and flow of the tide. Q Waters are presently used, or have been used in the past, or may be susceptible for use to transport interstate or foreign commerce. Explain:

B. CWA SECTION 404 DETERMINATION OF JURISI)ICTION.

There Aien "waters of the U.S" within Clean Water Act (CWA).jurisdiction (as defined by 33 CFR part 328) in the review area. [Required]

1. Waters of the U.S. a. Indicate presence of waters of U.S. in review area (check all that apply): O TNWs, including territorial seas Wetlands adjacent to TNWs Relatively permanent waters2 (RPWs) that flow directly or indirectly into TNWs 0 Non-RPWs that flow directly or indirectly intoTNWs Wetlands directly abutting RPWs that flow directly or indirectly into TNWs Wetlands adjacent to but not directly abutting RPWs that flow directly or indirectly into TNWs O] Wetlands adjacent to non-RPWs that flow directly or indirectly into TNWs E3 Impoundments of jurisdictional waters C] Isolated (interstate or intrastate) waters, including isolated wetlands

b. Identify (estimate) size of waters of the U.S. in the review area: Non-wetland waters: linear feet: width (11)and/or NA acres. Wetlands: NA acres.

c. Limits (boundaries) of jurisdiction based on: Pi-kLIjA

Boxes checked below shall be supported by completing the appropriate sections in Section III below. For purposes of this form, an RPW is defined as a tributary that is not a TNW and that typically flows year-round or has continuous flow at least "seasonally" (e.g., typically 3 months). Elevation of established OIWM (if known):

2. Non-regulated waters/wetlands (check if applicable):3 0 Potentially jurisdictional waters and/or wetlands were assessed within the review area and determined to be not jurisdictional. Explain:

Two small intermittent drainages are located on the southwest quadrant of Section 27 (Map 2). Base flow conditions were not observed within the drainages during an October 23, 2010 site visit. Surface flows most likely occur in response to precipitation events. The drainages grade to the southeast and coalesce approximately 1,300 ft south of the section boundary. The western drainage is clearly defined on Section 27 due to a moderately incised channel and the presence of Honey Mesquite (Prosopis glandulosa) bushes along the banks. The drainage to the east is shallow and not easily delineated from the surrounding land surface.

The coalesced drainage continues to grade to the south / southeast toward Monument Draw. Monument Draw is a major surface drainage feature in southern Lea County and is clearly present in topographical maps approximately 14 miles southeast of the section boundary. Although thc drainage present in Section 27 grade toward Monument Draw, a review of topographic maps did not reveal a clear physical connection to Monument Draw. The drainage terminates in a playa approximately 8 miles southeast of the section (Map 3).

Small surface depressions are located throughout Section 27. Several of the most substantial depressions are identified on Map 2. The depressions tend to be circular in shape and range from 50 ft to 300 ft in diameter and 3 ft to 5 ft in depth below the surrounding grade. Several of the larger depressions have been identified on Map 2. The depressions occasionally fill with water in response to precipitation events. The depressions were dry during the October 23, 2010 site visit. The frequency and duration of surface water in the depressions is unknown; however, it is likely that water or saturated conditions are present for less than 10% of the year.

A change from the surrounding vegetation community occurs within the surface depressions. Vegetation within the depressions is dominated by the perennial grasses Burro grass (Scleropogon brevifolius) and Galleta Grass (Pleuraphis jamesii). Neither plant species are included in the National List of Vascular Plant Species that Occur in Wetlands: 1996 National Summary. Vine Mesquite (Panicum obtusum), Western wheatgrass (Pascoyrum smithii), and Blueweed (Helianthus cilaris) were present at low densities (<5% of areal herbaceous cover). Each of these three species are described as either FAC or FAC- in the National List.

A soil core was collected from two of the deeper depressions on Section 27. Each of the cores was approximately 16 inches in depth. The soil consisted of dark brown sandy to silty loam with some organic matter. No mottling or sulfidic material was observed in the cores.

It is the opinion of GL Environmental, Inc. that waters of the U.S are not present in Section 27. Surface drainage flows are infrequent, low volume and short in duration. Additionally, the drainage is not connected through surface channels to regional surface water features. Surface depressions are not dominated by wetland plants, lack indicators of anoxic soil conditions, and most likely are not saturated for more than 10% of the year. The surface depressions lack the characteristics of a wetlands as defined in the Corps of Engineers Wetlands Delineation Manual, January 1987. GL Environmental, Inc. seeks concurrence from the USACE that any water features on Section 27 are isolated and "Waters of the U.S." are not present within Section 27..

Supporting documentation is presented in Section III.F. SECTION III: CWA ANALYSIS

A. TNWs AND WETLANDS ADJACENT TO TNWs

The agencies will assert jurisdiction over TNWs and wetlands adjacent to TNWs. If the aquatic resource is a TNW, complete Section IIl.A.] and Section III.D.I. only; if the aquatic resource is a wetland adjacent to a TNW, complete Sections III.A.I and 2 and Section IlI.D.l.; otherwise, see Section 111.B below.

I. TNW Identify TNW: NA.

Summarize rationale supporting determination:

2. Wetland adjacent to TNW Summarize rationale supporting conclusion that wetland is "adjacent": NA.

B. CHARACTERISTICS OF TRIBUTARY (THAT IS NOT A TNW) AND ITS ADJACENT WETLANDS (IF ANY):

This section summarizes information regarding characteristics of the tributary and its adjacent wetlands, if any, and it helps determine whether or not the standards for jurisdiction established under Rapanos have been met.

The agencies will assert jurisdiction over non-navigable tributaries of'TNWs where the tributaries are "relatively permanent waters" (RPWs), i.e. tributaries that typically flow year-round or have continuous flow at least seasonally (e.g., typically 3 months). A wetland that directly abuts an RPW is also jurisdictional. If the aquatic resource is not a TNW, but has year-round (perennial) flow, skip to Section III.D.2. If the aquatic resource is a wetland directly abutting a tributary with perennial flow, skip to Section III.D.4.

A wetland that is adjacent to but that does not directly abut an RPW requires a significant nexus evaluation. Corps districts and EPA regions will include in the record any available information that documents the existence of a significant nexus between a relatively permanent tributary that is not perennial (and its adjacent wetlands if any) and a traditional navigable water, even though a significant nexus finding is not required as a matter of law.

4 If the waterbody is not an RPW, or a wetland directly abutting an RPW, a JD will require additional data to determine if the waterbody has a significant nexus with a TNW. If the tributary has adjacent wetlands, the significant nexus evaluation must consider the tributary in combination with all of its adjacent wetlands. This significant nexus evaluation that combines, for analytical purposes, the tributary and all of its adjacent wetlands is used whether the review area identified in the JD request is the tributary, or its adjacent wetlands, or both. If the JD covers a tributary with adjacent wetlands, complete Section III.B.! for the tributary, Section Il.B.2 for any onsite wetlands, and Section ilI.B.3 for all wetlands adjacent to that tributary, both onsite and offsite. The determination whether a significant nexus exists is determined in Section IlI.C below.

1. Characteristics of non-TNWs that flow directly or indirectly into TNW

(i) General Area Conditions: Watershed size: Pickkiist Drainage area: TI&k List Average annual rainfall: 14.6 inches Average annual snowfall: 5 inches

(ii) Physical Characteristics: (a) Relationship with TNW: El Tributary flows directly into TNW. [] Tributary flows through Pi- • s~~--tributaries before entering TN W.

Project waters are PRWRZklLAI river miles from TNW. Project waters a river miles from RPW. Project waters are ksi aerial (straight) miles from TNW. Project waters are ,_'__I_ , aerial (straight) miles from RPW. Project waters cross or serve as state boundaries. Explain:

Identify flow route to TNW5: Tributary stream order, if known:

Note that the Instructional Guidebook contains additional information regarding swales, ditches, washes, and erosional features generally and in the arid West. Flow route can be described by identifying, e.g., tributary a, which flows through the review area, to flow into tributary b, which then flows into TNW. (b) General Tributary Characteristics (check all that apply): Tribi~tary is: FI Natural El Artificial (man-made). Explain: El Manipulated (man-altered). Explain:

Tributary properties with respect to top of bank (estimate): Average width: feet Average depth: feet Average side slopes: @RR i,.

Primary tributary substrate composition (check all that apply): C] Silts C Sands rC Concrete F1 Cobbles C Gravel F1 Muck El Bedrock C Vegetation. Type/% cover: El Other. Explain:

Tributary condition/stability [e.g., highly eroding, sloughing banks]. Explain: Presence of run/riffle/pool complexes. Explain: Tributary geometry: Pi ':i i• Tributary gradient (approximate average slope): %

(c) Flow: Tributary provides for: Intrmie ibut. asonaflo Estimate average number of flow events in review area/year: Pe Is• Describe flow regime: Other information on duration and volume: Surface flow is: Pkk-iL. Characteristics:

Subsurface flow: -_ILis•. Explain findings: E] Dye (or other) test performed:

Tributary has (check all that apply): EC Bed and banks EC OHWM 6 (check all indicators that apply): EC clear, natural line impressed on the bank the presence of litter and debris C changes in the character of soil destruction of terrestrial vegetation C shelving El the presence of wrack line C vegetation matted down, bent, or absent Cl sediment sorting EC leaf litter disturbed or washed away C1 scour E] sediment deposition multiple observed or predicted flow events E] water staining abrupt change in plant community E] other (list): El Discontinuous OUIWM. 7 Explain:

If factors other than the OHWM were used to determine lateral extent of CWA jurisdiction (check all that apply): 0 High Tide Line indicated by: E] Mean High Water Mark indicated by: C oil or scum line along shore objects E] survey to available datum; El fine shell or debris deposits (foreshore) C physical markings; C physical markings/characteristics [] vegetation lines/changes in vegetation types. C tidal gauges C other (list):

(iii) Chemical Characteristics: Characterize tributary (e.g., water color is clear, discolored, oily film; water quality; general watershed characteristics, etc.). Explain: Identify specific pollutants. if known:

"Anatural or man-made discontinuity in the OHWM does not necessarily sever jurisdiction (e.g.. where the stream temporarily (lows underground, or where the OHWM has been removed by development or agricultural practices). Where there is a break in the OIWM that is unrelated to the waterbody's flow regime (e.g.. flow over a rock outcrop or through a culvert), the agencies will look ror indicators o1 flow above and below the break. 7Ibid. (iv) Biological Characteristics. Channel supports (check all that apply): EU Riparian corridor. Characteristics (type. average width): EU Wetland fringe. Characteristics: U] Ilabitat for: EU Federally Listed species. Explain findings: U Fish/spawn areas. Explain findings: EU Other environmentally-sensitive species. Explain findings: F] Aquatic/wildlife diversity. Explain findings:

2. Characteristics of wetlands adjacent to non-TNW that flow directly or indirectly into TNW

(i) Physical Characteristics: (a) General Wetland Characteristics: Properties: Wetland size: acres Wetland type. Explain: Wetland quality. Explain: Project wetlands cross of serve as state boundaries. Explain:

(b) General Flow Relationship with Non-TNW: Flow is: W Explain: Surface flow is: KRE-GERt Characteristics:

Subsurface flow: Pijkisi. Explain findings: [J Dye (or other) test performed:

(c) Wetland Adiacency Determination with Non-TNW: Ul Directly abutting EU Not directly abutting U] Discrete wetland hydrologic connection. Explain: E] Ecological connection. Explain: [] Separated by berm/barrier. Explain:

(d) Proximity (Relationship) to TNW Project wetlands are 1ik 1ist river miles from TNW. Project waters are PickLls• aerial (straight) miles from I[NW. Flow is from: Fick'Li-4t. Estimate approximate location of wetland as within the PiclLil floodplain.

(ii) Chemical Characteristics: Characterize wetland system (e.g., water color is clear, brown, oil film on surface; water quality; general watershed characteristics; etc.). Explain: Identify specific pollutants, if known:

(iii) Biological Characteristics. Wetland supports (check all that apply): U] Riparian butffer. Characteristics (type, average width): U] Vegetation type/percent cover. Explain: M Habitat for: F- Federally Listed species. Explain findings: Ul Fish/spawn areas. Explain findings: U Other environmentally-sensitive species. Explain findings: U AquaticAvildlife diversity. Explain findings:

3. Characteristics of all wetlands adjacent to the tributary (if any).-. All wetland(s) being considered in the cumulative analysis: PikL.si Approximately ( ) acres in total are being considered in the cumulative analysis. For each wetland, specify the following:

Directly abuts? (Y/N) Size (in acres) Directly abuts? (Y/N) Size (in acres)

Summarize overall biological, chemical and physical functions being performed:

C. SIGNIFICANT NEXUS DETERMINATION

A significant nexus analysis will assess the flow characteristics and functions of the tributary itself and the functions performed by any wetlands adjacent to the tributary to determine if they significantly affect the chemical, physical, and biological integrity of a TNW. For each of the following situations, a significant nexus exists if the tributary, in combination with all of its adjacent wetlands, has more than a speculative or insubstantial effect on the chemical, physical and/or biological integrity of a TNW. Considerations when evaluating significant nexus include, but are not limited to the volume, duration, and frequency of the flow of water in the tributary and its proximity to a TNW, and the functions performed by the tributary and all its adjacent wetlands. It is not appropriate to determine significant nexus based solely on any specific threshold of distance (e.g. between a tributary and its adjacent wetland or between a tributary and the TNW). Similarly, the fact an adjacent wetland lies within or outside of a floodplain is not solely determinative of significant nexus.

Draw connections between the features documented and the effects on the TNW, as identified in the Rapanos Guidance and discussed in the Instructional Guidebook. Factors to consider include, for example: " Does the tributary, in combination with its adjacent wetlands (if any), have the capacity to carry pollutants or flood waters to TNWs, or to reduce the amount of pollutants or flood waters reaching a TNW? " Does the tributary, in combination with its adjacent wetlands (if any). provide habitat and lifecycle support functions for fish and other species, such as feeding, nesting, spawning, or rearing young for species that are present in the TNW? * Does the tributary, in combination with its adjacent wetlands (if any), have the capacity to transfer nutrients and organic carbon that support downstream fbodwebs? " Does the tributary, in combination with its adjacent wetlands (if any), have other relationships to the physical, chemical, or biological integrity of the TNW?

Note: the above list of considerations is not inclusive and other functions observed or known to occur should be documented below:

!. Significant nexus findings for non-RPW that has no adjacent wetlands and flows directly or indirectly into TNWs. Explain findings of presence or absence of significant nexus below, based on the tributary itself, then go to Section I I.D:

2. Significant nexus findings for non-RPW and its adjacent wetlands, where the non-RPW flows directly or indirectly into TNWs. Explain findings of presence or absence of significant nexus below, based on the tributary in combination with all of its adjacent wetlands, then go to Section III.D:

3. Significant nexus findings for wetlands adjacent to an RPW but that do not directly abut the RPW. Explain findings of presence or absence of significant nexus below, based on the tributary in combination with all of its adjacent wetlands, then go to Section I11.D:

1). DETERMINATIONS OF JURISDICTIONAL FINDINGS. THE SUBJECT WATERS/WETLANDS ARE (CHECK ALL THAT APPLY):

1. TNWs and Adjacent Wetlands. Check all that apply and provide size estimates in review area: E TNWs: linear feet width (If), Or, acres. Wetlands adjacent to TNWs: acres. 2. RPWs that flow directly or indirectly into TNWs. [ Tributaries of TNWs where tributaries typically flow year-round are jurisdictional. Provide data and rationale indicating that tributary is perennial: E Tributaries ofTNW where tributaries have continuous flow "seasonally" (e.g., typically three months each year) are jurisdictional. Data supporting this conclusion is provided at Section 1II.B. Provide rationale indicating that tributary tlows seasonally: Provide estimates for jurisdictional waters in the review area (check all that apply): [3 Tributary waters: linear feet width (ft). E3 Other non-wetland waters: acres. Identify type(s) of waters:

3. Non-RPWs 8 that flow directly or indirectly into TNWs. [3 Waterbody that is not a TNW or an RPW, but flows directly or indirectly intoa TNW. and it has a significant nexus with a TNW is jurisdictional. Data supporting this conclusion is provided at Section III.C.

Provide estimates for jurisdictional waters within the review area (check all that apply): T ributary waters: linear feet width (ft). Other non-wetland waters: acres. Identify type(s) of waters:

4. Wetlands directly abutting an RPW that flow directly or indirectly into TNWs, O Wetlands directly abut RPW and thus are jurisdictional as adjacent wetlands. O Wetlands directly abutting an RPW where tributaries typically flow year-round. Provide data and rationale indicating that tributary is perennial in Section II1.D.2, above. Provide rationale indicating that wetland is directly abutting an RPW:

[] Wetlands directly abutting an RPW where tributaries typically flow "seasonally." Provide data indicating that tributary is seasonal in Section III.B and rationale in Section III.D.2, above. Provide rationale indicating that wetland is directly abutting an RPW:

Provide acreage estimates forjurisdictional wetlands in the review area: acres.

5. Wetlands adjacent to but not directly abutting an RPW that flow directly or indirectly into TNWs. o Wetlands that do not directly abut an RPW, but when considered in combination with the tributary to which they are adjacent and with similarly situated adjacent wetlands, have a significant nexus with a TNW are jurisidictional. Data supporting this conclusion is provided at Section III.C.

Provide acreage estimates for jurisdictional wetlands in the review area: acres.

6. Wetlands adjacent to non-RPWs that flow directly or indirectly into TNWs. 0 Wetlands adjacent to such waters, and have when considered in combination with the tributary to which they are adjacent and with similarly situated adjacent wetlands, have a significant nexus with a TNW are jurisdictional. Data supporting this conclusion is provided at Section III.C.

Provide estimates for jurisdictional wetlands in the review area: acres. 9 7. Impoundments of jurisdictional waters. As a general rule, the impoundment of ajurisdictional tributary remains jurisdictional. [0 Demonstrate that impoundment was created from "waters ot the U.S.," or F Demonstrate that water meets the criteria for one of the categories presented above (1-6), or Demonstrate that water is isolated with a nexus to commerce (see E below).

E. ISOLATED IINTERSTATE OR INTRA-STATEI WATERS, INCLUDING ISOLATED WETLANDS, THE USE, DEGRADATION OR DESTRUCTION OF WIHICHI COULD AFFECT INTERSTATE COMMERCE, INCLUDING ANY SUCH WATERS (CHECK Al. THAT APPLY):10 C] which are or could be used by interstate or foreign travelers for recreational or other purposes. [] from which fish or shellfish are or could be taken and sold in interstate or foreign commerce. Q which are or could be used for industrial purposes by industries in interstate commerce. El Interstate isolated waters. Explain: 0 Other factors. Explain:

Identify water body and summarize rationale supporting determination:

'See Footnote # 3. To complete the analysis refer to the key in Section IIID.6 of the Instructional Guidebook. • Prior to asserting or declining CWA jurisdiction based solely on this category, Corps Districts will elevate the action to Corps and EPA HQ for review consistent with the process described in the Corps/EPA Memorandum Regarding CWA Act JurisdictionFollowing Rapanos. Provide estimates for jurisdictional waters in the review area (check all that apply): [D Tributary waters: linear feet width (ft). E] Other non-wetland waters: acres. Identify type(s) of waters: Ol Wetlands: acres.

F. NON-JURISDICTIONAL WATERS, INCLUDING WETLANDS (CHECK ALL TItAT APPLY): 0] If potential wetlands were assessed within the review area, these areas did not meet the criteria in the 1987 Corps of Engineers Wetland Delineation Manual and/or appropriate Regional Supplements. 0 Review area included isolated waters with no substantial nexus to interstate (or foreign) commerce. El Prior to the Jan 2001 Supreme Court decision in "SWVANCC," the review area would have been regulated based solely on the "Migratory Bird Rule" (MBR). 0 Waters do not meet the "Significant Nexus" standard, where such a finding is required for jurisdiction. Explain: El Other: (explain, if not covered above):

Provide acreage estimates for non-jurisdictional waters in the review area, where the sole potential basis ofjurisdiction is the MBR factors (i.e., presence of migratory birds, presence of endangered species, use of water for irrigated agriculture), using best professional judgment (check all that apply): El Non-wetland waters (i.e., rivers, streams): linear feet width (1i). El Lakes/ponds: acres. [3 Other non-wetland waters: acres. List type of aquatic resource: E] Wetlands: acres.

Provide acreage estimates for non-jurisdictional waters in the review area that do not meet the "Significant Nexus" standard, where such a finding is required for jurisdiction (check all that apply): [I Non-wetland waters (i.e., rivers, streams): linear feet,. width (fi). E] Lakes/ponds: acres. El Other non-wetland waters: acres. List type of aquatic resource: 0 Wetlands: acres.

SECTION IV: DATA SOURCES.

A. SUPPORTING DATA. Data reviewed for JD (check all that apply - checked items shall be included in case tile and, where checked and requested, appropriately reference sources below): 0 Maps, plans, plots or plat submitted by or on behalf of the applicant/consultant: Maps 1-3. U Data sheets prepared/submitted by or on behalf of the applicant/consultant. E3 Office concurs with data sheets/delineation report. El Office does not concur with data sheets/delineation report. O Data sheets prepared by the Corps: [3 Corps navigable waters' study: o] U.S. Geological Survey Hydrologic Atlas: El USGS NHD data. El USGS 8 and 12 digit IHUC maps. 0 U.S. Geological Survey map(s). Cite scale & quad name: Monument North 7.5 rnin Quadrangel Map, Hobbs Southwest 7.5 Min Quadrangel Map. E] USDA Natural Resources Conservation Service Soil Survey. Citation: El National wetlands inventory map(s). Cite name: E] State/Local wetland inventory map(s): E] FEMA/FIRM maps: fl 100-year Floodplain Elevation is: (National Geodectic Vertical Datum of 1929) 0 Photographs: Z Aerial (Name & Date):Monument North 2009 NE, NW., Hobbs Southwest 7.5 Min Quadrangel Map. or F- Other (Name & Date): E] Previous determination(s). File no. and date of response letter: H Applicable/supporting case law: Applicable/supporting scientific literature: El Other information (please specify):

B. ADDITIONAL COMMENTS TO SUPPORT JD: It is the opinion of GL Environmental, Inc. that waters of the U.S are not present in Section 27. Surface drainage flows are infrequent, low volume and short in duration. Additionally, the drainage is not connected through surface channels to regional surflace water features. Surface depressions are not dominated by wetland plants, lack indicators of anoxic soil conditions, and most likely are not saturated for more than 10% of the year. GL Environmental, Inc. seeks concurrence from the USACE that any water features on Section 27 are isolated and "Waters of the U.S." are not present within Section 27.. (CLean wata Act, Sotwa 4&4) 121, "0A LIFP-011 S-owVcUeftim ý-wadmerzasso 15-00-1.A SasVeatbon (n01t.UWk 124001-10A IIFP-012 WedanodDemesne"O Dr-aft 194OCt-10A Wetlan DeterminatonDraf IIFP-013 LIS Army Corpsof Eng~nemsRegulatory Rsoe Paocm 08-OOV-10* ~~US A"m COMlof Engoeema Regulatoy ReviewPamod IIPP-014 DeWaMeommoOf C$000 WSW. Ad. Se0m. 404 APOeCahIfy 10-UAW-11' -0 DOW-,eo*. ofa.a WaSWAM. S.W. 404Applbfttel

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