BIOLOGICAL EVALUATION FOR THE COPPER CITIES RECLAMATION PLAN OF OPERATIONS Prepared for: SRK Consulting, Inc. Prepared on behalf of: BHP Copper Inc. Prepared by: WestLand Resources, Inc. Date: March 15, 2017 Project No.: 815.24 07 TABLE OF CONTENTS 1. INTRODUCTION AND BACKGROUND ...................................................................................... 1 2. ANALYSIS AREA DESCRIPTION ..................................................................................................... 2 2.1. Land Uses .......................................................................................................................................... 2 2.2. Physical Features ............................................................................................................................... 2 2.3. Surface Water Features .................................................................................................................... 3 2.4. Vegetation .......................................................................................................................................... 4 3. SPECIAL STATUS SPECIES SCREENING ANALYSIS METHODS ....................................... 4 3.1. Special Status Species Identification .............................................................................................. 4 3.2. Surveys Within the Analysis Area................................................................................................... 5 3.3. Special Status Species Screening ..................................................................................................... 5 4. SPECIAL STATUS SPECIES SCREENING ANALYSIS RESULTS ........................................... 6 4.1. Arizona Hedgehog Cactus ............................................................................................................. 15 4.2. Southwestern Willow Flycatcher .................................................................................................. 16 4.3. Yellow-Billed Cuckoo .................................................................................................................... 17 4.4. Ocelot ............................................................................................................................................... 18 4.5. Arizona Toad ................................................................................................................................... 19 4.6. Lowland Leopard Frog .................................................................................................................. 20 4.7. Sonora Mud Turtle ......................................................................................................................... 20 4.8. Golden Eagle ................................................................................................................................... 21 4.9. Pinyon Jay ........................................................................................................................................ 22 5. REFERENCES ....................................................................................................................................... 24 TABLES Table 1. Screening Analysis Potential for Occurrence of ESA Listed Species within the Analysis Area ............................................................................................................... 8 Table 2. Screening Analysis Potential for Occurrence of BLM Phoenix District Sensitive Species within the Analysis Area .................................................................. follows text Q:\Jobs\800's\815.24\ENV\BE\Submittal 2017_03_15\CC RPO BE_2017_03_15.docx WestLand Resources, Inc. Biological Evaluation for the Copper Cities March 15, 2017 Reclamation Plan of Operations Page ii FIGURES (follow text) Figure 1. Vicinity Map Figure 2. Aerial Overview Figure 3. Geological Resources Map APPENDICES Appendix A. 2016 US Fish and Wildlife Service Information for Planning and Conservation Report (IPaC) Online Query Appendix B. Updated (February 2017) Bureau of Land Management Sensitive Species List for Arizona Appendix C. Arizona Game and Fish Department Heritage Database Management System (HDMS) On-Line Review Appendix D. Representative Photographs of the Analysis Area Q:\Jobs\800's\815.24\ENV\BE\Submittal 2017_03_15\CC RPO BE_2017_03_15.docx WestLand Resources, Inc. Biological Evaluation for the Copper Cities March 15, 2017 Reclamation Plan of Operations Page 1 1. INTRODUCTION AND BACKGROUND WestLand Resources, Inc. (WestLand) was retained by SRK Consulting, Inc. on behalf of BHP Copper Inc. (BHP) to evaluate the potential for special status species to occur on lands administered by the Bureau of Land Management (BLM) within unpatented claims at the Copper Cities Unit (the Analysis Area; Figure 1). Special status species screened for this report include those that have been recorded or have some potential to occur within or near the Analysis Area, and are: 1) Species listed under the Endangered Species Act (ESA) by the U.S. Fish and Wildlife Service (USFWS) that: a. are identified by the USFWS Arizona Ecological Services Field Office Information, Planning, and Conservation System (IPaC) tool (Appendix A), and/or b. are listed by the Bureau of Land Management (BLM) for the Phoenix District, and 2) Species listed as BLM Arizona Sensitive Species for the Phoenix District (Appendix B). The Analysis Area is located in Gila County, north of Miami, Arizona within portions of Sections 11 to 14 of Township 1 North, Range 14 East of the Gila and Salt River Baseline and Meridian (Figure 1). The Analysis Area occupies approximately 219 acres of BLM-administered land within the approximately 4,465 total acres of the Copper Cities Unit (Figure 2). The Analysis Area boundary was determined by a combination of BLM surface management mapping, unpatented claims data, and on-site survey. The Analysis Area includes undisturbed land as well as portions of an inactive leach dump and an inactive overburden rock pile, unpaved haul and access roads, a few structures, surface water management facilities, and old mine workings. The Copper Cities Unit was a copper extraction and beneficiation facility operated by a predecessor firm from 1951 until 1982, although some prospecting and minor mining took place earlier. Activities during the operational period included open pit mining and ore processing. Sulfide ore was processed by flotation recovery and oxide ore by dump leaching. In the interim since shutdown, virtually all processing infrastructure has been removed and the facility has remained inactive and unstaffed. Neither open-pit mining nor sulfide ore processing were ever conducted on the Analysis Area. A small portion of the oxide ore leaching operation was conducted and a portion of one overburden rock pile was placed on BLM-administered land. Neither the leach dump nor the overburden rock pile have been added to since facility shutdown in 1982. Other active facilities appurtenant to the mining operation (e.g., roads and water management facilities) are also on the BLM-administered land. Current activities on the Analysis Area are limited to periodic reclamation projects, water management, and general maintenance and support. Generally, the proposed reclamation and closure activities are intended to promote the establishment of a self-sustaining ecosystem consistent with the biotic communities of the surrounding area, with consideration of the specific conditions that exist at the Q:\Jobs\800's\815.24\ENV\BE\Submittal 2017_03_15\CC RPO BE_2017_03_15.docx WestLand Resources, Inc. Biological Evaluation for the Copper Cities March 15, 2017 Reclamation Plan of Operations Page 2 Analysis Area. Post-closure monitoring and maintenance will follow the completion of reclamation to ensure success of the program and compliance with performance criteria. 2. ANALYSIS AREA DESCRIPTION The Copper Cities Unit lies within a landscape heavily altered by mining activities over the last 65 years; the Analysis Area is at the southern edge of the disturbed lands within Copper Cities Unit. The location, land uses, and physical and biological resources of the Analysis Area are described below. 2.1. LAND USES The Analysis Area consists of both disturbed and undisturbed lands. Portions of an overburden rock pile and a leach dump occur within the Analysis Area, as well as water management facilities, some utility lines, a network of unpaved roads, and old mine workings. The western portion of the Analysis Area, south of the Diamond H Pit and south and west of Lost Gulch, contains rocky and rugged terrain that has not been affected by mine activities and remains relatively undisturbed. Access roads associated with the operation of the Copper Cities Unit and subsequent reclamation activities have impacted portions of the Analysis Area. General land-clearing activities for construction yards and transmission lines have impacted some portions as well. Some of the facilities have naturally revegetated since the mine shutdown in 1982, with dense vegetation growth on the top surface, but sparse vegetation on the side slopes. Roads and ponds are bare of vegetation. 2.2. PHYSICAL FEATURES The Analysis Area is located in the Central Highlands Physiographic Province, a transitional area between the Colorado Plateau Physiographic Province and the Basin and Range Physiographic Province (Ffolliott 1999). Elevation within the Analysis Area ranges from approximately 3,700 to 4,200 feet (ft) above