BLM Black Rock Field Office/Winnemucca, Nevada

Winnemucca District Office / Nevada

-2011-0001-EIS 030-2011-0001-EIS

NV-W -BLM-

Hycroft Mine Expansion Project Project Expansion Mine Hycroft

DOI FINAL ENVIRONMENTAL IMPACT STATEMENT

Winnemucca NV 89445-2921 NV Winnemucca Management of Land U.S. Bureau Office District Winnemucca Rock Office Field Black Blvd. 5100 E. Winnemucca July 2012 July

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

BLM/NV/WN/ES/12-2+1793

DOI-BLM-NV-W030-2011-0001-EIS

HYCROFT MINE EXPANSION PROJECT FINAL ENVIRONMENTAL IMPACT STATEMENT

TABLE OF CONTENTS

ABBREVIATIONS AND ACRONYMS...... XIII EXECUTIVE SUMMARY ...... ES­1 1 INTRODUCTION...... 1­1 1.1 Introduction ...... 1­1 1.2 Organization of Document ...... 1­2 1.3 Purpose of and Need for Action ...... 1­7 1.4 Land Use Plan Conformance...... 1­8 1.4.1 Sonoma Gerlach Management Framework Plan...... 1­8 1.4.2 Paradise Denio Management Framework Plan...... 1­8 1.5 BLM and Non­BLM Policies, Plans, and Programs ...... 1­8 1.6 Authorizing Actions ...... 1­8 1.7 Scoping ...... 1­9 1.8 Issues...... 1­10 1.9 Mine History and Existing and Approved Facilities...... 1­10 1.9.1 Mine History ...... 1­10 1.9.2 Existing and Approved Facilities ...... 1­11 2 DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES...... 2­1 2.1 Proposed Action...... 2­1 2.1.1 Open Pit Mining Methods ...... 2­3 2.1.2 Equipment...... 2­7 2.1.3 Waste Rock Facilities ...... 2­7 2.1.4 Heap Leach Facilities ...... 2­10 2.1.5 Storm Water Management ...... 2­20 2.1.6 Support Facilities...... 2­21 2.1.7 Rights­of­Way and Leases ...... 2­22 2.1.8 Haul and Access Roads ...... 2­22 2.1.9 Transportation...... 2­25 2.1.10 Employment ...... 2­25 2.1.11 Public Safety ...... 2­26 2.1.12 Chemical Use and Management...... 2­26 2.1.13 Sustainability ...... 2­27 2.1.14 Exploration...... 2­27 2.1.15 Applicant­Committed Environmental Protection Measures ...... 2­28 2.1.16 Growth Media...... 2­31 2.1.17 Reclamation of Open Pits ...... 2­41 2.1.18 Reclamation of Waste and Development Rock Piles...... 2­41 2.1.19 Reclamation of Heap Leach Facilities ...... 2­49 2.1.20 Reclamation of Solution Ponds ...... 2­52 2.1.21 Road Reclamation ...... 2­53 2.1.22 Measures to Minimize Loading of Sediment to Drainage Channels ...... 2­53 2.1.23 Disposition of Buildings and Ancillary Facilities...... 2­54 2.1.24 Surface Facilities or Roads Not Subject to Reclamation ...... 2­54 2.1.25 Post­Reclamation Monitoring and Maintenance...... 2­54 2.1.26 Drill Hole Plugging Procedures...... 2­55 2.1.27 Concurrent Reclamation ...... 2­55 2.2 Alternatives to the Proposed Action ...... 2­55

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2.2.1 No Action Alternative ...... 2­56 � 2.2.2 Alternatives Considered but Eliminated from Detailed Analysis...... 2­57 � 2.2.3 The BLM Preferred Alternative ...... 2­60 � 2.3 Summary of Effects...... 2­60 � 3 � AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES (DIRECT AND INDIRECT)...... 3­1 3.1 Introduction ...... 3­1 � 3.1.1 General Project Setting...... 3­1 � 3.1.2 Supplemental Authorities ...... 3­1 � 3.1.3 Additional Affected Resources ...... 3­3 � SUPPLEMENTAL AUTHORITIES ...... 3­6 � 3.2 Air and Atmospheric Resources ...... 3­6 � 3.2.1 Regulatory Framework...... 3­6 � 3.2.2 Affected Environment...... 3­6 � 3.2.3 Environmental Consequences and Mitigation Measures ...... 3­10 � 3.3 Cultural Resources ...... 3­27 � 3.3.1 Regulatory Framework...... 3­27 � 3.3.2 Affected Environment...... 3­27 � 3.3.3 Environmental Consequences and Mitigation Measures ...... 3­34 � 3.4 Migratory Birds...... 3­41 � 3.4.1 Regulatory Framework...... 3­41 � 3.4.2 Affected Environment...... 3­41 � 3.4.3 Environmental Consequences and Mitigation Measures ...... 3­44 � 3.5 Native American Religious Concerns...... 3­46 � 3.5.1 Regulatory Framework...... 3­46 � 3.5.2 Affected Environment...... 3­46 � 3.5.3 Environmental Consequences and Mitigation Measures ...... 3­47 � 3.6 Wastes and Materials (Hazardous and Solid) ...... 3­49 � 3.6.1 Regulatory Framework...... 3­49 � 3.6.2 Affected Environment...... 3­49 � 3.6.3 Environmental Consequences and Mitigation Measures ...... 3­50 � 3.7 Water Quality (Surface and Ground) ...... 3­54 � 3.7.1 Regulatory Framework...... 3­54 � 3.7.2 Affected Environment...... 3­54 � 3.7.3 Environmental Consequences and Mitigation Measures ...... 3­72 � ADDITIONAL AFFECTED RESOURCES...... 3­76 � 3.8 Geology, Minerals, and Energy...... 3­76 � 3.8.1 Regulatory Framework...... 3­76 � 3.8.2 Affected Environment...... 3­77 � 3.8.3 Environmental Consequences and Mitigation Measures ...... 3­86 � 3.9 Noise...... 3­88 � 3.9.1 Regulatory Framework...... 3­88 � 3.9.2 Affected Environment...... 3­91 � 3.9.3 Environmental Consequences and Mitigation Measures ...... 3­96 � 3.10 Realty...... 3­105 � 3.10.1 Regulatory Framework...... 3­105 � 3.10.2 Affected Environment...... 3­105 � 3.10.3 Environmental Consequences and Mitigation Measures ...... 3­109 �

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TABLE OF CONTENTS

3.11 � Recreation ...... 3­110 � 3.11.1 Regulatory Framework...... 3­110 � 3.11.2 Affected Environment...... 3­110 � 3.11.3 Environmental Consequences and Mitigation Measures ...... 3­112 � 3.12 � Social Values and Economics ...... 3­116 � 3.12.1 Regulatory Framework...... 3­116 � 3.12.2 Affected Environment...... 3­117 � 3.12.3 Environmental Consequences and Mitigation Measures ...... 3­140 � 3.13 � Soils...... 3­145 � 3.13.1 Regulatory Framework...... 3­145 � 3.13.2 Affected Environment...... 3­145 � 3.13.3 Environmental Consequences and Mitigation Measures ...... 3­150 � 3.14 � Special Status Species...... 3­159 � 3.14.1 Regulatory Framework...... 3­159 � 3.14.2 Affected Environment...... 3­159 � 3.14.3 Environmental Consequences and Mitigation Measures ...... 3­167 � 3.15 � Transportation, Access, and Public Safety ...... 3­178 � 3.15.1 Regulatory Framework...... 3­178 � 3.15.2 Affected Environment...... 3­179 � 3.15.3 Environmental Consequences and Mitigation Measures ...... 3­183 � 3.16 � Vegetation...... 3­189 � 3.16.1 Regulatory Framework...... 3­189 � 3.16.2 Affected Environment...... 3­189 � 3.16.3 Environmental Consequences and Mitigation Measures ...... 3­193 � 3.17 � Visual Resources...... 3­198 � 3.17.1 Regulatory Framework...... 3­198 � 3.17.2 Affected Environment...... 3­199 � 3.17.3 Environmental Consequences and Mitigation Measures ...... 3­200 � 3.18 � Wildlife ...... 3­220 � 3.18.1 Regulatory Framework...... 3­220 � 3.18.2 Affected Environment...... 3­221 � 3.18.3 Environmental Consequences and Mitigation Measures ...... 3­223 � 3.19 � The Relationship Between Short­ and Long­Term Uses of Man’s Environment and Maintenance and Enhancement of Long­Term Productivity...... 3­227 3.20 Irreversible and Irretrievable Commitment of Resources ...... 3­228 � 4 CUMULATIVE IMPACTS ...... 4­1 � 4.1 � Introduction ...... 4­1 � 4.2 � Cumulative Effect Study Areas...... 4­2 � 4.3 � Past, Present, and Reasonably Foreseeable Future Actions...... 4­16 � 4.3.1 Grazing and Rangeland Improvements ...... 4­16 � 4.3.2 Utilities and Infrastructure...... 4­17 � 4.3.3 Land Development ...... 4­18 � 4.3.4 Mineral Development and Exploration...... 4­19 � 4.3.5 Geothermal Leasing and Development ...... 4­20 � 4.3.6 Hazardous/Solid Waste and Hazardous Materials ...... 4­21 � 4.3.7 Recreation ...... 4­21 � 4.3.8 Wildland Fires ...... 4­22 � 4.4 � Cumulative Impacts for the Proposed Action ...... 4­22 �

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4.4.1 Air and Atmospheric Resources ...... 4­23 � 4.4.2 Cultural Resources ...... 4­24 � 4.4.3 Geology, Minerals, and Energy...... 4­26 � 4.4.4 Migratory Birds...... 4­26 � 4.4.5 Recreation ...... 4­27 � 4.4.6 Social Values and Economics ...... 4­28 � 4.4.7 Soils...... 4­29 � 4.4.8 Special Status Species...... 4­29 � 4.4.9 Transportation, Access, and Public Safety ...... 4­31 � 4.4.10 Vegetation...... 4­31 � 4.4.11 Visual Resources...... 4­33 � 4.4.12 Water Quality and Quantity (Surface and Ground)...... 4­33 � 4.4.13 Wildlife ...... 4­34 � 4.5 Cumulative Impacts from the No Action Alternative...... 4­35 � 4.5.1 Air and Atmospheric Resources ...... 4­36 � 4.5.2 Cultural Resources ...... 4­36 � 4.5.3 Geology, Minerals, and Energy...... 4­36 � 4.5.4 Migratory Birds...... 4­36 � 4.5.5 Recreation ...... 4­36 � 4.5.6 Social Values and Economics ...... 4­37 � 4.5.7 Soils...... 4­37 � 4.5.8 Special Status Species...... 4­37 � 4.5.9 Transportation, Access, and Public Safety ...... 4­37 � 4.5.10 Vegetation...... 4­37 � 4.5.11 Visual Resources...... 4­37 � 4.5.12 Wastes, Hazardous and Solid...... 4­38 � 4.5.13 Water Quality and Quantity (Surface and Ground)...... 4­38 � 4.5.14 Wildlife ...... 4­38 � 5 MITIGATION AND MONITORING ...... 5­1 � 5.1 Proposed Action...... 5­1 � 5.1.1 Recommended Mitigation Measures ...... 5­1 � 5.1.2 Applicant Committed Environmental Protection Measures...... 5­3 � 5.1.3 Applicant Committed Monitoring ...... 5­5 � 5.2 No Action Alternative ...... 5­7 � 6 LIST OF PREPARERS...... 6­1 � 6.1 BLM...... 6­1 � 6.2 Cooperating Agencies...... 6­1 � 6.3 Enviroscientists, Inc...... 6­2 � 7 CONSULTATION AND COORDINATION...... 7­1 � 7.1 Consultation with Federal, State, and Local Agencies...... 7­1 � 7.2 Native American Coordination ...... 7­1 � 8 PUBLIC INVOLVEMENT...... 8­1 � 8.1 Public Scoping...... 8­1 � 8.2 Public Meetings on the Draft EIS ...... 8­1 � 8.3 Public Comments on the Draft EIS and Responses ...... 8­2 � 9 REFERENCES...... 9­1 � 10 GLOSSARY...... 10­1 � 11 ALPHABETICALLY ORDERED INDEX ...... 11­1 �

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TABLE OF CONTENTS

LIST OF TABLES

Table 1.6­1: Major Permits and Authorizations...... 1­8 � Table 1.8­1: Issues of Concern Identified in Project Scoping...... 1­10 � Table 1.9­1: Existing and Authorized Disturbance Acreage ...... 1­12 � Table 1.9­2: Existing and Authorized Open Pit Parameters ...... 1­15 � Table 1.9­3: Existing and Authorized Waste Rock Facility Parameters...... 1­15 � Table 1.9­4: Existing Growth Media Stockpile Volumes ...... 1­17 � Table 1.9­5: Historic and Current Mine Employment...... 1­18 � Table 1.9­6: Summary of Existing Fuels and Reagents Usage ...... 1­19 � Table 1.9­7: Existing Rights­of­Way within the Hycroft Mine Project Area...... 1­21 � Table 2.1­1: Summary of Project Surface Disturbance and Plan Boundary Acreage. 2­1 � Table 2.1­2: Proposed and Total Surface Disturbance by Activity...... 2­2 � Table 2.1­3: Proposed Open Pit Parameters...... 2­4 � Table 2.1­4: Summary of Projected Annual Mining, Waste Rock Placement, and Ore � Placement Sequences...... 2­4 � Table 2.1­5: Approximate Tonnages of Ore and Waste Rock...... 2­7 � Table 2.1­6: Anticipated Mobile Surface Equipment...... 2­7 � Table 2.1­7: Summary of Predicted Waste Rock Geochemistry...... 2­9 � Table 2.1­8: Heap Leach Design Parameters ...... 2­18 � Table 2.1­9: Pond Volumes ...... 2­19 � Table 2.1­10: Growth Media Stockpile Volumes ...... 2­22 � Table 2.1­11: Projected Mine Employment...... 2­25 � Table 2.1­12: Summary of Proposed Fuels and Reagents Usage ...... 2­27 � Table 2.1­13: Committed Practices for Fugitive Dust Control...... 2­28 � Table 2.1­14: Recommended BLM Revegetation Seed Mixture ...... 2­32 � Table 2.1­15: Proposed Reclamation Schedule ...... 2­34 � Table 2.1­16: Slope Stability Analysis – Waste Rock Facility ...... 2­41 � Table 2.1­17: Slope Stability Analysis – Heap Leach Pad ...... 2­41 � Table 2.3­1: Summary of Potential Environmental Effects, Recommended Mitigation � Measures, and Effectiveness of Mitigation...... 2­61 � Table 3.1­1: Supplemental Authorities ...... 3­2 � Table 3.1­2: Additional Affected Resources...... 3­4 � Table 3.2­1: Federal Ambient Air Quality Standards for Criteria Pollutants...... 3­7 � Table 3.2­2: State of Nevada Ambient Air Quality Standards for Criteria Pollutants..... � ...... 3­8 Table 3.2­3: Modeled Emission Rates for the NEPA Model...... 3­11 Table 3.2­4: Background Values for Criteria Pollutants ...... 3­16 Table 3.2­5: Highest Modeled Air Pollutant Concentrations from the Proposed Action at Receptor Points Accessible to Public...... 3­17 Table 3.2­6: Hazardous Air Pollutants Emissions for the Hycroft Mine Expansion Project...... 3­23 Table 3.2­7: Proposed Action and No Action Alternative Fuel and Power Consumption and Greenhouse Gas Emissions ...... 3­24 � Table 3.3­1: Cultural Resource Sites Recorded within the APE by Type...... 3­33 � Table 3.3­2: Cultural Resource Sites Eligibility by Type...... 3­33 � Table 3.3­3: Site Eligibility by Type with Potential Impacts ...... 3­36 � Table 3.3­4: Potential Project Impacts to Eligible Sites...... 3­36 �

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Table 3.6­1: Existing Fuels and Reagents...... 3­50 Table 3.7­1: Project Humidity Cell Test Results as of November 2011...... 3­58 Table 3.7­2: 2010­2011 Hycroft Mine Precipitation Data...... 3­60 Table 3.7­3: 2010 Monitoring Wells Water Table Elevations ...... 3­62 Table 3.7­4: Surface Water Quality Data...... 3­67 Table 3.7­5: Ground Water Quality Data ...... 3­68 Table 3.7­6: Water Rights by Manner of Use ...... 3­72 Table 3.9­1: Common Sources of Noise ...... 3­88 Table 3.9­2: Federal Transit Administration Upper Noise Level Limits for “No Impact” at Noise Sensitive Land Uses within the Range of Ambient Hourly Noise Levels...... 3­90 Table 3.9­3: Potentially Significant Increases in Cumulative Noise Noise Exposure for Transportation Noise Sources ...... 3­91 Table 3.9­4: Summary of Measured Noise Levels August 24 – 25, 2011 ...... 3­95 Table 3.9­5: Bases for Ambient Hourly Noise Level Assumptions...... 3­98 Table 3.9­6: Comparison of Predicted and Ambient Hourly Noise Levels ...... 3­99 Table 3.9­7: Comparison of Predicted and Ambient Day­Night Levels ...... 3­99 Table 3.9­8: Reference Noise Emission Levels and Usage Factors for Construction Equipment...... 3­100 Table 3.10­1: Existing BLM Rights­of­Way...... 3­106 Table 3.11­1: 2010 Big Game Harvest by Hunt Unit or Group...... 3­111 Table 3.11­2: Recreational Areas and Estimated Annual Visitors ...... 3­112 Table 3.12­1: Population Data for the Assessment Area and Projected Populations in the Assessment Area and State of Nevada...... 3­118 Table 3.12­2: 2010 Age Distribution of Assessment Area and State of Nevada Populations...... 3­121 Table 3.12­3: Ethnic Composition of Assessment Area and State of Nevada Populations ...... 3­121 Table 3.12­4: 2009 Income Level of the Assessment Area Compared with the State of Nevada ...... 3­122 Table 3.12­5: 2009 Employment by Industry in Assessment Area Compared with the State of Nevada ...... 3­123 Table 3.12­6: Top Ten Employers in Assessment Area Counties ­ 2011 ...... 3­124 Table 3.12­7: Labor Force Statistics for the Assessment Area Compared with the State of Nevada...... 3­125 Table 3.12­8: Housing Characteristics of the Assessment Area and State of Nevada 3­126 Table 3.12­9: Enrollment, Capacity and Teaching Staff for Schools in the Humboldt County School District ...... 3­135 Table 3.12­10: Historic Student Enrollment and Teaching Staff Levels...... 3­135 Table 3.12­11: Enrollment, Capacity and Teaching Staff for Schools in the Pershing County School District ...... 3­136 Table 3.12­12: Enrollment, Capacity and Teaching Staff for Schools in Census Tract 35.01 in the Washoe County School District...... 3­136 Table 3.12­13: Revenues and Expenditures in Assessment Area Counties...... 3­138 Table 3.12­14: Assessed Valuation and Tax Revenue Distribution of Net Proceeds of Minerals by Assessment Area County...... 3­140 Table 3.12­15: Mining­Related Real and Personal Property Valuation as a Percentage of Total Property in the Assessment Area Counties...... 3­140

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Table 3.12­16: Proposed Action Annual Operating Costs and Taxes Generated...... 3­143 Table 3.13­1: Summary of Soil Mapping Units and Characteristics ...... 3­149 Table 3.15­1: Nevada Department of Transportation Average Annual Daily Traffic Volumes ...... 3­179 Table 3.15­2: Jungo Road Average Daily Travel...... 3­180 Table 3.15­3: Hazardous Material Types Transported on Jungo Road...... 3­183 Table 3.15­4: Changes in Average Daily Travel along Jungo Road ...... 3­184 Table 3.15­5: Proposed Hazardous Material Types and Transport Levels on Jungo Road...... 3­185 Table 3.15­6: Estimate of Annual Number of Spills Resulting from Truck Accidents under the Proposed Action ...... 3­185 Table 3.15­7: No Action Alternative Portion of Average Daily Travel along Jungo Road ...... 3­186 Table 3.15­8: Existing Hazardous Material Types and Transport Levels on Jungo Road ...... 3­187 Table 3.15­9: Estimate of Annual Number of Spills Resulting from Truck Accidents under the No Action Alternative...... 3­188 Table 3.16­1: General Vegetation Community Types and Coverage Classifications within the Project Area...... 3­190 Table 3.16­2: Vegetation Communities Affected by the Mining Activities Associated with the Proposed Action...... 3­194 Table 3.16­3: Vegetation Communities Affected by the Mining Activities Associated with the No Action Alternative...... 3­196 Table 3.17­1: BLM Visual Resource Management Classes ...... 3­198 Table 3.20­1: Irreversible and Irretrievable Commitment of Resources by the Proposed Action...... 3­228 Table 4.2­1: Cumulative Effects Study Areas by Resource ...... 4­7 Table 4.2­2: Summary of Activities that May Cumulatively Affect Resources ...... 4­11 Table 4.2­3: Surface Disturbance or Area Associated with Projects within the Cumulative Effects Study Areas ...... 4­12 Table 4.2­4: Surface Disturbance or Area Associated with Past and Present Projects within the Cumulative Effects Study Areas...... 4­14 Table 4.2­5: Surface Disturbance or Area Associated with Reasonably Foreseeable Future Actions within the Cumulative Effects Study Areas ...... 4­15 Table 4.3­1: Rangeland Improvements Located within Each CESA...... 4­17 Table 4.3­2: Acres of Mineral Development and Exploration Disturbance within Each CESA ...... 4­19 Table 4.3­3: Mineral Development and Exploration RFFAs within Each CESA ...... 4­20 Table 4.3­4: Wildland Fires within Each CESA ...... 4­22 Table 4.4­1: Vehicular Emissions from I­80 within the Air Quality CESA...... 4­23

LIST OF FIGURES

Figure 1.1.1: Project Location and Access...... 1­3 � Figure 1.1.2: Land Status and Boundary of Project Area ...... 1­5 � Figure 1.9.1: Existing and Authorized Disturbance and Facilities...... 1­13 � Figure 1.9.2: Photograph of Existing Successful Project Reclamation...... 1­23 �

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Figure 2.1.1: Proposed Disturbance and Facilities ...... 2­5 � Figure 2.1.2: Proposed North Brimstone Heap Leach Facility Cross Sections...... 2­11 � Figure 2.1.3: Proposed South Heap Leach Facility Cross Section ...... 2­13 � Figure 2.1.4: Proposed Heap Leach Process Flowsheet ...... 2­15 � Figure 2.1.5: Typical Haul Road Cross Section ...... 2­23 � Figure 2.1.6: Post­Mining Topography...... 2­35 � Figure 2.1.7: Post­Reclamation Topography...... 2­37 � Figure 2.1.8: Typical Waste Rock Facility Operational and Reclamation Detail...... 2­39 � Figure 2.1.9: Proposed Center Open Pit and West Waste Rock Facility Cross � Sections...... 2­43 Figure 2.1.10: Proposed Brimstone Open Pit Cross Section...... 2­45 Figure 2.1.11: Proposed Bay Area and Boneyard Open Pits and North Waste Rock Facility Cross Sections ...... 2­47 Figure 3.2.1: Air Dispersion Modeling Fenceline...... 3­13 Figure 3.2.2: Average Wind Frequency Distribution Plot for 2006 to 2010 Lovelock, Nevada Meteorological Data ...... 3­15 � Figure 3.2.3: Isopleth of the Modeled Highest 24­hour PM10 Concentrations...... 3­19 � Figure 3.2.4: Isopleth of the Modeled Highest 24­hour PM2.5 Concentrations ...... 3­21 � Figure 3.3.1: Cultural Resources APE...... 3­29 � Figure 3.7.1: Black Rock Desert Hydrographic Basin ...... 3­55 � Figure 3.7.2: Surface Water Features and Monitoring Wells...... 3­63 � Figure 3.7.3: Ground Water Table Contour Map ...... 3­65 � Figure 3.8.1: Geology in the Project Area ...... 3­79 � Figure 3.8.2: East­West Cross Section of Lithologic Units across the Hycroft � Deposit ...... 3­81 � Figure 3.8.3: Hydrothermal Alternation Assemblage Cross Section ...... 3­83 � Figure 3.9.1: Ambient Noise Measurement Sites ...... 3­93 � Figure 3.9.2: Measured Hourly Noise Levels Site LT ­ 1 ...... 3­95 � Figure 3.9.3: Measured Hourly Noise Levels Site LT ­ 2 ...... 3­95 � Figure 3.9.4: Measured Hourly Noise Levels Site LT ­ 3 ...... 3­96 � Figure 3.9.5: Typical Blast Acoustical Spectrum...... 3­101 � Figure 3.9.6: A­Weighting Filter Response ...... 3­102 � Figure 3.10.1: Existing BLM Issued Rights­of­Way and Authorizations...... 3­107 � Figure 3.11.1: Recreation Areas within the Project Area Vicinity...... 3­113 � Figure 3.12.1: Social Values and Economics Assessment Area ...... 3­119 � Figure 3.13.1: Soils in the Project Area ...... 3­147 � Figure 3.13.2: Surface Erodibility Ratings for Soils in the Project Area ...... 3­151 � Figure 3.13.3: Potential for Soil Use as Reclamation Fill Material and Topsoil in the � Project Area ...... 3­153 � Figure 3.14.1: Greater Sage­Grouse Habitat...... 3­163 � Figure 3.14.2: Crosby’s Buckwheat Habitat in the Project Area...... 3­169 � Figure 3.15.1: Transportation, Access, and Public Safety Assessment Area ...... 3­181 � Figure 3.16.1: Vegetation Communities in the Project Area ...... 3­191 � Figure 3.17.1: Top of Hycroft Mine Viewshed and Key Observation Points...... 3­201 � Figure 3.17.2: Dark Sky Observation Points in the Vicinity of the Hycroft Mine...... 3­203 � Figure 3.17.3: KOP #1 Existing Condition Looking Southwest ...... 3­206 � Figure 3.17.4a: KOP #2 Existing Conditions Looking Southeast...... 3­207 � Figure 3.17.4b: KOP #2 No Action Alternative at Full Build Out...... 3­207 �

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Figure 3.17.4c: KOP #2 No Action Alternative at Full Reclamation...... 3­207 � Figure 3.17.4d: KOP #2 Proposed Action Full Build Out ...... 3­209 � Figure 3.17.4e: KOP #2 Proposed Action Full Reclamation...... 3­209 � Figure 3.17.5a: KOP #3 Existing Condition Looking Northeast ...... 3­213 � Figure 3.17.5b: KOP #3 No Action Alternative at Full Build Out...... 3­213 � Figure 3.17.5c: KOP #3 No Action Alternative Fully Reclaimed...... 3­215 � Figure 3.17.5d: KOP #3 Proposed Action at Full Build Out...... 3­215 � Figure 3.17.5e: KOP #3 Proposed Action at Full Reclamation ...... 3­217 � Figure 3.17.6: KOP #4 Existing Condition Looking Due East ...... 3­217 � Figure 4.2.1: Large Scale Cumulative Effects Study Area Map...... 4­3 � Figure 4.2.2: Small Scale Cumulative Effects Study Area Map ...... 4­5 � Figure 4.2.3: Cumulative Effects Data Collection Area ...... 4­9 �

APPENDICES

Appendix A: � Comment Letters on the Draft Environmental Impact Statement with Substantive Comments

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ABBREVIATIONS AND ACRONYMS �

Reader Note: Refer to the list below for abbreviations or acronyms that may be used in t his document.

< less than 3­86 ≤ less than or equal to 1­19 > greater than 3­96 ° Degrees 1­17 µg/m3 micrograms per cubic meters 3­6 AADT annual average daily traffic 3­186 AAQS Ambient Air Quality Standards 3­5 ABA acid base accounting 2­9 ACE U.S. Army Corps of Engineers 3­61 ACHP Advisory Council on Historic Preservation ADT average daily traffic 3­186 afa acre feet annually 3­73 AHPA Archaeological and Historic Preservation Act of 1974 3­38 AIRFA American Indian Religious Freedom Act of 1978 3­38 AML Appropriate Management Levels 3­5 amsl above mean sea level 1­17 ANFO ammonium nitrate/fuel oil mixture 2­6 ANSI American National Standards Institute 3­97 AP Advanced Placement 3­143 APE Area of Potential Effect 3­38 AQMA Air Quality Management Area 3­11 ARD acid rock drainage 3­77 ARPA Archaeological Resource Protection Act of 1979 3­38 ASW Applied Soil and Water Technologies AUM animal unit month 3­5 B&K Bruel & Kjaer (microphones) 3­97 BAPC Bureau of Air Pollution Control 3­10 BAQP Bureau of Air Quality Planning 3­11 BATF Bureau of Alcohol, Tobacco, Firearms, and Explosive 2­5 BBA Brown Buntin Associates, Inc. 3­97 BCR Bird Conservation Region 3­49 BEA Bureau of Economic Analysis 3­130 bgs below ground surface 3­67 BIA Bureau of Indian Affairs 3­112 BLM Bureau of Land Management ES­1 BMPs Best Management Practices 1­2 BMRR Bureau of Mining Regulation and Reclamation 1­18 BRFO Black Rock Field Office 1­1 BSA Barkdull Spencer Agency 3­134 C Celsius CAB Community Advisory Boards 3­146 CEQ Council on Environmental Quality 1­2

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CERCLA ­ Comprehensive Environmental Response, Compensation, and 3­56 Liability Act CESA ­ cumulative effects study area 1­6 CFR ­ Code of Federal Regulations 1­1 cm/sec ­ centimeters per second 2­10 CNEL ­ Community Noise Equivalent Level 3­96 CO ­ carbon monoxide 3­6 CO2(e) ­ carbon dioxide equivalent 3­12 dB ­ Decibels 3­94 dBA ­ decibel with A weighting filter 3­95 DE ­ diatomaceous earth 1­18 DETR ­ Department of Employment, Training, and Rehabilitation 3­132 DMV ­ Department of Motor Vehicles 3­183 DOI ­ Department of the Interior 1­7 EIS ­ Environmental Impact Statement ES­1 EMS ­ Emergency Medical Services 3­140 ENM ­ Environmental Noise Model 3­103 EO ­ Executive Order 3­1 EPA ­ U.S. Environmental Protection Agency 1­22 EPCRA ­ Emergency Planning and Community Right­To­Know Act 3­56 ESA ­ Endangered Species Act 3­167 ET ­ Evapotranspiration 2­52 F ­ Fahrenheit 3­1 FCAA ­ Federal Clean Air Act FCWA ­ Federal Clean Water Act FHWA ­ Federal Highway Administration 3­102 FICON ­ Federal Interagency Committee on Noise 3­95 FLPMA ­ Federal Land Policy and Management Act 1­1 FMCSA ­ Federal Motor Carrier Safety Administration 3­190 ft/day ­ feet per day FTA ­ Federal Transit Administration 3­95 GBBO ­ Great Basin Bird Observatory GED ­ General Educational Development 3­143 GHG ­ greenhouse gas ES­3 GID ­ General Improvement District 3­136 GIS ­ Geographic Information System 3­207 gpd ­ gallons per day 3­136 gpm ­ gallons per minute 1­18 gpm/ft2 ­ gallons per minute per square foot 2­17 GPS ­ global positioning system 1­25 H:V horizontal to vertical 1­17 H2S hydrogen sulfide HAP Hazardous Air Pollutants HCRMP Humboldt County Regional Master Plan 1­8 HCSD Humboldt County School District 3­143 HCSO Humboldt County Sheriff’s Office 3­138

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ABBREVIATIONS AND ACRONYMS

HCT humidity cell test 3­78 HDA Humboldt Development Authority 3­134 HDPE high density polyethylene 2­10 HGH Humboldt General Hospital 3­140 HMA Herd Management Areas 3­5 HRDI Hycroft Resources and Development, Inc. ES­1 HSWA Hazardous and Solid Waste Amendments 3­56 Hz Hertz 3­106 I­80 Interstate 80 1­1 ICC International Code Council ICP induced coupled plasma 3­78 ID Interdisciplinary 1­6 IM Instruction Memorandum 1­2 IMPROVE Interagency Monitoring of Protected Visual Environments 3­21 IPCC Intergovernmental Panel on Climate Change 3­12 KMG Kamma Mountains Group 3­79 KOP key observation point 3­203 Ktons Kilotons 2­6 kV Kilovolt 1­20 KVA kilovolt amperes 1­20 L50 noise level median 3­94 LCRS leak collection recovery system 2­17 Ldn noise levels day/night 3­94 Leq noise level average 3­94 LFD Lovelock Fire Department 3­114 Lmax noise level maximum 3­100 LMWD Lovelock Meadows Water District 3­136 LPD Lovelock Police Department 3­139 LR2000 Land and Mineral Legacy Rehost System LRL Lockwood Regional Landfill 3­137 LTT long­term trust MBTA Migratory Bird Treaty Act 2­30 MDB&M Mount Diablo Base & Meridian 1­1 MFP Management Framework Plan 1­8 mg/L milligrams per liter 3­72 mg/m3 milligrams per cubic meter 3­6 Mgal million gallons 2­18 Mgd million gallons per day 3­135 MMPA Materials and Minerals Policy Act 3­76 MOU Memorandum of Understanding 3­223 mph miles per hour 3­12 MSDS Material Safety Data Sheet 3­60 MSHA Mine Safety and Health Administration 1­21 mW/m2 milliwatt per square meter 3­90 MWMP Meteoric Water Mobility Procedure 3­78 NAAQS National Ambient Air Quality Standards 3­5

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NAC Nevada Administrative Code 2­7 NAD83 North American Datum 1983 1­2 NAG net acid generation 3­78 NAGPRA Native American Graves Protection and Repatriation Act of 1990 3­38 NAIP National Agricultural Imagery Program NCA National Conservation Area ES­3 NDE Nevada Department of Education NDEP Nevada Division of Environmental Protection 1­18 NDOA Nevada Department of Agriculture 3­3 NDOT Nevada Department of Transportation 1­19 NDOW Nevada Department of Wildlife 2­18 NDSP Nevada Division of State Parks 3­117 NDWR Nevada Division of Water Resources 2­55 NEPA National Environmental Policy Act ES­2 NESHAP National Emission Standard for Hazardous Air Pollutants 3­6 NHPA National Historic Preservation Act of 1966 3­38 NHPD Nevada Highway Patrol Division 3­138 NNHP Nevada Natural Heritage Program 3­168 NNPS Nevada Native Plant Society 3­168 NO2 nitrogen dioxide 3­6 NOI Notice of Intent 1­10 Non­PAG non­potentially acid generating 2­7 NOX oxides of nitrogen 3­20 NRCS Natural Resource Conservation Service 3­153 NRHP National Register of Historic Places NRS Nevada Revised Statutes 3­145 NSAAQS Nevada State Ambient Air Quality Standards 3­5 NSHD Nevada State Health Division 3­141 NSO BLM Nevada State Office 1­2 NSPL National System of Public Lands 1­1 NSPS New Source Performance Standards 3­6 NVAAQS Nevada Ambient Air Quality Standards NVCRIS Nevada Cultural Resources Information System 3­39 NV DOT Nevada Department of Transportation NVHC Nevada Health Centers, Inc. 3­142 NWIS National Water Information System 3­90 NWS National Weather Service 3­11 O3 Ozone 3­6 OLSG Old Lang Syne Group 3­82 opt ounces per ton OSHA Occupational Safety and Health Administration PASS Personal Achievement School Success 3­143 PAG potential acid generating 2­7 Pb Lead 3­6 PCMP Pershing County Master Plan 1­8 PCPI per capital personal income 3­130

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ABBREVIATIONS AND ACRONYMS

PCRI properties of cultural or religious importance 3­38 PCS petroleum contaminated soils 1­20 PCSD Pershing County School District 3­144 PCSO Pershing County Sheriff’s Office 3­138 PHREEQC PH­REdox­EQuilibrium­Chemistry 3­78 Plan Plan of Operations ES­1 PLS pure live seed 2­32 PM10 particulate matter with aerodynamic diameter less than 10 microns 1­11 PM2.5 particulate matter with aerodynamic diameter less than 2.5 microns 1­11 PMU population management unit 3­171 ppb parts per billion 3­6 PPE personal protective equipment 3­191 ppm parts per million 3­6 PRIA Public Rangelands Improvement Act of 1978 3­222 Project Hycroft Mine Expansion Project ES­1 PSD Prevention of Significant Deterioration 3­6 psi pounds per square inch 3­109 PVC polyvinyl chloride 1­23 RCE reclamation cost estimate RCRA Resource Conservation and Recovery Act 2­26 REMSA Regional Emergency Medical Services Authority 3­141 RFFAs reasonably foreseeable future actions 4­1 RFRA Religious Freedom Restoration Act RMIS Recreation Management Information System 3­119 RMP Resource Management Plan 3­203 ROD Record of Decision ROW right­of­way ES­1 RPC Regional Planning Commission 3­145 RV recreational vehicle 3­135 SARA Superfund Amendments and Reauthorization Act 3­56 SCORP Statewide Comprehensive Outdoor Recreation Plan 3­117 SEA Safe Explosives Act 3­56 SEM scanning electron microscopy 3­87 SG Sulphur Group 3­85 SHPO State Historic Preservation Office 3­43 SLAMS state and local air monitoring site 3­11 SO2 sulfur dioxide 3­6 SR State Route 1­1 SRA State Recreation Area 3­120 SWPPP Storm Water Pollution Prevention Plan 2­30 TCP traditional cultural property 3­52 TDS total dissolved solids 3­71 Title V Federal Operating Permit Program 3­6 tpd tons per day 3­137 tpy tons per year 3­8 TRI Toxics Release Inventory 3­56

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TSCA Toxic Substances Control Act 3­56 U.S. United States 1­7 UBC Uniform Building Code 3­76 USDC United States Department of Commerce UNR University of Nevada Reno 3­39 UPRR Union Pacific Railroad 3­100 USDA United States Department of Agriculture 3­12 USDA­FS United States Department of Agriculture­ Forest Services 3­12 USDOT United States Department of Transportation 3­183 USFS United States Forest Service 3­112 USFWS United States Fish and Wildlife Service 3­48 USGS United States Geological Survey 3­78 UTM Universal Transverse Mercator 1­2 VFD Volunteer Fire Department 3­139 VOC volatile organic compounds 3­21 VRM Visual Resource Management 3­202 WAD weak acid dissolvable 3­72 WCDCD Washoe County Department of Community Development 3­138 WCHD Washoe County Health District 3­137 WCSD Washoe County School District 3­145 WCSO Washoe County Sheriff’s Office 3­139 WEG wind erodibility group 3­154 WPCP Water Pollution Control Permit 1­23 WPD Winnemucca Police Department 3­138 WRF waste rock facility ES­1 WRFD Winnemucca Rural Fire Department 3­139 WRMP Waste Rock Management Plan 2­7 WWTF Wastewater Treatment Facility 3­136 XRD X­Ray diffraction 3­87

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6 LIST OF PREPARERS

6.1 BLM

Name Title EIS Area of Responsibility Degree and Experience Bureau of Land Management, Black Rock Field Office Project Lead, Geology, B.A. Geology Kathleen Minerals, and Energy, Noise, Transportation – 22 years of Geologist Rehberg Soils, Transportation, Public experience Safety M.S. Range Management Gerald Moritz BLM Contractor EIS Project Assistant 26 years experience Planning and B.S. Biology Lynn Ricci Environmental NEPA Compliance 20 years experience Coordinator Ph.D. Archaeology Kathryn Ataman Archaeologist Cultural Resources 24 years experience Ph.D. Anthropology Mark Hall Archaeologist Native American Consultation 19 years experience B.S. Range Ecology/Wildlife Celeste Wildlife, Migratory Birds, Wildlife Biologist Habitat Management Mimnaugh Special Status Species 7 years experience Outdoor Recreation Recreation and Visual M.A. Recreation Administration Joey Carmosino Planner Resources 5 years experience B.S. Wildlife Ecology and Wild Horse and Melanie Mirati Wild Horses Conservation Burro Specialist 8 years experience Realty Specialist Julie McKinnon Realty Specialist Lands, Realty, Access 4 years experience Rangeland B.S. Soils/Meteorology Rangeland Management, Ron Pearson Management 25 years experience Vegetation Specialist B.S. Geology Jeanette Black Hydrogeologist Water Resources 22 years experience BLM National B.S./M.S. Atmospheric Sciences Craig Nicholls Air Quality Operations Center 22 years experience Rangeland B.S. Environmental Science Rob Burton Management Invasive, Nonnative Species 12 years experience Specialist Geology (waste B.S./M.S./Ph.D. Geology Tom Olsen Hydrogeologist rock/geochemistry) 30 years experience B.S./M.S. Geology Fred Holzel Geologist Wastes (Solid and Hazardous) 22 years experience NLM National Social Values, Economics, Ph.D. Economics Joshua Sidon Operations Center Environmental Justice 6 years experience

6.2 Cooperating Agencies �

Name Title EIS Area of Responsibility Cooperating Agencies U.S. Environmental Protection Agency (EPA) Carter Jessop Physical Scientist Air and Water Resources Nevada Department of Wildlife Kenny Pirkle Biologist, Habitat Division Wildlife, Special Status Species, Migratory Birds

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6.3 Enviroscientists, Inc.

Name Title EIS Area of Responsibility Degree and Experience Enviroscientists, Inc. – EIS Third Party Contractor M.S. Geology Project Manager, Technical M.S. Resource Management Richard DeLong President Review, Geochemistry B.A. Geology 25 years experience Assistant Project Manager, M.S. Geology Opal Adams Vice President Visual Resources, Noise, B.S. Geology Technical Review 30 years experience Project Coordinator, Migratory B.A. Geography Senior Birds, Wildlife, Wild Horses, 11 years experience Melissa Sherman Specialist/Resource Invasive, Nonnative Species, Manager Special Status Species, Vegetation Chapters 1 and 2, Chapter 4, M.A. Geography LR2000 Database, Recreation, 10 years Senior Project Catherine Lee Transportation, Access and Specialist Public Safety, Social Values, Realty, Environmental Justice Keshab M.S. Environmental Science Senior Specialist Air and Atmospheric Resources Simkhada 8 years experience Environmental Geology, Minerals, and Energy, B.S. Hydrogeology Kaitlin Sweet Specialist Soils 4 years experience B.S. Mining and Mineral Lucy Downer Senior Specialist Wastes, Hazardous and Solid Processing 12 years experience WCRM, Principal M.A. Anthropology Ed Stoner Cultural Resources Archaeologist 25 years experience Ph.D. History Steve Mehls WCRM, Historian Cultural Resources 33 years experience Ph.D. Civil Engineering InTerraLogic, M.S. Hydrology­Ground Water Technical Reviewer –Water Fred Marinelli Senior Ground B.A. Geology Resources Water Hydrologist 30 years experience

Technical Reviewer – Geology, M.S. Geology­Geochemistry InTerraLogic, Brent Johnson Minerals, and Energy and Water 19 years experience Senior Geochemist Resources Brown­Buntin B.A. Zoology Associates, Inc., Baseline Noise Collection and Board Certification – Noise Jim Buntin Principal Reporting Control Engineering Consultant 38 years experience Professor and Ph.D. Political Science Chair, UNR Technical Reviewer­ Social 29 years experience Eric Herzik Department of Values and Economics Political Science GIS Data Management and B.S. Geography Jess Kohler GIS Specialist Figure Production 8 year experience

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7 CONSULTATION AND COORDINATION

7.1 Consultation with Federal, State, and Local Agencies

In preparing the EIS, the BLM communicated with and received input from federal, state, and local agencies, as well as private organizations and individuals. The following is a list of the agencies and private organizations that provided input:

Federal Government Agencies United States Environmental Protection Agency United States Fish and Wildlife Service National Park Service

State Government Agencies Nevada Department of Wildlife Nevada Natural Heritage Program

Local Governments ­ None currently identified. ­

Private Organizations ­ Hycroft Resources and Development, Inc. ­

7.2 Native American Coordination

The following federal legislation, regulations, and executive orders require government­to­ government consultation between federally­recognized Native American Tribes and federal agencies prior to taking any action that would affect Native American Tribes, including the following: the National Historic Preservation Act; the Native American Graves Protection and Repatriation Act; the American Indian Religious Freedom Act; Regulations 36 CFR 800, sections 106 and 119; and Executive Order 13007 (Sacred Sites). BLM Manual Section 8160, entitled “Native American Coordination and Consultation”, establishes agency policy regarding American Indians and integrates into all programs the management of resources valued by Native Americans.

The purpose of the government­to­government coordination process is to discuss the issues and concerns of a proposed Project with local Native American Tribes in the preliminary planning stages. Information gathered from the Native Americans would be used to develop Project alternatives and mitigation measures that would reduce the effects of the Project. In addition, the Tribes have access to cultural resources reports prepared for the Project, as well as sections of the EIS before they are reviewed by the general public.

The BLM has conducted coordination activities with the following Tribes:

• Fort McDermitt Paiute and Shoshone Tribe • Lovelock Paiute Colony • Pyramid Lake Paiute Tribe • Shoshone­Paiute Tribes of Duck Valley • Summit Lake Paiute Tribe • Winnemucca Indian Colony

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From the mailing of notification letters requesting consultation on the Proposed Action, the BLM held consultation meetings with the Fort McDermitt Paiute and Shoshone Tribe on June 10, 2011 and July 18, 2011, the Pyramid Lake Paiute Tribe on February 15, 2011, and the Summit Lake Paiute Tribe on February 19, 2011. Site visits were planned with the Fort McDermitt Paiute and Shoshone Tribe on July 1, July 14, and August 8, 2011, but the Tribe cancelled on all three occasions. The BLM cancelled a site visit scheduled for February 10, 2012. Consultation meetings between the BLM and the Fort McDermitt Paiute and Shoshone Tribe occurred in the proposed Project Area on February 17, 2012 and March 29, 2012. Additional consultation meetings between the BLM and the Tribe occurred on March 19, 2012 and April 16, 2012.

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8 PUBLIC INVOLVEMENT

8.1 Public Scoping

To initiate the public scoping process, the BLM published the Notice of Intent to Prepare an Environmental Impact Statement for the Proposed Hycroft Mine Expansion Project, Humboldt and Pershing Counties, Nevada in the Federal Register (Vol. 76, No. 63, page 18243) on Friday, April 1, 2011. A news release was also issued by the BLM on Tuesday, April 5, 2011, that stated the comment period to accept public comments was open for 90 days until June 29, 2011.

The BLM also held three public open house meetings as follows:

• May 10, 2011 from 6p.m. – 8p.m. at 820 6th Street in Lovelock, Nevada; • May 11, 2011 from 6p.m. – 8p.m. at 401 Cottonwood Street in Gerlach, Nevada; and • May 12, 2011 from 6p.m. – 8p.m. at 50 West Winnemucca Boulevard in Winnemucca, Nevada.

Dates for these meetings were also announced in separate correspondence and on the BLM Winnemucca District Office’s website at: www.blm.gov/nv/st/en/fo/wfo/blm_information/nepa0.html.

The public scoping meeting on May 10, 2011 was held in Lovelock, Nevada, at the Lovelock Community Center. A total of six members of the public attended this meeting and three written comments were provided.

The public scoping meeting on May 11, 2011, was held in Gerlach, Nevada, at the Gerlach Community Center. A total of six members of the public attended this meeting, but no written comments were provided.

The public scoping meeting on May 12, 2011, was held in Winnemucca, Nevada, at the Winnemucca Convention Center. A total of ten members of the public attended this meeting and two written comments were provided.

8.2 Public Meetings on the Draft EIS

To solicit public comments and feedback on the Draft EIS, the BLM published the Notice of Availability of the Draft Environmental Impact Statement for the Hycroft Mine Expansion, Humboldt and Pershing Counties, NV in the Federal Register (Vol. 77, No. 18, page 4360) on Friday, January 27, 2012. There was a 45­day public review period following the publication in the Federal Register.

The BLM held three public open house meetings as follows:

• February 14, 2012, from 6p.m.­8p.m. at 50 West Winnemucca Boulevard in Winnemucca, Nevada; • February 15, 2012, from 6p.m.­8p.m. at 820 6 th Street in Lovelock, Nevada; and • February 16, 2012, from 6p.m.­8p.m. at 401 Cottonwood Street in Gerlach, Nevada.

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8.3 Public Comments on the Draft EIS and Responses

A total of 79 comment letters were received on the Draft EIS listed below by Comment Letter Number and Commentor. Five comment letters contained substantive comments (indicated by an asterisk [*] below). �

Comment Letter Number Commentor Commentor Affiliation 1 Jean Public 2* Mel Hummel Mel Hummel Ranch 3 Molly Reeves 4 Chris Long Add Ons, inc. 5 Kevin Kunkel 6 Elizabeth Tissier Allied Nevada Gold Corp. 7 Scott A. Caldwell 8 Uriel Pullido Winnemucca Motors 9 Mark Gorman Gorman Family 10 Gwen Harris Nevada Resident 11 Stella Maestrejuan 12 Barbara Dunkan 13 Marian Tyree Humboldt County School District 14 Lupe Pulido 15 Matthew Hoffer Allied Nevada Gold Corp. 16 David C. Flint 17 Mike Bell Humboldt County Commission 18* Skip Canfield, Rebecca Lynn Nevada State Clearinghouse Palmer, Alexi Lanza 19 Winthrop A. Rowe 20 Dennis P. Bryan Western Lithium Corp 21 Catherine Clark 22 Chuck Van Houten 23 Scott E. Soderstrom 24 Steve Snyder 25 Graham L. Kelsey 26 Arthur Leger F.R.O.G. Consulting 27 Tracey M. Thom Allied Nevada Gold Corp. 28 Jim Cameron 29 Travis Mullins Komatsu Equipment Company 30 Clark West AGRU 31 Joseph D. Martini 32 Joe Adams EKS&H 33 John Ollson 34 Michael A. Warnert Hycroft 35 Jennifer Leavell Hycroft 36 Charles Evans Reese River Associates 37 Nancy J. Wolverson

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CHAPTER 8 PUBLIC INVOLVEMENT

38 Ross Barkley � 39 � Glen Carter � 40 � Gary W. Banbury � Allied Nevada Gold Corp. 41 � Chris Dunbar � Allied Nevada Gold Corp. 42 � Steven Gill � Allied Nevada Gold Corp. 43 � Hal D. Kirby � Allied Nevada Gold Corp. 44 � Warren D. Woods � Hycroft 45 � Dan Moore 46 Rebecca Rivenbark 47 Brandon Long 48 Greg Vroman 49 Heather Zagar 50 John Elliott 51 Todd Sylvester 52 Nathan J. Gordon EKS&H 53 Brian Korinek 54 Brandi Cotroneo Allied Nevada Gold Corp. 55 Patrick Sergott Allied Nevada Gold Corp. 56 David Hill 57 Greg Preston 58 Alissa Sanchez 59 Jeff Campbell Pershing County Economic Diversification 60 Brian Goerke 61 Peter P. Dupak 62 Bonnie Samms Hycroft 63 Loren Hunewill Hunewill Construction Company 64 Robert F. Birdsey J.P. Morgan 65 Mike Lortie Caterpillar Inc. 66 Brandy King 67 Heidi E. Lusby Pershing County Economic Diversification 68 Robert Chaudoin 69* Dave Cooper 70 John Currie Cashman Equipment 71 Jessica Irvin GIS Land Services 72 Tony Araquistain 73 James Kyte 74 Brian Korinek (repeat of comment letter #53) 76 Jamie Phelps Allied Nevada Gold Corp. 78* Kathleen Martyn Goforth U.S. Environmental Protection Agency 79* Billy A Bell Fort McDermitt Paiute and Shoshone Tribe

Copies of the five comment letters containing substantive comments are included for reference in Appendix A. The text of the specific substantive comments from these letters is included below with a response to address each comment.

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COMMENT LETTER 2 (MEL HUMMEL RANCH)

Comment 1

Would it be feasible to work jointly with Humboldt County, and the Geo­Thermal plant to cost share on getting Jungo Road paved.

Response 1

HDRI and the Blue Mountain Geothermal Plant each have independent road maintenance agreements with Humboldt County. As outlined in Section 2.1.9 of the Draft EIS HRDI provides road maintenance support to Humboldt County on Jungo road from the mine to Winnemucca. The maintenance activities include providing equipment, manpower and materials for maintenance, road watering, and general dust suppression activities. In addition, HRDI provides bus transport to and from the mine, which reduces the number of vehicle on the roads. This minimizes the generation of fugitive dust and the speed of the bus is under the control of HRDI. No change to the Final EIS text has been made to address the comment.

Comment 2

Another concern I have is the speed limit not being enforced.

Response 2

The Jungo Road is a Humboldt County Road. Therefore, the Humboldt County Sheriff has jurisdiction to enforce speed limits on the road. HRDI has entered into an agreement with Humboldt County Sheriff’s Department (HCSD) to provide necessary infrastructure upgrades to increase the range and reliability of radio communications outside of the Winnemucca area. This will allow the HCSD to provide an increased presence along the entire length of Jungo road without losing radio contact. Also see the response to Comment 1 in Comment Letter 2. No change to the Final EIS text has been made to address the comment.

COMMENT LETTER 18 (NEVADA STATE CLEARINGHOUSE – NEVADA DIVISION OF STATE LANDS)

Comment 1

Multiple use activities on Nevada’s public lands are supported and encouraged. There are continuing concerns about the cumulative visual impacts to public lands user’s experiences from certain activities (temporary and permanent). Some notable activities include proliferation of new roads, poorly­sited and design structures, lack of co­location of infrastructure and improper lighting, to name a few.

Cumulative visual impacts to public lands user’s experiences should be considered.

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CHAPTER 8  PUBLIC INVOLVEMENT

Response 1

Chapter 4 of the Draft EIS (pages 4­1 through 4­38) addresses the cumulative impacts associated with the Proposed Action. The following resources are analyzed in this chapter: air and atmosphere resources; cultural resources; geology, minerals, and energy; migratory birds; recreation; social values and economics; soils; special status species; transportation, access, and public safety; vegetation; visual resources; wastes, hazardous and solid; water quality and quantity; and wildlife. No change to the Final EIS text has been made to address this comment.

Comment 2

The following language is suggested that should be provided up front to applicants who purpose development on public lands that include lighting:

Utilize appropriate lighting:

� Utilize consistent lighting mitigation measures that follow “Dark Sky” lighting practices. � Effective lighting should have screens that do not allow that bulb to shine up or out. All proposed lighting shall be located to avoid light pollution onto any adjacent lands as viewed from a distance. All lighting fixtures shall be hooded and shielded, face downward, located within soffits and directed on to the pertinent site only, and away from adjacent parcels or areas. � A lighting plan should be submitted indicating the types of lighting and fixtures, the locations of fixtures, lumens of lighting, and the areas illuminated by the lighting plan. � Any required FAA lighting is exempt from this condition, but should be consolidated and minimized wherever possible.

Response 2

Section 2.1.15.5 of the Proposed Action portion of the Draft EIS addresses HRDI’s planned activities relative to lighting, which, in part, states “…utilize screening on proposed stationary lights and light plants. Lighting would be directed onto the pertinent site only and away from adjacent areas not in use with safety and proper lighting of the active work areas being the primary goal.” In addition, HRDI has proposed a lighting management plan, which is included as an appendix to the Plan of Operations that addresses measures to reduce light pollution for the existing source of light at the mining operation. No change to the Final EIS text has been made to address the comment.

Comment 3

In addition, the following mitigation measures should be employed.

Utilize building materials, colors and sit placement that are compatible with the natural environment

� Utilize consistent mitigation measures that address logical placement of improvements and use of appropriate screening and structure colors. Existing utility corridors, roads

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and areas of disturbed land should be utilized wherever possible. Proliferation of new roads should be avoided. � For example, the use of compatable paint colors on structures reduces the visual impacts of the built environment. Using screening, careful site placement, and cognitive use of earth­tone colors/materials that match the environment improve the user experience for others who might have different values than what is fostered by built environment activities. � Federal agencies should require mitigation measures as conditions of approval for all permanent and temporary applications.

Response 3

The Proposed Action is a continuation of an ongoing mining operation. As such, there are a limited number of structures that would be constructed. In addition, the Proposed Action does not propose any new roads that would not be reclaimed as part of the Project reclamation and closure. Please also see the response to Comment 2 of Comment Letter 18. No change to the Final EIS text has been made to address the comment.

COMMENT LETTER 69 (MR. DAVE COOPER)

Comment 1

There should have been at least 2 more observation points (KOP) that better represents the vantage points of recreational users in the Black Rock NCA, Wilderness areas and especially along the emigrant trail from which to analyze the visual impacts. One KOP located along the emigrant trail between Black Rock Point and the Rail road and another in the Black Rock Playa west of Black Rock Point. These are areas frequented by visitors to the Black Rock. Touring along the historic trail is another popular activity that takes place throughout the summer and fall. The mine is in full view along the trail route south of Black Rock Point to a point south of the railroad as well as over to Sulphur where the ingress egress route to the trail is located. Camping, land sailing, rocket launches, astronomy and other activities occur on the deep Black Rock Playa.

Response 1

The analysis of potential impacts of the Proposed Action and alternatives to visual resources is presented in the Draft EIS on pages 3­198 through 3­220. This analysis includes a presentation of where the Project would likely be visible at distances up to 20 miles (Figure 3.17.1). The Draft EIS established four key observation points (KOPs) at locations where there is substantial use by the public and where the Project would be visible. These four KOPs were chosen because they are representative of the potential visual effects of the Proposed Action. These KOPs are between one and ten miles from the planned Project activities. The addition of other KOPs would not improve the analysis or represent impacts that the Draft EIS had not otherwise disclosed. The following text has been added to the end of Section 3.17.2.2 “The existing mining operation lights are visible from the north and west in the Black Rock Desert, Black Rock Point, and along the Jungo Roads for approximately 15 miles west of the mine, as well as along portions of the Nobles Trail.”

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CHAPTER 8 PUBLIC INVOLVEMENT

Comment 2

One of the main reasons people seek out recreation adventures in the Black Rock NCA and wilderness areas is the solitude that this region offers. The vast open spaces and lack of any development or alternation to the landscape gives a visitor the sense of remoteness and being alone. That experience can be disrupted or impacted by development or large alterations to the surrounding landscape.

Response 2

The Proposed Action is the continuation of an ongoing mining operation that began operations in the late 1980s. Implementation of the Proposed Action would not change the land use or type of activities in the vicinity of the Project. The view of the Project from the Black Rock NCA or the wilderness areas should not appreciably change during daylight hours. During night hours the view of the Project should decrease due to the implementation of the HRDI light management plan, which is incorporated into the Proposed Action. No change to the Final EIS text has been made to address the comment.

Comment 3

The EIS focused on the visible light from the mine site while at Burning Man. The issue is not what affect there is or occurs during one week of the Burning Man event, the issue is the visible light emitted from the mine site that impacts the visitors and recreational users and the region through the rest of the year. Outside of Burning Man there are hundreds of other visitors to the Black Rock that come here for the remoteness and solitude that is part of the experience many of these people seek.

Lights from the Hycroft mine are the only lights visible from many areas within the Black Rock NCA, South Jackson Mountain Wilderness, Black Rock Desert Wilderness Black Rock Desert Playa, and some 25 to 30 miles away in the Calico Mountain Wilderness as well as the Granite Mountains. Thousands of people visit the NCA and wilderness areas each year to experience solitude or just immerse themselves into the vast open landscapes of the Black Rock. Many come to the playa to view the night skies and engage in astronomy. The lack of light pollution in the Black Rock is a major reason that this area is a great place for star gazing. The lights from the Hycroft mine are very visible from the deep playa where many go to camp and engage in a number of other activities and events each years such as rocket launching and land sailing. Visitors to the area have been confused at night thinking the Hycroft mine lights were the town of Gerlach. Once in the deep playa the only lights that are visible at night are at the Hycroft mine.

The real impact is to the visitors to the Black Rock NCA and visitors that tour the historic Applegate Lassen trail as well as visitors to the adjacent wilderness areas. They come to seek solitude in this remote region and that sense of remoteness and solitude is adversely impacted by outside sights coming from the contrasting colors of the mine tailings and most especially from the lights emitted at night in an otherwise natural and primitive landscape.

Implementing a lighting plan to lessen the impact of lights in this remote region of the Black Rock will help but will not completely eliminate the impacts to visitor experiences over the 20 year life of the mine.

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Response 3

See the response to Comment 2 of Comment Letter 18. No change to the Final EIS text has been made to address the comment.

COMMENT LETTER 78 (U.S. ENVIRONMENTAL PROTECTION AGENCY)

Comment 1

The DEIS does not provide sufficiently detailed information on water usage, water quality, and groundwater availability. Inconsistencies within the document make it difficult to verify the accuracy of the information presented, particularly with respect to groundwater quality and water usage.

Response 1

See responses to Comments 4, 6, and 7 of Comment Letter 76.

Comment 2

We recommend that the water quality data be examined more closely by analyzing the geochemical patterns of the surface water, groundwater, and mine process waters.

Response 2

See response to Comment 5 of Comment Letter 76.

Comment 3

We also recommend that BLM consider measures to further minimize impacts to various resources and include additional information on air quality, cumulative impacts, and other topics, as described in our detailed comments.

Response 3

See responses to Comments 22, 23, 24, and 28 of Comment Letter 76.

Comment 4

Water Usage and Water Rights

The U.S. Environmental Protection Agency is concerned about water rights and water usage associated with the Hycroft Mine Expansion Project. The Draft Environmental Impact Statement presents conflicting information on water rights and limited information on water usage, particularly with respect to the Proposed Action. The Hycroft Mine is located within the Black Rock Desert Hydrographic Basin, which has a sustained yield of approximately 30,000 acre­feet per year (pgs. 3­55; 3­71). Water rights totaling 21,808 afy have been distributed within the basin by manner of use, with 4,515 afy allocated to mining and milling (pg. 3­71). The DEIS

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CHAPTER 8 ­ P UBLIC I NVOLVEMENT states, in Chapter 1, that Hycroft Resources and Development, Inc. holds water rights for approximately 1.6 billion gallons of annual consumption, or 4,910.2 afy (pg. 1­17). In Chapter 3, however, the DEIS states that HRDI’s water rights include 2,910.83 afy within the basin (pg. 3­ 72).

The DEIS provides very limited information on water usage associated with the proposed project, except to note that current consumption is approximately 900 million gallons per year, or 2,762 afy (pg. 1­17). If this estimate is correct ­ and HRDI’s water rights are, indeed, 2,910.83 afy – this would mean that only 148 afy of water would be available for the proposed expansion of the Hycroft Mine.

In the permit application 1 submitted to the State of Nevada, HRDI states that the existing Brimstone Heap currently uses approximately 1,800 gallons/minute (2,903 afy), and the total maximum make­up water application rate for the proposed North Brimstone Heap facility would be 4,100 gpm (6,612 afy), which includes 2,300 gpm (3,709 afy) for the expanded heap. The maximum make­up water application rate for the proposed South Heap facility will be 2,700 gpm (4,354 afy). Therefore, the total make­up water demand for the Hycroft Mine Expansion project is expected to be 6,800 gpm (10,967 afy). According to the application, existing flow rights total 2,897 afy. Based on these numbers, it would appear that HRDI would need an additional 8,070 afy for the expansion of the Proposed Project. If that is correct, then the water usage associated with the Proposed Project would surpass the 4,515 afy currently allocated to mining and milling within the Black Rock Desert Hydrographic Basin.

Recommendations:

The Final Environmental Impact Statement should:

• Describe the consumptive water use associated with the Hycroft Mine, including current operations and the proposed expansion of the Mine. • Define the quantity of groundwater needed for the Proposed Action and the No Action Alternative. • Describe the extent of HRDI’s water rights, including whether HRDI holds water rights in multiple basins or strictly within the Black Rock Desert Hydrographic Basin. • Clarify whether the water usage associated with the Proposed Project will surpass mining and milling allocations within the Black Rock Desert Hydrographic Basin and, if so, what other sources would be used for the proposed Project. • Revise the text to eliminate any inconsistencies in the numbers used to quantify water rights and water usage.

1 Application for Permit to Appropriate the Public Waters of the State of Nevada, Application No. 81409, December 23, 2011.

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Response 4

In the mine/processing plan for the Proposed Action, which is outlined in detail in the HRDI Plan of Operations, the North and South Heap Leach Facilities do not operate at the same time; therefore, the statements in the Plan of Operations and the Draft EIS regarding the water usage is correct. HRDI’s water rights permitted with the State of Nevada is based on a long­term heap and processing strategy developed with the State Engineer and the values presented are in the HRDI water rights application. The best available information on water pumping and usage for the Proposed Action has been presented in the Draft EIS in Sections 1.9.2.5 and 2.1.6.3. No change to the Final EIS text has been made to address the comment.

Comment 5

Water Quality

According to the DEIS, surface water in the vicinity of the Hycroft Mine is very limited and consists of ephemeral streams and two mapped springs west of the Project facilities, which have accumulated ponded water at the clay borrow source area (pg. 3­60). The two springs are sampled semi­annually and the clay borrow ponded area was sampled in 1991, 2005, and 2011. Elevated concentrations of arsenic, chloride, fluoride, sulfate and total dissolved solids are seen at these three locations (pg. 3­67; table 3.7­4). In addition, concentrations of aluminum, antimony, beryllium, iron, lead, manganese, mercury, and pH are also elevated.

Groundwater quality data were collected in 2010 and 2011. A summary is presented in Table 3.7­5 and includes minimum and maximum concentrations, as well as reference values (pg. 3­ 68). Elevated concentrations of several constituents, including those detected in surface water samples, were also detected in the groundwater samples. Elevated concentrations of some constituents can be indicative of natural processes, including basic geology and geothermal activity, or potential contamination from mining processes.

According to the DEIS, there appear to be multiple aquifers in the Project Area vicinity, with the surface water data representing the shallow perched aquifer system. The DEIS concludes that the perched aquifer system does not appear to be connected to the deeper groundwater system; however, the DEIS provides no basis for this conclusion and, in fact, notes that fault zones may serve as conduits for vertical groundwater flow between shallow, deep, and basement systems (pg. 3­62). Although it is reasonable to assume that the springs likely represent the shallow perched aquifer system, we are concerned, nonetheless, that there may be connections between the perched aquifer and the deeper groundwater system. Without further information on baseline/reference conditions and more detailed information on the surface and groundwater samples, it is not possible to ascertain whether the systems are interconnected, or the degree of connectivity, based on the information presented in the DEIS.

One way to determine if there are potential connections between surface and groundwater systems is to examine the geochemistry of the samples collected, particularly the composition of major ions. The geochemistry of groundwater is the result of interactions between groundwater, minerals, rocks and soils; however, human activity can alter water chemistry by contributing additional ions. Elevated levels of some ions may indicate anthropogenic inputs of contaminants, including industrial discharges. Major ion data are often examined graphically, using Piper or

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Stiff Diagrams, to determine if there is a geochemical pattern that can be associated with a particular site or sample. In many cases, a geochemical pattern, or fingerprint, can be identified that can be used to characterize groundwater, surface water, and leachate.

In February 19 99, EPA published a report 2 on the characterization of mine leachates as part of an effort to develop a groundwater monitoring strategy for mine sites. EPA obtained water quality monitoring records from 22 heap leaching facilities in Nevada, including the Hycroft Mine, and four copper mines in Arizona. EPA determined that mine waste leachate has a distinct ionic composition that characterizes it at the source and can be used to differentiate it from adjacent surface water or groundwater. Geochemical monitoring results from the Hycroft Mine (1991 – 1993) show that the ionic composition of the barren pond is identical to that observed at the pregnant pond, providing a reliable signature for the mine process water. Furthermore, the ionic composition of the makeup water is distinguishable from that of the mine process water and that of the spring water nearby. The report notes that groundwater samples were not collected because it was considered unlikely that groundwater would be impacted from mining operations, due to the high rate of evaporation and the depth to groundwater (500 feet).

Recommendations:

Examine the ionic composition of the surface water samples and groundwater samples to verify that the ionic composition of the deeper groundwater is distinct from the ionic composition of the perched aquifer, as reflected by the spring box/surface water samples. Summarize this information in the FEIS.

Examine the major ion chemistry of the water samples at each of the monitoring wells and sampled sites to determine how groundwater varies spatially.

Determine the geochemical signature of the mine process water and makeup water and summarize this information in the FEIS.

Evaluate the ionic compositions of the mine process water, makeup water, surface water (springs), and groundwater and determine if they are unique. Ascertain whether there are any indications that the mine process water could be interacting with makeup water, surface water, or groundwater.

Compare these results with data collected and published previously, for example the data published in 1991­1993, to ensure that there have been no significant temporal shifts.

Data collected during the initial years of operation should also be examined, as should any samples representing baseline, or reference, conditions.

Discuss, in the FEIS, the influence of geothermal activity on water quality samples.

2 Characterization of Mine Leachates and the Development of a Ground­Water Monitoring Strategy for Mine Sites, EPA/600/R­99/007, February 1999.

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Response 5

Based on the analysis in Section 3.7.3.3 of the Draft EIS, the Proposed Action would not impact the ground water quality. Therefore, the analysis of the geochemical character of the ground water would not provide any information that would be needed in the assessment of the potential impacts of the Proposed Action or the alternatives. No change to the Final EIS text has been made to address the comment.

Comment 6

Contamination of Shallow Groundwater

The DEIS does not mention contamination of groundwater at the Hycroft Mine; however, contamination of shallow groundwater is discussed briefly in the Hycroft Mine amended Plan of Operations (September 2010; Appendix C – pg. 29). According to this document, the influence of process solution is still evident in several shallow investigation wells that are sampled quarterly. Monitoring data indicate that the residual effects of historic losses of process solutions on shallow groundwater are diminishing, since remediation measures were initiated in 2003. Furthermore, these concentrations do not appear to be migrating away from these areas and affecting the shallow groundwater system.

Recommendation:

The contamination of groundwater, due to historic causes or other reasons, should be discussed in the FEIS, including any remediation measures that have been implemented. Temporal and spatial trends relevant to the geochemical characterization of site waters should also be examined.

Response 6

The Final Plan for Permanent Closure of the Crofoot Heap Leach Facility (referenced in the Draft EIS) contains a complete assessment of the shallow ground water chemistry and background conditions. Also see response to Comment 5 of Comment Letter 76. No change to the Final EIS text has been made to address the comment.

Comment 7

Springs and Seeps

The DEIS states that the Proposed Action would not impact the flows of nearby springs or seeps, but offers insufficient justification for this conclusion (pg. 3­73). According to the DEIS, initial pump tests on the production and potable water wells showed favorable groundwater replenishment to the aquifer in the vicinity of the well, with projections of zero residual drain down (pg. 1­17). Pumping activities to date have confirmed these findings, with the wells producing adequate quantities of water and groundwater levels replenishing during the times of temporary closure (pg. 3­73). Detailed information on the type of testing performed (well tests, slug tests, or aquifer tests) is not presented in the DEIS. Likewise, as mentioned earlier, the DEIS provides very little information on water usage associated with the proposed project. Without

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more detailed information, we are unable to concur with this conclusion and remain concerned that the Proposed Action could impact the flows of nearby springs or seeps.

Recommendation:

The FEIS should provide the basis for the conclusion that the Proposed Action will not impact the flows of nearby springs or seeps. If well tests or aquifer tests were conducted to support that determination, such reports should be summarized and referenced in the FEIS and included in an Appendix.

Response 7

The following text has been added to Section 3.7.2.2.7 of the Final EIS that outlines the results of the ground water pump test work that was referenced in the Draft EIS and included in the Plan of Operations as Appendix C; “Based on the data from the pump tests conducted on the production wells, the anticipated drawdown at 1,500 feet from the production well after eight years would be approximately ten feet (Hydro­Search, Inc. 1988).” In addition, the following text has been added to the text and the summary of impacts text under Section 3.7.3.3.1 in the Final EIS; “In addition, the combination of the distance of the production wells from the springs and the limited amount of drawdown, would not likely result in changes to the spring flows.”

Comment 8

Open Pits

The DEIS concludes that pit lakes are not anticipated due to the depth of the groundwater and the limited extent of groundwater in the vicinity of the open pits; however, this conclusion is not clearly supported in the document. The discussion on pg. 3­74 references Table 3.7­2 regarding the elevation of the water table, and Table 2.1­2 regarding the planned depth of the Project open pits, yet depths of the open pits and elevations of the water table are not presented in either of these tables. Based on our rough estimates, using Figures 1.9.1 and 3.7.3 and Table 2.1­3, as well as Drawing 1 from the Plan of Operations, it appears that pit lakes could form at the Brimstone Pit and Central Pit. Furthermore, it seems possible that the shallow perched aquifer could transect the open pits, resulting in the formation of pit lakes unless dewatering activities were implemented.

Recommendations:

The FEIS should provide the basis, including supporting documentation, for concluding that pit lakes will not form at any of the open pit locations. Include a table that shows the proposed depths of the various pits along with the depth to groundwater at these locations, or revise Table 2.1­3 accordingly.

Overlay the locations of the pits onto Figure 3.7.3 in order to illustrate the groundwater table at each of the proposed pits.

Correct the incorrect references to figures and tables.

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Response 8

The reference to Table 3.7­2 has been changed to Table 3.7­3. The reference to Table 2.1­2 has been changed to Table 2.1­3. Table 2.1­2 has been revised to include a depth to ground water at each open pit.

Comment 9

Inconsistencies in the DEIS make it difficult to verify the accuracy of the information presented in the document. For example, Table 2.1­3 describes the proposed open pit parameters for the Brimstone, Boneyard, Center, and Bay Area Pits (pg. 2­3); however, the locations of the Center Pit and the Bay Area Pit are not shown on the figures in the DEIS that illustrate other pits, such as Figure 1.9.1 or Figure 2.1.1.

Recommendation:

Provide detailed maps in the FEIS that illustrate the locations of all the open pits, including the Center Pit and Bay Area Pit.

Response 9

The labels for the open pits on Figures 1.9.1 and 2.1.1, Tables 1.9­1, 1.9­2, 2.1­2, 2.1­3, 2.1­4, and 2.1­5, and the text in Chapters 1, 2, and 3 have been revised to reflect the consistent and correct names of the existing and proposed open pits.

Comment 10

According to the DEIS, the Boneyard and Bay Area Open Pits would be completely backfilled, the Center Open Pit would be backfilled up to 90 percent, and the Brimstone Open Pit would not be backfilled (pg. 2­41). Figures 2.1.10 and 2.1.11 illustrate the elevations of the proposed Brimstone Open Pit and Bay Area and Boneyard Open Pits using 2008, 2012, and 2024 topography. Elevations used in both these figures, however, do not concur with the depths presented in Table 2.1­3 for the Brimstone Pit, Bay Area Pit, and Boneyard Pit. For example, the profiles of the Brimstone Pit and the Bay Area/Boneyard Pits show that the elevation will go down to about 4,250 feet (fig. 2.1.10; fig. 2.1.11). Table 2.1­3, however, shows the following proposed pit depths: Brimstone Pit (4,300 feet), Bay Area Pit (4,350 feet), and Boneyard Pit (4,350 feet).

Recommendation:

Compare Figures 2.1.10 and 2.1.11 with Table 2.1­3 and verify that depths and elevations for the Brimstone Pit, Bay Area Pit, and Boneyard Pit are accurately depicted. Revise and correct figures and tables if necessary.

Explain why the Brimstone open pit will not be backfilled in the future.

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Response 10

The depths of the open pits in Table 2.1­2 have been corrected. The Proposed Action does not propose to backfill the Brimstone Open Pit and the issue of backfilling was not identified by the public during scoping.

Comment 11

Waste Rock Characterization Study

The DEIS states that results from the waste rock characterization study are discussed in detail in Section 2.1.3.1 and 3.7.2.3.5 to 3.7.2.3.6 (pg. 3­73); however, Sections 3.7.2.3.5 and 3.7.2.3.6 do not exist.

Recommendation:

Revise the text in the FEIS to correctly reference the appropriate sections that discuss the waste rock characterization study.

Response 11

The references to Sections 3.7.2.3.5 and 3.7.2.3.6 have been changes to 3.7.2.2.5 and 3.7.2.2.6, respectively, in the Final EIS.

Comment 12

Material types from the Hycroft deposit that are predicted to generate acid and leach potentially deleterious constituents when exposed to air and water include argillic, silica, and propylitic altered material that has been partially oxidized or unoxidized (pg. 3­71). The DEIS concludes, though, that predictive modeling indicates that seepage and runoff from the proposed waste rock facilities would not degrade waters of the State (SRK 2011). According to the DEIS, modeling also indicates that runoff from waste rock facility surfaces would be circum­neutral, with all chemical constituents below Nevada Division of Environmental Protection reference values (pg. 3­73). The DEIS does not, however, reference specific documents that support this conclusion.

Recommendation:

Include supporting documentation, within the FEIS, for the conclusion that seepage and runoff from the proposed waste rock facilities would be circum­neutral and are not expected to degrade waters of the state. Describe the infiltration and seepage rates that were used to make this determination. Explain exactly what is meant by “circum­ neutral” in this context.

Response 12

On page 3­73 and 3­74 the Draft EIS specifically references the report “SRK 2011b” which is titled “Hycroft Mine Final – Phase I Waste Rock Characterization Report”. Details are provided in the report. No changes to the Final EIS have been made to address the comment.

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Comment 13

Waste Rock Facilities

The DEIS states that the waste rock facilities have been designed to manage potentially acid generating materials and to minimize visual contrasts with natural topography (pg. 2­8). Such facilities will be constructed by end dumping waste rock from mine haul trucks over existing waste rock facilities, onto native alluvial soil, or into existing open pits. Twenty­four inches of non­PAG material, including 6 inches of growth media, would be deposited over waste rock material to limit the exposure to meteoric water during operation (pg. 2­8). The DEIS does not, however, describe what will be used at the bottom or base of the waste rock facilities.

Recommendation:

Describe what will be used underneath the waste rock facilities. If liners or compacted soil and/or clay will not be used, the FEIS should provide sufficient justification for the conclusion that such protective measures would not be necessary to prevent environmental degradation.

Response 13

As described in Section 2.1.3.1 the waste rock dumps would be constructed by end dumping “… onto native alluvial material, or into existing open pits.” The text at the top of page 3­74 of the Draft EIS discusses the results of the geochemical work on the waste rock, as well as the anticipated effect. Specifics of the modeling work are included in the specifically referenced report (SRK 2011b). No change to the Final EIS has been made to address this comment.

Comment 14

After closure, if any slopes of waste and development rock piles are left without encapsulation by non­PAG material, they would be sloped prior to placement of a two­foot thickness of non­PAG material, followed by six inches of growth media (pg. 2­42). These requirements differ, however, from those described in Section 2.1.3.1 (pg. 2­8) and Section 2.1.18.1 (pg. 2­41).

Recommendations:

Provide the basis for utilizing a greater thickness of non­PAG material and growth media (30 inches) on the slopes of the waste and development rock piles, as compared to the waste rock facilities (24 inches). Correct inconsistencies within the text regarding cover requirements, particularly in Sections 2.1.3.1 and 2.1.18.1.

Include a copy of the Waste Rock Management Plan in the FEIS within an appendix.

Response 14

The text on page 2­42 of the Draft EIS was incorrect. There would be a total of 24 inches of material and the top six inches of the 24 inches would be growth media. Therefore, on page 2­42

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of the Draft EIS the words “followed by” have been replaced with “, which would include” in the Final EIS.

Comment 15

Heap Leach Pads

The DEIS states that a growth media cover would be placed on the heap leach pads to a depth of six inches to isolate the process materials in the heap leach pads from storm water, as demonstrated on the Lewis heap leach facility (pg. 2­51). We note, however, that the cover requirements at waste rock facilities appear to be more stringent than at the heap leach pads, as the waste rock facilities utilize 24 inches of non­PAG material, including 6 inches of growth medium (pg. 2­41). Furthermore, the DEIS states that a soil cover is not needed for the purpose of limiting infiltration of meteoric water into the heaps (pg. 2­50).

Recommendations:

The FEIS should clarify why the requirements for the amount of cover differ for heap leach pads versus waste rock facilities.

Clarify whether the underlying media and the cover that will be used at the other heap leach facilities are, in fact, comparable to those used at the Lewis heap leach facility. If not, then results might not be comparable to the Lewis heap leach facility, and additional precautions may be needed.

Response 15

The growth media cover (six inches) would be the same for waste rock and heap leach facilities. The waste rock facilities would contain material that is not conducive to plant growth and thus material that has been classified geochemically as “non­PAG” would be added to the cover. The heap leach facilities would not contain this type of material as it affects metal recovery. No change to the Final EIS text has been made to address this comment.

Comment 16

The DEIS states that the Brimstone heap leach facility would be expanded by placing waste rock to the north of the heap to create an engineered (geotechnically sound) and compacted fill, on which the four process ponds would be located (pg. 2­10). EPA is concerned about the suitability of using waste rock as the base for four process ponds associated with the heap leach facility. Even if liners are used on top of the waste rock, we are concerned that the compacted fill and waste rock might shift due to varying loads on top of the facilities or seismic activity.

Recommendation:

The FEIS should discuss the suitability of using waste rock as the base for four process ponds in the heap leach facilities and provide supporting documentation to account for the geotechnical suitability of such an action.

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Response 16

The engineering criteria would be presented to NDEP through the NAC.445A regulatory process for a water pollution control permit. This program requires compliance with standard engineering practices and standards for geotechnical stability. The Design Report would include material and compaction specifications. Final Heap Leach designs have not been completed as part of this evaluation. To date, waste rock material from open pits at the Project have low permeability characteristics that would be amenable to use as engineered fill. Final engineering that is in progress indicates that little or no fill will be necessary. No change to the Final EIS text has been made to address this comment.

Comment 17

Post­Reclamation Monitoring and Maintenance

Heap effluent drainage from closed heaps would be monitored in accordance with the Water Pollution Control Permit. Post­closure vegetation monitoring would consist of surveys coordinated with the Bureau of Land Management and the Nevada Division of Environmental Protection. Post­mining ground water quality would be monitored according to the requirements established by the NDEP upon approval of the permanent closure plan, with the goal of demonstrating non­degradation of groundwater quality (pg. 2­54).

Table 2.1­15 illustrates the proposed reclamation schedule for the Hycroft Mine. According to this table, monitoring will be conducted until 2035 (pg. 2­33). The DEIS states that post­closure monitoring time frames are based on the regulatory minimum, but could be extended based on actual field conditions.

Recommendations:

Include a copy of the Hycroft Mine Monitoring Plan in the FEIS and describe what type of conditions would lead to extended monitoring.

Describe the groundwater monitoring that would be undertaken in accordance with existing permits.

Describe the water quality monitoring that will be required to ensure compliance with water quality standards. Describe the locations of all groundwater monitoring wells and points of compliance on the site, including screening intervals, parameters to be monitored, and monitoring frequencies.

Response 17

As described in Section 2.1.25 the monitoring would include heap effluent and ground water monitoring. The specifics of those monitoring activities would be defined and determined by the NDEP in the WPCP that would be issued for the expansion. This permit has yet to be issued by the NDEP. No change to the Final EIS text has been made to address this comment.

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Comment 18

National Ambient Air Quality Standards

On page 3­18 (Summary of Impact 3.2.3.3­2), the DEIS states that the modeled NO2 and SO2 1­ hour concentrations would be in exceedance of the NAAQS, but concludes: “Even with this impact, the Proposed Action would be in compliance with the FCAA. This is due to the NAAQS exceedance resulting from mobile and fugitive sources of NO2 and SO2. The mobile sources are regulated under Title II of the FCAA, which requires engine manufacturers to meet specific emission standards. The Proposed Action is regulated under Title I of the FCAA. Therefore, these mobile and fugitive sources are not considered when a permit is issued under Title I of the FCAA.” On page 3­26 (Summary of Impact 3.2.3.4­2), the DEIS sets forth the same type of rationale for finding that the No Action Alternative would be in compliance with the FCAA, notwithstanding the modeling results that indicate that there would be exceedances of the 1­hour NO2 and SO2 NAAQS. Further, this information is summarized in Table 2.3­1 (pgs. 2­61 and 2­ 62).

We recognize that some of the emissions sources associated with the Proposed Action would be covered by a permit issued by Bureau of Air Pollution Control, and some emissions sources associated with the Proposed Action (such as the combustion emissions from mobile equipment) would not be covered. We also recognize that the permit would be issued under a program approved by EPA as meeting the requirements of Title I of the FCAA, and that nearly all of the mobile sources are, to some degree, subject to emissions standards established by EPA under regulations promulgated under Title II of the FCAA. However, source­specific emissions standards are fundamentally different than health­based ambient air quality standards. For NEPA purposes, ambient air quality impact analyses should not distinguish between Title I sources and Title II sources, nor should such analyses discount emissions sources because they were manufactured to meet certain emissions standards. Instead, the impact analyses should take into account all Project­related emissions sources (fugitive and non­fugitive stationary, area, and mobile) and evaluate whether such sources, considered together, would cause or contribute to an exceedance of the NAAQS.

Based on the results presented in the DEIS, it is clear that the emissions sources associated with the Proposed Action would result in modeled exceedances of the one­hour NO2 and SO2 NAAQS. This does not mean that the Proposed Action would violate the FCAA, but it does indicate that the project would likely result in an adverse environmental impact.

Recommendation:

Revise the text in Section 3.2.3.3.1, Section 3.2.3.4.1, and Table 2.3­1 accordingly, and identify any feasible mitigation measures.

Response 18

The text in the Final EIS has been revised to retain the discussion of the reasoning for the impacts so as to better inform the reader and explain the impacts in the context of regulatory requirements. The latter half of the Summary of Impact 3.2.3.3­2 has been revised to read “The modeled NO2 and SO2 1­hour concentrations would be in exceedance of the NAAQS. The

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NAAQS exceedance results from mobile and fugitive sources of NO2 and SO2. The direct impacts from the Proposed Action would not exceed the NvAAQS. The Proposed Action activities would be authorized under an Operating Permit issued by the BAPC. The following environmental measure is recommended for implementation by HRDI. The following equipment emissions reduction measures could be implemented to reduce NO2 and SO2 emissions from the Project’s dedicated mining equipment:

• Engines are tuned to the engine manufacturer’s specification in accordance with an appropriate time frame; • Vehicles do not idle for more than five minutes (unless, in the case of certain drilling engines, it is necessary for the operating scope); • Engines are not tampered with in order to increase horsepower; • Use diesel fuel having a sulfur content of 15 parts per million or less, or other suitable alternative diesel fuel, unless such fuel cannot be reasonably procured in the market area; • Include particulate traps, oxidation catalysts and other suitable control devices on all mining equipment used at the Project site; and • The determination of which equipment is suitable for control devices should be made by an independent Licensed Mechanical Engineer. Equipment suitable for control devices may include drilling equipment, generators, compressors, graders, bulldozers, and dump trucks.”

Comment 19

On page 3­26 (Summary of Impact 3.2.3.4­2), the DEIS states that the NO2 and SO2 modeled concentrations would be expected to be above the NAAQS (except the 1­hour standards). The text is incorrect as written and should be revised to state the NO2 and SO2 modeled concentrations would be expected to be below the NAAQS (except the 1­hour standards). This error is repeated in Table 2.3­1 (pg. 2­61).

Recommendation:

Revise the text in Section 3.2.3.4.1 (pg. 3­26) and Table 2.3­1 (pg. 2­61), accordingly.

Response 19

The word above in Summary of Impact 3.2.3.4­2 and Table 2.3­1 has been changed to below in the Final EIS.

Comment 20

The DEIS describes and estimates air emissions from the proposed expansion of the Hycroft Mine. The DEIS states that PM10 and PM2.5 emissions are generated by almost all sources listed in Table 3.2­4, but this table lists background values for criteria pollutants instead of emission sources (pg. 3­16).

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Recommendation:

Revise the text in Section 3.2.3.3.1 to indicate the correct table.

Response 20

The words “listed in Table 3.2­4” have been removed in the Final EIS.

Comment 21

Mercury Emissions

The DEIS states that the current operations are permitted for a mercury emissions rate of 0.00529 ton/year, approximately 20 percent less than the projected emissions of the Proposed Action (pg. 3­26). The text appears to be incorrect as written, since 20% less than the projected emissions3 of the Proposed Action would be 0.02032 ton/year. Based on the information provided in the DEIS, it appears that mercury emissions associated with the Proposed Action will be 4­5 times higher than current emissions.

Recommendations:

Revise the text to provide the correct numbers.

Clarify whether the Mercury Operating Permit to Construct will need to be revised; and provide the status of any such revision.

Response 21

The sentence in the Final EIS has been revised to read “Based on the existing mercury operating permit, the current operations are permitted for a mercury emissions rate of 0.00529 tpy, which would be approximately 20 percent of the projected emissions from the Proposed Action (0.00254 tpy for the Proposed Action * 20 percent = 0.00508 tpy).”

Comment 22

Recommended Measures to Reduce Emissions

The area where the Proposed Project will be implemented is in “attainment – unclassifiable” for all pollutants having an air quality standard. In the interest of minimizing adverse impacts, EPA recommends consideration of measures to reduce emissions of criteria air pollutants and hazardous air pollutants.

Response 22

See response to Comment 18 of Comment Letter 76.

3 The projected emissions of mercury for the Proposed Action are 0.0254 tpy (pg. 3­23). Twenty percent of the projected emissions would be 0.2 * 0.0254 = 0.00508 tpy. Twenty percent less than the projected emissions would then be 0.0254 – 0.00508 = 0.02032.

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Comment 23

Recommendations:

• Equipment Emissions Mitigation Plan (EEMP) – The FEIS should identify the need for an EEMP. An EEMP will identify actions to reduce diesel particulate, CO, hydrocarbons, and NOx associated with construction activities. We recommend that the EEMP require that all construction­related engines:

o are tuned to the engine manufacturer’s specification in accordance with an appropriate time frame; o do not idle for more than five minutes (unless, in the case of certain drilling engines, it is necessary for the operating scope); o are not tampered with in order to increase engine horsepower; o include particulate traps, oxidation catalysts and other suitable control devices on all construction equipment used at the Project site; o use diesel fuel having a sulfur content of 15 parts per million or less, or other suitable alternative diesel fuel, unless such fuel cannot be reasonably procured in the market area; and o include control devices to reduce air emissions. The determination of which equipment is suitable for control devices should be made by an independent Licensed Mechanical Engineer. Equipment suitable for control devices may include drilling equipment, generators, compressors, graders, bulldozers, and dump trucks.

Response 23

See the response to Comment 18 of Comment Letter 76.

Comment 24

• Fugitive Dust Control Plan ­ The FEIS should identify the need for Fugitive Dust Control Plan. We recommend that it include these general recommendations:

o Stabilize open storage piles and by covering and/or applying water or chemical/organic dust palliative where appropriate. This applies to both inactive and active sites, during workdays, weekends, holidays, and windy conditions. o Install wind fencing and phase grading operations where appropriate, and operate water trucks for stabilization of surfaces under windy conditions; and o When hauling material and operating non­earthmoving equipment, prevent spillage and limit speeds to 15 miles per hour (mph). Limit speed of earth­ moving equipment to 10 mph.

Response 24

Section 2.1.15.1 of the Proposed Action portion of the Draft EIS outlines for the air quality protection measures committed to by HRDI. This includes a dust control plan, which is an

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appendix in the HRDI Plan of Operations. Table 2.1­13 of the Draft EIS (page 2­28) outlines the fugitive dust control measures to be implemented as part of the Proposed Action. No change to the Final EIS text has been made to address the comment.

Comment 25

In the cumulative impacts analysis, the DEIS notes that the Proposed Action would result in significant cumulative impacts to air quality due to the exceedances in the 1­hour NO2 and SO2 NAAQS (pg. 4­24). In contrast, the DEIS does not discuss the significance of the 1­hour exceedances in Chapter 3 and concludes, instead, that the Proposed Action would be in compliance with the FCAA, because the NAAQS exceedances result from mobile and fugitive sources of NO2 and SO2. [Mobile sources are regulated under Title II of the FCAA; whereas, the Proposed Action is regulated under Title I of the FCAA.]

Recommendation:

Discuss the significance of the 1­hour exceedances within Chapter 3 as well as Chapter 4 (Cumulative Impacts).

Response 25

The Draft EIS discusses the significance of the 1­hour exceedances page 3­18 and an additional recommended measure was added to the Final EIS in the Summary of Impact 3.2.3.3­2 to address this impact. In order to clarify the potential cumulative impacts and their relationship to the impacts discussed in Chapter 3, the Final EIS includes text that has been revised to state the following “The Proposed Action would result in a cumulative impact to Air and Atmosphere Resources that would exceed the federal one­hour standards for NO2 and SO2, which is the same impacts as the Proposed Action when considered individually.”

Comment 26

The DEIS includes estimates for the criteria pollutant emissions (PM10, SO2, NO2, and CO) from existing mining operations within the Cumulative Effects Study Area, but does not include similar estimates for Hazardous Air Pollutants.

Recommendation:

Provide estimates for Hazardous Air Pollutants from the other mining projects within the Cumulative Effects Study Area.

Response 26

The data used to complete the cumulative impacts analysis was provided by the BAPC. This data base does not have emission inventories of the hazardous air pollutant emissions. The database from the BAPC is the best available source of data for this cumulative analysis. The following text has been added to the Past and Present Actions Section under Section 4.4.1 “The facilities listed in Table 4.4­2, as well as vehicle use in the CESA would have emissions of HAPs. An inventory of these HAPs emissions is not readably available for use in this EIS.”

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Comment 27

The Cumulative Effects Study Area for water quality and quantity (surface and ground) is defined as the Devil’s Corral HUC 5 Watershed (pg. 4­8). The DEIS states that no impacts to groundwater quality or quantity were identified in the Proposed Action or alternatives, so the cumulative impacts analysis addresses only surface water. As we noted previously, however, contamination of shallow groundwater was discussed in the Hycroft Mine Expansion Project Amendment to Plan of Operations; therefore, the potential impacts to shallow groundwater and the existing contamination are issues that should be addressed in the FEIS. Furthermore, discrepancies were noted regarding the extent of HRDI’s water rights and water usage. Consumptive use of groundwater in a desert environment is a potentially significant issue and should be examined in greater detail.

Recommendations:

Extend the Cumulative Effects Study Area for groundwater to encompass the Black Rock Desert Hydrographic Basin.

Discuss the contamination of shallow and deep groundwater, due to historic causes or other reasons, in the FEIS. Discuss any remediation measures that have been implemented at the Hycroft Mine or any other mine within the newly defined Cumulative Effects Study Area.

Demonstrate whether there is sufficient groundwater for the lifetime of this Project and other reasonably foreseeable projects in the study area. Describe the current status of groundwater within the Black Rock Desert Hydrographic Basin, including whether it is over­allocated.

Discuss the potential effect of climate change on the Proposed Project and groundwater development.

Response 27

Given the limited extent of ground water use effects from the Proposed Action, the lack of any dewatering activities, and the lack of the development of a pit lake, the use of the Devil’s Corral as the cumulative effects study area is appropriate. The Proposed Action effects were easily encompassed by the use of this study area. No change to the Final EIS text has been made to address this comment.

Comment 28

Up to 2,172 acres of surface disturbance and vegetation removal would occur as a result of the Hycroft Mine expansion project. Such activities could adversely affect sage grouse, golden eagles, or other raptors, which are known to occur in and around the Project area. The BLM has recently issued Greater Sage­Grouse Conservation Guidance in the form of two Instructional Memoranda (IM No. 2012­043 and IM No. 2012­044) that are designed to guide both immediate and longer­term conservation actions aimed at conserving the greater sage­grouse and its

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sagebrush habitat in 10 Western states, including Nevada. Neither of these new IMs, however, are mentioned in the DEIS.

All raptor and owl species are protected under the Migratory Bird Treaty Act. The golden eagle and bald eagle also receive protection under the Bald and Golden Eagle Protection Act. In September 2009, the U.S. Fish and Wildlife Service finalized permit regulations under the BGEPA for the take of bald and golden eagles on a limited basis, provided that the take is compatible with preservation of the eagle and cannot be practicably avoided. The final rule states that if advanced conservation practices can be developed to significantly reduce take, the operator of a facility may qualify for a programmatic take permit. Most permits under the new regulations would authorize disturbance, rather than take. Projects or activities that could impact golden or bald eagles may require the preparation of an Eagle Conservation Plan.

Recommendations:

Work with the USFWS to ensure that requirements regarding the protection of eagles and other raptors are appropriately addressed in the FEIS.

Consider incorporating appropriate actions and management strategies included in the BLM’s Greater Sage Grouse IMs into the FEIS.

Mitigation and monitoring measures that result from consultation with USFWS to protect sensitive biological resources should be included in the FEIS and incorporated into the Record of Decision.

Discuss and identify potential compensatory mitigation for loss of sage­grouse habitat. Coordinate closely with the USFWS in the identification of such lands to ensure that compensatory lands are of comparable or superior quality. Discuss mechanisms that will ensure habitat selected for compensatory mitigation will be protected in perpetuity.

The FEIS should include a requirement for a Worker Environmental Awareness Training program in order to ensure project personnel and contractors are aware of their responsibility to implement the Best Management Practices and mitigation measures. Knowledge and practice of these measures should be the responsibility of all on­site personnel.

Response 28

The BLM has consulted with the USFWS and other wildlife agencies on the sensitive biological resources that are known or have the potential to occur in the Project Area. Recommended mitigation and monitoring activities for several special status species have been incorporated into the Draft EIS in Sections 3.14.3, 5.1.2 and 5.1.3. No additional mitigation or monitoring is recommended at this time and no change to the document has been made to address this comment.

The Project falls within the Majuba 1 PMU of the Majuba PMU Complex. The Majuba 1 PMU habitat was not assessed during the recent NDOW greater sage­grouse habitat characterization mapping effort; however, habitat and population information is available in the Majuba Complex

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PMU Plan and through recent communication with the NDOW indicates that the PMU does not have adequate composition and structure of habitat elements to support a year­round population of greater sage­grouse. Rather, the occasional sightings of greater sage­grouse are thought to reflect transient movement of individuals. Based on site­specific surveys, no greater sage­grouse or sign of use were observed within the Project Area and there are no known leks in the PMU.

Based on PMU information, the BMPs (outlined in IM No. 2012­044) as they pertain to locatable mineral operations and reclamation, “Equip tanks and other above ground facilities with structures or devices that discourage nesting of raptors and corvids” and “Restore disturbed areas at final reclamation to pre­disturbance landform and desired plant community” were determined to be adequate to reduce impacts to greater sage­grouse due to the Project. All power poles would be constructed with anti­perching devices to reduce predation as described in Section 2.1.6.1 of the Proposed Action. Little sagebrush (Artemisia arbuscula) and Wyoming big sagebrush (Artemisia tridentata) were added to Table 2­1­14, Recommended BLM Revegetation Seed Mixture, in the Final EIS.

Additionally, the USFWS has not indicated the need to compensate for habitat loss due to Project activities and; therefore, no additional mitigation measures for loss of potential greater sage­grouse habitat has been identified for this Project.

IMs No. 2012­043 and No. 2012­044 were issued by the BLM on December 27, 2011, and the Draft EIS was finalized prior to that date to ensure delivery to the EPA and OEPC; therefore, references to these IMs were not included in Section 3.14.1. References to these IMs have been added to Section 3.14.1 of the Final EIS.

The HRDI Environmental Department reviews all proposals for any areas of new surface disturbance. Authorization to proceed is required prior to initiation of any surface disturbance activities. The Environmental Department reviews all appropriate permit authorizations, BMPs, environmental protection measures, mitigation measures, and local, state, and federal regulations prior to giving any authorization to proceed. From this review, any necessary actions are taken to comply with the requirements prior to initiation of any activities. These actions could include denial of the activity.

Comment 29

Geology in the Project Area is shown on Figure 3.8.1, but the locations of the proposed facilities are not illustrated on the map.

Recommendation:

Overlay the locations of the pits, waste rock facilities, and heap leach pads as seen on Figure 2.1.1 onto Figure 3.8.1 to provide greater clarity to the reader.

Response 29

In an effort to have Figure 3.8.1 remain readable and not be too cluttered with data, only an outline of the total authorized and proposed surface disturbance is shown along with the geologic formations. No change to the Final EIS text has been made to address the comment.

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Comment 30

According to the DEIS, HRDI intends to explore the nature and extent of the geothermal resources at the Hycroft Mine and, if appropriate, develop those resources for purposes of power generation. From the proposed reclamation plans, it appears that there will be large flat surfaces at the top of many of the reclaimed mining facilities, including pits, waste rock facilities, heap leach pads, and process ponds. Such reclaimed mine surfaces may be appropriate for other types of power generation as well.

Recommendation:

Consider the suitability of the reclaimed mine surfaces for solar as well as geothermal energy development.

Response 30

The development of solar power generation is not part of the Proposed Action. In addition, the solar power as an alternative to the Proposed Action would not meet the purpose and need, as stated in Section 1.3 of the Draft EIS. No change to the Final EIS has been made to address the comment.

Comment 31

As noted in Chapter 4 (Cumulative Effects) of the DEIS, State and federal regulations require project operators of Notices and plans of operation to provide financial assurance to guarantee that surface disturbance due to mineral activities would be reclaimed when mineral exploration and mining activities have been completed (pgs. 4­27; 4­29; 4­30; 4­34; and 4­35). Typically, requirements regarding financial assurance for reclamation are noted in the Description of the Proposed Action and Alternatives (Chapter 2) of a DEIS. We found no further mention of such requirements in the DEIS for the Hycroft Mine Expansion Project, except for the mention of a Reclamation Bond Determination within Table 1.6­1 (Major Permits and Authorizations).

Recommendations:

The FEIS should:

Note any existing closure and reclamation bond for the Hycroft Mine, and discuss any additional bond that would be required for the Proposed Project. We recommend presenting this information in Chapter 2 of the FEIS.

Discuss the project’s need, if any, for long­term financial assurance. If long­term monitoring would be required, the FEIS should include at least a draft long­term financial assurance cost estimate and address how financial assurance requirements would be met (based on future monitoring), should the project proponent be no longer financially viable following the unplanned cessation or planned conclusion of operations.

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Response 31

The 43 CFR 3809 regulations do not require information regarding reclamation cost estimates (RCEs) and Long Term Trusts (LTTs) for the plan of operations to be considered complete for NEPA review. Therefore, BLM does not and will not require such information from the operator, or generate it, for NEPA review unless the 43 CFR 3809 regulations are changed. The reason the BLM regulations do not include RCEs/LTTs in the NEPA process is that NEPA requires the agency to analyze potential environmental impacts from a proposed major federal action. The RCEs/LTT estimates are a financial backup if the operator fails to comply with the reclamation requirements. Those estimates are not part of the environmental impact analysis. No change to the Final EIS text has been made to address the comment.

COMMENT LETTER 79 (FORT MCDERMITT PAIUTE AND SHOSHONE TRIBE)

Comment 1

The DEIS does not analyze an adequate range of alternatives. The DEIS only analyzes the Proposed Action and No Action Alternative. The DEIS states that “To date, no issues have arisen that would result in the formulation of an additional alternative(s). Three other alternatives were considered but eliminated from detailed analysis and are discussed in Section 2.2.2.” DEIS at ES­2. The DEIS identifies that the “alternatives were considered relative to the criteria in Section 2.1.” DEIS at 2­57. The DEIS further states:

The analysis of alternatives in this EIS is based on the following criteria: a) public or agency concern; b) technical feasibility; c) potential to reduce an environmental impact of the Proposed Action; d) ability to meet the purpose of and need for the Proposed Action; and e) compliance with regulatory and legal guidance (i.e., National Mineral Policy Act). . . . Alternatives to the Proposed Action derived through the scoping process (internal and public) include the following: No Action; Daylight Only Hours of Operation; Modified Exploration Activities; and Different WRF and Heap Leach Pad Configurations [bullet points omitted].” DEIS at 2­55.

The BLM indicates that the scoping process identified numerous environmental parameters that must be addressed in the EIS, but the “Alternatives Considered But Eliminated From Detailed Analysis” were not reflective of many of the major concerns identified and listed. DEIS at ES­2 and 3. Thus, the BLM failed to appropriately construct a reasonable range of alternatives given the scoping issues and issues that our Tribe submitted to the BLM (e.g., letter dated February 25, 2011). The BLM also failed to develop an appropriate range of alternatives given potential environmental impacts.

NEPA requires the development, study, and description of “appropriate alternatives to recommend courses of action in any proposal that involves unresolved conflicts concerning alternative uses of available resources.” Moreover, the BLM has the directive to analyze:

a reasonable number to cover the full spectrum of alternatives. . . . Reasonable alternatives include those that are practical or feasible from the technical and economic standpoint and using common sense, rather than simply desirable from the standpoint of the applicant.” BLM Handbook at 49, 50.

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Given the BLM's failure to analyze a reasonable range of alternatives and its failure to develop sufficient alternatives based on the scoping process and the best available information, the DEIS alternatives clearly and simply respond to the applicant's desired outcome. Even a preliminary constraints analysis for the proposed expansion would have demonstrated significant impacts of particular resources, including cultural resources and Native American values. Indeed, the DEIS identifies that the Proposed Action would result in adverse impacts to 21 sites that are eligible for the National Register of Historic Properties under the NHPA. DEIS at 2­63. These significant impacts alone provide a trigger for the need and development of reasonable alternatives, but the BLM avoids additional working alternatives by requiring treatment plans or other mitigation that still allow for the Proposed Action to be selected as the preferred alternative. These issues are errors of noncompliance.

Under NEPA, an EIS must analyze appropriate alternatives that conform to BLM land use plans. The DEIS states that the “Proposed Action conforms to the BLM's Sonoma Gerlach Management Framework Plan (MFP)”, basing the sole conformance criterion to Section .42 Minerals of the MFP that has the stated objective to “[m]ake all public lands and other federally owned minerals available for the exploration and development of mineral and material commodities.” DEIS at 1­8. The DEIS also states that the “Proposed Action conforms to the BLM's Paradise Denio MFP”, again using only a single conformance criterion to determine conformance – “[p]rovide the public with the opportunity to acquire minerals from the public lands to meet market demands.” DEIS at 1­8. The DEIS singles out a single section objective to base the document's conformance, rather than examining the entirety of MFPs for conformance. This error results in noncompliance between the DEIS and MFPs.

The range of alternatives analyzed fails to match the Federal Land Policy and Management Act of 1976 (Pub. L. 94­579, 94th Congress), as amended, as a multi­use mandate. FLPMA is the BLM's “organic act that establishes the agency's multiple­use mandate to serve present and future generations.” Instead, the alternatives simply respond to the applicant's revised Plan to expand mining operations. The DEIS fails to consider alternatives that meet the multiple­use mandate that would meet both the applicant's expansion plans and the BLM's mandate to manage lands in manner that will:

protect the quality of scientific, scenic, historical, ecological, environmental, air and atmospheric, water resource, and archeological values; that, where appropriate, will preserve and protect certain public lands in their natural condition; that will provide food and habitat for fish and wildlife and domestic animals; and that will provide for outdoor recreation and human occupancy and use. 43 USC 1701 § 102(8).

Thus, the DEIS must analyze an appropriate range of alternatives that meets that multiple­use mandate and conforms with the entirety of the MFP's.

Response 1

As noted by the commentor, the BLM is required to analyze a reasonable range of alternatives to the Proposed Action in their NEPA documents. For the Hycroft Mine Expansion Project EIS the alternatives to the Proposed Action are fully addressed under Section 2.2 of the Draft EIS. The range of alternatives discussed under Section 2.2 does meet the standard for an analysis of a reasonable range of alternatives, which includes those that are fully analyzed in the Draft EIS, as

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well as those that are considered but eliminated from detailed consideration. In addition, modification of facility design and placement in the early planning stages of the Project was agreed to by HRDI to minimize the effects of lighting on the Applegate Trail.

The summary of issues identified in the Draft EIS is outlined in Section 1.7, Scoping and Section 1.8, Issues. The Draft EIS addressed these issues in various ways, either through the consideration of an alternative, the analysis of an issue relative to an applicant­committed environmental protection measure incorporated into the Proposed Action, or analysis of an issue as an impact from the implementation of the Proposed Action, and where appropriate, addressed the issues with specific mitigation. All issues identified through scoping and summarized in Section 1.8 are addressed in the Draft EIS. No change to the Final EIS text has been made to address the comment.

Comment 2

Under NEPA, an EIS is required to inform the reader as to whether the project would conform with the applicable BLM land use plans. 43 CRF 1610.5­3, 43 CFR 2920.2­5. The BLM's planning regulations state that conformance or conformity means that “a resource management action shall be specifically provided for in the plan, or if not specifically mentioned, shall be clearly consistent with the terms, conditions, and decisions of the approved plan or amendment.” 43 CFR 1601.0­5(b). According to the BLM 2008 Handbook, if the proposed action does not conform to the existing land use plan, either the proposal should be modified to conform, or a land use plan amendment that allows the action to be considered. Moreover, if the existing land use plan is silent about an activity, the plan direction should be reviewed, including the broad and programmatic goals and objectives.

This EIS fails to make the required conformity determinations. First, although the DEIS states that it conforms to the MFPs, it fails to make any finding of conformance other than a single criterion of meeting Objective M­1 of the SGMFP and Objective M 1.0. DEIS at 1­8. It does not make any conclusions or findings of conformity with other salient parameters in the MFPs. The DEIS states only that “Proposed Action conforms to the BLM's Sonoma Gerlach Management Framework Plan (MFP)” and that the “Proposed Action conforms to the BLM's Paradise Denio MFP”. DEIS at 1­8. Those statements are not a finding on conformance. The DEIS must, and currently fails to, answer the questions: Does the project conform? Will this be multiple use?

Second, this DEIS fails to disclose whether or not the Proposed Action and alternatives have possible conflicts with the applicable BLM land use plans and/or MFPs. The NEPA question is compliance with land use plans: “Possible conflicts between the proposed action and the objectives of Federal . . . land use plans . . . .” The DEIS must disclose these possible conflicts. If that information is not in the DEIS, the DEIS must be revised so this disclosure can be subject to public notice and comment. This failure does not meet NEPA's requirements for full and reasonable disclosure of the Project land use plan conformity.

Third, the DEIS fails to address whether it conforms with the Winnemucca District Draft Resource Management Plan.

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Response 2

Sections 1.4.1 and 1.4.2 of the Draft EIS cite the two management framework plans (MFPs) for which this federal action is subject. According to the MFPs, the location of this action is open to activities under the mining law as indicated by the objectives quoted. These objectives were arrived at through a land use planning process and were subject to a conflict resolution analysis. The MFPs did not recommend this area be closed to mining. The MFPs envisioned mining activities under the mining law would go on. The nature of an area being open to activities under the mining law does not; however, exempt an activity from compliance with a multitude of laws, regulations and policies as listed, for example, in Section 1.5 (found on page 1­8) of the Draft EIS. The Winnemucca District RMP is in the final stages of completion toward becoming a final land use plan document. Until such time as it is final, the RMP will not be used to document land use plan conformance. No change to the Final EIS text has been made to address the comment.

Comment 3

If the Project does not comply with its land use plans (MFPs or RMPs), then the BLM is not permitted to approve the Project (unless, prior to Project approval, it amends the land use plans to eliminate the conflict– such an amendment also would be subject to NEPA review). The FLPMA question is compliance with the land use plans, as well, except that compliance is mandatory, as indicated in the Shasta Resources Council v. U.S. Dept. of Interior, 629 F.Supp.2d 1045, 1054 (E.D. Cal. 2009) case:

Furthermore, given the dictates of the 1993 RMP, it is eminently probable that the local easement alternative was precluded by statute. See 43 U.S.C. 1732(a) (“The Secretary shall manage the public lands ... in accordance with the land use plans developed by him under section 1712 ....”); Utah Shared Access Alliance v. Carpenter, 463 F.3d 1125, 1129 (10th Cir.2006) (“FLPMA prohibits the BLM from taking actions inconsistent with the provisions of RMPs.” (citing Norton v. S. Utah Wilderness Alliance, 542 U.S. 55, 69, 124 S.Ct. 2373, 159 L.Ed.2d 137 (2004); 43 U.S.C. § 1732(a); 43 C.F.R. § 1610.5­3)); Klamath Siskiyou Wildlands Ctr. v. Boody, 468 F.3d 549, 557 (9th Cir.2006) (providing that “provisions of FLPMA ... require BLM to manage public lands in accordance with resource management plans once they have been established”). Plaintiffs did not formally challenge the 1993 RMP when it was issued fifteen years ago (AR 43, 933, 1583­84), and any new challenge to its provisions would be untimely under the APA's six­year statute of limitations. See 5 U.S.C. § 704; 28 U.S.C. § 2401(a).

Although the facts of that case are not the facts for this Project, the central notion of BLM land use plans and the compliance with those land use plans (RMPs in the above case) remains, with citations. The DEIS must therefore answer the question: Does the Project comply with the any and all applicable land use plans? If not, the BLM may not approve the Project under the current land use plans. The DEIS is impermissibly mute on this critical issue. Therefore, it must be revised to include the required conformity analysis and recirculated for public review and comment.

A review of the Project impacts as identified in the DEIS, and those impacts that the BLM did not disclose in this DEIS, with respect to the BLM's applicable land use plans stated on Page 1­8 indicates that the Project would not conform with those land use plans.

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Response 3

See the response to Comment 2 for Comment Letter 77.

Comment 4

The DEIS's analysis of impacts on culturally significant resources, sacred sites, and exercise of Tribal religion is severely deficient. The DEIS greatly diminishes the importance of the area and its cultural/sacred resources on affected Tribes. The DEIS falsely states that no impacts will occur on sacred sites and religious freedom rights. The BLM failed to uphold its trust responsibilities to the Tribe by approving this Project with significant impacts to tribal trust resources and sacred areas. The BLM failed to provide meaningful and adequate mitigation measures that would protect tribal interests and resources.

Response 4

First, the issuance of a Draft EIS does not mean the proposed Project has been approved. The issuance of a Draft EIS is to disclose the impacts of the proposed Project. Second, in terms of trust responsibilities, the proposed Project Area is on private land and lands managed by the BLM. There are no tribal lands within the Project boundary and no statute giving the BLM responsibility to manage Indian lands or resources. There is no trust obligation (See South Fork Band v. US Dept. of Interior 3:08­CV­00616­LRH­RAM, pgs 16­17). No change to the Final EIS text has been made to address the comment.

Comment 5

The BLM failed to disclose impacts on the Pulpit Rock area sacred site. Preliminary Class I assessments of the area identify the Pulpit Rock area as a sacred site to Northern Paiute and Western Shoshone. This data is provided in an ethnographic document prepared for the BLM Nevada State Office in 20021. Bengston (2002) report identified that:

The focus of this document is to provide a contextual basis for ongoing consultations between the contemporary Northern Paiute and Western Shoshone tribes in Nevada and the BLM in northern Nevada (i.e., Winnemucca, Battle Mountain, Elko, Ely, and Carson City field offices; see Figure 1.1). This has been accomplished through a review, analysis, and synthesis of existing ethnographic and ethnohistoric literature and archival materials containing information on Traditional Cultural Properties, sacred sites, traditional lifeway areas, other culturally important places, Native American Graves Protection and Repatriation Act (NAGPRA) concerns, and other heritage issues between contemporary Northern Paiute and Western Shoshone tribes in Nevada.

Response 5

Bengston (2003) is a synthesis of several ethnographic sources. The information on Pulpit Rock comes from McGuckian (1996:270­271). In McGuckian (1996:270­271), Pulpit Rock is mentioned as a stop along a trail from the Seven Troughs Range to Rosebud Canyon to Pulpit Rock and then ending at Black Rock Point. McGuckian’s informant noted that the existing mining activity had already disturbed the trail route between Rosebud Canyon and Pulpit Rock.

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While the informant expressed concern over potential damage to Pulpit Rock, it was not identified as a sacred site as were the spires in Rosebud Canyon. An applicant­committed protection measure was added to the Final EIS in Section 2.1.15 that states the following: “HRDI would avoid Pulpit Rock and the known rock shelter locations within the Project Area by establishing a 250­foot setback from the cliff areas and Pulpit Rock for operational activities. HRDI may fence the Project boundary, but an arrangement would be reached with the Northern Paiute Tribes to allow them access to Pulpit Rock and the cliff face.”

Comment 6

To facilitate its use as a cultural resources management tool, this report has been divided into the following components. Chapter 1 contains introductory information, including a brief mention of the laws and other legislation pertinent to Native American consultation regarding the BLM. To provide a background and contextual basis for the current study, Chapters 2 and 3 provide a brief ethnohistoric and more extensive ethnographic information on the Northern Paiutes and Western Shoshones. Chapter 4 contains a brief description of the ethnographic/ethnohistoric studies undertaken to date in Nevada to identify culturally­significant places of importance to Northern Paiutes and Western Shoshones. The chapter also includes a list of the culturally­significant places identified during these studies, as well as a listing of other concerns and issues identified through Native American consultation for these projects. In addition to a discussion on the definition and evaluation of what is called a “Traditional Cultural Property” or TCP, Chapter 5 provides a discussion of culturally­significant property types, as well as potential mitigation treatment for these properties. Chapter 6 presents a listing by property type and brief discussion of culturally­significant sites identified during the archival and literature review. Other Native American issues, concerns, and recommendations, as ascertained in the studies discussed in Chapter 4, are discussed in Chapter 7. Chapter 8 contains recommendations for further studies, especially in regards to obvious research information gaps. Bengston Report (2002) at 1, 2.

The purpose of this Bengston 2002 Report, which BLM contracted with SWCA to provide, was for the purpose of having information on culturally significant areas, including sacred sites/areas, either for government­to­government consultation purposes or for resource management and planning purpose which includes NEPA.

The Bengston Report provided the Winnemucca District BLM with known sacred sites within the Project Area and adjacent lands no matter whether our Tribe submitted the information to BLM or not. The DEIS attempts to make the case that the BLM was unaware of any sacred sites/areas within the proposed expansion boundary (or adjacent areas) because our Tribe was unable to attend several site visits due to extenuating circumstances. BLM made the false determination that:

Tribal participants have not made any formal TCP designations or identified specific locations of religious or spiritual activity within or in close proximity to the Project Area.

Concern was expressed on what impact the Proposed Action would have on springs in the area, and Pulpit Rock. Some springs are considered sacred by the Northern Paiutes and Shoshone, and some are believed to be the home of supernatural creatures dubbed "Water Babies" (Hultkrantz 1986). Neither the springs or Pulpit Rock would be impacted by the Proposed

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Action; therefore, no direct or indirect impacts are anticipated from the Proposed Action. However, Native American coordination and consultation are ongoing. DEIS at 3­47, 3­48.

Response 6

36 CFR section 800.8(a)(2) states: “SHPO/THPOs, Indian Tribes and Native Hawaiian organizations, other consulting parties, and organizations and individuals who may be concerned with the possible effects of an agency action on historic properties should be prepared to consult with agencies early in the NEPA process, when the purpose of and need for the proposed action as well as the widest possible range of alternatives are under consideration.”

Letters requesting consultation with the potentially affected Tribes were sent out on December 23, 2010. In the consultation meeting between the BLM and the Fort McDermitt Paiute and Shoshone Tribe that occurred on June 10, 2011, the tribal chairman, while asking questions on how the proposed project would affect springs and Pulpit Rock, did not divulge any information on the significance or importance of Pulpit Rock and the surrounding area. The mine expansion was discussed with the Tribal chairman and tribal council in a consultation meeting on July 18, 2011 at Fort McDermitt. Site visits with the tribal chair and elders were planned on July 1, July 14, and August 8, 2011, but were canceled by the Tribe. The BLM cancelled a site visit scheduled for February 10, 2012. Consultation meetings between the BLM and the Fort McDermitt Paiute and Shoshone Tribe occurred in the proposed Project Area on February 17, 2012, and March 29, 2012. Additional consultation meetings between the BLM and the Tribe occurred on March 19, 2012, and April 16, 2012.

The following text has been added to Section 3.5.3.3­1 in the Final EIS in Section 3.5 to address this comment:

“McGuckian (1996:270­271) notes that Pulpit Rock was one of the spiritual sites along a trail that ran from Rosebud Canyon to Pulpit Rock and then to Black Rock Point. The trail was used by Northern Paiute men as part of a naming ceremony. McGuckian’s informant noted that the trail ran through the current area of the Hycroft Mine and was already disturbed by previously permitted mining operations.

From consultation in February 2012 and March 2012, the Fort McDermitt Paiute and Shoshone Tribe has asserted that the area around Pulpit Rock, including the cliff face to the east and northeast, is a sacred site. NRHP evaluation of this area would be dealt with in the cultural resources treatment plan. The Proposed Action would not impact Pulpit Rock or the cliff face based on a 250­foot buffer from the cliff face to the proposed North WRF; therefore, no direct or indirect impacts are anticipated from the Proposed Action.

Fort McDermitt Paiute and Shoshone Tribe also expressed concerns early on concerning the springs in the area. Some springs are considered sacred by the Northern Paiutes and Shoshone, and some are believed to be the home of supernatural creatures dubbed “Water Babies” (Hultkrantz 1986). The springs in the proposed Project Area would not be impacted by the Proposed Action; therefore, no direct or indirect impacts are anticipated from the Proposed Action.

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From the site visits, the Fort McDermitt Paiute and Shoshone Tribe expressed concerns that 35 isolated stone features may have cultural or spiritual significance. These isolated stone features may have been trail markers for the trail between Rosebud Canyon and Pulpit Rock. These features are within the proposed Project Area and may be adversely impacted by the Proposed Action. Evaluation and potential mitigation of these isolated stone features would be addressed in the cultural resources treatment plan.

■  Summary of Impact 3.5.3.3­1: The Proposed Action would not have any known impacts on Pulpit Rock or the cliff face. Isolated stone features would be impacted by the Proposed Action.

■  Recommended Mitigation Measure 3.5.3.3­1: Isolated stone features would be evaluated per the Memorandum of Agreement and the cultural resources treatment plan.

■  Effectiveness of Mitigation: The recommended mitigation would fulfill the requirements of Section 106 of the NHPA.”

Comment 7

That determination is false in several respects. First, the Proposed Action would directly and indirectly impact the Pulpit Rock sacred site. Second, formal consultation with our Tribe has not occurred.

Response 7

The BLM 8120­1 manual Guidelines for Conducting Tribal Consultation requires the appropriate line manager and tribal official being present for consultation to occur. On June 10, 2011, Fort McDermitt’s tribal chair met with the Black Rock Field Manager. The mine expansion plan was discussed in the consultation meeting held on July 18, 2011, at Fort McDermitt tribal headquarters. At this meeting the Humboldt River Field Manager was present representing the BLM, and Fort McDermitt was represented by the tribal chairman and council. Since the release of the Draft EIS, consultation meetings to discuss this proposed Project occurred on February 17, 2012, March 19, 2012, March 29, 2012, and April 16, 2012. In all meetings held in 2012, the tribal chair and a BLM line manager were present. Additional language was added to Section 3.5.2.2.1 in the Final EIS to include the recent consultation meetings which reads “The BLM cancelled a site visit scheduled for February 10, 2012. Consultation meetings between the BLM and the Fort McDermitt Paiute and Shoshone Tribe occurred in the proposed Project Area on February 17, 2012, and March 29, 2012. Additional consultation meetings between the BLM and the Tribe occurred on March 19, 2012, and April 16, 2012.”

Comment 8

The Pulpit Rock area is a sacred site to our Tribe. The Pulpit Rock sacred site includes area surrounding Pulpit Rock and extends northeast to encompass the basalt cliffs and surrounding area. The proposed expansion boundary would directly impact this sacred land. The Proposed Action would result in:

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• lost or reduced access to the sacred site, • physical destruction of the sacred site, • alteration of setting, • impairment of the character of the area, and • would render the sacred site unsuitable for religious purposes.

Response 8

The assertion of a site being sacred by a Tribe does not automatically confer to it National Register status, nor does it render the site inviolate. All sacred sites are required to be evaluated against the National Register criteria in 36 CFR 60.4. No property type has categorical eligibility; for sacred sites, this is further emphasized in the Advisory Council of Historic Preservation’s Final Rule (Federal Register Vol. 65, No. 239, pp. 77698­77739):

Properties of religious and cultural significance to Tribes must meet the National Register criteria in order to be considered ‘‘historic’’ and subject to section 106 consideration. The fact that a Tribe attaches religious and cultural significance to them does not make them ‘‘historic,’’ but neither does it preclude them from meeting the National Register criteria. The Federal agency makes the determination of eligibility, and disputes are ultimately resolved by the Keeper based on the secular National Register criteria. The Tribe is consulted but, again, the ultimate decision in the case of a dispute with the Federal agency finding by a SHPO/THPO, is the Keeper. (2000:77706)

The consultation meeting on February 17, 2012 made the BLM aware that the cliffs and area around Pulpit Rock are important to the Tribe. The Proposed Action does not impact Pulpit Rock or the cliffs, and the proponent agrees to keep operations 250 feet away from the cliff edge. In the consultation meeting on March 29, 2012, this was relayed to the Tribe. On that day, the BLM offered to do a site visit to that area, but the Tribe declined.

Recent rulings by the 9th Circuit Court state: “[…] the NHPA requires that the BLM protect only against adverse effects on the features of these areas that make them eligible for the National Register” (Te­Moak Tribe of Western Shoshone of Nevada v. United States Department of Interior, Case No.07­16336, p. 9015). Consultation with Fort McDermitt Paiute and Shoshone Tribe is on­going; further, the Proposed Action never threatened damage to Pulpit Rock and in the March 29, 2012, consultation meeting and the proponent has agreed to keep proposed operations 250 feet away from the cliff face. The text is Section 2.1.15 has been revised to incorporate this measure as follows “HRDI would avoid Pulpit Rock and the known rock shelter locations within the Project Area by establishing a 250­foot setback from the cliff areas and Pulpit Rock for operational activities. HRDI may fence the Project boundary, but an arrangement would be reached with the Northern Paiute Tribes to allow them access to Pulpit Rock and the cliff face.”

No mining operations are planned to occur in the area between Pulpit Rock and the cliff face. HRDI would fence their Project boundary, including Pulpit Rock and the cliff face and an arrangement would be reached with the Northern Paiute Tribes to allow them access to Pulpit Rock and the cliff face. The text in Section 2.1.15 has been revised to incorporate this measure as follows “HRDI would avoid Pulpit Rock and the known rock shelter locations within the Project

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Area by establishing a 250­foot setback from the cliff areas and Pulpit Rock for operational activities. HRDI may fence the Project boundary, but an arrangement would be reached with the Northern Paiute Tribes to allow them access to Pulpit Rock and the cliff face.”

Pulpit Rock and the cliff face would not be directly impacted by the Proposed Action. As noted by McGuckin’s informant in 1996, the trail between Rosebud Canyon and Pulpit Rock had already been impacted by mining. Visual simulation prepared for Native American consultation illustrates that only a small portion of the North WRF would be visible from Pulpit Rock. Consultation with the Tribe has occurred and will continue to occur for developing mitigation for the Proposed Action. Further, this is a subjective statement, which the courts have found do not constitute a substantial burden on the free exercise of religion (see Navajo Nation v. US Forest Service, 535 F. 3d 1058, p. 1070).

Comment 9

These impacts would be direct violations of EO 13007, NHPA, AIRFA/RFRA. Moreover, the DEIS provides no information on sacred/spiritual trails and the corresponding impacts analysis and mitigation, even though preliminary information has been provided to the BLM in Bengston's Report. BLM failed to examine their own documents to disclose tribal sacred areas. Federal mandates and executive orders require the BLM to consult with our Tribe in an appropriate government­to­government consultation. DEIS at 3­46 states:

In accordance with the NHPA (P.L. 89­665), the NEPA (P.L. 91­190), the FLPMA (P. L.94­579), the AIRFA (P.L. 95­341), the NAGPRA (P.L. 101­601), ARPA (P.L. 96­95), EO 13007 (Indian Sacred Sites, 1996), and EO 13175 (Consultation and Coordination with Indian Tribal Governments 2000), the BLM must provide affected Tribes, organizations, and/or individuals an opportunity to participate in, comment, and consult on proposed actions that might impact resources, sites, or activities of concern. Through consultation initiation with area tribes, BLM must attempt to identify specific traditional/cultural/spiritual sites, activities, and resources and limit, reduce, or possibly eliminate any negative impacts.

Response 9

There are no violations of EO 13007 since the Northern Paiute will still have access to Pulpit Rock and the cliff face. There are no violations of the NHPA since consultation is on­going and the Pulpit Rock area including the cliff face is being treated as if eligible for the NRHP. Finally, following recent 9th Circuit court rulings, there are no violations of AIRFA/Religious Freedom Restoration Act (RFRA) since the Proposed Action does not force individuals to “choose between following the tenants of their religion and receiving a governmental benefit or (2) coerces individuals to act contrary to their religious beliefs by the threat of civil or criminal sanctions” (South Fork Band v. US Dept. of Interior 3:08­CV­00616­LRH­RAM Order, p. 20). No change to the Final EIS text has been made to address the comment.

Comment 10

The BLM failed to use existing information and resources to identify and protect sacred sites and historic properties from the Proposed Action in this DEIS. The BLM failed to act in a

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Response 10

From the work of McGuckian (1996), which is the sole source of Bengston’s information on Pulpit Rock, the BLM has been aware of Pulpit Rock being important to some of the Northern Paiutes; specifically the Lovelock Paiute Tribe and the Pyramid Lake Paiute Tribe. McGuckian’s informant also reported that the trail between Rosebud Canyon and Pulpit Rock had already been directly impacted by mining activity.

The BLM has offered the Fort McDermitt Tribe a data sharing agreement for cultural resources. A document has been drafted and the BLM has been waiting since early 2011 either for further revisions from the Tribe, or the signing of the document. This topic was last brought up in a consultation meeting held March 19, 2012.

While Native American tribes can consult on the importance of a site, it is the government agency that makes determination on whether properties are eligible for the NRHP. In the Advisory Council of Historic Preservation’s Final Rule (Federal Register Vol. 65, No. 239, pp. 77706): “Properties of religious and cultural significance to Tribes must meet the National Register criteria in order to be considered ‘‘historic’’ and subject to section 106 consideration. The fact that a Tribe attaches religious and cultural significance to them does not make them ‘‘historic,’’ but neither does it preclude them from meeting the National Register criteria. The federal agency makes the determination of eligibility, and disputes are ultimately resolved by the Keeper based on the secular National Register criteria.” Further, Section 106 compliance does not require the Federal agency to consult on post­approval mitigation measures (see Te­Moak Tribe of Western Shoshone of Nevada v. US Dept. of Interior No. 07­16336 DC No. CV­05000279­LRH Opinion, p. 9014). No change to the Final EIS text has been made to address the comment.

Comment 11

The BLM and our Tribe have arranged meetings and site visits to the Project Area. Our Tribe has attended meetings with the BLM. Both BLM and our Tribe also have canceled various prearranged sites visits on numerous occasions. The BLM incorrectly used those planned site visits to meet their consultation obligations. The DEIS never mentions that our Tribe attended any meetings with the BLM regarding this project when in fact the Tribe did. Further, the BLM has used site visit meetings and cancellation of those meetings as a basis to prejudice our Tribe in this DEIS­NEPA process regarding consultation, even though BLM has canceled those meetings on occasion. The project site visit meetings are not formal government­to­government consultation.

Response 11

The BLM canceled the meeting scheduled for February 10, 2012. Fort McDermitt canceled the meetings scheduled on July 1, July 14, and August 8, 2011. Text has been added to

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Section 3.5.2.2.1 to state the following: “The BLM cancelled a site visit scheduled for February 10, 2012. Consultation meetings between the BLM and the Fort McDermitt Paiute and Shoshone Tribe occurred in the proposed Project Area on February 17, 2012 and March 29, 2012. Additional consultation meetings between the BLM and the Tribe occurred on March 19, 2012 and April 16, 2012.”

Comment 12

The DEIS fails to disclose how many sites important to Native Americans will be adversely affected by the Proposed Action or by any alternatives. The DEIS states incorrectly that “Neither the springs or Pulpit Rock would be impacted by the Proposed Action; therefore, no direct or indirect impacts are anticipated from the Proposed Action.” The BLM must revise the DEIS to provide the correct information. The DEIS also does not disclose the extent or magnitude of effects either on culturally significant eligible historic properties or on sacred sites/trails. It is not simply a numbers exercise of how many sites/locations. The DEIS then fails to address the cumulative impacts of the Proposed Action to examine extent and magnitude in addition to numbers of sites/locations, along with other past, present, and future actions on the cultural sites, cultural practices, and beliefs. The DEIS has no assessment of this question whatsoever. Furthermore, the DEIS fails to fully disclose why a fraction of the historic sites were eligible while others were not eligible on the National Register, and the BLM failed to seek Tribal input on eligible prehistoric sites or other culturally significant properties. No discussion was provided, nor did BLM seek any Tribal guidance/input, about how disputes between the Tribe and the BLM would be resolved regarding significance of historic properties. The BLM also did not seek any guidance/input from our Tribe as to what was an appropriate delineation of the Pulpit Rock sacred area. Instead, the BLM incorrectly reduced the sacred site to only include an extremely small area, or point. Thus, there is insufficient information and false information presented in this DEIS to satisfy requirements under NEPA, NHPA, EO 13007, AIRFA, and other mandates.

Because there are sacred areas and culturally significant sites/resources adjacent to and within the proposed expansion area, our Tribe requested that the BLM conduct an ethnographic study early on in the NEPA process for this project. Our Tribe made that request during various conversations with the BLM, as indicated and acknowledged by the BLM in a letter sent to the FMPST Chairman on February 13, 2012 (re: 8160, 1790, 3800, NV030.00). The BLM did not date their letter. The letter states:

During our conversations, you have requested that I require. . . the preparation of an ethnographic study. I have considered your request in light of the Draft EIS findings and reflective briefings by staff Archaeologists, and I have decided to not require an ethnographic study for this project.

Response 12

The Final EIS in Sections 3.5.2.2.1 and 3.5.3.3.1 have been revised to contain the relevant information that has been gleaned from consultation with the Tribe since February 1, 2012. The Draft EIS was released before site visits occurred with the Tribe.

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Direct and indirect impacts are detailed in Section 3.3.3.3 of the Draft EIS. The Cumulative Effects are described in Section 4.4.2 of the Draft EIS. A cultural resources treatment plan is being developed, which will describe in detail how prehistoric and historic sites will be mitigated and the logic behind the mitigation. The Native American Tribes will have 30 days to comment on a draft of the treatment plan.

From the ethnographic information in McGuckian (1996), the trail between Rosebud Canyon and Pulpit Rock has been directly impacted by previous mining.

A procedure is in place on how disputes are dealt with between Tribes and federal agencies on NRHP eligibility. As noted in the Advisory Council on Historic Preservation (ACHP’s) Final Rule: “The Federal agency makes the determination of eligibility, and disputes are ultimately resolved by the Keeper based on the secular National Register criteria.” See also 36 CFR Sec. 800.4(c)(2) and 800.5(c)(2)(iii).

While the Tribe did request this determination, the Tribe never came forward as to why such a survey was needed for this area. The BLM’s records indicated that Pulpit Rock was important to the Lovelock and Pyramid Lake Paiutes.

Comment 13

Our Tribe's determination is that site visits with BLM staff are completely inadequate to provide the necessary kind of information on the significance of the sacred sites and cultural areas within and adjacent to the Project Area in a manner that our Tribe, its elders, and spiritual leaders can provide. The BLM is fully aware of this and as such has precluded our Tribe from having a fair and reasonable opportunity to participate in the NEPA and NHPA process. The BLM has also precluded our Tribe from having a fair and reasonable opportunity to provide the necessary information about sacred areas/trails in this DEIS/NEPA process. The BLM offered to our Tribe to do an ethnographic study that would be available for future projects, but not for the Hycroft Mine Expansion Project. The BLM has thus precluded the Tribe from having a reasonable opportunity to participate in the resolution of adverse impacts as is required under 36 CFR 800.2(c)(ii)(A).

Response 13

The cited CFR is not relevant in this situation; the Tribe has not assumed the functions of the SHPO. The relevant CFR is 36 CFR 800.2(c)(2)(ii). Letters requesting consultation with the potentially affected Tribes went out on December 23, 2010. Consultation meetings between the BLM and the Fort McDermitt Paiute and Shoshone Tribe were held on June 10, 2011, and July 18, 2011. Site visits with the Tribal chair and elders were planned on July 1, July 14, and August 8, 2011, but were canceled by the Tribe. Since the issuance of the Draft EIS, consultation meetings have been held with the Tribe on February 17, 2012, March 19, 2012, March 29, 2012 and April 16, 2012. Text has been added to Section 3.5.2.2.1 to state the following: “The BLM cancelled a site visit scheduled for February 10, 2012. Consultation meetings between the BLM and the Fort McDermitt Paiute and Shoshone Tribe occurred in the proposed Project Area on February 17, 2012 and March 29, 2012. Additional consultation meetings between the BLM and the Tribe occurred on March 19, 2012 and April 16, 2012.”

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Comment 14

The BLM also failed to make a reasonable and good faith effort to attach religious and cultural experiences to the historic properties in the area of potential effects. 36 CFR 800.3(f). The DEIS largely ignores the significance of areas within and adjacent to the Project Area for our Tribe. For example, BLM failed to conduct an ethnographic study and failed to consider important existing information. The DEIS only mentions Pulpit Rock sacred area in one instance and provides no information about the importance of that site and other sacred areas. DEIS at 3­47. NEPA documents are required to “provide full and fair discussion” of environmental impacts. 40 CFR 1502.1. The courts have repeatedly affirmed that federal agencies take a hard look at the potential environmental consequences of a proposed action. Moreover, the BLM is required (1) to consider every significant aspect of the environmental impact of a proposed action and (2) to inform the public that it has indeed considered environmental concerns in its decision­making process. Both the BLM's refusal to conduct the ethnographic study in order to provide the necessary information and BLM's failure to disclose information in this DEIS are violations of NEPA.

Response 14

Letters requesting consultation with the potentially affected Tribes went out on December 23, 2010. Consultation meetings between the BLM and the Fort McDermitt Paiute and Shoshone Tribe were held on June 10, 2011 and July 18, 2011. Site visits with the Tribal chair and elders were planned on July 1, July 14, and August 8, 2011, but canceled by the Tribe. Since the issuance of the Draft EIS, consultation meetings have been held with the Tribe on February 17, 2012, March 19, 2012, March 29, 2012, and April 16, 2012. No change to the Final EIS text has been made to address the comment.

Comment 15

The federal government is charged with moral obligations of the highest responsibility and trust. Its conduct, as disclosed in the acts of those who represent it in dealings with the Indians, should therefore be judged by the most exacting fiduciary standards. The trust responsibility restrains government action that affects Indians and therefore is an important source of protection for Indian rights. This trust responsibility applies to all federal actions or projects and agencies that occur beyond Indian reservation boundaries. The Tribes have the right to maintain their religious practices in the same place and in the same manner as their ancestors have since time immemorial. The federal government's trust responsibilities to the Tribe are such that government actions must prevent adverse impacts on American Indian religious beliefs and practices, and to protect the spiritual lives of tribal members now and into the foreseeable future. In this case, the BLM has failed to uphold its trust obligations to the Tribe. Furthermore, the BLM has not complied with numerous Executive Orders that apply to federal agency actions and are specifically designed to protect Indian interests. E.g., EO 13007 (agencies must “avoid adversely affecting the physical integrity of such sacred sites”); EO 11593 (agencies shall “administer the cultural properties under their control in a spirit of stewardship and trusteeship”). Additionally, violation of NEPA, NHPA, EO 13007, AIRFA in this DEIS does not fulfill that trust responsibility.

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Response 15

The proposed Project Area is on private land and lands managed by the BLM. There are no tribal lands within the project boundary and no statute giving the BLM responsibility to manage Indian lands or resources. There is no trust obligation (See South Fork Band v. US Dept. of Interior 3:08­CV­00616­LRH­RAM, pgs 16­17).

The relevant language in EO 13007 is:

“Section 1. Accommodation of Sacred Sites. (a) In managing Federal lands, each executive branch agency with statutory or administrative responsibility for the management of Federal lands shall, to the extent practicable, permitted by law, and not clearly inconsistent with essential agency functions, (1) accommodate access to and ceremonial use of Indian sacred sites by Indian religious practitioners and (2) avoid adversely affecting the physical integrity of such sacred sites.

It is important to note is the clauses “to the extent practicable” and “not clearly inconsistent with essential agency functions”. EO 13007 does not render sacred sites inviolate, but does require the federal land management agency to look at alternatives and mitigations. Further, Section 4 of EO 13007 notes the order does not create: “any right, benefit, or trust responsibility, substantive or procedural, enforceable at law or equity by any party against the United States, its agencies officers, or any person.”

The Proposed Action would not damage or destroy Pulpit Rock. The proponent has agreed to keep operations 250 feet away from the cliff face as stated in the new applicant­committed protection measure included in Section 2.115 of the Final EIS. Consultation with the Tribe would continue throughout the Project. Text has been added to Section 3.5.2.2.1 to state the following: “The BLM cancelled a site visit scheduled for February 10, 2012. Consultation meetings between the BLM and the Fort McDermitt Paiute and Shoshone Tribe occurred in the proposed Project Area on February 17, 2012, and March 29, 2012. Additional consultation meetings between the BLM and the Tribe occurred on March 19, 2012 and April 16, 2012.”

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9 REFERENCES

Allen, Sharon. 2011. Personal communication (phone). Humboldt County Library Director. September 23, 2011.

AMEC Earth and Environmental. 2011. Hycroft Resources and Development, Inc. Heap Leach Pad Expansion Project Lewis Heap Leach Pad Design. April 20, 2011.

Applied Soil and Water Technologies, LLC (ASW). 2010. Lewis Leach Pad Evapotranspirative Cover Evaluation.

Bannister, Karen. 2011. Personal Communication (e­mail). Humboldt County Commissioner’s Office. September 22, 2011.

Barkdull Spencer Agency (BSA). 2011. Personal Communication (e­mail) from Beth Reid, Lovelock/Pershing County Chamber of Commerce with Elaine Barkdull­Spencer. September 14, 2011.

Beidleman, C. (ed) 2000. Partners in Flight Land Bird Conservation Plan. Version 1.0. Colorado Partners in Flight. Estes Park, Colorado.

Bengston, Ginny. 2003. Northern Paiute and Western Shoshone Land Use in Northern Nevada: A Class I Ethnographic/Ethnohistoric Overview. Reno: U. S. Department of the Interior, Bureau of Land Management.

Benolkin, Andrew. 2011. Personal communication (e­mail). Pershing County EMT Coordinator and Nevada Attitude Real Estate Broker. September 22, 2011.

Bertschi, Lisa. 2011. Personal communication (e­mail). Chairman, Gerlach General Improvement District. October 6, 2011.

Bjerke, Thom. 2011. Personal communication (phone). Lieutenant, Pershing County Sheriff’s Office. October 6, 2011.

Booth, Lisa. 2011. Personal communications (e­mail). City Clerk for City of Lovelock. September 15, 2011 and September 22, 2011.

Bowell, R.B; J.P. 2009. Gold Acres Geochemical Evaluation of Heap Rinsing of the Gold Acres Heap, Cortez Joint Venture, Nevada.

Brinkerhoff, Kathie. 2011. Personal communication (e­mail). Library Director, Pershing County Library. September 15, 2011.

Brown­Buntin Associates, Inc. (BBA). 2011. Environmental Noise Analysis Hycroft Mine Expansion Project, Humboldt and Pershing Counties, Nevada. September 20, 2011.

Bureau of Land Management (BLM). 1982a. Paradise­Denio MFP III. Winnemucca, Nevada.

_____. 1982b. Sonoma­Gerlach MFP III. Winnemucca, Nevada.

9­1 2489U.HycroftEIS.FEIS.FINAL.docx HYCROFT RESOURCES AND DEVELOPMENT INC. HYCROFT MINE EXPANSION PROJECT ­ FINAL ENVIRONMENTAL IMPACT STATEMENT ­

_____. 1986. Visual Resources Management, “Visual Resource Contrast Rating,” BLM Manual, Section 8431:1.

_____. 2008a. National Environmental Policy Act Handbook H­1790­1. Washington, D.C.

_____. 2008b. Lovelock Fire Station website. http://www.blm.gov/nv/st/en/fo/wfo/blm_programs/Fire_and_Aviation/Operations/lovelo ck_station.html. Accessed August 12, 2011.

_____. 2008c. McDermitt Fire Station website. http://www.blm.gov/nv/st/en/fo/wfo/ blm_programs/Fire_and_Aviation/Operations/mcdermitt_station.html. Accessed August 12, 2011.

_____. 2008d. USFS Paradise Valley Station website. http://www.blm.gov/nv/st/en/fo/ wfo/blm_programs/Fire_and_Aviation/Operations/pardise_valley.html. Accessed August 12, 2011.

_____. 2008e. Winnemucca Fire Station website. http://www.blm.gov/nv/st/en/fo/wfo/blm programs/Fire_and_Aviation/Operations/winnemucca_station.html. Accessed August 12, 2011.

_____. 2009. Supplemental Authorities to Consider in National Environmental Policy Act (NEPA) Documents. BLM Instruction Memorandum No. NV­2009­030, Change 1.

_____. 2010a. Rock Characterization Resources and Water Analysis Guidance for Mining Activities. BLM Instruction Memorandum No. NV­2010­014.

_____. 2010b. Sandman Exploration Project Environmental Assessment. Winnemucca, Nevada.

_____. 2010c. Visitor and Visitor Days by RMA. Recreation Management Information System.

_____. 2011a. 2011 Special Recreation Permit Decision. http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/winnemucca_field_office/n epa/recreation/0.Par.99547.File.dat/2011%20SRP%20Decision.pdf. Accessed August 10, 2011.

_____. 2011b. Land & Mineral Legacy Rehost System. http://www.blm.gov/landandresources reports/rptapp/criteria_select.cfm?rptId=1&APPCD=2&. Accessed September 16, 2011.

Bureau of Economic Analysis (BEA). 2009. CA25N: Total full­time and part­time employment by NAICS industry. http://www.bea.gov/regional/reis/action.cfm. Accessed November 18, 2011.

Call & Nicholas, Inc. 2010. FINAL – Slope Angle Recommendations for Hycroft Mine (Brimstone, Center, and Bay Pit Areas), memorandum to Mr. Scott Anderson (Allied Nevada Gold Corporation), March 17, 2010.

9­2 2489U.HycroftEIS.FEIS.FINAL.docx

CHAPTER 9 REFERENCES

City of Lovelock. 2011. Parks and Recreation website. http://www.cityoflovelock.com/ Offices/parks.html. Accessed August 10, 2011. Lovelock, Nevada.

City of Winnemucca. 2008. Your Mayor, City Council, and Administration website. http://www.winnemuccacity.org/Mayor.cfm. Accessed August 15, 2011.

_____. 2011. Winnemucca Parks website. http://www.winnemuccacity.org/Parks.cfm. Accessed August 10, 2011. Winnemucca, Nevada.

Childs, Rene. 2011. Personal communication (e­mail). 2009 and 2010 Annual Fiscal Report data for Pershing County. Pershing County Recorder­Auditor. September 28, 2011.

Cochrane, S. 2011. Personal Communication (E­mail), Steve Cochrane, Cyanco Environmental Safety and Health Manager. June 14, 2011.

Cooperative Libraries Automated Network (CLAN). 2010. Humboldt County Library website. http://www.clan.lib.nv.us/polpac/library/clan/HCL/humtest.htm. Accessed August 15, 2011.

Crim, Joe. 2011. Personal communication (phone). Public Works Director, City of Lovelock. October 4, 2011.

DeCarli, Steven. 2011. Personal communication (phone). Deputy, Washoe County Sheriff’s Department. September 27, 2011.

Department of Employment, Training, and Rehabilitation, Research & Analysis Bureau, Nevada Workforce Informer (DETR). 2011a. Labor Force. http://www.nevadaworkforce.com/cgi/dataanalysis/labForceReport.asp?menuchoice=LA BFORCE. Accessed August 4, 2011.

_____. 2011b. Nevada’s Largest Employers 1st Quarter 2011. http://www.nevadaworkforce.com/ ?PAGEID=67&SUBID=169. Accessed August 16, 2011.

_____. 2011c. Quarterly Employment and Wages. http://www.nevadaworkforce.com/cgi/data Analysis/IndustryReport.asp. Accessed August 18, 2011.

Department of Energy (DOE). 2000. Carbon Dioxide Emissions from the Generation of Electric Power in the United States. Available online at ftp://ftp.eia.doe.gov/environment/co2emiss00.pdf.

Donaldson, Lacey. 2011. Personal communication (e­mail). Pershing County Clerk­Treasurer. September 28, 2011.

Dunyon, D. Adam. 2011. Personal communication (e­mail). Mine Controller, HRDI. September 22, 2011.

9­3 2489U.HycroftEIS.FEIS.FINAL.docx HYCROFT RESOURCES AND DEVELOPMENT INC. HYCROFT MINE EXPANSION PROJECT ­ FINAL ENVIRONMENTAL IMPACT STATEMENT ­

Ebert, S. W., Groves, D.I., and Jones, J.K. 1996. Geology, Alteration, and Ore Controls of the Crofoot/Lewis Mine, Sulphur, Nevada: A Well­Preserved Hot­Springs Gold­Silver Deposit. In Coyner, A.R., and Fahey, P.L., eds., Geology and Ore Deposits of the American Cordillera: Geological Society of Nevada Symposium Proceedings, Reno/Sparks, Nevada. April 1995, p. 209­234.

Ebert, S.W. and R.O. Rye. 1997. Secondary precious­metal enrichment by steam­heated fluids in the Crofoot–Lewis hot spring gold– silver deposit and relation to paleoclimate. Economic Geology. Volume 92, pg. 578­600.

EMS World. 2011. Remote Rescue. http://www.emsworld.com/print/EMS­World/Remote­ Response/1$9810. Accessed August 15, 2011.

Environmental Protection Agency (EPA). 1974. Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety," EPA/ONAC 550/9­74­004. March 1974.

_____. 2005. Revision to the Guideline on Air Quality Models: Adoption of a Preferred General Purpose (Flat and Complex Terrain) Dispersion Models and Other Revisions; Final Rule. Federal Register, 40 CFR Part 51. November 9, 2005.

_____. 2006. National Ambient Air Quality Standards for Particulate Matter: Final Rule. Federal Register, 40 CFR Part 50. Office of Air Quality Planning and Standards. October 17, 2006.

_____. 2008a. Inventory of Greenhouse Gas Emissions and Sinks, 1990­2006. Washington, D.C.

_____. 2008b. National Ambient Air Quality Standards for Ozone: Final Rule. Federal Register, 40 CFR Parts 50 and 58. Office of Air Quality Planning and Standards. March 27, 2008.

_____. 2008c. National Ambient Air Quality Standards for Lead: Final Rule. Federal Register, 40 CFR Parts 50, 51, 53, and 58. Office of Air Quality Planning and Standards. November 12, 2008.

_____.2009. EPA AP­42 Emission Factors. Available online at http://www.epa.gov/ttn/chief/ap42/index.html.

_____. 2010a. Primary National Ambient Air Quality Standards for Nitrogen Dioxide: Final Rule. Federal Register, 40 CFR Parts 50 and 58. Office of Air Quality Planning and Standards. February 9, 2010.

_____. 2010b. Primary National Ambient Air Quality Standard for Sulfur Dioxide: Final Rule. Federal Register, 40 CFR Parts 50, 53, and 58. Office of Air Quality Planning and Standards. June 22, 2010.

_____. 2011a. Climate Change: Science. State of Knowledge website. Available online at: http://www.epa.gov/climatechange/science/stateofknowledge.html.

9­4 2489U.HycroftEIS.FEIS.FINAL.docx

CHAPTER 9 REFERENCES

_____. 2011b. Review of National Ambient Air Quality Standard for Carbon Monoxide: Final Rule. Federal Register, 40 CFR Parts 50, 53, and 58. Office of Air Quality Planning and Standards. August 31, 2011.

_____. 2011c. List of Water Systems in SDWIS; Humboldt County, Nevada. http://oaspub.epa.gov/enviro/sdw_query_v2.get_list?wsys_name=&fac_search=fac_begi nning&fac_county=HUMBOLDT&pop_serv=500&pop_serv=3300&pop_serv=10000& pop_serv=100000&pop_serv=100001&sys_status=active&pop_serv=&wsys_id=&fac_st ate=NV&last_fac_name=&page=1&query_results=&total_rows_found=. Accessed August 11, 2011.

_____. 2011d. List of Water Systems in SDWIS; Pershing County, Nevada. http://oaspub.epa.gov/enviro/sdw_query_v2.get_list?wsys_name=&fac_search=fac_begi nning&fac_county=PERSHING&pop_serv=500&pop_serv=3300&pop_serv=10000&po p_serv=100000&pop_serv=100001&sys_status=active&pop_serv=&wsys_id=&fac_state =NV&last_fac_name=&page=1&query_results=&total_rows_found=. Accessed August 11, 2011.

_____. 2011e. List of Water Systems in SDWIS; Washoe County, Nevada. http://oaspub.epa.gov/enviro/sdw_query_v2.get_list?wsys_name=&fac_search=fac_begi nning&fac_county=WASHOE&pop_serv=500&pop_serv=3300&pop_serv=10000&pop _serv=100000&pop_serv=100001&sys_status=active&pop_serv=&wsys_id=&fac_state =NV&last_fac_name=&page=1&query_results=&total_rows_found=. Accessed August 11, 2011.

Enviroscientists, Inc. (Enviroscientists). 2011a. Environmental Justice Evaluation, Hycroft Mine Expansion Project, Humboldt and Pershing Counties, Nevada. Reno, Nevada.

_____. 2011b. Hycroft Resources and Development, Inc. ­ Hycroft Mine Expansion Project Environmental Impact Statement – Public Scoping Comment Summary, Issues and Alternatives Identification. Reno, Nevada. July 29, 2011; Amended September 12, 2011.

_____. 2011c. Livestock Grazing Evaluation, Hycroft Mine Expansion Project, Humboldt and Pershing Counties, Nevada. Reno, Nevada.

_____. 2011d. Noxious Weeds, Invasive and Nonnative Species Evaluation, Hycroft Mine Expansion Project, Humboldt and Pershing Counties, Nevada. Reno, Nevada.

_____. 2011e. Paleontological Resources Evaluation, Hycroft Mine Expansion Project, Humboldt and Pershing Counties, Nevada. Reno, Nevada.

_____. 2011f. Wild Horses Evaluation, Hycroft Mine Expansion Project, Humboldt and Pershing Counties, Nevada. Reno, Nevada.

_____. 2011g. Dark Skies Evaluation, Hycroft Mine Expansion Project, Humboldt and Pershing Counties, Nevada. Reno, Nevada.

_____. 2011h. Air Quality Impact Assessment Report. Reno, Nevada.

9­5 2489U.HycroftEIS.FEIS.FINAL.docx HYCROFT RESOURCES AND DEVELOPMENT INC. HYCROFT MINE EXPANSION PROJECT ­ FINAL ENVIRONMENTAL IMPACT STATEMENT ­

Federal Motor Carrier Safety Administration (FMCSA). 2001. Comparative Risks of Hazardous Materials and Non­Hazardous Materials Truck Shipments Accidents/Incidents. Prepared by Battelle: Columbus, Ohio.

Fox, Daniel. 2011. Personal communication (e­mail). Superintendant, Pershing County School District. September 27, 2011.

Garrett, B. 2011. Personal Communication (E­mail), Ben Garrett, Humboldt County Roads Superintendant, Humboldt County Road Department. May 16, 2011.

Garrison, Dave. 2011. Personal communication (phone). Sergeant, Winnemucca Police Department. October 4, 2011.

Gooch, Shawn. 2011. Personal communication (phone). Chief, Gerlach Volunteer Fire Department. October 3, 2011.

Great Basin Bird Observatory (GBBO). 2010. Nevada Comprehensive Bird Conservation Plan. Version 1.0. Reno, Nevada.

Greene, Brian. 2011. Personal communication (e­mail). Road Superintendant, Pershing County. September 27, 2011.

Guy Hays, Heidi and Steven F. Mehls. 2011 Supplemental Report For: A Class III Inventory of 12,133 Acres at the Hycroft Mine, Humboldt and Pershing Counties, Nevada By Barbara Malinky Harmon, M.A. and An Historic Context for Sulphur, Nevada By Robert R. Kautz, Ph.D. Prepared by Western Cultural Resources Management, Inc. for Allied Nevada Gold Corporation/Hycroft Mines.

Harmon, Barbara Malinky, Robert R. Kautz, Margo Memmott, and Theresa Simpson. 2011. A Class III Inventory of 12,133 Acres at the Hycroft Mine, Humboldt and Pershing Counties, Nevada. Prepared by Kautz Environmental Consultants Inc. for Allied Nevada Gold Corporation/Hycroft Mines.

Harris, Thomas and John L. Dobra. 2009. The Economic Impacts of Reopening the Coeur Rochester Mine in Pershing County, Nevada. Center for Regional Economic Development, University of Nevada, Reno.

Herron, G.B., C.A. Mortimore, and M.S. Rawlings. 1985. Nevada Raptors: Their Biology and Management. Nevada Department of Wildlife, Biological Bulletin No. 8.

Hultkrantz, Ake. 1986. Mythology and religious concepts. In Warren L. D'Azevedo (ed.) Handbook of the North American Indians: Great Basin. Washington, DC: Smithsonian Institution, pp. 630­640.

Humboldt County. 1998. Humboldt County Policy Plan for Public Lands. Winnemucca, Nevada.

_____. 2002. Humboldt County Regional Master Plan. Winnemucca, Nevada.

9­6 2489U.HycroftEIS.FEIS.FINAL.docx

CHAPTER 9 REFERENCES

_____. 2005. Regional Planning Commission website. http://www.hcnv.us/planning/ members.htm. Accessed August 15, 2011.

Humboldt County Comptroller’s Office (HCCO). 2009. Humboldt County, Nevada: Comprehensive Annual Financial Report for the fiscal year ended June 30, 2009. Winnemucca, Nevada.

_____. 2010. Humboldt County, Nevada: Comprehensive Annual Financial Report for the fiscal year ended June 30, 2010. Winnemucca, Nevada.

Humboldt Development Authority (HDA). 2010. Housing. http://hdanv.org/life/housing/. Accessed September 15, 2011.

Humboldt General Hospital (HGH). 2011. Emergency Medical Services. http://www. hghospital.ws/Hospital_Services/Emergency_Medical_Services.aspx. Accessed August 15, 2011.

Hycroft Resources and Development, Inc. (HRDI). 1999. Final Closure Report Lewis Mine NEV89017. April 1999.

_____. 2010a. Hycroft Mine (NVN­064641) Amendment to Plan of Operations Hycroft Mine Expansion Project. April 2010; revised September 2010. Winnemucca, Nevada.

_____. 2010b. Hycroft Mine Waste Rock Management Plan. Winnemucca, Nevada.

_____. 2010c. Hycroft Mine Solid and Hazardous Waste Management Plan. Winnemucca, Nevada.

_____. 2010d. Hycroft Mine Noxious Weed Monitoring and Control Plan. Winnemucca, Nevada.

_____. 2010e. Hycroft Mine Monitoring Plan. Winnemucca, Nevada.

_____. 2011a. Hycroft Mine Lighting Management Plan. Winnemucca, Nevada.

_____. 2011b. Annual Revenue data. September 29, 2011.

Hydro­Search, Inc. 1988. Ground­Water Supply Evaluation and Development, Crofoot Project, Humboldt County, Nevada. March 31, 1988.

Imus, S. 1992. Topsoil Management: How to Identify and Salvage Suitable Growth Media for Vegetation. In Proceedings of the Successful Mine Reclamation: What Works Conference. Sparks, Nevada. 1992. pg 259­266.

Intergovernmental Panel on Climate Change (IPCC). 2007. Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change. Cambridge University Press. Cambridge, England and New York, New York. Available online at: http://www.ipcc.ch/publications_and_data/publications_ipcc_fourth_assessment_report_ wg1_report_the_physical_science_basis.htm.

9­7 2489U.HycroftEIS.FEIS.FINAL.docx HYCROFT RESOURCES AND DEVELOPMENT INC. HYCROFT MINE EXPANSION PROJECT ­ FINAL ENVIRONMENTAL IMPACT STATEMENT ­

International Code Council (ICC). 2006. Uniform Building Code.

JBR Environmental Consultants, Inc. (JBR). 2010a. Baseline Survey Report, Hycroft Mine, Mine Expansion Project. September 20, 2010; revised April 18, 2011. Reno, Nevada.

_____. 2010b. Hycroft Mine Waters of the U.S. Jurisdictional Determination, SPK­2008­0111, Humboldt County, Nevada. Reno, Nevada.

_____. 2011a. Baseline Survey Report Addendum 2011 Nesting Golden Eagle Survey and Bat Survey, Hycroft Mine, Mine Expansion Project. Reno, Nevada. June 7, 2011.

_____. 2011b. Baseline Survey Report Addendum II, 2011 Nesting Raptor Survey with NDOW Flight Data, Hycroft Mine Expansion Project. Reno, Nevada. July 21, 2011.

Johnson, M.G. 1977. Geology and Mineral Deposits of Pershing County, NV: Nevada Bureau of Mines and Geology Bulletin 89, 115 p.

Johnson, Michael. 2011. Personal communication (e­mail). Pershing County Director of Planning and Building. August 8 and September 27, 2011.

Kilgore, Ed. 2011. Personal communication (phone). Humboldt County Sheriff. September 22, 2011.

Lyman, Greg. 2011. Personal communication (phone). Engineer, Lovelock Meadows Water District. September 29, 2011.

Mancebo, Michael. 2011. Personal communication (e­mail). City of Lovelock Chief of Police. September 23, 2011.

Maurins, Arnie. 2011. Personal communication (e­mail). Director, Washoe County Library System. September 25, 2011.

McBride, Terri. 2010. Letter Report: RE: Cultural Resource Inventories within the Hycroft Mine’s Expanded Plan of Operations Boundary. Prepared by Kautz Environmental Consultants Inc. for Bureau of Land Management, Winnemucca District Office.

McGuckian, Margaret. 1996. Management Uses of Contemporary Ethnography and the Lovelock Paiute. Master’s Thesis. University of Nevada, Reno. p. 270­271.

McNamara, Bev. 2011. Personal communication (phone). Operations and Facilities Secretary, Humboldt County School District. September 27, 2011.

Mendez, Rolando R. 2011. Personal communication (letter) with Edward Stoner dated August 19, 2011. Winnemucca, NV.

The Mines Group. 2002. Hycroft Mine Reclamation Plan (Revision and Update), Reclamation Permit No. 0134, BLM Case File N26­87­002P. December 1, 2002. Updated March 2003.

9­8 2489U.HycroftEIS.FEIS.FINAL.docx

CHAPTER 9 REFERENCES

______. 2004. Hycroft Mine Groundwater Evaluation Report, Water Pollution Control Permit No. 60013, BLM Case File N26­87­002P.

Murbarger, Nell. 1959. “The Mine at Sulphur, Nevada,” Desert Magazine, 22(7), July, 1959.

National Park Service (NPS). 1990. How to Apply the National Register Criteria for Evaluation. National Register Bulletin 15. National Park Service, Interagency Resources Division, Department of the Interior, Washington, D.C.

Natural Resources Conservation Service (NRCS). 2011. Soil Survey of Humboldt County, Nevada, West Part. Soil Survey of Pershing County, Nevada, West Part. http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx

Nelson, Kate. 2011. Personal Communication (e­mail) from Lisa Bertschi, Chair, Gerlach General Improvement District, with Kate Nelson, Senior Engineer from Farr West Engineering. October 24, 2011.

Nevada Department of Education (NDE). 2010. 2007­2011 Enrollment by School. http://nde.doe.nv.gov/Resources.htm#Enrollment. Accessed August 9, 2011.

_____. 2010a. Directory of Licensed Personnel 2007 – 2008. http://nde.doe.nv.gov/Resources/ 2010­2011LicensedStaffDirectory.pdf. Accessed August 9, 2011.

_____. 2010b. Directory of Licensed Personnel 2008 – 2009. http://nde.doe.nv.gov/Resources/ 2010­2011LicensedStaffDirectory.pdf. Accessed August 9, 2011.

_____. 2010c. Directory of Licensed Personnel 2009 – 2010. http://nde.doe.nv.gov/Resources 2010­2011LicensedStaffDirectory.pdf. Accessed August 9, 2011.

_____. 2010d. Directory of Licensed Personnel 2010 – 2011. http://nde.doe.nv.gov/Resources 2010­2011LicensedStaffDirectory.pdf Accessed August 9, 2011.

Nevada Department of Environmental Protection (NDEP). 2007. State of Nevada Solid Waste Management Plan 2007. Carson City, Nevada.

_____. 2011. Lockwood Regional Landfill website. http://ndep.nv.gov/bwm/ landfill_lockwood.htm. Accessed August 12, 2011.

Nevada Department of Taxation (NV DOT). 2009. Annual Report Fiscal 2007­2008. Carson City, Nevada.

_____. 2010a. 2009­2010 Statistical Analysis of the Roll. Carson City, Nevada.

_____. 2010b. Annual Report Fiscal 2008­2009. Carson City, Nevada.

_____. 2011a. 2010­2011 Statistical Analysis of the Roll. Carson City, Nevada.

_____. 2011b. Annual Report Fiscal 2009­2010. Carson City, Nevada.

9­9 2489U.HycroftEIS.FEIS.FINAL.docx HYCROFT RESOURCES AND DEVELOPMENT INC. HYCROFT MINE EXPANSION PROJECT ­ FINAL ENVIRONMENTAL IMPACT STATEMENT ­

Nevada Department of Transportation (NDOT). 2009. 2009 Annual Traffic Report. Carson City, Nevada.

Nevada Department of Wildlife (NDOW). 2004. Greater Sage­Grouse Conservation Plan for Nevada and Eastern California. First Edition. June 30, 2004.

_____. 2010. 2010 Final Bighorn Sheep Hunt Results by Hunt and Unit Group. http://www.ndow.org/hunt/resources/odds/pdf/2010/ bighorn%20hunt%20 results%202010.pdf. Accessed August 10, 2011.

_____. 2010a. 2010 Mule Deer Harvest by Hunt Unit and Group. http://www.ndow.org/hunt/ resources/odds/pdf/2010/deer%20harvest%20by%20hunt%202010.pdf. Accessed August 10, 2011.

_____. 2010b. 2010 Pronghorn Harvest by Hunt and Unit Group. http://www.ndow.org/ hunt/resources/odds/pdf/2010/pronghorn%20harvest%202010.pdf. Accessed August 10, 2011.

Nevada Division of Environment Protection, Bureau of Air Pollution Control (NDEP­BAPC). 2011. Nevada Air Quality Trend Report 1998­2009. Available online at: http://ndep.nv.gov/ baqp/ monitoring/docs/trend.pdf.

Nevada Division of Water Resources (NDWR). 2011. Hydrographic Area Summary: Black Rock Desert. http://water.nv.gov/data/underground/printableSummary.cfm?basin=028&CFID=828447 &CFTOKEN=22585845. Accessed October 2, 2011.

Nevada Health Centers, Inc. (NVHC) 2011. Nevada Health Centers, Inc. Clinics website. http://www.nvrhc.org/centers.cfm. Accessed September 29, 2011.

Nevada State Demographer’s Office (NSDO). 2010. Nevada County Population Projections 2010 to 2030. http://nvdemography.org/ wp­content/uploads/2010/10/2010­ to­2030­Population­Projections­Report­REVISED­102610.pdf. Accessed August 4, 2011.

Nevada State Health Division (NSHD). 2011. Community Health Nursing website. http://health.nv.gov/CommunityHealthNursing.htm. Accessed September 22, 2011.

Nevada State Journal 26 November 1952:2

Olsen, Alan. 2011. Personal communication (e­mail). City of Winnemucca Fire Chief. September 20, 2011.

Paher, Stanley W. 1970. Nevada Ghost Towns and Mining Camps. Nevada Publications, Las Vegas.

Paquette, Anita. 2011. Personal communication (e­mail and phone). Indigent/Transient Services Coordinator, Humboldt County. September 29, 2011.

9­10 2489U.HycroftEIS.FEIS.FINAL.docx

CHAPTER 9 REFERENCES

Pershing County. 2002. Pershing County Master Plan. Lovelock, Nevada.

_____. 2010. Natural Resource and Land Use Plan. Lovelock, Nevada.

_____. 2011a. Ambulance website. http://pershingcounty.net/index.php/Fire­Department/ ambulance.html. Accessed August 15, 2011.

_____. 2011b. Board Appointments website. http://pershingcounty.net/index.php/Pershing­ County­Services/board­appointments.html. Accessed August 15, 2011.

_____. 2011c. County Library website. http://pershingcounty.net/index.php/County­Library/. Accessed August 15, 2011.

_____. 2011d. Fire Department website. http://pershingcounty.net/index.php/Fire­Department/. Accessed August 12, 2011.

Schrempp, Ron. 2011. Personal communication (e­mail). Chief, Winnemucca Rural Fire Department. September 29, 2011.

Schroeder, M.A., J.R. Young, and C.E. Braun. 1999. Sage­grouse (Centrocercus urophasianus). A. Poole and F. Gill, editors. Number 425, The Birds of North America. The Academy of Natural Sciences, Philadelphia, Pennsylvania and the American Ornithologists’ Union. Washington, D.C.

Schulze, Richard H. 1991. Practical Guide to Air Dispersion Modeling. Trinity Consultants, Inc. Dallas, Texas.

Shevenell, L. 1996. Statewide Potential Evapotranspiration Maps for Nevada. Nevada Bureau of Mines and Geology Report 48.

Singer, S. Fred and Dennis T. Avery. 2007. Unstoppable Global Warming: Every 1,500 Years. Rowman & Littlefield Publishers, Inc. Lanham, Maryland.

Soloman, Lawrence. 2008. The Deniers: the World Renowned Scientists Who Stood Up Against Global Warming Hysteria, Political Persecution, and Fraud and Those Who Are Too Fearful to Do So. Richard Vigilante Books. Minneapolis, Minnesota.

Songer, Pat. 2011. Personal Communication (e­mail). Director of Emergency Medical Services, Humboldt General Hospital. September 15, 2011.

Spencer, Roy. 2008. Climate Confusion: How Global Warming Hysteria Leads to Bad Science, Pandering Politicians and Misguided Policies that Hurt the Poor. Encounter Books, New York, New York.

SRK Consulting (SRK). 2010a. Preliminary Engineering Design Report for the Hycroft Mine Expansion Project. March 31, 2010.

9­11 2489U.HycroftEIS.FEIS.FINAL.docx HYCROFT RESOURCES AND DEVELOPMENT INC. HYCROFT MINE EXPANSION PROJECT ­ FINAL ENVIRONMENTAL IMPACT STATEMENT ­

_____. 2010b. Rock and Water Baseline Characterization for the Hycroft Mine Expansion Project.

_____. 2011a. 2010 Hycroft Groundwater Study Summary and Preliminary Data Review – Static Water Levels & Hydrologic Setting.

_____. 2011b. Hycroft Mine Final – Phase I Waste Rock Characterization Report. Winnemucca, Nevada. May 2011.

Stringham, Carrie. 2011. Personal communication (e­mail). Human Resource Manager, HRDI. September 22, 2011.

United States Census Bureau (U.S. Census Bureau). 2000. Total Population; Census 2000 Summary File 1 100 Percent Data; Census Tract 35.01, Washoe County, Nevada. http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_ 00_SF1_P001&prodType=table. Accessed August 3, 2011.

_____. 2009a. 2009 County Business Patterns. http://censtats.census.gov/cgi­ bin/cbpnaic/cbpsect.pl. Accessed August 16, 2011.

_____. 2009b. OnTheMap: Work Area Profile Analysis. http://lehdmap.did.census.gov/. Accessed August 16, 2011.

_____. 2010a. Age Groups and Sex: 2010; 2010 Census Summary File 1; Census Tract 35.01, Washoe County, Nevada. http://factfinder2.census. gov/faces/tableservices/jsf/pages/ productview.xhtml?pid=DEC_10_SF1_QTP1&prodType=table. Accessed August 3, 2011.

_____. 2010b. Profile of General Population and Housing Characteristics; 2010 Demographic Profile Data: Humboldt County, Nevada. http://factfinder2. census.gov/faces/ tableservices/jsf/pages/productview.xhtml?pid=DEC_10_DP_DPDP1&prodType=table. Accessed August 3, 2011.

_____. 2010c. Profile of General Population and Housing Characteristics; 2010 Demographic Profile Data: Pershing County, Nevada. http://factfinder2.census.gov/faces/ tableservices/jsf/pages/productview.xhtml?pid=DEC_10_DP_DPDP1&prodType=table. Accessed August 3, 2011.

_____. 2010d. Profile of General Population and Housing Characteristics; 2010 Demographic Profile Data: State of Nevada. http://factfinder2.census.gov/faces/tableservices/jsf/ pages/productview.xhtml?pid=DEC_10_DP_DPDP1&prodType=table. Accessed August 3, 2011.

_____. 2010e. Profile of General Population and Housing Characteristics; 2010 Demographic Profile Data: Winnemucca city, Nevada. http://factfinder2.census.gov/ faces/tableservices/jsf/pages/productview.xhtml?src=bkmk. Accessed October 3, 2011.

9­12 2489U.HycroftEIS.FEIS.FINAL.docx

CHAPTER 9 REFERENCES

_____. 2010f. Race and Hispanic or Latino Origin: 2010; 2010 Census Summary File 1; Census Tract 35.01, Washoe County, Nevada. http://factfinder2.census.gov/faces/ tableservices/jsf/pages/productview.xhtml?pid=DEC_10_SF1_QTP3&prodType=table. Accessed August 3, 2011.

_____. 2011a. State & County Quick Facts: Humboldt County, Nevada. http://quickfacts.census.gov/qfd/states/32/32013.html. Accessed August 16, 2011.

_____. 2011b. State & County Quick Facts: Pershing County, Nevada. http://quickfacts. census.gov/qfd/states/32/32027.html. Accessed August 16, 2011.

United States Department of Agriculture, Forest Service (USDA­FS). 2003. Regional Pollution Potential in the Northwestern United States. October 2003

United States Department of Commerce, Bureau of Economic Analysis (USDC ­ BEA). 2011a. Bearfacts: Humboldt, Nevada. http://www.bea.gov/regional/bearfacts/action.cfm?fips=32013& areatype=32013. Accessed August 18, 2011.

_____. 2011b. Bearfacts: Nevada. http://www.bea.gov/regional/bearfacts/action.cfm. Accessed August 18, 2011.

_____. 2011c. Bearfacts: Pershing, Nevada. http://www.bea.gov/regional/bearfacts/action.cfm. Accessed August 18, 2011.

Ulmschneider, H. 2004. Surveying for pygmy rabbits (Brachylagus idahoensis). BLM Technical Report, 4th Draft, June 3, 2004.

United States Fish and Wildlife Service (USFWS). 2010. The Interim Golden Eagle Technical Guidance: Inventory and Monitoring Protocols; and Other Recommendations in Support of Golden Eagle Management and Permit Issuance. Available online at: http://steinadlerschutz.lbv.de/fileadmin/www.steinadlerschutz.de/terimGoldenEagleTechnic alGuidanceProtocols25March2010_1_.pdf.

Valentine, David. 2002. “Ask Not for Whom the Toll Bills,” In­Situ: Newsletter of the Nevada Archaeological Association, Winter 2002.

Washoe County. 2011. Citizen Involvement: Boards & Commissions. http://www.co.washoe.nv.us/ citizens/boards.html. Accessed August 22, 2011.

Washoe County Department of Community Development (WCDCD). 2010. Master Plan Public Services and Facilities Element. Reno, Nevada.

Washoe County Health District (WCHD). 2011. Solid Waste Management Plan and Plan Element of the Regional Plan for Washoe County. Reno, Nevada.

Washoe County Library System (WCLS). 2011. Gerlach Community Library. http://www.washoecounty.us/library/gerlach.html. Accessed August 15, 2011.

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Washoe County School District (WCSD). 2011. Washoe County School District Website, School Directory. http://www.washoe.k12.nv.us/directory/search/schools/G. Accessed September 27, 2011.

Washoe County Sheriff’s Office (WCSO). 2011. Washoe County Sheriff’s Office website. http://www.washoesheriff.com/index.html. Accessed August 12, 2011.

Wesner, Karen. 2011. Personal communication (e­mail). Pershing County Board of Commissioners Administrative Assistant. September 22, 2011.

West, D. Stephen. 2011. Personal Communication (e­mail). City Manager/Engineer for City of Winnemucca. September 15, 2011.

Willden, R. 1964. Geology and Mineral Deposits of Humboldt County, Nevada. Nevada Bureau of Mines and Geology. Bulletin 59.

Wilson, S.E. 2011. Technical Report – Allied Nevada Gold Corp. Hycroft Mine, Winnemucca, Nevada. 175 p.

Woods, W. 2011. Personal Communication (E­mail). Warren Woods, Hycroft Mine Vice­ President and General Manager. December 14, 2011.

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10 GLOSSARY

Acoustical Terminology

AMBIENT NOISE LEVEL: The composite of noise from all sources near and far. In this context, the ambient noise level constitutes the normal or existing level of environmental noise at a given location.

CNEL: Community Noise Equivalent Level. The average equivalent sound level during a 24­hour day, obtained after addition of approximately five decibels to sound levels in the evening from 7:00 p.m. to 10:00 p.m. and ten decibels to sound levels in the night before 7:00 a.m. and after 10:00 p.m.

DECIBEL, dB: A unit for describing the amplitude of sound, equal to 20 times the logarithm to the base 10 of the ratio of the pressure of the sound measured to the reference pressure, which is 20 micropascals (20 micronewtons per square meter).

dBA Not all sound pressures are equally loud. This is because the human ear does not respond equally to all frequencies: we are much more sensitive to sounds in the frequency range about 1 kHz to 4 kHz (1000 to 4000 vibrations per second) than to very low or high frequency sounds. For this reason, sound meters are usually fitted with a filter whose response to frequency is a bit like that of the human ear. (More about these filters below.) If the "A weighting filter" is used, the sound pressure level is given in units of dB(A) or dBA. Sound pressure level on the dBA scale is easy to measure and is therefore widely used. It is still different from loudness, however, because the filter does not respond in quite the same way as the ear. To determine the loudness of a sound, one needs to consult some curves representing the frequency response of the human ear, given below.

DNL/Ldn: Day/Night Average Sound Level. The average equivalent sound level during a 24­hour day, obtained after addition of ten decibels to sound levels in the night after 10:00 p.m. and before 7:00 a.m.

Leq: Equivalent Sound Level. The sound level containing the same total energy as a time varying signal over a given sample period. Leq is typically computed over 1, 8 and 24­hour sample periods. NOTE: The CNEL and DNL represent daily levels of noise exposure averaged on an annual basis, while Leq represents the average noise exposure for a shorter time period, typically one hour.

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Lmax: � The maximum noise level recorded during a noise event.

Ln: � The sound level exceeded "n" percent of the time during a sample interval (L90, L50, L10, etc.). For example, L10 equals the level exceeded 10 percent of the time.

Air Resources Terminology

ATTAINMENT AREA: � An air basin or portion of an air basin that has attained compliance with the adopted NAAQS for one or more than one criteria pollutants

NON­ATTAINMENT AREA: � An air basin or portion of an air basin that has not attained compliance with the adopted NAAQS for one or more than one criteria pollutants

CRITERIA POLLUTANTS: � Six common air pollutants namely particulate matter, ground level ozone, carbon monoxide, sulfur oxides, nitrogen oxides, and lead that are found all over the United States. These pollutants are regulated by the EPA by setting ambient standards to satisfy the human health­based and/or environmentally based criteria (scientific based guidelines) specified in the Clean Air Act

MIXING HEIGHTS: � The depth of atmospheric mixed layer is known as the mixing height. It results from convective air motions, typically seen towards the middle of the day when the air at the surface is warmed and rises.

CO2(e) � Is the carbon dioxide equivalent, which is a metric measure used to compare the emissions from various greenhouse gases based upon their global warming potential (GWP). The carbon dioxide equivalent for a gas is derived by multiplying the tons of the gas by the associated GWP. CO2(e) is expressed in metric tons.

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11 ALPHABETICALLY ORDERED INDEX access, 1­1, 2­3, 2­19, 2­21, 2­22, 2­26, 2­28, 2­31, 2­53, 2­54, 2­55, 2­59, 2­64, 2­67, 2­83, 3­ 12, 3­16, 3­17, 3­18, 3­28, 3­38, 3­41, 3­47, 3­76, 3­91, 3­109, 3­110, 3­112, 3­115, 3­134, 3­ 180, 3­183, 3­184, 3­186, 3­187, 3­188, 3­189, 3­194, 3­199, 3­218, 3­224, 3­226, 3­228, 4­2, 4­7, 4­8, 4­28, 4­31, 4­35, 5­7, 7­1 access roads, 2­3, 2­54, 3­28, 3­91, 3­194, 3­224, 3­226, 4­31, 4­35 air quality, 2­28, 2­31, 2­58, 2­61, 2­63, 2­66, 3­6, 3­7, 3­10, 3­11, 3­12, 3­15, 3­16, 3­17, 3­18, 3­23, 3­24, 3­25, 3­26, 3­40, 3­41, 3­143, 3­228, 4­2, 4­22, 4­23, 4­24, 4­36, 5­3, 5­5, 5­6 alternatives, 2, 1­8, 2­1, 2­55, 2­56, 2­57, 2­58, 3­1, 3­2, 3­3, 3­4, 3­5, 3­6, 3­28, 3­34, 3­40, 3­ 47, 3­51, 3­76, 3­150, 3­200, 3­205, 4­1, 4­2, 4­33, 7­1 aquifer, 1­17, 2­21, 3­1, 3­57, 3­61, 3­67, 3­229 AUM, xiii authorized disturbance, 1­11, 2­2 bats, 2­80, 2­80, 3­166, 3­167, 3­173, 3­178, 4­30, 5­1 Black Rock Desert, 2­27, 3­1, 3­32, 3­33, 3­34, 3­54, 3­55, 3­59, 3­60, 3­61, 3­72, 3­78, 3­81, 3­ 85, 3­199, 3­200, 4­2, 4­7, 4­8, 4­16, 4­21, 4­23, 4­28, 9­10 CESAs, 4­1, 4­2, 4­8, 4­11, 4­16, 4­17, 4­18, 4­19, 4­20, 4­21, 4­22, 4­30, 4­31 climate change, 3­9, 3­10, 3­25, 3­190, 3­193 cultural resources, 2­29, 2­64, 2­64, 2­66, 3­27, 3­28, 3­34, 3­35, 3­38, 3­40, 3­41, 3­205, 3­228, 4­2, 4­8, 4­24, 4­25, 5­2, 5­3, 7­1 cumulative impacts, 3, 1­2, 1­10, 3­35, 4­1, 4­2, 4­8, 4­22, 4­24, 4­26, 4­28, 4­33, 4­34, 4­36, 4­ 37 dark skies, 2­58, 3­40, 3­199, 3­205, 4­37 employment, 1, 1­18, 2­1, 2­25, 2­58, 2­74, 2­75, 3­115, 3­116, 3­118, 3­122, 3­123, 3­125, 3­ 137, 3­140, 3­141, 3­143, 3­144, 3­145, 4­28, 9­2 energy resources, 2­72, 3­77, 3­86, 3­87, 3­88 ESA, xiv, 3­159, 3­160, 4­8 ET, xiv, 2­50, 2­52, 3­60 exploration, 1, 1­8, 1­10, 1­11, 2­1, 2­2, 2­27, 2­28, 2­55, 2­56, 2­59, 2­77, 2­78, 2­79, 2­84, 3­ 28, 3­35, 3­44, 3­45, 3­57, 3­85, 3­86, 3­109, 3­115, 3­117, 3­156, 3­175, 3­176, 3­177, 3­178, 3­193, 3­194, 3­195, 3­196, 3­197, 3­223, 3­225, 3­227, 4­1, 4­11, 4­19, 4­20, 4­21, 4­23, 4­ 24, 4­25, 4­26, 4­27, 4­28, 4­29, 4­30, 4­31, 4­32, 4­33, 4­34, 4­35, 4­36 FLPMA, xiv, 1­1, 1­8, 3­46, 3­76, 3­116, 3­189, 3­198, 3­220 fugitive emissions, 2, 1­10 geochemistry, 2­9, 6­1 geology and minerals, 2­71, 3­87, 3­88 geothermal, 2­22, 2­27, 2­54, 2­72, 3­82, 3­84, 3­85, 3­86, 3­87, 3­88, 3­180, 4­1, 4­11, 4­20, 4­ 21, 4­26, 4­28, 4­31 GHGs, 2, 3­9, 3­10, 3­24, 3­25 global warming, 3­24, 10­2 golden eagle, 3, 2­78, 2­79, 2­82, 3­43, 3­159, 3­160, 3­162, 3­165, 3­167, 3­171, 3­176, 3­178, 3­229, 4­7, 4­30, 5­1 greater sage­grouse, 2­77, 3­43, 3­160, 3­161, 3­162, 3­168, 3­175, 3­222, 4­7, 4­30 ground water, 1­17, 2­21, 2­31, 2­55, 2­56, 2­70, 3­1, 3­25, 3­51, 3­52, 3­53, 3­57, 3­59, 3­60, 3­ 61, 3­67, 3­68, 3­72, 3­73, 3­74, 3­75, 3­76, 4­33, 4­38, 5­5 growth media, 2, 1­17, 1­22, 2­2, 2­8, 2­10, 2­19, 2­20, 2­21, 2­28, 2­30, 2­31, 2­32, 2­41, 2­42, 2­49, 2­50, 2­51, 2­52, 2­53, 2­54, 2­56, 2­57, 2­76, 2­77, 3­150, 3­155, 3­156, 3­157, 3­158, 3­194, 3­195, 3­197, 4­29, 4­31, 5­5 haul and access roads, 1­19

11­1 2489U.HycroftEIS.FEIS.FINAL.docx HYCROFT RESOURCES AND DEVELOPMENT INC. HYCROFT MINE EXPANSION PROJECT ­ FINAL ENVIRONMENTAL IMPACT STATEMENT ­ hazardous materials, 2­26, 2­83, 3­49, 3­50, 3­51, 3­52, 3­53, 3­54, 3­180, 3­183, 3­184, 3­185, 3­186, 3­187, 3­188, 4­8, 4­21, 4­31 heap leach facilities, 1, 1­7, 2­1, 2­10, 2­17, 2­18, 2­19, 2­20, 2­21, 2­31, 2­33, 2­49, 2­50, 2­51, 2­56, 2­71, 3­61, 3­62, 3­67, 3­73, 3­86, 3­87, 3­229, 5­5 historic trails, 3­39, 4­26 housing, 2­75, 3­91, 3­101, 3­103, 3­124, 3­125, 3­126, 3­131, 3­132, 3­140, 3­142, 3­144, 9­7 HRDI, xv, 1, 2, 1­1, 1­7, 1­11, 1­15, 1­16, 1­17, 1­19, 1­20, 1­21, 2­1, 2­3, 2­7, 2­8, 2­9, 2­18, 2­ 19, 2­20, 2­21, 2­22, 2­25, 2­26, 2­27, 2­28, 2­29, 2­30, 2­31, 2­32, 2­33, 2­41, 2­50, 2­53, 2­ 54, 2­55, 2­56, 2­59, 2­64, 2­65, 2­66, 2­73, 2­82, 2­85, 3­2, 3­3, 3­11, 3­24, 3­25, 3­27, 3­38, 3­39, 3­49, 3­53, 3­54, 3­61, 3­68, 3­72, 3­74, 3­75, 3­82, 3­84, 3­86, 3­106, 3­109, 3­110, 3­ 112, 3­115, 3­124, 3­141, 3­143, 3­156, 3­158, 3­165, 3­174, 3­180, 3­183, 3­184, 3­185, 3­ 186, 3­187, 3­196, 3­219, 3­224, 4­26, 4­35, 5­1, 5­2, 5­3, 5­4, 5­5, 5­6, 5­7, 9­3, 9­7, 9­12 KOP, xv, 3­40, 3­199, 3­205, 3­206, 3­207, 3­209, 3­211, 3­212, 3­213, 3­215, 3­217, 3­218, 3­ 219, 3­220 land development, 4­11, 4­28, 4­31 livestock grazing, 2­33, 3­4, 3­5, 3­109, 3­195, 4­16, 4­18, 4­27, 4­29, 4­30, 4­31, 4­32, 4­34, 4­ 35 MBTA, xv, 2­30, 2­67, 2­78, 2­79, 3­41, 3­44, 3­45, 3­162, 3­168, 3­171, 3­172, 3­175, 3­176, 4­27, 5­4 mercury, 2, 1­10, 1­16, 1­17, 2­10, 2­63, 3­6, 3­23, 3­24, 3­25, 3­26, 3­41, 3­51, 3­53, 3­62, 4­ 19, 4­23 migratory birds, 3­42, 3­44, 3­45, 3­171, 3­172, 3­222, 4­2, 4­26, 4­27, 4­36, 4­38 mineral resources, 2, 1­10, 2­72, 3­76, 3­86, 3­87, 3­88, 3­229, 4­26, 4­36 mining operations, 1­1, 2­9, 2­66, 3­5, 3­40, 3­59, 3­97, 3­109, 3­111, 3­175, 3­193, 3­199, 3­ 228, 4­1, 4­19, 4­21, 4­23, 4­24, 4­26, 4­28, 4­38, 5­7 monitoring, i, xvii, 1­2, 1­7, 1­20, 1­22, 2­9, 2­33, 2­54, 2­55, 2­64, 2­65, 2­66, 2­84, 3­2, 3­3, 3­ 6, 3­7, 3­8, 3­9, 3­12, 3­15, 3­38, 3­39, 3­40, 3­61, 3­62, 3­68, 3­98, 3­144, 3­174, 3­195, 4­ 25, 4­34, 5­1, 5­2, 5­7, 9­10 NAGPRA, xvi, 3­27, 3­46 Native American consultation, 3­28 NCA, xvi, 3, 1­10, 2­54, 2­82, 3­1, 3­33, 3­91, 3­112, 3­115, 3­126, 3­174, 3­199, 3­206, 4­2, 4­ 7, 4­21, 5­1 NEPA, xvi, 2, 3, 1­1, 2­27, 2­57, 2­60, 3­9, 3­11, 3­12, 3­16, 3­17, 3­18, 3­46, 3­54, 3­116, 3­ 198, 4­1, 4­25, 6­1, 9­2 NHPA, xvi, 3­27, 3­28, 3­46, 3­47, 4­24, 4­25 No Action Alternative, i, 1, 2, 3, 2­56, 2­57, 2­60, 2­61, 2­63, 2­66, 2­67, 2­68, 2­69, 2­70, 2­71, 2­72, 2­73, 2­74, 2­75, 2­76, 2­77, 2­78, 2­79, 2­80, 2­82, 2­83, 2­84, 2­85, 2­86, 2­85, 2­86, 2­87, 3­24, 3­25, 3­26, 3­27, 3­41, 3­45, 3­48, 3­53, 3­54, 3­75, 3­76, 3­86, 3­87, 3­88, 3­104, 3­105, 3­109, 3­110, 3­112, 3­115, 3­141, 3­144, 3­145, 3­158, 3­168, 3­175, 3­176, 3­177, 3­ 178, 3­183, 3­186, 3­187, 3­188, 3­196, 3­197, 3­205, 3­206, 3­207, 3­211, 3­212, 3­213, 3­ 215, 3­218, 3­219, 3­220, 3­225, 3­226, 3­227, 4­22, 4­35, 4­36, 4­37, 4­38, 5­7 noise levels, xv, 3­40, 3­88, 3­89, 3­90, 3­91, 3­92, 3­96, 3­97, 3­98, 3­99, 3­100, 3­101, 3­102, 3­103, 3­104 noxious weeds, 2­31, 2­33, 3­2, 3­3, 3­155, 4­31, 4­32, 5­5, 5­7

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CHAPTER 11 ALPHABETICALLY ORDERED INDEX

open pit, 1, 1­7, 1­11, 1­15, 1­19, 1­21, 1­22, 2­1, 2­3, 2­4, 2­7, 2­8, 2­31, 2­41, 2­54, 2­56, 2­58, 2­59, 2­67, 2­68, 2­70, 2­73, 2­74, 2­77, 2­82, 2­85, 2­87, 3­41, 3­42, 3­43, 3­44, 3­45, 3­51, 3­53, 3­57, 3­73, 3­74, 3­76, 3­77, 3­86, 3­87, 3­91, 3­92, 3­98, 3­104, 3­105, 3­110, 3­115, 3­ 116, 3­155, 3­156, 3­157, 3­158, 3­171, 3­174, 3­176, 3­178, 3­194, 3­196, 3­197, 3­200, 3­ 212, 3­218, 3­224, 3­225, 3­226, 3­227, 3­228, 3­229, 4­19, 4­26, 4­31, 5­5 open pit mining methods, 2­3, 3­87 ore stockpile, 2­31, 4­23, 5­5, 5­6 past and present actions, 4­8, 4­26, 4­27, 4­28, 4­29, 4­30, 4­31, 4­32, 4­33, 4­34, 4­35, 4­36, 4­ 37, 4­38 Proposed Action, i, 1, 2, 3, 1­1, 1­2, 1­7, 1­8, 1­9, 1­10, 2­1, 2­21, 2­25, 2­26, 2­28, 2­30, 2­31, 2­55, 2­56, 2­57, 2­58, 2­59, 2­60, 2­61, 2­63, 2­66, 2­67, 2­68, 2­69, 2­70, 2­71, 2­72, 2­73, 2­74, 2­74, 2­75, 2­76, 2­77, 2­78, 2­79, 2­80, 2­82, 2­83, 2­84, 2­85, 2­86, 2­87, 3­1, 3­2, 3­3, 3­4, 3­5, 3­6, 3­10, 3­16, 3­17, 3­18, 3­23, 3­24, 3­25, 3­26, 3­34, 3­35, 3­38, 3­39, 3­40, 3­44, 3­45, 3­47, 3­48, 3­51, 3­52, 3­53, 3­54, 3­73, 3­74, 3­75, 3­76, 3­86, 3­87, 3­103, 3­104, 3­ 109, 3­110, 3­112, 3­115, 3­116, 3­141, 3­142, 3­143, 3­144, 3­145, 3­150, 3­155, 3­156, 3­ 157, 3­158, 3­168, 3­171, 3­172, 3­173, 3­174, 3­175, 3­177, 3­183, 3­184, 3­185, 3­186, 3­ 188, 3­193, 3­194, 3­195, 3­197, 3­200, 3­205, 3­209, 3­211, 3­212, 3­215, 3­217, 3­218, 3­ 219, 3­220, 3­223, 3­224, 3­225, 3­227, 3­228, 3­229, 4­1, 4­2, 4­8, 4­17, 4­20, 4­22, 4­24, 4­ 26, 4­27, 4­28, 4­29, 4­30, 4­31, 4­32, 4­33, 4­34, 4­35, 4­36, 4­37, 5­1, 5­3, 5­4 public safety, 3, 1­10, 2­22, 2­26, 2­41, 2­83, 3­51, 3­137, 3­155, 3­179, 3­180, 3­183, 3­184, 3­ 186, 3­187, 3­188, 4­2, 4­7, 4­31 reclamation, 1­2, 1­7, 1­15, 1­21, 1­22, 2­8, 2­21, 2­27, 2­30, 2­31, 2­33, 2­42, 2­51, 2­52, 2­53, 2­54, 2­55, 2­56, 2­67, 2­76, 2­78, 2­80, 2­84, 2­86, 3­44, 3­45, 3­72, 3­76, 3­85, 3­109, 3­ 115, 3­146, 3­150, 3­155, 3­156, 3­157, 3­158, 3­168, 3­171, 3­172, 3­173, 3­175, 3­176, 3­ 177, 3­178, 3­184, 3­187, 3­193, 3­194, 3­195, 3­196, 3­197, 3­211, 3­212, 3­218, 3­219, 3­ 220, 3­223, 3­224, 3­225, 3­226, 3­227, 3­228, 3­229, 4­8, 4­26, 4­27, 4­29, 4­30, 4­31, 4­32, 4­33, 4­34, 4­35, 4­38, 5­5, 5­7 recreation, 2­33, 2­73, 2­74, 3­1, 3­105, 3­109, 3­110, 3­112, 3­115, 3­116, 3­126, 3­137, 3­138, 3­143, 3­184, 3­187, 3­200, 3­228, 4­1, 4­2, 4­8, 4­11, 4­21, 4­23, 4­24, 4­25, 4­26, 4­27, 4­ 28, 4­29, 4­30, 4­31, 4­32, 4­33, 4­34, 4­35, 4­36, 9­2 revegetation, 1­22, 2­19, 2­32, 2­33, 2­49, 2­50, 2­51, 2­53, 2­54, 2­57, 2­76, 2­84, 3­155, 3­156, 3­157, 3­158, 3­171, 3­176, 3­193, 3­195, 3­211, 3­212, 3­219, 3­220, 3­224, 3­226, 3­229, 4­ 29, 4­32, 4­33, 4­35, 4­36, 4­37, 4­38, 5­7 ROWs, 1, 1­21, 2­1, 2­22, 2­73, 3­105, 3­106, 3­109, 3­110, 3­228, 4­18, 4­23, 4­25, 4­27, 4­29, 4­30, 4­32, 4­33, 4­34, 4­35 social and economic values, 3­116, 3­117, 3­129, 4­8, 4­28 soils, xvii, 1­18, 1­22, 2­50, 2­53, 2­59, 2­76, 2­82, 3­52, 3­145, 3­146, 3­150, 3­155, 3­156, 3­ 157, 3­158, 3­161, 3­166, 3­167, 3­174, 3­189, 3­224, 3­226, 4­2, 4­8, 4­29, 4­30, 4­32, 4­34, 4­35, 4­37 surface water, 2­53, 2­56, 2­69, 2­71, 3­51, 3­52, 3­53, 3­59, 3­60, 3­61, 3­62, 3­67, 3­72, 3­73, 3­74, 3­75, 3­76, 4­33, 4­34, 4­38 transportation, 2­25, 2­29, 2­56, 2­66, 2­83, 3­17, 3­18, 3­32, 3­36, 3­40, 3­50, 3­51, 3­53, 3­88, 3­89, 3­90, 3­91, 3­117, 3­143, 3­179, 3­180, 3­183, 3­185, 3­186, 3­187, 3­188, 4­2, 4­7, 4­8, 4­24, 4­31, 4­37, 5­4, 5­6 vegetation, 1­22, 2­8, 2­19, 2­20, 2­28, 2­33, 2­42, 2­49, 2­50, 2­51, 2­53, 2­54, 2­59, 2­67, 2­76, 2­77, 2­79, 2­82, 2­84, 2­85, 2­86, 2­87, 3­17, 3­42, 3­44, 3­45, 3­52, 3­60, 3­146, 3­156, 3­ 158, 3­161, 3­165, 3­166, 3­167, 3­168, 3­171, 3­172, 3­173, 3­174, 3­175, 3­176, 3­177, 3­ 178, 3­189, 3­190, 3­193, 3­194, 3­195, 3­196, 3­197, 3­200, 3­205, 3­211, 3­212, 3­219, 3­

11­3 2489U.HycroftEIS.FEIS.FINAL.docx HYCROFT RESOURCES AND DEVELOPMENT INC. HYCROFT MINE EXPANSION PROJECT ­ FINAL ENVIRONMENTAL IMPACT STATEMENT ­ visual resources, 2­58, 2­59, 3­199, 3­200, 3­218, 3­219, 3­220, 3­229, 4­2, 4­7, 4­8, 4­33, 4­37 water quality, 2­53, 2­55, 3­51, 3­53, 3­60, 3­67, 3­68, 3­72, 3­73, 3­74, 3­156, 3­224, 3­226, 4­ 2, 4­33, 4­34, 4­38 water resources, 2­7, 2­57, 3­72, 4­33, 4­34 water supply, 3­156 wilderness, 3, 1­10, 3­91 wildlife, 2­19, 2­28, 2­31, 2­32, 2­33, 2­59, 2­82, 2­86, 2­87, 3­42, 3­45, 3­159, 3­160, 3­167, 3­ 174, 3­186, 3­188, 3­193, 3­195, 3­197, 3­220, 3­221, 3­222, 3­223, 3­224, 3­225, 3­226, 3­ 227, 3­229, 4­2, 4­7, 4­8, 4­18, 4­29, 4­30, 4­31, 4­32, 4­34, 4­35, 4­38, 5­5, 5­7 work force, 2­67, 2­75, 3­40, 3­144 WRFs, 1, 1­15, 1­19, 1­21, 2­1, 2­4, 2­8, 2­9, 2­20, 2­21, 2­22, 2­31, 2­33, 2­41, 2­42, 2­49, 2­ 56, 2­57, 2­70, 2­71, 3­17, 3­59, 3­73, 3­74, 3­86, 3­87, 3­92, 3­98, 3­155, 3­156, 3­211, 3­ 219, 3­220, 3­229, 5­5

11­4 2489U.HycroftEIS.FEIS.FINAL.docx