Galiuro Exploration Drilling Plan of Operations Environmental Assessment

United States Department of Agriculture

Forest Service Coronado National Forests Safford Ranger District December 2017

For More Information Contact:

Richard Goshen 300 W. Congress St Tucson, AZ 85701 (520) 388-8341

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident. Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA’s TARGET Center at (202) 720- 2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English. To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632- 9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: [email protected]. USDA is an equal opportunity provider, employer and lender. Environmental Assessment

Preface Acronyms and Abbreviations AAC Arizona Administrative Code ABA Acid Base Accounting ACHP Advisory Council of Historic Preservation ADEQ Arizona Department of Environmental Quality ADWR Arizona Department of Water Resources AGFD Arizona Game & Fish Department AMA Active Management Area amsl Above Mean Sea Level APE Area of Potential Effects APP Aquafer Protection Permit ARD Acid Rock Drainage ARS Arizona Revised Statutes ASM Arizona State Museum ASOS Automatic Surface Observation System ASTM American Society for Testing & Materials AWQS Aquifer Water Quality Standard AZHGIS Arizona Heritage Geographic Information System AZPDES Arizona Pollutant Discharge Elimination System BAE Biological Assessment & Evaluation BCC Birds of Conservation Concern BGEPA Bald & Golden Eagle Protection Act BLM Bureau of Land Management BMP Best Management Practices CAA Clean Air Act CEQ Council of Environmental Quality CFR Code of Federal Regulations CGP Construction General Permit CNF Coronado National Forest CO Carbon Monoxide CWA Clean Water Act DF Design Feature DMGP De Minimis General Permit E. coli Escherichia coli EA Environmental Assessment EIS Environmental Impact Statement EMA Ecology Management Area EPA Environmental Protection Agency ESA Endangered Species Act FEMA Federal Emergency Management Agency FONSI Finding of No Significant Impact FP Forest Plan

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FSH Forest Service Handbook FSM Forest Service Manual GIS Geographic Information Systems GLO General Land Office GMU Game Management Unit gpm Gallons per minute GPS Global Positioning System GTES General Terrestrial Ecosystem Survey HDMS Heritage Data Management System HP Horsepower HUC Hydrologic Unit Code IDT Interdisciplinary Team IMPROVE Interagency Monitoring of Protected Visual Environments IPaC Information for Planning & Construction IRA Inventoried Roadless Area KEC Kennecott Exploration Company LRMP Land Resource Management Plan LZ Landing Zone MA Management Area MBTA Migratory Bird Treaty Act MIS Management Indicator Species MM Mitigation Measure MSL Mean Sea Level NEPA National Environmental Policy Act NFS National Forest System NHD National Hydrography Dataset NHPA National Historic Preservation Act NOAA National Oceanic and Atmosphere Administration NOx Nitrogen Oxide NPDES National Pollutant Discharge Elimination System NRHP National Register of Historic Places O&M Operations & Management PA Project Area PAC Protected Activity Center PM Particulate Matter PoO Plan of Operations PPEPM Proponent Proposed Environmental Protection Measure ppm Part per Million PRISM Parameter-elevation Regression on Independent Slopes Model RASES Riparian Area Survey and Evaluation System RMap USFS Region 3 GIS Riparian Map RP Reduced Pressure RecP Reclamation Plan SGCN Species of Greatest Conservation Need SHPO State Historic Preservation Office ii Environmental Assessment

SIO Scenic Integrity Objective SMS Scenery Management System SO2 Sulfur Dioxide SPLP Synthetic Precipitation Leach Procedures SRP Spill Response Plan SWPPP Storm Water Pollution Prevention Plan SWQS Surface Water Quality Standard TCLP Toxicity Characteristic Leach Procedures TEUI Terrestrial Ecological Unit Inventory ULSD Ultra-Low Sulfur Diesel USC University of Southern California USDA United States Department of Agriculture USFS United States Forest Service USFWS United States Fish and Wildlife Service USGS United States Geological Survey UV Ultra-violet VOC Volatile Organic Compounds VQO Visual Quality Objectives VRMS Visual Resource Management System WRCC Western Region Climate Center

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Contents

Preface Acronyms and Abbreviations ...... i

1 Introduction ...... 1 1.1 Location of the Proposed Project Area ...... 1 1.2 Forest Land and Resource Management Plan Direction ...... 2 1.2.1 Forest Service Mining Regulations ...... 2 1.2.2 Forest Service Mineral Policy ...... 2 1.2.3 Forest Plan Consistency ...... 2 1.3 Need for the Proposal ...... 3 1.4 Scope of the Federal Action ...... 3 1.4.1 Decision Framework ...... 3 1.5 Public Involvement ...... 4 1.6 Issues ...... 4

2 Proposed Action and Alternatives ...... 6 2.1 No Action Alternative ...... 6 2.2 Proposed Action ...... 6 2.2.1 Access ...... 6 2.2.2 Drilling and Related Activities ...... 12 2.2.3 Equipment ...... 20 2.2.4 Proponent Proposed Environmental Protection Measures ...... 20 2.3 Alternatives Considered but Eliminated ...... 23 2.4 CNF Proposed Mitigation Measures ...... 23 2.5 Comparison of Alternatives ...... 28

3 Environmental Impacts of the Proposed Action and No Action Alternative ...... 31 3.1 Cumulative Effects ...... 32 3.2 Air Quality...... 33 3.2.1 Regulatory Framework...... 33 3.2.2 Existing Conditions ...... 34 3.2.3 Environmental Consequences ...... 38 3.3 Cultural Resources ...... 40 3.3.1 Regulatory Framework...... 40 3.3.2 Existing Conditions ...... 41 3.3.3 Environmental Consequences ...... 41 3.4 Biological Resources ...... 42 3.4.1 Regulatory Framework...... 42 3.4.2 Existing Conditions ...... 43 3.4.3 Environmental Consequences ...... 46 3.5 Scenic Values ...... 70 3.5.1 Regulatory Framework...... 70 3.5.2 Existing Conditions ...... 71

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3.5.3 Environmental Consequences ...... 72 3.6 Water Quality ...... 73 3.6.1 Regulatory Framework ...... 73 3.6.2 Existing Conditions...... 75 3.6.3 Environmental Consequences ...... 77 3.7 Soils ...... 81 3.7.1 Regulatory Framework ...... 81 3.7.2 Existing Conditions...... 82 3.7.3 Environmental Consequences ...... 83 3.8 Recreation ...... 85 3.8.1 Regulatory Framework ...... 85 3.8.2 Existing Conditions...... 86 3.8.3 Environmental Consequences ...... 87 3.9 Rangeland and Noxious Weeds ...... 88 3.9.1 Regulatory Framework ...... 88 3.9.2 Existing Conditions...... 89 3.9.3 Environmental Consequences ...... 89 3.10 Fire Management ...... 91 3.10.1 Regulatory Framework ...... 91 3.10.2 Existing Conditions ...... 92 3.10.3 Environmental Consequences ...... 93

4 Consultation and Coordination ...... 94 4.1 List of Preparers ...... 94 4.1.1 Present Forest Service Interdisciplinary Team Members ...... 94 4.1.2 Past Forest Service Interdisciplinary Team Members...... 94 4.2 Federal and State Agencies: ...... 94 4.2.1 Federal: ...... 94 4.2.2 State: ...... 94 4.3 Tribes: ...... 94

5 References ...... 96

Appendix A Draft EA Comments/Responces ...... 104

List of Tables

Table 1. Township, Range, and (1/4) Section Locations for all Galiuro Project Disturbances ...... 1 Table 2. Unpatented Claims with Serial Numbers and Acreage of Disturbance ...... 12 Table 3. Drill Site Types of Powered Equipment ...... 20 Table 4. Comparison of Alternatives ...... 28 Table 5. Projects included in Cumulative Effects Analysis ...... 33 Table 6. USFWS Listed Species for Graham County, Arizona ...... 51 Table 7. Coronado National Forest Management Indicator Species and Occurrence in the Project Area ..59 Table 8. 1981-2010 Monthly Climate Summary, Location: Latitude: 32.7296 Longitude: -110.4437 Elev: 4629ft (Source: Western Regional Climate Center and Parameter elevation Regressions on Independent Slopes Model (PRISM), accessed 8/11/16) ...... 75

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Table 9. Proposed drills sites located in each watershed ...... 76 Table 10. Streams, USGS Reaches, Flow Regime and State Designated Uses ...... 76 Table 11. Commenters and Oranizations They Represent, Letter Numbers, and Starting Page ...... 105 Table 12. Reseponses to Public Comments Submitted During the Draft EA Comment Period: October XX, 2017 through October XX, 2017 ...... 106

List of Figures

Figure 2-1. Access Map to Galiuro Project (T8S, R18E, Sec. 24; T8S, 19E, Sec. 8 & 17-19; Pinal and Graham Counties, AZ) (provided by KEC) ...... 8 Figure 2-2. Galiuro Exploration Drilling Project Proposed Helicopter Flight Path (created by USFS) .... 10 Figure 2-3. Galiuro Project Area Land Ownership with Existing Roads and Proposed Drill Sites (provided by KEC) ...... 14 Figure 2-4. Potential Landing Zones in the Galiuro Project Area (provided by KEC) ...... 16 Figure 2-5. Generic Drill Site Layout (50'x50') (Sizes/Locations May Vary) (Provided by KEC) ...... 18 Figure 3-1. Annual Average Wind Rose Plot for Safford Municipal Airport ...... 35 Figure 3-2. Sulfur Dioxide Maintenance Area (ADEQ, 2016) ...... 36 Figure 3-3. Historic Visibility Monitoring - Galiuro Wilderness - 10/15/91 @ 1500 Hours - Winter Pristine Conditions (https://www.fsvisimages.com/gallery/GALI/Html/IMG0024.htm) ...... 37 Figure 3-4. Historic Visibility Monitoring - Galiuro Wilderness - 6/4/90 @ 1500 hours - Haze Event (https://www.fsvisimages.com/gallery/GALI/Html/IMG0040.htm) ...... 38 Figure 3-5. Nearest critical habitat to project area ...... 50

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1 Introduction The U.S. Department of Agriculture (USDA), Forest Service, Coronado National Forest (CNF) is proposing to approve a Plan of Operations (PoO) for exploratory drilling activities submitted by Kennecott Exploration Company (KEC) on 1.2 acres of the Safford Ranger District of the CNF.

The CNF prepared this Environmental Assessment (EA) in compliance with the National Environmental Policy Act of 1969 (NEPA) and other relevant Federal and State laws and regulations. This EA discloses direct, indirect, and cumulative environmental effects that would result from Forest Service approval of the PoO for the proposed activities. The Proposed Action is to approve the PoO as submitted by Kennecott. The Proposed Action is subject to the Project- Level Pre-decisional Administrative Review Process under Title 36 Code of Federal Regulations (CFR) Part 218, Subparts A and B. For more details of the Proposed Action, see the “Proposed Action and Alternatives” section of this document on p. 6. 1.1 Location of the Proposed Project Area The Project Area (PA) is located on the Safford Ranger District of the CNF with access through Pinal County and drilling activities conducted in Graham County, Arizona, approximately 12 miles ENE of the town of Mammoth in the following townships, ranges, and sections of the Gila and Salt River Baseline and Meridian (Table 1):

Table 1. Township, Range, and (1/4) Section Locations for all Galiuro Project Disturbances Hole ID Township Range Section County Gal01P /LZ 8S 19E NW¼ 19, SW¼ 18 Graham Gal02P /LZ 8S 19E SW¼ 18 Graham Gal03P/LZ 8S 19E NW¼ 18 Graham Gal04P/LZ 8S 19E SE¼ 18 Graham Gal05P/LZ 8S 19E SE¼ 18 Graham Gal06P/LZ 8S 19E NE¼ 18 Graham Gal07P/LZ 8S 19E NW¼ 17 Graham Gal09P/LZ 8S 19E SW¼ 8 Graham Gal10P/LZ 8S 19E SE¼ 8 Graham Gal12P/LZ 8S 19E SE¼ 8 Graham Gal13P/LZ 8S 19E NE¼ 8 Graham Gal14P/LZ 8S 19E NW¼ 17 Graham

Access to the project’s equipment staging area will utilize 16.1 miles of existing roads, crossing a mixture of BLM, State and private lands (see Figure 2-1). The staging area will be on private lands outside of the CNF. From the staging area on, personnel and equipment will be helicoptered to the planned drill sites, located on CNF lands.

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1.2 Forest Land and Resource Management Plan Direction

1.2.1 Forest Service Mining Regulations The regulatory framework for activities reasonably incident to locatable minerals operations on National Forest System lands is set forth in 36 CFR 228 Subpart A. The term “operations” is defined in 36 CFR Section (§) 228.3(a): Operations. All functions, work, and activities in connection with prospecting, exploration, development, mining or processing of mineral resources and all uses reasonably incident thereto, including roads and other means of access on lands subject to the regulations, regardless of whether said regulations take place on or off mining claims.

The regulations also set forth requirements for environmental protection in 36 CFR §228.8, which state: All operations shall be conducted so as, where feasible, to minimize adverse environmental impacts on National Forest surface resources…

36 CFR §228.8 states specific requirements for environmental protection relating to air quality, water quality, solid wastes, scenic values, fisheries and wildlife habitat, roads, and reclamation.

The PoO is not subject to Forest Service special use regulations. Land uses that are reasonably incident to prospecting, exploration, development, mining or processing of mineral resources under 36 CFR 228 Subpart A are exempt from the scope of the Forest Service special use regulations. As set forth at 36 CFR §251.50(a), the scope of the Forest Service special use regulations includes: “[a]ll uses of National Forest System lands, improvements, and resources, except those authorized by the regulations governing…minerals (part 228)”

1.2.2 Forest Service Mineral Policy The Forest Service mineral policy is taken directly from the Mining and Minerals Policy Act of 1970. Direction from the Forest Service Manual (FSM) 2800, Minerals and Geology, Chapter – Zero Code, defines the mission of the Forest Service for minerals management as follows: To encourage, facilitate, and administer the orderly exploration, development, and production of mineral and energy resources on National Forest System lands to help meet the present and future needs of the Nation.

The objectives of the Forest Service under FSM 2810 (Mining Claims) are to encourage and facilitate the orderly exploration and development of mineral and energy resources on National Forest System lands to maintain a viable and healthy minerals industry. Therefore, pursuant to FSM 2810, the activities proposed in the PoO are consistent with these objectives, and the activities would be integrated with the planning and management of other National Forest System lands.

1.2.3 Forest Plan Consistency Administration of National Forest Systems lands where the project would occur is directed by the Coronado National Forest Land and Resource Management Plan (Forest Plan) (Forest Service, 1986) and applicable amendments. The Forest Plan provides forest-wide and management area direction, including direction for minerals management.

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[The mission of the Coronado National Forest is to] manage the resources … under multiple use and sustained yield principles to provide for balanced contributions to the national welfare and to the economic and social needs of the people of Southeast Arizona and Southwest New Mexico. Management programs are to be oriented to maintain cultural values and a viable rural economy.

The project is located in Forest Management Areas 1 & 4 on the Safford Ranger District. Forest- wide goals include supporting environmentally sound energy and minerals development and reclamation.

The effort to revise the Forest Plan began in Spring 2005. The Coronado National Forest issued its draft EIS and Forest Plan in October 2013. To meet the project’s purpose and need, the Coronado National Forest reviewed both the existing Forest Plan (1986, as amended) and the revised plan currently under development. This project is in compliance with the existing Forest Plan as documented in Chapter 3 in the various resource areas. The proposed revised Forest Plan addresses similar conditions and management actions as the existing plan. The actions described in this EA are consistent with the direction that is currently being evaluated within the revised plan, which includes environmentally sound minerals exploration and developmet. 1.3 Need for the Proposal The purpose of this project is to approve a PoO for exploratory drilling activities submitted by Kennecott. The Forest Service needs to process, administer, and manage mining operations conducted on National Forest Systems (NFS) lands under the authorities of laws and regulations (General Mining law of 1872, as amended and 36 CFR §228 subpart A) that confer on the public a statutory right to go upon and use open public domain lands. 1.4 Scope of the Federal Action The Council on Enviornmental Quality (CEQ) regulations at 40 CFR §1508.25 for implementing NEPA define the “scope” of a NEPA analysis as “…the range of actions, alternatives, and impacts to be considered.” CEQ’s NEPA regulations at 40 CFR Part 1500, public scoping comments, and the context and intensity factors contained at 40 CFR §1508.27 were reviewed and considered in developing the scope of analysis for the Proposed Action.

Mineral development is commonly conducted in progressive steps (FSH 2809.15(12)), and Forest Service regualtions provide for this approach in 36 CFR §228.4(d).

After the Proposed Action is approved and carried out, the mineral development process may continue with another environmental analysis for approval of a mine plan of operations should mineralization characteristics identify a valuable mineral deposit.

1.4.1 Decision Framework The Safford District Ranger will be the responsible official. The need for the proposal outlined earlier sets the scope of the project and analysis to be completed. Based on the analysis, the Safford District Ranger will determine whether the proposed project and alternatives could result in a significant impact and require further analysis through a preparation of an EIS. If there is a Finding Of No Significant Impact (FONSI), the Safford District Ranger will select an alternative deciding:

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♦ Whether to implement PoO; ♦ What specific design criteria or mitigation measures are needed; ♦ What specific project monitoring requirements are needed to assure design criteria and mitigation measures are implemented and effective.

The decision will be based on: ♦ How well the selected alternative achieves the need, ♦ How well the selected alternative protects the environment and addresses issues and concerns, and ♦ How well the selected alternative complies with relevant policies, laws and regulations. If it is not necessary to prepare an Environmental Impact Statement (EIS), the decision will be documented in a Decision Notice and include a determination of consistency with the Forest Plan, NEPA, and applicable laws, regulations, and executive orders. Following issuance of a FONSI and Decision Notice, and resolution of any objections, Kennecott would revise the PoO as necessary to conform to the requirements in the Decision Notice. The PoO would be resubmitted to the Forest Service along with a reclamation bond or other acceptable form of financial assurance (36 CFR §228.13). The financial assurance would provide for reclamation in accordance with the Decision Notice, the revised Plan, and Forest Service reclamation requirements (36 CFR §228.8) in the event that Kennecott failed to complete the reclamation. Once the Forest Service determined that the revised PoO was changed to conform to the Decision Notice and that the financial assurance instrument was acceptable, it would notify Kennecott that the PoO is approved. 1.5 Public Involvement The proposal was listed in the Schedule of Proposed Actions1 in January of 2016. The Proposed Action was provided to the public and other agencies for comment during scoping June 5, 2016 to July 5, 2016. The scoping document was sent to the following: 82 individuals, 41 private organizations, 24 representatives from local tribes, 25 state/county/town officials and 22 federal agencies. From these scoping activities, 7 responses were received.

The Forest performed a content analysis on the comments received to determine if any significant issues were presented. An issue is defined as a point of disagreement, debate, or dispute with a proposed action based on some anticipated undesirable effect caused by the action. Some comments were about the process, were requests for clarification or additional information, or otherwise did not disagree with the Proposed Action because of its anticipated effects. 1.6 Issues The Forest Service separated the issues into two groups: significant and non-significant issues. Significant issues are defined as those directly or indirectly caused by implementing the Proposed Action. Non-significant issues are identified as those: 1) outside the scope of the Proposed Action; 2) already decided by law, regulation, Forest Plan, or other higher level decision; 3) irrelevant to the decision to be made; or 4) conjectural and not supported by scientific or factual evidence. CEQ NEPA regulations require this delineation in Sec. 1501.7, “…identify and

1 https://www.fs.fed.us/sopa/forest-level.php?110305

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eliminate from detailed study the issues which are not significant or which have been covered by prior environmental review (Sec. 1506.3)…”

5 significant issues were identified as a result of public scoping and are discussed below.

Issue #1: There is concern that dust, noise and lights from the drilling operations may disturb wildlife.

Issue #2: There is concern that dust and noise from the helicopter flights may adversely impact the character of the Inventoried Roadless Area, the quality of solitude and the wilderness experience.

Issue #3: There is concern that drilling operations could start a fire.

Issue #4: There is concern that there will be impacts on Copper Creek and San Pedro watershed.

Issue #5: There is concern that operations will disrupt bighorn sheep because the drilling and human presence may discourage them from the area.

These issues were presented to Forest resource specialists to consider and make determinations in their reports and development of mitigation measures.

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2 Proposed Action and Alternatives This chapter describes and compares in detail the Proposed Action, alternatives, and No Action alternative considered for the Galiuro Exploration Drilling project. This section presents the alternatives in comparative form, in order to define the differences between each alternative and providing a clear basis for choice among options by the decision maker and the public. Mitigation and monitoring measures incorporated into the alternatives are also described. 2.1 No Action Alternative The No Action alternative forms a baseline from which the effects of the proposed activities can be measured. Under the No Action alternative, none of the proposed activities would be approved and the current multiple use management of National Forest Systems lands within the project area would continue, as approved by the Forest Service.

If no action is taken, the PoO would not be approved. Therefore, no drilling would occur, which would mean that there would be no construction of drill pads, no equipment transported to the site, no exploration activities, no helicopter traffic in the Inventoried Roadless Area, no water purchased by Kennecott from a local vendor and no reclamation would be needed. Conditions in the project area would not be affected by the No Action alternative. 2.2 Proposed Action The Safford Ranger District, CNF, proposes to approve the PoO submitted by Kennecott. Because the project area is located in an Inventoried Roadless Area (IRA), sites would be accessed by helicopter from an off-Forest staging area on private property. The project is expected to be implemented once the Decision Notice and FONSI are signed, and would be completed within five years.

2.2.1 Access Kennecott employees and contractors would access a staging area located on private lands from the town of Mammoth, Arizona by way of E. Copper Creek and E. Bunker Hill Roads (Figure 2-1). From the staging area, employees and equipment would access drill sites via helicopter.

It is expected each drill site would require roughly 20-25 helicopter trips for equipment mobilization and another 20-25 trips for de-mobilization, being completed over 1-2 days for each site. Once all equipment is in place, 2 to 4 flights would occur each day (for a total of 14-28 trips per week) including crew changes and trips to deliver necessary drilling supplies. See Figure 2-2 for the projected flight path. Flights will only occur during daylight hours (crew changes around sunrise/sunset).

Daily trips (15-20 trips per week) to the water storage area on private lands would be made with a 3000-gallon water truck. A series of temporary hoses (ranging from 1”-2.5” in size) would be laid across the ground from the water storage area to the drill sites. Some of the sites may require up to two miles of water hose (depending on final private water storage location). If a water pump located at the water storage can provide enough power for the change in elevation, no additional pumps/storage would be necessary. However, if the elevation change prevents direct pumping from the water storage area, storage tanks and additional pumps would be placed at locations

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throughout the Project area. These locations will be co-located with permitted drill sites and/or locations pre-approved by the CNF.

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Figure 2-1. Access Map to Galiuro Project (T8S, R18E, Sec. 24; T8S, 19E, Sec. 8 & 17-19; Pinal and Graham Counties, AZ) (provided by KEC)

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Figure 2-2. Galiuro Exploration Drilling Project Proposed Helicopter Flight Path (created by USFS)

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2.2.2 Drilling and Related Activities Kennecott proposes to drill twelve holes (Figure 2-3) in Sections 8, 17, 18 and 19, Township 8 South, Range 19 East, Gila and Salt River Meridian, on a total of 1.2 acres (Table 2). Drilling is proposed to collect core samples at various depths (up to approximately 5,000 feet deep) to assess potential copper mineralization. Diamond drilling is the planned method of exploration for the remoteness of the Galiuro project. Diamond drilling allows ageologist (core logger) to obtain a “solid” core to perform analyses on the lithology, alteration, structure, geotechnical, and mineral characteristics of the sample in addition to obtaining a representative geochemical assay. This would be completed with a Boart-Longyear LFTM 90 (LF-90) drill rig, or equivalent, which requires a much smaller area of disturbance than a typical road accessed drill site and can easily be flown in by helicopter. All drilling would be completed by an experienced and bonded drilling contractor who can pass the rigorous Health, Safety, and Environment requirements mandated by Kennecott.

Prior to drilling activities, each drill site and helicopter landing zone would have vegetation over six inches tall cut and chipped or scattered outside of the project footprint to minimize the potential for fire starts. Once the drill sites are cleared and the drill can be safely secured to the drill deck or ground, the drill is set-up for a vertical or directionally angled borehole. Because many of the holes will most likely exceed 4000’ in depth, it is expected the boreholes will begin with PQ core (3.15”) and surface casing (6” tri-cone cleaning) to a depth of about 50’. PQ core may be obtained from approximately 0-1000’ in order to stabilize the hole in case faults or weathered rocks affect the drilling. If the holes are determined to be stable from surface and/or from 1000’ to 4000’, HQ (2.5”) will be drilled. NQ (1.87”) will be utilized if drill conditions or greater depths require it.

Samples will be transported offsite for analysis and testing. Operations would run continuously up to 24 hours per day, seven days per week. Crews of up to 8 people per shift would occupy and run the drill. The crew size could be up to 20 people during the setup and removal of equipment. It is anticipated that drilling will take approximately 3 months per hole, which includes site preparation, mobilization/de-mobilization of the drill rig, drilling operations and reclamation. There would be no more than two drill rigs operating in the project area at any given time. Table 2. Unpatented Claims with Serial Numbers and Acreage of Disturbance Hole ID Claim Serial# Acreage of Disturbance Gal01P /LZ GAL 217/GAL218 AMC402101/AMC402102 0.1 Gal02P /LZ GAL 213 AMC402097 0.1 Gal03P/LZ GAL 186 AMC399273 0.1 Gal04P/LZ GAL 235 AMC402112 0.1 Gal05P/LZ GAL 242; GAL 240 AMC407122; 0.1 AMC407121 Gal06P/LZ GAL 197; GAL198 AMC399284; 0.1 AMC399285 Gal07P/LZ GAL 255 AMC407131 0.1 Gal09P/LZ GAL 111; GAL 113 AMC391365; 0.1 AMC391367 Gal10P/LZ GAL 161 AMC399248 0.1 Gal12P/LZ GAL 155 AMC399242 0.1 Gal13P/LZ GAL 135 AMC391389 0.1

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Hole ID Claim Serial# Acreage of Disturbance Gal14P/LZ GAL 253 AMC407129 0.1 Total Forest Land 1.2

Each site would have a drill pad occupying an area of 2500 square feet, in addition to a separate helicopter landing zone (LZ) (Figure 2-4) that would occupy a space of 900 square feet and a 350 foot long path. Personnel delivered to each site via helicopter would walk between the LZ and drill pad. Within each 2500 square foot drill pad footprint, there would be one or two 256 square feet elevated wooden drill decks, maximum size of 25 feet long by 14 feet wide by 4 feet deep plastic-lined sumps, equipment, materials and a portable restroom (Figure 2-5).

All down-hole drilling materials will comply with Arizona Department of Water Resources (ADWR) requirements. The sumps would be utilized at each drill site to collect used drilling fluids, which will consist primarily of bentonite water and drill cuttings. The collected drilling fluids and cuttings will be disposed of off of National Forest System lands, at a permitted facility in accordance with applicable State of Arizona regulations.

Activities at the project site would be conducted in accordance with the Fire Plan, Reclamation Plan, Reportable Spill Response Plan, and all mitigation and monitoring mandated by the CNF. These plans and requirements, in addition to a reclamation bond, will be incorporated into the final approved PoO.

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Figure 2-3. Galiuro Project Area Land Ownership with Existing Roads and Proposed Drill Sites (provided by KEC)

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Figure 2-4. Potential Landing Zones in the Galiuro Project Area (provided by KEC)

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Figure 2-5. Generic Drill Site Layout (50'x50') (Sizes/Locations May Vary) (Provided by KEC)

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2.2.3 Equipment Table 3 is a description of the types of equipment that would be located at each of the drill sites. Manufacturer emission data descriptions below refer to the Environmental Protection Agency’s (EPA) designations.

Table 3. Drill Site Types of Powered Equipment Equipment Horsepower Hours Fuel Type Hourly Fuel (HP) Operated Consumption (hrs/day) (gal/hr) Boart-Longyear 175-300 (main 24 Diesel ~5.8 LF 90 Drill Rig engine) 15-25 (mud pump) Light Tower 15-30 8-12 Diesel ~0.2 Solids Removal 0.5-1.0 10-12 Diesel ~0.6-0.8 Unit (Centrifuge) (generator) 5-10 (pump) Generator/welder 10-25 24 Diesel ~1.0-2.1 Pump 6-10 20-22 Gasoline ~0.3-0.4

2.2.4 Proponent Proposed Environmental Protection Measures

2.2.4.1 Air Quality AQ-1: All personnel will maintain speeds that will keep dust levels to a minimum on lands outside of this Plan.

AQ-2: All dust particles from helicopter usage will be very temporary and will quickly dissipate. Since most LZs will have a platform, there is limited concern of excessive dust particles. If dust becomes a problem for the helicopter/pilot, water spray down of the LZs will occur.

AQ-3: Mud mixing will be completed with the appropriate dust masks and will generate limited particles.

AQ-4: There will be no burning of vegetation. The limited slash created during pad preparation will be stored within the disturbance footprint near the topsoil until it is used in the reclamation process. Kennecott will maintain fire suppression devices at all drill sites.

AQ-5: All equipment will maintain manufacturer-supplied pollution control devices.

2.2.4.2 Cultural Resources CR-1: A cultural resource survey has been completed under the direction of the CNF and any conflicts will be avoided, including readjusting drill site locations if necessary.

2.2.4.3 Fish and Wildlife FW-1: Helicopters will not buzz or chase animals.

FW-2: There will be no littering or improper garbage disposal.

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FW-3: All sumps will be fenced to protect wildlife from entrapment. Fences will be a combination of cattle panels and chain-link fence, 4’-5’ in height. Fencing will be secured to t-posts for stability.

FW-4: All trash will be allocated to the appropriate closed storage container. Trash will be stored within view of operations to avoid hazards to wildlife.

FW-5: No firearms will be allowed on-site.

FW-6: Will work with CNF on timing restrictions for wildlife protection.

FW-7: All equipment with hydrocarbons will be properly contained with spill containers, tarps, and spill pads. Any hydrocarbon leaks will be immediately remediated upon discovery, including digging up and properly disposing of the contaminated material.

FW-8: Lighting will be focused on the pad to avoid scatter and disturbance to wildlife.

2.2.4.4 Scenic Values SV-1: Minimizing surface disturbance for all drill sites and landing zones (not exceeding permitted disturbances).

SV-2: Reclaiming surface disturbances of all drill sites (within thirty days of drill hole completion), using CNF-approved native vegetation and seed mixtures.

SV-3: No burning of vegetation or materials will take place.

SV-4: Erosion control measures will be implemented to avoid bank destabilization.

SV-5: Dust will be kept to a minimum on access roads on private lands and at drill sites (watering will occur where necessary).

SV-6: There will be no driving off designated pathways.

SV-7: Drillers and Kennecott representatives will maintain proper housekeeping at all times and at all locations.

SV-8: Lighting will be placed in a manner to avoid community conflict and will be focused on the pad to avoid scatter and disturbance to wildlife.

2.2.4.5 Solid Wastes SW-1: Portable toilets placed at drill sites and/or the staging area will be serviced weekly by a third-party contractor. Drill sites will have new portable toilets flown in and exchanged for the used portable toilets.

SW-2: If allowable, drill cuttings and associated benign fluids/liners will be buried during sump backfilling. If not allowable, these drill cuttings/fluids may be placed down the hole in a grout/cement mix. Any leftover material (cuttings and/or liner, etc.) will be transported for disposal to approved landfills.

SW-3: General trash will be stored on-site in trash receptacles with lids. Once accrued, trash will be taken to the appropriate landfill as necessary. Trash will include food waste, drilling consumables, and non-recyclable plastics. Daily trash removal will occur from all sites.

21 Galiuro Exploration Drilling Project

Hydrocarbon waste (oily waste) will be stored on-site in oil drums with lids, separate from general trash and will be recycled at the appropriate recycling center.

SW-4: Additional Recyclables will be taken to the appropriate recycling facility in Tucson.

2.2.4.6 Water Quality WQ-1: Kennecott will adhere to those rules and apply for permits as required by the CNF and the Arizona Department of Water Resources, and any other pertinent agency.

WQ-2: Water used will be obtained from a private source and will be transported to a private water storage area where it will be pumped to the various drill sites through water lines for storage and drill usage. The amount used will vary but anticipated usage is 1 gallon/minute (~1500 gallons/day) for each active drill rig.

WQ-3: A centrifuge will be used to reduce water consumption while simultaneously separating benign mud/water from drill cuttings.

WQ-4: Water will be pumped at a rate to allow for maximum storage efficiency while avoiding unnecessary water runoff at the drill sites.

WQ-5: Sumps may be lined to avoid water seepage through the rock layers (determined by the CNF).

WQ-6: Drill pad creation and vegetation clearing will be minimized. Drill pads will only be disturbed 1-2 weeks before drilling is to begin.

WQ-7: Reclamation will occur within thirty days of drill hole completion; thus, aiding in revegetation to control erosion.

WQ-8: Water line(s) will be inspected as necessary to avoid leaks and erosion and will only be located in CNF-approved locations. This will include weekly walks along the length of the water hose.

WQ-9: Silt fences and straw waddles will be placed downslope of pad construction/sumps and near any potential stream crossings. Daily monitoring will occur and any observed problems will be corrected immediately.

WQ-10: No planned surface water monitoring is currently scheduled, but will occur if deemed necessary.

WQ-11: Exploration activities at the Galiuro project may be seasonal, thus drill sites will be reclaimed as they are completed and equipment is de-mobilized. This will include removing drill cuttings/drill fluids/liners and backfilling the sumps (unless burying is approved by the CNF). Since water evaporation is not always expedient, the benign water/mud/cuttings combination may be reinserted down the drill hole before reclamation (if no Acid Rock Drainage (ARD) potential exists).

WQ-12: All drill holes will be plugged, capped and abandoned to meet all Federal and State requirements. Depending upon whether or not aquifers are encountered when drilling, the drill holes will have smooth grout from the bottom up and all holes will be plugged at the surface with 20 feet of cement and 2 feet of natural material. If an artesian aquifer is

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intercepted, the hole will be properly plugged to prevent mixing of aquifers and/or effluent escaping from the hole prior to rig demobilization (to ADWR regulations).

WQ-13: No land application of waste water disposal is currently proposed.

WQ-14: CNF-required Best Management Practices (BMPs) (i.e. water bars/berms) will be created where necessary to allow appropriate water drainage. 2.3 Alternatives Considered but Eliminated No additional alternatives were eliminated from detailed study because scoping efforts did not result in identification of issues that could not be addressed through project design or mitigation measures. 2.4 CNF Proposed Mitigation Measures Mitigation measures have been developed by CNF natural resource specialists during their analysis of the Proposed Action to minimize or avoid impacts on resources in the project area. If the proposed action is selected, these measures will be implemented by Kennecott in order to protect resources in the project area.

MM-1: Design drilling pad facilities to minimize surface disturbance and fit into existing clearings wherever possible. Minimize vegetation removal (especially large shrubs and trees).

MM-2: Keep drilling sites clean and in good condition (contain litter and debris, ensure that storm water does not erode soils, etc.).

MM-3: If deemed necessary by the CNF, soils disturbed for preparation of the drill pad and recirculation sump, shall be stored for site reclamation and protected from erosion. Topsoil shall be segregated and stored separate from all other soil horizons. The stockpiled soils shall be maintained in good condition and protected from erosion, further manipulation, or compaction. The duration of topsoil storage must be minimized (1 year or less), as the soil may become sterile without additional storage preservation measures and techniques. Topsoil shall be covered with a breathable fabric (e.g. jute, coir, burlap) and surrounded by BMP’s (e.g. wattles, silt fence) to minimize dust and erosion.

MM-4: Naturalize drilling sites, helicopter landing zones, and footpaths by removing all facilities and debris, backfilling holes,restoring natural grades and drainage patterns , decompacting compacted areas, replacing salvaged topsoil and slash/branches and stabilizing soils if necessary. All disturbed areas will be re-vegetated, using locally collected native seed, according to the USFS Reclamation Plan (RecP). Non-native plants will be controlled according to the monitoring and maintenance section of the RecP.

MM-5: Temporary impacts to all vegetation will be replaced at a ratio of 1:1. Temporarily disturbed areas will be restored to pre-construction conditions or better following construction, according to the performance criteria outlined in the RecP.

MM-6: All areas experiencing ground disturbance from project activities must have their perimeters GPS’d and have pre and post construction representative photos of the sites taken. These shapefiles and photos must be sent to the CNF project administrator.

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MM-7: Prior to entering CNF lands all drill rigs, excavators and equipment must be washed and inspected to ensure they are free of plant and soil material to prevent potential introduction or spread of exotic invasive species. Invasive species can be plants, animals (exotic snails), and other organisms (e.g., microbes), which may cause alteration to ecological functions or compete with or prey upon native species and can cause social impacts (e.g., livestock forage reduction, increase wildfire risk).

MM-8: Adhere to Graham County Article 8 Outdoor Lighting Code to support dark night skies along with any applicable MSHA and OSHA work standards.

MM-9: Avoid/minimize wildlife impacts related to contacting hazardous and other human- made substances in facility water collection/storage basins, evaporation or settling ponds and/or facility storage yards. Design slopes to discourage wading birds and use fencing, netting, hazing or other measures to exclude wildlife.

MM-10: Adhere to proper food storage and sanitation procedures to minimize potential conflicts with black bears and other wildlife. Consult with Arizona Game and Fish for advice on bear-resistant food storage protocols.

MM-11: KEC will develop a Fire Plan, to minimize the risk of starting a fire, and measures to suppress a fire if one is started. Protocols will be included in this plan to direct onsite contractors’ actions should they start a fire or a fire starts on NF land within the vicinity of the drill sites. Aviation protocols will also be addressed in this plan to minimize the potential conflict between Kennecott aircraft and firefighting aircraft if a fire is within the vicinity of the drill site. This fire plan will be reviewed and approved by CNF fire personnel.

MM-12: KEC will avoid the one archaeological site that was recorded during a survey of the project area.

MM-13: All straw wattles used on site to reduce soil erosion will be composed of certified weed-free rice straw, wrapped in biodegradable material (not plastic or photodegradable material). Wattles shall be strategically placed to prevent erosion caused by run-on to the disturbance sites and run-off of the sites.

MM-14: The downhill drill pad boundary shall have any combination of certified weed-free rice straw wattles, certified weed-free rice hay bales, and/or properly installed and keyed-in silt fencing. All natural fibers can be left on site, however all other materials must be removed once sites have revegetated.

MM-15: Erosion and sedimentation controls shall be inspected and maintained weekly until restoration is initiated, and meet USFS BMP performance measures (USFS, 2012). The specifications in a State approved Storm Water Pollution Prevention Plan (SWPPP) that exceed these mitigation measures/BMPs described herein shall have precedent.

MM-16: Drilling fluids and cuttings are to be retained and managed within the permitted drill pad areas. Sumps are to be operated such that they effectively contain all drill cuttings and fluids produced by the drilling operation. KEC shall maintain proper discharge permit coverage at all times of operations from Arizona Department of Environmental Quality (ADEQ), if and as needed, under the Clean Water Act (CWA), potentially under the De Minimis General Permit (DMGP) program. KEC shall install seamless or welded seam sump-liners with sufficient strength to prevent leakage, tearing, or holes. Provide adequate

24 Environmental Assessment lighting of the sump level and retention berms during night operations. During active drilling operations, KEC shall continuously monitor and manage sump fluid levels and available freeboard closely, especially if the boring is beginning to make excessive water, artesian conditions are encountered, and during precipitation events. Maintain stormwater run- on/runoff and erosion controls around sump at all times. KEC shall report any release of drilling water, fluids or cuttings outside the authorized drill pad area to the Forest Mineral Administrator and notify ADEQ, if and as required by that agency. The Forest Service may specify additional assessment or monitoring requirments to assess and remediate any adverse effects resulting from the discharge.

MM-17: If an artesian aquifer is intercepted, the hole will be properly plugged to prevent mixing of aquifers and/or discharge water escaping from the borehole. Materials to control artesian flow shall be pre-staged and readily available at the active drill sites for the driller to immediately take necessary steps to control and mitigate borehole discharge should artesian conditions be encountered. KEC shall notify ADWR and ADEQ if and as required by those agencies. KEC shall notify the Forest Service Minerals Administrator as soon as possible, and within a maximum of 12 hours of becoming aware of artesian flow. A report documenting the artesian flow event (event period, volume of flow, extent of overland and stream impact), agency notifications made, on-site responses, materials used, zones and volumes of material emplaced, environmental effects, remedial actions taken, and any water or soil monitoring requirements by ADWR or ADEQ. The report shall be prepared for each event and shall be submitted to the Forest Service within 30 days of the event occurrence. The Forest Service may specify additional assessment or monitoring requirements to assess and remediate any adverse effects resulting from the discharge.

MM-18: Only water from an EPA/ADEQ regulated public/municipal water system or other United States Forest Service (USFS) pre-approved water source meeting ADEQ Aquifer Water Quality Standards (AWQS), will be introduced into the drill hole while drilling. To reduce the potential for inadvertent introduction of potential contaminants into groundwater, KEC shall provide for disinfection of the supply water if this water is derived from the Old Mercer Ranch dug well. KEC shall disinfect the water in accordance with ADEQ approved methods, procedures and guidelines (ADEQ, Engineering Bulletin 8, 1978). If chlorine is the disinfectant reagent, the concentration shall be maintained between 1 mg/L and 4 mg/L at all times of water delivery onto NFS lands. KEC shall monitor the disinfectant infrastructure and performance at least weekly, and record the following: total supply water delivered to the drill sites (gallons), chlorine levels (as free Cl in mg/L), reagent consumed (volume in ounces or gallons). Free chlorine levels shall be tested with an EPA compliant meter and method. If Ultra-violet (UV) disinfection is used, record the following: total supply water delivered to the drill sites (weekly in gallons), sample and analyze the water supply line for E. coli (by a laboratory licensed by the State of Arizona for that parameter) monthly. Annually, KEC shall provide a summary of the disinfection program. The report should include: the quantity of supply water delivered to the drill sites (in gallons, weekly), records of chlorine dosing (reagent quantities consumed, weekly) and routine inspections Operations and Management (O&M) activities, laboratory reports of the confirmatory E. coli samples (if UV disinfecting), and all free chlorine levels (in mg/L) tested by the operator.

MM-19: To prevent pollutants from migrating off NFS lands, and potentially into private potable domestic water sources, or off-site surface water drainages, the project will require installation, operation and maintenance of an approved backflow preventer on the drilling water supply line. The device shall be installed on or about the boundary of the NFS lands,

25 Galiuro Exploration Drilling Project

and in accordance with the University of Southern California (USC) - Foundation for Cross- Connection Control and Hydraulic Research, Manual of Cross-Connection Control. (USC, 2009) The backflow preventer shall be a Reduced Pressure (RP) principle backflow prevention assembly, and a device approved by and listed on the USC List of Approved Backflow Prevention Assemblies2 for use in public water systems. The device shall be maintained in proper operating condition at all times water is delivered to the piping system upon entering NFS Lands. KEC shall periodically (monthly) inspect the backflow preventer device for any apparent issues (leaks, visible damage). Annually, KEC will have the backflow device recertified by a State certified backflow tester. Annually KEC will send the certificate of inspection and proper operation to the USFS Minerals Administrator.

MM-20: All exploratory boreholes shall be fully plugged (abandoned) with the high solids bentonite grout with a permeability specification of 1 x 10-9 cm/sec. or less. No drill cuttings or fluids shall be returned to the borehole for final disposal prior to grouting. Grout is to be mixed and emplaced following the manufactures instructions. Grout shall be emplaced by tremie pipe or thru the drill stem initially placed near the bottom of the boring, progressing upward until the annular space is filled by displacement. Grout emplacement in the drill hole shall continue to a depth of 2 feet below the ground surface, and then capped with cement. Plugging of all exploratory boreholes shall also be consistent with Arizona Administrative Code R12-15-816, the Arizona Department of Water Resources Well Abandonment Handbook (ADWR, 2008), and the American Society for Testing and Materials (ASTM) International Standard Guide for Decommissioning of Groundwater Wells, Vadose Zone Monitoring Devices, Boreholes, and Other Devices for Environmental Activities (ASTM D5299-99) (ASTM, 2012). Should circulation be lost, or otherwise unable to fill the annular space, the operator shall contact and consult with the Forest Hydrogeologist. Initially, the zone of lost circulation should be identified and sealed off with packers and a continuation of the grout placement from the packer placement depth to the surface. The Forest Minerals Administrator shall be notified at least 24 hours prior to plugging of exploratory boreholes to provide for field inspection and monitoring of the borehole abandonment activities by a Forest Service minerals administrator and/or hydrogeologist. A report documenting the abandonment methods, materials, zones and volumes filled shall be prepared for each borehole and shall be submitted to the Forest Service within 60 days after completion of the abandonment activities. The ADWR well drilling completion, and well abandonment documents shall be copied and forwarded to the Forest Minerals Administrator. These logs shall include detailed geologic/hydrologic logs, completed with water levels, water quality and borehole flow conditions noted.

MM-21: Upon conclusion of drilling at each site, KEC will take a representative sample of the remaining drilling waste in the sump. A representative sample will be collected by arranging an evenly spaced grid across the sump, and collecting a full-depth aliquot from 20 grid nodes. The 20 aliquots will be placed in an appropriate, clean, laboratory provided container and delivered to the analytical laboratory. The laboratory shall process the sample mixing/ homogenized as recommended by EPA and/or Standard Methods procedures. The homogenized composite sample will then be analyzed by a laboratory licensed by the State of Arizona Department of Health Services for the parameters being tested. Waste characterization shall include the following parameters: Acid Base Accounting (ABA), Synthetic Precipitation Leach Procedures (SPLP) (Metals), Toxicity Characteristic Leach

2 http://fccchr.usc.edu/_downloads/List/list.pdf

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Procedures (TCLP) (Metals), EPA 13 Priority Pollutant (metals), pH, total sulfur and total sulfide. This information shall be provided to the Forest Minerals Administrator within 20 days after cessation of drilling at that specific drill pad. The USFS will respond with a timely decision on whether or not the waste can remain and be encapsulated on-site, or if a removal plan will be required pursuant to 36 CFR 228.8 (g)(3).

MM-22: Drill pads shall not be located in obvious drainages or swales that could be subject to conveying appreciable storm water flows, and cause excessive flooding or soil erosion in the drill pad area.

MM-23: To manage and reduce generation of fugitive dust in the active LZ, the LZ shall either be pre-watered or have the periodic application of lignin sulfonate (National Wildfire Coordinating Group, 2016). Once the fugitive dust abatement controls are implemented, and site helicopter operations begins, the effectiveness of the dust controls shall be inspected weekly, and again after larger storm events (> 0.75 inch/24 hours). Any perceived visual deficiencies/declines in the dust control performance by USFS or KEC personnel shall require correction or additional mitigation measures. For purposes of this MM, the “reasonable person standard” shall be initially applied, and is defined as, “the standard of average care, skill, and judgement that a reasonably prudent person would observe under a given set of circumstances”. Should there be a situation where there is an unresolved disagreement concerning dust generation levels using the “reasonable person standard”, a person with EPA visible emissions certification (also known as “smoke-school”) or other instrumentation use with appropriate operator credentials shall be consulted, and the final decisions of compliance with this MM, and any corrective actions required, shall rest with the USFS. KEC shall maintain the LZ fugitive dust inspection records on-site at each drill site for the duration of active site construction, drilling and initial reclamation phases. Annually KEC shall summarize the highlights of dust abatement program inspections, O&M activities, effectiveness of the controls and any adaptive management recommendations to reduce fugitive dust. Any changes recommended thru adaptive management shall be in writing and require USFS written approval before implementing.

MM-24: Verify and provide documentation to CNF Mineral Administrator prior to project mobilization, that all engine powered equipment and fuels meet minimum EPA emission criteria under the Clean Air Act (CAA) for the applicable engine class. KEC shall verify that diesel fuel delivered to the project equipment operated on NFS lands is ultra-low sulfur diesel (ULSD) fuel. Documentation shall include continued annual verification that diesel fuel used for the project meets the EPA requirement of 15 parts per million (ppm) sulfur specification, which was phased in for non-road uses in 2014 (EPA, Diesel Fuel Standards & Rulemakings, 2016). KEC shall maintain fuel type delivery records either at the project staging site, or on- site at each drill site for the duration of active site construction, drilling and initial reclamation phases, and make these records available to the Forest Minerals Administrator upon request.

MM-25: Ensure construction and drilling equipment are properly maintained and feature, as appropriate, factory-installed or approved exhaust mufflers, air intake filters, hoods, enclosures, and other means to minimize noise from engine operation.

MM-26: Require installation, operation and maintenance of water meters on the water supply pipeline at the point of entry, and points of water usuage. The entry point meter may be installed on or about the boundary of the NFS lands (or at the beginning of the pipeline at the project staging area on private lands, see conditions below). One water

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meter will be required at each intended point of use (presumably at each active drill rig site). The meters shall be maintained in proper operating condition, and repaired or replaced no longer than 5 days after a meter failure. In the event of meter failure the monitoring of the operating meters shall continue. The ‘entry point’ water meter may be co-located with the backflow preventer (as required in MM-19), and be located on NFS Lands in close proximity to the NFS boundary. Alternatively, the USFS is amenable to water metering installed on private lands at KEC’s option, as long as the metering criteria is met, and is properly monitored and reported.

MM-27: Should KEC encounter cultural resources during operations, KEC will cease activities immediately and contact CNF officials within 24 hours for further instructions.

MM-28: Within the footprint of the drill sites and landing zones KEC shall cut all vegetation over six inches tall and either chip the material within the site or scatter it at least 50 feet from the project footprint. 2.5 Comparison of Alternatives A summary of the effects of implementing each alternative are described by each resource in the text of chapter 3. This section provides a summary of the effects of implementing each alternative. Information in Table 4 is focused on activities and effects where different levels of effects or outputs can be distinguished quantitatively or qualitatively among alternatives.

Table 4. Comparison of Alternatives Attribute No Action Proposed Action National Forest Policy Consistent Consistent and Forest Plan (Forest Plan) Consistency Meets Purpose and Requires no action, The purpose and need Need therefore is not is met by the Proposed applicable to the Action because it would Purpose and Need authorize Kennecott to conduct drilling activities on their claim in the Galiuro Mountains under the General Mining Act of 1872 (as amended). Effects on Air Quality No effect on air quality May affect, but a combination of mitigations for fugitive dust generation and compliance with the existing CAA provisions for engine operations should reduce effects to negligible levels.

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Attribute No Action Proposed Action Effects on Wildlife and No effects on Federally May affect, but is not Plants listed or Forest Service likely to adversely affect Sensitive species and the endangered lesser habitats long-nosed bat (Leptonycteris curasoae yerbabuenae). No effect to any other T&E or FS Sensitive species. Effects on water No effects on water May affect water resources quality or water quantity quality, but a combination of mitigations for; CWA compliance, BMP implementation, erosion controls, reclamation, drilling fluid management, borehole abandonment, and waste disposal will reduce effects to negligible levels. There may be a contribution to the cumulative water quality as well, but for the reasons above, effects to cumulative water quality are expected to be negligible. No effects to water quantity on Forest water resources. Effects on soil condition No effect on soil Soils would be condition impacted by surface disturbance and compaction activities within the permit areas (drilling pads, LZs and foot paths). A combination of mitigations and reclamation should restore soils to near ambient conditions 3-5 years after the project is complete.

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Attribute No Action Proposed Action Effects on upland No effect on vegetation Upland vegetation and vegetation and and watershed watershed condition watershed condition condition would be impacted by disturbance activities within the permit areas (drilling pads, LZs and foot paths). A combination of mitigations and reclamation should restore upland vegetation and watershed condition to near ambient conditions 3-5 years after the project is complete. Riparian Areas and No effect on riparian No direct activities are Stream Channels areas proposed to occur in riparian areas. A combination of permit mitigations should maintain local riparian areas and stream channels in near ambient conditions. Heritage Resources No effect on Heritage No effect on Heritage Resources Resources Scenery Scenery would remain With mitigation, the as it presently exists Proposed Action is expected to meet Visual Quality Objectives. Recreation and Special No effects on recreation Minimal and Management Areas and management areas insignificant effects to the recreational experiences of Forest users. Fire Management No effect to the Fire Minimal impact to the Management Program Fire Management Program. Coordination will need to take place with Kennecott when we implement the Galiuro Firescape Cake RX Burn Block, Spring 2020.

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3 Environmental Impacts of the Proposed Action and No Action Alternative This chapter describes the affected environment (current conditions) and the environmental effects of the No Action and Proposed Action alternatives. The information used to develop this chapter was obtained from resource field studies of the area, publically available information sources, and communication with relevant government agencies and individuals with knowledge of the project area. Pursuant to direction found at 40 CFR §1500.1(b) and 1500.4, the discussions presented are focused on those issues significant to the action being proposed and deserving of study.

The affected environment is comprised of those areas in and adjacent to the project area that are likely to experience effects as a direct or indirect result of the No Action or Proposed Action alternatives. Each resource analyzed in this chapter may have different analysis areas in which the specific resource could be affected. In those analyses, an environmental effect is defined as any change from the present condition of any resource or resource use that may result as a consequence of the action. Effects include ecological (such as the effects on natural resources and on the components, structures, and functioning of affected ecosystems), aesthetics, historic, cultural, economic, social, and health, whether direct, indirect, or cumulative. Effects may also include those resulting from actions which may have both beneficial and detrimental effects; even if on balance the agency believes that the effect will be beneficial (40 CFR §1508.8).

Effects are analyzed by considering the impact of an action on a resource, as well as the impact of the action on a resource in combination with other projects or activities. For the environmental effects analyses, the following definitions of effects were applied (40 CFR §1508.7, 1508.8):

• Direct effects, which are caused by an action and occur at the same time and place.

• Indirect effects, which are caused by an action and are later in time or farther removed in distance, but are still reasonably foreseeable.

• Cumulative effects, which result from the incremental impact of an action when added to other past, present, and reasonably foreseeable future actions.

An example of a direct effect on soils associated with the Proposed Action would include the excavation of soil to build a drill site. Similarly, an example of an indirect effect would be the potential establishment of an invasive plant species in an area that had been reclaimed after the project had concluded.

The analyses also consider the timeframe over which effects would occur. For the purpose of these analyses, the effects are described in terms of their expected duration, which refers to the permanence and longevity of the impacts. Duration of effects is considered within the following time frames (where applicable to the resource):

• Temporary effects occur during construction and installation, maintenance, and/or decommissioning and persist for less than or equal to two years.

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• Short-term effects persist up to five years after disturbance concludes.

• Long-term effects persist for more than five years after disturbance concludes, and continue for a reasonable period after reclamation. 3.1 Cumulative Effects The Council on Environmental Quality has defined a cumulative impact as “…the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or non- federal) or person undertakes such actions. Cumulative impacts can result from individually minor, but collectively significant actions taking place over a period of time” (40 CFR 1508.7).

A cumulative effects analysis considers the cumulative effects of other past, present or reasonably foreseeable future actions, and evaluates whether addition of the incremental effect of the proposed action would trigger a resource to exceed a potential threshold of significance such as violation of a state or federal law imposed for protection of the environment, an adverse effect to sites listed in or eligible for listing on the National Register of Historic Places, or an adverse effect to threatened or endangered species.

Cumulative effects are evaluated in terms of the specific resource, ecosystem, and human community being affected. A cumulative effects analysis boundary is delineated to prevent dilution of the cumulative effects over large areas. Guidance from the CEQ’s Considering Cumulative Effects under the National Environmental Policy Act was used in identifying geographic and temporal boundaries (Council on Environmental Quality, Presidents Office, 1997). Analysis of the Proposed Action, along with external, public scoping, and internal scoping comments, provided the foundation for identifying the boundaries of the cumulative effects area, and identifying other actions that could lead to cumulative effects.

The geographic cumulative effects boundary is appropriate for the assessed resources because it incorporates areas potentially affected by the Proposed Action. The area evaluated considers potential effects on resources from the Proposed Action to the extent where impacts become non- measureable.

The cumulative effects analysis area is different for noise and climate change. This area was chosen for the analysis because noise-related impacts from the Proposed Action when combined with present and reasonably foreseeable activities would not have a detectable effect more than 0.5-mile from the project area. Climate change is not spatially bound and cumulative effects would likely extend beyond the analysis area.

The contribution of past and present actions on the environment has been taken into account in the existing environmental condition descriptions (affected environment). Existing conditions reflect the aggregate impact of all prior and ongoing human actions and natural events that have affected the environment, and serve as the baseline for analyzing the effects of future actions. Foreseeable future actions are those for which a proposed action has been approved or those proposed for NEPA analysis in the future. Other possible future actions are considered too speculative to include in this analysis.

When reviewing projects to be included in the cumulative effects discussion, projects that were included were determined to overlap in time and space pursuant to CEQ and EPA guidance. Table 5 shows the following projects or activities which could contribute toward cumulative

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impacts within the analysis area. Each resource area may analyze different projects, depending on the potential for impacts.

Table 5. Projects included in Cumulative Effects Analysis Project or Occurring in Miles from NEPA Timeframe Resources Activity Name Safford Project Area Decision Date Under Which Potentially Ranger (Expected or Activities Affected by District Past) have or will the Activity3 occur Yes 0 08/2014 Spring 2020, WL, Soil, Veg, Galiuro subject to Water, Firescape change Scenery, Arch, Management pending H&C (Cake Block weather Burn) conditions and/or funding Yes 1.5 10/2017 12/2017 WL, Veg, W, Travel S, Sc, Rec, Management Range Yes 0 02/2018 03/2018 WL, Veg, W, Forest Plan S, Sc, Rec, Revision Range

3.2 Air Quality

3.2.1 Regulatory Framework Federal - Clean Air Act

The basic framework for controlling air pollutants in the United States is mandated by the 1970 CAA, as amended in 1977 and 1990. The CAA was designed to “protect and enhance” air quality. Section 160 of the CAA requires measures “to preserve, protect, and enhance the air quality in national parks, national wilderness areas, national monuments, national seashores, and other areas of special national or regional natural, recreation, scenic, or historic value.” Stringent requirements are therefore established for areas designated as “Class I” areas. Class I areas include Forest Service and Fish and Wildlife Service wilderness areas over 5,000 acres that were in existence before August 1977 and National Parks in excess of 6,000 acres as of August 1977. Designation as a Class I area allows only very small increments of new pollution above already existing air pollution levels. The Galiuro project is located approximately 2 miles from the Galiuro Wilderness, which is a designated Class I area.

State of Arizona - Air Quality

Air quality regulations implemented by ADEQ include provisions applicable to construction projects which are considered “temporary sources.” A temporary source is defined in the Arizona Administrative Code (AAC), Title 18, Chapter 2, Article 1, Section 101 (R18-2-101), as a source that is portable and does not qualify as an affected source under the acid deposition rules of the Clean Air Act. It should be noted that items of equipment (specifically generators, equipment

3 WL-wildlife, S-soils, Veg-Vegetation, W-water, Rec-recreation, Sc-scenic quality, A-air, H&C-Heritage and Culture, etc.

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engines, and helicoptors) used during construction and drilling activities are generally not subject to State permitting.

Forest Plan

The Forest Plan requires that air resources in the Forest be maintained over time in a manner that meets or exceeds local, state, and Federal air quality standards.

• All management practices will be planned so that air quality will meet local, State and Federal standards (USDA USFS CNF, 1986, FP p45)

3.2.2 Existing Conditions Winds

The closest meteorological station with available wind data compiled for annual average wind rose plots is the Safford municipal airport Automatic Surface Observation System (ASOS) station (Figure 3-1). Given the similarities of the basin and range topography orientation in both the project area and the Safford station location, it is judged that the Safford data should be reasonably comparable to wind conditions at the project area. It is acknowledged that the macro climatology of the project site may differ from the airport data, however it is the best available dataset processed for this purpose. As the total project emissions are anticipated to be below ADEQ/EPA permitting thresholds, dispersion modeling is judged to not be necessary for this project. Therefore, meteorological parameters such as stability class, mixing height and inversion layers were not researched or acquired for this analysis.

As the data indicates in Figure 3-1, prevailing winds average 8.0 miles per hour. The data also exhibit a bimodal pattern with the most frequent and strongest winds from the WNW, with a secondary and lighter ESE prevailing wind. Information on seasonal precipitation and temperature is presented in Table 8 in section 3.6.2.

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Figure 3-1. Annual Average Wind Rose Plot for Safford Municipal Airport

Air Quality

There are no known air quality data in the project area, and there are no known State air quality monitoring stations within 25 miles of the project area (ADEQ, 2016b). The closest ADEQ air quality monitoring station is located in Hayden, AZ. Because of the distance of this station from the project, and known sources proximal to the Hayden monitoring station, the data recorded there would not be expected to be representative of air quality in the project area nor the Galiuro Wilderness.

The proposed project is located in Graham County, and is not located in a designated air quality ‘non-attainment’ area (Figure 3-2, ADEQ, 2016). Immediately to the west of the project area and the boundary of NFS lands is the Graham/Pinal County border. The area to the west in Pinal County, is designated as a Sulfur Dioxide Maintenance area.

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General Project Area

Figure 3-2. Sulfur Dioxide Maintenance Area (ADEQ, 2016)

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Visibility

The northern boundary of the Galiuro Wilderness is located approximately two miles southeast of the project area. With the passage of the Wilderness Act in 1964 (Public law 88-577) the 76,317 acre Galiuro Wilderness was designated a Federal Class 1 airshed.

The Galiuro Wilderness automatic photographic monitoring system operated between 1985 and 1992, and is available for archived images. Two examples of this archive are in Figure 3-3 and Figure 3-4 below. The closest Interagency Monitoring of Protected Visual Environments (IMPROVE) air quality stations are either the Saguaro National Park West, or the Chiricahua National Park. Due to the distances from the Galiuro wilderness to these monitoring stations, data from these stations would not necessarily be representative of the air quality in the Galiuro Wilderness.

Figure 3-3. Historic Visibility Monitoring - Galiuro Wilderness - 10/15/91 @ 1500 Hours - Winter Pristine Conditions (https://www.fsvisimages.com/gallery/GALI/Html/IMG0024.htm)

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Figure 3-4. Historic Visibility Monitoring - Galiuro Wilderness - 6/4/90 @ 1500 hours - Haze Event (https://www.fsvisimages.com/gallery/GALI/Html/IMG0040.htm)

3.2.3 Environmental Consequences

3.2.3.1 Methodology To analyze potential impacts on air resources, mapping tools were used to determine which airshed the project area is located in. This consisted of acquiring data from various agencies for air quality information in the project area. Information was also obtained from the PoO and various PoO supplemental documents.

Information Sources

Site-specific and general area information for this analysis was largely gathered from the sources below.

• Resource Policy and Guidance documents

External Resources:

• ADEQ - Air quality data and standards

• National Oceanic and Atmospheric Administration (NOAA) and affiliates - Climate data

• EPA – Air quality data and standards

• KEC – Galiuro PoO, proposed drill pad locations (GIS)

• KEC – Air emissions estimates

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Incomplete and Unavailable Information

The following desirable information was identified as incomplete or unavailable:

• Site-specific existing air quality

• Ambient air quality data [i.e., nitrogen oxides (NOx); sulfur dioxide (SO2); carbon monoxide (CO); particulate matter (PM10 and PM2.5), and volatile organic compounds (VOCs)]

• The results of air quality modeling of under ambient, proposed action, and cumulative effect conditions

Assumptions

To address some of the above incomplete/unavailable information, the effects analysis herein are based on the following assumptions:

• Based on guidance from ADEQ the project does not require an Air Quality permit under the CAA from ADEQ

• There is insufficient data to quantitatively model estimates of direct air quality and visability effects in the Class 1 airshed of the Galiuro Wilderness. However, if analyzed, the result would undoubtedly determine through calculation, that there is a contribution of pollutants to the local airshed from implementation of the Proposed Action.

3.2.3.2 Effects from No Action Because the no action alternative would not authorize any activities in the project area, there would be no potential to incur direct or indirect effects on air resources in the project area.

3.2.3.3 Effects from Proposed Action The project is not located in an air quality ‘non-attainment area’. Air emissions associated with the Proposed Action are: Engine emissions from the diesel powered drill rig, ancillary pumps, generators, and miscellaneous power equipment; jet engine emissions from helicopter operations; fugitive dust from helicopter landings and takeoffs, off-forest vehicle travel on non-paved roads, and construction-related fugitive dust emissions.

There is currently insufficient data to quantitatively model estimates of direct net air quality effects, nor is it possible to numerically calculate the potential for measurable visibility reduction in the Class 1 airshed of the Galiuro Wilderness. However, there is certainly a contribution of pollutants to the local airshed from implementation of the Proposed Action. Based on the prevailing winds and the location of the proposed activity and location and close proximity (approximately 2 miles) of the Galiuro Wilderness, emissions generated by the project may result in temporary and intermittent incremental effects to the Federal Class I airshed. Mitigation measures are proposed and include ensuring compliance with EPA engine emission controls and use of ultra-low sulfur diesel fuel, as well as implementation of dust abatement measures in helicopter landing zones.

3.2.3.4 Cumulative Effects The project would result in a temporary and intermittent incremental increase in air quality emissions. One foreseeable action with the potential for cumulative effects is the Galiuro

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Firescape project. This vegetation treatment project may have temporary effects to air quality and visibility that could overlap the PA in space and/or time. The prescribed burn treatments in the Galiuro Firescape project would generate additional temporary and intermittent incremental increase in air quality emissions. After the project is completed there would no longer be any cumulative effects to air quality. 3.3 Cultural Resources Cultural resources include pre-contact archaeological sites, historic properties, buildings and structures, and traditional cultural properties and life ways. Traditional cultural resources are associated with cultural practices or beliefs that are rooted in a traditional community’s history and are important in maintaining the cultural identity of the community.

The cultural resources analysis evaluates the effects of the Proposed Action and No Action alternatives on cultural resources within the PA.

3.3.1 Regulatory Framework Under Section 106 of the National Historic Preservation Act, the Forest Service has the responsibility, in consultation with the State Historic Preservation Officer, Tribes, and other interested parties, to identify historic properties within the area of potential effect and to determine the effects that the proposal could have on historic properties and cultural resources. Under Section 106, protection of historic properties is the same for National Register of Historic Places (NRHP) eligible sites as for listed sites. A process for identifying historic properties, potential effects, and possible mitigation is defined in the National Historic Preservation Act’s implementing regulations at 36 CFR 800. The First Amended Programmatic Agreement Regarding Historic Property Protection and Responsibilities among Arizona State Historic Preservation Officer and USDA Forest Service Region 3 and other parties contains guidelines pertaining to inventory of cultural resources and consultation requirements determined by the nature of the undertaking. In addition to NEPA and NHPA, the Forest Service addressed other pertinent laws, regulations, and policies in conducting the cultural analysis presented in this EA, including:

• Archaeological Resources Protection Act of 1979

• Executive Memorandum of April 29, 1994, Government-to-Government Relations with Native American Tribal Governments File Index I D 2 RCMB00731

• Executive Order 13007, May 24, 1996, Indian Sacred Sites

• Executive Order 13175, November 6, 2000, Consultation and Coordination with Indian Tribal Governments

• Forest Service Manual 2360, Heritage Program Management

• Forest Service Region 3 Tribal Relations Policy

The Federal government also has a trust responsibility related to the welfare of American Indians and their land and resources. Indian trust responsibilities for the Forest Service are defined by executive orders, laws, and treaties that are related to National Forest System lands. While there are no treaties tied to the project area, the Forest Service fulfills trust responsibilities by following laws that protect tribal rights and by making an effort to manage National Forest System lands in

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a way that accommodates the needs and concerns of Native American groups, while still maintaining a responsibility to all citizens of the U.S.

Although the cultural resource survey completed for this project was designed to locate all archeological and historic sites that might be eligible for the National Register, such sites may go undetected for a variety of reasons. Pursuant to the provisions found in 36 CFR 800.13, should any previously unidentified cultural resources be discovered during project implementation, activities that may be affecting that resource will be halted immediately. The resource will be evaluated by a professional archeologist and consultation will be initiated with the Arizona State Historic Preservation Officer (SHPO) to determine appropriate actions for protecting the resource and for mitigating any adverse effects on the resource. Project activities will not be resumed until the resource is adequately protected and until agreed upon mitigation measures are implemented with SHPO approval.

3.3.2 Existing Conditions Few cultural resource surveys have been conducted in the Galiuro Mountains and only one archaeological site has been excavated. A total of 50 sites have been recorded in Forest Service files. Cultural resources within the Galiuros include a variety of archaeological and historical sites created during the long course of human occupation. These include past habitations, artifact scatters, rock art sites, buildings, and other properties that bear evidence of human activity and use, and have scientific, historic, and cultural importance. Prior to European contact (pre-contact), extensive Native American occupation occurred in the nearby Gila River Valley, San Simon, Sulphur Springs, and San Pedro valleys. While long-term habitations were concentrated in these valleys, the high elevation areas contain specialized activity and sacred sites used at various times over the centuries. The condition of many of the recorded cultural resource sites in the Galiuro Mountains is not known. Given the relatively remote location and limited public access to the range, vandalism is not expected to be a major problem.

Prior to the survey conducted by SWCA Environmental Consultants, no cultural resources had been recorded within a 1 mile radius of the project area. The site recorded by SWCA is a historical site that may be related to historic mining or ranching; however, no evidence of either activity was observed in the area surveyed.

3.3.3 Environmental Consequences

3.3.3.1 Methodology A cultural resources survey of the area of potential effects (APE) for this project was conducted by SWCA Environmental Consultants (Barr 2016). Their pre-field research included a records search of the National Register of Historic Places, the AZSITE database, and the Coronado National Forest cultural resource files to identify previously conducted surveys and previously recorded cultural resources in the APE. No cultural resources have been recorded within a 1-mile radius of the PA. Historic maps, USGS quadrangles and General Land Office (GLO), were examined to identify historic-era properties. No cultural features were depicted on these maps within the APE.

The survey was conducted using standard procedures following Arizona State Museum (ASM) guidelines for survey coverage and site recording methodologies. Although the proposed areas of disturbance total less than 2 acres (1.2 ac), SWCA surveyed a total of 8.22 acres to permit in-field adjustments. One new archaeological site was recorded as a result of the survey.

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3.3.3.2 Effects from No Action Under the No Action alternative, mineral exploration activities would not occur. No drilling would occur. There would be no effects to cultural resources, either direct or indirect.

3.3.3.3 Effects from Proposed Action With respect to this project, direct effects are those that will occur during project implementation. In essence, any activity that has the potential to disturb the ground has the potential to directly affect cultural resource sites. Specific activities in the Galiuro Drilling Project that have the potential to directly affect cultural resources include the following:

• Drill pad and drill deck platform preparation;

• Landing zone preparation;

• Exploratory drilling;

• Foot traffic between landing zones and drill pads;

• Erosion control where ground disturbing methods are used.

The cultural resource site recorded by SWCA will be avoided and as there are no known cultural resources located within the remainder of the APE, it has been determined that the project activities are expected to have no effect on cultural resources.

3.3.3.4 Cumulative Effects Cumulative impacts may result from a combination of the proposed action with other past, current, and foreseeable activities (see Table 5). Wildland fire and suppression activities are potential sources of impacts to cultural resources.

In the past, historic properties have been damaged by wildfires. Properties could be adversely affected by high-intensity wildfire and by fire suppression efforts. Under the Galiuro Firescape Management project, fewer sites would likely be damaged from wildfire and/or suppression activities due to the removal of hazardous fuels. Known cultural resource sites would receive protection from project activities, either through avoidance, or controlled, low intensity burning to reduce fuel loads within site boundaries. There could likely be small, beneficial cumulative effects from the Galiuro Firescape project on heritage resources through the reduced potential for high intensity wildfires. 3.4 Biological Resources

3.4.1 Regulatory Framework Forest Service policy regarding designation of sensitive species includes those species identified by the Regional Forester (U.S. Forest Service, 2014a) for which population viability is a concern. Species appearing on the sensitive species list can include federally listed species, migratory birds, bald and golden eagles, and management indicator species (MIS). The National Forest Management Act of 1976 directed the Forest Service to identify and actively monitor MIS to assess effects of forest management activities on native biota. The Forest lists 27 MIS (U.S. Forest Service, 2012). Two species, the spotted towhee (Pipilo maculatus) and hairy woodpecker (Picoides villosus), are each listed twice as indicators of two different plant communities. The

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species indicator, aquatic macro-invertebrates, is a composite of 29 animal species that are indicators of aquatic environments.

Section 7 of the Endangered Species Act (ESA) requires Federal agencies to ensure that any action authorized, funded, or carried out by them is not likely to jeopardize the continued existence of listed, threatened, or endangered species or modify their critical habitat. Under section 7(a)(2), each Federal agency shall, in consultation with the Secretary, insure that any action authorized, funded, or carried out by such agency is not likely to jeopardize the continued existence of any endangered species or threatened species or result in the destruction or adverse modification of designated critical habitat. Consultation is required when a Federal agency determines that any action they authorize, fund, or carry out “may affect” a listed species or designated critical habitat. Information on the section 7 consultation process is available in 50 CFR Part 402 and the Service’s Endangered Species Consultation Handbook4. A Section 7 consultation with the United States Fish & Wildlife Service (USFWS) is required if listed species under its jurisdiction or their designated critical habitat could be affected by a proposed action.

Under the Migratory Bird Treaty Act (MBTA), it is unlawful to take, kill, or possess migratory birds. Executive Order 13186, issued on January 11, 2001, further defines the responsibilities of federal agencies to protect migratory birds. The MBTA also makes it illegal for anyone to take or possess (among other activities) the parts, nests, or eggs of migratory birds except under the terms of a valid Federal permit. The USFWS includes as migratory birds “all species native to the United States or its territories, which are those that occur as a result of natural biological or ecological processes” (70 Federal Register 12710, March 15, 2005). Protected migratory birds are listed at 50 CFR 10.13.

The Bald and Golden Eagle Protection Act (BGEPA) was enacted in 1940 (amended several times since then) and prohibits anyone without a permit issued by the Secretary of the Interior from “taking” eagles, including their parts, nests, or eggs. The BGEPA provides criminal penalties for persons who “take, possess, sell, purchase, barter, offer to sell, purchase or barter, transport, export or import, at any time or any manner, any bald eagle or any golden eagle, alive or dead, or any part, nest, or egg thereof.”

The BGEPA defines “take” as “pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest or disturb.”

3.4.2 Existing Conditions The project area elevation ranges between 4,633 feet (1,412 m) and 5,860 feet (1,786 m) above mean sea level (amsl). The project area is in the Interior Chaparral biotic community (Brown 1994). The project area is located in the Galiuro Mountains, approximately 12 miles (19.3 km) ENE of Mammoth, Arizona. The San Pedro River is approximately 10.7 miles (17.2 km) southwest and Aravaipa Canyon is approximately 9.9 miles (15.9 km) north of the project area. Copper Creek is located in the northeastern portion of the project area, Pipeline and Marics Canyons bisect the project area, Cake Mountain and Biscuit Peak are south of the project area, and numerous springs are within a 1-mile (1.6-km) radius. These springs include Norton Spring, Cake Mountain Spring, Willow Spring, and two unnamed springs. Surface sediments are associated primarily with the Middle Miocene to Oligocene Volcanic Rocks (USGS 2015). The Middle Miocene to Oligocene Volcanic deposits consist of lava, tuff, fine-grained intrusive rock,

4 https://www.fws.gov/ENDANGERED/esa-library/pdf/esa_section7_handbook.pdf

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and diverse pyroclastic rocks. The variable volcanic rocks include basalt, andesite, dacite, and rhyolite (USGS 2015). Surface sediments are generally rocky, reddish brown loam deposits.

No saguaros (Carnegiea gigantea), aquatic habitats (including stock ponds), broadleaf deciduous riparian vegetation communities (i.e., communities containing willow [Salix spp.], cottonwood [Populus spp.], or ash [Fraxinus spp.], etc.), or potential bat roost sites (e.g., natural caves or mine features) occur in the project area. There were multiple agaves (Agave spp.) observed in the project area; however, they occurred in low densities.

At higher elevations within the Galiuro Mountains, pine forest in the Madrean Province is dominated by ponderosa, southwestern white, Apache, Arizona and Chihuahua pines intermixed with some fir, Gambel oak and Alligator juniper. Fire suppression methods within this regime over the last century have created unnaturally dense fuel accumulations which encourage catastrophic fire occurrences (Allen 1994). Riparian areas are found in most of the streambeds which have enough water flow to support riparian vegetation. Cottonwood, sycamore, willow trees and many different grasses and shrubs are found within these areas.

Over time, the Madrean Provinces within the Galiuro Mountains have become denser in character due to fuel build-up, shrub and tree encroachment into grasslands, natural meadows and openings that were found throughout the mountain range.

Landing Zone and Drill Site O1P

This landing zone and associated drill site are located toward the south end of the project area at an elevation of approximately 4,700 feet amsl, and there is a proposed foot path that leads up to the drill site. The upland vegetation includes velvet mesquite, cholla (Cylindropuntia sp.), goldenbush (Ericameria sp.), catclaw mimosa (Mimosa aculeaticarpa var. biuncifera), and several grasses and forbs, including annual bursage (Ambrosia acanthicarpa), longleaf false goldeneye (Heliomeris longifolia), cane bluestem, purple grama (Bouteloua radicosa), poverty threeawn, and green sprangletop. Xeroriparian vegetation occurs adjacent but outside of the project limits includes juniper (Juniperus sp.), oak, Arizona sycamore, and Arizona cypress (Cupressus arizonica).

Landing Zone and Drill Site O2P

This landing zone and associated drill site are located toward the south end of the project area at an elevation of approximately 4,790 feet amsl, and there is a proposed foot path that leads up to the drill site. The dominant vegetation observed includes sideoats grama, poverty threeawn, cane bluestem, purple grama, and curly mesquite grass. Other vegetation observed includes sacahuista, catclaw mimosa, goldenbush, velvet mesquite, Wright’s buckwheat, longleaf false goldeneye, and hedgehog cactus. Velvet mesquite, juniper, and Emory oak (Quercus emoryi) were observed outside the project limits.

Landing Zone and Drill Site O3P

This landing zone and associated drill site are located toward the south end of the project area at an elevation of approximately 5,250 feet amsl. The vegetation is very similar to that observed at Drill Site O2P and associated landing zone, and includes cane bluestem, fingergrass, green sprangletop, poverty threeawn, purple grama, sotol, goldenbush, catclaw mimosa, Wright’s buckwheat, Palmer’s agave, pinkflower hedgehog cactus, velvet mesquite, prickly-pear cactus (Opuntia sp.), and ocotillo (Fouquieria splendens).

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Landing Zone and Drill Site O4P

This landing zone and associated drill site are located toward the south end of the project area at an elevation of approximately 5,480 feet amsl. The vegetation observed includes Sonoran scrub oak (Quercus turbinella), sotol, prickly-pear cactus, Palmer’s agave, Wright’s buckwheat, mountain mahogany (Cercocarpus montanus), cholla, juniper, goldenbush, barrel cactus (Ferocactus sp.), Emory oak, catclaw mimosa, fingergrass, green sprangletop, purple threeawn, tanglehead (Heteropogon contortus), and sideoats grama.

Landing Zone and Drill Site O5P

This landing zone and associated drill site are located toward the south end of the project area at an elevation of approximately 5,070 feet amsl. The vegetation observed at the landing zone includes juniper, velvet mesquite, catclaw mimosa, goldenbush, barrel cactus, Sonoran scrub oak, fingergrass, cane bluestem, green sprangletop, purple threeawn, and longleaf false goldeneye. The drill site contains similar vegetation as the landing zone, and also contains Emory oak, sacahuista, cholla, prickly-pear cactus, agave (Agave sp.), hairy grama (Bouteloua hirsuta), sideoats grama, and curly mesquitegrass. A single patch of Bermuda grass (Cynodon dactylon) was also observed.

Landing Zone and Drill Site O6P

This landing zone and associated drill site are located in the central portion of the project area at an elevation of approximately 5,140 feet amsl. The vegetation observed at the drill site includes catclaw mimosa, cholla, sacahuista, agave, juniper, threadleaf snakeweed, burroweed (Isocoma tenuisecta), delicate muhly (Muhlenbergia fragilis), purple grama, fingergrass, green sprangletop, sideoats grama, sotol, yucca (Yucca baccata), cocklebur (Xanthium sp.), and Wright’s buckwheat. The vegetation at this landing zone alternative was similar to that observed at Drill Site O6P but also included sideoats grama, sacaton, sotol, globe mallow (Sphaeralcea ambigua), and Sonoran scrub oak.

Landing Zone and Drill Site O7P

This landing zone and associated drill site are located in the central portion of the project area at an elevation of approximately 5,670 feet amsl. The vegetation observed at the alternative landing zone includes cholla, sacahuista, Schott’s century plant/shindagger agave (Agave schottii), annual bursage, Wright’s buckwheat, pink flower hedgehog cactus, delicate muhly, and one cheatgrass (Bromus sp.) plant. The vegetation observed at the drill site was similar and also included catclaw mimosa, dead oak trees, and a variety of ferns, grasses, and forbs.

Landing Zone and Drill Site O9P

This landing zone and associated drill site are located in the central portion of the project area at an elevation of approximately 5,250 feet amsl. The vegetation observed at the landing zone includes threadleaf snakeweed, catclaw, cholla, sacahuista, shin dagger agave, green sprangletop, Emory oak, Sonoran scrub oak, mountain mahogany, Wright’s buckwheat, cliff muhly (Muhlenbergia polycaulis), purple grama, nightshade (Solanum sp.), and stinkgrass (Eragrostis cilianensis). The vegetation at the drill site is similar, with alligator juniper (Juniperus deppeana) additionally observed.

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Landing Zone and Drill Site O10P

This landing zone and associated drill site are located in the central portion of the project area at an elevation of approximately 5,880 feet amsl. The vegetation observed includes goldenbush, sacahuista, shin dagger agave, cholla, mountain mahogany, Wright’s buckwheat, alligator juniper, purple grama, delicate muhly, and deergrass.

Landing Zone and Drill Site O12P

This landing zone and associated drill site are located toward the north end of the project area at an elevation of approximately 5,375 feet amsl. The vegetation observed includes threadleaf snakeweed, sacahuista, cholla, oak, alligator juniper, agave, prickly-pear cactus, purple grama, cane bluestem, fingergrass, curly mesquitegrass, and freckled milkvetch (Astragalus lentiginosus). Copper Creek occurs directly below the drill and landing site and contains the following vegetation: oak, juniper, single-leaf pinyon (Pinus monophylla), and sycamore.

Landing Zone and Drill Site O13P

This landing zone and associated drill site are located toward the north end of the project area at an elevation of approximately 5,280 feet amsl. The vegetation observed at the drill site includes threadleaf snakeweed, alligator juniper, redberry juniper, cholla, sotol, oak, goldenbush, fingergrass, curly mesquitegrass, and cane bluestem. The vegetation observed at the landing zone includes agave, sotol, mountain mahogany, Wright’s buckwheat, catclaw mimosa, hairy grama, and purple grama.

Landing Zone and Drill Site O14P

This landing zone and associated drill site are located in the central portion of the project area at an elevation of approximately 5,800 feet amsl. The vegetation observed includes agave, sotol, alligator juniper, shindagger agave, annual ambrosia, cholla, Wright’s buckwheat, fingergrass, stinkgrass, and purple threeawn.

3.4.3 Environmental Consequences

3.4.3.1 Methodology The scope of work for the Biological Assessment & Evaluation (BAE) and subsequent specialist report included: • review of the U.S. Fish and Wildlife Service (USFWS) species list for Graham County; • review of the USFS sensitive-species list for the CNF Safford Ranger District; • review of the Arizona Game and Fish Department (AGFD) online occurrence records for special status species near the project area; • review of the Management Indicator Species (MIS) for the CNF; • review of the Birds of Conservation Concern (BCC) listed for Graham County by USFWS; • review of the species protected by the MBTA and BGEPA; • review of the Species of Greatest Conservation Need (SGCN) predicted to occur based on predicted range models provided by the Heritage Data Management System (HDMS); • field reconnaissance of the project area; and • evaluation of the potential for the species listed in this report to occur in the project area.

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A SWCA biologist conducted a field reconnaissance of the project area on November 11–13, 2015. A USGS 7.5-minute topographic maps (Oak Grove Canyon and Rhodes Peak, Arizona), GPS coordinates, and helicopter service provided by Kennecott were used for general orientation and to locate the project sites. The field reconnaissance consisted of a pedestrian survey of the project area to evaluate vegetation and landscape features considered important to the potential occurrence of special-status plant and animal species. SWCA surveyed a total of 8.22 acres during the original field reconnaissance of the project area, which included the 1.2 acres of proposed disturbance at the 12 drill sites and helicopter landing zones. In addition, species-specific surveys for western yellow-billed cuckoos and golden eagles were conducted in the vicinity of the project area to determine the presence or absence of individuals. Three transects were surveyed four times for western yellow-billed cuckoos between June 29 and August 8, 2016, using standard USFWS protocol (Halterman et al. 2015). Helicopter-borne golden eagle nest surveys were conducted on April 20, 2016. Vegetation was classified to the community level according to the map “Biotic Communities of the Southwest” (Brown 1994).

The project limits for the 12 drill locations consist of a maximum footprint of 50 × 50 feet (15.2 × 15.2 m), a personnel foot path from LZ to drill pad, and twelve 30 × 30–foot (9.1 × 9.1–m) helicopter landing zones. All activities associated with this project would be contained within this defined area.

The analysis area for biological resources is defined as the project area of approximately 1.2 acres plus a larger surrounding area (350-foot [107-m] buffer) that may experience direct or indirect temporal and spatial impacts from the proposed project. Temporally, the potential on- site and off-site impacts resulting from the proposed project encompass all the activities associated with construction (approximately 5 years).

The analysis area includes areas outside the project area that may be affected by noise or dust. To develop the analysis area, a 350-foot-radius (107-m-radius) buffer was chosen because the project’s exploratory mining noise is likely the most far-reaching impact to biological resources. Although noise has the potential to impact several wildlife species within the analysis area, the noise levels at which different wildlife species are impacted are largely unknown. However, several noise studies have been conducted for one species, Mexican spotted owl (Strix occidentalis lucida), including a study on the impacts of helicopter noise on the species, which is directly relevant because helicopters would be used for this project. Due to the paucity of research on the effects of noise disturbance to other wildlife species in the analysis area, this research was used as a surrogate for all wildlife species assessed in this document. Delaney et al. (1999) recommended a 344-foot (105-m) radius to avoid flush responses to helicopter overflights and chainsaws. Although chainsaw noise is less than the approximately 95 A-weighted-decibel (dBA) noise levels for the drilling activities, the helicopter noise of approximately 97 dBA is comparable between Delaney et al. (1999) and this proposed project. The extent of dust impacts, however, is likely to be less than the 350- foot-radius (107-m-radius) potential extent of noise impacts due to small project limits of this project. Although the extent of dust impacts to species is unknown, it would likely continue to decrease with increased distance from the project area.

Species Evaluation The potential for occurrence of each species was summarized according to the categories listed below. Because not all species are accommodated precisely by a given category (i.e., category definitions may be too restrictive), an expanded rationale for each category assignment is provided. Potential for occurrence categories are as follows:

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Known to occur—the species has been documented in the project area by a reliable observer.

May occur—the project area is within the species’ currently known range, and vegetation communities, soils, etc., resemble those known to be used by the species.

Unlikely to occur—the project area is within the species’ currently known range, but vegetation communities, soils, etc., do not resemble those known to be used by the species, or the project area is clearly outside the species’ currently known range.

Following USFWS recommendations, one of three categories of possible effect as a result of a project can be assigned to those species listed (i.e., threatened or endangered) by the USFWS, and their critical habitat (if designated). Because Forest Service sensitive species are not protected under the authority of the ESA, effects determinations for these species do not follow USFWS recommendations. The effects determinations recommended by USFWS are as follows:

May affect, is likely to adversely affect—the proposed project is likely to adversely affect a species if 1) the species occurs or may occur in the project site; and 2) any adverse effect on listed species may occur as a direct or indirect result of the proposed action or its interrelated or interdependent actions, and the effect is not discountable, insignificant, or beneficial. In the event that the overall effect of the proposed action is beneficial to the listed species but also is likely to cause some adverse effects, then the proposed action “is likely to adversely affect” the listed species.

May affect, is not likely to adversely affect—the project is not likely to adversely affect a species if 1) the species may occur but its presence has not been documented and/or surveys following approved protocol have been conducted with negative results; and/or 2) project activity effects on a listed species are expected to be discountable, insignificant, or completely beneficial.

Beneficial effects are contemporaneous positive effects without any adverse effects on the species. Insignificant effects relate to the size of the impact and should never reach the scale where take occurs. Discountable effects are those extremely unlikely to occur. Based on best judgment, a person would not 1) be able to meaningfully measure, detect, or evaluate insignificant effects; or 2) expect discountable effects to occur.

No effect—the project will have no effect on a species if 1) it has no likelihood of effect on a listed species or its designated critical habitat (including effects that may be beneficial, insignificant, or discountable); or 2) the species’ habitat does not occur in the project site. The effect determinations for any species not protected under the ESA (e.g., Forest Service sensitive species and SGCN) are as follows:

• No effect—the project would have no impact on a species if 1) the species is considered unlikely to occur (range, vegetation, etc., are inappropriate); and 2) the species or its sign was not observed during surveys of the project areas. • Beneficial effect—the project is likely to benefit the species, whether it is currently present or not, by creating or enhancing habitat elements known to be used by the species. • May effect individuals, but is not likely to result in a downward trend toward federal listing as threatened or endangered or loss of viability—the project is not likely to adversely impact a species if 1) the species may occur but its presence has not been

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documented; and 2) project activities would not result in disturbance to areas or habitat elements known to be used by the species. • May effect individuals and is likely to result in a downward trend toward federal listing as threatened or endangered or loss of viability—the project is likely to adversely impact a species’ population if 1) the species is known or likely to occur in the project area; and 2) project activities would disturb areas or habitat elements known to be used by the species.

3.4.3.2 Effects from No Action Under the No Action alternative, mineral exploration activities would not occur. No drilling would occur. Wildlife habitats and current patterns of use in the area would remain intact. Aquatic and terrestrial habitats would remain unfragmented and undisturbed.

3.4.3.3 Effects from Proposed Action

3.4.3.3.1 Federally Listed Species Of the 22 species listed for Graham County by USFWS only the lesser long-nosed bat (Leptonycteris curasoae yerbabuenae) may occur in the project area. The project area is clearly beyond the known geographic or elevational range of the other 21 species or it does not contain vegetation or landscape features known to support these species, or both. Habitat requirements, potential for occurrence, and possible effects on these species are summarized in Table 6. The lesser long-nosed bat is discussed in further detail after the table. Although the woundfin (Plagopterus argentissimus) and the New Mexico meadow jumping mouse (Zapus hudsonius luteus) were both listed on the Graham County Information for Planning and Conservation (IPaC) list, neither of these species nor their critical habitat is known to occur in Graham County. According to Arizona Heritage Geographic Information system (AZHGIS), the project area does not occur in or near any federally proposed or designated critical habitat within 3 miles of the project area. Figure 3-5 provides the locations of the nearest critical habitats: Designated Critical Habitat for the Chiricahua leopard frog (Lithobates chiricahuensis), the Mexican spotted owl, and the southwestern willow flycatcher (Empidonax traillii extimus), and Proposed Critical Habitat for the yellow-billed cuckoo (Coccyzus americanus). Information about each of these critical habitats was used to help determine a potential of occurrence for each of the above-mentioned species in the project area.

There is an occurrence record for the golden eagle (Aquila chrysaetos) and the Santa Catalina/Rincon-Galiuro Linkage design. The Santa Catalina-Galiuro Corridor is situated around and follows the San Pedro River and is located approximately 15 miles to the west of the project area, (Pima County Wildlife Connectivity Assessment: Detailed Linkages, August 2012). The wildlife corridor is designed mainly for mammals and native fishes. Threats to this corridor include agriculture, the highway, the railroad, and urbanization. The project area is outside this corridor, and the project actions are not considered a threat to this corridor. Though this corridor was designed through a statewide assessment, no further refinement or modeling for this corridor has occurred.

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Figure 3-5. Nearest critical habitat to project area

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Table 6. USFWS Listed Species for Graham County, Arizona Common Name Potential for Occurrence in Determination Status* Range or Habitat Requirements (Species Name) Project Area of Effect Apache trout T Found in small, cold, high-gradient Unlikely to occur. The project No (Oncorhynchu streams on substrates that consist of area is over 60 miles southwest effect. s apache) boulders, rocks, and gravel with some of the known range of this sand or silt at elevations above 5,000 feet species. amsl in mixed- conifer forests and Additionally, the project and mountain meadows. action areas do not contain Restricted to streams in the upper Salt, suitable aquatic habitat for the Gila, Blue, and Little Colorado drainages species. Thus, this species is in the White Mountains on the White unlikely to occur in the project Mountain Apache Indian Reservation and and action areas. the Apache-Sitgreaves National Forest. Populations introduced outside the historic range may still exist on the Pinaleño Mountains in the CNF and the northern portion of the Kaibab National Forest. Arizona cliff- E Found in rolling limestone hills in the Unlikely to occur. The project No rose (Purshia Sonoran desertscrub, usually on white area is over 48 miles southwest effect. (=Cowania) Tertiary limestone lakebed deposits high of the nearest known population. subintegra) in lithium, nitrates, and magnesium at Additionally, the project area is elevations between 2,500 and 4,000 feet above the elevational range of amsl. All four localities of this species are this species and does not contain in central Arizona below the Mogollon suitable substrate features. Rim and include Burro Creek drainage Thus, this species is unlikely to (Mohave County); Horseshoe Lake occur in the project and action (Maricopa County); Verde Valley (Yavapai areas. County); and the San Carlos Indian Reservation (Graham County). Chiricahua T Historically occurred in cienegas, pools, Unlikely to occur. The nearest No effect to leopard frog livestock tanks, lakes, reservoirs, known critical habitat areas for species or (Lithobates streams, and rivers at elevations of 3,281 this species, the Oak Spring and designated chiricahuensis to 8,890 feet amsl. It is now often Oak Creek Unit and the Deer critical ) restricted to springs, livestock tanks, and Creek Unit, are over 8 miles and habitat. streams in the upper portions of 10 miles southeast of the project watersheds where non- native predators area, respectively (USFWS either have yet to invade or habitats are 2012a). Additionally, there is no marginal for them. Nearby critical habitat suitable dispersal habitat information: The Deer Creek unit was between the project area and once considered a metapopulation. these critical habitats, and there However, frogs died in the 1980s, and a is no suitable habitat for this severe drought in 2002 dried up all but species in the project area. Thus, one of the waters in the unit (USFWS this species is unlikely to occur in 2012a). Although there are plans for a the project and action areas. recovery of this site, there are no funds to implement this plan (USFWS 2012a). The Oak Spring and Oak Creek Unit does not contain a robust population with drought being a threat to the

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Common Name Potential for Occurrence in Determination Status* Range or Habitat Requirements (Species Name) Project Area of Effect continuation of the species at this site (USFWS 2012a).

Desert E Found in shallow waters of desert Unlikely to occur. The project No pupfish springs, small streams, and marshes at area is over 35 miles southwest effect. (Cyprinodon elevations below 5,000 feet amsl. One of the nearest known population. macularius) natural population still occurs in Additionally, the project and Quitobaquito Spring and Quitobaquito action areas do not contain Pond in Pima County, and suitable aquatic habitat for the reintroductions have been made in species. Thus, this species is Pima, Pinal, Maricopa, Graham, Cochise, unlikely to occur in the project La Paz, and Yavapai Counties. and action areas. Gila chub E Normally found in smaller headwater Unlikely to occur. The project No (Gila streams, cienegas, and springs or area is over 20 miles north of the effect. intermedi marshes of the Gila River Basin at nearest known population. a) elevations between 2,720 and 5,420 Additionally, the project and feet amsl. action areas do not contain suitable aquatic habitat for the species. Thus, this species is unlikely to occur in the project and action areas. Gila E Occurs in small streams, springs, and Unlikely to occur. The project No topminnow cienegas at elevations below 4,500 feet area is over 12 miles southeast of effect. (Poeciliopsis amsl, primarily in shallow areas with the nearest known population. occidentalis aquatic vegetation and debris for Additionally, the project and occidentalis) cover. In Arizona, most of the action areas do not contain remaining native populations are in the suitable aquatic habitat for the Santa Cruz River system. species. Thus, this species is unlikely to occur in the project and action areas.

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Common Name Potential for Occurrence in Determination Status* Range or Habitat Requirements (Species Name) Project Area of Effect Gila trout T Considered extirpated from Arizona, Unlikely to occur. The project No (Oncorhynch until a population was introduced into area is over 80 miles southwest effect. us gilae) Dude Creek. of the nearest known population. Additionally, the project and action areas do not contain suitable aquatic habitat for the species. Thus, this species is unlikely to occur in the project and action areas. Headwater PT Found in middle to headwater Unlikely to occur. The project No chub (Gila reaches of medium-sized streams of area is over 37 miles south of the effect. nigra) the Gila River Basin at elevations nearest known population. between Additionally, the project and 3,035 and 6,651 feet amsl. The known action areas do not contain current range includes 13 streams in the suitable aquatic habitat for the Verde River Basin, Tonto Creek subspecies. Thus, this species is Basin, and San Carlos River Basin in unlikely to occur in the project Yavapai, Gila, and Graham Counties. and action areas. Lesser long- E Found in southern Arizona from the May occur. See Section nosed bat Picacho Mountains southwesterly to See Section 4.3.1.1. 3.4.3.3.1.1 (Leptonycter the Agua Dulce Mountains and is curasoae southeasterly to the Galiuro and yerbabuena Chiricahua Mountains at elevations e) between 1,600 and 11,500 feet amsl. Roosts in caves, abandoned mines, and unoccupied buildings at the base of mountains where agave, saguaro, and organ pipe cacti (Stenocereus thurberi) are present. Forages at night on nectar, pollen, and fruit of paniculate agaves and columnar cacti. The foraging radius may be 30 to 60 miles per night or more. Loach E Found in small to large perennial creeks Unlikely to occur. The project No minnow and rivers, typically in shallow, turbulent area is approximately 8 miles effect. (Tiaroga riffles with cobble substrate, swift from Aravaipa Creek. cobitis) currents, and filamentous algae at Additionally, the project and elevations below 8,000 feet amsl. Its action areas do not contain range in Arizona is limited to reaches in suitable aquatic habitat for the the East Fork of the White River (Navajo species. Thus, this species is County); Aravaipa, Deer, and Turkey unlikely to occur in the project Creeks (Graham and Pinal Counties); San and action areas. Francisco and Blue Rivers; and Eagle, Campbell Blue, and Little Blue Creeks (Greenlee County). A population was discovered in the Black River in 1996.

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Common Name Potential for Occurrence in Determination Status* Range or Habitat Requirements (Species Name) Project Area of Effect Mexican T Found in mature montane forests and Unlikely to occur. The project No effect to spotted owl woodlands and steep, shady, wooded area contains conditions that species or (Strix canyons. Can also be found in mixed- are warm, dry, with relatively designated occidentalis conifer and pine-oak vegetation types. open canopies; thus, suitable critical lucida) Generally nests in older forests of mixed habitat for this species does not habitat. conifers or ponderosa pine (Pinus occur in the project area. ponderosa)–Gambel oak (Quercus Further, the nearest known gambelii). Nests in live trees on natural designated critical habitat for platforms (e.g., dwarf mistletoe this species is BR-W-9, Galiuro [Arceuthobium spp.] brooms), snags, and Mountains Area, which is canyon walls at elevations between approximately 5 miles southeast 4,100 and 9,000 feet amsl. Forest Service of the project area (USFWS information regarding Protected Activity 2004). This is also the area Centers (PACs) in the Galiuro Mountains: where the Forest Service– There are five PACs, which are located in identified PACs are located. the higher elevations of the mountain Additionally, there are no range, associated with heavily forested occurrence records from AZHGIS areas, and four of the five PACs are (2015) within 3 miles of the within the wilderness area (Forest project area. The nearest Service 2011a). sightings are over 27 miles southwest of the project area (eBird 2015). Mexican E/NEP Found in oak and pine-juniper Unlikely to occur. The project No wolf savannahs in the foothills and in mixed- area is far from the current effect. (Canis conifer woodlands at elevations above release locations but is located lupus 4,000 feet amsl. The last known within recovery Zone 2 of the baileyi) naturally occurring experimentation population U.S. specimen was found dead in New area, which is designated for Mexico in 1970. In 1998, the first 11 wolves to be allowed to Mexican wolves from captive stock naturally disperse within and were reintroduced into the wild as an occupy, and also where wolves experimental, nonessential population may be translocated. However, on the Apache National Forest in to date, no translocations are southeastern Arizona. planned for the next 5 years and it is unlikely that a wolf would disperse from the distant current reintroduction areas (USFWS 2015b). Mount Graham E Found in montane spruce-fir and Unlikely to occur. This species is No red squirrel old- growth Douglas fir (Pseudotsuga only known to occur in the effect. (Tamiasciurus menziesii) conifer forests at Pinaleño Mountains, which are hudsonicus elevations above 8,000 feet amsl. Its over 15 miles east of the project grahamensis) range is restricted to the Pinaleño area. Additionally, suitable Mountains. conifer forests are not present in the project or action areas.

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Common Name Potential for Occurrence in Determination Status* Range or Habitat Requirements (Species Name) Project Area of Effect Northern T This species is most abundant at Unlikely to occur. The project No Mexican elevations between 3,000 and 5,000 area does not contain suitable effect. gartersnake feet amsl in densely vegetated habitat habitat for this species. (Thamnophis surrounding cienegas, streams, and Additionally, the project area is eques megalops) stock tanks, in or near water along on the very upper end of this streams in valley floors and generally species’ elevational range. There open areas but not in steep mountain are no occurrence records for canyon stream habitat (Rosen and this species within 3 miles of the Schwalbe 1988). project area (AZHGIS 2015). Considered extant in fragmented populations within the middle to upper Verde River drainage, middle to lower Tonto Creek, Cienega Creek, and a small number of isolated wetland habitats elsewhere in southeastern Arizona. Ocelot E In Arizona, this species has typically Unlikely to occur. The species is No (Leopardus been observed in subtropical thorn very rare, and there are no effect. pardalis) forest, thornscrub, and dense, brushy dense, brushy thickets or thickets at elevations below 8,000 feet riparian bottomlands in the amsl and is often found in riparian project area. Additionally, there bottomlands. The critical habitat are no occurrence records for component is probably dense cover near this species within 3 miles of the the ground and complete avoidance of project area (AZHGIS 2015). open country. In Arizona, there are two recent confirmed sightings of ocelot in the Huachuca Mountains (2011), one near Globe (2010), and unconfirmed sightings in the Chiricahua and Peloncillo Mountains. Razorback E Found in backwaters, flooded Unlikely to occur. The project No sucker bottomlands, pools, side channels, and area is over 32 miles south of the effect. (Xyrauchen other slower- moving habitats at nearest known population. texanus) elevations below 6,000 feet amsl. In Additionally, the project and Arizona, populations are restricted to action areas do not contain Lakes Mohave and Mead and the lower suitable aquatic habitat for the Colorado River below Havasu in the species. Thus, this species is Lower Basin. In the Upper Basin, small unlikely to occur in the project remnant populations are found in the and action areas. Green, Yampa, and main stem Colorado Rivers. Roundtail PT Found in cool to warm water, mid- Unlikely to occur. This species No chub (Gila elevation streams and rivers with pools occurs approximately 8 miles effect. robusta) adjacent to swifter riffles and runs. In north of the project area in Arizona, this fish occurs at elevations Aravaipa Creek. Additionally, the between 1,210 and 7,220 feet amsl in project and action areas do not two tributaries of the Little Colorado contain suitable aquatic habitat River, several tributaries of the Bill for the species. Thus, this Williams River basin, the Salt River and species is unlikely to occur in the

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Common Name Potential for Occurrence in Determination Status* Range or Habitat Requirements (Species Name) Project Area of Effect four of its tributaries, the Verde River project and action areas. and five of its tributaries, Aravaipa Creek, and Eagle Creek.

Southwestern E Found in dense riparian habitats along Unlikely to occur. There is no No effect to willow streams, rivers, and other wetlands dense riparian corridors in the species or flycatcher where cottonwood, willow, boxelder project area. However, there designated (Empidonax (Acer negundo), saltcedar (Tamarix are dense riparian corridors critical traillii extimus) spp.), Russian olive (Elaeagnus (i.e., San Pedro River and habitat. angustifolia), buttonbush Aravaipa Creek) that converge (Cephalanthus spp.), and arrowweed in the region, surrounding the (Pluchea sericea) are present. Nests are project area, making it unlikely found in thickets of trees and shrubs, this species would use the primarily those that are 13 to 23 feet project area for migration since tall, among dense, homogeneous this species is more likely to foliage. Habitat occurs at elevations move within a drainage than below 8,500 feet amsl. between drainages (USFWS 2014a). Spikedace E Found in medium-sized to large Unlikely to occur. This species No (Meda perennial streams, where it inhabits occurs in Aravaipa Creek, 8 effect. fulgida) moderate- velocity to fast waters over miles north of the project area. gravel and rubble substrates, typically Additionally, the project and at elevations below 6,000 feet amsl. In action areas do not contain Arizona, populations are found in the suitable aquatic habitat for the middle Gila, lower San Pedro, and species. Thus, this species is Verde Rivers, and Aravaipa and Eagle unlikely to occur in the project Creeks. and action areas.

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Common Name Potential for Occurrence in Determination Status* Range or Habitat Requirements (Species Name) Project Area of Effect Yellow-billed T Typically found in riparian woodland Unlikely to occur. The project No effect to cuckoo vegetation (cottonwood, willow, or area does not contain typical species or (Coccyzus saltcedar) at elevations below 6,600 habitat for this species. While proposed americanus) feet amsl. Dense understory foliage this species has been known to critical habitat. appears to be an important factor in breed in atypical habitat in nest site selection. The highest southern Arizona (e.g., higher concentrations in Arizona are along the elevation drainages without Agua Fria, San Pedro, upper Santa Cruz, typical riparian gallery forest) and Verde River drainages and Cienega (MacFarland and Horst 2015), and Sonoita Creeks. the drainages in the project area were generally dry with relatively open canopies, making it unlikely that this species would occur; no western yellow- billed cuckoos were observed during species-specific surveys conducted in 2016, and no further surveys were recommended (see Appendix A for details). The nearest known critical habitat for this species is 6 miles north of the project area, Unit 41: AZ-33 Aravaipa Creek, and 10 miles west, Unit 28: AZ- 20 Lower San Pedro, Gila Rivers (USFWS 2014b). Source: Range or habitat information is from HDMS (AGFD 2013a, 2013b), USFWS IPaC website (2015a), Arizona Rare Plant Field Guide (2001), and Corman and Wise-Gervais (2005).

*USFWS Status Definitions E = Endangered. Endangered species are those in imminent jeopardy of extinction. The ESA specifically prohibits the take of a species listed as endangered. Take is defined by the ESA as to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to engage in any such conduct. NEP = Non-Essential Experimental Population. Experimental populations of a species designated under Section 10(j) of the ESA for which the USFWS, through the best available information, believes is not essential for the continued existence of the species. Regulatory restrictions are considerably reduced under an NEP designation. PT = Proposed threatened. Proposed threatened species are proposed to be listed as threatened species. T = Threatened. Threatened species are those in imminent jeopardy of becoming endangered. The ESA prohibits the take of a species listed as threatened under Section 4d of the ESA. Take is defined by the ESA as to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to engage in any such conduct.

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3.4.3.3.1.1 Lesser Long-Nosed Bat (Leptonycteris Curasoae Yerbabuenae) Construction activities for the proposed project will not result in the loss of roosting habitat in the action area. No direct effects to the lesser long-nosed bat in the form of mortality, noise, or dust are expected as a result of drill site construction for this project because all clearing and construction activities would happen during the daytime, when this nocturnal species is not active. No effects from mortality or from dust are anticipated on this species as a result of drilling. Minor effects may occur on this species from drilling noise and light, as drilling would occur through day and night. However, these effects are anticipated to be insignificant and discountable because 1) lesser long-nosed bats only occur in the project area for a portion of the year (April–September); 2) this area contains very low densities of forage plants; 3) the severity of noise impact is expected to decrease with increasing distance from the drill; and 4) only up to two drill sites would be active at any one time. The proposed project would impact lesser long- nosed bats through the removal of forage plants (i.e., paniculate agaves) in the project area at sites Landing Zone 80 and Drill Site 03P, Landing Zone 84 and Drill Site 04P, Landing Zone 81 (Alternative) and Drill Site 06P, Landing Zone 86 (Alternative) and Drill Site 07P, Landing Zone 87 and Drill Site 09P, Landing Zone 101 (Alternative) and Drill Site 010P, Landing Zone 70 Alternative 1 and Drill Site 012P, and Landing Zone 64 and Drill Site 014P. The exact number to be removed is unknown. However, agaves occur at low densities throughout the project vicinity, and only those within the project footprint would be removed during the drill site clearing.

3.4.3.3.2 Coronado National Forest Sensitive Species According to AZHGIS (2015), there are no occurrence records for any Forest Service sensitive plant species within 3 miles of the project area; however that is likely due to the remoteness of the project area and lack of data. Of the 71 Region 3 CNF sensitive plant species listed by the Forest Service, two have been determined to have the potential to occur in the analysis area: the Catalina beardtongue (Penstemon discolor) and Arizona alumroot (Heuchera glomerulata). The analysis area is clearly beyond the known geographic or elevational range of the 69 other species or it does not contain vegetation or landscape features known to support these species, or both.

Arizona alumroot was observed in Pipeline Canyon, the ephemeral drainage that is immediately north and east of Drill Sites 09P and 014P. However, no mining activity would occur in the drainage and this species typically occurs in riparian areas; thus, no direct impacts to this species are expected. These individuals may be indirectly impacted due to minor dust. May impact individuals, but is not likely to result in a downward trend toward federal listing as threatened or endangered, or loss of viability. Although Catalina beardtongue was not observed during a floral survey of the project area, there is suitable substrate and habitat for this species in the analysis area. Because the proposed project would not involve drilling or landing helicopters on bedrock, any individuals in the vicinity would not receive direct impacts, but may be indirectly impacted due to minor dust.

The effects determination for both Arizona alumroot and Catalina beardtongue was determined to be: may impact individuals, but is not likely to result in a downward trend toward federal listing as threatened or endangered, or loss of viability. This is because plants were not located in the ground disturbance areas, dust impacts are expected to be minor and air quality mitigation measures are in place to further reduce dust.

Sixteen of the 76 CNF sensitive wildlife species have the potential to occur in the project area. However, the project area clearly does not contain vegetation or landscape features known to support these species. According to AZHGIS, there are occurrence records for one Forest Service

58 Environmental Assessment sensitive wildlife species, the lowland leopard frog, within 3 miles of the project area (AZHGIS 2015).

3.4.3.3.3 Management Indicator Species for the Coronado National Forest Eight species and one MIS group have the potential to occur or are known to occur in the project area. Table 7 displays a brief rationale regarding which species will be evaluated.

Table 7. Coronado National Forest Management Indicator Species and Occurrence in the Project Area Common Name Evaluation for Analysis Determination of Effects (Scientific Name) American May occur within the project area on National Forest The proposed project is peregrine falcon System land. Optimum habitat is generally not expected to result in (Falco peregrinus considered to be steep, sheer cliffs overlooking detectable changes in the anatum) woodlands, riparian areas, or other habitats CNF-wide population of supporting avian prey species in abundance. In American peregrine falcon Arizona, the falcon seems to be breeding in less or to result in a loss of optimal habitat, either small broken cliffs in occupied habitat for this ponderosa pine forest or large, sheer cliffs in very species. xeric areas. The presence of an open expanse is critical. Observed within 10 miles of the project area (eBird 2015); aeries are possible where cliffs occur. Black bear (Ursus May occur within the project area on National Forest It is expected that this americanus) System land; black bears are habitat generalists. In project will impact far less Arizona, black bears typically occur in chaparral pine than 1% (0.0002%) of the forests and aspen-fir pine forests at about 4,000 to suitable habitat present for 10,000 feet amsl (AGFD 2009a). this species across the CNF; thus, the proposed project is not expected to result in detectable changes in the CNF-wide population of black bear. Desert bighorn May occur within the project area on National Forest It is expected that this sheep (Ovis System land. Desert bighorn sheep are known to project will impact far less canadensis occur in the Galiuro Mountains, and populations both than 1% (0.0017%) of the deserti) north and south of the project area have been suitable habitat present for augmented (AGFD 2013c). this species across the CNF; thus, the proposed project is not expected to result in detectable changes in the CNF-wide population of desert bighorn. Gould’s turkey May occur in the project area on National Forest The proposed project is (Meleagris System land. Gould’s turkeys were historically found not expected to result in gallopavo in southern Arizona within forested areas containing detectable changes in the mexicana) evergreen oak woodlands, Madrean pine-oak forests, CNF-wide population of and sycamore-dominated drainages. Populations Gould’s turkey or to result have been reestablished in the Chiricahua, Santa in a loss of occupied Catalina, Huachuca, Peloncillo, Santa Rita, and habitat for this species. Pinaleño Mountains (Heffelfinger et al. 2000), and individuals have been present nearby (eBird 2015).

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Common Name Evaluation for Analysis Determination of Effects (Scientific Name) Montezuma Known to occur within the project area on National It is expected that this (Mearns’) quail Forest System land. This species occurs in project will impact far less (Cyrtonyx evergreen oak-pine woodlands and adjacent than 1% (0.0005%) of the montezumae grasslands in areas in which native grasses grow suitable habitat present for mearnsi) medium height to tall and provide dense cover this species across the (Johnson 2014). This species was observed during CNF; thus, the proposed the field visit. project is not expected to result in detectable changes in the CNF-wide population of Montezuma quail. Northern This species may occur in the project area in It is expected that this beardless- National Forest System land because northern project will impact less tyrannulet beardless-tyrannulet inhabits relatively open riparian than 1% (0.09%) of the (Camptostoma woodland and heavily wooded dry washes in suitable habitat present for imberbe) southeastern Arizona. The nearest occurrence this species across the record for this species is Aravaipa Canyon (eBird CNF; thus, the proposed 2015). project is not expected to result in detectable changes in the CNF-wide population of northern beardless tyrannulet. Primary and May occur within the project area on National Forest The proposed project is secondary cavity System land; suitable habitat (cavities in trees) is not expected to result in nesters available. Numerous owls, woodpeckers, and detectable changes in the flycatchers known to nest in cavities may be present CNF-wide population of in the project area on National Forest System land. any cavity-nesting species Many of these species have been documented near or to result in a loss of the project area (eBird 2015). occupied habitat for these species. Sulphur-bellied May occur within the project area on National Forest The proposed project is flycatcher System land because this species typically occurs in not expected to result in (Myiodynastes riparian canyons in association with sycamores for detectable changes in the luteiventris) nest trees and walnuts (Juglans major) for nest CNF-wide population of material or pine-oak communities. sulphur-bellied flycatcher or to result in a loss of occupied habitat for this species. White-tailed deer May occur within the project area on National Forest It is expected that this (Odocoileus System land; widespread suitable habitat (oak- project will impact far less virginianus grassland/chaparral) is present in the project area than 1% (0.00008%) of couesi) (AGFD 2009b). the suitable habitat present for this species across the CNF; thus, the proposed project is not expected to result in detectable changes in the CNF-wide population of white-tailed deer. Unless otherwise indicated, range or habitat information is from AGFD (2013b), Brennan (2008), Brennan and Holycross (2006), CNF Forest Plan (Forest Service 1986), CNF MIS Population Status and Trends (Forest Service 2011b), Corman and Wise-Gervais (2005), and Hoffmeister (1986).

3.4.3.3.3.1 American Peregrine Falcon The American peregrine falcon is included in the Threatened and Endangered Species MIS group for the CNF (USFS 1986, 2011b). The population trend for this species on the CNF is apparently upward. This falcon breeds in Arizona wherever sufficient prey is available near cliffs, such as

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those associated with the Mogollon Rim, Grand Canyon, and Colorado Plateau. Optimum nesting habitat is generally considered to be steep, sheer cliffs overlooking woodlands, riparian areas, or other areas that support an abundance of avian prey species; the presence of an open expanse is critical (Glinski 1998). However, these falcons have been observed breeding in less optimal habitats (small broken cliffs in ponderosa pine forest or large, sheer cliffs in very xeric areas) as human development expands in Arizona (AGFD 2013b). In Arizona, these falcons return to breeding areas from mid-February to mid-March, although year-round resident birds are not uncommon. Nesting sites (also called aeries) usually consist of a shallow depression scraped into a ledge on the side of a cliff. Peregrine falcons feed almost exclusively on birds, but bats are also taken. In Arizona, these birds use areas of Sonoran, Mohave, and Great Basin desertscrub up through areas of Rocky Mountain and Madrean montane conifer forest from around 400 feet amsl along the lower Colorado River to 9,000 feet amsl along the Mogollon Rim. Peregrine falcons are capable of rapid, long-distance flight, and it is unlikely that the entire forest, including the project area, could provide suitable hunting habitat. For the purposes of this analysis, occupied habitat is defined as a combination of suitable nesting habitat and adjacent hunting areas. No specific monitoring method is identified in the Forest Plan for this species other than “measurements of appropriate habitat components” (Forest Service 1986:94). Although the Forest Plan does not specifically require monitoring for this species, known aeries have been identified and monitored periodically for many years by Forest Service personnel. Twenty-nine peregrine falcon territories have been identified on the CNF, and 14 of these have been identified for continued long-term monitoring as a condition of delisting the species (Abbate 2006; USFWS 2003b). In 2012, eight of the 12 monitored sites on the CNF were occupied (Abbate 2012). No forest-wide trends are discernible. Nationwide, the peregrine falcon population is considered secure and has been increasing for the past 30 years (USFWS 2003b). Forest-wide habitats are considered secure and sufficient to allow the species to be well distributed across the CNF (Forest Service 2011b). There are no known active aeries in the project area, and optimal nesting habitat is limited. However, peregrine falcons have been documented as occurring within 3 miles of the project area.

The Forest Plan gives no data for acres of occupied habitat on the CNF (USFS 1986), nor does it identify desired habitat conditions for this species. The project is not likely to cause a change in the local American peregrine falcon population. The project area is small and thus likely to result in only a small loss of foraging habitat for this species. Noise impacts to this species will decrease with increasing distance to the project area, and this species is highly mobile. Past, present, and reasonably foreseeable future projects or actions that have affected or will affect resources on the CNF include historical grazing activities, current and historical mining, natural fires and wildfire suppression, invasive plants, recreation, and water diversions.

3.4.3.3.3.2 Black Bear Black bears are included in the Riparian Species, Species Needing Diversity, and Game Species MIS groups in the Forest Plan (Forest Service 1986, 2011b). A current forest-wide population estimate is not available. However, the range of the species on the CNF has not changed significantly since 1986, and the population trend for this species on the forest appears to be stable. Black bears are wide-ranging habitat generalists that prefer areas of dense cover and high vegetative diversity. They will use riparian areas for cover and as travel corridors. In Arizona, black bears are found in a variety of habitats, including subalpine and montane conifer forests, riparian forests, evergreen woodlands, and chaparral (AGFD 2009a). Individuals establish home ranges but are capable of moving great distances (100 miles) in response to climatic conditions or food availability. They often return long distances after being moved.

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Most Arizona black bears hibernate from November through March, during which time they reduce their body temperature, heart rate, and metabolic function while still remaining somewhat conscious in the den (AGFD 2009a). They are normally solitary animals, the exception being family groups (mother and cubs), breeding pairs, and congregations at feeding sites. Bears will establish and defend territories, a behavior that tends to limit population densities in any given area. They feed on a variety of items, including berries, acorns, grass, insects, mesquite beans, and carrion. Grass has been shown to be a very important component of the diet in the spring. Prickly-pear cactus fruits are seasonally important in some years. In general, the diet consists of approximately 90% plant material and only 10% animal matter, primarily in the form of insects. They can be effective predators and have been known to take livestock, especially calves, on occasion.

Black bears are both wide-ranging and secretive and thus are difficult to census with any degree of accuracy (Forest Service 2011b). As a result, no attempts are made to survey for bears on the CNF. Across the forest, habitat is of sufficient quality and abundance to allow the species to be well distributed across federal lands. Historical habitats remain occupied, although the population fluctuates within occupied habitats based on the availability of forage. No population trends can be detected, although it is generally believed that poor mast crops over the past several years have led to a decrease in the carrying capacity for bears on the CNF. The project area falls within AGFD’s Game Management Unit (GMU) 32, which includes all of the Galiuro Mountains (AGFD 2015).

It is estimated that this species occupies 641,113 acres within the CNF (Forest Service 1986, 2011b), and there is a total 1.2 acres of habitat within the project area. Therefore, the proposed project has the potential to impact far less than 1% (0.0002%) of this species’ occupied habitat across the CNF. The project is not likely to cause a change in the local black bear population. The project may result in a small loss of foraging habitat for this species. The noise resulting from the project would decrease with increasing distance from the project area, so while noise from the project may impact this species’ activity patterns or the activity patterns of its prey, black bears are highly mobile and would be able to shift their use to less affected areas. Thus, the project is anticipated to result in minor direct impacts to black bears and its habitat. Past, present, and reasonably foreseeable future projects or actions that have affected or will affect resources on the CNF include historical grazing activities, current and historical mining, natural fires and wildfire suppression, invasive plants, recreation, and water diversions.

3.4.3.3.3.3 Desert Bighorn Sheep Desert bighorn are included in the Game Species and Threatened and Endangered MIS groups in the Forest Plan (Forest Service 2011b). A current forest-wide population estimate is not available, but the population occurring on the Pusch Ridge Wilderness Area declined and was eventually extirpated in the later 1990s. However, this species is currently being reintroduced to the Santa Catalina Mountains (AGFD 2014). Desert bighorn are also being reintroduced to other areas in and near the CNF (AGFD 2013c).

Desert bighorn occur in precipitous, rocky desert ranges in Arizona, where they often use areas of broken rock and gullies, typically in jojoba (Simmondsia chinensis) communities within areas where galleta grass (Hilaria sp.) is the dominant species at elevations between 3,000 and 4,000 feet amsl (Hoffmeister 1986), though they may occur up to 4,500 feet above mean sea level (amsl) (AGFD 2009c). Desert bighorn sheep have been released in Aravaipa Canyon approximately 8 miles north of the project area and on BLM and Nature Conservancy land

62 Environmental Assessment approximately 20 miles south of the project area off of CNF lands, and in an undisclosed location within the Galiuro Mountains (AGFD 2013c).

The Forest Plan identified 72,458 acres of occupied habitat in (USFS 1986, 2011b), and there is a total of 1.2 acres of habitat within the project area. Therefore, the proposed project has the potential to impact far less than 1% (0.0017%) of this species’ occupied habitat across the CNF. The project is not likely to cause a change in the local desert bighorn population, especially given that the project area is just outside the elevational range of this species. Thus, most of the project area is likely to be unoccupied by this species. The project may result in a small loss of foraging habitat for this species. The noise resulting from the project would decrease with increasing distance from the project area, so while noise from the project may impact this species’ activity patterns, desert bighorns are highly mobile and would be able to shift their use to less affected areas. Thus, the project is anticipated to result in minor direct impacts to desert bighorns and their habitat. Past, present, and reasonably foreseeable future projects or actions that have affected or will affect resources on the CNF include historical grazing activities, current and historical mining, natural fires and wildfire suppression, invasive plants, recreation, and water diversions.

3.4.3.3.3.4 Gould’s Turkey This MIS is also a Forest Sensitive species. It is included in the Threatened and Endangered Species MIS group and was selected as such within the Forest Plan because it inhabits oak- grassland-riparian associations with trees of sufficient size for roosting, free water, and herbaceous material and insects during the breeding season (USFS 1986, 2011b). The population trend for this species on the CNF is apparently upward. Turkeys were observed within the project vicinity; it is unknown whether they were Merriam’s turkeys or Gould’s turkeys.

Gould’s turkey is distributed throughout northern Mexico and into the southwestern United States. In Mexico, populations appear to be stable and well distributed (Heffelfinger et al. 2000). However, in Arizona, the species occurs only in isolated pockets in the Chiricahua, Galiuro, Santa Catalina, Huachuca, Peloncillo, Santa Rita, and Pinaleño Mountains because of the reestablishment of populations in those ranges. The native turkey population on the CNF is believed to have been extirpated during the early 1900s (with the possible exception of a small population within the Peloncillo Mountains). While no taxonomic records exist, it is likely that these birds were the Gould’s subspecies (M. g. mexicana), based on the proximity to and connectivity between existing Gould’s turkey habitats in northern Mexico and mountain ranges on the CNF. A small but apparently stable population of Gould’s turkeys has persisted in the Peloncillo, Animas, and San Luis Mountains in southeastern New Mexico.

In the 1980s, agency efforts focused on the establishment of the Gould’s subspecies into suitable habitats on the CNF throughout southeastern Arizona. Gould’s turkey populations on the CNF have increased since 1986, and increases since 1990 have been the result of natural reproduction and ongoing transplant efforts. Habitat on the CNF is of sufficient quality and distribution to allow the population to increase. Population trend data are not available for the period from 1997 to 2012 for this species in Arizona (Sauer et al. 2014), but the population trend for this species on the CNF appears to be upward due to recent release efforts (Forest Service 2011b).

The Forest Plan gives no data for acres of occupied habitat on the CNF (USFS 1986), and it does not identify desired habitat conditions for this species. The project is not likely to cause a change in the local Gould’s turkey population. The project area does not contain free water; thus, it is expected that any turkeys present would use this area very infrequently for foraging. The project is likely to result in a very minor loss of foraging habitat for this species, and nesting areas and

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reproductive success will not be impacted from the operation of mining on the project area. The project is anticipated to result in minor direct impacts—and is anticipated to result in only minor, short-term, indirect impacts—to Gould’s turkeys and its habitat. Past, present, and reasonably foreseeable future projects or actions that have affected or will affect resources on the CNF include historical grazing activities, current and historical mining, natural fires and wildfire suppression, invasive plants, recreation, and water diversions.

3.4.3.3.3.5 Montezuma Quail Montezuma quail are an indicator for the Species Needing Herbaceous Cover, Game Species, and Special Interest Species MIS groups in the Forest Plan. Montezuma quail are the largest and most secretive of Arizona’s quail species (Johnson 2014). It forms fall and winter coveys that are likely to remain in the same general area where they were raised. Montezuma quail prefer oak woodlands and oak savannas in the southeastern portions of the state, where grass cover is abundant. The maintenance of grass height over 6 inches is necessary to provide sufficient cover for the birds to hide from predators. Although Montezuma quail populations are considered to be highly correlated with the amount and timing of summer precipitation, high levels of grazing or other activities that decrease herbaceous production, especially during the growing season, have also been shown to have negative impacts to the Montezuma quail as a result of the decrease in cover (Brown 1982).

Montezuma quail nest only after the monsoon and often postpone breeding until after the summer solstice, when the days start getting shorter (Johnson 2014). They generally demonstrate high hatching success, and their highly fluctuating numbers are determined largely by how many birds survive the winter, as this species typically experiences relatively high winter mortality. Since 1979, harvested quail numbers and hunter interest have decreased, causing some hunters and wildlife managers to wonder whether a long-term decline in quail numbers may have occurred.

Effective techniques for measuring Montezuma quail abundance are lacking, and unlike Gambel’s, scaled, and masked bobwhite quail, Montezuma quail cannot be reliably censused using breeding season call counts (USFS 2011b). AGFD has collected harvest data from quail hunters in selected canyons since approximately 1980, and since 1987, harvest data have been collected annually by AGFD via a small-game mail questionnaire. Harvests have fluctuated widely, with no discernible long-term trend. According to the Breeding Bird Survey, population trend data are not available for this species (Sauer et al. 2014); however, the population trend for this species on the CNF appears to be stable (USFS 2011b).

This species was observed during the biological survey in November 2015. It is estimated that this species occupies 225,410 acres within the CNF (USFS 1986). There is a total of approximately 1.2 acres of habitat in the project area on National Forest System land, although some of this area is unlikely to be suitable habitat for this species. Therefore, the proposed project has the potential to impact far less than 1% (0.0002%) of this species’ occupied habitat across the CNF. . Thus, the project is anticipated to result in minor direct impacts to Montezuma quail and its habitat. Past, present, and reasonably foreseeable future projects or actions that have affected or will affect resources on the CNF include historical grazing activities, current and historical mining, natural fires and wildfire suppression, invasive plants, recreation, and water diversions.

3.4.3.3.3.6 Northern Beardless Tyrannulet This species is included in the Riparian Species, Species Needing Dense Canopy, Special Interest Species, and Threatened and Endangered Species MIS groups for the CNF. Northern beardless-

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tyrannulet inhabits relatively open riparian woodland and heavily wooded dry washes in southeastern Arizona (Corman and Wise-Gervais 2005). During the research period for the Arizona Breeding Bird Atlas, they were reported primarily from lowland riparian woodlands with Fremont cottonwood (Populus fremontii) and Goodding’s willow (Salix gooddingii) stands, but they also were found fairly regularly in intermittent foothill drainages and dry washes with stands of tall netleaf hackberry (Celtis laevigata var. reticulata). Most tyrannulets are migratory and return to breeding areas in early to mid-March, with the earliest nest building reported on April 12. Peak nesting for this species is early May through late June at elevations from 1,920 to 4,600 feet amsl. They were found nesting along the San Pedro River and its tributaries, Arivaca Creek, Sonoita Creek, upper Santa Cruz River, and in wooded foothill drainages of the Baboquivari, Atascosa, Santa Rita, and Santa Catalina Mountains.

On a global scale and state scale, the northern beardless-tyrannulet is considered demonstrably secure, with more than 100 occurrences, although it could be considered quite rare in some areas (USFS 2011b). Population trend data are not displayed for this species in the North American Breeding Bird Survey database (Sauer et al. 2014). The general breeding distribution has changed little since the 1990s (Corman and Wise-Gervais 2005). There are not sufficient data to determine population trends on the CNF, but optimal habitats are very limited, primarily because much of the forest is above the elevational range of the species (USFS 2011b).

It is estimated that this species occupies 1,270 acres within the CNF (Forest Service 1986), and there are 1.2 acres of habitat that would be impacted on Forest Service land. The nearest occurrence record for this species is Aravaipa Canyon (eBird 2015). The project is not likely to cause a change in the local northern beardless tyrannulet population because only some portions of the project area even contain suitable habitat; the remainder of the project area is likely too open. The project may to result in a very minor loss of foraging or breeding habitat for this species, and nesting areas and reproductive success may be impacted from the operation of mining on the project area. The project is anticipated to result in minor direct impacts—and is anticipated to result in only minor, short-term, indirect impacts—to northern beardless tyrannulet and its habitat. Past, present, and reasonably foreseeable future projects or actions that have affected or will affect resources on the CNF include historical grazing activities, current and historical mining, natural fires and wildfire suppression, invasive plants, recreation, and water diversions.

3.4.3.3.3.7 Sulphur-bellied Flycatcher This species is included in the Cavity Nesters, Riparian Species, Species Needing Diversity, and Special Interest Species MIS groups in the Forest Plan. Sulphur-bellied flycatchers are primarily tropical birds that nest from southeastern Arizona to Costa Rica (Corman and Wise-Gervais2005). In Arizona, they typically arrive in mid-May and depart by mid-September. They are generally confined to drainages containing tall, broadleaf woodlands but will travel up adjacent dry drainages or ascent slopes to forage in pines and oaks. Sulphur-bellied flycatchers are secondary cavity nesters, requiring flicker-sized cavities primarily in sycamores between 20 and 50 feet above the ground (USFS 2011b).

While the sulphur-bellied flycatcher is considered demonstrably secure globally, in Arizona it is locally common but within a restricted range (USFS 2011b). There are no organized surveys for sulphur-bellied flycatchers on the CNF, but as they are highly sought after by birders, the status of the bird is known anecdotally every year on the CNF. The population appears stable within the CNF, though with small sample sizes it is difficult to detect population trends (USFS 2011b).

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These birds are known to occur within the Galiuro Mountains, though they are infrequently observed (Corman and Wise-Gervais 2005).

There are no data on the acres of currently occupied habitat for this species on the CNF (USFS 2011b). The project is not likely to cause a change in the local sulphur-bellied flycatcher population because only some portions of the project area even contain suitable habitat; the remainder of the project area is likely too open and does not contain riparian-associated vegetation. Further, the project area is small (1.2 acres), and this species is only infrequently observed in the Galiuro Mountains.

The project may to result in a very minor loss of foraging or breeding habitat for this species, and nesting areas and reproductive success may be impacted from the operation of mining on the project area. Past, present, and reasonably foreseeable future projects or actions that have affected or will affect resources on the CNF include historical grazing activities, current and historical mining, natural fires and wildfire suppression, invasive plants, recreation, and water diversions.

3.4.3.3.3.8 Primary and Secondary Cavity Nesters Primary and secondary cavity nesters may potentially occupy burned trees in and around the project area. In general, cavity nesters require large, older–age class trees and snags (and columnar cacti where they occur). Activities that affect cavity nesters are those that change the rate of regeneration of cavity-forming trees. Numerous owls, woodpeckers, flycatchers, and other birds known to nest in cavities may be present in the project area on National Forest System land.

No monitoring of cavity-nesting birds as a group occurs on the CNF (USFS 2011b). North American Breeding Bird Survey information for the Cavity Nester group shows slight but statistically insignificant declines for ash-throated flycatcher (Myiarchus cinerascens) and Bewick’s wren (Thryomanes bewickii); a slight, but statistically insignificant increase for the ladder-backed woodpecker (Dryobates scalaris); and significant downward trends for northern flicker (Colaptes auratus) and American kestrel (Falco sparverius). For all other primary or secondary cavity nesters, either trends were not significant or no data were available. There has also been a substantial, but unquantified, increase noted in suitable habitats (snags) for high- elevation cavity-nesters across the CNF.

There are no data on the acres of currently occupied habitat for this group on the CNF (USFS 1986). The proposed project is likely to result in a small loss of foraging habitat for this species, and nesting areas and reproductive success may be impacted from noise. However, the noise impacts are expected to become less severe with increasing distance to the project area. Past, present, and reasonably foreseeable future projects or actions that have affected or will affect resources on the CNF include historical grazing activities, current and historical mining, natural fires and wildfire suppression, invasive plants, recreation, and water diversions.

3.4.3.3.3.9 White-tailed Deer White-tailed deer are included in the Species Needing Diversity, Species Needing Herbaceous Cover and Game Species MIS groups in the Forest Plan (USFS 1986, 2011b). The population trend for this species on the CNF is apparently downward. White-tailed deer are most common in the state’s southeastern mountains. They require areas of predictable summer precipitation and are most abundant in oak woodlands and chaparral-covered hillsides with oaks and pines (AGFD 2009b). While more resilient than mule deer (Odocoileus hemionus) to hunting pressure, white- tailed deer are less drought tolerant. In Arizona’s southern mountain ranges, they are generally found at higher elevations and in rougher country than mule deer. White-tailed deer will use a

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variety of habitats but prefer areas of thicker cover with freestanding water; thus, they likely benefit from the current presence of stock tanks and springs in the project area. Large-scale vegetation removal prior to and during the fawning period reduces hiding cover and may reduce fawn survival and recruitment (Ockenfels et al. 1991). Unlike mule deer, white-tailed deer rarely form herds, and most observations are of fewer than six animals (AGFD 2009b). Shrubs constitute the majority of the diet, although forbs are seasonally important. Prescribed burns can open up chaparral and dense stands of pinyon-juniper, creating favorable conditions for white- tailed deer (USFS 1986). The project area falls within AGFD’s GMU 32 (AGFD 2015).

It is estimated that this species occupies 1,430,071 acres within the CNF (Forest Service 1986, 2011b), and there is a total of 1.2 acres of habitat within the project area. Therefore, the proposed project has the potential to impact far less than 1% of this species’ occupied habitat across the CNF. The project is not likely to cause a change in the local white-tailed deer population. The project is not likely to result in a loss of foraging habitat for this species, and fawning grounds and reproductive success will not be impacted. The noise impacts from the operation of this mining project may cause additional impacts to this species, including avoidance of the area or shifting of activity patterns. Past, present, and reasonably foreseeable future projects or actions that have affected or will affect resources on the CNF include historical grazing activities, current and historical mining, natural fires and wildfire suppression, invasive plants, recreation, and water diversions.

3.4.3.3.4 Migratory Birds and Eagles

3.4.3.3.4.1 Birds of Conservation Concern Forty-one BCC species are listed for Graham County by the USFWS: Arizona woodpecker (Picoides arizonae), bald eagle (Haliaeetus leucocephalus), Bell’s vireo (Vireo bellii), Bendire’s thrasher (Toxostoma bendirei), black-chinned sparrow (Spizella atrogularis), black-throated gray warbler (Dendroica nigrescens), blue-throated hummingbird (Lampornis clemenciae), Brewer’s sparrow (Spizella breweri), burrowing owl (Athene cunicularia), canyon towhee (Pipilo fuscus), Cassin’s sparrow (Aimophila cassinii), chestnut-collared longspur (Calcarius ornatus), common black-hawk (Buteogallus anthracinus), elegant trogon (Trogon elegans), elf owl (Micrathene whitneyi), flammulated owl (Otus flammeolus), fox sparrow (Passerella iliaca), Gila woodpecker (Melanerpes uropygialis), gilded flicker (Colaptes chrysoides), golden eagle, Grace’s warbler (Dendroica graciae), gray vireo (Vireo vicinior), lark bunting (Calamospiza melanocorys), Lewis’s woodpecker (Melanerpes lewis), loggerhead shrike (Lanius ludovicianus), Lucy’s warbler (Vermivora luciae), McCown’s longspur (Calcarius mccownii), mountain plover (Charadrius montanus), northern beardless tyrannulet, olive warbler (Peucedramus taeniatus), olive-sided flycatcher (Contopus cooperi), peregrine falcon, pinyon jay (Gymnorhinus cyanocephalus), phainopepla (Phainopepla nitens), prairie falcon (Falco mexicanus), red-faced warbler (Cardellina rubrifrons), short-eared owl (Asio flammeus), Sonoran yellow warbler (Dendroica petechial sonorana), Sprague’s pipit (Anthus spragueii), Swainson’s hawk (Buteo swainsoni), and Williamson’s sapsucker (Sphyrapicus thyroideus).

Although these BCC do not receive protection under the ESA, they do receive protection under the MBTA and BGEPA. BCC have been identified as species, subspecies, or populations that are likely to be listed in the future if conservation measures are not taken (USFWS 2015a). Several of these BCC species were observed in the project area, including Arizona woodpecker, golden eagle, black-chinned sparrow, and northern beardless tyrannulet. Additionally, habitat components for several species are present; thus, they could potentially occur within the project area.

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3.4.3.3.5 Non-native Wildlife Species Field surveys were conducted in November 2015 that covered the entire project area. These studies were conducted that focused on documenting suitable habitat for wildlife and sensitive biological resources. The wildlife and sensitive biological resources present or potentially present were identified through a literature review identified in the table above. No non-native plant or wildlife species surveys were conducted. Wildlife species detected during field surveys by sight, calls, tracks, scat, or other sign were recorded.

In addition to species actually observed, expected wildlife usage of the area was determined according to known habitat preferences of wildlife species and knowledge of their relative distributions in the area.The main focus of the faunal species surveys was to identify habitat suitability for special-status wildlife within the project area, in order to predict those species with a higher probability of occurrence in the project area. The fact that a species was not detected does not mean that the species does not occur in the project area. Surveys for wildlife species have the inherent limitation that absence is difficult or impossible to determine; this is especially true for wildlife species with a nocturnal pattern of activity or that are otherwise difficult to detect.

No non-native species were observed in the project area during the field surveys; however, brown-headed cowbirds (Molothrus ater), European starlings (Sturnus vulgaris), and European house sparrows (Passer domesticus) have been documented in the project vicinity (eBird 2015). Surveys were likely not sufficient to detect all non-native animals or pathogens present in the project area. However, the risk associated with unknown/undetected invasive animals is considered low. This is mainly because the small disturbance size of the project does not create a large human disturbance that could attract these species.

The risk of introduction, establishment, and/or spread of invasive animals is low for this proposed project, since most of the invasive animal species are associated with aquatic environments (see Table 7), and this project does not include disturbance within aquatic environments or use of water sources that could contain these aquatic species. Additionally, the proposed action would not create favorable conditions (i.e., anthropogenic effects, such as habitation, recreation, agriculture, ranching, etc.) that would increase the spread of the other invasive animal species in Table 7 that are not aquatic species (i.e., bird species).

3.4.3.4 Cumulative Effects Cumulative effects for threatened and endangered species include the effects of future State, tribal, local or private actions that are reasonably certain to occur in the action area. Future Federal actions that are unrelated to the Proposed Action are not considered in this section because they require separate consultation pursuant to Section 7 of the Act. [50 CFR §402.02]. This definition of cumulative effects applies only to Section 7 analyses and should not be confused with the broader use of this term in the NEPA or other environmental laws.

The Coronado National Forest manages the lands within the action area, thus, most activities that could potentially affect listed species and designated critical habitats are Federal activities that are subject to Section 7 consultation and therefore not considered in this cumulative effects analysis. Examples of these kinds of actions include: management of Forest Service grazing permits, fuels reduction activities, travel management, and mineral activities.

Activities in the vicinity of the project area that are reasonably certain to occur but are not subject to Section 7 analysis include illegal activities and actions on private lands. Examples of illegal

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activities include: inappropriate use of off-highway vehicles, poaching, and illegal woodcutting. Illegal activities are difficult to predict and are assumed will occur indefinitely and uniformly dispersed throughout the vicinity of the project area. Because of the increase in the number of people on the landscape, the project may temporally decrease the levels of illegal activity in the project area.

Illegal activities could potentially affect many of the listed species and designated critical habitat through habitat destruction, introduction of non-native invasive species, increased noise levels, and an increase in the human presence in the area. Future illegal activities are anticipated to occur at very low levels and are not expected to significantly contribute to the effects to listed species and designated critical habitat.

Activities occurring on private lands may include residential development, farming/ranching, road construction and maintenance, and mineral exploration. These activities could potentially affect many of the listed species and designated critical habitat through habitat destruction, introduction of non-native invasive species, increased noise levels, and an increase in the human presence in the area. No new major developments of private lands are expected to occur within the immediate vicinity of the project or among the larger blocks of private land; therefore, future activities on private lands are not expected to significantly contribute to the effects to listed species and designated critical habitat.

Within the NEPA framework, cumulative effects are defined as “The incremental impact of an action, when added to other past, present, and reasonably foreseeable future actions”. For the purposes of this analysis, the cumulative effects boundary for cumulative effects to biological resources is the Gailuro Ecological Management Area (EMA) during the 5 year proposed project. Reasonably foreseeable future actions in the project area that affect biological resources include the Galiuro Firescape Project, which will provide long-term benefits to terrestrial and aquatic habitats by improving forest health and reducing risks of catastrophic wildfire. Additionally, the Travel Management Project (changes to the Safford Ranger District motorized travel system), will benefit wildlife and plants by reducing overall disturbance from vehicle traffic and improve aquatic habitats by decommissioning roads deemed unnecessary and/or causing resource damage.

Because there are no past or present actions that negatively impact wildlife and habitat, plants and future actions will provide benefits, no cumulative effects from this project are expected.

The cumulative effects of the Galiuro Drilling Project are not expected to change any of the determinations made on any listed species or designated critical habitats in this document. Furthermore, for those species that that had No Effect determinations and were not analyzed in detail, the cumulative effects of this project are not expected to change these determinations either.

3.4.3.4.1 Federally Listed Species

3.4.3.4.1.1 Lesser Long-Nosed Bat (Leptonycteris Curasoae Yerbabuenae) Cumulative effects include the effects of future state, tribal, local, or private actions that are reasonably certain to occur in the action area considered in this BAE. Future federal actions that are unrelated to the Proposed Action are not considered in this section because they require separate consultation pursuant to Section 7 of the ESA. The majority of the lands within the action area are federal lands within the project area; therefore, most of the activities that could potentially affect lesser long-nosed bats within the action area are likely federal activities subject

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to additional Section 7 consultation under the ESA. Exceptions could include recreation without a federal nexus and cross-border activities such as the following: human traffic, deposition of trash, new trails from human traffic, increased fire risk from human traffic, and water depletion and contamination. Because the proposed project is considered to be a low risk to the lesser long- nosed bat and its habitat, this project is not expected to add to the reasonably foreseeable impacts to this species on the CNF. 3.5 Scenic Values The 1.7 million acre CNF is comprised of 12 “sky island” mountain ranges. CNF visitors have opportunities to sightsee along forest roads, camp in developed and back-country camping areas, hike, rock climb, mountain bike, and enjoy extraordinarily high quality scenery in predominantly undeveloped landscapes. The results of a the 2012 National Visitor Use Monitoring survey show that 60 percent of visitors to the CNF participate in viewing natural features (scenery) and that this activity was the second most popular primary activity after hiking and walking.

The scenic landscapes of the Safford Ranger District are important to local residents and forest visitors, and the proposed Galiuro Drilling project would impact scenic quality. This report provides a brief overview of scenic resources in the project area, the impacts of the proposed project, and recommended mitigation measures.

The Visual Resources analysis addresses existing visual resources and the potential impacts to Visual Quality Objectives (VQO) based on visibility of the Proposed Action. A description of the regulatory framework, existing conditions (affected visual resource environment), and potential effects (environmental consequences) to visual resources is included in this analysis.

3.5.1 Regulatory Framework Visual Resource Management System and Scenery Management System

In recent years, there has been conflicting direction regarding the assessment of scenic resources on the CNF. The Coronado National Forest Plan (CNF, 1986) refers to Visual Quality Objectives (VQO) maps created under the 1974 Visual Resource Management System (VRMS), yet since the mid-1990s National Forests have been directed to use the improved Scenery Management System (SMS). In 2001, SMS mapping of Scenic Classes, which show the relative importance of scenic resources on the CNF, was completed. As soon as the forest began using SMS in environmental analyses, some problems became apparent because the new system is different than what is in the forest plan. This will be resolved when SMS is incorporated into the revised forest plan. In 2012, the CNF established draft recommended Scenic Integrity Objectives (SIOs), which will replace VQOs, and these have been made available for public review along with the revised plan and draft environmental impact statement.

Although on-the-ground maps for the two systems are very different, the components of both systems are similar and the analysis (affected environment, environmental consequences, and cumulative effects) for the proposed project yields largely the same results.

To be consistent with the current Forest Plan, this report provides an analysis of the proposed project using the VRMS and VQOs. However, direction from the draft revised Forest Plan (and SMS) is also briefly covered where it provides supplemental information.

The Coronado National Forest Plan

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Direction for managing scenery on the CNF is found in the Forest Plan. Current direction in the Forest Plan includes the following Forest-wide Standards and Guidelines for Visual Resource Management (page 28):

• Maintain and protect the visual integrity of the landscape.

• Rehabilitate or enhance the existing visual quality in the process of accomplishing other resource management practices.

3.5.2 Existing Conditions Characteristic Landscape

The landscape character in the proposed project area is a mosaic of mostly oak/juniper/pinyon, with smaller areas of pine-oak, desert shrub mix, chaparral, and grass mix on steep slopes (over 30%). Due to the remoteness of the area, there are few modifications to the valued landscape character. Existing scenic integrity is excellent.

Eleven of the proposed drilling sites lie within Management Area (MA) 1. One is located in MA 4. Scenic quality standards and guidelines for MA 1 require that "Visual quality objectives will be met" (see Management Emphasis and Intensity on page 47). Scenic quality standards and guidelines for MA 4 require that “Visual quality objectives will be met or exceeded” (see Management Emphasis and Intensity on page 62).

VQOs for every acre of the CNF were established in the early 1980s and incorporated into the Forest Plan. VQOs are based on two components:

1. Variety Class: A measure of the visual variety or diversity of landscape character. The three variety classes are A (Distinctive), B (Common), and C (Minimal).

2. Sensitivity Levels (Concern Levels in SMS) and Distance Zones: Sensitivity Levels are a measure of the viewer interest in scenic qualities of a landscape. The three levels are 1 (Highest), 2 (Average), and 3 (Lowest). Distance Zones include Foreground (up to 1/2 mile), Middleground (1/2 mile to 5 miles), and Background (over 5 miles).

Seven of the proposed drill sites are located in Variety Class B, and five are located in Variety Class A.

There are no maps of Sensitivity Levels for the project area. SMS mapping provides information about visually sensitive travelways in the area. In SMS, two trails within the Galiuro Wilderness (#271 and 289) have been designated Concern Level 1 (High Interest in Scenery). The closest of these is 2.7 miles away from the proposed project. The north end of trail #289 is mostly outside of Wilderness and passes near the project area, but has not been identified as a sensitive travelway because of the lack of public access and corresponding low trail use. Forest Road 8129 is a Concern Level 2 (Moderate Interest in Scenery), but is located 2.4 miles from the project area, but travelers on this road are unlikely to see the project due to distance and topography.

Eight of the proposed drilling sites are located in VQO Partial Retention. Four are located in VQO Modification. Definitions for VQOs are:

Partial Retention: Management activities must be visually subordinate to the characteristic landscape.

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Modification: Management activities may dominate the characteristic landscape, but must, at the same time, utilize naturally established form, line, color, and texture.

3.5.3 Environmental Consequences

3.5.3.1 Methodology This analysis was completed using the framework outlined in Forest Service Handbooks and GIS data. The proposed project would affect scenic resources. Activities that contrast with the valued landscape lower scenic integrity, and mineral exploration activities would introduce noticeable deviations to the characteristic form, line, color, and texture of a landscape.

3.5.3.2 Effects from No Action Under the No Action alternative, mineral exploration activities would not occur. No drilling would occur. Scenery would remain as it presently exists.

3.5.3.3 Effects from Proposed Action The project would include 12 drilling sites. Disturbance footprints at each site include a 50 ft. x 50 ft. drill pad, a 30 ft. x 30 ft. helicopter landing zone, and a foot trail (<350 feet long) between the two. A total of 1.2 acres would be disturbed.

Each site would have drill rigs and other facilities (including storage buildings and tanks, trash containers, and port-a-potties) as well as materials and processing areas. Drilling activities at each site would be completed within 2-3 months and reclamation would follow. The entire project may take 5 years to complete. No more than two sites would be drilled at one time. No roads would be constructed.

Visual impacts from the activities would occur from clearing vegetation and from industrial- looking facilities in an otherwise natural landscape. The tallest items at the drilling sites would be approx. 30 feet high. Topography and vegetation throughout the area varies, but is not expected to screen activities from sensitive travelways. Some drilling sites would likely be visible from hiking trails in the Galiuro Wilderness due to their locations in elevated and/or exposed areas with little vegetative screening, but because of distance (2 miles to the Wilderness boundary and 2.7 miles or more to sensitive trails) this impact is minor. Other drilling sites would be tucked into valleys where they are less visible from afar and/or partially screened by denser vegetation.

Drilling sites would contrast with the natural landscape and therefore negatively impact scenery, but reclamation of the site impacts is expected to meet the long term VQOs. Overland footpaths are not expected to require vegetation removal and would have no long-term effects. Water pipelines (and water storage tanks and pumps as needed) are not expected to impact scenery; no clearing is planned and these materials would be laid on the ground along access roads and removed when no longer needed for drilling activities.

Although the VRMS does not specifically require analysis of night-time project effects, drilling activities would operate 24 hours a day and the proposed project would include night time lighting at each site, which would alter the scenery and dark night-time setting in the areas. Additionally, helicopter landings during the winter months would require lights. However, because of distance from visually sensitive areas (2.7 miles or more), this impact is minor.

Planned reclamation is described in the Galiuro Drilling Project Plan of Operations (February 26, 2016) and includes grading to pre-disturbance topography, topsoil placement, seeding, and

72 Environmental Assessment placement of slash within 30 days of each drill hole completion. Additionally, the Plan of Operations mentions that dust will be kept to a minimum and proper housekeeping will be observed at all times. These measures would help reduce impacts to scenery. With the incorporation of the Proposed Action mitigation measures, the proposed project is expected to meet VQOs (as well as long-term SIOs).

3.5.3.4 Cumulative Effects Cumulative effects are defined as the incremental impact of an action, when added to other past, present, and reasonably foreseeable future actions. The cumulative effects boundary for cumulative effects to scenery is the Gailuro EMA during the 5 year proposed project.

Several projects on other portions of the Safford Ranger District, including proposed improvements at Fry Mesa and Treasure Park Campground, allotment analyses (Seventy Six, Two Troughs, Cedar Springs, and Veech), and Pinaleno Firescape) are outside of this boundary and therefore would not result in cumulative effects.

Reasonably foreseeable future actions in the project area that affect scenic resources include:

• Galiuro Firescape, which would provide long-term benefits to scenery by improving forest health and reducing risks of catastrophic wildfire.

• Forest Plan revision, which would improve the management of scenery on the CNF by implementing the SMS and providing improved direction for managing scenery (including guidance for future mineral exploration).

• Travel Management (changes to the Safford Ranger District motorized travel system), which would benefit scenic resources by decommissioning unnecessary and/or resource damaging roads.

Because there are no past or present actions that impact scenery, and most future actions would provide benefits, no cumulative effects from this project are expected. 3.6 Water Quality

3.6.1 Regulatory Framework Federal - Clean Water Act

The regulatory framework for surface water resources is established by the CWA and Arizona Revised Statute ARS Title 49. The CWA (33 United States Code [U.S.C.] Section 1250 et seq.) is the foundation for surface water quality protection. The objective of the CWA is to restore and maintain the chemical, physical, and biological integrity of domestic waters (i.e., waters of the U.S.). The CWA provides that states may receive delegated authority for controlling point and non-point source water pollution, designating uses for surface water bodies within state boundaries, and adopting water quality standards to protect those designated uses. Section 402 of the CWA established the National Pollutant Discharge Elimination System (NPDES) program, which prohibits point source discharge of pollutants to waters of the U.S. unless authorized by an NPDES permit. Effective December 2002, the EPA delegated implementation of the Federal NPDES program to the State of Arizona and is referred to as the Arizona Pollutant Discharge Elimination System (AZPDES).

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The ADEQ administers both individual and general AZPDES permits in accordance with ARS Title 49-255. The general permit known as the Arizona Construction General Permit (CGP) authorizes storm water discharges for multiple types of facilities without requiring site-specific applications for individual AZPDES permits. In general, land disturbances totaling one acre or more (including equipment and material staging areas) will require a CGP. In order to obtain coverage under the CGP, an operator must submit a Notice of Intent and may require preparation of a site-specific SWPPP.

Federal – Executive Orders

There are two Executive Orders related to water resources and this project: Executive Order 11988 (Floodplain Management), and Executive Order 11990 (Protection of Wetlands).

State of Arizona – Ground Water Regulations

Groundwater quality is regulated by the State of Arizona thru the ADEQ. ADEQ regulates and manages groundwater quality, primarily through the Aquifer Protection Permit (APP) program, and also establishes AWQS for the States ground waters.

Groundwater quantity and uses are regulated by the State of Arizona thru the ADWR. The ADWR regulates and manages groundwater quantity to ensure a long-term, sufficient and secure water supply. Under ARS Title 45, portions of the state have been designated “Active Management Areas” (AMA) for groundwater. The project area is not located in an AMA, thus no further discussion of AMAs will occur in this report.

The State of Arizona ADWR also regulates well construction under AAC Title 12, Chapter 15, and Article 8. These regulations outline minimum construction standards for wells/borings and specify the minimum methods for well and borehole abandonment.

Forest Service

The Forest Plan (1986, as amended) lists management objectives for Water Resources as follows:

• Manage all programs to eliminate or minimize onsite and downstream water pollution (CNF, 1986, Forest Plan (FP) p65)

• Monitor designated projects according to an approved water quality monitoring plan (USDA USFS CNF, 1986, FP p38)

• Manage riparian areas in accordance with legal requirements regarding flood plains, wetlands, wild and scenic rivers, and cultural and other resources. Recognize the importance and distinct values of riparian areas in Forest Plans. (FP, pg. 39).

• Manage riparian areas to protect the productivity and diversity of riparian-dependent resources by requiring actions within or affecting riparian areas to protect and, where applicable, improve dependent resources (Forest Service Manual (FSM) 2526). Emphasize protection of soil, water, vegetation, and wildlife and fish resources prior to implementing projects (FSM 2526). (FP, pg. 39).

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• Give preferential consideration to resources dependent on riparian areas over other resources. Other resource uses and activities may occur to the extent that they support or do not adversely affect riparian-dependent resources. (FP, pg. 39).

Floodplain Management Directives (FSM 2527.03) lists management objectives as follows:

• Avoid adverse impacts that may be associated with the occupancy and modification of floodplains and with the destruction, loss, or degradation of wetlands. Avoid filling of land within floodplains and wetlands wherever practicable.

• Do not permit floodplain development and new construction in wetlands wherever there is a practicable alternative

3.6.2 Existing Conditions Climate

The climate of the project area is typical of a moderately high elevation Arizona desert, with warm summers and moderate winter temperatures (Table 8). Table 8 shows that the area receives approximately 20 inches of precipitation annually (Western region Climate Center (WRCC), 2016). The area also experiences a bimodal precipitation pattern with short duration, high intensity monsoon thunderstorms in the summer months (July to Mid-September), and more prolonged storms that are associated with the passage of low pressure systems off the Pacific Ocean in the winter months (December – March). Fall and especially spring seasons are frequently very droughty. However, precipitation is infrequently but substantially increased from hurricane remnants in the months of September – November.

Table 8. 1981-2010 Monthly Climate Summary, Location: Latitude: 32.7296 Longitude: -110.4437 Elev: 4629ft (Source: Western Regional Climate Center and Parameter elevation Regressions on Independent Slopes Model (PRISM), accessed 8/11/16)

Jul Jan Jun Oct Apr Feb Sep Dec Aug Nov Mar May Annual

Avg. Max. Temp. (F) 55.1 58.3 64.1 72.8 82.9 91.7 92.3 89.9 86.6 77.0 64.7 55.2 74.2 Avg. Min. Temp. (F) 32.4 33.8 37.4 42.0 51.0 60.1 64.9 63.1 58.4 48.5 38.8 31.8 46.8 Avg. Precipitation (in) 2.25 2.05 1.97 0.69 0.35 0.21 2.91 2.95 1.71 1.38 1.41 2.17 20.04

Watersheds and Streams

The project area is located within two 6th code Hydrologic Unit Code (HUC) sub-watersheds of the greater San Pedro river valley, Copper Creek (HUC 150502030805), and Clark Wash (HUC 150502030801). Table 9 lists the proposed drill sites that are located in each sub-watershed.

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Table 9. Proposed drills sites located in each watershed HUC 6th Code Stream Name Proposed Drill Sites Watersheds Copper Creek Copper Creek Gal10P, Gal12P, (150502030805) Gal13P Copper Creek Pipeline Canyon Gal09P, Gal14P (150502030805) Copper Creek Marics Canyon Gal 03P, Gal06P, (150502030805) Gal07P Clark Wash Scanlon Wash Gal01P, Gal02P, (150502030801) Gal04P, Gal05P

The project area has four named streams appearing on the National Hydrography Dataset (NHD) and USGS quadrangles: Copper Creek, Pipeline Canyon, Marics Canyon, and Scanlon Wash. Table 10 below, lists information on each stream including: NHD Reach Code, Flow Regime, ADEQ Designated Uses (ADEQ, 2016b; ADEQ, 2016c). None of the streams in the project area have been designated as Unique Waters by the State of Arizona.

Table 10. Streams, USGS Reaches, Flow Regime and State Designated Uses Stream Name NHD Reach Code Flow Regime State Designated Uses (ADEQ) Copper Creek 15050203000203 Intermittent A&Ww, FBC, FC, AgL Pipeline Canyon 15050203001097 Intermittent A&Wc, FBC, FC Marics Canyon 15050203001096 Intermittent A&Wc, FBC, FC Scanlon Wash () 15050203000493 Intermittent A&Ww, FBC, FC NOTE: A&Ww – Aquatic & Wildlife warmwater A&Wc – Aquatic & Wildlife coldwater FBC – Full Body Contact FC – Fish Consumption AgL – Agricultural Livestock

Springs

There are two mapped springs proximal to the project area. An unnamed spring is located along Pipeline Canyon below proposed drill site Gal14P. A second spring (Norton Spring) is situated along Scanlon Wash just below proposed drill site Gal01P. The ADWR lists the flow at Norton Spring at 2 gallons per minute (gpm). (ADWR, 2016 Water Atlas Table 3.8-5(B) accessed 8/12/16)

Floodplains

The Federal Emergency Management Agency (FEMA) is the lead Federal Agency for floodplain delineation and mapping of floodplains. However, floodplains are largely unmapped on Forest Service Lands, and no FEMA floodplain mapping is available in the project area. Floodplains, as defined under Executive Order 11988, do exist along the streams in the project area. Further, some of the drill sites are within short distances to these streams and associated floodplains. To assess if any of the proposed actions would take place within previously unmapped floodplains, a cursory analytical floodplain determination was made at drill site Gal01P, which based on proximity and topography, was judged to be the most likely site to be potentially located in the floodplain. The analysis concluded that the proposed activities would not occur in a floodplain.

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Wetlands

No CWA jurisdictional wetland determinations are known to have been conducted or appear on Federal mapping databases reviewed for the project area (USFWS). Although some areas of riparian habitat are present (see section below), there are no areas known to meet the requirements of wetlands, as defined in 40 CFR 230.3(t), and under Section 404 of the Clean Water Act.

Riparian Areas

Riparian vegetation and habitat are identified within at least two areas in the general project area. However, the individual proposed drilling pads and helicopter LZ sites do not occur within these known riparian areas. The USFS riparian map (RMAP) identifies an “Arizona Walnut riparian segment” along Scanlon Wash from the NFS boundary upstream past Norton Spring and proposed drill sites GAL01P and Gal05P. The site visit conducted on August 17, 2016 confirmed presence of riparian vegetation and habitat along the stream corridors of Scanlon Wash in the project area.

The Safford RD Range program has conducted riparian vegetation and stream monitoring along Copper Creek since 1998. The Riparian Area Survey and Evaluation System (RASES) monitoring ratings were conducted in 1998, 2003 and 2010 (Dominguez, G., 2016). The 2010 evaluation notes increasing trends in riparian density/vigor from the NFS boundary continuing and increasing upstream. The evaluation indicated little to no impact from livestock or recreation uses.

Municipal Watersheds

The project area is not within a Source Water Protection Area for a public water supply or in an established Municipal Water Supply Watershed under FSM 2542 and 36 CFR 251.9.

3.6.3 Environmental Consequences

3.6.3.1 Methodology Analysis methods included identification and inventory of existing resource locations and conditions. This consisted of acquiring data from various agencies for climate, geology, water quantity, and water quality information. Field data was collected and included observations of soils, geology, floodplain and riparian conditions. Stream channel geometry was surveyed and a water quality sample was collected. Various mapping products and aerial photography were reviewed, laboratory water analysis were interpreted, and hydraulic stream and floodplain modeling was conducted. Information was also obtained from the PoO and various PoO supplemental documents.

Information Sources

Site-specific and general area information for this analysis was largely gathered from the sources below.

Internal U.S. Forest Service (USFS) Resources:

o GIS Mapping [e.g., soils General Terrestrial Ecosystem Survey (GTES), riparian (RMap)]

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o Aerial Photography

o Resource Policy and Guidance documents (e.g., Groundwater Management guidance, Exploratory Drilling guidance, Forest Plan direction and FSM directives, FSH, and BMP guidance),

o Field Collected Data (range/riparian monitoring, site-specific channel survey and floodplain analysis, sampling and analysis of ambient spring water quality)

External Resources:

o USGS – Geology, Watershed, Hydrography

o USFWS – Wetlands

o ADWR – Major watershed basin and groundwater data and statistics, well data

o ADEQ – Water quality data, designated uses, impaired waters data

o NOAA and affiliates - Climate data

o EPA –Water quality data and standards

o FEMA – Floodplain mapping

o KEC – Galiuro PoO, proposed drill pad locations (GIS) Incomplete and Unavailable Information

The following desirable information was identified as incomplete or unavailable:

• Finer resolution soils and terrestrial ecosystem mapping (e. g., Terrestrial Ecological Unit Inventory (TEUI))

• Information on the aquifers actually present in the analysis area and their hydraulic, geochemical and water quality characteristics

• Site-specific run-on/runoff storm water controls, soil erosion and sedimentation controls

• Finer resolution site specific topographic information

• Detailed floodplain mapping, and historic streamflow gaging records

• Comprehensive surface water and groundwater quality data

Assumptions

To address some of the above incomplete/unavailable information, the effects analysis herein are based on the following assumptions:

• Water used for drilling would be obtained from a shallow alluvial supply well located on private lands near a drainage with sensitive riparian habitat in the area

• Water used for drilling exceeds one or more State AWQS

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• The drilled boreholes would cross multiple aquifers

• Open boreholes would convey waters between aquifers

• Artesian pressures could be encountered in the boreholes, resulting in water discharge at the wellhead

• Aquifers penetrated by the boreholes have a direct connection to local springs

• The aquifers penetrated would include sulfide bearing geologic units with subsequent “mineralized” and/or “polluted” waters as defined by ADWR

• Stream reaches, as shown on the NHD within the NFS lands have intermittent flow with the presence of local perennial springs

• NHD stream reaches support riparian vegetation and habitat corridors, aquatic, wildlife, recreation and grazing uses

• NHD stream reaches and springs currently meet State Surface Water Quality Standards (SWQS) and all designated uses, with the exception of Copper Canyon which is anticipated to be CWA 303(d) listed as impaired in ADEQ’s 2016 assessment report (ADEQ, 2016b; ADEQ, 2016c)

• Surface water divides (watersheds) and groundwater divides (basins) are coincident

• The empirical peak stormflow and floodplain modeling estimates employed herein, are sufficient analytical tools for this project

• Any discharge of drilling fluids to drainages and NHD streams would cause an exceedance of State SWQS and be a violation of the CWA

• Drill cuttings brought to the surface would be sulfide bearing and include trace or priority pollutant metals, as defined by EPA. These waste materials would be assumed to be acid generating and capable of releasing metals.

• Soils are erodible and sensitive to disturbance

• Existing soils characteristics data is sufficient

3.6.3.2 Effects from No Action Because the no action alternative would not authorize any activities in the project area, there would be no potential to incur direct and or indirect effects on water resources in the project area.

3.6.3.3 Effects from Proposed Action Quantity

The annual water consumption of the project is estimated to be 3.36 acre-feet/year (ac-ft/year) (KEC, 2016) and be derived from a private well or municipal supply located outside of NFS lands, but within the Lower San Pedro basin. The ADWR estimates total cultural water demand in the Lower San Pedro basin is 25,700 ac-ft/year (as of 2005, ADWR, 2016). The additional incremental increase in cultural water demand due to the Proposed Action is a 0.013% temporary increase in water use on a basin-wide basis.

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Quality

Deep boreholes drilled through the groundwater system could create a temporary preferred pathway for groundwater located in deeper formations to migrate upward and intermingle with the shallow parts of the system. Surficial land disturbance, uncontrolled well discharge at the surface, loss or improper storage of geologically reactive (sulfide bearing, acid generating rock) drilling waste could impact surface waters. A combination of Proponent Proposed Environmental Protection Measures (PPEPMs), Design Features (DFs), Mitigation Measures (MMs) and BMPs effectively reduce these risks to surface and ground water quality to the point that direct short- term and long-term effects are effectively mitigated on NFS lands.

Groundwater

The Proposed Action consists of a mineral exploration drilling program that poses a relatively low risk, but nonetheless a potential risk to impact groundwater quality and quantity. Deep boreholes drilled through the groundwater system could create a preferred pathway for groundwater in deeper formations to migrate upward and intermingle with the shallow parts of the system. Borings could penetrate and directly affect perched or confined aquifers, and in turn affect adjoining aquifers, springs or surface waters in terms of both quantity and quality. A potential issue would be a risk of water exchange between aquifers as a result of the Proposed Action. While it is acknowledged that a small volume of groundwater could move from one aquifer to another or one lithologic unit to another while the boring is drilled and open, the period of time will be limited to perhaps a few weeks, after which the boring will be properly plugged and abandoned with high-solids bentonite and/or cement grout. While the boreholes are being drilled, open boreholes could also affect groundwater quality by acting as a preferred pathway for surface contaminants or spills to migrate into the subsurface through the open borehole. There is a potential risk for subsurface contamination to occur as long as the borehole remained open, but the risk would be eliminated once the boring is completed and properly abandoned. Upon the conclusion of drilling, the boreholes would be effectively sealed to prevent long-term exchange of water between aquifers, or between the surface and the aquifers below. Available water for drilling potentially poses a risk to groundwater quality and any subsequently connected surface waters. With this in mind, the drilling supply water underwent water quality testing to identify potential contaminants that may be introduced into the system. This testing found that the water source met all ADEQ aquifer water quality standards, except for Escherichia coli (E. coli) tested positive. A mitigation measure is proposed to address the E. coli concern, and the mitigation requires proper disinfection of any water derived from this source prior to use for drilling.

Surface Water

Surface disturbance of soils for drill pads could affect surface water quality by removing stabilizing vegetation and increasing soil erosion. Sediment from disturbed areas or soil stockpiles could be transported downslope via wind and water erosion and deposited in surface water drainages. Surface water quality effects could result from an accidental spill of fuel, hydraulic fluid, lubricants or coolants from power equipment, particularly if the spill goes undetected or occurs close to an existing surface water drainage or spring. KEC would reduce the potential for accidental spills by proper storage and handling methods as well as implementing a Spill Response Plan (SRP) that contains provisions to rapidly contain and clean-up accidental spills before the spilled material infiltrates into the subsurface. Direct effects to surface water could also occur if artesian flowing-well conditions are encountered and are not immediately controlled. Uncontrolled artesian water discharge to the land surface and drainages, could result in exceedances of State SWQS. There is a direct risk to surface water quality should the drilling

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water recirculation sump(s) be breached or overflow. There is a risk for soil contamination and subsequent impact to surface water (and groundwater) quality should geologically reactive drill cuttings not be properly managed upon site reclamation. Drill cutting wastes from coring operations, while relatively small in volume, have the potential to generate acid by oxidation of sulfide minerals brought up to the surface. The drilling water supply line provides a potential pathway for contaminated drilling fluids to backflow to a private potable domestic water supply or stream course outside of NFS lands. A series of DFs, MMs, and BMPs are proposed to address all of these potential risks, and are predicted to effectively mitigate these potential direct effects.

3.6.3.4 Cumulative Effects In regards to water quantity, there are negligible effects due to the Proposed Action, therefore, there are negligible cumulative effects to water quantity.

In regards to water quality, with the incorporation of the proposed DFs, MMs, and BMPs it is estimated that there are low to negligible effects to water quality from the Proposed Action. There are currently insufficient data to quantitatively model estimates of cumulative water quality. There would be small but calculable cumulative effects to water quality if the “Cake Burn block” of the Galiuro Firescape were to temporally overlap with the Proposed Action within 2-years of each activity. The cumulative water quality effects would expect to dissipate rapidly and reduce to pre-burn levels from the Galiuro Firescape project based on factors such as successive precipitation events moving ash and sediment thru the surface water system, and rapid regrowth in grasslands and chaparral vegetation types. 3.7 Soils

3.7.1 Regulatory Framework Soil management objectives, applicable to this project, include some of the provisions of the Federal CWA, in particular the non-point source control provisions. With the cooperation of the ADEQ, who administers the CWA in Arizona, the USFS has implemented Best Management Practices (BMPs) to reduce soil erosion and sediment delivery to streams from land disturbing activities. These are further discussed in FSM 2532. Specific BMPs for this project are located in the Appendix G.

The Forest Plan (1986, as amended) lists management objectives for soils as follows:

• Management of forest resources to protect or enhance watershed condition from both a hydrologic function and soil productivity standpoint.

• Mitigate any adverse effects of planned activities on soil and water resources through the use of Applicant-proposed BMPs and Forest BMPs and Mitigation Measures

• Through management services, provide information to minimize disturbance and improve already disturbed areas. Best management practices will be used to minimize the time of recovery to a satisfactory erosion level, minimize soil productivity loss, improve water quality and minimize channel damage. (FP, pg. 38).

• Restrict equipment use to terrain and climatic conditions where soil damage will be minimal. (FP, pg. 39).

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Using these objectives, the IDT evaluated potential impacts to soils in the project area, and prepared reports to disclose any effects determinations. A summary of the findings in the reports is described below.

3.7.2 Existing Conditions Topography

The project is located in the northwesterly corner of the Galiuro Mountain range, approximately 12 miles easterly of the Town of Mammoth, AZ. The project is bounded on the East by the peaks of Cake Mtn. (elevation 6522 Mean Sea Level (MSL)) and Biscuit Peak (approx. 6600 MSL). From the peaks, the land steeply declines off the western flank in deep ravines to the western boundary of the NFS lands (approx. 4600-5600 MSL, variable). Beyond the NFS lands the topography descends more gradually on the western mountain-front piedmont to the San Pedro River (approx. 3600 MSL). The San Pedro flows in a wide alluvial channel northwesterly towards the Gila River (approx. 1800 MSL).

Geology

The Galiuro Mountains are rugged block faulted mountains within the Basin and Range physiographic province, which is characterized by northerly trending, parallel alternating, broad intermountain valleys and high mountain ranges. Down-faulted valleys are filled with erosional sediment forming alluvial fans, pediments and floodplains.

The surficial geology of the project area, and all drill sites, is described as Tertiary andesitic rocks, and are composed of andesite, lava flows, breccia deposits, and interbedded sedimentary rocks (Drewes, H., 1996). Based on a review of the most current USGS geologic mapping, there are no mapped faults, or other notable structures in the project area. The prominent fault in the mountain range is the NNW trending Central Galiuro Fault (a.k.a. Rattlesnake Fault), which is located easterly of the project area, and not shown to extend into the project area. Known to be present (but not depicted on the USGS geology maps), are stringers of shallow Quaternary alluvium and floodplain deposits present along the stream channels. These are observed to be somewhat discontinuous, but can be of sufficient width and depth to support riparian habitat and vegetation.

Rock units below the Tertiary andesite, estimated to be at a depth of less than 1 km, and are believed to be Paleozoic sedimentary rocks of the Martin Formation and Escabrosa Limestone.

Soils

Detailed soils and vegetation data, such as the USFS TEUI mapping, are not yet available for this project area. However, the GTES is available for Region 3 at a mapped scale of 1:250,000. It is suitable for general assessment and evaluation of projects impacting large areas (FSM 2551.6 - Integrated Inventories R3 supplement).

The entire project area falls within Unit 483 in the GTES mapping. Unit 483 is described as a complex of moderately deep Typic Ustochrepts (deep, warm and droughty) and Lithic Ustochrepts soils (shallow, warm and droughty). Both soil types have extremely cobbly soil surfaces with calcareous sandy loam to loam soils. The slope range is 40 to 80 percent slopes. They are found in association with Limestone escarpments of 80 to 120 percent slopes. Any disturbance on these slopes with this soil will have issues with erosion (Boness, P., 2016).

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During a site visit to Norton Spring on 8/17/2016, upland soils were observed to be moderately thin and rocky, with moderate to steep slopes. Based on frequent exposed outcrops, and entrained coarse material, soils are predominantly derived from and underlain by variably weathered andesite bedrock, rather than limestone. Streambed alluvium and floodplain deposits were noted to be present along Scanlon Wash below Norton Spring.

3.7.3 Environmental Consequences

3.7.3.1 Methodology To analyze the potential effects of the Proposed Action on soils and vegetation, a Forest Hydrologist identified and inventoried existing resource locations and conditions in the Project Area. This consisted of acquiring data from various agencies. Collection of field data was included; observations of soils, vegetation, geology, floodplain and riparian conditions. Various mapping products and aerial photography were reviewed. Information was also obtained from the PoO and various PoO supplemental documents.

Information Sources

Site-specific and general area information for this analysis was largely gathered from the sources below. Internal USFS Resources:

o GIS Mapping [e.g., soils (GTES), riparian (RMAP)]

o Aerial Photography

o Resource Policy and Guidance documents (e.g., Exploratory Drilling guidance, Forest Plan direction and FSM directives, Forest Service Handbook (FSH), and BMP guidance),

o Field Collected Data External Resources:

o USGS – Geology, Topography

o KEC – Galiuro PoO, proposed drill pad locations (GIS) Incomplete and Unavailable Information

The following desirable information was identified as incomplete or unavailable:

• Finer resolution soils and terrestrial ecosystem mapping (e. g., TEUI)

• Site-specific run-on/runoff storm water controls, soil erosion and sedimentation controls

• Finer resolution site specific topographic information

Assumptions

To address some of the above incomplete/unavailable information, the effects analysis herein are based on the following assumptions:

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• Artesian pressures could be encountered in the boreholes, resulting in water discharge at the wellhead, and potentially soil erosion due to the release of water to the surface.

• Stream reaches, as shown on the NHD within the NFS lands have intermittent flow with the presence of local perennial springs.

• NHD stream reaches support riparian vegetation corridors, aquatic, wildlife, recreation and grazing uses.

• Any discharge of drilling fluids to drainages and NHD streams would cause an exceedance of State SWQS and be a violation of the CWA.

• Soils are erodible and sensitive to disturbance.

• Existing soils data is sufficient

Effects have been evaluated by considering the potential for the Proposed Action to cause soil erosion, transport and/or sedimentation. The key indicator for this analysis is the acreage of soil disturbance associated with the Proposed Action. The intensity of the effects is based on the Proposed Action disturbing soils at moderate to high risk for erosion in the project area. Analysis of the duration of impacts considers both the overall time interval of the project and the length of time during which effects on soils could be detected.

3.7.3.2 Effects from No Action Because the no action alternative would not authorize any activities in the project area, there would be no potential to incur direct and or indirect effects on soil resources in the project area.

3.7.3.3 Effects from Proposed Action A discontinuous area of approximately 1.2 acres of soils would be disturbed by the Proposed Action. The Proposed Action would result in some rather limited areas of soil compaction within the project area, particularly at the twelve, 2,500 ft 2 drill pads that would be used on a fairly continual basis during project development and implementation. The proposed DF’s, MM’s, and BMPs require stormwater management, erosion controls, control of drilling fluids and cutting wastes, and proper storage of stockpiled soils for reclamation. The operator is required to monitor, maintain and periodically report on these mitigation provisions. The PPEPMs, BMPs and MMs for reclamation will help prevent erosion, and include recontouring and reseeding. The proposed DF’s, MM’s, and BMPs require that drilling wastes be tested to determine if they are reactive and/or pose a potential soil or water contamination risk. The closure testing will determine if the waste drill cuttings can be safely encapsulated and remain on-site, or if they will be required to be removed from NFS lands. These reclamation activities would be conducted as drilling activities are completed at each individual site. Direct effects to soils would include soil disturbance and potential compaction in the drill pads, LZs, and the foot path areas, soil erosion, and the potential for soil contamination. The soils effects analysis predicts that the Proposed Action, as amended with the DF’s, MM’s, and BMPs, will result in negligible effects on Forest soil resources.

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3.7.3.4 Cumulative Effects The Proposed Action would contribute to cumulative soil resource effects (including localized increases in soil compaction, erosion, and sedimentation potential). One foreseeable action with the potential for cumulative effects is the “cake” burn block of the Galiuro Firescape project. This vegetation treatment project may have temporary soil stability and non-point source effect to water quality that could overlap the PA in space and/or time. However, because direct and indirect effects on soils from the Proposed Action would be minor and managed through multiple standards for reduction of soil erosion, the cumulative effect analysis for soil erosion and transport is very low, if not negligible. The soils effects analysis predicts that the Proposed Action as amended with the DF’s, MM’s, and BMPs, will result in negligible effects on soil resources. Therefore, the cumulative effects would also be essentially negligible. 3.8 Recreation In order to comprehensively determine effects on recreation resources, the District Recreation Staff Officer, Forest Landscape Architect and District Biologist analyzed effects on recreation, Wilderness Areas and Inventoried Roadless Areas. The results of their findings are disclosed below.

3.8.1 Regulatory Framework Multiple-Use Sustained Yield Act of 1960

This act states that the national forests are established and administered for outdoor recreation, range, timber, watershed, and wildlife and fish purposes. It authorizes and directs the Secretary of Agriculture to develop and administer the renewable surface resources of the national forests for multiple use and sustained yield of the products and services obtained therefrom.

Wilderness Act of 1964

The Galiuro Wilderness was designated under the Wilderness Act of 1964 and expanded to its current acreage under the Arizona Wilderness Act in 1984. The Wilderness Act of 1964 is the primary regulation that determines the management of wilderness areas throughout the nation; however, additional guidance is included in the Coronado National Forest Land and Resource Management Plan.

A wilderness area is defined as “an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserve its natural conditions and which (1) generally appears to have been affected primarily by the forces of nature, with the imprint of man's work substantially unnoticeable; (2) has outstanding opportunities for solitude or a primitive and unconfined type of recreation; (3) has at least five thousand acres of land or is of sufficient size as to make practicable its preservation and use in an unimpaired condition; and (4) may also contain ecological, geological, or other features of scientific, educational, scenic, or historical value” (Section 2(c)).

The Wilderness Act goes on to state that all federal agencies must administer wilderness in a manner which preserves wilderness character. In addition, the areas will be “devoted to the public purpose of recreational, scenic, scientific, educational, conservation, and historical use” (Section 4(b)). In an effort to uphold this portion of the Act, several prohibited uses were identified, including the use of motorized vehicles and equipment within wilderness boundaries, “except as

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necessary to meet minimum requirements for the administration of the [wilderness]” (Section 4(c)).

Roadless Rule of 2001

The 2001 Roadless Rule establishes prohibitions on road construction, road reconstruction, and timber harvesting on inventoried roadless areas on National Forest System lands. The intent of the Roadless Rule is to provide lasting protection for inventoried roadless areas within the National Forest System in the context of multiple-use management.

3.8.2 Existing Conditions The project area elevation ranges between 4,633 feet and 5,860 feet above mean sea level. The project area is located in the Galiuro Mountains, approximately 12 miles east-northeast of Mammoth, Arizona. The San Pedro River is approximately 10.7 miles southwest and Aravaipa Canyon is approximately 9.9 miles north of the project area. Copper Creek is located in the northeastern portion of the project area, Pipeline and Marics Canyons bisect the project area, Cake Mountain and Biscuit Peak are south of the project area, and numerous springs are within a 1-mile radius.

Recreation

There are no developed recreation sites in the immediate project area. There is one developed campsite, Deer Creek Campground, in the northeast portion of this mountain range, and there are several additional undeveloped sites, including free-use cabins at Jackson Cabin and Powers Garden.

The Galiuro Mountains and the project area contain opportunities for dispersed recreation including hiking, hunting, backpacking, climbing, and bird watching. The mountain range contains approximately 88 miles of trails. Extreme temperatures, lack of water, and rugged terrain limit the majority of recreational use to spring and fall, coinciding with local hunting seasons. The project area currently receives very little public use due to a lack of developed trails in the area as well as a lack of forest access roads in the project vicinity.

Wilderness

The Project Area is approximately two miles from the Galiuro Wilderness, which encompasses 76,317 acres, or approximately 57% of the Forest Service lands in this area. No use of motorized or mechanized equipment is authorized within the wilderness area, unless the use is approved by the Regional Forester. In February of 2009, motorized use was authorized in order to enable the AGFD, the National Wild Turkey Federation, and the Forest Service to release Gould’s wild turkeys into the Powers Garden area. In 2011, tree ring samples were collected in order to gather data regarding historic fire cycles. Samples were obtained by taking wedges from trees within the wilderness using chainsaws. For these projects, there was a determination that temporary reductions in wilderness character (i.e., opportunities for solitude and untrammeled wilderness character) occurred, but would not extend beyond the duration of the projects. Other than these uses, no authorizations of motorized/mechanized use have been made in recent history within this mountain range. General administrative access to the Galiuro Wilderness is accomplished on foot or horseback, which do not affect wilderness character.

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Inventoried Roadless Areas

The Project Area also lies within a designated IRAs which prohibits new road construction and reconstruction except where a road is needed in conjunction with the continuation, extension, or renewal of a mineral lease on lands that are under lease, or for new leases issued immediately upon expiration of an existing lease.

3.8.3 Environmental Consequences

3.8.3.1 Methodology Forest resource specialists used the regulatory framework in section 3.8.1 to analyze potential effects on recreation, Wilderness Areas and Inventoried Roadless Areas.

3.8.3.2 Effects from No Action Under the no action alternative, there would be no activities authorized and therefor no effects on recreation, Wilderness Areas or Inventoried Roadless Areas. Existing conditions would continue as they are in the project area.

3.8.3.3 Effects from Proposed Action Recreation

Developed recreation sites would not be affected because there are no developed sites within or near the proposed project.

Dispersed recreation would be negatively impacted by the project. Although no roads would be constructed and no trees removed, there would be other impacts that would affect the setting and solitude in this area throughout the 5 years of proposed activities. During construction, there would be noise and dust impacts from helicopters and construction equipment. During drilling, there would be noise from drill rigs as well as noise and dust impacts from helicopter flights. During reclamation, there would be additional noise and dust from helicopter flights, removal of equipment, and grading. All of these would result in a loss of quiet settings that are valued by forest visitors. Game species pursued by hunters could also be displaced from the area, which could negatively impact hunting success.

During drilling work, helicopter flights would be limited to 2-4 per day and the proposed flight path routes helicopters is from the west side of the EMA, which would minimize recreation impacts. Planned reclamation measures would help minimize impacts to recreation settings. There would be no long-term impacts to recreation.

Wilderness

This project takes place outside of the wilderness boundary and will have little or no effect on wilderness or wilderness character. The closest drilling hole is approximately 2 miles away from the wilderness boundary. Although helicopters sounds might be evident from within the wilderness, the effects would be similar to other noise from roads and aircraft currently in the area.

Planned reclamation measures would help minimize impacts to recreation settings. There would be no long-term impacts to Wilderness.

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Inventoried Roadless Areas

The IRA setting would have some negative impacts. Although no roads would be constructed and no trees removed, there would be other impacts that would affect the setting and solitude in this area during the 5 years of proposed activities. During construction, there would be noise and dust impacts from helicopters and construction equipment. During drilling, there would be noise from drill rigs as well as noise and dust impacts from helicopter flights. During reclamation, there would be additional noise and dust from helicopter flights, removal of equipment, and grading. All of these would result in a loss of quiet settings that are valued by forest visitors.

During drilling work, helicopter flights would be limited to 2-4 per day and the proposed flight path routes helicopters is from the west side of the EMA, which would minimize IRA impacts. Planned reclamation measures would help minimize impacts to recreation settings. There would be no long-term impacts to IRAs.

3.8.3.4 Cumulative Effects The existing conditions in the project area are excellent (including effects from past and present actions). Future actions include Galiuro Firescape, Forest Plan Revision, and Travel Management, all of which would provide benefits to recreation, Wilderness, and IRA resources and settings. Therefore, the proposed project, when combined with past, present, and foreseeable future actions, is not expected to result in cumulative effects to recreation, Wilderness, or IRAs. 3.9 Rangeland and Noxious Weeds

3.9.1 Regulatory Framework Rangeland

National Forest Service direction on range management is provided in FSM 2200 Range Management and the following handbooks:

• FSH 2209.13 (Grazing Permit Administration Handbook)

• FSH 2209.21 (Range Analysis Handbook)

• FSH 2209.22 (Structural Range Improvement Handbook)

• FSH 2209.23 (Non-structural Range Improvement Handbook)

The Forest Plan for Management Areas 1 and 4 identifies specific prescriptions to meet rangeland management program goals. These specific Forest-wide Management Prescriptions provide direction for range management activities to optimize production and utilization of forage allocated for livestock use consistent with maintaining the environment and providing the multiple uses of the range.

Noxious Weeds

There are no specific standards for invasive species management in the Forest Plan. Forest Service Manual direction for Invasive Species Management is contained in FSM 2900, effective December 5, 2011. This direction sets forth NFS policy, responsibilities, and direction for the prevention, detection, control, and restoration of effects from aquatic and terrestrial invasive species (including vertebrates, invertebrates, plants, and pathogens).

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FSM 2900 – Invasive Species Management, Amendment No.: 2900-2011-1, December 5, 2011. Establishes code and a new manual, FSM 2900 Invasive Species Management, which sets forth NFS policy, responsibilities, and direction for the prevention, detection, control, and restoration of effects from aquatic and terrestrial invasive species (including vertebrates, invertebrates, plants, and pathogens). It replaces FSM 2080 (noxious weed management).

Executive Order 13112, Invasive Species, December 5, 2016, Federal Register, maintains the National Invasive Species Council and directs that invasive species be controlled on all federal lands. The Council publishes the USDA Forest Service Guide to Noxious Weed Prevention Practices (USFS, 2001).

3.9.2 Existing Conditions Rangeland

This project area is located within the Copper Creek Range Allotment on the NE end of the Galiuro Mountain Range. This allotment is permitted for 120 head of cattle from 11/01-01/31. The allotment is about 3,550 acres. The major vegetation type include Madrean Encinal Woodlands, Arizona Walnut and Semi Desert Grasslands. Trends in vegetation condition are static or improving on all of the allotments and soils are considered stable. Riparian condition has been monitored at five year intervals since 1986 and is considered stable.

Noxious Weeds

Field studies were conducted and focused on recording dominant vegetation communities and floristic plant surveys. These surveys were floristic in nature, and a more focused search was not conducted for non-native species that may occur in the vicinity of the project area or use habitats similar to those associated with the project area. Further, botanical surveys were performed in winter, when plant species might not be detectable.

Surveys were likely not sufficient to detect all weeds present in the project area. However, the analysis area is remote, pristine, and contains few roads. Thus, few invasive species are expected to occur, and only three were observed: a small patch of Bermudagrass was observed at LZ85, 05P; a single brome plant was observed at LZ86, 07P; and morning glory (Ipomoea sp) was present, but uncommonly encountered in the Copper Creek Canyon.

3.9.3 Environmental Consequences

3.9.3.1 Methodology The analysis area includes the project area, vegetation of surrounding areas, and the locations where non-native plant species and noxious weeds could be introduced and spread from the Proposed Action.

3.9.3.2 Effects from No Action Because the no action alternative serves as a baseline to compare the Proposed Action to, this alternative would have no effect on rangeland resources or authorize any activities which would contribute to the introduction of noxious weeds.

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3.9.3.3 Effects from Proposed Action Rangeland

Approximately 1.2 acres of disturbance would occur in the 3,550-acre Copper Creek Allotment, accounting for approximately 0.03 percent of the allotment. This level of disturbance is not likely to cause a need for a reduction in the permitted use. This effect on range would be negligible, with short-term loss of forage. Noise in the project might irritate livestock in the beginning of their time on the allotment but they would adjust to it in a couple of days. The dust produced by activities in the project would not be measurable to rangelands.

An important part of reclamation is re-vegetation success, which also reestablishes forage for livestock. Livestock grazing could be detrimental to reclamation success. The Forest Service would not require the allotment permittee to change their management practices to ensure reclamation success. However, as part of the Reclamation Plan, KEC may be required to fence off the reclamation sites from livestock grazing to ensure revegetation success.

Noxious Weeds

As described above, weed surveys detected three invasive species in the Project Area, however, since surveys were performed in November, it is possible not all weeds were found. In order to determine the risk of weed expansion from existing or undetected weeds the following factors were considered: 1) the release of pre-existing but currently dormant weed seed banks at disturbed sites, 2) the rapid build-up of transient weed seed banks at disturbed sites, and 3) the creation of conditions favoring weed establishment at disturbed sites. The risks are labeled “high, moderate and low,” and are defined as follows:

. High: Chances of weed species infesting new areas range between 76 to 100 percent. . Moderate: Chances of weed species infesting new areas range between 31 to 75 percent. . Low: Chances of weed species infesting new areas range between 1 to 30 percent. The risk level anticipated for this project for weed expansion from current or undetected weeds is moderate. This risk ranking was chosen after careful consideration of the three avenues for weed proliferation listed above, in addition to the following three factors:

• Species-specific dispersal traits of weeds. Weed species with seeds dispersed by wind, by tumbleweed, water, or by animals can potentially spread weed propagules miles from their original sources. Most seeds are not moved far from the parent plant, but a small proportion of seeds can be found large distances away. Even propagules with low innate dispersal abilities, such as stem fragments of giant reed or castor bean seeds that fall close to the plant, can be carried far after initial dispersal by streams or surface runoff. However, species without wind, water, or animal-mediated dispersal are less likely to disperse propagules far from the original source. • Habitat being disturbed. While many weed species are generalists that can potentially colonize a fairly wide range of vegetation types, it is true that some habitats, particularly those with ample nutrients and soil moisture or those that have been recently disturbed, are more susceptible to invasion. Additionally, the suite of weed species that one would expect to colonize a site is dependent to some degree on the habitat where the disturbance occurred. • Type of ground disturbance. The type of disturbance creates conditions favoring release and establishment of different weed species. For example, vegetation removal is expected to favor the establishment of weed species that do best in full sun and soil disturbance is expected to favor the establishment of early-colonizing weed species that respond favorably to disturbed, denuded soils.

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The proposed project poses some risk of introducing invasive plant species. Heavy equipment would be brought to the project area by contractors from other geographic areas. In addition, areas of ground disturbance caused by ground-based heavy equipment operations are especially vulnerable to establishment and rapid spread of weeds. However, it is unknown what species might be brought in by equipment or whether they could establish in the project area, however the total disturbed area is small (1.2 acres). The risk of transporting new weeds into the project area is determined to be low, based on the definitions provided above and because of other precautions that will be taken by the company, such as washing equipment and the small about of noxious weeds in the current project area. Practices to reduce the spread of invasive weeds, particularly post-reclamation monitoring and re-establishment of native vegetation would allow for quick treatment to eradicate infestations that do occur.

3.9.3.4 Cumulative Effects Rangeland

Past and present mining, road construction, grazing and recreation have created the conditions that occur in the allotment currently. No change in the level of grazing or recreation is anticipated in the foreseeable future. Allotment Management Plans call for maintenance or replacement of range improvements. Any one of these actions will most likely lead to ground disturbance. The existing conditions in the project area are stable (including effects from past and present actions). Future actions include Forest Plan Revision, and Travel Management, both of which would have little to no measurable effects on the allotment. Galiuro Firescape fire treatments would result in a temporary loss of forage both before and after burning. In order to have sufficient fuel to carry fire grazing will be suspended for a season prior to the burn and at least one growing season rest must follow the burn to allow for recovery of plants to provide soil and plant health, and forage. Burned areas maybe be unavailable for grazing until these needs are met. Therefore, additional growing seasons of rest may be required. In the long term, fire treatment would benefit the forage resource and therefore benefit livestock indirectly. Once recovered, forage quality and quantity would be enhanced.

Noxious Weeds

Ongoing grazing and recreation could introduce and establish invasive species in areas void of vegetation like the drill pads. If invasive species establish, they can spread to areas outside of the project area. However, post reclamation monitoring would likely identify nearby infestations which would be reported and treated. Other future actions in the project area include Galiuro Firescape and Travel Management. Galiuro Firescape could open up vegetated areas and make them susceptible to noxious weed establishment, however, this would require an existing weed seed source or one close enough to be brought into the area by wind or animal. Travel Management should not affect the project area in regard to noxious weeds, due to limited access and the lack of roads in the project area. Overall, cumulative impacts on invasive species are anticipated to be minor. 3.10 Fire Management

3.10.1 Regulatory Framework Federal Fire Management Policies and Direction

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Overarching guidance and strategies for Department of Agriculture fire management programs and policies stem from: Managing Impacts of Wildfires on Communities and the Environment, Protecting People and Sustaining Resources in Fire Adapted Ecosystems: A Report to the President in Response to the Wildfires of 2000 (also known as the National Fire Plan [USDA and USDI 2002]) and the Federal Wildland Fire Management Policy and Program Review (USDA and USDI 2001). These documents can be found at http://www.forestsandrangelands.gov/.

Agency Standards and Guides Coronado National Forest Land Resource Management Plan (Forest Plan 1986; pages 9–11, 45): • Reduce the costs, resource damage, and threats to public and firefighter safety from future wildland fires. • Manage naturally occurring fires to restore and sustain ecological processes in fire- dependent ecosystems. • Create and maintain fuel conditions for low risk of extreme fire behavior and high- intensity wildland fires. • Cooperate with other Federal, state and local regulatory agencies to protect air quality as required by the Clean Air Act. • Provide for ecosystem diversity by at least maintaining viable populations of all native and desirable nonnative wildlife, fish, and plant species through improved habitat management. • Continue a program that enhances other resource values, and that effectively utilizes the wood fiber produced. Carry out silvicultural practices to improve stand health when such practices are consistent with other resource objectives. • Provide a favorable water flow in quantity and quality for off-Forest users by improving or maintaining all watersheds to a satisfactory or higher level. • Wildland fire use shall follow direction specific to the Forest’s Fire Management Plan. Use the established protocols identified in the Fire Management Plan for minimizing resource impacts. Coronado National Forest Plan Amendment 11: In 2005, the Forest Plan was amended to incorporate the policies of the 2001 Federal Wildland Fire Management Policy and Review (USDI and USDA 2001). The amended Forest Plan calls for an appropriate management response to wildland fires. This includes appropriate suppression response and the ability to allow natural ignitions to play, as nearly as possible, their natural ecological role Forestwide (Forest Plan [1989], page 45).

3.10.2 Existing Conditions The Northwestern side of the Galiuro mountain range is made up of Semi-Desert grasslands and possibly some Madrean Oak Woodland. These landscapes are characterized by a mixture of grasses and forbs with scattered to dense patches of shrubs and trees. Much of the landscape within the area would be considered a fire condition class (FRCC) 3. Condition classes are how it is determined that a landscape has deviated from its natural fire regime (see appendix 1 for definitions of condition classes). While much of the landscape falls within a condition class 3 there have been a few fires over the last ten years that could have altered the landscape and made it a condition class 2. Both the Cake fire 400 acres in 2009 and the Copper Creek fire (618

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acres) in 2011, fall within the project area. The project is an area that experiences intermittent fire.

3.10.3 Environmental Consequences

1.1.1.1 Effects from No Action Under the No Action alternative, mineral exploration activities would not occur. No drilling would occur. Fire conditions would remain as they presently exists.

3.10.3.1 Effects from Proposed Action The Kennecott Corporations proposed Galiuro Exploration Drilling Project will have no effect to minimal effects on fire operations within the Galiuro mountain range. Effects and mitigation measures have been identified in other areas within this document.

3.10.3.2 Cumulative Effects Within the project area there are only 2 concerns for the fire organization. One concern is that the Galiuro Fire Scape is within the project area. This project is a 138,000 acre project that is broken up into 8 prescribed burn blocks that are intended to be completed over the next 10 to 15 years. The Cake RX burn block is the block that the proposed core drilling is to be completed in. This unit is proposed to be completed within the next 3 to 5 years and will require coordination between the fire organization and Kennecott to complete a plan of action. The other concern is the possibility of having a wildfire within the project area. As stated above this area is intermittent when it comes to wildland fire starts but it has had fires within the area that could affect the operations of both the USFS wildfire operations and the Kennecott core drilling operations. However, overall, it is expected the Kennecott Corporations proposed Galiuro Exploration Drilling Project will have no effect to minimal effects on fire operations within the Galiuro mountain range. Effects and mitigation measures have been identified in other areas within this document.

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4 Consultation and Coordination The Forest Service consulted the following individuals, Federal, State, tribal, and local agencies during the development of this environmental assessment: 4.1 List of Preparers

4.1.1 Present Forest Service Interdisciplinary Team Members Katie Vinzant Forest NEPA Coordinator (Supervisor’s Office) Richard Goshen Team Leader/Geologist (Supervisor’s Office) Rachel Cory NEPA Writer/Editor (Supervisor’s Office) Debby Kriegel Landscape Architect (Supervisor’s Office) Greg Olsen Hydro Geologist (Supervisor’s Office) Manuel Silva Minerals & Geology Program Manager (Supervisor’s Office) Matthew McGarth Acting Safford District Ranger Steven Lunt Range Staff Officer (Safford Ranger District) Everett Phillips Fire Management Officer (Safford Ranger District) Lance Koch Biologist (Safford Ranger District) Gwen Dominguez Range Staff Officer (Safford Ranger District) Tamar Mannikko Archaeologist (Safford Ranger District) Stephanie Emery Recreation Tech (Safford Ranger District)

4.1.2 Past Forest Service Interdisciplinary Team Members Lynette Miller Forest NEPA Coordinator (Supervisor’s Office) Rachel Hohl Forest NEPA Coordinator (Supervisor’s Office) Ryan Cole Team Leader/Geologist (Supervisor’s Office) Mindy Vogel Minerals & Geology Program Manager (Supervisor’s Office) Tracy Weber Acting Safford District Ranger Dana Carter Acting Safford District Ranger Kent Ellet Safford District Ranger Buddy Zale Fire Management Officer (Safford Ranger District) Dave Mehalic Forest Archaeologist (Supervisor’s Office) Carlos Gonzales Recreation Officer (Safford Ranger District) 4.2 Federal and State Agencies:

4.2.1 Federal: US Fish & Wildlife

4.2.2 State: Arizona Department of Environmental Quality Arizona Game and Fish 4.3 Tribes: Ak-Chin Indian Community Ft. Sill Apache Tribe Gila River Indian Community

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Hopi Cultural Preservation Office Hopi Tribe Mescalero Apache Tribe Pascua Yaqui Tribe Pueblo of Zuni Salt River Pima-Maricopa Indian Community San Carlos Apache Tribe Tohono O’odham Nation White Mountain Apache Tribe Yavapai-Apache Nation

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5 References

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Arizona Department of Water Resources (ADWR), 2016, Arizona Water Atlas – Lower San Pedro Basin, web access http://www.azwater.gov/AzDWR/StatewidePlanning/WaterAtlas/SEArizona/documents/Vol_3 _LSP_final.pdf

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Bultman, M. W., Drews, H., 1996, Mineral Resources, Ore Deposit Models, and Resource Potential of Coronado National Forest – Locatable Minerals, USGS Bulletin 2083-A-K

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Phoenix, Arizona: Arizona Game and Fish Department, Research Branch. ———. 2012. Peregrine Falcon Nest Site Monitoring in Arizona: 2012 Breeding-Season Results.

Phoenix, Arizona: Arizona Game and Fish Department, Research Branch. Available at: http://www.azgfd.gov/w_c/nongameandendangeredwildlifeprogram/Raptors/documents/PEFA M onitoring2012FinalReportforPublic.pdf Accessed December 16, 2015.

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———. 2009b. Big game species: White-tailed deer. Available at:

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———. 2014. FAQs: Santa Catalina bighorn sheep reintroduction program. Available at: http://azgfdportal.devaz.gov/PortalImages/files/bighornSheep/FAQs_CatBHS.pdf . Accessed December 22, 2015.

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Appendix A Draft EA Comments/Responses

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Table 11. Commenters and Oranizations They Represent, Letter Numbers, and Starting Page Name/Organization Letter Number Starting Page Bahr, Sandy/Sierra Club 1 Pg. 106 Featherstone, Roger/AMRC 2 Pg. 110 Best, Erik/KEC 3 Pg. 116 Chapin, Joseph 4 Pg. 116

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Table 12. Reseponses to Public Comments Submitted During the Draft EA Comment Period: September 28, 2017 through October 28, 2017 ID # Comment Response 1-1 Our main concern with the Draft EA is the lack of attention given Figure 2-2 depicts the proposed drills sites within the IRA and to the Galiuro Inventoried Roadless Area. There is not even a map spatial relationship to the wilderness area. The EA discloses of the IRA in the entire document! Roadless Areas provide many effects from the proposed project on the IRA in Recreation, societal benefits that should always be weighed when making section 3.8.3.3 Inventoried Roadless Areas. After mitigation decisions on public lands. measures are applied, no long-term impacts are expected. Additionally, the 2001 Roadless Rule allows for exploration of locatable minerals pursuant to the General Mining Law of 1872. 1-2 The EA should provide background on Roadless Areas, going back During the 2001 Roadless Rule process, the Coronado NF to their creation in the 1964 Wilderness Act, RARE 11 in 1977, and identified IRAs across the forest, including the IRA in the the 2001 Roadless Rule (and subsequent litigation) making Galiuro EMA. The purpose of an EA is to briefly provide protection of Roadless Areas what it is today. sufficient evidence and analysis for determining whether to prepare an environmental impact statement or a finding of no significant impact. The EA summarizes and discloses the effects of proposed actions on the human environment, and discusses those effects relative to intensity and context of the proposed actions as described in the definition of “significantly” at 40 CFR 1508.27 [36 CFR 220.7(b)(3)(iii)]. The scope of analysis is limited to actions proposed, not a discussion of the history of the creation of roadless areas. The EA discloses the effects from the proposed project in Recreation, section 3.8.3.3 Inventoried Roadless Areas. Additionally, the 2001 Roadless Rule allows for exploration of locatable minerals pursuant to the General Mining Law of 1872. 1-3 The “Need for Proposal” statement at the beginning of the EA Kennecott holds the Galiuro mining claim in which this project is makes no mention of other mining opportunities outside the IRA to located. Pursuaint to the General Mining Law of 1872, as negate the need for additional exploration. Is such exploration as amended and 36 CFR §228 subpart A, the Forest Service is Kennecott is proposing necessary at this time? required to process, administer, and manage mining operations conducted on National Forest System lands. 1-4 The EA makes no attempt to determine the fate of the Galiuro IRA At this time there is not enough information to consider a future and the subsequent environmental impacts should exploration mine as a foreseeable action on Forest Service lands, requiring its determine that there exists a viable mineral deposit. The Draft EA consideration as a cumulative impact. A future mine is also

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ID # Comment Response offers no thoughts as to a large mine two miles from the Galiuro outside the scope of this project and would require it's own Wilderness and what cumulative impacts such a mine would cause NEPA analysis. Please see section 1.4. to wilderness values and to the IRA. 1-5 Repeated noisy helicopter trips where there was no noise previously Biology - Effects of noise from helicopters and drilling is going to disturb and disburse wildlife. Drill rigs and noise are operations was disclosed and discussed in several portions of the going to affect hikers on trails in the wilderness, diesel engines will wildlife section of the environmental analysis and effectd to pollute, and night lighting if used will disturb wildlife. individual species can be found in chapter 3.4.3 in the environmental consequences section. Recreation - The closest drilling site is approximately 2 miles away from the wilderness boundary and nearest trail. As disclosed in Recreation section 3.8.3.3., Wilderness, the effects would be similar to other noise from roads and aircraft currently in the area. Night lighting is disclosed in Scenery section 3.5.3.3. Air Quality - The concern that diesel engines will pollute is addressed in chapters; • chapter 2.2.2 (Drilling and Related Activities) • chapter 2.2.4.5 (Solid Wastes) section SW-2 • chapter 2.2.4.6 (Water Quality) sections WQ-3, WQ-11 • chapter 2.4 (CNF Proposed Mitigation Measures) sections MM- 13, MM-14, MM-15, MM16, MM-19, and MM-22 • chapter 3.2 (Air Quality) of the Draft EA. Within section 3.2.3.3 (Effects from Proposed Action) • chapter 3.6 (Water Quality) sections 3.6.3.1 (Methodology); 3.6.3.3 (Effects from Proposed Action) • chapter 3.7 (Soils) sections 3.7.3.1 (Methodology); 3.7.3.3 (Effects from Proposed Action) ), and Water, Soil and Air Resources Report The EA and Air Resources reports acknowledges that project use of diesel engines results in emissions of seven air quality parameters. This project was discussed telephonically with ADEQ and ADEQ concluded that no air permit is required for the project. The EA also acknowledges that visibility in the

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ID # Comment Response Galuiro class I airshed, some 2 miles from the project, may experience an intermittent, temporary, small but incremental decrease in visibility. This visibility reduction is expected to be below any ocular perceptible level, but if numerically calculated would show an effect none the less. MM-24 requires assurance that the diesel engines used meet all applicable EPA emission standards, and also requires documentation that the engines operating on USFS lands are fueled with Ultra-Low Sulfur Diesel (ULSD) fuel. The EA and Water/Soil Resources reports acknowledges the potential for contamination from spillage of diesel engine equipment fluids. KEC provided a comprehensive material storage, handling and spill response plan. Additionally the USFS imposed mitigation measures; MM-13, MM-14, MM-15, MM16, MM-19, and MM-22 to address soil and water site pollutant management. These MM’s combined with KECs Spill Response Plan, and Proponent Proposed Environmental Protection Measures; FW-7 SW-3, SW-4, WQ-9, and WQ-13, will very effectively mitigate soils and water effects due to the proposed diesel engine operations. 1-6 Contaminated water from lower aquifers could migrate to upper The concern about the projects potential impact on springs are aquifers during drilling and pollute springs. found in chapter 3.6.3.3 (Effects from Proposed Action - Groundwater), as well as the Water Resources specialist report provided. With the available information, there are no numeric, analytical, technical or practicable ways to quantify the actual impact to any specific spring from the temporary drilling of a specific deep borehole, without actually drilling it. The USFS has used the best available geologic and water resource data and environmentally conservative assumptions to assess the potential risk to springs, and concluded that an unknown and unknowable risk of effects to springs is possible. To address these risks, the USFS has included Mitigation Measures MM-17 (artesian flows)

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ID # Comment Response and MM-20 (borehole abandonment). These mitigation measures provide assurances that any temporary hydraulic connection(s) to springs created during the drilling, would be fully mitigated by effectively and permanently plugging the borehole within several days after the exploration borehole is completed to depth. 1-7 Invasive plants could easily get a foothold with the sudden influx of Please see Mitigation Measures 4, 5, 7, and 13 in section 2.4 of workers and problems could occur if drill cuttings are buried on site the EA for a detailed description of the activities required of instead of being moved off the IRA. Kennecott to 1) minimize the potential introduction and spread of invasives through the cleaning of all equipment; 2) remove all non-native species from the disturbance footprints; 3) revegetate with native species to prevent weed infestations; and 4) utilize only weed-free erosion control materials. All of these measures should prevent the spread and colonization of invasive plants. 1-8 The EA insists that cumulative impacts will be small, and argues Under Chapter 3 of the EA each resource has a section that that projects such as the Coronado Plan Revision, the Travel discusses the potential cumulative impacts. None of these Management Plan, and the FireScape Project will seemingly offset discussions say that the Coronado Plan Revision, Travel any negative impacts from the exploration project. Management Plan, or Galiuro FireScape Project would "offset" negative impacts from this project, rather that the majority of the cumulative impacts are expected to be small or short term when added to the impacts of the project itself. 1-9 The Draft EA discusses various permits issued by the Arizona Per 36 CFR §228.5, the operator will comply with all Federal and Department of Environmental Quality (ADEQ) and the Arizona State laws prior to authorizing officer approving their plan of Department of Water Resources (ADWR), but does not say which operations. Please see MM-16 through MM-18. permits would be required for this particular project. 1-10 The consultant (SWCA) apparently found one archeological site in As discussed in section 3.3.3.3 the archealogical site was found the project area but there was no information as to its importance or to be outside of the project area and impacts are not expected. consequence. Section 3.3.2 provides information about the site. The significance of the site was not addressed because it will be completely avoided by project activities. MM-12 also ensures KEC will avoid this site. The site has not been fully evaluated to determine its eligibility for the National Register of Historic Places.

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ID # Comment Response 1-11 Problems could occur if drill cuttings are buried on site instead of Please see Mitigation Measures 20 and 21 in section 2.4 of the being moved off the IRA. EA for a detailed description of the process required of Kennecott to properly dispose of drill cuttings. If this process is not followed or the tests show that the cuttings are toxic or contain polutants the CNF has the final authority to decide if the cuttings may remain. 2-1 The EA is lacking in information on baseline conditions in the The purpose of the proposed action section of the EA is to proposed action area. While there is a discussion on general discuss the parameters of the project activities (i.e. who will do characteristics of the area, a discussion of baseline water and air what, when and where will it occur, and how will the actions be conditions that could be effected by this action are inadequate. The implemented). The baseline or current conditions can be found in EA needs to show clearly what conditions exist before an action is the individual resource reports, as noted in our response to approved as a measure to judge not only whether the action is likely comment 1-2, the EA is a summary document. Please see the to affect public lands managed by the US Forest Service and other Existing Conditions language in section 3 of the EA for a federal agencies, but also what specifics conditions are changed or discussion on each resource of the environmental impacts of the impacted if the action is approved. proposed action. 2-2 Additional alternatives (for example, an alternative that lowers the No specific number of alternatives is required or prescribed for number of drill holes or changing location to lessen the impact), an EA (36 CFR 220.7(b)(2)). NEPA requires that the agency should have been analyzed. study, develop, and describe appropriate alternatives to recommend courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available resources. If no unresolved conflicts exists, the EA need only analyze the proposed action and proceed without consideration of additional topics (36 CFR 220.7(b)(2)(i)). With the incorporation of the mitigation measures in section 2.4 into the proposed action, CNF specialists feel that resource conflicts have been addressed to the best extent possible. 2-3 The purpose and need section of the EA is simply a discussion that The EA must briefly describe the need for the project and discuss the Forest (according to your interpretation) must approve the the relationship between the desired condition and the existing drilling project. This is inadequate and should show how the public condition in order to answer the question, “Why consider taking would benefit from this exploration project potentially taking place any action?” . (36 CFR 220.7(b)(1)). The Mining Law of 1872 on our land. as ammended Sec. 2319 states that "All valuable mineral desposits in lands belonging to the United States...declared to be

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ID # Comment Response free and open to exploration and purchase...". Also, 36 CFR §228.1 states mining laws (30 USC 21-54) to enter upon public lands to serach for minerals is a statutory right and that operations shall be conducted to minimize adverse environmental impacts on NFS surface resources. CNF specialists feel that EPMs (Section 2.2.4 of EA) and MMs (Section 2.4) minimize these impacts. 2-4 The EA needs a discussion on who Kennecott is exploring on Please see sections 1.3, 1.4, and 2.2.2 of the EA for information behalf of, what they are exploring for, and what a successful pertinent to the comment. exploration effort might result in. 2-5 The EA should analyze the impacts this proposal would have to the The EA discloses the short term and long term effects from the IRA both in the short term and the long-term consequences should proposed project on the IRA in Recreation, section 3.8.3.3 this plan be approved and irrevocably alter the character of the IRA Inventoried Roadless Areas. After mitigation measures are applied, no long-term impacts are expected. 2-6 The EA is inadequate because it does not analyze the impacts from Five of the drill sites are located in the Galiuro Addition Potential the exploration plan on the IRA regarding its possible future Wilderness Area. However, as disclosed in Recreation section designation as a Wilderness Area. As the Forest well knows, IRAs 3.8.3.3 and Scenery section 3.5.3.3, no long-term impacts are are to be managed to retain the qualities making them eligible a expected. Therefore, any possible future designation as a Wilderness. Would this exploration plan change the IRA Wilderness Area would not be affected. Additionally, the 2001 designation or render the IRA ineligible for future Wilderness Roadless Rule allows for exploration of locatable minerals designation? pursuant to the General Mining Law of 1872. 2-7 There needs to be an analysis of the impacts of this plan on Pursuant to direction found at 40 CFR §1500.1(b) and 1500.4, the negative economic conditions. analyses presented in the EA are focused on those issues significant to the action being proposed and deserving of study. The potential direct, indirect and cumulative economic impacts of this project were considered, but found to be negligible and therefore, not discussed in the EA. In an attempt to clarify this, language has been added to the EA in section 3. 2-8 There is no discussion in this EA about cumulative effects. The Cumulative effects are covered in the EA in Chapter 3 in the possible impact of this project, especially if it would result in a various resource sections. A future mine is not considered a future mine, must be discussed and analyzed in this EA in light of reasonably forseeable action. Should the drilling project lead to a mine, the Coronado NF would review the proposal and conduct

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ID # Comment Response the fact that it would take place in an IRA that could in the future another environmental analysis (sec 1.4). In the EA, Recreation be designated as a Wilderness Area. section 3.8.3.3 and Scenery section 3.5.3.3, no long-term impacts are expected. Therefore, the project is not expected to change the potential for future designation as Wilderness. Language was added to Section 1.4. 2-9 The EA is inadequate in examining the impacts of this action on In order to address this comment, the Coronado NF used GIS to trails in the IRA. While the EA mentions that the proposal would be analyze the visibility to the proposed project location from hiking visible from trails, it does not mention which ones and the level of trails within 8 miles of the prposed project (note: the USFS's this impact. Scenery Management System considers anything over 4 miles as "background", a distance zone where only large patterns are distinguishable). The result shows that none of the drill locations would be visible from trails. 2-10 The EA does not thoroughly analyze the impacts of the proposal on The concern about the projects potential impact on springs are springs within and adjacent to the IRA. As above, the mention of found in chapter 3.6.3.3 (Effects from Proposed Action - possible impacts without a full discussion or analysis is not Groundwater), as well as the Water Resources specialist report appropriate. provided. With the available information, there are no numeric, analytical, technical or practicable ways to quantify the actual impact to any specific spring from the temporary drilling of a specific deep borehole, without actually drilling it. The USFS has used the best available geologic and water resource data and environmentally conservative assumptions to assess the potential risk to springs, and concluded that an unknown and unknowable risk of effects to springs is possible. To address these risks, the USFS has included Mitigation Measures MM-17 (artesian flows) and MM-20 (borehole abandonment). These mitigation measures provide assurances that any temporary hydraulic connection(s) to springs created during the drilling, would be fully mitigated by effectively and permanently plugging the borehole within several days after the exploration borehole is completed to depth. 2-11 The EA states that water would be supplied to the drilling pads by The proponent addressed the issue of potential waterline leakage the placement of up to 2 miles of water hoses. There is no and soil erosion WQ-8 in chapter 2.2.4 (Proponent Proposed discussion on how these hoses would be placed (by hand, by Environmental Protection Measures) of the draft EA within the

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ID # Comment Response helicopter, by mechanical means?), or what the impacts from the section 2.2.4.6 (Water Quality). While the USFS has specified placement and then removal of hoses on the Forest. Each hose metering of Mercer Well water delivered to Forest Lands via the should have a flow metering protocol to ensure that hoses are not pipeline (see MM-18), hauled water and metering on both source leaking during use which could change conditions to the Forest and delivery point(s) was not specified. Therefore, the USFS (including erosion, changing wildlife movement patterns or accepts the commenter’s suggestion, and has added modifications activities, or change the condition of soils and vegetation). A once a to Mitigation Measure MM-26, requiring metering, logging, week “walk” of the water line, as indicated in the EA is not monitoring and reporting of water transiting the pipeline as both a sufficient. If this project is permitted, a condition of the permit must water resource consumption / soil conservation measure, and as a be that all water hoses must be removed. pipeline leakage detection method. MM-26 was added to Section 2.4 of the EA. 2-12 The EA is not clear on where pumps would be located if needed to The issue of additional waterline booster pump stations are found boost water from storage tanks outside the IRA to the drilling in chapter 2.2 (Proposed Action) of the Draft EA within the platforms. Would these pumps be within the IRA? If so, how would section 2.2.1 (Access). The proponent has included a they get there? Would they be carried by hand, by helicopter, or comprehensive spill prevention and response plan attached to the other means? How would they be maintained? What would be the Plan of Operations, and these procedure would apply to all impacts of maintaining these pumps? Would there be a spill plan? engine equipment operations to be conducted under this proposed What would be done in the event or a fuel spill or accident? All of action on Forest Lands, including the additional booster pumps. this must be analyzed whether pumps were planned within the IRA or not. 2-13 The EA did not adequately discuss and analyze the impacts (all of The acknowledgement of potential water truck usage is located in them) from daily trips for a 3,000 gallon water truck to the water chapter 2.2 (Proposed Action) of the Draft EA, within the section storage area. Would travel be on Forest roads? If so, what would be 2.2.1 (Access). The Air Resource analysis is found in chapter 3.2 the impacts of this? If not, what would be the impacts to the IRA (Air Quality) of the Draft EA. Within section 3.2.3.3 (Effects and other public lands from dust, noise, etc.., from this travel? from Proposed Action), and acknowledges that off-forest vehicle travel on non-paved roads is a contributing source of fugitive dust. 2-14 The EA is silent on any details about the drilling project itself. It Thank you for your comment. Language was added to section must disclose, discuss, and analyze how deep holes would be 2.2.2 to clarify drilling actions. drilled, whether there would be multiple directionally drilled holes from each location and where those would go, the size of the hole, how the hole would be drilled, etc.

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ID # Comment Response 2-15 All drilling wastes should be removed from the drilling pads upon Mitigation Measure MM-16 was specifically developed to ensure completion of each hole. that no drill cutting or fluid waste would be discharged or released from the containment sumps and drilling pad. MM-20 requires that no drill cuttings are to be disposed of in the boreholes. MM-21 Details the sump sampling procedure and a comprehensive suite of laboratory parameters, the USFS will examine prior to instructing KEC to remove from Forest lands or encapsulate on-site the drilling wastes. Only wastes sufficiently demonstrated to not pose a risk to the environment would be permitted to remain on site. MM-21 is very specific in the sampling methodology, laboratory analyses to be conducted, and that the USFS will make the final determination on the final disposition in the waste. 2-16 Well holes must be invisible upon completion. Please see proponent mitigation measure WQ-12 and MM-20. 2-17 The EA states that the Invasive Species Control Plan and the The language in the EA has been amended for consistency, in Reportable Spill Response Plan would need to be incorporated into that, the control of invasive species will not be a separate plan, any permits should this project be approved. The public has a right but incorporated into the Reclamation Plan. A draft of this plan to comment on those plans before the project is approved will be posted along with the Final EA. 2-18 The EA’s discussion and analysis of the noise and impacts from the The anticipated impacts of noise and helicopter use are discussed high level of helicopter use is inadequate in section 3 of the EA under the Air Quality, Biological, Recreation, Wilderness, Inventoried Roadless Areas, and Range resource discussions. As noted in our response to comment 1-2, the EA is a summary document and a more detailed discussion of the impacts of noise and helicopter use can be found in the specialist reports. 2-19 The EA should consider the use of energy efficient (LED) lighting Thank you for your comment, this suggestion shall be passed to for the drill pads to limit the amount of diesel used and should also the project proponent. consider the use of solar or battery powered lighting 2-20 Any final permits granted if this plan is approved should require Please see Mitigation Measure-8 in section 2.4 of the EA. compliance with dark sky lighting standards especially since drilling would be within an IRA and near a Wilderness area

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ID # Comment Response 2-21 The EA includes a condition for treating water from a presumably Please refer to Mitigation Measure-18 in section 2.4 of the EA. contaminated well on the Old Mercer Ranch. It seems to us that it would be better to simply require that all water used for the project come from sources that are already certified for drinking water rather than the complicated procedures for treatment and reporting called for in the EA. 2-22 All sumps at the drilling pads must be lined The issue of lining the sumps at the drilling pads are found in chapter 2.2.4.5 (Solid Wastes) section SW-2; chapter 2.2.4.6 (Water Quality) sections WQ-11; chapter 2.4 (CNF Proposed Mitigation Measures) section MM-16. 2-23 The discussion and analysis in the EA on the plugging of drill holes The concern of the risk of aquifer cross-contamination and to prevent cross contamination of separate water tables is borehole abandonment is addressed and can be found in inadequate and must be redone to protect the water within the IRA. Chapters: Chapter 2.2.2 (Drilling and Related Activities) Chapter 2.2.4.6 (Water Quality) WQ-12 chapter 2.4 (CNF Proposed Mitigation Measures) sections MM- 17, MM-20 chapter 2.5 (Comparison of Alternatives) chapter 3.6 (Water Quality), section 3.6.3.3 (Effects from Proposed Action) The USFS has determined that there is virtually no risk of aquifer cross-contamination after the borehole is properly abandon in accordance with MM-20. With the available information, there are no numeric, analytical, technical or practicable ways to quantify the actual impact to any specific spring from the temporary drilling of a specific deep borehole, without actually drilling it. The USFS has used the best available geologic and water resource data and environmentally conservative assumptions to assess the potential risk to springs, and concluded that an unknown and unknowable risk of effects to springs is possible. To address these risks, the USFS has included Mitigation Measures MM-17 (artesian flows) and MM-20

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ID # Comment Response (borehole abandonment). These mitigation measures provide assurances that any temporary hydraulic connection(s) to springs created during the drilling, would be fully mitigated by effectively and permanently plugging the borehole within several days after the exploration borehole is completed to depth. This comment is an opinion and lacks "supporting reasons for the responsible official to consider" per 36 CFR 218.2. 2-24 The public should be able to comment on the fire plan, including A draft of the fire plan will be posted along with the Final EA. fire in the event of a helicopter accident or from the use of pumps or other equipment away from the drilling pads before the plan is approved 2-25 A new Environmental Assessment be release for public comment The CNF will release a Final EA that corrects deficincies and before this plan is approved. typos prior to the approval of the Plan of Operations. 3-1 The USFS has recommended a number of proposed mitigation Thank you for your comment. measures in the Environmental Assessment (Section 2.4; MM-1 to MM-25) that Kennecott adopts into their comments and agrees with. 4-1 Should mining occur, what type of mine will be employed? This comment is outside the scope of analysis of the EA (Section 1.4) 4-2 There is a potential for adverse contact/impact with hunters and The EA discloses impacts to hunters in Recreation, section their ability to take game while operations are underway 3.8.3.3. Game species pursued by hunters could be displaced from the area, which could negatively impact hunting success. 4-3 Should an event occur which causes a fire, who will be responsible The mining company would be responsible for suppression of for its suppression and how will it be carried out any fire started by this operation. The FS will be notified immediately of any fire ignition and the FS would coordinate any fire that would threaten resources off of the drill sites. 4-4 What is the approximate distance to the Galiuro Wilderness Area In section 3.2.1 of the EA there is a discussion that the Galiuro and what impact will the noise from helicopters and the operation Wilderness Area is approximately two miles away from the have on that area project area. As disclosed in Recreation section 3.8.3.3., Wilderness, the effects would be similar to other noise from roads and aircraft currently in the area.

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