Biological Evaluation Sensitive Flora and Fauna 2016

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Silver Standard Resources, Inc. Biological Evaluation For Sensitive Flora and Fauna 2016

PERDITO EXPLORATION PROJECT

NOVEMBER, 2016

Silver Standard Resources, Inc.

Perdito Exploration Project

BIOLOGICAL EVALUATION - 2016 FOR SENSITIVE FLORA AND FAUNA

1.0 INTRODUCTION

Cedar Creek Associates, Inc. (Cedar Creek) was retained in 2016 by Silver Standard Resources, Inc. (Silver Standard) to re-evaluate an historic exploration area near Conglomerate Mesa, California for sensitive fauna and to verify a sensitive floral survey that occurred in 1997 with follow-up surveys completed in 2014 by Mr. Mark Bagley of Bishop, California. Also in 1997, BHP Minerals International Exploration, Inc. (BHP) retained Kiva Biological Consulting (aka Mr. Peter Woodman of Bakersfield, California) to evaluate an area for faunal resources, the footprint of which appears identical to that of the current Perdito project, but was known at the time as the Conglomerate Mesa Project. To facilitate this work, Cedar Creek consulted with the Ridgecrest Field Office of the Bureau of Land Management (Ms. Caroline Woods) to coordinate locations for surveys and target flora and fauna.

At present, Silver Standard is proposing to conduct a drilling program in this remote area of Inyo County within Township 17S, Range 39E, Sections 3 and 4 on lands managed by the Bureau of Land Management (BLM), Ridgecrest Field Office. As indicated above, the proposed drill roads appear to be identical to those established, reclaimed, and revegetated in 2000, by BHP. In addition to these previously disturbed alignments, the BLM has provided a few alternate alignment segments and locations that occur on undisturbed native ground. Project area elevations range from 6400 to 7400 feet above MSL and climate is temperate continental (hot dry summers and cold dry winters) with average annual precipitation in the 6-inch range. Dominant vegetation of the area is largely black sagebrush scrub, but is transitional with desert (shadscale) scrub with pockets of single-leaf Piñon (and occasional California juniper) as scattered stands at elevation. Immediately to the east of the project across Santa Rosa Flat (shadscale scrublands) is a large area visually dominated by Joshua trees (Yucca brevifolia) a few of which extend into the project area.

2.0 METHODS

Prior to fieldwork in 2016, a list of potential sensitive fauna and flora that may be resident in the project area was compiled and evaluated for veracity of that potential (e.g., Western Grebe is not possible given the lack of open water in the project area). Sources included past survey efforts by Bagley and Woodman as well as an IPaC Trust Resource Report (1/18/16) from the US Fish & Wildlife Service. Also evaluated were California Dept. of Fish and Game information sources and most important, information provided by the BLM. California Natural

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Diversity Database searches were included with previous investigations so were not repeated in 2016. These efforts yielded the following fauna and flora (Table 1) with the potential for residence in the project area rated as “remote” or greater. Also indicated on Table 1 is the optimal survey window for each taxon (May provided the best coverage as indicated in red) as well as an indication of past observations of specific taxa.

Table 1 - Perdito Project - Taxa of Interest to the BLM - Survey Windows for Fauna (Primary Interest) and Flora (Secondary Interest) Fauna March April May June July Aug Sept Obsvd.* Golden eagle XXX XXX XXX Sharp-shinned hawk XXX XXX XXX XXX Cooper's hawk XXX XXX XXX Prairie falcon XXX XXX XXX XXX Loggerhead shrike XXX XXX XXX XXX XXX OOO Pallid bat XXX XXX Spotted bat XXX XXX Townsend's big-eared bat XXX XXX Western mastiff bat XXX XXX American badger XXX XXX XXX XXX XXX XXX XXX Nelson's bighorn sheep XXX XXX XXX XXX XXX XXX XXX Mountain lion XXX XXX XXX XXX XXX XXX XXX Panamint alligator lizard XXX XXX XXX Black swift XXX XXX XXX

Flora March April May June July Aug Sept Obsvd. Ericameria nana XXX XXX XXX Purshia mexicana var. dubia XXX XXX Cymopterus ripleyi XXX XXX XXX Erythranthe calcicola XXX XXX XXX XXX XXX XXX Oxytheca watsonii XXX XXX XXX Mentzelia inyoensis XXX XXX XXX XXX XXX XXX Perityle inyoensis XXX XXX XXX OOO Sclerocactus polyancistrus XXX XXX XXX XXX OOO Cryptantha tumulosa XXX XXX XXX XXX Astragalus cimae var. sufflatus XXX XXX XXX Alliuym atrorubens var. cristatum XXX XXX XXX OOO Boechera shockleyi XXX XXX OOO Erioneuron pilosum XXX XXX OOO Hecastocleis shockleyi XXX XXX XXX OOO Oenothera caespitosa ssp. crinita XXX XXX XXX XXX OOO * Taxa historically observed by either Woodman (fauna) or Bagley (flora) within the project area.

As indicated, the primary emphasis of 2016 surveys was an evaluation of sensitive fauna, however, a secondary emphasis was “verification” of the previous floral surveys, the most recent of which was by Bagley in 2014. In this regard, Table 2 indicates the “sensitive” status of the 15 floral taxa rated as having at least some remote potential for existence in the project area as well as an indication of those that have been observed in the area (bold print). Prior to 2016 field activities, a field guide to these 15 floral taxa was prepared and included photos, line drawings, taxonomic characters, habitat requisites, etc. to facilitate positive identification of any observed specimens while in the field. This field guide is included with this document as Appendix A.

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Table 2 - Perdito Project - Rare and Sensitive Plants - 2016

BLM/USFS CNPS Global State Scientific Name (Synonyms) * Common Names Status Rank Rank Rank Allium atrorubens var. cristatum Crested onion 4.3 G4T4 S4 Astragalus cimae var. sufflatus Inflated Cima milkvetch BLMS 1B.3 G3T3 S2 Boechera shockleyi Shockley's rock cress USFSS 2B.2 G3 S2 Cryptantha tumulosa New york mountain cryptantha 4.3 G4 S4 Cymopterus ripleyi var. saniculoides Ripley's springparsley BLMS 1B.2 G3G4T3Q S1 Ericameria nana dwarf goldenbush 4.3 G5 S4 Erioneuron pilosum Hairy erioneuron 2B.3 G5 S3 Erythranthe calcicola Limestone monkeyflower BLMS 1B.3 G2 S1 Hecastocleis shockleyi Shockley's prickleleaf 3 G3G4 S3S4 Mentzelia inyoensis Inyo blazingstar BLMS USFSS 1B.3 G3 S3 Oenothera caespitosa ssp. crinita Cespitose evening-primrose 4.2 G5T4T5 S4 Oxytheca watsonii Watson's oxytheca 2B.2 G3 S1 Perityle inyoensis Inyo rockdaisy BLMS 1B.2 G2 S2 Purshia mexicana var. dubia Mexican cliffrose G5 Sclerocactus polyancistrus Mojave fish hook cactus 4.2 G3 S3 * Bold print indicates observed in the project area.

From May 6th through May 8th 2016, Cedar Creek’s Senior Range / Wildlife Ecologist (Mr. Steven R. Viert) surveyed the Perdito project area for evidence or direct observations of the taxa indicated on Table 1. Weather was partly sunny with short periods of light rain and one short period of snow flurries with highs in the 50’s and 60’s. Winds were restricted to light breezy conditions at worst, calm at best. Surveys largely consisted of a series of pedestrian transects across the project area (as indicated on Map 1); binocular surveys of appropriate landscape features (cliffs, trees, volcanic rock outcrops, etc.) out to the 500 meter boundary for faunal habitats, nests, etc.; and a spotlight survey during evening hours for potential bat identification. A Garmin 650t Montana GPS was carried during all daily surveys to record pedestrian transects, with one exception. The exception involved the easternmost surveys implemented during the first day when the GPS battery failed and transects were necessarily recorded on detailed field maps. The GPS battery was replaced with new AA batteries purchased prior to the next field day. At the time of survey, alternative road alignments as proposed by the BLM had not been developed and therefore, were unknown to Mr. Viert. As a result, these alternative alignments were not directly surveyed in the field. To the contrary, Silver Standard’s proposed alignment that followed BHP’s old reclaimed road was the principal alignment for site-specific field surveys given the potential for direct impact. As such, a quick perusal of Map 1 indicates survey routes that either were directly on the proposed alignment, or were slightly uphill or downhill, but parallel to, the proposed alignment. Holding to this alignment facilitated a careful review of the previous disturbance footprint to see if new individuals of the 15 sensitive species had taken root over the intervening 16+ years, while allowing a review to either side for both floral and faunal observations.

Binocular surveys were completed using 10x50 Redfield optics (military quality) that provide an inordinate ability to gather light for searching dark grottos, caves, rock crevices, etc. for evidence of habitation by bats, raptor nests, or materials associated with wildlife use. Scans of rock outcrops and/or tree canopies occurred at

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approximate 200-meter intervals along each transect indicated on Map 1. In the northern half of the project area with significant numbers of Piñons, binocular scans were completed on approximate 100-meter intervals to facilitate multiple angle views of the various tree canopies for raptor nests. Scans typically occurred over a one or two minute period, but occasionally scan durations were increased to as much as four or five minutes depending on outcrop and tree density.

Spotlight surveys were completed during a single evening (6th) using a 1M candlepower spotlight with both flood and spot capabilities. This survey occurred from approximately one hour before to one hour after sundown. Given that the parking area on the eastern side of the project was in the lowest portion of the project area and within a canyon, it was determined to be the most conducive for making observations of any foraging bats. During the diurnal portion of this period, surveys for foraging bats and for flying insects (bat prey) were facilitated by the use of the aforementioned binoculars. The observer remained vigilant for any aerial or arboreal foraging activity by bats. As the ambient light declined and for the remainder of the survey, the spotlight was used intermittently in the attempt to catch any foraging bats in the beam to facilitate both observation and identification. More than intermittent use of the spotlight would have been inappropriate as bats tend to avoid bright lights. As such, the area was scanned for 30-45 seconds on approximate 5-minute intervals.

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Map 1 - Perdito - Biological Survey Routes - 2016 Legend ^ Location of Inactive / Abandoned Raptor Nest ! Locations of Additional Sclerocactus polyancistrus " Helicopter Staging Areas Alignment of Survey Routes in May 2016 Previous and Proposed Access Alignment (Currently Reclaimed and Revegetated) Alternative Access Alignment (Native Ground) 50 Meter Buffer for 2014 Floral Surveys 500 Meter Buffer for 2016 Faunal Surveys Claim Boundary

Miles ² 0 0.1 0.2 0.4

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"" Map 1 - Perdito - Biological Survey Routes - 2016 Legend ^ Location of Inactive / Abandoned Raptor Nest ! Locations of Additional Sclerocactus polyancistrus " Helicopter Staging Areas Alignment of Survey Routes in May 2016 Previous and Proposed Access Alignment (Currently Reclaimed and Revegetated) Alternative Access Alignment (Native Ground) 50 Meter Buffer for 2014 Floral Surveys 500 Meter Buffer for 2016 Faunal Surveys Claim Boundary

Miles ² 0 0.1 0.2 0.4

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"" 3.0 FINDINGS

Table 1 indicates 14 sensitive fauna and 15 sensitive floral taxa that were identified as having some potential (remote or better) as residents of the project area. However, according to Woodman (1997), and re-verified for this investigation, no wildlife species that are afforded protection under the Endangered Species Act exist within or near the project area. Several sensitive species were determined as possible inhabitants, but site-specific surveys, both in 1997 and 2016, verify that only a single wildlife taxon, Loggerhead shrike, is resident within (or near) the project area. Conversely, and verified by Cedar Creek in 2016, Bagley (2014) found 7 of 15 sensitive floral taxa identified as possible inhabitants within the project area and include:

• Allium atrorubens var. cristatum Crested onion • Boechera shockleyi Shockley’s rock cress • Erioneuron pilosum Hairy erioneuron • Hecastocleis shockleyi Shockley’s prickleleaf • Oenothera caespitosa ssp. crinita Cespitose evening-primrose • Perityle inyoensis Inyo rockdaisy • Sclerocactus polyancistrus Mojave fish-hook cactus

Although the timing of Cedar Creek’s surveys in 2016 was not ideal for the detection of all these floral taxa, it was adequate to document the veracity of Bagley’s surveys and findings. Cedar Creek’s biologist visited the coordinates recorded by Bagley for several of his observations (Map 2) and following a brief search was able to relocate multiple specimens of Sclerocactus polyancistrus (typically budding) and Perityle inyoensis (not flowering). Only a single specimen of Boechera shockleyi (not in flower) could be relocated by these verification re-surveys, but this is a rather diminutive plant and easily overlooked without flower stalk and showy flower. In addition to verifying Bagley’s previous observations, Cedar Creek located several additional Sclerocactus polyancistrus plants and recorded the GPS coordinates of their locations.

In addition to the seven taxa documented by Bagley (2014), Cedar Creek also observed several specimens of Purshia mexicana (Mexican cliffrose) along the wash bottom access corridor leading into the project area. The taxonomy of this species with regard to the varietal dubia is inconsistent across many databases so a positive identification was not possible in the field and because the plants were not in flower matters were complicated further. However, given identification by a previous BLM botanist of Purshia mexicana var dubia in the area, it is likely that this species is present. The Mexican cliffrose observations by Cedar Creek occurred along the very eastern edge of the project area. It was estimated that a few scattered individuals extended about two hundred

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!( !(!( Map 2 - Perdito - Floral Survey Results - 2014 ") ") Legend ! ")") 50 Meter Buffer for 2014 Floral Surveys ")") Claim Boundary ")!(") ") Special Status Plants !(")") ! ")")!(")!( ") Allium atrorubens var. cristatum !( ")!( ")")")!(")") !( ")")")") !( Boechera shockleyi !( !(!( ")")") !( XW Erioneuron pilosum ")") ")") ") !( ") Hecastocleis shockleyi ")!( ") ") XW Oenothera caespitosa ssp. crinita !( ! Perityle inyoensis ") ") !( !(!(!( !(!(") ") !( !( Sclerocactus polyancistrus !(!(!( ") !( ")!(")!(")!( ") ") !(!(!(")") !( Miles !(!(!( ") ")!( 0 0.075 0.15 0.3 ² !(!( !(!(!(!( !(XW!(!(") ")XW")!(!(")!( !(") ")!(!(")")!( !(!( !(") !(!(!( !(!(") !( !( !( !(!( !( !(")!(!( !( !( !(!(!( !( !(")!( !( !( ")!(")!( !( !( !( !(!( !(! ") !(!!!( ") XW")") !!( !(!!(") !( ! !( !(!(!(") !(!(") !( !(!(")")") ") !( ")!(!(")")")")!(!(!(!(!( !(!(")")")")!(")!(!(!(")")!(!( ")!(") ")!(!( !( !(")!(")")")")")!( ") !(!(!(!( ")!( !( !(")") !( !( !(!( !( !( !(!(!(")!( !( !( !( !( !( !(!(!(!( !( !( !( !(!(!(") !(")!( ")")!(!( ") ")!(!( !( ")!(")!( !( XW ")!(!( ") ")!( !( ")!( ") !(!( !(

!( !( ") ") !( ")!( !(!(!(!(XW ! !( !( ! ! !( !( !(!( !!!!!! !(! ")") ! !! !( !( ") !(!( ! !(")") ") !(!(!( !( !( !( !( !(!(!(!( XW !( !( !(!( !( !(!( !( !( !( !(!( !( !(!(!( !( !( !(!( !( ! ! !( !( ! !(!(!( !( ! ! !(XW") !( !( !( !(!( !( !( !( ") !( !(!(!( !(!( !( !! !( !(!( !( !(!( ! !( !(!( !(!( !( !( !(!( !( !(!( !(!( !( !( ")")") !(!(!( !( !( !( !(!(!( !( !( !( !(!( !( !( !(!( !( !( !( !( !(!(!( !( !( !( !( !( !( !(!( !( !( !(!(!(!( !( !( !(!( !( !( !( !( !( !( !(!(!( !( !( !( !(

!( !( !( !( ") !( !( !(")") !(!( ")") !( !( !(!( Map 2 - Perdito - Floral Survey Results - 2014 ") ") Legend ! ")") 50 Meter Buffer for 2014 Floral Surveys ")") Claim Boundary ")(!") ") Special Status Plants !(")") ! "")) !()"(! ") Allium atrorubens var. cristatum !( )"(! ")")")!(") ") !( "))"")") !( Boechera shockleyi !( (!!( ")")") !( XW Erioneuron pilosum ")") ")") ") (! ") Hecastocleis shockleyi ")!( ") ") XW Oenothera caespitosa ssp. crinita (! ! Perityle inyoensis ") ") !( !(!(!( !(!(") ") !( !( Sclerocactus polyancistrus !(!(!!(( ") ") !( ")!(")!("!)( ") !((!(! ")") !( Miles (!!(!( ") ")!( 0 0.075 0.15 0.3 ² !((! !(!( !(!( !(XW!(!(") ")XW")!(!(")!( !(") ")!(!("")) !( !(!(!( (!") !(!( !((!") !( !( !( !(!( !( !(")!( !( !( !( !( !(!( !( !(")!( !( !( ")!(")!( !( !( !(!( !(! ") !(!!!( ") XW")") !!( !( !!(") !( ! !( !(!(!(") !(!(") !( !(!(")")") ") !( ")!(!(") ") ")")!(!(!(!(!( !(!(") ") ")") !(")!(!(!(")")!( !( ")!(") ")!(!( !( !(")!(")")")")")!( ") !(!( !(!( ")!( !( !(")") !( !( !(!( !( !( !(!(!(")!( !( !( !( !( !( !(!(!(!( !( !( !( !( !(!(") !(")!( ")")!(!( ") ")!(!( !( ")!(")!( !( XW ")!(!( ") ")!( !( ")!( ") !(!( !(

!( !( ") ") !( ")!( !((!!( !(XW ! !( !( ! ! !( !( !( !( !!!! !(! ")") ! !! !( !( )" !(!( ! !(")") ") !(!(!( !( !( (! !( (!!((!!( XW !( !( !(!( !( !((! !( !( !( (!!( !( !(!((! !( !( !((! !( ! ! (! !( ! !((!(! !( ! ! !(XW") !( !( (!(! !(!( ") (! !( !( !!(( !( !(!( !( !! (! !(!( !( (!!( ! !( !(!( (!(! !( !( !(!( !( !(!( !(!( !( !( ")")") !(!(!( !( !( !( !(!(!( !( !( !( !(!( !( !( !(!( !( !( !( !( !(!(!( !( !( !( !( !( !( !(!( !( !( !(!( !(!( !( !( !(!( !( !( !( !( !( !( !(!(!( !( !( !( !(

!( !( !( !( ") !( !( !(")") !(!( ")") !( meters into the project area along the wash bottom, but the majority of observations occurred to the east (also along the wash bottom).

As appropriate, specific findings with regard to each sensitive taxon will be addressed individually in sections to follow. However, general findings and observations resulting from Cedar Creek’s surveys are detailed immediately below.

3.1 General Findings and Observations

Following intensive binocular surveys of cliffs and tree habitat within the 500-meter buffer zone, only a single raptor nest was observed (Map 1). This nest was constructed on a ledge of a volcanic cliff face and appeared sufficiently sizeable to be that of a buteo (red-tailed hawk or golden eagle). Given an inability to determine scale, an accurate estimate of true size is difficult. It is possible that this was a raven nest, but unlikely. Access to the nest, or to an area above the nest, was not safely possible so verification of size, construction materials, evidence of recent use (fresh sticks, prey bones, etc.) was not possible. Review of the ground below the nest cliff revealed no evidence of the aforementioned indicators of nest ownership and no indicators of recent use. Given the best binocular perspective of the nest and the surrounding rock ledges, no whitewash, either recent or old, could be observed and therefore, the determination was made that the nest was inactive. Given Cedar Creek’s observation of extremely low prey density for buteos (cottontails, ground squirrels, etc.), it was hypothesized that this nest was a “false-start” nest, probably by a young and inexperienced dispersant. Following realization that prey was scarce, the nest would have been abandoned.

During the three days of survey, only a single raptor was observed. This observation was of a fly-over red- tailed hawk at sufficient elevation that a positive determination of age was not possible, even with 10x binoculars. However, it was not an immature of the year and was in transit from south to north. It took a straight-line course across the project area at significant elevation indicating it was in transit through the area and not hunting or nesting.

Including the red-tailed hawk, the following fauna were observed:

• Woodrat (likely Desert) old middens observed • Coyote scat / shallow exavations • Kangaroo rat characteristic burrow colony • Desert cottontail old pellets • Black-tailed Jackrabbit old pellets • Mule deer tracks and pellets • W-tailed antelope ground squirrel direct observation • Red-tailed hawk direct observation • Loggerhead shrike direct observation • Common raven direct observation • Cassin’s vireo direct observation • Broad-tailed hummingbird direct observation

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• American robin direct observation • Scrub jay direct observation • Unid. Sparrows direct observation • Desert spiny lizard direct observation • Sagebrush lizard direct observation

Given the several miles of pedestrian transects across the project area, observations of wildlife sign were notably scarce indicating only modest use of the project area by otherwise common wildlife species. In this regard, fewer than a half-dozen Kangaroo rat colonial burrows were noted, as were six shallow excavations by a carnivore (canid not badger), and seven coyote scats (only one was recent, the remainder were 3-5 years old). Desert cottontail pellets were very scarce (and old) and black-tailed jackrabbit pellets (also old) were only observed twice; both species being along the north-south trending ridge on the west side of the project. White- tailed antelope ground squirrels were observed in the Santa Rosa Flats to the east of the project, but not within the project boundaries. Only a few species of avifauna were observed (as listed above), and densities were low for mid-Spring.

Reptile observations were also quite scarce with only a single Desert Spiny (dark phase) and five Sagebrush Lizards observed*. Given the difficulty in non-destructive capture of active lizards for in-hand examination, the identification of these taxa can only be considered 95% confident. However, both lack of habitat (riparian and related) and sufficient time for binocular observation facilitated the determination that no reptiles observed in the project area presented with “tiger striping” indicative of the Panamint Alligator Lizard.

The most notable observation was an unexpected density of mule deer pellet groups within the north half of the project area (Piñon pine area) suggesting that the principal prey species for Mountain Lion may be marginally adequate to support this taxon. In this regard, a total of 32 pellet groups (of varying age, but mostly recent) were observed along approximately two miles of transect. This density and the observed distribution of pellet groups suggests that a small herd of 3-5 animals utilized the northern portion of the project area for a few days over the past year, and has utilized this area in the past. Although sparse, this density of deer would be marginally adequate to facilitate inclusion within the fringe of a large home range (perhaps 200+ mi2) of a resident lion. In other words, the project area could be hunted by a lion, but it would be far from a preferred hunting ground.

In addition, the observed pellet groups were carefully examined given that mule deer and bighorn sheep scats can be similar and both could exist in the project area. General observations of pellet size, shape, quantity, conformity, etc. led to the high-probability conclusion that they were evidence of mule deer. Furthermore, although mule deer and sheep diets overlap, examination of several pellets indicated a diet high in browse species (woody forage) and low in grasses as is typically found in mule deer pellets. This also led to the

* Depending on local variants, it is possible these were Western Fence Lizards.

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conclusion that the pellets were from mule deer and not desert bighorn (which typically show a reverse ratio between browse and grass composition).

In addition to recording faunal observations and sensitive plants, Cedar Creek’s biologist recorded the more dominant flora of the project area. These include:

• Single-leaf piñon pine Pinus monophylla • California Juniper Juniperus californica • Joshua tree Yucca brevifolia • Black sagebrush Artemisia arbuscula nova • Shadscale Atriplex confertifolia • Spiny hopsage Grayia spinosa • Spiny menodora Menodora spinescens • Little-leaf horsebrush Tetradymia glabrata • Green rabbitbrush Chrysothamnus viscidiflorus • Nevada jointfir Ephedra nevadensis • Budsage Artemisia spinescens • 4-winged saltbush Atriplex canescens (revegetated) • Pygmy cedar Peucephyllum schottii • Winterfat Krasheninnikovia lanata • California buckwheat Eriogonum californicum • Great-basin wildrye Elymus cinereus (revegetated) • Galleta Hilaria jamesii • Indian ricegrass Oryzopsis hymenoides (revegetated) • Sandberg bluegrass Poa secunda • Crested wheatgrass Agropyron cristatum (revegetated) • Needlegrass Stipa sp. (revegetated) • Red bromegrass Bromus rubens • Desert princesplume Stanleya pinnata • Desert trumpet Eriogonum inflatum • Desert globemallow Sphaeralcea ambigua • Green molly Kochia americana • Hawksbeard Crepis sp. • Indian paintbrush Castilleja chromosa • Broomrape Orbanche sp. • Beavertail prickly pear Opuntia basilaris • Popcorn flower Cryptantha sp. (not tumulosa) • Phacelia Phacelia sp.

During Cedar Creek’s pedestrian surveys that overlap the old road alignment (now reclaimed and revegetated), several observations are noteworthy. First, the return of the disturbed surface to approximate original contour (AOC) was judged an excellent effort. Cedar Creek’s personnel have witnessed many hundreds of miles of reclaimed drill road disturbances and must rank this effort among the very best. There were few “lips or banks” left and one could walk from undisturbed to disturbed without issue. Second, revegetation of the disturbed footprint was progressing in a reasonable manner, given the desert conditions. However, this process will take many decades before it is visually and fully mitigated. Unfortunately, species selection for the revegetation effort was not the best given that 4-winged saltbush, great-basin wild rye, and crested wheatgrass

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among others were used that are not native to this area. Therefore, these species stand out visually (as does the disturbed soil) despite an excellent effort at replacing the AOC. Future reclamation efforts should use site-specific taxa and Cedar Creek could readily provide several recommendations for both species to use, amounts and methodology for application of seed, etc. A final observation of note was that there has been modest reinvasion by native site-specific taxa (e.g., Joshua trees, galleta, etc.), however, there has been no notable reinvasion by the area’s sensitive floral species. This latter observation provides excellent justification for re-use of this alignment (versus the alternative alignments) for the proposed project as such re-use will preclude adverse impacts to the area’s sensitive plant populations.

3.2 Specific Findings and Observations

Golden Eagle – As indicated for the general discussion regarding the observed raptor nest, the project area provides a very poor prey base for large buteos like Golden Eagles. Based on the number of pellets observed, too few rabbits (either cottontail or jack) are resident in the area to support a successful nesting pair of eagles. Furthermore, ground squirrel populations are non-existent excepting for a few white-tailed antelope ground squirrels that were observed in the Santa Rosa Flats, several miles to the east of the project area. Other potential prey that are resident in the area are nocturnal and their populations are diminutive. Despite significant nesting opportunities extant in the area, both nesting and prey base must be present and adequate to facilitate residency by Golden Eagles. Given that a few prey animals are occasionally resident in the project area, it is possible, but with low probability, that golden eagles could be observed hunting in the area.

Sharp-shinned and Cooper’s Hawks – The single-leaf piñon and California juniper stands in the area are far too thin to support the prey base necessary for these arboreal raptors (as is readily visible on either Map 1 or Map 2, note the scattered distribution of trees). Furthermore, following extensive and thorough binocular searches, no raptor tree nests were observed. It’s possible that a transient hawk may pass through this area and harvest an occasional passerine, but there is no other prey base suitable to support either or both of these two species.

Prairie Falcon – As indicated above for Golden Eagle, the project area provides many nesting opportunities for this raptor, but the prey base is woefully inadequate to support a successful resident. Furthermore, no aeries typical of this raptor were observed anywhere in the cliffs of the project area. The only stick accumulations in rock crevices were at the bottom of cliffs and were judged to be woodrat middens given the materials present.

Loggerhead Shrike – Of the sensitive fauna indicated on Table 1, this species was the only one observed in the project area. In that regard, the vast majority of observations (8 - 10 per day) were in the 2-3 miles immediately before the boundary of the project area, and these observations of shrikes comprised the majority of avian observations in this area. Other passerines in this area (3 - 4 per day) appeared to be sparrows, however, the species of sparrow could not be determined while driving, and did not seem important enough to investigate so CEDAR CREEK ASSOCIATES, INC. PAGE 11

far from the project boundary. Within the boundaries of the project area only a single shrike was observed, and this observation was in the wash bottom about 200 meters into the project area. Shrikes are year-round residents in this area.

Bats (Pallid, Spotted, Townsend’s big-eared, and Western Mastiff) – Surveys specific for bats yielded zero results. The evening spotlight survey not only yielded no bats, but it showed very few flying insects such as moths (prey base). In this regard, only 3-4 flying insects were observed over a 2-hour period. Furthermore, during all pedestrian surveys it was noted that the project area insect population was significantly depauperate with only a scattered few (half dozen) ground dwelling insects comprised of the occasional small grasshopper or beetle. Significant time was expended scanning the thousands of cracks, crevices, caves, and holes in the volcanic cliffs and rocks scattered across the area to ascertain if any of these areas harbored roosting bats (as evidenced by guano accumulations). Nothing was observed. Given the poor prey base, it is doubtful that more than one or two bats could find sufficient prey to survive in this area. When leaving the site after dark on May 6th, Cedar Creek’s biologist observed a single small bat in the headlights (about 8-10 miles from the project area). The bat was only observable for a few moments, was very small, and presented as a pipestrelle, most likely a western pipestrelle.

American Badger – Pedestrian surveys across project area habitats yielded only six shallow excavations by a carnivore and these were determined to have resulted from coyote activity as opposed to badger. Coyote excavations (excepting dens) are generally shallow and oval in a vertical orientation (like those observed on site). Badger excavations are generally deeper with significant extracted material, and are oval in a horizontal orientation. Furthermore, as discussed for several other taxa, the prey base for badger is very thin and depauperate. In addition, soils of the project area are generally stony and shallow which precludes most deeper burrowing rodentia, the primary prey for badgers. No other evidence of badger use of the project area was noted during surveys, and it would not be expected.

Nelson’s Big Horn Sheep – The Inyo mountains have a known population of Desert Bighorn, but such populations are affiliated with available water (springs and/or seeps) during the hot and dry summer periods. Bighorns are more readily dispersed during winter months, but site-specific surveys yielded no evidence of use (beds, pellet groups, heavy grazing on grass clumps) within the project area. As previously discussed, the observed pellet groups were determined to be mule deer and not sheep. Because there is no source of water within reasonable proximity to the project area, it is not anticipated that bighorn would be observed in this area other than as possible transients.

Mountain Lion – the local population of mule deer estimated to occur in the project area and environs is marginally adequate to support occasional hunting by the lion whose territory overlaps the project. Given that this lion likely has a large home range (200+ square miles), a temporary disturbance due to drilling activity may

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go largely unnoticed. Furthermore, if the mule deer are modestly displaced during operations, so to would any resident lion as they typically harvest about one deer every two weeks (on average).

Panamint Alligator Lizard – As indicated under the general discussion above, only two species of lizard were observed on site, Desert spiny and Sagebrush (and/or Western Fence). None of these present with the “tiger striping” of the alligator lizard. Furthermore, there are no riparian habitats, springs, or seeps anywhere near the project area and as such, habitat does not exist for the Panamint Alligator Lizard.

Black Swift – As indicated for the Panamint Alligator Lizard there are no riparian habitats, springs, or seeps that exist anywhere near the project area. Given this circumstance, there can be no habitat for the black swift that prefers nesting on cliffs above such riparian areas.

Bagley’s Findings – As noted previously, Cedar Creek verified Mark Bagley’s work from 2014 in two ways. First, about a dozen coordinate locations indicated by Bagley (Map 2) were re-visited by Cedar Creek and with modest effort, the plants originally located by Bagley were again found (some still exhibiting flagging). Second, close examination of these plants in the field in comparison to Cedar Creek’s “field guide” developed for this project (Appendix A) indicated that they were in fact correctly identified. This verification occurred in a more or less random manner excepting that mapped plants near the alignment were selected as opposed to plants more distant laterally. This was possible given that all coordinates as indicated on Map 2 were downloaded into the GPS carried into the field by Cedar Creek. Excepting the first day when battery power issues occurred, Cedar Creek’s biologist was able to view on the GPS screen the previous mapped location and taxon for each of Bagley’s discoveries. Then at differing times and locations, Bagley’s plants were sought and verified. Cedar Creek’s biologist was able to relocate multiple specimens of Sclerocactus polyancistrus (typically budding) and Perityle inyoensis (not flowering). Only a single specimen of Boechera shockleyi (not in flower) could be relocated, but this is a rather diminutive plant and easily overlooked without flower stalk and showy flower. Additional specimens of the aforementioned three species or differing taxa found by Bagley were not sought as confidence in his work had been validated.

On occasion, Cedar Creek’s biologist happened across additional specimens of Sclerocactus polyancistrus that had not been identified by Bagley and recorded GPS coordinates for these specimens. Typically, these were external to Bagley’s search area, but not always. Often, a single GPS location was recorded for multiple specimens within close proximity to one another. For example, the first two sites and the 4th and 7th were each of a single plant. The 3rd was a group of 3, the 5th was a group of 2, the 6th was a group of 4 and the 8th was a group of 5 cacti. In total, an additional 18 cacti were documented. It should be noted that flowering was estimated to be between 1 and 2 weeks following the survey period given the stage of flower bud development. As such, it is anticipated that hundreds, perhaps thousands of additional observations of the Mojave fish-hook cactus could have occurred within the project area assuming surveys had occurred at a later time. Similarly, it is

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anticipated that many additional observations of the other sensitive species found by Bagley, could have been added to this compilation. These findings suggest that at least locally, many target taxa are more common than the typically sparse and scattered individuals of plants designated as “sensitive”.

Woodman’s Findings – Cedar Creek was not requested to verify Woodman’s findings, but supplement his two decades old findings. As such, a discussion comparing the two surveys (Cedar Creek’s and Woodman’s) seems appropriate. Neither Woodman nor Cedar Creek recorded significant numbers or diversity of local fauna, thereby indicating that the project area exhibits lower quality habitats for area wildlife. In fact, Woodman indicated that: “the site does not appear to be densely populated by wildlife, especially small rodents”. And, “rodent holes were not common anywhere on the site.” Further, “the lack of water on the project site also restricts the number of species that may be found.” Woodman documented 2 reptiles, 12 birds, and 7 mammals (shown in Appendix 1 of Woodman 1997) during his surveys of 1996 and 1997. Cedar Creek documented 2 reptiles, 8 birds, and 7 mammals during the 2016 surveys. Eight of these species were in common, but given that Woodman performed multi-seasonal surveys and small mammal trapping in addition to pedestrian transects, the modest difference is readily explainable.

Both investigators observed a single old stick nest that could potentially belong to “either a red-tailed hawk or common raven”. Woodman indicated his nest observation was “on a ledge in the rock cliffs in the Central Resource Area” therefore, it is possible, even likely, that this is the same nest, observed by Cedar Creek. However, no mapping is available in Woodman’s report to verify this hypothesis. Assuming it is the same nest, Woodman found it to be in disrepair and inactive in 1996, a condition that continues to the present (over a period of 20 years). Woodman also indicated negative results for bats, however, his surveys occurred during a low probability time of year. Regardless, his searches for guano and/or urine stained grottos in project area rock outcrops were negative as were Cedar Creek’s binocular surveys. Therefore, it is very unlikely that bats utilize the project area to an extent greater than the occasional transient.

The only sensitive faunal taxon observed by Woodman and by Cedar Creek was loggerhead shrike. Cedar Creek observed more shrikes in 2016 than Woodman in 1996/97. There are many possible explanations for this difference, with one of the more plausible being: the population in the area is stable at a minimum or increasing.

Overall, Woodman’s and Cedar Creek’s findings are very consistent and corroborate each other with a high degree of confidence. Similarly, Cedar Creek found Bagley’s surveys and findings to be highly accurate, correct, and competent.

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4.0 ASSESSMENT and RECOMMENDATIONS

As indicated on Map 1, Cedar Creek’s surveys overlapped the proposed alignment that in turn overlaps BHP’s previous alignment that has since been reclaimed to approximate original contour and revegetated. The short alternate alignment segments proposed by the BLM (in the southern part of the project area) had not been identified prior to Cedar Creek’s site surveys, therefore, surveys specific to these route segments did not occur. However, both Woodman’s and Cedar Creek’s faunal survey footprints visually covered these areas and there is nothing unique or unusual about these alternate alignments from a wildlife perspective (i.e., there is no difference between the proposed and the alternate alignments excepting the previous disturbance that has since been reclaimed). Therefore, it is Cedar Creek’s opinion that neither alternative will have more than a negligible direct impact on local fauna and their habitats.

With regard to the increased traffic and human activity in the area, there may be some modest indirect effect on local shrike populations (displacement of individuals for a short distance), however, such displacement is not anticipated to be long-term nor deleterious to those individuals. In fact, the surveys by Woodman, Bagley, Cedar Creek, and BLM personnel would likely yield an equivalent level of impact to shrike populations and/or individuals. Such impacts could / should be judged as inconsequential or non-existent.

To the contrary, because site-specific surveys for sensitive flora did not occur on the BLM alternate alignments, it cannot be stated with certainty, but can be hypothesized, that a modest direct impact to sensitive flora will occur given the relatively extensive and dense populations extant in the area (based on Bagley’s and Cedar Creek’s surveys). It is likely that some members of these sensitive taxa exist within or very near the BLM alternate alignments and as such could or would be subject to direct impact. This condition does not exist for the proposed alternative (previously disturbed and reclaimed alignments) because site-specific surveys have documented the observation that sensitive taxa have not reinvaded these areas after a period of at least 16 years.

Regardless of alternative, the loss of a few specimens of sensitive plants should be considered statistically insignificant to local populations, especially those that number in the hundreds, thousands, or more. Furthermore, loss of a few specimens would be negligible to overall populations given that these taxa exhibit distributions elsewhere in California and often several other states. For example, Sclerocactus polyancistrus is known from four counties in California and three counties in Nevada. The IUCN Red List indicates that this taxon “has a wide range and occurs in inaccessible areas and in protected areas.” “No major threats are known, hence it is listed as Least Concern.” The population is also listed as “stable”. Furthermore, the IUCN states that “no major threats to this species are known.” Similar findings exist for all the other sensitive taxa that have been observed on site.

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If this analysis is insufficient to address these negligible impacts and document that they do not warrant further consideration, or the BLM is not in concurrence with this opinion, a simple measure could be applied to mitigate any potential for impact to sensitive floral taxa. This measure would involve a bio-monitor (biologist) surveying routes of travel for subject plants immediately in advance of mechanized equipment. The bio-monitor could then flag the location of observed specimens to facilitate avoidance, or, if avoidance is impractical or impossible, could oversee transplantation of any specimens out of harm’s way. This is a common mitigation measure that has been used successfully on many occasions in the Western U.S.

There are two additional mitigation measures that Cedar Creek would recommend for preclusion of general resource damage: 1) access control, and 2) reclamation with proper seed mixes. The first of these would involve installation of controls to preclude access to the site by the general public until disturbances have been reclaimed and revegetated. The second would be Cedar Creek’s recommendation that reclamation of new disturbances occur with metrics and seed mixes that are conducive to replacement of AOC (similar to what occurred for BHP’s disturbances) and with seed mixes that are comprised of local taxa such as galleta and black sagebrush. If local taxa are used for revegetation, the visual impact of reclaimed drill roads will more rapidly diminish with time.

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4.0 REFERENCES CITED OR CONSULTED

Bagley, Mark. 2014. Unpublished results from floral surveys of the Perdito project area. GIS and Excel files.

California Department of Fish and Game. 1995. Endangered and threatened animals of California. Calif. Dept. Fish and Game, Sacramento, CA.

California Department of Fish and Game. 1996. Natural diversity database list of special animals. Calif. Dept. Fish and Game, Sacramento, CA.

Remsen, J. V., Jr. 1978. Bird species of special concern. Calif. Dept. of Fish and Game, Sacramento, Ca.

Williams, D. F. 1986. Mammalian species of special concern. Calif. Dept. of Fish and Game, Sacramento, Ca. Admin. Report 86-1.

Woodman, Peter. 1997. Vertebrate Survey for a Proposed Drilling Program in Inyo County, California. Unpublished report to BHP Minerals International Exploration, Inc. 20 pp.

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EXHIBIT A

FIELD GUIDE OF SENSITIVE FLORA POTENTIALLY IN THE PERDITO PROJECT AREA

BLM CNPS Global State USFS Scientific Name (Synonyms) Common Names Status Rank Rank Rank

Allium atrorubens var. cristatum Crested onion 4.3 G4T4 S4

Astragalus cimae var. sufflatus Inflated Cima milkvetch BLMS 1B.3 G3T3 S2

Boechera shockleyi Shockley's rock cress USFSS 2B.2 G3 S2

Cryptantha tumulosa New york mountain cryptantha 4.3 G4 S4

Cymopterus ripleyi var. saniculoides Ripley's springparsley BLMS 1B.2 G3G4T3Q S1

Ericameria nana dwarf goldenbush 4.3 G5 S4

Erioneuron pilosum Hairy erioneuron 2B.3 G5 S3

Erythranthe calcicola Limestone monkeyflower BLMS 1B.3 G2 S1

Hecastocleis shockleyi Shockley's prickleleaf 3 G3G4 S3S4

BLMS Mentzelia inyoensis Inyo blazingstar USFSS 1B.3 G3 S3

Oenothera caespitosa ssp. crinita Cespitose evening-primrose 4.2 G5T4T5 S4

Oxytheca watsonii Watson's oxytheca 2B.2 G3 S1

Perityle inyoensis Inyo rockdaisy BLMS 1B.2 G2 S2

Purshia mexicana var. dubia Mexican cliffrose G5

Sclerocactus polyancistrus Mojave fish hook cactus 4.2 G3 S3

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Allium atrorubens var. cristatum - Crested onion

Flowering Time: April to June

Habitat: 1240-2750m, Sandy, rocky, or clay soils on desert slopes and mountains; Joshua tree woodland, Mojavean desert scrub, Pinyon and juniper woodland

Toxicity: Minor

Characteristics: Tepals pale pink with darker pink midveins, lance-ovate to ovate, apex margins flat, not becoming involute.

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Astragalus cimae var. sufflatus - Inflated Cima milkvetch

Flowering Time: April to June

Habitat: 1570-2090m, Calcareous substrates, with pinyon pine, generally sagebrush. Endemic to the eastside of the Inyo Mountains; Desert Scrub to Pinyon-Juniper.

Characteristics: Perennial with glabrous green foliage and stems up to 12in (3dm) long. Leaves are 2- 4in (5-10cm) long with ovate to roundish leaflets, most about ½ in (13mm) long. Flowers ½ in (13mm) or more long, are slender with the banner gently curved upward - Petals purple with white wing tips. Pods thick-papery, inflated, 1 ¼ - 1 ½ in (3-4cm) long and ½ - ¾ in (6-13mm) wide, abruptly straight across the base and tapered toward a pointed tip. The distinguishing features are the pod’s square end and its long stem (strip), ¼ - ½ in (6-13mm) long, which protrudes from the calyx when mature. (Natural History of the White-Inyo Range, Eastern California edited by Clarence A. Hall)

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Boechera shockleyi - Shockley's rock cress

Flowering Time: May

Habitat: 875-2600m, Bare rock/talus/scree, tends to occur on calcareous substrates, such as limestone or dolomitic outcrops, gravels, and sediments; also occurs on quartzite rock and sands. Many sites are on rocky ridges and slopes. Often in pinyon-juniper woodlands; also occurs in sagebrush scrub, mountain mahogany, shadscale-galleta, and ephedra-matchweed communities.

Characteristics: Characterized by (1) a multi-layered basal rosette, (2) hoary-gray pubescence of leaves, stems, and inflorescences, and (3) arching glabrous siliques that are large compared to other species in the genus (Welsh et al. 2008).

Perennials; usually short-lived; sexual; caudex not woody, (rarely with persistent, crowded leaf bases). Stems usually 1 per caudex branch, arising from center of rosette near ground surface, (0.8-)2-5 dm, densely pubescent proximally, trichomes short-stalked, 7-12-rayed, 0.1-0.2 mm, densely to sparsely pubescent distally. Basal leaves: blade oblanceolate, 3-10 mm wide, margins entire, not ciliate, surfaces densely pubescent, trichomes short-stalked, 7-12-rayed, 0.1-0.2 mm. Cauline leaves: 14-60, concealing stem for most of length; blade auricles 0.5-4 mm, surfaces of distalmost leaves densely pubescent. Racemes 20-70-flowered, usually unbranched. Fruiting pedicels divaricate-ascending, straight, 7-28 mm, pubescent, trichomes appressed, branched. Flowers ascending at anthesis; sepals pubescent; petals lavender, 6-9 × 0.8-1.2 mm, glabrous; pollen ellipsoid. Fruits divaricate-ascending, not appressed to rachis, not secund, usually curved, rarely straight, edges parallel, 4.5-11 cm × 1.5-2 mm; valves glabrous or sparsely pubescent throughout; ovules 140-190 per ovary; style 0.05-0.6 mm. Seeds sub-biseriate, 1-1.3 × 0.7-0.8 mm; wing distal or, rarely, absent, 0.05-0.1 mm wide.

Boechera shockleyi is a distinctive sexual species recognizable by the combination of strongly overlapping cauline leaves, a dense covering of minute, 7-12-rayed trichomes, and relatively long, curved, divaricate- ascending fruits with sub-biseriate seeds. It is most similar to B. inyoensis, but differs from that species in its narrower (0.8-1.2 versus 1.2-2 mm) petals, eciliate basal leaves with smaller (0.1-0.2 versus 0.2-0.7 mm) trichomes, greater number (140-190 versus 74-134) of ovules per ovary, and shorter (1-1.3 versus 1.7-2 mm) seeds with distal (versus continuous) wings.

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@Flora of North America

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Cryptantha tumulosa - New york mountain cryptantha

Flowering Time: April - June

Habitat: 1240-2510m, Limestone, occasionally granitic gravel or clay soils, generally pinyon/juniper woodland; gravelly or clay, granitic or carbonate. Mojavean desert scrub, Pinyon and juniper woodland.

Characteristics: Perennial 7-25cm tall, branched woody caudex. Stem generally many; dense- tomentose, hairs ± yellow, spreading. Leaf basal rosettes generally many, 3-6cm; basal oblanceolate to ± spoon shaped, ± folded, thick, ± gray, dense-silky-tomentose, bristles appressed, bulbous-based. Inflorecence dense, cylindric, narrow, generally not elongated in front; pedicel elongated in front to 3- 6mm. Flower calyx 3.5-4.5mm, 7-10mm in front, bristles dense, ± yellow, soft; corolla deciduous, tube 3.5-4.5mm, limb 6-8mm diameter, appendages yellow. Fruit nutlets generally 1-3, 3-4mm, wide-ovate, occasionally constricted above, ± gray, dull, margin sharp-angled to a ±flat narrow rim; abaxially ± tubercled, ridge rounded, ± indistrict near base; adaxially ± papillate, tubercled, attachment scar edges wide-triangular-gapped, edges ± raised; axis beyond nutlet. (The Digital Jepson Manual: Vascular Plants of California edited by Bruce G. Baldwin, Douglas Goldman, David J Keil, Robert Patterson, Thomas J. Rosatti)

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Illustration from Mozingo and Williams, 1980. Photographer: Jeanne R. Janish Photo Date: 1980

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Cymopterus ripleyi var. saniculoides - Ripley's springparsley

Flowering Time: April to June

Habitat: 1000-1660m, Gravelly, sandy, carbonate, Joshua tree woodland, Mojavean desert scrub

Characteristics: Perennial herb without hairs, 4 - 6 inches (10-15cm) tall. Leaf round, 3/4 - 2 inches (2- 5cm) long, with a leaf stem 1 1/8 - 4 inches (3-10cm) long. Leaflets wedge-shaped and 3-lobed, with each lobe being lobed. Inflorescence is a dense, spherical umbel. Petals are purple. Fruit is hairy, wedge- shaped to obovate, 1/4 inch (6-7mm) long. (http://www.blm.gov/ca/st/en/prog/ssp/plants/cymopterus_ripleyi_saniculoides.html)

* Taxonomy is marginally inconsistent across databases. Due to lack of entries of specific variety, status of this taxon is unclear. Cymopterus ripleyi Barneby - accepted - Ripley's springparsley Cymopterus ripleyi var. saniculoides Barneby - not accepted (ITIS)

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Ericameria nana - Dwarf goldenbush

Flowering Time: July to November

Habitat: 1300-2900m, Arid rocky plains, desert mountain cliffs, crevices. Pinyon and juniper woodland (rocky, carbonate or granitic), crevices.

Characteristics: 5-50 cm. Stems erect to spreading or recurved, green when young, soon becoming tan to brown, then nearly black when older, highly branched, twigs glabrous, glandular, usually resinous. Leaves* ascending to spreading; blades usually elliptic to oblanceolate, occasionally spatulate, 10-15 × 0.5-1.5 mm, mostly adaxially sulcate, margins entire, midnerves usually obscure to weakly evident, apices acute, apiculate, faces glandular, sometimes irregularly gland-dotted (in shallow pits), resinous; axillary fascicles present, persistent. Heads in congested, cymiform arrays (0.5-2.5 cm wide). Peduncles 0.2-5 mm (mostly ebracteate, glabrous). Involucres obconic, 5.5-7.5 × 2.5-4 mm. Phyllaries 22-30 in 4-5 series, mostly tan, lanceolate to elliptic, 2-6.5 × 0.5-1.2 mm, strongly unequal, outer sometimes herbaceous or herbaceous-tipped (body apices obtuse or truncate to retuse, appendages erect), midnerves not evident or slightly raised, slightly expanded subapically, (mostly margins narrowly membranous, entire) apices acute to acuminate or attenuate, mid often aristate to cuspidate, abaxial faces glabrous, resinous. Ray florets 1-7; laminae elliptic, 3-4 × 0.8-1.3 mm. Disc florets 4-8; corollas 4.5-6.5 mm. Cypselae tan, narrowly oblanceoloid, 4-5.5 mm, glabrous or densely sericeous; pappi tan, 4-5.5 mm. 2n = 18.

*Some populations of Ericameria nana exhibit extreme variation in leaf shape and in phyllary apex length and shape. Whether such variants represent distinct taxa remains to be tested.

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Erioneuron pilosum - Hairy erioneuron

Flowering Time: May to June

Habitat: 1220-1810m, Rocky slopes, ridges, pinyon/juniper woodland; Pinyon and juniper woodland (rocky, sometimes carbonate)

Characteristics: Plant cespitose. Stem: erect, 1-3(4) dm. Leaf: sheath margin long-soft-hairy at collar; blade 3-6 cm, 1-1.5 mm wide, flat or folded, margin white. Inflorescence: raceme- or panicle-like, 1.5-4 cm, 1--2 cm wide, stalked and elevated above terminal leaf cluster. Spikelet: 1-1.5 cm; glumes 3-7 mm, tan or +- purple, awn 0; lemma 4-7 mm, tip minutely 2-toothed, awn 0.5-2.5 mm. (http://herbaria4.herb.berkeley.edu/eflora_display.php?tid=24990)

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Erythranthe calcicola - Limestone monkeyflower

Flowering Time: April to September

Habitat: 915-2165m, usually carbonate, usually talus slopes. Joshua tree woodland, Mojavean desert scrub, Pinyon and juniper woodland.

Characteristics: Annual herb. Plants 2–15 cm tall 3 1–8 cm wide; sparsely glandular pubescent. Stems erect, simple to branched, turning reddish with age; internodes 0.5–1.5 cm. Cotyledons persistent, ovate to round, 1–6 mm long, with clasping bases. Leaves opposite, epetiolate or with petioles short (0.5–1 mm long), connate at the base; blades 3–25 mm long 3 2–8 (10) mm wide, lanceolate to ovate, palmately veined with three prominent veins from the base in wider leaves, margins entire or sometimes toothed. Flowers solitary in each axil, fruiting pedicels 3–20 mm, exceeding calyx, erect to ascending. Calyx 4–8 mm long 3 2–4 (5) mm wide, widely campanulate to cylindric, enlarging in fruit; costa prominent, darker than intercostal regions; calyx teeth equal, 0.5–1 mm long, acute to obtuse, margins ciliate. Corolla 6–13 mm long 3 3–7 (9) mm wide, yellow or white with a yellow throat, early deciduous, lobes emarginate, limb weakly zygomorphic; tube-throat 5– 10 mm long, cylindric, expanding gradually to the limb, palate sparsely bearded, spotted with red markings. Stamens didynamous, 3–9 mm long; yellow, glabrous, included. Gynoecium 5–10 mm long, light yellow to white; style glabrous; stigma lobes slightly apically fringed, subequal, included. Capsules 4– 8 mm long, included to equal to calyx, cylindric, thin walled and fragile, dehiscing to base along both sutures. Seeds 0.5– 0.9 mm long 3 0.2–0.3 mm wide, elliptic to ovoid, brown.

(NAOMI S. FRAGA. A REVISION OF ERYTHRANTHE MONTIOIDES AND ERYTHRANTHE PALMERI (PHRYMACEAE), WITH DESCRIPTIONS OF FIVE NEW SPECIES FROM CALIFORNIA AND NEVADA, USA. Aliso, 30(1), pp. 49–68. 2012, Rancho Santa Ana Botanic Garden.)

Photo by Naomi Fraga

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Hecastocleis shockleyi - Shockley's prickleleaf

Flowering Time: May to July

Habitat: 1130-1880m, Dry, rocky slopes

Characteristics: Stiff, much branched shrub (4-7dm); glandular puberulent or becoming glabrous except for tufts of soft hair in axils of persistent leaf bases. Leaves simple and alternate. Primary leaves 1-3 cm long, linear to linear-lanceolate, sessile, spine-tipped, sparsely spiny-dentate. Flower heads 1- flowered, sessile, in dense, head-like clusters, surrounded by involucre of persistent, ovate, spiny- toothed, net veined bracts. True involucre narrowly cylindric. Corolla pink to reddish purple in bud, greenish white in flower; anthers purple. Pappus a crown of fringed scales. (NatureServe)

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Mentzelia inyoensis - Inyo blazingstar

Flowering Time: April to Oct

Habitat: 1140-1940m, Rocky slopes, canyons, washes, clay hills. Documented on a variety of substrates including carbonate rocks/gravel, calcareous pumice sand, whitish ash deposits, and clay soils of hillsides, occurs in habitats that include sagebrush scrub, shadscale scrub, and pinyon-juniper woodlands (Thompson and Prigge 2004).

Characteristics: Erect perennials to 40 cm tall, densely vestured with straight, retrorsely barbed hairs, the barbs in whorls of 3-6 including terminal whorl; stems several, from near the base, white. Rosette leaves lanceolate or oblanceolate, 4-11 cm long, 6-20 mm wide, crenate or irregularly and bluntly lobed, pet- iolate; cauline leaves lanceolate to linear-lanceolate, 6-10 cm long, 4-16 mm wide, sessile on lower stem and grading to clasping toward inflorescence; margins lobed; lobes blunt on lower leaves, narrower and pointed on upper leaves. Flowers axillary or terminal, subtended by a bract; bract linear, entire or with a pair of short basal lobes or teeth; calyx lobes narrowly triangular, acuminate, 4.5-12 mm long, 1.3-3.2 mm wide; petals 5, yellow, elliptic to oblanceolate, 11-18 mm long, 2.2-4.0 (-6) mm wide, acute; petaloid staminodia 0; stamens numerous, 5-15 mm long, diminishing in length in inner whorls; anthers 0.6-1.4 mm long; filaments of the outermost whorls to 1.5 mm wide, becoming narrower in inner stamen whorls; style 10-13 mm long. Capsules straight, cylindrical, 12-16 (-25) mm long, 6-8 mm wide. Seeds lenticular, 2.0-3.0 mm long, 1 .6-2.2 mm wide, narrowly winged, uni- formly tannish or faintly tesselate; seed coat cells with straight radial wall and 2-6 papillae (Thompson and Prigge 2004).

(Thompson and Prigge 2004).

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Oenothera caespitosa ssp. crinita - Cespitose evening-primrose Flowering Time: July to September (Calflora), June to September (Jepson) Habitat: 1400 to 3340m, Calcium soils in bristlecone-pine forest, pinyon/juniper woodland, desert scrub. Characteristics:

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Oxytheca watsonii - Watson's oxytheca Flowering Time: May to July (Calflora), June to Oct (Jepson/FloraNA) Habitat: 1200-2000m, Usually occurs in wetlands, but occasionally found in non wetlands [U.S. Fish & Wildlife Service.] Creosote Bush Scrub, Joshua Tree Woodland, wetland-riparian.

Dry, open, loose and/or lightly disturbed, often calcareous, sandy soils of washes, roadsides, alluvial fans, and valley bottoms, in salt desert shrub communities with Atriplex, Sarcobatus, Hymenoclea, Lycium, etc.

Characteristics: Plants erect to spreading, 0.5-2.5 × 0.4-4 dm. Stems glandular throughout. Leaf blades spatulate or obovate to oblanceolate, 0.7-4 × (0.1-)0.5-1.2 cm, strigose adaxially, less so abaxially, sparsely glandular on both surfaces. Inflorescences open to densely branched, 0.5-2 dm; bracts 1-5 × 0.5-3 mm, 3(-5) at first node and linear to ovate, otherwise distinct or basally connate and linear to triangular, ciliate and glandular; awns 1-3 mm. Peduncles deflexed, stout, 0.2-0.5 cm at proximal nodes, sometimes absent. Involucres 1.5-2 mm, typically glabrous, rarely with few scattered hairs abaxially; teeth 4; awns reddish, 2.5-3 mm. Flowers 2-4(-7); perianth white to pink, 1-1.5 mm, strigose and sparsely glandular abaxially; tepals dimorphic, entire, those of outer whorl oval to ovate and strigose abaxially, those of inner elliptic to oval or ovate and glabrous or sometimes pubescent adaxially at base; filaments 1-1.5 mm, glabrous; anthers cream to red, oval, 0.2 mm. Achenes dark brown to maroon, 1-1.5 mm. (James L. Reveal in Flora of North America (vol. 5))

Oxytheca watsonii is an uncommon species known only from scattered locations. The name was misapplied in pre-1980 California floras to Acanthoscyphus parishii var. goodmaniana.

CEDAR CREEK ASSOCIATES, INC. PAGE - A16

MOZINGO AND WILLIAMS, 1980.

CEDAR CREEK ASSOCIATES, INC. PAGE - A17

Perityle inyoensis - Inyo rockdaisy

Flowering Time: June to August (Calflora, CNPS), June to September (Jepson)

Habitat: 1800-2800m, Dry, rocky slopes rocky, carbonate. Great Basin scrub, Pinyon and juniper woodland

Characteristics: Perennials or subshrubs, 12–25 cm; pilose-villous indument intermixed with short glandular hairs. Leaves (opposite or alternate): petioles 5–20(–50) mm; blades orbiculate, ovate, or ovate-deltate, 8–18(–21) × 6–12(–15) mm, margins serrate to serrate-lobed. Heads borne singly or (2– 3) in corymbiform arrays, 7–8.5(–9) × 5–7(–8) mm. Peduncles 8–40 mm. Involucres campanulate. Phyllaries 14–21, linear-lanceolate to sub-lanceolate, 5.5–6.5 × 1.1–1.5 mm. Ray florets 0. Disc florets 35–60; corollas yellow, tubes 1.4–1.6 mm, throats subtubular to subfunnelform, 2–2.4 mm, lobes 0.6–0.7 mm. Cypselae narrowly oblanceolate to suboblanceolate, (2.5–)3–3.5 mm, margins thin-calloused, short-hairy; pappi usually inconspicuous, callous crowns, rarely of minute scales. (Flora of North America)

CEDAR CREEK ASSOCIATES, INC. PAGE - A18

Purshia mexicana var. dubia - Mexican cliffrose

Flowering Time: Apr to May (-Oct)

Habitat: 920-2660m, Pinyon-juniper, Joshua tree, yellow pine woodlands, arid desert scrub, desert chaparral.

Characteristics: Taxonomy is very inconsistent across databases. Due to lack of entries of specific variety, status of this taxa is unclear.

CEDAR CREEK ASSOCIATES, INC. PAGE - A19

Sclerocactus polyancistrus - Mojave fish hook cactus Flowering Time: April to July Habitat: 500-2500m, Limestone areas, hills and canyons, alluvial slopes; creosote-bush scrub, Joshua- tree woodland; Rocky alluvial, often alkaline soils, Mojave desert scrub.

Characteristics: Stems unbranched or in clusters, cylindric or elongate cylindric, 10-40(-45) × 5-9 cm; ribs 13-17, well developed, tubercles not evident on ribs. Spines dense, obscuring stems; radial spines 10-15(-18) per areole, white, straight, flat, 20-50 mm, glabrous; central spines 9-12 per areole, 5-8 hooked, others straight, terete to angled; abaxial and lateral central spines 6-8 per areole, red or reddish brown (rarely yellow), some hooked, (30-)56-100 × 0.7-1.2 mm; adaxial central spines usually 3 per areole, white, usually curved or twisted, flat, usually 37-86(-130) × 1.7-3.4 mm. Flowerswith spicy, pungent odor, funnelform, 5-10 × 5-9 cm; outer tepals with greenish purple midstripes and rose-purple or magenta margins, cuneate-spatulate, usually 15-30 × 6-9 mm; inner tepals rose-purple to magenta (rarely white), largest tepals ovate-lanceolate, 24-45 × 9-12 mm; filaments greenish yellow; anthers cream; style grooved, not papillate. Fruits irregularly dehiscent at base, green, tan, or red, barrel- shaped, 22-50 × 12-25 mm, dry at maturity; scales few, white fringed. Seeds black, 2.7-3.7 × 2-2.5 mm, shiny; testa with fine, rounded papillae.

Sclerocactus polyancistrus is the only member of the genus that truly lacks papillae on the style, and its style possesses grooves, somewhat reminiscent of Ferocactus. It is easily recognized by its massive stem size (relative to other species of Sclerocactus), large flowers, and numerous hooked central spines (five to nine). (Flora of North America)

CEDAR CREEK ASSOCIATES, INC. PAGE - A20 Silver Standard Resources, Inc. Biological Evaluation For Sensitive Flora - 2017 Minimum Construction Alternative Road

PERDITO EXPLORATION PROJECT

JUNE, 2017

Silver Standard Resources, Inc.

Perdito Exploration Project - 2017

BIOLOGICAL EVALUATION FOR SENSITIVE FLORA - MINIMUM CONSTRUCTION ALTERNATIVE ROAD

1.0 INTRODUCTION

Cedar Creek Associates, Inc. (Cedar Creek) was retained in 2017 by Silver Standard Resources, Inc. (Silver Standard) to evaluate the Perdito Minimum Construction Alternative (MCA) Road for sensitive flora. At present, Silver Standard is proposing to conduct a drilling program in this largely roadless area of Inyo County within Township 17S, Range 39E, Sections 3 and 4 on lands managed by the Bureau of Land Management, Ridgecrest Field Office. The proposed MCA road follows a new alignment for a section of the route that had been established, reclaimed, and revegetated in 2000, by TRC and/or BHP. Project area elevations range from 6,570 to 7,120 feet above MSL and climate is temperate continental (hot dry summers and cold dry winters) with average annual precipitation in the 8 to 10-inch range. Dominant vegetation of the area is largely black sagebrush scrub, but is transitional with desert (shadscale) scrub with pockets of single-leaf Piñon (and occasional juniper) as scattered stands at elevation. Immediately to the east of the project across Santa Rosa Flat (shadscale scrublands) is a large area visually dominated by Joshua trees (Yucca brevifolia) a few of which extend into the project area.

2.0 METHODS

Prior to fieldwork in 2017, a list of potential sensitive flora that may be resident in the project area was compiled and evaluated for reasonableness and veracity of that potential. Sources included past survey efforts by both Bagley and Woodman and recent information provided by the Bureau of Land Management. Natural heritage diversity database searches were included with previous investigations so were not repeated in 2017. These efforts yielded the following flora (Table 1) with the potential for residence in the project area rated as “remote” or greater. Also indicated on Table 1 is the optimal survey window for each taxon as well as an indication of past observations of specific taxa.

CEDAR CREEK ASSOCIATES, Inc. 1 Perdito Project - Exploration - 2017 MCA Flora Evaluation Table 1 Perdito Project - Plant Taxa of Interest to the BLM - 2017 Survey Window Obsvd.* Species March A pril May June July Aug Sept Allium atrorubens var. cristatum X X X O Astragalus cimae var. sufflatus X X X Boechera shockleyi X X O Cryptantha tumulosa X X X X O Cymopterus ripleyi X X X Ericameria nana X X X Erioneuron pilosum X X O Erythranthe calcicola X X X X X X Hecastocleis shockleyi X X X O Mentzelia inyoensis X X X X X X Oenothera caespitosa ssp. crinita X X X X X O Oxytheca watsonii X X X Perityle inyoensis X X X O Purshia mexicana var. dubia X X X O Sclerocactus polyancistrus X X X X O * Taxa observed by either Bagley or Cedar Creek within the project area.

Table 2 indicates the “sensitive” status of the 15 floral taxa rated as having at least some remote potential for existence in the project area as well as an indication of those that have been observed in the area (bold print). Prior to 2017 field activities, a field guide to these 15 floral taxa was prepared and included photos, line drawings, taxonomic characters, habitat requisites, etc. to facilitate positive identification of any observed specimens while in the field. This field guide is included with this document as Appendix A.

CEDAR CREEK ASSOCIATES, Inc. 2 Perdito Project - Exploration - 2017 MCA Flora Evaluation Table 2 Perdito Project - Rare and Sensitive Plants - 2017 BLM/USFS CNPS Global State Scientific Name* Common Name Status Rank Rank Rank A llium atrorubens var. cristatum Crested onion 4.3 G4T4 S4 Astragalus cimae var. sufflatus Inflated Cima milkvetch BLMS 1B.3 G3T3 S2 Boechera shockleyi Shockley's rock cress USFSS 2B.2 G3 S2 Cryptantha tumulosa New York Mtn. cryptantha 4.3 G4 S4 Cymopterus ripleyi var. saniculoides Ripley's springparsley BLMS 1B.2 G3G4T3Q S1 Ericameria nana Dwarf goldenbush 4.3 G5 S4 Erioneuron pilosum Hairy erioneuron 2B.3 G5 S3 Erythranthe calcicola Limestone monkeyflower BLMS 1B.3 G2 S1 Hecastocleis shockleyi Shockley's prickleleaf 3 G3G4 S3S4 Mentzelia inyoensis Inyo blazingstar BLMS USFSS 1B.3 G3 S3 Oenothera caespitosa ssp. crinita Caespitose evening-primrose 4.2 G5T4T5 S4 Oxytheca watsonii Watson's oxytheca 2B.2 G3 S1 Perityle inyoensis Inyo rockdaisy BLMS 1B.2 G2 S2 Purshia mexicana var. dubia Mexican cliffrose G5 Sclerocactus polyancistrus Mojave fish hook cactus 4.2 G3 S3 * Bold print indicates observed in the project area.

From June 1st through June 3rd 2017, Cedar Creek’s Senior Plant Ecologist, Mr. Erik Mohr and Rangeland Ecologist, Ms. Rachel Ridenour, surveyed the Perdito project area for flora indicated on Table 1 and 2. Surveys consisted of a series of pedestrian transects across the project area (these tracks are indicated on Maps 1 and 2) which included habitat within 50 meters of the proposed route and not already surveyed by Bagley in 2014. A Garmin 650t Montana GPS was carried on personnel during all surveys to record pedestrian transects. As such, a quick perusal of Map 1 indicates survey routes that ran parallel to the proposed alignment at distances of 10-20 meters between routes. All rare species encountered along these routes were recorded and approximate quantities noted (Table 3). All limestone rock outcrops were thoroughly searched for the primary species of concern, the Inyo rock daisy (Peritlye inyoensis), since this is the only habitat for this species. All rare species were verified using the Jepson Manual (Hickman 1993) and on-line plant image galleries. Photographs of the seven species encountered are included in at the end of this report.

CEDAR CREEK ASSOCIATES, Inc. 3 Perdito Project - Exploration - 2017 MCA Flora Evaluation !(!(

!( !( !(!( !( !( !(

!( !(!( !( Map 1 Perdito Project - 2017

!( !(!( Minimum Construction Alternative Road Flora Survey Rare Plant Locations & Survey Tracks

Survey Boundary - 50 meter buffer from Route

Area Surveyed by Bagley - 2014

Proposed MCA Route

!( Cedar Creek Survey Tracks - June 1-3, 2017 !( Rare Plants Allium atrorubens var. cristatum Cryptantha tumulosa !( !( Hecastocleis shockleyi !( !(!( !(!(!( !( !( !(!( !( !( !( !( !( !( !( !(!( !( !( !( Oenothera caespitosa ssp. crinita !( !(!( !( !( !( !( !( !(!( !(!( !(!( !( !( !(!( !(!(!(!( !(!( !( !( !(!( !( !( !(!(!(!( !(!( !(!(!( !( Perityle inyoensis !(!(!( !(!(!( !( !( !( !( !( !(!( !( !( !( !( !( !( !( !(!( Sclerocactus polyancistrus !( !(!( !( !( !(!( !( !( !(!(!( !(

!(!(!(!( !(!(!( !(!( 050 100 200 300 400 µ Meters

!( !(!(

!( !( !(!( !( !( !(

!( !(!( !( Map 1 Perdito Project - 2017

!( !(!( Minimum Construction Alternative Road Flora Survey Rare Plant Locations & Survey Tracks

Survey Boundary - 50 meter buffer from Route

Area Surveyed by Bagley - 2014

Proposed MCA Route

!( Cedar Creek Survey Tracks - June 1-3, 2017 !( Rare Plants Allium atrorubens var. cristatum Cryptantha tumulosa !( !( Hecastocleis shockleyi !( !(!( !(!(!( !( !( !(!( !( !( !( !( !( !( !( !(!( !( !( !( Oenothera caespitosa ssp. crinita !( !(!( !( !( !( !( !( !(!( !(!( !(!( !( !( !(!( !( !(!(!( !(!( !( !( !(!( !( !( !(!(!(!( !(!( !(!( !( !( Perityle inyoensis !(!(!( !(!(!( !( !( !( !( !( !(!( !( !( !( !( !( !( !( !( !( Sclerocactus polyancistrus !( !(!( !( !( !(!( !( !( !(!(!( !(

!(!(!(!( !(!(!( !(!( 0 50 100 200 300 400 µ Meters

!( !( !( !( Map 2 Perdito Project - 2017 Minimum Construction Alternative Road Flora Survey !( !( Peritlye!( Inyoensis - Outcrop Area !(

!( Survey Boundary - 50 meter buffer from Route !( !( !( !( !( !( Area Surveyed by Bagley - 2014 !( !( !( !( !( !( !( !( !( !( !( !( !( !( Proposed MCA Route !( !( !( !( !( Cedar Creek Survey Tracks - June 1-3, 2017 !(

!( !( Rare Plants !( !( !( Allium atrorubens var. cristatum !( Cryptantha tumulosa Hecastocleis shockleyi

!( !( !( !( !( Oenothera caespitosa ssp. crinita !( !( Perityle inyoensis Sclerocactus polyancistrus µ

05 10 20 30 40 50 Meters !( !( !( Map 2 Perdito Project - 2017 Minimum Construction Alternative Road Flora Survey !( !( Peritlye!( Inyoensis - Outcrop Area !(

!( !( Rare Plants !( !( !( Allium atrorubens var. cristatum !( Cryptantha tumulosa Hecastocleis shockleyi

!( !( !( !( !( Oenothera caespitosa ssp. crinita !( !( Perityle inyoensis Sclerocactus polyancistrus µ

0 5 10 20 30 40 50 Meters 3.0 FINDINGS

3.1 General Findings and Observations

Table 1 indicates 15 sensitive floral taxa that were identified as having some potential (remote or better) as residents of the project area. Cedar Creek encountered five of these sensitive floral taxa during the pedestrian transects in the MCA buffer zone:

• Allium atrorubens var. cristatum Crested onion • Cryptantha tumulosa New York Mtn. cryptantha • Oenothera caespitosa ssp. crinita Caespitose evening-primrose • Perityle inyoensis Inyo rockdaisy • Sclerocactus polyancistrus Mojave fish-hook cactus

Cedar Creek also observed one Hecastocleis shockleyi (Shockley’s prickleleaf) and numerous specimens of Purshia mexicana var. dubia (Mexican cliffrose) in Bagley’s survey area near the end of the present access road (not in the MCA buffer zone). The Mexico cliffrose and the nearly identical Purshia mexicana var. stansburyana (Cliffrose) are intermixed and common along the wash bottom access corridor leading into the project area. The taxonomy of this species with regard to the varietal dubia is inconsistent across many databases. The variety dubia (a.k.a. Cowania mexicana var. dubia and Cowania alba) is a hybrid between Purshia mexicana var. stansburyana and Purshia tridentata according to the Flora of North America. The Jepson manual mentions the hybrid but does not give it varietal status. Numerous individuals were inspected for the number of carpels/pistils present (three for var. dubia versus four to five for var. stansburyana) and both number of carpels were found, occasionally on the same plant (Photo 13). Given identification by a previous BLM botanist of Purshia mexicana var dubia in the area, it is likely that this variety is present in places along the wash bottoms and rock outcrops in the eastern entrances to the project area. A single Hecastocleis shockleyi was located just above the end of access road although numerous others were easily spotted in flower further up the hill (Photo 9).

In addition to recording faunal observations and sensitive plants, Cedar Creek’s biologist recorded the more dominant flora of the project area. These include:

• Single-leaf piñon pine Pinus monophylla • Utah Juniper Juniperus osteosperma • Joshua tree Yucca brevifolia • Black sagebrush Artemisia arbuscula nova • Shadscale Atriplex confertifolia • Spiny hopsage Grayia spinosa • Spiny menodora Menodora spinescens • Little-leaf horsebrush Tetradymia glabrata • Green rabbitbrush Chrysothamnus viscidiflorus

CEDAR CREEK ASSOCIATES, Inc. 6 Perdito Project - Exploration - 2017 MCA Flora Evaluation Table 3 Perdito Project - 2017 Page 1 of 2 Locations of Rare Plants & Quantities UTM - Nad 83 Zone 11 Quantity Latitude Longitude altitude (m) Species East (m) North (m) Allium atrorubens var. cristatum 1 36.478823 -117.741508 4037314.02 433576.52 2067.35 Allium atrorubens var. cristatum 1 36.473201 -117.742787 4036691.27 433457.14 2064.79 Allium atrorubens var. cristatum 3 36.472945 -117.744010 4036663.72 433347.35 2071.86 Allium atrorubens var. cristatum 5 36.473324 -117.743481 4036705.40 433395.07 2071.00 Allium atrorubens var. cristatum 5 36.473270 -117.742912 4036699.01 433446.00 2069.88 Allium atrorubens var. cristatum 10 36.473375 -117.742757 4036710.55 433459.98 2064.97 Allium atrorubens var. cristatum 10 36.473302 -117.742699 4036702.42 433465.11 2065.10 Allium atrorubens var. cristatum 4 36.473192 -117.742560 4036690.12 433477.47 2060.45 Allium atrorubens var. cristatum 10 36.473526 -117.743423 4036727.76 433400.44 2075.07 Allium atrorubens var. cristatum 1 36.473664 -117.744064 4036743.51 433343.13 2085.98 Allium atrorubens var. cristatum 5 36.473729 -117.744852 4036751.27 433272.59 2102.11 Allium atrorubens var. cristatum 1 36.473622 -117.745003 4036739.51 433258.97 2102.96 Allium atrorubens var. cristatum 1 36.473618 -117.745103 4036739.13 433250.01 2101.50 Allium atrorubens var. cristatum 1 36.473608 -117.745449 4036738.26 433219.01 2103.76 Allium atrorubens var. cristatum 1 36.473597 -117.745633 4036737.17 433202.51 2107.81 Allium atrorubens var. cristatum 1 36.473511 -117.746094 4036727.95 433161.14 2114.50 Allium atrorubens var. cristatum 1 36.472841 -117.747573 4036654.65 433028.06 2133.27 Allium atrorubens var. cristatum 1 36.472905 -117.747749 4036661.88 433012.35 2134.17 Allium atrorubens var. cristatum 1 36.473209 -117.747560 4036695.47 433029.54 2126.99 Allium atrorubens var. cristatum 1 36.473238 -117.747406 4036698.58 433043.36 2123.96 Allium atrorubens var. cristatum 1 36.473284 -117.747252 4036703.57 433057.20 2122.82 Allium atrorubens var. cristatum 1 36.473200 -117.747104 4036694.15 433070.39 2125.07 Allium atrorubens var. cristatum 1 36.473756 -117.746907 4036755.69 433088.51 2114.63 Allium atrorubens var. cristatum 1 36.473469 -117.746927 4036723.87 433086.48 2117.92 Allium atrorubens var. cristatum 1 36.473428 -117.746784 4036719.22 433099.25 2117.99 Allium atrorubens var. cristatum 1 36.473647 -117.746445 4036743.28 433129.81 2115.74 Allium atrorubens var. cristatum 1 36.473775 -117.746320 4036757.39 433141.12 2113.26 Allium atrorubens var. cristatum 1 36.473942 -117.746219 4036775.84 433150.31 2111.54 Allium atrorubens var. cristatum 1 36.473993 -117.746266 4036781.53 433146.14 2110.62 Allium atrorubens var. cristatum 1 36.473839 -117.745688 4036764.05 433197.79 2109.73 Allium atrorubens var. cristatum 1 36.473418 -117.743433 4036715.79 433399.45 2078.51 Allium atrorubens var. cristatum 1 36.473360 -117.743314 4036709.27 433410.06 2077.64 Allium atrorubens var. cristatum 1 36.473336 -117.743248 4036706.57 433415.96 2077.62 Allium atrorubens var. cristatum 1 36.473309 -117.743170 4036703.52 433422.92 2076.55 Allium atrorubens var. cristatum 1 36.473681 -117.742968 4036744.64 433441.34 2067.92 Allium atrorubens var. cristatum 12+ 36.473483 -117.743377 4036722.96 433404.52 2071.93 Allium atrorubens var. cristatum 1 36.473011 -117.743017 4036670.36 433436.37 2065.08 Allium atrorubens var. cristatum 4 36.473158 -117.743571 4036687.04 433386.87 2067.88 Allium atrorubens var. cristatum 4 36.472955 -117.743654 4036664.58 433379.26 2076.04 Allium atrorubens var. cristatum 1 36.472712 -117.743960 4036637.84 433351.63 2084.79 Allium atrorubens var. cristatum 10 36.473262 -117.743237 4036698.35 433416.88 2070.79 Allium atrorubens var. cristatum 15 36.473535 -117.744702 4036729.65 433285.87 2099.49 Allium atrorubens var. cristatum 20 36.473542 -117.745155 4036730.74 433245.29 2102.61 Allium atrorubens var. cristatum 6 36.471982 -117.748720 4036560.17 432924.56 2149.53 Allium atrorubens var. cristatum 1 36.471983 -117.748659 4036560.24 432930.03 2148.68 Allium atrorubens var. cristatum 1 36.472187 -117.748339 4036582.64 432958.87 2143.37 Allium atrorubens var. cristatum 1 36.472185 -117.748305 4036582.40 432961.92 2143.34 Allium atrorubens var. cristatum 3 36.472165 -117.748316 4036580.19 432960.91 2142.12 Allium atrorubens var. cristatum 1 36.472153 -117.748306 4036578.85 432961.80 2142.19 Allium atrorubens var. cristatum 3 36.472146 -117.748317 4036578.08 432960.81 2142.15 Allium atrorubens var. cristatum 1 36.472158 -117.748281 4036579.38 432964.04 2142.13 Allium atrorubens var. cristatum 3 36.472164 -117.748275 4036580.05 432964.59 2142.15 Allium atrorubens var. cristatum 2 36.472172 -117.748237 4036580.91 432968.00 2140.30 Allium atrorubens var. cristatum 1 36.472195 -117.748230 4036583.45 432968.64 2139.57 Allium atrorubens var. cristatum 2 36.472210 -117.747995 4036584.95 432989.71 2137.99 Allium atrorubens var. cristatum 2 36.472205 -117.747852 4036584.30 433002.52 2136.75 Allium atrorubens var. cristatum 1 36.472221 -117.747783 4036586.03 433008.71 2135.65 Allium atrorubens var. cristatum 1 36.472904 -117.747271 4036661.43 433055.17 2132.28 Allium atrorubens var. cristatum 1 36.472935 -117.747263 4036664.87 433055.91 2132.22 Allium atrorubens var. cristatum 1 36.473308 -117.747044 4036706.09 433075.85 2116.57 Allium atrorubens var. cristatum 1 36.472777 -117.746004 4036646.47 433168.57 2109.52 Allium atrorubens var. cristatum 1 36.472717 -117.746003 4036639.81 433168.61 2106.03 Allium atrorubens var. cristatum 1 36.472623 -117.745774 4036629.22 433189.04 2102.20 Allium atrorubens var. cristatum 1 36.472813 -117.745853 4036650.35 433182.13 2109.31 Allium atrorubens var. cristatum 1 36.472916 -117.745848 4036661.78 433182.67 2113.06 Allium atrorubens var. cristatum 1 36.472929 -117.745829 4036663.21 433184.38 2111.84 Allium atrorubens var. cristatum 1 36.473147 -117.745638 4036687.26 433201.68 2112.44 Allium atrorubens var. cristatum 1 36.473123 -117.745625 4036684.58 433202.82 2112.42 Allium atrorubens var. cristatum 3 36.473104 -117.745525 4036682.41 433211.76 2108.79

CEDAR CREEK ASSOCIATES, Inc. 7 Perdito Project - Exploration - 2017 MCA Flora Evaluation Table 3 (continued) Page 2 of 2 Locations of Rare Plants & Quantities UTM - Nad 83 Zone 11 Quantity Latitude Longitude altitude (m) Species East (m) North (m) Allium atrorubens var. cristatum 5 36.473099 -117.745486 4036681.83 433215.25 2108.87 Allium atrorubens var. cristatum 1 36.473063 -117.745487 4036677.83 433215.13 2107.98 Allium atrorubens var. cristatum 5 36.473014 -117.745415 4036672.35 433221.54 2107.19 Allium atrorubens var. cristatum 2 36.473154 -117.745283 4036687.79 433233.49 2105.45 Allium atrorubens var. cristatum 6 36.473146 -117.745257 4036686.88 433235.81 2105.81 Allium atrorubens var. cristatum 5 36.473115 -117.745144 4036683.36 433245.91 2101.19 Allium atrorubens var. cristatum 2 36.473187 -117.745110 4036691.33 433249.01 2101.29 Allium atrorubens var. cristatum 2 36.473289 -117.744928 4036702.51 433265.41 2100.03 Allium atrorubens var. cristatum 1 36.473310 -117.744907 4036704.83 433267.31 2100.03 Allium atrorubens var. cristatum 1 36.473251 -117.744834 4036698.23 433273.80 2098.30 Allium atrorubens var. cristatum 1 36.473228 -117.744747 4036695.62 433281.57 2096.51 Allium atrorubens var. cristatum 1 36.473221 -117.744622 4036694.76 433292.76 2093.38 Allium atrorubens var. cristatum 1 36.473246 -117.744514 4036697.46 433302.46 2093.39 Allium atrorubens var. cristatum 1 36.473276 -117.743203 4036699.88 433419.94 2075.93 Allium atrorubens var. cristatum 1 36.473177 -117.740270 4036686.88 433682.61 2042.16 Allium atrorubens var. cristatum 1 36.474218 -117.738994 4036801.47 433797.81 2046.95 Allium atrorubens var. cristatum 1 36.479782 -117.741753 4037420.57 433555.39 2063.28 Allium atrorubens var. cristatum 2 36.474055 -117.738804 4036783.26 433814.70 2050.40 Allium atrorubens var. cristatum 3 36.473999 -117.738754 4036777.02 433819.13 2048.23 Allium atrorubens var. cristatum 2 36.473954 -117.738736 4036772.01 433820.70 2047.93 Allium atrorubens var. cristatum 1 36.473919 -117.738703 4036768.11 433823.63 2046.93 Allium atrorubens var. cristatum 1 36.472702 -117.742537 4036635.75 433479.11 2058.70 Cryptantha tumulosa 2 36.473436 -117.747789 4036720.81 433009.22 2118.66 Hecastocleis shockleyi 1 36.482738 -117.735377 4037744.09 434129.06 2001.87 Oenothera caespitosa ssp. crinita 2 36.473106 -117.742976 4036680.87 433440.13 2065.32 Oenothera caespitosa ssp. crinita 10+ 36.472719 -117.743296 4036638.16 433411.13 2065.26 Oenothera caespitosa ssp. crinita 1 36.473302 -117.742499 4036702.28 433483.03 2059.09 Oenothera caespitosa ssp. crinita 1 36.482709 -117.735409 4037740.89 434126.17 2002.09 Oenothera caespitosa ssp. crinita 1 36.473205 -117.741748 4036691.00 433550.23 2050.15 Perityle inyoensis 20+ 36.472705 -117.743154 4036636.51 433423.84 2064.10 Perityle inyoensis 2 36.473074 -117.743489 4036677.67 433394.14 2067.74 Perityle inyoensis 2 36.472973 -117.743495 4036666.47 433393.52 2070.31 Perityle inyoensis 2 36.472904 -117.743504 4036658.82 433392.65 2072.17 Perityle inyoensis 3 36.479947 -117.739089 4037437.03 433794.18 2044.31 Perityle inyoensis 15 36.479806 -117.739031 4037421.35 433799.25 2046.36 Perityle inyoensis 9 36.472646 -117.743040 4036629.88 433434.00 2067.67 Perityle inyoensis 8 36.472623 -117.743121 4036627.39 433426.72 2072.69 Perityle inyoensis 15 36.473012 -117.743307 4036670.67 433410.39 2063.77 Perityle inyoensis 15 36.472702 -117.744085 4036636.82 433340.43 2087.26 Perityle inyoensis 1 36.479689 -117.741614 4037410.15 433567.77 2063.27 Perityle inyoensis 1 36.479728 -117.741684 4037414.53 433561.53 2063.31 Perityle inyoensis 1 36.479647 -117.741393 4037405.34 433587.53 2061.17 Perityle inyoensis 1 36.479223 -117.740888 4037357.96 433632.40 2094.35 Perityle inyoensis 5 36.479152 -117.740844 4037350.06 433636.29 2096.51 Perityle inyoensis 10 36.479845 -117.741483 4037427.37 433579.63 2058.74 Sclerocactus polyancistrus 1 36.473251 -117.742641 4036696.72 433470.26 2062.16 Sclerocactus polyancistrus 1 36.473434 -117.746247 4036719.51 433147.37 2114.58 Sclerocactus polyancistrus 1 36.473436 -117.746297 4036719.77 433142.89 2115.06 Sclerocactus polyancistrus 1 36.474004 -117.748090 4036784.02 432982.74 2114.61 Sclerocactus polyancistrus 1 36.475801 -117.739657 4036977.52 433739.77 2059.42 Sclerocactus polyancistrus 1 36.475485 -117.741595 4036943.81 433565.88 2093.63 Sclerocactus polyancistrus 1 36.473497 -117.745454 4036725.95 433218.46 2105.76 Sclerocactus polyancistrus 1 36.473506 -117.745575 4036727.03 433207.63 2108.68 Sclerocactus polyancistrus 1 36.470831 -117.749977 4036433.37 432810.95 2172.75 Sclerocactus polyancistrus 1 36.473844 -117.748385 4036766.48 432956.18 2123.26 Sclerocactus polyancistrus 1 36.472715 -117.746426 4036639.88 433130.71 2111.47 Sclerocactus polyancistrus 1 36.474130 -117.738698 4036791.51 433824.26 2043.83 Sclerocactus polyancistrus 1 36.479264 -117.741162 4037362.70 433607.89 2075.91 Sclerocactus polyancistrus 2 36.473817 -117.738925 4036756.94 433803.65 2040.71 Sclerocactus polyancistrus 1 36.473376 -117.741092 4036709.52 433609.14 2041.60 Sclerocactus polyancistrus 1 36.473715 -117.739207 4036745.82 433778.30 2037.27 Sclerocactus polyancistrus 3 36.478383 -117.740899 4037264.79 433630.70 2104.09 Sclerocactus polyancistrus 1 36.478454 -117.740416 4037272.33 433674.03 2106.36 Sclerocactus polyancistrus 1 36.478375 -117.740386 4037263.55 433676.65 2107.83 Sclerocactus polyancistrus 1 36.473988 -117.738768 4036775.80 433817.87 2049.37 Sclerocactus polyancistrus 1 36.473186 -117.742106 4036689.14 433518.14 2052.75 Sclerocactus polyancistrus 1 36.473551 -117.741387 4036729.13 433582.86 2043.84

CEDAR CREEK ASSOCIATES, Inc. 8 Perdito Project - Exploration - 2017 MCA Flora Evaluation • Nevada jointfir Ephedra nevadensis • Budsage Artemisia spinescens • Four-winged saltbush Atriplex canescens (revegetated) • Pygmy cedar Peucephyllum schottii • Winterfat Krasheninnikovia lanata • California buckwheat Eriogonum fasciculatum • Great-basin wildrye Elymus cinereus (revegetated) • Galleta Hilaria jamesii • Indian ricegrass Oryzopsis hymenoides (revegetated) • Sandberg bluegrass Poa secunda • Crested wheatgrass Agropyron cristatum (revegetated) • Needlegrass Stipa sp. (revegetated) • Desert princesplume Stanleya elata • Desert trumpet Eriogonum inflatum • Desert globemallow Sphaeralcea ambigua • Green molly Kochia americana • Indian paintbrush Castilleja chromosa • Beavertail prickly pear Opuntia basilaris

Specific findings with regard to each sensitive taxon will be addressed individually in sections to follow.

3.2 Specific Findings and Observations

Perityle inyoensis – A total of 17 individuals of Inyo rock daisy were located within the 50-meter buffer zone around the MCA road. These individuals were located on series of rock outcrops and cliffs along the southern edge of the MCA buffer zone about midway through route (Maps 1 and 2). A 100 percent search of the immediate area discovered numerous more individuals outside the 50-meter zone. A vast majority of the rock daisy individuals were not flowering at the time of survey, although they were easy to identify based on foliage. A few individuals were in flower (Photos 1 through 5) and identification to species was verified. Both locations of Inyo rock daisy were approximately 45 meters away from the MCA route and unlikely to be affected by construction disturbance or road traffic.

Allium atrorubens var. cristatum – A total of 91 individuals or clusters of crested onion were located during the survey (75 locations within the buffer zone). This species was fairly common on the hillsides along the route. A majority of the crested onion individuals were just past peak flowering although several specimens were in prime flowering condition (Photos 6 and 7). It is estimated that there are several thousand individuals within the survey buffer zone. Numerous crested onions were located on the faint two-track that the MCA route will follow and construction and road traffic will likely affect these individuals.

CEDAR CREEK ASSOCIATES, Inc. 9 Perdito Project - Exploration - 2017 MCA Flora Evaluation Sclerocactus polyancistrus – A total of 17 individuals or clusters of Mohave fish-hook cactus were located within the 50-meter buffer zone (22 total observations). This species was scattered on the hillsides along the route. The cactus was rarely flowering (Photos 10 through 12) making observations fairly difficult especially since this cactus is quite often found growing within the periphery of shrubs. It is estimated that there are 100 to 200 individuals within the survey buffer zone. Perhaps twice as many dead Mohave fish- hook cacti were found along the transects indicating a recent die-off, short life span, or simply the tangle of spines does not break down very quickly upon death. Several cacti were located on the faint two-track that the MCA route will follow and construction and road traffic will likely affect these individuals.

Oenothera caespitosa ssp. crinita – A total of four individuals of caespitose evening-primrose were located at three separate locations within the 50-meter buffer zone (five total observations). This species was fairly rare amongst the pockets of soil in the rock outcrops. The evening-primrose was past flowering although identification was still possible (Photo 8). It is estimated that there may be 10 – 20 individuals within the survey buffer zone. This species was mainly found in rock outcrops distant from the MCA route but construction and road traffic may affect several of these individuals.

Cryptantha tumulosa – One individual of New York Mountain cryptantha was located within the 50- meter buffer zone. This species was very rare in the survey area and was only found along a small drainage on the upper slopes of the surveyed area. The cryptantha was flowering and identification to species was verified (Photos 14 and 15). It is estimated that there may be less than 10 individuals within the survey buffer zone. This species was found distant from the MCA route but construction and road traffic may affect several of these individuals.

4.0 ANALYSIS

The proposed MCA route mainly follows wash bottoms or faint two-track routes on crests of hill that will require minimal or no cut-and-fill road construction. There will likely be no adverse effects on populations of Inyo rock daisy along the route since they are located at least 45 meters distant from the flagged route. Numerous crested onion individuals will likely be adversely affected by road construction and/or travel, although the species is fairly common in the survey area and adverse effects to the population as a whole will likely be very minimal. Several Mohave fish-hook cactus individuals may be adversely affected by the MCA road although there appears to be healthy population of this cactus in the area based on Bagley’s and Cedar Creek’s surveys. Adverse effects to caespitose evening-primrose and New York Mountain cryptantha will likely be minimal as only a few individuals were found in the area and at a distance from the proposed route.

CEDAR CREEK ASSOCIATES, Inc. 10 Perdito Project - Exploration - 2017 MCA Flora Evaluation 5.0 REFERENCES

Bagley, Mark. 2014. Unpublished results from floral surveys of the Perdito project area. GIS and Excel files.

Hickman, J.C., ed. 1993. The Jepson manual: higher plants of California. Univ. of Calif. Press, Berkeley, Calif. 1400 pp.

CEDAR CREEK ASSOCIATES, Inc. 11 Perdito Project - Exploration - 2017 MCA Flora Evaluation Photo 1 - Perdito - June 2, 2017 - Perityle inyoensis Photo 1 - Perdito - June 2, 2017 - Perityle inyoensis

Photo 3 - Perdito - June 2, 2017 - Perityle inyoensis Photo 4 - Perdito - June 2, 2017 - Perityle inyoensis Photo 5 - Perdito - June 2, 2017 - Perityle inyoensis Photo 6 - Perdito - June 2, 2017 - Allium atrorubens var. cristatum Photo 7 - Perdito - June 2, 2017 - Allium atrorubens var. cristatum

Photo 8 - Perdito - June 2, 2017 - Oenothera caespitosa ssp. crinita Photo 9 - Perdito - June 2, 2017 - Hecastocleis shockleyi Photo 10 - Perdito - June 2, 2017 - Sclerocactus polyancistrus Photo 11 - Perdito - June 2, 2017 - Sclerocactus polyancistrus

Photo 12 - Perdito - June 2, 2017 - Sclerocactus polyancistrus Photo 13 - Perdito - June 2, 2017 - Purshia mexicana var. dubia / Purshia stansburyana Photo 14 - Perdito - June 2, 2017 - Cryptantha tumulosa Photo 15 - Perdito - June 2, 2017 - Cryptantha tumulosa EXHIBIT A

FIELD GUIDE OF SENSITIVE FLORA POTENTIALLY IN THE PERDITO PROJECT AREA

BLM CNPS Global State USFS Scientific Name (Synonyms) Common Names Status Rank Rank Rank

Allium atrorubens var. cristatum Crested onion 4.3 G4T4 S4

Astragalus cimae var. sufflatus Inflated Cima milkvetch BLMS 1B.3 G3T3 S2

Boechera shockleyi Shockley's rock cress USFSS 2B.2 G3 S2

Cryptantha tumulosa New york mountain cryptantha 4.3 G4 S4

Cymopterus ripleyi var. saniculoides Ripley's springparsley BLMS 1B.2 G3G4T3Q S1

Ericameria nana dwarf goldenbush 4.3 G5 S4

Erioneuron pilosum Hairy erioneuron 2B.3 G5 S3

Erythranthe calcicola Limestone monkeyflower BLMS 1B.3 G2 S1

Hecastocleis shockleyi Shockley's prickleleaf 3 G3G4 S3S4

BLMS Mentzelia inyoensis Inyo blazingstar USFSS 1B.3 G3 S3

Oenothera caespitosa ssp. crinita Cespitose evening-primrose 4.2 G5T4T5 S4

Oxytheca watsonii Watson's oxytheca 2B.2 G3 S1

Perityle inyoensis Inyo rockdaisy BLMS 1B.2 G2 S2

Purshia mexicana var. dubia Mexican cliffrose G5

Sclerocactus polyancistrus Mojave fish hook cactus 4.2 G3 S3

Allium atrorubens var. cristatum - Crested onion

Flowering Time: April to June

Habitat: 1240-2750m, Sandy, rocky, or clay soils on desert slopes and mountains; Joshua tree woodland, Mojavean desert scrub, Pinyon and juniper woodland

Toxicity: Minor

Characteristics: Tepals pale pink with darker pink midveins, lance-ovate to ovate, apex margins flat, not becoming involute.

CEDAR CREEK ASSOCIATES, Inc. A - 1 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A Astragalus cimae var. sufflatus - Inflated Cima milkvetch

Flowering Time: April to June

Habitat: 1570-2090m, Calcareous substrates, with pinyon pine, generally sagebrush. Endemic to the eastside of the Inyo Mountains; Desert Scrub to Pinyon-Juniper.

Characteristics: Perennial with glabrous green foliage and stems up to 12in (3dm) long. Leaves are 2-4in (5- 10cm) long with ovate to roundish leaflets, most about ½ in (13mm) long. Flowers ½ in (13mm) or more long, are slender with the banner gently curved upward - Petals purple with white wing tips. Pods thick-papery, inflated, 1 ¼ - 1 ½ in (3-4cm) long and ½ - ¾ in (6-13mm) wide, abruptly straight across the base and tapered toward a pointed tip. The distinguishing features are the pod’s square end and its long stem (strip), ¼ - ½ in (6- 13mm) long, which protrudes from the calyx when mature. (Natural History of the White-Inyo Range, Eastern California edited by Clarence A. Hall)

CEDAR CREEK ASSOCIATES, Inc. A - 2 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A Boechera shockleyi - Shockley's rock cress

Flowering Time: May

Perennials; usually short-lived; sexual; caudex not woody, (rarely with persistent, crowded leaf bases). Stems usually 1 per caudex branch, arising from center of rosette near ground surface, (0.8-)2-5 dm, densely pubescent proximally, trichomes short-stalked, 7-12-rayed, 0.1-0.2 mm, densely to sparsely pubescent distally. Basal leaves: blade oblanceolate, 3-10 mm wide, margins entire, not ciliate, surfaces densely pubescent, trichomes short-stalked, 7-12-rayed, 0.1-0.2 mm. Cauline leaves: 14-60, concealing stem for most of length; blade auricles 0.5-4 mm, surfaces of distalmost leaves densely pubescent. Racemes 20-70-flowered, usually unbranched. Fruiting pedicels divaricate-ascending, straight, 7-28 mm, pubescent, trichomes appressed, branched. Flowers ascending at anthesis; sepals pubescent; petals lavender, 6-9 × 0.8-1.2 mm, glabrous; pollen ellipsoid. Fruits divaricate-ascending, not appressed to rachis, not secund, usually curved, rarely straight, edges parallel, 4.5-11 cm × 1.5-2 mm; valves glabrous or sparsely pubescent throughout; ovules 140- 190 per ovary; style 0.05-0.6 mm. Seeds sub-biseriate, 1-1.3 × 0.7-0.8 mm; wing distal or, rarely, absent, 0.05- 0.1 mm wide.

Boechera shockleyi is a distinctive sexual species recognizable by the combination of strongly overlapping cauline leaves, a dense covering of minute, 7-12-rayed trichomes, and relatively long, curved, divaricate-ascending fruits with sub-biseriate seeds. It is most similar to B. inyoensis, but differs from that species in its narrower (0.8-1.2 versus 1.2-2 mm) petals, eciliate basal leaves with smaller (0.1-0.2 versus 0.2-0.7 mm) trichomes, greater number (140-190 versus 74-134) of ovules per ovary, and shorter (1-1.3 versus 1.7-2 mm) seeds with distal (versus continuous) wings.

CEDAR CREEK ASSOCIATES, Inc. A - 3 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A

@Flora of North America

CEDAR CREEK ASSOCIATES, Inc. A - 4 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A Cryptantha tumulosa - New york mountain cryptantha

Flowering Time: April - June

Characteristics: Perennial 7-25cm tall, branched woody caudex. Stem generally many; dense-tomentose, hairs ± yellow, spreading. Leaf basal rosettes generally many, 3-6cm; basal oblanceolate to ± spoon shaped, ± folded, thick, ± gray, dense-silky-tomentose, bristles appressed, bulbous-based. Inflorecence dense, cylindric, narrow, generally not elongated in front; pedicel elongated in front to 3-6mm. Flower calyx 3.5-4.5mm, 7-10mm in front, bristles dense, ± yellow, soft; corolla deciduous, tube 3.5-4.5mm, limb 6-8mm diameter, appendages yellow. Fruit nutlets generally 1-3, 3-4mm, wide-ovate, occasionally constricted above, ± gray, dull, margin sharp-angled to a ±flat narrow rim; abaxially ± tubercled, ridge rounded, ± indistrict near base; adaxially ± papillate, tubercled, attachment scar edges wide-triangular-gapped, edges ± raised; axis beyond nutlet. (The Digital Jepson Manual: Vascular Plants of California edited by Bruce G. Baldwin, Douglas Goldman, David J Keil, Robert Patterson, Thomas J. Rosatti)

CEDAR CREEK ASSOCIATES, Inc. A - 5 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A

CEDAR CREEK ASSOCIATES, Inc. A - 6 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A Illustration from Mozingo and Williams, 1980. Photographer: Jeanne R. Janish Photo Date: 1980

Cymopterus ripleyi var. saniculoides - Ripley's springparsley

Flowering Time: April to June

Habitat: 1000-1660m, Gravelly, sandy, carbonate, Joshua tree woodland, Mojavean desert scrub

Characteristics: Perennial herb without hairs, 4 - 6 inches (10-15cm) tall. Leaf round, 3/4 - 2 inches (2-5cm) long, with a leaf stem 1 1/8 - 4 inches (3-10cm) long. Leaflets wedge-shaped and 3-lobed, with each lobe being lobed. Inflorescence is a dense, spherical umbel. Petals are purple. Fruit is hairy, wedge-shaped to obovate, 1/4 inch (6-7mm) long. (http://www.blm.gov/ca/st/en/prog/ssp/plants/cymopterus_ripleyi_saniculoides.html)

CEDAR CREEK ASSOCIATES, Inc. A - 7 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A Ericameria nana - Dwarf goldenbush

Flowering Time: July to November

Habitat: 1300-2900m, Arid rocky plains, desert mountain cliffs, crevices. Pinyon and juniper woodland (rocky, carbonate or granitic), crevices.

*Some populations of Ericameria nana exhibit extreme variation in leaf shape and in phyllary apex length and shape. Whether such variants represent distinct taxa remains to be tested.

CEDAR CREEK ASSOCIATES, Inc. A - 8 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A Erioneuron pilosum - Hairy erioneuron

Flowering Time: May to June

Habitat: 1220-1810m, Rocky slopes, ridges, pinyon/juniper woodland; Pinyon and juniper woodland (rocky, sometimes carbonate)

CEDAR CREEK ASSOCIATES, Inc. A - 9 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A Erythranthe calcicola - Limestone monkeyflower

Flowering Time: April to September

Habitat: 915-2165m, usually carbonate, usually talus slopes. Joshua tree woodland, Mojavean desert scrub, Pinyon and juniper woodland.

Characteristics: Annual herb. Plants 2–15 cm tall 3 1–8 cm wide; sparsely glandular pubescent. Stems erect, simple to branched, turning reddish with age; internodes 0.5–1.5 cm. Cotyledons persistent, ovate to round, 1– 6 mm long, with clasping bases. Leaves opposite, epetiolate or with petioles short (0.5–1 mm long), connate at the base; blades 3–25 mm long 3 2–8 (10) mm wide, lanceolate to ovate, palmately veined with three prominent veins from the base in wider leaves, margins entire or sometimes toothed. Flowers solitary in each axil, fruiting pedicels 3–20 mm, exceeding calyx, erect to ascending. Calyx 4–8 mm long 3 2–4 (5) mm wide, widely campanulate to cylindric, enlarging in fruit; costa prominent, darker than intercostal regions; calyx teeth equal, 0.5–1 mm long, acute to obtuse, margins ciliate. Corolla 6–13 mm long 3 3–7 (9) mm wide, yellow or white with a yellow throat, early deciduous, lobes emarginate, limb weakly zygomorphic; tube-throat 5– 10 mm long, cylindric, expanding gradually to the limb, palate sparsely bearded, spotted with red markings. Stamens didynamous, 3–9 mm long; yellow, glabrous, included. Gynoecium 5–10 mm long, light yellow to white; style glabrous; stigma lobes slightly apically fringed, subequal, included. Capsules 4– 8 mm long, included to equal to calyx, cylindric, thin walled and fragile, dehiscing to base along both sutures. Seeds 0.5– 0.9 mm long 3 0.2–0.3 mm wide, elliptic to ovoid, brown.

Photo by Naomi Fraga

CEDAR CREEK ASSOCIATES, Inc. A - 10 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A

CEDAR CREEK ASSOCIATES, Inc. A - 11 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A Hecastocleis shockleyi - Shockley's prickleleaf

Flowering Time: May to July

Habitat: 1130-1880m, Dry, rocky slopes

Characteristics: Stiff, much branched shrub (4-7dm); glandular puberulent or becoming glabrous except for tufts of soft hair in axils of persistent leaf bases. Leaves simple and alternate. Primary leaves 1-3 cm long, linear to linear-lanceolate, sessile, spine-tipped, sparsely spiny-dentate. Flower heads 1-flowered, sessile, in dense, head-like clusters, surrounded by involucre of persistent, ovate, spiny-toothed, net veined bracts. True involucre narrowly cylindric. Corolla pink to reddish purple in bud, greenish white in flower; anthers purple. Pappus a crown of fringed scales. (NatureServe)

CEDAR CREEK ASSOCIATES, Inc. A - 12 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A Mentzelia inyoensis - Inyo blazingstar

Flowering Time: April to Oct

(Thompson and Prigge 2004).

CEDAR CREEK ASSOCIATES, Inc. A - 13 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A Oenothera caespitosa ssp. crinita - Cespitose evening-primrose Flowering Time: July to September (Calflora), June to September (Jepson) Habitat: 1400 to 3340m, Calcium soils in bristlecone-pine forest, pinyon/juniper woodland, desert scrub. Characteristics:

CEDAR CREEK ASSOCIATES, Inc. A - 14 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A Oxytheca watsonii - Watson's oxytheca Flowering Time: May to July (Calflora), June to Oct (Jepson/FloraNA) Habitat: 1200-2000m, Usually occurs in wetlands, but occasionally found in non wetlands [U.S. Fish & Wildlife Service.] Creosote Bush Scrub, Joshua Tree Woodland, wetland-riparian.

Oxytheca watsonii is an uncommon species known only from scattered locations. The name was misapplied in pre-1980 California floras to Acanthoscyphus parishii var. goodmaniana.

CEDAR CREEK ASSOCIATES, Inc. A - 15 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A

MOZINGO AND WILLIAMS, 1980.

CEDAR CREEK ASSOCIATES, Inc. A - 16 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A Perityle inyoensis - Inyo rockdaisy

Flowering Time: June to August (Calflora, CNPS), June to September (Jepson)

Habitat: 1800-2800m, Dry, rocky slopes rocky, carbonate. Great Basin scrub, Pinyon and juniper woodland

Characteristics: Perennials or subshrubs, 12–25 cm; pilose-villous indument intermixed with short glandular hairs. Leaves (opposite or alternate): petioles 5–20(–50) mm; blades orbiculate, ovate, or ovate-deltate, 8–18(– 21) × 6–12(–15) mm, margins serrate to serrate-lobed. Heads borne singly or (2–3) in corymbiform arrays, 7– 8.5(–9) × 5–7(–8) mm. Peduncles 8–40 mm. Involucres campanulate. Phyllaries 14–21, linear-lanceolate to sub-lanceolate, 5.5–6.5 × 1.1–1.5 mm. Ray florets 0. Disc florets 35–60; corollas yellow, tubes 1.4–1.6 mm, throats subtubular to subfunnelform, 2–2.4 mm, lobes 0.6–0.7 mm. Cypselae narrowly oblanceolate to suboblanceolate, (2.5–)3–3.5 mm, margins thin-calloused, short-hairy; pappi usually inconspicuous, callous crowns, rarely of minute scales. (Flora of North America)

CEDAR CREEK ASSOCIATES, Inc. A - 17 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A Purshia mexicana var. dubia - Mexican cliffrose

Flowering Time: Apr to May (-Oct)

Habitat: 920-2660m, Pinyon-juniper, Joshua tree, yellow pine woodlands, arid desert scrub, desert chaparral.

Characteristics: Taxonomy is very inconsistent across databases. Due to lack of entries of specific variety, status of this taxa is unclear.

CEDAR CREEK ASSOCIATES, Inc. A - 18 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A Sclerocactus polyancistrus - Mojave fish hook cactus Flowering Time: April to July Habitat: 500-2500m, Limestone areas, hills and canyons, alluvial slopes; creosote-bush scrub, Joshua-tree woodland; Rocky alluvial, often alkaline soils, Mojave desert scrub.

Characteristics: Stems unbranched or in clusters, cylindric or elongate cylindric, 10-40(-45) × 5-9 cm; ribs 13- 17, well developed, tubercles not evident on ribs. Spines dense, obscuring stems; radial spines 10-15(-18) per areole, white, straight, flat, 20-50 mm, glabrous; central spines 9-12 per areole, 5-8 hooked, others straight, terete to angled; abaxial and lateral central spines 6-8 per areole, red or reddish brown (rarely yellow), some hooked, (30-)56-100 × 0.7-1.2 mm; adaxial central spines usually 3 per areole, white, usually curved or twisted, flat, usually 37-86(-130) × 1.7-3.4 mm. Flowerswith spicy, pungent odor, funnelform, 5-10 × 5-9 cm; outer tepals with greenish purple midstripes and rose-purple or magenta margins, cuneate-spatulate, usually 15-30 × 6-9 mm; inner tepals rose-purple to magenta (rarely white), largest tepals ovate-lanceolate, 24-45 × 9-12 mm; filaments greenish yellow; anthers cream; style grooved, not papillate. Fruits irregularly dehiscent at base, green, tan, or red, barrel-shaped, 22-50 × 12-25 mm, dry at maturity; scales few, white fringed. Seeds black, 2.7-3.7 × 2-2.5 mm, shiny; testa with fine, rounded papillae.

CEDAR CREEK ASSOCIATES, Inc. A - 19 Perdito Project - Exploration - 2017 MCA Flora Evaluation - Appendix A