BLM

U.S. Department of the Interior Bureau of Land Management

Environmental Assessment

DOI-BLM-NV-B020-2017-0012-EA Hasbrouck Mine Project

and

Hasbrouck 55 Kilovolt Reroute and 120 Kilovolt Transmission Line Project

General Wildlife Supplemental Environmental Report

July 2020

PREPARING OFFICE

U.S. Department of the Interior Bureau of Land Management Battle Mountain District, HASBROUCK MINE PROJECT GENERAL WILDLIFE SUPPLEMENTAL ENVIRONMENTAL REPORT

TABLE OF CONTENTS

Page 1 INTRODUCTION ...... 1 1.1 Project Description ...... 1 1.1.1 Hasbrouck Mine ...... 1 1.1.2 Hasbrouck 55 kV Reroute and 120 kV Transmission Line...... 3 1.2 Applicant-Committed Environmental Protection Measures ...... 6 1.3 Project Alternatives ...... 7 1.3.1 No Action Alternative ...... 7 1.4 Alternatives Considered but Eliminated from Detailed Analysis ...... 8 1.4.1 Alkali Spring Valley Basin Water Supply Alternative ...... 8 1.4.2 Relocation of Heap Leach Facility Alternative ...... 8 1.4.3 Relocation of Waste Rock Storage Areas Alternative ...... 8 2 WILDLIFE ...... 8 2.1 Affected Environment ...... 8 2.2 Environmental Consequences ...... 9 2.2.1 Proposed Action ...... 10 2.2.2 No Action Alternative ...... 11 2.3 Cumulative Impact Analysis ...... 11 2.3.1 Past, Present, and Reasonably Foreseeable Future Actions ...... 12 2.4 Evaluation of Potential Cumulative Impacts ...... 15 2.4.1 Proposed Action ...... 15 2.4.2 No Action Alternative ...... 16 3 REFERENCES ...... 17

LIST OF TABLES

Table 1: Surface Disturbance for the Proposed Project Facilities ...... 6 Table 2: Past and Present Rights-of-Way Actions in the CESA...... 14 Table 3: Past and Present Minerals Actions in the CESA ...... 14

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LIST OF FIGURES

Figure 1: NEPA Project Area, Access, and Land Status ...... 2 Figure 2: Proposed Facilities ...... 4 Figure 3: Proposed Transmission Line Details ...... 5 Figure 4: Biology and Soils CESA ...... 13

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LIST OF ACRONYMS AND ABBREVIATIONS

ADR Adsorption Desorption Recovery BITD Best in the Desert BLM Bureau of Land Management CESA cumulative effects study area CFR Code of Federal Regulations EA Environmental Assessment EMS EM Strategies, Inc. EPM Environmental Protection Measure HLF heap leach facility HMA herd management area kV kilovolt LR2000 Legacy Rehost System Mine Project Hasbrouck Mine Project NDOW Nevada Department of Wildlife NVE NV Energy OHV off-highway vehicle RFFA reasonably foreseeable future action ROW right-of-way ROW Project Hasbrouck 55 kV Reroute and 120 kV Transmission Line Project SER Supplemental Environmental Report US United States US 95 United States Highway 95 WK-AH WK – Allied Hasbrouck LLC WRSA waste rock storage area

iii 20200701_Hasbrouck_wildlife_SER_Public.docx HASBROUCK MINE PROJECT GENERAL WILDLIFE SUPPLEMENTAL ENVIRONMENTAL REPORT

1 INTRODUCTION

This Supplemental Environmental Report (SER) describes the existing conditions and outlines the direct, indirect, and cumulative impacts on general wildlife and their habitat that may occur at the Hasbrouck Mine Project (Mine Project) and Hasbrouck 55 kilovolt (kV) Reroute and 120 kV Transmission Line Project (Right-of-Way [ROW] Project). Both actions make up the entire Project. Environmental impacts for both actions are discussed in this SER and are also included in the same environmental assessment (EA) document. The Project is located on public lands administered by the Bureau of Land Management (BLM), Battle Mountain District, Tonopah Field Office and private lands controlled by WK-Allied Hasbrouck LLC (WK-AH). The Project is located approximately 5.5 miles south of Tonopah, Nevada. The Project is in parts of Sections 3, 4, 9, and 10, Township 1 North (T1N), Range 42 East (R42E), and Sections 4, 8 through 10, 15 through 17, 20, 21, 27 through 29, and 32 through 34, T2N, R42E, Mount Diablo Base and Meridian, Esmeralda County, Nevada (Project Area) (Figure 1). The Project Area can be accessed via a turn-out off United States (US) Highway 95 (US 95). US 95 passes through the Project approximately 0.25 mile west of the Hasbrouck deposit and is an all-weather, all-season roadway suitable for commercial semi-trailer traffic. A 2017 Baseline Biological Survey Report (EM Strategies, Inc. [EMS] 2017a) was prepared to describe the existing biological conditions for the Project. Information from the baseline report regarding general wildlife is summarized in this SER.

1.1 Project Description

1.1.1 Hasbrouck Mine

WK-AH proposes to construct, operate, reclaim, and close, in a phased manner, an open pit, heap leach, and precious metal mining operation. In general, the proposed mining operations would consist of an open pit mine and waste rock storage areas (WRSAs) on public lands, and processing of ore using heap leach technology on private land. The Project would include the following major components:

• One open pit; • Two WRSAs; • Ore crushing and conveying system; • A lime silo and ore agglomeration facility; • Ore stockpiles; • Power switch yard; • A clay borrow area; • A water delivery system; • A heap leach facility (HLF) with associated process water tanks and an event pond; • Storm water diversion ditches and storm water sediment basins; • An Adsorption Desorption Recovery (ADR) processing plant; • A refinery;

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30 26 26 25 29 28 27 26 25 30 29 28 27 Copyright:© 2013 National Geographic Society, i-cubed 35 36 31 32 33 34 35 36 Explanation BATTLE MOUNTAIN DISTRICT OFFICE Tonopah Field Office BUREAU OF LAND MANAGEMENT Project Area 1553 South Main Street Excluded from Project Area Tonopah, Nevada 89049 HASBROUCK MINE PROJECT

Land Status No warranty is made by the Bureau of Land Management NEPA Project Area, Access, as to the accuracy, reliability, or completeness of these data Bureau of Land Management for individual use or aggregate use with other data. Original data were compiled from various sources. This information may and Land Status not meet National Map Accuracy Standards. This product was Forest Service developed through digital means and may be updated without notification. Private Figure 1

0 1 2 Miles $ 01/28/2020 WK-ALLIED HASBROUCK LLC GENERAL WILDLIFE HASBROUCK MINE PROJECT SUPPLEMENTAL ENVIRONMENTAL REPORT

• Access and haul roads; • Ancillary facilities that include the following: haul and secondary roads; ready line; maintenance area; reagent and fuel storage; storage and laydown yards; explosive magazines; meteorological station; warehouse; truck maintenance shop; assay laboratory; administration/security building; growth media stockpiles; and solid and hazardous waste management facilities; • Exploration in the vicinity of the open pit to better define the ore body; and • Reclamation and closure, including the development of an evapotranspiration cell.

WK-AH proposes to mine approximately 36 million tons of heap leach ore and 40 million tons of waste rock (for an approximate maximum total of 76 million tons of material). The material (both ore and waste) would be extracted from the open pit using conventional open pit mining methods of drilling, blasting, loading, and hauling. WK-AH would use hydraulic shovels or front-end loaders to load the ore and waste into the haul trucks. The haul trucks would transport the waste rock to the WRSA near the open pit, and transport the ore material to the crushing, conveying and stacking facilities. The crushing facility would use a combination of stockpiles, grizzlies, crushers (jaw, cone, and grinding rolls) and screens to reduce the material size. After being crushed the ore would be agglomerated using cement and barren solution after which it would travel by overland conveyor to the HLF where it would be stacked and leached. The pregnant leach solution would be processed using ADR. The adsorbed carbon would be stripped using acid wash, desorption, and carbon regeneration. The desorbed product would be refined using electrowinning and retorting before being processed in a smelting furnace. The resultant doré would be shipped off site for further refining and sale. Exploration activities, as Phase I activities, are expected to disturb up to ten acres and would occur within the footprint of the open pit, waste rock dumps, and heap leach facility. The acreage of proposed surface disturbance associated with the Mine Project under Phase II is approximately 673 acres (Figure 2 and Table 1).

1.1.2 Hasbrouck 55 kV Reroute and 120 kV Transmission Line

A Plan of Development and ROW applications (SF-299 Forms) have been submitted to the BLM for the ROW Project. Sierra Pacific Power Company d/b/a NV Energy (NVE) has requested a BLM long-term ROW grant for approximately 29,189 linear feet, or approximately 5.5 miles, of a 40-foot wide permanent ROW on public land (approximately 26.8 acres) for an overhead 120 kV transmission line, four 50-foot radius angle structure sites, and an approximately 500 feet wide by 500 feet long ROW for a switching station (N-95909) (Figure 3). The rerouted 55 kV overhead transmission line would be on the same poles as the 120 kV overhead transmission line for approximately 23,778 linear feet, then would continue northeast separately for approximately 481 linear feet. This small segment would also include a 40-foot wide long-term ROW of approximately 0.3 acre (Nev 043264). A 300-foot wide short-term ROW for the 29,189 linear feet long 120 kV transmission line, three short-term 400-foot radius angle structure sites, and an additional 450 feet long by 900 feet wide short-term disturbance area for the proposed Siebert Switching Station are also being requested (N-96243) (Figure 3 and Table 1).

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Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community

Explanation BATTLE MOUNTAIN DISTRICT OFFICE Project Area (! Existing Monitoring Well Tonopah Field Office BUREAU OF LAND MANAGEMENT Excluded from Project Area (! Proposed Monitoring Well 1553 South Main Street Borrow Source Berm Tonopah, Nevada 89049 HASBROUCK MINE PROJECT Growth Media Stockpile Crusher/Conveyer System Heap Leach Pad Culvert D No warranty is made by the Bureau of Land Management Proposed Facilities Mine Road Fence as to the accuracy, reliability, or completeness of these data Pit Power Line for individual use or aggregate use with other data. Original data were compiled from various sources. This information may Pond Switch Yard not meet National Map Accuracy Standards. This product was developed through digital means and may be updated without notification. Septic Field Water Line Stormwater Diversion Channel Contour Figure 2 Structure Existing Fiber Optic Line Waste Rock Storage Area 0 2,000 4,000 01/31/2020 Yard Feet $ 08 10 11 09 Winnemucca !( Elko !(

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Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community

Explanation BUREAU OF LAND MANAGEMENT Hasbrouck Mine Project Area Proposed New 120 kV Transmission Line Land Status Transmission Line Work Area (Short-Term)(N-96243) !( Proposed Transmission Line Poles Bureau of Land Management HASBROUCK 55 KV REROUTE AND Existing Transmission Line [N-33242] Siebert Switching Station ROW (Long-Term)(N-95909) Private 120 KV TRANSMISSION LINE PROJECT Existing 55 kV Transmission Line [Nev 043264] Siebert Switching Station Disturbance Area Limits BATTLE MOUNTAIN DISTRICT OFFICE Proposed Transmission XXExisting 55 kV Transmission Line to be Rerouted [Nev 043264] NVE Temporary Staging Area Tonopah Field Office Line Details Proposed 55 kV Transmission Line Realignment South Access Road 1553 South Main Street Proposed 55 kV Transmission Line Right-of-Way (Long-Term)(Nev 043264) Existing Highway Tonopah, Nevada 89049 Figure 3 Existing Roads Proposed 120 kV Transmission Line Right-of-Way (Long-Term)(N-95909) 0 1,000 2,000 06/19/2020 Hasbrouck Switching Station Feet $ WK-ALLIED HASBROUCK LLC GENERAL WILDLIFE HASBROUCK MINE PROJECT SUPPLEMENTAL ENVIRONMENTAL REPORT

Table 1 presents the surface disturbance associated with the Project, by phase, by facility type.

Table 1: Surface Disturbance for the Proposed Project Facilities

Phase I Hasbrouck Disturbance Phase II Hasbrouck Disturbance Component Public Private Total Public Private Total Acres Acres Acres Acres Acres Acres Open Pit 0 0 0 0 77.7 77.7 WRSAs 0 0 0 115.9 75.8 191.7 Heap Leach Facility 0 0 0 169.8 0 169.8 Process/Administration Area1 0 0 0 6.4 0 6.4 Laydown Area 0 0 0 45.8 0.2 46.0 Roads 0 0 0 32.2 21.9 54.1 Water Pipeline2 0 0 0 47.0 0 47.0 Fence3 0 0 0 22.3 2.5 24.8 Borrow Areas 0 0 0 16.6 0 16.6 Diversion Ditches 0 0 0 6.9 1.4 8.3 Growth Media Stockpiles 0 0 0 30.5 0.1 30.6 Exploration4 5.0 5.0 10.0 0 0 0 Mine Project Total 5.0 5.0 10.0 493.4 179.6 673.0 ROW Short-Term Disturbance Total 0 0 0 234.7 0 234.7 ROW Long-Term Disturbance Total 0 0 0 32.8 0.0 32.8 Total 5.0 5.0 10.0 760.9 179.6 940.5 1This includes the ADR plant, Administrative building, parking lot, security building, reagent storage, assay laboratory, septic field, and switch yard 2Inlcudes the water pipeline from the Three Hills Mine to the Project facilities 3Includes the perimeter fence at 32,963 feet with a 30-foot construction disturbance width and a 4,921-foot berm on the west side of the Project Area with a 20-foot width 4Phase I exploration disturbance includes the 4.2 acres associated with the Hasbrouck Notice NVN-089750. Under Phase II the exploration disturbance is consumed by the open pit, WRSA, and HLF.

1.2 Applicant-Committed Environmental Protection Measures

WK-AH would commit to the following Environmental Protection Measures (EPMs) applicable to general wildlife to prevent unnecessary or undue degradation during construction, operation, and reclamation of the Project. A complete list of EPMs pertaining to other resources can be found in the EA prepared for the Project (BLM 2020a).

Hasbrouck Mine

• WK-AH would implement the Noxious Weed Monitoring and Control Plan (EMS 2017b) prepared for the Project during construction activities and continuing through operations and reclamation. Management strategies include prevention (i.e., monitoring of new weed infestations, and awareness and education), implementation of cultural practices (practices that reduce the potential for weed establishment), and treatment (i.e., mechanical treatment, chemical treatment, and biological treatment).

• All Project-related traffic would observe a prudent speed limit of a maximum of 25 miles per hour within the Project Area to enhance public safety, protect wildlife and livestock, and minimize dust emissions.

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Hasbrouck 55 kV Reroute and 120 kV Transmission Line

NVE would commit to the following EPMs applicable to general wildlife to prevent unnecessary or undue degradation during construction, operation, and reclamation of the Project. A complete list of EPMs pertaining to other resources can be found in the EA prepared for the Project (BLM 2020a).

• Project vehicle speeds would be limited to 20 mph in the construction area.

• Following Project construction, areas of disturbed land no longer required for operations would be reclaimed to promote the establishment of native plant and wildlife habitat.

• Noxious weeds would be controlled through implementation of the following best management practices: concurrent reclamation efforts; schedule weed management activities to maximize the effectiveness of control efforts on reclaimed areas; washing heavy equipment prior to entering the Project Area; and avoiding areas of known invasive, non-native, and noxious weeds during periods when the weeds could be spread by vehicles.

• Noxious weeds can readily invade disturbed areas. NVE would be responsible for the following: 1) identifying noxious weeds in the ROWs (noxious weed information would be provided by the BLM); 2) excluding noxious weeds from disturbed areas until reclamation has been accepted and released; and 3) ensuring that all equipment is “weed free” before traveling to and from the Project Area so that noxious weeds are not spread to new locations. All vehicles originating from outside southern Nevada would be cleaned in a powerwash in Tonopah. When noxious weeds are encountered in the ROWs, documentation of their location and extent would be provided to the BLM as soon as possible. NVE would obtain approval from the BLM-authorized officer prior to any herbicide application. NVE would contact the BLM’s noxious weed program lead regarding any issues concerning noxious weeds.

1.3 Project Alternatives

1.3.1 No Action Alternative

Under the No Action Alternative, the Project would not be approved by the BLM; however, the area would remain available for other multiple use activities as approved by the BLM and Nevada Division of Environmental Protection. WK-AH would continue Notice-level exploration activities under the Hasbrouck Notice (NVN-089750) in the Project Area on public land. The area would remain available for future exploration and mining activities or for other purposes, as approved by the BLM. The objective of the No Action Alternative is to describe the impacts that would result if the Project were not implemented. The No Action Alternative forms the baseline for which the impacts of all other alternatives can be measured.

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1.4 Alternatives Considered but Eliminated from Detailed Analysis

1.4.1 Alkali Spring Valley Basin Water Supply Alternative

Under this alternative, the Project water supply would be obtained within the Alkali Spring Valley Hydrographic Basin. This basin was designated by the Nevada State Engineer in March 2016. WK-AH would need to apply for a new water right in this basin. This could delay the Project schedule, denying WK-AH the opportunity to permit the Project in a timely manner. Therefore, this alternative has been eliminated from further analysis.

1.4.2 Relocation of Heap Leach Facility Alternative

Under this alternative, the HLF would be relocated. The current location of the HLF is adjacent to the administrative facilities, keeping most of the mine workers away from the open pit and blasting activities, and near the lab and processing facilities. Moving the HLF closer to the open pit would not be possible, since the WRSAs need to be close to the open pit. The only option for relocation of the HLF would be further from its current location, resulting in additional impacts to air quality, wildlife, special status , traffic, and public safety. If the HLF were moved to the east, it would be moved closer to more eagle nests; if it was moved west, the haul trucks would have to cross US 95. Therefore, this alternative has been eliminated from further analysis.

1.4.3 Relocation of Waste Rock Storage Areas Alternative

Under this alternative, the WRSAs would be relocated. The current location of the WRSAs locates them adjacent to the open pit. If the WRSAs were to be relocated further from the open pit, it would create additional surface disturbance for longer haul roads, resulting in additional impacts to air quality, wildlife, special status species, traffic, noise, and public safety. If the WRSAs were moved to the east, they would be moved closer to more eagle nests; if they were moved west, the haul trucks would have to cross US 95. Therefore, this alternative has been eliminated from further analysis.

2 WILDLIFE

2.1 Affected Environment

The Nevada Department of Wildlife (NDOW) was contacted to request information regarding wildlife use in the area. In a response letter dated March 21, 2017, NDOW indicated the following wildlife species have been observed in the vicinity of the Project Area: bobcat (Lynx rufus); chisel-toothed kangaroo rat (Dipodomys microps); common sagebrush (Sceloporus graciosus); common side-blotched lizard (Uta stansburiana); desert glossy ( elegans); gopher snake (Pituophis catenifer); Great Basin collared lizard (Crotaphytus bicinctores); Great Basin fence lizard (Sceloporus occidentalis longipes); Great Basin gopher snake (Pituophis catenifer deserticola); long-nosed leopard lizard (Gambelia wislizenii); long-tailed pocket mouse (Chaetodipus formosus); northern desert horned lizard (Phrynosoma platyrhinos platyrhinos); northern desert nightsnake (Hypsiglena chlorophaea deserticola); Panamint rattlesnake ( mitchellii stephensi); southwestern speckled rattlesnake (Crotalus pyrrhus); speckled rattlesnake

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(Crotalus mitchellii); western fence lizard (Sceloporus occidentalis); yellow-backed spiny lizard (Sceloporus uniformis); and zebra-tailed lizard (Callisaurus draconoides).

General wildlife field surveys were conducted in the Project Area on foot and by vehicle June 14, June 21 to 23, and July 5 to 7, 2017 (EMS 2017a). A total of eight species and four species were detected by sign (e.g., scat, bones, tracks, feathers) in the Project Area. The observed or detected by sign included: black-tailed jackrabbit (Lepus californicus); coyote (Canis latrans); (Sylvilagus audubonii); wild burro (Equius asinus); kangaroo rat (Dipodomys spp.); pronghorn antelope (Antilocapra americana); white-tailed antelope ground squirrel (Ammnospermophilus ieucurus); and woodrat (Neotoma spp). The observed or detected by sign included: Great Basin collared lizard; common side-blotched lizard; western fence lizard; and zebra-tailed lizard. Although these were the species observed during the June and July 2017 field surveys, potential habitat is present for other wildlife species as well (EMS 2017a).

Big game species

NDOW reported that occupied pronghorn antelope (Antilocapra americana) distributions exists within the entire Project Area and four-mile buffer area. No known occupied elk (Cervus canadensis) or mule deer (Odocoileus hemionus) distribution exists in the vicinity of the Project Area. No big game species were observed during the wildlife surveys. Pronghorn antelope scat was observed in a few locations, primarily in drainages in the southern portion of the Project Area (EMS 2017a).

2.2 Environmental Consequences

Effects Assessment Methodology

To qualitatively assess whether the Project would cause impacts to wildlife, information regarding general wildlife and their habitat was compiled from publicly available data of species’ distributions and habitat types and field surveys. Analysis of the intensity of effects to general wildlife were derived from the available project-specific information, current literature, and previous professional experience.

Effects Intensity Level Definitions

Negligible – Wildlife would not be affected, or impacts would not result in a loss of individuals or habitat.

Minor – Impacts on wildlife would be measurable or perceptible and local; however, the overall viability of the population or subpopulation would not be affected and without further adverse impacts the population would recover. Impacts on wildlife, such as displacement of nests or dens or obstruction of corridors, would be detectable. If mitigation is needed to reduce or rectify adverse impacts, it would be relatively simple to implement.

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Moderate – Impacts would be sufficient to cause a change in the population or subpopulation (e.g., abundance, distribution, quantity, or viability); however, the effect would remain local. The change would be measurable and perceptible, but the negative effects could be reversed. Mitigation would probably be necessary to reduce or rectify adverse impacts.

Major – Impacts would be substantial, highly noticeable, and could be permanent in their effect on population or subpopulation survival without active management. Extensive mitigation would likely be necessary to reduce or rectify adverse impacts, and its success could not be guaranteed.

Duration

Short-term – one year or less for an individual or habitat; five years or less for a population.

Long-term – Greater than one year for an individual or habitat; greater than five years for a population.

Context

Localized – Impacts are confined to a small part of the population, habitat, or range.

Regional – Impacts would affect a widespread area of suitable habitat or the range of the population or species.

2.2.1 Proposed Action

Direct impacts to general wildlife with suitable habitat in the Project Area would consist of habitat loss and disturbance from anthropogenic activities and potential collisions with Project equipment or vehicles. Indirect impacts resulting from habitat loss associated with vegetation removal from surface disturbing activities would result in a reduction of approximately 940.5 acres of wildlife habitat within the Project Area. The mine facilities and short-term ROW areas would be reclaimed and revegetated, returning approximately 830 acres of land to wildlife access and habitat. The open pit and long-term ROW area would not be reclaimed, permanently removing 110.5 acres from long-term wildlife habitat uses for most species. Noise from potential blasting, equipment and vehicles, and other human disturbances has the potential to disturb small and large mammals, but impacts are anticipated to be temporary, as the individuals would most likely disperse and return to the area. Approximately 110.5 acres of habitat would be permanently lost from the open pit and long-term ROW; however, habitat for small and large mammals occurs throughout the vicinity of the Project Area, so is not anticipated to cause a long-term permanent decline in the local or regional population. During final reclamation, a physical barrier (e.g., berms, fencing, or other appropriate barriers) would be installed along the open pit crest areas to control access by people, livestock, and large wildlife.

No noxious weed species were identified in the Project Area during the 2015 or 2017 botanical field surveys; however, the following invasive and non-native plant species were observed during the 2015 botanical field surveys: desert madwort (Alyssum desertorum); herb sophia (Descurainia

10 20200701_Hasbrouck_wildlife_SER_Public.docx WK-ALLIED HASBROUCK LLC GENERAL WILDLIFE HASBROUCK MINE PROJECT SUPPLEMENTAL ENVIRONMENTAL REPORT sophia); saltlover (Halogeton glomeratus); prickly Russian thistle (Salsola tragus); and Arabian schismus (Schismus arabicus) (Enviroscientists, Inc. 2015). Herb sophia, saltlover, and prickly Russian thistle were observed during the 2017 botanical field surveys (EMS 2017a). These invasive, non-native species may reduce the quality of habitat for wildlife. Project-related activities increase the potential for the spread of these species further reducing the quality of wildlife habitat in the Project Area. EPMs outlined in Section 1.2 would help reduce any impacts from noxious weeds, invasive and non-native species to wildlife habitat as a result of Project activities.

2.2.2 No Action Alternative

Under the No Action Alternative, up to five acres of surface disturbance would continue within the Project Area under Notice-level exploration activities. Reclamation of existing surface disturbance would gradually eliminate impacts to wildlife. Impacts to wildlife under the No Action Alternative would be similar, but proportionally less than the Proposed Action (approximately five acres of surface disturbing activities versus 940.5 acres associated with the Proposed Action).

2.3 Cumulative Impact Analysis

Council on Environmental Quality regulations define cumulative impacts as:

"...the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions [RFFAs] regardless of what agency (federal or non-federal) or person undertakes such other actions. Cumulative impacts can result from individual minor but collectively significant actions taken place over a period of time" (40 Code of Federal Regulations [CFR] 1508.7).

These cumulative impacts include both direct and indirect actions occurring as a result of Project activities and how they affect the resources of concern. The significance of impacts should be determined based on context (i.e., the setting of the Project) and intensity (40 CFR 1508.27). Significance exists if it is reasonable to anticipate a cumulatively significant impact on the environment (40 CFR 1508.27 (b)(7)). Intensity refers to the severity of the impact (40 CFR 1508.27 (b)). Factors that may be used to define the intensity of effects include the magnitude (relative size or amount of an effect), geographic extent, duration, and frequency of the effects.

This SER addresses those cumulative effects in the Cumulative Effects Study Area (CESA) that could result from Project implementation and reasonable alternatives, past actions, present actions, and RFFAs. For the purposes of this analysis and under federal regulations, ‘impacts’ and ‘effects’ are assumed to have the same meaning and are interchangeable. The cumulative impacts analysis was accomplished through the following three steps:

Step 1: Identify, describe, and map the CESA for the resource evaluated in this SER.

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Step 2: Define timeframes, scenarios, acreage, and activity estimates for cumulative impact analysis.

Step 3: Identify and quantify the location of possible specific impacts from the Project and judge the significance of these contributions to the overall impacts.

The CESA for general wildlife is a ten-mile radius around the Mine Project Area. This CESA encompasses approximately 305,341 acres and is shown on Figure 4 (Biology and Soils CESA).

2.3.1 Past, Present, and Reasonably Foreseeable Future Actions

2.3.1.1 Past and Present Actions

Livestock Grazing

Portions of the following grazing allotments are located within the CESA: Montezuma; Silver King; Sheep Mountain; San Antone; Ralston; and Monte Cristo.

Wild Horse and Burro Usage

Approximately 28,069 acres, or approximately nine percent of the CESA, is located within the Paymaster Herd Management Area (HMA). The remaining portion of the CESA is not located in any HMA.

Wildland Fires

There were no wildland fires reported within the CESA between 1910 and 2018.

Dispersed Recreation

Historical and present recreational activities that have occurred and are occurring within the CESA include primarily dispersed recreation activities such as the following: hunting; biking; primitive camping; rock hounding; and off-road vehicle (OHV) travel. There are several organized OHV events that sporadically receive BLM authorizations to travel through the CESA. These events include: the Rebelle Rally Race; the Zero1 Odyssey Tour; the Best in the Desert (BITD) “Vegas to Reno” Race Event; and the BITD Tonopah 250.

Rights-of-Way

The BLM’s Legacy Rehost System (LR2000) was used to query the various types of ROWs that have been authorized or constructed within the CESA by Section, Township, and Range, and include the following: roads and highways; power transmission; communication sites; telecommunications; water and irrigation facilities; and other ROWs. The exact acreage of surface disturbance associated with these ROWs cannot be quantified; however, it is assumed

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Explanation BATTLE MOUNTAIN DISTRICT OFFICE Tonopah Field Office BUREAU OF LAND MANAGEMENT Project Area 1553 South Main Street Excluded from Project Area Tonopah, Nevada 89049 HASBROUCK MINE PROJECT Biology and Soils CESA (305,341 acres) No warranty is made by the Bureau of Land Management Biology and Soils CESA as to the accuracy, reliability, or completeness of these data for individual use or aggregate use with other data. Original data were compiled from various sources. This information may not meet National Map Accuracy Standards. This product was developed through digital means and may be updated without notification. Figure 4

0 2.5 5 Miles $ 01/27/2020 WK-ALLIED HASBROUCK LLC GENERAL WILDLIFE HASBROUCK MINE PROJECT SUPPLEMENTAL ENVIRONMENTAL REPORT that these types of ROWs and the construction and maintenance associated with these facilities would create a level of surface disturbance that would contribute to cumulative impacts to various resources. The LR2000 database was queried on January 27, 2020, for the CESA. Any newly approved ROWs that have been added to the LR2000 database after this date are not included in the analysis. The approximate total acreages of existing and authorized ROWs within the CESA are included in Table 2.

Table 2: Past and Present Rights-of-Way Actions in the CESA

ROW Type Acres Roads and Highways 2,224 Power Transmission 1,063 Communication Sites 28 Telecommunications 875 Water and Irrigation Facilities 303 Total 4,493 Source: BLM 2020b

Mining and Mineral Exploration

The LR2000 database was queried by Section, Township, and Range to show the past and present mineral exploration or mining activities (i.e., authorized and expired Notices, authorized plans of operation, and mineral material disposal sites) that have been issued within the CESA. Past and present mineral exploration and mining activities in the CESA include historic and current mineral exploration and mining operations and mineral material disposal sites. Table 3 shows the results of the LR2000 query, in acres, of the exploration and mineral disposal activities within the CESA. The LR2000 database was queried on January 27, 2020, for the CESA. Any newly authorized Notices or plans of operation added to the LR2000 database after this date are not included in the analysis.

Table 3: Past and Present Minerals Actions in the CESA

Authorization Status Total Acres of Disturbance Authorized and Expired Notices 24 Authorized Plans of Operations 637 Mineral Material Disposal Sites 650 Total 1,311 Source: BLM 2020b

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2.3.1.2 Reasonably Foreseeable Future Actions

RFFAs in the CESA include livestock grazing, wild horse and burro usage, dispersed recreation, potential wildland fires, ROW construction and maintenance, and mineral exploration and mining.

2.4 Evaluation of Potential Cumulative Impacts

Past and Present Actions: Past and present actions that could have impacted and may be currently impacting general wildlife and their habitat include livestock grazing, wild horse and burro usage, dispersed recreation, ROW construction and maintenance, and mineral exploration. These activities had the potential to impact water resources and wildlife habitat or result in direct impacts to individuals in travel routes, or loss of forage, cover, and habitat, as well as disturbance of mating and brood rearing practices.

Authorized and expired mineral exploration and mining Notices or plans of operations, as well as mineral material disposal sites, total approximately 1,311 acres (approximately 0.4 percent of the CESA) of surface disturbance. Approximately 4,493 acres of ROWs were issued within the CESA that had the potential to create surface disturbance and disturb wildlife species and their habitat and vegetation. The CESA is also comprised of portions of NDOW Hunt Units 162, 171, 173, 212, 213, and 251, which have the potential to create noise and disturbance to wildlife from hunting activities. The CESA is also comprised of portions of the Montezuma, Silver King, Sheep Mountain, San Antone, Ralston, and Monte Cristo grazing allotments, and Paymaster HMA. Livestock grazing and wild horse and burro usage and associated management could have contributed to the establishment and spread of noxious weeds, invasive and non-native species, which could have had an indirect effect on wildlife and their habitat. However, disturbance to wildlife and their habitat from past and present actions would have been reduced through reclamation and seeding of disturbed areas and natural recolonization of native species. The past and present actions that are quantifiable have disturbed approximately 5,804 acres, or 1.9 percent of the CESA. There are no data on the number of acres reclaimed. State and federal regulations require reclamation; therefore, it is reasonable to assume that some areas have been reclaimed, become naturally stabilized, or have naturally revegetated over time.

RFFAs: Potential impacts to wildlife and their habitat from livestock grazing, wild horse and burro usage, dispersed recreation, potential wildland fires, ROW construction and maintenance, and mineral exploration and mining could occur. There are no specific data to quantify impacts to wildlife or their habitat within the CESA as a result of livestock grazing, wild horse and burro usage, dispersed recreation, or potential wildland fires. There are approximately 853 acres of pending minerals projects identified in the CESA, which includes the proposed Project, and approximately 1,050 acres of pending ROW projects.

2.4.1 Proposed Action

The Proposed Action (approximately 830 acres of temporary mating, brood rearing, and/or foraging habitat removal, not including the 77.7 acres of the open pit and 32.8 acres of the

15 20200701_Hasbrouck_wildlife_SER_Public.docx WK-ALLIED HASBROUCK LLC GENERAL WILDLIFE HASBROUCK MINE PROJECT SUPPLEMENTAL ENVIRONMENTAL REPORT long-term ROW that would not be reclaimed) would impact approximately 0.3 percent of the CESA. Quantifiable past and present actions and RFFA disturbance in the CESA total approximately 7,707 acres, which results in an incremental impact from the Proposed Action of 10.8 percent. Since there are limited quantifiable data for all activities in the CESA, this calculation is a conservative analysis of the potential incremental impact of the Proposed Action. Project-related impacts would be localized and minimized due to implementation of the EPMs outlined in Section 1.2 and reclamation. Therefore, based on the above analysis and findings, incremental impacts to general wildlife and their habitat as a result of the Proposed Action, when combined with the impacts from the past and present actions and RFFAs, are expected to be minor.

2.4.2 No Action Alternative

A total of the quantifiable past and present actions and RFFA disturbance within the CESA is approximately 7,707 acres, which is an impact to 2.5 percent of the CESA. This alternative (approximately five acres) would result in an incremental impact of approximately 0.06 percent. Impacts to general wildlife and their habitat from this alternative, in combination with past and present actions and RFFAs disturbance, would be negligible.

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3 REFERENCES

Bureau of Land Management (BLM). 2020a. Hasbrouck Mine Project Environmental Assessment. DOI-BLM-NV-B020-2017-0012-EA.

_____. 2020b. Bureau of Land Management’s Land & Mineral Legacy Rehost 2000 System - LR2000. http://www.blm.gov/lr2000/. Accessed January 7, 2020.

EM Strategies, Inc. (EMS). 2017a. Hasbrouck Mine Project, Esmeralda County, Nevada, 2017 Baseline Biological Survey Report. Finalized September 2017.

_____. 2017b. Hasbrouck Mine Project, Esmeralda County, Nevada, Noxious Weed Monitoring and Control Plan. August 25, 2017. Revised February 2020.

Enviroscientists, Inc. 2015. Hasbrouck Mine Project, Esmeralda County, Nevada, 2015 Baseline Biological Survey Report. October 9, 2015.

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