GEMINI SOLAR PROJECT Solar Partners XI, LLC

PALEONTOLOGICAL TECHNICAL STUDY

Prepared for: Bureau of Land Management – Southern Nevada District Office 4701 North Torrey Pines Dr. Las Vegas, NV 89130

Panorama Environmental, Inc. 1 Embarcadero Ctr., Suite 740 San Francisco, CA 94111

Prepared by: Paleo Solutions, Inc. 911 S. Primrose Ave., Unit N Monrovia, CA 91016

Geraldine Aron, M.S. – Principal Investigator Mathew Carson, M.S. – Report Author

PSI Report: NV18ClarkPAN01R

September 5, 2018

OFFICES 911 S. Primrose Ave., Unit N, Monrovia, CA 91016 Denver, CO; Redlands, CA; Oceanside, CA; Bend, OR (562) 818-7713 CERTIFICATIONS [email protected] • www.paleosolutions.com DBE • SBE • WBE • SDB • WOSB • EDWOSB

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

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PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

TABLE OF CONTENTS 1.0 Executive Summary ...... 5 2.0 Introduction ...... 7 2.1 Project Location ...... 7 2.2 Project Description ...... 7 3.0 Definition and Significance of Paleontological Resources ...... 14 4.0 Laws, Ordinances, Regulations, and Standards ...... 15 4.1 Federal Regulatory Setting ...... 15 4.1.1 National Environmental Policy Act (16 USC Section 431 et seq.) ...... 15 4.1.2 Federal Land Management and Policy Act (FLMPA) (43 USC 1701) ...... 15 4.1.3 Paleontological Resources Preservation Act (PRPA) ...... 15 4.1.4 Code of Federal Regulations, Title 43 ...... 16 4.2 State Regulatory Setting ...... 16 4.3 County Regulatory Setting ...... 16 4.4 Permits ...... 16 5.0 Methods ...... 16 5.1 Analysis of Existing Data ...... 17 5.2 Field Survey ...... 17 5.3 Criteria For Evaluating Paleontological Potential ...... 17 6.0 Analysis of Existing Data ...... 19 6.1 Literature Search ...... 19 6.1.1 Bird Spring Formation (PMb) ...... 19 6.1.2 Muddy Creek Formation, Fine-grained Facies (Tmf) ...... 20 6.1.3 Unnamed Sedimentary Deposits (T2k, QTk, QTa, Q2a, Q1a, Qct) ...... 20 6.1.4 Young Alluvium and Artificial Fill (Qa, af) ...... 22 6.2 Paleontological Record Search Results ...... 26 7.0 Field Survey ...... 26 7.1 Geology ...... 26 7.2 Paleontology ...... 27 8.0 Impacts to Paleontological Resources ...... 40 9.0 Recommendations ...... 40 References ...... 42 Appendix A. Museum Record Search Results ...... 46 Appendix B. BLM Permit and Fieldwork Authorization ...... 48 Appendix C. Location and PLSS Information ...... 54 Appendix D. Fossil Locality Forms ...... 57

TABLES

Table 1. Gemini Solar Project Summary ...... 8 Table 2. Potential Fossil Yield Classification (BLM, 2016) ...... 17

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

FIGURES

Figure 1. Project location map...... 10 Figure 2. Project overview map – northwestern area ...... 11 Figure 3. Project overview map – northeastern area ...... 12 Figure 4. Project overview map – southern area ...... 13 Figure 5. Project area geologic map – northwestern area ...... 23 Figure 6. Project area geologic map – northeastern area ...... 24 Figure 7. Project area geologic map – southern area...... 25 Figure 8. Ground disturbances in the Project area, including electrical towers and Crystal Substation. View west...... 29 Figure 9. Overview of Project area moderate topographic relief and ground cover. View northwest...... 29 Figure 10. Hill near Crystal Substation with exposures of Bird Spring Formation. View east...... 30 Figure 11. Outcrop of the Bird Spring Formation located on top of a hill near the Crystal Substation. View east...... 30 Figure 12. Outcrop of Muddy Creek Formation, fine-grained facies. View east...... 31 Figure 13. Plan view of Muddy Creek Formation, fine-grained facies surficial deposits, consisting of silt and fine-grained sand...... 31 Figure 14. Exposed slabs of calcrete (T2k), partially overlain by other surficial sediments. View east...... 32 Figure 15. Calcrete deposits (T2k) in outcrop and intercalated alluvial deposits (Qa) in the southwestern study areas. View north...... 32 Figure 16. Plan view of exposure with calcrete deposits (T2k)...... 33 Figure 17. Early Pleistocene- to Pliocene-age calcrete soil deposits (QTk). View north...... 33 Figure 18. Plan view of early Pleistocene- to Pliocene-age calcrete soil deposit (QTk) clasts exposed at the surface...... 34 Figure 19. Surface exposure of early Pleistocene- to late Pliocene-age sidestream alluvium deposits (QTa). View west...... 34 Figure 20. Exposed early to middle Pleistocene-age older sidestream alluvium (Q2a). View southeast...... 35 Figure 21. Plan view of early to middle Pleistocene-age older sidestream alluvium (Q2a), showing surficial gravel...... 35 Figure 22. Surficial sediments mapped as middle to late Pleistocene-age intermediate-age sidestream alluvium (Q1a) in the northern study area. View north...... 36 Figure 23. Surficial sediments mapped as middle to late Pleistocene-age intermediate-age sidestream alluvium (Q1a). View north...... 36 Figure 24. Low-relief channel incision exposing middle to late Pleistocene-age intermediate-age sidestream alluvium (Q1a). View east...... 37 Figure 25. Wash channel exposing thin veneer of young alluvium (Qa). View north...... 37 Figure 26. Fossil locality F180417-16-01 (NFO), consisting of fossil horn corals from the Bird Spring Formation. Fossils not collected...... 38 Figure 27. Fossil locality F180417-16-02 (NFO), consisting of fossil horn corals from the Bird Spring Formation. Fossils not collected...... 38 Figure 28. Fossil locality F180418-16-01 (NFO), consisting of a fossil horn coral in a carbonate clast in an area mapped as the Muddy Creek Formation, fine-grained facies (likely originating from the Bird Spring Formation). Fossil not collected...... 39 Figure 29. Fossil locality F180420-29-01 (SFL), consisting of a fossil bone, potentially a mammal(?) ear bone, from intermediate-age sidestream alluvium (Q1a). Fossil not collected...... 39

4 PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R 1.0 EXECUTIVE SUMMARY

This report presents the results of the paleontological technical study conducted by Paleo Solutions, Inc. (Paleo Solutions) under contract to Panorama Environmental, Inc. (Panorama) in support of the Gemini Solar Project (Project) in Clark County, Nevada. Solar Partners XI, LLC proposes to construct an approximately 690- megawatt (MW) alternating current (AC) solar photovoltaic (PV) power generating facility. The Project area is located in unincorporated Clark County, Nevada, approximately 33 miles northeast of the City of Las Vegas metropolitan area and immediately south of the Moapa River Indian Reservation along Interstate 15 (I-15) on land administered by the Bureau of Land Management (BLM) Southern Nevada District Office. All paleontological work was completed in compliance with the National Environmental Policy Act (NEPA), BLM policies and procedures, and best practices in mitigation paleontology. All paleontological work was conducted under Nevada BLM Paleontological Use Permit N- 91420 (Expiration September 23, 2018) and a BLM Fieldwork Authorization Request approved by the Southern Nevada District Office on April 12, 2018. Updates to the Project study area warranted a modification of the BLM Fieldwork Authorization, which was approved on June 14, 2018.

The paleontological potential of the Project area was evaluated based on an analysis of existing paleontological data and a field survey. The three components of the analysis of existing data included a geologic map review, a literature search, and an institutional record search. The analysis of existing data was supplemented with a pedestrian field survey. Geologic mapping by Beard et al. (2007) indicates that the Project area is underlain by early Permian to Late Mississippian Bird Spring Formation (PMb), late Miocene Muddy Creek Formation, fine-grained facies (Tmf), early Pliocene calcrete deposits (T2k), early Pleistocene to late Pliocene calcrete deposits (QTk), early Pleistocene to late Pliocene sidestream alluvium (QTa), middle to early Pleistocene older sidestream alluvium (Q2a), late to middle Pleistocene intermediate-age sidestream alluvium (Q1a), Holocene to Pleistocene colluvium and talus (Qct), Holocene young alluvium (Qa), and recent artificial fill (af). Note that Beard et al. (2007) uses the chronostratigraphic terminology (see Figure 3), which were used to denote the stratigraphic position of the geologic units; however, Paleo Solutions uses the geochronologic terminology throughout the remainder of this report to denote both the geologic age, as well as the stratigraphic position, of the geologic units in this assessment. According to the database and literature searches, there are no previously recorded fossil localities within the Project area. Additionally, the Las Vegas Natural History Museum (LVNHM) reported no fossil localities within the Project area (Bonde, 2018). The literature and database reviews identified numerous vertebrate, invertebrate, and plant fossils recovered from the Bird Spring Formation (PMb), Muddy Creek Formation (Tmf), and unnamed sedimentary deposits (T2k, QTk, QTa, Q2a, Q1a, Qct) elsewhere in Clark County, Nevada and the Mojave Desert region of southern California.

The field survey confirmed the presence of the Bird Spring Formation (PMb), Muddy Creek Formation (Tmf), and unnamed sedimentary deposits (T2k, QTk, QTa, Q2a, Q1a, Qct), and four fossil localities were recorded during the survey, which yielded non-significant fossil coral from areas mapped as Bird Spring Formation and Muddy Creek Formation, as well as a potentially significant vertebrate (mammal?) ear bone fragment from an area mapped as intermediate-age sidestream alluvium. No fossils were collected during the survey; however, it is recommended that the potentially significant ear bone fossil be collected prior to the start of construction. The three non-significant coral localities are recommended for immediate clearance.

The Potential Fossil Yield Classification (PFYC) system was applied to the results of the analysis of existing data and field survey (BLM, 2016). Early Permian- to Late Mississippian-age Bird Spring Formation (PMb) and late Miocene-age Muddy Creek Formation, fine-grained facies (Tmf) have moderate paleontological potential (PFYC 3) due to their abundant foraminifera and invertebrate fossils, and their rare vertebrate fossils. Additionally, early Pleistocene- to late Pliocene-age sidestream alluvium (QTa), middle to early Pleistocene-age older sidestream alluvium (Q2a), and late to middle Pleistocene-age (intermediate-age) sidestream alluvium (Q1a) also have a moderate paleontological potential (PFYC 3). The paleontological

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R potential of Pliocene- to Pleistocene-age calcrete deposits (T2k and QTk) and colluvium and talus deposits (Qct) are classified as having an unknown potential (PFYC U) for scientifically significant paleontological resources. Holocene-age young alluvium deposits (Qa) are estimated to be less than 10,000 years old and have low paleontological potential (PFYC 2) since they are too young to contain in-situ fossils. However, these younger deposits often overlie older geologic units with higher paleontological potential, which may be impacted at depth. Fossils contained in recent artificial fill (af) lack critical scientific information, and artificial fill is generally considered to have low paleontological potential (PFYC 2).

Based on the ground disturbance necessary to complete the Project, there is the potential for adverse impacts to scientifically significant paleontological resources within the subsurface of the Project area. Because of their moderate paleontological potential (PFYC 3), Bird Spring Formation (PMb), Muddy Creek Formation, fine- grained facies (Tmf), sidestream alluvium (QTa), older sidestream alluvium (Q2a), and intermediate-age sidestream alluvium (Q1a) should be monitored by a professional paleontologist to reduce potential adverse impacts on scientifically important paleontological resources to a less than significant level. Additionally, calcrete deposits (T2k, QTk) and colluvium and talus (Qct), which all have an unknown paleontological potential (PFYC U), should also be initially monitored to determine their thicknesses and to better refine their paleontological potential classification. If these geologic units are determined to have a low paleontological potential (PFYC 2), then the level of paleontological mitigation and monitoring can be reduced at the discretion of qualified professional paleontologist in cooperation with the BLM. Areas mapped as Holocene- age young alluvium (Qa) and recent artificial fill (af) should be spot checked during excavations that exceed depths of 3 feet to check for underlying, paleontologically sensitive geologic deposits. If older, native deposits are observed, full time monitoring should be implemented in those areas. If it is determined that only Holocene-age alluvium (PFYC 2) or recent artificial fill (PFYC 2) is impacted, the monitoring program should be reduced or suspended.

Prior to construction, a paleontological resource monitoring and mitigation plan (PRMMP) should be prepared by a qualified professional paleontologist. It should provide detailed recommended monitoring locations; a description of a worker training program; detailed procedures for monitoring, fossil recovery, laboratory analysis, and museum curation; and notification procedures in the event of a fossil discovery by a paleontological monitor or other project personnel. A curation agreement with LVNHM or another accredited repository approved by the BLM Southern Nevada District Office must also be obtained.

6 PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R 2.0 INTRODUCTION This report presents the results of the paleontological technical study conducted by Paleo Solutions under contract to Panorama on behalf of Solar Partners XI, LLC and the BLM in support of the Gemini Solar Project in Clark County, Nevada (Figure 1). This work was required by the BLM Southern Nevada District Office as the lead agency under NEPA. All paleontological work was completed in compliance with NEPA, BLM policies and procedures, and best practices in mitigation paleontology (Murphey et al., 2014). All paleontological work was conducted under Nevada BLM Paleontological Use Permit N-91420 (Expiration September 23, 2018) and a BLM Fieldwork Authorization Request approved by the Southern Nevada District Office on April 12, 2018 (Appendix B). Updates to the Project study area (Figure 1) warranted a modification of the BLM Fieldwork Authorization, which was approved on June 14, 2018.

2.0 PROJECT LOCATION The Project area is located in unincorporated Clark County, Nevada, approximately 33 miles northeast of the City of Las Vegas metropolitan area and immediately south of the Moapa River Indian Reservation along I-15 (Figures 2 through 4). It encompasses approximately 10,685 acres and is mapped on the USGS Piute Point, Dry Lake, and Dry Lake NW, Nevada 7.5’ Topographic Quadrangles. The Project area is situated on land administered by the BLM and bordered along its northern boundary by land administered by the Bureau of Indian Affairs (BIA) (Table 1). Geologic mapping by Beard et al. (2007) indicates that the Project area is underlain by early Permian- to Late Mississippian-age Bird Spring Formation (PMb), late Miocene-age Muddy Creek Formation, fine-grained facies (Tmf), early Pliocene-age calcrete deposits (T2k), early Pleistocene- to late Pliocene-age calcrete deposits (QTk), early Pleistocene- to late Pliocene-age sidestream alluvium (QTa), middle to early Pleistocene-age older sidestream alluvium (Q2a), late to middle Pleistocene-age intermediate- age sidestream alluvium (Q1a), Holocene- to Pleistocene-age colluvium and talus (Qct), Holocene-age young alluvium (Qa), and recent artificial fill (af) (Figure 5 through Figure 7).

2.1 PROJECT DESCRIPTION Solar Partners XI, LLC proposes to construct a 690-MW AC PV power generating facility. The power generated will be conveyed to the Nevada Energy transmission system to be distributed in Nevada and California. The primary elements of the Project include: solar array blocks consisting of solar PV modules; direct current (DC) collection system and Power Conversion Stations (PCS); overhead 34.5 kilovolt (kV) AC collection system; energy storage system; internal roadways; generation tie-lines (gen-ties); access roads along gen-ties; on-site substations; operation and maintenance (O&M) areas, which will include O&M building, parking area, and other associated facilities; telecommunication lines; meteorological towers; security facilities, which will include perimeter fencing, gates, on-site security patrol, lighting, electronic security systems, and/or remote monitoring; firebreak areas outside the fence perimeter; desert tortoise exclusion fencing around the perimeter; drainage control structures; and temporary construction mobilization and laydown areas.

7 PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

Table 1. Gemini Solar Project Summary Project Name Gemini Solar Project Solar Partners XI, LLC proposes to construct the Gemini Solar Project (Project), which entails construction of a 690-MW AC PV power generating facility. The power generated Project Description will be conveyed to the Nevada Energy transmission system to be distributed in Nevada and California. The Project area is located in unincorporated Clark County, Nevada, approximately 33 miles Project Area northeast of the City of Las Vegas metropolitan area and south of the Moapa River Indian Reservation along I-15. Total Acreage 10,685 Surveyed Location (PLSS) See Appendix C. Surface Management Agency Acres Land Owner Bureau of Land Management (BLM) 10,685 Topographic Map(s) USGS Piute Point, Dry Lake, and Dry Lake NW, Nevada 7.5’ Topographic Quadrangles Beard et al., 2007, Preliminary Geologic Map of the Lake Mead 30’ x 60’ Quadrangle, Clark Geologic Map(s) County, Nevada, and Mohave County, Arizona, scale 1:100,000. Paleontological Geologic Unit Map Symbol Age Potential (PFYC) Artificial fill and af Holocene/Recent 2 (Low) other disturbed land Young alluvium Qa Holocene 2 (Low) Holocene to Colluvium and talus Qct U (Unknown) Pleistocene Intermediate-age late to middle Q1a 3 (Moderate) sidestream alluvium Pleistocene Older sidestream middle to early Mapped Geologic Q2a 3 (Moderate) Units(s) and Age(s) alluvium Pleistocene early Pleistocene to late Sidestream alluvium QTa 3 (Moderate) Pliocene early Pleistocene to late Calcrete deposits QTk U (Unknown) Pliocene Calcrete deposits T2k early Pliocene U (Unknown) Muddy Creek Formation, fine- Tmf late Miocene 3 (Moderate) grained facies Bird Spring early Permian to Late PMb 3 (Moderate) Formation Mississippian Surveyor(s) Betsy Kruk, M.S., Joey Raum, B.S., Mathew Carson, M.S., and Daniel Nolan, B.S. Date(s) Surveyed April 17-21 and 23-25, 2018, and June 18-20, 2018 Bird Spring Formation (Pmb); Muddy Creek Formation, fine-grained facies (Tmf); Calcrete deposits (T2k); Calcrete deposits (QTk); Sidestream alluvium (QTa); Older sidestream Formations Surveyed alluvium (Q2a); Intermediate-age sidestream alluvium (Q1a); Colluvium and talus (Qct); and Quaternary alluvium (Qa) Nevada BLM Paleontological Use Permit N-91420 (Expiration September 23, 2018) and Permits BLM Field Work Authorization (Appendix B). Updates to the Project area warranted a modification of the BLM Fieldwork Authorization, which was approved on June 14, 2018. Previously Documented Fossil Record search was requested from the LVNHM. The LVNHM record search yielded no Localities within the known fossil localities recorded within the Project area (Appendix A). Project area

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

One significant fossil locality (SFL) was discovered during the survey (F180420-29-01), which yielded a fossil mammal (?) ear bone fragment. Additionally, three non-significant Paleontological fossil occurrences (NFO) were recorded (F180416-16-01, F180417-16-02, and F18-0418-16- Results 01). No fossils were collected during the survey; however, it is recommended that the ear bone fossil be collected prior to the start of construction. The three non-significant coral localities are recommended for immediate clearance. Disposition of Not applicable; no fossils collected during survey. Fossils Because of their moderate paleontological potential (PFYC 3), Bird Spring Formation (PMb), Muddy Creek Formation, fine-grained facies (Tmf), sidestream alluvium (QTa), older sidestream alluvium (Q2a), and intermediate-age sidestream alluvium (Q1a) should be monitored by a professional paleontologist to reduce potential adverse impacts on scientifically important paleontological resources to a less than significant level. Additionally, calcrete deposits (T2k, QTk) and colluvium and talus (Qct), which all have an unknown paleontological potential (PFYC U), should also be initially monitored to determine their thicknesses and to better refine their paleontological potential classification. If these geologic units are determined to have a low paleontological potential (PFYC 2), then the level of paleontological mitigation and monitoring can be reduced at the discretion of a qualified professional paleontologist in cooperation with the BLM. Areas mapped as Holocene-age young alluvium (Qa) and artificial fill (af) should be spot checked during Recommendation(s) excavations that exceed depths of 3 feet to check for underlying, paleontologically sensitive geologic deposits. If older, native deposits are observed, full time monitoring should be implemented in those areas. If it is determined that only Holocene-age alluvium (PFYC 2) or recent artificial fill (PFYC 2) is impacted, the monitoring program should be reduced or suspended.

Prior to construction, a PRMMP should be prepared by a qualified professional paleontologist. It should provide detailed recommended monitoring locations; a description of a worker training program; detailed procedures for monitoring, fossil recovery, laboratory analysis, and museum curation; and notification procedures in the event of a fossil discovery by a paleontological monitor or other project personnel. A curation agreement with LVNHM or another accredited repository approved by the BLM Southern Nevada District Office must also be obtained.

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

Figure 1. Project location map.

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

Figure 2. Project overview map – northwestern area.

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

Figure 3. Project overview map – northeastern area.

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

Figure 4. Project overview map – southern area.

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

3.0 DEFINITION AND SIGNIFICANCE OF PALEONTOLOGICAL RESOURCES As defined by Murphey and Daitch (2007): “Paleontology is a multidisciplinary science that combines elements of geology, biology, chemistry, and physics in an effort to understand the history of life on earth. Paleontological resources, or fossils, are the remains, imprints, or traces of once-living organisms preserved in rocks and sediments. These fossils include mineralized, partially mineralized, or unmineralized bones and teeth, soft tissues, shells, wood, leaf impressions, footprints, burrows, and microscopic remains. Paleontological resources include not only fossils themselves, but also the associated rocks or organic matter and the physical characteristics of the fossils’ associated sedimentary matrix.

The fossil record is the only evidence that life on earth has existed for more than 3.6 billion years. Fossils are considered non-renewable resources because the organisms they represent no longer exist. Thus, once destroyed, a fossil can never be replaced. Fossils are important scientific and educational resources because they are used to:

• Study the phylogenetic relationships amongst extinct organisms, as well as their relationships to modern groups; • Elucidate the taphonomic, behavioral, temporal, and diagenetic pathways responsible for fossil preservation, including the biases inherent in the fossil record; • Reconstruct ancient environments, climate change, and paleoecological relationships; • Provide a measure of relative geologic dating that forms the basis for biochronology and biostratigraphy, and which is an independent and corroborating line of evidence for isotopic dating; • Study the geographic distribution of organisms and tectonic movements of land masses and ocean basins through time; • Study patterns and processes of evolution, extinction, and speciation; and • Identify past and potential future human-caused effects to global environments and climates.”

Fossil resources vary widely in their relative abundance and distribution and not all are regarded as significant. According to BLM Instructional Memorandum (IM) 2009-011, a “Significant Paleontological Resource” is defined as:

“Any paleontological resource that is considered to be of scientific interest, including most vertebrate fossil remains and traces, and certain rare or unusual invertebrate and plant fossils. A significant paleontological resource is considered to be of scientific interest if it is a rare or previously unknown species, it is of high quality and well-preserved, it preserves a previously unknown anatomical or other characteristic, provides new information about the history of life on earth, or has an identified educational or recreational value. Paleontological resources that may be considered not to have scientific significance include those that lack provenience or context, lack physical integrity due to decay or natural erosion, or that are overly redundant or are otherwise not useful for research. Vertebrate fossil remains and traces include bone, scales, scutes, skin impressions, burrows, tracks, tail drag marks, vertebrate coprolites (feces), gastroliths (stomach stones), or other physical evidence of past vertebrate life or activities” (BLM, 2008).

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R Vertebrate fossils, whether preserved remains or track ways, are classified as significant by most state and federal agencies and professional groups. In some cases, fossils of plants or invertebrate animals are also considered significant and can provide important information about ancient local environments.

The full significance of fossil specimens or fossil assemblages cannot be accurately predicted before they are collected, and in many cases, before they are prepared in the laboratory and compared with previously collected fossils. Pre-construction assessment of significance associated with an area or formation must be made based on previous finds, characteristics of the sediments, and other methods that can be used to determine paleoenvironmental and taphonomic conditions.

4.0 LAWS, ORDINANCES, REGULATIONS, AND STANDARDS This section of the report presents the regulatory requirements pertaining to paleontological resources that apply to this Project.

4.0 FEDERAL REGULATORY SETTING

If any federal funding is used to wholly or partially finance a project, it is sited on federal lands, involves a federal permit, and/or includes a perceived federal impact, federal laws and standards apply, and an evaluation of potential impacts on paleontological resources may be appropriate and/or required. The management and preservation of paleontological resources on public and federal lands are prescribed under various laws, regulations, and guidelines. 4.0.1 National Environmental Policy Act (16 USC Section 431 et seq.) NEPA, as amended, requires analysis of potential environmental impacts to important historic, cultural, and natural aspects of our national heritage (USC, Section 431 et seq.; 40 CFR, Section 1502.25). NEPA directs Federal agencies to use all practicable means to “Preserve important historic, cultural, and natural aspects of our national heritage...” (Section 101(b) (4)). Regulations for implementing the procedural provisions of NEPA are found in 40 CFR 1500 1508. 4.0.2 Federal Land Management and Policy Act (FLMPA) (43 USC 1701) Federal law including the Federal Land Management and Policy Act (FLMPA) of 1976 (43 USC 1701) includes objectives such as the evaluation, management, protection and location of fossils on BLM-managed lands, defines fossils, and lays out penalties for the destruction of significant fossils. Also, NEPA requires the preservation of “historic, cultural, and natural aspects of our national heritage.” Most recently, the Omnibus Public Lands Act refines NEPA and FLMPA guidelines and strictures, as well as outlines minimum punishments for removal or destruction of fossils from Federal/public lands (see below). 4.0.3 Paleontological Resources Preservation Act (PRPA) Paleontological Resources Preservation, Title VI, Subtitle D in the Omnibus Public Lands Act of 2009, Public Law 111-011 Purpose: The Secretary (Interior and Agriculture) shall manage and protect paleontological resources on Federal land using scientific principles and expertise. With the passage of the PRPA, Congress officially recognizes the importance of paleontological resources on federal lands (U.S. Department of the Interior, US Department of Agriculture) by declaring that fossils from federal lands are federal property that must be preserved and protected using scientific principles and expertise. The PRPA provides:

• Uniform definitions for “paleontological resources” and “casual collecting”;

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

• Uniform minimum requirements for paleontological resource use permit issuance (terms, conditions, and qualifications of applicants); • Uniform criminal and civil penalties for illegal sale and transport, and theft and vandalism of fossils from Federal lands; and • Uniform requirements for curation of federal fossils in approved repositories. 4.0.4 Code of Federal Regulations, Title 43. Under the Title 43, Code of Federal Regulations, Section 8365.1-5, the collection of scientific and paleontological resources, including vertebrate fossils, on federal land is prohibited. The collection of a “reasonable amount” of common invertebrate or plant fossils for non-commercial purposes is permissible (43 CFR 8365.1-5 [United States Government Printing Office, 20014]).

4.1 STATE REGULATORY SETTING There are no State of Nevada laws, orders, regulations, or standards (LORS) that specifically address potential adverse impacts on paleontological resources. Therefore, no state-level protections of paleontological resources pertain to the Project.

4.2 COUNTY REGULATORY SETTING There are no Clark County LORS that specifically address potential adverse impacts on paleontological resources. Therefore, no county-level protections of paleontological resources pertain to the Project.

4.3 PERMITS All paleontological work was conducted under Nevada BLM Paleontological Use Permit N-91420 (Expiration September 23, 2018) and a BLM Fieldwork Authorization Request approved by the Southern Nevada District Office on April 12, 2018 (Appendix B). Updates to the Project study area warranted a modification of the BLM Fieldwork Authorization, which was approved on June 14, 2018. Geraldine Aron, Principal Investigator, oversaw all work as the permit holder and administrator.

5.0 METHODS This paleontological analysis of existing data included a geologic map review, a literature search, and a museum records search. The analysis of existing data was supplemented with a pedestrian field survey. The goal of this report is to evaluate the paleontological potential of the Project area and make recommendations for the mitigation of adverse impacts on paleontological resources that may occur as a result of the proposed Project. Mathew Carson, M.S., performed the background research and authored this report. Geraldine Aron, M.S., oversaw all aspects of the Project as the permit holder. Paleontological Principal Investigator Courtney Richards, M.S., performed the technical review of this report. GIS maps were prepared by Barbara Webster, M.S.

Copies of this report will be submitted to the BLM. A non-confidential version of the report will be submitted to Panorama and Solar Partners XI, LLC. Paleo Solutions will retain an archival copy of all Project information including field notes, maps, and other data.

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

5.1 ANALYSIS OF EXISTING DATA

Paleo Solutions reviewed geologic mapping of the Project area by Beard et al. (2007). The literature reviewed included published and unpublished scientific papers. The paleontological records search was conducted at the Las Vegas Natural History Museum (LVNHM) by Joshua Bonde, PhD. The results of the LVNHM records search (dated March 08, 2018) are attached as Appendix A. Additional record searches of online databases, such as the Paleobiology Database (PBDB) and the University of California Museum of Paleontology (UCMP), were completed by Paleo Solutions’ staff.

5.2 FIELD SURVEY The initial field survey was conducted by Paleo Solutions staff members Betsy Kruk, M.S., Joey Raum, B.S., and Mathew Carson, M.S., on April 17 - 21 and April 23 - 25, 2018. The survey areas that were added to the Project were surveyed by Betsy Kruk, M.S., and Daniel Nolan, B.S., on June 18-20, 2018. The paleontological survey was performed in order to determine the paleontological potential of the geologic deposits underlying the survey areas. The survey was conducted after a review of aerial photographs indicated the Project area included areas of undisturbed native sediment. The pedestrian survey included inspection of the Project area with the majority of focus occurring in areas with native sediment exposures. This survey included close inspection of sediment and bedrock outcrops. Rock exposures as well as the surrounding areas were photographed and documented. Reference points and locality information were acquired using a Garmin™ GPS. Sediment and bedrock lithologies were recorded and used to better interpret the Project’s paleontological sensitivity, and thus better understand the Project’s potential impact.

5.3 CRITERIA FOR EVALUATING PALEONTOLOGICAL POTENTIAL The PFYC system was developed by the BLM (BLM, 2016). Because of its demonstrated usefulness as a resource management tool, the PFYC has been utilized for many years for projects across the country, regardless of land ownership. It is a predictive resource management tool that classifies geologic units on their likelihood to contain paleontological resources on a scale of 1 (very low potential) to 5 (very high potential). This system is intended to aid in predicting, assessing, and mitigating paleontological resources. The PFYC ranking system is summarized in Table 2.

Table 2. Potential Fossil Yield Classification (BLM, 2016) BLM PFYC Assignment Criteria Guidelines and Management Summary (PFYC System) Designation Geologic units are not likely to contain recognizable paleontological resources. Units are igneous or metamorphic, excluding air-fall and reworked volcanic ash 1 = Very Low units. Potential Units are Precambrian in age. Management concern is usually negligible, and impact mitigation is unnecessary except in rare or isolated circumstances. Geologic units are not likely to contain paleontological resources. Field surveys have verified that significant paleontological resources are not present or are very rare. Units are generally younger than 10,000 years before present. 2 = Low Recent eolian deposits Sediments exhibit significant physical and chemical changes (i.e., diagenetic alteration) that make fossil preservation unlikely Management concern is generally low, and impact mitigation is usually unnecessary except in occasional or isolated circumstances. Sedimentary geologic units where fossil content varies in significance, abundance, 3 = Moderate and predictable occurrence. Potential Marine in origin with sporadic known occurrences of paleontological resources.

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

BLM PFYC Assignment Criteria Guidelines and Management Summary (PFYC System) Designation Paleontological resources may occur intermittently, but these occurrences are widely scattered The potential for authorized land use to impact a significant paleontological resource is known to be low-to-moderate. Management concerns are moderate. Management options could include record searches, pre-disturbance surveys, monitoring, mitigation, or avoidance. Opportunities may exist for hobby collecting. Surface-disturbing activities may require sufficient assessment to determine whether significant paleontological resources occur in the area of a proposed action and whether the action could affect the paleontological resources. Geologic units that are known to contain a high occurrence of paleontological resources. Significant paleontological resources have been documented but may vary in occurrence and predictability. Surface-disturbing activities may adversely affect paleontological resources.

Rare or uncommon fossils, including nonvertebrate (such as soft body 4 = High Potential preservation) or unusual plant fossils, may be present. Illegal collecting activities may impact some areas. Management concern is moderate to high depending on the proposed action. A field survey by a qualified paleontologist is often needed to assess local conditions. On-site monitoring or spot-checking may be necessary during land disturbing activities. Avoidance of known paleontological resources may be necessary. Highly fossiliferous geologic units that consistently and predictably produce significant paleontological resources. Significant paleontological resources have been documented and occur consistently Paleontological resources are highly susceptible to adverse impacts from surface disturbing activities. 5 = Very High Unit is frequently the focus of illegal collecting activities. Potential Management concern is high to very high. A field survey by a qualified paleontologist is almost always needed and on-site monitoring may be necessary during land use activities. Avoidance or resource preservation through controlled access, designation of areas of avoidance, or special management designations should be considered. Geologic units that cannot receive an informed PFYC assignment Geological units may exhibit features or preservational conditions that suggest significant paleontological resources could be present, but little information about the actual paleontological resources of the unit or area is unknown. Geologic units represented on a map are based on lithologic character or basis of origin, but have not been studied in detail.

Scientific literature does not exist or does not reveal the nature of paleontological U = Unknown resources. Reports of paleontological resources are anecdotal or have not been verified. Area or geologic unit is poorly or under-studied. BLM staff has not yet been able to assess the nature of the geologic unit. Until a provisional assignment is made, geologic units with unknown potential have medium to high management concerns. Field surveys are normally necessary, especially prior to authorizing a ground-disturbing activity.

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R 6.0 ANALYSIS OF EXISTING DATA The Project area is located in southern Nevada within the Las Vegas Valley in the Great Basin (Basin and Range Province) (Page et al., 2005). During the Paleozoic and early Mesozoic, southern Nevada was located on the western margin of the North American Craton (Pangaea) at a time when compressional tectonics created a foreland basin that was the site of deposition of the marine rocks that occur in Nevada (Dickinson, 2006). The Great Basin is the largest feature in the Basin and Range Province, spanning an approximate 600 by 600 kilometer tract of topography. Rocks found within the Great Basin in the Project area and vicinity dominantly represent shallow marine shelf environments under fluctuating sea levels deposited during the late Paleozoic to early Mesozoic. The Permian-age deposits were deposited after the Antler mountain building event (orogeny) within the foreland-basin east of the Antler Orogen, representing a shallow carbonate shelf. During the Mesozoic, tectonic forces and volcanism dominated the landscape, and in southern and eastern Nevada, deformation in the form of folds and faults from compressional forces occurred causing the Sevier Orogeny, which spanned from the Middle Jurassic to the latest Cretaceous or earliest Paleocene. During the Tertiary, tectonic extension and subduction of oceanic plates under the North American Plate caused additional igneous activity. By the Quaternary, glaciation within the higher mountains caused the development of large lakes, resulting in the development of sedimentary deposits, such as stream channel and wash gravels and sands and playa and fluvial fine-grained clays, muds, and sands in the valleys (Price, 2004).

6.0 LITERATURE SEARCH

Geologic mapping by Beard et al. (2007) indicates that the Project area is underlain by early Permian- to Late Mississippian-age Bird Spring Formation (PMb), late Miocene-age Muddy Creek Formation, fine-grained facies (Tmf), early Pliocene-age calcrete deposits (T2k), early Pleistocene- to late Pliocene-age calcrete deposits (QTk), early Pleistocene- to late Pliocene-age sidestream alluvium (QTa), middle to early Pleistocene- age older sidestream alluvium (Q2a), late to middle Pleistocene-age intermediate-age sidestream alluvium (Q1a), Holocene- to Pleistocene- colluvium and talus (Qct), Holocene-age young alluvium (Qa), and recent artificial fill and disturbed sediments (af). The geographic distributions of the geologic units in the Project area and their immediately vicinity, as mapped by Beard et al. (2007), are illustrated in Figure 5 through Figure 7. 6.0.1 Bird Spring Formation (PMb) The early Permian- to Late Mississippian-age Bird Spring Formation (PMb) is an approximate 8,202-foot thick (Page et al., 2005) series of limestone, sandstone, and shale beds named by Hewett (1931) after its significant exposure in the Bird Spring Range (Hewett, 1956). It was originally thought to be Pennsylvanian in age; however, Wilson (1991) determined the Bird Spring Formation (PMb) to be early Permian in age. More recently, dating methods indicate an early Permian- to Late Mississippian-age for the Bird Spring Formation (Beard et al., 2007). While the Bird Spring Formation is only locally continuous through the Bird Spring Range in Nevada, it may be equivalent to other fossiliferous early Permian to Late Mississippian carbonate units throughout Nevada and eastern California (Hewett, 1956).

Locally, the Bird Spring Formation (PMb) consists of medium- to light-gray, weathered yellowish- to brownish-gray, thinly to thickly bedded limestone or dolomite, with calcareous sandstone and siltstone weathered reddish-brown and containing layers and nodules of reddish-brown chert (Beard et al., 2007). This geologic unit is characterized by its stair-stepped “ledge-cliff-slope” appearance and is disconformable on the Mississippian Monte Cristo Group (not mapped within the Project vicinity) (Beard et al., 2007). The Bird Spring Formation (PMb) has been widely studied in southeastern California and southern Nevada for its biostratigraphy, paleogeographic evolution, and tectonic history (Brand and Bruckschen, 2002; Clapham and Bottjer, 2007; Stevens and Stone, 2007; Stone et al., 2013; Webster and Lane, 1987; Wilson, 1991; and Wilson and Langenheim, 1993, etc.). According to Beard et al. (2007), the Bird Spring Formation (PMb) has abundant marine fossils, including fusulinid foraminifera, sponges, corals, bryozoans, brachiopods,

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R gastropods, pelecypods, and ostracodes. Most studies of the Bird Spring Formation (PMb) have focused on the biostratigraphy of fusulinid foraminifera (Rich, 1961; Cassity and Langenheim, 1966; Marshall, 1969; Ho, 1990); however, several authors have published on corals (Wilson, 1991; Wilson and Langenheim, 1993), brachiopods and bryozoans (Lane, 1963; Wilson, 1982; Mills and Langenheim, 1987; Brand et al., 2012), and conodonts (Dunn, 1965; Dunn, 1966; Rice and Langenheim, 1974). Recently discovered taxa include a feather star (Poteriocrinites permicus), crinoids (Ekteinocrinus battleshipensis), and the first evidence of a Permian-age actinocrinitid in North America (Webster and Lane, 1987).

A review of the PBDB and the UCMP suggests that hundreds of invertebrate fossil specimens have been recovered from numerous localities in Clark County from the Bird Spring Formation (PMb), including sponges; corals; bryozoans; brachiopods (of which there are at least 150 different taxa recovered); polychaetes, such as the planispirally-shelled Spirorbis sp.; bryozoans (Nicklespora avia); mollusks, such as chitons (Acutichiton gracilis), scaphopods, bivalves, extinct rostroconchs, gastropods, and cephalopods; arthropods, such as ostracods and extinct trilobites; and echinoderms (PBDB, 2018; UCMP, 2018). Additionally, the PBDB contains records of plants, such as Stigmaria wedingtonensis; green algae (Mizzia cf. yabei), numerous fusulinid foraminifera; and bony fish (Osteichthyes) (PBDB, 2018). The early Permian to Late Mississippian Bird Spring Formation (PMb) deposits within the Project area have the potential to contain numerous invertebrate fossils and rare vertebrate and plant fossils and were deposited in a shallow marine environment; therefore, these deposits have a moderate paleontological potential (PFYC 3). 6.0.2 Muddy Creek Formation, Fine-grained Facies (Tmf) Late Miocene-age Muddy Creek Formation (Tmf) consists of mostly sandstone and siltstone, with deposits of evaporite, limestone, conglomerate, breccia, and tuff (Beard et al., 2007). Portions of the Project area are underlain by the fine-grained facies of the Muddy Creek Formation (Tmf), which consists of interbedded pink sandstone, siltstone, and claystone, with traces of gypsum; beds are parallel and range in thickness from 1 to 50 centimeters (Beard et al., 2007). Within the fine-grained facies, white tuff and salt deposits have also been observed. The Muddy Creek Formation occurs in the intermontane basins near the Colorado River between Las Vegas and the Grand Wash Cliffs to the east along the edge of the Colorado Plateau and is approximately 2,000 feet thick or more (King and Beikman, 1978). The age of the Muddy Creek Formation (Tmf) has been dated by extrusive igneous deposits (tuffs and basalt flows), which constrain the age of the Muddy Creek Formation (Tmf) to 4.1 to 8.5 million years old (Metcalf, 1982; Williams, 1997). Fossil localities recorded from the Muddy Creek Formation (Tmf) are either Miocene or Pliocene in age (Stock, 1921; Longwell, 1946; Kowallis and Everett, 1986), or Hemphillian Land Mammal Age, and have yielded horse, camel, llama, pronghorn, dog, and bear, as well as trace fossils, such as insect burrows, root casts, and animal tracks throughout its geographic distribution (Williams, 1997). Stock (1921) reports a tooth of extinct horse (Merychippus sp.), limb elements of camel (Alticamelus(?) sp. or Procamelus(?) sp.) recovered from near the type section of the Muddy Creek Formation near Overton, Nevada.

A review of the PBDB and the UCMP suggests that fossil localities from the Muddy Creek Formation (Tmf) in Clark County are rare. Fossil localities recorded in the PBDB within 100 miles of the Project area include camel (Alforjas sp. and Camelidae) and antelope (?Neotragocerus sp.) (PBDB, 2018). The UCMP records several localities from the Muddy Valley yielding camel (Camelidae), horse (Merychippus sp.), and indeterminant mammal fossils (UCMP, 2018). Because scientifically significant vertebrate fossils are rare, the Muddy Creek Formation fine-grained facies (Tmf) has a moderate paleontological potential (PFYC 3). 6.0.3 Unnamed Sedimentary Deposits (T2k, QTk, QTa, Q2a, Q1a, Qct) There are several Pliocene- to early Holocene-age unnamed sedimentary deposits mapped within the Project area. These consist of early Pliocene-age calcrete soil deposits (T2k), early Pleistocene- to Pliocene-age calcrete soil deposits (QTk), early Pleistocene- to late Pliocene-age sidestream alluvium deposits (QTa), early

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R to middle Pleistocene-age older sidestream alluvium (Q2a), middle to late Pleistocene-age (intermediate-age) sidestream alluvium (Q1a), and Pleistocene- to Holocene-age colluvium and talus (Qct).

Both the Pliocene-age calcrete deposits (T2k) and the Pleistocene- to Pliocene-age calcrete deposits (QTk) consist of laminar layers, which break laterally across imbedded clasts, resulting in discontinuous layers (Beard et al., 2007). Older calcrete deposits (T2k) are variably thick, ranging in thickness from 5 to 10 meters, and are locally present in the California Wash, the Gale Hills, and the Overton Arm areas, with older calcrete deposits (T2k), which overlie basalt flows dated to 4 to 5 million years old, situated along the western edge of the Grand Wash Trough. Younger calcrete deposits (QTk) are no more than 2 meters in thickness and observed over a widespread area.

Early Pleistocene- to late Pliocene-age sidestream alluvium (QTa), early to middle Pleistocene older sidestream alluvium (Q2a), and middle to late Pleistocene-age (intermediate-age) sidestream alluvium (Q1a) are sands and gravels derived from hydrologic processes and are present in channels and washes. Sidestream alluvium deposits (QTa) consist of poorly-sorted, angular gravel, derived from the erosion of nearby topographic high areas and are mapped mostly in alluvial fans and sidestream channels (Beard et al., 2007). Conversely, older sidestream alluvium deposits (Q2a) consist of sand with poorly-sorted gravel, and they are observed along terraces and alluvial fans, which are heavily dissected from hydrologic erosion (Beard et al., 2007). Intermediate-age sidestream alluvium deposits (Q1a) consist of locally derived sand and gravel, observed as being heavily dissected in alluvial fans and present within low-lying terraces within washes. Upgradient in areas of higher elevation, these deposits are characterized as desert pavement, with smooth and gently sloping topography (Beard et al., 2007).

Pleistocene- to Holocene-age colluvium and talus (Qct) deposits are described by Beard et al. (2007) as angular, poorly sorted, locally derived blocks of rock and colluvial material, covering slopes, and situated along the base of cliffs and steep slopes. These deposits are relatively shallow, ranging between 0 and 10 meters thick.

Since these units have not been assigned to a specific formation, the general geology and paleontologic content of these units is unknown and unlisted by the PBDB (2018) and UCMP (2018); though, fine-grained older alluvial deposits often have the potential to contain fossils. Pliocene-age alluvial deposits of the Mojave Desert have produced numerous well-preserved mammalian fossils including fish, salamanders, frogs, toads, giant tortoise, snakes, birds, rodents, rabbits, camels, and cats, among other taxa (Wagner and Prothero, 2001). These fossils were preserved in an undetermined alluvial deposit in a layer that contains calcareous concretionary sandstone and pebbly conglomerate located on Gypsum Ridge in Twentynine Palms, San Bernardino County, California. Vertebrate fossils have also been recovered from Pleistocene-age deposits of the Mojave Desert, including specimens of rodents (Peromyscus sp., Dipodomys ordii, Neotoma sp., Thomomys sp., among others), rabbits (Lepus sp.), horse (Equus conversidens), badger (Taxidea taxus), cats (Smilodon sp., Puma concolor), mammoth (Mammuthus sp.), camel (Camelops sp., Hemiauchenia sp.), sloth (Nothrotheriops sp., Megalonyx sp.), tortoise (Opherus agassizi), as well as bison, antelope, and many other taxa of mammals (Brattstrom, 1961; Jefferson, 1991; Reynolds, 1991). There is the potential for a similar fauna to be recovered during Project excavations.

There were no fossils reported from the Pliocene- to Pleistocene-age calcrete deposits (T2k and QTk) or colluvium and talus deposits (Qct), however, based on the age and depositional environments, the possibility that these geologic units may contain fossils cannot be precluded. Therefore, these geologic units are classified as having an unknown potential (PFYC U) for scientifically significant paleontological resources. Early Pleistocene- to late Pliocene-age sidestream alluvium deposits (QTa), early to middle Pleistocene-age older sidestream alluvium (Q2a), and middle to late Pleistocene-age (intermediate-age) sidestream alluvium (Q1a) have the potential to preserve scientifically significant fossil taxa; thus, these deposits have a moderate paleontological potential (PFYC 3).

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R 6.0.4 Young Alluvium and Artificial Fill (Qa, af) Holocene-age young alluvium (Qa) is primarily active channel alluvial deposits of channels, floodplains, low terraces, and alluvial fans (Beard et al., 2007). These deposits consist of poorly sorted silt, sand, and pebble to boulder gravel; unconsolidated; and lacking calcic soil horizons or desert pavement (Beard et al., 2007). Young alluvium typically caps older alluvium within the vicinity of the Project area but may be present within incisions of topographically higher and older alluvium, with maximum terrace height of approximately 10 meters. Artificial fill (af) is mapped where major excavations or filling by humans has occurred and has disturbed the surface to the extent that its pre-existing surficial and subsurficial lithological characterization cannot be accurately determined (Beard et al., 2007). Holocene-age (less than 11,000 years old) sediments are typically too young to contain fossilized material (SVP, 2010), but they may overlie sensitive older (e.g., Pliocene- and Pleistocene-age) deposits at variable depths. Younger alluvium (Qa) and artificial fill (af) are assigned low paleontological potential (PFYC 2) at the surface using BLM (2016) guidelines. However, they may overlie older geologic units with relatively higher paleontological potential.

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

Figure 5. Project area geologic map – northwestern area.

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

Figure 6. Project area geologic map – northeastern area.

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

Figure 7. Project area geologic map – southern area.

25 PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R

6.1 PALEONTOLOGICAL RECORD SEARCH RESULTS Paleo Solutions requested a paleontological search of records maintained by LVNHM. The museum responded on March 08, 2018 that there are no localities within the Project area (Bonde, 2018; Appendix A). Although the LVNHM has no records within the bounds of the Project area, Bonde (2018; Appendix A) suggests that significant fossils may be present within the Pleistocene-age or older geologic units throughout the Mojave region. 7.0 FIELD SURVEY The survey area is located along the I-15 near its intersection with Valley of Fire Highway, approximately 33 miles northeast of the City of Las Vegas. The terrain consists of hills and washes of moderate topographic relief within the northwestern portion of the Project area, and low topographic relief to completely flat, incised by shallow washes in the northeast and southern portions of the Project area. Existing ground disturbances include two-track dirt paths and unpaved roads, the I-15, electrical towers, Crystal Substation, and miscellaneous debris (Figure 8). Additionally, most of the Project area surface is covered in patchy desert grasses, dispersed creosote bushes or shrubs, sporadic cacti, and bare earth, exposing cobbles, gravel, and sand (Figure 9). Geologic exposures were observed along the surface, as well as in the shallow sidewalls of sheetwashes and rock outcrops in areas of higher topographic relief.

Paleo Solutions conducted an initial paleontological survey of the Project area on April 17-21 and April 23-25, 2018. After the initial survey, Solar Partners XI, LLC proposed additional study areas (Figures 1, 2, and 3), which were surveyed by Paleo Solutions on June 18-20, 2018. The results of both field surveys are incorporated into the following Geology and Paleontology subsections (sections 7.1 and 7.2, respectively).

7.1 GEOLOGY The early Permian- to late Mississippian-age Bird Spring Formation (PMb) is mapped throughout the northwestern most portion of the site, underlying portions of the roads and substation access areas. The Bird Spring Formation consisted of blue- to gray-colored siltstone, shale, claystone, and limestone, consisting of mostly well-cemented clay- and silt-sized clasts, with a massive to fissile texture and bioturbated structure. The bottom contact of the formation was not observed in the field, but the unit may be as much as 60 feet thick as observed in outcrops along moderate to moderately-steep relief hills (Figures 10 and 11). Calcite- filled factures and calcite veins were also noted during the survey.

The late Miocene-age Muddy Creek Formation (Tmf) is mapped throughout the western half of the site, underlying portions of the roads and substation access areas, as well as the main Project area. The Muddy Creek Formation was weathered at the surface, with intact bedrock not observed in some areas (Figure 12). When weathered at the surface, the Muddy Creek Formation consisted of reddish-brown-colored silt, very fine- to fine-grained sand, pebbles, and cobbles of metamorphic and well lithified sedimentary rock clasts, which were subangular, moderately sorted to very well sorted, and poorly to moderately compacted. The weathered remains of the formation were exposed on low to moderate relief mounds and in low-relief washes, with pebble-cover along the surface from fine-grained sediment winnowing. In other areas of the Project site, the Muddy Creek Formation bedrock was exposed and consisted of pale red-colored sandy siltstone, with very fine-grained sand-sized grains intermixed with silt, very well sorted, and moderately lithified (Figure 13). At the surface of bedrock exposures, mudcracks and popcorn weathering structures were visible (Figure 12). The bottom contact was not observed during the survey but was expected to be approximately 20 feet thick based on the topographic relief.

Pliocene-age calcrete soil deposits (T2k) are mapped throughout the western-most survey area, near Crystal Substation and the southwestern project areas, and in the northern-most portion of the survey area, in the

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R area closest to the intersection of I-15 and Valley of Fire Highway. These calcrete deposits consisted of orangish-tan, buff, tan, whitish-gray, light gray, and dark gray, conglomerate, with constituent clasts consisting of silt, very fine- to fine-grained sand, coarse- to very coarse-grained sand, granules, pebbles, and cobbles, very poorly sorted, subangular to well rounded, and massive. Calcrete deposits are moderately to well lithified with carbonate cementation (Figures 14 through 16). During the survey, it was noted that Pliocene-age calcrete deposits (T2k) were interfingered with younger alluvium and sidestream deposits at the surface in the western survey area (Figure 14) and the southwestern study areas (Figure 15). Early Pleistocene- to Pliocene- age calcrete soil deposits (QTk) were also exposed within the footprint of Crystal Substation, as well as along the path of the Alt Trans right of way (paths 1 through 3) in the western portion of the Project area. Early Pleistocene- to Pliocene-age calcrete soil deposits consisted of light tannish-gray-colored, medium- to very coarse-grained sand, granules, and pebbles, poorly sorted, subangular to angular, and well compacted (Figures 17 and 18). Calcrete soil deposits appeared relatively thin (e.g., less than 2 feet thick) in exposures in shallow sheetwash sidecuts; however, the bottom contact was not observed in geologic exposures. Early Pleistocene- to late Pliocene-age sidestream alluvium deposits (QTa) consist of poorly-sorted, angular gravel, compositionally similar to other sidestream alluvial deposits in the area (Figure 19). Early to middle Pleistocene-age older sidestream alluvium (Q2a) was exposed in the western Project area and consisted of light red-colored silt, very fine- to fine-grained sand, very well sorted, subangular to subrounded, and moderately compacted (Figures 20 and 21). Much like other Plio-Pleistocene calcrete and sidestream deposits, the bottom contact was not exposure in the survey area; however, based on the thicknesses exposed in sidewalls of washes, the older sidestream alluvium may be approximately five feet thick. Middle to late Pleistocene-age intermediate-age sidestream alluvium (Q1a) is exposed throughout much of the Project area, particularly in broad, flat regions in the central and eastern Project area, as well as in the northern and southwestern study areas (Figure 22). Intermediate-age sidestream alluvium consists of tan, buff, white, light gray, dark brown, reddish-brown alluvial deposits, with clasts comprised of silt, very fine- to fine-grained sand, very coarse-grained sand, granules, pebbles, and cobbles, all of which are composed of carbonate mudstones, as well as siliciclastic mudstones, sandstones, and conglomerate blocks, the latter of which contained smaller, subangular to well rounded, well cemented pebble- to cobble-sized clasts in a fine-grained matrix (Figures 23 and 24). At the surface, fine-grained sediments have been winnowed, leaving only coarse- grained sand to cobbles exposed at the surface. Clasts were very poorly sorted to moderately sorted, angular to subrounded, and poorly compacted. However, throughout the Project area along former washes, intermediate-age sidestream alluvium is present as broad blocks of well cemented matrix-supported carbonate conglomerate. Pleistocene- to Holocene-age colluvium and talus (Qct) consisted of angular, poorly sorted, locally derived clasts, compositionally similar to other alluvial and sidestream deposits.

Holocene-age young alluvium (Qa) is mapped in washes and stream channels that incise the overall Project area. Young alluvium consisted of buff, tan, light to medium brown-colored silt, very fine- to fine-grained sand, pebbles, and cobbles, moderately sorted to well sorted, angular to subrounded, poorly compacted, and with a sharp bottom contact with the underlying geologic units (Figure 25). The young alluvium was noted by field staff to form a thin veneer (e.g., less than one foot thick) sporadically overlying older geologic units in washes and channel incisions (Figures 15 and 25). Constituent clasts of the young alluvium were derived from older geologic units, such as the Bird Spring Formation, Muddy Creek Formation, and other Pliocene- to Pleistocene-age alluvial deposits. Recent artificial fill (af) was not observed by field staff but is mapped near the Crystal Substation along the Substation Access 2 right-of-way.

7.2 PALEONTOLOGY During the survey, four fossil localities were recorded by Paleo Solutions’ field technicians. Three of the four fossil localities were non-significant fossil occurrences (NFO), and one was a significant fossil locality (SFL). The NFO’s recorded during the survey included: F180417-16-01 (Figure 26), which contained both ex-situ (float) and in-situ (within an outcrop) fossil coral specimens preserved in grayish-blue, massive, well-lithified, carbonate mudstone of the Bird Spring Formation (PMb), located

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R ; F180417-16-02 (Figure 27), which also contained in-situ fossil coral specimens preserved in grayish-blue, massive, well-lithified, carbonate mudstone of the Bird Spring Formation, located ; and F180418-16-01 (Figure 28), which contained ex-situ fossil horn coral specimens preserved in a grayish-blue, well lithified carbonate mudstone clast in an area mapped as the Muddy Creek Formation (Tmf), fine-grained facies, but likely originating from the Bird Spring Formation. The SFL recorded during the survey included F180420-29-01 (Figure 29), which contained ex-situ vertebrate bone (likely a mammal(?) ear bone) from an area of low topographic relief intermediate-age sidestream alluvium (Q1a), which was locally very pale brown, red, or gray, very fine- to medium-grained sand, gravel, and granules, subrounded to subangular, poorly sorted, and poorly consolidated. Although slightly weathered and recorded as ex-situ, the vertebrate remains were well-preserved, with small, identifiable structures; however, the fossil was not collected, as stipulated in the Nevada BLM Paleontological Use Permit N-91420 and approved Fieldwork Authorization. The recorded fossil localities are summarized in Appendix D.

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Figure 8. Ground disturbances in the Project area, including electrical towers and Crystal Substation. View west.

Figure 9. Overview of Project area moderate topographic relief and ground cover. View northwest.

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Figure 10. Hill near Crystal Substation with exposures of Bird Spring Formation. View east.

Figure 11. Outcrop of the Bird Spring Formation located on top of a hill near the Crystal Substation. View east.

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Figure 12. Outcrop of Muddy Creek Formation, fine-grained facies. View east.

Figure 13. Plan view of Muddy Creek Formation, fine-grained facies surficial deposits, consisting of silt and fine-grained sand.

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Figure 14. Exposed slabs of calcrete (T2k), partially overlain by other surficial sediments. View east.

Figure 15. Calcrete deposits (T2k) in outcrop and intercalated alluvial deposits (Qa) in the southwestern study areas. View north.

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Figure 16. Plan view of exposure with calcrete deposits (T2k).

Figure 17. Early Pleistocene- to Pliocene-age calcrete soil deposits (QTk). View north.

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Figure 18. Plan view of early Pleistocene- to Pliocene-age calcrete soil deposit (QTk) clasts exposed at the surface.

Figure 19. Surface exposure of early Pleistocene- to late Pliocene-age sidestream alluvium deposits (QTa). View west.

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Figure 20. Exposed early to middle Pleistocene-age older sidestream alluvium (Q2a). View southeast.

Figure 21. Plan view of early to middle Pleistocene-age older sidestream alluvium (Q2a), showing surficial gravel.

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Figure 22. Surficial sediments mapped as middle to late Pleistocene-age intermediate-age sidestream alluvium (Q1a) in the northern study area. View north.

Figure 23. Surficial sediments mapped as middle to late Pleistocene-age intermediate-age sidestream alluvium (Q1a). View north.

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Figure 24. Low-relief channel incision exposing middle to late Pleistocene-age intermediate-age sidestream alluvium (Q1a). View east.

Figure 25. Wash channel exposing thin veneer of young alluvium (Qa). View north.

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Figure 26. Fossil locality F180417-16-01 (NFO), consisting of fossil horn corals from the Bird Spring Formation. Fossils not collected.

Figure 27. Fossil locality F180417-16-02 (NFO), consisting of fossil horn corals from the Bird Spring Formation. Fossils not collected.

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Figure 28. Fossil locality F180418-16-01 (NFO), consisting of a fossil horn coral in a carbonate clast in an area mapped as the Muddy Creek Formation, fine-grained facies (likely originating from the Bird Spring Formation). Fossil not collected.

Figure 29. Fossil locality F180420-29-01 (SFL), consisting of a fossil bone, potentially a mammal(?) ear bone, from intermediate-age sidestream alluvium (Q1a). Fossil not collected.

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Indirect impacts typically include those effects that result from the continuing implementation of management decisions and resulting activities, including normal ongoing operations of facilities constructed within a given project area. They also occur as the result of the construction of new roads and trails in areas that were previously less accessible. This activity increases public access and therefore increases the likelihood of the loss of paleontological resources through vandalism and unlawful collecting. Human activities that increase erosion also cause indirect impacts to surface and subsurface fossils as the result of exposure, transport, weathering, and reburial.

Cumulative impacts can result from incrementally minor but collectively significant actions taking place over a period of time. The incremental loss of paleontological resources over time as a result construction-related surface disturbance or vandalism and unlawful collection would represent a significant cumulative adverse impact because it would result in the destruction of non-renewable paleontological resources and the associated irretrievable loss of scientific information.

Excavations into areas containing Bird Spring Formation (Pmb); Muddy Creek Formation, fine- grained facies (Tmf); Calcrete deposits (T2k, QTk); Sidestream alluvium (QTa); Older sidestream alluvium (Q2a); Intermediate-age sidestream alluvium (Q1a); and Colluvium and talus (Qct) may result in significant impacts to paleontological resources. Topographic relief is highest in the northwestern portion of the Project area near Crystal Substation, with rolling hills, wash cuts, and outcrops visible to assess the relative thickness of the Bird Spring Formation and Muddy Creek Formation, fine-grained facies. However, topographic relief is minimal throughout the remaining survey area, and the lack of sediment exposures and outcrops provide little indication of the depth of Pliocene- to Pleistocene- age deposits across the entirety of the Project area. Holocene-age young alluvium (Qa) likely forms a thin veneer of younger surficial sediments within washes across the site and likely immediately overlies older deposits of moderate or unknown paleontological potential (PFYC 3 or U). Surface grading or shallow excavations entirely within Holocene-age young alluvium are unlikely to uncover significant fossil vertebrate remains. Excavations entirely within previously disturbed sediments or recent artificial fill (af) are unlikely to uncover significant fossil vertebrate remains; furthermore, any recovered resources will lack stratigraphic context. Nevertheless, both young alluvium and artificial fill may shallowly overlie older in-situ sedimentary deposits. Therefore, grading and other earthmoving activities may potentially result in significant adverse direct impacts to paleontological resources throughout the entirety of the Project area.

9.0 RECOMMENDATIONS The survey resulted in the discovery of four fossil localities, which yielded non-significant fossil coral from areas mapped as Bird Spring Formation and Muddy Creek Formation, as well as a potentially significant vertebrate (mammal?) ear bone fragment from an area mapped as intermediate-age

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Because of their moderate paleontological potential (PFYC 3), Bird Spring Formation (PMb), Muddy Creek Formation, fine-grained facies (Tmf), sidestream alluvium (QTa), older sidestream alluvium (Q2a), and intermediate-age sidestream alluvium (Q1a) should be monitored by a professional paleontologist to reduce potential adverse impacts on scientifically important paleontological resources to a less than significant level. Additionally, calcrete deposits (T2k, QTk), and colluvium and talus (Qct), which all have an unknown paleontological potential (PFYC U), should also be initially monitored to determine their thicknesses and to better refine their paleontological potential classification. If these geologic units are determined to have a low paleontological potential (PFYC 2), then the level of paleontological mitigation and monitoring can be reduced at the discretion of qualified professional paleontologist in cooperation with the BLM. Areas mapped as Holocene-age young alluvium (Qa) and artificial fill (af) should be spot checked during excavations that exceed depths of 3 feet to check for underlying, paleontologically sensitive geologic deposits. If older, native deposits are observed, full time monitoring should be implemented in those areas. If it is determined that only Holocene-age alluvium (PFYC 2) or artificial fill (PFYC 2) is impacted, the monitoring program should be reduced or suspended.

PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R REFERENCES

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PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R Hewett, D.F., 1956, Geology and Mineral Resources of the Ivanpah Quadrangle, California and Nevada: U.S. Geological Survey Professional Paper 275, scale 1:125,000.

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PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R Paleobiology Database, 2018, accessed January 31, 2018. Available online: https://paleobiodb.org/

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PANORAMA ENVIRONMENTAL, INC. & BUREAU OF LAND MANAGEMENT GEMINI SOLAR PROJECT PSI REPORT NO.: NV18CLARKPAN01R Wilson, E.C., and Langenheim, R.L., 1993, Early Permian corals from Arrow Canyon, Clark County, Nevada: Journal of Paleontology, v. 67, no. 6, p. 935-945.

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Quarter-Quarter Section Township/Range Surface Management Agency

SESE, SWSE, SESW, SWSW 31 Bureau of Land Management T16S R65E (BLM) SESW, SWSW 32 NWSW, NESW, NWSE, SWSW, SESW, SWSE, SESE 10 NWSE, NESE, SWSW, SESW, SWSE 11

NWNE, NENE, SWNW, SENW, SWNE, NWSW, 12 NWSE, NESE, SWSE, SESE NWNW, NENW, NWNE, NENE, SWNW, SENW, SWNE, SENE, NWSW, NESW, NWSE, NESE, SWSW, 13 SESW, SWSE, SESE NENW, NWNE, NENE, SWNE, SENE, NWSE, SWSE 14

NENW, NWNE, NENE 15

NWNE, NENE 23 T17S R64E BLM NWNW, NENW, NWNE, NENE, NESE, SESW, SWSE, 24 SESE NENW, NWNE, SWNW, SENW, SWNE, SENE, 25 NWSW, NESW, NESE, SWSW, SESW, SWSE, SESE NESE, SWSE, SESE 26 NWNE, NENE, SENW, SWNE, SENE, NWSW, NESW, 35 NWSE, NESE, SWSW, SESW, SWSE, SESE NWNW, NENW, NWNE, NENE, SWNW, SENW, SWNE, SENE, NWSW, NESW, NWSE, NESE, SWSW, 36 SESW, SWSE, SESE NENE, NWNE, NWNW, NENW, SENE, SWNE, SENW, SWNW, NESE, NWSE, NESW, NWSW, SESE, 7 SESW, SWSW NENE, NWNE, NENW, NWNW, SENE, NWNE,

SENW, SWNW, NESE, NWSE, NESW, NWSW, SESE, 8

SWSE, SESW, SWSW

NENE, NWNE, NENW, NWNW, SENE, SWNE, SENW, SWNW, NESE, NWSE, NESW, NWSW, SESE, 9 SWSE, SESW, SWSW NWNW, SWNW, NWSW, SWSW 10

SWNW, NWSW, NESW, SWSW, SESW 14

NWNW, SWNW, SENW, SWNE, SENE, NWSW, 15 NESW, NWSE, NESE, SWSW, SESW, SWSE, SESE NENE, NWNE, NENW, NWNW, SENE, SWNE, T17S R65E BLM SENW, SWNW, NESE, NWSE, NESW, NWSW, 16 SWSW, SESW, SWSE, SESE NENE, NWNE, NENW, NWNW, SENE, SWNE, SENW, SWNW, NESE, NWSE, NESW, NWSW, SESE, 17 SWSE, SESE, SWSE, SESW, SWSW NENE, NWNE, NENW, NWNW, SENE, SWNE, SENW, SWNW, NESE, NWSE, NESW, NWSW, SESE, 18 SWSE, SWSW NENE, NWNE, NENW, NWNW, SENE, SWNE, SENW, NESE, NWSE, NESW, NWSW, SESE, SWSE, 19 SESW, SWSW NENE, NWNE, NENW, NWNW, SENW, SWNE, SENW, SWNW, NESE, NWSE, NESW, NWSW, SESE, 20 SWSE, SESW, SWSW

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Quarter-Quarter Section Township/Range Surface Management Agency NWNW, NENW, NWNE, NENE, SENW, SWNE, 21 SENE, NWSW, SESW, SWSW NWNW, NENW, NWNE, NENE, SWNW, SENW, 22 SWNE, SENE, SWSE, NESE NWNW, NENW, SWNW, SENW, NWSW 23 NENW, NWNW, SENW, SWNW, NESW, NWSW, 28 SESW, SWSW NENE, NWNE, NENW, NWNW, SENE, SWNE, SENW, SWNW, NESE, NWSE, NESW, NWSW, SESE, 29 SWSE, SESW, SWSW NENE, NWNE, NENW, NWNW, SENE, SWNE, SENW, SWNW, NESE, SWSE, NESW, NWSW, SESE, 30 SWSE, SESW, SWSW NENE, NWNE, NENW, NWNW, SENE, SWNE, SENW, SWNW, NESE, NWSE, NESW, NWSW, SESE, 31 SWSE, SESW, SWSW NENE, NWNE, NENW, NWNW, SENE, SWNE, SENW, SWNW, NESE, NWSE, NESW, NWSW, SESE, 32 SWSE, SESW, SWSW NENW, NWNW, SENW, SWNW, SWSW 33 NWNW, NENW, NWNE, NENE, SWNW, SENW, 1 SWNE, SENE, NWSW, NESW, NWSE, SWSW, SESW

NWNW, NENW, NWNE, NENE, SWNW, SENW,

SWNE, SENE, NWSW, NESW, NWSE, NESE, SWSW, 2 SESW, SWSE, SESE T18S R64E BLM NESE 3 NWNW, NENW, NWNE, NENE, SWNW, SENW, 11 SWNE, SENE, SNWSW, NESW, NWSE, NESE NWNW, NENW, SWNW 12 NWNW, SWNW, NWSW, SWSW 4 NENE, NWNE, SENE, SWNE, SESE, NESE, NWSE, 5 SWSE, NWNW, NENW, SENW T18S R65E BLM NENE, NWNE 6 NENE 8

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