United States Department of Agriculture Forest Service February 2011 Revised March 2015 Biological Evaluation and Botanical Specialist Report Covering Listed, Proposed, Candidate, Sensitive, and Forest Watch Plant Species CuMo Project Idaho City Ranger District, Boise National Forest, Boise County, Idaho Prepared by: Robert G. Kremer, Ph.D. Christopher Reichard Brown and Caldwell 950 West Bannock Street, Suite 250 Boise, Idaho 83702 Kay Beall Boise National Forest, Idaho City Ranger District For Information Contact: Edna Rey-Vizgirdas Boise National Forest Supervisor’s Office 1249 S. Vinnell Way, Suite 200 Boise, Idaho 83709 208-373-4100 [email protected]
Transcript
United States Department of Agriculture
Forest Service
February 2011 Revised March 2015
Biological Evaluation and Botanical Specialist Report Covering Listed, Proposed, Candidate, Sensitive, and Forest Watch Plant Species CuMo Project Idaho City Ranger District, Boise National Forest, Boise County, Idaho Prepared by: Robert G. Kremer, Ph.D. Christopher Reichard Brown and Caldwell 950 West Bannock Street, Suite 250 Boise, Idaho 83702 Kay Beall Boise National Forest, Idaho City Ranger District
For Information Contact: Edna Rey-Vizgirdas Boise National Forest Supervisor’s Office
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iological Evalua i and o anical Spec·ali epo
Covering ·sted, P o osed, Ca didate Se sitive, and Forest
EXECUTIVE SUMMARY Refer to the 2015 Addendum to the BE for the determination concerning Lewisia sacajaweana. While no other known Sensitive plants appear to grow within the Project boundaries, habitat does exist for three other Sensitive species, Douglasia idahoensis (Idaho dwarf primrose), Phacelia minutissima (least phacelia), and Pinus albicaulis (whitebark pine). However, the likelihood of risk to any undocumented populations is low.
Under Alternative A or B, this Project may impact Douglasia idahoensis, Phacelia minutissima, and Pinus albicaulis individuals but would not likely contribute to a trend toward federal listing or cause a loss of viability to the population or species (MIIH).
Under Alternative C (No Action), this Project would have no impacts on Sensitive plants because road construction or drilling activities would not occur.
Mitigation Measures and Monitoring Refer to the 2015 Lewisia sacajaweana Addendum to the BE (USDA Forest Service 2015) for mitigation and monitoring measures concerning Lewisia sacajaweana.
Surveys will be conducted for the following Sensitive species Douglasia idahoenisis, Phacelia minutissima, and Pinus albicaulis in suitable habitat during the appropriate time by qualified botanists prior to any ground-disturbing activities (including road construction, road maintenance, drill pad construction, and drilling). If individuals of Douglasia idahoenisis, Phacelia minutissima, or Pinus albicaulis are located during surveys, occupied habitat shall not be impacted by Project-related activities (e.g., road construction, road maintenance, drill pad construction, drilling).
Table of Contents EXECUTIVE SUMMARY ...................................................................................................... i
Mitigation Measures and Monitoring ......................................................................................... i
INTRODUCTION .................................................................................................................. 1 Plant Species of Concern Categories ......................................................................................... 1
PROJECT AREA DESCRIPTION AND BACKGROUND ..................................................... 2
PROPOSED ACTION AND ALTERNATIVES ...................................................................... 7 Alternative A—Applicant Proposed Action .............................................................................. 7 Alternative B—Reduced Roads Alternative ........................................................................... 12 Alternative C—No Action Alternative .................................................................................... 13
FIELD SURVEYS AND RESULTS ......................................................................................16
DISCUSSION ......................................................................................................................19 Sensitive Species ..................................................................................................................... 19 Forest Watch Species .............................................................................................................. 21
EFFECTS OF ALTERNATIVES ..........................................................................................21 Alternative A—Applicant Proposed Action ............................................................................ 21
Direct and Indirect Effects .............................................................................. 21 Cumulative Impacts ........................................................................................ 24
Alternative B—Reduced Roads Alternative ........................................................................... 26 Direct, Indirect, and Cumulative Effects ........................................................ 26
Alternative C—No Action ....................................................................................................... 26 Direct, Indirect, and Cumulative Effects ........................................................ 26
FOREST PLAN CONSISTENCY ........................................................................................26
DETERMINATION AND RATIONALE ................................................................................27
LITERATURE CONSULTED ..............................................................................................28
List of Tables Table 1. Summary of Existing, Proposed, and Cumulative Roads ................................13 Table 2. Plants observed during 2007 field survey .........................................................17 Table 3. Sensitive plant species for the Boise National Forest and likely occurrence within the CuMo Project Area ...........................................................................................20 Table 4. Summary of impact determinations for rare plants with potential or occupied habitat in the project area .................................................................................................25
List of Figures Figure 1.General Project Vicinity ...................................................................................... 3 Figure 2. Access Routes to Project Area .......................................................................... 4 Figure 3. County roads providing access to the Project Area ........................................ 5 Figure 4. Alternative A ....................................................................................................... 9 Figure 5. Alternative B ......................................................................................................14 Figure 6. Alternative C ......................................................................................................15
INTRODUCTION This document has been prepared as supporting documentation for the CuMo Exploratory Drilling Project Environmental Assessment and Supplemental Environmental Assessment (SEA) required by the Boise National Forest (Forest), Idaho City Ranger District. This document has been prepared using the Botanical Specialist Report and Biological Evaluation Covering Listed, Proposed, Candidate, Sensitive, Priority, and Forest Watch Plant Species for the CuMo Project (“original report”; USDA Forest Service 2011) as a template. Due to similarities in the purpose and function between this and the original report, many of the discussions from the original report, prepared by Kay Beall, District Botanist, Idaho City Ranger District, Boise National Forest, have been used in their entirety, where applicable, in this report.
This report has been updated to identify applicable changes since the original report was prepared and the SEA was released for notice and public comment in August 2013. Changes include, but are not limited to, Project details, cumulative effects, and species status. The original report contained a discussion about the presence of Lewisia sacajaweana (Sacajawea’s bitterroot), a Region 4 Sensitive species, within the Project Area and analysis of the potential impacts to these populations. References to the Lewisia sacajaweana have been deleted because a supplement (USDA Forest Service 2015) has been prepared to this report that solely addresses this species whose status has changed from a Forest Watch species in 2011 to a Region 4 Sensitive species.
Plant Species of Concern Categories U.S. Fish and Wildlife Service (USFWS) Listed, Proposed, and Candidate Species—No federally listed or proposed plants are known to occur on the Forest. The only federal Candidate plant species know to occur on the Forest is Pinus albicaulis (whitebark pine). The list for the Idaho City Ranger District contains no listed or proposed plant species, thus no section 7 consultation for botanical species is required at this time.
Sensitive—Sensitive species are those plants eligible for listing under the Endangered Species Act (ESA) or whose viability is of concern. The current Region 4 Sensitive Plant List is dated February 2013. While no known Sensitive plants other than Lewisia sacajaweana (Sacajawea’s bitterroot; see the 2015 Addendum to the BE) appear to grow within the Project boundary, habitat does exist for three other Sensitive species, Douglasia idahoensis (Idaho dwarf primrose), Phacelia minutissima (least phacelia), and Pinus albicaulis (whitebark pine).
Forest Watch—Forest Watch species are those that do not meet the criteria to be included on the Regional Forester’s Sensitive Plant List but are of sufficient local viability concern to be considered in the planning process.
PROJECT AREA DESCRIPTION AND BACKGROUND The Project Area encompasses approximately 2,885 acres within the Forest in Sections 7, 8, 17, 18, 19, and 20, Township 8 North, Range 6 East (Figure 1). The Project Area is approximately 5 miles upstream of Pioneerville, Idaho, and about 14 miles north of Idaho City in Boise County, Idaho.
The proposed exploration Project Area, which is approximately 2 miles along its east–west axis and 2.4 miles along its north–south axis, lies within the Upper Grimes Creek subwatershed of the Boise–Mores drainage. It is bounded by Grimes Creek to the north and the Jackson Peak ridgeline to the south. Four routes lead into the Project Area (Figure 2 and Figure 3). One is by way of County Road (CR) 307 and CR 382 north from Idaho City; this road passes through Centerville and Pioneerville along Grimes Creek. The second route is southeastwardly from Garden Valley by way of CR 382; this route follows the Banks–Lowman Highway (State Highway 17, NFS road 24) along the south bank of the road runs along the south bank of the South Fork Payette River and Sweet Creek. The third route is by way of CR 307 and CR 382 east from Horseshoe Bend. The fourth route is by way of CR 615, CR 307, and CR 382 south from Garden Valley; this route passes through Placerville and Centerville (see Enviroscientists 2013). Within the subwatershed, the Project Area is accessed eastwardly from the Grimes Pass area by NFS roads 397 and 397B, although NFS road 397B is gated just beyond the Grimes Creek trailhead (NFS trail 169). NFS road 397B joins the existing network of unauthorized roads within the Project Area. The proposed operations would have access eastwardly from Grimes Creek by way of NFS roads 380F, 382B, 382C, and 382C4. These roads would join with the temporary road network proposed for this Project.
Average annual precipitation for the Project Area is 28–30 inches, largely as winter snowfall. The closest weather station with temperature data is in Garden Valley; historical values there range from a low of 17 degrees Fahrenheit (°F) in January to a high of 91 °F in July. Terrain within the Project Area is typical for the Upper Grimes Creek subwatershed, with incised valleys and steep hill slopes. Granodiorite and granitic rocks underlying the area are well weathered with few outcrops. Soil horizons are poorly developed; soil is typically sandy and well drained. Hillsides have intermingled dispersed forest and meadow. South-facing slopes in the northeastern part of the Project Area are largely denuded of vegetation. These bare slopes, which may result from geochemical side effects of base metal mineralization, were the original exploration target during the 1970s.
The CuMo Molybdenum Prospect (CuMo) was discovered by AMAX Exploration Inc. (AMAX) in 1963. AMAX and its joint venture partners, AMOCO Minerals and Climax Molybdenum, completed multiple stages of exploration beginning in 1968 and continuing through 1982. This exploration included geological mapping, geochemical surveys, geophysical surveys, and 26 exploration drill holes. During this time, AMAX developed a number of rough access roads. A segment of this network was incorporated into National Forest System (NFS) road 397B, and approximately 4.7 miles remain as existing unauthorized roads. A rough timber bridge was constructed on what is now NFS road 397B, where it crosses Grimes Creek; the bridge, which has been in very poor condition since 2005, was condemned by Forest Service engineers.
In 2005, Kobex Resources Ltd., of Vancouver, British Columbia, approached the Forest Service with a plan to drill 16 exploration holes at CuMo. They developed a Plan of Operations (PoO) that included drilling, using the existing 4.7-mile network of existing unauthorized roads, and replacing the Grimes Creek bridge with a culvert. The Grimes Creek culvert replacement included in the 2005 PoO included installing and removing the culvert; the culvert was to be removed prior to closing out the 2005 PoO. The Forest Service determined that the proposed project would have no individual or cumulative significant effects, and it was categorically excluded from further analysis by either an Environmental Assessment (EA) or an Environmental Impact Statement (EIS). After some delay, their PoO was approved and bonded. Kobex began operations in summer 2006 by installing the Grimes Creek culvert and drilling some core holes.
In fall 2006, Mosquito Consolidated Gold Mines Limited (MCGM), Vancouver, British Columbia, assumed control of the CuMo program and Kobex's bonded PoO. They continued using the culvert crossing Grimes Creek and the existing unauthorized road network. Exploration drilling began summer 2007. The Forest Service signed a decision memo for a request to extend the 2005 PoO on June 22, 2009. This request also extended the 2005 PoO through November 2009. Under the extended 2005 PoO, the culvert crossing at Grimes Creek was to be removed; it was removed in 2011. .
In February 14, 2007, MCGM submitted a new PoO. MCGM's subsidiary was established as Mosquito Gold Corp (now known as Idaho CuMo Mining Corporation [CuMoCo]) in Reno, Nevada. The new plan was to modify and replace the original and extended 2005 PoO. CuMoCo’s new plan proposed up dto 13.3 miles of new, temporary road construction, continued use of the 4.7 miles of permitted roads, and up to 122 drill pads. The plan was accepted as sufficient for processing by letter dated March 5, 2007. That letter also stated the need to prepare a detailed environmental statement; it was determined that an environmental assessment (EA) would be required.
The May 2007 Memorandum of Understanding (MoU) between the Forest Service and CuMoCo stipulated that the EA would be prepared by a third-party contractor. Brown and Caldwell of Boise, Idaho, was selected on May 30, 2007, to prepare the EA.
During 2007 and 2008, additional plan details were agreed to by the Forest Service and CuMoCo. These details were formalized in a letter dated April 29, 2008.
The Responsible Official, Forest Supervisor Cecilia R. Seesholtz, issued the DN/FONSI for the CuMo Exploration Project on February 11, 2011. The alternative selected for implementation was Alternative B. On July 27, 2011, a lawsuit was filed against the project:
Idaho Conservation League, et al., v. United States Forest Service (1:11-CV-00341-EJL). On August 29, 2012, the United States District Court of the District of Idaho (Court) issued its Memorandum Decision and Order. The Court ordered, “that the Defendant Forest Service’s decisions regarding groundwater made in the Environmental Assessment [be] vacated and the matter …remanded to the Forest Service for further proceedings consistent with this opinion…” CuMoCo ceased exploration activities, and the Forest Service prepared a Supplemental EA (SEA). The public review draft SEA was issued on August 19, 2013.
PROPOSED ACTION AND ALTERNATIVES Alternative A—Applicant Proposed Action Alternative A (Figure 4) is the Proposed Action, as described in the 2007 PoO submitted by CuMoCo on February 14, 2007. The Proposed Action described herein includes the details and minor modifications agreed to by CuMoCo and the Forest Service, as listed in a letter dated April 29, 2008, with updates to Project details, including Project-related activities conducted between the 2011 DN/FONSI and 2012 Court Order, and the additional 2 haul (fuel transportation) routes requested by CuMoCo in February 2014. The exploration drilling program will be result-driven, so that future holes will be drilled to expand and complement the existing database.
Consequently, predicting the exact sequence of events, exact road locations/alignments, and timing or orientation of a particular drill pad/hole is difficult. Not all of the temporary roads and/or drill pads in the design may be constructed. Additionally, the exploration program might end earlier than anticipated.
Under Alternative A, CuMoCo would conduct a 5-year mineral exploration project on the CuMo claim block (Project Area). More specifically, the exploratory operation would focus on delineating a viable copper/molybdenum mineral deposit that would allow subsequent modeling of the subsurface geology and associated structure and mineralization. A total of 12.67 miles of drill roads were constructed on the site by AMAX Exploration and Climax Corporations between 1973 and 1980. Under this Proposed Action, 4.7 miles of existing unauthorized roads would be permitted for use as existing temporary roads, and up to an additional 13.3 miles of temporary roads would be constructed over the next 5 years. A total of 17 stream crossings would be used, including 7 on existing NFS roads, 5 on the 4.7 miles of existing temporary roads, and 5 new crossings associated with the new, temporary roads to be constructed. At each drill site, a small drill pad and mud pit would be developed so that equipment and vehicles can access each site and drill fluids are retained onsite. Appropriate erosion control and Best Management Practices (BMPs) would be installed around drill pads and along temporary roads. Drill holes would be either vertical or angled holes designed to best investigate the subsurface geology. Holes would range in length from 1,500 to 3,000 feet.
The operating season would be approximately April 15 through December 15. The Forest Service would review special circumstances that may require date adjustments. At any given time, up to 4 drill rigs, each staffed by up to 3 personnel, could be operated in the Project Area. Because field operations would be managed by up to 2 additional staff from CuMoCo, a total of up to 15 staff could be onsite at any given time. Housing for staff would be located
on nearby private lands in Centerville or Garden Valley. Travel to the site would be provided by 1-ton type service and support vehicles owned and operated by the contracted drilling company. CuMoCo would anticipate 30 one-way vehicle trips per day. Of these 30 one way vehicle trips, 4 trips would be for fuel transportation. Under these conditions, CuMoCo’s vehicle trips would originate from Centerville, Horseshoe Bend, or Garden Valley to the Project Area. Each drill rig would be mobilized and demobilized once during the season, barring unforeseen events. When constructing temporary roads, natural routes and topographic features would be utilized and temporary roads would be located on ridges wherever possible.1
These temporary roads would be gated to control vehicle access to the Project Area. In addition, CuMoCo would avoid cultural sites designated by the Forest Service by ensuring the proposed new, temporary roads and drill pads did not intersect with cultural sites. CuMoCo anticipates a portion (60%–80%) of the proposed temporary roads would be constructed and operational at any one time. As a result, the total length of the temporary roads in service at any given time would be reduced by 20%–40%. During the Supplemental EA preparation and review process, CuMoCo updated its PoO by identifying 2 additional haul (fuel transportation) routes for the Project Area. CuMoCo would use all 4 routes to access the Project Area. The 4 haul routes would be on County maintained roads, and CuMoCo and Boise County would enter into a maintenance agreement. The primary access to the Project Area would be from NFS roads 380F, 382B, 382C, and 382C4 on the southwest side of the Project Area. Access to the Project Area via NFS road 397B would be for emergency use only.
Drill pads would generally be located along the temporary roads and would typically be 60 feet long by 25 feet wide with ends contoured back into the roadway. Each drill pad would have a compartmentalized mud pit developed so that equipment and vehicles could access each site and drill fluids are retained on site. These mud pits would measure 25 feet long, 6 feet wide, and 8 feet deep. Standard practices would include recirculating the drill fluid to create a closed system. Once the drill pad is no longer needed, the mud pits would be backfilled with native soil material, compacted, and recontoured. Drill cuttings and nontoxic, biodegradable drilling mud would remain in the backfilled mud pits.
1 The approximate lengths of the individual roads are shown in Table 1 of the 2007 PoO (Mosquito Consolidated Gold Mine 2008), and range from approximately 1,045 feet (about 0.2 miles) to 9,250 feet (about 1.75 miles). The labels given to individual roads in Table 1 of the 2007 PoO correlate to those labeled on Map 3 of the 2007 PoO (Mosquito Consolidated Gold Mine 2008).
Up to a total of 256 sample holes with various orientations and inclinations would be drilled from up to 122 drill pads, utilizing a truck, wagon, or skid-mounted diamond coring machine. The drilling would be completed in a series of stages, initially with wide-spaced drilling followed by infill drilling for reserve definition. Although most of the proposed drill holes would be vertical, geology might dictate angled drilling. Most drill pads would have more than one hole drilled from them. Upon completion, all holes would be filled with a bentonite-cement mixture designed to effectively seal and stabilize down-hole conditions. Each hole would be topped with a cement plug or similar device.
CuMoCo or its corporate predecessors MCGM and Kobex drilled 43 holes (a total of 68 diamond-bit core holes have been drilled from 1968 to the present). Of those 43 holes, 11 holes were drilled between the issuance of the 2011 DN/FONSI and the August 2012 Court Order. In order to drill the 11 holes, CuMoCo reconstructed 5 existing drill pads. From these 5 drill pads, CuMoCo drilled 7 drill holes. CuMoCo drilled the additional 4 drill holes on private patented lands. In addition to the 11 drill holes, CuMoCo also constructed approximately 1.53 miles of temporary roads connecting NFS road 382C with the existing 4.7 miles of temporary roads (AMAX roads).
Immediately upon completion and prior to December 15, the mud pits would be covered and compacted with a bulldozer, and the pad contoured. Drilling operations require water or some type of drilling fluid to cool the bit, lubricate the advancing hole, and remove cuttings from the bit face to the surface. Current practice is to use one or more of several types of synthetic nontoxic, biodegradable polymer mud products to increase the viscosity of water enough to achieve the desired effects.2
Plastic or steel tanks would be used to store or hold mixed drill fluids and to store make-up water at the drill site. Water holding tanks may also be used at pumping sites. Water would be supplied to the drill rigs by the way of one or two diesel or gas powered high-capacity pumps, and high-pressure rubber-coated woven steel water hose. CuMoCo would obtain a temporary approval of water appropriations before implementing any activities requiring the water appropriations. Water would be drawn from either an existing standpipe (located in the northeast portion of the Project Area as shown in Figure 4) with a turn valve adjacent to a road in the northeast quarter of section 17, T8N R6E, or it would be drawn from Grimes Creek and/or Charlotte Gulch. If water is pumped from Grimes Creek, a screen would be placed around the water intake to prevent fish from entering the pump. Water haul trucks might be used to move water from either source to drill pads.
No permanent structures would be placed or fabricated in the Project Area. An approximately 8-foot by 8-foot skid-mounted shed would be associated with each drill rig, for a total of up to 4 temporary storage sheds. Inclement weather (cold, snow, or heavy rain) might dictate that some sort of shelter be placed over the water pumps. A portable toilet would be provided for work crews and serviced regularly throughout the proposed action.
2 Some of these products are in powder form and come in plastic-lined paper bags weighing approximately 50 pounds (lbs) such as bentonite gel, which is commonly used for thickening drill mud. Other drill fluid additives are available in liquid in 5 gallon plastic containers such as Poly Plus 2000 polymer and Rod Ease. Poly Plus 2000 is a biodegradable polymer that forms long chain molecules when mixed with water. Rod Ease is a vegetable oil-based product added to the drill fluid to loosen up the drill string when squeezing conditions are present in the drill hole and to better lubricate the bit and drill string.
Drill machines and newer water pumps would be powered by diesel fuel, while older water pumps would be powered by gasoline. Fuel would be delivered in tanks located in the back of service pickups. When not in use, those pickups would be parked at the drill pads. Each water pump would utilize a 55-gallon drum as a fuel tank to supply fuel to the pump. Those pumps would be refueled by the service pickups that fuel the large equipment. Each pump and drum would be contained within a lined and enclosed spill prevention area. Each drill pad may also utilize one or more 5- to 10-gallon plastic fuel containers located within the drill pad. Total onsite fuel storage, excluding service pickups that would deliver fuel daily, would not exceed 250 gallons.
Fuel spill and containment equipment would be provided to respond to any spills that may occur during equipment fueling. Approximately 100 gallons of diesel would be consumed each day by each drill rig. If fuel storage is required onsite, fuel would be stored in a 55-gallon drum or other legal container located in a lined storage area capable of holding 1.5 times the container volume. Fuel spill control kits would be provided for any fuel storage location.
Onsite storage of drill consumables, including drill fluid products would be held to a minimum. Bagged items would be protected from weather using plastic sheeting. The plastic drum-contained liquids would be stored on wood pallets. All refuse and debris generated by the use of these products would be regularly brought offsite and disposed of via the local waste disposal provider.
A Spill Prevention Control and Countermeasure Plan (SPCC) has been developed for the site. Mosquito prepared the SPCC in June 2011, and the Forest Service reviewed and approved the SPCC (Forsgren 2011b). CuMoCo would be responsible for updating the SPCC as the Project moves forward. Drilling crews would take immediate action to contain and collect any spill of hazardous or non-hazardous substances. Upon completion of control and collection efforts, the supervisor of the operating facility would record the date, time, nature, and character of the spill along with the actions taken to contain and collect the materials. The report would document whether any material entered surface waters. It would also estimate how much of the spilled product, if any, was not able to be collected. A hazardous substance spill would be reported in accordance with State and federal reporting requirements.
CuMoCo has obtained a Multi-Sector General Permit (MSGP) and Construction General Permit (CGP) under the National Pollutant Discharge Elimination System (NPDES). CuMoCo prepared and submitted its Notice of Intent and Stormwater Pollution Prevention Plan (SWPPP) in April 2011. Per the SWPPP, CuMoCo is required to control soil and pollutants that originate from the Project site and prevent them from entering surface waters. The SWPPP serves as a guideline for contractors to implement BMPs on the Project site (Forsgren 2011b). CuMoCo would be required to maintain the MSGP and CGP for the life of the project and update the SWPPP, as needed.
CuMoCo obtained their final §401 Water Quality Certification from the Idaho Department of Environmental Quality (IDEQ) in June 2011. CuMoCo must comply with all monitoring and reporting requirements under the State certification program (IDEQ 2011).
Concurrent reclamation3 and interim stabilization would be implemented throughout the
proposed action in order to remain within a 60%–80% threshold for permitted temporary roads open at one time. All temporary roads would be reclaimed (13.3 miles of newly constructed roads and 4.7 miles of existing roads) as close as practical to their original topography; and affected areas would be revegetated to forest standards by the end of the reclamation period (i.e., up to 2 years after the 5-year exploration period).
Reclamation or obliteration of the temporary roads and drill holes would consist of earthwork and revegetation of all surface disturbances to stabilize the reclaimed areas and to achieve post-exploration land use pursuant to 36 CFR §294.12(b)(7). More specifically, reclamation would include backfilling and re-contouring the mud pits as drilling is completed. Temporary roads constructed on steep slopes would be backfilled and re-contoured to the approximate original contour. Temporary roads constructed on moderate and shallow slopes would be reclaimed using a combination of partial contouring and ripping as site conditions warrant. All disturbed areas would be seeded with a combination of range and reclamation species that are suitable for soil stabilization and reclamation projects on the Forest.
Alternative B—Reduced Roads Alternative Alternative B (Figure 5) was developed to address issues identified during the 2011 EA scoping—namely, the extent of proposed temporary roads and resultant concern over potential erosion and sedimentation to Grimes Creek.
Under Alternative B, up to 10.2 miles of new, temporary roads would be constructed, involving 4 new stream crossings (total of 16 stream crossings), up to 137 drill pads,4
and up to 259 drill holes (Figure 5). Alternative B represents a reduction of 3.1 miles (approximately 22%) in the total mileage of proposed roads compared to Alternative A (Table 1). This reduction includes eliminating 0.62 miles of new, temporary road that is proposed under Alternative A. Under Alternative A, this road segment is proposed within 500 feet of Grimes Creek in the northeastern portion of the Project Area. To reduce the miles of road construction, the proposed design would require increasing the number of inclined holes under Alternative B compared to Alternative A. Alternative B also proposes increasing the total number of drill holes (up to 259, compared to up to 256 under Alternative A) and increasing the total number of drill pads (up to 137, compared to up to 122 under Alternative A). The remainder of operations proposed under Alternative B would be identical to Alternative A.
3 Concurrent reclamation is defined as final reclamation conducted during exploration operations 4 The July 2010 EA, which was released for a 30-day notice and comment period, specified that up to 134, rather than up to 137, drill pads would be constructed. This figure (134) was later determined to be an error that has been corrected. No change in environmental consequences as a result of this correction would be anticipated.
Alternative C—No Action Alternative Under Alternative C, no drilling or temporary road and drill pad construction would occur (Figure 6).
Table 1. Summary of Existing, Proposed, and Cumulative Roads
Road Type Alternative A (Proposed
Action) Alternative B
Alternative C (No Action
Alternative)
Existing Unauthorized Roads (Utilized and Maintained Roads Under Separate Actions) 4.7 4.7 4.7
Existing NFS Roadsa 7.9 7.9 7.9
Proposed New, Temporary Roads 13.3 10.2 0.0
Cumulative Roadsb 18.0 14.9 4.7
aIncludes 0.5 miles of trails that allow motorized use bCumulative effects analysis for roads includes 4.7 miles of existing unauthorized roads in addition to proposed roads under each alternative. Existing NFS roads are described by and included in the Affected Environment.
FIELD SURVEYS AND RESULTS Refer to the 2015 Lewisia sacajaweana Addendum to the BE for the discussion of field surveys and results concerning Lewisia sacajaweana . The following discussion pertains to other rare plants. The analysis area for direct and indirect effects to Sensitive plants is the CuMo Project Area (Figure 1).
The Project Area is dissected by two perennial and several ephemeral and intermittent streams, in addition to the place where NFS road 397B crosses Grimes Creek. NFS road 397B roughly forms the northern perimeter, while the interior is crisscrossed by other existing minor roads. The Project Area elevation ranges from roughly 5,200 feet where NFS road 397B crosses Grimes Creek to nearly 7,100 feet at the uppermost proposed roads and drill pads (T8N, R6E, Section 20).
The lower forested areas are dominated by Douglas-fir and ponderosa pine. Understory plant species observed during the 2007 field surveys included ninebark, white spirea, buffaloberry, mountain hollyhock, pinegrass, cinquefoil, Wheeler’s bluegrass, western yarrow, hawkweed, low penstemon, arnica, huckleberry valerian, and many others (Table 2). East slopes and upper elevations support mixed stands of subalpine fir and Douglas-fir (much of it damaged by mistletoe) and a variety of forbs. Forested stands in all Potential Vegetation Groups (PVGs) are intermixed with extremely dry, rocky openings that support scattered Douglas-fir and ponderosa pine.
Scattered instances of the noxious weed rush skeletonweed (Chondrilla juncea) were observed along CR 382, Charlotte Gulch Road. No other noxious weeds were observed in the area. Several introduced plant species were also observed, including smooth brome (Bromopsis inermis), salsify (Tragopogon dubius), and dandelion (Taraxacum officinale). The area is dominated by native plant species while noxious and introduced species also occur, primarily near existing roadways.
DISCUSSION Sensitive Species Habitat suitability for Sensitive plant species was analyzed using various botanical field surveys within the Project Area, timber stand PVG data, and the original report. Other than the identified population of Lewisia sacajaweana, (see USDA Forest Service 2015), no Rare Plant Communities (as identified in Appendix C of the Forest Plan [USDA Forest Service 2010]) were identified through either PVG analysis or field surveys as part of this study, and have been eliminated from further analysis. The areas analyzed for this report include the CuMo Project Area (Figure 1).
See Table 3 for a list of Sensitive plant species for the Forest, including those not discussed in detail in this report.
Pinus albicaulis (whitebark pine): Pinus albicaulis is a high-elevation conifer species that is declining throughout its range due to factors including white pine blister rust, fire exclusion, mountain pine beetle, and climate change. Potential habitat for this species may be found above approximately 7,000 feet within the Project Area. Currently, no known locations of this species exist in the Project Area. Scattered Pinus albicaulis individuals have been located as low as 5,400 feet approximately 8 miles east of the CuMo Project Area (3 miles east of Pilot Peak). Thus, it is remotely possible that individual Pinus albicaulis could occur below 7,000 ft in the Project Area.
Lewisia sacajaweana (Sacajawea’s bitterroot): A separate supplement addressing Lewisia sacajaweana, including potential impacts from Project-related activities has been prepared (see USDA Forest Service 2015).
Douglasia idahoensis (Idaho dwarf primrose): Douglasia idahoensis is a perennial, mat forming herb with prostrate-to-ascending stems and magenta flowers with yellow throats. Douglasia idahoensis is endemic to north and central Idaho with 21 sites documented on the Forest and 7 sites in the Idaho City Ranger District. Habitat consists of north and east facing slopes on open, subalpine ridges in Pinus albicaulis and subalpine fir forests with elevations ranging from 7,200 to 9,000 feet. It typically grows on composed loose slopes of decomposed bedrock. The species is associated with Pinus albicaulis, subalpine fir, ballhead gilia, alpine fleeceflower, and Lewisia sacajaweana . Since most of the Project Area is below 7,200 feet and no Pinus albicaulis occur within the Project Area, it is highly unlikely that the species is present. Douglasia idahoensis has not been located during field surveys, and much of the Project Area does not support Douglasia idahoensis habitat since the elevation is too low. An exception is the southern part of the Project Area, which includes elevations of 7,200 feet and higher near Jackson Peak.
Further, much of the central and southern portions of the Project Area were deemed unlikely to support Lewisia sacajaweana due to dense herbaceous and shrub cover, which would likely preclude Douglasia idahoenisis.
Phacelia minutissima (least phacelia): Phacelia minutissima is a tiny annual that occurs in areas that are vernally saturated (summer drying) and sparsely vegetated, often near Veratrum californicum (false hellebore) and/or aspen stands and swales in sagebrush. No known locations of this species exist in the Project Area or on the Forest. The closest known
Phacelia minutissima site occurs approximately 50 miles east of the CuMo Project in the Soldier Mountains, Sawtooth National Forest. Small areas of potential habitat for this species occur in the Project Area.
Table 3. Sensitive plant species for the Boise National Forest and likely occurrence within the CuMo Project Area
USFWS Listed/Proposed/Candidate
Species Habitat and Rationale for Eliminating from Consideration
Small-scale openings in sagebrush-steppe habitat. Occurs in microsites where soils have higher clay and sodium content than adjacent areas. Low - mid elevation sites (up to 5,300 ft). No habitat present; out of geographic range
No
Pinus albicaulis—Whitebark pine G3G4/Candidate/Sensitive
Subalpine plant communities at high-elevation sites (~7,300–10,500 ft) in Idaho. Potential habitat occurs above ~7,000 ft in Project Area
Yes
Region 4, Boise National Forest
Sensitive Species Habitat and Rationale for Eliminating from Consideration
Relatively sparse upper slopes and ridgetops. Fractured bedrock, granitic soils near late snow banks. 5,400–9,500 ft. Refer to USDA Forest Service 2015
Yes
Douglasia idahoensis—Idaho dwarfprimrose (G3 S3)
North/east facing slopes on open, subalpine ridges in Pinus albicaulis and subalpine fir forests. 7,200–9,000 ft. Limited habitat present, generally above 7,000 ft in Project Area
Yes
Phacelia minutissima—Least phacelia (G3 S2)
Sagebrush and aspen stands with late snow banks or seeps; false hellebore patches; open understory. 5,000–8,200 ft. Closest known >50 miles from Project Area; no known populations on the Boise National Forest
Yes
Allium tolmiei var. persimile—Tolmie's onion (G4 T3 S3)
Mixed semiarid shrub and grasslands in swales, ephemeral watercourses, or seeps; basalt. Seasonally wet soil dry by late summer; south slopes. 3,000–5,000 ft. Habitat not present
No
Bryum calobryoides—Bryum moss (G3 SH)
Low gradient wetlands, moist soil or rocks at montane to subalpine elevations. Above 5,000 ft. Meadows to moist cliff sides. State historic species; no known populations in Idaho
Vernally wet meadows and flats with shallow, basalt soils. Grassland/sagebrush communities. 4,600–6,500 ft. Habitat not present
No
Note: Components of Ranks: G = Global rank indicator based on rangewide status; S = State rank indicator based on status within Idaho; T = Trinomial rank indicator denotes status of infraspecific taxa.
1 = Critically imperiled because of extreme rarity or because some factor of its biology makes it especially vulnerable to extinction (typically 5 or fewer occurrences). 2 = Imperiled because of rarity or because other factors demonstrably make it vulnerable to extinction (typically 6 to 20 occurrences). 3 = Rare or uncommon but not imperiled (typically 21 to 100 occurrences). 4 = Not rare and apparently secure, but with cause for long-term concern (usually more than 100 occurrences). 5 = Demonstrably widespread, abundant, and secure. H = Historic.
Sedum leibergii (Leiberg stonecrop): Sedum leibergii is a robust stonecrop with a large basal rosette of rounded leaves. It grows on cliffs and rocky slopes with west and northwest exposures on a variety of rock materials. It is commonly associated with Douglas-fir; and known populations range in elevation from 5,000 to over 9,000 feet. An abundance of rocky habitat occurs within the Project Area, and some of it may be suitable for Sedum leibergii. The closest known population is north of the Forest in Valley County.
Botrychium simplex (least moonwort) (Forest Watch): Botrychium simplex is a very small perennial fern. This species is known to grow in a wide variety of habitats, including meadows and forested types, usually at mid-to-high elevations. On the Forest, populations of least moonwort are known to grow in peatland habitat on the Lowman Ranger District and grassy openings in lodgepole pine stands on the Cascade Ranger District. The greatest likelihood for this species within the Project Area is along riparian areas and seeps. The upland stands appear too dry to support least moonwort unless some scattered moist pockets of suitable habitat exist.
Botrychium crenulatum (scalloped moonwort) (Forest Watch): Botrychium crenulatum is a small perennial fern with three known populations on the Forest, and all occur in riparian habitat. Suitable habitat exists within the Project Area along streams or other moist pockets such as springs.
Sanicula graveolens (Sierra sanicle) (Forest Watch): Sanicula graveolens is a taprooted, herbaceous perennial that ranges from southern British Columbia to southern California and east to western Montana and northwest Wyoming. It grows in open or slightly wooded slopes and flats between 2,000 and 6,500 feet. No populations are known to exist on the Forest. Although potential habitat occurs in the Project Area, the likelihood of presence of this species is very low.
EFFECTS OF ALTERNATIVES Alternative A—Applicant Proposed Action Direct and Indirect Effects Pinus albicaulis (Whitebark pine) (Candidate/Sensitive): Currently, this species has not been located in the Project Area but a whitebark pine stand 1,000 meters southeast of the CuMo project boundary was documented. If present, this species could be impacted by Project activities involving ground disturbance, such as road building and drill pad construction. However, impacts would be avoided or substantially minimized through the requirement to survey areas prior to disturbance activity authorization (see pre-disturbance
checklist, Appendix B). If this species is identified, occupied habitat would be avoided to the maximum extent practicable5.
Lewisia sacajaweana (Sacajawea’s bitterroot): A separate supplement analyzing the potential impacts to Lewisia sacajaweana from Project-related activities has been prepared (see USDA Forest Service 2015).
Douglasia idahoensis (Idaho dwarf primrose) (Sensitive): No known locations of this species occur in the Project Area or the surrounding 5th field HUC, but some potential habitat exists in the southwestern portion of the Project Area. A portion of the two proposed southernmost roads would rise above 7,200 feet elevation into areas near Jackson Peak that may contain Idaho primrose. Based on aerial photos, these two roads would pass through primarily forested area and would appear to avoid the bare areas shown on the map, which are more likely to contain Idaho primrose. The two roads would pass through areas that appear similar in vegetative ground cover to the lower portions of the Project Area that are not potential Douglasia idahoensis habitat due to dense herbaceous ground cover. Therefore, potential impacts to Douglasia idahoensis would be possible but would not be likely due to the small footprint impacts through potential Idaho primrose habitat and the requirement to survey areas prior to disturbance activity authorization. If identified, occupied habitat would be avoided to the maximum extent practicable.
Since Douglasia idahoensis often co-occurs with Lewisia sacajaweana at other locations, mitigation measures to protect Lewisia sacajaweana (including potential habitat and pollinator habitat) would also likely benefit any unknown Douglasia idahoensis plants..
5 Use of Maximum Extent Practicable (MEP) and Requirements under 36 CFR 228 The term “maximum extent practicable,” or MEP, is embodied as the basic performance standard in numerous State and federal regulations, including the Federal Endangered Species Act and Section 404 of the Federal Clean Water Act. The MEP standard does not necessarily involve the same criteria in each application; it is intended to address projects or actions on an individual basis considering each of their specific circumstances and purposes. Under the EPA guidelines, practicable is defined as: "available and capable of being done after taking into consideration cost, existing technology and logistics in light of overall project purposes (40 CFR 230.10(a)(2)).” The USFWS/NOAA HCP Handbook (Section 7.B.2) states that a conservation program may be evaluated against the MEP standard by: “weighing the benefits and costs of implementing additional mitigation, the amount of mitigation provided by other applicants in similar situations, and the abilities of that particular applicant." Avoidance of impacts to LESA is the objective where practicable. Where avoidance is not practicable (see next paragraph), then activity impacts to LESA plants will be minimized to the MEP. When impacts cannot be avoided, the botanist shall be required to document, through the checklist process, that the location of the activity and techniques used to minimize impacts were sufficient to NOT change the current effects determination disclosed in the Supplemental EA (i.e., “may impact individuals but is not likely to cause a trend toward federal listing or a loss in viability”. If the botanist determines that the effects determination would change, the Responsible Official will make a determination as to whether or not the new information or changed circumstances are within the scope and range of effects considered in the original analysis or a correction, supplement, or revision to an environmental document is necessary (FSH 1909.15, section 18.4). Thus, when a mitigation states that a activity will be “avoided” or “minimized” to the MEP, it will be interpreted within the framework of determinations as to whether the avoidance or minimization mitigation can be applied in a manner that will not “endanger or materially interfere with prospecting, mining, or processing operations or uses reasonably incident thereto (FSH 2809.15; 36 CFR 228.8; 30 U.S.C. § 601, et seq.) as documented in a Surface Use Evaluation and Determination (FSH 2809.15 (13)), or equivalent report.
Phacelia minutissima (least phacelia): No known locations of this species occur in the Project Area. Although it is highly unlikely that this species will be found (no known populations grow on the Forest), if present, Phacelia minutissima could be impacted by ground disturbance including road building and drill pad construction. Impacts would be expected to be negligible to low, due to the narrow nature of the footprint impacts and the requirement to survey areas prior to disturbance activity authorization. If identified, occupied habitat would be avoided to the maximum extent practicable.
Botrychium simplex (least moonwort): No known locations of this species occur in the Project Area or the surrounding 5th field HUC. Potential Botrychium simplex habitat exists along stream corridors, wet seeps, and potentially some moist pockets in the Project Area. No Botrychium species were discovered during field surveys, but due to the difficulty in surveying these plants, the presence of unknown populations cannot be dismissed. The likelihood of locating plants is reduced because of its diminutive size and the irregular appearance of the aboveground photosynthetic fronds. However, this species is not expected to occur in the driest upland portions of the Project Area.
Because the uplands within the Project Area are largely too dry to support Botrychium, the risk to potential habitat is greatly reduced. The likelihood of impacting an undocumented occurrence of Botrychium simplex is low. In addition, in order to meet Forest Plan standard MIST08, which requires that new structures, support facilities, and roads be located outside Riparian Conservation Areas (RCAs) unless no other alternative exists in order to meet the mineral exploration objectives (USDA Forest Service 2010), impacts within RCAs would be minimized. The predisturbance checklist process in Appendix B requires the proponent to examine other options outside RCAs before proposing disturbance within an RCA. Thus, because the likelihood of habitat disturbance for this species is low for the reasons stated above, it is unlikely that ground disturbance would impact any undocumented occurrence of least moonwort.
In light of the existing RCA mitigation requirements that were developed to ensure consistency with Forest Plan standard MIST08, the need to include this species in predisturbance survey requirements, similar to that required for bitterroot and other Sensitive species, was not deemed necessary.
Sedum leibergii (Leiberg Stonecrop): An abundance of rocky habitat exists within the Project Area, and some of it may be suitable for Sedum leibergii. While no Sedum leibergii has been found, the Project Area was not completely surveyed. Suitable habitat should overlap with that of Lewisia sacajaweana, so similar potential impacts would be expected. Mitigations developed for Lewisia sacajaweana should reduce risk to this stonecrop, if it were to occur. Given the proximity of the closest known population (Payette National Forest, Valley County), the likelihood of unknown populations in the Project Area is very low.
Botrychium crenulatum (scalloped moonwort): No known locations of this species exist in the Project Area or the surrounding 5th field HUC, but potential habitat exists along streams and other wet areas. Impacts to habitat and conclusions as to the likely effects to this species would be similar to those for Botrychium simplex.
Sanicula graveolens (Sierra sanicle): No known locations of this species exist on the Forest. The closest known Sierra sanicle population is found in the North Fork Payette watershed in Valley County. Habitat for this species covers a broad elevation and vegetative range, and
specific avoidance measures would be impracticable. However, because potential habitat is abundant across the modified Activity Area and in light of the small impact area of proposed activities, anticipated impacts to the species’ populations or its habitat would be negligible.
Cumulative Impacts The analysis area for cumulative impacts is the Project Area. Cumulative impacts are the impacts on the environment, resulting from the incremental impact of the action combined with other past, present, and reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions occurring over a period of time (40 CFR §1508.7).
Past and ongoing activities have been considered in describing the current conditions of the Project Area. Four identifiable actions, considered geographically concurrent with the Project Area and potentially contributing to cumulative impacts, are described as follows. A summary of impact determinations for rare plants is included in Table 4. (See USDA Forest Service 2015 for a discussion regarding cumulative impacts to Lewisia sacajaweana).
Past Logging Approximately 2,450 acres or 86% of the Project Area was logged between 1982 and 1993, which included salvage, seed tree, and shelterwood prescriptions.
Erosion and vegetative disturbance from past road building and other logging activities can potentially add cumulative impacts to the proposed actions. However, due to the amount of time that has passed since these logging operations, the ground surface has largely revegetated and stabilized. Past logging, despite temporary adverse impacts through physical destruction of plants, may have had short- and long-term beneficial impacts on rare plant species as dense forests were opened up, allowing more light to reach the ground surface. Compared to the acreages of past logging operations, the proposed project, under either Alternatives A or B, would result in substantially less ground disturbance and thus lower potential impacts on rare plants. Since removal of trees during logging operations may have in the short to long term benefitted rare plants, which are adapted to periodic disturbances through fires, the effects of past logging combined with the proposed impacts under Alternatives A or B would not be expected to result in cumulative impacts.
Past and Current Grazing The entire Project Area falls within the Boise Basin Sheep and Goat Allotment. The total acreage of the grazing allotment is approximately 253,000 acres, and is currently used by two 1,000-head bands of sheep from June through October annually.
Grazing and associated soil damage can potentially add cumulative impacts to the proposed actions. Grazing activities have the potential to remove or trample rare plants as the animals roam and feed.
Past and Current Mineral Exploration Between 1968 and 1982 mineral exploration activities in the area included geological mapping, geochemical surveys, geophysical surveys, and 26 exploration drill holes. During this time, AMAX developed a number of rough access roads. A segment from this network was incorporated into NFS road 397B, and approximately 4.7 miles remain as existing
unauthorized roads. A rough timber bridge was constructed on what is now NFS road 397B, where it crosses Grimes Creek; the bridge, which has been in very poor condition since 2005, was condemned by Forest Service engineers.
Approximately 290 acres of private lands occur in the Project Area. Since summer 2010, CuMoCo has been conducting exploration activities on the portion of its 2007 PoO that occurs on private lands. They intend to conduct exploration activities on up to 0.5 miles of new exploration roads on private lands. Though rare plant habitat information is unavailable for private lands, these current exploration activities might impact rare plants. The present mineral exploration on private lands is expected to have only minor potential additive impacts on rare plants.
Table 4. Summary of impact determinations for rare plants with potential or occupied habitat in the project area
Effect/Impact
Determination
Alt C (No
Action)
Effect/Impact
Determination
Alt A
(Proposed)
Effect/Impact
Determination
Alt B
(Reduced
Rds.)
USFWS Listed/Candidate
Pinus albicaulis – Whitebark pine No Impact MIIH MIIH
Intermountain Region USDA-FS Sensitive Species
Douglasia idahoensis Idaho primrose
NI MIIH MIIH
Lewisia sacajaweana Sacajawea’s bitterroot
NI MIIH MIIH
Phacelia minutissima Least Phacelia
NI MIIH MIIH
Boise National Forest Watch Species
Risk to
Populations
Risk to
Populations
Risk to
Populations
Botrychium crenulatum Scalloped moonwort
None Low Low
Botrychium simplex Least moonwort
None Low Low
Sedum leibergii Leiberg stonecrop
None Low Low
Sanicula graveolens Sierra sanicle
None Low Low
Note: NI = No impact to any populations, species or habitat. MIIH = May impact individuals, but will not likely contribute to a trend towards Federal listing or loss of viability to the populations or species.
Alternative B—Reduced Roads Alternative Direct, Indirect, and Cumulative Effects Under Alternative B, direct, indirect, and cumulative impacts to Sensitive and Forest Watch plant species would be expected to be similar to those described for Alternative A, though less likely and of a lower magnitude due to a 3.1-mile decrease in roads constructed.
Alternative C—No Action Direct, Indirect, and Cumulative Effects Under Alternative C, no road construction or additional exploratory drilling would be approved. Since no land disturbance activities would occur under Alternative C, direct, indirect, or cumulative impacts to Sensitive or Forest Watch plant species would not occur.
MITIGATION MEASURES Refer to the 2015 L0ewisia sacajaweana Addendum to the BE for the mitigation and monitoring measures concerning Lewisia sacajaweana.
Surveys will be conducted for the following Sensitive species: Idaho dwarf primrose (Douglasia idahoenisis), least phacelia (Phacelia minutissima) and whitebark pine (Pinus albicaulis) in suitable habitat during the appropriate time by qualified botanists prior to any ground disturbing activities (including road construction, road maintenance, drill pad construction, and drilling).
If individuals of Douglasia idahoensis, Phacelia minutissima, or Pinus albicaulis are located during surveys, occupied habitat shall not be impacted by Project-related activities (road construction, road maintenance, drill pad construction, and drilling).
FOREST PLAN CONSISTENCY The CuMo Exploratory Drilling Project Area is in Management Area 8 – Mores Creek. Acreage is primarily in Management Prescription Category (MPC) 5.1 (Restoration and Maintenance Emphasis within Forested Landscapes).
With mitigations in place, the proposed Project is consistent with management direction for Sensitive species and Botanical Resources. This includes the Forest level Standards and Guidelines found in the Boise National Forest LMP 2003, TEPC, III-8-9, 11-12, 15; Botanical Resources, III-32-34 (USDA 2010), and the Objectives and Standards for Botanical Resources within the Mores Creek MA (USDA Forest Service 2010, Botanical Resources, p. III-188). These objectives stress maintenance or restoration of Threatened, Endandered, Sensitive, Proposed, or Candidate plant populations and occupied habitat in order to contribute to the long-term viability of these species, and reduction in noxious weed populations that may threaten rare plant habitat.
DETERMINATION AND RATIONALE No Sensitive plants, except for Lewisia sacajaweana, are known to occur within the Project Area. While some potential habitat exists for the Sensitive species Douglasia idahoensis, Phacelia minutissima, and Pinus albicaulis, the likelihood of risk to any undocumented populations is low.
The determination for impacts is as follows:
• This project may impact Douglasia idahoensis (Idaho dwarf primrose), Phacelia minutissima (least phacelia), and Pinus albicaulis (whitebark pine) but would not likely contribute to a trend toward federal listing or cause a loss of viability to the population or species (MIIH). Likewise, no impacts to potential habitat for other Sensitive plant species would occur.
Rationale for this determination:
• The area of ground disturbance associated with proposed Project activities is relatively small, and potential habitat for Douglasia idahoensis is limited. Since Douglasia idahoensis often occurs with Lewisia sacajaweana , the mitigation measures for Lewisia sacajaweana would likely also provide protection for unknown Douglasia idahoensis plants that could potentially occur.
• The likelihood of Phacelia minutissima presence within the Project Area is very low, given the distance (~50 miles) to the nearest known population and the small amount of suitable habitat.
• While it is possible that Pinus albicaulis may be found at high elevations within the CuMo Project Area, it is unlikely since it has not been identified during previous survey efforts.
• If any Douglasia idahoenisis, Phacelia minutissima, or Pinus albicaulis individuals are located, they will be avoided by Project activities as per mitigation measures included herein.
This Project would have low-level potential for risks to population viability on the Forest Watch species Botrychium simplex, Sedum leibergii, Botrychium crenulatum, and Sanicula graveolens.
USDA Forest Service. 2010. Boise National Forest Land and Resource Management Plan, Vol. 1 and 2. Boise, ID: USDA Forest Service, Boise National Forest.
USDA Forest Service. 2011. Botanical Specialist Report and Biological Evaluation Covering Listed, Proposed, Candidate, Sensitive, Priority, and Forest Watch Plant Species for the CuMo Project. Boise, ID: USDA Forest Service, Boise National Forest.
USDA Forest Service. 2015. Lewisia sacajaweana Addendum to the Biological Evaluation of the Effects on Sensitive Plant Species for the CuMo Mine Exploration Project.
