Table S.1: Summary of Potential Environmental Effects and Mitigation Measures

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Table S.1: Summary of Potential Environmental Effects and Mitigation Measures
	PROPOSED ACTION	WEST PIT ALTERNATIVE	EAST PIT ALTERNATIVE	COMPLETE PIT BACKFILL ALTERNATIVE	NO ACTION ALTERNATIVE
Resource:	GEOLOGY AND MINERAL RESOURCES
Issue:	Slope stability and seismic effects
Measures Incorporated by Project Design or Regulation:	4.1.1-1: Heap leach pad and waste rock stockpile slopes shall be constructed at overall slopes no steeper than 2H:1V. 4.1.1-2: Mine pit slopes shall be constructed at overall slopes no steeper than 1H:1.2V (50 degrees) unless mining conditions and geotechnical factors demonstrate through engineering analysis that steeper slopes would be safe, and such steeper slopes shall be approved by the BLM. Slopes shall not be steeper than is safe considering actual rock strength and structural conditions encountered. Pit slope angles in the West Pit and East Pit shall be re-evaluated after one (1) year of mining of that pit. 4.1.1-3: Approximately 40-foot wide benches shall be constructed at approximately 80-foot high intervals on mine pit slopes to catch loose rocks. Approval shall be obtained from the BLM prior to construction of mine pit benches which differ substantially from these specifications. 4.1.1-4: To avoid any substantial slumping or slope failure of the heap and waste rock stockpile slopes, the recommendations of the slope stability analyses of these facilities shall be followed during the construction of these facilities. 4.1.1-5: Project structures subject to the Uniform Building Code shall be designed and constructed consistent with the standards of Seismic Zone 4.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	No substantial slumping or failure of the ore heap, waste rock stockpile, of pit slopes is anticipated. Buildings should not fail due to seismic shaking.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	No impact
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Issue:	Subsidence
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	No subsidence from ground water pumping is anticipated.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	No impact
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Issue:	Naturally occurring radioactive materials
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	No substantial increase in naturally occurring radioactive materials is anticipated	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	No impact
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Issue:	Loss of mineral potential
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Potential mineral resources may be lost through complete or partial backfilling of pits.	No mining of East Pit. Less backfilling of West Pit.	No mining of West Pit.	Complete backfilling of all pits.	None
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Resource:	SOIL RESOURCES
Issue:	Loss of soil resources
Measures Incorporated by Project Design or Regulation:	4.1.2-1: Surface disturbance shall be kept to the minimum that is required to construct and operate the project. 4.1.2-2: Soils shall be salvaged from all areas where sufficient soil development is noted in conformance with the approved Reclamation Plan. Soils shall be salvaged to the greatest depth practicable and placed in stockpiles clearly delineated with signs to assure the material is not mistaken as waste rock. Soil stockpiles shall be located away from washes and other areas prone to erosion and consolidated as appropriate to reduce disturbance to undisturbed areas within the Project mine and process area. Stockpiles shall be kept shallow and dry, if not to be used within one (1) year of initial placement, to protect seeds. 4.1.2-3: All mine facilities shall be designed and constructed with erosion control features engineered to meet the performance standards of 14 CCR 3706, including the control of runoff and protection of areas susceptible to erosion from surface flows. 4.1.2-4: A Storm Water Pollution Prevention Plan, incorporating the use of Best Management Practices for erosion control, shall be developed and implemented in accordance with the California Storm Water NPDES permit program.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Soils would be lost through direct disturbance and from erosion, either from precipitation falling directly within the Project mine and process area, or from flow events in the ephemeral washes.	Somewhat less disturbance and erosion potential than Proposed Action	Slightly less disturbance and erosion potential than Proposed Action	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Resource:	HYDROLOGY (SURFACE WATERS)
Issue:	Stream flow alterations
Measures Incorporated by Project Design or Regulation:	4.1.3.1-1: Major watercourses shall be diverted only to the extent necessary to protect Project facilities, and shall be diverted back into the same wash system after as short a diversion as practical. Permanent diversion channels shall be built to approximate the original drainage system in both gradient and channel geometry, and shall be engineered to adequately contain and deliver stream flows resulting from the 100-year/24-hour precipitation event. The diversion system shall also be designed to adequately contain and deliver stream flows predicted from the 500-year, 24-hour precipitation event. 4.1.3.1-5: Diversion channels shall be designed to prevent the abrupt diversion of flows from their natural courses, and shall provide sufficient natural protective materials at the points of diversions where necessary to protect the diversion works. All designs for the diversion channels shall be signed and stamped by an engineer registered to practice in California and submitted to the Imperial County Public Works Department for approval prior to commencement of construction.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	The diversion of the five (5) ephemeral drainage channels within the Project mine and process area would not result in substantial alterations of the flow in downstream reaches and would not overflow during extraordinary flow events.	Only three (3) drainage channels would be diverted, but otherwise same as Proposed Action	Only three (3) drainage channels would be diverted, but otherwise same as Proposed Action	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Issue:	Stream sediment and quality degradation
Measures Incorporated by Project Design or Regulation:	4.1.3.1-2: All chemicals shall be stored in conformance with applicable local, state and federal regulations. All non-mining wastes shall be stored in secondary containment areas, as required, and disposed of off-site in an approved landfill. Regulated wastes shall be recycled or disposed of in conformance with all applicable local, state and federal laws and regulations, and in a manner approved by the responsible regulatory agencies. 4.1.3.1-3: Major maintenance of equipment shall be conducted within the concrete-paved and bermed areas of the maintenance yard to the extent possible to minimize accidental discharges of waste lubricants and other materials to the ground. 4.1.3.1-4: Each phase of the heap leach pad system (heap, pad, ponds, etc.) shall be designed to provide for 100-percent containment of the precipitation from the maximum probable one (1)-hour storm event occurring simultaneously with a 24-hour power outage while still maintaining a two-foot freeboard in the process and overflow ponds, and shall be consistent with the requirements of the CRWQCB .	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Erosion of Project facilities would be minimal and not result in sedimentation of washes; and spills or leaks of Project chemicals would be minimized and contained, and the potential for the process facility ponds to fail or overtop is low, so that surface water degradation would be minimal.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Issue:	Floodplain encroachment
Measures Incorporated by Project Design or Regulation:	4.1.3.1-6: Project facilities shall not be constructed within special flood hazard zones (Zone A) as noted on Federal Emergency Management Agency (FEMA) National Flood Insurance Program Flood Insurance Rate Map (FIRM) for Imperial County, California (Unincorporated Areas), Panel 700 of 1175, Community-Panel Number 060065 0700 B, Effective Date: March 15, 1984, except as may be authorized by a Development Permit approved by the Imperial County Flood Administrator pursuant to Division 4 of Title 7 of the codified ordinances of Imperial County and, if applicable, restrictions contained in the approvals of the appropriate federal authorizing agencies.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Project facilities would not be sited or constructed in identified floodplain areas without the required permit.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Issue:	Ground water inflows
Measures Incorporated by Project Design or Regulation:	None (see also measures listed under Biological Resources)	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	The potential for formation of a pit lake is eliminated, and surface water quantity and quality would not be adversely affected by any ground water inflows into the open pit(s) or waste rock backfilled into the pit(s).	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Issue:	"Waters of the United States"
Measures Incorporated by Project Design or Regulation:	4.1.3.1-7: Applicant shall acquire and comply with the necessary approvals from the U.S. Army Corps of Engineers for all jurisdiction "waters of the United States" under Section 404 of the Clean Water Act which may be dredged or filled through Project actions.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Some jurisdictional "waters of the United States" located in the ephemeral stream channels would be dredged or filled by the Project.	29 percent fewer acres than the Proposed Action would be dredged or filled	17 percent fewer acres than the Proposed Action would be dredged or filled	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Resource:	HYDROLOGY (GROUND WATERS)
Issue:	Ground water production
Measures Incorporated by Project Design or Regulation:	4.1.3.2-1: To prevent excessive drawdown or possible damage to the well or pumping system, ground water production from well PW-1 shall be limited to a maximum average of 550 gpm unless a higher pumping rate, supported by reasonable proof of increased well efficiency, is approved by the ICPWD. The maximum average production rate from each additional production well drilled shall be limited to that rate which prevents excessive drawdown or possible damage to the well or pumping system. 4.1.3.2-2: The total annual ground water production rate shall not exceed 1,200 afy. 4.1.3.2-6: Applicant shall obtain approval from the ICPWD of a "Ground Water Management Ordinance" permit prior to drilling any ground water production well intended for continued use. Production of ground water from the Project ground water well field shall be monitored and reported to the ICPWD consistent with the requirements of this permit.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Individual well and total ground water well field production rates will not produce substantial drawdowns in other existing wells and will not excessively draw down or damage the aquifer.	A maximum of two (2) wells would be drilled, and less than one-half of the water would be produced, but otherwise same as Proposed Action	A maximum of three (3) wells would be drilled, and approximately two-thirds of the water would be produced, but otherwise same as Proposed Action	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Issue:	Ground water quality
Measures Incorporated by Project Design or Regulation:	4.1.3.2-3: Ground water production and monitoring wells shall be plugged and abandoned in conformance with applicable regulatory requirements, including 14 CCR 3713(a). 4.1.3.2-4: The heap leach pad shall be designed, constructed and operated in conformance with the specifications, requirements and prohibitions of Waste Discharge Requirements issued by the CRWQCB . 4.1.3.2-5: The heap leach pad shall be monitored in conformance with the requirements of the Monitoring and Reporting Program issued by the CRWQCB . This would include collection of groundwater quality baseline data prior to mine development.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Spills or leaks of Project chemicals would be minimized and contained; the potential for the process facility ponds or leach pad liner to leak is low; and rain water moving through waste rock stockpiles would not leach substantial metals; so that the potential for ground water degradation would be minimal.	Somewhat less than Proposed Action	Slightly less than Proposed Action	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Issue:	Pit water quality
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	No impacts to ground water quality are expected to occur from the complete or partial backfilling of any of the pits.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Resource:	AIR RESOURCES
Issue:	Compliance with ambient air quality standards
Measures Incorporated by Project Design or Regulation:	4.1.4-1: Chemical dust suppressant treatments, in combination with water sprays, shall be applied to the haul and maintenance roads within the Project mine and process area to minimize the generation of fugitive PM10. Only chemical dust suppressants acceptable to all appropriate agencies shall be applied, and the application rates and frequencies, for both the dust suppressant and water, shall be consistent with the guidance of the manufacturer to achieve optimal suppression of dust. Dust suppressant and/or water shall be applied no less than twice per day on days without precipitation unless road surface moisture is documented as sufficient to achieve maximum suppression of fugitive dust emissions without the additional dust suppressant or water. 4.1.4-2: Project employees, contractors, and visitors shall be advised of the need to adhere to speed limits to minimize the generation of fugitive dust. Applicant shall develop and implement appropriate measures to strengthen compliance with posted speed limits to prevent the generation of fugitive dust. 4.1.4-3: Shrouding of the lime discharge to the ore trucks, or equivalent RACM for these fugitive PM10 emissions, shall be implemented and maintained. 4.1.4-4: Water sprays or dust suppressants (chemical treatments acceptable to all appropriate agencies) shall be applied to Indian Pass Road from its intersection with Ogilby Road to the boundary of the Project mine and process area with sufficient frequency to minimize the emissions of fugitive PM10 from Project traffic on Indian Pass Road. 4.1.4-5: All disturbed surfaces no longer needed for project activities shall be reclaimed as soon as practical to minimize fugitive PM10 emissions from wind erosion. 4.1.4-6: All permits required by the ICAPCD shall be obtained, and all operations conducted in compliance with the conditions of these permits. 4.1.4-7: All fuels used at the Project shall conform to the CARB low-sulfur requirements in order to minimize SOx emissions from Project-related vehicular activities.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Project emissions of NOx, SOx and CO from mobile combustion sources and PM10 from fugitive emission sources would result in maximum ambient concentrations of these pollutants below the applicable ambient air quality standards, although maximum ambient concentrations of NOx and PM10 would be close to the applicable ambient air quality standards with the addition of background ambient concentrations; the Project would contribute to exceedences of the 24-hour CAAQS for PM10 which may continue to occur in the future during periods of high wind.	Same as Proposed Action, although project emissions would end substantially sooner	Same as Proposed Action, although project emissions would end somewhat sooner	Same as Proposed Action, although highest project emission rates would continue longer	None
Level of Significance of Resulting Impact:	Cumulatively significant for PM10, Not significant otherwise	Cumulatively significant for PM10, Not significant otherwise	Cumulatively significant for PM10, Not significant otherwise	Cumulatively significant for PM10, Not significant otherwise	Cumulatively significant for PM10
Mitigation Measures:	4.1.4-9: Applicant shall, in consultation with the ICAPCD, establish and maintain one (1) meteorological monitoring station (for wind speed and wind direction) and two (2) PM10 monitoring stations (6-day high volume samplers) to monitor project the ambient concentrations of PM10 which may be generated by Project activities. It shall be the intent of the two (2) PM10 monitors to be located in generally an upwind and downwind arrangement and operated simultaneously to provide information on the Project's effects on ambient PM10 concentrations. Should the monitoring show that Project operations may be contributing to a significant increase in ambient PM10 concentrations, then the Applicant shall review its procedures for reducing PM10 emissions and recommend to the ICAPCD methods which could be applied to reduce these emissions sufficiently to eliminate the significant increase.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Cumulatively significant for PM10, Not significant otherwise	Cumulatively significant for PM10, Not significant otherwise	Cumulatively significant for PM10, Not significant otherwise	Cumulatively significant for PM10, Not significant otherwise	Cumulatively significant for PM10
Issue:	Other air quality related health concerns
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Fugitive dust emissions from initial disturbance would not result in substantial emissions of the spores which cause "valley fever."	Somewhat less than Proposed Action	Slightly less than Proposed Action	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	4.1.4-8: Appropriate measures, such as water sprays, dust suppressants (chemical treatments acceptable to all appropriate agencies), or reduced operating speeds, shall be applied to all activities which disturb the top foot of soil in any areas during construction and reclamation activities to minimize emissions of fugitive PM10 which may contain Coccidiodes immitis spores. Project employees, contractors, and visitors shall be advised to use appropriate precautions regarding the inhalation of dust while in the Project area during the initial construction/reclamation phases to minimize exposure to Coccidiodes immitis spores.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Resource:	BIOLOGICAL RESOURCES
Issue:	Reclamation of vegetation and plant habitat
Measures Incorporated by Project Design or Regulation:	4.1.5-16: Upon completion of mining activities, Applicant shall remove all equipment and materials from the Project area. Unless explicitly directed otherwise by the BLM (in consultation with the CDFG), all diversion channel lining materials and rip rap shall be removed from the diversion channels and any necessary reclamation completed by the Applicant, consistent with the approved Reclamation Plan. 4.1.5-17: The Project Reclamation Plan shall include the collection of both fairy duster seeds and winged cryptantha seeds and distribution of the collected seeds of both species within appropriate microhabitats within the Project mine and process area. During Project operations, the Applicant shall experiment with the seeds (and transplants if reseeding is not successful), of both species to assure plant success and survival. Recovery of these two (2) species shall be considered successful when species density meets or exceeds the criterion set in the Approved Reclamation Plan. 4.1.5-18: Applicant shall stockpile available soil from the wash channels to be disturbed within the Project mine and process area and store the soil for subsequent use during reclamation activities. Soil stockpiles shall be located away from washes and other areas prone to erosion and consolidated as appropriate to reduce disturbance to undisturbed areas within the Project mine and process area. Stockpiles shall be kept shallow and dry, if not to be used within one (1) year of initial placement, to protect seeds. 4.1.5-19: Applicant shall salvage specimens of selected plant species from the Project mine and process area prior to construction to be utilized during Project reclamation, habitat enhancement activities, or other reclamation needs. Plant species may include cactus, ocotillo, ironwood, palo verde, or other appropriate species identified by the BLM. 4.1.5-20: Applicant shall implement weed control measures such that all introduced plants (e.g., salt cedar (tamarisk species), mustard, and other noxious weeds) would not become established within the Project area. Manual or mechanical means of control shall be the preferred methods employed. Use of other methods (e.g., herbicides) shall require approval by the BLM. The weed control measures shall be implemented within six (6) months of when noxious weeds are visually identified within the Project area and shall continue over the life of the Project. Tamarisk species shall be actively controlled throughout the life of the Project by eradication of any seedlings or growth observed. A portion of the reclamation bond in an amount determined appropriate by the BLM and Imperial County shall be retained to fund an eradication program to eliminate factor(s) conducive to tamarisk growth (e.g., moist areas) if tamarisk is determined to be a continuing problem after the completion of reclamation. 4.1.5-21: Applicant shall implement the revegetation program contained in the Project Reclamation Plan approved by Imperial County and the BLM. The revegetation program shall include a test plot program, surface contouring and shaping, salvage and distribution of stockpiled soils, collection of a seedbank of seeds from within and in the vicinity of the Project area, preparation of seedbeds, seeding with approved mixtures of native plant species endemic to the area, planting of the plants salvaged from the area prior to mine construction, monitoring for invasion of noxious weeds or salt cedar, and vegetation success monitoring. The standards for revegetation success shall be specific to each vegetation type and based on reasonably achievable results that shall provide a plant cover and density sufficient to support long-term revegetation. Final bond release shall occur when the vegetation success criteria set forth in the Reclamation Plan have been met and the reestablishment of vegetation is confirmed. 4.1.5-22: Applicant shall integrate the revegetation program activities with other stabilization and reclamation activities required by the approved Reclamation Plan. 4.1.5-23: Access roads which are created, or any other areas which are disturbed, for the construction of the transmission line, pipeline, and well field shall be reclaimed where they are not needed for ongoing maintenance. Reclamation methods shall include regrading, surface preparation, and revegetation either through seeding or natural processes. 4.1.5-24: To compensate for those lands not reclaimed within the East Pit, Applicant shall perform reclamation activities on one or more off-site locations on land in the vicinity of the Project acceptable to Applicant, and the BLM, as appropriate, to reclaim habitat which has been adversely impacted by previous actions unrelated to the Project. 4.1.5-25: Applicant shall repair any detected leak in the water pipeline along Indian Pass Road immediately in order to prevent tamarisk invasion and eliminate an attractive nuisance to wildlife.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Substantial vegetation and plant habitat would be disturbed, but concurrent and final reclamation would revegetate and reestablish plant habitat over all of the disturbed areas except the slopes of the open East Pit.	Somewhat less disturbance than Proposed Action	Slightly less disturbance than Proposed Action	Same disturbance as Proposed Action	None
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Other Measures:	4.1.5-51: A Revegetation and Monitoring Review Committee shall be formed to serve in an advisory capacity to the BLM and Imperial County. The committee shall review the annual vegetation monitoring reports filed by the Applicant for the purpose of interpreting the information contained in the reports, advising the Applicant of actions it might take to improve the success of its revegetation efforts, and advising the BLM and Imperial County as to adjustments which should be made to the revegetation success standards. The composition of the committee shall be proposed by the Applicant and approved by the BLM and Imperial County.	None	None	None	None
Issue:	Disturbance to microphyll woodland habitat
Measures Incorporated by Project Design or Regulation:	4.1.5-7: Applicant shall construct a fence, no less than four (4) feet in height with 3-strands of smooth wire, or equivalent, around the approximately 40-acre south-central portion of the central wash within the Project mine and process area which is not intended to be disturbed by Project operations to prevent accidental surface disturbance of the microphyll woodland habitat in this internal area during mine construction and operation. 4.1.5-8: Applicant shall provide periodic slug irrigation to enhance the establishment of ironwood and deer browse vegetation within the surface drainage identified by Mitigation Measure 4.1.5-7 to enhance the quality of habitat and provide established deer browse which would be immediately available at the end of the active life of the mine. Vegetation selected for enhanced deer browse establishment shall be comprised of species known to occur in the Project area. The irrigation shall be reduced and then ceased once the vegetation is established. The composition of the seed mix and the design of the vegetation enhancement measures shall be submitted to the CDFG for approval prior to implementation. 4.1.5-10: Applicant shall provide periodic slug irrigation to enhance the establishment of ironwood and deer browse vegetation along the western slopes and banks of the approximately 3,000-foot section of the existing ephemeral stream channel immediately adjacent to, but outside of, the east-southeast boundary of the Project mine and process area. Vegetation selected for enhanced deer browse establishment shall be comprised of species known to occur in the Project area. Supplemental watering shall only be conducted for the first few years to allow the plants to become established. Water shall be reduced over a period of time to enable the plants to acclimate to natural moisture conditions. The composition of the seed mix and the design of the vegetation enhancement measures shall be submitted to and approved by the CDFG prior to implementation. 4.1.5-11: Applicant shall conduct annual transect surveys in the spring season of the ephemeral washes which flow out of the Project mine and process area, the principal washes which flow into the Project mine and process area upstream of the Project mine and process area to serve as a control, and the undisturbed ephemeral washes within the Project mine and process area, for the purpose of determining if Project construction and/or operations are having an indirect adverse effect on microphyll woodland habitat not directly effected by surface disturbance. The surveys shall document the diversity, density, and cover of the vegetation directly associated with the washes, and shall include observations regarding the general "health" of the vegetation. The surveys shall also document any observations regarding sediment transport processes within the washes any incidental sightings of deer fawn, bighorn sheep, bobcat, kit fox, mountain lion, or other species specified by the BLM. An annual report of the results of the surveys shall be prepared and submitted to the BLM and CDFG in a form acceptable to the BLM. If, as a result of these surveys, microphyll woodland habitat downstream of the Project mine and process area are determined to be adversely impacted by the Project, appropriate additional mitigation measures may be required by the BLM and shall be implemented by the Applicant. BLM may require the Applicant to acquire title to off-site private lands with comparable microphyll woodland habitat, in a location acceptable to the BLM and the Applicant, to compensate at a 3:1 ratio for adverse impacts to microphyll woodland habitat not otherwise compensated for which cannot be mitigated through application of these additional mitigation measures. 4.1.5-12: Applicant shall construct all stream channel diversions to divert flows back into the same major wash system and ensure the continuing flow of an equivalent pre- and post-Project quantity of water through the major drainages to preserve the downstream microphyll woodland habitat within the drainages 4.1.5-13: Applicant shall implement the Project Reclamation Plan in conformance with the requirements of the BLM and Imperial County. The Reclamation Plan shall include a program for revegetation of the permanent diversion channels, including the planting of seedlings of young ironwood and palo verde at a density approximating that of the displaced washes and seeding of the pre-Project wash habitat. The transplanted seedlings shall be protected from browsing or trampling by wire cages for the first two (2) years and from excessive sun by shade material, if necessary, or native nurse plants, if available and necessary, to facilitate transplant success. Microphyll woodland vegetation within the permanent diversion channels shall be established during early mining operations and managed and monitored throughout the life of the Project. Applicant shall conduct annual transect surveys in the spring season of the diversion channels for the purpose of determining revegetation success. The surveys shall document the diversity, density, and cover of the vegetation directly associated with the washes, and shall include observations regarding the general "health" of the vegetation. An annual report of the transect surveys shall be prepared and submitted to the BLM, Imperial County and CDFG in a form acceptable to the BLM and Imperial County. Should the surveys indicate that the revegetation of the diversion channels may not meet the standards required by the approved Reclamation Plan, the BLM and Imperial County may require appropriate additional revegetation measures to be implemented by the Applicant. 4.1.5-15: Project actions would require the realignment of sections of washes. Applicant shall develop a specific plan for approval of the BLM that ensures maintenance of intermittent flood water flow down these realigned wash channels into unmodified drainage boundaries outside of the Project in order to preserve vegetation and wildlife habitat. Design of these sections of realigned wash shall also include appropriate dimensions and slopes to accommodate continued use by wildlife during mining operations and to facilitate revegetation. A specific plan shall be prepared by Applicant and submitted to the ICPWD and BLM for review, and approval of the BLM, prior to the onset of any activities that would result in disturbance to these drainages. Plan design shall include the vegetation of channel diversions with native species that include ironwood and palo verde in order to maintain continuity of washes and enhance wildlife habitat, in conformance with the approved Reclamation Plan. Unless explicitly directed otherwise by the BLM (in consultation with the CDFG), all diversion channel lining materials and rip rap shall be removed from the diversion channels. 4.1.5-26: Applicant shall enter into a Stream Alteration Agreement with the California Department of Fish and Game (CDFG) as required pursuant to California Fish and Game Code Section 1603 which shall contain those measures which CDFG and Applicant agree may be necessary, or appropriate, to mitigate, and compensate for, the impacts of the Project on the stream channels and associated microphyll woodland habitat and wildlife. The July 11, 1997 draft of the Stream Alteration Agreement for the Imperial Project includes the following substantive requirements, which are subject to modification until agreed to by both parties: (1) Applicant shall acquire title to off-site private lands with comparable microphyll woodland habitat, in a location acceptable to the CDFG and the Applicant, to compensate at a 3:1 ratio for microphyll woodland directly impacted as a result of the Project. Ownership of the acquired land shall be transferred to the CDFG for long term habitat management. (2) Applicant shall construct and/or maintain over the life of the Project three (3) big game and/or small game guzzlers in a design and location acceptable to the CDFG, Applicant, and BLM, as appropriate, to enhance the habitat for deer and other wildlife. One (1) additional guzzler shall be installed and maintained on the acquired off-site mitigation lands. The guzzlers shall be designed and constructed in a manner which allows desert tortoise to readily exit the guzzlers. (3) Approximately 40 acres of habitat within the Central Wash area shall be fenced to prevent human intrusion. The fencing shall be 4-strand smooth wire to allow wildlife movement and the bottom shall be fenced for the exclusion of tortoises. (4) Surrounding microphyll woodlands shall be enhanced through various methods (e.g. irrigation, replanting with native species). (5) In those Project areas where nesting birds may occur, the Operator either shall not remove potential nesting riparian (sic) vegetation from March 15 through July 30, or shall survey all potential nesting riparian (sic) vegetation within the Project area for active bird nests. If an active bird nest is located, the nest site shall be flagged or staked a minimum of five (5) yards in all directions, and this flagged zone shall not be disturbed until the nest becomes inactive, unless otherwise directed by the CDFG. 4.1.5-28: Project actions may require either an individual dredge and fill permit (404 permit) from the U.S. Army Corps of Engineers (ACOE) or operate under one or more Nationwide Permits. Applicant shall obtain the appropriate authorization from the ACOE prior to the onset of any actions that would disturb drainages within the Project area. 4.1.5-29: The California Regional Water Quality Control Board, Colorado River Basin Region (CRWQCB ) shall be notified by the Applicant of Project actions, and Applicant shall comply with CRWQCB requirements for obtaining Waste Discharge Requirements and Certification under Section 401 of the Clean Water Act for proposed discharges to land and a general Storm Water Permit.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Approximately 90 acres of microphyll woodland habitat would be would be disturbed, but the carrying capacity of adjacent habitat would be enhanced, concurrent and final reclamation would start to reestablish about one-half of this disturbed habitat within the area of the Proposed Action, and three times this disturbed amount would be purchased and protected off-site.	Same as Proposed Action, although only 52 acres of microphyll woodland habitat would be disturbed	Same as Proposed Action, although only 62 acres of microphyll woodland habitat would be disturbed	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Issue:	Disturbance to wildlife and wildlife habitat
Measures Incorporated by Project Design or Regulation:	4.1.5-1: Applicant shall construct a fence around the entire Project mine and process area. The fence shall be constructed no less than four (4) feet in height with 3-strands of smooth wire, or equivalent. That portion of the perimeter fence constructed along the western boundary of the Project mine and process area, including all of the fenceline adjacent to Indian Pass Road (see Figure 2.2), shall be a chain-link fence, no less than six (6) feet in height, to restrict public access to the Project mine and process area. The entire perimeter fence shall include desert tortoise exclusion fencing, in conformance with responsible agency requirements, to inhibit tortoise access to Project facilities (see also Mitigation Measure 4.1.5-40). Applicant shall construct a chain-link fence, no less than six (6) feet in height, with one (1) foot of barbed wire at the top, around the ore leach pad, process facilities, and fresh water pond to further restrict wildlife from accessing these facilities. Applicant shall routinely inspect and repair the fences, as necessary. Applicant shall document any deer or other wildlife mortalities observed within the Project mine and process area, shall monthly report such mortalities to the BLM and the CDFG, and shall work with the BLM and CDFG to implement additional or amended measures to reduce the mortalities. A field contact representative (FCR) shall be responsible for maintaining the records of perimeter fence inspections and repair, and shall have authority to direct the repair of damaged or destroyed fences. The FCR may be a project manager, company environmental coordinator, contract biologist, or other person identified as responsible by the Applicant. 4.1.5-2: Applicant shall prohibit cross-country use of vehicles and equipment except within those portions of the Project mine and process area subject to surface disturbance.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Measures Incorporated by Project Design or Regulation:	4.1.5-3: Applicant shall cover the pregnant and barren solution ponds with either small-mesh nets; a solid, 40-mil, HDPE/polypropylene cover; floating plastic balls; or equivalent cover acceptable to the BLM to keep wildlife out of the ponds. Applicant shall maintain the cover over the life of the Project. Applicant shall keep records of all wildlife kills which may be associated with the use of cyanide by the project, including all dead wildlife found in or adjacent to the ponds or heap. Individual threatened and endangered species found dead on the Project mine and process area shall be sent for necropsies. Observations of wildlife killed in the ponds or on the heap shall be reported to the BLM, CDFG, and the U.S. Fish and Wildlife Service (USFWS) monthly for evaluation and, if determined necessary, for possible imposition of additional mitigation requirements. 4.1.5-4: Applicant shall advise Project employees, contractors, and visitors of the need to adhere to speed limits and to avoid any animals, including the desert tortoise, flat-tailed horned lizard, and deer which may be encountered on or crossing the road to and from the Project area. Applicant shall also require Project employees, contractors, and visitors to report all incidences of wildlife injury or mortality resulting from Project-related vehicle traffic on roads used to access the Project to the FCR, who shall monthly report these incidences to the BLM and the CDFG. Applicant shall participate in agency efforts to reduce mortality of wildlife on the roads used as access to the Project when so requested by the BLM. 4.1.5-5: Prior to completion of mining, Applicant shall conduct an assessment of the potential for a pit lake to form in the East Pit. If the assessment indicates a reasonable potential for a pit lake to form, Applicant shall backfill the East Pit to an elevation higher than the level of any pit lake which may be predicted to form from the inflow of ground water and, thereby, prevent the creation of an attractive nuisance for wildlife. The findings of the pit lake assessment shall be completed and submitted for approval by the BLM prior to the completion of mining activities. Applicant shall monitor open pit areas monthly during the duration of post-mining reclamation for any evidence of the formation of a pit lake. The results of this monitoring shall be reported monthly to the BLM. Should the BLM determine that the monitoring indicates that a pit lake is forming or may form, the Applicant may be required to conduct an additional study or place additional backfill material into the bottom of the East Pit. 4.1.5-6: Before removal of the perimeter fence at the end of the active life of the Project, Applicant shall regrade haul roads within the open pit such that wildlife or humans may still use them to exit the residual open pit should they pass the barricade around the rim. 4.1.5-9: Applicant shall construct and maintain during the life of the Project three (3) big game guzzlers in a design and location acceptable to the BLM and the CDFG in the general vicinity of the Project mine and process area to provide for more intensive use of the existing habitat by deer and other wildlife. Within one (1) year of approval of the ROD, the Applicant shall have either: provided sufficient funds to a third party (acceptable to BLM and CDFG) which shall construct, own, and operate the guzzler; or completed construction of the guzzler. Applicant or the acceptable third party shall obtain the required permits from the BLM prior to guzzler construction. The guzzler shall remain after reclamation. 4.1.5-14 Applicant shall construct and maintain as a part of final reclamation, one or more big game and/or small game guzzlers within the Project mine and process area in a design and location acceptable to the BLM and the CDFG to enhance the area as habitat for deer and other wildlife. Final Project reclamation bond(s) shall not be released until either: the Applicant has provided sufficient funds to a third party (acceptable to BLM and CDFG) which shall construct, own, and operate the guzzler; or the Applicant has completed construction of the guzzler. Applicant or the acceptable third party shall obtain the required permit from the BLM prior to guzzler construction. The guzzler shall remain after reclamation. The guzzler shall be designed and constructed in a manner which allows desert tortoise to readily exit the guzzler.
Resulting Impact:	Wildlife habitat would be temporarily eliminated over all disturbed areas and wildlife movements altered, but the carrying capacity of adjacent habitat would be enhanced, concurrent and final reclamation would start to reestablish this habitat, and an amount equal this disturbed acreage would be purchased and protected off-site. Should mining be suspended or terminated prior to either partial or complete backfilling of the West Pit and Singer Pit, wildlife could be injured or killed by falling into the pit or being attracted by a pit lake.	Same as Proposed Action, although disturbed acres would be reduced by 38 percent	Same as Proposed Action, except that disturbed acres would be reduced by 19 percent	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	4.1.5-48: Should mining be terminated prior to backfilling of the West Pit above the ground water level, Applicant shall conduct an assessment of the probability of the formation of a pit lake after mining. Any evaluation of the potential for the formation of a pit lake in an open pit shall consider the quantity of surface flow runon and direct precipitation. If the assessment reasonably indicates that ground water encountered in the West Pit may enter the pit in sufficient quantity, considering evaporation, to create a pit lake, the Applicant shall place sufficient backfill into the open portion of the West Pit to raise the floor of the pit to a level higher than the level of any pit lake which the study indicates may form. 4.1.5-49: Any pit left open following the completion of mining shall be left in a condition which minimizes the potential for, and quantity of, water which may enter the pit through surface water runon. In addition, the bottom of any pit left open after the completion of mining shall be composed of a layer of loose rubble to minimize the potential for the formation of standing water in the bottom of the pit from either precipitation or surface water runon. 4.1.5-50: Before removal of the perimeter fence, Applicant shall regrade haul roads within the open pit(s) such that wildlife or humans may still use them to exit the residual open pit(s).	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Other Measures:	4.1.5-52: Chuckwallas shall be moved away from any threats (approximately 100 meters outside the perimeter fence) during construction activity and if found within the Project mine and process area during mining operations. 4.1.5-53: To prevent the inadvertent electrocution of raptors, unless otherwise agreed to by the authorized officer in writing, transmission and distribution lines shall be constructed in accordance with standards outlined in the publication "Suggested Practices for Raptor Protection on Power Lines" (Raptor Research Foundation, Inc., 1996). The right-of-way holder shall assume the burden and expense of proving that pole designs not shown in this publication are "raptor safe." Such proof shall be provided by a raptor expert approved by the authorized officer. The BLM reserves the right to require modifications or additions to all power line structures placed on these rights-of-way should they be necessary to ensure the safety of large perching birds. Such modifications and/or additions shall be made by the holder without liability or expense to the United States. 4.1.5-54: Trash and food items shall be contained in closed containers to reduce attractiveness to opportunistic predators such as ravens, coyotes, and kit foxes. 4.1.5-55: Recreational firearms and pet dogs shall be prohibited from the Project mine and process area. 4.1.5-56: Applicant shall contact local animal control agents to remove feral dogs that are observed within the Project area.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Issue:	Impacts to listed species
Measures Incorporated by Project Design or Regulation:	4.1.5-27: Applicant shall comply with all of the terms and conditions of the Biological Opinion prepared for the Project by the U.S. Fish and Wildlife Service in response to the BLM request for formal consultation pursuant to Section 7 of the Endangered Species Act of 1973, as amended.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	The Project would result in the "take" of the federal- and state- listed desert tortoise.	Somewhat less than the Proposed Action	Slightly less than the Proposed Action	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	4.1.5-30: Applicant shall designate a field contact representative (FCR) who shall be responsible for overseeing compliance with protective stipulations for listed species. The FCR shall have authority to halt all activities that are in violation of the stipulations. The FCR shall have a copy of all appropriate stipulations when work is being conducted within the Project area. The FCR may be a project manager, company environmental coordinator, contract biologist, or other person identified as responsible by the Applicant. Applicant shall provide the name and contact information of the FCR to the BLM and applicable responsible agencies prior to construction. 4.1.5-31: During the life of all Project activities, stockpiling of equipment and vehicles shall utilize only those portions of the Project area that would be subject to permanent disturbance. Temporary or inadvertent disturbance to remaining portions of the area should be minimized by: staking, "flagging," or otherwise clearly marking the boundaries of the alignment; notifying employees of the specific areas, boundaries of the areas, and the need to avoid disturbance to remaining areas; and posting signs or erecting temporary fencing at access points to limit access to authorized vehicles and equipment only. All employees shall be instructed that their activities shall be confined to locations within flagged or otherwise marked areas. The area of disturbance shall be confined to the smallest practical area, considering extent and location of ore bodies, topography, placement of facilities and access roads, locations of sensitive species , public health and safety, and other limiting factors. To the extent practical, previously disturbed areas within the Project mine and process area shall be used for the placement of equipment, work staging sites, or parking of vehicles. 4.1.5-32: Open pipeline trenches, test holes, or test trenches shall be regularly inspected by the FCR, or qualified biologist acceptable to the BLM, a minimum of three (3) times per day. During excavation of trenches or holes, escape ramps consisting of loose earth deposited in the test hole or trench shall be placed to facilitate the escape of any wildlife species that may inadvertently become entrapped. Any animals discovered shall either be allowed to escape before activities resume or carefully removed from the pit or trench and allowed to escape. A final inspection of the open trench segment or hole shall also be made by the FCR, or qualified biologist acceptable to the BLM, immediately prior to backfilling. Arrangements shall be made prior to the onset of maintenance or construction to ensure that listed wildlife species can be removed from the trench without violating any requirements of the federal or California Occupational Safety and Health Administration. All test holes shall be immediately capped or abandoned upon completion of drilling to prevent access of wildlife. 4.1.5-33: Toxic materials contained on the Project area shall be stored and used in a manner that prevents harm to desert tortoises and other wildlife species. Methods of containment shall be approved by the BLM. 4.1.5-34: Nets or other suitable coverings shall be placed over all ponds containing toxic solutions to prevent contact by area wildlife species, including bats. These coverings shall be regularly inspected and maintained by Applicant for the duration of the Project. Methods of cover, inspection, and maintenance shall be approved by the BLM. 4.1.5-35: Project employees involved with regular activities shall be required to take a threatened and endangered species education program which shall include a discussion of both endangered and threatened species and species that are not endangered or threatened. The program shall include information on the biology of listed, sensitive and unlisted species as well such as the desert tortoise, flat-tailed horned lizard, mule deer, big horn sheep, and bats and their occurrence in the Project area. The discussion shall include information on the measures being implemented for the protection of these species and their habitats during Project activities and means by which individual employees can facilitate this process. A program approved by BLM shall be employed and taught by a qualified individual acceptable to the BLM. Wallet-size cards signifying completion of training shall be issued to employees. All employees shall participate in the education program prior to commencing Project activities. New employees shall receive formal approved training prior to working on-site. The program shall typically last from between one and two hours and shall cover the following topics at a minimum: · Distribution in general and in the Project area; · General behavior and ecology; · Sensitivity to human activities; · Legal protection; · Penalties for violation of State and federal laws; · Reporting requirements; and · Project mitigation measures. 4.1.5-36: Incidences of observations of desert tortoises and their sign during activities shall be conveyed to the FCR during all Project activities. Employees shall be notified that they are not authorized to handle or otherwise move any desert tortoises encountered. 4.1.5-37: Tortoises commonly seek shade during the hot portions of the day. During mine project activities, employees shall be required to check under equipment and vehicles prior to moving such. If tortoises are encountered, the vehicle shall not be moved until such animals have voluntarily moved to a safe distance away from the parked vehicle. 4.1.5-38: If desert tortoises must be moved during any Project activities, the following procedures shall be implemented by persons authorized by the USFWS to handle desert tortoises: (1) Desert tortoises shall be handled only by an authorized tortoise handler and only when necessary. New latex gloves shall be used when handling each desert tortoise to avoid the transfer of infectious diseases between animals. Desert tortoises shall be moved the minimum distance possible within appropriate habitat to ensure their safety. In general, desert tortoises shall not be moved in excess of 1,000 feet for adults and 300 feet for hatchlings. An authorized tortoise handler should follow the general handling methods contained in the "Protocols for Handling Live Tortoises" (USFWS 1990). (2) Desert tortoises that are found above ground and need to be moved shall be placed in the shade of a shrub. All desert tortoises removed from burrows shall be placed in an unoccupied burrow of approximately the same size as the one from which it was removed. All excavation of desert tortoise burrows shall be done using hand tools, either by or under the direct supervision of an authorized tortoise handler. If an existing burrow is unavailable, an authorized tortoise handler shall construct or direct the construction of a burrow of similar shape, size, depth, and orientation as the original burrow. Desert tortoises moved during inactive periods shall be monitored for at least two days after placement in the new burrows to ensure their safety. An authorized tortoise handler shall be allowed some judgement and discretion to ensure that survival of the desert tortoise is likely. (3) If desert tortoises need to be moved at a time of the day when ambient temperatures could harm them (less than 40 degrees F or greater than 90 degrees F), they shall be held overnight in a clean cardboard box. These desert tortoises should be kept in the care of an authorized tortoise handler under appropriate controlled temperatures and released the following day when temperatures are favorable. All cardboard boxes shall be appropriately discarded after one use. (4) All desert tortoises moved shall be marked for future identification. An identification number using the acrylic paint/epoxy covering technique should be placed on the fourth costal scute (USFWS 1990). No notching should be authorized. To facilitate clearing the area of desert tortoises, excavation of burrows should begin no more than fourteen (14) days prior to the onset of surface disturbing activities, as long as a final survey is conducted within 24 hours of the onset of activities to ensure that desert tortoises have not returned to the work area. 4.1.5-39: In order to minimize any exposure risk to desert tortoises, a specially designed fence shall be constructed around all portions of the Project area containing pits, ponds, waste rock stockpiles, ore processing areas, maintenance areas, and surface facilities. The final fence design shall be discussed with and found acceptable to the USFWS, BLM, and CDFG. The desert tortoise exclusion fence must meet the following preliminary design specifications: (1) Fencing shall result in a non-breachable barrier, and its support structure may be comprised of a variety of materials; (2) Galvanized ½-inch diameter mesh and 36-inch wide hardware cloth shall be used; and (3) The hardware cloth shall be buried 12 inches underground, extend at least 24 inches above the ground, and be firmly attached to the bottom of the perimeter fence and other wildlife exclusion fences. 4.1.5-40: Following fence installation, and prior to initiation of mining, authorized biologists under the supervision of an authorized tortoise handler shall conduct a complete (i.e., 100%) survey for desert tortoises within the fenced area. All tortoises found shall be marked and removed from the fenced mine area for safe off-site release within 1,000 feet of the outside of the Project fence using protocols acceptable to the BLM, USFWS, and the CDFG. Prior to release, ten (10) of these tortoises (consisting, insofar as possible, equal sex ratios of adult animals) shall be equipped with radio transmitters, and a equal number of individual additional tortoises (consisting, insofar as possible, equal sex ratios of adult animals) from the "resident" tortoise population outside of the Project mine and process area shall also be equipped with radio transmitters. These tortoises shall then be monitored to determine their survival rates and the impacts on resident tortoises. Data shall be collected weekly over a three year period during the activity period of this species in order to develop a model relating habitat composition (vegetation, soil suitability for burrowing, forage availability, conspecific densities, etc.) and tortoise density to carrying capacity. A goal of the model would be to provide valuable information on the effects of relocating tortoises. Prior to the implementation of this study the USFWS, CDFG, and BLM shall be consulted. 4.1.5-41: At the conclusion of Project pre-activity surveys and the relocation of any desert tortoises outside of the Project fence, Applicant and an authorized tortoise handler shall prepare a summary report documenting the desert tortoise protection measures implemented. The summary report shall be submitted to the BLM. 4.1.5-42: Pipeline placement design outside of tortoise-proof fenced project boundaries shall allow for the unimpeded movement of tortoises and other small terrestrial wildlife species. 4.1.5-43: That portion of the transmission line corridor extending outside of the fenced Project mine and process area boundary shall be re-surveyed for desert tortoise burrows and pallets within fourteen (14) days preceding line upgrading/construction. Tortoise burrows and pallets encountered within the construction zone (if any) shall be conspicuously flagged by the surveying biologist(s) and avoided during power pole placement or existing line upgrading. Contingent upon the findings of the pre-survey for the transmission line upgrade/construction, a determination shall be made by the BLM as to whether or not on-site desert tortoise monitoring would be required during the transmission line upgrade/construction activities. 4.1.5-44: Transmission and distribution pole design shall prevent nesting or perching by ravens, a major predator of young desert tortoises (see also Mitigation Measure 4.1.5-54). 4.1.5-45: As an alternative to the use of speed bumps, notification signs for the desert tortoise and speed limit signs shall be placed and maintained within the Project boundary by Applicant to reduce chances for inadvertent vehicle-induced injury or mortality to desert tortoises and other wildlife species. Applicant, with concurrence of County, shall also place these signs along Indian Pass Road leading to the Project mine and process area. 4.1.5-46: Applicant shall participate in the BLM desert tortoise program for acquiring offsetting lands in compensation for adverse modification of desert tortoise habitat. Under the BLM policy, undesignated lands such as the Project area, where tortoises or tortoise sign are located, become Class III tortoise habitat. Within Class III habitat, an offsetting ratio of 1:1 (e.g., one (1) acre of land secured and protectively managed for each acre affected) is applied. Lands shall be first considered in the affected County and would include 87 acres of habitat within microphyll woodland. 4.1.5-47: For any well field changes or drilling activities subsequently proposed for the Project, Applicant shall comply with the relevant terms and conditions of the Biological Opinion for Small Mining and Exploration Operations in the California Desert, dated June 1, 1992, prepared with respect to desert tortoise by the USFWS, and amended as necessary to be consistent with the desert tortoise protection measures prescribed in the USFWS Biological Opinion for the Project.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Resource:	CULTURAL AND PALEONTOLOGICAL RESOURCES
Issue:	Disturbance or destruction of cultural resource sites or features determined eligible for the National Register of Historic Places
Measures Incorporated by Project Design or Regulation:	· 4.1.6-1: To reduce Project impacts on identified cultural resources, Project facilities associated with the Project mine and process area shall be located consistent with those presented in the Plan of Operations (Revised September 1997). This shall include all of the Project revisions included since the previous Plan of Operation (Revised October 1996), including the revised boundary of the Project mine and process area, the reduction in the height of the waste rock stockpiles, the elimination of one (1) waste rock stockpile and two (2) soil stockpiles, and the reconfiguration of the remaining waste rock stockpiles, soil stockpiles, haul roads, and the heap leach pad.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Numerous prehistoric cultural resources determined eligible for the NRHP under criterion "A," "B," "C" and/or "D" would be subject to either direct or indirect impacts from the Project	Same as Proposed Action, although slightly fewer features and sites would be affected	Same as Proposed Action, although substantially fewer features and sites would be affected	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	· 4.1.6-2: Applicant shall designate a project contact representative (PCR) who would be responsible for overseeing Project compliance with the conditions and stipulations for cultural resources. The PCR shall have authority to halt all activities that are in violation of the stipulations. The PCR may be a project manager, company environmental coordinator, or other person identified as responsible by the Applicant. Applicant shall provide the name and contact information of the PCR to the BLM prior to construction. · 4.1.6-3: Should previously unidentified cultural resources be discovered during project construction or operations, Applicant shall immediately cease all activities in the immediate vicinity of the discovery and notify the BLM. Activities shall not be reinitiated in the vicinity of the discovery until authorized by the BLM.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Significant unavoidable for sites determined eligible for the National Register of Historic Places (NRHP) under criterion "A," "B" and/or "C," and Not significant under criterion "D."	Significant unavoidable for sites determined eligible for the NRHP under criterion "A," "B" and/or "C," and Not significant under criterion "D."	Significant unavoidable for sites determined eligible for the NRHP under criterion "A," "B" and/or "C," and Not significant under criterion "D."	Significant unavoidable for sites determined eligible for the NRHP under criterion "A," "B" and/or "C," and Not significant under criterion "D."	Not significant
Issue:	Physical disturbance within the Project mine and process area to the features of religious-symbolic significance within the Indian Pass-Running Man ATCC
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Physical disturbance within the Project mine and process area which will affect to the features of religious-symbolic significance within the Indian Pass-Running Man ATCC	Same as Proposed Action, although slightly fewer features and sites would be affected	Same as Proposed Action, although substantially fewer features and sites would be affected	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	The following mitigation measures were identified by KEA Environmental, Inc. as a result of the inventory and evaluation of cultural resources that may be affected by the Proposed Action. These mitigation measures have not been incorporated in the Project by the Applicant, but may be incorporated, in whole or in part, into BLM's Record of Decision for the Proposed Action following completion of on-going consultation with the SHPO and ACHP pursuant to Section 106 of the NHPA, and on-going Government-to-Government consultation with the Quechan Tribe: 4.1.6-4: Extant cultural features in the Indian Pass-Running Man ATCC should be avoided to the extent possible. KEA's GPS data base should be provided to Glamis Imperial to determine whether additional features can be avoided. 4.1.6-5: A professional archaeologist should flag or fence avoided features near construction areas prior to initial site preparation. Environmental inspectors should monitor avoidance. Flags outside of the perimeter fence should be removed immediately after construction of that fence. 4.1.6-6: An archaeological data recovery program conforming to that recommended in Chapter 9 of the KEA report should be implemented and should include a description and analysis of the features and artifacts that would be destroyed by the project and a technical archaeological report.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Significant unavoidable	Significant unavoidable	Significant unavoidable	Significant unavoidable	Not significant
Issue:	Physical disturbance within the Project mine and process area to significant Native American trails
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Physical disturbance within the Project mine and process area will occur to significant Native American trails and will cut-off the ability of the Quechan to travel physically and spiritually along the Trail of Dreams	Same as Proposed Action, although slightly fewer features and sites would be affected	Same as Proposed Action, although substantially fewer features and sites would be affected	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	The following mitigation measures were identified by KEA Environmental, Inc. as a result of the inventory and evaluation of cultural resources that may be affected by the Proposed Action. These mitigation measures have not been incorporated in the Project by the Applicant, but may be incorporated, in whole or in part, into BLM's Record of Decision for the Proposed Action following completion of on-going consultation with the SHPO and ACHP pursuant to Section 106 of the NHPA, and on-going Government-to-Government consultation with the Quechan Tribe: 4.1.6-7: In consultation with the Quechan, extant trails in the Indian Pass-Running Man ATCC should be field mapped and their significance to Native Americans ascertained. Low-level aerial photography and video photography should be used to document trails that will be destroyed. It appears from present information that certain trail corridors through the Indian Pass-Running Man ATCC west of the mine and process area can be preserved, including routes to Avikwaame. Preserved segments with high Native American sensitivity should be nominated to the NRHP and a preservation plan prepared and adopted by the BLM.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Significant unavoidable	Significant unavoidable	Significant unavoidable	Significant unavoidable	Not significant
Issue:	Physical disturbance and visual and aural intrusions in and from the Project mine and process area into the Indian Pass-Running Man ATCC
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Physical disturbance and visual and aural intrusions in and from the Project mine and process area into the Indian Pass-Running Man ATCC will conflict with the Quechan traditional practices and inhibit the Quechan's ability to conduct traditional religious activities at the Indian Pass-Running Man ATCC	Same as Proposed Action, although slightly fewer features and sites would be affected	Same as Proposed Action, although substantially fewer features and sites would be affected	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	The following mitigation measures were identified by KEA Environmental, Inc. as a result of the inventory and evaluation of cultural resources that may be affected by the Proposed Action. These mitigation measures have not been incorporated in the Project by the Applicant, but may be incorporated, in whole or in part, into BLM's Record of Decision for the Proposed Action following completion of on-going consultation with the SHPO and ACHP pursuant to Section 106 of the NHPA, and on-going Government-to-Government consultation with the Quechan Tribe: 4.1.6-8: In accordance with the current Plan of Operations, the height of the waste rock stockpiles and heap should be restricted to 300 feet. 4.1.6-9: The BLM should continue consultation with the Quechan to ensure continued access to the Indian Pass-Running Man ATCC during Project implementation and after Project closure.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Significant unavoidable	Significant unavoidable	Significant unavoidable	Significant unavoidable	Not significant
Issue:	Disturbance created within the Project mine and process area could inhibit or destroy the Quechan's ability to use the Indian Pass-Running Man ATCC for traditional cultural education programs
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Disturbance created within the Project mine and process area will inhibit or destroy the Quechan's ability to use the Indian Pass-Running Man ATCC for traditional cultural education programs	Same as Proposed Action, although slightly fewer features and sites would be affected	Same as Proposed Action, although substantially fewer features and sites would be affected	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	The following mitigation measures were identified by KEA Environmental, Inc. as a result of the inventory and evaluation of cultural resources that may be affected by the Proposed Action. These mitigation measures have not been incorporated in the Project by the Applicant, but may be incorporated, in whole or in part, into BLM's Record of Decision for the Proposed Action following completion of on-going consultation with the SHPO and ACHP pursuant to Section 106 of the NHPA, and on-going Government-to-Government consultation with the Quechan Tribe: 4.1.6-10: Provide for a cultural educational program which would include a professional-quality video documentary of the Indian Pass-Running Man ATCC prior to disturbance; a full or part-time teaching/curatorial position for a Quechan tribal member for a period of three (3) to five (5) years; preconstruction cultural educational classes in the Indian Pass-Running Man ATCC; and a comprehensive report documenting Quechan history and prehistory written in part or in its entirety by the Quechan. 4.1.6-11: Delay or phase construction activities to allow the Quechan the opportunity to conduct traditional cultural education in the Indian Pass-Running Man ATCC prior to their loss of this resource. 4.1.6-12: A non-technical report should be written based on the archaeological and ethnographic studies written for the Quechan tribe, addressing the part of Quechan history that would be destroyed by the mine. 4.1.6-13: Provide for the expansion of the Quechan Museum and curation of artifacts from the Project in this facility.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Significant unavoidable	Significant unavoidable	Significant unavoidable	Significant unavoidable	Not significant
Issue:	Disturbance created within the Project mine and process area may have a cumulative effect
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Disturbance created within the Project mine and process area will have a cumulative effect on traditional cultural sites in Quechan territory.	Same as Proposed Action, although slightly fewer features and sites would be affected	Same as Proposed Action, although substantially fewer features and sites would be affected	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	The following mitigation measures were identified by KEA Environmental, Inc. as a result of the inventory and evaluation of cultural resources that may be affected by the Proposed Action. These mitigation measures have not been incorporated in the Project by the Applicant, but may be incorporated, in whole or in part, into BLM's Record of Decision for the Proposed Action following completion of on-going consultation with the SHPO and ACHP pursuant to Section 106 of the NHPA, and on-going Government-to-Government consultation with the Quechan Tribe: 4.1.6-14: The Indian Pass-Running Man ATCC, the Trail of Dreams, Pilot Knob, Muggins Peak, and the Picacho Basin should be nominated to the NRHP as traditional cultural properties. 4.1.6-15: A recording and protection program for the concentration of scratched petroglyphs at Indian Pass should be implemented. 4.1.6-16: Consultation should be initiated with the Quechan to identify a site of traditional concern that could be acquired and protected.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Significant unavoidable	Significant unavoidable	Significant unavoidable	Significant unavoidable	Not significant
Issue:	Disturbance created within the Project mine and process area may result in lost data and historic context
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Physical disturbance created by the Project mine and process area to all or parts of seven (7) multicomponent and twelve (12) trail sites will result in data loss and the destruction of historic context	Same as Proposed Action, although slightly fewer features and sites would be affected	Same as Proposed Action, although substantially fewer features and sites would be affected	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	The following mitigation measures were identified by KEA Environmental, Inc. as a result of the inventory and evaluation of cultural resources that may be affected by the Proposed Action. These mitigation measures have not been incorporated in the Project by the Applicant, but may be incorporated, in whole or in part, into BLM's Record of Decision for the Proposed Action following completion of on-going consultation with the SHPO and ACHP pursuant to Section 106 of the NHPA, and on-going Government-to-Government consultation with the Quechan Tribe: 4.1.6-17: An archaeological data recovery program (in accordance with the recommendations provided in Chapter 9 of KEA's cultural resource report) should be implemented at sites that cannot be avoided.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Significant unavoidable	Significant unavoidable	Significant unavoidable	Significant unavoidable	Not significant
Issue:	Physical disturbance within the Project ancillary area may affect cultural sites
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Physical disturbance created by construction within the Project ancillary area may result in effects to significant archaeological sites	Essentially the same as Proposed Action	Similar to Proposed Action, although Indian Pass Road would not be relocated	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	The following mitigation measures were identified by KEA Environmental, Inc. as a result of the inventory and evaluation of cultural resources that may be affected by the Proposed Action. These mitigation measures have not been incorporated in the Project by the Applicant, but may be incorporated, in whole or in part, into BLM's Record of Decision for the Proposed Action following completion of on-going consultation with the SHPO and ACHP pursuant to Section 106 of the NHPA, and on-going Government-to-Government consultation with the Quechan Tribe: 4.1.6-18: No ground disturbance should be allowed within features that contribute to the significance of the Indian Pass-Running Man ATCC. In site CA-IMP-2727, the water pipeline should be rerouted to the area already disturbed by Indian Pass Road. Alternatively, boring could be utilized to avoid impacts to contributing features. All NRHP-eligible archaeological sites outside of the Indian Pass-Running Man ATCC should be avoided. Flagging and monitoring should be done in accordance with mitigation measure 4.1.6-5.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Issue:	Physical disturbance within the overbuilt 92 kV/34.5 kV transmission line corridor may affect historic Camp Pilot Knob
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Physical disturbance within the overbuilt 92 kV/34.5 kV transmission line corridor may affect features that contribute to the NRHP-eligibility of Camp Pilot Knob	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	The following mitigation measures were identified by KEA Environmental, Inc. as a result of the inventory and evaluation of cultural resources that may be affected by the Proposed Action. These mitigation measures have not been incorporated in the Project by the Applicant, but may be incorporated, in whole or in part, into BLM's Record of Decision for the Proposed Action following completion of on-going consultation with the SHPO and ACHP pursuant to Section 106 of the NHPA, and on-going Government-to-Government consultation with the Quechan Tribe: 4.1.6-19: Prior to construction, a professional historical archaeologist should flag all features in the vicinity of existing poles that contribute to the NRHP eligibility of Camp Pilot Knob. Periodic archaeological monitoring should be conducted to ensure avoidance. In case of accidental damage, BLM should consult with SHPO regarding an appropriate mitigation program. Oral history and archival research should be considered along with archaeological data recovery in case of such an eventuality. 4.1.6-20: If adverse effects cannot be avoided, an interpretive display should be developed to supplement the E Clampus Vitus sign that already exists on-site. This display should address the relationship of Camp Pilot Knob to the overall Desert Training Center operations and include historical photos of the camp during its period of significance.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Issue:	Physical disturbance within the overbuilt 92 kV/34.5 kV transmission line corridor may affect significant archeological sites
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Physical disturbance during construction within the overbuilt 92 kV/34.5 kV transmission line corridor may affect significant archaeological sites	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	The following mitigation measures were identified by KEA Environmental, Inc. as a result of the inventory and evaluation of cultural resources that may be affected by the Proposed Action. These mitigation measures have not been incorporated in the Project by the Applicant, but may be incorporated, in whole or in part, into BLM's Record of Decision for the Proposed Action following completion of on-going consultation with the SHPO and ACHP pursuant to Section 106 of the NHPA, and on-going Government-to-Government consultation with the Quechan Tribe: 4.1.6-21: All NRHP-eligible sites should be flagged for avoidance of direct impacts prior to construction of the transmission line. Avoidance of flagged archaeological sites should be part of the overall environmental monitoring program for the Project. In addition, periodic monitoring by a professional archaeologist and Quechan representative should be conducted to ensure avoidance. In case of accidental damage, BLM should consult with SHPO regarding an appropriate mitigation program. Oral history archival research, and ethnographic research should be considered as appropriate along with archaeological data recovery in case of such an eventuality.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Resource:	VISUAL RESOURCES
Issue:	Lighting
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Project lighting could interfere with low-level military overflight operations using night vision devices (NVD).	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	4.1.7-4: High intensity lighting used for mining and processing operations at night shall be directed downward to reduce fugitive light. Lighting shall have reflectors or shields to further minimize fugitive light. Light stanchions shall be no higher than necessary for safe and efficient lighting. 4.1.7-5: Applicant shall establish a working relationship with the U.S. Marine Corps (USMC) to ensure that nighttime lighting of the Project mine and process area does not substantially interfere with the use of Night Vision Devices (NVD) in the vicinity of the Project area or nighttime overflight operations within flight corridor VFR-299. As part of this mitigation measure, Applicant shall provide the USMC Air Station, Yuma, Arizona, with a detailed, to-scale, map of the Project area identifying the principal surface facilities, transmission lines, and locations of potential light sources to enable the USMC to avoid or accommodate these areas during nighttime flight activities.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Issue:	Visibility reduction
Measures Incorporated by Project Design or Regulation:	See Air Resources (measures to reduce the emissions of fugitive dust)	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Emissions of fugitive dust and oxides of nitrogen would slightly reduce visibility	Same as Proposed Action, although project emissions would end substantially sooner	Same as Proposed Action, although project emissions would end somewhat sooner	Same as Proposed Action, although highest project emission rates would continue longer	None
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Issue:	Visual contrast
Measures Incorporated by Project Design or Regulation:	4.1.7-1: Following completion of Project mining activities, all buildings, equipment, supplies, and debris shall be removed to improve the visual appearance of the Project area. 4.1.7-2: Dust suppressants shall be utilized, as necessary and in accordance with ICAPCD permit requirements, on haul roads to minimize fugitive airborne dust generation on the Project mine and process area. 4.1.7-3: In conformance with the Reclamation Plan as approved by the BLM and Imperial County, all disturbed areas shall be recontoured and reseeded or revegetated with native or indigenous species complementary to vegetation found in the surrounding area.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Unavoidable physical changes in the existing contour and character of the Project area, which would be visibly most apparent over the active life of the Project, but would diminish through the completion of reclamation and revegetation activities contained as part of the Proposed Action. These physical changes to the area would be permanent, but would continue to lessen following the completion of final reclamation as natural processes continued to soften the line and form to and match the surrounding landscape. A visual contrast with the surrounding area and change in the existing character of the landscape to a degree which would not conform with the BLM Class II visual objectives which have been applied to this Class L-designated area would also occur.	Same as Proposed Action, although somewhat reduced	Same as Proposed Action, although slightly reduced	Same as Proposed Action, although substantially reduced	None
Level of Significance of Resulting Impact:	Significant and unmitigatable	Significant and unmitigatable	Significant and unmitigatable	Significant and unmitigatable	Not significant
Mitigation Measures:	None	None	None	None	None
Level of Significance after Mitigation:	Significant and unmitigatable	Significant and unmitigatable	Significant and unmitigatable	Significant and unmitigatable	Not significant
Resource:	NOISE
Issue:	Production of noise
Measures Incorporated by Project Design or Regulation:	4.1.8-1: All heavy equipment, drilling rigs, and other internal combustion engines shall be equipped with mufflers to minimize noise generated during construction, operation and reclamation activities. 4.1.8-2: Applicable Occupational Safety and Health Administration (OSHA) worker noise protection requirements, as set forth in 29 CFR 1910.95, et seq, and California Occupational Safety and Health Administration (Cal-OSHA ) requirements, as set forth in 8 CCR 5095, et seq, shall be implemented by the Applicant.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Noise from operations would be discernable in the vicinity of the Project mine and process area, but except for blasting would probably be intrusional only to those dispersed recreational users in the immediate area of the Project mine and process area.	Same as Proposed Action, although would occur for only half the time	Same as Proposed Action, although would occur for only two-thirds of the time	Same as Proposed Action	No impact
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	4.1.8-3: Blasting shall only be conducted during daylight hours unless required for safety reasons. During the months of October through March, the Applicant shall take all reasonable steps to avoid blasting on weekend days (Saturday and Sunday), and shall not blast on the following major recreational holidays (Thanksgiving [Thursday through Sunday]; Christmas [Christmas day and all associated weekend days]; New Years [New Years eve, New Years day, and all associated weekend days]; and President's Day [and associated weekend days]) unless required for safety reasons or necessary to maintain production due to the mechanical breakdown of production equipment or other unforseen circumstances. Prior to conducting blasting on any of these designated weekend days or major holidays, Applicant shall on that day notify the BLM and take reasonable steps to notify those recreational users of the public lands located along Indian Pass Road or within one (1) mile of the boundary of the Project mine and process area boundary of the approximate time that blasting will occur.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Resource:	LAND USE
Issue:	Compatibility with existing uses, land use plans and policies, wilderness, and recreation
Measures Incorporated by Project Design or Regulation:	4.1.9-1: At the conclusion of mining activities, consistent with the approved Reclamation Plan, Applicant shall recontour all disturbed areas except the pit slopes as appropriate to create undulating land forms that are stable, safe, do not allow for any pooling or ponding, and blend with the surrounding undisturbed topography. Applicant shall also construct a loose rock barricade comprised of large boulders to prevent vehicle access and restrict public entry into the open pit area(s). 4.1.9-2: Applicant shall conduct mining operations in conformance with the Class L BLM multiple land use guidelines outlined in the CDCA Plan for mining in the area. The Applicant shall also comply with the federal land use requirements prescribed in 43 CFR 3809.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	The Proposed Action would generally be compatible with all existing uses and existing plans and policies except the use by low flying military aircraft, and would not produce direct impacts to the nearby wilderness areas. Project operations would likely reduce dispersed recreational uses in the immediate vicinity of the Project mine and process area during the active life of the Project, but with the exception of the open pit, disturbed lands would be available again for dispersed recreation following the completion of final reclamation.	Same as Proposed Action, although effects would be somewhat reduced in area and time	Same as Proposed Action, although effects would be slightly reduced in area and time	Same as Proposed Action	No impact
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	4.1.9-3: Applicant shall keep the USMC air station in Yuma, Arizona apprized of the current schedule and location for blasting at Project mine and process area to minimize the potential for low-flying military aircraft to be over the Project mine and process area during blasting activities.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Resource:	SOCIOECONOMICS
Issue:	Creation of adverse socioeconomic effects
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Only positive economic benefits would result.	Same as Proposed Action, although effects would be somewhat reduced in size and time	Same as Proposed Action, although effects would be slightly reduced in size and time	Same as Proposed Action, although slightly expanded in size and time	No impact
Level of Significance of Resulting Impact:	Beneficial	Beneficial	Beneficial	Beneficial	Not significant
Mitigation Measures:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Resource:	ROADS
Issue:	Effects on traffic and public access
Measures Incorporated by Project Design or Regulation:	4.1.11.1-1: Applicant shall realign an approximate 6,000-foot section of Indian Pass Road around the Project mine and process area prior to surface disturbance which would impede through traffic on this road, and shall maintain Indian Pass Road open to the public during construction of the relocated portion. 4.1.11.1-2: Applicant shall not route heavy traffic over Hyduke Road. 4.1.11.1-3: That section of Indian Pass Road realigned prior to mine construction shall be realigned to a location east of and approximately parallel to the diverted West Pit West diversion channel as soon as practicable, but prior to the completion of final reclamation and release of the physical reclamation bond. 4.1.11.1-4: Applicant shall post warning signs at the two (2) wash crossings along the relocated portion of Indian Pass Road warning drivers not to cross the wash when flooded, and shall undertake repairs or maintenance, as may be necessary and authorized by Imperial County, if Indian Pass Road is damaged by flooding where it crosses these washes. 4.1.11.1-5: Applicant shall apply water and/or dust suppressants (chemical treatments acceptable to all appropriate agencies) to Indian Pass Road from its intersection with Ogilby Road to the boundary of the Project mine and process area. 4.1.11.1-6: Applicant shall acquire the necessary approvals of the BLM and Imperial County to construct the relocated section of Indian Pass Road and the realigned intersection of Indian Pass Road and Ogilby Road, and shall design, construct and maintain these facilities in accordance with the permit conditions which are applicable at the time of construction. 4.1.11.1-7: Applicant shall encourage employees and construction workers to carpool to the Project area. 4.1.11.1-8: Applicant shall maintain Indian Pass Road from the intersection with Ogilby Road to the point immediately northeast of the Project mine and process area, including the section of the road relocated by the Project, during the active life of the Project in consultation with the Imperial County Public Works Department.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	There would a slight increase in traffic on public roads in the vicinity of the Project area over the 20-year life of the Project, and the closure of several currently open "routes" in the immediate vicinity of the Project mine and process area. Indian Pass Road would be temporarily rerouted but maintained open, and may lead to some proliferation of roads.	Same as Proposed Action, although effects would be somewhat reduced in area and time	Same as Proposed Action, although effects would be slightly reduced in area and time	Same as Proposed Action	No impact
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Other Measures:	4.1.11.1-9: To reduce the potential that access and "spur" roads constructed to provide temporary access to the new transmission line, water pipeline, and water wells may continue to be used by the public following the completion of Project reclamation, these roads, when constructed in areas of dark "desert varnished" desert pavement, shall be reclaimed in a manner, such as the application of Permeon, to reduce the visual contrast between the disturbed area and the surrounding undisturbed dark desert pavement.	None	None	None	None
Resource:	UTILITIES
Issue:	Effects on utility services
Measures Incorporated by Project Design or Regulation:	4.1.11.2-1: Applicant shall make available an on-site, diesel-fuel generator to meet emergency power needs for essential loads and services during periods of utility-provided electrical service interruption. 4.1.11.2-2: Applicant shall, at the end of the active life of the Project, remove all below-grade structures and all foundations, including the process pond liners; transport all surplus materials, storage containers and trash to a reuse or recycle facility, or to a landfill, authorized to accept this material; remove all remaining non-mining waste products, all surplus fuel oil, and other materials from the Project mine and process area and dispose of them according to then-current state and federal regulations. 4.1.11.2-3: Applicant shall acquire the necessary approvals of the BLM, Imperial Irrigation District, and other appropriate agencies to construct the 92 kV transmission line over the existing 34.5 kV transmission line, and shall design, construct and maintain this transmission line in accordance with the conditions of these permits, including avoiding the disturbance of any new surface areas during construction.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	There would a very slight demand placed on utilities, which would not create capacity which would stimulate new development.	Same as Proposed Action, although effects would be somewhat reduced in time	Same as Proposed Action, although effects would be slightly reduced in time	Same as Proposed Action	No impact
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Other Measures:	4.1.11.2-4: Applicant shall work with the USMC to ensure that neither the microwave communication system nor the Project FM mine communication system interfere with military overflight communications.	None	None	None	None
Resource:	PUBLIC SERVICES
Issue:	Demands on public services
Measures Incorporated by Project Design or Regulation:	4.1.11.3-1: Applicant shall provide an on-site septic system for wastewater treatment, which shall be removed upon completion of Project activities. 4.1.11.3-2: When no longer required for Project operations, Applicant shall remove that portion of the 92 kV/13.2 kV transmission line owned by the Project. 4.1.11.3-3: Applicant shall provide potable water for hand washing and drinking purposes. 4.1.11.3-4: Applicant shall obtain necessary permit(s) for on-site sanitary facilities from the Imperial County Department of Health Services. 4.1.11.3-5: To the extent feasible, all GLO/BLM Cadastral Survey monuments shall be avoided and protected from any accidental damage or destruction. All monuments which may be subject to either intentional or accidental damage or destruction within the Project mine and process area shall be perpetuated by the installation and survey of witness monuments, subject to the prior approval of the survey by the BLM Cadastral Survey and conformance with the applicable California codes, and documented with a record of survey.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	No demand on public services is anticipated.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	No impact
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Resource:	EMERGENCY SERVICES AND PUBLIC SAFETY
Issue:	Potential to create public hazards
Measures Incorporated by Project Design or Regulation:	4.1.12-1: Applicant shall provide appropriate levels of on-site security, fire protection services, and emergency first-aid medical services. 4.1.12-2: Applicant shall construct and maintain a fence around the perimeter of the Project mine and process area over the life of the Project, and a chain-link fence, no less than six (6) feet in height, with one (1) foot of barbed wire at the top, around the ore leach pad, process facilities, to prevent the public from accessing these facilities. 4.1.12-3: Sodium cyanide shall be shipped to, and received at, the Project mine and process area in solid, briquette from in the manufacturer's dry bulk trucks, and be put into solution directly from the dry bulk trucks at the Project mine and process area process facility. 4.1.12-4: Before removal of the perimeter fence at the end of the active life of the Project, Applicant shall construct around the rim of the open East Pit a barricade with large boulders to prevent vehicular access and discourage pedestrian access by the public over slopes which could constitute a hazard. The barricade shall consist of boulders averaging approximately four (4) feet in diameter, which shall be stacked into a continuous wall no less than eight (8) feet high. This "wall" shall be set back from the edge of the pit by no less than 100 feet. In addition, the uppermost ten (10) feet of the pit slope shall slope no greater than 2H:1V (30 degrees), and shall terminate at its lower side into a horizontal bench no less than ten (10) feet wide. 4.1.12-5: Applicant shall post no trespassing and hazardous chemical signs, in both English and Spanish, at strategic locations along perimeter locations of the Project mine and process area perimeter fence and the process facilities barbed wire-topped chain-link fence, respectively. 4.1.12-6: Applicant shall prepare a hazardous material spill/release contingency plan and provide appropriate training to all Project employees on the proper response to potential chemical releases. 4.1.12-7: Applicant shall prepare an emergency response contingency plan which provides for actions to be taken in the event of an injury accident, hazardous materials release, fire, flash flooding on Indian Pass Road, or other emergency situation. The emergency response contingency plan shall include emergency phone numbers and services available for both surface and air transport of injured employees. The emergency contingency response plan shall incorporate protocols acceptable to the BLM, ICPWD, and the Imperial County Sheriff's Office for dealing with flash floods and public safety on Indian Pass Road. The protocols shall address notification of agencies and closures of Indian Pass Road. 4.1.12-8: Applicant shall prepare and maintain a hazardous material business plan in conformance with the requirements of Imperial County. 4.1.12-9: Applicant shall conform with all applicable safety regulations required by the Mine Safety and Health Administration (MSHA), Occupational Safety and Health Administration (OSHA), and California Occupational Safety and Health Administration (Cal-OSHA).	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	Should mining be terminated prior to the complete backfilling of either the West Pit or the Singer Pit, these pits would not be barricaded under the Proposed Action.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	No impact
Level of Significance of Resulting Impact:	Significant	Significant	Significant	Significant	Not significant
Mitigation Measures:	4.1.12-10: Before removal of the perimeter fence at the end of the active life of the Project, Applicant shall construct around the rim of the all open pit(s) a barricade with large boulders to prevent vehicular access and discourage pedestrian access by the public over slopes which could constitute a hazard. The barricade shall consist of boulders averaging approximately four (4) feet in diameter, which shall be stacked into a continuous wall no less than eight (8) feet high. This "wall" shall be set back from the edge of the pit by no less than 100 feet. In addition, the uppermost ten (10) feet of the pit slope shall slope no greater than 2H:1V (30 degrees), and shall terminate at its lower side into a horizontal bench no less than ten (10) feet wide.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant
Resource:	OTHER RESOURCES
Issue:	Environmental justice
Measures Incorporated by Project Design or Regulation:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Resulting Impact:	No disproportionately high and adverse indirect human health or environmental effects to minority or low-income populations would result.	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	No impact
Level of Significance of Resulting Impact:	Not significant	Not significant	Not significant	Not significant	Not significant
Mitigation Measures:	None	Same as Proposed Action	Same as Proposed Action	Same as Proposed Action	None
Level of Significance after Mitigation:	Not significant	Not significant	Not significant	Not significant	Not significant

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