Coal Diver Everything you wanted to know about coal, but were afraid to ask.

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APPENDIX A P E R M I T A P P L I C AT I O N S

Application for Transmission and Utility Systems and Facilities on Federal Lands June 8, 2007

Application for Transmission and Utility Systems and Facilities on Federal Lands September 27, 2005

Bureau of Land Management Standard Coal Lease Form

APPENDIX B S TA N D A R D P R A C T I C E S A N D M I T I G AT I O N M E A S U R E S

Appendix B Standard Practices and Mitigation Measures
TABLE OF CONTENTS Page 1.0 2.0 3.0 4.0 5.0 Introduction..................................................................................................................... B-1 Mine Reclamation Plan ................................................................................................ B-33 Mine Revegetation Plan................................................................................................ B-35 Noxious Weed Control Plan......................................................................................... B-43 Revegetation Success Monitoring Plan ....................................................................... B-44 5.1 Determining Revegetation Success: General Requirements and Standards ........ B-44 5.2 Revegetation Success Criteria.............................................................................. B-46 5.3 Herbaceous Cover................................................................................................ B-46 5.4 Herbaceous Production ........................................................................................ B-47 5.5 Woody Plant Density ........................................................................................... B-47 5.6 Diversity............................................................................................................... B-48 5.7 Unique Circumstances ......................................................................................... B-50 5.8 Revegetation Community Mapping / Stratification............................................. B-50 5.9 Sample Layout ..................................................................................................... B-50 5.10 Determination of Ground Cover .......................................................................... B-52 5.11 Determination of Production................................................................................ B-53 5.12 Determination of Woody Plant Density............................................................... B-53 5.13 Determination of Seedling Emergence ................................................................ B-54 5.14 Sample Adequacy Determination / Success Evaluation ...................................... B-54 5.15 Rill and Gully Inspections ................................................................................... B-56 5.16 Soil Testing Plan .................................................................................................. B-56 5.17 Disposal of Debris, Acid-Forming and Toxic Forming Materials....................... B-57 5.18 Sealing or Managing Mine Openings, Exploration Holes, Other Boreholes or Wells................................................................................................................ B-57 Subsidence Monitoring Program................................................................................. B-60 Railroad Fire Mitigation .............................................................................................. B-61 7.1 Mechanical Clearing ............................................................................................ B-61 7.2 Burning ................................................................................................................ B-61 7.3 Chemical Treatment............................................................................................. B-62 7.4 Fire Resistant Plants............................................................................................. B-62 7.5 Fire Fighting Methods.......................................................................................... B-62 BLM’s Standards and Guidelines (BLM 1997) ......................................................... B-64 8.1 Standards for Public Land Health ........................................................................ B-64 8.2 Guidelines for Livestock Grazing Management .................................................. B-66 Special Stipulations....................................................................................................... B-68 9.1 General................................................................................................................. B-68 9.2 Roads.................................................................................................................... B-69 9.3 Transmission Lines .............................................................................................. B-70 9.4 Railroad Spur and Water Pipeline........................................................................ B-70 9.5 Cultural Resources ............................................................................................... B-70 9.6 Soils and Vegetation ............................................................................................ B-71 B-i

6.0 7.0

8.0

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Appendix B Standard Practices and Mitigation Measures
9.7 9.8 9.9 9.10 9.11 Noxious Weeds .................................................................................................... B-71 Threatened and Endangered Species ................................................................... B-71 Hazardous Materials ............................................................................................ B-71 Visual Resources.................................................................................................. B-72 Health and Safety................................................................................................. B-72

10.0 References...................................................................................................................... B-72 List of Tables Table B-1 Table SM-1 Table SM-2 Table SM-3 Table E5-6 Applicable Legal and Policy Requirements and Mitigation Measures by Resource..........................................................................................................B-3 Stabilization (Temporary) Seed Mix .................................................................B-36 Red Cliff Project – Suggested Revegetation Seed Mix for Topsoiled Areas Targeting Grazingland Land Use – 2007...........................................................B-36 Red Cliff Project – Suggested Revegetation Seed Mix for Topsoiled Areas Targeting Wildlife Habitat Land Use – 2007 ....................................................B-39 Vegetation Cover – 2006 ...................................................................................B-49

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Appendix B Standard Practices and Mitigation Measures
List of Acronyms AHR AO AQCC ASTM BACT BLM BMP BP CAL AD CCR CDOT CDOW CDPS CFR CMM COE CR CRS CSP DEIS DRMS ECSQG EIS EPCRA ERRP F&L FRA GHG GPS MINER MSDS annual hydrology report Authorized Officer Colorado Air Quality Control Commission Regulations American Society for Testing and Materials Best Available Control Technology U.S. Bureau of Land Management Best Management Practice before present calendar AD date Code of Colorado Regulations Colorado Department of Transportation Colorado Division of Wildlife Colorado Department of Public Safety Code of Federal Regulations Coal Mine Methane U.S. Army Corps of Engineers County Road Colorado Revised Statutes Colorado State Parks Draft Environmental Impact Statement Division of Reclamation, Mining and Safety Erosion Control and Stormwater Quality Guide Environmental Impact Statement Emergency Planning and Community Right-To-Know Act of 1986 Erosion, Revegetation and Restoration Plan Field & Laboratory Federal Railroad Administration greenhouse gas global positioning system Mine Improvement and New Emergency Response Act of 2006 material safety data sheets B-iii

Appendix B Standard Practices and Mitigation Measures
MSHA NAAQS NAGPRA NEPA NHPA NIFC NRCS NPDES OSHA ORV PPE RA RCRA ROD ROW SARA SHPO SM SPCC SSPS su SWPPP T&E TDS Trec US USACE USDA USFWS VAM VRM Mine Safety and Health Administration National Ambient Air Quality Standards Native American Graves Protection and Repatriation Act National Environmental Policy Act National Historic Preservation Act National Interagency Fire Center Natural Resources Conservation Service National Pollution Discharge Elimination System Occupational Safety & Health Administration off-road vehicle personal protective equipment reference area Resource Conservation and Recovery Act of 1976 Record of Decision right-of-way Superfund Amendments and Reauthorization Act State Historic Preservation Officer seed mix Spill Prevention, Control, and Countermeasures special-status plant species standard units Stormwater Pollution Prevention Plans threatened and endangered total dissolved solids Total Recoverable United States U.S. Army Corps of Engineers U.S. Department of Agriculture U.S. Fish and Wildlife Service ventilation air methane Visual Resource Management

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Appendix B Standard Practices and Mitigation Measures
1.0 Introduction

Appendix B, Standard Practices and Mitigation Measures, contains a table (Table B-1, Applicable Legal and Policy Requirements and Mitigation Measures by Resource) listing all of the applicable laws, regulations, policies, additional U.S. Bureau of Land Management (BLM)/Cooperating Agency recommended mitigation and enhancements, and operator-proposed features to mitigate impacts by resource. The Laws and Authorities column lists federal, state, and local government agency laws and regulations that must be followed. The BLM Policies and Regulations column describes BLM policies that must be adhered to. The Limits or Controls Stipulated column describes the Laws and Authorities and BLM Policies and Regulations columns in more detail. The Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements column includes mitigation measures proposed by BLM or a Cooperating Agency that are not backed by that agency’s regulatory authority, but are proposed as potential mitigation. These mitigation measures are either proposed by BLM, a Cooperating Agency, or are current text in the Draft Environmental Impact Statement (DEIS). The agency proposing the mitigation measure is indicated in parentheses; otherwise the mitigation measure is current text in the DEIS. The Operator-Proposed Features to Mitigate Impacts column includes facility design, construction and operation timing, reclamation, revegetation, noxious weed plan, monitoring, wildlife mitigation, and conservation. The rationale for these features is to mitigate potential impacts to less than significant. The term “operator" refers to the future operator of the mine, which would be the successful bidder for the lease area. Neither the BLM/Cooperating Agency recommended mitigation and enhancements nor the operator-proposed features to mitigate impacts are finalized. These mitigation measures are not tied to any regulatory authority and are currently under discussion to determine if they are reasonable, feasible, and whether they relate directly to an impact of the proposed action. The Record of Decision (ROD) for this EIS will contain BLM’s required mitigation measures. BLM does not have the authority to require mitigation on lands and resources outside BLM’s jurisdiction, including the following: Mesa County roads, state and federal highways, private land under Mesa or Garfield county’s jurisdiction, and Highline Lake State Park. Following the table are the proposed Mine Reclamation Plan, Mine Revegetation Plan, Noxious Weed Control Plan, Revegetation Success Monitoring Plan, and Subsidence Monitoring Program. A Railroad Fire Mitigation Plan, adopted from an existing Field Guide, is also included. Also included are BLM’s Standards and Guidelines, and Special Stipulations.

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Appendix B Standard Practices and Mitigation Measures

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Land Ownership and Use Laws and Authorities Mine Safety and Health Administration (MSHA) Rules (30 CFR § 75.1700). Rules and regulations of the Colorado Mined Land Reclamation Board Pursuant to the Colorado Surface Coal Mining Reclamation Act – Section 2.05.4 BLM Policies and Regulations See the Special Stipulations section in this appendix. Use of Federal lands would require the mine operator to obtain rights-of-way grants on these federal lands. Limits or Controls Stipulated Some gas wells overlying the lease area may be plugged or “mined around” per Mine Safety and Health Administration (MSHA) Rules (30 CFR § 75.1700). Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements New transmission lines would be constructed along existing county road easements on private lands, and new rights-of-way would be secured for construction of new transmission lines on BLM-administered lands. All temporary construction areas would be reclaimed and revegetated per BLM policy. Upon decommissioning of the mine, surface facilities would be removed and the land would be restored to its original vegetative cover per BLM policy. Access roads would be closed to the public, and the disturbed area would be reclaimed. Upon project termination, the railroad would be removed, including bridges, cross warning devices, and gate systems at road intersections, and the area would be revegetated according to BLM policy. For Transmission line Alternatives A and B, Grand Valley Power would need to acquire new easements on private lands. Fence repair or rebuilding would be done as required. New water sources would be supplied. Cattle guards may need to be installed to protect livestock from rail or vehicular traffic. See Section 7.0, Railroad Fire Mitigation, in this appendix. Operator-Proposed Features to Mitigate Impacts The proposed postmining land use would be achieved by reclaiming the disturbed area and planting same in accordance with the reclamation plan presented in this appendix.

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• Grazing See the Special Stipulations section in this appendix. BLM Guidelines for Livestock Grazing Management (BLM 1997) Wilderness and Special Designations Recreation See BLM’s Standards and Guidelines in this appendix • • • •

See Mine Reclamation Plan in this appendix.

No mitigation is required. See the Special Stipulations section in this appendix. • Within the North Fruita Desert SRMA, BLM would require that existing trails impacted by the mine facilities and the railroad be mitigated. One way in which this may be done would be for the Applicant to contract with the Colorado Off-Highway Vehicle Coalition to design and construct alternate trail routes for those that are closed by the mine facilities or railroad alignment. Existing trails crossed by the rail line would need to be restored to be suitable for their original designation. (BLM) Potential negative impacts on property values can be in part avoided by properly addressing some of the other concerns: safety, noise, deterioration in viewsheds, etc. Some uncertainties about future developments could be mitigated by providing quality land use planning and related information to the community, e.g., through an appropriate role being played by the responsible governmental entities, such as the Mesa County Planning Commission.

• Socioeconomics •

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated • Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Landscaping measures could overcome some of the visual impact concerns. Horn noise mitigation could in part be addressed through grade separations and a "quiet crossing" for County Road (CR) M.8 and CR 10. The deeper social impacts on rural values could in part be addressed by working more closely with the community to enhance traditional social interactions, community cohesion, historic preservation, and rural fire protection and alleviate possible school crowding. Recommendations by the community have been made for safer crossings, especially at CR 10 and CR M.8, by creating grade separations. Additional adaptations to the community’s design suggestions about safety and road realignments would require additional public involvement in a collaborative mode in order to create satisfactory mitigation alternatives. Some mitigation benefits could be provided through clearer and more transparent communications about associated land use restrictions, intentions, and objectives. In the long run the role and authority of local governments in guiding compatible land uses, working directly with the community residents, would be quite vital to maintaining the rural quality of life within the Mack-Loma community area. Along with the other specific mitigation measures, a framework to improve community-company communications and relations is needed. This could take many forms, but should be based on an agreement between the parties to establish clearer expectations and open lines of communication about the mine and rail construction and operations phases. A commitment among all parties to establish a neighborly, working partnership would pay long term benefits for community sustainability, towards more effective mine operations, and for employee wellbeing. Carpooling of workers should be employed to minimize transportation impacts. (Colorado Division of Wildlife [CDOW]) Employees should be bussed to the mine site from a central location in the Fruita/Loma/Mack area. CDOW stated that it would lessen vehicle/animal collisions, and allow for a smaller parking lot. (CDOW) County Road X should have a 35-mph speed limit during the day and 25-mph speed limit from 1 hour before sunset to 1 hour after sunrise. (CDOW) A traffic management plan would be developed during the final design of the project to minimize disruption Operator-Proposed Features to Mitigate Impacts

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Transportation

Mesa County Road and Bridge Specifications Mesa County and Colorado Department of Transportation (CDOT) design and safety standards.

CR X would be designed to meet Mesa County Road and Bridge Standard requirements. Since this road lies with in the Grand Valley Airshed, the road surface would be asphalt or chipn-seal to remain dust free. The intersection improvements would incorporate the latest

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated design and safety standards and be designed in accordance with Mesa County and CDOT standards. Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements to traffic flow. These plans would be designed in accordance with agency standards and would include maintenance of access to private property, minimizing disruption to local businesses, and provide detours or alternate routes as needed. Construction activities would be coordinated with agency officials to avoid the need for night time construction in certain sensitive areas near residents. If county roads are built along proclamated ROW in the future that cross the railroad spur, an appropriate crossing would be constructed. (Mesa County) Weed control along the railroad corridor could be used to mitigate potential impacts of fire caused by the railroad. (CDOW) Bond the company for reclamation costs in case of a fire caused by the railroad. (CDOW) See Section 7.0, Railroad Fire Mitigation, in this appendix. Operator-Proposed Features to Mitigate Impacts

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Utilities – Railroad

Title 49 Code of Federal Regulations (49 CFR) • Section 213.37 - Vegetation. • Section 230.204 - General precautions. Healthy Forests Restoration Act of 2003 • Sec. 102. Authorized Hazardous Fuel Reduction Projects. • Sec. 104. Environmental Analysis.

Any underground phone lines and small electric distribution lines within the railroad/pipeline rightof-way (ROW) would be replaced or moved in accordance with all applicable federal, state, and utility provider regulations and policies. In accordance with 49 CFR Part 659 and Colorado Revised Statutes (CRS) 40-18, the Colorado Public Utilities Commission has responsibility for the oversight of the safety and security of rail fixed guideway systems within the state. See the Special Stipulations section in this appendix.

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Utilities – Water Pipeline

• • Roads would be constructed and maintained to BLM road standards (BLM Manual Section 9113). Road segment #2 crosses an ephemeral stream that drains a watershed of over 1 square mile so the restrictions of rule 4.03.1(2)(b) apply. The Division of Reclamation, Mining, and Safety (DRMS) must • •

Utilities – Access Roads

Rules and regulations of the Colorado Mined Land Reclamation Board Pursuant to the Colorado Surface Coal Mining Reclamation Act (CRS Section 34-33-101) Regulations of the Colorado Mined Land Reclamation Board for Coal Mining (2 Code of Colorado Regulations [CCR] 407-2) Rule 4.03 Roads o Rule 4.03.1(2)(b) o Rule 4.03.1(6). o Rule 4.03.2(6).

BLM Manual Section 9113 – Road Standards See the Special Stipulations section in this appendix.

Hydrants would be installed on either side of the water pipeline to be used in case of fire. (BLM) The water pipeline would be pressure-sensitive in case of leaks. (BLM) Immediate reclamation of all construction related roads, Increased information/education and law enforcement. (CDOW)

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The combination of paving, dust control and sediment control comprised of drainage collection ditches located on each side of the road would assure the road crossing would not cause a violation of applicable water quality standards. During mining a culvert would be maintained under the road to assure water quality and quantity in the ephemeral channel is not adversely affected. After mining the road culvert would be removed and the stream channel restored so the water quality and quantity in the ephemeral channel is not adversely affected. In the placement of embankment for the haul road, materials would be spread in layers approximately 12 inches deep, and such lifts made uniformly over long stretches and for the full width of the embankment. Each lift would be moistened or dried to a uniform moisture content suitable for maximum compaction. Hauling equipment would be routed both ways over the fill and routing varied sufficiently to achieve uniform compaction. Compaction would be carried to the edge of the fills so that the final slopes are firm. A sheepsfoot roller or other suitable equipment may be required to achieve compaction. Compaction of each lift would continue until the unit dry weight of the lift reaches a value not less than 90 percent of maximum unit dry weight attained in a laboratory compaction

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities Rule 4.05 Hydrologic Balance o Rule 4.05.18. Handbook of Steel Drainage & Highway Construction Products (1983). BLM Policies and Regulations Limits or Controls Stipulated specifically authorize this stream channel crossing under Rule 4.05.18. Culverts are designed in accordance with the Handbook of Steel Drainage & Highway Construction Products (1983). The haul roads on-site would be maintained in accordance with Rule 4.03.1(6). The access roads on-site would be maintained in accordance with Rule 4.03.2(6). Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Operator-Proposed Features to Mitigate Impacts test in accordance with the specifications of American Society for Testing and Materials (ASTM) D 698, Method D. Where the embankment is placed against the existing slopes, the slopes would be benched and scarified down to a firm dense base as the new fill is being placed. Material so loosened would be mixed with the new fill and the resultant mix blended firmly into the slope. When rock or rocky material is used for embankment, placement shall be in layers not exceeding the maximum size of the rock present, and in no case shall lifts exceed 30 inches in depth. Rock layers shall be compacted by routing the spreading equipment and loaded hauling equipment over the entire width of the fill until compaction is obtained. Temporary erosion control measures would be implemented during the construction of the haul roads. Straw bales, riprap, check dams, vegetation or other alternative sedimentation control measures would be used to reduce overland flow velocity, reduce run-off volume, or trap sediment. After construction is complete the area disturbed would be seeded and mulched to reduce the rate and volume of run-off. The minimum depth of cover for corrugated steel pipe, H-20 live load, 2 2/3 X 1/2 inch corrugations is 12-inches for diameters or spans of 12 to 96 inches. The depth of cover is measured from the top of pipe to the top of subgrade. Therefore all culverts would be covered by compacted fill to a minimum depth of 1 foot. The inlet end of all culverts would be protected by an end section or a rock or concrete headwall. Acid or toxic forming substances would not be used in haul road surfacing. The paved road surfaces would be patched as necessary and potholes would be filled. Gravel road surfaces would be periodically watered and maintained with a motor grader. Ditches along the roadways would be periodically cleaned with a motor grader and the road shoulders would be smoothed to conform to the paved surface. Cut and fill sections would be vegetated and gullies, if any, would be repaired at least annually. If the haul road is damaged by a catastrophic event such as a flood or earthquake, it would be repaired as soon as practicable after the damage has occurred. Gravel would be added to the road surfaces as necessary. The haul road from State Highway 139 to the preparation plant area would not be totally reclaimed. Asphalt surfacing would be removed from the entire road surface. The waste asphalt would either be recycled or placed in the waste rock pile for final disposal. The road bed would be narrowed from a travel width of over 24 feet to a travel width of 14 to 16 feet. Culverts would be removed. The road is to be left in place so the light use roads on the property are re-established after reclamation. Reclamation of the remaining haul roads would involve returning the road to its pre-mining contours. Roads would be closed to vehicular traffic. Natural drainage patterns shall be restored. Bridges and culverts shall be removed. Roadbeds shall be ripped plowed or scarified. Fill slopes shall be rounded or reduced and shaped to conform the site to adjacent terrain and to meet natural drainage restoration standards. Cut slopes shall be shaped to blend with the natural contour. Terraces shall be constructed as necessary to prevent excessive erosion and to provided long term stability in cut and fill slope. The regraded area shall be covered with topsoil and revegetated. Road surfacing materials that are incompatible with the postminig land use and revegetation requirements shall be removed and disposed of in appropriate disposal areas as authorized by the DRMS. Temporary erosion control measures would be implemented during the construction of the access roads. Straw bales, riprap, check dams, vegetation or other alternative sedimentation control measures would be used to reduce overland flow velocity, reduce run-off volume, or trap sediment. After construction is complete the area disturbed would be seeded and mulched to reduce the rate and volume of run-off. Access roads would to the extent practicable, be located on ridges or on the most stable available slopes to minimize erosion.

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Operator-Proposed Features to Mitigate Impacts The road surfaces would be patched as necessary and potholes would be filled. Gravel road surfaces would be periodically watered and maintained with a motor grader. Ditches along the roadways would be periodically cleaned with a motor grader and the road shoulders would be smoothed to conform to the road surface. If the access road is damaged by a catastrophic event such as a flood or earthquake, it would be repaired as soon as practicable after the damage has occurred. Gravel would be added to the road surfaces as necessary. • All access roads would be reclaimed. Roads would be closed to vehicular traffic. Natural drainage patterns shall be restored. Bridges and culverts shall be removed. Roadbeds shall be ripped plowed or scarified. Fill slopes shall be rounded or reduced and shaped to conform the site to adjacent terrain and to meet natural drainage restoration standards. Cut slopes shall be shaped to blend with the natural contour. Terraces shall be constructed as necessary to prevent excessive erosion and to provided long term stability in cut and fill slope. The regraded area shall be covered with topsoil and revegetated. Road surfacing materials that are incompatible with the postminig land use and revegetation requirements shall be removed and disposed of in appropriate disposal areas as authorized by the DRMS. The following design specification for the sediment ponds is adapted from Rule 4.05.9(7): The embankment foundation area shall be cleared of all organic matter, all surfaces sloped no steeper than 1h:1v, and the entire foundation surface scarified. The fill material shall be free of sod, large roots, other large vegetation matter, and frozen soil, and in no case shall coalprocessing waste be used in embankment construction. The placing and spreading of fill material shall be started at the lowest point of the foundation. Materials would be spread in layers approximately 12 inches deep, and such lifts made uniformly over long stretches and for the full width of embankment. Each lift would be moistened or dried to a uniform moisture content suitable for maximum compaction. The fill material shall be compacted until it attains at least 95 percent of the maximum dry density attained in a laboratory compaction test in accordance with ASTM D698. This compaction is necessary to achieve the strength parameters used in the embankment stability analyses. Compaction tests would be taken at a frequency and location of not less than one per every other layer, at random locations across the embankment. The embankment shall be constructed so the design height is achieved at all times, including the period after settlement. The combined upstream and downstream side slopes of the settled embankment shall not be steeper than 5h:1v, with neither slope steeper than 2h:1v. Faces of the embankments including the surrounding areas disturbed would be vegetated to enhance stability. Anti-seep collars would be installed to control seepage along conduits that extend through the embankment. The sediment ponds must be dewatered if they contain water above the maximum sediment level. Ponds A, D and E would be dewatered with a portable pump. Remaining ponds would be dewatered through their primary spillways which consist of six inch diameter pipes. All ponds have a standard emergency spillway with the inlet placed at the maximum water storage elevation. Dewatering events should occur within 48 hours after the storm event or mine discharge which caused the water accumulation. Sediment would be removed from all ponds no later than when the ponds are 75 percent full of sediment. Sediment ponds would be removed after the site has been reclaimed and the vegetation on the reclaimed site is adequate to control erosion. Pond removal must be authorized by the Division and the untreated drainage from the disturbed area ceases to contribute additional suspended solids above natural conditions. Mine discharge would be treated in underground sumps if required. Any discharge from the mine or mine facilities would be treated to meet Colorado Department of Public Safety (CDPS) discharge permit requirements. •

Utilities – Sediment ponds

Regulations of the Colorado Mined Land Reclamation Board for Coal Mining (2 CCR 407-2) Rule 4.05 Hydrologic Balance • Rule 4.05.3 • Rule 4.05.4 • Rule 4.05.6 • Rule 4.05.9

See the Special Stipulations section in this appendix.

The sediment ponds are considered temporary ponds and are designed to meet the requirements of Rules 4.05.6 and 4.05.9. Collection ditches and diversion ditches have been designed to comply with the requirements of rules 4.05.3 and 4.05.4.

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Utilities – Transmission Line Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated • • Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Any displaced distribution lines would be replaced with underbuild lines. Transmission lines shall be constructed in accordance to standards outlined in “Suggested Practices for Raptor Protection on Power Lines”. See Section 9.3, Transmission Lines, in this appendix. Full-cutoff lighting at the mine facilities could be used to reduce nighttime light impacts. Mine facilities would be painted colors that would blend with the background colors. Operator-Proposed Features to Mitigate Impacts

Visual

BLM Visual Resource Management Guidance Temporary construction areas would be revegetated according to BLM policy, thus reducing visual impacts due to construction. Upon termination of the project, the aboveground mine facilities would be removed and the area would be revegetated in accordance with BLM policy. See the Special Stipulations section in this appendix. See the Special Stipulations section in this appendix.

Mine facilities would be painted colors that would blend with the background colors as required by the Standard Design Practices in the Grand Junction RMP (BLM 1987) (unless prevented by safety or permitting requirements).

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Noise

The Colorado General Assembly has established statewide standards for noise level limits during various time periods in various areas (25-12-101). FTA Transit Noise and Impact Assessment Manual

If the sound levels of a noise are above the given limit when heard 25 feet away, then the noise is a public nuisance. For industrial zones, noises cannot exceed 80db(A) between the hours of 7am and 7pm and cannot exceed 75db(A) between 7pm and 7am. The criteria to mitigate severe railroad horn noise impacts states that mitigation should be considered when there is a 5 dBA increase in Ldn or Leq, and the total noise level exceeds 65 dBA.

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Noiseless crossing at CR 10 is considered mitigation. (Mesa County) CR M.8 crossing would be a quiet zone. (Mesa County) Mitigation measures include tall earth berms or noise walls to reduce noise to acceptable FTA levels. Other noise mitigation measures can include insulating the home or structure, installing noiseless crossing traffic control devices at the grade crossing to create ‘quiet zones’, or purchasing and moving the residential property. Noise mitigation is required for receptor R10 at the CR 10 grade crossing location. Noise mitigation at this location should consider an earth berm, or a concrete noise wall, or a combination earth berm/concrete wall, or insulating the building with sound proof material, or installing a noiseless crossing traffic control device at the grade crossing, or purchasing & moving the residence. The operator would take appropriate measures to reduce noise from construction equipment; this would include the installation and maintenance of engine

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements mufflers. To avoid noise impacts at night, night-time construction may be curtailed in certain sensitive areas near residents. Permitting, reporting, transportation, management, and disposal of all hazardous substances, petroleum products, and/or solid waste materials produced must comply with all state and federal regulations. Such regulations should include spill prevention and response plans for all components of the coal mining operations. (CDOW) Hazardous substances, petroleum products, and/or solid waste materials produced must be stored such that heavy rains would not flush these materials into nearby waterways. Containment areas should be constructed to allow for maximum storage of the above materials, with the potential for an increase in volume due to heavy precipitation. (CDOW) The operator would implement a program to reduce, reuse, and recycle materials to the extent practicable at facility locations. Operator-Proposed Features to Mitigate Impacts

Hazardous Materials

Solid and Hazardous Waste Commission Regulations (6 CCR 1007-3) • Part 260- Hazardous Waste Management System: General • Part 261- Identification and Listing of Hazardous Waste • Part 262- Standards Applicable to Generators of Hazardous Waste • Part 263- Standards Applicable to Transporters of Hazardous Waste • Part 266- Financial Requirements • Part 267- Standards for the Management of Specific Hazardous Waste and Specific Types of Hazardous Waste Management Facilities • Part 268- Land Disposal Restrictions • Part 100- Permit Regulations • Part 6-Hazardous Waste Commission Fees • Part 262-Standards Applicable to Generators of Hazardous Waste Regulations of the Colorado Mined Land Reclamation Board for Coal Mining (2 CCR 407-2) • Rule 4.05 Hydrologic Balance • Rule 4.09 Disposal of Excess Soil • Rule 4.10 Coal Mine Waste Banks • Rule 4.11 Coal Mine Waste • Rule 4.14 Backfilling and Grading

See the Special Stipulations section in this appendix.

All waste rock would be analyzed to determine if it is an acid or toxicforming material. If the rock is determined to be non-acid or non-toxic forming, it would be stockpiled within the waste rock pile as described in the associated surface facilities section of Chapter 2 in accordance with applicable state regulations (2 CCR 4072.2.04.09 through 2 CCR 407-2.2.04.11). If it is determined to be acid or toxic forming, waste would be stored, handled and disposed of in accordance with applicable state (2 CCR 407-2.4.05.8, 2 CCR 4072.4.10.1 and 2 CCR 4072.4.14.3) and federal regulations. The facility would have a Spill Prevention, Control, and Countermeasures (SPCC) Plan (40 CFR Part 112) addressing the accidental release of materials to the environment. Section 303 of the Emergency Planning and Community Right-ToKnow Act of 1986 (SARA Title III) (EPCRA) requires the preparation of Emergency Response Plans for rail emergencies.

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities 40 CFR Part 112 - Requirements for Preparation and Implementation of Spill Prevention Control and Countermeasure Plans. Section 303 of the Emergency Planning and Community RightTo-Know Act of 1986 (SARA Title III) (EPCRA) 4 Code of CCR 723-7 Part 7 Rules Regulating Railroads, Rail Fixed Guideways, Transportation by Rail, and Rail Crossings Toxic Substances Control Act of 1976, as amended (15 U.S.C. 2601 et seq.) Rules and regulations of the Colorado Mined Land Reclamation Board Pursuant to the Colorado Surface Coal Mining Reclamation Act – • Rule 4.02.6 Blasting Signs • Rule 4.08.2 Pre-blasting Survey 30 CFR 75.1711 Sealing of Mines 40 CFR Part 112 - Requirements for Preparation and Implementation of Spill Prevention Control and Countermeasure Plans. MSHA Rules (30 CFR § 75.1700) Occupational Safety & Health Administration (OSHA) regulations (29 CFR part 1926 Safety and Health Regulations for Construction ) OSHA publication for Hearing Conservation (OSHA 3074) BLM Policies and Regulations Limits or Controls Stipulated Under 4 Code of Colorado Regulations (CCR) 723-7 Part 7, the Public Utilities Commission requires every transit agency to establish and maintain a written system safety program plan. The holder shall comply with the Toxic Substances Control Act of 1976, as amended with regard to any toxic substances that are used, generated by, or stored on the ROW. See Section 9.9, Hazardous Materials, of this appendix. Blasting signs would be erected on all roads leading to the blast site as required by Rule 4.02.6. Rule 4.08.2 requires the operator to provide written notification to all residents or owners of dwellings or other structures located within one-half mile of the permit area which explains how to request a pre-blast survey. Such notice is to be given 30 days before initiation of blasting. The mine portals would be sealed in accordance with 30 CFR 75.1711. The facilities would have a SPCC Plan (40 CFR Part 112). The SPCC Plan would include spill prevention, containment as well as response and Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Operator-Proposed Features to Mitigate Impacts

Health and Safety

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Dust from roads and earthwork – Dust from earth moving machinery would be controlled by water and dust suppression chemicals. Traffic incidents on-site – Construction workers operating vehicles, as well as personnel working around vehicles on-site would be trained and licensed where applicable, so that these vehicles are operated in a safe and appropriate manner. Construction equipment hazards – Construction vehicles and equipment would be operated within the manufacturers specifications. All vehicles and equipment would be maintained and serviced on a regular basis. Maintenance ‘lock-out/tag-out’ safety systems would be implemented. Cold and heat stress – Personnel training, monitoring, and correct personal protection can help mitigate the effects of temperature extremes. Slips, trips and falls – Identifying and eliminating or minimizing hazards, use of proper footwear and implementing behavioral based training would help reduce injuries associated with slips, trips and falls. Confined space entry and excavation and trench hazards – Personnel would be trained and/or knowledgeable about applicable OSHA safety training and regulations. Rock and roof falls – Best Practices have been developed through experience and research to reduce these risks. They combine engineering design, roof support, equipment, mining methods, and human

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A sign would be placed on the road on each side of the blast site. The signs would be placed about one half mile from the blast site. Since blasting activities would be sporadic, the signs would be displayed at least 10 days before any blasting activity. The blasting signs would be removed shortly after the blasting activities have concluded. A public notice of surface blasting schedule would be published in a newspaper of general circulation in the locality of the blasting site at least ten days but no more than twenty days before initiating any blasting program. Since this surface blasting plan is applicable to surface blasting activities incident to underground mining activities, the written notification would only be given to all residents or owners of dwellings or other structures located within one-half mile of the blast site. The contractor responsible for the construction of the site would have a temporary explosive storage area or would haul and remove explosives from the site after each blast.

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities Federal Mine Safety & Health Act of 1977, Public Law 91-173 (as amended by Public Law 95164) BLM Policies and Regulations Limits or Controls Stipulated clean-up to an accidental spill or leak. Noise – Appropriate hearing protective equipment would be utilized by construction workers as required by MSHA and OSHA regulations. Employers must provide hearing protectors to all workers exposed to 8-hour time weighted average (TWA) noise levels of 85 dB or above. This requirement ensures that employees have access to protectors before they experience any hearing loss. The OSHA publication for Hearing Conservation (OSHA 3074) provides guidance for monitoring and appropriate Personal Protective Equipment (PPE) for construction workers. Health standard provision of the Federal Mine Safety & Health Act of 1977, Public Law 91-173 (as amended by Public Law 95-164) would be strictly adhered to. Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements factors to create safer workplaces and work practices (NIOSH 2008). Underground air quality – Ventilation to supply fresh air and remove/ dilute contaminants and pollutants would be a component of the mining design. Blasting – Blasting experts would utilize safe blast design, control of access and evacuation warnings before blasting. Personnel in the vicinity of a blast would wear PPE and all personnel would observe safe distances during blasting activities. Safety procedures would be strictly adhered to. Fire in coal storage and handling facilities – A fire suppression system would be an element of the engineering design. Relevant site staff would complete fire safety training. An Emergency Response Plan inclusive of a local trained fire crew and proper containment and shutdown procedures would be implemented. Accidents related to use of tools and machinery – Equipment and machinery would be operated within the manufacturer’s specifications. All equipment and machinery would be maintained and serviced on a regular basis. Employees would be trained and have current licenses where necessary. Maintenance ‘lockout / tag-out’ safety systems would be implemented. Birds and bats – Cleaning up affected areas would help to prevent the spread of infection. Ventilation to supply fresh air and remove/dilute contaminants and pollutants as well as proper PPE use would be a component of the mining design. Traffic incidents on-site – Miners operating vehicles on-site would be trained and licensed, so that these vehicles are driven in a safe and appropriate manner. Chemical release to atmospheric or ground systems – Personnel would be trained in appropriate storage and handling and incident response. Material safety data sheets (MSDS) would be available on-site. Chemical incidents would be included in the Emergency Response Plan. Contact with high voltage electricity – Construction and operation of this transmission line would adhere to all approved codes of practices and procedures. Qualified electricians and secured access and isolation procedures would reduce risks associated with high voltage. Failure to provide adequate emergency treatment and response – The federal government recently initiated the Mine Improvement and New Emergency Response (MINER) Act of 2006, signed into law on Operator-Proposed Features to Mitigate Impacts

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements June 15, 2006 by President Bush. In addition to additional emergency air supply regulations, the MINER Act calls for a plan of post-accident communication between underground and surface personnel via a wireless, two-way medium, and for an electronic tracking system, permitting surface personnel to determine the location of any persons trapped underground. The new federal standards are mandated to be implemented by June 2009. Dust generated by vehicle travel and construction activities should be minimized near waterways to reduce increased sedimentation. (CDOW) Concentrations of nitrogen (including ammonium) and sulfur compounds should be reduced through Best Available Control Technology (BACTs) to reduce the potential impacts of dry and wet deposition. (CDOW) Mitigation measures / controls are planned to be implemented to control particulate fugitive dust emissions during production and construction activities. Most of the coal transfer points and processing actions during coal production would be enclosed and therefore limit the amount of “fugitive” emissions. Storage piles are planned to be watered as necessary to limit wind erosion potential. All vehicle travel emissions for production and construction on non-paved surfaces would be controlled utilizing dust suppression chemicals. . Operator-Proposed Features to Mitigate Impacts

Air Quality

Clean Air Act (42 USC 7401 et seq.) Colorado Air Quality Control Commission Regulations (AQCC) 1001 • Regulation 1- Particulates, Smokes, Carbon Monoxide, and Sulfur Oxides • Regulation 3- Stationary Source Permitting and Air Pollutant Emission Notice Requirements • Regulation 5- Generic Emissions Trading and Banking • Regulation 7- Emissions of Volatile Organic Compounds • Regulation 8- Control of Hazardous Air Pollutants • Regulation 12- Reduction of Diesel Vehicle Emissions

See the Special Stipulations section in this appendix.

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Climate Change/ Greenhouse Gases

BLM Oil & Gas Leasing Regulations 43 CFR 3100

Methane emission estimates from the underground mine ventilation and degasification systems are based on the total methane ventilated from the mine plus the methane liberated from degasification systems, less any methane that would be recovered. Construction Potential mitigation measures to decrease GHG emissions during construction include: • Use of alternative fuel construction equipment • Use of local building materials • Recycling of demolished construction material Operation Methane mitigation would include methods to reduce emissions from both the ventilation air and degasification systems.

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Mitigation measures to decrease methane (GHG) emissions from coal mines include: • Methane liberation from the mine may be reduced through mine planning, sealing previously mined areas, and degasification efforts. Coal Mine Methane (CMM) mitigation would include methods to reduce emissions from both the ventilation air (VAM) and degasification systems. As part of the Proposed Action, an adaptive management plan for methane recovery and control or beneficial use from the mine is proposed. Some or all of these methods may not be feasible at the proposed mine. Potential methane recovery and control or beneficial use options include: • VAM — The low methane concentration in VAM (typically 0.5 percent by volume) complicates methane control by oxidation/combustion or beneficial use. The low heat content of VAM and the potential for moisture or dust in VAM are limiting factors and generally restrict VAM emission reduction scenarios to non-beneficial uses since it is not a quality fuel. VAM can be destroyed in special types of thermal or catalytic oxidizers, or it can sometimes be used as combustion air for engines or turbines. In some cases, the methane concentration of VAM can be increased to make beneficial use more feasible. • Methane from Degasification Systems — Emissions from methane degasification systems have relatively high methane concentrations (above 30 percent by volume) and, depending on the type of degasification system, can be nearly pure methane. Methane from degasification systems can be controlled using flares or other oxidation technologies, or can be put to beneficial use. Examples of typical beneficial uses of degasification methane include the following: o Inject the gas into a nearby natural gas pipeline (if the methane concentration of the gas exceeds 95 percent and meets other criteria) involving the recovery of methane gas streams and collection into pipelines for sale to pipeline companies; o Fuel power-generating equipment such as internal combustion engines or turbines (either at the mine or at nearby facilities); Fuel mine or nearby facility heaters, furnaces, or dryers; and/or o Fuel for coal mine vehicles. See Section 4.2.1, Air Quality, for additional information. o Operator-Proposed Features to Mitigate Impacts

B-13

Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Cultural Resources Laws and Authorities National Historic Preservation Act (16 USC 470 et seq.) National Register of Historic Places (36 CFR 60.1-60.15) Archaeological Resources Protection Act (16 USC 470aamm) 43 CFR Part 10 Native American Graves Protection and Repatriation Act (NAGPRA) Regulations; Final Rule CRS 24-65.1/HB-1041 Colorado Land Use Act CRS29-20/HB-1034 Local Government Land Use Control Enabling Act of 1974 CRS24-80.1, 101-108- Register of Historic Places Statue and 8CCR 1504-5- State Register of Historic Places, Rules and Procedures 8CCR 1504-7- Historical, Prehistorical, and Archaeological Rules and Procedures CRS 30-11.101 as Amended/HB 90-1104- Powers of Counties CRS 38-30.5-101-111Conservation Easements CRS 24-80-501-502- State Historical Monuments • • BLM Policies and Regulations See the Special Stipulations section in this appendix. Limits or Controls Stipulated Pursuant to 43 CFR 10.4(g), the AO must be notified immediately upon the discovery of human remains, funerary items, sacred objects, or objects of cultural patrimony. Work in the vicinity of the discovery must stop. See Section 9.5, Cultural Resources, in this appendix. Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Site 5GF3880 requires monitoring during conveyor construction. If the waste rock disposal area changes in this area of the mine project and facilities cannot avoid the site, a testing plan to determine if any remaining cultural deposits are present would be developed and submitted for review through additional consultation with the SHPO. Access to one eligible site, 5ME15398, would be limited by fencing potential access points. The fencing would have to prevent any access to the ridge where the site is located. The fence would be gated and locked to allow administrative access for any maintenance on the existing transmission line. The fence would be constructed prior to any construction activity. Site 5ME15398 would be avoided by direct impacts from the mine project but because of its location it may be affected by secondary impacts associated with off highway vehicle use or changes in the current BLM transportation plan in this area of the North Fruita Desert Planning Area. If the road is not closed as a result of the mine development, secondary impacts would be avoided by fencing the road along the site boundary. There would be an approved subsidence monitoring plan in place prior to the commencement of mining that would proactively address any potential subsidence impacts to cultural resources prior to their occurrence. When a transmission line alternative is selected, a cultural resources survey would be conducted. Operator-Proposed Features to Mitigate Impacts Sites 5GF3878, 5GF3879, 5GF3880, and 5ME15398 were field evaluated as eligible for listing on the National Register of Historic Places. These should be protected and preserved. Site 5GF3880, a slab-lined hearth feature, was tested for eligibility and was dated 1150±40 BP (CAL AD 780 – 990). Although that test removed the significant, scientific data from the cultural feature and determined the surrounding soils were deflated by about 15cm, monitoring in its vicinity is advised because early and middle Holocene deposits are exposed in that area. The Operator would assure a qualified person is present during any operations that may disturb the area surrounding the slab-lined hearth feature. The other sites determined “field eligible” would apparently be avoided by the projected impact areas; however, final determinations of effect must be made by the BLM in consultation with the State Historic Preservation Officer.

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If new information is provided by Native Americans during the NEPA process, additional or edited terms and conditions for mitigation may have to be negotiated or enforced, such as the following: • If new information is brought forward any sitespecific Native American mitigation measures suggested during notification/ consultation would be considered during the implementation of the Proposed Action. Strict adherence to the confidentiality of information concerning the nature and location of archeological resources would be required of Company and their subcontractors (Archeological Resource Protection Act, 16 U.S.C. 470hh). Inadvertent discovery: The NHPA, as amended, requires that if newly discovered cultural resources are identified during the Proposed Action implementation, work in that area must stop and the BLM Authorized

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Officer (AO) notified immediately (36 CFR 800.13). The Native American Graves Protection and Repatriation Act (NAGPRA) requires that if inadvertent discovery of Native American Remains or Objects occurs, any activity must cease in the area of discovery, a reasonable effort made to protect the item(s) discovered, and immediate notice be made to the BLM AO, as well as the appropriate Native American group(s) (IV.C.2). Notice may be followed by a 30-day delay (NAGPRA Section 3(d)). On private lands, laws for Historic, Prehistoric, and Archaeological Resources, and for unmarked Human Graves (CRS 24-80-401 and CRS 24-80-1301) would be adhered to by Company and their subcontractors. These state statutes require that the federal Authorizing Officer be notified immediately of any historic or prehistoric finds or human grave. The find must be protected until the authorizing officer indicates the action may proceed. (BLM) Subsidence • Mitigation of subsidence impacts can best be done by appropriate design of the mine plan. It is possible to somewhat mitigate the adverse impacts by varying panel width, by designing gateroad pillars between panels to yield when the first of two adjacent panels is mined and crush after the face of the second panel is mined past and by positioning longwall panels with respect to a particularly important surface feature. Normally, if landslides or rockfalls are present in an area, constraints on design and construction may be necessary to minimize risk. • Longwall panels should not be completed in overburden conditions of less than 200 feet. The 200foot overburden contour extends approximately 360 feet upstream from the outcrop line in Big Salt Wash and approximately 550 feet upstream from the outcrop line in Garvey Canyon. Long-term protection from chimney subsidence to the overlying ground surface can be provided in such shallow overburden by partially backfilling the entries in these two areas upon final closure of the Red Cliff Mine. • The potential for draining surface water into the Red Cliff Mine is low, but probably precludes longwall mining under stream courses and water impoundments when the bedrock overburden thickness is less than 95 feet. Big Salt Wash is particularly at risk because it also contains a road and has agricultural uses. No longwall panels will be completed beneath Big Salt Operator-Proposed Features to Mitigate Impacts

Geology/Subsidence

DRMS Section 2.05.06(6) Subsidence Survey, Subsidence Monitoring, and Subsidence Control Plan. DRMS Section 4.20 Subsidence Control DRMS Rule 8 Mine Subsidence Protection Program

See the Special Stipulations section in this appendix.

Section 2.05.06(6) establishes survey, monitoring and control requirements for subsidence. Section 4.20 establishes requirements to prevent subsidence from causing material damage to the surface, public notification requirements, and buffer zones. Rule 8 provides the detailed specifications for carrying out the Colorado Mine Subsidence Protection Program.

See Subsidence Monitoring Program in this appendix.

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Wash. Because there is no available depth of alluvium below any of the deeply incised canyons and the absence of any data on the potential fault control of the nearly trellis drainage pattern in the project area, conservatism must be used and a minimum of 200 feet of overburden required to positively prevent water loss from longwall mining under even intermittent stream courses. • It is possible to at least partially mitigate tilting hazards and similar potential major toppling hazards in Big Salt Wash, Garvey Canyon, and along Munger Creek by designing the longwall panels to retreat toward these drainages from the north and from the south. Retreating toward these drainages would slightly flatten the slope of the canyon walls as opposed to advancing away from Big Salt Wash which would slightly steepen the canyon walls. • A conceptual mine plan has been proposed that would mitigate potential subsidence impacts in the project area. The goals of the conceptual plan were to maximize safety, then mitigate to the extent possible subsidence impacts and finally to maximize resource recovery. • The mine operator would also be required to comply with state and federal regulations regarding subsidence impacts as they prepare their mine plan and permit application. Rockfall Hazards • Based on project plans to date, a conveyor and mine portal access road would cross the boundary of the rockfall hazard area. Constructing these facilities would undoubtedly change the existing natural conditions. Therefore, site-specific engineering designs and rockfall mitigation measures would be necessary to ensure the safety of both infrastructure and personnel in these areas. Slope stability studies and, where appropriate, rockfall stability analyses should be completed for structures proposed in the rockfall hazard area. Landslide Hazards • If the practice of avoidance is adopted for the proposed construction, risks associated with future movement of the landslide deposit are considered low. Accelerated Erosion • Project plans should be guided by an engineering firm qualified in geotechnical engineering design. • During periods of isolated heavy precipitation or rapid snowmelt accelerated erosion is exaggerated. Site specific engineering designs and mitigation measures Operator-Proposed Features to Mitigate Impacts

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements should be developed to control the flow of surface water away from the upstream headward erosion scars of the two zones. Other Geologic Hazards • Although the anticipated loadings from the proposed Red Cliff Mine facilities would be relatively large, foundation designs should be based on results of laboratory swell/consolidation testing. • Foundation designs should be guided by results of swell/consolidation laboratory testing. Other • See Subsidence Monitoring Program in this appendix. • If any surface disturbing activities (e.g., vent shafts) are planned on areas underlain by the Wasatch Formation, the site should be surveyed by a qualified paleontologist prior to construction. This would significantly decrease the possibility of fossil destruction. • A survey would not be required prior to the BLM authorization for any activities not immediately underlain by the Wasatch Formation. However, if any fossils are noticed at anytime, the AO must be notified so the resource can be recorded, evaluated, stabilized, or mitigated. • All persons associated with operations under this authorization shall be informed that any objects or sites of paleontological or scientific value, such as vertebrate or scientifically important invertebrate fossils, shall not be damaged, destroyed, removed, moved, or disturbed. If in connection with operations under this authorization any of the above resources are encountered the operator shall immediately suspend all activities in the immediate vicinity of the discovery that might further disturb such materials and notify the BLM authorized officer of the findings. The discovery must be protected until notified to proceed by the BLM authorized officer. • As feasible, the operator shall suspend grounddisturbing activities at the discovery site and immediately notify the BLM authorized officer of any finds. The BLM authorized officer would, as soon as feasible, have a BLM-permitted paleontologist check out the find and record and collect it if warranted. If ground-disturbing activities cannot be immediately suspended, the operator shall work around or set the discovery aside in a safe place to be accessed by the BLM-permitted paleontologist. Operator-Proposed Features to Mitigate Impacts

Paleontology

8CCR 1504-7- Historical, Prehistorical, and Archaeological Rules and Procedures

See the Special Stipulations section in this appendix.

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Soils Laws and Authorities USDA Natural Resources Conservation Service (NRCS) suggested reseeding mix BLM Policies and Regulations Reclamation standards for disturbance BLM Standards for Public Land Health (BLM 1997) See the Special Stipulations section in this appendix. Limits or Controls Stipulated See Standard 1 in BLM’s Standards and Guidelines in this appendix. Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Reclamation and Revegetation • Soils suitable to support plant growth would be salvaged for use in reclamation. Soil stockpiles would be protected from disturbance and erosional influences. Soil material that is not suitable to support plant growth would not be salvaged. Soil or overburden materials containing potentially harmful chemical constituents would need to be specially handled. After soil is replaced on reclaimed surfaces, revegetation would reduce erosion. The mine would construct sediment control structures as needed to trap eroded soil. • Vegetation growth should be monitored on reclaimed areas to determine if soil amendments are needed. These measures are required by regulation and are therefore considered to be part of the proposed action. • Follow the U.S. Department of Agriculture (USDA) recommended re-seeding mix. • Re-seed according to alternatives listed for erosion control and stabilization of disturbed areas (e.g., roadsides, construction sites, mine sites, and spoils) for salt desert shrub. Erosion and Sedimentation • In order to mitigate erosion and sedimentation on construction sites, adding mulch and seeding may protect the soil from erosion. Straw bales, silt fences, gravel bags, narrow grass strips or buffers, vegetative barriers, and terraces and diversions catch sediment and shorten the length or the erosive surface. Combinations of cover and structural practices help to control erosion and sedimentation and improve soil quality. Some temporary measures, such as a silt fence at the base of the slope, do not reduce the hazard of erosion on the slope but trap some of the sediment leaving the slope. • Soils would be exposed during construction. It is essential that the exposed area is minimized and that a protective cover is established. Conservation practices that provide immediate permanent cover or provide intermittent cover are very effective in controlling erosion and runoff. Other practices, such as diversions and terraces, also help to control erosion and runoff. They provide temporary protection until vegetation becomes established, and they provide permanent protection for the site (NRCS 2004). • Reduction of sediment (and the salts it contains) is an ongoing concern, and BLM management of the Mancos shale areas would continue to receive scrutiny, particularly in view of the effects salinity on Operator-Proposed Features to Mitigate Impacts All topsoil would be salvaged from the areas to be disturbed after vegetation cover that would interfere with the use of the topsoil is cleared. Sagebrush, forbs and grasses would not be cleared prior to topsoil salvage. Oak brush and Pinyon and Juniper trees would be cleared from areas prior to topsoil salvage. Since the area would be reclaimed as rangeland and wildlife habitat and there is no prime farmland in the proposed mining area, all suitable topsoil horizons would be salvaged together. Additionally, subsoil would be salvaged and placed in stockpile and later used for cover material for the coal mine waste disposal area. The stockpiles are located on a stable surface area within the permit area, where they would not be disturbed by mining operations and would be protected from wind and water erosion, unnecessary compaction, and contamination which would lessen the capability of the material to support vegetation. An effective cover of non-noxious, quick-growing annual and perennial plants, would be seeded or planted during the first appropriate growing season after removal. A berm would be constructed around the base of stockpiles where necessary to prevent loss of topsoil from the stockpiles. Straw bales or a silt fence would be installed in the low point of the berm. Stockpiled topsoil and other materials shall not be moved until required for redistribution on a regraded area unless approved by the Division. Selected overburden materials are not planned to be used for or as a supplement to topsoil. Topsoil would be removed by rubber tired scrapers with the assistance of tracked dozers or a track mounted backhoe and truck equipment spread. Reseeding mix: o Streambank wheatgrass (Agropyron riparium) o Galleta grass (Pleuraphis jamesii) o Alkali sacaton (Sporobolus airoides) o Indian ricegrass (Achnatherum hymenoides) o Thickspike wheatgrass (Elymus lanceolatus) o Western wheatgrass (Pascopyrum smithii) o Green needlegrass (Nassella viridula) o Prairie junegrass (Koeleria macrantha) o Rocky Mountain penstemon (Penstemon strictus) o Four-wing saltbrush (Atriplex canescens) Seeding alternatives listed for erosion control and stabilization of disturbed areas (e.g., roadsides, construction sites, mine sites, and spoils) for salt desert shrub include: o Crested wheatgrass (Agropyron cristatum) o Russian wildrye (Psathyrostachys juncea) o Thickspike wheatgrass (Elymus lanceolatus) o Streambank wheatgrass (Agropyron riparium) o Indian ricegrass (Achnatherum hymenoides) o Lewis flax (Linum lewisii) o Palmer penstemon (Penstemon palmeri) o Four-wing saltbrush (Atriplex canescens) o Forage kochia (Kochia americana) See Mine Revegetation Plan, Noxious Weed Plan, and Revegetation Success Monitoring Plan in this appendix.

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements water quality regarding threatened or endangered fish species, agricultural use, and drinking water (NFDMP 2004). • A maintenance and emergency plan would be developed for slope stabilization. (BLM) Saline Soils • Given that saline sediment and increased water runoff is one of the key pollutants in the Colorado River basin, significant investments in stormwater control and upkeep would be necessary and would help minimize erosion if properly chosen and installed. • Adding mulch, seeding, and providing sod protects the soil from erosion. Straw bales, silt fences, gravel bags, narrow grass strips or buffers, vegetative barriers, and terraces and diversions catch sediment and shorten the length of the erosive surface. • Combinations of cover and structural practices help to control erosion and sedimentation and improve soil quality. • Some temporary measures, such as a silt fence as the base of the slope, do not reduce the hazard of erosion on the slope but trap some of the sediment leaving the slope. The following are some basic principles of erosion and water-runoff control on construction sites (Muckel 2004): o Divide the project into smaller phases, clearing smaller areas of vegetation. o Schedule excavation during low-rainfall periods when possible. o Fit development to the terrain. o Excavate immediately before construction instead of exposing the soil for months or years. o Cover disturbed soils with vegetation or mulch as soon as possible and thus reduce the hazard of erosion. o Divert water from disturbed areas. o Control concentrated flow and runoff, thus reducing the volume and velocity of water from work sites and preventing the formation of rills and gullies. o Minimize the length and gradient of slopes (e.g., use bench terraces). o Prevent the movement of sediment to offsite areas. o Inspect and maintain all structural control measures. o Install windbreaks to control wind erosion. Operator-Proposed Features to Mitigate Impacts

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements o Avoid soil compaction by restricting the use of trucks and heavy equipment to limited areas. o Break up of till compacted soils prior to vegetating or placing sod. o Avoid dumping excess concrete or washing trucks onsite. • Conservation practices that provide immediate cover (sod) or provide intermittent cover (mulching and seeding) are very effective in controlling runoff and erosion. Other practices, such as diversions and terraces, also help to control runoff and erosion. Expansive/Shrink-Swell Soils • The potential for structural damage can often be minimized or the damage avoided altogether by following certain practices. With expansive soils, the main goal is to minimize fluctuations in soil water content. Proper surface drainage, plant species choices, and long-term maintenance are all important. In more arid areas, as is the climate within the project area, excess moisture should be kept several feet away from structures and foundations (NRCS 2004). Landslides/Slope Failure • Geotechnical engineers should be brought in to remediate a slope failure. Any remediation work should involve skilled and experienced geologists and engineers. Important Farmlands • There are several soil series south of the Highline Canal classified as prime farmland if irrigated. Efforts to minimize human impacts should be made by concentrating traffic and activities within confined areas. Biological Soil Crusts • Efforts to minimize human impacts to biological soil crusts should be made by concentrating traffic and activities within confined areas. Soil Compaction • If compaction occurs in the top six to eight inches of the soil, tillage tools such as a chisel plow or moldboard plow can be used to shatter the compacted layer. However, if compaction is below eight to 10 inches, tillage tools such as a subsoiler, ripper, or paraplow may be needed. • The following are preventative measures that could be taken to minimize soil compaction: o Reduce traffic, especially under wet conditions – Traffic is the major cause of excessive soil compaction. The more often equipment travels Operator-Proposed Features to Mitigate Impacts

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements across a site, the greater the opportunity for soil compaction. Reduce the number of passes. o Reduce tire pressure to reduce surface compaction – While reduced tire pressure would not reduce subsurface compaction, it would reduce surface compaction. Low pressure tires or dual wheels would reduce the degree of surface soil compaction but may increase the area compacted. The soil must support the weight of the equipment. Duals or low pressure tires simply spread out the weight. Reduce traffic under wet condition – Soil is more compressible when wet. Traffic during high moisture conditions may compact soil, whereas the same traffic under dry conditions would not. As the soil dries, it has a higher soil strength, making it less susceptible to compaction. A dry soil supports traffic more readily than a wet soil. In addition, compaction stresses generated from the same wheel would be transmitted deeper in wet soils. Operator-Proposed Features to Mitigate Impacts

o

Groundwater

Clean Water Act (33 USC 1251 et seq.)

See the Special Stipulations section in this appendix.

• •

Control traffic – Whenever possible, restrict all equipment to specific tracks or traffic lanes through the field, leaving the rest of the site essentially uncompacted. This requires some equipment management but may be well worth the effort. Appropriate mitigation measures would be required if data from the monitoring wells showed adverse impacts to groundwater. Use BMP's related to groundwater production during the construction phase and throughout the operational life of the mine. (CDOW) o

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Surface Water Laws and Authorities Clean Water Act (33 USC 1251 et seq.) State Stormwater Discharge Permit (5 CCR 1002-61) National Pollutant Discharge Elimination System (NPDES) guidelines for stormwater quality (33 USC 1342) Section 107.25 (Water Quality) and Section 208 (Erosion Control) of the CDOT Standard Specifications for Road and Bridge Construction. Erosion Control and Stormwater Quality Guide (ECSQG), CDOT, 2002 5 CCR 1002-8 Surface Water Standards BLM Policies and Regulations See BLM Standards for Public Land Health (BLM 1997) See the Special Stipulations section in this appendix. Limits or Controls Stipulated Stormwater discharges must comply with all state and federal regulations. Discharge from the package sewage treatment plant would have to meet water quality standards in order to meet discharge permit requirements. See Standard 5 in BLM’s Standards and Guidelines in this appendix. Water Quality Standards for surface and ground waters include the designated beneficial uses, numeric criteria, narrative criteria, and anti-degradation requirements set forth under State law as found in (5 CCR 1002-8), as required by Section 303(c) of the Clean Water Act NPDES guidelines for stormwater quality, including obtaining a stormwater construction permit, would be followed during construction. All work performed on the project within the CDOT ROW would conform to Section 107.25 (Water Quality) and Section 208 (Erosion Control) of the CDOT Standard Specifications for Road and Bridge Construction. A Stormwater Management Plan would Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Construction • Prior to construction of the mains or tunnels under Big Salt Wash, the rock would be drilled and tested, and the competent rock overburden measured. There would be a minimum of 200 feet of competent bedrock overburden over the mains under Big Salt Wash. • Install and implement temporary BMPs for construction, including re-establishment of native vegetation. • Temporary BMPs would be implemented to reduce selenium concentrations and selenium loading in waterways and wastewater containment areas to downstream tributaries and ultimately the Colorado River. Sediment ponds should be designed to settle out sediment, for a specific water quality capture volume, as specified in the City of Grand Junction and/or Mesa County drainage criteria manuals. • Construction access to the site, for items such as haul roads, crane paths, and concrete washout areas, would be planned to minimize or avoid impacts to sensitive habitats. • To ensure water quality is maintained in streams when construction vehicles need to cross a waterway, temporary stream crossing would be designed and constructed. Construction of any specific crossing method shall not cause a significant water level difference between upstream and downstream water surface elevations. Construction shall also not disturb or create a barrier in the stream channel during fish migration and spawning periods. • Temporary clear-water diversion structures would be implemented where appropriate permits have been obtained to perform work in a running stream or waterbody. Diversion structures would be constructed with minimal water quality impacts. The construction impacts of diversion structures on streams shall be minimized by scheduling operations during low-flow periods and avoiding fish migrations and spawning periods. • Concrete washout area applicable to highway improvements would be constructed at the improvement site(s) with the following specifications: o Suitable locations within the ROW would be set aside for a concrete truck wash-out area. o A pit with sufficient capacity to hold all anticipated wastewaters would be constructed at least 50 feet away from any Operator-Proposed Features to Mitigate Impacts The mining operation could impact the surface drainage system by increasing the sediment load in the streams. This impact would be mitigated by passing runoff through sediment ponds or some other form of alternative sediment control. Mine water discharge could impact the surface drainage system by mixing mine water with surface water. Mine water is typically high in total dissolved solids (TDS) relative to surface water so mixing mine water with surface water would be expected to increase the TDS of the resultant mix. However, the surface water in the permit and adjacent area has elevated TDS so mine water discharge may not elevate TDS concentration in the surface water. In the event that contamination, diminution, or interruption in the underground or surface water supplies result from coal mining operations, the following protective measures would be followed. 1. Adequate protection of water rights would be monitored. The Operator has designed and implemented a complete hydrologic monitoring program. 2. Adequate protection of water rights is ensured by regular monitoring and quick repair of subsidence induced problems. 3. Possible alternative sources of water would be utilized, if required. The Operator has a 3.0 cfs absolute water right for industrial and domestic uses on Mack Wash near the town of Mack. The Operator would pump water from Mack Wash to the mine site. Excess water from the Mack water right can be used as an alternative water supply. The above discussion indicates three ponds may be affected by the mine operation. Therefore, the excess water from the mine should provide an adequate quantity of alternative water. The table showing the quality of water from Mack Wash is presented in Volume III, Tab 3. Mack Wash near Mack shows perennial flow during the period of record. Mean monthly conductivity measurements vary between 1,410 umhos/cm in September to 3,920 umhos/cm in November. Based on conductivity measurements alone, this water supply is similar to the surface water in East Salt Creek and Big Salt Wash. Thus, the alternative water supply is of a quality similar to the water being replaced. The East Salt Wash and Big Salt Wash alluvium would be protected from the effects of subsidence. Coal Gulch alluvium would be protected.

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B-22

Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated be developed that would detail the BMPs to be used for construction. Practices from the Erosion Control and Stormwater Quality Guide (ECSQG), CDOT, 2002 are outlined below. The City of Grand Junction and Mesa County have Drainage Criteria Manuals addressing similar BMPs can also be referenced. • Adjacent disturbed slopes would be revegetated with native plant species to protect exposed soils from erosion. • Where temporary or permanent seeding operations are not feasible due to seasonal constraints, mulch or other CDOT-approved methods of stabilization would be applied to protect soils from erosion. • Erosion control blankets and ditches would be used as appropriate on newly seeded slopes to control erosion and promote the establishment of vegetation. Temporary berms would be given priority consideration for protecting the sensitive areas in the project area. Additional erosion control measures, Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements state waters, and the bottom of the pit would be at least 5 feet higher than groundwater. o The area would be signed as a concrete wash-water clean-out area and the access road leading to a paved road or highway shall have a stabilized construction entrance as detailed in the Erosion Control and Stormwater Quality Guide. Non-structural BMPs, such as pesticide and fertilizer application guidelines, anti-icing and de-icing guidelines, would be employed to improve water quality in conjunction with BMP implementation. Other non-structural BMPs such as water quality signage adjacent to the receiving streams and irrigation ditches, are examples of other tools that shall be considered for implementation. To mitigate recreation impacts within the project area, heavy equipment from the construction of the railroad spur could be used to dredge out Mack Mesa, and to potentially construct a sediment-settling pond between the Government Highline Canal and the inlet to Mack Mesa Lake. (CDOW) A storm water permit and storm water pollution prevention plan detailing BMPs is required for surface disturbance greater than one acre, (BLM) Stream crossings by the proposed railroad spur and transmission lines would require the use of BMPs to reduce erosion, sedimentation, and loading of selenium and salts to waterways. (CDOW) Operator-Proposed Features to Mitigate Impacts

•

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•

Surface Water Quality • Permanent BMPs would be used where practical for use during the construction phase to improve the water quality control at the site to minimize erosion, sedimentation, and loading of selenium and salts to waterways. • Permanent BMPs would be implemented to reduce selenium concentrations and selenium loading in waterways and sediment ponds to prevent increased concentrations to downstream tributaries and ultimately the Colorado River. Diversion ditches and sediment ponds should be designed to control runoff and prevent the release of high concentrations of selenium to the receiving water bodies. • Bridges would be installed to decrease further aquatic and riparian impairment created by stream crossings. Diversion ditches and sediment ponds would be designed to control runoff and prevent the release of

B-23

Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated such as silt fences and erosion bales, can be implemented, but with care and not as the sole erosion control system at the construction site. Erosion logs and bales would be certified weed-free of noxious weeds. Erosion logs and bales can be used as sediment barriers and filters along the toeof-fills adjacent to water surface waterways and drainages, and at the cross-drain inlets where appropriate with additional reinforcement and in conjunction with other erosion control measures, such as temporary berms. Where appropriate, silt fences can be used to intercept sediment-laden runoff before it enters a water body, such as a wetland, only when they are used in conjunction with other erosion control measures such as temporary berms. Where appropriate, slope drains would be used to convey concentrated runoff from the top to the bottom of disturbed slopes. Slope and cross-drain outlets would be constructed to trap sediment. Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements high concentrations of selenium to the receiving water bodies. • Under the federal regulations, rail tracks are not required to be covered by a stormwater permit, and are not required to implement BMPs. However, the UPRR has emergency response procedures to address spills and derailments.. • BMPs to reduce/prevent increased selenium concentrations to downstream tributaries during temporary construction and long-term, permanent operations of the mine by stabilizing severely eroding stream channels, limiting surface-disturbing activities to the extent practicable, protecting municipal watersheds, and installing bridges with proper drainage features (e.g., downspouts with riprap at the end that daylights) for project stream crossings to decrease aquatic and riparian impairment. • Inlet and outlet protection would be considered as part of the long-term mitigation for culverts. • BMPs should be implemented to reduce selenium concentrations and selenium loading in waterways and wastewater containment areas. (CDOW) • Implement BMPs such as the use of silt fences, berms, catch basins, seeding, mulching, and erosion control netting to minimize construction run-off. (CDOW) • Surface water quality from waters that may be impacted from any activities associated with the project should be monitored and assessed to develop baseline criteria for future comparison. (CDOW) • The wash bay/coal wash plant/ washout area should be located at least 300 feet from any waterway. (CDOW) Other • No subsidence would occur under Big Salt Wash and other perennial waters and springs. (DRMS) Operator-Proposed Features to Mitigate Impacts

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B-24

Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated • Check dams would be used where appropriate to slow the velocity of water through roadside ditches and swales. CAM’s existing water rights on Mack Wash are administered in the Colorado Division of Water Resources (Office of the State Engineer) priority system, in accordance with the Prior Appropriation Doctrine of first-in-time, first-in-right. Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Operator-Proposed Features to Mitigate Impacts

Water Rights

Colorado Division of Water Resources (Office of the State Engineer)

If CAM needs to utilize water out of priority, it would file an application with the Water Court, Water Division 5 (Colorado River and White River Basins) explaining exactly where the water would be obtained, where water would be used, what it would be used for, how much would be used, the source of augmentation water, when and where augmentation water would be required, and how the augmentation plan would be operated (Colorado Division of Water Resources 2008).

• • • •

Map Code 2, non-jurisdictional dam. Located southwest of permit boundary. Sediment ponds located on the mine site could reduce the amount of water available for this pond. Operator may need to supplement flow to this pond. Map Code 19, non-jurisdictional dam. Located south of permit boundary. Sediment ponds located on the mine site could reduce the amount of water available for this pond. Operator may need to supplement flow to this pond. Map Code 20, non-jurisdictional dam. Located within the permit boundary. Sediment ponds located on the mine site would reduce the amount of water available for this pond. Operator may need to supplement flow to this pond. The United States Fish and Wildlife Service (USFWS), considers any consumptive use of water by the mine to deplete the flow in the Colorado River. Water depletions in the Upper Colorado River Basin have been recognized as a major source of impact to endangered fish species (USFWS 2/93). The Operator would implement the conservation measures that the USFWS believe are necessary to offset this impact.

Floodplains

Colorado Conservation Board Colorado Department of Natural Resources Rules and Regulations for Regulatory Floodplains in Colorado

See the Special Stipulations section in this appendix.

Colorado Conservation Board Colorado Department of Natural Resources Rules and Regulations for Regulatory Floodplains in Colorado provides standards for activities that may impact regulatory floodplains in Colorado

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Vegetation

Reclamation standards for disturbance Impacts to vegetation would be reduced by implementing a reclamation plan that includes, among other best management practices, seeding native herbaceous and woody species immediately after the most intense disturbances have been completed. The

See Standard 3 in BLM’s Standards and Guidelines in this appendix.

•

Temporary impacts from construction could be mitigated through the use of Best Management Practices (BMPs) and other mitigation measures described for Surface Water, as well as following local floodplain management regulations. By implementing specific temporary and permanent best management practices for construction activities and long-term facility operations, impacts to floodplains would be minimized. No longwall or full extraction mining would occur under Big Salt Wash under the Proposed Action. By implementing specific temporary and permanent BMPs for construction activities and long-term facility operations, impacts to floodplains and alluvial valley floors would be minimized. Because of the predominance of weedy species in much of the study area, it is likely that construction equipment would pass through weed-infested areas on the way to work sites. In the short term, weeds along any potential access route should be controlled prior to entry of work-related equipment and all equipment should be regularly power-washed when moving between sites. For the longer term, the proponent would need to provide a long-term Integrated Weed Management plan to address weed issues on both private and federal surfaces. This plan should include periodic inventories, prompt treatment of discovered weeds, and long-term maintenance control. The proponent would need to coordinate with the BLM

• •

An effective cover of non-noxious, quick-growing annual and perennial plants, would be seeded or planted during the first appropriate growing season after removal. See Mine Revegetation Plan, Noxious Weed Plan, and Revegetation Success Monitoring Plan in this appendix.

B-25

Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations existing abundance of exotic invasive species throughout much of the study area means that any surface disturbing activity would likely be colonized first by these exotics, absent any measures to reduce this risk. If weed colonization and dominance results, it may reduce the effectiveness of any plan for restoring these disturbed areas to healthy stands of native vegetation. BLM Standards for Public Land Health (BLM 1997) See the Special Stipulations section in this appendix. Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Weed Management Specialist to help develop the plan for federal surfaces within the project area. For project areas on private surface, the mitigation measures such as monitoring and treatment would fall within the jurisdiction of Mesa County. Mesa County suggests that weed-free seed mixes be used to control noxious weeds. Coordination among all three entities would ensure that effective and collaborative weed management took place as a result of implementation of the proposed action. The plan would also ensure compliance with local, state and federal regulations. An aggressive reclamation plan for reestablishing desirable vegetation would help mitigate the establishment of undesirable species. As an example of one component of such a plan, an approved seed mix of desirable species should be applied immediately after an access road has been developed. The verges and center of the access road, as well as any areas of cut-and-fill, should be treated with this seed mix. In this manner, if weather conditions arise that are conducive to seed germination and establishment, there would be seeds of desirable species in place at this time. In addition to promoting establishment of native species, vegetated roadside verges would aid in controlling runoff and erosion. Re-seeding and weed control should be continued as necessary, and at least annually, until the dominant species of each vegetation association in restored areas reaches 80 percent of the pre-disturbance condition of desirable species for the site. Reclamation standards on private surface should conform to the wishes of the landowner. Reclamation may be enhanced by off-site weed control and native species seeding practices prior to any surface disturbing activities. Such practices may further help to reduce the threat of weeds becoming the dominant vegetation within the project development areas. A unique seed mix should be identified for each vegetation association impacted by project activities. In areas with abundant well-developed soil biological crusts (i.e., those dominated by lichens), in particular along the route of the railroad spur north of the Highline Canal, these crusts should be removed, stored and kept dry prior to any surface disturbing activities. A survey to clearly demarcate these areas should be performed prior to any surface disturbing areas. It is estimated that the area of well-developed crusts comprises not more than 1 acre in total area. Operator-Proposed Features to Mitigate Impacts

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B-26

Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements As soon as the soils within these identified project areas have been recontoured and stabilized, the salvaged crusts should be redistributed on the affected surfaces, perhaps simultaneously with an appropriate native seed mix. Traditional land recontouring and topsoil redistribution can result in soil homogenization that is not conducive for successful reestablishment of many native species. Thus, reclamation practices that promote soil heterogeneity at the meter-scale should be included in any reclamation plans. Such practices may include small pits, surface armoring and other types of features that result in localized capture of nutrients and water. Weed-free seed mixes would be used to control noxious weeds. (Mesa County) Include Wyoming big sage, greasewood, shadscale saltbush, and gardner saltbush in the seed mix and remove crested wheatgrass from the seed mix. CDOW generally believes crested wheatgrass should be used because this is a harsh site and crested is more likely to compete with cheatgrass than a native-only seed mix. (CDOW) Degradation of both jurisdictional and nonjurisdictional wetland habitats should be mitigated. (CDOW) The aggressive application of reclamation and weed management plans that include the above suggestions should result in at least partial mitigation of vegetation losses directly caused by the proposed project. Offsite weed control and native plant seeding could result in enhanced native vegetation cover and productivity compared to current vegetation status. BMPs should be adhered to in wetland and riparian areas that may be impacted through project construction activities, i.e., water diversion structure construction, and the construction of transmission lines and pipeline corridors. (CDOW) Installation of the diversion structure should consider bank stabilization to prevent further riparian and stream bank degradation, and erosion. (CDOW) A vegetation and treatment plan should be considered to minimize further invasion and spread of noxious weeds. (CDOW) Any riparian or upland disturbance should be revegetated with native plants and grasses. (CDOW) Post-project monitoring surveys of macroinvertebrates and fishes should be completed to evaluate impact of the diversion structure. (CDOW) Operator-Proposed Features to Mitigate Impacts

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Wetlands and Riparian

Section 404 of the Clean Water Act (33 USC 1344)

• •

See the Special Stipulations section in this appendix. BLM Standards for Public Land Health (BLM 1997)

See Standard 2 in BLM’s Standards and Guidelines in this appendix. Mitigation would be provided in accordance with U.S. Army Corps of Engineers (USACE) standards. Temporary impacts would be mitigated by application of standard erosion/ sedimentation control measures. Wetland mitigation and monitoring would be performed in accordance with an approved USACE permit, not yet submitted. It is likely that the project would qualify for Nationwide Permit (NWP) #12, Utility Line Activities, since fill would be limited to less than the 0.5 acres allowed under NWP #12.

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An effective cover of non-noxious, quick-growing annual and perennial plants, would be seeded or planted during the first appropriate growing season after removal.

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B-27

Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Fish and Wildlife Laws and Authorities Colorado Division of Wildlife Guidelines: Wetland Wildlife Conservation Program Wetland Wildlife Conservation Statewide Goals and Strategy BLM Policies and Regulations See the Special Stipulations section in this appendix. Limits or Controls Stipulated • Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Avoiding construction during the prairie dog breeding season between March 1 and June 15 would reduce impacts to prairie dogs inhabiting railroad spur crossings or adjacent areas. Young and adults would be more mobile after June 15 and able to relocate themselves to avoid construction equipment. By avoiding construction within 150 feet of prairie dog colonies inhabited by burrowing owls from March 15 to August 31, disturbance to potential nesting owls would be minimized and consequently would reduce impacts to burrowing owl populations (CDOW 2008). The CDOW recommends no surface occupancy within 0.25 mile of active golden eagle nests, and no human disturbance within 0.5 mile of an active golden eagle nest from December 15 to July 15 (CDOW 2008). The CDOW recommends no surface occupancy within 0.33 mile of active red-tailed hawk nests, and no human disturbance within 0.5 mile of an active red-tailed hawk nest from February 15 to July 15 (CDOW 2008). Wildlife-vehicle collisions could be reduced by placing speed limits of 35 mph on all access roads and restricting use of roads traversing winter range areas to essential personnel. By implementing proper drainage and sediment control measures, avoiding construction during the spawning and immediate post spawning season (March 1 to July 31) and timing construction activity during the low flow period, the effects on macroinvertebrates and native fishes would be minimized. Construction of water diversion structures that do not impede fish movement and placement of 0.25 inch screens on water intake devices to preclude entrainment of fish would reduce impacts to the native fishery. Limiting access to winter range areas between December 1 and March 1 could reduce impacts to wintering deer, elk and pronghorn. Losses to vegetative communities could be partially mitigated through the use of effective reclamation of disturbed areas and habitat enhancements. Immediate reclamation of all temporary access roads and staging areas used during construction in sagebrush habitats could help alleviate impacts to existing big game winter range. Habitat enhancements done in adjacent off-site areas could further offset winter range habitat Operator-Proposed Features to Mitigate Impacts Wildlife use of water in the permit and adjacent areas is for subsistence. Wildlife use the perennial streams and ponds. It is possible the mine could impact some of the ponds. If this impact occurs, the Operator would mitigate this water loss by constructing or repairing pond(s) and augmenting the flow with water from the mine water supply line. A large portion of the coal mine waste disposal area would be constructed on and against a steep Mancos shale slope. Revegatation of this area would improve the wildlife habitat since a nearly bare Mancos shale slope would become vegetated area capable of producing food and forage for wildlife. There would be a waterline that runs from Mack to the mine site. The Operator agrees to work with the CDOW to build waterholes at strategic locations. See Mine Reclamation Plan in this appendix.

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B-28

Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements lost during project construction. With adequate reclamation for disturbed areas and off-site habitat enhancement, loss of sagebrush habitat is not likely to affect the total population numbers of wintering deer, elk and pronghorn in this area. Mitigation for wildlife corridors or bottlenecks. (BLM) Winter range improvements. (BLM) Netting would be placed over open wastewater containment areas to preclude exposure of migratory birds to increased selenium concentrations, as well as any hazardous materials, especially petroleum products. (CDOW) Screens of 0.25 inch aperture should be placed on water intake devices to preclude entrainment of native fishes. (CDOW) BMPs should be adhered to during construction of the diversion structure. (CDOW) Water depletion and any construction in-channel or within the riparian zone should occur during the irrigation season, when surplus water from upstream irrigation practices and releases from Highline Lake are maximized. (CDOW) Within this irrigation season (usually April 1 – November 1), water depletion and/or construction activities should be avoided during the native fishes spawning and immediate post-spawning seasons (March 1 through July 31). (CDOW) Increased sedimentation from construction activities and/or water depletion should be minimized. (CDOW) BMPs for sediment control should be implemented during construction. (CDOW) Continue with seasonal restriction on construction as proposed. (CDOW) Actions to minimize the adverse impacts of project development to these species [Northern leopard frog, longnose leopard lizard, and midget-faced rattlesnake] and other sympatric amphibians and reptiles should be implemented. (CDOW) Transmission line poles should be raptor-safe and raptor-proof. Install raptor perch deterrents on power poles. (CDOW) CDOW raptor standards should be followed: No surface disturbance within 1/4 mile of golden eagle nests, and no human disturbance within 1/2 mile of an active nest form Dec 15 to July 15 (CDOW 2008). For red-tailed hawk nests no surface occupancy within 1/3 mile of the nest year round and no human Operator-Proposed Features to Mitigate Impacts

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements encroachment within 1/3 mile of active nests from February 15 through July 15 (CDOW 2008). For northern harriers 1/4 mile buffer from April 15 to August 15. (CDOW) In areas where the railroad spur would be elevated above ground level place culverts at ground level to facilitate safe movement of kit fox and their prey including prairie dogs, place in areas where the railroad spur would intersect prairie dog towns in addition to other areas. (CDOW) Include two crossing areas for deer and elk to cross the coal conveyer line. (CDOW) Water should be distributed for pronghorn use. (CDOW) The railroad should be bermed for pronghorn crossings. (CDOW) Shift the railroad spur to the western periphery of the prairie dog town that includes burrowing owl colony #11. (CDOW) For burrowing owl colony #12 do not place any amenities within ½ mile of the location. (CDOW) Additional water sources should be provided for wildlife. Create 3 water developments on the north and 3 water developments on the south of the rail line for pronghorn use. Create a pond to replace the pond near the load-out facility for bat use, locate it within the same radius from the Bookcliff front as the current pond. Place a water guzzler between the Mesa/Garfield County line and waste rock area to mitigate the impacts to chukar. (CDOW) Pre-construction surveys of the selected transmission line route would be conducted in order to apply mitigations and avoidance on federal lands. Surveys would be conducted for federal listed, BLM sensitive, and CDOW listed species. BLM would require the Applicant to provide signs or construct gates if they are needed to discourage unauthorized travel along the transmission line route. BLM would require raptor perch deterrents on transmission line structures. BLM would stipulate surveys and mitigation for wetland, surface water, and riparian areas as part of the coal lease. Natural spawning of flannel-mouth suckers occurs in Salt Creek (Martin 2007). Activities that could adversely impact the flannel-mouth spawn would be avoided from March 1 to July 31. Operator-Proposed Features to Mitigate Impacts

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B-30

Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Threatened and Endangered Species Laws and Authorities Endangered Species Act (16 USC 1531-1544) BLM Policies and Regulations BLM Standards for Public Land Health (BLM 1997) See the Special Stipulations section in this appendix. Limits or Controls Stipulated See Standard 4 in BLM’s Standards and Guidelines in this appendix. Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements Endangered and Sensitive Fish Species • Because the project involves water depletions to the Upper Colorado River system, formal consultation would be required under Section 7 of the Endangered Species Act for impacts to the four endangered Colorado River fishes. Mitigation would be governed by the programmatic biological opinion for minor water depletions in the Upper Colorado River Basin, #ES/GJ-6-CO-94-F-017 (June 13, 1994) and would involve a one-time payment to the Upper Colorado River Recovery Program. • Best Management Practices to contain and reduce sediment discharge into Mack Wash and other drainages would minimize impacts to aquatic species. Netting would be placed over open wastewater containment areas to preclude exposure of migratory birds to increased selenium concentrations, as well as any hazardous materials, especially petroleum products. Bridges would be installed to decrease further aquatic and riparian impairment created by stream crossings. • Construction of water diversion structures that do not impede fish movement and placement of 0.25 inch screens on water intake devices to preclude entrainment of fish would reduce impacts to the native fishery. • Withdrawing water during the irrigation season at high flows and storage of water for later use during low flows periods and during fish spawning would reduce water depletion impacts to the fishery. Grand Buckwheat • Given the lack of definitive evidence that there would be, or would not be, significant project impacts on Grand buckwheat, a number of practices should be implemented in order to minimize and/or mitigate these potential impacts. These practices include: o Collect seeds each fall prior to and during the project, to be stored and used during reclamation and revegetation following project completion. o Separate and reserve the top 1 to 3 inches of soil from areas of Grand buckwheat density at the initiation of ground disturbing activities. This volume of soil would contain the seed bank. Since the longevity and viability of Grand buckwheat seeds is unknown, this practice may result in more useful seeds. Separating and reserving the top 12 inches of soil dilutes the seedbank and thus does not serve as an adequate mitigation practice. Operator-Proposed Features to Mitigate Impacts Prairie dog towns should be surveyed on two consecutive mornings for burrowing owl presence if a prairie dog town is to be disturbed between March 1 and October 31. The revegetation plan would establish a diverse, effective and permanent vegetative cover of similar seasonal variety as that native to the area The final reclamation plan is designed to enhance habitat through the establishment of shrubs on all reclaimed acreage. However, because erosion control would be of paramount importance on steeper slopes, grasses would be encouraged in these areas. Water depletions in the Upper Colorado River Basin have been recognized as a major source of impact to endangered fish species. The Operator agrees to implement the conservation measures that the USFWS believes are necessary to offset the water depletion impact. See Mine Reclamation Plan in this appendix.

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Appendix B Standard Practices and Mitigation Measures
Table B-1 APPLICABLE LEGAL AND POLICY REQUIREMENTS AND MITIGATION MEASURES BY RESOURCE
Resource/Issue Laws and Authorities BLM Policies and Regulations Limits or Controls Stipulated Additional BLM/Cooperating Agency Recommended Mitigation and Enhancements o Aggressively control weeds in areas of potential habitat. During the baseline study it was found that Grand buckwheat was absent from plots with greater than 50 percent cover of cheatgrass or where two or more weeds each comprised over 3 percent cover. o Investigate whether Grand buckwheat individuals tolerate disturbance and regenerate from broken branches as do some other species in the genus. o Investigate whether Grand buckwheat individuals can be successfully transplanted by digging up and moving some individuals that are found within the proposed project disturbance area. o Perform follow up monitoring adopting the sampling protocols of the baseline study (WestWater 2007). Those study plots should be relocated and sampled periodically to identify trends in the population numbers. It may be necessary to identify additional plots if an objective is to assess whether trends in abundance in the fragmented areas differs from trends in the larger, intact occupied habitat areas. Other Species • Impacts that could affect potential prey base for the black-footed ferret could be reduced by avoiding construction during the prairie dog breeding season between March 1 and June 15. This would reduce impacts to prairie dogs inhabiting railroad spur crossings or adjacent areas. Young and adults would be more mobile after June 15 and able to relocate themselves to avoid construction equipment. Operator-Proposed Features to Mitigate Impacts

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Appendix B Standard Practices and Mitigation Measures
2.0 Mine Reclamation Plan

The areas disturbed by the mine facilities will be returned to a rangeland and wildlife habitat land use. This will be accomplished by restoring the area to the approximate original contour. Surface areas will be covered with topsoil and seeded with the approved seed mix. Reclamation work will be initiated when the mine reserves are depleted or when the operator, with approval from BLM deems the mine to no longer be an economically viable operation. Reclamation of the site might take four years. The first year would be set aside to salvage and sell assets. The second year would involve the removal of buildings and structures from the site. The third and fourth year would be used to grade the disturbed area to approximate original contours, place topsoil on the regraded area and seeding the area with the approved seed mix. A detailed estimate of the cost of reclamation of the proposed mine and mine facilities are presented in Section 3.05 Performance Bond Requirements. The mine facilities area, haul road and utility corridor were designed using a proximate balanced cut and fill technique. To reclaim the areas to approximate original contour, the fill placed on the outslopes must be returned to the cut slopes. Reclaimed areas will be compacted to at least 95 percent of the maximum dry density attained in a laboratory compaction test in accordance with American Society for Testing Materials (ASTM) D698 with moisture content +/-2 percent of optimum. Reclaimed slopes constructed of weathered shale will be stable (FS >1.5) at slope inclinations of up to 1.5H:1V. Reclaimed slopes constructed of overburden (non weathered shale will be stable) (FS >1.5) at slope inclinations of up to 1.75H:1V. The 65.2 acre phase I coal mine waste pile has 3.7 inches of topsoil available to be replaced. There are 140,000 cubic yards of subsoil available in stockpile. This subsoil stockpile will be used to finish to top of the coal mine waste pile. Subsoil for the remainder of the pile will be salvaged contemporaneously. As each 50 foot (ft) lift is complete it will be plated with 44.3 inches of subsoil obtained from subsoil map unit E. This material will be salvaged from the founding of the coal mine waste pile. The slopes and benches on the coal mine waste pile are 43.4 acres in aerial extent. A total of 248,000 cubic yards will need to be salvaged contemporaneously over the 51 acres of subsoil map unit E and placed on the slopes and benches of the pile. This equals an average depth of 36.2 inches that needs to be salvaged contemporaneously from the coal mine waste pile founding. The top of the coal mine waste pile will be covered with the material from the coverfill stockpile to finish the reclamation work. The coverfill stockpile will have approximately 65,000 cubic yards of good quality Map Unit A material and 75,000 cubic yards of lesser quality material. The coverfill material will be placed in two layers on top of the pile. The first layer will be approximately comprised of the lesser quality material. The second layer will be comprised of the good quality Map Unit A material. The top of the coal mine waste pile encompasses 21.8 acres. The subsoil in the coverfill stockpile will plate the top of the pile 47.8-inches deep. Thus there is a little extra coverfill to supplement the slopes. Since the coal mine waste pile founding slopes to the south, the founding will be exposed on the north end of the pile as coal mine waste is placed on the south end of the pile. This will facilitate the salvage of subsoil north of the B-33

Appendix B Standard Practices and Mitigation Measures
active area as the coal mine waste pile is being constructed. The Postminig Topography Map 17 series is presented in Volume II along with the Postmining and Premining Cross Sections Map Nos. 19-1 & 19-2. The slope inclinations of the reclaimed surfaces shown on the postmining cross sections are typically flatter than 1.5H:1V. Therefore, the reclaimed area should have a factor of safety greater than 1.5. There are numerous areas where steep slopes will be backfilled during the operational phase of the project. The integrity of the steep slopes will not be affected by the backfilling and removal of the backfill during reclamation. The steep slopes do not need to be restored during reclamation. The steep slopes only need to be uncovered to establish previously stable configurations. Large rocks and rock piles will be randomly placed throughout the reclaimed areas to provide small wildlife habitat. During reclamation operations topsoil will be placed on regraded areas in an approximate uniform, stable thickness. Topsoil stockpile 2 contains 82,180 cubic yards and will be spread over 129.4 acres which will provide an approximate uniform stable thickness of 4.7- inches. Topsoil stockpile 2 contains 32,860 cubic yards and will be spread over the 65.2 acre coal mine waste pile which will provide an average replacement depth of approximately 3.7-inches. The self-sustaining vegetation is appropriate for the postmining land use of rangeland and wildlife habitat. The regraded and topsoiled surface will reestablish the surface water drainage system by returning the area to the approximate original contours. The regraded surfaces will be ripped if necessary to relieve compaction and to provide for root penetration. Topsoil will be placed and spread with either scrapers or a front end loader and truck equipment spread. The topsoil will be spread with a track dozer. Handling topsoil in such a manner will minimize deterioration of the biological, chemical, and physical properties of the topsoil and will prevent excess compaction and contamination of the topsoil. Topsoil will not be handled when saturated either during the initial stripping, spreading or final grading. Handling sticky or plastic soils in a saturated state will reduce the quality of the topsoil by degrading the physical characteristics.

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3.0

Mine Revegetation Plan

Schedule of Revegetation The schedule of revegetation for the majority of the disturbed areas is not possible to predict. When the mine is no longer an economically viable operation, it will be reclaimed and revegetated. The time frame for the revegetation could vary from as little as five years to more than fifty years. Topsoil stockpiles, cut slopes and other disturbed surfaces associated with the mine construction will be revegetated during the first available planting season typically October 15th to November 15th. Seed Mix The revegetation objective is to establish on all disturbed land within the mine plan area a diverse, effective and permanent vegetative cover of similar seasonal variety as that native to the area. The seeded vegetative cover will be comprised of native species that are desirable and necessary to achieve the approved postmining land use. Three seed mixes will be used for the revegetation work, one for temporary soil stabilization and two for final reclamation purposes. The first seed mix (SM-1) will be a soil stabilization mix used for the interim reclamation of topsoil stockpiles, cut and fill slopes and other disturbed surfaces associated with the mine construction. As indicated by the two proposed permanent seed mixes, (SM-2 & SM-3) the establishment of shrubs will be attempted on all reclaimed acreage. However, because erosion control will be of paramount importance on steeper slopes, grasses will be encouraged in these areas and relief from a restrictive woody plant density standard will be necessary. Seeding rates that are listed are drill seed rates which will be increased for areas that must be broadcast seeded.

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Appendix B Standard Practices and Mitigation Measures
The three seed mixes are as follows: Table SM-1 STABILIZATION (TEMPORARY) SEED MIX
Species Common Name Rate PLS/AC 4 4 4 4 16 Seeds/Lb -1000 156 110 154 159 Seeds per Sq Ft 14.33 10.1 14.14 14.6 53.17 Percent GRP 26.94 19.00 26.60 27.46 100.00

GRASSES Elymus lanceolatus ssp. Streambank Wheatgrass psammophilus (Sodar) Pascopyrum smithii Western Wheatgrass (Arriba) Elymus lanceolatus ssp. Thickspike Wheatgrass lanceolatus (Critana) Slender Wheatgrass (Primar) Elymus trachycaulus ssp, trachycaulus Rates listed above are for drill seeding; for broadcast seeding rates should be doubled

Table SM-2 RED CLIFF PROJECT – SUGGESTED REVEGETATION SEED MIX FOR TOPSOILED AREAS TARGETING GRAZINGLAND LAND USE – 2007 *
Preferred Variety Arriba Trailhead Site Collected Viva Paloma PLS lbs/ac 2.00 1.50 2.00 1.00 0.50 PLS / ft2 5.1 3.3 11.7 3.7 2.2 % PLS by Seeds/ft2 5.4 3.5 12.4 3.9 2.3

No. 1 2 3 4 5

Common Name Western Wheatgrass Great Basin Wildrye Salina Wildrye Galleta Indian Ricegrass

Scientific Name Agropyron smithii Elymus cinereus Elymus salinus Hilaria jamesii Oryzopsis hymenoides

PLS / lb. 110,000 95,000 254,500 159,000 188,000

Comment Native - Fair Performer Native - Fair Performer Collect from site, not commercially avail. Native - Fair Performer Native - Fair Performer

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Appendix B Standard Practices and Mitigation Measures
Table SM-2 RED CLIFF PROJECT – SUGGESTED REVEGETATION SEED MIX FOR TOPSOILED AREAS TARGETING GRAZINGLAND LAND USE – 2007 *
Preferred Variety Salado PLS lbs/ac 0.50 0.75 8.25 2,770,000 58,500 293,000 610,000 592,000 500,000 0.10 0.50 0.25 0.30 0.25 0.25 1.65 2,500,000 52,000 64,900 56,700 0.10 0.75 0.50 0.75 2.10 12.00 PLS / ft2 10.6 30.3 66.7 6.4 0.7 1.7 4.2 3.4 2.9 19.2 5.7 0.9 0.7 1.0 8.4 94.24 % PLS by Seeds/ft2 11.3 32.1 70.8 6.7 0.7 1.8 4.5 3.6 3.0 20.4 6.1 1.0 0.8 1.0 8.9 100 If Conditions Correct, Will Respond Native - Excellent Performer Native - Fair Performer Performance under correct conditions Native - Fair Performer Native Native - Proven Performer Native - Showy, Proven Performer Native - Proven Performer Native - Fair Performer

No. 6 7 8 9 10 11 12 13

Common Name Sandberg Bluegrass Alkali Sacaton Forbs Western Yarrow Annual Sunflower Lewis Flax Palmer Penstemon Rocky Mtn. Penstemon Scarlet Globemallow Shrubs Wyoming Big Sagebrush Fourwing Saltbush Shadscale Winterfat

Scientific Name Poa secunda Sporobolus airoides Subtotal Achillea millefolium Helianthus annuus Linum lewisii Penstemon palmeri Penstemon strictus Sphaeralcea coccinea Subtotal Artemisia tridentata var wyo. Atriplex canescens Atriplex confertifolia Krascheninnikovia lanata Subtotal Total

PLS / lb. 925,000 1,758,000

Comment Native - Adapted to Skeletal Soils Native - Fair Performer

14 15 16 17

Alternative species which may be used as substitutes for secondary or tertiary species: Grasses Bottlebrush Squirreltail Sitanion hystrix 192,000 0.25 1.1 1.2

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Appendix B Standard Practices and Mitigation Measures
Table SM-2 RED CLIFF PROJECT – SUGGESTED REVEGETATION SEED MIX FOR TOPSOILED AREAS TARGETING GRAZINGLAND LAND USE – 2007 *
Preferred Variety PLS lbs/ac 0.50 0.10 0.10 1.00 1.00 1.00 0.50 PLS / ft2 0.8 5.7 2.8 1.4 2.6 9.2 0.3 % PLS by Seeds/ft2 0.8 6.1 3.0 1.5 2.7 9.7 0.3 Native - Fair Performer Native - Fair Performer Native - Fair Performer Native - Fair Performer Native - Fair Performer Native - Fair Performer

No. Forbs

Common Name Rocky Mtn. Beeplant Showy Evening Primrose Prairie Coneflower

Scientific Name Cleome serrulata Oenethera speciosa Ratibida columnifera Atriplex corrugata Atriplex gardnerii Chrysothamnus naseousus Ephedra viridis

PLS / lb. 65,900 2,500,000 1,230,000 60,000 111,500 400,000 25,000

Comment

Shrubs Mat Saltbush Gardner Saltbush Rubber Rabbitbrush Green Mormon Tea Spiny Hopsage

Grayia spinosa 166,800 0.50 1.9 2.0 Sarcobatus vermiculatus Greasewood 210,000 1.00 4.8 5.1 Primary Species - Should not be substituted for. Secondary Species - Should be in mix unless unavailable, or an alternate is more desirable for a given area. Tertiary Species - Recommended to be in mix as indicated, but may be substituted if desired. * The 12 lb/ac mix is designed for drill seeding (of grasses) and broadcasting (of forbs and shrubs) at Red Cliff. When broadcast or hydroseeding methods are used for all lifeforms, the rate for grasses should be increased 1.5 times and the seed must be placed prior to mulching.

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Appendix B Standard Practices and Mitigation Measures
Table SM-3 RED CLIFF PROJECT – SUGGESTED REVEGETATION SEED MIX FOR TOPSOILED AREAS TARGETING WILDLIFE HABITAT LAND USE – 2007 *
Preferred Variety Arriba Trailhead Viva Paloma PLS lbs/ac 0.40 0.40 0.40 0.40 0.40 2.00 2,770,000 58,500 293,000 610,000 592,000 0.10 0.50 0.50 0.30 0.25 1.65 2,500,000 52,000 64,900 111,500 400,000 0.35 1.50 2.00 1.50 0.50 PLS / ft2 1.0 0.9 1.5 1.7 8.5 13.6 6.4 0.7 3.4 4.2 3.4 18.0 20.1 1.8 3.0 3.8 4.6 % PLS by Seeds/ft2 1.1 0.9 1.5 1.8 9.0 14.4 6.7 0.7 3.6 4.5 3.6 19.1 21.3 1.9 3.2 4.1 4.9 If Conditions Correct, Will Respond Native - Excellent Performer Native - Fair Performer Native - Fair Performer Native - Fair Performer Native - Fair Performer Native Native - Proven Performer Native - Showy, Proven Performer Native - Proven Performer

No. 1 2 3 4 5 6 7 8 9 10

Common Name Grasses Western Wheatgrass Great Basin Wildrye Galleta Indian Ricegrass Sandberg Bluegrass Forbs Western Yarrow Annual Sunflower Lewis Flax Palmer Penstemon Rocky Mtn. Penstemon Shrubs

Scientific Name Agropyron smithii Elymus cinereus Hilaria jamesii Oryzopsis hymenoides Poa secunda Subtotal Achillea millefolium Helianthus annuus Linum lewisii Penstemon palmeri Penstemon strictus Subtotal Artemisia tridentata var wyo. Atriplex canescens Atriplex confertifolia Atriplex gardnerii Chrysothamnus naseousus

PLS / lb. 110,000 95,000 159,000 188,000 925,000

Comment Native - Fair Performer Native - Fair Performer Native - Fair Performer Native - Fair Performer Native - Adapted to Skeletal Soils

11 12 13 14 15

Wyoming Big Sagebrush Fourwing Saltbush Shadscale Gardner Saltbush Rubber Rabbitbrush

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Appendix B Standard Practices and Mitigation Measures
Table SM-3 RED CLIFF PROJECT – SUGGESTED REVEGETATION SEED MIX FOR TOPSOILED AREAS TARGETING WILDLIFE HABITAT LAND USE – 2007 *
Preferred Variety PLS lbs/ac 1.50 1.00 8.35 12.00 PLS / ft2 2.0 4.8 40.1 71.62 % PLS by Seeds/ft2 2.1 5.1 42.5 76

No. 16 17

Common Name Winterfat Greasewood

Scientific Name Krascheninnikovia lanata Sarcobatus vermiculatus Subtotal Total

PLS / lb. 56,700 210,000

Comment Performance under correct conditions Native - Fair Performer

Alternative species which may be used as substitutes for secondary or tertiary species: Grasses Salina Wildrye Alkali Sacaton Bottlebrush Squirreltail Forbs Rocky Mtn. Beeplant Showy Evening Primrose Scarlet Globemallow Prairie Coneflower Cleome serrulata Oenethera speciosa Sphaeralcea coccinea Ratibida columnifera 65,900 2,500,000 500,000 1,230,000 0.50 0.10 0.25 0.10 0.8 5.7 2.9 2.8 0.8 6.1 3.0 3.0 Native - Fair Performer Elymus salinus Sporobolus airoides Sitanion hystrix Salado 254,500 1,758,000 192,000 1.00 1.00 0.25 5.8 40.4 1.1 6.2 42.8 1.2 Preferred but Not Currently Available Native - Fair Performer

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Appendix B Standard Practices and Mitigation Measures
Table SM-3 RED CLIFF PROJECT – SUGGESTED REVEGETATION SEED MIX FOR TOPSOILED AREAS TARGETING WILDLIFE HABITAT LAND USE – 2007 *
Preferred Variety PLS lbs/ac 1.00 0.50 0.50 PLS / ft2 1.4 0.3 1.9 % PLS by Seeds/ft2 1.5 0.3 2.0

No. Shrubs

Common Name Mat Saltbush Green Mormon Tea Spiny Hopsage

Scientific Name Atriplex corrugata Ephedra viridis Grayia spinosa

PLS / lb. 60,000 25,000 166,800

Comment

Primary Species - Should not be substituted for. Secondary Species - Should be in mix unless unavailable, or an alternate is more desirable for a given area. Tertiary Species - Recommended to be in mix as indicated, but may be substituted if desired. * The 12 lb/ac mix is designed for drill seeding (of grasses) and broadcasting (of forbs and shrubs) at Red Cliff. When broadcast or hydroseeding methods are used for all lifeforms, the rate for grasses should be increased 1.5 times and the seed must be placed prior to mulching.

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Appendix B Standard Practices and Mitigation Measures
Planting and Seeding The seed mixture(s) will be drilled on level areas and on slopes which will permit machine work along the contour. On slopes which prevent safe or adequate machine work, the surface will be hydroseeded or broadcast seeded. Broadcast seeding will also be used for small isolated areas. Dozer tracking up and down steep slopes or other roughening techniques will be used before seeding to establish a better seedbed. On predominantly south and west facing steep slopes, the surface will be extensively roughened to provide for increased moisture retention and favorable micro sites for plant establishment. Seeding will be done in the fall after October 15th. Mulching Techniques The Operator currently does not plan to mulch except for steep slope embankments (such as road cuts/fills). Chisel plowing, terracing and/or contour furrowing would be utilized to stabilize, reduce compaction and increase the moisture retention capacity of regraded topsoiled areas. Spoil will be regraded to minimize long, uninterrupted slopes. Respreading of topsoil will be followed by chisel plowing and contour furrowing (as necessary). Irrigation and Weed Control Use of the planting and mulching methods specified above will result in satisfactory plant establishment, barring abnormally dry conditions. There are no plans to irrigate the reclaimed areas.

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Appendix B Standard Practices and Mitigation Measures
4.0 Noxious Weed Control Plan

The baseline vegetation survey presented in Volume III, Exhibit 5 identified two noxious weeds on-site. They are Salt Cedar (Tamarisk) and Jointed Goatgrass. Garfield County lists both Salt Cedar and Jointed Goatgrass as noxious weeds. Mesa County does not list Jointed Goatgrass as a noxious weed. Mesa County lists Salt Cedar as a noxious weed “preferred to be controlled” rather than mandatory. If noxious weed infestations occur at levels which may interfere with successful revegetation or are detrimental to stand quality, weed control using herbicides will be implemented. If cheat grass invades topsoil piles or other disturbed areas it will be controlled with Roundup. Spraying will be done by use of a backpack spray system or an ATV-mounted spray tank. Salt Cedar will be controlled by mechanical removal or by cutting the stem and applying herbicide (known as the cut-stump method). Individual tamarisk plants will be cut as close to the ground as possible and herbicide will be applied immediately thereafter to the perimeters of the cut stems. The herbicides used will be triclopyr (e.g., Garlon4 or PathfinderII) or imazapyr (Arsenal). Fall treatments are believed to be most effective because the plants are translocating materials to their roots. Jointed Goatgrass will be controlled with the chemical Glyphosate sulfometuron+chlorsulfuron (Landmark) spayed in accordance with the manufacture’s recommendation. In permanently vegetated areas where cheatgrass is a detriment to successful vegetation, the cheatgrass will be treated with a mix of 6 ounces of Plateau and 2 ounces of Roundup per acre in the fall. This treatment will be repeated the following year without using Roundup. The treated areas will then be interseeded with a permanent seedmix after the soil is scarified by using an ATV mounted spike tooth harrow if required to ensure minimal damage to the mature shrub overstory. Additional weed control may include control of any type of vegetation which may grow around substations, buildings, conveyors, within 100 feet of mine portals, and other areas where vegetation may present a fire hazard. The Operator commits to performing aggressive weed control during the operations and reclamation phases of the operation. Persons who perform weed control on BLM managed lands will be licensed.

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Appendix B Standard Practices and Mitigation Measures
5.0 Revegetation Success Monitoring Plan

Initially, revegetation success will be qualitatively evaluated during routine inspections of the reclaimed sites. These evaluations shall include assessments of noxious weeds, species diversity and the general health of the vegetation. Results of these evaluations will be included in the annual reports. 5.1 Determining Revegetation Success: General Requirements and Standards

The success of revegetation at the Red Cliff project shall be determined by comparison to established reference areas (RA) as allowed by Rule 4.15.7 (3). During the summer of 2006, four reference areas were selected to represent the four major vegetative communities to be disturbed. These communities included: Salt Desert Shrub (933 acres or 49.5 percent of the study area), Juniper Scrub (437 acres or 23.2 percent of the study area), Sagebrush (355 acres or 18.8 percent of the study area), and Greasewood (126 acres or 6.7 percent of the study area). The remaining 1.8 percent of the study area was due to minor, disclimactic communities. The four reference areas are 12.7, 6.8, 11.4, and 7.0 acres in size, respectively. These reference areas were sampled for herbaceous cover, herbaceous production, and woody plant density in 2006. Species diversity was determined utilizing herbaceous cover data from the premining baseline inventories of the various communities. Sample adequacy testing was performed on both the pre-mine and reference area data to insure that representative cover and production data had been obtained at the appropriate confidence level. Where necessary, the mean, variance and number of observations for the pre-mine and reference area data were used to perform t-tests on the cover and production data to insure that there were no significant differences at the 90 percent level of confidence between the respective sets of cover and production data. However, in certain instances (primarily due to the influence of annual vegetation such as cheatgrass and Russian thistle), such testing became problematic. Therefore, an alternate procedure as explained below was utilized to compensate. This alternate procedure is excerpted directly from the vegetation baseline evaluation (Volume III, Exhibit 5 Section 6.0). Section 6.0 – Discussion & Recommendations for Bond Release Standards A total of six vegetation communities were identified from the pre-disturbance Red Cliff Mine permit area: 1) Salt Desert Shrub, 2) Juniper Scrub, 3) Sagebrush, 4) Greasewood, 5) Annual Grassland, and 6) Perennial Grassland. Of these, only the first four occupy significant acreage within the permit area and are late seral communities. Both grassland areas are small representations of early seral or disclimactic stages of late seral types. The Annual Grassland area is a strongly disclimactic early seral subtype of the Salt Desert Shrub community. The small area of Perennial Grassland exists because of a reasonably recent fire that removed the overstory (greasewood and/or sagebrush) of the late seral community. Given these circumstances, reference areas were established for each of the four major vegetation communities to facilitate future revegetation evaluations and bond release efforts. As indicated in previous sections, the extreme variability of the project area vegetation resources (primarily due to the influence of annual taxa) has complicated the selection of these four reference areas. However, it is recommended in this baseline report that despite the B-44

Appendix B Standard Practices and Mitigation Measures
complications due to annual taxa, the current quartet of selected reference areas should still be utilized for revegetation performance comparisons. These comparisons, however, must necessarily reflect non-standard techniques for documenting successful revegetation. In this regard, it is Cedar Creek’s recommendation that for performance criteria for the variable of ground cover, each reference area may be used individually or in an acreage-weighted manner for testing purposes, however, only ground cover due to perennial vegetation shall be utilized for comparison. The contribution due to annual species shall be deleted from the final comparison set of statistics (following collection of a statistically adequate sample where necessary) for both reference areas and revegetated areas. Rationale for this action is readily apparent when reviewing the reference area validation testing on Table E5-1 for total ground cover vs. perennial ground cover. Three of the four reference areas fail the validation test for Total Ground Cover due to the influence of the highly variable annual plant contribution. All four reference areas pass testing when only Perennial Ground Cover is utilized. With regard to current annual production, it is again Cedar Creek’s recommendation that each reference area may be used individually or in an acreage-weighted manner for testing purposes, however, “baseline-adjusted” herbaceous perennial vegetation production shall be utilized for comparison. The contribution due to annual species shall be deleted from the final comparison set of statistics (following collection of a statistically adequate sample where necessary) for both reference areas and revegetated areas. Once the future perennial herbaceous production has been identified, the “adjusted reference area” mean will be determined by multiplying each future reference area perennial mean value by the ratio of pre-mining baseline versus reference area as follows: • • • • For all future measurements of the Salt Desert Shrub Reference Area, mean Perennial Herbaceous Production shall be “adjusted” downward by the multiplication factor of 0.541. For all future measurements of the Sagebrush Reference Area, mean Perennial Herbaceous Production shall be “adjusted” upward by the multiplication factor of 1.272. For all future measurements of the Juniper Scrub Reference Area, mean Perennial Herbaceous Production shall be “adjusted” downward by the multiplication factor of 0.736. For all future measurements of the Greasewood Reference Area, mean Perennial Herbaceous Production shall be “adjusted” upward by the multiplication factor of 2.879.

In effect, this procedure will facilitate a “comparison” or “control” area style evaluation whereby the original baseline data are utilized to adjust the reference area mean (given the aforementioned ratios), and differences over time due to climatic influences will still be accounted for by changes in reference area data. This procedure is recommended for use because the next best alternative (standards developed from NRCS data) would result in standards ranging from 3 to 10 times too great a value. This would effectively preclude any opportunity for future release of liability and/or financial assurances. To help avoid confusion, the following example is provided to demonstrate the determination of a single acreage-weighted value that herbaceous perennial revegetation area production might have to meet. B-45

Appendix B Standard Practices and Mitigation Measures
Pre-Mine Community Juniper Scrub Sagebrush 1.272 0 736 2 75 95.40 0.236 22.53 103.8 175 128.80 0.192 24.71

Parameter/Adj. Factor/Etc. Pre-Mine Ref. Area / Baseline Ratio Post-Mine Ref. Area Perennial Production (Hypothetical) Baseline Ratio Adjusted Ref. Area Total Perennial Herb. Prod. Weighting Factor based on Study Area Acreage Acreage Wtd. Herb. Perennial Prod. (Pounds/Acre) by Type Total Target Wtd. Perennial Prod. (Pounds/Acre) For Year XXXX (or Success Criterion)

Salt Desert Shrub 0.541 100 54.10 0.504 27.27

Greasewood 879 150 431.85 0.068 29.31

As indicated in Rule 4.15.7 (5) the 10-year liability period will begin following the last year of augmented seeding, fertilization, irrigation, or related revegetation work. To facilitate bond release, revegetation success criteria must be met for two of the last four years of the liability period excepting that sampling for final success determination cannot occur prior to year 9 of this period. The liability period will be reinitiated for augmentation work excepting work associated with normal management activities as defined under Rule 4.15.7 (5) (a-g). 5.2 Revegetation Success Criteria

The Operator will meet the requirements of this Subsection to insure that the postmining vegetation will be adequate for final bond release. The Operator will utilize established reference areas for the purpose of comparing vegetation information between the reclaimed area and the undisturbed area for the variables of ground cover and production. For the variables of woody plant density and species diversity, the Operator shall compare revegetated area parameters against defined standards detailed later in this section. Data to be used in these comparisons must be from statistically adequate sampling (where necessary) as indicated in Rule 4.15.11. 5.3 Herbaceous Cover

Herbaceous cover of the revegetated area will be considered adequate for final bond release if the perennial herbaceous cover is not less than 90 percent of the perennial herbaceous cover as determined from the reference area(s) with a 90 percent statistical confidence utilizing one of the three methods detailed under Rule 4.15.11 (2) [(a), (b) or (c)]. As allowed by Rule 4.15.7 (4), either weighted-average or individual protocols will be followed. Preference will first be given to testing using the weighted average approach (Rule 4.15.7 (4) (b)) where reference area data and revegetated area data are “weighted” (each combined into a single value for comparison) based on the acreage of premine communities within the disturbance area footprint. Testing for either approach will then follow procedures detailed under Rule 4.15.11 (2) with preference being given first to subsection (a) [direct comparison], second to subsection (c) [reverse-null testing], and third subsection (b) [classic t-test].

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Appendix B Standard Practices and Mitigation Measures
5.4 Herbaceous Production

Herbaceous production of the revegetated area will be considered adequate for final bond release if the perennial herbaceous production is not less than 90 percent of the perennial herbaceous production as determined from the reference area(s) with a 90 percent statistical confidence utilizing one of the three methods detailed under Rule 4.15.11 (2) [(a) (b) or (c)]. As allowed by Rule 4.15.7 (4), either weighted-average or individual protocols will be followed. Preference will first be given to testing using the weighted average approach (Rule 4.15.7 (4) (b) where reference area data and revegetated area data are “weighted” (each combined into a single value for comparison) based on the acreage of pre-mine communities within the disturbance area footprint. Testing for either approach will then follow procedures detailed under Rule 4.15.11 (2) with preference being given first to subsection (a) [direct comparison], second to subsection (c) [reverse-null testing], and third subsection (b) [classic t-test]. Furthermore, as detailed above, production testing requires adjustment for baseline conditions (to eliminate the impact due to annuals). In this regard, each reference area mean utilized in the comparison will need to be adjusted as follows: • • • • • For all future measurements of the Salt Desert Shrub Reference Area, mean Perennial Herbaceous Production shall be “adjusted” downward by the multiplication factor of 0.541. For all future measurements of the Sagebrush Reference Area, mean Perennial Herbaceous Production shall be “adjusted” upward by the multiplication factor of 1.272. For all future measurements of the Juniper Scrub Reference Area, mean Perennial Herbaceous Production shall be “adjusted” downward by the multiplication factor of 0.736. For all future measurements of the Greasewood Reference Area, mean Perennial Herbaceous Production shall be “adjusted” upward by the multiplication factor of 2.879. These adjustments, either individually or on an acreage-weighted basis, will allow use of the existing set of reference areas established in 2006 for comparison. The selected reference areas were the only tenable examples of each community present within reasonable proximity of the study area. Since no other usable reference areas were present, this “adjustment” was the only logical alternative for success criteria establishment. Woody Plant Density

5.5

The variable of woody plant density is largely associated with the land use of wildlife habitat, therefore, the application of such a success criterion must be qualified in this regard. Reclamation will specifically target both livestock grazing and wildlife habitat in combination, both of which are the two primary components of the Pre- and Post-mining Rangeland Land Use. Accounting for the proportion of each land use that should be targeted by reclamation efforts can be a difficult process, however, livestock grazing in the project area tends to be a more significant and dominant use of the rangeland with wildlife habitat being subordinate. In addition, preliminary evaluations of post-mining topography, indicate that about 35 percent of the reclaimed landscape will afford flat or gently sloping surfaces with reduced exposure to erosion. It is on these less exposed more gentle slopes where development of wildlife conducive shrubland habitats such as sagebrush steppe can be encouraged with minimal risk of excessive erosion. Therefore, the Operator proposes that stronger efforts encouraging woody plants be B-47

Appendix B Standard Practices and Mitigation Measures
limited to the flat or more gently sloping surfaces (thereby targeting wildlife habitats), and only weak efforts applied to the more erosion prone slopes (thereby targeting livestock grazing). This approach will encourage a reasonable distribution and proportion of revegetated communities that target the respective post-mining land uses without overly compromising the primary need for controlling erosion. However, no commitment is made to the establishment of any specific percentages of either land use targeted reclaimed community within the permit area. As indicated by the two proposed seed mixes, the establishment of shrubs will be attempted on all reclaimed acreage. However, because erosion control will be of paramount importance on steeper slopes, grasses will be encouraged in these areas and relief from a restrictive woody plant density standard will be necessary. To the contrary, grasses can be more restricted on flatter slopes (less prone to erosion) to help encourage shrubs, and as such a woody plant success criterion can be utilized for any shrub patches that develop within these areas. As shrublands evolve on these “shrub community attempts”, they will be segregated into “core” areas and “ecotonal” areas (as is typically evident in nature), each with a separate woody plant density success criterion. Furthermore, it has been noted repeatedly in the industry that the 10-year bond responsibility period is insufficient for the adequate development of more dense shrub populations. In this regard, flexibility must be built into the success evaluation process (and/or criteria). In this regard, if a positive recruitment rate to the shrub population can be shown to exist, there would be no need to achieve elevated densities within a modest time-frame such as a 10-year period. Given this focus on erosion control, targeting of specific land uses, and the fact that the environs of the Red Cliff Project Area are conducive to the long-term development of desert shrub populations (across several decades), the following woody plant density success criteria will be applied to revegetation efforts: On grassland communities (targeted on approximately 65 percent of reclamation), zero woody plant density will be required as a success criterion although a goal of 50 plants per acre will be sought. If shrub communities evolve in these areas this acreage will count toward the wildlife habitat goal and be subject to appropriate standards. On shrubland communities (targeted on approximately 35 percent of reclamation designed for the post-mining land use goal of wildlife habitat), the following criteria will be applied depending on shrubland classification. On “core areas” (areas of shrub concentration), the standard shall be 300 plants per acre after 10 years, or 200 plants per acre with documentation of a positive shrub population recruitment rate. Similarly, in ecotonal areas, the standard shall be 150 plants per acre after 10 years, or 100 plants per acre with documentation of a positive recruitment rate. 5.6 Diversity

Since the 1980s DRMS regulations have allowed for the use of direct comparisons of species composition based on relative cover (composition) between reclaimed areas and undisturbed vegetation (e.g., baseline or reference areas) to document diversity. Baseline vegetation studies completed in 2006 revealed an average of 4.25 perennial species exhibiting between 3 and 50 percent relative cover across the late seral communities of the entire study area (see Table E5-6 – from the vegetation baseline).

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Appendix B Standard Practices and Mitigation Measures
When viewing baseline communities alone an average of 5.25 perennial species between 3 and 50 percent composition are indicated. However, the four reference areas (reasonable examples of each community) only exhibit an average of 3.25 perennial species. Furthermore, as indicated in Table E5-6, the diversity of perennial forbs is weakly represented in most native communities. Because these native areas are, by definition, late seral and revegetated areas are early to mid seral, allowances must be made regarding diversity. In this regard and given a weighted comparison, diversity of revegetated areas will be considered adequate for final bond release if the number of perennial species exhibiting between 3 and 50 percent relative cover (composition) is equal to or greater than two. Furthermore, there should be no distinction among these species with regard to life form given the weak representation from forbs in the baseline data set. If a direct comparison is made (i.e., community to community such as sagebrush reclamation to sagebrush reference area), then the number of species exhibiting between 3 and 50 percent relative cover (composition) must be 90 percent of the number of species documented from the appropriate reference area (rounded down to the nearest integer (whole number). For example, a juniper to juniper comparison would result in the need to exhibit 3 species between 3 and 50 percent composition (4 X 0.9 = 3.6 and 3.6 rounded down to the nearest integer would be 3). Table E5-6 VEGETATION COVER – 2006
Diversity – Perennial Species with 3% – 50% Relative Cover (Including 2nd Hits) Salt Desert Juniper Shrub Scrub Community Type --> Greasewood Reference Reference Reference Baseline Baseline Baseline

Sagebrush Reference 10.17 1 6.96 1 59.97 4.28 Baseline 8.77 6.07 3.49 3 0 43.08 3.71

N P Elymus salina

Unit --> Salina Wildrye

19.61 3.18 2

45.35

11.36 5.17 7.13 1 24.37

N P Hilaria jamesii James' Galleta N P Poa secunda Sandberg Bluegrass Number of Perennial Grasses N P Erigeron Navajo Fleabane concinnus N P Phlox hoodii Carpet Phlox Number of Perennial Forbs N P Artemisia Wyo. Big Sagebrush tridentata var. wyo. N P Atriplex confertifolia N P Atriplex gardneri N P Grayia spinosa N P Gutierrezia sarothrae N P Juniperus osteosperma Shadscale Saltbush Gardner's Saltbush Spiny Hopsage Snakeweed Utah Juniper

1

7.96 1

13.32 1

2 7.44 3.10 2 15.70 3.10

0

0

0 7.62

0 20.69

1 14.48

19.89 20.86 3.87

36.63 6.73

12.40 10.74

37.93

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Appendix B Standard Practices and Mitigation Measures
Diversity – Perennial Species with 3% – 50% Relative Cover (Including 2nd Hits) Salt Desert Juniper Community Type --> Shrub Greasewood Scrub Reference Reference Reference Baseline Baseline Baseline

Sagebrush Reference 1 3 4 Baseline 2 5

N P Sarcobatus vermiculatus

Unit --> Greasewood Number of Shrubs Total Average 2 5

34.36 2 3 4 2 3 3

45.14 2 3 4 8 6 2 4

5.7

Unique Circumstances

Finally, based on pre-mine mapping, approximately 5 percent of the vegetation study area (and probably more of the disturbance footprint) is effectively barren of vegetation (less than 3 percent ground cover). These areas are indicated as “BR” and “DSN”. The BR areas are effectively 100 percent exposed Mancos shale. The DSN areas exhibit very thin cover values from a single shrub species (Atriplex corrugata) with occasional scattered patches of a grass, Salina wildrye (Leymus salinus). These would be very difficult to revegetate given the several decades of “weathering” of Mancos shale that would necessarily have to occur before these two species could be reintroduced to such circumstances. Therefore, as much as 5 percent of the reclaimed surface could exhibit barren or very thinly vegetated areas and still qualify for final bond release. 5.8 Revegetation Community Mapping / Stratification

During monitoring of revegetated units, developing shrub patches will be identified and as necessary delineated (circumnavigated with a sub-meter global positioning system [GPS] unit to document boundaries and acreage) to facilitate mapping that in turn will represent the juxtaposition (stratification) of developing communities. As indicated previously, delineated shrub patches will be classified as either “core” areas or “ecotonal” areas depending on apparent density of developing shrub populations. Such stratification is necessary as success criteria associated with areas of wildlife habitat will be applicable to shrub-dominated communities as opposed to grassland success criteria applicable to remaining revegetation efforts targeting livestock grazing land uses. 5.9 Sample Layout

The sample layout protocol for revegetation monitoring and bond release evaluations shall be a systematic procedure designed to better account for the heterogeneous expression of seedings within reclaimed areas while precluding bias in the sample site selection process. By design, the procedure is initiated randomly, and thereafter, samples are located in a systematic manner, along grid coordinates spaced at fixed distances, e.g., 200 feet. In this manner, “representation” B-50

Appendix B Standard Practices and Mitigation Measures
from across the target reclamation unit is “forced” rather than risking the chance that significant pockets are entirely missed or overemphasized as often occurs with simple random sampling. Unless too small, older reclaimed units (e.g., 7 or more years) shall receive a minimum of 20 ground cover transects and in monitoring areas – co-located shrub density belts. Production for monitoring purposes shall be collected from a representative subset (five) of these 20 sample points. For bond release efforts, production will be collected from a statistically adequate sample (where necessary) as defined below. Monitoring efforts for younger reclaimed units (e.g., 2 to 4 years) shall receive 15 transects and co-located woody density belts (as necessary) but no production sampling. First year units will receive one cluster of five emergent density quadrats spread in a representative manner for approximately every two to three acres of reclamation. With regard to any two-year-old or older reclamation unit that is smaller than about 5 acres, the number of samples (for monitoring) shall be limited to five. The systematic procedure for sample location in revegetated units shall occur in the following stepwise manner. First, a fixed point of reference (e.g., fence corner) will be selected for the target unit to facilitate location of the systematic grid in the field. Second, a systematic grid of appropriate dimensions will be selected to provide a reasonable number of coordinate intersections (e.g., 5, 15, 20, etc.) that would then be used for the set of sample sites. Third, a scaled representation of the grid will be overlain on a computer-generated map of the target unit extending along north/south and east/west lines. Fourth, the initial placement of this grid will be implemented by selection of two random numbers (an X and Y distance) to be used for locating a systematic coordinate from the fixed point of reference, thereby making the effort unbiased. Fifth, where an excess number of potential sample points (grid intersections) is indicated by overlain maps, the excess may be randomly chosen for elimination. (If later determined that additional samples are needed, the eliminated potential sample sites would be added back in reverse order until enough samples can be collected.) Sixth, utilizing a handheld compass and pacing techniques, or a hand-held GPS, sample points will be located in the field. Once a selected grid (sample) point is located in the field, sampling metrics will be utilized in a consistent and uniform manner. In this regard, ground cover sampling transects will always be oriented in the direction of the next site to be physically sampled to further limit any potential bias while facilitating sampling efficiency. Depending on logistics, timing, and access points to a target sampling area, the field crew may occasionally layout a set of points along coordinates in one direction and then sample them in reverse order. However, orientation protocol will always be maintained (i.e., in the direction of the next point to be physically sampled). If the boundary of an area is encountered before reaching the full length of a transect, the transect orientation will be turned 90 degrees in the appropriate direction so the transect will be completed within the target unit. In this manner, edge transects will be retained entirely within the target unit by “bouncing” off the boundaries. Production quadrats will always be oriented 90 degrees to the right (clockwise) of the ground cover transect and placed one meter (m) from the starting point so as to avoid any trampled vegetation. Woody plant density belts (typically for monitoring efforts) will be extended parallel to the ground cover transects for a distance of 50 m and width of 2 m. (If the grid distance is less than 50 m, density belts will be reconfigured to be 4 m X 25 m or similar configuration, but always totaling 100 square meters (m2).

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Appendix B Standard Practices and Mitigation Measures
5.10 Determination of Ground Cover

Ground cover at each sampling site will be determined utilizing the pointintercept methodology. This methodology will be applied as follows: First, a transect 10 m in length will be extended from the starting point of each sample site toward the direction of the next site to be sampled. Then, at each one-meter interval along the transect, a “laser point bar”, “optical point bar” or 10-point frame will be situated vertically above the ground surface, and a set of 10 readings recorded as to hits on vegetation (by species), litter, rock (greater than 2mm), or bare soil. Hits will be determined at each meter interval as follows: 1. When a laser point bar is used, a battery of 10 specialized lasers situated along the bar at 10-centimeter intervals will be activated and the variable intercepted by each of the narrow (0.02 inch) focused beams will be recorded; 2. If an optical point bar is used, intercepts will be recorded based on the item intercepted by fine crosshairs situated within each of 10 optical scopes located at 10-centimeter intervals. 3. If a 10-point frame is used, sharpened pins will be used to determine intercepts at 10-centimeter intervals. Care will be taken to NOT record “side touches” on the pins as this will result in a significant overestimation error. The following sampling rules should apply during data collection. Intercepts will be recorded for the first (typically highest) current annual (alive during the current growing season) plant part intercepted without regard to underlying intercepts or attachment to a living base except when multiple strata are present. In this circumstance, multiple live hits may be recorded, but only one hit per stratum with the second live hit being recorded separately and not used to calculate total ground cover. Otherwise, the intercept will be litter, rock or bare soil. Rock intercepts are based on a particle size of 2 mm or larger (NRCS definition), otherwise it would be classified as bare soil. To distinguish between current year senescent plant material and litter (including standing dead), the following rule should apply: 1) if the material is gray or faded tan it should be considered litter; and 2) if the material is bright yellow or beige it should be considered current annual (alive) and recorded by species. On occasion, experience with non-conforming taxa may override this rule. When using laser or optic instruments during windy field conditions, the observer should consistently utilize one of the following techniques for determining a hit: 1) record the first item focused upon that is intercepted by the narrow laser beam or cross-hair; 2) wait a few moments and record the item intercepted for the longest time, or 3) block the wind and record the intercept. When using a pin frame, the observer must wait for the wind to subside. With regard to gaps in the overstory, the point-intercept procedure naturally corrects for overestimations created by 2-dimensional areal (quadrat) or 1- dimensional linear (line-intercept) techniques. In this regard, the 0-dimensional point is extended along a line-of-sight until it “intercepts” something that is then recorded. Frequently points simply pass through overstory gaps until a lower plant part, litter, rock or bare soil is encountered. Regardless of instrument, a total of 100 intercepts per transect will be recorded resulting in 1 percent cover per intercept. This methodology and instrumentation (excepting the 10-point frame) facilitates the collection of the most unbiased, repeatable, precise, and cost-effective ground cover data possible. Identification and nomenclature of plant species should follow Weber and Wittman (1996) Colorado Flora: Western Slope or newer accepted publication. B-52

Appendix B Standard Practices and Mitigation Measures
5.11 Determination of Production

Where production samples are to be collected (7 or more year-old units or Bond Release units) current annual herbaceous production will typically be collected from a 0.5 square meter (m2) quadrat frame (0.5m x 1.0m) placed one meter and 90 degrees to the right (clockwise) of the ground cover transect to facilitate avoidance of vegetation trampled by investigators during sample site location. Where elevated variability is apparent within a reclamation unit or reference area, the sampling unit (quadrat frame) for that unit / reference area can be increased in size to 1m2 or 2m2 for the entire unit to help absorb additional variation. The best frame shape to maintain is rectangular and therefore, should be 0.5m x 2m for a 1m2 sample or 0.5m x 4m for a 2m2 sample. However, it is important that all samples from within a given unit or reference area remain consistent in size and shape (i.e., quadrat size and shape can only be changed between areas). Once collected, care must be taken to report data on a consistent basis (typically 0.5 m2 basis) and then converted to pounds per acre. If more production samples are necessary than cover samples (typical case for bond release efforts), orientation protocol will be maintained except that no ground cover data will be collected from the extra sample points. For example: if it is expected that 45 production samples are necessary for an adequate production estimate, then cover would only be recorded from those samples not evenly divisible by 3. This would result in 30 cover samples and 45 production samples. From within each quadrat, all above ground current annual herbaceous vegetation within the vertical boundaries of the frame will be clipped and bagged separately by life form as follows: • • • Perennial Grass Perennial Forb Annual Grass Annual Forb Subshrub Noxious Weeds (if found)

All production samples will be returned to the lab for drying and weighing. Drying will occur at 105 degrees C until a stable weight is achieved (24 hours). Samples will then be re-weighed to the nearest 0.1 gram. 5.12 Determination of Woody Plant Density

Two sampling methods may be employed for monitoring woody plant density within Red Cliff’s revegetated units. The first method, belt transects, may be employed when the size of the monitoring unit exceeds about five acres. At each sample site in such areas, a 2-meter wide by 50-meter long belt transect (or alternately 4 x 25 meter transect) should be established parallel to the ground cover transect and in the direction of the next sampling point. All woody plants (shrubs and trees but not subshrubs), within each belt will be enumerated by species. Determination of whether or not a plant may be counted is dependent upon the location of its main stem or root collar where it exits the ground surface with regard to belt limits. A total of 5, 15 or 20 belt transects may be sampled for each monitoring unit. For bond release sampling, sufficient samples must be collected to insure adequacy of the effort (to facilitate valid testing) in accordance with one of the three methods under either Rule 4.15.11 (2), or Rule 4.15.11 (3). Depending on the selected protocol, care must be taken to collect at B-53

Appendix B Standard Practices and Mitigation Measures
least the minimum number of samples indicated (15, 30, 40, or 75, depending on the procedure utilized). The second method, total enumeration, may be employed for monitoring units of any size, but feasibly only when the size of a unit is less than approximately five acres. For bond release purposes, total enumeration shall be the typical method utilized unless shrub patches are too large (e.g., greater than 10 to 15 acres) to practically utilize this technique (in which case belts will be utilized). Total enumeration involves total counts of woody plant populations as opposed to estimates of mean densities through statistical sampling. Implementation of the total count technique would involve circumscribing the boundaries of a target polygon with hip chain thread, tree marking paint, surveyor’s flagging, or similar visible designation. Once a unit is circumscribed in this manner, a team of two or more biologists (shoulder-to-shoulder) traverse the patch enumerating each plant by species (tally meters aid this process immensely). The person farthest inside the line of observers trails hip chain thread, or by other means marks their path to prevent missing or double counting specimens on subsequent passes. The distance between observers should be 15 to 20 feet or less depending on the height of grasses and the presence of low growing taxa such as rose or snowberry. Each internal observer should also “zigzag” as the team progresses, occasionally turning to view the area just passed to ensure visual coverage of the entire survey path. Constant communication among team members precludes double counting or missing of plants located along the margins of observed paths. Results from total enumeration efforts can be compared directly with success criteria without statistical testing. 5.13 Determination of Seedling Emergence

At each emergent density sample point (revegetation monitoring only), five one-square foot (ft2) quadrats should be blindly tossed to the ground and the number of emergents rooted within the perimeter of each shall be recorded accordingly into one of five classes: perennial grass, perennial forb, shrub, annual grass, or annual forb. Where possible recognizable taxa may be recorded by species. Efforts with 0-1 perennial emergents may be problematic and require remediation. At a minimum, future monitoring should be mandated. Efforts with 1-2 perennial emergents per ft2 are considered to be fair, while 2-3 perennial emergents per ft2 are considered good. A range of 3-4 perennial emergents per ft2 would be considered very good. Five or more perennial emergents per ft2 can be considered excellent. 5.14 Sample Adequacy Determination / Success Evaluation

Sampling within each monitored unit shall be conducted to a minimum of 5, 15 or 20 samples as appropriate for most procedures, however, reverse null testing requires a minimum of 30 samples (but sample adequacy does not have to be demonstrated). At Red Cliff, sampling within each unit under consideration for bond release shall start with a minimum of 15 (reference area) or 20 (revegetated area) samples and continue until a statistically adequate sample (if necessary) has been obtained in accordance with Rule 4.15.11 (2) (a)[direct comparison], (b)[standard-null testing], or (c)[reverse-null testing]. From initial sampling efforts, sample means and standard deviations for total non-overlapping vegetation ground cover, production, and woody plant density will be calculated. For bond release applications, the typical procedure is that sampling B-54

Appendix B Standard Practices and Mitigation Measures
continues until an adequate sample, nmin, has been collected in accordance with the Cochran formula (below) for determining sample adequacy, whereby the population is estimated to within 10 percent of the true mean (μ) with 90 percent confidence. For woody plant density, the estimate is to within 15 percent of the true mean. When the inequality (nmin ≤ n) is true, sampling is deemed adequate; and nmin is determined as follows: nmin = (t2 s2) / (dx- )2 where: n = the number of actual samples collected (initial size = 15 or 20) t = the value from the one-tailed t distribution for 90 percent confidence with n-1 degrees of freedom (a value of approximately 1.3); s2 = the variance of the estimate as calculated from the initial samples; d = precision (0.10 for cover and production or 0.15 for woody plant density;
x

= the mean of the estimate as calculated from the initial samples.

If the initial samples do not provide a suitable estimate of the mean (i.e., the inequality is false), additional samples should be collected until the inequality (nmin ≤ n) becomes true. However, where sampling is for managerial (monitoring) information, adequacy is not necessary and is calculated for informational purposes only. If reverse-null testing will be utilized to document success, then in accordance with Rule 4.15.11 (2) (c) a minimum of 30 samples must be collected and demonstration of sample adequacy is not necessary. In this regard, the smaller the variance (given by extra sampling) the better the chances of passing closely matched parameters. For certain statistical demonstrations of woody plant density, a determination of sampling adequacy is often problematic, hence Rule 4.15.11 (3) may be used in lieu of Rule 4.15.11 (2). Rule 4.15.11 (3) (a) is a reverse-null approach based on the median and requires a minimum of 30 samples. Rule 4.15.11 (3) (b) allows direct comparison with standards if a statistically adequate sample cannot be demonstrated in accordance with Rule 4.15.11 (2) (a), however, a minimum of 75 samples with a minimum quadrat size of 100 m2 is required (equivalent to total enumeration of 1.85 acres). Rule 4.15.11 (3) (c) is a standard-null approach based on determination of a “running mean” and a minimum of 40 samples is required. To summarize, success evaluations involve either a direct or a statistical t-test comparison of appropriate parameters for each variable of interest (cover, production, diversity, or woody plant density). For monitoring efforts, comparisons shall be made directly with either the reference area parameters or the permitted standards to facilitate a determination of the progress of revegetation. In the case of ground cover and to a more limited degree, production, comparisons shall be made against reference area data of the same year. Diversity and woody plant density variables shall be compared against the standards defined above. For bond release efforts, direct comparisons are made when the revegetated area mean value for a given variable is greater than either 90 percent of the standard or the reference area mean assuming that a statistically adequate sample has been collected. If a statistically adequate sample cannot be obtained, a “reverse-null” hypothesis test may be employed as detailed in Rule B-55

Appendix B Standard Practices and Mitigation Measures
4.15.11 (2)(c). If an adequate sample is obtained for a particular variable, but the mean is less than 90 percent of the reference area mean or standard, a “standard-null” hypothesis t-test may be employed as detailed in Rule 4.15.11 (2) (b). For the typically problematic variable of woody plant density, Colorado has implemented three alternate adequacy / success evaluation methods under Rule 4.15.11 (3) that may be utilized in lieu of those detailed under 4.15.11 (2). Until experience dictates which procedure is best (because these are relatively new metrics to the science), it would be prudent to collect a minimum of 75 belt transects (at least 100 m2 in size) as indicated in 4.15.11 (3)(b)(i) unless total population enumeration occurs. These data can then be used for the various analyses / comparisons. Revegetation will be monitored once during the third to fifth years of the liability period based on the results of a visual assessment of the vegetation and in consultation with the Division. Should the reclamation appear successful and the vegetation warrant such, monitoring data will be collected in preparation for a Phase II bond release application. Absolute cover data will be collected to adequacy in both reclaimed and reference areas. Multiple hit data will not be collected. An estimate of the species diversity success will be based on first hit data which, in the case of a herb dominated community, is highly correlated with multiple hit data. Should the reclaimed areas not be candidates for a Phase II bond release application, cover data will not necessarily be collected to adequacy. Should the reclamation and revegetation successfully meet the requirements, quantitative sampling will be carried out in years nine and ten of the bond liability period. Methods will be consistent with the methods and analytical techniques used during the baseline study except that woody stem density sampling would not be carried out because no standard applies. 5.15 Rill and Gully Inspections

Reclaimed areas will be checked annually after snowmelt for the formation of rills and gullies. To document each inspection, a report will be prepared and be made available for inspections as required under Rule 5.02.4. Rills and gullies deeper than nine inches will be noted in the report. By the end of August of the same year, laborers or small equipment will be used to fill, grade or otherwise stabilize rills and gullies deeper than nine inches. The repaired area will be seeded and mulched by the end of the same year. Mulch will be anchored to the ground with netting if appropriate. 5.16 Soil Testing Plan

Upon reclamation, an analysis of the soils will be made to determine the fertilization requirements of the areas involved. If the analysis shows that the soil is deficient in phosphorus, it will be added to the soil prior to seeding. Other elements may be added the year after seeding. Unneeded fertilization and irrigation will be avoided. Native plants have low potential response to fertilizer and undesirable weed competition is likely.

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Appendix B Standard Practices and Mitigation Measures
5.17 Disposal of Debris, Acid-Forming and Toxic Forming Materials

There is no indication that any acid-forming or toxic forming materials will be encountered onsite. If sustained combustion of debris or non-coal waste becomes a problem the operator will be prepared to react appropriately. Chemical fire extinguishers will be available in the shop warehouse area and on mobile equipment. A water truck will be available to respond to any problem area. Earth moving equipment may be available to smother a fire if necessary. 5.18 Sealing or Managing Mine Openings, Exploration Holes, Other Boreholes or Wells

The mine portals will be sealed in accordance with 30 CFR 75.1711. The exploration and monitoring holes will be sealed in accordance with the requirements of Rule 4.07. Drill holes, not completed to aquifers will be sealed by replacing cuttings or other suitable media in the hole and placing a suitable plug 10 feet below the ground to support a cement plug or other media approved by the Division to within 3 feet of the ground surface. Drill holes completed in non artisan aquifers will be sealed using cement or other suitable sealant by placing the sealant to extend 20 feet above and below the water bearing zone. A surface plug will then be placed in accordance with the above paragraph. The hole will be marked. The following monitoring plan is designed to provide data which will verify the Red Cliff Mine will not have significant adverse impacts on the surface or subsurface water which is within or adjacent to the permit area. Stock Ponds will be monitored quarterly. Depending on weather conditions, the first quarter monitoring event may be delayed until April or May. Freeboard or water depth will be collected for each pond. The following four monitoring wells will be monitored: F-50, 7-34-7, 8-2-8, 8-3-10. Depending on weather conditions, the first quarter monitoring event may be delayed until April or May. Field parameters will be measured each quarter. A full suite sample will be obtained semiannually during the second and fourth quarters. Alluvial wells VB-06-03 and VB-06-10 will be monitored quarterly for field parameters. A full suite sample will be obtained semi-annually during the second and fourth quarters. Surface water monitoring stations SW-1, SW-2 and SW-3 will be monitored quarterly for field parameters. A full suite sample will be obtained semi-annually during the second and fourth quarters. Big Salt Wash will be monitored at BSW-1 and BSW-2 to develop baseline information in anticipation of the mine expanding to the west. BSW-1and BSW-2 will be monitored quarterly for field parameters. A full suite sample will be obtained semi-annually during the second and fourth quarters. East Salt Creek will be monitored at two locations ESC-1 and ESC-2. ESC-1 is located where East Salt Creek flows under SH-139 at approximate mile marker 15.5. ESC-2 is located where East Salt Creek flows under CR T. The sediment ponds will be monitored in accordance with discharge permit requirements. B-57

Appendix B Standard Practices and Mitigation Measures
Mine inflows will be measured semi-annually for field parameters. An annual full suite analysis will be obtained for any point source of inflow greater than 5 gallons per minute. Results of the mine inflow monitoring including a seep location map and seep rate of flow will be submitted with the annual hydrologic report. Water samples are typically analyzed by ACZ Laboratories, Inc. of Steamboat Springs, or Enviro-Chem of Grand Junction for the following parameters.
Ground Water Parameter Water Level (Field) pH (F & L) Conductivity (F & L) Temperature (Field) Total Dissolved Solids Bicarbonate (HCO3-) Calcium (Ca+2)(Dis) Carbonate (CO3-) Hardness Chloride (Cl-) Magnesium (Mg+2) (Dis) Ammonia, (NH3) Nitrate-Nitrite Phosphate (PO4-3 as P) Sodium (Na+) (Dis) Sulfate (SO4--) Arsenic (As) (Dis) Cadmium (Cd) (Dis) Iron (Fe) (Dis) Iron (Fe) (Trec) Manganese (Mn) (Dis) Manganese (Mn) (Trec) Mercury (Hg) (Dis) Selenium (Se) (Dis) Zinc (Zn) (Dis) Trec = Total Recoverable Dis = Dissolved
F & L = Field & Laboratory

Units feet standard uhmos/cm Celsius mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l

Surface Water List Parameter Flow (Field) pH (F & L) Conductivity (F & L) Temperature (Field) Total Suspended Solids Total Dissolved Solids Total Alkalinity Bicarbonate (HCO3-) Carbonate Hydroxide Sulfate (SO4--)

Units GPM – CFS su uhmos/cm Celsius mg/l mg/l mg/l mg/l mg/l mg/l mg/l

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Appendix B Standard Practices and Mitigation Measures
Surface Water List Parameter Calcium (Ca+2)(Trec) Magnesium (Mg+2) (Trec) Sodium Adsorption Ratio Hardness Chloride (Cl-) Sodium (Na+) (Trec) Potassium Aluminum (Al) (Trec) Arsenic (As) (Trec) Boron (B) (Trec) Copper (Cu) (Trec) Iron (Fe) (Trec) Lead (Pb) (Trec) Manganese (Mn) (Trec) Selenium (Se) (Trec)

Units mg/l mg/l -mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l

Trec = Total Recoverable; F & L = Field & Laboratory; su = Standard Units

Records of the above monitoring will be maintained on-site and submitted to the Division annually in the form of an annual hydrology report. The annual hydrology report (AHR) will be submitted each year on or before April 30th. Pictures of stock ponds will be taken annually and included in the AHRs. The data obtained from the monitoring program outlined above will be utilized to determine if the mine is having an impact on the hydrologic balance. Impact on the hydrologic balance will be evaluated by analyzing rapid and/or unanticipated changes at a monitoring site. A rapid drop in the water level in one of the monitoring wells might indicate the mine is impacting the perched water bearing zone. A change in water quality might indicate the mining operation is causing water bearing zones to mix or is disturbing water bearing zones.

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Appendix B Standard Practices and Mitigation Measures
6.0 Subsidence Monitoring Program

Surveyed subsidence monuments will not achieve the monitoring required to determine if a light use road has been damaged. Therefore, the Operator will visually monitor the light use roads above the area to be mined to determine if there has been material damage. The monitoring will be performed four times per year. Since access to the area is restricted during winter and spring months, the four monitoring events will likely occur on or about May, June, August and October of each year. Results of the monitoring program shall be submitted to the DRMS semiannually. The monitoring program will extend for a time, beyond cessation of mining in any area, consistent with the need for verification of the subsidence prediction.

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7.0 Railroad Fire Mitigation1

In order to mitigate fires caused by the train, it is necessary to treat potentially hazardous vegetation within the railroad ROW. There are three basic methods of reducing ROW fire hazards: mechanical clearing (physical removal of vegetation), burning, and chemical treatment. These fire hazard reduction methods often need to be used in combination for optimum hazard reduction. Mechanical clearing is most useful for initial clearing of heavy fuels, such as old logs, and for construction and maintenance of firebreaks. Chemical treatment is most useful for maintenance of clearings already established. However, it can create flash-fuel problems if used as the first treatment. Burning can be used for either initial or maintenance treatment but is normally unsafe without a mechanically cleared firebreak. Certain fire hazards cannot be treated by removal, burning or herbicides. These might include vegetation such as moss and grass growing on rock cliffs or cut-banks, rare or endangered plant species, and short stretches of ROW where these fire hazard reduction methods are precluded for any reason. In these situations, fire retardant chemicals should be employed, either alone or in combination with the other methods. 7.1 Mechanical Clearing

The most common method of railroad ROW hazard reduction is mechanical clearing, i.e., physical removal of the flammable vegetation and debris. This is sometimes done over an entire area from the edge of the railroad bed to the edge of the ROW or other desired width, and is a sufficient positive fire prevention measure since all vegetation is removed to bare soil. It is also considerably expensive, and can lead to adverse environmental impacts including soil erosion. A more common use of mechanical clearing is to construct a firebreak at the outer edge of the area to be treated. This is not considered an effective measure unless the area between the firebreak and the railroad bed is also treated. 7.2 Burning

In many situations burning is one way of getting rid of ROW fire hazards. Achieving the desired results safely is not easy nor is it simple. According to the National Interagency Fire Center (NIFC) (NIFC no date), a prescribed fire may be defined as any fire ignited by management actions under certain pre-determined conditions to meet specific objectives related to hazardous fuels reduction or habitat improvement. NEPA requirements must be met prior to ignition, along with approval of a prescribed fire plan which provides the information needed to implement an individual prescribed fire project. Prescribed fires are ignited and managed within a "window" of very specific conditions including winds, temperatures, humidity, and other factors specified in the prescribed fire plan. The “window” guides the selection of appropriate management responses. The prescribed fire plan also may include other required actions including safety, economic factors, air quality, public health, and other environmental, geographic, administrative, social, or legal considerations (NIFC no date).
1

Adapted from Union Pacific Railroad et al. 1999

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Appendix B Standard Practices and Mitigation Measures
Environmental concerns are more of a factor in burning operations than they are in mechanical clearing operations. The items of primary importance are air and water pollution. Soil erosion, which is the primary concern in mechanical clearing, is of minor or secondary concern in burning since the roots are usually left to hold the soil. Also, if the burning is done properly, the larger plants will remain. Open burning is regulated by fire laws and air pollution control laws. 7.3 Chemical Treatment

Chemical treatment of fire hazards involves the application of herbicides and/or fire retardant. Both federal and state law closely regulates this type of activity. These laws require most effective chemicals to be applied by a licensed or certified applicator. The most common type of chemical treatment of railroad rights-of-way is with a non-selective soil-applied herbicide applied to the railroad bed and to enough additional width to comply with Federal Railroad Administration (FRA) regulations. In most cases, unless hindered by adverse weather or other outside factors, this provides excellent fire prevention protection within the width treated. 7.4 Fire Resistant Plants

Another approach to ROW fire hazard reduction is the replacement of native vegetation with fire resistant vegetation. Most of the research in this field has been directed toward landscaping for structures located in hazardous fire areas rather than large scale ROW plantings. However, some limited success has been achieved which might be applied to ROW fire hazard reduction. 7.5 Fire Fighting Methods

When fires do occur on railroad property or ROW, the company has a legal responsibility to report them to the protection agency and to do all in its power to suppress the fire. Some railroad companies use hyrailer (a vehicle that can travel on rails and roads) patrols and water tank cars in fire-prone areas to fight wildfires started by trains. Hyrailer patrols may be timed to follow 10-15 minutes behind trains. They may only be activated during fire season and usually only during daylight hours. They may have a one or two-person crew which is provided with a radio and limited firefighting tools. Unless they discover a fire while it is still very small they will usually need help in suppressing it. Such patrols are quite costly, and they are, therefore, seldom put behind every train during an entire fire season. Some companies activate them based on “very high” and “extreme” ratings or specified burning indexes of the National Fire Danger Rating system obtained from the protection agencies. Other companies activate the patrols only on Red Flag Alert or Warning also obtained from the protection agencies. A few automatically patrol behind every train during fire season. Several railroad companies provide water tank cars exclusively for fire protection purposes during fire season. These large water sources (8,000-12,000 gallons each) can be of great help to fire suppression forces. To be fully effective, they must be capable of being moved to the scene of a fire quickly and left there, or nearby, as long as needed. Use of water tank cars often presents some problems as it may not be economically practical to have a locomotive and crew on standby where the cars are parked. Also ROW fires seldom occur at sidings, thus a tank car at the fire will usually tie up a mainline track. In spite of these problems, such tank cars have proven of great value to firefighters. B-62

Appendix B Standard Practices and Mitigation Measures
One type of water tank car is attached to the rear of each train and is equipped with spray nozzles that can sprinkle the entire ROW for approximately 20 feet each side of centerline. The nozzles can be activated either by the brake pipe reduction, which applies the train air brakes, or manually by the conductor.

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Appendix B Standard Practices and Mitigation Measures
8.0
8.1

BLM’s Standards and Guidelines (BLM 1997)
Standards for Public Land Health

Standards describe conditions needed to sustain public land health, and relate to all uses of the public lands. Standards are applied on a landscape scale and relate to the potential of the landscape. Standard 1: Upland soils exhibit infiltration and permeability rates that are appropriate to soil type, climate, land form, and geologic processes. Adequate soil infiltration and permeability allows for the accumulation of soil moisture necessary for optimal plant growth and vigor, and minimizes surface runoff. Indicators: • • • • • • • • Expression of rills, soil pedestals is minimal. Evidence of actively-eroding gullies (incised channels) is minimal. Canopy and ground cover are appropriate. There is litter accumulating in place and is not sorted by normal overland water flow. There is appropriate organic matter in soil. There is diversity of plant species with a variety of root depths. Upland swales have vegetation cover or density greater than that of adjacent uplands. There are vigorous, desirable plants.

Standard 2: Riparian systems associated with both running and standing water function properly and have the ability to recover from major disturbance such as fire, severe grazing, or 100-year floods. Riparian vegetation captures sediment, and provides forage, habitat and bio-diversity. Water quality is improved or maintained. Stable soils store and release water slowly. Indicators: • • • • • • • • Vegetation is dominated by an appropriate mix of native or desirable introduced species. Vigorous, desirable plants are present. There is vegetation with diverse age class structure, appropriate vertical structure, and adequate composition, cover, and density. Streambank vegetation is present and is comprised of species and communities that have root systems capable of withstanding high streamflow events. Plant species present indicate maintenance of riparian moisture characteristics. Stream is in balance with the water and sediment being supplied by the watershed (e.g., no headcutting, no excessive erosion or deposition). Vegetation and free water indicate high water tables. Vegetation colonizes point bars with a range of age classes and successional stages. B-64

Appendix B Standard Practices and Mitigation Measures
• • • • An active floodplain is present. Residual floodplain vegetation is available to capture and retain sediment and dissipate flood energies. Stream channels with size and meander pattern appropriate for the stream's position in the landscape, and parent materials. Woody debris contributes to the character of the stream channel morphology.

Standard 3: Healthy, productive plant and animal communities of native and other desirable species are maintained at viable population levels commensurate with the species and habitat's potential. Plants and animals at both the community and population level are productive, resilient, diverse, vigorous, and able to reproduce and sustain natural fluctuations, and ecological processes. Indicators: • • Noxious weeds and undesirable species are minimal in the overall plant community. Native plant and animal communities are spatially distributed across the landscape with a density, composition, and frequency of species suitable to ensure reproductive capability and sustainability. Plants and animals are present in mixed age classes sufficient to sustain recruitment and mortality fluctuations. Landscapes exhibit connectivity of habitat or presence of corridors to prevent habitat fragmentation. Photosynthetic activity is evident throughout the growing season. Diversity and density of plant and animal species are in balance with habitat/landscape potential and exhibit resilience to human activities. Appropriate plant litter accumulates and is evenly distributed across the landscape. Landscapes composed of several plant communities that may be in a variety of successional stages and patterns.

• • • • • •

Standard 4: Special status, threatened and endangered species (federal and state), and other plants and animals officially designated by the BLM, and their habitats are maintained or enhanced by sustaining healthy, native plant and animal communities. Indicators: • • • All the indicators associated with the plant and animal communities standard apply. There are stable and increasing populations of endemic and protected species in suitable habitat. Suitable habitat is available for recovery of endemic and protected species.

Standard 5: The water quality of all water bodies, including ground water where applicable, located on or influenced by BLM lands will achieve or exceed the Water Quality Standards established by the State of Colorado. Water Quality Standards for surface and ground waters B-65

Appendix B Standard Practices and Mitigation Measures
include the designated beneficial uses, numeric criteria, narrative criteria, and anti-degradation requirements set forth under State law as found in (5 CCR 1002-8), as required by Section 303(c) of the Clean Water Act. Indicators: • • Appropriate populations of macroinvertabrates, vertebrates, and algae are present. Surface and ground waters only contain substances (e.g., sediment, scum, floating debris, odor, heavy metal precipitates on channel substrate) attributable to humans within the amounts, concentrations, or combinations as directed by the Water Quality Standards established by the State of Colorado (5 CCR 1002-8). Guidelines for Livestock Grazing Management

8.2

Guidelines are the management tools, methods, strategies, and techniques (e.g., best management practices) designed to maintain or achieve healthy public lands as defined by the standards. Currently, the only guidelines for BLM Colorado that have been developed in concert with the Resource Advisory Councils are livestock grazing management guidelines. 1. Grazing management practices promote plant health by providing for one or more of the following: – – – periodic rest or deferment from grazing during critical growth periods; adequate recovery and regrowth periods; opportunity for seed dissemination and seedling establishment.

2. Grazing management practices address the kind, numbers, and class of livestock, season, duration, distribution, frequency and intensity of grazing use and livestock health. 3. Grazing management practices maintain sufficient residual vegetation on both upland and riparian sites to protect the soil from wind and water erosion, to assist in maintaining appropriate soil infiltration and permeability, and to buffer temperature extremes. In riparian areas, vegetation dissipates energy, captures sediment, recharges ground water, and contributes to stream stability. 4. Native plant species and natural revegetation are emphasized in the support of sustaining ecological functions and site integrity. Where reseeding is required, on land treatment efforts, emphasis will be placed on using native plant species. Seeding of non-native plant species will be considered based on local goals, native seed availability and cost, persistence of non-native plants and annuals and noxious weeds on the site, and composition of nonnatives in the seed mix. 5. Range improvement projects are designed consistent with overall ecological functions and processes with minimum adverse impacts to other resources or uses of riparian/wetland and upland sites. 6. Grazing management will occur in a manner that does not encourage the establishment or spread of noxious weeds. In addition to mechanical, chemical, and biological methods of weed control, livestock may be used where feasible as a tool to inhibit or stop the spread of noxious weeds. B-66

Appendix B Standard Practices and Mitigation Measures
7. Natural occurrences such as fire, drought, flooding, and prescribed land treatments should be combined with livestock management practices to move toward the sustainability of biological diversity across the landscape, including the maintenance, restoration, or enhancement of habitat to promote and assist the recovery and conservation of threatened, endangered, or other special status species, by helping to provide natural vegetation patterns, a mosaic of successional stages, and vegetation corridors, and thus minimizing habitat fragmentation. 8. Colorado Best Management Practices and other scientifically developed practices that enhance land and water quality should be used in the development of activity plans prepared for land use.

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9.0
9.1

Special Stipulations
General

1. The holder shall notify the BLM Authorized Officer (AO) at least 24 hours prior to the commencement of any surface-disturbing activities under this grant. The BLM contact person is Christina Stark, Grand Junction Field Office, 2815 H Road, Grand Junction, Colorado 81506, phone (970) 244-3022. a. This authorization is contingent upon receipt of and compliance with all appropriate federal, state, county, and local, permits. The applicant shall be responsible for obtaining all necessary environmental clearances and permits from all agencies (U.S. Army Corps of Engineers, Colorado Division of Wildlife, U.S. Fish and Wildlife, U.S. Forest Service, Colorado Department of Transportation, Colorado Department of Health and Environment, County Health Department, etc.) before commencing any work. Without all clearances and permits, this authorization shall be not in effect. Applicant shall assume all responsibility and liability related to potential environmental hazards encountered in connection with work under this authorization. 2. The holder shall construct, operate, maintain and reclaim the ROW and all work areas in strict conformity with the submitted application and BLM stipulations. 3. Copies of the ROW grant with the stipulations shall be kept on-site during construction and maintenance activities. All construction personnel shall review the grant and stipulations before working on the ROW. 4. The holder shall notify all existing ROW holders in the project area prior to beginning any surface disturbance or construction activities. The holder shall obtain an agreement with any existing ROW holders or other parties with authorized facilities that cross or are adjacent to those of the holder to assure that no damage to an existing ROW or authorized facility will occur. The agreement(s) shall be obtained prior to any use of the ROW or existing facility. 5. The exterior boundaries of the construction area shall be clearly flagged prior to any surface disturbing activities. 6. The holder shall promptly remove and dispose of all waste caused by its activities. The term "waste" as used herein means all discarded matter including, but not limited to, human waste, trash, garbage, refuse, petroleum products, ashes, and equipment. No burning of trash, trees, brush, or any other material shall be allowed. 7. Proper precautions shall be taken at all times to prevent or suppress fires. Range or forest fires will be reported to the BLM Grand Junction Field Office. The operator shall be responsible for the prevention and suppression of fires on public lands caused by its employees, contractors, or subcontractors. During conditions of extreme fire danger, surface use operations may be either limited or suspended in specific areas, or additional measures may be required by the BLM. 8. Sixty days prior to termination of the ROW, the holder shall contact the AO to arrange a joint inspection of the ROW. This inspection will be held to agree to an acceptable B-68

Appendix B Standard Practices and Mitigation Measures
termination and rehabilitation plan. This plan shall include removal of facilities, recontouring, and seeding at the discretion of the AO. The AO must approve the plan in writing prior to the holder's commencement of any termination activities. 9. Applicant shall comply with all State and County regulations and permit requirements. 10. Stormwater BMPs identified in the Storm Water Management Plan shall be in place prior to any earth-disturbing activity. Additional BMPs will be installed as determined necessary by the AO. 9.2 Roads 1. Roads will be constructed and maintained to BLM road standards (BLM Manual Section 9113). All vehicle travel will be within the approved driving surface. A copy of the manual can be obtained from the BLM Grand Junction Field Office. 2. No signs or advertising devices shall be placed on the premises or on adjacent public lands, except those posted by or at the direction of the AO. 3. If requested by the AO the holder shall furnish and install culverts of the gauge, materials, diameter(s), and length(s) as indicated and approved. Culverts shall be free of corrosion, dents, or other deleterious conditions. Culverts shall be placed on channel bottoms on firm, uniform beds which have been shaped to accept them and aligned to minimize erosion. Backfill shall be thoroughly compacted. No equipment shall be routed over a culvert until backfill depth is adequate to protect the culverts. 4. All maintenance and road improvement activities shall be confined to the existing road surface and ditches, unless prior approval is obtained from the AO. 5. All existing authorized roads used for construction shall be maintained in as good as, or in better than existing condition. This may include, but is not limited to, roadway surface repairs (blading the roadway), cleaning ditches and drainage facilities, and dust abatement. After construction, existing roads shall be restored to meet or exceed conditions existing prior to construction. All road maintenance activities must be approved by the AO. a. As part of the required reclamation, all disturbed areas shall be seeded with a seed mixture suitable to specific site conditions. This mixture shall be approved prior to reclamation by the AO. All seed mixtures must be certified to be weed-free. Application rates are for pure, live seed. Certification and seed tags must be submitted to the Field Manager within 30 days of seeding. b. Prepare seedbed by contour cultivating four to six inches deep. Drill seed after September and before soil is frozen, covering seed 0.5 to 1 inch deep. Where seed cannot be drilled, broadcast application shall be used at twice the recommended application rate, and cover 0.5 to 1 inch deep with a harrow or drag bar. Disturbed portions of the ROW surface shall be left rough and not smoothed to help facilitated seed germination and seedling survival. c. Seeding must be completed after September 15 and prior to December 15.

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Appendix B Standard Practices and Mitigation Measures
9.3 Transmission Lines 1. Unless otherwise agreed to by the AO in writing, transmission lines shall be constructed in accordance to standards outlined in "Suggested Practices for Raptor Protection on Power Lines," (Raptor Research Foundation, Inc. 1981). The holder shall assume the burden and expense of proving that pole designs not shown in the above publication are "eagle safe." Such proof shall be provided by a raptor expert approved by the AO. The BLM reserves the right to require modifications or additions to all transmission line structures placed on this ROW, 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. 2. Holder shall evenly spread the excess soil material excavated from the pole holes within the ROW and in the immediate vicinity of the pole structure. 9.4 Railroad Spur and Water Pipeline 1. Topsoil shall be conserved during excavation and reused as cover on disturbed areas to facilitate re-growth of vegetation. Topsoil shall only be used for reclamation and shall not be used to bed or pad the pipe during backfilling. 2. Vegetation removed from the ROW will not be placed in piles or windrows. All cut vegetation shall either be removed completely from the site or chipped and scattered onsite. 3. If traffic is disrupted during construction then suitable traffic control measures will be implemented. Traffic control measures will include warning signs, barriers or flagmen unless otherwise approved by the AO. 4. Open trenches shall be maintained in a safe condition. Trenches adjacent to access roads shall be covered and/or warning barriers erected upon completion of daily construction or at anytime personnel are not present on the construction site. 9.5 Cultural Resources 1. The applicant is responsible for informing all persons in the area who are associated with this project that they will be subject to prosecution for knowingly disturbing historic or archaeological sites, or for collecting artifacts or fossils. Any cultural and/or paleontological resource (historic or prehistoric site or object) discovered by the holder, or any person working on his behalf, on public or Federal land shall be immediately reported to the AO. Holder shall suspend all operations in the immediate area of such discovery until written authorization to proceed is issued by the AO. An evaluation of the discovery will be made by the AO to determine appropriate actions to prevent the loss of significant cultural or scientific values. The holder will be responsible for the cost of evaluation and any decision as to proper mitigation measures will be made by the AO after consulting with the holder. 2. Pursuant to 43 CFR 10.4(g), the holder of this authorization must notify the AO, by telephone, with written confirmation, immediately upon the discovery of human remains, funerary items, sacred objects, or objects of cultural patrimony. Further, pursuant to B-70

Appendix B Standard Practices and Mitigation Measures
43 CFR 10.4(c) and (d), you must stop activities in the vicinity of the discovery and protect it for 30 days or until notified to proceed by the AO. 9.6 Soils and Vegetation 1. When saturated soil conditions exist on or along the ROW, construction shall be halted until soil material dries out sufficiently for construction to proceed without undue damage and erosion to the ROW. 2. The holder shall disturb and remove only the minimum amount of soils and vegetation within the authorized ROW necessary for the construction of structures and facilities. 3. All disturbed areas shall be recontoured to blend with the natural topography to the satisfaction of the AO within 30 days of project completion or cessation of construction activity. 4. The grant holder shall provide satisfactory reclamation of all sites disturbed by their activity. This may include installation of erosion control devices and seeding at the discretion of the AO. 9.7 Noxious Weeds 1. All construction equipment and vehicles shall be clean and free of weeds and weed seeds prior to moving equipment onto public lands and start of construction. Cleaning shall be accomplished by pressure-washing with water unless otherwise approved by the AO. 2. On the ROW, the holder shall monitor and control those noxious weeds that may occur or be found, as listed in the booklet, Noxious Weeds of Mesa County. If chemical control is necessary, use of pesticides shall comply with the applicable Federal and State laws. Pesticides shall be used only in accordance with their registered uses and within limitations imposed by the Secretary of the Interior. Prior to the use of pesticides, the holder shall obtain from the AO written approval of a plan showing the type and quantity of material to be used, the pest(s) to be controlled, method of application, location of storage and disposal of containers, and any other information deemed necessary by the AO. Emergency use of pesticides shall be approved in writing by the AO prior to such use. 9.8 Threatened and Endangered Species 1. The BLM AO shall be notified at least 30 days prior to any non-emergency related surface disturbance or maintenance activities. The AO may require the completion of a special status plant species survey by a third-party contractor at the expense of the holder, or the BLM may choose to complete the survey. The BLM may take actions or make recommendations to protect any special status plant populations identified near or on the ROW. 9.9 Hazardous Materials 1. The holder shall comply with all applicable federal laws and regulations existing or hereafter enacted or promulgated. In any event, the holder shall comply with the Toxic B-71

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Substances Control Act of 1976, as amended (15 U.S.C. 2601 et seq.) with regard to any toxic substances that are used, generated by or stored on the ROW or on facilities authorized under this ROW grant (see 40 CFR, Part 702 799 and especially, provisions on polychlorinated biphenyls, 40 CFR 761.1 761.193). Additionally, any release of toxic substances (leaks, spills, etc.) in excess of the reportable quantity established by 40 CFR, Part 117 shall be reported as required by the Comprehensive Environmental Response, Compensation and Liability Act of 1980, Section 102b. A copy of any report required or requested by any federal agency or state government as a result of a reportable release or spill of any toxic substances shall be furnished to the AO concurrent with the filing of the reports to the involved Federal agency or State government. 9.10 Visual Resources

1. To limit changes in the observable character of the landscape, as many trees as possible shall be retained. 2. To mitigate straight line visual effects of cut slopes or cleared vegetation, adaptive management techniques may be required by BLM staff to create an irregular shape or mosaic pattern. 3. Surface facilities shall be painted a non-reflective Shale Green color that blends with the natural environment, or another color as determined by the AO. 9.11 Health and Safety

The holder shall comply with applicable state standards for public health and safety, environmental protection and siting, construction, operation and maintenance, if these state standards are more stringent than Federal standards for similar projects.

10.0 References
4Offsets, LLC. 2008. Purchase CO2 Offsets. http://www.4offsets.com/buy-carbon-offsets.php. Accessed July 24, 2008. California Climate Action Registry. No date. Frequently Asked Questions. http://www.climateregistry.org/offsets/frequently-asked-questions.html. Accessed July 24, 2008. Colorado Division of Wildlife (CDOW). 2008. Recommended Buffer Zones and Seasonal Restrictions for Colorado Raptors. National Interagency Fire Center (NIFC). No date. Prescribed Fire Treatments. Available online at http://www.nifc.gov/fuels/overview/prescribedTreatment.html Accessed July 14, 2008. Union Pacific Railroad, Burlington Northern Santa Fe Railroad, Central Oregon and Pacific Railroad, California Department of Forestry and Fire Protection, United States Forest Service, and the Bureau of Land Management. 1999. Railroad Fire Prevention Field Guide. April 1999. Available online at http://cdfdata.fire.ca.gov/pub/fireplan/fpupload/fppguidepdf100.pdf. Accessed July 14, 2008. B-72

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U.S. Bureau of Land Management (BLM). 1997. BLM Colorado’s Standards and Guidelines. February 3,1997. http://www.blm.gov/co/st/en/BLM_Programs/grazing/ rm_stds_guidelines.html. Accessed May 15, 2008.

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APPENDIX C M I N I N G O P E R AT I O N S A N D S U B S I D E N C E

Appendix C Mining Operations and Subsidence
TABLE OF CONTENTS Page Introduction................................................................................................................................. C-1 Room-and-Pillar Mining Operations .......................................................................................... C-1 Longwall Mining Operations...................................................................................................... C-3 Mechanisms of Subsidence......................................................................................................... C-5 Subsidence-Related Deformation ............................................................................................ C-5 Factors Controlling Subsidence............................................................................................... C-6 Prediction of Subsidence ......................................................................................................... C-8 The Subsidence Event ........................................................................................................... C-10 List of Figures Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 Figure 8 Figure 9 Figure 10 Figure 11 Figure 12 Conceptual Room-and-Pillar Mining.................................................................C-12 Conceptual Longwall Mining ............................................................................C-13 Typical Longwall Panel Layout in the United States .......................................C-14 Plan View of Surface Subsidence Over a Longwall Panel ................................C-15 Conceptual Representation of Subsidence Deformation Zones ........................C-16 Potential Collapse Heights ................................................................................C-17 Critical Panel Width for Maximum Subsidence ................................................C-18 NCB Panel Width/Depth Maximum Subsidence (Smax) Prediction ....................C-19 NCB Subsidence Profile Graph .........................................................................C-20 Critical Panel Width for Maximum Tensile (+E) and Compressive (-E) Strains ................................................................................................................C-21 NCB Maximum Strain and Slope Prediction Graph..........................................C-22 NCB Horizontal Strain Profile Graph................................................................C-23

C-i

Appendix C Mining Operations and Subsidence

C-ii

Appendix C Mining Operations and Subsidence
Introduction
Coal mining involves the extraction of coal seams or beds. Although the thickness of a coal seam will vary, minable seams generally are continuous over large areas. When the deposit is close to the ground surface (less than approximately 200 feet deep), it is generally mined using surface methods. Deeper deposits are generally mined by underground methods. Geologic strata above and below a coal seam are known as overburden and underburden, respectively. The overburden and underburden strata that are actually in contact with coal in an underground mine are called the “roof” and “floor,” respectively. Blocks of coal left in place to help support the roof of the underground mine are called “pillars.” Removal of coal by underground methods creates a limited void in the stratigraphic column. As a block of coal is extracted, natural forces act on the stability of the overburden and if large enough, cause the overlying column to subside. Even in the strongest formations, large underground mine openings will eventually be filled by the collapse of the overburden and may result in crushing of adjacent pillars by the transfer of the overburden load previously carried by the mined coal. Underground coal mining methods are generally classified, or distinguished from each other, by the type of support used to prevent the roof from collapsing prematurely, endangering workers and equipment.

Room-and-Pillar Mining Operations
Room-and-pillar mining is a type of underground extraction used where the roof is supported primarily by pillars. Coal is extracted as a group of rectangular shaped parallel rooms, or entries, are driven into the coal seam. Crosscuts are periodically driven between entries. Parts of the coal seam are left between the entries and crosscuts and serve as pillars to support the roof. The pillars are arranged in a regular pattern, or grid, to simplify planning and operation. Pillars can be of any shape but are usually square or rectangular. The dimensions of the rooms and pillars depend on many design factors, including the stability of the immediate roof and floor, the strength of the coal in the pillars, the thickness of the coal seam extracted, and the depth of mining. A series of entries are designed to outline an area called a panel or block of coal that defines a working section of a mine. Panels are typically bordered by barrier pillars in order to permit easier isolation of abandoned panels from active parts of a mine. Typically, coal seams mined by underground methods in the United States range in thickness from 2.5 to 15 feet. For roof control and safety reasons, the width of the rooms, or entries is generally limited to 20 feet. The spacing, or centers, between entries varies from 40 to 100 feet depending on the stress distributions determined in the design and operation of the mine. Spacing between crosscuts is limited by ventilation required and is subject to federal and/or state safety laws (usually limited to approximately 100 feet). A general representation of room-andpillar mining is shown in Figure 1, Conceptual Room and Pillar Mining. In underground coal operations, there are two types of room-and-pillar mining: • • Conventional room-and-pillar mining Continuous room-and-pillar mining

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Appendix C Mining Operations and Subsidence
Conventional mining involves a cyclical system of extraction, employing mobile equipment to conduct the production cycle of operations as follows:. • • • • • Undercut the coal face Load overlying holes in the coal seam with explosives Blast Load broken coal Install roof bolt or other support

In continuous room-and-pillar mining, the first four unit operations of conventional mining are eliminated and performed by a high-performance continuous-mining machine. In the United States, most room-and-pillar mining is conducted using a continuous-miner system which includes: • • • A coal extraction machine (continuous miner) A coal haulage system (shuttle cars and conveyor belts) A ground support system (roof bolts and pillars)

The continuous miner is electric and hydraulic powered and track-propelled. Major components of this machine include a rotating-cutting drum and a gathering system beneath the cutting drum which loads an internal conveyor. The machine operator drives the rotating-cutting drum which is situated at the front (head) of the machine to the unmined coal face, activates the hydraulic pistons that force the rotating-cutting drum into the coal and cuts coal out of the coal face. The gathering arms which are located on an inclined plate beneath the rotating cutting drum shifts the cut coal to the internal conveyor for transfer to the rear (tail) of the machine. A rear, articulating conveyor then transfers the coal to independently-operated shuttle cars or a series of short transfer conveyors. The shuttle cars (10 to 15 tons per car) or transfer conveyors are used to transport mined coal from the continuous miner to a conveyor belt transfer point within the mine. Shuttle cars are either electric or diesel powered, 2- or 4-wheel drive, and have either a conveyor or push-ram system to discharge the coal to the stationary conveyor belt system which transports coal outside the mine portal, usually to a run-of-mine (ROM) coal stockpile. Pillars and roof bolts are used to support the roof and overburden. Solid pillars of coal are left in place within each panel during the initial (advance) mining stage to support the overburden above the panel and along the main access corridors (main entries) of the mine. Support of the immediate roof over panel entries and crosscuts is typically provided by the use of roof bolts. Roof bolts are long steel rods or wire-rope cables anchored in holes drilled into the roof rock. Bolt anchorage is provided by either resin glue or mechanical anchors. The bolts create a supporting “beam” of rock by bonding or “bolting” several layers of the immediate roof-rock strata together. The general mining/production sequence allows for the continuous miner to advance about 20 feet before the roof of the mined area must be secured with roof bolts. More than one continuous-miner may be advancing entries and crosscuts in one panel, in order to allow for uninterrupted mining, i.e., while roof bolts are being installed in some entries, mining, loading and haulage can continue in other panel entries. C-2

Appendix C Mining Operations and Subsidence
As a general rule, 15 to 70 percent of the coal within a panel remains in place in the form of pillars after the rooms are mined on the advance (partial extraction). To increase coal recovery, the roof can be temporarily reinforced with props and/or additional bolts so that some portion of those pillars not required to temporarily support and to protect the active entries can be systematically removed on the retreat from a panel (full extraction). In this second stage of mining, pillars are “robbed” (partially removed) as the mining equipment “retreats” from each advance mined room. As pillar-robbing progresses back toward the panel access, the rooms are allowed to cave in, and the mined-out panel is sealed and abandoned. Pillar robbing can be anticipated to reduce the coal left in place in the form of pillars to 10 to 60 percent of the coal in the panel.

Longwall Mining Operations
Longwall mining is an underground extraction method used in generally flat-lying, tabular coal deposits. A “long” face is established across a panel, which is bounded on both sides by entries. These entries are known as the “headgate” entries and the “tailgate” entries. The headgate entries are used for the passage of intake air and the transportation of coal, personnel, and supplies, while the tailgate entry is used for the passage of the return air. A general representation of a longwall mining face area is shown in Figure 2, Conceptual Longwall Mining. The longwall panel layout is simple and conducive to good ventilation, and crews always work under heavily supported roof. Since the longwall system involves caving across the entire face width, no coal is left as residual pillars within the block of coal, as must be done in room-andpillar mining. Therefore, coal recovery is higher for longwall mining. Depth of overburden for a longwall operation can vary from 200 to over 2,500 feet, with coal extraction thickness ranging from 4 to 15 feet. Panel width and panel length are usually determined by experience, based on the size and shape of the coal deposit, geologic conditions, and the capacities of the transportation, ventilation, and power equipment that can be supplied. In the United States, the panel width typically ranges from 700 to 1,200 feet; panel length also varies, ranging from 3,000 to over 15,000 feet. While the width of the panel face, or wall, is measured in hundreds of feet, the actual working area is narrow, measured in feet out from the face. A longwall system is kept open, by a series of heavy-duty, electric and hydraulic powered, yielding supports that form a cantilever or umbrella of protection over the face. As a cut, or slice, is taken along the panel face, the supports behind the shearer retract, advance and re-engage, allowing the roof to cave in the mined-out area behind the supports. The caved material is known as the “gob.” A very old method, longwall mining originated in European coal mines in the seventeenth century and has widespread use in coal-producing countries outside the United States. Only since the 1960s, when self-advancing, hydraulic support systems (chocks and shields) were perfected, has longwall mining been accepted in the United States. Other innovations that have led to its growing use in coal fields are the development of mobile, flexible, armored conveyors and high-speed continuous longwall mining machines (shearers). Longwall mining operations in the United States are predominantly of the “retreating” type. That is, the headgate, tailgate, starter and recovery entries are initially developed completely around the block of coal to be mined. Then the longwall mining system is erected in the starter C-3

Appendix C Mining Operations and Subsidence
room and the longwall face “retreats” from the starter room at the back of the panel toward the shield recovery room separated from the main entries by a barrier pillar. See Figure 3, Typical Longwall Panel Layout in the United States. Longwall development is strikingly similar to the development for room-and-pillar mining. Longwall operations in the United States are conducted with a longwall mining system. As with the continuous miner, the longwall system will include: • • • A coal cutting (extraction) machine (shearer). A coal haulage system (face conveyor and headgate panel conveyor). A roof support system (shields).

Whereas, the continuous-mining system involves several independently operated pieces of equipment to mine coal, the longwall mining system is totally integrated, with all of the necessary equipment interconnected. For example, the longwall mining system, the shearer actually rides on top of the face conveyor and the shields are physically connected to the face conveyor. The shearer, like the continuous miner, is electric and hydraulic powered. The major components of this machine are the rotating-cutting drums and the tram system. The drums, located at each end of the machine, are limited to an up-down movement. The machine operator drives the rotating-cutting drums into the coalbed as the machine trams laterally along the face on the face conveyor, thereby cutting coal from the coal face. Cut coal falls to the floorsupported face chain conveyor for transport to one end of the longwall, the “headgate.” There, the coal is transferred to a belt conveyor system that transports the coal outside the mine portal. The opposite end of the chain conveyor from the headgate is across the ‘‘tailgate.” Longwall roof support is provided at the face by the hydraulic roof supports (shields). Major components of the shields include canopy, hydraulic cylinders, hydraulic controls, and the base. The canopy is a thick, reinforced-steel plate that is pushed against the roof by the hydraulic cylinders to support the weight of roof rock from four to more than ten times the shearing height while coal removal operations continue in the shielded area below. Shields are generally 5 feet wide, vary from 4 to 15 feet high, and have a design-load capacity of 500 tons or more per shield. The base length of the shield is relatively short, allowing the face conveyor to sit on the floor in front of the shield bases. Shields are designed to be large enough to safely cover the face conveyor, shearer, and workers. In the longwall system, individual shields are installed next to each other along the entire longwall face, from the face conveyor headgate to its tailgate. See Figure 2, Conceptual Longwall Mining. The mining/production sequence involves cutting (shearing) a section of coal face, typically 30 to 42 inches deep, from the headgate to the tailgate, using hydraulic rams to move the face conveyor up against the face of the fresh-cut coal seam. Hydraulic rams attached to the face conveyor then move individual shields forward. The unsupported roof behind the shields is allowed to cave to the floor. As slices of the block of coal are systematically removed, the mined area is gradually abandoned.

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Appendix C Mining Operations and Subsidence
Mechanisms of Subsidence
Removal of coal deposits by underground mining methods creates voids that are filled when the stress concentrations in the roof of the openings exceed the strength of immediate roof rock allowing the immediate roof to collapse unless supported. The concentration of more and more overburden load onto pillars will eventually crush the pillars when sufficient extraction has occurred. Deterioration of pillars over time has weakened pillars to the point that they fail. These phenomena all lead to potential subsidence of the main roof, the overburden, to deflect downward. The complete removal of large areas of coal by longwall mining allows the almost immediate collapse of the immediate roof and downward deflection of the overburden to the ground surface, known as subsidence. Vertical lowering typical of a flat-lying ground surface over and adjacent to an underlying longwall panel is indicated on Figure 4, Plan View of Surface Subsidence over a Longwall Panel. Subsidence-related deformation of rocks above underground mines can consist of fracturing, fragmentation, caving and chimney collapse, sagging and bedding-plane separation. However, caving of the immediate roof into mined areas does not always translate into surface subsidence. The type of deformation that occurs, and whether the deformation reaches the surface, depends on a number of factors, including rock type, percent swell of overlying rock, rock strength, thickness and competence of overlying beds, mine layout, mine depth, mining height and how far a particular competent horizon lies above the void in the mined area. The magnitude, extent, and duration of subsidence can be minimized by an efficient mine layout, proper barrier and gateroad pillar design, and a rapid and efficient mining system.

Subsidence-Related Deformation
In the overburden above mined areas, three zones of deformation tend to develop in response to subsidence, as shown on Figure 5, Conceptual Representation of Subsidence Deformation Zones. In the caved (fragmented) zone, rocks of the immediate roof are expected to fragment, collapse, and rotate. This zone in coal measure rocks is typically between two and four times thicker than the longwall mining height, but can be as much as ten times thicker than the mining height (the void produced by mining) over adverse four-way entry and crosscut room-and-pillar intersections and similar four-way gateroad intersections. This is shown on Figure 6, Potential Collapse Heights. Directly above the caved zone, is the fractured zone, where rock strata are expected to fracture into bedding bounded blocks and deflect downward while maintaining bedding continuity. Bedding-plane separations may, however, develop. This zone can be as much as an additional 18 times thicker than the mining height, depending primarily on the competency of the rocks in this section of the overburden. In the third zone, the deformation zone (which some engineers separate into two zones, the continuous deformation zone and the near surface deformation zone) rocks should sag downward without major fracturing, but bedding-plane separations and discontinuous tension cracks can still occur in tensile strain zones at the top and bottom of individual beds. This zone can extend from the top of the fractured zone to the ground surface. After the deformation process, fractures that developed in the softer mudstones, siltstones, shales and softer sandstones tend to close, while fractures that developed in stronger and more brittle rocks may remain open indefinitely. If deformation reaches the surface, subsidence will typically appear as basins or depressions, pits, and/or open cracks. Subsidence basins can form above room-and-pillar mines with pillars C-5

Appendix C Mining Operations and Subsidence
that were initially stable but crushed (failed) after a period of deterioration, or during the robbing of pillars on the retreat or above longwall panels on the retreat. These basins are typically ovaloidal in plan and trough-shaped in section because the panels are large and rectangular, and because coal seams often are nearly horizontal. Subsidence pits (chimneys to the surface) can form above shallow, almost always less than 200-foot deep, intersections of entries and crosscuts, particularly in room-and-pillar mines where the pillars have not been robbed. The overburden directly above the pillars continues to be supported, while the overburden above the mined area collapses into the mined-out rooms and intersections. Horizontal strain, both tensile and compressive, results from lowering of the surface during subsidence. Tension that can cause cracks occurs as the surface begins to subside and stretch over the outer edges of an undermined panel. Compression develops toward the center of a panel and closes some of the tension cracks in the ground that bend back toward its pre-mining slope. Subsidence induced changes in surface slope are generally minor, having a magnitude commonly less than 3 degrees. Tension cracks are more apparent than compression features because rocks are stronger in compression. Tension cracks are more abundant in solid rock than they are in unconsolidated materials. At the surface, tension cracks can range from small (less than an inch), subtle features that are difficult to recognize to fractures that are several feet wide and several feet deep. Surface fractures may be temporary, with many closing during successive subsidence events, after natural deposition of sediment, or when frost heaving fills them. Surface tension cracks over the edges of individual longwall panels, over gateroad pillars between panels, over the barrier pillars at the ends of individual panels and over barrier pillars adjacent to panel groups, frequently referred to as sections, and along edges of the mined area (the mining boundaries) may remain open indefinitely. This is most evident in areas where brittle sandstones or other rocks crop out. The surface soil cover will have an influence on the cracking that is actually visible at the surface. Unconsolidated deposits of alluvium, colluvium, and soil tend to obscure surface cracks.

Factors Controlling Subsidence
Several factors control the area, amount, rate and duration of subsidence. Mining factors include mining method, mine geometry, extraction ratio, height of the mine workings, and mining rate. Geologic factors include depth of the coal seam, along with the thickness, lithology, strength, structure, fracture and joint set orientation, and bulking or swell factor of the overburden. The subsidence factor and the angle of draw are used to describe the maximum vertical displacement and the areal extent of subsidence, respectively. The mine geometry (or mine design) determines the size and configuration of the rooms, pillars, and panels, the height of the openings and pillars; and the spatial relation to any abandoned mines that may be located above and/or below the active mine. Generally, mines are designed so that the subsidence process can take advantage of joints in the overburden. This can smooth subsidence by minimizing sagging of the immediate roof before the roof collapses, minimizing the potential of periodic weighting of either pillars or the coal exposed in the longwall face. Although subsidence can be reduced by leaving pillars for support, this procedure may only delay subsidence because pillars and roof rocks generally deteriorate and yield with time and weathering.

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Appendix C Mining Operations and Subsidence
The extraction ratio is the ratio of the amount of coal extracted to the total amount of coal in either the panels, entries or the mine area. Longwall mining, because it potentially extracts 100 percent of the coal between the gateroad pillars, generally achieves an overall panel extraction ratio of about 78 percent of the total coal in the panel, including the gateroad pillars on either side of the panel. The extraction ratio typically decreases to about 72 percent when the barrier pillars within a mining section are included. Room-and-pillar mining generally extracts about 64 percent of the total coal within individual panels on the advance. Pillar robbing upon retreat from a panel generally increases the extraction ratio to about 81 percent of the total coal between the panel barrier pillars. When barrier pillars within a mining section are included the recovery drops to about 51 percent of the total coal in an individual panel employing advance mining only, and to about 70 percent when barrier pillars within a mining section are included. Recovery from advance and retreat room-and-pillar mining is generally nearly as much of the coal as does longwall mining. However, longwall mining has proven to be generally safer, more productive and effective at greater depths than room-and-pillar mining. The mining method also influences the amount of subsidence. Longwall mining usually results in more subsidence than room-and-pillar mining, partially because of its generally greater extraction of coal and partly because the stump pillars left within the panels when robbing do not crush out flat when they fail under the overburden load. Efficient robbing of pillars, however, can result in surface subsidence nearly equal in magnitude to that associated with longwall mining. Subsidence above room-and-pillar mining areas is also less predictable and more variable in surface expression than above longwall panels because the extraction ratios and heights of caving are more variable. Long-term deterioration of coal pillars can delay the resulting surface subsidence decades and the timing of a pillar collapse cannot be accurately predicted. The mining rate also affects subsidence. When the mine face is extracted at an even and rapid rate, smoother subsidence profiles occur with less differential movement. The extracted mining height, width of the individual panel with respect to the depth of the deposit and thickness of the overburden control maximum subsidence. The subsidence factor is the ratio of maximum surface subsidence to the seam mining height and is often expressed as a percentage. For example, if a maximum 7 feet of subsidence occurred over a mine panel with a 10-foot mining height, then the subsidence factor would be 70 percent. In the Western United States, subsidence factors range from about 45 to 90 percent of the thickness of coal extracted. However, the subsidence factor will increase with increasing panel width, unless both the previous and new panel widths exceed the critical width, which ranges from approximately 1.0 to 1.4 times the depth. Figure 7, Critical Panel Width for Maximum Subsidence, indicates that the maximum surface subsidence (Smax) over a longwall panel develops when panel width reaches and exceeds the critical width. The load on the collapsed roof rock, gob, increases as panel width increases up to the limiting critical panel width. The load on the central portion of panels wider than critical is the weight of the overburden, with none of the overburden load transferred to adjacent unmined coal or barrier pillars. The angle of draw identifies the measurable limits of subsidence beyond the boundaries of the mined area, i.e. the areal extent of subsidence occurring at the ground surface will be larger than the area extracted underground. It is expressed in degrees from vertical above the edge of the mined area. For example, if the angle of draw were 20 degrees and the overburden were 1,000 feet thick, then measurable subsidence would be anticipated as much as 364 feet beyond the edge C-7

Appendix C Mining Operations and Subsidence
of the mined area. In the western United States, subsidence angles of draw range from about 5 to 30 degrees. The angle of draw appears to be dependent on the proportion of different rock types present in the overburden. The angle of draw increases with an increasing proportion of lower strength mudstone and shale in the overburden. The angle of draw decreases with an increasing proportion of stronger sandstone and limestone in the overburden. Sagging, caving, and fragmentation are governed by the strength and structure of the overburden. The composition of the mineral grains and the cements that bind the grains together affect the strength of the rocks. The dip of faults and fractures in the overburden may present low shear strength sliding surfaces that can influence, or even locally control, the angle of draw. The strength and structure of the overburden rocks are considered when determining room, pillar, and panel orientation. The percent swell, or the volumetric percent increase of fragmented rocks relative to their undisturbed in-place volume, is a factor influencing subsidence. The bulking factor is determined by the size and shape of the broken rocks, the contact stresses among rock fragments within the fragmented zone, and the relative strengths of the affected rocks. The percent swell is generally lowest where the overburden is composed of soft claystones and thinly bedded shales, and highest where hard, thickly bedded to massive sandstones and limestones predominate. If rock fragments randomly fall to the floor of the mined area, and if strong, massive rocks occur in the collapsed, fractured and deformation zones, then the percent swell is higher. Higher percent swell of the overburden results in filling the mined volume with less collapsed rock and, therefore, in less subsidence of the overlying rocks and reduced tension and compression at the surface.

Prediction of Subsidence
Subsidence associated with underground mining is anticipated, and its magnitude and extent can be predicted. Often, predictions of maximum surface subsidence and horizontal tensile and compressive strains are used to help assess the secondary impacts to other resources (both human and natural). Data collected during actual subsidence are used to verify that measured subsidence does not exceed predicted values. A method of calculation developed by the British National Coal Board (NCB) on the basis of surface and underground measurements at 177 named and 10 unnamed longwall panels offers one of the most comprehensive, conservative, and accurate techniques for predicting subsidence, surface strains and slope (tilt) associated with longwall mining. Other researchers have modified it for the generally greater proportion of stronger sandstone strata in the overburden overlying coal mines in the western United States. Inputs to the longwall subsidence prediction model are depth, mining height, frequently less than seam thickness, and panel and gateroad geometry. Inputs to room-and-pillar subsidence prediction are the same except percent extraction and final panel pillar, entry and crosscut geometry replaces longwall geometry. Subsidence profiles can be used to illustrate subsidence and strain predictions above and across longwall or room-and-pillar retreat mined panels. In this example, the longwall panels are in a virgin area (not previously subsided), 800 feet (244 m) wide including the 20-foot width of the gateroad entries on both side of the longwall block, overburden is about 1,000 feet (305 m) thick and mining height is 11 feet. The panel width to panel depth based maximum subsidence prediction can be conservatively made using Figure 8, NCB Panel Width/Depth Maximum C-8

Appendix C Mining Operations and Subsidence
Subsidence (Smax) Prediction, predicts 0.76 times the 11-foot mining height, or 8.4 feet. Applying the virgin ground correction of 0.9 for the previously subsided NCB model reduces the predicted maximum subsidence factor to 0.68 and the predicted maximum subsidence (Smax) to 7.5 feet. Maximum subsidence would occur over the middle of each panel with the same Subcritical width/depth ratio. Figure 9, NCB Subsidence Profile Graph, permits the conservative estimation of subsidence for any distance from the center of a panel for any point along a cross section perpendicular to the long axis of any panel whose location is at least 0.7 times its depth from either end of the panel, i.e. the center of the panel is not affected by the barrier pillars at the panel ends. Final subsidence over the gateroad pillars between two adjacent panels is dependent on whether the gateroad pillars are designed to be rigid or to yield when the first panel is retreated past or if at least one of the gateroad pillars is designed to function as a rigid pillar or to crush when the face of the second panel has retreated well past. If the two gateroad pillars in the example above are 40-foot wide and separated by a 20-foot wide entry and considered rigid, the distance from the panel centerline to the center of the gateroad is 450 feet (800/2 + 40 + 20/2). Enter the Y-axis of Figure 9, NCB Subsidence Profile Graph, for the panel width/depth ratio of 0.8 (800/1000). The X-axis entry point is 0.45. These two lines converge at approximately 0.173 times Smax, 7.5 feet, or 1.3 feet of subsidence when the first panel has been mined and subsidence has stabilized and twice that, 2.6 feet after the second panel has passed. Additional subsidence will take place if the gateroad pillars crush. An available method of estimating the additional subsidence resulting from gateroad pillar crushing assumes that the gateroad pillars are part of a room-and-pillar panel. The method requires the pillar dimensions and extraction percentage. Tensile stretching and compressing of the ground surface has been the greatest adverse subsidence impact, particularly in urban areas. Tensile strain develops at the ground surface above, outside and inside the boundaries of a mined and subsided panel and compressive strain develops inside the area inside a mined panel. Figure 10, Critical Panel Width for Maximum Tensile (+E) and Compressive (-E) Strains, graphically demonstrates that sub-critical width panels will develop lower maximum tensile strain (+E) values than critical or super-critical width panels, but that the maximum compressive strain (-E) can be greater for sub-critical panels because the compressive strains from both sides of the sub-critical panel become additive toward the center of narrow sub-critical panels. Tensile strains are the cause of tensile cracking of the ground surface around the perimeter of an underlying longwall panel and compressive strains can cause pressure ridges to be forced up at the ground surface. Tensile and compressive strains exceeding the individual tolerances of all kinds of surface structures can cause severe damage. Strains on the order of 1,000 to 1,500 µε (micro-strain which is 0.001 in/in) may result in the cracking of gypsum plaster; gas mains may be at risk at 2,000 µε; cracks become obvious in monolithic reinforced concrete buildings, river beds and reservoirs may experience leakage and main railways damaged when subject to 4,000 µε and 6,000 µε may damage and distort 60-foot long residential buildings, main roads, structures steel, brick and even wood buildings will be distorted. The NCB subsidence study developed the graphical method of predicting maximum tensile (+E) and compressive (-E) strains based on maximum subsidence (Smax) and mining depth, as shown on Figure 11, NCB Maximum Strain and Slope Prediction Graph. The longwall example produced a maximum subsidence (Smax) of 7.5 feet, assumed an 800-foot panel width, a C-9

Appendix C Mining Operations and Subsidence
1000-foot panel depth, for an 0.8 width/depth ratio. Enter the X-axis with the 0.8 panel width/depth ratio, which crosses the EXTENSION (+E) line at a MULTIPLIER value of 0.64 and the COMPRESSION (-E) line at a MULTIPLIER value of 0.68. The predicted maximum tensile strain is: +E = 0.64(7.5/1000) = 0.004800 in/in (4800 µε) and the predicted maximum compressive strain is: -E = 0.68(7.5/1000) = 0.005100 in/in (5100 µε) Similarly, the tangent of the maximum slope angle (G) is: Tan G = 2.82(7.5/1000) = 0.02115 (G = 1.21°) The British NCB also produced a graphical method of predicting the location of maximum tensile and compressive strains across the subsidence trough. See Figure 12, NCB Horizontal Strain Profile Graph. In the longwall example case, with a panel width to depth ratio of 0.8, the maximum tensile strain (+E) is located on the overlying ground surface approximately 0.42 times the 1,000-foot panel depth on both sides of the panel centerline, or 420 feet. Subtracting onehalf the 800-foot panel width means that predicted maximum tensile strain (+E) is located approximately 20 feet outside both panel ribsides. The predicted location of the maximum compressive strain (-E) is 0.11 times the 1,000-foot depth from the panel centerline, or on the overlying ground surface approximately 110 feet on both sides of the centerline. The maximum compressive strain (-E) is predicted to be 290 feet inside the gateroad coal pillars that define the panel ribside. A monitoring program is generally implemented at underground mines to collect subsidence data. The measurements are typically periodic 3-dimensional horizontal and vertical monument locations. These data are used to verify that the predicted subsidence effects are not exceeded by the actual ground conditions and to detect mining induced impacts to surface resources, both predicted and not predicted. In addition, site specific angle of draw, subsidence factor, and tensile and compressive strains can be calculated from the measurements. A number of techniques and types of equipment can be used in subsidence monitoring programs: conventional ground surveying of monuments located over panels and extending out over unmined areas to measure monument locations and elevations at periodic intervals and calculate the average horizontal and vertical strain between monuments, vector movement and slope (tilt) between monuments; installation of extensometers to measure displacement between monuments and calculate strain; serial photographic surveying; analytical aerial triangulation; digital terrain modeling; surface observations; as well as surface water and spring monitoring. Global Positioning System Monitoring may not have the accuracy needed, but could potentially speed the process and decrease the cost. To be effective, monuments must be constructed so they are unaffected by movements unrelated to subsidence, such as soil heave due to freezing and thawing as well as shrinking and swelling of clay minerals in surface alluvium during dry and wet periods.

The Subsidence Event
Subsidence occurs when either the load of the overburden exceeds the ability of the roof rock to transfer the overburden load to adjacent unmined coal or barrier pillars, or the strength of the C-10

Appendix C Mining Operations and Subsidence
gateroad and/or barrier pillars is insufficient to the support the total overlying and arched load transferred from above the adjacent panels. The detailed scenario follows: Coal is removed to open up the mine void, and the roof support system is withdrawn or is advanced and removed. The immediate roof collapses and “bulks” into the mined volume. The main roof deflects downward onto the collapsed rock. As the main roof deflects, the ground surface follows. The maximum surface downward deflection is a percentage of the mining height, i.e. the subsidence factor. The surface sags downward behind the retreating longwall face or when room-and-pillar pillars are robbed, the pillars fail and the immediate roof collapses during retreat. The subsidence trough formed at the surface is wider than the mined areas, limited in extent outside the panel boundaries by the angle of draw. The retreat of the longwall face or when panel pillars are robbed and the immediate roof collapses during retreat in room-and-pillar mining, also extends the deformation in the overburden ahead of the moving retreat line. As coal is mined and the retreat progresses, the overburden rocks bend into the subsidence trough, new ground is placed in tension, and new surface fractures open up. When the mining face passes under and progresses away from a particular point on the surface, the area of tensile stress moves away as well. Settling, accompanied by compression, takes over behind the temporary area of tensile stress, and the tension fractures partially close. As the retreat line progresses and successive areas are undermined, this activity takes the form of a smooth subsidence wave on the ground surface. Longwall gateroad pillars and individual room-and-pillar panel pillars can be designed to yield or crush under the overlying and/or arched overburden load transferred. When panels or rooms are progressively mined alongside gateroad pillars, first on one side and later on the other side, gateroad pillar failure will increase subsidence of the overlying ground surface. Gateroad pillar failure can help smooth out surface irregularities and close some of the remaining surface cracks. Massive sandstones in the overburden can also assist in smoothing out irregularities when they act as “beams” and produce a more complete and uniform collapse of different size, shape and strength pillars. Subsidence movement over longwall mines and over room-and-pillar mines where pillars have been robbed tends to be relatively short-lived. Ninety to 95 percent of the subsidence is expected to occur once coal extraction in an area is complete. The remaining residual subsidence should be completed within 2 to 5 years after mining an individual panel has ceased. Some delayed subsidence may occur over isolated larger and stronger pillars that can deteriorate more slowly. Sudden subsidence events may occur over room-and-pillar mines where large pillars are deliberately left behind, i.e. not robbed on the retreat, to support the overburden. The pillar, room and crosscut dimensions are designed to support the overburden weight tributary to each pillar. Eventually, one pillar will deteriorate and yield to shed the unsupportable part of its tributary load, onto adjacent stronger pillars. The area of yielded pillars will grow until a group of several pillars will fail. Even the strongest pillar will eventually deteriorate and collapse. Where a room-and-pillar mined area is fairly shallow and thick and competent beds are present in the roof the overburden load can temporarily be transferred from overloaded pillars that yield to larger and/or stronger nearby rigid pillars. In such a situation, a large area of pillars may fail suddenly as a unit. Subsidence can occur abruptly when a competent overlying bed breaks and the overburden load suddenly tries to shift back onto yielded pillars. Here, the surface expression may not be as smooth as that previously described, and larger cracks can result. C-11

Appendix C Mining Operations and Subsidence
Additionally, a series of such sudden pillar failures can take place progressively, one group of pillars bordering a previously collapsed area will temporarily support the transferred load. However, those pillars will deteriorate more rapidly under the heavier load and after an unpredictable additional time another group of pillars may fail. Figure 1. Conceptual Room-and-Pillar Mining

C-12

Appendix C Mining Operations and Subsidence
Figure 2. Conceptual Longwall Mining

C-13

Appendix C Mining Operations and Subsidence
Figure 3. Typical Longwall Panel Layout in the United States

C-14

Appendix C Mining Operations and Subsidence
Figure 4. Plan View of Surface Subsidence Over a Longwall Panel

C-15

Appendix C Mining Operations and Subsidence
Figure 5. Conceptual Representation of Subsidence Deformation Zones

C-16

Appendix C Mining Operations and Subsidence
Figure 6. Potential Collapse Heights

C-17

Appendix C Mining Operations and Subsidence
Figure 7. Critical Panel Width for Maximum Subsidence

C-18

Appendix C Mining Operations and Subsidence
Figure 8. NCB Panel Width/Depth Maximum Subsidence (Smax) Prediction

C-19

Appendix C Mining Operations and Subsidence
Figure 9. NCB Subsidence Profile Graph

C-20

Appendix C Mining Operations and Subsidence
Figure 10. Critical Panel Width for Maximum Tensile (+E) and Compressive (-E) Strains

C-21

Appendix C Mining Operations and Subsidence
Figure 11. NCB Maximum Strain and Slope Prediction Graph

C-22

Appendix C Mining Operations and Subsidence
Figure 12. NCB Horizontal Strain Profile Graph

C-23

APPENDIX D SUBSIDENCE

Draft Environmental Impact Statement/Subsidence
TABLE OF CONTENTS
Page No. 1.0 2.0 3.0 INTRODUCTION............................................................................................... D-1 DEFINITION OF TERMS AND SYMBOLS....................................................... D-1 GENERAL MINING INFORMATION ................................................................ D-3 3.1 Panel Design ........................................................................................ D-3 3.2 Gateroad Pillar Configuration and Design ............................................. D-4 3.3 Previous Mining ..................................................................................... D-5 3.4 Multiple Seam Mining ............................................................................ D-8 3.5 Compression Arches and Load Transfer............................................... D-8 GEOLOGIC FACTORS INFLUENCING SUBSIDENCE ................................ D-11 4.1 Structure .............................................................................................. D-11 4.2 Lithologic Factors Affecting Subsidence.............................................. D-14 4.3 Lithology and Angle of Draw................................................................ D-16 TOPOGRAPHIC FACTORS AFFECTING SUBSIDENCE ............................. D-16 5.1 Rugged Terrain.................................................................................... D-16 5.2 Variable Overburden Thickness .......................................................... D-19 SUBSIDENCE ESTIMATION OVER CAMEO SEAM LONGWALL PANELS, RED CLIFF MINE, PROJECT AREA............................................. D-21 6.1 Subsidence Zones............................................................................... D-22 6.1.1 Caved Zone .......................................................................... D-22 6.1.2 Fractured Zone ..................................................................... D-23 6.1.3 Continuous Deformation Zone .............................................. D-25 6.1.4 Near-Surface Zone ............................................................... D-25 PREDICTED SUBSIDENCE OVER THE RED CLIFF MINE PROJECT AREA .............................................................................................................. D-27 7.1 Maximum Vertical Subsidence (Smax) .................................................. D-27 7.2 Maximum Horizontal Strain ................................................................. D-32 7.3 Maximum Tilt (G) ................................................................................. D-34 7.4 Angle of Draw ...................................................................................... D-36 7.5 Break Angle ......................................................................................... D-36 7.6 Rate and Duration of Subsidence........................................................ D-38 IMPACTS OF SUBSIDENCE ON STRUCTURALLY SENSITIVE AREAS............................................................................................................ D-39 8.1 Longwall Mining in Geologic Hazard Areas of Landslides, Rockfalls, and Unstable Slopes........................................................... D-39 8.2 Mining Beneath Stream Courses......................................................... D-40 SURFACE SUBSIDENCE MONITORING ...................................................... D-41 REFERENCES................................................................................................ D-42 FIGURES ........................................................................................................ D-44

4.0

5.0

6.0

7.0

8.0

9.0 10.0 11.0

D-i

APPENDIX A

RECOMMENDED STRUCTURE LIMITS FOR SUBSIDENCE INDUCED STRAIN AND TILT

LIST OF TABLES
Table No. 1 2 3 4 5 6 7 8 9 10 11 12 Title Page

Predicted Maximum Subsidence for Selected Panels, McClane Canyon Mine ................................................................................ D-6 Predicted Maximum Strains and Tilt for Selected Panels, McClane Canyon Mine ................................................................................ D-7 Slope Geometries Within Project Area ............................................................ D-12 Bank Density, Swell Factor and Percent Free Swell for Selected Rocks and Soils.................................................................................................... D-15 Lithologic Distributions for Dorchester Project Overburden............................. D-17 Angles of Draw for Coal Mining in the United States and Europe ................... D-18 Formulae for Predicting Fracture Zone Height ................................................ D-24 Maximum Vertical Subsidence (Smax) for Planned Red Cliff Mine Longwall Panels ........................................................................................... D-29 Maximum Tensile (+E) and Compressive (-E) Strains for Planned Red Cliff Mine Longwall Panels.................................................................... D-31 Predicted Surface Fracture Widths Based on York Canyon Mine Measurements.............................................................................................. D-33 Maximum Slope Angle (Tilt) Change for Planned Red Cliff Mine Longwall Panels ........................................................................................... D-35 Angles of Draw for Mines in Flat-Bedded Sedimentary Rocks with Respect to Lithology of Overburden ............................................................. D-37

D-ii

LIST OF FIGURES
(See EIS Figure Volume) Figure No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Title Red Cliff Mine Project and Coal Lease Areas Plan View of Three Adjacent Longwall Panels Estimated Gateroad Pillar Loads From Mining First Adjacent Panel Load Transfer Distance Data Estimated Gateroad Pillar Loads From Mining Second Adjacent Panel McClane Canyon Mine Workings Subsidence Predicted for Five Selected Panels, McClane Canyon Mine Subsidence Over Room-And-Pillar Workings After Pillar Failure Localized Mining Induced Slope Angle Changes Potential Collapse Heights Above Different Mine Opening Geometries Cumulative Percent of Chimney Collapse Height Time Interval Between Mining and Surface Breached or Dropped Overburden and Outcrop Map for the Project Area Estimated Angle of Draw in Relation to Percent Sandstone and Limestone Cross Panel Compression Ridge in Alluvium, York Canyon Mine Cross Panel Tension Cracks in Alluvium, York Canyon Mine Ribside Tension Crack On Steep Slope, York Canyon Mine Ribside Tension Cracks in Road Fill and Cliff Face, York Canyon Mine Maximum Vertical Subsidence (Smax) With Respect to Panel Width and Depth Tension Crack Over Starter Room, York Canyon Mine Subsidence Monitoring Program

D-iii

D-iv

1.0

INTRODUCTION

Estimated subsidence magnitudes presented in this Draft Environmental Impact Statement for the Red Cliff Mine, Project Area containing the Coal Lease Application and the Existing Coal Lease areas are planned for principally longwall mining of coal north of Mack and Loma Colorado and the south facing Book Cliffs and east of Colorado State Highway 139 as indicated on the general location map titled Red Cliff Mine, Proposed Mine Facilities and Rail Spur. The Coal Lease Application area is east of the Existing Coal Lease that includes the active McClane Canyon Mine and the closed and reclaimed Munger Mine. 2.0 DEFINITION OF TERMS AND SYMBOLS

Terms used to evaluate and analyze subsidence processes and amounts are described below. Longwall Mining: See Affected Environment/Subsidence for an overview of underground coal mining. Mining Panel: A rectangular mining area where mine openings are developed and coal is extracted. In longwall mining panels, development entries, or gate roads, are driven at either side of the panel boundaries and the intervening coal is extracted with a longwall cutting machine. Headgate: Entries and crosscuts driven on the side of the mining panel adjacent to unmined coal, and on the side of the panel that is in the direction of further panel development and used for removal by belt of coal as cut from the longwall face and bringing ventilation to the longwall face. Tailgate: Entries and crosscuts driven on the opposite side of the mining panel from the head gate entries and provide a path for return ventilation air from the face. Panel Length and Width (W, L): The length and width of the longwall panel where coal is being extracted. Subsidence: The vertical downward movement of the overburden and ground surface caused by extracting the coal. Maximum Subsidence: The maximum vertical downward movement of the overburden and ground surface above the center of the panel caused by extracting the coal. Tilt and Maximum Tilt (M): The inclination of the ground surface caused by mining the coal in a longwall panel, the vertical displacement difference between two points on the ground surface divided by the horizontal distance between these points; maximum tilt is the maximum inclination that develops as the ground surface deflects downward towards the center of a panel, i.e. the subsidence trough. Maximum Strain (+E, -E): Strain is the change in length between two points of measurement divided by the original distance between these two points (unit change in length); tensile strain (+e) is the unit elongation between any two points on the surface moving further apart (unit elongation) as the ground surface deflects downward towards

D-1

the center of a panel; compressive strain (-e) is the unit shortening between any two points on the surface moving closer together as the ground surface deflects downward towards the center of a panel. The maximum values are for the unique conditions present at an individual panel. Subsidence Trough: A trough-like depression (downwarped area) that occurs directly above and somewhat outside the panel where coal is being extracted; the trough is caused by differential vertical displacement of the ground surface. Coal Extraction Thickness (m): The thickness of coal being mined; this value may be less than the actual seam thickness, because some coal of low quality may not be mined, some coal may be left in the roof ("top coal") for roof stability, or the seam may be too thick to be mined completely. Overburden Depth (d): The vertical distance between the top of the coal seam being mined and the ground surface above it. Critical Panel Width: The minimum mining panel width necessary to cause maximum subsidence on the ground surface, generally along a line over the center of a panel. The length of the mining panel must also be equal to, or exceed this critical width. Critical width varies from 1.0 to 1.4 times the mining depth (overburden thickness). Critical Panel Length: The length of the mining panel (length of coal area extracted) necessary to cause maximum vertical displacement (1.0 to 1.4 times the overburden depth). Supercritical Panel Length and Width: A mining panel with a length and width that is greater than the critical mining width. Super Panel: Two or more mining panels that behave like one large panel because the gateroad pillars have crushed; the overlying subsidence profile looks roughly like a very wide single panel. Angle of Draw (α): The angle (from a vertical reference) of a straight line projected from the edge of the mining panel to the limit of measurable subsidence outside the edge of a panel at the ground surface. Break Angle (β): The angle (from a vertical reference) between a straight line projected vertically upward from the edge of the mining panel to the point of maximum extension (maximum tensile strain - +E) at the surface above the panel. Bedrock: Rock that was originally formed under natural conditions, in contrast to unconsolidated material (colluvium, alluvium, and soil) derived from bedrock. Cleat: A system of planar cross-bedding fractures in coal; there commonly are two cleat sets that are nearly perpendicular to each other. Lineament: A linear topographic feature, which can be observed on-site and on aerial photographs, that often indicates a fault or an extensive fracture or fracture system that may more readily erode, frequently controlling the drainage pattern.

D-2

Joint: A fracture surface or parting in rock, usually sub-planar, without displacement and frequently one of closely spaced sub-parallel fractures forming a joint set. Fault: A fracture surface, parting, or series of partings in rock, more extensive than joints, where rock on either side of the surface, or surfaces, is displaced (offset). Percent Swell: The percent increase in volume of intact rock when broken, collapsed or caved into the open space produced by mining. Coal Bump: The sudden release of strain energy that may produce an explosion-like sound and shock waves in locations where stress (pressure) on the coal exceeds its strength. May be accompanied by sudden sloughing from the face of an advancing entry, sudden uplift of floor coal and/or sudden outward movement of coal from a rib. More frequently occurs in room-and-pillar mining during pillar robbing during retreat from a panel, when mining the pillars were stressed by load transfer from the entries and crosscuts driven on the advance into a panel. Rock Burst: The sudden release of strain energy that produces an explosion-like sound, seismic shock waves recorded on seismographs. Rock bursts or coal will generally be violently ejected from ribs, roof and/or floor of mine openings. Generally occurs at depths exceeding 1,500 feet, in stronger rock types and coal seams and in locations where mining has increased pillar and/or rib stress concentrations that exceed the strength of the rock or coal. 3.0 GENERAL MINING INFORMATION

Longwall and room-and-pillar mining are planned for the Red Cliff Mine, with longwall mining predominant. The Proposed Coal Lease tract is bounded by the dashed red line on Figure 1. Red Cliff Mine Project and Coal Lease Areas. There has not been any previous mining in the Coal Lease Application area or the Project Area. The following design specifications were developed for the purposes of describing the potential impacts. A final mine plan will be developed and approved by OSM and the Colorado DRMS. Pillar widths and panel design may vary from those described in this section. 3.1 Panel Design

Panels in the Red Cliff Coal Lease Application are projected to be arranged in groups of three or four, with the long axis of the panels oriented in a north-south direction, at an angle that will range from roughly 20o to 70o counterclockwise from the Big Salt Wash drainage, the major topographic feature in the Project Area. The projected north-south panel orientation will align the east-west longwall face between 70o and 20o to this major lineament direction. Big Salt Wash and the upper reaches of Buniger Canyon, Hatchet Canyon and Garvey Canyon are between 20o and nearly 90o to the direction of the secondary drainages that feed into Big Salt Wash from both sides (Post Canyon, Lapham Canyon and other unnamed smaller side canyons), and the lower reaches of Buniger Canyon, Hatchet Canyon and Garvey Canyon. This panel orientation should minimize any parallel alignment of both linear drainage features to the direction of the longwall face and, thereby, possible periodic loading of the face supports. A barrier pillar about 200 feet wide is projected to be left between adjacent panel groups. All panels will be oriented in the north-south direction. The longwall panels are projected

D-3

to be from 800 to 1200 feet wide, and could range from 7,300 feet to 13,500 feet in length. The Main Cameo Seam, also called the Lower Cameo Seam, outcrops at the mine portals, Section 3, T. 8 S., R. 102 W., 6th P.M., the lower reaches of Big Salt Wash in Sections 12 and 1, T. 8 S., R. 102 W., 6th P.M., the lower reaches of Garvey Canyon in Section 12, the lower reaches of Buniger Canyon in Section 1 of the Coal Lease Application area. Therefore, the overburden depth (depth of cover above the Main Cameo ranges from zero in the extreme southwestern part of the Coal Lease Application to slightly more than 2,000 feet on the extreme eastern part of the proposed lease area. The planned minimum overburden depth for longwall mining is 200 feet in order to minimize 1) the potential for chimney caving to the ground surface, 2) the interception and diversion of ground water through the mine workings, 3) the loss of surface water to the fracture zone overlying completed longwall panels and 4) the potential development of up to 20-inch wide surface fractures along the sides of the panels. The planned coal mining height ranges from 8 to 11 feet. The 11-foot maximum planned mining height was used as a conservative maximum thickness in the subsidence analysis. 3.2 Gateroad Pillar Configuration and Design

The currently planned gateroads will generally follow the example on Figure 2. Plan View of Three Adjacent Longwall Panels, where the gateroad pillars involve one row of yield pillars and one row of rigid pillars. The advantage of this design is that it should minimize stress levels at the headgate and tailgate ends of the longwall face. The centerline distance between the planned 20-foot wide gateroad entries will be 100 feet for the projected 80-foot wide rigid pillars. The centerline distance between the 20-foot wide gateroad crosscuts will be 200 feet for the 180-foot long rigid pillars. The centerline distance between the gateroad entries adjacent the 30-foot wide yield pillars will be 50 feet and 100 feet between the crosscuts adjacent to the 80-foot long yield pillars. Every other crosscut for the yield pillars will line up with a rigid pillar crosscut. Figure 3. Estimated Gateroad Pillar Loads From Mining First Adjacent Panel indicates the estimated minimum load and average stress that must be supported by the 30-foot wide by 80-foot long yield pillars, if the yield pillar is not to potentially crush. Figure 3 also indicates the estimated rigid pillar load that must be supported by the planned 80-foot wide rigid pillars, after the longwall face of the first adjacent panel has been advanced roughly one Load Transfer Distance, approximately 329 feet, past any location. The Load Transfer Distance is how far from active mining that deformation or loading in response is measurable or otherwise detectable, and shown on Figure 4. Load Transfer Distance Data (compiled by Abel, 1988). Figure 5. Estimated Gateroad Pillar Loads From Mining Second Adjacent Panel indicates the estimated minimum load and average stress that must be supported by the planned 80-foot wide by 180-foot long rigid pillars, if the rigid pillar is not to potentially crush, after the longwall face of the second adjacent panel has been advanced roughly one Load Transfer Distance past any gateroad location. It is not essential that the central gateroad entry remain open for ventilation through the gob to the bleeder entries. Two of the active panel tailgate entries will be open to the bleeder entries at all times during mining of the panel. See Figure 2. The disadvantage of a line of rigid gateroad pillars through the gob is the potential for higher horizontal tensile strain at the ground surface overlying the gateroad because the overburden initially bends toward the first adjacent panel as it is mined and then in the

D-4

opposite direction when the second adjacent panel is mined, i.e. the tensile strains are additive over rigid gateroads. The optimum situation is for the 80-foot wide rigid pillar to be only temporarily rigid as the second longwall face passes. The rigid pillar can safely be allowed to yield and then crush after it is roughly 100 feet out from the longwall face between collapsed gob on both sides. This, in effect, reduces the tensile strain, and fracture opening, that is directly proportional to the differential vertical subsidence between the gateroad and the maximum subsidence (Smax) over the center of the adjacent panels. 3.3 Previous Mining

There is no known previous mining within the proposed coal lease. However, the McClane Canyon Mine is operating in the immediately adjacent existing coal lease on most of Sections 15, 16, 21 and 22, T. 7 S., R. 102 W., 6 P.M. A small coal operation, the Munger Mine now closed and reclaimed, operated in adjacent Section 27. Figure 1. Red Cliff Mine Project and Coal Lease Areas shows the location of these workings. The McClane Canyon Mine map, Figure 6. McClane Canyon Mine Workings, indicates room- and-pillar advance mining, without pillar robbing on the retreat, to overburden depths just over 1,500 feet (generally 80 by 80-foot pillars on 100-foot centers for 36% recovery). Pillars were robbed on the retreat from other panels at depths of very nearly 1,300 feet. Total coal extraction (recovery) appears to have been as much as 78% within two small (roughly 520-foot maximum width) irregular shaped panels that were retreat mined to depths of 1,100 feet. The mine map indicates that robbing the 100 by 70-foot advance pillars using a method called “christmas treeing” was incomplete and erratic, with many 100 by 70-foot advance pillars and occasional 100 by 30-foot stump pillars left within the panels. This method is no longer permitted by MSHA because of safety concerns. In general, however, panel recovery was approximately 64% when robbing pillars on the retreat, apparently leaving different shaped stump pillars when retreating from different panels. The width of those panels ranged from 350 to 570 feet. No observations have been reported of surface subsidence effects over the McClane Canyon Mine. Estimates of maximum subsidence (Smax), tensile and compressive strains and maximum slope changes were made over the five selected panels and are indicated by number on Figure 7. Subsidence Predicted for Five Selected Panels, McClane Canyon Mine. The method used combined the British National Coal Board (NCB, 1975) method for longwall subsidence prediction and the room-and-pillar adaptation by Abel and Lee (1984) presented on Figure 8. Subsidence Over Room-And-Pillar Workings After Failure. Table 1. Predicted Maximum Subsidence For Selected Panels, McClane Canyon Mine presents the estimated super-critical subsidence over each of the selected room-and-pillar panels and the predicted NCB corrected subsidence for the panel width with respect to depth. The predicted maximum surface subsidence for the five panels ranged from 1.52 feet to 2.56 feet. Table 2. Predicted Maximum Strains and Tilt for Selected Panels, McClane Canyon Mine presents the maximum tensile and compressive strains and slope angle changes In addition, a rough estimate of potential open surface fracture widths was made for each selected panel. This rough estimate was based on the relationship between the vertical subsidence measured over York Canyon Mine longwall panels with known widths and overburden depths, measured surface fracture widths and the NCB predicted maximum surface tensile strains for these known conditions permitted an estimate of the potential width of surface tension fractures.

D-5

Table 1. Predicted Maximum Subsidence for Selected Panels, McClane Canyon Mine Panel Mid-Depth feet (m) Robbed Pillar Width (feet) 20 9.576 35.5% (3.55) 24.9% (2.49) 25.0% (2.50) 39.9% (3.99) 18.4% (1.84) 0.55 Lmax (Pillar Ht /Panel Depth) SuperCritical Subsidence (feet) Panel Correction Factor 900 (274m) 400 (122m) 500 (152m) 800 (2.44m) 355 (108m) 0.958 7.77 34 2.285 0.644 27.86 20 13.93 1.070 11.97 30 3.990 1.425 9.89 25 3.954 0.517 19.15 Ratio Panel Width/ Depth Lmax Predicted Smax feet

Panel Ident.

Panel Width feet (meters)

1

465 (142m)

1.95

2

570 (174m)

0.61

1.52

3

535 (163m)

0.81

2.02

4

515 (157m)

0.64

2.56

D-6

5

340 (104m)

0.85

1.56

NOTES: Assumed 160 PCF overburden density, 10-foot mining height, stump pillar widths are minimums after pillar robbing on the retreat from the panel, all values approximate?

Table 2. Predicted Maximum Strains and Tilt for Selected Panels, McClane Canyon Mine Smax/ Depth με Tensile Strain (+E) Multiplier Maximum Tensile Strain με open crack (in) 1780 (1.02) 1.28 2774 3.33 Compressive Strain (-E) Multiplier Maximum Compressive Strain με Slope Multiplier (G) Maximum Subsidence Induced Slope Angle Change 0.72% 0.41o 24.8 min 2.75 1.04% 0.60o 35.9 min 2.77 1.12% 0.64o 38.6 min 3003 3.00 0.96% 0.55o 33.0 min 0.56 2460 2.78 1.22% 0.70o 42.0 min

Panel Ident.

Panel Width/ Depth Ratio

1

0.517

2167

0.82

2

1.425

3800

0.65

2470 (1.50)

0.51

1938

3

1.070

4050

0.65

2630 (1.61)

0.55

2228

D-7

4

0.644

3196

0.57

1830 (1.06)

0.94

5

0.958

4393

0.65

2860 (1.77)

The magnitude of the maximum predicted surface extension strains presented in Table 2 would develop roughly over the perimeters of the selected retreat mined panels, which ranged from 1780 με to 2860 με. Extension strains in the predicted range from approximately 1800 με to 2900 με on the surface would cause repairable damage, ranging from cracking of single story brick walls to cracking of reinforced concrete frames. The predicted tensile strains would result in estimated 1-inch to 2-inch wide tensile cracks at the ground surface. The predicted magnitude of the maximum surface compressive strains ranged from 1940 με to 3000 με, as presented in Table 2 should have developed over the centers of the selected retreat mined panels. Compressive strains in the predicted range would cause repairable damage to structures on the surface. The predicted maximum increase in surface slope resulting from subsidence over and adjacent to the five selected room-and-pillar panels, presented in Table 2, range from 0.72% (0.41o or 25 min) to 1.22% (0.70o or 42 min). Slope changes of this magnitude could adversely affect floor drainage, turbo generators and overhead crane rail operations. Railroad switching Including all facilities, that depend on rolling of rail cars could be adversely affected. Rubber-tired vehicles could be induced to roll at the grades above 1%. None of the potential structures or land uses indicated was or is present over the McClane Canyon Mine. Increasing a short section of an already steep slope by 0.4o to 0.7o could induce downslope movement. However, the direction that a panel was mined and/or the pillars failed could also flatten a slope. Figure 9. Localized Mining Induced Slope Angle Changes indicates the normally minor effect of the direction of mining on a much steeper slope angle. 3.4 Multiple Seam Mining

Longwall mining is planned as the principal mining method in the Main Cameo Seam. There are no plans to mine any other coal seams, because of the thickness and coal quality of adjacent seams and because of the local 20 to 25-foot thickness where the Cameo Seams split and/or merge. 3.5 Compression Arches and Load Transfer

Compression arches commonly develop across longwall panels where the coal has been and/or is being mined, provided the panel is narrow enough and(or) deep enough for both ends of the arch to span the panel width and bear on rock. These arches are zones of tangential compressive stress where some of the weight of the overburden overlying the arch can be transferred onto abutments; ahead, behind and on either side of the longwall panel being mined (somewhat like the way stone-arched bridges transfer their weight and load to the bridge abutments). However, some or all of the downward deflected rock under the arch will bear on the collapsed rock under the arch. If the width of a longwall panel is too wide or too shallow for the arch to span the panel width, a smaller arch will form, with one side of the arch bearing on and compressing the collapsed gob. The balancing arch abutment can be on the solid barrier pillar behind the starter room, on rigid pillars in the gateroads and on the unmined coal ahead of the advancing longwall face. The arch over the longwall face will follow the advancing face. The arch abutment load following the advancing longwall face will progressively consolidate the collapsed roof rock, the gob. If the face stops moving the face arch will shorten in length and can add load the face supports.

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Compression arches in intact rock can typically support relatively high compressive stresses, compared to tensile stresses, because rock is much stronger in compression than in tension. Major abutment zones in a longwall mining operation will develop on (1) the unmined coal ahead of a longwall face, (2) the unmined coal behind the starter room, (3) the caved zone (gob) behind the supports and possibly on (4) rigid gateroad pillars on either side of the longwall panel. If the planned gateroad pillars do not have sufficient strength to support the arch load abutment, they will yield, transferring that arch load abutment onto unmined coal on one side of the panel and onto the gob left behind the previously mined adjacent panel on the other side. See Figure 2. Plan View of Three Adjacent Longwall Panels. In a longwall mining operation, the immediate roof rocks behind the face supports collapse into the volume formerly occupied by the extracted coal. The face supports advance following the shearer, as it cuts each slice of coal off the coal face, much of the weight of the overburden arching over the longwall face will be borne by the re-compressed caved material (gob). The load carried by the gob reduces the abutment load and stress on the coal ahead of the face. Abutment loads acting on the coal ahead of the face are smallest when the roof caves immediately behind the longwall face supports. The magnitude of the weight of overburden transferred is reduced when the length between the advancing face abutment and the following gob abutment is shortened. Caving of the immediate roof, which is necessary to form an abutment zone on the gob, is partially controlled by the lithology of the immediate roof rocks. Generally, shales, mudstones and some siltstones, cave readily because the are relatively weak, whereas beds of stronger sandstone and limestone frequently cave with difficulty. Thin-bedded rock units, with closely spaced joints tend to cave more readily than thick bedded rock units, with more widely spaced joints, particularly the stronger rock types that tend to temporarily hang up and then periodically collapse, occasionally violently. Coal mine bumps and outbursts from abutment loaded pillars and from a longwall face, which may occur when the abutment pressure exceeds the strength of the coal, are minimized both in number and magnitude where the immediate and near roof rocks consist of shales and claystones, but may occur in greater frequency and magnitude where the immediate and near roof rocks are strong, i.e. sandstones and limestones. The thick Rollins sandstone, and numerous thinner sandstone beds occur in the coal bearing lower sequence of the Mount Garfield Formation (Mesaverde Group) that contains the Cameo Seam in the Coal Lease Application area. The Rollins sandstone occurs over much of the western Colorado coal mining districts and is locally exposed as a prominent buff-colored cliff-forming outcrop in canyon walls. However, weak immediate roof rocks can cause roof control and support problems in the gateroad entries and crosscuts and caving ahead of the face supports between the time the shearer exposes a portion of the immediate roof and the face supports can move forward to provide the necessary roof support. Coal outbursts that may occur at the coal face can release weak roof rocks to collapse onto the face conveyor.

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Ground stresses and mining induced stress concentrations increase with increasing overburden above a coal seam. Room-and-pillar mining becomes significantly more difficult in overburden more than 1,500 to 2,000 feet thick, because the mine roofs and pillars are already more highly stressed, before coal extraction transfers additional overburden stress. Miners can be forced out of an area by roof falls, pillar slabbing, rib sloughing and floor bumps before planned pillar robbing can be completed. The longwall method overcomes some of the room-and-pillar stability problems. There are no highly stressed pillars present that are split during pillar robbing on the retreat from a panel. Abutment stresses are generally lower and more uniform than in coal mined by the room-and-pillar method. There is also a major body of solid confined load carrying coal immediately in front of the longwall face. More frequent and larger magnitude bumps and related seismic activity may occur where a large incompletely caved and consolidated gob area develops behind the longwall face supports. The presence of a thick sandstone bed, such as the Rollins sandstone, in the near roof can be progressively cantilevered further out over the gob until the sandstone suddenly breaks. This is particularly troublesome when the longwall face roughly parallels a widely-spaced and persistent joint set. When the shearer undercuts such a joint, the face supports can be subject to a sudden load increase, i.e. a long line of joint blocks can suddenly be released. When a moderately large rigid gateroad pillar is loaded by the abutment arch from mining of the longwall panel on one side, considerable strain energy can be stored in the pillar. The loading of the pillar will be rapidly doubled when the adjacent panel is mined past the pillar on the other side. If the strength of the gateroad pillar is only marginally strong enough to carry the arched load, the stored strain energy can be suddenly released as a rib bump or outburst. It is necessary to achieve a balance between a rigid gateroad pillar when the first panel passes and a pillar that will yield, but not fail until the second panel has been mined well past the location. A barrier pillar can be left between every set of two longwall panels. This practice can waste part of the coal resource. A rigid barrier pillar between adjacent longwall panels can induce higher tensile strains in the overlying ground surface. Rigid barrier pillars are normally designed to isolate panel groups and protect mains and submains and bleeder rooms. Rigid barrier pillars can locally concentrate stresses in closely overlying and underlying coal seams hindering their future mining. For a given point of observation on the surface, the compression arch will have dissipated when subsidence and surface strains have ceased. This, however, takes time, potentially years for the differential stresses to decrease to a stable and permanently supportable level. Active measurable surface subsidence will temporarily decrease significantly when the given point is over a gateroad and between 0.5 to 0.7 times the depth horizontally from any adjacent active longwall panel face. If none of the gateroad pillars are rigid to the load applied when the first adjacent panel passes, less subsidence will occur on the surface over the gateroad when the adjacent longwall panel is mined. When the gateroad pillars yield, the excess load they were unable to support will be transferred to the unmined coal in the adjacent panel. The adjacent gob (collapsed immediate roof rock) will be more uniform if all the gateroad pillars yield when the first panel passes. However, when the

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adjacent panel passes the yielded pillars major overburden loading must be carried by the coal at the tailgate corner of the face, see Figure 2. Keeping the tailgate entry open to ventilate the longwall becomes a serious problem. 4.0 GEOLOGIC FACTORS INFLUENCING SUBSIDENCE

It is extremely difficult to quantify the impact of geology on the extraction of coal and the resulting subsidence of the ground surface. There are some obvious generalities that can be stated with complete confidence, but predicting what will happen and where is fraught with risk. The overall geology of the coal bearing Mesaverde Group is generally known, but the site specific geologic conditions aren’t fully understood because it is only possible to see outcrops, the immediate roof and floor and the coal seam and the overburden lithology is changing. 4.1 Structure

The strike and dip of the bedding, the orientation of known faults, the direction of lineaments, the strike and dip of the bedding cross joints and the spacing and direction of the coal cleats (bedding cross joints in the coal seam) are important factors to consider in the design of longwall mining panels. Bedrock in the Proposed Coal Lease area for the Red Cliff Mine dips northeastward at approximately 3 degrees. The relatively flat dip is not expected to noticeably affect the angle of draw from that of flat-lying beds, based on NCB information (NCB, 1975). The relatively flat dip should not affect the panel orientation. The lineaments in the lease area are the deeply incised canyons indicated on Table 3. Slope Geometries Within Project Area. The perennial stream in Big Salt Wash canyon and the intermittent streams in the side canyons do not follow the normal dendritic (leaflike) drainage pattern. The drainage pattern, shown on Figure 1. Red Cliff Mine Project and Coal Lease Areas, roughly follows the orthogonal (right angle) trellis drainage pattern, also shown on the Garvey Canyon Quadrangle topographic map. The dominant Project Area linear feature is Big Salt Wash which enters the Coal Lease Application area bearing approximately N 22o E and continues for about 12,400 feet where it rotates further easterly, bearing approximately N 31o E for about 6,900 feet, then at N 45o E for 6,100 feet, then exits the Coal Lease Application area after bearing N 54o E for 3,600 feet. From the eastern boundary of the Coal Lease Application area to the eastern boundary of the Project Area, Big Salt Wash bears approximately N 69o E for 4,100 feet. The sub-parallel valley lineaments also follow the same directional rotation, from northeast on the west side of the proposed Lease Area, to a much more easterly direction on the east side of the Project Area. The secondary lineaments, that are side canyons entering Big Salt Wash from the northwest, bear northwest on the west side (lower Buniger Canyon bears roughly N 57o W) and bear more northerly from west to east across the lease area. The easternmost side canyon on the northwest side of Big Salt Wash, Lapham Canyon, bears approximately N 8o W. The less consistent secondary lineaments represented by side canyons entering Big Salt Wash from the southeast starting with Garvey Canyon that bears about S 82o E, past Hatchet Canyon that bears about S 65o E, to the last unnamed southeast side canyon before the Project Area eastern boundary which bears approximately S 57o E. The southeast side canyons seemingly bear less easterly and more southerly toward the east side of the Project Area.

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Table 3. Slope Geometries Within Project Area Quadrangle Location Direction Up Slope N 61O W S 58O E N 78O E N 00O W S 47O W N 62O W S 60O E N 34O E S 47O W S 58O E N 50O W N 08O E Vertical Horizontal Height Distance (feet) (feet) Overall Slope Angles & Grade 27O (51%) 27O (51%) 29O (55%) 31O (60%) 25O (47%) 21O (38%) 32O (62%) 41O (87%) 31O (60%) 32O (62%) 32O (62%) 37O (75%) S 55O E S 80O E 560 930 31O (60%) 30O (58%)

Howard Canyon

Munger Creek, 8910 feet from Highway 139 East Salt Creek Garvey Canyon, 2860 feet off Big Salt Wash road Garvey Canyon, 5000 feet east of Big Salt Creek Garvey Canyon, 10040 feet east of Big Salt Creek Buniger Canyon, 2400 feet west of Big Salt Creek Buniger Canyon, 13880 feet northwest of Big Salt Creek Big Salt Wash, 2880 feet up from Buniger Creek Hatchet Canyon, 6890 feet east of Big Salt Creek Hatchet Canyon, 7170 feet east of Big Salt Creek Big Salt Wash, 3680 feet up from Hatchet Creek Big Salt Wash, 3970 feet up from Hatchet Creek Big Salt Wash, side canyon 6690 feet up from Hatchet Creek Big Salt Wash, 6920 feet up from Hatchet Creek Big Salt Wash, opposite side from Post Canyon

980

1900

Garvey Canyon

920

1820

840

1500

760

1280

600

1310

440

1160

920

1500

400

456

290

490

760

1240

760

1200

680

890

880

1500

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Table 3. Slope Geometries Within Project Area (Continued) Quadrangle Location Direction Up Slope N 78o E N 30o E N 06o E Vertical Horizontal Height Distance (feet) (feet) Overall Slope Angle & Grade 29o (55%) 35o (70%) 25o (47%) 33o (65%) 30o (58%)

Garvey Canyon

Post Canyon, 4180 feet northwest from Big Salt Wash Post Canyon, 5420 feet northwest from Big Salt Wash Big Salt Wash, 1080 up side canyon, after 3280 feet up Big Salt Wash from Post Canyon Lapham Canyon, 2080 feet from Big Salt Wash Lapham Canyon, 5550 feet from Big Salt Wash

720

1300

600

860

520

1130

N 68o E N 61o W

480

740

440

760

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4.2

Lithologic Factors Affecting Subsidence

Different lithologies (rock types) have differing strengths and therefore differing swell potential when broken. As indicated on Table 4. Bank Density, Swell Factor and Percent Free Swell for Selected Rocks and Soils, there is considerable variation in the percent swell between rock types and within rock types. The height of caving above the mine workings is reduced where the roof rocks consist of strong (high percent swell) sandstones compared to weak (low percent swell) shales, mudstones or soft siltstones. However, the height of rock fracturing above mined openings is greater for strong, brittle sandstones compared to weak, more yieldable shales, mudstones and soft siltstones. The mean percent swell of the overburden rocks controls the potential maximum height of the collapse zone upward in the immediate roof above a longwall panel, an entry or an intersection between an entry and a crosscut. Figure 10. Potential Collapse Heights Above Different Mine Opening Geometries by Piggott and Eynon (1977) provides a percent swell based method for predicting the maximum collapse height in the rock above different mining geometries, i.e. rectangular collapse over large area panels, wedge collapse over long narrow entries and conical collapse over four-way roadway intersections. The calculation simply is for what height of roof rock must collapse and expand to fill an underlying mined void applying three types of collapse geometry. Once the void and chimney are filled with caved rock (gob), it is assumed that further roof collapse will be prevented by the broken rock fill. Gray, Bruhn and Turka (1977) tabulated data on 126 chimney collapses above roomand-pillar workings in the nominally 6-foot thick Pittsburgh Seam to the overlying ground surface. The relative cumulative frequency curve, Figure 11. Cumulative Percent of Chimney Collapse Height, suggests that there is a very small probability, 0.8 percent, that a collapse chimney of any type will progress upward through 200 feet of Pennsylvanian formation coal overburden to the ground surface, irrespective either mining geometry or collapse geometry. Gray et al. (1977) recorded the elapsed time after mining that chimneys, sinkholes, breached the ground surface and pillar collapse troughs dropped the ground surface, shown on Figure 12. Time Interval Between Mining and Surface Breached or Dropped. They indicate that the time interval can be as much as 100 years. The McClane Canyon Mine has extracted approximately 36% of Cameo Seam coal by advance room-and-pillar mining at approximately 225 feet of depth, apparently without any chimney collapse to the overlying ground surface. This can be seen on Figure 6. McClane Canyon Mine Workings. This is common practice for operating coal mines because the roof is reinforced as it is exposed and can be resupported as required during the operating life of the mine to prevent progressive chimney collapse. After a mine is closed progressive deterioration of the roof can result in chimney failures, which at shallow depths can and frequently do breach the ground surface. Areas where the overburden thickness is less than 200 feet above the Cameo Seam in the Proposed Coal Lease area should be considered at risk for long-term chimney collapse to the surface. The 200-foot overburden contour is shown on Figure 13. Overburden and Outcrop Map for the Project Area. The 200-foot overburden contour extends approximately 360 feet upstream from the outcrop line in Big Salt Wash and approximately 550 feet upstream from the outcrop line in Garvey Canyon. Longterm protection from chimney subsidence to the overlying ground surface can be provided in such shallow overburden by partially backfilling the entries in these two areas upon final closure of the Red Cliff Mine.

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Table 4. Bank Density, Swell Factor and Percent Free Swell for Selected Rocks and Soils Sedimentary Rocks or Soils ________________________________ Clay, natural Coal, anthracite bituminous Conglomerate Earth, wet loam Gravel, pit run Limestone typical values Montmorillonite, chlorite, kaolin illite, smektite Sand, dry damp wet Sandstone Shale, mudstone Siltstone, hard soft Bank Density __________ 126 PCF 100 PCF 80 PCF 153 PCF 126 PCF 96 PCF 135 PCF 155-163 PCF 141 PCF 100 PCF 120 PCF 130 PCF 153-157 PCF 104 PCF 153-157 PCF 126 PCF Swell Factor __________ 0.82 0.74 0.74 0.72-0.63 0.79 0.81 0.89 0.57-0.60 0.59 0.77 0.89 0.89 0.89 0.60 0.75 0.57-0.60 0.82 Free Swell _________ 22% 35% 35% 40-60% 27% 23% 12% 67-75% 69% 30% 12% 12% 12% 67% 33% 67-75% 22%

Free swell (%) = change in volume broken as a percent of original bank volume Swell factor = broken density/bank density Adapted from: Caterpillar, Inc., 1987, Caterpillar performance handbook, p 740 and Euclid Road Machinery Co., 1953, Estimating production and costs

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4.3

Lithology and Angle of Draw

The purpose of the reasonably nearby drilling through the Mount Garfield formation for Dorchester Coal Company's Fruita Project was to explore for potential mining of the Main Cameo which ranged from 10 to 29 feet thick at depths of up to 1600 feet in their proposed lease area. The reported lithologic distribution of rock types above the Main Cameo from 19 drillholes, which individually penetrated between 67 and 1316 feet of overlying rock, for a total of 13,880 feet of drilling is presented in Table 5. Lithologic Distributions for Dorchester Project Overburden. The overall average percentage of sandstone in the overburden is approximately 46%. Abel and Lee (1984) collected data on the relationship between measured angles of draw and the lithologic distribution in the overburden above several coal seams. Figure 14. Estimated Angle of Draw in Relation to Percent Sandstone and Limestone presents the relationship. The Dorchester Project drilling indicated 46% sandstone and no limestone and predicts a 19o angle of draw (α). The Dorchester drilling indicated considerable lateral rock type variation. Therefore, it should be anticipated that there will be a similar variation in the angle of draw. The range of sandstone percentage as determined from the drillholes was from 28 to 65%, suggesting a range for the angle of draw from just over 15o to over 25o. Angles of draw were predicted at 25o at two coal mines in Colorado mining in the Mesaverde Group based on drillhole lithology. Later survey measurements indicated angles of draw of 21o and 22o. A 19o to 22o angle of draw is on the low end of the range of values reported for the countries listed on Table 6. Angles of Draw for Coal Mining in the United States and Europe. The British National Coal Board’s (NCB) conservative 35o angle of draw has, however, been measured in Pennsylvania (Auchmuty, 1931). The larger NCB angle of draw estimate will be used because it should overestimate the area outside a longwall panel potentially affected by mining. In addition, the NCB maximum subsidence value (Smax) calculated from the flatter English terrain measurements was 17% to 21% greater than what was measured for ridge tops over three longwall panels in Mesaverde Group rocks and mountainous terrain at the York Canyon Mine west of Raton, New Mexico. NCB predicted subsidence in topographic lows were 55% greater than measured at the York Canyon Mine. This implies that the maximum tensile strain, compressive strain and tilt estimated using the NCB method may be similarly greater than what will be measured in the Project Area because the strains and tilt are directly proportional to the maximum panel subsidence (Smax) value. 5.0 5.1 TOPOGRAPHIC FACTORS AFFECTING SUBSIDENCE Rugged Terrain

The Red Cliff Mine Project Area is located in canyon-ridge topography. As shown on Table 3, overall slope angles range from 21o to 41o (38% to 87%) for canyon walls ranging from 400 feet to 920 feet high. Cliff sections are present on some canyon walls where thicker sandstones outcrop. Because of this rugged terrain, subsidence related surface impacts may change several times as the overburden depth changes along the roughly 7,300-foot to 13,500-foot lengths of the longwall panels. Subsidence, strain and tilt predictions will be less certain than would be the case in more gentle and flatter terrain. For example, vertical displacement may be as much as 30 percent greater over narrow ridge tops. The overburden ahead of a moving longwall face will move down slope as the subsidence trough ahead of the longwall face approaches but will not be

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Table 5. Lithologic Distributions for Dorchester Project Overburden

Drillhole Number Coal Sandstone

Above Main Cameo (feet) Siltstone Shale/Mudstone

Total (feet)

Percent Argillaceous

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1 2 4 11 16 17 18 30 32 33 37 38 39 42 CM1 CM2 CM3 CM4 CM7

6 (1.2%) 6 (0.6%) 17 (5.8%) 12 (0.9%) 21 (2.1%) 9 (0.9%) 28 (2.5%) 5 (0.4%) 15 (2.6%) 20 (2.8%) 15 (1.4%) 11 (1.0%) 12 (2.8%) 3 (2.0%) 4 (6.0%) 13 (4.0%) 7 (1.2%) 10 (1.0%) 10 (4.7%)

254 (50.0%) 375 (37.7%) 150 (51.0%) 647 (51.0%) 453 (44.2%) 486 (46.9%) 544 (48.1%) 504 (38.3%) 255 (44.4%) 197 (27.9%) 563 (51.7%) 577 (49.9%) 212 (49.4%) 75 (50.7%) 46 (68.7%) 150 (46.7%) 297 (50.5%) 485 (47.6%) 137 (64.9%)

66 (13.0%) 451 (45.3%) 26 (8.8%) 320 (25.2%) 97 (9.5%) 55 (5.3%) 101 (8.9%) 593 (45.1%) 130 (22.6%) 280 (39.7%) 226 (20.8%) 186 (16.1%) 36 (8.4%) 6 (4.1%) 0 (0.0%) 51 (15.9%) 213 (36.2%) 249 (24.5%) 25 (11.8%)

182 (35.8%) 163 (16.4%) 101 (34.4%) 290 (22.9%) 453 (44.2%) 487 (47.0%) 457 (40.4%) 214 (16.3%) 174 (30.3%) 209 (29.6%) 284 (26.1%) 383 (33.1%) 169 (39.4%) 64 (43.2%) 17 (25.4%) 107 (33.3%) 71 (12.1%) 247 (26.9%) 39 (18.5%)

508 995 294 1269 1024 1037 1130 1316 574 706 1088 1157 429 148 67 321 588 1018 211

48.8% 61.7% 43.2% 48.1% 53.7% 52.3% 49.3% 61.4% 52.9% 69.3% 46.9% 49.2% 47.8% 47.3% 25.4% 49.2% 48.3% 51.4% 30.3%

Total Footage Percentage 6407 46.2%

224 1.6%

3111 22.4%

4138 29.8%

13880 52.2%

Table 6. Tabulated Angles of Draw for Coal Mining in the United States and Europe Country or District Netherlands------Ruhr----------------Lower Rhine-----France-------------Great Britain-----Poland-------------Pennsylvania----South Wales-----Colorado----------Brauner Wardell (1973, p. 9) (1959, p. 530) 35°-45° 30°-45° ---------35° 25°-35° ---------20° ------------------35°-45° --------29°-39° --------28°-40° 19°-34° ------------------------Newhall and Plein (1934, p. 65) ------------------------------------------------20°-25° ----------------Pendleton (1985) --------------------------------------------------------21° Collins (1977) -------------------------------------------------32°-40° --------

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able to push uphill against gravity after the face passes. If the longwall panel subsequently advances under the ridge, that side of the ridge will displace down slope on that side of the ridge. In the course of extracting the underlying coal, a ridge with steep slopes in adjacent valleys will subside more than would be the case in flat terrain. Parts B and C of Figure 9. Localized Mining Induced Slope Angle Changes indicates how this will occur. The potentially additive subsidence on ridges will increase the tensile strain and the width of open surface cracking. Higher compression ridges, but negligible tensile fractures, are likely to occur in narrow valley bottoms, because the overburden on both sides will try to move toward the bottom of the valley as the subsidence trough approaches and then passes the valley bottom. Consequently subsidence impacts are likely to be greater on narrow ridges and lesser in narrow valley bottoms than they would be in more subdued terrain. Strains and displacements on steep slopes with thin alluvial cover, particularly cliffs, may cause surface fractures on the order of a several inches to more than two feet wide and possibly 25 feet deep, compared to a fraction of an inch to a few inches wide and a few feet deep in valley bottoms at the same overburden depth. When the relief is subdued and terrain gentle, the surface fractures will be consistent in width and depth and generally follow a smoothed ovaloid around the panel perimeter. See Figure 4. Plan View of Typical Subsidence Over a Longwall Panel in Affected Environment/Subsidence. Cracks will tend to be widest (approaching 20 inches wide) and deepest (possibly 50 feet) along prominent joints and fractures on the steepest slopes and cliffs, which, in turn may become less stable and more susceptible to landslides and rockfalls. Landslides and rockfalls will be most likely to occur where mining approaches the outcrop, and the overburden depth is decreasing. Tilting and tensile strain elongation of the ground surface is greatest where the overburden is the least. The greatest subsidence impact is likely to occur in geologic hazard areas where either of the following two conditions occur: 1. The subsidence-induced tilt direction, which is towards the longwall panel, parallels the slope direction, which temporarily increases the slope of the valley wall, but the progressively greater depth progressively decreases the surface tensile strain. See Figure 9. Localized Mining Induced Slope Angle Changes in part C. 2. The direction of longwall face advance is in the same direction as the slope inclination, which opens progressively wider surface fractures, i.e. as the longwall face moves from deeper towards shallower overburden progressively increases the surface tensile strain, but temporarily decreases the slope of the valley wall. See part B of Figure 9. Localized Mining Induced Slope Angle Changes. 5.2 Variable Overburden Thickness

For any mining panel width and coal extraction thickness, the maximum subsidence, tilt, and strain at the ground surface should decrease with increasing overburden depth. A

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single panel may range from supercritical under shallow overburden to subcritical under deeper overburden. Gate road yield pillars will tend to yield more with increasing overburden depth, such that two or more adjacent panels begin to approach the theoretical behavior of a single super-panel at overburden depths greater than 1,000 to 1,500 feet. At these depths, gateroad yield pillars may be loaded beyond the minimum loading and will begin to crush. Even yield pillars are extremely unlikely to yield to the level of the adjacent caved, broken and compacted gob behind the shield canopies at the face of the longwall panel. Figure 3 Estimated Gateroad Pillar Loads From Mining First Adjacent Panel indicates the minimum load the planned 30-foot by 80-foot gateroad yield pillar must support. The 80-foot by 180-foot gateroad pillars are designed to support the load arched from over the gob when the first adjacent panel passes as the result of the yielding of the 30-foot by 80-foot pillar. Figure 3 also shows the estimated maximum rigid pillar load transferred onto the 80-foot by 180-foot gateroad pillar after the first adjacent panel has passed. The 80-foot by 180-foot gateroad pillar could be allowed to yield after the first adjacent panel has passed. In that case, as the second panel is retreated a major arched load could be transferred onto the tailgate corner of the second adjacent longwall panel from both gob areas shown on Figure 2,. Rigid gateroad pillars, such as the 80-foot by 180-foot pillars, are designed to help protect the tailgate corner during longwall mining. Rigid gateroad pillars, such as the 80-foot wide by 180-foot long gateroad pillars, shown on Figure 5. Estimated Gateroad Pillar Loads From Mining Second Adjacent Panel, must support arched loads from over both adjacent panels or they will yield and very likely crush a short distance after the second panel has passed, as indicated by the arrow showing the “Panel Face Retreat Direction” on Figure 2. Plan View of Planned Gateroad Pillars. The estimated rigid pillar loading shown on Figure 5 is for 1500 feet, but individual Red Cliff Mine panels may have as much as 2000 feet of overburden in the Coal Lease Application area. At 1500 feet, the maximum estimated rigid pillar load on the 80-foot by 180-foot resulted in an estimated stress of 6930 psi. At the planned maximum depth of 2000 feet, the estimated rigid pillar stress is 10760 psi, approximately a 55% increase. Both rigid pillar stresses exceed the 4760 psi uniaxial compressive strength of specimens from the Cameo “B” Seam at the Roadside Mine near Palisade, Colorado. However, an 80-foot wide by 11-foot high pillar should be stronger than the ASTM Standard 2-inch diameter by 4-inch long core test sample specified by American Society for Testing and Materials (ASTM), in the method for unconfined compressive strength of intact rock core specimens D2938. The rigid pillar has a width/height ratio of 7.3 versus 0.5 for the core specimens. The central part of the rigid pillars will be capable of carrying much greater stresses because of the central core of the pillar is confined by the coal around the core. Pillar ribsides of rigid pillars at the Roadside Mine rapidly sloughed into the adjacent entries and crosscuts at 1800 feet of depth. When the coal sloughed off such a pillar ribside was removed, the entry width had increased. The

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shape on the exposed pillar ribsides is commonly referred to as “hour glassed”. After such a cleanup, the pillars sloughed again, and repeated until the pillar ribsides were supported and restrained. 6.0 SUBSIDENCE ESTIMATION OVER CAMEO SEAM LONGWALL PANELS, RED CLIFF MINE PROJECT AREA

The primarily graphical subsidence estimation method developed by the British National Coal Board (NCB, 1975) for estimating trough subsidence over longwalls was used for the Red Cliff Mine Project Area. The method was based on 177 profiles measured over named longwall panels and 10 over unnamed longwall panels. This provides a means of making a worst-case estimate of the maximum vertical subsidence (Smax), tensile strain (+E), compressive strain (-E) and slope change or tilt (G) of the ground surface anywhere over a longwall panel, provided the mining height (m), mining depth (h) and panel dimensions are known. Graphs provide a means of constructing a subsidence profile from the center of a longwall panel across the sides or ends of the panel to the limit of subsidence. A graph also provides a method of constructing a horizontal strain profile from the center of a longwall panel across the sides or ends of the panel to the limit of subsidence. The NCB method has been routinely used to estimate the maximum potential magnitude and location of tensile and compressive strains and slope inclination changes that could be induced at the ground surface by planned longwall mining. Being able to predict worst-case subsidence effects has made it possible to take measures to mitigate damage to surface structures. Coal has been routinely mined under cities, highways, pipelines, power lines, factories, railroads, rivers, bridges, harbors, cathedrals, churches, schools, historic castles and keeps and other sensitive structures. The method provides conservative estimates so that engineering adjustments could be made to accommodate the conservatively predicted (worst case) subsidence effects before they develop. The NCB method has been used to conservatively estimate subsidence impacts in the Project Area. The NCB method, which is a step-by-step procedure for predicting subsidence effects from mining a longwall panel based on the fundamental factors of coal extraction thickness, panel width between gateroad pillars and overburden depth. Initially the method provides a graph for estimating the maximum vertical subsidence reduction factor for the mining height based on Panel Width versus Panel Depth (Figure 8. NCB Panel Width/Depth Maximum Subsidence (Smax) Prediction in Affected Environment/Subsidence). Then the method provides a graphical plot of various proportions of the maximum subsidence along a profile based on the Panel Width/depth ratio from the center of a panel, across the side of the panel to the limit of subsidence outside the panel (Figure 9. NCB Subsidence Profile Graph in Affected Environment/Subsidence). The distance from the center of the panel is in terms of the panel depth. The next graph provides multipliers for the ratio of the maximum subsidence divided by the depth for a wide range of Panel Width/Depth ratios. The values taken from the graphical plot for the particular Panel Width/Depth ratio cross three lines, the “EXTENSION” line estimates the maximum tensile strain (+E), the “COMPRESSION” line the maximum compressive strain (-E) and the “SLOPE” line the maximum slope change or tilt (G), (Figure 11. NCB

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Maximum Strain and Slope Prediction Graph in Affected Environment/Subsidence). The final graph provides various proportions of the maximum tensile strain (+E) and maximum compressive strain (-E) along a profiles from the center of a panel, across the side of the panel to the limit of subsidence outside the panel (Figure 12. NCB Horizontal Strain Profile Graph in Affected Environment/Subsidence). The method has been modified by others to extend its application to room-and-pillar panel mining and to consider the impact of varying proportions of sandstone, limestone and shale or mudstone in the overburden. The NCB subsidence method is used directly for longwall mines and has been modified for room-and-pillar mines. Reported subsidence predicted and measured over room-and-pillar workings at the Roadside Mine east of Palisade Colorado predicted 1.61 feet, measured 1.02 feet in the Cameo Seam; the Eagle No. 5 Mine southwest of Craig, Colorado reported having measured 10% more subsidence than predicted and the Southland Mine near Canon City, Colorado predicted 1.51 feet, measured 0.89 feet. The NCB method has been applied for subsidence prediction over a longwall panel in the Mid Continent Mine west of Redstone, Colorado predicted 4.99 feet and measured 1.71 feet; the York Canyon Mine west of Raton, New Mexico predicted 8.1 feet and measured 7.09 feet. Subsidence was predicted using a modified NCB method at the Chimney Rock coal augering mine east of Pagosa Springs, Colorado predicted 2.59 feet, measured 0.49 feet. 6.1 Subsidence Zones

There are approximately four overburden zones to consider and analyze in the trough subsidence process over a longwall panel. Figure 5. Conceptual Representation of Subsidence Deformation Zones in Affected Environment/Subsidence presents one such representation (Peng, 1992). There a four generally agreed zones of overburden response to longwall mining. They are (1) the caved or collapsed zone, (2) the fractured zone, (3) the continuous deformation zone and (4) the near-surface zones. These zones are really transitional from one to another, and not sharply bounded. 6.1.1 Caved Zone

After the removal of the coal under the roof of a longwall panel, the immediate roof collapses and caves upward to fill up the mined void. Piggott and Eynon (1977) calculated the height of the collapse zone over a longwall panel in coal measure rocks as 2 to 3.3 times the mining height based on a typical range of percent swell of 30 to 50%, see Figure 10. Potential Collapse Heights Above Different Mine Opening Geometries. The collapsed rock is a jumbled mass of rubble that will be partially reconsolidated by the overburden load. The collapsed rock no longer gives the appearance of having been part of a bedded or stratified sedimentary formation. H.F. Schulte (1957) reported that the height of the rubble zone exposed in a winze excavated down into the center of a worked area was 2.4 times the mining height above the seam floor. P. Kenny (1959) reported observing and measuring the active height of caving into the original roof above a longwall panel to range from two to four times the mining height, depending on the angle of repose, fragmentation, bed thickness and swell of the immediate roof rocks. S. Peng (1992) reported the height of the caved zone is normally 2 to 8 times the mining height, depending on the properties of the immediate roof and

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the overburden. The caved zone is extremely permeable and if the caved zone breaches an aquifer the water will enter the mine workings as an unrestricted flow. 6.1.2 Fractured Zone

Rocks in this zone undergo fracturing and fissurization both completely and partially across one or more rock layers and along bedding surfaces between layers. The bottom of the fracture zone is located where an individual bedding contact can be traced despite offsets and slight rotations between rock blocks. The fracturing decreases upward from open interconnected fractures and bedding surfaces to tight fissurization. Stream flow readings and water level fluctuations indicated by piezometers and packer tests in drill holes before, during and after longwall mining under and within the angle of draw outside panels have been used to determine the approximate upper boundary of the fracture zone (Bauer, et al, 1995: Mattson and Meggars, 1995a; Mattson and Meggars, 1995b; Peng, 1992). Whenever a monitoring well bottoms in what will be part of the fracture zone the water level and(or) pressure will initially rise slightly as the longwall face approaches, then drop significantly shortly after the longwall face passes and finally may recover somewhat over an extended period of time. Bauer, et al. (1995) reported that the water level returned to its pre-mining elevation within 2 years after mining ceased. Peng (1992, p. 143) indicates that the lower 2/3 of the fracture zone has increased hydraulic conductivity as the result of fracturing associated with subsidence. Peng states that the upper 1/3 of this zone has only minor, unconnected fractures and thus undergoes only a minor increase in water conductivity as the result of being subsided by longwall mining. Booth and Spande (1992) report an order of magnitude increase in water conductivity for an overlying sandstone as the result of subsiding in the fracture zone. According to Peng (1992, p. 6-8), the height of fracturing is a function of lithology and thickness of the stratigraphic layers. Table 7. Formulae for Predicting Fracture Zone Height (modified from Peng, 1992, p. 7), predicts the height of the fracture zone based on the competency of the overburden as indicated by the unconfined compression strength. The results of the application of this table to the planned 11-foot mining height at the Red Cliff Mine could result in the fracture zone extending 183 feet or 16.6 mining heights up into the overburden if that overburden were entirely “Hard and strong rock”; to a potential height of 123 feet or 11.2 mining heights if the overburden were “Medium hard rock”; to a potential height of 71.5 feet or 6.5 mining heights if that overburden were entirely “Soft and weak rock” overburden; to a potential height of 44.4 feet or 4 mining heights if that overburden were entirely “Weathered soft and weak rock” overburden. The Mesaverde Group overburden is a laterally and vertically variable mixture of sandstone, argillaceous shale/mudstone, siltstone and coal. Table 5. Lithologic Distributions for Dorchester Project Overburden, containing the lithologic logs from 13,880 feet of drilling for 19 drill holes at the nearby Dorchester Project site, indicates the probable considerable variability at the Red Cliff Mine Project Area. The probably dominant sandstone lithology, around 46%, could not be considered the “Hard and strong rock” with uniaxial compression strength greater than 5888 psi indicated on Table 7. The fact that it is a cliff former where present in canyon walls suggests it is locally probably in the range for “Medium hard rock”. On the other end of the scale, the “Weathered soft and weak rock” does not fit the overburden, because it is not weathered. Therefore it is recommended that the maximum height of the fracture zone

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Table 7. Formulae for Predicting Fracture Zone Height (modified from Peng, 1992 referencing Liu, 1981) SI System Hf = σ = +8.9 meters
100m 100m meters 1.2m+2.0

Rock Type Hf = 0.366m+2.0 feet σ = +29.2 feet
100m

English System

Hard and strong rock (Good water conductivity)

Medium hard rock (Worse water conductivity) Hf = σ = +5.6 meters

100m meters 1.6m+3.6

Hf = 0.488m+3.6 feet σ = +18.4 feet
100m

Soft and weak rock (Bad water conductivity) Hf = σ = +4.0 meters

100m meters 3.1m+5.0

Hf = 0.945m+5.0 feet σ = +13.1 feet
100m

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Weathered soft and weak rock (Bad water conductivity) Hf = σ = +3.0 meters

100m meters 5.0m+8.0

Hf = 1.524m+8.0 feet σ = +9.8 feet

1. hf= fractured zone height, m = mining height, σ = standard deviation. All units in meters (SI System) or feet (English System).

2. Rock type is classified based on the uniaxial compressive strength (c): hard and strong rock c > 5888 psi (39.23 MPa); medium hard rock c = 2644 - 5888 psi (19.62 - 39.23 MPa); soft and weak rock c = 1200 - 2844 psi (8.28 19.62 Mpa). (Original in Peng, 1992, p7)

for planning should be a weighted average of 46% “Medium hard rock” and 54% “Soft and weak rock”, for a worst case estimate for the fractured zone height as 95 feet. 0.46 times 123 feet plus 0.54 times 71.5 feet = 95 feet The potential for draining surface water into the Red Cliff Mine is low, but probably precludes longwall mining under stream courses and water impoundments when the bedrock overburden thickness is less than 95 feet. Consideration should be given to geophysically measuring the thickness of alluvium beneath valley where the total overburden thickness above the Cameo Seam is 200 feet or less, as shown on Figure 13. Overburden and Outcrop Map for the Project Area. 6.1.3 Continuous Deformation Zone

This zone, which is transitional to the underlying fracture zone, is from the upper limit of the fractured zone to the near-surface weathered bedrock and soil zone. See Figure 5 Conceptual Representation of Subsidence Deformation Zones in Affected Environment/Subsidence. This zone contains subsidence induced fractures, but the fractures in this zone do not persist from bed to bed and generally not across even a single bed. Pre-mining cross bedding joints remain tight through the subsidence induced downward deflection that moves with the underlying and advancing longwall face. Obviously, the continuous deformation zone can have considerable thickness, potentially hundreds of feet thick, when the overburden depth to the mining horizon is a 1,000 feet or more and the fracture zone is on the order of 100 feet. The downward deflection of the beds during subsidence above the fracture zone as the overburden beds bend toward the void left by the longwall mining operation. The deflecting beds approximate psuedo-elastic plates. The upper part of each plate-like bed undergoes subsidence induced tensile strains which may open bedding cross joints. These tensile strains are in the area from the limit of subsidence outside the panel and the inflection point between downward bending and upward bending slightly inside the active panel from the gateroad pillars. There is a similar inflection point slightly inside the active panel from the starter room. when it bends down toward the void left by the longwall mining operation. The lower part of each plate-like bed undergoes subsidence induced compressive stress that balances the tension. In the part of the trough-like subsidence curve where the bed is bent back to its original inclination the stresses are reversed in each bed, compression in the upper part and tension in the lower part. Strain relief overcoring has demonstrated that there are 3-dimensional compressive stresses in the rock below the ground surface. The horizontal compression appears to prevent the opening of pre-mining cross bedding joints in the tensile stress zone associated with the downward bending in the continuous deformation zone. After the longwall is completed, the bending pattern will be repeated over the recovery room pillars. 6.1.4 Near-Surface Zone

Most subsidence measurements are made at the top, ground, surface of this zone. From top to bottom, the near-surface zone typically consists of: (a) A relatively thin layer, generally a few feet at most, of either fragmented residual soil, weathered from the underlying rock, or colluvium that has

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moved down slope under gravity to where it lies on weathered rock, or alluvium that has been transported over the weathered rock by flowing water; (b) Beneath the fragmented surface material is the weathered, chemically altered, weakened and frequently iron-stained bedrock. The bedding cross joints are frequently slightly-open and soil-filled. There may even be minor breaks along some bedding contacts. The weathered bedrock blocks remain in position with respect to each other, but may be completely detached but inplace blocks of the weakened rock. The tensile strength of a mass of weathered bedrock is extremely low, if not zero. Weathered bedrock retains a measurable compressive strength even though the may be intensely weathered. The weathering of the in-place bedrock progressively decreases with depth until it transitions into fresh bedrock. In addition, many of the bedding cross joints become discontinuous as the weathered bedrock transitions into fresh bedrock. Fresh bedrock has a tensile strength, albeit normally more than an order of magnitude less that its compressive strength.

(c)

The upper soil-like materials in this zone are generally quite weak and cannot sustain any subsidence induced tensile strain without rupturing. These fragmented materials are stretched as the bedrock they rest on bends downward toward the center of the subsidence trough and then compressed as they reverse the bend as they approach closer to the center of the trough. See Figure 7. Critical Panel Width for Maximum Subsidence in Affected Environment/Subsidence. The in situ horizontal stress in the soil layer will be the active soil pressure, approximately one-third the gravitational stress at that depth. Longwall mining under weakly-bonded alluvium at similar depths, from 240 to 440 feet, will probably subject the area toward the center of a panel to subsidence induced compressive stress. The compressive stress is commonly evidenced by mounds, as shown on Figure 15. Cross Panel Compression Ridge in Alluvium, York Canyon Mine. In general, when fragmented materials like alluvium once deform in compression the easier it appears to continue deforming at the same location. Figure 16. Cross Panel Tension Cracks in Alluvium, York Canyon Mine shows a series of sub-parallel tension cracks in fragmental soil-like alluvium. The presence of one tensile crack in alluvium does not necessarily release the tensile strain over any significant distance. The underlying weathered bedrock materials range from extremely weak in tension and compression immediately under the fragmented soil zone layer to much weaker in tension than in compression in fresh bedrock. The in situ horizontal stress in bedrock is the remaining residual stress within the rock layers in coal bearing formations, such as the Mesaverde Group, present in the swamp deposits at the time of solidification when buried under generally thick shallow sea sediments. The original solidification stress field was probably very close to hydrostatic, equal in all directions. Uplift and erosion has progressively reduced the overburden confining pressure, but not the is situ horizontal pressure. Large shear stress can develop between the vertical and horizontal stresses when uplift and erosion is rapid, and thrust faulting or even major overthrusts may occur when the horizontal stress is released in a short period of geologic time. When uplift is gradual, the shear stress can be released gradually by long-term creep and yielding of the rock toward the lower vertical stress. The time necessary for different rock types to deform (yield) significantly to release the higher horizontal stress was discussed in detail by S. Warren Carey

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(1954). The stronger and more competent the rock type, the longer it takes for the shear stress to dissipate. However, the horizontal stress decreases as it approaches the ground surface. The lower the horizontal stress the more readily can the natural bedding cross joints open when the upper part of a layer (bed) is subjected to subsidence induced tensile bending stress. Large single fractures open at the ground surface when there is only a thin layer of fragmented material above weathered bedrock as was the case for Figure 17. Ribside Tension Crack On Steep Slope, York Canyon Mine. This open fracture follows the offset pattern of two joint sets in the underlying bedrock. Figure 18. Ribside Tension Cracks in Road Fill and Cliff Face, York Canyon Mine shows a sequence of small tension cracks in the road fill that disappear in the bedrock exposed in a cliff face. The tensile strain was sufficient to open joint blocks and(or) tilt a few of the outer sandstone blocks at the cliff face and topple them onto the roadway. It should be anticipated that longwall mining under the canyon walls will present a similar hazard for rock to roll out from undermined sandstone outcrops. The slopes of the canyon walls are certainly steep enough within the Red Cliff Mine Project Area to result in thin fragmented soil cover and, therefore, 1-foot wide surface fractures opening when undermined by a longwall panel at the shallower depths, under approximately 500 feet. The conductivity of the valley fill alluvium in the valley bottoms will potentially increase when longwall mining is performed under the valleys. No loss of surface or groundwater into the mine should occur, provided the fracture zone is not intersected. 7.0 PREDICTED SUBSIDENCE OVER THE RED CLIFF MINE PROJECT AREA

The NCB subsidence effects prediction method was used to estimate worst-case maximum vertical subsidence (Smax), maximum tensile (+E) and compressive (-E) strains and maximum slope change or tilt (Gmax) as the result of longwall mining 11 feet of coal at depths of 200 feet, 500 feet, 1000 feet, 1500 feet and 2000 feet employing the potential 800-foot wide, 900-foot wide, 1000-foot wide, 1100-foot and 1200-foot wide longwall panels. In addition, the location of maximum vertical subsidence, maximum tensile strain, maximum compressive strain and maximum slope change with respect to the centerline of the panel conditions described above were calculated. Prediction of the maximum surface fracture widths were made using fracture measurements collected at the York Canyon Mine and NCB calculated tensile strains for the fracture measurement locations relative to the underlying mined longwall panels. 7.1 Maximum Vertical Subsidence (Smax)

By itself, simply vertically lowering the ground surface would not be a problem. However, the ground surface is only lowered over and near a longwall panel as the coal between the panel headgate and tailgate pillars is progressively extracted and the longwall face is advanced. The surface subsidence trough advances with the longwall face and all sides of the longwall panel deflect downward toward the center of the panel, where the vertical subsidence is maximum. The bending of the overburden develops as the longwall panel progresses and forms a stable semi-permanent trough after the panel is completely mined. The maximum vertical subsidence over a panel is of major importance because it contributes to the magnitude of extension, compression and tilting. These subsidence effects can potentially damage surface and underground structures, infrastructure improvements and hydrologic features as well as potentially adversely impacting nearby

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overlying and underlying coal seams. All such features have a limited tolerance for these potentially adverse effects. The magnitude of the potentially adverse impacts is directly related to the maximum subsidence, i.e. the greater the subsidence the greater the magnitude of the impact, provided the depth and panel dimensions do not change. The magnitude of the potentially adverse surface impacts is inversely related to the mining depth, i.e. the magnitude of potentially adverse impacts decrease as the mining depth increases. Great Britain has lead the world in researching these relationships because every major metropolitan area, except London, was underlain by multiple mineable coal seams. It is possible to somewhat mitigate the adverse impacts by varying panel width, by designing gateroad pillars between panels to yield when the first of two adjacent panels is mined and crush after the face of the second panel is mined past and by positioning longwall panels with respect to a particularly important surface feature. The conservative NCB maximum vertical subsidence prediction for supercritical longwall panel widths is 0.9 times the mining height (m) for overburden has been previously subsided. The NCB method specifies that the previously subsided maximum vertical subsidence prediction be multiplied by 0.9 for ground that has not been previously subsided. The adjustment for previously unmined ground is referred to as the “virgin” ground correction in Great Britain. Subsidence over the proposed Red Cliff Mine Project Area was analyzed as virgin ground because none of the proposed lease area appears to have been previously mined. The overall supercritical subsidence factor for virgin ground is 0.81 times the mining height. The lowering of the ground surface over and around a supercritical longwall panel is trough shaped, as shown on Figure 4. Plan View of Typical Subsidence Over a Longwall Panel in Affected Environment/Subsidence. Figure 4 shows a supercritical width panel with the maximum subsidence (Smax) as a narrow area around and along the center of the panel and inside the 1.00 times Smax contour line. The maximum subsidence (Smax) over a critical or subcritical longwall panel occurs along a line roughly at the center of the panel, as shown on Figure 7. Critical Panel Width for Maximum Trough Subsidence in Affected Environment/Subsidence. Table 8. Maximum Vertical Subsidence (Smax) for Planned Red Cliff Mine Longwall Panels presents the Smax results of applying Figure 8. NCB Panel Width/Depth Maximum Subsidence (Smax) Prediction in Affected Environment/Subsidence and the location of Smax with respect to the individual panel centerline through application of Figure 9. NCB Subsidence Profile Graph in Affected Environment/Subsidence. Figure 19. Maximum Vertical Subsidence (Smax) With Respect to Panel Width and Depth is a plot of the predicted maximum subsidence for the potential range of panel widths at the anticipated longwall mining depths at the Red Cliff Mine Project Area. In Table 8, the Panel Width in the first column and Overburden Depth in the second column are given in both English and metric units because the NCB graphs are in metric units. Column 5 presents both the subsidence factor and immediately below the predicted maximum number of feet of vertical subsidence in a parenthesis for the planned maximum 11-foot mining height. The conservative NCB predicted maximum horizontal tensile (+E) and compressive (-E) strain values presented on Table 9. Maximum Tensile (+E) and Compressive (-E) Strains for Planned Red Cliff Mine Longwall Panels were estimated using Figure 11. NCB Maximum Strain and Slope Prediction Graph in Affected Environment/

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Table 8. Maximum Vertical Subsidence (Smax) for Planned Red Cliff Mine Longwall Panels. Panel Width feet (meters) 800 (243.8) Overburden Depth feet (meters) 200 (61.0) 500 (152.4) 1000 (304.8) 1500 (457.2) 2000 (609.6) 200 (61.0) 500 (152.4) 1000 (304.8) 1500 (457.2) 2000 (609.6) 200 (61.0) 500 (152.4) 1000 (304.8) 1500 (457.2) 2000 (609.6) 200 (61.0) 500 (152.4) 1000 (304.8) 1500 (457.2) 2000 (609.6) Width/ Depth Ratio (feet) 4.000 1.600 0.800 0.533 0.400 Supercritical, Critical or Subcritical Panel Supercritical Supercritical Subcritical Subcritical Subcritical Smax/m Subsidence Factor (feet) 0.810 (8.91) 0.810 (8.91) 0.681 (7.49) 0.435 (4.79) 0.292 (3.21) 0.810 (8.91) 0.810 (8.91) 0.716 (7.87) 0.490 (5.39) 0.342 (3.76) 0.810 (8.91) 0.810 (8.91) 0.747 (8.22) 0.549 (6.04) 0.396 (4.36) 0.810 (8.91) 0.810 (8.91) 0.765 (8.42) 0.598 (6.58) 0.550 (4.85) Smax Distance, from Panel Centerline Ribside from to from to (feet) (feet) 0 0 0 0 0 +10 +25 0 0 0 -400 -400 -400 -400 -400 -390 -375 -400 -400 -400

900 (274.3)

4.500 1.800 0.716 0.600 0.450

Supercritical Supercritical Subcritical Subcritical Subcritical

0 0 0 0 0

+10 +25 0 0 0

-450 -450 -450 -450 -450

-440 -425 -450 -450 -450

1000 (304.8)

5.000 2.000 1.000 0.667 0.500

Supercritical Supercritical Subcritical Subcritical Subcritical

0 0 0 0 0

+10 +25 0 0 0

-500 -500 -500 -500 -500

-490 -475 -500 -500 -500

1100 (335.8)

5.500 2.200 1.100 0.667 0.500

Supercritical Supercritical Subcritical Subcritical Subcritical

0 0 0 0 0

+10 +25 0 0 0

-550 -550 -500 -500 -500

-540 -525 -500 -500 -500

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Table 8. Maximum Vertical Subsidence (Smax) for Planned Red Cliff Mine Longwall Panels (Cont.) Panel Width feet (meters) 1200 (365.8) Overburden Depth feet (meters) 200 (61.0) 500 (152.4) 1000 (304.8) 1500 (457.2) 2000 (609.6) Width/ Depth Ratio (feet) 6.000 2.400 1.200 0.667 0.500 Supercritical, Critical or Subcritical Panel Supercritical Supercritical Subcritical Subcritical Subcritical Smax/m Subsidence Factor (feet) 0.810 (8.91) 0.810 (8.91) 0.788 (8.55) 0.681 (7.13) 0.490 (5.39) Smax Distance, from Panel Centerline Ribside from to from to (feet) (feet) 0 0 0 0 0 10 +25 0 0 0 -600 -600 -600 -600 -600 -590 -575 -600 -600 -600

NOTES: Single panel analysis and positive distances are away from the panel centerline and negative distances are toward the panel centerline.

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Table 9. Maximum Tensile (+E) and Compressive (-E) Strains for Planned Red Cliff Mine Longwall Panels. Width/ Depth Ratio Maximum Extension Multiplier Maximum Smax/ Subsidence Depth Smax Ratio (feet) 8.91 8.91 7.49 4.79 3.21 8.91 8.91 7.87 5.39 4.31 8.91 8.91 8.22 6.04 4.36 8.91 8.91 8.42 6.58 4.85 8.91 8.91 8.55 7.13 5.39 0.04555 0.01782 0.00855 0.00475 0.00270 0.65 0.65 0.65 0.66 0.75 0.04455 0.01782 0.00842 0.00439 0.00242 0.65 0.65 0.66 0.67 0.78 29000 11600 5470 2940 1890 29000 11600 5560 3140 2020 0.04455 0.01782 0.00822 0.00403 0.00218 0.65 0.65 0.66 0.72 0.82 29000 11600 5420 2900 1790 500 500 512 537 626 550 550 558 584 642 600 600 608 624 674 0.04455 0.01782 0.00787 0.00359 0.00188 0.65 0.65 0.68 0.75 0.83 29000 11600 5350 2690 1560 450 450 460 504 636 0.51 0.51 0.59 1.05 1.55 0.51 0.51 0.54 0.91 1.37 0.51 0.51 0.52 0.78 1.18 0.51 0.51 0.53 0.68 1.05 0.04455 0.01782 0.00749 0.00319 0.00160 0.65 0.65 0.66 0.78 0.79 29000 11600 4940 2490 1260 400 400 417 477 662 0.51 0.51 0.68 1.25 1.72 22700 9090 5090 3990 2750 22700 9090 4640 3770 2920 22700 9090 4440 3670 1790 22700 9090 4380 3420 2860 22700 9090 4530 3230 2840 Maximum Distance Maximum Maximum Distance Tensile from Compression Compressive from Strain(+E) Centerline Multiplier Strain(-E) Centerline (υ-strain) (feet) (υ-strain) (feet) 235 235 110 4 0 264 264 190 72 16 293 293 200 117 36 323 323 245 135 66 352 352 289 164 96

Panel Overburden Width Depth (feet) (feet)

800

200 500 1000 1500 2000 4.500 1.800 0.900 0.600 0.450 5.000 2.000 1.000 0.667 0.500 5.500 2.200 1.100 0.733 0.550 6.000 2.400 1.200 0.800 0.600

4.000 1.600 0.800 0.533 0.400

900

200 500 1000 1500 2000

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1000

200 500 1000 1500 2000

1100

200 500 1000 1500 2000

1200

200 500 1000 1500 2000

Subsidence. The locations of the maximum tensile and compressive strains with respect to the individual panel centerlines were estimated using Figure 12. NCB Horizontal Strain Profile Graph in Affected Environment/Subsidence. The maximum tensile and compressive strains are important because if they can be conservatively predicted steps can be taken to reinforce critical surface structures or modify the mining plan to reduce the maximum tensile and compressive strains. For example, high pressure natural gas pipelines have been undermined by longwalls by maintaining a smooth pipeline through the period when the trough is forming under the pipeline, while the longwall face advances across or along the pipeline. This has been accomplished by digging up, temporarily supporting the section of the pipeline ahead of the advancing longwall face and reburying the pipeline after the longwall face has advanced well past the elevated section of the pipeline. This procedure prevents the buried pipeline from being pulled apart at an open fracture. Many countries with significant longwall coal mining operations have recommended and(or) established allowable strains for particular surface features. Some of these are included in APPENDIX A. RECOMMENDED LIMITS FOR SUBSIDENCE INDUCED STRAIN AND TILT. 7.2 Maximum Horizontal Strain

The maximum horizontal tensile strains are the most serious potential hazard with respect to anticipated subsidence impacts from longwall mining in the proposed Red Cliff Mine lease area. This involves protecting the public from larger open fractures, as shown on Figure 20. Tension Crack Over Starter Room, York Canyon Mine, when longwall mining at shallow depths (<500 feet). There is also the temporary potential for large boulders being dislodged from sandstone cliffs on the canyon walls by smaller tensile strains from deeper active longwall panels, as indicated on Figure 18. Ribside Tension Cracks in Road Fill and Cliff Face, York Canyon Mine. Table 10. Predicted Surface Fracture Widths Based on York Canyon Mine Measurements presents the relationship between predicted tensile strain and the measured width of selected open subsidence fractures above three longwall panels at the York Canyon Mine west of Raton New Mexico. The York Canyon Mine was mining coal in the Mesaverde Group, but the overburden lithology could well differ from that present at the Red Cliff Mine proposed Project Area. The horizontal tensile strain over the barrier pillars between panel groups will probably increase because the strain at the surface over the barrier pillar caused by each adjacent panel is additive. It is possible that the maximum horizontal tensile strain above the larger barrier pillars planned between panel groups could as much as double the tensile strain on the surface over the center of such a barrier pillar. This is possible because it depends on the panels on both sides being subcritical precisely enough to place the maximum tensile strain at the center of the barrier pillar. For example, using Figure 12. NCB Horizontal Strain Profile Graph in Affected Environment/Subsidence, the center of a 1000-foot wide panel at the depth of 2000 feet (Panel Width/Depth Ratio = 0.500) is 600 feet from the center of a 200-foot wide barrier pillar, 0.300 times the 2000-foot depth. The predicted tensile strain over the center of the barrier pillar from the first longwall panel to be completed on one side of the group barrier pillar is 95% of the predicted maximum horizontal tensile strain. If a longwall panel group with the same dimensions and depth is mined on the other side of the barrier pillar is completed it would add 95% of its maximum horizontal tensile strain at the center of the 200-foot barrier pillar, nearly doubling (approximately 1.9 times) the tensile strain at that location,

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Table 10. Predicted Surface Fracture Widths Based on York Canyon Mine Measurements. Assumes virgin ground and 11-foot mining height. Panel Width (feet) Overburden Depth (feet) Width/ Depth Ratio Maximum Maximum Subsidence Tensile (feet) Strain (υ-strain) 8.91 8.91 7.49 4.79 3.21 8.91 8.91 7.87 5.39 3.76 8.91 8.91 8.22 6.04 4.36 8.91 8.91 8.42 6.58 4.85 8.91 8.91 8.55 7.13 5.39 29000 11600 4940 2490 1260 29000 11600 5350 2690 1560 29000 11600 5420 2900 1790 29000 11600 5470 2940 1890 29000 11600 5560 3140 2020 Open Fracture Width (inches) 19.8 7.8 3.2 1.5 0.7 19.8 7.8 3.5 1.7 0.9 19.8 7.8 3.5 1.8 1.0 19.8 7.8 3.6 1.8 1.1 19.8 7.8 3.6 2.0 1.2 Predicted Distance from from Centerline Ribside (feet) (feet) 400 400 417 477 662 450 450 460 504 636 500 500 512 537 626 550 550 558 584 642 600 600 608 624 674 0 0 17 77 262 0 0 10 54 186 0 0 12 37 126 0 0 8 34 92 0 0 8 24 74

800

200 500 1000 1500 2000 200 500 1000 1500 2000 200 500 1000 1500 2000 200 500 1000 1500 2000 200 500 1000 1500 2000

4.000 1.600 0.800 0.533 0.400 4.500 1.800 0.900 0.600 0.450 5.000 2.000 1.000 0.667 0.500 5.500 2.200 1.100 0.733 0.550 6.000 2.400 1.200 0.800 0.600

900

1000

1100

1200

NOTE: Single panel subsidence analysis.

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and similarly increase the width of the predicted open fracture. The total additive tensile strain at other locations along the overlapping strain profiles could be conservatively predicted by superimposing the subsidence profiles from the two adjacent longwall panels. The rapidly changing overburden depths at the Red Cliff Mine Project Area could make estimating the total tensile strains across barrier pillars using the NCB method a time consuming process. 7.3 Maximum Tilt (G)

The maximum slope or tilt change as the result of mining a longwall panel occurs at the inflection point between bending progressively more downward toward the center of the panel to bending progressively less downward closer to the center of the panel. On Figure 4. Plan View of Surface Subsidence Over a Longwall Panel in Affected Environment/Subsidence, this is the 0.50 Smax contour line. With the exception of subcritical panels, where the panel width is less than approximately 0.41 times the panel depth, the inflection line is within the sides of the panel projected to the ground surface. Table 11. Maximum Slope Angle (Tilt) Change for Planned Red Cliff Mine Longwall Panels lists potential panel widths, depths, panel width/depth ratios and the slope (tilt) change multiplier from Figure 10. NCB Maximum Strain and Slope Prediction Graph in Affected Environment/Subsidence. The calculated maximum slope angle change is presented in terms of percent grade change and degrees. The conservative NCB predicted single panel maximum slope angle changes resulting from longwall mining of the proposed Red Cliff Mine Project Area, potentially ranging from approximately 0.5% to 12% (0.3o to 7o) would present significant hazards to overlying industrial, business and residential uses. However, no such land uses are planned over the Red Cliff Mine. The principal tilting hazard posed to the undeveloped surface overlying the proposed lease area by longwall mining would appear to be tilting cliff forming sandstone beds outcropping on the canyon walls and potentially toppling sandstone boulders toward the canyon floors. Figure 18. Ribside Tension Cracks in Road Fill and Cliff Face, York Canyon Mine show a sandstone cliff failure in the combined downslope tilted and tension zone approximately 50 feet outside the underlying longwall panel ribside. Table 3. Slope Geometries Within Project Area lists some of the higher overall canyon slopes in the lease area. The slopes of Big Salt Wash canyon, the major canyon in the proposed lease area, walls are as high as 920 feet and as steep overall as 32o, which is the most impressive combination in the Project Area. It is possible to at least partially mitigate this and similar potential major toppling hazards in Garvey Canyon and along Munger Creek by retreating toward these drainages from the north and from the south. Retreating toward these drainages, would slightly flatten the slope of the canyon walls as opposed to advancing away from Big Salt Wash which would slightly steepen the canyon walls. See Figure 9. Localized Mining Induced Slope Angle Changes. The slope angle or tilt change over a barrier pillar is not additive like horizontal tensile strains over barrier pillars. The slope angle or tilt change coming from longwall panels on opposite sides of a barrier pillar are in opposite directions Therefore, where the tilting overlaps the longwall mining induced slope changes at least partially cancel each other. The maximum interaction is potentially possible complete cancellation is unlikely.

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Table 11. Maximum Slope Angle (Tilt) Change for Planned Red Cliff Mine Longwall Panels. Panel Overburden Width/ Width Depth Depth (feet) (feet) Ratio (feet) 800 200 500 1000 1500 2000 200 500 1000 1500 2000 200 500 1000 1500 2000 200 500 1000 1500 2000 200 500 1000 1500 2000 4.000 1.600 0.800 0.533 0.400 4.500 1.800 0.900 0.600 0.450 5.000 2.000 1.000 0.667 0.500 5.500 2.200 1.100 0.733 0.550 6.000 2.400 1.200 0.800 0.600 0.04455 0.01782 0.00749 0.00319 0.00160 0.04455 0.01782 0.00787 0.00359 0.00188 0.04455 0.01782 0.00822 0.00403 0.00218 0.04455 0.01782 0.00842 0.00439 0.00242 0.04455 0.01782 0.00855 0.00475 0.00270 2.73 2.73 2.82 3.27 3.37 2.73 2.73 2.76 3.12 3.45 2.73 2.73 2.75 2.97 3.37 2.73 2.73 2.74 2.87 3.24 2.73 2.73 2.74 2.82 3.12 12.16 4.86 2.11 1.04 0.54 12.16 4.86 2.17 1.12 0.65 12.16 4.86 2.26 1.20 0.73 12.16 4.86 2.31 1.26 0.78 12.16 4.86 2.34 1.34 0.84 6.93 2.78 1.21 0.60 0.31 6.93 2.78 1.24 0.64 0.37 6.93 2.78 1.29 0.69 0.42 6.93 2.78 1.32 0.72 0.45 6.93 2.78 0.45 0.77 0.48 325 325 288 315 412 366 366 327 336 400 407 407 373 363 407 447 447 416 392 427 488 488 459 431 448 -75 -75 -112 -85 12 -84 -84 -123 -114 -50 -93 -93 -127 -137 -93 -103 -103 -134 -158 -123 -112 -112 -151 -169 -152 Smax/ Depth Ratio Slope (Tilt) Multiplier Maximum Slope or Tilt Angle o (%) ( ) Predicted Distance from from Centerline Ribside (feet)

900

1000

1100

1200

NOTE: Positive distances are away from the panel centerline and negative distances are toward the panel centerline.

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7.4

Angle of Draw

The angle of draw defines the extent that subsidence can be detected beyond the limits of mining. The angle of draw is the angle formed by the vertical line above the outer limit of mining and the lateral limit of detectable subsidence. It has special importance to land-use planning because it indicates where the surface will be unaffected by mininginduced subsidence. Reported angles of draw are highly variable, as indicated by Table 6. Angles of Draw for Coal Mining in the United States and Europe which presents angles of draw from 19o to 45o collected from various countries and sources. The study by Abel and Lee (1984) demonstrated that the potential for error in applying the angle of draw measured in one country to another, or even within one country and(or) district, is considerable. Table 12. Angles of Draw for Mines in Flat-Bedded Sedimentary Rocks with Respect to Lithology of Overburden, from their paper, shows a wide range of angles of draw, from 0o to 40o, indicates that lithology statistically appears to plays a roll in determining the angle of draw. The various sources of data demonstrate that the NCB’s 35o angle of draw is a conservative estimate. 7.5 Break Angle

The historic concept of a break angle as the location of the tensile surface cracking has been discarded because it coincides with the location of maximum tensile strain (+E). In areas of thick soil or alluvium, tensile cracking at the surface may be difficult to see because the tensile strain typically produces several narrow cracks, as can be seen on Figure 18. Ribside Tension Cracks in Road Fill and Cliff Face, York Canyon Mine. Narrow cracks fill rapidly because the alluvium contains fines and has little tensile strength. When bedrock is close to the surface, the easiest tensile crack to see open is over the starter room, because it initially increases in width and doesn’t close as the longwall face advances. Cracks on the surface over a starter room are usually the first to open and take a long time to fill by the natural processes of weathering, mass wasting, and erosion. The tensile crack accompanying the advance of the longwall face is mobile, i.e. it advances as the longwall face advances. However, the opening of bedding cross joints in the moving tensile strain zone ahead of an advancing underlying longwall face is temporary. These tensile cracks start to close after the longwall face has passed about 0.15 times the depth (approximately 8o) and the horizontal compressive strain starts. Closure in the compressive strain zone reaches a maximum when the longwall face is approximately 0.3 times the depth past the tensile fracture. Figure 15. Cross Panel Compression Ridge in Alluvium, York Canyon Mine shows a compression mound that was pushed up when the soil that fell into the initial tension crack was compressed by the trailing compression zone. Similarly, the tensile strain zones on the ground surface roughly over the panel ribsides, starter room and eventually the shield recovery room is relatively easy to see as it develops. As the longwall face passes a position on the surface overlying any location along either gateroad the tensile crack, or cracks, develop. After the longwall face has advanced approximately 0.7 times the depth the trough and associated tensile crack remains open, as shown on Figure 17 Ribside Tension Crack On Steep Slope, York Canyon Mine.

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Table 12. Angles of Draw for Mines in Flat-Bedded Sedimentary Rocks with Respect to Lithology of Overburden (Abel and Lee, 1984) Lithologic Percentages in Overburden Shale1 Sandstone Limestone Angle of Draw (degrees)2 References

Location, Commodity

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Pennsylvania coal. Do----------------------Do----------------------New Mexico coal. Great Britain coal. Do----------------------Do----------------------Do----------------------Do----------------------New Mexico uranium. California borate 3 Pennsylvania coal. India coal. Do----------------------Do----------------------Do----------------------Do----------------------Do----------------------Do----------------------Do----------------------Illinois coal. Do----------------------Do----------------------Arizona copper.

50 78 59 63 12 68 63 64 51 86 17 48 25 23 57 37 35 35 23 32 71 57 85 0

22 13 11 37 88 32 29 36 48 14 83 52 75 77 43 63 65 65 77 68 17 38 9 0

28 9 30 0 0 0 8 0 1 0 0 0 0 0 0 0 0 0 0 0 12 5 6 100

18.0 24.0 9.0 15.0 0.0 17.0 12.0 29.0 16.5 40.0 8.0 (avg.) 18.0 13.0 21.0 28.0 18.0 17.0 17.0 17.0 27.0 8.5 0.0 34.7 12.0

Greenwald and others (1937). Maize, Thomas, and Greenwald (1940). Maize and Greenwald (1939). Abel and Gentry (1978). English (1940). Sinclair (1950). Do. Briggs and Ferguson (1933). Thorneycroft (1931). C. H. Parrish written commun., 1979). Obert and Long (1962). Montz and Norris (1930). Kumar and Singh (1973). Do. Do. Do. Do. Do. Do. Do. Herbert and Rutledge (1927). Do. Auchmuty (1931). Trischka(1934)3.

3

'Includes all argillaceous rocks. 2Angles measured from vertical. Fault bounded on all four sides. Therefore, not employed in statistical analysis.

7.6

Rate and Duration of Subsidence

The first potentially detectable subsidence at a given point on the ground surface ahead of an approaching longwall face begins when the longwall face is something less than approximately 0.75 times the overburden depth of the seam, has subsided about 15% of Smax when the longwall face passes under the point, is approximately 50 percent complete when the longwall face is 0.2 to 0.3 times the overburden depth beyond the point, and appears to have stopped subsiding when the face is between 0.5 and 0.6 times the overburden depth beyond the point. However, there is still 5% to 9% of residual subsidence to take place after the longwall face has either mined beyond the influence distance or the panel has been completed. Residual subsidence is probably the result of consolidation of the gob and closure of some overlying bed separations in the overburden. Measuring the time until residual subsidence is complete requires extremely precise leveling to measure subsidence. Collins (1977) reported the results of an eight year program in the South Wales Coalfield. He reported the results from six panels at depths from 207 feet to 2330 feet. Longwall mining of the six panels was completed over periods from 0.5 to 1.5 years and measurable residual subsidence continued for 2.0 to 4.5 years afterwards. Complete stability is not significant because the potentially damaging strains and tilt are directly dependent on the magnitude of the subsidence and the magnitude of residual subsidence is small in relation to the subsidence that takes place during the active period. Shortly after the advancing longwall face has opened up enough area to initiate the first major roof cave behind the shields, the wave of surface subsidence accompanying face advance will start. The movement of the longwall face and the ground surface are so closely tied together that when the advance of the face stops the advance of the accompanying wave of surface subsidence advance may stop in less than a shift, but definitely over a weekend. Stopping the advance of a longwall face will, however, potentially increase the loads on the face supports. Sloughing from the coal face can also occur during stoppages. Restarting face advance after holiday periods, etc. can be difficult. Peng (1992, p. 20-22) reports maximum dynamic tilt and horizontal strain decreases with increasing speed of longwall extraction. Peng presents graphical data for the rate of face advance for various longwall faces in a West Virginia coal mine which increased from roughly 10 feet/day to roughly 43 feet/day: 1. Maximum dynamic tilt appears to have decreased an average of approximately 44 percent (Peng, 1992, Fig. 3.6). The scatter of the dynamic tilt data is so large and the contradictory indication of an increasing maximum dynamic tilt for the single most rapid 43 feet/day face advance indicated on Fig. 3.6 that it appears statistically only possible to state that the tilt probably decreased with increasing face advance rate. 2. Maximum dynamic tensile strain decreased by an average of approximately 28 percent (Peng, 1992, Fig. 3.7). The scatter of the dynamic tensile strain data indicated on Fig. 3.7 is less than for the dynamic tilt data and it may be statistically possible to indicate a rough numerical relationship between decreasing tilt and increasing face advance rate.

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3. Maximum dynamic compressive strain decreased by an average of approximately 62 percent (Peng, 1992, Fig. 3.8). The scatter of the dynamic compressive strain data indicated on Fig. 3.8 is nearly as large as that for the dynamic tilt data. It appears statistically possible to state that the maximum dynamic compressive strain decreased with increasing face advance rate. 8.0 8.1 IMPACTS OF SUBSIDENCE ON STRUCTURALLY SENSITIVE AREAS Longwall Mining in Geologic Hazard Areas of Landslides, Rockfalls, and Unstable Slopes

These unstable areas occur naturally on steep canyon walls in the Mesaverde Group. Unstable slope features already present can be adversely impacted by longwall mining. It is important to develop an inventory of baseline data on any landslide, rockfall, and generally unstable areas before mining begins, so that movements due to natural processes can be excluded from any potential mining impacts if they would create a hazard to the public. It is also important to have an assessment plan to distinguish between mining-related impacts on existing unstable areas and other activities, such as road construction. The assessment plan should include a subsidence monitoring program which should indicate the maximum angle of draw to the maximum limit of subsidence effects for the Red Cliff Mine Project area. Tilt and strain caused by subsidence may reactivate movement in a currently stable or dormant landslide and rockfall areas where slope movements would be expected to eventually naturally reoccur due to natural causes. In the case of unstable natural slopes they are most likely to develop, reoccur and grow on steeper slopes during periods of increased precipitation. If a dormant landslide or rockfall area starts moving during a dry period and within approximately 0.7 times the depth distant from an advancing longwall face, the movement has very likely to have been triggered by the mining. Large tilt and horizontal strain values caused by longwall mining under the shallower overburden, close to the coal outcrop or on the lower sections of steep canyon walls on the southwest side of the Project Area, could potentially cause the greatest mining impacts on areas that are already unstable. 1. Tilt values greater than about 5 percent, with approximately 500-foot overburden depth or less, may impact areas that are already prone to landslides or rockfalls, particularly where the tilt direction parallels the downslope direction, and, therefore, increases the overall slope angle by roughly the maximum predicted tilt amount. See Figure 9 C and Figure 18. 2. The stability of geologic hazard areas may also be increased by subsidence, where the subsidence induced tilt direction is opposite to the topographic slope direction. In this instance, the overall slope angle would

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be decreased by as much as the maximum subsidence-induced tilt change. See Figures 9B. 3. Horizontal tensile strain values generally greater than approximately 1 percent (10000 υε) at 500-foot overburden depths and less also may accelerate natural landslide movement or rockfall, particularly during periods of high or increased precipitation. Figure 18. Ribside Tension Cracks in Road Fill and Cliff Face, York Canyon Mine shows a location where a sandstone cliff face failed after some of the shale underlying a sandstone cliff face had been removed for the pioneer road and then the headgate end of the longwall panel was mined past at approximately 360 feet below but over 50 feet to the right of the cliff. The estimated non-maximum tensile strain acting on the cliff face was about 0.5 percent (~5000 υε). 8.2 Mining Beneath Stream Courses

The only permanent stream courses indicated on the Garvey Canyon Quadrangle and Howard Canyon Quadrangle for the Project Area are Big Salt Wash and East Salt Creek. Big Salt Wash is the only perennial stream that overlies planned Red Cliff Mine workings in the Cameo Seam. East Salt Creek does not cross over any part of the Cameo Seam within the Existing Coal Lease or Coal Lease Application area. The Cameo Seam outcrop crosses Big Salt Wash approximately 7,800 feet upstream from the southern boundary of the Coal Lease Application area, as shown on Figure 13. Overburden and Outcrop Map for the Project Area. Within the Existing Coal Lease area, the Cameo Seam outcrop crosses the intermittent stream course in Stove Canyon, Section 2, T. 8 S., R102 W. northwest of Big Salt Wash and the intermittent stream courses in Munger Canyon and its southeast tributary, Sections 22 and 27, S. 7 S., R. 102 W. These Cameo Seam outcrops are within the Project Area. Within the Coal Lease Application area the Cameo Seam outcrop crosses the intermittent stream course in Buniger Canyon approximately 4,500 feet upstream from where it meets the perennial stream in Big Salt Wash. In order to mitigate potential subsidence impacts in the Coal Lease Application area and the immediately adjacent north, east and south parts of the Project Area, it was necessary to have a conceptual mining plan. The goals of the conceptual plan were to maximize safety, then mitigate to the extent possible subsidence impacts and finally to maximize resource recovery. The proposed portal is the anchor for the concept. The conceptual plan that follows involves at least two sets of east-west mains driven off the Big Salt Wash mains. A bleeder entry may well be necessary along the south boundary of the Project Area. Either a bleeder entry or a third set of mains would probably be required along the northern boundary of the Project Area. It will be necessary to drive the main access entries approximately 5,000 feet N 45o E from the planned Red Cliff Mine portal to where it will cross under the overlying intermittent stream course in Stove Canyon at a depth of less than 200 feet., The main entries will probably continue to a distance of approximately 9,000 feet where it will cross beneath the intermittent stream course in Buniger Canyon at a depth of slightly less than

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500 feet, still within the Existing Coal Lease area. The N 45o E direction of the Red Cliff Mine main entries indicates that the Main entries will probably turn half-right after passing under Buniger Canyon to drive east just south of the boundary between T. 7 S. and T. 8 S. Driving the mains in this direction would reach Big Salt Wash in approximately 8,200 feet at a depth of approximately 200 feet. It is anticipated that the main entries will split at Big Salt Wash with one branch continuing to the east, the 1st East Mains, and the other driven to the northeast under Big Salt Wash, the Northeast Mains. The East Mains would be the base for developing longwall panels as much as 14,000 feet to the south. If no longwall panels are driven to the north it could be possible to rob the barrier and main entry pillars on the retreat provided the retreat mining was protected by unmined coal on the north side of the 1st East Mains. This assumes that the individual longwall panels driven south off the 2nd East Mains are mined after the 2nd West Mains and that the 2nd East Mains longwall panels are sequenced from east to west and retreated from south to north following the retreat of the 1st East Mains pillars. Retreat mining the 2nd West Mains and the 2nd East Mains would probably require a third set of main entries driven from East Salt Creek or Munger Creek and across the north end of the Project Area. Mining beneath the perennial and intermittent stream courses will necessitate preventing water loss to the underlying workings. As discussed previously in section 6.1.2 Fractured Zone, water loss to the fracture zone is probable through 100 feet or less of overburden when longwall mining in the Red Cliff Mine Project Area. Big Salt Wash is particularly at risk because it also contains a road and has agricultural uses. Because there is no available depth of alluvium below any of the deeply incised canyons and the absence of any data on the potential fault control of the nearly trellis drainage pattern in the Project Area, conservatism must be used and a minimum of 200 feet of overburden required to positively prevent water loss from longwall mining under even intermittent stream courses. Table 10. Predicted Surface Fracture Widths Based on York Canyon Mine Measurements provides conservative estimates of fracture widths with respect to depth of overburden and panel width. 9.0 SURFACE SUBSIDENCE MONITORING

Various governmental bodies may require a monitoring demonstration that the predicted subsidence effects are indeed conservative and not significantly exceeded. Specifically, a monitoring program over one of the initial longwall panels that will obtain subsidence data on the maximum vertical subsidence (Smax), tensile (+E) and compressive (-E) horizontal strains, angle of draw (α) and subsidence induced tilt (G) for this unique geologic environment. If room-and-pillar panels are mined it may be necessary to measure the same subsidence effects, or to demonstrate that sufficient pillars are left to prevent subsidence. The Surface Subsidence Monitoring Guidelines by Abel (1982) indicate one possible monitoring program that has been utilized to provide the data, when required. Figure 21. Subsidence Monitoring Program indicates the location of surface monuments for flat lying terrain. The rugged terrain and rapidly changing overburden depth in the Project Area will necessitate panel-by-panel monument spacing modifications in the field after the locations of the initial panels become available. Either monument spacing for the test

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panel will have to be continuously changed to match overburden changes or all monuments will have to be spaced to match the shallowest overburden for that panel. Considerable advances have been made since the early subsidence transit and leveling monitoring programs by the NCB. The precise leveling used by Collins (1977), has been replaced by Electronic Distance Measurement (EDM) and more recently the Global Positioning System (GPS) has apparently increased its accuracy to the point that it has been used to measure subsidence induced changes at the ground surface. There is no substitute for properly constructed monuments either anchored to bedrock or at sufficient depth to prevent temperature and moisture changes from impacting the measurements. 10.0 REFERENCES

Abel, Jr., J.F., 1982, Surface Subsidence Monitoring Guidelines, Phase 1 Report: U.S. Geol. Survey Contract No. 14-08-001-18822, 11 p. Abel, Jr., J.F. & F.T. Lee, 1984, Lithologic Controls on Subsidence: Trans. SME/AIME, v 274, p 2028-2034. Abel, Jr., J.F., 1988, Soft rock pillar design: Intl. Jour Mining & Geological Engrg, v 6, p 215-248 Bauer, R.A., B.B. Mehnert, D.J. van Roosendaal, P.J. DeMaris, N. Kawamura & C.J. Booth, 1995, Land subsidence and hydrologic changes due to longwall coal mining in Illinois: in Land Subsidence Case Studies and Current Research, AEG Sp Pub 8, p 218-228. Booth, C.J. and E.D. Spande, 1992, Potentiometric and aquifer property changes above subsiding longwall min panels: Ground Water, v 30, n 3, May-June, p 362-368. Brauner, G., 1973:, Ground movements and mining damage, Pt. 2 of Subsidence due to underground mining: U.S. Bureau of Mines Information Circular 8572, 53 p. Briggs, Henry, 1929, Mining Subsidence. London, Edward Arnold and Co., 153 p. Carey, S.W., 1954, The rheid concept in geotectonics: Jour. Geol. Soc. Aust., v 1, n 1, p 67-117. Collins, B. J., 1977, Measurement and analysis of residual mining subsidence movements, in Geddes, J. D., ed., Large ground movements and structures: New York, Halsted Press, p 3-29. Dunrud, C. R., 1976, Some engineering geologic factors controlling coal mine subsidence in Utah and Colorado. U. S. Geological Survey Professional Paper 969. Dunrud, C. R., and F.W. Osterwald; 1980, Effects of coal mine subsidence in the Sheridan, Wyoming, area: USGS Geological Survey Professional Paper 1164, 49 p. Gentry, D. W. and J.F. Abel, Jr., 1978, Rock mass response to mining longwall panel 4N, York Canyon Mine: Mining Engineering, Society of Mining Engineers, Mar 1978, p 273-280.

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Hutchings, R., M. Fajdiga and D. Raisbeck, 1978, The effects of large ground movements resulting from brown coal open cut excavations in the Latrobe Valley, Victoria: in Proc. Conference on large ground movements and structures, J.D. Geddes ed, Cardiff, Wales, 1977, p 136-161. Kenny, P., 1969, The caving of waste on longwall faces: Intl Jour Rock Mech Min Sci, v 6, p 541-555. Lee, A. J., 1966, The effect of faulting on mining subsidence: Mining Engineer, p 735745, August. Lee, F.T. & J.F. Abel, Jr., 1983, Subsidence from Underground Mining, Environmental Analysis and Planning Considerations: U.S. Geol. Survey Circular 876, 28 p. Mattson, L.L., J.A. Magers & D.R. Dolinar, 1995, Subsidence impacts on ground and surface water at a western coal mine: in Land Subsidence Case Studies and Current Research, AEG Sp Pub 8, p 267-273 Mattson, L.L., J.A. Magers, 1995, Ground-water variation at a western longwall coal mine: in Land Subsidence Case Studies and Current Research: 1995, AEG Sp Pub 8, p 275-280. National Coal Board, 1975, Subsidence engineer's handbook. National Coal Board, United Kingdom, Mining Department, 111 p. Ochab, Z., 1961, Rules concerning new instructions for the determination of safety pillars in the collieries of Upper Silesian coal fields: Polish Ministry for Mining and Power, Report No. 271 Pendleton, J.A., 1985, Coal mine subsidence in Colorado, Practical application in a regulatory setting: SME Preprint No 85-328, 8 p. Peng, S.S., 1992, Surface subsidence engineering. Society for Mining, Metallurgy and Exploration, Inc., 161 p. Piggott, R. M. and P. Eynon, 1977, Ground movements arising from the presence of shall mine workings: in large ground movements and structures, Geddes, J. D., ed., p 749-780, Wiley, N.Y. Schulte, H. F., 1957, The effects of subsidence on the strata immediately above a working, with different types of packing and in level measures: European Congress on Ground Movement, Leeds, April 1957, Proceedings, p 188-197, disc. 198. Voight, B., and W. Pariseau, 1970, State of predictive art in subsidence engineering: American Society of Civil Engineers Proceedings, Soil Mechanics and Foundations Division Journal, v 96, n 3, SM2, p 721-750. Wagner, H., and M.D.G. Salamon, 1972, Strata control techniques in shafts and large excavations: Association of Mine Managers of South Africa Papers and Discussions, v 1972-73, p 123-140.

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11.0

FIGURES

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Red Cliff Mine EIS

Figure 1 Red Cliff Mine Project and Coal Lease Areas

Red Cliff Mine EIS

Figure 2 Plan View of Three Adjacent Longwall Panels

Red Cliff Mine EIS

Figure 3 Estimated Gateroad Pillar Loads from Mining First Adjacent Panel

Red Cliff Mine EIS

Figure 4 Load Transfer Distance Data

Red Cliff Mine EIS

Figure 5 Estimated Gateroad Pillar Loads from Mining Second Adjacent Panel

Red Cliff Mine EIS

Figure 6 McClane Canyon Mine Workings

Red Cliff Mine EIS

Figure 7 Subsidence Predicted for Five Selected Panels, McClane Canyon Mine

Red Cliff Mine EIS

Figure 8 Subsidence Over Room-and-Pillar Workings after Pillar Failure

Red Cliff Mine EIS

Figure 9 Localized Mining Induced Slope Angle Changes

Red Cliff Mine EIS

Figure 10 Potential Collapse Heights Above Different Mine Opening Geometries

Red Cliff Mine EIS

Figure 11 Cumulative Percent of Chimney Collapse Height

Red Cliff Mine EIS

Source: Gray, Bruhn & Turka, 1977

Figure 12 Time Interval Between Mining and Surface Breached or Dropped

Red Cliff Mine EIS

Figure 13 Overburden and Outcrop Map for the Project Area

Red Cliff Mine EIS

Figure 14 Estimated Angle of Draw in Relation to Percent Sandstone and Limestone

Red Cliff Mine EIS

Figure 15 Cross Panel Compression Ridge in Alluvium, York Canyon Mine

Red Cliff Mine EIS

Figure 16 Cross Panel Tension Cracks in Alluvium, York Canyon Mine

Red Cliff Mine EIS

Figure 17 Ribside Tension Crack on Steep Slope York Canyon Mine

Red Cliff Mine EIS

Figure 18 Ribside Tension Cracks in Road Fill and Cliff Face, York Canyon Mine

Red Cliff Mine EIS

Figure 19 Maximum Vertical Subsidence (Smax) with Respect to Panel Width and Depth

Red Cliff Mine EIS

Figure 20 Tension Crack Over Starter Room, York Canyon Mine

Red Cliff Mine EIS

Figure 21 Subsidence Monitoring Program

APPENDIX A. RECOMMENDED LIMITS FOR SUBSIDENCE INDUCED STRAIN AND TILT Table A1. Acceptable Subsidence Damage References: (1) Wagner & Salamon, 1973; (2) Voight & Pariseau, 1970 Horizontal Strain ( ) __________ 1000 Vertical Strain ( ) __________ 1000 Tilt Tan ______ 0.0010 ( ) _______ 0.057o Comments and References _________________________ "tolerable level of strain likely to be on the order of"---for high speed hoisting (1) High continuous brick walls damaged (2) One-story brick mill building, wall cracking (2) Plaster cracking (qypsum) (2) Reinforced-concrete building frame damaged (2) Reinforced concrete curtain walls cracked (2) Steel frame, continuous simple steel frame distorted (2) 0.004 0.229o 0.573o 0.172o 0.011o 0.172o 0.573o to 1.146o Tilting limits for smoke stacks and towers (2) Rolling of trucks stacking goods (2) Cotton loom (2) Turbo-generator (2) Crane rails (2)

500-1000

500-1000

1000-2000

1000-2000

1000 2500-4000

1000 2500-4000

3000

3000

5000

5000

0.010 Machine operation limits: 0.003 0.0002 0.003 0.01 to 0.02

Floor drainage problems (2)

Table A2. Categories of Protection, Poland (Brauner, 1973) Category Allowable tilt 0.0025 (0.143o) 0.0050 (0.286o) 0.0100 (0.573o) Allowable strain 1500 Explanation

I

Slight damage allowable, such as hair hair cracks in plaster. Small reparable damage allowable.

II

3000

III

6000

Building damage severe, but does not does not destroy the building or impair its service. Movements so severe that reinforced structures are required to resist them.

IV

0.0150 (0.859o)

9000

Table A3. Tolerance of Structures to Differential Subsidence (Hutchings, et al,1978) DIFFERENTIAL SUBSIDENCE (Strain - %) STRUCTURAL SIGNIFICANCE

0.1% (1000 ) 0.1%-0.2% (1000-2000 ) 0.2%-0.4% (2000-4000 ) 0.7% (7000 ) 0.8% (8000 ) 2% (20000

Limiting value for high continuous brick walls and brick-clad column frames

Single story brick mill building, wall cracking

Limiting value for steel and reinforced concrete frames

Structural damage to buildings

Slight damage to 2-1/2 story brick veneer homes

Severe damage to 2-1/2 story brick veneer )

Table A4. Subsidence Damage Description for Horizontal Strain (British National Coal Board, 1975) Class of damage Change of length of structure Up to 0.1 ft Description of typical damage

Very slight or negligible Example: 50-ft long building extended Slight

Hair cracks in plaster. Perhaps isolated slight fracture in the building, not visible on outside. 50 u - in./in.

0.1 ft-0.2 ft

Example: 110-ft long building extended Appreciable 0.2 ft-0.4 ft

Several slight fractures showing inside the building. Doors and windows may stick slightly. Repairs to decoration probably necessary. 1,600 u - in./in. Slight fractures showing on outside of building (or one main fracture). Doors and windows sticking ; service pipes may fracture. 3,700 u - in./in. Service pipes disrupted. Open fractures requiring rebonding and allowing weather into the structure. Window and door frames distorted; floors sloping noticeably. Some loss of bearing in I-beams. If compressive damage, overlapping of roof joints and lifting of brickwork with open horizontal fractures. 2,300 u - in./in. As above, but worse, and requiring partial or complete rebuilding. Roof and floor beams lose bearing and walls lean badly and need shoring up. Windows broken with distortion. Severe slopes on floors. If compressive damage, severe buckling and bulging of the roofs and walls. 6,000 u - in./in.

Example: 90 ft long building extended Severe 0.4 ft-0.6 ft

Example: 220 ft 1ong apartment house compressed Very severe More than 0.6 ft

Example: 180 ft long apartment

Table A4. Subsidence Damage Description for Horizontal Strain (Cont.)

Table A5. Classication of Permissible Strain and Tilt (Ochab, 1961) POLISH MINISTRY FOR MINING AND POWER PERMISSIBLE HORIZONTAL TILT STRAIN (o) _______ ______ 0.142o TYPE OF STRUCTURE OR SERVICE

0.2% (2000 )

Gas mains which require particular protection against the danger of a gas explosion if damaged, also items such as water tanks and industrial installations recognized as being especially important or particularly susceptible to damage with regard to life and safety Industrial reinforced concrete buildings of monolithic construction or with gantry cranes, churches with domes and other big buildings for public use such as hospitals, theaters, etc, river beds and water reservoirs, provided the hydro-geological opinion is that the character of the ground does not require any increase or decrease of safety conditions, main railway lines and railway stations with a quantity of technical equipment, tunnels and arched bridges, main water pipes, also large residential buildings with a length of more than 20 m Main roads, railway tracks and small railway stations, girder bridges, industrial buildings of brick, steel and timber construction without cranes and which are not too susceptible to ground movements, cooling towers, high chimney stacks, water towers, churches with beam construction roofs, residential buildings with a length of 10 to 20 m, residential buildings more than 20 m long, but of a specially protected construction, main sewers and airfields

0.4% (4000 )

0.283o

0.6% (6000 )

0.567o

0.9% 0.858o Large sports stadiums, residential buildings up 10 m long, residential (9000 ) buildings 10 to 20 m long buildings of a specially protected construction and other items of small importance ________________________________________________________________________________

APPENDIX E C O O R D I N AT I O N A N D C O N S U LTAT I O N S

Notice of Intent

[Federal Register: July 27, 2006 (Volume 71, Number 144)] [Notices] [Page 42659-42660] From the Federal Register Online via GPO Access [wais.access.gpo.gov] [DOCID:fr27jy06-54] ----------------------------------------------------------------------DEPARTMENT OF THE INTERIOR Bureau of Land Management [CO-130; COC 69290]

Notice of Intent To Prepare an Environmental Impact Statement for the Proposed Red Cliff Coal Mine, Railroad Spur Line, and Other Associated Surface Facilities in Garfield County and Mesa County, CO AGENCY: Bureau of Land Management, Interior; U.S. Army Corps of Engineers, Army; Office of Surface Mining, Interior. ACTION: Notice of intent. ----------------------------------------------------------------------SUMMARY: Pursuant to Section 102(2)(c) of the National Environmental Policy Act of 1969 (NEPA) and the Federal Land Policy and Management Act of 1976, notice is hereby given that the Bureau of Land Management (BLM), Grand Junction Field Office located in Grand Junction, CO, will be directing the preparation of an Environmental Impact Statement (EIS) for the Proposed Red Cliff Coal Mine near Loma, Colorado, including Right-of-Way and Land Use Applications for facilities on Federal Lands, submitted by CAM-Colorado, LLC (CAM). The EIS will analyze the development of surface facilities for coal mining associated with CAM's proposed underground Red Cliff Mine, including roads, a water pipeline, coal stockpile and waste disposal areas, a coal preparation plant, the mine portal, other administrative and operations facilities, and a railroad spur line that would connect to the existing Union Pacific Railroad line near Mack, Colorado. Cooperating agencies include the U.S. Army Corps of Engineers, the Office of Surface Mining, the Colorado Department of Natural Resources, Mesa County, and Garfield County. The BLM invites the public to participate in the NEPA process. DATES: The scoping comment period will commence with the publication of this notice and terminate at 45 days. A public meeting will be held during the scoping comment period in Fruita, Colorado. Comments on the scope of the EIS, including concerns, issues, or proposed alternatives that should be considered, can be made at the public meeting or can be submitted in writing to the address below. The date of the public meeting will be announced through the local media, newsletters, and the BLM Red Cliff Mine mailing list. The Draft EIS is expected to be available for public review and comment in Spring 2007 and the Final EIS is expected to be available in late 2007. ADDRESSES: Written comments should be sent to: David Lehmann, BLM, 2815

H Road, Grand Junction, Colorado 81506. At the close of the scoping comment period, written comments, including names and addresses of respondents, will be available for public review at the offices of the BLM Grand Junction Field Office, 2815 H Road, Grand Junction, Colorado 81506, during normal working hours (7:30 a.m. to 4:30 p.m., except holidays). Submissions from organizations or businesses will be made available for public inspection in their entirety. Individuals may request confidentiality with respect to their name, address, and phone number. If you wish to have your name or street address withheld from public review, or from disclosure under the Freedom of Information Act, you must state this prominently at the beginning of your comment. Such requests will be honored to the extent allowed by law. Comment contents will not be kept confidential. The Draft EIS will consider comments and issues received during public scoping, and responses to comments on the Draft EIS will be published as part of the Final EIS. FOR FURTHER INFORMATION CONTACT: For further information or to have your name added to our mailing list, contact David Lehmann, Supervisory Natural Resource Specialist, at (970) 244-3021. E-mail can be directed to David_Lehmann@blm.gov and mail can be sent to the address above. SUPPLEMENTARY INFORMATION: On September 28, 2005, CAM filed a Right-ofWay application with BLM for facilities associated with the proposed Red Cliff Mine. Subsequently, on February 10, 2006, CAM submitted a Land Use Application to the BLM for other facilities supporting the proposed coal mine project. A mine permit will also be required for all mine facilities, in accordance with U. S. Office of Surface Mining and Colorado Division of Minerals and Geology regulations. This EIS will meet the National Environmental Policy Act requirements for the mine permit. There will be additional opportunities for public [[Page 42660]] involvement when the mine permit application is processed. The proposed Red Cliff Mine is located approximately 11 miles north of the towns of Mack and Loma, Colorado, and 1.5 miles east of Colorado State Highway 139. CAM is proposing a new portal and associated facilities to extract low-sulfur coal from Federal Coal Leases C0125515 and C-0125516 and from several potential new Federal leases as well as a small amount of private coal. The proposed railroad line would traverse approximately 9.5 miles of Federal land, and include one crossing of State Highway 139 and approximately 5 miles of private land. The EIS will analyze the potential impacts associated with the construction and operation of facilities proposed in CAM's Right-of-Way and Land Use Applications, and other potential impacts associated with the Red Cliff Mine project. Citizens are invited to help identify issues or concerns and to provide input on the proposed action. Alternatives will be developed through the public involvement process and analyzed in the EIS. A company affiliated with CAM is currently mining approximately 280,000 tons of coal per year from the nearby McClane Canyon Mine. CAM's production from the Red Cliff Mine would be approximately 8 million tons per year. CAM is proposing to load the coal onto rail cars at the mine site and ship it to coal consumers. CAM would recover this coal by mining the Cameo Seam using both room and pillar and longwall mining techniques. As is consistent with the goals of the 2001 National Energy Policy report and the Energy Policy Act of 2005, this project

would help meet the existing and future domestic market demand for lowsulfur coal, thereby supporting clean coal initiatives; and would encourage and facilitate meeting national demands for electricity from a domestic source of energy. The BLM will analyze the potential impacts of the proposed action and no action alternatives, as well as other reasonable alternatives that could include optional approaches for activities proposed in the project area. The alternatives will be further defined as part of the scoping and planning process. Consultation with tribal governments will be accomplished as part of the planning process. Section 106 consultations with the Colorado State Historic Preservation Officer will be conducted as required by the National Historic Preservation Act. U. S. Fish and Wildlife Service Section 7 consultations will be conducted as required by the Endangered Species Act. BLM will consult with the U.S. Army Corps of Engineers as required by the Clean Water Act. Dated: June 5, 2006. Catherine Robertson, Field Manager. [FR Doc. E6-12010 Filed 7-26-06; 8:45 am] BILLING CODE 4310-JB-P

ESA Consultation

CAM–Colorado, LLC Red Cliff Mine Biological Assessment Garfield and Mesa Counties, Colorado

Razorback Sucker

Prepared by: WestWater Engineering 2516 Foresight Circle #1 Grand Junction, CO 81505

September 2008

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1.0 INTRODUCTION This Biological Assessment (BA) was prepared at the request of the Bureau of Land Management (BLM), Grand Junction Field Office (GJFO), for submittal to the U.S. Fish and Wildlife Service (USFWS), Western Colorado Ecological Services Field Office, Grand Junction, Colorado. The purpose of this BA is to review the proposed CAM–Colorado, LLC (CAM) Red Cliff coal mine proposal in sufficient detail to determine potential effects to Endangered Species Act (ESA) listed species. Section 7(a)(2) of the ESA of 1973 (USFWS 1973) (as amended) requires Federal agencies to consult with the USFWS to ensure that any action the agency authorizes, funds, or implements is not likely to jeopardize the continued existence of a listed species, threaten a species or result in the destruction or adverse modification of habitat. This BA is intended to fulfill the consultation requirements of Section 7(a)(2) associated with the approval of the requested BLM right of way (ROW). 2.0 PROPOSED ACTION 2.1 Location of the Red Cliff Mine The proposed Red Cliff Mine project area is located in west-central Colorado approximately 11 miles north of the towns of Mack and Loma, Colorado, and 1.5 miles east of Colorado State Highway (SH) 139 (Figure 1). This location was selected based on location and quality of coal outcrop, access issues, and the need to be within CAM’s existing coal leases. The Proposed Action consists of a new underground coal mine including the construction of mine portals and associated processing facilities in Section 3, Township 8 South, Range 102 West (T8S, R102W). Coal would be transported from the mine site to the existing Union Pacific Railroad (UPRR) Grand Valley rail line, via a new spur line that will be constructed beginning near Mack, Colorado, to the mine site. 2.2 Purpose The purpose of this project is to mine, transport, and offer coal for sale to help supply the energy needs of the United States. CAM proposes to utilize public and private lands to mine the coal and transport it to market. Underground mining would be conducted 24 hours per day, 7 days per week, and 365 days per year by room and pillar and longwall mining techniques. CAM’s production from the Red Cliff Mine would be up to 8 million tons per year of clean coal, with an estimated life of the mine of 30 years. CAM is proposing to load the coal onto rail cars at the mine site and ship it to coal consumers via the UPRR.

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CAM is proposing to construct new mine entries (portals) and associated facilities to extract lowsulfur coal from existing Federal Coal Leases C 0125515, C 0125516, and C 0125439 (defined collectively as logical mining unit COC-57198); potential new federal coal leases; and a small amount of private coal. In addition to locating facilities on the existing and potential new coal leases, CAM would locate surface facilities on approximately 1,140 acres of BLM lands. These facilities would include the waste rock pile, railroad loop, the unit train loadout, and a conveyor system to move the coal and waste rock. Mesa County Road (CR) X (also known as Mitchell Road or Power Line Road) would be upgraded to serve as the mine access road from SH 139. Other facility components are listed below. 2.3 Construction Timing The time of year that construction would commence depends upon obtaining BLM land use and ROW permits, along with other state and federal permits. Construction was broken down into two phases. Phase I (heavy earthwork) is estimated to take approximately six months; Phase II structure and installation) would require nine months, for an estimated total construction time of 12 to 15 months. 2.4 Facilities 2.4.1 Description Proposed facilities associated with the mine include: Portal conveyor transfer buildings Fuel oil storage/fueling stations Electrical transformers Bathhouse/office building/parking lot Outdoor material storage areas Equipment shop Warehouse Washbay Covered storage Sewage treatment plant Water tank Water treatment building Mine vent fan 2.4.2 Surface Facilities-Mine Site A number of surface facilities are proposed to support the mining operation including, but not limited to, a ventilation fan, office, shop, package sewage treatment plant, and raw coal stockpile. These facilities would be located on the existing and proposed coal leases. It is also proposed to locate surface facilities on non-leased BLM-managed lands for which a land-use permit will be required. CAM submitted a Land Use Application and Permit dated February 10, 2006, to BLM for facilities to be located on BLM-managed lands. Surface facilities associated with the mine are described below. Dimensions and other details may change during final design. Power line Non-coal waste storage Rock dust storage Pump house Conveyor transfer buildings Railroad Maintenance Road Water pipeline and diversion Coal storage piles Unit train loadout Coal preparation plant Mine access roads

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Coal Preparation Plant – The coal preparation plant would be a structural steel building where coal and rock are separated with heavy media circuits. The structure would be approximately 55 feet by 70 feet by 80 feet high. Facilities associated with the coal preparation plant include a thickener and motor control center. Motor Control Center – The motor control center room would be approximately 10 feet by 12 feet by 12 feet high. Thickener – The thickener would be a concrete structure where water is cleaned and returned to the preparation plant. The tank would be approximately 70 feet in diameter and 10 feet high. The reinforced concrete walls and floor would be approximately 10 inches thick. Conveyors – There would be fourteen separate conveyors associated with the mine. Conveyors would transport raw coal, waste rock, and clean coal throughout the facility. Conveyor Transfer Buildings – Conveyor transfer buildings are structural steel buildings where the beltline from the raw coal stockpile has angle points and, therefore, needs to change direction. o The portal conveyor transfer building would be a structural steel building where the main conveyor belt from the mine terminates. The coal from the mine will transfer to the stockpile conveyor. Waste rock conveyed from the mine will be transferred to the waste rock belt. The dimensions of the building would be approximately 22 feet by 26 feet by 45 feet high. o There would be four transfer buildings between the raw coal stockpile and the coal preparation plant. The dimensions of these buildings would be approximately 16 feet by 16 feet by 25 feet high. o There would be two additional transfer buildings near the preparation plant for clean coal and for waste rock. Raw Coal Stockpile – The raw coal stockpile would contain up to 300,000 tons of raw coal and would cover an area of 3.1 acres, including the stacking tubes. Stacking Tubes – The raw coal would be stacked by up to three concrete tubes each to minimize coal segregation and air particulate emissions. The tubes would be approximately 100 feet high and 12 feet in diameter. Reclaim Tunnel – A reclaim tunnel would be located under the stacking tubes and raw coal stockpile. It would be constructed of reinforced concrete. The inside dimensions of the tunnel would be approximately 13 feet high by 12 feet wide by approximately 430 feet long. A 42-inch diameter escape tube would be located on the northeast end of the tunnel. The 150-foot-long escape tube would terminate at a concrete fan housing that would be approximately 6 feet by 6 feet by 8 feet high. Washbay – The washbay would be a pre-engineered metal building used to clean equipment. The building would be approximately 50 feet by 25 feet with 24-foot eave heights. Unit Train Loadout – The disturbance associated with the unit train loadout would be located southwest of the mine on a private rail spur. Facilities associated with the unit train loadout would include the rail, access road, batch weigh system and conveyor. The loadout facilities would cover approximately 10.2 acres.

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Loadout Structure/Batch Weigh System – The loadout structure would consist of a structural steel building where the loadout conveyor terminates. The coal would be batch weighed and loaded into rail cars at this location. The dimensions of the building are approximately 30 feet by 40 feet by 120 feet high. Water Tank – A water tank would be a fabricated steel tank constructed on an oiled sand base. The tank would be approximately 52 feet in diameter and 32 feet high with a capacity of approximately 500,000 gallons. Water Treatment Building – The water treatment building would be located near the water tank. It would be approximately 14 feet by 20 feet with a 12-foot eave height. Sewage Treatment Plant – The package sewage treatment plant would utilize settling tanks, chlorine treatment, and an active aeration system. Any sludge generated would be hauled off-site and disposed of in accordance with local and state ordinances. Treated water would be discharged to a sedimentation pond and eventually into ephemeral surface drainage near the mine site. The building would be approximately 30 feet by 30 feet with a 10-foot eave height. Shop – The shop would be a pre-engineered metal building to store supplies and to repair and fabricate equipment. The building would be approximately 100 feet by 50 feet with a 24-foot eave height. Bath House/Office – The bath house and office would be a two story pre-engineered metal building of approximately 150 feet by 50 feet with a 24-foot eave height. There would be a paved parking area for employees and visitors at the office encompassing 0.8 acres. Retaining Wall – The 8-foot-high retaining wall would be approximately 850 feet long. This retaining wall would elevate the immediate portal area above the general portal level and provide a landing area for rock fall. Refuse Bin – The refuse (waste rock) bin would be utilized to hold surges in refuse production from the coal preparation plant and will load waste rock haul trucks. The refuse bin would be constructed of structural steel and is approximately 20 feet by 20 feet by 60 feet high. Rock Bins – Rock bins would be located at the mine portal. The bins would consist of a concrete base of 20 feet by 30 feet and back wall and separation walls are 90 feet long and 8 feet high. Mine Vent Fan – A mine ventilation fan and steel duct work would be located at the return entry of the mine portal. The ventilation fan would be approximately 8 feet in diameter. Substation – A gravel-surfaced fenced area located near the preparation plant would contain the substation for the mine facilities. The outside dimensions of the facility are 100 feet by 120 feet. The substation would contain transformers to reduce the primary line power to a suitable voltage. Power Line – A high-voltage overhead power line would extend from the substation to the preparation plant and portal level. Warehouse – The warehouse would be a pre-engineered metal building for materials storage. This building would be approximately 50 feet by 60 feet with a 24-foot eave height.

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Material Storage – Open areas would be reserved to store materials. Materials to be stored include roof bolts, roof pans, timbers, caps, wedges, hoses, pipe, pipe supplies, electrical equipment, electrical cable, electrical supplies, conveyor belt, conveyor components, motors, gear boxes, mine equipment, mine equipment components, surface equipment, surface equipment components, and rock dust. The material storage areas would cover about 1.6 acres. Covered Storage – Two three-sided, pre-engineered metal buildings would be used for storage. One would be approximately 30 feet by 80 feet with a 20-foot eave height and the other would be 30 feet by 100 feet with a 20-foot eave height. Non-Coal Waste Storage – Non-coal waste would be stored at various locations within the disturbance area in commercially available dumpsters. Rock Dust Storage Area – The rock dust would be contained in a silo approximately 50 feet high and 8 feet in diameter. The cinderblock building under the silo would contain a rock dust pod and a distribution compressor approximately 30 feet by 20 feet by 8 feet. Fuel Oil Storage/Fueling Station – The fueling station would be a concrete and steel structure containing gas, fuel and oil. The structure would be approximately 20 feet by 30 feet long. The facility would contain 10,000 gallon diesel tank, a 500 gallon DOT diesel tank, a 10,000 gallon hydraulic oil tank, a 500-gallon antifreeze tank, a 2,000-gallon gear oil tank, a 2,500-gallon gas tank and a 1,000-gallon motor oil tank. The containment area would be constructed of 6-inch-thick, 4-foot-high walls. Waste Rock Pile – A waste rock pile would be constructed southwest of the mine portals. The disturbance associated with the waste rock pile would include clearing the area necessary to form the boundary of the pile. Facilities associated with the waste rock pile include a topsoil stockpile, cover fill stockpile, conveyor, haul road, and a sediment pond. Temporary Waste Rock Pile – Waste rock would be periodically transported from the underground workings on the mine conveyors. At the portal transfer building, waste rock would be transferred to the waste rock conveyor. The waste rock would be stacked in a temporary waste rock pile located near the transfer building. The waste rock would then be transported to the permanent waste rock disposal area. Up to 1,500 tons may be stored in the temporary waste rock pile at one time. Sediment Ponds – There would be eight sediment ponds constructed for the mine facilities named sediment ponds A through H. The sediment ponds would be capable of containing the run-off from a 10-year event with a spillway system designed to handle the peak flow generated by a 25-year storm event. Dewatering of the sediment ponds would be by either a centrifugal pump or a primary spillway pipe with a normally closed valve. The water would flow into ephemeral drainages adjacent to the ponds. Dewatering would take place only when the run-off was greater than the ability of the ponds to hold the water until it evaporated and percolated into the soil. 2.4.3 Coal Operations The coal would be transported from within the mine via a portal conveyor. The portal conveyor is an extension of the conveyor from within the mine. It would be 72-inches wide and extend from the portal to the portal transfer building. A 48-inch-wide non-coal waste rock belt would convey waste rock from the portal transfer building to a temporary waste rock pile. A 72-inchWestWater Engineering
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wide stockpile conveyor would then transfer coal from the portal transfer tower to the stacking tube and raw coal stockpile. A reclaim conveyor would transfer coal from the coal stockpile to the coal preparation plant. A 48-inch-wide clean coal belt would deliver the coal to the stacking tubes and clean coal loadout stockpile. A 72-inch-wide loadout belt would feed coal to the unit train loadout. A 48-inch-wide waste rock belt would send waste rock to the waste rock bin and waste rock pile. Coal would be stored in one of two open stockpiles: run-of-mine or clean coal. There will be two potential streams of coal that will make up the clean coal pile. They are coal that has been washed through the preparation plant and raw coal that has bypassed the preparation plant. Up to 300,000 tons of mixed coal and rock would be stored in the run-of-mine pile; located within the coal lease boundary. The clean coal stockpile would be located near the unit train loadout. Up to 350,000 tons of coal would be stored in the clean coal stockpile. Stacking tubes would also be used to transfer coal into stockpiles, to minimize coal size segregation and air particulate emissions. Stacking tubes would be 80 to 100 feet high and 10 to 12 feet in diameter. They have numerous, evenly spaced 4-foot-square openings to allow coal to flow from the tube to the stockpiles. 2.4.4 Railroad Spur Significant mining of these coal reserves has not occurred because of the remote location and difficulties and cost to transport the coal to market. A key element of the proposal is the railroad spur from the Red Cliff Mine to the railroad main line near Mack, Colorado. The railroad would be located on BLM and private lands, with the railroad connecting to the existing UPRR near Mack, Colorado. The proposed railroad would traverse approximately 9.5 miles of BLM land, including one crossing of SH 139 and approximately 5 miles of private land. The proposed railroad would also cross Mesa CR M.8, CR 10, and CR T. Coal will be loaded onto rail cars at the mine site and transported via the rail spur to the main rail line connection. A ―wye‖ (a triangular shaped arrangement of railway tracks with a switch point at each corner) would be constructed to link the railroad spur with the main line at Mack to allow uninterrupted train flow in all directions. Loaded coal trains from the spur line would enter the main line and proceed to carry coal to the specified destination. The loadout would be comprised of a coal stockpile, reclaim tunnel, conveyor belt(s), and loadout tower. Ethylene glycol would be applied to the coal and coal cars to minimize freezing during winter months. These products are stored in sealed 500 gallon tanks located near the loadout structure. There would be an average of four trains per day (two full and two empty) at a maximum production rate of 8,000,000 tpy, traveling at a speed of approximately 20 miles per hour (mph) full and 25 mph empty. Each car would carry approximately 100 to 110 tons of coal and would typically consist of between 100 and 120 cars, with three, four, or five locomotives. Trains would typically be 6,500 to 7,700 feet in length. Construction of the railroad spur would require construction of bridges. One bridge would cross Mack Wash and would be supported by concrete-capped piles with a center support in Mack Wash. Another bridge would be constructed over the Highline Canal, also supported by concrete-capped piles. WestWater Engineering
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2.4.5 Auxiliary Facilities The mine operations would require water, electricity, and access roads. These auxiliary facilities are discussed in this section. 2.4.5.1 Water Line Adequate water resources for operations are not available at the Red Cliff Mine site, so water must be piped to the mining operation. CAM has a 3.0 cubic foot per second (cfs) absolute water right on Mack Wash, near Mack (Case No. 03CW228). A portion of those waters, totaling approximately 724 acre–feet per year (approximately 1 cfs), would be piped to the Red Cliff Mine site for use during mining operations. Due to the nature and location of CAM’s water rights, the point of diversion must be on Mack Wash below (downstream of) more senior water rights. There are no feasible alternatives to diverting the water from Mack Wash at other upstream sites. A water diversion structure would be constructed in-channel on the west bank of Mack Wash, just north of the CR M.8 Bridge (Figure 1) on CAM-owned land. The pump and waterline system would have a maximum capacity of approximately 750 gallons per minute (gpm). The diversion/pump would be connected to a meter and water pipeline. The pipeline would be constructed of steel and polyvinyl chloride (PVC) and would be buried along the railroad spur alignment. It would extend to a water tank above the mine portals. This pipeline would supply all of the water needs for the mine operation and would be pumping water, more or less, continuously throughout the year. The system would remain in operation for the life of the mine. Best Management practices (BMPs) would be utilized during construction to minimize impacts to in-channel and riparian habitat and to prevent bank degradation. CAM will obtain a permit from the United State Army Corps of Engineers (USACE) prior to constructing the diversion structure in Mack Wash. Approximately nine roads to the mine sites would provide access for a variety of uses. The roads would be plated with gravel surfacing or would be paved. To control fugitive emissions, roads would be watered using water from the water pipeline and cleaned as necessary. Dust suppression would be used on heavily traveled roads to control air pollution. Roads would be constructed and maintained in accordance with Mesa County, BLM, and Mine Safety and Health Administration (MSHA) standards, as applicable and appropriate. 2.4.5.2 Electric Power Electric power is needed at the mine to run the underground mining machinery, the conveyor system, and the other mine support facilities. CAM would contract with Grand Valley Power (GVP), the local utility, to supply the necessary electric power. GVP would need to construct a new 69-kilovolt (kV) transmission line from the Uintah Substation to the mine to supply this power. The transmission line would be approximately 14 miles long, with approximately 7 miles on federally managed lands and 7 miles on private land. 3.0 CONSULTATION HISTORY Informal consultation with USFWS representatives concerning this project has included: July 9, 2008 – WestWater Engineering, Inc. (WWE), personal communications with USFWS Ecological Services, Western Colorado Field Office, Biologist Rick Kruger regarding inclusion WestWater Engineering
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of black-footed ferret in the BA analysis. He said that due to the presence of white-tailed prairie dog populations and the potential for ferrets to occur, a May Affect, Not Likely to Adversely Affect is likely warranted. July 17, 2008 – WWE (Klish and Graham) discussed species to be addressed in the BA with USFWS biologist Collin Ewing. Affects to Colorado River endangered fish would include depletions and USFWS wanted clarification of potential effects to water quality. July 30, 2008 - WWE discussed (with Collin Ewing) combining redundant Colorado River endangered fish management information regarding water depletions and hazardous-materials into one section rather than repeat the same information four times. Further discussions occurred regarding water discharges from the mine site and affects to waters in Mack Wash. August 14, 2008 - WWE phone conversation with Patty Gelatt (USFWS, Grand Junction) regarding Colorado River endangered fish status and occurrence in the Colorado River at the confluence of Salt Creek with the Colorado River. 4.0 SPECIES CONSIDERED AND SPECIES EVALUATED Based on the USFWS list of Threatened and Endangered Species for Garfield and Mesa Counties, Colorado (USFWS 2006) and consultation with the Grand Junction BLM and USFWS, the following species, which may be impacted by the project, were evaluated for consideration for inclusion in the BA. razorback sucker (Xyrauchen texanus), Colorado pikeminnow (Ptychocheilus lucius), humpback chub (Gila cypha), bonytail (Gila elegans), Black-footed ferret (Mustela nigripes) Colorado hookless cactus (Sclerocactus glaucus) DeBeque phacelia (Phacelia scopulina var. submutica) Bald Eagle Haliaeetus leucocephalus) Only those species with identified habitat, potential habitat or critical habitat within the proposed project area, or habitat that could be affected by the project were analyzed in this BA. All of the species considered in the BA have identified habitat, potential habitat or critical habitat within the proposed project area, or habitat that could be affected by the project. These are listed in Table 1 along with their species status under the ESA. For purposes of this BA, the four fish species are collectively referred to as the ―Colorado River endangered fishes.‖

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Table 1. Species Evaluated in the CAM project BA Common Name Scientific Name ESA Status ESA Endangered, Candidate, Sensitive Species for Consultation
COLORADO RIVER ENDANGERED FISHES Razorback sucker Xyrauchen texanus Endangered Colorado pikeminnow Ptychocheilus lucius Endangered Humpback chub Gila cypha Endangered Bonytail Gila elegans Endangered MAMMALS Black-footed ferret Mustela nigripes Endangered PLANTS Colorado hookless cactus Sclerocactus glaucus Threatened Phacelia scolelina spp. Debeque phacelia submutica Candidate

Colorado hookless cactus and DeBeque phacelia were not analyzed in detail based on the results of biological surveys for the hookless cactus and phacelia (described below). Bald eagle was not analyzed because of the removal of Bald Eagle from the USFWS threatened list in 2007. 4.1 Colorado Hookless Cactus Colorado hookless cactus has been found at a few locations in the Grand Valley (Spackman et al. 1997), but not within the proposed project area. The cactus is usually found on rocky hills, mesa slopes, and alluvial benches in desert shrub communities, but can be found in other habitats. Surveys of the project area by WWE and Cedar Creek Associates did not locate any individuals or populations of this species (WWE 2006; Cedar Creek 2006). Therefore, the project would have no effect on Colorado hookless cactus. 4.2 DeBeque Phacelia This plant is a candidate for listing under the ESA and is also considered to be a BLM sensitive species. DeBeque phacelia grows only in Garfield and Mesa Counties within the Piceance Basin in western Colorado (Spackman et al. 1997). The species’ total range is less than 300 square miles. To date, no individuals or populations of this plant have been reported in the Grand Valley or the proposed project area. Surveys of the project area by WWE and Cedar Creek Associates did not locate any individual or population of this species (WWE 2006; Cedar Creek 2006). The project would have no effect on DeBeque phacelia.

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5.0 AFFECTED ENVIRONMENT (BASELINE) The project area is planned for development in a cold desert, saltbush/sagebrush shrublands landscape north of the Colorado River corridor. The terrain is gently rolling hills, bisected by numerous small washes and two larger drainages. The mine site is to be constructed in currently undeveloped piñon-juniper and shrubland habitat located at the base of the Book Cliffs. A portion of the project, including a railroad spur line and a water pipeline, lies below the Highline Canal on private lands. The natural shrub vegetation in this area has largely been altered due to agricultural production including the development of an extensive irrigation system. However, the majority of the spur rail line is designed to avoid irrigated farm lands and is situated in upland areas that still support native saltbush vegetation. The segment of the rail line above the Highline Canal would be constructed in native, saltbush shrublands. The vegetation within the general project area can generally be categorized into ten vegetation associations/plant communities: saltbush, sagebrush, greasewood, mesic mountain shrub, piñonjuniper, riparian, Douglas-fir, aspen, grass dominated, and disturbed rangeland communities. However, the project area (mine facilities area and railroad corridor) is comprised of four dominant and reasonably distinct habitat community types: agricultural, salt desert shrub, sagebrush and juniper woodlands. Above the Highline Canal, the project crosses and impacts ephemeral washes that drain into Mack Wash and East Salt Creek. Below the Highline Canal, irrigation seepage and return flows from field irrigation provide permanent flows in most large natural drainages and in small field collection drains. Riparian and wetland vegetation is encountered where there is sufficient water to support this vegetation. Water potentially affected by the project flows into either East Salt Creek or Mack Wash. Mack Wash joins East Salt Creek south of Mack and the combined drainages flow into the Colorado River at a site locally known as Crow Bottom at the upper end of Ruby Canyon. The USACE Jurisdictional Determination (JD) concluded that no potentially jurisdictional Waters of the United States were present in the project area north of the Highline Canal. South of the Highline Canal, several wetlands and one Relatively Permanent Water (RPW) were identified. Identified wetlands are related directly to application of irrigation water on agricultural lands, and on the basis of March 2007 USACE Regulatory Branch Memorandum 2007-1 (USACE 2007) were considered to be non-jurisdictional. The only jurisdictional wetland in the project area is 0.7 acres along the RPW, Mack Wash. The jurisdictional Waters of the United States (WOUS) includes 0.6 acres of non-wetland (Mack Wash flow path) and 0.1 acres of adjacent fringe wetland. Approximately 16.1 acres of delineated wetlands were considered to be non-jurisdictional because they are related to irrigation water application and return flows. Of this, approximately 11.5 aces are emergent wetland marshes, 3.1 acres are fringe wetland along irrigation ditches, and 1.5 acres are emergent marsh that no longer has wetland hydrology. All of these wetlands exist on private lands located south of the Highline Canal along the rail spur alignment.

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6.0 COLORADO RIVER ENDANGERED FISHES 6.1 Species Descriptions 6.1.1 Colorado Pikeminnow Description: The Colorado pikeminnow, formerly known as the Colorado squawfish, is the largest North American minnow. These fish have been known to reach six feet in length and 80 pounds in weight. Adult fish may be green-gray to bronze on their backs and silver to white along their sides and bottoms. During spawning, their fins can take on an orange hue. Range: Historically, the pikeminnow occurred in great numbers throughout the Colorado River system from Green River in Wyoming to the Gulf of California in Mexico. In Colorado, they are currently found in the Green, Yampa, White, Colorado, Gunnison, San Juan, and Dolores Rivers. Habitat: The Colorado pikeminnow thrives in swift flowing muddy rivers with quiet, warm backwaters. Colorado pikeminnow live in warm-water reaches of the Colorado River mainstem and larger tributaries, and require uninterrupted stream passage for spawning migrations and dispersal of young. The species is adapted to a hydrologic cycle characterized by large spring peaks of snowmelt runoff and low, relatively stable base flows. The Colorado pikeminnow is an obligate warm-water species that requires relatively warm temperatures for spawning, egg incubation, and survival of young. Critical Habitat: Designated critical habitat for the Colorado River pikeminnow in Colorado extends in its 100-year floodplain from the Colorado River Bridge at exit 90 (Rifle town exit) north off Interstate 70 (T6S, R93W, section 16 (6th Principal Meridian) to the Colorado-Utah state line. Other critical habitats are designated in portions of the Colorado River in Utah, downstream from the Colorado-Utah state line. . The primary constituent elements used to define critical habitat for the Colorado River pikeminnow are water, physical habitat, and biological environment. Diet: Colorado pikeminnow are primarily piscivorous (fish-eaters), but smaller individuals also eat insects and other invertebrates. Reproduction: The species spawns during the spring and summer over riffle areas with gravel or cobble substrate. Eggs are randomly splayed onto the bottom and usually hatch in less than one week. 6.1.2 Razorback Sucker Description: The razorback sucker is a large, bronze to yellow fish that grows to a weight of about 15 pounds and has a sharp-edged keel behind the head. Breeding males turn gray-black with a bright orange belly. Range: The razorback is most often found in quiet, muddy backwaters along the Colorado River. The razorback sucker was once widespread throughout most of the Colorado River Basin from Wyoming to Mexico. In the upper Colorado River Basin, they are now found only in the upper Green River in Utah, the lower Yampa River in Colorado and occasionally in the Colorado River near Grand Junction (USFWS 2008a). Small numbers of razorback suckers also have been found in Lake Powell at the mouths of the Dirty Devil, San Juan and Colorado rivers.

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Habitat: Razorbacks are found in deep, clear to turbid waters of large rivers and some reservoirs over mud, sand or gravel. In the upper Colorado River, near Grand Junction, Colorado, Osmundson and Kaeding (1989) reported habitat use in pools and slow eddies from November through April; runs and pools from July through October; runs and backwaters during May; and backwaters, eddies, and flooded gravel pits during June. Selection of depths changed seasonally; use of relatively shallow water occurs during spring and use of deeper water during winter. Critical Habitat: Designated critical habitat for the razorback sucker in Colorado extends in its 100-year floodplain from the Colorado River Bridge at exit 90 (Rifle town exit) north off Interstate 70 (T6S, R93W, section 16 (6th Principal Meridian) to the Colorado-Utah state line. Other critical habitats are designated in portions of the Colorado River in Utah, downstream from the Colorado-Utah state line. . The primary constituent elements used to define critical habitat for the razorback sucker are water, physical habitat, and biological environment. Diet: Like most suckers, the razorback feeds on both plant and animal matter. Reproduction: The razorback sucker spawns in the spring. Breeding males turn black up to the lateral line, with brilliant orange extending across the belly. 6.1.3 Humpback Chub Description: The humpback chub is a member of the minnow family that is green to silver and white with an abrupt hump behind the head. They grow to about 18 inches in length. Range: The historic range of the humpback is similar to the pikeminnow, occurring in great numbers throughout the Colorado River system from Green River in Wyoming to the Gulf of California in Mexico. Today, they can be found in deep, canyon-bound portions of the Colorado River system, such as Black Rocks and Westwater Canyons on the Colorado River and Yampa Canyon inside Dinosaur National Monument. Habitat: The humpback prefers deep, fast-moving, turbid waters often associated with large boulders and steep cliffs. Critical Habitat: Designated critical habitat for the humpback chub in Colorado extends in its 100-year flood plain from Black Rocks to the Colorado-Utah state line. Other critical habitats are designated in portions of the Colorado River in Utah, downstream from the Colorado-Utah state line. . The primary constituent elements used to define critical habitat for the humpback chub are water, physical habitat, and biological environment. Diet: Humpback chubs feed predominately on small aquatic insects, diatoms and filamentous algae. Reproduction: Spawning occurs between April and July during high flows from snowmelt. During breeding, males develop red tinges on the venter and cheeks. 6.1.4 Bonytail Description: This large chub is also a member of the minnow family. It’s similar to the humpback chub, but it has only a slight hump behind the head and a long, narrow tail. Adults are dark on top and light below. They are very dark in clear waters and pale in turbid waters. WestWater Engineering
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Bonytails can reach 24 inches in length. They have green-gray backs with lighter sides and white bellies. During breeding, males turn red-orange on the belly and paired fins. Their fins are large, slightly falcate. Dorsal fins typically have 10 rays; tail fins have 10 to 11 rays. ―Bonytail‖ is the accepted common name for Gila elegans. The synonym ―Bonytail chub‖ was used when the species was listed in 1980 and is an often-used common name. Range: Historically, bonytail were present in the Colorado River system, which includes the Yampa, Green, Colorado and Gunnison rivers. Today, there are no known populations in Colorado. They can be found in the Green River drainage in Utah and Mohave Reservoir on the Arizona-Nevada border. Habitat: This fish typically lives in large, fast-flowing waterways of the Colorado River system. But their distribution and habitat status are largely unknown due to its rapid decline prior to research into its natural history. Critical Habitat: Designated critical habitat for the bonytail in Colorado extends in its 100-year flood plain from Black Rocks to the Colorado-Utah state line. Other critical habitats are designated in portions of the Colorado River in Utah, downstream from the Colorado-Utah state line. The primary constituent elements used to define critical habitat for the bonytail are water, physical habitat, and biological environment. Diet: Adult bonytail feed on terrestrial insects, zooplankton, algae and plant debris. Young feed mainly on aquatic insects. Breeding: Although bonytail spawning in the wild is now rare, the species does spawn in the spring and summer over gravel substrate. Many bonytail are now produced in fish hatcheries, with the offspring released into the wild when they are large enough to survive in the altered Colorado River system environment. Females produce between 1,000 and 17,000 eggs. Hatching occurs about nine hours after fertilization and swim-up begins generally 48 to 120 hours later. Survival rate of young fish is about 17 to 38 percent. 6.2 USFWS Management Since publishing of the four Colorado River Endangered Fish Recovery Plans in 1991, the USFWS has pursued reasonable actions that were presented in the plan and followed subsequent supplements and amendments to the recovery plan. The following references are from the four Recovery Goals documents (USFWS 2002a-d) that address potential affects that may result from project effects including Colorado River water depletions and hazardous material spills. 6.2.1 Recovery Goals: Management Actions Needed The USFWS has developed recovery goals for the Colorado River endangered fishes and uses site-specific management actions to aid in the recovery of the Colorado River endangered fish. The following management actions are included in the 2002 plans and applicable to the proposed action: Provide and legally protect habitat (including flow regimes necessary to restore and maintain required environmental conditions) necessary to provide adequate habitat and sufficient range for all life stages to support recovered populations (Listing Factor A). WestWater Engineering
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Minimize the risk of hazardous-materials spills in critical habitat (Listing Factor E).
The principles of recovery and conservation of a species including implementing regulations and USFWS policy demonstrate a strong relationship between the delisting criteria used for recovery and the five listing factors contained in the ESA. The following two of listing factors (A and E) are applicable to the Red Cliff Mine.

Listing Factor A: The Present or Threatened Destruction, Modification, or Curtailment of Its Habitat or Range (from Colorado River Endangered Fishes Goals 2002a-d: synopsis of sections) Streamflow regulation and associated habitat modification are identified as primary threats to Colorado River endangered fish populations. Regulation of streamflows in the Colorado River Basin is manifested as changes in flow patterns, sediment loads, and water temperatures. Flow recommendations have been developed that specifically consider flow-habitat relationships within occupied habitat of Colorado River endangered fish in the upper Colorado River. These flow recommendations will be evaluated and revised (as necessary) as part of an adaptive-management process, and flow regimes to benefit the endangered fishes will be implemented through multi-party agreements or by other means. Listing Factor E: Other Natural or Manmade Factors Affecting Its Continued Existence Pesticides and Pollutants (Hazardous-materials Spills used in mining and transportation of coal) Hazardous-materials spills are identified as a threat to Colorado River endangered fish. Pesticides find their way to the Colorado River from agricultural runoff, and other pollutants in the system include petroleum products, heavy metals (e.g., mercury, lead, zinc, copper), nonmetals (i.e., selenium), and radionuclides. Potential spills of petroleum products threaten wild populations of Colorado River endangered fish.
Management actions are directed at development of State and Federal hazardous-materials spills emergency-response plans to ensure adequate protection for Colorado River endangered fish populations from hazardous-materials spills, including prevention and quick response to hazardous-materials spills.

6.2.2 Recovery Goals: Site-Specific Management Actions and Tasks by Recovery Factor (applicable to upper Colorado River) Factor A: Adequate habitat and range for recovered populations provided
Management Action A-1.—Provide flows necessary for all life stages of Colorado River endangered fish to support recovered populations, based on demographic criteria. This section addresses potential critical habitat water depletions resulting from CAM’s use of 724 acre-feet per year of Mark Wash water, which directly affects flows in the Colorado River. Task A-1.1.—Identify, implement, evaluate, and revise flow regimes to benefit Colorado River endangered fishes in the upper Colorado River.

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Task A-1.2.—Provide flow regimes that are necessary for all life stages of Colorado River endangered fishes to support recovered populations in the upper Colorado River subbasin.

Factor E: Minimize the risk of hazardous-materials spills in critical habitat. Management Action E-2.—Minimize the risk of hazardous-materials spills in critical habitat. Task E-1.1.—Review and recommend modifications to State and Federal hazardousmaterials spills emergency-response plans to ensure adequate protection for Colorado River endangered fish populations from hazardous-materials spills, including prevention and quick response to hazardous-materials spills. Task E-1.2.—Implement State and Federal emergency-response plans that contain the necessary preventive measures for hazardous-materials spills. 6.2.3 Project Area Conditions The Red Cliff Mine project is located in the Colorado River Basin. This is the second-largest basin in Colorado, encompassing more than 18,160 square miles and 19,340 miles of streams. The volume of water that flows through the basin is greater than the combined flows of all the other basins in the state. The project area is located in a sub-basin within the Lower Colorado River watershed, north of the Colorado River near the Colorado-Utah border. The site encompasses the East Salt Creek, Mack Wash, and Big Salt Wash sub-basins. Many ditches and 20 major streams (19 intermittent and one perennial) are located in the Red Cliff Mine project area. The base flow of these streams is provided by groundwater seepage into the channel. In addition to these streams, there are also four reservoirs and lakes, numerous springs, and irrigation ditches and laterals in the project area that may be affected. The reservoirs and lakes include Highline Lake, Ruby Lee Reservoir, Mack Mesa Lake, and Mack Mesa Reservoir. The main ditch/canal in the project area is the Highline Canal. A bridge is proposed to be constructed over the Highline Canal for the railroad spur. The proposed railroad spur crosses one perennial stream (Mack Wash), one irrigation ditch (Highline Canal) and approximately 180 small ephemeral washes within the project area. The railroad wye, water diversion and water pipeline construction will take place approximately 2.5 air-miles from the Colorado River. The closest known occupied Colorado River endangered fish habitat is in the Colorado River at the confluence of Salt Creek, which is approximately 3.6 river miles (linear drainage distance) from the coal mine rail spur junction. The current status of the endangered fish in the Colorado River near the confluence with Mack Wash is as follows: Colorado pikeminnow are increasing in numbers; humpback chub are decreasing in numbers for unknown reasons, and razorback sucker and bonytail are increasing in numbers due to stocking of hatchery raised fish (USFWS 2008b). Salt Creek and Mack Wash are not known occupied habitat for any of the endangered fish species. Fish species known to inhabit Mack Wash include flannel-mouth suckers, roundtail WestWater Engineering
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chubs, bluehead suckers, and speckled dace. Natural spawning of flannel-mouth suckers occurs in Salt Creek (Martin, pers. comm. 2007). Salt Creek and East Salt Creek are not crossed by the railroad, and no flowing washes were encountered between the Highline Canal and the Book Cliffs during the field surveys that were conducted during all seasons in 2006 and 2007. Except for East Salt Creek and scattered stock ponds on the desert (mostly dry), all water in the project area is a result of irrigation development. 6.2.4 Effects Analysis 6.2.4.1 Project-Related Effects 6.2.4.1.1 Water Depletions For several years the Department of Interior, Colorado, Wyoming, Utah, water users and environmental groups cooperated to develop a Recovery Program for the Colorado River endangered fish species. This process culminated in the USFWS issuing the Final Programmatic Biological Opinion for Bureau of Reclamation’s Operations and Depletions, Other Depletions and Funding and Implementation of the Recovery Program Actions in the Upper Colorado River Above the Confluence with the Gunnison River, in 1999. This opinion covered existing depletions and addressed ―new depletions‖ which were additional depletions by existing water rights that occur after 1995. Small amounts of water from the Salt Creek Mine and McClane mine water rights were considered existing depletions, but the increased depletions for this project would be considered ―new depletions‖ and addressed by the opinion. For the Red Cliff Mine Project, Colorado River hydrology would be affected by a total water depletion of approximately 724 acre-feet annually, which will be withdrawn from Mack Wash for mine operations. Depletions would adversely affect water flow at different life-stages that are essential to these native fishes. Reduction in water quantity reduces the ability of the river to create and maintain the primary constituent elements that define critical habitats. Food supply, predation, and competition are important elements of the biological environment. Food supply is a function of nutrient supply and productivity, which may be limited by reduction of high spring flows brought about by water depletions. Predation and competition from nonnative fish species have been identified as factors in the decline of these endangered fishes. Water depletions contribute to alterations in flow regimes that favor nonnative fishes. Particularly important are flows sufficient enough and at a reasonable frequency (mimicking the natural hydrograph) to allow for creation, maintenance and use of important micro-habitats including spawning bars and backwater habitats needed by adult and young fish. Reduced water flows can reduce spawning habitat availability and usability and dewater important backwater habitats or fail to connect river and backwater habitats, resulting in lowered habitat quality, complexity, and availability. All of the above effects can result in declines in species recruitment and overall productivity. CAM currently holds a 3 cfs water right in Mack Wash and an alternate point of diversion is expected to be applied for to move this existing right upstream by approximately 1 mile. The impacts of this diverted water have been accounted for in the original water right and will be similar in the alternate point. WestWater Engineering
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Temporary impacts to surface waters may result during construction, resulting in the disturbance of soils that could potentially affect sediments loads in Mack Wash and the Colorado River. The project would potentially impact approximately 0.1 acre of jurisdictional wetlands along Mack Wash as a result of installing the water diversion structure. In addition, the center supports for the railroad bridge will occupy a very small area of Mack Wash. 6.2.4.1.2 Hazardous-materials During construction, natural sediments and human-caused pollutants from petroleum products would potentially affect Colorado River waters. If spills occurred, petroleum products used during construction activities would adhere easily to soil particles and other surfaces and would potentially affect water quality in the Colorado River. Adverse effects are unlikely because of mitigations including spill containment and cleanup programs and because most of the construction area is located several miles or more from the Colorado River. Normal operation of the Red Cliff mine and rail traffic would not result in the release of any hazardous material to the environment, although operation of the proposed mine-site facilities at the base of the Bookcliffs would involve potentially toxic or hazardous-materials including hydrocarbon waste, detergents, solvents, and batteries. These materials would be handled in accordance to Federal and State regulations and would be transported from the mine by motor vehicles. The proposed railroad would not haul hazardous-materials. In the advent of a railroad derailment, no hazardous-materials likely would be spilled or released as a result of the Proposed Action alternative. The diesel fuel, which is used to power a locomotive, is contained in doubled walled tanks and is less likely to rupture than single walled fuel tanks on trucks. A coal spill is not a considered a hazardous material. The Federal Railroad Administration (FRA) requires that the track operator have in-place an Emergency Response Plan prior to commencement of any track operations. This plan includes very specific procedures to mitigate rail derailment and any resulting spills. In the unlikely event of a major accidental release, the effects of a diesel fuel spill (from locomotive tanks) on Colorado River endangered fishes would be dependent on multiple variables. Diesel fuel is toxic to fish and direct mortality may result. Impacts to Colorado River endangered fishes would depend on where spills occurred, the amount of spill, time of the year (high or low water) and numerous other variables. Studies (Lytle and Peckarsky 2001) have demonstrated that a diesel fuel spill can significantly reduced the density of invertebrates and taxonomic richness in an aquatic environment for up to 15 months. Therefore, as well as potential direct effects to fish, habitats may be compromised for a period of time until recovery occurs. In extreme cold Ethylene glycol will be sprayed on the rail cars as a de-icer. It will be stored in a closed 500 gallon tank at the rail loadout. It would be extremely unlikely that the tank would leak and product reach East Salt Creek. Likewise, the amount of glycol potentially dripping from the rail cars would be negligible by the time the train reached the bridge over Mack Wash.

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6.2.4.2 Cumulative Effects State or Private Development in the Project Area. Within the project area in Mesa County on private lands, there are approximately 20 active development applications for residential, commercial, and agricultural development as of mid-2008 (Mesa County 2008). There are no major highway projects planned in Mesa County within the project area (Mesa County 2008). The development of natural gas resources in the general area (Grand Valley) is increasing as industry expands operations from on-going centralized operations that have been focused in the area of Parachute, Colorado. A limited amount of natural gas exploration and development is currently occurring in the project area. Other Federal Actions: Other than CAM-Colorado, there are currently no formal plans or applications for coal leasing before the BLM near the project area. Other sources of disturbance associated with Federal actions in the project vicinity that may increase the potential for cumulative effects on Colorado River fishes include the potential for expanded exploratory natural gas development on BLM lands in the project area. Slate River Resources developed a natural gas well in the CAM project area during 2007. 6.2.5 Conservation Measures Conservation measures included in the EIS include: 6.2.5.1 Construction Period 1. All gravel roads would be watered or treated with a surface surfactant to control potential fugitive air emissions. Water for dust suppression and compaction would be obtained from Mack Wash. A temporary pipeline would be installed along the rail route to provide necessary water for construction activities. 2. Any stormwater runoff that will be conveyed to surface water during construction activities would use appropriate erosion and sediment controls (i.e., BMPs), as applicable. These impacts are temporary in nature and would be mitigated with erosion and sediment controls, described further in the mitigation measures section. 6.2.5.2 Operational Period 1. In the event of a train derailment and spill, material could reach surface water from the contents of the rail cars. An emergency spill plan would be created to mitigate the likelihood that this causes an impact to the water quality. This will be part of the mine’s industrial stormwater permit or other similar plan to address spills. Impacts to surface water from blowing coal dust from the trains should be minimal, as the coal would come from the coal preparation plant wet and the mining operation would employ dust suppression (watering) on their conveyor systems. 2. Compliance with all remediation actions contained in CAM’s stormwater management plan to reduce the potential from increased silt loads in the Colorado River. CAM will be required to obtain a Storm Water Discharge Permit and a National Pollutant Discharge Elimination System (NPDES) permit from the State of Colorado Surface water runoff from the majority of the area, including all of the mine facilities and the rail loadout area, but not including the rail line, would be collected in sediment ponds. Sediment ponds are designed to provide adequate capacity to contain or treat the runoff or inflow entering the

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pond as a result of a 10-year, 24-hour precipitation event and any additional storage resulting from inflow from the underground mine. 3. Surface runoff not collected in a sediment pond would be filtered through a sediment trap such as a silt fence or straw bales. Mine water discharge (groundwater) may mix with surface water. Surface infiltration around coal stockpiles or waste rock piles may allow mixing of surface and groundwater. 4. Aquatic species will be protected during pumping to fill the pipeline, by covering intakes systems with screening. 5. CAM will comply with the Toxic Substances Control Act of 1976 (15 U.S.C. 2601 et seq.) with regard to any toxic substances that are used, generated by or stored on the ROW or on facilities authorized under this ROW grant. Additionally, any release of hazardous wastes (leaks, spills, etc.) in excess of the reportable quantity would be reported as required by the Comprehensive Environmental Response, Compensation and Liability Act of 1980. 6. In the unlikely event of a water pipeline failure during operation, the decreased pressure and flow rate in the pipeline would be detected remotely, and flow would stop. Some short-term flooding could occur in topographic lows and drainage channels, resulting in short-term adverse impacts to the floodplain. 7. Generated wastes would be handled in accordance with applicable regulations as described in Section 3.1.10, Hazardous-materials. Hazardous wastes generated during operation would be removed from the site by a licensed regulated waste management contractor at regular intervals and trucked to authorized facilities for recycling or treatment and disposal. 8. Increased sediment load to any waterways that are tributary to the Colorado River is a concern during construction. Sediment loads are not expected to increase to levels, which would adversely affect Colorado River endangered fish that are well-adapted to the high sediment loads traditionally carried by the Colorado River. Water quality impacts, resulting from increased sedimentation in stream channels and increased turbidity and salinity of surface waters due to runoff and erosion from disturbed areas, are expected to be minimal because surface water control measures are part of the project design. All construction activities would utilize best management practices to prevent sediment from entering drainages that enter Mack Mesa Reservoir, Highline Lake, Mack Wash and Salt Creek. In order to mitigate erosion and sedimentation on construction sites, mitigation practices would include: Adding mulch and seeding to protect the soil from erosion, Utilizing standard stormwater management practices including straw bales, silt fences, gravel bags, terraces and diversions designed to catch sediment, Implementation of reclamation and revegetation plans will decrease the likelihood of increased sedimentation into the Colorado River that would potentially affect water quality conditions. On federal lands, a BLM approved seed mix will be used. Reclamation standards on private surface should conform to the wishes of the landowner, Implementation of an approved noxious weed management plan will increase the potential for successful revegetation of native plant communities.

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9. As a means of offsetting the water depletion impacts associated with the proposed action, CAM-Colorado, LLC proposes to submit a one-time contribution in the form of a monetary payment to the National Fish and Wildlife Foundation on behalf of the Recovery Program for the 4 Colorado River endangered fishes in the current amount of $17.79 per acre-foot of the project's average annual depletion. 6.3.5 Determination 1: Colorado River Water Depletions Determination of effects of action(s), as described, on the Colorado pikeminnow, razorback sucker, humpback chub and bonytail, and their critical habitat: ______ No Effect May Affect, Is Not Likely to Adversely Affect X May Affect, Is Likely to Adversely Affect

Rationale: In accordance with the USFWS Final Section 7 Consultation Handbook (USFWS 1998), a determination of ―may affect, is likely to adversely affect‖ is the appropriate conclusion if any adverse effect to listed species may occur as a direct or indirect result of the proposed action or its interrelated or interdependent actions, and the effect is not: discountable, insignificant, or beneficial. The determination of ―may affect, is likely to adversely affect|‖ is appropriate because water depletions from the Colorado River will occur. These water rights have not undergone Section 7 consultation and, therefore, are not addressed in the existing USFWS 1999 Programmatic Biological Opinion regarding the Colorado River endangered fishes (USFWS 1999). The volume of water is large enough to require mitigation. The BLM has a programmatic biological opinion covering small volumes of water, which would not be applicable for this project. Conclusion: With respect to conservation measure bullet number 9 above, the applicant (CAMColorado, LLC) proposes to offset the water depletion impacts associate with the proposed action by submitting a one-time monetary contribution to the Recovery Program. At the time of this consultation, it has been determined that the proposed action would annually deplete up to 724 acre-feet of water per year. For Fiscal Year 2008 (October 1, 2007, to September 30, 2008), the depletion charge is $17.79 per acre-foot. Thus, based on our calculated average annual depletion, a one-time payment of $12,879.96 would be required to cover the proposed action and help to offset projected impacts. This amount will be provided to the Service's designated agent, the National Wildlife Foundation. The balance will be paid at the end of FY-08 by CAM-Colorado, LLC. Fifty percent of the funds will be used for acquisition of water rights to meet the instream flow needs of the endangered fishes (unless otherwise recommended by the Implementation Committee); the balance will be used to support other recovery activities for the Colorado River endangered fishes. The one-time payment will be made to the National Fish and Wildlife Foundation: Rebecca Kramer, Special Funds Coordinator National Fish and Wildlife Foundation 28 Second Street, 6th Floor San Francisco, California 94105 The payment will be accompanied by a cover letter that identifies the project and biological WestWater Engineering
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opinion that requires the payment, the amount of payment enclosed, check number, and any special conditions identified in the biological opinion relative to disbursement or use of the funds (there are none in this instance). The cover letter also shall identify the name and address of the payor, the name and address of the Federal Agency responsible for authorizing the project, and the address of the Service office issuing the biological opinion. This information will be used by the Foundation to notify the BLM, the lead Federal Agency, and the Service that payment has been received. The Foundation is to send notices of receipt to these entities within 5 working days of its receipt of payment. 6.3.6 Determination 2: Hazardous-materials affects Determination of effects of action(s), as described, on the Colorado pikeminnow, razorback sucker, humpback chub and bonytail, and their critical habitat: ______ No Effect X May Affect, Is Not Likely to Adversely Affect May Affect, Is Likely to Adversely Affect Rationale: In accordance with the USFWS Final Section 7 Consultation Handbook (USFWS 1998), a determination of ―may affect, is not likely to adversely affect‖ is the appropriate conclusion if any adverse effect to listed species may occur as a direct or indirect result of the proposed action or its interrelated or interdependent actions, and the effect is discountable, insignificant, or beneficial. The determination of ―may affect, is not likely to adversely affect|‖ is appropriate because potential effects on critical habitat including water quality affects from hazardous-materials is remote/insignificant due to mitigation programs including hazardous-waste handling programs. No hazardous material will be transported in the coal cars.

7.0 BLACK-FOOTED FERRET 7.1 Species Description Black-footed ferrets are considered an endangered species by both federal and state authorities. Since 1967, black-footed ferrets have been listed as endangered under the federal Endangered Species Act. The black-footed ferret is a large weasel, about the size of a mink, 18 – 22 inches long with a 4to 6- inch tail. The pelage is yellowish brown above, with a blackish wash on the back, black feet and face mask, and a black-tipped tail. They are difficult to distinguish from domestic ferrets, but they are larger and heavier than the long-tailed weasel (which in Colorado seldom has a face mask). Black-footed ferrets seem never to have been abundant in Colorado. They ranged statewide. Their habitat included the eastern plains, the mountain parks and the western valleys – grasslands or shrub lands that supported some species of prairie dog, the ferret’s primary prey.

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Females do not exhibit the delayed implantation of embryos typical of the weasel family. Instead they mate in early spring and give birth to a litter of three or four mouse-sized pups after a seven-week gestation period. The native range in northwest Colorado includes remote scrubland in Rio Blanco and Moffat Counties in northwest Colorado. 7.2 USFWS Management-Colorado USFWS management plans are directed at establishment of self-sustaining population in areas of suitable habitat that have been selected in northwest Colorado. Currently, the Wolf Creek Management Area for the black footed ferret, which is in Moffat County about 50 miles north of the project area, is the closest site to the CAM project area. Management is accomplished through a partnership with the BLM, the Colorado Division of Wildlife (CDOW) and the USFWS. Ferrets have been reintroduced into the Wolf Creek population in northwestern Colorado near Rangely. Since 2001, 237 black-footed ferrets have been released in the Wolf Creek area and wild-born ferret kits were first found there in 2005. Recent survey conducted by CDOW and BLM confirmed 16 ferrets present in the reintroduction area at the end of 2007. A second ferret population has been established at Coyote Basin, which straddles the Colorado-Utah border west of Rangely. Currently, there are no USFWS plans for reintroduction of black-footed ferrets in the Grand Valley area, which includes the CAM project site. There are no current inventories for ferret occurring in the project area though surveys have been conducted in the Grand Valley in the past. Black-footed ferrets are obligate species and occurrence is directly related to the presence of prairie dog colonies. The USFWS service does not management prairie dog colonies in the Grand Valley area. The State of Colorado, CDOW provides management and regulatory authority. 7.3 Project Area Conditions Numerous black-footed ferret surveys have been performed in the Grand Valley since the species was included on the ESA list. To date, no ferrets have been observed in the Grand Valley or within the project area. All existing populations of black-footed ferrets in Colorado were introduced from captive-reared stock. The nearest such experimental population is located at Wolf Creek between Massadona and Elk Springs, approximately 60 miles north of the project area. Within the CAM project area, white-tailed prairie dog colonies were encountered at various points on public and private lands from the Highway 6&50 crossing to the mine facilities area. Figure 2 and Table 2 indicate areas on and adjacent to proposed facilities, roads, and rail line that currently support prairie dog populations. Thirteen separate white-tailed prairie dog colonies were identified. Of these, eleven are located along the proposed rail spur alignment, eight of which may be crossed by the rail spur. Two colonies were found along the access road to the facility site. WestWater Engineering
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Burrow densities and areas occupied by various populations varied considerably. The largest concentrations occurred on private land north of Highway 6 & 50 and on private and public land east of the farm grounds along East Salt Wash and north of the Highline Canal. Table 2. Area and estimated burrow density of white-tailed prairie dog colonies, Red Cliff Mine project area Colony Number Area of Colony Estimated Burrow (numbered from south to north on Figure 2) Acres Density (Acre) 1 > 173.78 * 16 2 3 4 5 6 7 8 9 10 11 12 13
*Surveys in these areas were limited by land ownership issues

4.70 18.57 1.59 17.85 23.01 74.10 9.00 16.89 >12.33 * 137.73 56.77 9.43

10 3 8 3 6 12 3 2 2 11 4 2

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CDOW has mapped prairie dog colonies in the Grand Valley as part of ongoing wildlife management programs (Figure 3). The most recent surveys were conducted in 2004 and 2005. Within the overall range in the Grand Valley from Palisade to the Colorado/Utah state line, CDOW estimates approximately 13,400 acres were within occupied white-tail prairie dog habitat at the time of the study. CDOW (Kindler, CDOW, pers. comm. 2008) cautions that this information was a snapshot of the occupied habitat at the time surveys were completed and may not represent current (2008) conditions. Prairie dog populations are dynamic; occupied ranges and colony densities may fluctuate due to disease outbreaks or changes in the carrying capacity related to habitat conditions. 7.4 Effects Analysis Black-footed ferret surveys were conducted in the Grand Valley by CDOW and BLM during the early 1980s when extensive searches were being conducted in Western states in an effort to locate evidence of the species existence. These searches were in part a response to the discovery of black-footed ferrets in Meeteetse, Wyoming, in 1981. No black-footed ferret individuals or populations have ever been documented in the Grand Valley or within the project area. The black-footed ferret is an obligate species; its existence is dependent upon the prairie dog (Cynomys spp.) as a source of food and uses its burrows for shelter. Active prairie dog colonies are an essential component of black-footed ferret habitat. The USFWS has determined that any actions that kill prairie dogs or alter their habitat could prove detrimental to ferrets occupying the affected prairie dog towns(s). The USFWS has established minimum guidelines for ferret surveys (USFWS 1996). For white-tailed prairie dog colonies or complexes with at least 200 acres in area, with a burrow density of at least 8 burrows per acre and located within 4.34 miles of a similar colony may be considered potential black-footed ferret habitat (USFWS 1996). Based on the results of surveys for this project and CDOW surveys, white-tailed prairie dog habitat may be of sufficient size and juxtaposition to be potential habitat for black-footed ferret. The prairie dog colonies north of the Highline Canal in the project ROW are less than 200 acres, but likely are located close enough to other occupied colonies to be considered a suitable complex. The 6 prairie dog colonies located south of the Highline Canal are either linear in nature or each is less than 200 acres. The surrounding habitat is largely developed irrigated farmland, which result in a narrow corridor of potential ferret habitat and likely compromises a complex of sufficient size to be suitable black-footed ferret habitat. The prairie dog habitat north of the Highline Canal is extensive on BLM lands. The lack of any data demonstrating the presence of black-footed ferret in the Grand Valley supports the supposition that a self-sustaining population is not present. In order for the habitat to become occupied by black-footed ferret, a reintroduction program would be necessary or a wild population could potentially immigrate into the area. Currently, the USFWS, CDOW and BLM are not planning on a reintroduction program in the Grand Valley area. Immigration to the project area and establishment of a self-sustaining black-footed ferret population from the Wolf Creek-Coyote Basin population north of Rangely is unlikely. Approximately 50 miles of unsuitable habitat that lacks prairie dog colonies separates to the two areas.

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Black-footed ferrets, under current environmental conditions and lack of planned management actions (reintroductions), are unlikely to occur in the Grand Valley and, therefore, would not be affected by the Red Cliff mine project. 7.5 Cumulative Effects 7.5.1 State or Private Development in the Project Area Within the project area in Mesa County on private lands, there are approximately 20 active development applications for residential, commercial, and agricultural development as of mid2008 (Mesa County 2008). There are no major highway projects planned in Mesa County within the project area (Mesa County 2008). The development of natural gas resources in the general area (Grand Valley) is increasing as industry expands operations from on-going centralized operations that have been focused in the area of Parachute, Colorado. A limited amount of natural gas exploration and development is currently occurring in the project area 7.5.2 Other Federal Actions Other than CAM-Colorado, there are currently no formal plans or applications for coal leasing before the BLM near the project area. Other sources of disturbance associated with Federal actions in the project vicinity that may increase the potential for cumulative effects on potential black-footed ferret habitat include the potential for expanded exploratory natural gas development on BLM lands in the project area. Slate River Resources developed a natural gas well in the CAM project area during 2007. 7.6 Conservation Measures 1. Implementation of reclamation and revegetation plans will help maintain native vegetation community to provide a forage base for potentially affected prairie dog colonies. On federal lands, a BLM approved seed mix will be used. Reclamation standards on private surface should conform to the wishes of the landowner. 2. Implementation of an approved noxious weed management plan will increase the potential for successful revegetation of native plant communities. 3. Minimize the width of the spur line within affected prairie dog colonies and minimize construction affects. 7.7 Determination Determination of effects of action(s), as described, on the black-footed ferret: _____ No Effect X May Affect, Is Not Likely to Adversely Affect May Affect, Is Likely to Adversely Affect

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Rationale: In accordance with the USFWS Final, Section 7, Consultation Handbook (USFWS 1998), a determination of ―may affect, is not likely to adversely affect‖ is the appropriate conclusion when effects on listed species are expected to be discountable, or insignificant, or completely beneficial. The determination of ―may affect, is not likely to adversely affect|‖ is appropriate given the fact that white-tailed prairie dog habitat may be suitable habitat for the black-footed ferret, however the ferret is highly unlikely to naturally colonize the project area and no reintroduction program is planned for the project area. 8.0 REFERENCES Cedar Creek Associates, Inc. (Cedar Creek). 2006. Unpublished CAM Wildlife Baseline report submitted to CAM Colorado LLC. Cedar Creek Associates, Inc., Fort Collins, Colorado. 23 pp. + appendices. Kindler. J. 2008. Colorado Division of Wildlife, personal communication, CDOW, Ft. Collins, CO. Lytle, D.A. and B.L. Peckarsky. 2001. Spatial and temporal impacts of a diesel fuel spill on stream invertebrates. Freshwater Biology, Volume 46, Issue 5, pages 693-704. Martin, L. 2007. Personal conversation with WWE biologists regarding fish species occurrence in Mack Wash. WestWater Engineering, Grand Junction, Colorado. Mesa County. 2008. Regional Focus: CDOT Update. www.mesacounty.us/mcweb/mpotpr/2008_1st_quarter.pdf. Accessed April 28. Osmundson, D.B., and L.R. Kaeding. 1989. Studies of Colorado squawfish and razorback sucker use of the ―15-Mile Reach‖ of the upper Colorado River as part of conservation measures for the Green Mountain and Ruedi Reservoir water sales. Final Report. U.S. Fish and Wildlife Service, Colorado River endangered fishery project, Grand Junction, Colorado. Spackman, S., B. Jennings, J. Coles, C. Dawson, M. Minton, A. Kratz, and C. Spurrier. 1997. Colorado Rare Plant Field Guide, Prepared for the U.S. Bureau of Land Management, the U.S. Forest Service and the U.S. Fish and Wildlife Service by the Colorado Natural Heritage Program. USACE. 2007. USACE Regulatory Branch Memorandum 2007-1. U.S. Army Corps of Engineers, Sacramento District, Colorado West Branch, Grand Junction, Colorado. USFWS. 1973. Endangered Species Act of 1973. 16 U.S.C. 1544. U.S. Fish and Wildlife Service. USFWS. 1994. Federal Register / Vol. 59, No. 54 / Monday, March 21, 1994 / Determination of critical habitat for the Colorado River endangered fishes: Razorback Sucker, Colorado Squawfish, Humpback Chub, and Bonytail Chub. U.S. Fish and Wildlife Service.

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USFWS. 1996. Black-footed ferret survey guidelines. U.S. Fish and Wildlife Service. http://www.fs.fed.us/r2/nebraska/ gpng/reports/ferret_guidelines.html. USFWS. 1998. Final, Endangered Species Act, Section 7, Consultation Handbook. U.S. Fish and Wildlife Service. USFWS. 1999. Final Programmatic Biological Opinion: Upper Colorado River (ES/GJ-6-C O99-F-033). U.S. Fish and Wildlife Service. USFWS. 2002a. Colorado pikeminnow, recovery goals. U.S. Fish and Wildlife Service, Region 6 Office, Denver, Colorado. USFWS. 2002b. Razorback sucker, recovery goals. U.S. Fish and Wildlife Service, Region 6 Office, Denver, Colorado. USFWS. 2002c. Humpback chub, recovery goals. U.S. Fish and Wildlife Service, Region 6 Office, Denver, Colorado. USFWS. 2002d. Bonytail recovery goals. U.S. Fish and Wildlife Service, Region 6 Office, Denver, Colorado. USFWS. 2006. Federal Register / Vol. 71, No. 240 / Thursday, December 14, 2006 / Proposed Rules. U.S. Fish and Wildlife Service. USFWS. 2008a. U.S. Fish and Wildlife Service, Upper Colorado Fish Recovery Program, internet site, http://www.fws.gov/ColoradoRiverrecovery. USFWS. 2008b. Telephone conversation with USFWS representative Patty Gelatt, August 14. WWE. 2006. Unpublished biological surveys of the CAM Red Cliffs project area. WestWater Engineering, Grand Junction, Colorado.

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Native American Consultation

SHPO Consultation

USACE Consultation

Jurisdictional Determination Request January 31, 2008

January 31, 2008

Mr. Steve Moore US Army Corps of Engineers 402 Rood Ave., Room 142 Grand Junction, CO 81501 RE:

Via e-mail: Stephen.A.Moore@spk01.usace.army.mil

Jurisdictional Determination Request: Part 2, Request for confirmation of wetland delineation and jurisdictional determination for the CAM Colorado LLC Coal Mine and Rail Spur Project, Mesa and Garfield Counties, Colorado

Mr. Moore: This is WestWater’s request for a confirmation of a wetland delineation and jurisdictional determination for the potential wetlands portion of the CAM Colorado LLC project in Mack, CO. This request includes the wetland delineation report, figures, photos, a jurisdictional JD form (2a), a non-jurisdictional JD form (2b), and COE data sheets. Feel free to contact our office if you have questions, or if we can be of service in any way. Sincerely,

Brett F. Fletcher Environmental Scientist/ Wetland Biologist

cc: Bill_Killam@urscorp.com Jeffrey_dawson@urscorp.com

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Jurisdictional Determination Request Proposed CAM Colorado LLC Red Cliff Mine and Rail Spur Mesa County, Colorado January 2008 This is a request for U.S. Army Corps of Engineers (COE) jurisdictional determination and confirmation of a wetland delineation performed on the site of the proposed Red Cliff Mine and related rail spur, north of Mack, Colorado (Figure 1). The delineation was performed by WestWater Engineering (WestWater) biologists on the following dates: June 19, 20, 21, Aug. 17, Nov. 17, 18, 20, 21, 27, Dec. 8, 18, 2006 and Feb. 23, 24, 2007. Background CAM Colorado, LLC, proposes to develop a coal mine facility in the southwest corner of Garfield County. Development of the mine will also require the construction of approximately 15 miles of rail spur on public and private lands in Mesa and Garfield Counties to transport coal from the mine facility to the Union Pacific Railroad south of Mack, Colorado. Based on maps of the proposed railroad right-of-way and the proposed mine facility provided by CAM Colorado, WestWater Biologists surveyed the approximately 2,450 acre project site and surrounding areas to identify and delineate potential wetlands and Waters of the United States (WOUS) within and adjacent to proposed construction boundaries (Figure 1). At the request of the COE the project was divided into two parts: 1. Request for a Jurisdictional determination identifying potential non-wetland WOUS. 2. Request for confirmation of Wetland delineation and Jurisdictional determination. Part 1 of this project report identified non-wetland dry wash crossings within the project area. The majority of these washes were located north of the Government Highline Canal and the report was submitted to the Colorado/Gunnison Basin Office of the Army Corps of Engineers December 5, 2007. Part 2 of this project report identifies wetland areas within the project area, all of which are south of the Government Highline Canal (Figure2). This report is a request for confirmation on wetland delineations preformed and a request for a determination on the jurisdictional status of these wetland areas. This report is Part 2 Delineation Methods Wetland delineation was performed during the 2006 growing season while irrigation of nearby agricultural areas was underway. Recent (2005 and 2007) precipitation has been near normal for the Grand Valley, unlike the preceding drought years (2002 through 2004), so related wetland characteristics were considered to be in relatively normal condition as well. WestWater biologists surveyed approximately 15.5 miles of the proposed rail alignment extending from the existing rail line in the town of Mack, Colorado to the base of the Book Cliffs. Potential wetlands were identified within the 500 foot rail spur right-of-way and any wetlands that could potentially be disturbed were also identified. Wetland boundaries were
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identified on the basis of the vegetation, soils and hydrologic characteristics present at the site in accordance with Interim Arid West Regional supplement to the COE Wetland Delineation Manual, December 2006, and the U.S. Army Corps of Engineers Jurisdictional Determination Form Instructional Guide Book, May 30, 2007. The wetland boundary delineation included identification of plant species, vegetation composition and structure. Soil borings (18 ± inches deep) were taken with an auger for observation of wetland hydrologic and soil characteristics. Soil horizons were examined for color, texture, and moisture characteristics. The wetland boundaries based on these evaluation methods were marked with numbered orange flags and surveyed by Meritt L S. Army Corps of Engineers wetland delineation data forms are in appendix A of this report. Jurisdictional findings are presented in this report and on the Jurisdictional Determination Forms (JDF) 2a and 2b. Significant nexus determinations were made by examining the functions that may significantly affect the physical, chemical, and biological integrity of downstream Traditionally Navigable Waters (TNWs) or contributing Relatively Permanent Waters (RPWs) and Non-RPWs. Additionally, these wetlands were evaluated for their potential to retain or transport sediment and/or pollutants into a TNW or RPW. Where wetland characteristics were present, wetlands were walked to determine surface water connectivity to WOUS and TNWs. Individual wetlands were evaluated based on their physical, chemical, and biological functions and values. Upland to wetland transects were installed and relevant vegetation, soils and hydrologic characteristics were recorded on COE Data Forms. Delineation Findings This delineation included an irrigation canal, irrigation ditches, wetlands, and 2 potential crossings of one perennial stream. WestWater’s delineation identified 19 polygons with wetland characteristics. Wetland type, polygon ID’s, areas, and flag numbers are summarized in Table 1, jurisdictional findings are summarized in Table 2, and individual flag and transect locations are listed in Table 3. Table 1. Wetland Area Summary
Wetland Type Emergent Wetland Marsh (Total area = 11.51 acres) Area ID A H K M O D E Wetland Fringe (Total area = 3.12 acres) B C F G P Area in acres 0.4 10.85 0.166 0.077 0.008 0.0001 0.013 0.26 0.6 0.023 0.01 0.1 Flag Numbers A001-A021 H001-H112 K001-K018 M001-M006 O001-O003 D001 E001-E004 B001-B018 C001-C052 F001-F004 G001-G005 P001-P014 Upland/Wetland Transects and comments TAU (upland) – TAW (wetland), Located at boundary flags A004. THU – THW, between flags H019 & H020 Raised water table from impounded irrigation water TBU – TBW, located between flags B002 & B003 Ditch water has been impounded to raise water levels (B,C,P,Q,R)

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Table 1. Wetland Area Summary
Wetland Type Area ID Q R S T U V L Area in acres 0.38 1.09 0.49 0.03 0.11 0.035 1.45 Flag Numbers Upland/Wetland Transects and comments TPU – TPW, between flags P008 & L009.

Wetland Fringe (Total area = 3.12 acres

Q001-Q014 R001-R039 S001-S032 T001-T008 U001-U047 V001-V024 L001-L019

Mack Wash Gov. Highline Canal TLU- TLW, between flags L018 & L019 Within polygon H

De-Watered Wetland Marsh (total area = 1.45 acres) Dry areas within Wetlands

J

J001-J008

Emergent Wetland Marsh Polygons H, K, M, and O are located on a terrace east of East Salt Creek. This complex consists of one large emergent wetland marsh (H) (Photos 19 & 20), and three smaller emergent wetland marshes, polygons K, M, & O (Figure 3). These polygons receive irrigation return flow from elevated agricultural lands and a tree farm east of 10 Road. Excess water in spring and summer months provides a surface water connection to East Salt Creek. Irrigation return flows appear to be augmented by groundwater that sustains hydrology when irrigation flows stop. Surface water connections that were observed with East Salt Creek were associated with irrigation return flows. Plant species in these wetlands include: cattail (Typha latifolia), three-square (Scirpus pungens), and alkaligrass (Puccinellia spp.). Polygon A is located 1.6 miles south of polygon H on the same terrace. It is located below an agricultural field, Photo 18 and Figure 4, and its primary source of hydrology is irrigation return flows from that field. During irrigation season the area establishes periodic surface water connections with Mack Wash and groundwater seepage maintains hydrology during the growing season. Vegetation in polygon A is dominated by cattails and some common spikerush. Soils for all polygons on the terrace are mapped as Persayo silty clay loam. Polygons A, H, K, M, and O had hydric soil indictors categorized as F3, Depleted Matrix, which is characterized by 60 percent or more chroma of 2 or less and meets thickness requirements established by NRCS. Soils in polygon A also showed gleying. Wetland Fringe Polygons B, C, D, E, F, G, S, and T receive water from an irrigation ditch that passes underneath the railroad tracks near delineation flag B-6. Water at polygon B is impounded and transferred through a culvert into polygon C (Photos 2-4). Polygons E and D are associated with a subsurface connection from impounded water in Polygon B (Figure 5). Polygon C also impounds water and conveys it down an irrigation ditch to the west. This ditch is elevated 2 to 4

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feet above the existing area topography (Photos 4-6). Polygons F and G are remnants of a previous ditch and are subject to seepage from the elevated irrigation ditch in polygon C (Figure 5). Polygon C passes through a culvert under an access road into the concrete ditch in Polygon S. Broken portions of the concrete ditch and vegetation-induced blockages have caused the ditch to leak water into the Hwy 6&50 borrow ditch. It also overflows into the old agricultural fields to the south, widening the wetland footprint (Photos 7-10). Polygon S flows west through a culvert under an access road and into Polygon T. Polygon T terminates at a culvert that conveys the remainder of flow into Mack Wash just south of Hwy 6&50 bridge (Figure 5) (Highway 6&50 is also known as M 8/10 Road in this part of Mesa County). Vegetation in these polygons is dominated by cattails along the outer edges, except for polygon T which is dominated by Reed canarygrass (Photo 11). Soils are mapped as the Sagers and Homko series and show redoximorphic features and low chroma colors in the first 12 inches. Polygons P, Q, and R appear to be ditches that are raised above the natural topography. They receive water from an irrigation ditch that passes under the railroad near flag P-1. Polygon P curves around a disturbed fill area. The water passes through a culvert to the west into Polygon Q and flows between an access road and the railroad. Polygon Q conveys water through a culvert under the access road to Polygon R which follows the railroad west (Figure 5). The dominant species in polygons P, Q, and R is cattails. The wetland in Polygon R continues another 500 feet west beyond the limits of the project boundary (Figure 5). The remaining water from the ditch empties into a confined channel that west eventually flowing into Mack Wash, approximately 1.5 miles down stream of the 6&50 bridge. Soils are mapped as the Sagers and Homko series and show redoximorphic features and low chroma colors in the first 12 inches. Polygon U is emergent fringe wetlands along Mack Wash. Polygon U extends from the Hwy 6&50 Bridge upstream approximately 800 feet (Photo 17 and Figure 5). The polygon includes 1 potential crossing of Mack Wash and an alternative restructuring of the Hwy 6&50 bridge. Fringe wetlands along Mack Wash are dominated by tamarisk. Soils are mapped as Ustiffuvents and showed gleying within the first 12 inches. Mack Wash flows year round except in years of extreme drought. Polygon V is a proposed crossing along Government Highline Canal (Figure 6). Wetland vegetation along the canal is limited to a 1 foot wide row of cattails on the canal edges. Soils did not show redoximorphic features and were highly compacted. Hydrology is supplied by irrigation water diverted from the Colorado River during irrigation season. Water is withdrawn from the Colorado River near Palisade, CO and the canal terminates near West Salt Creek, west of Mack, CO. De-Watered Wetland Marsh Polygon L appeared to be two manmade ponds that were connected by a ditch (Figure 3). Soil borings in wetland Polygon L had redoximorphic features with sharp and distinct boundaries indicating relict redoximorphic features. WestWater biologists observed declines in wetland vegetation (reduced re-establishment and dead vegetation). Lack of wetland hydrology in

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Polygon L appears to be due to a change in irrigation practices upslope. Polygon L does not appear to be a groundwater discharge area and had no signs of hydrology during site visits. Jurisdictional Findings The polygons were divided into 2 groups; those likely to be jurisdictional and those believed to be non-jurisdictional. The project area includes 2 crossings of 1 perennial stream, Mack Wash, with its associated fringe wetlands. There are 18 polygons with wetland characteristics that are believed to be non-jurisdictional in the project area. Waters of the US, other waters, and their associated wetlands are summarized in Table 2. Surveyed UTM coordinates of wetland points and transects are listed in Table 3. Table 2. Jurisdictional Summary
Type Waters of the U.S. (WOUS) Wetlands Associated With WOUS Area ID U U B,C,D,E,F, G,S,T P,Q,R Total acres 0.6 0.11 0.1 Status Jurisdictional Jurisdictional Non-Jurisdictional Justification and Dimensions RPW Adjacent wetlands Irrigation waters 3000ft x 1.5ft Irrigation waters 3000ft x 1.5ft Irrigation waters 900ft x 0.5ft Irrigation waters 3100ft x 1ft Irrigation waters 700ft x 1ft Irrigation Canal 750ft x 35ft Marsh created by irrigation seepage Resultant of impounded Irrigation water Adjacent to irrigation ditches Distance to RPW 0 0 300ft to 1500ft To *Mack Wash 2600ft to *Mack Wash 3000ft to 7000ft to *Mack Wash 500ft to 1500ft to **East Salt Creek 3000ft to **East Salt Creek 6 miles to *** West Salt Creek

0.09

Non-Jurisdictional

A Other Waters

0.01

Non-Jurisdictional

H

0.08

Non-Jurisdictional

K,M,O

0.02

Non-Jurisdictional

V

0..6

Non-Jurisdictional

A,H,K,M,O

11.50

Non-Jurisdictional

Wetlands Associated With Other Waters

D,E,

0.013

Non-Jurisdictional

B,C,F,G,P, Q,R,S,T,V

3.01

Non-Jurisdictional

Lacks wetland De-Watered L 1.45 Non-Jurisdictional hydrology Wetlands * Distance from Mack Wash at Hwy 6&50 bridge to Colorado River Approx. 3.5 river miles. ** Distance from East Salt Creek (just below polygon H) to Colorado River Approx. 8 miles. *** Distance from Gov. Highline Canal and West Salt Ck. to Colorado River Approx. 16 miles

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Jurisdictional Wetlands Jurisdictional waters and wetlands in the project area consist of the perennial stream Mack Wash and its associated riparian fringe wetlands. Mack Wash flows year around and is considered a relatively permanent water of the US. The surveyed portion of Mack Wash extended 800 lineal feet up stream starting from just south of the Hwy 6&50 bridge. The area of jurisdictional nonwetland WOUS was 0.6 acres, adjacent riparian fringe wetlands totaled 0.11 acres. Non-Jurisdictional Wetlands Wetlands evaluated in this jurisdictional determination are associated with irrigation ditches, seepage, and irrigation return flows. Wetland characteristics and vegetation are a direct result of irrigation water. Without this source of hydrology these wetlands would cease to exist. Nonjurisdictional wetlands in the project area are associated with water allocated from the Colorado River, TNW, as irrigation water in a series of canals, and lateral ditches constructed by the Bureau of Reclamation in the late 19th century (BOR 1985). Wetlands established and maintained solely by artificial irrigation does not meet the definition of Waters of the U.S. under the criteria contained in the 1987 Corps of Engineers Wetlands Jurisdictional Manual or its regional supplements. Artificially irrigated wetlands that would revert to uplands if irrigation would cease are not generally considered to be jurisdictional waters of the United States under section 404 of the Clean Water Act (Sacramento RBM 2007-01). The 18 polygons showing wetland characteristics that are likely to be non-jurisdictional based on their source of hydrology are A, B, C, D, E, F, G, H, K,L, M, N, O, P, Q, R, S, T, and V (Figures 2 through 6). A description of the progression of water flow through a series of ditches to the project area follows. Flow into the Grand Valley Canal is diverted from the Colorado River east of Grand Junction in Palisade, Colorado. The canal flows west through the City of Grand Junction distributing irrigation water to lateral ditches. Between 12 and 13 Roads the canal turns south, crosses underneath Highway 6&50, and returns flow to the Colorado River near 13 Road. On the south side of the Highway 6&50 crossing, the Grand Valley Canal distributes water into the Mack Lateral. The Mack Lateral conveys water from the canal, via underground pipe, approximately 1.5 miles east to the town of Mack and its associated agricultural lands. The section of the Mack lateral that is piped ends at the Interstate-70 exit to the Town of Mack and is an open ditch from there on. The lateral meanders around the southern portion of Mack until just west of 10 Road where it turns north. The lateral splits into two main irrigation ditches. One ditch feeds two small agricultural ponds, crosses under the railroad tracks and turns west eventually flowing into to Mack Wash 1.5 miles downstream of the Highway 6&50 bridge. The other ditch continues north, crosses under the railroad tracks and divides into two smaller ditches. One of the smaller ditches flows north under Highway 6&50 and into Mack Wash. The other ditch is diverted to the west paralleling Highway 6&50 and ends up flowing through an underground conduit into Mack Wash, just south of the Highway 6&50 bridge (Photo 12 and Figure 5). From the Highway 6&50 bridge, Mack Wash flows southwest to Salt Creek and then into the Colorado River.

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The proposed rail alignment crosses the Government Highline Canal, which is another main irrigation canal in the Grand Valley. Government Highline Canal originates just north of the Grand Valley Canal from the Colorado River in Palisade, CO. The canal parallels the Grand Valley Canal to the north until the Grand Valley Canal turns south near 13 Road. Government Highline Canal continues west distributing irrigation water to lateral ditches north and west of Mack (Figures 1 & 6). The canal terminates at West Salt Creek. West Salt Creek flows into Salt Creek, which flows into the Colorado River. Irrigation ditches within the project area have been constructed in uplands. These ditches do not capture or convey jurisdictional waters of the US from tributaries along their flow path. The dry washes that are crossed flow only in times of heavy precipitation events (BOR 1977) and do not exhibit any wetland indicators such as hydric soils or wetland vegetation. Aerial photos in Figures 7 and 8 show distinct land surface changes in previously non-irrigated land that has been converted into agricultural production in the Mack area. Prior to the construction of these ditches the area was considered salt shrub desert and wetlands were confined to perennial washes. Transit loss and leakage from ditches have created wetland hydrology in some areas where it was previously non-existent. Unlined ditches and laterals, depending on substrate and sediment load, have losses of up to 2 cubic feet per square foot of ditch area per day (BOR 1986). During the last century of agricultural irrigation in the Grand Valley, a shallow perched water table has developed from water infiltrating weathered fractures in the Mancos shale (BOR 1986 & 1977). Water is leached through the fractures down to an impermeable layer of shale, which creates a perched water table. The impermeable shale can be 30 feet below the ground surface or just a few feet from the ground surface (BOR 1985 & 1977). Ground water is derived almost entirely from deep percolation of irrigation water and seepage from irrigation systems. Natural ground water recharge is less than 1% of the recharge occurring in the Grand Valley (BOR 1977 & 1985). The perched water table in the Grand Valley would be non existent without irrigation (BOR 1977). Aerial photos show the distinct vegetative boundaries between irrigation canals, lateral ditches, and the non-irrigated naturally arid salt-shrub desert (see Figures 7 and 8). Several local soil scientists were interviewed regarding their professional opinions as to the causes and extent of wetland redoximorphic soil features and groundwater soil inclusions in the project area. All of these individuals are considered local soil experts and have been involved in numerous projects and studies involving soils and groundwater. The following paragraph is based on the professional opinions they provided during discussions about the project area in Mack, Colorado. Ken Weston, Bureau of Reclamation Project Manager retired, Grand Junction Office. Extensive involvement in the Colorado River Basin Salinity Control Project and connected research. Bob Rayer, NRCS Soil Survey Project Manager, Grand Junction Office

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Max Schmidt, NRCS Soil Survey Project Manager retired, Grand Junction Office, and Bureau of Reclamation and EPA research on polyacrylamide used to line canals, ditches, and ponds to decrease transit losses. Soils in the area develop redoximorphic features as a result of impeded or excess surface water; this allows water to infiltrate through weathered fractures in the Mancos shale to an impermeable shale layer (Schmidt and BOR 1977 & 1985). Impermeable shale depths vary from the ground surface to depths of ~30 feet (Weston and BOR 1977). Water trapped in this horizon creates an unconfined perched water table and what would appear to be formation of near surface wetland soil inclusions and groundwater pockets (Rayer & Weston). The lack of water in the area precludes natural redoximorphic soil feature development; except where soils are in direct contact with perennial streams (Ken Weston and BOR 1977 & 1985). Studies on canal seepage that were conducted during the Colorado River Basin Salinity Control Project indicate that subsurface water tables directly relate to water levels present in irrigation canals and ditches (Ken Weston and BOR 1977 & 1985). Local area soil scientists believe that wetlands would not exist in the Grand Valley if it were not for irrigation, except when directly associated with perennial streams and permanent bodies of water (Weston, Rayer, Schmidt). When these scientists were asked if these wetlands would remain if irrigation was removed, they replied with a “No”. Significant Nexus Physical These areas with wetland characteristics are adjacent to non-jurisdictional irrigation ditches that provide insignificant contributions to the system other than returning irrigation flows. Natural runoff is limited in the arid environment and the lateral irrigation ditches in the area do not convey runoff from anything but small non-jurisdiction intermittent washes that only flow in times of severe localized precipitation events (BOR 1977). The functions of regulation of flow and flood attenuation are not applicable to irrigation ditches in the project area. Surface water connections from the Colorado River and into the Mack Lateral irrigation ditch are controlled by head gates during irrigation season. Chemical Natural salinity from salt-shrub desert and selenium transport from Mancos shale is expected when soils maintain extended periods of saturation. Irrigation runoff is assumed to include fertilizers and herbicides (not tested). Irrigation ditches may also provide a filtration and storage capacity for agriculturally related chemicals. Groundwater re-charge and creation of the perched water table can be viewed as a potential negative function as it mobilizes selenium and salinity that will be eventually transported into the Colorado River (TNW). Biological The habitat supports common amphibians and incidental use by terrestrial species that are characteristic of the salt desert shrub community. Active Northern Harrier Hawk nests were found in polygons A and H, and mule deer were frequently observed in these areas as well.

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Irrigation water has created wildlife habitat which differs considerably from those occurring naturally (BOR 1985). Conclusion This report presents information demonstrating the project area was not likely to have wetland characteristics prior to introduction of irrigation water. Most wetlands in the project area are the direct result of irrigation and are believed to be non-jurisdictional. A wetland established and maintained solely by artificial irrigation does not meet the definition of adjacent wetlands to WOUS under the criteria contained in the 1987 COE Wetlands Jurisdictional Manual or its regional supplements. Irrigation waters are generally considered non-jurisdictional by COE (RBM 2007-02). The hydrologic source associated with these wetlands should not be considered a tributary because it is water allocated from the TNW, Colorado River, to the Grand Valley Canal for the sole purpose of irrigation. No jurisdictional WOUS are collected from tributaries in the Mack lateral and water in excess of that required for agricultural purposes is conveyed back to the Colorado River as irrigation return flow. There is no information available to show that these irrigation ditches: 1) are or could be used by interstate or foreign travelers for recreational or other purposes, 2) produce fish or shellfish which are or could be taken and sold in interstate or foreign commerce, or 3) are or could be used for industrial purposes by industries in the interstate commerce (33 CFR 328.3). Consensus of local experts and studies is that the areas with wetland characteristics are a direct result of irrigation. If the source of irrigation water was removed the area would revert to uplands and wetland characteristics would no longer be apparent. Fringe wetlands and adjacent flood plains are the only naturally occurring wetlands in the area.

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Mack Wash

Project Area

Irrigation Return Ditch Railroad Crossing Points

Highway 6 &50

Irrigation Return Flow-paths Pre-irrigation Condition: note distinct vegetation line in 415 Lateral Ditch Railroad Tracks

Mack Lateral Ditch

Figure 7:

Mesa County Aerial 1937 Mack, CO

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Figure 8:

Mack Wash Project Area

Mesa County Aerial 2003 Mack, CO
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Irrigation Return Flow Ditch Railroad Crossing Points

Railroad Tracks Highway 6 &50

Irrigation Return Flow-paths

Irrigation Induced Land Surface Change

End of piped section Mack Lateral Ditch

Mack Lateral Ditch

Interstate 70 Mack Exit

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Photo 1. Return ditches south of railroad before coming into project area.

Photo 2. Return flow culvert into polygon B, north side of photo 1

Photo 3. Small pond in polygon B and culvert to elevated ditch polygon C
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Photo 4. Road side Hwy 6&50 looking east borrow ditch and elevated irrigation ditch with cattails
January 2008

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Photo 5. Polygon C culverts under road to concrete ditch in polygon S at blue truck

Photo 6. Elevated ditch in polygon C is approximately 3 feet above adjacent landscape

Photo7. Concrete ditch overgrown with cattails in polygon S
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Photo 8. Leakage from concrete ditch in polygon S to road side borrow ditch, looking east, Hwy 6&50 just to left of photo
January 2008

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Photo 9. East end of concrete ditch in polygon S

Photo 10. West end of concrete ditch in polygon S, most of the water has leaked into the borrow ditch by this point

Photo 11. Waters from polygon S flows through a culvert into polygon T (above)
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Photo 12. Return flows from polygon T are released via culvert into Mack Wash just south of Hwy 6&50 bridge
January 2008

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Photo 13. Culvert under railroad into polygon P

Photo 14. Polygon P flows around gravel pile and through a culvert into polygon Q

Photo 15. Wooden box culvert under road from polygon Q to polygon R
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Photo 16.East end of polygon R, composition similar to polygons P & Q
January 2008

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Photo 17. Mack Wash near proposed crossing north of Hwy 6&50 bridge

Photo 18. Polygon A and adjacent agricultural field.

Photo 19. Looking north along western edge of polygon H
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Photo 20. Looking northeast across polygon H
January 2008

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Table 3. Survey Boundary Flags
Description
B1 B2 TBW TBU B3 B4 B5 B6 B7 B8 B9 B10 D1 B11 B12 B13 B14 B15 B16 B17 B18 C1 C2 C3 C4 C5 C6 C7 C8 C9 C10 C11 C12 C13 C14 C15 C16 C17 C18 C19 C20 C21 C22 C23 C24 C25

Easting
683986.7171 683985.1446 683991.4528 683992.5349 683998.3796 684003.0099 684016.6633 684026.3269 684040.4491 684056.6618 684075.4657 684101.3638 684086.1304 684076.8688 684060.2916 684041.7859 684032.2831 684026.0486 684015.0335 684004.0288 683989.6787 683979.6688 683965.5192 683950.036 683936.9628 683922.0107 683903.1642 683888.9274 683871.8368 683858.1719 683846.8537 683832.1663 683814.719 683804.3881 683821.1489 683830.7218 683821.2389 683806.3249 683791.1102 683769.4976 683753.708 683735.6921 683716.9652 683698.0563 683677.2009 683659.0877

Northing
4343930.312 4343907.573 4343907.459 4343904.057 4343904.185 4343907.098 4343891.068 4343862.166 4343855.214 4343844.959 4343834.34 4343823.981 4343842.537 4343838.583 4343849.278 4343858.239 4343869.666 4343886.098 4343900.495 4343915.553 4343932.562 4343937.283 4343952.745 4343966.524 4343981.767 4343995 4344011.862 4344026.27 4344041.193 4344053.329 4344063.008 4344077.12 4344094.367 4344103.572 4344095.315 4344090.798 4344097.365 4344105.692 4344112.848 4344121.372 4344126.535 4344133.44 4344140.102 4344146.787 4344153.972 4344158.041

Description
C26 C27 C28 C29 C30 C31 C32 C33 C34 C35 C36 C37 C38 C39 C40 C41 C42 C43 C44 C45 C46 C47 C48 C49 C50 C51 C52 E1 E2 E3 E4 G5 G4 G3 G2 G1 F1 F2 F3 F4 A1 A2 A3 A4 TAW TAU

Easting
683655.4764 683651.3304 683667.1417 683689.6849 683715.5824 683733.3114 683757.1664 683781.2412 683802.193 683812.6297 683826.1818 683841.8499 683854.7152 683869.9034 683886.1857 683901.7581 683917.833 683934.292 683945.6063 683958.7038 683970.7262 683967.7102 683954.0793 683939.3755 683952.4393 683966.7478 683971.8189 683983.469 683988.4219 683997.5303 683992.7583 683838.0725 683848.8826 683860.1838 683878.723 683892.2028 683891.3513 683889.5578 683883.0444 683883.8054 683146.5536 683162.6013 683179.849 683197.6977 683197.8561 683197.0985

Northing
4344165.431 4344155.511 4344154.198 4344147.964 4344139.033 4344132.204 4344123.083 4344113.8 4344103.624 4344088.45 4344076.698 4344062.755 4344050.832 4344037.465 4344021.284 4344007.009 4343991.942 4343976.334 4343964.263 4343950.191 4343940.698 4343934.888 4343940.423 4343929.888 4343914.68 4343903.109 4343917.756 4343896.194 4343889.071 4343884.851 4343893.097 4344087.482 4344081.411 4344074.288 4344064.241 4344055.568 4344031.548 4344047.941 4344057.885 4344044.261 4345044.571 4345040.462 4345038.212 4345031.326 4345031.937 4345031.096

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Table 3. Survey Boundary Flags
Description
A5 A6 A7 A8 A9 A10 A11 A12 A13 A14 A15 A16 A17 A18 A19 A20 A21 H1 H2 H3 H4 H5 H6 H7 H8 H9 H10 H11 H12 H13 H14 H15 H16 H17 H18 H19 THW THU H20 H21 H22 H23 H24 H25 H26 H27

Easting
683216.7622 683238.3659 683258.1726 683282.7903 683303.8148 683319.8631 683317.5494 683296.809 683271.9524 683284.5035 683264.1214 683246.265 683229.1212 683217.3839 683200.6046 683181.0948 683160.0213 683628.4643 683605.0252 683581.4348 683552.951 683530.3305 683512.9402 683528.2021 683544.0384 683541.1962 683537.9246 683520.0454 683535.0373 683534.0198 683530.8575 683544.854 683556.4273 683558.5794 683568.4143 683593.4628 683596.1201 683595.3705 683615.4379 683628.4083 683620.2557 683628.6604 683635.29 683648.0318 683662.7272 683679.6854

Northing
4345013.105 4345006.667 4345006.522 4345009.668 4345017.247 4345019.745 4345027.074 4345023.212 4345031.73 4345016.524 4345013.223 4345013.067 4345012.72 4345027.108 4345040.686 4345046.594 4345055.471 4347544.207 4347554.434 4347556.048 4347542.519 4347534.822 4347541.159 4347557.425 4347571.65 4347593.03 4347606.964 4347614.64 4347623.651 4347644.901 4347658.227 4347679.826 4347690.287 4347716.63 4347729.421 4347727.828 4347727.538 4347724.171 4347711.177 4347695.268 4347714.837 4347721.626 4347734.51 4347731.991 4347730.832 4347732.212

Description
H28 H29 H30 H31 H32 H33 H34 H35 H36 H37 H38 H39 H40 H41 H42 H43 H44 H45 H46 H47 H48 H49 H50 H51 H52 H53 H54 H55 H56 H57 H58 H59 H60 H61 H62 H63 H65 H66 H67 H68 H69 H70 H71 H72 H73 H74

Easting
683694.0628 683711.6985 683695.8858 683669.8837 683673.0676 683685.8135 683696.2251 683697.5971 683708.042 683711.0487 683690.1484 683672.6761 683681.4529 683676.0962 683680.8532 683685.4032 683689.264 683689.1352 683697.6521 683689.3874 683673.0773 683665.7847 683649.2712 683658.1817 683662.3457 683659.0445 683670.9934 683692.3682 683703.2613 683685.2754 683663.438 683647.1063 683628.2852 683606.4449 683612.2657 683591.1739 683575.9494 683574.2366 683561.8472 683562.6186 683542.5577 683520.2729 683502.592 683483.3493 683485.1359 683457.2312

Northing
4347729.158 4347736.601 4347746.717 4347757.285 4347776.815 4347788.427 4347790.273 4347813.789 4347816.052 4347831.363 4347841.961 4347841.163 4347860.388 4347876.337 4347876.337 4347860.547 4347862.673 4347870.35 4347870.16 4347886.053 4347883.562 4347901.438 4347912.733 4347932.51 4347941.565 4347948.679 4347959.665 4347972.55 4347983.64 4347975.33 4347969.266 4347955.592 4347934.333 4347937.565 4347918.024 4347911.45 4347878.211 4347862.202 4347845.337 4347818.768 4347830.398 4347830.857 4347831.955 4347838.528 4347815.772 4347797.11

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Table 3. Survey Boundary Flags
Description
H75 H76 H77 H78 H79 H80 H81 H82 H83 H84 H85 H86 H87 H88 H89 H90 H91 H92 H93 H94 H95 H96 H97 H98 H100 H101 H102 H103 H104 H105 H106 H107 H108 H109 H110 H111 H112 J1 J2 J3 J4 J5 J6 J7 J8 N1

Easting
683488.6006 683514.0963 683541.012 683536.5532 683539.837 683534.2096 683541.2828 683522.0518 683503.9228 683527.4618 683510.1957 683499.9605 683520.3672 683496.8583 683499.2374 683494.9973 683472.9855 683479.947 683475.7993 683456.3419 683435.8737 683418.5852 683427.697 683424.3902 683426.9359 683426.0573 683448.0819 683463.2607 683474.8217 683480.2336 683499.9859 683517.7526 683539.5318 683561.9745 683581.8408 683598.5743 683626.7961 683503.5844 683496.2167 683477.2114 683465.2502 683442.7829 683443.6901 683470.0292 683486.9 683676.6747

Northing
4347808.306 4347815.593 4347817.556 4347804.506 4347793.721 4347782.638 4347766.007 4347756.644 4347753.292 4347746.493 4347732.874 4347723.52 4347694.617 4347688.001 4347666.119 4347646.326 4347639.56 4347623.271 4347605.052 4347592.079 4347589.057 4347573.794 4347559.683 4347545.724 4347534.748 4347525.844 4347522.525 4347517.346 4347506.668 4347521.055 4347530.67 4347528.522 4347529.037 4347524.834 4347511.236 4347520.354 4347533.272 4347539.196 4347547.781 4347546.425 4347539.231 4347537.137 4347530.861 4347522.5 4347532.026 4348098.712

Description
K1 K2 K3 K4 K5 K6 K7 K8 K9 K10 K11 K12 K13 K14 K15 K16 K17 N2 M1 M2 M3 M4 M5 M6 O3 O2 O1 L19 TLW TLU L18 L17 L16 L15 L14 L13 L12 L11 L10 L9 L8 L7 L6 L5 L4 L3

Easting
683695.4635 683682.543 683676.7512 683673.7554 683667.4549 683659.9 683656.9488 683664.8991 683643.8486 683647.9803 683658.11 683673.6411 683676.027 683691.3471 683702.9005 683686.3421 683688.2155 683680.3839 683646.8215 683679.8325 683693.7678 683703.237 683687.651 683671.6747 683696.8441 683709.6355 683721.3435 683705.6001 683703.7298 683704.9472 683702.0509 683645.6218 683612.1377 683597.8267 683603.4352 683597.1879 683609.7808 683644.1882 683679.9745 683708.6581 683766.3142 683796.3088 683829.7958 683828.6693 683841.6057 683862.7417

Northing
4348149.203 4348133.294 4348119.312 4348103.906 4348089.893 4348094.707 4348085.11 4348084.775 4348058.849 4348055.697 4348071.71 4348091.515 4348080.005 4348078.324 4348086.295 4348089.605 4348103.915 4348090.034 4348035.227 4348036.412 4348044.423 4348063.923 4348049.019 4348042.264 4348154 4348163.284 4348176.051 4348232.785 4348211.01 4348208.803 4348208.617 4348161.461 4348167.939 4348177.379 4348188.146 4348197.935 4348218.597 4348225.707 4348241.359 4348243.707 4348242.358 4348243.291 4348243.658 4348250.802 4348263.079 4348266.629

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Table 3. Survey Boundary Flags
Description
L2 L1 P1 P2 P3 P4 P5 P6 P7 P8 TPU TPW P9 P10 P11 P12 P13 P14 Q1 Q2 Q3 Q4 Q5 Q6 Q7 Q8 Q9 Q10 Q11 Q12 Q13 Q14 R1 R2 R3 R4 R5 R6 R7 R8 R9 R10 R11 R12 R13 R14

Easting
683860.6888 683839.0001 683741.5344 683736.5718 683726.94 683711.8974 683697.6173 683688.1456 683662.2741 683662.2544 683664.0571 683664.5589 683682.7856 683695.2355 683709.0683 683723.1201 683733.6031 683738.4431 683658.7795 683632.0291 683614.9875 683590.5831 683557.5734 683542.7155 683530.2606 683546.0649 683558.7796 683580.3225 683603.0114 683626.3075 683642.4839 683658.5621 683554.2544 683535.1113 683517.2304 683495.1177 683477.9758 683457.6843 683435.1187 683409.2132 683387.0928 683366.7475 683345.2306 683323.2864 683303.3353 683281.0868

Northing
4348253.725 4348247.254 4343987.411 4344003.408 4344015.212 4344025.332 4344032.781 4344041.446 4344040.069 4344036.862 4344035.5 4344036.938 4344035.032 4344031.587 4344022.954 4344012.361 4344000.356 4343988.106 4344039.547 4344038.449 4344036.234 4344032.705 4344027.431 4344023.075 4344020.853 4344019.112 4344018.734 4344018.692 4344017.672 4344018.01 4344023.596 4344036.669 4344041.135 4344041.977 4344042.03 4344041.327 4344037.867 4344036.847 4344036.303 4344031.959 4344028.266 4344026.228 4344021.849 4344019.85 4344017.576 4344016.769

Description
R15 R16 R17 R18 R19 R20 R21 R22 R23 R24 R25 R26 R27 R28 R29 R30 R31 R32 R33 R34 R35 R36 R37 R38 R39 T-1 T-8 T-2 T-7 T-3 T-6 T-4 T-5 S-20 S-21 S-22 S-23 S-24 S-25 S-26 S-27 S-28 S-29 S-30 S-31 S-32

Easting
683258.1387 683233.9354 683213.2303 683192.4327 683161.1052 683147.6306 683174.6651 683208.8102 683237.0157 683251.5787 683272.9017 683296.7174 683321.2872 683345.3241 683365.1008 683388.1205 683397.7983 683401.6188 683432.0243 683455.9608 683480.2835 683502.6957 683520.3002 683533.3551 683552.8884 683460.9126 683460.1477 683449.9499 683448.126 683440.4135 683437.7287 683428.123 683427.2138 683467.3343 683465.4256 683477.0346 683489.7504 683500.5674 683511.493 683527.0513 683538.47 683552.1849 683565.5301 683578.6564 683589.2938 683579.0494

Northing
4344010.062 4344009.37 4344009.413 4344013.402 4344008.951 4343977.62 4343983.191 4343987.2 4343992.557 4344002.132 4344006.314 4344010.646 4344015.232 4344018.229 4344022.046 4344024.59 4344018.17 4344024.681 4344023.511 4344030.79 4344029.336 4344030.164 4344033.051 4344035.103 4344035.307 4344279.829 4344278.562 4344285.805 4344282.558 4344293.206 4344290.573 4344297.246 4344295.869 4344275.603 4344270.444 4344262.693 4344254.522 4344247.395 4344240.428 4344230.386 4344223.022 4344214.239 4344205.02 4344197.034 4344188.735 4344184.712

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Table 3. Survey Boundary Flags
Description
S-1 S-2 S-3 S-4 S-5 S-6 S-7 S-8 S-9 S-10 S-11 S-12 S-13 S-14 S-15 S-16 S-17 S-18 S-19 U1 U2 U3 U4 U5 U6 U7 U8 U9 U10 U11 U12 U13 U14 U15 U16 U17 U18 U19 U20 U21 U22 U23 U24 U25 U26

Easting
683587.3782 683601.6188 683613.056 683613.8612 683629.4669 683643.3208 683645.1891 683633.049 683622.6782 683609.3314 683596.5397 683582.2217 683567.1154 683552.8199 683538.2517 683521.9319 683507.6068 683493.5375 683481.7662 683355.8 683363.7 683368.5 683371.7 683374.5 683376.7 683379.7 683381.9 683382.7 683385.8 683392.3 683401.1 683410 683422.7 683435 683441.7 683450.6 683460.6 683471.3 683477.8 683482.8 683488.7 683497.3 683492.8 683487.3 683481.9

Northing
4344179.829 4344179.932 4344172.52 4344169.493 4344164.066 4344157.465 4344169.487 4344176.298 4344179.863 4344186.941 4344195.391 4344204.838 4344213.65 4344222.143 4344231.581 4344243.522 4344253.65 4344262.445 4344270.119 4344310 4344313 4344320 4344329 4344338 4344346 4344355 4344363 4344374 4344381 4344383 4344382 4344381 4344383 4344386 4344391 4344396 4344394 4344388 4344382 4344376 4344366 4344371 4344377 4344385 4344391

Description
U27 U28 U29 U30 U31 U32 U33 U34 U35 U36 U37 U38 U39 U40 U41 U42 U43 U44 U45 U46 U47 V1 V2 V3 V4 V5 V6 V7 V8 V9 V10 V11 V12 V13 V14 V15 V16 V17 V18 V19 V20 V21 V22 V23 V24

Easting
683475 683467.7 683461 683451.7 683444.6 683439.6 683430.7 683421.7 683411.7 683402.4 683392.7 683385.3 683377.8 683374.8 683373.9 683372.6 683370.4 683367.8 683365 683360.5 683353.6 685432.7 685447.7 685465.1 685483.3 685498.3 685517.2 685537 685552 685567 685578 685590.6 685600.9 685608 685599.3 685582 685569.3 685555.1 685543.3 685526.7 685506.2 685486.4 685461.1 685443 685424

Northing
4344395 4344399 4344401 4344401 4344401 4344396 4344394 4344392 4344391 4344391 4344389 4344390 4344387 4344380 4344371 4344361 4344351 4344340 4344331 4344322 4344317 4350835 4350825 4350816 4350806 4350798 4350786 4350772 4350757 4350742 4350727 4350706 4350688 4350665 4350713 4350738 4350755 4350770 4350781 4350792 4350806 4350816 4350831 4350841 4350851

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PROJECT INFORMATION
Project Proponent: CAM Colorado, LLC 116 Main Street Pikeville, KY 41501 Mr. Nicholas R. Glancy CAM Colorado PO Box 1169 Pikeville, KY 41502 (859) 389-6500 CAM Colorado, LLC 116 Main St. Pikeville, KY 41501 United States Bureau of Land Management Grand Junction Field Office 2815 H Road Grand Junction, CO 81506 Hudson Ranch Estates of Great Western Colorado LLC P.O. Box 123 Mack, CO 81525 Vernon Langford 1725 10 Road Mack, CO 81525 Joseph Bennett P.O. Box 59 Mack, CO 81525 Michael J Ballew 1852 10 Road Mack, CO 81525 Doug Johnson 1833 11 Road Loma, CO 81524 State of Colorado Dept. of Natural Resources 1313 Sherman Street Denver, CO 80203 Joanne M Leishuck 1910 10 Road. Mack, CO 81525 #11 Enterprises 1218 Webster Street Houston, TX 77002 URS Corporation 8181 East Tufts Avenue Denver, CO 80237 WestWater Engineering 2516 Foresight Circle #1 Grand Junction, CO 81505 URS Corporation 8181 East Tufts Avenue Denver, CO 80237 Ph: (303)-740-3816

Proponent Contact:

Land Owners:

EIS Consultant:

Wetland Consultant:

Ph: (970) 241-7076 Fax: (970) 241-7097 Ph: (303)-740-3816

Project Location:

Mine Facility and Access Roads: Sections 3, 4, 9, 10, 15, 16, 17, 18, 19, T8S, R102W, 6th PM Rail Spur: Sec. 16, 21, 20, 29, 31, 32 T8S, R102W, 6th PM; Sec. 36, T8S, R103W, 6th PM; Sec. 1, 2, 11, 14, T9S, R103W, 6th PM; Sec. 6, 19, T2N, R3W, Ute PM; & Sec. 15, 22, 27, 34, T2N, R103W, 6th PM Red Cliff Coal Mine and associated facilities supporting the proposed coal mine project.

Project Description:

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References BOR. 1986. Bureau of Reclamation, Colorado River Basin Salinity Control Project Grand Valley Unit, Stage Two Development; Water Resources Technical Supporting Data for the Verification Memorandum. BOR. 1985. Bureau of Reclamation, Final Impact Statement; Grand Valley Unit, Stage Two Colorado River Basin Salinity Control Project, Mesa County Colorado. BOR. 1977. Bureau of Reclamation, Environmental Assessment, Grand Valley Unit, Colorado River Basin Salinity Control Project, December 1977. BOR. 1976. Bureau of Reclamation, Final Report on Flora and Terrestrial Vertebrate Studies of the Grand Valley Unit. Ecology Consultants, Incorporated, Fort Collins, Colorado. June 1976. CDOW. 2007. Colorado Division of Wildlife, Colorado Department of Natural Resources http://wildlife.state.co.us/WildlifeSpecies/SpeciesOfConcern/Reptiles/ CDSS. 2007. Colorado Decisions Support Systems. http://cdss.state.co.us/DNN/Stations/tabid/74/Default.aspx COE. 2007a. U.S. Army Corps of Engineers, 33 CFR Regulatory Regulations. http://www.sac.usace.army.mil/permits/33cfr.html [33 CFR 328.3(a)(3)(i-iii) and (a)(5)]. COE. 2007b. U.S. Army Corps of Engineers, Regulatory Guidance Letter 07-02. Subject: Exemptions for Construction or Maintenance of Irrigation Ditches and Maintenance of Drainage Ditches under Section 404 of the Clean Water Act. COE. 2007c. U.S. Army Corps of Engineers Jurisdictional Determination Form Instructional Guidebook. Prepared Jointly by U.S. Army Corps of Engineers and U.S. Environmental Protection Agency. COE. 2007d. U.S. Army Corps of Engineers, Sacramento District. Regulatory Branch Memorandum 2007-01. CESPK-CO-R (1145). US Army Corps of Engineers Regulatory Branch 1325 J Street, Room 1480 Sacramento, CA 95814 Environmental Law Institute. 2007. The Clean Water Act Jurisdictional Handbook. Washington, DC. FWS. 2002. Birds of conservation concern 2002. U.S. Fish and Wildlife Service, Division of Migratory Bird Management, Arlington, Virginia. NRCS. 2007. National Resource Conservation Service. http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx NWCC. 2007. National Water and Climate Center, National Resource Conservation Service. ftp://ftp.wcc.nrcs.usda.gov/support/climate/wetlands/co/08077.txt Spackman, S., B. Jennings, J. Coles, C. Dawson, M. Minton, A. Kratz, and C. Spurrier. 1997. Colorado Rare Plant Field Guide. Prepared for the U.S. Bureau of Land Management, the U.S. Forest Service and the U.S. Fish and Wildlife Service by the Colorado Natural Heritage Program (CNHP). U.S. Department of Commerce. 1973. NOAA Atlas 2: Precipitation- Frequency Atlas of the Western United States, Volume III-Colorado. National Oceanic and Atmospheric

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Administration, Silver Spring, Maryland. USGS. 1956-1972. Annual Reports on: Badger Wash Cooperative Study, Precipitation, Runoff, and Sediment Yield. U.S. Department of the Interior, U.S. Geological Survey, Washington, DC. USGS. 2007. Colorado Water Science Center, Colorado Current and Historical Water Data Online, U.S. Geological Survey. http://waterdata.usgs.gov/co/nwis/sw Rayer, Bob. 2007. NRCS Soil Survey Project Manager, Grand Junction Office. Personal communication Schmidt, Max. 2007. NRCS Soil Survey Project Manager, Grand Junction Office, retired. Personal communication Weston, Ken. 2007. Bureau of Reclamation Project Manager, Grand Junction Office retired. Personal communication

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Jurisdictional Determination Request for Confirmation Wetland Delineation Form 2a, Jurisdictional Wetlands

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APPROVED JURISDICTIONAL DETERMINATION FORM U.S. Army Corps of Engineers This form should be completed by following the instructions provided in Section IV of the JD Form Instructional Guidebook. SECTION I: BACKGROUND INFORMATION A. REPORT COMPLETION DATE FOR APPROVED JURISDICTIONAL DETERMINATION (JD):

B. DISTRICT OFFICE, FILE NAME, AND NUMBER: C. PROJECT LOCATION AND BACKGROUND INFORMATION: CAM Colorado proposes to develop a coal mine facility on approximately 1,886 acres of Bureau of Land Management land at the Red Cliff Mine site in the southwest corner of Garfield County. Development of the mine will also require the construction of approximately 15 miles of rail line on public and private lands in Mesa County to transport coal from the mine facility to the Union Pacific Railroad south of Mack, Colorado. Based on maps of the proposed railroad right of way and the proposed mine facility provided by CAM Colorado, WestWater Biologists surveyed the approximately 2,450 acre project site and surrounding areas to identify and delineate potential wetlands and waters of the U.S.(WOUS) within and adjacent to proposed construction boundaries. At the request of the COE the project was divided into two parts: 1. Request for a Jurisdictional Determination identifying potential non-wetland WOUS. 2. Request for confirmation of Wetland Delineation and Jurisdictional Determination. Form 2a Jurisdictional wetlands and waters of the U.S. Form 2b Non-jurisdictional wetlands and other waters This form is part 2a, Jurisdictional wetlands. State: CO County/parish/borough: Mesa City: Mack Center coordinates of site (lat/long in degree decimal format): Lat. 39.3183° N,Long. -108.8072° E. Universal Transverse Mercator: Name of nearest waterbody: Salt Creek and Mack Wash, RPWs Name of nearest Traditional Navigable Water (TNW) into which the aquatic resource flows: Colorado River Name of watershed or Hydrologic Unit Code (HUC): 14010005 Check if map/diagram of review area and/or potential jurisdictional areas is/are available upon request. Check if other sites (e.g., offsite mitigation sites, disposal sites, etc…) are associated with this action and are recorded on a different JD form. D. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT APPLY): Office (Desk) Determination. Date: Field Determination. Date(s): SECTION II: SUMMARY OF FINDINGS A. RHA SECTION 10 DETERMINATION OF JURISDICTION. There Are no “navigable waters of the U.S.” within Rivers and Harbors Act (RHA) jurisdiction (as defined by 33 CFR part 329) in the review area. [Required] Waters subject to the ebb and flow of the tide. Waters are presently used, or have been used in the past, or may be susceptible for use to transport interstate or foreign commerce. Explain: .

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B. CWA SECTION 404 DETERMINATION OF JURISDICTION. There Are “waters of the U.S.” within Clean Water Act (CWA) jurisdiction (as defined by 33 CFR part 328) in the review area. [Required] 1. Waters of the U.S. a. Indicate presence of waters of U.S. in review area (check all that apply): 1 TNWs, including territorial seas Wetlands adjacent to TNWs Relatively permanent waters2 (RPWs) that flow directly or indirectly into TNWs Non-RPWs that flow directly or indirectly into TNWs Wetlands directly abutting RPWs that flow directly or indirectly into TNWs Wetlands adjacent to but not directly abutting RPWs that flow directly or indirectly into TNWs Wetlands adjacent to non-RPWs that flow directly or indirectly into TNWs Impoundments of jurisdictional waters Isolated (interstate or intrastate) waters, including isolated wetlands b. Identify (estimate) size of waters of the U.S. in the review area: Non-wetland waters: 800 linear feet: 32 width (ft) and/or 0.6 acres. This area starts just south of the Hwy 6 &50 bridge (Highway 6 &50 is also known as M and 8/10 Road in this part of Mesa County) on Mack Wash and extends upstream approx. 800 feet. Wetlands: 0.11 acres for the total riparian fringe in the surveyed area. c. Limits (boundaries) of jurisdiction based on: Interim Arid West Regional Supplement to the Corps of Engineers Wetland Delineation Manual, December 2006. Elevation of established OHWM (if known): . 2. Non-regulated waters/wetlands (check if applicable):3 Potentially jurisdictional waters and/or wetlands were assessed within the review area and determined to be not jurisdictional. Explain: Other waters and associated wetlands likely to be considered nonjurisdictional will be evaluated in JD form 2b. SECTION III: CWA ANALYSIS A. TNWs AND WETLANDS ADJACENT TO TNWs The agencies will assert jurisdiction over TNWs and wetlands adjacent to TNWs. If the aquatic resource is a TNW, complete Section III.A.1 and Section III.D.1. only; if the aquatic resource is a wetland adjacent to a TNW, complete Sections III.A.1 and 2 and Section III.D.1.; otherwise, see Section III.B below. 1. TNW Identify TNW: . .

Summarize rationale supporting determination: 2.

Wetland adjacent to TNW Summarize rationale supporting conclusion that wetland is “adjacent”:

.

Boxes checked below shall be supported by completing the appropriate sections in Section III below. For purposes of this form, an RPW is defined as a tributary that is not a TNW and that typically flows year-round or has continuous flow at least “seasonally” (e.g., typically 3 months). 3 Supporting documentation is presented in Section III.F.
2

1

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B. CHARACTERISTICS OF TRIBUTARY (THAT IS NOT A TNW) AND ITS ADJACENT WETLANDS (IF ANY): This section summarizes information regarding characteristics of the tributary and its adjacent wetlands, if any, and it helps determine whether or not the standards for jurisdiction established under Rapanos have been met. The agencies will assert jurisdiction over non-navigable tributaries of TNWs where the tributaries are “relatively permanent waters” (RPWs), i.e. tributaries that typically flow year-round or have continuous flow at least seasonally (e.g., typically 3 months). A wetland that directly abuts an RPW is also jurisdictional. If the aquatic resource is not a TNW, but has year-round (perennial) flow, skip to Section III.D.2. If the aquatic resource is a wetland directly abutting a tributary with perennial flow, skip to Section III.D.4. A wetland that is adjacent to but that does not directly abut an RPW requires a significant nexus evaluation. Corps districts and EPA regions will include in the record any available information that documents the existence of a significant nexus between a relatively permanent tributary that is not perennial (and its adjacent wetlands if any) and a traditional navigable water, even though a significant nexus finding is not required as a matter of law. If the waterbody4 is not an RPW, or a wetland directly abutting an RPW, a JD will require additional data to determine if the waterbody has a significant nexus with a TNW. If the tributary has adjacent wetlands, the significant nexus evaluation must consider the tributary in combination with all of its adjacent wetlands. This significant nexus evaluation that combines, for analytical purposes, the tributary and all of its adjacent wetlands is used whether the review area identified in the JD request is the tributary, or its adjacent wetlands, or both. If the JD covers a tributary with adjacent wetlands, complete Section III.B.1 for the tributary, Section III.B.2 for any onsite wetlands, and Section III.B.3 for all wetlands adjacent to that tributary, both onsite and offsite. The determination whether a significant nexus exists is determined in Section III.C below. 1. Characteristics of non-TNWs that flow directly or indirectly into TNW washes are (i) General Area Conditions: Watershed size: Pick List Drainage area: Pick List Average annual rainfall: Average annual snowfall: (ii) Physical Characteristics: (a) Relationship with TNW: Tributary flows directly into TNW. Tributary flows through tributaries before entering TNW. Project waters are Pick List river miles from TNW. Project waters are Pick List river miles from RPW. Project waters are Pick List (straight) miles from TNW. Project waters are Pick List aerial (straight) miles from RPW. Project waters cross or serve as state boundaries. Explain: . Identify flow route to TNW5: Tributary stream order, if known:

.

4 Note that the Instructional Guidebook contains additional information regarding swales, ditches, washes, and erosional features generally and in the arid West. 5 Flow route can be described by identifying, e.g., tributary a, which flows through the review area, to flow into tributary b, which then flows into TNW.

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(b) General Tributary Characteristics (check all that apply): Natural Tributary is: Artificial (man-made). Explain: . Manipulated (man-altered). Explain: Tributary properties with respect to top of bank (estimate): Average width: feet Average depth: feet Average side slopes: Primary tributary substrate composition (check all that apply): Silts Sands Concrete Cobbles Gravel Muck Bedrock Vegetation. Type/% cover: Other. Explain: Tributary condition/stability [e.g., highly eroding, sloughing banks]. Explain: Presence of run/riffle/pool complexes. Explain: Tributary geometry: Tributary gradient (approximate average slope (c) Flow: Tributary provides for Estimate average number of flow events in review area/year Describe flow regime Other information on duration and volume Surface flow is: Characteristics Subsurface flow: Explain findings: Dye (or other) test performed: . Tributary has (check all that apply): Bed and banks OHWM6 (check all indicators that apply): clear, natural line impressed on the bank changes in the character of soil shelving vegetation matted down, bent, or absent leaf litter disturbed or washed away sediment deposition water staining other (list):

the presence of litter and debris destruction of terrestrial vegetation the presence of wrack line sediment sorting scour multiple observed or predicted flow events abrupt change in plant community Discontinuous OHWM.7 Explain:

If factors other than the OHWM were used to determine lateral extent of CWA jurisdiction (check all that apply): High Tide Line indicated by: Mean High Water Mark indicated by: oil or scum line along shore objects survey to available datum; fine shell or debris deposits (foreshore) physical markings; physical markings/characteristics vegetation lines/changes in vegetation types. tidal gauges other (list): (iii) Chemical Characteristics: Characterize tributary (e.g., water color is clear, discolored, oily film; water quality; general watershed characteristics, etc.). Explain: Identify specific pollutants, if known:
6 A natural or man-made discontinuity in the OHWM does not necessarily sever jurisdiction (e.g., where the stream temporarily flows underground, or where the OHWM has been removed by development or agricultural practices). Where there is a break in the OHWM that is unrelated to the waterbody’s flow regime (e.g., flow over a rock outcrop or through a culvert), the agencies will look for indicators of flow above and below the break. 7 Ibid.

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(iv) Biological Characteristics. Channel supports (check all that apply): Riparian corridor. Characteristics (type, average width): . Wetland fringe. Characteristics: . Habitat for: Federally Listed species. Explain findings: . Fish/spawn areas. Explain findings: . Other environmentally-sensitive species. Explain findings: Aquatic/wildlife diversity. Explain findings: 2. Characteristics of wetlands adjacent to non-TNW that flow directly or indirectly into TNW (i) Physical Characteristics: (a) General Wetland Characteristics: Properties: Wetland size: acres Wetland type: Explain: Wetland quality: Explain: Project wetlands cross or serve as state boundaries. (b) General Flow Relationship with Non-TNW: Flow is: Explain: Surface flow is: Characteristics: Subsurface flow: Explain findings: Dye (or other) test performed: . (c) Wetland Adjacency Determination with Non-TNW: Directly abutting Not directly abutting Discrete wetland hydrologic connection. Explain: Ecological connection. Explain: . Separated by berm/barrier. Explain: (d) Proximity (Relationship) to TNW Project wetlands are river miles from TNW. Project waters are aerial (straight) miles from TNW. Flow is from: Estimate approximate location of wetland as within the floodplain: (ii) Chemical Characteristics: Characterize wetland system (e.g., water color is clear, brown, oil film on surface; water quality; general watershed characteristics; etc.). Explain: Identify specific pollutants, if known: . (iii) Biological Characteristics. Wetland supports (check all that apply): Riparian buffer. Characteristics (type, average width): Vegetation type/percent cover. Explain: Habitat for: Federally Listed species. Explain findings: Fish/spawn areas. Explain findings: Other environmentally-sensitive species. Explain findings: Aquatic/wildlife diversity. Explain findings 3. Characteristics of all wetlands adjacent to the tributary (if any) All wetland(s) being considered in the cumulative analysis: 6 Approximately ( ) acres in total are being considered in the cumulative analysis. For each wetland, specify the following: Directly abuts? (Y/N) Size (in acres)

Explain:

Directly abuts? (Y/N)

Size (in acres)

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Summarize overall biological, chemical and physical functions being performed C. SIGNIFICANT NEXUS DETERMINATION A significant nexus analysis will assess the flow characteristics and functions of the tributary itself and the functions performed by any wetlands adjacent to the tributary to determine if they significantly affect the chemical, physical, and biological integrity of a TNW. For each of the following situations, a significant nexus exists if the tributary, in combination with all of its adjacent wetlands, has more than a speculative or insubstantial effect on the chemical, physical and/or biological integrity of a TNW. Considerations when evaluating significant nexus include, but are not limited to the volume, duration, and frequency of the flow of water in the tributary and its proximity to a TNW, and the functions performed by the tributary and all its adjacent wetlands. It is not appropriate to determine significant nexus based solely on any specific threshold of distance (e.g. between a tributary and its adjacent wetland or between a tributary and the TNW). Similarly, the fact an adjacent wetland lies within or outside of a floodplain is not solely determinative of significant nexus. Draw connections between the features documented and the effects on the TNW, as identified in the Rapanos Guidance and discussed in the Instructional Guidebook. Factors to consider include, for example: • Does the tributary, in combination with its adjacent wetlands (if any), have the capacity to carry pollutants or flood waters to TNWs, or to reduce the amount of pollutants or flood waters reaching a TNW? • Does the tributary, in combination with its adjacent wetlands (if any), provide habitat and lifecycle support functions for fish and other species, such as feeding, nesting, spawning, or rearing young for species that are present in the TNW? • Does the tributary, in combination with its adjacent wetlands (if any), have the capacity to transfer nutrients and organic carbon that support downstream foodwebs? • Does the tributary, in combination with its adjacent wetlands (if any), have other relationships to the physical, chemical, or biological integrity of the TNW? Note: the above list of considerations is not inclusive and other functions observed or known to occur should be documented below: 1. Significant nexus findings for non-RPW that has no adjacent wetlands and flows directly or indirectly into TNWs. Explain findings of presence or absence of significant nexus below, based on the tributary itself, then go to Section III.D: Significant nexus findings for non-RPW and its adjacent wetlands, where the non-RPW flows directly or indirectly into TNWs. Explain findings of presence or absence of significant nexus below, based on the tributary in combination with all of its adjacent wetlands, then go to Section III.D: Significant nexus findings for wetlands adjacent to an RPW but that do not directly abut the RPW. Explain findings of presence or absence of significant nexus below, based on the tributary in combination with all of its adjacent wetlands, then go to Section III.D

2.

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D. DETERMINATIONS OF JURISDICTIONAL FINDINGS. THE SUBJECT WATERS/WETLANDS ARE (CHECK ALL THAT APPLY): 1. TNWs and Adjacent Wetlands. Check all that apply and provide size estimates in review area: TNWs: linear feet width (ft), Or, acres. Wetlands adjacent to TNWs: acres. RPWs that flow directly or indirectly into TNWs. Tributaries of TNWs where tributaries typically flow year-round are jurisdictional. Provide data and rationale indicating that tributary is perennial: Mack Wash flows year around except in years of extreme drought. Tributaries of TNW where tributaries have continuous flow “seasonally” (e.g., typically three months each year) are jurisdictional. Data supporting this conclusion is provided at Section III.B. Provide rationale indicating that tributary flows seasonally: . Provide estimates for jurisdictional waters in the review area (check all that apply): Tributary waters: 800 linear feet 32 width (ft) This area starts just south the Hwy 6&50 bridge on Mack Wash and extends upstream approx. 800 feet (Figure 5 in report). Other non-wetland waters: 3. acres.

2.

Identify type(s) of waters: . Non-RPWs8 that flow directly or indirectly into TNWs. Waterbody that is not a TNW or an RPW, but flows directly or indirectly into a TNW, and it has a significant nexus with a TNW is jurisdictional. Data supporting this conclusion is provided at Section III.C. Provide estimates for jurisdictional waters within the review area (check all that apply): N/A Tributary waters: linear feet acres. . width (ft).

Other non-wetland waters: Identify type(s) of waters: 4.

Wetlands directly abutting an RPW that flow directly or indirectly into TNWs. Wetlands directly abut RPW and thus are jurisdictional as adjacent wetlands. Wetlands directly abutting an RPW where tributaries typically flow year-round. Provide data and rationale indicating that tributary is perennial in Section III.D.2, above. Provide rationale indicating that wetland is directly abutting an RPW: Mack Wash riparian fringe wetland. Wetlands directly abutting an RPW where tributaries typically flow “seasonally.” Provide data indicating that tributary is seasonal in Section III.B and rationale in Section III.D.2, above. Provide rationale indicating that wetland is directly abutting an RPW: . Provide acreage estimates for jurisdictional wetlands in the review area: 0.11 acres.

5.

Wetlands adjacent to but not directly abutting an RPW that flow directly or indirectly into TNWs. Wetlands that do not directly abut an RPW, but when considered in combination with the tributary to which they are adjacent and with similarly situated adjacent wetlands, have a significant nexus with a TNW are jurisidictional. Data supporting this conclusion is provided at Section III.C. Provide acreage estimates for jurisdictional wetlands in the review area: acres.

6.

Wetlands adjacent to non-RPWs that flow directly or indirectly into TNWs. Wetlands adjacent to such waters, and have when considered in combination with the tributary to which they are adjacent and with similarly situated adjacent wetlands, have a significant nexus with a TNW are jurisdictional. Data supporting this conclusion is provided at Section III.C. Provide estimates for jurisdictional wetlands in the review area: acres.

8

See Footnote # 3.

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7.

Impoundments of jurisdictional waters.9 As a general rule, the impoundment of a jurisdictional tributary remains jurisdictional. Demonstrate that impoundment was created from “waters of the U.S.,” or Demonstrate that water meets the criteria for one of the categories presented above (1-6), or Demonstrate that water is isolated with a nexus to commerce (see E below).

E. ISOLATED [INTERSTATE OR INTRA-STATE] WATERS, INCLUDING ISOLATED WETLANDS, THE USE, DEGRADATION OR DESTRUCTION OF WHICH COULD AFFECT INTERSTATE COMMERCE, INCLUDING ANY SUCH WATERS (CHECK ALL THAT APPLY):10 which are or could be used by interstate or foreign travelers for recreational or other purposes. from which fish or shellfish are or could be taken and sold in interstate or foreign commerce. which are or could be used for industrial purposes by industries in interstate commerce. Interstate isolated waters. Explain: . Other factors. Explain: . Identify water body and summarize rationale supporting determination: .

Provide estimates for jurisdictional waters in the review area (check all that apply): Tributary waters: linear feet acres. width (ft). Identify type(s) of waters: .

Other non-wetland waters: Wetlands: acres.

F. NON-JURISDICTIONAL WATERS, INCLUDING WETLANDS (CHECK ALL THAT APPLY): If potential wetlands were assessed within the review area, these areas did not meet the criteria in the 1987 Corps of Engineers Wetland Delineation Manual and/or appropriate Regional Supplements. Review area included isolated waters with no substantial nexus to interstate (or foreign) commerce. Prior to the Jan 2001 Supreme Court decision in “SWANCC,” the review area would have been regulated based solely on the “Migratory Bird Rule” (MBR). Waters do not meet the “Significant Nexus” standard, where such a finding is required for jurisdiction. Explain: Other: (explain, if not covered above): . Provide acreage estimates for non-jurisdictional waters in the review area, where the sole potential basis of jurisdiction is the MBR factors (i.e., presence of migratory birds, presence of endangered species, use of water for irrigated agriculture), using best professional judgment (check all that apply): Non-wetland waters (i.e., rivers, streams): linear feet width (ft). Lakes/ponds: acres. Other non-wetland waters: acres. List type of aquatic resource: Wetlands: acres.

.

Provide acreage estimates for non-jurisdictional waters in the review area that do not meet the “Significant Nexus” standard, where such a finding is required for jurisdiction (check all that apply): Non-wetland waters (i.e., rivers, streams): Lakes/ponds: acres. Other non-wetland waters: acres. List type of aquatic resource: Wetlands: acres.

.

9

10

To complete the analysis refer to the key in Section III.D.6 of the Instructional Guidebook. Prior to asserting or declining CWA jurisdiction based solely on this category, Corps Districts will elevate the action to Corps and EPA HQ for review consistent with the process described in the Corps/EPA Memorandum Regarding CWA Act Jurisdiction Following Rapanos.

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SECTION IV: DATA SOURCES. A. SUPPORTING DATA. Data reviewed for JD (check all that apply - checked items shall be included in case file and, where checked and requested, appropriately reference sources below): Maps, plans, plots or plat submitted by or on behalf of the applicant/consultant: WestWater Engineering. Data sheets prepared/submitted by or on behalf of the applicant/consultant. Office concurs with data sheets/delineation report. Office does not concur with data sheets/delineation report. Data sheets prepared by the Corps: . Corps navigable waters’ study: . U.S. Geological Survey Hydrologic Atlas: www-atlas.usgs.gov. USGS NHD data. USGS 8 and 12 digit HUC maps. U.S. Geological Survey map(s). Cite scale & quad name: USGS 1:24,000 Mack, CO., Ruby Canyon, CO., Badger Wash, CO., Highline Lake, CO., Howard Canyon, CO. USDA Natural Resources Conservation Service Soil Survey. Citation: http://websoilsurvey.nrcs.usda.gov/app/ National wetlands inventory map(s). Cite name: www.fws.gov/nwi/ State/Local wetland inventory map(s): . FEMA/FIRM maps: . 100-year Floodplain Elevation is: (National Geodectic Vertical Datum of 1929) Photographs: Aerial (Name & Date): USDA NAIP 2005. Other (Name & Date): WestWater Engineering, or Previous determination(s). File no. and date of response letter: . Applicable/supporting case law: Applicable/supporting scientific literature Other information (please specify): B. ADDITIONAL COMMENTS TO SUPPORT JD: .

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Jurisdictional Determination Form Request for Jurisdictional Determination Form 2b, Non-Jurisdictional Wetlands and Other Waters

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APPROVED JURISDICTIONAL DETERMINATION FORM U.S. Army Corps of Engineers This form should be completed by following the instructions provided in Section IV of the JD Form Instructional Guidebook. SECTION I: BACKGROUND INFORMATION A. REPORT COMPLETION DATE FOR APPROVED JURISDICTIONAL DETERMINATION (JD):

B. DISTRICT OFFICE, FILE NAME, AND NUMBER: C. PROJECT LOCATION AND BACKGROUND INFORMATION: CAM Colorado proposes to develop a coal mine facility on approximately 1,886 acres of Bureau of Land Management land at the Red Cliff Mine site in the southwest corner of Garfield County. Development of the mine will also require the construction of approximately 15 miles of rail line on public and private lands in Mesa County to transport coal from the mine facility to the Union Pacific Western Railroad south of Mack, Colorado. Based on maps of the proposed railroad right of way and the proposed mine facility provided by CAM Colorado, WestWater Biologists surveyed the approximately 2,450 acre project site and surrounding areas to identify and delineate potential wetlands and waters of the U.S.(WOUS) within and adjacent to proposed construction boundaries. At the request of the COE the project was divided into two parts: 1. Request for a Jurisdictional Determination identifying potential non-wetland WOUS. 2. Request for confirmation of Wetland Delineation and Jurisdictional Determination. Form 2a Jurisdictional wetlands and waters of the U.S. Form 2b Non-jurisdictional wetlands and other waters This form is part 2b, Non-Jurisdictional wetlands. State: CO County/parish/borough: Mesa City: Mack Center coordinates of site (lat/long in degree decimal format): Lat. 39.3183° N,Long. -108.8072° E. Universal Transverse Mercator: Name of nearest waterbody: Salt Creek and Mack Wash, RPWs Name of nearest Traditional Navigable Water (TNW) into which the aquatic resource flows: Colorado River Name of watershed or Hydrologic Unit Code (HUC): 14010005 Check if map/diagram of review area and/or potential jurisdictional areas is/are available upon request. Check if other sites (e.g., offsite mitigation sites, disposal sites, etc…) are associated with this action and are recorded on a different JD form. D. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT APPLY): Office (Desk) Determination. Date: Field Determination. Date(s): SECTION II: SUMMARY OF FINDINGS A. RHA SECTION 10 DETERMINATION OF JURISDICTION. There Are no “navigable waters of the U.S.” within Rivers and Harbors Act (RHA) jurisdiction (as defined by 33 CFR part 329) in the review area. [Required] Waters subject to the ebb and flow of the tide. Waters are presently used, or have been used in the past, or may be susceptible for use to transport interstate or foreign commerce. Explain: .

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B. CWA SECTION 404 DETERMINATION OF JURISDICTION. There Are no “waters of the U.S.” within Clean Water Act (CWA) jurisdiction (as defined by 33 CFR part 328) in the review area. [Required] 1. Waters of the U.S. a. Indicate presence of waters of U.S. in review area (check all that apply): 1 TNWs, including territorial seas Wetlands adjacent to TNWs Relatively permanent waters2 (RPWs) that flow directly or indirectly into TNWs Non-RPWs that flow directly or indirectly into TNWs Wetlands directly abutting RPWs that flow directly or indirectly into TNWs Wetlands adjacent to but not directly abutting RPWs that flow directly or indirectly into TNWs Wetlands adjacent to non-RPWs that flow directly or indirectly into TNWs Impoundments of jurisdictional waters Isolated (interstate or intrastate) waters, including isolated wetlands b. Identify (estimate) size of waters of the U.S. in the review area: Non-wetland waters: linear feet: width (ft) and/or Wetlands: acres.

acres.

c. Limits (boundaries) of jurisdiction based on: Interim Arid West Regional Supplement to the Corps of Engineers Wetland Delineation Manual, December 2006, 33 CFR Part 328.3, RGL 07-02, and CESPK-CO-R (1145) RBM 2007-01. Elevation of established OHWM (if known): . 2. Non-regulated waters/wetlands (check if applicable):3 Potentially jurisdictional waters and/or wetlands were assessed within the review area and determined to be not jurisdictional. Explain:

Waters are not currently used, or used in the past, and are not susceptible to use in interstate or for foreign commerce, nor are these waters subject to ebb and flow of tide. Artificially irrigated wetlands that would revert to uplands if irrigation would cease are not considered to be waters of the United States under section 404 of the Clean Water Act. (Sacramento RBM 2007-01) There is no information available to show that these ditches: 1) are or could be used by interstate or foreign travelers for recreational or other purposes, 2) produce fish or shellfish which are or could be taken and sold in interstate or foreign commerce, or 3) are or could be used for industrial purposes by industries in interstate commerce The hydrologic source associated with these wetlands is not considered a tributary because it is water allocated from the TNW, Colorado River, for the sole purpose of irrigation. Water in excess of that required for agricultural purposes in conveyed back to the TNW, Colorado River, as irrigation return flow. Irrigation canals are augmented by dry washes that flow only in times of intense short term precipitation events, these washes lack the ability to support wetland vegetation and have no indicators of hydric soils. There are no jurisdictional flows captured by the lateral ditches within the project area and aerial photos show distinct vegetative boundaries between irrigation canals, laterals, ditches, and the naturally arid salt desert environment. Wetlands established and maintained solely by artificial irrigation do not meet the definition of Waters of the U.S. under the criteria contained in the 1987 Corps of Engineers Wetlands Jurisdictional Manual or its regional supplements.

Boxes checked below shall be supported by completing the appropriate sections in Section III below. For purposes of this form, an RPW is defined as a tributary that is not a TNW and that typically flows year-round or has continuous flow at least “seasonally” (e.g., typically 3 months). 3 Supporting documentation is presented in Section III.F.
2

1

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SECTION III: CWA ANALYSIS A. TNWs AND WETLANDS ADJACENT TO TNWs The agencies will assert jurisdiction over TNWs and wetlands adjacent to TNWs. If the aquatic resource is a TNW, complete Section III.A.1 and Section III.D.1. only; if the aquatic resource is a wetland adjacent to a TNW, complete Sections III.A.1 and 2 and Section III.D.1.; otherwise, see Section III.B below. 1. TNW Identify TNW: . .

Summarize rationale supporting determination: 2.

Wetland adjacent to TNW Summarize rationale supporting conclusion that wetland is “adjacent”:

.

B. CHARACTERISTICS OF TRIBUTARY (THAT IS NOT A TNW) AND ITS ADJACENT WETLANDS (IF ANY): This section summarizes information regarding characteristics of the tributary and its adjacent wetlands, if any, and it helps determine whether or not the standards for jurisdiction established under Rapanos have been met. The agencies will assert jurisdiction over non-navigable tributaries of TNWs where the tributaries are “relatively permanent waters” (RPWs), i.e. tributaries that typically flow year-round or have continuous flow at least seasonally (e.g., typically 3 months). A wetland that directly abuts an RPW is also jurisdictional. If the aquatic resource is not a TNW, but has year-round (perennial) flow, skip to Section III.D.2. If the aquatic resource is a wetland directly abutting a tributary with perennial flow, skip to Section III.D.4. A wetland that is adjacent to but that does not directly abut an RPW requires a significant nexus evaluation. Corps districts and EPA regions will include in the record any available information that documents the existence of a significant nexus between a relatively permanent tributary that is not perennial (and its adjacent wetlands if any) and a traditional navigable water, even though a significant nexus finding is not required as a matter of law. If the waterbody4 is not an RPW, or a wetland directly abutting an RPW, a JD will require additional data to determine if the waterbody has a significant nexus with a TNW. If the tributary has adjacent wetlands, the significant nexus evaluation must consider the tributary in combination with all of its adjacent wetlands. This significant nexus evaluation that combines, for analytical purposes, the tributary and all of its adjacent wetlands is used whether the review area identified in the JD request is the tributary, or its adjacent wetlands, or both. If the JD covers a tributary with adjacent wetlands, complete Section III.B.1 for the tributary, Section III.B.2 for any onsite wetlands, and Section III.B.3 for all wetlands adjacent to that tributary, both onsite and offsite. The determination whether a significant nexus exists is determined in Section III.C below. 1. Characteristics of non-TNWs that flow directly or indirectly into TNW washes are (i) General Area Conditions: Watershed size: 436 square miles Drainage area: 225 square miles Average annual rainfall: 7.34 inches Average annual snowfall: 9.8 inches

Note that the Instructional Guidebook contains additional information regarding swales, ditches, washes, and erosional features generally and in the arid West.

4

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(ii) Physical Characteristics: (a) Relationship with TNW: Tributary flows directly into TNW. Tributary flows through Pick List tributaries before entering TNW. Irrigation ditches are not generally considered tributaries. These ditches are subdivided into numerous lateral ditches and piped sections that distribute water to agricultural fields. Multiple return ditches combine to collect and distribute waters to down gradient agricultural fields. The ditches eventually return irrigation water into an RPW (Mack Wash, East Salt Creek). Project waters are 3-5 river miles from TNW. Project waters are 0-1 river miles from RPW. Project waters are 2-3 (straight) miles from TNW. Project waters are 1 (or less) (straight) miles from RPW. Project waters cross or serve as state boundaries. Explain: N/A Identify flow route to TNW5: Flow into the Grand Valley Canal is diverted from the Colorado River east of Grand Junction in Palisade, CO. The canal flows west through the City of Grand Junction distributing irrigation water to lateral ditches. Between 12 and 13 Road the canal turns south, crosses underneath Highway 6&50 (Highway 6&50 is also known as M and 8/10 Road in this part of Mesa County), continues south and returns flow to the Colorado River near 13 Road. The projects area of concern is the Mack Lateral Ditch south of the Highway 6&50 crossing. The Mack Lateral conveys water from the canal, via underground pipe, approximately 1.5 miles east to the town of Mack and its associated agricultural lands. The section of the Mack lateral that is piped ends at the Interstate-70 exit to the Town of Mack and is open ditch from there on. The lateral meanders around the southern portion of Mack just west of 10 Road where it turns north. The lateral splits into 2 main irrigation ditches. One ditch feeds 2 small agricultural ponds, crosses under the railroad tracks and turns west eventually flowing into to Mack Wash approximately 1.5 miles downstream of the Highway 6&50 bridge. The other ditch continues north, crosses under the railroad tracks and divides into 2 smaller ditches. One of the smaller ditches flows north under Highway 6&50 and into Mack Wash. The other ditch is diverted to the west paralleling Highway 6&50 and ends up flowing through underground corrugated plastic pipe into Mack Wash, just south of the Highway 6&50 bridge. From the Highway 6&50 bridge, Mack Wash flows southwest into Salt Creek, which flows into the Colorado River (Figure 5). The proposed rail alignment crosses the Government Highline Canal, which is another main irrigation canal in the Grand Valley. Government Highline Canal originates just north of the Grand Valley Canal from the Colorado River in Palisade, CO. The canal parallels the Grand Valley Canal to the north until the Grand Valley Canal turns south near 13 Road. Government Highline Canal continues west distributing irrigation water to lateral ditches north and west of Mack. The canal terminates at West Salt Creek. West Salt Creek flows into Salt Creek, which flows into the Colorado River. Tributary stream order, if known: Mack Wash, East Salt Creek, and West Salt Creek are a 1, Salt Creek is a 2. (b) General Tributary Characteristics (check all that apply): Natural Tributary is: Artificial (man-made). Explain: Government Highline Canal, Mack Lateral, and connected irrigation ditches are all created in uplands. Manipulated (man-altered). Explain: Tributary properties with respect to top of bank (estimate): Average width: 3 feet open ditch portion of Mack lateral Average depth: 3 feet Average side slopes: 2:1 Return ditches are considerably smaller, with an average width and depth of 1 foot or less. Government Highline Canal is approximately 35 feet wide and 7 feet deep.

Flow route can be described by identifying, e.g., tributary a, which flows through the review area, to flow into tributary b, which then flows into TNW.

5

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Primary tributary substrate composition (check all that apply): Silts Sands Concrete Cobbles Gravel Muck Bedrock Vegetation. Type/% cover: 0-100% Other. Explain: Portions of the Highline canal, Mack lateral, and subsequent ditches are lined with concrete, rip-rap, and flow through culverts and piping made of various materials. Tributary condition/stability [e.g., highly eroding, sloughing banks]. Explain: Ditch leakage and seepage is evident in some areas. Approximately 57 miles of Government Highline Canal have been lined with polyacrylamide (PAM) and other substances to reduce transit loss and improve bank stability (BOR. 1986). Presence of run/riffle/pool complexes. Explain: N/A Tributary geometry: Determined by irrigation requirements. Tributary gradient (approximate average slope): 2 % or less (c) Flow: Tributary provides for: Seasonal irrigation Estimate average number of flow events in review area/year: Typically flows from May through October. Other information on duration and volume: Flow into the Mack Lateral from the Grand Valley Canal is approximately 5 cfs during irrigation season. Surface flow is: Discrete and confined Characteristics: Discrete flows are present where ditch leakage has persisted. Subsurface flow: perched watertable Explain findings: Lined portions of the Grand Valley Canal have a transit loss of approximately 1cfs. per canal mile. Unlined ditches and laterals, depending on substrate and sediment load have losses of up to 2 cubic feet per square foot of ditch area per day (BOR 1986). Over a century of agricultural irrigation in the Grand Valley has caused a shallow perched water table to develop. Water infiltrates weathered fractures in the Mancos shale and is leached to impermeable layer of shale. (BOR 1986 & 1977. The impermeable shale can be just a few feet from the ground surface or up to 30 feet below the ground surface (BOR 1985 & 1977). Ground water is derived almost entirely from deep percolation of irrigation water and seepage from irrigation systems. Natural ground water recharge is less than 1% of the recharge occurring in the Grand Valley (BOR 1977 & 1985). The perched water table in the Grand Valley would be non existent without irrigation (BOR 1977). Dye (or other) test performed: Numerous studies have been conducted by the Bureau of Reclamation and NRCS in conjunction with the Grand Valley Unit Colorado River Salinity Project. The focus of the investigation was to determine salinity transport capability of the perched water table and if lining canals and ditches would reduce the salinity load in the Colorado River (BOR 1977, 1985, 1986). A system of monitoring wells was installed and long-term water table investigations were conducted. Tributary has (check all that apply): Bed and banks OHWM6 (check all indicators that apply): clear, natural line impressed on the bank changes in the character of soil shelving vegetation matted down, bent, or absent leaf litter disturbed or washed away sediment deposition

the presence of litter and debris destruction of terrestrial vegetation the presence of wrack line sediment sorting scour multiple observed or predicted flow

6 A natural or man-made discontinuity in the OHWM does not necessarily sever jurisdiction (e.g., where the stream temporarily flows underground, or where the OHWM has been removed by development or agricultural practices). Where there is a break in the OHWM that is unrelated to the waterbody’s flow regime (e.g., flow over a rock outcrop or through a culvert), the agencies will look for indicators of flow above and below the break.

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water staining other (list): Discontinuous OHWM.7 Explain:

events abrupt change in plant community

If factors other than the OHWM were used to determine lateral extent of CWA jurisdiction (check all that apply): High Tide Line indicated by: Mean High Water Mark indicated by: oil or scum line along shore objects survey to available datum; fine shell or debris deposits (foreshore) physical markings; physical markings/characteristics vegetation lines/changes in vegetation types. tidal gauges other (list): 1987 Corps of Engineers Wetland Delineation Manual, Interim Arid West Regional Supplement to the Corps of Engineers Wetland Delineation Manual, December 2006, 33 CFR Part 328.3, RGL 07-02, and CESPK-CO-R (1145) RBM 2007-01. (iii) Chemical Characteristics: Characterize tributary (e.g., water color is clear, discolored, oily film; water quality; general watershed characteristics, etc.). Explain: Water flowing through irrigation ditches is mostly clear. Natural salinity from salt-shrub desert soils and selenium from Mancos shale is expected. Irrigation return flows are also assumed to contain fertilizers and herbicides (not tested). Identify specific pollutants, if known:

.

(iv) Biological Characteristics. Channel supports (check all that apply): Riparian corridor. Characteristics (type, average width): . Wetland fringe. Characteristics: . Habitat for: Federally Listed species. Explain findings: . Fish/spawn areas. Explain findings: . Other environmentally-sensitive species. Explain findings: Aquatic/wildlife diversity. Explain findings: The habitat supports common amphibians and incidental use by terrestrial species that are characteristic of the salt desert shrub community (BOR 1976). 2. Characteristics of wetlands adjacent to non-TNW that flow directly or indirectly into TNW (i) Physical Characteristics: (a) General Wetland Characteristics: Properties: Wetland size: 15.97 acres Total for 18 polygons Wetland type. Explain: Fringe wetlands along ditches and Marsh wetlands associated with ditch leakage. Wetland quality. Explain: Wetland conditions are marginal. Annual changes in irrigation water allocation and urban expantion to agricultural land have created an inconsistent runoff regime. De-watered wetlands are common and ditch leakage has created wetlands in undesirable locations. Project wetlands cross or serve as state boundaries. Explain: N/A (b) General Flow Relationship with Non-TNW: Flow is: Seasonal. Explain: Typically surface flows are associated with irrigation season or extreme precipitation events in early spring and late fall (BOR 1977 & 1986). Surface flow is: Discrete and Confined Characteristics: Surface flows primarily come from irrigation return water ditches; discrete flows are associated with leaky portions of the ditches (BOR 1976, 1977 & 1985). Subsurface flow: Yes. Explain findings: Polygons A, H, M, K, and O have hydrology associated
7

Ibid.

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with the discharge of a shallow perched aquifer that supplies ground water to portions of these wetlands throughout most of the growing season. Ground water in this perched aquifer is derived almost entirely from deep percolation of irrigation water and seepage from irrigation systems. Natural ground water recharge is less than 1% of the recharge occurring in the Grand Valley (BOR 1977 & 1985). The perched water table in the Grand Valley would be non existent without irrigation (BOR 1977). Dye (or other) test performed: Numerous studies have been conducted by the Bureau of Reclamation and NRCS in conjunction with the Grand Valley Unit Colorado River Salinity Project. The focus of the investigation was to determine salinity transport capability of the perched water table and if lining canals and ditches would reduce the salinity load in the Colorado River (BOR 1977, 1985, 1986). A system of monitoring wells was installed and long-term water table investigations were conducted. (c) Wetland Adjacency Determination with Non-TNW: Directly abutting: Irrigation ditches Not directly abutting Discrete wetland hydrologic connection. Explain: Polygons A, H, M, and O receive irrigation return flow from elevated agricultural lands east of 10 Road (Figure 3). During irrigation season excess water is spilled off into small channels that form a periodic surface water connection with East Salt Creek. Polygon A receives water from an adjacent agricultural field and returns flow to Mack Wash (Figure 4). Polygon L has been de-watered from changes in upslope irrigation; flow lines in Figure 3 show historical flow paths when return flows were present. Ecological connection. Explain: . Separated by berm/barrier. Explain: Portions of the ditches have been impounded to raise water levels to allow for extended delivery area. Ditches conveying impounded waters are sometimes elevated 4 feet above the existing topography. (d) Proximity (Relationship) to TNW Project wetlands are 2-5 river miles from TNW. Project waters are 2-3 aerial (straight) miles from TNW. Flow is from: TNW to irrigation ditches to RPW and returned to TNW. Estimate approximate location of wetland as within the floodplain. N/A (ii) Chemical Characteristics: Characterize wetland system (e.g., water color is clear, brown, oil film on surface; water quality; general watershed characteristics; etc.). Explain: Water flowing from wetlands is mostly clear. Natural salinity from salt-shrub desert and selenium transport from Mancos shale is expected. Irrigation runoff is assumed to include fertilizers and herbicides (not tested). Identify specific pollutants, if known: .

(iii) Biological Characteristics. Wetland supports (check all that apply): Riparian buffer. Characteristics (type, average width): Vegetation type/percent cover. Explain: Habitat for: Federally Listed species. Explain findings: Fish/spawn areas. Explain findings: Other environmentally-sensitive species. Explain findings: Aquatic/wildlife diversity. Explain findings: The habitat supports common amphibians and incidental use by terrestrial species that are characteristic of the salt desert shrub community. Active Northern Harrier Hawk nests were found in polygons A and H, and mule deer were frequently observed in these areas as well. Irrigation water has created wildlife habitat which differs considerably from the habitat occurring historically (BOR 1985).

3.

Characteristics of all wetlands adjacent to the tributary (if any)

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All wetland(s) being considered in the cumulative analysis: 18 Approximately (15.97) acres in total are being considered in the cumulative analysis. For each wetland, specify the following: Polygons A, B, C, D, E, F, G, H, K, L, M, O, P, Q, R, S, T and V, are potentially non-jurisdictional wetland polygons. Their sole source of hydrology is irrigation water. They maintain a surface water connection with the nearest RPW only by irrigation return flows. Directly abuts? (Y/N) Size (in acres) A, No 0.40 B, Yes 0.26 C, Yes 0.6 D, No 0.0001 E, No 0.013 F, Yes 0.023 G, Yes 0.01 H, No 10.85 K, No 0.166 Directly abuts? (Y/N) L, No M, No O, No P, Yes Q, Yes R, Yes S, Yes T, Yes V, Yes Size (in acres) 1.45 0.077 0.008 0.1 0.38 1.09 0.49 0.03 0.035

** No, indicates the wetlands are not adjacent or abutting an irrigation ditch ***Yes, indicates the wetlands are adjacent or abutting an irrigation ditch Summarize overall biological, chemical and physical functions being performed: Potential wetlands evaluated in this jurisdictional determination are associated with irrigation ditches, seepage, and irrigation return flows. Wetland characteristics and vegetation are a direct result of irrigation water, without this source of hydrology these wetlands would cease to exist. Although these wetlands are relatively low in quality and diversity, they do perform some wetland functions. These areas may serve as migratory bird habitat. Irrigation ditch fringe wetlands that lack open water serve as limited habitat for most birds. Some predator species have been observed in the area including: Golden Eagle, Red-tailed Hawk, and Northern Harrier Hawk. Wetlands are subject to use by terrestrial species that are characteristic of the salt desert shrub community, particularly mule deer. Irrigation ditches may also provide a filtration and storage capacity for agriculturally related chemicals. Groundwater recharge and creation of the perched water table can be viewed as a potential negative function as it mobilizes selenium and salinity that will be eventually transported into the Colorado River (TNW). C. SIGNIFICANT NEXUS DETERMINATION A significant nexus analysis will assess the flow characteristics and functions of the tributary itself and the functions performed by any wetlands adjacent to the tributary to determine if they significantly affect the chemical, physical, and biological integrity of a TNW. For each of the following situations, a significant nexus exists if the tributary, in combination with all of its adjacent wetlands, has more than a speculative or insubstantial effect on the chemical, physical and/or biological integrity of a TNW. Considerations when evaluating significant nexus include, but are not limited to the volume, duration, and frequency of the flow of water in the tributary and its proximity to a TNW, and the functions performed by the tributary and all its adjacent wetlands. It is not appropriate to determine significant nexus based solely on any specific threshold of distance (e.g. between a tributary and its adjacent wetland or between a tributary and the TNW). Similarly, the fact an adjacent wetland lies within or outside of a floodplain is not solely determinative of significant nexus. Draw connections between the features documented and the effects on the TNW, as identified in the Rapanos Guidance and discussed in the Instructional Guidebook. Factors to consider include, for example: • Does the tributary, in combination with its adjacent wetlands (if any), have the capacity to carry pollutants or flood waters to TNWs, or to reduce the amount of pollutants or flood waters reaching a TNW? • Does the tributary, in combination with its adjacent wetlands (if any), provide habitat and lifecycle support functions for fish and other species, such as feeding, nesting, spawning, or rearing young for species that are present in the TNW? • Does the tributary, in combination with its adjacent wetlands (if any), have the capacity to transfer nutrients and organic carbon that support downstream foodwebs?

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• Does the tributary, in combination with its adjacent wetlands (if any), have other relationships to the physical, chemical, or biological integrity of the TNW? Note: the above list of considerations is not inclusive and other functions observed or known to occur should be documented below: 1. Significant nexus findings for non-RPW that has no adjacent wetlands and flows directly or indirectly into TNWs. Explain findings of presence or absence of significant nexus below, based on the tributary itself, then go to Section III.D: 2. Significant nexus findings for non-RPW and its adjacent wetlands, where the non-RPW flows directly or indirectly into TNWs. Explain findings of presence or absence of significant nexus below, based on the tributary in combination with all of its adjacent wetlands, then go to Section III.D: Based on the information provided in Section III, B-1, B-2, and B-3 above, the wetlands within the proposed project impact area were found to be the direct result of irrigation water return flows and not from natural hydrology. Waters associated with these areas are unlikely to meet the definition of a WOUS as presented in Section 404 of the Clean Water Act. Irrigation ditches and their associated wetlands within the proposed project impact area are likely to have no more than an insignificant and speculative impact on the physical, chemical, and biological integrity of the downstream TNW (Colorado River) or its RPW tributaries (Mack Wash and East Salt Creek). 3. Significant nexus findings for wetlands adjacent to an RPW but that do not directly abut the RPW. Explain findings of presence or absence of significant nexus below, based on the tributary in combination with all of its adjacent wetlands, then go to Section III.D: . D. DETERMINATIONS OF JURISDICTIONAL FINDINGS. THE SUBJECT WATERS/WETLANDS ARE (CHECK ALL THAT APPLY): 1. TNWs and Adjacent Wetlands. Check all that apply and provide size estimates in review area: TNWs: linear feet width (ft), Or, acres. Wetlands adjacent to TNWs: acres. RPWs that flow directly or indirectly into TNWs. Tributaries of TNWs where tributaries typically flow year-round are jurisdictional. Provide data and rationale indicating that tributary is perennial: Tributaries of TNW where tributaries have continuous flow “seasonally” (e.g., typically three months each year) are jurisdictional. Data supporting this conclusion is provided at Section III.B. Provide rationale indicating that tributary flows seasonally: . Provide estimates for jurisdictional waters in the review area (check all that apply): Tributary waters: linear feet acres. width (ft).

2.

Other non-wetland waters:

3.

Identify type(s) of waters: . 8 Non-RPWs that flow directly or indirectly into TNWs. Waterbody that is not a TNW or an RPW, but flows directly or indirectly into a TNW, and it has a significant nexus with a TNW is jurisdictional. Data supporting this conclusion is provided at Section III.C.

Provide estimates for jurisdictional waters within the review area (check all that apply):
8

See Footnote # 3.

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Tributary waters:

linear feet acres. .

width (ft).

Other non-wetland waters: Identify type(s) of waters: 4.

Wetlands directly abutting an RPW that flow directly or indirectly into TNWs. Wetlands directly abut RPW and thus are jurisdictional as adjacent wetlands. Wetlands directly abutting an RPW where tributaries typically flow year-round. Provide data and rationale indicating that tributary is perennial in Section III.D.2, above. Provide rationale indicating that wetland is directly abutting an RPW: Wetlands directly abutting an RPW where tributaries typically flow “seasonally.” Provide data indicating that tributary is seasonal in Section III.B and rationale in Section III.D.2, above. Provide rationale indicating that wetland is directly abutting an RPW: . Provide acreage estimates for jurisdictional wetlands in the review area: acres.

5.

Wetlands adjacent to but not directly abutting an RPW that flow directly or indirectly into TNWs. Wetlands that do not directly abut an RPW, but when considered in combination with the tributary to which they are adjacent and with similarly situated adjacent wetlands, have a significant nexus with a TNW are jurisidictional. Data supporting this conclusion is provided at Section III.C. Provide acreage estimates for jurisdictional wetlands in the review area: acres.

6.

Wetlands adjacent to non-RPWs that flow directly or indirectly into TNWs. Wetlands adjacent to such waters, and have when considered in combination with the tributary to which they are adjacent and with similarly situated adjacent wetlands, have a significant nexus with a TNW are jurisdictional. Data supporting this conclusion is provided at Section III.C. Provide estimates for jurisdictional wetlands in the review area: acres. Impoundments of jurisdictional waters.9 As a general rule, the impoundment of a jurisdictional tributary remains jurisdictional. Demonstrate that impoundment was created from “waters of the U.S.,” or Demonstrate that water meets the criteria for one of the categories presented above (1-6), or Demonstrate that water is isolated with a nexus to commerce (see E below).

7.

E. ISOLATED [INTERSTATE OR INTRA-STATE] WATERS, INCLUDING ISOLATED WETLANDS, THE USE, DEGRADATION OR DESTRUCTION OF WHICH COULD AFFECT INTERSTATE COMMERCE, INCLUDING ANY SUCH WATERS (CHECK ALL THAT APPLY):10 which are or could be used by interstate or foreign travelers for recreational or other purposes. from which fish or shellfish are or could be taken and sold in interstate or foreign commerce. which are or could be used for industrial purposes by industries in interstate commerce. Interstate isolated waters. Explain: . Other factors. Explain: .

Identify water body and summarize rationale supporting determination:

.

9

10

To complete the analysis refer to the key in Section III.D.6 of the Instructional Guidebook. Prior to asserting or declining CWA jurisdiction based solely on this category, Corps Districts will elevate the action to Corps and EPA HQ for review consistent with the process described in the Corps/EPA Memorandum Regarding CWA Act Jurisdiction Following Rapanos.

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Provide estimates for jurisdictional waters in the review area (check all that apply): Tributary waters: linear feet acres. . width (ft).

Other non-wetland waters: Identify type(s) of waters: Wetlands: acres.

F. NON-JURISDICTIONAL WATERS, INCLUDING WETLANDS (CHECK ALL THAT APPLY): If potential wetlands were assessed within the review area, these areas did not meet the criteria in the 1987 Corps of Engineers Wetland Delineation Manual and/or appropriate Regional Supplements. Wetlands established and maintained solely by artificial irrigation do not meet the definition of a wetland under the criteria contained in the 1987 Corps of Engineers Wetlands Jurisdictional Manual or its regional supplements (COE 2007a & d) Review area included isolated waters with no substantial nexus to interstate (or foreign) commerce. Prior to the Jan 2001 Supreme Court decision in “SWANCC,” the review area would have been regulated based solely on the “Migratory Bird Rule” (MBR). Waters do not meet the “Significant Nexus” standard, where such a finding is required for jurisdiction. Explain: Waters within the proposed project impact area are likely to have no more than an insignificant and speculative impact on the physical, chemical, and biological integrity of the down stream TNW (Colorado River) or its RPW tributaries. Other: (explain, if not covered above): Provide acreage estimates for non-jurisdictional waters in the review area, where the sole potential basis of jurisdiction is the MBR factors (i.e., presence of migratory birds, presence of endangered species, use of water for irrigated agriculture), using best professional judgment (check all that apply): Non-wetland waters (i.e., rivers, streams): linear feet width (ft). Lakes/ponds: 0.5 acres. Approximate acreage of impounded irrigation water creating ponds. Other non-wetland waters: 0.94 acres. List type of aquatic resource: Irrigation ditch and canal surface water area. Wetlands: 3.01 acres. Wetlands adjacent or abutting irrigation ditches. 12.96 acres not adjacent or abutting irrigation ditches. Provide acreage estimates for non-jurisdictional waters in the review area that do not meet the “Significant Nexus” standard, where such a finding is required for jurisdiction (check all that apply): Non-wetland waters (i.e., rivers, streams): Lakes/ponds: 0.5 acres. Approximate acreage of impounded irrigation water creating ponds. Other non-wetland waters: .94 acres. List type of aquatic resource: Irrigation ditch and canal surface water area. Wetlands: 15.97 acres. Wetlands adjacent or abutting irrigation ditches that are likely to have no more than an insignificant and speculative impact on the physical, chemical, and biological integrity of the down stream TNW (Colorado River) or its RPW tributaries.

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SECTION IV: DATA SOURCES. A. SUPPORTING DATA. Data reviewed for JD (check all that apply - checked items shall be included in case file and, where checked and requested, appropriately reference sources below): Maps, plans, plots or plat submitted by or on behalf of the applicant/consultant: WestWater Engineering. Data sheets prepared/submitted by or on behalf of the applicant/consultant. Office concurs with data sheets/delineation report. Office does not concur with data sheets/delineation report. Data sheets prepared by the Corps: . Corps navigable waters’ study: . U.S. Geological Survey Hydrologic Atlas: www-atlas.usgs.gov. USGS NHD data. USGS 8 and 12 digit HUC maps. U.S. Geological Survey map(s). Cite scale & quad name: USGS 1:24,000 Mack, CO., Ruby Canyon, CO., Badger Wash, CO., Highline Lake, CO., Howard Canyon, CO. USDA Natural Resources Conservation Service Soil Survey. Citation: http://websoilsurvey.nrcs.usda.gov/app/ National wetlands inventory map(s). Cite name: www.fws.gov/nwi/ State/Local wetland inventory map(s): . FEMA/FIRM maps: . 100-year Floodplain Elevation is: (National Geodectic Vertical Datum of 1929) Photographs: Aerial (Name & Date): USDA NAIP 2005. Other (Name & Date): WestWater Engineering, or Previous determination(s). File no. and date of response letter: . Applicable/supporting case law: Rapanos. Applicable/supporting scientific literature: Colorado River Basin Salinity Control Project and associated studies, and Groundwater well data logs from the Bureau of Reclamation and NRCS. Other information (please specify): RGL 07-02, Sacramento district RBM 07-01, 33 CFR Part 328.3, Section 404 CWA B. ADDITIONAL COMMENTS TO SUPPORT JD: .

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Appendix A COE Data Forms

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WETLAND DETERMINATION DATA FORM - Arid West Region
Project/Site: Red

Cliff Mine

City/County:Mesa State:CO Section, Township, Range:

Sampling Date:8/17/06 Sampling Point:TPU

Colorado LLC Investigator(s): WestWater Engineering Renner/Fletcher
Landform (hillslope, terrace, etc.): Terrace Subregion (LRR):D - Interior Deserts Soil Map Unit Name: Avalon

Applicant/Owner: CAM

Section 34, T9S, R103W
Slope (%):<2% Datum: NAD83

Local relief (concave, convex, none): None Lat: 39.22614 N Long: 108.87230 W NWI classification:N/A No (If no, explain in Remarks.)

Are climatic / hydrologic conditions on the site typical for this time of year? Yes Are Vegetation Are Vegetation Soil Soil
or Hydrology or Hydrology

significantly disturbed? naturally problematic?

Are "Normal Circumstances" present? Yes (If needed, explain any answers in Remarks.)

No

SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Hydric Soil Present? Wetland Hydrology Present? Remarks: Yes Yes Yes No No No Is the Sampled Area within a Wetland? Yes No

VEGETATION
Tree Stratum 1. 2. 3. 4. Sapling/Shrub Stratum % (Use scientific names.) Absolute % Cover Dominant Indicator Species? Status Dominance Test worksheet: Number of Dominant Species That Are OBL, FACW, or FAC: Total Number of Dominant Species Across All Strata: Percent of Dominant Species That Are OBL, FACW, or FAC:

1 3 33.3
%

(A)

(B)

(A/B)

Sarcobatus vermiculatus 2. Chrysothamnus nauseosus
1. 3. 4. 5. Total Cover: Herb Stratum 1.Muhlenbergia 2. 3. 4. 5. 6. 7. 8. Total Cover: Woody Vine Stratum 1. 2. Total Cover: % Bare Ground in Herb Stratum Remarks: %

30 20

Yes Yes

FACU UPL

Prevalence Index worksheet: Total % Cover of: OBL species FACW species FAC species Multiply by: x1= x2= x3= x4= x5= (A) (B)

50 50

%

FACU species UPL species

asperifolia

Yes

FACW

Column Totals:

Prevalence Index = B/A = Hydrophytic Vegetation Indicators: Dominance Test is >50% Prevalence Index is ≤3.01 Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet) Problematic Hydrophytic Vegetation1 (Explain)

50

%
1

Indicators of hydric soil and wetland hydrology must be present.

% %

% Cover of Biotic Crust

Hydrophytic Vegetation Present?

Yes

No

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SOIL
Depth (inches) Matrix Color (moist) Redox Features Color (moist) % Type 1

Sampling Point: TPU

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) % Loc 2 Texture 3 Silt Silt Silt Remarks

0-6 6-12 12-18

10 YR 6/4 10 YR 6/3 10 YR 6/4

90 90 90

1 3

2 Type: C=Concentration, D=Depletion, RM=Reduced Matrix. Location: PL=Pore Lining, RC=Root Channel, M=Matrix. Soil Textures: Clay, Silty Clay, Sandy Clay, Loam, Sandy Clay Loam, Sandy Loam, Clay Loam, Silty Clay Loam, Silt Loam, Silt, Loamy Sand, Sand.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.)

Indicators for Problematic Hydric Soils:

4

Histosol (A1) Histic Epipedon (A2) Black Histic (A3) Hydrogen Sulfide (A4) Stratified Layers (A5) (LRR C) 1 cm Muck (A9) (LRR D) Depleted Below Dark Surface (A11) Thick Dark Surface (A12) Sandy Mucky Mineral (S1) Sandy Gleyed Matrix (S4) Restrictive Layer (if present): Type: Depth (inches): Remarks:

Sandy Redox (S5)

Stripped Matrix (S6) Loamy Mucky Mineral (F1) Loamy Gleyed Matrix (F2) Depleted Matrix (F3) Redox Dark Surface (F6) Depleted Dark Surface (F7) Redox Depressions (F8) Vernal Pools (F9)

1 cm Muck (A9) (LRR C) 2 cm Muck (A10) (LRR B) Reduced Vertic (F18) Red Parent Material (TF2) Other (Explain in Remarks)

4

Indicators of hydrophytic vegetation and wetland hydrology must be present.

Hydric Soil Present?

Yes

No

HYDROLOGY
Wetland Hydrology Indicators: Primary Indicators (any one indicator is sufficient) Surface Water (A1) High Water Table (A2) Saturation (A3) Water Marks (B1) (Nonriverine) Sediment Deposits (B2) (Nonriverine) Drift Deposits (B3) (Nonriverine) Surface Soil Cracks (B6) Inundation Visible on Aerial Imagery (B7) Water-Stained Leaves (B9) Field Observations: Surface Water Present? Water Table Present? Yes Yes No No Depth (inches): Depth (inches): Yes No Salt Crust (B11) Biotic Crust (B12) Aquatic Invertebrates (B13) Hydrogen Sulfide Odor (C1) Oxidized Rhizospheres along Living Roots (C3) Presence of Reduced Iron (C4) Recent Iron Reduction in Plowed Soils (C6) Other (Explain in Remarks) Secondary Indicators (2 or more required) Water Marks (B1) (Riverine) Sediment Deposits (B2) (Riverine) Drift Deposits (B3) (Riverine) Drainage Patterns (B10) Dry-Season Water Table (C2) Thin Muck Surface (C7) Crayfish Burrows (C8) Saturation Visible on Aerial Imagery (C9) Shallow Aquitard (D3) FAC-Neutral Test (D5)

Saturation Present? Depth (inches): Yes No Wetland Hydrology Present? (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available: Remarks:

US Army Corps of Engineers WestWater Engineering Page 57 of 75 Arid West - Version 11-1-2006 January 2008

WETLAND DETERMINATION DATA FORM - Arid West Region
Project/Site: Red

Cliff Mine

City/County:Mesa State:CO Section, Township, Range:

Sampling Date:6/21/06 Sampling Point:TLW

Colorado LLC Investigator(s): WestWater Engineering Renner/Fletcher
Landform (hillslope, terrace, etc.): Terrace Subregion (LRR):D - Interior Deserts Soil Map Unit Name: Cojam

Applicant/Owner: CAM

Section 22, T9S, R103W
Slope (%):<2% Datum: NAD83

Local relief (concave, convex, none): None Lat: 39.26371 N Long: 108.87071 W NWI classification:N/A No (If no, explain in Remarks.)

Are climatic / hydrologic conditions on the site typical for this time of year? Yes Are Vegetation Are Vegetation Soil Soil
or Hydrology or Hydrology

significantly disturbed? naturally problematic?

Are "Normal Circumstances" present? Yes (If needed, explain any answers in Remarks.)

No

SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Hydric Soil Present? Wetland Hydrology Present? Remarks:This Yes Yes Yes No No No Is the Sampled Area within a Wetland? Yes No

area has apparently been de-watered by a change in upslope irrigation practices. Soils are dry and hydrophytic vegetation is dying.

VEGETATION
Tree Stratum 1. 2. 3. 4. Sapling/Shrub Stratum 1.Tamarix 2. 3. 4. 5. Total Cover: Herb Stratum 1.Typha 3. 4. 5. 6. 7. 8. Total Cover: Woody Vine Stratum 1. 2. Total Cover: % Bare Ground in Herb Stratum Remarks: % % % % (Use scientific names.) Absolute % Cover Dominant Indicator Species? Status Dominance Test worksheet: Number of Dominant Species That Are OBL, FACW, or FAC: Total Number of Dominant Species Across All Strata: Percent of Dominant Species That Are OBL, FACW, or FAC:

3 3 100.0 %
Multiply by:

(A)

(B)

(A/B)

spp.

30

Yes

FACW

Prevalence Index worksheet: Total % Cover of: OBL species FACW species FAC species x1= x2= x3= x4= x5= (A) (B)

30 30 10

%

FACU species UPL species

latifolia 2.Scirpus pungens

Yes Yes

OBL OBL

Column Totals:

Prevalence Index = B/A = Hydrophytic Vegetation Indicators: Dominance Test is >50% Prevalence Index is ≤3.01 Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet) Problematic Hydrophytic Vegetation1 (Explain)

40

%
1

Indicators of hydric soil and wetland hydrology must be present.

% Cover of Biotic Crust

Hydrophytic Vegetation Present?

Yes

No

Condition of vegetation was marginal, most of the basil cover was dead or wilting from lack of water. It is likely that the primary source of hydrology was from irrigation return flows that have been redirected up slope and no longer contribute to the area. There was no evidence of a ground water source.

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SOIL
Depth (inches) Matrix Color (moist) Redox Features Color (moist) % Type 1

Sampling Point: TLW

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) % Loc 2 Texture 3 Silty loam Silty loam Silty loam Remarks

0-6 6-12 12-18

10 YR 5/2 10 YR 5/3 10 YR 5/3

90 90 90

oxidation mottles

1 3

2 Type: C=Concentration, D=Depletion, RM=Reduced Matrix. Location: PL=Pore Lining, RC=Root Channel, M=Matrix. Soil Textures: Clay, Silty Clay, Sandy Clay, Loam, Sandy Clay Loam, Sandy Loam, Clay Loam, Silty Clay Loam, Silt Loam, Silt, Loamy Sand, Sand.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.)

Indicators for Problematic Hydric Soils:

4

Histosol (A1) Histic Epipedon (A2) Black Histic (A3) Hydrogen Sulfide (A4) Stratified Layers (A5) (LRR C) 1 cm Muck (A9) (LRR D) Depleted Below Dark Surface (A11) Thick Dark Surface (A12) Sandy Mucky Mineral (S1) Sandy Gleyed Matrix (S4) Restrictive Layer (if present): Type: Depth (inches): Remarks:

Sandy Redox (S5)

Stripped Matrix (S6) Loamy Mucky Mineral (F1) Loamy Gleyed Matrix (F2) Depleted Matrix (F3) Redox Dark Surface (F6) Depleted Dark Surface (F7) Redox Depressions (F8) Vernal Pools (F9)

1 cm Muck (A9) (LRR C) 2 cm Muck (A10) (LRR B) Reduced Vertic (F18) Red Parent Material (TF2) Other (Explain in Remarks)

4

Indicators of hydrophytic vegetation and wetland hydrology must be present.

Hydric Soil Present?

Yes

No

Oxidation mottles had sharp and distinct boundaries and appeared to be relict of when a more consistent source of hydrology was present.

HYDROLOGY
Wetland Hydrology Indicators: Primary Indicators (any one indicator is sufficient) Surface Water (A1) High Water Table (A2) Saturation (A3) Water Marks (B1) (Nonriverine) Sediment Deposits (B2) (Nonriverine) Drift Deposits (B3) (Nonriverine) Surface Soil Cracks (B6) Inundation Visible on Aerial Imagery (B7) Water-Stained Leaves (B9) Field Observations: Surface Water Present? Water Table Present? Yes Yes No No Depth (inches): Depth (inches): Yes No Salt Crust (B11) Biotic Crust (B12) Aquatic Invertebrates (B13) Hydrogen Sulfide Odor (C1) Oxidized Rhizospheres along Living Roots (C3) Presence of Reduced Iron (C4) Recent Iron Reduction in Plowed Soils (C6) Other (Explain in Remarks) Secondary Indicators (2 or more required) Water Marks (B1) (Riverine) Sediment Deposits (B2) (Riverine) Drift Deposits (B3) (Riverine) Drainage Patterns (B10) Dry-Season Water Table (C2) Thin Muck Surface (C7) Crayfish Burrows (C8) Saturation Visible on Aerial Imagery (C9) Shallow Aquitard (D3) FAC-Neutral Test (D5)

Saturation Present? Depth (inches): Yes No Wetland Hydrology Present? (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available: Remarks: It

is likely that the primary source of hydrology was from irrigation return flows that have been redirected up slope and no longer contribute to the area. There was no evidence of a ground water source.

US Army Corps of Engineers WestWater Engineering Page 59 of 75 Arid West - Version 11-1-2006 January 2008

WETLAND DETERMINATION DATA FORM - Arid West Region
Project/Site: Red

Cliff Mine

City/County:Mesa State:CO Section, Township, Range:

Sampling Date:6/21/06 Sampling Point:TLU

Colorado LLC Investigator(s): WestWater Engineering Renner/Fletcher
Landform (hillslope, terrace, etc.): Terrace Subregion (LRR):D - Interior Deserts Soil Map Unit Name: Cojam

Applicant/Owner: CAM

Section 22, T9S, R103W
Slope (%):<2% Datum: NAD83

Local relief (concave, convex, none): None Lat: 39.26371 N Long: 108.87071 W NWI classification:N/A No (If no, explain in Remarks.)

Are climatic / hydrologic conditions on the site typical for this time of year? Yes Are Vegetation Are Vegetation Soil Soil
or Hydrology or Hydrology

significantly disturbed? naturally problematic?

Are "Normal Circumstances" present? Yes (If needed, explain any answers in Remarks.)

No

SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Hydric Soil Present? Wetland Hydrology Present? Remarks: Yes Yes Yes No No No Is the Sampled Area within a Wetland? Yes No

VEGETATION
Tree Stratum 1. 2. 3. 4. Sapling/Shrub Stratum 1.Sarcobatus 3. 4. 5. Total Cover: Herb Stratum 1.Distichlis 2. 3. 4. 5. 6. 7. 8. Total Cover: Woody Vine Stratum 1. 2. Total Cover: % Bare Ground in Herb Stratum Remarks: % % % Prevalence Index = B/A = Hydrophytic Vegetation Indicators: Dominance Test is >50% Prevalence Index is ≤3.01 Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet) Problematic Hydrophytic Vegetation1 (Explain) % (Use scientific names.) Absolute % Cover Dominant Indicator Species? Status Dominance Test worksheet: Number of Dominant Species That Are OBL, FACW, or FAC: Total Number of Dominant Species Across All Strata: Percent of Dominant Species That Are OBL, FACW, or FAC:

1 2 50.0
%

(A)

(B)

(A/B)

vermiculatus 2.Tamarix spp.

40 15

Yes

FACU FACW

Prevalence Index worksheet: Total % Cover of: OBL species FACW species FAC species Multiply by: x1= x2= x3= x4= x5= (A) (B)

55 30

%

FACU species UPL species

spicata

Yes

FAC

Column Totals:

30

%
1

Indicators of hydric soil and wetland hydrology must be present.

% Cover of Biotic Crust

Hydrophytic Vegetation Present?

Yes

No

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SOIL
Depth (inches) Matrix Color (moist) Redox Features Color (moist) % Type 1

Sampling Point: TLU

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) % Loc 2 Texture 3 Silty loam Silty loam Silty loam Remarks

0-6 6-12 12-18

10 YR 5/3 10 YR 6/3 10 YR 6/3

90 90 90

1 3

2 Type: C=Concentration, D=Depletion, RM=Reduced Matrix. Location: PL=Pore Lining, RC=Root Channel, M=Matrix. Soil Textures: Clay, Silty Clay, Sandy Clay, Loam, Sandy Clay Loam, Sandy Loam, Clay Loam, Silty Clay Loam, Silt Loam, Silt, Loamy Sand, Sand.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.)

Indicators for Problematic Hydric Soils:

4

Histosol (A1) Histic Epipedon (A2) Black Histic (A3) Hydrogen Sulfide (A4) Stratified Layers (A5) (LRR C) 1 cm Muck (A9) (LRR D) Depleted Below Dark Surface (A11) Thick Dark Surface (A12) Sandy Mucky Mineral (S1) Sandy Gleyed Matrix (S4) Restrictive Layer (if present): Type: Depth (inches): Remarks:

Sandy Redox (S5)

Stripped Matrix (S6) Loamy Mucky Mineral (F1) Loamy Gleyed Matrix (F2) Depleted Matrix (F3) Redox Dark Surface (F6) Depleted Dark Surface (F7) Redox Depressions (F8) Vernal Pools (F9)

1 cm Muck (A9) (LRR C) 2 cm Muck (A10) (LRR B) Reduced Vertic (F18) Red Parent Material (TF2) Other (Explain in Remarks)

4

Indicators of hydrophytic vegetation and wetland hydrology must be present.

Hydric Soil Present?

Yes

No

HYDROLOGY
Wetland Hydrology Indicators: Primary Indicators (any one indicator is sufficient) Surface Water (A1) High Water Table (A2) Saturation (A3) Water Marks (B1) (Nonriverine) Sediment Deposits (B2) (Nonriverine) Drift Deposits (B3) (Nonriverine) Surface Soil Cracks (B6) Inundation Visible on Aerial Imagery (B7) Water-Stained Leaves (B9) Field Observations: Surface Water Present? Water Table Present? Yes Yes No No Depth (inches): Depth (inches): Yes No Salt Crust (B11) Biotic Crust (B12) Aquatic Invertebrates (B13) Hydrogen Sulfide Odor (C1) Oxidized Rhizospheres along Living Roots (C3) Presence of Reduced Iron (C4) Recent Iron Reduction in Plowed Soils (C6) Other (Explain in Remarks) Secondary Indicators (2 or more required) Water Marks (B1) (Riverine) Sediment Deposits (B2) (Riverine) Drift Deposits (B3) (Riverine) Drainage Patterns (B10) Dry-Season Water Table (C2) Thin Muck Surface (C7) Crayfish Burrows (C8) Saturation Visible on Aerial Imagery (C9) Shallow Aquitard (D3) FAC-Neutral Test (D5)

Saturation Present? Depth (inches): Yes No Wetland Hydrology Present? (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available: Remarks:

US Army Corps of Engineers WestWater Engineering Page 61 of 75 Arid West - Version 11-1-2006 January 2008

WETLAND DETERMINATION DATA FORM - Arid West Region
Project/Site: Red

Cliff Mine

City/County:Mesa State:CO Section, Township, Range:

Sampling Date:6/21/06 Sampling Point:THW

Colorado LLC Investigator(s): WestWater Engineering Renner/Fletcher
Landform (hillslope, terrace, etc.): Terrace Subregion (LRR):D - Interior Deserts Soil Map Unit Name: Cojam

Applicant/Owner: CAM

Section 22, T9S, R103W
Slope (%):<2% Datum: NAD83

Local relief (concave, convex, none): concave Lat: 39.25941 N Long: 108.87250 W NWI classification:N/A No (If no, explain in Remarks.)

Are climatic / hydrologic conditions on the site typical for this time of year? Yes Are Vegetation Are Vegetation Soil Soil
or Hydrology or Hydrology

significantly disturbed? naturally problematic?

Are "Normal Circumstances" present? Yes (If needed, explain any answers in Remarks.)

No

SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Hydric Soil Present? Wetland Hydrology Present? Remarks: Yes Yes Yes No No No Is the Sampled Area within a Wetland? Yes No

VEGETATION
Tree Stratum 1. 2. 3. 4. Sapling/Shrub Stratum 1. 2. 3. 4. 5. Total Cover: Herb Stratum 1.Typha % % (Use scientific names.) Absolute % Cover Dominant Indicator Species? Status Dominance Test worksheet: Number of Dominant Species That Are OBL, FACW, or FAC: Total Number of Dominant Species Across All Strata: Percent of Dominant Species That Are OBL, FACW, or FAC: Prevalence Index worksheet: Total % Cover of: OBL species FACW species FAC species FACU species UPL species Multiply by: x1= x2= x3= x4= x5= (A) (B)

1 1 100.0 %

(A)

(B)

(A/B)

latifolia 2.Scirpus pungens 3.Pucinellia spp.
4. 5. 6. 7. 8. Total Cover:

60 10 10

Yes

OBL OBL OBL

Column Totals:

Prevalence Index = B/A = Hydrophytic Vegetation Indicators: Dominance Test is >50% Prevalence Index is ≤3.01 Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet) Problematic Hydrophytic Vegetation1 (Explain)

Woody Vine Stratum 1. 2. Total Cover: % Bare Ground in Herb Stratum Remarks: %

80

%
1

Indicators of hydric soil and wetland hydrology must be present.

% %

% Cover of Biotic Crust

Hydrophytic Vegetation Present?

Yes

No

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SOIL
Depth (inches) Matrix Color (moist) Redox Features Color (moist) % Type 1

Sampling Point: THW

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) % Loc 2 Texture 3 Silty loam Silty loam Silty loam Remarks

0-6 6-12 12-18

10 YR 4/2 10 YR 4/2 10 YR 4/2

90 90 90

1 3

2 Type: C=Concentration, D=Depletion, RM=Reduced Matrix. Location: PL=Pore Lining, RC=Root Channel, M=Matrix. Soil Textures: Clay, Silty Clay, Sandy Clay, Loam, Sandy Clay Loam, Sandy Loam, Clay Loam, Silty Clay Loam, Silt Loam, Silt, Loamy Sand, Sand.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.)

Indicators for Problematic Hydric Soils:

4

Histosol (A1) Histic Epipedon (A2) Black Histic (A3) Hydrogen Sulfide (A4) Stratified Layers (A5) (LRR C) 1 cm Muck (A9) (LRR D) Depleted Below Dark Surface (A11) Thick Dark Surface (A12) Sandy Mucky Mineral (S1) Sandy Gleyed Matrix (S4) Restrictive Layer (if present): Type: Depth (inches): Remarks:

Sandy Redox (S5)

Stripped Matrix (S6) Loamy Mucky Mineral (F1) Loamy Gleyed Matrix (F2) Depleted Matrix (F3) Redox Dark Surface (F6) Depleted Dark Surface (F7) Redox Depressions (F8) Vernal Pools (F9)

1 cm Muck (A9) (LRR C) 2 cm Muck (A10) (LRR B) Reduced Vertic (F18) Red Parent Material (TF2) Other (Explain in Remarks)

4

Indicators of hydrophytic vegetation and wetland hydrology must be present.

Hydric Soil Present?

Yes

No

Redoximorphic features may be related to the length of time the soils have been subject to wetland hydrology or soil chemistry of the clay soils involved. In the opinion of the field observers the clear wetland hydrology observed (likely to be a combination of irrigation return flow and ground water discharge) indicated the soils should be considered hydric.

HYDROLOGY
Wetland Hydrology Indicators: Primary Indicators (any one indicator is sufficient) Surface Water (A1) High Water Table (A2) Saturation (A3) Water Marks (B1) (Nonriverine) Sediment Deposits (B2) (Nonriverine) Drift Deposits (B3) (Nonriverine) Surface Soil Cracks (B6) Inundation Visible on Aerial Imagery (B7) Water-Stained Leaves (B9) Field Observations: Surface Water Present? Water Table Present? Yes Yes No No Depth (inches): Depth (inches): Salt Crust (B11) Biotic Crust (B12) Aquatic Invertebrates (B13) Hydrogen Sulfide Odor (C1) Oxidized Rhizospheres along Living Roots (C3) Presence of Reduced Iron (C4) Recent Iron Reduction in Plowed Soils (C6) Other (Explain in Remarks) Secondary Indicators (2 or more required) Water Marks (B1) (Riverine) Sediment Deposits (B2) (Riverine) Drift Deposits (B3) (Riverine) Drainage Patterns (B10) Dry-Season Water Table (C2) Thin Muck Surface (C7) Crayfish Burrows (C8) Saturation Visible on Aerial Imagery (C9) Shallow Aquitard (D3) FAC-Neutral Test (D5)

7
Yes No

Saturation Present? Depth (inches): 7 Yes No Wetland Hydrology Present? (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available: Remarks:

US Army Corps of Engineers WestWater Engineering Page 63 of 75 Arid West - Version 11-1-2006 January 2008

WETLAND DETERMINATION DATA FORM - Arid West Region
Project/Site: Red

Cliff Mine

City/County:Mesa State:CO Section, Township, Range:

Sampling Date:6/21/06 Sampling Point:THU

Colorado LLC Investigator(s): WestWater Engineering Renner/Fletcher
Landform (hillslope, terrace, etc.): Terrace Subregion (LRR):D - Interior Deserts Soil Map Unit Name: Cojam

Applicant/Owner: CAM

Section 22, T9S, R103W
Slope (%):<2% Datum: NAD83

Local relief (concave, convex, none): concave Lat: 39.25941 N Long: 108.87250 W NWI classification:N/A No (If no, explain in Remarks.)

Are climatic / hydrologic conditions on the site typical for this time of year? Yes Are Vegetation Are Vegetation Soil Soil
or Hydrology or Hydrology

significantly disturbed? naturally problematic?

Are "Normal Circumstances" present? Yes (If needed, explain any answers in Remarks.)

No

SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Hydric Soil Present? Wetland Hydrology Present? Remarks: Yes Yes Yes No No No Is the Sampled Area within a Wetland? Yes No

VEGETATION
Tree Stratum 1. 2. 3. 4. Sapling/Shrub Stratum 1.Sarcobatus 3. 4. 5. Total Cover: Herb Stratum 1.Muhlenbergia 3. 4. 5. 6. 7. 8. Total Cover: Woody Vine Stratum 1. 2. Total Cover: % Bare Ground in Herb Stratum Remarks: % % % % (Use scientific names.) Absolute % Cover Dominant Indicator Species? Status Dominance Test worksheet: Number of Dominant Species That Are OBL, FACW, or FAC: Total Number of Dominant Species Across All Strata: Percent of Dominant Species That Are OBL, FACW, or FAC:

2 4 50.0
%

(A)

(B)

(A/B)

vermiculatus 2.Chrysthamus nauseosus

30 20

Yes Yes

FACU UPL

Prevalence Index worksheet: Total % Cover of: OBL species FACW species FAC species Multiply by: x1= x2= x3= x4= x5= (A) (B)

50 40 15

%

FACU species UPL species

asperifolia 2.Disticulas spicata

Yes Yes

FACW FAC

Column Totals:

Prevalence Index = B/A = Hydrophytic Vegetation Indicators: Dominance Test is >50% Prevalence Index is ≤3.01 Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet) Problematic Hydrophytic Vegetation1 (Explain)

55

%
1

Indicators of hydric soil and wetland hydrology must be present.

% Cover of Biotic Crust

Hydrophytic Vegetation Present?

Yes

No

US Army Corps of Engineers WestWater Engineering

Page 64 of 75

Arid West - Version 11-1-2006 January 2008

SOIL
Depth (inches) Matrix Color (moist) Redox Features Color (moist) % Type 1

Sampling Point: THU

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) % Loc 2 Texture 3 Silty loam Silty loam Silty loam Remarks

0-6 6-12 12-18

10 YR 4/3 10 YR 5/3 10 YR 5/4

1 3

2 Type: C=Concentration, D=Depletion, RM=Reduced Matrix. Location: PL=Pore Lining, RC=Root Channel, M=Matrix. Soil Textures: Clay, Silty Clay, Sandy Clay, Loam, Sandy Clay Loam, Sandy Loam, Clay Loam, Silty Clay Loam, Silt Loam, Silt, Loamy Sand, Sand.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.)

Indicators for Problematic Hydric Soils:

4

Histosol (A1) Histic Epipedon (A2) Black Histic (A3) Hydrogen Sulfide (A4) Stratified Layers (A5) (LRR C) 1 cm Muck (A9) (LRR D) Depleted Below Dark Surface (A11) Thick Dark Surface (A12) Sandy Mucky Mineral (S1) Sandy Gleyed Matrix (S4) Restrictive Layer (if present): Type: Depth (inches): Remarks:

Sandy Redox (S5)

Stripped Matrix (S6) Loamy Mucky Mineral (F1) Loamy Gleyed Matrix (F2) Depleted Matrix (F3) Redox Dark Surface (F6) Depleted Dark Surface (F7) Redox Depressions (F8) Vernal Pools (F9)

1 cm Muck (A9) (LRR C) 2 cm Muck (A10) (LRR B) Reduced Vertic (F18) Red Parent Material (TF2) Other (Explain in Remarks)

4

Indicators of hydrophytic vegetation and wetland hydrology must be present.

Hydric Soil Present?

Yes

No

HYDROLOGY
Wetland Hydrology Indicators: Primary Indicators (any one indicator is sufficient) Surface Water (A1) High Water Table (A2) Saturation (A3) Water Marks (B1) (Nonriverine) Sediment Deposits (B2) (Nonriverine) Drift Deposits (B3) (Nonriverine) Surface Soil Cracks (B6) Inundation Visible on Aerial Imagery (B7) Water-Stained Leaves (B9) Field Observations: Surface Water Present? Water Table Present? Yes Yes No No Depth (inches): Depth (inches): Yes No Salt Crust (B11) Biotic Crust (B12) Aquatic Invertebrates (B13) Hydrogen Sulfide Odor (C1) Oxidized Rhizospheres along Living Roots (C3) Presence of Reduced Iron (C4) Recent Iron Reduction in Plowed Soils (C6) Other (Explain in Remarks) Secondary Indicators (2 or more required) Water Marks (B1) (Riverine) Sediment Deposits (B2) (Riverine) Drift Deposits (B3) (Riverine) Drainage Patterns (B10) Dry-Season Water Table (C2) Thin Muck Surface (C7) Crayfish Burrows (C8) Saturation Visible on Aerial Imagery (C9) Shallow Aquitard (D3) FAC-Neutral Test (D5)

Saturation Present? Depth (inches): Yes No Wetland Hydrology Present? (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available: Remarks:

US Army Corps of Engineers WestWater Engineering Page 65 of 75 Arid West - Version 11-1-2006 January 2008

WETLAND DETERMINATION DATA FORM - Arid West Region
Project/Site: Red

Cliff Mine

City/County:Mesa State:CO Section, Township, Range:

Sampling Date:6/19/06 Sampling Point:TBW

Colorado LLC Investigator(s): WestWater Engineering Renner/Fletcher
Landform (hillslope, terrace, etc.): Terrace Subregion (LRR):D - Interior Deserts Soil Map Unit Name: Cojam

Applicant/Owner: CAM

Section 19, T2N, R3W
Slope (%):<2% Datum: NAD83

Local relief (concave, convex, none): None Lat: 39.22487 N Long: 108.86845 W NWI classification:N/A No (If no, explain in Remarks.)

Are climatic / hydrologic conditions on the site typical for this time of year? Yes Are Vegetation Are Vegetation Soil Soil
or Hydrology or Hydrology

significantly disturbed? naturally problematic?

Are "Normal Circumstances" present? Yes (If needed, explain any answers in Remarks.)

No

SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Hydric Soil Present? Wetland Hydrology Present? Remarks: Yes Yes Yes No No No Is the Sampled Area within a Wetland? Yes No

VEGETATION
Tree Stratum 1. 2. 3. 4. Sapling/Shrub Stratum % (Use scientific names.) Absolute % Cover Dominant Indicator Species? Status Dominance Test worksheet: Number of Dominant Species That Are OBL, FACW, or FAC: Total Number of Dominant Species Across All Strata: Percent of Dominant Species That Are OBL, FACW, or FAC:

4 4 100.0 %
Multiply by:

(A)

(B)

(A/B)

Salix exigua 2. Tamarix spp.
1. 3. 4. 5. Total Cover: Herb Stratum 1.Muhlenbergia 2.Typha 3. 4. 5. 6. 7. 8. Total Cover: Woody Vine Stratum 1. 2. Total Cover: % Bare Ground in Herb Stratum Remarks: %

20 10

Yes Yes

FACW FACW

Prevalence Index worksheet: Total % Cover of: OBL species FACW species FAC species x1= x2= x3= x4= x5= (A) (B)

30 50 30

%

FACU species UPL species

asperifolia

spp.

Yes Yes

FACW OBL

Column Totals:

Prevalence Index = B/A = Hydrophytic Vegetation Indicators: Dominance Test is >50% Prevalence Index is ≤3.01 Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet) Problematic Hydrophytic Vegetation1 (Explain)

80

%
1

Indicators of hydric soil and wetland hydrology must be present.

% %

% Cover of Biotic Crust

Hydrophytic Vegetation Present?

Yes

No

US Army Corps of Engineers WestWater Engineering

Page 66 of 75

Arid West - Version 11-1-2006 January 2008

SOIL
Depth (inches) Matrix Color (moist) Redox Features Color (moist) % Type 1

Sampling Point: TBW

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) % Loc 2 Texture 3 Silty loam Remarks

0-6 6-12 12-18

10 YR 4/2 10 YR 4/1 10 YR 3/3

75 50 40

GC1 4/5G GC1 4/5G

30 40

RM RM

M M

Silty loam Silty loam

diffuse oxidation gley gley

1 3

2 Type: C=Concentration, D=Depletion, RM=Reduced Matrix. Location: PL=Pore Lining, RC=Root Channel, M=Matrix. Soil Textures: Clay, Silty Clay, Sandy Clay, Loam, Sandy Clay Loam, Sandy Loam, Clay Loam, Silty Clay Loam, Silt Loam, Silt, Loamy Sand, Sand.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.)

Indicators for Problematic Hydric Soils:

4

Histosol (A1) Histic Epipedon (A2) Black Histic (A3) Hydrogen Sulfide (A4) Stratified Layers (A5) (LRR C) 1 cm Muck (A9) (LRR D) Depleted Below Dark Surface (A11) Thick Dark Surface (A12) Sandy Mucky Mineral (S1) Sandy Gleyed Matrix (S4) Restrictive Layer (if present): Type: Depth (inches): Remarks:

Sandy Redox (S5)

Stripped Matrix (S6) Loamy Mucky Mineral (F1) Loamy Gleyed Matrix (F2) Depleted Matrix (F3) Redox Dark Surface (F6) Depleted Dark Surface (F7) Redox Depressions (F8) Vernal Pools (F9)

1 cm Muck (A9) (LRR C) 2 cm Muck (A10) (LRR B) Reduced Vertic (F18) Red Parent Material (TF2) Other (Explain in Remarks)

4

Indicators of hydrophytic vegetation and wetland hydrology must be present.

Hydric Soil Present?

Yes

No

HYDROLOGY
Wetland Hydrology Indicators: Primary Indicators (any one indicator is sufficient) Surface Water (A1) High Water Table (A2) Saturation (A3) Water Marks (B1) (Nonriverine) Sediment Deposits (B2) (Nonriverine) Drift Deposits (B3) (Nonriverine) Surface Soil Cracks (B6) Inundation Visible on Aerial Imagery (B7) Water-Stained Leaves (B9) Field Observations: Surface Water Present? Water Table Present? Yes Yes No No Depth (inches): Depth (inches): Yes No Salt Crust (B11) Biotic Crust (B12) Aquatic Invertebrates (B13) Hydrogen Sulfide Odor (C1) Oxidized Rhizospheres along Living Roots (C3) Presence of Reduced Iron (C4) Recent Iron Reduction in Plowed Soils (C6) Other (Explain in Remarks) Secondary Indicators (2 or more required) Water Marks (B1) (Riverine) Sediment Deposits (B2) (Riverine) Drift Deposits (B3) (Riverine) Drainage Patterns (B10) Dry-Season Water Table (C2) Thin Muck Surface (C7) Crayfish Burrows (C8) Saturation Visible on Aerial Imagery (C9) Shallow Aquitard (D3) FAC-Neutral Test (D5)

8

Saturation Present? Depth (inches): 8 Yes No Wetland Hydrology Present? (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available: Remarks:

US Army Corps of Engineers WestWater Engineering Page 67 of 75 Arid West - Version 11-1-2006 January 2008

WETLAND DETERMINATION DATA FORM - Arid West Region
Project/Site: Red

Cliff Mine

City/County:Mesa State:CO Section, Township, Range:

Sampling Date:6/19/06 Sampling Point:TBU

Colorado LLC Investigator(s): WestWater Engineering Renner/Fletcher
Landform (hillslope, terrace, etc.): Terrace Subregion (LRR):D - Interior Deserts Soil Map Unit Name: Cojam

Applicant/Owner: CAM

Section 19, T2N, R3W
Slope (%):<2% Datum: NAD83

Local relief (concave, convex, none): None Lat: 39.22487 N Long: 108.86845 W NWI classification:N/A No (If no, explain in Remarks.)

Are climatic / hydrologic conditions on the site typical for this time of year? Yes Are Vegetation Are Vegetation Soil Soil
or Hydrology or Hydrology

significantly disturbed? naturally problematic?

Are "Normal Circumstances" present? Yes (If needed, explain any answers in Remarks.)

No

SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Hydric Soil Present? Wetland Hydrology Present? Remarks: Yes Yes Yes No No No Is the Sampled Area within a Wetland? Yes No

VEGETATION
Tree Stratum 1. 2. 3. 4. Sapling/Shrub Stratum 1. 2. 3. 4. 5. Total Cover: Herb Stratum 1.Acroptilon 3. 4. 5. 6. 7. 8. Total Cover: Woody Vine Stratum 1. 2. Total Cover: % Bare Ground in Herb Stratum Remarks: % % % % (Use scientific names.) Absolute % Cover Dominant Indicator Species? Status Dominance Test worksheet: Number of Dominant Species That Are OBL, FACW, or FAC: Total Number of Dominant Species Across All Strata: Percent of Dominant Species That Are OBL, FACW, or FAC:

2 3 66.7
%

(A)

(B)

(A/B)

Tamarix spp,

5

Yes

FACW

Prevalence Index worksheet: Total % Cover of: OBL species FACW species FAC species Multiply by: x1= x2= x3= x4= x5= (A) (B)

5 40 20

%

FACU species UPL species

repens 2.Muhlenbergia asperifolia

Yes Yes

UPL FACW

Column Totals:

Prevalence Index = B/A = Hydrophytic Vegetation Indicators: Dominance Test is >50% Prevalence Index is ≤3.01 Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet) Problematic Hydrophytic Vegetation1 (Explain)

60

%
1

Indicators of hydric soil and wetland hydrology must be present.

% Cover of Biotic Crust

Hydrophytic Vegetation Present?

Yes

No

US Army Corps of Engineers WestWater Engineering

Page 68 of 75

Arid West - Version 11-1-2006 January 2008

SOIL
Depth (inches) Matrix Color (moist) Redox Features Color (moist) % Type 1

Sampling Point: TBU

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) % Loc 2 Texture 3 Remarks

0-6 6-12 12-18

10 YR 6/3 10 YR 6/3 10 YR 5/4

90 90 80

1 3

2 Type: C=Concentration, D=Depletion, RM=Reduced Matrix. Location: PL=Pore Lining, RC=Root Channel, M=Matrix. Soil Textures: Clay, Silty Clay, Sandy Clay, Loam, Sandy Clay Loam, Sandy Loam, Clay Loam, Silty Clay Loam, Silt Loam, Silt, Loamy Sand, Sand.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.)

Indicators for Problematic Hydric Soils:

4

Histosol (A1) Histic Epipedon (A2) Black Histic (A3) Hydrogen Sulfide (A4) Stratified Layers (A5) (LRR C) 1 cm Muck (A9) (LRR D) Depleted Below Dark Surface (A11) Thick Dark Surface (A12) Sandy Mucky Mineral (S1) Sandy Gleyed Matrix (S4) Restrictive Layer (if present): Type: Depth (inches): Remarks:

Sandy Redox (S5)

Stripped Matrix (S6) Loamy Mucky Mineral (F1) Loamy Gleyed Matrix (F2) Depleted Matrix (F3) Redox Dark Surface (F6) Depleted Dark Surface (F7) Redox Depressions (F8) Vernal Pools (F9)

1 cm Muck (A9) (LRR C) 2 cm Muck (A10) (LRR B) Reduced Vertic (F18) Red Parent Material (TF2) Other (Explain in Remarks)

4

Indicators of hydrophytic vegetation and wetland hydrology must be present.

Hydric Soil Present?

Yes

No

HYDROLOGY
Wetland Hydrology Indicators: Primary Indicators (any one indicator is sufficient) Surface Water (A1) High Water Table (A2) Saturation (A3) Water Marks (B1) (Nonriverine) Sediment Deposits (B2) (Nonriverine) Drift Deposits (B3) (Nonriverine) Surface Soil Cracks (B6) Inundation Visible on Aerial Imagery (B7) Water-Stained Leaves (B9) Field Observations: Surface Water Present? Water Table Present? Yes Yes No No Depth (inches): Depth (inches): Yes No Salt Crust (B11) Biotic Crust (B12) Aquatic Invertebrates (B13) Hydrogen Sulfide Odor (C1) Oxidized Rhizospheres along Living Roots (C3) Presence of Reduced Iron (C4) Recent Iron Reduction in Plowed Soils (C6) Other (Explain in Remarks) Secondary Indicators (2 or more required) Water Marks (B1) (Riverine) Sediment Deposits (B2) (Riverine) Drift Deposits (B3) (Riverine) Drainage Patterns (B10) Dry-Season Water Table (C2) Thin Muck Surface (C7) Crayfish Burrows (C8) Saturation Visible on Aerial Imagery (C9) Shallow Aquitard (D3) FAC-Neutral Test (D5)

Saturation Present? Depth (inches): Yes No Wetland Hydrology Present? (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available: Remarks:

US Army Corps of Engineers WestWater Engineering Page 69 of 75 Arid West - Version 11-1-2006 January 2008

WETLAND DETERMINATION DATA FORM - Arid West Region
Project/Site: Red

Cliff Mine

City/County:Mesa State:CO Section, Township, Range:

Sampling Date:6/19/06 Sampling Point:TAW

Colorado LLC Investigator(s): WestWater Engineering Renner/Fletcher
Landform (hillslope, terrace, etc.): Terrace Subregion (LRR):D - Interior Deserts Soil Map Unit Name: Killpack

Applicant/Owner: CAM

Section 34, T9S, R103W
Slope (%):<2% Datum: NAD83

Local relief (concave, convex, none): None Lat:39.23519 N Long:108.87741 W NWI classification:N/A No (If no, explain in Remarks.)

Are climatic / hydrologic conditions on the site typical for this time of year? Yes Are Vegetation Are Vegetation Soil Soil
or Hydrology or Hydrology

significantly disturbed? naturally problematic?

Are "Normal Circumstances" present? Yes (If needed, explain any answers in Remarks.)

No

SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Hydric Soil Present? Wetland Hydrology Present? Remarks: Yes Yes Yes No No No Is the Sampled Area within a Wetland? Yes No

VEGETATION
Tree Stratum 1. 2. 3. 4. Sapling/Shrub Stratum 1. 2. 3. 4. 5. Total Cover: Herb Stratum 1.Typha 3. 4. 5. 6. 7. 8. Total Cover: Woody Vine Stratum 1. 2. Total Cover: % Bare Ground in Herb Stratum Remarks: % % % % (Use scientific names.) Absolute % Cover Dominant Indicator Species? Status Dominance Test worksheet: Number of Dominant Species That Are OBL, FACW, or FAC: Total Number of Dominant Species Across All Strata: Percent of Dominant Species That Are OBL, FACW, or FAC:

3 3 100.0 %
Multiply by:

(A)

(B)

(A/B)

Tamarix spp.

10

Yes

FACW

Prevalence Index worksheet: Total % Cover of: OBL species FACW species FAC species x1= x2= x3= x4= x5= (A) (B)

10 65 20

%

FACU species UPL species

latifolia 2.Eleocharis palustris

Yes Yes

OBL OBL

Column Totals:

Prevalence Index = B/A = Hydrophytic Vegetation Indicators: Dominance Test is >50% Prevalence Index is ≤3.01 Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet) Problematic Hydrophytic Vegetation1 (Explain)

85

%
1

Indicators of hydric soil and wetland hydrology must be present.

% Cover of Biotic Crust

Hydrophytic Vegetation Present?

Yes

No

US Army Corps of Engineers WestWater Engineering

Page 70 of 75

Arid West - Version 11-1-2006 January 2008

SOIL
Depth (inches) Matrix Color (moist) Redox Features Color (moist) % Type 1

Sampling Point: TAW

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) % Loc 2 Texture 3 Silty loam Silty loam Silty loam Remarks

0-6 6-12 12-18

7.5 YR 4/2 7.5 YR 5/2 7.5 YR 5/2

70 65

GC1 4/5G GC1 4/5G

5 10

C RM

M M

spotty oxidation and gley increased gley

1 3

2 Type: C=Concentration, D=Depletion, RM=Reduced Matrix. Location: PL=Pore Lining, RC=Root Channel, M=Matrix. Soil Textures: Clay, Silty Clay, Sandy Clay, Loam, Sandy Clay Loam, Sandy Loam, Clay Loam, Silty Clay Loam, Silt Loam, Silt, Loamy Sand, Sand.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.)

Indicators for Problematic Hydric Soils:

4

Histosol (A1) Histic Epipedon (A2) Black Histic (A3) Hydrogen Sulfide (A4) Stratified Layers (A5) (LRR C) 1 cm Muck (A9) (LRR D) Depleted Below Dark Surface (A11) Thick Dark Surface (A12) Sandy Mucky Mineral (S1) Sandy Gleyed Matrix (S4) Restrictive Layer (if present): Type: Depth (inches): Remarks:

Sandy Redox (S5)

Stripped Matrix (S6) Loamy Mucky Mineral (F1) Loamy Gleyed Matrix (F2) Depleted Matrix (F3) Redox Dark Surface (F6) Depleted Dark Surface (F7) Redox Depressions (F8) Vernal Pools (F9)

1 cm Muck (A9) (LRR C) 2 cm Muck (A10) (LRR B) Reduced Vertic (F18) Red Parent Material (TF2) Other (Explain in Remarks)

4

Indicators of hydrophytic vegetation and wetland hydrology must be present.

Hydric Soil Present?

Yes

No

Redoximorphic features may be related to the length of time the soils have been subject to wetland hydrology or soil chemistry of the clay soils involved. In the opinion of the field observers the wetland hydrology observed (likely to be a combination of irrigation return flow and ground water discharge) indicated the soils should be considered hydric.

HYDROLOGY
Wetland Hydrology Indicators: Primary Indicators (any one indicator is sufficient) Surface Water (A1) High Water Table (A2) Saturation (A3) Water Marks (B1) (Nonriverine) Sediment Deposits (B2) (Nonriverine) Drift Deposits (B3) (Nonriverine) Surface Soil Cracks (B6) Inundation Visible on Aerial Imagery (B7) Water-Stained Leaves (B9) Field Observations: Surface Water Present? Water Table Present? Yes Yes No No Depth (inches): Depth (inches): Salt Crust (B11) Biotic Crust (B12) Aquatic Invertebrates (B13) Hydrogen Sulfide Odor (C1) Oxidized Rhizospheres along Living Roots (C3) Presence of Reduced Iron (C4) Recent Iron Reduction in Plowed Soils (C6) Other (Explain in Remarks) Secondary Indicators (2 or more required) Water Marks (B1) (Riverine) Sediment Deposits (B2) (Riverine) Drift Deposits (B3) (Riverine) Drainage Patterns (B10) Dry-Season Water Table (C2) Thin Muck Surface (C7) Crayfish Burrows (C8) Saturation Visible on Aerial Imagery (C9) Shallow Aquitard (D3) FAC-Neutral Test (D5)

Saturation Present? Depth (inches): Yes No Wetland Hydrology Present? (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available: Remarks:

1 1 0

Yes

No

US Army Corps of Engineers WestWater Engineering Page 71 of 75 Arid West - Version 11-1-2006 January 2008

WETLAND DETERMINATION DATA FORM - Arid West Region
Project/Site: Red

Cliff Mine

City/County:Mesa State:CO Section, Township, Range:

Sampling Date:6/19/06 Sampling Point:TAU

Colorado LLC Investigator(s): WestWater Engineering Renner/Fletcher
Landform (hillslope, terrace, etc.): Terrace Subregion (LRR):D - Interior Deserts Soil Map Unit Name: Killpack

Applicant/Owner: CAM

Section 34, T9S, R103W
Slope (%):<2% Datum: NAD83

Local relief (concave, convex, none): None Lat:39.23519 N Long:108.87741 W NWI classification:N/A No (If no, explain in Remarks.)

Are climatic / hydrologic conditions on the site typical for this time of year? Yes Are Vegetation Are Vegetation Soil Soil
or Hydrology or Hydrology

significantly disturbed? naturally problematic?

Are "Normal Circumstances" present? Yes (If needed, explain any answers in Remarks.)

No

SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Hydric Soil Present? Wetland Hydrology Present? Remarks: Yes Yes Yes No No No Is the Sampled Area within a Wetland? Yes No

VEGETATION
Tree Stratum 1. 2. 3. 4. Sapling/Shrub Stratum % (Use scientific names.) Absolute % Cover Dominant Indicator Species? Status Dominance Test worksheet: Number of Dominant Species That Are OBL, FACW, or FAC: Total Number of Dominant Species Across All Strata: Percent of Dominant Species That Are OBL, FACW, or FAC:

2 3 66.7
%

(A)

(B)

(A/B)

Chrysothamnus nauseosus 2.Tamarix spp.
1. 3. 4. 5. Total Cover: Herb Stratum 1.Muhlenbergia 2. 3. 4. 5. 6. 7. 8. Total Cover: Woody Vine Stratum 1. 2. Total Cover: % Bare Ground in Herb Stratum Remarks: %

30 20

Yes Yes

UPL FACW

Prevalence Index worksheet: Total % Cover of: OBL species FACW species FAC species Multiply by: x1= x2= x3= x4= x5= (A) (B)

50 30

%

FACU species UPL species

asperifolia

Yes

FACW

Column Totals:

Prevalence Index = B/A = Hydrophytic Vegetation Indicators: Dominance Test is >50% Prevalence Index is ≤3.01 Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet) Problematic Hydrophytic Vegetation1 (Explain)

30

%
1

Indicators of hydric soil and wetland hydrology must be present.

% %

% Cover of Biotic Crust

Hydrophytic Vegetation Present?

Yes

No

US Army Corps of Engineers WestWater Engineering

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SOIL
Depth (inches) Matrix Color (moist) Redox Features Color (moist) % Type 1

Sampling Point: TAU

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) % Loc 2 Texture 3 Silty loam Silty loam Silty loam Remarks

0-6 6-12 12-18

7.5 YR 4/3 7.5 YR 4/3 7.5 YR 5/4

70 70 70

1 3

2 Type: C=Concentration, D=Depletion, RM=Reduced Matrix. Location: PL=Pore Lining, RC=Root Channel, M=Matrix. Soil Textures: Clay, Silty Clay, Sandy Clay, Loam, Sandy Clay Loam, Sandy Loam, Clay Loam, Silty Clay Loam, Silt Loam, Silt, Loamy Sand, Sand.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.)

Indicators for Problematic Hydric Soils:

4

Histosol (A1) Histic Epipedon (A2) Black Histic (A3) Hydrogen Sulfide (A4) Stratified Layers (A5) (LRR C) 1 cm Muck (A9) (LRR D) Depleted Below Dark Surface (A11) Thick Dark Surface (A12) Sandy Mucky Mineral (S1) Sandy Gleyed Matrix (S4) Restrictive Layer (if present): Type: Depth (inches): Remarks:

Sandy Redox (S5)

Stripped Matrix (S6) Loamy Mucky Mineral (F1) Loamy Gleyed Matrix (F2) Depleted Matrix (F3) Redox Dark Surface (F6) Depleted Dark Surface (F7) Redox Depressions (F8) Vernal Pools (F9)

1 cm Muck (A9) (LRR C) 2 cm Muck (A10) (LRR B) Reduced Vertic (F18) Red Parent Material (TF2) Other (Explain in Remarks)

4

Indicators of hydrophytic vegetation and wetland hydrology must be present.

Hydric Soil Present?

Yes

No

HYDROLOGY
Wetland Hydrology Indicators: Primary Indicators (any one indicator is sufficient) Surface Water (A1) High Water Table (A2) Saturation (A3) Water Marks (B1) (Nonriverine) Sediment Deposits (B2) (Nonriverine) Drift Deposits (B3) (Nonriverine) Surface Soil Cracks (B6) Inundation Visible on Aerial Imagery (B7) Water-Stained Leaves (B9) Field Observations: Surface Water Present? Water Table Present? Yes Yes No No Depth (inches): Depth (inches): Yes No Salt Crust (B11) Biotic Crust (B12) Aquatic Invertebrates (B13) Hydrogen Sulfide Odor (C1) Oxidized Rhizospheres along Living Roots (C3) Presence of Reduced Iron (C4) Recent Iron Reduction in Plowed Soils (C6) Other (Explain in Remarks) Secondary Indicators (2 or more required) Water Marks (B1) (Riverine) Sediment Deposits (B2) (Riverine) Drift Deposits (B3) (Riverine) Drainage Patterns (B10) Dry-Season Water Table (C2) Thin Muck Surface (C7) Crayfish Burrows (C8) Saturation Visible on Aerial Imagery (C9) Shallow Aquitard (D3) FAC-Neutral Test (D5)

Saturation Present? Depth (inches): Yes No Wetland Hydrology Present? (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available: Remarks:

US Army Corps of Engineers WestWater Engineering Page 73 of 75 Arid West - Version 11-1-2006 January 2008

WETLAND DETERMINATION DATA FORM - Arid West Region
Project/Site: Red

Cliff Mine

City/County:Mesa State:CO Section, Township, Range:

Sampling Date:8/17/06 Sampling Point:TPW

Colorado LLC Investigator(s): WestWater Engineering Renner/Fletcher
Landform (hillslope, terrace, etc.): Terrace Subregion (LRR):D - Interior Deserts Soil Map Unit Name: Avalon

Applicant/Owner: CAM

Section 34, T9S, R103W
Slope (%):<2% Datum: NAD83

Local relief (concave, convex, none): None Lat: 39.22614 N Long: 108.87230 W NWI classification:N/A No (If no, explain in Remarks.)

Are climatic / hydrologic conditions on the site typical for this time of year? Yes Are Vegetation Are Vegetation Soil Soil
or Hydrology or Hydrology

significantly disturbed? naturally problematic?

Are "Normal Circumstances" present? Yes (If needed, explain any answers in Remarks.)

No

SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc.
Hydrophytic Vegetation Present? Hydric Soil Present? Wetland Hydrology Present? Remarks: Yes Yes Yes No No No Is the Sampled Area within a Wetland? Yes No

VEGETATION
Tree Stratum 1. 2. 3. 4. Sapling/Shrub Stratum 1. 2. 3. 4. 5. Total Cover: Herb Stratum 1.Typha 2. 3. 4. 5. 6. 7. 8. Total Cover: Woody Vine Stratum 1. 2. Total Cover: % Bare Ground in Herb Stratum Remarks: % % % Prevalence Index = B/A = Hydrophytic Vegetation Indicators: Dominance Test is >50% Prevalence Index is ≤3.01 Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet) Problematic Hydrophytic Vegetation1 (Explain) % % (Use scientific names.) Absolute % Cover Dominant Indicator Species? Status Dominance Test worksheet: Number of Dominant Species That Are OBL, FACW, or FAC: Total Number of Dominant Species Across All Strata: Percent of Dominant Species That Are OBL, FACW, or FAC: Prevalence Index worksheet: Total % Cover of: OBL species FACW species FAC species FACU species UPL species Multiply by: x1= x2= x3= x4= x5= (A) (B)

1 1 100.0 %

(A)

(B)

(A/B)

spp,

60

Yes

OBL

Column Totals:

60

%
1

Indicators of hydric soil and wetland hydrology must be present.

% Cover of Biotic Crust

Hydrophytic Vegetation Present?

Yes

No

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SOIL
Depth (inches) Matrix Color (moist) Redox Features Color (moist) % Type 1

Sampling Point: TPW

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) % Loc 2 Texture 3 Silty loam Remarks

0-6 6-12 12-18

10 YR 4/2 10 YR 4/3 10 YR 4/3

85 60 50

GC1 4/5G GC1 4/5G

15 20

C RM

M M

Silty loam Silty loam

gley gley

1 3

2 Type: C=Concentration, D=Depletion, RM=Reduced Matrix. Location: PL=Pore Lining, RC=Root Channel, M=Matrix. Soil Textures: Clay, Silty Clay, Sandy Clay, Loam, Sandy Clay Loam, Sandy Loam, Clay Loam, Silty Clay Loam, Silt Loam, Silt, Loamy Sand, Sand.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.)

Indicators for Problematic Hydric Soils:

4

Histosol (A1) Histic Epipedon (A2) Black Histic (A3) Hydrogen Sulfide (A4) Stratified Layers (A5) (LRR C) 1 cm Muck (A9) (LRR D) Depleted Below Dark Surface (A11) Thick Dark Surface (A12) Sandy Mucky Mineral (S1) Sandy Gleyed Matrix (S4) Restrictive Layer (if present): Type: Depth (inches): Remarks:

Sandy Redox (S5)

Stripped Matrix (S6) Loamy Mucky Mineral (F1) Loamy Gleyed Matrix (F2) Depleted Matrix (F3) Redox Dark Surface (F6) Depleted Dark Surface (F7) Redox Depressions (F8) Vernal Pools (F9)

1 cm Muck (A9) (LRR C) 2 cm Muck (A10) (LRR B) Reduced Vertic (F18) Red Parent Material (TF2) Other (Explain in Remarks)

4

Indicators of hydrophytic vegetation and wetland hydrology must be present.

Hydric Soil Present?

Yes

No

HYDROLOGY
Wetland Hydrology Indicators: Primary Indicators (any one indicator is sufficient) Surface Water (A1) High Water Table (A2) Saturation (A3) Water Marks (B1) (Nonriverine) Sediment Deposits (B2) (Nonriverine) Drift Deposits (B3) (Nonriverine) Surface Soil Cracks (B6) Inundation Visible on Aerial Imagery (B7) Water-Stained Leaves (B9) Field Observations: Surface Water Present? Water Table Present? Yes Yes No No Depth (inches): Depth (inches): Yes No Salt Crust (B11) Biotic Crust (B12) Aquatic Invertebrates (B13) Hydrogen Sulfide Odor (C1) Oxidized Rhizospheres along Living Roots (C3) Presence of Reduced Iron (C4) Recent Iron Reduction in Plowed Soils (C6) Other (Explain in Remarks) Secondary Indicators (2 or more required) Water Marks (B1) (Riverine) Sediment Deposits (B2) (Riverine) Drift Deposits (B3) (Riverine) Drainage Patterns (B10) Dry-Season Water Table (C2) Thin Muck Surface (C7) Crayfish Burrows (C8) Saturation Visible on Aerial Imagery (C9) Shallow Aquitard (D3) FAC-Neutral Test (D5)

2

Saturation Present? Depth (inches): 6 Yes No Wetland Hydrology Present? (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available: Remarks:

US Army Corps of Engineers WestWater Engineering Page 75 of 75 Arid West - Version 11-1-2006 January 2008

Jurisdiction Determination July 2, 2008

Jurisdictional Determination Request December 5, 2007

2516 FORESIGHT CIRCLE, #1

GRAND JUNCTION, COLORADO 81505

(970) 241-7076

FAX: (970) 7097

December 5, 2007
Mark Gilfillan US Army Corps of Engineers 400 Rood Avenue, Room 142 Grand Junction, CO 81501
Via email: Bill_Killam@urscorp.com jeffrey_dawson@urscorp.com

RE:

Jurisdictional Determination Request: Part 1, Identifying Potential Waters of the US CAM Colorado LLC Coal Mine and Rail Spur Project Mesa County and Garfield County, Colorado

Mr. Gilfillan: WestWater’s request for a non-Jurisdiction Determination for Part 1, Potential Waters of the US portion of the CAM Railroad is attached for your review. Feel free to contact our office if you have questions, or if we can be of service in any way. Sincerely,

Brett F. Fletcher Environmental Scientist/ Wetland Biologist

Attachments cc URS, B. Killam URS, J. Dawson

Jurisdictional Determination Request Proposed CAM Colorado LLC Red Cliff Mine and Rail Spur Mesa County, Colorado December 2007 This is a request for U.S. Army Corps of Engineers (COE) jurisdictional determination and confirmation of a wetland delineation performed on the site of the proposed Red Cliff Mine and related rail spur, north of Mack, Colorado (Figure 1). The delineation was performed by WestWater Engineering (WestWater) biologists on the following dates: June 19, 20, 21, Aug. 17, Nov. 17, 18, 20, 21, 27, Dec. 8, 18, 2006 and Feb. 23, 24, 2007. Wetlands were delineated in accordance with COE standards included in the “Corps of Engineers Wetlands Delineation Manual, Environmental Laboratory, Vicksburg, MS, January 1987” and the “U.S. Army Corps of Engineers Jurisdictional Determination Form Instructional Guide Book” (May 30, 2007). Background Wetland delineation was performed during the 2006 growing season while irrigation of nearby agricultural areas was underway. Recent (2005 and 2006) precipitation has been near normal for the Grand Valley, unlike the preceding drought years (2002 through 2004), so related wetland characteristics were considered likely to be in a relatively normal condition as well. CAM Colorado proposes to develop a coal mine facility on approximately 1,886 acres of Bureau of Land Management land at the Red Cliff Mine site in the southwest corner of Garfield County. Development of the mine will also require the construction of approximately 15 miles of rail spur on public and private lands in Mesa and Garfield Counties to transport coal from the mine facility to the Union Pacific Railroad south of Mack, Colorado. Based on maps of the proposed railroad right of way and the proposed mine facility provided by CAM Colorado, WestWater Biologists surveyed the approximately 2,450 acre project site and surrounding areas to identify and delineate potential wetlands and waters of the United States (WOUS) within and adjacent to proposed construction boundaries (Figure 1). At the request of the COE the project was divided into two parts: 1. Request for a Jurisdictional determination identifying potential non-wetland WOUS. 2. Request for confirmation of Wetland delineation and Jurisdictional determination. Delineation Methods Drainages were identified as potentially jurisdictional WOUS based on the drainage’s Ordinary High Water Mark (OHWM) and the drainages ability to contribute flow to a Relatively Permanent Water (RPW), Traditional Navigable Water (TNW), or drainages that form a significant nexus with a TNW. Significant nexus determinations were made by examining the functions that may significantly affect the chemical, physical, and biological integrity of downstream TNWs or contributing RPWs and Non-RPWs. Additionally, these drainages were evaluated for potential to transport sediment and/or pollutants into a TNW or RPW. Where evidence of flow was apparent, drainages were walked downstream to determine the likelihood that the storm water flow eventually connected to RPWs or TNWs of the United States. NonWestWater Engineering Page 1 of 24 COE Jurisdictional Determination Request

RPW drainage measurements were made at the proposed railroad centerline crossing and included depth and width at OHWM. Locations of potentially jurisdictional drainages were recorded using handheld GPS units (Datum: NAD 83) and mapped electronically onto aerial photographs. The East Salt Creek drainage area was divided into sub-basin drainages that were measured from rail spur drainage crossing points upstream. Sub-basin crossing points were then grouped by the general location within larger drainage basins. Group distances, in river miles, were measured to the TNW (Colorado River) from the crossing point nearest to the RPW East Salt Creek in each group. In-channel flow distances (river miles) to RPW’s and TNW’s were measured from aerial photos (Tables 1 and 2; Figures 2 and 3). These measurements were used to evaluate each of the individual drainage’s potential to affect the physical, chemical, and biological integrity of the down stream TNW. Table 1. River mile distance from southern most point in grouped crossings to TNW Colorado River
Distance to TNW (river miles) 5.700 11.271 11.932 14.165 14.916 17.786 20.014 19.464 Sub-Drainage Measuring Point W006 V017 V024 W035 W041 W075 W080 V057 Crossing Point Groups W002-W022 and V001-V016 W023-W031 and V017-V023 W-032-W033 and V024-V029 W-034-W040 and V030-V036 W-041-W074 and V037-V050 W-075-W079 and V051-V052 W-079-W086B and V053-V054 W-100-W111B and V055-V060

Delineation Findings WestWater located one RPW Perennial Stream (Mack Wash), one irrigation ditch (Government Highline Canal (GHC)), and examined approximately 180 washes within the project area. Drainage crossing points (W002-W086B and V001-V054) are located along the proposed railroad alignment, and crossing points (W100-W111B) are located within the proposed mine facility site and along the existing access road to the facility site. The locations of washes are shown on attached Figures 2 and 3. UTM coordinates of washes are listed in Table 2. The RPW perennial stream is Mack Wash, which was measured near the old Hwy 50 Bridge. Information pertaining to Mack Wash and its abutting and adjacent wetlands will follow in the second JD and request for wetland delineation confirmation for this project. The majority of the washes examined in this report are north of GHC. All of these washes drain to the west and are part of the East Salt Creek Drainage area. Soils in the East Salt Creek drainage area are mapped as the Persayo series which consist of shallow well-drained soils that occupy slopes from 3-25%. Vegetation primarily consists of saltbush, rabbitbrush, galletagrass, Indian ricegrass, and cheat grass. Annual precipitation for the east Salt Creek drainage ranges from 9.18 inches in the valley to 23 inches in the higher elevations of the Book Cliffs (NWCC 2007).
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Points W011-W019 originate from an old irrigation ditch constructed on the upland terrace that runs along the west side of Mack Mesa. The ditch is no longer functional and has numerous failures along its length. Eroded gullies have developed below many of the failures in the ditch and were not considered to be jurisdictional tributaries (COE 2007a). Points V001-V060 are believed to be non-jurisdictional due to lack of OHWM. These drainages also lacked evidence of flow and contained perennial and annual vegetation in the drainage bottoms, absence of evidence of flow such as shelving and detritus build up, and lack of connectivity to other WOUS. Points W002-W111B are drainages that showed some evidence of an OHWM. The OHWMs within these washes were inconsistent and lack continuity in their flow path to RPW East Salt Creek. These drainages were further evaluated for their potential to significantly alter the physical, chemical, and biological properties of down stream TNW in a significant nexus evaluation. Photos representing typical washes and drainage basins within the project area are in Appendix A – they are labeled by crossing points in Table 2 and mapped in Figures 2 and 3. Significant Nexus Evaluation Physical These dry washes are believed to be non-RPW’s with no abutting or adjacent wetlands and are contained within the East Salt Creek drainage. The East Salt Creek drainage covers approximately 225 square miles of which approximately 151 square miles are part of the Book Cliffs geographic area to the north of the project area. The proposed project utilizes approximately 16 of the remaining 74 square miles of the lower East Salt Creek drainage. The Book Cliffs provide snow melt and spring runoff from elevations up to 8500 ft. The lower valley of East Salt drainage receives 9.18 inches of precipitation annually with most of the volume of flow in the washes associated with precipitation events between the months of April and October (NWCC 2007). Typically high flow volumes in neighboring drainages are associated with October precipitation events; however, the spring runoff month of May contributed the highest average flow volume in East Salt Creek over the gauging period of record. Spring flows are related to snow melt from the 14 miles the East Salt Creek drainage extends into the Book Cliffs. Peak flows at the gauging station in East Salt Creek averaged 30 cfs and are typically sustained for an average of 15 days during the months of peak runoff. Intermittent flows in East Salt Creek outside of the peak runoff months average less than 5 cfs. The USGS gauging station 9163310 in East Salt Wash (recording period 1973-1982), is located 4.5 straight miles and 7.92 river miles upstream from the confluence of the East and West Salt Wash (RPW) and measured run off for 197 square miles of drainage area (USGS 2007). Discharges from storm events are localized into small drainages and are the result of fast moving microburst storms (NWCC 2007). Spatial storm variation can produce runoff in one wash and none in another; variation of precipitation can be as much as 0.4 inches between small drainages within 0.5 linear miles of each other, resulting in intermittent and inconsistent surface water connections between sub-basins and the nearest RPW (USGS 1956-1972). A 2-year
WestWater Engineering Page 3 of 24 COE Jurisdictional Determination Request

precipitation event is 1 inch in 24 hours. It is unlikely that a storm of this magnitude would extend over the entire East Salt Creek drainage area. Runoff generated from such an event is estimated at approximately 0.03 cfs per acre and drainage basins within the project impacted area could potentially produce 195 cfs. The proposed dry wash crossings are located in the upper reaches of drainage basins. The dry wash crossing points range from approximately 0.5 miles to 20 plus miles (river miles) away from East Salt Wash (the nearest RPW) and an additional 5 to 10 miles from the nearest TNW, the Colorado River. Individual drainages average 38.55 acres, the smallest being 0.2 acres and the largest being 951 acres. Some of the smaller drainage basin areas are contained within boundaries of larger drainage basins. The total area of all individual drainages represent less than 0.04% of the total drainage area in the East Salt Creek drainage basin and less than 0.02% of the total area of the Salt Creek Watershed contributing to the nearest TNW, Colorado River. Drainage information is contained in Table 2. Washes in drainage basins with areas of 35 acres or larger typically had channels with a predominantly gravel substrate with some sand and cobble. These channels were evaluated throughout their individual lengths to the point where the OHWM was no longer clear and distinct and surface water connectivity was no longer evident. The largest drainage basin, 951 acres, within the project impact area contributes to crossing point W100. The wash disperses 1.5 miles below crossing point W100 forming an alluvial fan. Weak indicators of OHWM and perennial and annual vegetation growing in the channel bottoms were observed at the time of survey. Changes in the channel as it flows downstream are depicted in a sequence of pictures provided in Appendix B. The photos illustrate changes in the OHWM and lack of surface water connectivity. Similar trends are present in the large drainages to the south below grouped points W080, W075, W041, and W035. Chemical No water was present in washes during the time of survey. Potential railroad crossing points are typically located in upper reaches of the individual drainage basins and even in high intensity localized precipitation events are not considered capable of contributing significant sediment and nutrients or transporting pollutants to down stream RPWs. The Salt Creek watershed extends 30 aerial miles from the Colorado River to the Book Cliffs. Elevation at the base of the Book Cliffs is 5,486 ft; elevations in the Book Cliff portion of the watershed exceed 8,000 ft. The range of elevation in the project area is 4,400 to 5,200 ft. Spring runoff events are associated with precipitation and snow melt from the higher elevations. Snow accumulation below 5,500 ft. is minimal and seldom remains on the ground for more than a few days (NWCC 2007). Chemical transport functions of the drainages is most likely insignificant; however, during severe wide spread precipitation events the washes could connect with East Salt Creek (RPW) and transport sediment and potential pollutants downstream. Naturally occurring selenium in Mancos shale could be transported during these events.

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Biological No aquatic species are supported by the washes within the project area, however, incidental use by terrestrial species characteristic of the salt desert shrub community occurs. Species common to the project area include deer, elk, pronghorn antelope, mountain lion, bobcat, badger, cottontail rabbits, white-tailed prairie dogs, and a number of small rodents. Several U.S. Fish and Wildlife Service Birds of Conservation Concern (BOCC) were observed by WestWater Biologists during the project survey including: Northern Harrier, Burrowing Owl, and Golden Eagle. Red-tailed Hawks and Great-horned Owls were also observed (CDOW 2007 and FWS 2002). The long-nosed leopard lizard and Grand Buckwheat (Eriogonum contortum), reside in the project area and are considered sensitive species by the BLM and state special concern species by the Colorado Division of Wildlife (CNHP 1997, CDOW 2007 and FWS 2002). Summary of Significant Nexus Findings The dry washes would be impacted in the upper reaches of drainage basins in the East Salt Creek Drainage (ESCD). The ESCD drainage receives most of its flow volume from spring snow melt in the Book Cliffs and the impacted project area represents a small portion, less than 3%, of the total drainage area. There is no surface water connection to RPW’s and the OHWM is discontinuous and inconsistent in drainage channels. Variations in precipitation intensity and spatial distribution further decrease the ability of the washes to transfer nutrients, sediment, or pollution to down stream RPW’s. No aquatic species are supported by the washes within the project area, however, incidental use by terrestrial species characteristic of the salt desert shrub community occur. Based on findings in the significant nexus evaluation, dry wash tributaries within the proposed project impact area were found to have no more than an insignificant and speculative impact on the physical, chemical, and biological integrity of the down stream TNW (Colorado River) or its RPW tributaries. There is no information available to show that these washes: 1) are or could be used by interstate or foreign travelers for recreational or other purposes, 2) produce fish or shellfish which are or could be taken and sold in interstate or foreign commerce, or 3) are or could be used for industrial purposes by industries in interstate commerce (COEa 2007).

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Table 2. Crossing Locations (UTM NAD 83, zone 12) Depth, Width, Distance from TNW, Drainage Area, and Group Measuring Point
Crossing point W001 W002 W003 W004 W005 W006 W008 W009 W010 W011 W012 W013 W014 W015 W016 W017 W018 W019 W020 W021 W022 W023 W024 W025 W026 W027 W028 W029 W030 W031 W032 W033 W34 W35 W36 W37 W38 W39 W40 W41 W42 W43 W44 W45 W46 W47 Easting 683112 683106 683106 683107 683114 683113 683114 683125 683159 683185 683199 683203 683217 683244 683271 683288 683353 683362 683382 683455 683470 683817 683881 684352 684420 684428 684481 684562 684763 684831 685432 685366 685377 685464 685504 685730 685796 685963 686152 686319 686388 686576 686661 686704 686773 686945 Northing 4345238 4345362 4345429 4345466 4345549 4345555 4345677 4345701 4345789 4345911 4345968 4345987 4346051 4346169 4346291 4346365 4346657 4346684 4346790 4347106 4347179 4348833 4348929 4349270 4349314 4349331 4349381 4349438 4349607 4349683 4351065 4351276 4351643 4351727 4351762 4351964 4352066 4352302 4352559 4352670 4352708 4352795 4352847 4352856 4352902 4353090 Depth (Inches) Width (Inches) River miles to TNW from group measuring point 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 11.271 11.271 11.271 11.271 11.271 11.271 11.271 11.271 11.271 11.932 11.932 14.165 14.165 14.165 14.165 14.165 14.165 14.165 14.916 14.916 14.916 14.916 14.916 14.916 14.916 Drainage Area square (miles) 0.00251 0.00036 0.00415 0.00866 0.01451 0.00405 0.00669 0.01561 0.00141 0.00379 0.00669 0.01406 0.00666 0.00401 0.02193 0.02011 0.01554 0.02696 0.03210 0.07060 0.00493 0.01061 0.02971 0.01490 0.01343 0.00226 0.00130 0.00529 0.00481 0.00133 0.01438 0.00297 0.01844 0.04390 0.00859 0.02109 0.05173 0.04230 0.00074 0.00387 0.00342 0.00528 0.00098 0.01151 0.00582 Drainage Area (Acres) 1.61 0.23 2.66 5.54 9.28 2.60 4.28 9.99 0.90 2.43 4.28 9.00 4.26 2.57 14.04 12.87 9.94 17.25 20.55 45.18 3.15 6.79 19.01 9.54 8.59 1.44 0.83 3.39 3.08 0.85 9.20 1.90 11.80 28.10 5.50 13.50 33.10 27.07 0.47 2.47 2.19 3.38 0.63 7.36 3.72 River Miles Measuring Point for Groups Irrigation ditch W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 V017 V017 V017 V017 V017 V017 V017 V017 V017 V024 V024 W035 W035 W035 W035 W035 W035 W035 W041 W041 W041 W041 W041 W041 W041

3.96 3 3 2.4 3.6 4.8 5.4 4.2 6 3.6 3 3.6 4.2 2.4 1.8 2 1 1.73 1.75 2 2.4 1 2 1 0.75 1.5 0.75 1.75 1.5 0.5 2 1.75 4 3 8.5 6 8.5 3.75 4 6.75 2.25 2 1.75 5.25 1.5

49.2 6 21.6 21.6 16.8 21.6 20.4 13.2 30 18 24 7.2 33.6 3.6 6 11 12 13 12 6 4.8 10 6 5 13 8 11 8 6 27.5 33 29 41 38 89 65 56 49 15 23.25 31.5 25.25 15 33 17.5

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Table 2. Crossing Locations (UTM NAD 83, zone 12) Depth, Width, Distance from TNW, Drainage Area, and Group Measuring Point
Crossing point W48 W49 W50 W51 W52 W53 W54 W55 W56 W57 W58 W59 W60 W61 W62 W63 W64 W65 W66 W67 W68 W69 W70 W71 W72 W73 W74 W75 W76 W77 W78 W79 W80 W81 W82A W82B W82C W82D W82E W82F W83A W83B W84A W84B W84C W84D Easting 687038 687092 687189 687262 687396 687441 687519 687752 687833 687879 687972 688500 688576 688603 688675 688803 688922 689052 689110 689110 689153 689162 689150 689181 689204 689228 689228 689248 689656 690478 690483 690497 690414 690962 690842 691093 691132 691156 691153 691152 690811 691070 690793 690914 690960 690966 Northing 4353198 4353347 4353509 4353635 4353717 4353732 4353738 4353686 4353665 4353647 4353629 4353923 4353954 4353980 4354014 4354143 4354244 4354352 4354485 4354526 4354746 4354817 4354858 4354940 4355076 4355163 4355215 4355383 4355696 4357242 4357462 4358276 4358810 4358733 4358874 4358790 4358851 4358925 4358951 4358980 4358945 4359084 4359015 4359193 4359235 4359337 Depth (Inches) 1.75 3.75 3.25 3.75 6 3.75 4.5 5.5 4.25 2 3.5 5 5.5 8.5 3 5.75 11.75 7.5 8.75 6.25 2.5 3.25 6.5 5.5 9 2 10.25 8.25 4.5 4.75 3.75 3.5 9.75 6.25 12.75 6.25 3.75 3.25 8.25 5.5 8.5 7.5 12.5 9 6 6 Width (Inches) 22.5 31.5 18.5 29 31 42 88.5 47 31.5 20 33.75 21.5 24 28.25 22 21.5 45.25 30.75 89.75 60.5 25 10.5 33 18.75 37.75 13.5 51 38.75 24.75 37.5 26.75 16 67.5 13 31.5 13 15.75 10.5 18.75 9.25 31.75 18 57.75 43.5 30.5 19.75 River miles to TNW from group measuring point 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 17.786 17.786 17.786 17.786 19.742 19.742 19.742 19.742 19.742 19.742 19.742 19.742 19.742 19.742 19.742 19.742 19.742 19.742 19.742 Drainage Area square (miles) 0.00507 0.00956 0.01337 0.00209 0.00776 0.00251 0.02920 0.02215 0.00960 0.00192 0.00808 0.00341 0.00579 0.00187 0.01845 0.01870 0.04339 0.00886 0.11719 0.01524 0.00466 0.00089 0.00487 0.00067 0.00673 0.00034 0.02936 0.02384 0.00538 0.03173 0.30972 0.04258 0.54003 0.31955 0.03806 0.00295 0.00057 0.00188 0.01056 0.00216 0.03112 0.01817 0.08697 0.06221 0.01463 0.01484 Drainage Area (Acres) 3.25 6.12 8.56 1.34 4.96 1.60 18.69 14.17 6.14 1.23 5.17 2.18 3.71 1.20 11.81 11.97 27.77 5.67 75.00 9.76 2.98 0.57 3.12 0.43 4.31 0.22 18.79 15.26 3.44 20.31 198.22 27.25 345.62 204.51 24.36 1.89 0.36 1.20 6.76 1.39 19.92 11.63 55.66 39.81 9.36 9.50 River Miles Measuring Point for Groups W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W075 W075 W075 W075 W079 W079 W079 W079 W079 W079 W079 W079 W079 W079 W079 W079 W079 W079 W079

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Table 2. Crossing Locations (UTM NAD 83, zone 12) Depth, Width, Distance from TNW, Drainage Area, and Group Measuring Point
Crossing point W84E W85 W86A W86B W100 W101 W102 W103 W104 W105 W106A W106B W106C W106D W106E W107A W107B W107C W107D W107E W108 W109 W110A W110B W110C W110D W111A W111B V001 V002 V003 V004 V005 V006 V007 V008 V009 V010 V011 V012 V013 V014 V015 V016 V017 V018 Easting 690935 690591 690647 690825 689630 691763 691208 691224 691220 691274 691192 691512 692430 692321 692776 690842 691538 691752 691899 691658 690962 690929 690970 691061 691313 691439 691109 691744 683205 683224 683295 683307 683404 683435 683493 683521 683567 683604 683709 683731 683744 683762 683785 684050 684240 684240 Northing 4359500 4359267 4359513 4359491 4359049 4359691 4359822 4359866 4359895 4360006 4360061 4360309 4360606 4361578 4362012 4360358 4360466 4360852 4361286 4360831 4360704 4360515 4360740 4360765 4360867 4360875 4361037 4361539 4345997 4346081 4346397 4346447 4346881 4347025 4347272 4347339 4347412 4347466 4347651 4347894 4348191 4348597 4348750 4349076 4349230 4349231 Depth (Inches) 9.5 9 19 4.25 10.25 7.25 3.25 3.75 6.75 3.5 7 7.25 4.75 5.5 11.5 12.5 6.25 13.5 4 5 5 4.75 4.75 5 4.25 14.75 12.5 Width (Inches) 15.75 33.75 20.25 9.25 140 48 11.25 19 28 25.5 98 50 75 45 62.5 92.5 50.25 29.75 38.25 25.75 15.25 14.25 23.25 15.25 25.25 17 57.75 105.8 River miles to TNW from group measuring point 19.742 19.742 19.742 19.742 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 19.464 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 5.700 11.271 11.271 Drainage Area square (miles) 0.01609 0.00947 0.01408 0.00096 1.48543 0.10269 0.00234 0.00105 0.00802 0.00546 0.89775 0.86013 0.21314 0.33817 0.03925 0.22236 0.16061 0.06675 0.01513 0.01952 0.01907 0.02068 0.02505 0.02086 0.00769 0.00311 0.15544 0.01432 Drainage Area (Acres) 10.30 6.06 9.01 0.61 950.67 65.72 1.50 0.67 5.13 3.50 574.56 550.48 136.41 216.43 25.12 142.31 102.79 42.72 9.69 12.49 12.21 13.23 16.03 13.35 4.92 1.99 99.48 9.16 River Miles Measuring Point for Groups W079 W079 W079 W079 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 V057 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 W006 V017 V017

0.02776

17.77

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Table 2. Crossing Locations (UTM NAD 83, zone 12) Depth, Width, Distance from TNW, Drainage Area, and Group Measuring Point
Crossing point V019 V020 V021 V022 V023 V024 V025 V026 V027 V028 V029 V030 V031 V032 V033 V034 V035 V036 V037 V038 V039 V040 V041 V042 V043 V044 V045 V046 V047 V048 V049 V050 V051 V052 V053 V054 V055 V056 V057 V058 V059 V060 Easting 684587 684615 685051 685206 685590 685471 685442 685443 685411 685375 685330 685543 685646 685784 685886 686018 686059 686099 686360 686503 686753 686861 686905 686961 687106 687127 687166 687360 687708 688219 688831 689138 689314 690481 690472 691134 691022 688260 691350 691351 690756 690825 Northing 4349463 4349491 4349884 4350009 4350428 4350921 4351017 4351017 4351128 4351246 4351501 4351793 4351870 4352018 4352173 4352369 4352429 4352489 4352679 4352754 4352888 4352971 4353015 4353080 4353339 4353387 4353481 4353701 4353707 4353685 4354163 4354646 4355534 4357386 4359000 4359032 4359122 4358220 4359906 4359907 4359581 4359584 Depth (Inches) Width (Inches) River miles to TNW from group measuring point 11.271 11.271 11.271 11.271 11.271 11.932 11.932 11.932 11.932 11.932 11.932 14.165 14.165 14.165 14.165 14.165 14.165 14.165 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 14.916 17.786 17.786 19.742 19.742 19.464 19.464 19.464 19.464 19.464 19.464 Drainage Area square (miles) Drainage Area (Acres) River Miles Measuring Point for Groups V017 V017 V017 V017 V017 V024 V024 V024 V024 V024 V024 W035 W035 W035 W035 W035 W035 W035 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W041 W075 W075 W079 W079 V057 V057 V057 V057 V057 V057

0.00069 0.00449

0.44 2.87

0.01811

11.59

Crossing points V001-V060 did not have indicators of an OHWM, so width, depth, and areas were not measured, except for points (V017,024,025,and 057) that were utilized to estimate group distances to the Colorado River.

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PROJECT INFORMATION
Project Proponent: CAM Colorado, LLC 116 Main Street Pikeville, KY 41501 Mr. Nicholas R. Glancy CAM Colorado PO Box 1169 Pikeville, KY 41502 (859) 389-6500 CAM Colorado, LLC 116 Main St. Pikeville, KY 41501 United States Bureau of Land Management Grand Junction Field Office 2815 H Road Grand Junction, CO 81506 Hudson Ranch Estates of Great Western Colorado LLC P.O. Box 123 Mack, CO 81525 Vernon Langford 1725 10 Road Mack, CO 81525 Joseph Bennett P.O. Box 59 Mack, CO 81525 Michael J Ballew 1852 10 Road Mack, CO 81525 Doug Johnson 1833 11 Road Loma, CO 81524 State of Colorado Dept. of Natural Resources 1313 Sherman Street Denver, CO 80203 Joanne M Leishuck 1910 10 Road. Mack, CO 81525 #11 Enterprises 1218 Webster Street Houston, TX 77002 URS Corporation 8181 East Tufts Avenue Denver, CO 80237 WestWater Engineering 2516 Foresight Circle #1 Grand Junction, CO 81505 URS Corporation 8181 East Tufts Avenue Denver, CO 80237 Ph: (303)-740-3816

Proponent Contact:

Land Owners:

EIS Consultant:

Wetland Consultant:

Ph: (970) 241-7076 Fax: (970) 241-7097 Ph: (303)-740-3816

Project Location:

Mine Facility and Access Roads: Sections 3, 4, 9, 10, 15, 16, 17, 18, 19, T8S, R102W, 6th PM Rail Spur: Sec. 16, 21, 20, 29, 31, 32 T8S, R102W, 6th PM; Sec. 36, T8S, R103W, 6th PM; Sec. 1, 2, 11, 14, T9S, R103W, 6th PM; Sec. 6, 19, T2N, R3W, Ute PM; & Sec. 15, 22, 27, 34, T2N, R103W, 6th PM Red Cliff Coal Mine and associated facilities supporting the proposed coal mine project.

Project Description:

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References CDOW. 2007. Colorado Division of Wildlife, Colorado Department of Natural Resources http://wildlife.state.co.us/WildlifeSpecies/SpeciesOfConcern/Reptiles/ CDSS. 2007. Colorado Decisions Support Systems. http://cdss.state.co.us/DNN/Stations/tabid/74/Default.aspx COE. 2007a. U.S. Army Corps of Engineers, 33 CFR Regulatory Regulations. http://www.sac.usace.army.mil/permits/33cfr.html [33 CFR 328.3(a)(3)(i-iii) and (a)(5)]. COE. 2007b. U.S. Army Corps of Engineers, Regulatory Guidance Letter 07-02. Subject: Exemptions for Construction or Maintenance of Irrigation Ditches and Maintenance of Drainage Ditches under Section 404 of the Clean Water Act. COE. 2007c. U.S. Army Corps of Engineers Jurisdictional Determination Form Instructional Guidebook. Prepared Jointly by U.S. Army Corps of Engineers and U.S. Environmental Protection Agency. Environmental Law Institute. 2007. The Clean Water Act Jurisdictional Handbook. Washington, DC. FWS. 2002. Birds of conservation concern 2002. U.S. Fish and Wildlife Service, Division of Migratory Bird Management, Arlington, Virginia. NRCS. 2007. National Resource Conservation Service. http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx NWCC. 2007. National Water and Climate Center, National Resource Conservation Service. ftp://ftp.wcc.nrcs.usda.gov/support/climate/wetlands/co/08077.txt Spackman, S., B. Jennings, J. Coles, C. Dawson, M. Minton, A. Kratz, and C. Spurrier. 1997. Colorado Rare Plant Field Guide. Prepared for the U.S. Bureau of Land Management, the U.S. Forest Service and the U.S. Fish and Wildlife Service by the Colorado Natural Heritage Program (CNHP). U.S. Department of Commerce. 1973. NOAA Atlas 2: Precipitation- Frequency Atlas of the Western United States, Volume III-Colorado. National Oceanic and Atmospheric Administration, Silver Spring, Maryland. USGS. 1956-1972. Annual Reports on: Badger Wash Cooperative Study, Precipitation, Runoff, and Sediment Yield. U.S. Department of the Interior, U.S. Geological Survey, Washington, DC. USGS. 2007. Colorado Water Science Center, Colorado Current and Historical Water Data Online, U.S. Geological Survey. http://waterdata.usgs.gov/co/nwis/sw

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APPROVED JURISDICTIONAL DETERMINATION FORM U.S. Army Corps of Engineers This form should be completed by following the instructions provided in Section IV of the JD Form Instructional Guidebook. SECTION I: BACKGROUND INFORMATION A. REPORT COMPLETION DATE FOR APPROVED JURISDICTIONAL DETERMINATION (JD): B. DISTRICT OFFICE, FILE NAME, AND NUMBER:

C. PROJECT LOCATION AND BACKGROUND INFORMATION: CAM Colorado proposes to develop a coal mine facility on approximately 1,886 acres of Bureau of Land Management land at the Red Cliff Mine site in the southwest corner of Garfield County. Development of the mine will also require the construction of approximately 15 miles of rail line on public and private lands in Mesa County to transport coal from the mine facility to the Union Pacific Railroad south of Mack, Colorado. Based on maps of the proposed railroad right of way and the proposed mine facility provided by CAM Colorado, WestWater Biologists surveyed the approximately 2,450 acre project site and surrounding areas to identify and delineate potential wetlands and waters of the U.S.(WOUS) within and adjacent to proposed construction boundaries. At the request of the COE the project was divided into two parts: 1. Request for a Jurisdictional Determination identifying potential non-wetland WOUS. 2. Request for confirmation of Wetland Delineation and Jurisdictional Determination. This is part 1, Jurisdictional Determination of non-wetland Waters of the US. County/parish/borough: Mesa City: Mack State: CO Center coordinates of site (lat/long in degree decimal format): Lat. 39.3183° N,Long. -108.8072° E. Universal Transverse Mercator: Name of nearest waterbody: Salt Creek, RPW Name of nearest Traditional Navigable Water (TNW) into which the aquatic resource flows: Colorado River Name of watershed or Hydrologic Unit Code (HUC): 14010005 Check if map/diagram of review area and/or potential jurisdictional areas is/are available upon request. Check if other sites (e.g., offsite mitigation sites, disposal sites, etc…) are associated with this action and are recorded on a different JD form. D. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT APPLY): Office (Desk) Determination. Date: Field Determination. Date(s):

SECTION II: SUMMARY OF FINDINGS A. RHA SECTION 10 DETERMINATION OF JURISDICTION. There Are no “navigable waters of the U.S.” within Rivers and Harbors Act (RHA) jurisdiction (as defined by 33 CFR part 329) in the review area. [Required] Waters subject to the ebb and flow of the tide. Waters are presently used, or have been used in the past, or may be susceptible for use to transport interstate or foreign commerce. Explain: . B. CWA SECTION 404 DETERMINATION OF JURISDICTION. There Are no “waters of the U.S.” within Clean Water Act (CWA) jurisdiction (as defined by 33 CFR part 328) in the review area. [Required] 1. Waters of the U.S. a. Indicate presence of waters of U.S. in review area (check all that apply): 1 TNWs, including territorial seas Wetlands adjacent to TNWs Relatively permanent waters2 (RPWs) that flow directly or indirectly into TNWs Non-RPWs that flow directly or indirectly into TNWs Wetlands directly abutting RPWs that flow directly or indirectly into TNWs Wetlands adjacent to but not directly abutting RPWs that flow directly or indirectly into TNWs Wetlands adjacent to non-RPWs that flow directly or indirectly into TNWs Impoundments of jurisdictional waters Isolated (interstate or intrastate) waters, including isolated wetlands b. Identify (estimate) size of waters of the U.S. in the review area:
1 2

Boxes checked below shall be supported by completing the appropriate sections in Section III below. For purposes of this form, an RPW is defined as a tributary that is not a TNW and that typically flows year-round or has continuous flow at least “seasonally” (e.g., typically 3 months).

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Non-wetland waters: Wetlands: acres.

linear feet:

width (ft) and/or

acres.

c. Limits (boundaries) of jurisdiction based on: Not established at this time. Elevation of established OHWM (if known): . 2. Non-regulated waters/wetlands (check if applicable):3 Potentially jurisdictional waters and/or wetlands were assessed within the review area and determined to be not jurisdictional. Explain:

Mack Wash crossing is an RPW crossing that will be evaluated in the (Part 2) request for confirmation of Wetland Delineation and Jurisdictional Determination. Crossing Points W011-W019 originate from an irrigation ditch constructed on the upland terrace that runs along the west side of Mack Mesa. The ditch is no longer functional and has numerous failures along its length. Eroded gullies have developed below many of the failures in the ditch and were not considered to be jurisdictional tributaries. The irrigation ditch was constructed in upland and is not considered to be jurisdictional. Crossing Points V001-060 are points that were considered to be non-jurisdictional due to lack of OHWM. These drainages also lacked evidence of flow and contained perennial and annual vegetation in the drainage bottoms, absence of evidence of flow such as shelving and detritus build up, and lack of connectivity to other waters of the U.S. Crossing Points W002-W111B are drainages that showed some evidence of an OHWM. These drainages were further evaluated for their potential to significantly alter the chemical, biological, or physical properties of down stream TNWs. Information on these washes is provided in Section III, B-1. The washes within the proposed project impact area have an insignificant and speculative impact on the physical, chemical, and biological integrity of the down stream TNW (Colorado River) or its tributaries. There is no information available to show that these washes: 1) is or could be used by interstate or foreign travelers for recreational or other purposes, 2) produces fish or shellfish which are or could be taken and sold in interstate or foreign commerce, or 3) is or could be used for industrial purposes by industries in the interstate commerce.

3

Supporting documentation is presented in Section III.F.

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SECTION III: CWA ANALYSIS A. TNWs AND WETLANDS ADJACENT TO TNWs The agencies will assert jurisdiction over TNWs and wetlands adjacent to TNWs. If the aquatic resource is a TNW, complete Section III.A.1 and Section III.D.1. only; if the aquatic resource is a wetland adjacent to a TNW, complete Sections III.A.1 and 2 and Section III.D.1.; otherwise, see Section III.B below. 1. TNW Identify TNW:

. .

Summarize rationale supporting determination: 2.

Wetland adjacent to TNW Summarize rationale supporting conclusion that wetland is “adjacent”:

.

B.

CHARACTERISTICS OF TRIBUTARY (THAT IS NOT A TNW) AND ITS ADJACENT WETLANDS (IF ANY): This section summarizes information regarding characteristics of the tributary and its adjacent wetlands, if any, and it helps determine whether or not the standards for jurisdiction established under Rapanos have been met. The agencies will assert jurisdiction over non-navigable tributaries of TNWs where the tributaries are “relatively permanent waters” (RPWs), i.e. tributaries that typically flow year-round or have continuous flow at least seasonally (e.g., typically 3 months). A wetland that directly abuts an RPW is also jurisdictional. If the aquatic resource is not a TNW, but has year-round (perennial) flow, skip to Section III.D.2. If the aquatic resource is a wetland directly abutting a tributary with perennial flow, skip to Section III.D.4. A wetland that is adjacent to but that does not directly abut an RPW requires a significant nexus evaluation. Corps districts and EPA regions will include in the record any available information that documents the existence of a significant nexus between a relatively permanent tributary that is not perennial (and its adjacent wetlands if any) and a traditional navigable water, even though a significant nexus finding is not required as a matter of law. If the waterbody4 is not an RPW, or a wetland directly abutting an RPW, a JD will require additional data to determine if the waterbody has a significant nexus with a TNW. If the tributary has adjacent wetlands, the significant nexus evaluation must consider the tributary in combination with all of its adjacent wetlands. This significant nexus evaluation that combines, for analytical purposes, the tributary and all of its adjacent wetlands is used whether the review area identified in the JD request is the tributary, or its adjacent wetlands, or both. If the JD covers a tributary with adjacent wetlands, complete Section III.B.1 for the tributary, Section III.B.2 for any onsite wetlands, and Section III.B.3 for all wetlands adjacent to that tributary, both onsite and offsite. The determination whether a significant nexus exists is determined in Section III.C below. 1. Characteristics of non-TNWs that flow directly or indirectly into TNW (i) General Area Conditions: Watershed size: 436 square miles Salt Creek Drainage area: 225 square miles East Salt Creek Average annual rainfall: 7.34 inches Average annual snowfall: 9.8inches 9.18 total annual precipitation

(ii) Physical Characteristics: (a) Relationship with TNW: Tributary flows directly into TNW. Tributary flows through 4 (or more) tributaries before entering TNW. Project waters are 10-15 river miles from TNW. Project waters are 1-2 river miles from RPW. Project waters are 2-5 aerial (straight) miles from TNW. Project waters are 1 (or less) aerial (straight) miles from RPW. Project waters cross or serve as state boundaries. Explain: N/A. Identify flow route to TNW5: Typically multiple dry washes combine before formation of a non-RPW tributary occurs. All NonRPW tributaries within the project area eventually join East Salt Creek (RPW). East Salt Creek and West Salt Creek (RPW) converge and flow into Mack Wash (RPW). Mack Wash then combines with Salt Creek (RPW) and flows into the Colorado River. Depending on their individual location within the East Salt Creek drainage basin non-RPW tributaries can be directly adjacent to RPW East Salt Creek or combine with as many as 16 non-RPW tributaries before reaching RPW East Salt Creek. Individual crossing distances from the Colorado River TNW varied from 5.7 river miles to more than 25 miles. Tributary stream order, if known: .
4 5

Note that the Instructional Guidebook contains additional information regarding swales, ditches, washes, and erosional features generally and in the arid West. Flow route can be described by identifying, e.g., tributary a, which flows through the review area, to flow into tributary b, which then flows into TNW.

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(b) General Tributary Characteristics (check all that apply): Tributary is: Natural Artificial (man-made). Explain: . Manipulated (man-altered). Explain: Project area contains pipelines, gas wells, powerlines, man made ponds, and roads. This area has been used for grazing cattle as well as an off-road recreation area. Tributary properties with respect to top of bank (estimate): Average width: 2.11 feet Average depth: 0.372 feet Average side slopes: 2:1. Primary tributary substrate composition (check all that apply): Silts Sands Concrete Cobbles Gravel Muck Bedrock Vegetation. Type/% cover: variable 0 to 10% Other. Explain: Substrate is largely dependent on the tributaries location within the sub-basins. Drainage heads are sandy and covered with perennial and annual vegetation. Basin confluences typically have more gravels and some cobbles with perennial vegetation bordering a narrow flow path that will ocasionally have some annuals growing in it. Basin flats are generally areas of heavy silt deposition dominated by woody perennials and scattered annuals. Tributary condition/stability [e.g., highly eroding, sloughing banks]. Explain: Banks are typically compact and erode only in extreme events; however, some washes exhibit deep entrenchment and show signs of sloughing banks in meanders. Presence of run/riffle/pool complexes. Explain: Tributaries tend to disperse and fan out in flat basins where water flows braid out, divide, and form new discrete channels. Confined channels above and below flat basins show signs of periodic pooling with silt accumulations. Tributary geometry: Meandering Tributary gradient (approximate average slope): less than 1% in basin flats and 1.5 to 30% in drainage basins. (c) Flow: Tributary provides for: Seasonal flow Estimate average number of flow events in review area/year: 20 (or greater) Describe flow regime: Flows are associated with precipitation events between the months April and October. Typically high flow volumes are associated with October precipitation events; however, the spring runoff month of May contributed the highest average flow volume in East Salt Wash over the gauging period of record. The East Salt Drainage is approximately 225 square miles of which approximately 151 square miles are part of the Book Cliffs that provides spring runoff from elevations up to 8500 ft. Other information on duration and volume: Discharges from storm events are localized into small drainages and are the result of fast moving microburst storms. Spatial storm variation can produce runoff in one wash and none in another. Measured variability of precipitation can be as much as 0.4 inches between small catchments within 0.5 linear miles of each other, resulting in a high variability of discharge rates within a small area. This also results in a low level of continuous surface water connectivity between basins and the nearest RPW. Average annual precipitation is 9.18 inches in areas south of the Book Cliffs and the percentage of precipitation to runoff ratios average 66% in neighboring washes. Surface flow is: Discrete and confined. Characteristics: Combination of discrete, confined, and sheet flow. Subsurface flow: No. Explain findings: Depth of impermeable Mancos shale (clay) to Dakota formation (sandstone) can be in excess of 1000 ft, which is typically where water table is found. Dye (or other) test performed: . Tributary has (check all that apply): Bed and banks OHWM6 (check all indicators that apply): clear, natural line impressed on the bank the presence of litter and debris changes in the character of soil destruction of terrestrial vegetation shelving the presence of wrack line vegetation matted down, bent, or absent sediment sorting leaf litter disturbed or washed away scour sediment deposition multiple observed or predicted flow events water staining abrupt change in plant community other (list): Discontinuous OHWM.7 Explain: Distinct OHWM indicators are lost as channel flows are dispersed over basin flats. The OHWM in down gradient channels are inconsistent. If factors other than the OHWM were used to determine lateral extent of CWA jurisdiction (check all that apply):
6 A natural or man-made discontinuity in the OHWM does not necessarily sever jurisdiction (e.g., where the stream temporarily flows underground, or where the OHWM has been removed by development or agricultural practices). Where there is a break in the OHWM that is unrelated to the waterbody’s flow regime (e.g., flow over a rock outcrop or through a culvert), the agencies will look for indicators of flow above and below the break. 7 Ibid.

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High Tide Line indicated by: oil or scum line along shore objects fine shell or debris deposits (foreshore) physical markings/characteristics tidal gauges other (list):

Mean High Water Mark indicated by: survey to available datum; physical markings; vegetation lines/changes in vegetation types.

(iii) Chemical Characteristics: Characterize tributary (e.g., water color is clear, discolored, oily film; water quality; general watershed characteristics, etc.). Explain: No Water was present in washes during time of survey. The Salt Creek watershed extends 30 aerial miles from the Colorado River in to the Book Cliffs. Topography is relatively flat 14 aerial miles to the base of the Book Cliffs. From the base of the Book Cliffs at 5486 ft., elevations in the watershed exceed 8000 ft. Spring runoff events are associated with snow melt from the higher elevations and snow accumulation below 5500 ft. is minimal and seldom remains as ground cover for more than a few days. The range in elevation of the project area is 4400 to 5200 ft. Chemical function is most likely insignificant, however, during severe wide spread precipitation events the washes could conect with East Salt Creek (RPW) and transport sediment and pollutants downstream. The naturally occuring selenium in mancos shale could be transported during these events. . Identify specific pollutants, if known:

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(iv) Biological Characteristics. Channel supports (check all that apply): Riparian corridor. Characteristics (type, average width): . Wetland fringe. Characteristics: . Habitat for: Federally Listed species. Explain findings: . Fish/spawn areas. Explain findings: . Other environmentally-sensitive species. Explain findings: Several US Fish and Wildlife Service Birds of Conservation Concern (BOCC) were observed the survey area including: Northern Harrier, Burrowing Owl, and Golden Eagle. The longnosed leopard lizard, a BLM sensitive species, and Grand Buckwheat (Eriogoneum contortum) a BLM sensitive plant species also reside in the project area. Aquatic/wildlife diversity. Explain findings: No aquatic species, however, incidental use by terrestrial species that are characteristic of the salt desert shrub community. 2. Characteristics of wetlands adjacent to non-TNW that flow directly or indirectly into TNW (i) Physical Characteristics: (a) General Wetland Characteristics: Properties: Wetland size: acres Wetland type. Explain: . Wetland quality. Explain: . Project wetlands cross or serve as state boundaries. Explain: (b) General Flow Relationship with Non-TNW: Flow is: Pick List. Explain: . Surface flow is: Pick List Characteristics: Subsurface flow: No. Explain findings: Dye (or other) test performed: . .

.

(c) Wetland Adjacency Determination with Non-TNW: Directly abutting Not directly abutting Discrete wetland hydrologic connection. Explain: Ecological connection. Explain: . Separated by berm/barrier. Explain: .

.

(d) Proximity (Relationship) to TNW Project wetlands are Pick List river miles from TNW. Project waters are Pick List aerial (straight) miles from TNW. Flow is from: Pick List. Estimate approximate location of wetland as within the Pick List floodplain. (ii) Chemical Characteristics: Characterize wetland system (e.g., water color is clear, brown, oil film on surface; water quality; general watershed characteristics; etc.). Explain: . Identify specific pollutants, if known: . (iii) Biological Characteristics. Wetland supports (check all that apply): Riparian buffer. Characteristics (type, average width): . Vegetation type/percent cover. Explain: . Habitat for: Federally Listed species. Explain findings: . Fish/spawn areas. Explain findings: . Other environmentally-sensitive species. Explain findings: . Aquatic/wildlife diversity. Explain findings: . 3. Characteristics of all wetlands adjacent to the tributary (if any) All wetland(s) being considered in the cumulative analysis: Pick List Approximately ( ) acres in total are being considered in the cumulative analysis.

For each wetland, specify the following: Directly abuts? (Y/N) Size (in acres) Directly abuts? (Y/N) Size (in acres)

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Summarize overall biological, chemical and physical functions being performed:

.

C.

SIGNIFICANT NEXUS DETERMINATION A significant nexus analysis will assess the flow characteristics and functions of the tributary itself and the functions performed by any wetlands adjacent to the tributary to determine if they significantly affect the chemical, physical, and biological integrity of a TNW. For each of the following situations, a significant nexus exists if the tributary, in combination with all of its adjacent wetlands, has more than a speculative or insubstantial effect on the chemical, physical and/or biological integrity of a TNW. Considerations when evaluating significant nexus include, but are not limited to the volume, duration, and frequency of the flow of water in the tributary and its proximity to a TNW, and the functions performed by the tributary and all its adjacent wetlands. It is not appropriate to determine significant nexus based solely on any specific threshold of distance (e.g. between a tributary and its adjacent wetland or between a tributary and the TNW). Similarly, the fact an adjacent wetland lies within or outside of a floodplain is not solely determinative of significant nexus. Draw connections between the features documented and the effects on the TNW, as identified in the Rapanos Guidance and discussed in the Instructional Guidebook. Factors to consider include, for example: • Does the tributary, in combination with its adjacent wetlands (if any), have the capacity to carry pollutants or flood waters to TNWs, or to reduce the amount of pollutants or flood waters reaching a TNW? • Does the tributary, in combination with its adjacent wetlands (if any), provide habitat and lifecycle support functions for fish and other species, such as feeding, nesting, spawning, or rearing young for species that are present in the TNW? • Does the tributary, in combination with its adjacent wetlands (if any), have the capacity to transfer nutrients and organic carbon that support downstream foodwebs? • Does the tributary, in combination with its adjacent wetlands (if any), have other relationships to the physical, chemical, or biological integrity of the TNW? Note: the above list of considerations is not inclusive and other functions observed or known to occur should be documented below: 1. Significant nexus findings for non-RPW that has no adjacent wetlands and flows directly or indirectly into TNWs. Explain findings of presence or absence of significant nexus below, based on the tributary itself, then go to Section III.D: The dry washes would be impacted in the upper reaches of drainage basins in the East Salt Creek Drainage (ESCD). The ESCD drainage receives most of its flow volume from spring snow melt in the Book Cliffs and the impacted project area represents a small portion, less than 3%, of the total drainage area. There is no surface water connection to RPW’s and the OHWM is discontinuous and inconsistent in drainage channels. Variations in precipitation intensity and spatial distribution further decrease the ability of the washes to transfer nutrients, sediment, or pollution to down stream RPW’s. No aquatic species are supported by the washes within the project area, however, incidental use by terrestrial species characteristic of the salt desert shrub community occurs. Based on the information provided in Section III, B-1 above, tributaries within the proposed project impact area were found to have an insignificant and speculative impact on the physical, chemical, and biological of the down stream TNW (Colorado River) or its RPW tributaries. There is no information available to show that these washes: 1) is or could be used by interstate or foreign travelers for recreational or other purposes, 2) produces fish or shellfish which are or could be taken and sold in interstate or foreign commerce, or 3) is or could be used for industrial purposes by industries in the interstate commerce

2.

Significant nexus findings for non-RPW and its adjacent wetlands, where the non-RPW flows directly or indirectly into TNWs. Explain findings of presence or absence of significant nexus below, based on the tributary in combination with all of its adjacent wetlands, then go to Section III.D: . Significant nexus findings for wetlands adjacent to an RPW but that do not directly abut the RPW. Explain findings of presence or absence of significant nexus below, based on the tributary in combination with all of its adjacent wetlands, then go to Section III.D: .

3.

D.

DETERMINATIONS OF JURISDICTIONAL FINDINGS. THE SUBJECT WATERS/WETLANDS ARE (CHECK ALL THAT APPLY): 1. TNWs and Adjacent Wetlands. Check all that apply and provide size estimates in review area: TNWs: linear feet width (ft), Or, acres. Wetlands adjacent to TNWs: acres. RPWs that flow directly or indirectly into TNWs. Tributaries of TNWs where tributaries typically flow year-round are jurisdictional. Provide data and rationale indicating that tributary is perennial: . Tributaries of TNW where tributaries have continuous flow “seasonally” (e.g., typically three months each year) are jurisdictional. Data supporting this conclusion is provided at Section III.B. Provide rationale indicating that tributary flows seasonally: .

2.

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Provide estimates for jurisdictional waters in the review area (check all that apply): Tributary waters: linear feet width (ft). Other non-wetland waters: acres. Identify type(s) of waters: . 3. Non-RPWs8 that flow directly or indirectly into TNWs. Waterbody that is not a TNW or an RPW, but flows directly or indirectly into a TNW, and it has a significant nexus with a TNW is jurisdictional. Data supporting this conclusion is provided at Section III.C. Provide estimates for jurisdictional waters within the review area (check all that apply): Tributary waters: linear feet width (ft). Other non-wetland waters: acres. Identify type(s) of waters: .

4.

Wetlands directly abutting an RPW that flow directly or indirectly into TNWs. Wetlands directly abut RPW and thus are jurisdictional as adjacent wetlands. Wetlands directly abutting an RPW where tributaries typically flow year-round. Provide data and rationale indicating that tributary is perennial in Section III.D.2, above. Provide rationale indicating that wetland is directly abutting an RPW: . Wetlands directly abutting an RPW where tributaries typically flow “seasonally.” Provide data indicating that tributary is seasonal in Section III.B and rationale in Section III.D.2, above. Provide rationale indicating that wetland is directly abutting an RPW: . Provide acreage estimates for jurisdictional wetlands in the review area: acres.

5.

Wetlands adjacent to but not directly abutting an RPW that flow directly or indirectly into TNWs. Wetlands that do not directly abut an RPW, but when considered in combination with the tributary to which they are adjacent and with similarly situated adjacent wetlands, have a significant nexus with a TNW are jurisidictional. Data supporting this conclusion is provided at Section III.C. Provide acreage estimates for jurisdictional wetlands in the review area: acres.

6.

Wetlands adjacent to non-RPWs that flow directly or indirectly into TNWs. Wetlands adjacent to such waters, and have when considered in combination with the tributary to which they are adjacent and with similarly situated adjacent wetlands, have a significant nexus with a TNW are jurisdictional. Data supporting this conclusion is provided at Section III.C. Provide estimates for jurisdictional wetlands in the review area: acres.

7.

Impoundments of jurisdictional waters.9 As a general rule, the impoundment of a jurisdictional tributary remains jurisdictional. Demonstrate that impoundment was created from “waters of the U.S.,” or Demonstrate that water meets the criteria for one of the categories presented above (1-6), or Demonstrate that water is isolated with a nexus to commerce (see E below).

E.

ISOLATED [INTERSTATE OR INTRA-STATE] WATERS, INCLUDING ISOLATED WETLANDS, THE USE, DEGRADATION OR DESTRUCTION OF WHICH COULD AFFECT INTERSTATE COMMERCE, INCLUDING ANY SUCH WATERS (CHECK ALL THAT APPLY):10 which are or could be used by interstate or foreign travelers for recreational or other purposes. from which fish or shellfish are or could be taken and sold in interstate or foreign commerce. which are or could be used for industrial purposes by industries in interstate commerce. Interstate isolated waters. Explain: . Other factors. Explain: . Identify water body and summarize rationale supporting determination: .

See Footnote # 3. To complete the analysis refer to the key in Section III.D.6 of the Instructional Guidebook. 10 Prior to asserting or declining CWA jurisdiction based solely on this category, Corps Districts will elevate the action to Corps and EPA HQ for review consistent with the process described in the Corps/EPA Memorandum Regarding CWA Act Jurisdiction Following Rapanos.
9

8

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Provide estimates for jurisdictional waters in the review area (check all that apply): Tributary waters: linear feet width (ft). Other non-wetland waters: acres. Identify type(s) of waters: . Wetlands: acres.

F.

NON-JURISDICTIONAL WATERS, INCLUDING WETLANDS (CHECK ALL THAT APPLY): If potential wetlands were assessed within the review area, these areas did not meet the criteria in the 1987 Corps of Engineers Wetland Delineation Manual and/or appropriate Regional Supplements. Review area included isolated waters with no substantial nexus to interstate (or foreign) commerce. Prior to the Jan 2001 Supreme Court decision in “SWANCC,” the review area would have been regulated based solely on the “Migratory Bird Rule” (MBR). Waters do not meet the “Significant Nexus” standard, where such a finding is required for jurisdiction. Explain: Tributaries within the proposed project impact area have been determined to have no more than an insignificant and speculative impact on the physical, chemical, and biological of the down stream TNW (Colorado River) or its RPW tributaries. Other: (explain, if not covered above): . Provide acreage estimates for non-jurisdictional waters in the review area, where the sole potential basis of jurisdiction is the MBR factors (i.e., presence of migratory birds, presence of endangered species, use of water for irrigated agriculture), using best professional judgment (check all that apply): Non-wetland waters (i.e., rivers, streams): linear feet width (ft). Lakes/ponds: acres. Other non-wetland waters: acres. List type of aquatic resource: . Wetlands: acres. Provide acreage estimates for non-jurisdictional waters in the review area that do not meet the “Significant Nexus” standard, where such a finding is required for jurisdiction (check all that apply): Non-wetland waters (i.e., rivers, streams): Crossings impact an average of 200 linear feet of dry wash, Dry wash average width 2.11 (ft). Based on the average wash dimensions, for 180 dry washes, approximately 2 acres of dry washes will be impacted. Lakes/ponds: acres. Other non-wetland waters: acres. List type of aquatic resource: . Wetlands: acres.

SECTION IV: DATA SOURCES. A. SUPPORTING DATA. Data reviewed for JD (check all that apply - checked items shall be included in case file and, where checked and requested, appropriately reference sources below): Maps, plans, plots or plat submitted by or on behalf of the applicant/consultant: WestWater Engineering. Data sheets prepared/submitted by or on behalf of the applicant/consultant. Office concurs with data sheets/delineation report. Office does not concur with data sheets/delineation report. Data sheets prepared by the Corps: . Corps navigable waters’ study: . U.S. Geological Survey Hydrologic Atlas: www-atlas.usgs.gov. USGS NHD data. USGS 8 and 12 digit HUC maps. U.S. Geological Survey map(s). Cite scale & quad name: USGS 1:24,000 Mack, CO., Ruby Canyon, CO., Badger Wash, CO., Highline Lake, CO., Howard Canyon, CO. USDA Natural Resources Conservation Service Soil Survey. Citation: http://websoilsurvey.nrcs.usda.gov/app/ National wetlands inventory map(s). Cite name: www.fws.gov/nwi/ State/Local wetland inventory map(s): . FEMA/FIRM maps: . 100-year Floodplain Elevation is: (National Geodectic Vertical Datum of 1929) Photographs: Aerial (Name & Date): USDA NAIP 2005. or Other (Name & Date): WestWater Engineering, Previous determination(s). File no. and date of response letter: . Applicable/supporting case law: Rapanos. Applicable/supporting scientific literature: USGS Badger Wash Study (1957-1972). Other information (please specify): RGL 07-02

B. ADDITIONAL COMMENTS TO SUPPORT JD:

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Appendix A

Photos of Typical Washes and Drainage Basins (see Figures 2 and 3)

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Photo 1. Crossing Point W061

Photo 2. Crossing Point W061

Photo 3. Crossing Point W061
Page A -2

Photo 4. Crossing Point W043
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Photo 5. Crossing Point W044

Photo 6. Crossing Point W044

Photo 7. Crossing Point W053
Page A -3

Photo 8. Crossing Point W057
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Photo 9. Crossing Point W053

Photo 10. Crossing Point W057

Photo 11. Crossing Point W045
Page A -4

Photo 12. Crossing Point W082F
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Photo 13. Crossing Point W084A

Photo 14. Crossing Point W086A

Photo 15. Crossing Point W084E
Page A -5

Photo 16. Crossing Point W106C
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Photo 17. Crossing Point W101

Photo 18. Crossing Point W107

Photo 19. Crossing Point W040
Page A -6

Photo 20. Crossing Point W035
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Appendix B Photos of Changes in Channel (see Figures 2 and 3)

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Photo 1. Looking downstream at point W100

Photo 2. Looking upstream one mile below W100

Photo 3. Looking at alluvial fan at the end of drainage
Page B - 2

Photo 4. Looking downstream of alluvial fan west of Hwy 139
COE Jurisdictional Determination Request

WestWater Engineering

Jurisdictional Determination February 25, 2008

APPENDIX F S O I L S D ATA

CAM Colorado, LLC – Red Cliff Mine Soils1
Map Symbol 5 Soil Series Name Battlement loam; 1 to 8% slopes Biedsaw-Sunup gravelly loams; 10 to 40% slopes Cameo fine sandy loam; 1 to 6% slopes Cathedral-Veatch complex; 25 to 85% slopes Chipeta silty clay loam; 3 to 30% slopes Cryorthents-Rock outcrop complex; 50 to 90% slopes Grobutte very channery loam; 30 to 60% slopes Soil Survey Area Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties Soil Description The Battlement series consists of very deep, well or moderately well drained, moderately permeable soils on flood plains, low stream terraces, and narrow valley floors. They formed in alluvium derived from sedimentary rock. This map unit is on side slopes of mountains and ridges. The Biedsaw is deep, and the Sunup soil is shallow, however both are well drained, formed in colluvium over residuum derived dominantly from the Wasatch shale formation. The Cameo series consists of very deep, well drained, moderately, rapidly permeable soils on flood plains and low stream terraces. These soils formed in calcareous, stratified alluvium derived from mixed sources. This map unit is on mountain slopes and benches. These soils are well drained and formed in residuum derived dominantly from sandstone. Veatch soil is moderately deep, and Cathedral soil is shallow. This shallow, well drained soil is on low, rolling hills, ridges, and toeslopes. It formed in residuum derived dominantly from calcareous, gypsiferous shale. This map unit is mainly on south- and southwest- facing mountainsides and ridges. Cryorthents commonly are well drained and are moderately deep or deep to hard or soft shale formed in residuum and colluvium derived from shale. Rock outcrop consists of barren escarpments, ridge caps, rocky points of shale, and small areas of sandstone. This deep, well drained soil is on steep hills and mountainsides. It formed in colluvium derived dominantly from mixed material. The map unit is on mountainsides and benches. The Hesperus soils are on the steeper mountainsides and are deep and well drained formed in residuum derived dominantly from sandstone and shale. The Empedrado is on the benches and in the less sloping areas and is deep and well drained formed in residuum and colluvium derived dominantly from interbedded sandstone and shale. The Pagoda soil is on the benches and mountainside and is deep and well drained formed in colluvium derived dominantly from shale. This map unit is on fans and benches. Soils are deep and well drained formed in alluvium derived dominantly from sedimentary rock. This deep, well drained soils are found on low terraces and flood plains. It formed in alluvium derived dominantly from mixed materials. This shallow, well drained soil is found on upland hills. It formed in residuum derived dominantly from shale. This map unit is on south-facing slopes of mountains, hills, ridges, and canyonside in extremely rough and eroded areas. It supports only sparse vegetation. Rock outcrop consists of barren escarpments, ridge caps, and rocky points of sandstone, shale, limestone, or siltstone. Torriorthents commonly are very shallow and shallow over hard bedrock. The soils are well drained and formed in residuum and colluvium derived from sandstone, shale, or siltstone. The map unit is on eroded fans, in swales, and along narrow valley bottoms. Typically, Torrifluvents are deep and well drained to somewhat excessively drained and formed in calcareous alluvium derived dominantly from mixed sources. Gullied land consists of areas where soil horizons have been removed by water, resulting in a network of V-shaped or U-shape channels resembling miniature badlands. Generally, gullies are so large (3 to 25 feet deep and 5 to 100 feet wide) that extensive reshaping is necessary for most uses. This map unit is on steep, mainly south-facing slopes on mountains, hills, ridges, and canyon sides in extremely rough and eroded areas. Torriorthents commonly are very shallow to deep over hard or soft bedrock, well drained or somewhat excessively drained and formed in residuum and colluvium derived from sandstone, shale, limestone, or siltstone. Rock outcrop consists of barren escarpments, ridge caps, and rocky points of sandstone, shale, limestone, or siltstone. This map unit is on steep, mainly south-facing slopes on mountains, hills, ridges, and canyon sides in extremely rough and eroded areas. Torriorthents commonly are very shallow to deep over hard or soft bedrock, well drained or somewhat excessively drained formed in residuum and colluvium derived from sandstone, shale, limestone, or siltstone. Rock outcrop consists of barren escarpments, ridge caps, and rocky points of sandstone, shale, limestone, or siltstone. Prime Farmland Prime farmland if irrigated Not prime farmland Prime farmland if irrigated Not prime farmland Erosion Potential (Off-road/Offtrail)/(Road/Trail) Slight/Moderate Roadfill/Shrink-Swell Capacity Good Poor; Shrink-Swell Capacity = Biedsaw (0.87) Good Salinity Slightly to moderately alkaline; Strongly alkaline below a depth of 10 inches Slightly to moderately alkaline. Depth to Bedrock (Inches) 60

7

Moderate/Severe

20 to 60

15

Slight/Moderate

Slightly to strongly alkaline Moderately acid to strongly alkaline Slightly to strongly alkaline

60

17

Very severe/Severe

Poor Poor; Shrink-Swell Capacity (0.87) Poor

11 to 32

21

Not prime farmland

Moderate/Severe

17

27

Not prime farmland

Very severe/Severe

Not measured

28

42

Not prime farmland

Severe/Severe

Poor

Moderately to strongly alkaline

60

47

Hesperus-Empedrado, moist-Pagado complex; 5 to 35% slopes

Not prime farmland

Moderate/Severe

Fair; Shrink-Swell Capacity = Hesperus (0.87); Pagado (0.75)

Lightly acid to moderately alkaline

40 to 60

51

Mesa-Avalon complex; 3 to 12% slopes Panitchen loam; 1 to 6% slopes Persayo silty clay loam; 3 to 25% slopes

Not prime farmland Prime farmland if irrigated Not prime farmland

Slight/Moderate

Good

Slightly to strongly alkaline

60

54

Slight/Moderate

Good Poor; Shrink-Swell Capacity = Persayo (0.87)

Moderately to strongly alkaline.

60

59

Slight/Severe

Slightly to strongly alkaline

14

61

Rock outcrop-Torriorthents complex; 15 to 90% slopes

Not prime farmland

Very severe/Severe

Not Rated

Slightly to strongly alkaline

13

64

Torrifluvents-Gullied land complex; 0 to 2% slopes

Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties

Not prime farmland

Slight/Slight

Good

Slightly to strongly alkaline

60

65

Torriorthents, cool-Rock outcrop complex; 35 to 90% slopes

Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties

Not prime farmland

Very severe/Severe

Poor

Slightly to strongly alkaline

4 to 60

66

Torriorthents, warm-Rock outcrop complex; 35 to 90% slopes

Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties

Not prime farmland

Very severe/Severe

Poor

Slightly to strongly alkaline

4 to 60

1

CAM Colorado, LLC – Red Cliff Mine Soils1
Map Symbol 67 Soil Series Name Tosca channery loam; 25 to 80% slopes Wrayha-Rabbitex-Veatch complex; 45 to 65% slopes; very stony Tolman-Rock outcropChugcreek complex, 3 to 12 percent slopes, very stony Soil Survey Area Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties Douglas-Plateau Area, Colorado, Parts of Garfield and Mesa Counties Soil Description This deep, well drained soil is on mountain side slopes and footslopes. It formed in colluvium derived dominantly from Green River shale. This map unit is on canyon side slopes. It formed in deeply truncated residuum and localized colluvium derived dominantly from marine shales, siltstones and sandstones. These soils are moderately well drained to well drained. The Tolman series consists of well drained soils that are shallow to hard bedrock. They formed in slope alluvium, colluvium, and residuum from sedimentary beds. Tolman soils are on hillslopes, ridges, plateaus, and mountain slopes. Rock outcrop consists of barren escarpments, ridge caps, rocky points of shale, and small areas of sandstone. The Chugcreek series consists of well drained soils that are moderately deep to hard igneous bedrock. They formed in slope alluvium and colluvium from granite and gneiss. Chugcreek soils are on gently sloping to steep foothills and mountain slopes. Badlands are found on rolling to very steep, nearly barren mountainsides, low hills, ridgetops, and canyon sides. These soils formed in residuum derived dominantly from highly calcareous and gypsiferous shale and bentonite. The badlands are very shallow, do not exhibit significant soil characteristics and produce a large amount of sediment. The Deaver series consists of moderately deep, well drained soils that formed in residuum derived from shale. Deaver soils are on hills and ridges. The Chipeta series consists of very shallow and shallow, well drained, slowly permeable soils that formed in residuum and colluvium from shale. Chipeta soils are on upland pediments and hills. The Killpack series consists of moderately deep, well drained, slowly permeable soils that formed in alluvium and residuum from saline marine shale. Killpack soils are on sideslopes and toeslopes of rolling shale hills. Badlands are found on rolling to very steep, nearly barren mountainsides, low hills, ridgetops, and canyon sides. It formed in residuum derived dominantly from highly calcareous and gypsiferous shale and bentonite. The Badlands are very shallow, do not exhibit significant soil characteristics and produce a large amount of sediment. The Persayo series consists of shallow, well drained soils on hills, terraces, and ridges. These soils formed in thin sediments weathered from underlying soft sedimentary bedrock. The Leebench series consists of very deep, well drained, slowly permeable soils that formed in alluvium from sedimentary and metamorphic rocks. Leebench soils occur on alluvial fans, fan remnants, strath terraces and fan terraces. The Avalon series consists of very deep, well drained, moderately slow and moderately permeable soils formed in alluvium derived mainly from sandstone and shale. These soils are on terraces, alluvial fans, dissected fans, and hills. The Mack series consists of very deep, well drained soils that formed in slope alluvium and alluvium derived from sandstone and shale. Mack soils are on fan remnants, terraces, alluvial fans, and mesas. The Avalon series consists of very deep, well drained, moderately slow and moderately permeable soils formed in alluvium derived mainly from sandstone and shale. These soils are on terraces, alluvial fans, dissected fans, and hills. The Killpack series consists of moderately deep, well drained, slowly permeable soils that formed in alluvium and residuum from saline marine shale. Killpack soils are on sideslopes and toeslopes of rolling shale hills. The Neiberger series consists of moderately deep, well drained soils that formed in eolian deposits over residuum derived from shale. Neiberger soils are on summits, shoulders, sideslopes and footslopes of hills. The Sagers series consists of very deep, well drained, moderate to slowly permeable soils that formed in alluvium and slope alluvium derived from marine shale. These soils are on basin and valley floor remnants, alluvial fans, and stream terraces. The Skumpah series consists of very deep, well drained soils that formed in alluvium derived from shale, limestone, and sandstone. Skumpah soils are on alluvial flats, lake plains, and fan skirts. The Turley series consists of very deep, well drained, moderately slowly permeable soils that formed from alluvium and eolian materials derived from sandstone and shale. Turley soils are found on terraces, fan remnants, and alluvial fans. The Sagrlite series consists of very deep, well drained soils that formed in alluvium from shale and sandstone and are on alluvial fans and terraces. The Fruitland series consists of very deep, well drained and somewhat excessively drained soils that formed in eolian material and moderately coarse textured alluvium and stream alluvium derived from sandstone and shale. Fruitland soils are on stream terraces on valley floors, alluvial fans on valley sides, and summits of mesas. Prime Farmland Erosion Potential (Off-road/Offtrail)/(Road/Trail) Very severe/Severe Roadfill/Shrink-Swell Capacity Poor Salinity Depth to Bedrock (Inches) 60

Not prime farmland

Slightly to moderately alkaline

75

Not prime farmland

Very severe/Severe

Good

Mildy to strongly alkaline

32 to 60

2

Mesa County Area, Colorado

Not prime farmland

Slight/Not Rated

Poor

Neutral to mildly Alkaline

10 to 38

52

Badlands-Deaver-Chipeta complex; 25 to 99% slopes; extremely stony

Mesa County Area, Colorado

Not prime farmland

Severe/Severe

Poor

Slightly to strongly alkaline

17 to 24

68

Killpack-Badlands-Persayo complex; 3 to 25% slopes, saline

Mesa County Area, Colorado

Not prime farmland

Not rated/Not rated

Poor;Killpack ShrinkSwell Capacity (0.87)

Mildy to moderately alkaline

14 to 29

69

Leebench, warm-Avalon complex; 3 to 12% slopes

Mesa County Area, Colorado

Not prime farmland

Slight/Moderate

Good

Slightly to very strongly alkaline

60

71

Mack-Avalon complex, 3 to 12% slopes

Mesa County Area, Colorado

Not prime farmland

Slight/Moderate

Good

Neutral to strongly alkaline

60 to 80

72

Killpack-Neiberger complex; 3 to 25% slopes

Mesa County Area, Colorado

Not prime farmland

Slight/Moderate

Poor; Killpack and Neiberger Shrink-Swell Capacity (0.87) Fair; Sagers and Skumpah Shrink-Swell Capacity (0.87)

Mildy to strongly alkaline

29 to 30

73

Sagers-Skumpah complex; 0 to 3% slopes

Mesa County Area, Colorado

Not prime farmland

Slight/Slight

Moderately to very strongly alkaline.

60

74

Turley-Sagrlite-Fruitland complex; 0 to 3% slopes

Mesa County Area, Colorado

Not prime farmland

Slight/Slight

Good

Moderately to strongly alkaline

70 to 81

2

CAM Colorado, LLC – Red Cliff Mine Soils1
Map Symbol Soil Series Name Soil Survey Area Soil Description The Moffat series consists of very deep, well drained, moderately rapidly permeable soils that formed in eolian and alluvial sediments. These soils are on plains, plains on structural benches, and alluvial fans. The Kompace series consists of shallow, well drained soils that formed in eolian deposits over old outwash derived from sandstone. Kompace soils are on summits of small mesas. The Trail series consists of very deep, well drained and somewhat excessively drained soils that formed in stratified alluvium. The Persayo series consists of shallow, well drained soils on hills, terraces, and ridges. These soils formed in thin sediments weathered from underlying soft sedimentary bedrock. The Blackston series consists of very deep, well drained soils that formed in alluvium and slope alluvium derived from mixed sources. Blackston soils are on edges of old high terraces and on fan remnants. Rock outcrop consists of barren escarpments, ridge caps, and rocky points of sandstone, shale, limestone, or siltstone. The Hoovers series consists of shallow, well drained soils that formed in loamy slope alluvium derived from sandstone and shale over loamy residuum derived from sandstone. Hoovers soils are on dipslopes on cuestas and summits on mesas. The Deaver series consists of moderately deep, well drained soils that formed in residuum derived from shale. Deaver soils are on hills and ridges. The San Mateo series consists of very deep, well drained, moderately slowly permeable soils that formed in alluvium, fan alluvium and stream alluvium from mixed sources on alluvial fans on valley sides and flood plains on valley floors. The Escavada series consists of very deep, well drained soils that formed in stratified alluvium derived dominantly from sandstone, and shale. Escavada soils are on flood plains. The Skumpah series consists of very deep, well drained soils that formed in alluvium derived from shale, limestone, and sandstone. Skumpah soils are on alluvial flats, lake plains, and fan skirts. The Killpack series consists of moderately deep, well drained, slowly permeable soils that formed in alluvium and residuum from saline marine shale. Killpack soils are on sideslopes and toeslopes of rolling shale hills. The Persayo series consists of shallow, well drained soils on hills, terraces, and ridges. These soils formed in thin sediments weathered from underlying soft sedimentary bedrock. This map unit is on steep, mainly south-facing slopes on mountains, hills, ridges, and canyon sides in extremely rough and eroded areas. Torriorthents commonly are very shallow to deep over hard or soft bedrock, well drained or somewhat excessively drained formed in residuum and colluvium derived from sandstone, shale, limestone, or siltstone. Rock outcrop consists of barren escarpments, ridge caps, and rocky points of sandstone, shale, limestone, or siltstone. This map unit is on steep, mainly south-facing slopes on mountains, hills, ridges, and canyon sides in extremely rough and eroded areas. Torriorthents commonly are very shallow to deep over hard or soft bedrock, well drained or somewhat excessively drained formed in residuum and colluvium derived from sandstone, shale, limestone, or siltstone. Rock outcrop consists of barren escarpments, ridge caps, and rocky points of sandstone, shale, limestone, or siltstone. The Avalon series consists of very deep, well drained, moderately slow and moderately permeable soils formed in alluvium derived mainly from sandstone and shale. These soils are on terraces, alluvial fans, dissected fans, and hills. The Massadona series consists of very deep, well drained soils that formed in alluvium derived from shale. Massadona soils are on hills, toeslopes, and alluvial fans. The Sagers series consists of very deep, well drained, moderate to slowly permeable soils that formed in alluvium and slope alluvium derived from marine shale. These soils are on basin and valley floor remnants, alluvial fans, and stream terraces. The Skumpah series consists of very deep, well drained soils that formed in alluvium derived from shale, limestone, and sandstone. Skumpah soils are on alluvial flats, lake plains, and fan skirts. The Sagers series consists of very deep, well drained, moderate to slowly permeable soils that formed in alluvium and slope alluvium derived from marine shale. These soils are on basin and valley floor remnants, alluvial fans, and stream terraces. The Cojam series consists of very deep, poorly drained soils that formed in alluvium derived from shale. Cojam soils are on alluvial fans and terraces. The Sagers series consists of very deep, well drained, moderate to slowly permeable soils that formed in alluvium and slope alluvium derived from marine shale. These soils are on basin and valley floor remnants, alluvial fans, and stream terraces. Prime Farmland Erosion Potential (Off-road/Offtrail)/(Road/Trail) Moderate/Severe Roadfill/Shrink-Swell Capacity Salinity Depth to Bedrock (Inches) 32 to 60

84

Moffat-Kompace complex; 6 to 35% slopes Trail fine sandy loam; 0 to 5% slopes Persayo-Blackston complex; 6 to 45% slopes

Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado

Not prime farmland

Fair

Slightly to strongly alkaline.

85

Not prime farmland

Slight/Moderate

Good Poor; Persayo Shrink-Swell Capacity (0.87)

Slightly to strongly alkaline

60

87

Not prime farmland

Severe/Severe

Slightly to moderately alkaline

14 to 60

89

Rock outcrop-HooversDeaver complex, 25 to 65% slopes; very stony

Mesa County Area, Colorado

Not prime farmland

Not rated/Not rated

Not Rated

Moderately to strongly alkaline

18 to 24

91

San Mateo-Escavada, dry complex; 0 to 3% slopes

Mesa County Area, Colorado

Not prime farmland

Slight/Slight

Good

Slightly to strongly alkaline.

70

94

Skumpah very fine sandy loam; 0 to 3% slopes Killpack-Persayo complex; 3 to 25% slopes

Mesa County Area, Colorado Mesa County Area, Colorado

Not prime farmland

Slight/Slight

Fair; Skumpah Shrink-Swell Capacity (0.87) Poor; Killpack Shrink-Swell Capacity (0.87)

Moderately to strongly alkaline.

60

108

Not prime farmland

Slight/Moderate

Mildy to strongly alkaline

14 to 29

210

Torrirthents, cool-rock outcrop; 35 to 90% slopes

Mesa County Area, Colorado

Not prime farmland

Very severe/severe

Poor

Slightly to strongly alkaline

4 to 60

275

Torriorthents, warm-rock outcrop; 35 to 90% slopes Avalon sandy loam, gravelly substratum; 2 to 5% slopes Massadona silty clay loam; 0 to 2% slopes Sagers silty clay loam; 0 to 2% slopes Skumpah silt loam; 0 to 2% slopes Sagers silty clay loam, saline; 0 to 2% slopes Cojam loam; 0 to 2% slopes Sagers silty clay loam; 2 to 5% slopes

Mesa County Area, Colorado

Not prime farmland

Very severe/Severe

Poor

Slightly to strongly alkaline

4 to 60

Av

Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado

Prime farmland if irrigated Not prime farmland Prime farmland if irrigated Not prime farmland Not prime farmland

Slight/Moderate

Good Fair; Shrink-Swell Capacity (0.63) Fair; Shrink-Swell Capacity (0.87) Good Fair; Shrink-Swell Capacity (0.87) Poor; Shrink-Swell Capacity (0.89) Fair; Shrink-Swell Capacity (0.87)

Moderately to strongly alkaline.

60

Ba

Slight/Slight

Moderately to strongly alkaline.

60

Bc BcA BcS

Slight/Slight Slight/Slight Slight/Slight

Moderately to strongly alkaline. Moderately to strongly alkaline. Moderately to very strongly alkaline. Slightly to moderately alkaline Moderately to very strongly alkaline.

60 60 60

BcW

Not prime farmland Prime farmland if irrigated

Slight/Slight

60

Bd

Slight/Moderate

60

3

CAM Colorado, LLC – Red Cliff Mine Soils1
Map Symbol Be Soil Series Name Green River silty clay loam; 0 to 2% slopes Blackston gravelly loam; 0 to 2% slopes Blackston gravelly loam; 2 to 5% slopes Persayo silt clay loam; 5 to 12% slopes Persayo silty clay; 0 to 2% slopes Persayo silt clay loam; 2 to 5% slopes Fruita clay loam; 0 to 2% slopes Fruita clay loam; 2 to 5% slopes Fruitvale clay loam; 0 to 2% slopes Fruitvale clay loam; 2 to 5% slopes Fruitland fine sandy loam; 0 to 2% slopes Soil Survey Area Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Soil Description The Green River series consists of very deep, moderately well drained, moderately permeable soils that formed in alluvium derived from sedimentary, metamorphic rocks, and igneous rocks. These soils are on flood plains and terraces. The Blackston series consists of very deep, well drained soils that formed in alluvium and slope alluvium derived from mixed sources. Blackston soils are on edges of old high terraces and on fan remnants. The Blackston series consists of very deep, well drained soils that formed in alluvium and slope alluvium derived from mixed sources. Blackston soils are on edges of old high terraces and on fan remnants. The Persayo series consists of shallow, well drained soils on hills, terraces, and ridges. These soils formed in thin sediments weathered from underlying soft sedimentary bedrock. The Persayo series consists of shallow, well drained soils on hills, terraces, and ridges. These soils formed in thin sediments weathered from underlying soft sedimentary bedrock. The Persayo series consists of shallow, well drained soils on hills, terraces, and ridges. These soils formed in thin sediments weathered from underlying soft sedimentary bedrock. The Fruita series consists of very deep, well drained soils formed in slope alluvium derived from gypsiferous shale over alluvium derived from sandstone and shale. Fruita soils are on treads on terraces. The Fruita series consists of very deep, well drained soils formed in slope alluvium derived from gypsiferous shale over alluvium derived from sandstone and shale. Fruita soils are on treads on terraces. The Fruitvale series consists of very deep, well drained, moderately slow over slowly permeable soils on terraces. They formed in slope alluvium derived from sandstone and shale over residuum weathered from clayey shale. The Fruitvale series consists of very deep, well drained, moderately slow over slowly permeable soils on terraces. They formed in slope alluvium derived from sandstone and shale over residuum weathered from clayey shale. The Fruitland series consists of very deep, well drained and somewhat excessively drained soils that formed in eolian material and moderately coarse textured alluvium and stream alluvium derived from sandstone and shale. Fruitland soils are on stream terraces on valley floors, alluvial fans on valley sides, and summits of mesas. The Fruitland series consists of very deep, well drained and somewhat excessively drained soils that formed in eolian material and moderately coarse textured alluvium and stream alluvium derived from sandstone and shale. Fruitland soils are on stream terraces on valley floors, alluvial fans on valley sides, and summits of mesas. The Fruitvale series consists of very deep, well drained, moderately slow over slowly permeable soils on terraces. They formed in slope alluvium derived from sandstone and shale over residuum weathered from clayey shale. The Fruitvale series consists of very deep, well drained, moderately slow over slowly permeable soils on terraces. They formed in slope alluvium derived from sandstone and shale over residuum weathered from clayey shale. The Bebeevar series consists of very deep, moderately well drained soils that formed in alluvium derived from sandstone, granite, and quartzite. Bebeevar soils are on inter-channel bars of low, braided flood plains along perennial streams. The Pit series consists of very deep, poorly drained soils that formed in fine-textured alluvium weathered from extrusive and basic igneous rocks. Pit soils are on flood plains and in basins. The Glenton series is a member of the coarse-loamy, mixed (calcareous), mesic family of Typic Torrifluvents. Typically, Glenton soils have calcareous very friable granular A horizons, and calcareous very stratified but predominantly moderately coarse textured C horizons. The Killpack series consists of moderately deep, well drained, slowly permeable soils that formed in alluvium and residuum from saline marine shale. Killpack soils are on sideslopes and toeslopes of rolling shale hills. The Killpack series consists of moderately deep, well drained, slowly permeable soils that formed in alluvium and residuum from saline marine shale. Killpack soils are on sideslopes and toeslopes of rolling shale hills. The Mack series consists of very deep, well drained soils that formed in slope alluvium and alluvium derived from sandstone and shale. Mack soils are on fan remnants, terraces, alluvial fans, and mesas. Prime Farmland Prime farmland if irrigated Not prime farmland Erosion Potential (Off-road/Offtrail)/(Road/Trail) Slight/Slight Roadfill/Shrink-Swell Capacity Good Salinity Depth to Bedrock (Inches) 60

Moderately to strongly alkaline.

Bk

Slight/Slight

Good

Moderately to strongly alkaline.

60

Bl

Not prime farmland

Slight/Slight

Good Poor; Shrink-Swell Capacity (0.87) Poor; Shrink-Swell Capacity (0.87) Poor; Shrink-Swell Capacity (0.87) Good Good Fair; Shrink-Swell Capacity (0.89) Fair; Shrink-Swell Capacity (0.89) Good

Moderately to strongly alkaline.

60

Cc

Not prime farmland

Slight/Severe

Slightly to strongly alkaline

14

Cd

Not prime farmland

Slight/Slight

Slightly to strongly alkaline

14

Ce Fe Ff Fg

Not prime farmland Prime farmland if irrigated Prime farmland if irrigated Prime farmland if irrigated Prime farmland if irrigated Prime farmland if irrigated

Slight/Moderate Slight/Slight Slight/Moderate Slight/Slight

Slightly to strongly alkaline Slightly to moderately alkaline Slightly to moderately alkaline Slightly to moderately alkaline

14 65 65 60

Fh

Slight/Moderate

Slightly to moderately alkaline

60

Fp

Slight/Slight

Slightly to moderately alkaline

70

Fr

Fruitland fine sandy loam; 2 to 5% slopes Fruitvale fine sandy loam; 0 to 2% slopes Fruitvale fine sandy loam; 2 to 5% slopes Bebeevar loam; 0 to 2% slopes Pits, gravel Glenton very fine sandy loam; 0 to 2% slopes Killpack silty clay loam; 2 to 5% slopes Killpack silty clay loam; 0 to 2% slopes Mack loam; 0 to 2% slopes

Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado

Prime farmland if irrigated Prime farmland if irrigated Prime farmland if irrigated Prime farmland if irrigated and drained Not prime farmland Prime farmland if irrigated Not prime farmland

Slight/Moderate

Good Poor; Shrink-Swell Capacity (1.00) Poor; Shrink-Swell Capacity (1.00) Good Not Rated Good Poor; Shrink-Swell Capacity (0.87) Poor; Shrink-Swell Capacity (0.87) Good

Slightly to moderately alkaline

70

Fs

Slight/Slight

Slightly to moderately alkaline

60

Ft

Slight/Moderate

Slightly to moderately alkaline

60

Gk GP Gt

Slight/Slight Not rated/Not rated Slight/Slight

Slightly to moderately alkaline Mildly to moderately alkaline Moderately alkaline

70 60 60

Hj

Slight/Moderate

Mildly alkaline

29

Hk Ma

Not prime farmland Prime farmland if irrigated

Slight/Slight Slight/Slight

Mildly alkaline Neutral to strongly alkaline

29 80

4

CAM Colorado, LLC – Red Cliff Mine Soils1
Map Symbol Soil Series Name Soil Survey Area Soil Description The Fruitland series consists of very deep, well drained and somewhat excessively drained soils that formed in eolian material and moderately coarse textured alluvium and stream alluvium derived from sandstone and shale. Fruitland soils are on stream terraces on valley floors, alluvial fans on valley sides, and summits of mesas. The Sagrlite series consists of very deep, well drained soils that formed in alluvium from shale and sandstone and are on alluvial fans and terraces. The Persayo series consists of shallow, well drained soils on hills, terraces, and ridges. These soils formed in thin sediments weathered from underlying soft sedimentary bedrock. Ustifluvents are moderately well drained soils found on flood plains. Parent material consists of alluvium derived from sandstone and shale. The Skumpah series consists of very deep, well drained soils that formed in alluvium derived from shale, limestone, and sandstone. Skumpah soils are on alluvial flats, lake plains, and fan skirts. The Turley series consists of very deep, well drained, moderately slowly permeable soils that formed from alluvium and eolian materials derived from sandstone and shale. Turley soils are on terraces, fan remnants, and alluvial fans. Not applicable Prime Farmland Erosion Potential (Off-road/Offtrail)/(Road/Trail) Slight/Slight Roadfill/Shrink-Swell Capacity Salinity Depth to Bedrock (Inches) 70

Rc

Fruitland sandy clay loam; 0 to 2% slopes Sagrlite loam; 0 to 2% slopes Persayo silty clay loam; 12 to 40% slopes Ustifluvents; 0 to 2% slopes Skumpah very fine sandy loam; 0 to 2% slopes Turley clay loam; 0 to 2% slopes Water

Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado Mesa County Area, Colorado

Prime farmland if irrigated Prime farmland if irrigated Not prime farmland Not prime farmland Not prime farmland Prime farmland if irrigated Not prime farmland

Good

Slightly to moderately alkaline

Re Rp Rs Sk Tr

Slight/Slight Severe/Severe Slight/Slight Slight/Slight Slight/Slight NA

Good Poor; Shrink-Swell Capacity (0.87) Fair Good Good NA

Slightly to moderately alkaline Slightly to strongly alkaline Moderately to strongly alkaline. Moderately to strongly alkaline. Moderately to strongly alkaline. NA

63 14 60 60 81 NA

1

Data Sources: Soil Survey of Douglas-Plateau Area, Colorado; Soil Survey of Mesa County Area, Colorado; WSS (Web Soil Survey) 2007.

5

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26
87

25

30

52

29

28
75

27

26

65

25
61

74

35

Lay to

72

33

34

87

35

36

72

74

31

32

33
87

34

69

36
87

31

32
71

72

72 71

87

33

nW a sh

52

118

51

52

34

51

2

35

65

36

4
108 Rp Ce 68 Bd Rs

3

Bc Gt Re

Bc Re

Bd

Re Re

2
Re Hj

Gt

Bc Bl

T-R

d oa

69 118 52 47 275 69 210

1
69

6
87

5

108

87

4

3

2

1

6

BcA

Ff

5

87

4

3

2
87

Ff Gt Bc Hk Bl Cc BcW Rp Bl Rp Fe Hk Fh Hj GP 68 74

1
52

Hk Re

9
Re Hk Hk

BdCe

Cc

69 75 72

275

6

Cd Ce Hk Cd Hk

Hk BcA Hk Ff Bl Fe Bc

Bc

10

11
Bl

12
GP Gt

69

GP GP

7

8

BcSRp Ff

Bc

9
108

10

73

11

Bc Ce Hk Ba Bc Hk Hk

BcW Bc Cc Rp Hj

14

Bc

Hj Cc

999

Bl

13

108

12

108

7

8

52

9

18

10

75

16 Cd

Cc

17

11
75

16
72

12
75

Av

Bl Cc Ce Hk

15

Hk

15
72

75

7
87

14

13

69 74

6

Bl Av

Hk

BcA Av Bl Cc

Hj BcA

Hk Cc Hj Bl Cc CdCe Rp GP Ff Av Cc Hk Hk Hj Cc

10 Road
Hk Ce Bl Rp

Ce Hk Bl Av Av Bc

Bc Bl Hk

Cre

Salt

Hk

Hk

21
Sk Bc Sk

Cc

Bl

Eas t

Sk

Av Rp Bl Av

Bl Re Cc

22
Rs

ek

Hk Fe Cc Hj

Hk

Hk

BcW

7

Hj

Government Highlin
Hk Tr 69 Ff

Ma

8

e Canal
11
Tr

74 74

68

D ry

Cc

Fg

68

5

Gulc

Rp Bc

6

h

5

999 69

18

17
52

16

75

4

3

2

1

4

3
108

2

1

15

108

14

13
87

87

18

9

10

Fs

Hk

Hk

Ce Hk Ce

FfHj Re Cc Bl Av BcW Fh Hk Cd Hk Ce Hk Ce Hk

Hk Hj Hk Re

12

74

68 74 Hj Rs Cc

7
69

8

eede

Hj Ba Bc Bc

RpFf Fe

Gt

Ce Cc

Bc Sk

Av Rp

18Cc
Hj RpCc

SkGt 52

Sk Bc

Ff 999 Cc

Sk Re Sk

Bc Cc Hj Rp Ff

17

999

Wash

Av RpFf

Fe

Sk Rp Av Hk Rp Cc Sk

Gt Bc Av Bl Cc BcW

Bk Rp

n ipa L 9

h as W
10
74

108

75

11

75

12

22
52

23

24

75

19

28

BcA Gt

Gt

27

Cc

Hj Cc Av

Bc Av Sk

Hj

BcW

Ce Hk

Hk

Bc Rs Bc Hk Rp

Bl Fe Re Tr Bd

16
Cc Fh

15

Hj

14
Hk

Rp

13

Hj

52

68

18

Hj Bd

Bc

Hk Hj

Ma

Hj

127 91

lt Sa

e Cr

Tr

4

§ ¦ ¨

70

Hj

Gt

Hj

Bl Ff Hk Fh Bl

Rs

3

Hj 72

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Fh Cc

Hk

Tr

Fh

30 Av
Tr 68

999 Hj Hk Ce

Cd

Hk Av Hk BcS Fh Hk Hj Fh Cc Ce Bc Hk

Hj Hj Hj Cc

Bc Rs Re BcS Hk Re Hj Hj Cc Rp Rp Cc Fp Ff Rp Cc Hj Fr Fh Hk Rp Bl Fg Cc Rp

Ba RpHk Fe Fh Bc Hj Rs Bc Hk Hj Fe Bc Ff Cc

Cc

Ea

78

ek

Hj

Cc

999

Bc

Hk

Fg

Tr

Hk

Cc Re BcS Cc Cc Bl Fh Re Hk Hj Re Hk Re Hj Cc Fh Fg Fh Ff TrC Hk Hk Re Cd Hk Hj Hk Fe Bc Cd Hk Fe

st

Sk

Av

BcW

Hj Hk Fh

Ce Bc

Br

89

Sk Gt BcA

Sk

Bc

Hk

Rp

Bc

BcA

19

Ba

Re

20

Cc

Hj

an

Sk

Ff

Mack Hj Hj

Cc Rp

Hj

Hk

Hk

23

Cd

24

Bc

Bc

ch

Av

Re

Cc

Cc

999

Bi g

Rp

Hk

Hj

34

Sk

M BcA Cc 19 Gt Ff

Bc BlRe

Cc

Rp

20

Hj

Fe

Rs Bc

21

Bc

22

Ea

st

an Br

ch

Hj

Rc

Tr

Re Hk

Hk Rp BkD Cc Me

Sa

Rp

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BcA Gt

Av

33

Hj

d Bc

Cc

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Hk

Ff

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Bc

Hj

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lt W as

Bc Av

M.8

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Hk

h as BcA Rp W Bl

and B

Wa ed

Cc

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Cc

h

Cc

Rp

17
Rc

16

Hk

sh

15

14

13

27
85

26

25

30

87 108

21

Hk

Rc

22
Cc Cd 74

23

24

34

35

36

31

Fs

Fe Re

Fg

29

Ce

Av

28
Hj Fe Bc Fh Hj Fg

Hj

na l

Hk

Ca

Va l

127

68

Tr Tr Hj Fg Fh

Fh Hk Bc Hk Ff Fe

Fh

BcS Fh Cc Hk

Cc

Hk

Ff Fh

Fh Fg Fe

BcA Hj BcS BcS Fp BcA

BcS Hj

G

Hk

Hk

Fe

Ff

34

nd

88

89

ra

88

31

72

68

32

Ce

Hk

Hj

33

Fe

Fg

Fe

Bc

le y

78

9

10

68

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Fh Tr Fg Hj

Tr BcA Fg Hj

Av Hj Fe Cc Hj BcS Av Ff Cc Sk Bc Hj Fe Fh Fe Ff Hj Fg Hj Fe Hk Hk Hk Fh Ff Tr

27

Bc Cc

Fg Hk

Cc

26
Hk Hj BcS Cc BcA

BcS

25
Tr

Hk

Fg

30
Fs

Fg

Tr Cd

Bc Fh Fg Bc Hj Fh Bc Fe Tr Bd

Fg

29

Hk

Re Bc Rp Bk BkD

Fh Cc Fh Ff BcHk

TrFg Cc Ce Rp Ff Hk Hk Fh Hj

Fh

Bc Tr Av BkD

Hk HkHj BkD Tr Hk Bc Tr BlRe

28

Fr

74 Hk Ff Re

68

27
Fg Fh Ff Fg Hk Fs

Fg Cd

Fh

Ff

Fe Fh

Fg Rc Tr Re Rc

Fg

BcS

Hj Fe

Hk

Fe Sk

Sk

35Bc

36

Fp

Fe

45 91

alt

76

6
88

67

Fe Fh Re

Fp Ff BcW Fh BcW

Ff

Fp Re

Fr

Hj

Fe Re

6

Fg

Fp Fg

Bc

Rc BkD

5
Hj Fr

Cc Cc Fp Fr Av

Hj Fr Hj Hj

4
Fs

Hk

Lit tle S

5

72

Fh Hk

4

Fe

Hj

Hj

Fh Bc Fh

Fg Hk Fg

BcS

Hj

Hj

3

BcW Fe

2

Hk

Ff Fg Fe

Fe

1

Tr

Tr

Fr

101 91 999 91 76

8
76 71 91 67 76

Be Gt Bk

7

C

ra lo o

Tr

Ad

do

9 10
76

11
Bc 999

Be Rc Gk

Tr

12
Bc Ba Tr Rc

Be

Re Rc Bc Tr Rs Rc Tr Re

Fp

7

28

ll Bu
67

ny Ca

on

27

67 101 67

101 71 67

11
Ro

Gk

BcA Re Rc Re Be Rc Bc Rc Rc

BcS Bc Tr

Ft Rc

8
Rs

Fr Tr Re

Hj Tr

Fs Rc

Tr Be

Fp

Cc Fh

Hj Hk Rc Bc

Tr

ob eC

76

Ri

v

er

Fe

Fs

Fr

Cc

Bc

ree

21

22

7

68

10

Hj Rc Bc Fs Hk Ft Re Fs Fe Rc Tr Fr Tr Rc Bc

Ft

Bc

Tr

Re Bc Gm

Cc

BkD BcS Bc

W as

16

Fh

Fr Fg Fe Hk Fs Re Fh Rs

Rp

BkD Fe

h

Color

ado R
91

ive r

15

904

Hj

Bc BcS Hk

Ce Fe

Fe Fg Fp Fs

Cd Ce Fg

Fs Fh Av Fg Tr Hk

31

Hk Fg Bc

Gt

32
Re

Me

Re

Sk BkDBl BkD Hj Re Hj

Av Fh

Fg Fe

Hk

Ba Fs

Hk Cd Ce Ff Hk Fg Ba Fe Fg Fp Re Re Rc Re Tl

26

3

2 11 2 11 2

1 12 1 12
74

11 2 12 11 2 1 11 1 12 14 13
74

69

74

25

1

6

Hj

Fe

Hk

33

Hk

Fg

Hk

Fp Ma Fg

Fh

Fg

Fp

Rc Rc Hk Cd Hk Fg Fp

Hk

Hj

Hk Tr Hj Ff Hj Hj

Fs

Rc

Ff

Bk Fh

Fh Fs Hk Hj Ba Cd Bc Fg

34

Tl Rc Tr Rc

35

BcA Rs Tl

10 36

12 11 2
Rc

Fs

Tr

Tr

Bb Ce

Re Tr Tl Tr Tl Bc

Fh

Fp Hk Fg Hj Fg

Bc

Hj

15
Tr Cc Tr Rs

11

14 3

2 13 12 14 2 13 12

7

Hk Cc

14
Bc

11

1

18
52

Fg Tl Bc Re Gt Bc GcS BcS

3

Fg

2
Bc

Tl

Tl BcWRe

Hj Fg

1

Fh Fp

Ce

Rc Bb Tr BcS Ba

BcBcS BcS Tl Tr Tl

Bc

BcS

Bc

BcS

Ce

Bc

Fp

Rc

Bc Tr Cd Fe

Rc

Cc

Hj

k

Hj Cc Ce Fg Fp

Hk Bb

6

Cd Cc Hk Cd

74

Hk

Bc Tl Tr Rc

Rc Re Rc Bc

Tr Rc Rs Bc

Ba Be

Be Rc

9

Re Be Ba Rc

10
Rc

11 Tl
Ba

Fe

Ba Ba Tr Tr Re Tr Tl

Bc

12

18
101

999

Bc Ro

67

904

17

16
67 67

101

15

101

76 76 76

14

Ro Ro 88

999

Re

Bc

Re

Be

Tr Rc Bc Rc Re Tr

Rc Rc Bc Tr Ce

Tr BcW Ff Fg Hj Ba Hj Fg Fe Ff FfRp Tr Fe BkD Tr Ff Bk Ff Fp Rp Fe Rp Bc

Ff Tr

Fg Fs Ff FpHk Fh

Ba Bc

Cd Hj Fp Hj Tr

Hk Re Hk Hj Fe Bc

7

Rc Cc Bd Bc Hj Rp Hk Ce Bd Bc Fp Bd Hk Tr Hj Hj AvCRp CeRs Rp Tr Hk BkD Rp Hk Bc Hj Cd HjCe Ce Re Rc Rs Bb

Hk Bc Rp

5 Tr

Legend

4

Proposed Rail Spur 69kV Transmission Line Route Proposed Road
74

68

8

Hj

Ba Hk Bc Rs Fs Re

Ba Rs Av

Bc Hj CcCe Bd Rp Tr

Hk

swdc.CRWCD.allrivers 74 74 Hk swdc.CRWCD.alllakes Bd Rs

Rp

Coal Lease Application Hj Proposed Waste Rock Rs Re Disposal Area Cc
RpCc Proposed Land Use ApplicationCdCe Area Ce Cd Cc

9

68

13

Ro

Rc Cc

89

45

Ro

18

BcS Tr

Bc

17

999 999

Tr

16

Rc Tr

Bc

Be Re Re Tr Tr

15

Rs Tl Rc Rc

Bc BaSRp Ba Fg BkD Bl Ff

Hj Bc Fp

14

Rc

Rg

13 BcSAvC

Ff 999

Hj BcS Hk

Ba Tr

BaS

Ba

BcW

Fs Fg

18

Ff Re Rc Fe Hj Rs

Av

Tr

Rc Re

17

Project BaS Area
Hk

Hk

Ba

Hj Ce

Tr

0

0.5

1

2

3

4 Miles

´

Appendix F Project Area Soils

Red Cliff Mine EIS

16 Tr

Bc

Hk

ry
29 71 71 55 67 61 2 47 47 47

75

33

61

Fo
31
52 52 87 75 AvC

78

31

67

rk

Ho wa rd Ca n nyo

71

East

67

Gulch

H ch at et C yo an n

Sto ve Ca n nyo

Re e d

Wash

APPENDIX G W AT E R D ATA A N D I N F O R M AT I O N

Stream Classifications and Water Quality Standards

STREAM CLASSIFICATIONS and WATER QUALITY STANDARDS

REGION: 11 Desig PHYSICAL and BIOLOGICAL INORGANIC mg/l METALS ug/l Classifications NUMERIC STANDARDS

BASIN: LOWER COLORADO RIVER

TEMPORARY MODIFICATIONS AND QUALIFIERS

Stream Segment Description

11g. All tributaries to East Fork Parachute Creek on the south side of the East Fork Parachute Creek from a point immediately below First Anvil Creek to the confluence with Parachute Creek; all tributaries to Parachute Creek on the east side of Parachute Creek from a point immediately below the East Fork of Parachute Creek to the confluence with the Colorado River; and all tributaries to the Colorado River on the north side of the Colorado River from a point immediately below Cottonwood Creek to the confluence with Parachute Creek. Aq Life Cold 2 Recreation 1b Agriculture D.O. = 6.0 mg/l D.O.(sp)=7.0 mg/l pH=6.5-9.0 F.Coli=325/100ml E.Coli=205/100ml NH3(ac/ch)=TVS Cl2(ac)=0.019 Cl2(ch)=0.011 CN=0.005 S=0.002 B=0.75 NO2=0.05 As(ch)=100(Trec) Cd(ac)=TVS(tr) Cd(ch)=TVS CrIII(ac/ch)=TVS CrVI(ac/ch)=TVS Cu(ac/ch)=TVS Fe(ch)=1000(Trec) Pb(ac/ch)=TVS Mn(ac/ch)=TVS Hg(ch)=0.01(tot) Ni(ac/ch)=TVS Se(ac/ch)=TVS

Aq Life Cold 2 Recreation 2 Agriculture B(ch)=0.75

D.O. = 6.0 mg/l D.O.(sp)=7.0 mg/l pH=6.5-9.0 F.Coli=2000/100ml E.Coli=630/100ml

CN(ac)=0.2 NO2(ac)=10 NO3(ac)=100

As(ch)=100(Trec) Be(ch)=100(Trec) Cd(ch)=10(Trec) CrIII(ch)=100(Trec)

CrVI(ch)=100(Trec) Cu(ch)=200(Trec) Pb(ch)=100(Trec) Mn(ch)=200(Trec)

Ni(ch)=200(Trec) Se(ch)=20(Trec) Zn(ch)=2000(Trec)

11h. Mainstem of Parachute Creek from the confluence of the West and East Forks to the confluence with the Colorado River.

Ag(ac)=TVS Ag(ch)=TVS(tr) Zn(ac/ch)=TVS

12. All tributaries to East Fork Parachute Creek from its source to a point immediately below the mouth of First Anvil Creek.

Aq Life Cold 1 Recreation 2 Agriculture

D.O. = 6.0 mg/l D.O.(sp)=7.0 mg/l pH = 6.5-9.0 F.Coli=2000/100ml E.Coli=630/100ml

NH3(ac/ch)=TVS Cl2(ac)=0.019 Cl2(ch)=0.011 CN=0.005

S=0.002 B=0.75 NO2=0.05 NO3=10 Cl=250

As(ac/ch)=TVS Cd(ac)=TVS(tr) Cd(ch)=TVS CrIII(ac/ch)=TVS CrVI(ac/ch)=TVS Cu(ac/ch)=TVS

Fe(ch)=1000(Trec) Pb(ac/ch)=TVS Mn(ac/ch)=TVS Hg(ch)=0.01(tot) Ni(ac/ch)=TVS Se(ac/ch)=TVS

Ag(ac)=TVS Ag(ch)=TVS(tr) Zn(ac/ch)=TVS

13a. All tributaries to the Colorado River including wetlands, from a point immediately below the confluence of Parachute Creek to the Colorado/Utah border except for the specific listings in Segments 13b through 19. UP Aq Life Warm 2 Recreation 1a Agriculture D.O.= 5.0 mg/l pH = 6.5-9.0 F.Coli=200/100ml E.Coli=126/100ml NH3(ac/ch)=TVS Cl2(ac)=0.019 Cl2(ch)=0.011 CN=0.005

UP

Aq Life Warm 2 Recreation 1b Agriculture

D.O.= 5.0 mg/l pH = 6.5-9.0 F.Coli=325/100ml E.Coli=205/100ml

CN(ac)=0.2 NO2(ac)=10 NO3(ac)=100

B(ch)=0.75

As(ch)=100(Trec) Be(ch)=100(Trec) Cd(ch)=10(Trec) CrIII(ch)=100(Trec) S=0.002 B=0.75 NO2=0.05 As(ch)=100(Trec) Cd(ac/ch)=TVS CrIII(ac/ch)=TVS CrVI(ac/ch)=TVS Cu(ac/ch)=TVS

CrVI(ch)=100(Trec) Cu(ch)=200(Trec) Pb(ch)=100(Trec) Mn(ch)=200(Trec) Fe(ch)=1000(Trec) Pb(ac/ch)=TVS Mn(ac/ch)=TVS Hg(ch)=0.01(tot) Ni(ac/ch)=TVS Se(ac/ch)=TVS

Ni(ch)=200(Trec) Se(ch)=20(Trec) Zn(ch)=2000(Trec)

13b. All tributaries to the Colorado River, including wetlands, from the Government Highline Canal Diversion to a point immediately below Salt Creek, downgradient from the Government Highline Canal, the Orchard Mesa Canal No. 2, Orchard Mesa Drain, Stub Ditch and the northeast Colorado National Monument boundary, except for specific listings in Segment 13c.

Ag(ac/ch)=TVS Zn(ac/ch)=TVS

Temporary modifications: Se(ch)=existing ambient quality based on uncertainty. Persigo Wash from Grand Junction discharge to confluence with the Colorado River; and Little Salt Wash from Fruita discharge to confluence with the Colorado River for D.O., F. Coli., NH3, Cd, Cu, Ag, Ni, B, Hg, NO2 = existing quality. Expiration date of 2/28/09. NH3(ac/ch)=TVS(old)(Type i). Expiration date of 12/31/2011. D.O.= 5.0 mg/l pH = 6.5-9.0 F.Coli=200/100ml E.Coli=126/100ml NH3(ac/ch)=TVS Cl2(ac)=0.019 Cl2(ch)=0.011 CN=0.005 S=0.002 B=0.75 NO2=0.05 As(ch)=100(Trec) Cd(ac/ch)=TVS CrIII(ac/ch)=TVS CrVI(ac/ch)=TVS Cu(ac/ch)=TVS Fe(ch)=1000(Trec) Pb(ac/ch)=TVS Mn(ac/ch)=TVS Hg(ch)=0.01(tot) Ni(ac/ch)=TVS Se(ac/ch)=TVS Ag(ac/ch)=TVS Zn(ac/ch)=TVS Temporary modifications: Se(ch)=existing ambient quality, based on uncertainty. Expiration date of 2/28/09.

13c. Walker Wildlife Area Ponds.

Aq Life Warm 1 Recreation 1a Agriculture

STREAM CLASSIFICATIONS and WATER QUALITY STANDARDS
Desig PHYSICAL and BIOLOGICAL INORGANIC mg/l NH3(ac/ch)=TVS Cl2(ac)=0.019 Cl2(ch)=0.011 CN=0.005 S=0.002 B=0.75 NO2=0.05 NO3=10 Cl=250 SO4=WS S=0.002 B=0.75 NO2=0.05 NO3=10 Cl=250 SO4=WS As(ch)=100(Trec) Cd(ac/ch)=TVS CrIII(ac/ch)=TVS CrVI(ac/ch)=TVS Cu(ac/ch)=TVS Fe(ch)=WS(dis) Fe(ch)=1000(Trec) Pb(ac/ch)=TVS Mn(ch)=WS(dis) Mn(ac/ch)=TVS Hg(ch)=0.01(tot) Ni(ac/ch)=TVS Se(ac/ch)=TVS Ag(ac/ch)=TVS Zn(ac/ch)=TVS As(ac)=50(Trec) Cd(ac)=TVS(tr) Cd(ch)=TVS CrIII(ac)=50(Trec) CrVI(ac/ch)=TVS Cu(ac/ch)=TVS Fe(ch)=WS(dis) Fe(ch)=1000(Trec) Pb(ac/ch)=TVS Mn(ch)=WS(dis) Mn(ac/ch)=TVS Hg(ch)=0.01(tot) Ni(ac/ch)=TVS Se(ac/ch)=TVS Ag(ac)=TVS Ag(ch)=TVS(tr) Zn(ac/ch)=TVS METALS ug/l Aq Life Cold 1 Recreation 1b Water Supply Agriculture D.O.=6.0 mg/l D.O.(sp)= 7.0 mg/l pH=6.5-9.0 F.Coli=325/100ml E.Coli=205/100ml Classifications NUMERIC STANDARDS

REGION: 11 TEMPORARY MODIFICATIONS AND QUALIFIERS

BASIN: LOWER COLORADO RIVER

14a. Mainstem of Roan Creek including all wetlands, tributaries, lakes, and reservoirs, from its source to a point immediately above the confluence with Clear Creek.

14b. Mainstem of Roan Creek including all tributaries, wetlands, lakes and reservoirs, from a point immediately below the confluence with Clear Creek to the confluence with the Colorado River.

Aq Life Warm 1 Recreation 1b Water Supply Agriculture

D.O.=5.0 mg/l pH=6.5-9.0 F.Coli=325/100ml E.Coli=205/100ml

NH3(ac/ch)=TVS Cl2(ac)=0.019 Cl2(ch)=0.011 CN=0.005

15. Mainstem of Plateau Creek including all tributaries, wetlands, lakes, and reservoirs, from its source to the confluence with the Colorado River.

Aq Life Cold 1 Recreation 1a Water Supply Agriculture

D.O.=6.0 mg/l D.O.(sp)= 7.0 mg/l pH=6.5-9.0 F.Coli=200/100ml E.Coli=126/100ml

NH3(ac/ch)=TVS Cl2(ac)=0.019 Cl2(ch)=0.011 CN=0.005

S=0.002 B=0.75 NO2=0.05 NO3=10 Cl=250 SO4=WS

As(ac)=50(Trec) Cd(ac)=TVS(tr) Cd(ch)=TVS CrIII(ac)=50(Trec) CrVI(ac/ch)=TVS Cu(ac/ch)=TVS

Fe(ch)=WS(dis) Fe(ch)=1000(Trec) Pb(ac/ch)=TVS Mn(ch)=WS(dis) Mn(ac/ch)=TVS Hg(ch)=0.01(tot)

Ni(ac/ch)=TVS Se(ac/ch)=TVS Ag(ac)=TVS Ag(ch)=TVS(tr) Zn(ac/ch)=TVS

16. Deleted.

17. Mainstem of Rapid Creek, including all tributaries, wetlands, lakes and reservoirs, from its source to the confluence with the Colorado River.

Aq Life Cold 1 Recreation 1b Water Supply Agriculture

D.O. = 5.0 mg/l pH = 6.5-9.0 F.Coli=200/100ml E.Coli=126/100ml

NH3(ac/ch)=TVS Cl2(ac)=0.019 Cl2(ch)=0.011 CN=0.005

S=0.002 B=0.75 NO2=0.05 NO3=10 Cl=250 SO4=WS

As(ac)=50(Trec) Cd(ac)=TVS(tr) Cd(ch)=TVS CrIII(ac)=50(Trec) CrVI(ac/ch)=TVS Cu(ac/ch)=TVS Fe(ch)=WS(dis) As(ac)=50(Trec) Cd(ac)=TVS(tr) Cd(ch)=TVS CrIII(ac)=50(Trec) CrVI(ac/ch)=TVS Cu(ac/ch)=TVS

Fe(ch)=1000(Trec) Pb(ac/ch)=TVS Mn(ch)=WS(dis) Mn(ac/ch)=TVS Hg(ch)=0.01(tot) Ni(ac/ch)=TVS

Se(ac/ch)=TVS Ag(ac)=TVS Ag(ch)=TVS(tr) Zn(ac/ch)=TVS

18. Mainstem of Little Dolores River, including all tributaries, wetlands, lakes and reservoirs, from its source to immediately below the confluence with Hay Press Creek.

Aq Life Cold 1 Recreation 1b Water Supply Agriculture

D.O. = 6.0 mg/l D.O.(sp)=7.0 mg/l pH = 6.5-9.0 F.Coli=325/100ml E.Coli=205/100ml

NH3(ac/ch)=TVS Cl2(ac)=0.019 Cl2(ch)=0.011 CN=0.005

S=0.002 B=0.75 NO2=0.05 NO3=10 Cl=250 SO4=WS S=0.002 B=0.75 NO2=0.05

Fe(ch)=WS(dis) Fe(ch)=1000(Trec) Pb(ac/ch)=TVS Mn(ch)=WS(dis) Mn(ac/ch)=TVS Hg(ch)=0.01(tot) As(ch)=100(Trec) Cd(ac/ch)=TVS CrIII(ac/ch)=TVS CrVI(ac/ch)=TVS Cu(ac/ch)=TVS Fe(ch)=1000(Trec) Pb(ac/ch)=TVS Mn(ac/ch)=TVS Hg(ch)=0.01(tot) Ni(ac/ch)=TVS Se(ac/ch)=TVS

Ni(ac/ch)=TVS Se(ac/ch)=TVS Ag(ac)=TVS Ag(ch)=TVS(tr) Zn(ac/ch)=TVS

19. All lakes and reservoirs tributary to the Colorado River from a point immediately below the confluence of the Colorado River and Parachute Creek to the Colorado-Utah border.

Aq Life Warm 1 Recreation 1a Agriculture

D.O.=5.0 mg/l pH=6.5-9.0 F.Coli=200/100ml E.Coli=126/100ml

NH3(ac/ch)=TVS Cl2(ac)=0.019 Cl2(ch)=0.011 CN=0.005

Ag(ac/ch)=TVS Zn(ac/ch)=TVS

Baseline Hydrologic Data Report and Spring Inventory Prepared for the Dorchester Coal Company Fruita Mine Permit Application

Water Quality Data

BLM Surface Water Analytical Data

BLM Water Quality Data
COND_F
HARDNESS CaCO3 mg/l

NAME μS/cm μS/cm NTU μg/l mg/l μg/l μg/l mg/l μg/l μg/l mg/l mg/l μg/l mg/l mg/l mg/l Co/Pt mg/l

DATE

Q

PH_L

PH_F

TEMP

COND_L

TURBIDITY

ARSENIC

BARIUM

CADMIUM

CHROMIUM FLUORIDE

LEAD

MERCURY

NITRATE

SELENIUM

SILVER

BICARBONAT CARBONATE POTASSIUM

COLOR

CALCIUM

cfs

SU

SU

C.

9.00

2230

7.80

650

0.0 0.0 0.0

470 323 301 312

BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) 1750 1490 1700 1900 1300 1950 1500 2000 1200 1700 1500 50.0 140.0 150.0 4.0 66.0 48.0 320.0 750.0 101.0 1580.0 280.0 175.0 60.0 74.0 75.0 65.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 460 464 299 440 572 406 515 390 436 401 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.10 0.19 0.00 0.05 0.03 0.0 0.0 0.0 0.0 0.4 0.4 0.0 0.5 0.0 0.0 0.2 0.2 0.0 1.0 0.0 0.2 2.0 0.0 0.0 4.0 0.0 1.0 0.0 0.0 0.0 0.0 3.0 0.0 0.0 0.0 0.0 1.0 0.0 0.0 0.0 0.0 3.0 1.0 0.0 0.0 0.0 0.0 0.0 1.0 0.0 5.0 3.0 0.0 0.00 0.00 0.00 0.00 0.16 0.01 0.00 0.00 0.00 0.00 0.00 0.13 0.00 0.22 0.00 0.69 0.000 0.000 0.001 0.000 0.000 0.000 0.000 0.002 0.000 0.004 0.000 0.000 0.000 0.000 0.000 0.004 0.00 0.00 0.00 0.00 0.00 0.20 0.00 0.00 0.00 0.00 0.00 0.80 0.00 0.00 0.20 0.00 351.0 283.0 313.0 107.0 387.0 425.0 371.0 384.0 375.0 347.0 308.0 338.0 357.0 356.0 330.0 365.0 0.00 26.40 0.00 10.10 9.00 0.00 0.00 0.00 0.00 15.30 36.00 0.00 26.00 0.00 30.70 0.00 0.0 0.0 0.0 3.0 0.0 0.0 10.0 2.0 5.0 7.0 12.0 5.0 5.0 3.0 5.0 0.0 980 900 1100 1320 1220 1300 1400
1256 1512 202.2 0.0 0.12 0.2 0.5 0.279 0.7 0.05 0.196 0.001 0.06 338.0

8/25/1981 6/29/1982 9/3/1982 5/6/1983 8/24/1983 9/23/1983 3/9/1984 8/14/1984 6/13/1985 9/10/1985 6/4/1986 9/9/1986 7/8/1987 9/1/1987 6/14/1988 9/14/1988 5/23/1989 6/21/1990 9/18/1990 6/25/1991 5/22/1992 7/28/1993 9/28/1993 5/26/1994 7/17/1995 9/11/1995 1050 1070 1350 1850 1410 1160 1470 278.0 220.0 30.0 9.5 4.0 47.0 125.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.38 0.00 0.62 1.02 0.04 0.14 0.00 0.2 0.3 0.1 0.2 0.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.0 0.0 0.380 0.390 0.310 0.340 0.320 0.380 0.400 1.0 0.0 0.0 0.0 0.0 0.0 1.0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.398 0.220 0.340 0.330 0.440 0.260 0.600 0.001 0.000 0.000 0.000 0.000 0.000 0.004 0.20 0.00 0.00 0.00 0.00 0.00 0.00 338.0 369.0 350.0 453.0 355.0 243.0 268.0 37.00 0.00 5.40 0.00 19.20 24.60 44.30
12.35

0.05 1.85 0.90 28.60 1.72 0.67 4.34 4.03 11.60 1.70 13.40 2.10 2.20 0.70 2.40 0.62 1.32 0.00 0.00 0.80 1.70 2.50 0.67 2.68 3.10 0.69 4.10 3.20 2.30 3.40 3.50 1.70 4.90
3.65

8.40 8.20 8.10 8.20 8.25 8.50 8.45 8.00 8.46 8.30 8.30 8.20

8.80 8.80 8.70 8.90 8.50 8.40 8.80 8.10 8.00 8.50 8.50 8.80 8.80 8.75 8.20 7.40 7.90

27.0 16.0 22.0 8.0 17.5 15.5 2.5 23.0 12.0 15.0 20.5 18.0 19.0 23.0 22.0 9.0 18.0

2270 1180 1000 560 1175 1150 950 1350 1250 1500 1170 1750 1220 1880 1200 1100 1210

0.400 0.180 0.260 0.230 0.220 0.255 0.241 0.500 0.270 0.280 0.190 0.140 0.200 0.200 0.280 0.270 0.070

0.110 0.000 0.000 0.000 0.000 0.000 0.085 0.210 0.740 0.000 0.267 0.200 0.060 0.001 0.058 0.000 0.379

2.80 2.50 2.40 1.80 3.40 2.93 3.75 3.00 14.80 2.10 2.00 2.90 2.40 2.60 2.00 10.00 3.00

33.0 30.2 27.2 42.9 43.5 30.1 90.2 45.3 57.4 72.1 68.0 51.0 43.0 42.0 33.0 39.0 36.0

8.35 8.35 8.40 8.25 8.50 8.40 8.70

8.50 7.70 8.60 8.70 8.50 8.40 8.50

15.0 21.0 14.0 13.0 23.0 25.0 19.0

7.0 0.0 0.0 4.0 0.0 0.0 1.0
3.0

349 307 468 508 399 314 341
404

41.0 36.0 46.0 49.0 38.0 37.0 41.0
44.7

BIG SALT WASH ABV DIVERSION (K) averages

3.47

8.3

8.4

17.4

EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I)
3770 4446 202.4 0.0 0.15 0.6 0.8 0.346 3.7 0.02 0.647

8/15/1984 6/13/1985 9/10/1985 6/4/1986 9/9/1986 7/8/1987 9/1/1987 6/14/1988 9/14/1988 5/23/1989 8/30/1989 6/21/1990 9/17/1990 6/25/1991 9/5/1991 5/22/1992 9/4/1992 7/28/1993 9/28/1993 5/26/1994 8/30/1994 7/17/1995 9/11/1995

5.30 18.60 2.50 34.20 0.92 1.00 1.70 4.60 1.44 0.42 1.62 2.19 1.84 1.42 0.25 3.50 0.40 1.50 1.89 5.10 1.50 4.90 0.64

7.85 7.95 7.95 8.40 8.50 8.40 8.40 8.20 8.00 8.00 7.70 7.90 7.80 7.80 7.60 8.15 7.70 8.10 7.80 8.50 7.60 8.40 8.00

7.95 8.40 8.40 8.50 8.60 8.30 8.10 7.50 7.30 7.05 8.30 7.80 7.80 7.20 7.40

8.25 7.80 8.10 7.65 8.25 7.80

23.5 27.0 17.0 21.0 21.0 19.0 16.5 19.0 12.0 20.0 22.0 20.0 25.0 23.0 18.0 26.0 17.0 18.0 19.0 25.0 23.0 26.0 23.0

3420 2550 4400 2250 7200 4900 4370 3850 3600 7200 1600 1000 2230 1020 3700 3780 6000 6000 1800 5000 3000 3750 4100

5000 2750 5400 2500 7350 4800 5200 3900 4700 8000 2000 1200 2200 900 4100 3950 12000 6700 2200 5380 3650 3940 4430

375.0 600.0 42.0 163.0 34.0 30.0 380.0 100.0 400.0 37.5 125.0 525.0 500.0 230.0 18.0 450.0 5.0 15.0 85.0 0.9 30.0 290.0 220.0

0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

0.00 0.00 0.20 0.00 0.00 0.40 0.08 0.65 0.00 0.36 0.03 0.00 0.01 0.00 0.00 0.27 0.20 0.00 1.21 0.04 0.05 0.00 0.00

0.0 0.0 0.0 0.0 0.0 1.0 0.2 0.8 9.4 0.6 0.0 0.0 0.2 0.2 0.2 0.0 0.8 1.0 0.2 0.2 0.0 0.0 0.0

0.0 0.0 0.0 0.0 5.0 5.0 5.0 3.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

0.450 0.270 0.330 0.210 0.240 0.300 0.180 0.320 0.260 0.460 0.500 0.200 0.370 0.220 0.410 0.510 0.300 0.420 0.360 0.450 0.280 0.450 0.470

4.0 0.0 0.0 0.0 0.0 6.0 0.0 0.0 2.0 9.0 2.0 0.0 4.0 1.0 0.0 0.0 0.0 55.0 1.0 0.0 0.0 0.0 0.0

0.00 0.00 0.00 0.09 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.11 0.00 0.10 0.00 0.00 0.00 0.00 0.00 0.00 0.14 0.00 0.00

0.248 0.590 0.177 0.630 0.150 0.075 0.667 0.395 0.575 0.880 0.667 1.100 1.530 0.228 0.820 0.920 0.867 0.570 0.630 0.840 0.560 1.010 0.750

0.000 0.004 0.000 0.000 0.001 0.006 0.004 0.002 0.000 0.003 0.000 0.000 0.004 0.010 0.000 0.000 0.000 0.000 0.000 0.002 0.009 0.000 0.000
0.002

0.3 0.0 0.0 0.0 0.7 0.8 0.5 0.0 0.8 0.0 0.0 0.5 0.2 0.3 0.0 0.0 0.0 0.0 0.0 0.2 0.0 0.0 0.0
0.2

100.0 338.0 341.0 309.0 538.0 384.0 255.0 426.0 358.0 456.0 196.0 163.0 186.0 154.0 336.0 421.0 577.0 361.0 234.0 433.0 253.0 332.0 332.0
325.3

0.00 0.00 0.00 28.10 28.00 38.00 17.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 18.80 0.00 34.40 0.00
7.1

11.70 21.20 7.80 4.80 8.20 7.60 7.70 4.80 40.00 7.50 10.00 6.40 12.30 4.10 13.70 10.10 12.30 6.60 14.90 11.60 13.20 6.20 15.60
11.2

10.0 3.0 3.0 10.0 5.0 5.0 5.0 3.0 7.0 0.0 0.0 0.0 25.0 6.0 7.0 30.0 0.0 0.0 15.0 1.0 5.0 5.0 5.0
6.5

1040 765 1500 784 2120 1770 2020 965 1490 1910 727 345 806 284 1530 1020 4550 2320 1100 1467 1060 749 1200
1371

125.0 79.9 205.0 77.0 172.0 147.0 134.0 110.0 173.0 160.0 293.0 86.0 200.0 67.0 280.0 107.0 322.0 236.0 161.0 185.0 171.0 91.0 208.0
164.8

EAST SALT CREEK ABOVE CANAL (I) averages

4.2

8.0

7.9

20.9

EAST SALT CREEK AT 6&50 (I) EAST SALT CREEK AT 6&50 (I) EAST SALT CREEK AT 6&50 (I) EAST SALT CREEK AT 6&50 (I) EAST SALT CREEK AT 6&50 (I) EAST SALT CREEK AT 6&50 (I) EAST SALT CREEK AT 6&50 (I) 3500
3500 140.1 0.1 2277 0.00

8/24/1981 6/29/1982 9/3/1982 5/5/1983 8/24/1983 9/23/1983 3/9/1984

13.90 8.60 15.50 63.90 21.40 14.00 12.00

1200 1112 1154 575

7.80

8.20 8.60 8.30 8.60 8.20 8.50 8.30

23.0 24.0 19.0 10.0 16.5 11.0 4.0

2910 2610 2400 1220 2020 2580 2200

0.0 45.0 160.0 640.0 4.0 12.0 120.0

0.0 0.0 0.0 0.0 0.0 0.0 1.0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

0.0 0.0 0.0 0.0 0.2 0.2 0.7
0.2

0.0 4.0 0.0 0.0 1.0 0.0 1.0
0.9

0.300 0.130 0.250 0.297 0.200 0.270 0.244
0.242

0.0 1.0 0.0 0.0 0.0 3.0 1.0
0.7

0.00 0.00 0.00 0.00 0.00 0.00 0.18
0.03

3.200 1.750 3.470 0.190 0.780 0.950 0.550
1.556

0.000 0.000 0.000 0.000 0.000 0.000 0.006
0.001

0.0 0.0 0.0 0.0 0.0 0.0 0.0
0.0

0.0 188.0 261.0 311.0 284.0 267.0 391.0
243.1

0.00 0.00 0.00 12.00 0.00 0.00 0.00
1.71

6.50 7.63 6.80 8.11 3.96 6.93 4.67
6.37

0.0 5.0 0.0 0.0 2.0 2.0 0.0
1.3

280.0 232.0 252.0 89.3 191.0 252.0 160.0
1010 208.0

EAST SALT CREEK AT 6&50 (I) averages

21.33

7.8

8.4

15.4

SALT CREEK AT I-70 (H) SALT CREEK AT I-70 (H) SALT CREEK AT I-70 (H) SALT CREEK AT I-70 (H) SALT CREEK AT I-70 (H) 1480 1700 1865
1774 276.0

averages averages averages averages averages 87.0 250.0 700.0 67.0
1420

8/24/1981 6/29/1982 5/5/1983 8/2/1993 9/28/1993

127.00 112.50 185.50 98.90 150.00

8.10

2050 0.0 0.0 0.0 0.0
0.0

8.00 8.20 7.95

8.20 8.50 8.40 8.20 7.90

23.0 22.0 16.0 23.0 16.0

1770 1250 1250 1500 1330

0.00 0.00 0.00 1.30
0.33

0.0 0.0 0.1 0.3
0.1

27.0 0.0 0.0 0.0
6.8

0.300 0.180 0.300 0.310 0.350
0.288

1.0 0.0 0.0 0.0
0.3

0.00 0.00 0.00 0.00
0.00

1.800 1.200 0.210 1.110 0.960
1.056

0.000 0.000 0.002 0.000
0.001

0.00 0.00 0.00 0.00
0.00

188.0 154.0 208.0 209.0
189.8

0.00 4.85 0.00 0.00
1.21

5.20 4.25 5.27 4.50 6.20
5.08

0.00 0.00 5.00 1.00
1.50

570 566 464 818 744
632

190.0 136.0 104.0 208.0 190.0
165.6

SALT CREEK AT I-70 (H) averages

134.78

8.06

8.24

20.00

Page 1 of 4

BLM Water Quality Data
COND_F
HARDNESS CaCO3 mg/l

NAME μS/cm μS/cm NTU μg/l mg/l μg/l μg/l mg/l μg/l μg/l mg/l mg/l μg/l mg/l mg/l mg/l Co/Pt mg/l

DATE

Q

PH_L

PH_F

TEMP

COND_L

TURBIDITY

ARSENIC

BARIUM

CADMIUM

CHROMIUM FLUORIDE

LEAD

MERCURY

NITRATE

SELENIUM

SILVER

BICARBONAT CARBONATE POTASSIUM

COLOR

CALCIUM

cfs

SU

SU

C.

8.10 8.55 7.65 8.40 8.20 8.10 7.60 8.05 0.0 5.0 0.0 0.0 7.0 1.0 8.0 1.0 0.320 4.0 0.08 0.281 0.000 0.0 135.0 0.00 5.20 30.0 746 2230 2050 100000 0.0 0.02 0.4

8.40 8.40 8.60 8.55 8.00 7.70 7.20 7.20

24.0 26.0 17.0 16.0 22.0 17.0 15.0 22.0

5010 13800 4000 8200 7950 8000 11000 16000

5250 12000 6500 13500 7800 9300 22200 16000

1630 12.0 87.0 90.0 15.0 450.0 5.0 0.2

0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

0.00 0.00 0.76 0.00 0.80 0.00 0.25 0.06

0.5 0.0 0.0 0.5 1.3 0.3 0.0 0.8

0.200 0.240 0.360 0.180 0.440 0.220 0.450 0.610

0.0 2.0 3.0 0.0 0.0 1.0 0.0 21.0

0.00 0.00 0.00 0.00 0.10 0.00 0.07 0.00

0.710 0.150 0.024 0.000 0.170 0.370 0.542 1.130

0.000 0.000 0.000 0.000 0.000 0.000 0.004 0.001

0.0 0.4 0.9 0.4 0.0 0.2 0.0 0.0

298.0 333.0 338.0 267.0 359.0 353.0 407.0 345.0

0.00 38.00 0.00 12.00 0.00 0.00 0.00 0.00

13.20 17.60 11.40 13.40 11.40 4.00 16.90 32.20

10.0 5.0 7.0 10.0 1.5 6.0 0.0 2.0

1850 4550 2720 3480 3160 3430 5040 5630

225.0 395.0 267.0 342.0 316.0 345.0 406.0 451.0 217.0

7.70

7.80

26.0

WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') 8500 14500 12000 14500 12000 8000
9245 11569 286.2 0.0 0.23 2.0 3.0 0.338 3.4 0.02 0.387 0.001 0.2 337.5 6.25

6/4/1986 9/9/1986 7/8/1987 9/1/1987 6/14/1988 9/1/1988 5/23/1989 8/30/1989 6/21/1990 9/17/1990 6/25/1991 9/5/1991 5/22/1992 9/4/1992 7/28/1993 9/28/1993 7/17/1995 9/11/1995 5600 14800 13400 20800 16000 7730 11100 1.5 1.5 2.8 275.0 16100 0.0 0.0 0.0 0.0 0.0 0.0 0.04 0.10 0.00 2.88 0.00 0.00 0.3 1.2 0.7 1.3 0.0 0.3 0.0 0.0 0.0 3.0 0.0 2.0 0.570 0.420 0.410 0.460 0.480 0.480 0.0 9.0 3.0 0.0 9.0 2.0 0.00 0.00 0.00 0.00 0.00 0.00 1.500 0.690 0.690 0.750 0.800 2.030 0.000 0.001 0.000 0.002 0.002 0.000 0.0 0.0 0.0 0.0 0.2 0.0 376.0 451.0 449.0 430.0 323.0 342.0 0.00 0.00 0.00 35.40 34.40 0.00 21.70 24.20 12.80 24.40 18.20 18.80
15.01

6.60 0.36 1.04 0.58 0.43 0.33 0.01 0.03 0.00 0.41 0.00 0.00 0.02 0.05 0.14 0.09 0.79 0.27 0.0 0.0 5.0 10.0 5.0 17.0
5.2

8.00 8.25 8.10 8.35 8.40 8.30

7.60

8.25 8.30 8.35 8.10

30.0 17.0 28.0 23.0 28.0 26.0

2390 1910 5430 6010 3150 2060
3733

271.0 293.0 420.0 476.0 311.0 290.0
343.4

WEST SALT CREEK AT GAGE (J') averages

0.62

8.1

8.0

19.9

8.20

WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) 1200 6600 5500 5800 10800
5980.0 4007.8 0.0 0.00 0.2 0.9 0.261 2.0 0.08 0.527 0.001

8/25/1981 6/29/1982 9/3/1982 5/5/1983 8/24/1983 9/23/1983 3/9/1984 8/15/1984 6/14/1985 9/10/1985 210.0 310.0 300.0 3.0 86.0 15.0 35000 95.0 51.0
0.3

24.60 16.60 40.70 40.70 32.40 33.70 2.09 1.80 2.40 0.79 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0 0.0 0.0 0.0 0.0 1.6 0.2 0.1 0.0 2.0 0.0 0.0 1.0 0.0 5.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 9.0 6.0 1.0 0.0 2.0 0.00 0.00 0.00 0.00 0.61 0.14 0.00 0.00 0.00 0.000 0.000 0.000 0.000 0.000 0.004 0.000 0.001 0.001 0.0 0.0 0.0 0.0 0.0 2.5 0.0 0.0 0.0
3082.5

7.50

7.90 7.85 6.70 8.20 8.20

8.40 8.10 8.30 8.20 8.50 8.30

700 642 500 516

8.20 8.20

16.0 23.0 15.0 14.0 16.5 12.5 7.0 21.5 22.0 19.0

1845 1420 1190 1500 1200 1220 4350 3900 6100 8100

0.300 0.130 0.220 0.260 0.175 0.270 0.208 0.420 0.270 0.360

0.810 0.640 0.681 0.240 0.455 0.330 1.400 0.361 0.350 0.000

192.0 186.0 199.0 84.0 155.0 317.0 189.0 321.0 352.0
221.7

0.00 0.00 4.85 72.40 0.00 0.00 0.00 0.00 0.00
8.58

4.90 6.58 4.10 4.98 2.80 5.25 8.85 23.30 40.60 11.00
11.24

0.0 0.0 5.0 2.0 2.0 0.0 30.0 4.0 5.0
5.3

2090 2670 3480
1514

185.0 170.0 114.0 104.0 134.0 115.0 496.0 503.0 302.0 327.0
245.0

WEST SALT CREEK NR 8 ROAD (J) averages

19.58

7.8

8.3

16.7

Page 2 of 4

BLM Water Quality Data

NAME
MANGANESE
MOLYBDENUM

DATE
PHOSPHATE ALUMINUM

Q mg/l mg/l mg/l μg/l mg/l μg/l μg/l μg/l mg/l mg/l mg/l μg/l

MAGNESIUM

SODIUM

CHLORIDE

SULFATE

PHEN_ALK

TOT_ALK

DIS_SOLID

IRON

COPPER

ZINC

AMMONIA

BORON

cfs

mg/l

mg/l

mg/l

mg/l

BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) BIG SALT WASH ABV DIVERSION (K) 0.00 22.00 0.00 84.40 7.50 0.00 0.00 0.00 0.00 12.70 30.00 0.00 22.00 0.00 25.60 0.00 0.0 20.0 30.0 16.0 53.0 2.0 0.0 13.0 0.0 0.0 0.0 0.0 0.0 0.0 2.0 2.0 0.0 0.0 0.0 5.0 1.0 1.0 2.0 11.0 2.0 1.0 0.0 29.0 6.0 5.0 4.0 3.0 5.0 27.0 3.0 0.0 0.0 4.0 3.0 6.0 5.0 12.0 11.0 12.0 20.0 20.0 0.0 0.0 12.0 15.0 31.0 15.0 21.0 8.0 6.0 3.0 12.0 0.000 0.000 0.040 0.660 0.120 0.000 0.320 0.000 0.090 0.083 0.320 0.450 0.000 0.300 0.800 0.440 0.130 0.180 0.110 0.135 0.179 0.095 0.070 0.070 0.180 0.000 0.200 0.182 0.015 0.000 0.215 0.080 30.50 0.00 4.50 0.00 16.00 20.50 36.90
13.59 312.4 1106 75.8 0.006 2.3 6.6 12.8 0.227 0.046 0.110 9.3

8/25/1981 6/29/1982 9/3/1982 5/6/1983 8/24/1983 9/23/1983 3/9/1984 8/14/1984 6/13/1985 9/10/1985 6/4/1986 9/9/1986 7/8/1987 9/1/1987 6/14/1988 9/14/1988 5/23/1989 6/21/1990 9/18/1990 6/25/1991 5/22/1992 7/28/1993 9/28/1993 5/26/1994 7/17/1995 9/11/1995 340.0 305.0 298.0 374.0 325.0 242.0 295.0 945 847 964 1670 1271 861 1120 0.0 0.0 0.0 100.0 70.0 60.0 380.0 0.002 0.000 0.001 0.028 0.001 0.005 0.000 12.0 0.0 6.0 0.0 2.0 3.0 5.0 3.0 10.0 11.0 6.0 5.0 15.0 0.0 20.0 15.0 15.0 8.0 12.0 15.0 12.0 0.080 0.850 0.000 0.000 0.000 0.000 0.670 0.050 0.010 0.000 0.010 0.040 0.000 0.010 0.277 0.049 0.060 0.015 0.067 0.146 0.085 9.0 0.0 0.0 0.0 2.0 3.0 0.0

0.05 1.85 0.90 28.60 1.72 0.67 4.34 4.03 11.60 1.70 13.40 2.10 2.20 0.70 2.40 0.62 1.32 0.00 0.00 0.80 1.70 2.50 0.67 2.68 3.10 0.69

94.00 55.40 51.70 47.10 83.00 81.30 60.00 83.90 77.60 28.40 88.00 102.00 75.00 94.00 75.00 79.00 74.00

400.00 139.00 135.00 60.00 146.00 139.00 265.00 194.00 185.00 254.00 156.00 267.00 240.00 325.00 159.00 300.00 380.00

38.00 8.00 10.00 6.00 8.80 9.20 12.00 4.00 3.20 4.40 10.00 17.00 9.00 17.00 14.00 23.00 10.00

790.0 326.0 233.0 135.0 540.0 300.0 600.0 375.0 619.0 442.0 550.0 888.0 730.0 725.0 363.0 653.0 781.0

450.0 290.0 278.0 259.0 257.0 335.0 351.0 307.0 317.0 310.0 312.0 314.0 279.0 339.0 294.0 324.0 302.0

1630 798 678 456 980 972 1210 1110 966 1420 1030 1460 1090 1510 1010 1250 1300

20.0 0.0 434.0 0.0 0.0 0.0 136.0 35.0 253.0 70.0 10.0 230.0 0.0 20.0 0.0 0.0 0.0

0.010 0.023 0.019 0.003 0.018 0.001 0.002 0.002 0.004 0.000 0.003 0.002 0.000 0.014 0.004 0.009 0.003

0.010 0.000 0.015 0.040 0.000 0.010 0.006 0.109 0.030 0.000 0.010 0.090 0.040 0.040 0.090 0.000 0.496

60.00 53.00 86.00 87.00 74.00 54.00 58.00

167.00 106.00 72.00 324.00 250.00 131.00 226.00

10.00 1.00 5.00 6.00 16.00 10.00 32.00

300.0 275.0 365.0 733.0 513.0 380.0 531.0

BIG SALT WASH ABV DIVERSION (K) averages

3.47

71.7

209.2

11.8

506.1

EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) EAST SALT CREEK ABOVE CANAL (I) 4160 6670 1470 719 1780 790 2870 2400 8200 4420 1570 4060 2930 2830 3400
3211.3 85.0 0.087 10.9 26.9 5.3 0.424 5.9 454.9 0.093 0.163

8/15/1984 6/13/1985 9/10/1985 6/4/1986 9/9/1986 7/8/1987 9/1/1987 6/14/1988 9/14/1988 5/23/1989 8/30/1989 6/21/1990 9/17/1990 6/25/1991 9/5/1991 5/22/1992 9/4/1992 7/28/1993 9/28/1993 5/26/1994 8/30/1994 7/17/1995 9/11/1995

5.30 18.60 2.50 34.20 0.92 1.00 1.70 4.60 1.44 0.42 1.62 2.19 1.84 1.42 0.25 3.50 0.40 1.50 1.89 5.10 1.50 4.90 0.64

217.00 131.00 236.00 126.00 368.00 261.00 315.00 161.00 246.00 298.00 2.00 32.00 75.00 29.00 202.00 183.00 911.00 422.00 170.00 253.00 155.00 127.00 166.00

615.00 414.00 832.00 385.00 1600.00 945.00 908.00 682.00 798.00 1670.00 185.00 56.50 277.00 124.00 365.00 294.00 745.00 394.00 68.30 665.00 438.00 578.00 740.00

94.00 34.00 48.00 33.00 210.00 72.00 126.00 91.00 111.00 260.00 240.00 76.00 141.00 62.00 158.00 81.00 118.00 46.00 156.00 133.00 22.00 76.00 188.00

2200.0 1300.0 3050.0 1320.0 4870.0 2630.0 3060.0 1910.0 2750.0 4210.0 568.0 265.0 1080.0 350.0 1830.0 1300.0 5500.0 2950.0 763.0 2500.0 1875.0 1430.0 2040.0

0.00 0.00 0.00 23.40 23.00 32.00 14.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 15.70 0.00 28.70 0.00

82.6 279.0 4640.0 301.0 492.0 381.0 239.0 0.0 296.0 377.0 162.0 135.0 154.0 127.0 278.0 348.0 477.0 298.0 193.0 389.0 209.0 332.0 274.0

3390 1840 0 2060 6650 4240 4200

70.0 360.0 0.0 65.0 400.0 0.0 110.0 0.0 0.0 0.0 60.0 420.0 0.0 10.0 70.0 0.0 10.0 0.0 100.0 90.0 100.0 0.0 90.0

0.005 0.013 0.058 0.015 0.099 0.075 0.130 0.000 0.042 0.060 0.057 0.016 0.052 0.016 0.386 0.000 0.443 0.054 0.015 0.069 0.182 0.031 0.183

5.0 0.0 0.0 0.0 0.0 5.0 3.0 0.0 18.0 0.0 4.0 1.0 9.0 33.0 0.0 0.0 2.0 163.0 0.0 0.0 6.0 1.0 0.0

7.0 9.0 4.0 73.0 1.0 0.0 0.0 0.0 273.0 8.0 12.0 5.0 20.0 8.0 49.0 16.0 0.0 69.0 52.0 4.0 3.0 5.0 0.0

0.0 13.0 0.0 17.0 8.0 5.0 5.0 0.0 1.0 4.0 10.0 0.0 8.0 2.0 8.0 10.0 2.0 2.0 2.0 10.0 7.0 2.0 6.0

0.100 0.260 0.155 0.100 1.530 0.450 0.000 0.000 1.250 0.695 0.063 0.020 1.280 0.070 0.080 0.800 0.630 0.000 0.000 0.000 0.130 0.900 1.250

0.152 0.030 0.000 0.000 0.030 0.110 0.150 0.000 0.120 0.070 0.530 0.060 0.090 0.110 0.050 0.000 0.000 0.000 0.250 0.030 0.080 0.190 0.080

0.000 0.035 0.265 0.200 0.450 0.455 0.100 0.000 0.472 0.030 0.282 0.000 0.000 0.130 0.300 0.105 0.163 0.110 0.060 0.243 0.000 0.175 0.183

0.0 0.0 0.0 84.0 115.0 115.0 0.0 0.0 98.0 24.0 0.0 0.0 0.0 3.0 5.0 8.0 0.0 2.0 0.0 3.0 25.0 1.0 0.0
21.0

EAST SALT CREEK ABOVE CANAL (I) averages

4.2

221.1

599.1

112.0

2163.1

EAST SALT CREEK AT 6&50 (I) EAST SALT CREEK AT 6&50 (I) EAST SALT CREEK AT 6&50 (I) EAST SALT CREEK AT 6&50 (I) EAST SALT CREEK AT 6&50 (I) EAST SALT CREEK AT 6&50 (I) EAST SALT CREEK AT 6&50 (I)
1.43 232.4 2194 147.6 0.047

8/24/1981 6/29/1982 9/3/1982 5/5/1983 8/24/1983 9/23/1983 3/9/1984

13.90 8.60 15.50 63.90 21.40 14.00 12.00

130.00 136.00 126.00 84.10 115.00 162.00 181.00

290.00 279.00 225.00 194.00 215.00 192.00 530.00

220.00 116.00 153.00 22.00 107.00 160.00 74.00

1300.0 1250.0 1125.0 750.0 900.0 1275.0 1650.0

0.00 0.00 0.00 10.00 0.00 0.00 0.00

200.0 155.0 216.0 277.0 235.0 221.0 323.0

2370 1900 2518 1282 2204 2948 2136

40.0 0.0 770.0 50.0 0.0 0.0 173.0

0.040 0.038 0.210 0.002 0.038 0.001 0.000

0.0 2.0 0.0 0.0 0.0 1.0 4.0
1.0

0.0 5.0 9.0 3.0 6.0 9.0 7.0
5.6

0.0 0.0 6.0 15.0 14.0 11.0 15.0
8.7

0.000 0.080 0.190 10.600 0.780 0.000 0.125
1.682

0.020 0.000 0.030 0.040 0.000 0.010 0.060
0.023

0.000 0.280 0.420 0.140 0.180 0.257 0.205
0.212

0.0 0.0 0.0 0.0 0.0 0.0 20.0
2.9

EAST SALT CREEK AT 6&50 (I) averages

21.33

133.4

275.0

121.7

1178.6

SALT CREEK AT I-70 (H) SALT CREEK AT I-70 (H) SALT CREEK AT I-70 (H) SALT CREEK AT I-70 (H) SALT CREEK AT I-70 (H) 0.00 4.04 0.00 0.00
1.01 163.0 1226

averages averages averages averages averages

8/24/1981 6/29/1982 5/5/1983 8/2/1993 9/28/1993

127.00 112.50 185.50 98.90 150.00

67.00 48.10 48.20 73.00 66.00

170.00 91.10 135.00 92.50 125.00

180.00 68.00 100.00 87.00 140.00

690.0 508.0 425.0 696.0 613.0

180.0 155.0 135.0 172.0 173.0

1430 930 1048 1370 1350

10.0 0.0 50.0 0.0 340.0
80.0

0.011 0.049 0.007 0.008 0.029
0.021

4.0 0.0 7.0 0.0
2.8

49.0 13.0 5.0 12.0
19.8

0.0 26.0 2.0 5.0
8.3

0.130 1.000 0.000 0.000
0.283

1.000 0.000 0.005 0.000 0.000
0.201

0.150 0.070 0.040
0.087

2.0 0.0
1.0

SALT CREEK AT I-70 (H) averages

134.78

60.46

122.72

115.00

586.4

Page 3 of 4

BLM Water Quality Data

NAME
MANGANESE
MOLYBDENUM

DATE
PHOSPHATE ALUMINUM

Q mg/l mg/l mg/l μg/l mg/l μg/l μg/l μg/l mg/l mg/l mg/l μg/l

MAGNESIUM

SODIUM

CHLORIDE

SULFATE

PHEN_ALK

TOT_ALK

DIS_SOLID

IRON

COPPER

ZINC

AMMONIA

BORON

cfs

mg/l

mg/l

mg/l

mg/l

322.00 737.00 426.00 647.00 576.00 575.00 1050.00 1100.00 0.0 20.0 24.0 0.0 0.0 0.00 111.0 1620 30.0 0.026 14.0 17.0 0.0 2.120 0.000 0.000

843.00 2840.00 1760.00 1790.00 1470.00 1600.00 2920.00 3240.00

46.00 168.00 76.00 108.00 224.00 112.00 162.00 285.00

3650.0 9940.0 6350.0 6500.0 5000.0 2560.0 10500.0 11800.0

0.00 32.00 0.00 10.00 0.00 0.00 0.00 0.00

246.0 339.0 279.0 241.0 297.0 292.0 336.0 267.0

4920 11200 8030 9920 6300 6820 15000 14500

30.0 350.0 30.0 30.0 0.0 0.0 40.0 0.0

0.026 0.071 0.308 0.357 0.039 0.246 0.617 0.006

0.0 0.0 4.0 2.0 4.0 14.0 0.0 33.0

9.0 4.0 4.0 4.0 9.0 9.0 9.0 16.0

9.0 0.0 3.0 0.0 5.0 1.0 3.0 1.0

0.039 7.250 1.650 0.000 0.940 1.000 0.450 0.027

0.000 0.040 0.120 0.160 0.075 0.050 0.620 0.290

0.131 0.295 0.245 0.210 0.127 0.700 0.330 0.628

42.0 15.0 10.5

WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') WEST SALT CREEK AT GAGE (J') 0.00 0.00 0.00 29.50 28.70 0.00
5.25 287.1 9586 60.0 0.209 7.1 8.0 2.8 1.420 0.169 0.333 15.9

6/4/1986 9/9/1986 7/8/1987 9/1/1987 6/14/1988 9/1/1988 5/23/1989 8/30/1989 6/21/1990 9/17/1990 6/25/1991 9/5/1991 5/22/1992 9/4/1992 7/28/1993 9/28/1993 7/17/1995 9/11/1995 311.0 373.0 371.0 414.0 324.0 283.0 3620 10800 9940 14900 10900 6340 0.0 0.0 10.0 250.0 0.0 80.0 0.059 0.012 0.043 0.207 0.080 0.030 0.0 2.0 0.0 0.0 0.0 0.0 41.0 38.0 16.0 3.0 49.0 188.0 1.0 1.0 0.0 1.0 3.0 3.0 0.480 2.800 0.000 0.830 0.000 4.250 0.010 0.000 0.000 0.010 0.010 0.180 0.280 0.313 0.286 0.300 0.217 0.148 20.0 0.0 0.0 0.0 5.0 0.0

6.60 0.36 1.04 0.58 0.43 0.33 0.01 0.03 0.00 0.41 0.00 0.00 0.02 0.05 0.14 0.09 0.79 0.27

50.00

265.00

31.00

1160.0

417.00 286.00 1070.00 1180.00 579.00 325.00

102.00 2660.00 892.00 2580.00 1800.00 1520.00

102.00 85.00 92.00 134.00 146.00 80.00

2330.0 7030.0 7000.0 10000.0 6000.0 5090.0

WEST SALT CREEK AT GAGE (J') averages

0.62

679.1

2057.9

147.6

7037.5

0.0

WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) WEST SALT CREEK NR 8 ROAD (J) 0.00 0.00 40.40 60.30 0.00 0.00 0.00 0.00 0.00 10.0 11.0
11.19 195.8 3257 52.6 0.079 5.0 14.9 9.7 0.569 0.096 0.167 7.0

8/25/1981 6/29/1982 9/3/1982 5/5/1983 8/24/1983 9/23/1983 3/9/1984 8/15/1984 6/14/1985 9/10/1985 2.0 4.0 0.0 0.0 1.0 5.0 28.0 5.0 0.0 12.0 21.0 12.0 1.0 15.0 7.0 21.0 29.0 16.0 3.0 2.0 21.0 13.0 13.0 23.0 0.0 9.0 3.0 0.090 0.180 1.410 0.460 0.020 0.040 2.160 0.700 0.060 0.120 0.170 0.155 0.155 0.178 0.315 0.000 0.250 0.162

24.60 16.60 40.70 40.70 32.40 33.70 2.09 1.80 2.40 0.79

57.00 51.20 37.70 62.00 50.30 67.97 405.00 187.00 460.00 639.00

170.00 82.20 117.00 194.00 100.00 117.00 982.00 554.00 380.00 1640.00

190.00 64.00 126.00 173.00 100.00 162.00 233.00 42.00 67.60 6.80

620.0 608.0 325.0 456.0 375.0 496.0 4000.0 2800.0 3090.0 7000.0

180.0 159.0 154.0 172.0 190.0 128.0 262.0 156.0 265.0 292.0

1350 1200 988 1102 1088 1432 6500 4300 4210 10400

10.0 0.0 2.5 50.0 0.0 0.0 245.0 0.0 190.0 28.0

0.013 0.061 0.230 0.009 0.013 0.003 0.135 0.294 0.033 0.001

0.010 0.000 0.015 0.050 0.000 0.045 0.000 0.810 0.030 0.000

WEST SALT CREEK NR 8 ROAD (J) averages

19.58

201.7

433.6

116.4

1977.0

Page 4 of 4

USGS Surface Water Analytical Data

USGS Station Salt Ck nr Mack Station Number 9163490 Specific conductance mS/cm at 25ºC Suspended sediment concentration mg/L

Date 4/4/1973 4/12/1973 4/20/1973 5/2/1973 6/5/1973 7/6/1973 8/3/1973 8/8/1973 11/28/1973 2/20/1974 3/8/1974 5/29/1974 8/13/1974 12/10/1974 3/5/1975 5/22/1975 8/5/1975 11/4/1975 12/15/1975 1/14/1976 2/6/1976 3/9/1976 4/6/1976 5/4/1976 6/8/1976 7/2/1976 8/6/1976 9/7/1976 10/6/1976 11/30/1976 12/16/1976 1/18/1977 2/2/1977 3/8/1977 4/8/1977 7/8/1977 10/19/1977 2/14/1978 4/5/1978 7/11/1978 11/14/1978 3/13/1979 5/9/1979 7/23/1979 11/7/1979 1/29/1980 4/23/1980 7/17/1980 10/7/1980 2/18/1981 5/14/1981 7/23/1981 12/3/1981 3/24/1982 6/15/1982 10/14/1982 1/6/1983 5/3/1983 8/10/1983 9/7/1983 3/20/1991 6/25/1991 8/27/1991 2/4/1992 3/24/1992 4/27/1992 6/8/1992 7/15/1992 8/10/1992 12/15/1994 1/20/1995 2/13/1995 3/13/1995 4/24/1995

Temperature Discharge ºC cfs 11 15 8 10 16.5 20 23 17.5 1 0 3 16 18.5 0 3.5 13 22.5 10.5 0 0 3 11.5 14 16.5 20.5 23 21.5 20 12.5 0.5 0.5 0.5 3 7 16 22 11.5 5 8.5 17 8 1 8 18.5 7 1 14 18 12 2 13.5 22 2.5 10 21 10 0 12 20.5 19.5 5 14.5 19 0 13 13.5 17 18.5 21 0 0 3.9 10.6 14

pH

Turbidity severity code

Fluoride Selenium Bicarbonate mg/l μg/L mg/L

Hardness mg/L as CaCO3

Sodium Sulfate mg/L mg/L

122 18 10 21 109 148 16

16

67

9.9

91

8 7.7 8.1 7.9 7.8 8.2 7.9 8 8.3 8.3 8.1 7.8 8.1 7.8 7.8 8.1 8 7.6 7.7 8.1 7.8 8

5410 1630 2970 5090 4700 1710 1490 4870 1870 2780 1830 4970 1670 4540 1330 1020 1280 4750 4760 4930 3610 1350

0.5 0.4 0.5 0.4 0.3 0.3 0.2 0.3 0.3 0.3 0.3 0.3 0.4 0.3 0.4 0.3 0.3 0.2 0.4 0.3 0.3 0.3 0.2 0.3 0.3 0.2 0.2 0.3 0.3 0.3 0.3 0.2 0.3 0.3 0.2 0.3 0.3 0.3 0.3 0.3 0.4 0.3 0.3 0.2 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.4 0.3 0.4

820 2300 2200 1400 650 730 1700 1900 450 760 2200 2300 2300 1800 2000 2300 640 570 850 810 790 650 2200 2300 2300 2200 2300 610 730 580 2500 1700 800 2100 870 560 740 2100 2000 400 610 850 2100 550 820 2500 2200 610 510 2400 630 850 590 2200 620 2100

140 420 480 350 110 130 410 460 100 130 380 420 450 400 530 550 170 100 130 140 170 160 400 440 420 430 450 220 180 170 440 400 140 420 230 160 120 420 460 130 120 190 630 150 160 480 550 110 130 490 160 160 120 500 130 420

780 2500 2600 1800 610 660 2900 2300 390 720 2400 2600 2700 2100 2500 2900 640 500 810 660 670 550 2400 2500 2500 2500 2500 560 640 510 2700 1900 730 2300 1100 580 700 2200 2400 380 570 740 2800 470 710 2900 2800 620 450 2800 650 1200 700 3300 570 2400

0.3 0.3 0.3 0.3 0.3

2200 2200 2000 1300 370

470 460 540 410 130

2500 2600 2500 1700 280

Page 1 of 6

USGS Station Salt Ck nr Mack Station Number 9163490 Specific conductance mS/cm at 25ºC 1130 1280 884 1070 1390 1630 4170 4670 4960 4790 4870 1090 1240 1050 1190 1580 1260 1390 4260 4110 3940 1430 1180 1160 1040 Suspended sediment concentration mg/L

Date 5/25/1995 6/27/1995 7/24/1995 8/22/1995 9/27/1995 10/24/1995 11/20/1995 12/15/1995 1/16/1996 2/12/1996 3/11/1996 4/9/1996 5/14/1996 6/27/1996 7/24/1996 8/26/1996 9/19/1996 10/18/1996 11/13/1996 1/6/1997 3/10/1997 5/13/1997 7/9/1997 8/13/1997 5/13/1998

Temperature Discharge ºC cfs 12.4 15.1 16.8 19.8 12.3 6.3 6.3 3.8 0 0.9 3.8 9.4 13.7 15.8 17.9 18.8 15.8 9.3 3.3 0 5.7 16 17 17 14.5

pH 8 7.7 7.7 7.8 8 8.1 7.4 7.7 7.4 7.7 7.7 8 8 7.9 7.9 7.9 8.1 8 7.7 7.7 7.7 8 8 8.1 8.2

Turbidity severity code

Fluoride Selenium Bicarbonate mg/l μg/L mg/L 0.3 0.2 0.2 0.3 0.2 0.3 0.2 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.28 0.24 0.26 0.3

Hardness mg/L as CaCO3 380 490 340 380 460 540 1800 2100 2300 2100 1900 340 430 450 470 560 400 410 2100 1900 1400 500 480 410 380

Sodium Sulfate mg/L mg/L 98 99 59 76 120 140 380 480 530 530 560 100 110 64 81 130 110 120 380 350 470 120 66.6 87.1 89.3 300 480 280 300 360 470 2100 2500 2700 2400 2600 290 420 350 370 470 310 330 2200 2100 2100 480 411 337 299

7 9

12

26

11 220

2

3790

Page 2 of 6

USGS Station East Salt Ck near Mack Station Number 9163310 Specific conductance mS/cm at 25ºC Suspended sediment concentration mg/L

Date 7/2/1973 7/19/1973 7/24/1973 8/8/1973 8/8/1973 9/11/1973 9/27/1973 11/27/1973 2/20/1974 3/8/1974 5/29/1974 8/13/1974 12/10/1974 3/4/1975 5/22/1975 8/5/1975 11/4/1975 12/15/1975 1/13/1976 2/6/1976 3/9/1976 4/6/1976 5/4/1976 6/8/1976 7/2/1976 8/6/1976 9/7/1976 10/4/1976 11/30/1976 12/16/1976 1/18/1977 2/2/1977 3/8/1977 4/8/1977 7/8/1977 10/19/1977 2/14/1978 4/1/1978 7/14/1978 11/15/1978 3/13/1979 5/9/1979 7/23/1979 11/6/1979 1/29/1980 4/22/1980 7/16/1980 10/7/1980 2/18/1981 5/12/1981 7/23/1981 12/3/1981 3/24/1982 6/15/1982 5/2/1991 2/4/1992

Temperature Discharge ºC cfs 28 17 18 23 23 18 12 5 2 6.5 14 14.5 3 4.5 9.5 23 12 2 3 1.5 12.5 11.5 16 24 23.5 20.5 20 17 4.5 1 1.5 5 8 19.5 19 8 4.5 12 16.5 6 1 9 21 11 4 12 16.5 12 4.5 14 19.5 2.5 1 15 11 0

pH

Turbidity severity code

Fluoride Selenium Bicarbonate μg/L mg/l mg/L

Hardness mg/L as CaCO3

Sodium Sulfate mg/L mg/L

0.18

0.5

521

2200

660

2700

0.3 0.15 2.6 1.7 0.55

8.3 8.1 8.1 7.9 8.4 7.9 8.1 7.8

7320 9150 3180 7640 5200 3220 7050 6860

0.4 0.6 0.5 0.5 0.4 0.3 0.2 0.4 0.4 0.3 0.4 0.4 0.4 0.5 0.5 0.4 0.3 0.6 0.4 0.4 0.3 0.3 0.4 0.4 0.3 0.3 0.4 0.4 0.4 0.4 0.4 0.3 0.3 0.3 0.3 0.3 0.4 0.4 0.4 0.6 0.4 0.4 0.4 0.3 0.4 0.4 0.3 0.5 0.6

472 605 355 297 530 523 256 309 414 565 593 599 255 469 595 440 447 369 404 425 488 568 580 573 585 587 520 430 430 460 220 230 530

8 21

2200 2400 730 820 1900 1800 560 340 1300 2100 2400 2300 610 850 2000 830 850 990 1300 1500 1900 2200 2300 2300 2400 2500 2200 1700 2100 2500 630 640 2000 680 240 1900 2300 2100 450 1200 1600 2100 2400 1100 2700 1600 1000 2000 2300

850 990 360 120 600 650 270 94 290 640 770 900 330 490 1100 430 450 240 320 380 510 720 800 870 910 960 880 360 570 740 210 180 630 330 160 590 830 810 160 640 660 1200 1600 380 1400 800 450 1200 1000

3300 3700 1300 920 2400 2500 780 250 1400 2500 3100 3400 1000 1400 3400 1200 1300 980 1300 1600 2200 3000 3100 3400 3100 3500 3300 1700 2300 3200 810 670 2700 970 310 2600 3200 2900 540 2000 2200 3600 4500 1300 4700 2600 1500 3900 3600

Page 3 of 6

USGS Station Big Salt Wash at Fruita Station Number 9153270 Specific conductance mS/cm at 25ºC Suspended sediment concentration mg/L

Date 3/7/1973 4/11/1973 5/2/1973 6/4/1973 6/19/1973 6/20/1973 8/2/1973 8/7/1973 11/27/1973 2/19/1974 3/8/1974 5/28/1974 8/12/1974 12/10/1974 3/4/1975 5/22/1975 8/5/1975 11/4/1975 12/15/1975 1/13/1976 2/5/1976 3/9/1976 4/6/1976 5/3/1976 6/8/1976 7/1/1976 8/4/1976 9/3/1976 10/4/1976 11/30/1976 12/15/1976 1/18/1977 2/2/1977 3/8/1977 4/8/1977 7/6/1977 3/20/1991 6/25/1991 8/27/1991 2/5/1992 4/27/1992 6/8/1992 11/20/1995 12/15/1995 2/12/1996 3/11/1996 4/9/1996 5/13/1996 6/27/1996 7/24/1996 8/26/1996 9/6/1996 9/6/1996 9/19/1996 10/18/1996 11/11/1996 12/3/1996 1/6/1997 3/10/1997 4/15/1997 5/13/1997 6/16/1997 7/9/1997 8/13/1997 5/13/1998 11/19/1998 12/17/1998 1/20/1999 3/8/1999

Temperature Discharge ºC cfs 6 12 11.5 9 10 9 7 21 7 4.5 10 17.5 19 1.5 5.5 10 16.5 8.5 2 5 7 5 5 17 14.5 22.5 22 20 12.5 3 6 1.5 5 4 9 18.5 7.5 15 20.5 1.5 15 18 6.6 5.2 7 7.7 11.8 15.3 15.5 18.4 18.3 18.2 18.2 11.7 8.3 5.7 4.1 5 3 7.5 11.5 14 17 18.5 11 7 4.5 6 8

pH

Turbidity severity code

Fluoride Selenium Bicarbonate μg/L mg/l mg/L

Hardness mg/L as CaCO3

Sodium Sulfate mg/L mg/L

106 18 9.5 16 94 92

17

7.7 8 7.8 7.9 8 7.2 7.5 7.6 7.6 7.9 7.9 7.8 7.8 7.8 7.7 7.7 7.9 7.9 7.8 7.5 7.5 7.6 8.1 7.8 7.8 7.9 8 8 7.6 7.7 7.6 7.6

3350 1870 3390 1330 1560 3300 3050 3300 3360 931 1290 1290 1780 1850 1680 1690 1720 1810 2380 3300 3350 2400 1300 1070 1040 1490 1250 1060 3190 3170 3180 3150

0.3 0.3 0.5 0.5 0.5 0.3 0.3 0.3 0.3 0.4 0.3 0.3 0.3 0.4 0.4 0.4 0.3 0.3 0.4 0.4 0.4 0.3 0.3 0.3 0.3 0.4 0.5 0.4 0.3 0.3 0.3 0.3

660 1800 1600 1400 550 750 1700 1100 410 780 1800 1600 1700 1600 800 920 630 590 800 870 910 630 1700 1600 1700 1700 1600 520 820 1500 730 1500

130 280 270 260 78 140 260 220 70 130 250 250 260 250 200 250 120 83 110 150 170 140 240 250 250 250 260 180 180 290 130 270

640 1800 1500 1400 450 670 1600 1000 330 690 1600 1600 1700 1500 850 1000 540 490 720 680 760 490 1500 1600 1600 1500 1500 420 730 1500 660 1500

2

0.2 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.29 0.22 0.2 0.27 0.28 0.3 0.23 0.24 0.27 0.27

20 12 13

12 7

12 228

1600 1500 1600 1600 310 530 590 780 720 610 610 680 660 1100 1700 1600 800 400 420 490 640 490 420 1500 1700 1500 1600

220 220 270 270 73 77 71 110 140 130 130 130 130 180 230 260 250 122 61.7 59.4 82.7 84.2 71.2 211 232 227 230

1500 1200 1400 1500 240 450 450 640 610 500 520 550 550 890 1500 1500 960 324 330 361 529 385 317 1440 1420 1430 1420

1570

Page 4 of 6

USGS Station Mack Wash near Mack Station Number 9163340 Specific conductance mS/cm at 25ºC Suspended sediment concentration mg/L

Date 7/27/1973 8/8/1973 9/14/1973 10/10/1973 11/27/1973 11/28/1973 1/8/1974 1/22/1974 2/20/1974 2/20/1974 3/6/1974 3/21/1974 4/11/1974 4/23/1974 5/14/1974 5/28/1974 6/11/1974 6/25/1974 7/16/1974 8/12/1974 8/15/1974 9/9/1974 12/10/1974 3/4/1975 5/22/1975 8/5/1975 11/4/1975 12/15/1975 1/13/1976 2/5/1976 3/9/1976 4/6/1976 5/4/1976 6/8/1976 7/2/1976 8/6/1976 9/7/1976 10/4/1976 11/30/1976 12/16/1976 1/18/1977 2/2/1977 3/8/1977 4/8/1977 7/8/1977 10/18/1977 2/14/1978 4/3/1978 7/14/1978 11/15/1978 3/13/1979 5/10/1979 7/23/1979 11/6/1979 1/29/1980 4/22/1980 7/16/1980 10/7/1980 2/18/1981 5/12/1981 7/23/1981 12/3/1981 3/24/1982 6/15/1982

Temperature Discharge ºC cfs 21 19 19 12 10 10.5 3 9 7 8 11 12.5 9.5 13 13 18.5 17 12 17 21.5 21 24.5 7.5 11 14 21 11.5 8.5 9 10.5 13.5 9.5 11 20 17.5 22 22 16 10 8 9 9.5 10 11.5 22 14 9.5 13.5 14 12 15 13 18 11 9 15 22 16.5 9 16 22 8 8.5 20.5

pH

Turbidity severity code

Fluoride Selenium Bicarbonate μg/L mg/l mg/L

Hardness mg/L as CaCO3 1600

Sodium Sulfate mg/L mg/L

7.8

0.7

227

200

1700

2.4

0.3

262

1900

240

1900

2.2

0.5

250

1900

230

1900

32

0.3

163

440

110

380

33

0.3

135

440

100

410

0.2 0.3 0.3 0.3 0.2 0.3 0.3 0.4 0.3 0.3 0.3 0.2 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.2 0.3 0.3 0.4 0.3 0.2 0.3 0.3 0.3 0.2 0.3 0.3 0.3 0.3 0.4 0.3 0.3 0.2 0.2 0.3 0.3 0.3

271 253 168 161 272 269 259 253 248 252 245 145 227 157 152 165 268 265 258 262 250 180 160 170 260 260 270 280

7.8 7.6 7.9 8.1 7.7 7.8 7.6

2570 3650 1380 1600 3960 3400 1700

2000 1900 370 630 1900 1900 1900 1900 1800 1900 1800 310 1400 530 470 360 1900 1900 1900 1900 1900 440 440 330 2000 1900 1800 1900 1800 290 1900 1900 1900 350 360 1300 1900 620 580 1900 1900 690

230 230 100 100 240 210 230 220 210 220 220 72 180 99 110 120 220 220 220 210 210 170 150 150 240 230 240 240 240 83 53 230 220 120 73 280 250 300 130 240 240 110

2000 1900 260 600 1800 1900 1900 1900 1800 1900 1900 230 1400 450 390 270 2000 1900 1900 1800 1800 370 360 240 1900 1900 1800 1900 1800 200 1400 1900 1900 250 300 1200 1900 340 500 2100 1900 610

Page 5 of 6

USGS Station West Salt Ck nr Mack Station Number 9153400 Specific conductance mS/cm at 25ºC Suspended sediment concentration mg/L

Date 9/12/1973 9/26/1973 9/12/1976 10/3/1976 9/11/1977 10/7/1977 3/3/1978 4/1/1978 1/22/1979 3/13/1979 4/11/1979 2/19/1980 4/21/1980 8/25/1980 7/17/1981 7/17/1981 8/12/1981 8/13/1981 8/14/1981 9/14/1981 10/5/1981 2/24/1983 2/28/1983 3/14/1983 3/15/1983 4/13/1983 5/3/1983 5/17/1983 5/24/1983 6/7/1983 6/13/1983 7/6/1983 7/26/1983 8/9/1983 9/7/1983 12/4/1995 3/13/1997

Temperature Discharge ºC cfs 29 10 13.5 16 0.97 0.06

pH

Turbidity severity code

Fluoride Selenium Bicarbonate μg/L mg/l mg/L 0.5 0.9 0.3 0.3 0.2 0.4 0.6 0.4 0.1 0.2 0.5 0.5 0.5 0.4 0.4 0.4 0.4 0.2 0.4 0.3 142 90 180 45 220 97 220

Hardness mg/L as CaCO3 670 2600 510 320 890 590 1300 480 540 650 1800 2500 740 2400 1300 5100 2600 1000 5100 950

Sodium Sulfate mg/L mg/L 310 510 190 97 27 86 200 300 40 120 890 530 340 360 72 2000 1100 290 1600 120 1200 3500 490 380 900 590 1500 890 490 780 3400 3500 4300 3000 1100 6900 4500 1400 8200 1100

4 11 2 9 10 7 25 24 7.2 7.1 26.5 25 25.5 12 13.5 6.5 10 9 10 9 8 26 15 12 32 21 33 17.1 2.8 2.5 7.3 8.4 7.2 2070 9910 7070 11200 1980

130000 318000

8 7.7

11700 1820

0.2 0.1

3

4200 500

2000 210

7400 810

6980

Page 6 of 6

Red Cliff Mine Surface Water Analytical Data

Bowie Resources, LLC Bowie No. 2 Mine 2006 Annual Hydrology Report
Red Cliff Mine Surface Water SW-1 Easting Northing 1063946 572835

Ground Water TC-03-01 East (R) Terror Creek - Monitoring Well Elevation - 7118' Depth - 871'

Field Parameters Static Water Level Water Elevation FieldComment ph Conductivity Temperature Lab Parameters pH Conductivity Total Dissolved Solids Total Suspended Solids Total Alkalinity Bicarbonate Carbonate Hydroxide Sulfate Calcium Magnesium SAR in water Ammonia Hardness Chloride Sodium Potassium Aluminum Nitrate Nitrite Nitrate-Nitrite Phosphate Arsenic - Dissolved Boron Copper Cadmium - Dissolved Iron - Dissolved Iron - Total Recoverable Lead Manganese (Dissolved) Manganese (Total) Mercury - Dissolved Selenium - Dissolved Zinc - Dissolved

UNITS Feet Feet su umhos/cm Celsius UNITS mg/L mg/L mg/L mg/L umhos/cm mg/L mg/L mg/L su mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L

Date Summary Information Baseline Operation Min Ave Max Min Ave 0 --0 0.0 --0.0 0 --0 --0 --0 0 0

6/30/2007

4/30/2007

8/30/2006

10/24/2006

Max

7.89 1780.2 =1.0

Canyonlands National Park

Arches National Park

Maroon – Bells Snowmass Wilderness

Dinosaur National Monument

Flat Tops Wilderness

Modeling Period→ ↓Year/SIL→ 86 87 88 89 90 86 87 88 89 90 86 87 88 89 90 86 87 88 89 90 86 87 88 89 90

H-27

Appendix H Air Quality Analysis Modeling Report

Table 4-5 MAXIMUM CALPUFF-LITE PREDICTED IMPACTS FROM PHASE 1 (RAILROAD CONSTRUCTION)
Deposition N2 kg/ha/yr 0.005
0.00628 0.00694 0.00866 0.00876 0.00670 0.00000 0.00000 0 0 1 0.00000 0.00000 0.00000

Pollutant→ 3-hour μg/m3 1
0.00332 0.00390 0.00359 0.00347 0.00339 0.00153 0.00217 0.00166 0.00181 0.00171 0.00025 0.00001 0.74300 0.02810 0.00022 0.00028 0.00001 0.00001 0.75800 0.67500 0.02110 0.02340 0.00037 0.00001 0.91200 0.02560 0 0.00025 0.00001 1.00000 0.02130 1 0.00070 0.00004 1.53000 0.10700 6 0.00080 0.00005 2.64000 0.14600 16 0.00069 0.00005 2.39000 0.14600 20 0.00069 0.00004 2.39000 0.10500 7 0.00062 0.00003 1.97000 0.09490 3

Deposition S3 kg/ha/yr 0.005
0.00001 0.00001 0.00001 0.00001 0.00001 0.00000 0.00000 0.00000 0.00000 0.00000

Class I & Class II Areas↓
0.03430 0.03980 0.05260 0.05030 0.03640 0.00223 0.00246 0.00209 0.00281 0.00283

NOx Annual μg/m3 0.1 Annual μg/m3 0.08

SOx 24-hour μg/m3 0.2

PM10 24-hour Annual μg/m3 μg/m3 0.32 0.16

Visibility1 Deciview Change Days >=1.0

Colorado National Monument

Black Canyon of the Gunnison Wilderness

Modeling Period→ ↓Year/SIL→ 86 87 88 89 90 86 87 88 89 90

1

Number of days with deciview change >1.0. 2 Nitrogen deposition (N) 3 Sulfur deposition (S) µg/m = micrograms per meter kg/ha/yr = kilogram per hectare per year NOx = nitrogen oxides PM10 = particulate matter with an aerodynamic diameter less than 10 micrometers SIL = significant impact levels = sulfur oxides SOx

H-28

Appendix H Air Quality Analysis Modeling Report
Table 4-6 MAXIMUM CALPUFF-LITE PREDICTED IMPACTS FROM PHASE 2 (MINE AREA, TRANSMISSION LINE, AND ROAD CONSTRUCTION)
NOx Annual μg/m3 3-hour μg/m3 24-hour μg/m3 Annual μg/m3 24-hour μg/m3 Annual μg/m3 Deciview Change SOx PM10 Visibility1 Deposition N2 kg/ha/yr Deposition S3 kg/ha/yr

Pollutant→

Class I & Class II Areas↓

Modeling Period→

Canyonlands National Park

Arches National Park

Maroon – Bells Snowmass Wilderness

Dinosaur National Monument

Flat Tops Wilderness

↓Year/SIL→ 86 87 88 89 90 86 87 88 89 90 86 87 88 89 90 86 87 88 89 90 86 87 88 89 90

0.1 0.00039 0.00035 0.00033 0.00040 0.00054 0.00072 0.00061 0.00064 0.00066 0.00098 0.00100 0.00089 0.00086 0.00117 0.00096 0.00119 0.00123 0.00126 0.00149 0.00135 0.00122 0.00123 0.00125 0.00148 0.00137

1 0.00031 0.00031 0.00047 0.00025 0.00027 0.00055 0.00034 0.00031 0.00065 0.00030 0.00201 0.00187 0.00225 0.00167 0.00181 0.00170 0.00193 0.00230 0.00178 0.00170 0.00183 0.00199 0.00255 0.00196 0.00177

0.2 0.00005 0.00006 0.00007 0.00004 0.00005 0.00008 0.00005 0.00006 0.00012 0.00007 0.00031 0.00030 0.00031 0.00023 0.00026 0.00028 0.00027 0.00030 0.00024 0.00024 0.0003 0.00028 0.00033 0.00025 0.00023

0.08 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001

0.32 0.36657 0.33262 0.40435 0.52048 0.55103 0.35640 0.28351 0.39629 0.80472 0.75804 1.10210 1.08590 0.98654 0.76340 0.91212 1.06900 0.90548 1.02960 0.77674 0.79433 1.17490 1.00660 1.18150 0.84322 0.82726

0.16 0.01498 0.01545 0.01517 0.01475 0.01954 0.01502 0.01575 0.01811 0.01584 0.02247 0.03164 0.03155 0.02846 0.03164 0.03471 0.03211 0.03711 0.0345 0.03479 0.03766 0.03354 0.03866 0.03522 0.03580 0.03817

Days >=1.0 0 0 0 0 0 0 0 0 0 0 1 1 1 0 2 3 1 2 0 2 2 2 2 3 2

0.005 0.00034 0.00043 0.00039 0.00032 0.00040 0.00045 0.00055 0.00040 0.00045 0.00040 0.00118 0.00155 0.00137 0.00134 0.00130 0.00132 0.00186 0.00159 0.00142 0.00137 0.00117 0.00175 0.00151 0.00137 0.00127

0.005 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001

H-29

Appendix H Air Quality Analysis Modeling Report
Table 4-6 MAXIMUM CALPUFF-LITE PREDICTED IMPACTS FROM PHASE 2 (MINE AREA, TRANSMISSION LINE, AND ROAD CONSTRUCTION)
NOx Annual μg/m3 3-hour μg/m3 24-hour μg/m3 Annual μg/m3 24-hour μg/m3 Annual μg/m3 Deciview Change SOx PM10 Visibility1 Deposition N2 kg/ha/yr Deposition S3 kg/ha/yr

Pollutant→

Class I & Class II Areas↓

Modeling Period→

Colorado National Monument

Black Canyon of the Gunnison Wilderness

↓Year/SIL→ 86 87 88 89 90 86 87 88 89 90

0.1 0.01149 0.01160 0.01090 0.01281 0.01008 0.00125 0.00129 0.00137 0.00165 0.00148

1 0.01062 0.00542 0.00760 0.00801 0.00794 0.00198 0.00181 0.00229 0.00173 0.00177

0.2 0.00133 0.00068 0.00095 0.00100 0.00102 0.00030 0.00029 0.00030 0.00025 0.00026

0.08 0.00003 0.00002 0.00003 0.00003 0.00003 0.00001 0.00001 0.00001 0.00001 0.00001

0.32 3.00000 1.76320 1.63920 2.41570 2.33550 1.12130 1.08850 1.04900 0.82995 0.89975

0.16 0.08551 0.08955 0.09963 0.09787 0.09230 0.03423 0.04014 0.03797 0.03864 0.04111

Days >=1.0 4 1 2 3 4 4 2 2 1 3

0.005 0.00562 0.00459 0.00499 0.00440 0.00524 0.00130 0.00184 0.00163 0.00150 0.00138

0.005 0.00002 0.00002 0.00002 0.00001 0.00002 0.00001 0.00001 0.00001 0.00001 0.00001

1

2

Number of days with deciview change >1.0. Nitrogen deposition (N) 3 Sulfur deposition (S) µg/m = micrograms per meter kg/ha/yr = kilogram per hectare per year NOx = nitrogen oxides PM10 = particulate matter with an aerodynamic diameter less than 10 micrometers SIL = significant impact levels SOx = sulfur oxides

H-30

Appendix H Air Quality Analysis Modeling Report

Table 4-7 MAXIMUM CALPUFF-LITE PREDICTED IMPACTS FROM PHASE 3 (PRODUCTION)
NOx Annual μg/m3 3-hour μg/m3 24-hour μg/m3 Annual μg/m3 24-hour μg/m3 Annual μg/m3 Deciview Change SOx PM10 Visibility1 Deposition N2 kg/ha/yr Deposition S3 kg/ha/yr

Pollutant→

Class I & Class II Areas↓

Modeling Period→

Canyonlands National Park

Arches National Park

Maroon – Bells Snowmass Wilderness

Dinosaur National Monument

Flat Tops Wilderness

↓Year/SIL→ 86 87 88 89 90 86 87 88 89 90 86 87 88 89 90 86 87 88 89 90 86 87 88 89 90

0.1 0.00128 0.00136 0.00126 0.00145 0.00173 0.00410 0.00423 0.00411 0.00419 0.00471 0.00272 0.00269 0.00262 0.00334 0.00321 0.00441 0.00447 0.00448 0.00478 0.00451 0.00424 0.00419 0.00419 0.00465 0.00438

1 0.00004 0.00004 0.00004 0.00009 0.00004 0.00011 0.00007 0.00006 0.00013 0.00006 0.00033 0.00046 0.00041 0.00036 0.00038 0.00047 0.00042 0.00067 0.00042 0.00052 0.00046 0.00045 0.00059 0.00042 0.00048

0.2 0.00001 0.00001 0.00001 0.00002 0.00001 0.00002 0.00002 0.00002 0.00003 0.00002 0.00006 0.00007 0.00006 0.00006 0.00006 0.00008 0.00006 0.00009 0.00007 0.00007 0.00007 0.00006 0.00008 0.00006 0.00006

0.08 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00001 0.00000 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001 0.00001

0.32 0.01457 0.00960 0.01452 0.05401 0.03470 0.02026 0.01457 0.02009 0.06061 0.05266 0.04951 0.06006 0.05746 0.04932 0.04857 0.06406 0.05619 0.07507 0.05984 0.05996 0.06253 0.05940 0.06742 0.05727 0.05524

0.16 0.00153 0.00157 0.00152 0.00169 0.00190 0.00303 0.00308 0.00297 0.00320 0.00344 0.00437 0.00474 0.00436 0.00487 0.00466 0.00581 0.00626 0.00600 0.00601 0.00555 0.00562 0.00606 0.00583 0.00594 0.00547

Days >=1.0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

0.005 0.00057 0.00066 0.00061 0.00056 0.00067 0.00123 0.00139 0.00128 0.00120 0.00133 0.00186 0.00231 0.00205 0.00218 0.00198 0.00246 0.00304 0.00288 0.00252 0.00228 0.00221 0.00281 0.00265 0.00236 0.00219

0.005 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000 0.00000

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Appendix H Air Quality Analysis Modeling Report

Table 4-7 MAXIMUM CALPUFF-LITE PREDICTED IMPACTS FROM PHASE 3 (PRODUCTION)
NOx Annual μg/m3 3-hour μg/m3 24-hour μg/m3 Annual μg/m3 24-hour μg/m3 Annual μg/m3 Deciview Change SOx PM10 Visibility1 Deposition N2 kg/ha/yr Deposition S3 kg/ha/yr

Pollutant→

Class I & Class II Areas↓

Modeling Period→

Colorado National Monument

Black Canyon of the Gunnison Wilderness

↓Year/SIL→ 86 87 88 89 90 86 87 88 89 90

0.1 0.06837 0.07231 0.06916 0.06345 0.06544 0.00471 0.00479 0.00481 0.00512 0.00483

1 0.00129 0.00115 0.00115 0.00100 0.00116 0.00041 0.00042 0.00070 0.00041 0.00054

0.2 0.00023 0.00024 0.00031 0.00028 0.00026 0.00007 0.00006 0.00009 0.00007 0.00007

0.08 0.00004 0.00004 0.00004 0.00004 0.00004 0.00001 0.00001 0.00001 0.00001 0.00001

0.32 0.16324 0.17413 0.21695 0.20546 0.19258 0.06379 0.05737 0.07874 0.06002 0.05988

0.16 0.02776 0.02933 0.02777 0.02721 0.02717 0.00594 0.00648 0.00619 0.00622 0.00574

Days >=1.0 0 0 0 0 0 0 0 0 0 0

0.005 0.01416 0.01507 0.01414 0.01360 0.01361 0.00241 0.00306 0.00286 0.00253 0.00225

0.005 0.00001 0.00001 0.00001 0.00001 0.00001 0.00000 0.00000 0.00000 0.00000 0.00000

1

2

Number of days with deciview change >1.0. Nitrogen deposition (N) 3 Sulfur deposition (S) µg/m = micrograms per meter kg/ha/yr = kilogram per hectare per year NOx = nitrogen oxides PM10 = particulate matter with an aerodynamic diameter less than 10 micrometers SIL = significant impact levels SOx = sulfur oxides

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Appendix H Air Quality Analysis Modeling Report

5.0

References

Air Resource Specialists. 2005. CALPUFF Reviewer’s Guide Prepared for Federal Land Managers. CDPHE, Machovec. 2007. Meteorology guidance. Earth Tech, Inc. 2000. A User’s Guide for the CALMET Meteorological Model (Version 5.8) Earth Tech, Inc. 2000. A User’s Guide for the CALPUFF Dispersion Model (Version 5.8) EPA, Air Quality Modeling Group. 1998. Interagency Workgroup on Air Quality Modeling (IWAQM) Phase 2 Summary Report and Recommendations for Modeling Long Range Transport Impacts. Research Triangle Park, NC. USDI – Bureau of Land Management, Archer. 2003. Seasonal FLAG Screening Analysis Spreadsheet. USFS, NPS, and USFWS. 2000. Federal land Managers’ Air Quality Related Values Workgroup (FLAG), Phase I Report.

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Appendix H Air Quality Analysis Modeling Report

Attachment A Estimated Duration for Project Phases

Appendix H Air Quality Analysis Modeling Report

Appendix H Air Quality Analysis Modeling Report

Source: email sent from Jim Stover to URS Corporation, 12/17/2007.

Appendix H Air Quality Analysis Modeling Report

Appendix H Air Quality Analysis Modeling Report

Attachment B Emission Calculations

Appendix H Air Quality Analysis Modeling Report