The following information is summarized from the Eastern Interior RMP Reasonably Foreseeable Developments for Locatable Minerals and Leasable Hardrock Mineral Resources in the White Mountains Subunit (BLM 2012b) which is incorporated by reference. In the reasonably foreseeable development scenario (RFD) the BLM developed models for typical suction dredging, small placer, and large placer operations, describing acres of annual disturbance, size of the crew, hours of operation, fuel requirements, and type of equipment used for each type of operation. These same models were used for the analysis of hardrock mineral leasing. This analysis assumes that development under mineral leases would occur in a similar manner to development under the 3809 regulations (43 CFR 3809).

In accordance with the regulations for hardrock leasing (43 CFR 3500), the BLM envisions the following potential developments:

Suction Dredge Placer Leases: In addition to the mechanical operations described below, the BLM estimates there would be 10 suction dredge operations on lands with high placer development potential and one additional operation on lands with medium development potential. A suction dredge operation is limited to within active steam margins and would disturb about one-half acre per year. The maximum potential disturbance from all 11 operations for the twenty-year life of the plan with natural concurrent reclamation is 84 acres.

Mechanized Placer Leases: To estimate the effects of development of traditional placer mining operations, the BLM considered two mining models: a smaller mobile placer operation using a small dozer and excavator feeding an 11 cubic yard-per-hour washplant and a larger 145 cubic yard-per-hour “Kantishna-type” washplant supported by a larger excavator and track-dozer. A small operation would mine and reclaim one acre per year, but have a continual 4.4 acres of disturbance per year for a total disturbance of 27 acres for the life of this plan. A large operation would have a continual 20 acres of disturbance and a total disturbance of 107 acres over the life of this plan. The BLM estimates there could initially be two large and eight small operations annually, with an additional three small operations following work done under exploration licenses, for a total disturbance of 507 acres over the life of the plan.

Placer Exploration Licenses: The BLM may require exploration of placer resources in the medium development potential areas prior to issuing placer leases; the applicant may request exploration licenses in the higher development potential areas before the BLM offers competitive leases. Most placer exploration would cause minimal disturbance, but the applicant could also request approval for more intensive placer sampling with heavy equipment. The BLM anticipates there could be four exploration licenses (5,000 acres each) requested within the lands opened to leasing, resulting in direct disturbance to and reclamation of 20 acres over the life of the plan.

Rare-Earth Element Exploration Licenses: If the White Mountains NRA were opened to hardrock leasing, there would likely be an exploration license request for the 11,000 acres in the Roy Creek REE known deposit. Exploration activities would range from field mapping and sampling, to trenching and core-drilling. The total life-of-plan disturbance from exploration of the Roy Creek REE deposit is expected to be 50 acres.

Surface disturbing activities, including mining and exploration activities outlined here, directly and adversely impact cultural and paleontological resources. Disturbance to prehistoric sites by any particular mining or exploration operation would need to be assessed on a case-by-case basis. Their locales on the landscape are a bit more predictable than are historic mining sites. In sum, hardrock mineral leasing would likely directly and adversely impact all manner of surface and buried cultural and paleontological resources.

Similarly, new access roads might be authorized to reach future valid mineral leases. New road construction has a direct and adverse effect on cultural and paleontological resources. It also has an indirect effect when new users (such as recreators, hunters, and those interested in procuring forest and woodland products) gain access to previously isolated lands. With more resource users accessing BLM-managed lands, the potential increases for more people finding surface cultural resources and adversely impacting them, whether intentional or not.

Many low-level, seemingly minor impacts (such as walking or camping on a site) can slowly and cumulatively grow into a larger direct adverse effect over time. Similarly, visitors to sites often feel an urge to connect with the past by removing a piece of the site when they leave, like an artifact. Removal of a one, two, three, or more artifacts would not likely affect overall site interpretation. However, the point would come when enough artifacts are removed, that the cumulative removal would irreversibly affect any interpretations that can be made about that site. By promoting and increasing use and visitation upon public lands, hardrock mineral leasing may inadvertently adversely impact cultural and paleontological sites in this cumulative manner.

Methods and Assumptions: Potential impacts on fish and aquatic resources are based on interdisciplinary team knowledge of the resources and the planning area. Impacts were identified using best professional judgement and were assessed according to the following assumptions:

Approximately 160,000 acres are recommended open to hardrock mineral leasing in Alternative D, including 250 miles of headwater streams located in the southeast portion of the White Mountains NRA. These streams form the headwaters of Beaver Creek WSR (Figure M.1). These headwater streams are clear, rapid streams with long riffles, few pools, with an average width of 50 feet (Rhine 2005). The substrate generally consists of a gravel-cobble mixture (3 to 12 inches in diameter). Although some placer mining activity has occurred in headwater areas of Beaver Creek, most of these streams are thought to be in pristine condition, with the exception of Nome Creek. Nome Creek was heavily placer mined for gold from the early 1900s to the late 1980s. Mining disturbed more than seven miles of stream and by the 1980s the floodplain was largely obliterated (Kostohrys 2007). From 1991 to the present, the BLM has been working to restore the floodplain, reestablish riparian vegetation, and maintain a single thread channel. The BLM has expended an estimated $450,000 on the Nome Creek reclamation project (USKH 2006).

Fish species found within the upper Beaver Creek watershed that are adjacent to or within areas recommended open to mining include Chinook salmon (Oncorhynchus tshawytscha), Arctic grayling (Thymallus arcticus), whitefish (Coregoninae spp.), and slimy sculpin (Cottus cognatus). Beaver Creek also supports regionally significant fish species which include small populations of coho (O. kisutch), and summer chum salmon (O. keta). The creek also supports moderate to high densities of Arctic grayling and northern pike (Esox lucius) which provide important recreational fishing opportunities. These populations of regionally significant fish species, unique concentrations of Arctic grayling, and the river’s pristine habitat support BLM’s identification of fish as an Outstanding Remarkable Value (ORV) for Beaver Creek (BLM 2012a, Appendix E).

The BLM monitored Beaver Creek Chinook salmon escapement from 1996 to 2000 and the data revealed a declining trend similar to the overall decline of Yukon River Chinook salmon (Volk et al. 2009). The Beaver Creek Chinook salmon escapement for these years ranged from 114 to 315 Chinook salmon. Although Beaver Creek Chinook salmon were designated as a BLM Alaska sensitive species in 2004 due to the downward trend of this small population, they were recently removed from that list and placed on a watch list. Since 2000, the Alaska Department of Fish & Game (ADF&G) has considered the Yukon River Chinook salmon stock as a stock of yield concern based on escapement performance, expected yields, and harvestable surpluses (Howard et. al. 2009). Beaver Creek Chinook are a component of the Yukon stock. Between 1996 and 2000, the overall Yukon River Chinook escapement range from the highest (about 300,000) to the lowest (about 100,000) dating back to 1982. Beaver Creek contributes a small percentage of the overall Yukon River Chinook salmon stock. The Yukon stock, however, is made up of numerous genetic stocks (such as the Beaver Creek stock) all of which are considered important to the overall health and viability of the stock.

The ADF&G Anadromous Water Catalog identifies Chinook salmon spawning and rearing in Beaver and Ophir creeks and Chinook spawning in Nome Creek (Figure M.2). Adult Chinook salmon in spawning condition have been observed at the confluence of Bear and Champion Creek (E. Yeager, pers. comm. May 15, 2012). That location is many miles farther upstream than what the Anadromous Waters Catalog identifies as the extent of anadromy. This reinforces ADF&G’s assumption that approximately 50 percent of the anadromous streams or extent of anadromy have not yet been identified.

The excellent opportunity for Arctic grayling fishing was one of the values identified for establishing Beaver Creek as a component of the National Wild and Scenic Rivers System (BLM 1983). In 2000, the BLM and ADF&G performed an Arctic grayling study on the upper 30 miles of Beaver Creek, including the area between the confluence of Bear and Champion creeks and the confluence of Nome Creek (Fleming et al. 2001). This study estimated the population density of Arctic grayling at 1,325 per mile, which is higher than other studies on summer feeding populations in Alaska by as much as 44 percent. The study also revealed an increase in the size of grayling as the study moved upstream to the headwaters of Beaver Creek. This pattern was reinforced by other studies that found large male Arctic grayling migrating from downstream areas to Bear and Champion creeks during late May and June, while females and smaller males move into these areas during July and August (Rhine 1985). Within the upper 100 miles of Beaver Creek, the headwater streams (e.g., Bear and Champion creeks) have produced the largest and oldest Arctic grayling based on BLM and ADF&G fish sampling efforts and reports from recreational anglers (T. Dupont, pers. comm., May 22, 2012). This pattern reflects the generally accepted life-history paradigm for Arctic grayling that larger and older fish spend the summer feeding period in headwater areas and tributaries of rapid runoff rivers in Alaska (Armstrong 1982). Although Arctic grayling primarily use the headwater streams for summer feeding, some evidence of spawning has been observed (Rhine 1985; Kretsinger 1986) and may justify future inventory work.

Suction dredging, a type of placer mining, can have both beneficial and adverse effects on fish and aquatic habitat depending on the timing and location of the activity.

Suction dredging has been shown to locally reduce benthic (bottom dwelling) invertebrates (Thomas 1985; Harvey 1986), cause mortality to early life stages of fish due to entrainment by the dredging equipment (Griffith and Andrews 1981), destabilize spawning and incubation habitat, remove large roughness elements such as boulders and woody debris that are important for forming pool habitat and that can govern the location and deposition of spawning gravels (Harvey and Lisle 1998), increase suspended sediment, decrease the feeding efficiency of sight-feeding fish (Barrett et al. 1992), and reduce living space by depositing fine sediment (Harvey 1986).

Conversely, suction dredging may temporarily improve fish habitat by creating deep pools or by creating more living space by stacking large non-embedded substrate (Harvey and Lisle 1998; Figure M.2). In dredged areas, invertebrates and periphyton are known to recolonize relatively rapidly, as long as the disturbance area is sufficiently limited to maintain populations of recolonizing organisms (Griffith and Andrews 1981; Thomas 1985; Harvey 1986). In addition, dredge tailings may increase spawning sites in streams lacking spawning gravel or streams that are armored by substrate too large to be moved by fish (Kondolf et al. 1991). In some cases, reduced visibility caused by elevated levels of turbidity can diminish the feeding efficiency of fish, while at the same time the reduced visibility may lessen the risk of predation (Gregory 1993).

Suction dredging operations within the Steese Subunit have been known to adversely impact streambank stability as well as riparian and stream channel function. Although disturbance to streambank and riparian habitats and alterations to the stream course is prohibited for suction dredging operations, in some cases these areas have been impacted. This type of activity results in an overwidened and shallow stream course, which is braided around stacked piles of large substrate. These impacts adversely affect riparian and stream function and if not reclaimed may persist for extended periods of time (years/decades) due to the amount of stream energy required to redistribute this large-sized substrate in the stream channel. It is assumed that these situations would be limited and that lease and license stipulations would minimize the level and duration of impacts to aquatic resources.

The anticipated number of suction dredging operations during the life of this plan is 11 (Table M.3). There would be 250 miles of stream open mineral leasing with an anticipated disturbance of 84 acres, or 14 miles of stream. Suction dredging operations are anticipated to disturb 22,000 cubic yards of stream gravel over the life of this plan or the equivalent of 2,200 typical (10 cubic yard) dump truck loads of stream gravel. Impacts from suction dredging operations that do not alter streambank stability or adversely impact riparian and stream channel function, and adhere to stipulations in the suction dredge permit, are likely to be minimal and of short-term duration (less than or equal to five years).

Conventional mechanized placer mining involves the use of heavy equipment to access gold deposits. One method of mine development is to move the stream into a bypass channel, while the original stream channel is excavated for gold deposits. During this process the streambed, streambanks, and riparian vegetation are physically removed in order to access gold-bearing fluvial deposits which may extend to the bedrock. This method destroys the existing fish and aquatic habitat and eliminates all biological stream functions. Impacts to fish and aquatic resources can be severe and last for decades under the stream-altering bypass method (Tidwell et al. 2000, Arnett 2005, Viereck et al. 1993; Milner and Piorkowski 2004; BLM 1988 a, b, and c). Soil erosion from large surface disturbing activities (such as mechanized mining) often results in poor water quality and elevated turbidity levels harmful to fish and fish habitat far beyond the impact site. The River Management Plan for Beaver Creek National Wild River (BLM 1983c) stated that placer mining activities in the headwaters of Beaver Creek resulted in turbid water conditions as far as 30 miles downstream. Surface management regulations have since changed, in part to reduce adverse impacts to water quality from mining. The severity and duration of impacts are substantially reduced when mining operations occur outside of the stream channel and active floodplain.

The anticipated number of mechanized placer mining leases during the 20-year life of this plan is 13 (BLM 2012b). Approximately 250 miles of stream would be open to leasing for mechanized placer mining with an anticipated amount of disturbance of 507 acres. This disturbance would likely occur within floodplain areas and/or in the stream channel. In an attempt to quantify the number of stream miles that may be directly impacted by leasing, the length of a typical mining claim block (660 feet) from other subunits was used. The anticipated number of stream miles directly impacted by leasing would be eight miles. The likelihood of impacts would be greatest in the high development potential areas, which, contain more than half of the stream miles open to mechanized leasing.

If mining did occur, the ROPs specific to fish and aquatic species (Appendix A) would improve the likelihood of obtaining desired future conditions for aquatic habitats within an accelerated timeframe after reclamation. A range of success would be expected based on several factors. These factors include baseline data collection, stream channel design/construction technique, the reclamation measures specified for the particular operation, the watershed characteristics, the capability of the site to revegetate, and the probability of experiencing a flood event prior to the reestablishment of riparian vegetation that is capable of dissipating stream energy and preventing erosion.

Assuming that baseline data is collected, reclamation is designed using the best available techniques such as those outlined in the Natural Resources Conservation Service’s (NRCS, 2007) Stream Restoration Design, National Engineering Handbook, Part 654, and all of the factors previously mentioned are favorable, it is likely that instream habitats would rehabilitate within five years following reclamation. In these cases, impacts would be expected to be minor and short-term. However, stream channel design/reconstruction and aquatic habitat rehabilitation is very complex, especially within the planning area due to the harsh environmental conditions (such as short growing season, aufeis) and limited availability of hydrography data. Recognizing this complexity, a more realistic outcome may be a strong positive trend toward the desired habitat conditions within five to ten years under this management scenario. It would be essential that reclamation plans incorporate stream channel design based on channel forming discharge (typically a 1.5 year recurrence interval) and the floodplain be capable of transporting 100-year flood flows. This would minimize the chance of reclamation failure and the need for subsequent reclamation work by the operator.

In summary, placer mining can negatively affect fish and aquatic resources by degrading or eliminating aquatic habitat; reducing available food sources and water quality; reducing available pool habitat; eliminating riparian vegetation and function; creating sparsely vegetated valleys and floodplains with slow rates of natural revegetation and unstable stream channels with highly erodable beds and banks; altering the longitudinal slope, geometry, and sediment transport rates in streams; and, creating undersized or absent floodplains.

Potential adverse impacts would likely be from surface erosion of disturbed soils and the destruction of riparian vegetation resulting in elevated turbidity levels and sedimentation to nearby water bodies. The effects of excess sediment and the removal of riparian vegetation to fish and aquatic resources is described in section 4.3.1.4.1 of the Eastern Interior Draft RMP/EIS, which is incorporated by reference. Although sediment is a natural part of the aquatic ecosystem, an increase in fine sediment has the potential to affect the availability of food, predator avoidance, immune system heath, and reproduction of fish and aquatic species. The ROPs (Appendix A) should reduce impacts from exploration to a negligible level with short duration given the anticipated level of disturbance from exploration activities. The larger the surface disturbance and the closer it is to the stream, the greater the severity and duration of the impact.

It is anticipated that one lode exploration license would be requested in the Roy Creek REE deposit, resulting in 50 acres of disturbance. While it is unlikely that fish or fish habitat studies have ever been performed in the headwaters of Roy Creek, it is reasonable to conclude that fish may not be present in the headwaters of this relatively small, high gradient stream. Direct impacts from lode exploration are not anticipated. Potential indirect adverse impacts from surface erosion would be similar to those described above for placer exploration activities.

Previous surveys in the Roy Creek area indicate that the soils are mainly of the granitic type (John Hoppe, pers. comm. May 10, 2012) that pose little threat to fish and aquatic life when disturbed and exposed to air and water. Although unlikely, if soils containing sulfide bearing ore were disturbed and exposed to air and water during exploration activities, acid mine drainage may occur and result in adverse indirect impacts to downstream waters. Acid mine drainage can cause physical, chemical, and biological degradation to aquatic habitat (Jennings et al. 2008). Predicting the risk of acid mine drainage at mine sites is often inaccurate (Jennings et al. 2008). It will be necessary to collect site-specific information variables and data to predict the potential for acid mine drainage in the Roy Creek area.

Beaver Creek Chinook salmon are currently a BLM Watch List species (BLM 2010). This species should be emphasized for additional inventory, monitoring, or research efforts to better understand the population or habitat trends. Beaver Creek Chinook salmon are a component of the Yukon River Chinook stock, a stock of yield concern since 2000 (Howard et al. 2009). Beaver Creek Chinook salmon spawn and rear immediately downstream and potentially within the area proposed for opening to conventional mining (Figure M.1). The adverse impacts from mechanized mining, including the downstream effects and habitat degradation, could cause the Beaver Creek Chinook to become designated as a BLM Alaska Sensitive Species.

Fish and aquatic resources have been adversely impacted from past mechanized mining activity in the Beaver Creek drainage. The majority of these impacts occurred from 1900 until the mid-1980s in Nome Creek, where extensive mining for placer gold obliterated seven miles of stream and floodplain (Kostorhys 2007). This activity resulted in the direct loss of fish habitat and sediment pollution to Beaver Creek. Although habitat conditions in Nome Creek have greatly improved from nearly 20 years of reclamation work by the BLM, desired conditions for aquatic habitat have not yet been achieved (desired future conditions are described in section 2.4.1.3 of the Draft RMP/EIS, BLM 2012a). Portions of Nome Creek have not been reclaimed and are not likely to be in desired condition for aquatic habitats. Mechanized mining activities have also occurred in other tributaries, but to a much lesser extent. There are no known current mining activities in the Beaver Creek drainage.

A hardrock mineral leasing program would open 160,000 acres to the leasing and exploration of formally locatable minerals in the White Mountains NRA with an anticipated disturbance of 661 acres and eight miles of stream. Suction dredging activities may impact 14 miles of stream. Past and future mechanized mining proposed in this alternative may result in approximately 20 miles of stream within the NRA that would not meet the desired conditions for aquatic habitats. Cumulative impacts specific to the NRA would be in addition to the cumulative impacts described in section 4.3.1.4.2. of the Eastern Interior Draft RMP/EIS (BLM 2012a). Cumulative impacts from Alternative D, would have the greatest potential for adverse impacts to fish and aquatic resources relative to the other alternatives.

Alternative D also allows the most latitude to OHV use and rights-of-way and would result in the greatest disturbance to soil and vegetation in the areas recommended open to hardrock mineral leasing. This would create the greatest potential for the introduction of nonnative invasive plant species (invasive plants) within the White Mountains NRA. Equipment imported for mineral exploration and development activities often harbor seeds of invasive species that could dislodge and germinate at these remote sites.

The reasonable foreseeable development scenario (RFD) forms the basis for evaluating the impacts to resources (section M.3.1) from hardrock mineral leasing. The total disturbance over the life of the plan is expected to be 661 acres from all hardrock leasing and exploration licenses, a relatively small portion of the 160,000 acres open to exploration and development. Assuming that exploration and development occurs throughout the open area, invasive plant species could be introduced in a dispersed rather than concentrated pattern, complicating control and containment.

The RFD includes the assumption that 20 miles of roads would be built in support of new placer developments. The roads are linear vectors for the introduction and spread of invasive plants into these remote areas. Seeds from infestations along roads can move along other intersecting linear features, such as trails and waterways, further spreading undesirable nonnative species into remote areas. For example, infestations of white sweetclover (Meliotus officianalis) have been documented on sand bars along the Nenana River, spreading from source populations upstream (Conn et al. 2008). Section 4.7.1.3.4 of the Eastern Interior Draft RMP/EIS (BLM 2012a), which is incorporated by reference, contains analysis of rights-of way development in the White Mountains NRA for Alternative C. Impacts identified in this section apply to the roads in support of new placer developments analyzed in this supplement.

Any natural or human-caused disturbance to the landscape provides an opportunity for invasive plants to become established. Equipment, watercraft, vehicles, and gear may harbor seeds that may then be transported to project sites. Climate change may accelerate the ability for invasive plants to become established (Rupp and Springsteen 2009). More general information about vectors and impacts from introduction and spread of nonnative invasive plants are in Chapter 4 of the Eastern Interior Draft RMP/EIS (BLM 2012a). This information is incorporated by reference. Section 4.3.1.5 discusses effects common to all subunits. Section 4.7.1.3 of the Draft RMP/EIS contains analysis of impacts for locatable minerals on 4,000 acres of valid existing rights outside the NRA and other decisions, but assumes no hardrock leasing within the White Mountains NRA. Impacts from hardrock mineral leasing would be similar to those from locatable mineral exploration and development.

ROPs and Leasing Stipulations in Appendix A of the draft RMP/EIS and those modified in this supplement (shown in Appendix A of this document) to mitigate impacts from hardrock mineral leasing would be applied on a case-by-case basis to leases and exploration licenses. ROPs in section M.4.2.10 of this document specifically address eliminating or minimizing the introduction and spread of invasive plants by prescribing standards for vegetation treatment, revegetation with native plants, reclamation for roads and trails, and salvage of vegetative mat and topsoil. Other ROPs in Appendix A would also help limit the introduction and spread of invasive plants.

Nonnative invasive species other than plants may be introduced by exploration or development when equipment from Canada or other parts of the United States are imported to the work sites. This equipment can harbor insect eggs, larvae, pupae, adult or other viable life cycle stages and other undesirable pathogens and pests. Little documentation exists that invasive species other than plants have been introduced into Interior Alaska. Over the life of the plan where there may be concerns about other invasive species, however, permit stipulations to mitigate introduction of insects, other pests and pathogens would be developed on a case-by-case basis.

Indirect impacts would result where invasive plants become established due to hardrock exploration development, including potentially long-term changes in plant community structure and diversity and wildlife habitat degradation. Costs include long-term monitoring and control. Containment and control of invasive plants for the long-term may also include further soil disturbance and the application of herbicides.

Compared to other alternatives, Alternative D would result in the greatest disturbance to soil resources and adverse impacts to water quality because selected areas (Figure M.1) would be open to hardrock mineral leasing. Ongoing climate change would also affect these resources and may increase the magnitude of effects from mining.

Anticipated disturbance in the White Mountains NRA is estimated at 507 acres by mechanized placer mining operations, 20 acres associated with the issuance of placer exploration licenses, 50 acres from the issuance of rare earth element exploration licenses, and 84 acres of disturbance from placer gold suction dredging in areas with high placer gold potential, including Ophir, Bear, Quartz, Champion, Little Champion and Moose creeks. Mining activities would be limited to approximately 160,000 acres in areas of known historic mineral activity in the south/southeast part of the White Mountains NRA. Lands within one-half mile of Nome Creek would be closed to leasing because of long-term ongoing stream reclamation as well as parcels of wetland acreage committed in perpetuity as U.S. Army Corps of Engineers compensatory wetland mitigation acreage.

Disturbance to soil and water resources by any particular mining or exploration operation would need to be assessed on a case-by-case basis. Impacts to soil and water resources vary depending on the development methods used, size of the operation, and number of mines. Because 160,000 acres would be open to mineral development under Alternative D there would be increased potential for adverse impacts to soil and water resources. Impacts would be reduced through application of ROPs and site-specific analysis of subsequent authorizations.

Placer mining can have an adverse effect on the existing soil profile structure by stripping of overburden and riparian/wetland vegetation. The usual procedure is for the overburden (including organic materials) to be stripped, coarse underlying materials separated from gold-bearing material in the processing plant, and fine materials discharged to a series of settling ponds with recycled water used by the processing plant. There is an irretrievable loss of any soil that enters waterways and is transported downstream.

Erosion of soils from non-point sources typically contribute to the sediment load of stream systems and may result from stream crossings, roadways directly adjacent to stream channels, improved roads and trails which converge down-gradient to stream channels.

The primary impact to water quality from mining is an increase in sedimentation and turbidity. Some direct effects on water quality can be anticipated during the development stage of an operation due to the construction of settling ponds and stream bypasses, and through re-channelization of the stream. This would result in short-term increases in sediment levels and turbidity while equipment operates near or in the active stream channel.

Leasees would be required to meet Alaska Department of Environmental Conservation water quality standards and acceptable discharge standards available online at http:\\dec.alaska.gov/commish/regulations/index.htm. It is anticipated that turbidity as a result of direct and indirect discharge from placer mine operations would meet ADEC water quality standards. However, it is likely that occasional high water or failure of water control structures would introduce sediments collected by the water treatment system into the stream channel. This would result in short-term increases in turbidity and sediment load levels and possible localized sedimentation of the stream substrate. The degree of impact would depend on the amount of material released and the streamflow at the time of release.

Stream channel morphology would be directly affected in all areas where activities associated with mining occur in the active channel; by-pass channels are usually constructed to allow mining in the active channel.

Indirect impacts to water quality would occur through non-point source erosion from disturbed areas associated with placer operations including access road and trails and equipment staging areas directly adjacent to stream channels. Channel readjustment would occur where the active channel was modified. These processes increase suspended sediment into the stream system, particularly during spring break-up and floods.

The impacts to soil and water resources could be expected to decrease after cessation of mining, successful revegetation of the disturbed areas, and stabilization of the disturbed channel. It is estimated that reestablishing vegetation on placer waste rock piles may take decades. The rate of succession (revegetation) seems to be heavily influenced by the proportions of particles of silt and clay size in the surface layer of the tailings (Rutherford and Meyer 1981).

ROPs (Appendix A) have been developed to reduce impacts to soil and water resources that may result from hardrock mineral leasing activities. Additional mitigation measures, if necessary, could be developed during NEPA analysis of specific mineral leases or exploration licenses. Water quality monitoring requirements (Wagner et al. 2006) would be defined through this process.

Daily stream flow and water quality is currently monitored on lower Nome Creek and on Beaver Creek near its confluence with Victoria Creek to document daily, annual, and long-term variation in flows and water quality. The BLM would continue to monitor water quality and in-stream flow in selected streams and lakes to ensure that state water quality standards were met and to document changes in stream flow. Activities expected to adversely alter natural flows would not be permitted.

In Interior Alaska a majority of the suction dredge operations occur in the Fortymile River area. The USGS conducted a systematic water quality study of the Fortymile River and many of its major tributaries in June of 1997 and 1998 (Wanty et al. 1999). Surface-water samples were collected for chemical analyses to establish regional baseline geochemistry values and to evaluate the possible environmental effects of suction-dredge placer gold mining and bulldozer-operated placer gold mining (commonly referred to as cat-mining). They concluded, based on water-quality chemistry and turbidity data, that the suction dredges had no apparent impact on the Fortymile River system, although possible effects on biota were not evaluated. One of the three cat-mining operations monitored, however, had adverse impacts on local water quality and streambed morphology.

Cumulative impacts can also result from repetitive use of an area, such as a single OHV stream crossing along a user-created trail. Minor disturbance may result from a single crossing, however, multiple use of an unimproved OHV stream crossing site can result in substantial cumulative impacts including soil compaction, damage to riparian vegetation, erosion along user-created trails and potential decrease in bank stability and local water quality.

Placer mine development has occurred in the Steese-White Mountains area since the early 1800s using a variety of mechanized methods including dredges, draglines, dozers, and excavators. The soil profile is typically destroyed for long periods in areas of active dredging or sluicing, with shorter-term impacts of soil compaction and alteration in areas of facilities, roads, and trails. Water quality is often degraded by increased siltation depending on site characteristic and the type of mining operation.

The total disturbed area from historic placer activity on BLM-managed lands in the planning area is estimated at 7,500 acres, with less than 500 acres likely disturbed by past mining activity in the White Mountains. Alternative D of the Draft RMP/EIS would recommend opening selected areas to mining, potentially resulting in development of new access roads and mine operations. A portion of this projected mining, however, would likely occur in previously mined areas. Development of an estimated 61 small-scale (20 to 30 acres) placer mines and eight large-scale (60 to 80 acres) would be expected on BLM-managed land under Alternative D, all outside of the White Mountains NRA. The addition of a hardrock mineral leasing program in the White Mountains NRA would potentially add two large-scale placer mines, 11 small-scale placer mines, and 11 suction dredging operations in the White Mountains. This level of activity is projected to add an additional 661 acres of new disturbance in the NRA.

In its 2007 Mineral Industry Report, the Alaska Division of Geologic and Geophysical Surveys (DGGS), lists 81 separate companies or individuals that were estimated to be producing gold in the planning area (Szumigala et al. 2008). The amount of acreage on state and private land that has been disturbed or reclaimed by mining operations within the planning area is uncertain.

Two large-scale lode mines, Pogo and Fort Knox, are in operation on state lands within the planning area. One potential lode mine, “Money Knob”, is located near the town of Livengood along the western boundary of the White Mountains subunit. If potential lode mines are developed, varied impacts to soil and water resources would be expected depending on the type of mine development and ore processing methods.

Wetland, riparian, and aquatic habitats support most of the BLM Alaska sensitive animal species. Olive-sided flycatcher, blackpoll warbler, rusty blackbird, Alaskan brook lamprey, Alaska endemic mayfly (Rithrogena ingalik), a mayfly (Acentrella feropagus), and a stonefly (Alaska sallfly, Alaskaperla ovibovis) are BLM Alaska sensitive species that are dependent on these habitats and may occur in the hardrock leasing area, or downstream in areas potentially affected by hardrock leasing activities. The Alaska tiny shrew (Sorex yukonicus) may also occur more frequently in riparian habitats. Placer mining and associated changes in access could result in substantial localized impacts to riparian and aquatic habitats and species, if the species occurs in or downstream of the area of disturbance. Rangewide impacts are unlikely to be substantial. Reclamation requirements for riparian and aquatic habitats should increase reclamation success and reduce impacts for sensitive species occurring in these habitat types.

Olive-sided flycatcher, blackpoll warbler, and rusty blackbird are found in the White Mountains in low densities. These species are widely distributed in the planning area. All are associated to some extent with riparian or wetland habitats. ROPs that minimize impacts to riparian and wetland habitats through reclamation would reduce impacts over the long-term. Occurrence of these species in other habitats and areas is dispersed enough that anticipated activities are unlikely to impact any of them at a population level.

Alaskan brook lamprey is found in the Chatanika River, near the Elliott Highway bridge close to the Beaver Creek drainage in the White Mountains NRA, but is not known to occur on BLM-managed lands. Alaska endemic mayfly, a mayfly, and Alaska sallfly are not currently known to occur in the Beaver Creek headwaters or the White Mountains NRA, but data on distribution is extremely limited. It is not known how much of these species habitat, if any, is encompassed by the hardrock mineral leasing area, but disturbance of up to 591 acres of riparian habitats within the headwaters of Beaver Creek is not expected to result in impacts at the population level nor cause a trend toward federal listing for any of these species.

The Alaska tiny shrew occurs in low density within a variety of habitats, but is most common in riparian shrub habitats. It has been documented to occur in the Steese National Conservation Area near Twelvemile Summit. Widespread activities that clear large areas of vegetation could negatively impact this species. Mining could have localized effects to shrew habitat, but given the variety of habitats used and the low level of disturbance anticipated, would not likely occur at a scale or degree to cause a trend toward federal listing.

Most BLM Alaska sensitive plant species occur in habitats with specialized conditions, such as: steep south-facing dry bluff habitats; moist alpine herbaceous sites; rocky ridges, slopes, and screes; and, calcarious rocks or soils. Four species are known to occur in the White Mountains: Douglasia arctica is known from Mount Schwatka, Victoria Mountain and VABM Fossil (Parker et al. 2003); Poa porsildii found in the Lime Peak and VABM Fossil areas; Ranunculus camissonis collected in the Lime Peak area; and, Trisetum sibiricum collected from below Mount Schwatka and on Lime Peak. Although not documented, there is a potential for BLM Alaska sensitive plant species to occur in the mineral leasing area, particularly on the ridge between Quartz, Bear, and Champion creeks and in the Roy Creek REE deposit. There is less potential for these species to occur in creek bottom habitats where placer mining would occur. Given the habitat preferences for these species, the highest potential for impacts would be from REE mineral exploration activities. Exploration activities would result in minimal surface disturbance and impacts would be localized at drilling or trenching sites. ROPs SS-2 and SS-3 which require site-specific measures, such as avoidance, to protect sensitive plant species populations or individuals would further reduce the potential for direct impacts.

Hardrock leasing would impact individuals of some BLM Alaska sensitive species, the distribution of which are generally not well-known. Hardrock mineral leasing in the White Mountains NRA would result in greater impacts to sensitive species relative to Alternatives A, B, and C, and would add to cumulative impacts described for Alternative D in section 4.3.1.7.2 of the Eastern Interior Draft RMP/EIS (BLM 2012a). It is not anticipated, however, that the hardrock mineral leasing in Alternative D would trend any sensitive species toward federal listing.

A direct loss of native vegetation on 661 acres (less than one percent of the area open to mining) is estimated to occur at exploration and leasing operations during the life of the plan. Most of this vegetation would be riparian and wetland habitats. Some of this area would be needed for ongoing operations and would remain unvegetated for several to many years. A portion would be allowed to revegetate beginning within a year or two of disturbance. Times to reestablish vegetative cover would vary widely. Areas which have adequate fine and organic soil materials and viable seed and vegetative plant parts revegetate relatively quickly. Lease stipulations which require vegetation cover to meet pre-determined standards would result in faster revegetation. Riparian areas in which the stream channel was disturbed and a stable stream channel was not established would remain largely unvegetated until the channel stabilizes. Loss of fines and organic material through flooding and shifting channels can delay revegetation for decades.

The roads and trails developed for access to exploration and mine sites would disturb an undetermined area of native vegetation and supporting soils. Heavy, season-long use may result in significant loss of vegetation and degrading of soils in a variety of vegetation types. Vehicles larger than 1,000 pound curb weight and 50 inch width would be allowed in some instances, resulting in relatively greater impacts. Additional disturbance would occur through expansion of this network of roads and trails by recreational users. Much of the hardrock leasing area burned in a wildfire in 2004 and soils and vegetation may be more susceptible to impacts from motorized use.

In addition to changes in vegetation at exploration and mine sites and the network of roads and trails, establishment and spread of non-native invasive plant species could occur, facilitated by motor vehicle use.

Under Alternative D, 843,000 would be closed to hardrock mineral leasing, protecting visual resources in these areas (Figure M.1). Closed areas include the Beaver Creek WSR Corridor, the Research Natural Areas, and approximately 86 percent of the White Mountains NRA. This would protect visual resources by not allowing surface disturbing activities associated with mineral development. The reclaimed areas along Nome Creek would be closed protecting the viewshed from the access road.

Approximately 16 percent of the NRA (160,000 acres) would be recommended open to hardrock mineral leasing. Two large-scale and 11 small-scale placer mine operations are anticipated in this area. Total disturbance from all mechanized placer mining is anticipated to be 507 acres over the life of the plan.

Approximately 11 suction dredge operations are anticipated. Each operation would have a camp with a footprint of one-half acre over the life of the mine for a total maximum disturbance from all operations of 84 acres over the life of the plan. The movement of materials from dredging occurs underwater and thus does not have a noticeable impact to visual resources and is generally redistributed each spring during break-up or high water events. Impacts from the suction dredge camps are anticipated to be less that six acres annually over the life of this plan.

Exploration licenses could be issued on up to 11,000 acres in the Roy Creek REE deposit; however, exploration activities would disturb only an estimated 50 acres over the life of the plan.

Impacts to visual resources by exploration activities would depend on the scale of the action. Changes to line, form, color and texture of the natural landscape would result from activities such as trenching, access trails, vegetation clearing for drilling activities with the removal of vegetative cover and stockpiled materials creating form contrast between the trenched areas and the stockpiled materials and the background landforms. Trenched material stockpiles would also create color contrast between the greens of vegetation and the browns of soils. Texture would change from a natural medium, subtle texture of vegetation to a course, rough contrast of disrupted soils and organic materials. Changes in line from the irregular, weak line of the natural landscape to a regular, strong line between natural vegetation. Drill structures would introduce straight regular lines into a natural irregular weak line of the natural landscape as well as color contrast between the greens of vegetation and the drill structure for the short time the drill was in place.

The northern portions of the hardrock leasing area (including the Roy Creek REE deposit and upper Bear Creek and Quartz Creek placer gold areas) have been especially utilized by caribou. These areas occur within the core (most highly used) calving/postcalving area of the White Mountains caribou herd and the area most highly used by the Fortymile caribou herd in the past. The Fortymile herd calved in the White Mountains until 1963, and were reported to “most heavily” utilize the upper portions of Bear, Quartz, and Champion creek drainages (Olson 1957), which are mostly within the hardrock leasing area. The “concentrated calving area” identified by Olson (1957) centered on and included almost all of Bear and Champion creek drainages and headwater portions of Moose and Nome creeks. The location of Fortymile herd calving shifted from year-to-year, but reports indicate that the head of Bear Creek and Quartz Creek were the center of the herd’s long-term calving distribution.

Dall sheep habitat occurs in and adjacent to northern portions of the hardrock mineral leasing area. A Dall sheep mineral lick occurs 0.7 mile from the mineral leasing area in upper Little Champion Creek. The Roy Creek REE deposit is utilized by Dall Sheep during the rutting season. Hobgood and Durtsche (1990) mapped the ridgeline in this area as rutting habitat. The area was not included in a recent delineation of medium-to-high Dall sheep use based on a 2004-2008 study of radio-collared Dall sheep, but that study did document short-term use by one ram during the rut, supporting the earlier designation. The scattered granite tors on the ridge between Quartz, Champion, and Bear creeks are utilized by Dall sheep in all seasons. Although not included in the area to be opened to leasing, this ridge is likely to be utilized for access to leases.

The hardrock mineral leasing area contains relatively high densities of moose, during at least the October through April time period. Rut concentrations in the area were identified by Durtsche et al. (1990). High-quality riparian and aquatic habitats, including salmon spawning and rearing and high densities of Arctic grayling, support aquatic and terrestrial wildlife species. Nutrient transfer from aquatic to upland environments increases productivity of upland habitats. One known peregrine falcon nest site occurs in the hardrock leasing area and a gyrfalcon nest site occurs adjacent to the hardrock leasing area. Redtail hawk nest throughout the leasing area, often near streams.

Hardrock mineral leasing in Alternative D would result in an estimated direct disturbance from exploration and mining of 661 acres of terrestrial wildlife habitat. In addition, 20 miles of road is estimated to be built for access. Much of the surface disturbance from mining and access would occur to riparian areas and wetlands habitats which are typically high-value wildlife habitats. Effects of surface disturbance of these habitats would extend, to some extent, downstream into Beaver Creek WSR (e.g., through effects on turbidity or fish migration). Human activities associated with mines would reduce use of riparian habitats by many wildlife species in the immediate vicinity of the activity.

Changes in access and resulting increases in human use of the area may have a greater effect on wildlife and their habitats than direct habitat disturbance from mining-related activities. Most of the leasing area is not accessible via existing trails and much of the existing network of trails (mostly user-created) is susceptible to degradation from increased use. Mining activities would require much heavier use than the current levels of use (much of which is related to hunting) and for longer periods. Vehicles larger than allowed under OHV designations would be permitted in some cases, likely creating proportionally greater disturbance. The linear amount of new access has not been determined, but if each of the estimated 29 suction dredge and placer operations and exploration leases resulted in an average three miles of new trails (or seriously degraded existing trail), about 87 miles of such new or seriously degraded trail might be predicted.

Winter overland moves would often require clearing of vegetation. The linear clearings created may lead to summer use by OHVs and establishment of new OHV trails. The network of mining access trails would be utilized by lessees and recreationists to reach previously inaccessible areas, within which additional new trails may be created, resulting in further expansion of trail networks. Similarly, roads built for mine access would facilitate much greater OHV activity in the area in which they are constructed. In general, motorized access would increase throughout the hardrock leasing area, especially in the high potential areas. In addition to direct changes in habitat from user-created trails, the creation and use may also facilitate the establishment and spread of invasive plants, especially in areas recently burned.

Although little Dall sheep habitat is within the identified hardrock leasing areas, human use of additional access to sheep habitats in the Upper Champion Creek and Quartz Creek area may reduce sheep use of those habitats.

Moose may benefit from some ground disturbances that result in growth of deciduous browse species, such as willow. Increased hunting pressure and harvest in previously remote areas would likely reduce harvest in areas with already-established access, such as Nome Creek. Hunting pressure may result in some displacement of moose from high-density rutting areas.

Most of the estimated 661 acres of habitat disturbance would occur within the historical calving range of the Fortymile caribou herd and current calving area of the White Mountains caribou herd (Figure M.3). The White Mountains caribou herd has a dispersed calving distribution and the hardrock leasing area comprises a small proportion (11 percent) of the current White Mountains caribou herd calving/postcalving area. The much larger Fortymile Herd calves in a dense distribution. More than half of the hardrock leasing area of high development potential occurs within the area of concentrated calving identified by Olson (1957) for the Fortymile herd in 1956. Exploration of the Roy Creek REE deposit is estimated to result in disturbance of 50 acres of current and historic caribou calving habitat. Exploration activities would be required to occur outside of calving/postcalving season in this area, limiting impacts from those activities. The greatest impact to caribou would likely be the change in access, human infrastructure, and the generally increased levels of human activity in the area. Although anticipated placer gold mining operations in the area may have little direct effect on caribou use of the area, the combined direct and indirect effects from changes in access and human use patterns in the area would likely reduce the suitability of the area as calving habitat and potentially reduce the likelihood that the Fortymile Herd would reestablish a habit of calving season use of the White Mountains. The overall level of disturbance, including linear disturbance, and human activity within the calving area would influence the likelihood of use by caribou.

Compared with other large migratory caribou herds, the Fortymile herd’s current annual range has a low proportion of range above treeline (17 percent; Boertje et al. in press). Boertje and others (in press) surmised that overgrazing of the herd’s current core upland tundra habitat may have resulted in reduced herd nutrition levels and suggested that expansion to additional spring and summer upland tundra in the White Mountains may be of key importance to realizing continued herd growth.

Several species of migratory birds are dependent on (or found in much higher densities in) riparian habitats. Placer mining would remove habitat for these species in localized areas and habitat recovery may require several decades. Regardless of when the vegetation clearing occurs, impacts from the changes in vegetation would persist probably for many years. ROPs (Appendix A) protect only currently nesting birds. Nesting peregrine falcon and gyrfalcon are more likely to be affected indirectly by changes in access than directly by mining activities. Nesting redtail hawk may be displaced by nearby placer mining and dredging activities. These impacts are not expected to result in planning area population level declines of any species of migratory birds.

In Alternative D, with this supplement, 26 percent of the current White Mountains caribou calving/postcalving area would be open to leasing of hardrock minerals. A much higher proportion of the Fortymile herd’s historical (prior to 1963) would be open to leasing (Figure M.3). Almost the entire 38-mile segment of historical calving and migration habitat between Mount Prindle and Clum’s Fork calving area would be open to location or leasing of hardrock minerals (Fig 3.4). The addition of hardrock mineral leasing would further decrease the likelihood that Fortymile caribou would reestablish a tradition of calving in the White Mountains vicinity. Given the relatively small amount of alpine habitat within the range of the Fortymile herd, re-occupation of the calving and postcalving habitats in the White Mountains may be necessary for maintenance and growth of the Fortymile caribou population.

The development of mines and associated access in the hardrock leasing area during the life of the plan would likely make additional mines more economically feasible to develop in later years, possibly including the Roy Creek REE deposit. This could expand the intensity and zone of impacts to wildlife beyond that predicted during the life of this plan, including additional caribou and Dall sheep habitats.

In contrast, active mining operations and related infrastructure has the potential to have negative effects for those recreation visitors seeking a more primitive form of recreation experience, particularly in summer, when the effects of mining are more visible. The experience expectation for primitive recreation includes a feeling of solitude and closeness to nature. The 2007 and 2009 Benefits Based Management studies for the White Mountains (Fix 2007, Harrington and Fix 2009) demonstrated that in Nome Creek valley and adjacent areas of the NRA, awareness of the natural world, awareness of minimum impact recreation, and family bonding were rated as important to over 60 percent of the respondents. Highest rated activities in these areas included hiking, walking, hunting big game, berry picking and ATV riding.

The areas currently managed as a Semi-Primitive zone did have historic mining activity prior the 1980 Congressional designation. These areas were targeted for development in the Recreation Activity Management Plan (BLM 1986) to improve and sustain existing access routes and provide for a semi-primitive experience including OHV hunting opportunities, scenic qualities, recreational access to primitive areas and river put-in, wildlife viewing, and hiking opportunities. Since 1986 two campgrounds, a non-motorized hiking trail, a series of motorized summer and winter trails, recreational cabins, and river put-in have been established. These planned infrastructure developments have been entered into BLMs Facility Asset Management system and the BLM receives an annual budget for maintenance and program management.

The White Mountains NRA has quickly developed into an easily accessible recreation destination with a steady increase from 1,200 user days in 1986 to over 12,000 user days in 2011. The bulk of this visitor use increase is in the Semi-Primitive zones.

Very little historic mining occurred in areas currently managed for a primitive recreation experience. Any historic mining in the Primitive zone took place prior to the Congressional designation in 1980. Areas managed for a semi-primitive experience in the NRA have not seen mining activity for 20 years or more.

The anticipated continuous noise production for suction dredging is expected to occur up to four hours per day over a ten hour period in the same location. This continual noise could displace some recreation visitors anticipating a backcountry experience under the current recreation management classification. The RFD suggests that there would be 11 such leases. Lands immediately adjacent to the area recommended open for suction dredge leases are currently managed for primitive recreation setting. There are some large trees adjacent to the creeks in many areas that could dampen the noise levels and shield passersby from the undesirable experience.

The smell of exhaust from a continuously running engine associated with a suction dredge may impact some users by displacing them out of range of the exhaust fumes. Though similar to the exhaust fumes from an ATV, the exhaust smell from a stationary operation would not pass by the recreationalist, but creates a situation where the recreationalist has to displace their intended route to avoid the smell.

Buffers around BLM-maintained facilities (ROPs R-1 and R-2) would be implemented in areas of high and medium development potential (Figure M.1), the terrain is hilly, the trees are small or non-existent and sight distances can be miles long. Views of mining activity would be visible from ridge tops. The visual resource management ROPs would reduce visual impacts.

The Table Top Trail was designed as part of the White Mountains Gateway Project in 1987. It was designed to give non-motorized users a place to go in the midst of an area intensively managed for many uses, including various types of developed facilities including roads, OHV trails, and campgrounds. The trail crosses a ridge top with views to the ridgelines to both the north and south. Mining activity would be visible toward the north. Visual impacts may be mitigated with the ROPs.

Occupancy of mining equipment and related operations may impact as much as 0.2 acres of land for approximately 90 days per operation and impact some recreation users that would be displaced as far as necessary to be out of sight of the camp and out of audio range of the mining operation. This could potentially be miles away. Proper location of camps and staging areas could reduce this impact.

Occasional increases in turbidity levels occurred 30 to 50 miles downstream of active mining in Nome Creek (BLM 1988b, Webb 1982), a primary tributary of Beaver Creek WSR. It is conceivable to assume that new mining activities in Bear, Champion, Little Champion, Ophir, and Trail Creeks could produce similar increases in turbidity especially if mining activity was occurring on more than one creek at the same time, however under the current mining regulations, turbidity levels should be greatly reduced. All of the aforementioned creeks flow into Beaver Creek. Increased turbidity or muddy water, inherent with mining activities, would reduce the aesthetic appeal of Beaver Creek and negatively influence the floating experience by boat floaters (BLM 1983). The semi primitive recreation management zones are managed for naturalness including clear, free flowing streams with the appearance of being untouched and undisturbed by humans. Beaver Creek supports a popular grayling fishery. Fishing success would decrease in muddy water and displace some users. River hazards are more difficult to identify in muddy waters which increases floating difficulty.

Access routes to leases could benefit other users if trails were constructed in the proper locations and use sustainable trail construction techniques. Cross-country travel is allowed under alternative D, however, the addition of more concentrated routes with multiple passes over the same area would compact the soil and vegetation and create a permanent scar on the landscape. User-created trails or routes created by four-wheelers are not typically sustainable because they tend to go straight up and straight down hills, which creates a path for water to accelerate and intensify erosion. User-made trails deteriorate over time. They become difficult to travel and negotiate with an OHV. This can develop into a safety hazard. Roads and trails associated with mining operations are attractive to motorized recreation users. While contributing to greater access by the motoring public, it will also greatly expand the proliferation of user-made trails and multiple routes to the same location. The cumulative impact of such actions may result in increased costs for BLM administration of the recreation area and maintenance of new and unsustainable travel routes. These impacts may be mitigated during site-specific NEPA analysis when access routes for each exploration license or lease block is identified, and routed in the most appropriate location.

Mining activity is expected to occur adjacent to Backcountry and Semi-Primitive recreation management zones which are closed to the summer use of OHVs (April 15 through October 30). Mining access routes could attract more ATV users into these border areas where there is currently little to no motorized activity. Access into Bear and Quartz creeks, where suction dredge leasing would occur (and mechanized placer mining in Bear Creek), is generally on north facing slopes typical of black spruce forests and tussock tundra. These areas are underlain with permafrost near the surface and have slopes greater than 20 percent. These environmental conditions can be difficult obstacles for building trails or any kind of sustained access.

The Trail Management Objective (TMO) for managed OHV trails in the White Mountains NRA are for a type 2 semi-primitive motorized trail and describe access as “more difficult” with a tread width of 72 inches maximum and clearance width of 6 to 8 feet. The trails are not developed for access by vehicles other than ATVs and snowmobiles (generally 1,000 pounds or less curb weight and not exceeding 50 inches in width). Any mobilization of mining equipment on these trails would require the trails to be widened. A wider trail corridor could attract use of vehicles larger than allowed by current OHV regulations. Sixty-one miles of these trails are designed for winter use and are not maintained for summer use due to wet and boggy soil conditions. An increase in summer use on these little-used trails will have adverse effects on winter trails. Summer use causes rutting and erosion making winter trail maintenance difficult and reducing the quality of the trails for winter uses. Trail drainage structures currently in place would not accommodate larger vehicles.

The Quartz Creek Trail is a hardened, sustainable trail located in the area of high development potential and would be an attractive access route for mining activity. The trail is currently designed for a three-year maintenance schedule. With the anticipated increase in use, the maintenance schedule may have to be accelerated to every year. To date, there has been a significant investment of public funds into this trail, which would increase with additional maintenance needs.

According to the RFD (BLM 2012b) up to 20 miles of road could be considered for access into Bear and Quartz creeks. Up to 10 miles of road could be considered for access into Ophir Creek. Roads also attract a larger vehicle types not associated with the mining activity that are beyond the scope of the management objectives for travel management in the NRA. Larger vehicles (over 50 inches in width and greater than 1,000 pounds curb weight) would likely leave the road for cross-country travel and create some enforcement issues. Indirect effects from road construction include the reclamation of road beds after the life of the mine or the maintenance and redevelopment of sustainable road infrastructure by the BLM and would require additional expense and maintenance beyond the life of the plan.

Direct effects to recreation are expected to be short-term and could be mitigated through the ROPs or stipulations associated with NEPA analysis of each exploration or leasing action. The access needs and infrastructure associated with the mining activity will increase the proliferation of user-created trail networks in a heavily used area. The proximity to Fairbanks, growing popularity of the area, existing recreation facilities, layered with new user and travel access needs are expected to have a cumulative adverse effect on the administration of the recreation area.

The areas recommended open to mineral leasing through this supplement are within the current White Mountains caribou herd calving and postcalving area and the historic calving and postcalving range of the Fortymile caribou herd. Caribou are most vulnerable to disturbance during these periods. The area is also important current winter range for White Mountains and Fortymile caribou. The northern portion of the area, which includes the Roy Creek REE deposit and upper Bear and Quartz creeks placer gold, are current and historic high use calving and postcalving areas for both caribou herds. Dall sheep movement corridors and habitat are within and adjacent to the area proposed for hardrock mineral leasing. The area contains relatively high densities of moose during rut and winter seasons (October through April).

Fortymile caribou are among the most important subsistence resources in the planning area. As Yukon River salmon stocks decline, Fortymile caribou become increasingly important to subsistence users in and adjacent to the planning area. Research on land use patterns by rural residents indicates that residents of Birch Creek Village area moved seasonally into the White Mountains to harvest caribou and sheep (Caulfield 1983). Contemporary harvest data indicate little current use of White Mountains caribou and Dall sheep by rural subsistence hunters however use of these populations could increase in importance over the life of the plan and should not be discounted (Subsistence Resources, White Mountains Subunit, Draft RMP/EIS).

ROPs and stipulations developed in the draft RMP/EIS and Supplement (Appendix A) to mitigate the impacts of land use actions on subsistence wildlife resources would be attached as stipulations to the authorizing documents. Minimal direct impacts to subsistence wildlife resources or uses would occur from hardrock mineral leases and exploration licenses because no exploration activities would be allowed in Dall sheep habitat from May 10 through June 1 or in caribou calving and postcalving areas from May 15 through July 15. Exceptions would be allowed when it can be demonstrated that caribou or Dall sheep do not occupy the area (Table M.6, Stipulation 5). Therefore, no direct impacts on abundance of subsistence wildlife resources is expected from this plan decision.

Indirect impacts are expected to be greater and more difficult to mitigate. Increased access to largely remote wildlife habitat is expected to occur as roads to support placer mining are developed and areas cleared of vegetation for winter overland moves become used as summer OHV pioneered trails (section M.3.2.9 Recreation and Travel Management, of this appendix). The resulting increase in non-mining activities may reduce the suitability of the areas for calving and postccalving. Analysis of data on Fortymile caribou habitat condition indicates that current calving and postcalving range has been diminished from overgrazing and limited suitable habitat is available. The research indicates that this area of the White Mountains NRA will become increasingly important to continued growth and stability of the Fortymile caribou herd (Boertje et al. in press). Analysis of indirect impacts to Fortymile caribou from mineral leasing resulted in a finding of may significantly restrict subsistence use of Fortymile caribou (See the ANILCA Section 810 Analysis in Appendix B of this document for further analysis and findings.)

Some conflicts between hardrock-leasing related activity and federal qualified subsistence users may occur from mid-August through September and from November through March if exploration and placer mining is active during these time periods. Access by subsistence hunters may be restricted due to perceived or real barriers to wildlife resources. As a result, hunters may be displaced to other areas. When caribou are in the area during seasons open to hunting they are generally distributed over a wider area, thereby minimizing access issues for subsistence hunting. Moose are available through the greater area and much of the rural resident harvest of moose occurs away from the area open to hardrock mineral leasing, although distribution of moose hunters could change due to increased access into the area. Conflicts among hunters are not expected to be significant.

Ophir Creek, a tributary of Beaver Creek, has been identified as an area with high development potential for placer gold in Alternative D. Spawning areas for Chinook salmon have been identified within Ophir Creek. Because active mining is likely to occur in and adjacent to these spawning areas, direct impacts on this population are expected.

Indirect impacts to subsistence fish species and local water quality from mineral leasing may occur downstream due to turbidity, crossing of streams, high water events and occasional failure of settling ponds (sections M.3.2.4 Soil and Water Resources and M.3.2.2 Fish and Aquatic Species). These impacts are likely to be short-term. Regulations and ROPs that require recycling of turbid water through settling ponds and reclamation of disturbed stream channels should mitigate most of these impacts.

For subsistence fisheries resources, when analyzed with the cumulative case, impacts may incrementally contribute to the downward trend and resiliency of Yukon River Chinook salmon stocks. Chinook salmon are highly important subsistence species within the Yukon River drainage. The Alaska Board of Fish (Board) classified the Yukon River Chinook salmon stock as a stock of yield concern in 2000 (Howard et. al., 2009). Each regulatory cycle the Board reassesses the stocks and Yukon River Chinook salmon have remained a stock of concern as it continues to decline with lower returns each year and harvestable yields not being maintained. Genetic diversity of these small stocks, such as the Ophir Creek population, are extremely important for resiliency of the Yukon drainage stocks and are often overlooked in impact analysis (JTC 2012). Due to declines of the Yukon River Chinook salmon stock and the importance of Chinook salmon to Upper Yukon subsistence villages, analysis of Alternative D with the cumulative case has resulted in a finding of may significantly restrict subsistence use of Chinook salmon within the Upper Yukon River including and downstream from the village of Beaver.

The following discussion is based on gold mining activities likely to occur on land leased for placer or suction dredge mining (Stebbins 2009). Section 4.4.4.1.2 Fortymile Subunit, Effects from Locatable Minerals of the Draft RMP/EIS (BLM 2012a) outlines the Stebbins models for small- and large-scale placer mines, life of mines, and a background discussion of the types of economic impacts and is incorporated by reference.

Economists consider three categories of employment and income in considering the effect of an activity such as mining. These three categories are: direct employment and income, including only employees of mining companies; Indirect employment and income such as employees of businesses providing goods and services to mining companies: and, induced employment and income occurring when jobs are created as a result of spending of direct and indirect income attributable to mining activity. All employment and income shown in this analysis is estimated using input and assumptions from BLM reports (Stebbins 2009, BLM 2009) and McDowell reports (2006 and 2009).

Opening the identified lands in the White Mountains NRA to hardrock mineral leasing under Alternative D is predicted to result in large and small-scale placer mining operations. Small-scale placer mining uses a bulldozer, and excavator and a mobile wash plant to excavate and process gold-bearing gravel. In this model, a two-man crew works 12 hours per day, seven days per week, during a 130-day season. The camp includes one support person and a cook; a total of four workers. Eleven small-scale placer mines are forecast to operate with employment of about four workers each.

Large-scale placer operations utilize excavation equipment larger than the small-scale model. In this model, 2 two-man crews moving material each work a 10-hour shift, seven days per week, during a 130-day season. Five additional employees, including a supervisor, skilled workers, and laborers; a total of nine workers are included in the model. Assuming two large-scale placer mines, the resulting employment is about eighteen workers.

Suction dredging would occur on about 11 new leases. These would employ approximately two workers per operation, for all phases.

In addition, the BLM development scenario indicates approximately four licensed placer exploration efforts. These are included in direct income calculations show in Table M.3.

The total mining employment on BLM-managed lands would be estimated at 84 part-year workers. Data prepared by the State of Alaska uses full-time equivalents. The full-time equivalent in the White Mountain Subunit would be approximately 33 workers, based on the Stebbins (2009) models. Total employment by the Alaska minerals industry in 2008 was 3,392 full-time equivalent jobs (Szumigala et al. 2009). The statistics indicate less than one percent of the industry employment on BLM-managed lands would occur at White Mountain operations. The DGGS reported the average monthly wage for mining in Alaska during 2010 at $8,345. White Mountains gold mining operations account for approximately $3 million in wages, annualized. Jobs data indicates maximum level of effect predicted to occur during the life of the plan. Development scenarios used as the basis for analysis do not contain time lines for development. Mineral exploration licenses or leases may not be issued for years after the plan is completed.

The BLM plans to open 11,000 acres of known deposits at the headwaters of Roy Creek to mineral leasing and predicts that it will eventually issue competitive leases for deposits of certain rare earth elements under 43 CFR part 3500 on these lands. The lease is offered competitively and a royalty may result. The BLM will charge fair and reasonable rental, determined at the time of licensing or leasing. These rentals are exclusive of royalties.

Exploration activities could include mapping and drilling or trenching in the lease area over a five year period. Income effects would depend upon the size of the initial operation, which may begin with as few as three personnel plus a helicopter crew, all based off site. It is fair to assume the minimum cost of exploration over a 120 day period would average approximately $2,000 to $2,500 per day. This is $240,000 to $300,000 per season in overall cost. The cost is essentially field personnel, helicopter contract, and fuel. Part of this cost would be attributed to the Fairbanks economy. Beyond the initial exploration, expansion of activities may occur, including further drilling and delineation, and eventual mining operation. Additional NEPA analysis will be necessary on a case-by-case basis for the BLM decision to lease for production.

There are no special recreation permits in the area of likely mineral development. No impacts to commercial recreation permits are anticipated (section M.3.2.9). The likely economic effect in an area of little or no commercial recreational activity is zero.

Section M.3.2.10 Subsistence reports: "Contemporary harvest data indicate little current use of White Mountains caribou and Dall sheep by rural subsistence hunters however use of these populations could increase in importance over the life of the plan and should not be discounted (Subsistence Resources, White Mountains Subunit, Draft RMP/EIS)." Given that there is little or no documented subsistence use in the White Mountains NRA, an economic effect is unlikely.

Possible negative impacts to environmental justice populations and the entire population of the area include loss of employment in another existing industry due to mining development. However, there are no commercial activities in the area potentially opened to mining under Alternative D providing employment that will be affected. All populations may benefit from expanded recreation industry employment as well as mining employment within the White Mountains Subunit. This includes additional land outside of the White Mountains NRA.

Loss of subsistence resources or opportunity may be considered. However, the extent of subsistence use of the specific areas likely to be affected must be demonstrated before there is an attributable and measurable impact. Current data indicate little subsistence activity in these areas. The Fairbanks North Star Borough is also classified as a non-rural community as such, residents of the borough do not quality to fish or hunt under federal subsistence regulations.