AIR Responses and Attachments - WPPH by rPlusEnergies

White Pine Waterpower, LLC FERC Project No. 14851-003 April 28, 2023 Addi�onal Informa�on Request Responses FERC-A1-1

General Comments

The consultation record is incomplete. For instance, the record is missing some agency comments and correspondence that were provided to the applicant or to the project record, but do not appear to have been filed to eLibrary or included in Appendix A, Consultation Record of the FLA (e.g., BLM email dated December 15, 2020, noting a need for an EA due to the roads; meeting notes from the November 15, 2022 meeting of the Natural Resource Advisory Committee of White Pine County attended by Greg Copeland of rPlus Hydro, LLLP; BLM email dated November 18, 2022, indicating BLM cannot currently support a sitespecific amendment to the Record of Decision and Approved Resource Management Plan Amendments for the Great Basin Region, Including the Greater Sage-Grouse Sub-Regions of Idaho and Southwestern Montana, Nevada and Northeastern California, Oregon, and Utah. Washington, D.C. September 2015 and that other options should be evaluated; Park Service and Nevada Northern Railway (NNR) January 20, 2023 correspondence indicated “For the Record”; etc.). A copy of all correspondence provided by agencies to the applicant should be included in the consultation record. Please revise Appendix A accordingly so that staff has an accurate context for the agency’s concerns summarized in the table in Appendix A. Additionally, if agency comments were provided to the applicant and referenced in Appendix L, Response to Comments on the Draft License Application, but were not filed to eLibrary or were not included in Appendix A, Consultation Record, please revise Appendix A accordingly so that staff has an accurate context for the agency’s concerns summarized in the comment/response table in Appendix L. Response As part of the response to FERC’s deficiency issued on April 28, 2023, the applicant revised the consulta�on record to include missing copies of correspondence documented in the consulta�on log. This consulta�on record was filed with FERC on June 12, 2023, and is available on FERC’s e-library. For FERC’s ease of reviewing, the applicant is refiling a full version of the consulta�on record. This is included as Atachments 1-1,1-2,1-3, and 1-4. Regarding the examples of missing correspondence listed above, the applicant notes the following: • •

•

The applicant added the BLM email dated December 15, 2020, to the consulta�on record. Mee�ng notes from the November 15, 2022, mee�ng of the Natural Resource Advisory Commitee of White Pine County have been added to consulta�on log. In addi�on, the applicant has included the mee�ng agenda in the consulta�on record. The applicant added the BLM leter dated November 18, 2022, to the consulta�on record. Note that the applicant revised the consulta�on log to reﬂect this correspondence as a leter rather than an email. The applicant included the NPS and NNR email dated January 20, 2023, in the consulta�on record.

Comments provided to the applicant and referenced in Appendix L, Response to Comments on the Draft License Application, are included in Appendix A (Consulta�on Record) of the Final License Applica�on.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 1

FERC-A1-2

General Comments

The FLA states that the project is located outside of the coastal zone and that consistency with the Coastal Zone Management Act (CZMA) is not applicable. However, no documentation is provided to support this statement. Please file documentation from the State of Nevada confirming that a CZMA consistency determination is not needed for the project. Response As provided in Atachment 2-1, 2-2, and 2-3, the applicant sent a leter to the Nevada Department of Environmental Protec�on (NVDEP) at the address listed below via cer�fied mail on June 27, 2023, reques�ng confirma�on that the State of Nevada does not have a coastal zone management program and the project does not require a Coastal Zone Management Area Consistency Determina�on. On July 16, 2023, the applicant called the NVDEP and emailed Dave Simpson reques�ng response to the Coastal Zone Management Consistency Determina�on leter. The applicant received a response, on July 17, 2023, from the NVDEP confirming that the State of Nevada does not have a coastline or a coastal zone management program. Nevada Division of Environmental Protec�on 901 S. Steward Street, Suite 4001 Carson City, Nevada 89701

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 2

FERC-A1-3

General Comments

The FLA states that the project will not involve discharge into navigable waters and therefore a 401 Water Quality Certification (WQC) will not be required. On March 15, 2023, rPlus Hydro, LLLP filed a copy of correspondence from the Nevada Division of Environmental Protection (NDEP) regarding 401 WQC requirements, in which NDEP indicates that a 401 WQC is not likely to be required for the project but that it recommends the project applicant consult with the U.S. Army Corps of Engineers to determine whether waters of the U.S. (WOTUS) are present within the proposed project area to determine if a Section 404 permit for the project will be required. Please consult with the U.S. Army Corps of Engineers to acquire an Approved Jurisdictional Determination and a determination letter that indicates whether a Section 404 permit would be required, and file both in the revised FLA. Response The applicant is consul�ng with the U.S. Army Corps of Engineers (USACE) regarding an Approved Jurisdic�onal Determina�on for applicability of 404 permi�ng for the Project. At this �me, the USACE has communicated to the applicant that it has put a hold on any jurisdic�onal determina�ons as a result of the recent Supreme Court ruling on May 25, 2023, in Sackett v. EPA. Agencies are developing a rule to amend the final “Revised Defini�on of ‘Waters of the United States’” rule, consistent with the US Supreme Court’s May 25, 2023, decision. The agencies intend to issue a final rule by September 1, 2023. At which point, the applicant will con�nue to pursue an Approved Jurisdic�onal Determina�on with USACE to confirm that a Sec�on 404 permit will not be required. Please see link below to USACE’s website for further informa�on: htps://www.usace.army.mil/Media/Announcements/Ar�cle/3440421/27-june-2023-update-supremecourt-ruling-in-sacket-v-environmental-protec�on/

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 3

FERC-A1-4

General Comments

Many map figures throughout Exhibit E show a "project footprint" and the proposed location of aboveground project facilities, but do not show the proposed project boundary and proposed location of the underground project facilities, which would be encompassed by the project boundary. Section 4.41(h)(2) of the Commission’s regulations indicate that project boundaries enclose the project works that are to be licensed and include land necessary for operation and maintenance of the project and for other project purposes. Please modify and re-file all map figures that do not already show the proposed project boundary and the location of underground project facilities encompassed by the project boundary. If the "project footprint" is dissimilar from the proposed project boundary, please explain what the difference is and differentiate both on the map figures using two different colored lines. Please correct the third footnote to Table 3.2-1 Geographic Scope by Resource for Cumulative Effects Associated with the White Pine Pumped Storage Project, to indicate that the project boundary is the permanent operation boundary, including underground works. Response The applicant is providing revised Exhibit E figures in Atachment 4-1, with two differen�a�ons: i) indicated between the project footprint, and project boundary, and ii) underground project facili�es included within the project boundary. As noted in Exhibit E, Sec�on 1 of the FLA and consistent with Sec�on 4.41(h)(2) of the Commission’s regula�ons, the project boundary incorporates all lands required for project opera�ons and maintenance. The project footprint includes both the project boundary and temporarily disturbed areas associated with project construc�on. Addi�onally, the applicant provided below a revised Table 3.21 with an updated second footnote and a corrected third footnote indica�ng that underground works are included in the project boundary.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 4

Revised Table 3.2-1. Geographic Scope by Resource for Cumulative Effects Associated with the White Pine Pumped Storage Project

Resource

Geographic Scope

Justification

Geologic and Soil Resources

Project Footprint*

Effects on soils and surficial geology generally will be localized and confined to the area of direct disturbance associated with the Project.

Water Resources

HUC-12 watersheds in which the Project is located

Watersheds are natural, well-defined boundaries for surface water flow, and commonly contribute to the recharge of groundwater resources. Effects on water resources could extend throughout a HUC-12 watershed.

Fish and Aquatic Resources

HUC-12 watersheds in which the Project is located

Consideration of effects within a HUC-12 watershed sufficiently accounts for effects on fish and aquatic resources that could be directly affected by construction activities and for indirect effects such as changes in habitat availability and displacement of transient species.

Botanical Resources

Project Footprint

Similar to soils, effects on vegetation (including special status species) generally will be confined to the area directly affected by construction activities. Exceptions are noted.

Wildlife Resources

HUC-12 watersheds in which the Project is located

Consideration of effects within a HUC-12 watershed sufficiently accounts for effects on wildlife (including special status species) that could be directly affected by construction activities and for indirect effects such as changes in habitat availability and displacement of transient species. Potential for exceptions based on cumulative effects are noted.

Recreation

Within 1 mile of Project Footprint

Potential effects on public recreation will generally be restricted to the area within and up to 1 mile from the construction workspaces.

Land Use

Within 1 mile of Project Footprint

Absent special circumstances, effects on general land uses could occur within and up to 1 mile from the construction workspaces.

Cultural Resources

Area of Potential Effect (APE)**

Cultural resources could be affected by disturbance within the Project Footprint and Project O&M activities, and other project effects could cause changes in the character or use of historic properties in areas outside the Project Footprint (see Section 3.10.1.2).

Aesthetic Resources

Area where the Project would be visible

Assessing the effect based on the viewshed allows for consideration of other features that could have an effect on visual resources.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 5

Resource

Geographic Scope

Justification

Socioeconomic Resources

White Pine County, NV

Most socioeconomic effects will occur in the county in which the Project will be located and where most workers are expected to reside during construction and operation of the Project (i.e., White Pine County). White Pine County will experience the greatest effects associated with employment, housing, public services, transportation, traffic, property values, economy, and taxes.

Environmental Justice

The area encompassed within a 5-mile buffer of the proposed Project Boundary***

FERC specified the 5-mile buffer of the proposed Project Boundary as the geographic scope of analysis for environmental justice in its comments on the DLA. The geographic scope of potential effects for environmental justice generally captures the potential effect areas for resources that are linked to environmental justice impacts such as noise, aesthetics, traffic, and water resources.

* The Project Footprint encompasses the area needed for construction workspace and includes the footprint of the permanent facilities. ** The APE for the Project had not yet been determined at the time of FLA filing. In the April 28, 2023, Deficiency of License Application and Additional Information Request issuance, FERC staff deemed the proposed Project Footprint as the APE for direct, project-related adverse effects, and a one-mile buffer beyond the proposed Project Footprint as the APE for all potential indirect project-related effects. *** The Project Boundary is the permanent operational boundary, including underground works.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 6

FERC-A1-5

Initial Statement and Exhibit A

Section 1.3, Existing Facilities and Infrastructure, states that White Pine proposes to consult with the NNR about an additional track crossing on the surface to facilitate heavy vehicle access for project construction. However, the FLA does not describe where existing track crossings are located and what, if any, improvements would be necessary to facilitate project construction-related traffic at these crossings. Please describe, in detail, the improvements that would be necessary to facilitate project constructionrelated traffic at existing crossings. Response The project will establish a new single crossing of the inac�ve Mainline and two new crossings of the HiLine. These loca�ons are marked on Exhibit F submited with the FLA February 27, 2023 (See Exhibit F Design Drawing No. F-104). In accordance with US Department of Transporta�on (USDOT)/Federal Railroad Administra�on (FRA) regula�ons and guidelines, these new crossings would include, as a minimum, the following improvements to facilitate project construc�on and opera�ons traffic at all crossings (See Exhibit F Design Drawing No. F802): 1. Grade crossing signals on each approach including flashing red-light gate, 2. Graded approaches to ensure level approaches to the track and track surface panels, and 3. Railroad pavement marking symbols.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 7

FERC-A1-6

Initial Statement and Exhibit A

Section 1.3, Existing Facilities and Infrastructure, states that the currently inactive NNR Mainline could be reactivated in the coming years but does not describe the rail use that would or could occur on this line. Please clarify whether the rail traffic on this line would only be for NNR-run trains or if other passenger or freight rail operate on this line. Response The Mainline track adjacent to the Project is inac�ve and in disrepair. The NNR has stated that it has received funding and intends to rehabilitate and reopen the Mainline in the future. Following this, the NNR has indicated that it intends to transfer some of its current rail excursion rides from other routes that are distant from the project boundary, to the Mainline. Addi�onally, in March 2023, the NNR publicly stated that it has par�cipated in mul�ple studies to develop the railroad, and the Mainline, for commercial traffic and that it is working with the City of Ely to apply for a Consolidated Rail Infrastructure and Safety Improvements Program grant in December of 2023. Other than these statements, the applicant has not been provided by the NNR and is not aware of the NNR’s specific plans, intended uses, or schedule for the inac�ve Mainline. The applicant is not aware of any publicly available sources that would provide addi�onal informa�on regarding the NNR’s intended future use for the inac�ve Mainline, its construc�on schedule, what type of rail traffic will be opera�ng on it and how o�en, or who will operate it, should the reac�va�on occur.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 8

FERC-A1-7

Initial Statement and Exhibit A

Section 1.3, Existing Facilities and Infrastructure, indicates that existing power lines will be required to be rerouted and upgraded because of proposed project facilities and that details of the reroutes and upgrades will be developed with the utility owners during the FLA. For Commission staff to effectively analyze project effects on resources, details of the reroutes and upgrades must be provided. Please file these details in the revised FLA. Response The proposed route for the reloca�on of the exis�ng 69 kV transmission line is west of the lower reservoir as shown in Figure 7-1. The new route will require approximately 15 new structures of similar height, span width, and configura�on (monopole construc�on) as the exis�ng 69 kV line and will be subject to further consulta�on with the BLM and with Mt Wheeler Power, Inc. The proposed route will relocate the exis�ng 69 kV line further away from the NNR HiLine, align it adjacent to an exis�ng distribu�on line corridor and reduce the visual disturbance in the immediate vicinity for riders on the NNR HiLine excursion trains. Figure 7-1: Proposed route for relocation of the 69kV existing power line

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 9

FERC-A1-8

Initial Statement and Exhibit A

Section 1.3, Existing Facilities and Infrastructure, states that no provisions have been made to reroute any unoﬃcial unpaved roads or tracks, except for the ridge road that will be rerouted to bypass construction and permanent facilities as shown on Figure 1.0-1. However, Figure 1.0-1 does not appear to identify the ridge road and it does not indicate the current location or proposed relocation of the road. Please modify Figure 1.0-1 and all other applicable maps to identify current location and proposed relocation of the ridge road. Also, please describe in detail the characteristics of the ridge road including, but not limited to: (a) its dimensions; (b) the road surface and other materials it is constructed of; (c) the landowner(s) of the land on which the road is located; and (d) who or what entity currently maintains the road. Response Figure 1.0-1 in Exhibit A is provided to illustrate the permanent facili�es needed for opera�on. The ridge road is an exis�ng unpaved road and is not used for opera�on, therefore it is not included in Figure 1.0-1. The length of the ridge road re-rou�ng is approximately 1,600 � and would not be clear at the scale of Figure 1.0-1. However, the re-rou�ng of the ridge road is shown in Exhibit F (See Exhibit F, Design Drawings, F-803) and reproduced below in Figure 8-1. All other exis�ng roads are shown in Exhibit F (See Exhibit F, Design Drawings, F-104). Figure 8-1: Existing Ridge Road (Blue) and Rerouting (Red) as shown in Exhibit F-803

The rerouted ridge road will be equivalent to the characteris�cs of the exis�ng ridge road (see Figure 8.2) as follows: a. The exis�ng ridge road is an unpaved track approximately 8� wide with surface characteris�cs suitable for only 4WD or oﬀ-road vehicles. The exis�ng ridge road is en�rely on BLM land and is not ac�vely maintained. b. The rerouted ridge road will similarly be a single-lane unpaved track with surface characteris�cs suitable for only 4WD or oﬀ-road vehicles and will be constructed with minimal grading of the exis�ng ground. The alignment of the rerouted ridge road will follow the exis�ng general topography. c. The sec�on of the ridge road that will be rerouted is on BLM land and will not be maintained.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 10

Figure 8.2: Existing Ridge Road at the approximate location of the re-routing

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 11

FERC-A1-9

Initial Statement and Exhibit A

Section 1.3, Existing Facilities and Infrastructure, states that NV Energy will design and construct a new bay at the Robinson Summit Substation. However, it is unclear exactly where the new bay would be located. Please revise the FLA to indicate if this new bay would be constructed within the existing footprint of the Robinson Summit Substation, and if not, where it would be constructed in relation to the substation. Please also indicate who would own and maintain the new bay. Response In accordance with the Large Generator Interconnec�on Agreement, dated 2/13/2022, between the applicant and Nevada Energy, Inc. (NVE), the applicant will fund and NVE will construct the new bay within the footprint of the exis�ng Robinson Summit Substa�on. The new bay will connect in the center of the North 345 kV Bus, just to the East of the exis�ng 345 kV Bays. The proposed loca�on is shown on the Transmission Plan and Proﬁle drawings in Exhibit F (See Exhibit F, Drawing F-705). The transmission provider, NV Energy, will own and maintain the new bay and interconnec�on facili�es.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 12

FERC-A1-10

Initial Statement and Exhibit A

Section 2.4.2, Lower Reservoir Inlet/Outlet Structure, states that the lower reservoir intake/outlet structure is approximately 92.5 feet wide and the structure subdivides the ﬂow between four rectangular openings, each with dimensions of 26 feet by 20 feet. However, it is not clear which dimension, 26 feet or 20 feet, is the width of each rectangular opening. Assuming the width of each rectangular opening is 26 feet wide, then the total width of all four rectangular openings is 104-feet-wide, whereas if the width of each rectangular opening is 20 feet wide, then the total width of all four rectangular openings is 80 feet wide; neither of which is equivalent to 92.5 feet. Please revise the FLA to (a) identify the width of each of the four rectangular openings and (b) clarify the apparent discrepancy that the total width of all four rectangular openings does not equal 92.5 feet. Response The applicant is providing the following addi�onal informa�on to clarify any discrepancy on the dimensions of the Lower Reservoir Inlet/Outlet Structure. The Lower Reservoir Inlet/Outlet structure divides the ﬂow between four equal rectangular openings. The dimensions provided are internal hydraulic dimensions that do not include the substan�al concrete dividing or external walls. Addi�onally, the openings are splayed radially to improve hydraulics so will have a wider screen area than the overall width of the structure. This is illustrated in Exhibit F (see Exhibit F, Design Drawings F-306) and below in Figure 10-1. a) Dimensions of rectangular openings i) Width of the rectangular openings (inside dimension) is 20 �. The width of four openings is 80 �. ii) Height of the rectangular openings (inside dimension) is 26 �. iii) Width of the internal walls is 3 � each. Three internal walls and two external add to 15 �. iv) Total width of these openings in a straight line would be 80 � plus 15 � or a total of 95 �. b) However, the four intakes are not parallel but splayed 15 degrees each so the total width of the structure is 92.6 � - slightly below the expected 95 �. Figure 10-1: Intake opening plan dimensions.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 13

FERC-A1-11

Initial Statement and Exhibit A

Exhibit A, Table 2.1-6. Pump-Turbine and Generators indicates that the rated power of each turbine would be 340 megawatts. However, Exhibit A, section 2.8.1 Pump-Turbines, indicates the rated power of each pump turbine would be 333 megawatts. Please revise the FLA to explain this discrepancy and provide a correction if necessary. Response In Exhibit A, Table 2.1-6 refers to Turbine (sha�) Power. The turbine is rated to deliver 340MW of sha� (mechanical) power and assuming that the generator is 98% eﬃcient, this translates to 333MW electrical output at the generator terminals. For the generator itself, for a power factor of 0.95 the megavolt-ampere (MVA) generator capacity is then 333/0.95 = 350 MVA. Sec�on 2.8.1 discusses the Pump-Turbines, and the applicant has edited this sec�on to remove the reference to rated output to avoid confusion: “The three 333-MW (rated output power at rated power factor) variable speed reversible Francis-type pump-turbines are tentatively proposed to provide a total of 1,000 MW of generating power and pumping load. The rated head for each unit (in generating mode) is approximately 2,034 feet, resulting in approximately 2,143 cubic feet per second (cfs) ﬂow at full generating power and 1,593 cfs at full pumping power. Pump-turbine performance and dimensions are based on information supplied by reputable manufacturers (i.e., Voith, Andritz, and GE). The pump-turbine centerline will be set at El. 6,043 ft, which is 312 feet below the minimum operating level of the lower reservoir. The maximum spiral case width is 32 feet, 6 inches and the runner diameter is 13 feet, 6 inches”.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 14

FERC-A1-12

Initial Statement and Exhibit A

Section 2.10.1 Underground Cables, states that nine high-voltage 345-kilovolt generator-motor conductor cables, three medium-voltage underground power cables, and one underground ﬁber-optic cable will be conveyed from the unit transformers in the transformer cavern through to the cable tunnel portal where the cables will then be buried in a duct bank between the portal and the outdoor switchyard where they will terminate. Although the FLA provides a description for the types of cables, it does not provide the lengths of each type of cable nor does it provide the voltage capacity of the three medium-voltage cables. Please revise the FLA to provide the voltage capacity of the three medium-voltage cables and the lengths of each type of cable that would be installed in the cable tunnel and the lengths of each type of cable that would be installed in the duct bank. Please revise the FLA to specify if cables of one type would be varying lengths (i.e., if one 345-kilovolt cable would be a diﬀerent length than the other 345-kilovolt cables) and provide those lengths. Response The voltage capacity of the medium voltage cables is 34.5 kV. The lengths of each type of cable and their voltage capacity are summarized in Table 12-1 below. The cables travel down the length of the cable tunnel mounted to the tunnel wall then transi�on into an underground bus duct near the tunnel portal. The same cables are pulled from the Powerhouse to the switching sta�on without a change in cable type. Table 12-1:

Underground Cable Summary

Cable

Voltage

Circuits

No. Cables

Cable Length Total Length

High Voltage

345 kV

5,250 ft

47,250 ft

Medium Voltage

34.5 kV

5,750 ft

17,250 ft

6,000 ft

Fiber Optic

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 15

FERC-A1-13

Initial Statement and Exhibit A

Exhibit A, Table 2.1-9 Power and Transmission, indicates that transmission line structures would typically be 125-feet-tall. However, Exhibit A, section 2.10.2 High Voltage Transmission Line, indicates that transmission line structures would be up to 150-feet-tall. Please revise the FLA to address this apparent discrepancy. Response The average height of the transmission structures is 125 feet, however, where necessary to accommodate changes in terrain, the tallest structure is 150 feet above grade. These structures will be similar in design and height to the exis�ng Nevada Energy structures of the Robinson Summit to Gondor 345 kV Transmission Line they parallel. A corrected Table 2.1-9 is shown below: Table 13-1:

Transmission Structure Characteristics

Characteris�c

Detail

345-kV Switchyard

345-kV collec�on bus with three 345-kV collec�on breakers and one 345-kV line breaker

Transmission Line

25 miles of 345-kV lines

Transmission Line Structures

114 structures, ranging from 125 � to 150 � tall.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 16

FERC-A1-14

Initial Statement and Exhibit A

Section 2.10.2 High Voltage Transmission Line, states that "an additional high-speed communications path, if required, [would] be provided by [optical ground wire] on a separate line... installed as under-build, or a separate underground fiber-optic cable, or a combination of these to create the path". Please revise the FLA to describe the following: (1) how and when the use of an additional high-speed communications path would be determined; (2) whether the optical ground wire would be co-located on the planned new transmission line structures or would be installed on its own structures; (3) how the determination would be made to use a separate underground fiber-optic cable or combination of the two; and, (4) how, if determined it was needed, the separate underground fiber-optic cable would be installed and if it would be installed entirely within the proposed 160- to- 250-foot-wide transmission line ROW. Response The final routes and installa�on of the first and second fiber-op�c cables will be determined during later design phases. The currently proposed routes are described as follows: 1. Two geographically diverse and redundant high speed communica�on paths for protec�on purposes are required in accordance with the Large Generator Interconnec�on Agreement (LGIA), dated 2/13/2022 between the applicant and Nevada Energy, Inc. 2. An Op�cal Ground Wire, OPGW, will be installed on the new Genera�on Transmission Line structures as the primary means of communica�ons. 3. The applicant will provide secondary means of communica�ons by adding new fiber op�c communica�ons cables to the new distribu�on line providing sta�on power to the Genera�on facility, and then u�lizing joint use communica�on conductors on exis�ng transmission lines or as a new overhead or underground fiber op�c line, as necessary, to connect with the Robinson Summit Substa�on.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 17

FERC-A1-15

Initial Statement and Exhibit A

Section 2.10.3, Low-Voltage Distribution Line, makes three references to a "switching station", however, the remainder of Exhibit A does not reference a "switching station" when discussing electric power transmission. Please revise the FLA to address this discrepancy and revise subsection 2.10.3 if necessary to comport with the language used throughout the rest of Exhibit A. Response The applicant intended the terms ‘switching sta�on’ and ‘switchyard’ to refer to the same project facility referenced in Exhibit A, Sec�on 2.10.1 Underground Cables, and Sec�on 2.10.2 High Voltage Transmission. The applicant has removed the use of the term “switching sta�on” from Exhibit A, Sec�on 2.10.3 and replaced it with ‘switchyard’ as shown below. “Exhibit A, 2.10.3 Low-Voltage Distribution Line In order to provide back up control power to the switchyard and the powerhouse, a 24.9 kV distribution line will be constructed from the switchyard to the nearest existing distribution line. Upgrades to the existing distribution line may be required if it is inadequate for the additional loads. A direct source of power may be available by distribution line from the Gonder Substation. A transformer will be installed at the switchyard to transform the power from local distribution standard levels to 35 kV for the powerhouse requirement. Power will be delivered from the switchyard to the powerhouse by an underground power distribution line.”

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 18

FERC-A1-16

Initial Statement and Exhibit A

Exhibit A, Table 2.1-7 Access Tunnels states the main access tunnel would be 5,108 feet long. However, Exhibit A, section 2.11, Access and Cable Tunnels, states the main access tunnel would be 4,290 feet long. Please revise the FLA to address this discrepancy and revise subsection 2.10.3 if necessary. Response The Main Access Tunnel (MAT) extends from the portal entrance to the powerhouse cavern providing access to the tailrace tunnel and transformer cavern along its length. The total length of the main access tunnel is 5,108 �. • • •

The length of the main access tunnel from the portal entrance to the point the tailrace access tunnel connects is 4,290 �. The length from the tailrace access tunnel to the transformer cavern the 701 feet. The por�on of the tunnel connec�ng the transformer and powerhouse cavern is 117 feet.

Exhibit A, Sec�on 2.11 ﬁrst paragraph is revised as follows: "The primary access to the powerhouse and transformer caverns will be from the main access portal via the 5,108-ft-long, shotcrete-lined main access tunnel, which will also serve as the primary route to transport the largest pieces of equipment (transformers) down into the transformer and powerhouse cavern."

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 19

FERC-A1-17

Initial Statement and Exhibit A

Section 2.11, Access and Cable Tunnels, states that several construction-access tunnels would be built to support construction of the proposed underground facilities and that some of the tunnels would be retained to provide access and emergency egress during project operation. However, the FLA does not specify the number of tunnels or other information regarding the tunnels. Therefore, please provide the following information: (a) the total number of construction-access tunnels proposed to be constructed; (b) the number of tunnels proposed to be retained for future access to underground project facilities; (c) the number of tunnels proposed to be plugged along with descriptions of how and when the tunnels would be plugged (e.g., materials); and (d) the approximate dimensions, lining, and appurtenant features of all proposed construction-access tunnels. Response Informa�on including plan alignments and cross sec�on details on these tunnels is included in Exhibit F and is referenced in the responses below. (a) A total of six construc�on-access tunnels are proposed to be constructed (See Exhibit F drawing F-605). (b) Four construc�on-access tunnels are proposed to be retained for future access to underground project facili�es for periodic inspec�ons and maintenance. (c) Two construc�on-access tunnels (the tailrace and headrace access tunnel) are proposed to be plugged by a 30 � concrete plug with secondary void grou�ng where they provided access for waterway construc�on. Grout curtains in these areas may be required depending on the specific geological condi�ons encountered. Details of these plugs and grou�ng requirements will be addressed during final detailed design (See Exhibit F drawing F-605) (d) Construc�on access tunnels are either 16 � or 24 � internal diameter and are unlined (no secondary lining). However, the an�cipated rock support for these tunnels will include a 6-inch fibre reinforced shotcrete and 2-inch plain shotcrete full perimeter primary lining and a 1 � 2 in thick cast in place reinforced slab (See Exhibit F drawing F-606)

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 20

FERC-A1-18

Initial Statement and Exhibit A

Section 3.0 Project Access Roads, states that the locations of access roads, as currently proposed, could be changed at any time while the Commission staff reviews the application. For staff to effectively analyze potential project effects to environmental resources caused by construction and/or use of any proposed access roads, and appropriately condition any potential license that might be issued for the project, the final proposed locations of all current and potential/alternative access roads must be provided. Response The applicant confirms that the access roads shown in Exhibit F (See Exhibit F, Design Drawings F-104) are in their final proposed loca�ons including the upper reservoir access road and the upper reservoir op�onal access road.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 21

FERC-A1-19

Initial Statement and Exhibit A

Section 3.1 Western Access Road, states that construction and operational access to the main access portal will be provided from US-93 via the 1.7-mile-long permanent, paved, dual-lane western access road. Exhibit G appears to show the following related to the proposed western access road: (a) the project boundary encompassing less than 1 mile of the existing US-93 and (b) the project boundary encompassing about 1 mile of unknown, existing roadway that leads from US-93 towards the proposed lower reservoir location; for a total of about 2 miles of roadway. Although aerial imagery indicates US-93 is paved it does not show that the unknown roadway is paved, rather it appears to be an unimproved, unpaved track. Please revise the FLA to clarify this apparent discrepancy. Response The Western Access Road referred to Sec�on 3.1 will be a newly constructed, paved, dual-lane access road. Regarding the following areas of Exhibit G: a) The por�on of the boundary that encompasses a sec�on of the exis�ng US-93 covers limited widening of this road to support an intersec�on with the new Western Access Road. b) The project boundary leading from US-93 to the lower reservoir covers approximately 1 mile of the new western access road as noted. The remainder of this access road con�nues to the east to provide access to the tunnel portals and is included in the project boundary. Exhibit G Maps have been re-issued at a larger scale with the Western Access Road now clearly shown (See Atachment 19-1, Exhibit G, Map G9 and G10)

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 22

FERC-A1-20

Initial Statement and Exhibit A

Section 3.2, Upper Reservoir Access Road, states that access to the proposed upper reservoir, and associated other proposed project facilities, will be by the 7-mile-long, permanent, paved, dual-lane upper reservoir access road. This appears to indicate that a road currently exists that would be used as the project’s upper reservoir access road; however, it is unclear if a road currently exists. Please revise the FLA to clarify if a road currently exists that would be used as the upper reservoir access road or if no road currently exists and the upper reservoir access road would need to be constructed. Response The 7-mile-long, permanent, paved, dual-lane upper reservoir access road referred to in Sec�on 3.2 does not currently exist. This road will be a new construc�on. The upper reservoir op�onal access road also does not currently exist and would need to be constructed. Both the upper reservoir access road and the upper reservoir op�onal access road Aare encompassed by the project boundary shown in Exhibit G (See Atachment 19-1, Exhibit G, Map G10, G11, and G13). Revised Sec�on 3.2 text has been provided below to clarify the intent: “Access to the upper reservoir perimeter and crest roads, the upper reservoir laydown and staging areas, and the upper reservoir well will be by a proposed new 7-mile-long, permanent, paved, duallane upper reservoir access road traversing the Steptoe Valley from a tie-in along the western access road at Station 16+00, about 0.3 mile from US93. The proposed new upper reservoir access road will also cross the active HiLine track of the Nevada Northern Railway further to the south. An alternative access to the upper reservoir from the Duck Creek side, referred to as the upper reservoir optional access road is proposed as a new 3.5-mile, improved, gravel, single-lane access road for optional and/or emergency use that will traverse the Duck Creek range and would cross the Duck Creek from a tie-in along the White Pine County Road 29 (NV-486).”

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 23

FERC-A1-21

Initial Statement and Exhibit A

Section 3.2, Upper Reservoir Access Road, states that a proposed alternative access to the upper reservoir, referred to as the upper reservoir optional access road, is still under consideration. Please revise the FLA to describe how and when the need for this proposed alternative access road would be determined. Response Revised Sec�on 3.2 text has been provided to clarify the intent: “Access to the upper reservoir perimeter and crest roads, the upper reservoir laydown and staging areas, and the upper reservoir well will be by a proposed new 7-mile-long, permanent, paved, duallane upper reservoir access road traversing the Steptoe Valley from a tie-in along the western access road at Station 16+00, about 0.3 mile from US93. The proposed new upper reservoir access road will also cross the active HiLine track of the Nevada Northern Railway further to the south. An alternative access to the upper reservoir from the Duck Creek side, referred to as the upper reservoir optional access road is proposed as a new 3.5-mile, improved, gravel, single-lane access road for optional and/or emergency use that will traverse the Duck Creek range and would cross the Duck Creek from a tie-in along the White Pine County Road 29 (NV-486).”

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 24

FERC-A1-22

Initial Statement and Exhibit A

Section 3.3, Wellfield Conveyance Access Road, states that the 3.2-mile wellfield conveyance access road will provide permanent access to the groundwater wells. This appears to indicate that a road currently exists that would be used as the project’s wellfield conveyance access road; however, it is unclear if a road currently exists. Please revise the FLA to clarify if a road currently exists that would be used as the wellfield conveyance access road or if no road currently exists and the wellfield conveyance access road would need to be constructed. Additionally, Table 2.1-8 does not include details of this access road and Exhibit G, Map G5 does not appear to show this access road. Please revise Table 2.1-8 to include details of this access road and modify Exhibit G, Map G5, and any other maps throughout the FLA on which this road should appear, to show this access road. Response The proposed 3.2-mile wellfield conveyance access road does not currently exist and will need to be constructed. Table 2.1-8 is revised below to include this Wellfield Conveyance Access Road. The applicant has reissued Exhibit G Maps at a larger scale with the Wellfield Conveyance Access Road now clearly shown (See Atachment 19-1, Exhibit G, Map G9 and G12). Revised Table 2.1-8: Access Roads Characteristic

Length

No. of lanes / Pavement Width

Western Access Road

9,008 �

2 lanes/ 30 �

Wellﬁeld Conveyance Access Road Lower Reservoir Perimeter Road

37,190 � 4,872 �

1 lane / 20 � 1 lane / 20 �

Switchyard Access Road

572 �

1 lane / 20 �

Upper Reservoir Access Road

37,300 �

2 lanes/ 24 �

Upper Reservoir Perimeter Road

6,200 �

1 lane / 20 �

Upper Reservoir Op�onal Access Road

18,867 �

2 lanes / 24 �

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 25

FERC-A1-23

Initial Statement and Exhibit A

Section 3.5, Other Access Roads, indicates that an access plan, for accessing sections of the proposed transmission line ROW, would be developed with contractors and in consultation with affected landowners. However, without this plan, staff would be unable to determine possible environmental impacts from access to the transmission line ROW. Please clarify how the plan will be developed in consultation with affected landowners and when the plan will be filed with the Commission. Additionally, considering the other proposed project access roads that would be used to access all other project facilities aside from the transmission line ROW, and the proposed use of existing roads to access other project facilities, please clarify if the access plan will be developed in consultation with affected landowners through whose land these other proposed access roads and existing roads are located and state when such consultation would occur. Please consult with BLM and other landowners that may be affected by this plan in preparing the response and provide a record of the consultation. Response Most of the proposed transmission line ROW is immediately adjacent to an exis�ng Nevada Energy, Inc. (NVE), transmission line ROW that includes both public and private lands. Access to the proposed transmission line ROW for construc�on and opera�onal service will be via exis�ng NVE transmission line maintenance roads. The applicant has previously surveyed the proposed transmission line ROW for environmental and cultural impacts and has included the public lands associated with the proposed transmission line ROW in its applica�on for BLM Right-of-Way Grant and Land Use Permit (SF-299). The applicant has iden�fied the access roads within the ROW on the updated Exhibit G Maps (Atachment 191, Exhibit G, Maps G1 through G9). The applicant will develop, in conjunc�on with its building contractor, the referenced access plan during the project’s final detailed design The means and methods for the construc�on of the proposed transmission line will also be determined at that �me. The applicant has consulted with and will con�nue to consult with private landowners and BLM on land easements and/or ROW agreements for the yet to be finalized access roads that will be determined as a result of the final detailed design process. For all other facili�es, the applicant will construct new access roads as laid out in the updated Exhibit G Maps and encompassed by the project boundary.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 26

FERC-A1-24 Initial Statement and Exhibit A Section 4.1, Spoil Disposal, states that additional areas adjacent to the proposed spoil disposal location have been identiﬁed for additional soil disposal if the spoil area requirements grow through the development of project. However, the section does not identify and describe what additional areas could be used for additional spoil disposal. Please revise the FLA to identify and describe what additional areas could be used for additional spoil disposal and identify the current landowner(s) of the additional spoil disposal areas. Response The applicant has iden�ﬁed two primary areas for addi�onal spoil disposal should it be required during the development of the project. The applicant has included both areas within the project footprint in addi�on to all areas that would be disturbed during construc�on. Both primary areas for addi�onal spoil disposal are on BLM administered public lands and, if needed, will be contoured a�er construc�on is complete to approximate the surrounding topography, covered with topsoil, and reclaimed with na�ve vegeta�on to restore the appearance of the surrounding desert landscape. 1. Lower Reservoir Addi�onal Spoil Disposal Area – This area is located to the south of the proposed lower reservoir spoil disposal site bounded by the Western Access Road to the south. 2. Upper Reservoir Access Road Addi�onal Spoil Disposal Area – This area is located downslope and adjacent to the upper reservoir access road at its southern most extent. The disposal area is approximately 1,000 � by 2,000 � and shown in Exhibit E, Figure 2.3-2.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 27

FERC-A1-25

Exhibit C

Table 1.0-1 Project Milestones indicates that the anticipated date the Commission may issue any license for the project would be in February 2025. However, the table also indicates a proposal to begin construction of some project facilities (e.g., access roads, conveyance system and wells) in August 2024, several months before any license may be issued. Please note that any construction of project facilities is not authorized until Commission staﬀ have analyzed the proposal and made recommendations to the Commission on whether to authorize the proposed project, and if authorized, what measures to include as conditions of the license. Therefore, please revise the schedule accordingly in Table 1.0-1 and elsewhere in the FLA as needed. Response The applicant will begin no work on site before the following approvals are granted: 1. Commission authoriza�on of the proposed project including measures required as condi�ons of the license. 2. BLM issuance of a Right of Way Grant and Land Use Permit authorizing work on BLM-administered federal lands 3. Table 1.0-1 Project Milestones assumes the Commission may issue a license for the project in February 2025. Row four of the same table lists No�ce To Proceed (NTP) with Early Works (Access road, wellﬁeld and water conveyance, laydown area, u�lity lines reloca�on etc.) but this marks the end of the project’s procurement phase. Table 1.0-1 row eight then shows construc�on work beginning on 14-Mar-2025 only once these milestones are achieved and any further Commission condi�ons met. This �ming is further illustrated on page one of the Gant Chart schedule atached to Exhibit C. As a result, the applicant has not changed Table 1.0-1 as construc�on of project facili�es are currently scheduled only a�er Commission authoriza�on.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 28

FERC-A1-26

Exhibit E

Need for Pumped Storage Hydropower

Section 1.1.2 Need for Pumped Storage Hydropower, states that White Pine County would lose thousands of construction and operation employment jobs, associated indirect income and spending over the potential life of the project if the project is not licensed, and an opportunity to use industrial water rights originally granted for energy project development, and that White Pine County and the State of Nevada would lose property tax income. These statements are inaccurate because the project does not currently exist for White Pine County to lose these stated benefits and for the State of Nevada to lose property tax income. Rather, White Pine County and the State of Nevada might not gain the stated benefits. Please revise the section to appropriately indicate that White Pine County and the State of Nevada might not gain the benefits that are stated for each. Response Please see revised text to replace the 3rd bullet point for Exhibit E, Sec�on 1.1.2: “White Pine County would not gain property tax revenues in the amount of hundreds of millions of dollars over the life of the Project, along with thousands of employment job-years in construction and operation and associated indirect income and spending. The State of Nevada would also not gain significant property tax income that is specifically dedicated to the advancement of renewable energy development in the State.”

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 29

FERC-A1-27

Exhibit E

Consultation

Section 1.3 Consultation states that: (a) White Pine understands that the NNR HiLine train excursions operate three days per week, between mid-May to mid-September; (b) there are at least two specialty train excursions on the HiLine during the period mid-May to mid-September; and (c) the NNR has other excursions that operate annually, departing from the same NNR depot, but do not use the HiLine and therefore don’t intersect with the project. However, this section does not mention the Haunted Ghost Train, Santa's Reindeer Flyer, and the Fire and Ice Fireworks Train, or other excursions on which, previously indicated in this section, the Park Service recommends surveys be administered. Please revise the FLA to provide a full 2023 schedule of all HiLine excursions, including regular and specialty excursions throughout the year, including during the mid-May to mid-September timeframe during which White Pine proposes to conduct the NNR Visitor Use Assessment Survey and the mid-September to mid-May timeframe that is not proposed to be studied. Response A full 2023 schedule of train excursions as the applicant understands it is listed in Atachment 27-1. These excursions include: -

regular and specialty excursions throughout the year; trains during the mid-May to mid-September �meframe during which the applicant proposes to conduct the NNR Visitor Use Assessment Survey; the mid-September to mid-May �meframe that is not proposed to be studied.

This 2023 schedule of train excursions is based on both the NNR website and a printed train schedule calendar available in the NNR Gi� Shop, also included in Atachment 27-2. Infrequently, the NNR will add a train ride to the schedule on short no�ce which may not be reflected in Atachment 27-1. During May to September, there are between four (4) and five (5) HiLine excursion trains per week (average of 17.6 per month). During October to April, there are an average of 1.1 HiLine trains per month. Specifically, only 8.3% of all HiLine excursion train rides occur between October and April. The NNR also hosts a program called “Be the Engineer” on both its diesel and stream trains. Par�cipants receive instruc�on by one of the NNR’s cer�fied engineers and are allowed to operate the engine under the direct supervision of the NNR engineer. “Be the Engineer” is a private train excursion that does not, to applicant’s knowledge, operate on the HiLine route. The applicant has no informa�on about when these train excursions occur and as such, these have not been included in the list.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 30

FERC-A1-28

Exhibit E

Consultation

Figure 1.3-1 Locations and Angles of Photo simulations is illegible. Please edit the figure to clarify the image and refile the image. Because the above information is specifically related to the NNR Visitor Use Survey and recreation resources, and not specifically to consultation, please appropriately revise Section 3.8 Recreation of the FLA to include all additional information requested above. Response The applicant has refiled Figure 1.3-1. Please see Atachment 28-1 and 28-2. Atachment 28-1 is the Key Observa�on Point (KOP) map filed with the FLA on February 27, 2023. Atachment 28-2 is the KOP map with camera angles adjusted for true North.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 31

FERC-A1-29

Exhibit E

Incomplete Studies

Incomplete Studies Section 1.0, Introduction states that additional study efforts are planned by White Pine to complete surveys for the cultural and terrestrial resource studies (e.g., Greater Sage-Grouse Lek and Habitat Study) as well as supplemental study efforts regarding recreation, visual and aesthetic resources, and socioeconomics (e.g., NNR Visitor Use Assessment Study, Visual and Aesthetic Resources Study, Socioeconomic Study) resulting from stakeholder input on the DLA; Table 2.2-3 Environmental Measures Proposed by WPW also indicates that additional study efforts are planned (e.g., noise modeling). Additionally, Section 3.6 Botanical Resources, indicates that after field surveys for several terrestrial resource studies were completed in July 2022, the “project footprint” was modified. As a result, White Pine states it has scheduled additional, though unspecified, field studies in areas that were not previously surveyed. The FLA also states that results of these studies will be provided to FERC as they are completed. However, it is unclear which specific study elements are incomplete and when the results would be filed, as well as why the study results were not completed before the FLA was filed for staff’s review. Because the ongoing studies will collect information on environmental resources that would be potentially affected by the project, the results are needed to inform staff’s environmental analyses and scoping process for the project as required by the National Environmental Policy Act (NEPA). This information must be filed with the Commission before we can initiate scoping and prepare the NEPA document. Therefore, please describe the specific provisions of any study plans that are not complete and provide a schedule for completing any remaining data collection, analyses, and report preparation, including when the information will be filed with the Commission. Response The applicant performed the applicable studies in 2021. A�er comple�on of these studies, the applicant modified, in 2022, the design of the upper reservoir access road, laydown areas and transmission line resul�ng in the need for addi�onal studies on the addi�onal adjacent areas. The addi�onal adjacent areas total approximately 288-acres, and the applicant will complete the studies as shown in the table below. The applicant will conduct these studies within the applicable seasonal restric�ons and expects to commence these studies in September 2023. The applicant will complete these studies in July 2024. The addi�onal adjacent areas that applicant will have similar or the same habitat characteris�cs and wildlife use as the areas that applicant previously surveyed. Approximately 81-acres of land are directly adjacent to exis�ng areas that were previously studied and approximately 207-acres of land are located within the same types of ecosystems and near areas that have previously been studied. Several other studies are included as part of the Na�onal Park Service Study Dispute. The applicant is conduc�ng these studies in consulta�on with the Na�onal Park Service and the Northern Nevada Railroad. These studies are in progress and the applicant will file the supplemental studies as they are completed. The applicant has provided Atachment 29-1 and 29-2, Maps of addi�onal study areas.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 32

Table 29-1: Planned Studies and Timeline

Study

Reason for Additional Study

Timeline for completing data collection, analyses, and report preparation

Cultural Resources

Expanded Study Area

Report completion by July 2024

Recreation Study (NNR Visitor Use Assessment Study)

National Park Service Study Dispute

Report completion by November 2023

Visual and Aesthetic Resources

National Park Service Study Dispute

Report completed July 2023

Socioeconomic Study

National Park Service Study Dispute

Report completion by November 2023

Botanical Study

Expanded Study Area

Report completion by July 2024

Additional Noise Modelling

PM&E Measure Development

Model completion by July 2024

Floodplain Study

Expanded Study Area

Report completion by December 2023

Aquatic Resources Delineation

Expanded Study Area

Report completion by July 2024

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 33

FERC-A1-30

Exhibit E

Project Facilities

The application does not fully describe all proposed, temporary project facilities. For example, Section 3.7.2.1 Terrestrial Wildlife and Habitat states that concrete batch plants would likely be erected to produce concrete for the project and no further description is provided. However, Section 2.2.1 Project Facilities does not describe any proposed concrete batch plants. Section 4.41(f)(3)(iv) of the Commission’s regulations requires the following material and information regarding any mitigation measures or facilities, identiﬁed under clause (iii), proposed for implementation and construction: a) Functional design drawings; b) A description of proposed operation and maintenance procedures for any proposed measures or facilities; c) An implementation, construction, and operation schedule for any proposed measures or facilities; d) An estimate of the costs of construction, operation, and maintenance of any proposed facilities or implementation of any measures; e) A statement of the sources and amount of ﬁnancing for mitigation measures or facilities; and f)

A map or drawing showing, by using shading, crosshatching, or other symbols, the identity the location of any proposed measures or facilities.

For staff to have a complete and comprehensive understanding of the proposed project and proposed construction activities, please ensure that all proposed temporary and permanent project facilities, including temporary facilities installed to support construction of the project, are adequately described in Section 2.2.1 Project Facilities. Response A descrip�on of the proposed temporary infrastructure including concrete batch plants is provided in Exhibit F Preliminary Suppor�ng Design Report Sec�on 2.3.2 Temporary Construc�on Facili�es. For ease of reference the applicant has cited this below. The applicant understood the purpose of Exhibit A to describe the principal project features, hence the descrip�on below that was included in Exhibit F Preliminary Suppor�ng Design Report Sec�on 2.3.2 of temporary construc�on facili�es was not included in Exhibit A. “To support the construction of the project, several laydown and staging areas are required as shown on the access road, laydowns and wellfield conveyance drawings in Exhibit F. These areas will allow for the establishment of temporary facilities including offices, change houses for the construction crews, light vehicle and construction equipment parking, warehousing and storage areas, workshops, a material testing laboratory, concrete batch plant, spoil handling and processing equipment and construction wastewater treatment facilities. Temporary explosives storage will be sited away from the main construction facilities with secured access in accordance with regulatory requirements.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 34

Temporary construction water supply will be from the wellﬁeld. The Contractor would propose connections to this and stage his own pumps and pipework for distribution. Temporary construction power would be via diesel generators located at the switchyard until the Station service power transmission line is installed. Contractor would establish their temporary electrical houses and distribution to support the works. Power for construction at the upper reservoir area will be by a dedicated diesel generator farm.” The applicant has highlighted the laydown areas in red in Figure 30-1 below. Figure 30-1 is an extract of Exhibit F drawing F-104. Figure 30-1: Laydowns

The temporary construc�on infrastructure will be located within the laydown and staging areas included in the Exhibit F drawings. The applicant is providing further informa�on related to the temporary construc�on facili�es and speciﬁcally related to concrete supply (batch plant) establishment. Security and Access Barricades will be established at key points along exis�ng unpaved access roads as shown on the drawings in Exhibit F. Chain link fencing will be erected around all laydown sites for security. A boom gate will be provided across the Western Access Road just oﬀ the intersec�on of SR-93 to control access into the project area. Several access roads that run along both the ac�ve and inac�ve Nevada Northern railway lines will be maintained through the road crossings. Addi�onal fencing and/or signage to prevent access into the work areas will be erected for security and public safety. Temporary Site Facili�es The applicant, and its building contractor, will establish the following temporary facili�es on site at designated laydown and staging areas. • •

Oﬃce trailers for both Contractors, Owners team Lunch / kitchen trailers

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 35

• • • • • • •

Warehouses and heated storage facili�es to store all incoming materials, equipment and tools. OEM equipment will be warehoused locally. Ablu�on blocks and a change trailer (to allow workers the ability to change out their work clothes, wash and shower and change into clean clothes, etc.) Medical/First Aid facili�es Explosive’s storage facili�es Batch plant to produce all shotcrete, concrete and grout for the project Quality Control Laboratory to perform all materials tes�ng Workshops to maintain all equipment and perform any preassembly welding and fabrica�on

Construc�on Staging Laydown Areas The applicant has designed laydown and staging areas to the lower and upper reservoirs, the main access tunnel portal, as well as near the SR-93 site entrance as shown on the access drawings in Exhibit F. The loca�on and size of the laydown areas consider the following • • • •

• •

Proximity to major work areas and adjacent to access roads Minimizing environmental impact and where possible located outside of ac�ve wildlife habitat Op�mizing the cut ﬁll balance to not generate any addi�onal spoil material Restora�on of the laydown areas post construc�on includes contouring the laydown areas to approximate the surrounding topography, covering with topsoil, and reclaiming the laydown areas with na�ve vegeta�on to restore the appearance of the surrounding desert landscape. Accommodate various construc�on facili�es required at each laydown area Provide space for construc�on-related equipment parking, vehicle access within the laydown area, water tanks to store water, equipment storage, bulk material condi�oning, and aggregate bins.

These laydown and staging areas will be temporary, with gravel or asphalt surfaces, and therefore will require temporary dust control mi�ga�on measures. These laydown areas will be fenced off for security purposes. Temporary Construc�on Wastewater The applicant will establish construc�on wastewater treatment facili�es at the Lower Reservoir and Underground Laydown areas. The applicant will use/reuse treated water for construc�on purposes such as tunneling and batch plant opera�on and material condi�oning, as irriga�on for reclama�on areas, or for dust control mi�ga�on measures. The applicant will pump sanitary waste into tankers and haul off site. Temporary Construc�on Power Diesel generators will provide temporary construc�on power at the upper reservoir site, including power for the offices, warehouses, workshops, and headrace sha�. The applicant will make connec�ons to the local grid lines at 24.5KV or 29.4 KV to provide 3 phase power to the following: •

Main Staging Area (warehouses, workshops, batch plant, oﬃces and tes�ng laboratories, temporary, kitchen trailers)

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 36

Lower Reservoir Laydown (workshops, offices, tailrace tunnel equipment, tailrace tunnel ven�la�on, tailrace tunnel services, heaters, and the wastewater treatment plant) Power for the wells along the well field will be provided from the main staging area along a buried line adjacent to the well field conveyance pipeline Power for the main underground works (drilling equipment, shotcrete machines, pumps, ven�la�on fans, tunnel services, heaters) and the facili�es (warehouses, offices, workshops, heated storage staged at the underground laydown area) will be provided through early establishment of the 24.5KV overhead service power line that will later connect to the switchyard and provide sta�on service power.

• • •

Temporary Construc�on Water Supply The applicant will provide construc�on water supply through early establishment of the upper reservoir well and lower site well field and conveyance line. The applicant will use water tanks and pumps to distribute water throughout the project. Concrete Supply The applicant will establish early in the project’s construc�on a batch plant capable of supplying all concrete, shotcrete, and grout. The applicant will transport cement, fly ash, accelerators, fibres and addi�ve’s from suppliers by truck that will be stored on site at a loca�on close to the batch plant. The applicant will import aggregate and store it in dedicated aggregate bins close to the batch plant. The applicant will use, when possible, processed and washed excavated material as aggregate for concrete. The processing will take place close by the permanent spoil disposal area and from where aggregate will be taken from designated stockpiles to feed the aggregate bins. The applicant will test and determine the suitability of excavated aggregate for use in the concrete. Adequate laydown areas for storage of delivered materials such as silos and pigs for cement and fly ash, aggregate bins and heated dry storage for accelerators, addi�ves and fibres that are sensi�ve to temperature and moisture are required for the delivery of these items. Total an�cipated volume of concrete: 90,000 m3 (including 20,000 m3 of backfill concrete with lower cement content). With reference to sec�on 4.41(f)(3)(iii) of the Commission’s regula�ons, following selec�on of the Engineering, Procurement, and Construc�on (EPC) contractor and during the final design phase, the applicant and its EPC contractor will develop and provide to FERC the details regarding the following temporary construc�on facili�es and measures. The applicant and its EPC contractor will also then provide to FERC the material and informa�on requested in sec�on 4.41(f)(3)(iv) of the Commission’s regula�ons for any mi�ga�on measures or facili�es, iden�fied under clause (iii), that are proposed for implementa�on and construc�on. • • • •

Construc�on wastewater treatment facility Explosives management storage facility Acid rock drainage and management measures Fugi�ve dust control management measures

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 37

• •

Stormwater Pollu�on Preven�on Plan Spill Preven�on, Control, and Countermeasure Plan o Hazardous materials management o Construc�on waste management

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 38

FERC-A1-31

Exhibit E

Proposed Environmental Measures

In Section 2.2.4 Summary of Proposed Environmental Measures, Table 2.2-3 lists 27 proposed environmental measures, about half of which are resource management plans that would consist of multiple provisions and measures. The table includes general descriptions of the goals and objectives of the proposed plans (e.g., Outdoor Lighting Plan) as well as some rudimentary examples of measures under consideration and indicates that studies (e.g., noise modeling) would be undertaken to inform development of measures. Otherwise, the FLA indicates that plans and measures are still being developed and specific measures have yet to be identified; hat some plans would be developed at some future, unspecified date prior to construction; or that other measures may be proposed based on continued consultation with resource agencies. Further, no additional information on the proposed measures is provided in the resource sections that follow in Section 3.0 Environmental Analysis. This level of uncertainty and detail is not sufficient. For staff to adequately evaluate any proposed measures and prepare our NEPA analysis, and to weigh the benefits of the proposed measures along with their costs (economic, generation, and other competing uses) to compare with any alternative measures that may be recommended by stakeholders substantially more information must be provided in the revised FLA. Indicating that some measures may or may not be developed at an unspecified future date does not conform with the application content requirements in section 4.38 of the Commission’s regulations. For example, the proposal to construct the 25-mile-long transmission line with consideration of design guidelines recommended by the Avian Power Line Interaction Committee (APLIC) in order to minimize avian electrocution and collision hazards. The proposed Raptor-Safe Transmission Line Structure Plan, the Raptor and Bat Protection Plan, and the Greater Sage-Grouse Mitigation Plan provide general examples of aviansafe devices and designs, including markers, diverters, perch guards, line spacing, insulative covers, etc. that are under consideration. However, no information is provided on what specific measures are proposed, including the where, how many, when, why, and how any potential measures would be implemented. Additionally, no supporting analysis is provided on how the measures would minimize effects of the proposed project on environmental resources. Accordingly, we are also unable to understand how costs are assigned for the proposed measures in Table 4.3-1. For example, under the Habitat Restoration, Reclamation, and Enhancement Plan (PME #9) the FLA lists a capital cost of $100,000 and an annual cost of $20,000. However, we cannot determine if this cost estimate is reasonable because we do not understand what would be implemented for a capital cost of $100,000 and an annual cost of $20,000. This amount seems low considering the number of acres that would be disturbed and would presumably be revegetated. For each measure listed in Table 4.3-1, please describe, at least at the conceptual level, what would be done, and the basis of the estimated cost included in the table. Therefore, for staff to process the application more specific information is needed for all the proposed measures in listed in Table 2.2-3. Additionally, please review the Guidance on Environmental Measures in License Applications available on the Commission’s website2 and revise the FLA to clearly describe and specify all proposed measures and facilities, including: relevant goals and objectives; the what, where, how many, when, why, and how any measures would be implemented; the project-related effects the measures address and their benefits to specific resources; relevant conceptual drawings and maps; consultation with resource agencies leading to the measures (summarize and attach correspondence); and costs (capital and annual). Sufficient detail should be included for staff to understand and evaluate the specific provisions of each measure with reference to the related impact and where relevant: the conditions under which implementation would occur (e.g., continuously or in the event of contingencies) with reference to project design and/or operating procedures; any technical aspects for implementation; an implementation schedule that includes the

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 39

timing, frequency, and duration; procedures providing information on the progress and results of mitigation and monitoring measures; any necessary monitoring including the linkages between impacts, measurement indicators, detection limits (where appropriate), and defined thresholds/triggers that would signal the need for corrective actions; and reporting protocols. This information is needed for staff to evaluate the proposed measures in our NEPA analyses as well as to draft potential license conditions with sufficient detail for clear implementation and enforcement of the measure’s provisions and parameters. In the sections that follow, staff also outline information needs specific to individual proposed plans and measures. Response As requested by FERC’s April 28, 2023 Deficiency of License Applica�on and Addi�onal Informa�on Request (AIR) leter, and pursuant to Title 18 Code of Federal Regula�ons (CFR) § 5.18(b)(5)(ii)(C) and FERC’s Guidance on Environmental Measures in License Applica�ons (FERC 2020), the applicant has merged the contents of Final License Applica�on (FLA) Table 2.2-3 (Summary of Proposed Environmental Measures) and Table 4.3-1 (Cost of Environmental Mi�ga�on and Enhancement Measures Considered in Assessing the Environmental Effects of Con�nuing to Operate the WPW Project) into a Revised Table 4.31 (Atachment 31-1) to include: • • • • • •

Supplemental informa�on regarding each of its 27 proposed protec�on, mi�ga�on, and enhancement (PM&E) measures; A conceptual level descrip�on of the PM&E measure; What the PM&E measure is intended to mi�gate for based on poten�al environmental eﬀects outlined in the FLA A basis for the es�mated capital and annual costs, when such costs required further explana�on (previously included in Table 4.3-1 of the FLA); A list of coordina�ng en��es that will be engaged for consulta�on by PM&E measure; and A proposed consulta�on plan with relevant agencies.

The intent of the Revised Table 4.3-1 is to replace Table 2.2-3 and Table 4.3-1 in their en�rety. As such, the applicant is providing replacement pages of the FLA from pages 350 through 392, which are now renumbered as pages 350 through 401. Pursuant to the Federal Land Policy and Management Act, the applicant an�cipates that early development and finaliza�on of certain management plans, proposed as PM&E measures, may be necessary to obtain a Right-of-Way (ROW) Grant Authoriza�on and Record of Decision from the U.S. Bureau of Land Management (BLM). Those plans are iden�fied within the Revised Table 4.3-1 (Atachment 31-1), and the applicant will con�nue consulta�on with relevant agencies to develop these management plans prior to FERC’s issuance of an original license for the project. As these management plans are developed early, the applicant will submit a dra� to relevant agencies for a 30-day comment period. Following agency review and comment, mee�ng summaries and associated consulta�on will be included as an appendix to each final resource management plan and filed with FERC for approval. The applicant par�cipates in a monthly Technical Working Group (TWG), which the BLM established to allow coordina�on, facilitate discussion, and assist in reaching consensus on appropriate PM&E and resource management measures related to wildlife. The ini�al TWG mee�ng was hosted on June 29, 2023, and included staff from the following agencies: BLM, Nevada Department of Wildlife (NDOW), Nevada

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 40

SETT, and White Pine County. The next TWG mee�ng will be hosted on August 31, 2023. Both the U.S. Fish and Wildlife Service (USFWS) and the U.S. Forest Service (USFS) were invited to the TWG but declined to par�cipate. TWG discussions are intended to guide the development of wildlife-related management plans proposed in the applicant’s PM&Es. Pre-license consulta�on unrelated to wildlife will be conducted on an as-needed basis with relevant agencies or stakeholders.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 41

FERC-A1-32

Exhibit E

General Description of the River Basin

Figure 3.1-3 Topography of the Project Vicinity shows the topography within the vicinity of the “project footprint”, which includes the reservoirs, some project access roads, the underground facilities, and portion of the transmission line mostly east of Hercules Gap. However, there is no similar map that shows the topography in the vicinity of the proposed project transmission line to the west of Hercules Gap. Please provide a map(s), like Figure 3.1-3 that show the topography in the vicinity of the proposed project transmission line to the west of Hercules Gap. Response Figure 32-1 below is the requested ﬁgure, like Figure 3.1-3, but showing topography along the proposed project transmission West of Hercules gap. Exhibit F also provides an addi�onal resource regarding topography.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 42

Figure 32-1: Topographic Map West of Hercules Gap

te Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 43

FERC-A1-33

Exhibit E

General Description of the River Basin

Section 3.1.3.1 Major Land Uses and Ownership states that the total acreage within the “project footprint”, which includes permanent and temporary disturbance areas, would be 1,338 acres. However, Exhibit A, Table 1.4-1 Summary of Lands within the Project Boundary, states that a total of 1,143.21 acres of land would be located within the project boundary. Please revise the FLA to address the nearly 200-acre difference and provide the correct acreage that is located within the project boundary; if the response would cause other parts of the FLA to be corrected, please provide the location within the FLA of each of these corrections. Additionally, it is unclear whether all permanent and temporary disturbance areas would occur within the project boundary or if certain of those disturbance areas would occur outside the project boundary, but within the “project footprint”. Please revise the FLA to clarify (a) what, if any, difference there is between the “project footprint” and the project boundary and (b) if certain of those permanent and temporary disturbance areas would be located outside the project boundary, but within the “project footprint”. Response The difference between these two values relates to the difference between “Project Footprint” and “Project Boundary”. The “Project Footprint” is 1,338 acres total, and the “Project Boundary” is 1,143.21 acres. The difference between the two is approximately 200 acres, which is the area of land that would be temporarily disturbed during construc�on and included in the “Project Footprint” but not in the “Project Boundary” as described further below. The “Project Boundary” incorporates all lands required for the project’s opera�ons and maintenance (See Exhibit E, Sec�on 1.2 Footnote 1). “Project Footprint” incorporates the “Project Boundary” in addi�on to all areas that would be disturbed during Construc�on (See Exhibit E, Sec�on 1.0 of the FLA). The “Project Boundary” includes only opera�onal areas and areas used for maintenance, while “Project Footprint” includes both the “Project Boundary” and the temporarily disturbed areas. Addi�onal clarifica�on around “Project Footprint” and “Project Boundary” can be found in the following sec�ons of the FLA: • •

•

Exhibit E Sec�on 1.0 Introduc�on states, ‘the Project Footprint incorporates the Project Boundary in addition to all areas that would be disturbed during construction’. Exhibit E Sec�on 1.2, Footnote 1 states, ‘WPW initially drew a Conceptual Project Boundary for the Pre-Application Document in 2020. It was revised as Project design advanced for the resource studies conducted in 2021. WPW has continued to reﬁne the Project Boundary and in this FLA presents the revised Project Boundary (incorporating all lands required for Project operations and maintenance) as well as the Project Footprint (incorporating the Project Boundary in addition to all areas that would be disturbed during construction)’. Exhibit E, Sec�on 3.1.3.1 Major Land Uses and Ownership, states ‘The Project Footprint encompasses all lands potentially needed for Project construction, operation, and maintenance and is shown in Figure 2.3-2. The total acreage within the Project Footprint, which includes permanent and temporary disturbance areas, is 1,338 acres. Within the Project Footprint is the FERC Project Boundary (Project Boundary) which includes only those lands required for Project operation and maintenance, such as all Project facilities and access roads. The Project Boundary is presented in Exhibit G Maps G-01 to G-04 of this FLA’.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 44

FERC-A1-34

Exhibit E

General Description of the River Basin

Section 3.1.3.1 Major Land Uses and Ownership states that approximately 1,281 acres of land administered by the BLM and approximately 57 acres of privately-owned land are located within the “project footprint”. However, Exhibit A, Table 1.4-1 Summary of Lands within the Project Boundary, states that 1,095.76 acres of land administered by the BLM and approximately 47.45 acres of privately-owned land are located within the project boundary. Please revise the FLA to address this discrepancy and provide the correct acreage for each of these landowners. Response The difference between these two values relates to the difference between “Project Footprint” and “Project Boundary”. The area of the “Project Footprint” which is administered by the BLM is 1,281 acres, and the area of the “Project Footprint” that is privately-owned is 57 acres (1,338 total acres). The area of the “Project Boundary” which is administered by BLM is 1,095.76, and the area of the “Project Boundary” that is privately owned is 47.45 acres (1,143.21 total acres). The difference between the two values is the temporarily disturbed areas, which are included in the “Project Footprint” but not in the “Project Boundary” as described further below. The “Project Boundary” incorporates all lands required for the project’s opera�ons and maintenance (See Exhibit E, Sec�on 1.2 Footnote 1). “Project Footprint” incorporates the “Project Boundary” in addi�on to all areas that would be disturbed during construc�on (See Exhibit E, Sec�on 1.0 of the FLA). The “Project Boundary” includes only opera�onal areas and areas used for maintenance, while “Project Footprint” includes both the “Project Boundary” and the temporarily disturbed areas.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 45

FERC-A1-35

Exhibit E

General Description of the River Basin

Figure 3.1-4 Land Ownership in the Project Vicinity shows the land ownership within the vicinity of the “project footprint”, which includes the reservoirs, some project access roads, the underground facilities, and portion of the transmission line mostly east of Hercules Gap. However, there is no similar map that shows the land ownership in the vicinity of the proposed project transmission line to the west of Hercules Gap. Please provide a map(s), like Figure 3.1-4 that show the land ownership in the vicinity of the proposed project transmission line to the west of Hercules Gap. Response Figure 35-1 below is the requested ﬁgure similar to Figure 3.1-4 that shows land ownership along the proposed project transmission West of Hercules Gap. Atachment 19-1 Exhibit G Maps provides an addi�onal resource, with maps G1 through G4 displaying land ownership West of Hercules Gap.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 46

Figure 35-1: Landownership West of Hercules Gap

te Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 47

FERC-A1-36

Exhibit E

Environmental Eﬀects Analysis

A footnote to Table 3.2-1 Geographic Scope by Resource for Cumulative Effects Associated with the White Pine Pumped Storage Project states that the “project footprint” encompasses the area needed for project construction and that it includes the footprint of the permanent project facilities. This appears to mean that the (a) “project footprint” would encompass the project boundary (i.e., footprint of the permanent project facilities) and (b) project-related construction activities would occur outside of the project boundary. Please revise the FLA to confirm whether project-related construction activities are proposed to take place outside of the proposed project boundary. Response The applicant will conduct project-related construc�on ac�vi�es outside of the proposed project boundary, and within the project footprint. The applicant clarifies the footnote in Table 3.2-1 to read: “The Project Footprint encompasses the area needed for construction workspace and includes the Project Boundary.” The “Project Boundary” incorporates all lands required for the project’s opera�ons and maintenance (See Exhibit E, Sec�on 1.2 Footnote 1). “Project Footprint” incorporates the “Project Boundary” in addi�on to all areas that would be disturbed during Construc�on (See Exhibit E, Sec�on 1.0 of the FLA). The “Project Boundary” includes only opera�onal areas and areas used for maintenance, while “Project Footprint” includes both the “Project Boundary” and the temporarily disturbed areas.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 48

FERC-A1-37

Exhibit E

Environmental Eﬀects Analysis

Although Section 3.2.2.2 Reasonably Foreseeable Future Actions references several potential, non-project projects and actions, it does not include any reasonably foreseeable future actions related to the White Pine project, such as the proposed annual groundwater pumping to supply the project with make-up water. Please revise this section to include a description of this proposed project action, and any other potential future project-related action, that could cumulatively affect environmental resources. Response The applicant has revised the second paragraph of Sec�on 3.2.2.2 Reasonably Foreseeable Future Ac�ons, as follows: “Reasonably foreseeable future actions relevant to the cumulative effects analysis include: (1) potential solar and wind energy projects in the Steptoe Valley along the transmission line toward Robinson Summit substation; (2) expanded operations of the NNR; (3) additional transmission lines in the Section 368 energy corridors; (4) actions funded by the Southern Nevada Public Lands Management Act (SNPLMA) grants; (5) BLM actions; and (6) Nevada Department of Transportation (NVDOT) projects; and (7) Project use of groundwater resources. The analysis also considers population and development trends in White County. In many cases, specific projects have not yet been proposed, nor are specific locations known, and therefore the cumulative effects analysis for those future actions is largely qualitative. “ The applicant has added the following to the end of Sec�on 3.2.2.2. Reasonably Foreseeable Future Ac�ons, as follows: “Construction and operation of the project will use groundwater resources. During the initial reservoir fill stage of construction, groundwater pumping will result in approximately 10 feet of drawdown at one domestic well east of PW-3 and may (depending on aquifer transmissivity) cause 10 feet of drawdown at four other wells used for domestic and irrigation purposes. During operation, on average, approximately 560 AF will be needed each year to make up for losses due to seepage, leakage, and evaporation. Continued use of groundwater resources each year to make up for losses due to seepage, leakage, and evaporation is a reasonably foreseeable future action. . .” The applicant has revised Table 3.2-2. Reasonably Foreseeable Future Ac�ons, as follows:

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 49

Table 3.2‑2. Reasonably Foreseeable Future Actions Approximate Distance from Project Footprint

Description

Potential Resources Cumulatively Affected

Project or Action

Location

Potential Solar and Wind Energy Projects

Steptoe Valley

Unknown (not anticipated to overlap with Project Footprint)

A recent voter-approved Nevada constitutional requirement for 50 percent renewable energy sourcing by 2030 and a law requiring 100 percent carbon-free resources by 2050 will likely result in solar and wind energy development in Steptoe Valley along the transmission line toward Robinson Summit substation (Alonzo 2020).

Water Resources Fish and Aquatic Resources Wildlife Resources Recreation Resources Land Use Aesthetic Resources Socioeconomic Resources Environmental Justice

Expanded Operations of NNR

Steptoe Valley

Overlaps with Project Footprint

White Pine County, in conjunction with the NNR Foundation, is planning to restore operation approximately 16 miles of railroad track from Ely to McGill, and make improvements to the depot and trails systems within the railroad right-of-way in White Pine County (White Pine County 2021).

Geologic and Soil Resources Water Resources Fish and Aquatic Resources Botanical Resources Wildlife Resources Recreation Resources Land Use Aesthetic Resources Socioeconomic Resources Environmental Justice

Additional Transmission Lines or Pipelines in Section 368 Energy Corridors

Section 368 Energy Corridor located within White Pine County

Unknown

A Section 368-designated energy corridor exists within the Project Footprint and is designed to support connectivity to multiple energy generation sources*. Specific projects are described in the next two rows.

Geologic and Soil Resources Water Resources Fish and Aquatic Resources Botanical Resources Wildlife Resources Recreation Resources Land Use Aesthetic Resources Socioeconomic Resources

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Project or Action

Location

Approximate Distance from Project Footprint

Description

Potential Resources Cumulatively Affected Environmental Justice

Greenlink North Transmission Line (part of Section 368 Energy Corridor)

White Pine County

Overlaps with Project Footprint at Robinson Summit Substation

A 525 kV transmission line approved to facilitate transmission of renewable resources. The line starts at the Robinson Summit substation and heads west to the Yerington substation (NV Energy 2022).

Cross-Tie Transmission Project (part of Section 368 Energy Corridor)

White Pine County

Overlaps with Project Footprint at Gonder Substation and parallels the Project

A proposed 500 kV transmission line that will connect the Gonder substation and the Clover substation in Utah, and strongly link the Nevada and Utah systems (BLM 2022b).

Southwest Intertie Project-North (SWIP-North) Line (part of Section 368 Energy Corridor)

White Pine County, Elko County

Overlaps with Project Footprint at RobinsonSummit Substation, and perpendicular to the Project

A 500 kV transmission line that is almost fully permitted, the SWIP-North Line will connect the Robinson Summit substation to the Pacific Northwest market (LS Power 2016).

Geologic and Soil Resources Water Resources Fish and Aquatic Resources Botanical Resources Wildlife Resources Recreation Resources Land Use

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Project or Action

Location

Approximate Distance from Project Footprint

Description

Potential Resources Cumulatively Affected Aesthetic Resources Socioeconomic Resources Environmental Justice

Actions Funded by SNPLMA Grants

Greater Las Vegas Valley

Unknown

A total of 92 SNPLMA grants have been awarded in White Pine County since the act was passed in 1998. Grants are typically issued to enhance environmental values. Additional projects to restore habitat, reduce risk of wildfire, and conserve natural resources in White Pine County are expected to receive funding under SNPLMA over the next 30 to 50 years.

Water Resources Fish and Aquatic Resources Wildlife Resources Recreation Resources Land Use Aesthetic Resources Socioeconomic Resources Environmental Justice

Garnet Hill Recreation Area Management Plan (part of actions funded by SNPLMA Grants)

White Pine County

South of transmission line (Egan Crest Trail System 0.1 mile; Garnet Hill Recreation Area 5 miles)

The BLM Bristlecone Field Office is proposing improvements to the Garnet Hill Recreation Area and the Egan Crest trail systems including upgrading roads, adding campgrounds, enlarging trailheads, and constructing trail systems. The improvements are funded as part of Round 18 of SNPLMA (BLM 2022e).

Water Resources Fish and Aquatic Resources Wildlife Resources Recreation Resources Land Use Aesthetic Resources Socioeconomic Resources Environmental Justice

Smith Valley Mastication and Hand Thinning

Bristleco ne BLM Field Office

Perpendicular to Project transmission line, north and south (0 miles)

A proposal to remove stage I, II and III pinyon and Utah Juniper within the Smith Valley to make habitat more suitable for Greater Sage-grouse and mule deer (DOI 2022, BLM 2022f).

Geologic and Soil Resources Water Resources Fish and Aquatic Resources Botanical Resources Wildlife Resources Recreation Resources Land Use Aesthetic Resources Socioeconomic Resources

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Project or Action

Location

Approximate Distance from Project Footprint

Description

Potential Resources Cumulatively Affected Environmental Justice

NVDOT Statewide Transportation Improvement Program projects within White Pine County

White Pine County

Unknown (not anticipated to overlap Project Footprint)

Nevada Department of Transportation has three projects within a 5-mile buffer of the Project: an Americans with Disabilities Act of 1990 (ADA) project along the main street in McGill, drainage improvement in the city of Ely, and paving a stretch of multi-use track near the NNR museum in Ely (Nevada DOT 2021).

Water Resources Fish and Aquatic Resources Wildlife Resources Recreation Resources Land Use Aesthetic Resources Land Use Socioeconomic Resources Environmental Justice

Recreation Trail Building School Grant

State of Nevada

Approximately 6 miles south of Project Footprint

The U.S. Economic Development Administration is providing a $160,000 grant to the Great Basin Institute to build a professional trail building school, located in Ely, Nevada (Robertson 2021).

Wildlife Resources Recreation Resources Land Use Socioeconomic Resources

Increasing Population and Development

White Pine County

Unknown

The population of White Pine County has mildly fluctuated at around 10,000 people, and declined slightly from 1990 to 2020. However, given the large population increase in the state overall, this cumulative effects analysis conservatively assumes that population and development will increase in White Pine County over the temporal scope of the analysis.

Project use of groundwater resources

White Pine County

Approximately 6 miles south of Project Footprint

The Project will utilize groundwater for initial fill and annual make-up of losses of water from seepage, leakage, and evaporation. WPW estimates that, on

Geologic and Soil Resources Water Resources Fish and Aquatic Resources

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Project or Action

Location

Approximate Distance from Project Footprint

Description average, approximately 560 AF will be needed each year to make up for losses to seepage, leakage, and evaporation.

Potential Resources Cumulatively Affected Botanical Resources Wildlife Resources Recreation Resources Land Use Socioeconomic Resources

*A programmatic EIS was prepared to analyze the environmental impacts of designating and developing energy corridors on federal lands pursuant to Section 368 of the Energy Policy Act of 2005 (US DOE and BLM 2008). Energy corridors have been located to avoid, where possible, conflicting land uses and important resources (BLM 2021b).

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FERC-A1-38

Exhibit E

Soils

Table 3.3.-1 Soil Types Mapped in the Project Footprint indicates the acreages of areas of different farmlands as classified by the Natural Resources Conservation Service that would be located within the “project footprint”. However, the table does not indicate the acreages of those farmlands that would be located within the project boundary. Please revise Table 3.3-1 to indicate the acreages of the farmlands that would be located within the project boundary and file a map showing the location of the different farmlands with respect to the proposed project boundary. Response The applicant has revised table 3.3-1 to include the acreages of the farmlands that will be located within the project boundary. The applicant has also prepared maps, included as Atachment 38-1, showing the loca�on of the different farmlands with respect to the proposed project boundary. Revised Table 3.3-1. Soil Types Mapped in the Project Footprint and Project Boundary

Map Unit Symbol

Map Unit Name

Farmland Classification

Project Project Project Project Footprint Footprint Boundary Boundary Acreage Percentage Acreage Percentage

Zola loam 0 to 2 percent Prime farmland if irrigated slopes

328.74

24.57%

290.58

25.40%

100

Anawalt-VanwyperAlyan association

Not prime farmland

115.34

8.62%

115.34

10.08%

108

Anawalt-Oreneva complex

Not prime farmland

21.26

1.59%

21.26

1.86%

109

Hyzen-Cavehill association

Not prime farmland

2.76

0.21%

23.53

2.06%

111

Aycab-Alta-Tosp association

Not prime farmland

26.42

1.97%

26.42

2.31%

189

Cleavage-SoftscrabbleNot prime farmland Sumine complex

16.98

1.27%

16.98

1.48%

201

Davey loamy fine sand 2 Farmland of statewide to 8 percent slopes 1/ importance

1.44

0.11%

0.98

0.09%

226

Enko-Rad association

Farmland of statewide importance

132.77

9.92%

113.27

9.90%

233

Dun Glen very fine sandy loam 0 to 2 percent slopes 1 /

Prime farmland if irrigated and reclaimed of excess salts 5.82 and sodium

0.43%

5.82

0.51%

282

Bloor-Enko association Not prime farmland

3.15

0.24%

3.15

0.28%

286

Chiara-Jenor association Not prime farmland

61.78

4.62%

29.89

2.61%

297

Creemon-OrovadaTulase association

10.74

0.80%

6.7

0.59%

Not prime farmland

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Map Unit Symbol

Map Unit Name

Farmland Classification

Project Project Project Project Footprint Footprint Boundary Boundary Acreage Percentage Acreage Percentage

351

Cowbell-Brownsbowl association

Not prime farmland

1.94

0.14%

1.94

0.17%

455

Macnot very gravelly ashy fine sandy loam 2 Not prime farmland to 8 percent slopes

4.09

0.31%

2.97

0.26%

481

Ninemile-WestbutteNot prime farmland Softscrabble association

14.08

1.05%

14.08

1.23%

531

Raglan-Isolde association

Not prime farmland

1.14

0.09%

1.14

0.10%

567

Softscrabble-DosieHutchley association

Not prime farmland

0.85

0.06%

0.85

0.07%

690

Sodhouse-Golconda association

Not prime farmland

9.32

0.70%

5.77

0.50%

710

Xipe silt loam 1/

Not prime farmland

6.37

0.48%

6.37

0.56%

752

Snapp-Orovada association

Not prime farmland

39.61

2.96%

39.61

3.46%

760

Piline complex

Not prime farmland

50.14

3.75%

50.14

4.38%

763

Segura-Douhide-McIvey Not prime farmland association

42.07

3.14%

42.07

3.68%

800

Udelope-Bregar-Rock outcrop association

Not prime farmland

76.36

5.71%

16.17

1.41%

801

Udelope-HackwoodTusel association

Not prime farmland

0.21

0.02%

0.14

0.01%

8101

Batan-Goldrun association

Not prime farmland

134.40

10.31%

84.59

7.39%

911

Barnard-Devada association

Not prime farmland

6.74

0.50%

6.74

0.59%

977

Zimbob-Pookaloo association

Not prime farmland

4.46

0.33%

4.46

0.39%

991

Hyzen-Cavehill-Tecomar Not prime farmland association

54.71

4.09%

54.71

4.78%

1230

Raglan-Mazuma association

Prime farmland if irrigated and reclaimed of excess salts 16.84 and sodium

1.26%

10.87

0.95%

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 56

Map Unit Symbol

Map Unit Name

1392

Ninemile-Newlands association

Not prime farmland

15.19

1.14%

15.19

1.33%

1451

Atlow-Reluctan-Trunk association

Not prime farmland

58.44

4.37%

58.44

5.11%

Croesus-Rock outcrop 1520 complex, 50 to 75 percent slopes

Not prime farmland

31.46

2.35%

31.46

2.75%

Grandeposit3262 Majorsplace-Grube association

Not prime farmland

42.35

2.90%

42.35

3.70%

Farmland Classification

Project Project Project Project Footprint Footprint Boundary Boundary Acreage Percentage Acreage Percentage

Underground works are subsurface features that are included within the project boundary. Lands above these features would not be disturbed. 1

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 57

FERC-A1-39

Exhibit E

Water Resources

The level of detail provided in this section is not sufficient for staff to prepare its environmental analysis and to weigh the benefits of the proposed measures along with their costs (economic, generation, and other competing uses) and any alternative recommended measures. Therefore, please review the Guidance on Environmental Measures in License Applications available on the Commission’s website and revise the FLA to clearly describe all proposed measures, including the goals and objectives; where, when, and how they would be implemented; the project-related effects the measures address and its benefits to specific resources; relevant conceptual drawings and maps; any consultation with resource agencies leading to the measures; and costs (capital and annual). In Exhibit E– Section 3.4.1, Water Resources, indicates that no surface water would be affected, but five new groundwater wells would be drilled for the initial fill and periodic refill. Exhibit B– Section 4.2, Initial Fill, states this would use 5,000 acre-feet (AF), filled over 12 to 18 months, equal to the sum of active storage (4,082 AF); dead storage for the upper and lower reservoirs (176 AF and 159 AF, respectively); volume of the conveyance system (120 AF); and estimated net losses (approximately 240 to 560 AF) due to precipitation, evaporation, and leakage over the filling period. This would be completed under White Pine County’s permitted water rights of 20,000 AF per year. The estimate provided in Exhibit B – Section 4.3, Make-up Water, for annual losses of water in the system ranges from 140 AF to a maximum of 720 AF, with a conservative average of 360 AF lost per year and 560 AF needed per year for refill. The FLA notes that the State Engineer approved the change application to move the points of diversion and places of use for the new water rights permit, but it remains unclear if the water rights are currently being used for withdrawals from the groundwater aquifer. Please provide more information on current usage by the County and supply more details on the timeline for future hydrogeological studies referenced in Exhibit B – Section 3.3, Initial Fill and Make-up Water Sourcing and Delivery Alternatives. Additional information is needed regarding the application to the Bureau of Land Management for the proposed hydrogeological study in the vicinity of the project, and if there is a potential for subsidence as the result of proposed project operations. Finally, while it is noted by the Nevada Department of Environmental Quality that a 401 certification is likely not required, please include in the revised FLA a determination from the U.S. Army Corps of Engineers that documents if the project would impact Waters of the United States (WOTUS). Response Groundwater for the project will be produced via a wellfield array consis�ng of four (4) produc�on wells and a 3.8-mile buried pipeline conveyance delivering water to the project’s lower storage reservoir. The groundwater produc�on wellfield is designed to supply water for the ini�al lower reservoir fill at a rate of 3,000 gpm as well as provide make up water to the lower reservoir on a periodic basis at a much lower rate of up to 750 gpm. The produc�on wells are located and designed to target water producing Quaternary alluvial fill gravels located on the eastern side of Steptoe Valley. Each produc�on well is designed as a high-capacity industrial well producing a maximum of 1,000 gpm per well. The system maximum design produc�on rate is 4,000 gpm including a 25% redundant produc�on capability of 1,000 gpm. Water produced by the wellfield will be discharged from individual wells to a pipeline system ini�ally sized at 8-inch diameter then increasing in diameter as addi�onal well produc�on is added and line capacity requirements increase nearer the lower reservoir.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 58

The water rights are not currently being used for withdrawals from the groundwater aquifer by either the applicant or White Pine County. The hydrogeologic tes�ng program will include the drilling and construc�on of two hydrogeologic evalua�on (HE) holes (completed as test wells) and three (3) alluvial monitoring wells needed to test and monitor groundwater chemistry as well as track groundwater response to pumping. These wells will provide data on local aquifer stra�graphy, groundwater eleva�on and water chemistry needed to support the design of the water supply wellﬁeld as well as provide design data on water quality for design of the wider pump storage facility. The hydrogeologic tes�ng is subject to greater sage grouse seasonal restric�ons and, as such, can only be conducted between September 15 and October 31 in any given year, unless a waiver is granted by NDOW. In the absence of a waiver approval, the tes�ng will be conducted in 2024. An SF-299 applica�on for a land use permit from BLM has been submited. BLM requested addi�onal informa�on which is being prepared for submital. The BLM has indicated that the applica�on will likely be eligible for a categorical exclusion. Depending on workload, BLM approval is expected within three months. Geotechnical explora�on in the vicinity of the hydrogeologic test wells and the planned produc�on wells indicate that there is no expecta�on of subsidence. The objec�ves of the HE borehole / test well inves�ga�on includes: •

• •

Aquifer tes�ng, hydrogeologic characteriza�on and produc�vity assessment of the local alluvial aquifer that will be the primary source of water for the project. The HE boreholes will be completed as small diameter test wells in both loca�ons near MW-1 and MW-2. Evaluate and characterize hydrogeologic condi�ons to support the ﬁnal design of the produc�on wells and preliminary pump selec�on. Conversion to a standpipe piezometer to support baseline NEPA data collec�on. Following tes�ng the HE boreholes will be instrumented with vibra�ng wire piezometers (VWP) and data loggers to track and record background sta�c water levels through �me.

The objec�ves of the monitoring well drilling includes: • • • •

Establishing baseline groundwater levels and water quality along the eastern alluvial apron of Steptoe Valley. Provide alluvial inves�ga�on sites to characterize groundwater eleva�ons and alluvial stra�graphy, Func�on as piezometric monitoring points during the alluvial well pumping tests to es�mate aquifer proper�es from responses during aquifer tes�ng. Establish long-term groundwater monitoring at the site of the project wellﬁeld.

The applicant will file with FERC the SF-299 approval with its associated planned of development (POD). The applicant is consul�ng with the U.S. Army Corps of Engineers (USACE) regarding an Approved Jurisdic�onal Determina�on for applicability of 404 permi�ng for the Project. At this �me, the USACE has communicated to the applicant that it has put a hold on any jurisdic�onal determina�ons as a result of the recent Supreme Court ruling on May 25, 2023, in Sackett v. EPA. Agencies are developing a rule to amend the final “Revised Defini�on of ‘Waters of the United States’” rule, consistent with the US Supreme Court’s May 25, 2023, decision. The agencies intend to issue a final rule by September 1, 2023. At which

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 59

point, the applicant will con�nue to pursue an Approved Jurisdic�onal Determina�on with USACE to conﬁrm that a Sec�on 404 permit will not be required. Please see link below to USACE’s website for further informa�on: htps://www.usace.army.mil/Media/Announcements/Ar�cle/3440421/27-june-2023-update-supremecourt-ruling-in-sacket-v-environmental-protec�on/

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 60

FERC-A1-40

Exhibit E

Terrestrial Resources

The application defines the “project footprint” as the “area needed for construction workspace and includes the footprint of the permanent facilities”. Section 3.1.3.1 Major Land Uses and Ownership states that 1,338 acres would be permanently or temporarily disturbed by construction of the proposed project (i.e., the project footprint). Section 3.6.2.1 Project Effects on Terrestrial Habitats (Table 3.6-4) breaks down the acreage of each vegetation community type that would be permanently lost due to construction of the proposed upper and lower project reservoirs, which is 154.5 acres in total. However, the application does not similarly break down the remaining 1,183.5 acres within the project footprint that would be permanently lost due to construction of proposed project facilities or that would be temporarily affected by proposed construction activities. Therefore, please estimate the number of acres of each vegetation community type described in the application that would either be permanently lost or temporarily impacted by proposed project facilities and construction activities (as in Table 3.6-4) including, but not limited to, new access roads and detours, existing roads proposed to be widened, ROWs for the transmission line and conveyance facilities, concrete batch plants, staging and laydown areas, temporary structures (e.g., personnel trailers), quarries, hazardous waste and stockpile sites, demolition areas and other temporary sites to be used during proposed construction, etc. Also, please provide maps displaying where any proposed temporary facilities and construction activities would be located. The maps should also include vegetation community types as well as any other relevant wildlife habitat, wetlands, landscape features, etc. This information is necessary for staff to adequately describe and assess the significance of any potential adverse effects, which includes the location and extent of potential disturbance to vegetation communities and their associated species, within the project-affected area/project footprint. Response The applicant es�mates the number of acres of each vegeta�on community type described in the applica�on that would either be permanently or temporarily impacted by proposed project facili�es and related construc�on ac�vi�es. A total of 1,144 acres will be permanently impacted within the project boundary. An addi�onal 194 acres will be temporarily impacted within the project footprint. As a correc�on to the FLA, the proposed upper and lower reservoir structure facili�es are designed to occupy 154 acres, but the project boundary around these facili�es, which will accommodate project opera�ons, totals about 200 acres. A revised Table 3.6-4 is provided below. A new set of maps that display vegeta�on communi�es along with temporary disturbance areas and permanent features is included as Atachment 40-1. The applicant has conserva�vely assumed that all of the area within the project footprint will be impacted.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 61

Revised Table 3.6-4: Vegetation Communities within the vicinity of the Project

Project Area

Transmission Line and Substation

Landfire Vegetation Type

Acres within Project Boundary

Acres within Acres within Project Project Footprint and Footprint outside Project Boundary

AG - Agriculture

4.68

0.00

BIG - Inter-Mountain Basins Big Sagebrush Shrubland

10.46

0.00

BIGDIST - Inter-Mountain Basins Big Sagebrush Shrubland - Disturbed

0.69

0.00

DEV - Developed, Medium High Intensity

3.12

0.00

DIST - Disturbed, Non-Specific

0.32

0.00

MIXSCRUB - Inter-Mountain Basins Mixed Desert Scrub

7.11

0.00

NNG - Invasive Annual Grassland

1.41

0.00

No Data

1.84

0.00

PJC - Great Basin PinyonJuniper Woodland - Closed

279.35

280.07

0.72

PJO - Great Basin PinyonJuniper Woodland - Open

118.59

121.84

3.25

PJV - Great Basin PinyonJuniper Woodland - Very Open

25.69

0.00

RAIL - Railroad

0.53

0.00

ROAD - Hardscape Road

1.26

0.00

ROCK - Inter-Mountain Basins Cliff and Canyon

1.02

0.00

SALT - Saltlover Field

0.03

0.00

SAV - Great Basin Xeric Mixed Sagebrush Shrubland - Juniper Savannah

28.93

32.80

3.87

SERV - Great Basin Xeric Mixed Sagebrush Shrubland Serviceberry Shrubland

25.50

0.00

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 62

Project Area

Wellfield

Lower Reservoir

Landfire Vegetation Type

Acres within Project Boundary

Acres within Acres within Project Project Footprint and Footprint outside Project Boundary

XER - Great Basin Xeric Mixed Sagebrush Shrubland

182.59

185.90

3.31

XERBIG - Great Basin Xeric Mixed Sagebrush Shrubland Big Sagebrush Shrubland

41.79

0.00

XERDIST - Great Basin Xeric Mixed Sagebrush Shrubland – Disturbed

0.72

0.00

Totals

735.64

746.78

11.14

NNG - Invasive Annual Grassland

0.16

0.19

0.03

No Data*

0.98

2.57

1.59

XER - Great Basin Xeric Mixed Sagebrush Shrubland

34.09

50.38

16.29

XERDIST - Great Basin Xeric Mixed Sagebrush Shrubland Disturbed

0.00

0.01

Totals

35.23

53.15

17.92

GRASS - Inter-Mountain Basins Semi-Desert Grassland

2.43

0.00

MIXSCRUB - Inter-Mountain Basins Mixed Desert Scrub

0.19

0.36

0.17

MIXSCRUB - Inter-Mountain Basins Mixed Desert Scrub

0.00

NNG - Invasive Annual Grassland

2.83

4.61

1.78

NNG - Invasive Annual Grassland

0.00

No Data*

0.00

19.59

RAIL - Railroad

0.14

0.22

0.08

ROAD - Hardscape Road

0.19

1.67

1.48

SAV - Great Basin Xeric Mixed Sagebrush Shrubland - Juniper Savannah

0.04

0.05

0.01

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 63

Project Area

Underground Works**

Upper Reservoir Access

Upper Reservoir

Landfire Vegetation Type

Acres within Project Boundary

Acres within Acres within Project Project Footprint and Footprint outside Project Boundary

STEP - Inter-Mountain Basins Montane Sagebrush Steppe

75.87

84.28

8.41

XER - Great Basin Xeric Mixed Sagebrush Shrubland

43.80

94.05

50.25

XERDIST - Great Basin Xeric Mixed Sagebrush Shrubland Disturbed

1.64

2.97

1.33

Totals

127.14

210.24

83.81

No Data*

48.27

0.00

PJO - Great Basin PinyonJuniper Woodland - Open

0.13

0.00

STEP - Inter-Mountain Basins Montane Sagebrush Steppe

0.35

0.00

XER - Great Basin Xeric Mixed Sagebrush Shrubland

0.00

Totals

48.75

0.00

CERCO - Inter-Mountain Basins Curl-Leaf Mountain Mahogany Woodland

0.33

0.49

0.16

No Data*

77.13

163.56

86.43

PJO - Great Basin PinyonJuniper Woodland - Open

0.23

0.32

0.09

STEP - Inter-Mountain Basins Montane Sagebrush Steppe

1.91

0.00

XER - Great Basin Xeric Mixed Sagebrush Shrubland

5.10

10.31

5.21

Totals

84.70

176.10

91.40

CERCO - Inter-Mountain Basins Curl-Leaf Mountain Mahogany Woodland

1.86

2.25

0.39

CHAP - Great Basin SemiDesert Chaparral

1.97

0.00

PJO - Great Basin PinyonJuniper Woodland - Open

0.10

0.83

0.73

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 64

Project Area

Upper Reservoir Optional Access

Grand Total

Landfire Vegetation Type

Acres within Project Boundary

Acres within Acres within Project Project Footprint and Footprint outside Project Boundary

STEP - Inter-Mountain Basins Montane Sagebrush Steppe

69.03

85.36

16.33

Totals

72.96

90.91

17.95

CERCO - Inter-Mountain Basins Curl-Leaf Mountain Mahogany Woodland

1.17

1.75

0.58

CHAP - Great Basin SemiDesert Chaparral

5.02

7.57

2.55

No Data

22.55

34.88

12.33

PJC - Great Basin PinyonJuniper Woodland - Closed

1.59

2.57

0.98

PJO - Great Basin PinyonJuniper Woodland - Open

3.92

5.81

1.89

Rip - Inter-Mountain Basins Montane Riparian System

0.75

1.51

0.76

ROAD - Hardscape Road

0.10

0.24

0.14

STEP - Inter-Mountain Basins Montane Sagebrush Steppe

1.09

1.35

0.26

XER - Great Basin Xeric Mixed Sagebrush Shrubland

3.41

5.14

1.73

Totals

39.61

60.81

21.20

1,144.03

1,337.99

243.42

* No Data indicates areas that have not been surveyed for vegetation communities ** Underground works are subsurface features that are included within the project boundary. Vegetation communities above these features would not be disturbed. Source: LANDFIRE Landscape Fire and Resource Management Planning Tools, U.S. Department of Agriculture Forest Service and U.S. Department of the Interior, 2023.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 65

FERC-A1-41

Exhibit E

Terrestrial Resources

Section 3.6.2.1 Project Effects on Terrestrial Habitats states that project operation and maintenance activities would likely continue to affect vegetation, but at a lower intensity than during construction of the project, and that these activities would likely include periodic vegetation management along the proposed transmission line ROW and access roads, as well as around project facilities to provide access for maintenance and repairs. Please describe any proposed vegetation management activities related to project operation and maintenance activities around any facilities, access roads, and the rights-of-ways associated with the transmission line and water conveyance structures (e.g., penstock), including methods (e.g., mechanical, chemical), specific herbicides, approximate dates when proposed activities would occur, and vegetation cover types or specific plant species that would be potentially affected and/or targeted for control. Response The applicant will develop a Noxious Weed Management Plan (NWMP) for construc�on, opera�on, and maintenance of the project. The applicant will prepare the NWMP in coordina�on with BLM and NDOW and submit it to BLM for review and approval. The applicant will request a 30-day review by BLM and NDOW for comment and recommenda�ons before filing the NWMP with FERC. The NWMP will include measures to reduce the spread or introduc�on of noxious weed and invasive plant species. The NWMP will incorporate restric�ons and guidelines for applica�on of pes�cides, including herbicides, and avoidance of known sensi�ve plant species. The applicant will comply with BLM requirements regarding herbicide use on BLM lands. At a minimum, NWMP measures will include the following: •

•

• •

•

• • • •

Control introduc�on and spread of noxious weeds and invasive plants in the project footprint by cleaning vehicles and equipment prior to movement into the project footprint and/or prior to movement to a new loca�on within the project footprint, in order to minimize the poten�al for transpor�ng seeds. Worker awareness and responsibility training for control of noxious weeds and invasive plants. Training will include field iden�fica�on of weeds; reproduc�ve biology of weeds; ecological and economic impact of weeds; invasive plant preven�on Best Management Prac�ces (BMPs); inspec�on and cleaning protocols for vehicles, equipment, tools, and gear; and how to report occurrences for invasive or noxious plants. Inspec�on procedures and protocols for construc�on materials and equipment used in the project footprint. Work with land managers to develop and implement a plan to assess, treat, and monitor noxious weeds and invasive plants within the project footprint and in the adjacent landscape where they are present. Work with the local weed and pest district to implement long-term plans for successful restora�on and reclama�on of disturbed sites. The NWMP goals and objec�ves will include the following: Implement early detec�on and rapid response (EDRR) protocols through regular monitoring; Define containment strategies; Control movement of invasive and noxious plant material and seeds; Encourage the reduc�on of soil and vegeta�on disturbance; and

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 66

•

Maintain desired plant communi�es.

BMPs to be implemented during construc�on, opera�on, and maintenance include the following: • To prevent noxious weeds from spreading into the project footprint, prior to commencing grounddisturbing ac�vi�es, and during such ac�vi�es, a cer�fied biologist will survey the respec�ve areas of the project footprint and any associated access roads for popula�ons of noxious weeds. All popula�ons of noxious weeds within 50 feet of the permited ROW, roads, or access zones will be flagged and treated prior to the start of ground-disturbing ac�vi�es. • During the course of construc�on, at least once every growing season, noxious weed surveys will be conducted for new noxious weed popula�ons. Pedestrian transects (where permissible) will be completed of all incoming vector access points including ROWs, roads, and ground disturbances. The infesta�ons will be mapped, and then flagged, to eliminate foot or vehicular traffic from spreading the popula�on. The popula�on will be treated/controlled at the earliest possible �me. The utmost priority will be placed on controlling and elimina�ng EDRR species. Any detec�ons of noxious weeds will be reported to the appropriate agency. • Monitoring of exis�ng and previously treated infesta�ons will take place throughout the construc�on phase of the project to determine if the popula�ons are s�ll extant, the efficacy of the previous treatments, and if control measures should be altered. • A�er construc�on is complete, the applicant will inspect all sites where prior treatments occurred to determine if addi�onal treatments are required. Follow-up treatments will be completed if necessary. Post-construc�on noxious weed monitoring will occur during the growing season within one year a�er construc�on is completed, and on an ongoing basis annually.

• • •

Botanical resources related to the project were presented within Exhibit E, Sec�on 3.6 of the FLA, as well within the following appendices: Aqua�c Resources Delinea�on Study Report (HDR 2023a); 2022 Rare, Threatened, and Endangered Wildlife Species Assessment Study Report (HDR 2022); and Special-Status Plants and Noxious Weeds Study Report (HDR 2023b). The State of Nevada Department of Agriculture (NDA) has listed 54 weeds as noxious, which are categorized into three classes: Category A Weeds are weeds that are generally not found or that are limited in distribu�on throughout the state. Category B Weeds are weeds that are generally established in scatered popula�ons throughout the state. Category C Weeds are weeds that are generally established and generally widespread in many coun�es in the state. In addi�on, NDA now priori�zes and tracks Early Detec�on and Rapid Response (EDRR) species. These are Category A and B species that pose the most significant threat to Nevada’s rangeland, wildland, and agricultural areas if they were to be introduced, established, or spread. The EDRR list is currently composed of 39 species. A list of noxious weed species of par�cular concern to the BLM (Bristlecone Field Office) and the State of Nevada will be provided in the final NWMP.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 67

List of Noxious Weed Species of Concern: Common Name

Scien�ﬁc Name

Ra�ng

Black henbane

Hysocyamus niger

Carolina horse netle

Solanum carolinense

Dalma�on toadﬂax

Linaria dalmatica

Spoted knapweed

Centaurea biebersteinii

Diﬀuse knapweed

Centaurea diﬀusa

Giant reed

Arundo donax

Mayweed chamomile

Anthemis cotula

Perennial sowthistle

Sonchus arvensis

Medusahead rye

Taeniatherum caput-medusae

Sahara mustard

Brassica tournefortii

Silverleaf nightshade

Solanum elaeagnifolium

Canada thistle

Cirsium arvense

Hoary cress

Cardaria draba

Musk thistle

Carduus nutans

Scotch thistle

Onopordum acanthium

Russian knapweed

Acroptilon repens

Salt cedar

Tamarix spp.

Poison hemlock

Conium maculatum

Whitetop

Lepidium draba

The Special-Status Plants and Noxious Weeds Study Report, iden�ﬁed a total of three noxious species that are present within the botanical study area of the project footprint: • Canada Thistle (Cirsium arvense) is a Category C rated noxious weed and was observed along Duck Creek and at one spot along an access road of the proposed upper reservoir. In the study area, Canada thistle generally grows in moderately disturbed habitats either along a road or watercourse. The total es�mated popula�on for Canada thistle in the study area is 90 individuals (HDR 2023b). • Musk Thistle (Carduus nutans) is a Category C rated noxious weed and was observed at three loca�ons along Duck Creek. In the study area, musk thistle grows along the Duck Creek stream margins in areas with a rela�vely open canopy. The total observed popula�on for musk thistle in the study area is 13 individuals (HDR 2023b). • Whitetop (Lepidium draba) is a Category C rated noxious weed and was observed at McGill Spring adjacent to an access road of the proposed upper reservoir. In the study area, whitetop grows at the crest of the depression leading into McGill Spring. The total es�mated popula�on for whitetop in the study area is 50 individuals (HDR 2023b). Cheatgrass (Bromus tectorum) was also observed within the botanical study area. Cheatgrass is not rated as a noxious weed by the NDA (Nevada Department of Agriculture 2021). Cheatgrass is White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 68

widespread throughout the majority of the botanical study area and was only no�ceably absent from the Smith Valley and Steptoe Valley por�ons of the proposed transmission corridor. Areas of rela�vely high concentra�on of cheatgrass were found in the northern half of the upper reservoir vicinity, the western half of the proposed lower reservoir vicinity, and a por�on of the proposed transmission corridor approximately three miles from the Robinson Summit Substa�on. Areas of very high concentra�on of cheatgrass, suﬃcient to make the vegeta�on type of the area be an invasive annual grassland, are found in the northwestern por�on of the proposed lower reservoir vicinity. These areas of invasive annual grassland are mapped in the 2022 Rare, Threatened, and Endangered Wildlife Species Assessment Study Report. The total es�mated popula�on of cheatgrass in the botanical study area is over 100,000 individuals (HDR 2023b). Treatment Methods:

•

• •

•

The applicant will include the requirements for herbicide treatments in the NWMP and will implement noxious weed control measures that will be in accordance with exis�ng regula�ons and jurisdic�onal land management agency agreements. Before construc�on, only herbicides that are approved by the State of Nevada and the BLM will be applied to any iden�fied weed infesta�ons on public lands to reduce the spread or prolifera�on of weeds. Post-construc�on control measures may include one or more of the following methods: Mechanical methods rely on equipment used to mow or disc weed popula�ons. If such a method is used, subsequent seeding will be conducted to re-establish a desirable vegeta�ve cover that will stabilize the soils and slow the poten�al re-invasion of noxious weeds. Seed selec�on will be based on site-specific condi�ons, the appropriate seed mix iden�fied for those condi�ons, and will be approved by the BLM for applica�on on public lands. Disking or other mechanical treatments that would disturb the soil surface within na�ve habitats will be avoided. Herbicide applica�on is an effec�ve means of reducing the size of noxious weed popula�ons and any applica�on to any iden�fied weed infesta�on on public lands will be approved by the State of Nevada and the BLM. Only a State of Nevada licensed contractor, who is also approved by the BLM, will perform herbicide applica�ons. All herbicide applica�ons must follow United States Environmental Protec�on Agency label instruc�ons. Treatment methods will be based on species-specific and area-specific condi�ons (e.g., proximity to agricultural areas, �me of year, soil condi�ons, etc.) and will be coordinated with the local regulatory offices. A Pes�cide Applicator Record (PAR) will be prepared for any herbicide treatments. If areas are not seeded un�l the following spring because of weather or scheduling constraints, all annuals and undesirable vegeta�on that have become established will be treated before seeding.

The invasive plant species found in and adjacent to the project footprint are known to occur throughout the western United States and are spread by various land uses. The combina�on of past and present land use ac�vi�es in the vicinity of the project has contributed to and likely will con�nue to facilitate the crea�on of disturbed and weedy habitats. It is well known that many types of land uses contribute to the invasion and spread of non-na�ve invasive species including ground-disturbing ac�vi�es as well as ac�vi�es that promote the dispersal of weed seed. Roads, agriculture, farming/ranching, recrea�on, and residen�al and commercial developments all can contribute to the spread of invasive botanical species.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 69

The applicant will minimize and control the spread of invasive botanical species that could result from construc�on and opera�on of the project through development of a Noxious Weed Management Plan. Given adequate and appropriate weed management and site restora�on ac�vi�es, the project should have minimal nega�ve effects on plant communi�es and could provide a net benefit by reducing weed infesta�ons in the project footprint and vicinity. Thus, the project is not expected to have significant impacts to the landscape from the spread of noxious weed species.

Cita�ons: Bureau of Land Management (BLM). 2009. 2017. Updated Bureau of Land Management (BLM). Sensi�ve Species List for Nevada. Reno, Nevada. Accessed March 17, 2021. htps://www.blm.gov/policy/nv-im-2018-003 Nevada Department of Agriculture. 2021. “Nevada Noxious Weed List.” Last updated February 2, 2021. htp://agri.nv.gov/Plant/Noxious_Weeds/Noxious_Weed_List/. Sparks, Nevada. Nevada Department of Agriculture. 2022. “Weed Management Cost Share Request for Proposals: Atachment B Nevada Early Detec�on and Rapid Response Species. Sparks, Nevada. Special-Status Plants and Noxious Weeds Study Report. 2023b. Prepared by HDR Engineering, Inc for White Pine Waterpower, LLC.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 70

FERC-A1-42 (a) Exhibit E

Terrestrial Resources

As discussed above under item # 31, more specific information is needed for staff to understand the proposed resource management plans, including their respective goals, objectives, provisions and measures, methods, reporting, and implementation schedules. Also, please indicate, where relevant, the resource- and/or site-specific impacts that any proposed measures would mitigate. Please address the following information needs listed below. (a) Erosion and Sediment Control Plan – describe in detail the proposed methodologies and protocols to minimize effects of windblown and fugitive dust generated from proposed construction activities, equipment, and vehicles on air quality, vegetation, and wildlife in the project area (e.g., application of water or dust-control chemicals). The plan should also include a discussion of any potential impacts and measures to mitigate effects associated with proposed measures to minimize fugitive dust (e.g., environmental effects of dust-control chemicals). Response FERC requested more specific informa�on on the proposed Erosion and Sediment Control Plan (ESCP), including goals, specific measures, methodologies, and proposed implementa�on schedule. The applicant is developing an ESCP that will address this specific informa�on, as outlined below. The applicant proposes that within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing ac�vity, whichever comes first, the applicant will file for FERC approval of an ESCP to minimize poten�al adverse impacts of erosion, and other pollutants. The ESCP will be designed such that the final approved ESCP can be tailored for future ac�ons requiring Temporary ESCPs, such as construc�on projects that could arise during the life of the project a�er ini�al construc�on. The ESCP will include, at a minimum: • • • •

•

• •

A narra�ve descrip�on and a map (where applicable) showing the project work areas; Supervision, inspec�on and responsibili�es of the Environmental Inspector responsible for implemen�ng the ESCP; Environmental training details for all contractors that will be on-site during construc�on; Details on how to control sediment and other pollutants on the construc�on site by using control prac�ces throughout the dura�on of the construc�on project and providing future stabiliza�on of the site, including techniques for reservoir and underground facili�es (piping and pumps), typical ROW requirements, and access roads; Standard erosion and sediment control Best Management Prac�ces (BMP) (see below), including measures such as construc�on site disturbance minimiza�on and boundary marking, sediment ponds, sediment trapping pads and booms, silt fences, straw waddles, and temporary ma�ng; Sequencing, inspec�on, and maintenance procedures for BMPs will be included in the project speciﬁc Temporary ESCPs as they are developed for future use in post-license issuance construc�on and maintenance projects; A site inspec�on form which tracks structure types, inspec�on details, treatment details, slope stability observa�ons, seepage observa�ons, surface soil erosion observa�ons, details on proximity to water, photos, comparison to previous inspec�ons, and risk assessments; Ac�ons to address earthworks in soils that are highly erodible; and Post-construc�on ac�vi�es, including monitoring for uplands and waterbodies.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 71

• • •

• • • •

As noted above, the following is a list of poten�al BMPs that will be included in the ﬁnal ESCP, as recommended by the State of Nevada, to specify erosion control measures to help minimize poten�al adverse impacts: Stabilizing truck exit areas for washing the wheels of all trucks that enter paved roadways from the construc�on site and dirt roads leading from the construc�on site; Installing tracking pads at construc�on exits to prevent dirt from being tracked onto roadways; Applying water or dust reducing agents to all exposed surfaces on project lands, as needed, during dry weather, including, but not limited to soil piles, graded areas, unpaved parking areas, staging areas, and project access roads, or, in cases where project access roads would remain in place for an extended dura�on, covering the routes with gravel to avoid re-suspension of dust; Covering and maintaining at least two feet of free board space on haul trucks transpor�ng soil, sand, or other loose material at the project; Paving all project roadways, driveways, sidewalks, and parking lots as soon as possible and laying building pads as soon as possible a�er grading unless seeding or soil binders are used; Incorpora�ng dust control measures (e.g., dust collectors and covers limi�ng pathways for dust) into the temporary concrete batch plant, if used at the construc�on site; and Establishing inspec�on and maintenance programs and signage to minimize idling �me of construc�on equipment on project lands.

The applicant will prepare the ESCP a�er consulta�on with the Nevada Division of Environmental Protec�on (NDEP) and the BLM. The ESCP will include documenta�on of consulta�on, copies of comments and recommenda�ons on the completed ESCP a�er it has been prepared and provided to the agencies, and specific descrip�ons of how the agencies’ comments are accommodated by the ESCP. The applicant will allow a minimum of 30 days for all relevant state, federal, and local agencies to comment and make recommenda�ons before filing the ESCP with FERC. If the applicant does not adopt a recommenda�on, the filing will include the applicant’s reasons, based on project-specific informa�on.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 72

FERC-A1-42 (b) Exhibit E

Terrestrial Resources

(b) Noxious Weed Management Plan – describe in detail the proposed methodologies and protocols for controlling any non-native, invasive plants that could be introduced and spread by construction, operation, and maintenance of the proposed project, including control measures (e.g., mechanical and/or herbicide use); measures to minimize transport and introduction of invasive plant propagules on project equipment and vehicles, and in materials (e.g., fill); monitoring and success criteria to evaluate the implementation of measures to meet the plan’s stated goals and objectives; protection of any special-status species that could be affected as a result of plan implementation; any proposed monitoring and control measures during operation of the project; agency consultation; etc. Response FERC requested more specific informa�on on the proposed Noxious Weeds Management Plan (NWMP), including goals, specific measures, methodologies, and proposed implementa�on schedule. The applicant is developing an NWMP that will address this specific informa�on, as outlined below. The applicant proposes that within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing ac�vity, whichever comes first, the applicant will file for FERC approval a NWMP to reduce the spread or introduc�on of noxious weed and invasive plant species during construc�on and opera�on and maintenance of the project. At a minimum, the plan will include measures to: • •

•

• • • •

•

Prevent introduc�on and establishment by cleaning vehicles and equipment prior to movement to a new loca�on in order to minimize the poten�al for transpor�ng seeds; Work with land managers to develop and implement a plan to assess, treat, and monitor noxious weeds and invasive plants at the project and in the adjacent landscape where they are present; and Work with the local weed and pest district to implement long-term plans for successful restora�on of disturbed sites. NWMP goals and objec�ves include the following: Stop movement of invasive and noxious plant material and seeds; Where feasible, reduce soil and vegeta�on disturbance; Maintain desired plant communi�es; and Prac�ce early detec�on and rapid response (EDRR) through regular monitoring. Common BMPs to be implemented during the construc�on and opera�on and management phases include the following: The applicant will keep their project area free of state-listed noxious weeds. The applicant shall perform annual monitoring for invasive and noxious weed species. Any detec�ons of noxious weeds will be reported to the appropriate agency. To reduce the accidental spread of noxious weeds, the applicant and any contractors shall avoid or minimize all types of travel through state-listed, noxious weed-infested areas that can be carried to the project area. Project-related equipment will be cleaned of all mud, dirt, and plant parts before moving into rela�vely weed-free areas or out of rela�vely weed-infested areas. Project workers shall inspect, remove, and dispose of weed seed and plant parts found on their clothing and personal equipment, bag the plant products, and dispose of them in a dumpster.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 73

•

The applicant will review the annual weed inventory prior to any ground disturbing ac�vi�es; limit the size of any vegeta�on and/or ground disturbance to the absolute minimum necessary to perform the ac�vity safely and as designed; begin ac�vi�es in weed free areas whenever feasible before opera�ng in weed-infested areas; locate equipment storage, machines, and vehicle parking or any other area needed for the temporary placement of people, machinery, and supplies in areas that are rela�vely weed free; and avoid or minimize all types of travel through weed-infested areas or restrict major ac�vi�es to periods of �me when the spread of seed or plant parts are least likely. Use of pes�cides and herbicides shall comply with all applicable Federal and State laws. Pes�cides and herbicides shall be used only in accordance with their registered uses within limita�ons imposed by the appropriate agency. Prior to the use of the pes�cides, the applicant shall obtain from the BLM or other appropriate agency, writen approval of a Pes�cide Use Plan, showing the type and quan�ty of material to be used, pest(s) to be controlled, method of applica�on, loca�ons of storage and disposal of containers, and any other informa�on deemed necessary by the BLM or other appropriate agency. Implementa�on of a pre-work training program (see PM&E 7: Biological Resources Protec�on Training Program) on invasive plants and preven�on BMPs to staff and contractors. Training will include: field iden�fica�on of weeds; reproduc�ve biology of weeds; ecological and economic impact of weeds; invasive plant preven�on BMPs; inspec�on and cleaning protocols for vehicles, equipment, tools, and gear; and how to report occurrences for invasive or noxious plants.

The applicant will prepare the NWMP a�er consulta�on with BLM. The NWMP will include documenta�on of consulta�on, copies of comments and recommenda�ons on the completed NWMP a�er it has been prepared and provided to the agencies, and specific descrip�ons of how the agencies’ comments are accommodated by the NWMP. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommenda�ons before filing the NWMP with FERC. If the applicant does not adopt a recommenda�on, the filing will include the applicant’s reasons, based on project-specific informa�on.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 74

FERC-A1-42 (c) Exhibit E

Terrestrial Resources

(c) Habitat Restoration, Reclamation, and Enhancement Plan – describe in detail the proposed methodologies and protocols for restoration and revegetation efforts including methods to salvage protected cacti species prior to construction; identification of appropriate native plant species for revegetation including consideration of site-specific conditions; planting designs, locations, and methods including maintenance of revegetated areas; regrading of disturbed ground (e.g., temporary access roads); control of invasive plant species that could affect revegetation efforts; monitoring and success criteria to evaluate the implementation of measures to meet the plan’s stated goals and objectives; estimate the acres for each habitat type that is anticipated would need restoration; etc. Response Pursuant to the Federal Land Policy and Management Act, the applicant an�cipates that early development and finaliza�on of a Habitat Revegeta�on, Restora�on, and Enhancement Plan (HRREP) to clearly iden�fy measures for the management, avoidance, and mi�ga�on of poten�al habitat and associated vegeta�on losses during construc�on and opera�on and maintenance of the project will be necessary to obtain a ROWGrant Authoriza�on and Record of Decision from BLM. Accordingly, the applicant will ini�ate early consulta�on with relevant agencies to develop the HRREP prior to FERC’s issuance of a license for the project. The applicant an�cipates that a NEPA-ready Habitat Revegeta�on, Restora�on, and Enhancement Plan (HRREP) would be dra�ed prior to commencement of the NEPA process, such that the expected outcomes of restora�on and specific mi�ga�on measures could be integrated into the impacts analysis. Typically, restora�on plans are developed prior to FERC’s environmental assessment to provide a framework of proposed reclama�on ac�vi�es. The HRREP would primarily be focused on impacts from construc�on and ongoing post-construc�on restora�on. As the project moves closer to construc�on, a more detailed (i.e., NTP-ready) HRREP would be developed with sufficient detail for construc�on contractors to implement the required revegeta�on and restora�on ac�ons and appropriate mi�ga�on measures. At a minimum, the HRREP would include the following: • • • • •

Specific restora�on and habitat mi�ga�on requirements for greater sage-grouse and other special status wildlife species that may require special restora�on considera�ons; Es�mate of acreage for each habitat type needing restora�on in various soil types and vegeta�on communi�es; Clear ar�cula�on of goals and objec�ves for habitat revegeta�on, restora�on, and enhancement that will be implemented post-construc�on; Descrip�on of revegeta�on efforts to prevent soil erosion and the spread of weeds, maintain or restore exis�ng na�ve plant communi�es and wildlife habitat, and integrate site features with the surrounding environment; Iden�fica�on of specific measures to restore vegeta�on disturbed by project-related construc�on ac�vi�es, including proposed methodologies/protocols for implementa�on, seed mix and/or plant species specifica�ons (which would consider soil types, local vegeta�on communi�es, and environmental condi�ons), regrading of disturbed ground (e.g., temporary access roads), site prepara�on approach (e.g., topsoil handling, recontouring, soil analysis and amendments, seedbed prepara�on), plan�ng designs and loca�ons, and ongoing maintenance methods for revegetated areas;

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 75

• • • • • • • •

Iden�fica�on of appropriate na�ve plant species for revegeta�on, including considera�on of site-specific condi�ons; Iden�fica�on of methods to salvage protected cac� before ground disturbance in compliance with Nevada regula�ons; Specifica�on of methods for control of invasive plant species that could affect revegeta�on efforts; Iden�fica�on of site-specific restora�on, reclama�on, and enhancement measures should future temporary ground disturbance be needed; Clear ar�cula�on of monitoring and success criteria to evaluate the implementa�on of measures that will meet the HRREP’s stated goals and objec�ves; Defini�on of monitoring requirements and methods (e.g., monitoring approach, determina�on of control plot for monitoring, and �me frames and milestones, data, and repor�ng); Descrip�on of an adap�ve management approach to address issues that arise if ini�al restora�on or revegeta�on efforts do not meet success criteria; Clear development of an es�mate of costs associated with the restora�on methods, ongoing maintenance, and final restora�on, which will be adapted from standard reclama�on cost es�mate procedures, as provided by the appropriate agency.

The applicant will prepare the HRREP a�er consulta�on with the BLM Ely District’s Bristlecone Field Office of the BLM (following the Ely District BLM RMP/ROD), NDOW, Nevada SETT, and other required agencies. The HRREP will include documenta�on of consulta�on, copies of comments and recommenda�ons on the completed plan a�er it has been prepared and provided to the agencies, and specific descrip�ons of how the agencies’ comments are accommodated by the HRREP. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommenda�ons before filing the HRREP with FERC. If the applicant does not adopt a recommenda�on, the filing will include the applicant’s reasons, based on project-specific informa�on.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 76

FERC-A1-42 (d) Exhibit E

Terrestrial Resources

(d) Noise Mitigation Strategies – Table 2.2-3 states that noise modeling results will inform the development of additional mitigation strategies, if needed, to reduce potential effects of project-related noise at sagegrouse leks. The FLA describes several proposed construction activities that would generate levels of noise that are significantly above ambient conditions (e.g., blasting). Accordingly, it is unclear why measures to minimize the impacts of noise on wildlife species, including the greater sage-grouse, have not already been developed in consultation with the relevant resource agencies. Therefore, please proceed to consult with the resource agencies to develop appropriate measures to minimize and mitigate the potential effects of noise on wildlife species. Also, please clarify if proposed noise mitigation for the greater sage-grouse would be included as part Greater Sage-Grouse Mitigation Plan or as part of a separate plan. Response As discussed in the Greater Sage-Grouse Lek and Habitat Study Report (2023) (Appendix D of the FLA), a previous noise modeling study was conducted within ¼ mile from eight lek sites to compare pre-project noise levels to an�cipated noise levels during construc�on and opera�on and maintenance of the proposed project. Noise monitoring systems were deployed May 4, 2021 and collected on May 18, 2021. The construc�on noise modeling results show that construc�on noise is expected to exceed the limits at almost all leks, both with the upper and lower reservoir ac�vi�es combined and individually; however, noise levels during opera�on are expected to be within the allowable L50 limits at each lek. Since a few project features have been changed since the noise modeling was conducted in 2021 (i.e. upper reservoir access road, the alignment, layout, and design of the upper reservoir, etc.), the applicant will conduct an addi�onal noise modeling study in 2024 to further aid in efforts to minimize the effects of noise related to construc�on and opera�on and maintenance of the proposed project, notably effects to greater sage-grouse, by iden�fying current noise levels at the site and evalua�ng the changes to those levels as a result of the proposed project. Predicted construc�on-generated noise levels at nearby receptors will be calculated using the Federal Highway Administra�on Roadway Construc�on Noise Model (RCNM). The RCNM is FHWA’s na�onal model for the predic�on of construc�on noise. This so�ware is based on actual sound-level measurements from various equipment types taken during the Central Artery/Tunnel project conducted in Boston, Massachusets, during the early 1990s. The maximum noise levels presented at a specified distance from the source are based on a roster of likely construc�on equipment opera�ng. Although the project is not a road construc�on project, the RCNM includes the same types of equipment that would be used in the construc�on of the project. Noise impacts will be es�mated for the opera�ons on the project site. Ac�vi�es that would generate noise levels are mechanical sound from pumps, water conveyance, turbines, transformers, and road access. Noise impact assessment for the opera�onal phase will be based on engineering calcula�ons for the pieces of noise-genera�ng equipment at the proposed site using SoundPLAN Essen�al Version 5.1. The model incorporates a three-dimensional geometric model of the study area developed from digital terrain informa�on, available GIS informa�on, grading data, and aerial photography. SoundPLAN Essen�al v5.1 incorporates more than 25 noise modeling standards and provides a set of model solu�ons/standards for outdoor noise modeling that include the Interna�onal Organiza�on for Standardiza�on (ISO) 9613-2 general environmental noise model (point and line area sources). The noise study will include a noise White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 77

isopleth receptor map of the analysis area. The significance of noise-related impacts will be determined in comparison to applicable local, state, and/or federal noise standards. The final noise study report will include documenta�on of consulta�on, copies of comments and recommenda�ons on the completed report a�er it has been prepared and provided to the agencies, and specific descrip�ons of how the agencies’ comments are accommodated by the final noise study report. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommenda�ons before filing the final noise study report with FERC.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 78

FERC-A1-42 (e) Exhibit E

Terrestrial Resources

(e) Pre-Construction Surveys – Table 2.2-3 states that based on survey results, White Pine would consult with applicable regulating agencies to identify reasonable avoidance and mitigation measures to reduce effects to nesting raptors and other migratory bird species nesting in the project area. Staff cannot evaluate measures that may be developed at some future, unspecified date. Therefore, staff require more information to evaluate this plan in the NEPA analysis. Please consult with FWS, NDOW, and BLM to development avoidance and mitigation measures for nesting birds to describe in the revised FLA. Refer to FWS’ Avian Protection Plan (APP) Guidelines available on its website for additional guidance. Response FERC requested more specific informa�on on the proposed plan to address avoidance and mi�ga�on measures that may be developed for nes�ng birds. The applicant intends to conduct consulta�on with the USFWS, NDOW, Nevada SETT, and the BLM to determine the appropriate �ming and level of effort for preconstruc�on surveys. The applicant proposes that within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing ac�vity, whichever comes first, the applicant will complete pre-construc�on botanical surveys, wildlife surveys, and habitat assessments, as determined through consulta�on with relevant agencies. Surveys will be conducted by trained biologists in areas that will be disturbed by the proposed project. Specific pre-construc�on ac�vi�es may include, but are not limited to, surveys for the following: • • • •

Raptors and raptor nests within the project vicinity; Nes�ng migratory birds; Protected wildlife and plant species; and Lek counts for greater sage-grouse leks within 3.1-miles of project components, as coordinated with the NDOW.

Based on the findings of the surveys, the applicant will consult with applicable regula�ng agencies for the pre-construc�on survey requirements. Based on the findings of the surveys, the applicant will consult with applicable regula�ng agencies to iden�fy reasonable avoidance or mi�ga�on measures (AMMs) to reduce adverse impacts. The applicant will use the best available resources, science, and AMMs protect sensi�ve biological resources, including the USFWS Avian Protec�on Plan (APP) Guidelines and BLM Ely RMP, and BLM Nevada’s Statewide Wildlife Survey Protocols. Upon comple�on of the surveys, the applicant will prepare a study report and provide it to relevant agencies for comment review. The final report will include documenta�on of consulta�on, copies of comments and recommenda�ons on the completed report a�er it has been prepared and provided to the agencies, and specific descrip�ons of how the agencies’ comments are accommodated by the final report. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommenda�ons before filing the final report with FERC.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 79

FERC-A1-42 (f) Exhibit E

Terrestrial Resources

(f) Raptor and Bat Protection Plan – Table 2.2-3 states that White Pine would develop the plan in consultation with FWS and NDOW prior to the onset of ground disturbance at the start of construction activities. Staff require more information to evaluate this plan in the NEPA analysis. Therefore, please consult with FWS and NDOW now to complete the development of this plan to describe in the revise FLA. Also, the plan includes a provision for protective spatial buffers around active raptor nests, which seems duplicative with the proposed measures for pre-construction surveys. To avoid confusion when staff evaluate proposed measures to potentially recommend as conditions of any license that could be issued for the proposed project, including project costs, please clarify and ensure proposed plans and measure are organized appropriately to avoid overlap and redundancy in measures. Response FERC requested more specific informa�on on the proposed Raptor and Bat Protec�on Plan (RBPP), including goals, specific measures, methodologies, and proposed implementa�on schedule. The applicant is developing an RBPP that will address this specific informa�on, as outlined below. The applicant proposes that within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing ac�vity, whichever comes first, the applicant will file for FERC approval a RBPP to protect avian species from collision or electrocu�on as a result of landing or perching on transmission lines. At a minimum, the RBPP will include: •

•

Nes�ng bird and raptor survey protocols (see PM&E 12) to be implemented Within two weeks of the commencement of construc�on ac�vi�es. The pre-construc�on survey area will include the Project Area and a 0.25-mile to 0.5mile buffer around project features. Previous surveys have resulted in no iden�fied nes�ng loca�ons. Based on the results of pre-construc�on surveys, the applicant will develop appropriate seasonal or spa�al buffers, if necessary, in consulta�on with Nevada Department of Fish and Wildlife (NDOW), the U.S. Bureau of Land Management (BLM), and the USFWS Region 8 that incorporate the applicant’s goal of certain construc�on ac�vi�es (tunneling, concrete batch plant opera�on, construc�on of reservoirs, etc.) being conducted on a 365/24/7 schedule that is not limited by wildlife restric�ons, to the extent possible. Mi�ga�on measures and BMPs to minimize impacts to raptor and bat species (i.e., descrip�on of where to install visibility enhancement devices to reduce risk of collision on new or exis�ng lines; descrip�on of where to install perch guards between closely spaced conductors above arms and conductors to keep raptors from contac�ng energized parts; descrip�on of where flight diverters will be most effec�ve; a descrip�on of regular maintenance of the transmission line and retrofi�ng the lines as applicable; a descrip�on of safe alterna�ve loca�ons for perching and nes�ng); Raptor-safe guidelines for all new electrical construc�on (see PM&E 10): Detailed avian collision and electrocu�on monitoring plan, that describes methods, implementa�on schedule, quan�fiable thresholds for determining when correc�ve measures would need to be implemented to address high-collision and electrocu�on areas along the transmission line or at the reservoir fences, and procedures for documen�ng and repor�ng bird fatali�es and injuries to NDOW, BLM, and the USFWS; A provision for filing with the Commission a report by March 31 of each year that includes: the results of any surveys or monitoring, any occurrence of project-related avian injuries/mortali�es,

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 80

• • •

es�mated fatality rates, and any recommenda�ons for correc�ve measures, if necessary. The licensee must allow a minimum of 30 days for the resource agencies to comment on the report before ﬁling it with FERC; Employee training to ensure plan compliance, pursuant to PM&E 7; Repor�ng system for avian and bat injuries and fatali�es; Adap�ve monitoring and management plan.

The plan will address how the applicant considered the Avian Power Line Interac�on Commitee’s (APLIC) guidelines: Suggested Prac�ces for Avian Protec�on on Power Lines, The State of the Art in 2006 [APLIC 2006] and Reducing Avian Collisions with Power Lines: The State of the Art in 2012 [APLIC 2012]) to protect avian species from collision or electrocu�on as a result of landing or perching on transmission lines. The applicant will consult with BLM and NDOW regarding the RBPP. The RBPP will include documenta�on of consulta�on, copies of comments and recommenda�ons on the completed RBPP a�er it has been prepared and provided to the agencies, and specific descrip�ons of how the agencies’ comments are accommodated by the RBPP. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommenda�ons before filing the RBPP with FERC. If the applicant does not adopt a recommenda�on, the filing will include the applicant’s reasons, based on project-specific informa�on.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 81

FERC-A1-42 (g) Exhibit E

Terrestrial Resources

(g) Reservoir Wildlife Exclusion – the presence of artificial water sources, particularly in arid regions, is likely to attract wildlife seeking water to drink. Also, some wildlife species may still be able to gain access to the reservoirs due to their smaller size or their ability to burrow under (e.g., pygmy rabbit) or climb over the proposed 10-foot-high game fencing. Section 2.2.1 Project Facilities states that the proposed upper and lower reservoirs would be designed with an impermeable liner to reduce water losses from seepage. We note that the materials for such liners are often relatively smooth and potentially afford little traction for wildlife that may enter the reservoir, which could cause wildlife to become trapped and drown. Therefore, please describe in more detail the design of the proposed reservoirs, including the steepness of the shoreline, additional materials or structures around the reservoir perimeter that could be used by stranded wildlife to exit the water, and what the proposed monitoring of the reservoirs would entail. Response FERC requested more specific informa�on on the proposed measures regarding wildlife exclusions to the reservoir to mi�gate for poten�al game species that may be atracted to the ar�ficial water source given the arid habitat of the proposed project loca�on. The applicant proposes that within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing ac�vity, whichever comes first, the applicant will coordinate with the wildlifefocused TWG to develop measures to prevent catle, wild ungulates, and other medium- to large-sized animals from accessing the reservoirs. At a minimum, reservoir wildlife exclusions measures will include: • • • • • •

Installa�on of a 10-foot-tall game fence and gate(s) at the toe of the embankment of each reservoir; Installa�on of a geomembrane inside each reservoir; Installa�on of a one-way exit gate to facilitate a safe exit in the event that wildlife was to enter the fenced-oﬀ area; and Regular maintenance on the materials and structures around the reservoir perimeter; and Rou�ne monitoring to ensure the fencing has not failed. Installa�on of mo�on detectors inside reservoir perimeter fencing.

Specific measures will be determined in coordina�on with the wildlife-focused TWG and included in final construc�on design. Measures implemented at the project for reservoir wildlife exclusion will be included in the Public Safety Plan to be filed with FERC, as proposed under PM&E 22.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 82

FERC-A1-42 (h) Exhibit E

Terrestrial Resources

(h) Pygmy Rabbit Management – Section 3.7.2.3 Rare, Threatened, and Endangered Wildlife Species states that direct mortality of the pygmy rabbit, a BLM sensitive species, could occur through destruction of occupied burrows during vegetation clearing, excavation, and grading, or by collision with vehicles on project roads. The FLA proposes to avoid active pygmy rabbit habitat during proposed construction, when feasible, and if habitat cannot be avoided, BLM would be consulted to coordinate the develop of appropriate mitigation measures. Because suitable habitat for the pygmy rabbit occurs throughout the project area, please consult with BLM now to develop appropriate measures to minimize impacts to this sensitive species and describe the measures in the revised FLA. Also, please describe the methodology for identifying and avoiding active habitat during construction. Response The pygmy rabbit is classified as a NDOW “Species of Special Concern” and a BLM sensi�ve species. Field studies conducted within the project study area have not iden�fied pygmy rabbit individuals or evidence of pygmy rabbit habitat use to date, but the project study area is in the known range of the species and suitable habitat is present (HDR 2022b). Direct mortality can occur by destruc�on of occupied burrows during vegeta�on clearing, excava�on, and grading, or by collision with vehicles on roads to and from the project. As discussed under PM&E 12, within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing ac�vity, whichever comes first, the applicant will complete pre-construc�on wildlife surveys and habitat assessments for pygmy rabbits, as determined through consulta�on with relevant agencies. Surveys will be conducted by trained biologists in areas that will be disturbed by the proposed project. During construc�on of the project, ac�ve pygmy rabbit habitat use will be avoided when feasible. Avoidance and minimiza�on measures during construc�on will be coordinated with the BLM and NDOW, and may include: • •

• • • •

•

Incorpora�ng into the construc�on ROW the use of exis�ng roads as to reduce the amount of new surface disturbance required for the ROW area; Making micro-adjustments to the proposed project construc�on footprint to reduce the incursion into suitable habitat for pygmy rabbits (e.g., routes could be shi�ed slightly to avoid an important feature such as an ac�ve burrow); Upgrades to exis�ng roads will be limited to situa�ons where the road would not be otherwise passable by construc�on equipment; Avoid cu�ng vegeta�on in areas of suitable pygmy rabbit habitat, and re-seed as part of restora�on post-construc�on; To the maximum extent possible, restore the vegeta�on in the project footprint to achieve similar composi�on, diversity, and cover to that of the surrounding desert landscape; As described in the NWMP, implement a comprehensive invasive species plant control program to prevent the introduc�on of noxious and invasive plants in areas disturbed by project construc�on; and Implement dust control measures as outlined in the ESCP, to limit release of dust from access roads and other project areas.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 83

If ac�ve pygmy rabbit habitat use cannot be avoided, BLM and NDOW will be contacted, and appropriate mi�ga�on measures will be developed.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 84

FERC-A1-43

Exhibit E

Terrestrial Resources

To mitigate the effects of the proposed project on wildlife, the FLA proposes to implement Wildlife Seasonal Restrictions (PM&E #18) in consultation with BLM Nevada Department of Wildlife (NDOW) to plan for construction windows that provide for wildlife protection and allow for feasible project construction timelines. However, the application indicates that year-round construction would be necessary. Yet, BLM’s timing restrictions for protecting various wildlife species, outlined in Table 3.7-10 Current BLM Seasonal Timing Restrictions Applicable to the Project Footprint, seem to preclude developing effective construction windows that would allow for year-round construction. Additionally, in Appendix L Response Comment Matrix, the response to comments by White Pine County indicates that an exception or variance from the BLM and NDOW would be requested to allow for continued construction activity in the area of the proposed upper and lower reservoirs. The response also states that if construction activities are necessary during seasonal timing restrictions you may consult with BLM and NDOW to develop additional mitigation or request that some construction activities be permitted during seasonal restrictions dates. However, the application does not specify with any certainty what seasonal timing restrictions and additional mitigation, if any, are proposed. Therefore, please consult with BLM, NDOW, and FWS now to at least define a conceptual construction schedule that addresses the agencies’ concerns and any additional proposed measures to mitigate potential adverse effects to wildlife. If you disagree with any agency recommendations explain why and provide alternative measures with an explanation as to why they would be more appropriate. Response The applicant currently par�cipates in a monthly TWG mee�ng, which was established by the BLM to allow coordina�on with par�cipa�ng agencies to guide the development of wildlife-related management and mi�ga�on plans proposed in the applicant’s PM&E measures, such as the development of wildlife seasonal restric�ons during construc�on. The ini�al TWG mee�ng was hosted on June 29, 2023, and included staff from the following agencies: BLM, NDOW, Nevada SETT, and White Pine County. The next TWG mee�ng is scheduled for July31, 2023. Both the U.S. Fish and Wildlife Service (USFWS) and the USFS were invited to the TWG but have declined to par�cipate. The applicant will con�nue to consult with the already-formed wildlife-focused TWG (e.g., BLM, NDOW, Nevada SETT, White Pine County, and other relevant agencies) to develop a conceptual construc�on schedule and/or addi�onal proposed measures to mi�gate poten�al adverse effects to wildlife. Through the consulta�on process, the applicant will define the length of �me and �me of year that impacts are expected to occur, including considera�on of any proposed unavoidable seasonal wildlife restric�ons. A dra� construc�on schedule, proposed unavoidable seasonal wildlife restric�ons, and/or other mi�ga�on measures will be provided to the TWG for review and comment. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommenda�ons before filing the proposal with FERC. If the applicant does not adopt a recommenda�on, the filing will include the applicant’s reasons, based on project-specific informa�on.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 85

FERC-A1-44(i) Exhibit E

Terrestrial Resources

Section 3.7.2 Direct and Indirect Environmental Effects – Wildlife Resources does not adequately describe the potential effects of construction and operation of the proposed project for some wildlife species because the application does not fully quantify the effects on existing wildlife habitat. To adequately prepare our NEPA analysis, staff must be able to describe potential adverse effects of the proposed project on wildlife and assess the significance of those effects. Therefore, please provide the following information on the species listed below. (i) Table 3.7-11 Big Game Habitat Within the Project Footprint estimates that amount of suitable habitat for elk, mule deer, and pronghorn antelope in the project footprint, but the quantity of habitat that may be permanently lost and temporarily impacted by the project is not estimated. Please provide a table that includes this spatial habitat information (in acres) for each ungulate species by habitat type (e.g., winter range, summer range, etc.). Response Table 3.7-11 below es�mates the quan�ty of temporary and permanent disturbance impacts to big game species’ spa�al habitat (in acres) for each ungulate species by habitat type (e.g., winter range, summer range, etc.) based on an analysis of the proposed Project Boundary GIS data proposed in the applicant’s FLA. Table 3.7-11. Acreage of Big Game Habitat Within the Project Footprint Species

Crucial Winter Range

Winter Range

Crucial Summer Range

Summer Range

YearRound

Total Acreages of Habitat

Elk Temporary

47.77

87.28

135.05

Permanent

150.22

172.86

605.7

928.78

Total:

1,063.83

Mule Deer Temporary

55.29

58.15

1.95

115.39

Permanent

394.35

40.06

4.43

226.71

665.55

Total:

780.94

Pronghorn Temporary

Permanent

243.84

Total:

243.84

Data source: NDOW Data Portal – Big Game Distribu�ons. Reference: Nevada Department of Wildlife (NDOW). 2017. Occupied Pronghorn Distribu�on. [Online] URL: htps://gis-ndow.opendata.arcgis.com/datasets/NDOW::ndow-big-game-distribu�ons/about?layer=5. Accessed July 24, 2023

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 86

Nevada Department of Wildlife (NDOW). 2017. Occupied Elk Distribu�on. [Online] URL: htps://gisndow.opendata.arcgis.com/datasets/NDOW::ndow-big-game-distribu�ons/about?layer=2. Accessed July 24, 2023 Nevada Department of Wildlife (NDOW). 2017. Occupied Elk Distribu�on. [Online] URL: htps://gisndow.opendata.arcgis.com/datasets/NDOW::ndow-big-game-distribu�ons/about?layer=4. Accessed July 24, 2023

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 87

FERC-A1-44(j) Exhibit E

Terrestrial Resources

(j) For the greater sage-grouse, please estimate the acreage of each BLM-designated Habitat Management Area and Seasonal Habitat Type (e.g., Priority Habitat Management Area, Nesting/Breeding, etc.) that would be temporarily aﬀected by or permanently lost due to construction of the proposed project and provide the basis for these acreages. Response Table 3.7-2 below es�mates the quan�ty of BLM-designated Habitat Management Area and Seasonal Habitat Type (e.g., Priority Habitat Management Area, Nes�ng/Breeding, etc.) that would be temporarily aﬀected by or permanently lost due to construc�on of the proposed project based on an analysis of the Project Boundary GIS data proposed in the applicant’s FLA. Table 3.7-2. Acreage of Greater Sage-Grouse Habitat Within the Project Footprint Impacts

PHMA OHMA GHMA (Breeding, nes�ng, (low to moderate (Seasonal or yearround habitat) wintering, and quality habitat) brood rearing habitat)

Non-Habitat

Temporary

34.37

18.63

184.83

4.09

Permanent

165.95

140.36

478.45

358.65

Total:

200.32

158.99

663.28

362.74

Data source: BLM. May 25, 2023. BLM NV CA ARMPA GRSG Habitat 2015. htps://gbp-blmegis.hub.arcgis.com/datasets/BLM-EGIS::blm-nv-ca-armpa-grsg-habitat2015/explore?ﬁlters=eyJHUlNHX0NhdGVnIjpbIk9ITUEiLCJQSE1BIiwiR0hNQSJdfQ%3D%3D&loca�on=40.0 85162%2C-116.315271%2C9.00. Accessed July 21, 2023. Greater sage-grouse habitat in Nevada was delineated by the USGS for BLM in the 2015 Nevada and Northeastern California Greater Sage-Grouse Record of Decision and Approved Resource Management Plan Amendment Greater Sage-Grouse Habitat Mapping (ARMPA Greater Sage-Grouse [GRSG] Habitat Mapping) (BLM 2015) and updated in 2019 and 2022 into habitat management categories to help apply management guidelines designed to protect and/or manage greater sage-grouse habitat. These habitat management categories are referred to as Priority Habitat Management Area (PHMA), General Habitat Management Area (GHMA), and Other Habitat Management Area (OHMA). In ARMPA GRSG Habitat Mapping, the management categories are deﬁned as follows: •

PHMA: BLM-administered lands iden�fied as having the highest value to maintaining sustainable sage-grouse popula�ons. Areas of PHMA largely coincide with areas iden�fied as priority areas for conserva�on in the USFWS’s Conserva�on Objec�ves Team report. These areas include breeding, late brood-rearing, and winter concentra�on areas and migra�on or connec�vity corridors. Seasonal habitat for greater sage-grouse is part of the development process for iden�fying Priority Habitat Management Areas (PHMAs). Therefore, acres in PHMA reflect impacts to important seasonal ranges for greater sage-grouse, including nes�ng and brood-rearing areas.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 88

• •

GHMA: BLM-administered lands where some special management will apply to sustain sagegrouse popula�ons; these are areas of occupied seasonal or year-round habitat outside of PHMA. OHMA: BLM-administered lands iden�ﬁed as having low to moderate suitability for greater sagegrouse in areas of es�mated low space use and which are less frequently used by greater sagegrouse.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 89

FERC-A1-44(k) Exhibit E

Terrestrial Resources

(k) For temporary impacts on the species’ habitat types listed in (a) and (b), describe the length of time and time of year that impacts are expected to occur, including consideration of any proposed seasonal wildlife restrictions. Response The applicant currently par�cipates in a monthly TWG mee�ng, which was established by the BLM to allow coordina�on with par�cipa�ng agencies to guide the development of wildlife-related management and mi�ga�on plans proposed in the applicant’s PM&E 17 (greater sage-grouse), PM&E 18 (general wildlife seasonal restric�ons), and PM&E 20 (big game), such as the development of wildlife seasonal restric�ons during construc�on. The ini�al TWG mee�ng was hosted on June 29, 2023, and included staff from the following agencies: BLM, NDOW, Nevada SETT, and White Pine County. Both the U.S. Fish and Wildlife Service (USFWS) and the USFS were invited to the TWG but have declined to par�cipate. As discussed in PM&E 18, based on the results of pre-construc�on surveys (PM&E 10), the applicant will con�nue to consult with the already-formed wildlife-focused TWG (e.g., BLM, NDOW, Nevada SETT, White Pine County, and other relevant agencies) to develop a conceptual construc�on schedule and/or addi�onal proposed measures to mi�gate poten�al adverse effects to wildlife that incorporate the applicant’s goal of certain construc�on ac�vi�es (tunneling, concrete batch plant opera�on, construc�on of reservoirs, etc.) being conducted on a 365/24/7 schedule that is not limited by wildlife restric�ons, to the extent possible. Through the consulta�on process, the applicant will define the length of �me and �me of year that impacts are expected to occur, including considera�on of any proposed unavoidable seasonal wildlife restric�ons. A dra� construc�on schedule, proposed unavoidable seasonal wildlife restric�ons, and/or other mi�ga�on measures will be provided to the TWG for review and comment. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommenda�ons before filing the proposal with FERC. If the applicant does not adopt a recommenda�on, the filing will include the applicant’s reasons, based on project-specific informa�on.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 90

FERC-A1-45

Exhibit E

Terrestrial Resources

Appendix L Response Comment Matrix states that on November 18, 2022, BLM indicated to White Pine that it cannot currently support a site-specific amendment to BLM’s 2015 Nevada and Northeastern California Greater Sage-Grouse Record of Decision and Approved Resource Management Plan Amendment (ARMPA) for Greater Sage-grouse and that other options should be evaluated. Therefore, WPW is coordinating with BLM and NDOW to form a technical working group to develop a path forward and potential mitigation plans, likely in the form of a Resource Management Plan (RMP) exception or variance to allow for project construction. However, Section 3.7 Wildlife Resources of the FLA does not: (1) discuss why BLM cannot support an amendment, (2) summarize ongoing consultation on the grouse with BLM, or (3) provide a schedule outlining future consultation and development of plan(s) with BLM and NDOW. Please provide this information in the revised FLA. Response On February 10, 2023, the applicant sent a leter to the BLM reques�ng the establishment of a TWG to discuss various issues related to wildlife, including: a project-specific excep�on to the Greater Sage-Grouse (GrSG) Approved Resource Management Plan Amendment (ARMPA), as parts of the proposed project are located within GrSG Priority Habitat Management Areas (PHMA), General Habitat Management Areas (GHMA), and Other Habitat Management Areas (OHMA). The project’s construc�on ac�vi�es will extend into seasonal limita�ons rela�ng to GrSG; there will also be both temporary and permanent disturbance within PHMA and GHMA habitats. In the request to create a TWG, the applicant suggested the following stakeholders: Nevada Department of Wildlife (NDOW), US Fish and Wildlife Service (USFWS), Nevada SETT, White Pine County, and other interested par�es. The applicant also requested that the group facilitate discussion and assist in defining acceptable and achievable mi�ga�on measures that will help frame a project-specific excep�on to the current GrSG ARMPA. These mi�ga�on measures will be incorporated into the environmental review process for both the BLM and the FERC. The TWG will also allow coordina�on and input rela�ng to any proposed mi�ga�on measures between the applicant, BLM, and other agencies. In response, BLM provided a leter to the applicant, NDOW, Nevada SETT, White Pine County, USFWS, and the USFS, invi�ng them to par�cipate in the TWG and reques�ng a response by May 5, 2023. The stated goal of the TWG is to review the White Pine Pumped Storage proposal, analyze its poten�al impacts to wildlife, and iden�fy opportuni�es for mi�ga�on. The ini�al TWG mee�ng was hosted on June 29, 2023, and included staff from the following agencies: BLM, NDOW, Nevada SETT, and White Pine County. Both the USFWS and USFS were invited to the TWG but declined to par�cipate. TWG discussions are intended to guide the development of wildlife-related management plans proposed in the applicant’s PM&Es and are currently scheduled to con�nue through December 2023. Following FERC’s issuance of an original license for the proposed project, TWG mee�ng summaries and associated consulta�on will be included as an appendix to each relevant final resource management plan.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 91

FERC-A1-46

Exhibit E

Terrestrial Resources

Section 2.2.4 Summary of Proposed Environmental Measures states that a Greater Sage-Grouse Mitigation Plan is still being developed in consultation with BLM and NDOW and that the plan will be completed before initiating ground-disturbance activities associated with construction of the proposed project. However, the plan does not include enough information to evaluate for the NEPA analysis. Please clarify if this plan is separate from the RMP discussed in item #46 above, as it is unclear what specific plans and measures are being developed for the greater sage-grouse and if any of them are duplicative. As discussed under item #30 above, proposed resource management plans must have sufficient detail to evaluate in our environmental analysis in order to weigh their benefits along with their costs, and to compare with any alternative measures recommended by stakeholders. Therefore, please consult with BLM and NDOW now to finish developing the plan for inclusion in the revised FLA. Response Comment BLM-3 from Appendix L (Response Comment Matrix) of Exhibit E of the Final License Applica�on states the following: “In a letter dated November 18, 2022, BLM indicated to WPW that they cannot currently support a site-specific amendment to the Approved Resource Management Plan Amendment (ARMPA) for Greater Sage-grouse and that other options should be evaluated. Therefore, WPW is coordinating with BLM and NDOW to form a technical working group to develop a path forward and potential mitigation plans, likely in the form of a Resource Management Plan (RMP) exception or variance to allow for Project construction. WPW looks forward to continued consultation with the BLM regarding Project permitting, renewable energy goals, and a potential exception or variance to the Ely District RMP.” Within that comment, the “Resource Management Plan” that is noted refers to the BLM’s Ely District Resource Management Plan, for which the applicant may poten�ally require a site-specific excep�on or waiver for the proposed project. This is an exis�ng BLM management plan and separate from the Greater Sage-Grouse Mi�ga�on Plan proposed by the applicant under PM&E 17 to minimize and mi�gate adverse impacts to Greater Sage-Grouse as a result of the proposed project.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 92

FERC-A1-47

Exhibit E

Terrestrial Resources

Project Power Lines

"To transmit electricity from the proposed project to the grid, the FLA proposes to construct an approximately 25-mile-long, 345-kV project transmission line. Additionally, to provide back up control power to the proposed switchyard and the powerhouse, the FLA proposes to construct a 24.9-kV distribution line from the switching station to the nearest acceptable existing distribution line and that upgrades to the existing distribution line may be required. However, the length and specific route of the proposed 24.9-kv distribution line are not included in the FLA as it indicates the final design is still undecided. As discussed above, more information is needed on the proposed measures (Raptor-Safe Transmission Line Structure Plan PM&E #10, Raptor and Bat Protection Plan PM&E #14, Greater SageGrouse Mitigation Plan PM&E #17). Therefore, please provide the information for the items below. (l) Describe the final plan for the proposed 24.9-kV distribution line including its length, route, phase-tophase spacing, avian-safe structures, and any necessary modifications. (m) Describe in detail the any avian-safe designs for the proposed transmission and distribution lines that the FLA proposes to construct/modify and any additional devices (e.g., markers, perch deterrents) you propose to install, including the number of devices with relevant specifications (e.g., dimensions, spacing, etc.) and their locations. (n) The use of shield wires, guy lines, and appurtenant project structures associated with the power lines that could affect wildlife and their habitat. (o) Describe and provide maps of the proposed transmission and distribution lines that display the features listed below that occur within at least a 500-foot buffer surrounding the respective rights-of-way of the two power lines: i. the location and/or spans where any avian-safe structures would be installed; ii. shield wires, guy lines, access roads, and other appurtenant project structures; iii. relevant wildlife habitat/vegetation cover types (including sage-grouse habitat types and leks) and wetlands, topography, and other landscape features that have the potential to increase the risk of bird interactions (e.g., ridgelines, water bodies, cliff faces, etc.); and iv. an analysis of potential, species- and location-specific impacts to birds and other wildlife associated with the proposed power lines should also be provided and that include justifications supporting proposed measures, construction designs, devices, and related measures that would be implemented to minimize effects. (p) Describe the routine maintenance and retrofitting you anticipate as well as any monitoring protocols to assess: the condition and effectiveness of avian-safe devices and structures and bird interactions including nests on electrical structures, bird-caused outages, and injured and dead birds found along power line corridors, which may necessitate re-evaluation and follow-up actions (e.g., repair and retrofitting equipment, consultation with resource agency, etc.), as necessary." Response The applicant is providing the following informa�on on the requested items:

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 93

24.9 kV Distribu�on Line

The final proposed route of the 24.9kV distribu�on line, including plan and profile, is shown in the Exhibit F Design Drawings (See Exhibit F, Drawing No. F-717) There are no iden�fied Greater Sage Grouse Leks within the s�pulated buffer, as such there is no need for avian safe structures, and they are not included in the drawings provided. m) Avian-safe designs and Devices. The transmission and distribu�on lines will abide by Avian Power Line Interac�on Commitee, APLIC, "Suggested Prac�ces for Avian Protec�on of Power Lines" and "Reducing Avian Collisions with Power Lines". Required horizontal (60"+) and ver�cal (40"+) spacing will be used to mi�gate for poten�al avian electrocu�ons. Distribu�on lines constructed, or a por�on of lines modified, for this project will maintain the recommended spacing per APLIC. Addi�onally, for distribu�on lines that will traverse setback buffer areas from known Greater Sage Grouse lek loca�ons, an�-perch devices will be installed on the crossbars and the top of the poles to mi�gate the use of the poles as predator perches. A new 25.9 kV distribu�on line is proposed to provide power to the hydrogenera�on facility and switchyard. This line is just under a mile in length and will require 20 distribu�on structures. An addi�onal 0.5 miles of exis�ng distribu�on lines will be required to connect to the Mt. Wheeler Power, Inc. - Gondor Substa�on. The new line and any structures which will be modified or replaced in the exis�ng lines will be constructed or modified per the APLIC requirements for distribu�on lines noted above. The applicant will construct the new 345 kV Transmission line in accordance with APLIC separa�on guidelines. Addi�onally, there are three areas where raptors may use the transmission lines as a perch to prey upon the Greater Sage Grouse: Structures 101 through 106 in the east (6 Structures), structures 115 through 147 in the center (32 Structures), and structures 169 through 196 in the west (27 Structures). For these structures the an�-perch devices shall be placed on the horizontal crossmembers and the pole caps will be conical rather than flat to discourage raptor perching. In areas where the transmission line will be outside of the setback buffers from known Greater Sage Grouse lek loca�ons, perch diverters will be installed above each phase of the transmission line to mi�gate electrocu�ons. Space at the end of the cross arms or next to the suppor�ng poles will be clear of obstruc�on to allow for bird perching in safer loca�ons. Bird diverters will also be placed on the overhead sta�c wire or op�cal ground wire in selected loca�ons to make the lines more visible to migratory birds. n) Shield wires, guy lines, access roads, and appurtenant project structures that could affect wildlife and their habitat The shield wires for the transmission line are described above. Guy lines will extend away from structures where angles are being turned or are terminal dead ends, by approximately 115 �. Cross plate, grouted, or appropriate anchors will be installed to support the guys. Bird diverters will also be placed on guy lines to make the lines more visible to ground nes�ng bird species. The distribu�on line does not have shield wires. Guy wires for the new distribu�on line will be required at both ends of the distribu�on line. Guy wires will extend away from the poles approximately 75 �. Cross

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 94

plate, grouted, or appropriate anchors will be installed to support the guys. Bird diverters will also be placed on distribu�on line guy wires to make the lines more visible to ground nes�ng bird species. Access roads will be developed using the exis�ng Nevada Energy 345 kV transmission line maintenance access routes, as much as possible. Short tap access routes between the new and exis�ng transmission lines may be required. o) Descrip�on and map of features that occur within a 500-foot buffer to the ROWs of the two power lines Mapping is provided for the features associated with the ROWs of the two power lines in Exhibit E of the FLA: Figure 3.7-1. Mapping of NDOW Habitat Designa�ons for Elk; Figure 3.7-2. Mapping of NDOW Habitat Designa�ons for Mule Deer; Figure 3.7-3. Mapping of NDOW Habitat Designa�ons for Pronghorn; and, Figure 3.9-1 Land Use within Project Vicinity. Also, atached to Exhibit E of the FLA: Appendix B: Aqua�c Resources Delinea�on Study Report; Appendix C: Special-Status Plants and Noxious Weeds Study Report; Appendix D: Greater Sage-Grouse Lek and Habitat Study Report; and, Appendix E: 2021 Rare, Threatened, and Endangered Wildlife Species Assessment Study Report. These reports describe the requested environmental features. Analysis buffers vary depending on resource. Study plans were approved by the appropriate agencies prior to conduc�ng the studies and the analyses. Design of the transmission line and structure placement will be finalized during the final design phase. Micro-si�ng and specific design considera�ons such as the placement of avian-safe structure installa�ons, shield wires, guy lines, access roads, and other appurtenant project structures will be determined during this final design process. i.

ii.

iii.

iv.

For transmission and distribu�on lines that will traverse the 3.1-mile setback buffer areas from known Greater Sage Grouse lek loca�ons, avian-safe structures will be installed. There are three areas where raptors may use the transmission lines as a perch to prey upon the Greater Sage Grouse: Structures 101 through 106 in the east (6 Structures), structures 115 through 147 in the center (32 Structures), and structures 169 through 196 in the west (27 Structures). For these structures the an�-perch devices shall be placed on the horizontal crossmembers and the pole caps will be conical rather than flat to discourage raptor perching. For transmission and distribu�on lines that will traverse the 3.1-mile setback buffer areas from known Greater Sage Grouse lek loca�ons, bird diverters will be placed on the overhead sta�c wire or op�cal ground wire to make the lines more visible to migratory birds, and bird diverters will be placed on guy wires to make them more visible to ground nes�ng bird species. Relevant wildlife habitat/vegeta�on cover types are located within the FLA as described above. The FLA also includes a discussion of poten�al impacts in Exhibit E of the FLA, Subsec�ons 3.3 through 3.13. The applicant discusses in Table 2.2.3, minimiza�on measures it will conceptually implement to ameliorate impacts on species- and loca�on-specific impacts to birds and other wildlife associated with the proposed power lines including jus�fica�ons suppor�ng proposed measures, construc�on designs, devices, and other related measures. The applicant is currently consul�ng with a Technical Working Group and through agency coordina�on specific Greater Sage Grouse mi�ga�on plans and other species mi�ga�on measures will be developed. Rou�ne maintenance, retrofi�ng and monitoring protocols

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The applicant will conduct required annual inspec�ons of the transmission and distribu�on lines. If devia�ons are noted they will be scheduled for maintenance or replacement as necessary. The applicant will conduct a visual inspec�on of avian-safe devices and structures every 5 years along with normal annual transmission line maintenance inspec�ons. Addi�onal maintenance and retroﬁ�ng, and monitoring protocols to assess the condi�on and eﬀec�veness of avian-safe devices and structures and bird interac�ons, including nests on electrical structures, bird-caused outages, and injured and dead birds found along power line corridors, which may necessitate re-evalua�on and follow-up ac�ons, will be included as inspec�on criteria during the normal annual transmission line maintenance inspec�ons and within mi�ga�on plans currently under development with appropriate agencies.

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FERC-A1-48

Exhibit E

Terrestrial Resources

To be eﬀective, avian-safe structures and devices should be maintained over the license term. For the Raptor-Safe Transmission Line Structure Plan (PME #10), in Table 4.3-1 Cost of Environmental Measures provides a capital cost of $1,750,000, but no annual maintenance cost. However, the description states that regular maintenance of the line is included as part of the measure; therefore, annual maintenance costs should also be speciﬁed here. Please provide an estimated cost for annual maintenance activities or indicate if the maintenance costs are factored elsewhere. Response The applicant will conduct a visual inspec�on of avian-safe devices and structures every 5 years along with normal annual transmission line maintenance inspec�ons. The applicant has determined that there are no addi�onal maintenance costs associated with these inspec�ons and of the avian-safe structures and devices. Any repairs or replacement costs for avian-safe devices are included in the regular and expected transmission line maintenance costs.

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FERC-A1-49

Exhibit E

Terrestrial Resources

Exhibit E - Terrestrial Resources - Both the Raptor and Bat Protection Plan (PM&E #14) and Greater SageGrouse Mitigation Plan (PM&E #17) list measures related to the design of the proposed power lines, including raptor-safe guidelines for all new electrical construction and minimizing spacing between existing and proposed transmission lines. However, it is unclear if these proposed measures are also included as part of the Raptor-Safe Transmission Line Structure Plan (PME #10), and in Table 4.3-1, under which proposed plan(s) their associated capital and annual costs are accounted. Please clarify this information in the revised FLA. Response The proposed measures related to design of the power lines, to include raptor-safe guidelines and sage grouse considera�ons, are proposed for each PM&E (#10, #14, and #17). The applicant included the capital and annual costs only under PM&E #10 as these costs are associated with the actual construc�on and maintenance of the transmission lines.

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FERC-A1-50

Exhibit E

Project Power Lines

Sections 3.9.1.2 and 3.9.2.3 state that over 100 acres of the proposed transmission line corridor are in 100year or 500-year floodplains and that it is anticipated that the location of transmission line foundations and structures would have to be adjusted during the final design to avoid or minimize temporary and permanent impacts on floodplains. The proposed environmental measure, Transmission Line Design (PME #24) states that if proposed transmission line structures and access roads could not be located outside of floodplains, BLM would be consulted to identify measures to minimize adverse impacts to water features. Because adjustments would likely be needed, it is unclear why necessary measures have not already been developed and described in the FLA. Staff cannot evaluate unknown measures that could be developed in future consultation. Therefore, please consult with BLM now to develop final contingency measures for when such adjustments are needed in to minimize potential effects on water features and vegetation resulting from construction, repairs, and maintenance of the proposed transmission and distribution lines, including the access roads/trails and the transmission line ROW (e.g., vegetation management). Response In December 2021, the applicant submited an applica�on for a ROW grant and land use permit to the BLM for placement of the majority of the project’s proposed transmission line within the exis�ng BLM Sec�on 368(a) designated energy #110-114 corridor (Sec�on 368 Energy Corridor). The proposed transmission line corridor would be primarily (70%) located within the designated Sec�on 368 Energy Corridor, with the remainder routed through private property (8%) and BLM-managed land (22%) within the Legacy Locally Designated Corridor. By placing the transmission line within the energy corridor, which already contains a separate transmission line, impacts to the surrounding environmental resources may be reduced and future management and mi�ga�on efforts consolidated with the exis�ng infrastructure. As noted above, the currently proposed transmission line and access road are posi�oned within the exis�ng BLM Sec�on 368(a) designated energy #110-114 corridor (Sec�on 368 Energy Corridor), which crosses the Steptoe Creek floodplain. The overhead transmission line would be constructed to connect the project switchyard to Nevada Energy’s Robinson Summit Substa�on located 17 miles northwest. The corridor designa�on has been iden�fied as the preferred loca�on for the development of energy transport projects to avoid significant known resource and environmental conflicts and is therefore already approved as an appropriate route for mul�ple energy genera�on sources. The ROW width will be approximately 160 feet wide, with H-frame transmission structures spaced approximately 1,000 feet apart. Based on preliminary designs, floodplain sec�ons may poten�ally accommodate 16 H-frame structures (see Exhibit G, Sheet G-5 of the FLA). The floodplain contains few delineated ephemeral features that were determined to have no downstream connec�vity to other Waters of the United States (see Appendix B: Aqua�c Resources Delinea�on Report of the FLA), making them poten�ally non-federally jurisdic�onal. The exact placement of H-frame structures has not been iden�fied yet, which allows for maximum avoidance and minimiza�on of impacts within the floodplain. Where feasible, transmission line widths will be designed to span floodplain features. Based on the 2023 Aqua�c Resources Delinea�on Report (Appendix B of the FLA), it is assumed that construc�on of the access road along the proposed transmission line will result in minimal impacts to state-regulated aqua�c resources and poten�ally regulated federal aqua�c resources. As a result, temporary work areas would be minimized to avoid addi�onal temporary impacts to regulated resources

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to the maximum extent prac�cable. Impacts to aqua�c resources and habitat may require permits and employment of avoidance and minimiza�on measures such as: • • • •

BMPs to control water and sediment during construc�on; Pre-construc�on biological resource and plant surveys; Staking and ﬂagging; and Poten�al seasonal avoidance measures. Throughout the ﬁnal design phase, BLM, USACE, and FEMA will be consulted, as appropriate, to ensure the proposed transmission H-frame structures, placement, extents, and associated access road comply with the permited corridor requirements and that all necessary USACE or FEMA permits are obtained.

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FERC-A1-51

Exhibit E

Recreation Resources

Table 3.8-1, Outdoor Recreation Facilities within Approximately 10 miles of the Proposed Project Location, lists existing, non-project recreational facilities within about 10 miles of the proposed project location and provides a brief description of the facilities, their ownership, and their estimated use. However, the estimated use provided for some of the facilities gives no quantitative data on use but states “unknown”, “light”, “medium”, and “heavy” use. So that staﬀ can properly analyze recreation use within the project area and potential project eﬀects on that use, please revise the table to provide quantitative use data for the facilities where quantitative data on use is not provided. Additionally, although the table indicates the listed facilities are within about 10 miles of the proposed project location, the table does not provide the distance of each facility to the proposed project site. Please revise the table to provide the distance from each existing, non-project recreational facility to the proposed project location. Response To support the development of the Recrea�on Resources Study Report, the applicant conducted a desktop review of publicly available recrea�on and visitor use informa�on on all referenced loca�ons in Table 3.81 of Exhibit E of the FLA. Addi�onally, in 2021, the applicant contacted the various land management agencies for each facility to inquire about addi�onal data on recrea�on usage es�mates (see Appendix A of Exhibit E of the FLA). The applicable managing agency provided the qualita�ve es�mates to the applicant that were provided in Table 3.8-1. The following exis�ng, non-project recrea�onal facili�es within about 10 miles of the proposed project loca�on did not have quan�ta�ve recrea�on data publicly available: • • • • • • • • • • •

Berry Creek Campground; Timber Creek Campground and Picnic Site; Steptoe Valley WMA; Bird Creek Campground; East Creek Campground; Ward Mountain Campground and Picnic Site (Ward Mountain South); Basset Lake; White Pine County Fairgrounds; White Pine Golf Course; Ely KOA Journey Campground; and Egan Crest Trail System.

The applicant has conducted a supplemental desktop review of publicly available recrea�on data for these sites since the ﬁling of the FLA and did not ﬁnd quan�ta�ve or qualita�ve es�mates of recrea�on usage. Subsequently, the applicant contacted each managing agency of the aforemen�oned recrea�on facili�es in June 2023. At the �me of this submital, the applicant has only heard back from the BLM who provided quan�ta�ve usage es�mates for the Egan Crest Trail System, and from the White Pine Golf Course who provided quan�ta�ve usage es�mates for the site. To assist the Commission in its review, the applicant has provided addi�onal detail about each of these recrea�on sites below. Berry Creek Campground

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Berry Creek Campground is a dispersed campground with picnic tables and campfire rings and limited ameni�es. The U.S. Forest Service (USFS) classifies usage at the site as “light” (USFS Undated(a)). There are no reserva�ons or fees associated with the Berry Creek Campground, further limi�ng the ability to monitor recrea�onal usage. The USFS was unable to provide quan�ta�ve recrea�on use levels as part of the Recrea�on Resources Study Report, DLA, FLA, or this response to this addi�onal informa�on request (AIR). Timber Creek Campground and Picnic Site Timber Creek Campground consists of 11 campsites, including five group sites and six RV sites. The USFS classifies usage at the site as “heavy” (USFS Undated(b)). While reserva�ons and fees are required, there is no publicly available data for annual or monthly visitors to the campground. The USFS was unable to provide quan�ta�ve recrea�on use levels as part of the Recrea�on Resources Study Report, DLA, FLA, or this response to this AIR. Steptoe Valley WMA The Steptoe Valley Wildlife Management Area (WMA) does not have any entry restric�ons and allows the use of vessels between 11:00 AM and sunset. Camping and campfires are not permited. Hun�ng is allowed every day for wildlife species upon which there is an established open season (NDOW 2022). A�er having conversa�ons with NDOW staff, who manage this WMA, they noted that the site has “considerable public usage”, but were unable to provide a discrete number at the �me of the FLA. The NDOW was unable to provide quan�ta�ve recrea�on use levels as part of the Recrea�on Resources Study Report, DLA, FLA, or this response to this AIR. Bird Creek Campground The Bird Creek Campground consists of nine campsites, including two double sites and one group site. The USFS classifies usage at the site as “medium” (USFS Undated(c)). While reserva�ons and fees are required, there is no publicly available data for annual or monthly visitors to the campground. The USFS was unable to provide quan�ta�ve recrea�on use levels as part of the Recrea�on Resources Study Report, DLA, FLA, or this response to this AIR. East Creek Campground The East Creek Campground consists of seven campsites, including one tent only camping site and six RV sites. The USFS classifies usage at the site as “medium” (USFS Undated(d)). While fees are required, there is no publicly available data for annual or monthly visitors to the campground. Reserva�ons are not required for East Creek Campground. The USFS was unable to provide quan�ta�ve recrea�on use levels as part of the Recrea�on Resources Study Report, DLA, FLA, or this response to this AIR. Ward Mountain Campground and Picnic Site (Ward Mountain South) The Ward Mountain Campground consists of 33 campsites, including nine back-in and three pull-thru RV sites. The USFS classifies usage at the site as “heavy” (USFS Undated(e)). While reserva�ons and fees are required, there is no publicly available data for annual or monthly visitors to the campground. The USFS was unable to provide quan�ta�ve recrea�on use levels as part of the Recrea�on Resources Study Report, DLA, FLA, or this response to this AIR.

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Basset Lake The NDOW was unable to provide quan�ta�ve recrea�on use levels as part of the Recrea�on Resources Study Report, DLA, FLA, or this response to this AIR. White Pine County Fairgrounds White Pine County was unable to provide quan�ta�ve recrea�on use levels as part of the Recrea�on Resources Study Report, DLA, FLA, or this response to this AIR. White Pine Golf Course White Pine County manages the White Pine Golf Course. On June 27, 2023, the applicant contacted Randy Long with the White Pine Golf Course to inquire again about es�mated recrea�on use levels at the site. Mr. Long reported on June 28, 2023 that the golf course is open from March to October and averages approximately 9,000 rounds per year. The applicant has updated Table 3.8-1 to include this es�mate. Ely KOA Journey Campground The Ely KOA Journey Campground was unable to provide quan�ta�ve recrea�on use levels as part of the Recrea�on Resources Study Report, DLA, FLA, or this response to this AIR. Egan Crest Trail System The BLM manages the Egan Crest Trail System. On June 27, 2023, the applicant spoke with John Miller of the BLM Bristlecone Field Oﬃce, Ely District to inquire again about es�mated recrea�on use levels at the site. Mr. Miller reported approximately 1,200 visitors annually. The applicant has updated Table 3.8-1 to include this es�mate. The applicant has revised Table 3.8-1 to include the distance from each exis�ng, non-project recrea�onal facility to the proposed project loca�on. The applicant has also updated the es�mated usage levels for the Egan Crest Trail System.

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Table 3.8-1: Outdoor Recreation Facilities within Approximately 10 miles of the Proposed Project Location

Recreation Facility

Facility Summary

Owner/Operator

Estimated Usage

Berry Creek Campground

Located on the North Fork Berry Creek in the High Schells Wilderness at approximately 8,200 feet elevation. This dispersed campground has no fee and provides minimal amenities, but provides access to opportunities for hiking, biking, horseback riding, fishing, and winter activities.

USFS (Ely District)

Ranger

Light

3.71

Timber Creek Campground and Picnic Site

Developed campground located in a forested setting of Engelmann spruce, aspen, and white fir trees providing partial shade throughout the campground and attractive fall foliage. Timber Creek, a perennial stream, flows through the facility and provides visitors with rainbow and brook trout fishing opportunities. In addition, the High Shells Wilderness, with several peaks over 11,000 feet in elevation, can be accessed approximately 0.5 mile from the campground. Access is also available to the Ranger offhighway vehicle (OHV) trail for horseback riding, OHV riding, mountain biking, hiking, and winter activities.

USFS (Ely District)

Ranger

Heavy

5.99

5.98

Steptoe Valley WMA

Numerous surface water bodies, including Steptoe Creek, several small ponds, and Comins Lake are available for fishing in the WMA. There is an abundance of habitat types in the WMA, including wet meadows, riparian corridors, sagebrush, and pinyon-juniper uplands, providing habitat for a variety of wildlife species. Common wildlife species in the WMA include mule deer, pronghorn, sage-grouse, ducks, and other non-game species. Elk tags are intensely sought after for the Steptoe Valley WMA. Visitors may hunt, boat, fish, hike, or view wildlife at this facility.

NDOW

Considerable public usage

3.82

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Distance Distance from FERC from Project Project Footprint Boundary (miles) (miles)

Recreation Facility

Facility Summary

Owner/Operator

Estimated Usage

Bird Creek Campground

Located in Duck Creek Basin, high in the Schell Creek Range at approximately 8,200 feet elevation. Bird Creek, a perennial stream, flows through the campground and the area is slightly forested with juniper, pinyon pine, and alder trees providing limited shade. Ranger Trail is accessible from the campground, providing opportunities for OHV use, mountain biking, and hiking. Visitors may also fish in Bird Creek.

USFS (Ely District)

Ranger

Medium

8.55

East Creek Campground

Dispersed campground located in the Schell Creek Range at approximately 6,750 feet elevation. The area is forested with alder, pinyon, and juniper. East Creek, a perennial stream, flows through the picnic area, providing habitat for birds during the spring and summer months. Most of the campsites are located along the creek. Available activities include mountain biking, camping, day hiking, backpacking, and OHV road/trail riding.

USFS (Ely District)

Ranger

Medium

10.54

Cave Lake State Park

There are two campgrounds located within the park: Elk Flat Campground and Lake View Campground. Each campground contains one day-use group site and one group camping site. There are also two picnic areas along the shore of Cave Lake with restrooms, tables, grills, and water. Cave Lake is popular for fishing all year round and is stocked with rainbow and brown trout. Four developed hiking trails are also located in the park. Activities available in the park include camping, hunting, hiking, wildlife viewing, mountain biking, fishing, swimming, boating, and winter activities.

NDSP

Approx. 60,000 camper nights per year; Day use max. capacity of 1,600 people exceeded on a regular basis

10.26

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Distance Distance from FERC from Project Project Footprint Boundary (miles) (miles)

Recreation Facility

Facility Summary

Owner/Operator

Estimated Usage

Ward Mountain Campground and Picnic Site (Ward Mountain South)

Located near Ward Mountain below the summit, but high above the desert floor at approximately 7,400 feet elevation. The facility has access to 10 miles of USFS trails with the main trailhead for Ward Mountain (elevation 10,800-foot summit) located at the east side of the campground. Activities available at the campground and picnic site include mountain biking, road cycling, camping, day hiking, backpacking, OHV road/trail hiking, horseback riding, and winter activities.

USFS (Ely District)

Heavy

9.84

Ward Mountain Recreation Area (Ward Mountain North)

Recreation area with BLM-administered trails including four trail loops of 10 total miles that meander through sagebrush and pinyon-juniper forests. There is also an 18-hole disc golf course located adjacent to Ward Mountain Recreation Area at 7,400 feet elevation. There are no fees to use the Ward Mountain Recreation Area and it is open year-round. Accessible pit toilet restrooms are provided, as well as picnic tables, shade structures, and trash cans at the trailhead. However, no potable water is available.

BLM

Approx. 1,500 visitors per year

9.31

Nevada Northern Railway Museum and Depot

Working historic passenger railroad that offers train rides as well as a variety of themed train rides or other events. The trains are over 110 years old and provide visitors with mountain scenery and historical narration. Regular trains rides run several times per week for 90 minutes from April through October with special trains running other times of year. The NNR is open year-round and daily except for select holidays as posted on its website. Special themed trains for 2021 include the Night Sky – Star Train, Sunset Stars and Champagne tour, the Roarin’ 20’s tour, the Geology Train, Haunted Ghost Train, and Santa’s Reindeer Flyer tour. The Night Sky – Star Train and the Sunset Stars and Champagne tours operate on the NNR HiLine, which runs in close proximity to the Project.

NNR

During 2021, the NNR was open at 50 percent capacity due to the COVID-19 pandemic; Special theme trains often sell out in advance.

4.09

4.08

Ranger

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Distance Distance from FERC from Project Project Footprint Boundary (miles) (miles)

Recreation Facility

Facility Summary

Owner/Operator

Estimated Usage

Nevada Game Management Units 111, 121, and 131

Bassett Lake

All three management units are managed for elk, mule deer, and pronghorn. Primitive camping is allowed on public lands of NDOW Game Management Units. Unit 111 is popular for hunting elk and mule deer and terrain ranges from gently to extremely difficult to traverse. Unit 121 lies on BLM land with terrain ranging from gentle hills to steep canyons. Unit 131 contains large flat valleys and steep mountains and is most popular for mule deer hunting.

NDOW

2020 season estimate: Unit 111 – 1,301 hunters; Unit 121 – 791 hunters; Unit 131 – 803 hunters

0.00

Primarily used for fishing and boating, with no developed facilities and no camping allowed. Two unimproved boat launches are located on each side of the lake. Largemouth bass are popular game fish in Bassett Lake. Fishing is typically best during early spring to early summer. During summer, biting insects and a thick algal mat may render the lake unfishable. Additionally, shoreline fishing can be difficult so fishing via boat is recommended.

NDOW

Unknown

8.34

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Distance Distance from FERC from Project Project Footprint Boundary (miles) (miles)

Recreation Facility

Facility Summary

Owner/Operator

Estimated Usage

Ely Community Parks

Community parks owned and maintained by White Pine County located in Ely include Camp Success, County Park/ Courthouse Park, Little League Field, Marich Field, and Steptoe Park. Camp Success is located in a remote setting and includes a lodge with restrooms and showers and a propane refrigerator as well as a grill, fire pit, RV parking, and tents. County Park/Courthouse Park contains a duck pond, park benches, picnic tables, shade trees, and a war memorial. The Little League Field and Marich Field each contain three baseball fields. Steptoe Park includes a walking trail, barbeque area, pavilion, picnic tables, playground, soccer field, restrooms, and shade trees.

White Pine County

Camp Success appears to have received regular usage during the 2021 season; Approx. 20 youth teams use the Little League Field; other parks unknown

4.12

McGill Community Parks

Community parks owned and maintained by White Pine County in McGill include the McGill Pool Park, McGill Baseball Field, and Avenue K Park. The pool is fed from a nearby warm spring and is surrounded by a sand beach. The park located next to the pool offers a barbeque area, picnic tables, volleyball court, concessions stand, shade trees, and restrooms. The McGill Baseball Field is an outdoor field typically used by youth leagues and is open year-round. Avenue K Park contains playground equipment, grassy fields, and walking paths and is open year-round.

White Pine County

McGill Pool Park receives approx. 90 swimmers per day; other parks unknown

3.34

3.33

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Distance Distance from FERC from Project Project Footprint Boundary (miles) (miles)

Recreation Facility

Facility Summary

Owner/Operator

Estimated Usage

Shooting Ranges

Three shooting ranges are located in White Pine County in the vicinity of the Project. The White Pine Long Distance Range is open to the public and provides a range of 100 – 1,000 yards for shooting and archery. The Steptoe Valley Trap, Skeet, and Target (SVTST) Range was opened to maintain a place to provide U.S. citizens who are legally allowed to possess a firearm with a place to learn and implement the safe and efficient use of firearms for home and personal protection, hunting, competitive shooting, and shooting recreation. The McGill Archery Barn is open to members and includes a 20-yard indoor archery range.

White Pine Long Distance Range – White Pine County; SVTST Range – SVTST Club; McGill Archery Barn – owned by White Pine County and managed by the Bristlecone Bowman Club

White Pine Steptoe Valley Steptoe Valley Long Shooting Shooting Range: Distance Range: 0.00 0.00 Range – 2530 visitors per day; White Pine White Pine other ranges Shooting Shooting Range: unknown Range: 1.69 1.67

White Pine County Fairgrounds

The White Pine County Fairgrounds offers short-term and long-term animal boarding and pen rentals as well as rental opportunities for special events. There are several arenas, concession stands, bar areas, and barbeque pits available for special events. The annual County Fair is also held here, which includes horse racing, live music, barbeque, crafts, vendors, 4-H shows and exhibits, livestock auctions, rodeo, and more.

White Pine County

Unknown

2.95

White Pine Golf Course

The White Pine Golf Course is a 6,843-yard course with a par of 72. The first nine holes of the course are along the NNR. The golf course contains restored red barns and scenic mountain views and offers a full-service pro shop, club house, and driving range. Events are also held here throughout the playing season. The golf course is open from March through November.

White Pine County

Open March – October with an estimated 9,000 rounds per year

3.24

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 109

Distance Distance from FERC from Project Project Footprint Boundary (miles) (miles)

Recreation Facility

Facility Summary

Owner/Operator

Estimated Usage

Ely KOA Journey Campground

The Ely KOA Journey Campground provides RV, tent, cabin, and teepee camping sites. Potable water, restrooms with showers, propane, trash services, and a ‘kamping kitchen’ are provided at the campground. The campground also features a basketball court, volleyball court, playground, horseshoe pits, movie cabin, two dog parks, and a horse corral. There is access to OHV trails directly from the campground.

Kampgrounds America (KOA)

Unknown

6.33

6.32

Garnet Hill Recreation Area

The top elevation of Garnet Hill is 7,300 feet and was designated a public recreation area in 1970 for public enjoyment, rock hounding, and scientific study. Garnet Hill is famous for its dark-colored garnets found in flowbanded rhyolitic volcanic rock. Visitors may find ruby red, semi-precious gems in the rocky volcanic outcrops or just by searching the ground. A hiking and OHV trail provides access to the top of Garnet Hill and there is limited camping space at the top of the hill with picnic tables, barbeque area, and restrooms.

BLM

Approx. 3,200 visitors per year

4.16

Egan Crest Trail System

The Egan Crest Trail System provides recreationists with 24 miles of trails with a variety of terrain from rolling sagebrush flats to the higher elevations in pinyon and juniper forests. The trails consist of single-track and signed two-track roads and are open to hiking, mountain biking, equestrian, motorcycles, and ATVs. The trail system includes two trail loops and two connector trails. Other amenities include picnic tables and shade structures at the trailhead.

BLM

Approx. 1,200 visitors per year

0.10

White Pine Waterpower, LLC | FERC Project No. 14851-003 | April 28, 2023 Addi�onal Informa�on Request Responses| 110

Distance Distance from FERC from Project Project Footprint Boundary (miles) (miles)

Cita�ons Nevada Department of Wildlife (NDOW). 2022. Steptoe Valley Wildlife Management Area. Online [URL]: htps://storymaps.arcgis.com/stories/9cddee91cb7f4679847ddbf6c920d3ab. Accessed: June 2023. U.S.

Forest Service. Undated(a). Berry Creek Dispersed Campground. htps://www.fs.usda.gov/recarea/htnf/recrea�on/campingcabins/recarea/?recid=83380&ac�d=34. Accessed: June 2023.

Online

[URL]:

U.S

Forest Service. Undated(b). Timber Creek Campground. Online htps://www.fs.usda.gov/recarea/htnf/recarea/?recid=65534. Accessed: June 2023.

[URL]:

U.S.

Forest Service. Undated(c). Bird Creek Campground. Online htps://www.fs.usda.gov/recarea/htnf/recarea/?recid=65184. Accessed: June 2023.

[URL]:

U.S.

Forest Service. Undated(d). East Creek Campground. htps://www.fs.usda.gov/recarea/htnf/recrea�on/campingcabins/recarea/?recid=65228&ac�d=29. Accessed: June 2023.

Online

[URL]:

U.S.

Forest Service. Undated (e). Ward Mountain Campground. htps://www.fs.usda.gov/recarea/htnf/recrea�on/campingcabins/recarea/?recid=65536&ac�d=29. Accessed: June 2023.

Online

[URL]:

FERC-A1-52

Exhibit E

Recreation Resources

Section 3.8.1.4 Specially Designated Recreation Areas, National Trails System and Wilderness Areas, states that no portion of the project boundary is located within any designated Wilderness Areas. Although this appears to be correct, as stated above the proposed project upper reservoir would be approximately 4 miles from the High Schells Wilderness and the proposed project transmission line would be approximately 1.2 miles from the Bristlecone Wilderness, at its closest point to the transmission line ROW. Please revise the FLA to indicate the proposed project's proximity to the High Schells Wilderness and Bristlecone Wilderness, and provide details about the wilderness areas, including details on recreation facilities, such as trails, that might be present within each. Response The applicant has added the following text to Exhibit E, Sec�on 3.8.1.4 Specially Designated Recrea�on Areas, Na�onal Trails System and Wilderness Areas: “The proposed project upper reservoir will be approximately 4 miles from the High Schells Wilderness and the proposed project transmission line will be approximately 1.2 miles from the Bristlecone Wilderness at its closest point to the transmission line right of way (ROW). Therefore, no portion of the project boundary is located within any designated Wilderness Areas. The High Schells Wilderness and the Bristlecone Wilderness are shown in relation to the project on Figure 52-1 (also filed with response to FERC Deficiency No. 11). The Wilderness Act in 2006 designated the High Schells Wilderness as a wilderness area consisting of 121,497 acres in White Pine County, 10 miles northeast of Ely. The eastern portion has canyons that lead down into Spring Valley, a vertical mile below. The east-side canyons are deeply incised and heavily wooded, with riparian thickets along stream banks. Wheeler Park and the South Snake Range, a mountain island surrounded by desert valleys, are to the southeast. Bristlecone Pines and equally impressive Limber Pines are present in the higher elevation forests. Popular recreation activities include hiking, horseback riding, backcountry skiing, fishing, big game and upland game bird hunting (USFS, Undated). The Wilderness Act in 2006 designated the Bristlecone Wilderness as a wilderness area consisting of 14,095 acres in White Pine County near Ely. The Bristlecone Wilderness contains diverse landforms and vegetation types, including sage, grass and juniper at lower elevations, mixed with aspen stands in the middle elevations, and bristlecone pine and fir stands mixed with grasses and forbs at the upper elevations. It ranges in elevation from 7,400 feet to 9,800 feet in the central Egan Range. Hiking to the summit of Heusser Mountain, the prominent landmark of the Bristlecone Wilderness, is a current recreational activity in the Bristlecone Wilderness. Visitors may also enjoy several primitive recreational opportunities, such as hunting, camping, scenic viewing and photography (BLM, 2014). Two cherry-stem routes provide public access to Bristlecone Wilderness. Cherry-stem routes are dead-end routes where the boundary of the wilderness extends up one side of the route, around its terminus, and down the other site. Dispersed camping is permitted in the Bristlecone Wilderness but is not heavily used and visitation is not monitored. Hunting and trapping are allowed, but they are not a common activity. In the 2014 Bristlecone and Goshute Canyon Wilderness Preliminary

Wilderness Management Plan, BLM describes that annual visitation is diﬃcult to quantify, but visitor encounters are infrequent (BLM, 2014).”

Figure 52-1: High Schells Wilderness and the Bristlecone Wilderness Proximity to the Project

Cita�ons Bureau of Land Management (BLM). 2014. Bristlecone and Goshute Canyon Wilderness Preliminary Wilderness Management Plan. BLM Ely District Oﬃce. DOI-BLM-NV-L000-2014-0001-EA. U.S.

Forest Service (USFS). Undated. High Schells Wilderness. Online [URL]: htps://www.fs.usda.gov/detailfull/htnf/home/?cid=stelprdb5238646. Accessed: June 2023.

FERC-A1-53

Exhibit E

Recreation Resources

Section 3.8.4.2 Applicant Recommendations, states that White Pine proposes to manage lands over which it has control in the project boundary for appropriate public access. However, the FLA does not explain how this would occur or for what purpose public access would occur within the project boundary. Please revise the FLA to provide details about how White Pine would manage lands within the project boundary for public access and what types of public access are anticipated. Response Exhibit E, Sec�on 3.8.1.2 of the FLA indicates that “It is the policy of White Pine County to provide ci�zens of the county access to public lands for recrea�onal use and economic ac�vity, as well as protect the environment and natural resources within the county for future genera�ons (White Pine County 2018). White Pine County supports the concept of “Mul�ple Use Management”, which includes recrea�on along with a balanced and diverse use of natural resources for other purposes. White Pine County recrea�onal policies include conserva�on and protec�on of recrea�onal and open space resources, and the promo�on of sustainable recrea�on use. The County also encourages the use of dispersed recrea�on and the addi�onal development of recrea�on facili�es on appropriate public lands.” Nonetheless, NDOW has expressed concerns that wildlife could be impacted given that project access roads can provide new and addi�onal public access to public lands in the general project area. Currently the public has recrea�onal access to exis�ng roads on public lands administered by the BLM. Further, the applicant will construct and maintain the upper reservoir access road during construc�on and opera�on. At least 90 days prior to the start of any ground-disturbing ac�vity the applicant will coordinate access and security plans with the BLM, NDOW, and White Pine County. The applicant will also ﬁle a Public Safety Plan with FERC’s Division of Dam Safety and Inspec�ons (D2SI). The plan will include a descrip�on of all safety devices and signage needed to warn the public of project-related hazards or to otherwise protect the public in the use of project lands based on FERC’s Guidelines for Public Safety at Hydropower Projects. The applicant an�cipates that recrea�onal public access could include a) oﬀ-road vehicle use, b) access to hun�ng areas, c) wildlife viewing, d) hiking, e) trail running, f) mountain-bike` use, g) horseback riding, and h) camping. The applicant has revised Sec�on 3.8.4.2 Applicant Recommenda�ons, as follows: “Public Access: WPW proposes to manage lands over which it has control in the Project Boundary for appropriate public access due to potential security and safety concerns, as follows: •

•

During construction and operation, install barriers, signage, and gates at each end of the upper reservoir access road to limit public access during wildlife seasonal habitat restrictions, as determined by the BLM, NDOW, and White Pine County (removal to be determined by BLM/NDOW/White Pine County). During construction, install a display map near the boom gate across the Western Access Road just oﬀ SR-93 that shows the location of all public safety measures implemented at the project (to be removed after construction is complete).”

FERC-A1-54

Exhibit E

Recreation Resources

Section 3.8.4.2 Applicant Recommendations, states that White Pine proposes to coordinate with NNR throughout the project construction to minimize potential effects to NNR operations. However, the FLA does not explain how this coordination would occur. For staff to analyze potential project effects in our NEPA analysis and evaluate the proposal to coordinate with NNR, along with any recommended measures, this information is needed. Therefore, please provide details about how coordination with NNR would occur. Response The applicant has consulted and con�nues to consult with the NNR on issues rela�ng to the project. These consulta�ons have occurred in-person, via video conference, telephonic, and through party representa�ves. Most recently, the applicant has successfully worked with the NNR on implemen�ng a visitor use and experience survey at the NNR Depot in Ely, NV. The applicant has requested regular and periodic mee�ngs with NNR to discuss and resolve concerns and provide project updates. The applicant will con�nue consul�ng regularly with the NNR through the FERC licensing process and during construc�on and opera�on of the project. The applicant will consult and coordinate with the NNR on the following areas before and during construc�on and opera�on: •

•

• • •

Easement and/or right-of-way agreements for crossing NNR deeded property along the Mainline corridor. These agreements will include terms for a) construc�ng the Western Access Road improvements and the proposed railroad crossing, b) right-of-way (ROW) and crossing condi�ons for the buried well-ﬁeld supply line, and c) transmission line easement and ROW crossings for both the project transmission line and the distribu�on line for sta�on service electrical supply. The placement and �ming of construc�on of the proposed two rail crossings on the NNR HiLine rail line. The HiLine route occupies a non-exclusive ROW on public lands that has been granted by the BLM. Sec�on 106 consulta�on for the segments of the NNR Mainline and HiLine that are eligible for na�onal historic lis�ng – ini�ated and on-going. Finalizing the Supplemental Recrea�onal Survey and Supplemental NNR Socioeconomic Impact Study – to be completed by November 2023. Consult with the NNR on poten�al mi�ga�on measures that the applicant may implement during project construc�on and opera�on to mi�gate or minimize/alleviate poten�al safety or recrea�on/visual concerns.

FERC-A1-55

Exhibit E

Recreation Resources

Section 3.8.4.2 Applicant Recommendations, states that the Recreation Resources Study was adequate for the Commission to conduct its NEPA review. However, this statement is inaccurate. The Commission has not determined that the proposed Recreation Resources Study is adequate, and it has not yet begun its NEPA review (which begins once the Commission issues a Notice of Ready for Environmental Analysis). Please remove this statement from the FLA. Response The applicant has removed this statement from the FLA, as seen below in revised Sec�on 3.8.4.2, paragraph 1: “Although the Recreation Resources Study was adequate for FERC to conduct its NEPA review, WPW has agreed to conduct supplemental eﬀorts related to recreation resources based on NPS comments on the DLA. Section 1.3 describes WPW’s consultation with NPS and NNR regarding proposed supplemental recreation resource study steps and remaining areas of disagreement with NPS.”

FERC-A1-56

Exhibit E

Recreation Resources

Section 3.8.4.2 Applicant Recommendations, states that the supplemental Recreation Resources Study would include a survey period of sixteen survey days to be accomplished over an eighteen-week timeframe, and that four survey events are planned during this period. However, no explanation is provided regarding the methodology that would be used to choose the sixteen survey days or the four survey events. Please revise the FLA to explain the methodology that would be used to choose the sixteen survey days and four survey events. Response The applicant, the Na�onal Park Service, and the NNR agreed to the survey methodology and the fielding events for the visitor use and experience survey. The par�es agreed to four survey fielding events between June and September 2023 during which the majority of all NNR excursions are scheduled. The dates of these fielding events target a variety of NNR excursions and riders, including mul�ple rides on the HiLine, across mul�ple months. The survey days are scheduled for Wednesday to Saturday, to capture HiLine train rides as HiLine train rides are most frequent on those days. The Na�onal Park Service has requested addi�onal survey dates which the applicant has not adopted. Please see the applicant’s leter to FERC dated July 19, 2023 for a more detailed descrip�on of the visitor use and experience survey and its methodology.

FERC-A1-57

Exhibit E

Land Use Resources

Section 3.9.1 Affected Land Use Environment, states that the upper and lower reservoirs would be located mostly within an industrial area. Although the general area in the Steptoe Valley, where the Town of McGill and City of Ely are located and in which the lower reservoir would be located, currently has industrial uses, the area in which the upper reservoir would be located (identified as “37 – Duck Creek Bench”, in Appendix H, Visual and Aesthetics Report, Appendix B. BLM Maps, Map 2-10a), is public land administered by the BLM and BLM classified this area as Scenic Quality B and Sensitivity Level – High. As such, there appears to be a discrepancy and incompatibility between the prescriptions of county land use management and BLM visual resource management for this land. Please revise the FLA to clarify this discrepancy, if possible, and describe what actions would be necessary to correct this incompatibility in order for the proposed upper reservoir and other related project facilities to be constructed on this land. Response The loca�on of the proposed upper reservoir is located on BLM owned and managed lands, as shown in Figure 3.1-4 of Exhibit E of the FLA. To determine land use classifica�ons within the project vicinity, the applicant used data acquired from the White Pine County Accessor Office as shown in Table 3.9-1 and Figure 3.9-1 of Exhibit E of the FLA. The White Pine County Accessor Office classifies land owned by the BLM, USFS, and private landowners. White Pine County has classified the land where the upper reservoir would be located as industrial. The land is managed by the BLM. The upper reservoir area is within a VRM Class II area with a BLM management goal to retain the exis�ng character of the landscape and to allow a low level of change that should not atract the aten�on of a casual observer. The applicant has designed the upper reservoir such that materials will blend in with the exis�ng form, line, color, and texture of the exis�ng landscape to the extent feasible. The ridgeline of the upper reservoir would be visible from four KOPs as documented in Exhibit E, Appendix H Visual and Aesthe�c Resources Study Report. KOP 10 on Highway 486, at 2.5 miles east of the project, is the closest to the upper reservoir loca�on. From KOP 10, the ridgeline of the upper reservoir would be visible as a straight line when compared with the rolling hills of the surrounding terrain. However, the tan color and smooth texture of the reservoir will blend in with the surrounding unvegetated ridgeline. Sec�on 3.9.2.1 of Exhibit E of the FLA includes text describing the industrial uses on BLM lands. To clarify, the applicant has added the following text in Sec�on 3.9.2.1 of the FLA referencing industry use on BLM land to read: “White Pine County Assessor Office has the responsibility and authority to revise land use classifications. The applicant will communicate with White Pine County Assessor to provide information to assist the Assessor Office with any classification conversions related to the project.” Cita�ons Bureau of Land Management (BLM). 2008. Ely District Record of Decision and Approved Resource Management Plan.

FERC-A1-58

Exhibit E

Land Use Resources

Section 3.9.1 Aﬀected Land Use Environment, states that 1,281 acres of land, administered by the BLM, and 57 acres of private land are located within the “project footprint”. However, the FLA does not specify the amount of BLM administered land or private land that would be encompassed within the proposed project boundary. Please revise the FLA to clarify the acreage of BLM and private land that would be encompassed by the project boundary. Additionally, because the project boundary does not appear to encompass subsurface project facilities, (i.e., powerhouse, tunnels, and related subsurface features) the acreage and the landownership of that subsurface land is unknown. Please revise the FLA to specify who or what entity is the landowner of the subsurface lands in which the underground facilities would be located and how many acres of subsurface lands would be occupied by the project. Response The amount of BLM administered land encompassed by the project boundary is 1,095.76 acres. The amount of private land is 47.45 acres within the project boundary. (See Exhibit A, Table 1.4.5). The project boundary encompasses both surface and subsurface project facili�es including the powerhouse, tunnels and related features. The acreage of the subsurface land occupied by these subsurface facili�es is approximately 21 acres as shown in Figure 58-1. All subsurface lands are located on public lands administered by the BLM. Figure 58-1: Area occupied by subsurface lands shaded in blue.

FERC-A1-59

Exhibit E

Land Use Resources

Section 3.9.1.1 Section 368-Designated Transmission Corridor, and 3.9.1.2 Floodplains and Wetlands state that the proposed transmission line would be completely within the Section 368-designated transmission corridor, but Section 3.9.2.2 Transmission Line Corridor states that it would be primarily within the Section 368-designated transmission corridor. Please revise the FLA to clarify this discrepancy and revise the FLA where necessary to appropriately indicate the location of the proposed transmission line within the Section 368-designated transmission corridor. Additionally, please ﬁle a map the clearly shows the Section 368designated transmission corridor and the proposed ROW of the project transmission line. Response The proposed project transmission right-of-way (ROW) corridor is located primarily within the Sec�on 368designated transmission corridor as stated in Sec�on 3.9.2.2 and as can be seen in Exhibit E, Figure 3.2-2, reproduced as Figure 59-1 below. The applicant has revised Exhibit E, Sec�on 3.9.1.1 as follows: “The proposed transmission corridor is primarily (70%) located within the designated Section 368 Energy Corridor. The remaining transmission corridor is routed through private property (8%) and BLM managed land (22%) within the Legacy Locally Designated corridor. The proposed transmission corridor is located entirely within the BLM’s Legacy Locally Designated Corridor.”

Figure 59-1: Energy Corridor Maps

FERC-A1-60

Exhibit E

Land Use Resources

Section 3.9.1.1 Section 368-Designated Transmission Corridor, states that the proposed project transmission line would be completely within the existing transmission ROW from the proposed project switchyard approximately 25 miles to the interconnection location. This statement is confusing because it appears to indicate that a ROW currently exists, running from the location of the proposed, non-existing project switchyard to the interconnection point. Please revise the FLA to clarify if there is an existing ROW in which the proposed transmission line would be located or if the ROW does not currently exist and is also proposed. Response The applicant will construct the transmission line en�rely within a newly designated ROW proposed as part of the project. This transmission line ROW (“transmission corridor”) would parallel exis�ng transmission corridors as outlined in Sec�on 3.9.2.2. The applicant has removed reference to the transmission corridor being located en�rely within an exis�ng ROW from the revised sec�on 3.9.1.1 as presented in the response to FERC-A1-59. This revised Sec�on 3.9.1.1 will read: “The proposed transmission corridor is primarily (70%) located within the designated Section 368 Energy Corridor. The remaining transmission corridor is routed through private property (8%) and BLM managed land (22%) within the Legacy Locally Designated corridor. The proposed transmission corridor is located entirely within the BLM’s Legacy Locally Designated Corridor.” Exhibit E, Sec�on 3.9.2.2 of the FLA characterizes the transmission corridor.

FERC-A1-61

Exhibit E

Land Use Resources

Section 3.9.1.3 Grazing, states that all BLM land within the project boundary is managed as grazing allotments and Table 3.9-2 Grazing Allotments in the Project Footprint provides the percentage of land area in each affected grazing allotment that would be encompassed by the “project footprint”. However, the table does not provide the percentage of land area in each affected grazing allotment that would be encompassed by the project boundary. Please revise Table 3.9-2 to show the percentage of land area in each affected grazing allotment encompassed by the project boundary and the number of acres the project boundary would encompass in each affected grazing allotment. Additionally, please file a map that shows the entire project boundary and each grazing allotment that would be affected by the project. Response Table 61-1 shows the percentage of land area in each affected grazing allotment encompassed by the project boundary and the number of acres the project boundary will encompass in each affected grazing allotment. The applicant has also included the percentage and acreage of each allotment occupied by the project footprint. The applicant has prepared Figure 61-11 showing the en�re project boundary, footprint, and each grazing allotment that the project will affect. Table 61-1. Grazing Allotments in the Project Footprint and Project Boundary

Grazing Allotment Name

Total Allotment Acreage

Percent of Allotment Occupied by Project Boundary

Acreage of Allotment within the Project Boundary

Percent of Allotment Occupied by Project Footprint

Acreage of Allotment within the Project Footprint

35.2

0.1 %

53.2

127.2

0.4 %

210.3

Wellfield West Schell Bench

50,601

<0.1 % Lower Reservoir

West Schell Bench

50,601

0.3 %

Underground Works* West Schell Bench

50,601

<0.1 %

42.8

0.0 %

0.0

Gilford Meadows

5,236

0.1 %

5.9

0.0 %

0.0

Upper Reservoir Access West Schell Bench

50,601

0.2 %

84.1

0.4 %

176.1

Gilford Meadows

5,236

<0.1 %

0.6

<0.1 %

0.6

Upper Reservoir

West Schell Bench

50,601

N/A

<0.1 %

4.4

Gilford Meadows

5,236

1.4 %

73.0

1.6 %

86.1

The applicant created this figure in response to FERC AIR No. 61. It has not been included in previous FERC filings.

Duck Creek

12,672

N/A

<0.1 %

0.4

Upper Reservoir Optional Access Gilford Meadows

5,236

<0.1 %

2.0

<0.1 %

2.8

Duck Creek

12,672

0.3 %

37.6

0.5 %

58.0

Transmission Line Badger Spring

33,765

0.2 %

54.6

0.2 %

54.6

Jakes Unit Trail

32,735

0.4 %

144.8

0.4 %

144.8

Thirty Mile Spring

188,866

0.2 %

323.7

0.2 %

323.7

Georgetown Ranch

29,455

0.7 %

191.5

0.7 %

191.5

Heusser Mountain

41,715

0.2 %

77.1

0.2 %

77.1

West Schell Bench

50,601

0.2 %

88.7

0.2 %

99.9

* Underground works are subsurface features that are included within the project boundary. Grazing allotments above these features would not be disturbed.

Figure 61-1. Grazing Allotments within the Project Boundary

FERC-A1-62

Exhibit E

Land Use Resources

Section 3.9.1.2 Agricultural Lands, states that approximately 66.8 acres of land within the proposed project boundary is classified by the County Assessor as farm or agricultural lands. Please file a map that shows the entire project boundary and the farms/agricultural lands that would be encompassed by the project boundary. Response Agricultural Lands, Exhibit E Sec�on 3.9.1.4 states that approximately 66.8 acres of land within the proposed boundary is classified as farm or agriculture lands. Upon further review, the acreage of farmland within the project boundary is corrected to 31.1 acres and is presented in the revised land use Table 3.9.1 provided in the response to FERC-A1-64, Table 64-1: Revised Table 3.9.1. The Figure 3.9-1 Land Use in the Project Vicinity within Exhibit E shows the en�re project boundary and the farm lands encompassed by the project boundary. Please see Atachment 4-1; the applicant updated Figure 3.9-1 as part of the response to FERC-A1-4.

FERC-A1-63

Exhibit E

Land Use Resources

Section 3.9.2 Direct and Indirect Environmental Effects – Land Use, describes permanent land use impacts associated with the proposed project boundary and project facilities including the proposed reservoirs, transmission line and substation, wellfield, access roads, and water conveyance for make-up water. However, the section does not describe permanent land use impacts to subsurface lands associated with the proposed tunnels and the proposed powerhouse and transformer caverns. Please revise Section 3.9.2 to describe and quantify permanent land use impacts to subsurface lands that would occur because of construction of the proposed tunnels and the proposed powerhouse and transformer caverns. Response No effect on surface land use is an�cipated during construc�on or long term due to the subsurface construc�on or opera�on of the proposed tunnels and the proposed powerhouse and transformer caverns outside of the areas iden�fied for the access and cable tunnel portals. The project boundary encompasses both surface and subsurface project facili�es. The acreage of the subsurface land occupied by these subsurface facili�es is approximately 21 acres as shown in Figure 58-1. The subsurface land occupied by the subsurface facili�es will have limited impact to future mineral extrac�on in the immediate vicinity.

FERC-A1-64

Exhibit E

Land Use Resources

Section 3.9.2 Direct and Indirect Environmental Effects – Land Use, states that land will be temporarily removed from its current use and converted to construction workspaces while project construction occurs. However, FLA does not specify the acreage of, and the current uses for, the amount of land to be temporarily impacted by this proposal. Additionally, Table 3.9-3 Permanent Land Use Impacts Associated with Project Boundary, indicates acreages of permanent impacts to land would result from siting the proposed upper and lower reservoirs, access roads, wellfield, water conveyance facilities for makeup water, substation, and transmission line. However, the table does not indicate the acreage of permanent impacts that would result from siting the proposed spoil disposal site and subsurface project facilities. Please revise the FLA to (a) specify the acreage of, and the current uses for, the amount of land to be temporarily impacted and (b) provide the acreage of permanent impacts that would result from siting the proposed spoil disposal site and subsurface project facilities. Response Table 64-1: Revised Table 3.9-3 below provides the acreages of land that will be temporarily impacted (in the project footprint) and permanently impacted (in the project boundary) along with the current land uses provided by the White Pine County Assessor Office2. Table 64-1: Revised Table 3.9-3 Land Use Impacts

White Pine County Assessor Land Use Category

Permanent Impact Acres

Temporary Impact Acres

(Project Boundary)

(Project Footprint )

Temporary Only Impact Acres (Footprint – Boundary)

Transmission Line Corridor and Substation Farm

19.4

Industrial

85.8

97.0

11.2

Residential

53.5

Special

20.5

Utility

46.3

Vacant

510.1

22.3

33.9

11.6

Wellfield Vacant

Although the White Pine County Accessor Office classifies land owned by the BLM, USFS, and private landowners, Section 102 of the Federal Land Policy and Management Act directs BLM to prepare land use plans that serve as the basis for all activities that occur on BLM-administered lands. The applicable land use plan in the vicinity of the project is the Ely District Record of Decision and Approved Resource Management Plan (BLM 2008), as amended.

Temporary Only Impact Acres

Permanent Impact Acres

Temporary Impact Acres

(Project Boundary)

(Project Footprint )

Industrial

11.4

17.1

5.7

Special

1.5

2.1

0.6

38.4

Industrial

127.2

168.8

41.6

Special Use

0.0

2.9

Vacant

0.0

0.2

48.7

0**

84.7

176.1

91.4

73.0

90.9

17.9

Farm

11.7

18.5

6.8

Industrial

27.9

42.3

14.4

1,144

1,338

242.7

White Pine County Assessor Land Use Category

(Footprint – Boundary)

Spoil Disposal Sites Industrial Lower Reservoir

Subsurface Project Facilities* Industrial Upper Reservoir Access

Industrial Upper Reservoir Industrial Upper Reservoir Optional Access

Total

* Subsurface project facilities are included within the project boundary. Land above these features would not be disturbed or temporarily impacted. ** Footprint is not subtracted from the boundary in this instance.

FERC-A1-65

Exhibit E

Land Use Resources

Section 3.9.2.1 Reservoir and Conveyance Areas, Table 3.9-1 Land Use in the Project Footprint, and Figure 3.9-1 Land Use in the Project Vicinity, indicate that most of the land where the upper reservoir would be located is classified by the White Pine County Assessor’s Office as industrial. However, this appears contradictory because the upper reservoir would be located within public land administered by the BLM and in an area classified by BLM as a Class II Visual Resource Management (VRM) Area (identified as “37 – Duck Creek Bench”, in Appendix H, Visual and Aesthetics Report, Appendix B. BLM Maps, Map 2-10a), described in Table 3.11-1 BLM VRM Classes, which is managed to “retain the existing character of the landscape” and that “the level of change to the characteristic landscape should be low, that management activities can be seen but not immediately noticeable by casual observation, and that any changes must repeat (i.e., imitate) the basic forms, lines, colors and textures found in the predominant natural features of the characteristic landscape”. Additionally, the FLA states in Section 3.9.2.1 that remaining lands will be converted to industrial land, but it does not specify which remaining lands would be converted and why they would be converted. Please revise the FLA to address this apparent land management discrepancy and clarify what remaining lands would be converted to industrial land and why, and if the project boundary would encompass any of these lands. Response The loca�on of the proposed upper reservoir is located on BLM owned and managed lands, as shown in Figure 3.1-4 of Exhibit E of the FLA. To determine land use within the project vicinity, the applicant used data acquired from the White Pine County Accessor Office as shown in Table 3.9-1 and Figure 3.9-1 of Exhibit E of the FLA. The White Pine County Accessor Office classifies land owned by the BLM, USFS, and private landowners. White Pine County has classified the land where the upper reservoir will be located as industrial. The land is managed by the BLM. will The upper reservoir area is within a VRM Class II area with a BLM management goal to retain the exis�ng character of the landscape and to allow a low level of change that should not atract the aten�on of a casual observer. The upper reservoir will be designed such that materials will blend in with the exis�ng form, line, color, and texture of the exis�ng landscape to the extent feasible. The ridgeline of the upper reservoir would be visible from four KOPs as documented in Exhibit E, Appendix H Visual and Aesthe�c Resources Study Report. KOP 10 on Highway 486, 2.5 miles east of the project, is the closest to the upper reservoir loca�on. From KOP 10, the ridgeline of the upper reservoir would be visible as a straight line when compared with the rolling hills of the surrounding terrain. However, the tan color and smooth texture of the reservoir will blend in with the surrounding unvegetated ridgeline. Sec�on 3.9.2.1 of Exhibit E of the FLA includes text describing the industrial uses on BLM lands. To clarify, the applicant has revised the text referenced in Sec�on 3.9.2.1 of the FLA referencing industry use on BLM land to read: “White Pine County Assessor Office has the responsibility and authority to revise land use classifications. The applicant will communicate with White Pine County Assessor to provide information to assist the Assessor Office with any classification conversions related to the project.” Cita�ons Bureau of Land Management (BLM). 2008. Ely District Record of Decision and Approved Resource Management Plan.

FERC-A1-66

Exhibit E

Land Use Resources

Although maps in Appendix B, BLM Maps of Appendix H, Visual and Aesthetics Report are good to show the full extent of BLM visual resource assessments within the broad area of Nevada in which the project would be located, they do not very clearly show the BLM visual resource assessments within the immediate area of the proposed project. Please file four new maps, one each to show the BLM visual resource assessments as indicated in Map 2-10a, Map 3-2a, Map 4-1, and Map 5-1a, within a 1, 5, 10, and 15-mile buffer (i.e., like what is shown in Attachment 1, Map of Study Area) of the project boundary. Please include the full extent of the project boundary in each map. Response The applicant prepared four new figures (Figures 66-1 to 66-4) showing the BLM visual resource assessments as indicated in Map 2-10a, Map 3-2a, Map 4-1, and Map 5-1a (of Appendix B of Appendix H of Exhibit E of the FLA) within a 1, 5, 10, and 15-mile buffer. The full extent of the project boundary is shown on each figure.

Figure 66-1: BLM Scenic Quality Classifications

Figure 66-2: BLM Sensitivity Levels

Figure 66-3: BLM Visual Resource Inventory Classes

Figure 66-4: BLM Distance Zones

FERC-A1-67.1

Exhibit E

Land Use Resources

Appendix L, Responses to DLA Comments, includes a response to BLM’s comment (BLM-3) that indicates White Pine is continuing to coordinate with BLM and NDOW to form a technical working group with the goal of reaching consensus on potential mitigation plans, specifically in the form of a resource management plan exception or variance that would allow construction of the project on BLM lands. Because the mitigation plan or measures for this have not been filed, staff cannot properly analyze the effects of the measure or plan on resources for the purpose of NEPA analysis. Please file measures and/or plans in accordance with the instructions provided above under Proposed Environmental Measures. Response On February 10, 2023, the applicant submited a request to BLM – Bristlecone Field Office, Ely District for BLM to convene a GrSG technical working group (TWG) to facilitate discussion and assist in defining acceptable and achievable mi�ga�on measures. The purpose of these mi�ga�on measures is to help frame a project-specific excep�on or waiver to the current 2015 GrSG ARMPA that will result in a net conserva�on gain for GrSG popula�on and habitat; as certain areas of the project are located within GrSG Priority Habitat Management Areas (PHMA), General Habitat Management Areas (GHMA), and Other Habitat management Areas (OHMA). Further discussions with BLM have resulted in broadening the scope of the TWG to discuss and consider mi�ga�on measures for both GrSG, ungulates, and other wildlife. The BLM invited via leter several federal, state, and local agencies to par�cipate in the TWG. Seven individuals from four organiza�ons (NDOW, BLM, WPC, and NV-SETT) have formed the TWG along with the applicant. The first mee�ng of the TWG was held on June 27, 2023; the next mee�ng is scheduled for July 31, 2023. Goals established include defining a boundary for wildlife impacts (both direct and indirect) and developing a comprehensive mi�ga�on plan that includes Nevada’s Conserva�on Credit system. Mee�ngs are set to occur monthly, with a target end date of December 2023. The applicant an�cipates that the TWG will have a NEPA-ready Greater Sage Grouse Mi�ga�on Plan (GSGMP) dra�ed prior to commencement of the NEPA process, such that the expected outcomes of mi�ga�on measures could be integrated into the impacts analysis. The GSGMP would primarily be focused on impacts from construc�on and ongoing post-construc�on opera�ons and maintenance ac�vi�es. Upon consensus by the TWG, the applicant will file the GSGMP with FERC prior to the commencement of the NEPA process.

FERC-A1-67.2

Exhibit E

Land Use Resources

Appendix L, Responses to DLA Comments, in response to White Pine County’s comment (WPC-56) that it understands potential limitations to public access to the immediate project area but that it does not support restrictions (even temporary in nature to recreation access to surrounding public lands, states that White Pine will restrict areas only as required for health and safety and that: (a) permanent fencing would be used only to restrict access to the reservoirs and switchyard; (b) additional access restrictions required during construction would be removed when no longer needed for safety reasons; and (c) permanent fencing would not restrict access to surrounding public lands. This appears to indicate that because of the project, certain public lands administered by the BLM would become off limits to the public (i.e., public access to the lands on which the reservoirs and switchyard would be located would be permanently prohibited). Please revise the FLA to explain how existing public access to those lands would be permanently prohibited, taking into consideration that a ROW does not cede ownership of real property from the current landowner (BLM) to the recipient of the ROW (White Pine), rather a ROW allows access to the land for an approved use. Also, please clarify if any other BLM lands, aside from those previously indicated for use for the project reservoirs and switchyard, would be used for project purposes and would be permanently off limits to public access. Response Exhibit E, Sec�on 3.8.1.2 of the FLA indicates that “It is the policy of White Pine County to provide ci�zens of the county access to public lands for recrea�onal use and economic ac�vity, as well as protect the environment and natural resources within the county for future genera�ons (White Pine County 2018). White Pine County supports the concept of “Mul�ple Use Management”, which includes recrea�on along with a balanced and diverse use of natural resources for other purposes. White Pine County recrea�onal policies include conserva�on and protec�on of recrea�onal and open space resources, and the promo�on of sustainable recrea�on use. The County also encourages the use of dispersed recrea�on and the addi�onal development of recrea�on facili�es on appropriate public lands.” Nonetheless, wildlife could be impacted given that project access roads will provide new and addi�onal public access to public lands in the general project area. Currently the public has recrea�onal access to exis�ng roads on public lands administered by the BLM. The applicant will construct and maintain the upper reservoir access road during construc�on and opera�on. At least 90 days prior to the start of any ground-disturbing ac�vity the applicant will coordinate access and security plans with the BLM, NDOW, and White Pine County. The applicant will also file a Public Safety Plan with FERC’s Division of Dam Safety and Inspec�ons (D2SI). The plan will include a descrip�on of all safety devices and signage needed to warn the public of project-related hazards or to otherwise protect the public in the use of project lands based on FERC’s Guidelines for Public Safety at Hydropower Projects. The applicant an�cipates that recrea�onal public access could include a) off-road vehicle use, b) access to hun�ng areas, c) wildlife viewing, d) hiking, e) trail running, f) mountain-bike use, g) horseback riding, and h) camping. The applicant will install 10-foot-tall game fencing, signage, and other safety and security design features around the outside edge of the upper and lower reservoir perimeter roads, switchyard, and main access portal for site security, public safety, and wildlife protec�on. The applicant will install barriers, signage, and gates at each end of the upper reservoir access road to limit public access during wildlife seasonal habitat

restric�ons, as determined by the BLM, NDOW, and White Pine County. No other BLM lands will be used for project purposes that would then be permanently oﬀ limits to public access. The applicant has revised Sec�on 3.8.4.2 Applicant Recommenda�ons, as follows: “Public Access: WPW proposes to manage lands over which it has control in the Project Boundary for appropriate public access due to potential security and safety concerns, as follows: •

•

During construction, install signage and barriers along existing, unpaved access routes to prevent unauthorized access into the construction work zones as shown on drawings in Exhibit F (to be removed after construction is complete). During construction, install fencing around all laydown sites for security. A boom gate will be provided across the new Western Access Road just oﬀ the intersection of SR-93 to control access into the project construction area (to be removed after construction is complete). During construction and operation, install 10-foot-tall game fencing, signage, and other safety and security design features around the outside edge of the upper and lower reservoir perimeter roads, switchyard, and main access portal for site security, public safety, and wildlife protection (permanent installation). During construction and operation, install barriers, signage, and gates at each end of the upper reservoir access road to limit public access during wildlife seasonal habitat restrictions, as determined by the BLM, NDOW, and White Pine County (removal to be determined by BLM/NDOW/White Pine County). During construction, install a display map near the boom gate across the Western Access Road just oﬀ SR-93 that shows the location of all public safety measures implemented at the project (to be removed after construction is complete).”

FERC-A1-68 through FERC-A1-85

Cultural Resources

Response: The applicant has separately ﬁled responses as privileged for AIRs 68, 69, 70, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84, and 85 in Atachment 68-85.

FERC-A1-87

Exhibit E

Aesthetic Resources

Appendix H, Visual and Aesthetics Report, Section 3.6 appears to indicate that KOPs were chosen because they are almost all on BLM land, “provide representative views of existing conditions and depict changes from the project”, and stakeholder input was used. However, it is unclear why these KOPs are representative of where the greatest number of people could view the project area the most often (i.e., KOP 1 is 9 miles north of the project area, while McGill is about 4 miles away and within the viewshed visible area. Additionally, why were no KOPs established east of Route 486, within the viewshed visible area, in the Duck Creek Range or High Schells Wilderness? Please revise the FLA to address how the KOPs were determined but do not appear to fully represent likely locations where the greatest number of people could view the project area the most often and explain why no KOPs were established east of Route 486 in the Duck Creek Range or High Schells Wilderness. Response The applicant selected poten�al KOPs due their poten�al for high visual impact (e.g., recrea�on trail, road, other recrea�on areas) and representa�ve views. These areas typically see the most use by visitors and recreators and therefore have the highest poten�al impact on viewers. The applicant also proposed KOPs based on their distance to the project facili�es (foreground, middleground, or background), land ownership and associated visual resource management plans, public access, and amount of redundancy/overlap with other proposed KOPs. To determine the final KOP loca�ons for the study, the applicant first conducted a viewshed analysis in GIS based on the loca�on and proposed height of project facili�es within the study area (see Figure 2 of Appendix H, Exhibit E of the FLA). Any poten�al viewpoint within the study area that was part of the visible viewshed was eligible as a KOP loca�on. The applicant then selected representa�ve KOPs for inclusion in the dra� Visual and Aesthetic Resources Study Plan. Secondly, the applicant considered input from stakeholders. On May 26, 2021, the applicant distributed the proposed Visual and Aesthe�c Resources Study Plan to stakeholders on the project’s distribu�on list (see Appendix A, Exhibit E of the FLA). The distribu�on list included representa�ves from federal agencies such as the BLM, USFS, FERC, NPS; na�ve American tribes; state agencies; county representa�ves; and local representa�ves. The selected KOPs were then included and analyzed in the DLA and appended Visual and Aesthe�c Resources Study Report that was distributed to stakeholders for addi�onal comments on February 17, 2022. Preliminary comments from the NPS and NNR in 2021 requested that views of passengers on the HiLine Branch be considered as part of the study. Based on input from other stakeholders, the applicant included the Schell Creek Range, Highway 93, Duck Creek Basin Loop (Success Loop), Success Summit, Camp Success, Timber Creek Campground, and Steptoe Valley as part of the KOP determina�on process. The KOPs analyzed in the 2021 Study Report are representa�ve of views from loca�ons iden�fied by stakeholders and include views most likely to be affected by proposed project features present in the foreground/middleground. The applicant selected KOP 1 due to its loca�on at the intersec�on of two commonly traveled roads: Highway 93 and State Route 486. KOP 1 is located near a direc�onal kiosk where many travelers stop and therefore have the poten�al to view project facili�es for an extended period of �me. While there are no KOPs located directly in McGill, there are many KOPs in and abu�ng the City of Ely which has approximately four �mes the amount of year-round residents as McGill. Due to the larger popula�on size and nearby tourist atrac�ons, including the NNR, the applicant chose representa�ve KOP loca�ons in and

near Ely, which has a higher poten�al visual impact than McGill. As described in the 2021 Study Plan, it was not feasible to conduct visual analysis from each viewpoint of the project. The applicant made an effort to focus on representa�ve areas with the poten�al highest impact to viewers as a conserva�ve approach. The greatest number of people who could view the project area would occur from travelers along SR 486, the City of Ely, and recreators using the NNR rail system; all of which have KOPs. As evidenced in the viewshed analysis, project features will be visible mostly from loca�ons in Steptoe Valley and westward. Only the upper reservoir dam will be visible from loca�ons along Route 486 and eastward. The applicant did include poten�al KOP loca�ons in the Duck Creek Range and High Schells Wilderness as part of the evalua�on process. Since there is limited public access and public facili�es within the Duck Creek Range and High Schells Wilderness, the poten�al impact on viewers in this area is low when compared to other areas within the viewshed. Only 7.4 percent of the High Schells Wilderness area falls within the visible viewshed and at much higher eleva�ons than much of the viewshed, thus not making it a representa�ve loca�on of a key viewing area. Within the wilderness, the few areas within the visible viewshed occur greater than 5-miles away and it is likely that a KOP in this loca�on would provide background views of project facili�es only. Addi�onally, while the wilderness does offer recrea�on opportuni�es it is in a very remote area which further reduces the number of poten�al viewers impacted by the project. Similarly, while part of the Duck Creek Range is within the visible viewshed, the largest visual impact to viewers within the Duck Creek Range would occur from traveling along SR486 or by the NNR rail system. Understanding that it would not be feasible or necessary to get KOP loca�ons in every affected area, the applicant conserva�vely chose loca�ons that would result in the greatest visual presence to viewers within the study area.

FERC-A1-88

Exhibit E

Aesthetic Resources

The Humboldt-Toiyabe National Forest, including the High Schells Wilderness, administered by the United States Forest Service is located approximately 4 miles from the proposed location of the project upper reservoir with many locations within the forest from where the upper reservoir could be visible (see Figure 3.11-1 KOPs and Viewshed Analysis). However, it appears that no consultation with Forest Service was conducted regarding potential project effects on visual resources within the National Forest. Please clarify if consultation with Forest Service was conducted regarding potential project effects on visual resources within the National Forest, and if not, why a decision was made not to conduct consultation with Forest Service on potential project effects on visual resources within the National Forest when it is clear from viewshed analysis that views from Forest Service administered land could be affected by project construction and operation. Response Guidelines for the iden�fica�on of visual resources on public land are contained in BLM Manual Handbook 8410-1, Visual Resource Inventory (BLM 1986). The BLM meets statutory requirements with their Visual Resource Management (VRM) program. The VRM classes are based on an inventory of three key elements: (1) scenic quality, (2) sensi�vity level, and (3) distance zones. Most lands within the Project Boundary are managed by BLM. Based on the Ely District RMP (BLM 2008b), the project boundary lies within Class II, Class III, and Class IV lands. The upper reservoir is in a Class II area. Both the lower reservoir and switchyard are in a Class III area. The transmission line crosses through Class II, Class III, and Class IV lands. There are no VRM Class I lands within the Project Boundary. Landscapes are subdivided into three distance zones based on rela�ve visibility from travel routes or from vistas. The observer’s proximity to elements will affect percep�on of their spa�al importance. Longer viewing distances tend to reduce the impression of spa�al enclosure and dominance. The three seen distance zones are defined as follows: •

•

Foreground-Middleground Zone: Areas less than 3-5 miles away from a travel route or viewpoint. From this distance, management ac�vi�es might be viewed in detail. The outer boundary of this distance zone is deﬁned as the point where the texture and form of individual plants are no longer apparent in the landscape. Background Zone: Areas beyond the 3–5-mile zone up to 15 miles away. This does not include areas in the background which are so far distant that the only thing discernible is the form or outline. To be included within this distance zone, vegeta�on should be visible at least as paterns of light and dark. Seldom Seen Zone: Areas that are not visible within the foreground-middleground and background zones and areas beyond the background zones.

The distance between the Na�onal Forest and the upper reservoir of the project would fall within the “Background Zone” of the iden�ﬁed distance zones. The Visual and Aesthetic Resources Study Report, Exhibit E – Appendix H, describes the results of the visual and aesthe�c resources study that was conducted in 2021. The study goal was to objec�vely assess the visual condi�on and impact of the project at various Key Observa�on Points.

Since there is limited public access and public facili�es within the Duck Creek Range and High Schells Wilderness, the poten�al impact on viewers in this area is low when compared to other areas within the viewshed. Only 7.4 percent of the High Schells Wilderness area falls within the visible viewshed and at much higher eleva�ons than much of the viewshed, thus not making it a representa�ve loca�on of a key viewing area. Within the wilderness, the few areas within the visible viewshed occur greater than 5-miles away and it is likely that a KOP in this loca�on would provide background views of project facili�es only. Addi�onally, while the wilderness does offer recrea�on opportuni�es it is in a very remote area which further reduces the number of poten�al viewers impacted by the project. On May 26, 2021, the applicant distributed the proposed Visual and Aesthetic Resources Study Plan to stakeholders on the project’s distribu�on list (see Appendix A, Exhibit E of the FLA). The distribu�on list included representa�ves from federal agencies such as the BLM, USFS, FERC, NPS; na�ve American tribes; state agencies; county representa�ves; and local representa�ves. The applicant consulted with USFS representa�ves during the various studies that have been conducted, before and a�er the submital of the Dra� License Applica�on (DLA), and a�er the submital of the Final License Applica�on (FLA). The applicant provided the USFS with no�fica�on and access to both the DLA and the FLA and specifically requested the USFS to provide comments on the documents, including the Visual and Aesthetic Resources Study Report. Most recently, the USFS was invited to par�cipate in a Technical Working Group to determine appropriate and applicable wildlife mi�ga�on measures for the project. USFS representa�ves declined to par�cipate.

FERC-A1-89

Exhibit E

Aesthetic Resources

Although stated several times in this section that nighttime construction activities may introduce temporary lighting in the project area, the FLA does not appear to provide details about nighttime lighting that would be in place at the project once it would be constructed. Additionally, although the FLA provides nighttime and dusk simulations from KOP 5 and KOP 7, respectively, it is not apparent during which phase of the project (construction or operation) each represents. Further, the FLA does not include nighttime simulations from all other KOPs. Please revise the FLA to: 1. describe the locations and types of permanent lighting that would be used at the project for project operation and 2. include nighttime simulations from each KOP showing the project’s likely nighttime lighting during project construction and operation. Response The project will have no no permanently lit areas following construc�on. Outdoor security ligh�ng will be installed as part of the project at the switchyard and tunnel portal. This ligh�ng will only be u�lized infrequently when needed for safety and maintenance. All outdoor ligh�ng will be switch or mo�on sensor controlled. Red railroad warning lights will also be used at the railroad crossings that will be installed. As noted in Exhibit A, Sec�on 4.2.1, opera�ng exterior ligh�ng will be minimal following construc�on. Area ligh�ng for the Project’s surface facili�es will consist of ligh�ng around the switchyard and main access tunnel portal and is proposed to incorporate both the Interna�onal Dark Sky Associa�on criteria and Occupa�onal Safety and Health Administra�on outdoor workplace safety requirements. In addi�on, ligh�ng may be provided to facilitate inspec�ons of the reservoir dams in the unlikely event of an emergency. Ligh�ng there would be used only during such occasions and would be controlled by switch. In consulta�on with the NPS and NNR for the supplemental studies currently underway, consensus was reached that nigh�me photo-simula�ons were not necessary (see Exhibit E, Appendix A Consulta�on Log). All par�es agreed that nigh�me photo-simula�ons would not show the project features.

FERC-A1-90

Exhibit E

Aesthetic Resources

Figure 3.11-1 KOPs and Viewshed Analysis, indicates the existence of a KOP – Highline Excursion Turnaround, Approximate Location. However, it appears no current image or simulated image for this identified KOP is provided. Please provide a current image and a simulated image for this identified KOP. Additionally, although Figure 3.11-1 indicates land from which the project could be visible it does not identify specific land types or places such as private residential areas and public spaces (e.g., parks and wilderness areas) from which the project could be visible. Please revise Figure 3.11-1, or provide a new figure, to show and identify these types of lands and places from which the project could be visible. Response The applicant did not develop the KOP-Highline Excursion Turnaround for Exhibit E, Sec�on 3.11 nor Exhibit E, Appendix H, Visual and Aesthe�c Study Report. KOP 12, which the applicant developed as a part of the Supplemental Visual and Aesthe�c Study Report, is representa�ve of the views from the HiLine Excursion Turnaround point. Through consulta�on with NPS (see Exhibit E, Appendix A Consulta�on Log, pdf page 3182) a photo-simula�on from KOP 12 was determined to be unnecessary. Consensus with NPS was reached to develop photo-simula�ons for KOP 4, 5, 15, 16, and 17. KOP 12 and 14 photo-simula�ons were not developed as a result. The applicant modified Figure 3.11-1 to remove the text for the missing KOP and iden�fy specific land type or places, such as private residen�al areas and public spaces. Please see Atachment 90-1, updated Figure 3.11-1.

FERC-A1-91

Exhibit E

Aesthetic Resources

Section 3.11.1 Affected Aesthetic Environment, states that most lands within the project boundary are managed by BLM and are located within the BLM VRM Class II, Class III, and Class IV lands. The section further explains that certain proposed project facilities would be located within certain VRM Class lands (e.g., the upper reservoir would be located in a Class II area). While these explanations are helpful it is difficult to understand spatially where proposed project facilities would be located related to VRM classified lands and where VRM classified lands are located in relation to each other. Please file a map showing (a) the VRM classifications of all lands on which project facilities would be located (please use a color to represent each VRM classified land) and (b) the proposed project boundary and all proposed project facilities within those lands. Response Figure 91-1 shows the BLM VRM classifica�ons of all lands on which project facili�es would be located (using a color to represent each VRM classified land, as specified in the figure legend) and the proposed project boundary and all proposed project facili�es within those lands.

Figure 91-1: BLM Visual Resource Inventory Classes

FERC-A1-92

Exhibit E

Aesthetic Resources

Although Section 3.11.1 Affected Aesthetic Environment, provides a brief description of the general aesthetic environment of the project area it does not provide sufficient detail about aesthetics of the actual lands on which the proposed project facilities would be located. Please revise the FLA to provide more details about the aesthetic character of all lands on which all proposed project facilities would be located. Response The proposed project will be located in White Pine County approximately 8 miles northeast of the City of Ely. The average temperatures range from between 39.0 degrees Fahrenheit in January to 86.9 degrees Fahrenheit in July. The average annual rainfall for the period of record (1892-2016) in the project vicinity is 8.86 inches, which is par�ally comprised of an average annual snowfall that is 22.10 inches (Western Regional Climate Center 2021). Major water sources within the project vicinity are Steptoe Creek and Duck Creek. Duck Creek, approximately 2 miles northeast of the project boundary, is the closest body of free-flowing surface water to the project and much of the creek flow originates as spring snowmelt in the Schell Creek Mountain Range. The surrounding areas consist of flat valleys, rolling foothills, and pyramidal mountains allowing the user a wide and far range of views and are generally undisturbed except for minor infrastructure such as power lines, paved and dirt roads, ranch land, and the City of Ely and the Town of Ruth (BLM 2016). The project vicinity is characterized by a high desert landscape, with a visually interes�ng transi�on from the more developed valley floor (agriculture) to the surrounding mountain ranges, including the Egan and Schell Creek Mountain Ranges. The south end of the valley where the proposed project will be located contains the most development (BLM 2008). Eleva�ons in the project vicinity are widely variable. The approximate eleva�on of the proposed lower reservoir is 6,500 feet. The approximate eleva�on of the proposed upper reservoir is 8,500 feet. Terrain is rugged in the mountain ranges and rela�vely flat on the valley floor. Ini�al and secondary upli� of the region has created stream gradients such that the streams of the region have down cut into and dissected the exis�ng landforms, crea�ng dissected drainage paterns on the mountain slopes, which typically terminate in alluvial fans on the adjacent valley floors. Within the immediate project area, the majority of land cover includes woodland, desert scrub, grasslands, and shrubland. The land is dominated by sagebrush scrub in the lower eleva�on areas generally below 6,800 feet and pinyon-juniper woodland in the higher eleva�on areas above 6,500 feet. A riparian woodland occurs to the east of the project footprint and occasional chaparral habitat types also occur in the project footprint. Seasonal catle grazing occurs throughout the project area. The sagebrush scrub in the project footprint is dominated by a mixture of litle sagebrush (Artemisia arbuscula), black sagebrush (Artemisia nova), and mountain big sagebrush (Artemisia tridentata ssp. vaseyana) in the shrub community, along with scatered occurrences of broom snakeweed (Gu�errezia sarothrae), basin big sagebrush (Artemisia tridentata ssp. tridentata), mated wild buckwheat (Eriogonum caespitosum), and rubber rabbitbrush (Ericameria nauseosa). In some isolated areas, big sagebrush is the dominant species. A steppe form of this habitat also occurs with lesser cover of woody shrubs and greater cover of grasses such as thickspike wheatgrass (Elymus lanceolatus), Sandberg bluegrass (Poa secunda),

bluebunch wheatgrass (Pseudoroegneria spicata), Leterman’s rice grass (Achnatherum letermanii), and Indian rice grass (Achnatherum hymenoides). The pinyon-juniper woodland is a mix of Utah juniper (Juniperus osteosperma) and single-leaf pinyon (Pinus monophylla) with variable dominance of both species in the tree community, along with some occurrences of the same species found in sagebrush scrub in the shrub community, most notably mated wild buckwheat. A juniper savannah-like habitat occurs around the proposed reservoir loca�ons that is similar to the steppe form of sagebrush scrub but differs in having cover of mature Utah juniper trees. Bristlecone pine was not observed during field studies in the loca�on of any proposed project facili�es. The most common herbaceous species observed in the loca�on of the proposed project facili�es are cheatgrass (Bromus tectorum), widewing spring parsley (Cymopterus purpurascens), thorny skeletonweed (Pleiacanthus spinosus), James’ cryptantha (Cryptantha cinera var. abor�va), flat spine sheepbur (Lappula occidentalis), long spur lupine (Lupinus arbustus), northwestern Indian paintbrush (Cas�lleja angus�folia var. dubia), and Simpson’s buckwheat (Eriogonum microthecum var. simpsonii). The proposed upper reservoir will be approximately 4 miles from the High Schells Wilderness and the proposed transmission line will be approximately 1.2 miles from the Bristlecone Wilderness at its closest point to the transmission line right of way (ROW). The Wilderness Act in 2006 designated the High Schells Wilderness as a wilderness area under the which consists of 121,497 acres in White Pine County, 10 miles northeast of Ely. The eastern por�on has canyons that lead down into Spring Valley, a ver�cal mile below. The east-side canyons are deeply incised and heavily wooded, with riparian thickets along stream banks. Wheeler Park and the South Snake Range, a mountain island surrounded by desert valleys, are to the southeast. Bristlecone pines and equally impressive limber pines are present in the higher eleva�on forests. Popular recrea�on ac�vi�es include hiking, horseback riding, backcountry skiing, fishing, big game and upland game bird hun�ng (USFS,Undated). The Wilderness Act in 2006 designated the Bristlecone Wilderness as a wilderness area which consists of 14,095 acres in White Pine County near Ely. The Bristlecone Wilderness contains diverse landforms and vegeta�on types, including sage, grass and juniper at lower eleva�ons, mixed with aspen stands in the middle eleva�ons, and bristlecone pine and fir stands mixed with grasses and forbs at the upper eleva�ons. It ranges in eleva�on from 7,400 feet to 9,800 feet in the central Egan Range. Hiking to the summit of Heusser Mountain, the prominent landmark of the Bristlecone Wilderness, is a recrea�onal ac�vity in the wilderness area. Visitors may also enjoy several primi�ve recrea�onal opportuni�es, such as hun�ng, camping, scenic viewing, and photography (BLM, 2014). Highway 50, an east-west travel route and statedesignated scenic byway (also known as “America’s Loneliest Highway”) and Highway 93, a north-south travel route, are to the west and east of general project area respec�vely. State Route 486 is a scenic northsouth travel route in the eastern por�on of the project footprint. The BLM manages most lands within the project footprint and are subject to the BLM’s Ely District Resource Management Plan (RMP) with goals to manage public lands and ac�vi�es in a manner consistent with the BLM Ely District Office Visual Resource Inventory objec�ves. Public lands are rated as Class A (high scenic quality), Class B (typical or average scenic quality), or Class C (low scenic quality) based on the apparent scenic quality, and have several key factors: landform, vegeta�on, water, color, adjacent scenery, scarcity, and the presence or absence of exis�ng cultural modifica�ons.

The majority of project facili�es are in areas classified as Class B while areas like the Bristlecone Wilderness are classified as Class A. The project transmission line lies largely within Class B but also crosses over Class A and Class C areas to the west of the project reservoirs. Lands poten�ally affected by Project construc�on, opera�on, and maintenance are largely undeveloped. Cita�ons Bureau of Land Management (BLM). 2008. Final Environmental Impact Statement for the White Pine Energy Sta�on Project. FES 08-38. Department of the Interior. Reno, NV. Bureau of Land Management (BLM). 2014. Bristlecone and Goshute Canyon Wilderness Preliminary Wilderness Management Plan. BLM Ely District Office. DOI-BLM-NV-L000-2014-0001-EA. Bureau of Land Management (BLM). 2016. Final Environmental Assessment – Robinson Mine Expansion Project. [Online] URL: htps://eplanning.blm.gov/epl-frontoffice/projects/nepa/68666/94309/113835/Robinson_Final_EA_20161222_508.pdf (Accessed March 17, 2020). Bureau of Land Management (BLM). Undated. Visual Resource Management. [Online] URL: htps://www.blm.gov/programs/recrea�on/recrea�on-programs/visual-resource-management (Accessed March 17, 2020). U.S. Forest Service (USFS). Undated. High Schells Wilderness. Online htps://www.fs.usda.gov/detailfull/htnf/home/?cid=stelprdb5238646. Accessed: June 2023.

[URL]:

Western Regional Climate Center. 2021. Climate Summary for the Period of Record (1892–2016) in McGill, Nevada (Sta�on 264950). Accessed June 28, 2021. htps://wrcc.dri.edu/summary/. Western Regional Climate Center, Reno, NV.

FERC-A1-93

Exhibit E

Aesthetic Resources

Section 3.11.2.3 KOP 2: County Road 28, states that the KOP location in the foothills of the Egan Range was selected to be representative of views from the nearby BLM Bristlecone Wilderness. Whereas, KOP 2 appears to be located at about 6,200 feet elevation, the Bristlecone Wilderness (not shown in Figure 3.111 KOPs and Viewshed Analysis) encompasses the higher elevations of Heusser Mountain, from 7,000 feet to over 8,800 feet elevation, and does not extend down to the foothills. Therefore, views from KOP 2 cannot be representative of views from the Bristlecone Wilderness. Please revise the FLA to provide KOP both current views and simulated views towards the proposed project location from the Bristlecone Wilderness. Response KOP 2 has a higher recorded visitorship in the area around KOP 2tan wi�hn the Bristlecone Wilderness. The applicant selected KOP 2 over other poten�al KOPs within the Bristlecone Wilderness because of this higher poten�al for visual impact to these visitors. While approximately 71 percent of the Bristlecone Wilderness falls within the visible viewshed, views of project facili�es from eleva�ons greater than 7,000 feet are likely to be background views, having lower visual impact on viewers when compared to middle ground or foreground views. To be conserva�ve, the applicant chose a loca�on near the Bristlecone Wilderness that had representa�ve middleground views of the project facili�es (KOP 2). Addi�onally, the lands within the Bristlecone Wilderness have limited accessibility since mechanized and motorized vehicles are not allowed. As such, recrea�on ac�vity is not ac�vely monitored within the wilderness, the applicant selected KOP 2 as a representa�ve loca�on along County Road 28 which has a greater number of viewers than loca�ons within the Bristlecone Wilderness, thus having a higher poten�al visual impact. Viewer groups from KOP 2 include recrea�onists traveling to and from the Bristlecone Wilderness, residents, workers, and other travelers. The applicant circulated a study plan for the visual and aestheic report to stakeholders in 2021, and no stakeholder requested to include photo simula�ons from within the Bristlecone Wilderness. Addi�onally, the applicant included the study plan and methodology with the report submited with the DLA in 2022, and no stakeholder requested to include photo simula�ons from within the Bristlecone Wilderness.

FERC-A1-94

Exhibit E

Aesthetic Resources

Appendix H Visual and Aesthetics Report, Attachment 1, Map of Study Area, appears to show State Route 893 but does not show State Route 486 which is currently used by visitors to access portions of the High Schells Wilderness and could be used by project construction vehicles to access the proposed upper reservoir access road to the east of the proposed upper reservoir. Please modify Attachment 1, Map of Study Area, to show State Route 486, the boundary of the High Schells Wilderness, and the boundary of any other wilderness area within the 15-mile study area buﬀer shown on the map. Response Appendix H Visual and Aesthe�cs Report, Atachment 1, Map of Study Area, is part of the 2021 Visual and Aesthe�c Resources Study Plan that the applicant distributed to stakeholders on March 10, 2021. Appendix H Visual and Aesthe�cs Report, dated January 17, 2022, includes a revised map of the study area (Figure 1 on page 3) which shows State Route 486. The applicant has further revised Figure 1 of Appendix H of Exhibit E of the FLA (see Figure 94-1 below) to include the boundary of the High Schells Wilderness, Bristlecone Wilderness, and Shelback Wilderness. The revised Figure 1 is included below. In addi�on, an alterna�ve access to the upper reservoir from the Duck Creek side, referred to as the upper reservoir op�onal access road is proposed as a new 3.5-mile, improved, gravel, single-lane access road for op�onal and/or emergency use that will traverse the Duck Creek range from a �e-in along the White Pine County Road 29 (NV-486). As such, project construc�on vehicles will not be able to use or access the upper reservoir via the upper reservoir op�onal access road, to the east of the proposed upper reservoir.

Figure 94-1: Revised Figure 1 Aesthe�c and Visual Resources Study Area with Wilderness Areas

FERC-A1-95

Exhibit E

Aesthetic Resources

Appendix H Visual and Aesthetics Report, Section 2.3 Photosimulation, indicates images were created compositing a scaled, geo-referenced model of existing and proposed conditions with a photograph. However, it is unclear from this explanation and from the photosimulations that all proposed project facilities within specific viewsheds of each KOP are represented within the view shown in each photosimulation. All proposed permanent and temporary project facilities and features including, but not limited to, the wellfield, access roads, spoil disposal site, construction and staging areas (including any potential office/operations trailers), and explosives storage facilities, must be represented in each photosimulation in which they are located within the viewshed of the corresponding KOP. Additionally, while the descriptions provided in Section 4.1 Construction and Operational Impacts, of the locations of some project facilities within the KOP photosimulations are helpful, the image resolution of the photosimulations is not high enough for the viewer to properly see project facilities that are included in some images; specifically, in the images where the KOP is at a greater distance from the proposed project location (e.g., Figure 19). Therefore, please (a) modify the photosimulations to include all proposed project facilities and features that would be located within the viewshed of the corresponding KOP and increase the image resolution of the photosimulations where the KOP is at a greater distance from the proposed project location, then refile these photosimulations, and (b) file a duplicate of each photosimulation that identifies project facilities and features that appear in the image. Response The applicant generated photo simula�ons for the 2022 Visual and Aesthe�c Report to represent the condi�ons following construc�on of the project prior to revegeta�on. The Supplemental Key Observa�on Points and Photo Simula�ons to the Visual and Aesthe�c Resources Study Report, dated July 16, 2023 (Supplemental Visual and Aesthe�c Report) includes photo simula�ons of the project facili�es following construc�on and before revegeta�on. The photo simula�ons generated for the 2022 Visual and Aesthe�c Report do not include spoils piles or laydown areas, however, the applicant included these features in the photo simula�ons for the Supplemental Visual and Aesthe�c Report. Photo simula�ons do not include temporary features such as construc�on ac�vi�es due to the temporary nature of the visual impact and level of variability on a day-to-day basis. Construc�on ac�vi�es vary greatly throughout the day and phases of construc�on, photo simula�ons would not be able to capture a moment in �me that would be considered representa�ve. The applicant circulated a study plan to stakeholders in 2021, and no stakeholder requested to include construc�on ac�vi�es in the photo simula�ons. Addi�onally, the applicant included the study plan and methodology with the report submited with the DLA in 2022, and no stakeholder requested to include construc�on ac�vi�es in the photo simula�ons. The visual impact of construc�on at each KOP is described in Sec�on 4.1 of the 2022 Visual and Aesthe�c Report. In regards to image resolu�on and ability to see project facili�es at greater distances, the applicant generated photo simula�ons to be representa�ve of what would be visible in the picture at that distance. Manipula�ng the resolu�on of the photo-simula�ons to make the project facili�es more visible would be a misrepresenta�on and inaccurate. Project facili�es at a distance will have a lower resolu�on from a viewer's perspec�ve.

Please see Atachment 95-1: KOP 1-10 Current and Photo-Simula�ons, which includes a side by side of the photos for current and simulated. Included a�er each photo simula�on is list of the project facili�es that are included in the photo simula�on. FERC-A1-96

Exhibit E

Socioeconomic Resources

Section 3.12.2.2 Social Impacts Analysis, states that the project is expected to bring to the county more than 900 non-resident, construction-related workers during the construction period. However, it is not clear whether the more than 900 workers would relocate temporarily to the project area. Please revise the FLA to clarify whether this means that some or all of the 900 non-resident construction related workers would relocate temporarily to the project area for the duration of construction activities. If not all of the workers are expected to relocate temporarily, how many would relocate temporarily and how many would commute daily to the construction site from places outside of the project-affected area? Response The applicant does not yet know from where the various goods and services required during construc�on and opera�ons would be sourced, from where the poten�al bidders for the work would come from, or which companies would be awarded the contracts. The applicant an�cipates that the construc�on company (or companies) awarded this project will strive to hire as many local construc�on contractors as possible. For conserva�ve impact planning purposes as described below, the applicant es�mates that up to 900 non-resident construc�on related workers would temporarily relocate to the project area for the dura�on of construc�on ac�vi�es. The applicant conserva�vely assumed that all the 900 workers would relocate temporarily to the project area for the dura�on of construc�on ac�vi�es in response to the different phases of the project when evalua�ng poten�al project related socioeconomic impacts. It is unknown what percentage of local and commutable construc�on workforce will accept short-term, temporary construc�on opportuni�es at the project. Cita�ons U.S. Census Bureau. Undated. White Pine County, Nevada. Online [URL]: htps://data.census.gov/profile/White_Pine_County...?g=050XX00US32033. Accessed: May 2023.

FERC-A1-97

Exhibit E

Socioeconomic Resources

Section 3.12.2.2 Social Impacts Analysis, states that few if any displacements of residences or businesses would likely occur in order to construction and operate the project. This appears to indicate that displacements of residences and/or business could occur. Please describe the residences and/or businesses that could be displaced and the location(s) of each. Please also describe how White Pine would acquire these properties and what types of payments would be made to the aﬀected land or business owner(s). Response The applicant does not an�cipate any displacements of residences or businesses to occur in order to construct and operate the project. The text referenced in Exhibit E, Sec�on 3.12.2.2 should read: “The Project Footprint and adjacent lands are sparsely populated. Displacements of residences or businesses is not anticipated to occur as part of Project construction or operation.” Therefore, a descrip�on of the residences and/or businesses that could be displaced and the loca�on(s) of each is not applicable to the project. Because displacement of residents and businesses is not an�cipated, the applicant does not plan to acquire any such property or businesses.

FERC-A1-98

Exhibit E

Comprehensive Plans

Section 5.3 Consistency with Comprehensive Plans, states that White Pine is considering four additional plans recommended by stakeholders, including: (a) Bureau of Land Management. 2019. Nevada and Northeastern California Greater Sage-grouse Record of Decision and Approved Resource Management Plan Amendment. March 2019; (b) White Pine County. 2018. White Pine County Public Lands Policy Plan. Prepared by the White Pine County Public Land Users Advisory Committee. October 2018; (c) White Pine County. 2019. Approval of Resolution 2020-051 Adopting White Pine County Water Resource Plan Element to the White Pine County Master Plan; and (d) White Pine County. 2005. White Pine County Open Space Plan. September 2005. Ely, Nevada. Please file these plans with the Commission so that staff can properly review the plans and analyze potential project effects that could impact resources managed by these plans. Response In October 2019 a federal court granted an injunc�on to prevent the BLM from implemen�ng the Nevada and Northeastern California Greater Sage-grouse Record of Decision and Approved Resource Management Plan Amendment. Because of this injunc�on, the BLM reverted to the 2015 guidance. Therefore, the following plan has been removed from considera�on.: •

Bureau of Land Management. 2019. Nevada and Northeastern California Greater Sage-grouse Record of Decision and Approved Resource Management Plan Amendment. March 2019.

As requested, the following plans are atached as Atachments 98-1, 98-2, and 98-3: • • •

White Pine County. 2018. White Pine County Public Lands Policy Plan. Prepared by the White Pine County Public Land Users Advisory Commitee. October 2018. White Pine County. 2019. Approval of Resolu�on 2020-051 Adop�ng White Pine County Water Resource Plan Element to the White Pine County Master Plan. White Pine County. 2005. White Pine County Open Space Plan. September 2005. Ely, Nevada.

FERC-A1-99

Exhibit E

Comprehensive Plans

Section 5.3 Consistency with Comprehensive Plans, states that the project, as currently designed, is inconsistent with two of the plans: Bureau of Land Management. 2015. Record of Decision and Approved Resource Management Plan Amendments for the Great Basin Region, Including the Greater Sage-Grouse Sub-Regions of Idaho and Southwestern Montana, Nevada and Northeastern California, Oregon, and Utah. Washington, D.C. September 2015 and Bureau of Land Management. 2019. Nevada and Northeastern California Greater Sage-grouse Record of Decision and Approved Resource Management Plan Amendment. March 2019. However, the FLA does not appear to explain why the project is inconsistent with the plans. Please revise the FLA to explain why the project, as currently designed, is inconsistent with the two plans. Response In the applica�on, the applicant reviewed the 16 federal and state comprehensive plans listed in FERC’s List of Comprehensive Plans for Nevada. The applicant determined that nine of the plans were poten�ally applicable to the project and ini�ally ruled out the other seven. Upon addi�onal analysis the applicant has determined that of those nine comprehensive plans only one directly guides the use of the project lands: BLM 2015 Nevada and Northeastern California Greater Sage-Grouse Approved Resource Management Plan Amendment (2015 ARMPA). In October 2019, an injunc�on was granted to prevent the BLM from implemen�ng the 2019 ARMPA and as a result the BLM reverted to the 2015 ARMPA guidance. The BLM Ely District Resource Management Plan (BLM Ely District RMP), as amended (2008) incorporated several comprehensive plans including the Egan Resource Area Management Plan (1987). While the BLM Ely District RMP is not included in the list of the 16 federal and state comprehensive plans iden�ﬁed in FERC’s List of Comprehensive Plans for Nevada, the RMP has also been iden�ﬁed as an applicable comprehensive plan. Consequently, there are two guiding comprehensive plans. Table 99-1 summarizes issues of noncompliance with the 2015 ARMPA and the BLM Ely District RMP and explains the process to address issues of non-compliance.

Table 6-1: Summary of Consistency with Comprehensive Plans Comprehensi ve Management Plan

FLA Reference Resource Sec�on

BLM Ely Exhibit E Sage Grouse District Sec�on 3.7.1.9 Record of Decision and Approved Resource Management Plan, as amended. 2008

Introduced in Exhibit E Sec�on 1.2.2

Management Plan Limita�on

Why Devia�on Required

is Path Forward

No surface ac�vity would be allowed within two miles of a sage grouse lek from March 1 through May 15 (June 15)

Por�ons of the project footprint are within winter and summer range and cannot be constructed without use of this land. Construc�on No surface ac�vity would be would need to proceed allowed within winter range for year-round to eﬃciently sage grouse from November 1 develop the project through March 31.

The applicant is coordina�ng with the BLM to form a technical working group that will include NDOW and other stakeholders, to develop mi�ga�on strategies that would in part provide a conserva�on gain to GRSG whereupon the BLM could grant an excep�on 1

NOTE: The BLM 2015 Nevada and Northeastern California Greater Sage-Grouse ARMPA supersedes these 2008 limita�ons Exhibit E Elk/mule Sec�on 3.7.1.6 deer/prongh orn crucial summer range Seasonal Limita�ons

No surface ac�vity would be allowed within big game calving/fawning/kidding/lambing grounds from April 15 through June 30

Por�ons of the project are located within the elk/mule deer/pronghorn crucial summer range and cannot be constructed without use of this land. Construc�on would need to proceed year-round to eﬃciently develop the project

The applicant is coordina�ng with the BLM to form a technical working group to develop mi�ga�on strategies for ungulates (in addi�on to the GRSG)1. The applicant will request an excep�on for this seasonal limita�on from the BLM

Comprehensi ve Management Plan

FLA Reference Resource Sec�on

Management Plan Limita�on

Why Devia�on Required

Exhibit E Elk/mule Sec�on 3.7.1.6 deer/prongh orn crucial winter range Limita�ons

No surface ac�vity would be allowed within big game crucial winter range from November 1 through March 31

Por�ons of the project are located within the elk/mule deer/pronghorn crucial winter range and cannot be constructed without use of this land. Construc�on would need to proceed year-round to develop the project

The applicant is coordina�ng with the BLM to form a technical working group to develop mi�ga�on strategies for ungulates (in addi�on to the GRSG)1.

Exhibit E Ac�ve raptor No surface ac�vity will be allowed Construc�on would need Sec�on 3.7.1.7 nest sites from May 1 through July 15 within to proceed year-round to 0.5 mile of a raptor nest site that develop the project has been ac�ve within the past 5 years.

The applicant will conduct pre-construc�on surveys for raptors and migratory bird nests. Construc�on ac�vi�es that can be delayed un�l the young have ﬂedged will be scheduled as such. In areas where the construc�on ac�vi�es cannot be temporarily halted, the applicant will coordinate with BLM and NDOW to develop appropriate mi�ga�on and request an excep�on for this seasonal limita�on from the BLM

Note that FLA Table 3.7-10 lists a March 1 – July 31 raptor limita�on. May 1 – July 15 is a correc�on to the FLA

is Path Forward

The applicant will request an excep�on for this seasonal limita�on from the BLM

Comprehensi ve Management Plan

FLA Reference Resource Sec�on

BLM 2015 Exhibit E Nevada and Sec�on 3.7.1.9 Northeastern California Greater SageGrouse Approved Resource Management Plan Amendment (ARMPA)

Sage Grouse Priority Habitat Management Area (PHMA)

Introduced in Exhibit E Sec�on 1.2.2

Management Plan Limita�on

Why Devia�on Required

is Path Forward

PHMAs are subject to no surface occupancies (NSOs), with no waivers or modiﬁca�ons. Excep�ons would be granted under two circumstances: if the proposed ac�on would not have direct, indirect, or cumula�ve eﬀects on GRSG or its habitat; or if the ac�on is proposed to be undertaken as an alterna�ve to a similar ac�on occurring on a nearby parcel, and it would provide a clear conserva�on gain to GRSG.

Both temporary and permanent disturbance are within PHMA and the project cannot be constructed without use of this land

The applicant is coordina�ng with the BLM to form a technical working group to develop mi�ga�on strategies that would provide a conserva�on gain to GRSG whereupon the BLM could grant an excep�on 1

Both temporary and permanent disturbance are within GHMA and the project cannot be constructed without use of this land

2015 ARMPA Sec�on 1.4 Table 1-4 Exhibit E Sec�on 3.7.1.9

Sage Grouse General Habitat Management Area (GHMA)

Restric�ons on development in GHMAs are intended to allow disturbance but minimize adverse eﬀects of disturbance with restric�ons. Disturbance is subject to a controlled surface use and �ming limita�on s�pula�on and subject to mi�ga�on, with the objec�ve of ﬁrst

Comprehensi ve Management Plan

FLA Reference Resource Sec�on

Management Plan Limita�on

Why Devia�on Required

is Path Forward

avoiding and minimizing poten�al impacts on GRSG or its habitat and then compensa�ng for unavoidable impacts on GRSG or its habitat Exhibit E Sec�on 3.7.1.9

PHMA, GHMA Seasonal Timing Limita�ons

Greater Sage-grouse breeding habitat within 4 miles of ac�ve/pending leks: March 1 – June 30 Greater Sage-grouse rearing habitat: May 15 – September 15

Construc�on would need to proceed year-round to develop the project. Note that without relief from seasonal limita�ons there is only a 6-week open brood- period to construct (September 15 – November 1)

The applicant is coordina�ng with the BLM to form a technical working group to develop mi�ga�on strategies that would provide a conserva�on gain to GRSG whereupon the BLM and NDOW could grant an excep�on 3

Greater Sage-grouse winter habitat: November 1 – February 28

In mid-2022, the applicant requested the BLM convene a mul�-stakeholder technical working group (TWG) to consider various minimiza�on and mi�ga�on measures to address concerns with Greater Sage Grouse (GrSG) habitat within the project area boundary. These measures would then support a poten�al sitespecific amendment to the GrSG - Approved Resource Management Plan Amendment (ARMPA). The BLM indicated in response that pursuit of a site-specific amendment to the GrSG ARMPA would likely conflict with the na�onal policy review of a GrSG Resource Management Plan Amendment that is currently underway. 3

FERC-A1-100

Exhibit E

Comprehensive Plans

Section 5.3 Consistency with Comprehensive Plans, states that: (a) White Pine has begun consultation with the BLM; (b) BLM will evaluate the project to determine if it is in conformance with the goals and objectives of the Ely District Resource Management Plan (BLM 2008); and (c) White Pine proposes to continue to coordinate with BLM to adopt measures to ensure compliance with the Ely District Resource Management Plan and the 2015 Record of Decision and Approved Resource Management Plan Amendments for the Great Basin Region, Including the Greater Sage-Grouse Sub-Regions of Idaho and Southwestern Montana, Nevada and Northeastern California, Oregon, and Utah. It appears that consultation activities are not complete and that additional, relevant information from further consultation activities may be forthcoming that would be necessary to complete the FLA. As such, please: (a) explain this apparent incomplete consultation with BLM; (b) indicate if additional consultation has also just begun (or is ongoing) with other stakeholders and agencies; (c) identify when consultation activities are anticipated to be complete; and (d) identify when additional, relevant information (including potential measures) from further consultation activities may be filed with the Commission. Additionally, please explain why the Ely District Resource Management Plan is not included in the list of applicable comprehensive plans identified by White Pine as relevant to the project. If the Ely District Resource Management Plan is relevant to the project, as it appears to be because White Pine proposes to adopt measures to ensure compliance with the it, then revise the list of applicable comprehensive plans to include the plan. Response In the license applica�on, the applicant reviewed the 16 federal and state comprehensive plans listed in FERC’s List of Comprehensive Plans for Nevada. The applicant determined that nine of the plans were poten�ally applicable to the project and ini�ally ruled out the other seven. Upon addi�onal analysis the applicant has determined that of those nine comprehensive plans only one directly guides the use of the project lands: BLM 2015 Nevada and Northeastern California Greater Sage-Grouse Approved Resource Management Plan Amendment (2015 GrSG ARMPA). The BLM Ely District Resource Management Plan (BLM Ely District RMP), as amended (2008) incorporated several comprehensive plans including the Egan Resource Area Management Plan (1987). Therefore, the applicant has iden�fied two guiding comprehensive plans, BLM Ely District RMP and the 2015 GrSG ARMPA, both of which are implemented by BLM. Consulta�on began with BLM in 2020 and is ongoing. In addi�on to obtaining a FERC license for the project, the project requires a right of way (ROW) grant on BLM administered federal lands. In early 2023, the applicant submited a request to BLM – Bristlecone Field Office, Ely District for BLM to convene a GrSG technical working group (TWG) to facilitate discussion and assist in defining acceptable and achievable mi�ga�on measures. The purpose of these mi�ga�on measures is to help frame a projectspecific excep�on to the current 2015 GrSG ARMPA that will result in a net conserva�on gain for GrSG popula�on and habitat. Further discussions with BLM have resulted in broadening the scope of the TWG to discuss and consider mi�ga�on measures for both GrSG, ungulates, and other wildlife. The BLM invited via leter several federal, state, and local agencies to par�cipate in the TWG. Seven individuals over four organiza�ons (NDOW, BLM, WPC, and NV-SETT) have formed the TWG along with the applicant. The first mee�ng of the TWG was held on June 27, 2023. Goals established include defining a boundary for wildlife impacts (both direct and indirect) and developing a comprehensive mi�ga�on plan that includes Nevada’s Conserva�on Credit system. Mee�ngs are set to occur monthly, with a target end date of December 2023.

The applicant will consult with the TWG on comprehensive mi�ga�on plans that will be incorporated into the environmental review process and inform the project-specific excep�on to the comprehensive plan to facilitate construc�on and opera�on of the project. The applicant expects these mi�ga�on measures will be incorporated into the FERC environmental review process . The TWG will also allow coordina�on and input rela�ng to any proposed mi�ga�on measures between the applicant, BLM, and FERC. While the BLM Ely District RMP is not included in the list of the 16 federal and state comprehensive plans iden�fied in FERC’s List of Comprehensive Plans for Nevada, the applicant has iden�fied the BLM Ely District RMP as an applicable plan. This RMP includes a renewable energy goal to “provide opportuni�es for development of renewable energy sources such as wind, solar, biomass, and other alterna�ve energy sources while minimizing adverse impacts to other resources.” The project complies with this renewable energy goal as it will provide an opportunity for significant energy storage capability for these alterna�ve energy sources.

FERC-A1-101

Exhibit F

Section 4.41(g)(3)(iv) of the Commission’s regulations requires that the supporting design report include the stability and stress analyses for all major structures and critical abutment slopes under all probable loading conditions, including seismic and hydrostatic forces induced by water loads up to the Probable Maximum Flood as appropriate. Although the Preliminary Supporting Design Report is acceptable, the following additional analyses would need to be completed as per FERC Engineering Guidelines, Chapter 4 during the project design phase if a license is issued: § Considering the frequent drawdown operation expected for the project, stability evaluation for the lower and upper reservoir embankments should be completed for sudden drawdown under static and seismic loading. This stability evaluation should consider the potential impacts of linear failure and defects. Since some input parameters and considerations for these analyses may depend on other noncompleted yet studies and evaluations, the sudden drawdown stability analyses should be performed after completing the site-specific Seismic Hazard Assessment. § Time history seismic deformation analyses should be performed for the lower and upper reservoirs. These analyses should be performed after completing the Final Site-Specific Seismic Hazard Assessment. Refer to our Engineering Guidelines, Chapter 13, for guidance on site-specific Seismic Hazard Assessments. RESPONSE: The applicant acknowledges the Commissions regula�ons requiring addi�onal analysis during the project design phase following issuance of a license. The applicant confirms that the following addi�onal studies and analysis will be carried out in the next phase of design and looks forward to further input and review by the Commission on these items. 1. Site Specific Hazard Assessment 2. Rapid drawdown for both upper and lower reservoirs under sta�c and seismic loading and with the poten�al impacts of linear failure and defects 3. Time history seismic deforma�on analysis for both upper and lower reservoirs

FERC-A1-102

Exhibit G

Although Maps G5 and G6 appear to show that the project boundary encompasses the project cable, main access, and tailrace tunnels, neither is identiﬁed in the maps. Please modify Maps G5 and G6 to identify the project facilities. RESPONSE: The applicant has updated the requested maps to show the loca�on of all project works and principal features. To facilitate addi�onal labels and facility linework, the applicant has increased the scale and number of maps to allow for addi�onal detail. All principle underground works within the project boundary are now shown and iden�ﬁed including the cable, main access and tailrace tunnels. (See Atachment 19-1 - Map G10)

FERC-A1-103

Exhibit G

Although Map G6 shows PLSS sections, it does not identify the associated Townships and Ranges. Please modify Map G6 to identify the Townships and Ranges. RESPONSE: The applicant has updated the requested maps to show the Townships and Ranges more clearly and included clearer Township and Range outline linework on the maps and legends (See Atachment 19-1 Map G1 – G13)

White Pine Waterpower, LLC FERC Project No. 14851-003 May 25, 2023 Addi�onal Informa�on Request Responses

FERC-A2-1

Exhibit A

Section 3.1 Western Access Road and Exhibit E, Section 2.2.1.12 Access Roads appear to indicate that the Western Access Road would provide construction and operational access to laydown and staging areas. While project construction activities would be temporary and would terminate with the completion of construction of project facilities, project operational activities would be ongoing for the duration of any project license. Considering that the FLA states that the Western Access Road would provide operational access, please clarify whether laydown and staging areas used during construction would also be used during project operations. If the laydown and staging areas would be temporary, and only for use during project construction, please clarify whether these areas would be restored after project construction is complete. We recognize that in our previous request for additional information, issued on April 28, 2023, we requested corrections to Exhibit G Maps G5 and G6 to identify the location of lower reservoir laydown areas and upper reservoir laydown areas. However, if the laydown areas would be for temporary use during project construction, and not for potential continued use during project operations, the laydown areas would not need to be identiﬁed in Exhibit G. Response The laydown and staging areas included in the project footprint, but not the project boundary, will be temporary and only for use during project construc�on. These areas will be restored a�er project construc�on.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | May 25, 2023 Addi�onal Informa�on Request Responses | 1

FERC-A2-2

Exhibit A

Section 3.0 Project Access Roads mentions that a temporary explosives storage facility would be located along an existing unpaved access track, to the east of the main access tunnel portal. However, no details about the temporary explosives storage facility, including the physical composition, dimensions, and general configuration of the facility are provided. In your response, please provide as many details as possible about the temporary explosives storage facility, including the materials used to construct it, dimensions, and if the facility would be above or below ground. We recognize that in our previous request for additional information, issued on April 28, 2023, we requested corrections to Exhibit G Maps G5 and G6 to identify the location of the proposed temporary explosives storage area and the existing roads proposed to be utilized to access the storage area. However, if the explosives storage area and the existing roads would only be for temporary use during project construction, and not for potential continued use during project operations, the explosives storage area and the existing roads would not need to be identified in Exhibit G. Response The project will use and store explosives as part of its construc�on ac�vity. The primary use for these explosives will be underground during construc�on of the powerhouse and suppor�ng tunnels. The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) has jurisdic�on over commercial explosives. An ATF permit is required to ship, transport, or receive commercial explosives. Addi�onally, the ATF protects the public from unsafe or unsecure storage of explosive materials and regularly inspects the explosives storage magazines and records of licensees and permitees to ensure compliance with federal regula�ons. The facility used to store explosives during construc�on will be specified by the contractor prior to construc�on. The explosives storage facility will comprise a licensed explosives storage magazine(s) compliant with ATF Federal explosives regula�ons at 27 CFR, Part 555, Subpart K. A typical image of a magazine is provided below (See Figure A2-2-1). The applicant, with its building contractor, will determine at a later stage in the project the exact dimensions, configura�on and number of explosives storge magazine(s) that will be required. In addi�on to the magazine security required by federal regula�ons the area will be graded and secured by fencing and gated access during construc�on.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | May 25, 2023 Addi�onal Informa�on Request Responses | 2

Figure A2-2-1: Typical Explosive Storage Magazine

White Pine Waterpower, LLC | FERC Project No. 14851-003 | May 25, 2023 Addi�onal Informa�on Request Responses | 3

White Pine Waterpower, LLC FERC Project No. 14851-003 July 13, 2023 Additional Information Request Responses FERC-A3-1

Deficiency No. 3.

In your response, you include one certified mail receipt addressed to McConnell Law, Attn: Katie Howe McConnell. However, this recipient is not listed as a landowner, or identified as a representative of a landowner, in the license application Exhibit G, section 2.0 Landowner Information. Please clarify whether the recipient is a landowner or is a representative of a landowner, and if the recipient is a representative of a landowner, please identify that landowner.

Response The Uhalde family owns land within the project boundary and is identified as a landowner in the FLA. In an email dated January 26, 2022, an attorney representing the Uhalde family, Katie Howe McConnell, Esq., indicated to the applicant that any communication with the Uhalde family regarding the project must go through her office. A copy of this email is included in Attachment A3-1. At the time of the FLA filing in February 2023, the applicant understood that McConnell Law was representing the Uhalde family and provided notice of the FLA directly to Ms. McConnell as the representative of the Uhalde family. On April 12, 2023, Stephanie Sharp of the law firm Robison, Sharp, Sullivan and Brust, submitted a letter to FERC (Accession Number: 20230412-5088) indicating that she is currently representing the Uhalde Family. The Applicant provided a new notice to Ms. Sharp on May 5, 2023.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | July 13, 2023 Additional Information Request Responses | 1

FERC-A3-2.

Deficiency No. 6

In your response, you state that while the BLM Ely District Resource Management Plan (BLM Ely District RMP) is not included in the list of the 16 federal and state comprehensive plans identified in FERC’s List of Comprehensive Plans for Nevada, the BLM Ely District RMP has been identified as an applicable comprehensive plan to the project. Please file this plan for consideration with the Commission in accordance with 18 CFR section 2.19 of the Commission’s regulations.

Response The applicant is including the BLM Ely District RMP as Attachment A3-2. The applicant is not including the appendices to the BLM Ely District RMP in this attachment due to file size; however these appendices are accessible through the Bureau of Land Management National NEPA Register (ePlanning), at https://eplanning.blm.gov/eplanning-ui/project/87546/510. The applicant filed the BLM Ely District RMP with FERC referencing Docket No. ZZ09-5 (Accession Number 202308045004), per FERC’s instructions. The applicant also requested the BLM file the Ely District RMP with the Commission.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | July 13, 2023 Additional Information Request Responses | 2

FERC-A3-3.

Deficiency No. 6

In your response, on page 12, you state that White Pine will collaborate with a technical working group on comprehensive mitigation plans that will be incorporated into the environmental review process for the BLM and inform the project-specific exception to the comprehensive plans to facilitate construction and operation of the project. The Commission notes that any plans required for review by BLM (a cooperating agency under FAST-41 and NEPA) that would be necessary for BLM to complete its environmental review process would also be required for review by the Commission to complete its environmental review obligations under NEPA.

Response The applicant acknowledges this comment. The applicant will continue to provide updates on the progress of the Technical Working Group (TWG) and share such plan(s) with FERC. The applicant anticipates these plan(s) will be complete by the end of the year.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | July 13, 2023 Additional Information Request Responses | 3

FERC-A3-4.

Deficiency No. 6

In your response, on page 12, you state that the proposed project is not subject to the Nevada Statewide Comprehensive Outdoor Recreation Plan (SCORP) because the principal proposed project features would be located entirely on land managed by BLM. However, no rationale is provided in your response to justify why the SCORP is not applicable to the land managed by BLM. Commission staff note that a letter by Nevada Governor Steve Sisolak included in the SCORP states that, “ ...the 2022-2026 SCORP is the first to have developed a baseline inventory of all local, state, and federal outdoor recreation assets throughout the state...”. Please clarify why White Pine believes the SCORP is not applicable to land managed by BLM and to the recreation resources within those lands. Additionally, you state that White Pine reviewed three plans that were suggested by stakeholders, the: White Pine County Public Lands Policy Plan (October 2018), Approval of Resolution 2020-051 Adopting White Pine County Water Resource Plan Element to the White Pine County Master Plan (2019), and White Pine County Open Space Plan (September 2005), and determined that the plans don’t meet the Commission’s definition of “comprehensive plan” per the Commission’s regulations. Further, you state that White Pine determined county plans don’t have jurisdiction over lands managed by BLM, but that they can be utilized as an advisory tool. Commission staff acknowledge that most proposed project facilities and features would be located on land managed by BLM. However, some project facilities and features would be located on privately-owned lands, subject to county plans and regulations. Therefore, please file the three county plans for consideration by the Commission.

Response The applicant included the three county plans as Attachments: A3-4-1, A3-4-2, A3-4-3. The applicant previously filed these plans with FERC as a part of the July 27, 2023 responses to the additional information request dated April 28, 2023 (Accession No. 20230727-5134, Attachments 98-1, 98-2, and 98-3). The applicant included the Nevada Statewide Comprehensive Outdoor Recreation Plans (SCORP) as Attachment A3-4-4. The SCORP lists 38 recreation resources and facilities managed by BLM Ely District Office. Of those 38 recreation resources and facilities, none are within the project vicinity. Additionally, the SCORP lists two state managed recreation resources and facilities in White Pine County. Of those two recreation resources and facilities, none are within the project vicinity. There are zero recreation resources and facilities managed by White Pine County. Therefore, the project is not subject to the Nevada SCORP.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | July 13, 2023 Additional Information Request Responses | 4

FERC-A3-5.

Deficiency No. 10

In your response, you state that based on publicly available information there is sufficient existing infrastructure near the project, such as schools, public safety, utilities, hospitals, and housing that has the capacity to support the project. However, this appears contradictory, in part, to FLA Appendix I, Socioeconomic Report, Section 3.4 Public Services, which states that the project might put additional stress on the White Pine County’s health care system. Please provide any publicly available information that informs the determination that incremental government expenditures would not be needed to support public safety, such as the County’s health care system, to respond to the additional stress the project might cause to it.

Response The applicant reviewed publicly available data from the American Hospital Association which Statista1 compiled, see Attachment A3-5. The graph in Figure 5-1 below, shows the number of community hospital beds that serve an average population of 1,000 in the United States. The United States average number of community hospital beds per 1,000 population from 2000 to 2019 is 2.53 beds. The lowest state average number of community hospital beds per 1,000 population from 2000 to 2019 is 1.72 beds. The applicant’s 2019 socioeconomic study (Appendix I of Exhibit E of the FLA) reported 9,580 residents in White Pine County. Based on the national averages above, White Pine County requires between 16.48 and 24.3 beds. The William Bee Ririe Hospital located in Ely, NV is a critical access hospital containing 25 beds serving the citizens of White Pine County (WPC). William Bee Ririe Hospital has sufficient beds to service the population of WPC and the additional temporary population from the project’s construction. Based on the reported United States average and lowest state average (2.53 per 1,000 population and 1.72 per 1,000 population respectively), Willian Bee Ririe Hospital has the capacity to support an additional temporary population of between 280 and 4,953 for critical access hospital care. As a result, the applicant anticipates that no additional public expenditures are required to expand capacity in response to the increase of shortterm, temporary workers. During construction, the project might put additional stress on the White Pine County’s health care system in the form of utilizing currently available services, however no additional public expenditures will be required as a result. Furthermore, the applicant will require the construction contractor to provide on-site medical staff and facilities for employees during construction. During operation, the expected number of permanent staff should not impact the current healthcare services or require incremental government expenditures. As noted in Appendix I of Exhibit E of the FLA, other public resources, such as schools, public safety services, and housing, currently have the capacity to support the project during operation.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | July 13, 2023 Additional Information Request Responses | 5

Figure 5-1: Community hospital beds per 1,000 population in the US (2000-2019)

Footnote 1: Community hospital beds per population U.S. 2000-2019 | Statista

White Pine Waterpower, LLC | FERC Project No. 14851-003 | July 13, 2023 Additional Information Request Responses | 6

FERC-A3-6.

Deficiency No. 10

In your response, you indicate that temporary recreation vehicle (RV) parks would be established to house construction workers during project construction. However, no details are provided about the proposed size and location of these RV parks. Please describe the RV parks, including the sizes and locations of each one and the public utilities each one would require. Additionally, the FLA, Appendix I, Socioeconomic Report, Social Impacts of Project Construction and Operation, states that White Pine County’s existing housing stock may not have the capacity to accommodate all nonresident workers migrating to the county during construction, and White Pine anticipates its construction contractor will construct worker camps if needed. However, the section and your response provide no details about the worker camps. Please clarify whether these would be different from the RV parks, and if so, provide details about the worker camps, including the sizes, locations, and the public utilities each one would require.

Response The applicant is amending the response to deficiency No. 10 to read as follows: “At the time of the analysis there were approximately 1,000 vacant housing units in White Pine County. The applicant believes this is sufficient to accommodate most of the non-resident workers during the construction phase of the project. However, the condition, size, pricing, and market availability of the housing needed at the start of each phase of construction are not known at this time. The applicant anticipates that non-resident workers will not typically bring family members to the area for the construction period. Many construction trades will not be required for the entire duration of construction; therefore, most non-resident workers are expected to reside in temporary housing units such as hotels, existing RV parks, or temporary RV parks established temporary worker housing for project construction. Within a daily commuting distance of 50 miles of the project, there are 10 RV parks/campgrounds. Based on publicly available information, there are 23 lodging establishments near the project. The applicant does not anticipate a significant amount of local government expenditure related to housing and associated public utility costs.” The applicant, along with its construction contractor, will develop plans for temporary worker housing to support construction activities at least 90 days prior to contractor mobilization. The applicant will develop, in consultation with White Pine County, the location, type, size, and specifications (e.g. zoning and permitting) of the temporary worker housing.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | July 13, 2023 Additional Information Request Responses | 7

FERC-A3-7.

Deficiency No. 12

In your response, modified Exhibit G maps appear to show proposed new project access roads (green, solid lines) providing access to and from various proposed project facilities, including the proposed transmission line. The maps are clear regarding the existing roads from which some of the proposed new project access roads would originate (e.g., Western Access Road from US Hwy 93, Map G9; unnamed project access road from Jakes Wash Road to proposed transmission line, in Township 18N, Range 61E, Section 31, Map G1). However, it is unclear from what roads many of the other proposed project access roads would originate (e.g., unnamed project access roads to proposed transmission line, in Township 18N, Range 61E, Section 30, Map G2; unnamed project access roads to proposed transmission line, in Township 18N, Range 61E, Section 25, Map G4) because no existing roads, or vehicular trails (4WD), appear to be shown from which the new project access roads would originate. Please revise Exhibit G to clearly show all existing roads and vehicular trails that would be used by the project to directly reach all proposed new project access roads; these are the access roads that Commission staff requested to be indicated by a bold, orange line.

Response The applicant has included additional and updated details of the existing roads and vehicular trails (4WD) that the applicant will use to access the project facilities. The applicant traced these roads and vehicular trails (4WD) back to the nearest paved road. The applicant revised Exhibit G maps, as seen in Attachment A3-7, to show the roads and vehicular trails (4WD) needed to provide access within the proposed Transmission Line right of way. The applicant identified these features, as requested, in color. In several locations, including Township 18N, Range 62E, Section 28, Map G5, the applicant extended the project boundary to cover additional roads and vehicular trails (4WD) that the applicant will require to access individual transmission pole sites. The total project boundary area increased by 0.25 acres into BLM Land. This increase in project boundary acreage does not materially change the data, conclusions, or potential impacts within the FLA.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | July 13, 2023 Additional Information Request Responses | 8

FERC-A3-8.

Visual and Aesthetics Report

In Exhibit E, Appendix H, Visual and Aesthetics Report, the report does not include details about, or analysis of the potential impacts of, the proposed location of the permanent spoil disposal area of approximately 1,005,000 cubic yards of spoil, and the additional areas adjacent to the proposed spoil disposal area that might be needed to store additional spoil material should the permanent spoil area requirements increase through the development of the design. Additionally, none of the KOP viewshed photo simulations include the proposed spoil disposal area, which as currently designed would be approximately 0.5 mile long (north to south) and approximately 0.1 mile at its widest, and located immediately to the west of the proposed lower reservoir and approximately 0.25 miles to the east of the NNR Mainline railroad track. Further, the FLA, including the Visual and Aesthetics Report, does not appear to provide any information on the height of the currently proposed spoil disposal area, nor does it provide details including potential dimensions or locations of the additional spoil disposal areas, known by WPW but not publicly identified, should the spoil area requirements increase. Please provide the following information: (1) details, including all proposed and potential dimensions and locations, of the currently proposed spoil disposal area and all potential additional spoil disposal areas known by WPW but not publicly identified; (2) KOP viewshed photo simulations that include the currently proposed spoil disposal area and all potential additional spoil disposal areas; and, (3) appropriate visual and aesthetics analysis of the currently proposed spoil disposal area and all potential additional spoil disposal areas for the Visual and Aesthetics Report.

Response Table A3-8 below summarizes the dimensions of all proposed and potential spoil disposal areas. The applicant produced a map identifying these locations, see Attachment A3-8-1. The applicant produced photo simulations and descriptions relating to the spoil disposal sites described above as a part of the Supplemental Key Observation Points and Photo Simulations to the Visual and Aesthetic Resources Study Report Dated July 19, 2023 (Accession Number 20230719-5141). Table A3-8: List of potential disposal sites ID

Site Name

Area (acres)

Length (ft)

Width (ft)

Maximum Height (ft)

Comment

Permanent Spoil Disposal Site (West of Lower Reservoir)

38.41

2700

620

As described in the Exhibit F, Supporting Design Report

Lower Reservoir Staging Area (South of Lower Reservoir)

5.50

570

420

Excess material will be used to create this laydown and the site will be contoured and revegetated once construction is complete.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | July 13, 2023 Additional Information Request Responses | 9

Site Name

Area (acres)

Length (ft)

Width (ft)

Maximum Height (ft)

Comment

Underground Laydown Area (South of Switchyard and MAT Portal)

4.34

570

330

Excess material from the portal and excavated material for the permanent laydown will be used to create this permanent laydown area.

North Upper Reservoir Laydown (North of Upper Reservoir)

5.35

950

250

This laydown will be developed from excess cut arising from the reservoir site. The laydown will be revegetated and evaluated for regrading.

South Upper Reservoir Laydown (South of Upper Reservoir)

5.26

600

380

This laydown will be developed from spoil and stripping from the reservoir site. The laydown will be revegetated and evaluated for regrading.

Upper Reservoir Access Road Material Handling Area (South of Access Road)

51.14

2130

1050

This area has been provided for material staging and excess cuttings from the upper reservoir access road. It will be contoured and revegetated to minimize visual impact once construction is complete.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | July 13, 2023 Additional Information Request Responses | 10

FERC-A3-9.

Air Quality and Greenhouse Gas Emissions

Section 1.2 Statutory and Regulatory Requirements states that White Pine (or contractors) will obtain permits necessary for emissions associated with construction, Section 3.3.2.2 Water Erosion and Windblown Dust states that windblown dust is caused by soil erosion during project construction and operation and hazards related to windblown dust include reduced air quality, respiration of dust, and transport during construction of the project, and Section 3.7.2.2 Common Wildlife Species states that unspecified measures will reduce fugitive dust emissions that could disturb nesting birds and affect habitat. However, the FLA does not include sections dedicated to providing details about air quality and GHG emissions related to the proposed project. Please revise the FLA to provide details about air quality and GHG emissions related to the proposed project, including but not limited to: (a) current air quality in the project area; (b) air quality impacts from construction; (c) air quality impacts from operations; (c) construction and personnel vehicle emissions impacts on air quality; and (e) proposed measures to minimize project effects to air quality. Sufficient detail should be included for staff to understand and evaluate the specific details of air quality, GHG emissions, potential project effects on air quality, and provisions of each proposed measure that would mitigate project effects to air quality. Commission staff note that construction activities would require land clearing for construction staging and materials storage, heavy equipment operation, and worker commuting and materials delivery via light and heavy-duty trucks. These activities and equipment operation would result in emissions of air pollutants, fugitive dust, and GHGs. Although we understand that the estimates for type, number, duration, and location of construction equipment are preliminary, equipment requirements and construction activities can be estimated based on similar construction projects and activities. Therefore, please provide estimates of the project’s levels of emissions of criteria pollutants and GHGs. You should include the anticipated emissions from project construction, operation, and maintenance, including potential emissions of methane or carbon dioxide from the upper reservoir during project operation.1 National Ambient Air Quality Standards Under section 176(c)(4) of the Clean Air act of 1970, the General Conformity rule requires federal agencies to work with state, tribal, and local governments in areas that do not meet National Ambient Air Quality Standards (NAAQS) to ensure that federal actions conform to any state or tribal plans to improve air quality. As the lead federal agency, we must perform a General Conformity applicability test and Determination (if applicable) for projects located in areas that do not currently meet NAAQS. These areas are referred to as “nonattainment” or “maintenance areas.” To meet our obligations under the General Conformity rule, we need more information on current air quality conditions and emissions (if applicable) from the proposed construction activities to perform the applicability test and Determination. Therefore, please explain whether any portion of the project is located within a designated “nonattainment” or “maintenance” area for any of the six common air pollutants for which NAAQS have been established under the Clean Air Act. If any portion of the project is located within a designated nonattainment or maintenance area, you must provide the project-related construction emissions for each of the six criteria pollutants for comparison with General Conformity applicability thresholds.3 The considered emissions must include construction White Pine Waterpower, LLC | FERC Project No. 14851-003 | July 13, 2023 Additional Information Request Responses | 11

equipment, vehicle emissions on paved and unpaved roads, fugitive dust, and commuter emissions. If the project is not located in a nonattainment or maintenance area, then you need not quantify construction emissions for the six criteria pollutants. Greenhouse Gases In addition to the emission of criteria air pollutants, project construction activities would emit GHGs. However, the license application does not quantify anticipated GHG emissions from construction vehicles. Therefore, please provide an estimate of the GHG emissions in tons from proposed construction activities. The considered emission sources must include construction equipment (e.g., loaders, excavators, trucks, generators), vehicle emissions on paved and unpaved roads (e.g., trucks for material delivery and disposal), and commuter emissions (e.g., cars and light-duty trucks). GHG emissions are typically calculated using vehicle fuel consumption rates, power ratings, utilization rates, and anticipated hours of operation of each vehicle type for the duration of construction. Emission Factors for GHG emissions for construction equipment and vehicles are typically based on EPA-certified emission standards, manufacturer data, EPA’s current AP-42 emission factors, or emissions studies for the equipment. All construction GHG emissions should be given as carbon dioxide (CO2), nitrous oxide (N2O), methane (CH4), and combined as CO2 equivalents (CO2e). The Global Warming Potential value used should be based on EPA’s Emissions Factors for GHG emissions. Although we understand that these estimates would be preliminary, equipment requirements and construction activities can be estimated based on similar construction projects and activities. To provide context on the level of GHGs emitted by the project, GHG emissions should be compared to current state and national GHG inventories. In addition, should you propose any long-term operation and maintenance activities at the project with the potential to emit substantial quantities of GHGs, you should describe those activities and provide the same analysis for those activities as described above for construction activities. Lastly, project operation would provide a clean renewable source of power and would not burn any fossil fuels to generate electricity. This displaces an equivalent amount of generation from the current mix of generating sources in Nevada that could include some natural gas and coal-fired generation. To assess the project’s effects on GHG emissions over the long term, please quantify how much the project’s average annual generation would displace GHGs produced by an equivalent amount of energy generated from other grid-connected generating sources in Nevada.

Response The applicant submitted a request to FERC for an extension to provide a response for this Additional Information Request. The applicant will file the comprehensive response to this item on or before September 8, 2023.

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White Pine Waterpower, LLC FERC Project No. 14851‐003 July 13, 2023 Additional Information Request Responses FERC‐A3‐9

Deficiency No. 12‐9: Air Quality and Greenhouse Gas Emissions.

The following resources are publicly available from the U.S. Environmental Protec on Agency: Greenhouse Gas Inventory Data Explorer – h ps://cfpub.epa.gov/ghgdata/inventoryexplorer/#iallsectors/allsectors/allgas/gas/all; Emissions factors for Greenhouse Gas Inventories – h ps://www.epa.gov/system/files/documents/2022‐04/ghg_emission_factors_hub.pdf; Inventory of U.S. Greenhouse Gas Emissions and Sinks – h ps://www.epa.gov/ghgemissions/inventory‐us‐greenhouse‐gas‐emissions‐and‐sinks

White Pine Waterpower, LLC | FERC Project No. 14851‐003 | July 13, 2023 Addi onal Informa on Request Responses | 1

to ensure that federal actions conform to any state or tribal plans to improve air quality. As the lead federal agency, we must perform a General Conformity applicability test and Determination (if applicable) for projects located in areas that do not currently meet NAAQS. These areas are referred to as “nonattainment” or “maintenance areas.” To meet our obligations under the General Conformity rule, we need more information on current air quality conditions and emissions (if applicable) from the proposed construction activities to perform the applicability test and Determination. Therefore, please explain whether any portion of the project is located within a designated “nonattainment” or “maintenance” area for any of the six common air pollutants for which NAAQS have been established under the Clean Air Act.2 If any portion of the project is located within a designated nonattainment or maintenance area, you must provide the project‐related construction emissions for each of the six criteria pollutants for comparison with General Conformity applicability thresholds.3 The considered emissions must include construction equipment, vehicle emissions on paved and unpaved roads, fugitive dust, and commuter emissions. If the project is not located in a nonattainment or maintenance area, then you need not quantify construction emissions for the six criteria pollutants. Greenhouse Gases In addition to the emission of criteria air pollutants, project construction activities would emit GHGs. However, the license application does not quantify anticipated GHG emissions from construction vehicles. Therefore, please provide an estimate of the GHG emissions in tons from proposed construction activities. The considered emission sources must include construction equipment (e.g., loaders, excavators, trucks, generators), vehicle emissions on paved and unpaved roads (e.g., trucks for material delivery and disposal), and commuter emissions (e.g., cars and light‐duty trucks). GHG emissions are typically calculated using vehicle fuel consumption rates, power ratings, utilization rates, and anticipated hours of operation of each vehicle type for the duration of construction. Emission Factors for GHG emissions for construction equipment and vehicles are typically based on EPA‐certified emission standards, manufacturer data, EPA’s current AP‐42 emission factors, or emissions studies for the equipment. All construction GHG emissions should be given as carbon dioxide (CO2), nitrous oxide (N2O), methane (CH4), and combined as CO2 equivalents (CO2e). The Global Warming Potential value used should be based on EPA’s Emissions Factors for GHG emissions.4 Although we understand that these estimates would be preliminary, equipment requirements and construction activities can be estimated based on similar construction projects and activities. To provide context on the level of GHGs emitted by the project, GHG emissions should be compared to current state and national GHG inventories.5

The six common air pollutants are defined as “criteria” air pollutants because EPA has determined that these pollutants can injure health, harm the environment, and cause property damage. The six criteria air pollutants include: (1) carbon monoxide, (2) sulfur dioxide, (3) ozone, (4) par culate ma er, (5) nitrogen dioxide, and (6) lead. EPA has developed guidelines for se ng permissible levels of these pollutants to protect human health and the environment. 3 General Conformity applicability thresholds for criteria pollutants are described at 40 CFR § 93.153(b)(1)‐(b)(2) (2015) (emissions thresholds in tons per year). 4 Available at h ps://www.epa.gov/sites/default/files/2021‐04/documents/emission‐factors_apr2021.pdf. 5 See EPA’s Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990‐2020. Available at h ps://www.epa.gov/ghgemissions/inventory‐us‐greenhouse‐gas‐emissions‐and‐sinks.

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In addition, should you propose any long‐term operation and maintenance activities at the project with the potential to emit substantial quantities of GHGs, you should describe those activities and provide the same analysis for those activities as described above for construction activities. Lastly, project operation would provide a clean renewable source of power and would not burn any fossil fuels to generate electricity. This displaces an equivalent amount of generation from the current mix of generating sources in Nevada that could include some natural gas and coal‐fired generation. To assess the project’s effects on GHG emissions over the long term, please quantify how much the project’s average annual generation would displace GHGs produced by an equivalent amount of energy generated from other grid‐connected generating sources in Nevada.6

Response The applicant performed an analysis of the potential impacts of the construction, operation, and maintenance of the proposed project on air quality and greenhouse gases (GHGs). The analysis discusses the current air quality in the project area as well as the climate change trends. Air quality and greenhouse gas emissions from project construc on and opera ons are es mated with the outlined methodology and the results are provided in the following analysis to demonstrate that the project’s emissions will not have a significant impact to the air quality in the project area. A discussion of the poten al benefits of the project due to displacement of GHG emissions is also included demonstra ng the pumped storage hydropower project would not result in significant impacts on global CO2e concentrations. The inten on and purpose of the project is to facilitate the use of renewable energy genera on on the grid and to allow the region to decarbonize it energy genera on away from fossil fuels.

Current Air Quality in Project Area This evalua on considers the poten al impacts of the construc on, opera on, and maintenance of the proposed project on air quality and greenhouse gases (GHGs). Emissions from project construc on include the opera on of construc on equipment (on‐road and oﬀ‐road) and fugi ve dust genera on. Opera on and maintenance (O&M) equipment (on‐road and oﬀ‐road) and fugi ve dust genera on also have poten al to emit air pollutants and GHGs. The air quality and GHG analysis area is White Pine County, Nevada, where the project is located. Because climate change is a global issue, na onal levels are also considered to provide context. The Clean Air Act (CAA) is the primary controlling federal legisla on governing air quality. Ambient air quality and the emission of air pollutants are regulated under both federal and state laws and regula ons. The project must abide by the U.S. Environmental Protec on Agency’s (EPA’s) Na onal Ambient Air Quality Standards (Na onal AAQS). In addi on, the project is subject to Nevada‐specific ambient air quality standards and state‐level rules and regula ons, as described below. In Nevada, the Nevada Division of Environmental Protec on (NDEP) Bureau of Air Pollu on Control and Air Quality Planning (BAPC) has primary responsibility under Nevada Revised Statutes 445B.100 through 445B.825 for managing air quality through state regula ons. The NDEP‐BAPC regulates par culate ma er emissions from construc on projects disturbing areas greater than 5 acres. Nevada Administra ve Code

Information on the current source of generating sources for electricity consumed in Nevada is available at U.S. Energy Information Administration’s State Profile for Nevada at: https://www.eia.gov/state/?sid=NV. White Pine Waterpower, LLC | FERC Project No. 14851‐003 | July 13, 2023 Addi onal Informa on Request Responses | 3

(NAC) Sec on 445B.22037 requires fugi ve dust from construc on projects to be controlled (regardless of the size or amount of acreage disturbed) and requires an ongoing program using best management prac ces to prevent par culate ma er from becoming airborne. NAC Sec on 445B.22097 contains the Nevada State Ambient Air Quality Standards (Nevada State AAQS). The CAA requires the EPA to set Na onal AAQS for air pollutants considered harmful to public health and the environment. The EPA has set Na onal AAQS for six criteria pollutants: carbon monoxide (CO), nitrogen dioxide (NO2), ozone (O3), lead (Pb), sulfur dioxide (SO2), and par culate ma er (PM). Primary standards are established to protect public health, and secondary standards are established to protect public welfare. These standards define the maximum level of air pollu on allowed in the ambient air. The CAA and subsequent amendments allow states to promulgate addi onal air quality standards that are the same or more stringent than the Na onal AAQS. Two addi onal pollutants of concern – nitrogen oxides (NOx) and vola le organic compounds (VOCs) – contribute to the forma on of O3 in the atmosphere, which is a regulated criteria pollutant with a Na onal AAQS. The applicable Na onal AAQS, which have been adopted and expanded on in the Nevada State AAQS for criteria pollutants, are provided in Table 1. Table 1. National and Nevada State Ambient Air Quality Standards Pollutant NO2 SO2

Averaging Period

Primary National AAQS

Secondary National AAQS

Nevada State AAQS

1‐hour

0.100 ppm*

N/A

0.100 ppm*

Annual

0.053 ppm

0.053 ppm†

1‐hour

0.075 ppm‡

N/A

75 ppb

3‐hour

N/A

0.50 ppm

0.5 ppm¶

24‐hour

N/A

0.14 ppm¶

Annual

N/A

0.03 ppm†

PM10

24‐hour

150 µg/m†, #

PM2.5

24‐hour

35 µg/m†, **

Annual

12 µg/m†, ††

15 µg/m†, ††

12 µg/m†, ††

1‐hour

35 ppm§

N/A

35 ppm§

8‐hour

9 ppm§

N/A

6 ppm¶, ‡‡

3‐month

0.15 µg/m†, ¶

8‐hour

0.070 ppm§§

H2S

1‐hour

N/A

0.08 ppm¶

Sources: EPA (2023a) Notes: N/A = not applicable; H2S = hydrogen sulfide; ppm = parts per million; µg/m = micrograms per cubic meter; PM10 = particulate matter of 10 microns or less; PM2.5 = particulate matter of 2.5 microns or less. On January 6, 2023, EPA proposed to revise the primary annual PM2.5 standard to within the range of 9.0 to 10.0 µg/m3 but has not been finalized. *The standard is based on the 3‐year average of the 98th percentile of the daily maximum 1‐hour average. †Annual mean value. ‡The standard is based on the 3‐year average of the 99th percentile of the daily maximum 1‐hour average. §Not to be exceeded more than once per calendar year. ¶Not to be exceeded. # Not to be exceeded more than once per calendar year on average over 3 years. **The standard is based on the 3‐year average of the 98th percentile of the 24‐hour average. ††The standard is based on the 3‐year average of the weighted annual mean. ‡‡The standard is 9 ppm for areas with an elevation less than 5,000 feet above mean sea level. §§The standard is based on the fourth highest daily maximum 8‐hour concentration averaged over 3 years.

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For each criteria pollutant, the EPA classifies areas as in “attainment” if the area complies with National AAQS or as “nonattainment” if one or more National AAQS is exceeded. Areas designated as nonattainment for a criteria pollutant are required to develop plans to bring those areas into attainment with the current National AAQS. EPA will redesignate a nonattainment area as a “maintenance” area once the standards and additional redesignation requirements have been met. White Pine County (Central Steptoe Valley) is currently designated as a maintenance area for one for the six criteria air pollutants, SO2, for the historical 1971 National AAQS (EPA 2023b). Thus, the General Conformity Rule, which is designed to protect ambient air quality within nonattainment and maintenance areas against further degradation, applies. The remaining five criteria pollutants within the air quality analysis area are classified as either in attainment or unclassified; thus, the General Conformity Rule would apply only for SO2. The General Conformity de minimis thresholds for SO2 pursuant to 40 Code of Federal Regulations (CFR) Section 93.153 (b)(1) is 100 tons per year (tpy) (EPA 2023c). Criteria pollutants are monitored throughout various parts of the country. Monitors measure concentrations of pollutant in the atmosphere and the results are often presented in parts per million (ppm) or micrograms per cubic meter (µg/m3). Pursuant to 40 CFR Section 58.14 (c)(1), the EPA and state monitoring agencies periodically analyze and review monitoring locations, discontinue monitoring at locations where pollutant concentrations have been well below the standards, and add monitors in areas where pollutant concentrations may be approaching air quality standards. Instantaneous, on‐demand, monitored outdoor air quality data collected from state, local, and tribal monitoring agencies can be obtained from EPA’s Air Data webpage and interactive tool (EPA 2023d). The EPA uses the criteria pollutant monitoring data to determine a “design value” for each pollutant and averaging time (Table 2). A design value is a statistic representing the monitored concentration of a given pollutant in each location, expressed in the manner of its standard, which can be compared to the National AAQS. Design values are updated annually and posted to the EPA’s Air Quality Design Value website (EPA 2023e). The 2022 design values (the most recently available) for White Pine County, Nevada, are provided in Table 2. Rural counties may not have existing monitors; therefore, no data are available, and it is assumed that pollutant concentrations meet ambient air quality standards. Other counties may have monitors that record only certain pollutants. Design values are typically used to designate and classify nonattainment areas, as well as to assess progress toward meeting the National AAQS. None of the design values listed in Table 2 exceed the National AAQS (EPA 2023e). Table 2. 2022 Design Values for White Pine County, Nevada Pollutant O3

White Pine County 2022 Design Values 0.066 ppm

Averaging Time

NAAQS

0.070 ppm

†

53 ppb

8‐hour

NO2

N/A

Annual

NO2

N/A

1‐hour*

100 ppb

PM2.5

N/A

Annual‡

60 µg/m3

PM2.5

N/A

24‐hour§

35 µg/m3

Source: EPA (2023e). Note: PM10 = particulate matter of 10 microns or less; PM2.5 = particulate matter of 2.5 microns or less; N/A= not available; ppb = parts per billion. White Pine County monitors do not report PM10, SO2, and CO. Many rural counties have no monitoring data and are assumed under the CAA to be in attainment. * Annual fourth highest daily maximum 8‐hour concentration, averaged over 3 years. † Not to be exceeded during the year. ‡ Annual mean, average over 3 years. § 98th percentile, averaged over 3 years.

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The EPA’s air quality index (AQI) is a metric used by the EPA to disclose the quality of ambient air to the public. The AQI index is one way to evaluate how clean or polluted an area’s air is and whether associated health effects might be a concern. The EPA calculates a daily AQI based on local air monitoring data. When the AQI value is between 0 and 50, air quality is categorized as “good” and criteria air pollutants pose little or no risk. Table 3 lists the White Pine AQI data from the most recent 3‐year period (2020–2022). The AQI data indicate that air quality in the analysis area is generally good to moderate with unhealthy air quality days occurring infrequently. Due to wildfire smoke from fires in other states, 2021 had a higher percentage of moderate and unhealthy air quality days than other years. Table 3. Annual Air Quality Index for White Pine County, Nevada Year

# Days with AQI

# Days Good

# Days Moderate

# Days Unhealthy

% Days Rated Good

% Days Rated Moderate

% Days Rated Unhealthy

2020

361

294

81.4

17.7

0.8

2021

361

278

77.0

22.4

0.6

2022

346

291

84.1

15.9

0.0

Source: EPA (2022a)

CAA regulations also control the release of hazardous air pollutants (HAPs): chemicals that are known or suspected to cause cancer or other serious health effects, such as reproductive effects, birth defects, or adverse environmental effects. EPA currently lists 188 HAPs, some of which, such as benzene, toluene, and formaldehyde, can be emitted from oil and gas development operations. National AAQS have not been set for HAPs; rather HAP emissions are regulated by source type‐ or industrial sector‐specific regulations. The AirToxScreen, published by the EPA, provides a screening tool for state, local, and tribal air agencies. AirToxScreen’s results help the EPA and other agencies identify which pollutants, emission sources, and places they may wish to study further to better understand any possible risks to public health from air toxics. AirToxScreen is the successor to the previous National Air Toxics Assessment. In December 2022, EPA released the results of its 2019 AirToxScreen assessment. AirToxScreen calculates concentration and risk estimates from a single year’s emissions data using meteorological data for that same year. The risk estimates assume a person breathes these emissions each year over a lifetime (or approximately 70 years). AirToxScreen then provides quantitative estimates of potential cancer risk and five classes of non‐ cancer hazards (grouped by organ/system: immunological, kidney, liver, neurological, and respiratory) associated with chronic inhalation exposure to real‐world toxics for each county and census tract (EPA 2023f). The 2019 AirToxScreen assessment includes emissions, ambient concentrations, and exposure estimates for about 181 of the 188 CAA air toxics, plus diesel PM. AirToxScreen cannot give precise exposures and risks for a specific individual; therefore, AirToxScreen data are best applied to larger areas. AirToxScreen derives concentration and risk estimates from emissions data from a single year and assumes a person breathes these emissions each year over a lifetime (approximately 70 years). Lastly, AirToxScreen only considers health impacts from breathing air toxics and does not take into account indoor hazards, contacting or ingesting these air toxics, or other ways in which people may be exposed (EPA 2023f). The 2019 AirToxScreen map application reveals that the total cancer risk (defined as the probability of contracting cancer over the course of a 70‐year lifetime, assuming continuous exposure) from human‐

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caused emissions of HAPs in White Pine County is 8.3 cases per 1 million people, which is lower than the nationwide level (25.5 cases per 1 million people) (EPA 2023f). GHGs include carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), and several fluorinated species of gas. CO2 is emitted primarily from the combustion of fossil fuels; CH4 is emitted from the production and transport of coal, natural gas, and oil; and N2O is emitted during agricultural and industrial activities. Fluorinated gases, which are synthetic, are emitted from a variety of industrial processes. CO2 and other GHGs are naturally occurring gases in the atmosphere; their status as a pollutant is not related to their toxicity but instead is due to the added long‐term impacts on climate because of their increased incremental levels in Earth’s atmosphere and their effect on the atmosphere’s ability to retain heat that would otherwise be emitted to space (EPA 2023g). The global warming potential (GWP) of gases was developed to allow comparison of global warming impacts between different gases. The GWP of a gas depends on how well the gas absorbs energy and how long the gas stays in the atmosphere. It is a measure of the total energy that a gas absorbs over a particular period (usually 100 years) compared to CO2, which has a GWP of 1. The larger the GWP, the more warming the gas causes. For example, CH4 has a 100‐year GWP estimated to be 29.8, meaning that CH4 would cause 29.8 times as much warming as an equivalent mass of CO2, over a 100‐year period (Intergovernmental Panel on Climate Change [IPCC] 2021). The GWP for N2O is estimated to be 273. The term carbon dioxide equivalent (CO2e) is used to describe different GHGs in a common unit. CO2e is calculated with CO2, CH4, and N2O multiplied by the high‐end 100‐year global warming potential values from the IPCC’s Sixth Assessment Report (IPCC 2021). Triennially, the EPA publishes a comprehensive summary of air emissions data known as the National Emissions Inventory (NEI). The most recently available NEI data are from 2020. These data are useful to assess impact intensity by comparing emissions associated with the project with the emission inventories of the state (Nevada) and the United States. Table 4 provides the 2020 emissions data for the six criteria air pollutants and HAPs for the United States, Nevada, and White Pine County, Nevada. Table 5 provides the 2020 GHG emissions data for the United States, Nevada, and White Pine County, Nevada (EPA 2023h). Table 4. National Emissions Inventory 2020 Criteria and Hazardous Air Pollutant Emissions Data for the United States, Nevada, and White Pine County, Nevada Pollutant

U.S. (tons)

Nevada (tons)

White Pine County, Nevada (tons)

NOx

8,814,608

80,106

1,965.00

66,065,689

412,095

13,831.00

VOC

46,140,059

267,402

23,219.00

PM10

16,761,114

117,964

4,237.00

PM2.5

5,815,036

29,738

1173

SO2

1,838,518

4,807

HAPs

5,964,882

57,126

4,933.58

Source: EPA (2023h) Notes: PM10 = particulate matter of 10 microns or less; PM2.5 = particulate matter of 2.5 microns or less.

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Table 5. National Emissions Inventory 2020 GHG Emissions Data for the United States, Nevada, and White Pine County, Nevada Pollutant

United States (mtpy)

Nevada (mtpy)

White Pine County, NV (mtpy)

CO2e

4,567,587,840

34,566,069

218,882

Carbon dioxide (CO2)

4,378,761,025

33,915,829

208,578

Methane (CH4)

5,304,516

19,211

337

Nitrous oxide (N2O)

108,357

285

N/A

Sulfur hexafluoride (SF6) Source: EPA (2023h); IPCC (2021) Note: Values are in metric tons per year (mtpy); N/A = not available.

Climate change is a global issue that results from several factors, including the release of GHGs, land use management practices, and the albedo effect (or reflectivity of various surfaces, including reflectivity of clouds). Specific to the project, GHGs are produced and emitted by various sources during construction and O&M. The primary sources of GHGs associated with the project are CO2, CH4, and N2O from fuel combustion in construction and O&M of vehicles and equipment. The National Oceanic and Atmospheric Administration releases state climate summaries that provide climate change trends for the state of Nevada (Runkle et al 2022). Nevada is largely a dry state with a highly diverse climate due its large range of elevations, from less than 500 feet in the scorching lowland desert in the south to more than 13,000 feet in the cool mountain forests in the north. Much of the state lies within the Great Basin, a region between the Rockies and the Sierra Nevada, encompassing numerous small mountain ranges and high‐elevation desert valleys. Nevada is on the east side of the Sierra Nevada, which blocks much of the moisture from the Pacific Ocean from reaching the state. Nevada is the Nation’s driest state, with statewide annual average (1895–2020) precipitation of only 10.2 inches. Regionally, annual average (1991–2020 normals) precipitation varies from 4 inches in some low elevation locations in the southwest to more than 50 inches on high mountain peaks of the Sierra Nevada. Temperatures in Nevada have risen almost 2.4 degrees Fahrenheit (°F) since the beginning of the 20th century. Over the last 26 years, the annual number of very hot days has been above average, with the highest 5‐year average occurring during the period from 2015 through 2020, partly because of very high annual values in 2017, 2018, and 2020. In addition to a general daytime warming, Nevada has experienced an above average number of warm nights since 2000. These climate change projections use the Representative Concentration Pathways (RCPs) modeling, with Shared Socioeconomic Pathways (SSPs) not yet incorporated. The higher emissions pathway (RCP8.5) assumes state emissions trajectories follow historical growth and assumes no climate policies are enacted to reduce emissions, while the lower emissions pathway (RCP2.6) assumes global GHG emissions are reduced substantially over time. IPCC looks at a range of emissions pathways because the largest source of uncertainty in future climate change projections is emissions projections. Since the RCP8.5 scenario was developed in 2007, there have been a combination of global commitments to the Paris Agreement and changes in the global energy landscape have made this scenario much more unlikely. Although, it is still useful, as it provides valid model projections of how the earth would respond to global carbon emissions reaching the levels implied by RCP8.5. However, from a policy standpoint, presenting RCP8.5 as a plausible business‐as‐usual scenario could be counterproductive to global climate efforts. For example,

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when considering the effort required to keep global warming below two degrees over the next few decades, the cost may seem “exorbitant” to policymakers if RCP8.5 is their basis of comparison. For Nevada: 

Under a higher emissions pathway (RCP8.5), historically unprecedented warming is projected to continue through this century. Even under a lower emissions pathway (RCP2.6), annual average temperatures are projected to exceed historical record levels most likely by the middle of this century. However, a large range of temperature increases is projected under both pathways, and under the lower pathway, a few projections are only slightly warmer than historical records.



Extreme high temperatures are projected to increase substantially, with potentially large impacts in the very hot southern deserts, particularly the Las Vegas metro area, where 70% of the state’s population resides. Extreme heat, combined with the urban heat island effect, would result in poor air quality and an increased risk of chronic respiratory conditions and heat stress.



Projected rising temperatures in Nevada would raise the snow line (the average lowest elevation at which snow falls). This would increase the likelihood that precipitation would fall as rain rather than snow, reducing water storage in the snowpack, particularly at those lower mountain elevations that are now on the margins of reliable snowpack accumulation. Higher spring temperatures would also result in earlier melting of the snowpack, further decreasing water availability during the already dry summer months.



Warmer temperatures are likely to decrease the amount of water in the mountain snowpack and increase the demand for water. Higher temperatures would also increase the evaporation rate, which would reduce streamflow and soil moisture. Thus, the intensity of future droughts is likely to increase, as would the risk of wildfires in some ecosystems. Increases in population and potentially decreased water flow from the Colorado River may lead to future water security issues across the state.

On a global scale, the GHG emission contribution of any single source on a subnational scale is dwarfed by the large number of comparable national and subnational contributors. The relative contribution of GHG emissions from construction and O&M of the project would vary, depending on contemporaneous changes in other sources of GHG emissions. A single subnational contributor is very unlikely to influence global cumulative emissions. The project alone is very unlikely to influence global cumulative emissions on a scale to make observable any increase or lessening of the social cost of all global emissions.

Analysis Methodology The following methodology was used to estimate air quality and GHG impacts from construction and O&M of the proposed project in the sections below. The air quality analysis area consists of White Pine County, Nevada, where the project will be constructed. Air pollutants tend to disperse into the atmosphere, becoming less concentrated as they travel away from a source of pollution, and therefore cannot be confined within defined boundaries, such as the boundary of the project. The GHG analysis area consists of the White Pine County, Nevada, and the state of Nevada where the project will be constructed. In addition, a discussion of GHGs displaced by the project is included in the analysis.

White Pine Waterpower, LLC | FERC Project No. 14851‐003 | July 13, 2023 Addi onal Informa on Request Responses | 9

The applicant subdivided emissions calculations for the project into construction‐related emissions (those emissions that are expected to be temporary in nature) and O&M‐related emissions (those emissions that are expected to occur throughout O&M of the project). Construction and O&M‐related emissions include the following: 

Exhaust from on‐ and off‐road construction and O&M vehicles and equipment



Exhaust from on‐road construction and O&M worker commuter vehicles



Exhaust from on‐road construction material and equipment delivery vehicles



Fugitive dust from vehicular travel on paved and unpaved roads



Fugitive dust from earthmoving and general construction activities

The applicant used the following assumptions to complete the air quality impact analysis for the project: 

78‐month construction timeline, 6‐day week, 12‐hour day, spanning March 2025 to September 2031. The bulk of civil and earthwork activities fall within the first 3 years of construction.



Emissions from off‐road construction equipment and vehicles; heavy‐duty, on‐road construction equipment; construction worker commuting; on‐road construction equipment; and equipment delivery were estimated using EPA’s Motor Vehicle Emission Simulator emission factors for 2022 (EPA 2022b).



An estimated number of 1,396,304 construction worker trips are assumed to commute from Ely, Nevada (approximately 11.5 miles away from midpoint of project).



Heavy‐hauling trucks would be used to deliver materials (clay, granular fill, processes aggregates, underflow sand borrow, whole tailings borrow, and ready mix) from Ely, Nevada (approximately 11.5 miles away from midpoint of project).



Equipment will be delivered from Ely, Nevada (approximately 11.5 miles away from midpoint of project).



Emission factor calculations from EPA’s compilation of air pollutant emission factors were used to estimate fugitive dust emissions from vehicle travel on paved roads (EPA 2011) and unpaved roads (EPA 2006).



Fugitive dust emissions from earthmoving were estimated using the Western Regional Air Partnership’s 2006 Fugitive Dust Handbook (Countess Environmental 2006).



Construction and operational emissions were estimated using published and agency‐accepted emission factors, such as AP‐42 emission factors when appropriate, to estimate GHG emissions (EPA 2023i).

Impact intensity is assessed by comparing emissions associated with the project with the emission inventories of the impacted county (White Pine County) and the General Conformity de minimis level for SO2.

White Pine Waterpower, LLC | FERC Project No. 14851‐003 | July 13, 2023 Addi onal Informa on Request Responses | 10

Impacts from Construction Air Quality Table 6 presents the estimated total criteria pollutant and HAP emissions that would occur from construction over the 78‐month construction period. Table 7 presents the estimated criteria pollutant and HAP emissions that would occur from construction in tpy. The impacts of project per year emissions would be low compared to the analysis area’s existing emissions, approximately 0.60% for particulate matter of 10 microns or less (PM10), and less than the 100 tpy General Conformity de minimis level for SO2 (See Table 7). Table 6. Estimated Total Project Construction Emissions in Tons Construction Emission Source

NOX

SOX

PM10

PM2.5

VOCs

HAPs

Construction equipment (off‐road)

13.53

52.94

0.05

2.04

1.98

2.36

1.18

Worker and on‐road construction equipment commuting

71.58

11.47

0.06

40.21

9.98

1.36

0.32

Equipment/Material delivery

1.19

1.71

<0.01

3.53

0.89

0.10

0.02

Fugitive dust from construction operation

–

120.70

12.07

–

86.30

66.12

0.12

166.48

24.92

3.82

1.52

Total construction emissions for the project Notes: PM2.5 = particulate matter of 2.5 microns or less.

Table 7. Estimated Annual Project Construction Emissions in Tons per Year Construction Emission Source

NOX

SOX

PM10

PM2.5

VOCs

HAPs

Construction equipment (off‐road)

2.08

8.14

0.01

0.31

0.30

0.36

0.18

Worker and on‐road construction equipment commuting

11.01

1.76

0.01

6.19

1.54

0.21

0.05

Equipment/Material delivery

0.18

0.26

<0.01

0.54

0.14

0.02

<0.01

Fugitive dust from construction operation

–

–‐

–

18.57

1.86

–

13.28

10.17

0.02

25.61

3.83

0.59

0.23

Total construction emissions of project

White Pine Waterpower, LLC | FERC Project No. 14851‐003 | July 13, 2023 Addi onal Informa on Request Responses | 11

Construction Emission Source

NOX

SOX

PM10

PM2.5

VOCs

HAPs

White Pine County emissions inventory (EI) total

13,831

1.965

4,237

1,173

23,219

4,934

Percentage of White Pine County EI total

0.10%

0.52%

0.02%

0.60%

0.33%

< 0.01%

De minimis threshold (tpy)

N/A

100

N/A

–

De minimis threshold exceeded?

N/A

Note: PM2.5 = particulate matter of 2.5 microns or less; N/A = not applicable.

Greenhouse Gas Emissions GHG emissions, primarily in the form of CO2, CH4, and N2O, would be generated by the project using on‐ road and off‐road vehicles during project construction and O&M. Non‐tree vegetation and soil disturbance could also result in an increase in GHG concentrations. Emissions because of soil disturbance would be short lived and return to background levels within several hours (IPCC 2006; Kessavalou et al. 1998). The small amount of carbon that would be stored in removed vegetation would be offset in time by the growth and accumulation of carbon in soils and new vegetation. Also, with other larger contributors of GHG totals, there would be no notable contribution from soil and vegetation disturbance compared to the overall project GHG estimates. For these reasons, the temporary increase in GHG concentrations because of soil and vegetation disturbance were not quantified. Direct GHG emissions resulting from the project were calculated using the methodology described above and assumptions described in Appendix A. The project could result in an estimated total of 4,440 metric tons of CO2e emissions during the peak construction year and 28,862 metric tons of CO2e emissions during the 78‐month construction period using vehicles and equipment during construction activities. GHG emissions associated with equipment operation and vehicle use were estimated using the information in Appendix A to account for all potential construction activities and associated material deliveries to and from the construction site. To provide context for these levels of emissions, the EPA mandatory reporting threshold for large emission sources of GHG is 25,000 metric tons of CO2e emitted annually (74 CFR 56260). Given that the level of CO2e emissions per year for the project is far below (18%) this annual reporting threshold during construction and O&M and there is potential for indirect CO2e benefits from the project, it is anticipated that the project would not result in significant impacts on global CO2e concentrations. The construction emissions for the 78‐month period exceed the annual reporting threshold; however, annual construction emissions are 18% of this threshold. To put the estimated GHG emissions in a relatable context, potential emissions can be compared with other common activities that generate GHG emissions and with emissions at the state and national levels. The EPA GHG equivalency calculator can be used (https://www.epa.gov/energy/greenhouse‐gas‐ equivalencies‐calculator) to express the potential average year GHG emissions on a scale relatable to everyday life (EPA 2023j). For instance, the 28,862 metric tons of CO2e emissions during the 78‐month construction period are equivalent to 6,423 gasoline‐fueled passenger vehicles driven for 1 year, or the White Pine Waterpower, LLC | FERC Project No. 14851‐003 | July 13, 2023 Addi onal Informa on Request Responses | 12

emissions that could be avoided by operating eight wind turbines as an alternative energy source or offset by the carbon sequestration of 34,418 acres of forest land. Given the low amount of GHG emissions and potential for indirect GHG benefits from the project, impacts on global GHG concentrations would be minor. GHG emissions associated with construction of the powerhouse and transmission line are summarized in Table 8 and Table 9. Appendix A provides the details of these calculations. Impact intensity is assessed by comparing GHG emissions associated with the project with the emission inventory of the impacted White Pine County from the 2020 NEI. Table 8 presents the total construction activity GHG emission for the 78 months and the emissions from the total construction of the project as a percentage of the county’s total emissions. Table 9 presents construction activity GHG emission per year and the emissions from the construction of the project as a percentage of the county’s total emissions. GHGs expressed as CO2e include CO2, CH4, and NO2 using the GWP discussed above. GHG emissions from construction of the project would be 4,440 metric tpy, which is less than 0.013% of the total 2020 annual emissions for Nevada. Table 8. Estimated Total Project Construction Greenhouse Gas Emissions Construction Emission Source

CH4

N2O

CO2

CO2e

Construction equipment (off‐road)

0.55

0.25

17,140

17,225

Worker and on‐road construction equipment commuting

0.25

0.04

10,518

10,537

Equipment/Material delivery

0.01

0.002

1,099

Fugitive dust from construction operation

‐

Total construction emissions for the project

0.81

0.30

28,757

28,862

Note: Values are in metric tons

Table 9. Estimated Annual Project Construction Greenhouse Gas Emissions Construction Emission Source

CH4

N2O

CO2

CO2e

Construction equipment (off‐road)

0.085

0.039

2,637

2,650

Worker and on‐road construction equipment commuting

0.038

0.007

1,618

1,621

Equipment/Material delivery

0.002

0.0003

169

Fugitive dust from construction operation

–

Total construction emissions for the project

0.12

0.05

4,424

4,440

Nevada emissions inventory (EI) CO2e total Project CO2e percentage of White Pine County EI CO2e total

34,566,069 0.013%

Note: Values are in metric tons

White Pine Waterpower, LLC | FERC Project No. 14851‐003 | July 13, 2023 Addi onal Informa on Request Responses | 13

Impacts from Operations Air Quality O&M activities would occur after completion of construction activities and throughout the life of the project. During O&M, criteria pollutant emissions would be generated from worker vehicles and off‐road maintenance equipment and are anticipated to be significantly less than construction emissions. The information provided in Table 10 estimates the maximum potential emissions per year from O&M activities. The impacts of project per year emissions would be low compared to the analysis area’s existing emissions, approximately 0.02% for NOx, and less than the General Conformity de minimis level for SO2 of 100 tpy. Table 10. Estimated Total Project Operational Emissions in Tons per Year Emission Source

NOX

SOX

PM10

PM2.5

VOC

HAPs

Operation equipment (off‐road)

0.06

0.48

<0.01

0.01

<0.01

Worker and on‐road construction equipment commuting

<0.01

Total project operational emissions

0.07

0.48

<0.01

0.01

De minimis threshold (tpy)

N/A

100

N/A

–

De minimis threshold exceeded?

N/A

White Pine County emissions inventory (EI) total

13,831

1,965

4,237

1,173

23,219

4,934

Percentage of White Pine County EI total

< 0.01%

0.02%

< 0.01%

Greenhouse Gas Emissions GHG emissions associated with O&M of the powerhouse and transmission line are summarized Table 11. Table 11 also presents O&M activity emissions and the emissions from the O&M of the project as a percentage of the county’s total emissions. Table 11. Project Operation and Maintenance Greenhouse Gas Emissions per Year Pollutant

O&M (tons) Annual

CO2

154

CH4

0.001

N2 O

0.0005

CO2e

154

Nevada NEI

34,566,069

Project CO2e percentage of NEI

0.00045

Note: Values are in metric tons

White Pine Waterpower, LLC | FERC Project No. 14851‐003 | July 13, 2023 Addi onal Informa on Request Responses | 14

GHG emissions emitted from project O&M would be 154 metric tons, which is less than 0.00045% of the respective statewide total 2020 annual emissions. Assumptions and complete GHG emission calculation methodology and data are provided in Appendix A.

Mitigation The project’s fugitive dust emissions would be minimized to comply with NAC Section 445B.22037, which requires fugitive dust from construction projects to be controlled (regardless of the size or amount of acreage disturbed) and requires an ongoing program, using best management practices, to prevent particulate matter from becoming airborne. The applicant will implement measures to minimize criteria pollutant and GHG emissions from fossil fuel combustion, including keeping all vehicles in good operating condition to minimize exhaust emissions, limiting the idling of equipment to the extent feasible to reduce exhaust emissions, turning off construction equipment during prolonged periods of non‐use, and no open burning of construction trash or other open fires. In Table 4.3‐1 of the Final License Application, the applicant proposes to implement an erosion and sediment control plan (ESCP) under protection, mitigation, and enhancement (PM&E) measure No. 1 to minimize erosion, emission, and fugitive dust impacts from both initial construction activities, as well as construction projects that may arise during the life of the project after initial construction. See Table 4.3‐1 for specific mitigation measures related to PM&E measure No. 1.

White Pine Waterpower, LLC | FERC Project No. 14851‐003 | July 13, 2023 Addi onal Informa on Request Responses | 15

Displacement of GHG Emissions Pumped storage hydropower is a commercially proven energy storage technology, with an increasing need in the western United States as new renewable energy sources are developed and older coal and nuclear‐powered baseload generation facilities are retired. Renewable energy sources often generate power during periods of low demand. The project will use this off‐peak or excess available energy to pump water from the lower reservoir to the upper reservoir and will be able to store up to 8,000 megawatt‐ hours (MWh) of electricity (in an 8‐hour operating cycle) during periods of low demand and return the stored energy to the grid during periods of peak demand. Equipment is tentatively proposed to consist of three 333‐MW, variable‐speed, reversible pump‐turbines totaling 1,000 megawatts (MW) of generating capacity, with the project having an overall energy storage capacity of 8,000 MWh. Total annual gross energy production is projected at approximately 2,400 gigawatt‐hours (GWh) (assuming operation for 8 hours per day, 6 days per week, 50 weeks per year). The rotational speed of variable‐speed pump‐turbines is continually adjusted so that the efficiency of pumping or generation is kept optimal as the flow rates and head change during a normal cycle. The net generation for the state of Nevada totaled 41,754,584 MWh in 2021, which resulted in 13,899,000 metric tons of CO2 emissions or 732 pounds CO2/MWh (EIA 2022). Pumped storage hydropower produced by the project is considered a renewable energy source and could potentially offset traditional fossil fuel‐ generated electric, lowering the statewide emissions once under commercial operation. Using the project’s total annual gross energy production (approximately 2,400 GWh) and the 2021 Nevada CO2 per MWh emission rate (732 pounds of CO2/MWh), the potential reduction of CO2 was quantified. The project could potentially offset 796,185 metric tons of CO2 per year based on the 2021 mix of gross energy production in Nevada. The project total construction CO2e emissions are estimated at 28,862 metric tons and the project’s total annual emissions due to O&M are estimated at 154 metric tons per year, totaling 29,016 metric tons, which is 0.04% of the CO2 emissions potentially offset by one year of project operations.

White Pine Waterpower, LLC | FERC Project No. 14851‐003 | Sept. 1, 2023 Addi onal Informa on Request Responses | 16

References Countess Environmental. 2006. WRAP Fugitive Dust Handbook. Available at: https://www.env.nm.gov /wp‐content/uploads/sites/2/2017/02/WRAP_FDHandbook_Rev_06.pdf. Accessed August 21, 2023. Intergovernmental Panel on Climate Change (IPCC). 2006. 2006 IPCC Guidelines for National Greenhouse Gas Inventories. Available at: https://www.ipcc.ch/report/2006‐ipcc‐guidelines‐for‐national‐ greenhouse‐gas‐inventories/. Accessed August 21, 2023. ———. 2021. AR6 Climate Change 2021: The Physical Basis. Available at: https://www.ipcc.ch/report/ar6/wg1/. Accessed August 21, 2023. Kessavalou A, Mosier AR, Doran JW (1998) Fluxes of carbon dioxide, nitrous oxide, and methane in grass sod and winter wheat‐fallow tillage management. Journal of Environmental Quality, 27, 1094– 1104. Runkle, J., K.E. Kunkel, S.M. Champion, D.R. Easterling, and S.A. McAfee, 2022: Nevada State Climate Summary 2022. National Oceanic and Atmospheric Administration Technical Report National Environmental Satellite, Data, and Information Service 150‐NV. Silver Spring, Maryland: National Oceanic and Atmospheric Administration/National Environmental Satellite, Data, and Information Service. U.S. Energy Information Administration (EIA). 2022. Nevada Electricity Profile 2021. Available at: https://www.eia.gov/electricity/state/nevada/index.php. Accessed August 21, 2023. U.S. Environmental Protection Agency (EPA). 2006. AP‐42, Fifth Edition, Volume 1, Chapter 13: Miscellaneous Sources. 13.2.2 Unpaved Roads. Available at: https://www.epa.gov/air‐ emissions‐factors‐and‐quantification/ap‐42‐fifth‐edition‐volume‐i‐chapter‐13‐miscellaneous‐0. Accessed August 21, 2023. ———. 2011. AP‐42, Fifth Edition, Volume 1, Chapter 13: Miscellaneous Sources. 13.2.1 Paved Roads. Available at: https://www.epa.gov/air‐emissions‐factors‐and‐quantification/ap‐42‐fifth‐edition‐ volume‐i‐chapter‐13‐miscellaneous‐0. Accessed August 21, 2023. ———.2022a. Air Quality Index Reports. Available at: https://www.epa.gov/outdoor‐air‐quality‐ data/air‐quality‐index‐report. Accessed August 21, 2023. ———. 2022b. Latest Version of Motor Vehicle Emission Simulator (MOVES). Available at: https://www.epa.gov/moves/latest‐version‐motor‐vehicle‐emission‐simulator‐moves. Accessed August 21, 2023. ———. 2023a. NAAQS Table. Available at: https://www.epa.gov/criteria‐air‐pollutants/naaqs‐table. Accessed August 21, 2023. ———. 2023b. Current Nonattainment Counties for All Criteria Pollutants. Available at: https://www3.epa.gov/airquality/greenbook/anayo_nv.html. Accessed August 21, 2023.

White Pine Waterpower, LLC | FERC Project No. 14851‐003 | Sept. 1, 2023 Addi onal Informa on Request Responses | 17

———. 2023c. General Conformity De Minimis Tables. Available at: https://www.epa.gov/general‐ conformity/de‐minimis‐tables. Accessed August 21, 2023. ———. 2023d. Air Data. Available at: https://epa.maps.arcgis.com/apps/webappviewer/ index.html?id=5f239fd3e72f424f98ef3d5def547eb5&extent=‐146.2334,13.1913,‐ 46.3896,56.5319. Accessed August 21, 2023. ———. 2023e. Air Quality Design Values. Available at: https://www.epa.gov/air‐trends/air‐quality‐ design‐values#report. Accessed August 21, 2023. ———. 2023f. 2019 AirToxScreen. Available at: https://www.epa.gov/AirToxScreen/2019‐airtoxscreen‐ assessment‐results. Accessed August 21, 2023. ———. 2023g. Overview of Greenhouse Gases. Available at: https://www.epa.gov/ghgemissions/overview‐greenhouse‐gases. Accessed August 21, 2023. ———. 2023h. 2020 National Emissions Inventory. Available at: https://www.epa.gov/air‐emissions‐ inventories/2020‐nei‐supporting‐data‐and‐summaries. Accessed August 21, 2023. ———. 2023i. AP‐42: Compilation of Air Emissions Factors. Available at: https://www.epa.gov/air‐ emissions‐factors‐and‐quantification/ap‐42‐compilation‐air‐emissions‐factors. Accessed August 21, 2023. ———. 2023j. GHG Equivalency Calculator. Available at: https://www.epa.gov/energy/greenhouse‐gas‐ equivalencies‐calculator. Accessed August 21, 2023.

White Pine Waterpower, LLC | FERC Project No. 14851‐003 | Sept. 1, 2023 Addi onal Informa on Request Responses | 18

APPENDIX A

Air Pollutant & GHG Emission Calculations

White Pine Pumped Storage Project Air Resources Emission Calculations Construction and Operational Emissions Summary Total Construction Emissions Summary

Emissions, tons

Construction Emission Source Construction Equipment (Off-Road) Worker and On-Road Construction Equipment Commuting Equipment/Material Delivery Fugitive Dust From Construction Operations Total:

NOX

SOX

PM10

PM2.5

VOC

HAPs

Emissions, mt 100-year CO2e

13.53 71.58 1.19 86.30

52.94 11.47 1.71 66.12

0.05 0.06 0.00 0.12

2.04 40.21 3.53 120.70 166.48

1.98 9.98 0.89 12.07 24.92

2.36 1.36 0.10 3.82

1.18 0.32 0.02 1.52

17,225 10,537 1,099 28,862

Annual Construction Emissions Summary

Emissions, tpy

Construction Emission Source CO

Emissions, mtpy

NOX

SOX

PM10

PM2.5

VOC

HAPs

100-year CO2e

Construction Equipment (Off-Road)

2.08

8.14

0.01

0.31

0.30

0.36

0.18

2,650

Worker and On-Road Construction Equipment Commuting

11.01

1.76

0.01

6.19

1.54

0.21

0.05

1,621

Equipment/Material Delivery Fugitive Dust From Construction Operations

0.18

0.26

0.00

0.54

0.14

0.02

0.00

169

13.28

10.17

0.02

18.57 25.61

1.86 3.83

0.59

0.23

4,440

Total:

Annual Operational Emissions Summary

Emissions, tpy

Operational Emission Source Maintenance/Inspection Activities Total:

Emissions, mtpy

NOX

SOX

PM10

PM2.5

VOC

HAPs

100-year CO2e

0.07 0.07

0.48 0.48

0.00 0.0005

0.01 0.01

154 154

White Pine Pumped Storage Project Air Resources Emission Calculations County Emission Inventory Comparison to Proposed Action Emissions Construction Emissions - Percent of County Inventory

Emissions, tpy

Emissions Source

Emissions, mtpy

NOX

SOX

PM10

PM2.5

VOC

HAPs

CO2e

Total Construction Emissions

86.30

66.12

0.12

166.48

24.92

3.82

1.52

28,861.60

White Pine County, NV Emissions Inventory (EI) Total

13,831

1,965

4,237

1,173

23,219

4,934

218,882

Percent of White Pine EI Total

0.62%

3.37%

0.14%

3.93%

2.12%

0.02%

0.03%

13.19%

Note: Emission inventory data from the National Emissions Inventory, 2020

Construction Emissions - Percent of County Inventory

Emissions, tpy

Emissions Source

Emissions, mtpy

NOX

SOX

PM10

PM2.5

VOC

HAPs

CO2e

Annualized Construction Emissions

13.28

10.17

0.02

25.61

3.83

0.59

0.23

4,440.25

White Pine County, NV Emissions Inventory (EI) Total

13,831

1,965

4,237

1,173

23,219

4,934

218,882

Percent of White Pine EI Total

0.10%

0.52%

0.02%

0.60%

0.33%

< 0.01%

2.03%

Note: Emission inventory data from the National Emissions Inventory, 2020

Operational Emissions - Percent of County Inventory

Emissions, tpy

Emissions Source

Emissions, mtpy

NOX

SOX

PM10

PM2.5

VOC

HAPs

CO2e

Operational Emissions

0.07

0.48

0.00

0.01

154

White Pine County, NV Emissions Inventory Total

13,831

1,965

4,237

1,173

23,219

4,934

218,882

Percent of White Pine County EI Total

< 0.01%

0.02%

< 0.01%

0.07%

Note: Emission inventory data from the National Emissions Inventory, 2020

White Pine Pumped Storage Project Air Resources Emission Calculations Construction Emissions: Equipment Emissions 1 2 EPA MOVES3 2022 National Average Emission Factors (g/hr) Equipment Off-Highway Trucks Off-Highway Tractors Dumpers/Tenders Cranes Graders Dumpers/Tenders Forklifts Crawler Tractor/Dozers Excavators Sweepers/Scrubbers Trenchers Aerial Lifts Bore/Drill Rigs

NOX

SOX

PM10

PM2.5

VOC

HAPS

CH4

CO2

N2O

77.90 185.71 24.76 24.00 19.78 24.76 6.76 42.86 17.13 9.53 29.34 32.76 63.11

710.21 750.54 28.58 97.46 57.08 28.58 60.15 142.19 58.49 42.75 96.14 41.55 233.01

0.67 0.66 0.02 0.15 0.18 0.02 0.08 0.23 0.15 0.06 0.07 0.02 0.13

14.60 26.35 3.79 4.30 4.10 3.79 1.04 7.17 3.35 1.71 4.17 4.59 11.62

14.16 25.56 3.67 4.17 3.97 3.67 1.01 6.96 3.25 1.66 4.05 4.45 11.27

18.46 30.08 5.78 5.37 3.40 5.78 1.27 6.49 2.91 1.78 4.71 7.18 16.03

9.90 15.23 2.62 2.72 1.71 2.62 0.66 3.33 1.49 0.95 2.44 3.28 7.37

1.59 2.07 1.48 2.60 0.29 1.48 7.33 0.53 0.26 65.82 2.18 2.19 5.97

247913.47 229531.47 4739.68 52939.16 64844.20 4739.68 31790.89 82746.34 54725.42 22923.84 25851.39 7115.48 40746.37

0.72 0.94 0.68 1.19 0.13 0.68 3.34 0.24 0.12 30.03 0.99 1.00 2.72

Global Warming Potentials CO2 CH4 N2O

100 year

20 year

1 29.8 273

1 82.5 273

Global warming potentials are based on IPCC AR6 Climate Change 2021: the Physical Science basis. Chapter 7. The Earth's Energy Budget, Climate Feedbacks and Climate Sensitivity. Available online at: https://www.ipcc.ch/report/ar6/wg1/ downloads/report/IPCC_AR6_WGI_Ch apter07.pdf Accessed 2/3/2023.

Note: Emission factors obtained from EPA's MOVES3 National Average Emission Factors for 2022.

Off-Road Mobile Source Emissions Emissions, tons

Equipment Construction Timeframe

ROW Clearing

Foundations Structure Installation Conductor Installation

Decommissioning

Reclamation

Equipment Type Bulldozer Excavator Grader Dump Truck Drilling Rig Front End Loader Excavator Flatbed Truck w/Crane Crane Pulling and Tensioning Trailers Telescopic Forklift Splice Lab Pulling and Tensioning Trailers Telescopic Forklift Crane Bulldozer Front End Loader Excavator Dump Truck

Total Mapped MOVES3 Hours per Days of Cumulative Quantity Equipment Category Day Use Hours of Use Crawler Tractor/Dozers 1 12 936 11,232 Excavators 1 12 936 11,232 Graders 1 12 936 11,232 Dumpers/Tenders 2 12 936 22,464 Bore/Drill Rigs 1 12 936 11,232 Forklifts 1 12 936 11,232 Excavators 1 12 936 11,232 Cranes 1 12 936 11,232 Cranes 1 12 936 11,232 Off-Highway Tractors 3 12 936 33,696 Forklifts 2 12 936 22,464 Off-Highway Tractors 1 12 936 11,232 Off-Highway Tractors 3 12 104 3,744 Forklifts 2 12 104 2,496 Cranes 1 12 104 1,248 Crawler Tractor/Dozers 1 12 52 624 Forklifts 1 12 52 624 Excavators 1 12 52 624 Dumpers/Tenders 2 12 52 1,248 Total:

Emissions, mt

NOX

SOX

PM10

PM2.5

VOC

HAPs

CH4

N2O

CO2

100-year CO2e

0.53 0.21 0.24 0.61 0.78 0.08 0.21 0.30 0.30 6.90 0.17 2.30 0.77 0.02 0.03 0.03 0.00 0.01 0.03 13.53

1.76 0.72 0.71 0.71 2.88 0.74 0.72 1.21 1.21 27.88 1.49 9.29 3.10 0.17 0.13 0.10 0.04 0.04 0.04 52.94

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.02 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.05

0.09 0.04 0.05 0.09 0.14 0.01 0.04 0.05 0.05 0.98 0.03 0.33 0.11 0.00 0.01 0.00 0.00 0.00 0.01 2.04

0.09 0.04 0.05 0.09 0.14 0.01 0.04 0.05 0.05 0.95 0.02 0.32 0.11 0.00 0.01 0.00 0.00 0.00 0.01 1.98

0.08 0.04 0.04 0.14 0.20 0.02 0.04 0.07 0.07 1.12 0.03 0.37 0.12 0.00 0.01 0.00 0.00 0.00 0.01 2.36

0.04 0.02 0.02 0.06 0.09 0.01 0.02 0.03 0.03 0.57 0.02 0.19 0.06 0.00 0.00 0.00 0.00 0.00 0.00 1.18

0.01 0.00 0.00 0.04 0.07 0.09 0.00 0.03 0.03 0.08 0.18 0.03 0.01 0.02 0.00 0.00 0.01 0.00 0.00 0.61

0.00 0.00 0.00 0.02 0.03 0.04 0.00 0.01 0.01 0.04 0.08 0.01 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.28

1,024.50 677.56 802.85 117.37 504.49 393.61 677.56 655.45 655.45 8,525.60 787.22 2,841.87 947.29 87.47 72.83 56.92 21.87 37.64 6.52 18,894.04

930.32 615.12 728.83 111.60 468.01 369.79 615.12 599.12 599.12 7,745.06 739.57 2,581.69 860.56 82.17 66.57 51.68 20.54 34.17 6.20 17,225.27

Note: The equipment type is 'mapped' to the appropriate EPA MOVES3 equipment category in order to determine the emission factor for estimating emissions. Emissions of GHG include CH4, N2O, and CO2 emissions; they are not in addition to those emissions. Example Calculation: [ emission factor, g/hour ] * [1 lb. / 453.59 grams ] * [ total hours used per day, hours/day ] * [ total days of construction, days/project ] * [ 1 ton / 2,000 lb. ] = tons of pollutant for duration of project

White Pine Pumped Storage Project Air Resources Emission Calculations On-Road Vehicle Emissions: Construction Worker Commuting and Equipment/Material Delivery 0.907185 US ton to metric ton conversion Total Project On-Road Vehicle Miles

Construction Timeframe

Initial Mobilization

Reservoir Excavation and Construction

Powerhouse and Tunnel Excavation and Construction

Transmission Corridor Foundations

Transmission Corridor Structure Installation

Transmission Corridor Conductor Installation

Decommissioning

Vehicle Type

Worker Pickup 3/4-ton truck 3/4 or 1-ton truck Lowboy Fuel Truck Water Truck Maintenance Truck Worker Pickup 3/4-ton truck 3/4 or 1-ton truck Lowboy Concrete Truck Fuel Truck Water Truck Maintenance Truck Worker Pickup 3/4-ton truck 3/4 or 1-ton truck Lowboy Concrete Truck Fuel Truck Water Truck Maintenance Truck Worker Pickup 3/4-ton truck 1-ton truck Lowboy Concrete Truck Fuel Truck Water Truck Maintenance Truck Worker Pickup 3/4 or 1-ton truck 1-ton truck Bucket Trucks Fuel Truck Water Truck Maintenance Truck Worker Pickup 3/4 or 1-ton truck Lowboy Bucket Trucks Fuel Truck Water Truck Maintenance Truck Worker Pickup 3/4 or 1-ton truck Lowboy Bucket Trucks Fuel Truck

Class

Passenger Passenger Passenger Light Commercial Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Passenger Passenger Passenger Light Commercial Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Passenger Passenger Passenger Light Commercial Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Passenger Passenger Passenger Light Commercial Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Passenger Passenger Passenger Single Unit Short-haul Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Passenger Passenger Light Commercial Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Passenger Passenger Light Commercial Truck Single Unit Short-haul Truck Single Unit Short-haul Truck

Quantity

67 2 4 20 2 2 1 67 0 0 0 28 2 2 0 67 0 44 0 10 2 2 0 67 4 1 3 10 2 2 1 67 4 1 1 2 2 2 33 2 2 2 2 1 2 69 4 2 2 1

One-Way Trips Days Used per Vehicle per Day

936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 936 104 104 104 104 104

4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 2 4 6 2 4

Commuting/Fuel, Water, & Delivery Miles

Paved

Unpaved

Commuting Miles (OneWay Trip)

Total Miles per Day

12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12

3,082 92 184 920 92 92 46 3,082 0 0 0 1,288 92 92 0 3,082 0 2,024 0 460 92 92 0 3,082 184 46 138 460 92 92 46 3,082 184 46 46 92 92 92 1,518 92 92 92 92 46 92 1,587 184 138 46 46

Commuting Total Miles for Miles (OneProject Way Trip) 2,884,752 86,112 172,224 861,120 86,112 86,112 43,056 2,884,752 0 0 0 1,205,568 86,112 86,112 0 2,884,752 0 1,894,464 0 430,560 86,112 86,112 0 2,884,752 172,224 43,056 129,168 430,560 86,112 86,112 43,056 2,884,752 172,224 43,056 43,056 86,112 86,112 86,112 1,420,848 86,112 86,112 86,112 86,112 43,056 86,112 165,048 19,136 14,352 4,784 4,784

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 0 0

Total Miles per Day

Total Miles for Project

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 0 0

250,848

Number of one-way trips

250,848

Number of one-way trips

250,848

Number of one-way trips

250,848

Number of one-way trips

250,848

Number of one-way trips

123,552

Number of one-way trips

14,352

Number of one-way trips

Water Truck Maintenance Truck Worker Pickup 3/4 or 1-ton truck Lowboy Fuel Truck Water Truck Maintenance Truck

Reclamation

Single Unit Short-haul Truck Single Unit Short-haul Truck Passenger Passenger Light Commercial Truck Single Unit Short-haul Truck Single Unit Short-haul Truck Single Unit Short-haul Truck

1 1 40 4 2 1 1 1

104 104 52 52 52 52 52 52

6 2 2 4 6 4 6 2

12 12 12 12 12 12 12 12

69 23 920 184 138 46 69 23

7,176 2,392 47,840 9,568 7,176 2,392 3,588 1,196

0 0 0 0 0 0 0 0

4,160

1,396,304

Number of one-way trips

Total number of one-way trips

Notes: Workers were assumed to commute from Ely, NV, each in their own pickup. Estimated 0 miles on average unpaved road travel from paved road to center of project ROW. Estimated 11.5 miles paved road travel from Ely, NV to center of project using Google Maps. Construction vehicles were assumed to commute from Ely, NV.

EPA MOVES3 2022 National Average Emission Factors (g/mile) 2022

NOX

VOC

SOX

PM10

PM2.5

HAPS

CO2

CH4

N2O

Passenger (gasoline)

3.21787

0.23472

0.04145

0.00222

0.02348

0.00553

0.011449783

363.97136

0.01084

0.00184 0.00162

Light Commercial Truck (diesel)

1.33811

1.17709

0.16425

0.00181

0.08206

0.05344

0.02624022

531.86797

0.00949

Combination Long-haul Truck (diesel)

1.90952

3.91450

0.13212

0.00542

0.17178

0.09168

0.024233785

1613.94194

0.01656

0.00167

Single Unit Short-haul Truck (diesel)

0.89592

1.35782

0.07984

0.00301

0.10122

0.04402

0.013679659

895.30453

0.00985

0.00177

Single Unit Long-haul Truck (diesel)

0.82834

1.18819

0.06964

0.00282

0.08672

0.03774

0.011810593

841.10511

0.00827

0.00169

20-year

PM2.5

Global Warming Potentials

100-year

PM10 0.38 1.07 1.28 0.00 0.01 0.02

0.04 0.11 0.13 0.00 0.00 0.00

CO2 CH4 N2O

1 29.8 273

1 82.5 273

Vehicle Type

Total miles

NOX

VOC

SOX

PM10

PM2.5

HAPS

CO2

CH4

N2O

100-year CO2e, mtpy

Passenger Passenger Passenger Passenger Passenger Passenger Light Commercial Truck HHDT HHDT Single Unit Short-haul Truck HHDT HHDT Single Unit Short-haul Truck Concrete Truck Concrete Truck

16,057,496 16,057,496 0 2,698,176 2,698,176 0 1,097,928 1,097,928 0 1,404,104 1,404,104 0 2,066,688 2,066,688 0

56.96 9.57 1.62 1.39 2.04 -

4.15 0.70 1.42 2.10 3.09 -

0.73 0.12 0.20 0.12 0.18 -

0.04 0.01 0.00 0.00 0.01 -

0.42 8.11 0.00 0.07 1.36 0.00 0.10 5.81 0.00 0.16 7.43 0.00 0.23 16.53 0.00

0.10 1.99 0.00 0.02 0.33 0.00 0.06 1.43 0.00 0.07 1.82 0.00 0.10 4.06 0.00

0.20 0.03 0.03 0.02 0.03 -

6,442.42 1,082.53 643.70 1,385.72 2,039.62 -

0.19 0.03 0.01 0.02 0.02 -

0.03 0.01 0.00 0.00 0.00 -

5,857.73 984.29 584.75 1,258.19 1,851.92 -

71.58

11.47

1.36

0.06

40.21

9.98

0.32

11,594.00

0.27

0.05

10,536.89

Note: Emission factors obtained from EPA's MOVES3

Emission Factors for Fugitive Dust from Roads, lb/VMT Source Unpaved Roads Emission Factors for Passenger Vehicles Unpaved Roads Emission Factors for HHDT Vehicles Unpaved Roads Emission Factors for Concrete Trucks Paved Roads Emission Factors for Passenger Vehicles Paved Roads Emission Factors for HHDT Vehicles Paved Roads Emission Factors for Concrete Trucks

On-Road Vehicle Emissions - Total Tons Type Construction Worker Commute Fugitive Dust From Paved Roads Fugitive Dust From Unpaved Roads Construction Vehicles Fugitive Dust From Paved Roads Fugitive Dust From Unpaved Roads Construction Vehicles Fugitive Dust From Paved Roads Fugitive Dust From Unpaved Roads Construction Vehicles Fugitive Dust From Paved Roads Fugitive Dust From Unpaved Roads Concrete Truck Fugitive Dust From Paved Roads Fugitive Dust From Unpaved Roads Total: Example Calculations: { ( [ Unpaved Emission Factor, g/mile ] * [ Total unpaved vehicle miles traveled for duration of project, miles/project ]) + ( [ Paved Emission Factor, lb/mile ] * [ Paved vehicle miles traveled for duration of project, miles/project ])} * [ 1 ton/2,000 lb ] = Tons of pollutant for duration of project [ Emission Factor, lb/mile ] * [1 lb. / 453.59 grams ] * [ Total vehicle miles traveled for duration of project, miles/project ] * [ 1 ton/2,000 lb ] = Tons of pollutant for duration of project

Example Calculation: [ Emission Factor, lb/mile ] * [ Total vehicle miles traveled per day, miles/day ] = Pounds of pollutant per day

White Pine Pumped Storage Project Air Resources Emission Calculations Construction Emissions: Equipment Delivery Emission Factors for Heavy-Heavy Duty Trucks Fugitive Dust from Unpaved Roads 2 (lb/mile)

On-Road MOVES3 Emission Factors (g/mile) Vehicle Type

Delivery Trucks

NOX

SOX

PM10

PM2.5

VOC

0.82834

1.18819

0.00282

0.08672

0.03774

0.06964

HAPS

CO2

0.01181059 841.10511

CH4

N2 O

PM10

PM2.5

PM10

PM2.5

0.00827

0.00169

0.78

0.08

0.01

0.00

Emission factors obtained from EPA's MOVES3 National Average Emission Factors for 2022. Emission factors for delivery truck use emission factors for a diesel single unit long-haul truck. 2 Based on fugitive dust emission factors calculated for delivery trucks. Weight of delivery truck approximated to be 10 tons for fugitive dust emission factors.

Heavy Duty Truck Material Delivery Assumptions Parameter Delivery Trips per Day Project Duration in Days Total Truck Trips On-Road Material Delivery Miles, Round-Trip, per Load Total On-Road Material Delivery Miles Traveled per Day Total On-Road Material Delivery Miles Traveled Off-Road Material Delivery Miles, Round-Trip, per Load Total Off-Road Material Delivery Miles Traveled per Day Total Off-Road Material Delivery Miles Traveled Total On- and Off-Road Material Delivery Miles Traveled per Day Total On- and Off-Road Material Delivery Miles Traveled

Value 28 2028 56,784 23 644 1,306,032 0.0 0 0 644 1,306,032

Source / Notes Assumed approximately 28 trucks per day are expected to deliver materials & equipment on average 6.5 years = 78 months = 338 weeks= 2028 days Delivery Trips per Day x Project Duration in Days Assumed materials would come from Ely, NV (distance estimated using Google Maps) Delivery Trips per Day x On-Road Material Delivery Miles, Round-Trip, per Load Total Truck Trips x On-Road Material Delivery Miles, Round-Trip, per Load Estimated 4.5 miles from paved road to transmission line ROW on average, round trip Delivery Trips per Day x Off-Road Material Delivery Miles, Round-Trip, per Load Total Truck Trips x Off-Road Material Delivery Miles, Round-Trip, per Load Total On-Road Material Delivery Miles Traveled per Day + Total Off-Road Material Delivery Miles Traveled per Day Total On-Road Material Delivery Miles Traveled + Total Off-Road Material Delivery Miles Traveled

Project Emissions From Material Delivery Using Heavy-Heavy Duty Trucks Emissions, tons

Emissions, mt

Vehicle Type

On-Road Delivery Trucks Fugitive Dust From Paved Roads Fugitive Dust From Unpaved Roads Total Emissions from Material Delivery

NOX

SOX

PM10

PM2.5

VOC

HAPs

CO2

CH4

N2 O

CO2e

1.19 1.19

1.71 1.71

0.00 0.00

0.12 3.41 0.00 3.53

0.05 0.84 0.00 0.89

0.10 0.10

0.02 0.02

1,210.90 1,210.90

0.01 0.01

0.00 0.00

1,099.44 1,099.44

Example Calculation (for HHDT): [ Emission Factor, lb/mile ] * [ Total vehicle miles traveled for all loads, miles/project ] * [ 1 ton / 2000 lb ] = Tons of pollutant for duration of project. Emission Factor (g/mile) * [1 lb. / 453.59 grams ] = Emission Factor (lb/mile).

Fugitive Dust from Paved Roads 2 (lb/mile)

White Pine Pumped Storage Project Air Resources Emission Calculations Construction Emissions: Earthmoving Activities Fugitive Dust From Construction Operations: General Construction and Cut/Fill Source / Notes Parameter Value Total Acres Affected During Construction Total Months of Construction General Construction PM10 Emission Factor, ton/acre-month Assumed Control Efficiency, % Total Cubic Yard On-Site Cut/Fill (in 1,000 cubic yards) On-Site Cut-Fill PM10 Emission Factor, ton/1,000 cubic yards Project Duration in Days

335

Assumed 25% of the total disturbed project area (not including the access roads) is disturbed at one time

78 0.011 61% 148.601 0.059 2028

Total project timeline is March 2025- September 2031. WRAP Fugitive Dust Handbook, Table 3-2, "Level 2" WRAP Fugitive Dust Handbook, Table 3-7, for applying water at various intervals (3.2-hr watering interval) Access roads for the project would disturb 157.9 acres (6,878,124 ft 2 ) 6,878,124 ft 2 x 0.583 ft = 4,012,239 ft 3 = 148.6 1,000-yd 3 WRAP Fugitive Dust Handbook, Table 3-2, "Level 2" 6.5 years = 78 months = 338 weeks= 2028 days

Source: Based on WRAP Fugitive Dust Handbook, Table 3-2, "Recommended PM10 Emission Factors for Construction Operations," Level 2. http://www.wrapair.org/forums/dejf/fdh/content/final-handbook.pdf

Annual Fugitive Dust Emissions From Construction Operations, in Tons Source

NOX

SOX

PM10

PM2.5

VOC

HAPs

CH4

CO2

CO2e

General Construction On-Site Cut/Fill Total Fugitive Dust Emissions, tons

111.93 8.77 120.70

11.19 0.88 12.07

Note: PM2.5/PM10 ratio of 0.10 used from the WRAP Fugitive Dust Handbook, Section 3.3.1. On-site cut-fill emissions do not assume controls. Example Calculation, General Construction: [ Emission Factor, ton/acre-month] * [ # of acres affected ] * [# of months of construction/project ] * [1 - Control Efficiency] = Tons of pollutant for duration of project Example Calculation, On-Site Cut/Fill: [ Emission Factor, ton/1,000 cu yds] * [ total cu yds of material/1,000 ] = Tons of pollutant for duration of project

White Pine Pumped Storage Project Air Resources Emission Calculations Operational Emissions: Off-Road Vehicles Line Maintenance Emissions 1

EPA MOVES3 2022 National Average Emission Factors (g/hr) Equipment Off-Highway Trucks Off-Highway Tractors Dumpers/Tenders Cranes Graders Dumpers/Tenders Forklifts Crawler Tractor/Dozers Excavators Sweepers/Scrubbers Trenchers Aerial Lifts Bore/Drill Rigs

NOX

SOX

PM10

PM2.5

VOC

HAPS

CH4

CO2

N2 O

77.90 185.71

710.21 750.54

0.67 0.66

14.60 26.35

14.16 25.56

18.46 30.08

9.90 15.23

1.59 2.07

247,913.47 229,531.47

0.72 0.94

24.76 24.00 19.78 24.76 6.76 42.86 17.13 9.53 29.34 32.76 63.11

28.58 97.46 57.08 28.58 60.15 142.19 58.49 42.75 96.14 41.55 233.01

0.02 0.15 0.18 0.02 0.08 0.23 0.15 0.06 0.07 0.02 0.13

3.79 4.30 4.10 3.79 1.04 7.17 3.35 1.71 4.17 4.59 11.62

3.67 4.17 3.97 3.67 1.01 6.96 3.25 1.66 4.05 4.45 11.27

5.78 5.37 3.40 5.78 1.27 6.49 2.91 1.78 4.71 7.18 16.03

2.62 2.72 1.71 2.62 0.66 3.33 1.49 0.95 2.44 3.28 7.37

1.48 2.60 0.29 1.48 7.33 0.53 0.26 65.82 2.18 2.19 5.97

4,739.68 52,939.16 64,844.20 4,739.68 31,790.89 82,746.34 54,725.42 22,923.84 25,851.39 7,115.48 40,746.37

0.68 1.19 0.13 0.68 3.34 0.24 0.12 30.03 0.99 1.00 2.72

Global Warming Potentials

100 year

20 year

CO2 CH4 N2O

1 29.8 273

1 82.5 273

Note: Emission factors obtained from EPA's MOVES3 National Average Emission Factors for 2022.

Off-Road Mobile Source Emissions Operations Task

Maintenance Activities

Equipment Type

Mapped MOVES3 Equipment Category

Quantity

Crane Pickup Trucks Bulldozer Water Truck Boom Truck Material Truck Tractor Trailer

Cranes Off-Highway Trucks Crawler Tractor/Dozers Off-Highway Trucks Off-Highway Trucks Off-Highway Trucks Off-Highway Tractors

1 8 1 1 1 3 2

Emissions, mtpy

Emissions, tpy

Equipment Hours per Days of Use Day 8 8 8 8 8 8 8

5 5 5 5 5 5 5

Total Cumulative Hours of Use 40 320 40 40 40 120 80 Total:

NOX

SOX

PM10

PM2.5

VOC

HAPs

CH4

N2 O

CO2

100-year CO2e

1.06E-03 2.75E-02 1.89E-03 3.43E-03 3.43E-03 1.03E-02 1.64E-02 6.40E-02

0.00 0.25 0.01 0.03 0.03 0.09 0.07 0.48

6.61E-06 2.38E-04 1.02E-05 2.97E-05 2.97E-05 8.91E-05 5.80E-05 4.61E-04

1.89E-04 5.15E-03 3.16E-04 6.44E-04 6.44E-04 1.93E-03 2.32E-03 1.12E-02

1.84E-04 5.00E-03 3.07E-04 6.24E-04 6.24E-04 1.87E-03 2.25E-03 1.09E-02

2.37E-04 6.51E-03 2.86E-04 8.14E-04 8.14E-04 2.44E-03 2.65E-03 1.38E-02

1.20E-04 3.49E-03 1.47E-04 4.37E-04 4.37E-04 1.31E-03 1.34E-03 7.29E-03

1.15E-04 5.59E-04 2.33E-05 6.99E-05 6.99E-05 2.10E-04 1.83E-04 1.23E-03

5.23E-05 2.55E-04 1.06E-05 3.19E-05 3.19E-05 9.56E-05 8.33E-05 5.61E-04

2.33 87.45 3.65 10.93 10.93 32.79 20.24 168.33

2.13 79.41 3.31 9.93 9.93 29.78 18.39 152.88

Note: The equipment type is 'mapped' to the appropriate EPA MOVES3 equipment category in order to determine the emission factor for estimating emissions. Emissions of GHG include CH4, N2O, and CO2 emissions; they are not in addition to those emissions. Example Calculation: [ emission factor, g/hour ] * [1 lb. / 453.59 grams ] * [ total hours used per day, hours/day ] * [ total days of use per year, days/year ] * [ 1 ton / 2000 lb ] = Tons of pollutant per year

White Pine Pumped Storage Project Air Resources Emission Calculations On-Road Vehicle Emissions: Operational Maintenance On-Road Construction Vehicles On-Road Vehicle Miles Commuting/Material Delivery Miles Vehicle Type

Inspection Worker Pickup Maintenance Worker Pickup Construction Pickup Bucket Truck Material Truck

Class

Passenger Passenger Single Unit Short-haul Truck Single Unit Short-haul Truck Single Unit Long-haul Truck

Quantity

3 17 1 1 1

Days Used

4 5 5 5 5

Commuting/Material Delivery Miles

Paved

Unpaved

Commuting Miles (Round Trip)

Total Miles per Day

Total Miles per Year

Commuting Miles (Round Trip)

Total Miles per Day

Total Miles per Year

23 23 23 23 23

69 391 23 23 23

276 1,955 115 115 115

0 0 0 0 0

Notes: Workers were assumed to commute from Ely, NV, each in their own pickup. Estimated 11.5 miles paved road travel from Ely, NV to middle of project using Google Maps. Construction vehicles were assumed to commute from Ely, NV. Material deliveries were assumed to come from Ely, NV, approximately 11.5 miles away (estimated using Google Maps).

EPA MOVES3 2022 National Average Emission Factors (g/mile) 2022

NOX

VOC

SOX

PM10

PM2.5

HAPS

CO2

CH4

N2 O

Passenger (gasoline) Single Unit Short-haul Truck (diesel) Single Unit Long-haul Truck (diesel)

3.21787 0.89592 0.82834

0.23472 1.35782 1.18819

0.04145 0.07984 0.06964

0.00222 0.00301 0.00282

0.02348 0.10122 0.08672

0.00553 0.04402 0.03774

0.011449783 0.013679659 0.011810593

363.97136 895.30453 841.10511

0.01084 0.00985 0.00827

0.00184 0.00177 0.00169

Note: Emission factors obtained from EPA's MOVES3 National Average Emission Factors for 2022. Emissions for passenger vehicles based on passenger truck gasoline emission factors, emissions for the construction pickup trucks and bucket truck are based on single unit short-haul truck diesel emission factors, and material delivery truck emissions are based on single unit long-haul truck diesel emission factors.

Emission Factors for Fugitive Dust from Roads, lb/VMT Source Unpaved Roads Emission Factors for Passenger Vehicles Unpaved Roads Emission Factors for Delivery Truck Unpaved Roads Emission Factors for HHDT Vehicles Paved Roads Emission Factors for Passenger Vehicles Paved Roads Emission Factors for Delivery Truck Paved Roads Emission Factors for HHDT Vehicles

PM10 0.38 0.78 1.07 0.00 0.01 0.01

Global Warming Potentials CO2 CH4 N2O

PM2.5 0.04 0.08 0.11 0.00 0.00 0.00

100-year

20-year

1 29.8 273

1 82.5 273

Annual On-Road Vehicle Emissions (tons/year) Type Worker/Maintenance Commute Fugitive Dust From Paved Roads Fugitive Dust From Unpaved Roads Construction Vehicle Fugitive Dust From Paved Roads Fugitive Dust From Unpaved Roads Heavy-Heavy Duty Vehicles Fugitive Dust From Paved Roads Fugitive Dust From Unpaved Roads

Vehicle Type Passenger Passenger Passenger Single Unit Short-haul Truck HHDT HHDT Single Unit Long-haul Truck Delivery Truck Delivery Truck

Total miles 2,231 2,231 0 230 230 0 115 115 0 Total:

NOX

VOC

SOX

PM10

PM2.5

HAPS

CO2

CH4

N2 O

100-year CO2e, mtpy

0.01 3.39E-04 1.05E-04 0.01

5.77E-04 2.98E-04 1.51E-04 1.03E-03

1.02E-04 4.16E-05 8.83E-06 1.52E-04

5.45E-06 4.58E-07 3.57E-07 6.26E-06

5.78E-05 1.13E-03 0.00 2.08E-05 1.22E-03 0.00E+00 1.10E-05 3.00E-04 0.00E+00 0.00

1.36E-05 2.77E-04 0.00E+00 1.35E-05 2.99E-04 0.00E+00 4.78E-06 7.36E-05 0.00E+00 6.81E-04

2.82E-05 6.65E-06 1.50E-06 3.63E-05

0.90 1.35E-01 0.11 1.14

2.67E-05 2.41E-06 1.05E-06 3.01E-05

4.53E-06 4.11E-07 2.14E-07 5.16E-06

0.81 0.12 0.10 1.03

Example Calculations: { ( [ Unpaved Emission Factor, g/mile ] * [ Total unpaved vehicle miles traveled for duration of project, miles/project ]) + ( [ Paved Emission Factor, lb/mile ] * [ Paved vehicle miles traveled for duration of project, miles/project ])} * [ 1 ton/2,000 lb ] = Tons of pollutant for duration of project [ Emission Factor, lb/mile ] * [1 lb. / 453.59 grams ] * [ Total vehicle miles traveled for duration of project, miles/project ] * [ 1 ton/2,000 lb ] = Tons of pollutant for duration of project

White Pine Pumped Storage Project Air Resources Emission Calculations Operational Emissions: Inspection and Maintenance Emissions Emission Factors for On-Road Passenger Vehicles On-Road MOVES3 Emission Factors (g/mile)

Vehicle Type

Passenger Vehicles

Fugitive Dust from Unpaved Roads (lb/mile)

Fugitive Dust from Paved Roads (lb/mile)

NOX

SOX

PM10

PM2.5

VOC

HAPS

CO2

CH4

N2 O

PM10 1

PM2.5 1

PM10 1

PM2.5 1

3.21787

0.23472

0.00222

0.02348

0.00553

0.04145

0.01145

363.97136

0.01084

0.00184

0.38

0.04

0.00

Emission factors from EPA MOVES3 for a gasoline-fueled passenger vehicle. 1 Fugitive dust from paved and unpaved road emission factors estimated using AP-42 Section 13.2.1 & Section 13.2.2. Mean vehicle weight was conservatively estimated at 2 tons for passenger vehicles.

Inspection and Maintenance Activity Assumptions Parameter

Value

Number of Site Visits per Year Total On-Road Miles, Round-Trip Total On-Road Miles, Round-Trip, Per Year Length of Transmission Line (miles) Off-Road Distance Traveled Round-Trip Total Off-Road Miles Traveled per Year Total On- and Off-Road Vehicle Miles Traveled per Round-Trip Total On- and Off-Road Vehicle Miles Traveled per Year

4 23 92 25 0 0 23 92

Source / Notes Assumption Assumed truck travels from Ely, NV and Ely is 11.5 miles from the project area. Number of Site Visits per Year x Total On-Road Miles, Round-Trip Transmission line is 25 mile long Assumption Off-Road Distance Traveled Round-Trip x Number of Site Visits per Year = Total Off-Road Miles Traveled per Year Total On-Road Miles, Round-Trip + Off-Road Distance Traveled Round-Trip Total On-Road Miles, Round-Trip, Per Year + Total Off-Road Miles Traveled per Year

Annual Emissions From Inspection and Maintenance Activities using On-Road Passenger Vehicles Emissions, tpy Vehicle Type On-Road Passenger Vehicles Fugitive Dust from Paved Roads Fugitive Dust from Unpaved Roads Total Inspection and Maintenance Activity Emissions

NOX

SOX

PM10

PM2.5

VOC

HAPs

CO2

CH4

N2 O

0.00 0.00

0.00 0.00 0.00 0.00

0.00 0.00

0.04 0.04

0.00 0.00

Example Calculation: [ Emission Factor, lb/mile ] * [ Total vehicle miles traveled per year, miles/year ] * [ 1 ton / 2,000 lb ] = Tons of pollutant per year Note: GHG are based on the GWP of CO2 (1) and CH4 (25). HAPs are assumed to be equal to 10% of VOC emissions.

Emissions, mtpy 100-year CO2e 0.03 0.03

White Pine Waterpower, LLC FERC Project No. 14851-003 October 18, 2023 Additional Information Request Responses FERC-A4-1

Exhibit E

In your response, you indicate that after completion of applicable studies in 2021, design modifications were made in 2022 to the upper reservoir, upper reservoir access road, laydown areas, and transmission line. Therefore, you indicate that additional studies for cultural resources, botanical resources, aquatic resources, and noise modelling (for terrestrial resources) are needed to assess potential project effects on approximately 288 acres of additional land. You indicate that the timeframe to complete data collection, analysis, and prepare the applicable study reports is July 2024. Because the additional studies will collect information on environmental resources that would be potentially affected by the project, the results are needed to inform staff’s environmental analyses and scoping process for the project as required by the National Environmental Policy Act (NEPA). This information must be filed with the Commission before we can initiate scoping and prepare the NEPA document. Therefore, please provide this information by July 31, 2024.

Response: The applicant is nearing comple�on of supplemental cultural resources, botanical resources, aqua�c resources, and noise modelling studies rela�ng to the approximately 288 acres of addi�onal land. WPW an�cipates ﬁling the completed study reports with the FERC by the end of December 2023 to inform staﬀ’s environmental analysis and scoping process for the project as required by NEPA, and in support of the current schedule.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | Oct. 18, 2023 Addi�onal Informa�on Request Responses | 1

FERC-A4-2

Exhibit E

In your response, you indicate that hydrogeologic testing is subject to greater sage grouse seasonal restrictions and can only be conducted between September 15 and October 31, in any given year, unless a waiver is granted by the Nevada Department of Wildlife (NDOW). You also indicate that, in the absence of a waiver approving the testing activities outside of the restricted period (in this case, July 27 through September 15 and November 1 through December 31, 2023), the testing will be conducted in 2024. Please advise if NDOW granted a waiver to you for testing in 2023 and, if so, ﬁle the waiver to the project record. If testing will need to occur in 2024, please provide a date for completion of the testing and for ﬁling the results. Please provide this information within 30 days from the date of this letter

Response NDOW did not grant a waiver for hydrogeologic tes�ng in 2023 as any such waiver is con�ngent upon the Bureau of Land Management (BLM) issuance of a land use permit to conduct the hydrogeologic tes�ng. The applicant submited an SF-299 applica�on to BLM for a land use permit and BLM has requested addi�onal informa�on. As a result of geotechnical explora�on that has occurred in the vicinity of the proposed hydrogeologic test wells, and ac�ve monitoring of groundwater levels for the past 12 months in the same vicinity, the BLM has indicted that the performance of the hydrogeologic tes�ng is likely eligible for a categorical exclusion. The applicant is working with the BLM and an�cipates receiving the land use permit from the BLM in Q1 2024, at which �me the applicant will submit a waiver request to NDOW for greater sage grouse seasonal restric�ons. Once approved, the applicant will file with FERC BLM’s issued land use permit and any associated waiver that NDOW may grant for the performance of the hydrogeologic tes�ng. The hydrogeologic tes�ng program will include the drilling and construc�on of two hydrogeologic evalua�on test wells and three alluvial groundwater monitoring wells. These wells will provide data on local aquifer stra�graphy, groundwater eleva�on and water chemistry needed to support the design of the water supply wellfield as well as provide data on water quality. The applicant an�cipates the hydrogeologic tes�ng to begin in Fall 2024 and to be completed at the end of November 2024. The applicant will file with FERC the hydrogeologic test results once they are completed.

White Pine Waterpower, LLC | FERC Project No. 14851-003 | Oct. 18, 2023 Addi�onal Informa�on Request Responses | 2

Jessica Brooks From: Sent: To: Cc: Subject: Attachments:

Cyndi Bardman Monday, July 17, 2023 11:30 AM Gregory Copeland; Jessica Brooks Rhiannon Scanlon Fwd: White Pine Pumped Storage - Coastal Zone Management Consistency 230716_Coastal Zone Letter final REV1.pdf

Jessica, Please see attached for coordination file as well as CZM comment response. Cyndi Sent from my Verizon, Samsung Galaxy smartphone Get Outlook for Android From: Dave Simpson <dsimpson@ndep.nv.gov> Sent: Monday, July 17, 2023 10:58:09 AM To: Cyndi Bardman <cbardman@rplusenergies.com> Cc: Jason Kuchnicki <kuchnicki@ndep.nv.gov>; Danilo Dragoni <ddragoni@ndep.nv.gov> Subject: FW: White Pine Pumped Storage ‐ Coastal Zone Management Consistency Caution! This message was sent from outside your organization.

Allow sender | Block sender

Cyndi, the attached Coastal Zone letter asks Nevada to “provide a Coastal Zone Management Area Consistency Determination for this project.” As you provided in our phone conversation this is just an acknowledgement that Nevada does not have coastline or a Coastal Zone Management Area. I can attest that Nevada does not have a traditional coastline or coastal zone management area. This does not relieve you for securing any other pertinent approvals, permits, etc. for the proposed White Pine Pumped Storage project. Dave Dave Simpson Environmental Scientist, Supervisor Standards Branch, Bureau of Water Quality Planning Nevada Division of Environmental Protection Department of Conservation and Natural Resources 901 S. Stewart Street, Suite 4001 Carson City, NV 89701 dsimpson@ndep.nv.gov (O) 775‐687‐9548 | (F) 775‐687‐9561

From: Cyndi Bardman <cbardman@rplusenergies.com> Sent: Sunday, July 16, 2023 5:35 PM To: Dave Simpson <dsimpson@ndep.nv.gov> Cc: Gregory Copeland <gcopeland@rplusenergies.com>; Jessica Brooks <jbrooks@rplusenergies.com>; Rhiannon Scanlon <rscanlon@rplusenergies.com> Subject: White Pine Pumped Storage ‐ Coastal Zone Management Consistency

WARNING ‐ This email originated from outside the State of Nevada. Exercise caution when opening attachments or clicking links, especially from unknown senders.

Dave, Thank you so much for taking my call last week. I really appreciate you responding to the attached Coastal Zone Management Consistency Determination request (see letter attached). I hope our work together in the future is a fun and lighthearted as this request! Kindest regards, Cyndi Bardman | Senior Permitting Manager rPlus Hydro, LLLP | 484.357.5131

CONFIDENTIALITY NOTICE: This email and any files attached may contain confidential information and/or legally privileged communications or attorney work product. If you are not the intended recipient, or a person responsible for delivering it, you are notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please destroy the original transmission and its attachments without reading or saving them in any manner.

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£ ¤

FLOOD HAZARD ZONES 1% ANNUAL CHANCE FLOOD HAZARD (100 YEAR), A

1% ANNUAL CHANCE SHALLOW FLOOD HAZARD (100 YEAR), AH 1% ANNUAL CHANCE SHALLOW FLOOD HAZARD (100 YEAR), AO 0.2% ANNUAL CHANCE FLOOD HAZARD (500 YEAR), X AREA OF MINIMAL FLOOD HAZARD, X

I 1

Miles

FLOOD HAZARD

WHITE PINE WATERPOWER, LLC Figure 3.9-2

Page 1 of 1

NNR Train Schedule

Train Schedule Date Saturday, January 14, 2023 Saturday, January 14, 2023 Friday, February 3, 2023 Thursday, February 9, 2023 Friday, February 17, 2023 Saturday, March 11, 2023 Sunday, March 12, 2023 Friday, March 17, 2023 Saturday, March 18, 2023 Friday, March 24, 2023 Saturday, March 25, 2023 Saturday, April 1, 2023 Sunday, April 2, 2023 Saturday, April 8, 2023 Sunday, April 9, 2023 Saturday, April 15, 2023 Sunday, April 16, 2023 Saturday, April 22, 2023 Sunday, April 23, 2023 Saturday, April 29, 2023 Sunday, April 30, 2023 Saturday, May 6, 2023 Sunday, May 7, 2023 Saturday, May 13, 2023 Sunday, May 14, 2023 Thursday, May 18, 2023 Thursday, May 18, 2023 Friday, May 19, 2023 Friday, May 19, 2023 Saturday, May 20, 2023 Saturday, May 20, 2023 Saturday, May 20, 2023 Sunday, May 21, 2023 Thursday, May 25, 2023 Thursday, May 25, 2023 Friday, May 26, 2023 Friday, May 26, 2023 Saturday, May 27, 2023 Saturday, May 27, 2023 Saturday, May 27, 2023 Sunday, May 28, 2023 Sunday, May 28, 2023 Monday, May 29, 2023 Tuesday, May 30, 2023 Wednesday, May 31, 2023 Thursday, June 1, 2023 Thursday, June 1, 2023 Friday, June 2, 2023 Friday, June 2, 2023 Saturday, June 3, 2023 Saturday, June 3, 2023 Saturday, June 3, 2023 Sunday, June 4, 2023 Monday, June 5, 2023 Tuesday, June 6, 2023 Wednesday, June 7, 2023 Thursday, June 8, 2023 Thursday, June 8, 2023 Friday, June 9, 2023 Friday, June 9, 2023 Saturday, June 10, 2023 Saturday, June 10, 2023 Saturday, June 10, 2023 Sunday, June 11, 2023 Monday, June 12, 2023 Tuesday, June 13, 2023 Wednesday, June 14, 2023 Thursday, June 15, 2023 Thursday, June 15, 2023 Friday, June 16, 2023 Friday, June 16, 2023 Saturday, June 17, 2023 Saturday, June 17, 2023 Saturday, June 17, 2023 Sunday, June 18, 2023 Monday, June 19, 2023 Tuesday, June 20, 2023 Wednesday, June 21, 2023 Thursday, June 22, 2023 Thursday, June 22, 2023 Friday, June 23, 2023 Friday, June 23, 2023 Saturday, June 24, 2023 Saturday, June 24, 2023 Saturday, June 24, 2023 Sunday, June 25, 2023 Monday, June 26, 2023 Tuesday, June 27, 2023 Wednesday, June 28, 2023 Thursday, June 29, 2023 Thursday, June 29, 2023 Friday, June 30, 2023 Friday, June 30, 2023 Saturday, July 1, 2023 Saturday, July 1, 2023 Saturday, July 1, 2023 Sunday, July 2, 2023 Monday, July 3, 2023 Tuesday, July 4, 2023 Tuesday, July 4, 2023 Wednesday, July 5, 2023 Thursday, July 6, 2023 Thursday, July 6, 2023 Friday, July 7, 2023 Friday, July 7, 2023 Saturday, July 8, 2023 Saturday, July 8, 2023 Saturday, July 8, 2023 Sunday, July 9, 2023 Monday, July 10, 2023 Tuesday, July 11, 2023 Wednesday, July 12, 2023 Thursday, July 13, 2023 Thursday, July 13, 2023 Friday, July 14, 2023 Friday, July 14, 2023 Saturday, July 15, 2023 Saturday, July 15, 2023 Saturday, July 15, 2023

Time Train Ride 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Fire & Ice Fireworks Special 2023 1:00:00 PM Winter Steam Spectacular 3:00:00 PM Winter Photo Shoot 1:00:00 PM Winter Steam Spectacular 1:00:00 PM STEAM - Robinson Canyon 12:00:00 PM STEAM - Robinson Canyon 1:00:00 PM DIESEL - Valley Vista 1:00:00 PM DIESEL - Robinson Canyon 1:00:00 PM DIESEL - Valley Vista 1:00:00 PM DIESEL - Robinson Canyon 1:00:00 PM STEAM - Robinson Canyon 11:30:00 AM STEAM - Robinson Canyon 1:00:00 PM STEAM - Robinson Canyon 11:30:00 AM STEAM - Robinson Canyon 1:00:00 PM STEAM - Robinson Canyon 11:30:00 AM STEAM - Robinson Canyon 1:00:00 PM STEAM - Robinson Canyon 11:30:00 AM STEAM - Robinson Canyon 1:00:00 PM STEAM - Robinson Canyon 11:30:00 AM STEAM - Robinson Canyon 1:00:00 PM STEAM - Robinson Canyon 11:30:00 AM STEAM - Robinson Canyon 1:00:00 PM STEAM - Robinson Canyon 11:30:00 AM STEAM - Robinson Canyon 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Copper, Trains, and Ely 7:15:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Silver State Express 7:15:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 2:00:00 PM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Roaring 20's Limited 7:15:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Silver State Express 7:15:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Rockin' Rollin' Geology Train 7:15:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Copper, Trains, and Ely 7:15:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Rockin' Rollin' Geology Train 7:15:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 1:00:00 PM STEAM - Robinson Canyon 6:30:00 PM Fourth of July Train 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Roaring 20's Limited 7:15:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Copper, Trains, and Ely 7:15:00 PM Sunset Stars & Champagne

Hi-Line Route *HiLine Route? No No No Yes No No No Yes No Yes No No No No No No No No No No No No No No No No Yes No Yes No No Yes No No Yes No Yes No No Yes No No No Yes Yes No Yes No Yes No No Yes No No Yes Yes No Yes No Yes No No Yes No No Yes Yes No Yes No Yes No No Yes No No Yes Yes No Yes No Yes No No Yes No No Yes Yes No Yes No Yes No No Yes No No No No Yes Yes Yes No Yes No No Yes No No Yes Yes No Yes No Yes No No Yes

Source: Total Schedule: Star Train Schedule: Hi-Line Route Designation:

https://dr.nnry.com/pages/trainride.php https://dr.nnry.com/pages/StarTrain.php Most all of our trips head southwest, through two tunnels and up real mountain grades through Robinson Canyon up toward the Ruth Copper Mining District. Several trains each month, those specifically marked Valley Vista, run north, out the Steptoe Valley, on the hi-line toward McGill.

Sunday, July 16, 2023 Monday, July 17, 2023 Tuesday, July 18, 2023 Wednesday, July 19, 2023 Thursday, July 20, 2023 Thursday, July 20, 2023 Friday, July 21, 2023 Friday, July 21, 2023 Saturday, July 22, 2023 Saturday, July 22, 2023 Saturday, July 22, 2023 Sunday, July 23, 2023 Monday, July 24, 2023 Tuesday, July 25, 2023 Wednesday, July 26, 2023 Thursday, July 27, 2023 Thursday, July 27, 2023 Friday, July 28, 2023 Friday, July 28, 2023 Saturday, July 29, 2023 Saturday, July 29, 2023 Saturday, July 29, 2023 Sunday, July 30, 2023 Monday, July 31, 2023 Tuesday, August 1, 2023 Wednesday, August 2, 2023 Thursday, August 3, 2023 Thursday, August 3, 2023 Friday, August 4, 2023 Friday, August 4, 2023 Saturday, August 5, 2023 Saturday, August 5, 2023 Saturday, August 5, 2023 Sunday, August 6, 2023 Monday, August 7, 2023 Tuesday, August 8, 2023 Wednesday, August 9, 2023 Thursday, August 10, 2023 Thursday, August 10, 2023 Friday, August 11, 2023 Friday, August 11, 2023 Saturday, August 12, 2023 Saturday, August 12, 2023 Saturday, August 12, 2023 Sunday, August 13, 2023 Monday, August 14, 2023 Tuesday, August 15, 2023 Wednesday, August 16, 2023 Thursday, August 17, 2023 Thursday, August 17, 2023 Friday, August 18, 2023 Friday, August 18, 2023 Saturday, August 19, 2023 Saturday, August 19, 2023 Saturday, August 19, 2023 Sunday, August 20, 2023 Monday, August 21, 2023 Tuesday, August 22, 2023 Wednesday, August 23, 2023 Thursday, August 24, 2023 Thursday, August 24, 2023 Friday, August 25, 2023 Friday, August 25, 2023 Saturday, August 26, 2023 Saturday, August 26, 2023 Saturday, August 26, 2023 Sunday, August 27, 2023 Monday, August 28, 2023 Tuesday, August 29, 2023 Wednesday, August 30, 2023 Thursday, August 31, 2023 Thursday, August 31, 2023 Friday, September 1, 2023 Friday, September 1, 2023 Saturday, September 2, 2023 Saturday, September 2, 2023 Saturday, September 2, 2023 Sunday, September 3, 2023 Sunday, September 3, 2023 Monday, September 4, 2023 Tuesday, September 5, 2023 Wednesday, September 6, 2023 Thursday, September 7, 2023 Thursday, September 7, 2023 Friday, September 8, 2023 Friday, September 8, 2023 Saturday, September 9, 2023 Saturday, September 9, 2023 Saturday, September 9, 2023 Saturday, September 9, 2023 Sunday, September 10, 2023 Monday, September 11, 2023 Tuesday, September 12, 2023 Wednesday, September 13, 2023 Thursday, September 14, 2023 Thursday, September 14, 2023 Friday, September 15, 2023 Friday, September 15, 2023 Saturday, September 16, 2023 Saturday, September 16, 2023 Saturday, September 16, 2023 Sunday, September 17, 2023 Monday, September 18, 2023 Wednesday, September 20, 2023 Friday, September 22, 2023 Saturday, September 23, 2023 Saturday, September 23, 2023 Sunday, September 24, 2023 Monday, September 25, 2023 Wednesday, September 27, 2023 Friday, September 29, 2023 Saturday, September 30, 2023 Sunday, October 1, 2023 Monday, October 2, 2023 Wednesday, October 4, 2023 Friday, October 6, 2023 Saturday, October 7, 2023 Sunday, October 8, 2023 Monday, October 9, 2023 Wednesday, October 11, 2023 Friday, October 13, 2023 Friday, October 13, 2023 Monday, October 14, 2024

11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Silver State Express 7:15:00 PM Night Sky - Star Train 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Roaring 20's Limited 7:15:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Silver State Express 7:15:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Roaring 20's Limited 7:15:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Rockin' Rollin' Geology Train 6:45:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Copper, Trains, and Ely 6:45:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Rockin' Rollin' Geology Train 6:45:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 2:30:00 PM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 8:00:00 AM Race The Rails 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Roaring 20's Limited 6:45:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM DIESEL - Robinson Canyon 7:15:00 PM Sunset Stars & Champagne 4:30:00 PM STEAM - Robinson Canyon 7:15:00 PM Night Sky - Star Train 1:00:00 PM STEAM - Robinson Canyon 4:30:00 PM Silver State Express 6:45:00 PM Sunset Stars & Champagne 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM STEAM - Robinson Canyon 1:00:00 PM STEAM - Robinson Canyon 6:30:00 PM A Taste of Italy 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM STEAM - Robinson Canyon 1:00:00 PM STEAM - Robinson Canyon 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM STEAM - Robinson Canyon 1:00:00 PM Pumpkin Train 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM STEAM - Robinson Canyon 6:45:00 PM Sunset Stars & Champagne 7:30:00 AM Solar Eclipse Limited

No No Yes Yes No Yes No Yes No No Yes No No Yes Yes No Yes No Yes No No Yes No No Yes Yes No Yes No Yes No No Yes No No Yes Yes No Yes No Yes No No Yes No No Yes Yes No Yes No Yes No No Yes No No Yes Yes No Yes No Yes No No Yes No No Yes Yes No Yes No Yes No No Yes No No No Yes Yes No Yes No Yes No No No Yes No No Yes Yes No Yes No Yes No No Yes No No Yes No No No No No Yes No No No No Yes No No No No Yes No Yes No

Saturday, October 14, 2023 Saturday, October 14, 2023 Sunday, October 15, 2023 Monday, October 16, 2023 Wednesday, October 18, 2023 Friday, October 20, 2023 Friday, October 20, 2023 Saturday, October 21, 2023 Saturday, October 21, 2023 Sunday, October 22, 2023 Monday, October 23, 2023 Wednesday, October 25, 2023 Friday, October 27, 2023 Friday, October 27, 2023 Saturday, October 28, 2023 Saturday, October 28, 2023 Sunday, October 29, 2023 Monday, October 30, 2023 Saturday, November 4, 2023 Saturday, November 11, 2023 Saturday, November 11, 2023 Saturday, November 18, 2023 Saturday, November 18, 2023 Friday, November 24, 2023 Friday, November 24, 2023 Friday, November 24, 2023 Saturday, November 25, 2023 Saturday, November 25, 2023 Saturday, November 25, 2023 Friday, December 1, 2023 Saturday, December 2, 2023 Saturday, December 2, 2023 Saturday, December 2, 2023 Friday, December 8, 2023 Saturday, December 9, 2023 Saturday, December 9, 2023 Saturday, December 9, 2023 Sunday, December 10, 2023 Thursday, December 14, 2023 Friday, December 15, 2023 Friday, December 15, 2023 Saturday, December 16, 2023 Saturday, December 16, 2023 Saturday, December 16, 2023 Sunday, December 17, 2023 Sunday, December 17, 2023 Sunday, December 17, 2023 Monday, December 18, 2023 Thursday, December 21, 2023 Friday, December 22, 2023 Friday, December 22, 2023 Saturday, December 23, 2023 Saturday, December 23, 2023 Tuesday, December 26, 2023 Wednesday, December 27, 2023 Thursday, December 28, 2023

1:00:00 PM Pumpkin Train 1:00:00 PM STEAM - Robinson Canyon 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM STEAM - Robinson Canyon 7:00:00 PM Haunted Ghost Train 1:00:00 PM STEAM - Robinson Canyon 7:00:00 PM Haunted Ghost Train 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 9:30:00 AM DIESEL - Valley Vista 4:30:00 PM STEAM - Robinson Canyon 7:00:00 PM Haunted Ghost Train 1:00:00 PM STEAM - Robinson Canyon 7:00:00 PM Haunted Ghost Train 11:30:00 AM STEAM - Robinson Canyon 9:30:00 AM STEAM - Robinson Canyon 1:00:00 PM DIESEL - Robinson Canyon 9:30:00 AM Community Food Drive Train 1:00:00 PM Community Food Drive Train 4:30:00 PM Santa's Reindeer Flyer 7:00:00 PM Santa's Reindeer Flyer 1:00:00 PM Santa's Reindeer Flyer 4:30:00 PM Santa's Reindeer Flyer 7:00:00 PM Santa's Reindeer Flyer 1:00:00 PM Santa's Reindeer Flyer 4:30:00 PM Santa's Reindeer Flyer 7:00:00 PM Santa's Reindeer Flyer 6:30:00 PM Santa's Reindeer Flyer 1:00:00 PM Santa's Reindeer Flyer 4:30:00 PM Santa's Reindeer Flyer 7:00:00 PM Santa's Reindeer Flyer 6:30:00 PM Santa's Reindeer Flyer 1:00:00 PM Santa's Reindeer Flyer 4:30:00 PM Santa's Reindeer Flyer 7:00:00 PM Santa's Reindeer Flyer 1:00:00 PM Santa's Reindeer Flyer 6:30:00 PM Santa's Reindeer Flyer 4:30:00 PM Santa's Reindeer Flyer 7:00:00 PM Santa's Reindeer Flyer 1:00:00 PM Santa's Reindeer Flyer 4:30:00 PM Santa's Reindeer Flyer 7:00:00 PM Santa's Reindeer Flyer 1:00:00 PM Santa's Reindeer Flyer 4:30:00 PM Santa's Reindeer Flyer 7:00:00 PM Santa's Reindeer Flyer 6:30:00 PM Santa's Reindeer Flyer 6:30:00 PM Santa's Reindeer Flyer 4:30:00 PM Santa's Reindeer Flyer 7:00:00 PM Santa's Reindeer Flyer 1:00:00 PM Santa's Reindeer Flyer 4:30:00 PM Santa's Reindeer Flyer 4:30:00 PM Santa's Reindeer Flyer 4:30:00 PM Santa's Reindeer Flyer 4:30:00 PM Santa's Reindeer Flyer

No No No No Yes No No No No No No Yes No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No

Hi-Line Route?

Train STEAM - Robinson Canyon DIESEL - Robinson Canyon Sunset Stars & Champagne Copper, Trains, and Ely Silver State Express DIESEL - Valley Vista Roaring 20's Limited Rockin' Rollin' Geology Train Fourth of July Train Race The Rails A Taste of Italy Pumpkin Train Solar Eclipse Limited Haunted Ghost Train Community Food Drive Train Santa's Reindeer Flyer Fire & Ice Fireworks Special 2023 Night Sky - Star Train Winter Photo Shoot Winter Steam Spectacular HyRail Experience

HiLine Route No No Yes No No Yes No No No No No No No No No No No Yes Yes No No

Count 114 20 39 4 5 40 5 4 1 1 1 2 1 4 2 35 1 16 1 2 0

Hi-Line Route Summary Hi-Line Route Yes No TOTAL

Count 96 202 298

% 32% 68% 100%

D u c k C r e e k R a n g e

486

l l e

¬ «

V a

KOP 11

t o

£ ¤

S t

e p

KOP 12

KOP 13

159°

KOP 14

KOP 3

¬ « 486

360°

KOP 15

60°

200° 360°

240°

KOP 16 20°

McGill Spring

260°

£ ¤

KOP 17 120°

40°

KOP 18

60°

KOP 4 180°

KOP 20

Mainline

£ ¤

260°

KOP 5

Hi line

490

¬ «

100°

Service Layer Credits: USGS The National Map: National Boundaries D u c k Dataset, 3DEP Elevation Program, C r e e k Geographic Names Information System, R a n g e National Hydrography Dataset, National Land Cover Database, National

KOP 6

! 2021 SINGLE-VIEW KOP 2022 KOP PANORAMA PHOTO ! 2022 PANORAMA KOP 2022 SINGLE-VIEW KOP ! 2022 SINGLE-VIEW KOP RAILROADS ! PHOTOGRAPHS AVAILABLE Project Location

TRANSMISSION LINE AND SUBSTATION WELLFIELD

LOWER RESERVOIR STEPTOE ACCESS

UPPER RESERVOIR

UPPER RESERVOIR OPTIONAL ACCESS ROAD

KOP PHOTO DIRECTIONS WHITE PINE WATERPOWER, LLC

1 Miles Page 1 of 1

D u c k C r e e k R a n g e

486

l l e

¬ «

V a

KOP 11

t o

£ ¤

S t

e p

KOP 12

KOP 13

159°

KOP 14

KOP 3

¬ « 486

360°

KOP 15

KOP 16

60°

202.8° 360° 22.5°

240° 240°

£ ¤

KOP 17 142°

60°

40°

KOP 18

McGill Spring

KOP 4 180°

KOP 20

288.5°

£ ¤ Mainline

KOP 5

Hi line

490

¬ «

100°

KOP 6

! 2021 SINGLE-VIEW KOP 2022 KOP PANORAMA PHOTO ! 2022 PANORAMA KOP 2022 SINGLE-VIEW KOP ! 2022 SINGLE-VIEW KOP RAILROADS ! PHOTOGRAPHS AVAILABLE Project Location

TRANSMISSION LINE AND SUBSTATION WELLFIELD

LOWER RESERVOIR STEPTOE ACCESS

UPPER RESERVOIR

UPPER RESERVOIR OPTIONAL ACCESS ROAD

KOP PHOTO DIRECTIONS WHITE PINE WATERPOWER, LLC

1 Miles Page 1 of 1

W a t er C a n y o n R d

ALLEY

STEPTOE V

DUCK CREEK RAN

n Li

F-

6152 ft

6148 ft

8553 ft

6170 ft D uck

nal

Cr e

ek GILFORD MEADOWS

Lavon

nyo

n Rd

ALLEY STEPTOE V

r Ca

8678 ft

NGE

6213 ft

8950 ft

Wate

212th S t

2 1 2th S t N

DUCK CREEK RA

E 22 5 t h S t N

E 19 9t h St N

-4

5th S

Project location

9266 ft E 185th St N

N F - 4 61

E 22

rt Rd

Ely Airport-Yelland Field

M ING LA

J U NI

E 1 4 5 th S t N

Al pha S t

YARD

CULTURAL SURVEY

BONE

SURVEYED AREA (2022 AND BEFORE)

WHITE PINE WATERPOWER, LLC

NEW SURVEY NEW SURVEY - ADJACENT

NEVADA

0.5

1 Miles

FIGURE 29-1

W a t er C a n y o n R d

ALLEY

STEPTOE V

DUCK CREEK RAN

n Li

F-

6152 ft

6148 ft

8553 ft

6170 ft D uck

nal

Cr e

ek GILFORD MEADOWS

Lavon

nyo

n Rd

ALLEY STEPTOE V

r Ca

8678 ft

NGE

6213 ft

8950 ft

Wate

212th S t

2 1 2th S t N

DUCK CREEK RA

E 22 5 t h S t N

E 19 9t h St N

-4

5th S

Project location

9266 ft E 185th St N

N F - 4 61

E 22

rt Rd

Ely Airport-Yelland Field

M ING LA

J U NI

E 1 4 5 th S t N

Al pha S t

YARD

BIOLOGICAL SURVEY BONE

SURVEYED AREA (2022 AND BEFORE)

WHITE PINE WATERPOWER, LLC

NEW SURVEY NEW SURVEY - ADJACENT

NEVADA

0.5

1 Miles

FIGURE 29-2

Final Draft

Final License Application – Exhibit E White Pine Pumped Storage Project

Table 4.3-1. Revised Cost of Environmental Mitigation and Enhancement Measures Considered in Assessing the Environmental Effects of Continuing to Operate the WPW Project PM&E Number

Name of Plan/PM&E

Erosion and Sediment Control Plan (ESCP)

• •

A narrative description and a map (where applicable) showing the project work areas; Supervision, inspection and responsibilities of the Environmental Inspector responsible for implementing the ESCP; Environmental training details for all contractors that will be on-site during construction; Details on how to control sediment and other pollutants on the construction site by using control practices throughout the duration of the construction project and providing future stabilization of the site, including techniques for reservoir and underground facilities (piping and pumps), typical ROW requirements, and access roads; Standard erosion and sediment control Best Management Practices (BMP) (see below), including measures such as construction site disturbance minimization and boundary marking, sediment ponds, sediment trapping pads and booms, silt fences, straw waddles, and temporary matting; Sequencing, inspection, and maintenance procedures for BMPs will be included in the project-specific Temporary ESCPs as they are developed for future use in post-license issuance construction and maintenance projects; A site inspection form which tracks structure types, inspection details, treatment details, slope stability observations, seepage observations, surface soil erosion observations, details on proximity to water, photos, comparison to previous inspections, and risk assessments; Actions to address earthworks in soils that are highly erodible; and Post-construction activities, including monitoring for uplands and waterbodies.

As noted above, the following is a list of potential BMPs that will be included in the final ESCP, as recommended by the State of Nevada, to specify erosion control measures to help minimize potential adverse impacts: • • •

• • •

•

Stabilizing truck exit areas for washing the wheels of all trucks that enter paved roadways from the construction site and dirt roads leading from the construction site; Installing tracking pads at construction exits to prevent dirt from being tracked onto roadways; Applying water or dust reducing agents to all exposed surfaces on project lands, as needed, during dry weather, including, but not limited to soil piles, graded areas, unpaved parking areas, staging areas, and project access roads, or, in cases where project access roads would remain in place for an extended duration, covering the routes with gravel to avoid resuspension of dust; Covering and maintaining at least two feet of free board space on haul trucks transporting soil, sand, or other loose material at the project; Paving all project roadways, driveways, sidewalks, and parking lots as soon as possible and laying building pads as soon as possible after grading unless seeding or soil binders are used; Incorporating dust control measures (e.g., dust collectors and covers limiting pathways for dust) into the temporary concrete batch plant, if used at the construction site; and Establishing inspection and maintenance programs and signage to minimize idling time of construction equipment on project lands.

Entities/Consultation Plan Coordinating Entities: • WPW • BLM • NDEP • USACE • FERC Staff Consultation Plan: The applicant will prepare the ESCP after consultation with the Nevada Division of Environmental Protection (NDEP), U.S. Army Corps of Engineers (USACE) and the BLM. The applicant will include documentation of consultation within the ESCP, copies of comments and recommendations on the completed ESCP after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the ESCP. The applicant will allow a minimum of 30 days for all relevant state, federal, and local agencies to comment and make recommendations before filing the ESCP with FERC. If the applicant does not adopt a recommendation, the filing will include the applicant’s reasons, based on project-specific information.

Capital (2022$)

Annual Cost (2022$)

$200,000

$20,000

Note: The capital cost in this table reflects a professional estimate of the level of effort anticipated to develop an ESCP of this magnitude. No erosion measures/BMPs, or erosion inspections have been included.

Note: The annual cost in this table reflects an estimated level of effort to maintain and update the ESCP as necessary.

February 2023 (Revised July 2023) | 350

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures Because the proposed project will disturb greater than one acre of land through ground disturbing activities, coverage under the NDEP Bureau of Water Pollution Control (BWPC) Construction Stormwater General Permit requires the creation of a Stormwater Pollution Prevention Plan (SWPPP). The applicant will file a SWPPP for approval with the NDEP BWPC to prevent erosion, scouring, and general water quality degradation during project construction. The construction contractor will develop a SWPPP to include, at a minimum: •

•

• • 2

Storm Water Pollution Prevention Plan (SWPPP)

• •

• • • •

A narrative description of the project and site, major objectives of the SWPPP, certification of a qualified SWPPP developer, reporting requirements, permit deadlines associated with installation, maintenance, and removal of stormwater controls and stabilization measures, sequence and estimated dates of construction activities, potential construction site pollutant sources, and identification of non-stormwater discharges from support activities related to project construction such as equipment staging areas, material storage areas, and access roads; Relevant maps including locations of construction activities, where sediment or spoils will be stockpiled, locations of any crossings or surface waters, designated points on the site where vehicles will exit onto paved road, locations of construction support activities covered by the General Construction Permit, locations of temporary and permanent stormwater control measures identified in the SWPPP, stabilization control measure areas, areas protected by buffers, a site map with the boundary line of buffers, locations of on-site materials, waste, borrow areas or equipment storage areas, locations of all potential pollutant-generating activities, and any water quality impaired waters within a quarter-mile of the construction site; Stormwater discharge location(s) that include where stormwater and/or allowable non-stormwater discharges are discharged to a Water of the United States (WOTUS) or any discharges to municipal separate storm sewer systems (MS4s) from the construction site; A copy of the requirements incorporated by reference shall be included as an attachment to the SWPPP (BLM, NDOT, NDEP, NNR, as applicable); Discussion of other potential pollutions sources (e.g., vehicle fueling, equipment maintenance); Standard SWPPP BMPs (including those related to erosion prevention, sediment control, temporary and permanent stabilization measures, construction site dewatering, good housekeeping, bulk storage of petroleum products, concrete waste, employee training, maintenance schedule, and inspection schedule), including measures covered under the ESCP, non-stormwater and materials management, site specific construction operations, and post-construction stormwater management measures; BMP inspection, maintenance, and rain event protocols; Procedures for handling and disposing of all wastes generated at the site, including, but not limited to, clearing and demolition debris, sediment removed from the site, construction and domestic waste, hazardous or toxic waste, and sanitary waste; A list of responsible parties and operators who will be responsible for SWPPP activities, including identification of permittee(s), owner/operator, sub-contractors, stormwater team, and/or inspectors; A description of a construction site monitoring program (e.g., location of all stormwater controls on the site required by this permit and how they are to be maintained, including a map, safety information related to conducting monitoring, visual monitoring/inspections, water quality sampling and analysis, and quality assurance and quality control processes, reporting requirements and record retention); A training plan for each contractor and subcontractor on the project site during construction, including implementation of a training log (records of employee training and date training was received), and when and how to conduct inspections, record applicable findings, and take corrective actions; A description of any corrective action taken at the site, including events and dates when problems were discovered, and modification occurred; Areas where final stabilization has been accomplished and no further construction permit requirements apply; and A plan for post-construction stormwater management.

Entities/Consultation Plan Coordinating Entities: • WPW • BLM • NDEP • NDOT • NNR Foundation • FERC Staff Consultation Plan: The applicant will prepare the SWPPP after consultation with the NDEP, NDOT, NNR, and the BLM. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommendations before submitting the approved SWPPP with FERC.

Capital (2022$)

Annual Cost (2022$)

$50,000

$20,000

Note: The capital cost in this table reflects a professional estimate of the level of effort anticipated to develop a SWPPP of this magnitude. No stormwater control measures and BMPs, stormwater control measures/BMP installation, or stormwater inspections have been included.

Note: The annual cost in this table reflects an estimated level of effort to maintain and update the SWPPP as necessary.

February 2023 (Revised July 2023) | 351

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures Within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing activity, whichever comes first, the applicant will file for FERC approval a Hazardous Substances Spill Prevention and Cleanup Plan (HSSPCP) to address potential issues resulting from spills of hazardous substances or fuels during construction, operation, or maintenance of the project. The applicant will create a HSSPCP listing incompatible substances that should be separated from each other in storage by distance, or by partitions, dikes, berms, secondary containment or otherwise, to preclude accidental contact between them. The applicant will utilize the HSSPCP to describe in detail how all hazardous substances will be stored in containers, such as those approved by the NDOT. As part of the HSSPCP, the applicant will include a list of all Hazardous substances used in the project area(s) including substances which, when mixed, react violently, or evolve toxic vapors or gases, or which in combination become hazardous by reason of toxicity, oxidizing power, flammability, explosibility, or other properties, will be evaluated for compatibility before storing on the project. At a minimum, the applicant will include the following in the HSSPCP: • • • •

Hazard Substance Spill Prevention and Cleanup Plan (HSSPCP)

• • • • • •

• • • •

A plan and layout of hazardous substances storage including containers for the storage of hazardous substances that plainly label containers (e.g., “Used Oil”, “Pesticides”, etc.) that could be susceptible to spillage or leakage to encourage proper handling and facilitate rapid response as spills or leaks occur; A description of preventative measures such as barriers between material storage and traffic areas, secondary containment provisions, and procedures for material storage and handling; Procedures for expeditiously stopping, containing, and cleaning up spills, leaks, and other releases which identifies the personnel name or position of the employee(s) responsible for detection and response of spills or leaks; Procedures for notification of appropriate facility personnel, emergency response agencies, and regulatory agencies where a leak, spill, or other release containing a hazardous substance or oil in an amount equal to or in excess of a reportable quantity established under either 40 CFR Part 110, 40 CFR Part 117, or 40 CFR Part 302, occurs during a 24-hour period. Contact information shall be in locations that are readily accessible and available; Procedures for handling and disposing of all wastes generated at the site, including, but not limited to, clearing and demolition debris, sediment removed from the site, construction, and domestic waste, hazardous or toxic waste, and sanitary waste; Spill response and cleanup procedures including lists of the major facilities/locations that store hazardous substances and facilities that store materials to contain and clean up hazardous substances; Notification and Reporting Procedures which may also include BLM, NDOT, NNR, etc.; Monitoring Spill Cleanup including a monitoring plan created so that if a spill occurs the cleanup is documented and or recorded/reported based on FERC guidelines, SPCC/40 CFR Part 112 requirements, and SDS reportable quantities requirements; HSSPCP personnel and contact information A plan for training employees in implementation of the HSSPCP to include information on where to find Safety Data Sheets and how to use the information, as well as procedures for notification and reporting of spills of hazardous substances that comply with hazardous substance release reporting regulations (40 CFR 112 and 40 CFR 302), materials handling procedures and storage requirements, how to identify, notify, and cleanup procedures for areas in which spills may occur, site specific inventory, storage, and handling methods for hazardous materials, and procedures to help minimize accidental pollutant releases which could contaminate surface or groundwater or stormwater runoff; Specify materials handling procedures and storage requirements; Identify spill notification and cleanup procedures for areas in which spills may occur; Identify inventory, storage, and handling methods for hazardous materials; Develop employee training procedures to help minimize accidental pollutant releases which could contaminate surface or groundwater or stormwater runoff.

Entities/Consultation Plan Coordinating Entities: • WPW • BLM • NDEP • NDOT • FERC Staff Consultation Plan: The applicant will prepare the HSSPCP after consultation with NDEP, NDOT, BLM, and other relevant agencies, as applicable. The applicant will include documentation of consultation within the HSSPCP, copies of comments and recommendations on the completed HSSPCP after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the HSSPCP. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommendations before filing the HSSPCP with FERC. If the applicant does not adopt a recommendation, the filing will include the applicant’s reasons, based on project-specific information.

Capital (2022$)

Annual Cost (2022$)

$45,000

$20,000

Note: The capital cost in this table reflects a professional estimate of the level of effort anticipated to develop a HSSPCP. No hazardous substance control measures/BMPs, hazardous substance control measures/BMP installation, or hazardous substance inspections have been included.

Note: The annual cost in the table reflects an estimated level of effort to maintain and update the HSSPCP as necessary.

On May 25, 2023, FERC issued an additional information request that identified a data gap in Exhibit A, Section 3.0 Project Access Roads. FERC requested detailed information regarding the temporary explosives storage facility that would be located along an existing unpaved access track, to the east of the main access tunnel portal. This HSSPCP would cover information on the hazardous materials stored inside the temporary facility; however, this response is not intended to resolve details regarding the facility’s construction, dimensions, or spatial configuration.

February 2023 (Revised July 2023) | 352

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures

Entities/Consultation Plan

Within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing activity, whichever comes first, the applicant will file for FERC approval a Landowner Coordination Plan (LCP) to discuss and sequence the timing of the installation and placement of transmission line poles and other project construction activities in order to minimize adverse effects on area farming practices, where feasible. At a minimum, the applicant will include within the LCP:

Coordinating Entities: • WPW • Landowners with active grazing permits • FERC Staff

• • • •

Landowner Coordination Plan (LCP)

A map showing the location of transmission line poles and other relevant project features in relation to specific agricultural operations; A description of impacts on these operations; Addresses of properties with which the applicant coordinated; and Measures proposed to avoid or mitigate such impacts.

Consultation Plan: The applicant will prepare the LCP in consultation with all landowners with active grazing permits that would be crossed by the transmission line or affected by the construction of other project features. The applicant will include documentation of consultation within the LCP, copies of comments and recommendations on the completed LCP after it has been prepared and provided to the entities above, and specific descriptions of how the entities comments are accommodated by the LCP. The applicant will allow a minimum of 30 days for the entities to comment and to make recommendations before filing the plan with FERC. If the applicant does not adopt a recommendation, the filing will include the applicant’s reasons, based on project-specific information.

Capital (2022$)

Annual Cost (2022$)

Note: Costs of implementation of landowner coordination are considered under Exhibit D, Table 1.0-1. Summary of Estimated Cost of New Construction (2021$), and Table 1.2-1. Estimated Indirect Construction Costs (2021$).

Note: The LCP is not relevant postconstruction. During construction, costs are incorporated into Capital Costs, and no modifications are anticipated postconstruction.

February 2023 (Revised July 2023) | 353

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures Within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing activity, whichever comes first, the applicant will file for FERC approval a Traffic Management Plan (TMP) to minimize construction impacts on wildlife and local traffic. The applicant will utilize a plan that is standard for this type of project and will include or consider, at a minimum, the following elements: • •

Traffic Management Plan (TMP)

•

Identification of the following, related to project construction requirements: o The numbers, types, and weights of loads required over time for construction of the project; and o The numbers, types, weights, and widths of vehicles required to haul project equipment and materials. A traffic study to identify the following, related to existing conditions: o The condition and weight limits of existing roads, bridges, and other transportation infrastructure; o Existing road width, available turning radius, and line of sight conditions; o Existing rail and aviation infrastructure and potential conflicts or impacts; o Overhead utilities and vegetation; o Areas with poor drainage that may be prone to flooding; o Existing vehicular and truck traffic volume expressed as average daily traffic (ADT); o Roads and other transportation infrastructure near sensitive human or wildlife receptors; o Roads and other transportation infrastructure suitable for hauling project equipment and materials; o Identification of preferred and alternate route(s) for transportation of project equipment, materials, and workers; and o Identification of all necessary permits and authorizations, such as hauling permits for vehicles/loads that exceed certain widths or weights. Development of traffic management measures to minimize impacts related to traffic and transportation, including: o Any needed improvements or extensions of existing roads or infrastructure (e.g., additional traffic lights or turning lanes); o A narrative description of how work shifts would be scheduled to minimize traffic impacts; o Specific traffic safety measures and management protocols to be employed during project construction to mitigate impacts to wildlife, including speed limits to reduce wildlife-vehicle collisions and injuries, and methods of enforcement; o Procedures to notify the public of traffic changes; o Specific measures to minimize mud and dust generated by construction traffic; o Provisions to use existing access roads wherever possible (any temporary access roads built for project construction will be decommissioned and revegetated after use); o A description of construction traffic coordination to minimize interference with White Pine County roadway and maintenance and operations, including snow and dust control, as applicable; o Specific measures to control off-highway vehicle access to project lands and adjoining lands from project access roads, such as gating or blocking access roads; o Measures to minimize potential effects on traffic on public land, including BLM land; o A plan for coordination with appropriate entities to minimize any potential disturbance to school buses and other public traffic, including accessibility for public safety and emergency vehicles; o Specific measures to mitigate any damage caused by project-related traffic, such as filling potholes, repairing damaged guardrails, culverts, etc.; and o A plan for parking project-related vehicles.

Entities/Consultation Plan Coordinating Entities: • WPW • BLM • NDOT • White Pine County • City of Ely • NNR Foundation • FERC Staff Consultation Plan: The applicant will prepare the plan after consultation with BLM, NDOT, White Pine County, the City of Ely, and the Nevada Northern Railway Foundation (NNR). The TMP will include documentation of consultation, copies of comments and recommendations on the completed TMP after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the TMP. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommendations before filing the TMP with FERC. If the applicant does not adopt a recommendation, the filing will include the applicant’s reasons, based on project-specific information.

Capital (2022$)

Annual Cost (2022$)

$150,000

$5,000

Note: The capital cost in this table reflects a professional estimate of the level of effort anticipated to perform a traffic study, assess, and document existing conditions, identify suitable mitigation measures, and develop the TMP, including consultation/coordi nation with agencies.

Note: The annual cost in this table reflects an estimated level of effort to assess the effectiveness of the TMP and to maintain and update the TMP as necessary.

February 2023 (Revised July 2023) | 354

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures In January 2009, pursuant to the EPAct, the BLM designated 117 “west-wide” or “Section 368” energy corridors traversing more than 5,000 miles and adopted Interagency Operating Procedures (IOPs) to guide the use of the corridors. Since 2009, the BLM has conducted a review of the development and use of those corridors, and established a process to identify potential corridor revisions, deletions, and additions, in connection with a Settlement Agreement relating to a challenge of the BLM’s Section 368 corridor designation decision.

Transmission Line / Energy Corridor

In December 2021, the applicant submitted an application for a ROW grant and land use permit to the BLM for placement of the majority of the project’s proposed transmission line within the existing BLM Section 368(a) designated energy #110-114 corridor (Section 368 Energy Corridor). The proposed transmission line corridor would be primarily (70%) located within the designated Section 368 Energy Corridor, with the remainder routed through private property (8%) and BLM-managed land (22%) within the Legacy Locally Designated Corridor. By placing the transmission line within the energy corridor, which already contains a separate transmission line, impacts to the surrounding environmental resources may be reduced and future management and mitigation efforts consolidated with the existing infrastructure.

Entities/Consultation Plan Coordinating Entities: • WPW • BLM • FERC Staff Consultation Plan: The applicant intends to continue consultation with the BLM regarding the ROW application, and land use permitting process, and will keep FERC apprised of any developments.

The applicant continues to update its application with the BLM as the licensing process moves forward and added information is gathered. The applicant anticipates that upon license issuance from FERC, the BLM will also provide their ROW grant, land use permit, and notice to proceed with construction within the energy corridor. Upon receipt of BLM authorization, the applicant will file all relevant documents with the FERC. Within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing activity, whichever comes first, the applicant will file for FERC approval a Biological Resources Protection Training Program (BRPTP) to inform construction contractors and project staff of the sensitive biological resources in the area. The applicant will include within the BRPTP, at a minimum: • • • • • •

Biological Resources Protection Training Program (BRPTP)

An overview of the life history of the sensitive biological resources in the area, including habitat; An explanation of how construction activities may impact these species and their habitats; Instructions on what to do if these resources are encountered; BMPs for protecting sensitive biological resources and avoiding and minimizing impacts; A description of the process for conducting mitigation and monitoring activities; and An explanation of the importance of documenting and reporting any observations of sensitive species or habitats during construction.

The applicant will tailor the training program to the project and include a 30- to 60-minute presentation and informational booklet that workers can carry on-site for reference. The applicant will provide the presentation annually each spring throughout the entire 5-year construction period.

Coordinating Entities: • WPW • NDOW • NDEP • USFWS • BLM • FERC Staff Consultation Plan:

Capital (2022$)

Annual Cost (2022$)

Note: Costs of transmission line development are considered under Exhibit D, Table 1.0-1. Summary of Estimated Cost of New Construction (2021$), and Table 1.2-1. Estimated Indirect Construction Costs (2021$).

Note: The transmission line effort is not relevant post-construction. During construction, costs are incorporated into Capital Costs.

$50,000

$5,000

Note: Capital cost estimate includes the development of the training program, and resources utilized for developing initial materials.

Note: Anticipated cost for annual training.

The applicant will prepare the training program after consultation with BLM, NDOW, NDEP, and the U.S. Fish and Wildlife Service (USFWS). The applicant will include documentation of consultation within the BRPTP, copies of comments and recommendations on the completed BRPTP after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the BRPTP. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommendations before filing the BRPTP with FERC. If the applicant does not adopt a recommendation, the filing will include the applicant’s reasons, based on project-specific information.

February 2023 (Revised July 2023) | 355

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures The applicant will develop a Noxious Weed Management Plan (NWMP) for construction, operation, and maintenance of the project. The applicant will prepare the NWMP in coordination with BLM and NDOW and submit it to BLM for review and approval. The applicant will request a 30-day review by BLM and NDOW for comment and recommendations before filing the NWMP with FERC. The applicant will include, within the NWMP, measures to reduce the spread or introduction of noxious weed and invasive plant species. The applicant will incorporate within the NWMP restrictions and guidelines for application of pesticides, including herbicides, and avoidance of known sensitive plant species. The applicant will comply with BLM requirements regarding herbicide use on BLM lands. At a minimum, the applicant will include the following measures within the NWMP: • Control introduction and spread of noxious weeds and invasive plants in the project footprint by cleaning vehicles and equipment prior to movement into the project footprint and/or prior to movement to a new location within the project footprint, in order to minimize the potential for transporting seeds. • Worker awareness and responsibility training for control of noxious weeds and invasive plants. Training will include: field identification of weeds; reproductive biology of weeds; ecological and economic impact of weeds; invasive plant prevention Best Management Practices (BMPs); inspection and cleaning protocols for vehicles, equipment, tools, and gear; and how to report occurrences for invasive or noxious plants. • Inspection procedures and protocols for construction materials and equipment used in the project footprint. • Work with land managers to develop and implement a plan to assess, treat, and monitor noxious weeds and invasive plants within the project footprint and in the adjacent landscape where they are present. • Work with the local weed and pest district to implement long-term plans for successful restoration and reclamation of disturbed sites.

Noxious Weed Management Plan (NWMP)

The applicant will include the following within the NWMP goals and objectives: • Implement early detection and rapid response (EDRR) protocols through regular monitoring; • Define containment strategies • Control movement of invasive and noxious plant material and seeds; • Encourage the reduction of soil and vegetation disturbance; and • Maintain desired plant communities.

Entities/Consultation Plan Coordinating Entities: • WPW • NDOW • BLM • FERC Staff Consultation Plan: The applicant will prepare the NWMP after consultation with BLM and NDOW. The applicant will include documentation of consultation within the NWMP, copies of comments and recommendations on the completed NWMP after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the NWMP. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommendations before filing the NWMP with FERC. If the applicant does not adopt a recommendation, the filing will include the applicant’s reasons, based on project-specific information.

Capital (2022$)

Annual Cost (2022$)

$50,000

$20,000

Note: The capital cost in this table reflects a professional estimate of the level of effort anticipated to develop a NWMP. No noxious weed measures/BMPs, or noxious weed inspections have been included.

Note: The annual cost in the table reflects an estimated level of effort to maintain and update the NWMP as necessary.

The applicant will implement the following BMPs during construction, operation, and maintenance: • To prevent noxious weeds from spreading into the project footprint, prior to commencing ground-disturbing activities, and during such activities, a certified biologist will survey the respective areas of the project footprint and any associated access roads for populations of noxious weeds. All populations of noxious weeds within 50 feet of the permitted ROW, roads, or access zones will be flagged and treated prior to the start of ground-disturbing activities. • During the course of construction, at least once every growing season, noxious weed surveys will be conducted for new noxious weed populations. Pedestrian transects (where permissible) will be completed of all incoming vector access points including ROWs, roads, and ground disturbances. The infestations will be mapped, and then flagged, to eliminate foot or vehicular traffic from spreading the population. The population will be treated/controlled at the earliest possible time. The utmost priority will be placed on controlling and eliminating EDRR species. Any detections of noxious weeds will be reported to the appropriate agency. • Monitoring of existing and previously treated infestations will take place throughout the construction phase of the project to determine if the populations are still extant, the efficacy of the previous treatments, and if control measures should be altered. • After construction is complete, the applicant will inspect all sites where prior treatments occurred to determine if additional treatments are required. Follow-up treatments will be completed if necessary. Post-construction noxious weed monitoring will occur during the growing season within one year after construction is completed, and on an ongoing basis annually. Treatment Methods: The applicant will include the requirements for herbicide treatments in the NWMP and will implement noxious weed control measures that will be in accordance with existing regulations and jurisdictional land management agency agreements. Before construction, only herbicides that are approved by the State of Nevada and the BLM will be applied to any identified weed infestations on public lands to reduce the spread or proliferation of weeds. Post-construction control measures may include one or more of the following methods: February 2023 (Revised July 2023) | 356

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures •

• •

Entities/Consultation Plan

Capital (2022$)

Annual Cost (2022$)

Mechanical methods rely on equipment used to mow or disc weed populations. If such a method is used, subsequent seeding will be conducted to re-establish a desirable vegetative cover that will stabilize the soils and slow the potential reinvasion of noxious weeds. Seed selection will be based on site-specific conditions, the appropriate seed mix identified for those conditions, and will be approved by the BLM for application on public lands. Disking or other mechanical treatments that would disturb the soil surface within native habitats will be avoided. Herbicide application is an effective means of reducing the size of noxious weed populations and any application to any identified weed infestation on public lands will be approved by the State of Nevada and the BLM. Only a State of Nevada licensed contractor, who is also approved by the BLM, will perform herbicide applications. All herbicide applications must follow United States Environmental Protection Agency label instructions. Treatment methods will be based on species-specific and area-specific conditions (e.g., proximity to agricultural areas, time of year, soil conditions, etc.) and will be coordinated with the local regulatory offices. A Pesticide Applicator Record (PAR) will be prepared for any herbicide treatments. If areas are not seeded until the following spring because of weather or scheduling constraints, all annuals and undesirable vegetation that have become established will be treated before seeding.

The invasive plant species found in and adjacent to the project footprint are known to occur throughout the western United States and are spread by various land uses. The combination of past and present land use activities in the vicinity of the project has contributed to and likely will continue to facilitate the creation of disturbed and weedy habitats. It is well known that many types of land uses contribute to the invasion and spread of non-native invasive species including ground-disturbing activities as well as activities that promote the dispersal of weed seed. Roads, agriculture, farming/ranching, recreation, and residential and commercial developments all can contribute to the spread of invasive botanical species. The applicant will minimize and control the spread of invasive botanical species that could result from construction and operation of the project through development of a Noxious Weed Management Plan. Given adequate and appropriate weed management and site restoration activities, the project should have minimal negative effects on plant communities and could provide a net benefit by reducing weed infestations in the project footprint and vicinity. Thus, the project is not expected to have significant impacts to the landscape from the spread of noxious weed species.

February 2023 (Revised July 2023) | 357

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures Pursuant to the Federal Land Policy and Management Act, the applicant anticipates that early development of a Habitat Revegetation, Restoration, and Enhancement Plan (HRREP) to clearly identify measures for the management, avoidance, and mitigation of potential habitat and associated vegetation losses during construction and operation and maintenance of the project will be necessary to obtain a Right-of-Way Grant Authorization and Record of Decision from BLM. Accordingly, the applicant will initiate early consultation with relevant agencies to develop the HRREP prior to FERC’s issuance of a license for the project. Drafting of a NEPA-ready HRREP prior to commencement of the NEPA process would ensure that the expected outcomes of restoration and specific mitigation measures could be integrated into the impacts analysis. Typically, restoration plans are developed prior to FERC’s environmental assessment to provide a framework of proposed reclamation activities. The applicant would primarily focus the HRREP on impacts from construction and ongoing post-construction restoration. As the project moves closer to construction, a more detailed final (i.e., NTP-ready) the applicant would develop the HRREP with sufficient detail for construction contractors to implement the required revegetation and restoration actions and appropriate mitigation measures.

Habitat Restoration, Reclamation, and Enhancement Plan (HRREP)

At a minimum, the applicant will include the following within the HRREP: • Specific restoration and habitat mitigation requirements for greater sage-grouse and other special status wildlife species that may require special restoration considerations; • Estimate of acreage for each habitat type needing restoration in various soil types and vegetation communities; • Clear articulation of goals and objectives for habitat revegetation, restoration, and enhancement that will be implemented post-construction; • Description of revegetation efforts to prevent soil erosion and the spread of weeds, maintain or restore existing native plant communities and wildlife habitat, and integrate site features with the surrounding environment; • Identification of specific measures to restore vegetation disturbed by project-related construction activities, including proposed methodologies/protocols for implementation, seed mix and/or plant species specifications (which would consider soil types, local vegetation communities, and environmental conditions), regrading of disturbed ground (e.g., temporary access roads), site preparation approach (e.g., topsoil handling, recontouring, soil analysis and amendments, seedbed preparation), planting designs and locations, and ongoing maintenance methods for revegetated areas; • Identification of appropriate native plant species for revegetation, including consideration of site-specific conditions; • Identification of methods to salvage protected cacti before ground disturbance in compliance with Nevada regulations; • Specification of methods for control of invasive plant species that could affect revegetation efforts; • Identification of site-specific restoration, reclamation, and enhancement measures should future temporary ground disturbance be needed; • Clear articulation of monitoring and success criteria to evaluate the implementation of measures that will meet the HRREP’s stated goals and objectives; • Definition of monitoring requirements and methods (e.g., monitoring approach, determination of control plot for monitoring, and time frames and milestones, data, and reporting); • Description of an adaptive management approach to address issues that arise if initial restoration or revegetation efforts do not meet success criteria; • Clear development of an estimate of costs associated with the restoration methods, ongoing maintenance, and final restoration, which will be adapted from standard reclamation cost estimate procedures, as provided by the appropriate agency.

Entities/Consultation Plan Coordinating Entities: • WPW • NDOW • Nevada SETT • Bristlecone FO BLM • FERC Staff Consultation Plan: The applicant will prepare the HRREP after consultation with the BLM Ely District’s Bristlecone Field Office of the BLM (following the Ely District BLM RMP/ROD), NDOW, Nevada (Sagebrush Ecosystem Team) SETT, and other required agencies. The applicant will include documentation of consultation within the HRREP, copies of comments and recommendations on the completed plan after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the HRREP. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommendations before filing the HRREP with FERC. If the applicant does not adopt a recommendation, the filing will include the applicant’s reasons, based on project-specific information.

Capital (2022$)

Annual Cost (2022$)

$100,000

$20,000

Note: The capital cost in this table reflects a professional estimate of the level of effort anticipated to develop a HRREP. The applicant has not included restoration measures/BMPs, restoration installation, or restoration inspections in the costs. The applicant included those costs in the cost of construction.

Note: The annual cost in the table reflects an estimated level of effort to maintain and update the HRREP as necessary.

February 2023 (Revised July 2023) | 358

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures A final transmission line design is still under development. Prior to the onset of ground disturbance, the applicant will use existing baseline data and desktop analysis covering all suitable eagle and raptor nesting habitat to determine what specific design features, guided by Avian Power Line Interaction Committee (APLIC) (2005 and 2012) standards, will be necessary to minimize risk of raptor injury and mortality. If existing baseline data is deemed insufficient through agency consultation, additional data will be collected. The applicant will complete desktop analysis through data queries from NDOW, Nevada SETT, USFWS, and NDNH. Additionally, consideration for topography and discussion with the engineering team will be necessary to implement transmission tower design features such as markers, diverters, perch guards, line spacing, insulative covers, etc., and where their placement will be most advantageous through each phase of the project. More information is necessary to create a comprehensive strategy to mitigate injury and mortality from collision and electrocution via transmission towers and their components. Transmission line structure location and related needs for species included in the Greater Sage-Grouse Mitigation Plan (PM&E 17) and Raptor and Bat Protection Plan (PM&E 14) will be considered during transmission line design, and any relevant findings from this process will be included in those plans. Transmission Line Design is further outlined in PM&E 24.

Raptor-Safe Transmission Line Structures

Entities/Consultation Plan Coordinating Entities: • WPW • NDOW • NDNH • Nevada SETT • USFWS • BLM • FERC Staff Consultation Plan: The applicant will consult with NDOW, NDNH, Nevada SETT, USFWS, and the BLM on raptor-safe transmission line structures. The applicant will provide documentation of consultation (See RBPP (PM&E 14)), copies of comments and recommendations on the completed plan after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the RBPP. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommendations before filing the RBPP with FERC. If the applicant does not adopt a recommendation, the filing will include the applicant’s reasons, based on project-specific information.

Capital (2022$)

Annual Cost (2022$)

$1,750,000

Note: The capital cost in this table reflects implementation of data analysis, specific design features, and engineering of tower design, as well as material costs for markers, diverters, perch guards, insulative covers, etc.

Note: The transmission line effort is not relevant post-construction. The applicant will have already incorporated PM&E measures during construction and will implement the RBPP with those associated annual costs.

February 2023 (Revised July 2023) | 359

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Noise

Description of Protection, Mitigation, and Enhancement (PM&E) Measures

Entities/Consultation Plan

As discussed in the Greater Sage-Grouse Lek and Habitat Study Report (2023) (Appendix D of the FLA), a previous noise modeling study was conducted within ¼ mile from eight lek sites to compare pre-project noise levels to anticipated noise levels during construction and operation and maintenance of the proposed project. Noise monitoring systems were deployed May 4, 2021 and collected on May 18, 2021. The construction noise modeling results show that construction noise is expected to exceed the limits at almost all leks, both with the upper and lower reservoir activities combined and individually; however, noise levels during operation are expected to be within the allowable L50 limits at each lek.

Coordinating Entities: • WPW • BLM • FERC Staff

In 2024, the applicant will conduct an additional noise modeling study to further aid efforts to minimize the effects of noise related to construction and operation and maintenance of the proposed project, notably effects to greater sage-grouse, by identifying current noise levels at the site and evaluating the changes to those levels as a result of the proposed project.

Upon completion of the study plan, the applicant with provide BLM 30-day comment-review. The applicant will include documentation of consultation within the final noise study report, copies of comments and recommendations on the completed report after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the final noise study report. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommendations before filing the final noise study report with FERC.

Predicted construction-generated noise levels at nearby receptors will be calculated using the Federal Highway Administration (FHWA) Roadway Construction Noise Model (RCNM). The RCNM is FHWA’s national model for the prediction of construction noise. This software is based on actual sound-level measurements from various equipment types taken during the Central Artery/Tunnel project conducted in Boston, Massachusetts, during the early 1990s. The maximum noise levels presented at a specified distance from the source are based on a roster of likely construction equipment operating. Although the project is not a road construction project, the RCNM includes the same types of equipment that would be used in the construction of the project. Noise impacts will be estimated for the operations on the project site. Activities that would generate noise levels are mechanical sound from pumps, water conveyance, turbines, transformers, and road access. Noise impact assessment for the operational phase will be based on engineering calculations for the pieces of noise-generating equipment at the proposed site using SoundPLAN Essential Version 5.1. The model incorporates a three-dimensional geometric model of the study area developed from digital terrain information, available GIS information, grading data, and aerial photography. SoundPLAN Essential v5.1 incorporates more than 25 noise modeling standards and provides a set of model solutions/standards for outdoor noise modeling that include the International Organization for Standardization (ISO) 9613-2 general environmental noise model (point and line area sources). The noise study will include a noise isopleth receptor map of the analysis area. The significance of noise-related impacts will be determined in comparison to applicable local, state, and/or federal noise standards.

Consultation Plan:

Capital (2022$)

Annual Cost (2022$)

$75,000

Note: The capital cost in this table reflects a professional estimate of the level of effort anticipated to conduct a noise modeling study.

Note: The noise modeling study will not be relevant postconstruction.

February 2023 (Revised July 2023) | 360

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures Within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing activity, whichever comes first, the applicant will complete botanical surveys, wildlife surveys, and habitat assessments, as determined through consultation with relevant agencies. The applicant will verify that surveys are conducted by trained biologists in areas that will be disturbed by the proposed project. Specific pre-construction activities may include, but are not limited to, surveys for the following: • • • •

Raptors and raptor nests within the project vicinity; Nesting migratory birds; Protected wildlife and plant species; and Lek counts for greater sage-grouse leks within 3.1-miles of project components, as coordinated with the NDOW.

Based on the findings of the surveys, the applicant will consult with applicable regulating agencies for the pre-construction survey requirements. The applicant will also consult with applicable regulating agencies to identify reasonable avoidance or mitigation measures (AMMs) to reduce adverse impacts. The applicant will use the best available resources, science, and AMMs protect sensitive biological resources, including the USFWS Avian Protection Plan (APP) Guidelines and BLM Ely RMP, and BLM Nevada’s Statewide Wildlife Survey Protocols.

Pre-Construction Surveys

Entities/Consultation Plan Coordinating Entities: • WPW • USFWS • NDOW • BLM • FERC Staff Consultation Plan:

Capital (2022$)

Annual Cost (2022$)

$500,000

Note: Capital costs outlined for this PM&E include estimated implementation of all pre-construction surveys.

Note: Preconstruction surveys are not relevant postconstruction.

Upon completion of the surveys, the applicant will prepare a study report and provide it to relevant agencies for comment-review. The applicant will include documentation of consultation within the final report, copies of comments and recommendations on the completed report after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the final report. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommendations before filing the final report with FERC.

February 2023 (Revised July 2023) | 361

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures The applicant proposes to have biological construction monitors on site during construction to monitor sensitive biological resources. Biological monitoring will occur based on Ely RMP stipulations, discretion of the biological monitor, and the results of pre-construction and baseline surveys.

Biological Construction Monitoring

The biological monitor will be responsible for biological clearance surveys and administration of Biological Resources Protection Training Program (BRPTP) (see PM&E 7), as well as advising construction personnel on implementing AMMs and BMPs. The biological monitor will conduct avian nesting surveys of areas near active construction during typical nesting season (March 1 to July 31). The applicant will coordinate with the BLM to determine the minimum radius of species-specific protective buffers around active nests within or near the project construction footprint. It should be noted that birds will sometimes nest outside of the typical nesting season and will still be protected under the Migratory Bird Treaty Act if they do. The monitors will have the authority to temporarily halt construction equipment if any sensitive wildlife is in harm’s way during construction activities. The biological monitor will determine if the animal can be relocated outside of the construction area or if it will need to leave by its own accord.

Entities/Consultation Plan Coordinating Entities: • WPW • NDOW • BLM • FERC Staff Consultation Plan: The applicant will coordinate with the BLM and NDOW on the appropriate frequency and timing of the biological construction monitors.

Capital (2022$)

Annual Cost (2022$)

$1,000,000

Note: Cost will be dependent on the frequency that a biological monitor is needed on site. The applicant has identified this cost as a preliminary estimate contingent on the timing and frequency of construction monitoring required.

Note: Construction monitoring is not relevant postconstruction.

February 2023 (Revised July 2023) | 362

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures Within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing activity, whichever comes first, the applicant will file for FERC approval a Raptor and Bat Protection Plan (RBPP) to protect avian species from collision or electrocution as a result of landing or perching on transmission lines. At a minimum, the applicant will include within RBPP: •

•

Raptor and Bat Protection Plan (RBPP)

•

• • •

Nesting bird and raptor survey protocols (see PM&E 12) to be implemented within two weeks of the commencement of construction activities. The pre-construction survey area will include the Project Area and a 0.25 mile to 0.5-mile buffer around project features. Previous surveys have resulted in no identified nesting locations.Based on the results of preconstruction surveys, the applicant will develop appropriate seasonal or spatial buffers, if necessary, in consultation with Nevada Department of Fish and Wildlife (NDOW), the U.S. Bureau of Land Management (BLM), and the USFWS Region 8 that incorporate the applicant’s goal of certain construction activities (tunneling, concrete batch plant operation, construction of reservoirs, etc.) being conducted on a 365/24/7 schedule that is not limited by wildlife. Mitigation measures and BMPs to minimize impacts to raptor and bat species (i.e., Description of where to install visibility enhancement devices to reduce risk of collision on new or existing lines; description of where to install perch guards between closely spaced conductors above arms and conductors to keep raptors from contacting energized parts; description of where flight diverters will be most advantageous; a description of regular maintenance of the transmission line and retrofitting the lines as applicable; a description of safe alternative locations for perching and nesting); Raptor-safe guidelines for all new electrical construction (see PM&E 10): Detailed avian collision and electrocution monitoring plan, that describes methods, implementation schedule, quantifiable thresholds for determining when corrective measures would need to be implemented to address high-collision and electrocution areas along the transmission line or at the reservoir fences, and procedures for documenting and reporting bird fatalities and injuries to NDOW, BLM, and the USFWS; A provision for filing with the Commission a report by March 31 of each year that includes: the results of any surveys or monitoring, any occurrence of project-related avian injuries/mortalities, estimated fatality rates, and any recommendations for corrective measures, if necessary. The licensee must allow a minimum of 30 days for the resource agencies to comment on the report before filing it with FERC; Employee training to ensure plan compliance, pursuant to PM&E 7; Reporting system for avian and bat injuries and fatalities; Adaptive monitoring and management plan.

Entities/Consultation Plan Coordinating Entities: • WPW • USFWS • NDOW • BLM • FERC Staff Consultation Plan: The applicant will consult with BLM and NDOW regarding the RBPP. The applicant will include documentation of consultation within the RBPP, copies of comments and recommendations on the completed RBPP after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the RBPP. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommendations before filing the RBPP with FERC. If the applicant does not adopt a recommendation, the filing will include the applicant’s reasons, based on project-specific information.

Capital (2022$)

Annual Cost (2022$)

$40,000

$20,000

Note: The capital cost in this table reflects a professional estimate of the level of effort anticipated to develop a RBPP.

Note: The annual cost in the table reflects an estimated level of effort to maintain and update the RBPP as necessary.

The applicant will ensure that the plan addresses consideration of the Avian Power Line Interaction Committee’s (APLIC) guidelines: Suggested Practices for Avian Protection on Power Lines, The State of the Art in 2006 [APLIC 2006] and Reducing Avian Collisions with Power Lines: The State of the Art in 2012 [APLIC 2012]) to protect avian species from collision or electrocution as a result of landing or perching on transmission lines.

February 2023 (Revised July 2023) | 363

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Outdoor Lighting Plan (OLP)

Outdoor lighting designed to reduce impacts on foraging bats, migrating and nocturnal birds, and night skies; Use of localized and portable lighting during construction, where and when work is occurring; Provisions to power lighting equipment by generators with switches to cut power when lighting is not required; Reduction of lighting at the upper reservoir to minimize potential negative impacts to the nighttime sky; Luminaires/fixtures equipped with specific optical systems and shields listed by the manufacturer as “nighttime friendly”; and Implementation of 3000K warm yellow light to minimize potential nighttime glow.

Additionally, the applicant will incorporate, within the OLP, BMPs associated with BLM-managed lands included in BLM Technical Note 457- Night Sky and Dark Environments: Best Management Practices for Artificial Light at Night on BLM-Managed Lands. These practices include lighting position, direction, mounting, and shielding, along with the use of “night sky friendly” narrow spectrum light sources in as few places as needed for safety during work hours and security during off hours. See PM&E 23 for lighting coordination with NNR.

The pygmy rabbit is classified as a NDOW “Species of Special Concern” and a BLM sensitive species. Field studies conducted within the Project Area have not identified pygmy rabbit to date, but the project area is in the known range of the species and suitable habitat is present (HDR 2022b). Direct mortality can occur by destruction of occupied burrows during vegetation clearing, excavation, and grading, or by collision with vehicles on roads to and from the project. As discussed under PM&E 12, within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing activity, whichever comes first, the applicant will complete wildlife surveys and habitat assessments for pygmy rabbits, as determined through consultation with relevant agencies. The applicant will verify that surveys are conducted by trained biologists in areas that will be disturbed by the proposed project. 16

Pygmy Rabbit Management

During construction of the project, active pygmy rabbit habitat will be avoided when feasible. The applicant will coordinate avoidance and minimization measures during construction with the BLM and NDOW. These measures may include: • Incorporating into the construction ROW the use of existing roads as to reduce the amount of new surface disturbance required for the ROW area; • Making micro-adjustments to the proposed project construction footprint to reduce the incursion into suitable habitat for pygmy rabbits (e.g., routes could be shifted slightly to avoid an important feature such as an active burrow); • Upgrades to existing roads limited to situations where the road would not be otherwise passable by construction equipment; • Avoid cutting vegetation in areas of suitable pygmy rabbit habitat, and re-seed as part of restoration post-construction; • To the maximum extent possible, restore the vegetation in the project footprint to achieve similar composition, diversity, and cover to that of the surrounding desert landscape; • As described in the NWMP, implement a comprehensive invasive species plant control program to prevent the introduction of noxious and invasive plants in areas disturbed by project construction; and • Implement dust control measures as outlined in the ESCP, to limit release of dust from access roads and other project areas.

Entities/Consultation Plan Coordinating Entities: • WPW • USFWS • NDOW • NNR Foundation • BLM • FERC Staff Consultation Plan: The applicant will prepare the OLP after consultation with BLM. The applicant will include documentation of consultation within the OLP, copies of comments and recommendations on the completed OLP after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the OLP. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommendations before filing the OLP with FERC. If the applicant does not adopt a recommendation, the filing will include the applicant’s reasons, based on project-specific information. Coordinating Entities: • WPW • NDOW • BLM • FERC Staff Consultation Plan: As noted in the description of the PM&E, the applicant will consult with NDOW and the BLM on measures to mitigate for impacts to pygmy rabbits, including implementation of baseline data collection, field surveys, and construction monitoring.

Capital (2022$)

Annual Cost (2022$)

Note: Costs of implementation of the Outdoor Lighting Plan are considered under Exhibit D, Table 1.0-1. Summary of Estimated Cost of New Construction (2021$), and Table 1.2-1. Estimated Indirect Construction Costs (2021$).

Note: The OLP is not relevant postconstruction. During construction, costs are incorporated into Capital Costs, and no modifications are anticipated postconstruction.

$75,000

Note: Capital costs for this PM&E reflect implementation of measures specifically related to pygmy rabbit mitigation.

Note: Annual costs post-construction are not anticipated for this PM&E measure.

February 2023 (Revised July 2023) | 364

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures Pursuant to the Federal Land Policy and Management Act and as required by the BLM’s Greater Sage-Grouse (GRSG) Approved Resource Management Plan Amendment (ARMPA), early development of a Greater Sage-Grouse Mitigation Plan (GSGMP) will be necessary in the process to obtain a Right-of-Way Grant Authorization and Record of Decision from the BLM. Accordingly, the applicant participates in a monthly Technical Working Group (TWG), which was established by the BLM to allow coordination with participating agencies to guide the development of wildlife-related management and mitigation plans proposed in the applicant’s PM&E measures, such as the GSGMP. The initial TWG meeting was hosted on June 29, 2023, and included staff from the following agencies: BLM, NDOW, Nevada SETT, and White Pine County. Both the USFWS and the USFS were invited to the TWG but have declined to participate. The applicant anticipates that a NEPA-ready GSGMP would be drafted prior to commencement of the NEPA process, such that the expected outcomes of mitigation measures could be integrated into the impacts analysis. Typically, mitigation plans are developed prior to FERC’s environmental assessment to provide a framework of proposed mitigation activities. The GSGMP would primarily be focused on impacts from construction and ongoing post-construction operations and maintenance activities. As the project moves closer to construction, a more detailed, final (i.e., NTP-ready) GSGMP would be developed with sufficient detail for construction contractors to implement the appropriate mitigation measures. In addition to the development of the GSGMP, the applicant will comply with Nevada SETT and Nevada’s Conservation Credit System (CCS) process to offset impacts to greater sage-grouse, as proposed in PM&E 21.

Greater Sage-Grouse Management Plan (GSGMP)

Within 90 days prior to the start of any ground-disturbing activity, the applicant will file for FERC approval a final GSGMP to avoid, minimize, and/or mitigate potential impacts to greater sage-grouse. At a minimum, the mitigation plan would include measures to: • • •

Locate transmission line infrastructure within the existing BLM Section 368(a) designated energy #110-114 (Ely to Milford) corridor to reduce and collocate infrastructure through greater sage-grouse habitat; Collocate proposed transmission infrastructure with existing transmission infrastructure, to the extent practicable; and Identify BMPs and mitigation measures to avoid, minimize, and mitigate potential impacts from transmission lines by designing transmission lines that comply with applicable APLIC guidelines in “Best Management Practices for Electric Utilities in Sage-grouse Habitat” (APLIC 2015), including the following: o Install anti-perch and/or anti-nesting devices to reduce use by predatory birds; o Limit construction disturbance and access during breeding season; o Minimize spacing between existing and proposed transmission lines; and o Minimize the height and number of tall structures at the upper reservoir to reduce the project facilities that are visible from the four active greater sage-grouse leks within 3.1-miles from project components (i.e., transmission lines).

Entities/Consultation Plan Coordinating Entities: • WPW • BLM • NDOW • Nevada SETT • White Pine County • USFS • USFWS • FERC Staff Consultation Plan:

Capital (2022$)

Annual Cost (2022$)

$3,000,000

$10,000

Note: Capital costs for this PM&E reflect plan development and implementation measures associated with greater sagegrouse.

Note: The annual cost in the table reflects an estimated level of effort to maintain and update the GSGMP as necessary.

The applicant will prepare a GSGMP after consultation with the already-formed wildlife-focused TWG (e.g., BLM, NDOW, Nevada SETT, White Pine County, and other relevant agencies). The mitigation plan will also include documentation of consultation, copies of comments and recommendations on the completed plan after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the plan. The applicant will allow a minimum of 30 days for the agencies to comment on the final GSGMP and to make recommendations before filing the plan with FERC. If the applicant does not adopt a recommendation, the filing will include the applicant’s reasons, based on project-specific information.

February 2023 (Revised July 2023) | 365

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures The applicant currently participates in a monthly TWG meeting, which was established by the BLM to allow coordination with participating agencies to guide the development of wildlife-related management and mitigation plans proposed in the applicant’s PM&E measures 17 (greater sage-grouse), 18 (general wildlife seasonal restrictions), and 20 (big game), such as the development of wildlife seasonal restrictions during construction. The initial TWG meeting was hosted on June 29, 2023, and included staff from the following agencies: BLM, NDOW, Nevada SETT, and White Pine County. Both the USFWS and the USFS were invited to the TWG but have declined to participate.

Wildlife Seasonal Restrictions

The applicant will continue to consult with the already-formed wildlife-focused TWG (e.g., BLM, NDOW, Nevada SETT, White Pine County, and other relevant agencies) to develop a conceptual construction schedule and additional proposed measures to mitigate potential adverse effects to wildlife. Through the consultation process, the applicant will define the length of time and time of year that impacts are expected to occur, including consideration of any proposed seasonal wildlife restrictions. A draft construction schedule, proposed seasonal wildlife restrictions, and other mitigation measures will be provided to the TWG for review and comment. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommendations before filing the proposal with FERC. If the applicant does not adopt a recommendation, the filing will include the applicant’s reasons, based on project-specific information.

Within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing activity, whichever comes first, the applicant will coordinate with the wildlife-focused TWG to develop measures to prevent cattle, wild ungulates, and other medium- to large-sized animals from accessing the reservoirs. At a minimum, reservoir wildlife exclusions measures will include: • • • • • 19

Reservoir Wildlife Exclusion

Installation of a 10-foot-tall game fence and gate(s) at the toe of the embankment of each reservoir; Installation of a geomembrane inside each reservoir; Installation of a one-way exit gate to facilitate a safe exit in the event that wildlife was to enter the fenced-off area; and Regular maintenance on the materials and structures around the reservoir perimeter; and Routine monitoring to ensure the fencing has not failed.

Specific measures will be determined in coordination with the wildlife-focused TWG and included in final construction design. Measures implemented at the project for reservoir wildlife exclusion will be included in the Public Safety Plan to be filed with FERC, as proposed under PM&E 22.

Entities/Consultation Plan Coordinating Entities: • WPW • BLM • NDOW • Nevada SETT • White Pine County • USFS • USFWS • FERC Staff Consultation Plan: As outlined in the description of the PM&E, the applicant will consult with the BLM, NDOW, Nevada SETT, White Pine County, and other relevant agencies and continue coordination at TWGs. The TWG will be offered the opportunity to comment on the draft construction schedule, proposed seasonal restrictions, and other mitigation measures, as appropriate. Coordinating Entities: • WPW • BLM • NDOW • Nevada SETT • White Pine County • USFS • USFWS • FERC Staff Consultation Plan:

Capital (2022$)

Annual Cost (2022$)

Note: Costs of implementation of the wildlife seasonal restriction measures are considered under Exhibit D, Table 1.0-1. Summary of Estimated Cost of New Construction (2021$), and Table 1.2-1. Estimated Indirect Construction Costs (2021$).

Note: This PM&E is not relevant postconstruction. During construction, costs are incorporated into Capital Costs, and no modifications are anticipated postconstruction.

$300,000

$10,000

Note: Capital costs for this PM&E reflect plan development and implementation measures associated with excluding wildlife from the reservoir area.

Note: The annual cost in the table reflects an estimated level of effort to maintain wildlife exclusion areas for the reservoir.

February 2023 (Revised July 2023) | 366

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures The applicant currently participates in a monthly TWG meeting, which was established by the BLM to allow coordination with participating agencies to guide the development of wildlife-related management and mitigation plans proposed in the applicant’s PM&E measures, such as the development of wildlife seasonal restrictions during construction. The initial TWG meeting was hosted on June 29, 2023, and included staff from the following agencies: BLM, NDOW, Nevada SETT, and White Pine County. Both the USFWS and the USFS were invited to the TWG but have declined to participate.

Big Game

The applicant will continue to consult with the already-formed wildlife-focused TWG (e.g., BLM, NDOW, Nevada SETT, White Pine County, and other relevant agencies) to secure appropriate exceptions or variances, as needed, for construction in big game crucial summer and winter areas. Furthermore, the applicant will review and incorporate the BLM stipulations in Ely Resource Management Plan for seasonal restrictions relevant to big game and develop a conceptual construction schedule and additional proposed measures to mitigate potential adverse effects to wildlife. Through the consultation process, the applicant will define the length of time and time of year that impacts are expected to occur, including consideration of any proposed seasonal wildlife restrictions related to big game. A draft construction schedule, proposed seasonal wildlife restrictions, and other mitigation measures will be provided to the TWG for review and comment, as proposed in PM&E 18. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommendations before filing the proposal with FERC. If the applicant does not adopt a recommendation, the filing will include the applicant’s reasons, based on project-specific information.

The applicant proposes to purchase credits through Nevada’s Conservation Credit System (CCS) from credit developers in White Pine County to offset debits to greater sage-grouse, as calculated through the Debit Project Analysis through the CCS. If credit developers are not available in White Pine County, then the applicant will purchase credit within the appropriate or approved service area to White Pine County. The estimate of the total debits resulting from direct and indirect impacts of the project is approximately 827 debits. If the project footprint changes, the Debit Project Analysis will be revised to include any changes. The applicant will coordinate directly with the Nevada SETT to work with an approved credit provider to purchase credits through a Phased Purchase Agreement equal to the debits calculated for the project plus debits resulting from a proximity factor. Provisions for purchasing CCS credits for potential impacts to greater sage-grouse will be determined with the Nevada SETT, parallel to and included in the development of the GSGMP and coordination with the TWG, as proposed in PM&E 17. The GSGMP will include documentation of consultation, copies of comments and recommendations, and specific descriptions of how the agencies’ comments were accommodated regarding the purchase of CCS credits.

Entities/Consultation Plan Coordinating Entities: • BLM • NDOW • Nevada SETT • White Pine County • USFS • USFWS

Capital (2022$)

Annual Cost (2022$)

See PM&E 18.

Note: The value of the CCS credits is still undetermined pending further consultation.

Consultation Plan: As outlined in the description of the PM&E, the applicant will consult with the agencies outlined and continue coordination at TWGs. The TWG will be offered the opportunity to comment on the draft construction schedule, proposed seasonal restrictions, and other mitigation measures, as appropriate. Coordinating Entities: • WPW • BLM • NDOW • SETT • Nevada SETT • White Pine County • USFS • USFWS • FERC Staff Consultation Plan:

Greater Sage-Grouse Credit

Provisions for purchasing CCS credits for potential impacts to greater sage-grouse will be determined with the SETT, parallel to and included in the development of the GSGMP and coordination with the TWG, as proposed in PM&E 17. The GSGMP will include documentation of consultation, copies of comments and recommendations, and specific descriptions of how the agencies’ comments were accommodated regarding the purchase of CCS credits. The applicant will coordinate directly with the Nevada SETT to work with an approved credit provider to purchase credits through a Phased Purchase Agreement equal to the debits calculated for the project plus debits resulting from a proximity factor. February 2023 (Revised July 2023) | 367

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures Within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing activity, whichever comes first, the applicant will file a Public Safety Plan with FERC’s Division of Dam Safety and Inspections (D2SI). The plan will include a description of all safety devices and signage needed to warn the public of project-related hazards or to otherwise protect the public in the use of project lands and waters based on FERC’s Guidelines for Public Safety at Hydropower Projects. At a minimum, the plan will include the following measures to:

Public Access

• • • •

Install signage and barriers along existing, unpaved access routes to prevent unauthorized access into the construction work zones; Install signage and 10-ft-tall game fencing around both reservoirs for site security, public safety, and wildlife protection; Fencing and other safety and security design features around the outside edge of the perimeter roads, switchyard, and main access portal; and A map showing the location of all public safety measures implemented at the project.

The applicant will continue to coordinate with NNR from now throughout project construction to minimize potential effects to NNR operations. Coordination efforts may include: •

Northern Nevada Railroad (NNR) Coordination

• • • •

Development of outdoor lighting schedule and design during construction to avoid nighttime NNR excursion schedules (see PM&E 15 for the development of an Outdoor Lighting Plan for the project); Section 106 mitigation; Design and timing of railroad crossings; Providing educational information about the project and the role of pumped storage projects in stability and resiliency of the electric grid for NNR passengers on the HiLine; or Potential impact mitigation opportunities and costs.

The applicant will continue to coordinate with NNR and the National Park Service from now throughout project construction to minimize potential effects to NNR operations. As well as the specific coordination efforts noted above, the applicant is additionally coordinating with NNR on PM&Es 2, 5, 6, 26, and 27 (as appropriate).

Transmission Line Design (Floodplains / Wetlands)

A desktop review and delineation assessment for wetland areas was completed June 28 through July 1, 2021, and May 17 through May 20, 2022. Additional information about wetland assessments for the project is provided in Section 3.4 (Water Resources) of the FLA. A final transmission line design is still under development. The applicant will finalize design of transmission facilities (including locations of transmission towers and access roads) in a manner that minimizes surface disturbing activity in identified 100-year floodplains, areas within 500 feet of perennial waters and wetland/riparian areas, and areas within 100 feet from the inner gorge of ephemeral channels, as specified in the BLM Ely RMP. Within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing activity, whichever comes first, the applicant will file for FERC approval a Transmission Line Design (as well as the Landowner Coordination Plan (LCP) noted as PM&E 4) to discuss and sequence the timing of the installation and placement of transmission line structures and other project construction activities in order to minimize adverse effects, where feasible. If transmission structures cannot be located outside of floodplains or if discharge or fill of wetlands is unavoidable, the applicant will consult with BLM, USACE, and FEMA, as appropriate, to identify reasonable mitigation measures to minimize adverse impacts to water features.

Entities/Consultation Plan Coordinating Entities: • WPW • FERC (D2SI) Consultation Plan: The applicant will work with FERC D2SI to determine appropriate public safety measures for the Project Area.

Coordinating Entities: • WPW • NNR • NNR Foundation • National Park Service • FERC Staff Consultation Plan: The applicant will continue to coordinate directly with the NNR from now throughout project construction to mitigate impacts to NNR operations. As well as the specific coordination efforts noted above, the applicant is additionally coordinating with NNR on PM&Es 2, 5, 6, and 26. Coordinating Entities: • WPW • BLM • FEMA • USACE • FEMA • FERC Staff

Capital (2022$)

Annual Cost (2022$)

$300,000

$1,000

Note: Capital costs for this PM&E reflect plan development and implementation measures associated with public access in the Project Area.

Note: The annual cost in the table reflects an estimated level of effort to maintain public safety in the Project Area.

$100,000

$10,000

Note: Capital costs for this PM&E reflect plan development and implementation measures associated with mitigation for impacts to NNR operations.

Note: The annual cost in the table reflects an estimated level of effort to mitigate effects to NNR operations.

Consultation Plan: Within one year of license issuance, or at least 90 days prior to the start of any ground-disturbing activity, whichever comes first, the applicant will file for FERC approval a Transmission Line Design (as well as the Landowner Coordination Plan (LCP) noted as PM&E 4) to discuss and sequence the timing of the installation and placement of transmission line structures and other February 2023 (Revised July 2023) | 368

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures

Entities/Consultation Plan

Capital (2022$)

Annual Cost (2022$)

project construction activities in order to minimize adverse effects, where feasible. If transmission structures cannot be located outside of floodplains or if discharge or fill of wetlands is unavoidable, the applicant will consult with BLM, USACE, and FEMA, as appropriate, to identify reasonable mitigation measures to minimize adverse impacts to water features.

February 2023 (Revised July 2023) | 369

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures During final design, the applicant will incorporate best management practice principles from First Edition 2103 – Best Management Practices for Reducing Visual Impacts of Renewable Energy Facilities on BLM-Administered Lands. This guidance document provides BMPs for common project elements on BLM lands such as mitigation planning, siting and design, structure design and material selection, material surface treatments, lighting, soil and vegetation disturbance, reclamation, and good housekeeping. At a minimum, the BMPs would include the following measures: Upper and Lower Reservoirs • Use locally-quarried (or from the site) rock and weed-free top soil on the outer berm of the reservoirs to reclaim the site and plant vegetation to further blend the reservoirs with the existing landscape. • Mimic surrounding natural features within the construction of the reservoirs to blend contours with the existing landscape. • Vary the gradient on the south face of the lower reservoir to further blend with background landscape. • Establish appropriate native vegetation on the reservoir berms, to blend the project with the existing landscape to the extent practicable Project Structures (Upper Reservoir Inlet/Outlet Structure, Lower Reservoir Inlet/Outlet Structure, Water Supply and Conveyance, Powerhouse and Transformer Cavern Plant and Equipment) • Paint all fences, gates, structures and other above-ground facility features with Bureau of Land Management-approved paint colors (Standard Environmental Colors, Color Chart CC-001) that match the surrounding landscape and dull the surfaces that cannot be painted. • Establish appropriate native vegetation around project structures to blend project with the existing landscape to the extent practicable. • Keep facility yards clean of debris and unused materials to minimize the appearance of these structures.

Visual Resources Best Management Practices

Linear Features (Transmission Line, and Access Roads) • Co-locate the proposed transmission line with existing rights-of-way where possible. • Install transmission line structures that are consistent with or complementary to existing structures of similar scale present in the surrounding landscape. • Install conductors with non-specular materials where possible to minimize visibility and contrast of the transmission line with the surrounding landscape. • Reduce the prominence of land-scarring and vegetation changes from the construction or modification of access roads to the extent possible by (a) using low-impact construction techniques such as helicopter to place and maintain transmission line poles in sensitive or difficult to access locations; using locally quarried aggregate to match colors of the surrounding landscape; modifying road surface color to match the surrounding landscape; minimizing the widening and grading of roads; employing dust-suppression measures during construction; and replanting all disturbed areas with permanent vegetation consistent with the Habitat Restoration, Reclamation, and Enhancement Plan.

Entities/Consultation Plan Coordinating Entities: • WPW • BLM • FERC Staff Consultation Plan: The plan will include documentation of consultation, copies of comments and recommendations on the completed plan after it has been prepared and provided to the BLM, and specific descriptions of how the BLM’s comments are accommodated by the plan. The applicant will allow a minimum of 30 days for the BLM to comment and to make recommendations before filing the plan with FERC. If the applicant does not adopt a recommendation, the filing will include the applicant’s reasons, based on project-specific information.

Capital (2022$)

Annual Cost (2022$)

$1,100,000

Note: The capital cost of this plan includes costs to implement design features and BMPs.

Note: The applicant does not anticipate costs associated with this PME postconstruction.

Within 90 days of the completion of project construction, the applicant will file with FERC – in the form of photographs or as-built drawings – documentation of completion of the above measures. The applicant will consult with BLM and FERC staff, as appropriate, to identify reasonable BMPs that will be implemented for visual resource impacts.

February 2023 (Revised July 2023) | 370

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures This PM&E measure is contingent on the potential need for additional lodging for non-local workers during the construction period. The peak non-local workforce during construction is expected to be approximately 900 persons, and workers are not expected to bring families with them during construction. The available data indicates that there may be a shortage of available long-term housing units in the county. As noted in Section 3.12.1.2 of the FLA, recent data from the U.S. Census Bureau indicate that there are almost 700 vacant housing units in White Pine County; however, only 51 of these are currently available for rent and another 194 are available for seasonal, recreational, or occasional use. The county has identified developing additional housing as a priority to attract residents and businesses; therefore, the stock of available housing may increase by the time construction begins.

Temporary Housing

In an April 25, 2023 letter to the FERC, the City of Ely and NNR state that existing temporary lodging would not be sufficient, as current demand from travelers, visitors to the railroad and Great Basin National Park, and other recreationists and tourists cannot currently be met. On July 13, 2023, FERC issued an Additional Information Request (AIR) that included specific requests related to temporary worker housing; the difference between work camps and RV parks; and the size, locations, and public utilities each would require. The applicant has initiated an in-depth investigation, which includes polling and interviews, into RV parks within a 50-mile radius of the proposed project location that have the potential to accommodate worker housing. As part of the investigation, the applicant is seeking to understand and catalog the existing average number of vacancies, and potential plans for expansion (both timing and capacity).

Entities/Consultation Plan Coordinating Entities: • WPW • City of Ely • NNR Foundation • Other Key Local Landowners • FERC Staff Consultation Plan: Following FERC’s issuance of a Notice of Ready for Environmental Analysis for the proposed project, the applicant will begin discussions with White Pine County to formulate a development agreement that stipulates a special use permit to address, among other items, a plan for temporary housing during construction of the project. The final development agreement will be filed with FERC upon execution.

Capital (2022$)

Annual Cost (2022$)

Note: The capital cost is currently estimated as $0 because this PME is contingent. This estimate will be updated when more information is available.

Note: The applicant does not anticipate costs associated with this PME postconstruction.

February 2023 (Revised July 2023) | 371

Final Draft

PM&E Number

Final License Application – Exhibit E White Pine Pumped Storage Project Name of Plan/PM&E

Description of Protection, Mitigation, and Enhancement (PM&E) Measures A draft Historic Properties Management Plan (HPMP) was submitted with the FLA; however, the Cultural Resources Study Report on which the draft HPMP was based does not accurately reflect the project footprint (which encompasses the Project Boundary). On July 12, 2023, the applicant submitted updated direct and indirect Area of Potential Effects (APE) boundaries to the Nevada State Historic Preservation Office (Nevada SHPO). Section 106 consultation with the Nevada SHPO and local Tribes is still underway and scheduled to be continued through 2024. The applicant expects to hear back from the Nevada SHPO by August 11, 2023 (30 days after letter). The applicant will ensure additional cultural resources inventory of the updated direct APE and assessment of the corresponding updated APE. Once the applicant has received the Nevada SHPO’s concurrence on the updated APE, any newly added or modified portions of the direct APE will be inventoried for cultural resources. Surveys for the remaining direct APE footprint and corresponding Class I Surveys, as well as the complete indirect APE literature review and corresponding fieldwork are expected to be completed and ready for SPHO review at the end of this year. The inventory will include reporting and evaluation of National Register of Historic Places (NRHP) eligibility for all sites identified within the APE. The applicant will revise and update the draft HPMP to reflect the results of the new inventory and assess adverse effects for historic properties in the updated APE. The applicant will provide the revised draft HPMP to Section 106 consulting parties for comment and will address and track consulting party comments in a comment matrix.

Historic Properties Management Plan (HPMP)

The applicant will provide FERC with a final HPMP prior to license issuance. The development of the final HPMP would follow pertinent guidance documents, namely Guidelines for the Development of Historic Properties Management Plans for FERC Hydroelectric projects issued by FERC and the Advisory Council on Historic Preservation (ACHP) in 2002 (FERC and ACHP 2002) and would utilize the HPMP developed for the Bucks Creek Hydroelectric Relicensing (FERC Project No. 619) as a guideline. The final HPMP will be implemented to manage the effects on historic properties of activities associated with constructing, operating, and maintaining the proposed project. The final HPMP would contain, at a minimum, the following information: • • • • • • • • • • •

A statement of purpose; Overview of proposed facilities; Discussion of the APE and properties identified within; Summary of consultation with Native American Tribes and Other Interested Parties, SHPO, and other Federal agencies; Summary of the historic contexts; Summary of the ethnographic, archaeological, and architectural history surveys; National register evaluations of historic properties within the APE; Discussion of potential project effects; Proposed general management measures and specific archaeological management measures; Implementation procedures and responsibilities; and Ongoing consultation, project review requirements, and implementation protocols.

Entities/Consultation Plan Coordinating Entities: • WPW • Nevada SHPO • NNR Foundation • Ely Shoshone Tribe • Duckwater Shoshone Tribe • Confederated Tribes of the Goshute Reservation • Te-Moak Tribe of Western Shoshone • ACHP • FERC Staff

Capital (2022$)

Annual Cost (2022$)

$600,000

$5,000

Note: Capital costs for this PM&E reflect plan development and implementation measures associated with mitigation for impacts to cultural and historic properties.

Note: The annual cost in the table reflects an estimated level of effort to maintain and update the HPMP as necessary.

Consultation Plan: The applicant has initiated consultation with the Nevada SHPP and Tribes regarding the HPMP. The HPMP will include documentation of consultation, copies of comments and recommendations on the completed RBPP after it has been prepared and provided to the agencies, and specific descriptions of how the agencies’ comments are accommodated by the HPMP. The applicant will allow a minimum of 30 days for the agencies to comment and to make recommendations before filing the HPMP with FERC. The applicant anticipates FERC will initiate the process of developing a Programmatic Agreement to include implementation of the HPMP after receipt of the final HPMP.

February 2023 (Revised July 2023) | 372

11 10

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PJC

CHAP

PJO PJO

PJC

PJO

XER Rip

CERCO

PJO

CHAP

PJO

XER

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PJO

CERCO

ROAD

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XER

CHAP PJO

PJO

CHAP

18 14 15

22 MAP LABEL LEGEND

CHAP

23 No Data

CHAP - Great Basin Semi-Desert Chaparral

Rip - Inter-Mountain Basins Montane Riparian System

ROAD - Hardscape Road

PJC - Great Basin Pinyon-Juniper Woodland - Closed

XER - Great Basin Xeric Mixed Sagebrush Shrubland

CERCO - Inter-Mountain Basins Curl-Leaf Mountain Mahogany Woodland

PJO - Great Basin Pinyon-Juniper Woodland - Open

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1,000 Feet

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CHAP

PJC PJO

PJO

CERCO

PJO

XER

PJO XER

STEP

CHAP

PJO 16

CHAP

CERCO

PJO

PJO 14

CERCO

PJO

CHAP

XER PJO

17N 64E PJO

PJC

PJO

CHAP

SAV XER

SAV

CERCO

PJO

MAP LABEL LEGEND

No Data

PJC - Great Basin Pinyon-Juniper Woodland - Closed

STEP - Inter-Mountain Basins Montane Sagebrush Steppe

CERCO - Inter-Mountain Basins Curl-Leaf Mountain Mahogany Woodland

PJO - Great Basin Pinyon-Juniper Woodland - Open

XER - Great Basin Xeric Mixed Sagebrush Shrubland

CHAP - Great Basin Semi-Desert Chaparral

SAV - Great Basin Xeric Mixed Sagebrush Shrubland - Juniper Savannah

PROJECT BOUNDARY

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XER

XER 32

XER - Great Basin Xeric Mixed Sagebrush Shrubland

PROJECT BOUNDARY

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1,000 Feet

2,000

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XER 25

17N 64E

17N 63E

XER

XER - Great Basin Xeric Mixed Sagebrush Shrubland

PROJECT BOUNDARY

PROJECT FOOTPRINT

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1,000 Feet

2,000

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SAV XER

NNG

SAV

17N 64E

XER

17N 63E

XER

29 30

No Data MAP LABEL LEGEND

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XER - Great Basin Xeric Mixed Sagebrush Shrubland

NNG - Invasive Annual Grassland SAV - Great Basin Xeric Mixed Sagebrush Shrubland - Juniper Savannah

PROJECT BOUNDARY

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2,000

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STEP 07

GRASS

ROAD XERDIST

MIXSCRUB

NNG

XERDIST

17N 64E

GRASS

NNG

NNG XERDIST

XER

RAIL

ROAD

17N 63E

DIST

DEV

18 XERDIST

DEV

RAIL ROAD

PJO 15

MIXSCRUB 13

XER

RAIL

NNG

SAV

XER

16 XER

PJO

XER

PJC

PJO

XER

SAV SAV

SAV

XER NNG

MAP LABEL LEGEND

Service Layer Credits: USGS The National Map: National Boundaries Dataset, 3DEP Elevation Program, Geographic Names Information System, National Hydrography Dataset, National Land Cover Database, 21 National Structures Dataset, and National Transportation Dataset; USGS Global

No Data

DEV - Developed, Medium - High Intensity

MIXSCRUB - Inter-Mountain Basins Mixed Desert Scrub

PJO - Great Basin Pinyon-Juniper Woodland - Open

XER - Great Basin Xeric Mixed Sagebrush Shrubland

ROAD - Hardscape Road

DIST - Disturbed, Non-Specific

NNG - Invasive Annual Grassland

SAV - Great Basin Xeric Mixed Sagebrush Shrubland - Juniper Savannah

XERDIST - Great Basin Xeric Mixed Sagebrush Shrubland - Disturbed

RAIL - Railroad

GRASS - Inter-Mountain Basins Semi-Desert Grassland

PJC - Great Basin Pinyon-Juniper Woodland - Closed

STEP - Inter-Mountain Basins Montane Sagebrush Steppe

PROJECT BOUNDARY

PROJECT FOOTPRINT

PLSS TOWNSHIP / RANGE PLSS SECTION

1,000 Feet

2,000

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18N 63E

18N 64E 31

PJO BIG

17N 64E

XER

XER XERBIG PJO

XER

NNG

BIGDIST

XERBIG

ROAD

MIXSCRUB

XER

XERBIG

ROAD XER

XER

17N 63E

XERDIST

XER XER

NNG

XERDIST

GRASS

NNG MIXSCRUB

DEV DIST

XER

18 13

STEP

GRASS

ROAD

MIXSCRUB

XERBIG

SALT

16 18

DEV

RAIL

XER

ROAD NNG

MIXSCRUB

XERDIST

XER

RAIL

SAV

NNG

MAP LABEL LEGEND

19 Service Layer Credits: USGS The National Map: National Boundaries Dataset, 3DEP XER Elevation Program, Geographic Names Information System, National Hydrography Dataset, National Land Cover Database, National Structures Dataset, and National Transportation Dataset; USGS Global 29

No Data

BIG - Inter-Mountain Basins Big Sagebrush Shrubland

GRASS - Inter-Mountain Basins Semi-Desert Grassland

SALT - Saltlover Field

XERBIG - Great Basin Xeric Mixed Sagebrush Shrubland - Big Sagebrush Shrubland

ROAD - Hardscape Road

BIGDIST - Inter-Mountain Basins Big Sagebrush Shrubland - Disturbed

MIXSCRUB - Inter-Mountain Basins Mixed Desert Scrub

SAV - Great Basin Xeric Mixed Sagebrush Shrubland - Juniper Savannah

XERDIST - Great Basin Xeric Mixed Sagebrush Shrubland - Disturbed

RAIL - Railroad

DEV - Developed, Medium - High Intensity

NNG - Invasive Annual Grassland

STEP - Inter-Mountain Basins Montane Sagebrush Steppe

AG - Agriculture

DIST - Disturbed, Non-Specific

PJO - Great Basin Pinyon-Juniper Woodland - Open

XER - Great Basin Xeric Mixed Sagebrush Shrubland

PROJECT BOUNDARY

PROJECT FOOTPRINT

PLSS TOWNSHIP / RANGE PLSS SECTION

2,000 Feet

4,000

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PJC

18N 63E

18N 62E PJO 34

XER PJC

XER

PJC 04

PJO

PJC

XER BIG

17N 62E 10

17N 63E

XER XERBIG PJO

XERBIG 15

MAP LABEL LEGEND

XER

NNG

BIGDIST - Inter-Mountain Basins Big Sagebrush Shrubland - Disturbed

PJC - Great Basin Pinyon-Juniper Woodland - Closed

XER - Great Basin Xeric Mixed Sagebrush Shrubland

MIXSCRUB - Inter-Mountain Basins Mixed Desert Scrub

PJO - Great Basin Pinyon-Juniper Woodland - Open

XERBIG - Great Basin Xeric Mixed Sagebrush Shrubland - Big Sagebrush Shrubland

BIG - Inter-Mountain Basins Big Sagebrush Shrubland

NNG - Invasive Annual Grassland

SALT - Saltlover Field

XERDIST - Great Basin Xeric Mixed Sagebrush Shrubland - Disturbed

PROJECT FOOTPRINT

PLSS SECTION

2,000 Feet

4,000

XERBIG

MIXSCRUB SALT

Service Layer Credits: USGS The National Map: National Boundaries Dataset, 3DEP XER ROAD XERBIG Elevation Program, Geographic Names BIGDIST Information System, National Hydrography Dataset, National Land Cover Database, 15 National Structures Dataset, and National Transportation Dataset; USGS Global

AG - Agriculture

PLSS TOWNSHIP / RANGE

ROAD - Hardscape Road

PROJECT BOUNDARY

XER

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22 SERV

XER

XERBIG

SERV

ROCK

PJC

18N 61E

PJC

ROAD PJV

PJC

XER

PJC

XER

18N 62E

PJV

XERBIG

PJV 26

BIG

29 30 PJC

PJO 34

MAP LABEL LEGEND

17N 61E

PJC - Great Basin Pinyon-Juniper Woodland - Closed

ROCK - Inter-Mountain Basins Cliff and Canyon

ROAD - Hardscape Road

PJO - Great Basin Pinyon-Juniper Woodland - Open

SERV - Great Basin Xeric Mixed Sagebrush Shrubland - Serviceberry Shrubland

BIG - Inter-Mountain Basins Big Sagebrush Shrubland

PJV - Great Basin Pinyon-Juniper Woodland - Very Open

XER - Great Basin Xeric Mixed Sagebrush Shrubland

PLSS TOWNSHIP / RANGE PLSS SECTION

17N 62E

No Data

PROJECT FOOTPRINT

PROJECT BOUNDARY

Service Layer Credits: USGS The National XER Map: National Boundaries Dataset, 3DEP Elevation Program, Geographic Names Information System, National Hydrography Dataset, National Land Cover Database, National Structures Dataset, and National Transportation Dataset; USGS Global 02 03

PJC

XERBIG - Great Basin Xeric Mixed Sagebrush Shrubland - Big Sagebrush Shrubland

2,000 Feet

4,000

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18N 60E 23

PJC

PJO 20

XER

21 PJC

18N 61E SERV

PJV

PJC

XER

XERBIG

SERV

ROCK

30 26

No Data

PJO - Great Basin Pinyon-Juniper Woodland - Open

SERV - Great Basin Xeric Mixed Sagebrush Shrubland - Serviceberry Shrubland

ROAD - Hardscape Road

PJV - Great Basin Pinyon-Juniper Woodland - Very Open

XER - Great Basin Xeric Mixed Sagebrush Shrubland

PJC - Great Basin Pinyon-Juniper Woodland - Closed

ROCK - Inter-Mountain Basins Cliff and Canyon

XERBIG - Great Basin Xeric Mixed Sagebrush Shrubland - Big Sagebrush Shrubland

PROJECT BOUNDARY

PROJECT FOOTPRINT

PLSS TOWNSHIP / RANGE PLSS SECTION

2,000 Feet

PJC

ROAD

PJC

XER

PJC

Service Layer Credits: USGS The National Map: National Boundaries Dataset, 3DEP Elevation Program, Geographic Names Information System, National Hydrography 36 35 Dataset, National Land Cover Database, National Structures Dataset, and National Transportation Dataset; USGS Global

PJO

MAP LABEL LEGEND

PJC

PJV

PJO

4,000

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PJO

18N 60E

PJC

PJO 33

18N 61E

PJV PJC

PJO

XER DIST PJV

17N 60E 09

MAP LABEL LEGEND

XER

No Data

PJO - Great Basin Pinyon-Juniper Woodland - Open

DIST - Disturbed, Non-Specific

PJV - Great Basin Pinyon-Juniper Woodland - Very Open

PJC - Great Basin Pinyon-Juniper Woodland - Closed

XER - Great Basin Xeric Mixed Sagebrush Shrubland

PROJECT BOUNDARY

PROJECT FOOTPRINT

PLSS TOWNSHIP / RANGE PLSS SECTION

17N 61E

Service Layer Credits: USGS The National Map: National Boundaries Dataset, 3DEP Elevation Program, Geographic Names Information System, National Hydrography Dataset, National Land Cover Database, 15 National 16 Structures Dataset, and National Transportation Dataset; USGS Global

2,000 Feet

4,000

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£ ¤

893

¬ «

Triple B Habitat Management Area

East Creek Campground

Æ Bassett Lake l

¬ «

ll Va ey

F ! 50

Heusser Mountain

1 mi

£ ¤

5 mi

¬ « F

È Ely !

KOP 7 Saxton Peak

F !

KOP 8 Rib Hill

10 mi

F !

Shellback Wilderness

£ ¤ !F

Nevada Northern Railway Museum and Depot

Æ ?

KOP 10 " - State Route 486

High Schells Wilderness

KOP 5 NNR Star Platform

KOP 6 Train near Nevada Northern Railway Museum

Duck Creek Range

Steptoe Valley WMA

Ward Mountain Campground and Picnic Area

486

¬ «

" 9

15 mi

Steptoe Creek

WATERBODY US ROUTE

Project Location

STATE ROUTE

PROJECT BOUNDARY

Service Layer Credits: Source: Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, 893 IGN, and the GIS User Community USGS The National Map: National Boundaries Dataset, 3DEP Elevation Program, Geographic Names Information

¬ «

KEY OBSERVATION POINT (KOP) VISUAL STUDY AREA BUFFER (1, 5, 10, 15 MILES)

VISUAL STUDY AREA VISIBLE

NOT VISIBLE PATH: \\BIL-SRV02\BILDATA\GIS\PROJECTS\GRIDFLEX\WHITEPINE\MAP_DOCS\MXD\FERC AIRS 2023\VIEWSHED_KOPS_FERC-A-90_JULY2023.MXD - USER: JOBAIRD - DATE: 7/6/2023

£ ¤

Æ l

£ ¤

£ ¤ PROJECT FOOTPRINT

Cave Lake Campground

Cave Lake

Æ l

Bald Mountain Wilderness

Mt. Moriah Wilderness

" 9 Comins Lake

White Pine Range Wilderness

Berry Creek Campground

F ! KOP 4 - NNR

490

Copper Flat

" " 5 9 5

KOP 3 Highway 93 & 347th North

Pancake Habitat Management Area

McGill

KOP 2 CountyRoad 28

Pancake Habitat Management Area

Timber Creek Campground Timber Creek Group Picnic Site

F !

i th

Bristlecone Wilderness

£ ¤

" 5

486

F !

KOP 9 Highway 50

Bird Creek Campground

F !

KOP 1 Highway 93 & State Route 486

" 9

MANAGED LAND

WILDLIFE MANAGEMENT AREA

BLM - WILD HORSE AND BURRO MANAGMENT AREA WILDERNESS AREA

RECREATION FACILITY

" 9

CAMPGROUND

l " 5

PICNICKING

È ! ?

FISHING HORSE RIDING MUSEUM

I Miles

VIEWSHED ANALYSIS, KOPS, AND RECREATION 5

WHITE PINE WATERPOWER, LLC Page 1 of 1

Figure 95-1

Figure 95-2

KOP 1: Highway 93 & State Route 486 – Current Conditions

KOP 1: Highway 93 & State Route 486 – Photo-simulation Project Features: • • •

Lower Reservoir (nearly imperceptible), Switchyard (nearly imperceptible), and Transmission Line (nearly imperceptible).

Figure 95-3

Figure 95-4

KOP 2: County Road 28– Current Conditions

KOP 2: County Road 28– Photo-simulation Project Features: • • •

Lower Reservoir (visible, weak contrast), Switchyard (nearly imperceptible), and Transmission Line (visible, weak contrast).

Figure 95-5

Figure 95-6

KOP 3: Highway 93 & 347th North – Current Conditions

KOP 3: Highway 93 & 347th North – Photo-simulation Project Features: •

Lower Reservoir (visible, strong contrast).

Figure 95-7

Figure 95-8

KOP 4: Nevada Northern Railway (NNR)– Current Conditions

KOP 4: Nevada Northern Railway (NNR)– Photo-simulation Project Features: • •

Lower Reservoir (imperceptible) and Transmission Line (imperceptible).

Figure 95-9

Figure 95-10

KOP 5: Nevada Northern Railway Star Pla�orm (night)– Current Conditions

KOP 5: Nevada Northern Railway Star Pla�orm (night)– Photo-simulation Project Features: • • •

Lower Reservoir (nearly imperceptible), Switchyard (nearly imperceptible) and Transmission Line (visible, weak contrast).

Figure 95-11

Figure 95-12

KOP 6: Train near Nevada Northern Railway Museum – Current Conditions

KOP 6: Train near Nevada Northern Railway Museum – Photo-simulation Project Features: • • •

Upper Reservoir (nearly imperceptible), Lower Reservoir (nearly imperceptible), and Transmission Line (nearly imperceptible).

Figure 95-13

Figure 95-14

KOP 7: Saxton Peak – Current Conditions

KOP 7: Saxton Peak – Photo-simulation Project Features: •

Upper Reservoir (nearly imperceptible).

Figure 95-15

Figure 95-16

KOP 8: Rib Hill – Current Conditions

KOP 8: Rib Hill – Photo-simulation Project Features: • • • •

Upper Reservoir water surface (nearly imperceptible), Upper Reservoir (nearly imperceptible), Lower Reservoir (nearly imperceptible), and Transmission Line (nearly imperceptible).

Figure 95-17

Figure 95-18

KOP 9: Highway 50 – Current Conditions

KOP 9: Highway 50 – Photo-simulation Project Features: •

Transmission Line (visible, strong contrast).

Figure 95-19

Figure 95-20

KOP 10: State Route 486 – Current Conditions

KOP 10: State Route 486 – Photo-simulation Project Features: •

Upper Reservoir (nearly imperceptible).

White Pine County Public Lands Policy Plan

2018

2018 White Pine County Public Lands Policy Plan Prepared by:

The White Pine County Public Land Users Advisory Committee Jacob Carter, Chair Craig Baker Curt Leet Mark Tefft Bill Wilson In collaboration with: Emily Willard, Secretary

Adopted by the White Pine County Public Lands Users Advisory Committee: July 10, 2018 Adopted by the White Pine County Board of County Commissioners: October 24, 2018

2018 White Pine County Public Lands Policy Plan Table of Contents I.

PLAN BACKGROUND………………………………………………………….. Location…………………………………………………………………………..

Page 1 1

II.

PLAN PURPOSE…………………………………………………………………

III.

PROCESS…………………………………………………………………………

IV.

ENVIRONMENT………………………………………………………………… Climate……….………………………………………………………………….. Geology…..……………………………………………………………………… Geographic Features..………………………………………………………… Hydrology……………………………………………………………………….. Vegetation………………………………………………………………………. Wildlife……………………………………………………………………………

6 6 8 8 9 10 13

CULTURE AND HISTORY…………………………………………………….. Recreation………………………………………………………………………. Population………………………………………..…………………………….. Economics.………………………………………..……………………………..

16 16 16 19

VI. POLICIES……………………………………………………………………….. 19 1. Plan Implementation, Agency Coordination and Local Voice……… 19 2. Management of Public Lands………………..…………………………….. 22 3. Federal Land Transactions...………………………………………………. 23 4. Agriculture and Livestock Production………………….……………….. 26 5. Forestry……………………..………….………………………………………. 27 6. Wild Horses………………………………………..…………………………… 28 7. Mineral Resources…..………………………………………..……………… 29 8. Wilderness………………………………………..……………………………. 30 9. Wildlife...…………………………………………..…………………………… 32 10. Public Safety…………………………………………………………………… 33 11. Air Quality….…………………………………………………………………… 34 12. Cultural Resources..………………………………………………………….. 34 13. Recreation and Open Space.………………………………………………. 36 14. Wetlands, Riparian Areas, Waters of the US……..…….……………… 37 15. Fire Management..………………………………………..………………….. 38 16. Noxious Weeds and Invasive Species.……………..…………………… 39 17. Off Highway Vehicles….…………………………………………………….. 40 18. Military Operations…..………………………………..…………………….. 41 19. Water Resources……………………………………………………………… 41 SOURCES CITED………………………………………………………………………… 42 INDEX … … … … … … … … … … … … … . . … … … … … … … … … … … … … … … … … … … 43

LIST OF TABLES AND FIGURES Figure 1-Location…………………………………………………………….. Figure 2-Land Status…….………………………………………………….. Table 1-Land Status Acres.…………………………………………………. Figure 3-Ely, Nevada Precipitation…………………..………………….. Figure 4-General Vegetation Types..…………………………………….. Table 2- White Pine County Big Game Populations………………….. Figure 5-NDOW Management Unit Map………………………………… Table 3-Gastropods Native to White Pine County……………………. Table 4-White Pine County Population………………………………….. Table 5-Populations of Cities/Towns in White Pine County…….…. Table 6-Income, White Pine County & Nevada……………………….. Table 7-White Pine County Annual Population Trend……………….. Figure 6-White Pine County Labor Force……………………………….. Table 8-Wilderness Areas in White Pine County……………………...

1 2 3 7 12 13 14 15 17 17 18 18 19 31

PLAN BACKGROUND

Location White Pine County is in east central Nevada and is bordered on the east by Utah, Elko County on the north, Eureka County to the west, and Lincoln and Nye Counties to the South. Ely, the County seat, is located to the west and south of the County’s center at the cross roads of US Highways 50 and 93. Reno is 320 miles to the west, Las Vegas is 250 miles to the south, and Salt Lake City is 250 miles to the northeast. Ely is the largest population center in a 150-mile radius serving the White Pine County communities of McGill, Ruth, Lund, and Baker; Eureka, 80 miles west; Pioche (Lincoln County), 129 miles south; and Ibapah, Garrison, and Goshute on the Nevada/Utah border approximately 100 miles east. Recent growth in southern Utah makes St. George (population 72,897) 217 miles from Ely and Cedar City (population 28,857) 200 miles from Ely the closest population centers for retail shopping and medical services (United States Census Bureau, 2010 Census). They join Elko, (population 18,297) 180 miles north and west; Fallon (population 8,606) 250 miles west; and Twin Falls, Idaho (population 44,125) 255 miles north as the closest communities providing larger business and service centers (United States Census Bureau, 2010 Census). The County is roughly square in shape, measuring approximately 104 miles north to south and 96 miles east to west. It covers 8,941 square miles making it larger than the state of Massachusetts. The County ranks fifth in size in Nevada, covering 8.1 percent of the state’s total land area.

Figure 1 – Location

Nevada is a state that is comprised predominately of federally-managed lands. Approximately 86.5% of all lands in the state are under the jurisdiction of federal agencies with the majority percentage under Bureau of Land Management (BLM) jurisdiction. The US Forest Service is secondary, followed by the Department of Defense, National Park Service, US Fish and Wildlife Service, Bureau of Indian Affairs and Bureau of Reclamation. Additional lands are managed by the State of Nevada. This land ownership pattern leaves very few areas under private control for economic development and community expansion. White Pine County is no exception to this land use pattern. Since most of the county is under federal management, little private land exists for community expansion. However, the White Pine County Conservation, Recreation, and Development Act of 2006 authorizes the BLM to dispose of 45,000 acres in White Pine County. “The Ely District Office and the County will jointly select the parcels of land to offer for sale” (BLM, 2008). Recent sales include approximately 6,265 acres were transferred to the state to augment the Steptoe Valley Wildlife Management area, 658 acres to augment the Ward Charcoal Ovens State Park, 1,550 acres for Ely Airport Expansion, and 200 acres for the White Pine County Industrial Park Expansion (BLM, 2008). These recent federal land transfers within the County have not yet been recorded and these statistics are not included in Figure 2 or Table 1 (Hankins, 2018). An additional 18,719 acres are available for potential disposal within White Pine County (BLM, 2008).

Figure 2 – Land Status

Table 1 – Land Status (Acres) Land Lands Administered by Federal Agencies BLM Forest Service National Park Service Fish and Wildlife Service

Acres

Land Area in Percent

5,439,707 4,513,533 761,568 77,128 13,058

95.6 79.2 13.4 1.35 0.23 minima

Tribal

8 69,766

State

18,344

0.27

Local Government/Private

239,612

4.21

5,693,016

100.0

Total Acres

1.22

Source BLM 2007. Note: Acreage Statistics total based on GIS database. Note: These figures include the expansion of Cave Lake State Park (+2,960 acres), Ward Charcoal Ovens State Park (+650 acres) and Steptoe Valley Wildlife Management Area (+6,281 acres)

II.

PLAN PURPOSE

The purpose of the Plan is to: 

Detail White Pine County’s vision and strong policy voice concerning public lands.



Define White Pine County’s public land-related issues and needs.



Provide locally developed land management policies that enable the federal land management agencies to better understand and respond in a positive fashion to the concerns and needs of White Pine County in a collaborative process.



Increase the role White Pine County has in determining the management of the federal lands.



Provide an opportunity to positively address federal land use management issues directly and thereby offer a proactive alternative rather than an after-the-fact response.



Encourage public comment and involvement.

The initial White Pine County Public Lands Policy Plan (Plan) was developed between 1983 and 1984 as part of a state-wide effort resulting from the passage of Senate Bill 40. Under SB40, the State Land Use Planning Agency section of the Nevada Division of State Lands (SLUPA) was directed by the 1983 State Legislature to: 

“Prepare, in cooperation with appropriate state agencies and local governments throughout the state, plans or policy statements concerning the use of lands in Nevada which are under federal management.”

The Plan was revised in 2007 and incorporated into the White Pine County Master Plan. The 2018 Plan represents a review of existing and emerging public lands issues that are of importance to White Pine County as it works with federal agencies under the National Environmental Policy Act (NEPA) and other public processes. Within the Plan are descriptions of issues and opportunities relating to public lands and how best to work collaboratively with the federal planning partners, most notably Bureau of Land Management (BLM), U.S. Forest Service (USFS), Bureau of Reclamation, U.S. Fish and Wildlife Service (USFWS) and the Bureau of Indian Affairs. The Plan enables the federal land management agencies to better understand and respond to the concerns and needs of White Pine County. Planning, effective communication and coordination by Nevada’s governments, in concert with its citizens, can establish a set of policies for the proper use of these lands and to take advantage of the “consistency” language in Section 202(c)(9) of the Federal Land Policy and Management Act (FLPMA). Section 202(c)(9) governs BLM Planning and directs the BLM to give consideration to appropriate state, local, and tribal lands in the development of land use plans for federal lands. The BLM is to provide for meaningful public involvement of state and local government officials in the development of land use plans, regulations and decisions for federal lands. The BLM will review each Resource Management Plan (RMP) and proposed federal action for consistency with the White Pine County Public Lands Policy Plan and will attempt to make the RMPs and proposed actions compatible with the Plan to the extent that the Secretary of the Interior finds consistent with federal law and the purpose of FLPMA. Forest Service Regulations for Land Management Planning and for implementing the National Environmental Policy Act (NEPA) requires that the Forest Service determine the consistency of any project proposal with state and/or local laws and plans.



III.

The agency is required to describe any inconsistencies and the extent to which the agency would reconcile its proposal with the state/local laws and plans. This consistency review is also provided for by the Council of Environmental Quality (CEQ) regulations (40 CFR 1506.2(d)) developed to implement NEPA.

PROCESS

The following is a summary of the process followed to adopt the 2007 Plan: The White Pine County Public Land Users Advisory Committee (PLUAC) reviewed existing policies and issues with the assistance of the State Land Use Planning Agency in 2006 and early 2007 during publicly noticed meetings in Ely. The final Draft Plan was presented at the April 3, 2007 PLUAC meeting in Ely. The PLUAC held an official public review meeting on May 8, 2007 and recommended approval of the Plan. The Regional Planning Commission held a public hearing on June 6, 2007 and recommended approval of the Plan to the White Pine County Board of Commissioners. The White Pine County Board of Commissioners held a public hearing on June 13, 2007 and adopted the Plan. The PLUAC approved an updated Plan in 2012 and submitted these updates to the White Pine County Board of Commissioners for adoption. IV.

ENVIRONMENT 

Climate

White Pine County has a semi-arid climate and the Basin and Range topography results in a cold desert climate with seasonal shifting of the sub-tropical highs influential less than six months of the year. Interior locations are dry because of their distance from moisture sources or their locations in rain shadow areas on the lee side of mountain ranges. This combination of interior location and rain shadow positioning produces the cold desert. The dryness, generally clear skies, and sparse vegetation lead to high heat loss and cool evenings (Intertech Services Corporation and Buqo, Thomas S.). Average annual precipitation for Ely from 1987 to 2017 was 9.39 inches, and 9.66 inches from 2007 to 2017 (NOAA, 2018). Precipitation for Ely, Nevada between July 2017 and June 2018 was 7.7 inches (196.4 millimeters) with a deficit of 1.5 inches

(38.9 millimeters). Figure 3 – Ely, Nevada Precipitation from July 2017 through June 2018 White Pine County’s average annual precipitation is 9.71 inches, the average for the state of Nevada (which is the driest in the nation) (NOAA, 2018). The average annual precipitation increases with altitude: between 5,000 and 6,000 feet, it is less than 8 inches per year, between 6,000 and 7,000 feet it is 8 to 12 inches, between 7,000 and 8,000 feet, 12 to 15 inches, between 8,000 and 9,000 feet, 15 to 20 inches, and above 9,000 feet, more than 20 inches (Hose, Richard K. and Blake M.C. Junior). At higher elevations snow accumulates to considerable depths. Much of the snowmelt irrigates nearby valleys. Drought is common and expected. Historically, critical water sources in the County respond to drought conditions and climate changes with approximately four years lag time (Intertech Services Corporation and Buqo, Thomas S.). In White Pine County’s mid-latitude climate, the average potential evaporation rate exceeds the average annual precipitation, with actual average evaporation ranging from 45 to 51 inches. On an annual basis, as much as 90 to 95 percent of the total annual precipitation is lost through evaporation and transpiration; only an estimated 5 to 10 percent recharges the ground water regime (Intertech Services Corporation and Buqo, Thomas S.). In western White Pine County, summers are hot, especially at the lower elevations

and winters are cold. The length of the growing season ranges from about 100 to 120 days with the shorter season in the western part of the County (Intertech Services Corporation and Buqo, Thomas S.). The mean annual temperature (Fahrenheit) in Ely is 45 degrees, the mean annual low is 28, and the mean annual high is 62 degrees (Intellicast.com, 2018). The lowest temperature on record for Ely is –30 on February 6th, 1989 (Intertech Services Corporation and Buqo, Thomas S.), and the highest recorded temperature was recorded in Ely on July 12th, 2002 at 101 degrees (Intellicast, 2018). Mean annual precipitation for Ely, Nevada from 1987 through 2017 was 9.39 inches, and 9.66 inches from 2007 through 2017 (NOAA, 2018). In Ely, Nevada, average temperatures are increasing 0.1-degree Fahrenheit per decade and average precipitation is decreasing by approximately 0.1 inches per decade (NOAA, 2018). 

Geology

White Pine County is made up of the elongate north-trending mountain ranges and generally flat-bottomed valleys that typify the Basin and Range physiographic province. The dominant rock types found within the County include quartzite, limestone, dolomite, sandstone, siltstone, and shale. The area was affected by two major tectonic events; the younger of the two produced the elongate fault-block mountain ranges and flat-bottomed valleys that characterize the region today. The older event produced a variety of structural features including high-angle faults and low-angle faults, and large amplitude folds (Hose, Richard K. and Blake M.C. Junior). The geologic units of White Pine County may be grouped into seven categories: 1) the valley-fill deposits, comprising mixtures of gravel, sand, silt and clay that include the alluvial and playa deposits; 2) younger volcanic rocks, comprising ash-flow tuff and basalt; 3) older volcanic rocks, comprising dacite, latite, andesite, and tuffs; 4) Triassic sediments, comprising freshwater limestone, conglomerate, sandstone, siltstone, and tuff; 5) intrusive rocks, comprising granitic plutons; 6) upper Paleozoic carbonate rocks, comprising predominantly limestone and dolomite, but with inter-bedded shale and siltstone aquitards; and 7) lower Paleozoic and older rocks, comprising predominately clastic rocks including shale and quartzite, but with some interbedded carbonate units (Intertech Services Corporation and Buqo, Thomas S.). 

Geographic Features

White Pine County is typical of the Basin and Range topography. The landscape is dominated by north-south mountain ranges, 8,000 to 12,000 feet in elevation, which are separated from down-dropped alluvial filled valleys along major north-trending “basin and range” normal faults. Strata in the ranges have been subject to intense folding and thrust faulting during many earlier tectonic events. Intrusions of granite

rocks cut across the older, complex geological structures. Early deposits of marine conglomerate, sandstone, limestone, and dolomite occur throughout the County. This carbonate rock contains arches, rock shelters, and highly decorated caves. From west to east, the major ranges are the Diamond Mountains, the White Pine Range, the Butte Mountains, the Egan Range, Cherry Creek Range, Schell Creek Range, the Snake Range, and the Kern Mountains. The highest point is Wheeler Peak in the Snake Range at 13,061 feet in elevation. Natural gaps or passes in the mountain ranges are important in allowing cross-country transportation. Between the mountain ranges are long narrow valleys, which range from 5,000 to 7,000 feet in elevation. The valleys are the sites of transportation corridors, agricultural activity, industrial development and urban centers. The major valleys are: Newark Valley: On the western edge of the county, irrigated by Cole and Newark Creeks and several springs Steptoe Valley: Between the Egan and Schell Creek ranges is one of the longest valleys in the United States at over 100 miles extending from Elko County on the north through the entire length of White Pine County. The valley’s water is supplied by Duck Creek and Steptoe Creek. It houses the County’s major urban and industrial development as well as 70,000 acres of tillable land. Spring Valley: Between the Schell Creek and Snake ranges is twelve miles wide and almost one hundred miles long. Its northern portion has a number of small creeks, which provide irrigation water for the valley’s cropland Snake Valley: Lies on the eastern border of the county, sloping to the south and east, its climate is the warmest in White Pine County 

Hydrology

The majority of White Pine County is located within the Great Basin, meaning that the water within this physiographic region does not flow to the ocean; instead it is deposited entirely in underground aquifers. Hydrology of the area can be described in the surface water resources and the ground water resources, the latter of which less information is known. The major bodies of water in the County are four reservoirs:   

Cave Lake (32 acres) Source: Nevada State Parks, 2018 Comins Lake (410 acres, maximum pool) Source: NDOW, 2018 Bassett Lake (77 acres) Source: NDOW, 2018

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Illipah Reservoir (160 acres maximum pool) Source: BLM, 2018

It is noteworthy that over the past decade Bassett Lake has decreased in size by 43 acres (down from 120 acres in 2007) and Illipah Reservoir by 90 acres (down from 160 acres in 2007). Cave Lake’s acreage has remained stable and Comins Lake has increased in size by 28 acres. The southern portion of Ruby Lakes extends into the northeastern corner of the County. There are numerous small ponds and lakes in the County for a total of 773 water acres. Ninety streams (281 stream miles) have been surveyed in the County. White Pine County has sixteen warm or hot springs. Only one, Monte Neva Hot Springs in Steptoe Valley has been identified by the U.S. Geological Survey as having enough potential for geothermal steam to warrant investment. o Surface Water Resources Although White Pine County has no major lakes or rivers, there are important surface water resources in many locations. Surface water flows are important sources of irrigation water in the agricultural areas in the major valleys of the county. Groundwater that discharges to the surface at springs is also an important surface water resource. Many springs in White Pine County have been developed for irrigation, livestock watering, municipal and domestic water supplies, and the mining industry. The surface water resources of White Pine County are also extensively used for recreational purposes including, fishing, hunting, boating and skiing, swimming, camping, picnicking, and relaxation. Wildlife cannot thrive without a dependable source of water and the many springs, streams, and lakes in White Pine County support the habitat for many desirable species (Intertech Services Corporation and Buqo, Thomas S.). Warm springs, particularly those in Steptoe Valley, have been historically developed into public spas. Several have the potential for geothermal energy development (Hinz, et. al., 2015) o Ground Water Resources In addition to their surface water resources, White Pine County has groundwater resources. Groundwater occurs at various depths under the entire county and has been developed for municipal, agricultural, and mining supplies as well as for other purposes. In recent years, the demand on the groundwater resources has grown significantly, in part reflecting the growth of the various economic sectors of the County, and in part reflecting the interest in exporting water from White Pine County through large-scale interbasin transfers of water. Additional information may be found in the White Pine County Water Resources Plan. 

Vegetation

Vegetation and wildlife occur throughout the County in patterns that generally reflect

the elevations, which give them the optimum moisture and temperature combinations. Vegetation in the valley floors includes shadscale, sagebrush, and winterfat. Heavy bands of pinyon pine and juniper exist in the foothills giving way to mountain mahogany at the 7,500-foot level. Alpine forests cover the highest mountain slopes. Above 8,500 feet there are stands of white fir, Englemann spruce, and limber pine. At the 9,000-foot level, bristlecone pine forests can be found. Some of White Pine County’s specimens of bristlecone, the oldest known living species, have been aged at over 4,000 years. The swamp cedar (Rocky Mountain Juniper, Juniperus scopulorum) is found in three places in the world on durapans or perched water tables; all of these locations are within the borders of White Pine County. The type of vegetation varies widely with amount of rainfall and temperature and hence with altitude. Shrubs and grasses dominate the valley floors while in the foothills and on slopes at intermediate altitudes, there are many juniper and pinon trees. Between 8,500 feet and timberline, the most abundant tree species are limber pine, bristlecone pine, and white fir (Hose, Richard K. and Blake M.C. Junior). Noxious and invasive weed species threaten native species throughout White Pine County. Public and private agencies manage and mitigate their spread in response to fire, ground disturbance, and drought.

Figure 4 – General Vegetation Type

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Wildlife

The expansive amount of public land in White Pine County provides vast amounts of habitat for a variety of wildlife including big game species such as elk, mule deer, bighorn sheep and antelope, a variety of bird species, both migratory and resident, including sage grouse, as well as a variety of reptile, small mammal, and fish species. The Nevada Department of Wildlife estimated that there were 3,300 elk, 14,000 mule deer, and 3,000 antelope populating White Pine County as of spring 2005. To date, the County is still home to some of the largest big game herds in the State of Nevada (Menghini, 2018), making White Pine County one of Nevada’s premier hunting and wildlife viewing destinations. These animals require large amounts of contiguous unfragmented land, which includes the seasonal habitats required for their survival. There are 19 state Management Unit Groups in White Pine County (Figure 5). Table 2 shows 2018 mule deer, elk, and pronghorn antelope population estimates for those Units that mainly fall within the boundaries of White Pine County. Some animals within these estimates do not reside in White Pine County (Menghini). Table 2 – White Pine County Big Game Populations NDOW 2018 Big Game Population Estimates, White Pine County Mule Deer: Elk: Pronghorn Antelope: Population Population Population Units Units Units No.'s No.'s No.'s 5,000 104, 108, 121 750 078, 105-107, 121 1,100 111-113 1,400 108, 131, 132 370 111-114 1,800 114-115 2700 111-115, 221-223 4,400 131, 145,163, 164 900 121 4,700 400 131-134 221-223, 241 221-223 4,300 Total 18,100 Total 5,520 Total 4,200 Source: Menghini, 2018.

Figure 5 – Nevada Department of Wildlife Management Units

In addition to impressive big game resources White Pine County is also known for being one of the key fishing areas of the state. The lakes and streams of the county provide habitat for six species of trout (Bonneville cutthroat, Bowcutt, Brook, Brown, Rainbow, and Tiger) and largemouth bass that are highly sought after by recreational anglers. The counties streams and lakes also provide habitat for native fish species, such as the Redside shiner, the mottle sculpin, the Pahrum poolfish, the Relict dace, the White River desert sucker, the White River speckled shiner dace, and the Fish Creek Springs tui chub (Korell, 2018). The counties lakes, streams, and wetland areas also provide habitat for a variety of shorebird, wading bird, and waterfowl species including the Black Tern, American avocet, eared grebe, common loon, and Long-billed Curlew and a number of important raptors including the Bald Eagle, Peregrine Falcon, Northern Goshawk, Golden Eagle, Prairie Falcon, American Kestrel, and several species of owls. The water sources of the county are also important stopping off points for a variety of migratory bird species that travel through the area (Intertech Services Corporation and Buqo, Thomas S.). Common waterfowl that nest in White Pine County include Mallard, Northern Pintail, Gadwall, American Wigeon, Northern Shoveler, Cinnamon Teal, Canvasback, Redhead, Ruddy Duck, Canada Goose (Henriod, 2018). Only three amphibian species can be found in White Pine County, the Northern Leopard Frog (protected by NAC 503.075.2), the Western Toad, and the Great Basin Spadefoot, although the Nevada Department of Wildlife is still determining distributions of some species (Korell, 2018). The following table outlines the County’s native gastropods. Table 3 – Gastropods Native to White Pine County. Gastropods Species (Native) Steptoe hydrobe White Pine mountainsnail Schell Creek mountain snail Longitudinal gland pyrg Transverse gland pyrg Landyes pyrg Hardy pyrg Neritiform Steptoe Ranch pyrg Sub-globose Steptoe Ranch pyrg Bifid duct pyrg Flat-topped Steptoe pyrg White River Valley pyrg Northern Steptoe pyrg Southern Steptoe pyrg Toquerville springsnail Source: Korell, 2018.

Sage grouse are also an important bird species that inhabit White Pine County. These birds are under state and federal management. V. CULTURE AND HISTORY White Pine County and the surrounding areas have at least 10,000 years of continuous human occupation and can be seen through thousands of recorded cultural resource sites. Some of the earliest cultural sites include several substantial finds of the PaleoIndian tradition, the earliest prehistoric peoples known in North America. More abundant pre-historic sites are related to the hunter-gatherers of the Desert Archaic tradition and the more recent Shoshone and Southern Paiute groups. Sites from the Fremont culture, a horticulturally based group, can be found in the eastern part of White Pine County. The various remains of these pre-historic cultures are found in a variety of site types including campsites, rock art, artifact scatters, rockshelters, isolated finds, and structural sites. Historic use of the area began with early exploration efforts during the first half of the nineteenth century by the likes of Jedediah Smith, John C. Fremont, and Kit Carson. These early explorations led to the establishment of the Pony Express route traveling through this area in 1860-1861 and later to the discovery of silver and subsequently expansive mining efforts comprised of boom towns and mining camps (Bureau of Land Management, Archeology in the Ely BLM District). All of this mining effort led White Pine County, throughout its history, to produce more mineral wealth than any other county in Nevada through the mid twentieth century (Hose, Richard K. and Blake M.C. Junior). In the early 1900’s copper mining and the establishment of the Nevada Northern Railroad also came to the area along with agriculture and livestock grazing. The evidence of this development and history can be found in historic trails, mining buildings and structures (there are 37 mining districts in White Pine County), homesteads, and cemeteries. 

Recreation

The majority of the recreation in the area is based upon Public Lands and the resources that they offer. The major recreational pursuits include hunting, fishing, camping, hiking, horseback riding, along with off highway vehicles and motorcycles. As recreation interest in the region grows other forms of recreation in the area are seeing a slight increase as well such as mountain biking, rock climbing, skiing, and snowmobiling. 

Population

Since the 1800's the County’s population reflected the boom bust cycle of the mining industry. As early as 1868, the population was 10,000 in Hamilton alone. Throughout the 19th Century, gold and silver camps flourished and then became ghost towns overnight. From 1900 to 1910 the opening of the copper mines caused a 279 percent

increase in population. The County’s population reached a peak of 12,377 in 1940. In the 1950's the major copper holdings were consolidated under the ownership of Kennecott Copper Company. The mergers resulted in substantial mine layoffs and the population fell to 9,424. By l970 it had risen to 10,150. The mine, and smelter layoffs were responsible for a 21 percent decline in population when the population dropped to 8,167. Following the 1980 Census Kennecott closed the smelter and railroad closed and the University of Nevada’s Bureau of Business and Economic Research estimated that the population dropped to 7,640 by 1985. The 1990 Census showed that the population had risen to 9,000 again due to increases from the gold mining industry. Between 1970 and 1980 net out-migration was a 28 percent loss and from 1986 to 1996 it was a 22 percent growth rate. At the same time the state experienced a growth of 53 percent between 1970 and 1980 and a 39 percent growth rate between 1980 and 1990. The population jumped by approximately 1,000 in 1989 with the opening of the Ely State Prison. Population continued to fluctuate in the early 1990's and rose from 1994 to 1999 with the employment and business activity from the BHP mine. With the closure of Robinson mine, the population dropped to 9,181 (Census) in 2000 and continued to drop until it reaches 8,842 in 2003. The population began to increase in 2004 and 2005. The population reflected an estimated increase of 1.4 percent in 2004 and 3.4 percent in 2005 making White Pine County the fourth fastest growing County in the state and 46th fastest growing County in the country as of 2007. The 2017 population of White Pine County is estimated at 10,705, increasing by 21% (2,096 individuals) in the 10-year period between 2005 and 2015 (Nevada Department of Taxation, 2018). Table 4 – White Pine County Population White Pine County Year

Population

2013 2014 2015 2016 2017

10,095 10,218 10,336 10,413 10,705

Source: Nevada Department of Taxation, 2018

Table 5 – Population of Cities/Towns in White Pine County Source: Nevada Department of Taxation, 2018; Sandoval, 2018

City Ely Lund McGill Ruth Ely State Prison as of 2018

Estimated 4,276 205 1,191 450 1,084

Table 6 – Income, White Pine County & Nevada White Pine County Nevada Year Household Per Capita Average HouseholdPer Capita Average Median Monthly Wage Median Monthly Wage 2015 $54,975.00 $41,645.00 $3,470.42

$52,544.00 $41,992.00 $3,499.33

Source: Nevada Department of Employment, Training, and Rehabilitation 2017

Table 7: White Pine County Annual Population Trend White Pine County Annual Population Estimates 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001

7,890 8,000 8,390 8,650 9,410 9,296 9,141 8,953 8,881 9,609 10,134 10,185 9,991 9,767 9,181 8,783

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

8,863 8,842 8,968 9,275 9,542 9,590 9,694 9,570 10,030 10,002 9,945 10,095 10,218 9,811 9,682 10,339

2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033

10,279 10,181 10,058 9,910 9,743 9,560 9,366 9,165 8,955 8,760 8,602 8,468 8,353 8,256 8,175 8,103

Sources: Nevada State Demographer (1986-2014, 2017-2033 based on 2013 estimate). US Census Bureau (2015-2016).

Figure 6 – White Pine County Labor Force.

Economics By mid-2006, the County was experiencing rapidly increasing housing prices, lack of affordable housing, workforce shortages, lack of contractor availability and rapidly increasing costs of construction. All indicators of economic activity have increased including population, housing units, new housing starts and active building permits, total labor force, assessed valuation, room tax revenues, and taxable sales. Between 2005 and 2007, the County sold thirty-six acres of land in its Industrial Park and issued two Revolving Loan Fund loans. As of June 2018 four active mines exist within White Pine County, two gold mines (the Bald Mountain Mine and the Pan Mine), one copper mine (Robinson Nevada Mining Company), and the Mount Moriah Stone Quarry. An estimated four gravel pits are currently within operation in White Pine County, JCR, J&M, CPS Rock and Sand, and Titon (Davis, 2018). VI.

POLICIES

This section is organized by major public land issue topic and describes White Pine County’s policies and action items related to each issue. The action items are intended to help resolve the State’s public land issues and implement the policies in collaboration with the federal planning partners. 1.

Plan Implementation, Agency Coordination and Local Voice

Agency coordination of planning is mandated by federal laws. 

The Federal Land Policy and Management Act, 43 U.S. § 1701, declared the National Policy to be that "the national interest will be best realized if the public lands and their resources are periodically and systematically inventoried and their present and future use is projected through a land use planning process coordinated with other federal and state planning efforts." See 43 USC §1701 (a) (2).

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43 U.S.C. § 1712 (c) sets forth the "criteria for development and revision of land use plans." Section 1712 (c) (9) refers to the coordinate status of a county which is engaging in land use planning, and requires that the "Secretary [of interior] shall" "coordinate the land use inventory, planning, and management activities... with the land use planning and management programs of other federal departments and agencies and of the State and local governments within which the lands are located." This provision gives preference to those counties which are engaging in a land use planning program over the general public, special interest groups of citizens, and even counties not engaging in a land use planning program.

White Pine County Code Section 2.88 and Resolution 2009-49 creates the White Pine County Public Land Users Advisory Committee (PLUAC). The purpose of PLUAC is to assist the Board of County Commissioners in developing policies, evaluating proposed actions, and informing state and federal agencies of the County’s needs and preferences regarding the use of public lands within White Pine County. White Pine County provides administrative support to PLUAC to ensure accurate records of its meetings and timely communication with the County Commission. The goals of the White Pine County Commission are to provide the citizens of White Pine County with access to public lands for recreational use, economic activity and to protect the quality of the County’s environment and natural resources for future generations. White Pine County maintains primary consideration for the principles on multiple use and sustained yield as the status and their responses of the lands permit. The White Pine County Commission seeks input from area citizens with interest and expertise in the use of the county’s public lands for economic activity, recreational use, and environmental quality. The White Pine County Commission is an active participant in reviewing proposed land transactions and public land policies, seeks status as a cooperating agency in NEPA processes, and makes every effort to continually review and update its local planning documents to reflect the need for access to and uses of public lands.

The PLUAC conducts its meetings under the provisions of the Nevada Open Meeting Law and provides an open forum for public land users, White Pine County citizens, and representatives of federal, state, and local public agencies to discuss public land use issues. The Duties and Responsibilities of the White Pine County Public Land Users Advisory Committee are: 1). To serve as an advisory board to assist the Board of County Commissioners regarding the use and management of public lands in White Pine County. 2). To periodically review, develop and recommend revisions to the White Pine County Public Land Use Policy as appropriate, but no less than every five years. 3). To review proposed actions on or impacting public lands in White Pine County and recommend comments and action to the Board of County Commissioners. 4). At the discretion of the Board of County Commissioners, to represent White Pine County at meetings and proceedings by state and federal agencies regarding the management and use of public lands in White Pine County and regarding other matters relating to public lands within White Pine County. 5). To make a report of its findings, determinations, or recommendations to the Board of County Commissioners on all matters considered by the advisory board, for final action or disposition by the Board of County Commissioners. Federal land management policies and procedures, land transactions, and compatibility with the local land use goals are of critical importance to the County’s residents. As outlined in County Code Section 2.88.100, White Pine County’s Board of County Commissioners supports a policy of multiple uses of public lands that are in the best interests of the residents of the County including recreational activities, production of revenue and other public purposes. Policy 1-1: The Bureau of Land Management, National Park Service, US Forest Service, Nevada Department of Wildlife, Nevada Division of State Parks, and other regulatory agencies commonly submit proposals that affect public lands and their use within White Pine County. Such proposals should be brought to the attention of the PLUAC for its review to determine if the action is in conformance with this Policy Plan. PLUAC will report its findings and recommendations to the Board of County Commissioners. Policy 1-2: White Pine County will participate with State and Federal agencies on actions that affect public lands within the county. The PLUAC will serve in an advisory capacity only, and act as liaison between the White Pine County Commission and the federal and state land management agencies. Studies concerning impacts of proposed actions affecting public lands should be conducted by professionals. The PLUAC requests the commission be notified by the federal and state agencies before any studies sponsored by the federal and state land management agencies are

initiated. Copies of resource studies should be provided to the PLUAC as soon as available. Policy 1-3: The PLUAC emphasizes compatibility between this Plan and all federal and state land use plans which apply to White Pine County. Policy 1-4: The PLUAC requests inclusion as a recipient of the BLM Northeastern Great Basin Resource Advisory Council (RAC) meeting minutes and agendas. The PLUAC will reciprocate by forwarding agendas and minutes to the RAC. Policy 1-5: The PLUAC will confer with other County Advisory Boards, as appropriate, on projects that may affect additional County resources and planning. 2.

Management of Public Lands

Policy 2-1: Support the concept of Multiple Use Management as an overriding philosophy for management of the public lands based on multiple use and sustainable yield concepts, and in a way that will conserve natural resources. Pursuant to County Code Section 288.100, “multiple use” means and includes: 1. The management of public lands and their various resources so that they are used in the combination which will best meet the needs of the residents of the County. 2. The use of public lands and some or all of their resources or related services in areas large enough to allow for periodic adjustments in the use of the lands to conform to changing needs and conditions. 3. The use of certain public lands for less than all of their available resources. 4. A balanced and diverse use of resources which takes into account the long term needs of the residents of the County for renewable and non-renewable resources including but not limited to recreational areas, range, timber, minerals, watershed, wildlife and fish, and natural scenic, scientific, and historic areas. 5. The harmonious and coordinated management of public lands and their various resources without the permanent impairment of the productivity of the lands and the quality of the environment with consideration being given to the relative values of the resources and not necessarily to the combination of uses that will produce the greatest yield or economic return for each parcel of land. Pursuant to County Code Section 288.100, “sustained yield” means the maintenance of the high-level annual or other periodic yield from the various renewable resources of

public lands consistent with multiple use. Policy 2-2: Protect and preserve the quality of the environment, and economic, cultural, ecological, scenic, historical and archeological values; protect and preserve wildlife habitat values compatible with economic opportunities needed to provide for long term benefits for the people of White Pine County now, and future generations. Policy 2-3: Support coordination of public land use policies and actions with all appropriate federal, state, and local entities and the components of the County’s Comprehensive Master Plan. Policy 2-4: Support the Great Basin Restoration Initiative. Policy 2-5: Ensure that appropriate access is maintained for the diverse uses of public lands. 3.

Federal Land Transactions

The following are policies developed by White Pine County relating to the federal land program. Appendix A provides a list of parcels initially identified by the County for disposal in the BLM Ely Resource Management Plan. The White Pine County Conservation, Recreation and Development Act of 2006 authorizes as many as 45,000 acres of federal land for disposal to the County and private sectors for local public purposes, community expansion and economic development. This could increase the non-federal land base of White Pine County by 17.3%. The list and the map provide a general description of the lands identified for acquisition and is expected to be updated annually by the County Commission in coordination with the BLM. Each parcel will need to be further reviewed at the time a specific reality action is proposed. White Pine County has a total land base of 5,699,200 acres. Federally managed public lands amount to 5,439,707 acres and this number represents 95.4% of the county’s total land base. Most of the public lands within and adjacent to the communities are administrated by the BLM and US Forest Service. Lands identified for disposal are shown in the Ely Resource Management Plan. Appendix A of this plan cross references the Ely RMP. White Pine County recognizes that many of the policies described below are currently part of the BLM procedures for land transactions. However, the County believes the basic policies on land tenure need to be clearly expressed in this Plan to communicate county policies not only to the federal agencies, but to the citizens of White Pine County as well.

White Pine County has identified many parcels for public purposes and for economic development. The specific land transaction program is to be guided by the following policies: Policy 3-1: White Pine County recognizes and will weigh carefully the value of public lands for recreation, sight-seeing, hunting, fishing, grazing, hiking, mining, and a wealth of other multiple use activities when supporting or recommending specific land transactions or designations. Short and long-term costs and benefits of all public lands disposals must be carefully weighed. Policy 3-2: Evaluate federal land disposals for private development utilizing the following criteria and priorities and policies: Criteria: 1. Compliance with the zoning designations, land use recommendations in the County’s Comprehensive Master Plan, priorities for economic and community development identified in the annual Comprehensive Economic Development Strategy and other community planning efforts; cost of County services including water, sewer, roads, utilities, fire and police protection, weed control, and other infrastructure; and impact to existing commercial, residential, and industrial activities. 2. Adequate assurance of public access to and through disposed lands and to adjacent public lands for recreation and other multiple uses (through the recordation of an easement and deed restriction). If alternative routes of access is required they should be acquired and guaranteed prior to the disposal and loss of any existing access should be of equal value and public benefit. 3. Impacts to existing uses including important wildlife habitat, key seasonal grazing rights, mineral resources, municipal watersheds, flood prone areas, visual values, access, and recreational use of the lands. 4. Availability of water resources to support the proposed use. 5. Compliance with the policies contained in this Public Lands Policy Plan. Priorities: 1. Isolated tracts of public lands. 2. Any public lands in-holdings within existing private land should receive a high priority for sale or exchange. 3. Land sales and exchanges that make private lands more manageable. 4. Public lands should be sold or exchanged to the private sector when suitable for intensive agricultural operations. 5. At the request of local governmental entities, public lands within the municipal service areas of Ely, McGill, Baker, Lund, Ruth, Preston and Cherry Creek should

be made available for urban expansion. Policies: 1. Disposals for private residential and commercial development should be structured so that local residents have a reasonable opportunity to acquire parcels on a competitive basis. 2. As appropriate, and at the request of adjacent land owners and users, encourage preference for direct sale or preferential bid. 3. Encourage disposals including direct sale and preferential bid for land disposals based on a Record of Decision following completion of Environmental Impact Statement (EIS) and Environmental Assessment (EA) processes where the public has had substantial opportunity to review and comment on the proposed project. 4. When land disposals result in loss of AUM’s or range improvements, encourage full compensation and alternatives allowed under the law. Policy 3-3: Rights-of-Way: Support designation of corridors for the future transmission of energy, communications, and transportation when they are planned for in harmony with other multiple uses on federally administered lands in accordance with the NEPA processes. Policy 3-4: Land Transfers to Local Government and State Government: As requested by local governments and state agencies, lands identified for public purposes should be made available through the R&PP process. A. Lands within municipal service areas should be made available for public purposes only when local governments determine that it is an opportune time and the transfer will not burden the local government. B. Requests for R&PP transfers should receive preference to disposal for private development. C. Preference should be given for land sales and exchanges that consolidate high value public purposes Policy 3-5: Specially Designated Lands (i.e., National Recreation Areas, National Conservation Areas, Wildlife Refuges, Wilderness Areas, State Parks, State Wildlife Management Areas, etc.). A. Support designation of new specially designated lands within White Pine County which are suitable and beneficial to White Pine County citizens, consolidate high value public purposes lands, and are valuable assets to the State and its residents. B. Support a balanced review and inventory of all multiple interests prior

to designation of any new wilderness areas. Policy 3-7: Plans to develop federal or state lands for projects that do not support multiple use should be treated similarly to disposals of federal land to nonfederal parties. In particular, projects adjacent to communities and other private lands should conform, as much as possible, to the County’s Land Use Plans and zoning designations. A.

B. C. D.

Support withdrawals from mineral entry only after careful evaluation of mineral resources which is documented by a mineral report that adequately describes the mineral potential of those lands. Support minimal separation of surface and mineral estates in all realty actions. Encourage federal management policies on existing split mineral estates based on state and local participation Support limited use of the mineral withdrawal process to protect environmentally sensitive lands.

Policy 3-8: White Pine County opposes any further military withdrawals of land and restrictions of airspace. Policy 3-9: Acquisition of Private Land for Public Purposes: Recognize that the acquisition of some private lands for certain special public purposes is a benefit to its residents. A. Recommendations for acquisition of private land for public purposesshall ensure: 1. All transactions must involve a “willing seller”. 2. Private land is not acquired unless it clearly benefits the citizens of White Pine County. 3. Environmental, recreation, and cultural values are protected. 4. Private property interests are protected and enhanced. 5. Socio-economic impacts are duly considered, and the local economy is not negatively impacted. 6. Due process is guaranteed to all private parties involved in land use controversies by means that do not demand or create a financial hardship. 4.

Agriculture and Livestock Production

Agricultural production is necessary to help maintain the historical, cultural and economic viability of White Pine County. Policy 4-1: Preserve agricultural land and promote the continuation of agricultural

pursuits, both traditional and non-traditional, in White Pine County. Policy 4-2: The pursuit and production of renewable agricultural resources are consistent with the long-term heritage of White Pine County. This private industry benefits White Pine County economically and culturally. Policy 4-3: Opportunities for agricultural development on public lands should continue at levels that are consistent with historical customs, environmental sustainability, culture and compatibility with other multiple uses. Policy 4-4: Grazing should utilize sound adaptive management practices. White Pine County supports the periodic updating of the Nevada Rangeland Monitoring Handbook to help establish proper levels of grazing. Policy 4-5: Allotment management strategies should be developed that provide incentives to optimize stewardship by the permittee. Flexibility should be given to the permittee to reach condition standards for the range. Monitoring should utilize the use of long-term trend studies as described above. Policy 4-6: Encourage agencies managing public lands to coordinate with the N-4 Grazing Board on all manners affecting livestock grazing on public lands within White Pine County. Policy 4-7: Range water rights and improvements such as those associated with seeps, springs, streams, lakes and wells used by livestock should be protected in the long term for that use. Encourage cooperation between the federal land management agencies and the grazing operator in protecting the riparian values of these water sources. Policy 4-8: White Pine County is opposed to the forced transfer of water rights in order to obtain permission for water developments on public land. Policy 4-9: White Pine County affirms the right of access to private interests, including water rights, located on public land. Protecting access to private interests is important for White Pine County’s economy. Private entities need to have access to private land, water rights, and the distribution systems necessary for the conveyance of water over public land for the purpose of use or maintenance. 5.

Forestry

Forest and forestry products production in White Pine County is a benefit to the livelihood and wellbeing of its citizens. Therefore, it is the policy of White Pine County to protect forest resources and promote the continuation of a sustainable forestry products

industry. Policy 5-1: Promote multiple use of public forest resources to realize sustainable and continuous provisions of timber, forage, firewood, wildlife, fisheries, recreation and water. Policy 5-2: Support the prompt salvage of forest losses due to fire, insect infestation or other events. Policy 5-3: Support the management of woodlands/forest by ecological condition for a diversity of vegetation communities. Grass and shrub ecosystems with no or few invasive species are preferable to pinyon/juniper monocultures. Policy 5-4: Urge BLM and Forest Service to allow and promote thinning of wildland/urban interface. This should be done in such a manner that local entities have an opportunity to derive economic benefit from the forest. Policy 5-5: Recognize the importance of maintaining healthy aspen communities and encourages activities that will retain and improve the vigor of these communities. Policy 5-6: Allow free use cutting of green pinyon-juniper. 6.

Wild Horses

Sightings of wild horses are thrilling and memorable moments for many travelers crossing public lands. An overabundance of horses, however, may be detrimental to the health of these lands. Management must carefully balance needs of wild horses against the needs of other multiple uses. Policy 6-1: Publicize and encourage visitation in areas where wild horses can be seen by the public. Policy 6-2: Manage wild horses to reduce detrimental impacts to other multiple uses. Potential adverse effects on private lands, rangelands, wildlife habitat, and water sources should be avoided or properly mitigated. Policy 6-3: The BLM, US Forest Service and the State should work cooperatively on wild horse management issues. Appropriate management levels (AMLs) should be set at reasonable limits as determined through public involvement through coordinating agencies such as the BLM Northeast Great Basin Resource Advisory Council, the White Pine Coordinated Resource Advisory Council, and the Nevada Wild Horse Commission.

Policy 6-4: Inform Congress and the public on the impacts of wild horses. Encourage legislation to allow greater flexibility for their management and adoption. Policy 6-5: Encourage the BLM to increase the potential of the adoption program for wild horses through an aggressive marketing program. Holding and adoption facilities for wild horses should be created in White Pine County. 7.

Mineral Resources

The development of Nevada’s mineral resources is desirable and necessary to the economy of the nation, the state and particularly to White Pine County. White Pine is the state’s leading producer of copper and has produced vast quantities of gold, silver, and other metals. The area is an active frontier for oil and geothermal development. Sand, gravel, decorative rock, and other industrial minerals are produced daily. Policy 7-1: Encourage the careful development and production of White Pine County’s mineral resources while recognizing the need to conserve other environmental resources. Policy 7-2: Support State and federal policy that encourages both large and smallscale operations. Regulatory hurdles should not be so complex that they undermine the principles of the various mining and leasing laws, including the Mining Law of 1872. Policy 7-3: Mineral operations should be consistent with best management practices for the protection of the environmental qualities and the multiple use of public lands. Federal and state regulatory agencies should continue to enforce existing reclamation standards to ensure there is no unnecessary or undue degradation of the public lands and adjacent private lands. Policy 7-4: Mine site and exploration reclamation standards should be consistent with the best possible post mine use for each specific area. Specific reclamation standards should be developed for each property rather than using broad based universal standards. Private properties (i.e., patented claims) should be reclaimed to the standard and degree desired by their respective owners, following state law and regulations. Policy 7-5: Reclamation of mine sites should be coordinated with the White Pine County Commission and the PLUAC. Options should be considered for postmine use of buildings, access roads, water developments, and other infrastructure for further economic development by industry as well as uses pursuant to the Recreation and Public Purposes Act. White Pine County must be an active participant in planning for the eventual closure and reclamation of the Robinson copper mine.

Policy 7-6: Support the policy of the small miner exemption if the miner is offered the opportunity to develop the property. Federal and state regulators should work closely with the small miner to ensure that permitting costs and complexity do not prevent the implementation of this option. An annual assessment requirement for holding mining claims has led to unjustified land disturbances which did not necessarily aid in the furtherance of the property’s resource development. These requirements have since been revised and require the claim holder to pay an annual rental fee to the BLM, in lieu of doing work on the ground. There is an exemption for a small miner who holds ten claims or less. If the small miner chooses the exemption, $100 of assessment work must be expended annually to hold the claim. Policy 7-7: Federal, State and county governments should cooperate in continuing to provide sources of gravel, topsoil, rock and other mineral materials for local communities. These should be located as near as practical to present and planned urban areas while being in conformance with County development plans. County, State and federal agencies should jointly plan for the efficient development and use of material sites for both the government agencies and the private sector. Policy 7-8: Mining activities generate important revenues for White Pine County: net proceeds of mines from hardrock operations and lease and royalty payments from oil and geothermal leasing and production. Federal and State regulatory agencies should ensure that their permitting and leasing protocols provide the maximum efficiency in making Public Lands available for minerals activities. Sales of oil leases within White Pine County should be offered on a quarterly schedule. 8. Wilderness The benefits of designating wilderness areas include protecting the scenic, recreational and ecological values of the land. Furthermore, special areas in White Pine County should be protected from irresponsible OHV use, speculative oil and gas development, and to provide for clean air and water for future generations. While OHV users continue to enjoy the majority of public lands where roads and trails already exist, it is important to provide for some areas where non-motorized users can experience and enjoy wilderness quality lands. Dollar values are difficult to place on wilderness areas, but wilderness pays in a number of ways.  Direct income from recreational use.  Passive value by passing its legacy on to future generations.  “Ecosystem benefits” such as cleaning the air we breathe and the water we drink.

Protecting land as wilderness can act as a strong economic lure to draw people to live in nearby areas for business, pleasure and retirement. Residents see this as a benefit to their quality of life that brings economic development. The White Pine County Conservation, Recreation and Development Act of 2006 (HR 6111) created additional wilderness in the county and released other areas to multiple use. Table 8 shows the total acres (485,431) of federally-managed Wilderness Areas in White Pine County. There are 12 Wilderness Areas in the County, one of which, Mount Moriah, is comanaged by the BLM and the USFS. Six Areas are managed solely by the USFS (350,903 acres) and five are managed solely by the BLM (134,528). Table 8 – Wilderness Area Acres in White Pine County US Forest Service Bureau of Land Management Name Acres Name Acres Mount Moriah* 18,189 92,419 Becky Peak High Schells Schellback White Pine Range Bald Mountain Red Mountain Currant Mountain Total Acres

121,497 36,143 40,013 22,366 17,562 20,903 350,903

Bristlecone Mount Moriah* South Egan Range Government Peak Mount Grafton Total Acres

14,328 8,797 32,942 6,325 53,947 134,528

*Co-Managed by BLM and USFS Source: Rajala, 2018; Miller, 2018.

Policy 8-1: Wilderness in appropriate areas is supported for its economic benefits to White Pine County. Policy 8-2: As wilderness protects scenic, recreation and ecological values important to the economic future and as well as protecting important natural resources, including clean air and water of White Pine County, we support designation and proper management of existing wilderness areas in the County. Policy 8-3: Existing wilderness should be managed to protect White Pine County’s important natural resources, its clean water and air, its scenic and recreational values, and its economic future. Policy 8-4: Support the reclamation of unnecessary roads and trails and the proper management of wilderness lands by the administering agency. Policy 8-5: White Pine County recognizes that multiple interests exist on potential wilderness areas and supports a balanced review and inventory of all such interests prior to any designation of new wilderness areas.

Wildlife

White Pine County residents support a diversity of wildlife species. Coordination of federal and state wildlife and fisheries’ management and enforcement is encouraged. Policy 9-1: Recommendations made by the White Pine County Wildlife Advisory Board should be followed, and actions taken where appropriate. Policy 9-2: The Nevada Wildlife Commission should consider and give high priority to White Pine County Wildlife Advisory Board recommendations. Policy 9-3: The White Pine County Wildlife Advisory Board and the White Pine County PLUAC should maintain an active and constructive dialogue. Policy 9-4: A yearly update by Federal and State agencies should be provided to the PLUAC to maintain an active and constructive dialogue regarding threatened and endangered species and potential listings of same. Policy 9-5: Identify habitat needs for wildlife species, such as adequate forage, water, cover, etc., and provide for those needs so as to, in time, attain appropriate population levels compatible with other multiple uses as determined by public involvement. Policy 9-6: Support the Wildlife Services Environmental Analysis for the Humboldt National Forest and the Animal Damage Control Plan for the Ely District BLM. Policy 9-7: Support habitat restoration to improve wildlife habitat when compatible with other uses. Policy 9-8: Support big game species management through the White Pine County Advisory Board to Manage Wildlife and the County and State Management Plans for elk, mule deer, antelope, bighorn sheep and mountain goat. Policy 9-9: Support hunting and fishing as recreational resources and as a multiple use of public lands. White Pine County endorses the State’s programs to provide sustained levels of game animals. Policy 9-10: The Ruby Lake National Wildlife Refuge should continue to be managed for wildlife and appropriate recreational uses. Policy 9-11: Support limiting raven and crow populations to levels that don’t negatively affect the populations of other wildlife species.

Policy 9-12: Hunting of any wildlife species being considered for listing as threatened or endangered should be discontinued. The listing of any species would be detrimental to industries in White Pine County that are dependent on the multiple use of public lands. 10.

Public Safety

White Pine County appreciates the safe passage of its residents and visitors on public lands. Policy 10-1: Any unfenced rights-of-way along State highways should be fenced to protect the traveling public and to reduce the loss of livestock. This fencing should be constructed under a cooperative effort between the BLM, US Forest Service, Nevada Department of Transportation, Nevada Department of Wildlife, Nevada Division of Forestry, private property owners, and the permittees. Policy 10-2: White Pine County supports the existing protocol between BLM and other federal law enforcement officers and the White Pine County Sheriff and other Federal and State law enforcement agencies. Policy 10-3: Support cooperative training in areas of public safety such as search and rescue and hazardous materials. The US Forest Service and BLM should work with the County to ensure adequate personnel, training and equipment to meet the increased demand for back country rescues. Policy 10-4: Military Withdrawals of Land and Air Space: Support full evaluation of criteria listed in the Public Land Use Policy Plan regarding any public land and air space withdrawals for military use including those with potential for transportation, storage, and disposal of all hazardous, toxic, or nuclear materials. Policy 10-5: Abandoned mines should be properly sealed through a cooperative agreement between the County, BLM, the Nevada Division of Minerals, mining companies and private land owners. Emphasis should be placed on those mines in close proximity to communities and high-use recreational areas. Policy 10-6: Roads on public lands should be maintained for safe passage. Areas of high travel should be made a priority. Where road conditions are dangerous, signs and other public notification should be utilized until the condition can be mitigated. Maintenance of roads should be coordinated between the BLM, US Forest Service, County and thepublic.

11.

Air Quality

Air quality in White Pine County is currently some of the best in the nation and it is an important factor influencing the quality of life and wellbeing of its citizens. Therefore, it is the policy of White Pine County to protect air quality. Policy 11-1: Air quality must be protected with a balanced approach that provides economic growth without a detriment to the social, aesthetic, cultural and ecological values of the County. Policy 11-2: All energy proposals shall attain the lowest possible emissions and highest possible efficiencies consistent with federal, state and county guidelines, regulations, and industry standards. Policy 11-3: All water rights applications associated with proposed pipeline projects should require comprehensive monitoring programs to include air quality measurements. If PM-10 levels increase and immediate revegetation project will be necessary to stabilize the surface of any areas where any vegetation is changing as a result of the project. Policy 11-4: Air quality standards should be established based on best available control techniques by the Nevada Division of Environmental Protection. White Pine County’s excellent air quality should be maintained as an important aspect of the quality of life of the citizens and visitors. Policy 11-5: Particulate monitoring stations should be established by the Nevada Division of Environmental Protection to establish local ambient air quality. Policy 11-6: Greenhouse Gases: Greenhouse gases should be considered as an air quality issue. 12.

Cultural Resources

White Pine County cultural resources and customs include all the prehistoric and historic archaeological resources and traditional cultural practices of the people of White Pine County. The Great Basin Heritage Route traverses White Pine County and is a valuable asset that showcases the county’s resources. Cultural resources include, but are not limited to:     

historic roads trails railways highways and associated buildings sidings

           

stations rock art sites historic townships mining camps and districts racetracks cemeteries and isolated gravesites Paleoindian sites prehistoric villages and campsites rock shelters caves tool stone sources quarries White Pine Public Museum historic ranching and associated landscapes arborglyphs (aspen art)

Less tangible resources include:     

dance forms Native American languages customary beliefs material traits of a group integrated patterns of human behavior passed to succeeding generations by stories and traditions

Policy 12-1: Support conservation of historic properties, landscapes and practices which use these landscapes in a manner that does not degrade them for future generations. Policy 12-2: Participate in the planning of appropriate uses and the protection of cultural resources. Threats to cultural resources include fire, vandalism, unauthorized use and rural/urban sprawl. Policy 12-3: Promote educational programs for citizen stewardship of cultural resources in a manner that will guarantee the thrill of discovery for future generations. This includes the County’s ghost town and mining heritage and the Great Basin Heritage Route. Policy 12-4: Tangible artifact remains, and records of folk life and cultural heritage should be preserved locally, rather than removed to out-of-county or outof-state sites. Citizen access to the remains and the actual sites is encouraged if the resources are protected. Policy 12-5: The customs and culture associated with American Indian activities in White Pine County is necessary to the livelihood and wellbeing of

American Indians. White Pine County supports American Indian activities on public lands. Policy 12-6: Utilize and support the conservation, curation, and education efforts of the wealth of local museums, historical groups, and cultural organizations in White Pine County. 13.

Recreation and Open Space

White Pine County enjoys many natural amenities that attract local residents and visitors. These resources should be protected and developed for the public’s multiple use benefit. This section is cross-referenced to, and is consistent with, the County Open Space Plan and County Wildland Urban Interface Emergency Services Plan, coordinated with White Pine County, BLM, US Forest Service, NDF and the UNR Cooperative Extension. Open space is critical to White Pine County’s economic, historical and cultural identity. Policy 13-1: Conserve and protect scenic, historical, recreational and open space resources for the benefit of the present and future generations with continuing consultation with local, State and federal governments and users. White Pine County recognizes that recreation in all forms is consistent with multiple uses of public lands. All resources utilized by the public should be conserved and White Pine County reserves the right for application under the Recreation and Public Purposes Act (R&PP) for all such resources. Policy 13-2: Encourage sustainable recreational use in White Pine County by increasing marketing efforts that describe the opportunities available. Marketing programs that promote such features as the recently designated Wilderness Areas, the Great Basin Trails Alliance, the Great Basin Heritage Route, The Loneliest Highway in America, the Pony Express Trail, Great Basin National Park, the mining history of Hamilton and other areas, the Ghost Train, and state parks should be increased. Policy 13-3: Promote “Eco-tour” and responsible off highway vehicle businesses in the County. The themes of the tours could vary from wildlife viewing, to visiting hot springs, historical sites, or to learn to ride motorcycles and drive four-wheel vehicles on hundreds of miles of existing roads and trails. Ensure that all governmental agencies work in a cooperative effort to encourage such uses while protecting the resources from damage. OHV users are encouraged to visit and patronize county communities. Policy 13-4: Encourage the development of a community ski hill to provide close and low-cost winter recreation opportunities for residents and visitors.

Policy 13-5: Encourage dispersed recreation opportunities on all appropriate public lands as a substantial economic asset to local economies. Policy 13-6: Public lands with value for concentrated recreational use should be identified, protected and developed for recreational purposes. The BLM and US Forest Service should consider withdrawing these key areas from minelawral entry on a limited basis. Any proposals for mineral withdrawals should be coordinated with the PLUAC. Policy 13-7: Recognizing that most Nevadans reside in towns, investments in open space, park and recreation facilities should be concentrated as close to resident populations as feasible. Policy 13-8: Protect and promote the Pony Express Trail and Lincoln Highway corridors as cultural and recreational resources in ways that protect private property rights and promote tourism. Policy 13-9: Protect water quality and water rights for recreational fishing at Comins Lake, Illipah reservoir and other important water resources. Recreational uses and facilities are encouraged and should be developed where appropriate. Policy 13-10: Support hunting and fishing as recreational resources and as a multiple use of public lands. White Pine County endorses the State’s programs to provide sustained levels of game animals. Policy 13-11: The establishment of new specially designated lands (i.e. National Recreation Areas, National Conservation Areas, Wildlife refuges, Wilderness Areas, State parks, etc.), may be a valuable asset to White Pine County and its residents. Determination of value can only be achieved through close coordination with the PLUAC and close adherence to a public and transparent citizen input process. Policy 13-12: Promote increased marketing of the Silver State Classic automobile road race between Lund and Hiko. Policy 13-13: White Pine County encourages the development of hiking and recreational trails on public lands. 14.

Wetlands, Riparian Habitat and Waters of the United States

Wetlands, riparian habitat and waters of the United States support the diverse populations of waterfowl, fisheries, wildlife, and plant communities prized by all public land users within the County. These policies correspond to the policies and statements

contained in the White Pine County Water Plan. Policy 14-1: Wetlands, riparian habitat and waters of the US should be protected from undue degradation. Undue degradation may result from over pumping of groundwater, destruction of vegetation for over-development or misplacement of recreational facilities, poorly planned land dispositions, unintentional misuse of riparian resources by public and private users, and other actions. Policy 14-2: Wetlands, riparian habitat and waters should be managed in responsible and balanced manner with other resources.

Policy 14-3: Support a coordinated effort to protect wellhead protection areas and municipal watersheds from undue degradation through proactive zoning and development controls, pursuant to the County’s Wellhead Protection ordinance. Policy 14-4: Ensure that both governmental and private actions comply with the provisions of the White Pine County Water Plan. 15.

Fire Management

Fire is an integral component of the well-being of public lands. However, introduced factors have led to the dangerous potential for out of control wild fires that affect the economic and environmental well-being of the County. Policy 15-1: The recommendations contained in the current White Pine County UrbanWildland Interface Regulation Review and the current White Pine County Wildland-Urban Interface Handbook should be implemented as soon as possible. Defensible space should be a responsibility of federal, state and local agencies, as well as the private property owner. Policy 15-2: Maintain local coordination between BLM, US Forest Service, Nevada Division of Forestry (NDF) and local volunteer fire departments to increase the effectiveness of fire suppression. The federal agencies need to take advantage of the skills and local knowledge of local residents. This is particularly important when using out-of-area fire crews for firefighting. White Pine County will aid in any way possible in suppression of wildfires that endanger the livelihoods and personal wellbeing of its citizens. Policy 15-3: Encourage the development of mutual aid agreements between the local fire departments, NDF and the federal agencies. White Pine County supports the use of mutual aid agreements and encourages the federal

agencies to utilize local firefighting resources as much as possible. Policy 15-4: Encourage the federal agencies to continue the policy of contracting with White Pine County residents for privately owned equipment suitable for firefighting. Encourage the practice of early season inspections and signups well before the fire season. Policy 15-5: Encourage the federal agencies to consider using livestock to reduce the fire hazard. There may be situations where livestock grazing can be effective in reducing the fire danger and will not result in environmental damage. Sheep and goats should be used wherever practical to reduce fuel loads. Policy 15-6: The use of green stripping is encouraged if the treated areas are seeded with fire-resistant grasses and maintained. Policy 15-7: Nevada Department of Transportation (NDOT) should mow and/or spread herbicide on all highway rights-of-ways as frequently as possible to reduce the potential for the spread of fires onto adjacent public and private lands. Policy 15-8: All fire equipment should be cleaned to assure it is “weed- free” before being dispatched to a wildfire. Policy 15-9: Encourage the federal agencies to develop and implement fire management plans to incorporate thinning, fire use areas, prescribed burns and reseeding to restore natural functioning and reduce the impact of invasive species. Policy 15-10: Incorporate free wood cutting as a tool for thinning. 16.

Noxious Weeds and Invasive Species

Invasive weeds in White Pine County are currently displacing diverse native plant communities and greatly impacting Nevada’s natural and economic resources. That threat to the biological diversity that makes the surrounding ecosystem function will expand rapidly unless kept in check by constant vigilance and work to control them whenever they are found. Policy 16-1: Support the Tri-County Weed Program’s cooperative weed management areas to control invasive species and institute a revegetation program in areas where weeds are treated. Establish a monitoring program to determine the effectiveness of the treatments.

Policy 16-2: Support the education of off-road vehicle operators about the hazard of transporting weeds from currently infested areas. Policy 16-3: Surface disturbing activities in the county should be quickly revegetated to prevent the establishment of invasive species. Policy 16-4: Water rights applications associated with pipeline projects should include a comprehensive revegetation monitoring program. Policy 16-5: If weeds increase due to plant community changes as a result of any water project, immediate revegetation projects will be necessary to stabilize the surface and revegetate the area with adapted species. Policy 16-6: Support the Nevada Weed Free Forage Certification program. Any hay being transported for feed on public land needs to be from a certified weed free field. Policy 16-7: Federal, State and county agencies should investigate and treat invasive species as soon as they are detected in the County, and before those species develop an infestation. Proactive treatment at first detection will cost much less than treatment of established populations (E.g. the hoary cress/white top in the Georgetown Ranch area and along State Route 490, between US 93 and the Lackawanna Road, and the recent emergence of Sahara Mustard in Clark County). 17.

Off-Highway Vehicles (OHV's)

The use of off-highway vehicles (OHV's) has increased significantly over the past decade. Important to many Nevadan's lifestyles for work and play, they provide many economic benefits and many environmental impacts. Policy 17-1: Encourage and support the development of a White Pine County OHV Management Plan by using the CRMC process encouraging a broad-based local planning group to provide input in determining and prioritizing needs for current and future OHV use and management in White Pine County. Policy 17-2: Encourage and support the development of a White Pine County OHV Management Plan and any other policy and regulation that: 1. Incorporates the guidelines set forth by Congress in Title III White Pine County Conservation, Recreation and Development, Section 355 Silver State Off-Highway Vehicle Trail for any future consideration, development and management of any additional OHV trails, routes or limited off-road use areas in White Pine County. 2. Promotes sensible and responsible use of OHV's through registration, education, training, advertising and other means.

3. Requires OHV users to stay on designated roads and trails or in limited offroad use areas and actively discourage the pioneering of new trails. 4. Encourages sufficient resources to be made available to local district offices to publish maps of areas and routes suitable for OHV use. 5. Effectively monitors and manages off-highway vehicles in areas where they are allowed. Policy 17-3: Encourage and support the development of policy and regulation that will: 1. Register off-highway vehicles and make them identifiable in the field. 2. Provide for the safety of OHV users and non-users, water, wildlife and vegetation. 4. Provide for restoration of damaged lands. 5. Provide for the enforcement of such rules and regulations. 6. Provide for the recreational enjoyment of both OHV users and non-users. Policy 17-4: Encourage and support administration of money generated through offhighway vehicle registration that will: 1. Be administered by a balanced broad-based board with an emphasis on rural representation. 2. Provide public safety and enforcement. 3. Provide restoration and rehabilitation of damaged lands and trails. 4. Provide maintenance for existing trails. 5. Pay for new trail construction. 18.

Military Operations

Policy 18-1: Support a collaborative dialogue with the Department of Defense on the use of all public lands and air space for military operations. Policy 18-2: See Policy 10-4. 19.

Water Resources

Water is fundamental to White Pine County’s present and future. Water availability is essential for, and is the limit to, the economic future of White Pine County. The vegetation, wildlife, and landscapes of White Pine County are dependent on adequate water. The connection between groundwater and springs, streams, lakes, and wetlands is generally accepted by the scientific community. Policy 19-1: Promote the intent and policies of the White Pine County Water Resources Plan.

Sources Cited Bureau of Land Management (BLM). Illipah Reservoir Recreation Area, [accessed May 10, 2018]. <https://www.blm.gov/visit/illipah-reservoir-recreation-area> BLM. Ely District Record of Decision and Approved Resource Management Plan [Internet]. 2008. Washington D.C. BLM. [cited 2018/06/18]. Available from: <https://ia800207.us.archive.org/31/items/elydistrictrecor00unit/elydistrictrecor00u nit.pdf> Davis, David A., Geologic Information Specialist, Personal Communication, June 6, 2018. Hankins, Alicia, Land Law Examiner, Ely District Bureau of Land Management, Personal Communication, June 25, 2018. Henriod, Adam, Wildlife Area Supervisor II, Nevada Department of Wildlife, Personal Communication, June 15, 2018. Hinz, Nicholas H., Coolbaugh, Mark F., and Faulds, James E., 2015, Geothermal Resource Potential Assessment, White Pine County, Nevada; Nevada Bureau of Mines and Geology, Report 55 Intellicast. C2018. Historic Averages, East Ely, NV, [accessed June 16, 2018]. <http://www.intellicast.com/Local/History.aspx?month=2> Korell, Heath, Fisheries Biologist, Nevada Department of Wildlife, Personal Communication, June 15, 2018. Menghini, Kody, Game Biologist, Nevada Department of Wildlife, Personal Communication, June 25, 2018. Nevada State Parks. Cave Lake State Park, [accessed May 10, 2018]. <parks.nv.gov/parks/cave-lake> Nevada Department of Wildlife (NDOW). Bodies of Water, Comins Lake, [accessed May 10, 2018]. <http://www.ndow.org/bodies_of_water/Comins-Lake/> Nevada Department of Wildlife (NDOW). Bodies of Water, Bassett Lake, [accessed May 10, 2018]. <http://www.ndow.org/bodies_of_water/Bassett-Lake/> National Oceanic and Atmospheric Administration (NOAA). National Centers for

Environmental Information, Climate at a Glance: City Time Series, [accessed June 16, 2018]. < https://www.ncdc.noaa.gov/cag/city/time-series/USW00023154/tavg/12/7/20072017?base_prd=true&firstbaseyear=1895&lastbaseyear=2018&trend=true&trend_ base=10&firsttrendyear=1895&lasttrendyear=2018> Rajala, Erin, Recreation and Wilderness Program Manager, Ely District US Forest Service, Personal Communication, June 26, 2018. Sandoval, Tasheena, Caseworker, Ely State Prison, Personal Communication, June 6, 2018. State of Nevada Department of Taxation, The Official State of Nevada Website. c2017. Population of Nevada’s Counties and Incorporated Cities 2017 Governor’s Certified Series, [accessed May 28, 2018]. <https://tax.nv.gov/Publications/Population_Statistics_and_Reports/>

Index

Bureau of Land Management · See BLM Bureau of Reclamation · 2

A acreage · 4, 10 Advisory Committee · 6, 20, 21 Agency · 5, 6, 19, 20 agriculture · 16 air · 30, 31, 33, 34, 41 allotment · 27 amphibian · 15 anglers · 15 animal · 32 aquifer · 9 artifact · 16, 35 AUM · 25

B Baker · 1, 24 big game · 13, 15, 32 bird · 13, 15, 16 BLM · 2, 4, 5, 16, 22, 23, 28, 29, 30, 32, 33, 34, 36, 37, 38 Board · 6, 20, 21, 27, 32 Board of Commissioners · 6 boating · 10 Bureau of Indian Affairs · 2, 5

C camping · 10, 16 campsite · 16 carbonate · 8 Cave Lake · 4, 9, 10, 37 central · 1 Cherry Creek · 9, 24 cities · 17, 43 city · 1, 17, 42 Clark County · 40 climate · 6, 42 Comins Lake · 9, 37 Commission · 6, 20, 21, 23, 28, 29, 32 communication · 5, 20 compensation · 25 compliance · 24 conservation · 23, 25, 31, 37, 40 conserve · 22, 29 control · 2, 24, 34, 38, 39 cooperative agreement · 33 Cooperative Extension · 36 coordination · 19, 32 copper · 16, 19, 29 corridors · 9, 25, 37

44 cultural · 16, 23, 26, 34, 35, 36, 37 cutting · 28, 39

D damage · 36, 39 desert · 6, 15, 16 Department of Defense · 2, 4, 41 development · 2, 5, 9, 16, 20, 23, 24, 25, 27, 29, 30, 31, 36, 37, 38, 40, 41 dispersed · 37 disposal · 23, 24, 25, 33 drought · 7

E eagle · 15 eastern · 9, 16 economic · 2, 10, 19, 20, 22, 23, 24, 26, 28, 29, 31, 34, 36, 37, 38, 39, 40, 41 economy · 26, 27, 29 EIS · 25 Elko County · 1, 9 Ely · 1, 6, 7, 8, 16, 17, 23, 24, 32, 43 endangered · 32, 33 energy · 25, 34 enforcement · 32 entities · 23, 24, 27, 28 entity · 36 environmental · 5, 6, 25, 26, 32, 34, 42 Environmental Impact Statement · See EIS estimate · 18 Eureka · 1

F federal · 2, 4, 5, 16, 19, 20, 21, 22, 23, 24, 26, 27, 29, 30, 32, 33, 34, 36, 38, 39 fine · 4 fire · 24, 28, 35, 38, 39 fisheries · 28, 32, 38 fishing · 10, 15, 16, 24, 32, 37 forage · 28, 32, 40 forced · 27 forest · 27, 28 forestry · 27, 38 forum · 21 free · 28, 39, 40 Fremont · 16

G gases · 34 geographic · 8 geology · 8 gold · 15 government · 5, 25, 30 grass · 28 grazing · 27 Great Basin · 9, 15, 22, 23, 28, 34, 35, 36 greenhouse · 34

H habitat · 37 hearing · 6 highway · 36, 37, 40 hiking · 16, 24, 37 Hiko · 37 historic · 16, 22, 34, 35 history · 16, 36 horseback riding · 16 horses · 28 Humboldt · 32 hunting · 10, 13, 16, 24, 32, 37 hydrology · 9

I Ibapah · 1 Idaho · 1 Illipah · 9, 10, 37 implementation · 19 incentive · 27 income · 18 Indian · 2, 5, 16, 36 industrial · 9, 24, 29 industry · 10, 16, 27, 28, 29, 34 insect · 28 invasive · 28, 39, 40 irrigation · 9, 10

J juniper · 10, 11, 28 jurisdiction · 2

noxious · 39

land status · 3, 4 land use · 5, 6, 21, 26, 33 landscape · 8 Las Vegas · 1 law · 5, 25, 29, 33 Lincoln County · 1 Lincoln Highway · 37 livestock · 26 local · 5, 6, 20, 21, 23, 24, 25, 26, 28, 30, 34, 36, 37, 38, 40, 41 location · 1 Lund · 1, 17, 24, 37

O off-highway · See off-road off-road · 40, 41 OHV · 30, 36, 40, 41 Open Meeting Law · 21 open space · 36 opportunities · 5, 23, 36, 37 opportunity · 4, 25, 28, 30

mammal · 13 management · 2, 4, 5, 16, 20, 21, 22, 26, 27, 28, 29, 31, 32, 39, 40 McGill · 1, 17, 24 measure · 34 meeting · 6 military · 26, 33, 41 mine · 16,017, 19, 29, 30, 33 See Mining miner · 30 mineral · 16, 24, 26, 29, 30, 37 mining · 10, 16, 24, 29, 30, 33, 35, 36 motorized · 30 mountain · 6, 8, 9, 10, 15, 16, 32 multiple use · 20, 22, 23, 24, 26, 28, 29, 31, 32, 33, 36, 37 municipal · 10, 24, 25, 38 mutual · 38

Paiute · 16 permittee · 27 pinyon · 10, 28 plant · 38, 39, 40 PLUAC · 6, 20, 21, 22, 29, 32, 37 pond · 38 Pony Express Trail · 37 population · 1, 16, 17, 18, 19, 32, 43 precipitation · 6, 7 prehistoric · 16, 34, 35 preserve · 23 Preston · 24 private · 2, 23, 24, 25, 26, 27, 28, 29, 30, 33, 37, 38, 39 production · 21, 26, 27, 29, 30 project · 5, 25, 34, 40 protected · 15, 26, 27, 30, 34, 35, 36, 37, 38 public · 5, 6, 16, 20, 21, 22, 24, 26, 29, 30, 33, 35, 36, 37 public land · 4, 13, 19, 20, 21, 23, 27, 33, 38, 40

NAC · 15 national · 2, 4, 5, 20, 21, 25, 32, 36, 37, 42 National Park Service · See NPS, See NPS native · 15, 35 Native American · 35 natural resources · 20 NDF · 36, 38, 39 NDOT · See Nevada Department of Transportation NEPA · 5, 6, 20, 25 Nevada · 1, 2, 5, 6, 7, 8, 13, 15, 16, 17, 18, 19, 21, 27, 28, 29, 32, 33, 34, 38, 39, 40, 42, 43 Nevada Department of Wildlife · See NDOW Nevada Division of Forestry · See NDF NOAA · 6, 7, 8, 42 northeastern · 22

quality · 20, 22, 23, 30, 31, 34, 37 quarry · 19

R rain · 6, See precipitation ranching · 35 range · 9, 22, 25, 27 rangeland · 27 ranges · 6, 7, 8, 9 record · 8 recreation · 16, 23, 25, 29, 31, 36, 37, 40 refuge · 32

46 regional · 6 Reno · 1 reptile · 13 reservoir · 37, 42 resources · 9, 10, 15, 16, 20, 22, 24, 26, 27, 28, 29, 31, 32, 34, 35, 36, 37, 38, 39, 41 responsibility · 38 restore · 39 rights-of-way · 25 riparian · 27, 37, 38 road · 33, 37 rural · 35, 41 Ruth · 1, 17, 24

S safety · 33 sage grouse · 13 season · 7, 39 seasonal · 6, 13, 24 sheep · 13, 32 Sheriff · 33 Shoshone · 16 shrub · 28 silver · 37, 40 skiing · 10, 16 snow · 7 social · 34 southern · 1, 10 species · 10, 11, 13, 15, 16, 28, 32, 33, 39, 40 spring · 13 state · 2, 4, 5, 6, 13, 17, 18, 19, 20, 21, 25, 28, 29, 30, 32, 33, 36, 37, 40, 43 stone · 8 strategies · 27 strategy · 24 stream · 10 swimming · 10

T temperature · 8, 10, 11 thinning · 28, 39 threatened · 32, 33 tourism · 37 town · 35 trail · 36, 37, 40

transactions · 20, 21, 23, 24, 26 transportation · 9, 25, 33 travel · 15, 33 treatment · 40 tree · 11

U University of Nevada · See UNR UNR · 36 urban · 9, 25, 28, 30, 35 US Forest Service · 5, 21, 23, 28, 33, 34, 36, 37, 38, See USFS USFS · 5, 31 Utah · 1

V vegetation · 6, 11, 28, 34, 38, 41 vehicle · 36, 40, 41 village · 35

W water · 10, 38, 40, 41 water table · 11 waterfowl · 15, 38 waters · 37 watershed · 22 western · 7, 9 wetlands · 37, 38 White Pine County · 1, 2, 4, 5, 6, 7, 8, 9, 10, 11, 13, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 29, 30, 31, 32, 33, 34, 36, 37, 38, 39, 40, 41 wild · 28 wild horses · 28, 29 Wilderness · 25, 30, 31, 36, 37 wildlife · 2, 4, 5, 10, 13, 15, 21, 25, 32, 37, 42 wood · 39

Z zoning · 24, 26, 38

From: Katie McConnell <katie@kmlawnv.com> Sent: Wednesday, January 26, 2022 4:00 PM To: Kevin Baker <kbaker@rplusenergies.com> Cc: Luigi Resta <LResta@rplusenergies.com> Subject: RE: Letter to the United States Department of the Interior, Dated November 10, 2021 Caution! This message was sent from outside your organization.

Allow sender | Block sender

sophospsmartbannerend

Mr. Baker, Your email dated January 14, 2022 has been received by my office on behalf of the Uhalde family. Please accept this email as a continued notice and request that any communication with the Uhalde family regarding this project shall go through my office as the agent for the Uhalde family. Please ensure that all representatives of White Pine Waterpower, LLC or its affiliates stop contacting the Uhalde family directly, and instead direct the communication through my office. Thank you,

Ely District Record of Decision and Approved Resource Management Plan

August 2008 COOPERATING AGENCIES: Great Basin National Park Humboldt-Toiyabe National Forest Nellis Air Force Base Nevada Department of Transportation Nevada Division of Minerals Nevada Department of Wildlife Nevada State Historic Preservation Office

Lincoln County Nye County White Pine County Duckwater Shoshone Tribe Ely Shoshone Tribe Moapa Band of Paiutes Yomba Shoshone Tribe

BLM Mission Statement It is the mission of the Bureau of Land Management to sustain the health, diversity, and productivity of the public lands for the use and enjoyment of present and future generations.

BLM/NV/EL/PL-GI08/25+1793

Cover Photo: Cottonwood Canyon – Fortification Range Wilderness, Lincoln County, Nevada. Ely BLM photo. May, 2002.

ELY DISTRICT RECORD OF DECISION

AUGUST 2008

Ely District RMP Record of Decision

CONTENTS INTRODUCTION..................................................................................................................1 DECISION ............................................................................................................................3 Appeal Procedures for Implementation Decisions ........................................................3 PROPOSED PLAN AND ALTERNATIVES ........................................................................4 Alternatives Analyzed in Detail......................................................................................4 Environmentally Preferable Alternative .........................................................................5 MANAGEMENT CONSIDERATIONS .................................................................................5 Rationale for the Decision .............................................................................................5 MITIGATION MEASURES...................................................................................................6 PLAN MONITORING ...........................................................................................................6 PUBLIC INVOLVEMENT.....................................................................................................7 Endangered Species Act...............................................................................................8 Tribal Participation.........................................................................................................9 References ....................................................................................................................9

Ely District RMP Record of Decision LIST OF TABLES 1

Planning Area Land Administration/Ownership Status ............................................................................ 1

LIST OF MAPS

Planning Area for the Ely District RMP ..................................................................................................... 2

iii

Ely District RMP Record of Decision

INTRODUCTION This Record of Decision (ROD) approves the attached Resource Management Plan (RMP) to manage the public lands administered by the Bureau of Land Management’s (BLM's) Ely District Office. The Ely District Approved RMP is based on that described as the Proposed RMP in the November 2007 Ely Proposed RMP/Final Environmental Impact Statement (EIS) (U.S. Department of the Interior [USDI]-BLM 2007) with exceptions as noted in this ROD. The background and rationale for approving the proposed decisions contained in the Proposed RMP, as well as clarifications and modifications made to address protests to the Proposed RMP are described in this ROD. The attached Approved RMP constitutes the final decisions. The planning area for the Ely RMP consists of the geographic area within which the decisions contained in the Approved RMP would apply (Map 1). The planning area includes all lands regardless of jurisdiction; however, the approved RMP decisions only apply to public lands administered by the Ely District Office in Lincoln, White Pine, and a portion of Nye counties in east-central Nevada. The decision area also includes those private lands on which there is “split estate,” and BLM continues to manage surface or subsurface interests. The planning area measures approximately 230 miles (north-south) by 115 miles (east-west). The decision area is managed as a single administrative unit. Table 1 summarizes the land administration/ownership in the planning area. Table 1 Planning Area Land Administration/Ownership Status Administration/Ownership U.S. Department of the Interior Bureau of Land Management National Park Service Bureau of Indian Affairs Fish and Wildlife Service U.S. Department of Agriculture Forest Service U.S. Department of Defense State of Nevada Private Total

Acres 11,463,419 77,128 73,555 282,995 825,136 778,010 34,131 392,978 13,927,352

Regional View 30 225 232 80

766

229

227

304

228

306

305

Elko County

100

200 Miles

93 Alt

Legend Cities and towns 489

Eureka County

U.S. highway

Cherry Creek

892 50

McGill

Utah

White Pine County

278

Nevada

Lander County

Interstate

Roads County boundary State boundary

893

Planning area

486

Ely 50

Baker 487

Lund

379 82

894 6 21

Nye County

Pioche 375

Lincoln County Panaca 318

25 56

Hiko

120

Caliente

12.5

25 Miles

18 317

Alamo

Nevada

Clark County

Utah Arizona

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data. Original data were compiled from various sources. This information may not meet National Map Accuracy Standards. This product was developed through digital means and may be updated without notification.

168

a ad ia ev rn ifo al

12 95

Ely District ROD/Approved RMP

Las Vegas

Map 1 Planning Area for the Ely District RMP

93 15

95 165

Ely District RMP Record of Decision

DECISION The decision is hereby made to approve the attached RMP for the Ely District BLM. This plan was prepared under the regulations implementing the Federal Land Policy and Management Act of 1976 (43 Code of Federal Regulations Part 1600). An EIS was prepared for this RMP in compliance with the National Environmental Policy Act (NEPA) of 1969. The Approved RMP is based upon that described in the Ely District Proposed RMP/Final EIS published in November 2007. Specific management decisions for public lands and minerals under the jurisdiction of the Ely District are presented in the section titled “Resource Management Plan.” This ROD serves as the final decision for the land use plan decisions described in the Approved Plan and becomes effective on the date this ROD is signed. No further administrative remedies are available at this time for these land use plan decisions.

Appeal Procedures for Implementation Decisions The decision identifying designated routes of travel for motorized vehicles in Duck Creek Basin (Management Action TM-3) is an implementation decision and appealable to the Interior Board of Land Appeals under 43 Code of Federal Regulations Part 4, upon approval of this ROD. This decision is contained in the Travel Management section of the Approved RMP. Any party adversely affected by the BLM's decision(s) to identify, evaluate, define, delineate, and/or select specific routes as available for motorized use within designated areas of travel as set forth in the Ely RMP may appeal within 30 days of publication of the Notice of Availability, in accordance with the U.S. Department of the Interior’s appeal regulations (43 Code of Federal Regulations Part 4). The appeal should state the specific route(s) by section, township, and range on which the decision is being appealed, and be submitted to the Ely District Manager at the following address: Bureau of Land Management Ely District Office HC 33 Box 35500 Ely, Nevada 89301-9408 The appeal may include a statement of reasons at the time the notice of appeal is filed, or the statement of reasons may be filed within 30 days of filing the appeal. A copy of the notice of appeal, statement of reasons, and all supporting documentation also must be sent to the following address: Regional Solicitor, Pacific Southwest Region U.S. Department of the Interior 2800 Cottage Way Room E-2753 Sacramento, CA 95825-1890

Ely District RMP Record of Decision If a statement of reasons is filed separately from the notice of appeal, it also must be sent to the following location within 30 days after the notice of appeal was filed: Board of Land Appeals Office of Hearings and Appeals 4015 Wilson Boulevard Arlington, VA 22203

PROPOSED PLAN AND ALTERNATIVES Five alternatives, including a no action alternative, were analyzed in detail in the Proposed RMP/Final EIS. Alternatives were developed to include different combinations of management direction to address issues and resolve conflicts among resources and resource uses. In addition to addressing issues, alternatives must meet the purpose and need stated for the RMP, must not be remote or speculative, and must be technically and economically practical or feasible. Each alternative was a complete land use plan that provided a framework for multiple use management of the full spectrum of resources, resource uses, and resource programs within the planning area. Under all alternatives except Alternative D, the Ely District Office would manage the public lands in accordance with all applicable laws, regulations, and BLM policy and guidance, and to meet the Resource Advisory Council standards for rangeland health. As noted in the discussion below, Alternative D was not consistent with all existing laws, regulations, and policies.

Alternatives Analyzed in Detail The Proposed RMP was initially presented as Alternative E (the Preferred Alternative) in the Draft RMP/EIS (July 2005) (BLM 2005). The Proposed RMP provides a framework for vegetation management on the basis of currently available scientific knowledge to modify vegetation communities in a manner to enhance ecological health and resilience. The Proposed RMP balances the need to restore, enhance, and protect resources, with the public’s desire to provide for the production of food, fiber, minerals, and services on public lands. This would be accomplished within the limits of an ecological system’s ability to sustainably provide these products and services within the constraints of various laws and regulations. Alternative A is the continuation of existing management in the decision area and comprises the “No Action Alternative.” This alternative continues present management based on existing land use plans and other decision documents. Direction contained in existing laws, regulation, and policy also continued to be implemented. Under Alternative A, resources, resource uses, and sensitive habitats receive management emphasis (methods and mix of multiple use management of public land) at present levels. In general, most activities would be analyzed on a case-by-case basis, and few uses would be limited or excluded as long as land health standards could be met. Alternative B emphasizes the maintenance of functioning and healthy ecological systems and the restoration of ecological systems and their historic mosaic patterns that have been degraded or altered. Commodity production is constrained to protect resources and systems displaying healthy ecological processes or to accelerate improvement in those areas that did not. Production of food, fiber, minerals, and

Ely District RMP Record of Decision services are more constrained than in the other alternatives, and in some cases and some areas, uses are excluded to protect sensitive resources. Alternative C emphasizes commodity production and production of food, fiber, minerals, and services, including provisions for several types of recreation. Under this alternative, constraints on commodity production for the protection of sensitive resources are the least restrictive possible within the limits defined by law, regulation, and BLM policy, including the Endangered Species Act, cultural resource protection laws, and wetland preservation. In this alternative, constraints to protect sensitive resources would be implemented in specified geographic areas rather than across the entire Ely RMP planning area. Alternative D excludes all permitted, discretionary uses of the public lands including livestock grazing, mineral sale or leasing, lands and realty actions (such as disposals, leases, and rights-of-way), recreation uses requiring permits, etc. Some components of Alternative D could be implemented through the discretionary authority of the Ely District Manager or the Nevada State Director, while others would require action by the Secretary of the Interior or new legislation by Congress. This alternative was included in the Proposed RMP/Final EIS in response to scoping comments for the RMP, which requested the elimination of certain uses of the public lands in the RMP planning area. It set a baseline for the comparison of impacts from management actions included in other alternatives and allowed for the analysis of a range of management actions in the EIS. This alternative allows no commodity production and includes management actions necessary to maintain or enhance resources and protect life and property.

Environmentally Preferable Alternative The Proposed RMP, as the agency Preferred Alternative and Proposed Action, is considered the environmentally preferable alternative based on a balance between the human (social and economic) environment as well as addressing the need to restore, enhance, and protect the natural environment.

MANAGEMENT CONSIDERATIONS Rationale for the Decision The decision to approve the Proposed Plan takes in account statutory, regulatory, and national policy considerations. The decision also was based on review and comment of public, industry, federal, tribal, state and local governments and agencies, as well as the 14 cooperating agencies that participated in the planning process. BLM has determined that the Proposed Plan (as modified in consideration of public and agency comments and public protest) is the most consistent with its legal mandates while incorporating the best management practices identified through agency and public consultation. Through the review process, all practicable methods to reduce environmental harm were incorporated into the Approved Plan. The Approved Plan best addresses the diverse needs within the Planning Area within a comprehensive framework for the management of public lands.

Ely District RMP Record of Decision

MITIGATION MEASURES The Approved RMP includes all practical measures to avoid or minimize environmental impacts. Management actions identified in the Approved RMP were developed based on best management practices (Appendix A of the Approved RMP) and agency input, including the Biological Opinion (U.S. Fish and Wildlife Service 2008) (Appendix D of the Approved RMP), to ensure compliance with applicable laws and standards. The Ely Proposed RMP/Final EIS identified five potential mitigation measures in addition to the standard operating procedures and best management practices included in the RMP (Section 4.29 of the Proposed RMP/Final EIS). Three of the five proposed mitigation measures were selected for adoption and included in the Approved Plan and two proposed mitigation measures were not carried forward as they were already addressed more broadly under other management actions included in the Approved Plan. The mitigation measures adopted into the Approved RMP are Proposed Mitigation Measure 1, modified and included under Management Action FM-7; Proposed Mitigation Measure 2, included in Management Action REC-4; and Proposed Mitigation Measure 5, Option 1, included under Management Action LR-24. These approved mitigation measures are consistent with BLM authority. Additional measures to avoid or mitigate environmental impacts associated with future actions may be developed during NEPA analysis for those actions at the planning and project stages.

PLAN MONITORING The BLM planning regulations (43 Code of Federal Regulations 1610.4-9) require the monitoring of RMPs on a continual basis with a formal evaluation done at periodic intervals. All BLM Nevada land use plans are monitored and formally evaluated at 5-year intervals after the plan is approved. In some cases, formal evaluations may occur more frequently than every 5 years, if appropriate. Monitoring plan decision implementation is an essential component of natural resources management because it provides information on the relative success of RMPs and specific management strategies. Implementation monitoring will be completed annually and will be documented in a tracking log or report, which will be available to the public. Effectiveness monitoring strategies will be developed as allowable uses and management actions are implemented Monitoring for each resource program is outlined in the “Management Decisions” section of the Approved Plan. Monitoring also is an integral part of adaptive management and is a key component to achieving the management goals and objectives of the RMP. Tracking the progress of management actions and measuring changes resulting from these activities is important in either determining success or the need for a different management approach. Monitoring results will provide information to determine whether objectives have been met, and whether to continue or modify the management actions. Findings obtained through monitoring, together with research and other new information will provide a basis for adaptive management changes. Within this framework, if monitoring shows land use plan actions or best management practices are not effective, the BLM may modify or adjust management without amending or revising the plan if we are in conformance with the Approved Plan. In those cases where the BLM considers implementing actions that will alter or not conform to the overall direction of the Approved Plan, the BLM will prepare a plan amendment or revision and environmental analysis of appropriate scope.

Ely District RMP Record of Decision

PUBLIC INVOLVEMENT Public participation for this planning effort began with the publication of the Federal Register Notice of Intent (Federal Register Vol. 68 No. 27, pages 6770-6771, Monday, February 10, 2003) to prepare a RMP. With this Notice of Intent, individuals and organizations were invited to submit comments in writing to the BLM and cooperating agencies were invited to participate in the planning process. Several governmental agencies and tribes agreed to serve as cooperating agencies and had varying levels of involvement in the development of the Draft RMP/EIS. These agencies and tribes continued to be involved through preparation of the Proposed RMP/Final EIS. Cooperating agencies that participated in the development of the Ely RMP/EIS are: • • • • • • •

• • • • • • •

Great Basin National Park Humboldt-Toiyabe National Forest Nellis Air Force Base Nevada Department of Transportation Nevada Department of Wildlife Nevada Division of Minerals Nevada State Historic Preservation Office

Lincoln County Nye County White Pine County Duckwater Shoshone Tribe Ely Shoshone Tribe Moapa Band of Paiutes Yomba Shoshone Tribe

Six public scoping meetings were held in March and April 2003. Ninety-three (93) letters were received via mail, fax, e-mail, an on-line web comment form, or handed in during the scoping meetings. These letters from individuals and organizations contained 798 unique comments for consideration in the planning process. As documented in the Scoping Report, issues identified were evaluated for their applicability to be addressed through alternatives. A Notice of Availability was published in the Federal Register (Vol. 70, No. 145, pages 43902-43903, Friday, July 29, 2005) announcing the availability of the Ely Draft RMP/EIS for public review and comment for a 120-day formal comment period that ended on November 28, 2005. Six public meetings on the Draft RMP/EIS were held in October, 2005. Six hundred and fifty comment letters on the Draft RMP/EIS were received via U.S. mail and email. These included 81 unique letters and 569 form letters. From these letters, 1,667 comments were identified in the set of comment letters received on the Draft RMP/EIS. All public comments were responded to in the Proposed RMP/Final EIS. A Notice of Availability was published in the Federal Register (Vol. 72 No. 230, pages 67748-67750, Friday, November 30, 2007,) announcing the availability of the Ely Proposed RMP/Final EIS. This began a 30-day protest period that ended December 30, 2007, and a 60-day governor’s consistency review in accordance with planning regulations at 43 Code of Federal Regulations Part 1610.3-2(e), which ended on January 29, 2008. Copies of the Proposed Plan were mailed to over 1,200 agencies, organizations, and individuals. The Governor’s Office did not identify any inconsistencies between the Proposed RMP/Final EIS and state or local plans, policies, or programs during the 60-day Governor’s Consistency Review.

Ely District RMP Record of Decision Six protest letters were received by BLM during the 30-day protest period provided of the management actions contained in the Ely Proposed RMP/Final EIS. Protesting parties consisted of: y y y y y

Clay Iverson Center for Biological Diversity Cindy MacDonald Western Watersheds Project (submitted two protest letters) Craig Downer

Based on previous involvement in the planning process, only two of the protesting parties were determined to have standing as defined in the BLM Land Use Planning Handbook (H 1601-1). Main protest points pertained to the following: management of grazing within the planning area; effects of management actions on threatened and endangered species and species of concern (including wild horses); inadequate analysis of impacts of management actions on global warming, cultural resources, and visual resources; area of critical environmental concern (ACEC) designation and management; management associated with vegetation resources and control of weeds; limited analysis of alternatives; effects of management actions on recreation and off-highway use vehicles; and concern that land disposals were not well defined and did not meet a no net loss criteria. The Director reviewed all valid protests, and letters responding to the protests were signed on June 20, 2008. No changes to the Proposed RMP were made as a result of the Director’s review of the protests. One letter provided by a protesting party determined to not have standing did include a comment determined to be germane to the planning process. This comment pertained to the location and designation of the Hendry’s Creek/Rock Animal Corral ACEC. Due to this comment, the BLM State Director reevaluated the location and need for the proposed ACEC to protect the resources at the Rock Animal Corral Archaeological Site. Based on this re-evaluation, the BLM State Director determined that the area proposed for designation of the Hendry’s Creek/Rock Animal Corral ACEC is not necessary to protect the relevant and important values of the historic property, and the Approved RMP has been modified to reflect this determination.

Endangered Species Act Formal consultation with the U.S. Fish and Wildlife Service was initiated by BLM for the Ely Proposed RMP/Final EIS under Section 7 of the Endangered Species Act of 1973 (as amended). Based on the list of federally listed, proposed, and candidate species and BLM sensitive species addressed in the Proposed RMP/Final EIS and the biological assessment, the U.S. Fish and Wildlife Service has issued a formal Biological Opinion (Appendix D) that includes terms and conditions to minimize impacts to federally listed, proposed, and candidate species, as well as BLM sensitive species.

Ely District RMP Record of Decision

Tribal Participation As a federal agency, the BLM is mandated to consult with American Indian tribes concerning the identification of cultural values, religious beliefs, and traditional practices of American Indian people, as well as other possible environmental and social concerns that may be affected by actions on federal lands. Consultation for the Ely RMP/EIS was initiated with Western Shoshone, Goshute, and Southern Paiute reservations, colonies, organizations, and individuals. The Western Shoshone included the Te-Moak Tribes, Battle Mountain Band, Elko Band, South Fork Band, Wells Band, Duckwater Shoshone Tribe, Ely Shoshone Tribe, Timbisha Shoshone Tribe, Yomba Shoshone Tribe, Duck Valley Sho-Pai Tribes, the Western Shoshone Historic Preservation Society, Nevada Indian Commission, Intertribal Council of Nevada, and Western Shoshone Defense Project. Included for the Goshute were the Goshute Tribe (Ibapah) and Skull Valley Band of Goshute. The Southern Paiute included the Paiute Tribe of Utah, Las Vegas Paiute Tribe, Moapa Paiute Tribe, the Colorado Indian Tribes, the Chemehuevi Tribe, and individuals residing in Eagle Valley and Caliente. Tribal concerns identified through this consultation process were addressed during preparation of the Ely District RMP and are reflected in the Approved RMP to the extent practicable.

References Bureau of Land Management (BLM). 2007. Ely Proposed Resource Management Plan/Final Environmental Impact Statement for the Ely District. U.S. Department of the Interior, Bureau of Land Management, Ely Field Office, Ely, Nevada. November 2007. U.S. Department of the Interior – BLM. 2005. Draft Resource Management Plan/Environmental Impact Statement for the Ely District. U.S. Department of the Interior, Bureau of Land Management, Ely Field Office, Ely, Nevada. July 2005. U.S. Fish and Wildlife Service. 2008. Programmatic Biological Opinion (84320-2008-F-0078), Informal Consultation (84320-2008-I-0079), and Technical Assistance (84320-2008-TA-0080) for the Bureau of Land Management's Ely District Resource Management Plan. Nevada Fish and Wildlife Office, Las Vegas, Nevada. July 2008. 238 p.

ELY DISTRICT APPROVED RESOURCE MANAGEMENT PLAN

AUGUST 2008

Ely District Approved Resource Management Plan

CONTENTS

INTRODUCTION AND BACKGROUND .............................................................................1 Purpose of and Need for the Plan .................................................................................1 Planning Area and Maps ...............................................................................................3 Notice of Modifications ..................................................................................................6 Hendry’s Creek/Rock Animal Corral ACEC....................................................................................... 6 Pony Express Trail.............................................................................................................................. 6

Legislative Constraints ..................................................................................................7 Lincoln County Conservation, Recreation, and Development Act of 2004 ...................................... 7 White Pine County Conservation, Recreation, and Development Act of 2006 ................................ 7 Resource Advisory Councils .............................................................................................................. 8

Planning Process...........................................................................................................8 Relationship to Federal, State, Local and Tribal plans, Other Stakeholder Relationships .............. 8

Related Plans ..............................................................................................................12 State and Local Plans....................................................................................................................... 12 Federal Plans.................................................................................................................................... 15 Tribal Plans ....................................................................................................................................... 16 Consistency with Other Programs, Plans, and Policies .................................................................. 16

Public Involvement ......................................................................................................18 Management Plan Implementation .............................................................................19 Priorities ............................................................................................................................................ 19 Costs ................................................................................................................................................. 19

Plan Evaluation and Adaptive Management ...............................................................19 Plan Monitoring ................................................................................................................................. 19 Land Use Plan Evaluations .............................................................................................................. 20 Adaptive Management...................................................................................................................... 20

Ely District Approved Resource Management Plan CONTENTS (Cont’d)

MANAGEMENT DECISIONS ............................................................................................21 Air Resources ..............................................................................................................21 Goals – Air Resources...................................................................................................................... 21 Objectives – Air Resources .............................................................................................................. 22 Management Actions – Air Resources ............................................................................................ 22 Monitoring– Air Resources ............................................................................................................... 22

Water Resources.........................................................................................................22 Goals – Water Resources ................................................................................................................ 23 Objectives – Water Resources......................................................................................................... 23 Management Actions – Water Resources ....................................................................................... 23 Monitoring – Water Resources......................................................................................................... 23

Soil Resources ............................................................................................................24 Goals – Soil Resources.................................................................................................................... 24 Objectives – Soil Resources ............................................................................................................ 24 Management Actions – Soil Resources........................................................................................... 25 Monitoring – Soil Resources ............................................................................................................ 25

Vegetation Resources .................................................................................................25 Goals – Vegetation Resources ........................................................................................................ 26 Objectives – Vegetation Resources................................................................................................. 26 Management Actions – Vegetation Resources ............................................................................... 26 Monitoring – Vegetation Resources................................................................................................. 33

Fish and Wildlife ..........................................................................................................33 Goals – Fish and Wildlife.................................................................................................................. 34 Objectives – Fish and Wildlife .......................................................................................................... 34 Management Actions – Fish and Wildlife......................................................................................... 35 Monitoring – Fish and Wildlife .......................................................................................................... 37

Special Status Species................................................................................................37 Goals – Special Status Species....................................................................................................... 37 Objectives – Special Status Species ............................................................................................... 38 Management Actions – Special Status Species.............................................................................. 39 Monitoring – Special Status Species ............................................................................................... 45

Wild Horses .................................................................................................................46 Goals – Wild Horses......................................................................................................................... 46 Objectives – Wild Horses ................................................................................................................. 46

Ely District Approved Resource Management Plan CONTENTS (Cont’d) Management Actions – Wild Horses................................................................................................ 47 Monitoring – Wild Horses ................................................................................................................. 49

Cultural Resources ......................................................................................................49 Goals – Cultural Resources ............................................................................................................. 49 Objectives – Cultural Resources...................................................................................................... 50 Management Actions – Cultural Resources .................................................................................... 50 Monitoring – Cultural Resources...................................................................................................... 62

Paleontological Resources..........................................................................................62 Goals – Paleontological Resources ................................................................................................. 62 Objectives – Paleontological Resources ......................................................................................... 63 Management Actions – Paleontological Resources........................................................................ 63 Monitoring – Paleontological Resources ......................................................................................... 63

Visual Resources.........................................................................................................63 Goals – Visual Resources ................................................................................................................ 64 Objectives – Visual Resources ........................................................................................................ 64 Management Actions – Visual Resources....................................................................................... 64 Monitoring – Visual Resources ........................................................................................................ 64

Lands and Realty.........................................................................................................64 Goals – Lands and Realty ................................................................................................................ 65 Objectives – Lands and Realty ........................................................................................................ 66 Management Actions – Lands and Realty....................................................................................... 66 Monitoring – Lands and Realty ........................................................................................................ 73

Renewable Energy ......................................................................................................73 Goals – Renewable Energy.............................................................................................................. 73 Objectives – Renewable Energy...................................................................................................... 73 Management Actions – Renewable Energy .................................................................................... 74 Monitoring – Renewable Energy...................................................................................................... 74

Travel Management ....................................................................................................74 Goals – Travel Management............................................................................................................ 75 Objectives – Travel Management .................................................................................................... 75 Management Actions – Travel Management................................................................................... 76 Monitoring – Travel Management .................................................................................................... 78

iii

Ely District Approved Resource Management Plan CONTENTS (Cont’d)

Recreation ...................................................................................................................78 Goals – Recreation........................................................................................................................... 79 Objectives – Recreation ................................................................................................................... 79 Management Actions – Recreation.................................................................................................. 79 Monitoring – Recreation ................................................................................................................... 84

Livestock Grazing........................................................................................................85 Goals – Livestock Grazing ............................................................................................................... 85 Objectives – Livestock Grazing........................................................................................................ 86 Management Actions – Livestock Grazing ...................................................................................... 86 Monitoring – Livestock Grazing........................................................................................................ 88

Forest/Woodland Products..........................................................................................88 Goals – Forest/Woodland Products................................................................................................. 88 Objectives – Forest/Woodland Products ......................................................................................... 88 Management Actions – Forest/Woodland Products........................................................................ 89 Monitoring – Forest/Woodland Products ......................................................................................... 91

Geology and Mineral Extraction ..................................................................................91 Goals – Geology and Mineral Extraction ......................................................................................... 92 Objectives – Geology and Mineral Extraction.................................................................................. 92 Management Actions – Geology and Mineral Extraction ................................................................ 94 Monitoring – Geology and Mineral Extraction................................................................................ 103

Watershed .................................................................................................................104 Goals – Watershed......................................................................................................................... 104 Objectives – Watershed ................................................................................................................. 105 Management Actions – Watershed................................................................................................ 105 Monitoring – Watershed ................................................................................................................. 106

Fire.............................................................................................................................106 Goals – Fire .................................................................................................................................... 106 Objectives – Fire............................................................................................................................. 106 Management Actions – Fire ........................................................................................................... 106 Monitoring – Fire............................................................................................................................. 109

Noxious and Invasive Weeds....................................................................................109 Goals – Noxious and Invasive Weeds ........................................................................................... 109 Objectives – Noxious and Invasive Weeds ................................................................................... 109 Management Actions – Noxious and Invasive Weeds.................................................................. 110 Monitoring – Noxious and Invasive Weeds ................................................................................... 111

Ely District Approved Resource Management Plan CONTENTS (Cont’d)

Special Designations Management...........................................................................112 Goals – Special Designations Management.................................................................................. 112 Objectives – Special Designations Management .......................................................................... 112 Management Actions – Special Designations Management ........................................................ 112 Monitoring – Special Designations Management .......................................................................... 121

REFERENCES.................................................................................................................122

APPENDIX A – BEST MANAGEMENT PRACTICES Appendix A.1 Appendix A.2 Appendix A.3

Resource Program Best Management Practices BLM Wind Energy Best Management Practices Fluid Minerals Lease Notices and Stipulations

APPENDIX B – LEGAL DESCRIPTIONS FOR LAND DISPOSAL APPENDIX C – LEGAL DESCRIPTIONS AND MAPS FOR AREAS OF CRITICAL ENVIRONMENTAL CONCERN APPENDIX D – BIOLOGICAL OPINION APPENDIX E – GRAZING ALLOTMENT STATUS APPENDIX F – MAPS

Ely District Approved Resource Management Plan LIST OF TABLES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

Planning Area Land Administration/Ownership Status.............................................................................. 3 Desired Range of Conditions of Pinyon-Juniper (Distribution of Woodland Phases and States) .......... 27 Desired Range of Conditions of Aspen (Distribution of Phases and States) .......................................... 28 Desired Range of Conditions of High Elevation Conifer (Distribution of States and Phases)................ 29 Desired Range of Conditions of Ponderosa Pine (Distribution of States and Phases) .......................... 29 Desired Range of Conditions of Salt Desert Shrub (Distribution of Phases and States) ....................... 30 Desired Range of Conditions of Sagebrush (Distribution of Phases and States)................................... 30 Desired Range of Conditions of Mountain Mahogany (Distribution of Phases and States)................... 31 Desired Range of Conditions of Creosotebush and Bursage (Distribution of Phases and States) ....... 32 Desired Range of Conditions of Blackbrush (Distribution of Phases and States) .................................. 32 Desired Range of Conditions of Seedings (Distribution of Phases and States) ..................................... 33 Herd Management Areas.......................................................................................................................... 47 Herd Management Areas Dropped .......................................................................................................... 48 Summary of Limitations for Non-speed Off-highway Vehicle Events Within Desert Tortoise ACECs......................................................................................................................................... 82 Allotments Within Desert Tortoise Habitat but Outside ACECs .............................................................. 87 Summary of Fluid Mineral Leasing Acreages .......................................................................................... 95 Timing and Surface Use Stipulations ....................................................................................................... 96 No Surface Occupancy for Fluid Mineral Leasing.................................................................................. 98 Areas Closed to Fluid Mineral Leasing ................................................................................................... 99 Summary of Solid Mineral Leasing........................................................................................................... 99 Areas Closed to Solid Leasable, Locatable, and Mineral Materials.................................................... 101 Summary of Locatable Minerals ............................................................................................................. 102 Summary of Mineral Materials ................................................................................................................ 102 Watershed Priority for Analysis and Treatment ..................................................................................... 105 Summary of Fire Management Units for the Ely District Office ............................................................. 107 Management Prescriptions for ACECs ................................................................................................. 113

LIST OF MAPS 1 2

Planning Area for the Ely District Approved Resource Management Plan ............................................... 4 Land Status within the Planning Area......................................................................................................... 5

vii

Ely District Approved Resource Management Plan

INTRODUCTION AND BACKGROUND This section contains background information on the planning process and sets the stage for the information that is presented in the rest of the document. There are nine main discussions in this section. They are: y y y y y y y y y

Purpose of and Need for the Plan Planning Area and Maps Notice of Modifications Legislative Constraints Planning Process Related Plans Public Involvement Management Plan Implementation Plan Evaluation/Adaptive Management

Section 102 of the Federal Land Policy and Management Act directs the BLM to prepare land use plans that serve as the basis for all activities that occur on BLM-administered lands. “The national interest will be best realized if the public lands and their resources are periodically and systematically inventoried and their present and future use is projected through a land use planning process coordinated with other Federal and State planning efforts.” Section 202 of the Federal Land Policy and Management Act requires that “the Secretary shall, with public involvement … develop, maintain, and when appropriate, revise land use plans.” Across the country, the first generation of BLM land use plans was prepared in the late 1970s and early 1980s. Within the Ely District Office, one RMP and one Management Framework Plan (MFP) were prepared in this timeframe. In 1996, management of the Caliente Resource Area was transferred from the Las Vegas District Office to the Ely District Office. The Caliente Resource Area also was covered by an MFP. Even with periodic amendments, these three 15- to 20 year-old plans no longer meet the management needs of the Ely District Office. This RMP is expected to serve the management direction needs of the Ely District Office for the foreseeable future. The Approved Ely RMP would remain in effect as long as the management direction contained in the Plan is valid in light of scientific understanding and current management needs. It is BLM policy to evaluate RMPs every 5 years to determine if a plan revision or amendment is needed in response to changing conditions over time. The Plan would be updated and amended periodically to maintain its effectiveness as long as practical. When the Plan reaches the end of its effective life, a new plan would be prepared. The life of an RMP is typically about 20 years.

Purpose of and Need for the Plan The purpose of the Approved RMP is to provide direction for management of renewable and nonrenewable resources found on public lands within the Ely planning area and to guide decision-making for future site-specific actions. The Approved RMP will direct the Ely District Office in resource management activities including leasing minerals such as oil and gas; construction of electrical transmission lines, gas pipelines, and roads; grazing management; recreation and outfitting; preserving and restoring wildlife habitat; selling or

Ely District Approved Resource Management Plan exchanging lands for the benefit of local communities; military use of the planning area; and conducting other activities that require land use planning decisions. The need for the action is to consolidate, update, and establish appropriate goals, objectives, management actions, priorities, and procedures, within a multiple-use management context, for all BLM public land resource programs administered by the Ely District Office. The RMP is needed to provide a land use plan consistent with current laws, regulations, and policies, and to update resource management direction to allow Ely District Office managers to meet nationwide BLM goals and objectives and to ensure their actions are consistent with current BLM policy. The Approved RMP also is needed to facilitate implementation of the Great Basin Restoration Initiative, a regional initiative to implement actions to maintain or improve ecological health at the landscape scale. This Approved Resource Management Plan provides direction and guidance for the management of approximately 11.5 million acres of public land and minerals located in Lincoln, White Pine, and a portion of Nye counties in eastern Nevada that are administered by the BLM Ely District Office. The Ely Approved RMP consolidates the Schell and Caliente Management Framework Plans approved in 1983 and 1981, respectively, the Egan Resource Management Plan approved in 1987, the Egan Resource Management Plan Oil and Gas Leasing Amendment and Record of Decision, May 1994, and the Approved Caliente Management Framework Plan Amendment and Record of Decision for the Management of Desert Tortoise Habitat, September 2000, and focuses on the principles of multiple use and sustained yield as prescribed by Section 202 of the Federal Land Policy and Management Act of 1976. Issues addressed during the formulation of the Approved RMP include maintenance and restoration of resiliency to disturbed ecological systems within the portion of the Great Basin administered by the Ely District Office, protection and management of habitats for special status species, upland and riparian habitat management, noxious weeds, commercial uses (including livestock grazing, mineral development, oil and gas leasing, rights-of-way, and communication use areas), Areas of Critical Environmental Concern, travel management, land disposal, and wild horses. The Approved RMP primarily is based on the Proposed RMP alternative presented in the Proposed RMP/Final EIS (November 2007), and is a compilation of those individual management actions from the other four alternatives, plus unique management actions, that the Ely District Office believes will best meet its obligations for multiple use management of the resources found within the planning area. Management actions in the Proposed RMP were developed through consideration of the planning criteria, public protests, BLM policy especially as presented in the Land Use Planning Handbook, the professional judgment of the staff in the Ely District Office, and comments from a wide array of users of the planning area. The management actions that are presented in the Approved RMP are based on those in the Proposed RMP; changes made in response to protest letters received, governor’s consistency review, and the Biological Opinion are discussed within this document.

Ely District Approved Resource Management Plan

Planning Area and Maps The planning area for the Ely RMP/EIS consists of the geographic area within which the BLM Ely District Office would make land management decisions (see Map 1). The planning area includes all lands regardless of jurisdiction; however, the BLM would only make decisions on lands that fall under BLM's jurisdiction. Map 2 shows the land status within the planning area. The “decision area” consists of public lands administered by the Ely District Office in White Pine, Lincoln, and a portion of Nye counties in eastcentral Nevada. The “decision area” also includes those private lands on which there is “split estate,” and the BLM continues to manage subsurface mineral commodities. The planning area measures approximately 230 miles (north-south) by 115 miles (east-west). Table 1 summarizes the land administration/ownership in the planning area. Table 1 Planning Area Land Administration/Ownership Status Administration/Ownership U.S. Department of the Interior Bureau of Land Management National Park Service Bureau of Indian Affairs Fish and Wildlife Service U.S. Department of Agriculture Forest Service U.S. Department of Defense State of Nevada Private Total

Acres 11,463,419 77,128 73,555 282,995 825,136 778,010 34,131 392,978 13,927,352

Regional View 30 225 232 80

766

229

227

304

228

306

305

Elko County

100

200 Miles

93 Alt

Legend Cities and towns 489

Eureka County

U.S. highway

Cherry Creek

892 50

McGill

Utah

White Pine County

278

Nevada

Lander County

Interstate

Roads County boundary State boundary

893

Planning area

486

Ely 50

Baker 487

Lund

379 82

894 6 21

Nye County

Pioche 375

Lincoln County Panaca 318

25 56

Hiko

120

Caliente

12.5

25 Miles

18 317

Alamo

Nevada

Clark County

Utah Arizona

168

a ad ia ev rn ifo al

12 95

Ely District ROD/Approved RMP

Las Vegas

Map 1 Planning Area for the Ely District RMP

93 15

95 165

Regional View

489

Cherry Creek

100

200 Miles

892

Legend Cities and Towns

McGill 893

Roads 50

Ely

County boundary Land Status

486

Bureau of Indian Affairs

BLM 50

Private

487

Department of Defense U.S. Fish and Wildlife Service

Lund

379

White Pine County

National Park Service

894

State of Nevada Nye County

U.S. Forest Service

318

322

Pioche

12.5

320 321

Lincoln County

25 Miles

320

Panaca

319

318

Caliente

375

93 317

Hiko

Alamo

Ely District ROD/Approved RMP 93

Map 2 Land Status within the Planning Area

Ely District Approved Resource Management Plan

Notice of Modifications As a result of protests on the Proposed RMP/Final EIS and continuing internal review, BLM made two substantive modifications to the Proposed Plan. Discussions associated with the Management Decisions in the Approved RMP have been adjusted to reflect these modifications. Hendry’s Creek/Rock Animal Corral ACEC To resolve an issue identified within a protest letter, BLM modified management actions in the Approved RMP to reflect not designating the Hendry’s Creek/Rock Animal Corral ACEC, but maintaining the Rock Animal Corral Archaeological Site under previous management. The Proposed RMP/Final EIS proposed the designation of 3,650 acres as the Hendry’s Creek/Rock Animal Corral ACEC for the protection of prehistoric values. After review, BLM found that this location did not require special management as an ACEC to protect its relevant and important values. Protection of those values could be achieved by maintaining the designation as an archaeological site with restrictions on fluid and solid minerals, locatable minerals and mineral material sales on the 160 acres contained in the current special designation. This adjustment is not considered a significant change since the area will still be managed to protect the relevant and important values of the site, and the effects of managing these lands to protect these values were adequately projected in the Proposed RMP/Final EIS released in November, 2007. Pony Express Trail The Visual Resource Management classification in the Proposed RMP/Final EIS was mapped in error for the Pony Express Trail. As noted in decision CR-6, the area of direct effect around national historic trails is 1 mile from the centerline. Acreages of Visual Resource Management classifications (Class 1 through Class 4) have been adjusted in the Approved RMP based on these revisions. This adjustment is not considered a significant change since the adjustments to the Visual Resource Management associated with the Pony Express trail would be consistent with previously defined areas of direct effect. The following clarifications and minor corrections made to the information included in the Proposed RMP/Final EIS are reflected in the Approved RMP. y

BLM review determined six of the seven implementation decisions indicated in the Proposed RMP were not implementation-level decisions but planning-level decisions. The Approved RMP has been modified to reflect this determination; however, no associated changes were made to management action wording.

Management actions associated with species listed in the Biological Opinion (U.S. Fish and Wildlife Service 2008) were adjusted based on U.S. Fish and Wildlife Service Section 7 consultation. These management actions are now consistent with the Biological Opinion, included as Appendix D of the Approved RMP.

Ely District Approved Resource Management Plan y

Clarifications and editorial changes associated with adjusting titles and language from the Proposed RMP/Final EIS to conform with the desired Approved RMP format.

Updated information associated with lands conveyed to White Pine County in accordance with the White Pine County Conservation, Recreation and Development Act of 2006.

The mitigation measures adopted into the Approved RMP are Proposed Mitigation Measure 1, modified and included under Management Action FM-7; Proposed Mitigation Measure 2, included in Management Action REC-4; and Proposed Mitigation Measure 5, Option 1, included under Management Action LR-24. These approved mitigation measures are consistent with BLM authority.

Legislative Constraints The BLM administers public lands within a framework of numerous laws. The most comprehensive of these is the Federal Land Policy and Management Act of 1976. All BLM policies, procedures, and management actions must be consistent with the Federal Land Policy and Management Act and the other laws that govern use of the public lands. In the Federal Land Policy and Management Act, Congress established the principle of “multiple use” management, defined as “management of the public lands and their various resource values so that they are utilized in the combination that will best meet the present and future needs of the American people.” In addition to the legislative and procedural agency guidance for the preparation of the Approved RMP, other initiatives and legislation have contributed to the scope and management direction for this document. Lincoln County Conservation, Recreation, and Development Act of 2004 On November 30, 2004, the Lincoln County Conservation, Recreation, and Development Act of 2004 was signed into law. This legislation implements a comprehensive plan that balances the needs for infrastructure development, recreation opportunities, and conservation of natural resources and public lands in Lincoln County, Nevada. White Pine County Conservation, Recreation, and Development Act of 2006 On December 20, 2006, the White Pine County Conservation, Recreation, and Development Act of 2006 was signed into law. This legislation implements a comprehensive plan that balances the needs for infrastructure development, recreation opportunities, and conservation of natural resources and public lands in White Pine County, Nevada. The White Pine Act is modeled after the Southern Nevada Public Land Management Act, the Clark County Lands Act, and the Lincoln County Conservation, Recreation, and Development Act.

Ely District Approved Resource Management Plan Resource Advisory Councils The Ely District Office receives input from two of the three Resource Advisory Councils in Nevada. The Northeastern Great Basin Resource Advisory Council helps advise the Ely District Office on public lands issues in White Pine County, while the Mojave/Southern Great Basin Resource Advisory Council provides input for Lincoln and Nye counties. The Secretary of the Interior has approved standards and guidelines for rangeland health, off-highway vehicle use, and wild horses that were developed with the involvement of these two Resource Advisory Councils. The standards and guidelines are written to accomplish four fundamentals of rangeland health. The fundamentals are that: • • • •

Watersheds are functioning properly; Ecological processes are functioning properly to support healthy biotic populations and communities; Water quality complies with state water quality requirements; and Habitats of protected species are functioning properly.

The terms and conditions of grazing permits and leases must result in meeting or making progress toward meeting these Resource Advisory Council standards. Thus, these Resource Advisory Council standards and guidelines constitute existing policy that has been incorporated into the Approved RMP without modification. While the standards and guidelines developed by the Northeastern Great Basin and Mojave/Southern Great Basin Resource Advisory Councils are not identical in terms of the resources addressed or their specific wording, the goals presented in the Approved RMP were developed to be consistent with both sets of standards.

Planning Process Relationship to Federal, State, Local and Tribal plans, Other Stakeholder Relationships A multitude of laws, regulations, and policies, as well as land use planning documents, direct how the Ely District Office manages resources. Further, there are cooperative relationships that have been established with other federal, state, local, and tribal governments that manage lands and resources within the overall boundaries of the planning area. This entire body of relationships is too extensive to treat even in a summary manner in this document; however, certain relationships are key to understanding the management actions in the Approved RMP, and these are presented below. Fourteen federal, state, local, and tribal entities agreed to be formal Cooperating Agencies assisting in the preparation of the Ely Approved RMP. Federal Agencies Parts of the Humboldt-Toiyabe National Forest and the entire Great Basin National Park are within the planning area. The Ely District Office, U.S. Forest Service, and National Park Service strive to achieve similar resource management goals on adjoining lands.

Ely District Approved Resource Management Plan The Ely District Office also coordinates with the U.S. Fish and Wildlife Service on decisions that may affect the National Wildlife Refuge System. All or portions of Ruby Lake National Wildlife Refuge, Pahranagat National Wildlife Refuge, and Desert National Wildlife Range occur within the planning area. The U.S. Fish and Wildlife Service administers the Endangered Species Act of 1973 (as amended). The BLM consults with the U.S. Fish and Wildlife Service whenever a federal project or action that the BLM funds, authorizes, or carries out may affect a listed species, or may adversely modify its designated critical habitat. The BLM and the U.S. Fish and Wildlife Service have entered into an agreement to conduct programmatic consultations on RMPs. Programmatic consultations can provide the benefit of streamlining the consultation process while leading to a more landscape-based approach to consultations that can minimize the potential “piecemeal” effects that can occur when evaluating individual projects out of the context of the complete agency program. As part of this agreement, the BLM and U.S. Fish and Wildlife Service developed a list of federally listed, proposed, and candidate species and BLM sensitive species that are addressed in the Proposed RMP/Final EIS and in the Biological Assessment. Based on information contained in the Biological Assessment and discussions held during consultation, the U.S. Fish and Wildlife Service has issued a formal Biological Opinion that includes terms and conditions to minimize impacts to federally listed, proposed, and candidate species (Appendix D). The Biological Opinion also includes conservation recommendations for BLM sensitive species. Under the programmatic consultation process, once a specific project is developed that may adversely affect listed species, the Ely District Office will provide project-specific information that describes: 1) the proposed action and a map of the specific areas to be affected; 2) the species and designated critical habitat that may be affected; 3) the anticipated effects to listed species and their designated critical habitat that may result for the proposed actions; and 4) proposed measures to minimize potential effects of the action. Subsequently, the U.S. Fish and Wildlife Service reviews the information and effects analysis provided for each proposed project and determines the anticipated incidental take for each action, at the project level, which may be a subset of the incidental take anticipated in the programmatic biological opinion. The U.S. Fish and Wildlife Service completes a response and this documentation is then physically attached (appended) to the programmatic biological opinion. The programmatic biological opinion, together with the appended documentation, fulfills the consultation requirements for implementation of both program-level and project-level actions. Monitoring will be conducted, at least annually, by the Ely District Office and the U.S. Fish and Wildlife Service to ensure that the effects analysis in the programmatic biological opinion is accurate. Monitoring would include a comprehensive review of how the program-level biological opinion is working and whether its implementing procedures are in compliance. During this review, the environmental baseline would be reviewed and updated as needed to account for unanticipated effects or the lack of anticipated effects. During this process it may be determined that the program-level biological opinion is functioning as anticipated and, therefore, activities should continue, or that adjustments should be made.

Ely District Approved Resource Management Plan The Ely District Office and U.S. Department of Agriculture, Animal and Plant Health Inspection Service work jointly under a national memorandum of understanding on animal damage control, including predator and insect control. The Ely District Office and U.S. Army Corps of Engineers work together on issues related to wetlands and stream crossings that require Section 404 permits. The Ely District Office works with the Natural Resources Conservation Service on soil and water management issues, as well as other resource concerns. The Ely District Office consults with the U.S. Geological Survey on mineral and water resources and research. The Department of Defense utilizes much of the airspace above and has numerous surface activities in the planning area. The Ely District Office works with the Department of Defense through Nellis and Hill Air Force Bases and Fallon Naval Air Station on military overflights and surface uses. State Agencies The Ely District Office and Nevada Department of Wildlife work closely on site-specific activities including wildlife habitat and population management, introduction or reintroduction of wildlife species, species recovery activities, vegetation monitoring and evaluation, and the installation of range, fish, and wildlife improvements. Coordination also occurs on the management of State Wildlife Management Areas that are adjacent to BLM-administered lands, and on review of mine plans of operation and NEPA compliance documents. The Department of Conservation and Natural Resources, Nevada Natural Heritage Program works with the Ely District Office to maintain status and location information for BLM sensitive plant and animal species. The Ely District Office and Nevada Division of State Parks consult on management of public land adjacent to state parks. Public lands also can be transferred to the state for park purposes under authority of the Recreation and Public Purposes Act. The Ely District Office consults with the Nevada State Historic Preservation Officer prior to any activities that might adversely affect cultural resources. This consultation involves assessing the potential effects of proposed projects on cultural resources and developing appropriate mitigation measures when adverse impacts cannot be avoided. The Nevada Division of Minerals manages oil and gas and geothermal development at the state level. The Nevada Division of Environmental Protection participates with the Ely District Office in joint bonding, review, and authorization of mine plans of operation. The Ely District Office works closely with these two agencies to avoid duplication in regulations, inspections, and approval of reclamation plans and attempts to minimize costs for mine operators, public, and government.

Ely District Approved Resource Management Plan

The Nevada BLM and Nevada Division of Environmental Protection work together to meet implementation requirements of the Clean Air Act and Clean Water Act. A Memorandum of Understanding was executed between the agencies in September 2004 to coordinate water quality management efforts. The Ely District Office, Nevada Department of Agriculture, and county governments cooperate on inventory, study, and management of noxious weeds, and on insect control. The Ely District Office and Nevada Department of Transportation cooperate and coordinate land use activities and/or authorizations such as road rights-of-way, mineral material sources, communications sites, and other issues related to public highway safety. The Nevada Commission for the Preservation of Wild Horses works with the Ely District Office to maintain and ensure the proper management of wild horses. Local Government The Ely District Office coordinates with a number of county agencies and organizations on mutual goals for resource management and land disposals for public purposes. Coordination includes county commissions, planning departments, soil and water conservation districts, weed control agencies, coordinated resource management steering committees, road/highway departments, and the Tri-County Group. Tribal Governments The Ely District Office coordinates with affected or interested American Indian groups as required or recommended in the National Historic Preservation Act (1966), National Environmental Policy Act (1969), Archaeological Resources Protection Act (1979), Native American Graves Protection and Repatriation Act (1990), executive orders on sacred sites (Executive Order 13007) and government-to-government consultation (Executive Order 13175), and Nevada BLM Instruction Memorandum on the consultation process (2005-008). The Ely District Office also would coordinate with appropriate tribal representatives in the early stages of activity planning or projects that may affect tribal interests, treaty rights, or traditional use areas. Non-governmental Organizations To maximize restoration capability and success while achieving mutual goals, including implementation of the Great Basin Restoration Initiative, the Ely District Office has formed an external partnership with the Eastern Nevada Landscape Coalition. This non-profit community-based partnership has approximately 90 members from businesses, organizations, government agencies, and individuals that represent agricultural, conservation, cultural, environmental, scientific, private enterprise, and other interests. The Nevada BLM and other federal agencies work with the Eastern Nevada Landscape Coalition through a cooperative agreement to implement a variety of resource management activities on public land in eastern Nevada. In addition, the Ely District Office works cooperatively with the Great Basin Cooperative Ecological

Ely District Approved Resource Management Plan Systems Study Unit to facilitate the implementation of research to assist in providing both baseline and other studies regarding potential alternative actions to maintain or restore the ecological health and resiliency of Great Basin landscapes within eastern Nevada.

Related Plans BLM planning regulations (43 Code of Federal Regulations 1610.3.2[a]) require that BLM resource management plans be consistent with officially approved or adopted resource-related plans of other federal, state, local, and tribal governments to the extent those plans are consistent with federal laws and regulations applicable to public lands. Plans formulated by federal, state, local, and tribal governments that relate to management of lands and resources have been reviewed and considered as the Ely Approved RMP has been developed. State and Local Plans State of Nevada • Natural Heritage Program, Lincoln County Rare Species List, 2002 • Natural Heritage Program, Nye County Rare Species List • Natural Heritage Program, White Pine County Rare Species List, 2002 • Nevada State Parks, Beaver Dam State Park Development Plan, 1992 • Nevada State Parks, Cathedral Gorge State Park Development Plan, No Date • Nevada State Parks, Cave Lake State Park Development Plan, 1990 • Nevada State Parks, Echo Canyon State Park Development Plan, 1990 • Nevada State Parks, Kershaw-Ryan State Park Development Plan, No Date • Nevada State Parks, Spring Valley State Park Development Plan, 1992 • Nevada State Parks, Ward Charcoal Ovens State Historic Site Development Plan, 1991 • Nevada State Parks, 2002 SCORP Issues P-1 (Draft) • State of Nevada, Department of Conservation and Natural Resources, Division of Wildlife, Wayne E. Kirch Wildlife Management Area Conceptual Management Plan, July 2000 • State of Nevada, Department of Conservation and Natural Resources, Division of Wildlife, Steptoe Valley Wildlife Management Area Conceptual Management Plan, January 2002 • State of Nevada, Department of Conservation and Natural Resources, Division of Environmental Protection, Memorandum of Understanding for Water Quality Management Activities within the State of Nevada, September 2004 • State of Nevada, Department of Conservation and Natural Resources, Natural Heritage Program Scorecard, 2000 • State of Nevada, Department of Conservation and Natural Resources, Natural Resource Status Report, August 2002 • State of Nevada, Department of Conservation and Natural Resources, Division of Water Resources, Southern Nevada Surface Water Data Network, 2002 • State of Nevada, Department of Natural Resources, Division of Water Planning, State Water Plan, 1999

Ely District Approved Resource Management Plan • • • • • • • • • • • • • • •

State of Nevada, Department of Transportation, Transportation System Projects 2003-2012 – Lincoln County, 2002 State of Nevada, Department of Transportation, Transportation System Projects 2003-2012 – Nye County, 2002 State of Nevada, Department of Transportation, Transportation System Projects 2003-2012, White Pine County, 2002 State of Nevada, Department of Wildlife, Bighorn Sheep Management Plan, 2001 State of Nevada, Department of Wildlife, Conservation Assessment of Greater Sage-grouse and Sagebrush Habitats, 2004 State of Nevada, Department of Wildlife, Greater Sage-grouse Conservation Plan for Nevada and Eastern California, 2004 State of Nevada, Department of Wildlife, Lincoln County Elk Management Plan, July 1999 State of Nevada, Department of Wildlife, Nevada Sage-grouse Conservation Strategy, 2004 State of Nevada, Department of Wildlife, Pahranagat Valley Native Fishes Management Plan, 1999 State of Nevada, Department of Wildlife, White Pine County Elk Management Plan, March 1999 State of Nevada, Division of Environmental Protection, Nevada's 2002 303(d.) Impaired Waters List, October 2002 State of Nevada, Division of Environmental Protection, Nevada Smoke Management Program, July 1999 State of Nevada, Division of Environmental Protection, Solid Waste Management Program State of Nevada, Revised Nevada Bat Conservation Plan, 2006 State of Nevada, Conservation Agreement and Conservation Strategy for Bonneville Cutthroat Trout, 2006

Mohave County, Arizona • Mohave County, Arizona, General Plan, March 1995, Revised January 2002 Clark County, Nevada • Clark County Master Plan, Clark County Federal Lands Element, Adopted July 1, 1997 • Clark County Multiple Species Habitat Conservation Plan and Environmental Impact Statement, September 2000 Eureka County, Nevada • Eureka County Master Plan, June 2000 • Eureka County Natural Resource Management Ordinance, November 1996 Lincoln County, Nevada • Alamo Area Land Use Planning Project,1990 • Lincoln County/City of Caliente, Rachel Area Conceptual Development Plan, 1989 • Lincoln County Master Plan, Revision, 2006 • Lincoln County Economic Development Strategy 2005 • Lincoln County Strategic Marketing Plan, 2005 • Lincoln County Capital Improvements Plan and Program, 2001

Ely District Approved Resource Management Plan • • • • • •

Lincoln County Planned Unit Development Ordinance, 2002 Lincoln County Public Land and Natural Resource Management Plan, 1997 Lincoln County Hazardous Materials Emergency Response Plan, 2006 Lincoln County Solid Waste Management Plan, 2000 Needs Assessment for Lincoln County, 2005 Water Plan for Lincoln County, 2001

Nye County, Nevada • Nye County, Policy Plan for Public Lands, 1985 White Pine County, Nevada • Public Lands Identified for Transfer from the BLM to Local Government for Community Expansion, 1998, Appendix 2, White Pine County Land Use Plan • White Pine County Annual Comprehensive Economic Development Strategy, August 2005 • White Pine County, Emergency Operations Plan, 1994 • White Pine County, Land Use Plan, 1998 • White Pine County, Marketing Manual, August 1997 • White Pine County, McGill Highway Area Master Plan, August 2000 • White Pine County, Nevada Water Resources Plan, 1999 • White Pine County Open Space Plan, September 2005 • White Pine County, Public Land Use Plan, 1998 • White Pine County, Tourism Master Plan, August 2001 • White Pine County, Water Resources Plan, August 2006 Iron County, Utah • Iron County Master Plan, Utah – General Plan, Land Use Element, Digital Copy, 1981 Millard County, Utah • Millard County, Utah – General Plan, Federal and State Lands, No Date Tooele County, Utah • Tooele County, Utah – General Plan, November 1995 Washington County, Utah • New Harmony Valley General Plan, Washington County, Utah, July 1997 • Washington County, Utah – General Plan, October 2002 • Washington County, Utah, Wilderness Recommendation – Cougar Canyon Wilderness Area, October 1991

Ely District Approved Resource Management Plan City of Caliente, Nevada • City of Caliente Master Plan, 1992 • City of Caliente, Wellhead Protection Plan, October 2002 • Fiscal and Capital Improvement Program, Caliente Public Utilities, 1990 City of Ely, Nevada • City of Ely Master Plan – Business Plan Element, May 1999 • City of Ely, Wellhead Protection Plan, April 2002 • Ely Master Plan, 1999 Federal Plans Department of Energy • U.S. Department of Energy, Yucca Mountain Final EIS National Park Service • Great Basin National Park Final General Management Plan, Development Concept Plans, EIS, Natural Resources Management • Great Basin National Park RMP, Updated 2000 U.S. Fish and Wildlife Service • Big Spring Spinedace Recovery Implementation Plan, 1999 (Draft) • Big Spring Spinedace Recovery Plan, 1993 • Desert Tortoise Recovery Plan, 1994 • Pacific States Bald Eagle Recovery Plan, 1986 • Pahranagat National Wildlife Refuge Wildland Fire Management Plan, 2001 • Railroad Valley Springfish Recovery Plan, 1997 • Recovery Plan for the Aquatic and Riparian Species of Pahranagat Valley, 1998 • Ruby Lake Management Plan, September 1986 • Ruby Lake National Wildlife Refuge Fire Management Plan, 2001 • Ruby Lake National Wildlife Refuge Water Management Plan, May 1988 • Southwestern Willow Flycatcher Recovery Plan, 2002 • White River Spinedace Recovery Plan, 1994 U.S. Forest Service, Humboldt National Forest • Humboldt National Forest Land and RMP, 1986 • Amendment #1 – Humboldt National Forest Land and RMP, December 1989 • Amendment #2 – Humboldt National Forest Land and RMP, July 1990 • Amendment #3 – Humboldt National Forest Land and RMP • Amendment #4 – Humboldt National Forest Land and RMP

Ely District Approved Resource Management Plan • • •

Amendment #5 – Humboldt National Forest Land and RMP Amendment #6 – Humboldt National Forest Land and RMP, August 1996 Amendment #7 – Humboldt National Forest Land and RMP, November 1998 Tribal Plans

The Ely District Office communicated on a government-to-government basis with five tribal groups (Duckwater Shoshone Tribe, Ely Shoshone Tribe, Moapa Band of Paiutes, Yomba Shoshone Tribe, and Confederated Tribes of the Goshute Reservation), the first four of which were formal cooperating agencies on the RMP/EIS, regarding any plans or policies that should be reviewed for consistency. No planning documents were provided for this review. Consistency with Other Programs, Plans, and Policies During the development of the Ely RMP/EIS, the planning documents cited above were consulted and considered as alternatives were developed. Parallel RMP-level decisions currently in place on adjoining state and federal lands, including some in Utah and Arizona, and local agency policies were reviewed for consistency. Management actions identified in the Approved RMP are substantially consistent with these federal, state, and local planning documents. Where the Approved RMP does not contain a management action that corresponds with one contained in another agency’s planning document (or vice versa), the Approved RMP was judged to be consistent with the other document. While there is not uniformity in land management practices or goals across the region (i.e., they are not identical), management actions are compatible with adjoining jurisdictions, and there is no apparent conflict. Key areas of consistency are highlighted in the following sections, and minor inconsistencies also have been noted. Federal Plans and Policies Wildland fire management by the Ely District Office is directed by the Ely Fire Management Plan. It was found that fire management for adjoining BLM District Offices may be inconsistent in certain locations. For example, an area in the planning area may be identified as having “few constraints” (requirements) for fire suppression, while the adjoining area in another BLM planning area may be identified as “full suppression.” However, the Ely Fire Management Plan has been in effect for several years and has proven to be compatible with fire management on adjoining units overall; therefore, no conflicts are foreseeable. State Plans and Policies The Nevada Division of State Lands currently is preparing an update to the Statewide Public Lands Policy Plan. The Ely District Office has reviewed the preliminary public land management goals identified for the state plan and has found them to be consistent with the Approved RMP. The state goals would be revisited once they are finalized. The Nevada State Water Plan states: “Since most water supply sources originate on watersheds managed by federal agencies, their participation in watershed planning and management is essential” (Nevada

Ely District Approved Resource Management Plan Division of Water Planning 1999). The Ely District Office intends to involve the Nevada Division of Water Planning in the development of watershed restoration strategies, and thus, the ROD and Approved RMP is consistent with the state water plan. The Approved RMP also includes a decision to manage designated wellhead protection areas. The Nevada Smoke Management Program includes the following goal: “Acknowledge the role of fire in Nevada and allow the use of fire under controlled conditions to maintain healthy ecological systems while meeting the requirements of the Clean Air Act” (Nevada Division of Environmental Protection 1999). Wildland fire use requires an annual permit (including an initial or revised burn plan and map), as well as daily evaluation of the fire to: “determine if the conditions meet the prescription of the permitted burn, and that ambient air quality standards are not being violated.” Thus, prescribed and wildland fire use as tools in the restoration of watersheds would require coordination with the state in those areas where the Ely Fire Management Plan allows management options other than full suppression. County Plans and Policies Overall, the management actions contained in the ROD and Approved RMP are consistent with the planning documents of the three directly affected counties, seven neighboring counties, and two major communities (Ely and Caliente). These jurisdictions have developed a wide range of planning goals addressing topics from recreation to livestock grazing to mineral development. However, the topic that was of greatest interest to the three cooperating counties (White Pine, Lincoln, and Nye) and the City of Caliente during preparation of the RMP/EIS was the future availability of BLM-administered land for economic development and community expansion. These goal statements are presented below. •

White Pine County – “Support the sale or exchange of public land which increases private land holdings in the County available for agriculture, industrial and community development.” “Encourage BLM to amend its Resource Management Plan to reflect County goals and implementation strategies for public land and specific parcels identified for transfer to accommodate community expansion needs” (White Pine County 1998).

•

Lincoln County – “Lincoln County should help facilitate the exchange of federal (BLM) lands into private ownership for both residential and industrial uses.” “The predominance of public lands restricts community expansion and economic development. The county is identifying public lands desired for economic development and/or community expansion” (Lincoln County 2001).

•

Nye County – “Increase opportunities for local economic development by selectively increasing the amount of privately owned and locally managed land within the county except for lands with high recreational, wildlife, mineral, and other public values.” “Disposal of public lands in a timely fashion to allow the expansion of existing communities, the possible creation of new ones and the construction of needed residential and commercial facilities” (Nye County 1985).

•

City of Caliente – “Those lands which could provide needed area for growth adjacent to the city should be identified and pursued for acquisition from the Bureau of Land Management” (City of Caliente 1992).

Ely District Approved Resource Management Plan

Two areas where county planning documents are inconsistent with the Approved RMP also were identified. These are presented below. •

Lincoln County – “No additional wetlands shall be designated in Lincoln County. Any wetlands in existence shall not be used by public agencies managing them to harm or impede agriculture or other economic activities in Lincoln County whatsoever” (Lincoln County 1997). Wetland identification and management planning would be a component of the watershed analysis process. It is anticipated that wetlands will be managed for resource values other than agriculture or economic development.

•

Lincoln County – On June 20, 1994, the Lincoln County Commission passed a resolution stating that it is “adamantly opposed … to land exchanges or transfers that take land either off of county tax rolls or place land into a tax exempt status” (Lincoln County Commission Resolution #1994-10). The Approved RMP will allow the acquisition of land, which could result in a decrease in the number of acres of land on the county tax rolls.

Public Involvement The BLM will continue to actively seek the views of the public using techniques such as news releases, mass mailing, and website postings to ask for participation and to inform the public of news and ongoing project proposals, site-specific planning, and opportunities and timeframes for comment. The public is encouraged to actively participate in implementing these decisions by doing the following:

Requesting that their name be added to project or NEPA mailing lists by sending or calling in a request (via mail or phone) to the following address/phone number: Ely District Office HC 33 Box 33500 702 North Industrial Way Ely, Nevada 89301 775 289-1800

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Talking with a manager or staff member by calling or emailing; Monitoring BLM’s website (www.nv.blm.gov) for project proposals or information; and/or Attending public meetings and provide written comments on site-specific project proposals.

The BLM will continue to coordinate and consult, both formally and informally, with various Federal and state agencies, Indian Tribes, local agencies and officials, and communities and groups interested and involved in the management of public lands in the Ely District.

Ely District Approved Resource Management Plan

Management Plan Implementation Priorities Land use plan decisions are generally implemented or become effective upon approval of the RMP and signing of the Record of Decision. These decisions include the goals, objectives, land use allocation decisions and all special designations. Management actions in this Approved RMP that require additional site-specific project planning as funding becomes available, will require further environmental analysis, completion of Section 106 compliance for cultural resources, and Section 7 consultation. Decisions to implement site-specific projects will be subject to administrative review at the time such decisions are made. The BLM will continue to involve and collaborate with the public during implementation of this Approved RMP. Opportunities to become involved in plan implementation will include development of partnerships and community-based citizen groups. The BLM invites citizens and user groups interested in the management of the Ely District to become actively involved in the implementation of plan decisions. The BLM and citizens can collaboratively develop site-specific goals and objectives that mutually benefit public land resources, local communities, and the people who live, work, or recreate on public lands. Costs The costs associated with the implementation of this plan will be developed in association with future site-specific plans.

Plan Evaluation and Adaptive Management Plan Monitoring Monitoring is an essential component of natural resources management, because it provides information on the relative success of resource management plans and specific management strategies. This importance is recognized in the BLM’s Land Use Planning Handbook (H-1601-1), which provides direction for monitoring. “Land use plan monitoring is the process of (1) tracking the implementation of land use planning decisions (implementation monitoring) and (2) collecting data/information necessary to evaluate the effectiveness of land use planning decisions (effectiveness monitoring).” Implementation monitoring will be completed annually and will be documented in a tracking log or report, which will be available to the public. Effectiveness monitoring strategies will be developed as allowable uses and management actions are implemented. “The monitoring process should collect information in the most cost-effective manner and may involve sampling and remote sensing. Monitoring could be so costly as to be prohibitive if it is not carefully and reasonably designed.” Monitoring for each resource program is outlined in the “Management Decisions” section of the Approved Plan. If monitoring shows land use plan actions or best management practices are not effective, the BLM

Ely District Approved Resource Management Plan may modify or adjust management without amending or revising the plan as long as assumptions and impacts disclosed in the EIS analysis remain valid, and broad-scale goals and objectives are not changed. Where the BLM considers taking or approving actions that will alter or not conform to the overall direction of the Approved Plan, the BLM will prepare a plan amendment or revision and environmental analysis of appropriate scope. Land Use Plan Evaluations Plan evaluation is a crucial part of the implementation process. Evaluation will determine: 1. 2. 3. 4. 5.

If decisions are relevant to current issues; If decisions are effective in achieving desired outcomes; If decisions need to be revised; If any decisions need to be removed from further consideration; and If any new areas/issues need decisions.

Evaluations may identify resource needs and means for correcting deficiencies and addressing issues through plan maintenance, amendments, or new starts. Adaptive Management The Interior Departmental Manual 516 DM 4.16 defines adaptive management as “a system of management practices based on clearly identified outcomes, monitoring to determine if management actions are meeting outcomes and, if not, facilitating management changes that would best ensure that outcomes are met or re-evaluate the outcomes.” The Ely District Office recognizes that specific knowledge regarding natural resource systems is sometimes uncertain and in those situations, adaptive management is the preferred management method. Adaptive management is a formal, systematic, and rigorous approach to learning from the results of management actions, accommodating change, and improving management. It involves synthesizing existing knowledge, exploring alternative actions, and making explicit forecasts about their results. Management actions and monitoring programs are carefully designed to generate reliable feedback and clarify the reasons underlying results. Actions and objectives are then adjusted based on this feedback and improved understanding. In addition, decisions, actions, and results are carefully documented and communicated to others, so that knowledge gained through experience is passed on rather than lost when individuals move or leave the organization. Goals, objectives, special designations, and allocations could not be changed through adaptive management. Plan amendments would be required to change these decisions. Implementation or activity level decisions could be adapted. Future activity level plans would follow NEPA procedures and involve the public.

Ely District Approved Resource Management Plan

MANAGEMENT DECISIONS Acreages displayed in this document should be considered approximations even when displayed to the nearest acre. Most acreages were calculated from Geographic Information System coverage and rounded to the nearest 1,000 acres. As a result, the acreages presented may not match acres provided in prior published documents containing calculations from master title plats or other base data. The data used throughout this document are for land use planning purposes and not necessarily for on-the-ground implementation. The precision afforded by Geographic Information System calculation does not reflect project-level accuracy. Acreage figures that are provided in this document for land use plan analysis purposes would be refined as subsequent site-specific analysis is conducted. In accordance with Section 7 of the Endangered Species Act, the U.S. Fish and Wildlife Service issued a programmatic Biological Opinion. Where appropriate, decisions in the Proposed RMP/Final EIS have been modified to incorporate the new conditions from the Biological Opinion into the Approved RMP. The Biological Opinion is included as Appendix D.

Air Resources The Clean Air Act requires the BLM to minimize emissions of air quality pollutants from activities on public lands to protect human health and the environment. The Clean Air Act also requires each state to develop a state implementation plan for regions within the state that have nonattainment status, to ensure that the national ambient air quality standards are attained and maintained for the criteria pollutants. Federal agencies are required to ensure that their actions conform to state implementation plans. The Nevada Division of Environmental Protection is responsible for producing the state implementation plan. The Nevada Smoke Management Program coordinates and facilitates the statewide management of prescribed outdoor burning in the State of Nevada. This program is designed to meet the requirements of Nevada Revised Statutes 445B.100 through 445B.845, inclusive, which deal with air pollution, and the requirements of the U.S. Environmental Protection Agency Interim Air Quality Policy on Wildland and Prescribed Fires (April 1998). The planning area is considered in attainment. The Clean Air Act places additional restrictions on impacts to air quality and visibility within Class I and II areas. Class I areas consist of many national wildlife refuges and most national parks and designated wilderness that existed when legislation was enacted in 1977. Class II areas include most other western public lands. Little degradation of air quality is allowed in Class I areas; less stringent requirements apply to Class II areas. There are no Class I areas in the planning area; the nearest Class I areas are the Jarbidge Wilderness in northeast Nevada and Zion National Park in southwest Utah. Goals – Air Resources Meet all applicable local, state, and tribal constraints, and National Ambient Air Quality Standards under the Clean Air Act (as amended), and prevent significant deterioration of air quality (defined as violation of air quality regulations) within the Ely planning area from all direct and authorized actions.

Ely District Approved Resource Management Plan Objectives – Air Resources To ensure air quality in the Ely planning area meets all National Ambient Air Quality Standards. Management Actions – Air Resources AR-1: Develop burn plans that include incident and cumulative air quality considerations prior to implementing all prescribed burn treatments. AR-2: Coordinate with the Nevada Division of Environmental Protection prior to the planning of prescribed fires and other air quality related actions. AR-3: Authorize activities likely to adversely affect the Class II classification of public lands within the planning area, or the designation of the nearest Class I areas, such as Jarbidge Wilderness, on a case-bycase basis after compliance with appropriate laws. Monitoring– Air Resources On a project-specific basis, monitoring may be required to comply with state air quality permit requirements.

Water Resources Suitable water quality is important for proper ecological function as well as for supporting designated beneficial uses, including domestic supply (drinking water). The maintenance or improvement of water quality in streams and aquifers is, therefore, a major BLM management goal. The Federal Water Pollution Control Act of 1977, as amended, (commonly known as the “Clean Water Act”) requires the restoration and maintenance of the chemical, physical, and biological integrity of the Nation’s waters. The State of Nevada has regulatory primacy in administering the Act within its boundaries. A Memorandum of Understanding identifies responsibilities and activities to be performed by each agency in carrying out water quality programs on agency-administered lands in Nevada. In addition to the Clean Water Act, numerous laws, regulations, policies, and Executive Orders direct the BLM to manage water quality for the benefit of the Nation and its economy, and to sustain multiple uses of the land. The BLM is required to maintain water quality where it presently meets approved state water quality requirements, guidelines, and objectives, and to improve water quality on public lands where it does not meet those requirements, guidelines, and objectives. It is BLM policy to conform with applicable state laws and administrative claims procedures for water rights when managing and administering all BLM programs and projects, except as otherwise specifically mandated by Congress. The State Engineer Office, in the Division of Water Resources of the Nevada Department of Conservation and Natural Resources, administers water rights programs in Nevada based on beneficial use and the Doctrine of Prior Appropriation. The State of Nevada regulates its water rights programs using guidance in chapters 533 and 534 of the Nevada Revised Statutes. The BLM will acquire and perfect water rights necessary for public land management purposes according to these state laws and

Ely District Approved Resource Management Plan procedures. The BLM also will protect existing water rights of the U.S. by protesting or providing comment during the state permitting process on applications for new water rights or for changes to existing water rights that may interfere with BLM’s ability to utilize such water for public land management purposes. Goals – Water Resources The quality of water resource on public lands administered by the Ely District Office will be suitable for the appropriate beneficial uses and will meet approved federal, state, tribal, and local requirements, guidelines, and objectives. The quantity of water on public lands administered by the Ely District Office will be suitable to meet public land management purposes. Northeastern Great Basin Resource Advisory Council Standard. Riparian and wetland areas exhibit a properly functioning condition and achieve state water quality criteria. Objectives – Water Resources To protect the chemical, physical, and biological integrity of waters as needed to maintain healthy ecological systems and provide values that support multiple uses. Acquire and perfect sufficient water rights to meet public land management needs. Management Actions – Water Resources WR-1: Ensure authorized activities on public lands do not degrade water quality by complying with the Clean Water Act and Nevada Water Pollution Control Regulations (Nevada Revised Statute 445A). Cooperate with the Nevada Division of Environmental Protection to reduce non-point source water pollution as per the Memorandum of Understanding between the BLM and Nevada Division of Environmental Protection dated September 2004. WR-2: Integrate land health standards, best management practices, and appropriate mitigation measures into authorized activities to ensure water quality meets state requirements and BLM resource management objectives (BLM Manual 7240 Nevada Supplement). WR-3: Recognize community wellhead protection areas approved by the State of Nevada and only authorize activities within such areas that do not have potential for degrading groundwater quality. WR-4: Maintain or improve watershed conditions by controlling or restricting land uses and utilizing tools, where appropriate, to promote desired vegetation conditions. Monitoring – Water Resources Cooperation with state agencies, municipalities, industry, agriculture, universities, and other federal agencies in the planning area will occur to collect and interpret water resources data, and to participate in local, state, and regional water resources management. Aquifer recharge will be monitored at selected

Ely District Approved Resource Management Plan representative wells and springs throughout the planning area and on nearby lands as access agreements allow. Water levels and spring flows and durations will be monitored periodically either by the Ely District Office individually or cooperatively with other agencies. Existing historical data will be retrieved as available and archived with new data. Stream channel geometry and flow data also will be collected periodically at selected perennial, intermittent, and ephemeral locations of interest. Meteorological data (e.g., precipitation, temperature, wind speed and direction, solar radiation, and relative humidity) also will be collected at selected locations. Site selection, data collection procedures, and the frequency of data collection will depend on the data type, prior knowledge of suitable and significant monitoring locations, budget and personnel considerations, and anticipated resource activities within specific locales. Water resources trends within the planning area will be reviewed periodically. Water quality monitoring will be conducted at selected sites (wells, springs, and streams) for various parameters to compare applicable water quality requirements and objectives to current conditions. Data collection and interpretations will be performed either by the Ely District Office individually or cooperatively with other agencies. Water quality data collection will be conducted in coordination with the water quantity monitoring described above. Water quality constituents to be analyzed will be determined with due consideration of planning needs and the Memorandum of Understanding between the BLM and the State of Nevada. Sampling and analysis will follow standard field and laboratory protocols approved by the U.S. Environmental Protection Agency. Drinking water sources will be protected by developing and implementing wellhead protection plans and assessing the presence and effects of fertilizers, pesticides, herbicides, and other contaminants released to water resources by agriculture, municipalities, industry, and the BLM itself. Water quality trends will be reviewed periodically within the planning area for management purposes.

Soil Resources Soils are the growth medium for vegetation and the source of sediment in streams. Management goals for vegetation, watershed, wildlife, and livestock cannot be achieved without productive and stable soils. Goals – Soil Resources Maintain or improve long-term soil quality. Northeastern Great Basin Resource Advisory Council Standard. Upland soils exhibit infiltration and permeability rates that are appropriate to soil type, climate, and landform. Mojave/Southern Great Basin Resource Advisory Council Standard. Watershed soils and stream banks should have adequate stability to resist accelerated erosion, maintain soil productivity, and sustain the hydrologic cycle. Objectives – Soil Resources To ensure that soils throughout the planning area exhibit infiltration and permeability appropriate to the soil type, with erosion and compaction having minimal effect on soil quality.

Ely District Approved Resource Management Plan

Management Actions – Soil Resources SR-1: Restore and maintain desired range of conditions to increase infiltration, conserve soil moisture, promote groundwater recharge, and ground cover composition (including litter and biotic crusts) to increase or maintain surface soil stability and nutrient cycling. SR-2: For soil disturbing actions which will require reclamation, salvage and stockpile all available growth medium prior to surface disturbances. Seed stock piles if they are to be left for more than one growing season. Re-contour all disturbance areas to blend as nearly as possible with the natural topography prior to re-vegetation. Rip all compacted portions of the disturbance to an appropriate depth based on site characteristics. Establish an adequate seed bed to provide good seed-to-soil contact. SR-3: Protect soils from high compaction during surface disturbing activities through soil moisture and/or seasonal use restrictions commensurate with soil surface texture or other properties on a case-by-case basis. Monitoring – Soil Resources Soil health and condition will be monitored by conducting reviews of ground-disturbing projects for implementation and effectiveness of best management practices, and by periodically assessing selected undisturbed sites for various parameters including erosion and sedimentation, topsoil characteristics, and groundcover. Monitoring the effects of other resource management actions such as livestock grazing and watershed projects will consider soil condition and health. Baseline soil condition data will be provided through the ecological site inventories and watershed analyses. Site selection, data collection procedures, and the frequency of data collection will depend on the data type, prior knowledge of suitable and significant monitoring locations, budget and personnel considerations, and anticipated resource activities within specific locales. Soil quality trends within the planning area will be reviewed periodically for management purposes.

Vegetation Resources The Federal Land Policy and Management Act, the Public Rangeland Improvement Act, and the Healthy Forests Restoration Act, provide objectives and priorities for management of public land vegetation resources. Guidance contained in Title 43, Subpart 4180 of the Code of Federal Regulations directs public land management toward the maintenance or restoration of the physical function and biological health of vegetation systems. Land Health Standards for lands administered by the BLM in Nevada were approved by the Secretary of the Interior in 1997. Ecological site descriptions will be used as the initial basis to guide integrated management/treatments to meet the desired goals and objectives for vegetation.

Ely District Approved Resource Management Plan Specific management actions and decisions will be implemented by vegetation community to achieve the desired range of conditions and objectives, and to meet the overall goal of vegetation in the Approved RMP. A variation of 5 percent above or below the values listed in the desired range of conditions for all vegetation communities is considered acceptable. Goals – Vegetation Resources Manage vegetation resources to achieve or maintain resistant and resilient ecological conditions while providing for sustainable multiple uses and options for the future across the landscape. Northeastern Great Basin Resource Advisory Council Standard. Habitats – Exhibit a healthy, productive and diverse population of native and/or desirable plant species, appropriate to the site characteristics, to provide suitable feed, water, cover, and living space for animal species and maintain ecological processes; habitat conditions meet the life cycle requirements of threatened and endangered species. Mojave/Southern Great Basin Resource Advisory Council Standard. Habitats and watersheds should sustain a level of biodiversity appropriate for the area and conducive to appropriate uses. Habitats of special status species should be able to sustain viable populations of those species. Objectives – Vegetation Resources To manage for resistant and resilient ecological conditions including healthy, productive, and diverse populations of native or desirable nonnative plant species appropriate to the site characteristics. Management Actions – Vegetation Resources General Vegetation Management VEG-1: Emphasize treatment areas that have the best potential to maintain desired conditions or respond and return to the desired range of conditions and mosaic upon the landscape, using all available current or future tools and techniques. VEG-2: Develop specific management objectives through the watershed analysis process, incorporating direction from activity plans (see Management Actions WL-8 and WL-15). VEG-3: Adhere to the Healthy Forests Restoration Act of 2003 (Section 102 [e]) to protect old-growth characteristics or their equivalent. VEG-4: Design management strategies to achieve plant composition within the desired range of conditions for vegetation communities, and emphasize plant and animal community health at the mid scale (watershed level).

Ely District Approved Resource Management Plan VEG-5: Focus restoration of undesirable conditions initially on those sites that have not crossed vegetation transitional thresholds. VEG-6: Emphasize the conservation and maintenance of healthy, resilient, and functional vegetation communities before restoration of other sites. VEG-7: Determine seed mixes on a site-specific basis dependent on the probability of successful establishment. Use native and adapted species that compete with annual invasive species or meet other objectives. Parameter – Pinyon-Juniper Woodlands VEG-8: Implement actions to attain the desired vegetation states shown in Table 2. Table 2 Desired Range of Conditions of Pinyon-Juniper (Distribution of Woodland Phases and States)

State and Phase Canopy Description2

LANDFIRE classes Approved RMP3

Herbaceous State 0 to 10% canopy coverincludes herbaceous, herbaceous-shrub, and sapling phase A and B

Tree State Herbaceous State (Mature Woodland (Immature Woodland Phase) Phase) 11 to 20% canopy 21 to 35% canopy cover cover

Tree State (Overmature Woodland Phase)1 >36 to 50% canopy cover

D and E

Altered State Site dominated by invasive species or weeds Uncharacteristic

10% (359,300 acres)

20% (718,700 acres)

65% (2,335,700 acres)

5% (179,700 acres)

0% (0 acres)

Overmature woodland refers to woodlands exhibiting greater than 35 percent canopy cover. This classification is not the same as “old growth” although the two classifications may coincide in some situations. 2 Canopy descriptions derived from Natural Resource Conservation Service Ecological Site Descriptions. 3 The Approved RMP approximates and incorporates the LANDFIRE Biophysical Settings models for Great Basin pinyon-juniper woodland. Altered state is an uncharacteristic condition not recognized by LANDFIRE Biophysical Settings models but is part of current conditions.

VEG-9: Integrate treatment priorities to include: 1. Public safety and protection from catastrophic wildland fire above other considerations. 2. Limit the transition of immature and mature phases to the overmature phase and from becoming infested with invasive species. 3. Direct overmature woodlands toward earlier phases (i.e., herbaceous state and phase) on a watershed basis, and only if existing immature and mature woodlands are considered resilient and do not need treatments to maintain resiliency.

Ely District Approved Resource Management Plan 4. Manage for pinyon-juniper old-growth characteristics to include broad asymmetric tops, deeply furrowed bark, twisted trunks or branches, dead branches and spike tops, large lower limbs, hollow trunks (mostly in juniper), large trunk diameters relative to tree height, and branches covered with a bright yellow-green lichen on true woodland sites as defined by ecological site description. Parameter – Aspen VEG-10: Implement actions to attain the desired vegetation states shown in Table 3. Table 3 Desired Range of Conditions of Aspen (Distribution of Phases and States)

State and Phase 1 Canopy Cover

Herbaceous State (Herbaceous, and Herbaceous-Shrub and Sapling Phase) 0 to 15% tree canopy cover

LANDFIRE A classes 2 Approved RMP 14% (980 acres) 1 2

Herbaceous State (Immature Woodland Phase) 16 to 29% tree canopy cover. B

Tree State (Mature Woodland Tree State Phase) (Overmature Woodland Phase) 30 to 45% tree 45% or greater tree canopy cover canopy cover (includes conifer dominated) C and D D and E

40% (2,800 acres)

45% (3,150 acres)

<1% (<70 acres)

Canopy cover determined from Natural Resource Conservation Service Ecological Site Descriptions. The Approved RMP approximates and incorporates the LANDFIRE Biophysical Setting Models for Rocky Mountain aspen forest and Inter-mountain Basin aspen-mixed conifer forest and woodland. Description of LANDFIRE CLASSES can be found at www.landfire.gov.

VEG-11: Integrate treatment priorities that include: 1. Areas where select species of conifers dominate the tree overstory and where canopy cover exceeds the percentages listed in the desired range of conditions in Table 3 (Overmature Phase). 2. Areas where understory species are declining and aspen are not regenerating. 3. Managing aspen communities (using disturbance) to remain in or move toward those phases that are more resilient and resistant to disturbance. 4. Allowing regeneration to occur where potential allows, and to protect that regeneration through use restrictions or other protection methods. 5. Selecting and applying protection measures on a site-specific basis during implementation of the RMP. 6. Managing aspen stands to maintain or improve stand characteristics and promote regeneration.

Ely District Approved Resource Management Plan Parameter – High Elevation Conifer Species VEG-12: Implement actions to attain the desired vegetation states shown in Tables 4 and 5. Table 4 Desired Range of Conditions of High Elevation Conifer (Distribution of States and Phases)

State and Phase Canopy Cover2 LANDFIRE classes Approved RMP3

Herbaceous State, (Herbaceous, and Herbaceous/Sapling Phase) 0 to 15% canopy Cover A 20% (9,400 acres)

Herbaceous State (Immature Phase) 16 to 31% canopy cover B 20% (9,400 acres)

Tree State Tree State (Mature Phase) (Overmature Phase)1 31 to 40% canopy cover 41 to 60% canopy cover C 50% (23,500 acres)

C 10% (4,700 acres)

Overmature high elevation conifer refers to stands with canopy cover exceeding 40 percent. This classification is not the same as “old growth,” although the two classifications may coincide in some situations. 2 Canopy cover derived from Natural Resource Conservation Service Ecological Site Descriptions. 3 The Approved RMP approximates and incorporates the LANDFIRE Biophysical Setting Models for Inter-Mountain white fir limber-bristlecone pine woodland (47,000 acres).

Table 5 Desired Range of Conditions of Ponderosa Pine (Distribution of States and Phases)

State and Phase Canopy Cover LANDFIRE Classes Approved RMP1

Herbaceous State, (Herbaceous, and Herbaceous/Sapling Phase) 0 to 5% canopy cover

Tree State (Saplings and survivors) 5-10% canopy cover

Tree State (Mature Phase) 10-20% canopy cover

A 10% (900 acres)

C 20% (1,800 acres)

D 60% (5,400 acres)

Tree State (Overmature Phase) Greater than 20% canopy cover B and E 10% (900 acres)

LANDFIRE Biophysical Setting Model for southern Rocky Mountain ponderosa pine and appropriate ecological site descriptions.

VEG-13: Integrate treatment priorities that include: 1. Areas where tree overstory canopy is approaching threshold levels (i.e., self-thinning and understory is diminishing). 2. Areas where overstory tree canopy cover and density have crossed a threshold, and are restricting understory growth.

Ely District Approved Resource Management Plan 3. Protect conifer trees, as appropriate, that meet the old growth criteria. General characteristics are: white fir, 24 inches diameter breast height and 75 feet in height; limber pine, 20 inches diameter breast height and 75 feet in height; ponderosa pine, 30 inches diameter breast height and 75 feet in height. Parameter – Salt Desert Shrub VEG-14: Implement actions to attain the desired vegetation states shown in Table 6. Table 6 Desired Range of Conditions of Salt Desert Shrub (Distribution of Phases and States)

Habitat Type LANDFIRE classes Approved RMP1

Herbaceous State A 5% (61,050 acres)

Altered State Annual Invasive/Exotic State Uncharacteristic 0% (0 acres)

Shrub State B and C 77% (940,170 acres)

Altered State Perennial Nonnative Seeded Uncharacteristic 18% (219,800 acres)

The Approved RMP approximates and incorporates the LANDFIRE Biophysical Setting Models for Inter-Mountain Basins mixed salt desert shrub and Inter-Mountain Basin greasewood flat. Altered state (invasive species/weeds) is an uncharacteristic condition not recognized by LANDFIRE Biophysical Setting Models but is part of current conditions.

VEG-15: Intensively manage areas currently in the herbaceous state to facilitate conversion to the shrub state. Parameter – Sagebrush (basin big sagebrush, Wyoming big sagebrush, mountain big sagebrush, and black sagebrush) VEG-16: Implement actions to attain the desired vegetation states shown in Table 7. Table 7 Desired Range of Conditions of Sagebrush (Distribution of Phases and States)

State/Phase Name LANDFIRE classes Approved RMP2 1 2

Total Herbaceous State (Early, Mid, and Late Phases)1 A, B, and C

Total Shrub State D

85% (4,776,500 acres)

5% (281,000 acres)

Altered State Annual/Perennial Invasive Uncharacteristic

Altered State Nonnative Perennial Seeded Uncharacteristic

5% (281,000 acres)

0% (0 acres)

5% (281,000 acres)

Total Tree State

Sagebrush in the mid-late phase of the herbaceous state is desired for wildlife habitat. The Approved RMP approximates and incorporates the LANDFIRE Biophysical Setting Models for Great Basin xeric mixed sagebrush and Inter-Mountain Basin big sagebrush. Altered states (annual/perennial invasive and nonnative perennial seeded) are an uncharacteristic condition not recognized by LANDFIRE Biophysical Setting Models but are part of current conditions.

Ely District Approved Resource Management Plan VEG-17: Integrate treatments to: 1. Establish and maintain the desired herbaceous state or early shrub state where sagebrush is present along with a robust understory of perennial species. 2. Prioritize treatments toward restoration of sagebrush communities on areas with deeper soils and higher precipitation. VEG-18: Manage native range to meet the requirements of wildlife species. Management will focus on maintaining or establishing diversity, mosaics, and connectivity of sagebrush between geographic areas at the mid and fine scales. Parameter – Mountain Mahogany VEG-19: Implement actions to attain the desired vegetation states shown in Table 8. Table 8 Desired Range of Conditions of Mountain Mahogany (Distribution of Phases and States)

State and Phase Canopy Cover2

LANDFIRE classes Approved RMP3

Herbaceous State (Herbaceous Phase) 0-15% mahogany canopy cover

Shrub State (Shrub/ Herbaceous Phase) 15-25% mahogany canopy cover (desired mix of herbaceous and shrub species in understory)

Shrub State (Shrub Phase) 30-45% mahogany canopy cover (approaching threshold with no understory)

A and C 20% (9,200 acres)

B 20% (9,200 acres)

D 15% (6,900 acres)

Shrub/Tree-like State (No Understory Phase)1 45-60% mahogany cover (shrub/tree-like and tree dominant)

E 45% (20,700 acres)

Refers to savanna sites. Canopy cover determined from Natural Resource Conservation Service Ecological Site Descriptions. 3 The Approved RMP approximates and incorporates the LANDFIRE Biophysical Setting Models for Inter-Mountain Basin mountain mahogany woodland and shrubland. 2

VEG-20: Integrate treatments in areas where: 1. Wildlife habitat requirements will receive the highest priority consideration when determining site-specific objectives in mountain mahogany sites. 2. Desirable understory is still present and where canopy cover is near threshold level or exceeds percentages listed for the desired range of conditions above (i.e., shrub/tree-like dominant state).

Ely District Approved Resource Management Plan Parameter – Mojave Desert Vegetation VEG-21: Implement actions to attain the desired vegetation states shown in Tables 9 and 10. Table 9 Desired Range of Conditions of Creosotebush and Bursage (Distribution of Phases and States)

Habitat Type LANDFIRE Classes Approved RMP1 1

Altered State (Annual Invasive and Exotics) Uncharacteristic

15% (54,825 acres)

70% (255,850 acres)

0% (0 acres)

Herbaceous State

Shrub State

Perennial Nonnative Seeded State Uncharacteristic 15% (54,825 acres)

In creosotebush/bursage communities, the herbaceous state and shrub state will correspond respectively to Class A and Class B as given in the LANDFIRE Biophysical Setting Model for Sonora-Mojave creosotebush-white bursage description. Altered states are an uncharacteristic condition not recognized by LANDFIRE Biophysical Settings models but are part of current conditions.

Table 10 Desired Range of Conditions of Blackbrush (Distribution of Phases and States)

Habitat Type LANDFIRE Classes Approved RMP1 1

Altered State (Annual Invasive and Exotics) Uncharacteristic

15% (57,375 acres)

75% (286,875 acres)

0% (0 acres)

Herbaceous State

Shrub State

Perennial Nonnative Seeded State Uncharacteristic 10% (38,250 acres)

The herbaceous state and shrub state will correspond respectively to Class A and Class B as given in the LANDFIRE Biophysical Setting Model for Mojave mid-elevation desert scrub. Altered states are an uncharacteristic condition not recognized by LANDFIRE Biophysical Settings models but are part of current conditions.

VEG-22: Intensively manage areas currently in the herbaceous state to facilitate conversion to the shrub state. Parameter – Riparian/Wetlands Desired Range of Conditions. The Ely District Office is directed to follow the appropriate rangeland health standards. The Northeastern Great Basin Resource Advisory Council states “Riparian and wetland areas exhibit a properly functioning condition and achieve state water quality criteria.” The Mojave/Southern Great Basin Resource Advisory Council specifies “Riparian and watershed vegetation should have structural and species diversity characteristic of the stage of stream channel succession in order to provide forage and cover, capture sediment, and capture, retain, and safely release water (watershed function).” In addition to achieving riparian proper functioning condition, composition, structure, and cover of riparian vegetation will occur within capabilities of the site. Ground cover and species composition will be appropriate to the site.

Ely District Approved Resource Management Plan Riparian areas with free-flowing water (i.e., undeveloped springs) that are non-functional or functioning at risk will show improving trends toward proper functioning condition. VEG-23: Promote vegetation structure and diversity that is appropriate and effective in controlling erosion, stabilizing stream banks, healing channel incisions, shading water, filtering sediment, and dissipating energy, in order to provide for stable water flow and bank stability. VEG-24: Focus management actions on uses and activities that allow for the protection, maintenance, and restoration of riparian habitat. Parameter – Nonnative Seedings (Existing) VEG-25: Implement actions to attain the desired vegetation states shown in Table 11. Table 11 Desired Range of Conditions of Seedings (Distribution of Phases and States)

Habitat Type Approved RMP

Herbaceous State 65% (175,200 acres)

Shrub State 25% (67,400 acres)

Tree State 10% (26,900 acres)

Altered State (Annual Invasive) 0% (0 acres)

VEG-26: Include the following integrated treatments: 1. Use of ecological site descriptions as references for identifying appropriate management of non-seeded species on the sites. 2. Management of seedings to allow sagebrush, perennial grasses, and forbs to become established on the site. Monitoring – Vegetation Resources Vegetation communities in both treated and untreated areas will be monitored to determine progress toward attaining desired range of conditions. Monitoring to determine success in meeting vegetation management objectives will shift to measuring cover, composition, and structure of the community (i.e., the parameters essential for identification of phases within the state and transition model concept). Periodic measurements of vigor and productivity will continue and will utilize standard methodologies (National Research Council 1994; Swanson 2006).

Fish and Wildlife Section 102(8) of the Federal Land Policy and Management Act of 1976, as amended, states it is policy to manage public lands in a manner that will protect the quality of multiple resources and provide habitat for

Ely District Approved Resource Management Plan fish, wildlife, domestic livestock, and wild horses. Standards and guidelines direct BLM to foster productive and diverse populations and communities of plants and animals. It also is BLM policy to cooperate with state agencies to accommodate species management population goals to the extent that they are consistent with the principles of multiple use management. The BLM acknowledges the role of the State of Nevada and the Nevada Department of Wildlife, under the direction of the State Board of Wildlife Commissioners, in managing, protecting, augmenting, and restoring fish and wildlife populations. The Ely District Office will work in close coordination with the State of Nevada and the Nevada Department of Wildlife and draw on and implement the goals, objectives, and actions outlined in Nevada’s Wildlife Action Plan and various species management plans, as appropriate. The ecological condition of the various vegetation communities greatly influences the quality of wildlife habitat. The Ely District Office fish and wildlife habitat management, as presented in this RMP, will emphasize restoration to achieve the desired range of conditions for the various vegetation communities. Goals – Fish and Wildlife Provide habitat for wildlife (i.e., forage, water, cover, and space) and fisheries that is of sufficient quality and quantity to support productive and diverse wildlife and fish populations, in a manner consistent with the principles of multi-use management, and to sustain the ecological, economic, and social values necessary for all species. Northeastern Great Basin Resource Advisory Council Standard. Habitats exhibit a healthy, productive and diverse population of native and/or desirable plant species, appropriate to the site characteristics, to provide suitable feed, water, cover and living space for animal species and maintain ecological processes. Habitat conditions meet the life cycle requirements of threatened and endangered species. Mojave/Southern Great Basin Resource Advisory Council Standard. Habitats and watersheds should sustain a level of biodiversity appropriate for the area and conducive to appropriate uses. Habitats of special status species should be able to sustain viable populations of those species. Objectives – Fish and Wildlife To manage suitable habitat for aquatic species, priority wildlife species, and migratory birds in a manner that will benefit wildlife species directly or indirectly and minimize conflicts among species and wildlife or habitat losses from permitted activities. Priority species for terrestrial wildlife habitat management are elk, mule deer, pronghorn antelope, Rocky Mountain bighorn sheep, desert bighorn sheep, and migratory birds; because these species cover the entire Ely RMP planning area. Priority habitats include calving/fawning/kidding/lambing grounds, crucial summer range, crucial winter range, and occupied desert bighorn sheep habitat. To use wildlife water developments, both natural and artificial, to improve the condition of wildlife habitat, and to use artificial wildlife water developments to mitigate impacts to wildlife species from loss of natural water sources or loss of habitat.

Ely District Approved Resource Management Plan

Management Actions – Fish and Wildlife General Wildlife Habitat Management (Aquatic and Terrestrial) WL-1: Emphasize management of priority habitats for priority species. (See the discussion on Vegetation Resources for the desired range of conditions for the various vegetation communities.) See Map 3, Map 4, Map 5, and Map 6. WL-2: Release wildlife on public lands within the planning area in conformance with Manual 1745, and the Memorandum of Understanding between the BLM and the Nevada Department of Wildlife. WL-3: Consider objectives listed in the appropriate U.S. Fish and Wildlife Service National Wildlife Refuge Comprehensive Conservation Plan when managing wildlife habitat adjacent to a national wildlife refuge. WL-4: Mitigate all discretionary permitted activities that result in the loss of aquatic and priority wildlife habitats by improving 2 acres of comparable habitat for every 1 acre of lost habitat as determined on a project-by-project basis (see Map 3, Map 4, Map 5, and Map 6). Parameter – Elk, Mule Deer, Pronghorn Antelope, and Rocky Mountain Bighorn Sheep Habitats WL-5: In coordination with Nevada Department of Wildlife, update priority habitats for elk, pronghorn antelope, mule deer, and Rocky Mountain bighorn sheep, as well as other seasonal habitats for these priority species (see Map 3, Map 4, Map 5, and Map 6). WL-6: Where appropriate, restrict permitted activities in big game calving/fawning/kidding/lambing grounds and crucial summer range from April 15 through June 30 (see Map 3, Map 4, Map 5, and Map 6). WL-7: Where appropriate, restrict permitted activities in crucial winter range from November 1 through March 31 (see Map 3, Map 4, Map 5, and Map 6). WL-8: Focus restoration projects initially in priority habitats (i.e., calving/fawning/kidding/lambing grounds, crucial summer range, and crucial winter range), and then in other seasonal habitats within a watershed (see Map 3, Map 4, Map 5, and Map 6). WL-9: Manage elk habitat by implementing the actions and strategies identified in the Central Nevada, Lincoln County, and White Pine County Elk Management Plans that the Ely District Office has the authority to implement, and that are consistent with watershed restoration strategies. WL-10: Manage habitat for Rocky Mountain bighorn sheep in the Snake Range. Manage domestic sheep and goats in accordance with current BLM policy when changes to BLM grazing permits are being considered in the Snake Range.

Ely District Approved Resource Management Plan WL-11: Consider managing habitat for Rocky Mountain bighorn sheep in unoccupied ranges if and when domestic sheep grazing no longer occurs in the area (see Map 6). Parameter – Desert Bighorn Sheep Habitat WL-12: Manage desert bighorn sheep habitat in all occupied ranges (see Map 6). Manage domestic sheep and goats in accordance with current BLM policy when changes to BLM grazing permits are being considered. WL-13: Where appropriate, restrict permitted activities within occupied desert bighorn sheep habitat from March 1 through May 31 and from July 1 through August 31 (see Map 6). WL-14: Consider managing habitat for desert bighorn sheep in unoccupied ranges if and when domestic sheep grazing no longer occurs in the area (see Map 6). Parameter – Migratory Bird Habitat WL-15: Identify the spatial and temporal habitat needs for those migratory bird species of concern for the sagebrush biome to help achieve the desired range of conditions of the various vegetation communities (see the discussion on Vegetation Resources). WL-16: When planning projects, consider migratory birds, as appropriate, to minimize take and limit impacts. WL-17: Work with the U.S. Fish and Wildlife Service, Nevada Department of Wildlife and other partners (e.g., Great Basin Bird Observatory, Partners in Flight) to conduct breeding bird surveys to document the population status and trends of those migratory bird species of concern. Parameter – Wildlife Water Developments WL-18: Restore natural water sources (i.e., springs and seeps) to increase water availability through restoration of riparian habitats and proper livestock and wild horse management. WL-19: Identify areas of suitable wildlife habitat that are water limited in coordination with the Nevada Department of Wildlife and interested public (i.e., elk management technical review teams, sportsmen groups, etc.). WL-20: Use the criteria listed below to identify artificial wildlife water developments: • • •

To mitigate for loss of natural water sources; To mitigate for habitat loss or habitat fragmentation; To reduce inter-specific competition between wildlife, livestock, and wild horses;

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To reduce inter-specific competition between wildlife species; and In suitable wildlife habitat that is water limited. Monitoring – Fish and Wildlife

Periodic inventories of fisheries are conducted by the Nevada Department of Wildlife on perennial streams and reservoirs. The Ely District Office will coordinate with the Nevada Department of Wildlife in review of information relating to management of fisheries habitat on public lands. Baseline wildlife use patterns and estimated population levels will be calculated using information collected annually by the Nevada Department of Wildlife. These will be compared with post-treatment use patterns and population numbers to determine relative effectiveness of watershed restoration. Forage production will be monitored on an allotment basis during livestock allotment evaluations. Annual livestock and wild horse utilization records gathered by Ely District Office staff and wildlife observations reported by the Nevada Department of Wildlife and Ely District Office will be used to determine possible conflicts. Conflicts between livestock, wild horses, and wildlife will be resolved during the assessments and subsequent management actions including appropriate management level adjustments in herd management areas, cooperative habitat management actions with Nevada Department of Wildlife, and grazing permit renewals. Impacts to wildlife populations will take into account changes in herd management objectives as set by the Nevada Department of Wildlife.

Special Status Species Section 102(8) of the Federal Land Policy and Management Act of 1976, as amended, requires that public land be managed to protect the quality of multiple resources and to provide habitat for fish, wildlife, domestic livestock, and wild horses. Special status species include federally listed, proposed, or candidate species; state listed species; and BLM sensitive species. The BLM must follow the requirements of the Endangered Species Act of 1973, as amended, and BLM policy to conserve federally listed threatened and endangered species and the ecological systems on which they depend. BLM policy also states, “…ensure that actions requiring authorization or approval by the Bureau of Land Management (BLM or Bureau) are consistent with the conservation needs of special status species and do not contribute to the need to list any special status species, either under provisions of the ESA or other provisions of this policy.” The Ely District Office will manage special status species following the direction and guidance identified in BLM Manual 6840; recovery plans; biological opinions; conservation agreements, plans, and strategies; habitat conservation plans; and the recommendations from interagency recovery implementation teams. Goals – Special Status Species Manage public lands to conserve, maintain, and restore special status species populations and their habitats; support the recovery of federally listed threatened and endangered species; and preclude the need to list additional species.

Ely District Approved Resource Management Plan Northeastern Great Basin Resource Advisory Council Standard. •

Habitats exhibit a healthy, productive, and diverse population of native and/or desirable plant species, appropriate to the site characteristics, to provide suitable feed, water, cover, and living space for animal species and maintain ecological processes. Habitat conditions meet the life cycle requirements of threatened and endangered species.

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Riparian and wetland areas exhibit a properly functioning condition and achieve state water quality criteria.

Mojave/Southern Great Basin Resource Advisory Council Standard. •

Habitats and watersheds should sustain a level of biodiversity appropriate for the area and conducive to appropriate uses. Habitats of special status species should be able to sustain viable populations of those species.

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Watersheds should possess the necessary ecological components to achieve state water quality criteria, maintain ecological processes, and sustain appropriate uses. Riparian and wetlands vegetation should have structural and species diversity characteristic of the stage of stream channel succession to provide forage and cover, capture sediment, and capture, retain, and safely release water (watershed function). Objectives – Special Status Species

To manage suitable habitat for special status species in a manner that will benefit these species directly or indirectly and minimize loss of individuals or habitat from permitted activities. Management in Great Basin riparian habitat will benefit the following special status species: • • • • •

Pahrump poolfish (federally listed endangered species) White River spinedace (federally listed endangered species) Railroad Valley springfish (federally listed threatened species) Big Spring spinedace (federally listed threatened species) Ute ladies’-tresses (federally listed threatened species)

Management in Mojave Desert and Great Basin riparian habitat will benefit the following special status species: • • •

Southwestern willow flycatcher (federally listed endangered species) Western yellow-billed cuckoo (federal candidate species) Meadow Valley Wash desert sucker (BLM sensitive species)

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Meadow Valley Wash speckled dace (BLM sensitive species) Arizona southwestern toad (BLM sensitive species)

Management in Mojave Desert riparian habitat will benefit the following special status species: • • •

White River springfish (federally listed endangered species) Hiko White River springfish (federally listed endangered species) Pahranagat roundtail chub (federally listed endangered species)

Management in Mojave Desert scrub habitat will benefit the following special status species: • •

Desert tortoise (federally listed threatened species) Banded Gila monster (BLM sensitive species)

To manage Mojave Desert and Great Basin desert scrub and salt desert shrub habitats for the benefit of the following special status species: • •

Western burrowing owl (BLM sensitive species) Sunnyside green gentian (BLM sensitive species)

To manage Great Basin sagebrush habitats for the benefit of the following special status species: • •

Greater sage-grouse (BLM sensitive species) Pygmy rabbit (BLM sensitive species) Management Actions – Special Status Species

Parameter – Special Status Species Habitat SS-1: Prioritize conservation, maintenance, and restoration actions for special status species based on the following order of importance: 1) federally listed endangered species, 2) federally listed threatened species, 3) federal proposed species, 4) federal candidate species, and 5) BLM sensitive species. SS-2: Develop and implement an interagency inventory and monitoring program for special status plant and animal species. SS-3: Participate on interagency recovery implementation teams to identify and address implementation of management actions for the recovery of listed species in the Ely planning area. SS-4: Where appropriate, restrict permitted activities from May 1 through July 15 within 0.5 mile of raptor nest sites unless the nest site has been determined to be inactive for at least the previous 5 years.

Ely District Approved Resource Management Plan SS-5: Manage Bonneville cutthroat trout habitat by implementing those actions and strategies identified in the Conservation Agreement and Conservation Strategy for Bonneville Cutthroat Trout in the State of Nevada that the Ely District Office has the authority to implement. SS-6: Use the Revised Nevada Bat Conservation Plan (Bradley et al. 2006) for guidance on implementation of bat management actions, such as: • • • • • • • •

Bat-friendly techniques for abandoned mine closures; Proper bat surveys of abandoned mines identified for hard closure techniques; Improving livestock grazing of riparian and upland habitat; Limiting off-highway vehicle travel in or near riparian habitat; Stopping conversion of native sagebrush vegetation communities to annual grasslands, and restoration to native rangelands; Installing escape ramps in artificial water sources; Monitoring wind energy development projects; and Rehabilitating areas damaged by fires.

SS-7: Implement management actions identified in the Ely Cave Management Plan (BLM 1986) (i.e., closures, bat gates, etc.) to protect bats, on a case-by-case basis. SS-8: In vegetation communities, especially riparian areas and pinyon-juniper woodlands, consider the habitat needs of obligate bat species in restoration treatments. SS-9: Perform springsnail surveys prior to the development of any spring source. SS-10: Mitigate all discretionary permitted activities that result in the loss of special status species habitats on a ratio of 2 acres of comparable habitat for every 1 acre of lost habitat as determined on a project-by-project basis. This will not apply to desert tortoise habitat as remuneration fees and other measures to minimize effects to the tortoise are required for disturbance in desert tortoise habitat. Parameter – Great Basin Riparian Habitat SS-11: Manage the refugium at Shoshone Ponds for Pahrump poolfish in accordance with the Recovery Plan for the Pahrump Killifish (now called the Pahrump poolfish) (also see Appendix D). SS-12: Expand the fenced area at Shoshone Ponds (also see Appendix D). SS-13: Manage the uplands around Shoshone Ponds to increase vegetation cover, reduce runoff, and prevent excessive siltation into the ponds (also see Appendix D). SS-14: Develop additional ponds at Shoshone Ponds to increase the habitat for the Pahrump poolfish. This development would be consistent with the Biological Opinion (Appendix D).

Ely District Approved Resource Management Plan SS-15: Manage public lands adjacent to designated critical habitat for the White River spinedace, located on private land, in accordance with the White River Spinedace Recovery Plan (also see Appendix D). SS-16: Manage public lands adjacent to designated critical habitat for the Railroad Valley springfish, located on the Duckwater Indian Reservation, in accordance with the Railroad Valley Springfish Recovery Plan (also see Appendix D). SS-17: Manage Big Spring spinedace habitat by implementing those actions and strategies identified in the Big Spring Spinedace Recovery Plan that the Ely District Office has the authority to implement, and in accordance with the Condor Canyon Habitat Management Plan (also see Appendix D). SS-18: In cooperation with the U.S. Fish and Wildlife Service, survey appropriate habitats on public lands in Lincoln County for the Ute ladies’-tresses. Develop and implement conservation and recovery actions for any populations that may be discovered (also see Appendix D). Parameter – Mojave Desert and Great Basin Riparian Habitats SS-19: Manage southwestern willow flycatcher habitat by implementing those actions and strategies identified in the Southwestern Willow Flycatcher Recovery Plan and appropriate actions from future habitat conservation plans that the Ely District Office has the authority to implement (also see Appendix D). SS-20: Limit livestock grazing in the Lower Meadow Valley Wash ACEC through terms and conditions and/or season-of-use restrictions on grazing permits in accordance with a site-specific ACEC plan (also see Appendix D). Parameter – Mojave Desert Riparian Habitat SS-21: Manage White River springfish habitat at Ash Spring by implementing those actions and strategies identified in the Recovery Plan for the Aquatic and Riparian Species of Pahranagat Valley and the Ash Springs Coordinated Management Plan that the Ely District Office has the authority to implement (also see Appendix D). SS-22: Manage public lands adjacent to designated critical habitat for the Hiko White River springfish, located on private land, in accordance with the Recovery Plan for the Aquatic and Riparian Species of Pahranagat Valley (also see Appendix D). SS-23: Manage public lands adjacent to the aquatic habitat for the Pahranagat roundtail chub, located on private and state land, in accordance with the Recovery Plan for the Aquatic and Riparian Species of Pahranagat Valley (also see Appendix D).

Ely District Approved Resource Management Plan Parameter – Mojave Desert Scrub Habitat SS-24: Manage desert tortoise habitat by implementing those actions and strategies identified in the Desert Tortoise Recovery Plan, and appropriate actions from future habitat conservation plans that the Ely District Office has the authority to implement (also see Appendix D). SS-25: Coordinate with the U.S. Fish and Wildlife Service and the Nevada Department of Wildlife to inventory desert tortoise habitat and desert tortoise populations. Management would be consistent with the Biological Opinion (also see Appendix D). SS-26: Implement an interagency monitoring program for desert tortoise habitat and desert tortoise populations, approved by the U.S. Fish and Wildlife Service and the Desert Tortoise Management Oversight Group (also see Appendix D). SS-27: Cooperate with the U.S. Fish and Wildlife Service, Nevada Department of Wildlife, and the U.S. Department of Agriculture-Wildlife Services in a program to control desert tortoise predators (also see Appendix D). SS-28: Coordinate with the U.S. Fish and Wildlife Service and Nevada Department of Wildlife to develop approved translocation research projects for desert tortoises (also see Appendix D). SS-29: Coordinate with the U.S. Fish and Wildlife Service, Nevada Department of Wildlife, Federal Highway Administration, the Nevada Department of Transportation, and Lincoln County to install tortoise-proof fencing and crossing culverts along U.S. Highway 93 in the Kane Springs ACEC and along other roads, as needed, in all three desert tortoise ACECs (also see Appendix D). SS-30: Manage leased public lands in the Coyote Springs area in accordance with Public Law 100-275 dated March 31, 1988, and the Land Lease Agreement signed July 14, 1988. SS-31: Limit maintenance of existing roads to the existing disturbance and perform maintenance in accordance with specifications provided by the Ely District Office in consultation with the U.S. Fish and Wildlife Service (also see Appendix D). SS-32: Where appropriate, restrict permitted activities from March 1 through October 31 within desert tortoise habitat (see Map 7 and Appendix D). SS-33: Implement the following management actions for desert tortoise habitat (see Map 7). Implement the additional conditions for desert tortoise and conditions for the Southwest willow flycatcher, White River springfish, Pahrump poolfish, and Big Springs spinedace habitat contained in the 2008 Biological Opinion (Appendix D) (also refer to discussions on Wild Horses, Lands and Realty, Recreation, Geology and Minerals, and Fire Management).

Ely District Approved Resource Management Plan •

Within desert tortoise ACECs: If fence construction occurs during the tortoise active season, a qualified tortoise biologist will be onsite during construction of the tortoise-proof fence to ensure that no tortoises are harmed. If the fence is constructed during the tortoise inactive season, a qualified tortoise biologist will thoroughly examine the proposed fence line and burrows for the presence of tortoises no more than three days before construction. Any desert tortoises or eggs found in the fence line will be relocated offsite by the biologist in accordance with approved protocol (Desert Tortoise Council 1994, 1999). Tortoise burrows that occur immediately outside of the fence alignment that can be avoided by fence construction activities will be clearly marked to prevent crushing.

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Within desert tortoise ACECs: Projects will require fencing, unless determined by the BLM authorized officer and U.S. Fish and Wildlife Service that the project should not be fenced. In accordance with current specifications, fencing will consist of 1-inch horizontal by 2-inch vertical mesh. The mesh will extend at least 18 inches aboveground and, where feasible, 6 to 12 inches belowground. In situations where it is not feasible to bury the fence, the lower 6 to 12 inches of the fence will be bent at a 90 degree angle towards potentially approaching tortoises and covered with cobble or other suitable material to ensure that tortoise or other animals cannot dig underneath.

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Within desert tortoise ACECs: Tortoise fencing will be inspected on a quarterly basis, and any repairs completed within 72 hours from March 1 through October 31, and within 7 days from November 1 through February 28/29. The operator will inspect the fencing at least on a quarterly basis and after major precipitation events to ensure zero ground clearance. Monitoring and maintenance will include regular removal of trash and sediment accumulation and restoration of zero ground clearance between the ground and the bottom of the fence, including re-covering the bent portion of the fence if not buried. The operator will perform maintenance when needed including removing trash, sediment accumulation, and other debris. Fencing will be removed upon termination and reclamation of the project, or when it is determined by the BLM authorized officer and U.S. Fish and Wildlife Service that the fence is no longer necessary.

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Within desert tortoise ACECs: During surface-disturbing activities, tortoise burrows will be avoided whenever possible. If a tortoise is found onsite during project activities, which may result in take of the tortoise (i.e., in harm’s way), such activities will cease until the tortoise moves, or is moved, out of harm’s way. The tortoise will be moved by a qualified tortoise biologist. All workers also will be instructed to check underneath all vehicles before moving such vehicles and within stockpiled materials. Tortoises often take cover under vehicles and construct burrows in stockpiled material.

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Within desert tortoise ACECs: The BLM authorized officer will approve the selected consulting firm/biologist to be used by the applicant to implement the terms and conditions of the permit issued by the BLM. Any biologist and/or firm not previously approved will submit a curriculum vitae and be approved by the BLM authorized officer. Other personnel may assist with implementing terms and conditions that involve tortoise handling, monitoring, or surveys, only under direct field supervision of the approved, qualified biologist.

Ely District Approved Resource Management Plan •

Within desert tortoise ACECs: Tortoises and nests that are found will be handled and relocated by a qualified tortoise biologist in accordance with U.S. Fish and Wildlife Service-approved protocol. Burrows containing tortoises or nests will be excavated by hand, with hand tools, to allow removal of the tortoise or eggs. Desert tortoises moved during the tortoise inactive season or those in hibernation, regardless of date, will be placed into an adequate burrow; if one is not available, one will be constructed in accordance with Desert Tortoise Council protocol. During mild temperature periods in the spring and early fall, tortoises removed from the site will not necessarily be placed in a burrow. Tortoises and burrows will only be relocated to federally managed lands. If the responsible federal agency is not the BLM, verbal permission, followed by written concurrence, will be obtained before relocating the tortoise or eggs to lands not managed by the BLM.

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Desert tortoises moved in the winter (i.e., November 1 through February 28/29), or those in hibernation regardless of date, will be placed into an adequate burrow; if one is not available, one will be constructed utilizing the protocol for burrows in Section B.5.f. of the U.S. Fish and Wildlife Service-approved guidelines (U.S. Fish and Wildlife Service 1994).

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All projects in desert tortoise habitat will be reviewed by the BLM’s wildlife staff to ensure that appropriate measures have been incorporated into the BLM authorization (e.g., material site, land sale, or off-highway vehicle event) to minimize the potential take of desert tortoise and loss of habitat.

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A BLM representative(s) will be designated and will be responsible for overseeing compliance with terms and conditions of all permitted activities and reporting requirements. The designated representative will provide coordination among the permittee, project proponent, the BLM, and the U.S. Fish and Wildlife Service.

Parameter – Mojave and Great Basin Desert Scrub and Salt Desert Shrub Habitats SS-34: Identify the spatial and temporal habitat needs for the western burrowing owl to help achieve the desired range of conditions of the various vegetation communities (see the discussion on Vegetation Resources). SS-35: Work with the U.S. Fish and Wildlife Service, Nevada Department of Wildlife and other partners (e.g., Great Basin Bird Observatory, Partners in Flight) to conduct breeding bird surveys to document the population status and trends of western burrowing owls. SS-36: Inventory and monitor populations of the Sunnyside green gentian in conjunction with the development of the White River Valley ACEC management plan. Parameter – Great Basin Sagebrush Habitat SS-37: Manage greater sage-grouse habitat by implementing those actions and strategies identified in the BLM National Sage-Grouse Habitat Conservation Strategy, Greater Sage-Grouse Conservation Plan for

Ely District Approved Resource Management Plan Nevada and Eastern California, and local greater sage-grouse conservation plans that the Ely District Office has the authority to implement (also see Appendix D). SS-38: Maintain intact and quality sagebrush habitat. Prioritize habitat maintenance actions from the BLM National Sage Grouse Conservation Strategy to: 1) maintain large areas of high quality sagebrush currently occupied by greater sage-grouse; 2) maintain habitats which connect seasonal sagebrush habitats in occupied source habitats; and 3) maintain habitats that connect seasonal sagebrush habitats in occupied isolated habitats (also see Appendix D). SS-39: Implement proactive and large scale management actions to restore lost, degraded, or fragmented sagebrush habitats and increase greater sage-grouse populations. Prioritize habitat restoration actions from the BLM National Sage Grouse Conservation Strategy to: 1) reconnect large patches of high quality seasonal habitats, which greater sage-grouse currently occupy; 2) enlarge sagebrush habitat in areas greater sage-grouse currently occupy; 3) reconnect stronghold/source habitats currently occupied by greater sage-grouse with isolated habitats currently occupied by greater sage-grouse; 4) reconnect currently occupied and isolated habitats; 5) restore potential sagebrush habitats that currently are not occupied by greater sage-grouse. Develop allowable use restrictions in greater sage-grouse habitats undergoing restoration, on a case-by-case basis, as dictated by monitoring (also see Appendix D). SS-40: Outside of designated corridors, above-ground facilities will not be constructed within 0.25 mile of greater sage-grouse leks. Underground facilities will not be installed within 0.25 mile of greater sage-grouse leks unless the vegetation can be established to pre-disturbance conditions within a reasonable period of time. No new roads will be constructed within 0.25 mile of greater sage-grouse leks. Exceptions may be granted by the authorized officer, in consultation with Nevada Department of Wildlife, if the project can be designed so that it will not affect breeding activity nor degrade the integrity of the habitat associated with the lek, or if the lek has been inactive for at least 5 consecutive years or the habitat has changed such that there is no likelihood that the lek will become active. SS-41: Where appropriate, restrict permitted activities from March 1 through May 15 within 2 miles of an active greater sage-grouse lek (see Map 8). SS-42: Where appropriate, restrict permitted activities from November 1 through March 31 within greater sage-grouse winter range (see Map 8). SS-43: Survey all proposed ground disturbing activities in suitable pygmy rabbit habitat utilizing the appropriate protocol. Surveys will be completed by a qualified biologist approved by the Ely District Office (also see Appendix D). Monitoring – Special Status Species In conjunction with other private, state, or federal agencies, monitoring of known populations of special status species that are considered to be important indicators or obligates to a particular habitat community type (such as greater sage-grouse for sagebrush communities) will continue. Monitoring could consist of

Ely District Approved Resource Management Plan intensive research projects or passive population inventories designed to help identify the extent of the populations and habitats being used. Inventories for special status species will be completed within the planning area and information will be used to measure the effectiveness in meeting management objectives on a landscape level and watershed basis.

Wild Horses The Wild Free-Roaming Horse and Burro Act of 1971 (Public Law 92-195) requires the BLM to protect and manage wild horses in areas where they were found at the time of the Act, in a manner designed to achieve and maintain a thriving natural ecological balance in keeping with the multiple use management concept of public lands. These requirements are further detailed in the Standards and Guidelines for Wild Horses and Burros developed by the Northeastern Great Basin Resource Advisory Council and the Mojave/Southern Great Basin Resource Advisory Council. Goals – Wild Horses Maintain and manage healthy, self-sustaining wild horse herds inside herd management areas within appropriate management levels to ensure a thriving natural ecological balance while preserving a multiple-use relationship with other uses and resources. Northeastern Great Basin Resource Advisory Council Standard. Healthy wild horse and burro populations exhibit characteristics of healthy, productive, and diverse population. Age structure and sex ratios are appropriate to maintain the long-term viability of the population as a distinct group. Herd management areas are able to provide suitable feed, water, cover and living space for wild horses and burros and maintain historic patterns of habitat use. Mojave-Southern Great Basin Resource Advisory Council Standard. Wild horses and burros within herd management areas should be managed for herd viability and sustainability. Herd management areas should be managed to maintain a healthy ecological balance among wild horse and/or burro populations, wildlife, livestock, and vegetation. Objectives – Wild Horses To maintain wild horse herds at appropriate management levels within herd management areas where sufficient habitat resources exist to sustain healthy populations at those levels. Herds will consist of healthy animals that exhibit diverse age structure, good conformation, and any characteristics unique to the specific herd.

Ely District Approved Resource Management Plan Management Actions – Wild Horses General Wild Horse Management WH-1: Do not authorize domestic horse grazing permits within wild horse herd management areas (see Map 9). WH-2: Coordinate wild horse management with other federal and state jurisdictions and resource management agencies. WH-3: Do not construct permanent fences that prohibit the free-roaming behavior of wild horses or prevent wild horses from moving within herd management areas. Remove existing fences within herd management areas that restrict the free-roaming behavior of wild horses. Parameter – Herd Management Area Establishment WH-4: Manage wild horses within six herd management areas designated from herd areas (see Map 9) based on wild horse use and habitat suitability listed in Table 12 covering approximately 3.7 million acres. Table 12 Herd Management Areas Herd Management Areas Pancake Triple B Antelope Silver King Eagle Diamond Hills South1

Size Acres 855,000 1,225,000 331,000 606,000 670,000 19,000 3,705,000

Initial Appropriate Management Level 240-493 250-518 150-324 60-128 100-210 10-22 810-1,695

Managed as a complex with Elko and Battle Mountain BLM.

WH-5: Remove wild horses and drop herd management area status for those areas that do not provide sufficient habitat resources to sustain healthy populations as listed in Table 13. Parameter – Population Management WH-6: Initially manage the appropriate management level as a range between 810 and 1,695 animals on all herd management areas within the planning area. Manage populations within ranges of appropriate management levels in which the upper level is based on available habitat and the lower level is based on the projected recruitment rate between gather cycles as developed from herd monitoring data (see Table 12).

Ely District Approved Resource Management Plan Table 13 Herd Management Areas Dropped Public Land Area (acres)1 62,900 30,300 84,600 3,200 33,100 168,000 183,600 65,500 153,700 53,000 94,500 89,400 53,300 37,400 358,800 116,300 1,587,600

Herd Management Areas Antelope (west of Highway 93) Applewhite Blue Nose Peak Cherry Creek (eastern portion) Clover Creek Clover Mountains Delamar Mountains Highland Peak (southern 2/3) Jakes Wash Little Mountain Meadow Valley Mountains Miller Flat Moriah Rattlesnake (southern 1/2) Seaman White River Totals 1

Rounded to hundreds.

WH-7: Base adjustments to appropriate management levels on monitoring data and perform adjustments typically, but not exclusively, in conjunction with the watershed analysis process. WH-8: Manage sex ratios, phenotypic traits, reproductive cycles, and other population dynamics on a herd management area basis. WH-9: Implement the following management actions for desert tortoise habitat (also refer to the discussion on Special Status Species). The Ely District Office does not plan to manage for any wild horses in desert tortoise habitat and this management only will be used if emergency gathers are needed in the future should wild horses reenter the area. •

For gathers: Trap sites should be located at previous trap site locations or in previously disturbed areas, where possible. All trap and holding sites, and access routes will be cleared by a qualified tortoise biologist before the trap and holding facilities are set up. The parcel will be surveyed for desert tortoise using survey techniques that provide 100 percent coverage.

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For gathers: Holding facilities will not be located inside ACECs. If possible, they should be located outside of desert tortoise habitat. If they cannot be located outside of desert tortoise habitat, they should be placed in previously disturbed areas.

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For gathers: All vehicle use in desert tortoise habitat will be restricted to existing roads and trails and within surveyed areas. Vehicles will not exceed 25 mph.

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For gathers: Trash and garbage will be contained in a covered, raven-proof trash receptacle and disposed of off-site in a designated facility. No trash or garbage will be buried at the sites.

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For gathers: Use of hay or grains as enticements into the traps will not occur within desert tortoise habitat to avoid the introduction of nonnative plant species. The feeding of hay or grains to animals will not be allowed within ACECs. The feeding of hay or grains to animals at holding facilities on public land within desert tortoise habitat will be avoided when possible. Monitoring – Wild Horses

Aerial and ground census information periodically will be gathered to determine the number of adults and foals, colors, special characteristics, and overall health of each wild horse herd. Aerial counts will occur at a minimum of once every 3 years. Other herd data, including the ratio of mares to studs, age classes, colors, special characteristics, and overall health will be collected during gathers and at the time wild horses are processed for adoption. Wild horse actual use of forage will be estimated by multiplying inventoried or estimated numbers of horses by the length of grazing period on their summer and winter ranges. Utilization and trend study methods are the same as presented in the monitoring section for Livestock Grazing Management. Data collected in other studies, such as watershed analyses, monitoring of vegetation treatments, special status plants and animals, microbiotic crusts, wildlife, water resources, weeds, riparian, and wetland sources may be used to determine the effects of wild horses on these resources.

Cultural Resources Management of cultural resources is directed primarily by two laws: the National Historic Preservation Act of 1966, as amended, and the Archaeological Resources Protection Act of 1979. The National Historic Preservation Act requires management and enhancement of significant historic properties and the Archaeological Resources Protection Act requires protection of archaeological resources (sites and objects of 100 years or more in age). The Federal Land Policy and Management Act directs the BLM to manage public lands on the basis of multiple use and to “protect the quality of historical resources and archaeological values.” This act provides for the periodic inventory of public lands and resources. Goals – Cultural Resources Identify, preserve, and protect significant cultural resources and ensure that they are available for appropriate uses by present and future generations (Federal Land Policy and Management Act, Section 103(c), 201(a), and (c); National Historic Preservation Act, Section 110(a); Archaeological Resources Protection Act, Section 14 [a]). Seek to reduce imminent threats and resolve potential conflicts from natural or human-caused deterioration, or potential conflict with other resource uses (Federal Land Policy and Management Act, Section 103(c),

Ely District Approved Resource Management Plan National Historic Preservation Act, Section 106, 110[a][2]) by ensuring that all authorizations for land use and resource use will comply with the National Historic Preservation Act, Section 106. Northeastern Great Basin Resource Advisory Council Standard. Land use plan will recognize cultural resources within the context of multiple use. Objectives – Cultural Resources To protect and maintain cultural resources on BLM-administered land in stable condition. Appropriate management actions will be determined after evaluation and allocation of cultural resource use categories through cultural resource project plans. Management Actions – Cultural Resources General Cultural Resources Management CR-1: Prioritize inventories to identify sites eligible to the National Register. CR-2: Allocate all cultural resources in the planning area, whether already recorded or projected to occur on the basis of existing data synthesis (including cultural landscapes), or not projected to occur but later identified through inventory, to the following six uses according to their nature and relative preservation value: Scientific Use, Conservation for Future Use, Traditional Use, Public Use, Experimental Use, and Discharged from Management. See the Cultural category in the glossary for definitions. These use allocations pertain to cultural resources, not to areas of land. Each resource will be assigned to a primary use category, but that assignment does not preclude management from other use categories. Allocate and manage all sites determined eligible to the National Register of Historic Places to Scientific, Public, and Conservation for Future Use. Focus on three of the six cultural resource use allocations: Scientific Use, Public Use, and Conservation for Future Use. These allocations currently address the majority of issues within the planning area and, therefore, are of high importance. Do not emphasize the remaining three cultural resource use allocations – Traditional Use, Experimental Use, and Discharged from Management – for the following reasons: •

Traditional Use. Several recent and extensive efforts have identified no Traditional Cultural Properties within the planning area. Appropriate measures for identification and evaluation of Traditional Cultural Properties, as well as assignment to use categories, will be taken during tribal consultation and public involvement in planning and project implementation. Although currently not identified as such, several historic cemeteries may qualify as Traditional Cultural Properties.

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Experimental Use. Because there are few activities in the planning area where the destructive nature of impacts on archaeological sites are uncertain or unknown, this allocation will not be emphasized.

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Discharged from Management. This cultural resource use allocation may occur. However, this will not be emphasized because conducting a program driven by this goal would defeat the long-term preservation of these resources.

CR-3: Allocate and manage all sites determined not eligible to the National Register of Historic Places and not containing archaeological resources as Discharged from Management Use. CR-4: Pending completion of watershed, site type, or site-specific Cultural Resource Project Plans, direct inventory priorities to testing high-medium-low predictions found in archaeological predictive models, including the Gnomon forecast model (Gnomon 2004). CR-5: Continue to educate the public on Cultural Heritage resources, their importance as a non-renewable resource, and the laws that provide for their preservation. Work with local groups and volunteers to enhance interpretive capabilities and provide educational opportunities. CR-6: The following thirteen classes of site types found in the planning area have specific management needs based on each site type. Priorities for inventory and appropriate management actions have been identified for each site type. Parameter – Cultural Resource Use Allocation: Historic Roads, Trails, Railways, Highways, and Associated Sidings and Stations •

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Management: − Perform an intensive archaeological inventory of the corridor of each site to establish baseline information on a priority basis as identified in Cultural Resources Project Plans. − Write an historic context report for each resource on a priority basis as identified in Cultural Resource Project Plans. − Encourage the use of site stewards for monitoring. Scientific Use: − Inventory road/trail/railway/highway related sites (e.g., stage stops, stage stations) and record the condition on a priority basis as identified in Cultural Resources Project Plans. − Allow excavation subject to management plan with appropriate research design (which conserves samples for future use). Conservation for Future Use: − Post informational signs at all major intersections along existing Public Use sites. − Allow excavation subject to management plan with appropriate research design (which conserves samples for future use). − Inventory road/trail/railway/highway related sites (e.g., stage stops, stage stations) and record the condition.

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Public Use: − Post informational signs at all major intersections along Public Use sites as appropriate. − Prepare activity level cultural resource project plans for public use sites to identify interpretive needs including signs, interpretive kiosks, driving guides, etc. − Complete National Register nominations for all Public Use sites on a priority basis as identified in Cultural Resource Project Plans. Priorities for Inventory: − Potential threats identified in Cultural Resource Project Plans − Existing designated National Scenic and Historic Trails − Routes under national study

Manage the cultural historic landscape (setting) around the Pony Express Trail and California Trail (National Historic Trail) according to the National Historic Preservation Act and current policy regarding Historic Landscape Management along National Historic Trails and current policy regarding the Determination of the Direct Effects Analysis Area for National Historic Trails. The area of direct effect around national historic trails is established as 1 mile from centerline, although in some cases, the area of effect may be larger or smaller than 1 mile from centerline. Manage designated national historic trails according to the National Scenic and Historic Trail Act (16 United States Code sections 1241-1251) and the BLM’s National Scenic and Historic Trails Strategy and Work Plan (BLM 2006). Allocate and manage all National Register eligible historic roads, trails, railways, highways, and associated sidings and stations for Scientific, Conservation, and Public Use. No fee sites will be established. Allocate national historic trails to Public Use and prepare Cultural Resource Project Plans to better balance Public, Scientific, and Conservation Use. Establish fee sites at Public Use sites as appropriate. Parameter – Cultural Resource Use Allocation: Rock Art Sites •

Management: − Consider for allocation to Public Use, any rock art site with evidence of public use. − Allocate any rock art site with no evidence of public use to Conservation Use and/or Scientific Use and consider those sites for public use as appropriate. − Preserve in place all rock art sites eligible to the National Register of Historic Places under Criterion c. Do not discharge these sites from management. − Use the best and most accurate technologies available to photograph and gather locational information at all rock art panels (for example, digital photographs and global positioning system readings with position error no greater than 20 feet). − Take detailed measured drawings and sub-meter global positioning system locations of all panels. − Allow Scientific Use subject to management plans that minimize physical damage to rock art. − Conduct condition monitoring of rock art sites on at-risk/threatened rock art sites annually. − Limit livestock and human contact with rock art panels through physical barriers (fences or natural barriers such as plantings or boulder placement).

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− Allow emergency stabilization if natural or cultural threats are causing loss of integrity to rock art. − Evaluate fire potential and remove fuels where there is threat of loss. − Encourage the use of site stewards for monitoring. Scientific Use: − Permit surface collection of artifacts on non-rock art portions of sites under the Archaeological Resources Protection Act of 1979 if there is threat of loss or destruction. Public Use: − Post informational signs on rock site etiquette and the Archaeological Resources Protection Act of 1979 at all Public Use sites. − Develop site-specific recreation management plans/interpretative plans for all Public Use rock art sites before implementing Cultural Resource Project Plan actions. − Consider installing at least one interpretative trail/footpath at each rock art site allocated to Public Use. − Install visitor registers at all Public Use sites. Priorities for Inventory: − Potential threats identified in Cultural Resource Project Plans − Those areas containing rock art identified for prescribed or wildland fire use − Existing designated sites

Allocate and manage all National Register eligible rock art sites for Scientific, Conservation, and/or Public Use, and continue to develop interpretative sites with priority placed on maintaining and improving existing interpretative facilities. Establish fee sites at Public Use rock art sites as appropriate. American Indians will be exempt from fees only when visiting rock art sites for religious practices. Parameter – Cultural Resource Use Allocations: Historic Townsites, Historic Mining Camps, Historic Mining Districts and Related Historic Buildings and Standing Structures, and Historic Racetracks •

Management: − Stabilize or rehabilitate standing structures on a priority basis as identified in Cultural Resources Project Plans and consistent with the Memorandum of Agreement with the Nevada Division of Minerals for Mine Safety Closures (State Protocol Agreement, page 38, Appendix F, Part B: Hazard Abatement). − Write an historic context report and an historic structure report for each mining district based on priorities identified in Cultural Resource Project Plans. − Complete an intensive archaeological inventory of the resource (townsite, camp, or district) for baseline information based on priorities identified in Cultural Resource Project Plans. − Follow Appendix H of the State Protocol Agreement for recording all standing structures for baseline information based on priorities identified in Cultural Resource Project Plans. − Evaluate fire potential and remove fuels where there is threat of loss. − Encourage the use of site stewards for monitoring.

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Scientific Use: − Allow excavation subject to management plan with appropriate research design (which conserves samples for future use). − Post signs with information on site etiquette and the Archaeological Resources Protection Act of 1979 as appropriate. − Permit surface collection of artifacts under the Archaeological Resources Protection Act of 1979 if there is threat of loss or destruction. − Permit data recovery in those instances where future protection is not feasible. Conservation for Future Use: − Allow excavation subject to management plan with appropriate research design (which conserves samples for future use). − Post signs with information on site etiquette and the Archaeological Resources Protection Act of 1979 as appropriate. − Perform stabilization and/or rehabilitation of standing structures on a priority basis as identified in Cultural Resource Project Plans. Public Use: − Place at least one kiosk with interpretation panel for each resource. − Develop site-specific information brochures for all Public Use sites. − Complete National Register nominations for all Public Use sites based on priorities developed in Cultural Resource Project Plans. − Consider preservation and reuse of historic buildings as appropriate. Priorities for Inventory: − Potential threats identified in Cultural Resource Project Plans − Those areas containing historic townsites, mining camps, mining districts, buildings, standing structures and historic racetracks identified for prescribed or wildland fire use − Existing designated sites

Allocate and manage all National Register eligible sites with evidence of unauthorized excavation for Conservation Use and/or Scientific Use in order to perform data recovery in those instances where future protection is not feasible. Allocate and manage the remaining National Register eligible sites for Scientific and/or Public Use. Allocate and manage all of the National Register eligible sites with standing structures for Conservation and/or Public Use. Establish fee sites at Public Use sites as appropriate.

Ely District Approved Resource Management Plan Parameter – Cultural Resource Use Allocations: Historic Cemeteries and Isolated Historic Gravesites •

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Management: − Allow preservation in place and emergency stabilization if natural or cultural threats are causing loss of integrity to cemetery (including wood treatment and stone repair). − Write historic context report and equivalent of historic structure report for all cemeteries based on priorities identified in Cultural Resource Project Plans. − Follow Appendix H of the State Protocol Agreement for recording all standing structures for baseline information based on priorities identified in Cultural Resource Project Plans. − Follow Appendix H of the State Protocol Agreement based on priorities identified in Cultural Resource Project Plans. − Evaluate fire potential and remove fuels where there is threat of loss. − Install visitor registers and create informational brochures. − Install fences or physical barriers. − Install physical protection of historic cemeteries and isolated gravesites in the Cultural Resource Project Plans. − Post appropriate signs with information on site etiquette and the Archaeological Resources Protection Act of 1979. − Encourage the use of site stewards for monitoring. − If established, allocate and manage for Traditional Use. Scientific Use: − No scientific excavation of cemeteries except in those instances where physical disturbance is unavoidable and scientific study of human remains and associated funerary objects, and/or burial patterns, may be appropriate to answer questions about demography, health, and/or status, as well as site significance. Public Use: − Prepare National Register nominations, with the expectation that historic cemeteries and isolated gravesites that are no longer in use and part of historic townsites, landscapes, or themes, will meet National Register criteria. Discharged from Management: − Discharge from Management under the Act of June 14, 1926, commonly known as the Recreation and Public Purposes Act, to a public (government) body requesting transfer with conditions/stipulations that maintain historic character. Priorities for Inventory: − Potential threats identified in Cultural Resource Project Plans − Those areas containing historic cemeteries or isolated gravesites identified for prescribed or wildland fire use − Existing designated sites

Allocate and manage all sites for Conservation and/or Public Use.

Ely District Approved Resource Management Plan Establish fee sites at Public Use sites as appropriate. Parameter – Cultural Resource Use Allocations: Ethnic Arboreal Narratives and Graphics, and Bow Stave Trees •

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Management: − Perform detailed recordation of all arboreal narratives, graphics, and bow stave trees on a priority basis as identified in Cultural Resource Project Plans. Recordation will include, for example, detailed measured drawings, digital photographs, and sub-meter global positioning system locational information. − Evaluate fire potential and remove fuels where there is threat of loss. − Develop management plans and National Register nomination addressing collection/curation policy for specimens. − Perform a reconnaissance inventory of all threatened aspen stands based on priorities identified in Cultural Resource Project Plans. − Post appropriate signs with information on site etiquette and the Archaeological Resources Protection Act of 1979 as appropriate. − Encourage the use of site stewards for monitoring. Priorities for Inventory: − Potential threats identified in Cultural Resources Project Plans − Those areas containing aspen stands identified for prescribed or wildland fire use − Oldest aspen groves with known carvings − Existing designated sites

Allocate and manage all National Register eligible sites for Scientific Use while promoting public access. Parameter – Cultural Resource Use Allocations: Paleoindian Sites The term Paleoindian is defined as follows: “Paleoindian or Pre-Archaic has been attributed to include both fluted and stemmed complexes as well as being reserved for complexes containing fluted points and extinct megafauna. The term Paleoindian is used here to denote archeological sites and artifact assemblages dating between 12,000 to 8,000 years Before Present, which include fluted or stemmed points, and possibly crescents. Under this broad Paleoindian umbrella there are several local traditions and possible variants that may represent different peoples using the land in different ways. This includes Clovis, Folsom, Western Pluvial Lakes Tradition, and Stemmed Complex” (Sherve 2001). •

Management: − Due to fragility of these sites to unauthorized collection, do not allocate these sites to public use, unless disclosure of site location does not harm but benefit the resource. − Complete National Register nominations for all sites on a priority basis as identified in Cultural Resource Project Plans. − Develop partnerships to encourage scientific research on Paleoindian sites in the planning area.

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Address research and preservation potential in Cultural Resource Project Plans. Perform site recordation to include, for example, collection of sub-meter global positioning system locational information of all diagnostic Paleoindian tools when located. − Encourage the use of site stewards for monitoring. Scientific Use: − Allow excavation subject to management plan with appropriate research design to conserve samples for future use. Conservation Use: − Post appropriate signs with information on site etiquette and the Archaeological Resources Protection Act of 1979 where evidence of unauthorized collection is evident. − Conduct annual monitoring of all Paleoindian sites on a priority basis as identified in Cultural Resource Project Plans. − Allow activities that do not have direct impacts to the integrity of the sites. Priorities for Inventory: − Potential threats identified in Cultural Resource Project Plans − Existing designated sites

Allocate and manage all National Register eligible sites for Scientific and/or Conservation Use. Parameter – Cultural Resource Use Allocations: Formative Puebloan Sites •

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Management: − Evaluate fire potential and remove fuels where there is threat of loss. − Allow preservation in place and emergency stabilization if natural or cultural threats are causing loss of integrity to sites. − Post appropriate signs with information on site etiquette and the Archaeological Resources Protection Act of 1979. − Develop partnerships to encourage scientific research on formative Puebloan sites. − Conduct annual monitoring of all formative Puebloan sites based on priorities developed in Cultural Resource Project Plans. − Allocate no more than one site per watershed to Public Use. − Address Scientific, Conservation, and Public Use, as well as public participation in research on formative Puebloan sites in Cultural Resource Project Plans. − Protect formative Puebloan sites from vehicular traffic in the event of fire on or near the sites. Scientific Use: − Allow excavation/scientific research subject to management plan with appropriate research design (which maximizes conservation of the site for future use and also maximizes public participation in the research). Conservation for Future Use: − Post appropriate signs with information on site etiquette and the Archaeological Resources Protection Act of 1979 only where public knowledge is inevitable.

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Public Use: − Install visitor registers and create informational brochures based on priorities established in Cultural Resource Project plans. − Develop specific recreation management plan/interpretative plans for all formative Puebloan sites developed for Public Use. − Perform surface collection of artifacts on all sites allocated to Public Use prior to Public Use designation. Priorities for Inventory: − Potential threats identified in Cultural Resource Project Plans − Existing designated sites

Allocate and manage all National Register eligible sites for Scientific, Conservation Use, and Public Use. Establish fee sites at Public Use sites as appropriate. Parameter – Cultural Resource Use Allocations: Rockshelter and Cave Sites •

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Management: − Evaluate fire potential and remove fuels where there is threat of loss. − Preserve in place and allow emergency stabilization if natural or cultural threats are causing loss of integrity to sites. − Post appropriate signs with information on site etiquette and the Archaeological Resources Protection Act of 1979 where evidence of ongoing public use exists. − Conduct a Class II inventory of areas identified as high potential for aboriginal site occurrence on a priority basis as identified in Cultural Resource Project Plans. − Encourage the use of site stewards for monitoring. Scientific Use: − Encourage partnerships that assist the Ely District Office in evaluating loss of scientific data due to vandalism and in estimating cost of restoration and repair. − Develop partnerships for excavation/scientific research to assist the Ely District Office to understand the paleo-environmental record. Conservation for Future Use: − Evaluate the cost of restoration and repair as soon as vandalism is detected. Public Use: − Install visitor registers and create informational brochures based on priorities established in Cultural Resource Project plans. − Develop specific recreation management plan/interpretative plan for all rockshelter cave sites developed for Public Use. − Perform surface collection of artifacts on all sites allocated to Public Use prior to Public Use designation.

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Priorities for Inventory: − Potential threats identified in Cultural Resource Project Plans − Those areas containing rockshelters identified for prescribed or wildland fire use − Existing designated sites

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Management: − Evaluate fire potential and remove fuels where there is threat of loss. − Post appropriate signs with information on site etiquette and the Archaeological Resources Protection Act of 1979, where evidence of public use exists. − Develop Cultural Resource Project Plans that further define this class of sites and clarify acceptable management actions. − Allow excavation subject to management plan with appropriate research design (which conserves samples for future use). − Subject all sites initially allocated to Conservation, Scientific, Experimental, or Discharged from Management Use to site-specific activity plans that preserve portions of the sites for future use. − Encourage the use of site stewards for monitoring. Scientific Use: − Complete National Register nominations for all sites allocated to Scientific Use on a priority basis as identified in Cultural Resource Project Plans. Public Use: − Continue to produce materials and programs on “Leave What You Find” principles and environmental ethics. − Develop and produce a brochure covering the topic “What Do You Do If You Find an Artifact?”. Priorities for Inventory: − Potential threats identified in Cultural Resource Project Plans − Existing designated sites

Allocate and manage 90 percent of the National Register eligible sites for Conservation and/or Scientific Use and up to 10 percent of the sites per watershed for Experimental Use. Parameter – Cultural Resource Use Allocations: Toolstone Sources or Quarries •

Management: − Evaluate fire potential and remove fuels where there is threat of loss.

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Post appropriate signs with information on site etiquette and the Archaeological Resources Protection Act of 1979, where evidence of public use exists. − Develop Cultural Resource Project Plans that include addressing mineral collection of non-artifacts from quarry/source locations. − Implement photographic monitoring for all obsidian sources. − Encourage the use of site stewards for monitoring. Scientific Use: − Compile National Register nominations for all sites allocated to Scientific Use on a priority basis as identified in Cultural Resource Project Plans. Public Use: − Develop and produce a brochure to enable the public to distinguish between artifacts and mineral specimens. Priorities for Inventory: − Potential threats identified in Cultural Resource Project Plans − Existing designated sites

Allocate and manage all obsidian toolstone sources/quarries for Scientific and/or Conservation Use; 90 percent of all other National Register eligible material sources/quarries for Scientific and/or Conservation Use; and up to 10 percent of all other National Register eligible material sources/quarries for Experimental Use. Parameter – Cultural Resource Use Allocations: Historic Ranching and Livestock-related Historic Sites, Buildings, Standing Structures, and Landscapes •

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Management: − Evaluate fire potential and remove fuels where there is threat of loss. − Post appropriate signs with information on site etiquette and the Archaeological Resources Protection Act of 1979 where evidence of public use exists. − Write historic context reports on a priority basis as identified in Cultural Resource Project Plans. − Write historic structure reports on a priority basis as identified in Cultural Resource Project Plans. − Complete Level I documentation (measured drawings, plans, elevations, photos, and narratives) on all standing structures on a priority basis as identified in Cultural Resource Project Plans. − Obtain photo documentation of historic features and landscapes. − Encourage the use of site stewards for monitoring. Scientific Use: − Allow excavation subject to management plan with appropriate research design (that conserves samples for future use). Conservation Use: − Emphasize conservation of the setting. − Perform stabilization and/or rehabilitation of standing structures on a priority basis as identified in Cultural Resource Project Plans.

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Discharged from Management: − Subsequent to scientific use, discharge sites when preservation in place is impractical. Public Use: − Complete National Register nominations for all Public Use sites on a priority basis as identified in Cultural Resource Project Plans. − Consider standing structures for adaptive uses. Priorities for Inventory: − Potential threats identified in Cultural Resource Project Plans − Existing designated sites

Manage and allocate sites for Public Use on a watershed basis. Allocate and manage all of the National Register eligible sites for Scientific Use and/or Public Use. Parameter – Cultural Resource Use Allocations: Ethnohistoric Sites, Sacred Sites, Traditional Use Areas, Traditional Cultural Properties •

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Management: − When identified, describe locations and boundaries of Ethnohistoric Sites, Sacred Sites, Traditional Use Areas, and Traditional Cultural Properties with global positioning systems or other appropriate technology. − When identified, record Ethnohistoric Sites, Sacred Sites, Traditional Use Areas, and Traditional Cultural Properties. − Evaluate fire potential and remove fuels where there is threat of loss. − Complete National Register nominations on a priority basis as identified in Cultural Resource Project Plans. − Pending approval of Cultural Resource Project Plans, allocate all sites to Conservation use. − Encourage the use of site stewards for monitoring. Priorities for Inventory: − Potential threats identified in Cultural Resource Project Plans − Existing designated sites

Allocate and manage all National Register eligible Ethnohistoric Sites primarily for Conservation Use unless subject to Cultural Resource Project Plans. Allocate and manage all identified Traditional Cultural Properties primarily for Traditional Use. Allocate and manage all identified Sacred Sites or Traditional Use Areas for Conservation Use. Parameter – Cultural Resource Use Allocations: “Other” Sites “Other” is defined as those sites not included in any of the above 12 site types.

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Management: − Evaluate fire potential and remove fuels where there is threat of loss. − Post appropriate signs with information on site etiquette and the Archaeological Resources Protection Act of 1979, where evidence of public use exists. − Encourage the use of site stewards for monitoring. Public Use: − Due to sensitivity of some of these resources, monitor public use on these sites (excluding the agave roasting pits). Priorities for Inventory: − Potential threats identified in Cultural Resource Project Plans − Existing designated sites

Allocate and manage all National Register eligible sites for Scientific and/or Conservation Use with public use being monitored. Permit Scientific Use if it does not destroy features. Allocate all of the agave roasting pits to Scientific, Conservation, and/or Public Use. Monitoring – Cultural Resources Monitoring of cultural resource sites within the planning area will continue, with assistance from the Nevada Heritage Site Stewardship Program and/or other volunteer groups. Identified sites will be monitored to determine condition, impacts, deterioration, and use of such sites. The condition of the sites and other data collected will be entered into the cultural resources database. If a site is listed on or is eligible to the National Register of Historic Places, consultation with the State Historic Preservation Office will be conducted, when necessary, to determine the appropriate action to stop the deterioration of the site or to assist with mitigation. The effectiveness of presentations to the public, educational brochures, interpretative materials, informational materials and displays, scientific research collections and materials, and the site steward program also will be monitored. In addition to monitoring specific sites, the effectiveness of archaeological predictive models developed to assist the Ely District Office in predicting site locations and densities will be monitored. The predictive models will be updated as information on cultural resource sites within the planning area is obtained prior to BLM management actions and issuing approvals for non-BLM actions.

Paleontological Resources The BLM has authority to manage and protect paleontological resources under the Federal Land Policy and Management Act of 1976, the National Environmental Policy Act of 1969, and various sections of Part 43 of the Code of Federal Regulations. Goals – Paleontological Resources Identify and manage at-risk paleontological resources (scientific value); preserve and protect vertebrate fossils through best science methods; and promote public and scientific use of invertebrate and paleobotanical fossils.

Ely District Approved Resource Management Plan

Objectives – Paleontological Resources To manage fossil sites with high scientific value in a stable condition, while allowing appropriate research and casual public collecting. Management Actions – Paleontological Resources General Paleontological Resource Management PAL-1: Allocate and manage all vertebrate sites for Scientific Use. PAL-2: Allocate and manage all invertebrate and paleobotanical sites for Public and/or Scientific Use. PAL-3: Change the use allocation without a plan amendment if another use is evident or proposed. Parameter – Trilobite Collecting PAL-4: Establish a no-fee-based registration system. PAL-5: Establish the following priorities for Inventory: • • •

Predicted threats identified in Cultural Resource Project Plans Existing designated sites Lands identified for disposal Monitoring – Paleontological Resources

Paleontological resource sites will be monitored to determine if site conditions are stable and to assist in management actions to mitigate deteriorating conditions.

Visual Resources Section 102(8) of the Federal Land Policy and Management Act declares that public land will be managed to protect the quality of scenic values and, where appropriate, to preserve and protect certain public land in its natural condition. NEPA, section 101(b), requires federal agencies to “. . . assure for all Americans . . . esthetically pleasing surroundings.” Section 102 of NEPA requires agencies to “. . . utilize a systematic, interdisciplinary approach which will ensure the integrated use of . . . Environmental Design Acts in the planning and decision making . . .” process. Guidelines for the identification of visual resource management classes on public land are contained in BLM Manual Handbook 8410-1, Visual Resource Inventory. New technology in the form of geographic information systems, as well as changing public perceptions about visual resources led to the development of a new inventory for the planning area.

Ely District Approved Resource Management Plan Goals – Visual Resources Manage public land actions and activities in a manner consistent with Ely District Office visual resource management class objectives. Objectives – Visual Resources To implement multiple use activities within the planning area with mitigation measures consistent with the visual resource management classes. Management Actions – Visual Resources VR-1: Manage designated wilderness, wilderness study areas, and some special designation areas such as ACECs (see the discussion on Special Designations) for scenic qualities under Visual Resource Management Class I objectives. VR-2: Manage wilderness study areas released by Congress at the baseline visual resource inventory class. VR-3: Manage visual resources in accordance with the following visual resource management classes (approximate acreages – see Map 10). Class I: 1,138,730 acres Class II: 1,966,212 acres Class III: 5,205,134 acres Class IV: 3,146,526 acres VR-4: Manage the Pony Express National Historic Trail corridor under Visual Resource Management Class II objectives. Monitoring – Visual Resources Monitoring will be conducted for all projects (including, but not limited to projects associated with any developments, land alterations, vegetation manipulation, etc.) that could potentially affect visual resources. These projects will be monitored to ensure compliance with established visual resource management classes. Monitoring will include the use of the visual contrast rating system, described in BLM Manual 8400 (BLM 1984).

Lands and Realty Section 102(a)(1) of the Federal Land Policy and Management Act requires that public land be retained in federal ownership unless disposal of a particular parcel will serve the national interest. Acquisition of land to consolidate ownership patterns will provide for more efficient land management and administration for both

Ely District Approved Resource Management Plan public and private landowners. Retention and acquisition of land containing significant resource values will provide for long-term protection and management of those values. Rights-of-way and other land uses are recognized as major uses of the public lands and are authorized pursuant to sections 302 and 501 of the Federal Land Policy and Management Act. Section 503 of the Federal Land Policy and Management Act provides for the designation of utility corridors and encourages utilization of rights-of-way in-common to minimize environmental impacts and the proliferation of separate rights-of-way. It is BLM policy to encourage prospective applicants to locate their proposals within corridors. Only facilities and uses that are consistent with the special designation associated with that area will be permitted in avoidance areas. Designation of exclusion zones—those areas where no new rights-of-way will be allowed—will provide protection of lands and resources with values that are not compatible with rights-ofway or other land uses. The acquisition of legal public and administrative access is required to ensure continued effective administration and public use of these lands. This need becomes more acute as public use of these lands increases and as landowners become more aware of the value of public and private land for recreation and other purposes. Land tenure adjustment actions (exchanges or fee purchases) can be a valuable tool for access acquisitions. However, without careful review, lands actions, particularly disposals, can result in lost access. Section 204 of the Federal Land Policy and Management Act gives the Secretary of the Interior the authority to make, modify, extend, or revoke withdrawals and mandates periodic review of existing withdrawals. Goals – Lands and Realty Manage public lands in a manner that: •

Allows the retention of public land with high resource values;

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Consolidates public land patterns to ensure effective administration and improve resource management;

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Makes public lands that promote community development available for disposal;

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Meets public, local, state, and federal agency needs for use authorizations such as rights-of-way, permits, leases, and easements while avoiding or minimizing adverse impacts to other resource values; and

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Utilizes withdrawal actions with the least restrictive measures and minimum size necessary to accomplish the desired purpose.

Ely District Approved Resource Management Plan Objectives – Lands and Realty To respond to public, local, state, and federal agency needs for land for community development, utility and other associated rights-of-way, communication sites, and other allowed uses of BLM-administered lands. Management Actions – Lands and Realty Parameter – Retention LR-1: Retain lands or interest in lands within designated critical habitat for federally listed threatened and endangered species unless the disposal results in the acquisition of land with higher quality habitat. LR-2: Retain lands within ACECs. LR-3: Under authority of the Federal Land Policy Management Act, Section 203, retain portions of the National Trails System including the corridors of both the Pony Express National Historic Trail and the California National Historic Trail within the designated corridor. This limitation is without regard for eligibility to the National Register of Historic Places and is instead tied to the congressionally-designated corridor. LR-4: Prior to disposal, review all lands for National Natural Landmark eligibility and retain lands containing resources qualifying as National Natural Landmarks. LR-5: Retain all public lands with springs and creeks that contain fisheries in federal ownership unless the disposal of these lands will result in the acquisition of lands with higher quality habitat. LR-6: Retain lands in areas with high recreation value, unless state and county entities show an over-riding need through an acceptable recreation management plan. Parameter – Disposal (Sales, Exchanges, Recreation and Public Purposes Act, and Airport Conveyances) LR-7: In accordance with Section 7 of the Taylor Grazing Act, 43 U.S.C. 315f, and Executive Order No. 6910, the described lands are hereby classified for disposal by sale, exchange, Recreation and Public Purposes Act, and airport conveyances. LR-8: In accordance with the Lincoln County Conservation, Recreation, and Development Act of 2004, the Ely District Office will dispose of not more than 90,000 acres of public land in Lincoln County identified for disposal by the Ely District Office through the Ely Resource Management Plan or a subsequent amendment to the land use plan. The Ely District Office and the County jointly will select the parcels of land to offer for sale. The lands identified in the approved plan upon signature of the Record of Decision will be withdrawn from: •

All forms of entry and appropriation under the public land laws, including the mining laws;

Ely District Approved Resource Management Plan • •

Location, entry, and patent under the mining laws; and Operation of the mineral leasing and geothermal leasing laws.

Once the lands are disposed of by a sale or an election by the County to obtain land under the Recreation and Public Purposes Act, the withdrawal will no longer apply. LR-9: In accordance with the Lincoln County Conservation, Recreation, and Development Act of 2004, up to 15,000 acres of public land in Lincoln County could be conveyed to Lincoln County for open space and parks. LR-10: In accordance with the Lincoln County Conservation, Recreation, and Development Act of 2004, approximately 4,780 acres of public land in Lincoln County could be conveyed to the State of Nevada for state park expansion. LR-11: In accordance with the White Pine County Conservation, Recreation, and Development Act of 2006, the Ely District Office will dispose of not more than 45,000 acres of public land in White Pine County identified for disposal by the Ely District Office through the Ely Resource Management Plan or a subsequent amendment to the land use plan. The Ely District Office and the County will jointly select the parcels of land to offer for sale. The lands identified in the approved plan upon signature of the Record of Decision will be withdrawn from: • • •

All forms of entry and appropriation under the public land laws, including the mining laws; Location, entry, and patent under the mining laws; and Operation of the mineral leasing and geothermal leasing laws.

Once the lands are disposed of by a sale or an election by the County to obtain land under the Recreation and Public Purposes Act, the withdrawal will no longer apply. LR-12: In accordance with the White Pine County Conservation, Recreation, and Development Act of 2006, the following lands will be conveyed to the State of Nevada, subject to valid existing rights, for no consideration, all right, title, and interest if the state and White Pine County enter into a written agreement supporting the conveyances. •

Approximately 6,265 acres identified as “Steptoe Valley Wildlife Management Area Expansion Proposal”; and

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Approximately 658 acres identified as “Ward Charcoal Ovens Expansion.”

LR-13: In accordance with the White Pine County Conservation, Recreation and Development Act of 2006, the following lands will be conveyed to White Pine County, subject to valid existing rights, for no consideration, all right, title, and interest:

Ely District Approved Resource Management Plan • •

Approximately 1,550 acres identified as “Airport Expansion”; and Approximately 200 acres identified as “Industrial Park Expansion.”

LR-14: The U.S. mineral estate inside or outside the designated disposal areas may be conveyed to consolidate surface and sub-surface management ownership, if there is no known mineral value present, or if the reservation of mineral rights by the U.S. is interfering with or precluding appropriate non-mineral development that is considered to be a more beneficial use of the land. Conveyance of mineral interest shall be made only to the owner of record of the surface, upon payment of administrative costs and the fair market value of the interests being conveyed. LR-15: Subject all Land Tenure adjustments to valid existing rights at the time of disposal. LR-16: Dispose of lands outside of designated disposal areas to resolve unauthorized use of public land only when there are no other practical means of resolution. LR-17: Maintain access to recreation areas. LR-18: Exchanges. Consider land exchanges that serve the national interest and are beneficial to Ely District Office programs or that support the programs of other agencies, per Sections 102, 205, and 206 of Federal Land Policy Management Act. LR-19: Recreation and Public Purposes Act. Convey or lease public lands only for an established or definitely proposed project for which there is a reasonable timetable of development and satisfactory development and management plans. Convey no more land than is reasonably necessary for the proposed use. LR-20: A total of 75,758 acres are available for potential disposal: 57,039 acres in Lincoln County; 0 acres in Nye County; and 18,719 acres in White Pine County. See Map 11. (See Appendix B.) Federal Land Policy and Management Act of 1976, Sections 203 and 209, states that sales are the preferred method of disposal. LR-21: If rights-of-way are approved for power plants, dispose of up to 4,500 acres in White Pine County by direct sale. LR-22: Dispose of 40 acres located at Township 6 South, Range 57 East, Section 25, NW¼ NW¼ by direct sale to resolve a long standing agricultural lease that has several structures on it. LR-23: If a right-of-way is approved for a power plant, dispose of up to 640 acres in Lincoln County by direct sale. LR-24: Use the following criteria for disposal. These criteria may be modified as appropriate in the future.

Ely District Approved Resource Management Plan •

Allow land disposal of parcels containing National Register eligible sites when mitigation and/or data recovery has occurred prior to patent.

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Allow disposal of lands that are difficult to manage and are not suitable for management by another federal department or agency.

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Allow disposal of lands when disposal will serve important public objectives, including but not limited to community expansion or economic development; disposal could not be achieved prudently or feasibly on land other than public lands; and disposal outweighs other public objectives or values.

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Process existing Desert Land Entry, Carey Act, and Indian Allotment applications. If the application is cancelled, relinquished, or rejected, the lands could not be applied for again. Reject applications for Desert Land Entries, Carey Act, or Indian Allotments in designated disposal areas if they are located within a closed water basin unless existing water rights are held.

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Allow land disposals within herd management areas when the disposal 1) will not prohibit free roaming behavior within or between areas inside the herd management area, 2) will not eliminate so much habitat within the herd management area that a significant reduction of the appropriate management levels will result, and 3) will be subject to mitigation.

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Dispose of lands only in identified areas (see Appendix B). Exceptions will be Recreation and Public Purposes Act, Airport Conveyances, existing Desert Land Entries, Carey Act and Indian Allotments, and disposals to resolve trespasses.

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The Ely District Office will provide public notice prior to disposal of public land under military operations areas acknowledging the risks associated with the development of the land and the possible restrictions to uses that would be compatible with the military operations areas.

LR-25: The BLM will work cooperatively with tribes when specific expansion proposals are provided to BLM in the future. They will be reviewed and processed according to appropriate BLM policy related to the expansion of tribal lands. Parameter – Acquisitions LR-26: Limit acquisition of lands to situations where no other reasonable alternative exists. Coordinate on acquisitions with federal, state, and county agencies, and other interested parties prior to the acquisition. Consider private lands or rights for acquisition from willing sellers. •

Consider acquisition of lands or interest in lands with at-risk or high resource values or those characteristics that contribute to restoration, healthy watersheds, or other resource goals (e.g., ACECs, wilderness study areas, habitat for threatened and endangered species, cultural resources, and designated wilderness) in the planning area, or those lands that also provide for environmentally responsible commercial activities.

Ely District Approved Resource Management Plan

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Consider split-estate where appropriate to improve resource management while protecting resource values.

LR-27: Acquire legal public or administrative access from willing landowners, where a public demand or administrative need exists. LR-28: Manage newly acquired lands in the same manner as comparable surrounding public lands or in conformance with established guidelines for the special management area. LR-29: Prior to the acquisition of non-federal lands, conduct assessments (e.g., noxious weed) to enable the authorized officer to factor the cost of weed control into the acquisition decision. Parameter – Withdrawals LR-30: Implement proposed withdrawals, if appropriate, consisting of the BLM Caliente Administrative Site (2 acres), Murry Springs Watershed (the municipal water supply for the City of Ely) (1,260 acres), and the entrance area from Baker to Great Basin National Park (6,720 acres). LR-31: Recommend withdrawal of lands with sensitive or high resource values (e.g., ACECs) from surface and mineral entry (see the discussion on Geology and Mineral Extraction). LR-32: Consider requests by other federal agencies for new withdrawals, withdrawal relinquishments, and modifications on a case-by-case basis. LR-33: Withdraw the 80-acre area around Ash Springs (Township 5 North, Range 61 East, Section 31, SW¼ SW¼, and Township 6 North, Range 61 East, Section 6, Lot 8, Mount Diablo Meridian) from settlement, sale, location, or entry (with the exception of a no surface occupancy stipulation for fluid mineral leasing). Parameter – Corridors LR-34: Manage corridors in the RMP planning area as follows (see Map 12): A. Retain a 1,000-foot wide corridor centered on existing telephone fiber optic lines, from within Township 11 South, Range 71 East, Section 30 in an easterly direction to the Arizona state line. B. Retain the 0.5 mile wide east-west Falcon to Gonder corridor interconnecting with the Ely-to-Utah State Line portion of the Southwest Intertie Project corridor. C. Retain the Ely to Utah State Line portion of the Southwest Intertie Project corridor at 0.5 mile wide.

Ely District Approved Resource Management Plan D. Designate the approved Southwest Intertie Project corridor at 0.75 mile wide from the Elko/White Pine County line to the point where it parallels Highway 93 and the Pahranagat Wildlife Refuge, and at 0.5 mile wide from that point to the Clark County line. E. Maintain the Moapa corridor at 0.5 mile wide. F. Maintain the corridors designated by the Lincoln County Conservation, Recreation and Development Act at 0.5 mile wide. G. Designate a new, 0.5-mile-wide corridor, beginning near the Atlanta Mine where the Lincoln County Conservation, Recreation, and Development Act corridor ends; following a northerly direction along the west side of Spring Valley; and ending at the Southwest Intertie Project corridor. Parameter – Communication Sites LR-35: Authorize communication site locations that support community and economic development with an emphasis on co-location of sites. LR-36: Establish wilderness study areas as avoidance areas. LR-37: Establish designated wilderness as exclusion areas. LR-38: Establish ACECs as avoidance or exclusion areas. LR-39: Coordinate, as appropriate, with appropriate local, state, and federal agencies on siting and construction for all communication towers. Parameter – Land Use Authorizations (Rights-of-Way, Permits, Leases, Easements, and Unauthorized Use) LR-40: Establish wilderness study areas as avoidance areas. LR-41: Establish designated wilderness as exclusion areas. LR-42: Establish ACECs as avoidance or exclusion areas (see the discussion on Special Designations). LR-43: Coordinate, as appropriate, with appropriate local, state, and federal agencies on siting and construction for rights-of-way proposals. LR-44: Consider existing material site rights-of-way in ACECs (both developed and undeveloped) authorized under the provisions of the Federal Highway Aid Act as valid existing rights and consistent with the land use plan. Material site rights-of-way will be authorized within the 1-mile-wide corridor (0.5 mile on each side) on state and county roads and will be restricted to not less than 10-mile separations.

Ely District Approved Resource Management Plan

LR-45: Manage rights-of-way in desert tortoise habitat the same as that described for the Beaver Dam Slope, Kane Springs, and Mormon Mesa ACECs (also see Appendix D). LR-46: Reclaim surface disturbances from unauthorized uses to pre-disturbance conditions, if possible. LR-47: Where feasible, consolidate new land use authorizations within or adjacent to existing authorizations. LR-48: Coordinate with the U.S. Fish and Wildlife Service on utility line development and Avian Protection Plan guidelines. LR-49: Implement the following management actions for desert tortoise habitat (see Map 7). Implement the additional conditions for desert tortoise and conditions for the Southwest willow flycatcher, White River springfish, Pahrump poolfish, and Big Springs spinedace habitat contained in the 2008 Biological Opinion (Appendix D) (also refer to discussions on Special Status Species and Geology and Minerals). •

A speed limit of 25 miles per hour will be required for all vehicles on the project site and unposted dirt access roads.

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If possible, overnight parking and storage of equipment and materials, including stockpiling, will occur in previously disturbed areas or areas to be disturbed that have been cleared by a qualified tortoise biologist. If not possible, areas for overnight parking and storage of equipment will be designated by the BLM authorized officer based on recommendations of a qualified tortoise biologist.

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All vehicular traffic will be restricted to existing access roads, or those roads approved by the BLM authorized officer in consultation with the U.S. Fish and Wildlife Service.

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Project activity areas will be clearly marked or flagged at the outer boundaries before the onset of construction. All activities will be confined to designated areas. Blading of vegetation will occur only to the extent necessary and will be limited to areas designated for that purpose by the BLM authorized officer based on recommendations from a qualified tortoise biologist.

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Projects resulting in residual impacts will require the submission of a BLM and U.S. Fish and Wildlife Service-approved reclamation plan, unless determined by the BLM authorized officer and U.S. Fish and Wildlife Service that reclamation or rehabilitation is not necessary. The reclamation/rehabilitation plan will describe objectives and methods to be used, species of plants and/or seed mixture to be used, time of planting, success standards, and follow-up monitoring. Depending upon the size and location of the project, reclamation could range from recontouring, to rehabilitation and restriction of access points, to intensive reclamation over the entire area of surface disturbance. The plan will be prepared within 60 days following completion of the surface disturbance phase of the project. Reclamation will be addressed on a case-by case basis.

Ely District Approved Resource Management Plan •

If trenches or holes are to remain open overnight, they will be checked for tortoises at the end and beginning of each workday. The trenches or holes also will be checked immediately prior to backfilling.

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The project applicant will notify the BLM’s authorized officer at least ten days before initiation of any project. Notification will be made to the BLM’s wildlife staff in Caliente or Ely.

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BLM’s wildlife staff in Caliente or Ely and the U.S. Fish and Wildlife Service’s Southern Nevada District Office must be notified of any desert tortoise death or injury due to the project implementation by close of business on the following work day.

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All appropriate Nevada Department of Wildlife permits or letters of authorization will be acquired prior to handling desert tortoises and their parts, and prior to initiation of any activity that may require handling tortoises.

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The project proponent must submit a document to the BLM within 30 days of completion of the project, showing the number of acres disturbed; remuneration fees paid; and the number of tortoises taken, which includes capture and displacement, killed, injured, and harassed by other means, during project activities. Monitoring – Lands and Realty

The need for monitoring of rights-of-way and other land use authorizations will be asessed as proposals are evaluated through the NEPA process. Individual projects will be monitored to ensure compliance with the terms and conditions of the authorizing document and through the BLM accomplishment tracking process.

Renewable Energy The Ely District Office will follow established policy for the processing of right-of-way applications for potential renewable energy development projects on public lands administered by the BLM, and for evaluating the feasibility of installing energy systems on BLM administrative facilities and projects. Guidance also will be obtained from the BLM Wind Energy Development Programmatic EIS. (Note: Geothermal energy is discussed with Geology and Mineral Extraction.) Goals – Renewable Energy Provide opportunities for development of renewable energy sources such as wind, solar, biomass, and other alternative energy sources while minimizing adverse impacts to other resources. Objectives – Renewable Energy To be responsive to applications for renewable energy sites and associated rights-of-way, as encouraged by current BLM policy.

Ely District Approved Resource Management Plan Management Actions – Renewable Energy RE-1: Review proposed renewable energy developments on a project-specific basis, considering potential resource conflicts and mitigation measures. Areas of high potential for wind and solar energy development are identified but no specific areas are designated for such development (see Maps 13 and 14). RE-2: Conform wind energy development to the direction presented in Appendix A, Section 3 – BLM Wind Energy Development Program Policies and Best Management Practices. RE-3: Wind energy developers should conduct pre-application consultation with the Ely District Office, the appropriate Department of Defense representatives, and the Department of Homeland Security, to determine possible constraints posed by military testing and training operations. RE-4: Establish wilderness study areas as avoidance areas. RE-5: Establish designated wilderness as exclusion areas. RE-6: Establish ACECs as avoidance or exclusion areas (see the discussion on Special Designations). RE-7: Increase the utilization of biomass from BLM lands and utilize tools of the Healthy Forest initiative such as Stewardship Contracting. Review proposed biomass energy development on a project-specific basis in relation to specific areas of restoration needed to restore healthy vegetation communities. Monitoring – Renewable Energy Monitoring for renewable energy projects will depend on site characteristics and the type of project being proposed (e.g., wind, solar, biomass). For example, local differences in wildlife populations and movement patterns, habitats present, area topography, weather, and facility design result in each proposed renewable energy development project being unique and requiring a detailed individual evaluation plan. Data on wildlife use and mortality at one wind energy facility are not necessarily applicable to others. Monitoring protocols will be developed for the unique assemblage of resources that could be affected and in accordance with the BLM policies that are in place at the time each individual project is proposed.

Travel Management Federal regulations (Title 43 Code of Federal Regulations Subpart 8340) and BLM planning guidance require the Ely District Office to designate all BLM-administered land as either open, limited, or closed in regard to off-road vehicle (now termed off-highway vehicle) use. These designations are designed to help meet public demand for off-highway vehicle activities, protect natural resources, ensure public safety, and minimize conflicts among users. The BLM designates areas as “open” for cross country vehicle use where there are no compelling resource protection needs, user conflicts, or public safety issues to warrant limiting cross-country travel.

Ely District Approved Resource Management Plan

The BLM designates areas as “limited” where it must restrict off-highway vehicle use to meet specific resource management objectives. These limitations may include: restricting the number or types of vehicles; limiting the time or season of use; allowing permitted or licensed use only; limiting use to existing roads and trails; and limiting use to designated roads and trails. The BLM may enact other limitations, as necessary to protect resources, particularly in areas of intense motorized off-highway vehicle use. The BLM designates areas as “closed” if closure to all vehicular use is necessary to protect resources, ensure visitor safety, or reduce use conflicts. Goals – Travel Management Provide and maintain suitable access to public lands. Manage off-highway vehicle use to protect resource values, promote public safety, provide off-highway vehicle opportunities where appropriate, and minimize conflict. Work closely with local, state, tribal, and other affected parties and other resource users to address off-highway vehicle management including land use and route designations, and monitoring and adaptive management strategies such as applying the Limits of Acceptable Change process. Objectives – Travel Management To manage motorized vehicle traffic to sustain this type of use while protecting sensitive resources and providing access. Comprehensive travel and transportation planning is the BLM’s interdisciplinary approach to addressing multiple-use access concerns. Comprehensive travel management planning addresses all resource use aspects and accompanying modes and conditions of travel on public lands, and is not limited to recreational off-highway vehicle activities. Providing and maintaining access to the public lands is an important public service provided by the BLM. The National Management Strategy for Motorized Off-Highway Vehicle Use on Public Lands (BLM 2001) provides guidance in developing and implementing solutions to off-highway vehicle issues. Roads on BLM-administered lands are used by permitted users such as miners and livestock operators and by recreationists for dispersed recreation activities such as hunting, fishing, camping, rock-hounding, off-highway vehicle use, and sightseeing. Access is necessary for BLM personnel to administer the various resource management programs on public land including livestock grazing, mining, wildlife habitat management, watershed management, recreation management, and numerous other programs. Access also is an important factor in fire suppression and fire management. Complexity, incomplete data, and insufficient resources have made it infeasible to complete road and trail network selection and data collection for this planning effort. Collection will follow a standardized process using appropriate technology to allow staff to record road and trail conditions and characteristics.

Ely District Approved Resource Management Plan Travel Management in the planning area will be: •

Comprehensive: All motorized and non-motorized travel that occurs on public lands will be considered.

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Multi-functional: Participation will encompass all functions within the BLM.

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Collaborative: Travel plans will be accomplished in a collaborative and community-based process.

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Outcome based: Travel systems will be designed for transportation outcomes.

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Holistic: Travel management implementation will be accomplished in a holistic approach that provides clear direction for access and recreation opportunities while protecting sensitive areas. This includes signs, maps, education, maintenance, construction, reconstruction, planning, field presence, law enforcement, and monitoring. Management Actions – Travel Management

Parameter – Transportation Plan TM-1: Close designated wilderness to motorized and mechanized travel according to policy and enabling legislation. TM-2: Close the Park Range, Blue Eagle, Antelope Range, and Riordan’s Well wilderness study areas to motorized and mechanized travel. TM-3: Incorporate the Duck Creek Basin designations into the transportation plan 1 (see Map 15). TM-4: Update the Ely District Office Transportation Plan through subsequent implementation-level plans completed primarily along watershed boundaries. Transportation planning may move ahead of the watershed analysis process where the need for vehicle route designation is a greater priority than other watershed management needs. If this is the case, changes in route designations may be made once watershed analysis and additional site-specific NEPA is complete. Until site-specific implementation plans and route designations are complete, motorized travel will be limited to existing roads and trails except when cross-country travel is needed for safety, required for government (federal, state, and local) administrative needs, as authorized on a permit, for big game retrieval, or as otherwise officially approved. The planning process is described as follows: •

Establish an interdisciplinary team to ensure broad participation from a variety of resources.

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Define the goals and objectives of the proposed Travel and Transportation Management Plan.

Implementation level decision.

Ely District Approved Resource Management Plan

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From inventory data, complete a map of the proposed planning area, and identify the baseline of roads, primitive roads, and trails. As road and trail data collection is completed, the interdisciplinary review team will analyze each route and make recommendations for designations within the specific watershed based on the following criteria. (Other criteria will be added as new issues develop in different watersheds over time.) In addition to making recommendations on designations for existing routes, the review team may recommend the development of new roads or trails based on the same criteria. -

Route redundancy Wildlife habitat needs – integrate concepts of habitat connectivity into off-highway vehicle planning to minimize habitat fragmentation Visual resource management class objectives Recreation opportunities Administrative needs Public access needs Special management areas Cultural resources Riparian and wetland resources

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Hold public scoping meetings. Notify the public of the meetings through local media, as appropriate, to reach the potentially affected public. Involve Resource Advisory Councils, local government, state and federal agencies, gateway communities, local motorized and non-motorized user group clubs as applicable to the planning area. Notify the meeting attendees of the objective of the proposed plan using maps and other appropriate materials to facilitate discussion regarding public issues, concerns, and access needs.

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Produce a map depicting the designated roads, primitive roads, and trails available for use (also see Appendix D).

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Implement decisions on the ground. Rehabilitate roads that have been identified through the process as closed to motorized traffic on a case-by-case basis to discourage continued motorized use. In addition, place signs and barriers and produce public maps and other appropriate forms of education and communication to inform the public of updated route designations (also see Appendix D).

TM-5: Limit motorized vehicle traffic to designated routes within desert tortoise habitat outside of designated wilderness. This action will be given a high priority for completion (also see Appendix D). TM-6: Restrict the establishment of new permanent roads and trails in designated desert tortoise habitat. New access routes may be allowed on a temporary basis, or permanently if approved through the NEPA process (also see Appendix D). TM-7: Reroute roads and trails, where feasible, to improve manageability of desert tortoise habitat (also see Appendix D).

Ely District Approved Resource Management Plan

TM-8: Coordinate with the U.S. Fish and Wildlife Service, Lincoln County Road Department, and the Nevada Department of Transportation when possible to identify roads and trails with high tortoise mortality due to impacts from vehicles. Fences and culverts may be installed along these roads and trails to allow for the safe passage of desert tortoises. Parameter – Off-highway Vehicles TM-9: Manage off-highway vehicles in accordance with the following designations (see Map 16). •

Off-highway vehicle use limited to designated roads and trails: 10,306,500 acres.

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Closed to off-highway vehicle use: 1,153,500 acres. This acreage reflects designated wilderness and wilderness study areas. Monitoring – Travel Management

Roads within the planning area will be monitored, usually on an annual basis in coordination with other BLM resource programs and county highway departments, to determine maintenance needs. Monitoring of closed roads will be done in conjunction with monitoring associated with other resource uses such as watershed condition or off-highway vehicle use. The purpose of this monitoring is to ensure that closed roads are not being used and that resource damage, such as erosion, is not occurring. Monitoring off-highway vehicle uses within the planning area will focus on compliance with specific designations, and will determine whether these uses are causing adverse effects on various resources (i.e., soils, water, air, vegetation, fish and wildlife, etc.). Roads and trails are common vectors for noxious and invasive species and monitoring will routinely occur. Methods of monitoring may include visitor contacts, permit review, visual surveillance (including aerial reconnaissance), traffic counters, and/or periodic patrols to check boundaries, signing, visitor use, and limits of acceptable change. Closures will be monitored to ensure public safety and protect affected roadbeds or areas. Baseline data will be established for sites where off-highway vehicle use is occurring, and sites will be rehabilitated or closed as necessary.

Recreation The Federal Land Policy and Management Act provides for recreation use of public land as an integral part of multiple use management. Dispersed, unstructured activities typify the recreational uses occurring throughout the majority of the planning area. BLM Manual 8300 directs the BLM to designate special units known as special recreation management areas. Management within special recreation management areas focuses on providing recreation opportunities that will not otherwise be available to the public, reducing conflicts among users, minimizing damage to resources, and reducing visitor health and safety problems.

Ely District Approved Resource Management Plan Goals – Recreation Provide quality settings for developed and undeveloped recreation experiences and opportunities while protecting resources. Conduct an assessment of current and future off-highway vehicle demand, and plan for and balance the demand for this use with other multiple uses/users. Develop sustainable off-highway vehicle use areas to meet current and future demands, especially for urban interface areas. Objectives – Recreation To provide a wide variety of recreation opportunities to satisfy a growing demand by a public seeking the open, undeveloped spaces that are characteristic of the planning area. To provide visitor information to familiarize people with recreational opportunities throughout the planning area and encourage minimum impact or “Leave No Trace” and “Tread Lightly” recreational skills and ethics for recreational activities. Management Actions – Recreation Parameter – Special Recreation Management Areas REC-1: Manage for the protection of cave resources in the planning area according to the Ely District Office Cave Management Plan. REC-2: Manage five special recreation management areas for a broad recreation opportunity spectrum ensuring a balance of recreation experiences (see Map 17). • • • • •

The Loneliest Highway Special Recreation Management Area (675,123 acres); The Chief Mountain Special Recreation Management Area (111,181 acres); The Egan Crest Special Recreation Management Area (53,455 acres); The Pahranagat Special Recreation Management Area (298,500 acres); and The North Delamar Special Recreation Management Area (202,890 acres).

REC-3: Develop recreation sites, as appropriate, to proactively manage for tourism and recreation experiences. REC-4: Write recreation area management plans for each special recreation management area identified in REC-2 to provide further management guidance at a site-specific level. The process for development of recreation area management plans is described as follows:

Ely District Approved Resource Management Plan •

Establish an interdisciplinary team to ensure broad participation.

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Hold public scoping meetings, as appropriate, to identify the potentially affected publics. Involve Resource Advisory Councils, local government, state and federal agencies, gateway communities, local user groups as applicable to the recreation management area. Prepare appropriate maps to facilitate discussion in identifying issues, concerns and desired future needs.

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Using information from the interdisciplinary team and through public scoping, identify different recreation niches to be served in the special recreation management area. Write specific objectives for the recreation opportunities that would be provided and managed. Use the recreation opportunity spectrum to describe the existing setting character and the desired future setting character.

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Collect and analyze data identified through the scoping process to assist in the development of the best set of proposed actions to meet the recreation and other resource objectives of the area.

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All recreation area management plans will incorporate guidance from Appendix C of the BLM Land Use Planning Handbook. Plans would address the following:

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Development of specific recreation management zones within each special recreation management area.

Public education and interpretation. This would include working with the local communities and other land management agencies in public outreach as well as in marketing an areas recreation opportunities.

Monitoring.

Necessary support actions for the administration of the areas including any business plans, fee programs, permit programs and potential concessionaires.

Utilize Best Management Practices to mitigate localized disturbances to wildlife. These may include, but are not limited to: placement of signs and public education at key recreation access areas; identification of seasonal motorized route closures to protect wildlife during sensitive periods of their lifecycles; re-routes or existing roads and trials; permanent closures of existing routes; and the establishment of recreation use limitations.

REC-5: Manage areas not designated as Special Recreation Management Areas as extensive recreation management areas. A majority of the planning area is available for dispersed, backcountry, and undeveloped recreational uses. REC-6: Manage for recreation facilities and services such as trails, trailheads, staging areas, and associated structures in extensive recreation management areas following activity-level plans and NEPA analysis for the management of designated wilderness, ACECs, the Silver State Off-highway Vehicle Trail,

Ely District Approved Resource Management Plan backcountry byways, and where appropriate, for management of recreational impacts to natural and cultural resources. REC-7: Develop or construct recreation trails and routes in extensive recreation management areas as future needs are identified in site-specific planning. REC-8: Conduct a study of potential routes for the Silver State Off-highway Vehicle trail in White Pine County in accordance with Subtitle E of the White Pine County Conservation, Recreation, and Development Act of 2006. REC-9: Continue to provide visitor orientation information, interpretive activities, signage, safety programs, and other visitor outreach activities. Familiarize the public with recreational opportunities throughout the planning area and encourage minimum impact or “Leave No Trace” behavior for recreational activities. Parameter – Special Recreation Permits REC-10: Monitor the use and number of outfitter and guide permits for geographic regions within the planning area for 3 years following plan implementation. Following the monitoring period, issue outfitter and guide permits with special stipulations and conditions to protect resources and reduce user conflicts. REC-11: Manage four special recreation permit areas totaling approximately 1.3 million acres to provide opportunities for competitive motorcycle special recreation permit events (see Map 18). REC-12: Manage competitive motorcycle events on designated routes within special recreation permit areas (see Map 18). REC-13: Designate event routes and develop additional mitigation in subsequent activity level plans (also see Appendix D). REC-14: Manage for a maximum of two competitive truck events each calendar year. REC-15: Manage four routes for competitive truck events. Rotate use of routes to lessen impacts. REC-16: Permit non-competitive off-highway vehicle events on a case-by-case basis. REC-17: Close desert tortoise ACECs to all high-speed, competitive off-highway vehicle use (also see Appendix D). REC-18: Close desert tortoise ACECs to all types of organized non-speed, off-highway vehicle events from March 1 to June 15, and September 1 to October 31 (also see Appendix D). REC-19: Limit non-speed off-highway vehicle events in desert tortoise ACECs as identified in Table 14 (also see Appendix D).

Ely District Approved Resource Management Plan

REC-20: Limit vehicle off-loading areas, if authorized within desert tortoise habitat, to areas of existing disturbance. Limit event size by the number of vehicles that can be involved without expanding the disturbed area. Terms and conditions and best management practices describe stipulations that will be attached to all special recreation permits for organized off-highway vehicle events in desert tortoise habitat. Table 14 Summary of Limitations for Non-speed Off-highway Vehicle Events Within Desert Tortoise ACECs Corridors Stipulations Dates allowed for events

Maximum number of vehicles Maximum number of laps Maximum number of events allowed per tortoise ACEC

Carp-Elgin, Halfway Wash, and East Halfway Wash June 16 – August 31 November 1 – February 2829 100 1 3

Littlefield November 1 – February 28-29 300 4-wheeled vehicles or 400 motorcycles 1 4

Kane Springs Road June 16 – August 31 November 1 – February 2829 300 1 4

REC-21: Implement the following management actions for desert tortoise habitat (see Map 7). Implement the additional conditions for desert tortoise and conditions for the Southwest willow flycatcher, White River springfish, Pahrump poolfish, and Big Springs spinedace habitat contained in the 2008 Biological Opinion (Appendix D) (also refer to discussions on Special Status Species). •

For speed events: Event participants will be informed that they will not ride their ATVs or motorcycles in the desert after they finish an event. This includes the open desert as well as roads and trails. Failure to comply with this condition by anyone associated with a particular rider will result in the disqualification of that rider.

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For speed events including non-speed sections: If a vehicle breaks down, it will be moved to the side of the race course, avoiding damage to vegetation to the extent possible. Participants who stop to rest will pull over onto side roads or areas devoid of perennial vegetation, if possible. Riders who voluntarily retire from the event will either wait along the course for their crew to pick them up, or travel along the course to a pit area. Chase crews will be limited to retrieving vehicles that are broken down along the course. All chase vehicles must have a pit pass, retrieval pass, or other form of access permission from the Ely District Office.

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For speed events: No spectators or spectator areas will be allowed in ACECs. Spectator vehicles will be allowed in designated spectator areas only. Spectator areas will be confined to existing disturbed areas or new areas selected in coordination with the U.S. Fish and Wildlife Service. Spectator areas are established for viewing purposes only and vehicles will be prohibited. The promoter will be required to mark the boundaries of the spectator area so that spectators can readily tell where the boundary is

Ely District Approved Resource Management Plan located. Rope or wire with warning triangles or other similar sturdy materials will be used. A monitor will be placed at each spectator area to ensure spectators remain within the designated boundary. Anyone found outside of the designated area will be subject to citation. •

For speed events: Pit crews will use only authorized pit areas. Pits shall be confined to existing disturbed areas, unless otherwise approved by the U.S. Fish and Wildlife Service. Pit areas will be marked with a sign stating that a pit pass is required. A maximum of ten pit passes will be issued to each entrant; however, in unusual cases, the Ely District Office may authorize issuance of additional passes to meet specific needs or conditions. Under no circumstances will the issuance of additional passes create or contribute to expansion of designated pit areas. Pit passes should be identified by color or unique number, the name and date of event, and distinguish the pit to which the pass applies (i.e., main pit or course pit), and will be affixed to the windshield of each vehicle. Vehicles in the pit area without pit passes will be towed at the owner’s expense. Unauthorized duplication of pit passes will result in disqualification of the entrant and this will be stated on each pass.

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For speed events including non-speed sections: All event-related activities will be confined to authorized vehicle routes, pit areas, spectator areas, and the course itself, and will not stray into vegetated areas. All major access routes leading into restricted areas will be monitored or marked closed and bannered off. Personnel will be stationed at these areas, as appropriate, to enforce access restrictions. Directional signs to spectator and pit areas will be posted at all main access points. “Race-in-progress” signs will be posted at each location where the race crosses another road. Other disqualification or hazard zones will be monitored periodically during the event.

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For all events, Ely District Office staff will be present to check for compliance with stipulations of the race permit. The importance of staying on the race course will be stressed to all participants by the Ely District Office and promoter.

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For all events: A sufficient number of BLM rangers, monitors, and crowd control officials, as determined by the Ely District Office in coordination with the U.S. Fish and Wildlife Service, will be required to enforce compliance with stipulations of the event permit. Monitors may be Ely District Office or proponent personnel and will be stationed at all disqualification or hazard areas to record any violations. As a general guideline, the Ely District Office will provide one law enforcement officer per 50 participants to control unauthorized vehicular travel off existing roads, and ensure that habitat damage does not occur. The number of law enforcement officers present may be increased or decreased based on the event proponent’s past history of event management and stipulation compliance, the estimated number of spectators, geographic setting of the event, or experience gained from previous similar events, at the discretion of the BLM’s authorizing officer.

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For all events including non-speed sections: To reduce casual use of the race course, the race area may be legally closed to casual use on the day of the race. The promoter will be required to station monitors or post signs at road intersections, prohibiting public access, where the general public is likely to access the race course. A Federal Register notice providing authority to close race areas in the Ely and Las Vegas District Offices will be issued. This will allow BLM law enforcement officers to enforce

Ely District Approved Resource Management Plan regulations. A legal notice will be published in the local newspaper, or other appropriate publication, before the permitted events take place. •

For speed events: Publicity runs will not occur within ACECs, and all event-related vehicular activity will be confined to authorized routes and the course itself and will not stray into vegetated areas.

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For all events: To the extent possible, the event course will be cleared of all unauthorized vehicles and personnel prior to each event.

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For all events: Participants in each event who violate any stipulation of that event will be disqualified from the event. Additionally, failure to comply with permit conditions by any member of the support team or spectators associated with a particular driver or rider will result in the disqualification of that driver or rider.

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For all events: Participants will be informed that passing will be limited to the disturbed areas of roads, trails, and washes and will not occur in vegetated areas adjacent to the course.

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For speed events: To help control spectators, the event promoter will station at least one person at the primary entrance to the spectator area for at least 2 hours before the start of the race and 1 hour after the start of the race. This individual will stop all cars coming into the area, give the occupants information on the limits of the spectator area, and advise them where they can and cannot park.

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For non-speed portions of speed events in ACECs: Participants will be escorted through the ACEC at a speed of no greater than 25 miles per hour.

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For organized non-off-highway vehicle events within ACECs (e.g., dog trials, model airplane events, etc.): The event area will be surveyed for desert tortoise immediately prior to the event. If desert tortoise or sign of desert tortoise is observed, the event will be moved to a different location or set up in such way as to avoid adverse effects to desert tortoise.

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Horse endurance rides will be limited to existing roads and trails. Horse endurance rides are considered speed events and will not be permitted in desert tortoise ACECs. Monitoring – Recreation

Monitoring of recreational use will be designed to ensure visitor compliance with rules and regulations, establish baseline data and observation points for determining impacts from recreation use, and determine appropriate levels and patterns of recreational use. Monitoring will focus on visitation levels and dispersed uses; compliance with rules, regulations, and permit stipulations for specific sites (developed sites); and prescribed standards and guidelines as set in the respective recreation opportunity spectrum classes. Methods of monitoring may include the use of visitor contacts; traffic counters; surveillance at developed recreation sites; periodic patrols to check boundaries, signing, and visitor use; and studies to determine limits of acceptable change, including photo documentation of the changes in resource conditions over time.

Ely District Approved Resource Management Plan Monitoring data will be used to manage visitor use, develop plans and projects to reduce visitor impacts, and meet visitor demand.

Livestock Grazing The Taylor Grazing Act, as amended and supplemented, is the legislative authority providing for livestock grazing on, and protection of, public land. The Federal Land Policy Management Act of 1976 and the Public Rangeland Improvement Act of 1978 direct the management of public land for multiple use and sustained yield. Rangeland management strategies will provide for the maintenance or restoration of watershed function, nutrient cycling and energy flow, water quality, habitat for special status species, and habitat quality for populations and communities of native plants and animals. These management strategies have been supported by development of Standards for Rangeland Health and Guidelines for Livestock Grazing for the Mojave/Southern Great Basin and Northeastern Great Basin regions, which were adopted and approved by the Secretary of Interior in 1997. Goals – Livestock Grazing Manage livestock grazing on public lands to provide for a level of livestock grazing consistent with multiple use, sustained yield, and watershed function and health. Northeastern Great Basin Area Standards •

Upland soils exhibit infiltration and permeability rates that are appropriate to soil type, climate, and land form.

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Riparian and wetland areas exhibit a properly functioning condition and achieve state water quality criteria.

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Habitats exhibit a healthy, productive, and diverse population of native and/or desirable plant species, appropriate to the site characteristics, to provide suitable feed, water, cover and living space for animal species and maintain ecological processes. Habitat conditions meet the life cycle requirements of threatened and endangered species.

Mojave-Southern Great Basin Area Standards •

Watershed soils and stream banks should have adequate stability to resist accelerated erosion, maintain soil productivity, and sustain the hydrologic cycle.

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Watersheds should possess the necessary ecological components to achieve state water quality criteria, maintain ecological processes, and sustain appropriate uses. Riparian and wetlands vegetation should have structural and species diversity characteristic of the stage of stream channel succession in order to provide forage and cover, capture sediment, and capture, retain, and safely release water (watershed function).

Ely District Approved Resource Management Plan

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To allow livestock grazing to occur in a manner and at levels consistent with multiple use, sustained yield, and the standards for rangeland health. Management Actions – Livestock Grazing LG-1: Make approximately 11,246,900 acres and 545,267 animal unit months available for livestock grazing on a long-term basis (see Map 19). LG-2: The following public lands are unavailable for livestock grazing (see Map 19): • • • • •

Mormon Mesa, Kane Springs, and Beaver Dam Slope ACECs (203,670 acres); Baker Archaeological Site ACEC (80 acres) and Snake Creek Indian Burial Cave ACEC (40 acres); Leased public lands associated with the Coyote Springs Development (6,200 acres); Public lands west of U.S. Highway 93 and west of the Desert National Wildlife Range (6,900 acres); and Private/Utah Allotment above Beaver Dam State Park (4,400 acres).

LG-3: Allow allotments or portions of allotments within desert tortoise habitat, but outside of ACECs to remain at current stocking levels as shown in Table 15 unless a subsequent evaluation indicates a need to change the stocking level (also see Appendix D). LG-4: Continue to monitor and evaluate allotments to determine if they are continuing to meet or are making significant progress toward meeting the standards for rangeland health. Table E-1 in Appendix E shows the current grazing preference, season-of-use, and kind of livestock for those allotments that currently are evaluated for meeting standards, are making progress towards achieving the standards, or are in conformance with the policies as determined either through the allotment evaluation process or associated with fully processed term permit renewals. Changes, such as improved livestock management, new range improvement projects, and changes in the amount and kinds of forage permanently available for livestock use, can lead to changes in preference, authorized season-of-use, or kind of livestock. Such changes will continue to meet the RMP goals and objectives, including the standards for rangeland health.

Ely District Approved Resource Management Plan Table 15 Allotments Within Desert Tortoise Habitat but Outside ACECs Allotment Boulder Spring Breedlove Buckhorn Delmar Garden Spring Gourd Springs Grapevine Henrie Complex Lime Mountain Lower Lake East Lower Lake West Lower Riggs Mormon Peak Pahranagat East Pahranagat West Snow Spring Summit Spring Terry White Rock 1

Map Unit Number1 22 23 26 57 76 85 86 91 102 106 107 108 126 143 144 191 202 207 222

Season-of-use 10/1 to 3/31 3/1 to 2/28 3/1 to 3/28 3/1 to 2/28 10/1 to 5/31 10/1 to 5/31 3/1 to 2/28 3/1 to 2/28 10/1 to 5/15 3/1 to 2/28 3/1 to 2/28 5/1 to 3/24 3/1 to 2/28 8/1 to 5/31 10/1 to 5/31 10/1 to 5/31 10/1 to 5/15 11/1 to 5/31 10/1 to 5/31

Active Use Animal Unit Months 416 698 3,370 5,558 2,809 3,458 349 1,380 6,754 640 1,247 1,408 600 511 2,144 3,567 715 1,511 2,880

Map unit number refers to livestock grazing allotments shown on Appendix E.

LG-5: Maintain the current grazing preference, season-of-use, and kind of livestock until the allotments that have not been evaluated for meeting or making progress toward meeting the standards or are in conformance with the policies are evaluated (see Table E-2 in Appendix E). Depending on the results of the standards assessment, maintain or modify grazing preference, seasons-of-use, kind of livestock, and grazing management practices to achieve the standards for rangeland health. Changes, such as improved livestock management, new range improvement projects, and changes in the amount and kinds of forage permanently available for livestock use, can lead to changes in preference, authorized season-of-use, or kind of livestock. Ensure changes continue to meet the RMP goals and objectives, including the standards for rangeland health. LG-6: When changes to BLM grazing permits are being considered in Rocky Mountain and desert bighorn sheep occupied habitat, manage domestic sheep and goats in accordance with current BLM policy. LG-7: Manage allotments that become vacant, for any reason including relinquishment by the permittee, to best meet site-specific and land use planning objectives. Authorized uses may include new grazing permits, forage reserve allotments, dedication to purposes that preclude livestock grazing, and others such as offsetting allotments for permittees who are displaced for any reason. LG-8: Implement management actions for desert tortoise habitat (see Map 7) contained in the 2008 Biological Opinion (Appendix D). Implement conditions in the Biological Opinion for the Southwest willow

Ely District Approved Resource Management Plan flycatcher, White River springfish, Pahrump poolfish, and Big Springs spinedace habitat (also refer to discussions on Special Status Species). Monitoring – Livestock Grazing Monitoring to assess rangeland health standards will include records of actual livestock use, measurements of forage utilization, ecological site inventory data, cover data, soil mapping, and allotment evaluations or rangeland health assessments. Conditions and trends of resources affected by livestock grazing will be monitored to support periodic analysis/evaluation, site-specific adjustments of livestock management actions, and term permit renewals. Monitoring will determine when grazing will be authorized in burned areas, and will contribute to the selection of prescribed burn treatments or other types of treatments based on attainment of resource objectives.

Forest/Woodland Products The Federal Land Policy and Management Act of 1976 directs BLM to “. . . manage public lands according to the principles of multiple-use and sustained yield . . .” One of the multiple uses of resources within the planning area includes the use of forest/woodland areas for fuelwood collection, pinyon nut harvesting, Christmas tree harvesting, posts and poles, seed collection, cactus and yucca collection, and other vegetation product collection. Vegetation management tools (e.g., prescribed fires, thinning) will allow for the regeneration of forest/woodland vegetation types and the selective thinning of these communities to improve their overall health within the planning area and achievement of applicable Resource Advisory Council standards and the desired ranges of conditions for various types of woodlands. Commercial collection of cacti, yucca, and evergreen trees within the state also is regulated under Nevada Revised Statutes (N.R.S. 527.060.120) and the Nevada Administrative Code Chapter 527. Goals – Forest/Woodland Products Provide opportunities for traditional and non-traditional uses of vegetation products on a sustainable, multiple-use basis. Objectives – Forest/Woodland Products To make healthy forest/woodlands and populations of other plants available for the responsible harvesting of forest/woodland and plant products by the public, commercial interests, and American Indians and allow access for traditional and non-traditional uses.

Ely District Approved Resource Management Plan Management Actions – Forest/Woodland Products General Forest/Woodland and Other Plant Product Management FP-1: Do not allow bristlecone pine, limber pine, or swamp cedar to be harvested except for education, scientific, research purposes; for salvage; or for the purpose of preventing or limiting insect or disease problems. Do not permit the cutting of rare or unique trees and shrubs including bearing trees. FP-2: Allow the sale and salvage of desert vegetation (primarily cactus and yucca) based on NEPA analysis and, if necessary, Section 7 consultation with the U.S. Fish and Wildlife Service. FP-3: Allow the harvest of desert vegetation for educational or scientific research purposes. FP-4: Limit vehicle traffic associated with woodland and vegetation product harvesting to existing roads and trails except in areas where completed site-specific analysis or activity plans (e.g., watershed analysis, forestry management plans, etc.) allow. Specific areas would be identified as a condition of the permits/contracts for large quantity sales of vegetation products. These areas generally would be in locations where such activity would assist in meeting watershed objectives. Parameter – Fuelwood Collection FP-5: Allow collection of fuelwood from both live and dead trees for personal use (pinyon, juniper, and mountain mahogany) and commercial use (pinyon and juniper) throughout the planning area, except in closed areas (e.g., wilderness study areas, designated wilderness). FP-6: Allow harvest/collection of other tree species (e.g., aspen, ponderosa pine, and white fir) on a case-by-case basis or through the watershed analysis process. Parameter – Pinyon Pine Nut Harvesting FP-7: Allow personal use collection of pine nuts throughout the planning area. FP-8: Utilize commercial harvest sale areas that have been designated throughout the planning area after coordination with American Indian tribes to avoid traditional use areas. Sell these sites through a competitive bidding process. When the competitive bidding is complete and the sales are awarded, the specific sale area will be documented on the permittee’s contract. Parameter – Christmas Tree Harvesting FP-9: Make pinyon, juniper, and white fir available for personal use throughout the planning area, except in closed areas (e.g., wilderness study areas, designated wilderness). FP-10: Allow commercial use to only pinyon and juniper throughout the planning area.

Ely District Approved Resource Management Plan

FP-11: Make white fir available for commercial harvest if future site-specific planning activities (e.g., watershed analysis) determine that harvest will assist in achieving the desired range of conditions, health and resiliency of the stand, and site-specific objectives for the site. Parameter – Post and Pole Harvesting FP-12: Make pinyon and juniper available for personal and commercial use throughout the planning area, except in closed areas. FP-13: Allow the use of aspen, fir, and spruce on a case-by-case basis, and if harvest will improve the health of the stand. FP-14: If harvest will assist in achieving site-specific objectives, designate areas open to harvest with specified limitations until desired conditions are achieved. Parameter – Seed Collection FP-15: Allow commercial collection on a case-by-case basis. FP-16: Do not allow harvesting of more than 50 percent of the annual seed crop available in any one area. FP-17: Do not allow seed harvest of special status plants except for research, federally/state endorsed propagation for restoration, or case-specific small scale commercial/personal use regulated under permit process. All special status seed harvest will be monitored by the Ely District Office, in the form of permit requirements. FP-18: Encourage hand collection methods, and allow mechanical collection on a limited basis. Parameter – Other Vegetation Products (i.e., wildings, boughs, etc.) Collection FP-19: Allow personal and commercial collection on a case-by-case basis. FP-20: Specify areas for collection on the vegetation sales contract. FP-21: Limit collection methods to those with the least surface disturbing activities. Parameter – Biomass Products FP-22: Allow biomass harvest in areas where vegetation projects require vegetation removal and meet project objectives.

Ely District Approved Resource Management Plan Monitoring – Forest/Woodland Products Periodic monitoring will ensure that commercial use of forest/woodland products within designated areas is in accordance with specifications provided in the contract, and that public use throughout the planning area occurs in accordance with the Approved RMP. If monitoring shows that harvest in a specific area is causing nonattainment of vegetation objectives, the area will be closed until it is determined that objectives are being met and harvest could be allowed to resume. Outbreaks of disease and infestations of insects affecting woodland species will be monitored to ensure timely implementation of management actions to limit the spread and level of damage related to such problems.

Geology and Mineral Extraction The general mining laws give the public the right to locate and develop mining claims on public land. The Mining and Minerals Policy Act of 1970 declares that it is the continuing policy of the federal government to foster and encourage private enterprise in the development of domestic mineral resources. Section 102 of the Federal Land Policy and Management Act of 1976 directs that the public land will be managed in a manner that recognizes the Nation’s need for domestic sources of minerals and other commodities from the public lands, while protecting scientific, scenic, historic, archeological, ecological, environmental, air and atmospheric, and hydrologic values. The BLM’s mineral and national energy policy states that public lands shall remain open and available for mineral exploration and development unless withdrawal or other administrative action is justified in the national interest. Federally owned minerals in the public domain are classified into three categories: leasable minerals, locatable minerals, and mineral materials as discussed below. The classifications are based on acts passed by the U.S. Congress. These acts provide the opportunity for the public to explore for, develop, and produce publicly owned minerals. Leasable minerals are those minerals on public lands where the land is leased to individuals for their exploration and development. The leasable minerals have been subdivided into two classes, fluid and solid. Fluid minerals include oil and gas; geothermal resources and associated by-products; and oil shale, native asphalt, oil impregnated sands, and any other material in which oil is recoverable only by special treatment after the deposit is mined or quarried. Solid leasable minerals are those leased under the mineral leasing acts and those hardrock minerals leased under Reorganization Plan No. 3 of 1946 (acquired lands). Solid leasable minerals are specific minerals such as coal and phosphates. All minerals on acquired lands are considered to be leasable minerals. Leasable minerals are associated with the following laws: Mineral Leasing Act of 1920, as amended and supplemented, Mineral Leasing Act for Acquired Lands of 1947, as amended, and the Geothermal Steam Act of 1970, as amended. Locatable minerals are those “minerals acquired through the General Mining Law of 1872, as amended” (National Research Council 1999). Locatable minerals can include gold, silver, platinum, lead, zinc, magnesium, nickel, tungsten, bentonite, barite, feldspar, uranium, and uncommon varieties of sand, gravel, and stone. Locatable minerals on public lands (if open to mineral entry) can be acquired by initially staking claims over the deposits. However, before mining can occur, permits from various state and federal agencies must be obtained.

Ely District Approved Resource Management Plan

Mineral materials are common varieties of minerals such as sand, gravel, rock, cinders, and common clay. Mineral materials are disposed of through sales contracts or free use permits and are regulated under the Mineral Material Act of July 23, 1947, as amended, and the Surface Use and Occupancy Act of July 23, 1955. Disturbance of public lands in association with mineral material sales is considered a discretionary activity. This means that the action may be denied if resource concerns cannot be protected or mitigated. Goals – Geology and Mineral Extraction Allow for meeting the Nation’s energy needs while providing environmentally responsible production of fluid leasable minerals, and geophysical exploration for energy resources on public lands. Allow development of solid leasable and locatable minerals in a manner to prevent unnecessary or undue degradation. Allow development of mineral materials in a manner that will prevent unnecessary or undue degradation, meet public demand, and minimize adverse impacts to other resource values. Objectives – Geology and Mineral Extraction To provide for the responsible development of mineral resources to meet local, regional, and national needs, while providing for the protection of other resources and uses. Fluid Mineral Leasing Areas available for fluid mineral leasing are identified through management determinations during the planning process. These determinations designate the land as closed or open to leasing, and if open, what stipulations should be applied to the lease. All leases are subject to the terms and conditions of the standard lease form which allows for up to 60-day timing deferments and 200 meter (656 feet) displacements (Title 43 Code of Federal Regulations Section 3101.1-2). Stipulations modify the lease rights beyond the standard lease terms. Constraints are considered to be either major, such as no surface occupancy, or moderate. Moderate constraints consist of timing limitations (seasonal restrictions) and controlled surface use restrictions. Timing limitations indicate that a leased area generally is open to development activities except during a specified period of time to protect identified resource values such as wildlife. Controlled surface use stipulations may require operating constraints to protect resources year round; for example, staying on existing roads. A lease notice may be attached to the lease to inform potential lessees of important resource issues under existing laws and regulations that may result in delays associated with subsequent permitting, and appropriate mitigation of those resource concerns. Resources are further protected during operational activities through the application of best management practices, as contained in the Gold Book (U.S. Department of the Interior and U.S. Department of Agriculture 2006) and the development of site-specific conditions of approval.

Ely District Approved Resource Management Plan Under certain conditions, waivers, exceptions, and modification to lease stipulations may be granted. The circumstances for granting an exception, waiver, or modification are attached to each stipulation. Any lease stipulation may be waived or modified as per Title 43 Code of Federal Regulations Section 3101.1-4. A waiver or modification is allowable only if the authorized officer determines that the factors leading to its inclusion in the lease have changed sufficiently to make requirements of the stipulation(s) no longer justified, or mitigation contained in individual permits will preclude unacceptable impacts. If the waiver or modification is of major concern to the public, such modification will be subject to a 30-day public review. This review can be held concurrent with the required 30-day posting of applications for permit to drill. Plan amendments are not required to waive, modify, or provide exception to lease stipulations. A waiver eliminates a stipulation from the lease. The stipulation waiver can be considered concurrent with application for permit to drill approvals and can be accomplished with any NEPA vehicle available such as an environmental assessment, documentation of NEPA adequacy, categorical exclusion, or any similar process available to the Ely District Office. Waivers can be found in Appendix A, Section 2, for various resource concerns. A modification usually is considered a long-term change in the stipulation to fit the new conditions for which the stipulation was applied; however, it can be short term as well. Depending upon the site conditions, the stipulation may or may not apply to all actions or authorizations on the leasehold. An example of a modification could be a greater sage-grouse lek site that may no longer need a no surface occupancy stipulation on drilling and construction operations if BLM, in consultation with Nevada Department of Wildlife, determines that portions of the area can be occupied without adversely affecting the sage grouse lek. Public notice is required only if the authorized officer determines it is of major public concern. An exception is a one-time exception to all or part of the stipulation for a particular action due to changed environmental conditions at the time and place of the action being considered. For example, a seasonal restriction on drilling in critical winter range could be excepted if the winter is mild and the target species have not moved onto the critical portions of the winter range (near the drilling location). In subsequent years, the conditions could change and preclude an exception being granted. Normally, exceptions are considered minor actions and, therefore, are not subject to a 30-day public review. Solid Leasable, Locatable, and Mineral Materials For lands that are open to the location of mining claims, the claimant has statutory authority under the mining laws to ingress, egress, and development of those claims. This authority means that those areas open to mineral entry for the purposes of exploration or development of locatable minerals cannot be unreasonably restricted.

Ely District Approved Resource Management Plan Mineral Materials (Saleable Minerals) The same areas are closed for mineral materials as for locatable minerals with the exception of Lower Meadow Valley Wash. Management Actions – Geology and Mineral Extraction General Geology and Mineral Management MIN-1: Implement the following management actions for desert tortoise habitat (see Map 7). Implement the additional conditions for desert tortoise and conditions for the Southwest willow flycatcher, White River springfish, Pahrump poolfish, and Big Springs spinedace habitat contained in the 2008 Biological Opinion (Appendix D ) (also refer to discussions on Special Status Species and Lands and Realty). This decision applies to fluid and solid leasable minerals, locatable minerals and mineral materials resources. •

Ensure, through the review of the proposed action and development of the mitigation measures, that the impacts from the proposed action will not jeopardize the continued existence of a listed species or result in the destruction or adverse modification of designated critical habitat. The operator, U.S. Fish and Wildlife Service, and BLM will need to reach concurrence that proposed actions are below the jeopardy or adverse modification threshold. If it is determined that the proposed action will not be below the jeopardy or adverse modification threshold, the project will not go forward.

Parameter – Fluid Leasable Minerals MIN-2: Open to Leasing – Allow leasing on approximately 6.0 million acres open to leasing subject to existing laws, regulations, and formal orders and the terms and conditions of the standard lease form. A lease notice will be attached, where applicable, to inform potential lessees of important resource issues under existing laws and regulations that may result in delays associated with subsequent permitting and appropriate mitigation of those resource concerns. Lease notices will consist of: Cultural Site – Areas of known high potential for cultural sites. Properties known at the time of lease announcements that are listed on or eligible for the National Register of Historic Places will be avoided where possible using lease exclusions or limits on surface use. The preferred avoidance option is to exclude areas containing National Register of Historic Places-eligible sites from leasing and all forms of surface disturbance. The next preferred option is to establish no surface occupancy around these sites, including an adequate buffer. Similar constraints may be placed on proposed lease areas based on probability models and the likelihood of encountering properties eligible for the National Register of Historic Places. Cultural sites not avoided may require consultation with State Historic Preservation Officer and potential treatment plans. Historic Sites – Areas include the Pony Express Trail, the Hastings Cutoff, the Lincoln Highway, and the Osceola Ditch. Any activity planned within 1 mile of these sites must undergo a visual assessment in conjunction with environmental review to determine if the activity will adversely affect the visual integrity.

Ely District Approved Resource Management Plan Appropriate mitigation will take place as necessary to keep the management corridor in as natural a condition as possible. Nondiscretionary activity will be mitigated as needed to preserve the visual integrity. Desert Tortoise Habitat – All proposed projects in desert tortoise habitat will require Section 7 consultation with the U.S. Fish and Wildlife Services. See Map 20 for Lease Notices. Table 16 summarizes the acres open and closed to fluid mineral leasing under the Approved RMP. Table 16 Summary of Fluid Mineral Leasing Acreages Acres1 Open to Fluid Mineral Leasing Standard Lease Terms and Conditions Moderate Restrictions (Timing/Surface Use Limitations) Major Restrictions (No Surface Occupancy) Open – Total Closed to Fluid Mineral Leasing Designated Wilderness/Wilderness Study Areas Discretionary Closures Closed – Total Total

6,532,500 3,277,200 230,100 10,039,800 1,153,500 306,700 1,460,200 11,500,000

Note: There will be about 1,087,620 acres of lease notices that could apply to any of the above open categories. 1

Rounded to hundreds.

MIN-3: Open to leasing, subject to moderate constraints – Protect resources beyond the standard lease terms and conditions by requiring timing and controlled surface use restrictions as indicated in Table 16. Table 17 and Map 20 contain a complete description of all the lease stipulations. There is considerable overlap of acreages associated with various types of timing restrictions. Including this overlap, the cumulative acreage of the separate timing and surface use stipulations totals approximately 3.7 million acres. Timing stipulations apply to the following wildlife species: •

Greater Sage-grouse – The greater sage-grouse is a Nevada BLM sensitive species and was petitioned for listing under the Endangered Species Act as a threatened or endangered species. Timing limitations are required to protect greater sage-grouse breeding and nesting activities and habitat during the crucial winter period (also see Appendix D).

Ely District Approved Resource Management Plan Table 17 Timing and Surface Use Stipulations Resource Greater Sage-grouse Nesting Habitat Associated with Leks

Potential Restriction Timing Limitation. No surface activity will be allowed within two miles of a greater sage-grouse lek from March 1 through May 15. Greater Sage-grouse Winter Timing Limitation. No surface activity will be allowed within Range winter range for greater sage-grouse from November 1 through March 31. Big Game Calving/Fawning/ Timing Limitation. No surface activity will be allowed within Kidding/Lambing Grounds big game calving/fawning/kidding/lambing grounds from April 15 through June 30. Big Game Crucial Winter Timing Limitation. No surface activity will be allowed within Range big game crucial winter range from November 1 through March 31. Desert Tortoise Habitat Timing Limitation. No surface activity will be allowed within desert tortoise habitat from March 1 to October 31 (also see Appendix D). Desert Bighorn Sheep Habitat Timing Limitation. No surface activity will be allowed within occupied desert bighorn sheep habitat from March 1 through May 31 and from July 1 through August 31. Raptor Nest Sites Timing Limitations. No surface activity will be allowed from May 1 through July 15 within 0.5 mile of a raptor nest site that has been active within the past 5 years. Totals of Individual Categories (including overlap) 1

Acres1 1,244,200

100,300

794,200

756,800

314,700

477,600

40,900

3,728,700

Rounded to hundreds.

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Raptors – Raptors (i.e., hawks, eagles, owls, etc.) are protected under numerous laws including the Migratory Bird Treaty Act, the Bald and Golden Eagle Protection Act, and the Endangered Species Act of 1973. Timing limitations are required to protect raptor nesting activities.

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Big Game – Elk, mule deer, pronghorn antelope, and Rocky Mountain bighorn sheep are priority species in the planning area. Timing limitations are required to protect elk, mule deer, pronghorn antelope, and Rocky Mountain bighorn sheep from disturbance during calving, fawning, kidding, and lambing and from disturbance during the crucial winter period.

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Desert Bighorn Sheep Habitat – The desert bighorn sheep is a Nevada BLM sensitive species and is a priority species in the planning area. Timing limitations are required to protect desert bighorn sheep from disturbance during lambing and the crucial hot summer months.

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Desert Tortoise Habitat – The desert tortoise is listed as a threatened species under the Endangered Species Act. Timing limitations are required to protect desert tortoise during the most active period (also see Appendix D).

Ely District Approved Resource Management Plan MIN-4: Stipulation Maintenance – Regularly maintain wildlife databases of species subject to the above stipulations to reflect current inventory status. For example an updated greater sage-grouse lek inventory may show the location of a new lek for which the lease stipulation will be applied in subsequent lease sales. MIN-5: Existing leases – Apply the constraints and requirements identified in this RMP (and ongoing stipulation maintenance) to new use authorizations on existing leases provided that they are within the authority reserved by the terms and conditions of the lease. MIN-6: Open to leasing, subject to major constraints. Apply a no surface occupancy restriction as shown in Table 18 and Map 20. The no surface occupancy for greater sage-grouse leks is a 0.25-mile buffer. MIN-7: Closed to leasing – Close approximately 1.5 million acres to leasing including designated wilderness/wilderness study areas, Congressionally mandated closures, and additional discretionary closures. It is BLM policy to apply the least restrictive constraint to meet the resource protection objective. However, for ACECs (other than desert tortoise ACECs) that exceed 1 mile in length and width, the outer 0.5-mile perimeter is proposed as no surface occupancy and the remainder closed. Areas closed to leasing are shown in Table 19. MIN-8: Evaluate geophysical exploration on a case-by-case basis. Geophysical exploration will not necessarily be subject to the same restrictions as shown for fluid leasing. MIN-9: Apply the following special management actions for leasing within desert tortoise habitat (also see Appendix D): a. Continue closure of the Kane Springs ACEC to leasing. b. Manage the Mormon Mesa and Beaver Dam Slope ACECs as no surface occupancy with exceptions granted upon completion of Section 7 consultation with the U.S. Fish and Wildlife Service. c.

Attach a lease notice for all areas within desert tortoise habitat, to alert the lessee that a Section 7 consultation with U.S. Fish and Wildlife Service will be completed prior to any surface disturbance within desert tortoise habitat.

d. Impose a timing stipulation for all areas within desert tortoise habitat. The stipulation will involve no surface occupancy from March 1 to October 31. e. Unless otherwise authorized, all vehicular traffic will be restricted to existing roads and trails.

Ely District Approved Resource Management Plan Table 18 No Surface Occupancy for Fluid Mineral Leasing Name Andies Mine Trilobite Site Ash Springs Proposed Withdrawal Baker Archaeological Site ACEC Baking Powder Flat ACEC Beaver Dam Slope ACEC1 Blue Mass Scenic Area ACEC Caliente Field Station Cleve Creek Recreation Area Condor Canyon ACEC Egan Crest Trailhead Garnet Hill Rock Animal Corral Highland Range ACEC Honeymoon Hill/City of Rocks ACEC Illipah Reservoir Kirch Wildlife Management Area Lower Meadow Valley Wash ACEC Mormon Mesa ACEC1 Mount Irish ACEC Pahroc Rock Art ACEC Pony Springs Fire Station Rose Guano Bat Cave ACEC Sacramento Pass Recreation Site Greater Sage-grouse Leks Schlesser Pincushion ACEC Shooting Gallery ACEC Shoshone Ponds ACEC Snake Creek Indian Burial Cave ACEC Sunshine Locality National Register District1 Swamp Cedar ACEC Ward Mountain Recreation Site White Pine County Shooting Range White River Archaeological District White River Valley ACEC Total2 1 2

Acres 180 80 80 6,620 36,800 950 2 90 2,880 250 160 160 3,700 3,900 290 5,000 25,000 66,430 8,000 2,400 10 40 440 31,520 4,930 5,800 1,240 40 6,460 3,200 240 255 230 13,100 230,477

See Appendix A, Section 2 for exception. Total acres differ from summary table due to overlap among individual areas and categories.

Ely District Approved Resource Management Plan Table 19 Areas Closed to Fluid Mineral Leasing Name Baker Proposed Withdrawal Baking Powder Flat ACEC Condor Canyon ACEC Designated Wilderness/Wilderness Study Areas Highland Range ACEC Kane Spring ACEC Coyote Springs leased public lands (Congressional) Lincoln County Conservation, Recreation, and Development Act State Park Lincoln County Conservation, Recreation, and Development Act Utility Corridors Lincoln County Proposed Disposals Mount Irish ACEC Murry Spring Watershed Shooting Gallery ACEC Steptoe Valley Wildlife Management Area Expansion Sunshine Locality National Register District White Pine County Conservation, Recreation, and Development Act Airport Expansion White Pine County Conservation, Recreation, and Development Act Industrial Park Expansion White Pine County Conservation, Recreation, and Development Act Additional Withdrawals White Pine County Conservation, Recreation, and Development Act Disposals Total*

Acres 6,720 7,020 1,625 1,153,500 3,200 57,190 6,200 4,780 119,460 57,000 7,100 1,260 9,800 6,265 12,640 1,550 200 98,125 18,600 1,572,235

* Total acres differ from summary table due to overlap among individual areas and categories.

Parameter – Solid Leasable Minerals MIN-10: Open to leasing – Allow solid mineral leasing on approximately 9.9 million acres of federal mineral estate, subject to best management practices. Table 20 and Map 21 show the areas that will be available to leasing Table 20 Summary of Solid Mineral Leasing

Open to Solid Mineral Leasing Closed – Designated Wilderness/Wilderness Study Areas Closed – Discretionary Total 1

Acres1 9,855,400 1,153,500 491,100 11,500,000

Rounded to hundreds.

MIN–11: Issue mineral use authorizations for prospecting permits, exploration licenses, preference right leases, competitive leases, lease modifications, and use permits.

Ely District Approved Resource Management Plan

MIN–12: Closed to leasing – Close approximately 1.6 million acres to solid mineral leasing. This includes designated wilderness and wilderness study areas. Closed areas include existing closed areas carried forward (i.e., Lincoln County Conservation, Recreation, and Development Act). Table 21 and Map 21 show the areas that will be closed to leasing. MIN–13: Apply the following special management actions for solid mineral leasing within desert tortoise ACEC habitat: a. Continue closure of the Kane Springs ACEC to solid mineral leasing. b. Close the Mormon Mesa and Beaver Dam Slope ACECs to solid mineral leasing. Parameter – Locatable Minerals MIN-14: Open to locatable – Allow locatable mineral development on approximately 9.9 million acres of federal mineral estate, subject to the prevention of unnecessary or undue degradation of public lands (see Table 22). MIN-15: Closed to locatable – Manage approximately 1.6 million acres of federal mineral estate from operation of the mining law as closed to locatable mineral entry. Review any lands with closures that expire to determine whether the withdrawals should be extended, revoked, or modified. Table 21 describes the areas that are closed. MIN-16: Apply the following special management actions for locatable minerals within desert tortoise habitat (also see Appendix D): a. Close the Kane Springs, Mormon Mesa, and Beaver Dam Slope ACECs to locatable mineral entry. Existing mining claims that have valid existing rights and mining operations could occur in the ACEC. The BLM will be required to perform validity exams on the existing claims to determine if they are valid claims before any operation may proceed within the ACEC. The operation could proceed once the review of the plan of operation, NEPA review, and Section 7 consultation have occurred. b. Inform operators submitting a notice for activities within desert tortoise habitat, but outside of ACECs, of their responsibilities to comply with specific provisions of the Endangered Species Act.

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Ely District Approved Resource Management Plan Table 21 Areas Closed to Solid Leasable, Locatable, and Mineral Materials Name Andies Mine Trilobite Site Ash Springs Withdrawal Baker Archaeological Site ACEC Baker Withdrawal Baking Powder Flat ACEC Beaver Dam Slope ACEC1 Blue Mass Scenic Area ACEC Caliente Field Station Cleve Creek Recreation Site Condor Canyon ACEC Designated Wilderness/Wilderness Study Areas Egan Crest Trailhead Garnet Hill Rock Animal Corral Highland Range ACEC Honeymoon Hill / City of Rocks ACEC Illipah Reservoir Kane Spring ACEC1 Kirch Wildlife Management Area Coyote Springs leased public lands (congressional) Lincoln County Conservation, Recreation, and Development Act Corridors Lincoln County Conservation, Recreation and Development Act State Park Lincoln County Proposed Disposals Lower Meadow Valley Wash ACEC2 Mormon Mesa ACEC1 Mount Irish ACEC Murry Spring Watershed Pahroc Rock Art ACEC Pony Springs Fire Station Rose Guano Bat Cave ACEC Sacramento Pass Recreation Site Schlesser Pincushion ACEC Shooting Gallery ACEC Shoshone Ponds ACEC Snake Creek Indian Burial Cave ACEC Steptoe Valley Wildlife Management Area Swamp Cedar ACEC Ward Mountain Recreation Site White Pine County Conservation, Recreation, and Development Act Additional Withdrawal White Pine County Conservation, Recreation, and Development Act Airport Expansion White Pine County Conservation, Recreation, and Development Act Industrial Park Expansion White Pine County Conservation, Recreation, and Development Act Proposed Disposals White Pine County Shooting Range White River Archaeological District White River Valley ACEC Total*

Acres 180 80 80 6,720 13,640 36,800 950 2 90 4,500 1,153,500 250 160 160 6,900 3,900 290 57,190 5,000 6,200 119,460 4,780 57,000 25,000 66,430 15,100 1,255 2,400 10 40 440 4,930 15,600 1,240 40 6,265 3,200 240 98,125 1,550 200 18,600 255 230 13,100 1,752,082

* Total acres differ from summary table due to overlap among areas and categories. 1 2

Subject to exception for existing valid claims. Closed for solid leasable and locatable minerals, but open with special stipulations for mineral materials. Mineral materials activities subject to controlled surface use, seasonal timing restrictions, restricted or no use in avoidance areas (e.g., riparian areas, live water, areas with special wildlife or plant features, and sensitive viewsheds), additional NEPA analysis, and Section 7 consultation.

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Ely District Approved Resource Management Plan Table 22 Summary of Locatable Minerals

Open to Locatable Minerals Closed – Designated Wilderness/Wilderness Study Areas Closed – Discretionary Total 1

Acres 9,855,400 1,153,500 491,100 11,500,000

Rounded to hundreds.

Parameter – Mineral Materials (Salable Minerals) MIN-17: Open to mineral materials – Allow disposal of mineral materials on approximately 9.9 million acres of federal mineral estate, subject to best management practices (see Table 23 and Map 21). Table 23 Summary of Mineral Materials

Open to Mineral Materials Closed – Designated Wilderness/Wilderness Study Areas Closed – Discretionary Total 1

Acres1 9,865,600 1,153,500 480,900 11,500,000

Rounded to hundreds.

MIN-18: Space mineral material sites appropriately to accommodate public and private needs while preserving environmental qualities. MIN-19: Maintain and locate community pits and common use areas to provide for the needs of local communities as they develop. MIN-20: Closed to mineral materials – Close approximately 1.6 million acres to mineral materials disposal as shown in Table 23 and Map 21. MIN-21: Apply the following special management actions for mineral material disposal within desert tortoise habitat (also see Appendix D): a. Close the Kane Springs, Mormon Mesa and Beaver Dam Slope ACECs to mineral material disposal except for a 1-mile-wide corridor, 0.5-mile each side of the road, on designated roads (U.S. Highway 93, Carp-Elgin, and Kane Springs roads). Space mineral material site developments to provide approximately 10 miles between adjacent sites. This corridor will be open only for free use permits and

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Ely District Approved Resource Management Plan federal highway material site rights-of-way. Within desert tortoise ACECs, allow mineral materials disposal within the three designated 1-mile-wide corridors only from November 1 through February 28/29. b. Close and reclaim existing pits and designations identified as not needed to meet current and future demand. Monitoring – Geology and Mineral Extraction Monitoring of mineral action disturbances will ensure compliance with Title 43 Code of Federal Regulations Subparts 3100 (oil and gas leasing), 3200 (geothermal leasing), 3500 (solid mineral leasing), 3600 (mineral materials disposal), 3715 (mining occupancy), 3802 (mining, wilderness review), and 3809 (surface management) regulations. Monitoring activities will consist of periodic field inspections of mineral extraction disturbances. Monitoring for leasable minerals will ensure compliance with applicable laws and regulations, term and conditions of leases, standard practices and procedures for geophysical exploration, and conditions of approval for drilling and production operations. On producing leases, monitoring is intended to ensure an accurate accounting of material produced and protect the environment and public health and safety. Monitoring will include field inspection of leasable mineral activities as authorized under Title 43 Code of Federal Regulations Subparts 3161 and 3590. Monitoring for locatable minerals will include periodic field inspections of mining and exploration operations. BLM policy establishes minimum inspection frequencies for mining operations as follows: quarterly inspections are required for all operations using cyanide, and biannual inspections for all other active operations. Operations in sensitive areas or operations with a high potential for greater than usual impacts will be inspected more often. Reclamation would be in accordance with the Title 43 Code of Federal Regulations Subpart 3809, 3715, and BLM Handbook H3042-1. Any noncompliance items will be noted and resolved in accordance with Title 43 Code of Federal Regulations Subparts 3809 and 3715. Monitoring for mineral materials will ensure compliance with applicable laws, regulations, BLM policy contained in BLM Manual Section 3600 and Handbook H-3600-1, the Title 43 Code of Federal Regulations Subpart 3600 regulations, and the requirements of approved contracts and operation plans. An accurate accounting of material removed; protection of the environment and public health and safety; identification and resolution of mineral material trespass issues; and reclamation will be ensured. Monitoring activities will include periodic field inspection of common use areas and other mineral material extraction operations. Operations in sensitive environmental areas or operations with a high potential for greater than usual impacts will be inspected more often and noncompliance items will be noted under procedures as directed by Title 43 Code of Federal Regulations Subpart 3600.

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Ely District Approved Resource Management Plan

Watershed The planning area has been divided into 61 watershed units (entire watersheds or manageable portions thereof). Watershed conditions are controlled by climate, geology, topography, vegetation, and soil characteristics. Vegetation and soil conditions change naturally over time in response to climate, fire, and other natural processes and management. The rate water is captured by the watershed, the amount of storage available, and the rate and location of water release depends on the amount and type of vegetation and type and condition of soil. Thus, healthy watersheds are dependent on achieving or maintaining land health standards.

Goals – Watershed Manage watersheds to achieve and maintain resource functions and conditions required for healthy lands and sustainable uses. Northeastern Great Basin Resource Advisory Council Standards •

Upland soils exhibit infiltration and permeability rates that are appropriate to soil type, climate, and land form.

•

Riparian and wetland areas exhibit a properly functioning condition and achieve state water quality criteria.

•

Habitats exhibit a healthy, productive, and diverse population of native and/or desirable plant species, appropriate to the site characteristics; to provide suitable feed, water, cover, and living space for animal species; and maintain ecological processes. Habitat conditions meet the life cycle requirements of threatened and endangered species.

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Land use plans will recognize cultural resources within the context of multiple use.

Mojave/Southern Great Basin Resource Advisory Council Standards •

Watershed soils and stream banks should have adequate stability to resist accelerated erosion, maintain soil productivity, and sustain the hydrologic cycle.

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Watersheds should possess the necessary ecological components to achieve state water quality criteria, maintain ecological processes, and sustain appropriate uses.

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Riparian and wetlands vegetation should have structural and species diversity characteristic of the stage of stream channel succession in order to provide forage and cover; capture sediment; and capture, retain, and safely release water (watershed function).

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Ely District Approved Resource Management Plan •

To manage watersheds that display physical and biological conditions or functions required for necessary ecological components to achieve state water quality criteria, maintain ecological processes, and sustain appropriate uses. Management Actions – Watershed WS-1: Perform watershed analysis initially on the following watersheds: North Spring Valley, Antelope Valley, Gleason Creek, Smith Valley, South Steptoe Valley, Clover Creek South, North Antelope Valley, Steptoe A, and Spring Valley. When these analyses are complete, analyze the high priority watersheds listed in Table 24 followed by the low priority watersheds. Table 24 Watershed Priority for Analysis and Treatment Watershed Name Antelope Valley Beaver Dam Wash Cave Valley Clover Creek North Clover Creek South Coyote Springs Dry Lake Valley Dry Valley Duck Water Eagle Valley Escalante Desert Gleason Creek Hamblin Valley Huntington Kane Spring Wash Lake Valley Long Valley Meadow Valley Wash N Meadow Valley Wash S Newark North Antelope Valley

Priority High High High High High High High High High High High High High High High High High High High High High

Watershed Name North Spring Valley Panaca Valley Patterson Wash Rose Valley Smith Valley Snake Valley South South Spring Valley South Steptoe Valley Spring Valley Spring Valley South East Spring Valley South West Steptoe A Steptoe B Steptoe C Tikaboo Valley Toquop Wash Tule Desert White River Central White River North White River South

Priority High High High High High High High High High High High High High High High High High High High High

Watershed Name Big Sand Springs Valley Butte Central Little Smoky Valley Coal Valley Deep Creek Delamar Valley Duck Creek Basin Egan Basin Emmigrant Fox-gap Mountain Garden Valley Jakes Valley North Little Smoky Valley Park Range Railroad Valley Ruby Valley Sand Hollow Wash Sand Spring Valley Snake Valley North South Little Smoky Valley

Priority Low Low Low Low Low Low Low Low Low Low Low Low Low Low Low Low Low Low Low Low

WS-2: Additional forage resulting from implementation of vegetation restoration projects identified through the watershed analysis process will be allocated to livestock and wild horses and/or reserved for watershed maintenance and wildlife, depending on the degree of watershed function required to maintain rangeland health standards.

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Ely District Approved Resource Management Plan

Monitoring – Watershed Most parameters essential for evaluating watershed health (e.g., vegetation cover, species composition and community structure, erosion features, resistance to disturbance, etc.) will be monitored in conjunction with other resource programs such as vegetation and soils.

Fire The BLM is charged with clearly defining fire management goals, objectives, and actions in comprehensive fire management plans. Strategic watershed-scale fuel management and fire use planning that integrates a variety of treatment methods, will cost-effectively reduce fuel hazards to acceptable levels and benefit ecological system health. Fire management programs and activities should be based upon safety to fire fighters and the public, protecting resources, minimizing costs, and achieving land management objectives. Goals – Fire Provide an appropriate management response to all wildland fires, with emphasis on firefighter and public safety, consistent with overall management objectives. Return fire to its natural role in the ecological system and implement fuels treatments, where applicable, to aid in returning fire to the ecological system. Establish a community education program that includes fuels reduction within the wildland urban interface to create fire-safe communities. Objectives – Fire To manage wildland and prescribed fires as one of the tools in the treatment of vegetation communities and watersheds to achieve the desired range of condition for vegetation, watersheds, and other resource programs (e.g., livestock, wild horses, soils, etc.). Management Actions – Fire FM-1: Use prescribed fire and wildland fire in compliance with applicable smoke management requirements as specified by the Nevada Smoke Management Program. Obtain annual permits and provide daily evaluation of the fire conditions to ensure applicable air quality regulations are not violated. FM-2: Coordinate with the Department of Defense when planning prescribed burns utilizing aircraft within their military operating air spaces in the planning area. FM-3: Implement and update the Ely Fire Management Plan, as needed. Tier the Ely Fire Management Plan to the general fire management actions in this RMP. Fire management units within the planning area have been identified on the basis of similar vegetation type and condition, management constraints, issues, and objectives and strategies (see Map 22 and Table 25). The following management actions will take place within those fire management units.

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Ely District Approved Resource Management Plan Table 25 Summary of Fire Management Units for the Ely District Office Number NV-040-01 NV-040-02 NV-040-03 NV-040-04 NV-040-05 NV-040-06 NV-040-07 NV-040-08 NV-040-09 NV-040-10 NV-040-11 NV-040-12 NV-040-13 NV-040-14 NV-040-15 NV-040-16 NV-040-17 NV-040-18 NV-040-19 NV-040-20 NV-040-21 NV-040-22 NV-040-23 NV-040-24 NV-040-25 1

Name Meadow Valley-Deerlodge Irish/Timber/Worthington Mountains Northern Mountains Southern Benches Seaman Range-Murphy Gap Elgin/Blue Nose/Kane Spring Pinyon Juniper Southern Valleys Northern Valleys Lincoln County Ely/Lund/Duckwater Cherry Creek/Goshute Ely/Lund Watershed and Wildland Urban Interface Caliente Watershed and Wildland Urban Interface Southern Benches Northern Benches Buck and Bald/Diamond Mountains North Pahroc and Pahranagat Bullwhack Illipah/Wells Station/Horse and Quinn Clover/Delamar/South Pahroc/Irish Highlands and South Egan Range Kern/Snake/Cherry Creek/Park Mountain Mojave Mojave and Highlands Alamo and Hiko

Type Vegetation Vegetation Vegetation Vegetation Vegetation Vegetation Vegetation Vegetation Wildland Urban Interface Wildland Urban Interface Wildland Urban Interface Wildland Urban Interface Wildland Urban Interface High Value Habitat High Value Habitat High Value Habitat High Value Habitat High Value Habitat High Value Habitat High Value Habitat High Value Habitat High Value Habitat Special Management Area Special Management Area Wildland Urban Interface

A fire management type is assigned to each fire management unit to clearly define its primary resource management objective and fire protection values.

1) Wildland fire suppression – provide Appropriate Management Response on all wildland fires that occur within the fire management jurisdiction of the Ely District Office; 2) Fuels treatments – develop and implement prescribed fire and non-fire fuels treatments (mechanical, chemical, and biological) to create fire-safe communities, protect private property, achieve resource management objectives (see the discussion on Vegetation Resources), and restore ecological system health; 3) Wildland fire use – manage, to the extent practical for resource benefit, to improve ecological system function, and to allow fire to function as a natural part of the ecological system, approximately 8.9 million acres would be available for wildland fire use; 4) Emergency stabilization and rehabilitation – design and implement to achieve vegetation, habitat, soil stability, and watershed objectives in accordance with the Programmatic Emergency Stabilization and Rehabilitation Plan; and

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Ely District Approved Resource Management Plan 5) Community assistance/protection – establish an active community education and assistance program where needed to create fire-safe communities and prevent catastrophic impacts on sensitive natural resources. FM-4: Incorporate and utilize Fire Regime Condition Class as a major component in fire and fuels management activities. Use Fire Regime Condition Class ratings in conjunction with vegetation objectives (see the discussion on Vegetation Resources) and other resource objectives to determine appropriate response to wildland fires and to help determine where to utilize prescribed fire, wildland fire use, or other non-fire (e.g., mechanical) fuels treatments. FM-5: In addition to fire, implement mechanical, biological, and chemical treatments along with other tools and techniques to achieve vegetation, fuels, and other resource objectives. FM-6: Base fire management priorities on: 1) firefighter and public safety, and 2) resource protection objectives. FM-7: Implement the following management actions for desert tortoise habitat (see Map 7). Implement the additional conditions for desert tortoise and conditions for the Southwest willow flycatcher, White River springfish, Pahrump poolfish, and Big Springs spinedace habitat contained in the 2008 Biological Opinion (Appendix D ) (also refer to discussions on Special Status Species). •

Assign a qualified resource advisor to each wildland fire to provide relevant information on the occurrence of desert tortoise and important habitat to the incident commander. The resource advisor serves as the field contact representative responsible for coordination with the U.S. Fish and Wildlife Service.

•

Do not authorize burning out of unburned fingers or islands of vegetation, unless it is necessary for safety.

•

Establish fire camps, staging areas, and helispots in previously disturbed areas outside of ACECs, where possible, and in consultation with a qualified resource advisor. Prior to use of any area, allow a resource advisor to survey 100 percent of the area. If a desert tortoise or desert tortoise burrow is found, the area will be adjusted, if possible, to avoid the tortoise or burrow. If avoidance is not possible, a qualified desert tortoise biologist will examine the burrow for occupancy by tortoise. Any tortoise found in burrows or within the area will be relocated.

•

Restrict off-road travel and use of tracked vehicles to the minimum necessary to suppress wildland fires. All vehicles will be parked as close to the road as possible using disturbed areas or wide spots in the road to turn around. All tracks will be obliterated immediately following fire suppression activities, to the extent possible.

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Provide all firefighters and support personnel with a briefing on desert tortoises and their habitat to minimize take, particularly those associated with vehicle use.

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•

Control the speed of fire suppression vehicles to ensure that tortoises on roads can be seen and avoided.

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If possible, rehabilitate fire lines and disturbances associated with fire suppression activities. Determine seed mixtures on a site-specific basis dependent on the probability of successful establishment. Use native and adaptive species that compete with annual invasive species or meet other objectives.

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Conduct post-fire suppression surveys to identify desert tortoise mortalities and report any take of desert tortoise.

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Pre-position suppression fences in critical areas during of periods of high fire danger. Monitoring – Fire

Monitoring will determine whether fire management strategies, practices, and activities are meeting resource management objectives, public concerns, and land health standards. Pre-fire condition and postfire effects will be determined by monitoring plant community composition and trends in burn areas to determine natural recovery, responses from seed planting, and weed and cheatgrass expansion. Monitoring methods may include photo points; density, cover, and frequency plots (pre- and post-burn); fire regime condition class determination (degree of departure from natural regime); and ocular estimates.

Noxious and Invasive Weeds The Federal Land Policy and Management Act of 1976 and Pesticide Registration Improvement Act of 2003 direct the BLM to “. . . manage public lands according to the principles of multiple-use and sustained yield . . .” and “. . . manage the public lands to prevent unnecessary degradation . . . so they become as productive as feasible.” The “Carlson-Foley Act” (Public Law 90-583) and the “Federal Noxious Weed Act” (Public Law 93-629) direct weed control on public land. Executive Order 13112, Invasive Species, was authorized to prevent the introduction of invasive species, provide for their control, and to minimize the economic, ecological, and human health impacts caused by these species. Nevada Revised Statute 555, Control of Insects, Pests, and Noxious Weeds, provides information regarding the designation and eradication of and inspection for noxious weeds within the State of Nevada. Goals – Noxious and Invasive Weeds Prevent the introduction and spread of noxious and invasive weeds. Control or eradicate existing populations. Objectives – Noxious and Invasive Weeds To reduce introduction of, and the areal extent of, noxious and invasive weed populations and the spread of these populations.

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Management Actions – Noxious and Invasive Weeds WEED-1: Continue to use integrated weed management to treat weed infestations and use principles of integrated pest management to meet management objectives and to reestablish resistant and resilient native vegetation communities. WEED-2: Develop weed management plans that address weed vectors, minimize the movement of weeds within public lands, consider disturbance regimes, and address existing weed infestations. WEED-3: When manual weed control is conducted, remove the cut weeds and weed parts and dispose of them in a manner designed to kill seeds and weed parts. WEED-4: All straw, hay, straw/hay, or other organic products used for reclamation or stabilization activities, must be certified that all materials are free of plant species listed on the Nevada noxious weed list or specifically identified by the Ely District Office. WEED-5: Where appropriate, inspect source sites such as borrow pits, fill sources, or gravel pits used to supply inorganic materials used for construction, maintenance or reclamation to ensure they are free of plant species listed on the Nevada noxious weed list or specifically identified by the Ely District Office. Inspections will be conducted by a weed scientist or qualified biologist. WEED-6: Where appropriate, vehicles and heavy equipment used for the completion, maintenance, inspection, or monitoring of ground disturbing activities; for emergency fire suppression; or for authorized off-road driving will be free of soil and debris capable of transporting weed propagules. Vehicles and equipment will be cleaned with power or high pressure equipment prior to entering or leaving the work site or project area. Vehicles used for emergency fire suppression will be cleaned as a part of check-in and demobilization procedures. Cleaning efforts will concentrate on tracks, feet or tires, and on the undercarriage. Special emphasis will be applied to axles, frames, cross members, motor mounts, on and underneath steps, running boards, and front bumper/brush guard assemblies. Vehicle cabs will be swept out and refuse will be disposed of in waste receptacles. Cleaning sites will be recorded using global positioning systems or other mutually acceptable equipment and provided to the Ely District Office Weed Coordinator or designated contact person. WEED-7: Animals used on public lands by special recreation permittees or by contractors for weed control or reclamation will be cleaned, quarantined, and fed weed-free feed prior to being used or released on public lands. The length of this quarantine will be specified in the special recreation permit or contract. WEED-8: Prior to the entry of vehicles and equipment to a planned disturbance area, a weed scientist or qualified biologist will identify and flag areas of concern. The flagging will alert personnel or participants to avoid areas of concern.

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Ely District Approved Resource Management Plan WEED-9: To minimize the transport of soil-borne noxious weed seeds, roots, or rhizomes, infested soils or materials will not be moved and redistributed on weed-free or relatively weed-free areas. In areas where infestations are identified or noted and infested soils, rock, or overburden must be moved, these materials will be salvaged and stockpiled adjacent to the area from which they were stripped. Appropriate measures will be taken to minimize wind and water erosion of these stockpiles. During reclamation, the materials will be returned to the area from which they were stripped. WEED-10: Prior to project approval, a site-specific weed survey will occur and a weed risk assessment will be completed. Monitoring will be conducted for a period no shorter than the life of the permit or until bond release and monitoring reports will be provided to the Ely District Office. If the presence and/or spread of noxious weeds is noted, appropriate weed control procedures will be determined in consultation with Ely District Office personnel and will be in compliance with the appropriate BLM Handbook sections and applicable laws and regulations. All weed control efforts on BLM-administered lands will be in compliance with BLM Handbook H-9011, H 9011-1 Chemical Pest Control, H-9014 Use of Biological Control Agents of Pests on Public Lands, and H-9015 Integrated Pest Management. Submission of Pesticide Use Proposals and Pesticide Application Records will be required. Monitoring – Noxious and Invasive Weeds Monitoring of noxious and invasive weeds within the planning area will continue in cooperation with the State of Nevada, counties, and private interests as well as other federal agencies. Inventories to identify new introductions, distribution, and density of noxious weed populations will be carried out on an annual basis in cooperation with these entities as follows: •

Known noxious weed sites that are identified for treatment will be visited each year and evaluated for effectiveness of control.

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Known sites not identified for treatment will be visited as funding is available.

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All known sites visited will be located with a global positioning system unit (or other suitable technology), measured, and a determination of the need for future treatment will be made.

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Inventories for new noxious weeds will be conducted within the planning area subject to funding. Emphasis will be placed on areas having a high potential for weed introduction and dispersal, such as road corridors and off-highway vehicle trails.

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All burned areas (natural and prescribed) will be surveyed for noxious weeds following the burn as funding becomes available. Any newly discovered sites will be located with a global positioning system unit, measured, and a determination of the need for future treatment will be made.

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Special Designations Management This section deals with a variety of special designations mandated by a number of laws, regulations, and policies. Included are ACECs, the BLM’s Back Country Byway program, wilderness designated by Congress, wilderness study areas, wild and scenic rivers, and other special designations such as National Historic Trails. Section 202(c)(3) of Federal Land Policy and Management Act mandates that priority be given to the designation and protection of ACECs. These areas are defined in section 103(a) as areas where special management attention is required to protect and prevent irreparable damage to important values, resources, systems or processes, or to protect life and safety from natural hazards. Goals – Special Designations Management Evaluate areas of interest for special designation and appropriately manage those areas that meet necessary requirements. Objectives – Special Designations Management To ensure that multiple use activities within the planning area are consistent with the management plans developed for special designation areas such as ACECs. Management Actions – Special Designations Management Parameter – Areas of Critical Environmental Concern SD-1: Manage the Kane Springs, Mormon Mesa, and Beaver Dam Slope ACECs primarily for the recovery of the desert tortoise (203,670 acres) (see Map 23 and Table 26; also see Appendices C and D). SD-2: Develop management plans for the Kane Springs, Beaver Dam Slope, Mormon Mesa, and Lower Meadow Valley Wash ACECs within 3 years to address and implement multiple-use management actions and conservation measures for desert tortoise and Southwestern willow flycatcher. When completing the management plan for Lower Meadow Valley Wash ACEC, all Union Pacific rights-of-way (approximately 2,675 acres) located within the ACEC will receive special consideration noting the legal limitations contained in the right-of-way grants (also see Appendix D). SD-3: Designate 16 ACECs totaling an additional 106,980 acres. See Map 23 and Table 26 for additional information including management prescriptions for each of the ACECs.

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Ely District Approved Resource Management Plan Table 26 Management Prescriptions for ACECs1 Baker Archaeological Site (80 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2 Limited3 III Limited4 Limited5 No surface occupancy Closed Closed No disposal Open6 No New Roads Unavailable Not applicable Closed7

Baking Powder Flat (13,640 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2 Limited3 III, IV Limited4 Limited5 No surface occupancy/Closed Closed Closed No disposal Open6 No New Roads Available8 Not applicable Closed7

Beaver Dam Slope (36,800 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Limited9/avoidance area2 Closed/limited3 IV Limited4 Limited5 No surface occupancy with exception10 Closed11 Closed No disposal Limited12 Limited Unavailable Not applicable Closed7

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Ely District Approved Resource Management Plan Table 26 (Continued) Blue Mass Scenic Area (950 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2 Limited3 I Limited4 Limited5 No surface occupancy Closed Closed No disposal Limited12 Limited, no new roads Available8 Closed Closed7

Condor Canyon (4,500 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2 Limited3 II, III Limited4 Limited5 No surface occupancy/Closed Closed Closed No disposal Limited12 No new roads Available8 Open6 Closed7

Highland Range (6,900 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2 Limited3 III, IV Limited4 Limited5 No surface occupancy/Closed Closed Closed No disposal Limited12 Limited Available8 Closed Closed7

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Ely District Approved Resource Management Plan Table 26 (Continued) Honeymoon Hill/City of Rocks (3,900 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2 Limited3 III, IV Limited4 Limited5 No surface occupancy Closed Closed No disposals Open6 No new roads Available8 Open6 Closed7

Kane Springs (57,190 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Limited9/avoidance2/exclusion area Closed/limited3 I, II, III, IV Limited4 Limited5 Closed Closed11 Limited13 No disposal Limited12 Limited Unavailable Not applicable Closed7

Lower Meadow Valley Wash (25,000 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2 Limited3 II, III, IV Closed Limited5 No surface occupancy Closed Open14 No disposals Limited12 No new roads Available8 Closed Closed7

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Ely District Approved Resource Management Plan Table 26 (Continued) Mount Irish (15,100 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2 Limited3 II, III Limited4 Limited5 No surface occupancy/Closed Closed Closed No disposals Open6 Limited Available8 Closed Closed7

Mormon Mesa (109,680 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Limited9/avoidance2/exclusion area Closed/limited3 I, II, III, IV Limited4 Limited5 No surface occupancy with exception10 Closed11 Limited13 No disposal Limited12 Limited Unavailable Not applicable Closed7

Pahroc Rock Art (2,400 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2 Limited3 II/III Limited4 Limited5 No surface occupancy Closed Closed No disposals Open6 No new roads Available8 Open6 Closed7

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Ely District Approved Resource Management Plan Table 26 (Continued) Rose Guano Bat Cave (40 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2 Limited3 II Limited4 Limited5 No surface occupancy Closed Closed No disposals Open6 No new roads Available8 Open6 Closed7

Schlesser Pincushion (4,930 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2 Limited3 II Limited4 Limited5 No surface occupancy Closed Closed No disposals Limited12 No new roads Available8 Not applicable Closed7

Shooting Gallery (15,600 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2; valid existing rights will remain in effect Limited3 II, III Limited4 Limited5 No surface occupancy/Closed Closed Closed No disposals Open6 No new roads Available8 Open6 Closed7

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Ely District Approved Resource Management Plan Table 26 (Continued) Shoshone Ponds (1,240 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Exclusion area; rights-of-way will not be granted within the area Limited3 III Closed Limited5 No surface occupancy Closed Closed No disposals Limited12 Limited Available6 Closed Closed7

Snake Creek Indian Burial Cave (40 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2 Limited3 III Limited4 Limited5 No surface occupancy Closed Closed No disposals Open6 No new roads Unavailable Not applicable Closed7

Swamp Cedar (3,200 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2 Limited3 III Closed Limited5 No surface occupancy Closed Closed No disposals Limited12 Limited Available8 Closed Closed7

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Ely District Approved Resource Management Plan Table 26 (Continued) White River Valley (13,100 acres) Management Activities Land Use Authorization Off-highway vehicle use Visual resource management class Plant collecting Road maintenance Leasable minerals Locatable minerals Mineral materials Lands disposal Fire management Transportation Livestock management Fuelwood cutting Renewable energy

Management Prescriptions Avoidance area2 Limited3 III, IV Limited4 Limited5 No surface occupancy Closed Closed No disposals Limited12 No new roads Available8 Not applicable Closed7

Acres within the existing Beaver Dam Slope, Kane Springs, and Mormon Mesa ACECs are those within the planning area (see Map 23). Avoidance area; granting rights-of-way (surface, subsurface, aerial) within the area will be avoided, but rights-of-way may be granted if there is minimal conflict with identified resource values and impacts can be mitigated. 3 Off-highway vehicle use is limited to designated roads and trails. Areas within ACECs designated as wilderness are closed to off-highway vehicle use. 4 Plant materials, including common species, may be collected by permit only. 5 Road maintenance is limited to the designated roadway; shoulder barrow/ditch construction is be limited to only that necessary to ensure public safety and serviceability of the road. 6 The activity is allowed in the area. NEPA compliance and clearances for cultural resources and threatened and endangered species required for some activities. 7 Closed to renewable energy facilities; avoidance area for ancillary rights-of-way for access roads, transmission lines, and pipelines. 8 Livestock grazing is controlled through terms and conditions on the grazing permit. 9 Rights-of-way; limit authorization of future communication sites to existing established rights-of-way unless technically unfeasible and encourage use of existing corridors for all future rights-of-way when possible. 10 Exception requires Section 7 consultation with a no adverse impact conclusion. 11 Subject to exception for valid claims existing prior to designation as an ACEC. 12 Limits could be placed on fire management activities. 13 Closed except for free use permits and federal highway material site rights-of-way on a 1-mile corridor, 0.5 mile each side of road on three designated roads. 14 Open with special stipulations. Open to mineral material activities subject to controlled surface use, seasonal timing restrictions, restricted or no uses in avoidance areas (e.g., riparian areas, live water, areas with special wildlife or plant features, and sensitive viewsheds), additional NEPA analysis, and Section 7 consultation. 2

Parameter – Back Country Byways SD-4: Retain the Mount Wilson Back Country Byway. In addition, designate the Rainbow Canyon and the Silver State Trail as back country byways (see Map 24). Parameter – Designated Wilderness SD-5: Manage 22 designated wilderness areas in accordance with the Wilderness Act of 1964; the Nevada Wilderness Protection Act of 1989; the Lincoln County Conservation, Recreation, and Development Act of 2004; the White Pine County Conservation, Recreation and Development Act of 2006.

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Ely District Approved Resource Management Plan Twenty-two designated wilderness areas totaling approximately 1.1 million acres have been designated by Congress in this decision area. This includes six citizen-proposed areas of wilderness quality that were not managed by the Ely District Office as wilderness study areas (see Map 23). Parameter – Wilderness Study Areas SD-6: The Ely District Office currently manages the Park Range and Riordan’s Well wilderness study areas in Nye County. Portions of the Blue Eagle and Antelope Range wilderness study areas, which are managed by the Battle Mountain District Office, also overlap with the planning area. Wilderness study areas within the planning area total approximately 81,000 acres. Manage wilderness study areas under the Interim Management Policy for Lands Under Wilderness Review until such time as Congress makes a determination regarding wilderness designations. Manage lands identified as having wilderness characteristics to protect those characteristics through a variety of other land use plan decisions such as establishing visual resource management class objectives to preserve the existing landscape; attaching conditions to permits, leases, and other authorizations; and establishing limited or closed off-highway vehicle designations. Manage lands released from wilderness study area designation by Congress in the same manner as surrounding lands. In the event that lands released from wilderness study area designation are protected under some other special designation, those lands will retain those protections (e.g., ACECs within a wilderness study area). Wilderness study area lands not retained under some other special designation will be released for other purposes and uses. These other special designations are not a substitute for wilderness designation but provide specific management prescriptions to protect important resources. Parameter – Other Special Designations This section describes management for special designations other than those described in the previous subsections. The types of special designations include scenic areas, geologic areas, natural areas, research natural areas, and rock hound areas. No herd management areas are recommended for designation as wild horse ranges. No rivers have been identified for wild and scenic designation within the planning area. A full inventory and evaluation has not occurred. This evaluation potentially could identify rivers or river segments within the Ely District Office jurisdiction that are eligible for inclusion under the Wild and Scenic Rivers Act. If appropriate, management actions associated with these locations will be amended to the RMP. SD-7: Manage the three special designation areas that are retained as follows (see Management Action SD-3 and Map 23): •

White River Narrows Archaeological District (500 acres) 1. Roads – Maintenance of existing roads (except State Route 318) will only be allowed if it is determined that maintenance will not have an effect on the setting and features that placed this site on the National Register of Historic Places in 1978. New roads will not be permitted.

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2. Structures – Maintenance and construction of structures is allowed if identified in existing habitat management plans or if needed for management of natural values. •

The Garnet Hill Rock Hounding Area (totaling 1,210 acres) 1. This entire area will be segregated from disposal under the public land laws. The recreation site (160 acres) will be closed to solid leasable, locatable, and mineral materials. In addition, the 160 acres will have a no surface occupancy condition for fluid minerals leasing.

•

The Rock Animal Corral Archaeological Area (160 acres) 1. The area will be closed to solid leasable, locatable, and mineral materials. In addition, the area will have a no surface occupancy condition for fluid mineral leasing.

SD-8: Designate the following 7 areas as ACECs (see Management Action SD-3 and Map 23): • • •

Scenic Areas – Blue Mass Natural Areas – Shoshone Ponds, Swamp Cedar Archaeological Sites – Rose Guano Bat Cave, Snake Creek Indian Burial Cave, Baker, Mount Irish

SD-9: Drop the following nine areas, totaling 2,275 acres from special designation status: • • • •

Scenic Areas – Kious Spring, Weaver Creek Geologic Areas – Goshute Cave, Leviathan Cave, Cave Valley Cave, Whipple Cave Research Natural Areas – Pygmy Sage Archaeological Sites – Baker Creek, Garrison Monitoring – Special Designations Management

Areas managed as a special designation (such as ACECs, back country byways, and designated wilderness) will be monitored annually to determine if the resource values for which the area was designated are stable. Monitoring will focus on threats to resource values and the effectiveness of management provisions in protecting and preserving those resource values. Monitoring will assist the BLM in tracking resource conditions and making effective decisions to improve conditions for the special resource over time. Where necessary, the monitoring strategy for special designation areas will be refined during activity level planning, e.g., development of ACEC management plans and designated wilderness management plans.

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REFERENCES Bradley, P. V., M. J. O’Farrell, J. A. Williams, and J. E. Newmark, editors. 2006. The Revised Nevada Bat Conservation Plan. The Nevada Bat Working Group. June 2006. Reno, Nevada. 216 pp. Bureau of Land Management (BLM). 2007. Ely Proposed Resource Management Plan/Final Environmental Impact Statement for the Ely District. U.S. Department of the Interior, Bureau of Land Management, Ely Field Office, Ely, Nevada. November 2007. BLM. 2006. Bureau of Land Management National Scenic and Historic Trails Strategy and Work Plan. Produced by U.S. Department of the Interior, Bureau of Land Management, National Landscape Conservation System, National Scenic and Historic Trails Program. BLM-WO-GI-06-020-6250. Washington, D.C. BLM. 2001. National Management Strategy for Motorized Off-highway Vehicle Use on Public Lands. U.S. Department of the Interior, Washington, D.C. January 19, 2001. BLM. 1986. Ely Cave Management Plan for the Ely District. Bureau of Land Management. Ely District. Ely, Nevada. 1986. BLM 1984. Manual 8400 – Visual Resource Management. Internet website: http://www.blm.gov/nstc/ VRM/8400.html. City of Caliente. 1992. City of Caliente Master Plan. 1992. Desert Tortoise Council. 1999. Proceedings of 1999 Symposium Reports and Papers Presented at the 24th Annual Symposium of the Desert Tortoise Council, March 5-8, 1999. St. George, Utah. Desert Tortoise Council. 1994. Proceedings of the 1994 Desert Tortoise Council Symposium. Gnomon. 2004. Technical Report: Cultural Resources Analysis and Probability Model for the Bureau of Land Management, Ely District. Authors M. Drews and E. Ingbar. June 7, 2004. Lincoln County. 2001. Lincoln County Master Plan. Lincoln County. 1997. Lincoln County Public Land and Natural Resource Management Plan. National Research Council. 1999. Hardrock Mining on Federal Lands. National Academy Press, Washington, D.C., 247 p. National Research Council. 1994. Rangeland Health: New Ways to Classify, Inventory, and Monitor Rangelands. National Academy Press, Washington, D.C. 180 pp.

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Ely District Approved Resource Management Plan Nevada Division of Environmental Protection. 1999. Nevada Smoke Management Plan. State of Nevada, Department of Conservation and Natural Resources. Nevada Division of Water Planning. 1999. Nevada State Water Plan. Department of Conservation and Natural Resources. Carson City, Nevada. Internet web site: http://dcnr.nv.gov/nrp/waterpl.htm. Nye County. 1985. Nye County Policy Plan for Public Lands. Sherve, C. W. 2001. Location, Location, Location: Archaeological Models and PaleoIndian Sites in Nevada. Master’s Thesis, University of Nevada, Reno. Swanson, S. (ed.) 2006. Nevada Rangeland Monitoring Handbook. Second Edition. Educational Bulletin 06-03. 81 p. U.S. Department of the Interior and the U.S. Department of Agriculture. 2006. Surface Operating Standards and Guidelines for Oil and Gas Development; BLM/WO/ST-06/021+3071. BLM, Denver, Colorado. 84 p. Available at http://www.blm.gov/wo/st/en/prog/energy/oil_and_gas/best_management_practices/gold_ book.html. U.S. Environmental Protection Agency. 1998. Interim Air Quality Policy on Wildland and Prescribed Fires. Available at http://www.epa.gov/ttn/oarpg/t1/memoranda/firefnl.pdf. 43 pp. April 23, 1998. U.S. Fish and Wildlife Service. 2008. Programmatic Biological Opinion (84320-2008-F-0078), Informal Consultation (84320-2008-I-0079), and Technical Assistance (84320-2008-TA-0080) for the Bureau of Land Management's Ely District Resource Management Plan. Nevada Fish and Wildlife Office, Las Vegas, Nevada. July 2008. 238 p. U.S. Fish and Wildlife Service. 1994. Desert Tortoise (Mojave Population) Recovery Plan. U.S. Fish and Wildlife Service, Portland, Oregon. 73 pages plus appendices. White Pine County. 1998. White Pine County Land Use Plan.

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N E VA D A

Statewide Comprehensive Outdoor Recreation Plan 2022-2026

Nevada Department of Conservation & Natural Resources Division of State Parks Division of Outdoor Recreation

“Outdoor recreation is integral to life in Nevada, and the SCORP underscores that our outdoor infrastructure should inspire people to get outside, connect with nature, and enjoy our state’s diverse recreational splendor. Collectively, the goals and action items put forward under the SCORP will help elevate Nevada’s celebrated outdoor heritage for generations to come.” — Governor Steve Sisolak

Acknowledgements We would like to acknowledge the Statewide Comprehensive Outdoor Recreation Plan Advisory Team and the Nevada Advisory Board on Outdoor Recreation members who provided key oversight, insight, and contributions to the 2022-2026 Nevada Statewide Comprehensive Outdoor Recreation Plan. In addition, we would like to acknowledge and thank the outdoor enthusiasts and outdoor recreation professionals across the state who participated in surveys and group discussions, and provided helpful input and feedback to early drafts of this document.

Nevada SCORP Core Team Janice Keillor, Deputy Administrator, Nevada Division of State Parks Dana Dapolito, Planning Program Manager, Nevada Division of State Parks Heather Giger, Park and Recreation Program Manager, Nevada Division of State Parks Colin Robertson, Administrator, Nevada Division of Outdoor Recreation Gretchen Kelley Bietz, The Blueprint Collaborative Lois Ann Porter, The Blueprint Collaborative

Nevada SCORP Advisory Team Alan “Scott” Bohemier, Active Transportation Manager, Nevada Department of Transportation (former) Kelly Clark, Rural Development Special Projects and Outreach Coordinator, U.S. Department of Agriculture, Nevada State Office (retired) Tina Dortch, Program Manager, Office of Minority Health and Equity, Nevada Department of Health and Human Services Cheva Gabor, Nevada State Liaison, U.S. Forest Service, Region 4 Intermountain Regional Office Jamie Fields, Nevada State Wilderness Program Lead, Bureau of Land Management, Nevada State Office Bobby Jones, Outdoor Connections Coordinator, Nevada Department of Wildlife Joseph Lednicky, Economist, Community and Economic Development, University of Nevada, Reno Extension Brina Marcus, Managing Director, High Energy Sports, Inc., and Owner/Consultant, Brinergy, LLC Zachary Ormsby, National Monuments and National Conservation Lands Specialist, Bureau of Land Management, U.S. Department of the Interior Sydney Martinez, Content Manager, Nevada Department of Tourism and Cultural Affairs Matthew Weintraub, Deputy Administrator, Nevada Division of Outdoor Recreation James Woolsey, Superintendent, Great Basin National Park, National Park Service, U.S. Department of the Interior Cover photo: Basin and Range National Monument

Acknowledgements (Continued) Nevada Advisory Board on Outdoor Recreation Lieutenant Governor Lisa Cano Burkhead, Chair Lieutenant Governor Kate Marshall, Chair (former) Mauricia Baca, Nevada State Director, The Nature Conservancy Amy Berry, CEO, The Tahoe Fund Bradley Crowell, Director, Nevada Department of Conservation and Natural Resources Kostan Lathouris, Chair, Nevada Indian Commission Robert Mergell, Administrator, Nevada Division of State Parks Dr. Andrew Pasternak, Silver Sage Center for Family Medicine Bob Potts, Deputy Director, Governor’s Office of Economic Development Brenda Scolari, Director, Nevada Department of Tourism and Cultural Affairs Mario Walther, Walther Law Offices Tony Wasley, Director, Nevada Department of Wildlife

We also want to recognize the Northern Nevada International Center’s Language Center for translating the public survey into Spanish and assisting with outreach to the Hispanic/Latino communities across the state to encourage participation in the public surveys for the Statewide Comprehensive Outdoor Recreation Plan (SCORP).

Table of Contents Executive Summary

Part 1: Introduction

Nevada in Context Once in Generations: An Opportunity for Nevada Outdoor Recreation Economic Impacts in Nevada Background, Purpose, and Legal Authority Wetlands Priority Outdoor Recreation Agencies and Programs 2016–2021 SCORP: Our Accomplishments 2022–2026 SCORP: Our Planning Process

Part 2: Outdoor Recreation in Nevada: Research and Findings Outdoor Recreation Supply in Nevada 2021 Nevada Outdoor Recreation Asset Inventory Summary Outdoor Recreation Demand in Nevada Outdoor Recreation Public Survey Results Land Manager Survey Results

5 6 7 9 11 12 15 22

25 26 31 33 36 53

Part 3: 2022–2026 Nevada SCORP Framework

Outdoor Recreation Issues of Statewide Importance 2022-2026 SCORP Themes Goals, Strategic Objectives, and Recommendations

Part 4: Implementation Plan How to Use this Plan Implementation Matrix Ongoing and Future Engagement

Part 5: Call To Action

64 66

68 69 71 75

Table of Contents (Continued)

Acronyms

Appendices

Appendix A: Appendix B: Appendix C: Appendix D: Appendix E: Appendix F: Appendix G: Appendix H: Appendix I: Appendix J: Appendix K: Appendix L: Appendix M: Appendix N: Appendix O:

BEA ORSA 2020 Numbers BEA Nevada 2020 Land and Water Conservation Fund (LWCF) Stateside Assistance Program Funding Overview Nevada Wetlands Priority Conservation Plan, Technical Review Draft, January 2006 Nevada Priority Wetlands Inventory 2007 Land Manager Survey Summary Data Land Manager Survey Comments 2021 SCORP Stakeholder Engagement and Targeted Outreach 2021 Nevada Outdoor Recreation System Asset Inventory Public Surveys Summary Data Public Surveys Comments County Data Reports Part 2 Survey Regional Maps Outdoor Recreation Shared Stewardship Agreement, Nevada 2022 2022-2026 Nevada Open Project Selection Process (OPSP)

SCORP 2022- 2026 | Part 1: Introduction

EXECUTIVE SUMMARY The Land and Water Conservation Fund (LWCF) Stateside Assistance Program was created to assist states in preserving, developing, and assuring accessibility to outdoor recreation resources and to strengthen the health and vitality of U.S. citizens. The program provides funding for outdoor recreation acquisition and development projects for states, cities, counties, and tribal governments. To be eligible for LWCF assistance, each state must prepare a Statewide Comprehensive Outdoor Recreation Plan (SCORP) every five years. This document is Nevada’s 2022-2026 SCORP. In Nevada, the Division of State Parks (NDSP) leads the development of the SCORP, a research-based plan that evaluates the supply and demand of outdoor recreation resources and facilities across all jurisdictions. Specifically, the SCORP identifies outdoor recreation needs and opportunities for recreation improvements and development, provides the foundation for the distribution of LWCF monies for outdoor recreation and open space acquisition, and outlines the overall status of outdoor recreation in Nevada. At the core of the SCORP is an implementation plan designed to address the needs and goals identified by Nevada’s citizens, recreation planners, land managers, and community leaders. The 2022-2026 Nevada SCORP was developed over an 18-month period and represents a collaboration between NDSP and the Nevada Division of Outdoor Recreation (NDOR). From the extensive data collection, analysis, and significant public and land manager engagement and feedback, the SCORP provides an aspirational yet essential vision for the future of outdoor recreation in Nevada.

SCORP 2022- 2026 | Executive Summary

Why does it matter? People and businesses are drawn to Nevada by outdoor recreation, which contributes substantially to Nevada’s high quality of life and plays a significant role in Nevada’s overall economy. Good-paying jobs in outdoor recreation businesses and industries drive Nevada’s economic diversification and contribute to the recruitment and retention of highly skilled workers. Outdoor recreation is a key reason why people want to live, work, and play in Nevada. The following pages provide valuable information gained through multiple surveys that garnered almost 7,000 responses. Additional input was provided by the Nevada Advisory Board on Outdoor Recreation, and the Nevada SCORP Advisory Team. Based on this input, three themes emerged: •

Sustainable Outdoor Recreation

•

Community and Economic Vitality

•

Pathways to Health and Wellness

These themes respond to issues, current trends, user preferences, and opportunities for outdoor recreation in Nevada. They also reflect the finicky supply-and-demand matrix necessary to balance high-quality outdoor experiences while conserving and stewarding natural and cultural resources. The SCORP themes are interconnected and critical components to achieving a vision for the future where Nevada’s great outdoors continue to provide rich recreation experiences and enjoyment for residents and visitors alike.

Great Basin National Park

The SCORP concludes with an implementation plan outlining goals, strategic objectives, and recommendations based on public and land manager input. To address identified recreation issues, barriers and priorities, the plan also highlights the partnership needed between outdoor recreation and conservation agencies. No single entity can address all the challenges and opportunities outdoor recreation faces in Nevada. Successful achievement of the goals outlined in this plan will come from working collaboratively across interests, sectors, agencies, and organizations to implement projects supporting meaningful outdoor experiences and vibrant communities and economies statewide.

SCORP in the time of COVID-19 The 2022-2026 SCORP has been influenced in ways different from all past plans. The data collection for this SCORP cycle took place as the nation was within the first year of the COVID-19 pandemic and, as such, certainly impacted how Nevadans participated in outdoor recreation in 2020-2021. A few of the findings that seem most influenced by the pandemic and outlined in the narrative of this document include: Increase/decrease in level of recreating outdoors Types of barriers to outdoor recreation The pause/cancellation of team and organized sports in 2020/2021

SCORP 2022- 2026 | Executive Summary

Part One Boundary Peak

INTRODUCTION

In this section: Nevada in Context Once in Generations: An Opportunity for Nevada Outdoor Recreation Economic Impacts in Nevada Background, Purpose, and Legal Authority Wetlands Priority Outdoor Recreation Agencies and Programs 2016–2021 SCORP: Our Accomplishments 2022–2026 SCORP: Our Planning Process

SCORP 2022- 2026 | Part 1: Introduction

“I believe that there is a subtle magnetism in Nature, which, if we unconsciously yield to it, will direct us aright.” — Henry David Thoreau

Arc Dome Wilderness

So, it comes as no surprise — even today, with technology as a constant distraction and most learning and working occurring indoors — that people are not satisfied with an indoor lifestyle. Concrete, asphalt, and four walls are not a natural environment for humans, and our bodies know that instinctually. More and more people are beginning to view outdoor recreation as fundamental, similar to the need for public schools, clean water, and affordable housing. Spending time outdoors is not only a necessity for a high quality of life, it is a necessity of the human spirit. We must maintain our connection to the outdoors, or we lose the connection to ourselves.

Washoe Lake State Park

Humans have an innate affiliation with nature, with a connection to the outdoors that evolved over hundreds of thousands of years. Our ancestors were required to study, understand, and rely on the natural environment for their survival. It was critical to know what plants to eat, the migration patterns of animals, and how to predict the weather.

SCORP 2022- 2026 | Part 1: Introduction

Diamond Peak Ski Resort

NEVADA IN CONTEXT It is no mystery why spending time outdoors is a way of life for so many Nevadans. More than 85 percent of Nevada is public land - the highest percentage among all states in the continental U.S.1 This land is open to the public for recreational purposes, with limited exceptions. Because of the state’s large areas of public land, low population density, and high levels of public access, the outdoors is an important part of residents’ lives, visitors’ experiences, and the state’s economy.2 Geographically, Nevada is the seventh largest state in the nation in sheer land mass, with 110,000 square miles, 70 million acres, and 314 named mountain ranges3, earning the state the distinction of the most mountainous state in the continental U.S. The Silver State is known for its wide-open spaces; other-worldly landscapes; more than 6 million acres of National Forest lands; 48 million acres of Bureau of Land Management (BLM) lands; four national park units; and 27 state parks, historic parks, and recreation areas in all reaches of the state. While many people might conjure up images of Nevada as neon lights, casinos, deserts, and dry creek beds, Nevada has more than 200 lakes and reservoirs (including Lake Tahoe, the largest alpine lake in North America); upwards of 600 rivers and streams; over 300 natural hot springs (more than any other state); the oldest living trees on earth (Pinus longaeva, known as the Great Basin bristlecone pine); some of the darkest skies and brightest stars in the U.S.; and more ghost towns than “living” towns (600+).

As a result of access to the natural and cultural resources Nevada has to offer, participation in outdoor recreation in Nevada has increased in recent years4. Many factors are cited for this surge, including an increasing awareness of Nevada’s spectacular scenic beauty and diverse landscapes; the ease of access to the outdoors and public lands here; and a growing population drawn, in part, by extraordinary opportunities to recreate outdoors. In the past decade alone, the population of Nevada grew by 14%, spiking from 2.7 million to 3.1 million people between 2010-2020. However, challenges arise with the growth in participation and appreciation for Nevada’s great outdoors. Consequences of this growth include: overcrowding in some areas; insufficient financial and/or human resources to manage, maintain, or grow park and recreation infrastructure in response to population growth; misuse, abuse, and vandalism; and heavier use of parks, trails, and other facilities than is sustainable. In short, the integrity of existing outdoor recreation facilities, the availability of new outdoor recreation infrastructure, and positive visitor experiences is at risk.

1 https://www.leg.state.nv.us/Division/Research/Publications/PandPReport/35-PLGNR.pdf 2 Nevada Outdoors 3 Travel Nevada, 2021 Official State Visitors Guide 4 2021Outdoor Recreation Participation Trends Report, Outdoor Foundation https://ip0o6y1ji424m0641msgjlfy-wpengine.netdna-ssl.com/ wp-content/uploads/2015/03/2021-Outdoor-Participation-Trends-Report.pdf

SCORP 2022- 2026 | Part 1: Introduction

ONCE IN GENERATIONS: AN OPPORTUNITY FOR NEVADA The timing of the 2022-2026 Statewide Comprehensive Outdoor Recreation Plan (SCORP) coincides with a constellation of historic circumstances: the COVID-19 pandemic, the incredible resilience of Nevadans in the face of pandemic-induced uncertainty, and the unprecedented state and federal response to the pandemic.

Gold Butte National Monument

The largest federal investments ever seen in outdoor recreation infrastructure, maintenance, and programming will be made during the period of time this SCORP is relevant, from 2022-2026. Legislation passed during the pandemic, including the Great American

Outdoors Act, the American Rescue Plan Act, the Bipartisan Infrastructure Law (Infrastructure Investment and Jobs Act) will contribute to the enhancement of outdoor recreation opportunities and related infrastructure across the country. Simultaneously, awareness of the importance of safe, fun, and engaging outdoor recreation experiences is increasing. The unique combination of federal investment, growing awareness, and increasing participation afford Nevada the chance to markedly improve the daily lives of citizens across the state through outdoor recreation.

SCORP 2022- 2026 | Introduction

Black Rock Desert

OUTDOOR RECREATION ECONOMIC IMPACTS IN NEVADA According to the U.S. Bureau of Economic Analysis (BEA) Outdoor Recreation Satellite Account (ORSA), Nevada’s outdoor recreation economy generates substantial economic benefits to the state through direct spending on travel and hotel room nights, retail equipment and gear purchases, private industry, manufacturing and logistics, and a myriad of supporting and supplemental sectors across the entire economy.⁵ The BEA established the ORSA in the U.S. Department of Commerce in 2018. The ORSA conducts annual analyses of industry specific clusters at the national and state levels, developing methods and estimates for understanding the economic contributions of outdoor recreation to state and national economies.6 The ORSA is a collaborative, intergovernmental effort to measure the impact of outdoor recreation on the U.S. economy, focusing in particular on current dollar gross domestic product (GDP), employment, and compensation estimates for the outdoor recreation sector.

In 2020, outdoor recreation in Nevada contributed: $4 billion in economic output 49,501 jobs in the state $2.2 billion in compensation and wages earned 3.8% of Nevada’s total employment

See Appendix A. BEA ORSA 2020 Numbers 5 Outdoorindustry.org/wp-content/uploads/2015/ORDA-Nevada.pdf 6 BEA ORSA 2020 Numbers

SCORP 2022- 2026 | Part 1: Introduction

2020 — Nevada ⁷

Economic Impacts of Outdoor Recreation in Nevada Value added (GDP)

Employment

Compensation

ORSA TOTAL

Share of State

ORSA Total

Share of State

ORSA Total

Share of State

$4.0 billion

2.30%

49,501 jobs

3.80%

$2.2 billion

2.40%

2020

State Rank

Activity

2018

2019

Boating/Fishing

$179,497

$194,931

$260,673

RVing

$130,914

$140,659

$155,967

Motorcycling/ATVing

$64,214

$68,195

$76,832

Hunting/Shooting/Trapping

$63,649

$64,701

$62,648

Snow Activities

$53,096

$59,193

$45,111

Climbing/Hiking/Tent Camping

$34,063

$37,256

$37,370

Equestrian

$33,876

$31,374

$27,624

Bicycling

$10,761

$12,753

$14,831

Recreational Flying

$7,465

$9,062

$9,399

People and businesses are drawn to Nevada by its outdoor recreation opportunities. Outdoor recreation contributes substantially to Nevada’s high quality of life and plays a significant role in the effort to grow and diversify Nevada’s overall economy. Goodpaying jobs in outdoor recreation businesses and industries are driving Nevada’s economic diversification and contributing to the recruitment and retention of highly skilled workers. Outdoor recreation is a strong reason why people want to live, work, and play in Nevada.

Nye County

Value Added by Select ORSA Activity (thousands of dollars)

For the Nevada 2020 BEA analysis, see Appendix B. BEA Nevada 2020.

7 BEA – Nevada 2020

SCORP 2022- 2026 | Part 1: Introduction

Lake Mead

BACKGROUND, PURPOSE, AND LEGAL AUTHORITY The Land and Water Conservation Fund (LWCF) Stateside Assistance Program was established by the LWCF Act of 1965 to stimulate a nationwide program to assist in preserving, developing, and assuring accessibility to outdoor recreation resources, and to strengthen the health and vitality of U.S. citizens. The program provides matching grants to states and through states to local units of government for the acquisition and development of public outdoor recreation sites and facilities. •

Address the demand for, and supply of, public outdoor recreation resources (local, state, federal, and tribal)

•

Meet state and locally identified public outdoor recreation resource needs to strengthen the health and vitality of the American people

Identify capital investment priorities for acquiring, developing, and protecting all types of outdoor recreation resources

•

Increase the number of protected state and local outdoor recreation resources, and ensure their availability for public use in perpetuity

Assure continuing opportunity for local units of government and private citizens to take part in planning for statewide outdoor recreation

•

Coordinate all outdoor recreation programs throughout the state

The income for the entire LWCF ($900 million per year) is provided largely from Outer Continental Shelf mineral receipts.8 No taxpayer dollars are distributed through this process.9 Reflecting the goals of the LWCF Act, the goals of the LWCF Stateside Assistance Program are to:

•

Encourage sound planning and long-term partnerships to expand the quantity, and ensure the quality of needed state and local outdoor recreation resources

To be eligible for LWCF assistance for acquisition and development grants, each state must prepare and update, every five years, a SCORP to:

Each state shall develop an Open Project Selection Process (OPSP) that provides objective criteria and standards for grant selection that are, in part, explicitly based on each state’s priority needs for the acquisition and development of outdoor recreation resources as identified in the SCORP. The OPSP is the connection between the SCORP and the use of LWCF grants to assist state efforts in meeting high priority outdoor recreation resource needs.

8 Land and Water Conservation Fund, Stateside Assistance Program, Federal Financial Assistance Manual, Volume 71, Effective March 11, 2021 9 https://www.nps.gov/subjects/lwcf/congressionalacts.htm

SCORP 2022- 2026 | Part 1: Introduction

Carson Ridge Disc Golf Course

The LWCF Act authorizes the Secretary of the Interior to provide financial assistance to states for outdoor recreation purposes. To be eligible for assistance under the LWCF Act, the governor of each state shall designate a State Liaison Officer (SLO) and one or more Alternate State Liaison Officers (ASLO) who have authority to accept and administer funds for purposes of the LWCF Program. In Nevada, the LWCF program is administered by NDSP. The SLO is the NDSP Administrator and the ASLO’s are the Deputy Administrator and Park and Recreation Program Manager. LWCF monies are apportioned to the states by the Secretary of the Interior each fiscal year. LWCF assistance may be available to:

•

Acquire lands and waters or interests in lands and water for public outdoor recreation

•

Develop outdoor recreation facilities to serve the general public

To be eligible for assistance, projects must be in accordance with the SCORP, be sponsored by a governmental agency, and meet other state and federal requirements. Eligible entities include local units of government and native American tribal governments. LWCF assistance is provided on a matching basis, up to 50%, to individual projects that are submitted through the SLO to the NPS for approval. The 2022-2026 SCORP will help guide investment in and planning for outdoor recreation projects in Nevada by providing funding to eligible entities to acquire lands and waters, as well as to develop and improve outdoor recreation infrastructure. See Appendix C for a more detailed overview and explanation of the legal authority of LWCF. Over the past 20 years, NDSP has granted over $19 million in federal funding for outdoor recreation through the LWCF program.

SCORP 2022- 2026 | Part 1: Introduction

WETLANDS PRIORITY

Wetlands are defined by the U.S. Fish and Wildlife Service (USFWS) as lands transitional between terrestrial and aquatic systems where the water table is usually at or near the surface or the land is covered by shallow water. As required by 54 U.S.C. § 200305(d)(4), each SCORP must contain or reference a wetlands priority component consistent with Section 303 of the Emergency Wetlands Resources Act of 1986. At a minimum, the wetlands priority component must:

•

Be consistent with the National Wetlands Priority Conservation Plan prepared by the USFWS

•

Provide evidence of consultation with the state agency responsible for fish and wildlife resources

•

Contain a listing of those wetland types which should receive priority for acquisition

•

Consider outdoor recreation opportunities associated with its wetlands resources for meeting the State’s public outdoor recreation needs

In 2007, Nevada prepared the Priority Wetlands Inventory (Appendix E) which identified 234 vulnerable wetland areas highly valued for their wildlife habitat functions as well as their capacity to convey, store, and cleanse water; to control erosion and floods; and to provide immeasurable socioeconomic benefits, most notably a wide variety of outdoor recreation activities. Each priority wetland area in the inventory possesses some combination of wildlife, ecological, and socioeconomic characteristics and some combination of threats and deteriorating ecosystem health which, in aggregate, indicate elevated conservation importance and need. The Wetlands Priority remains a critical component of conservation and recreation planning in Nevada. Given the predominance of arid environments within the state, Nevada cannot withstand unmitigated wetland losses and achieve objectives to maintain and enhance our wildlife, plant, water, and outdoor recreation resources. The priorities and strategies contained in both documents remain current and have been considered in the development of this SCORP and the OPSP. The Nevada Division of Natural Heritage will complete an updated wetlands inventory and plan by September 2022.

Stillwater National Wildlife Refuge

Wetlands provide values that no other ecosystem can. They serve as nurseries for fish, feeding and nesting grounds for birds, and critical habitat for many animals and plants that can only live in wetlands. In fact, more than one-third of the United States’ threatened and endangered species live only in wetlands, and nearly half use wetlands at some point in their lives.10 Wetlands also provide natural water quality improvement, flood protection, shoreline erosion control, and opportunities for recreation and aesthetic appreciation. The importance of wetland protection cannot be overstated. Although conservation efforts since the 1950s have reduced the substantial loss of this diminishing resource, we remain on an alarming downward trend and must prioritize this resource to protect our entire ecosystem.

In 2006, the Nevada Wetlands Priority Conservation Plan, Technical Review Draft (Appendix D) was completed, which contained an assessment of the conservation status of wetlands in Nevada, the state’s list of priority (vulnerable and valuable) wetlands, and strategies that state agencies can employ to conserve priority wetlands. 10 United States Environmental Protection Agency

SCORP 2022- 2026 | Part 1: Introduction

Fort Churchill State Historic Park

OUTDOOR RECREATION AGENCIES AND PROGRAMS

NDSP plays the lead role in planning and implementing the SCORP. Achieving the SCORP’s broad goals, however, requires the collaboration of numerous other state agencies and programs in Nevada that work to help support the SCORP’s implementation. Some of the stakeholder agencies and programs include:

Nevada Department of Conservation and Natural Resources The Nevada Department of Conservation and Natural Resources (NDCNR) is a broad and multifaceted department consisting of eight divisions and three standalone programs committed to:

•

Protecting Nevada’s natural, cultural, and recreational resources

•

Leading efforts to address impacts of climate change throughout Nevada

•

Preserving Nevada’s unique historic and cultural heritage

•

Enhancing Nevada’s outdoor recreation, quality of life, environmental stewardship, and recreation economy

Fostering partnerships to advance innovative solutions and strategies to protect natural resources for the benefit of all Nevadans

SCORP 2022- 2026 | Part 1: Introduction

Nevada Division of Outdoor Recreation In January 2020, the Nevada Division of Outdoor Recreation (NDOR) was established to promote Nevada’s outstanding outdoor recreation opportunities, advocate for the conservation of its natural environment, grow Nevada’s economy through outdoor recreation, and educate the public about responsible recreation and healthy and active lives enriched by the outdoors.11 NDOR is committed to:

•

Enhancing and stewarding Nevada’s one-of-a-kind outdoor recreation opportunities

•

Promoting a healthy and sustainable outdoor recreation economy centered on protecting and conserving Nevada’s natural and cultural resources

•

Attracting existing outdoor recreation-oriented businesses to the state and supporting the creation of new outdoor recreation-oriented businesses in the state

•

Advancing understanding of Nevada’s unique variety of outdoor recreational opportunities as central to improving public health and wellness

•

Educating and engaging Nevada’s youth in outdoor recreation activities

•

Engaging underserved populations, ensuring all Nevadans have equitable access to outdoor recreation

Recreational Trails Program The Recreational Trails Program (RTP) is a grant program administered by the Federal Highway Administration at the federal level, passed through to the Nevada Department of Transportation (NDOT), and administered by NDSP for the state of Nevada. RTP was created by the Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA). Most recently, the RTP was reauthorized as part of the Fixing America’s Surface Transportation (FAST) Act. It was signed by President Obama on December 4, 2015 and covered Fiscal Years 2016-2020. RTP applies the “user-pay/user-benefit” philosophy of the Highway Trust Fund, returning federal tax on fuel used for nonhighway recreation to the states for trail projects. Although the gas tax supporting the fund is paid primarily by gas-using vehicles, resources are shared with other users of recreational trails to develop a balanced system.

Project categories eligible for funding are varied, giving states flexibility to administer state trail programs. State administrative and educational program costs are capped at 7% and 5% respectively. States are also encouraged to work with qualified youth conservation or service corps.

11 http://dcnr.nv.gov/divisions-boards/ndor

SCORP 2022- 2026 | Part 1: Introduction

Eligible projects include:

• •

Maintenance and restoration of existing recreational trails Development and rehabilitation of trailside and trailhead facilities and trail linkages for recreational trails

•

Purchase and lease of recreational trail construction and maintenance equipment

•

Construction of new recreational trails (with specific requirements when federal land is involved)

•

Trail project planning and clearance activities

•

Environmental education and trail building programs

•

Acquisitions of lands and waters by fee simple title or permanent recreational use easements

•

Assessment of trail conditions

Lincoln Bypass Trail

Nevada has received over $33 million in RTP funds since 1993

Nevada Department of Wildlife The Nevada Department of Wildlife (NDOW) is the state agency responsible for the restoration and management of fish and wildlife resources and the promotion of boating safety on Nevada’s waters. Protecting and managing Nevada’s wildlife is at the core of NDOW’s purpose and mission.

SCORP 2022- 2026 | Part 1: Introduction

Prison Hill Recreation Area

2016-2021 SCORP: OUR ACCOMPLISHMENTS Successful implementation of a SCORP is a comprehensive effort that requires dedication from not only the state agencies responsible for developing and adopting the planning document, but also partnering land management agencies and nonprofit organizations at the local, regional, and statewide levels.

The following section outlines the outdoor recreation priorities that were the focus of the previous SCORP and highlights some of the accomplishments that were achieved from 2016-2021. Also, below are excerpts from the Land Manager Survey detailing areas of significant progress over the past five years, followed by a list of LWCF-assisted outdoor recreation projects that were selected for funding due to their close alignment with the 2016-2021 SCORP priorities. Following the project list, three exceptional LWCF projects completed in recent years are showcased.

SCORP 2022- 2026 | Part 1: Introduction

There were eight priorities set out in the 2016 SCORP: Maintain and rehabilitate existing facilities Increase connectivity between trails, facilities, and other recreation locations Ensure safety Develop new facilities Conserve water and habitat Engage youth Integrate with economic security and growth Meet the needs of under-served regions and populations

Significant Progress - In Their Words The 2021 SCORP Land Manager Survey asked respondents to provide highlights of significant progress made over the past five years to improve outdoor recreation opportunities. Below, and throughout this section, we provide a sampling of land manager highlights of significant progress. Federal Land Manager Respondents Cited: Increased and leveraged partnerships Finalized several travel management plans Increased level of programming to underrepresented communities Improved visitor center Expanded opportunities for hunting and fishing on National Wildlife Refuges

“Our greatest progress has been to partner with other federal, state, and local agencies to work towards common goals and pool limited resources.”

— Federal Land Manager

Built multipurpose trails and improved ADA walking trail stability Upgraded campgrounds and facilities Implemented a reservation system Initiated three large-scale non-motorized trail projects in the last five years

State Land Manager Respondents Cited: Stayed open through budget cuts and COVID Different types of interpretive programs to cater to new visitor demographics New parks More trails in our parks, trail projects completed Installed power to many parks Campground upgrades and road improvements Constructed new cabins, improved campground by providing power/water hook-ups to many more locations

County Respondents Cited: Worked with Truckee Meadows Regional Planning Agency (TMRPA) on regional trail map/plan Enhanced trail connectivity to federal lands Reduced wildfire risk on open space parcels adjacent to housing subdivisions Planted native plants in previous fire scars to promote native vegetation and discourage noxious weeds

City Respondents Cited: Leveraged sales tax initiative funds with grants Grant-funded trail and trailhead projects Added parking and trailhead infrastructure Multiple new parks Adopted both a parks and open space master plan, and a public arts plan

The full results of the land manager survey are included in Appendix F: Land Manager Survey Summary Data. All land manager responses to “Significant Progress” and additional quotes/comments are provided in Appendix G. SCORP 2022- 2026 | Part 1: Introduction

Projects Funded by LWCF Since 2016, a total of $9,155,567 in LWCF funding has been awarded across the state of Nevada, with over $14 million in match. Below is a chart displaying the investments and match since 2016.

LWCF Funded Outdoor Recreation in Nevada 2016-2020

SCORP Priority

Award Amount

Match

2016 Jaycee Inclusive Playground

D, F, H

$99,984

$99,184

Bird Viewing Preserve Signage and Dock

B, C, E, F

$17,200

$39,781

Valley of Fire State Park, White Domes Trailhead Restrooms and Parking Expansion

A, G

$100,000

$313,500

State Parks Interpretive Displays and Videos

D, F, G, H

$30,675

Miguel Ribera Skatepark

D, F, H

$225,390

$350,000

Ross Gold Playground

A, C, F, H

$262,157

$261,657

Carson Ridge Disc Golf Course Complex

D, F, G, H

$118,785

$118,285

Kellogg Park Phase 1

D, F, H

$211,519

$833,481

Walker River Restrooms

D, G

$463,750

Pitchfork Ranch Development

D, G

$2,650,753

$3,413,669

Ice Age Fossils State Park Visitor Center

D, G, H

$2,394,914

Simkins Park Phase III Lighting

D, F, G, H

$277,320

Robert Spellberg Recreation Complex Enhancement

D, F, G

$42,500

Hamm Property Acquisition

B, D, E

$250,000

Somersett West Park

D, F

$200,000

$850,000

Lions Park Pool

A, F, G, H

$34,312

Echo Canyon Campground Rehab

A, G

$290,125

Spooner Lake Frontcountry Improvements

D, G

$593,533

$3,363,356

SCORP Planning

N/A

$150,600

Ice Age Fossils State Park - Phase 2a

D, F, G, H

$742,050

$9,155,567

$14,319,159

2017

2018

2019

2020

Totals

A. B. C. D. E.

Maintain/rehabilitate existing facilities Increase connectivity Ensure safety Develop new facilities Conserve water and habitat

SCORP 2022- 2026 | Part 1: Introduction

F. Engage youth G. Integrate with economic security and growth H. Meet underserved needs

Red Rock Canyon National Conservation Area

PROJECT HIGHLIGHTS

•

Somersett West Park

•

Jaycee Inclusive Playground

•

Walker River State Recreation Area

Several projects completed during the 20162021 SCORP exemplified the intent of the LWCF program, assuring that natural areas, water resources, and recreation opportunities are protected and available for public enjoyment.

SCORP 2022- 2026 | Part 1: Introduction

Somersett West Park Located in northwest Reno, Somersett West Park was a successful partnership between the City of Reno, the Somersett Owners Association (SOA), the Truckee Meadows Parks Foundation and Toll Brothers, a residential developer for Somersett. This project consisted of the construction of a new 5.6-acre neighborhood park that includes a children’s playground, restroom, picnic shelter, pathways, open turf area, 50 community garden plots with 10 raised beds for accessibility, separate off-leash areas for small and large dogs, park furnishings, and landscaping.

The park provided a new outdoor recreation facility in a neighborhood of 3,900 homes.

The City of Reno and SOA partnered on the design and development of the site. The Truckee Meadows Parks Foundation, a local 501c(3) organization, collaborated with SOA on an online fundraising campaign to raise additional funds to support the development of the park. Toll Brothers donated two acres of property to the City to expand the park and assisted with the community garden, off-leash dog parks, construction of the driveway entrance, and parking. All were provided as match for the project. The resulting park and interior pathways increased connectivity to Somersett’s internal trail network, a series of paved trails within the development totaling over 11 miles. Additionally, the park provided a new outdoor recreation facility in a neighborhood of 3,900 homes, which previously was approximately 2.5 miles from the nearest park.

SCORP 2022- 2026 | Part 1: Introduction

Jaycee Inclusive Playground Prior to construction of the Jaycee Inclusive Playground, the City of Las Vegas had no centrally located inclusive playgrounds that were open to the public. The only playgrounds with accessible equipment for children with disabilities were in affluent areas of the city where access was limited. The Southeast Sector of Las Vegas, which includes the 18-acre Jaycee Community Park, contains some of the oldest neighborhoods and parks in the city. With approximately 35% of the city’s overall population, this sector is largely underserved in terms of park acreage with a level of service well below the city standard. The Southeast Sector’s current level of service is 1.36 acres of park land per 1,000 residents, the most park acreage-deficient sector compared to other parts of the city. There are four schools that primarily serve children with disabilities (ages 3 to 22 years of age) within a 2-mile radius of the park. This project created an inclusive playground in the most underserved sector of Las Vegas. The park offers recreational opportunities for individuals of all ages and abilities to increase mobility, provide recreational opportunities for children with disabilities, and allow interaction with peers and family while fostering friendship in a safe environment. The City of Las Vegas partnered with Variety Children’s Charity of Southern Nevada to match the LWCF funds 1:1. The project included an integrating carousel, G-flex playground surfacing, a Mega Tower, and a permanent shade structure to extend the season during which the playground can be used.

SCORP 2022- 2026 | Part 1: Introduction

This project created an inclusive playground in the most underserved sector of Las Vegas.

Walker River State Recreation Area Pitchfork Ranch Development

The Walker River State Recreation Area was conveyed to Nevada in 2017 by the Walker Basin Conservancy and dedicated by Governor Brian Sandoval in 2018. The property had been under private ownership for over 125 years and was not previously accessible to the public. With over 12,000 acres, 29 miles of the Walker River and four historic ranches, the property was ideal for developing into a state park. Upon completion of the transfer, NDSP was tasked with first developing the Pitchfork Ranch for public outdoor recreation use with only two years to plan, design and construct the project.

With the assistance of approximately $2.3 million of LWCF, NDSP was able to construct a full hook-up campground with 20 sites, a primitive campground, four cabins, restrooms, picnic areas with shelters, a kiosk, and an interpretive trail. Since opening, over 200,000 visitors have taken advantage of new outdoor recreation opportunities at the park to include camping, fishing, open float water recreation, mountain biking, hiking, and wildlife viewing.

Since opening, over 200,000 visitors have taken advantage of new outdoor recreation opportunities at the park.

SCORP 2022- 2026 | Part 1: Introduction

Walker River State Recreation Area

2022-2026 SCORP: OUR PLANNING PROCESS The planning process for the 2022 SCORP began in October 2020 with three primary groups providing initial and ongoing guidance and oversight: The SCORP Core Team was established to drive the process for the development of the SCORP by providing guidance and operational support. This team was made up of the NDSP Planning Program Manager, the Nevada LWCF ASLOs, and the NDOR Administrator. A consulting group, The Blueprint Collaborative (TBC), was engaged by NDSP to facilitate and carry out the SCORP planning process and lead the development of the SCORP document. The SCORP Advisory Team was established and made up of key stakeholders from varying levels of state government, land management agencies, and outdoor recreation constituencies with geographic and demographic diversity from across the state. Key to the development of the SCORP were three surveys and the first iteration of a Nevada Outdoor Recreation Asset Inventory. There were 6,807 public surveys (Outdoor Recreation Public Survey: Part 1 and Public Survey: Part 2 – How and Where You Recreate) submitted in 2021, which provided key responses regarding outdoor recreation participation, preferences, priorities, and barriers. This essential data provided the findings and informed the analysis that shaped the goals, strategic objectives, recommendations, and implementation plan defined in this document. In addition to the public surveys, the findings of 139 land manager survey responses have been incorporated into the analysis and resulting implementation plan. Further, the results of an unprecedented Nevada Outdoor Recreation Asset SCORP 2022- 2026 | Part 1: Introduction

Inventory captured asset and site details of 844 outdoor recreation facilities and sites managed at federal, state, tribal, county, and local levels.

The SCORP planning process was divided into three categories of work: •

February 2021 – July 2021 | Discovery: data collection and initial engagement

•

June 2021 – November 2021 | Data analysis and further engagement with focus groups

•

September 2021 – May 2022 | Report draft, external solicitation for feedback, final report

Data Collection Tool/Method

Outdoor Recreation Public Survey: Part 1 Public Survey: Part 2 – How and Where You Recreate

Intended Audience

Timeframe

# Responses Survey or Completion Participants Rate

Statewide public outreach

Feb – Jul 2021

6,086

92%

Apr – Jul 2021

720

95%

Mar – Sep 2021

139

55%

Apr – Sep 2021

844

N/A

Emailed survey to 1,479 participants from Public Survey Part 1 who agreed to provide additional information Federal, state, city, county, tribal, private,

Land Manager Survey

land trust, general improvement district land managers

Outdoor Recreation Asset Inventory

Focus groups/small group meetings

Federal, state, city, county, tribal, private, land trust, general improvement district land managers SCORP Advisory Team

Advisory Council for Outdoor Recreation

Federal/state land managers

Jun - Nov 2021

N/A

City/county managers/Parks and Recreation directors, Travel and Tourism representatives

Public (survey posted in English & Spanish on NDSP website, posted on SCORP Draft Review & Feedback

901 unique

social media)

views Jan – Mar 2022

100%

SCORP survey respondents (email

74 feedback

addresses for 1,479) and all SCORP

surveys

small group participants

For each of the three surveys and the asset inventory, beta tests were conducted by targeted users to solicit feedback and ensure usability before the actual surveys and inventory were officially launched. To encourage maximum participation in the public surveys, NDSP and NDOR enlisted the assistance of the public information officers at NDCNR, as well as the Office of Governor Steve Sisolak, and Travel Nevada, among others. A social media campaign was launched on Facebook, Twitter, and Instagram that included links to the public survey in both Spanish and English.

For a list of additional people, organizations, agencies, and both formal and informal networks that were solicited to assist in the distribution of the public survey, see Appendix H: 2021 SCORP Stakeholder Engagement and Targeted Outreach.

SCORP 2022- 2026 | Part 1: Introduction

Once the survey period closed, TBC conducted the initial data compilation and analysis. Summary data was then shared across a variety of smaller groups of stakeholders for input (see chart above for groups engaged).

Sand Mountain Recreation Area

Through the discovery and analysis process, themes and goals emerged, which the SCORP Core Team used to draft strategic objectives and recommended tactics to address the goals and barriers that had been identified in the process. This initial content was presented to several small groups in focus group settings, including land managers, county/city planners and managers, travel and tourism representatives, etc.

Summary This SCORP brings together the wants and needs of Nevada’s outdoor recreation users and providers into a single, comprehensive document. The following pages carry out the objectives established for this plan, which were to:

•

Establish outdoor recreation goals, objectives, and recommendations

•

Set evaluation criteria to allocate LWCF dollars

•

Protect, conserve, and provide direction for managing public lands, recreation spaces, and unique places for current and future generations

•

Encourage a highly integrated and connected outdoor recreation system

SCORP 2022- 2026 | Part 1: Introduction

•

Provide information to ensure a diverse and growing population has access to outdoor recreation spaces and opportunities to enjoy a range of recreation activities

•

Communicate the connections between sustainable outdoor recreation, individual health and wellness benefits, community health and vitality, and a thriving economy

•

Elevate public participation and engagement in outdoor recreation planning initiatives and issues 24

Washoe Lake State Park

Part Two

OUTDOOR RECREATION IN NEVADA: RESEARCH AND FINDINGS

In this section: Outdoor Recreation Supply in Nevada 2021 Nevada Outdoor Recreation Asset Inventory Summary Outdoor Recreation Demand in Nevada Outdoor Recreation Public Survey Results Land Manager Survey Results

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Ely Success Loop

OUTDOOR RECREATION SUPPLY IN NEVADA Over 85 percent of land in Nevada is managed for public use – which, with limited exceptions, includes recreational opportunities. Nevada contains more federal acreage than any other state in the continental U.S. This massive resource is at the core of the Silver State’s “supply” of outdoor recreation opportunities. Our outdoor recreation opportunities are managed by federal, state, county, city/municipal and tribal jurisdictions. Below is of a sampling of opportunities enjoyed across Nevada annually by tens of millions of Nevadans and visitors alike. To determine the amount and types of outdoor recreation infrastructure that we need, we must know what we have, along with what consumers want. It’s a simple supply and demand exercise, and in this case, one done specifically for outdoor recreation. Over the course of six months, NDSP and NDOR collected data regarding supply, demand, current use, and desired use of outdoor recreation.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

The results represent a wealth of information which will be used by land managers to assess the gaps, and implement actions to fund and develop outdoor recreation infrastructure. This information will not only assist with closing the gaps but will ultimately contribute to the overall economic health and diversity in Nevada communities by informing the development of additional outdoor recreation opportunities, one of our state’s fastestgrowing economic generators.

Humboldt Elko

Pershing Lander

Washoe Churchill

Storey Carson City Douglas

Eureka White Pine

Lyon

Mineral

Esmeralda

Nye

Lincoln

Clark National Conservation Area National Monument National Wildlife Refuges Tribal Lands US Forest Service (USFS) Nevada State Parks

100 Miles

National Park Service (NPS) Bureau of Land Management (BLM) Private or Restricted Lands

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Public and Tribal Lands in Nevada

Death Valley National Park

Recreation Supply Managed by Federal Agencies

Gold Butte National Monument

National Park Service Units NPS manages two parks in the state: Great Basin National Park and Death Valley National Park. NPS also manages the Lake Mead National Recreation Area in south-eastern Nevada, which is the first and oldest National Recreation Area in the U.S. It is also one of the NPS’s most visited sites, ranking amongst the top ten most visited park units in the country.12

National Conservation Lands and National Monuments BLM manages several unique areas popular with outdoor recreationists, including the Red Rock Canyon National Conservation Area, a landscape notable for its scenic motoring loop, red rock formations, and deep canyon wildernesses, and renowned by rock climbers, hikers, sightseers, and other outdoor enthusiasts. The BLM also manages the Black Rock Desert – High Rock Canyon Emigrant Trails National Conservation Area, an area of almost a million acres that offers visitors access to hot springs, rugged canyons, and large salt flats or “playas”.

12 Nevada’s Outdoor Recreation Economy and COVID-19 (etc.) page II-1.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Heavenly Ski Resort

National Forests There are three national forests in Nevada managed by the U.S. Forest Service (USFS). The Humboldt-Toiyabe National Forest is a 6.3 million-acre forest that is the largest national forest in the lower 48 states. Besides being home to the Mt. Rose Ski Tahoe, Lee Canyon ski Resort, and the Spring Mountains National Recreation Area, which includes Mount Charleston, the Humboldt-Toiyabe is also notable for being a non-contiguous national forest, with areas in western, northern, and eastern Nevada, and a small portion of the eastern Sierra in California. The Lake Tahoe Basin Management Unit manages the forest lands inside the Lake Tahoe Basin, including those on the Nevada side of the lake, and includes Heavenly Ski Resort. A portion of the Inyo National Forest, which includes the Boundary Peak Wilderness and Nevada’s highest point, is also located in the western part of the state.

Desert National Wildlife Refuge

National Wildlife Refuges USFWS manages multiple wildlife refuges throughout the state. The Sheldon National Wildlife Refuge, located in the Great Basin, is the second largest in the state. Ruby Lake National Wildlife Refuge, also located in the Great Basin, is a large area of spring-fed wetlands that supports an abundance of wildlife habitat for birds and mammals. The Stillwater National Wildlife Refuge, near Reno, is regarded as a premier destination for birders due to its importance for migratory bird species. The largest refuge in the state, the Desert National Wildlife Refuge, is also the largest refuge in the lower 48 states. Covering an area larger than Rhode Island, the 1.6 million-acre refuge was created to conserve habitat for multiple species, some of which are found nowhere else on earth.

Federally Recognized Tribal Nations While all land in Nevada is part of the ancestry of the original indigenous nations who inhabited the area before European settlers arrived, today there are 32 federally recognized tribal lands that cover 1,098,360 acres across the state. Some tribal lands offer outdoor recreation. For example, Pyramid Lake, which covers an area of 125,000 acres and is one of Nevada’s largest natural lakes, is managed by the Pyramid Lake Paiute Tribe and offers visitors a number of recreation opportunities, including world class fishing. The Walker River Paiute Tribe offers public access to the Walker River, which hosts numerous fisheries and offers visitors abundant recreation opportunities.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Valley of Fire State Park

Recreation Supply Managed by State, County, and Local Agencies The state of Nevada, along with county and municipal governments, also manage hundreds of sites with recreational amenities throughout the state. NDSP manages and maintains 27 parks, recreation areas, and historic parks throughout the state, including the Berlin-Ichthyosaur State Park in northern Nevada. This park showcases Nevada’s mining heritage and paleontological history by allowing visitors to explore the ghost town of Berlin and nearby fossil beds. Valley of Fire State Park, a unique area of bright red sandstone outcrops, petrified trees, and petroglyphs, offers visitors opportunities to explore its sites through day trips, camping, hiking, and picnicking. Sand Harbor State Park is located along the east shore of Lake Tahoe, and offers visitors opportunities for swimming, kayaking, fishing, water skiing, and picnicking. County and municipal governments throughout the state also maintain regional and local parks to provide recreational opportunities for their residents.13

13 Nevada’s Outdoor Recreation Economy and COVID-19 (etc.) pages II-2-4.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Great Basin National Park

2021 NEVADA OUTDOOR RECREATION ASSET INVENTORY SUMMARY Conducting the 2021 Nevada Outdoor Recreation Asset Inventory has been an essential part of determining outdoor recreation supply. The objectives for the inventory were to: •

•

Gather the most current information about outdoor recreation facilities across the state from the land managers closest to each facility/site to establish a record of supply Compile the data into a single Nevada outdoor recreation database, combining facility/site asset information from federal, state, county, local, and tribal outdoor recreation land managers

•

Identify gaps between the supply and demand in outdoor recreation in Nevada

•

Determine the priorities for the next five years for articulation into the SCORP

•

Provide public access to the most up-to-date information about places to recreate in Nevada and what amenities are available at each site (types of trails, accessibility, restrooms, parking, potable water, etc.)

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

The submission rate of asset inventories has been exceptional, and an encouraging foundation for a comprehensive, statewide Outdoor Recreation Asset Inventory. In 2021, the SCORP discovery process generated 844 inventories from multiple entities. The BLM submitted 134 sites, the USFWS submitted 4 sites, and the USFS submitted 138 sites. Nevada state agencies submitted 27 state park, recreation area and historic park inventories while county and city/municipal governments added an additional 541 outdoor recreation assets.

While the full results of the 2021 Nevada Outdoor Recreation System Asset Inventory are available in Appendix I, the data below highlights some of Nevada’s outdoor recreation assets.

4,059 83 1,075 408 4,185

Miles of Trails

Beaches

Toilets

Playgrounds

Campsites

20%

Type of Facility Park

Open Space

Recreation Area

Conservation Area

Trail System

Other

47%

9% 7%

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Liberty Lake

OUTDOOR RECREATION DEMAND IN NEVADA Demand for outdoor recreation opportunities in Nevada is increasing as the state’s population and visitation grows. One outcome is that outdoor recreation’s contribution to Nevada’s overall economy is growing, due in part to the rich array of outdoor experiences available to residents and visitors alike. Nevada’s outdoor recreation opportunities are frequently mentioned as important quality-of-life indicators for residents, and the state’s diverse geography and natural environments beckon visitors with the possibilities of exploration, adventure, and fun. As the population grows and more people visit the Silver State, however, it is essential to proactively plan for sustainable outdoor recreation in Nevada, to ensure the natural beauty and diverse environments that make Nevada unique are stewarded for future generations. Visitation to the State The Nevada Division of Tourism records data on outof-state and national park visitation for the State of Nevada. Travel and tourism are particularly important for the outdoor recreation economy since many jobs in the industry depend on visitor revenue from accommodations, food services, and retail trade. Arts, entertainment, recreation, transportation, and local governments also rely on visitor spending, but these industries can offset reductions in visitor spending by capturing local expenditures. In 2018, the Nevada Division of Tourism reported more than 56.5 million visits to the state. The Division conducted a survey of visitors to better understand their travel habits and primary purposes of travel which found that the average length of trip for out-of-state visitors was four days. The survey also asked visitors about the primary attractions and experiences during their trip.

While many visitors come to Nevada for gaming, dining, and live performances, the state’s public lands and natural amenities are also important draws for visitors. Survey results show that outdoor amenities and public lands play an important role in visitors’ experiences. Between 5.6 million and 12.9 million (10 to 23 percent) of visitors participate in scenic driving, while 7.3 million to 8.5 million (13 to 15 percent) visit a lake or reservoir during their trip. The state’s mountains are also an important part of visitor’s experiences, with 7.3 million to 11.3 million (13 to 20 percent) survey respondents stating that mountains were one of the top experiences during their stay. Additionally, 4.5 to 7.3 million (8 to 13 percent) visitors to the Reno and Las Vegas areas said that visiting parks and recreation areas was a top experience, while 3.4 million to 5.1 million (6 to 9 percent) of respondents said outdoor recreation was their top experience.14 14 Nevada’s Outdoor Recreation Economy and COVID-19 (etc.) pages II-4-5.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

NDSP experienced a 34% increase in visitation to state parks, recreation areas, and historic parks from December 2019 to December 2020. This increase was realized differently across the geographic regions of the state. For example, the Eastern Region (South Fork, Spring Valley, Wildhorse, Echo Canyon, etc.) saw an amazing 207% increase from December 2019 to December 2020, and the Northern Region (Washoe Lake, Rye Patch, Lahontan, etc.) saw a 217% increase. The Southern Region (Big Bend, Valley of Fire, etc.) saw a 34% decrease during the same period, due in part to a combination of closures and reduced tourism travel to Nevada.15

Ward Charcoal Ovens State Historic Park

Demand During the COVID-19 Pandemic Overall demand for outdoor recreation increased across all jurisdictions in the state during the pandemic.

In Nevada, the rebound in visitation to some areas was so extreme that access had to be limited to reduce crowding. Red Rock National Conservation Area, outside of Las Vegas, closed several times during 2020 to reduce crowding along its scenic loop drive and hiking trails and now requires reservations to access its scenic loop drive (Red Rock Canyon, 2020). The Lake Mead National Recreation Area also saw unprecedented increases in demand for access once public health and safety restrictions were eased (Boulder City Review, 2020).16

Camping in Nevada increased by 40% during COVID-19.17

These examples highlight the demand for outdoor recreation access and why greater coordination and increased infrastructure is needed. Demand for outdoor recreation is unlikely to return to pre-pandemic levels. 15 Nevada Division of State Parks, Summary of Visitation, Calendar Year January 2010 through December 2019 (with 2020 data added). 16 Nevada’s Outdoor Recreation Economy and COVID-19 (etc.) pages III-1-2. 17 Dcnr.nv.gov/blogs/Nevada_a_state-of-happy-campers, June 4, 2021.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

“The COVID-19 pandemic created a confusing paradox for Nevada’s outdoor industry. While people appeared to be spending more time outside during lockdown, the state’s outdoor industry took a substantial hit during the pandemic, according to a recently released report from the Nevada Outdoor Business Coalition. That’s because far fewer people traveled to and around Nevada, and those who did spent a lot less money while doing it. In 2020, April saw less than half a million visitors to the state, compared to nearly 5 million people during April of 2019 – a 92% decrease.” — Amy Alonzo, Reno Gazette-Journal, March 3, 2021

The SCORP public survey responses provided additional insight about outdoor activity during the pandemic. When asked if respondent’s or their family’s outdoor recreation activity level increased or decreased as a result of the COVID-19 pandemic, 40% of all respondents indicated an increase during the pandemic. See the chart for activity levels during COVID-19 by survey respondent type: all respondents versus those who identify as participating in outdoor recreation less than 3 hours/week, which we refer to as “lighter users”. There was a greater decrease in participation in outdoor activities for lighter users (37% as compared to 23% for all respondents). Since all SCORP public survey data was collected during the pandemic, no doubt the responses are influenced by this unprecedented event. Many survey respondents commented that their answers to many of the survey questions would have been different in a non-pandemic year.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Outdoor Recreation Activity Levels During COVID-19 40 35 30 25 20 15 10 5 0

Increase

Decreased

All Respondents

Same Lighter Users

OUTDOOR RECREATION PUBLIC SURVEY RESULTS To gauge the public’s usage, barriers, priorities and preferences for various types of outdoor recreation, the Outdoor Recreation Public Survey was launched online in February 2021. In total, 6,086 individuals responded to the survey with a 92% completion rate (those who completed 100% of the questions). The initial public survey contained 42 questions divided into six categories: •

Participation in outdoor recreation (13 questions)

•

Priorities for outdoor recreation (7 questions)

•

Geographic information of respondent (5 questions)

•

Demographic information of respondent (9 questions)

•

Barriers to participation in outdoor recreation (5 questions)

•

Comments and additional information (3 questions)

Analysis The 6,086 initial public survey responses have been aggregated as “All Respondents”. Answers to survey questions are summarized as percentages, reporting responses to each question by the percentage of answers to multiple-choice options. No questions were required on the public survey, therefore, the total number of responses for each question varied, particularly in the latter sections of the survey (questions 26 - 40).

Complete survey results can be found in Appendix J. A spreadsheet with all public survey comments can be found in Appendix K.

Who took the public survey? The typical SCORP survey respondent self-identified as:

53% 87%

Moderately active.

Predominately white.

82% Lives in one of Nevada’s urban counties.

72%

70% 64%

Graduated from college.

59%

Over 45 years old.

47% Has resided in Nevada for more than 21 years.

52% Has an annual household income less than $100,000.

55%

Does not have chronic health issues.

Does not have children under 18.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Engages in outdoor recreation more than once a week, and of that 70%, almost one third cite recreating outdoors as much as once a day.

Accessible Cross-Country Skiing, Lake Tahoe

Due to the nature of convenience sampling, where survey respondents are drawn from the population close at hand (in this case, those most likely to have a connection to or are interested in outdoor recreation), the Nevada Advisory Board on Outdoor Recreation and the SCORP Core Team raised a question regarding the majority (79%) of public survey respondents who indicated they were moderate to heavy outdoor recreation users or enthusiasts (those who recreate outdoors 3+ hours per week).

How could we analyze the data that might be more representative of the general population of Nevada?

To address this concern, analysis was conducted to better examine the responses of “lighter users”, which represent the 21% of survey respondents who participate in outdoor recreation anywhere from zero minutes to 3 hours per week. The lighter user respondents (n=1,256) are included in all the aggregate results as well. Analysis of data for the lighter users as compared to all respondents revealed that in 18 of 25 questions regarding activities, barriers, and priorities, the rankings remained consistent even when the percentages varied slightly inside the rankings. Meaning, the first, second, and third choices or priorities were consistent across both groups even if the percentages were not equal. There are notable response differences to seven questions between all respondents and the lighter users. These differences are called out in the narrative and/or charts.

In 18 of 25 questions regarding activities, barriers, and priorities, all respondents, including lighter users, share similar responses.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Demographics change slightly when we analyze the data from the lighter users. For this group, the majority of respondents were female (56%), slightly younger (41% ages 2544), and a larger percentage report living in Clark County (41%). Although public surveys were submitted from all 17 counties in the state, 82% were submitted from the three urban counties (Washoe, Clark, and Carson City). The aggregated results are heavily weighted by Washoe County respondents (41%), despite Washoe County making up only 15% of Nevada’s overall population. In contrast, only 35% of the surveys submitted were from Clark County yet it makes up 73% of Nevada’s population.

Humboldt Elko

Pershing Lander

Washoe Churchill

Storey Carson City Douglas

Eureka White Pine

Lyon

Mineral

Nye

Esmeralda Lincoln

Clark

1 - 20 20 - 50

100 Miles

50 - 100 100 - 175 175+

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

SCORP

Public Survey Responses by ZIP Code

Additional analysis was conducted by comparing all survey responses to those from counties with different population concentrations.18 Survey responses were segmented according to designation as urban (population centers), rural (outside of population centers), and frontier (<6 people per square mile).19

Humboldt Elko

Pershing Lander

Washoe Churchill

Storey Carson City Douglas

Eureka White Pine

Lyon

Mineral

Nye

Esmeralda Lincoln

Clark

Urban Counties (82% of Responses) - Carson City, Clark and Washoe

Rural Counties (9% of Responses) - Douglas, Lyon and Storey

100 Miles

Frontier Counties (9% of Responses) - Churchill, Elko, Esmerelda, Eureka, Humboldt, Lander, Lincoln, Mineral, Nye, Pershing and White Pine

Population Designations by County

18 Urban Counties = 82% survey respondents - Carson City, Clark, Washoe Rural Counties = 9% survey respondents - Douglas, Lyon, Storey Frontier Counties = 9% survey respondents - Churchill, Elko, Esmerelda, Eureka, Humboldt, Lander, Lincoln, Mineral, Nye, Pershing, White Pine 19 Nevada Rural and Frontier Health Data Book

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Due to the high participation rate of urban counties represented in the aggregate responses, we do not call out “urban” data any differently than all respondents when rural and frontier data is highlighted. Similar to the analysis between all respondents and the lighter users, 84% of survey questions show consistent responses between all respondents and rural counties. However, frontier county responses differ from urban and rural counties in 28% of the questions. For example, 54% frontier respondents feel they do not live within a comfortable walking distance from home to outdoor recreation, and a large majority of children of frontier respondents (78%) cite fishing as an outdoor activity compared to other survey respondent categories. These, and a few notable distinctions for frontier respondents, are outlined below. Lastly, public survey results were also analyzed by county for county-specific data reports (Appendix L). These results are available to land management agencies to assist with applications for LWCF funds through the OPSP (see Implementation Plan). The SCORP authors intend that the profiles will also be utilized by legislators, county commissioners, planning commissions, city councils, travel and tourism offices, non-profits, and parks and recreation departments. Activity Level/Participation — What do survey respondents do for outdoor recreation and how often?

The majority of survey respondents across all groups (56-60%) report that there are usually two people in their group when they recreate outdoors. “I am by myself when recreating outdoors” is the second highest rating for all respondents (36-43%).

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Cathedral George State Park

When considering frequency of participation in outdoor recreation, a high level of use was indicated. 91% of all respondents and 72% of lighter users report participating in outdoor recreation at least once a week over the past 12 months.

To understand participation in different types of outdoor recreation, the survey asked which outdoor recreation activities respondents had participated in over the past 12 months across six categories of activities: •

Trail/road activities

•

Water-based activities

•

Winter outdoor activities

•

Wildlife related activities

•

Outdoor sports (individual and team)

•

Other outdoor activities

Findings from the initial public survey indicate the most popular outdoor recreation activities overall during the previous 12-month period (regardless of category) were trail/road activities, which exceeded all other categories of outdoor recreation activities with hiking and walking ranking significantly higher than any other activity at 81%.

Top 10 Outdoor Recreation Activities All Respondents

Lighter Users

Rural Counties

Frontier Counties

1. Walking (81%)

1. Walking (82%)

1. Walking (81%)

2. Hiking (81%)

2. Hiking (70%)

2. Hiking (81%)

2. Hiking (75%)

3. Swimming (53%)

3. Picnicking (49%)

3. RV Camping (54%)

3. Wildlife viewing (64%)

4. Tent Camping (51%)

4. Swimming (46%)

4. Picnicking (52%)

4. Picnicking (58%)

5. Picnicking (51%)

5. Wildlife Viewing (38%)

5. Wildlife viewing (51%)

5. OHV (57%)

6. Wildlife Viewing (46%)

6. Tent Camping (37%)

6. Swimming (48%)

6. RV Camping (56%)

7. RV Camping/Cabins (42%)

7. RV Camping/Cabins (35%)

7. Tent camping (46%)

7. Tent Camping (53%)

8. Bird Watching (37%)

8. Bird Watching (31%)

8. Kayaking (40%)

8. Fishing (51%)

9. Mountain Biking (34%)

9. OHV (27%)

9. Bird Watching (40%)

9. Bird Watching (47%)

10. OHV (34%)

10. Playground Activity (25%)

10. OHV (38%)

10. Swimming (46%)

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Top 5 Outdoor Recreation Activities by Type (All Respondents) Trail/Road Water-Based Winter Wildlife Team/Indiv “Other”

Walking

Hiking

Mountain Biking

OHV

Jog/Running

81%

34%

31%

Swimming

Kayaking

Stand up paddle

Power boating

53%

33%

22%

17%

None of above

Resort skiing

Snowshoeing

Sled/tubing

36%

31%

27%

20%

Wildlife viewing

Bird watching

Fishing

None of above

Hunting

46%

37%

31%

30%

16%

None of above

Swimming

Golf

Disc/Frisbee golf

Tennis/pickleball

47%

20%

16%

14%

11%

Tent camping

Picnicking

RV Camping/cabins

Target shooting

Playground activities

51%

42%

22%

None of above 29%

“None of the above” was the #1 response for winter outdoor activities and outdoor sports (team or individual). This lack of participation may be attributed to such factors as the COVID-19 shut-down/pause of schools, lack of interest in certain activities, etc., but further investigation would be necessary to determine causality. What is the household proximity to outdoor recreation? How close one lives to an outdoor recreation facility or opportunity (trail/ trailhead, body of water, etc.) is a quality-of-life indicator for many researchers and planners. Findings across all respondents indicated that over 83% live within five miles of an outdoor recreation facility or opportunity. Over 64% say they live within a comfortable walking distance of an outdoor recreation facility or opportunity, and 40% to 46% live less than 1 mile from an outdoor recreation facility or opportunity.

Wild Horse State Recreation Area

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

When you compare the answers to this question for the rural and frontier counties, 54% of the frontier respondents said “no,” they do not live within a comfortable walking distance of an outdoor recreation facility or opportunity. County-by-county analysis provides a closer examination of this question (see Appendix L: County Data Reports). 42

What are the barriers to recreating outdoors? Some of the most telling and important sets of data gathered in the public survey came from two of the five questions regarding barriers:

•

What are the barriers that prevent you from participating in outdoor recreation?

•

What are the barriers that prevent you from enjoying outdoor recreation?

Top 5 Barriers to Participating in Outdoor Recreation Activities % of All Respondents Too Crowded Not Enough Time Limited Access User Conflicts Areas Not Developed Enough 0%

10%

The #1 barrier to participating, or actually getting outdoors to recreate, was different for all respondents compared to the lighter users. For all respondents, the #1 barrier to participating in outdoor recreation is that areas are too crowded (50%). Coming in a distant second for all respondents is “do not have enough time due to work/family/other commitments” at 37%. For lighter users, 50% state they “do not have enough time due to work/family/ other commitments” to participate in outdoor recreation. As a very close second response, 49% of lighter users cite over-crowdedness. One distinction between user groups regarding barriers to participating in outdoor recreation: 22% of lighter users and 20% of frontier county respondents cited the high costs associated with entrance, parking or other user fees as a barrier. Transportation came in as #5 for 17% of rural county respondents, which may reflect the greater distances rural residents may need to travel to access recreation locations.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

20%

30%

40%

50%

60%

The #1 barrier to enjoying outdoor recreation for all respondents was “areas too crowded” (47%). Twenty-nine percent cited “recreation areas damaged or overused”.

Top 5 Barriers to Enjoying Outdoor Recreation Activities All Respondents Areas too crowded

Recreation areas damaged or overused

None of the above

Conflicts between people using the same trails, parks, etc.

Availability of nearby recreational facility

47% 29% 26% 25% 19% 43

Outdoor Recreation and Children The survey data also provides information about families with children, children’s top outdoor activities, and barriers to children participating in outdoor recreation. Survey responses that include “Playground activities” or “Playgrounds/ Play Areas” also point to interesting perspectives specific to children and families with children. Parents represent a significant portion of survey responses. 28% of all respondents (30% lighter and frontier users, 21% rural) indicate having children under 18 years of age. Lighter users are the only group that includes “playground activities” in their top 10 outdoor recreation activities. However, “playground activities” is in all groups’ top 5 “other” outdoor activities. And, in the Priorities section, findings will show that “Playgrounds/Play Areas” ranked in the top 3 for all respondents and lighter users for ranking desired “outdoor recreation investments where I live.”

Camping and hiking were the most highly ranked children’s outdoor activities.

Top 10 Children’s Outdoor Activities All Respondents

Lighter Users

Rural Counties

Frontier Counties

1. Camping 80%

1. Hiking 72%

1. Camping 89%

1. Camping 87%

2. Hiking 78%

2. Camping 70%

2. Hiking 83%

2. Hiking 81%

3. Bicycling (all) 66%

3. Swimming 58%

3. Bicycling (all) 67%

3. Fishing 78%

4. Swimming 63%

4. Bicycling (all) 55%

4. Rafting/kayaking 61%

4. Swimming 63%

5. Fishing 56%

5. Fishing 49%

5. Fishing 60%

5. Wildlife viewing 61%

6. Team or indiv. sports 53%

6. Team or indiv. sports 49%

6. Skiing/snowboard 59%

6. Bicycling (all) 59%

7. Running (all) 52%

7. Running (all) 44%

7. Swimming 58%

7. OHV 56%

8. Skiing/snowboard 52%

8. Wildlife viewing 39%

8. Running (all) 55%

9. Rafting/kayaking 48%

9. Rafting/kayaking 39%

9. Team or indiv. sports 53%

9. Target shooting 55%

10. Wildlife viewing 46%

10. Skiing/snowboard 38%

10. Wildlife viewing 50%

10. Team or indiv sports 54%

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

When asked about factors that limit children’s engagement with the outdoors, all groups cite “busy schedule” as almost twice the #2 response (“other entertainment options”), with one exception. Frontier respondents cite “busy schedule” as twice their second choice, which was “money/finances”.

Top 5 Factors that Limit Children’s Outdoor Recreation Activities All Respondents

Lighter Users

Rural Counties

1. Busy schedule 62%

1. Busy schedule 65%

1. Busy schedule 67%

1. Busy schedule 64%

2. Other entertainment 31%

2. Other entertainment 33%

2. Other entertainment 38%

2. Money/finances 29%

3. Money/finances 18%

3. Lack of interest 21%

3. Money/finances 18%

3. Other entertainment 25%

4. Lack of interest 18%

4. Money/finances 18%

4. Lack of interest 15%

4. Lack of accessibility 19%

5. No spaces nearby 13%

5. No spaces nearby 15%

5. Lack of accessibility 14%

5. Lack of interest 16%

Outdoor Recreation and People with Disabilities Of the 14% (all respondents) to 20% (lighter users) who identify as having a disability or someone in their household having a disability, 80+% report physical disabilities, 12+% cite hearing as a disability, 7+% have a learning/cognitive disability, and 16+% selfidentify “other” types of disabilities such as allergies, pregnancy, and oxygen dependency. For individuals and family members who have a disability, 74% report that the outdoor recreation facilities and/or public lands they use to recreate outdoors meet the needs of the disability. This high level of satisfaction does vary somewhat by county and is highlighted in the county-specific data reports (Appendix L). In summary, the data survey findings highlighted above illuminate the demand for outdoor recreation, the barriers to participation and enjoyment of recreating outdoors, and provide solid insight that informs how the SCORP goals, strategic objectives, and recommendations might address both public and land management needs and priorities.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Frontier Counties

Preferences and Priorities A primary purpose of this SCORP is to outline the goals, objectives, and implementation strategies that will guide the distribution of LWCF funding across Nevada for public outdoor recreation, along with informing outdoor recreation planning and development, health and wellness efforts, and economic development initiatives over the next five years. Input from survey respondents regarding their outdoor recreation priorities, preferences, and barriers has helped shape the goals and implementation plan for this SCORP. According to the National Recreation and Park Association (NRPA), U.S. adults want their local governments to invest in community infrastructure, such as parks, community centers, recreation facilities, and senior centers. These investments allow for increased access to green space and nature, help bring vital services and programs to the community, and improve the physical and mental health of all residents.

•

More than 9 in 10 U.S. adults say it is important for local governments to invest in community infrastructure 20

•

Seventy percent of U.S. adults say investing in community infrastructure by local governments is extremely or very important

Tahoe Pyramid Trail

Key NRPA Findings

Responses to the Nevada Outdoor Recreation public surveys are consistent with the NRPA findings. A large majority (over 90%) of all respondents place a medium to high priority on allocating funding for parks, trails, open space, and outdoor recreation facilities in Nevada. All respondents and lighter users had very similar top-five responses to “Where would you like to see the biggest focus of recreation resources in Nevada?”, with one notable difference. For the lighter users, responses indicate support for State/National Parks in a tie with smaller neighborhood-based parks. Note: larger multi-purpose regional parks ranked last in all groups.

Top 5 Focus Areas for Outdoor Recreation Resources in Nevada All Respondents

34% 16%

Acquire land to preserve open space

State or National Parks

11%

29%

Develop or improve trails/trailheads

Smaller neighborhoodbased parks

Larger multi-use regional parks

20 https://www.nrpa.org/publications-research/park-pulse/investing-in-parks-and-recreation/

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

When asked to prioritize local outdoor recreation investments, the top five types of recreation areas that all groups would like to see “where they live” (ranked as essential + high priority) are as follows:

Ranking of Top-5 Priorities for Outdoor Recreation Investments “Where You Live” All Respondents

Lighter Users

Rural Counties

Frontier Counties

1. Unpaved walking paths

1. Nature/wildlife viewing areas

67%

65%

68%

60%

2. Nature/wildlife viewing areas 2. Nature/wildlife viewing areas 2. Nature/wildlife viewing areas 2. Unpaved walking paths 56%

59%

55%

56%

3. Playgrounds/play areas

3. Off-leash dog areas

3. OHV trails/areas

41%

44%

38%

45%

4. Off-leash dog areas

4. Picnic areas/shelters

4. OHV trails/areas

4. Picnic areas/shelters

39%

40%

36%

43%

5. Singletrack mt bike trails

5. Paved trails/paths

5. Singletrack mt bike trails

5. Playgrounds/play areas

39%

40%

32%

41%

All Respondents

88%

Open Space

74% Trailhead

72% Park

50% Recreational Facility

The #1 type of outdoor facility or opportunity that is “moderately important to very important” to survey respondents to have “within walking distance of home” is open space at 88%, with parks and trailheads vying for 2nd and 3rd across all user groups. Recreational facility is the #4 choice for all user groups to have within walking distance of home.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Top 5 Reasons to Recreate Outdoors All Respondents

Mental well-being

77% 50%

Spend time in nature

Exercise/physical health

When asked “How important to you are the following reasons to recreate outdoors?”, 94% of light users, 80% of all respondents, and 76% of rural respondents indicated “for mental well-being/to feel restored” as “very important.” The top reason (76%) to recreate outdoors for frontier respondents was to “enjoy or spend time in nature.” The chart below shows the results when survey respondents were asked to “provide your top three priorities from the following elements of outdoor recreation facilities in Nevada”. “Safety” was the #1 response for lighter users (45%). “Well-maintained” was #1 or #2 for all groups, and frontier respondents cited “wildlife viewing” as their top element (43%).

74%

Relax/unplug/solitude

Time with friends and family

Great Basin National Park

80% 70%

Priorities for Outdoor Recreation Facilities All Respondents

Lighter Users

Rural Counties

Frontier Counties

1. Well-maintained 41%

1. Safety 45%

1. Well-maintained 42%

1. Wildlife viewing 43%

2. Wildlife viewing 38%

2. Well-maintained 38%

2. Safety 40%

2. Well-maintained 38%

3. Safety 37%

3. Wildlife viewing 36%

3. Ease of use 39%

3. Safety 35%

4. Ease of use 37%

4. Ease of use 36%

4. Wildlife viewing 33%

4. Ease of use 32%

5. Accessible 22%

5. Accessible 24%

5. Accessible 23%

5. Cleanliness 32%

When asked how outdoor recreation areas or facilities could assist respondents in achieving their health and wellness/fitness goals or priorities, a majority of respondents across all groups indicated “protect and encourage more natural settings at outdoor recreation areas/facilities” and “provide more long-distance trails/pathways.” “Support health and fitness community events” came in #3 across all user groups for this question.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Great Basin National Park

Photo Credit: Travel Nevada

PUBLIC SURVEY PART 2

How and Where We Recreate At the conclusion of the public survey, we asked all respondents if they would be willing to provide additional information and input. The initial survey respondents who said “yes” (1,479/24%) were emailed a second survey, “Part 2: How and Where We Recreate.” There were 721 survey responses (49% response rate) to the Part 2 survey, and the following analysis is derived from those responses.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

The purpose of the Part 2 survey was to gather more specific information about respondents’ outdoor recreation activities over the past year, and where they participated in those activities. To determine location, we utilized the five geographic regions designated by Travel Nevada, the state’s tourism marketing portal (travelnevada.com), and correlated responses by survey respondent’s county of residence. The findings will be useful in many ways – particularly as regions seek to increase participation and thus economic vitality by attracting outdoor recreation visitors from other regions across the state. This data demonstrates what activities are most likely to be conducted in someone’s own backyard versus a willingness to travel to recreate in a region outside of their local

environment. Understanding this data is a crucial step in planning for and implementing sustainable recreation opportunities and infrastructure. To provide a glimpse into Part 2 survey results, below are the maps for one of the five regions. These maps represent the mobilization patterns for outdoor recreation across the state. The first shows the pattern of travel of Region 1 respondents who go outside of their region for outdoor activities. The second map shows travel of survey respondents from the other regions into Region 1 for specific activities. These maps are included as Appendix M and are available for each region (and the counties that make up each region) to use in their outreach and planning to cultivate community vibrancy and economic vitality through outdoor recreation.

Region 1: Where We Go to Recreate Where do the 24 survey respondents from Region 1 recreate, and in what top activities do they participate in each Region?

42%

38%

Region 1 Respondents go to Region 2 to:

Walk/Hike 8

Region 1 Respondents go to Region 3 to:

Walk/Hike 7

Ski/Snowmobile 4

View Wildlife 5

View Wildlife 4

Tent camp 4

Swim 3

REGION 1

Fish 3

Sled/tube 3

Backpack 3

Fish 3 Tent Camp 3 REGION 2

REGION 3

REGION 4

21%

Region 1 Respondents go to Region 5 to:

Walk/Hike 2

Region 1 Respondents go to Region 4 to:

Walk/Hike 3 View Wildlife 3

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

View Wildlife 2

REGION 5

Who Comes to Region 1 to Recreate? What % of survey respondents from other regions come to Region 1 to recreate, and in what top activities do they participate in Region 1?

45%

Region 2 respondents go to Region 1 to:

100%

Region 1 respondents stay in Region 1 to:

OHV 46

Hike/walk 23

Picnic 14

Tent Camp 68

Picnic 39

Fish 18

Snowshoe 12

View Wildlife 65

Hunt 34

View wildlife 17

Jog/run 11

RV Camp/Cabins 62

Backpack 31

Tent camp 17

OHV 10

Bird watch 51

Fish 28

Swim 14

Backpack 10

Walk/Hike 116

65%

Region 3 respondents go to Region 1 to:

RV Camp/Cabins 7

Tent camp 4

Walk/Hike 6

Motorcycle 4

OHV 6

Hunt 2

View wildlife 4

Geocache 2

44%

Region 4 respondents go to Region 1 to:

Walk/Hike 7

Picnic 5

OHV 6

Hunt 3

RV Camp/ Cabins 5

Fish 3

Tent camp 5

View wildlife 3

18%

Bird watch 3

REGION 1

REGION 2

REGION 3

REGION 4

Region 5 respondents go to Region 1 to:

Walk/Hike 28

RV camp/cabins 9

Tent camp 16

Picnic 9

Bird watch 15

Backpack 7

OHV 13

Fish 5

View wildlife 13

Rock Climb 4

REGION 5

Overall, survey responses indicate a willingness among outdoor recreation enthusiasts to travel to engage in recreation. Over 50% of all respondents and the lighter users are willing to travel more than 50 miles to recreate outdoors. 67% of all respondents reported taking more than 12 daytrips, compared to lighter users where 51% reported taking 6-11 daytrips, and 0% reported taking more than 12 daytrips. Both groups took 2-5 overnight trips last year (36+%).

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Guru Road, Gerlach

Information and Technology Several questions in both the initial “Public Survey” and the follow-up survey, “Part 2: How and Where We Recreate” were asked to gain insight into how respondents access information about outdoor recreation, and how they use technology to support their activities. Findings indicated that 84% of respondents learn about outdoor recreation opportunities online. 73% get information through word of mouth, and 37% from print sources (newspaper, magazine, brochures). To gauge the utility of using technology when planning or recreating outdoors, the Part 2 survey, “How and Where You Recreate,” asked four questions:

•

What technology do you use to do research on where to go/visit?

•

What technology do you use to track your activities (speed, distance, route elevation, etc.)?

•

What technology do you use to assist in the activity (navigation, payment of fees, etc.)?

•

What technology do you use to share your adventures (photos, blogs, etc.)?

The top two answers to “What technology do you use” in each category are highlighted below:

What technology do you use to:

? Do Research

Track Activities

Assist in Activities

Share Adventures

All Trails 53% Facebook 41%

Garmin 27% Strava 20%

All Trails 21% Garmin 16%

Facebook 52% Instagram 39%

Responses to these questions indicate a comfort level with the use of technology when planning and recreating outdoors. This information will be helpful as NDSP, NDOR and land managers look to engage with users, share information, and identify opportunities to address the priorities and barriers identified in this document.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Spring Mountain Ranch State Park

LAND MANAGER SURVEY RESULTS In addition to the two public surveys, land managers across Nevada, representing federal, state, city/county, and tribal jurisdictions, were surveyed to provide input to the SCORP discovery process. Land managers are in a unique position to bring key insight about the delivery system of outdoor recreation since they are responsible for administering, developing, and maintaining natural sites for conservation and/or resource development. Land managers were invited through multiple channels to participate in the 2021 Nevada Land Manager Survey. There were 139 responses to the survey. Of the respondents who identified their type of agency, 64% affiliate with a federal agency, 26% state, 7% city/ municipality, and 3% county. Fifty-seven percent of the survey respondents have been professionally involved in outdoor recreation for 10 years or more. The land manager survey was divided into four categories of questions:

•

Accomplishments of the last five years (see “2016-2020 SCORP Accomplishments and Insight”)

•

Issues and barriers

•

Priorities

•

Agency information (planning, staffing, budget, and demographics)

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

From the four categories of questions, perhaps most influential to this SCORP’s goals and implementation plan are the field-based perspectives gained from land managers regarding issues, barriers, and priorities.

Issues and Barriers Survey findings indicate that insufficient resources (staff and budget) are the #1 barrier for land managers and their agencies to be able to fulfill obligations. In fact, when asked specifically if staffing levels are adequate to meet their agency needs for outdoor recreation, 90% of federal respondents, 83% of state respondents, 80% of city/municipality, and 75% of county respondents answered “no.”

Issues and Barriers: In Their Words

“We have an extremely dedicated staff, but they are always digging under rocks (partnerships, collection agreements, Interpretive associations, etc.) for funding/support of interpretive programs and site maintenance. It’s hard work. Our partners and staff suffer loving these lands so much.”

Spencer Hot Springs

— Federal Land Manager

“There has not been significant progress to improve outdoor recreation opportunities over the past 5 years. The county I work in was only just beginning to crawl back from the impacts of the 2008 - 2012 Recession

“Dedicated funding sources, resilient to the effects of economic downturns, are sorely needed.” — State Land Manager

when COVID-19 shut down the nation’s, state’s and local economies. The tax structure in Nevada severely restricted the county’s abilities to return to pre-Recession budgets and service levels. The resulting cuts to personnel and budgets took an additional hit with the COVID-19 closing of the economy just as things were looking up.” — County Land Manager SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Land managers were asked “How significant are the following funding issues related to outdoor recreation, parks, open space, waterways, etc., for your agency?” While the ranking of significance varied between land management agency types, all groups indicated that insufficient/unstable budget resources, inadequate staffing, and the lack of dedicated funding sources are “very significant” funding issues frequently faced by land managers. Without sufficient and sustainable funding resources, land managers are limited in their abilities to build and maintain agency and program capacity, leverage funding for partnerships and grants, and hire/retain adequate staffing levels.

Sustainable funding is a fundamental core issue that must be addressed to foster expansion of Nevada’s outdoor recreation system.

•

Reduce services or staff

•

Rely on additional volunteer services

•

Seek sponsorship or donations

•

Apply for grants

•

Increase user fees

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Lake Tahoe Nevada State Park, Spooner Lake

In times of financial shortfall, land manager survey respondents provided the top-five ranked solutions:

Answered “very significant” when asked about different funding issues related to outdoor recreation (by type of agency). Decrease in tax revenue

Instability of agency budget

Lack of dedicated funding source

Insufficient resources to fund budget

Inadequate funding to hire staff 0%

Federal

State

10%

20%

County

30%

40%

50%

60%

70%

City

Answered “very significant” when asked about different funding issues related to outdoor recreation (by type of agency).

Outdoor recreation is not a planning priority

Lack of dedicated funding source

Stability of agency budget

Insufficient resources to fund agency’s budget 0% Federal

State

County

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

10%

20%

30%

40%

50%

60%

70%

City

Comprehensive, up-to-date planning that is used for decision making and project implementation allows for optimal leverage of funding and other resources. Conversations with land managers across all jurisdictions indicate that planning services or staff are often the first to be cut during times of financial shortfall. These limited resources result in

planning gaps, including plans that are significantly out-of-date or planning efforts that are not undertaken at all. To support sustainable recreation that considers the wide spectrum of resource and user needs, current and relevant planning must be established as a baseline requirement in developing and implementing Nevada’s recreation system.

How significant are the following outdoor recreation management and visitor services issues for your agency? 80 70 60

72 63

56 50

40 30

20 10 0

Federal

State

County

Capacity of recreation assets to serve growing population

Balancing resource protection with sustainable recreation Capacity to develop new infrastructure

When asked if their agency has planning documents that guide decisions related to the use and management of parks, trails, open space or other land or water managed for outdoor recreation, 93% responded “yes.” Respondents indicate using many different types of recreation plans (trails plans, master plans, resource or forest management plans, travel management plans, etc.).

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

City

Capacity to maintain existing infrastructure

However, feedback from land managers indicates several key barriers to planning:

•

Plans are not up-to-date

•

Plans are not being utilized

•

Planning by agency type is done in isolation, not coordinated

•

Plans/agencies are not speaking the same language when it comes to planning

Barriers identified by the responding land managers were also captured in comments provided in multiple survey questions and in the comment section at the end of the survey. A sampling of these cited barriers, frustrations, and comments (segmented by agency type) include the following:

Needs and Challenges: In Their Words “Funding needs to be a higher priority for National Parks, and the Forest Service

Lake Tahoe Nevada State Park, Sand Harbor

to properly staff and care for the land. Employee burn out, due to under-staffing, is going to eventually be detrimental to shortfalls in the system of taking care of the land and serving the people. Without proper funding and proper staffing of personnel, the overcrowding on public land is going to start a snowball effect of reducing adequate care of the lands.” — Federal Land Manager

Nevada suffers from significant planning gaps. There is an opportunity in front of us to leverage this SCORP and other current initiatives to commit to, develop, and better utilize a more robust and thorough planning strategy. We often have the development cart far in front of the horse - and that is a direct result of insufficient capacity (staff) and resources (dollars) that are committed to planning. — State Land Manager

“Work with BLM to complete Resource Management Plans, then work with BLM to complete step down activity and area specific plans for trails and recreation facilities. Work with BLM to find creative funding sources to get projects completed AND maintained into the future. This process has worked in other places, BLM needs help to complete the planning and then needs local groups or governments to commit to maintenance of these valuable community assets.” — Federal Land Manager

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

The #1 trail-related priority for all agency types is “maintaining existing trails.” The second-ranked trail-related priority is “creating opportunities for non-motorized trail users,” and coming in third is “connecting existing trails.”

Jarbidge Wilderness

Priorities The land manager survey findings regarding priorities bring to light a sweet spot at the intersection of supply and demand – when supply (and upkeep) can thrive with a robust demand (increased/expanded participation in outdoor recreation). Well-documented increases in demand can justify increases in funding to accommodate additional sustainable development.

When asked to identify the top outdoor recreation priorities for their agencies for the next five years, “maintenance of existing facilities” was the #1 response cited by the majority of all agency type respondents, followed by “balancing visitation with natural resource protection” and “developing or expanding trail systems.”

Priorities: In Their Words “Primary challenge is maintaining the trail systems and recreation facilities with limited staff and funding. Partners and grants have become a necessity! Always looking for partnerships that provide mutual benefits!” — Federal Land Manager

“It is critically important that existing parks, facilities, and infrastructure be maintained and improved. This is especially important when/as user fees increase. If visitors don’t see improvements over time they begin to question where their money goes, as well as, agency/organization management.” — State Land Manager

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

of critical importance to society. More needs to be done to supply and financially support these resources. Planning is a critical piece that needs to be better supported as well.” — State Land Manager

Both the 5-year and trail-related priorities from the land managers dovetail nicely with the public survey responses. Findings from the public surveys place highest value on well-maintained and safe facilities (#1 priority from all types of land managers is the “maintenance of existing facilities”). The #1 barrier to public survey respondents’ enjoyment of outdoor recreation was overcrowding, while land managers place high priority on balancing visitation with natural resource protection and expanding/developing/connecting trail systems. However, as pointed out in the land manager “Barriers” narrative above, to be able to address and/or carry out these priorities, land managers identified adequate human and financial resources as significant barriers to having the capacity to meet demand and agency needs.

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

Washoe Lake State Park

“Parks, Open Space, and Trails are, in my opinion,

Land Manager Issues and the Intersection with Issues Provided by the Public Survey Respondents When asked what types of programs are offered by respondents’ agencies, a majority of land managers indicated they offer “Environmental/Conservation Education” and “Recreation” programs (with the exception of federal land managers, where only 32% report offering “Recreation” programs). Public survey respondents indicate “mental well-being/to feel restored” and “to exercise/improve physical health” as two of the top five reasons to recreate outdoors, and over 60% of all public survey respondents prioritized specific ways outdoor recreation facilities/areas could assist them in achieving their health and fitness goals or priorities. However, only 33% of city/municipality, 25% of county, 21% of federal, and 20% of state land managers indicated that they offer health programs. Based on focus group input, public health and wellness outcomes are being recognized by land managers as important connections with outdoor recreation and are being increasingly incorporated into their land management strategies. 60

To what extent does health & wellness of recreational visitors figure into your land management strategy? City County State Federal 0%

10%

20%

Very important/important

30% Neutral

40%

50%

60%

70%

80%

90%

100%

Less/not important

Issues of diversity, equity, and inclusion are now recognized as integral components to planning and development of outdoor recreation opportunities for all. While land manager survey responses indicate that this does not currently rank as high as other priorities, land managers will be called on to consider these elements moving forward toward more sustainable opportunities.

How much do issues of diversity, equity, and inclusion factor into your decisions about managing the land and recreational resources in your jurisdiction, particularly as it relates to access? 100% 80%

A great deal/sometimes

60% Neutral

40%

Seldom/not at all

20% 0% Federal

State

SCORP 2022- 2026 | Part 2: Outdoor Recreation In Nevada

County

City

Park to Park Pedal

Part Three

2022-2026 NEVADA SCORP FRAMEWORK

In this section: Outdoor Recreation Issues of Statewide Importance 2022-2026 SCORP Themes Goals, Strategic Objectives, and Recommendations

SCORP 2022- 2026 | Part 3: Nevada SCORP Framework

Big Bend of the Colorado State Recreation Area

OUTDOOR RECREATION ISSUES OF STATEWIDE IMPORTANCE Nevada is a special place, with unlimited options for outdoor recreation in all reaches of the state. The diversity of terrain and climate, along with access to over 70 million acres of public lands, makes our state an unparalleled outdoor recreation destination. The demand for outdoor recreation amenities in Nevada has always been high, but we learned during our survey process that the state’s facilities could not fulfill the public’s expectations. There is more demand than our available outdoor recreation assets can provide, resulting in diminished outdoor recreation experiences and damage to our natural and cultural resources. Overcrowding and lack of access were two of the biggest challenges, which brought to the forefront the need to identify areas for improvement. Yet, to maintain a healthy environment and outstanding outdoor recreation opportunities, it is our obligation to conserve our natural landscapes and resources to ensure Nevada’s beauty and recreational opportunities are available for current and future generations. It is critical to balance the interests of both recreation and conservation. We need to create a sustainable way forward. The 20222026 SCORP offers a guideline for all Nevadans to actively engage in the future of sustainable outdoor recreation and conservation. The challenges cannot be tackled alone. Successful implementation of the SCORP will require the continued active involvement of many individuals and organizations.

SCORP 2022- 2026 | Part 3: Nevada SCORP Framework

Building on the 2016-2021 SCORP, the themes and goals for the next five years respond to identified issues, current trends, user preferences, and opportunities for outdoor recreation in Nevada. They also reflect the finicky supply-and-demand matrix necessary to balance high-quality outdoor experiences with conserving and stewarding natural and cultural resources. These priorities are interconnected and critical components to achieving a vision for the future where Nevada’s great outdoors continue to provide rich recreation experiences and enjoyment for residents and visitors alike.

Sustainable Outdoor Recreation

Pathways to Health & Wellness

Community & Economic Vitality

2022-2026

SCORP THEMES

Van Sickle Bi-State Park

Working together, NDSP and NDOR identified three overarching themes based on valuable input from the SCORP Advisory Team, public and land manager surveys, workshops, and public comments. The resulting themes are:

SCORP 2022- 2026 | Part 3: Nevada SCORP Framework

Sustainable Outdoor Recreation Community and Economic Vitality Pathways to Health and Wellness

$ Sustainable Outdoor Recreation Special outdoor experiences, healthy and resilient environments and ecosystems, and the economic and community benefits of outdoor recreation, are only possible through the careful conservation and stewardship of Nevada’s natural and cultural resources, and public lands and waters. Without both the responsible use and appropriate management of the lands and waters on which Nevadans recreate outdoors, the numerous well-documented social, cultural, economic, and even spiritual benefits of outdoor recreation cannot be realized. This plan identifies sustainable recreation as an overarching theme, defined as high-quality outdoor recreation opportunities that meet identified needs without compromising the benefits to future generations. Sustainable recreation can be fostered by leveraging the unique strengths, missions, authorities, and capacities of local, state, and federal land management agencies, parks and recreation divisions, and other relevant agencies and organizations to plan and manage for outdoor recreation opportunities that consider the environmental, economic, and social impacts and benefits of outdoor recreation. Achieving this goal means prioritizing projects that:

•

Optimize and leverage funding to plan develop, maintain, and staff outdoor recreation opportunities

•

Protect natural and cultural resources while ensuring the broad benefits of outdoor recreation can be enjoyed by everyone

•

Foster sustainable outdoor recreation opportunities through conservation, stewardship, and recreation management

Community and Economic Vitality According to research conducted by Headwaters Economics, communities with strong outdoor recreation economies are more likely to attract new residents with greater wealth and offer faster-growing wages than their non-recreation counterparts. This is particularly true in rural communities.21 In Nevada, rural communities are often gateways to our state’s most beloved outdoor recreation opportunities. Abundant natural amenities, including public lands and waters, can help support outdoor recreation economies that contribute to strengthening and solidifying communities. Following communitybased visioning processes and guided by appropriate planning, outdoor recreation can be an important contributor to an overall economic development strategy for many communities, helping contribute to vibrancy indicators and economic vitality. For more information on Nevada’s outdoor recreation economy, see Appendix A. BEA ORSA 2020 Numbers.

Pathways to Health and Wellness Access to the outdoors and participation in outdoor recreation is broadly linked to improved public health outcomes. Simultaneously, outdoor recreation positively impacts numerous social determinants of health by engaging participants in modestly physical activity. State, federal, local, and non-governmental agencies can collaborate to improve public health outcomes by increasing access to the outdoors for people of all backgrounds and abilities. Additionally, by partnering with health and wellness stakeholders, agencies can establish common values and goals, build relationships, and generate innovative mechanisms to fulfill shared visions.

21 https://headwaterseconomics.org/economic-development/trends-performance/outdoor-recreation/

SCORP 2022- 2026 | Part 3: Nevada SCORP Framework

U.S. Highway 50: Loneliest Road in America

GOALS, STRATEGIC OBJECTIVES, AND RECOMMENDATIONS The goals, strategic objectives, and recommendations presented in this plan offer a direction for collective action over the next five years and are the building blocks to developing the SCORP Implementation Plan. Through implementation, these goals, strategic objectives, and recommendations will support opportunities for meaningful outdoor experiences while protecting our natural and cultural resources. The SCORP addresses the supply and demand of outdoor recreation in Nevada, identifies gaps, and builds on the existing initiatives occurring across the state. Success will come from working across sectors and interests to enact statewide and local solutions.

The goals, strategic objectives, and recommendations of this SCORP also reflect Nevada’s commitment to The Confluence Accords,22 a set of principles guiding the creation and work conducted by state offices of outdoor recreation across the U.S. (including NDOR). Adoption of The Confluence Accords commits Nevada to promoting, developing, maintaining, planning, and implementing outdoor recreation opportunities sustainably and responsibly, based on four key pillars:

Conservation and Stewardship Education and Workforce Training Economic Development Public Health and Wellness

22 To achieve the goals within each thematic area, goals, strategic objectives, and recommendations are defined as: Goal: A broad, thematic area of emphasis with a desirable outcome Strategic Objective: A planned action or desirable outcome needed to achieve a goal or make substantial process toward a goal’s achievement Recommendations: Specific examples of actions or projects that would substantially contribute to a goal’s achievement

SCORP 2022- 2026 | Part 3: Nevada SCORP Framework

•

Provide for an array of appropriate, high quality outdoor recreation experiences

•

Protect and conserve the natural environment

•

Preserve the culture and enhance the economies of Nevada communities

Echo Lake State Park

Additionally, Nevada is a leader in fostering interagency communication and collaboration to achieve shared visions and goals associated with the well-documented benefits of outdoor recreation. Nevada is the first state in the nation to have engaged state and federal agency partners to develop an agreement for outdoor recreation shared stewardship. Leveraging the strengths, missions, authorities, and capacities of state and federal agencies with substantial influence on land management and outdoor recreation opportunities and experiences, the Outdoor Recreation Shared Stewardship Agreement (Appendix N) commits partners to collaboratively plan and manage ecologically, economically, and socially sustainable outdoor recreation opportunities that:

With considerable overlap of goals and themes, the SCORP, The Confluence Accords, and the Outdoor Recreation Shared Stewardship Agreement offer co-related frameworks for engaging Nevadans, visitors, outdoor businesses, and a host of non-profit, government, and other organizations and agency partners in achieving this SCORP’s success and impact over the next five years. The themes, goals, strategic objectives 23, and recommendations of this plan are for everyone. Any successes it creates will be because of the input from the public and stakeholders, and because of broad participation and engagement in the plan’s implementation. Thank you for engaging in the future of conservation and recreation in Nevada.

23 To achieve the goals within each thematic area, goals, strategic objectives, and recommendations are defined as: Goal: A broad, thematic area of emphasis with a desirable outcome Strategic Objective: A planned action or desirable outcome needed to achieve a goal or make substantial process toward a goal’s achievement Recommendations: Specific examples of actions or projects that would substantially contribute to a goal’s achievement

SCORP 2022- 2026 | Part 3: Nevada SCORP Framework

Lake Tahoe Nevada State Park, Spooner Lake

Part Four

IMPLEMENTATION PLAN

In this section: How to Use this Plan Implementation Matrix Ongoing and Future Engagement

SCORP 2022- 2026 | Part 4: Implementation Plan

Accessible MTB Trail, Lake Tahoe

HOW TO USE THIS PLAN LWCF Project Selection and Allocation Project applicants to the LWCF program are an integral part of implementing the SCORP. The themes, goals, strategic objectives, and recommendations outlined in this document will be used to guide the selection of projects through the OPSP. Applicants are required to consider potential project partners, and will be asked to explain how a proposed project will support implementation of Nevada’s 2022-2026 SCORP. The OPSP is found in Appendix O.

SCORP 2022- 2026 | Part 4: Implementation Plan

Red Rock National Conservation Area

The 2022-2026 SCORP Implementation Plan identifies the goals, strategic objectives, and recommendations that will advance sustainable outdoor recreation in Nevada.

Guide and Coordinate Planning The 2022-2026 SCORP represents a next level effort for Nevada. Recreation planners, land managers, individuals, and communities will find survey results, inventory data, and findings that will lead the way towards a more sustainable outdoor recreation system over the next five years. From the local to the federal level, this plan will help guide, coordinate, and elevate outdoor recreation planning — and subsequently, development — across all sectors. This SCORP focuses on three thematic areas: Sustainable Outdoor Recreation, Community and Economic Vitality, and Pathways to Health and Wellness.

The implementation plan offers recommendations for how project partners can work with each other towards creating sustainable offerings in Nevada’s diverse and expansive outdoors.

It is essential to proactively plan for sustainable outdoor recreation in Nevada, to ensure the natural beauty and diverse environments that make Nevada unique are stewarded for future generations.

Flume Trail, Lake Tahoe

These three themes are foundational — and are woven throughout the goals, objectives, and strategies laid out in the implementation plan with the intention of strengthening the base upon which Nevada’s sustainable outdoor recreation opportunities are built.

Leverage Funding and Resources Over the past decade, outdoor recreation providers have come to understand the importance of collaboration in project planning and delivery. Nevada’s 2022-2026 SCORP calls on all with an interest in sustainable recreation to strengthen their efforts to plan and develop projects that leverage multiple funding sources and creatively and efficiently make use of resources. Sustainability includes financial and human resources, as well as natural and cultural resources.

SCORP 2022- 2026 | Part 4: Implementation Plan

Santa Rosa-Paradise Peak Wilderness Area

IMPLEMENTATION MATRIX

SCORP 2022- 2026 | Part 4: Implementation Plan

Theme: Sustainable Outdoor Recreation Goal: Create and expand upon a sustainable outdoor recreation system. Strategic Objectives and Recommendations 1. Optimize and leverage funding to plan, develop, maintain, and staff outdoor recreation needs while balancing conservation and resource protection. a. Build capacity for long-term investments in outdoor recreation infrastructure by identifying potential sustainable funding sources and methods. b. Build capacity for new outdoor recreation infrastructure by prioritizing planning that bridges the gap between user need and existing infrastructure. c. Leverage cross-sector funding opportunities. d. Foster public/private partnerships that enhance the development and maintenance of sustainable outdoor recreation infrastructure. 2. Plan and develop projects that support a sustainable outdoor recreation system which protects natural and cultural resources. a. Identify recreation sites and systems where over-use and overcrowding are currently damaging resources and develop plans and strategies to reduce outdoor recreation over-use and overcrowding. b. Rehabilitate and maintain existing outdoor recreation infrastructure where necessary. c. Develop, coordinate, and implement a statewide Resource Conservation Plan. d. Develop, coordinate, and implement a statewide Trails Plan (cross-jurisdictional). e. Develop, coordinate and implement a State Park System Plan. f. Develop and maintain a comprehensive library of outdoor recreation-related plans for the purposes of interagency cooperation. g. Develop and maintain a comprehensive statewide Outdoor Recreation Asset Inventory and gap analysis. h. Coordinate across outdoor recreation providers to optimize resources to support SCORP implementation. 3. Foster sustainable outdoor recreation through conservation and stewardship. a. Educate users and influence behavior on sustainable recreation best practices. b. Educate users about why protection and conservation of natural resources supports sustainable outdoor recreation. c. Target education/outreach to those who may not currently utilize outdoor recreation. d. Educate users in order to mitigate conflicts between people using the same trails, parks, etc. e. Develop partnerships with civic sector and community-based organizations to optimize resources and stewardship opportunities. SCORP 2022- 2026 | Part 4: Implementation Plan

Theme: Community and Economic Vitality Goal: Leverage the strength of outdoor recreation as a driver of community and economic vitality.

Strategic Objectives and Recommendations 1. Cultivate community vibrancy and economic vitality through healthy lands and waters that support sustainable outdoor recreation. a. Collaborate with communities to identify local and regional outdoor recreation opportunities that provide community and economic benefit. b. Develop partnerships with civic sector and community-based organizations to optimize resources and stewardship opportunities. c. Identify opportunities for multiple funding streams to support and enhance outdoor recreation. d. Optimize staff and volunteer capacity to develop and implement outdoor recreation projects and initiatives. e. Coordinate across jurisdictional boundaries to ensure that planning efforts result in complementary rather than duplicative recreational experiences. 2. Promote and increase awareness of diverse outdoor recreation opportunities while protecting Nevada’s natural and cultural resources. a. Educate current, new, and potential visitors about sustainable recreation and resource conservation. b. Design and implement programs that will attract and retain responsible outdoor recreation users. c. Target education/outreach to promote underutilized recreation areas. d. Develop educational tools designed to mitigate user conflicts. 3. Expand opportunities for people with diverse backgrounds to interact with natural and cultural resources and to equitably share benefits of outdoor recreation. a. Prioritize projects that support different types of recreational use. b. Target education/outreach to those who may not currently utilize outdoor recreation. c. Develop and promote programs that encourage recreational use by diverse groups. d. Partner with existing community-based organizations to promote outdoor recreation and its importance, while building capacity for public engagement in recreation planning. e. Develop programs that promote safe and welcoming outdoor recreation experiences for users of all types and abilities.

SCORP 2022- 2026 | Part 4: Implementation Plan

Theme: Pathways to Health and Wellness Goal: Expand pathways to health and wellness through outdoor recreation. Strategic Objectives and Recommendations 1. Leverage investment in outdoor recreation projects that advance the health and wellness benefits of outdoor recreation. a. Leverage cross-sector funding opportunities. b. Foster public/private partnerships that seek to improve community health and wellness. c. Develop agreements among multi-sector partnerships. 2. Enhance the awareness of health and wellness benefits of outdoor recreation through education and outreach. a. Leverage cross-sector partnerships to maximize education and outreach. b. Promote health benefit awareness through education and/or outreach. c. Target education/outreach to those who may not currently utilize outdoor recreation. d. Develop a dashboard of the health benefits and health-related cost savings of outdoor recreation. 3. Create a safe and welcoming environment that will enhance participation in and enjoyment of the health and wellness benefits of outdoor recreation. a. Develop and implement strategies to reduce overcrowding of recreation areas where this issue impacts the safety and user experience of visitors. b. Rehabilitate natural resources that are damaged or overused and conserve healthy lands and waters. c. Prioritize projects that seek to mitigate user conflicts as recreational goals. d. Advance accessibility by evaluating needs and prioritizing universal design principles. e. Improve equitable access to outdoor recreation opportunities for all communities. 4. Improve access to outdoor recreation for its health and wellness benefits. a. Improve and enhance existing outdoor recreation facilities that positively affect health outcomes. b. Increase the number of developed park spaces to address community need, including local parks, community gardens, and green spaces. c. Improve community connectivity to and between recreation facilities. d. Prioritize projects that address availability of recreational facilities. e. Improve existing and develop new safe and reliable transportation options to outdoor recreation areas.

SCORP 2022- 2026 | Part 4: Implementation Plan

Black Canyon Water Trail

ONGOING AND FUTURE ENGAGEMENT SCORP planning and implementation does not end with the publication of this document. Themes and Issues to Consider for the Next SCORP While this document meets the requirements of a SCORP, there were areas where additional data collection and discussion would have been of benefit based on feedback received. To include these topics in the next SCORP, questions specific to each issue will be developed and included in both the public and land manager surveys. The data collected will be assessed and discussed comprehensively in the document. Topics that were addressed in this SCORP but not discussed in detail will be developed further. Ultimately, a SCORP is an ongoing, iterative tool that supports Nevada in making optimal decisions, and providing exceptional opportunities for outdoor recreation in the Silver State. Synergistic efforts are at the heart of successful and sustainable outcomes. The implementation plan offers various recommendations that will promote ongoing and future engagement including increased coordination between sustainable outdoor recreation and conservation partners, education and outreach, and opportunities to leverage resources.

SCORP 2022- 2026 | Part 4: Implementation Plan

•

Improving facilities and access for OHV users

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Diversity, equity, and inclusion in outdoor recreation

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Private sector perspective of outdoor recreation

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Transportation barriers

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Sensitivity to species/habitat impact of recreation areas

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The importance of data for decision making

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Improving facilities and access for equestrians

Once the 2022-2026 SCORP is published, outdoor recreation participants and partners can expect continuation or commencement of the following initiatives:

Ongoing user surveys Nevada Outdoor Recreation Asset Inventory, Version 2 Nevada Division of State Parks System Plan update Federal/State Shared Stewardship Agreement

Spring Mountain Ranch State Park

As the SCORP runs on a five-year cycle, engagement opportunities will also come in the form of shaping the next SCORP. A statewide, comprehensive plan must be cross-sectoral, and will take time and the commitment to the best thinking on the part of many. Beginning in 2023, NDSP, and NDOR will identify stakeholders, draft the scope of work, and schedule for the 2027 SCORP update with the intention of taking yet another step toward ensuring that Nevada’s outdoor recreation legacy is sustainable.

SCORP 2022- 2026 | Part 4: Implementation Plan

Fort Churchill State Historic Park

Call to Action More than ever before, the 2022-2026 SCORP highlights Nevadans’ need for—and interest in—outdoor recreation, and provides a framework of goals, strategic objectives, and recommendations for how to meet those needs over the next five years. The plan reflects the shared vision and commitment of outdoor recreation and conservation partners to advance opportunities for all people to enjoy Nevada’s natural beauty, unique environments, and the benefits of outdoor recreation. The three overarching themes of this SCORP offer a framework and strategies for collective action on sustainable and responsible outdoor recreation in Nevada. The SCORP provides a roadmap, based on extensive public and land management agency input, that can help guide Nevadans to actively engage in and support the growth of outdoor recreation in our state. No single entity can address all the challenges and opportunities outdoor recreation faces in Nevada. Successful achievement of the goals outlined in this plan will come from working collaboratively across interests, sectors, agencies, and organizations to implement projects

Part Five

supporting meaningful outdoor experiences statewide.

SCORP 2022- 2026 | Part 5: Call To Action

Acronyms ASLO BEA BLM FAST GDP ISTEA LWCF NDCNR NDOR NDOT NDSP NRPA NPS OHV OPSP ORSA RTP SCORP SLO SOA TBC USFWS USFS

Alternate State Liaison Officer Bureau of Economic Analysis Bureau of Land Management Fixing America’s Surface Transportation Act Gross Domestic Product Intermodal Surface Transportation Efficiency Act of 1991 Land and Water Conservation Fund Nevada Department of Conservation and Natural Resources Nevada Division of Outdoor Recreation Nevada Department of Transportation Nevada Division of State Parks National Recreation and Park Association National Park Service Off Highway Vehicle Open Project Selection Process Outdoor Recreation Satellite Account Recreational Trails Program Statewide Comprehensive Outdoor Recreation Plan State Liaison Officer Somersett Owners Association The Blueprint Collaborative U.S. Fish and Wildlife Service U.S. Forest Service

Appendices Appendix A: Appendix B: Appendix C: Appendix D: Appendix E: Appendix F: Appendix G: Appendix H: Appendix I: Appendix J: Appendix K: Appendix L: Appendix M: Appendix N: Appendix O:

SCORP 2022- 2026 | Part 6: Appendices

Source: https://www.statista.com/statistics/184546/community-hospital-beds-per-1000-population-in-the-us/

Community hospital beds per 1,000 population in the U.S. from 2000 to 2019

Hospital beds per 1,000 population

5.3

5.1

4.8

4.7

2.9

2.6 1.9

2.5

2.4 1.7

2.4

1.7

2.4

1.7

1.6

2000

2010

United States

2015

Highest state*

Source Show sources information

Show publisher information

Use Ask Statista Research Service

Release date

2017

Lowest state**

2018

2019

August 2022

Region United States

Survey time period 2000 to 2019

Supplementary notes * 2000: North Dakota; 2010: North Dakota; 2015: DC; 2017: DC; 2018: South Dakota; 2019: South Dakota. ** 2000: New Mexico, Nevada, Oregon, Utah, Washington; 2010: Oregon, Washington; 2015: Oregon, Washington; 2017: Oregon, Washington; 2018: Oregon; 2019: Oregon.

Citation formats View options

Community hospital beds per 1,000 U.S. population 2019 Published by Frédéric Michas, Nov 28, 2022 In 2019, there was an average of 2.4 beds per 1,000 persons in the United States. The state with the highest share of community hospital beds was South Dakota, whereas the lowest share was found in Oregon. This statistic shows the number of community hospital beds per 1,000 population in the United States, from 2000 to 2019.

910 000 E

900 000 E

890 000 E

880 000 E

870 000 E

GRID

MAG

EX. POWER LINE

75 00

77 50

80 00

8250

7500 77 5500 800 0

7250

70 00

6750

6500

US HIGHWAY 93

0 825

6250 6250

PERMANENT SPOIL DISPOSAL

LOWER RESERVOIR (SEE DWG LRSRV-DR-CI-0001)

LOWER RESERVOIR STAGING AREA

UPPER RESERVOIR OPTIONAL ACCESS ROAD

WESTERN ACCESS ROAD

EX. OVERHEAD POWER LINE, TYP.

7500

7750

750 0

7000

67 50

6500

62 50

50 82

50 72

MAIN CONSTRUCTION LAYDOWN AREA (OFFICES, PARKING, EQUIPMENT AND MATERIAL DELIVERY)

7500 7750 800 0

WESTERN ACCESS ROAD NNR HILINE CROSSING

WHITE PINE COUNTY ROAD 29 NV-486

0 800

WESTERN ACCESS ROAD NNR MAINLINE CROSSING

UNDERGROUND COMPLEX (SEE DWG PWIDE-DR-GA-0006)

ACCESS AND CABLE TUNNEL PORTAL

UPPER RESERVOIR LAYDOWN

UPPER RESERVOIR (SEE DWG URSRV-DR-CI-0001)

24.9 kV OVERHEAD DISTRIBUTION LINE (SEE DWG TRLNE-DR-EL-0150) EXPLOSIVE STORAGE WELL 4

UNDERGROUND LAYDOWN AREA SWITCHYARD (SEE DWG SUBST-DR-EL-0100)

EXISTING DISTRIBUTION LINE, TYP.

27 930 000 N

82 5

27 930 000 N

80 00

UPPER RESERVOIR WELL (WELL 5)

345 kV OVERHEAD TRANSMISSION LINE (SEE DWG TRLNE-DR-EL-0100)

775

TAILRACE TUNNEL (SEE DWG WTRWY-DR-CI-0140)

UPPER RESERVOIR LAYDOWN

CABLE TUNNEL (SEE DWG TUNLS-DR-CI-0110)

EXISTING GONDER SUBSTATION

775

8500

850

8750

80 00

8000

8250

8750

900

Upper Reservoir Access Road Material Handling Area (South of Access Road) 90 900 0 0 0 900

27 920 000 N

8500

8750

8500

8250

South Upper Reservoir Laydown (South of Upper Reservoir) 8250

North Upper Reservoir Laydown (North of Upper Reservoir)

7750

6750

8000

7750

0 800

50 77

Underground Laydown Area (South of Switchyard and MAT Portal) 7

8000

8500

Lower Reservoir Staging Area (South of Lower Reservoir) 0

8250

8000

0 775

Permanent Spoil Disposal Site (West of Lower Reservoir)

7500

6500

0 700

72 50

WELL 2

750 0

7000

6750

6500 6250

0 625 27 920 000 N

50 67

875

UPPER RESERVOIR ACCESS ROAD (SEE DWG ACCSS-DR-CI-0120)

UPPER RESERVOIR ACCESS ROAD NNR HILINE CROSSING

EXISTING NEVADA NORTHERN RAILWAY MAINLINE (INACTIVE)

850

AREAS IDENTIFIED FOR PLACEMENT OF EXCESS MATERIAL 50 850

WELL 3

500 88500

8250

EX. UNPAVED ROAD, TYP.

00 80

NEVADA NORTHERN RAILWAY HILINE (ACTIVE)

7750

625

MAIN ACCESS TUNNEL (SEE DWG TUNLS-DR-CI-0100)

CRITICAL ENERGY INFRASTRUCTURE INFORMATION EXHIBIT No. F-104

PROJECT DWG No. PWIDE-DR-GA-0005

WHITE PINE PUMPED STORAGE PROJECT

900 000 E

890 000 E

880 000 E

GENERAL ARRANGEMENT

WATER POWER,LLC LLC WHITE PINE WATERPOWER, DATE: JANUARY, 2023

PLAN

750'

1"=1500'

3000'

SCALE: 1" = 1500'

910 000 E

MAIN WORKS

WELL 1 870 000 E

C:\Users\COM105550\ACCDocs\Mott MacDonald\WPINE\Project Files\02 - Design (Work in Progress)\GA - General\04 - Drawings (DR)\104181-MMD-WPINE-PWIDE-DR-GA-0005.dwg

WELLFIELD CONVEYANCE PIPELINE

FERC No. 14851 PREPARED BY: MOTT MACDONALD

White Pine Waterpower, LLC Cynthia Bardman [c/o] rPlus Hydro, LLLP 201 S Main St, Suite 2100 Salt Lake City, UT 84111 June 26, 2023 Revised July 16, 2023 Nevada Division of Environmental Protection Attn: Birgit Widegren, Nonpoint Source Branch Supervisor Attn: Dave Simpson, Branch Supervisor Water Quality Standards, Assessment, Monitoring and Bioassessment 901 S. Steward Street, Suite 4001 Carson City, Nevada 89701 Re:

White Pine Pumped Storage Project (FERC No. 14851) White Pine County, Nevada Request for Coastal Zone Management Area Consistency Determination

Dear Mr. Simpson, White Pine Waterpower, LLC’s (WPW), White Pine Pumped Storage Project (Project) is a proposed 1,000-megawatt (MW), closed loop, pumped storage hydropower facility with approximately 2,150 feet of maximum gross head. The proposed Project will have the capacity to store and subsequently generate electricity for up to 8 hours per day (8,000 MWh/day). The Project features will include two reservoirs interconnected by underground waterways that pass through an underground powerhouse complex that includes a generator step-up (GSU) transformer cavern. Access, cable routing, and ventilation to the powerhouse complex will be by two separate tunnels leading from the surface. The proposed interconnection transmission line will extend from a new switchyard located outside of the tunnel portal to the existing Robinson Summit Substation via a new 25-milelong 345-kilovolt (kV) generation tie-line located predominantly within the 110-114 Corridor of the Section 368 Region 3 Energy Corridor. New construction and operation phase access roads to the upper and lower reservoirs and tunnel portals would also be established. The Project will be located approximately 8 miles northeast of the City of Ely in White Pine County, Nevada, largely on public land administered by the U.S. Bureau of Land Management (BLM). Pumped storage projects move water between reservoirs located at different elevations (i.e., an upper and a lower reservoir) to store and generate electricity. Generally, when electricity demand is low, excess electric generation capacity in the grid is used to pump water from the lower reservoir to the upper reservoir. When electricity demand is high, the stored water is released from the upper reservoir to the lower reservoir through a turbine to generate electricity. A closed-loop pumped storage project is generally defined as a pumped storage project that utilizes reservoirs situated at locations other than natural waterways, lakes, wetlands, and other natural surface water features, and may rely on temporary withdrawals

Page 2 of 2

June 23, 2023

Nevada DEQ

from surface waters or groundwater only for the purposes of initial fill and of the periodic recharge needed for project operation. This Project will be a closed-loop facility. Additional project details, including the Final License Application submitted to the Federal Energy Regulatory Commission on February 27, 2023, can be found on the project website at www.whitepinepumped storage .com. As shown on the map below, Nevada does not contain coastal zones. Nevada is not included on the National Oceanic and Atmospheric Administration list as a State with an existing Coastal Zone Management Program. Hence, we believe the proposed activity complies with the enforceable policies of the State of Nevada as it relates to coastal zone management policies. Please provide a Coastal Zone Management Area Consistency Determination for this project. Should you have any questions please contact me at cbardman@rplusenergies.com or (484) 357-5131. Sincerely, Cynthia Bardman Senior Permitting Manager

Coastal Zones of the U.S.