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not get a cultural resources survey due to snow and road conditions and will be deferred until if <br />and when a survey can be completed and a determination on the sites potential effects to cultural <br />resources can be made. For the 11 sites surveyed, a no effect determination was made. A copy <br />of the cultural resource action memorandum is in the file. <br />3. Is existing analysis adequate in light of any new information or circumstances (such as, <br />rangeland health standards assessment; recent endangered species listings, updated list of <br />BLM sensitive species)? Can you reasonably conclude that new information and new <br />circumstances would not substantially change the analysis of the new proposed action? <br />Yes, the analysis is accurate. No new range health standards; endangered species listings, or <br />updated BLM sensitive species have been identified since the exploration license was approved. <br />4. Are the direct, indirect, and cumulative effects that would result from implementation of <br />the new proposed action similar (both quantitatively and qualitatively) to those analyzed in <br />the existing NEPA document? <br />Yes. The kind of disturbance and resulting impacts would be the same and within the same <br />exploration license boundary. This action does not amend the boundaries or duration of the <br />exploration license. Eleven new drill holes would be added. Each drill hole would require a <br />100x100 foot area. Table 1 shows the calculated disturbance acreage. <br />Table Z: Disturbance Acreage Calculation <br />2018 <br />New <br />(100 ft x 100 ft) x 11 holes= 110,000 ft. 1 acre= 43560 ft2. 110,400 ft2 <br />43,560 ft2 = 2.5 Acres <br />Total <br />2.5 Acres 2018 + 5.3 Acres 2017 = 7.8 Acres Total <br />Total disturbance from the project as amended (2017 2018) is estimated at 7.8 acres. No <br />statutory, regulatory or resource issues were identified that would have been any issues that <br />would have prevented the total project disturbance area from being approved under an EA, had <br />the amended proposal been analyzed all at once. The scope of the project would not have caused <br />any issues not identified in the original document. The indirect impacts would be the same. <br />Information derived from exploration could be used to inform future leasing actions, but any <br />additional leasing actions would require their own separate NEPA analysis. A separate cultural <br />resource inventory will be performed for hole GCC -18-12, which could not be accessed due to <br />conditions. If no cultural resources issues are identified it is anticipated that that site could also <br />be drilled, pending NEPA analysis or determination of NEPA adequacy. <br />5. Are the public involvement and interagency review associated with existing NEPA <br />document(s) adequate for the current proposed action? <br />Yes. Scoping letters were sent to the UMU tribe (the majority surface owner), other surface <br />estate owners, adjacent landowners, and other expressly interested parties. A total of 33 scoping <br />letters were sent out, in addition to appearing in the Tres Rios NEPA log. The following issues <br />were identified as a result of scoping. There have been no changes to the project that would have <br />any effect on concerns raised by public scoping respondents that were not addressed in the <br />original EA. 26 Native American Tribes were consulted on this project, but only 3 replied to <br />GCC Alinor Exploration Plan Amendment DOI-BLM-CO-S'070-2018-0014-DNA <br />COC -76563 Tres Rios Field Office <br />