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Responses to Questions Raised from Original Biological Assessment Dudley Bluffs bladderpod and Dudley Bluffs twinpod To clarify the reasoning for further plant surveys within the mining panels, please refer to the first 3 full pazagraphs on page 4-62 of the Draft EIS. Because of the patch}', discontinuous distribution of suitable habitat on the lease site (i.e., outcrops of the Thirteerunile tongue of the Green River formation) and the assumption that the plant populations ar•e operating as a metapopulation, BLM intends to require the inventory of interspersed and unoccupied but otherwise suitable habitat for the appearance of plants (i.e., recolonization of vacant habitat) over the life of the mine. The preliminary fmal draft of the EIS reiterates the mitigation presented on page 4-69 and 4- 70 of the Draft EIS (Section 4.10.3 Mitigation and Monitoring) as integral with the Agency Preferred Alternative. Pararhute penstemon and Uinta Basin hookless cactus Similaz to the discussion above, surveys would be conducted this field season to inspect those portions of the pipeline that have not been surveyed for these species. The mitigation presented in the draft EIS on page 4-71 (last two bullets before section 4.10.4) will be carried forwazd into the Agency Preferred Altemative of the Final EIS. Listed Plant Summary Although it is possible that individual plants or small colonies of listed plants have or will be overlooked during surveys and such plants would be vulnerable to direct or indrrect impacts associated with mine activity, BLM feels every reasonable effort has been extended to develop a thorough and accurate inventory of plant occurrence now and through mime life. Based on the application of protective mitigation, we believe our analyses continue to indicate that the proposed action would be unlikely to adversely affect these listed plants (i.e., "may affect, but unlikely to adversely affect"). r1 LJ