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<br /> <br />appeazs that cumulative impacts analyses should be undertaken for the following resources: <br />surface waters (quality, quantity and aquatic habitat), wetlands, local and regional air quality and <br />wildlife habitat. The purpose of a cumulative impacts analysis is to assess the incremental <br />impacts on each resource of concern.due to connected and unconnected actions that take place in <br />a geographic azea over time (i.e., past, present and future) no matter which entity (public or <br />private) undertakes the actions. A cumulative impacts analysis aids in identifying the level of <br />significance of those impacts on a particular resource and the appropriate type and level of <br />mitigation required to offset the project's contribution to these impacts. In the analysis of present <br />and reasonably foreseeable future actions, it is appropriate to examine anticipated activity trends <br />in the study azea, not just already approved "on-the-ground" projects. Examining activity trends <br />in other azeas with similar uses and contributory metrics can also be useful in this analysis. Also, <br />the appropriate azea of consideration and the time frame to use when assessing cumulative <br />impacts will vary for each resource under consideration. <br />3. Protecting wetlands and riparian areas and associated ecosystems. <br />Impact to wetland and ripazian areas may occur for this project. Possible impacts include , <br />damage or improvement to: water quality, habitat for aquatic and terrestrial life, channel and <br />bank stability, flood storage, ground water rechazge and dischazge, sources of primary <br />production, and recreation and aesthetics. Facility, road, railroad, and pipeline construction, land <br />clearing and earthwork generally include sedimentation and hydrologic impacts which at some <br />level may cause changes to surface and subsurface drainage patterns and, ultimately, wetland <br />integrity and function. Riparian habitats, similaz to wetlands, aze important ecological azeas <br />supporting many species of western wildlife. <br />` <br />` <br />" ', <br />signed in 1978 and amended in 1988, <br />Executive Order 11990, <br />. <br />Protection of Wetlands, _ <br />addresses potential long and short-term adverse impacts associated with the destruction or <br />modification of wetlands. In accordance with the intent of this order, EPA suggests a mitigation <br />commitment that indirect draining of, or direct disturbance of, wetland azeas will be avoided if at <br />all possible, and a commitment to replace in kind such unavoidably impacted wetlands. As <br />studies indicate that traditional mitigation is generally not successful in, fully restoring wetland , <br />function, it is suggested that the BLM require a two-to-one mitigation of wetland disturbance. <br />Bue to the time it can take to adequately reclaim some disturbed wetlands, and the potential life <br />of this project, it is suggested that mitigation of wetland disturbance occur during the project <br />operating time, and that mitigation for any particulaz wetland or ripaziari area begin concurrent <br />with the disturbance. The mitigation ratios may need to be increased to compensate for the <br />temporal loss of wetlands. Wetlands will cease to function during the 10 to 20 years of mining. ' <br />However, wetlands fed by groundwater will not regain function until the ground water table <br />recovers. We recommend that additional mitigation be established to compensate for the long- <br />term loss of wetland values. EPA also suggests that the BLM require complete avoidance of <br />disturbance to any fen wetland (a Category I resource). The EIS should recognize that dischazges <br />of fill material into certain wetlands and other waters of the United States subject to Clean Water <br />Act (CWA) jurisdiction aze regulated by Section 404 of the Clean Water Act, 33 U.S.C. 1344. <br />2 , <br /> <br />