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<br />increased erosion, increased runoff, increased soil surface strength, reduced plant
<br />production, inhibition of seed germination, impairment of root penetration and '
<br />growth, alteration in plant succession, reduced soil permeability to air and water,
<br />reduced soil moisture, reduction in soil depth and organic matter, reduction of _
<br />groundwater rechazge, alteration of hydrological flows, reduced nutrient cycling, '
<br />increase in heat conductivity and a decrease in heat capacity of soil, and
<br />augmentation of colonization by exotic species (Iverson et al. 1981, Wilshire and
<br />Nakata 1976, Sheridan 1979, Manning 1979, Wilshire et al. 1977, Mortenson '
<br />1989, Peters 1972, Veihmeyer and Hendrickson 1948, Buckman and Brady 1969,
<br />Shul'gin 1965, Beny 1980, Griggs and Wash 1981, Stebbins 1974, Eckert et al.
<br />1979, Liddle and Moore 1974, Liddle 1975, Liddle and Grieg-Smith 1975, Brown '
<br />et al. 1977, Weaver and Dale 1978, Kuss 1986, Hall and Kuss 1989, Kuss and
<br />Hall 1991, Leung and Marion 1996). These impacts aze both short and long
<br />term... (Schubert & Associates 1999, pp. 32-33). ,
<br />In fact, the effects of seismic exploration are long-lasting, and may persist for 50-300 years after
<br />activity ceases (Bureau of Land Management, Moab Field Office 2002; Belnap 2002). Two
<br />separate studies were undertaken to analyze the effect that one vibroseis truck making one pass
<br />on one day would have on the arid landscape, and the results were similar. (Menkens and '
<br />Anderson 1985; Young and Sawyer 1981). The flattening and crushing of the vegetation in the
<br />path of the truck maybe long lasting, and recovery will be slow. In each of these studies, only
<br />one truck was used, but multiple vehicles will be used in the proposed project. The BLM must '
<br />consider the profound environmental impacts that soil compaction may have on listed and
<br />Sensitive plant species. Specifically, the BLM should consider the effects that vehicles will have
<br />on the soil, and identify mitigation measures to reduce these effects. '
<br />5. BLM Must Consider the Impacts to Sensitive Soils and Biological Soil Crusts '
<br />The BLM must survey for sensitive soils to determine the extent to which they exist in the
<br />project area. The BLM must also undertake field sampling and surveying at representative '
<br />points within the project area to determine whether biological soil crusts occur in the azea. If
<br />biological soil crusts do occur in the project area, the BLM must take into consideration the
<br />impact that the proposed project may have on these soil crusts and develop measures to minimize '
<br />or eliminate this impact.
<br />6. Surface Disturbances and Vehicular Activity Facilitate Weed Establishment and '
<br />Dispersal
<br />The proposed project and its associated activities will likely have negative indirect effects on rare '
<br />plants by way of leaving the area vulnerable to establishment of nonnative species. There are two
<br />general elements of this project that will increase the likelihood that noxious weeds will be
<br />introduced into the project azea: vehiculaz traffic and surface disturbing acitivities. Should '
<br />noxious weeds be introduced within the project area, they could put healthy native plant
<br />communities, including habitats for sensitive plant species, at risk of invasion.
<br />Center for Native Ecosystems Page IO of 24 '
<br />Scoping Comments for the Proposed Red Cliff Coal Mine
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