2011-10-03_APPLICATION CORRESPONDENCE - C1981015

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McClane Canyon Mine Expansion and Fruita Loadout Facility Biological Assessment Cumulative Effects. As discussed above for Colorado pikeminnows, no State, tribal, local, or private actions are reasonably certain to occur within Reed Wash and the 100 -year floodplain. Other potential cumulative effects associated with human population growth in Garfield and Mesa counties are expected to generate cumulative effects to razorback suckers, as discussed above for Colorado pikeminnows. 4.3.2.4 Conservation Measures The same conservation measures that were proposed to avoid or minimize effects by the Proposed Action to Colorado pikeminnows and critical habitat in Reed Wash and the 100 -year floodplain would benefit conservation of razorback suckers. 4.3.2.5 Determination of Effects Species Effects. The Project may affect razorback suckers because: • Razorback suckers are likely to occur within the Colorado River, within Reed Wash, and within designated critical habitat in the Action Area. The Project is not likely to adversely affect razorback suckers for the same reasons identified for Colorado pikeminnows, above. Briefly, the reasons include 1) lining proposed sediment ponds at the Mine and Loadout Facility to prevent seepage of water and dissolved constituents and mobilization of contaminants in pond substrates into East Salt Creek and Reed Wash, 2) preventing discharge of water with selenium concentrations exceeding numeric standards 3) removing water from sediment ponds at the Loadout Facility and disposal off -site, 4) control of fugitive coal dust at the Loadout Facility, 5) installing a deck on the railroad bridge across Reed Wash, 6) avoiding driving pilings in the water column, 7) utilizing BMPs to minimize sedimentation and contaminant load in surface water, and 8) avoiding application of herbicides potentially toxic to fish near surface waters. The Project is likely to adversely affect razorback suckers because: • Water withdrawal from the Colorado River and /or from aquifers connected to the river by the Proposed Action would adversely affect razorback suckers. However, the amount of water depleted annually by the Proposed Action is Tess than 100 acre - feet and a contribution to the species' recovery would be waived. Critical Habitat Effects. The Project may affect razorback suckers' designated critical habitat because: • Designated critical habitat for razorback sucker is present within the Action Area, and the project would physically alter 0.124 acre of critical habitat within the 100 -year floodplain in Reed Wash. The Project is not likely to adversely affect razorback suckers critical habitat for the same reasons identified for Colorado pikeminnows, above. Briefly, the reasons described include 1) insignificant amount of physically altering the 100 -year floodplain, 2) the railroad bridge would not be flooded or cause avulsion during the 100 -year flood, 3) no bridge pilings are within the OHWM of Reed Wash, 4) effects to water quality PCE by multiple causes have been minimized, 5) BMPs would minimize sedimentation and contaminant loads in surface water, and 6) potentially toxic herbicides would not be used near the 100 -year floodplain. The Project is likely to adversely affect razorback sucker critical habitat because: • Water withdrawal from the Colorado River and /or from aquifers connected to the river by the Proposed Action would adversely affect critical habitat designated for razorback suckers. 31