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CUMO EXPLORATION PROJECT

Wolverine Addendum to the Wildlife Specialist Report and Biological Evaluation for Threatened, Endangered, and Sensitive Terrestrial and Avian Species for the

CuMo Exploration Project

August 2013

Submitted by

Idaho CuMo Mine Corporation

c/o Parsons Behle & Latimer

960 Broadway Avenue, Suite 250

Boise, Idaho 83706

Submitted to

United States Forest Service

Boise National Forest

Idaho City Ranger District

1249 S. Vinyl Way

Suite 200

Boise, Idaho 83709

Prepared by

Enviroscientists, Inc. 1650 Meadow Wood Lane

Reno, Nevada 89502 Phone: (775) 826-8822

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IDAHO CUMO MINING CORPORATION

Wolverine Addendum to the Wildlife Specialist Report and Biological Evaluation

for Threatened, Endangered, and Sensitive Terrestrial and Avian Species

for the CuMo Exploration Project

INTRODUCTION

Enviroscientists, Inc. (Enviroscientists) was retained by Idaho CuMo Mining Corporation (CuMoCo), formerly known as Mosquito Consolidated Gold Mines Limited (MCGM) to complete an addendum to the Wildlife Specialist Report and Biological Evaluation for Threatened, Endangered, and Sensitive Terrestrial and Avian Species for the CuMo Exploration Project (USDA FS 2010) for the CuMo Exploration Project (Project).

The distinct population segment (DPS) of the North American wolverine occurring within the contiguous United States (US) was proposed for listing as a threatened species under the Endangered Species Act (ESA) by the United States Fish and Wildlife Service (USFWS) on February 4, 2013 (78 Federal Register [FR] 7864). The wolverine is also currently listed as a United States Forest Service (USFS) Intermountain Region (R4) proposed species (list updated February 2013) by the United States Department of Agriculture (USDA). This Addendum (hereinafter Addendum) will address Section 7 consultation requirements for the change in status of the wolverine by updating the wildlife specialist and biological evaluation report prepared by Brown and Caldwell (USDA FS 2011a) to disclose effects to the wolverine from the proposed action. Within this Addendum, any updated information on the species’ life history, threats, or occurrence will be incorporated.

The baseline, project description, and effects have not changed from those disclosed in the original wildlife specialist and biological evaluation report, dated February 2011 (Wildlife Specialist Report and Biological Evaluation for Threatened, Endangered, and Sensitive Terrestrial and Avian Species for the CuMo Exploration Project, 2011, in the Project Record) (USDA FS 2011a).

This Addendum evaluates and discloses the effects to the contiguous US wolverine DPS from the Project located in the Idaho City Ranger District, Boise National Forest (NF), in Boise County, Idaho. The aforementioned Addendum is in accordance with the Forest Service Manual Direction (FSM 2672.4) to review all planned, funded, executed, or permitted programs, and activities for possible effects on endangered, threatened, or proposed species. The updated effects analysis for the wolverine has determined that the Project will not likely jeopardize the continued existence of the wolverine.

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2 PROJECT HISTORY

On February 14, 2007, CuMoCo submitted a new Plan of Operations (Plan) to the USFS for the CuMo molybdenum prospect. The USFS accepted the Plan on March 5, 2007, as sufficient for processing, and determined an Environmental Assessment (EA) would be required pursuant to the requirements of the National Environmental Policy Act of 1969 (NEPA). Brown and Caldwell prepared the 2010 Wildlife Specialist Report and Biological Evaluation for Threatened, Endangered, and Sensitive Terrestrial and Avian Species Report (hereinafter the 2010 Wildlife Report) (USDA FS 2010) in support of the EA. The 2010 Wildlife Report analyzed the potential impacts to terrestrial and avian wildlife species that may have occurred within the Project Area. At the time, the wolverine was listed as a R4 sensitive species by the USFS and had potential to occur within the Project Area; therefore, potential impacts were analyzed for the species in the 2010 Wildlife Report.

Brown and Caldwell prepared an updated version of the 2010 Wildlife Report (hereinafter the 2011 Wildlife Report) (USDA FS 2011a) which superseded the previous report. Two factors influenced the revision of the 2010 Wildlife Report: 1) a change in direction of the 2003 National Forest Land and Resource Management Plan (2003 Forest Plan) (USDA FS 2003) that resulted in the Wildlife Technical Report for the 2010 Boise National Forest Plan Amendment to Implement a Forest Wildlife Conservation Strategy (Nutt et al. 2010a) and the 2010 Addendum to the 2003 Boise National Forest Plan Biological Assessment and Biological Evaluations (Nutt et al. 2010b), and 2) a change in status of the wolverine.

The Wildlife Technical Report for the 2010 Boise National Forest Plan Amendment to Implement a Forest Wildlife Conservation Strategy, dated June 2010, served as the framework for the Boise NF’s Wildlife Conservation Strategy (WCS) (Nutt et al. 2010a). The findings in the June 2010 report were used to amend the 2003 Forest Plan for the Boise NF and serve as a baseline for selected USFS species (focal species) through the incorporation of a revised modeling approach (Nutt et al. 2010a). The wolverine was selected as a focal species, and the revised modeling approach incorporated ‘new science’ in the use of persistent snow to identify source habitat for the wolverine and replaced previous models based on vegetative groups (Nutt et al. 2007, Nutt et al. 2010a). Persistent snow modeling (‘new science’) was also incorporated into the June 2010 Addendum to the 2003 Boise National Forest Plan Biological Assessment and Biological Evaluations report (Nutt et al. 2010b). Thus, the “new science” model and the subsequent change in status of the wolverine to a Candidate species in the FR (75 FR 78030) published on December 14, 2010, facilitated the revision of the 2010 Wildlife Report.

2.1 Project Area Description

The Project area is the same as described in the 2011 EA for the Project (USDA FS 2011b). The Project is approximately five miles upstream of Pioneerville, Idaho and about 14 miles north of Idaho City in Boise County, Idaho (Figure 1) (Project Area). The Project Area encompasses approximately 2,885 acres of land located within the Boise NF in Sections 7, 8, 17, 18, 19 and 20, Township 8 North, Range 6 East1. The Project Area was modified to exclude the road corridor surrounding National Forest System (NFS) Road 382C. The modified Project Area

1 In scoping materials distributed in July 2007, the Project Area was described as encompassing approximately 1,200 acres. The Project Area was later expanded to better encompass the area within which the Proposed Action would occur. The EA distributed for 30-day notice and comment in July and August 2010 reflected the larger Project Area.


IDAHO CUMO MINING CORPORATION CUMO EXPLORATION PROJECT WOLVERINE ADDENDUM

encompasses approximately 2,848 acres and includes about 2,560 acres of NFS land and 288 acres of private land (Figure 2).

The Project Area, which is approximately two miles along its east-west axis and 2.4 miles along the north-south axis, lies within the Headwaters Grimes Creek 6th hydrologic unit code (HUC) (170501120502) of the Boise-Mores sub-basin. The Boise-Mores sub-basin is bounded by Grimes Creek to the north, Jackson Peak ridgeline to the south, and County Road (CR) 382 to the west. The Project Area can be accessed via two routes. One is by way of CR 307 and CR 382 north from Idaho City; this route passes through Centerville and Pioneerville along Grimes Creek. The second route is southeastwardly from Garden Valley by way of CR 382; this route follows the Banks-Lowman Highway (State Highway 17; Forest Highway 24) along the south bank of South Fork Payette River and Sweet Creek. The FS has granted Boise County jurisdiction on CRs 382 and 307 via a Forest Roads and Trails Act public road easement. Within the subwatershed, the Project Area is at present accessed eastwardly from the Grimes Pass area by NFS Roads 397 and 397B, although NFS Road 397B is currently gated just beyond the Grimes Creek trailhead (NFS Trail 169). NFS Road 397B joins with the existing network of currently unauthorized roads within the Project Area. The proposed operations would have access eastwardly from Grimes Creek by way of NFS Roads 380F, 382B, 382C and 382C4. These roads would join with the temporary road network proposed for this Project (USDA FS 2011b).

2.2 Purpose and Need

The following Purpose and Need discussion was taken from the 2011 EA for the Project (USDA FS 2011b).

“Mosquito needs to acquire detailed geologic data within the CuMo molybdenum prospect in order to determine the extent of mineral resources. The purpose of the project is to retrieve core samples from within the projected mineral deposit so that Mosquito can extract geologic data. The operator needs surface access to the proposed drill pad locations so that drill rigs can be set up, maintained, and operated. Mosquito is entitled to conduct operations that are reasonably incident to exploration and development of mineral deposits on its unpatented mining claims pursuant to the United States mining laws. Under regulations of the Secretary of Agriculture, Mosquito must conduct mining operations in accordance with regulations at 36 CFR 228A and with a PoO that has been approved by the FS. The need for the proposed federal action is that the FS is required to respond to a proposed PoO to conduct exploration operations pursuant to the mining laws.

Under 36 CFR 228.5, the FS must determine whether to approve the Plan submitted by Mosquito as it is proposed, or to require changes or additions deemed necessary to meet the requirements of the regulations for environmental protection. The purpose of the proposed action and evaluation of alternatives of the proposed action are to determine if changes or additions to the Plan are needed to meet the requirements of the regulation for environmental protection set forth in 36 CFR 228.8. In addition, a No Action Alternative is provided as a baseline from which to evaluate the environmental effects of the action alternatives.”



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2.3 Proposed Action

The EA was prepared for the Proposed Action for the Project with the following alternatives analyzed: Alternative A – Proposed Action, Alternative B – Reduced Roads and Alternative C – No Action (USDA FS 2011b). Table 1 provides a summary of key features for each alternative as described in the 2011 Wildlife Report (USDA FS 2011a) and the Project EA (USDA FS 2011b).

Table 1: Summary of Key Features of Each Alternative in Project Area for the Project

Activity Alternative A Proposed Action Alternative B Reduced Roads

Alternative C No Action

Proposed New Drill Pads (no.) 122 137 0

Proposed New Drill Holes (no.) 256 259 0

Proposed New Temporary Roads (miles) 13.3 10.2 0.0

Temporary/Unauthorized Roads* (maximum miles in short-term)

18.0 14.09 4.7

Temporary/Unauthorized Roads* (miles in long term)

0 0 0

Existing NFS Roads** (miles in long term) 7.1 7.1 7.1

Total Roads (NFS, unauthorized, and temporary miles)

Short-term 25.1 Long-term 7.1



*Considered “temporary roads” under Alternatives A and B and “unauthorized roads” under Alternative C because the extended 2005 PoO (Plan of Operations) has now expired. For the purposes of this table, “short-term” is during exploration period (1-5 years); “long term” is after reclamation period (1-2 years after five year exploration period). ** NFS roads 382C and 397B.

The USFS issued a Finding of No Significant Impact (FONSI) and Decision Notice (DN), selecting Alternative B (USDA FS 2011c). Alternative B was developed to address the major issue identified during scoping: namely, the extent of proposed temporary roads and resultant concern over potential erosion and sedimentation to Grimes Creek (USDA FS 2011b).

The following discussion of Alternative B is taken from the Project EA (USDA FS 2011b). Under Alternative B, up to 10.2 miles of new temporary roads would be constructed, involving four new stream crossings (total of 16 stream crossings), along with up to 137 drill pads and up to 259 drill holes. The reduction in road miles includes the elimination of 0.62 mile of new temporary road that would be constructed under Alternative A. (For further descriptions of Alternative A-C please refer to the Final EA, USDA FS 2011b).

As part of the Supplemental EA process, a mitigation measure is being added to Section 2.3.3 (Terrestrial and Avian Wildlife) of the EA. This mitigation measure addresses the potential for



direct effects (mortality and disturbance effects) to an occupied natal den in the Project Area. The mitigation feature is as follows:

In the event that an occupied wolverine natal den is discovered in the modified Project Area, the District Wildlife Biologist for the Idaho City Ranger District, Boise National Forest will be immediately notified. Disturbance activities near the den site will be evaluated by the District Wildlife Biologist and those activities that have been demonstrated to affect denning will be suspended from April 15 - May 15 to ensure that the natal den and occupying wolverine are not disturbed. Disturbing activities include, but may not be limited to, actions associated with temporary road construction and maintenance activities (snow plowing, blading, etc.), temporary drill pad construction and operation, and support traffic.

There are no changes to any of the Alternatives analyzed, nor the Alternative Selected in the DN.

2.4 Consultation History

Informal consultation with the USFWS occurred in response to the status change of the wolverine. The wolverine was designated a Candidate species for federal listing under the ESA on December 14, 2010 (75 FR 78030). The 2011 Wildlife Report, finalized February 2011, included the wolverine in the effects analysis and determined that potential impacts from the Proposed Action “may impact individual wolverines but are not likely to contribute to a trend towards federal listing or cause a loss of viability to the population or species” (USDA FS 2011a).

Following the listing of the contiguous US wolverine DPS as a Proposed species under the ESA on February 4, 2013 (78 FR 7864), the change in status triggered conferencing with the USFWS.


3 SPECIES ANALYZED – WOLVERINE (PROPOSED)

3.1 Background for Proposed Listing

The first petition to list the wolverine as a Threatened or Endangered Species in the contiguous US was received by the USFWS in 1994 and in 2000. The findings published in 1995 (60 FR 19567) and 2003 (68 FR 60112), respectively, stated the petitions failed to present “substantial scientific and commercial information indicating that listing may be warranted.” On March 11, 2008, the USFWS published a 12-month finding of “not warranted” for wolverine in the contiguous US in response to an earlier court-ordered reassessment of the wolverine. This finding was based on the determination that wolverine in the contiguous US did not constitute a DPS or a significant portion of the range of a listable entity of the wolverine in North America and so was not a listable entity under the Act (78 FR 7865). However, following additional litigation taken against the USFWS in 2008 and 2009 that resulted in a settlement agreement, a new 12-month finding for wolverine in the contiguous US constituted a DPS and that the DPS warranted listing under ESA, but that listing was precluded by higher priority listing actions (75 FR 78030). At this time, the contiguous US wolverine DPS was listed as a Candidate species in the FR. Following continuous monitoring of the wolverine’s status, including new information regarding wolverine biology and identifiable risks to the species, particularly in the realm of climate change, the USFWS published a rule to propose that the contiguous US wolverine DPS be listed as a Threatened species under the ESA on February 4, 2013 (78 FR 7864) (USDA FS 2013).


4 ENVIRONMENTAL BASELINE

The following discussion for wolverine source habitat requirements was taken from the Upper Middle Fork Payette River Project (USDA FS 2013).

4.1 Source Habitat Requirements

Source habitats for wolverine include alpine tundra and all subalpine and montane forests (Aubry et al. 2007). Within forest types, all structural stages except the closed canopy stem exclusion stage provide source habitat (Wisdom et al. 2000). Primary habitat during winter is mid-elevation conifer forest and summer habitat is subalpine areas associated with high-elevation cirques (Copeland 1996). Summer use of high-elevation habitats is related to the availability of prey and den sites and possibly human avoidance. In the southern extent of the wolverine’s range, which includes Central Idaho, wolverine avoid warm summer temperatures by remaining at higher elevations that retain cooler temperatures, and select areas with regular deep persistent snow maintained into the late warm season for denning habitat (Copeland et al. 2010). In Central Idaho, home ranges for females averaged nearly 95,000 acres, while male home ranges averaged over 376,000 acres (Copeland 1996). Wolverines show strong intrasexual non-overlap in territories but extensive intersexual overlap (Inman et al. 2007, Heinemeyer et al. 2010).

Key wolverine habitat features include talus slopes, boulder fields, beaver lodges, old bear dens, fallen logs, root wads of fallen trees, and large cavities used for den sites. Vegetation modeling, namely potential vegetative groups (PVGs), canopy cover, and tree size class were the primary parameters used to previously identify wolverine source habitat (Nutt et al. 2007, USDA FS 2010). However, research by Aubry et al. (2007) and Brock et al. (2007), found that all of the areas in the lower 48 States for which good evidence of persistent wolverine populations exists (i.e., Cascades, Sierra Nevada, northern and southern Rockies) contain large and well-distributed areas with deep snow cover that persists through the wolverine denning period. Hence, updated MODIS (Moderate-Resolution Imaging Spectroradiometer) modeling by Copeland et al. (2010) determined that persistent spring snow cover (April 15 to May 14) is the best overall predictor of wolverine occurrence.

Snow cover during the denning period is essential for successful wolverine reproduction range-wide (Hatler 1989, Magoun and Copeland 1998, Inman et al. 2007b). Wolverine dens tend to be in areas of high structural diversity such as logs and boulders with deep snow (Magoun and Copeland 1998, Inman et al. 2007b). Reproductive females dig deep snow tunnels to reach the protective structure of logs and boulders where they produce offspring. This behavior presumably protects the vulnerable kits from predation by large carnivores, including other wolverines (Pullianen 1968, Zyryanov 1989), but may also have physiological benefits for kits by buffering them from extreme cold, wind, and desiccation (Pullianen 1968). Denning activities occur from February through early May until the natal and/or maternal den site is abandoned (Magoun and Copeland 1998). Denning habitat may be a factor limiting distribution and abundance (Copeland 1996), and wolverines may abandon dens in response to disturbance (Copeland 1996, Magoun and Copeland 1998).

4.2 Potential Risks to the Species

The following discussion on potential risks to wolverine for climate change, human disturbance, and modification of source habitat was taken from the Upper Middle Fork Payette River Project (USDA FS 2013).



4.2.1 Direct Mortality

There is the risk of direct effects in the form of collision related mortality. Alternative B proposes the use of motor vehicles and other heavy equipment to construct temporary roads, drill pads, and drilling facilities, as well as use of such roads in operating and maintaining construction and drilling equipment during the timeframe for which wolverine may den in the Project Area. Such actions have the potential to impact occupied den sites and individual wolverine traveling through the Project Area

Wolverines are also exceptionally vulnerable to trapping (Weaver et al. 1996). Banci (1994), as discussed in Ruggiero et al. (1994) reported that trapping accounted for over half of all recorded mortalities in several wolverine studies in North America. Males may be more likely to encounter traps because they travel greater distances than females. The loss of a single male may impact reproductive success of several females in an area, further contributing to difficulties in maintaining populations. Idaho does not allow harvest; however, wolverines have been captured accidently in traps set for other species (IDFG 2005). Increased roads have provided trappers greater access to wolverine populations (Wisdom et al. 2000).

4.2.2 Climate Change

Wolverine productivity and population maintenance may be linked to availability and quality of reproductive den sites (Banci 1994). A critical feature of wolverine denning habitat is dependability of deep snow throughout the denning period (Magoun and Copeland 1998). Persistent snow is also important for food caching during summer (Magoun and Copeland 1998). Decreasing spring snow cover associating with a warm climate is likely to reduce landscape connectivity as the extent of persistent snow habitat decreases (Copeland et al. 2010). The Intergovernmental Panel on Climate Change (IPCC) provides scientific guidance to policymakers on the topic of climate change in the IPCC Fourth Assessment Report: Climate Change (Lemke et al. 2007). Changes in the amount, intensity, frequency, and type of precipitation, such as snow cover, have been summarized by the IPCC and the U.S. Global Change Research Program (Baldwin et al. 2003, Trenberth et al. 2007). As a result of thermal and precipitation regime changes, the IPCC expects the snowline (the lower elevation of year-round snow) in mountainous regions to rise 150 m (492 feet) for every 1°C (1.8°F) increase in temperature (Christensen et al. 2007). The IPCC concluded that snow-season length and depth of snowpack are very likely to decrease in most of North America (Christensen et al. 2007). Baldwin et al. (2003) and Leung et al. (2004) concluded that future warming increases in the western US will cause increased rainfall and decreased snowfall, resulting in reduced snow accumulation or earlier snowmelt. In many Northern Hemisphere regions, global warming has already caused a reduced snowpack (Trenberth et al. 2007, Brodie and Post 2010). Rauscher et al. (2008) have concluded that increased temperatures in the late 21st century could cause early-season snowmelt-driven runoff to occur as much as two months earlier than presently in the western US. Climate change is expected to reduce the extent of areas with persistent snow in the future and affect the availability and quality of sites suitable for wolverine denning habitat (Baldwin et al. 2003, Reiners 2003). A study in Canada recently looked at snowpack and wolverine population dynamics processes and found where snowpack declined most rapidly wolverine harvest had also declined quickly. Synchrony between climate change and wolverine populations increases the risk to the species’ persistence (Brodie and Post 2010).



The recent proposal to list the contiguous US wolverine DPS as Threatened under ESA was determined largely because of the threat climate change may have on wolverine habitat and persistence within the DPS. At present, the best scientific information available regarding climate change effects to wolverine in the contiguous US DPS is found in McKelvey et al. (2011) (78 FR 7874). This study modeled the distribution of snow cover in the Columbia, Upper Missouri, and Upper Colorado River Basins using a downscaled ensemble climate model. The ensemble model estimated snow cover by inserting regional temperature and precipitation patterns into a hydrologic model, and then took the arithmetic mean of ten global climate models that best fit historical climate trends and patterns to project the ensemble for each basin (McKelvey et al. 2011). As a form of comparison, the study also conducted an analysis based on MODIS snow cover relationships. In general, the models showed that wolverine habitat in the contiguous US will become smaller and more fragmented, with Central Idaho incurring some of the largest habitat losses (McKelvey et al. 2011).

4.2.3 Human Disturbance

There is a risk that activities associated with the construction and maintenance of temporary roads and drill pads and the operation of drilling equipment in the Project Area from April 15December 15 could result in disturbance effects upon wolverine that occupy the Project Area. Of particular concern would be the timing of such activities and their coinciding with wolverine occupying natal dens (April 15-May 15) and the potential for den abandonment or dispersal.

Winter recreational use, particularly snowmobile and heli-skiing, may have potentially severe localized habitat impacts on wolverines. A consistent negative association has been reported between wolverine occurrence and areas where helicopter and backcountry skiing occur (Heinemeyer et al. 2001, Krebs et al. 2007). However, the ongoing Idaho Wolverine – Winter Recreation Research Project, which began in 2009 and is currently in its fifth year, has documented wolverine presence in areas of both high and low winter recreation (Heinemeyer and Squires 2012).

Wolverines may abandon dens (but not necessarily kits) in response to disturbance (Copeland 1996, Magoun and Copeland 1998). Disturbances may include heli-skiing, snowmobiles, backcountry skiing, logging, hunting, and summer recreation (Wisdom et al. 2000). Most of these recreational activities occur in high-elevation areas used as denning sites by wolverines; disruption of the production of young at denning sites is considered a primary factor limiting wolverine population growth (Copeland 1996, Magoun and Copeland 1998).

Wolverine habitat selection may be negatively influenced by human activity, including roads, infrastructure, and backcountry recreation (Hornocker and Hash 1981, May et al. 2006, Krebs et al. 2007). Carroll et al. (2003) and Rowland et al. (2003) all concluded that roads and human density were important factors explaining current wolverine distributions. Copeland et al. (2007) found wolverines in his study did not use roads in summer; however, because most roads were at the periphery of the study area, he was unable to conclude whether this observation was due to the wolverines’ avoidance of human infrastructure or because most of the study area had few roads.



4.2.4 Modification of Source Habitat

Wolverines have a greater requirement for large, contiguous reserves than do other large carnivores (Weaver et al. 1996, Wisdom et al. 2000). Throughout its range, the wolverine occupies a wide variety of habitats; a common pattern among these habitats is their remoteness from the presence or influence of humans. The naturally low population of wolverines, coupled with their low reproductive potential, makes this species susceptible to population declines resulting from human activities, such as habitat loss. While Copeland (1996) found that wolverines in Idaho commonly crossed natural openings, burned areas, meadows, or open, mountain tops; snow-tracking and radio telemetry in Montana indicated that wolverines avoided recent clearcuts and burns (Hornocker and Hash 1981). In a British Columbia study, female wolverines avoided roads and recently logged areas in summer (Krebs et al. 2007).

Persistence of wolverines is critically dependent on their dispersal between habitat islands. Although dispersal dynamics are poorly understood, genetic data from both current and historical populations indicate that dispersal between mountain ranges is limited (Ruggiero et al. 2007). Findings from a study looking at the extent of gene flow across the southern edge of the current wolverine distribution in North America (Montana, Idaho, Wyoming, and Washington) suggest that Idaho’s wolverine population is isolated from all other populations, including those in neighboring Montana (Cegelski et al. 2006). Insular populations in west-central Idaho may provide


habitat in the Boise NF (Figure 3) and analyzing the 2010 Forest Plan Revision. The modeling parameters were based on persistent snow years two through year seven and only included areas where snow cover had remained constant until May 15 (Nutt et al. 2010a and 2010b).

Earlier models included both persistent snow cover and updated vegetation mapping descriptions (based on the 2010 Forest Plan revision) to describe wolverine source habitat and were used to calculate approximate wolverine source habitat acreage for the modified Project Area (USDA FS 2010, USDA FS 2011a, personal communication M. Feiger 2013). According to the 2011 Wildlife Report, approximately 2,621 acres or 91 percent of the modified Project Area was considered to be source habitat for the wolverine (USDA FS 2011a); however, the 91 percent is likely an overestimate. Based on new science of incorporating only persistent snow cover into source habitat modeling (Aubry et al. 2007, Copeland et al. 2010), only a portion of the modified Project Area is classified as having persistent spring snow (Figure 4). This suggests that wolverine source habitat and the potential for reproductive denning to occur within the modified Project Area is likely to be substantially less than what was reported in the 2011 Wildlife Report. However, the original intent of source habitat modeling was to be employed at the landscape-scale of the Boise NF (Figure 3) and refinement to the project-level is very rough and may not be quantifiably defensible. Therefore, project-level modeling for wolverine source habitat within the modified Project Area (Figure 4) is used as a guideline to aid in determination of effects for wolverine.



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4.5 Sightings

Idaho Conservation Data Center (IDCDC) indicates a known occurrence of wolverine approximately 5.6 miles northeast of the modified Project Area (IDFG 2005). Although, Idaho Department of Fish and Game (IDFG) recently reported that a wolverine was poached east of Horseshoe Bend (IDFG 2007).


5 EFFECTS ANALYSIS

5.1 Direct and Indirect Effects

The following information on direct and indirect impacts and cumulative impacts was taken from the 2011 Wildlife Report (USDA FS 2011a).

5.1.1 Potential for Direct Mortality

The risk of collision-related mortality associated with temporary road and drill pad construction, as well as traffic associated with maintenance and operation of drill pads during the operational timeframe of April 15 through December 15, is low. Such direct effects would not be anticipated. Reasons for this conclusion include the following:

Traffic speeds of construction, maintenance, and operations traffic would be relatively slow given the native surface and temporary-constructed nature of the roads; vehicle speeds would not reach highway speeds, where that risk would be greater;

Individual wolverine are highly mobile and would be able to avoid slower moving vehicle traffic on the temporary access roads in the Project Area; and

Mechanical disturbance associated with the daily operation of construction, maintenance, and support traffic, plus drilling equipment, would likely discourage the presence of individual wolverine within the Project Area, further reducing the risk.

Since source habitat associated with persistent snow cover occurs in the modified Project Area, wolverine denning could occur. The presence of a natal den along the location of a temporary road or drill pad (existing or to be constructed) could result in direct mortality to young occupying that den site at the time of road/drill pad construction and/or maintenance (plowing) (April 15-May 15). The risk of such effects, however, is low for the following reasons:

Likelihood of the presence and occupancy of a natal den in the Project Area, and specifically associated with the proposed road locations would be low, given the overall location of the Project Area (northwest corner of the large block of persistent snow source habitat) (Figure 4);

At times of overlap in natal den occupancy and the proposed activities (April 15-May 15), kits are old enough to be mobile, and typically are moved by the mother to alternate den sites during this time period. Females have been documented to move their kits when disturbed (Ruggiero et al. 1994); and

If an individual wolverine is sighted during road or drill pad construction or road maintenance work during the time period of April 15-May 15, the wolverine denning mitigation feature identified in Section 2.3.3 of the Supplemental EA would be implemented. The result would be a suspension of disturbance activities near the den site through May 15 if the District Wildlife Biologist would determine such activities would affect denning.

Direct mortality of adult wolverines is unlikely under Alternative B because of their mobility. The species has ample ability to avoid the modified Project Area during operations and would have the opportunity to return to the area once the project is complete. Current road and drilling activities make it less likely that wolverines would be present since they tend to avoid human interaction and there is ample suitable habitat adjacent to the modified Project Area.



Since persistent spring snow cover occurs in the modified Project Area, wolverine denning could occur. However, given the large home range of wolverine and generally low population densities, the likelihood of proposed temporary roads under Alternative B directly impacting a wolverine den in the Project Area is low. Females have been documented to move their kits when disturbed (Ruggiero et al. 1994).

5.1.2 Potential Effects from Human Disturbance

Project-related activities associated with Alternative B that may result in potential impacts to the wolverine from human disturbance primarily include the following: 1) noise from Project equipment associated with drill pad and road construction; and 2) noise from drilling rigs during drilling activities.

Though the causal factors are not well understood, research in the Canadian Rockies found a negative correlation between wolverine occurrence and helicopter skiing activities, indicating that wolverine may be sensitive to multiple forms of human disturbance (Copeland et al. 2007, Krebs et al. 2007, Ruggiero et al. 2007). However, the ongoing Idaho Wolverine – Winter Recreation Research Project, which began in 2009 and is currently in its fifth year, has documented wolverine presence in areas of both high and low winter recreation (Heinemeyer and Squires 2012). In Idaho, wolverines generally occur in remote mountainous areas, though this may be caused by human development and occupation of less steep, lower elevation habitats. Motorized vehicle use in winter and spring could disrupt wolverine behavior (Hornocker and Hash 1981, Ruggiero et al. 1994).

Wolverine denning could occur during the critical denning period for reproductive success (April 15-May 15), since persistent spring snow cover occurs in the modified Project Area. This time period overlaps with potential project implementation of Alternative B, and includes the potential disturbance activities previously identified.

If suitable denning habitat was occupied by a reproducing wolverine, and the activities proposed were to occur during the April 15-May 15 timeframe, there is potential for indirect effects to that reproducing wolverine and its kits. As noted above, reproducing wolverine may be sensitive to human disturbance, and the activities proposed (road and drill pad construction and drill pad operation) are consistent with the documented activities which have affected wolverine reproduction. Those disturbance effects could include the following:

1) disturbance to the mother and/or kit(s) that does not lead to natal den abandonment, but may affect success of reproductive effort;

2) relocation of the mother and kit(s) to an alternative den away from the disturbance; or

3) abandonment of the natal den and kit(s) by the mother, resulting in a reproductive failure.

Due to a variety of factors, however, the risk of the indirect effects described above is reduced. Those factors include the following:

1) relative juxtaposition of the Project Area and affected persistent snow source habitat to the larger patch of persistent snow habitat displayed in Figure 4. The Project Area occurs on the outer NW edge of the larger persistent snow patch, and represents a relatively



small percentage of the total patch. The likelihood of a denning wolverine choosing the Project Area is minimized;

2) activities proposed would only affect a small portion of persistent snow habitat which is nested within, and on the edge of, a larger patch of persistent snow source habitat;

3) the low likelihood that a wolverine would select the modified Project Area for a natal den given the choice of higher elevation, higher quality persistent snow habitat in the larger patch (USDA FS 2011a, personal communication M. Feiger 2013). Other areas, particularly east and south east of the Project Area occur at higher elevations, thereby increasing the likelihood of higher quality persistent snow denning habitat;

4) where a natal den would be established and activities proposed were to result in human related disturbances to the den site, there is the potential that the female may simply move the kit(s) to a more secluded, less disturbed location (Ruggiero et al 1994);

5) if a den site is located within the Project Area, appropriate measures, including timing restrictions identified in Section 2.3.3 of the Supplemental EA, would be implemented to ensure no disturbance impacts occur between the April 15th start of the operating period and May 15th that would impact denning activity.

Considering above, the overall risk to indirect disturbance effects to reproducing wolverine is low.

5.1.3 Potential Impacts from Habitat Modification

Project-related activities associated with Alternative B that may result in potential impacts to the wolverine from habitat modification primarily include the following: 1) drill pad and sump construction; 2) road construction; 3) snow plowing activities that may result in the creation of large berms or piles; and 4) drilling in and adjacent to suitable denning habitat.

Small reductions in source habitat would result from Alternative B; however, these impacts are expected to be temporary to short-term and would cease once the roads are obliterated and reclaimed. Table 2 summarizes the direct impacts on wolverine source habitat which is likely an overestimate because calculations are based on earlier wolverine source habitat models (see Section 4.4 for modeling discussion).

Table 2: Direct Impacts to Wolverine Source Habitat

Species Species Existing Source Habitat

(ac)

Alternative B Impacts (ac)

% of Source Habitat Impacted

Alternative B Wolverine 2,621 68.3 2.6%

5.2 Cumulative Effects

5.2.1 Past Actions

Historic mining, Amax roads and drilling, and timber sales have resulted in changes to forest structure, increases in road density, and human presence and surface disturbance to potential



wolverine habitat. Impacts on wolverine from historic mining may have included direct mortality of wolverine from the potential for miners to shoot or trap wolverine in the past. Timber sales and past recreational use of the Project Area likely resulted in temporary to short-term disturbances to wolverines, but since they are a wide ranging species, these impacts are likely insignificant. Those activities have also resulted in temporary and short-term modifications to source habitat. Past livestock grazing in the Project Area under the Boise Basin Grazing Allotment probably had no direct impact on wolverines. The impacts of past actions on wolverine in the Project Area are likely no longer detectable; therefore, the impacts of Alternative B on wolverine are not expected to result in cumulative impacts when combined with effects of past actions.

Limited exploration activity by CuMoCo and its predecessors occurred in the Project Area between the summer of 2006 and 2010. This exploration activity consisted of re-establishing approximately 4.7 miles of former exploration roads and exploratory drilling under a 2005 Plan. This action likely occurred in persistent spring snow cover areas (wolverine source habitat). Recent past exploration activities combined with the 2007 Plan would cumulatively result in approximately 12 years of human presence and related noise in the Project Area. Such effects may have altered distribution and utilization of source habitat in the Project Area. Cumulative, the disturbance effects of activities proposed during mid-April to mid-May associated with Alternative B could be additive to the overall disturbance effects of the past 12 years. Those affects, however, are minimized per the same rationale discussed in Section 5.1.2.

5.2.2 Present Actions

Approximately 290 acres of private lands occur in the Project Area. Since the summer of 2010, MCGM has been conducting exploration activities on the portion of its 2007 Plan that occurs on private lands which includes the construction of up to 0.5 miles of new exploration roads on private lands. Though snow cover data is unavailable for private lands, these current exploration activities likely occur in wolverine source habitat. Based on this assumption, activities proposed in Alternative B would contribute cumulatively to effects associated with the activities occurring on private land. However, those cumulative effects are minimized per the same rationale discussed in Section 5.1.2.

Current over snow/snowmobile recreational use is extensive within the Pilot Peak/Jackson Peak/Wilson Peak area. Forest Service Road 380F, located just south of the modified Project Area, is maintained as a groomed trail for snowmobiling and other snow-related sports. The proposed timeframe for non-operational Project activities (December 16 through April 14) would reduce the likelihood that wolverines would be impacted by both, winter recreational activities and project related activities. In addition, no motorized recreation would be authorized to travel on project roads which may further reduce the potential of impacts to wolverines. Cumulatively, effects associated with actions proposed in Alternative B could be additive to winter recreation disturbance effects spread out across the larger patch of persistent snow habitat. However, that risk of cumulative effects is reduced per the rationale discussed in Section 5.1.2.

Current grazing under the Boise Basin Grazing Allotment is not expected to impact wolverines. Therefore, grazing related cumulative effects on wolverine are not anticipated.



5.2.3 Future Actions

The recent listing of the wolverine was primarily driven by concerns regarding the potential effects climate change may affect the current amount and distribution of persistent snow source habitat across the contiguous US (USDA FS 2013). The proposed Project would not alter the amount or extent of persistent snow on the landscape, and thus would not add cumulatively to the effects of climate change on source habitat for wolverine.

Future recreation and grazing activities are expected to have similar potential impacts on wolverines as these activities currently do and should not result in substantive cumulative effects when added to the effects of Alternative B on wolverine.


6 DETERMINATION

Of the CuMo Exploration Project on Wolverine (Proposed):

No Effect Not likely to Jeopardize the Continued Existence Likely to Jeopardize the Continued Existence


7 RATIONALE FOR DETERMINATION

The rationale for the above determination is based on the following:

Minimal risk associated with direct effects (mortality) associated with temporary road and drill pad construction, maintenance, and operation during late wolverine denning period (April 15-May 15);

Natal den sites discovered in the Project Area would be protected through the mitigation measure identified in Section 2.3.3 in the Supplemental EA from disturbance and mortality effects;

Effects from the modification of source habitat from the construction of temporary roads and drill pads would account for only 2.6% of source habitat in the Project Area;

Risk of indirect disturbance effects is low due to factors described in 5.2.1;

Large home range and low population densities relative to a small Project Area reduces risk of effects to individuals;

There are no existing or reasonably foreseeable future projects in or near the modified Project Area that would substantially add to the effects associated with Alternative B;

The Project would not have a substantial effect on the current amount and distribution of persistent snow source habitat across the contiguous US, and therefore, would not affect source habitat from a climate change standpoint;

Denning wolverine may have a relative level of tolerance to disturbance such that reproductive success would not be adversely affected (Heinemeyer and Squires 2012, USDA FS 2013); and wolverine occupying a natal den during time frames of proposed activity could relocate to a natal den site away from that disturbance (Ruggiero et al. 1994).


8 REFERENCES

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Title Page1 INTRODUCTION2 PROJECT HISTORY2.1 Project Area Description2.2 Purpose and NeedFigure 1. General Project VicinityFigure 2. Alternative B: Modified Project Area

2.3 Proposed ActionTable 1: Summary of Key Features of Each Alternative in Project Area for the Project

2.4 Consultation History

3 SPECIES ANALYZED – WOLVERINE (PROPOSED)3.1 Background for Proposed Listing

4 ENVIRONMENTAL BASELINE4.1 Source Habitat Requirements4.2 Potential Risks to the Species4.2.1 Direct Mortality4.2.2 Climate Change4.2.3 Human Disturbance4.2.4 Modification of Source Habitat

4.3 Modified Project Area4.4 Existing Source Habitat Condition in Modified Project AreaFigure 3. Wolverine Current Source HabitatFigure 4. Adjacent Source Habitat

4.5 Sightings

5 EFFECTS ANALYSIS5.1 Direct and Indirect Effects5.1.1 Potential for Direct Mortality5.1.2 Potential Effects from Human Disturbance5.1.3 Potential Impacts from Habitat ModificationTable 2: Direct Impacts to Wolverine Source Habitat

5.2 Cumulative Effects5.2.1 Past Actions5.2.2 Present Actions5.2.3 Future Actions

6 DETERMINATION7 RATIONALE FOR DETERMINATION8 REFERENCES

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