vegetation clearing and area clearance plan

Arizona Business Unit 5255 E. Williams Circle, Suite 1065 Tucson, Arizona 85711-7407 tel 520-495-3500 Hudbayminerals.com

Vegetation Clearing and Area Clearance Plan

As Required By: Mitigation Measures: FS-GMP-01, FS-GMP-02, FS-SR-01, FS-SR-03, FS-BR-01, FS-BR-02, FS-BR-04, FS-BR-06, FS-BR-10, FS-BR-12, FS-BR-13, FS-BR-14, FS-BR-15, FS-BR-18, FS-VR-02, FS-PHS-01, FS-CR-01, FS-CR-02, FS-CR-04, FS-CR-05, FS-CR-07, FS-CR-09, OA-SR-01, OA-GW-05, OA-GW-08, CEC

June 2018

Prepared by:

Rosemont Copper Company

Vegetation Clearing and Area Clearance Plan, Rev. 2 Page i

Monitoring and Reporting Schedule

Task Schedule Purpose/Description/Timing Baseline Period

Pre-Construction Period / Construction Phase Operations Phase Final Reclamation

and Closure Phase1 AN AN W Q A AN W Q A AN W Q A

FS-BR-01

Initial review of plans Ensure that the plant site is built to reduce impacts to biological resources

X

Weekly visual inspections during plant facility construction and removal

Ensure that the plant site is built in accordance with the final MPO to reduce impacts to biological resources

X X

Report disturbance outside of approved plans to the Coronado within 24 hours

To determine impact on resources X X X

Report monitoring results of plant facility placement/removal quarterly and annually

Ensure that the plant site is built in accordance with the final MPO to reduce impacts to biological resources. Notify Forest Service as needed during operations if modifications are proposed.

X X X X X X

FS-BR-02

Inventory of NFS (National Forest Service) for Coleman’s Coralroot

Prior to ground disturbance X X2 X

Inventory of NFS (National Forest Service) for Beardless Chinch-weed

Prior to ground disturbance X2 X

Reporting for Coleman’s Coralroot Reporting to Forest Service X2 X

Reporting for Beardless Chinch-weed Reporting to Forest Service X2 X

Initial review of plans

Protected plant populations would not be impacted by plant site and facility construction or operations

X

Vegetation Clearing and Area Clearance Plan, Rev. 2 Page ii

Task Schedule Purpose/Description/Timing Baseline Period

Pre-Construction Period / Construction Phase Operations Phase Final Reclamation

and Closure Phase1 AN AN W Q A AN W Q A AN W Q A

Weekly visual inspections during plant facility construction and removal

Facilities would be constructed in accordance with the final MPO. Protected plant populations would not be impacted by plant site and facility construction or operations

X X

FS-BR-04 (also included in the Agave Management Plan)

Refine existing estimates of Palmer’s agave that would be impacted

Survey of agaves within the Security Fence X

Salvaging agaves Prior to disturbance X X X

FS-BR-06

Daily inspections during construction and removal of the powerline near talus slopes

To ensure or limit disturbance to talus snail habitat

X X

Report disturbance outside of planned footprint within 24 hours

To Forest Service

X X

FS-BR-10

Surveys for Pima Pineapple Cactus (PPC)

Prior to disturbance (utility corridor) X X

Mark & avoid or transplant PPC

Prior to construction or disturbance

X

Maintenance of PPC transplants

Watering for the “First few months” after transplant X

Monitoring of transplants Maintenance and success of transplants

X X X

Reporting

Notify U.S. Fish & Wildlife Service and Forest Service when each conservation measure (CM) is completed

X X X

Refer to Biological Monitoring Plan for FS-BR-02, FS-BR-06, FS-BR-12, FS-BR-13, FS-BR-14, FS-BR-15, FS-BR-18 Monitoring & Reporting Schedule

Refer to Revegetation and Growth Media Monitoring Plan for FS-SR-01 Monitoring & Reporting Schedule

Vegetation Clearing and Area Clearance Plan, Rev. 2 Page iii

Task Schedule Purpose/ Description/Timing

Baseline Period

Pre-Construction Period / Construction Phase

Operations Phase

Final Reclamation and Closure Phase1

AN AN W Q A AN W Q A AN W Q A FS-CR-01, FS-CR-02 & FS-CR-04

Excavation & Data recovery of cultural sites

Prior to disturbance and/or upon inadvertent discovery

X X X

Documentation of cultural resources and human remains repatriation

During excavation and/or upon inadvertent discovery

X X X

FS-CR-05 Approval of ground-disturbing activities between perimeter & security fences

In advance of disturbance

X X X

Reporting Cultural & other findings, as needed

X X X

FS-CR-07 & FS-CR-09

Coordinate plant removal with consulting tribes

Consulting tribes will be provided an opportunity to collect plants for removal to their reservations. Some plants would be transplanted to a designated area, inventoried, and access provided to collect plants used for medicinal, ceremonial, and craft purposes. Will occur prior to ground disturbance.

X X

X

Transplant plants used for medicinal, ceremonial, and craft purposes to private lands for later Tribe access/use

Prior to ground disturbance

X X

FS-GMP-01 & FS-GMP-02 Visual inspections/monitoring for significant paleontological resources, caves, and/or sinkholes

During ground disturbance

X X X

Vegetation Clearing and Area Clearance Plan, Rev. 2 Page iv


Baseline Period


Operations Phase


AN AN W Q A AN W Q A AN W Q A FS-VR-02

Weekly during plant site decommissioning; to ensure actions comply with permits

Inspection of removal of facilities not needed post-closure, including removal, breakage or burial of foundations

X

Quarterly to ensure all specifications are achieving specifications in Reclamation & Closure Plan

Inspection & reporting of closure activities, including removal, disturbance and reclamation

X

FS-PHS-01

Daily inspections of the Perimeter Fence during installation

Ensure that location and construction techniques comply with the final MPO

X X

Annual inspections of the entire length of the Perimeter Fence

Ensure that it is effective in restricting public access

X X X

FS-SR-03

Weekly visual inspections of the Perimeter buttress

1) To ensure that the locations are that specified in the FEIS/ROD/final MPO 2) geometry of facility adheres to final MPO specifications 3) waste rock placement in accordance with the Aquifer Protection Permit and stacking plan from the final MPO and 4) facilities are stable

X

Quarterly reporting Reporting of results from weekly inspections

X

OA-GW-05

Daily inspections of the footprint of the tailings facility

Ensure that the footprint is within the area specified in the FEIS/ROD/final MPO

X

Vegetation Clearing and Area Clearance Plan, Rev. 2 Page v


Baseline Period


Operations Phase


AN AN W Q A AN W Q A AN W Q A

OA-GW-08 (Refer to Well Abandonment Plan for detailed Monitoring & Reporting Schedule)

Cap open and/or abandoned boreholes or wells

Ensure groundwater is not contaminated

X X X

OA-SR-01

Weekly inspections of power line and water supply line during construction

Ensure that the location complies with the ACC, CEC, and final MPO

X

Other Forest Requirements

Reporting to USFS Annually track and report amount of saleable wood

X X X

Condition 21 of the Certificate of Environmental Compatibility (CEC) Biologist to monitor utility corridor for sensitive species or habitat, including Sonoran desert tortoise

During ground disturbance

X

A = Annually; AN = As Needed; Q = Quarterly; W= Weekly; 1 = Monitoring in post-closure period to be determined; 2 = Note that FS-BR-02 states that semi-annual inspections and reporting would be performed. However, each species will be monitored annually during different time periods. Therefore, monitoring and reporting is to be conducted annually for each species.

Vegetation Clearing and Area Clearance Plan, Rev. 2 Page iv

Revision Log

Revision Number

Revision Lead Purpose of Revision Revision

Date

1 Rosemont Based on Forest Service review of June 2017 MPO submittal. March 2018

2 Rosemont Based on Forest Service review of March 2018 MPO submittal. June 2018

Vegetation Clearing and Area Clearance Plan, Rev. 2 Page v

Table of Contents 1.0 PLAN OBJECTIVES AND DESCRIPTION ........................................................................ 1

1.1 PLAN OBJECTIVES ....................................................................................................... 1 1.2 PLAN DESCRIPTION..................................................................................................... 5

2.0 EXISTING VEGETATION................................................................................................... 6 2.1 VEGETATION AT THE MAIN PROJECT SITE ................................................................ 6 2.2 VEGETATION ALONG THE UTILITY CORRIDOR .......................................................... 6 2.3 INVASIVE SPECIES....................................................................................................... 7

3.0 AREA CLEARANCE AND VEGETATION SALVAGE ......................................................... 1 4.0 CLEARING AND GRUBBING ........................................................................................... 4

4.1 VEGETATION CLEARING IN MAIN PROJECT AREA .................................................... 4 4.2 VEGETATION CLEARING ALONG THE UTILITY CORRIDOR ....................................... 5 4.3 VEGETATION CLEARING IN OTHER AREAS ................................................................ 6

5.0 MONITORING AND REPORTING ..................................................................................... 8 5.1 MONITORING ................................................................................................................ 8 5.2 REPORTING .................................................................................................................. 9

6.0 CLOSURE AND BOND RELEASE .................................................................................. 10 6.1 INTERIM CLOSURE .................................................................................................... 10 6.2 FINAL CLOSURE ......................................................................................................... 10 6.3 BOND RELEASE ......................................................................................................... 10

7.0 DATA MANAGEMENT..................................................................................................... 11 8.0 REFERENCES ................................................................................................................ 12

Vegetation Clearing and Area Clearance Plan, Rev. 2 Page vi

Figure Figure 1 Rosemont Project Location Map

Appendix Appendix A Area Clearance Checklist

Vegetation Clearing and Area Clearance Plan, Rev. 2 Page 1

1.0 PLAN OBJECTIVES AND DESCRIPTION This Vegetation Clearing and Area Clearance Plan (Plan) was created to summarize, and provide guidance for, environmental clearances required to begin ground-disturbance in select areas. This Plan covers clearance requirements for the main Rosemont Copper Project (Project) site and the Utility Corridor (see Figure 1), as well as other areas prior to ground disturbance. Also incorporated into this Plan are those facility inspections required to ensure placement within approved footprints/alignments.

1.1 PLAN OBJECTIVES The objectives of this Vegetation Clearing and Area Clearance Plan are to:

• Summarize the clearances required prior to initiating vegetation clearing and grubbing operations (clear and grub) and growth media (soil) salvage, including a list of plant species requiring salvage and/or monitoring/management;

• Ensure facility placement per approved footprints/alignments;

• Provide guidance on the use of site vegetation (small to medium woody species) with relation to reclamation (scattered litter and mulch) and erosion control;

• Record the numbers of plants salvaged for consulting tribes; and

• Record the estimated amount of large, woody (saleable) species at the Project site.

The following conditions were derived from several mitigation and monitoring measure (Mitigation Measure) requirements of the U.S. Forest Service’s (USFS, Forest Service) Coronado National Forest (Coronado) Final Environmental Impact Statement (FEIS; USFS, 2013b) for the Project. These Mitigation Measure requirements/conditions are found in Appendix B of the FEIS, the ROD (USFS, 2017b), and the Errata (USFS, 2017a). Condition 21 of the Arizona Corporation Commission (AAC) Certificate of Environmental Compatibility (CEC) is also summarized below.

Area Clearance Measures:

• Mitigation Measure FS-GMP-01: Upon discovery of paleontological resources, suspension of operation pending Forest Service review (see page B-7 of the FEIS [USFS, 2013b]). Ground-disturbing activities could also be suspended in a previously cleared area upon discovery of additional paleontological resources. Activities would be resumed following investigation of the resource. Note: The term paleontological resources was clarified in the ROD (USFS, 2017b) and the Errata (USFS, 2017a) to mean vertebrate resources.

• Mitigation Measure FS-GMP-02: Upon discovery of a cave or sinkhole, suspension of operations pending Forest Service review (see pages B-7 and B-8 of the FEIS [USFS, 2013b]). Ground-disturbing activities could also be suspended in a previously cleared area upon discovery of additional caves/sinkholes. Activities would be resumed following investigation of the cave/sinkhole.

• Mitigation Measure FS-SR-03: Concurrent placement of perimeter buttress (see pages B-14 and B-15 of the FEIS [USFS, 2013b]). Inspections would occur during construction to ensure placement is within the specified footprint specified in the FEIS, ROD, and final Mine Plan of Operations (MPO).

• Mitigation Measure FS-BR-01: Plant site location and design adjustments to reduce impacts to biological resources (see page B-28 of the FEIS [USFS, 2013b]). The intent of this mitigation measure is to periodically inspect and review the plant site and building construction to make sure they are built in accordance with the plans and final MPO. Inspections are review would also occur and during closure and final reclamation phase when the plant site is removed and restored. This is to make sure that areas that were avoided during construction are not


destroyed or directly impacted by building removal and plant site restoration. Disturbance outside the areas depicted in approved plans would be reported to the Forest Service within 24-hours.

• Mitigation Measure FS-BR-02: Redesign of the coarse ore stockpile dome and pebble crusher/ball loading facility to avoid a subpopulation of sensitive plants (see pages B-28 and B-29 of the FEIS [USFS, 2013b]). This Mitigation Measure involves the protection of Coleman’s coralroot on the west side of the Plant Site. Among other requirements is to perform a complete inventory of Coleman’s coralroot and beardless chinch-weed within the disturbance footprint prior to ground disturbance. Details are provided in the Biological Monitoring Plan (MPO Volume II-f).

• Mitigation Measure FS-BR-06: Location of the electrical power line that provides power to the pit area so that it avoids talus slopes to the extent practicable (see page B-33 and of the FEIS [USFS, 2013b]). Design review and inspections during construction and decommissioning to minimize impacts to talus slopes. Disturbance to areas not included in approved plans would be reported to the Forest Service within 24-hours.

• Mitigation Measure FS-BR-12: Relocation of Chiricahua leopard frogs from areas in the immediate vicinity of the project area (see page B-39 of the FEIS [USFS, 2013b]). Details specific to this Mitigation Measure are provided in the Biological Monitoring Plan (MPO Volume II-f). Pre-disturbance surveys would be conducted and frogs relocated.

• Mitigation Measure FS-BR-13: Measures to ensure relocation of lesser long-nosed bat and other bat species in the immediate vicinity of the mine (see pages B-40 and B-41 of the FEIS [USFS, 2013b]). Details specific to this Mitigation Measure are provided in the Biological

Monitoring Plan (MPO Volume II-f). Pre-disturbance surveys would be conducted to ensure that bats are not trapped in abandoned mine workings or that they do not succumb to mining activities.

• Mitigation Measure FS-BR-14: Measures to reduce impacts to western yellow-billed cuckoo (see pages B-41 and B-42 of the FEIS [USFS, 2013b]). Details specific to this Mitigation Measure are provided in the Biological Monitoring Plan (MPO Volume II-f). Vegetation clearing would not occur in buffer areas within 50 meters of active nesting sites.

• Mitigation Measure FS-BR-15: Measures to protect two occurrences of Coleman’s coralroot during road decommissioning (see page B-42 of the FEIS [USFS, 2013b]). Details specific to this Mitigation Measure are provided in the Biological Monitoring Plan (MPO Volume II-f). Two (2) populations of Coleman’s coralroot would be avoided during decommissioning of National Forest Service Roads (NFSRs) 4051 and 4051A.

• Mitigation Measure FS-BR-18: Pre-disturbance surveys for Forest Service sensitive species (see pages B-45 and B-46 of the FEIS [USFS, 2013b]). Details specific to this Mitigation Measure are provided in the Biological Monitoring Plan (MPO Volume II-f). Surveys of ten (10) specific plant species and one (1) invertebrate species are required prior to ground disturbance. A specific survey plan or strategy is required that addresses documentation of the species along with possible collection, translocation, seed collection, etc.

• Mitigation Measure FS-VR-02: Removal of unneeded facilities during closure (see pages B-60 and B-61 of the FEIS [USFS, 2013b]). Details specific to this Mitigation Measure are provided in the Visual Resources Monitoring Plan (MPO Volume II-cc). The protection of biological and cultural resources would be maintained during decommissioning/closure activities. Previously undisturbed areas needed for reclamation and/or closure activities would be cleared prior to use.

• Mitigation Measure FS-PHS-01: Construction of a perimeter fence that would exclude the public (see pages B-68 and B-69 of the FEIS [USFS, 2013b]). This mitigation measure includes


inspections during installation to ensure compliance with the location and construction techniques stated in the final MPO.

• Mitigation Measure FS-CR-01: Archaeological data recovery on sites that would be adversely affected (see pages B-69 and B-70 of the FEIS [USFS, 2013b]). Details specific to this Mitigation Measure are provided in the Historic Properties Treatment Plan for the Proposed

Rosemont Copper Project (SWCA, 2014) and in A Historic Properties Treatment Plan for

Rosemont Copper Utilities (EPG, 2015). Testing and data recovery for affected cultural sites would occur prior to ground disturbing activities. This Mitigation Measure also applies to “FS-CR-02: Respectful and appropriate treatment of human remains that would be disturbed by the project” on page B-70 in Appendix B of the FEIS (USFS, 2013).

• Mitigation Measure FS-CR-02: Respectful and appropriate treatment of human remains that would be disturbed by the project (see page B-70 in Appendix B of the FEIS [USFS, 2013]). This applies to all known prehistoric and historic sites, as well as any inadvertent discovery of human remains during construction or project work. Details specific to this Mitigation Measure are provided in the Historic Properties Treatment Plan for the Proposed Rosemont Copper

Project (SWCA, 2014) and in A Historic Properties Treatment Plan for Rosemont Copper

Utilities (EPG, 2015).

• Mitigation Measure FS-CR-04: Monitoring and treatment of inadvertent discoveries (see page B-71 of the FEIS [USFS, 2013b]). Details specific to this Mitigation Measure are provided in the Historic Properties Treatment Plan for the Proposed Rosemont Copper Project (SWCA, 2014) and A Historic Properties Treatment Plan for Rosemont Copper Utilities (EPG, 2015). Ground-disturbing activities would be suspended upon discovery of additional cultural resources. Activities would be resumed upon testing and data recovery. This Mitigation Measure also applies to “FS-CR-02: Respectful and appropriate treatment of human remains that would be disturbed by the project” on page B-70 in Appendix B of the FEIS.

• Mitigation Measure FS-CR-05: Limiting ground-disturbing activity between the perimeter fence and security fence (see page B-72 of the FEIS [USFS, 2013b]). Details specific to this Mitigation Measure are provided in the Historic Properties Treatment Plan for the Proposed

Rosemont Copper Project (SWCA, 2014). Ground disturbing activities that could not avoid cultural sites would be cleared prior to disturbance. Clearance would include testing and data recovery.

• Mitigation Measure OA-SR-01: Power and water line locations (see pages B-75 and B-76 of the FEIS [USFS, 2013b]). Inspections would be performed during construction in order to ensure that the utility locations comply with the CEC and final MPO.

• Mitigation Measure OA-GW-05: Processing and placement of tailings to reduce water content and overall footprint (see pages B-86 and B-87 of the FEIS [USFS, 2013b]). Inspections would be made to ensure that the footprint of the tailings facility is within the area specified in the final EIS and ROD.

• Mitigation Measure OA-GW-08: Well abandonment and capping (see page B-87 of the FEIS [USFS, 2013b]). Details specific to this Mitigation Measure are provided in the Well

Abandonment/Capping Plan (MPO Volume IV-w). Wells and boreholes will be abandoned/capped to prevent potential pathways for contaminants between the surface and the aquifer. Vegetation may need to be cleared to maintain access to wells.

• Per Condition 21 of the Certificate of Environmental Compatibility issued for work in the Utility Corridor, monitoring for Sonoran desert tortoise will occur during all ground disturbance and construction activities that may affect sensitive species or habitat. Monitoring will be conducted in accordance with the protocol detailed in the Biological Monitoring Plan (MPO Volume II-f).


Vegetation Clearing Measures:

• Mitigation Measure FS-BR-04: Salvage, growing, planting, and monitoring of Palmer’s agave (see pages B-30 and B-31 of the FEIS [USFS, 2013b]). Details specific to this Mitigation Measure are provided in the Agave Management Plan (MPO Volume II-b). To the extent practicable, Palmer’s agave will be removed from disturbance areas and transplanted onto reclaimed surfaces. Agaves would be transplanted immediately, if practicable, or temporarily placed in an on-site nursery. Agave transplanting will ideally occur prior to monsoon rains, June to early July, or during the cool season, November to March, when agaves are dormant. (MPO Volume II-b)

• Mitigation Measure FS-BR-10: Measures to reduce and rectify impacts to Pima pineapple cactus (see page B-37 of the FEIS [USFS, 2013b]). Details specific to this Mitigation Measure are provided in the Biological Monitoring Plan (MPO Volume II-f). A pre-disturbance survey for Pima pineapple cactus (PPC) would be conducted prior to ground disturbance along the Utility Corridor. The PPC would be transplanted prior to ground disturbance or would be avoided where possible. PPC may be transplanted ahead of construction schedule, preferably prior to the monsoon season, for improved transplanting conditions.

• Mitigation Measure FS-CR-07: Project proponent would allow tribal members access, upon 5 days’ advance request, to the project area for cultural practices (see page B-73 of the FEIS [USFS, 2013b]). Areas to be accessed include springs, vision and other sacred sites, and resource-collecting areas.

• Mitigation Measure FS-CR-09: Transplanting of selected plant resources and inclusion of species within revegetation mixture (see pages B-73 and B-74 of the FEIS [USFS, 2013b]). Details specific to this Mitigation Measure are provided in the Historic Properties Treatment

Plan for the Proposed Rosemont Copper Project (SWCA, 2014). Tribes will be offered an opportunity to collect plants for removal to their reservations. Other plants will be transplanted to a Rosemont designated area and access will be provided to members of consulting tribes to collect plants used for medicinal, ceremonial, and craft purposes. Native tribes have expressed interest in agaves, beargrass, sotol, and other species. Plants will be transplanted during the dormant season when practicable, when this is not possible other measures, such as supplemental watering, will be taken to increase the plants chance of survival. Prior to removal of plants, tribes may perform ceremonies. During Section 106 consultations with the Native American tribal council, plant resources were addressed on pages 8 and 9 in the Memorandum of Agreement (MOA), which is in Appendix D of the FEIS (USFS, 2013b). The MOA states that:

o On Forest lands, opportunities to collect plants for traditional, medicinal, and ceremonial uses will continue with requests for collection coordinated by the Forest Archaeologist and Rosemont to ensure that proper health and safety requirements are met.

o Rosemont will schedule a week during which tribal representatives can visit the mine area before construction to collect specimens of agave, sotol, yucca, beargrass, coral bean, and medicinal plants. All tribal representatives will undergo necessary safety training before entering the Project area, and access will be coordinated with Rosemont prior to the removal of any plants. Tribes may perform ceremonies.

o Rosemont will permit collection of plants on conservation lands to the extent allowable under conservation requirements. Rosemont will coordinate access to the conservation lands by tribal representatives and may require a five (5) day notice of request for access.

Access to the Project site by the tribes is also summarized in the Cultural Resources

Management Plan (MPO Volume II-i).


1.2 PLAN DESCRIPTION The remainder of this Plan includes the following sections:

• Section 2.0: Existing Vegetation;

• Section 3.0: Area Clearance and Vegetation Salvage;

• Section 4.0: Clearing and Grubbing;

• Section 5.0: Monitoring and Reporting;

• Section 6.0: Closure and Bond Release;

• Section 7.0: Data Management; and

• Section 8.0: References.


2.0 EXISTING VEGETATION The following are covered in this section:

• Vegetation at the main Project site;

• Vegetation along the Utility Corridor; and

• Vegetation in other areas.

2.1 VEGETATION AT THE MAIN PROJECT SITE The main Project site, including the area between the Security and Perimeter fences, the Plant Site, and other areas on the east flank of the Santa Rita Mountains, is primarily located within a semi-desert grassland biome (plant community) with smaller areas of Madrean Encinal Woodland. Biomes are major vegetation formations centered in a geographic area. The semi-desert grassland is primarily composed of perennial grasses (Bouteloua curtipendula, Bouteloua eriopoda, Bothriochloa barbinodis,

Eragrostis intermedia) with few cacti (Opuntia engelmannii) and succulents (Agave palmeri, Nolina

microcarpa, Dasylirion wheeleri). Trees and shrubs (primarily Juniperus monosperma and Prosopis

velutina) are predominantly located on the north-facing slopes, and scattered across other slope aspects.

Limited areas of Madrean Encinal Woodland occur in the upper (western) elevations of the Project area. North-facing slopes can be densely covered with shrubs (Ceanothus breviflorus, Garrya wrightii,

Rhus choriophylla, Yucca schottii), succulents (Agave palmeri), and scattered trees (Juniperus

depeanna, Quercus arizonica, Pinus cembroides). Perennial grasses and forbs are also supported.

Xeroriparian plant communities are found along the drainages throughout the Project site. There are many shrubs and trees of various sizes. Some of the larger trees include Juglans major, Quercus

arizonica, Juniperus monosperma, Prosopis velutina, Acacia greggii, and Celtis laevigata var.

reticulata. Perennial grasses and forbs are well dispersed. Annual grasses and forbs are well represented as drainages are disturbed often by flooding events.

2.2 VEGETATION ALONG THE UTILITY CORRIDOR There are three (3) distinct vegetation communities associated with the Utility Corridor. These include the (1) transitional zone between Sonoran desertscrub and the semi-desert grassland transitional community, (2) lower encinal oak subdivision of Madrean Evergreen Woodland, and (3) xeroriparian vegetation communities. However, approximately three-quarters of the Utility Corridor is located within the Sonoran desertscrub/semidesert grassland transitional community and xeroriparian vegetation communities, and the remainder is within encinal oak communities.

Existing vegetation over most of the Sonoran Desert scrub/Semi-desert grassland area tends to be sparse with various species of cacti, locally common and exotic invasive species of Lehmann lovegrass (Eragrostis lehmanniana), Buffelgrass (Pennisetum ciliare) and snakeweed (Gutierrezia spp.). Trees are mostly limited to littleleaf paloverde (Parkinsonia microphyllum) and low-stature velvet mesquite (Prosopis velutina). As elevations increase to the east, vegetation density also increases and transitions into semi-desert grassland that supports abundant catclaw (Acacia greggii and Mimosa

aculeaticarpa), ocotillo (Fouquieria splendens), yucca (Yucca spp.). This community is where the federally listed endangered Pima pineapple cactus (Coryphantha scheeri var. robustispina) has been identified. The Pima pineapple cactus will be avoided or transplanted as described in the Biological

Monitoring Plan (MPO Volume II-f).

The higher elevations along the western flank of the Santa Rita Mountains are dominated by trees and succulents but also support grassland communities. This grassland gradually transitions into the encinal oak community as the Utility Corridor crests over the Santa Rita Mountains at Lopez Pass. Palmer’s agave (Agave palmeri), a variety of desert shrubs (Celtis pallida, Rhus trilobata), and clumps of beargrass (Nolina microcarpa) are commonly found. Along each side of the ridge, multiple species


of oak (e.g., Quercus emoryi), juniper (Juniperus spp.), and other woody shrubs typical of the encinal oak community can be found, with denser concentrations occurring along drainages and on northern exposures.

Xeroriparian areas are crossed by the Utility Corridor along the western flank of the Santa Rita Mountains. Xeroriparian habitat is characterized by higher biomass and taller-stature mesquite (Prosopis velutina) and Blue palo verde (Parkinsonia floridum) trees than those of surrounding uplands. This is due to increased soil moisture within low-lying drainages. Xeroriparian vegetation makes up a very small portion of the Utility Corridor.

Invasive species


3.0 AREA CLEARANCE AND VEGETATION SALVAGE Areas are considered available for construction activities following area clearance, which includes biological resource clearances, cultural resource clearances, and vegetation salvage. Vegetation salvage may also occur during vegetation clearing (clear and grub, and soil salvage) or construction activities. Large trees (including saleable wood) may be left in place until after construction activities commence to allow for equipment access. Following vegetation salvage, the area would be considered cleared (see Appendix A - Area Clearance Checklist), and vegetation clearing (and grubbing) may begin along with growth media salvage.

The following federally protected species, Forest Service sensitive species, or supporting species, as described in the Biological Monitoring Plan (MPO Volume II-f), may be avoided, salvaged, transplanted, or moved to suitable habitat:

• Coleman’s Coralroot (Hexalectris colemanii) • Arizona Coralroot (Hexalectris arizonica) • Arizona Manihot (Manihot davisiae) • Beardless Chinchweed (Pectis imberbis) • Pima Pineapple Cactus (Coryphantha scheeri var. robustispina) • Chiricahua leopard frog (Lithobates chiricahuensis) • Lesser long-nosed bat (Leptonycteris yerbabuenae) • Palmer’s agave (Agave palmeri) • Western yellow-billed cuckoo (Coccyzus americanus) • Sonoran desert tortoise (Gopherus morafkai)

An inventory of Coleman’s coralroot and beardless chinchweed would be completed prior to ground disturbance (FS-BR-02). Pre-activity surveys for Coleman’s coralroot would be conducted prior to decommissioning National Forest Systems Roads 4051 and 4051a. The vulnerable populations would be flagged or otherwise identified in order to avoid disturbance from decommissioning activities. Portions of NFSR 4051 and 4051A that are located near Coleman's coralroot populations that provide access for monitoring purposes will remain open as "authorized use only" roads until monitoring activities cease (FS-BR-15).

Pre-disturbance surveys will be conducted for a subset of Forest Service sensitive species as specified in FS-BR-18, which includes Arizona coralroot, Arizona manihot, and Beardless chinchweed. Cuttings of Arizona Manihot may be collected, and seeds of Beardless chinchweed may be collected prior to transplanting of these species (see Appendix D of the Biological Monitoring Plan (MPO Volume II-f) for more detail). As discussed in Section 4.2 of this Plan and FS-BR-10, pre-disturbance surveys would be conducted for Pima pineapple cactus (PPC) along the utility corridor followed by monitoring ‘by operators’ during construction. PPC located near disturbance areas would be marked and avoided. PPC that cannot be avoided would be transplanted.

Per FS-BR-12, if Chiricahua leopard frogs are found in a survey area, Rosemont would contact the Coronado to facilitate capture and relocation or otherwise determine a plan of action.

Surveys for Western yellow-billed cuckoo would be conducted during their nesting season (typically June to August) in potential habitat. Vegetation clearing would not occur within 50 meters (approximately 164 feet) of an active Western yellow-billed cuckoo nest or the center of an active territory during the nesting period. When vegetation clearing is proposed during the nesting season, Rosemont will coordinate with the Coronado and USFWS prior to clearing in suitable habitat (FS-BR-14).

A biological monitor will be present during ground disturbing activities along the utility corridor where Sonoran desert tortoise habitat is present (CEC). Details regarding sensitive and special status species can be found in the Biological Monitoring Plan (MPO Volume II-f). Tribes will be offered an opportunity to collect firewood and plants, including Palmer’s agaves, prior to ground disturbance upon request as discussed in the Cultural Resources Management Plan (MPO Volume II-i). Other plants, including


agaves, may also be transplanted to a designated area and access provided to members of consulting tribes (USFS, 2013: FS-CR-09).

Vegetation salvage by Rosemont in the main Project area will generally be limited to Palmer’s agave (see Mitigation Measure FS-BR-04 on pages B-30 and B-31 in the FEIS [USFS, 2013]), the sensitive plant species (as required) listed in Mitigation Measure FS-BR-18 (see pages B-45 and B-46 in the FEIS (USFS, 2013), and culturally important species (as required) associated with Mitigation Measure FS-CR-09 (see pages B-73 and B-74 in the FEIS (USFS, 2013). Once salvage is completed, general vegetation clearing (clear and grub) and soil salvage may commence.

If infestations of exotic invasive species are noted during area clearance activities, they would be treated prior to soil salvage. Exotic invasive species would also be surveyed and managed, to the extent practicable, prior to ground disturbance activities (see Invasive Species Management Plan [MPO Volume II-o)].

With regard to the salvage of saleable, large, woody materials, Rosemont has agreed to purchase these materials cleared from National Forest Service (NFS) lands. A preliminary volumetric estimate of this material has been made by the Coronado and is provided in this Plan. As a note, an Arizona Department of Agriculture (ADA) land-clearing permit will be required for the disturbance and clearing of State protected native plants on State and private lands, as required under the Arizona Native Plant Law (see page 32 of the FEIS, USFS 2013b). The notification would apply for clearing activities and the permits would apply only to plants removed off-site, and not transplanted, or otherwise used, in site reclamation. Permits would be the responsibility of those entities removing the plants, including nurseries, tribes, organizations, and those permitted, etc. ADA notices and permits are not required for Coronado National Forest Service lands, as the final MPO acts as the agreement for vegetation salvage and clearing between Rosemont and the Coronado.

To obtain cultural clearance, all data recovery activities must be completed before any ground-disturbing activities commence in the vicinity of an affected historic property, which include 60 sites that have been identified in FS-CR-01. A cultural monitor will be present during all ground disturbing activities to monitor for discoveries of unknown cultural resources (FS-CR-04). In the event of a discovery, the cultural monitor/project archaeologist will inform the construction foreman to cease project activities within 100-feet of the find. The cultural monitor/project archaeologist will make a determination of the significance of the discovery. If a discovery is significant, the Coronado archaeologist must provide approval before work in the area may continue. Additional details regarding cultural clearances can be found in the Cultural Resources Management Plan (MPO Volume II-i) and the Historic Properties Treatment Plan for the Proposed Rosemont Copper Project (SWCA, 2014) and A Historic Properties Treatment Plan for Rosemont Copper Utilities (EPG, 2015).

Other activities that are required for area clearance include well capping and abandonment, visual inspections for caves / sinkholes and paleontological resources, closure of abandoned mine features, and inspection of road-decommissioning activities. Well capping/abandonment (OA-GW-08) could occur during area clearance following biological and archaeological clearances, or following area clearance during construction activities. Upon discovery of significant paleontological resources (FS-GMP-01), cave or sinkhole (FS-GMP-02), work would be suspended at that site until permission to commence work is provided by the designated Forest Service representative. Mine features (including adits, shafts, and vents) encountered during area clearance will be properly marked and closed. The 20 mine features that are specified in FS-BR-13 will follow closure plans specified in the Biological


Ground disturbing activities (other than between the Perimeter Fence and Security Fence), such as vegetation clearing and grubbing (clear and grub) and growth media salvage, could be conducted once pre-disturbance conditions are met (area clearance).

Ground-disturbing activities between the Perimeter Fence and Security Fence will be limited (FS-CR-05). Prior to ground disturbance, permission will be obtained from the Coronado. Activities that could not avoid cultural sites would be cleared prior to disturbance. Clearance would include testing and data recovery.


During construction activities, visual inspections for caves/sinkholes, paleontological resources, and mine features will continue. If any findings occur, they will be handled as previously described.

Facilities will be placed within clear-limit boundaries, or otherwise reported to the proper agency. The construction of the perimeter fence would exclude the public from coming into contact with mining operations and potentially hazardous conditions (FS-PHS-01). Daily inspections during installation would ensure that the location and construction techniques comply with the final MPO.

The plant site and building construction would be built or placed in accordance with the plans in the final MPO. During closure and final reclamation, monitoring would be conducted to ensure that those areas avoided during construction were not destroyed or directly impacted by building removal and plant reclamation activities (FS-BR-01). The coarse ore stockpile dome and pebble crusher/ball loading facility footprints will be inspected during construction and removal of the facilities to ensure that Coleman’s coralroot are avoided (FS-BR-02).

Daily inspections will be conducted during construction and decommissioning of the electric power line loop that would be constructed on the west side of the pit and within the disturbance perimeter of the pit and diversion structures in order to avoid talus slopes and talus snail habitat. If disturbance occurs outside of the planned footprint, it would be reported to the Coronado within 24 hours (FS-BR-06).

Per OA-SR-01, weekly inspections would occur during construction of the power supply line and water supply line to ensure that the location complies with the ACC, CEC, and final MPO.

Daily inspections of the footprint of the tailings facility will ensure that the footprint is within the area specified in the FEIS/ROD and that those facilities are constructed in accordance with the final MPO (OA-GW-05).

Per FS-SR-03, weekly inspections of the perimeter buttress to ensure that 1) the locations are that specified in the FEIS/ROD/final MPO 2) geometry of facility adheres to final MPO specifications 3) waste rock placement in accordance with the Aquifer Protection Permit and stacking plan from the final MPO and 4) facilities are stable.


4.0 CLEARING AND GRUBBING Clearing refers to the removal of trees and other aboveground vegetation while grubbing refers to the removal of large underground plant material, such as stumps, roots, and buried logs. Grubbing would occur only where required. Growth media salvage would follow vegetation clearing and grubbing. Growth media includes topsoil (O horizon [if present], A horizon, and B horizons) and subsoil horizon (C horizon) and will be re-used to promote vegetation growth, hydrologic function, and stability. Details regarding soil salvage, per Mitigation Measure FS-SR-01, can be found in the Revegetation and

Growth Media Monitoring Plan (MPO Volume II-v).

Once the biological and archaeological clearances for an area are obtained, vegetation clearing and grubbing may commence prior to or along with growth media salvage. In general, once salvageable vegetation is removed, the remaining vegetation will need to be cleared and/or removed along with the growth media. It is anticipated that grasses and smaller vegetation will be cleared with the growth media to enhance the seed bank for the revegetation process. Larger woody materials will either be chipped/shredded and used as mulch for reclamation and erosion control purposes, or placed directly on the reclamation surfaces to provide habitat.

Clearing and grubbing activities are anticipated to begin six (6) to 12 months prior to when an area is needed for construction/development activities. As previously noted, vegetation salvage may occur simultaneously with clearing and grubbing activities. Regardless of sequencing, it may be necessary to trim or clear vegetation in order to access salvageable plants. Vegetation to be salvaged will be clearly marked.

The following are covered in this section:

• Vegetation clearing at the main Project area;

• Vegetation clearing along the Utility Corridor; and

• Vegetation clearing in other areas.

The anticipated vegetation clearing sequence for the main Project site (locations of construction and activities) is provided in the Reclamation and Closure Plan (MPO Volume III-a). Details for the Utility Corridor are provided in the Utility Corridor Reclamation Plan (MPO Volume III-b).

4.1 VEGETATION CLEARING IN MAIN PROJECT AREA Large shrubs and smaller trees removed during clearing will be shredded, chipped, or cut to manageable sizes for reclamation uses. Woody material to be used as surface mulch will be shredded or chipped. Current University of Arizona revegetation studies (Fehmi personal comm., 2014) suggest that a thin layer (1-centimeter [cm] or less cover) of woody plant mulch applied to the soil surface can aid in seedling establishment. Shredded mulch also does not require the use of a tackifier to keep it in place. As such, the placement of an approximate 1-cm thick layer (or 2 tons per acre) is planned on top of the soil surface in order to help seed establishment and to enhance soil stability. Stored mulch will be applied by mechanical equipment, such as dozers or agricultural tractors, and will occur following seeding operations. Mulching rates may increase for areas that have higher potential for erosion, but will remain at levels that will not inhibit seed germination. Using materials that are on-site will also reduce the potential to introduce new exotic invasive species. As detailed in the Invasive

Species Management Plan (MPO Volume II-o), equipment used for mulch application will be cleaned prior to coming on-site to prevent invasive plant spread.

Shredded, chipped, or otherwise processed woody material may be used for mulch as long as it is available. Woody debris may also be used in filter berms, filter socks, and in other forms of erosion control. Filter berms are generally trapezoidal shaped, and when placed perpendicular to sheet flow, controls erosion and retains sediment. Unlike silt fences, filter berms allow water to pass through. Filter socks are mesh tubes (8-, 12-, 18-, or 24-inches in diameter) that are filled with chipped woody materials and used to control sheet-flow runoff and to reduce erosion and retain sediment.


Grasses, forbs, cacti, and small shrubs will be removed with the growth media. This plant material will contribute to the re-establishment of the local genetic stock as some seeds will remain in the soil (seed bank) or attached to the plants. Rhizomes and other underground reproductive material will increase the ability of these plants to tiller (sprout) and become re-established on the Landform or other reclamation areas. Plant material that dies during the salvage process will be a source of organic matter for soil microbes.

Large segments of trees, including stumps, branches, and coarse woody material, will be scattered onto the reclaimed Landform, etc., following seeding to improve slope stability, add organic matter, and enhance microhabitats for invertebrate and small vertebrate species (see Mitigation Measure “FS-SR-01: Growth media salvage and application” on pages B-8 through B-11 of the FEIS [USFS, 2013b]). Large debris may be applied (scattered) at a rate from 10 to 30 tons per acre (Girard personal comm., 2013) while material is available. Density of woody debris will meet guidelines that are portrayed in the draft Coronado Forest Plan (USFS, 2013a). Burying cleared and grubbed material is not being considered. Large debris will be applied in a manner that does not negatively impact seeded areas.

An estimate of large, merchantable (saleable) woody material was calculated by SWCA and provided to the Coronado. SWCA estimated approximately 23,000 cords of wood is salvageable at the Rosemont site. One cord is equal to approximately 128 cubic feet, for a total of 2,944,000 cubic feet of wood.

As noted in Section 2.0, most of the large trees that would comprise the merchantable woody material are located within the drainages of Barrel Canyon Wash, Wasp Canyon Wash, and few side drainages. Woody vegetation is also located on north-facing slopes and in smaller quantities on other slope aspects. Removal of these trees would begin by cutting trees to near ground level. Trees may be cut into manageable sizes according to future uses, and then hauled away to areas either approved in advance by the Forest Service or to areas not on National Forest Service lands. Tree cuttings that are not sold would be placed/scattered on the reclaimed areas or shredded/chipped and used as mulch. Placing woody material on the reclaimed slopes will provide visual texture and the opportunity for microhabitats.

If vegetation clearance and/or ground disturbance is necessary between the Security and Perimeter Fences, it must be approved by the Coronado prior to the disturbance. As with other areas, biological and cultural clearance (as described above) must also be obtained.

Once area clearance is provided, mass vegetation clearing can proceed (per this Plan) followed by growth media salvage (see Mitigation Measure FS-SR-02 on pages B-8 through B-11 of the FEIS [USFS, 2013b]). Details specific to growth media salvage are provided in the Revegetation and Growth

Media Monitoring Plan (MPO Volume II-v).

4.2 VEGETATION CLEARING ALONG THE UTILITY CORRIDOR Per the Utility Corridor Reclamation Plan (MPO Volume III-b), disturbance within the Utility Corridor would be limited to the extent practicable and areas would be defined to preserve pockets of existing vegetation. This will reduce visual impacts and will preserve mature plant specimens for habitat recovery enhancement (reclamation).

Xeroriparian areas or sensitive plant specimens (i.e., saguaro cacti [Carnegiea gigantea]) would be avoided when possible. The endangered Pima pineapple cactus (Coryphantha scheeri var. robustispina; see Mitigation Measure FS-BR-10 on page B-37 in the FEIS [USFS, 2013]) would also be avoided, where possible. Other eligible specimens to avoid would include mature trees, shrubs, succulents, beardless chinchweed, or diverse vegetation groupings that would provide seed sources or microclimates for seedling germination along edges of the Utility Corridor right of way (ROW). Flagging or fencing of specimens to be preserved would be done before ground is disturbed. The flagging should delineate a buffer equal to or greater than the drip line/canopy cover perimeter of the plant to be avoided. Avoidance would also include Palmer’s agave (Agave palmeri; see Mitigation Measure FS-BR-04 on pages B-30 and B-31 in the FEIS [USFS, 2013]) to the extent practicable.


Specimens of Pima pineapple cactus that cannot be avoided will be transplanted (Mitigation Measure FS-BR-10) within the Utility Corridor into a suitable habitat and watered for the first few months followed by regular monitoring. Based on the 2009 Pima pineapple cactus Pima Pineapple Survey: Proposed

Rosemont Project Santa Rita Road Waterline (Westland, 2009), approximately forty-eight (48) Pima pineapple cacti occur within the Utility Corridor area of disturbance. For specific requirements regarding the Pima pineapple cactus, including other sensitive or special status species, see the Biological


Agaves and saguaros that qualify for salvage must be (1) currently in a healthy condition, as determined by qualified personnel, (2) agaves must not possess flower stalks, and (3) saguaros must be less than 15 feet in height. Sensitive plant species listed in Mitigation Measure FS-BR-18 (see pages B-45 and B-46 in the FEIS [USFS, 2013]) will be managed as specified in the Biological Monitoring

Plan (MPO Volume II-f), and select culturally important species will be managed as specified in the Revegetation and Growth Media Monitoring Plan (MPO Volume II-v; see Mitigation Measure FS-CR-09 on pages B-73 and B-74 in the FEIS [USFS, 2013]). Vegetation that does not qualify for salvage will be mixed into the growth media as a source of organic matter.

The orientation of succulents and cacti would be marked prior to salvage. Plants will be transplanted outside of the disturbance footprint in the designated Utility Corridor ROW.

Trees will either be removed or trimmed. Removal will generally consist of cutting trees off at or near ground level. The trees, or tree trimmings, may be scattered onto the reclaimed surfaces following seeding or shredded/chipped and used for mulch or erosion control. Tree trimming will minimize or reduce visual impacts. Tree trimming will occur prior to commencing work on the ROW to allow for clearance of construction vehicles and equipment. American National Standards Institute (ANSI) A300 will be used as a guideline to prune trees. When feasible, deciduous tree species will be pruned during their dormancy periods of the winter and (in some species) summer months. When feasible, evergreen tree species will be pruned late spring to early summer (approximately April to June), prior to the monsoon season, as pruning during high-moisture weather periods can result in fungal growths.

In some cases, vegetation shredding/chipping may occur in conditions where tree cutting is not feasible. Vegetation shredding involves the removal of brush and occasionally small trees by the use of a tractor-mounted flail or blade that shreds plants to the ground or to the desired height. This practice produces mulch made of leaves, pieces of branches, and woody fiber.

Soil will be disturbed during pipeline trenching and other construction activities along the Utility Corridor. Soil segregation will separate growth media from subsoils. Soil salvage for the Utility Corridor consists of the uppermost layer of the soil that contains organic material, including the seeds of plants growing on the site. Storage of salvaged soil will be located at designated sites within the Utility Corridor. Soil salvage, storage and replacement will follow the protocols outlined in Section 7.0 of the Revegetation

and Growth Media Monitoring Plan (MPO Volume II-v).

During final reclamation activities of the Utility Corridor, it may be necessary to clear vegetation. Final reclamation activities, as outlined in Mitigation Measure FS-VR-02 (see pages B-60 and B-61 in the FEIS [USGS, 2013], include the removal of some roads, power line, and piping systems, and the water supply pipeline. The Utility Corridor will be reclaimed during the Closure Phase (see Utility Corridor

Reclamation Plan [MPO Volume III-b]). Following initial construction of the utilities, seeding and/or planting will occur in disturbed areas of the Utility Corridor.

4.3 VEGETATION CLEARING IN OTHER AREAS Vegetation clearing may be necessary to abandon wells and boreholes (see Mitigation Measure OA-GW-08 on page B-87 of the FEIS [USFS, 2013]). These sites may have been abandoned for many years and vegetation may need to be cleared for access. This vegetation may remain in place, be pruned, or be removed. When vegetation is to remain in place, access may be provided using the overland drive and crush method. This technique minimizes surface disturbance for short-term access. Vegetation may be driven on by equipment but not removed. This method is described in the Utility

Corridor Reclamation Plan (MPO Volume III-b), which is part of the Reclamation and Closure Plan


(MPO Volume III-a). Alternatively, trees and shrubs may be cut back to allow for access, following the guidelines described in Section 4.2 of this Plan for trimming. If vegetation must be removed for access, trees and shrubs may be cut off at or near ground level. Debris from pruning or tree/shrub removal may be placed in selected areas to assist in erosion control, or chipped/shredded and spread across the soil surface. In areas within the footprint, vegetation will ideally be cleared prior to well abandonment. Well abandonment activities are scheduled to start in the Pre-Mining Period and include unused wells and boreholes.

Vegetation clearing may be necessary for final reclamation activities to be conducted in the Final Reclamation and Closure Phase (Closure Phase). Final reclamation activities, as outlined in Mitigation Measure FS-VR-02 (see pages B-60 and B-61 in the FEIS [USFS, 2013]), include the removal of buildings, the plant site, some roads, the perimeter and security fence, power supply line, and the water supply pipeline. Vegetation that is found at the plant site is included in Section 2.1 of this Plan. Vegetation found along the power line and water supply line is included in Section 2.2 of this Plan as well as in the Utility Corridor Reclamation Plan (MPO Volume III-b). Re-contouring of the plant site and burial of building foundations may require vegetation clearing and ground disturbance. Foundations will be buried where disturbance has previously occurred, if possible, but may require additional vegetation clearing and ground disturbance. Documented sensitive species, including the Coleman’s coralroot, will be avoided during vegetation clearing activities as described in the Biological Monitoring

Plan (MPO Volume II-f).


5.0 MONITORING AND REPORTING Monitoring and reporting components for this Plan are listed below.

5.1 MONITORING

The following monitoring requirements are required under this Plan:

• Pre-disturbance Clearance: Prior to disturbance, a survey of Palmer’s agaves would be conducted to refine the estimates of agaves that would be impacted (Mitigation Measure FS-BR-04). Areas to be disturbed would first receive clearance regarding biological and archaeological resources. Depending on site conditions, the salvage of plant materials may be concurrent with vegetation clearing. Consulting tribes will be offered access to salvage vegetation (and for other purposes). An inventory of vegetation salvaged by consulting tribes will be recorded. Note: Consulting tribes have been offered an opportunity to salvage plants for medicinal, ceremonial and craft purposes (per FS-CR-07 and FS-CR-09).

• Some biological clearances, such as for bats, western yellow-billed cuckoo, etc., are time-dependent (see Appendix A - Area Clearance Checklist for species to clear and Biological

Monitoring Plan [MPO Volume II-f] for survey/detection times). Open and/or abandoned boreholes or wells would be capped (OA-GW-08). Surveys for invasive species would be conducted prior to ground disturbance. Infestations of invasive species would be treated as soon as they are identified or as soon as conditions are appropriate for treatment (FS-SR-02), as detailed in the Invasive Species Management Plan (MPO Volume II-o).

• Construction monitoring: Monitoring the avoidance of, impact to, or mitigation of: Coleman’s coralroot and beardless chinchweed (FS-BR-02), Pima pineapple cactus (FS-BR-10), Sonoran desert tortoise (CEC), Forest Service sensitive species (FS-BR-18), nesting areas of the yellow-billed cuckoo (FS-BR-14), excavation and data recovery of cultural sites (FS-CR-01 and FS-CR-04), and approval of ground-disturbing activities between security and perimeter fences (FS-CR-05). Monitoring and reporting of unintended discoveries of cultural, paleontological, cave resources or sinkholes (FS-GMP-01 and FS-GMP-02). Facilities would be placed within the boundaries according to plans for the perimeter fence (FS-PHS-01), plant site (FS-BR-01), coarse ore stockpile dome and pebble crusher/ball loading facility (FS-BR-02), power line that would be constructed near talus slopes (FS-BR-06), and the power line and water supply line complies with the ACC, CEC, and final MPO (OA-SR-01). The footprint of the tailings facility would be as specified in the FEIS/ROD (OA-GW-05). The footprint of the perimeter buttress would be as specified in the FEIS/ROD/final MPO (FS-SR-03).

• Saleable Wood: Tracking the amount of saleable wood removed from the site.

• Salvaged plants: An inventory of species that were transplanted will be maintained in order to keep track of culturally important plants (FS-CR-09), as well as plants that will be used for revegetation purposes (FS-BR-04).

• Sensitive and special status species: Details regarding sensitive and special status species (Mitigation Measures FS-BR-02, FS-BR-10, FS-BR-12, FS-BR-13, FS-BR-14, FS-BR-15, FS-BR-18) are found in the Biological Monitoring Plan (MPO Volume II-f).

• During the Final Reclamation and Closure Phase, weekly inspections will be conducted of the plant site decommissioning to ensure the actions comply with permits. This will include all closure activities including removal, disturbance, and reclamation of the plant site, buildings, some roads, the perimeter and security fence, power supply line, piping systems, and water supply pipeline (FS-VR-02).


5.2 REPORTING

Quarterly and annual reporting to the Forest Service on the monitoring elements will be provided under this or another appropriate plan. Reporting on other aspects of vegetation clearing, such as clearance notifications and the results of pre-disturbance surveys, are covered under other plans.

An inventory of transplanted culturally important vegetation will be reported to the Forest Service annually (Mitigation Measure FS-CR-09). Tribal access for salvaging plants and other purposes will be documented and reported annually under the Cultural Resources Management Plan [MPO Volume II-i). Cultural resources findings would be also reported annually under the Cultural Resources

Management Plan [MPO Volume II-i). Biological resources will be reported under the Biological

Monitoring Plan (MPO Volume II-f). Saleable wood removed from the site would be reported annually under this Vegetation Clearing and Area Clearance Plan.

During the Final Reclamation and Closure Phase, quarterly reporting of closure activities will occur according to FS-VR-02.


6.0 CLOSURE AND BOND RELEASE This section addresses closure activities associated with this Plan as well as the approach for funding of those activities and bond release of those funds. If bonding is set for one year or less (i.e., simply completing test work or finalizing reporting) no bond release is proposed. For longer periods, the bonding terms and application for bond release, as well as the mechanism for that release, are included.

6.1 INTERIM CLOSURE There are no interim closure activities associated with this Plan.

6.2 FINAL CLOSURE There are no final closure requirements associated with this Plan. General monitoring costs are included in the Reclamation and Closure Plan (MPO Volume III-a).

6.3 BOND RELEASE There is no bonding associated with this Plan.


7.0 DATA MANAGEMENT Rosemont currently maintains data in various formats currently including logbooks, electronic logbooks, spreadsheets, hardcopy and database formats. It is Rosemont’s intent that ultimately a robust database will be used to house all data collected for the various monitoring programs. Numeric data ultimately will be stored in a database and spatial data will be maintained in an ESRI database.

Depending upon the type of data to be reported, Rosemont will develop custom reports displaying required information in table or figure format. Electronic submittals will be provided in pdf format to provide a permanent record of the submittal and “raw” data will be maintained on-site for review by the Forest Service. If the Forest Service requests numeric data, it may include information such as cumulative results documenting the monitoring history and include baseline data for the resource.

Electronic submittals will be made on the reporting period specified. Reports will be submitted in hardcopy form with a duplicate electronic pdf file. Delivery of the electronic files will depend upon the size of the file and will either be made via email, via a CD/DVD or thumb drive, or via a website set up and maintained for delivery of files to the Forest Service. Details regarding access will need to be worked out so transmittals can take place seamlessly.


8.0 REFERENCES Brown, D. E. Ed. Biotic Communities: Southwestern United States and Northwestern Mexico. Salt Lake

City, University of Utah Press. 1994. Print.

EPG, 2015. A Historic Properties Treatment Plan for Rosemont Copper Utilities, Pima County, Arizona.

November 2015 (Protected document- not publicly available)

Fehmi, J.S. 2014. Personal communications. University of Arizona. Tucson, AZ.

Girard, Michele. 2013. Personal communications. Coronado National Forest. Tucson, AZ.

SWCA, 2014. Historic Properties Treatment Plan for the Proposed Rosemont Copper Project, Pima

County, Arizona. December 2014 (Protected document- not publicly available)

USFS, 2013a. Coronado National Forest Draft Land and Resource Management Plan: Cochise,

Graham, Pima, Pinal, and Santa Cruz Counties, Arizona and Hidalgo County, New Mexico. MB-R3-05-7. October 2013.

2013b. Final Environmental Impact Statement for Rosemont Copper Project- A Proposed

Mining Operation, Coronado National Forest, Pima County, Arizona; Appendix B Mitigation and

Monitoring Plan; Biological Opinion; MOA. December 2013.

2017a. Errata – Rosemont Copper Project Final Environmental Impact Statement. April 26, 2017.

2017b. Record of Decision – Rosemont Copper Project and Amendment of the Coronado Land

and Resource Management Plan. June 6, 2017.

Westland, 2009. Pima Pineapple Cactus Survey: Proposed Rosemont Project Santa Rita Road

Waterline. December 18, 2009.

FIGURE

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Project:

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Date:

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Vegetation Clearing andArea Clearance Plan

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Source:

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Figure 1. Rosemont Project Location Map

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APPENDIX A

Area Clearance Checklist

of 2

Area Clearance Checklist

Date(s) of work: Sign-off Date: Specific location of work/Area to be cleared: Purpose of ground disturbance/Description of work: Is Biological Monitor required for ground disturbance activities? Yes No Reason for Biological Monitor: Note: Cultural Monitor is required to be present for all ground disturbing activities. Biological Monitor is required to be present during ground disturbing activities for Sonoran Desert Tortoise monitoring on West Side and during powerline installation/decommissioning near talus slopes.

BIOLOGICAL RESOURCES: Cleared, Salvaged, Marked and/or Fenced off from disturbance: Yes - None Found - Not Applicable Y NF NA

Coleman’s Coralroot Arizona Coralroot Arizona Manihot Beardless Chinch-weed Pima Pineapple Cactus* (West Side) Palmer’s Agave Invasive plant survey / infestation treatment

Clearance for: Yes - Not Applicable Y NA

Chiricahua Leopard Frog American Bullfrog and/or other invasive aquatic animals Lesser Long Nosed Bat & roosts Western Yellow-billed Cuckoo nesting sites Sonoran Desert Tortoise (West Side)* Track amount of saleable wood:

ADA Protected Native Plants and Wood Removal Permit

CULTURAL RESOURCES*: Cultural survey completed Cultural data recovery conducted, if applicable

OTHER: Well(s) capped / abandoned Visual inspection for caves and / or sinkholes* Closure of abandoned mine feature in area* Visual inspection for paleontological resources* Placement of facilities per MPO Placement of powerline according to the

CEC/Waterline according to ROW Inspection of road-decommissioning (avoiding impacts to preserved areas)

Placement of facilities with regard to talus slopes

If ground disturbance occurs between Security & Perimeter Fences, Forest approval must be obtained

Other:

*Monitoring will continue during ground disturbing activities.

of 2

Notes: Authorized Signature: Date: Printed Name: Name of Cultural Monitor(s) who performed clearance: Name of Biological Monitor(s) who performed clearance:

vegetation clearing and area clearance plan

Documents