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HomeMy WebLinkAbout1.10 Wildlife_Veg Report Article 4-203.G.6 Wildlife and Vegetation Impact Analysis Ursa Operating Company Speakman A Booster Compressor OA Project No. 015-3104 URSA OPERATING COMPANY, LLC. SPEAKMAN A INJECTION WELL Impact Analysis: Section 4-203-G (8) Environmental Impacts Garfield County Land Use and Development Code Cover photo: View across the Colorado River to the Speakman A well pad location (center). Prepared for: Ursa Operating Company, LLC. Prepared by: WestWater Engineering 2516 Foresight Circle #1 Grand Junction, CO 81505 In cooperation with: Olsson Associates, Inc. Nicholas Jaramillo, Biologist/Environmental Scientist February 2014 WestWater Engineering Page 1 of 13 February 2014 INTRODUCTION Project Description At the request of Olsson Associates, Inc. (Olsson), on behalf of Ursa Operating Company, LLC. (Ursa), WestWater Engineering (WestWater) has prepared this Garfield County Impact Analysis for the proposed Speakman A Injection Well project. The proposed injection well would be located on the existing Speakman A well pad location, and no new surface disturbance would be required. This project would be located on private lands in Section 24, Township 7 South, Range 96 West; Sixth Principal Meridian in Garfield County, Colorado (Figure 1). The purpose of the well is to dispose of produced water and flow-back water from Ursa’s drilling operations. The current primary uses of the project area are rural residential, rangeland, natural gas development, and wildlife habitat. This document reports the results and analysis of findings pertinent to the Garfield County Land Use and Development Code (July 15, 2013) as they apply to this project. Survey Methods The project area was evaluated for the potential occurrence of special status plants and wildlife, raptors, noxious weeds, and potential Army Corps of Engineers jurisdictional Waters of the U.S. by WestWater biologists on January 31, 2014. The survey took place outside the active growth period for plants in the project area and several inches of snow cover impeded plant identification and detection of weed species. The survey also took place outside the active nesting season for migratory birds and raptors in the project area. Based on existing survey data, literature review, and firsthand knowledge and experience of biological resources in the geographical area, WestWater biologists have made assertions regarding the plant and animal species which may or may not be present in the project area. Vegetation communities were determined through aerial photography, on-the-ground assessments, and WestWater’s previous experience in the project area. Plant species occurrence and identification was aided by using pertinent published field guides (Kershaw et al. 1998, Spackman et al. 1997, Weber and Wittmann 2012, Whitson et al. 2001, CWMA 2007). Mapped soil types, as published by the Natural Resources Conservation Service (NRCS), U.S. Department of Agriculture (USDA), were reviewed to determine the soil types and expected natural vegetation characteristics at the project site (NRCS 2014). Raptor and special status wildlife species surveys were conducted on foot within 0.25 miles of project features within suitable habitats for these species. Noxious weed conditions are reported in an Integrated Vegetation and Noxious Weed Management Plan (IVNWMP) that was prepared separately for this project (WestWater 2014). Data locations were recorded using handheld Global Positioning System (GPS) units (Datum: NAD83, Zone 12) and photographs were taken of the habitat, terrain, and biological features found during the survey. SECTION 4-203-G (8) - ENVIRONMENTAL IMPACTS EXISTING ENVIRONMENTAL CONDITIONS WATERS OF THE U.S. – Army Corps of Engineers (ACOE) WestWater biologists determined that no ACOE jurisdictional wetlands or drainages showing characteristics of Waters of the U.S. would be affected by the project. VEGETATION Native vegetation near the pad site is consistent with sagebrush communities and pinyon/ juniper woodlands that occur in the Colorado River valley corridor. Below the site much of the area is pastureland that leads into a riparian plant community. Common plant species observed or expected near the site are included in Table 1. WestWater Engineering Page 2 of 13 February 2014 Table 1. Common plant species observed or expected near the site. Common Name Scientific Name Common Name Scientific Name Bottlebrush squirreltail Elymus elymoides Pinyon pine Pinus edulis Brittle pricklypear cactus Opuntia fragilis Prairie junegrass Koeleria macrantha Broom snakeweed Gutierrezia sarothrae Rayless tansyaster Machaeranthera grindelioides Crested wheatgrass Agropyron cristatum Rubber rabbitbrush Ericameria nauseosa Eaton's fleabane Erigeron eatonii Sandberg bluegrass Poa secunda Hood's phlox Phlox hoodii Utah juniper Juniperus osteosperma Indian ricegrass Achnatherum hymenoides Utah serviceberry Amelanchier utahensis Low pussytoes Antennaria dimorpha Wyoming big sagebrush Artemisia tridentata var. wyomingensis Threatened, Endangered, Sensitive Plant Species The proposed injection well would be located on an existing well pad and no new surface disturbance would be required. The area immediately surrounding the Speakman A pad consists of former pinyon- juniper woodland and sagebrush rangeland that has historically been developed for agricultural purposes (hay pasture) and would not provide habitat for any special status plant species. A review of the Colorado Rare Plant Field Guide (Spackman et. al. 1997) and WestWater’s database indicated that no special status plant species are expected to occur in the project area. Noxious Weeds Noxious weed infestations, control techniques, and revegetation recommendations are reported in an IVNWMP that was prepared for this project (WestWater 2014). Noxious weed species listed by the State of Colorado (2005) detected in the project area included cheatgrass (Bromus tectorum), field bindweed (Convolvulus arvensis), redstem filaree (Erodium cicutarium), and tamarisk (Tamarix ramosissima). Several unlisted nuisance weed species that may be present in disturbed areas, including flixweed (Descurania sophia), kochia (Bassia scoparia), prostrate knotweed (Polygonum aviculare) ,prostrate pigweed (Amaranthus albus), Russian thistle (Salsola spp.), tumble mustard (Sisymbrium altissimum), and yellow sweet clover (Melilotus officinalis). WILDLIFE Threatened, Endangered, and Candidate Wildlife Species The project area was evaluated for threatened, endangered, or sensitive wildlife species listed in Garfield County (Table 2) (USFWS 2014). Table 2. Federal Threatened, Endangered, and Candidate Wildlife Species for Garfield County. Common Name Scientific Name Status Bonytail Gila elegans Endangered Canada lynx Lynx canadensis Threatened Colorado pikeminnow Ptychocheilus lucius Endangered Greater Sage-grouse Centrocercus urophasianus Candidate Greenback cutthroat trout* Oncorhynchus clarki stomias Threatened Humpback chub Gila cypha Endangered Mexican spotted owl Strix occidentalis lucida Threatened Razorback sucker Xyrauchen texanus Endangered WestWater Engineering Page 3 of 13 February 2014 Table 2. Federal Threatened, Endangered, and Candidate Wildlife Species for Garfield County. Common Name Scientific Name Status Yellow-billed cuckoo Coccyzus americanus Candidate Bold = Species which may be affected by project. * Recent genetic studies indicate that pure greenback cutthroat trout likely do not exist in western Colorado. Until the review and rulemaking process is complete, the U.S. Fish and Wildlife Service is recommending that “Lineage GB” cutthroat trout , which do exist in western Colorado, be managed as greenback cutthroat (USFWS 2012) Designated critical habitat for two endangered fish species (Colorado pikeminnow and razorback sucker) occurs in the Colorado River adjacent to the project and these species have been documented near Parachute (Maddux et al. 1993). Designated critical habitat for two additional species (bonytail and humpback chub) occurs downstream of the project near Grand Junction (Maddux et al. 1993). No other species listed in Table 2 would be expected, as habitat conditions are not appropriate for these species. Raptors At least fifteen raptor species may be found in suitable habitats surrounding the project area (Table 3). Nesting season for raptor species in this area takes place from January through mid-August. The most common raptor species observed in the area include American Kestrel, Cooper’s Hawk, Golden Eagle, Great Horned Owl, and Red-tailed Hawk. Bald Eagles have also been observed frequently along the Colorado River in recent years. Table 3. Raptor species that may nest near the project area. Common Name Scientific Name BCC* American Kestrel Falco sparverius No Bald Eagle§ Haliaeetus leucocephalus Yes Cooper’s Hawk Accipiter cooperii No Flammulated Owl Otus flammeolus Yes Golden Eagle Aquila chrysaetos Yes Great Horned Owl Bubo virginianus No Long-eared Owl Asio otus No Northern Harrier Circus cyaneus No Northern Pygmy Owl Glaucidium gnoma No Northern Saw-whet Owl Aegolius acadicus No Peregrine Falcon+§ Falco peregrines Yes Prairie Falcon Falco mexicanus Yes Red-tailed Hawk Buteo jamaicensis No Sharp-shinned Hawk Accipiter striatus No Swainson’s Hawk Buteo swainsoni No *BCC=U.S. Fish and Wildlife Service, Bird of Conservation Concern (USFWS 2008) + State species of concern (CPW 2014b) §BLM sensitive species (BLM 2009) The raptor survey was conducted outside the active nesting season for most species in the area. No raptor nests were detected within 0.25 miles of the proposed injection well. Due to close proximity to a major county road and several residences, the few scattered cottonwood trees between the project and the Colorado River would provide only marginal nesting habitat. The juniper woodlands south of the project would provide poor to marginal raptor nesting habitat due to low tree height and a very dense canopy in some areas. Higher quality raptor nesting habitat is available nearby, but beyond the 0.25-mile survey WestWater Engineering Page 4 of 13 February 2014 area for this project. It is likely that most raptors in this area would choose to nest more than 0.25-mile from the project. Suitable raptor nesting habitat and NDIS mapped Bald Eagle winter range and roost areas are illustrated in Figure 2. Birds of Conservation Concern, Migratory, and Non-migratory Birds (other than raptors) WestWater biologists evaluated the project area for migratory bird species that could be affected by the project. Birds of Conservation Concern (BCC) have been identified by the U.S. Fish and Wildlife Service (USFWS) for priority conservation management in an attempt to prevent or remove the need to list additional species under the Endangered Species Act (USFWS 2008). The survey was conducted in winter, when most neo-tropical migrant bird species would not be expected to occupy the area. A thorough literature review was conducted to identify BCC species with potential to occur during other times of the year (Table 4) (Andrews & Righter 1992, Kingery 1998, Righter et al. 2004). Table 4. BCC sensitive species that may occur in the project area. Common Name Scientific Name Status Habitat Description Potential to Occur Brewer’s Sparrow Spizella breweri BCC/BLM* Expansive sagebrush shrublands; occasionally found in greasewood or other shrublands. Likely to occur in sagebrush shrublands near the project area. Cassin’s Finch Carpodacus cassinii BCC May occur in pinyon-juniper woodlands and riparian cottonwood. May occur in pinyon- juniper habitat near the project area. Gray Vireo Vireo vicinior BCC Mature pinyon-juniper woodlands. May occur in pinyon- juniper habitat near the project area. Juniper Titmouse Baeolophus griseus BCC Pinyon-juniper woodlands. Likely to occur in pinyon-juniper habitat near the project area. Lewis’s Woodpecker Melanerpes lewis BCC Pinyon-juniper woodlands and riparian cottonwoods. May occur in pinyon- juniper or ripiarian habitats near the project area. Pinyon Jay Gymnorhinus cyanocephalus BCC Pinyon-juniper woodlands. Likely to occur in pinyon-juniper woodlands. * BLM sensitive species (BLM 2009) U.S. Fish and Wildlife Service guidance indicates that developments may potentially affect nesting migratory birds within 100-feet of a project. The survey took place outside the time period when many of these species would be found in western Colorado and no nesting was observed. Common Raven, Dark- eyed Junco, and Horned Lark were observed during surveys. American Elk and Mule Deer The site is located in CPW Game Management Unit (GMU) 42. The project area is within CPW-NDIS mapped mule deer severe winter range and a winter concentration area (CPW 2014a) (Figure 3). The site is located within a mapped elk winter concentration area (Figure 4). Both species utilize the area extensively throughout the winter. Mule deer were observed during the survey and elk tracks were noted in several locations. WestWater Engineering Page 5 of 13 February 2014 Black Bear and Mountain Lion CPW-NDIS mapping shows the project area to be within overall range for black bear and mountain lion and both species are known to occur nearby (CPW 2014a). The project area is mapped by CPW as a potential mountain lion/human conflict area and near a mapped black bear/human conflict area (Figure 5). Bears most likely occur in the area in late summer or early fall as they search for food. Black bears’ diets vary based on seasonal food availability, although their mainstay is vegetation. In spring, emerging grasses and succulent forbs are favored. In summer and early fall, bears take advantage of berries and other fruits, as well as acorns. Bears prey on other animals and will consume carrion opportunistically. Black bears typically hibernate from late fall through late spring. Mountain lions typically follow migrating deer herds, which provide their primary food source. Lions tend to have large territories and are highly mobile as they search for food or new territories. Mountain lions likely inhabit the general project area primarily during the winter months, but could be found year- round. Small Mammals Common small mammal species in the project area include coyote (Canis latrans), cottontail (Sylvilagus nuttallii), northern pocket gopher (Thomomys talpoides), least chipmunk (Tamias minimus), and a multitude of rodent species. Bobcat (Lynx rufus) tracks were observed in the snow during surveys. Reptiles Bull snake (Pituophis catenifer), collared lizard (Crotaphytus collaris), plateau striped whiptail (Cnemidophorus velox), racer (Coluber constrictor), sagebrush lizard (Sceloporus graciousus), short- horned lizard (Phrynosoma hernandesi), western terrestrial garter snake (Thamnophis elegans), and western rattlesnake (Crotalus viridis) are reptiles potentially occurring in the project area (Hammerson 1999). No reptiles were observed during surveys, as the site visit took place in winter. These species do not have any special protection by CPW or USFWS. Aquatic Species Since there are no permanent water sources within the project area no aquatic species are expected to occupy the area. The Colorado River is located within 0.5-mile of the project and stormwater runoff from the site could impact aquatic habitats downstream. SECTION 4-203 G (8) (a) - DETERMINATION OF LONG AND SHORT-TERM EFFECTS ON FLORA AND FAUNA FLORA The injection well would be placed within the existing disturbance of the Speakman A well pad and no additional native vegetation would be removed for construction. No special status plants occurrences are known to exist nearby. No special status plants would be directly affected by development of the injection well and indirect effects would be unlikely because the area surrounding the existing pad was previously developed for agriculture. Noxious weeds occurring in the area are discussed in an accompanying IVNWMP prepared by WestWater for this project (WestWater 2014). FAUNA Colorado River Endangered Fishes Designated critical habitat for two endangered fish species (Colorado pikeminnow and razorback sucker) occurs in the Colorado River adjacent to the project and critical habitat for two additional species (bonytail and humpback chub) occurs downstream of the project near Grand Junction (Maddux et al. WestWater Engineering Page 6 of 13 February 2014 1993). Colorado pikeminnow and razorback sucker have been documented in the river nearly to Rifle (W. R. Elmblad, retired CDOW fisheries biologist, pers. comm.). Potential impacts would be limited to runoff from storms or snowmelt that carry increased sediment loads or pollutants from the well pad to the river. Implementation of a Spill Prevention, Control, and Countermeasure Plan (SPCC), a Stormwater Management Plan (SWMP), and Best Management Practices (BMPs) associated with this type of project will provide a good degree of mitigation for any potential impacts. Garfield County Road 300 and its associated stormwater management features create an additional mitigating feature. There would be no anticipated depletions that could affect aquatic species associated with the project. Raptors No raptor nesting habitat is directly affected. There is a low possibility for long effects other than the loss of foraging habitat within the footprint of the well pad. Short-term effects include temporary displacement of raptors in an avoidance area immediately surrounding the well due to increased human presence and equipment activity associated with construction, operation, and maintenance of an injection well. American Elk and Mule Deer No additional habitat loss will occur from development of the injection well. No migration corridors are affected. Human presence and activity may affect animal distribution by creating avoidance areas and increasing stress on wintering big game. Over time, deer and elk that winter in this area have become habituated to human activity and the indirect effects of avoidance and displacement have decreased. An increase in vehicle traffic could result in additional vehicle related wildlife mortality, although additional traffic resulting from this project would contribute minimally, given current traffic volumes on the existing county road. Traffic volumes and speed on the private road accessing the site are unlikely to result in significant animal mortality from vehicles. Fences can pose an increased risk to big game and any fencing around the facility should be constructed according to published standards that reduce impacts to big game (Hanophy 2009). Black Bear and Mountain Lion Potential encounters of black bear with construction personnel could occur if garbage or food is available to resident bears and incidences of human-black bear interactions sometimes result in the euthanasia of offending bears by the CPW. An increase in traffic could result in vehicle related mortalities, although the contribution from this project is expected to be low. Small Mammals, Birds (BCC), and Reptiles No additional vegetation removal would be required for development of the injection well and no additional habitat would be lost. Human presence and activity may affect animal distribution. An increase in traffic could result in vehicle related mortalities, although the contribution from this project is expected to be low. SECTION 4-203 G (8) (b) – DETERMINATION OF THE EFFECT ON SIGNIFICANT ENVIRONMENTAL RESOURCES Placement of this project within the boundaries of an existing development has resulted in avoidance of additional contributions to cumulative effects of habitat alteration and fragmentation in the region. The development of the project is not expected to significantly affect any critical environmental resources. WestWater Engineering Page 7 of 13 February 2014 SECTION 4-203 G (8) (c) – IMPACTS ON WILDLIFE AND DOMESTIC ANIMALS  Creation of hazardous conditions: Some passerine bird species and small mammals may choose to inhabit or nest on equipment or objects at the site. The inherent risks associated with these structures are low. By closing or covering all ports, hatches, cavities, and openings (such as the ends of pipes) this potential is decreased. Most non-game bird species and their nests are protected under the Migratory Bird Treaty Act (16 U.S.C. 703-712; Ch. 128; July 13, 1918; 40 Stat. 755) and damaging occupied nests could be considered a “take” resulting in a violation. Livestock and big game will likely avoid the project site.  Indirect Construction Effects: Additional human presence and activity related to construction, operation, and maintenance of an injection well may influence spatial and temporal use of habitat surrounding the project by wildlife. Since the site exists adjacent to significant and long-term human presence, the additional disturbance from this project is expected to be low.  Road-kill: Speed limits are set low and most wildlife in the area has become habituated to vehicle traffic. The potential for vehicle related mortalities related to this project should be low. REFERENCES Andrews, R., and R. Righter. 1992. Colorado Birds: A Reference to Their Distribution and Habitat. Denver Museum of Natural History. Denver. BLM. 2009. BLM Colorado State Director’s Sensitive Species List. November 20, 2009 Update. CPW. 2014a. Natural Diversity Information Source—Colorado Division of Wildlife. http://ndis.nrel.colostate.edu/wildlife.asp. Accessed March 14, 2013. CPW. 2014b. State of Colorado species of concern list. Available online: http://wildlife.state.co.us/WildlifeSpecies/SpeciesOfConcern/Pages/SpeciesOfConcern1.aspx Accessed February 3, 2014. CWMA. 2007. S. Anthony, T. D’Amato, A. Doran, S. Elzinga, J. Powell, I. Schonle, K. Uhing. Noxious Weeds of Colorado, Ninth Edition. Colorado Weed Management Association, Centennial. Hammerson, G. A. 1999. Amphibians and Reptiles in Colorado, Second Edition. Colorado Division of Wildlife, Denver. Hanophy, W. 2009. Fencing with Wildlife in Mind. Colorado Division of Wildlife. Denver. Available online: http://wildlife.state.co.us/SiteCollectionDocuments/DOW/LandWater/PrivateLandPrograms/DO WFencingWithWildlifeInMind.pdf Kershaw, L., A. MacKinnon, and J. Pojar. 1998. Plants of the Rocky Mountains. Lone Pine Publishing, Auburn, Washington. Kingery, H. E. 1998. Colorado Breeding Bird Atlas. Colorado Bird Atlas Partnership, Colorado Division of Wildlife, Denver. Maddux, H., L. Fitzpatrick, and W. Noonan. 1993. Colorado River Endangered Fishes Critical Habitat. Biological Support Document. U.S. Fish and Wildlife Service, Utah/Colorado Field Office, Salt Lake City, Utah, 225 pp. NRCS. 2014. Web Soil Survey, U.S. Department of Agriculture, Natural Resource Conservation Service, Available online: http://websoilsurvey.nrcs.usda.gov. Accessed March 14, 2013. Righter, R., R. Levad, C. Dexter, and K. Potter. 2004. Birds of Western Colorado Plateau and Mesa Country. Grand Valley Audubon Society, Grand Junction. WestWater Engineering Page 8 of 13 February 2014 Spackman, S., B. Jennings, J. Coles, C. Dawson, M. Minton, A. Kratz, and C. Spurrier. 1997. Colorado Rare Plant Field Guide. Prepared for the Bureau of Land Management, the U.S. Forest Service, and U.S. Fish and Wildlife Service by the Colorado Natural Heritage Program. State of Colorado. 2005. Rules pertaining to the administration and enforcement of the Colorado Noxious Weed Act, 35-5-1-119, C.R.S. 2003. Department of Agriculture, Plant Industry Division, Denver, 78 p. USFWS. 2008. Birds of Conservation Concern 2008. U.S. Fish and Wildlife Service, Division of Migratory Bird Management, U.S. Fish and Wildlife Service, Arlington, Virginia. USFWS. 2012. Updated position paper on ESA consultations on greenback cutthroat trout, including the cutthroat trout referred to as Lineage GB. Updated Oct 4, 2012. USFWS. 2014. U.S. Fish and Wildlife Service Endangered Species List for the State of Colorado. Available online: http://ecos.fws.gov/tess_public/pub/stateListingAndOccurrenceIndividual.jsp?state=CO. Accessed February 3, 2014. Weber, W. A., and R. C. Wittmann. 2012. Colorado Flora, Western Slope. Fourth Edition, University Press of Colorado, Boulder. WestWater. 2014. Integrated vegetation and noxious weed management plan for Ursa Operating Company, LLC’s proposed Speakman A Injection Well. Grand Junction. Whitson, T. D. (editor), L. C. Burrill, S. A. Dewey, D. W. Cudney, B. E. Nelson, R. D. Lee and R. Parker. 2001. Weeds of the West – 9th edition. Western Society of Weed Science in cooperation with Cooperative Extension Services, University of Wyoming, Laramie WestWater Engineering Page 1 of 13 February 2014 D Pad Disturbance c:::J 100 Foot Weed Survey Area c:::J 1/4 Mile Raptor Survey Area --County Road --Ri vers and Stre ams LJ BLM 0 Figure 1 Ursa Operating Company Speakman A Injection Well Biological Survey Location .t'il!'NestWater Engineering -:;;;J1 Consulting Engineers & Scientists 0.1 0 .2 Miles February 2014 WestWater Engineering Page 1 of 13 February 2014 WestWater Engineering Page 1 of 13 February 2014 Legend D Pad Disturbance E::5:1 Mule Deer Severe Winter Range C::zl Mule Deer V'/inter Concentration Area D Mule Deer Winter Range --County Road --Ri vers and Streams lb"'J I BLM 3 0 29 Figure 3 Ursa Operating Company Speakman A Injection Well Biological Survey Mule Deer Activities n 'NestWater Engineering -:;;JI Consulting Engineers & Scientists 0.5 Miles 1.5 WestWater Engineering Page 1 of 13 February 2014 D Pad Disturbance Cl Elk Severe Winter Range l:ZI Elk Winter Concentration Area D Elk Winter Range --County Road --Rivers and Streams I F~1 1 BLM Figure 4 Ursa Operating Company Speakman A Injection Well Biological Survey Elk Activities n 'NestWater Engineering "::;;1 Co n sulting En g ineers & Scient ists 0.5 Miles 1.5 WestWater Engineering Page 1 of 13 February 2014 WestWater Engineering Page 1 of 2 February 2014 URSA OPERATING COMPANY, LLC. SPEAKMAN A INJECTION WELL Section 7-202 Protection of Wildlife Habitat Areas Garfield County Land Use and Development Code WILDLIFE Colorado River Endangered Fishes Designated critical habitat for four endangered fish occurs in the Colorado River adjacent to or downstream of the project area. Runoff from storms or snowmelt may carry increased sediment loads or pollutants from the well pad to the river. Implementation of a Spill Prevention, Control, and Countermeasure Plan (SPCC), a Stormwater Management Plan (SWMP), and Best Management Practices (BMPs) associated with this type of project will provide a good degree of mitigation for any potential impacts. Garfield County Road 300 and its associated stormwater management features create an additional mitigating feature. There would be no anticipated depletions that could affect aquatic species associated with the project. Raptors Activities associated with the project have minimal potential to impact raptor populations as no high quality raptor nesting habitat and no raptor nests occur within 0.25 miles of the project area. Indirect impacts would be related to displacement of foraging activities and the effect would be very small given the abundance of foraging habitat available. Due to these factors, in addition to a high ongoing level of human activity in the general project area, it is unlikely that the injection well would contribute to any negative impacts. American Elk, Mule Deer, and Black Bear Implementation of the Integrated Vegetation and Noxious Weed Management Plan (IVNWMP) (WestWater 2014) would help reduce impacts from habitat loss and alteration of native plant communities to the extent possible. A reclamation plan should be implemented to reduce the establishment of noxious weeds in disturbed areas. Reclamation of disturbed areas not critical for operations on the Speakman A location would replace a portion of the forage lost for mule deer and elk and decreases the presence of noxious weeds. Low speed limits already in place on area roads mitigate potential road kill. Facility fencing should be consistent with published standards that reduce potential harm to wildlife (Hanophy 2009). Black bear and mountain lion may occasionally be observed near the site and should not be approached if encountered. Personnel may be unfamiliar with wildlife in the area and should be informed of the potential for bear and lion interactions. Personnel should not feed or harass wildlife at any time. Trash should be stored in bear-proof receptacles and/or removed from the site on a daily basis to prevent attracting bears to the site. Negative interactions may result in euthanasia of problem animals. Birds, Small Mammals, and Reptiles Removal of native vegetation contributes to cumulative effects of habitat conversion and fragmentation in Garfield County. The placement of the injection well in a previously disturbed area has effectively reduced any additional impacts. Structures or equipment at the site may provide hunting perches for raptors that prey on smaller animals in the area and may contribute to increased predation if deterrent devices are not installed. Low speed limits on area roads mitigate potential road kill. WestWater Engineering Page 2 of 2 February 2014 PRESERVATION OF NATIVE VEGETATION No additional vegetation removal will be necessary for development of the injection well since it will be placed on an existing natural gas well pad. Application of the IVNWMP (WestWater 2014) would provide a degree of mitigation for the native vegetation that has already been removed. Reducing the amount of bare ground to only the area needed for utilization and maintenance of the well pad will help reduce the effect of the project on native vegetation and wildlife habitat. The best method to mitigate loss of wildlife habitat and provide the greatest benefit for wildlife is to increase the availability of native forage in the form of grasses and shrubs. Vegetation removal and soil disturbance during construction can create optimal conditions for the establishment of invasive, non-native species. Vehicles and equipment traveling from weed-infested areas into weed-free areas could disperse noxious or invasive weed seeds and propagates, resulting in the establishment of these weeds in previously weed-free areas. Several simple practices should be employed to prevent most weed infestations. The following practices should be adopted for any activity to reduce the costs of noxious weed control through prevention. The practices include:  Prior to delivery to the site, equipment should be thoroughly cleaned of soils remaining from previous construction sites which may be contaminated with noxious weeds.  If working in sites with weed-seed contaminated soil, equipment should be cleaned of potentially seed-bearing soils and vegetative debris at the infested area prior to moving to uncontaminated terrain.  All maintenance vehicles should be regularly cleaned of soil.  Avoid driving vehicles through areas where weed infestations exist. REFERENCES Hanophy, W. 2009. Fencing with Wildlife in Mind. Colorado Division of Wildlife. Denver. Available online: http://wildlife.state.co.us/SiteCollectionDocuments/DOW/LandWater/PrivateLandPrograms/DO WFencingWithWildlifeInMind.pdf WestWater Engineering. 2014. Integrated Vegetation and Noxious Weed Management Plan for Ursa Operating Company, LLC’s proposed Speakman A Injection Well. Grand Junction.