Biological Evaluation
for

Small Placer Miners in Idaho
National Pollutant Discharge Elimination System (NPDES)

General Permit

(NPDES General Permit No.: IDG-37-0000)
for the

U.S. FISH AND WILDLIFE SERVICE
and the

NATIONAL MARINE FISHERIES SERVICE

U.S. Environmental Protection Agency
Region 10
Seattle, Washington
January 2010


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1. EXECUTIVE SUMMARY

The EPA proposes to issue a general NPDES permit applicable for small placer miners in Idaho.
The general permit places conditions on the discharge of pollutants from each mining operation
and the best management practices (BMPs) that must be employed in order to ensure protection
of water quality and human health. The number of placer miners covered under this permit will
be determined by the number of NOIs submitted once the permit is issued; however, a list of
979 potential permittees based on previous permit applicants from the Idaho Department of
Water Resources (IDWR) database including the waterbodies that have been previously
permitted are provided in Appendix A of the Biological Evaluation.

Section 7 of the Endangered Species Act (ESA) requires federal agencies to consult with the
U.S. Fish and Wildlife Service (USFWS) and the National Marine Fisheries Service (NMFS) if
the federal agency's actions could beneficially or adversely affect any threatened and endangered
species or their critical habitat. The U.S. Environmental Protection Agency (EPA) conducted a
biological evaluation to identify potential impacts to federally-listed endangered or threatened
species that could result from the issuance of a National Pollutant Discharge Elimination System
(NPDES) general permit for small placer miners in Idaho.

Water quality-based Effluent Limitations. Section 301(b)(1) of the Act requires the
establishment of limitations in permits necessary to meet water quality standards by July 1, 1977.
All discharges to state waters must comply with state and local water management plans as well
as with state water quality standards, including the state's antidegradation policy. Discharges to
state waters must also comply with limitations imposed by the state as part of its certification of
NPDES permits under section 401 of the Act.

The NPDES regulations at 40 CFR 122.44(d)(1) require that permits include water quality-based
limits that "Achieve water quality standards established under section 303 of the CWA,
including State narrative criteria for water quality." EPA has determined that turbidity is a
pollutant of concern and it is expected that the proposed BMPs, when implemented properly, will
be protective of Water Quality Standards.

Best Management Practices (BMPs). BMPs are measures that are intended to prevent or
minimize the generation and the potential for the release of pollutants from industrial facilities to
the waters of the United States through normal operations and ancillary activities. Pursuant to
Section 402(a)(1) of the Clean Water Act, development and implementation of BMP Plans may
be included as a condition in NPDES permits. Section 402(a)(1) authorizes EPA to include
miscellaneous requirements that are deemed necessary to carry out the provision of the Act in
permits on a case-by case basis. BMPs are required to control or abate the discharge of
pollutants in accordance with 40 CFR § 122.44(k). The proposed permit requires compliance
with the following BMPs:

A. Silt and Clay Areas: Dredging of concentrated silt and clay should be avoided.

The Permittee shall use reasonable care to avoid dredging silt and clay materials that
would result in a significant increase in turbidity.

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Reasonable care includes moving the dredge to a new location or reducing the volume of
effluent discharge by limiting operation speed of the suction dredge.

This practice will decrease the amount of fine material that will be released into the
water that could cause turbidity plumes in excess of the permitted distance.

B.	Mercury: If mercury is found during suction dredge operation, (i.e. mercury is collected in the
sluice box), the operator must:

1)	Stop dredging immediately;

2)	Contact the local regional office of IDEQ ;

3)	Keep the mercury collected, do not remobilize the collected mercury; and

4)	Work with the appropriate regional office of IDEQ to dispose of the mercury properly.

Mercury was used in historic placer mining operations to amalgamate goldfines.
Elemental mercury may be present in stream beds and banks and if remobilized
can result in impacts to fish and other aquatic life. Placer miners encountering
mercury should take above steps to prevent mercury from reentering the water
body.

C.	Spacing between operations: Suction dredges shall not operate within 800 feet of:

1)	another suction dredging operation occurring simultaneously or,

2)	a location where it is apparent that another operation has taken place within the past

month

This practice should ensure that the mixing zone of a facility does not overlap
with that of another since 800feet is the distance of a 500foot mixing zone for
each operation plus a designated 300foot buffer before the next suction dredge
would impact water quality.

D. Spawning Fish and Spawning Habitat: Dredging and discharging are prohibited within
500 feet of locations where:

1)	fish are spawning or

2)	fish eggs or alevins are known to exist at the time dredging occurs

In addition: Suction dredge operation must not occur in gravel bar areas at the tail
of pools or where operations result in fine sediments discharging onto gravel bars.

This BMP is designed to minimize impacts to fish spawning and spawning habitat.

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E.	Stream Channel: Suction dredge operation must not change the stream channel in such a
way that directs the flow of water into a stream bank, which may cause bank erosion or
destruction of the natural form of the stream channel.

Under Section 101 of the Clean Water Act, EPA is required to restore and
maintain the chemical, physical and biological integrity of waters of the United
States. Protection of the physical integrity of waterbodies includes protection of
habitat.

F.	Erosion: Suction dredge operation that results in undercutting, littoral channeling, stream
bank or beach erosion, is prohibited.

This practice will ensure that erosion does not occur and that the finer sediments
that may be found in these areas do not cause excessive turbidity in the receiving
waters.

In addition, per IDAPA 37.03.07.64.04, the operation of the dredge shall be done
in a manner so as to prevent the undercutting of stream banks.

G.	Dams or Diversions: Damming or diversions within a stream channel are not authorized by
this GP.

EPA cannot authorize dams or diversions under Section 402 of the CWA. These
are generally authorized under Section 404 of the CWA which is administered by
the U.S. Army Corps of Engineers.

H.	Boulders and Natural Obstructions: Explosives, motorized winches or other motorized
equipment to move boulders, logs, or other natural obstructions are prohibited under this GP.

This practice should ensure that important habitat which may include large
organic debris and large boulders in these areas will not be destroyed.

I. Wheeled or Tracked Equipment: Wheeled or tracked equipment used in-stream is prohibited
while dredging is in progress.

This practice should minimize turbidity from sources other than the suction
dredge.

J. Refueling: Care shall be taken by the operator during refueling of equipment to prevent
spillage.

Any spills shall be cleaned up using materials such as sorbent pads and booms.

All spills shall be reported immediately or as soon as practical to the IDEQ and the
National Response Center at 1-800-424-8802.

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All chemical or petroleum products shall be stored in a safe and secure location at all
times. Fuel not stored and dispensed with an ANSO or UL approved safety container
must be maintained not less than 100 feet from the mean high water mark.

This practice will decrease the potential for contamination of surface water by petroleum
products.

EPA has determined that issuance of this permit is not likely to have an adverse effect on
essential fish habitat (EFH), federally listed threatened or endangered (T&E) species or critical
habitat. Effluent limitations have been incorporated into the draft permit based on criteria
considered to be protective of overall water quality in Idaho waters. The USFWS and the NMFS
will be provided with the draft permit, the fact sheet, and this BE during the public comment
period. Any comments received from NMFS regarding EFH, T&E species, or critical habitat
will be considered prior to final issuance of this permit.

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Section

TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY	1

SECTION 1.0 Introduction	11

SECTION 2.0 List of Species	13

2.1 Species Unlikely to Occur in Action Area	18

SECTION 3.0 Description of Action	22

3.1	Overview of Federal Regulations	22

3.2	Overview of Permit Action	22

3.3	Operations covered by the Permit	24

3.4	Receiving waters covered by the Permit	25

3.5	Receiving waters not authorized by the Permit	26

3.6	Permit Requirements	27

3.6.1	Technology-based Effluent Limitations	27

3.6.2	Water quality-based Effluent Limitations	28

3.6.3	Monitoring Requirements	28

3.6.4	Best Management Practices	28

SECTION 4 Description of Action Area	31

4.1	Biological Requirements in the Action Area	32

4.2	Environmental Baseline	32

4.3	Receiving Water Quality	32

SECTION 5 Species Descriptions	35

5.1 Banbury Springs Lanx (Lanx sp.)	35

5.1.1	Range of Species	35

5.1.2	Critical Habitat	35

5.1.3	Life History	35

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5.1.4 Population Trends and Risks	35

5.2	Bliss Rapids Snail (Taylorconcha serpenticola)	36

5.2.1	Range of Species	36

5.2.2	Critical Habitat	36

5.2.3	Life History	36

5.2.4	Population Trends and Risks	36

5.3	Bruneau Hot Springsnail (Pyrgulopsis bruneauensis)	37

5.3.1	Range of Species	37

5.3.2	Critical Habitat	37

5.3.3	Life History	37

5.3.4	Population Trends and Risks	37

5.4	Bull Trout (Salvelinus confluentus)	38

5.4.1	Range of Species	38

5.4.2	Critical Habitat	38

5.4.3	Life History	38

5.4.4	Population Trends and Risks	39

5.5	Fall Chinook Salmon (Oncorhynchus tshawytscha)	39

5.5.1	Range of Species	39

5.5.2	Critical Habitat	39

5.5.3	Life History	39

5.5.4	Population Trends and Risks	39

5.6	Spring/Summer Chinook Salmon (Oncorhynchus tshawytscha)	40

5.6.1	Range of Species	40

5.6.2	Critical Habitat	40

5.6.3	Life History	40

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5.6.4 Population Trends and Risks	40

5.7	Grizzly Bear (Ursus arctos)	41

5.7.1	Range of Species	41

5.7.2	Critical Habitat	41

5.7.3	Life History	41

5.7.4	Population Trends and Risks	41

5.8	Kootenai River White Sturgeon (Acipenser transmontanus)	41

5.8.1	Range of Species	42

5.8.2	Critical Habitat	42

5.8.3	Life History	42

5.8.4	Population Trends and Risks	42

5.9	Snake River Physa Snail (Talorconcha serpenticola)	43

5.9.1	Range of Species	43

5.9.2	Critical Habitat	43

5.9.3	Life History	43

5.9.4	Population Trends and Risks	43

5.10	Sockeye Salmon (Oncorhynchus nerka)	44

5.10.1 Range of Species	44

5.10.2Critical Habitat	44

5.10.3 Life History	44

5.10.4Population Trends and Risks	45

5.11	Steelhead (Oncorhynchus mykiss)	45

5.11.1	Range of Species	45

5.11.2	Critical Habitat	45

5.11.3	Life History	45

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5.11.4Population Trends and Risks	46

5.12 Utah Valvata Snail (Valvata utahensis)	46

5.12.1 Range of Species	46

5.12.2Critical Habitat	47

5.12.3 Life History	47

5.12.4Population Trends and Risks	47

SECTION 6.0 IMPACTS ON THREATENED AND ENDANGERED SPECIES	48

6.1	Parameters of Concern	49

6.1.1	Dredging Effects on Fish Spawning and Early Life Stages	49

6.1.1.1	Impacts on Fish Spawning Habitat	49

6.1.1.2	Impacts on Spawning Habitat Resulting in Effects on Eggs and Embryos	49

6.1.1.3	Impacts of Mercury	50

6.1.1.4	Egg and Larval Entrainment	51

6.1.2	Effects on Juvenile and Adult Fish	51

6.1.2.1	Juvenile and Adult Entrainment	 51

6.1.2.2	Pool Formation/Loss	51

6.1.2.3	Sedimentation	52

6.1.2.4	Loss of Woody Debris and Large Boulders	53

6.1.2.5	Behavioral Responses	54

6.1.2.6	Suspended Sediment	54

6.1.3	Effects to Snail Species	55

6.2	Effects Determination	56

6.2.1	Banbury Springs Lanx	56

6.2.2	Bliss Rapids Snail	56

6.2.3	Bruneau Hot Springsnail	57

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6.2.4	Bull Trout	57

6.2.5	Fall Chinook Salmon	58

6.2.6	Spring/Summer Chinook Salmon	59

6.2.7	Grizzly Bear	60

6.2.8	Kootenai River White Sturgeon	60

6.2.9	Snake River Physa Snail	60

6.2.10	Sockeye Salmon	61

6.2.11	Steelhead	61

6.2.12Utah Valvata Snail	62

6.3	Cumulative Impacts	63

6.4	Interdependent /Interrelated Actions	63

SECTION 7 CONSERVATION MEASURES	64

7.1 Best Management Practices	64

LIST OF TABLES

Table 1. Corresponding Sections of this BE to NMFS and USFWS Recommended

Contents for Biological Assessments	12

Table 2. Listed and candidate federally-threatened or endangered species that are known to
occur in Idaho by County	15

Table 3. State Water Quality Monitoring Information by River Basin	34

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ACRONYMS

BE

Biological Evaluation

BLM

Bureau of Land Management

BMP

Best Management Practice

CFR

Code of Federal Regulations

CWA

Clean Water Act

EFH

Essential Fish Habitat

EPA

Environmental Protection Agency

ESA

Endangered Species Act

ESU

Evolutionary Significant Unit

F

Fahrenheit

ft2

Square Feet

GP

General Permit

IDEQ

Idaho Department of Environmental Quality

IDWR

Idaho Department of Water Resources

in2

Square Inches

NMFS

National Marine Fisheries Service

NO A A

National Oceanic Atmospheric Administration

NPDES

National Pollutant Discharge Elimination System

PFMC

Pacific Fish Management Council

RM

River Mile

T&E

Threatened and Endangered

TSS

Total Suspended Solids

USFWS

United Service Fish and Wildlife Service

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SECTION 1.0 INTRODUCTION

The EPA proposes to issue a general NPDES permit applicable for small placer miners in Idaho.
The general permit places conditions on the discharge of pollutants from each mining operation
and the best management practices (BMPs) that must be employed in order to ensure protection
of water quality and human health.

The Endangered Species Act (ESA) requires federal agencies to consult with the U. S. Fish and
Wildlife Service (USFWS) and the National Marine Fisheries Service (NMFS) if the federal
agency's actions could beneficially or adversely affect any threatened and endangered species or
their critical habitat. In this case, the federal agency is the United States Environmental
Protection Agency (EPA), and the discretionary action is the issuance of a National Pollutant
Discharge Elimination System (NPDES) general permit (GP) for small placer miners in Idaho.

The action evaluated in this Biological Evaluation (BE) could affect species under the jurisdiction
of both the USFWS and NMFS. This BE identifies the endangered, threatened, and candidate
species and critical habitat in the project area and assesses potential effects to these species that
may result from the discharge authorized in the proposed NPDES general permit for small suction
dredge placer miners.

The following major discussions are provided in this evaluation using the best scientific and
commercial data available:

•	The proposed action and the action area (including the relevance of the environmental
baseline to the species' current status);

•	The listed species and critical habitat in the area of the proposed action and definitions of the
species' biological requirements and habitat, abundance trends, and current status;

•	The effects analyses of the proposed action on the listed species and critical habitat; and

•	References are provided at the end of the document.

In order to adhere to the recommended contents of a biological assessment for submission to
USFWS (USFWS and NMFS, 1998), the following table lists the sections of this BE that
correspond to the recommended content topics.

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Table 1. Corresponding Sections of this BE to NMFS and USFWS Recommended Contents for Biological Assessments



Recommended Content

Heading in this BE

Section(s)

Introduction



Introduction

I

List of Species

List of Species (citation)

List of Species

II



Critical Habitat (official status)





Project Description

Type and scope of Project

Description of Action

III



Project components pertinent to the species







Management actions such as proposed monitoring of species and







mitigation that may affect species





Description of Project Area

Legal description and map

Description of Action Area

IV



Define action area







Current condition of habitat parameters







Past and present activities related to species/habitat







Analysis of cumulative effects





Description of Species and Habitat

General species descriptions and habitat requirements

Species Descriptions

V



Species distribution and habitat specific to action area by life history

Habitat Characteristics of the Receiving waters

VI



phase







Species status, distribution, and abundance trends in action area







Description of Critical Habitat, if designated





Inventories and Surveys

Describe effort to obtain information on species status

Species Descriptions

V



Describe information used in Description of Species and Habitat in a







Table





Analysis of Effects

Description of parameters of concern

Analysis of Effects from the Action

VII



Analysis of potential direct and indirect effects







Analysis of interdependent and interrelated actions







Environmental baseline - track the conservation status of a species and its







environment up to the present moment (starting at time of listing or







earlier)







Effects determinations







Analysis of effects to designated critical habitat





Conclusions

Summary of determinations

Conclusions

VII



Statements of effect of the project on the species (e.g., no affect, may







affect, etc.)





References

Literature cited

References

i-vn



Copies of pertinent documents and maps







List of personal communication contacts, contributors, preparers





Supporting Information

Supporting documents that will assist the reviewer

Appendices

A-I

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SECTION 2.0

LIST OF SPECIES

Information provided by the NMFS and the USFWS on the distribution of threatened and
endangered species was consulted to identify species that may occur in the vicinity of the
discharges. In a letter dated December 30, 2009 the USFWS indicated the listed and candidate
federally-threatened or endangered species that are known to occur in Idaho, 14420-2010-SL-
0086. These are listed in Table 2. However, many of these are not found in the action areas and
would not be affected by small suction dredge placer miners. Therefore, EPA determined that
the NPDES permit for small suction dredge placer miners would have no effect on Canada Lynx,
Northern Idaho ground squirrel, Selkirk woodland caribou, spalding's catchfly, slickspot
peppergrass, Ute ladies tresses, McFarlane's four-o-clock, water howelia, yellow billed cuckoo,
southern Idaho ground squirrel, Goose Creek milkvetch, Columbia spotted frog, and Christ's
paintbrush. These species are discussed in Section 2.1 and a rationale for the no effect
determination is provided, however these species are not discussed further in this BE.

NMFS has designated the Snake River Basin DPS of steelhead (Oncorhynchus mykiss) as
threatened (71 FR 833), adding 6 hatchery populations and resident rainbow trout populations in
10 counties in Idaho: Clearwater, Blaine, Adams, Custer, Idaho, Latah, Lemhi, Lewis, Nez
Perce, and Valley. The Snake River Basin steelhead DPS includes all naturally spawned
populations of steelhead in streams in the Snake River Basin of southeast Washington, northeast
Oregon, and Idaho (62 FR 43937; August 18, 1997). Six artificial propagation programs are
considered part of the DPS: the Tucannon River, Dworshak NFH, Lolo Creek, North Fork
Clearwater, East Fork Salmon River, and the Little Sheep Creek/Imnaha River Hatchery
steelhead hatchery programs. NMFS has determined that these artificially propagated stocks are
no more divergent relative to the local natural population(s) than what would be expected
between closely related natural populations within the DPS (NMFS, 2004b).

Critical habitat has also been designated for the Snake River Basin DPS of steelhead in the
following counties (65 FR 7764): Adams, Blaine, Boise, Clearwater, Custer, Idaho, Latah,

Lewis, Lemhi, Nez Perce and Valley. This consists of river reaches of the Columbia, Snake, and
Salmon Rivers, and all tributaries of the Snake River including Clearwater, Grande Ronde,
Selway and Tucannon Rivers (except reaches above impassable natural falls, and Dworshak and
Hells Canyon Dam).

USFWS has designated critical habitat for the bull trout (Salvelinus confluentus) in 8 counties in
Idaho: Adams, Benewah, Bonner, Boundary, Kootenai, Nez Perce, Shoshone and Washington.
Approximately 294 stream/shoreline miles have been designated in Idaho as critical habitat for
the bull trout. River basins with designated critical habitat include the Clark Fork, Kootenai,
Lake Coeur d'Alene, Clearwater, Salmon, Southwest Idaho, Little Lost, Imnaha-Snake, and
Hells Canyon Complex. No critical habitat is being designated for the Jarbidge River population
of bull trout in Nevada and southern Idaho, where the Secretary of the Interior determined that
the benefits of excluding the area outweighed the benefits of including it.

Designated critical habitat for the Snake River sockeye salmon (iOncorhynchus nerka) consists of
river reaches of the Columbia, Snake, and Salmon Rivers, Alturas Lake Creek, Valley Creek,
and Stanley, Redfish, Yellow Belly, Pettit, and Alturas Lakes (Including their inlet and outlet
creeks).

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Designated critical habitat for fall Chinook salmon (Oncorhynchus tshawytscha) in Idaho
consists of river reaches of the Snake River, and all tributaries of the Snake River presently or
historically accessible to Snake River fall Chinook salmon (except reaches above impassable
natural falls, and Dworshak and Hells Canyon dam).

Designated critical habitat for spring/summer Chinook salmon (Oncorhynchus tshawytscha) in
Idaho consists of river reaches of the Snake River, and all tributaries of the Snake River (except
the Clearwater River) presently or historically accessible to Snake River spring/summer Chinook
salmon (except reaches above impassable natural falls and Hells Canyon Dam).

Designated critical habitat for the Kootenai River White Sturgeon includes 18.3 river miles (RM)
(29.5 river kilometers (RKM)) of the Kootenai River which are designated as critical habitat
within Boundary County, Idaho (73 FR 39505).

Designated critical habitat for Canada lynx includes terrestrial habitat within Boundary County,
Idaho.

No critical habitat has been designated or proposed for the other listed species.

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Table 2: Listed and Candidate Species and Listed Critical Habitat in Idaho1





Mammals











Fis

1







Steelhead Trout



Plants





Invertebrates

Candidate



County

Selkirk Mountains
Woodland caribou

Grizzly Bear

Northern Idaho Ground
Squirrel

Canada Lynx



Kootenai River White
Sturgeon



Bull Trout



Sockeye Salmon



bpring/bummer
Chinook Salmon

Fall Chinook Salmon





iviacharlane's l-our-
O'Clock

Slickspot Peppergrass

Water Howellia

Ute Ladies'- Tresses

Spalding's Catchfly

Utah Valvata Snail

Snake River Physa Snail

Bliss Rapids Snail

Banbury Springs Lanx

Bruneau Hot
Springsnail

Christ's Paintbrush

Columbia Spotted Frog

Goose Creek Milkvetch

























































































Ada





























X

























x |





























Adams





X

X



x3



x3

x3

x3



















































































































Bannock

































































X





















Bear Lake







X































































































































Benewah





























x3



























x |



X

























Bingham



























X



X







































































































Blaine





























X





x3





x3







x3















X





















Boise







X



X



























































































































Bonner





























X3























































Bonneville







X



















X



X







































































































Boundary

























x3



X























































Butte







X



X



























































































































Camas





























X



































X





















Canyon























X















































































































Caribou





















































































Cassia































X

X







X



X

























































































Clark





















































































Clearwater







X



X





x3

X3



















































































































Custer





























X





x3





X3







X3



































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Table 2: Listed and Candidate Species and Listed Critical Habitat in Idaho1



Mammals









Fis

1







1 Fall Chinook Salmon



Steelhead Trout









Plants







Invertebrates



Candidate



County

Selkirk Mountains
Woodland caribou

Grizzly Bear

Northern Idaho Ground
Squirrel

Canada Lynx

Kootenai River White
Sturgeon



Bull Trout



Sockeye Salmon



bpring/bummer
Chinook Salmon







iviacharlane's l-our-
O'Clock

Slickspot Peppergrass

Water Howellia

Ute Ladies'- Tresses

Spalding's Catchfly

Utah Valvata Snail

Snake River Physa Snail

Bliss Rapids Snail

Banbury Springs Lanx

Bruneau Hot
Springsnail

Christ's Paintbrush

Columbia Spotted Frog

Goose Creek Milkvetch

Elmore







X



X











X









X

X







































































































Franklin

























































































Fremont







X



















X



X











































































































Gem



















X































X





































Gooding































X

X

X

X





































































































Idaho



















X





x3





x3





x3





x3





X













X





























Jefferson







X



















X



X











































































































Jerome

































































X





X



X















Kootenai







X



x3













X



X













































































































Latah











































X3











x |





X





























Lemhi







X



X

x3

X3



X3























































































































Lewis



















X





X3





X3





X3





X3

















X





























Lincoln































X











































































































Madison

























































X







X

























Minidoka































X

X









































































































Nez Perce



















x3





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Table 2: Listed and Candidate Species and Listed Critical Habitat in Idaho1

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1	Please see attached Threatened, Endangered, and Candidate Species summary for species specific information.

2	Candidate species have no protection under the Act, but are included for your early planning consideration.

Candidate species could be proposed or listed during the project planning period. The Service advises an evaluation of potential effects
on section 7 consultation under the Act should the species become listed.

3	Designated Critical Habitat in addition to species presence.

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2.1 Species Unlikely to Occur in the Action Area

There are a number of species that while listed as threatened or endangered for the state of Idaho,
due to their habitat requirements, known locations or limited populations, are not likely to occur
in the action area or be affected by the activities covered under the general permit. The species
are listed below along with the rationale for why they would not be located in the action area.
Since these species will have no exposure to the effluent from the placer mining covered in this
permit, EPA has determined there would be no effect on the following species. Since these
species are not likely to occur in the action area and will have no effect from the effluents
covered in this permit, they are not discussed in additional detail.

Canada Lynx

Given the isolated areas where Canada lynx are known to occur and that are targeted for
recovery, and that their diet is comprised largely of small terrestrial mammals, the exposure of
the lynx to receiving waters for small placer mines is unlikely or infrequent. Therefore, EPA has
determined that the issuance of these NPDES general permit for small placer miners in Idaho
will have no effect on the Canada lynx.

Northern Idaho ground squirrel

The Northern Idaho ground squirrel is known to occur in shallow, dry rocky meadows or
shrub/grasslands usually associated with deeper, well-drained soils and surrounded by Ponderosa
pine and Douglas-fir forests not normally associated with shoreline or riparian habitats. Given
the diet of the Northern Idaho ground squirrel consists mainly of grass seed, stems and green,
leafy vegetation and their upland habitat, the exposure of the ground squirrel to receiving waters
for these facilities is unlikely or infrequent. Therefore, EPA has determined that the issuance of
NPDES general permit for small placer miners in Idaho will have no effect on Northern Idaho
ground squirrels.

Selkirk Woodland caribou

Since the 1960s, the woodland caribou population has restricted its range to the Selkirk
Mountains of northeastern Washington, northern Idaho and southeastern British Columbia.
Woodland caribou are generally found on moderate slopes above 4,000 feet elevation in the
Selkirk Mountains in Englemann spruce/subalpine fir and western red cedar/western hemlock
forest types. The limited range of the woodland caribou is outside of the action area of the
facilities covered in this permit. Since this species is not likely to occur in the action area covered
under these permits, EPA has determined that the NPDES general permit for small placer miners
in Idaho will have no effect on the woodland caribou.

MacFarlane's four-o'clock

MacFarlane's four-o'clock is a terrestrial plant species that occurs only in a limited geographic
area associated with Hells Canyon in Idaho. Most individual plants of this species occur in
uplands located in river canyon grasslands on dry open slopes with well drained soils. There are
no small placer locations in such uplands. Therefore, the EPA has determined that issuance of

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NPDES general permit for small placer miners in Idaho will have no effect on the MacFarlane's
four-o'clock.

Ute ladies'-tresses

Ute ladies' tresses is a perennial, terrestrial orchid endemic to mesic or wet meadows and
riparian/wetland habitats near springs, seeps, lakes, or perennial streams. Soils may be inundated
early in the growing season, normally becoming drier but retaining subsurface moisture through
the season. Grazing and recreational use appear to be the most likely activities affecting the
plant. Adequate data are not available; however, to determine what, if any, activities are
affecting this species along the main stem Snake River. It is generally believed that any activity
that degrades floodplain riparian or wetland habitats will also affect Ute ladies' tresses (57 FR
2053). Exposure to waterborne pollutants from point sources, such as small placer mines, is
expected to be limited in duration and infrequent during spring time high flows of the river into
the floodplain. Therefore, the EPA has determined that issuance of NPDES general permit for
small placer miners in Idaho will have no effect on Ute ladies'-tresses.

Slickspot peppergrass

Slickspot peppergrass is a small annual or biennial plant in the mustard family that occurs only in
sagebrush-steppe habitats in southwestern Idaho, including the Snake River Plain, Owyhee
Plateau and adjacent foothills. Slickspot peppergrass typically grows in sagebrush areas on
microsites known as "slickspots". These microsites are often lower than the surrounding areas
and retain water longer than the surrounding soils. Slickspot peppergrass has been found in Ada,
Canyon, Gem, Elmore, Payette and Owyhee counties. Twenty-eight of the 88 known or historic
slickspot peppergrass occurrences are found either wholly or partially on private lands. The
remaining occurrences are found on Federal land managed by the Bureau of Land Management
(BLM) or the Department of Defense. Due to the fact that the slickspot habitat is in sagebrush
steppe habitat and tends to occur away from riverine areas and most of the known slickspot
peppergrass habitat occurs on private or federal land, impacts to slickspot peppergrass from
small placer miners would not be expected to occur. Therefore, EPA has determined that
issuance of the NPDES general permit for small placer miners in Idaho will have no effect on
slickspot peppergrass.

Spalding's catchfly

Spalding's catchfly is a terrestrial plant species that occurs on open grasslands and deep-soiled
valley/foothill areas. These species occur in uplands that would never or very rarely be exposed
to flood waters from streams receiving discharges from small placer mines. Therefore, the EPA
has determined that issuance of the NPDES general permit for small placer miners in Idaho will
have no effect on the Spalding's catchfly.

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Water Howellia

Water howellia is an annual aquatic plant that completes its entire life cycle in one growing
season. The plant roots in bottom sediments of low-elevation ponds or sloughs. Only one site of
water howellia is known in Idaho. Most sites containing water howellia are less than 1 acre in
size. The potential for one of these species occurring in close proximity to an existing small
placer mine would be small. Therefore, EPA has determined that issuance of NPDES general
permit for small placer miners in Idaho will have no effect on water howellia.

Yellow-billed cuckoo

This species is primarily found in riparian areas. In Idaho, the yellow-billed cuckoo is
considered a rare visitor to the Snake River Valley. It is unlikely that existing or future small
placer mines would occur in habitats used by the yellow-billed cuckoo. Therefore, EPA has
determined that the NPDES general permit for small placer miners in Idaho will have no effect
on the yellow-billed cuckoo.

Southern Idaho ground squirrel

This species spends much of its time underground and the few months it is above ground it feeds
on grass seed, stems and leafy vegetables. Currently, the southern Idaho ground squirrel only
occurs in Gem, Payette and Washington Counties. The southern Idaho ground squirrel resides in
lower-elevation, sagebrush/grassland habitat. Given the diet of the Southern Idaho ground
squirrel consists mainly of grass seed, stems and green, leafy vegetation and their
sagebrush/grassland habitat, the exposure of the ground squirrel to surface waters that may be
impacted by these facilities is unlikely or infrequent. Therefore, EPA has determined that the
NPDES general permit for small placer miners in Idaho will have no effect on the Southern
Idaho ground squirrel.

Columbia spotted frog

The Columbia spotted frog lives in spring seeps, meadows, marshes, ponds and streams with abundant
vegetation. In Idaho the Columbia spotted frog occurs in mid-elevation of Owyhee uplands and southern
Twin Falls County. It is unlikely that existing or future small placer mines would occur in habitats used
by the Columbia Basin population of spotted frogs. Therefore, EPA has determined that the NPDES
general permit for small placer miners in Idaho will have no effect on the Columbia spotted frog.

Goose Creek milkvetch

Goose Creek milkvetch is a low-growing, matted perennial forb in the pea or legume family.

This species of milkvetch is only found in tuffaceous or ashy soils near Goose Creek drainage in
Cassia County, Idaho. Goose Creek drainage is closed to all Idaho small placer miners for the
entire year. Therefore, EPA has determined that the NPDES general permit for small placer
miners in Idaho will have no effect on the Goose Creek milkvetch.

Christ's paintbrush

This species grows in moist, gently sloping subalpine meadows. In Idaho, Christ's paintbrush is
only found on lands managed by Sawtooth National Forrest in high elevations of the Albion

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Mountains in Cassia County, Idaho. Since there are no facilities expected to be covered under
this permit in that area, EPA has determined that the NPDES general permit for small placer
miners in Idaho will have no effect on Christ's paintbrush.

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SECTION 3.0

DESCRIPTION OF ACTION

The federal action that is the subject of this BE is the issuance of a general NPDES permit for
small placer miners in Idaho. This section of the BE includes a general overview of the proposed
action, a discussion on the permit status, a description of the treatment process, a description of
the outfalls, and a discussion of the proposed effluent limits in the permit.

3.1 Overview of Federal Regulations

Section 7(a) of the Endangered Species Act ("ESA"), 16 U.S.C. Section 1536(a), requires that
each federal agency: in consultation with the U.S. Fish and Wildlife Service (US FWS) and
National Marine Fisheries Service (NMFS)(Services) insure that any action it authorizes, funds,
or carries out is not likely to jeopardize the continued existence of any listed species or to result
in the destruction or adverse modification of any designated critical habitat of each such species
(Section 7(a)(2)); and confer with the Service on any agency action that is likely to jeopardize
the continued existence of any species that is proposed for listing or result in the destruction or
adverse modification of any critical habitat proposed to be designated for any such species
(Section 7(a)(4)).

A biological evaluation provides an analysis of the potential effects of a proposed federal agency
action on any proposed and listed species or the designated critical habitat of any such species
based on the best scientific or commercial information available. This biological evaluation has
been prepared to assist the U.S. Environmental Protection Agency, Region 10 (EPA or Agency)
in carrying out their activities pursuant to ESA Sections 7(a)(2) and 7(a)(4) as they pertain to
EPA's proposed Small Placer Miners in Idaho NPDES General Permit. The ESA requires federal
agencies to review their actions as they apply to proposed and listed species. In this evaluation,
the EPA has included candidate species as well.

Section 305(b) of the Magnuson-Stevens Act [16 USC 1855(b)] requires federal agencies to
consult with NMFS when any activity proposed to be permitted, funded, or undertaken by a
federal agency may have an adverse effect on designated Essential Fish Habitat (EFH) as defined
by the Act. The EFH regulations define an adverse effect as any impact which reduces quality
and/or quantity of EFH and may include direct (e.g. contamination or physical disruption),
indirect (e.g. loss of prey, reduction in species' fecundity), site-specific, or habitat-wide impacts,
including individual, cumulative, or synergistic consequences of actions.

The EFH guidelines further interpret the EFH definition as:

•	Waters include aquatic areas and their associated physical, chemical, and biological
properties that are used by fish and may include aquatic areas historically used by fish
where appropriate

•	substrate includes sediment, hard bottom, structures underlying the waters, and associated
biological communities

•	necessary means the habitat required to support a sustainable fishery and the managed
species' contribution to a healthy ecosystem

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• and "spawning, breeding, feeding, or growth to maturity" covers a species' full life cycle.

EPA is providing NMFS with copies of the draft GP and fact sheet during the public notice
period. Comments received from NMFS regarding EFH will be considered prior to reissuance of
this permit. The Pacific Fishery Management Council (PFMC) designated EFH for groundfish
(PFMC 1998a), coastal pelagic species (PFMC 1998b), and Chinook salmon, coho salmon, and
Puget Sound pink salmon (PFMC 2000). The proposed action area for this consultation includes
waters of the United States occurring downstream from small placer mining facilities in Idaho
that are covered under this permit. The action area includes areas designated as EFH for various
life-history stages of Snake River Chinook salmon. The effects of the proposed action on EFH
are largely water quality related due to temporary increases in sediment and turbidity.

In streams where suction dredging occurs, the most critical life stage for salmon is the egg stage.
The GP prohibits suction dredging in locations where fish are spawning or where fish eggs or
alevins are known to exist. The GP is unlikely to be used during the critical phase. Recreational
dredge mining is regulated in Idaho by the Stream Channel Protection Act. This statute requires
dredge miners to apply for a general permit and consult with the Idaho Department of Water
Resources before any recreational dredge mining can be done. State regulations also specify the
streams where recreational dredging is prohibited. The EPA has determined that no adverse
impact to EFH would result from the issuance of this permit.

Effluent limitations and Best Management Practices (BMPs) have been incorporated into the
draft permit based on criteria considered to be protective of overall water quality in Idaho. Any
comments received from NMFS regarding EFH will be considered prior to final issuance of the
BE.

3.2 Overview of Permit Action

Section 301(a) of the Clean Water Act (CWA) provides that the discharge of pollutants to
surface waters of the United States is unlawful except in accordance with an NPDES permit.
EPA's regulations authorize the issuance of general NPDES permits to categories of discharges
when a number of point sources discharge:

•	The same or substantially similar types of operations;

•	The same type of waste/pollutants;

•	Within a geographic area;

•	Require the same effluent limitations;

•	Require the same or similar monitoring requirements; and

•	In the opinion of EPA, small suction dredge placer miner operations are more appropriately
controlled under a general permit than under individual permits [40 CFR § 122.28],

The EPA has determined that the owners and operators of small placer mining equipment
described in Part I of the draft general NPDES permit IDG-37-0000 are authorized to discharge

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water from small placer miner operations to the waters of the United States described in the
permit, in accordance with effluent limitations, monitoring requirements and other conditions set
forth in the permit. The number of small placer miners covered under this permit will be
determined by the number of NOIs submitted, however a list of 979 potential permittees based
on the Idaho Department of Water Resources (IDWR) previous recreational placer miner permit
applicants. This list includes the waterbodies that have been previously permitted and is
provided in Appendix A of the Biological Evaluation. The permit will expire five years after the
effective date of the permit.

EPA has determined that the general permit for small placer miner operations will contain the
minimum limitations and requirements for authorization to discharge pollutants from this type of
operation. These minimum requirements include water-quality based effluent limits, and
implementation of BMPs.

The Director may require any person authorized by a general permit to apply for and obtain an
individual permit, or any interested person may petition the Director to take this action. The
Director may consider the issuance of an individual permit when:

a.	The single discharge or the cumulative number of discharges is/are a significant contributor of
pollution;

b.	The discharger is not in compliance with the terms and conditions of the general permit;

c.	A change has occurred in the availability of demonstrated technology or practices for the
control or abatement of pollutants applicable to the point source;

d.	Effluent limitations guidelines are subsequently promulgated for the point sources covered by
the general permit;

e.	A Water Quality Management Plan containing requirements applicable to such point sources is
approved.

f.	Circumstances have changed since the time of the request to be covered so that the discharger
is no longer appropriately controlled under the general permit, or either a temporary or
permanent reduction or elimination of the authorized discharge is necessary

Individual NPDES permits for Idaho small placer miner operations will require a Spill
Prevention Control and Countermeasures Plan if the facility meets the requirements for a plan.
Also, individual permits would evaluate water quality standards, monitoring requirements and
reporting requirements on a site-by-site basis.

3.3 Operations covered by the Permit

EPA is proposing to issue a general NPDES permit for the discharge from small placer mining
operations that meet the eligibility criteria in this permit.

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Placer mining involves the mining and extraction of gold or other heavy metals and minerals
primarily from alluvial deposits. These deposits may be in existing stream beds or ancient, often
buried, stream deposits, i.e. paleo or fossil placers. Many placer deposits consist of
unconsolidated clay, sand, gravel, cobble and boulders that contain very small amounts of native
gold or other precious metals. Most are stream deposits that occur along present stream valleys
or on benches or terraces above existing streams.

Dredging systems are classified as hydraulic or mechanical (including bucket dredging),
depending on the methods of digging. Suction dredges, the most common hydraulic dredging
system, are quite popular in Idaho with the small and recreational gold placer miner. Like all
floating dredges, suction dredges consist of a supporting hull with a mining control system,
excavating and lifting mechanism, gold recovery circuits, and waste disposal system. All
floating dredges are designed to work as a unit to dig, classify, beneficiate ores and dispose of
waste. Because suction dredges work the stream bed rather than stream banks, the discharge
from suction dredges consists totally of stream water and bed material.

Suction dredges generally use water pumps driven by gasoline-powered engines. The pump
creates suction in a flexible intake pipe 2 inches in diameter or greater. The suction created in
the intake pipe vacuums the streambed sediment, gravel, smaller rocks, and any included gold
into a sluice, or header, box. The sluice box is a device that channels the water, along with the
vacuumed material, over small ridges that create numerous little pockets of slow or slack water
where the gold drops out and is captured in a grooved board, strip of carpet, or other feature
designed to hold it in place. The water, silt, gravel and other lighter material flows through the
sluice box and back into the stream. The gravel is usually deposited in a pile at the mouth of the
sluice box. The dredge engine, pump, and sluice box are all mounted on a floating platform
tethered over the work area.

Dredge operators study the river or stream looking for "dead" or "slack" water where gold is
most likely to have dropped out of the moving water column. Testing begins once a likely area
is identified. Testing consists of dredging small sample holes down to bedrock or until a hard
pack layer is reached. Gold is sought in the sediments, on the bedrock, or within cracks in the
bedrock. The size of the sample holes is kept as small as possible: usually only big enough to
reach bedrock or compact sediment layer, moving the least material necessary.

The GP authorizes placer mining by suction dredges with intake nozzles less than or equal to 5
inches and equipment rated to 15 horsepower or less, and non-powered sluice equipment moving
less than 50,000 cubic yards per year.

3.4 Receiving waters covered by the Permit

The permit authorizes discharges of specified pollutants to the waters of the United States in
Idaho except those waters excluded from coverage as protected, special, at-risk or degraded
water resources (see Appendix B of the permit). In general, the permit authorizes small suction
dredge placer mining operations to discharge stream water and bed material which are
immediately released back into the receiving waters of rivers, lakes and streams.

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Appendix C of the permit contains a listing of "Areas of Coverage/Areas of Closure". This
listing identifies the stream reaches, and seasons, where recreational dredging and power sluicing
is permitted if the operator obtains a recreational dredging permit.

3.5 Receiving waters not authorized by the Permit

The following are the receiving waters excluded from coverage, i.e., this GP does not authorize
the discharge from placer mining in the water bodies described below.

National Protected Areas: The draft GP does not apply to facilities that are
proposed to be located in National Parks System Units (i.e., Parks and Preserves), National
Monuments, National Sanctuaries, National Wildlife Refuges, National Conservation Areas,
National Wilderness Areas, or National Critical Habitat Areas.

National Wild and Scenic Rivers: Pursuant to the authorities specified in
Section 47-1323, Idaho Code, the State Board of Land Commissioners prohibits dredge mining
in any form from water bodies making up part of the National Wild and Scenic Rivers System.
This includes the following water bodies: Middle Fork of the Clearwater River, Middle Fork of
the Salmon River, and St. Joe River.

Appendix C of the GP, Part 1 provides specific details on the prohibited

waterbodies.

Withdrawn River Segments: Pursuant to the authorities specified in
Section 58-104(a) and 47-702, Idaho Code, the State Board of Land Commissioners has
prohibited recreational dredge and placer mining in certain segments of the following rivers:
Boise River, Payette River, Priest River, Salmon River, and Snake River.

Appendix C of the GP, Part 2 provides the complete list of specific withdrawn
river segments that are closed to placer mining.

State Protected Rivers: Pursuant to the authorities specified in Section 42-
1734A, Idaho Code and adopted by the Idaho Water Resource Board, certain waterways and/or
stream segments are protected as either a State Natural River or as a State Recreational River
with recreational dredge or placer mining prohibited.

Suction dredge mining is prohibited in portions of the following water bodies:
Priest River Drainage, Payette River Drainage, Boise River Drainage, Snake River Drainage,
Henry's Fork Snake River Drainage, South Fork Snake River Drainage, North Fork Clearwater
River Drainage, and Main Salmon River Drainage.

Appendix C of the GP, Part 3 provides a complete list of the segments of State
Protected Rivers where placer mining is prohibited.

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Water Quality Limited Segments: A water quality limited segment is any
waterbody, or definable portion of a waterbody, where it is known that the water quality does not
meet applicable water quality standards, and/or is not expected to meet applicable water quality
standards. Under 303(d) of the CWA, states must identify and list water quality limited
segments.

Section 303(d) requires states to develop a Total Maximum Daily Load (TMDL)
management plan for impaired waterbodies on the list. A TMDL is a mechanism for estimating
the assimilative capacity of a water body and allocating the capacity between point and nonpoint
sources.

There are many waterbodies identified on the State of Idaho's 303(d) list as water
quality limited for sediments. This permit does not authorize discharges from placer mining
operations in these waterbodies, unless there is a TMDL that specifies waste load allocations for
placer mining activities. Currently the only sediment TMDL that specifies allocations for
placer mining is the South Fork Clearwater TMDL.

Appendix C of the Permit, Part 4 contains a current list of segments that are water
quality limited for sediment as of December 2008 and are therefore not included in the coverage
area of this GP. IDEQ may be updating this list during the duration of this GP. Because this
general permit does not relieve a permittee of the requirements of other applicable federal, state
or local laws, it is the responsibility of the permittee to contact IDEQ for the most up-to-date list.
Pages 2 and 3 of this Fact Sheet and page 25 of the draft GP contain contact information.

Appendix B of the GP contains a listing of "Waterbodies Where Placer Mining Is
Not Authorized Under The General Permit". Operation of a recreational dredge on these river
segments is specifically not authorized under this permit.

3.6 Permit Requirements

In establishing permit limits, EPA first determines which technology-based limits apply to the
discharges in accordance with national effluent guidelines and standards. EPA then determines
which water quality-based limits apply to the discharges based upon an assessment of the
pollutants discharge and a review of state water quality standards. The effluent limit for a
particular pollutant is the more stringent of the technology-based effluent limit or the water
quality-based effluent limit.

3.6.1 Technology-based Effluent Limitations

Pursuant to Section 402(a)(2) of the Act and 40 CFR 122.44(k)(2), BMPs are being proposed in
the permit. Suction dredging's unique method of intake and displacement present unusual
permitting issues. As discussed above, a suction dredge is a mechanical device that floats on the
stream surface and pumps stream water and stream bed material through a suction intake conduit
to a sluice box from which gold or other minerals may be recovered. The discharge from suction
dredges consists totally of stream water and bed material immediately released back into the
receiving water. The BMPs in the permit are being proposed because technology-based numeric
effluent limitations are not feasible.

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3.6.2	Water quality-based Effluent Limitations

Section 301(b)(1) of the Act requires the establishment of limitations in permits necessary to
meet water quality standards by July 1, 1977. All discharges to state waters must comply with
state and local coastal management plans as well as with state water quality standards, including
the State's anti-degradation policy. Discharges to state waters must also comply with limitations
imposed by the state as part of its certification of NPDES permits under § 401 of the Act.

The NPDES regulations at 40 CFR 122.44(d)(1) require that permits include water quality-based
limits that "Achieve water quality standards established under § 303 of the CWA, including State
narrative criteria for water quality."

EPA has determined that turbidity is a pollutant of concern. Required turbidity monitoring is
designed to ensure that the BMPs are being implemented properly. The draft GP requires a daily
visual inspection for turbidity of the area within 500 feet downstream of the suction dredge
during operation. A visual increase in turbidity (any cloudiness or mudiness) above background
turbidity 500 ft. downstream of the suction dredge during operations is considered a violation of
this permit. This also includes any turbidity that may result from any other part of the operation.
If turbidity is observed beyond 500 feet, the draft GP requires the permittee to modify the
operation to meet the permit limitation. If the operation cannot be modified to meet the limit, the
operation is not authorized. In most cases, water quality recovers rapidly. The daily inspection
during operation, combined with the BMPs will assure that the water quality standards are met.

A copy of the draft GP is included in Attachment 2 of this BE. The GP will be finalized
following completion of this consultation.

3.6.3	Monitoring Requirements

Compliance with Idaho Department of Water Resource's (IDWR's) Stream Channel Permit is
regarded as adequate monitoring for suction dredge facilities. Suction dredge operators shall
visually monitor for turbidity at least once per day of operation. Individuals who conduct visual
monitoring shall observe the turbidity plume, where visible, immediately downstream or radially
from the dredge until the turbidity plume is no longer visible and note the distance.

There is no need to conduct more extensive monitoring if the turbidity plume blends with the
background at a distance of less than 500 feet.

All turbidity monitoring results shall be recorded daily. The permittee shall maintain records of
all information resulting from any visual inspections. Visual violation occurrences will be
reported to the EPA NPDES Compliance Unit along with the measures taken to comply with the
provisions of the GP.

3.6.4	Best Management Practices

BMPs are measures that are intended to prevent or minimize the generation and the potential for
the release of pollutants from industrial facilities to the waters of the United States through
normal operations and ancillary activities. Pursuant to Section 402(a)(1) of the CWA,

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development and implementation of BMP Plans may be included as a condition in NPDES
permits. Section 402(a)(1) authorizes EPA to include miscellaneous requirements that are
deemed necessary to carry out the provision of the Act in permits on a case-by case basis. BMPs
are required to control or abate the discharge of pollutants in accordance with 40 CFR §
122.44(k). The proposed permit requires compliance with the following BMPs:

A. Dredging of concentrated silt and clay should be avoided.

The Permittee shall use reasonable care to avoid dredging silt and clay materials that
would result in a significant increase in turbidity. Reasonable care includes moving the
dredge to a new location or reducing the volume of effluent discharge by limiting
operation speed of the suction dredge.

This practice will decrease the amount of fine material that will be released into the
water that could cause turbidity plumes in excess of the permitted distance.

B.	If mercury is found during suction dredge operation, (i.e. mercury is collected in the sluice
box), the operator must:

1)	Stop dredging immediately;

2)	Contact the local regional office of IDEQ (see page 3 for contact information);

3)	Keep the mercury collected, do not remobilize the collected mercury; and

4)	Work with the appropriate regional office of IDEQ to dispose of the mercury properly.

Mercury was used in historic placer mining operations to amalgamate gold fines.
Elemental mercury may be present in stream beds and banks and if remobilized
can result in impacts to fish and other aquatic life. Placer miners encountering
mercury should take above steps to prevent mercury from reentering the water
body.

C.	Suction dredges shall not operate within 800 feet of:

1)	another suction dredging operation occurring simultaneously or,

2)	a location where it is apparent that another operation has taken place within the past
month

This practice should ensure that the mixing zone of a facility does not overlap
with that of another since 800 feet is the distance of a 500 foot mixing zone for
each operation plus a designated 300 foot buffer before the next suction dredge
would impact water quality.

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A study conducted by the EPA on the Fortymile River in Alaska found turbidity and total
filterable solids were substantially elevated downstream of the dredge, although it was spatially
confined to within 525 ft of the dredge and was restricted to the portion of those days that the
dredge was operating (EPA 1999).

D.	Dredging and discharging are prohibited within 500 feet of locations where:

1)	fish are spawning or

2)	fish eggs or alevins are known to exist at the time dredging occurs

In addition: Suction dredge operation must not occur in gravel bar areas at the tail
of pools or where operations result in fine sediments discharging onto gravel bars.

This BMP is designed to minimize impacts to fish spawning and spawning habitat.

E.	Suction dredge operation must not change the stream channel way that directs the flow of
water into a stream bank, which may cause bank erosion or destruction of the natural form of the
stream channel.

Under Section 101 of the Clean Water Act, EPA is required to restore and maintain the
chemical, physical and biological integrity of waters of the United States. Protection of
the physical integrity of waterbodies includes protection of habitat

F.	Suction dredge operation that results in undercutting, littoral channeling, stream bank or beach
erosion, is prohibited.

This practice will ensure that erosion does not occur and that the finer sediments that
may be found in these areas do not cause excessive turbidity in the receiving waters.

G.	Damming or diversions within a stream channel are prohibited under this GP.

EPA cannot authorize dams or diversions under Section 402 of the CWA. These are
generally authorized under Section 404 of the CWA which is administered by the U.S.
Army Corps of Engineers.

H.	Explosives, motorized winches or other motorized equipment to move boulders, logs, or other
natural obstructions are prohibited under this GP.

This practice should ensure that important habitat which includes large organic debris
and large boulders in these areas will not be destroyed.

I.	Wheeled or tracked equipment used in-stream is prohibited while dredging is in progress.

This practice should minimize turbidity from sources other than the suction dredge.
J. Care shall be taken by the operator during refueling of equipment to prevent spillage.

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Any spills shall be cleaned up using materials such as sorbent pads and booms.
All spills shall be reported immediately or as soon as practical to IDEQ and the

All chemical or petroleum products shall be stored in a safe and secure location at all
times. Fuel not stored and dispensed with an ANSO or UL approved safety container
must be maintained not less than 100 feet from the mean high water mark.

This practice will decrease the potential for contamination of surface water by petroleum
products.

SECTION 4 DESCRIPTION OF ACTION AREA

Since the proposed action is an issuance of the NPDES permit, the direct effects are those that
would cause toxicity to a listed species from individual and combined pollutant concentrations
within the action area. The presence of parameters regulated by the permit could potentially be
present at a concentration that could cause toxicity to a listed species at different distances
downstream from the discharge, depending upon the effluent limit, available dilution from the
river, and the physical and chemical characteristics of the parameter.

The area where direct effects may occur commences at the point of discharge. Therefore, the
action area is bounded on the upper end at the outfall. The action area downstream for a specific
parameter depends on the physical and chemical properties that cause it to degrade or dilute as it
travels downstream. A parameter that is highly volatile or readily biodegradable in a river may
be present over a relatively small downstream area at a concentration that could potentially cause
toxicity, because several mechanisms effectively remove the parameter from the river. On the
other hand, a parameter that is persistent in the environment and is not readily biodegraded in a
river system might be present over a longer downstream distance at a concentration that could
potentially cause toxicity because removal mechanisms are less effective in eliminating this
parameter from the river.

Indirect effects for the proposed action are those that would cause an effect to a listed species or
habitat from individual and/or combined pollutant concentrations within the waterbody at a later
time. These effects would result from delayed exposure (e.g., uptake of deposited effluent
constituents from sediment resuspension), consumption of prey species, and habitat modification
(e.g., deposited effluent constituents on the riverbed, decrease in photosynthesis). Any of these
indirect effects could occur as long as there is influence on the receiving water column and
sediment quality from the discharge. Therefore, the indirect action area extends to the point
downstream where an indirect adverse effect could occur (e.g., where the concentration of a
parameter in the sediment resulting from the effluent discharge is high enough to cause an
adverse effect to threatened and endangered fish species).

The action area of coverage for the GP is located within all waterbodies of Idaho downstream of
the facilities covered by the GP.

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4.1 Biological Requirements in the Action Area

The biological requirements of ESA-listed species can be considered, at a minimum, to be met if
the species have access to critical habitat. Critical habitat is defined under Section 3 of the ESA
as "the specific areas within the geographic area occupied by a federally listed species on which
are found physical and biological features essential to the conservation of the species, and that
may require special management considerations or protection." Of the species that are evaluated
in this BE, six species, anadromous steelhead trout, bull trout, Snake River sockeye salmon, and
fall and spring/summer run Chinook salmon, have critical habitat designated within the action
area.

4.2	Environmental Baseline

There are over 115,000 thousand miles of rivers, streams and creeks in Idaho. Idaho reports that
52% of river and stream miles support aquatic life. Based on the state's 2008 Section 303(d) list,
the major causes of impairment in Idaho's rivers and streams include siltation, nutrients, flow
alterations, thermal modifications, and bacteria. Most of Idaho's rivers and streams flow into one
of five major river basins; the Snake, the Clearwater, the Salmon, the Bear, and the St. Joe.

Since the BE covers impacts from small placer miners discharging into surface waters, only
information on surface water quality was used in describing the environmental baseline for this
BE.

Additional information on baseline environmental conditions within the State of Idaho was
obtained from Idaho's 2008 Integrated 303(d)/305(b) Report published by DEQ in 2008. Every
two years, DEQ is required by the federal Clean Water Act to conduct a comprehensive analysis
of state water bodies to determine whether they meet state water quality standards or if additional
pollution controls are needed to meet beneficial uses.

Assessed water bodies are designated in the 2008 Integrated 303(d)/305(b) Report as either
supporting or not supporting water quality standards and beneficial uses. Water bodies that do
not meet water quality standards are called "water quality limited" or "impaired," and require
development of water quality management plans known as Total Maximum Daily Loads
(TMDLs) to bring them back into compliance and protect their beneficial uses. Water bodies
previously designated impaired that now meet water quality standards are removed from the
water quality limited list.

4.3	Water Quality

According to Idaho DEQ, there is approximately 115,595 miles of water in Idaho, of which more
than half (60,245 miles or 52 percent) have been monitored and assessed (DEQ 2008).
Approximately 26,000 miles of streams monitored and assessed during this cycle were found to
meet water quality standards. The proportion of streams meeting their beneficial uses is
increasing. The number of miles of water quality limited or impaired streams comprise a total of
34,175 miles compared to 21,000 in 2003, according to DEQ (IDEQ2003, 2008). Of those water
assessed in the most recent listing cycle, 43 percent met water quality standards. It is estimated

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that twenty percent of all waters in the state are deemed to meet water quality standards and their
beneficial uses (DEQ 2003).

Approximately 13,000 miles of TMDLs submitted to EPA have been approved (IDEQ 2008). In
2003, because flow and habitat are not considered pollutants under the Clean Water Act and do
not require a TMDL, 4,609 miles of streams were removed from those needing TMDLs because
they were listed for flow and/or habitat alternation (IDEQ 2003). During the most recent listing
cycle, 207 assessment units were added for temperature violations. However, many of these may
be due to natural background. Further study may find some of these are not water quality
limited.

According to the 2008 report, 17,060 miles of rivers and streams are threatened or impaired due
to sediment. This comprises 28% of the total miles assessed and 50% of the total impaired
miles. Approximately 5,338 miles of rivers and streams are impaired due to nutrients. This
comprises approximately 9% of the total miles assessed and 16% of the total impaired miles.
Approximately 15,293 miles are threatened or impaired due to temperature. This comprises
approximately 25% of the total assessed miles and 45% of the total impaired miles. The report
also states that 221.6 miles are threatened or impaired due to placer mining, which comprises
less than one percent of the total assessed miles.

Forty one percent of impaired waters in Idaho have complete TMDLs, while 58% are still
awaiting TMDLs and one percent of impaired waters are due to non-pollutant impairment (DEQ
2008). Of the TMDLs completed for impaired waters, more than 65 percent of the violations
were due to sediment, temperature, or nutrient exceedences, while the remainder were
attributable to violations for bacteria, biological impairment, organic enrichment/low dissolved
oxygen, metals, pathogens, unionized ammonia, oil and grease, and other unspecified violations
(DEQ 2003, 2008).

The Idaho State of the Environment Report 2001, published by the Idaho Department of
Environmental Quality (DEQ), provides an overview of environmental conditions in Idaho and
discusses environmental data collected throughout the state. According to the report, the
information on the environment is to be used in subsequent investigations as "indicators" of the
health of the environment. Five indicators of environmental health are used in the report:

Air quality,

Drinking water quality,

Ground water quality,

Surface water quality, and
Areas of waste contamination

The information in the State of the Environment Report is presented for each of five river basins:

Panhandle
Clearwater
Salmon
Southwest

Upper Snake/Bear River

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The Upper Snake River and Bear River basins were reported as a single basin. This information
is summarized in Table 3. As can be seen from the information in the table, only about 12
percent of Idaho's streams and rivers have been assessed for water quality, and of those water
that have been assessed, about 60 percent are water quality limited (DEQ 2001). The three
primary pollutants of concern for each of the river basins are sediments, nutrients, and
temperature.

Table 3. Surface Water Quality Monitoring Information by River Basin (DEQ 2001)

Basin

Total Stream
Miles

Stream Miles
Assessed

Water Quality
Limited (Miles)

Pollutants of
Concern

Monitoring
Sites

Panhandle

8,871

1,856

904

Sediments
Nutrients
Temperature
Metals

281

Clearwater

12,674

2,064

1,078

Sediments
Nutrients
Temperature

246

Salmon

17,879

2,400

1,179

Sediments
Nutrients
Temperature

228

Southwest

22,472

4,743

2,600

Sediments
Nutrients
Temperature
Bacteria

474

Upper Snake/
Bear River

58,385

3,457

2,930

Sediments
Nutrients
Temperature
Bacteria
Selenium

759

Total

120,281

14,520

8,691



1,988

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SECTION 5 SPECIES DESCRIPTIONS

This section describes the threatened and endangered (T&E) species that may occur in the action
area as indicated by the USFWS and NMFS. The discussion includes the life history, habitat
use, and habitat concerns as well as specific information on the abundance and timing of
occurrence of each species within the Action Area.

5.1 Banbury Springs Lanx (Lanx sp.)

The Banbury Springs lanx was first listed as endangered on December 14, 1992. This snail is a
member of Lancidae, a small family of pulmonates (snails that possess lunglike organs) endemic
to western North America. The species was first discovered in 1988 and has not been formally
described.

5.1.1	Range of Species

This lanx was first discovered in 1988 at Banbury Springs at river mile (rm) 589, with a second
colony found in nearby Box Canyon Springs at rm 588 in 1989. During 1991, a mollusc survey
at The Nature Conservancy's Preserve revealed a third colony in the outflows of Thousand
Springs (rm 584.6). Subsequent to this discovery, a more detailed investigation at the Preserve
revealed that the single colony was sporadically distributed within an area of only 129 to 151
square feet (ft2) (Frest and Johannes 1992). Population density ranged from 4 to 20
individuals/square inch (in2). The total adult population at the Preserve was estimated at
between 600 and 1,200. All three colonies of lanx were discovered in alcove spring complexes.
These spring complexes contain large areas of adjacent, presumably identical, habitat not
occupied by the species. At present, the Banbury Springs lanx is known to occur only in the
largest, least disturbed spring habitats at Banbury Springs, Box Canyon Springs, and Thousand
Springs.

5.1.2	Critical Habitat

No critical habitat has been designated for the Banbury Springs Lanx.

5.1.3	Life History

The species has been found only in spring-run habitats with well-oxygenated, clear, cold 59 to
61° F waters on boulder or cobble-size substrate. All known locations have relatively swift
currents. They are found most often on smooth basalt and avoid surfaces with large aquatic
macrophytes or filamentous green algae. The species has been reported at depths ranging from
12 to 30 inches on boulder substrate (Beak 1989). The species has been found in water as
shallow as 2 inches, but depths up to 6 inches were more typical. All lancids are particularly
affected by dissolved oxygen fluctuations since respiration is accomplished only through the
mantle; lungs, gills, and other specialized respiratory structures are lacking (Frest and Johannes
1992).

5.1.4	Population Trends and Risks

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The free-flowing, cool water environments required by these species have been impacted by and
are vulnerable to continued adverse habitat modification and deteriorating water quality from one
or more of the following: hydroelectric development, peak-loading effects from existing
hydroelectric project operations, water withdrawal and diversions, water pollution, and
inadequate regulatory mechanisms.

5.2 Bliss Rapids Snail (Taylorconcha serpenticola)

The Bliss Rapids snail was listed as threatened under the ESA on December 14, 1992.

5.2.1	Range of Species

The Bliss Rapids Snail was known historically from the mainstem middle Snake River and
associated springs between Indian Cove Bridge (rm 525.4) and Twin Falls (rm 610.5) (Hershler
et al. 1994). Based on live collections, the species currently exists as discontinuous populations
within its historic range. These colonies are primarily concentrated in the Hagerman reach, in
tail waters of Bliss and Lower Salmon Dams and several unpolluted springs including Thousand
Springs, Banbury Springs, Box Canyon Springs and Niagara Springs.

5.2.2	Critical Habitat

No critical habitat has been designated for the Bliss Rapids snail.

5.2.3	Life History

This snail occurs on stable cobble-boulder size substrate in flowing waters of unimpounded
reaches of the mainstem Snake River and in a few spring habitats in the Hagerman Valley. The
species does not burrow in sediments and normally avoids surfaces with attached plants. Known
river populations of the Bliss Rapids snail occur only in areas associated with spring influences
or rapids-edge environments and tend to flank shorelines. They are found at varying depths if
dissolved oxygen and temperature requirements persist and are found in shallow (0.5 inches)
depth, permanent, cold springs (Frest and Johannes 1992). The species resides on the lateral
sides and undersides of rocks during daylight. The species can be locally quite abundant,
especially on smooth rock surfaces with common encrusting red algae.

5.2.4	Population Trends and Risks

The free-flowing, cool water environments required by these species have been impacted by and
are vulnerable to continued adverse habitat modification and deteriorating water quality from one
or more of the following: hydroelectric development, peak-loading effects from existing
hydroelectric project operations, water withdrawal and diversions, water pollution, and
inadequate regulatory mechanisms. Additionally, a primary reason for listing the Bliss Rapids
snail as threatened in the Snake River drainage was the perceived impacts of the highly invasive
New Zealand mudsnail.

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5.3 Bruneau Hot Springsnail (Pyrgulopsis bruneauensis)

The Bruneau hot springsnail was listed as endangered under the ESA on February 24, 1993.

5.3.1	Range of Species

The Bruneau hot springsnail is found only in the springflows of Hot Creek and 128 small,
flowing thermal springs and seeps along an approximately 5.3 mile length of the Bruneau River
in southwestern Idaho (Mladenka 1992). A majority of occupied springsnail habitats are located
along both shorelines of the Bruneau River up to 2.8 miles above its confluence with Hot Creek
while the remaining sites occur up to 2.7 miles below the Hot Creek-Bruneau River confluence.
Most of the springs and seeps containing springsnails are small, ranging from 1.6 ft2 to 398 ft2 in
area, with a mean size of almost 10.8 ft2. These spring sites are located primarily above the
high-water mark of the Bruneau River and are separated by distances of less than 3.3 feet to
greater than 6,562 feet (Mladenka 1992). Most of the springs along the Bruneau River upstream
of Hot Creek are on lands administered by the Bureau of Land Management (BLM), while most
springsnail habitats downstream of the Indian Bathtub and Hot Creek are on private land.

5.3.2	Critical Habitat

No critical habitat has been designated for the Bruneau hot springsnail.

5.3.3	Life History

The species has been found in flowing thermal springs and seeps with temperatures ranging from
60.3 to 96.3 0 F (Mladenka 1992). No Bruneau hot springsnails have been collected outside
thermal plumes of hot springs entering the Bruneau River. They are found in these habitats on
the exposed surfaces of various substrates, including rocks, gravel, sand, mud and algal film.
However, during the winter period of cold ambient temperatures and icing, the springsnails are
most often located on the undersides of outflow substrates, habitats least exposed to cold
temperatures. Springsnail abundance generally fluctuates seasonally; abundance is influenced
primarily by water temperature, spring discharge and food availability.

Springsnails appear to be opportunistic grazers as food habit studies reveal algal genera are taken
in proportions similar to those found in their habitat (Mladenka 1992). However, springsnail
densities are lowest in areas of bright green algal mats, while higher snail densities occur where
periphyton communities are dominated by diatoms.

Sexual maturity can occur at two months. Reproduction occurs throughout the year except when
inhibited by high or low temperatures (Mladenka 1992). At sites affected by high ambient
temperatures during summer and early fall months, recruitment was seasonal, corresponding
with cooler periods. Likewise, sites with cooler ambient temperatures would likely exhibit
recruitment during the summer months. Springsnails use "hard" surfaces such as rock substrate
to deposit their eggs. They may deposit eggs on other snails' shells when other hard surfaces are
unavailable.

5.3.4	Population Trends and Risks

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The primary threat to this species continues to be agriculture-related ground-water withdrawal
and pumping. As the Bruneau Valley Aquifer is depleted, the geo-thermal springs that are
essential to the survival of this snail cease to flow and become filled with sediment. Within the
past 25 years, flows from the Indian Bathtub springs have decreased, thereby restricting the
springnail's habitat area and reducing its numbers. Ongoing drought conditions since the mid-
1980's have resulted in increased reliance on ground water for irrigated agriculture in the
Bruneau basin, causing the extent of seepage at several of the springnail's spring sources to be
greatly reduced in recent years. Considerable springsnail habitat has also been lost in recent
years due to sedimentation from flash flooding. In Hot Creek, approximately 1,000,000
Pyrgulopsis bruneauensis were estimated to occur in the "Low Indian Bathtub Hot Spring" in
1982, with as many as 60 snails/in2 observed on the wetted rockfaces surrounding Indian
Bathtub (Taylor 1982). A flood event occurred in Hot Creek in July 1992 which drastically
reduced P. bruneauensis from Hot Creek by filling much of the Indian Bathtub area with
sediment (Royer and Minshall 1993), and by 1997, the population had been totally extirpated
(Varricchione et al. 1997).

5.4 Bull Trout (Salvelinus confluentus)

The bull trout was listed as threatened under the ESA on June 10, 1998. Critical habitat for the
Bull trout was designated on September 26, 2005.

5.4.1	Range of Species

Bull trout are members of the char subgroup of the family Salmonidae and are native to waters of
western North America. Bull trout range throughout the Columbia River and Snake River
basins, extending east to headwater streams in Montana and Idaho, into Canada, and in the
Klamath River basin of south-central Oregon. The distribution of populations, however, is
scattered and patchy

5.4.2	Critical Habitat

Approximately 294 stream/shoreline miles have been designated in Idaho as critical habitat for
the bull trout. River basins with designated critical habitat include the Clark Fork, Kootenai,
Coeur d' Alene Lake, Clearwater, Salmon, Southwest Idaho, Little Lost, Imnaha-Snake, and
Hells Canyon Complex. No critical habitat has been designated for the Jarbidge River
population of bull trout in Nevada and southern Idaho, where the Secretary of the Interior
determined that the benefits of excluding the area outweighed the benefits of including it.

5.4.3	Life History

Bull trout and some other species are commonly referred to as "anadromous" (fish that can
migrate from saltwater to freshwater to reproduce). Bull trout exhibit a number of life history
strategies. Stream-resident bull trout complete their entire life cycle in the tributary streams
where they spawn and rear. Most bull trout are migratory, spawning in tributary streams where
juvenile fish usually rear from 1 to 4 years before migrating to either a larger river or lake where
they spend their adult life, returning to the tributary stream to spawn. Resident and migratory
forms may be found together, and either form can produce resident or migratory offspring. Bull

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trout can grow to more than 20 pounds in lake environments and live up to 12 years. Under
exceptional circumstances, they can live more than 20 years (USFWS 2005).

5.4.4 Population Trends and Risks

Bull trout have declined due to habitat degradation and fragmentation, blockage of migratory
corridors, poor water quality, past fisheries management, and the introduction of non-native
species such as brown, lake and brook trout. While bull trout occur over a large area, their
distribution and abundance has declined and several local extinctions have been documented.
Many of the remaining populations are small and isolated from each other, making them more
susceptible to local extinctions.

5.5 Snake River Fall Chinook Salmon (Oncorhynchus tshawytscha)

The fall Chinook salmon was listed as threatened under the ESA on April 22, 1992. Critical
Habitat was designated on December 28, 1993.

5.5.1	Range of Species

The evolutionary significant unit of fall Chinook salmon includes all naturally spawned
populations of fall-run Chinook salmon in the mainstem Snake River below Hells Canyon Dam,
and in the Tucannon River, Grande Ronde River, Imnaha River, Salmon River, and Clearwater
River, as well as four artificial propagation programs: the Lyons Ferry Hatchery, Fall Chinook
Acclimation Ponds Program, Nez Perce Tribal Hatchery, and Oxbow Hatchery fall-run Chinook
hatchery programs.

5.5.2	Critical Habitat

Designated critical habitat for fall Chinook salmon in Idaho consists of river reaches of the
Snake River, and all tributaries of the Snake River presently or historically accessible to Snake
River spring/summer Chinook salmon (except reaches above impassable natural falls, and
Dworshak and Hells Canyon dam).

5.5.3	Life History

Snake River fall-run Chinook salmon enter the Columbia River in July and August. The Snake
River component of the Chinook salmon fall run migrates past the lower Snake River mainstem
dams from August through November. Spawning occurs from October through early December.
Juveniles emerge from the gravels in March and April of the following year. Snake River fall-
run Chinook salmon exhibit an ocean-type life history pattern, with juveniles migrating
downstream from their natal spawning and rearing areas from June through early fall (USFWS
2005)

5.5.4	Population Trends and Risks

It has been estimated that 55 to 90 percent of migrating smolts do not make it downstream due to
hydropower facilities. These facilities may create weak water currents, warm waters, blocked

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migratory routes and dangerous turbines that can negatively affect the species. Habitat loss and
degradation; agricultural, urban and industrial pollution; mistaken angler harvest; clearcutting,
removal of streamside vegetation and livestock use; and some hatchery practices also pose
threats to the fall Chinook salmon (USFWS 2005).

5.6 Snake River Spring/Summer Chinook Salmon (Oncorhynchus tshawytscha)

The spring/summer Chinook salmon was listed as threatened under the ESA on April 22, 1992.
Critical Habitat was designated on December 28, 1993.

5.6.1	Range of Species

In general, spring-run type Chinook salmon tend to spawn in higher-elevation reaches of major
Snake River tributaries in mid- through late August, and summer-run Snake River Chinook
salmon spawn approximately one month later than spring-run fish. Summer-run Chinook
salmon tend to spawn lower in the Snake River drainages, although their spawning areas often
overlap with spring-run spawners.

5.6.2	Critical Habitat

Designated critical habitat for Spring/Summer Chinook salmon in Idaho consists of river reaches
of the Snake River, and all tributaries of the Snake River (except the Clearwater River) presently
or historically accessible to Snake River spring/summer Chinook salmon (except reaches above
impassable natural falls and Hells Canyon Dam).

5.6.3	Life History

Spring/summer-run Chinook salmon from the Snake River basin exhibit stream-type life history
characteristics. Eggs are deposited in late summer and early fall, incubate over the following
winter, and hatch in late winter and early spring of the following year. Juveniles rear through the
summer, overwinter, and migrate to sea in the spring of their second year of life. Depending on
the tributary and the specific habitat conditions, juveniles may migrate extensively from natal
reaches into alternative summer-rearing or overwintering areas. Snake River spring/summer-run
Chinook salmon return to natal rivers to spawn as 4- and 5-year-old fish after 2 to 3 years in the
ocean. A small fraction of the fish return as 3-year old "jacks," heavily predominated by males
(USFWS, 2005).

5.6.4	Population Trends and Risks

Tributary habitat conditions vary widely among the various drainages of the Snake River basin.
Habitat is degraded in many areas of the basin, reflecting the impacts of forest, grazing, and
mining practices. Impacts relative to anadromous fish include lack of pools, higher water
temperatures, low water flows, poor overwintering conditions, and high sediment loads.
Substantial portions of the Salmon River drainage, particularly in the middle fork, are protected
in wilderness areas.

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5.7 Grizzly Bear (Ursus arctos)

The grizzly bear was listed as threatened under the ESA on July 28, 1975.

5.7.1	Range of Species

The historical range of the grizzly bear included a variety of habitats across most of North
America. However, grizzly bear populations today only occupy two percent of their original
range (in the lower 48 states). They are generally found in wilderness areas of Alaska, Idaho,
Montana, Washington and Wyoming. The Idaho populations of grizzly bears are estimated to
include 30 to 40 bears that are found in the Cabinet-Yaak Recovery Zone, the Selkirk Mountain
Recovery Zone with approximately 40 to 50 bears and the Yellowstone Recovery Zone with
approximately 580 bears (USFWS, 2009). On March 22, 2007, the U.S. FWS announced that the
Yellowstone Distinct Population Segment (DPS) of grizzly bears was recovered, however this
decision was remanded on September 21, 2009 and the threatened status was reinstated for this
DPS of grizzly bear.

5.7.2	Critical Habitat

The USFWS has not designated any critical habitat for the grizzly bear.

5.7.3	Life History

A grizzly bear can stand up to nine feet tall, and adult males can weigh as much as 600 pounds.
Females generally are smaller, weighing about 250 to 350 pounds. Grizzlies prefer open
meadows and avalanche chutes in the spring and timberlands with berry bushes in late summer
and fall. The bear will forage for wild fruits, nuts, bulbs and roots, and it has been known to tear
rotten logs apart and overturn heavy stones in search of insects and larvae. Using its powerful
sense of smell, the grizzly finds carcasses of elk, deer and cattle to feed upon. Huge amounts of
food are consumed by the bear to build enough fat to sustain it through a long winter hibernation
period from November through April with no water nourishment.

Bears begin searching for their ideal den in early fall. Females produce an average of two cubs
every three years, and they stay with their young cubs for about two years. In Idaho, grizzly bear
range averages 200 to 300 square miles.

5.7.4	Population Trends and Risks

Grizzlies were almost extirpated from America's wildlands after more than a century of
unregulated killing. Habitat loss and low reproductive rates continue to affect grizzly bear
numbers in Idaho.

5.8 Kootenai River White Sturgeon (Acipenser transmontanus)

The Kootenai River population of white sturgeon was listed as endangered under the ESA on
September 6, 1994. Critical habitat was revised on July 9, 2008.

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5.8.1 Range of Species

Being one of 18 land locked populations of white sturgeon found in the Pacific Northwest, the
Kootenai River population of white sturgeon has a distribution extending from Montana to
British Columbia. Specifically their distribution extends from Kootenai Falls, Montana, located
31 river-miles below Libby Dam, downstream through Kootenay Lake to Corra Linn Dam on the
lower West Arm of Kootenay Lake, British Columbia (USFWS 1999).

5.8.2	Critical Habitat

The USFWS designated approximately 18.3 river miles of the Kootenai River as critical habitat
for the Kootenai River White Sturgeon. Critical habitat is currently designated in the braided
reach from RM 159.7 below the confluence with the Moyie River, downstream to RM 152.7 at
Bonners Ferry and continues downstream into the meander reach to RM 141.4 (71 FR 6383).

5.8.3	Life History

White sturgeon in general are a long lived species with females living from 34-70 years with
some individuals approaching 100 years (PSMFC 2008). Kootenai sturgeon reach sexual
maturity at 28 and 30 years, respectively, for males and females (Paragamian 2005).

Historically, prior to construction of the Libby Dam, spawning areas for white sturgeon were not
specifically known. From 1990 to 1998 monitoring programs were conducted that discovered
white sturgeon spawning areas within a 12-mile reach of the Kootenai River, primarily from
Bonners Ferry, Idaho downstream to the lower end of Shorty's Island (USFWS 1999).

Historically, spring runoff and warming water temperatures triggered the movement of white
sturgeon upstream to the spawning areas and their preparation physiologically for spawning.
White sturgeon spawn in fast-flowing water and water velocity acts as a clue for spawning.

Water depth also appears to be an important factor in spawning site selection for the Kootenai
sturgeon. White sturgeon usually broadcast their eggs over clean cobble at depths greater than
20 feet at column velocities greater than 0.8 meters per second. Kootenai sturgeon spawn within
a fairly narrow range of water temperatures, from 47.3 to 53.6° F (Paragamian et al. 2002).

Females are reported to spawn at 4 to 6 year intervals (USFWS 2008). The last significant
sturgeon recruitment in the Kootenai River occurred in 1974, prior to the Libby Dam becoming
operational (Partridge 1983). Recruitment failure is largely attributed to the spawning of
Kootenai sturgeon over unsuitable sandy substrates (Paragamian et al. 2001). Based on data
from 1992 through 2001, it is estimated that on average a total of only about 10 juvenile sturgeon
currently may be naturally produced annually in the Kootenai River.

5.8.4	Population Trends and Risks

The number of Kootenai sturgeon has decreased from approximately 7,000 individuals in the
1970s to fewer than an estimated 500 adults in 2005. It is projected that fewer than 30 females
will be spawning annually after the year 2015 (Paragamian 2005).

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Successful reproduction is dependent upon Kootenai sturgeon spawning at sites where the eggs
can settle in an area that supports their viability, and where the embryos have appropriate habitat
for development and protection from predators, which includes rocky substrates for spawning
and attachment of eggs. The braided reach consists of multiple shallow channels over gravel and
cobble and the meander reach is characterized as sandy substrate with low water velocities and
deep holes which is frequented by sturgeon in spawning condition. Shallow waters have
occurred in the braided reach following construction of the Libby Dam and this suggests a
possible behavioral barrier to migration into the upstream canyon reach, where suitable spawning
and incubation habitat appears to exist.

The Kootenai River population of white sturgeon is considered to be at risk due to the following
factors:

•	Hydropower operations, including decreased discharges resulting in less spawning habitat
(NBS 2005).

•	Flood control operations;

•	Poor recruitment;

•	Loss of habitat; and

•	Possibly contaminants affecting the water quality of their habitat (USFWS 1999).
5.9 Snake River Physa Snail (Talorconcha serpenticola)

The Snake River physa snail was listed as endangered under the ESA on December 14, 1992.

5.9.1	Range of Species

From 1956 through 1985 collections of the Snake River physa snail have been made from
Grandview upstream through the Hagerman Reach. This is considered the 'modern' historic
range for this species. Today, two populations are believed to remain in the Hagerman and King
Hill reaches, with potentially a third colony located immediately downstream of Minidoka Dam
(USFWS 1995).

5.9.2	Critical Habitat

The USFWS has not designated any critical habitat for the Snake River physa snail.

5.9.3	Life History

The Snake River physa snails occur in swift current of mainstem rivers on the underside of
gravel to boulder size substrates. Specimens have been found living at the margin of rapids at
the deepest accessible part of the river. It is believed that these snails are restricted to moving
waters of relatively good quality. This species likely lives for up to or just over one year based
on the life histories of other physid species.

5.9.4	Population Trends and Risks

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The factors that are threatening the Snake River physa snail include habitat destruction as a result
of dam construction and the formation of reservoirs and habitat deterioration as a result of
reduced water quality. Both factors lead to habitat fragmentation and eventually the isolation of
smaller populations which makes them more vulnerable to environmental changes and
fluctuations in population cycles. An additional threat comes from the presence of the New
Zealand mudsnail (Potamopyrgus antipodarum) that competes directly with the Snake River
physa snail for habitat in the mainstem Snake River (USFWS 1995).

5.10 Snake River Sockeye Salmon (Oncorhynchus nerka)

The Snake River sockeye salmon was listed as endangered under the ESA on November 20,
1991 and reaffirmed on June 28, 2005. A final designation for critical habitat was published on
December 28, 1993.

5.10.1	Range of Species

Numbers of Snake River sockeye salmon have declined dramatically over the years. In Idaho,
only the lakes of the upper Salmon River (Stanley Basin) remain as potential sources of
production. Historically, five Stanley Basin lakes (Redfish, Alturas, Pettit, Stanley, and Yellow
Belly lakes) supported sockeye salmon (Bjornn et al. 1968). Currently, only Redfish Lake
receives a remnant anadromous run. The Stanley Basin lakes are located within the Sawtooth
National Recreation Area. Basin lakes are glacial-carved and receive runoff from the east side of
the Sawtooth and Smoky mountains. All Basin lakes drain to the upper Salmon River which
flows into the Snake River and ultimately the Columbia River. Redfish Lake is located
approximately 1,450 river kilometers from the confluence of the Columbia River with the Pacific
Ocean.

5.10.2	Critical Habitat

The USFWS designated critical habitat for sockeye salmon on December 28, 1993. Critical
habitat for the Snake River sockeye salmon consists of river reaches of the Columbia, Snake, and
Salmon Rivers, Alturas Lake Creek, Valley Creek, and Stanley, Redfish, Yellow Belly, Pettit,
and Alturas Lakes (including their inlet and outlet creeks).

5.10.3	Life History

Sockeye salmon spawn in North America from the Columbia River in Oregon north to the
Noatak River in Alaska; and in Asia from Hokkaido, Japan north to the Anadyr River in Russia.
The vast majority of sockeye salmon spawn in inlet or outlet streams of lakes or in the lakes
themselves. The juveniles of these "lake-type" sockeye salmon rear in lake environments for 1
to 3 years, migrate to sea, and return to natal lake systems to spawn after 1 to 4 years in the
ocean. However, some sockeye salmon populations spawn in rivers without juvenile lake-
rearing habitat. Their juveniles rear in slow velocity sections of rivers for 1 or 2 years (river-
type) or migrate to sea as underyearlings, and thus rear primarily in salt water. As with lake-type
sockeye salmon, river- and sea-type sockeye salmon return to natal spawning habitat after 1 to 4
years in the ocean (NOAA 2005).

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5.10.4 Population Trends and Risks

After eight hydropower dams on the Columbia and Snake rivers were finished in the 1970s,
Snake River sockeye spawning runs declined dramatically. Human-caused disturbances such as
pollution, habitat loss and degradation, overfishing, and loss of spawning and rearing areas have
combined to harm the natural reproduction of the sockeye salmon (USFWS 2005).

5.11 Snake River Basin Steelhead (Oncorhynchus mykiss)

Snake River Basin steelhead was listed as threatened under the ESA on Jan. 5, 2006 (71 FR 834).
Critical habitat was designated by the USFWS on September 2, 2005 (70 FR 52630).

5.11.1	Range of Species

The present distribution of steelhead extends from Kamchatka in Asia, east to Alaska, and down
to southern California (NOAA 2005), although the historic range of steelhead extended at least
to the Mexico border.

The Snake River Basin steelhead Distinct Population Segment (DPS) is distributed throughout
the Snake River drainage system, including tributaries in southwest Washington, eastern Oregon
and north/central Idaho (NOAA 2005). Snake River steelhead migrate a substantial distance
from the ocean (up to 932 miles) and use high elevation tributaries (typically 3281-6562 feet
above sea level) for spawning and juvenile rearing. Snake River steelhead occupy habitat that is
considerably warmer and drier (on an annual basis) than other steelhead ESUs (NOAA 2005).

5.11.2	Critical Habitat

Critical habitat was designated for steelhead by the USFWS on November 2, 1999. Critical
habitat for the steelhead consists of river reaches of the Columbia, Snake, and Salmon Rivers,
and all tributaries of the Snake and Salmon River presently or historically accessible to Snake
River steelhead (except reaches above impassable natural falls, and Dworshak and Hells Canyon
Dam).

5.11.3	Life History

Steelhead exhibit a complex suite of life history traits. They can be anadromous or freshwater
resident (and under some circumstances, apparently yield offspring of the opposite form). Those
that are anadromous can spend up to seven years in freshwater prior to smoltification, then spend
up to 3 years in salt water prior to first spawning. Species of Oncorhynchus considered in this
document spawn once then die (NOAA 2005).

Two subspecies of steelhead with anadromous life history are recognized in North America.
These are: O. mykiss irideus (the coastal subspecies), which includes coastal populations from
Alaska to California (including the Sacramento River), and 0. mykiss gairdneri (the inland
subspecies), which includes populations from the interior Columbia, Snake, and Fraser rivers
(NOAA 2005).

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Steelhead can be divided into two basic reproductive ecotypes, based on the state of sexual
maturity at the time of river entry and duration of spawning migration. The stream-maturing
type (summer-run steelhead in the Pacific Northwest and northern California) enters freshwater
in a sexually immature condition between May and October and requires several months to
mature and spawn. The ocean-maturing type (winter-run steelhead in the Pacific Northwest and
northern California) enters freshwater between November and April, with well-developed
gonads, and spawns shortly thereafter. Coastal streams are dominated by winter-run steelhead,
whereas inland steelhead of the Columbia and Snake River basins are almost exclusively
summer-run steelhead (NOAA 2005).

Snake River Basin steelhead are summer steelhead, as are most inland steelhead, and comprise
two groups, A- and B-run, based on migration timing, ocean-age, and adult size. Snake River
Basin steelhead enter fresh water from June to October and spawn during the following spring
from March to May. Their eggs incubate in nesting gravel (redds) for up to four months before
hatching as alevins, a larval life stage dependent on food stored in a yolk sac. Snake River Basin
steelhead usually smolt as 2- or 3-year-olds (NOAA 2005).

5.11.4 Population Trends and Risks

Naturally produced fish make up only a small fraction of the total adult run of the Snake River
steelhead ESU. Although several large production hatcheries for steelhead exist throughout this
ESU, relatively few data exist regarding the numbers and relative distribution of hatchery fish
that spawn naturally, or the consequences of such spawnings when they do occur. On a more
positive note, sharp upturns in 2000 and 2001 in adult returns in some populations and evidence
for high smolt-adult survival indicate that populations in this ESU are still capable of responding
to favorable environmental conditions. In spite of the recent increases, however, abundance in
most populations for which there are adequate data are well below interim recovery targets.

Construction of dams beginning at the turn of the century eliminated vast areas of important
habitat once accessible to steelhead. Creation of eight large dams and reservoirs in their
migration corridors, and excessive harvest are the other primary factors contributing to the
salmons decline. Deterioration of their spawning and nursery habitats, predation, water
withdrawal from streams for other uses, and impacts from hatchery fish, are among the other
causes. Impacts of climate change are also considered a significant factor for decline (i.e.
prolonged drought conditions).

5.12 Utah Valvata Snail (Valvata utahensis)

The Utah valvata snail was listed as endangered under the ESA on December 14, 1992. It is
currently listed as endangered throughout its entire range. This species has recently been
proposed for delisting (74 FR 34539).

5.12.1 Range of Species

The Utah valvata snail once was found in the prehistoric lakes and rivers covering parts of
California, Nevada, Idaho, Wyoming and Utah. The 'modern' range extended as far downstream
as Grandview (rm 487). At present this species is only found in a few springs and mainstem

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river sites in Middle Snake River from American Falls Reservoir to the Hagerman Valley. A
few additional sites are located immediately upstream and downstream of Minidoka Dam near
the Eagle Rock damsite (rm 709) and below American Falls Dam downstream to Burley
(USFWS 1995).

5.12.2	Critical Habitat

No critical habitat has been designated for the Utah valvata snail.

5.12.3	Life History

Utah valvata snails occur in flowing water that is cold, clean and well-oxygenated. This species
is found in areas with clean mud bottoms and submerged aquatic vegetation (USFWS 1995). A
rooted aquatic plant, chara, concentrates calcium carbonate and silicon dioxide and is a common
associate of this snail. Utah valvata snails avoid areas with pure gravel boulders or swift current.
This snail is approximately 0.2 inches in height and is about as wide as it is high. It is primarily
a detritivore grazing diatoms and small plant debris found on the mud surface (USFWS 1995).

5.12.4	Population Trends and Risks

The formation of reservoirs, diversions of rivers and other forms of habitat modification have
lead to the deterioration of the Utah valvata snail habitat. In addition, altered natural flow and
pollution has reduced water quality and deteriorated the free-flowing, cold water environments
this species requires.

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SECTION 6.0

IMPACTS ON THREATENED AND ENDANGERED SPECIES

For the action considered in this BE, there are no direct impacts to listed species. Therefore,
approving the issuance of the general NPDES permit for placer miner activities in Idaho would
not change the environmental baseline or directly affect ESA-listed species. However, there may
be indirect effects of issuing the GP.

This BE evaluates the discharges and activities that would be authorized under the general
NPDES permit. The analysis of impacts assumes that the species of interest are exposed to
conditions that may exist if the NPDES permit conditions are met. Potential impacts arising
from violations of permit conditions are not evaluated.

There are three possible determinations of effects under the ESA (USFWS and NMFS 1998).
The determinations and their definitions are:

•	No Effect (NE) - the appropriate conclusion when the action agency determines its proposed
action will not affect listed species or critical habitat.

•	May affect, not likely to adversely affect (NLAA) - the appropriate conclusion when
effects on listed species are expected to be discountable, or insignificant, or completely
beneficial. Beneficial effects are contemporaneous positive effects without any adverse
effects to the species. Insignificant effects relate to the size of the impact and should never
reach the scale where take occurs. Discountable effects are those extremely unlikely to
occur. Based on best judgment, a person would not (1) be able to meaningfully measure,
detect, or evaluate insignificant effects; or (2) expect discountable effects to occur.

•	May affect, likely to adversely affect (LAA) - the appropriate conclusion if any adverse
effect to listed species may occur as a direct or indirect result of the proposed action or its
interrelated or interdependent actions, and the effect is not discountable, insignificant, or
beneficial (see definition of "is not likely to adversely affect"). In the event the overall effect
of the proposed action is beneficial to the listed species, but also is likely to cause any
adverse effects, then the proposed action "is likely to adversely affect" the listed species. An
"is likely to adversely affect" determination requires formal section 7 consultation.

For the purposes of Section 7 of the ESA, any action that is reasonably certain to result in "take"
is likely to adversely impact a proposed or listed species. "Take," as defined as in Section 3(18)
of the ESA, means to "harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or
attempt to engage in any such conduct". The USFWS further defines "harm" as "significantly
impairing behavioral patterns such as breeding, feeding, or sheltering", and "harass" as "actions
that create the likelihood of injury of listed species to such an extent as to significantly disrupt
normal behavior patterns which include, but are not limited to, breeding, feeding or sheltering".
Further, the "incidental take" in Section 10(a)(1)(B) of the ESA means "any taking otherwise
prohibited by Section 9(a)(1)(B) if such taking is incidental to, and not the purpose of, the
carrying out of an otherwise lawful activity". Finally, a "take" may occur only to individuals of
a species, not to a species' habitat or to designated critical habitat. The take prohibition does not
extend to proposed or candidate species.

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6.1 Parameters of Concern

The potential impacts of activities and discharges that would be authorized under the general
NPDES permit on threatened and endangered species are discussed below. The only parameter
of concern under this permit is Total Suspended Solids (TSS).

6.1.1 Dredging Effects on Fish Spawning and Early Life Stages

The following information was compiled from the California Department of Fish and Game
(CDFG) Suction Dredge Permitting Program Literature Review (2009).

6.1.1.1	Impacts on Fish Spawning Habitat

Fish species including Chinook salmon, steelhead and trout utilize small gravel to cobble
substrates for spawning habitat. Salmonids typically dig a redd (nest) and deposit eggs within
the stream sediment where incubation, hatching and emergence take place. Optimum substrate
for embryos is a gravel/cobble mixture with diameter of 0.5-4 inches with less than five percent
fines or particles smaller than 0.3 inch in diameter (Bjornn and Reiser 1979). While optimal
spawning habitat defined by habitat suitability models is typically found in riffles, proximity of
habitat to structural cover (pools, large woody debris, boulder clusters and overhanging
vegetation) and hydrodynamic shear zones provide equally important refuge from predation and
resting zones for energy conservation (Bilski 2008, Wheaton et al. 2004, Merz 2001).

Tailings created by dredges may offer increased availability of spawning gravel by loosening
compacted gravels, which could result in attractive material for spawning (Badali 1988; Harvey
and Lisle 1998). Tailings are often located near riffle crests, preferred locations for the
construction of redds by salmonids as they consist of loose substrate of the appropriate size).
Hassler et al. 1986 indicated that suction dredging increases availability of spawning gravel by
loosening compacted gravels. However, loose substrate found in dredge tailings is often too
unstable and embryos may experience reduced survival due to increased scouring (Thomas 1985;
Harvey and Lisle 1999). A study by Harvey and Lisle (1999) determined that Chinook salmon
redds located on dredge tailings experienced greater scouring than those on natural substrates.
Chinook salmon that spawn in the fall may be affected by constructing redds on dredge tailings,
which could be subject to higher scour than unaltered substrates and could result in compromised
reproductive success (Harvey and Lisle 1998).

Tailing piles from suction dredge mining may become suitable for spawning habitat after the
substrate has been dispersed resulting in more stable habitat (Hassler et al. 1986). Many species
of fish spawn after tailings from dredging during summer and fall have dispersed (Thomas 1985;
Harvey 1986). However, the extent to which fish populations depend on dredge tailings for
spawning habitat likely depends on the availability of suitable unaltered substrate and the quality
of the dredge tailings (Harvey and Lisle 1999).

6.1.1.2	Impacts on Spawning Habitat Resulting in Effects on Eggs and Embryos

In order to produce viable young, salmonids require spawning habitat with loose, uncompacted
gravels with high permeability consisting of unclogged interstices that allow for the removal of

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metabolic wastes (Hausle and Coble 1976). However, Mesick (2009) suggested that material
that is too clean may be detrimental to Chinook eggs because the eggs are not insulated from
agitation or eggs may become dislodged especially in high flow areas. As discussed in the
previous section, suction dredging has the potential to influence the availability of suitable
spawning and incubation habitat for spawning salmonids. Availability of intragravel water flow
(Vaux 1962; Cooper 1965) and dissolved oxygen is critical for the survival of developing
salmonid eggs (Cooper 1965; Daykin 1965). Higher levels of fines or increased organic matter
resulting from suction dredging can reduce flow and oxygen concentrations which can result in
negative effects on eggs and embryos including reduced size of embryos at various
developmental stages, increased development time of alevins, and higher pre- and post-hatching
mortality (Merz et al. 2006; Spence et al. 1996; Brannon 1965; Shumway et al. 1964; Silver et al.
1963). Increased fines in dredging areas can also delay emergence of fry. This may result in
smaller fry that are less able to compete for resources than their larger counterparts (Redding et
al. 1987).

The permit requires that dredging and discharging are prohibited within 500 feet of locations
where fish are spawning or fish eggs or alevins are known to exist at the time dredging occurs.
In addition, suction dredge operations must not occur in gravel bar areas at the tail of pools
where operations result in fine sediment discharging onto gravel bars. Finally the permit
requires avoidance of dredging concentrated silt and clay that would result in a significant
increase in turbidity by moving to a new location or reducing the volume and turbidity of
effluent discharge by limiting operation speed of the suction dredge. These best management
practices outlined in the general permit for Idaho small placer miners should minimize potential
adverse effects to eggs and embryos due to alteration of spawning and incubation habitat.

6.1.1.3 Impacts of Mercury

There is the potential for suction dredge mining to resuspend contaminants such as mercury.
Mercury was used in historic gold mining operations to amalgamate gold mines. Elemental
mercury may be present in stream beds and banks and could be remobilized by suction dredge
operations. Inorganic mercury tends not to be highly bioaccumulated or biomagnified in aquatic
food webs. Inorganic mercury can be methylated by microbes to form methyl mercury, a more
bioavailable form of mercury that due to its bioaccumulation by aquatic organisms is the more
toxic form of mercury. Methylation of mercury generally occurs by microbes that prefer anoxic
or low oxygen conditions.

Since suction dredge mining creates turbidity in the stream it is likely this action increases
oxygenation of the waters and methylation of inorganic mercury would be less likely to occur in
these habitats. Additionally, best management practices in the permit require that if mercury is
found during suction dredge operations, the operator must stop dredging and work with the local
regional office of IDEQ to ensure that the mercury is disposed of properly. Therefore, mercury
should not result in adverse effects to the aquatic organisms downstream of suction dredge
operations.

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6.1.1.4 Egg and Larval Entrainment

Excavation and subsequent displacement of eggs, fry and larvae can occur when they are
suctioned into the equipment and can result in mortality (Harvey and Lisle 1998). Griffith and
Andrews (1981) investigated the effect of suction dredging entrainment on the mortality of
aquatic organisms and found 100% mortality among uneyed eggs and 30% mortality among
eyed eggs in entrained cutthroat trout and 83% mortality for rainbow trout sac-fry. His results
also suggest that once sac-fry "button-up" they are less susceptible to entrainment-related
mortality. Trout greater than four inches (e.g. fingerlings) were able to avoid entrainment for
dredge intake velocities less than 1 ft/sec. Griffith and Andrews (1981) determined that
fingerlings still survive if they are entrained by dredging. Fish have been observed feeding from
the discharge of suction dredges (Lewis 1962). Fish would likely attempt to eat any eggs, larvae
and/or fry that survived entrainment or exposed following dredging. Any eggs or sac-fry that
survive to return to the substrate for cover would likely experience increased predation from
other predators displaced during suction dredging.

The permit requires that dredging and discharging are prohibited within 500 feet of locations
where fish are spawning or fish eggs or alevins are known to exist at the time dredging occurs.
These best management practices outlined in the general permit for Idaho small placer miners
should minimize the potential for entrainment of eggs and embryos to occur.

6.1.2 Effects on Juvenile and Adult Fish

6.1.2.1	Juvenile and Adult Entrainment

Studies show that most juvenile and adult fish are likely to avoid or survive passage through a
suction dredge (North 1993). In a study by Griffith and Andrews (1981) showed that all 36
juvenile and adult rainbow trout and brook trout intentionally entrained by suction dredges in
small Idaho streams survived. Sublethal impacts such as disorientation and infections were not
assessed. However, the permit requires that dredging and discharging are prohibited within 500
feet of location where fish are spawning or fish eggs or alevins are known to exist at the time
dredging occurs. These best management practices outlined in the general permit for Idaho
small placer miners should minimize the potential for entrainment of juvenile and adult listed
fish.

6.1.2.2	Pool Formation/Loss

It is possible that excavations from dredging operations can result in temporarily form pools or
deepen existing pools which may improve fish habitat. Deep scour may intersect subsurface
flow creating pockets of cool water during summer which can provide important habitat for fish
(Nielsen 1994). During times of low flow in a river or stream, increased water depth can provide
a refuge from predation by birds and mammals (Harvey and Stewart 1991). Eight fish occupying
a riffle during late summer in Butte Creek, California, moved into a dredged excavation nearby
(Harvey 1986). In addition, pools created by abandoned dredger sites can provide holding and
resting areas for juvenile and adult salmonids (Stern 1988). On the other hand, sedimentation
from the dredging site can fill in pool habitat downstream of the excavation site. One study
found that the number of rainbow trout in a small pool in Butte Creek, California declined 50%

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when upstream dredging filled in 25% of the pool volume (Harvey 1986). Following one year of
dredging activity on Gold Creek in Missoula County, Montana, all of the gravel at the dredged
area had moved downstream to fill in a downstream pool. Due to the creation of a pool at the
dredged site, there was no net loss of pool habitat in the stream (Thomas 1985). Additionally,
most pools and depositional piles are removed during subsequent winter/spring seasonal flows.

6.1.2.3 Sedimentation

Sediment discharges from suction dredges are sorted based on size, with coarser sediments
settling nearer to the dredge and finer sediments transported further downstream. Turbidity and
suspended sediment levels were measured to be two to three times higher than background levels
at 164 feet downstream from dredging operations (Stern 1988). Suction dredging generally
causes turbidities of between 15 and 50 Nephelometric Turbidity Units (NTU) immediately
downstream of the operation, with background levels returning between 164 and 525 feet
downstream and in some cases as short as 36 feet (Harvey 1986; Somer and Hassler 1992;
Thomas 1985, Griffith and Andrews 1981, Stern 1988, Prussian et al. 1999). The extent of the
turbidity plume can be influenced by the composition of the streambed. Dredging in streams
with higher proportions of fine materials will generate a more extensive turbidity plume (Harvey
et al. 1982, Harvey 1986). Studies have shown that suction dredging can elevate suspended
sediment concentrations up to 300-340 mg/L immediately downstream of the dredge with levels
decreasing to background within 524 feet (Stern 1988, Thomas 1985).

Stern (1988) monitored turbidity and total suspended solids (TSS) at transects upstream and
downstream from dredging sites. At 164 feet below the dredge, turbidity and TSS levels were 2-
3 times higher than the upstream controls while at 328 feet below the dredge, turbidity and TSS
levels approached control values. Thomas (1985) characterized the suspended sediment plume
for suction dredge operations by monitoring TSS downstream from a suction dredge operation.
The study indicated that suspended sediment returned to ambient levels 99 feet from the suction
dredge. This study also determined that the majority of the suspended sediment was re-deposited
within 20-36 feet of the dredge operation site. Prussian et al. (1999) monitored suspended solids
and turbidity resulting from operations using 8-10 inch nozzles in the Fortymile River in eastern
Alaskan River. They found that a relatively narrow turbidity plume (7% of the river width) was
generated by a 10-inch suction dredge nozzle and the suspended solids concentration was
elevated up to 524 feet downstream from the dredge. Harvey et al. (1982) and Harvey (1986)
measured settleable solids and turbidity in three California Rivers from dredging activities. The
settleable solids and turbidity levels reduced to background levels within 100 feet downstream.
The study also noted that substrate type was very influential in determining which particles were
suspended. The disturbance of clay deposits increased turbidity whereas disturbance of sand and
gravel did not increase turbidity. Harvey (1986) found turbidity peaked at 50 NTU 16 feet
downstream from a dredging operation and returned to background levels within 264 feet
downstream. These studies demonstrate that effects of suction dredging on turbidity and
suspended sediment concentrations are limited to the area immediately downstream of the
operation for the duration of the dredging activity.

Sedimentation of habitat downstream from dredging activities can adversely impact the
microhabitats of bottom-oriented stream fish such as juvenile salmon because these fish rely on

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cover that can become embedded during dredging operations (Havey 1986). Hassler et al.
(1986) found that high densities of deposited sediment 33-52 feet below dredging sites markedly
reduced the amount of instream cover for juvenile salmonids due to fine sediment filling gravel
interstices and stream bottom roughness. Suttle et al. (2004) found that juvenile steelhead
growth in the south fork Eel River decreased steeply and almost linearly with increasing fine-
sediment concentration. Steelhead confined to channels with higher levels of sedimentation
experienced lower food availability than those in less embedded channels. At higher levels of
embeddedmess, fine sediments can fill spaces under and between coarse obbles, producing a flat
bed. As interstitial refuges and prey declined, steelhead spent less time sheltering behind or
under cobbles and more time actively swimming.

A number of BMPs are included in the suction dredge permit to minimize these potential
impacts. The permit requires that dredging and discharging are prohibited within 500 feet of
locations where fish are spawning or fish eggs or alevins are known to exist at the time dredging
occurs. In addition, suction dredge operations must not occur in gravel bar areas at the tail of
pools where operations result in fine sediment discharging onto gravel bars. Finally the permit
requires avoidance of dredging concentrated silt and clay that would result in a significant
increase in turbidity by moving to a new location or reducing the volume and turbidity of
effluent discharge by limiting operation speed of the suction dredge. These best management
practices outlined in the general permit for Idaho small placer miners should minimize potential
adverse effects to salmonids due to sedimentation and suspended sediment.

6.1.2.4 Loss of Woody Debris and Large Boulders

Coarse woody debris and large boulders increase flow complexity and water retentionin streams,
and when water flow is backed up due to coarse woody debris, pools may form, which are an
important habitat for many species of fish (Mcintosh et al. 2000). Woody debris is also an
important energy source for benthic invertebrates (Anderson et al. 1978, Bisson et al. 1987).
Benthic invertebrates are an important food source for juvenile salmonids (Mundie 1974).

Woody debris provides cover for adult salmonids (Bjornn and Reiser 1991) and low gradient
sediment deposits upstream of debris accumulation can provide suitable spawning substrate in
sediment-poor drainages (Everest and Meehan 1981). Removal of coarse woody debris or
boulders from a river can have substantial impacts on the stream environment, including
redistribution of sediment and changes in stream topography and changes in size and location of
pools to name a few. These changes in flow can alter the production of benthic invertebrates and
the survival and development of developing fish embryos (Bilski 2008, Merz et al. 2006).

The permit prohibits the use of motorized equipment to move boulders, logs or other natural
obstructions. This should ensure that important habitat for aquatic organisms, which includes
large woody debris or large boulders will not be altered. This BMP will minimize potential
adverse effects to benthic invertebrates and fish from the potential loss or change of habitat due
to movement or elimination of woody debris or boulders.

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6.1.2.5	Behavioral Responses

Observations in a number of studies have shown fish behavioral responses to noises and
vibrations generated by dredging. Feeding behavior can be affected as juvenile salmonids have
been observed feeding on entrained organisms at dredge outfalls (Thomas 1985, Hassler et al.
1986). Temporary dredge piles spanning a substantial portion of the stream width could affect
normal feeding and escapement behavior of fish. Deeper areas or pools created by dredges may
be occupied by fish as habitat once dredging is completed (Harvey and Lisle 1998). Hassler et
al. (1986) observed spring-run Chinook and summer-run steelhead adults holding within 164 feet
of active dredges, but speculated that dredging may have inhibited upstream movement by fish.
Stern (1988) observed that suction dredging did not appear to influence the behavior of adult
spring-run salmonids in their holding habitat.

While there is the potential for behavioral changes due to suction dredging operations, significant
adverse impacts have not been shown from these behavioral changes. Studies have demonstrated
that salmonids remained in their holding habitat when suction dredging occurred near their
habitat. In some instances, behavioral changes from suction dredging operations can be
beneficial to the species, as fish may be able to occupy pools created by suction dredging or may
use the entrained benthic invertebrates in the effluent of the suction dredge operation as a food
source. BMPs included within the permit to limit potential effects on behavior of fish. The
permit requires that dredging and discharging are prohibited within 500 feet of locations where
fish are spawning or fish eggs or alevins are known to exist at the time dredging occurs. Suction
dredges shall not operate within 800 feet of another suction dredging operation occurring
simultaneously or a location where it is apparent that another operation has taken place within
the past month. Limiting the simultaneous operation of suction dredges will minimize the noise
and vibration during suction dredging.

6.1.2.6	Suspended Sediment

High concentrations of suspended sediment can alter survival, growth and behavior of aquatic
species. Indirect effects include reduction of light input and occlusion of gravel interstices for
hiding places and food. Direct effects include abrading or clogging delicate membranes, skin
irritation and abrasions, and facilitation of infections. Suspended sediments can cause direct
damage to gills, reduced growth rates due to limited vision in turbid waters altering the ability to
find prey, lowered growth rate due to reduced instream production of food organisms due to fine
sediment deposition and potentially reduced light penetration, and a reduction in carrying
capacity due to channel morphology changes (Roelofs 1983). Impacts due to suspended
sediment can increase with longer exposure time, smaller sediment particle size, temperature
extremes and higher organic content of the sediment (Newcombe and MacDonald 1991, Servizi
and Martens 1987, Servizi and Martens 1991, McLeay et al. 1987). Elevated suspended
sediment may reduce reactive distance of salmonids to drifting prey (Barrett et al. 1992) and prey
capture success (Berg and Northcote 1985). This effect may be offset by the fact that the
sediment plume may contain entrained invertebrates as a result of dredging.

Growth rates of steelhead and coho salmon in laboratory channels were higher and their
emigration rates lower in clear water than in turbid water (22-286 NTU) after 11-21 days (Sigler

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et al. 1984). Juvenile Chinook salmon spend more time foraging in water of moderate turbidity
(20-25 NTU) than in clearer water (Gregory 1993). Brook trout are also more active and spend
less time near cover in moderately turbid water than in clear water (Gradall and Swenson 1982).
Coho salmon do not avoid turbidities as high as 70 NTU, but move into turbid water when
frightened (Glisson and Bilby 1982). Sigler et al. (1984) analyzed the effect of chronic turbidity
on feeding of 30-65 mm long steelhead and coho salmon. Fish subjected to continuous clay
turbidities grew less well than those living in clear water, and more of them emigrated from
channels during the experiment. For salmon, suspended solids usually cause greater stress for
earlier life stages than for adults. Therefore, increased suspended sediment loads can negatively
impact eh quality and quantity of production if they coincide with the emergence and rearing of
young salmonids (Sigler et al. 1984). While extremely high levels of sediment can be very
harmful or lethal, these concentrations of suspended sediment are probably rarely produced by
small suction dredging and fish can usually avoid these higher concentrations (Harvey 1986).
Thomas (1985) and Harvey (1986) concluded that in streams where dredges operate at low
density, suspended sediment is not a significant concern because effects are highly localized and
readily avoided by mobile organisms.

Suction dredging typically produces turbidities no higher than 50 NTU immediately downstream
of the operation with suspended sediment levels returning to background within 500 feet
downstream of the operation. The State of Idaho has established a WQS for turbidity and it shall
not exceed background turbidity by more than 50 NTU instantaneously or more than 25 NTU for
more than 10 consecutive days. The general permit also requires the following effluent limit for
turbidity in that a visual increase in turbidity above background turbidity 500 feet downstream of
the suction dredge during operations is considered a violation of the permit. BMPs have been
included in the general permit to minimize the potential for turbidity. Suction dredges shall not
operate within 800 feet of another suction dredging operation occurring simultaneously or a
location where it is apparent that another operation has taken place within the past month. The
permit requires that dredging and discharging are prohibited within 500 feet of locations where
fish are spawning or fish eggs or alevins are known to exist at the time dredging occurs. In
addition, suction dredge operations must not occur in gravel bar areas at the tail of pools where
operations result in fine sediment discharging onto gravel bars. Finally the permit requires
avoidance of dredging concentrated silt and clay that would result in a significant increase in
turbidity by moving to a new location or reducing the volume and turbidity of effluent discharge
by limiting operation speed of the suction dredge. Adverse effects to fish general occur at
concentrations of suspended sediment that are higher than those seen during small suction
dredging operations. These best management practices outlined in the general permit for Idaho
small placer miners should minimize potential adverse effects to aquatic species due to
suspended sediment.

6.1.3 Effects to Snail Species

There are not many studies looking at the effects of small suction dredging operations on snail
species. One direct effect to benthic invertebrates by suction dredge operations can be
destruction of the benthic environment in which they reside. In general, benthic invertebrates
rapidly re-colonize small patches of new or disturbed substrate in streams (Mackay 1992).

Griffith and Andrews (1981) studied the effects of a small suction dredge on fishes and

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invertebrates in Idaho streams and found most of the recolonization of dredged plots were
completed by benthic invertebrates after 38 days. In a study of dredging effects in an Alaskan
stream, Royer et al. (1999) found that density of benthic invertebrates was reduced in the first 32
feet downstream of dredging with density returning to upstream composition within 260-520 feet
downstream of the activity. Since most of the snail species discussed in this biological
evaluation prefer habitats on rocks and cobble, they may be adversely impacted with fine
sediment covering these rocks and making grazing on algae more difficult. Snails and benthic
invertebrates may also become entrained during the suction dredge operation. Griffith and
Andrews (1981) found mortality rates of entrained benthic macroinvertebrates varied by species
but were generally low, usually less than one percent of over 3,600 individuals. Again, since the
species of listed snails in this biological evaluation prefer habitats on rocks and cobble, they will
be less likely to become entrained in the suction dredge operations.

BMPs within the permit that will limit potential adverse effects on the listed snail species.

Suction dredge operations must not occur in gravel bar areas at the tail of pools where operations
result in fine sediment discharging onto gravel bars. The permit requires avoidance of dredging
concentrated silt and clay that would result in a significant increase in turbidity by moving to a
new location or reducing the volume and turbidity of effluent discharge by limiting operation
speed of the suction dredge. Suction dredges shall not operate within 800 feet of another suction
dredging operation occurring simultaneously or a location where it is apparent that another
operation has taken place within the past month. Many of the listed snail species covered by this
biological evaluation occur in locations like nature preserves and hot springs which are areas in
which small suction dredging is not allowed or areas where suction dredging is not expected to
occur based on previous permit requests. The above factors should minimize potential effects to
the listed snail species from small suction dredge operations.

6.2 Effects Determination

This section provides impact analysis for the 12 ESA-listed species considered in this BE.

6.2.1	Banbury Springs Lanx

The proposed activities associated with the corresponding permit are not likely to impact the
Banbury springs lanx. Although it may occur in other places, the three areas where it has been
found are protected (TNC Nature Preserves and State Nature Preserves), and suction dredging is
not permitted. Additionally, BMPs within the permit should minimize potential adverse effects
to listed snails. Due to the fact that listed Banbury Spring lanx do not reside in areas used for
dredging and BMPs will minimize sediment effects to the snail habitat, the small placer miner
permit should result in insignificant effects to the listed snails. Therefore, EPA has determined
that the NPDES general permit for Idaho small placer miners may affect, but is not likely to
adversely affect the Banbury Springs Lanx.

6.2.2	Bliss Rapids Snail

Although the Bliss Rapids snail may occur in other places, most areas where the Bliss Rapids
snail has been found are protected (TNC Nature Preserves and State Nature Preserves), and
suction dredging is not permitted. Additionally, BMPs within the permit should minimize

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potential adverse effects to listed snails. Due to the fact that listed Bliss Rapids snails do not
reside in areas used for dredging and BMPs will minimize sediment effects to the snail habitat,
the small placer miner permit should result in insignificant effects to the listed snails).

Therefore, EPA has determined that the NPDES general permit for Idaho small placer miners
may affect, but is not likely to adversely affect the Bliss Rapids snail.

6.2.3	Bruneau Hot Springsnail

The Bruneau hot springsnail is found only in the warm springflows of Hot Creek and 128 small,
flowing thermal springs and seeps along an approximately 5.3 mile length of the Bruneau River
in southwestern Idaho. These spring sites are located primarily above the high-water mark of the
Bruneau River, and therefore, the Burneau hot springsnail would be unlikely to occur in areas
where impacts from suction dredging occurs. Additionally, BMPs within the permit should
minimize potential adverse effects to listed snails. Due to the fact that listed Bruneau hot
springnail do not reside in areas used for dredging and BMPs will minimize sediment effects to
the snail habitat, the small placer miner permit should result in insignificant effects to the listed
snails. Therefore, EPA has determined that the NPDES general permit for Idaho small placer
miners may affect, but is not likely to adversely affect the Bruneau hot springsnail.

6.2.4	Bull Trout

Suction dredges can result in adverse effects to bull trout populations. Bull trout spawn in gravel
areas of streams from September into December and their eggs and fry remain in the gravel
during winter. Incubation of bull trout eggs also occur over a longer period than other species
and their young have an extended period of residency in spawning gravels - 200 days as opposed
to about 60 days for other trout.

Direct effects to trout spawning occur when the spawning gravels themselves are disturbed and
the eggs and fry are either crushed or exposed to predators. Dredging may also adversely affect
fish eggs and fry by disturbing the fine sand and silt in the stream which is carried down stream
and blankets the spawning areas suffocating eggs and fry.

However, due to the potential for adverse effects to spawning as well as eggs and fry, dredging
and discharging are prohibited within 500 ft. of locations where fish are spawning or fish eggs or
alevins are known to exist at the time of dredging. Because the different species of fish spawn at
different times, some streams have fish eggs or fry in the gravel during every month of the year.

Additional BMPs are required for operating recreational suction dredges to prevent damaging
fish populations and were discussed in sections 6.1.1 and 6.1.2. Some of these include:

1.	Do not operate in the gravel bar areas at the tails of pools. This is the area preferred by trout
and salmon for spawning.

2.	Do not operate in such a way that fine sediment from the dredge discharge blankets gravel
bars.

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3. Do not change the stream channel in such a way that the current is directed into the bank
causing erosion or destruction of the natural form of the channel.

The best areas for locating gold which are not likely to affect aquatic life are around boulders
near the upstream end of pools where the current first starts to slow, in seams and pockets in
exposed bedrock and around midstream boulders or on the inside of a river bed at or near the
head of a gravel bar where the larger materials have accumulated.

If the above BMPs and requirements of the permit are followed by small suction dredge mining
operators in permitted waters of Idaho, potential effects for the bull trout should be insignificant.
Therefore, EPA has determined that the NPDES general permit for Idaho small placer miners
may affect, but is not likely to adversely affect the bull trout.

6.2.5 Fall Chinook Salmon

Suction dredges can result in adverse effects to Chinook populations. Salmon spawn in gravel
and cobblestones up to 3-4 inches in diameter. The preferred site is a gravel bar at the tail or side
of pools covered by 6 to 12 inches of smoothly flowing water. Fall Chinook salmon spawn in
October and November. Their eggs and fry remain in the gravel until the following spring.

Direct effects to salmon spawning occur when the spawning gravels themselves are disturbed
and the eggs and fry are either crushed or exposed to predators. Dredging may adversely affect
fish eggs and fry is by disturbing the fine sand and silt in the stream which is carried down
stream and blankets the spawning areas suffocating eggs and fry.

However, due to the potential for adverse effects to spawning as well as eggs and fry, dredging
and discharging are prohibited within 500 ft. of locations where fish are spawning or fish eggs or
alevins are known to exist at the time of dredging. Because the different species of fish spawn at
different times, some streams have fish eggs or fry in the gravel during every month of the year.

Additional BMPs are required for operating recreational suction dredges to prevent damaging
fish populations and were discussed in sections 6.1.1 and 6.1.2. Some of these include:

1.	Do not operate in the gravel bar areas at the tails of pools. This is the area preferred by trout
and salmon for spawning.

2.	Do not operate in such a way that fine sediment from the dredge discharge blankets gravel
bars.

3.	Do not change the stream channel in such a way that the current is directed into the bank
causing erosion or destruction of the natural form of the channel.

The best areas for locating gold which are not likely to effect aquatic life are around boulders
near the upstream end of pools where the current first starts to slow, in seams and pockets in
exposed bedrock and around midstream boulders or on the inside of a river bed at or near the
head of a gravel bar where the larger materials have accumulated.

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If the above BMPs and requirements of the permit are followed by small suction dredge mining
operators in permitted waters of Idaho, this permit should result in insignificant effects for the
fall Chinook salmon. Therefore, EPA has determined that the NPDES general permit for Idaho
small placer miners may affect, but is not likely to adversely affect the fall Chinook salmon.

6.2.6 Spring/Summer Chinook Salmon

Suction dredges can result in adverse effects to spring/summer Chinook populations. Salmon
spawn in gravel areas in Idaho streams in gravel and cobblestones up to 3-4 inches in diameter.
The preferred site is a gravel bar at the tail or side of pools covered by 6 to 12 inches of smoothly
flowing water. Spring/summer Chinook salmon spawn in August and September. Their eggs
and fry remain in the gravel until the following spring.

Direct effects to salmon spawning occur when the spawning gravels themselves are disturbed
and the eggs and fry are either crushed or exposed to predators. Dredging may also adversely
affect fish eggs and fry by disturbing the fine sand and silt in the stream which is carried down
stream and blankets the spawning areas suffocating eggs and fry.

However, due to the potential for adverse effects to spawning as well as eggs and fry, dredging
and discharging are prohibited within 500 ft. of locations where fish are spawning or fish eggs or
alevins are known to exist at the time of dredging. Because the different species of fish spawn at
different times, some streams have fish eggs or fry in the gravel during every month of the year.

Additional BMPs are required for operating recreational suction dredges to prevent damaging
fish populations and were discussed in section 6.1.1 and 6.1.2. Some of these BMPs include:

1.	Do not operate in the gravel bar areas at the tails of pools. This is the area preferred by trout
and salmon for spawning.

2.	Do not operate in such a way that fine sediment from the dredge discharge blankets gravel
bars.

3.	Do not change the stream channel in such a way that the current is directed into the bank
causing erosion or destruction of the natural form of the channel.

The best areas for locating gold which are not likely to effect aquatic life are around boulders
near the upstream end of pools where the current first starts to slow, in seams and pockets in
exposed bedrock and around midstream boulders or on the inside of a river bed at or near the
head of a gravel bar where the larger materials have accumulated.

If the above BMPs and requirements of the permit are followed by small suction dredge mining
operators in permitted waters of Idaho, this permit should result in insignificant effects for the
spring/summer Chinook salmon. Therefore, EPA has determined that the NPDES general permit
for Idaho small placer miners may affect, but is not likely to adversely affect the
spring/summer Chinook salmon.

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6.2.7 Grizzly Bear

The proposed activities do not include removal of any terrestrial habitat, and therefore, all
potential grizzly bear habitat would remain intact, however, human presence may cause localized
displacement of the species. Prey species such as fish and waterfowl may be disturbed and
displaced by suction dredging activities, but the impacts would be localized. Indirect impacts to
prey species may occur if a large amount of suction dredging occurs upstream of habitat areas of
the prey species. However, BMPs should minimize potential impacts to fish species that may be
prey for grizzly bears.

If the above BMPs and requirements of the permit are followed by small suction dredge mining
operators in permitted waters of Idaho, this permit should result in insignificant effects for the
grizzly bear. Therefore, EPA has determined that the NPDES general permit for Idaho small
placer miners may affect, but is not likely to adversely affect the grizzly bear.

6.2.8	Kootenai River White Sturgeon

The Kootenai River White Sturgeon is restricted to approximately 168 RM of the Kootenai River
with critical habitat in Boundary County, Idaho. The proposed activities associated with the
corresponding permit are not likely to impact the Kootenai River white sturgeon. The white
sturgeon usually broadcast their eggs in the spring over clean cobble at depths greater than 20ft.
Areas with these depths would not be used by small scale suction dredge placer mining.
Additionally, the Kootenai River is only open to small placer miners from July 15 to August 15,
which is several months past spawning season. Dredging and discharge are also prohibited
within 500 ft. of where fish are spawning or fish eggs or alevins are known to exist at the time of
dredging.

Due to the fact that the Kootenai River is closed during the spring when sturgeon spawn and
BMP prohibit dredging within 500 ft. of alevins that are known to be present, this permit should
result in insignificant effects for the Kootenai River White Sturgeon. Therefore, EPA has
determined that the NPDES general permit for Idaho small placer miners may affect, but is not
likely to adversely affect the Kootenai River White Sturgeon.

6.2.9	Snake River Physa Snail

The proposed activities associated with the corresponding permit are not likely to impact the
Snake River physa snail, although only two populations are believed to remain in the Hagerman
and King Hill reaches of the Snake River, with potentially a third colony located immediately
downstream of Minidoka Dam. Indirect impacts may occur if a large amount of suction
dredging occurs upstream of these areas, and/or BMPs are not followed, causing excess sediment
to float and settle downstream (Harvey and Lisle 1998).

If the above BMPs and requirements of the permit are followed by small suction dredge mining
operators in permitted waters of Idaho, this permit should minimize potential adverse effects
from sedimentation and result in insignificant effects for the Snake River physa snail. Therefore,
EPA has determined that the NPDES general permit for Idaho small placer miners may affect,
but is not likely to adversely affect the Snake River physa snail.

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6.2.10	Sockeye Salmon

Suction dredges can result in adverse effects to sockeye salmon populations. Salmon spawn in
gravel areas in Idaho streams in gravel and cobblestones up to 3-4 inches in diameter. The
preferred site is a gravel bar at the tail or side of pools covered by 6 to 12 inches of smoothly
flowing water. Sockeye salmon spawn in late summer and autumn. Their eggs and fry remain in
the gravel until the following spring.

Direct effects to salmon spawning occur when the spawning gravels themselves are disturbed
and the eggs and fry are either crushed or exposed to predators. Dredging can also adversely
affect fish eggs and fry by disturbing the fine sand and silt in the stream which is carried down
stream and blankets the spawning areas suffocating eggs and fry.

However, due to the potential for adverse effects to spawning as well as eggs and fry, dredging
and discharging are prohibited within 500 ft. of locations where fish are spawning or fish eggs or
alevins are known to exist at the time of dredging. Because the different species of fish spawn at
different times, some streams have fish eggs or fry in the gravel during every month of the year.

Additional BMPs are required for operating recreational suction dredges to prevent damaging
fish populations and were discussed in sections 6.1.1 and 6.1.2. Some of the BMPs include:

1.	Do not operate in the gravel bar areas at the tails of pools. This is the area preferred by trout
and salmon for spawning.

2.	Do not operate in such a way that fine sediment from the dredge discharge blankets gravel
bars.

3.	Do not change the stream channel in such a way that the current is directed into the bank
causing erosion or destruction of the natural form of the channel.

The best areas for locating gold which are not likely to effect aquatic life are around boulders
near the upstream end of pools where the current first starts to slow, in seams and pockets in
exposed bedrock and around midstream boulders or on the inside of a river bed at or near the
head of a gravel bar where the larger materials have accumulated.

If the above BMPs and requirements of the permit are followed by small suction dredge mining
operators in permitted waters of Idaho, this permit should result in insignificant effects for the
sockeye salmon. Therefore, EPA has determined that the NPDES general permit for Idaho small
placer miners may affect, but is not likely to adversely affect the sockeye salmon.

6.2.11	Steelhead

Suction dredges can result in adverse effects to steelhead populations. Salmon spawn in gravel
areas in Idaho streams in gravel and cobblestones up to 3-4 inches in diameter. The preferred
site is a gravel bar at the tail or side of pools covered by 6 to 12 inches of smoothly flowing
water. Snake River steelhead spawn in March through May. Their eggs incubate in nesting
gravel (redds) for up to four months before hatching as alevins.

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Direct effects to steelhead spawning occur when the spawning gravels themselves are disturbed
and the eggs and fry are either crushed or exposed to predators. Dredging may also adversely
affect fish eggs and fry is by disturbing the fine sand and silt in the stream which is carried down
stream and blankets the spawning areas suffocating eggs and fry.

However, due to the potential for adverse effects to spawning as well as eggs and fry, dredging
and discharging are prohibited within 500 ft. of locations where fish are spawning or fish eggs or
alevins are known to exist at the time of dredging. Because the different species of fish spawn at
different times, some streams have fish eggs or fry in the gravel during every month of the year.

Additional BMPs are required for operating recreational suction dredges to prevent damaging
fish populations and were discussed in sections 6.1.1 and 6.1.2. Some of the BMPs include:

1.	Do not operate in the gravel bar areas at the tails of pools. This is the area preferred by trout
and salmon for spawning.

2.	Do not operate in such a way that fine sediment from the dredge discharge blankets gravel
bars.

3.	Do not change the stream channel in such a way that the current is directed into the bank
causing erosion or destruction of the natural form of the channel.

The best areas for locating gold which are not likely to effect aquatic life are around boulders
near the upstream end of pools where the current first starts to slow, in seams and pockets in
exposed bedrock and around midstream boulders or on the inside of a river bed at or near the
head of a gravel bar where the larger materials have accumulated.

If the above BMPs and requirements of the permit are followed by small suction dredge mining
operators in permitted waters of Idaho, this permit should result in insignificant effects for
steelhead. Therefore, EPA has determined that the NPDES general permit for Idaho small placer
miners may affect, but is not likely to adversely affect the steelhead salmon.

6.2.12 Utah Valvata Snail

Utah valvata snails are found in areas with clean mud bottoms and submerged aquatic
vegetation, and avoid areas with pure gravel boulders, and therefore, would not be found in areas
typically mined by suction dredging. Additionally, BMPs within the permit should minimize
potential adverse effects to listed snails. Due to the fact that listed Utah valvata snails do not
reside in areas used for dredging and BMPs will minimize sediment effects to the snail habitat,
the small placer miner permit should result in insignificant effects to the listed snails. Therefore,
EPA has determined that the NPDES general permit for Idaho small placer miners may affect,
but is not likely to adversely affect the Utah valvata snail.

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6.3 Cumulative Impacts

Cumulative impacts include the effects of future state, tribal, local, or private actions on ESA
listed species or their critical habitat that are reasonably certain to occur in the action area
considered in this BE.

Sport fishing and hunting, timber harvesting and restoration, mining and reclamation,
agriculture, recreation and tourism, and public works projects, are all activities that take place
throughout Idaho. Results of these activities include channelization, excess sedimentation, and
bank instability in rivers and streams.

Along with these activities, the cumulative impacts analysis considers the small scale suction
dredge placer mining that could occur during the next 5 years.

Fine sediment and turbidity increase temporarily immediately downstream of active dredges. In
those areas where small amounts of fine sediment are being worked and stream flows are high,
only small increases in turbidity would be detectable and the effects would be small and of short
duration. If large amounts of fine sediments are encountered and stream flows are low or
moderate, detectable increases in turbidity could occur at the site and could extend a hundred feet
or more downstream. In areas of concentrated suction dredging, the amount of fine sediment
deposition would be cumulative.

Cumulative impacts could occur from fuel, oil, and grease being spilled into the creeks and
affecting aquatic resources. However, these products would be stored in areas and used in ways
that minimize the opportunity for accidental spillage into the stream. Several conditions with
which operators must comply should prevent any such impacts.

6.4 Interdependent /Interrelated Actions

Interdependent actions are defined as actions with no independent use apart from the proposed
action. Interrelated actions are those that are a part of a larger action and depend upon the larger
action for justification.

EPA is proposing to issue a general NPDES permit for small scale suction dredge placer mining
in Idaho. The draft GP sets conditions on the discharge - or release - of pollutants for these
operations. The permit places limits on the types and amount of pollutants that can be
discharged to ensure the protection of water quality and human health. The ESA regulations
require any action agency to evaluate all interdependent actions (actions having no independent
utility apart from the proposed action) and interrelated actions (actions that are part of a larger
action and depend on the larger action for their justification). The federal regulations at 50 CFR
section 402.02 define an action as all activities or programs of any kind authorized, funded, or
carried out, in whole or in part, by federal agencies in the United States or upon the high seas.
Because this is an existing activity that EPA is proposing to authorize in a general permit and
there are no other federal actions associated with this activity, EPA believes that there are no
interdependent or interrelated actions to this action.

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SECTION 7 CONSERVATION MEASURES

7.1 Best Management Practices

BMPs are measures that are intended to prevent or minimize the generation and the potential for
the release of pollutants from industrial facilities to the waters of the United States through
normal operations and ancillary activities. Pursuant to Section 402(a)(1) of the Clean Water Act,
development and implementation of BMP Plans may be included as a condition in NPDES
permits. Section 402(a)(1) authorizes EPA to include miscellaneous requirements that are
deemed necessary to carry out the provision of the Act in permits on a case-by case basis .

BMPs are required to control or abate the discharge of pollutants in accordance with 40 CFR §
122.44(k). The draft GP requires compliance with the following BMPs:

A. Dredging of concentrated silt and clay should be avoided.

The permittee shall use reasonable care to avoid dredging silt and clay materials that
would result in a significant increase in turbidity. Reasonable care includes moving the
dredge to a new location or reducing the volume of effluent discharge by limiting
operation speed of the suction dredge.

This practice will decrease the amount of fine material that will be released into the
water that could cause turbidity plumes in excess of the permitted distance.

B.	If mercury is found during suction dredge operation, (i.e. mercury is collected in the sluice
box), the operator must:

1)	Stop dredging immediately;

2)	Contact the local regional office of IDEQ (see page 3 for contact information);

3)	Keep the mercury collected, do not remobilize the collected mercury; and

4)	Work with the appropriate regional office of IDEQ to dispose of the mercury properly.

Mercury was used in historic placer mining operations to amalgamate gold fines.
Elemental mercury may be present in stream beds and banks and if remobilized
can result in impacts to fish and other aquatic life. Placer miners encountering
mercury should take above steps to prevent mercury from reentering the water
body.

C.	Suction dredges shall not operate within 800 feet of:

1)	another suction dredging operation occurring simultaneously or,

2)	a location where it is apparent that another operation has taken place within the past
month

Biological Evaluation	Small Suction Dredge Placer Mining in Idaho

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This practice should ensure that the mixing zone of a facility does not overlap
with that of another since 800 feet is the distance of a 500 foot mixing zone for
each operation plus a designated 300 foot buffer before the next suction dredge
would impact water quality.

D.	Dredging and discharging are prohibited within 500 feet of locations where:

1)	fish are spawning or

2)	fish eggs or alevins are known to exist at the time dredging occurs

In addition: Suction dredge operation must not occur in gravel bar areas at the tail
of pools or where operations result in fine sediments discharging onto gravel bars.

This BMP is designed to minimize impacts to fish spawning and spawning habitat.

E.	Suction dredge operation must not change the stream channel way that directs the flow of
water into a stream bank, which may cause bank erosion or destruction of the natural form of the
stream channel.

Under Section 101 of the Clean Water Act, EPA is required to restore and maintain the
chemical, physical and biological integrity of waters of the United States. Protection of
the physical integrity of waterbodies includes protection of habitat

F.	Suction dredge operation that results in undercutting, littoral channeling, stream bank or beach
erosion, is prohibited.

This practice will ensure that erosion does not occur and that the finer sediments that
may be found in these areas do not cause turbidity problems in the receiving waters.

G.	Damming or diversions within a stream channel are not authorized by this GP.

EPA cannot authorize dams or diversions under Section 402 of the CWA. These are
generally authorized under Section 404 of the CWA which is administered by the U.S.
Army Corps of Engineers.

H.	Explosives, motorized winches or other motorized equipment to move boulders, logs, or other
natural obstructions are prohibited under this GP.

This practice should ensure that important habitat which includes large organic debris
and large boulders in these areas will not be destroyed.

I.	Wheeled or tracked equipment used in-stream is prohibited while dredging is in progress.

This practice should minimize turbidity from sources other than the suction dredge.
J. Care shall be taken by the operator during refueling of equipment to prevent spillage.

Biological Evaluation	Small Suction Dredge Placer Mining in Idaho

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Any spills shall be cleaned up using materials such as sorbent pads and booms.

All spills shall be reported immediately or as soon as practical to IDEQ and the National
Response Center at 1-800-424-8802.

All chemical or petroleum products shall be stored in a safe and secure location at all
times. Fuel not stored and dispensed with an ANSO or UL approved safety container
must be maintained not less than 100 feet from the mean high water mark.

This practice will decrease the potential for contamination of surface water by petroleum
products.

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Small Suction Dredge Placer Mining in Idaho

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Badali, P. 1988. More Pertinent Information for Suction Dredge Mining. State of Idaho
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General Permit

67


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Acipenseridae. Cooperative Extension, University of California, Division of Agriculture and
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Everest, F.H., and W.R. Meehan. 1981. Forest Management and Anadromous Fish Habitat

Productivity. In Transactions of the 46th North American Wildlife and Natural Resources
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Frest, T.J. and E.J. Johannes. 1992. Distribution and Ecology of the Endemic Relict Mollusc
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Gradall, K. S., and W. A. Swenson. 1982. Responses of brook trout and creek chub to turbidity.
Trans. Am. Fish. Soc._l 11:392-395.

Green D.M., Kaiser H., Sharbel T.F.,Kearsley J. & McAllister K.R. 1997. Cryptic species of
Spotted Frogs, Ranapretiosa complex, in western North America. Copeia 1997(1): 1-8.

Gregory, R. S. 1993. Effect of turbidity on the predator avoidance behavior of juvenile chinook
salmon (Oncorhynchus tshawytscha). Can. J. Fish. Aquat. Sci._50:241-246.

Griffith, J.S. and D.A. Andrews. 1981. Effects of a Small Suction Dredge on Fishes and Aquatic
Invertebrates in Idaho Streams._North American Journal of Fisheries Management. 1(1):
21-28.

Harvey, B. C. 1986. Effects of suction gold dredging on fish and invertebrates in two
California streams. N. Am. J. Fish. Manage. 6:401-409.

Harvey, B. C. and T. E. Lisle. 1998. Effects of suction dredging on streams: a review and an
evaluation strategy. Fisheries. 23(8):8-17.

Harvey, B. C. and T. E. Lisle. 1999. Scour of Chinook Salmon Redds on Suction Dredge
Tailings. N. Am. J. Fish. Manage. 19: 613-617.

Biological Evaluation	Small Suction Dredge Placer Mining in Idaho

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Harvey, B. C., and A. J. Stewart. 1991. Fish size and habitat depth relationships in headwater
streams. Oecologia. 87:336-342.

Harvey, B. C., K. McCleneghan, J. D. Linn, and C. L. Langley. 1982. Some physical and
biological effects of suction dredge mining. California Department of Fish and Game,
Environmental Services Branch, Laboratory Report No. 823. 20 pp.

Hassler, T J., W. L. Somer, and G. R. Stern. 1986. Impacts of suction dredge mining on
anadromous fish, invertebrates, and habitat in Canyon Creek, California. California
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Hausle, D. A., and D. W. Coble. 1976. Influence of sand in redds on survival and emergence of
brook trout (Salvelinus fontinalis). Transactions of the American Fisheries Society 105:57-
63.

Hershler, R. 1994. A review of the North American freshwater snail genus Pyrgulopsis
(Hydrobiidae). Smithsonian Contributions to Zoology 554: 1-119.

Lewis, R. H. 1962. Results of gold suction dredge investigation. Memorandum of September 17,
1962. California Department of Fish and Game. Sacramento, California, 7 pp.

Lysne, S.J. 2003. The life history and ecology of two endangered Snake River gastropods: Utah
valvata (Valvata utahensis; Call) and Idaho springsnail {Pyrgulopsis idahoensis: Pilsbry).
M.S. Thesis, Boise State University, Boise, Idaho. 103 pp.

Mcintosh, B.A., Sedell, J.R., Thurow, R.F., Clarke, S.E., and Chandler, G.L. 2000. Historical
changes in pool habitats in the Columbia River basin. Ecol. Appl. 10: 1478-1496.

McLeay, D. J., I. K. Birtwell, G. E Hartman, and G. L. Ennis. 1987. Responses of arctic grayling
(Thymallus arcticus) to acute and prolonged exposure to Yukon placer mining sediment.
Can. J. Fish. Aquat. Sci. 44:658-673.

Merz, J. E., G. B. Pasternack, and J. M. Wheaton. 2006. Sediment budget for salmonid spawning
habitat rehabilitation in a regulated river, Geomorphology 76(1-2), 207-228.

Merz, J.E. 2001. Association of fall run chinook salmon redds with woody debris in the lower
Mokelumne River, California. California Fish and Game. 87(2): 51-60.

Mesick, C. 2009. 2004 and 2005 Phase II Studies. Knights Ferry Gravel Replenishment Project.
Produced for the Anadromous Fish Restoration Program, U.S. Fish and WildlifeService,
Stockton Fishery Resource Office, 4001 N. Wilson Way Stockton, California 95205. 43

pp.

Biological Evaluation	Small Suction Dredge Placer Mining in Idaho

General Permit

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Mladenka, G.C. 1992. The ecological life history of the Bruneau Hot Springs Snail (Pyrgulopsis
bruneauensis). Stream Ecology Center, Department of Biological Sciences, Idaho State
University, Pocatello, Idaho. Final Report to the U.S. Fish & Wildlife Service, Boise Field
Office. 116 pp.

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Newcombe, C. P, and D. D. MacDonald. 1991. Effects of suspended sediments on aquatic
ecosystems. N. Am. J. Fish. Manage. 11:72-82.

Nielsen, J. L., T. E. Lisle, and V Ozaki. 1994. Thermally stratified pools and their use by
steelhead in northern California streams. Trans. Am. Fish. Soc. 123:613-626.

North, A. P. 1993. A Review of the regulations and literature regarding the environmental
impacts of suction gold dredges. U.S. Environmental Protection Agency, Region 10,
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Paragamian, V.I., G. Kruse, and V. Wakkinen. 1997. Kootenai River White Sturgeon

Investigations. Annual Progress Report FY 1996. Prepared for U.S. Department of
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PFMC (Pacific Fishery Management Council). 1998. Groundfish Fisheries Management Plan.
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Pacific Fishery Management Council. 1998. The Coastal Pelagic Species Fishery Management
Plan. Portland, OR.

Pacific Fishery Management Council. 1999. Salmon Fishery Management Plan, Amendment
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Prussian, A., T. Royer, and W. Minshall. 1999. Impact of suction dredging on water quality,

benthic habitat, and biota in the Fortymile River, Resurrection Creek, and Chatanika River,
Alaska. Prepared for the U.S. Environmental Protection Agency.

Redding, J. M., C. B. Schreck, and EH. Everest. 1987. Physiological effects on coho salmon_and
steelhead of exposure to suspended sediment. Trans. Am. Fish. Soc. 116: 737-744.

Robinson, C.T., G.W. Minshall, and K. Sant. 1992. Bruneau Hot Springs Snail. Annual
Monitoring Report to Bureau of Land Management. 17 pp.

Royer, T., A. Prussian, G.W. Minshall. 1999. Impact of suction dredging on water quality,
benthic habitat, and biota in the Fortymile River and Resurrection Creek, Alaska. Final.
April.

Biological Evaluation	Small Suction Dredge Placer Mining in Idaho

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Servizi, J. A., and D. W. Martens. 1987. Some effects of suspended Fraser River sediments on
sockeye salmon (Oncorhynchus nerka). Pages 254-264 in H. D. Smith, L. Margolis and C.
C. Wood, eds. Sockeye salmon population biology and future management. Canadian
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Servizi, J. A., and D. W. Martens. 1991. Effect of temperature, season, and fish size on acute
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Sigler, J. W., T C. Bjornn, and E H. Everest. 1984. Effects of chronic turbidity on density and
growth of steelheads and coho salmon. Trans. Am. Fish. Soc._113:142-150.

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steelhead trout and Chinook salmon embryos at different water velocities. Transactions of
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Somer, W. L., and T. J. Hassler. 1992. Effects of suction dredge gold mining on benthic
invertebrates in a northern California stream. N. Am. J. Fish. Manage._12:244-252.

Spence, et al. 1996. An Ecosystem Approach to Salmonid Conservation. TR-4501-96-6057.

Stern, G. R. 1988. Effects of suction dredge mining on anadromous salmonid habitat in Canyon
Creek, Trinity County, California. M.S. Thesis, Humboldt State University, Areata,
California, 80 pp.

Suttle, K., M.E. Power, J.M. Levine, and C. McNeely. 2004. How fine sediment in river beds
impairs growth and survival of juvenile salmonids. Ecological Applications. 14(4): 969-74.

Thomas, V G. 1985. Experimentally determined impacts of a small, suction gold dredge on a
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(Acipenser transmontanus): Kootenai River Population. U.S. Fish and Wildlife Service,
Portland, Oregon. 96 pp. plus appendices.

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Threatened Species: Final Listing Determinations for 16 ESUs of West Coast Salmon, and
Final 4(d) Protective Regulations for Threatened Salmonid ESUs. June 28, 2005.

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USFWS (U.S. Fish and Wildlife Service). 2005b. 50 CFRPart 17, Endangered and Threatened
Wildlife Plants; Designation of Critical Habitat for the Bull Trout; Final Rule. September
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spawning habitat rehabilitation Design. Fifth International Symposium on Ecohydraulics.
Aquatic Habitats: Analysis & Restoration. Madrid, Spain.

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Appendix A: List of Potential Permittees

WatebID

StatelDNumber

Waterbody

SpecificLocation

OperatingSeason

330

1705

All Area

All Areas that Have Clamis of GPAA When open for Mining

1/1 -12/31/08

817

2006

All Lawfull Locations

All Lawfull Locations

1MM

816

2005

All Listed

All Lawful Locations

1MM

476

1729

All Open

All Open Streams in Idaho

Open to Closed

473

1732

All Open

All Open Streams in Idaho

Open to Closed

475

1730

All Open

All Open Streams in Idaho

Open to Closed

474

1731

All Open

All Stream Open in Idaho

Open to Closed

55

1567

All Open Waters

Idaho

All Year Around

668

1883

All Open Waters

All Open Waters



71

1566

All Open Waters

All Open water in State of Idaho

All Open dates Year Round

591

1853

All Open Waters of State

All Open Waters of State

Summer 2008

470

1738

American River/ Red
River, Confluence of

PI 359 Power Site Withdrawal; Confluence of American River/
Red River South of Fork Section 33 350 ft from confl.

7/25-8/15

657

1895

Atlanta

Not Reported

Jun - Nov

814

2003

Atlanta

2 Miles West of Atlanta Middle Fork Boise River

Jul 1 - Sept 30

351

1653

Bear Cr

150' from Mouth of Bear Creek

5/08 - 9/08

990

2016

Bear Gulch Cr

Upstream on Prichard Crto Bear Gulch left 1 Mile to Claim

8/20-10/20

736

1905

Beaver Cr

Trail Cr, Potosi Arm of Cr above Delta

Jan 1 - Dec 31

33

1635

Beaver Cr

Various locations below Delta



751

1843

Beaver Cr

Above Delta on Unclaimed Area

Jul 15

569

1767

Beaver Cr

FSR #933

Ditto

563

1788

Beaver Cr

Bedrock Gulch Club Claims

Summer/Fall

73

1529

Beaver Cr & Tribs

Not Reported

Entire Year

24

1660

Bednock Gulch

NWGPA Claim, Prichard Cr & Tribs

Apr 11, 2008-Mar 31, 2009

176

1679

Bepuer Cr?

On various claims owned by Friba 5?(illegible)

May to Jul

347

1686

Black Warrior Cr

Not Reported

7/5 - 8/30

421

1771

Blackfoot River

T35 to Trail Cr Bridge

Jul to Oct


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1955

1796

2072

1783

1666

1666

" 2011

1847

1815

2048

2009

1846

1829

1605

1688

2008

1864

2028

1976

1815

1972

1602

1704

1886

1494

2012

1881

2027

" 2061

Blackfoot River

Graves Cr Crossroad Area

Boise Basin

Boise Basin

Boise Basin

Grimes Creek, Mores Creek, Other Idaho City, South of
Centerville, Placeville

Boise Basin

Not Reported

Boise Drainage

Grimes Creek

Boise Drainage

Middle Fork Boise River

Boise R Drainage

Not Reported

Boise River

East to GPAA Claims

Boise River

Grimes Creek

Boise River

North Fk Where Open Unknown

Boise River

Grimes Cr & Tribs

Boise River

East to GPAA Claims

Boise River

Below Highway Bridge

Boise River

Below Star

Boise River

Idaho City

Boise River

M Fk of Boise River, Mile Marker 28

Boise River

Just below Cenntenial Park or Just below Notice Bridge

Boise River

Below Star Bridge

Boise River

Near Confluence with Snake? Lower End

Boise River

Middle Fork

Boise River

Sourth of Bridge

Boise River

Stream Bed Boise River Drainage

Boise River

South Fork Boise River Pine

Boise River

Drainage - Center

Boise River

Below Star Hway Bridge

Boise River

Not Reported

Boise River

Grimes Creek

Boise River

Below Star Bridge

Boise River

Barber Park Area


-------
978

2059

Boise River

Barber Park Area

9/14/08-12/31/08

1012

2079

Boise River

Below Star Bridge

1/1 to 12/31

974

2060

Boise River

Barber Park Area

9/4/08-12/31/08

806

1996

Boise River

(illegible) Cr

Jul 24 - Oct 30

195

1521

Boise River

South Fork Boise River Pine

Jan 1 to Dec 31

531

1808

Boise River

South of Bridge

5/28-12/31/08

834

1949

Boise River

Black Warrior Creek, Mile Marker 67, 12 Miles South of Atlanta

Jul 1 - Sept 30

836

1950

Boise River

Black Warrior Creek. Mile Marker 67, 12 Miles below Atlanta, ID,
South Side of Boise River

Jul 1 - Sept 30, 2008

534

1806

Boise River

Below Star Bridge

5/2/-12/31/08

123

1588

Boise River & Trib

MP 126 & Eagle Creek

Jul 1 to Sept 30

357

1757

Boise River Basin & Tribs

Lsland Claim and Other Club Claims

Summer - Fall, 2008

356

1757

Boise River Basin & Tribs

Lsland Claim and Other Club Claims

Summer - Fall, 2008

354

1758

Boise River Basin & Tribs

Idaho Claim & Other Club Claims

Summer - Fall, 2008

353

1758

Boise River Basin & Tribs

Idaho Claim & Other Club Claims

Summer - Fall, 2008

328

1705

Boise River below Stream

At Parma Area at DOE Millerhouse; T2N R10E SEC 8

1/1 - 12/31/08

624

1831

Boise River Drainage

Mores Cr - Idaho City

Last Week July, 2008

320

1711

Boise River Drainage

Grimes Creek & Tribs

Jun 15 - Oct 15

323

1710

Boise River Drainage

Grimes Creek & Tribs

Jun 15 - Oct 15

856

1985

Boise River Drainage

Grimes Cr & Tribs

Jan 1 - Dec 31

326

1709

Boise River Drainage

Grimes Creek & Tribs

Jun 15 - Oct 15

325

1709

Boise River Drainage

Middle Fork Boise River

Jul 1 - Sept 30

155

1662

Boise River Drainage

All open area. Grimes Creek, Centervill

Jan 1 to Dec 31

874

1975

Boise River Drainage

Boise River Drainage

When Open, Mid July -
December

322

1710

Boise River Drainage

Middle Fork Boise River

Jul 1 - Sept 30

857

1985

Boise River Drainage

Granite Cr

Jul 1 - Sept 30


-------
1711

1509

1831

1831

1818

1770

1781

1661

1663

1782

1985

1791

2040

1554

1515

1866

1568

1966

1581

1513

1644

1721

1498

2009

1922

1923

Boise River Drainage

Middle Fork Boise River

Boise River Drainage

North Fork of Boise River

Boise River Drainage

Middle Fk below Mt.Lantic?

Boise River Drainage

Grimes Cr - 2 Miles off Hwy 95

Boise River Drainage

All Rivers, Creeks' Tribs Open to Recreational Dredge

Boise River Drainage

1 Mile from Pioneerville (Same Location)

Boise River Drainage

Grimes Creek, Miss Lucy, Grimes Creek MDU, Paymaster
Goldern Rule, China Wine, Idaho Gold Prospectors Association
Claims

Boise River Drainage

All open area. Grimes Creek Centervill

Boise River Drainage

All open area. Grimes Cr, Centervill

Boise River Drainage

Grimes Creek, Miss Luicy, Grimes Creek MDU, Paymaster
Goldern Rule, China Wine, Idaho Gold Prospectors Association
Claims

Boise River Drainage

Bridge up Stream to Baker Gulch

Boise River Drainage

Middle Fork Boise River/ Grimes Creek

Boise River

M Fk

Above Ko???? River below North Fk Boise

Boise River

M Fk

3 Miles South of Atlanta

Boise River

M Fk

Below Queens River Campground

Boise River

M Fk

Various Claims & Own Personal Claims

Boise River

M Fk

Below Confluence of Queen River

Boise River

M Fk

6 Mi South of Atlanta

Boise River

M Fk

On my claim. ANY LEGAL WATER

Boise River

M Fk

Between Dutch Creek Ranger Station and Roaming River. T5N
R9E, Don Lookn? Claim	

Boise River

M Fk

Private Claims

Boise River

M Fk

Below Atlanta

Boise River

M Fk

SE Corner S34 T6N R9E 5200 ft SW

Boise River

M Fk

M Fk Mouth thru T5N R8E

Boise River

M Fk

Main Stream Channel & Gravel Bars

Boise River

M Fk

Main Stream Channel & Gravel Bars


-------
1570

1574

1921

1535

1925

1726

1943

1965

1553

1947

1550

1909

1987

1984

1516

1665

1551

1552

1668

" 2062

1907

2034

2035

1908

2041

2043

1689

1833

1720

2064

Boise River, M Fk

Boise gold GPAA Claim Middle Fork Boise River

2nd Week July & 1st Week
August	

Boise River

M Fk

South Side of River

7/1 - 9/30

Boise River

M Fk

J&R 1,J&R2

Jul 1 - Sep 30

Boise River

M Fk

Boise Gold Claim (Appox2 Mi Dwon River from Queens River
Camp Ground)	

3 das in July & 1 Wk in Aug.

Boise River

M Fk

Arrow Rock - Atlanta ID

Jul 1 - Sept 30

Boise River

M Fk

Weatherbee Landstrip

Aug 1 -Sept 31

Boise River

M Fk

8 Miles West of Atlanta

Jul 11. 2008

Boise River

M Fk

6 Mi South of Atlanta, Idaho

Jul 1 - Sept 30

Boise River

M Fk

3 Mile South of Atlanta

7/1/08-10/1/08

Boise River

M Fk

Not Reported

Jul 4 - Sept 30, 2008

Boise River

M Fk

Below Queens River Camp Ground

Jul 1 to Sept 3

Boise River

M Fk

Private Claim below Atlanta

Aug 08

Boise River

M Fk

Not Reported

Jul 1 - Sept 30

Boise River

M Fk

Arrow Rock T6N R10E SEC 27 BM

Jul 1 - Sept 30, 2008

Boise River

M Fk

Below Queens River Campground

Jul 1 - Sept 30

Boise River

M Fk

GPS 43*49'25.1"N (West End at Road) 115*15'28.7"W

7/1 - 8/20

Boise River

M Fk

Boise Gold Claim. Just for Fun Claims

July - Sept

Boise River

M Fk

Boise Gold Claim, Just for Fun Claims

July - Sept

Boise River

M Fk

Atlanta GPAA Claim

Jul - Sept

Boise River

M Fk

Claim J & R #2 Area 8 Pinnfifirvillfi

Sept 11 - Dec 30

Boise River

M Fk

Below Confluence of Queen

July, Aug & Sept

Boise River

M Fk

Granite Cr (Atlanta)

Jul 1 - Sept 3

Boise River

M Fk

Granite Cr (Atlanta)

Jul 1 - Sept 1

Boise River

M Fk

Below Confluence of Queen

July, Aug & Sept

Boise River

M Fk

Boise Gold Claim T6N R10E SEC 27BM Boise N.F.

Unknown Jul - Sept

Boise River

M Fk

Mile below & above Phifer Cr/ MP 20 & 21

Aug 25 - Sept 10

Boise River

M Fk

Bois Gold T6N R10E SEC27 BM

7/1 - 8/31/08

Boise River

M Fk

Atlanta Airport

All Year

Boise River

M Fk

Below Atlanta

7/1 - 9/30/08

Boise River

M Fk

Claim PMGR #172880 and 29 Atlanta

Sept 11 - Dec 31


-------
1906

2063

2065

1856

" 2061

2060

2059

2058

1748

2055

1761

1813

1814

1816

2021

2022

1612

1899

1611

2019

1898

2032

2025

1565

1900

1587

1775

1614

Boise River

M Fk

Below Queens River Campground near Confluence Eagle Creek

Boise River

M Fk

Claim PMGR #172880 and 29 Atlanta

Boise River

M Fk

Claim J & R #2 Area 8 Atlanta

Boise River

M Fk

GPAA Claim by Atlanta

Boise River

M Fk

Arrowrock Reservoir toward Atlanta

Boise River

M Fk

Arrowrock Reservoir toward Atlanta

Boise River

M Fk

Arrowrock Reservoir toward Atlanta

Boise River

M Fk

20 Mi West of Atlanta, ID

Boise River

M Fk

Not Reported

Boise River

M Fk

Upper area of Middle Fork rear where Black Warrior Creek
comes in

Boise River

M Fk

Main Stream Channel and Gravel Bars

Boise River

M Fk

T5N R9E SEC 4 & 5

Boise River

M Fk

Atlanta Airport

Boise River

M Fk

Xxx? 186770.186782/Silver City Area. AU xxx? National Claims

Boise River

M Fk

Dutch Cr Ranger Station

Boise River

M Fk

T5N R9E

Boise River

M Fk

GPAA Claim T6N SEC 27 BM "Boise Gold"

Boise River

M Fk

Queens Placer Claims - Operating Bxxx?

Boise River

M Fk

GPAA Claim T6N R10E SEC27BM, Boise Gold

Boise River

M Fk

17M South of Atalanta

Boise River

M Fk

Queens Placer Claims Operating Bxxd? in place 5
Atlanta

10 from

Boise River

M Fk

8 miles to City of Crouch

Boise River

M Fk

Not Reported

Boise River

M Fk

Below Queens River Campground

Boise River

M Fk

Approx. 1.5 Mi Downstream from Atlanta

Boise River

M Fk

Mile Pts 126 & Eagle Creek

Boise River

M Fk

Deer Creek

Boise River, M Fk

Between Dutch Creek Ranger Station & Roaring River, T5N R9E
"Dun Lookn Claim"


-------
2033

1789

1705

1943

1603

1797

1508

1706

1881

1502

1488

1785

2041

1910

2023

1770

1897

1665

1762

" 1900

2009

1854

" 1970

" 1979

" 1970

1889

" 2007

Boise River, M Fk [typed
in Boise River instead
Pine ]	

8 miles to City of Crouch

Boise River, S Fk

Not Reported

Boise River

S Fk

About 6 1/2 Mi N. Anderson R.R. When Open

Boise River

S Fk

2.5 Miles North of Pine

Boise River

S Fk

*Above line (S. Fork of Boise) also filed on seperate stream
alteration permit location closed. Dredging not allowed

Boise River

S Fk

GPAA Claim

Boise River

S Fk

Pine Bridge Area & above to 250 Yards

Boise River

S Fk

T29N R7E Sec 24 & 2

Boise River

S Fk

South Fork Boise

Boise River

S Fk

Above Pine Bridge

Boise River

S Fk

T2N R10ES5 IMC #174103

Boise River

S Fk

J&R #2 Miss Lucy

Boise River

S Fk

Thunder Dog Claim T2N R10E SEC8 BM BLM

Boise River

S Fk

Not Reported

Boise River

S Fk

Feathervile Area

Boise River

S Fk

(Run Both) 2 Miles South Queens River Campground

Boise River

S Fk

South Fork Boise River Pine

Boise River

S Fk

GPS 43* 31' 47.0"N (N-W Conner at Road) 115*18' 00"W

Boise River

S Fk

Atlanta Area

Boise River

S Fk

GPAA Claim at Dog Creek

Boise River

S Fk

Bear Cr

Boise River, S Fk

NW1/4 NW1/4 NW1/4 S8 T2N R10E (Thunder Dog Claim)

Boulder Cr

Boulder Cr (McCall Area), Idaho City

Boulder Cr

2 Miles W of Boulder Lake

Boulder Cr

Boulder Cr (McCall Area), Idaho City

Boundary River Drainage
or Boundary Creek
Drainage?	

Bed of Stream

Boundry

At the Mouth


-------
1762

1804

1805

1493

1571

1486

1530

2059

" 2061

2060

1755

1529

1788

1884

1767

1868

1823

1824

1867

1763

1956

1744

1957

1750

1708

1691

1963

1660

1592

2001

1964

Bridge Cr

Owyhee River Drainage

May - Jul

Brown Cr

GPS 46* 18' 19.00" N 115* 45' 4.40" W T34N R6E SEC6.7 BM

August

Brown Cr

GPS 46* 18' 19.00" N 115* 45' 4.40" W T34N R6E SEC6.7 BM

August

Bruneau River

Below Hot Creek

7/1 -9/10

Bruneau River

1/4 Mile Upstream from Bruneau Res

Aug 10 - Sept 10

Butle Gulch

Lower End West Side Sec 36

Jun 1 thru Sept 31

Butte Cr

West 100' of B4MC Mining Claim SEC 36

Jun to Sept 31

Cascade Reservoir

West Mt Streams

9/14/08-12/31/08

Cascade Reservoir

West Mt Streams

9/8/08-12/31/08

Cascade River

West Mt Streams

9/4/08 - 12/31/08

Casper Cr Snowshoe &
Elk

Salmon River from Center of Creek to High Water Mxx?

Jan 1 - Oct 31 Weekends &
Occasion Times

CDA River & Tribs

Not Reported

7/15-8/15

Cinebar Cr

Club Claims

Summer/Fall

Cinnabar Cr

Below Water Mark in Cr

Jul 15-Aug 15, 08

Cinnadal?

FSR #620

Summer to Fall

Cleanwater River

750' at MP 23 1/2

Jul 1 thru Sept 30

Clearwater River

Six Mile Cr

Open Season

Clearwater River

Six Mile Cr

Open Season

Clearwater River

750' MP 325'

Jul 1 - Sept 15

Clearwater River

Gibbs Eddy ID

7/1 -9/15/08

Clearwater River

Not Reported

Jul 1 - Sept 15

Clearwater River

Gibbs Eddy, Hogs Island, 1/2 Mile above Cherry Lane Bridge

Clearwater River

Not Reported

Not Reported

Clearwater River

Mile #26 - 27, 3738 North Side of River

Legal Time

Clearwater River

46* 29' 59"N; 116*19' 49" W

Jul 1 - Sept 15

Clearwater River

Gibbs Eddy

Jul 1 - Sept 15

Clearwater River

Between M Maker 16-17

Jul 1 - Aug 15

Clearwater River

Gibbs Eddy

Jul 1 - Sept 15, 2008

Clearwater River

1/10 mile down streem from mile marker 34 Hwy 12 (See Map)

Jul 1 to Sept 15, 2008

Clearwater River

North & South Forks near Golden and Grangeville

Jul 26 till Sept 15

Clearwater River

Gibbs Eddy Area

Not Reported


-------
1807

1585

1592

1592

1681

2026

1495

1969

1572

1680

1538

1684

1889

1734

1544

1843

1676

1677

1561

1728

1699

1857

1562

1728

1858

1659

" 1670

1737

1855

Clearwater River

Town City Pardee

Clearwater River

Below Kooskia across River from Jolindas Restaurant

Clearwater River

1/10 mile down streem from mile marker 34 Hwy 12 (See Map)

Clearwater River

1/10 mile down streem from mile marker 34 Hwy 12 (See Map)

Clearwater River

Gibbs Eddy

Clearwater River

River Drainage North Fork

Clearwater River

Red Rock Outcropings

Clearwater River

Not Reported

Clearwater River

Gibbs Eddy

Clearwater River

Gibbs Eddy

Clearwater River

Orofino Cr above Orofino Cr Falls

Clearwater River

See Map #1

Clearwater River
Drainage	

Bed of Stream, N Fk of Clearwater & Tribs below Kelly Cr

Clearwater River

N Fk

Upstream of Dworshak

Clearwater River

N Fk

Below Kelly Creek & Tribs

Clearwater River

N Fk

Within 2 Miles Main of Kelley Cr Confluence Downstream

Clearwater River

N Fk

masterFrench Cr or Orogrande Cr

Clearwater River

N Fk

Orogrande Cr & French Cr

Clearwater River

S Fk

MP39 & MP40

Clearwater River

S Fk

Mile Post #41 Area Around Dutch Oven Creek

Clearwater River

S Fk

Legget Creek South Fork Clearwater River

Clearwater River

S Fk

Dewey Mine Hole

Clearwater River

S Fk

MP 39 and MP40

Clearwater River

S Fk

Telephone Pie 4-57-7 Down River 0.6 of a Mile

Clearwater River

S Fk

Dewey Mine Hole

Clearwater River

S Fk

Same as last year between old sautam bridge and the Falls
Creek bridge in SEC 31 TWP 29N	

Clearwater River

S Fk

Mile Maker 46 - See Pictures

Clearwater River

S Fk

PI 395 Power Site Withdrawal; Section 33, Confluence of
American and Red River South Fork Clearwater

Clearwater River

S Fk

Dewey Mine Hole


-------
1684

1676

1677

1658

1751

1604

1577

1579

1752

1580

1807

1777

1933

1823

1840

1824

1840

" 1777

1688

2066

1541

1842

1974

1799

1932

1924

1804

1805

Clearwater River

S Fk

See Map #2

Jul 25 to Aug 15

Clearwater River

S Fk

Between mile marker 39 -42

Jul 25 - Sept 15

Clearwater River

S Fk

Between Mile Marker 39 - 42

Jul 25 - Sept 15

Clearwater River

S Fk

Same place as last year

Not Reported

Clearwater River

S Fk

Hwy 14 Mile Marker 40.5 Ol Center Star Bridge

Jul 25-Aug 15

Clearwater River

S Fk

Between mile marker 39 & 42

Jul 25-Aug 15

Clearwater River

S Fk

Township 29 Range 8E Section 29. Map attacehed used in past
years permits.	

7/25-8/15

Clearwater River

S Fk

Dutch Oven #2 Claim (See attached description)

7/25 to 8/15/08

Clearwater River

S Fk

Hwy 14 Mile Maker 40.5 Ol Center Star Bridge

Jun 25 - Aug 15

Clearwater River

S Fk

Dutch Oven #2 Claim (See attached description)

7/25 to 8/15/08

Clearwater River

S Fk

Map enclosed

7/25-8/15

Clearwater River

S Fk

#2 Near MP 38 on SH 14 Marked by 2 Red Posts

Jul 25-Aug 15

Clearwater River

S Fk

All

7/25-8/15

Clearwater River

S Fk

Miles Marker 39 to 42

Open Season

Clearwater River

S Fk

Telephone Pole 4-52-7 down River 6 of a Mile

7/25-8/15

Clearwater River

S Fk

Mile Makers 39 to 42

Open Season

Clearwater River

S Fk

Mile Post 41 Area around Dutch Oven Creeds

7/25-8/15

Clearwater River

S Fk

#1 Near MP 33 on SH 14 Marked by 2 Red Posts

Jul 25-Aug 15

Coeur d'Alene

Lewiston Area

5/1/08

Crimes Cr

Area 29 China Wine Cup Claim #172897, between Pioneerville &
Centerville

Year Around

Crimes Cr, Payette River

After turn off from Hiwy 21 - upstream?? I must go to BLM to find
out when and where I may dredge. (If it is open for dredging)

Hopefully a few times this
summer. Wish I could go
more.

Crossed Out

Crossed Out

Crossed Out

Crystal Cr

Discharging into Orogande Cr

Jul 1, 2008

Crystal Cr

Not Reported

Jul 1 - Aug 15

Danlee Cr

T35N R6E SEC 30

7/1 - 3/31

Dodge Cr

Down Rock Cr/SE 1/4 SEC 2T*N R5E Mouth of Cr

Jul 1 - Dec 1

Dunnigan Cr

GPS 43*44' 51,4"N 115*58' 7.60" W TN5 R4E SEC 27

August

Dunnigan Cr

GPS 43*44' 51,4"N 115*58' 7.60" W TN5 R4E SEC 27

August


-------
1755

1843

2066

1578

1768

1928

1894

1893

1548

1788

1635

1492

1673

1767

1504

1685

" 2057

1690

1615

2029

1981

1929

2038

1873

1960

1501

Eagle Cr

Salmon River from Center of Creek to High Water Mxx?

Jan 1 - Oct 31 Weekends &
Occasion Times

Eagle Cr

GPAA Claimed Area

Jul 15

Eagle Cr

Area 8 S Side Eagle Cr Claim J&R #2, Middle Fk, Boise River,
Atlanta

Jul 1 - Sept 30

Eagle Cr

Eagl Creek at End of Road Access (Coup Weekends at
Recreational)	

Jan 1 to Dec 31

Eagle Cr

See Attachment (2) Claims Description

Jan 1 - Dec 31, 2008

Eagle Cr

Prichard/ Murray Area

Jul - Aug

Eagle Cr

Up Eagle Creek

Wk Ends Jul - Sept
Wk Ends Jul-Sept

Eagle Cr

Up Eagle Creek

Jul - Sept

Eagle Cr

Behind Rocks & in Bedrock Cracks

Mar 1 to Nov 1, 2008

Eagle Cr

East and West Fork on NWGPA Club Claims

Summer/Fall

Eagle Cr

Approx 1/2 Mi above Pritchard Creek

Jul 15 to Aug 15

Eagle Cr

E. Fork between Tobggan Creek and Oregon Creek

7/2008

Eagle Cr

Claims belong to Northwest Gold Prospectors Association

Snow melt to Snow Fall

Eagle Cr

Eagle City Park East West Fork

Diito

Eagle Cr & W. Eagle Cr

1.1 Mi up Eagle on Rd

Eagle Cr, E Fk

Not Reported

Eagle Cr, E Fk

6 Miles North of Murray

1/1/08-12/31/08

Eagle Cr, E Fk

Eagle Creek Drainage Sections 16, 17, 19, 20, 30; T50N RSE

Jun - Oct on limited basis

East Eagle Cr

Various locations within the Idaho National Forest operating
dates during open season 2008	

Elk Cr

5 Miles from Idaho City

Jul 1 - Sept 30, 2008

Elk Cr

8 Miles Upstream from Idaho City

Aug 5 - Sept 3

Elk Cr

8 Miles up from Idaho City

Jul 1 to Sept 30

Elk Cr

Idaho City 4 Miles Upstream

Jul - Sept

Elk Cr

Above Eldorado Gulch

Jul 1 to Oct 1

Elk Cr

Lager Br, Rd up the Creek about 1 Mile

Jul 1 - Sept 30

Elk Cr

Above Idaho City T7N R6E S19, 1 /11 Sec SE

Jul 4-Jul 14,2008


-------
1507

1912

1506

1930

1839

2081

1935

1490

1911

1915

1493

1934

1936

1653

1653

1798

1787

1695

1543

1560

1594

1696

1963

1545

1974

1544

1499

1747

Elk Cr

Boarder Line between 7N6E SEC 19-20; 43*55.36.69" &
115*58.08.56"

Elk Cr

Above El Dorado

Elk Cr

Boarder Line between 7N6E SEC 19-20; 43*55.36.69" &
115*58.08.56"

Elk Cr

8 Miles up from Idaho City

Elk Cr

Claims "Dear 1", IMC #181254 and ECT

Elk Cr

Near Idaho City

Elk Cr

North of Eldorado Gulch

Elk Cr

Set 1 & 12

Elk Cr

Above El Dorado

Elk Cr

2 Miles from Deer Cr

Elk Cr

Above Floorwood? Gulch, T7N R6E S3.?NE..?

Elk Cr, Idaho City

Above Eldorado Gulch

Elk Cr, Idaho City

North of Eldorado Gulch

Elk Run Cr

150' from Mouth of Elk Run Creek

Emma Cr

150' from Mouth of Emma Creek

French & Oregande Cr

GPAA Claims Per Attached Maps

French & Orogande Cr

GPAA Claims Per Attached Maps

French Cr

At Twin Cabin Site Y East Fork of French Creek

French Cr

GPAA Claim - French Mt.

French Cr

Mile Marker 12-14

French Cr

250K Road to Blue Bell Gulch

French Cr

At Twin Cabin Site & East Fork of French Creek

French Cr

GPAA Claim Elk Spirit IMC 183091

French Cr

GPAA Claims

French Cr

Headwater 250 rd French Mta Saddle

French Cr

GPAA Claims

French Cr

Bank to Bank

French Cr

GPAA Claim Elk Spirit"IMC# 182091


-------
1743

1742

1740

1739

1741

1827

1575

1576

1660

1537

1816

1789

1748

1833

1897

1522

1814

1903

1835

1834

1691

1845

French Cr N Fk of
Cleanwater

Claim #194236 Twin Pine G Placer Claim E2, SE4, SE4, SW4 &
W2 SW4 SW4 SE4 of Section 7, T37N, R7E Clearwater County,
Idaho (10 Acres)	

7/1/08 to 8/15/08

French Cr N Fk of
cleanwater

Claim #194236 Twin Pine G Placer Claim E2, SE4, SE4, SW4 &
W2 SW4 SW4 SE4 of Section 7, T37N, R7E Clearwater County,
Idaho (10 Acres)	

7/1/08 to 8/15/08

French Cr N Fk of
Clearwater

Claim #194236 Twin Pine G Placer Claim E2, SE4, SE4, SW4 &
W2 SW4 SW4 SE4 of Section 7, T37N, R7E Clearwater County,
Idaho (10 Acres)	

7/1/08-8/15/08

French Cr N Fk of
Clearwater

Claim #194236 Twin Pine G Placer Claim E2, SE4, SE4, SW4 &
W2 SW4 SW4 SE4 of Section 7, T37N, R7E Clearwater County,
Idaho (10 Acres)	

7/1/08-8/15/08

French Cr N Fk of
Clearwater

Claim #194236 Twin Pine G Placer Claim E2, SE4, SE4, SW4 &
W2 SW4 SW4 SE4 of Section 7, T37N, R7E Clearwater County,
Idaho (10 Acres)	

7/1/08-8/15/08

French Mt

T37N R6E SEC 23, 25, 26, 27 & 35

July 25, 2008

Ganite CrTribs

Idah Mining Claim # 192920. All areas of tributary

Jul 1 - Sept 30

Ganite CrTribs

Idaho mining Claim # 92920, All areas of tributary

Jul 1 to Sept 30

George Gulch

NWGPA Claim, Prichard Cr & Tribs

Apr 11, 2008-Mar 31, 2009

Gold Cr and Tribs

Specific location undetermind - Variable

Variable

Granit Cr

Hazel 1 IMC #194810 Granit Cr, Pilgrim Sec 9 T7N

Jun - Nov 08

Granit Cr

Not Reported

Weekends

Granite Cr

3 Mi Placerville

Jan 31 - Dec 31

Granite Cr

Placerville

Jul 1 - Sept 30

Granite Cr

Granite Creek

Jul 1 - Sept 30

Granite Cr

See attached Maps

Jul 1 - Sept 30, 2008

Granite Cr

Quartzberg

Jan 1 - Dec 31

Granite Cr

1 1/2 Miles out of Idaho City

6/29 - 7/30/2008

Granite Cr

Quatz Burg 1 Mile North of Placerville

Not Reported

Granite Cr

Qurtz Burg 1 Mi North of Placerville

6/6-9/15

Greer Gulch

Greer Gulch Placer Claim, NWGPA, Mussel Shell Mining District

May 15 - Dec 31

Grimes Cr

Moneerville Near Wuddy Creek

6/1 - 9/30


-------
2064

1833

2066

" 2051

2065

1810

2025

1793

1792

2074

" 2075

1789

" 2075

1801

2076

1801

" 2071

" 2079

2062

1862

1849

1810

1811

1759

2053

2054

1811

1854

1794

Grimes Cr

China Wine Cup #172879 Area 29 Pioneerville

Grimes Cr

6 Miles N of Pioneerville

Gr

mes Cr

Area 29 Paymaster Golden Rule (Miss Lucy) Claim 172880,
between Pioneerville & Centerville

Gr

mes Cr

Near Pioneerville

Gr

mes Cr

China Wine Cup #172879 Area 29 Pioneerville

Gr

mes Cr

Miss Lucy IGPA Claim within 1 Mile of Pioneer Ville Buckskin Rd

Gr

mes Cr

Not Reported

Gr

mes Cr

3 Mi out of Centerville

Gr

mes Cr

3 Miles out of Centerville

Gr

mes Cr

From Mores Creek to Centerville

Gr

mes Cr

This Side MM4 on Grimes Creek toward Placeville

Gr

mes Cr

Township 5N Range 4E Section 27

Gr

mes Cr

1/7 Miles down Grives towards Placeville

Gr

mes Cr

Miss Lucy/ China Wine Cup

Gr

mes Cr

This Side of MM4 down Grimes toward Placeville

Gr

mes Cr

IGPA Claims 12 Mi out of xxx? Illegible

Gr

mes Cr

China Wine

Gr

mes Cr

Not Reported

Gr

mes Cr

China Wine Cup #172879 Area 29 Pioneerville

Gr

mes Cr

Between Pioneer Ville and Hwy21

Gr

mes Cr

GPAA Claim Clear Creek Bridge

Gr

mes Cr

China Wine Cup IGPA Claim

Grimes Cr

Wthin 1 Mile of Pioneer Ville Buckskin Rd. Miss Lucy Claim,
IGPA.

Grimes Cr

Tribs

Grimes Cr

Miss Lucy & China Wnecup IGPA Claims 3 Mile from
Pioneerville

Grimes Cr

Miss Lucy & China Wnecup IGPA Claims 3 Mile form
Pioneerville

Grimes Cr

China Wine Cup Claim, IGPA

Grimes Cr

NE1/4 NW1/4 S27 T5N R4E (His & His #14 #2 Claim)

Grimes Cr

Mile 5


-------
1852

1851

1814

2063

2080

1809

1925

1612

1547

1914

1527

1526

1525

1920

1953

1921

1921

1520

1523

1550

1926

1927

1939

1940

1726

1716

1954

1668

1987

1983

Gr

mes Cr

Miss Lucy & Cina Wine Cup IGPA Claims 3 Mile from Place Vile

Gr

mes Cr

Grimes Creek Centerville 4 Miles & 5 Miles xxx?

Gr

mes Cr

8 Miles North Pionerville

Gr

mes Cr

China Wine Cup #172879 Area 29 Pioneerville

Gr

mes Cr

IGPA Claims, Miss Lucy and Hanna

Gr

mes Cr

1/4 Mile Down from Pilot Peak

Gr

mes Cr

3 Miles out of Centerville/Placerville to Hwy 21

Gr

mes Cr

GPAA Claim T5N R4C SEC 27 His & Hers #1 & #2

Gr

mes Cr

Below 7 Mi and Wxxx? Illegible

Gr

mes Cr

Wthin Running Stream

Gr

mes Cr

West Side of Stream

Gr

mes Cr

Between Mile Post 5 and 6 on Rusty Nail Claim, Mining Claim
IMC 18447.

Gr

mes Cr

Between Mile Post 5 and 6 on Rusty Nail Claim

Gr

mes Cr

Grimes Tribs, Summit Flats Downstream

Gr

mes Cr

"difficult to decipher"

Gr

mes Cr

Hazel, Pilgrim

Gr

mes Cr

MOU Hannahl, China Wine Cup

Gr

mes Cr

Pioneerville

Gr

mes Cr

Between Mile Post 5 & 6 on Rusty Nail Claim, Mining Claim IMC
184447.

Gr

mes Cr

Below New Centervill

Gr

mes Cr

Mouth of Grimes Crto Grimes Pass near Mores Cr

Gr

mes Cr

3 or 4 miles out of Centerville

Gr

mes Cr

Grives Cr Upstream of Centerville

Gr

mes Cr

Grimes Cr Upstream of Centerville

Gr

mes Cr

Grimes Pass

Gr

mes Cr

Idaho Gold Club Claim in Pioneerville

Gr

mes Cr

Upper Sections & Midsections above Idaho City

Gr

mes Cr

Grimes Creek

Gr

mes Cr

Not Reported

Gr

mes Cr

Pioneerville at Buckskin Rd


-------
1980

1524

1508

1490

1491

1500

1991

1574

1506

1506

1569

1507

1565

1549

1828

1664

1564

1564

1563

1559

" 2076

1937

1552

1515

1551

1516

1517

Grimes Cr

Not Reported

Summer 2008

Grimes Cr

Between Mile Posts 5 & 6 on Rusty Nail Claim, Mining claim IMC
184447.

Mar - Sept

Grimes Cr

Secton above & below Private Areas

Jan - Dec

Grimes Cr

Pioneerville Area

Jul 1 - Sept 30

Grimes Cr

Right above Grimes Cr Bridge (1/4 Mi). -Usually only dredge for
me day in weekend if I can. Maybe 4 times a year. Also 2 mi
north of Centerville on 9 claim and in the dredge pond.	

Jul - Oct

Grimes Cr

Mouth to Headwater undecided this Earyl in the Senson

Year Round

Grimes Cr

Idaho City

Jan - Dec

Grimes Cr

Center of Creek

1/1 - 12/31

Grimes Cr

5N4E SEC 10 L3; 43*47' 12.42" & 115*57'52.13"

7/1 -9/30/2008

Grimes Cr

5N4E SEC 10, L3; 43*47' 02.49" & 115*58'8.56"

7/1 -9/30/2008

Grimes Cr

Idaho Gold Club Claims in Pioneer Ville

July or August 2008,
Pending time off work.

Grimes Cr

5N4E SEC 10 L3; 43*47' 12.42" & 115*57'52.13"

7/1 -9/30/2008

Grimes Cr

Below new Centerville

Jan 1 - Dec 31

Grimes Cr

MOU

All Year

Grimes Cr

Not Reported

Year Around

Grimes Cr

Machs Creek area

Open season

Grimes Cr

C&W at Max Creek

About 3 days in middle of
xxx?

Grimes Cr

Club Claims Idaho Gold Prospectors

Jan 1 to Dec 31, Weekends

Grimes Cr

All of

6/1 to 9/15/08

Grimes Cr

IGPA Claims

7/1 -9/30/08

Grimes Cr

1.7 Miles down Grimes toward Placeville

10/2/08-3/31/09

Grimes Cr

Bridge at Grimes Cr

Jun - Sept, 2008

Grimes Cr

His & His Claim, Hana 1 Claim

June

Grimes Cr

Below New Centerville

Jan 1 - Dec 31

Grimes Cr

His & His Claim, Hana 1 Claim

June

Grimes Cr

Below New Centervill

Jan 1 - Dec 31

Grimes Cr

C-W Claim

Spring, Summer & Fall


-------
1507

1772

1779

1605

1895

1611

2030

1900

1901

1613

1902

1774

1865

1904

1887

1906

" 2037

2038

1770

2041

1829

2043

1756

1830

2049

1689

1773

1644

2050

1655

Gr

mes Cr

5N4E SEC 10, L3; 43*47' 02.49" & 115*58'8.56"

Gr

mes Cr

China Wine Cup & Other Claims

Gr

mes Cr

T5N R4E SEC 27, Boise County

Gr

mes Cr

Tribs

Gr

mes Cr

Not Reported

Gr

mes Cr

GPAA Claim, T5N R4E SEC 27 His & His #1 & #2

Gr

mes Cr

SEC 3, Pioneer Ville, West 1/2

Gr

mes Cr

Approx. 3 Mi West of Hiway to Over Pass

Gr

mes Cr

4 Miles from Mores Creek

Gr

mes Cr

Centerville

Gr

mes Cr

1.5 from Highway Dunnigan Creek Topo

Gr

mes Cr

China Wine Cup/ ISPA Claims Centerville Area

Gr

mes Cr

Pioneerville Area near Muddy Creek

Gr

mes Cr

Above Centerville

Gr

mes Cr

T5N R4E Sect 27

Gr

mes Cr

IGPA Claims

Gr

mes Cr

His & His #1 & #2 Galo Claim T5N R4E SEC27

Gr

mes Cr

Idaho City & 6 Miles Placerville

Gr

mes Cr

Idaho Gold Prospectors Claims

Gr

mes Cr

His & His #1 & #2 Claim T5N R4E SEC 27 Boise N.F.

Gr

mes Cr

Centerville 3 Mile out of

Gr

mes Cr

Few Miles above Grimes Pass/ 3 Mi from ID21

Grimes Cr

Idaho Gold Prospectors Claim at Bridge below Centerville

Grimes Cr

Pioneerville Area Near Muddy Creek

Grimes Cr

Hwy 2a Upstream at Various Places

Grimes Cr

His & His #182, T5N R4E SEC 27 40 Acres

Grimes Cr

China Wine Cup/ IGPA Claims Centerville

Grimes Cr

GPAA Claims

Grimes Cr

Hwy 21 Upstream at Various Places

Grimes Cr

Upper Grimes Creek


-------
1705

1875

1655

1876

1877

1972

1645

1722

1879

2020

1971

1601

1581

1882

1719

1586

1587

1786

1785

1597

1599

1600

1866

1880

2052

2033

2032

2028

2027

Grimes Cr

1 1/2 Mi above Hway 21; His #1& #2 TtN R4E SEC27; & Other
Part Not under Claims upper xxx? Illegible	

Grimes Cr

GPAA Claims

Grimes Cr

Pay Master - Golden Rule and China Wine Cup

Grimes Cr

GPAA Claims

Grimes Cr

3 Miles out of Centerville

Grimes Cr

GPAA Claims -1 to 2 Miles from Centerville

Gr

mes Cr

Idaho Prospector Claim - Lower 1/2 of Claim by Bridge Middle of
Stream

Gr

mes Cr

Below Centerville

Gr

mes Cr

GPAA Claim

Gr

mes Cr

Near Clear Cr Rd & Placerville Area, Mores Cr N of Res

Gr

mes Cr

GPAA Claim

Gr

mes Cr

Several GPAP Claims - Grimes Creek and Atlanta etc

Gr

mes Cr

4 mile upstream. ANY LEGAL WATER

Gr

mes Cr

Upstream of Mores Creedk

Gr

mes Cr

Below Centerville

Gr

mes Cr

Hwy 21 to Pioneer Village

Gr

mes Cr

5 Miles from SH21 at bridge up & down Stream 1000 ft

Gr

mes Cr

China Wine Cup Claim in Pioneerville

Gr

mes Cr

All GPAA, All IGPA Claims

Gr

mes Cr

All

Gr

mes Cr

Pioneerville

Gr

mes Cr

Several GPAP Claims - Grimes Creek and Atlanta etc

Gr

mes Cr

Various Claims

Gr

mes Cr

IGPA Hannah Claim, Miss Lucy Claim

Gr

mes Cr & Tribs

Not Reported

Gr

mes Cr & Tribs

miles to nearst town 7 miles

Gr

mes Cr & Tribs

miles nearest from within 7 miles

Gr

mes Cr & Tribs

Between Grime Pass & Mores Cr

Gr

mes Cr & Tribs

To Mores Cr


-------
2023

1818

2048

2013

1757

1575

1576

1816

1808

1683

1806

2034

1878

1588

1655

1665

1954

1674

1490

1954

1533

1989

1722

1749

1993

2003

1716

1532

1998

1882

Grimes Cr & Tribs

4.3 Miles up from Hwy 21

Grimes Cr & Tribs

Grimes Cr & Tribs

Grimes Cr, Mores Cr &
Tribs

Not Known Yet

Grimes Cr, Thompson Cr
& Lewis Cr

Tributaries of Grimes Cr

Grimes Cr/ Payette River

Lsland Claim and Other Club Claims

Gr

mes/Boise River

Idaho Mining Claim #125809 3 miles from Golden xxx?

Gr

mes/Boise River

Idaho Mining Claim #125809, 3 miles from Golden xxx?

Gr

mms Cr & Tribs

Hannan xxx? Grimes Cr & Tribs

Gr

ms Cr

GPAA Claims

Gr

ms Cr

1 Mile by Hiway 21

Gr

ms Cr

GPAA Claims

Gr

ves Cr

Grimes Cr (Centerville

Grives Cr & Tribs

Not Reported

Grmes Cr & Tribs

5 Miles from SH-21 at bridge up & down Stream 1000"

Grmes Cr Drainage

K2 #1 & Miss Lucy West of Grimes Cr Claims

His & His #1 & #2

GPS 43*44'51.4"N (End on Road) 115*58'7.60"W

Hughes Cr & Dutch Cr

(As conditions allow) N of Salmon, ID*

Idaho, N

See attached sheet of claims

Illegible

Illegible

Indian Cr & Sage Cr

(As conditions allow) N of Salmon, ID*

Jordan Cr

Barns Gulch mule head placer claim

Jordan Cr

Silver City

Jordan Cr

Above Willimas Creek

Jordan Cr

Silver City Area

Jordan Cr

Above 2 Miles North of Silver City and 1 Mile South of Siver City

Jordan Cr

4 Miles from Silver City

Jordan Cr

West of Silver City Approximately 1 Mi

Jordan Cr

Barns Gulch mule head claim

Jordan Cr

T5S R3W4SEC 6 & 7?

Jordan Cr

Upstream of Wlson Creek


-------
1686

1977

1977

1772

1997

1569

2080

1786

1919

1919

1919

" 2067

" 2051

1892

1988

1570

1780

1689

1613

1605

1719

1522

1597

1563

1603

1983

1990

1645

1841

1924

Jordan Cr

Not Reported

All Year

Jordan Cr

UGPC SiverCity Claim 18

Nov 1 - Nov 5

Jordan Cr

UGPC SiverCity Claim 18

Jul 24 - 7/28

Jordan Cr

IGPA & utah GPA Claims and Other Areas

1 Jan - 31 Dec

Jordan Cr

T5S R3W SEC 6 & 7

Jul 25-27

Jordan Cr

Idah Gold Prospectors Club Claim, Jordan Creek W. of Siver City

29-31 May & Last 2 Weeks
in July 2008	

Jordan Cr

IGPA Claims

Year Round

Jordan Cr

1 Mile West of Siver City Claims

Jan 1 - Dec 31

Jordan Cr

T55 R3WSE 1/4 6 NE 1/4 SEC 7

Jan 1 - Dec 31

Jordan Cr

T55 R3W NW 1/4 NW 1/4 SEC 5

Jan 1 - Dec 31

Jordan Cr

T45 R4WSE 1/4 SEC 25

Jan 1 - Dec 31

Jordan Cr

Between Silver City and De Lamar

Sept 20 - Oct 20

Jordan Cr

Edge of Silver City 1 1/2 Mi Downctream

Aug 2008

Jordan Cr

Rear

Occasional

Jordan Cr

Siver City Area

Jul 25-27, 2008

Jordan Cr

North Star IGPA claim

Late Sept

Jordan Cr

9 Miles xxx? Jordan Valley

Jan 1 - Dec 31

Jordan Cr

2 Miles NW of Silver City, T4S R4WSEC25, Boise Mxx?

6/1 -8/31/08

Jordan Cr

Delaman

May - Oct

Jordan Cr

Above Wllams Creek

Jan 1 to Dec 31

Jordan Cr

Above Willims Cr

Jan 1 - Dec 31

Jordan Cr

See attached Maps

Mar 4- Dec 31, 2008

Jordan Cr

Demar Mine Bridge to Siver City

May to Sept 08

Jordan Cr

Upstream from Wlliams Creek

6/1 to 9/15/08

Jordan Cr & Tribs

Private Claim above Silver City, another claim below Silver City.
Jordan Creek above Wlliams Creek.

5/25 to 8/1/08

Jordan River

Silver City South MP5

Jan 1 - Dec 31

Jorden Cr

Above Williams Cr, Silver City

Jul - Sept

Jordon Cr

R3WT5S SEC31

Jan 1 to Dec 31

Kelly Cr

SE Clearwater Co ID

Ditto

Lambing Cr

From Mouth at Arrowrock Reservoir upstream 1000 yds

Jul 1 - Dec 1


-------
2079

1850

1841

2058

1701

1590

1946

1719

1722

2020

1697

1933

1765

1579

1580

1764

1531

1723

1724

1769

1702

1703

1826

2042

1714

1725

1826

1826

1754

1748

1713

Little Canyon Cr

Not Reported

Little Moose & Kelly Cr

About 14 Mi Upstream from Kelly Fork Ranger Station SE
Clearwater Co ID

Little Moose, Moose

About 14 Miles Upstream from Kelly Fork Ranger Station

Little Smocky CI

Couch Summit Rd - Downstream 2 Ml

Loho Cr

T34N R6E SEC6 & 7 BM GPS 46*18'19.00"N

Lower Part of Grimes Cr

Side of Stream Various Claims on Sight

M Fk Payette

Garden Valley

M Fk Payette

Upstream to Wet Ft Creek

M Fk Payette

Upstream to Wet Ft Creek

M Fk Payette River

N of Tie Cr Campgound, Silver Cr NW of Plunge

Magic River

1/4 mile above Magic Dam

Main Clearwater

All

Main Clearwater

Gibbs Eddy

Main Clearwater

1 1/2 mile upstream from Lenore, ID (See attached description)

Main Clearwater

1 1/2 miles upstream from Lenore, ID (See attached description)

Main Clearwater

Gibbs Eddy

Main Clearwater River

Mouth to Kooskia (Gibbs Eddy to Myetle Bar) (Big Eddy)

Main Salmon

200 ft from boat ramp at rest area

Main Salmon

Site # 1 & 2 (See Map)

Main Salmon

3 Miles South of Riggins

Main Salmon

Hammer Creek to Long Tom bar

Main Salmon

Long Tom Bar to Hammer Creek

Main Salmon

Lucile Boat Ramp, BLM Land

Main Salmon

T24N R2E SEC20 Tween MP PST 5&6

Main Salmon

Hammer Creek to Long Tom Bar

Main Salmon

Site # 1 & 2 (See Map)

Main Salmon

Bridge at Lucile, BLM Land

Main Salmon

Pealy Loop Road, BLM Land

Main Salmon

East side of River at Mile Marker 204 and North

Main Salmond

Hammor Creek - Long Tom Far

Main Salom

Near Lucile


-------
219

1505

Meadow Cr

200' up West Meadow Creek, just off the Main Meadow Creek

Aug 1 - Aug 10

445

1763

Meadow Cr

Micky Mouse Claim (Nampa) - Florance ID North West Gold
Prospectors Association

7/1 - 9/30/08

929

2037

Mob Foax Boise

Boise Galo Claim T6N R10E SEC27

Weekend Aug - Sept

607

1845

Mons Cr

Island Claim

7/1 - 9/30

159

1664

Moores Cr

Daggott Creek

Open season

815

2004

Moores Cr

Robie Cr Turn off Hwy 21

End of Season

863

1981

Moors Cr

Mile Marker 42 Hwy 21

Jul 21 - Aug 5

46

1593

Moose Cr

SE 1/4 of Section 4 and the SW1/4 of Sections, T30N rue
BM Idaho

Jul 1 to Aug 15, 2008

602

1846

Mores & Grimes Cr

GPAA Local Club Claims Area

Jun 1 to Nov, 2008

599

1847

Mores & Grimes Cr

GPAA & Idaho Gold Pros Club Claims

Jun 11 to Nov 1, 2008

862

1982

Mores Cr

Just down from Robie Cr Turn of from Hwy 21

July 1 - Sept 30

1002

2071

Mores Cr

1.5 Miles above Idaho City

Open Period

935

2040

Mores Cr

Mores Cr below Boulder Cr

Sept 30 - ?

932

2038

Mores Cr

Idaho City Area 7 Miles Downstream

Jul - Sept

909

2025

Mores Cr

Not Reported

Jul 1- Sept 30

109

1599

Mores Cr

MP24

7/1 to 9/30

647

1901

Mores Cr

Various Banks

Jan 1 - Dec 31

124

1587

Mores Cr

Mile Pts 24 Grimes Creek

Jul 1 to Dec 31

128

1586

Mores Cr

Upstream of Daggett Creek

May 1 to Oct 31

1019

2081

Mores Cr

Near Idaho City

Entire Year

575

1862

Mores Cr

From Grimes to Lucky Peak Reservoir

Jul 1 - Sept 30

709

1926

Mores Cr

IGPA - Island Claim near Idaho City

Jul 1 - Sep 30

638

1906

Mores Cr

Below Confluence of Grimes Creek

7/1 - 9/30/08

198

1520

Mores Cr

Idaho City

7-1-08 Open Season

824

1937

Mores Cr

Bridge at Mores Cr

Jun - Sept, 2008

801

1991

Mores Cr

Siver City

Jan - Dec


-------
626

1830

Mores Cr

Island Claim

Jul 1 - Sept 30

707

1927

Mores Cr

Tribs downstream of Boulder below high water mark - main
stream channel

7/1/- 9/30

895

2013

Mores Cr & Granit Cr

Tributaries of Mores Cr

Aug 8 thru 21

122

1588

Mores Cr & Trib

MP 24 on SH-21

Jul 1 to Sept 30

510

1818

Mores Cr & Tribs

Mores Cr & Tribs down Stream of Boulder Cr

Jul - Sept 30

663

1886

Mores/Grimes Cr

Drainage - Center

Jan 1 - Dec 31

692

1865

Mores? Cr

Island Claim

Jul 1 - Sept 30

118

1590

Moris Cr

Middle Stream Various Claims on Sight

Year around 1/1/08

731

1910

Morris Cr

Not Reported

All Open Dates

780

1945

Moyte

9 Miles North Hwy 2

7/15-8/15-08

228

1494

Mud Cr

Not Reported

Aug 1 - Mar 1

956

2065

Muddy Cr

Claim PMGR #172880 and 29 Pioneerville

Sept 11 - Dec 31

959

2064

Muddy Cr

Claim J & R #2 Area 8 Pioneerville

Sept 11 - Dec 31

964

2063

Muddy Cr

Claim J & R #2 Area 8 Pioneerville

Sept 11 - Dec 31

968

2062

Muddy Cr

Claim PMGR #172880 Area 29 Atlanta

Sept 11 - Dec 30

1004

2071

Muddy Cr

Pay Master

Open Period

537

1805

Mule Cr

GPS 45* 56' 34.0" N 115* 37' 33.1" WT30N R7E SEC Multible
BM

August

540

1804

Mule Cr

GPS 45* 56' 34.0" N 115* 37' 33.1" WT30N R7E SEC Multible
BM

August

279

1558

N Fk Boise

Near Deer Park Cabin

7/2/08 -9/30/08

278

1559

N Fk Boise

Not Reported

Not Reported

902

2020

N Fk Boise River

N of Owl Cr Rd, M Fk Boise River, Hot Spring Area

Aug - Oct

207

1514

N Fk Boise River

Between Dutch Creek Ranger and Roaming River, T5N R9E,
Dun Lookn? Claim

Aug 8 - Sept 1

37

1604

N Fk Cleanwater

Orogrande Cr - French Cr.

Jul 1 - Sept 15

60

1545

N Fk Cleanwater

Below Kelly Creek & Tribs

Jul 1 to Aug 15, 2008


-------
436

1765

N Fk Clearwater & Tribs

N Fk Larson Cr to Kelly Cr - Orogrande Crk - 250 Rd & GPAA
Claims

7/1 to 8/15/08

441

1764

N Fk Clearwater & Tribs

N Fk Larson Cr to Kelly Cr - Orogrande Cr - 250 Rd & GPAA
Claims

7/1 to 8/15/08

565

1787

N Fk Clearwater River

Below Bungalow Bridge

Jul 21 - Aug 1

548

1798

N Fk Clearwater River

Below Bungalow Bridge

Jul 21 to Aug 1

453

1753

N Fk Palouse

Above Sand Creek

1 Jun - 30 Sept

185

1539

N Fk Paluse River

J&D Placer #1 & 2, Sec 14 Township 42N Range 2W Attachment

Jul 08 to Oct 08

629

1829

N Fk Payette

Cabarton?Bridge to Big Payette

Jan 1 - Dec 31

908

2024

N Fk Payette Drainage

Pond off Warm Wagon Rd

Not Reported

838

1952

N Fk Payette Trib

East National Forest Boundary 1/2 Mile East High Valley
Cabarton Rd

Jul to Sept

698

1708

N Fk River

46* 29' 59"N; 116* 19' 49" W

Jul 1 - Aug 15
Jul 1 - Aug 15

66

1543

N. Fork Clearwater

Below Kelly Creek & Tribs

7/1/08 to 8/15/08

114

1596

Nakkohe Morning Star,
T37N R7E Sections 6 & 7

Clearwater County - Land Status Clearwater NF GPS, 46 34 42
56" MCN - E Corhee at Road 115 36' 49 51W



454

1753

Neadow Cr

In Florance District above the Old Airport Road

1 Jun - 30 Sept

67

1542

Not Reported

Not Reported

Not Reported

982

2056

Not Reported

Not Reported

Not Reported

994

1496

Not Reported

Not Reported

Not Reported

765

1822

Not Reported

Not Reported

Not Reported

239

1503

Opher Cr

Lost Cabin Mine. 1 Mile Section on Road 386A

May to Oct

119

1590

Ophra Cr

Lower Part of GSide of Stream

Year around 1/1/08

500

1838

Oragrande Cr

Owanchaya Claim: T37N R7E Sec 6

7/1 -8/15

32

1635

Oregon Gulch

Approx 1 Mi above Eagle Creek

Jul 15 to Aug 15


-------
1660

1548

1528

1495

1823

1824

1512

1701

1891

1891

1560

1874

1534

1511

1967

1536

1676

1677

2014

" 2015

1969

1963

1957

1604

1956

1691

1941

Oregon Gulch

NWGPA Claim, Prichard Cr & Tribs

Apr 11, 2008-Mar 31, 2009

Oregon Gulch

Behind Rocks & in Bedrock Cracks

Mar 1 to Nov 1, 2008

Orofino Cr

Drainage above Falls

7/1/thru 9/15

Orofino Cr

Above Falls Rock Outcroping

7/1 to 8/15 Weekends

Orofino Cr

Headwaers to Mouth

Open Season

Orofino Cr

Headwaters to Mouth

Open Season

Orofino Cr

Above Orifino Creek Falls

5/1/08 to 3/1/09

Orofino Cr

T37N R5E Hay Creek and McAauley Creeks Mouth

7/1 - 3/31

Orofino Cr

NWNWSEC 4T36N R5E

Jul 1 - Mar 31

Orofino Cr

Px? SEC36 T37N R4E

Jul 1 - Mar 31

Orofino Cr

Omill Area

Jul - Oct

Orofino Cr

Pirece, ID

July 1

Orofino Cr

Yours N Mine #1 Claim

Apr 30 to Oct 30, 2008

Orofino Cr

Rd 250- MP 2.5 to MP 4.5

7/1 to 10/1/08

Orofino Cr

Center of Creek

Jul 1 - Sept 15

Orofino Cr

Yours N Mine Claim #1

Apr 30 to Oct 30, 2008

Orofino Cr

Above Falls

Jul 1 - Mar 31

Orofino Cr

Above Falls

Jul 1 - Mar 31

Orofino Cr

Above the Falls

Entire Season

Orofino Cr

Above the Falls

Entire Season

Orofino Cr

Near Falls

Jul 1 - Oct 10

Orofino Cr

Above Orofino Cr Falls

Jul 1 - Mar 31

Orofino Cr

Not Reported

Not Reported

Orofino Cr

Above the Falls

Jul 1 - Mar 31

Orofino Cr

N of Fall

Jul 1 - Mar 31

Orofino Cr

Above Orofino Creek Falls

Jul 1 - Mar 31

Orofino Cr

SW Coner of SEC 36, T37N, R4E, Thence Upstream Apprx.
500"

7/15-10/1/08


-------
772

1932

Orofino Cr

Rhodes Cr meets Orofino Cr

7/1 - 3/31

182

1684

Orofino Cr

See Attached ID-15 & ID-16

Jul 1 to Mar 31

524

1812

Orofino Cr Drainage

Orofino Creek Drainage

Jul 1 - Sept 15

492

1695

Orogrand Cr

After Pavement Ends

Not Reported

490

1696

Orogrand Cr

After Pavement Ends

Not Reported

753

1843

Orogrande

GPAA Claimed Area

Jul 1

513

1817

Orogrande

Mile Post 18 below Bridge. GPAA Claim

7/1 - 8/15

790

1963

Orogrande

GPAA Claim Nahkohe Morning Star

Jul 1 - Aug 15

773

1932

Orogrande

Where Syivan Cr meets Orogrande Cr

7/1 - 3/31

819

2010

Orogrande

11 Miles from head of the North Fork of Clearwater River on the
Orogrande

Jul 30, 2008 - Jan 31, 2009

377

1733

Orogrande

Crystal Cr

Jul - Aug

811

2001

Orogrande

Between Mile 13 and 23

Jul 20 till Closed

748

1884

Orogrande Cr

Below Water Mark in Cr T37N R7E SEC 6

Jul 15-Aug 15, 08

768

1918

Orogrande Cr

Starting 328 ft Upstream from Tama Cr Confluence to Approx.
2164 ft Upstream from Tama Cr Confluence, Total Area length is
approximately 1836 ft.

7/31 - 8/8/08

458

1747

Orogrande Cr

GPAA Claim Nahkohe IMC# 175241

7/1/08-8/15/08

767

1917

Orogrande Cr

Starting 328 ft Upstream from Tama Cr Confluence to Approx.
2164 ft Upstream from Tama Cr Confluence, Total Area length is
approximately 1836 ft.

Jul 15 - Aug 8

766

1916

Orogrande Cr

Starting 328 ft Upstream from Tama Cr Confluence to Approx.
2164 ft Upstream from Tama Cr Confluence, Total Area length is
approximately 1836 ft.

Jul 31 - Aug 8

254

1574

Orogrande Cr

Center of Creek

7/1 -8/15

459

1747

Orogrande Cr

GPAA Claim Owanchaya IMC# 175242

7/1/08-8/15/08

374

1736

Orogrande Cr

N. Fk Cleanwater, 46.5858, and 115.57775

7/1 - 8/15

481

1706

Orogrande Cr

T38 R7E Sec 33

7/1 - 8/15

546

1799

Orogrande Cr

Not Reported

Jul 1 - Aug 15

503

1837

Orogrande Cr

Owanchaya Claim: T37N R7E Sec 6

7/15-8/15


-------
77

1510

Orogrande Cr

Between Crystal Creek and Baily Gulch

7/1 to 8/15 Intermittently

671

1882

Other Creeks

to be determined

Jun to Nov

324

1709

Owhyee River Drainage

Jordan Creek above Williams Creek

May15 - Oct 15

321

1710

Owhyee River Drainage

Jordan Creek above Williams Creek

May15 - Oct 15

318

1711

Owhyee River Drainage

Jordan Creek above Williams Creek

May 15 - Oct 15

143

1654

Ownhee River

Jordon Creek Drainage

All season

674

1881

Owyhee River

Jodan Creek

Aug to Sept

349

1682

Owyhee River

Jordan Dreek above Willims Creek

1/1 - 12/31

519

1815

Owyhee River

Jordan Creek

7/10 - 8//30

150

1661

Owyhee River Drainage

All open area. Jordon River, Silver City

Jan 1 to Dec 31

153

1663

Owyhee River Drainage

All open area. Jordon River, Siver City

Jan 1 to Dec 31

156

1662

Owyhee River Drainage

All open area. Jordon River, Siver City

Jan 1 to Dec 31

745

1889

Owyhee River Drainage

Bed of Stream

Open til Close Season

165

1666

Owyhee River Drainage

Jordon Creek

5/20 - 5/30

556

1791

Owyhee River Drainage

Jordan Creek

May 20 - Sept 30

58

1545

Palouse River

Wasted Years/ Crazy Jackass & Strychnine Creek

Jan 1 to Dec 31, 2008

1014

1807

Palouse River

All Open Water

1/1 -12/31

50

1573

Palouse River

Township 42N Range 2W Sectionl

May 30 to Oct 30, 2008

51

1573

Palouse River

Township 42N Range 2W Section 14

May 30 to Oct 30, 2008

779

1944

Palouse River

Main River below Laird Park

July 1st - Sept, 3-4 times
total

64

1543

Palouse River

Wasted Years/ Crazy Jackass & Strychnine Creek

1/1/08 to 12/31/08

171

1669

Palouse River

Tribs



61

1544

Palouse River

Wasted Years/ Crazy Jackass to Strychnine Creek

1/1/08 to 12/31/08

79

1512

Palouse River

All

Summer


-------
480

1706

Palouse River

T42N R2W Sec 28

Aprox. 7/1 -11/5

557

1790

Palouse River & Tribs

Working Stream Bed and Bars

Jun 1 - Nov 1,2008

550

1795

Palouse River & Tribs

Stream Bed & Gravel Bars

6/1/08-11/1/08

482

1707

Palouse River Drainage

Palouse River and Tribs

Jan 1 - Dec 31

240

1504

Palouse River, N Fk

2 Mi N. of Land Park

Jun - Jul

19

1675

Palouse River, N Fk

Within Boundary of J&D Macer#1 1/4 S14 T42N R2W

Jul 1 to Oct 1

30

1636

Palouse River, N Fk

J&D Placer and J&D Placer #1 & 2 TWN 42N R2WSEC14. See
Attachment.

Apr 1 2008 to Sept 31, 2008

170

1669

Paouse River

Drainage 2 Mi North of Land Park

June to July

332

1704

Payette River

South Fork Payette River MF to Big Pine Creek

Jan 1 - Dec 31

987

2045

Payette River

Downstream from Lowman

8/08-10/1/08

355

1758

Payette River

Idaho Claim & Other Club Claims

Summer - Fall, 2008

873

1976

Payette River

Near Headwater

Ditto

197

1521

Payette River

South Foprk Payette River M.F. to Big Pike Cr

Jan 1 to Dec 31

389

1700

Payette River

S. Fk from Five Mile

7/5 - 7/31

988

2044

Payette River

Downstream from Lowman

8/08-10/1/08

200

1519

Payette River

South Fork of the Payette River in the vacinity of Gallier Creek

Intermittently Jul 1 to Sept
30, 2008

506

1828

Payette River

Not Reported

7/1 - 10/30

292

1549

Payette River

South Fork

All Year

277

1559

Payette River

Near Deer Park Cabin

Not Reported

645

1902

Payette River

Lowman Area Deadwood River to 5 miles

Jul 1 - Sept 30

280

1555

Payette River

Sawtooth to Banks. Really don't know

7/4 -8/2

893

2012

Payette River

Not Reported

Aug 1 - Dec 30

643

1903

Payette River

Lowman 2 Miles up from Idaho City

6/29 - 7/30/2008

572

1868

Payette River

North Banks to Big Payette Lake

Jul 1 to Oct 31

120

1589

Payette River

South fork of the Payette river in the vacinity of Gallier Creek

Intermittanly Jul 1 to Sept
30, 2008


-------
1712

1564

" 2011

1663

1661

1662

2069

2068

" 2070

1953

1800

2028

1951

1856

2018

1961

2027

2036

1962

1713

2040

1584

1979

" 2013

1869

1862

2047

1973

Payette River

Not Reported

Payette River

xxx? to 5 Mile River

Payette River Drainage

Not Reported

Payette River Drainage

All open area. Loman area

Payette River Drainage

All open area. Loman area

Payette River Drainage

All open area. Loman area

Payette River

M Fk

7.6 Miles out of Crouch

Payette River

M Fk

From Headwaters to It's Confluence w/ Little xxxxxx

Payette River

M Fk

7.6 Miels out of Crouch, Idaho

Payette River

S Fk

"difficult to decipher"

Payette River

S Fk

Inside the Reserved Area for Recreation

Payette River

S Fk

M Fk to Big Pine Cr of Deadwook River to Five Miles

Payette River

S Fk

Ado Cr Bridge

Payette River

S Fk

Below Pine Creek Danskin

Payette River

S Fk

Lowman Hwy- Garden Valley Mile Marker 15-16

Payette River

S Fk

Between Garden Valley and Gallagher Cr

Payette River

S Fk

[M Fk Payette to Big Pine Ck] Dead Wood River to Five Mile Ck

Payette River

S Fk

Between Danskin Cr and Alder Cr

Payette River

S Fk

1 Mi out of Garden Valley

Payette River

S Fk

Near Garden Valley

Payette River

S Fk

M Fkto Big Pine

Payette River

S Fk

Were permitted

Payette River

S Fk

2 Miles out of Lowman

Payette River

S Fk

Below Richie Cr

Payette River

S Fk

From Danskin to 5 Mile

Payette River

S Fk

Grandjean to Garden Valley

Payette River

S Fk

5 Miles N of Garden Valley

Payette River

S Fk

Lowman 20 Miles above


-------
1968

2046

2017

1865

1888

1830

1832

1878

1885

1508

1896

1773

1926

1774

1487

1885

1686

1864

1845

1500

1832

1775

1947

1870

1735

1772

1871

Payette River

S Fk

Waters Edge

Payette River

S Fk

Confluence with Deadwood R to 5 Mile Cr

Payette River

S Fk

Lowman Hwy - Garden Valley at Mile Maker 15-16

Payette River

S Fk

E of Crouch to Big Pine Creek

Payette River

S Fk

Lowman Area downstream around Deadwood River

Payette River

S Fk

E of Crouch to Big Pine Creek

Payette River

S Fk

3/4 Mile above Danskins Rest Area

Payette River

S Fk

Not Reported

Payette River

S Fk

Lowman Hwy - Mile Marker 16 - Upstream 200+ Yards

Payette River

S Fk

Lower Section above Garden Valley

Payette River

S Fk

Grimes Creek

Payette River

S Fk

Lowman Area MM 73. All Open Area

Payette River

S Fk

E of Crouch to Big Pine Cr

Payette River

S Fk

Sourth Fork Payette & Open Area, Lowman MM72V/1 - 9/30

Payette River

S Fk

Approx 5 to 6 miles up river from Garden Valley

Payette River

S Fk

Lowman Hwy - Mile Marker 16 - Other Side of Ridge 200 Yards

Payette River

S Fk

South Side

Payette River

S Fk

Mile Post 86

Payette River

S Fk

E of Crouch to Big Pine Creek

Payette River

S Fk

Thos Portions Open to the Public - Recreational Dredging

Payette River

S Fk

Below Ruins of Old CCC Camp

Payette River

S Fk

Pioneerville

Payette River

S Fk

S Fk Payette from M Fk to Big Pine Cr

Payette River

S Fk

MP86

Payette River

S Fk

S. Fk of Payette River (Garden Valley) to E. of Al Per Creek Rd.

Payette River

S Fk

Near Lowman & Other Areas Open on this Permit

Payette River

S Fk

MP86


-------
431

1762

Payette River, S Fk

Drainage Area

Jul - Aug

665

1885

Payette River, S Fk

Gorden Valley - Mile Marker 16 - Lowman Hwy & Upstream 100
Yards

7/4 - 7/11

829

1946

Payette River, S Fk

Garden Valley

Jul 1

427

1769

Payette River, S Fk

5 Miles up River from City of Grouch

Jul 1 - Sept 30

430

1766

Payette River, S Fk

Open Areas

Jul 15 - Sept 1

702

1942

Payette River, S Fk

N of Garden Valley

July - Sept

825

1938

Payette River, S Fk

Between Garden Valley & above Grouch



621

1832

Payette River, S Fk

1 1/2 Mile above Hot Springs Camp Ground

Jul 1 - Sept 30

846

1961

Payette, Main

Below Black Canyon Dam, above Emmett

Jul 15-Oct 31

828

1948

Peyette River

Pine Cr, Garden Valley

Jul - Sept

589

1854

Phi Fer Cr

S1/2 SE1/4 S27 T6N R10E (Boise Gold Claim)

When Stream Is Open

662

1887

Phifer Cr

T6N R1 OS Sect 27

Jun - Aug

728

1913

Pine Cr

By Pine Cr South Fk Payette River

Jul 15 - till end

54

1548

Pony Gulch

Behind Rocks & in Bedrock Cracks

Mar 1 to Nov 1, 2008

12

1678

Potoal Cr

3/4 mile from confluence with trail creek

May thru Oct

486

1698

Potosi Cr

T49 R4E Sec10 1/4SE & Sec2NE 1/4

Mar - Nov

755

1825

Potosi Cr

Protchard & Murray Area & St. Maries Area

Not Reported

750

1863

Potosi Cr

T49N R4ESEC11

Jun 15 - Oct 31

175

1679

Potosi Cr, Little Creeks
around Murry, ID

On various claims owned by Friba 5?(illegible)

May to Jul

771

1931

Potosi Gulch

Potosi Gulch

During Season

166

1667

Poud

Adjacent to Yaukee Fork near Bonaza, Idaho

May - Sept

796

1986

Prchard & Beaver Cr
Watersheds

49N & 50N - Townships; 3E, 4C, 5E & 6E - Ranges

From Current Time thru
Duration of Dreding Season

43

1594

Preacher Cr

Headwarters origin/Township 36N Range 6E/Sect 5 1/4 SEC
ME14

Jul 1 to Mar 31

45

1594

Preacher Cr

Section 32 Township 37 North Range 6

Jul 1 to Mar 31

989

2039

Prichard Cr

Murray Area

8/23/08 - 8/25/08


-------
100

1606

Prichard Cr

1/2 Mi E. of Murray, Lost Nugget Claim

May to Sept

188

1538

Priest River

Beaver Cr & tribs below Delta

Jan 1 to Dec 31

187

1538

Priest River

Pritchard Cr & Tribs below Granit Cr

Jun 1 to Dec 31

53

1546

Pritchard Cr

1/2 East of Murray/177 Lost Nugget Claim

All Year

22

1673

Pritchard Cr

including Oregon Gulch, George Gulch & Bednock Gulch

Snow melt to Snow Fall

385

1720

Quantz Cr

Atlanta



642

1903

Quart Cr

1 1/2 Miles out of Idaho City

6/29 - 7/30/2008

786

1957

Quarts Cr

Not Reported

Not Reported

81

1489

Quartz Cr

Orofino Creek Junction (I have a mineal lease with State of
Idaho)

7/1 to 9/30

783

1956

Quortz Cr

Blank

Blank

256

1571

Raft River

Just out of American Res

Jul 10 - Aug 10

227

1494

Raft River

Not Reported

Jul 1 - Sept10

741

1890

Red River

Red River Drainage (Red Horse Cr)

Jul 1 to Sept 30
Jul 1 to Sept 08

147

1656

Rhodes Cr

Center

7/1 - 10/1/2008

410

1776

Rhodes Cr

Center of Creek

7/1 -10/1/08 m

397

1785

Robie Cr

GPAA Island Claim

5/20/08-3/3109

715

1924

Rock Cr

NE and NW1/4 of SEC 20 T3N R7E 600'

Jul 1 - Dec 1

400

1784

Rose Ponds, The First of

Not Reported

Illegible

447

1759

S Jordan Cr

Upsteam train Williams Cr

Weather Conditional

507

1819

Salmon River

Same as Last Year. See Attached Map

6/1 - 9/30

313

1715

Salmon River

300 North of Johnday Creek, Sites: 3 Sections

May 31 - Sept 30

270

1562

Salmon River

Hammer Creek to Long Tom Bar

May 31 - Sept 30

920

2031

Salmon River

Twin Bridges to Black Hawk Rapids

Blank

508

1819

Salmon River

Same as Last Year. See Attached Map

6/1 - 9/30

407

1778

Salmon River

MP 212.0 to 212.2 - 215.7 to 215.8

5/30-10/1

309

1718

Salmon River

Both Sides 8 Middle (4 Mi East of Rigginsm ID at Island Bar) NE
Quarter of Section 13, T24N, R1E

6/1 - 9/1/08


-------
677

1878

Salmon River

Hammer Creek to Long Tome Bar

6/1 thru 9/30

181

1683

Salmon River

Hammer Cr to Long Tom Bar. Slat Creek ...? from Forest Sevice
Office

May 31 to Sept 30

315

1712

Salmon River

Mile Marker 708 1/2 West Side 300'

May 31 - Sept 30

438



Salmon River

Twin Bridges to Long Tom Bar

5/31 to 9/30/08

390

1803

Salmon River

North of Lucile Boat Landing

Jul 30 - Sept 30

391

1802

Salmon River

North of Lucile Boat Landing

Jul 20 - Sept 30

316

1712

Salmon River

Box Canyon West Side 300'

May 31 - Sept 30

29

1652

Salmon River

45* 44' 22.01" W & 116* 19' 05.59" W

May 31 - Sept 30

439

1765

Salmon River

Twin Bridges to Long tome Bar

5/31 to 9/30/08

372

1744

Salmon River

N of John Day Creek 500'

5/31/08

272

1561

Salmon River

Hammer Creek to Long Tom Bar

May 31 - Sept 30

5

1692

Salmon River

Island Bar

Mar 1 thru Sept 2008

805

1995

Salmon River

NE Quarter of Section 13, T 24 North Range 1 Est

Jul 24-Aug 30

360

1760

Salmon River

MP 212.2 to MP 212.0

6/1 /to 9/31

868

1978

Salmon River

R1ET24N Section 10

Jul 15 - Sept 30

579

1859

Salmon River

R1E Section 13T24N

Jul 1 - Sept 30, 2008

443

1764

Salmon River

Twin Bridges to Long Tom Bar

5/31 to 9/30/08

848

1962

Salmon River

Hammer Cr to Long Tom Bar

May 31 - Sept 30

6

1692

Salmon River

Lualle

Mar 1 thru Sept 2008

804

1994

Salmon River

NE Quarter of Sectjon 13 T24 North Range 1 East

Not Reported

174

1671

Salmon River

East of Riggins 3 to 5 Miles (South Side)

Jun - Oct

577

1861

Salmon River

Black Hawh Bar

Jul 2008

378

1727

Salmon River

Mile Marker 202 1/2 (See Map)

May 31 - Sept 30

183

1687

Salmon River

W1/2 NW1/4 NWSWAdj to Lots 2, 2 & 4 Sec 36 Township 27N
Range 1E near Slate Cr Settlment

Jun 1 to Sept 30

184

1540

Salmon River

Black Hwak Rapids

Nay 31 to Sept 30


-------
201

1518

Salmon River

See Maps T24N R2E SEC20, &18

May 31 to Sept 30

584

1856

Salmon River

Above Black Hawk Rapids & Slate Creek Area

May 31 - Sept 30

370

1744

Salmon River

S of Time Zone Bridge 500'

5/31/08

371

1744

Salmon River

Russel Bar 500'

5/31/08

172

1672

Salmon River

Up River above Riggins Idaho at Allison Creek

Jul 26 thru Aug

134

1582

Salmon River

See attached

5/31 to 9/30/08

111

1598

Salmon River

From 300' South of Slate Creek proceeding another 700' South
to Mile Marker 214 US Hwy95

Season, Jun 1 to Sept 31

115

1595

Salmon River

See Map #1 for Site #1 & #2



116

1595

Salmon River

See Map #2 for Site #3



111

1933

Salmon River

Open Area

5/31 - 9/30

343

1688

Salmon River

Near Challis Area

7/1/08

509

1819

Salmon River

Same as Last Year. See Attached Map

6/1 - 9/30

129

1585

Salmon River

400 Pt. below MM218 on Far Side of River across River from
Slate Creek Range Station

Jun to Sept

361

1760

Salmon River

MP 215.8 to MP 215.7

6/1 /to 9/31

133

1583

Salmon River

See attached

5/31 to 9/30/08

802

1992

Salmon River

Milepost 199 Lightning Cr200 ft below Boat Ramp. I don't
believe it is maintained, but I will stay 200 feet downstream.

May 31 - Sept 30

379

1727

Salmon River

At North Riggins (See Map)

May 31 - Sept 30

7

1692

Salmon River

Spring Bar

Mar 1 thru Sept 2008

130

1585

Salmon River

400 Pt. below MM218 on Far Side of River across River from
Slate Creek Range Station

Jun to Sept

399

1746

Salmon River

R1E Section 13T24N

6/1 - 9/30/08

334

1702

Salmon River, Main

T24N R2E SEC20, Between Mi Post 5 & 6

May 31 - Sept 30

36

1615

Salmon River, Main

Hammer Creek to Long Tom Bar



310

1717

Salmon River, Main

Hammer Cr to Long Tom Bar

May 31 - Sept 30

455

1753

Salmon/Clearwater River

See Maps

Not Reported

810

2000

Silver City? Not
Waterbody

Silver City, Idaho

Summer 2008

809

1999

Silver City? Not

Silver City, Idaho

Summer 2008


-------




Waterbody





609

1844

Sinker Cr

4 Miles out of Siver city on War Egle

Jan 1 - Dec 30

601

1847

Siver City

GPAA & Local Club Claims

Ditto

605

1846

Siver City Area

GPPA Local Club Claims Area

Ditto

504

1836

Snake River

American Falls Dam to Idaho Falls

Low Water ASAP

689

1866

Snake River

Below Confluence of Henry Fork

Dredge Season

682

1876

Snake River

Menan to Milner Dam

Jul/1 - Oct/31

684

1875

Snake River

From Menan to Milner Dam

Jul 1 to Oct 31

338

1694

Snake River

American Falls, Both Sides

4/23/08 - 3/31/09

842

1955

Snake River

By Menan

Open - Close

843

1955

Snake River

By Shelley

Open - Close

598

1848

Snake River

Pingree Blaackfoot Area

Regular Season

167

1668

Snake River

Snake River Blackfoot Golf Course Area

Jun - Nov

578

1860

Snake River

From Henry's Fork to Massacre Rocks State Park

When Possible

872

1976

Snake River

Murphy

Ditto

881

1971

Snake River

in River @ Mary's Mine

Jul 18 - End of Season

138

1643

Snake River

Tribitaru

4/1/08-3/31/09

137

1581

Snake River

Between Menan and Roberts. ANY LEGAL WATER

Aug 18, 2008

339

1693

Snake River

American Falls, Both Sides

4/23/08-12/31/09

257

1571

Snake River

1/2 Mile upstream from King Hill

Jul 1 - Jul 10 & Sept 10-
Oct 31

634

1820

Snake River

Snake River to Massacre Rocks, South Fork Boise River Pine
Braidge to Baker River & Tribs

Jul 1 - Oct 31

393

1797

Snake River

Tucker Ponds Area

6/15-10/30

658

1895

Snake River

from Idaho Falls to American Falls

Jun - Nov

1000

2073

Snake River

Pond by, SnakeRiver. South of Tilton Bridge SWxxx?. Hayden
Creek xxxx?

9/27/08 - 12/5/08


-------
285

1552

Snake River

Menan, American Falls

Oct

288

1551

Snake River

Menan, American Falls

Oct

733

1909

Snake River

American Falls to Lake Walcott

July - Aug 08

435

1745

Snake River

300 Feet Next of Boat Ramp in Roberts, ID (1500')

6/15-11/30

422

1771

Snake River

Black Foot Bridge to 1/4 Mile Downstream

Jun to Oct

892

2012

Snake River

Not Reported

Aug - Nov 30

555

1791

Snake River Drainage

Tetar River

Sept 1 - Nov 1

890

2011

Snake River Drainage

Not Reported

Aug 1 - Nov 30

300

1522

Snake River Drainage

See attached Maps

Mar 4- Dec 31, 2008

94

1608

Southfork

Puma Placer, IMC 186119, 1/4 Mi E, Junction Lodge, Hwy 14

7/25 to 8/15/08

99

1607

Southfork

Jes 2, IMC 186132 Due South from from Junction Lodge Trailer
Court, Hwy 14

7/25 to 8/15/08

97

1607

Southfork

Puma Placer, IMC 186119, 1/4 Mi E, Junction Lodge, Hwy 14

7/25 to 8/15/08

98

1607

Southfork

Jes1, IMC 183969, 1 Mi East, Junction Lodge, Hwy 14

7/25 to 8/15/08

95

1608

Southfork

Jes1, IMC 183969, 1 Mi E, Junction Lodge, Hwy 14

7/25 to 8/15/08

93

1609

Southfork

Jes 2, IMC 186132, Due South from Junction Lodge Trailer
Court, Hwy 14

7/25 to 8/15/08

92

1609

Southfork

Jes 1, IMC 183969, 1 Mi East Junction Lodge, Hwy 14

7/25 to 8/15/08

91

1609

Southfork

Puma Place, IMC 186119, 1/4 Mi E, Junction Lodge Hwy 14

7/25 to 8/15/08

96

1608

Southfork

Jes 2, IMC 186132 Due South from Junction Lodge Trailer Court,
Hwy 14

7/25 to 8/15/08

743

1889

Spokane River Drainage

Bed of Stream

Open til Close Season

68

1531

Spokane River Drainage

Prichard Creek & Tribs; Sec 17 & 30, T50, R5E E.F. Eagle
Creek.

1/1 to 12/31

484

1707

Spokane River Drainage

Where and When Open only. Pritchard Creek & Tribs

Jan 1 - Dec 31

483

1707

St Maries River

St. Maries River and Tribs

Jul 15 - Aug 15

787

1959

Tama Cr

Starting 328' Upstream from Tama Cr Confluence to approx.
2164' Upstream from Tama Cr Confluence Total Area Length
Approx. 1836'

Approx. Jul 26 - Aug 8,
2008


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487

1698

Thririd Cr

T49 R4E Sec 12

Mar - Nov

83

1492

Toboggon Cr

Lower 5280' of Cleek - Above Eagle Creek

Season 2008

40

1591

Trail Cr/ Beaver Cr,
Tributary of

200 ft East, Up Duncan Gulch from Switch back at Trail
Crrek/Gulch or Kings Pass Rd

Apr 1 - Oct 2008

177

1679

Treit Cr

On various claims owned by Friba 5?(illegible)

May to Jul

450

1755

Tributary

Salmon River from Center of Creek to High Water Mxx?

Jan 1 - Oct 31 Weekends &
Occasion Times

499

1838

Tributary Cr

Kevin Claim: T50N R5E Sec 19

7/15-8/15

35

1615

Tributary Cr

Various locations within the Idaho National Forest operating
dates during open season 2008



502

1837

Tributary Cr

Kevin Claim: T50N R5E Sect 19

7/15-8/15

757

1827

Tributary Cr

T50N R5E SEC 19 USGS... (illegible)

July 2, 2008

770

1928

Tributary Cr

Prichard/ Murray Area

Jul - Aug

746

1884

Tributary Cr

Below Water Mark. T50N R5E SEC 19

Jul 15-Aug 15, 08

148

1657

West Eagle Cr

Middle of Creek

6/1/08-7/15/08

595

1851

xxx? Cr

Milepost 20 downstream Mores Cr, GPAA/Nampa Birse? Claims

Jul 1 to Sept 30

734

1909

Yankee Fk

Private Claim above High Water Mark

Jul 08

880

1971

Yankee Fk

Private Claim

Jul 18-Jul 30, 2008


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