Washington County contains the northernmost reach of habitat range for the federally listed desert tortoise species found in southwestern Utah. In 2020, the Turkey Farm Road Fire burned on and adjacent to this project area. Since the fire, there has been significant cheatgrass, and Sahara mustard invasion, suppressing the native plant community. Rejuvra has demonstrated control on cheatgrass in areas with intact vegetative communities and a strong release of those species has been observed as the cheatgrass suppression is removed. Likewise, Plateau has proven to be effective in controlling Sahara mustard populations allowing for the release of desirable understory components that exist. This project will use a tank mix of rejuvra and plateau on a large scale to release the vegetative communities from the cheatgrass and Sahara mustard suppression that exists within the fire scar, as well as within the understory of adjacent plant communities that have not been burned but still have significant amounts of cheatgrass in the understory. Invasive, fine textured fuels, primarily consisting of Sahara Mustard (Brassica tournefortii Gouan) Red Brome (Bromus rubens) and Cheatgrass (Bromus tectorum), fueled a moderate to high intensity wildfire in the summer of 2020. The Turkey Farm Road fire consumed both the shrub canopy and understory vegetation. Soils within the burn are left exposed to wind, water erosion, and are now susceptible to invasion by noxious weeds and to the spread of cheatgrass and other non-native annual species. The soils within the fire area have been mapped and described as part of an official soil survey, completed by the Natural Resource Conservation Service (NRCS). The Turkey Farm Road fire has been classified as "moderately susceptible" to fire damage for the most part indicating that the soil within the burn has features that are moderately favorable for damage to occur. This rating is also directly related to burn severity, which in this case was moderate to high. Therefore, soils within the burn site could be classified as "moderately" to "highly" susceptible for damage to occur after the fire. Based on these findings, past fire history in similar areas, and visits to the burned area, protecting the watershed values and reducing the erosion potential within wildlife habitat would be a priority for the Turkey Farm Road ESR project, and this project is a follow up to treatments that didn't happen in conjunction to the original project. Additionally, containment and control of invasive, non-native species, such as cheatgrass, which may exacerbate erosion potential and fire frequency and severity that would further degrade habitat is also a very high priority. For these reasons we feel it is necessary to spray the herbicide rejuvra onto this site to help with cheatgrass infestations that have already begun and allow the native vegetation to have the competitive advantage. Specifically the proposal is to treat the remainder of the polygon within the fire scar that was mapped out during the last phase of this treatment, but was not treated due to increased cost in the chemicals as well as application of the chemicals due to inflation. This is an area that burned in the turkey farm fire and has shown good recovery, with native vegetation well on its way to re-establishing. Early evidence of cheatgrass and red brome re-introduction is also there and we desire to decrease its competition with the recovering native vegetation.

Restore native vegetation in T & E critical habitats. Maintain heathy ecosystems by rehabilitating habitats altered by fire. Reduce risk of non-native invasive species establishment. Release re-establishing native vegetation from competition from Sahara mustard cheatgrass and red brome. Remove cheatgrass and redbrome from intact native vegetation and reduce likelihood of future fires thereby protecting desert tortoise habitat. Reduce sedimentation and erosion by restoring a proper functioning Mohave Desert Plant community.

If nothing is done to restore the habitat to optimal conditions there is risk that the habitat may become less desirable for the federally listed species and may possibly even become no longer be suitable. If this occurs further decline of the species is expected, and all efforts to avoid this decline in the species should be taken. Cheatgrass has high probability of returning and re-establishing before other plant species due to the nature of this annual grass. As this happens, other plant species struggle to re-establish, especially native plant species that are the most desirable in these Mohave Desert systems. When this happens the landscapes become dominated by cheatgrass, which is a fine fuel that is annually primed for increased fire intervals. If the area is not rehabilitated with the application of rejuvra or another cheatgrass control, it is expected that a pattern of more fires similar to the Turkey Farm Road Fire will continue to occur within the area. This will in turn result in additional soil loss due to runoff during storm events post fire. This silt and soil loss ends up in the Virgin River and has negative impacts the protected and endangered fish species. By controlling cheatgrass and the resulting fire cycles, we are in turn helping to protect and preserve future disturbances to the River System in which these fish live. Mojave Desert Tortoise are listed as threatened under the ESA and the biggest threat to their habitat is fire. Reduction of the return intervals of fire due to the increase of invasives like red brome and cheatgrass is critical to protecting Desert Tortoise and their habitat. It is important to learn how to rehabilitate burned areas to break that fire cycle as well as to protect unburned areas from moving into that cycle of increased frequency of fires. During the most recent HCAC meeting we discussed with the body of people in attendance the benefits of the new chemicals on the market for treating cheatgrass invasion and protecting these habitats from future fire events. This group received this information very well and a new collaborative effort was formed to begin treating these areas. This project is necessary to show that there is an effort being made by the TNC and others to treat these areas of high importance and put protective measures in place to preserve the critical Desert Tortoise habitats. A plan is currently being scripted by a collaboration of professionals that were organized after the HCAC meeting and this group has been tasked with creating a 5-year and a 10-year plan to treat these areas. Prioritization of the highest valued areas is taking place and it is anticipated that a project of this type and variety is to be expected for many years in an attempt to treat and prevent future fire events from the devastating effects that they can and do have on Desert Tortoise habitats. For these reasons, we are asking for your support in funding this project in order to continue to strengthen then newly formed partnerships with BLM, UDWR, TNC, SITLA, Washington County, and Red Cliffs Reserve.

This action is consistent with the following land use plans and the Normal Year Fire Management Plan. LUP Name: Red Cliffs National Conservation Area Record of Decision and Approved Resource Management Plan (ROD/RMP). Date Approved December 2016. Other relevant Plans and associated NEPA analyses (copies available at BLM's St. George Field Office): Dixie Resource Area Draft Resource Management Plan and Draft Environmental Impact Statement; Oct. 1995, Dixie Resource Area Proposed Resource Management Plan and Final Environmental Impact Statement; Sept. 1998, Vegetation Treatment on BLM Lands in Thirteen Western States/FEIS; May, 1991 and associated ROD July, 1991 Vegetation PEIS ROD 2007 The Proposed Action is in conformance with the approved Red Cliffs National Conservation Area RMP/ROD because it is specifically provided for in the following management decisions: 6.6 Native Vegetation Communities Goal- Biodiversity, ecological integrity, and ecosystem resilience are conserved, protected, and restored in the unique native vegetation communities created by the convergence of the Mojave Desert, Great Basin, and Colorado Plateau ecoregions. VEG-4: Implement landscape-level fuel breaks and hazard fuel reduction projects in partnership with adjacent federal and state land managing agencies. VEG-5: Design fuel breaks and hazard fuel reduction projects to conserve and protect unburned native vegetation communities, evaluating factors such as vegetation types, seasonal wind direction, and expected fire behavior in project planning. VEG-6: Design fuel breaks to incorporate topographic features, water courses, major ephemeral drainages, road networks, and utility corridors, to minimize new surface disturbances and the loss of native vegetation. VEG-7: Design fuel breaks and hazard fuel reduction projects to utilize those methods that are environmentally sensitive and minimize new surface disturbances. VEG-9: Authorize the use of biological controls, targeted grazing, flaming, hand removal, herbicides, mechanical methods, or a combination of methods to develop fuel breaks and hazard fuel reduction projects (see Table 3 for descriptions of each method).* The project addresses threats to key habitats identified in the Utah Wildlife Action Plan as follows: a. Key Habitat- Aquatic Forested- Continuing the use of appropriate methods for reducing the spread and dominance of invasive weeds b. Key Habitat- Aquatic Shrub/Scrub- Continuing the use of appropriate methods for reducing the spread and dominance of invasive weeds c. Fire/Invasive Nonnative Plant Species- Conservation Action- Conduct upland vegetation treatments to restore characteristic upland vegetation, and reduce uncharacteristic fuel types and loadings. -Conduct riparian vegetation treatments to restore characteristic riparian vegetation, and reduce uncharacteristic fuel types and loadings. -Conduct post-fire rehabilitation, and control invasive Non Native Plant Species-

Cheatgrass is known for its frequent fire cycles, and by slowing the spread of this invasive grass, you lessen the chance of a fire happening in this area. This project will reduce the risk of a wildfire. This project is an FRCC class 2 currently and by treating with the prescribed methods, we are hoping that it will move towards a FRCC class 1. This project is also going to protect several values at risk in the area including but not limited to the WUI interface with the adjacent community of Washington City transmission lines and infrastructure that runs around and through this corridor, as well as critical desert tortoise habitat protected through the Red Cliffs Desert Tortoise Reserve.

This project is located in the Upper Virgin River drainage where the natural flow of water runs through the town of St. George, Utah and eventually to Lake Mead, Nevada. This restoration project will stabilize the topsoil, prevent erosion and soil loss, and reduce negative water quality effects of the Virgin River due to silting and erosion. Establishing and supporting a healthy plant community is critical to reduce erosion and protect the Upper Virgin River Basin, and will, with a normal water absorption rate and normal precipitation in the area, serve to recharge the aquifer in a very arid desert location. These water systems are prone to flash floods during precipitation events and burned areas contribute significantly to sedimentation in these flash events. Re-establishing and/or protecting areas of unburned habitat will help mitigate the sedimentation and erosion during these flash flood events.

Treatment will be occurring exclusively on state owned lands. There is also no ground disturbing activities planned. As such, there is no NEPA or Archeology component required prior to implementation. Rejuvra, which initially was marketed as Esplanade, was rebranded as Rejuvra due to a label change allowing for use in grazed areas making it available for a more broad use. This project will adhere to all chemical label recommendations for the soil type and the zone that it is being applied in.

We plan to contract the application of the chemical to the site by means of helicopter application. DWR will contract with a company to purchase the chemical and apply it at the rate of 7oz in 7 gallons for the rejuvra and 6oz in 7 gallons of plateau per acre to control the cheatgrass, red brome, and Sahara mustard outbreak within the treatment area. It is anticipated that the application will take place after December 10th when the Desert Tortoise have burrowed for the winter so as to not negatively effect them during the chemical application process. The contractor who is hired will be given the latitude after that date to apply the chemical on the front edge of a storm system so as to maximize the effectiveness of the chemicals being used. By removing the cheatgrass and annual mustard from the plant community we feel like we will encourage a plant community that will lend itself to more use by species like Mule Deer and Desert Cottontail Rabbit. We have seen these specific species in the area in the past and feel like this work will help their life cycle immediately by allowing more palatable forage to grow in the area as well as in the long run break the fire frequency cycle that has been occurring in the area allowing for this area and the surrounding area to keep serving these species needs into the future.

This treatment will be monitored each year for five years (2024-2028) and an annual monitoring summary report will be completed by early September each year. A number monitoring studies in conjunction with the BLM adjacent will be established.

Extensive discussions have occurred with multiple partners in regards to this project. We have worked with SITLA on a similar project where we applied rejuvra on an unburned state section at T-Bone Mesa during the turkey farm fire rehab and seek to continue that partnership with protecting these other unburned or re-establishing state lands. We have also discussed the use of the same idea on BLM lands with BLM staff and while they are not yet authorized to conduct similar treatments, however they are excited about its use on state lands and are working toward authorization on BLM owned lands. Finally, Washington County has also been a good partner. They have been treating transmission corridors, trails, roads, and other right of ways in similar ways to protect from the risk of fires starting on these corridors and have committed money towards this project as well.

The decision of the RMP for the purpose of the Red Cliffs NCA is the following: To conserve, protect, and enhance for the benefit and enjoyment of present and future generations the ecological, scenic, wildlife, recreational, cultural, historical, natural, educational, and scientific resources of the National Conservation Area; and to protect each species that is located in the National Conservation Area; and listed as a threatened or endangered species on the list of threatened species or the list of endangered species published under... the Endangered Species Act of 1973. (OPLMA Section 1974 (a)) These are the goals and guides for the management of this areas presently and for the foreseeable future. Specifically, the NCA will be managed to enhance habitat for the desert tortoise. Promoting vegetation that is beneficial to provide forage and cover for this species is way management practice to accomplish this goal. Also establishing fire resistant and resilient plant species will help in the purpose of the Red Cliffs NCA. This is the management plan for the Red Cliffs NCA, and these SITLA and State Owned Lands are managed for the most part under the same management plan, with the exception that they are more flexible on the practices that are allowable and as such this is why we are able to use Rejuvra on these lands were they are currently prohibited on the Federal BLM lands that are part of the Red Cliffs NCA.

The uses for this area are the following: To be a reserve for wildlife particularly for the threatened desert tortoise. To preserve cultural/historic sites. Also it is recreational area for public use with a trail system for biking, hiking, and horse back riding. As range land the area serves as a watershed resources when vegetation conditions are healthy and functioning. When soil erosion is mitigated and water from precipitation infiltrate's soil the range land is functioning properly.