Appendix C Weed Management Plan

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1 Weed Management Plan

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3 C-i Contents 1.0 Introduction... C Summary of Contacts... C Plan Purpose... C Goals and Objectives... C BLM Policy... C Noxious Weed Inventory... C Weed Management... C Preventative Measures... C Treatment Methods... C Herbicide Pre-treatment... C Post-construction Herbicide Treatment... C Education... C Monitoring... C Herbicide and Pesticide Application and Handling... C Herbicide Application and Handling... C Worker Safety and Spill Reporting... C Herbicide Use... C References... C-9

4 C-ii List of Tables Table 1 Designated Noxious Weed Species within the Project Area... C-2 List of Figures Figure 1 Overview of Noxious Weed Populations... C-4

5 C Introduction Noxious weeds and other invasive plant species can occur both directly and indirectly from energy development as well as other development that causes ground disturbance. Prevention and control of noxious weeds and other invasive plant species should be incorporated into the design, layout, and construction of access roads, pipelines, and well locations as well as other facilities. Discharge points for water including reservoirs, off-channel containment structures, drainages for runoff, etc., can harbor weeds and other invasive plants. Noxious weed control practices for the proposed Riley Ridge Unit Development (Project), as described in this plan, have been developed from coordination with the U.S. Forest Service and Bureau of Land Management (BLM) technical staff and local county Weed and Pest District supervisors; the BLM s Noxious and Invasive Weed Management Plan for Oil and Gas Development Areas (BLM n.d.); existing noxious weed management plans; and experience gained from other noxious weed control programs in Colorado, Nebraska, Montana, South Dakota, North Dakota, Utah, and Wyoming. 1.1 Summary of Contacts County Weed and Pest District supervisors in Wyoming were contacted to discuss issues related to noxious weed mitigation in their counties. Information gathered during these conversations has been used to write this plan. Specifically for this plan, information was provided through telephone conversations with Weed and Pest District coordinators for Sublette County, Wyoming, on April 15, 2013 (AECOM 2013). 1.2 Plan Purpose The purpose of the plan is to prescribe methods to prevent and control the spread of noxious weeds and other invasive plant species during and following construction of the RRD Project on federal, state, and private lands. Denbury Resources, Inc. (Denbury), based in Plano, Texas, and their contractors will be responsible for implementing the methods described in this plan. This plan is applicable to the construction of the utility corridor, as well as any areas where new ground-disturbing activities will occur due to construction of the RRD Project. 1.3 Goals and Objectives The goals of weed control are to prevent new infestations of noxious weeds in and around the Project area(s); provide inventory, monitoring, and control methods for existing infestations; and provide implementation guidelines for eradicating/managing noxious weed populations, including areas that may be affected off pad. Monitoring and treatment both prior to construction and during the operational phase, as applicable, will ensure that goals are achieved. 1.4 BLM Policy BLM policy on noxious weeds and other invasive plant species management on BLM-administered public lands includes the following: An approved Pesticide Use Permit (PUP) to apply chemical herbicide. Approval and proper permitting for domestic livestock is required prior to implementing use of pesticide as a weed control method. An approved Biological Release Permit (BRP) is required for the release of biological agents. Upon completion of any pesticide application, a Pesticide Application Record (PAR) will be completed within 24 hours and kept for 10 years.

6 C-2 ALL herbicide applications on BLM-administered public lands are required to be applied by a certified commercial applicator(s). A list of approved applicators is available at the BLM Pinedale Field Office. Weed lists are available for Wyoming and Sublette County at and at the BLM Pinedale Field Office. 1.5 U.S. Forest Service Policy U.S. Forest Service policy on noxious weeds and other invasive plant species management on U.S. Forest Service-administered public lands includes the following: Herbicide applications on U.S. Forest Service -administered public lands are required to be applied according to the U.S. Forest Service 1990 Bridger-Teton National Forest Land and Resource Management Plan and other applicable plans and guidance. 2.0 Noxious Weed Inventory Noxious weeds that are known to occur in the RRD Project area, as identified by the local Weed Districts and BLM and U.S. Forest Service offices, are presented in Table 1. In 2014, field biologists from SWCA Environmental Consultants conducted field surveys for noxious weed populations located within the proposed disturbance of the RRD Project area. These surveys identified existing noxious weed infestations located within the 200-foot-wide pipeline survey corridor, ancillary facilities along proposed access roads and within filed development areas where vegetation clearing may be required, and within the proposed well pad locations. Weed locations were identified and documented via Trimble GeoXH (submeter accuracy) Global Positioning System (GPS) units. Two populations of Canada thistle (Cirsium arvense) were identified during the 2014 surveys. One of these populations (N15SB002) is located within the proposed utility corridor for the flowline and the other population (N15SB001) is located on the south side of South Piney Creek but not within the proposed flowline utility corridor (Figure 1). Additional field surveys for weeds will be conducted for any new areas of disturbance if necessary (e.g., new reroutes, additional access roads, etc.). Information collected during future noxious weed surveys (including species identified, proximity to the RRD Project area, locations of infestations, and extent of infestations) will be submitted to the jurisdictional BLM and U.S Forest Service offices and local Weed and Pest Districts. Early identification of existing infestations will help to minimize the spread of noxious weeds with the implementation of preventative measures. Table 1. Wyoming and Sublette County Designated Noxious Weed Species within and near the RRD Project area. Common Name Scientific Name Wyoming 1 County 2 Sublette Cheatgrass Bromus tectorum X Hoary cress, whitetop Cardaria draba X Hoary cress, whitetop Cardaria pubescens X Musk thistle Carduus nutans X Canada thistle Cirsium arvense X Dyers woad Isatis tinctoria X Perennial pepperweed Lepidium latifolium X 1 Wyoming Weed and Pest Council Sublette County Weed and Pest District 2015.

7 C-4 Figure 1 Overview of Noxious Weed Populations

8 3.0 Weed Management C-5 Weeds are spread by a variety of means including vehicles, construction equipment, livestock, and wildlife. Physical disturbance of the soil from pipelines, well locations, road development, and other construction, as well as soil moisture and chemical alterations from produced water discharge, will create opportunities for the introduction, infestation, and spread of noxious weeds and other invasive plant species. Implementation of preventative measures to control the spread of noxious weeds and other invasive plant species is the most cost-effective management approach. Noxious weeds other invasive plant species controls will be included in each phase of RRD Project development and will be implemented within the construction utility corridor, ancillary facilities, and field development areas associated with the RRUD Project. 3.1 Preventative Measures The following preventative measures will be used to prevent the spread of noxious weeds and other invasive plant species where ground-disturbing activities might occur during construction. Denbury will be responsible for the treatment and eradication of any weed infestation within the construction utility corridor, ancillary facilities and field development areas. The U.S. Forest Service, BLM, County Weed and Pest Districts, and associated landowners will be responsible for controlling weed infestations outside of the construction utility corridor and field development areas. The pipeline utility corridor, ancillary facilities, and field development areas will be inspected for noxious weeds by the environmental inspector (EI), Weed and Pest District, or a qualified botanist, prior to the clearing of vegetation on the utility corridor and ancillary facilities. Any infestation will be recorded via GPS for pretreatment and post-construction monitoring purposes. Noxious weeds and other invasive plant species treatments or any other preventative measures on private lands will be discussed with individual landowners. It is a common request from landowners to have all vehicles, including four-wheelers and allterrain vehicles, construction equipment, and trucks thoroughly washed prior to entry onto the permanent/pipeline easement, temporary workspace, and additional temporary workspace. Prior to being allowed access to the utility corridor, ancillary facilities, and field development areas, the EI will ensure that vehicles and equipment are free of soil and debris capable of transporting noxious weed seeds, roots, or rhizomes. Chemical pre-treatment will be used prior to ground-clearing activities, as appropriate. Pretreatment methods are discussed in Section 3.2 of this plan. Selective vegetation clearing and soil stripping methods will be used to minimize the transport of noxious weeds and other invasive plant species seeds, rhizomes, or roots from infested areas into areas where weeds are not present. The contractor will clear vegetation from the construction utility corridor and field development areas in all vegetation communities, with the exception of forested areas, shelterbelts, and saturated wetlands, where the utility corridor may be reduced in width. During the reclamation phase of the RRD Project, all areas disturbed by construction will be reseeded. The utility corridor and field development areas will be reseeded with an approved seed mixture within the proper growing season to ensure appropriate vegetative cover/species will further reduce the establishment of noxious weeds. Seed mixtures used during reclamation may vary due to requests from landowners, BLM, U.S. Forest Service, and other agencies. Draft EA

9 C-6 Denbury will verify that all straw hay bales and seed is certified noxious weed free before being used on the Project. All gravel and fill material imported on-site must be source-identified by Denbury to ensure that the originating site is noxious weed free. 3.2 Treatment Methods Depending on the existing environment, the landscape, soils, vegetation, presence of water features, and/or threatened and endangered species, several different treatment methods, or a combination of methods may be implemented. When using any of these treatment methods, Denbury will comply with the following guidelines. Cultural Method The prompt seeding and revegetation of areas of disturbed soils with certified weed-free seed. Encourage the cleaning of equipment and vehicles prior to entering or leaving each management area (pressure wash in a designated area). Minimize soil disturbance, where possible. Use certified weed-free mulch/straw for erosion control. Physical Method Mowing of weeds in newly revegetated areas during the first season of establishment, prior to seed formation of the weeds in the revegetated area. Hand pull and remove weed plants in areas where sensitive species are found and in newly seeded areas. Biological Method Use of domestic animals and approved biological agents. Note: biological agents are speciesspecific and can take up to 5 years before any results may be detected. Biological agents also require prior approval. Use of domestic livestock considers the targeted weed species and the associated management/care of livestock species/breed to be used, such as fencing, watering, and herding requirements. Use of livestock requires prior approval. Chemical Consider weed species, the site on which the herbicide will be applied, method of application, and desired result when selecting the herbicide for treatment and control of noxious/invasive weeds. Ensure selected herbicides are BLM or U.S. Forest Service approved for weed(s) that are to be controlled, and chemical label applications are followed. ALL herbicides are required to be applied by a certified commercial applicator(s). Methods used to reduce the spread and establishment of noxious weeds will be discussed with the U.S. Forest Service, BLM, landowners, and County Weed and Pest Districts. Chemical treatments will be based on species-specific and site-specific (e.g., proximity to water or wetlands, time of year) conditions and will be coordinated with the local U.S. Forest Service, BLM offices, landowners, and County Weed and Pest Districts. Aquatic Invasive Species (AIS) concerns and prevention are a recent priority of the Wyoming Game and Fish Department. In 2010 the Wyoming legislature enacted the first laws regulating AIS. Denbury will implement Wyoming Game and Fish Department guidance to comply with these new regulations. Draft EA

10 C-7 Specifically, equipment will be cleaned using high-pressure (minimum 3,000 pounds square inch) hot water (minimum 140 degrees Fahrenheit) to thoroughly remove all vegetative matter and AIS after being used for construction through stream crossings where water is evident within the channel. Furthermore, the EI will perform a visual inspection to ensure all vegetative material and AIS are removed from equipment prior to the equipment being used on this Project Herbicide Pre-treatment Prior to construction activities that disturb soil and vegetation, noxious weeds and other invasive plant species will be treated with chemical herbicides at the appropriate time (spring, summer, or fall spraying) depending on the targeted weed species. The use of herbicides that break down and de-toxify relatively rapidly is necessary to prevent adverse effects on germination and growth of reseeded species. Only approved, short-lived herbicides will be used for pre-treatment of noxious weeds. Only approved herbicides will be used to control noxious weeds near water, wetlands, and riparian areas. Pre-spraying will be conducted prior to any clearing to reduce the spread of noxious weeds and other invasive plant species by equipment used during clearing. All treatment methods will vary due to sitespecific conditions and the type of species that are encountered. Methods used to reduce the spread and establishment of noxious weeds and other invasive plant species will be discussed with landowners and County Weed and Pest Districts. Prior to the initial application of chemical herbicides on public land, a 3-year PUP will be prepared and submitted to the BLM Authorized Officer. Following herbicide application, a PAR will be submitted to the BLM and the County Weed and Pest District supervisors. Appropriate paper work will be supplied to the U.S. Forest Service Post-construction Herbicide Treatment Post-construction treatment of noxious weeds, if required, will likely require use of more persistent herbicides (upland sites that are more than 100 feet from waterbodies, wetlands, or riparian areas). As discussed in Section 3.2.1, only approved herbicides will be used to control noxious weeds near water, wetlands, and riparian areas. Supplemental seeding will be based on the criteria in the RRD Project s reclamation plan. The timing of subsequent revegetation efforts will be based on the life of the selected herbicide. In areas of dense infestation, a broader application may be used and a follow-up seeding program implemented. 3.3 Education Information regarding noxious weed identification, management, and impacts on livestock and wildlife will be provided to all RRD Project personnel. Additionally, workers will be informed of the critical importance of preventing the spread of noxious weeds and other invasive plant species in areas not infested, and controlling the proliferation of weeds already present. The importance of adhering to measures to prevent the spread of noxious weeds and other invasive plant species (e.g., not driving off the cleared utility corridor, cleaning vehicles that collect soil and plant seeds prior to entering the utility corridor and oil field development areas, and quickly identifying new infestations of noxious weeds) will be emphasized. Awareness and educational programs will include coordination and cooperation with state, county, and federal agencies. 4.0 Monitoring Denbury will be directly responsible for annually monitoring the utility corridor, ancillary facilities, and field development areas for noxious weeds for 5 years after construction is complete. Site-specific field surveys will be conducted every year to include 1) invasion or infestation sites on the utility corridor, ancillary facilities, and field development areas, as identified by local U.S. Forest Service and BLM offices, Draft EA

11 County Weed and Pest Districts, landowners, or the Project EIs prior to construction; and 2) areas previously treated for noxious weeds and other invasive plant species. C-8 Data collected during monitoring events will include the noxious weed species, location information (GPS documentation and accompanying map products), the extent of the infestation, results of previous control measures implemented (if any), and recommendations for further control (if needed). Estimates will be made for the entire problem area, comparing disturbed and adjacent areas, and include the range of species cover and density values. Denbury will consult with local weed districts and land management agencies to determine the most appropriate control measures. All noxious weeds identified within the construction corridor and development areas will be delineated via Trimble GeoXH GPS units with submeter accuracy. 5.0 Herbicide and Pesticide Application and Handling 5.1 Herbicide Application and Handling The use of herbicides will be in compliance with all federal and state laws on proper use, storage, and disposal. Prior to herbicide application, Denbury will obtain the required permits from the local U.S. Forest Service and BLM offices and County Weed and Pest District, as appropriate. The chemical application will be done by a licensed, U.S. Forest Service or BLM-approved contractor in accordance with all applicable laws and regulations. The contractor will either prove knowledge in noxious weed identification, or be accompanied by a qualified botanist to ensure that the appropriate species are treated on site. All guidelines by the U.S. Environmental Protection Agency herbicide label instructions will be strictly followed. Applications of herbicides will not be permitted when the instructions on the herbicide label indicate conditions that are not optimal. Application of herbicides will be suspended if the following conditions exist. Wind velocity exceeds 20 miles per hour. Snow or ice covers the foliage of noxious weeds and other invasive plant species. Precipitation is occurring or imminent. Vehicle-mounted sprayers (e.g., handgun, boom, and injector) will be used primarily in open areas that are readily accessible by vehicle. Hand application methods (e.g., backpack spraying) that target individual plants will be used to treat small scattered weed populations in rough terrain. Application of herbicides will follow these restrictions: boom and hand gun sprayers will not be used within 25 feet of surface water; broadcast backpack spraying will not occur within 10 horizontal feet of water; only wipe applications (or hand-directed spray using a backpack sprayer) will be allowed within 10 horizontal feet of surface water; and herbicides will not be mixed in an area where an accidental spill could enter a waterbody. Fertilizers, lime, or mulch will not be used in wetlands unless required by agencies. Herbicides will be transported to the RRD Project site with the following provisions. Concentrate will be transported only in containers in a manner that will prevent tipping or spilling and in a compartment that is isolated from food, clothing, and safety equipment. Mixing will only be conducted on-site and more than 200 feet from open or flowing water, wetlands, or other sensitive resources. Draft EA

12 C Worker Safety and Spill Reporting All herbicide contractors will obtain and have readily available copies of the appropriate Environmental Protection Agency Safety Data Sheets for the herbicides being used. Herbicide spills will be reported in accordance with all applicable laws and requirements. 5.3 Herbicide Use The use of herbicides will comply with the federal, state and county laws governing their proper use, storage, and disposal. Further, the use of herbicides will be in compliance within any limitations imposed by the Secretary of the Interior. The following is the sequence of events to be followed for using herbicides on U.S. Forest Service or BLM-administered lands. An onsite reconnaissance shall occur between the company personnel, or their contractor, and the Sublette County Weed and Pest District personnel certified in pesticide application. A treatment plan will be formulated. The primary species targeted for control on U.S. Forest Service or BLM-administered lands and private lands will include those on the Wyoming Noxious Weed list as well as specific species of concern from the designated Sublette County Weed and Pest District. Individual and habitat loss to special status plant species due to weed control measures during utility corridor maintenance will be avoided by consultation between the special status plant species jurisdictional agency and weed control specialists. The 3-year PUP form has been completed, for herbicide application, by the permit holder and submitted to the BLM certified pesticide applicator (Authorized Officer) at the appropriate office. The PUP was developed with assistance from Natrona County Weed and Pest District Supervisor Brian Connelly. The permit holder will be notified by this office of approval of the PUP and be furnished a copy of the document with any changes noted and explained. Any special conditions, such as sign posting requirements or notice to livestock grazers, will be noted. The appropriate U.S. Forest Service or BLM office will be notified at least 72 hours prior to pesticide application so that application operations can be inspected. All herbicides, both restricted use and nonrestricted use, will be applied only by personnel certified in the use of these herbicides or under the direct supervision of certified applicators (State of Wyoming Commercial Applicator s License). A PAR form will be completed within 24 hours of ceasing herbicide application. The PAR will be submitted by the permit holder to the certified U.S. Forest Service or BLM pesticide applicator and the County Weed and Pest District supervisors, within 7 days of completion of field treatment operations for the season. 6.0 References AECOM Sublette County Weed and Pest District. Personal communication with P. Swartzinski. AECOM, Fort Collins, Colorado. April 15, Bureau of Land Management (BLM). n.d. Noxious and Invasive Weed Management Plan for Oil and Gas Development Areas. Available at: WeedMgmtPlan.pdf. Accessed February 23, Draft EA

13 C-10 Sublette County Weed and Pest District, Sublette County Declared Weed List. Retrieved from Wyoming Weed and Pest Council, Wyoming Weed and Pest Control Act Designated Weed List. Retrieved from Draft EA

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