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LAND EXCHANGE FEASIBILITY ANALYSIS Red Cliffs/Long Valley Land Exchange

UTU-88966FD/PT

I. INTRODUCTION/BACKGROUND INFORMATION The U.S. Fish and Wildlife Service (FWS) listed the Mojave population of the desert tortoise (Gopherus agassizii), located north and west of the Colorado River, as a threatened species in 1990 under the Federal Endangered Species Act (ESA). In 1994, the FWS designated 129,100 acres of critical habitat for the desert tortoise in Washington County, Utah. At that time, growth and development on private lands in the county were resulting in the “take” of individual tortoises and the loss of critical habitat. In order to resume development, Washington County applied for an Incidental Take Permit (ITP) and began preparation of a multi-species Habitat Conservation Plan (HCP), in support of the ITP. The key mitigation component of the HCP was to be the long-term management of an approximately 62,000-acre multi-jurisdictional (Federal, State, municipal, and private lands) reserve, which came to be called the Red Cliffs Desert Reserve (Reserve), directly north of St. George, Utah. At the time the Reserve was being established, approximately 2/3 of the proposed Reserve was administered by the Bureau of Land Management (BLM) or Utah State Parks & Recreation, and the remaining 1/3 was owned by private parties and the Utah State School and Institutional Trust Lands Administration (SITLA). As a result of the large amount of private and SITLA lands within the Reserve, acquisition of these lands was identified as one of the most challenging provisions of the HCP. Land acquisition within the Reserve was to be predicated upon the willing buyer/willing seller principal (Washington County, Utah Desert Tortoise ITP Application/Documents Part II, Dec. 1995, p. 23). It was acknowledged during the application phase of the Reserve that success of the HCP would likely be contingent upon the acquisition of the private and SITLA lands within the Reserve. In 1996, the FWS formally approved Washington County’s HCP and its ITP, authorizing the “taking” of an estimated 1,169 tortoises and 12,264 acres of habitat on private lands, and establishing the Reserve. The HCP is administered by the Washington County Commission. A Habitat Conservation Advisory Committee, comprised of representatives from BLM, FWS, Utah Division of Wildlife Resources (UDWR), environmental groups, and other interested parties, oversees administration of the HCP and serves in an advisory capacity to the Washington County Commission. The BLM also participates on the Technical and Education Committees. The BLM is one of three principal land managers in the reserve and is involved in signing, law enforcement, and managing compatible recreation and other activities in the Reserve. As envisioned during the establishment of the HCP, most of the Reserve was given National Conservation Area (NCA) status with the passage of Subtitle O of the Omnibus Public Land Management Act of 2009 (16 U.S.C. 7202, Public Law (PL) 111-11). PL 111-11 designated approximately 45,000 acres of the original 62,000-acre Reserve as an NCA, to be administered by the BLM’s St. George Field Office (SGFO), for the purpose of conserving, protecting, and enhancing its ecological, scenic, wildlife, recreational, cultural, historical, natural, educational,

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and scientific resources, with a particular emphasis on threatened and endangered species. Approximately 19,989 acres of the NCA are included within two Wilderness areas, the Red Mountain Wilderness and Cottonwood Canyon Wilderness, also designated through P.L. 111-11 and managed by the BLM. The BLM made a commitment to participate in the implementation of the HCP and “work to gain title” from SITLA and willing sellers of private lands within the Reserve. This commitment is memorialized in the HCP’s Final Implementation Agreement (December, 1995) as well as the St. George Field Office Record of Decision and Resource Management Plan, approved March 15, 1999. Environmental Land Technologies (ELT) owned the largest tract of private land within the Reserve (approximately 1,341 acres) up until Jim Doyle, principle owner of ELT, filed for bankruptcy in 2004. After the bankruptcy proceedings were finalized, much of the ELT property was distributed to creditors with Brennan Holdings LLC, owned by Robert Brennan (Brennan), receiving 821.59 acres, His Family Matters, LLC receiving 153.29 acres, and SITLA receiving 92 acres. ELT retained 274.17 acres of the original acreage. Brennan has been actively pursuing a land exchange with the BLM since 2010 when he acquired title to the property as a result of the ELT bankruptcy settlement. Brennan is a developer by trade and is highly motivated to enter into an exchange with the BLM so that he can acquire developable property outside the Reserve. Development of his private land within the Reserve would be difficult and costly, as it is designated critical habitat and supports populations of Mojave desert tortoise, a threatened species. To comply with Section 9 of the ESA, Brennan would be required to submit an HCP for approval to the FWS and be approved for an ITP. As of 2015, the BLM has acquired approximately 6,531.42 acres of inholdings within the Reserve through purchase, donation, and exchange. Land and Water Conservation Fund (LWCF) appropriations totaling $19,400,000 have been utilized to acquire lands within the Reserve. The BLM has continued to work towards acquisition of the remaining private inholdings within the Reserve but efforts to acquire the inholdings have been hampered by extremely high property values. Every possible avenue available to acquire land has been explored to acquire the remaining private land inholdings. The BLM and Washington County entered into a Memorandum of Understanding (MOU) in May 2014 for the purpose of working together to acquire the remaining Brennan acreage through exchange and possible donation. The County agreed to facilitate the exchange by contributing funding towards the processing costs of the exchange, and to work with Brennan on a separate agreement to acquire additional acreage through donation, concurrently with this exchange action. The MOU identified seven parcels for consideration for exchange. However, recently completed biological and cultural inventories funded by Washington County resulted in the elimination of all but two of the parcels from further consideration. This exchange proposal involves only one of the two parcels because it is expected to be the most feasible to accomplish within a reasonable timeframe.

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II. EXCHANGE PROPOSAL

The exchange would be between the BLM and Brennan, with Washington County acting as facilitator. The exchange involves one parcel of Federal land totaling 604.35 acres and one parcel of non-Federal land that is a part of the larger 788-acre parcel owned by Brennan. The specific amount of non-Federal acreage to be acquired will be that amount determined to be equivalent to the appraised value of the Federal land. Exhibits A and B provide specific information on the Federal and non-Federal parcels, including encumbrances and parcel maps. Exhibit C is a map showing the general vicinity of the exchange parcels.

A. Federal Land

1. Legal Description: The Federal parcel is described as follows:

Salt Lake Meridian, Utah T. 42 S., R. 14 W.

Sec. 20, lots 13 and 14; Sec. 29, lots 2, 4, 5, 7, 9, 12, 14, and 15, NE1/4NW1/4, SW1/4NW1/4; Sec. 30, lots 13, 16, 18, 19, 22, 24, and 25, NE1/4SE1/4; Sec. 31, lots 14, 15, 18, 20, and 22, NW1/4NE1/4.

The areas described above aggregate 605.61 acres.

2. Interests to be Reserved/Conveyed: BLM would convey both the surface and mineral estate to avoid the creation of split estate, in conformance with BLM policy. The United States would reserve a right-of-way for ditches and canals.

3. Encumbrances: Encumbrances include a power transmission line, an access road to the Southern Parkway, a borrow pit, and a grazing permit. The borrow pit is being utilized on a temporary basis in connection with the construction of the Southern Parkway, and this right-of-use will expire in August 2017. While the Southern Parkway forms the north and west boundary of the parcel, an interchange/off-ramp would be located on the northern portion of the parcel if constructed.

4. Cadastral Survey Needs: A cadastral survey of this parcel was completed by the

BLM and approved on September 30, 2014. 5. Method of Conveyance: The Federal parcel would be conveyed to Brennan

Holdings LLC by patent. 6. Segregation Date and Effect: The Federal parcel was segregated from the public

land laws and mineral laws on April 8, 2015.

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B. Non-Federal Land: 1. Legal Description: The non-Federal land to be acquired is a portion of the 788-acre

parcel owned by Brennan within the Reserve, located within Sections 8, 9, 16, and 17 in T. 42 S., R. 15 W., Salt Lake Meridian. The amount of acreage to be acquired will be determined based on the appraised value of the Federal parcel. The acreage to be acquired would originate at the northern end of the parcel, contiguous to a 33.6-acre parcel recently acquired by the United States, and then extend southward.

2. Interests to be Reserved/Conveyed: Only the surface estate would be conveyed; the mineral estate was previously reserved by the State of Utah. No interests would be reserved by Brennan.

3. Encumbrances/Title Issues: Authorized encumbrances on the 788-acre parcel

include a water pipeline, a transmission line, and two access road easements. The two easements were created to provide legal access, and neither road has been constructed. The title evidence for the 788-acre parcel has been reviewed twice in connection with prior purchase and donation actions, and there are no title issues.

4. Survey Needs: The final parcel configuration will be determined through a survey.

The appraiser will be asked to identify the amount of acreage to be acquired based on the equivalent value of the Federal parcel, and the survey will be completed immediately following the appraisal.

5. Method of Conveyance: Title will be conveyed by Brennan to the United States by

a warranty deed. The warranty deed will be prepared by the BLM and the exchange transaction will be handled through an escrow account with Southern Utah Title Company. The details of closing are outlined in the Agreement to Initiate an Exchange.

6. Relocation Needs: There are no known tenants occupying the property or

outstanding leases that would entitle individuals or corporations to relocation benefits.

III. GENERAL DESCRIPTION AND ANTICIPATED LAND USE

The Federal and non-Federal parcels are located within Washington County, Utah. The largest population center for Washington County is the City of St. George; other adjacent communities include Washington City, Hurricane, Santa Clara and Ivins. Until the recent economic downturn, Washington County had been one of the fastest growing retirement and recreational areas in the nation.

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Federal Parcel: The Federal parcel is located in Long Valley, approximately one and one-half miles from the new St. George Airport, six miles east of the City of St. George, and just outside of the city limits of the City of Washington, in unincorporated Washington County. Although the parcel is currently unincorporated, the property is identified as part of the General Plan of Washington City as an area eventually to be annexed into the City of Washington. The parcel is currently zoned as Open Space Conservation – 20 Acre Minimum. It is also worth noting that the Washington County Water Conservancy District is proposing to build a reservoir on BLM-administered land just east of the subject property within Warner Valley. The parcel is situated between Washington Dome and Warner Ridge which are prominent geological formations in the area. A dry wash generally bisects the property following the natural sloping terrain toward the Virgin River to the northeast. A portion of the natural drainage flows to the southwest near the southern portion of the parcel. Elevation ranges from approximately 2,800 feet above sea level near the center of the site to near 3,466 feet above sea level near the southeast corner along Warner Ridge. The parcel is generally moderate to rolling topography near the middle and western portion of the site, with steep sloping hillside terrain along the east boundary of the property along Warner Ridge. The north and west parcel boundary aligns with the edge of the right-of-way authorized to the Federal Highway Administration in 2010 for the Southern Parkway, which is currently under construction and expected to be completed by the end of 2015. There is at least one interchange that will provide access to the parcel and make the area highly accessible from the Cities of St. George and Hurricane. There has been discussion about the construction of an additional interchange near the southwest corner of the parcel which would benefit future development of the parcel. Neither interchange would be funded by the Utah Department of Transportation (UDOT) and would likely be the responsibility of the surrounding property owners and Washington City. An unpaved secondary road bisects the parcel in a southwest-northeast direction, with two-track spur roads intersecting with the secondary road. The parcel is surrounded by BLM-administered land and some SITLA land. The parcel is within the Sand Mountain Special Recreation Management Area (SRMA) and just north of the Warner Ridge/Fort Pearce Area of Critical Environmental Concern. Improvements on the parcel include a 69 kV power line crossing through the center of the parcel, and a Washington City road right-of-way from the Southern Parkway which benefits the parcel by providing immediate access from the north connecting to Washington Dam Road and the Southern Parkway. A 10-inch water line is located approximately 700 feet north of the parcel. If conveyed into private ownership, it is likely this parcel would be rezoned for master planned residential development. Non-Federal Parcel: The parcel is located just east of the Middleton Bench, approximately one-half mile east of Cottonwood Road and adjacent to the Green Springs master planned community to the east. The southern portion of the parcel is within city limits of St. George while the northern portion is in unincorporated area of Washington County, Utah. The parcel is zoned as Open Space. The 788-acre parcel has improved access points from the east within the Green Springs area and from the south within the Middleton area. The parcel has undulating terrain with a mixture of moderate to gradually sloping terrain.

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If acquired, the parcel would be managed by BLM pursuant to the Congressionally-identified purposes of the Red Cliffs NCA to conserve, protect, and enhance the land for the benefit and enjoyment of present and future generations the ecological, scenic, wildlife, recreational, cultural, historical, natural, educational, and scientific resources, and to protect all species listed under the ESA. The BLM is in the process of developing a Resource Management Plan (RMP) specific to the NCA and land acquired would be managed in accordance with the approved NCA RMP, once it is approved. PL 111-11 withdrew Federal lands in the NCA from all forms of entry, appropriation, and disposal under the public land laws, location, entry, and patenting under the mining laws, and from operation of the mineral leasing, mineral materials, and geothermal leasing laws, subject to valid existing rights. Any lands or interests subsequently acquired by the United States in the NCA are automatically withdrawn from operation of the applicable laws.

IV. CONSISTENCY WITH LAND USE PLANS AND LEGISLATIVE DESIGNATIONS

The Federal and non-Federal parcels are within the area administered by the BLM’s St. George Field Office (SGFO) and are managed consistent with the decisions outlined in the SGFO Record of Decision and RMP, approved March 15, 1999, as amended. When a Record of Decision has been signed for the Red Cliffs NCA RMP, management of public lands in the NCA will be in conformance with that land use plan. The following RMP decisions apply in general to land ownership changes:

LD-02 (p. 2.1): Land ownership changes will be considered on lands not specifically identified in this plan for disposal or acquisition if the changes are in accordance with resource management objectives and other Plan decisions and will accomplish one or more of the following criteria:

A) Such changes are determined to be in the public interest and will accommodate the needs of local and state governments, including needs for the economy, public purposes, and community growth.

B) Such changes result in a net gain of important and manageable resources on public lands such as crucial wildlife habitat, significant cultural sites, quality riparian areas, live water, listed species habitat, or areas key to productive ecosystems.

C) Such changes ensure public access to lands in areas where access is needed and cannot otherwise be obtained.

D) Such changes promote more effective management and meet essential resource objectives through land ownership consolidation.

E) Such changes result in acquisition of lands which serve regional or national priorities identified in applicable policy directives.

If the above criteria are not met, proposed land ownership changes outside of designated transfer areas will not be approved or will require a plan amendment.

The proposed exchange would meet all of the above criteria except for C).

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LD-05 (p. 2.2): Over the life of the Plan, it is expected that BLM may acquire up to 18,000 acres of land within Washington County. Nearly all of these acres will result from BLM’s fulfilling its commitment to acquire available state and private lands within the Washington County HCP… A pool of 30,030 acres of non-federal lands, which may meet the criteria listed in LD-02, is shown on Map 2.1 for potential acquisition as opportunities arise to help meet objectives for resource management descried elsewhere in this Plan.

The non-Federal parcel is identified for acquisition on Map 2.1. LD-06 (p. 2.2): Over the life of the Plan, it is expected that up to 18,000 acres of public lands may be transferred out of public ownership in Washington County. Most of these transfers will occur as a result of land exchanges needed to complete acquisition of state and private lands within the Washington County HCP Reserve.

Based on LR2000 data, a total of 7,239 acres have been disposed, mostly through exchange, since approval of the RMP.

FW-02 (p. 2.24): Consistent with other priorities, BLM will consolidate blocks of public lands resulting in improved habitat management capability. Such will occur in key habitat areas for listed species and other important wildlife populations including, but not limited to, lands within the Washington County Habitat Conservation Plan (HCP) Reserve. RC-20(e) (p.2.42): Generally, lands within the [Sand Mountain] SRMA not already identified in the RMP for disposal will be maintained in public ownership to provide long-term stability to user groups such as the OHV community who, as a result of urbanization and land use restrictions, have lost much of their traditional open use areas. As discussed in more detail under Sec. VI. C., the Federal parcel is located within the SRMA; however, it is not within the designated open use area that would be of primary concern to the OHV community. Motorized use on this parcel is restricted to existing roads and trails, and due to its location and physical features, is not heavily used for recreational purposes.

The Office of the Solicitor was asked to provide an opinion on this provision and concluded that that transfer of the identified lands from the Sand Hollow SRMA as part of a land exchange for certain private lands within the Reserve would be in conformance with the RMP - if the underlying BLM analysis adequately substantiates that the transfer would satisfy one or more of the criteria in RMP decision LD-02 (and thereby also satisfy decision LD-06). He interpreted the term "Generally" at the beginning of decision RC-20(e) to state a presumption in favor of retaining the lands within the SRMA as public lands, while recognizing that it is within BLM's discretion, based on the specific facts involved in each particular circumstance, to determine whether the public interest is served by retaining or transferring the subject lands. Therefore, a transfer of SRMA lands would be in conformance with decision RC-20(e) if, as mentioned above, the underlying BLM analysis adequately substantiates that the transfer would satisfy one or more of the criteria in RMP decision LD-02. See Solicitor communication in Exhibit D. Completion of this exchange would further the goals of the HCP and the FWS Desert Tortoise (Mojave Population) Recovery Plan (1994, revised 2011) by protecting designated critical

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tortoise habitat and populations within the Upper Virgin River Recovery Unit, considered to be the most at risk recovery unit because of its small size and proximity to urban growth areas in the St. George Basin.

V. ALTERNATIVES TO LAND EXCHANGE

The BLM has pursued a variety of different land acquisition strategies in an effort to complete the acquisition of the remaining private and SITLA lands within the Reserve, however high property values have significantly limited progress. PL 111-11 provides for the revenue generated from land sales in Washington County to be made available for the purchase of land within two NCAs and all Wilderness units designated through PL 111-11. The BLM offered six Federal parcels for competitive sale in October 2014, resulting in the sale of two parcels valued at $822,500. The BLM is in the process of purchasing acreage from other landowners in the Reserve/NCA with these proceeds. The BLM continues to submit LWCF funding requests to acquire lands within the Reserve. In FY2013 LWCF funds in the amount of $4,000,000 were allocated for private land acquisition, resulting in the acquisition of two parcels totaling 28.64 acres, based on fair market values. However, in conjunction with these purchases, two parcels totaling 14.325 acres were donated to the United States by the landowners, one of whom was Brennan. BLM will continue to request LWCF funding, however, acquisition of the more than 1,250 acres of remaining private land will also require the use of land exchanges to complete the land acquisition objectives for the Reserve.

VI. PRELIMINARY REVIEW OF RESOURCES

Below is a preliminary assessment of the resources and uses associated with both the Federal and non-Federal parcels, based on information currently available to the BLM. The BLM will prepare an appropriate level of analysis to comply with the National Environmental Policy Act, complete the necessary site inventories, and coordinate with other Federal, State and local agencies, Indian Tribes, and interested parties as applicable to determine if completing the exchange would meet the public interest criteria outlined in the Federal Land Policy and Management Act and the implementing regulations under 43 CFR Part 2200.

A. Threatened and Endangered Species: Federal Parcel: In June 2013, BLM and HCP biologists completed an inventory of the Federal parcel, which at the time encompassed over 800 acres. The inventory found a population of seven Mojave desert tortoises in the southern portion of the parcel and some signs that tortoises may have been present in the northern portion of the parcel. The SGFO RMP (Decision FW-13) provides for the disposal of habitat that supports federally-listed animal species, if the exchange or transfer will result in the acquisition of

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better quality habitat for the same species. The non-Federal parcel in the Reserve provides better quality designated critical habitat for the desert tortoise, so the proposed exchange would be in conformance with the RMP decision. The dwarf bearclaw poppy (Arctomenon humulis), a federally-listed endangered native plant species, was also found along the parcel’s southwestern edge. As a result of the inventories, approximately 200 acres of poppy habitat were removed from the parcel, as the disposal of habitat for federally listed native plant species would not be in conformance with the SGFO RMP (Decision VG-08) unless exchange or transfer would result in the acquisition of better habitat for the same species. The non-Federal parcel to be acquired in the Reserve does not support habitat for the dwarf bearclaw poppy. The FWS has been involved throughout the inventory process and is supportive of the exchange of this parcel. The BLM plans to complete a follow-up survey on the northern portion of the parcel to confirm there are no tortoises present prior to completion of the exchange. A biological assessment will be prepared and formal consultation with FWS under Section 6 of the ESA will be completed. Because the exchange would lead to the acquisition of designated critical desert tortoise habitat which will be managed to promote species recovery and preservation, this exchange would benefit the recovery and delisting of the Mojave desert tortoise in the Upper Virgin River Recovery Unit.

Non-Federal Parcel: When the Reserve was established, it was divided into 5 zones based on management goals. The 788 acre non-Federal parcel is located in Zone 3 of the Reserve and has been estimated to potentially provide habitat for as many as 36 tortoises, based on biannual monitoring studies completed by UDWR. Were development to occur on this parcel, it would fragment designated critical habitat within a core area of the Reserve that supports high concentrations of tortoises.

B. Fish and Wildlife: Federal Parcel: The parcel provides habitat to general wildlife species including small mammals, reptiles and birds. The more common species include badgers, antelope ground squirrels, kangaroo rats, deer mice, desert wood rats, Gambel’s quail, mourning doves, common ravens, wrens, house finches, lizards, and Western whiptails. Disposal of this parcel could result in the displacement of these species if the parcel is developed.

Non-Federal Parcel: This parcel contains many of the species listed above in addition to several species of conservation concern such as the BLM Sensitive Gila Monster, Chuckawalla, Banded Gecko and Kit Fox. Acquisition of the property would benefit all wildlife, as the lands would be managed consistent with habitat protection goals of the HCP and the Congressionally-defined purposes for the NCA.

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C. Recreation/Visual Resource Management: Federal Parcel: The Federal parcel is located within the Sand Mountain SRMA and adjacent to Sand Hollow Reservoir and State Park and the Sand Hollow Resort and Golf Course. The SRMA was designated in the RMP and encompasses 40,725 acres of BLM-administered land. The main attractions listed in the RMP for the SRMA are the Dinosaur Trackway, Fort Pearce Historic Site, Historic Trails, Sand Dune OHV Riding, and the Warner Valley Road. The primary recreation activity within the SRMA is motorized recreation which occurs in the Sand Mountain Open Off-Highway Vehicle (OHV) Area encompassing 21,486 acres. The Federal parcel is in the northwestern portion of the SRMA, outside of the Sand Mountain Open OHV Area, and motorized use in this area is restricted to existing road and trails (see Exhibit E). The Federal parcel amounts to approximately 1.5% of the total Federal acreage within the SRMA. Disposal of the Federal parcel is not expected to change the current use in the SRMA. The parcel is classified under BLM’s Visual Resource Management (VRM) guidelines as Class III. The objective of VRM Class III is to partially retain the existing character of the landscape. The level of change to the landscape can be moderate, and management activities may attract attention, but should not dominate the view of the casual observer. Non-Federal Parcel: Acquisition of this parcel may increase hiking and biking opportunities slightly; however OHV users will not have access. The public lands adjacent to this parcel are managed under VRM Class III in the 1999 SGFO RMP and acquired lands would be managed under that VRM class until such time as the new NCA RMP is approved. The objectives of Class III management are described above. Management alternatives in the new NCA RMP related to VRM propose to designate the adjacent public lands as VRM Class II, to conserve and protect the scenic qualities of the NCA, as this is one of the stated purposes for which the NCA was Congressionally-designated. The objective of VRM Class II is to retain the existing character of the landscape. Level of change to the landscape should be low, and changes should repeat the basic elements found in the natural features of the landscape – form, line, color, and texture. Management activities may be seen, but should not attract the attention of the casual observer.

D. Cultural/Archeological/Paleontological Resources:

Federal Parcel: Class III inventories have been conducted on the entire parcel, in compliance with Section 106 §800.4 (Identifying Historic Properties). A total of 13 cultural resource sites and 1 paleontological site are located either within or in very close proximity to the parcel boundary. The paleontological site has been classified as Class 5 – Unimportant; therefore, no management concerns need to be considered. Six of the cultural sites have been determined “non-eligible” and seven sites “eligible” to the National Register of Historic Places. Phase I data recovery has already been completed on three of the eligible sites in connection with the Southern Parkway Segment 3; New Airport to Washington Dam Road project; therefore, no further cultural resource work is required for these sites. The remaining four eligible cultural resource sites include

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prehistoric period lithic and ceramic scatters and erosion control features constructed by the Civilian Conservation Corps from 1937 to 1938, and will require the mitigation of adverse effects to these historic properties prior to the conveyance of the parcel from Federal management. A Memorandum of Agreement will be signed and implemented among BLM, the State Historic Preservation Officer, other invited signatories and concurring parties (1) to specify the mitigation measures agreed to by the signatories; (2) to identify who is responsible for carrying out the specified mitigation measures; and (3) to serve, along with its implementation, as evidence of BLM’s compliance with Section 106 of the National Historic Preservation Act (NHPA). Cost estimates for the required mitigation range from $350,000-$700,000; mitigation costs will be paid either by the County or Brennan.

Non-Federal Parcel: The non-Federal parcel has not been systematically inventoried to identify cultural or paleontological resources and there is no legal obligation that BLM undertake such inventories prior to the acquisition of this tract through exchange. After federal acquisition, all cultural resources on this parcel would be managed consistent with federal heritage preservation laws, including NHPA and Archaeological Resources Protection Act, and the conservation mandates from PL 111-11 for the NCA.

E. Grazing: Federal Parcel: The Federal parcel is located within an active grazing allotment. Dennis Iverson currently holds the permit for the Dome Allotment (#14019) which has a season of use of Dec. 1 – May 15. The total allotment is 2,817 acres with 2,021 acres of that being administered by the BLM. The Dome allotment currently supports 218 AUM’s (43-cows) and the rate of use over the last 8 years averaging approximately 80%. The Federal parcel is approximately 600 acres in size and is located within the best grazing the Dome allotment has to offer. In 1979 a rangeland inventory suggested that there were approximately 70-80 AUMs on the exchange parcel. Recently completed utilization studies suggest that the bulk of grazing use occurs along the Long Valley area. Once the exchange is completed, the stocking rate (# of cows) and the AUM's on the allotment would be reduced to reflect the change. A stock and monitor concept would be implemented to determine if grazing the allotment remains feasible. It is likely the Dome allotment will be unsuitable for continued management as a grazing allotment if the exchange is completed. The permittee was given a two-year notice of the BLM’s plans to dispose of this parcel in June 2013. No comment was received in connection with the notice. The BLM will provide an additional notice in connection with the exchange action, and grazing on the Federal lands would be allowed to continue for a two year period following the notice. There are no range improvements on the parcel that would require compensation.

Non-Federal Parcel: Grazing has not occurred on the non-federal parcel since 1996 when the grazing permits for a majority of the allotments on public lands in the HCP Reserve were purchased by Washington County. The 1999 SGFO RMP made all but three allotments in the Reserve unavailable for livestock grazing over the life of the RMP. The RMP that has been drafted for the NCA would not re-authorize livestock

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grazing on the public lands adjacent to the non-Federal parcel and grazing will not be authorized on this parcel upon conveyance of the land to the United States.

F. Mineral Resources:

Federal Parcel: The BLM completed a mineral potential report on this parcel in November 2012. The report concluded that the parcel has a high potential for sand and gravel resources; a low to moderate potential for locatable minerals; and a low to moderate potential for oil and gas resources. A borrow pit authorized in connection with the Southern Parkway (UTU-87808) is located on the parcel, but is being utilized on a temporary basis to support construction of the roadway. The permit is exempt from rental, expires in August 2017, and the land will be suitably reclaimed. A community pit encompassing 80 acres on the northern portion of the parcel was authorized, however, no materials were excavated from the pit and use of the pit was terminated in September 2013. There are no active mining claims or mineral development activity in the vicinity of the Federal parcel. The mineral potential report will be provided to the appraiser for consideration in the valuation of the parcel.

Non-Federal Parcel: All mineral rights to the non-Federal parcel were reserved by the State of Utah. There are currently no oil and gas leases or other mineral leases encumbering the parcel, and due to a low potential for marketable minerals, the likelihood of any mineral development on the parcel is extremely low. Section 9 of the ESA prohibits any person subject to the jurisdiction of the United States to take endangered species of fish and wildlife, or to violate any regulation promulgated by the Secretary pertaining to any threatened species of fish or wildlife. Regulations at 50 CFR 17.31(a) apply the prohibitions of Section 9 to all threatened species. Therefore, any mineral development of the mineral estate activities authorized by the State would be subject to the prohibitions under Section 9. Additionally, the State or its permittees and licensees would be required to obtain approval from the BLM for use of the surface, which would require Section 7 consultation with the FWS.

G. Water Resources:

Federal Parcel: There are no water rights or points of diversion on the non-Federal parcel according to the State of Utah, Division of Water Resources records. The entire parcel is in Zone X - areas determined to be outside the 0.2% annual change floodplain. Source: FEMA Flood Insurance Rate Map No. 49053C1055G, April 2, 2009. The 2014 National Wetland Inventory (NWI) created and maintained by the US Fish and Wildlife Service includes 6.38 miles of R4SBC classified riverine habitat (Riverine, Intermittent, Stream Bed) – all of which is identified as riparian habitat. The NWI also includes a 0.26 acre palustrine polygon classified as ‘Freshwater Pond’ or PUB (Palustrine, Unconsolidated Bottom). However, inspection of 2014 NAIP Aerial Photography of the parcel area indicates a complete absence of riparian or wetland vegetation in both the riverine and palustrine features in the Inventory. As a result, no wetland features are present or would be conveyed with the transfer of this parcel.

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Non-Federal Parcel: There are no water rights or points of diversion on the Federal parcel according to the State of Utah, Division of Water Resources records. The majority of the parcel is in Zone X (areas determined to be outside the 0.2% annual change floodplain), except for two small areas along the southern boundary of the parcel which are in Zone A (special flood hazard areas subject to inundation by the 1% annual change flood; no base flood elevations determined). Source: FEMA Flood Insurance Rate Map No. 49053C0793G, April 2, 2009. This portion of the parcel will not be acquired in the exchange. The 2014 National Wetland Inventory created and maintained by the US Fish and Wildlife Service includes 1.21 miles of classified riverine habitat – of which, 1.07 miles are classified as riparian. However, inspection of 2014 NAIP Aerial Photography of the parcel area indicate a complete absence of riparian or wetland vegetation. As a result, no wetland features are present or would be conveyed with the transfer of this parcel.

H. Land/Access:

Federal Parcel: The Federal parcel is bounded on the north and west sides by the Southern Parkway, an eastern belt route for Washington County that will become a four-lane divided expressway when fully built. The 33-mile parkway begins at I-15 Exit 2, extends east to the St. George Airport, north to State Route 9, and reconnects to I-15 at Exit 16. Segment 3, which bounds the Federal parcel, is currently under construction and is expected to be complete by the end of 2015. A planned interchange/off-ramp is located on the northern portion of the parcel and has been authorized as part of the Federal highway right-of-way. However, construction of the interchange would have to be funded by adjoining landowner(s) or other party that would benefit through its construction. Disposal of the Federal parcel would not hinder public access to the Open OHV Area. An underpass providing access to the OHV has been constructed just to the east of the parcel. An unpaved secondary road bisects the parcel and provides access and maintenance to the Dixie Escalante Electric power transmission line. Non-Federal Parcel: The 788-acre parcel has improved access points from the east within the Green Springs area and from the south within the Middleton area. Cottonwood Road, a partially improved road that provides access into the Reserve, runs north and south approximately one-half mile to the west of the parcel. Depending on what portion of the parcel is acquired in the exchange, physical access may not reach the parcel; however, legal access exists via an easement that was created in connection with the purchase of a 22.4-acre portion of the Brennan property by the United States in 2013. Administrative access could be gained via adjoining BLM-administered land, and public motorized access to the parcel is not necessary as the NCA is closed to motorized use.

I. Socio-Economics:

Federal Parcel: Disposal of the Federal parcel would provide Washington County with desirable developable land, adding to the local economy and increasing the tax base for Washington County and the surrounding communities.

14

Non-Federal Parcel: Acquiring the non-Federal land would provide a positive economic impact because it would support Washington County’s HCP allowing for continued development of other private land classified as desert tortoise habitat in Washington County and provide the BLM with a large nearly contiguous block of Federal land that would result in more effective and efficient natural resource management. The acquisition would reduce the amount of boundary and fencing the BLM must maintain and would significantly reduce the potential for conflict with the private land owner. In 1996, legislation was passed (PL 104-333) that requires private lands in Washington County to be appraised as if there were no encumbrances or market influences due to the presence of a threatened or endangered species. Because of this, the property value associated with the non-Federal parcel will not reflect the impacts of the existing reserve on the potential development and marketing of the parcel. Accordingly, the values of the Federal and non-Federal parcels might seem skewed to an outside observer. Because the exchange will be beneficial to Brennan in terms of future developability of the Federal parcel; to Washington County in terms of property tax revenues; and to the non-market Federal interest in protecting the species that will benefit from expansion of the Reserve, the exchange can be judged as being mutually beneficial and appropriate from an economic standpoint.

J. Hazardous Materials:

Federal Parcel: BLM completed a Preliminary Assessment on this parcel in October 2012. The assessment revealed no evidence of any hazardous substances or other recognized environmental conditions on the parcel. The BLM will complete an update to this assessment prior to completion of the exchange to ensure the conditions on the parcel, as noted in the assessment, have not changed.

Non-Federal Parcel: The 788-acre parcel has been inventoried and no hazardous substances or other recognized environmental conditions were found on the parcel. The last survey was completed in August 2013. Given the location and lack of access, it is likely the environmental conditions remain unchanged. A new environmental site assessment will be completed in compliance with 40 CFR Part 312 (All Appropriate Inquire (AAI) regulations) to determine the presence of hazardous substances, petroleum products, solid wastes, or physical hazards prior to conveying or accepting title. A certified environmental professional and BLM authorized officer(s) will review and approve the reports.

VII. RESOURCE SUMMARY AND PUBLIC INTEREST FACTORS:

Based on the preliminary assessment of the resource values and uses associated with the exchange parcels discussed above, the exchange would be in the public interest to pursue. The exchange would allow for the BLM to 1) acquire on behalf of United States acreage containing

15

critical habitat for the Federally-threatened Mojave desert tortoise; 2) consolidate Federal lands within the Reserve and NCA, resulting in improved management of the Federal lands and avoiding the threat of development and destruction of habitat; 3) further the objectives of the 1999 RMP to acquire lands within the Reserve; 4) meet the commitments made by the BLM in the 1995 HCP Final Implementation Agreement to participate in the HCP and “work to gain title” from willing sellers of private and SITLA lands within the Reserve; and 5) provide for the needs of State and local residents and their economies. The acquisition of lands within the Reserve will help facilitate renewal of the HCP and allow for the continued development of private lands within Washington County under the HCP ITP. Disposal of the Federal parcel would impact one grazing allotment and eliminate approximately 1.5% of the BLM-administered acreage from the Sand Mountain SRMA; however this western portion of the SRMA is not heavily used in comparison to the Open OHV Area of the SRMA. The exchange would convey a parcel into private ownership that is better suited for development due to its location along the newly constructed Southern Parkway corridor and proximity to the new St. George Airport.

VIII. VALUATION ANALYSIS: Washington County commissioned RCS Appraisal, Inc. to complete a preliminary value estimate (PVE) for the exchange parcels. The PVE was completed in January 2014, without the involvement of the Department of the Interior, Office of Valuation Services (OVS). The Federal parcel was valued at $6,930,000 ($11,000/acre), and the non-Federal parcel was valued at $24,140,000 ($32,000/acre). However, these value estimates were based on 630 acres for the Federal parcel rather than 604 (bringing the total value down to $6,644,000), and 754.39 acres for the non-Federal parcel rather than 788. It is not certain what impact, if any, these acreage differences may have on these value estimates, and it can be assumed that property values have since increased. Also, it should be noted that past appraisals completed on the non-Federal parcel in connection with other transactions, the per-acre value increased substantially as the total parcel acreage decreased. For example, the BLM purchased 22.4 acres of Brennan’s property in 2013, for a value appraised at $134,000 per acre due to the “economy of scale” factor. Based on the per-acre value estimates, the BLM anticipates that between 100 to 150 acres could be acquired in the exchange, depending on how the parcel is appraised. These estimates are sufficient to assist the BLM in structuring the exchange and to confirm that Congressional notification will be required, however, an appraisal approved by OVS needs to be completed. The OVS will direct and oversee the appraisals of the Federal and non-Federal parcels in accordance with Federal standards and regulations prescribed in 43 CFR 2201.3 and the “Uniform Appraisal Standards for Federal Land Acquisitions”. The appraiser will be instructed to appraise the non-Federal parcel without regard to the presence of a threatened or endangered species or any proposed or actual designation of the property as critical habitat for a listed species, pursuant to PL 104-333. Once the value of the Federal parcel is established, the appraiser will be instructed to then define the portion of the non-Federal parcel that can be acquired. This process may result in a slight difference in value, which can be eliminated

16

through an equalization payment by the appropriate party pursuant to the provisions of 43 CFR 2201.6

IX. ESTIMATED TIME FRAMES, COSTS, AND FUNDING SOURCES FOR COMPLETING THE EXCHANGE:

The roles and responsibilities for each party and the estimated costs for each task are outlined in the draft Agreement to Initiate the Exchange (ATI) prepared specifically for this exchange. Washington County will be a party to the ATI and will contribute towards the cost of processing the exchange. There would be no compensation of costs in this exchange. Significant deviations to these estimated costs may require further consideration and possible amendment to the ATI to ensure that costs for the exchange are accurately reflected. The BLM will provide a team lead and staff specialists in range, wildlife, recreation, minerals, archaeology and other areas as needed to provide inventories and reports or review work done by others as needed. Federal funding for the exchange will come primarily from the 1430 (Lands and Realty) and 1150 (T&E Species) accounts. The estimated time frames for the processing steps are outlined on Exhibit C of the ATI, and the BLM anticipates being able to complete the exchange within one year from execution of the ATI, if the authorized officer determines the exchange will serve the public interest.

X. ISSUES AND CONFLICTS:

PL 104-333 requires that private lands within Washington County be appraised without regard to the presence of a threatened or endangered species or any proposed or actual designation of the property as critical habitat for a listed species. This and the high demand for land in and adjacent to St. George for development has led to extremely high property values, and significant differences between the values of Federal and the non-Federal lands in Washington County.

The proposed disposal of lands within a designated SRMA could be controversial. Much of the 18,000 acres identified for disposal in the RMP that did not have resource conflicts have been disposed of in order to acquire lands within the Reserve pursuant to the HCP Implementation Agreement. There is little desirable Federal acreage left in Washington County that can be made available for exchange purposes. The high land values for acreage in the Reserve, due to its proximity to St. George and the provisions of PL 104-333, creates further complexities for the BLM in attempting to acquire lands through exchange. The BLM initially considered six additional Federal parcels for inclusion in this exchange in an effort to acquire more of the non-Federal parcel acreage; however, all six parcels were eliminated from further consideration in this exchange proposal due to resource conflicts identified in resource inventories.

XI. RECOMMENDATION:

The proposed land exchange is consistent with the decisions contained in the 1999 SFGO RMPand appears to be in the public interest to pursue. Most of the funding for processing theexchange will be provided by Brennan and Washington County. The BLM will acquire acreage

within the Reserve that provides critical habitat for the Federally-threatened Mojave desert

tortoise. Acquiring this critical habitat is a high priority for the FWS in their recovery efforts,

and will support Washington County's HCP by consolidating Federal lands within the Reserve

and allowing for the continued development of lands throughout Washington County under theITP. The exchange would further the BLM's commitment to acquire private inholdings made inthe 1995 Final Implementation Agreement for the HCP, and would convey into privateownership lands that would be better suited for development. The City of St. George,

Washington County, the State of Utah, and Utah's Congressional delegation strongly support theacquisition of private lands in the Reserve. For these reasons, I recommend that the exchange be

processed.

Rec ed by:

sþz/zotrField Manager" St. ge

A by

Date

1 LDirector

EXHIBITS:Exhibit A - Description and Map of Federal ParcelExhibit B - Description and Map of Non-Federal Parcel

Exhibit C - General Vicinity Map of Exchange ParcelsExhibit D - Solicitor Communication on Planning CriteriaExhibit E - Map of the Sand Mountain SRMA

I7

EXHIBIT A Federal Lands and Interests Proposed for Exchange

Brennan/Red Cliffs Land Exchange (UTU-88966-FD) Description of Land:

Salt Lake Meridian, Utah T. 42 S., R. 14 W.

Sec. 20, lots 13 and 14; Sec. 29, lots 2, 4, 5, 7, 9, 12, 14, and 15, NE1/4NW1/4, SW1/4NW1/4; Sec. 30, lots 13, 16, 18, 19, 22, 24, and 25, NE1/4SE1/4; Sec. 31, lots 14, 15, 18, 20, and 22, NW1/4NE1/4.

Acreage: 605.61 Interests to be Conveyed or Reserved: The parcel will be conveyed with a reservation to the United States for a right-of-way thereon for ditches or canals constructed by the authority of the United States under the Act of August 30, 1890 (43 U.S.C. 945). There is no water, timber, or other rights associated with the property. Encumbrances of Record: The parcel will be conveyed subject to the following third-party rights:

1. Transmission line right-of-way UTU-55640 granted to Dixie Rural Electric for a term ending December 31, 2044. Consistent with BLM policy, the right-of-way holder will be given the opportunity to amend this authorization for conversion to a perpetual term or to an easement prior to completion of the exchange.

2. Access road right-of-way UTU-88924, granted to the City of Washington, for a perpetual term.

3. Highway right-of-way UTU-87808, granted to the Federal Highway Administration for a perpetual term. Note the parcel boundary is the easterly right-of-way edge, however, the authorization includes a borrow pit and interchange/off-ramp located on the exchange parcel. The borrow pit is authorized for a temporary term of 3 years. Construction of the off-ramp is not currently planned.

4. Rights of grazing permittee, Dennis Iverson, may have to continue grazing under Federal grazing permit No. 14019 (Dome Allotment). The permit will remain in effect for a two-year period following formal notice to the permittee as required by 43 CFR 4110.4-2. Notice will be provided concurrent with publication of the NOEP.

19

21

20

283029

3331 32

24

25

36

R 15W R 14W

T 42

S

Red Cliffs/Long Valley Exchange - Federal Parcel

Federal Parcel

Sand Mountain SRMA

Southern Parkway ROW Ü

0 0.5 1

Miles

Exhibit A

Washington County

19

21

20

283029

3331 32

24

25

36

R 15W R 14W

T 42

S

Red Cliffs/Long Valley Exchange - Federal Parcel

Ü

0 0.5 1

Miles

Exhibit A

Washington County

Federal Parcel

Sand Mountain SRMA

Southern Parkway ROW

EXHIBIT B Non-Federal Lands and Interests Proposed for Exchange Red Cliffs/Long Valley Land Exchange (UTU-88966-PT)

Description of Land:

The description of the parcel to be acquired will be determined through a survey, following valuation of the Federal and non-Federal lands. The parcel will constitute a portion of the 788-acre parcel owned by Brennan located within Sections 8, 9, 16, and 17 in T. 42 S., R. 15 W., Salt Lake Meridian. The portion to be acquired will originate on the northern boundary of the parcel, contiguous to BLM-administered lands in Section 9, and will extend south to the extent that the value will be equivalent with the value of the Federal parcel.

Acreage: To be determined

Interests to be Conveyed or Reserved: Conveyance of the non-Federal land would include the surface estate only. The mineral estate was reserved in a prior transaction by the State of Utah. There is no water, timber, or other rights associated with the property.

Encumbrances of Record: Encumbrances on the larger 788-acre parcel are listed below. Depending on the final parcel configuration, some encumbrances may not cross the parcel. All encumbrances have been previously determined to be administratively acceptable and waived by the Office of the Solicitor:

1. Utility easement held by the City of St. George for a buried water pipeline.

2. Utility easement held by PacifiCorp for electric transmission and distribution lines andassociated facilities.

3. Use Agreement and Stipulated Judgment under which Dixie Escalante Rural ElectricalAssociation, Inc. has the right to utilize the above-noted PacifiCorp easement for theconstruction, access and maintenance of their power line easement.

4. Road easement in the favor of Brennan, His Family Matters, and the SITLA, providinglegal access to their respective land holdings.

5. Easement agreement in favor of the Trust for Public Land, providing an appurtenanteasement to a 22.4-acre parcel which was purchased by TPL and subsequently conveyedto the United States.

!"#@

030406

02

05

11

08 09 1007

1618

14

1517

201923

2221

R 15W

T 42

S

Red Cliffs/Long Valley Exchange - Non-Federal Parcel

Ü

0 0.5 1

Miles

Exhibit B

Red Cliffs Desert Reserve and NCA

Non-Federal Parcel

R 15W

T 42

S

Red Cliffs/Long Valley Exchange - Non-Federal Parcel

Ü

0 0.5 1

Miles

Exhibit B

Red Cliffs Desert Reserve and NCA Red Cliffs NCA

Non-Federal Parcel

Red Cliffs Desert Reserve andNational Conservation Area

ArizonaUtah

Dixie National Forest

Paiute Indian Reservation

Sand Hollow Reservoir

Hurricane

Ivins

La Verkin

Leeds

St.George

SantaClara

Toquerville

Washington

R 17W R 16W R 13WR 15W R 12WR 14W

T 39

ST

40S

T 41

ST

42S

T 43

S

Red Cliffs/Long Valley Land Exchange

Utah

0 5 10

MilesNon-Federal Exchange Parcel

Federal Exchange Parcel

August 2015

Exhibit C

3/26/2015 DEPARTMENT OF THE INTERIOR Mail - Re: Request for Opinion on RMP Disposal Language

https://mail.google.com/mail/u/0/?ui=2&ik=732a95ed19&view=pt&search=inbox&th=14c396c9238d6455&siml=14c396c9238d6455 1/2

Wehking, Joy <jwehking@blm.gov>

Re: Request for Opinion on RMP Disposal Language1 message

Karkut, James <james.karkut@sol.doi.gov> Fri, Mar 20, 2015 at 5:02 PMTo: Kent Hoffman <khoffman@blm.gov>, Pamela Jarnecke <pjarnecke@blm.gov>, Joy Wehking<jwehking@blm.gov>

Kent, Pam, and Joy --

This is to follow-up the meeting at the State Office on Wednesday, 3/18, among Kent, Pam, and me, mysubsequent review of the materials in Joy's email of the same date, and a discussion with my colleague JohnSteiger. As a result, I think it would be helpful for us to have a short teleconference or in-person meeting nextweek on the questions raised in Joy's email and at our meeting.

My assessment at this point, based on the facts as I understand them, is that a transfer of the identified landsfrom the Sand Hollow SRMA as part of a land exchange for certain private lands within the Red Cliffs Reservewould be in conformance with the RMP -- if the underlying BLM analysis adequately substantiates that thetransfer would satisfy one or more of the criteria in RMP decision LD-02 (and thereby also satisfy decision LD-06).

Regarding decision RC-20(e), I interpret the "Generally" at the beginning of the decision to state a presumption infavor of retaining the lands within the SRMA as public lands, while recognizing that it is within BLM's discretion,based on the specific facts involved in each particular circumstance, to determine whether the public interest isserved by retaining or transferring the subject lands. Therefore, a transfer of SRMA lands would be inconformance with decision RC-20(e) if, as mentioned above, the underlying BLM analysis adequatelysubstantiates that the transfer would satisfy one or more of the criteria in RMP decision LD-02. As I mentionedin Wednesday meeting, I recommend that BLM complete some due diligence and determine whether it statedany particular position regarding such language in either responding to comments on the Draft EIS/RMP or toobjections on the Final EIS/Proposed Final RMP, and how it may have interpreted similar language where itshows up in other decision in the RMP (if it does).

That leads to the question of whether the proposed exchange should be considered as part of a plan amendmentprocess. In our meeting on Wednesday, I leaned toward that process, but at this point, I am starting to thinkthat that would not be necessary. As mentioned above, I think it would be helpful to discuss the pros and consof what workable approaches exist next week. I am in the office Monday through Thursday, and am fairly openat this point, so please contact me regarding any follow-up you might like to have.

Jim

On Wed, Mar 18, 2015 at 5:29 PM, Wehking, Joy <jwehking@blm.gov> wrote:Hi Jim -

We would like to get your opinion on the land tenure language in the St. George RMP, and whether or not BLMshould do a plan amendment in connection with a planned disposal action through exchange. The parcel inquestion is within the Sand Mountain Special Recreation Management Area (SRMA). Attached are thefollowing documents for your reference:

The land tenure section of the RMPThe Sand Mountain SRMA section of the RMP Map of the Federal parcel (Long Valley) within the SRMARMP Maps of disposal parcels and SRMAs

The exchange parcel is not within the open OHV area of the SRMA, and the disposal of this parcel is notexpected to be controversial. The parcel would be exchanged for critical tortoise habitat within the Red CliffsDesert Reserve, so 4 out of the 5 disposal criteria in the RMP would be met, even though the parcel has not

Exhibit D

3/26/2015 DEPARTMENT OF THE INTERIOR Mail - Re: Request for Opinion on RMP Disposal Language

https://mail.google.com/mail/u/0/?ui=2&ik=732a95ed19&view=pt&search=inbox&th=14c396c9238d6455&siml=14c396c9238d6455 2/2

been specifically identified for transfer. The SRMA section of the RMP states that generally, land within theSRMA will be maintained in public ownership, which appears to give us some discretion. We would like youropinion on whether BLM could withstand a protest based on our failure to complete a plan amendment inconnection with an exchange action.

There is a little more to this story, but I'll save it for a phone call. Please review the attached documentswhen you get time and give me or Kent a call so we can discuss. We are both available through the rest ofthis week.

Thanks very much for your assistance.

-- Joy WehkingRealty SpecialistBLM Utah State OfficePhone: 801-539-4114

-- James E. KarkutOffice of the Regional SolicitorU.S. Department of the Interior125 South State Street, Suite 6201Salt Lake City, Utah 84138(801) 524-5677, ext. 225(801) 524-4506 (fax)

"{!.

Sand Hollow Reservoir

Washington

R 15W R 14W R 13W

T 42

ST

43S

Sand Mountain Special Recreation Management Area

Federal Parcel

Sand Mountain Open OHV

Sand Mountain SRMA Ü

0 2 4

Miles

Exhibit E

Washington County