A06_Attachment_1_PUP_0001.pdf

UNITED STATE DEPARTMENT OF THE INTERIOR

BUREAU OF LAND MANAGEMENT

PESTICIDE USE PROPOSAL

STATE: Oregon

COUNTY: Lane County

DISTRICT: Northwest Oregon District

DURATION OF PROPOSAL: 2024-2027

LOCATION: Northwest Oregon District

West Eugene Wetlands Project Area

ORIGINATOR – NAME: Megan McGinnis

ORIGINATOR – COMPANY: Bureau of Land

Management, Northwest Oregon District, Siuslaw

Field Office

ORIGINATOR – CONTACT INFORMATION: mmcginnis@blm.gov, 541-683-6979;

cbglade@blm.gov, 503-375-5678

PROPOSAL PREPARER - NAME: Same as above.

PROPOSAL PREPARER – COMPANY: Same as above.

PROPOSAL PREPARER – CONTACT INFORMATION: Same as above.

I. APPLICATION INFORMATION – Including mixtures and adjuvants:

a. Pesticides

Trade Name Common Name EPA Registration #

Manufacturer

Stinger Clopyralid 62719-73 Corteva Agriscience

Transline Clopyralid 62719-259 Corteva Agriscience

AquaNeat Glyphosate 228-365 Nufarm Americas Inc.

Gly Star Original Glyphosate 42750-60 Albaugh, LLC (Albaugh, Inc/Agri Star)

Gly Star Plus Glyphosate 42750-61 Albaugh, LLC (Albaugh, Inc/Agri Star)

Rodeo Glyphosate 62719-324 Corteva Agriscience

Roundup Custom Glyphosate 524-343 Bayer CropScience

Garlon 3A Triclopyr 62719-37 Corteva Agriscience

Garlon 4 Triclopyr 62719-40 Corteva Agriscience

Tahoe 3A Triclopyr 228-520 Nufarm Americas Inc.

Element 3A Triclopyr 62719-37 Corteva Agriscience

Element 4 Triclopyr 62719-40 Corteva Agriscience

Vastlan Triclopyr 62719-687 Corteva Agriscience

DATE: 05/15/2024

PROPOSAL NUMBER: ORN000-24-001-P

RMP REF. NUMBER: DOI-BLM-ORWA-E000-

2012-0001-RMP-EIS

DNA REF. NUMBER: DOI-BLM-ORWA-N030-

2023-0015-DNA

DECISION RECORD (DR) NUMBER: DOI-BLM-

ORWA-NO30-2023-0015-DNA

mailto:mmcginnis@blm.gov mailto:cbglade@blm.gov

Trade Name Max Active

Ingredient

Application

Rate in EA

(lbs a.i. or a.e.)

Max Application Rate on

Label

Intended Application Rate

Pounds a.i./a.e.

Formulated product

Pounds a.i./a.e.

Formulated product

Stinger 0.5 a.e. 0.5 a.e. 1.33 pints 0.35 a.e. 15 fl oz

Transline 0.5 a.e. 0.5 a.e. 1.33 pints 0.35 a.e. 15 fl oz

Aqua Neat 7 a.e. 8 a.e. 8 quarts 2 a.e. 2 quarts

Gly Star Original, Gly Star Plus

7 a.e. 7.95 a.e. 10.6 quarts 2 a.e. Up to 2.6 quarts

Rodeo 7 a.e. 8 a.e. 8 quarts. 2 a.e. 2 quarts

Roundup Custom 7 a.e. 8 a.e. 8 quarts. 2 a.e. 2 quarts

Garlon 3A 10 a.e. 9 a.e. 3 gallons 1 a.e. 1.33 quarts

Garlon 4 10 a.e. 8 a.e. 2 gallons 1 a.e. 1 quart

Tahoe 3A 10 a.e. 9 a.e. 3 gallons 1 a.e. 1.33 quarts

Element 3A 10 a.e. 9 a.e. 3 gallons 1 a.e. 1.33 quarts

Element 4 10 a.e. 9 a.e. 2 gallons 1 a.e. 1 quart

Vastlan 10 a.e. 9 a.e. 2.25 gallons 1 a.e. 1 quart

b. Adjuvants

Trade Name &

State Registration #

(if applicable)

Common Name

(Type)

Manufacturer Max Application Rate on

Label

Intended Application Rate

Hi-Light1 Colorant BASF Corporation

Up to 32 ounces / 100 gallons solution

16 – 32 ounces / 100 gallons solution

Agri-Dex Surfactant, Oil-based – Crop oil concentrate

Helena Holding

Company

4 pints per acre Up to 4 pints per acre or

1.0% by v/v with a minimum of 0.5% by volume.

LI-700 Surfactant, non-ionic, drift control

Loveland

Products, Inc.

8 pints in 100 gallons in non-crop settings

Up to 4 pints/100 gallons;

LI -700 not to exceed 5 % of the finished spray volume.

Syl-Tac-EA Surfactant, Silicone Based

Wilbur-Ellis

Co., LLC

4 fl. oz/acre. >30 gallons use .1% volume

Up to 4 fl. oz/ acre. The ultimate rate cannot exceed 5% of the finished spray volume.

Competitor Adjuvant, Oil-based, Vegetable Oil

Wilbur-Ellis

Co., LLC

For aquatic labelled herbicides the maximum rate is 2 pints per acre (in

5-30 gallons of water), Not to exceed 5% volume unless otherwise specified on herbicide label. Other (non-aquatic) herbicides the maximum rate is 4 pints per acre.

Up to 4 pints per acre with herbicides not labelled for aquatic use and up to 2 pints/ acre when used with aquatic labelled herbicides.

Motion1 Adjuvant, Oil-based, Vegetable Oil

Exacto, Inc. For high volume sprays, ½ gallon or more per 1000 sq. ft, must not exceed 5% v/v.

Up to 0.5-1% v/v.

Noble1 Adjuvant, Oil-based, Vegetable Oil

Winfield-

United

2 pints per acre with post-emergent herbicides.

Up to 2 pints per acre.

Amigo Adjuvant, Oil-based, Vegetable Oil

Loveland

Products, Inc.

2 quarts per acre. Up to 2 quarts per acre.

Elite Natural1 Adjuvant, Oil-based, Vegetable Oil

Red River

Specialties, Inc.

No rates provided on label. Follow herbicide manufacturer’s label recommendations for the addition of adjuvants.

Herbicide manufacturer’s label recommendation

Hasten-EA Adjuvant, Oil

Based, Methylated

Seed Oil

Wilbur-Ellis

Co., LLC

4 pints/ acre, unless otherwise specified on herbicide label. Can not exceed 5% of the finished spray volume.

Up to 4 pints/acre, unless otherwise specified on herbicide label. Can not exceed 5% of the finished spray volume.

W.E.B. Oil1 Diluent/Deposit ion Agent

Wilbur-Ellis

Co., LLC

Up to 40% in oil + water mixtures and up to sole carrier with oil soluble herbicides.

Up to sole carrier for oil soluble or miscible herbicides unless otherwise specified on herbicide label. Not labelled for aquatic use.

Bronc Max Fertilizer

(Nitrogen based) Water conditioning agent

Wilbur-Ellis

Co., LLC

8 pints/ 100 gallons of spray

1-8 pints/ 100 gallons of spray unless otherwise specified on herbicide label

Class Act NG Fertilizer

(Nitrogen based)

WinField-

United

5% v/v or 5 gallons/100 gallons of spray solution.

2.5-5 % v/v

Nu-Film_IR1 Surfactant, Spreader/ Sticker

Miller Chem. &

Fert. Corp.

2 oz/5 gallons of spray or .3% v/v

Up to 2 oz / 5 gallons of spray or .3% v/v

1 Product is not labelled for aquatic use.

1. METHOD OF APPLICATION: Spot treatments (≥ 95% of all treatments) and broadcast treatments (remaining 5% or less) using hand-held sprayers attached to vehicle-mounted trucks, utility vehicles (UTVs), all-terrain vehicles (ATVs) or backpack. Other treatment methods may include wipers, cut & frill, basal bark, hack and squirt, and injection. ATVs may be used by recipients and contractors, but not by BLM employees.

2. APPLICATION DATE(S): Treatments could occur at any time of the year, but most treatments will occur during the spring, prior to emergence of protected species, and/or in the fall after senescence. Based on species-specific requirements, target species will be treated when in active growth phases or when plants are actively translocating photosynthates back to their roots.

3. NUMBER OF APPLICATIONS: Generally, two broadcast treatments per year, per site, with additional spot treatments as necessary (providing the cumulative of all treatments remains within the allowable application rate).

II. PEST [List specific pest(s) and reason(s) for the proposed application of the pesticide]:

Target species include both non-native invasive plants and noxious weeds (authorized under the RMP), as well as native species in circumstances where they outcompete with federally listed species restoration and augmentation efforts (authorized by the RMP for certain chemicals in Prairie Restoration Areas).

Common invasive vegetation targeted in the West Eugene Wetlands includes reed canary grass, Himalayan blackberry, shining geranium, oxeye daisy, Canada thistle, orchard grass and false brome in addition to many others. Common native vegetation targeted for treatment includes Oregon ash, which frequently shades out prairie habitat due to lack of disturbance, as well as some native grasses where thatch buildup inhibits listed forb species germination. Over the life of this PUP the West Eugene

Wetlands (WEW) also expects to use herbicides to control some yet to be identified species infestations provided effective treatments could be implemented with the herbicides, adjuvants and treatment methods in this PUP. The species targeted for treatment are organized in the table below in the order their treatment key groups are presented in the District IIPM EA in Appendix C on pages 100 – 137.

District EA, Appendix A -

Treatment Key

Recommendations

Target Species

Annual Grasses bristly dogstail grass, cheatgrass, Biennial Thistles bull thistle, Italian plumeless thistle

Buckwheat Family knotweeds (Bohemian, Japanese, giant, and cultivated), curly dock, bitter dock

Canada Thistle Canada thistle

Geraniums geranium (Robert’s and shining)

Hawkweeds hawkweeds (common, meadow, New England, and orange)

Knapweeds knapweeds (diffuse, lesser, meadow, spotted, Tyrol, and yellow), garden cornflower

Lilies, Iris, Sedges, Rushes yellow flag iris

Miscellaneous Herbaceous –

Perennial bigleaf periwinkle, Mustards creeping yellowcress, cultivated radish, field mustard, field pepperweed, garlic mustard

Perennial Grasses Common velvetgrass, orchard grass, perennial ryegrass, reed canarygrass, slender false brome, tall fescue, tall oatgrass, timothy

Perennial Mints Yellow archangel

Perennial Peas Flat pea

St. Johnswort common St. Johnswort

Sunflower Family oxeye daisy, tansy ragwort

Teasels cutleaf teasel, fuller’s teasel

Woody Species Common pear, cotoneaster, English holly, English ivy, brooms

(French, Spanish, and Scotch), blackberries (Himalayan, cutleaf, and European), multiflora rose, oneseed hawthorn, orange eye butterfly bush, sweetbriar rose, tree of heaven

III. DESIRED RESULTS OF THE APPLICATION – LINKED TO THE OBJECTIVES OF THE

APPLICATION:

The District’s desired results of the applications are to prevent reproduction and spread of non-native invasive plants, reduce populations of invasive plant species, and maintain, enhance, and restore native prairie habitats. Some herbicides, such as glyphosate, would be used to eliminate competing, invading, undesired vegetation from sites where prairie restoration and enhancement of T&E species out-plantng will occur.

Site specific objectives for the project areas where these species are proposed for herbicide treatments in

2024 can be read in Attachment C -Table 4 of the WEW Integrated Herbicide Use and Prairie Restoration

Strategy DNA 2024-2027.

IV. APPLICATION SITE DESCRIPTION:

1. ESTIMATED NUMBER OF ACRES: In 2024, 181 acres are targeted for treatment. A similar number of acres is expected to be treated in subsequent years through 2027; however, the treatment area may vary by year, and not all acres or all species listed above will be treated in any one given year. The total number of acres treated will vary considerably depending on whether a prescribed burn and subsequent broadcast herbicide treatment are accomplished. Herbicide use will make up no more than 25% of all non-native invasive species treatments— 75% of acres will be treated with non-chemical methods either exclusively or in combination with herbicides.

Treatments are not to exceed 346 acres annually within the land use allocation Prairie Restoration

Area (WEW RMP BO, pg. 90).

1. GENERAL DESCRIPTION (Describe land type or use, size, stage of growth of target species, soil characteristics, and any additional information that may be important in describing the area to be treated.)

Treatments are located within the boundary of BLM owned parcels of the West Eugene

Wetlands. These areas are primarily within wet prairie habitat, with some upland habitats targeted for treatments as well. All sites are in either the Prairie Restoration Area (PRA) or the Natural

Maintenance Area (NMA). These two land use allocations (LUAs) comprise the entirety of the

WEW. Priorities will be to treat sites within the PRA first unless highly invasive weeds located within the NMA could spread. Primarily, the herbicide applications will be conducted to restore habitat to benefit T & E plant species and Bureau sensitive species such as the streaked horned lark, grasshopper sparrow, and western pond turtle by controlling monocultures such as reed canary grass and other competing vegetation.

Dispersed herbicide treatments in 2024 will be focused on habitat within the PRA; spot-spray of isolated weeds or clusters of weeds will occur both within the PRA and NMA. Sites for herbicide treatment will include the following sites; Balboa, Fir Butte, Speedway, Vinci, and Long Tom.

Sites such as Isabelle, Turtle Swale, North Taylor, Greenhill, and Hansen will also be targeted.

These sites contain a mixture of both PRA and NMA designations but because they contain threatened and endangered species both land designations will be targeted. Finally, one site, Stewart pond, located entirely within the NMA will be targeted specifically for the noxious species false brome, as well as other non-natives and nuisance weeds such as blackberry and poison oak which may hinder public access to the disc golf course or trails..

V. SENSITIVE ASPECTS AND PRECAUTIONS: In order to assist in tracking potential impacts associated with Federally threatened, endangered or proposed species, please answer the following questions and then provide the site specific conditions information.

1. Are there special status species (SSS) in the project area? “Yes” or “No” (Circle One)

A. If “No” Proceed to the site description portion of this section.

B. If “Yes” Are any of the SSS also federally threatened, Endangered, or proposed? “Yes” or “No” (Circle One)

a. If “No” Proceed to the site description portion of this section.

b. If “Yes” Did your Field Office coordinate with the local Fish and Wildlife Service

Office and/or NMFS “Yes” or “No” (Circle One)

I. If “No” Explain

II. If “Yes” Was Section 7 Consultation

Completed “Yes” or “No” (Circle One)

1. If “No” Explain

2. If “Yes” What extent of Section 7 was completed? “Formal Consultation”

(Circle One) “Informal Consultation”

“Technical Assistance”

2b. Describe the outcome of the consultation:

• USDI Fish and Wildlife Service. 2014. Biological Opinion (BO) for the West Eugene Wetlands

Resource Management Plan (01EOFW00-2014-F-0139). Consultation found that implementation of the WEW RMP was not likely to jeopardize any listed species or modify any critical habitat.

Implementation of the WEW RMP is likely to adversely affect individual listed terrestrial plants and Fender's blue butterfly within PRA LUAs; however despite adverse effects to individuals, annual restoration treatments including herbicide use would “likely to appreciably increase the effectiveness of the conservation program” (pg. 104) and present long-term benefit to listed species populations by improving critical habitat. The service concluded herbicide application is not likely to adversely affect listed birds, the listed aquatic plant, and other listed invertebrates, as well as critical habitat for all listed species. Within NMA LAUs, treatment will have no adverse effect and will be entirely beneficial. The BO addresses the impacts of herbicide application on

T&E species and provides management standards to protect them. It specifically provides for incidental take of Fender’s blue butterfly in conducting annual restoration treatments (pg. 110), and provides additional protective provisions related to herbicide treatment around Kincaid’s lupine and Fender’s blue butterfly populations in the WEW to minimize adverse effects. These provisions are incorporated in this plan and are found in Attachment B of the WEW Integrated

Herbicide Use and Prairie Restoration Strategy DNA 202-2027.

• National Marine Fisheries Service. 2019. Endangered Species Act Section 7(a)(2) Programmatic

Biological Opinion and Magnuson-Stevens Fishery Conservation and Management Act Essential

Fish Habitat Response for Integrated Invasive Plant Management for the Northwest Oregon

District, Bureau of Land Management. (WCRO-2019-00059). National Marine Fisheries Service.

2019. Errata for Endangered Species Act Section 7(a)(2) Programmatic Biological Opinion and

Magnuson-Stevens Fishery Conservation and Management Act Essential Fish Habitat Response for Integrated Invasive Plant Management for the Northwest Oregon District, Bureau of Land

Management. (WCRO-2019-00059).

NMFS concluded the implementation of the District’s IPMAHR EA proposed action is not likely to jeopardize the continued existence of Lower Columbia River (LCR) Chinook salmon

(Oncorhynchus tshawytscha), Upper Willamette River (UWR) Chinook salmon, LCR coho salmon (O. kisutch), Oregon Coast coho salmon, LCR steelhead (O. mykiss), UWR steelhead, or result in the destruction or adverse modification of their designated critical habitat. Project Design

Features adopted because of this consultation are included in Appendix 2 of the IPMAHR EA

Decision Record and they will be incorporated into in-house treatment prescriptions, as well as in contracts and agreements. The proposed action meets the “Applicability” section (§402.03) criteria since the effects of the action have no effect on listed fish species or critical habitat within the action area. Therefore, written concurrence is not required from the National Marine Fisheries

Service.

V. SENSITIVE ASPECTS AND PRECAUTIONS – (CONTINUED): Describe sensitive areas – marsh, endangered, threatened, candidate, and sensitive species habitat – and distance to application site. List measures to be taken to avoid impact to these areas):

All of the areas proposed for treatment are considered sensitive due to their wetland or riparian nature as well as the documented presence of threatened and endangered species. Treatments are a part of restoration and habitat quality improvement efforts. Specifically, treatments will be seasonally timed so that sensitive vegetation is senesced during application, and populations of living native vegetation and known animal nest sites are avoided to the extent possible and where it is compatible with restoration site preparation efforts.

Attachment B to the WEW Integrated Herbicide Use and Prairie Restoration Strategy DNA lists

Project Design Features to be implemented to protect water quality, wetland and riparian habitats, and

8 sensitive plant and animal populations within the West Eugene Wetlands, specifically. They are organized by resource program and treatment method. Specific project areas are highlighted in bold print for some PDFs designed to protect Threatened and Endangered and Bureau Sensitive plant, wildlife, fish and other aquatic species; special areas (Outstanding Natural Area, Scenic Corridor, Wild & Scenic River Corridors, and ACECs); nesting bird habitats; visual resources; recreation sites;

and adjacent landowners.

Both Hansen and Stewart Pond could be collection sites for local tribes, and coordination would be needed for Tribal members to collect plants in a safe manner in conjunction with the BLM using herbicides.

VI. NON-TARGET VEGETATION (Describe potential immediate and cumulative impacts to non-target pests in project area as a result of the pesticide application. Identify any planned mitigation measures that will be employed – BE GENERAL, SPECIFICS DISCUSSED IN THE EA):

Non-target vegetation is primarily native prairie graminoid and forb species including camas, perennial bunch grasses, and big leaf lupine. Theses species are at low risk for impacts from proposed herbicide treatments at the rates and methods intended. Weed treatments are designed and intended to facilitate vigorous growth by native species by eliminating competition from non-native invasive plant (including noxious weed) species. The risk of impacting a small percentage (<10%) of native vegetation including desirable broadleaved plants is outweighed by the reduction and/or elimination of weed species.

Small infestations may be manually removed if the infestation can be effectively controlled with manual methods. Most herbicide applications will be spot treatments using a hand wand and directed spray, thus avoiding most off-target damage. Broadcast treatments would only be implemented on dense infestations where there would be little chance of direct spray landing on non-target vegetation, or using selective herbicides that would not impact desirable vegetation. Attachment B of the WEW

Integrated Herbicide Use and Prairie Restoration Strategy DNA 2024-2027 includes several PDFs designed to prevent impacts to non-target vegetation.

VII. INTEGRATED PEST MANAGEMENT PRACTICES CONSIDERED IN THE OVERALL

PROJECT:

The West Eugene Wetlands’ process for identifying priority treatment areas is described in the RMP.

The RMP describes the integrated invasive plant management methods available for use. It explains how various methods are used together programmatically to control invasive plants. The District uses indirect and direct integrated invasive plant management tools and methods to manage invasive plants. Indirect methods implemented across the District include prevention, education, awareness, planning, coordination, and cooperation and are considered just as, if not more, important than the direct control methods. Direct control methods include manual and mechanical treatment methods

(includes propane torch use), competitive planting and seeding, solarization, prescribed fire, and herbicide application. Chemical treatments are limited to 346 acres within the PRA.

Manual methods (such as pulling, digging, chopping, girdling, cutting/lopping, weed wrenches, and grubbing) are typically used on small infestations and / or when a large pool of labor is available. The

WEW often uses manual treatments in combination with other techniques.

Mechanical treatment methods typically used on the WEW include string trimmers, brush cutters, chainsaws, masticators, and mowers. The WEW has shown interest in using propane torches to manage non-native invasive plants; District fire staff are negotiating with State officials whether or not a burn plan is required for these treatments. The District sometimes uses mechanical treatments before applying herbicides.

Competitive seeding and planting are used to provide a desirable native vegetative component to compete with invasive plants in treatment areas. This is a dominant component of prairie restoration and enhancement treatments at the WEW, specifically when out-planting Threatened and Endangered plant species. Native seed may include seed from federally listed species in addition to non-listed native species.

Prescribed fires can be used for invasive plant control in conjunction with other methods.

Prescribed fire can be a pre-treatment to an herbicide application, such as when the target invasive plants have gone to seed and there is a need to remove the seed source or to remove thatch. Broadcast herbicide treatment is often, but not always, conducted after prescribed burns in order to prevent invasive vegetation outcompeting native plants during the regrowth period. Site conditions including weather and invasive species presence determine need for follow-up post-burn herbicide treatment.

Herbicides are planned for use throughout the WEW. Most treatments are expected to be spot treatments applied with a hand wand. Broadcast treatments would be implemented less than five percent of the time in support of prairie restoration efforts. Other herbicide application methods that may be used over the life of this PUP include basal bark, hack & squirt, wipers, and injection.

Herbicides are utilized:

• on pure stands of a single invasive plant species where desirable and non-target plants are scarce or absent.

• for rhizomatous invasive plant species that would otherwise require repeated cutting or pulling for control.

• on plants whose characteristics make them difficult or unfeasible to remove with non-herbicide methods.

• in areas where non-herbicide methods are cost prohibitive.

• in areas where non-herbicide methods have unacceptable adverse effects to native plants.

MEGAN MCGINNIS MCGINNIS

Digitally signed by MEGAN

COLIN SAYRE Digitally signed by COLIN SAYRE

CHARITY GLADE

• in areas where considerable soil disturbance is not acceptable.

• for species located in remote or limited access areas where non-herbicide methods are not feasible.

• in combination with other control treatments.

USDA and

USDI 2006

USDA Forest Service, USDI Bureau of Land Management and USDI Fish and Wildlife Service.

2006. Interagency Conservation Agreement for Eucephalus vialis (Wayside Aster). BLM Eugene, Roseburg, and Medford Districts, USFS Rogue River-Siskiyou National Forest, and USFWS, Roseburg Field Office, Eugene, Oregon.

https://www.oregon.gov/oda/shared/Documents/Publications/PlantConservation/EucephalusVialisPr ofile.pdf.

USDI FWS

USDI Fish and Wildlife Service. 2010. Recovery Plan for the Prairie Species of Western Oregon and Southwestern Oregon. Portland, OR.

https://www.fws.gov/oregonfwo/Species/PrairieSpecies/Documents/PrairieSpeciesFinalRecoveryPl an.pdf

VIII. SIGNATURES:

1. Pesticide Use Proposal’s Originator: Date:

a. Company: Northwest Oregon District, Bureau of Land Management

2. Certified Pesticide Applicator: Date:

a. License Number:

b. Certifying Organization:

Digitally signed by CHARITY

3. District Office Pesticide/Noxious GLADE

Weed Coordinator: Date: 2024.05.15 15:17:10 -07'00' Date:

4. District Manager: Date:

5. BLM State Pesticide

Coordinator: Date:

6. Deputy State Director: Date:

Concur or Approved

Not Concur or Disapproved

Concur or Approved With Modifications o Any changes (modifications) to this proposal by the State Pesticide Coordinator will be listed in an attached memo to the manager requesting approval from the Deputy State Director.

24-088

Bureau of Land Management http://www.oregon.gov/oda/shared/Documents/Publications/PlantConservation/EucephalusVialisPr http://www.fws.gov/oregonfwo/Species/PrairieSpecies/Documents/PrairieSpeciesFinalRecoveryPla http://www.fws.gov/oregonfwo/Species/PrairieSpecies/Documents/PrairieSpeciesFinalRecoveryPla tcurtis Highlight