DAQ-2025-001934

DEPARTMENT OF THE ARMY
INSTALLATION MANAGEMENT COMi,IAND
UNITEO STATES ARMY GARRISON, DUGWAY PROVING GROUND
5450 DOOLITTLE AVE
DUGWAY, UTAH 84022.5000
March 7,2025
Mr. Bryce Bird
Director
Attn: Smoke Coordinator
Utah Division of Air QualitY
P.O. Box 144820
Salt Lake City, Utah 84114-4820
Dear Mr. Bird.
On behalf of U.S. Army Dugway Proving Ground (DPG) and in accordance with (lAW
DPG Title V Operating Permit condition 11.B.1.k.3 and 11.8.1.1.3, lam pleased to submit
one copy of the Non-burning Alternatives to Fire & Long-term Projections Report. This
report includes a list of areas treated using non-burning alternatives to fire conducted
during calendar year2024 and projections of future prescribed fire activities for upcoming
calendar year 2025.
Please direct your staff to contact Boyd Roberts of the Division of Environmental
Programs at [phone] with any questions or comments regarding this matter.
IAW operating permit provision l.K and Utah Administrative Code R307415-5d and
based on information and belief formed after reasonable inquiry, I certify that the
statements and information in this document are true, accurate, and complete.
Sincerely,
CHRISTOPHER D. DAMOUR
Garrison Manager
Enclosure
ENVIRONMENTAL QUALITY
DIVISION OF AIR OUALITY
B-2-10706
U.S. Army Dugway Proving Ground
Non-burning Alternatives to Fire &
Long-terrn Fire Projections Report
February 18,2025
l/An 1 1 20?_5
Submitted By
Division of Environmental Programs
U.S. Army Dugway Proving Ground
Dugway, UT 84022-5000
Prepared By
Mellor Engineering
Dugway Operations
Building 6672, Stark Road
Dugway, Utah 84022
UTAH DEPARTMENT
ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALIW
Table of Contents
List of Abbreviations/Acronyms... ................ii
1.0 Introduction ........ .....................1
2.0 Non-burning Alternatives to Fire ............. 1
2.1 Aerial C-130 Herbicide Application ....................... 1
2.2 Aerial Helicopter Granular Herbicide Application .................2
2.3 Firebreaks........... .................2
2.4 Tumbleweed Control..... ......3
3.0 Long-term Fire Projections.............. ........3
4.0 Referen@s......... ....................4
Appendix
A Maps .........A-1
List of Abbreviations/Acronyms
BLM
cY24
CY25
DPG
IAW
IWFMP
TVOP
UDAQ
U.S.
Bureau of Land Management
Calendar year 2024
Calendar year 2025
Dugway Proving Ground
ln accordance with
lntegrated \Mldland Fire Management Plan
Title V Operating Permit
Utah Division of Air Quality
United States
1.0 lntroduction
United States (U.S ) Army Dugway Proving Ground (DPG) Title V Operating Permit
(TVOP) Number 4500003005 issued by the State of Utah Division of Air Quality (UDAQ),
sets DPG's operating requirements in accordance with (lAW) Utah Administrative Code
R307, Environmental Quality, Air Quality. ryOP condition 11.8.1.k.3 and 11.8.1.1.3
"Prescribed Fires" requires DPG to submit an annual report containing a list of areas
treated using non-burning alternatives to fire conducted during the previous calendar
year, in addition to projections of future prescribed fire activities planned for the upcoming
calendar year.
The report is presented in the following sections:
. Section 2.0 - Non-burning Alternatives to Fire. Section 3.0 - Long-term Fire Projections. Section 4.0 - References
2.0 Non-burning Alternatives to Fire
This section describes non-burning alternatives to fire conducted during calendar year
2024 (CY24). The following information is provided for each alternative action:
. Description of the alternative action.. Number of acres.. Location of area.
2.1 Aerial C-130 Herbicide Application
ln October of 2024, DPG, in collaboration with HillAir Force Base, employed Youngstown
Air Force Reserve 91Oth Airlift \Mng C-130 aircraft and crew to conduct aerial application
of herbicide around the boundary and shot line of the White Sage Mortar Range and along
the DPG south boundary, to control undesirable invasive vegetation and facilitate
firebreak establishment and maintenance. This project was implemented to control
invasive weed species at DPG, which produce severe and dangerous conditions for range
fire ignition.
Aerial application of a selective herbicide was used to eliminate or reduce weeds and
prevent or minimize the extent of range fires. Two herbicides, imazapic, (trade name
Plateau@), and indaziflam (trade name Rejuvra@) were chosen for their target weed
specificity, low toxicity to humans, animals, and the environment. A specially equipped
C-1 30 fixed wing aircraft conducted the aerial application Oct2ld and 23d, spraying 100-
2OO-foot-wide swaths around the interior boundary of the White Sage Mortar Range, the
south DPG boundary, and along the Mite Sage shot line. The total area of application
was approximately 863 acres of impazapic and 284 acres of indaziflam. Locations of
aerial treatment areas have been provided in Appendix A, Map 1,'2024 Cl30 Aerial
H e rb icid e App I ication".
2.2 Aerial Helicopter Granular Herbicide Application
ln November 2024, DPG also conducted dispersal of granular herbicides by helicopter on
approximately 600 acres creating fuel breaks for the purpose of firebreak establishment,
maintenance, and control of undesirable non-native vegetation. This project was
implemented to control invasive weed species at DPG and lower the risk of range fire
ignition. The herbicide used, imazapic, commonly referred to by its trade name, Open
Range G@, was chosen for its specific characteristics that meet DPG's need to eliminate
multiple invasive weed species with very low toxicity to wildlife and the environment.
Open Range G@ is a pre-emergent herbicide that kills cheatgrass seeds as they
germinate, which provides effective controlfor up to 2 years.
Application of the granular herbicide occurred along the perimeter roads around Granite
Mountain, Ambush Alley, the tank trailfrom EV to Carr, and a firebreak that extends from
Rough Haul Rd northeast to the eastern DPG boundary. The total area of application
was approximately 600 acres. Locations of aerial treatment areas have been provided in
Appendix A Map 2, "2024 Aerial Helicopter Granular Herbicide Application".
2.3 Firebreaks
Firebreaks are the portions of fuel breaks that are unvegetated roads, or other
unvegetated features; they provide firefighters safe access. Certain roads that are
important to fire planning may not have a green strip alongside them, but are key to
human evacuation safety, or otherwise provide an added alternative for fire suppression.
During 2024, DPG partnered with the Bureau of Land Management (BLM) to support the
BLM OperatorTraining, DozerAcademy for BLM crews. Multiple crews cut approximately
35.14 miles of firebreaks along the DPG North boundary and RATO breaks, around Stark
Rd Rifle Range, the Pistol Range, West Dump Road, the DPG Eastern boundary, the
Fries Park guzzler, and SE Granite. Locations of newly cut firebreak areas have been
provided in AppendixA, Map 3,.BLM Dozer Academy Firebreak Area CY24".
Additional dirt roads located source-wide are considered key fire access roads and serve
as firebreaks. Dirt roads including those which parallel fence lines are graded and
maintained annually to at least 4-wheel drive fire engine capability. Key roads include
North Village lnterior Security Fence Line Road from the eastern main gate around
Colonel Hill and English Village and back to Stark Road; East Security Fence Line Road
from Stark Road south along this eastern security fence line around to Durand Road;
North Gate Road; Downwind West Road to Pigeon Loft Road; Road 5700; North Rough
Haul Road; Newt's Alley; White Sage lmpact Area; and Camp Tumbleweed Road.
Locations of dirt roads which are graded and maintained annually are provided in
AppendixA, Map 4, "Roads/Fenceline Graded and Maintained as Firebreaks".
2.4 Tumbleweed Gontro!
Each year, primarily in spring, certain segments of the DPG fences build up with mounds
of loose, dead tumbleweeds which blow in and stick against the fence lines. Many
ravines, ditches, and depressions accumulate tumbleweed which greatly increasing fire
hazards. Extreme fire behavior can be expected from these situations. Controlling
tumbleweeds and managing areas where tumbleweeds accumulate by manually
removing them reduce fire spread rates. During CY24, tumbleweed caches located
source-wide were removed using hand tools and a baler for gathering and transporting
baled tumbleweeds to the landfill.
Locations of primary fence lines which collect tumbleweed caches have been provided in
Appendix A, Map 5, "Primary Fenceline Tumbleweed Collection Areas".
3.0 Long-term Fire Projections
By treating fuels in advance, DPG can mitigate and reduce the risk of wildland fires by
eliminating or reducing flammable fuels through prescribed burn activities. Long-term fire
projections detailing planned prescribed burn activities projected to occur during calendar
year 2025 (CY25) have been outlined in the table below.
of Future Prescribed Firc
Planned Season(s)RX Name Location Area
Estimated
Acreaoe
Sorino Saoohire Saoohire Mountain 165
Sprinq, Summer Guzzler Frys Park 40
Sprinq, Summer Uooer Pistal RX Piles Uooer Pistal Ranqe 3
Sorinq. Summer Difto RX Pile Bv station 3 2
Sorino, Summer Ambush Alley Wio Mountain 172
Sorino. Summer lnterqetic Wio Mountain 42
Sorino, Summer Mustanq Wio Mountain 12
Sorino. Summer GWAT GWAT 19
Sorino. Summer Snioer Granite Mountain 5
Sorino, Summer Mica Bum 1 West Granite 65
Sorino. Summer Mica Bum 2 West Granite 2
Sorinq, Summer Mica Bum 3 South Granite 25
Sorino. Summer East Camel Back Brauch Tunnel 12
Sorinq, Summer Ridoeline GBTF 5
Sorino. Summer Prime Prime Pit 15
Sorinq, Summer Vickers Villaoe South Camelback 22
Sorino. Summer. Fall White Saoe White Saqe 593
Sorino, Summer, Fall GLCM North Wio Mountain 4
Sorino. Summer, Fall MTO North Wio Mountain 174
Sprinq, Summer, Fall, Winter CM lmoact North Wio Mountain 29
4.0 References
1 . State of Utah Department of Environmenta! Quality (UDEQ), Utah Division of Air
Quality (UDAQ), Salt Lake City, Utah, Title V Operating Permit 4500003005 lssued
to United States (U.S.) Army Dugway Proving Ground (DPG), Utah.
2. United States (U.S.) Army, Dugway Proving Ground, Dugway, Utah, lntegrated
Wldland Fire Management Plan, June2017.
3. Utah Office of Administrative Rules, Utah Administrative Code, R307.
Environmenta! Quality, Air Quality.
4
APPENDIX A
MAPS
Table of Contents
Appendix A
Map 1. C130 Aerial Herbicide Application ...................A-1
Map 2. Aerial Helicopter Granual Herbicide Application.............. .................A-2
Map 3. BLM DozerAcademy Firebreak ...A-3
Map 4. Roads/Fenceline Graded and Maintained as Firebreaks.......... .......A-4
Map 5. Primary Fenceline Tumbleweed Collection Areas ...........A-5
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