Applicants: Jack Locations: Carl Nate Designated Kevin Dec. Guay. Snv Langlois. for dor. Red Apex Apex climbing Moab River United Colorado Mountain Mountain Desert Adventures. and Special Bureau canvoneering School Adventures. States School. School, DOl-BLM-UT-V010-2019-145 Determination Recreation 1140 of Moab P0 Mines. Colorado of Phone: Department Moab. S. Moab routes 82 39 Box Land Main Desert East .June E. 1500 7331. Permits 435-259-2100 Field Center of in Utah and Dogwood School St.. the 2019 NEPA Adventures Illinois Avon, Management 0111cc Moab. 84532 Moub Street. and of Adequacy Street. CO Mines, of.the Amendments UT Field Moab. 81620 DNA 84532 Golden. Office Red UT Interior River 84532 CO 80401 Adventures I

I Worksheet Determination of NEP.4 Adequacy L.S. Department of [he Interior Utah Bureau of Land \Ianagement

The signed CONCLUSION at the end of this worksheet is part ofan interim step in the BLM’s internal analysis process and does not constitute an appealable decision: however, it constitutes an administrative record to be provided as evidence in protest. appeals and legal procedures.

OFFICE: Moab Field Office

PROPOSED ACTION TITLE: Special Recreation Permits and Amendments for Apex Mountain School. Colorado School of Mines. Red River Adventures, and Moab Desert Adventures.

LOCATION/LEGAL DESCRIPTION:

Climbing: Kane Creek Road (Icc Cream Parlor. Bakery. Space Tower. Predator. Abraxis. Tombstone). Highway 279 (The Scar. Kings I-land. Wall Street. Day Canyon. Culvert Canvon/Camcltoe. Jug Ilandle. Off \\idth Cit . lIighw tn 128 (River Road Dihedrals. Drinks Canon. Fake Out Beach Crags. Lighthouse Tower. Dolomite Tower. Big Bend Butte. Big Bend Boulders. Castle Valley (Castleton Tower. the Rectory, the Priest. Sister Superior. Parriott Mesa/Crooked Arrows Spire) Fisher Towers (the Lizard. Ancient Art. Kingfisher). and Utopia aka Terma.

Canyoneeuing: Mystery Towers (in side canyon of Onion Creek), Cable Arch. Cdmeltoe (Culvert). Entrajo (Chamisa). Fins and Things/Cactus Bowl and Bow and Arrow (Longbow

APPLICANTS: Jack Guav. Apex Mountain School. P0 Box 7331. Avon, CO 81620 Kevin Langlois. Colorado School of’Mines. 1500 Illinois Street. Golden, CO 80401 Carl Dec. Red River Adventures. 1140 S. Main St.. Moab. UT 84532 Nate Snydor. Moab Desert Adventures. 39 E. Center Street. .1oab, UT 84532

A. Description of the Proposed Action and Any Applicable Mitigation Measures

Jack Guay. on behalf’of Apex Mountain School. seeks a SRP to offer guided commercial rock climbing at various designated climbing locations within the Moab Field Office. (I-Icalso wishes to add mountain biking and hiking to his permit — these activities are analyzed separately). Apex Mountain School has had a permit with the Moab BLM. but it lapsed in 2017. I-Icseeks renewal at this time. For climbing locations. Mr. Guay asks for big Bend Bouldering. the Ice Cream Parlor. Wall Street. Day Canyon .Abraxis Wall. the Fisher Towers Group. the Castleton Group and the Lighthouse. For canvoneering. he has asked for Mvsten Tower in Onion Creek All use would be day use only, with an’ overnight use occurring at designated campgrounds or private facilities. As this is a renewal of a previous permit. it would be issued for a period of tem years. Standard stipulations as well as canvoneering and climbing—specificstipulations would apply to the SRP for Apex Mountain School.

Kevin Langlois. on behalfof Colorado School of Mines. seeks renewal of his SRP to oiler climbing trips at Wall Street in the Moab Field 0111cc(he has also asked for biking and hiking. which are analyzed separately) All use would be day use, with any overnight use occurring at designated campgrounds or private litcilities. Colorado School of Mines has held a permit with the Moab BLM during the 2017 calendar year. The renewal would be issued for a period often years. Standard stipulations as well as climbing specific stipulations would apply to tile SRI for Colorado School of Mines.

Carl Dec. on behalf of Red River Adventures, has requested an augmentation of his permit to add canyoneering and rock climbing locations (Abraxis Wall. tile Baker. Space Tower. Predator. Tombstone. Utopia (Terma) .Jug 1-landle.Oil Width City. Zig Zag (aka Bounce Test. Fins and Things canyoneering route. Cable Arch and Bow and Arrow (Longbow). All use would be day use. with any overnight use occurring at designated campgrounds or private focilities. Red River Adventures has had a permit with the BLM since 2010. The climbing and canvoneering routes would be added to their permit for the 2019 year. with an option to renew for a period often years. (Red River’s permit expires at the end of the 2019 year). Standard stipulations as well as climbing and canyoneering specific stipulations would apply to the SRP for Red River Ad en tu res.

Nate Snydor. on behalf of Moab Desert Adventures, has requested the following designated canyoneering and climbing locations be added to his permit: ZigZag (Bounce Test). Abraxis Wall. Utopia (Terma) and Cable Arch. Moab Desert Adventures has had a permit with the Moab BLM since 2011. The routes would he added to Moab Desert Adventures’ current permit. which expires at tile end of2020. Standard stipulations as well as climbing and canyoneering specific stipulations would apply to the SRP for the Moab Desert Adventures.

13. Land Use Plan (LUP) Conformance LUP \ame Moab Resource Management Plan Date Approved October. 2008 * List applicable LUPs (for example. resource management plans; activity, project. management or program iiins: or applicable amendments thereto). The proposed action is in conformance with the applicable LUPs because it is specifically provided for in the following [UP decisions: Page 97 of the Moab RMP reads as follows: Special Recreation Permits are issued as a discretionary action as a means to: help meet management objectives, provide opportunities for economic activity, facilitate recreational use of public lands, control visitor use. protect recreational and natural resources, and provide for the health and safety of visitors.” In addition. page 98 states: “All SRPs will contain standard stipulations appropriate for the type of activity and may include stipulations necessary to protect lands or resources. reduce user

conflicts, or minimize health and saibty concerns. . Issue and manage recreation permits for a wide variety of uses to enhance outdoor recreational opportunities. provide opportunities for private enterprise, manage user—group interaction. and limit the impacts to such uses upon natural and cultural resources.” Amendment considered

.-lmendmcnt Cable other A Canyon C. Aai’iec, Environmental Environmental NEPA Environmental explain Environmental in En project Highlights, to 2. Jackson environmental impacts locations 1. respect Documentation Documentation proposed values, YOl BLM—UT—YOlO—2015—0l

mnemic/nments

the those

Is

Is

Identify

No

ironmental

0-2010-0082.

the

the

related

Arch.

existing

Adequacy

Yes Yes

No and

signed

location why to Ibr

of

hole

analyzed

new is

range

action

the

permitted

under

canyoneering

signed

circumstances specifically for

fin

the

for

they

\ioiiniam

documents

proposed

new

Assessment Assessment December Assessment Assessment Assessment

NEPA

Pmnpkni

Desen

o of

concerns,

of

applicable

and

A-/nab

is

this

are DOI-BLM-UT-Y0I answer Criteria

answer

May in

alternatives

different,

proposed

a

climbing

the

Proposed

no

not document(s)?

!-hig/mlight.v.

(

4. contained

Un/c/es.

amivon

action

Patch,

73

existing

action (this

28.

that and

and 2018.

have substantial?

interests,

DOl—BLM-UT-Y0 DOl—BLNI—UT—Y0

DO1-BLM-UT—Y01 DOl—BLNI-Ll—Y0 DOl—BLM—UT—Y0

National

and

20l

are

action

explanation:

explanation:

and

is

cover

Action

Tourv.

not a

analyzed

signed

alternative.

signed

DOl—BLM—UT—Y010—2012—02l2 covers

also

2

feature

the

NEPA

in

signed

canyoneering

analv/.es

changed

the

and

(or

the

called

Is Environmental

geographic

0-2016-0048.

Wi

except

on

February

the

the

NEPA

existing

proposed

document(s)?

ndgate. resource

December

of,

in

August

Fins

Yes:

Yes:

project •the

the

l’he

to

the

or

Utopia

10-2016—0048,

l0—2012—0212. 10—2015—0173

10—2010—0082

a

0-2017-0l05, documents.

canvoneenng

and essentially

environmental

the existing

Environmental

tours degree

2010.

Moab

Bounce

proposed

and

13.

values?

action.

e<

within

DOl-BLM-UT-Y01 the

16.

Terma.

2017,

Policy

within

resource

sting

Cliffs This

that Bow

2015.

Ii

NEPA

Test).

there

the similar

covers

..Spccial

action),

wtrrants

NEPA

covers

Special

Special

Spec Act Special and the

activities and

analyzes

concerns,

same

Assessments

conditions

document(s)

are

Moab

each Arrow

(NEPA)

mcml

Canyons

Utopia/Terma.

documents

to,

all

given

differences,

Recreation

Recreation Recreation Recreation

Recreation

analv

broader

contain

of an

Field at

the

0-2017-0105.

canyoneering

interests,

the

Mster

alternative

documents

current

sis use

and

sufficiently

Office.

DOl—BLM—UT— climbing

consideration.

appropriate

area,

analysis

address

of

Desert

Pci,;,,! Permit

Peminit Permnu Penn/i

can

ZigZag

Canyon

resource

or

Each

you

analyzed DOl

routes. and

locations

the

oithe

if

for

for

similar

the

of

and

with

the 3. Is existing analysis adequate in light of any new information or circumstances (such as, ra ngela tid hea liii sEaiii dards assessmcn t; recent cii dangcred species listings, upda led list of BLM sensitive species)? Can you reasonably conclude (lint new information and new circumstances would not substantially change the analysis of the new proposed action? 0 Yes D Documentation of answer and explanation: Yes: the existing analysis and conclusions are adequate as there has been no new information or circumstances presented. It can be reasonably concluded that all new infbrmation and circumstances are insignificant with regard to analysis of the proposed action.

4. Are thc direct, indirect, and cumulative effects that would result from implementation of (lie new’proposed action similar (1)0111quantitatively and qualitatively) to those analyzed in the existing NEPA document? OYes CNo Documentation of answer and explanation: Yes’•.the direct and indirect impacts are substantially unchanged from those identified in the existing NEPA documents. Yes: site—specificimpacts analyzed in the existing document are the same as those associated with the current proposed action.

5.Are the public involvement and interagency review associated with existing NEPA document(s) adequate for the current proposed action? EYes DNo Nes: —Thepublic was notified of the preparation of Environmental Assessment DOl—BLM—UT—Y0l0- 2010—0082.Special Recreation Peinni for lackvon Hole .1lotoitain Guides, when it was posted on ENBB January 6. 2010. A thirty—daywaiting period ibr actions in a WSA was imposed on this action.

The public was notified of’the preparation of Environmental Assessment DOl—BLM—UT—Y0I0— 2016—0048.Special Recreation Permit ;lniemlnieizi lop I’iunpkinPatch when it was posted on the ePlanning website on December 1,2015.

The public was notified of the preparation of Environmental Assessment DOl—BLM-UT—Y0l0— 2012—0212.Spechil Recreation Peinilt fin ;Vai’iec.\\hen it was posted on the ENBB on August 24. 2012. This included a 30—da’notification period for actions in a WSA.

The public was notified of the preparation of Environmental Assessment DOf—BLNI—Ui’—VOIO— 2015—0173. Special Recreation Pennu niendniciii for Desert Highliglu.v.when it was posted on the ENBB website on April 17. 2015. This included a 30-day notirifcation period for actions in a \VSA.

The public was notifled of the preparation of Environmental Assessment DOl—BLNI—UF—VUI0—

, II A 20 I7—0I05. Special Recreation Penn/i :1Iiient/iiIe its for :\loan Cwit c)ii ioiu’.s bitIL’cite. bob C7ifi.and L’u,nvns mid Deceit Highlights, when it was posted on the ePlanning website on January 27. 2017.

This constitutes adequate public notification for the current proposed action.

E. Persons/Agencies/BLNI Staff Consulted:

Name Title Resource Represented

Gabe Bissonette 1-lydrologist Air quality: Water quality: Floodplains. Wetlands, Soils

I I Katie Stevens Recreat ion P1anncr Arcas niC riLieu Environment a Concern: Visual Resources, Recreation, Wild & Scenic Rivers

David Pals Geologist Wastes (hazardous or solid), Geology. Paleotitologv

Ashley Losey Archaeologist Cultural Resources: Nat Re Aineric:in

• Religious Concerns

Jordan Davis Range Management Specialist I invasi’. e. Non—native species: Threatened. Endangered, or Candidate Plant Species: Wood land

Pain Riddle Wildlife Biologist Threatened. Endangered. or Candidate Animal Species. Miiracory Birds. Visitatid Wildli(ë, Utah BLM Sensitive Species

Bill Stevens Recreation Planner Wilderness. Environmental Justice. Lands with Wilderness Characteristics. Socioeconotnics. BLM Natural Areas

Liz Cresto Realty Specialist Lands/Access

CONCLUSION Plan Conformance: proposal conforms to the applicable land use plan.

This proposal does not conform to the applicable land usc plan

Determination of’NEIA Adequacy

Based on the review documented above. I conclude that this proposal conforms to the applicable land use plan and that the NEPA documentation Iiill covers the proposed action and constitutes BLM’s compliance with the requirements of the NEPA. The existing NEPA documentution does not fully cover the proposed action Additional NEPA documentation is needed if the project is to he further considered. Decision Documentation: D A new decision will be prepared The Proposed Action is a subset of existing decisions. Therefore no new decision needs to he prepared

Signature of Project Lead Date tvfto( /cj Signature of NEPA Coordinator Date L ‘o/t(i Siunature of th ResponsIble C)flicialflt 44Izr Date Note: The signed Conclusion on this Worksheet is putt of an interim step in the BLMs internal decision process and does not constitute an appealable decision. l-lo e cr. dc lease. permit. or other authorization based on this DNA is subject to protest or appeal under 43 CFR Part 4 and the program—speciticregulations.

ATTACHMENTS:

II) Team Checklist WSA Report Determ DETE ‘lilt NC’ NC RESOURCES NC NC NC NC NC NC NC NC NC NC NC NC NC NC’ ! ion NP The Recreation Project NI Proj NEI’A P1 NC Project kM I— = = = = Section Farm ccl present bI present. not ( urnkinusurfliceiground WetIaitds IN \\atcr DN En’. Wild lo\\ Log Lands Title: En’. Description: Leader: ATI ltcligicitis Cultural present lands Snciti—l: Visual Witdcrncss;V.SA Circenliouse .-\rcas Nato As nonnienial ing Characteristics fl Permit irunincittal Nuitiber: and ANI) Flnodplains Air ResuurcestQuahi’. I) with Recreation lnussions Resource M ON mith but only) . Special elements oltlw c Riparian s.iiR (Prime Quality ot Natural Scenic Resources t.iiioii:is Katie \inenean in not Resources potential ISSUES OF Wilderness C C amendnients actions oncer:is the ritical . C affected DNA Gas itisticc . STAFF: DOI-BLM-UI-Y0l0-2019 onccrn Conducting Recreation Rn or Areas Ste INTERDISCIPLINARY area Zones are Lin cr5 CONSIDERED veils loon. and or not impacted ique). to relevant (Cl: present impacts a br The Pennits degree climbincanoneering vase Wild Red Rationale by impact in Ri’. not one 1-lorses dc that (INCLUDES the or Roliopiale er changed of proposed .ApeN Moab detailed Ad’. that iheftillowing column and -0115 entures need Niountani Field Burros. horn for analysis StIPPLEMENIALAUTHORITIES or to ma\ Detern,iliation* alternative 0111cc and those tours be DNA TEAM iiicltide ahhret’iak’d anakzed School .\ is on loab disclosed and required standard actions Desert NI ha’. and in CHECKLIST and e Colorado detail options in been routes Adventures the NP removed in cx discussions. fin’ the sting School the

Kk-Làteec EA N liom Gahe left Marie APPENDIX EPA Katie Katie Katie K:iiie Ashle\ :\l:le’ ol Bill BiE Bill Bill Bill David Signature cohunn) \Inies the Kiss Sie’.ens Stc’en9— Sw Stevens Sic’.eit Mc(fuin documents — Ste’. Ste’ SIc’ Stc’.cns I Lose Pals checLl n ose ens ens ens ens and I , ttc I j

C 11-1790-I) Special sr cited

e/Ii/)

k/i

6j

,/tp y/,

i

Ic/nfl?

0/’, (i I

I Date fJ

‘hg it in — .,

/ — I r

ii’

‘7 Deterini— Resource Rationale for Deternhinntion* Signature Date nation -

N \astc% I)a id Pal.’ r i - i tc (haiai-dous or scuitd

Xc lhrcatcicd. I ioa:tgercd or Candidate Animal Pam Rtddle (p7 i Spctcs /17/f NC Pain Riddle k Migratory Birds — NC Utah HIM Scnsitic I’ttt 1tith / Species /12/iQ NC Fish and Wildlife ‘ant Riddle \ I-xcltiding IISFW , / Dc,iiiiated Specie- F /I i//f XC I,t’asi’c Speeic \o\Ions I’/19 \\ccds ?i-t,t_ 4

XC I lircatened. I adaneered or CanLhdate Plant Pam Riddle/L

NC Livestock Grazing

NC RangdandlIeaIih q

NC Vegetattoit r; \CI oditig j ;i___—— iVUi’Ij

itodlaitti I tirett 5_

:: Josh Relph I ads/lire Nlaitauetnent

NC Geologs I N-Iineral Da id Pals Resoorces/Lnerg\ (Ii Irodttctititi 9 NC Laitds/Aecess Liz Urestt,

I’_IlelIltittigy I)a c Pal,- bt’ 1q

FINAL R[VIEV:

at4.e G- uLL() ______Yes

WILDERNESS INTERIM MANAGEMENT IMPAIRMENT/NON- IMPAIRMENT EVALUATION FORM With the passing of the deadline for comoletion of reclamation activities in September of 1990, only temporary, non—surface—disturbing actions that require no reclanatior.; crandfathered uses, and actions involving the exercise of valio ezzstzrg rights car. be approved within NSA’s. The reference document far evacators and nar.acers is ManuaZ 6330, Management of WiZdernes s Study Areas (JuZv, 2012)

DESCRIPTION OF ACTION

Name of action: DOI—BLM—UT—Y010—2019-035 DNA

Proposed Action: X Alternative Action: (check one)

Proposed by: Apex Mountain School, Colorado School of Mines, Red River Adventures, Moab Desert Adventures

Description of action: Apex Mountain School, Colorado School of Mines, Red River Adventures, and Moab Desert Adventures have requested authorization through new or amended Special Recreation Permits (SHE) to offer canyoneering and rock cliiLbinj trips to participants on desionated canyoneering and climbino locations in the Noah Fied Office of the s::i. Trips are day use only. Two of the additional canyoneerino routes (Zig Zag, Fins and Things) are within Wilderness Study Areas (NSA). Apex Mountain Schoo, Ccorado School of Mines, Red River Adventures, and Moab Desert Adventures each would have a maximum group size of 5 with 2 guides. Standard st:Puaticns would appy to the SR? for Apex Mountain Scnool, CoZorado Schoo of Mines, Red River Adventures, and Moab Desert Adventures. The only portions off the pervit analyzed in this dccunent are those activities within the ‘Ss. Location: Zig Zag, Fins and Things

What BLM WSAs are included in the area where the action is to take place? Behind the Rocks, Mill Creek Canyon

VALID RIGHTS OR GRAnDFATHERED USES (if any)

Is lease, mining claim, or grandfathered use pre—FLPMA? Yes X No

If yes, give name or number of lease(s) , mining claim(s) or grandfathered use and describe use or right asserted:

Has a valid existing right been established? X No

EVALUATION OF POTENTIAL FOR IMPAIRMENT OF WILDERNESS VALUES

Is the action temporary and non-surface disturbing? K Yes______No If yes, describe why action would be temporary and non—surface disturbing and identify the planned period of use:

1 Activity would consist of commercial guided canyoneering tours. Commercial activities are permitted uses in wilderness, including NSA’s. The Wilderness Act states: “Commercial activities may be performed within the wilderness areas designated by this Act to the extent necessary for activities which are proper for realizing the recreational or other wilderness purposes of the areas.” The BLM’s Manual 6330, Management of Wilderness Study Areas (July, 2012), states that most recreational activities are allowed within NSA’s. Failure to adhere to the permit’s stipulations could result in non—renewal by the BL:’s Administrative Officer. When the use, activity, or facility is terminated, would the areas wilderness values be degraded so far as to significantly constrain the Congress’s prerogative regarding the areas suitability for preservation as wilderness?

Naturalness: Effects to the natural environment would center on trails and natural travel routes where canyoneers could travel. Temporary ircacts could involve soils ar.d vegetation. Naturalness as an ingredient in wiLderness is defined as lac::ing evidence of man’s impacts on a relatively permanent basis. None of the potential effects described above would affect significantly this aspect of naturalness essential to wilderness character. Outstanding Opportunities for Solitude: This activity would not decrease opportuLities for solitude relative to their current status. The Zig Zag route through Hoonflower Canyon in the Behind the Rocks ;cSA is on its very periphery, and in an area receiving little current public use, presumably because of its technical difficulty. Most of the route that canyoneers would travel is very close to the paved and heavily usod Kane Creek road. If this were the only travel route in the area, there could he s:::fts concern for impacts to solitude . However, the 1991 EIS points out that the large number of fins and narrow canyons in this ;;SA provide numerous opcrtunities for selection of unused travel rcutes. Specifically, the above—mentior.ed report states:

“Regardless of the outside influences prcximity to Hoab, it is easy for a visitor to find seclusion within the WSA due to the screening and alternate travel paths afforded by the sandstone fins. In these areas, sights and sounds of others within the unit can easily be avoided”. 1931 Utah Scate:’ide ;cilierzess Study Report, Voiune 113, p. 706)

The Fins and Things route in the Mill Creek Canyon NSA receives very little current use, and is generally located in the front country portions of the NSA not necessarily providing these opportunities. Outstanding Opportunities for Primitive and Unconfined Recreation: There is no reason to believe that the proposed action will reduce these opportunities. There are no plans for trail construction or other modifications of the area. The activities would take place in portions of the NSA’s identified in the original wilderness inventories as front—country locations not necessarily providing such opportunities.

Optional Supplemental values: No perceived negative impacts. The 1990 Final

2 ____Yes____No

Environmental Impact Statement identified several threatened and endangered animal and plant species that may occur in the WSA. The current status is - the presence of several plant species on the Utah state sensitive list. These species are all alcove plants, and do not occur along the canyoneering route where the proposed action woud occur. Considered cumulatively with cast actions, would authorization of the action impair the area’s wilderness values? Yes X No Rationale: Canyoneering and commercial activities are permitted not onv in WSA’s, but in officially—designated wilderness.

RESULTS OF EVALUATION Non-impairment Standard

The only actions permissible in study areas are tencorarv uses that do not create surface disturbance, require no reclamation, and do not. involve permanent placement of structures. Such temporary or no—trace activities may continue until Congress acts, so long as they can be terminated easily and immediately. The only exceptions to the non—impairment standard are:

1) emergencies such as suppression activities associated with wildfire or search and rescue operations,

2) reclamation activities designed to minimize impacts to wilderness values created by IMP violations and emergencies;

3) uses and facilities which are considered grandfathered or valid existing rights as defined in Manual 6330,

4) uses and facilities that clearly protect or enhance the land’s wilderness values or that are the minimum necessary for public health and safety in the use end enjoyment of the wilderness values, and

5) recThnatior. of pre—ELEM.. impacts.

MAJOR CONCLUSION OF NON-ThAIRI€NT EVALUATION Action clearly fails to meet the non—impairment standard or any exceptions, e.g. WR, and should not be allowed: N No

Action appears to meet the non—impairment standard: N Yes _No

Action may be allowable, pre-FLPMA grandfathered use: Yes X N/A

Action may be allowable, pre-FLPMA VER: Yes No N N/A

OTHER CONCLUSIONS

Restrictions proposed may unreasonably interfere

3 ____Yes______Yes___YesK ______

with pre-rtPMA rights or grandfathered uses: No K N/A Reasonable measures to protect wilderness values and to prevent unnecessary or undue degradation of the lands are incoroorated: K Yes No_____ N/A

Environmental Assessment required: K Yes No

Plan of Operations Required: No K N/A

Discovery verification procedures recommended: No X N/A

Consider initiating reclamation through EA: No K N/A

RELATED ACTIONS’ Dated copy of Electronic Notification Board notice attached to case file: X Yes

Media notification appropriate: (optional) K No

Federal Register Notice appropriate: (optional) No

Information copy of case file sent to USO-933: K No

Evaluation prepared by: William P. Stevens June 19, 2019 Name(s) Date

4