United States Department of Agriculture

Malheur National Forest SiteSpecific Invasive Plants 

Treatment Project

Final Environmental Impact Statement

Forest Service

Malheur

National Forest March 2015
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Malheur National Forest Site-Specific Invasive Plants

Treatment Project Final Environmental Impact Statement

Grant, Baker, Harney, Malheur and Crook Counties, Oregon

Lead Agency: USDA Forest Service

Malheur National Forest

Responsible Official: Steve Beverlin, 

Forest Supervisor

Malheur National Forest

431 Patterson Bridge Road

PO Box 909

John Day, OR 97845

Information Contact: JOSEPH H. RAUSCH

Malheur National Forest

431 Patterson Bridge Road

PO Box 909

John Day, OR 97845

Phone: 541-575-3141

Email: jhrausch@fs.fed.us

The FEIS can be viewed and downloaded from the internet at 

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=35614. In addition, an electronic copy on a CD 

or a hard copy is available upon request from Joseph H. Rausch using the contact information provided 

previously.

Abstract

This final environmental impact statement (FEIS) discloses the effects of treating invasive plants in the 

Malheur National Forest. Invasive species were identified by the Chief of the Forest Service as one of the 

four threats to forest health (for more information see http://www.fs.fed.us/project/four-threats). Invasive 

plants are displacing native plants, potentially destabilizing streams, reducing the quality of fish and 

wildlife habitat; and degrading natural areas. 

We propose to treat invasive plants using integrated treatment methods in cooperation with our neighbors, 

and in accordance with the Pacific Northwest Region Invasive Plant Program Preventing and Managing 

Invasive Plants Record of Decision for Invasive Plant Program Management (USDA Forest Service 

2005b, herein referred to as R6 2005 ROD)and other relevant management direction, to reduce the extent 

and impact of invasive plants. The underlying purpose of treating invasive plant infestations is to maintain 

or improve the diversity, function, and sustainability of desired native plant communities and other natural 

resources that can be adversely impacted by invasive plant species. 

The project area encompasses the entire 1,459,422-acre Malheur National Forest and 240,000 acres of the 

Ochoco National Forest that are managed by the Malheur Forest (previously known as the Snow 

Mountain Ranger District, now managed as part of the Emigrant Creek Ranger District.) for a total of 

nearly 1.7 million acres located in eastern Oregon. These 1.7 million acres is the acreage considered as 

the Malheur National Forest for purposes of this analysis. We estimate that at this time (using our updated 

inventory), approximately 2,124 acres of invasive plants need to be suppressed, contained, controlled or 

eradicated.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Invasive plant spread is unpredictable and actual locations of target species may change abruptly over 

time. Accordingly, we need the flexibility to adapt to changing conditions, and rapidly respond to invasive 

plant threats that may currently be unknown. Timeliness of action is an important factor because the cost, 

difficulty, and potential adverse effects of controlling invasive plants increases with the size and extent of 

the population. The smaller the population when treated, the more likely the treatment will be effective. 

The proposed action includes a decision process and design features to ensure that treatments used for 

rapid response to new detections are within the scope of this analysis. This FEIS includes detailed 

consideration of four alternatives:

• Alternative A, the no-action alternative would not approve any invasive plant treatments. 

• Alternative B, the proposed action, is our proposal as the most cost-effective approach to invasive 

plant treatment while minimizing the adverse effects of treatment. Alternative B responds to the 

purpose and need for action by authorizing several herbicide and other integrated treatment methods 

on the ground. . Treatment options are intended to effectively reduce the size and density of invasive 

sites and abate the adverse effects of invasive plants. The project would continue to be implemented 

each year until the treatments were no longer needed or conditions substantially change on the ground 

to such a degree that the analysis in this EIS is no longer valid. The annual implementation planning 

process discusses how changed conditions would be evaluated for this project over time. This 

alternative would comply with standards and guidelines associated with invasive plant management 

and allow use of any of the 10 herbicides authorized for use in the R6 2005 ROD. It would also 

amend the Malheur National Forest Land and Resource Management Plan (LRMP) to allow the use 

of a new herbicide ingredient, aminopyralid.

Two action alternatives were developed in response to public issues related to herbicide use:

• Alternative C was developed in response to some public concerns about herbicide use on the Malheur 

National Forest. Alternative C would impose strict limitations on our ability to use herbicides to treat 

invasive plants. Compared to alternative B, alternative C responds to public issues about herbicide 

impacts to human health, non-target vegetation, soils, water, aquatic organisms, and wildlife, while 

still allowing for some limited herbicide use. Under alternative C, all of the alternative components 

for alternative B would be followed (including a Malheur National Forest LRMP amendment to allow 

use of aminopyralid), except that broadcasting/boom spraying would not be allowed; herbicide use 

would not be allowed within the boundaries of any mapped infested area that at any point is within 

100 feet of creeks, lakes, ponds and wetlands; and no picloram would be used on the Malheur as a 

part of this project. Components of alternative B that apply to broadcast spraying, herbicide use 

buffers within 100 feet of water bodies, and picloram would not apply to alternative C. 

• Alternative D - no use of aminopyralid was developed to evaluate the tradeoffs involved with using 

aminopyralid for invasive plant management, thereby effecting a Forest Plan amendment. Alternative 

D would be similar to alternative B, except aminopyralid would not be approved for use on the 

project and a Forest Land and Resource Management Plan amendment would not be completed. 

Aminopyralid would not be used to treat known sites or new detections. All of the components of 

alternative B would apply, except those that refer to aminopyralid would not be included. 

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Malheur National Forest Site-Specific Invasive PlantsTreatment Final Environmental Impact Statement

Figure 1. Vicinity Map

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

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Malheur National Forest Site-Specific Invasive PlantsTreatment Final Environmental Impact Statement

Table of Contents

Summary _______________________________________________________________________ 1

Introduction___________________________________________________________________ 1

Extent of the Primary Target Species and Management Objectives________________________ 1

Integrated Control Measures______________________________________________________ 3

Alternatives___________________________________________________________________ 7

Alternative Comparison _________________________________________________________ 9

Chapter 1. Purpose and Need for Action______________________________________________ 17

1.1 Introduction_______________________________________________________________ 17

1.2 Background_______________________________________________________________ 18

1.3 Project Area ______________________________________________________________ 19

1.4 Desired Future Conditions ___________________________________________________ 21

1.5 Purpose and Need __________________________________________________________ 21

1.6 Proposed Action ___________________________________________________________ 21

1.7 Management Direction ______________________________________________________ 22

1.7.1 Land and Resource Management Plan _______________________________________ 22

1.7.2 Additional Guidance ____________________________________________________ 26

1.8 Decision to be Made ________________________________________________________ 27

1.9 Public Involvement and Scoping ______________________________________________ 28

1.10 Issues___________________________________________________________________ 28

1.10.1 Treatment Cost-Effectiveness ____________________________________________ 28

1.10.2 Herbicide Impacts to Human Health _______________________________________ 29

1.10.3 Herbicide Impacts on Non-target Vegetation_________________________________ 29

1.10.4 Delivery to Water and Potential Herbicide Impacts on Fish _____________________ 30

1.10.5 Herbicide Impacts on Wildlife ____________________________________________ 30

1.10.6 Other Issues __________________________________________________________ 30

1.11 What this Proposal Does Not Include__________________________________________ 32

Chapter 2. Alternatives, Including the Proposed Action__________________________________ 33

2.1 Introduction_______________________________________________________________ 33

2.2 Extent of the Primary Target Species and Management Objectives____________________ 33

2.3 Alternatives Considered in Detail______________________________________________ 35

2.3.1 Alternative A – No Action ________________________________________________ 35

2.3.2 Alternative B – Proposed Action ___________________________________________ 37

2.3.3 Alternative C – Strict Limitations on Herbicide Use ____________________________ 68

2.3.4 Alternative D – No LRMP Amendment, No Aminopyralid ______________________ 73

2.4 Alternatives Considered but Eliminated from Detailed Study ________________________ 78

2.4.1 Alternative to Evaluate Effectiveness of Past Treatments by a Third Party __________ 78

2.4.2 Limitations on Herbicide-use Rates for All Herbicides __________________________ 78

2.4.3 Mandatory Decline on Herbicide Use Over Time ______________________________ 78

2.4.4 Use of Herbicides as a Last Resort__________________________________________ 79

2.4.5 Use of Herbicides for Only the Highest Priority Target Species ___________________ 79

2.4.6 No Herbicide Use in a Variety of Areas _____________________________________ 79

2.4.7 No Early Detection/Rapid Response (EDRR) _________________________________ 80

2.4.8 Increase Size of Herbicide Use Buffers ______________________________________ 80

2.4.9 No Herbicide Use_______________________________________________________ 80

2.4.10 No Use of Certain Herbicides ____________________________________________ 80

2.5 Alternatives Compared ______________________________________________________ 81

Chapter 3. Affected Environment and Environmental Consequences _______________________ 89

3.1. Introduction ______________________________________________________________ 89

3.1.1 The Effects Analysis ____________________________________________________ 89

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

3.1.2 Herbicide Risk Assessments ______________________________________________ 90

3.1.3 Site Types_____________________________________________________________ 95

3.1.4 Treatment Costs and Effectiveness _________________________________________ 96

3.1.5 Introduction to the Cumulative Effects Analysis______________________________ 103

3.2 Human Health____________________________________________________________ 119

3.2.1 Introduction __________________________________________________________ 119

3.2.2 Affected Environment __________________________________________________ 120

3.2.3 Environmental Consequences ____________________________________________ 121

3.3 Botany__________________________________________________________________ 131

3.3.1 Introduction __________________________________________________________ 131

3.3.2 Affected Environment __________________________________________________ 132

3.3.3 Environmental Consequences ____________________________________________ 138

3.4 Soils ___________________________________________________________________ 149

3.4.1 Introduction __________________________________________________________ 149

3.4.2 Affected Environment __________________________________________________ 149

3.4.3 Environmental Consequences ____________________________________________ 153

3.5 Water Resources__________________________________________________________ 162

3.5.1 Introduction __________________________________________________________ 162

3.5.2 Affected Environment __________________________________________________ 163

3.5.3 Environmental Consequences ____________________________________________ 167

3.6 Fisheries ________________________________________________________________ 179

3.6.1 Introduction __________________________________________________________ 179

3.6.2 Affected Environment __________________________________________________ 181

3.6.3 Environmental Consequences ____________________________________________ 189

3.7 Wildlife_________________________________________________________________ 211

3.7.1 Introduction __________________________________________________________ 211

3.7.2 Affected Environment __________________________________________________ 212

3.7.3 Environmental Consequences ____________________________________________ 242

3.8 Range __________________________________________________________________ 291

3.8.1 Introduction __________________________________________________________ 291

3.8.2 Affected Environment __________________________________________________ 292

3.8.3 Environmental Consequences ____________________________________________ 296

3.9 Recreation and Special Places _______________________________________________ 301

3.9.1 Introduction __________________________________________________________ 301

3.9.2 Affected Environment __________________________________________________ 302

3.9.3 Environmental Consequences ____________________________________________ 304

3.10 Archeological Resources __________________________________________________ 308

3.10.1 Introduction _________________________________________________________ 308

3.10.2 Affected Environment _________________________________________________ 309

3.10.3 Environmental Consequences ___________________________________________ 309

3.11 Specifically Required Disclosures ___________________________________________ 310

3.11.1 Irreversible or Irretrievable Impacts_______________________________________ 310

3.11.2 Long-term Productivity ________________________________________________ 310

3.11.3 Energy Requirements and Conservation Potential____________________________ 311

3.11.4 Non-significant Land and Resource Management Plan (LRMP) Amendment ______ 311

3.11.5 Floodplains and Wetlands ______________________________________________ 312

3.11.6 Prime Farmlands _____________________________________________________ 312

3.11.6 Permits and Licenses __________________________________________________ 312

Chapter 4. Consultation and Coordination ___________________________________________ 313

List of Preparers and Consultation _______________________________________________ 313

List of People to Whom This EIS has been Sent ____________________________________ 314

Individuals________________________________________________________________ 314

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Malheur National Forest Site-Specific Invasive PlantsTreatment Final Environmental Impact Statement

Organizations, Industry, and Local Agencies _____________________________________ 314

Oregon State Agencies ______________________________________________________ 314

Federal Agencies___________________________________________________________ 314

Local Officials_____________________________________________________________ 314

Tribal Contacts ____________________________________________________________ 314

References__________________________________________________________________ 315

Glossary ___________________________________________________________________ 338

Index ______________________________________________________________________ 353

Appendix A – Invasive Plant Inventory Watershed Analysis for the Malheur National Forest ___ 355

Summary of Invasive Plant Infestations by Watershed _______________________________ 357

North Fork John Day Sub-basin (17070202) _______________________________________ 359

Cottonwood Creek (1707020209)______________________________________________ 360

Lower North Fork John Day River (1707020210) _________________________________ 361

Middle Fork John Day Sub-basin (17070203) ______________________________________ 362

Bridge Creek- Middle Fork John Day River (1707020301) __________________________ 363

Camp Creek- Middle Fork John Day River (1707020302)___________________________ 364

Big Creek- Middle Fork John Day River (1707020303) ____________________________ 365

Long Creek (1707020304) ___________________________________________________ 367

Upper John Day Sub-basin – Main Stem Portion (17070201) __________________________ 368

Reynolds Creek-John Day River (1707020105) ___________________________________ 369

Grub Creek-John Day River (1707020106) ______________________________________ 370

Canyon Creek (1707020107) _________________________________________________ 371

Beech Creek (1707020108)___________________________________________________ 372

Laycock Creek-John Day River (1707020109) ___________________________________ 373

Fields Creek-John Day River (1707020110) _____________________________________ 374

Upper John Day Sub-basin – South Fork Portion (17070201) __________________________ 375

Upper South Fork John Day River (1707020101) _________________________________ 376

Middle South Fork John Day River (1707020102)_________________________________ 377

Murderers Creek (1707020103) _______________________________________________ 378

Upper Malheur Sub-basin – North Fork Portion (17050116)___________________________ 379

Upper North Fork Malheur River (1705011611) __________________________________ 380

Little Malheur River (1705011612) ____________________________________________ 381

Upper Malheur Sub-basin – Main Stem Portion (17050116)___________________________ 382

Headwaters Malheur River (1705011601) _______________________________________ 383

Wolf Creek (1705011602) ___________________________________________________ 384

Pine Creek (1705011603) ____________________________________________________ 385

Griffin Creek-Upper Malheur River (1705011605) ________________________________ 386

Otis Creek (1705011606) ____________________________________________________ 387

Silvies River Sub-basin (17120002)______________________________________________ 388

Headwaters Silvies River (1712000201)_________________________________________ 389

Bear Creek (1712000202)____________________________________________________ 390

Upper Silvies River (1712000203) _____________________________________________ 391

Middle Silvies River (1712000204) ____________________________________________ 392

Emigrant Creek (1712000205) ________________________________________________ 393

Sage Hen Creek (1712000206) ________________________________________________ 394

Silver Creek Sub-basin (17120004) ______________________________________________ 395

Claw Creek (1712000401) ___________________________________________________ 396

Upper Silver Creek (1712000402) _____________________________________________ 397

Middle Silver Creek (1712000403)_____________________________________________ 398

Harney-Malheur Lakes Sub-basin (17120001)______________________________________ 399

North Basin (1712000101) ___________________________________________________ 400

Malheur Slough (1712000102) ________________________________________________ 401

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Deschutes River Basin (170703) ________________________________________________ 402

South Fork Beaver Creek (1707030305) ________________________________________ 403

Appendix B - Invasive Species Monitoring Plan ______________________________________ 404

Appendix C - Adjuvant/Surfactant Information _______________________________________ 411

Adjuvant Types______________________________________________________________ 411

Wetter/Spreaders___________________________________________________________ 411

Sticker/Spreaders __________________________________________________________ 413

Oils _____________________________________________________________________ 413

Fertilizer/Surfactant Mixtures_________________________________________________ 414

Special Purpose or Utility Adjuvants ___________________________________________ 414

Colorants_________________________________________________________________ 415

Hazards __________________________________________________________________ 415

Alkylphenol-ethoxylate-based wetter/spreaders ___________________________________ 416

Alcohol ethoxylate-based wetter/spreader _______________________________________ 418

Silicone-based wetter/spreaders _______________________________________________ 419

Sticker/Spreaders __________________________________________________________ 421

Oils _____________________________________________________________________ 422

Vegetable Oils and Silicone Blends ____________________________________________ 424

Crop Oils and Crop Oil Concentrates ___________________________________________ 425

Fertilizer/Surfactant Mixtures_________________________________________________ 427

Acidifiers_________________________________________________________________ 428

Drift Reduction Agents ______________________________________________________ 429

Defoamers________________________________________________________________ 429

Colorants_________________________________________________________________ 431

Literature Cited In Bakke 2007________________________________________________ 435

Appendix D – Comments on the DEIS and Forest Service Responses _____________________ 437

Introduction ________________________________________________________________ 437

Processing and Evaluating Public Comments ______________________________________ 437

Comment Response Regulations ________________________________________________ 438

List of Tables

Table S- 1. Current treatment objectives for mapped, primary invasive plant species____________ 2

Table S- 2. Common control measures. _______________________________________________ 4

Table S- 3. Alternative comparison by activity ________________________________________ 10

Table S- 4. Comparison of first year/first choice herbicide by alternative ____________________ 11

Table S- 5. Alternative comparison relative to significant issues___________________________ 12

Table 1. R6 2005 standards and project compliance_____________________________________ 23

Table 2. Infested acres ___________________________________________________________ 25

Table 3. Current treatment objectives for mapped, primary invasive plant species _____________ 34

Table 4. Biological agents released on neighboring lands ________________________________ 36

Table 5. Proposed treatment methods descriptions______________________________________ 41

Table 6. Biological Control Agents Proposed for Redistribution ___________________________ 44

Table 7. Summary of herbicide use under alternative B__________________________________ 45

Table 8. Herbicide descriptions, risk assessment reference, and application rates# _____________ 46

Table 9. Common control measures for alternative B ___________________________________ 48

Table 10. Project Design Features __________________________________________________ 51

Table 11. Herbicide-use buffers (in feet) for streams, wetlands, lakes, ponds and roadside ditches 

with water present at the time of treatment. Measured in feet from the edge of surface water. 

Herbicides in bold are those most likely to be used._________________________________ 61

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Malheur National Forest Site-Specific Invasive PlantsTreatment Final Environmental Impact Statement

Table 12. Herbicide-use buffers (in feet) for stream channels that are dry at the time of treatment. 

Measured in feet from the edge of the channel as defined by the high water (bankfull) mark. 

Herbicides in bold are those most likely to be used._________________________________ 62

Table 13. Management objectives under early detection/rapid response _____________________ 64

Table 14. Common control measures for alternative C. Species order does not reflect priority. First 

choice herbicide is listed in bold followed by other effective herbicides in alphabetical order. 69

Table 15. Summary of herbicide and non-herbicide use under alternative C__________________ 73

Table 16. Common Control measures for alternative D. Species order does not reflect priority. First 

choice herbicide is listed in bold followed by other effective herbicides in alphabetical order. 73

Table 17. Summary of herbicide use under alternative D_________________________________ 77

Table 18. Alternative comparison by activity __________________________________________ 81

Table 19. Comparison of first year/first choice herbicide by alternative _____________________ 82

Table 20. Alternative comparison relative to significant issues ____________________________ 84

Table 21. Herbicide risk comparison ________________________________________________ 93

Table 22. Site type criteria and acres ________________________________________________ 96

Table 23. Estimated treatment costs for alternative B __________________________________ 100

Table 24. Estimated treatment costs for alternative C___________________________________ 101

Table 25. Estimated treatment costs for alternative D __________________________________ 102

Table 26. Results of the cost-effectiveness analysis for alternatives _______________________ 102

Table 27. Potential disturbance frequency for invasive plants spread ______________________ 109

Table 28. Foreseeable future projects on the Forest with project details, vectors for invasive plant 

spread, watershed(s) affected, and implementation schedule _________________________ 112

Table 29. Watersheds containing planned future activities and invasive plant treatments _______ 117

Table 30. Project design features in alternative B that minimize potential worker and public exposure 

to herbicides ______________________________________________________________ 127

Table 31. Potential Vegetation Groups on the Malheur National Forest’s 1.7 million acres and their 

susceptibility to invasive plants _______________________________________________ 133

Table 32. Sensitive plant populations within 100 feet of proposed invasive treatment areas_____ 134

Table 33. Sensitive plant species documented (D), suspected (S), or having a historical record (H) on 

the Malheur National Forest __________________________________________________ 135

Table 34. Summary of effects to sensitive plants and special forest products ________________ 148

Table 35. Most common soil types from SSURGO mapping-ordered from dry to mesic vegetation 

types ____________________________________________________________________ 152

Table 36. Soil properties of prevalent soil series ______________________________________ 153

Table 37. Beneficial uses of major streams on the Malheur National Forest _________________ 166

Table 38. Drinking water sources __________________________________________________ 166

Table 40. Herbicide physical and chemical properties __________________________________ 168

Table 41. Results for GLEAMS model run site 1, alternative B___________________________ 172

Table 42. Results for GLEAMS model runs sites 2-4, alternative B _______________________ 173

Table 43. Results for GLEAMS model run site 1, alternative C___________________________ 176

Table 44. Aquatic species of conservation concern ____________________________________ 181

Table 45. Special Status Fish in John Day River Watersheds_____________________________ 182

Table 46. Invasive Plants and Fish Species in 5th field watersheds ________________________ 185

Table 47. Toxicity indices for fish from project herbicides based on the R6 2005 FEIS and 2007 

SERA Risk Assessment for aminopyralid _______________________________________ 194

Table 48. Toxicity indices for algae from project herbicides based on the R6 2005 FEIS and 2007 

SERA Risk Assessment for aminopyralid _______________________________________ 195

Table 49. Toxicity indices for aquatic plants from project herbicides based on the R6 2005 FEIS and 

2007 SERA Risk Assessment for aminopyralid ___________________________________ 196

Table 50. Toxicity indices for aquatic invertebrates from project herbicides based on the R6 2005 

FEIS and 2007 SERA Risk Assessment for aminopyralid ___________________________ 196

Table 51. Bull trout PCEs and MPI habitat indicators __________________________________ 200

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Table 52. Invasive plants and fish species in focus watersheds ___________________________ 203

Table 53. Determinations for Fish Species of Conservation Concern ______________________ 208

Table 54. Cumulative effects, qualitative estimates within focus watersheds for fisheries ______ 210

Table 55. ESA species (listed, proposed, candidate, delisted) ____________________________ 214

Table 56. Acres of Lynx habitat in the project area ____________________________________ 216

Table 57. Forest Service sensitive species in the project area ____________________________ 221

Table 58. Management Indicator Species on the Malheur NF and Ochoco NF _______________ 233

Table 59. Habitat for Cavity Nesters (MIS) __________________________________________ 235

Table 60. Habitat for Featured Species______________________________________________ 237

Table 61. Northern Rocky Mountain Habitat Types - Landbird Focal Species and Their Habitats 238

Table 62. Columbia Plateau Habitat Types - Landbird Focal Species and Their Habitats_______ 239

Table 63. Birds of Conservation Concern____________________________________________ 240

Table 64. Gamebirds below desired condition ________________________________________ 241

Table 65. Toxicity indices for birds ________________________________________________ 248

Table 66. Toxicity indices for mammals ____________________________________________ 249

Table 67. Exposure scenario results from FS risk assessments for mammals, birds, and honeybees, 

using the typical and highest application rates and assuming upper residue rates _________ 250

Table 68. First year/first choice treatments by habitat type and action alternative_____________ 252

Table 69. Watersheds containing planned future activities and invasive plant treatments_______ 257

Table 70. Findings and determinations for ESA-listed wildlife species in the project area ______ 260

Table 71. Sensitive Species determinations and rationale _______________________________ 262

Table 72. Treatment effects determinations for management indicator species (MIS) _________ 281

Table 73. Exposure groups, habitat and species included in each group ____________________ 288

Table 74. Standards from the R6 2005 ROD and their relationship to range management ______ 291

Table 75. Invasive plant species information by allotment_______________________________ 293

Table 76. Allotment use and invasive plants _________________________________________ 295

Table 77. Herbicide label restrictions relevant to range _________________________________ 297

Table 78. Acres of Inventoried Roadless Areas _______________________________________ 303

Table 79. Invasive Plants Sites that may be Treated by Recreation Resource Area: No Action 

Compared to Action Alternatives ______________________________________________ 304

Table 80. Summary of Potential Cumulative Effects on Recreation _______________________ 308

Table C- 1. Standard Mammalian Acute Toxicity Testing Results ________________________ 432

Table C- 2. Standard Acute Aquatic Species Toxicity Testing Results _____________________ 434

Table D- 1. List of commenters ___________________________________________________ 437

Table D- 2. Commenter ID number, Comment and Forest Service Response ________________ 439

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Malheur National Forest Site-Specific Invasive PlantsTreatment Final Environmental Impact Statement

List of Figures

Figure 1. Vicinity Map.........................................................................................................................iii

Figure 2. Malheur National Forest project area map with infestations............................................... 20

Figure 3. Herbicide-use buffers........................................................................................................... 61

Figure 4. Questions that facilitate the decision for using herbicides................................................... 67

Figure 5. One area of the Forest showing treatment distribution........................................................ 83

Figure 6. Target invasive plant sites by elevation............................................................................. 150

Figure 7. Concentrations (ppm) of herbicide modeled for Wonder Series soils in the Clear Creek 

watershed .................................................................................................................................. 156

Figure 8. Disturbance from ongoing forest activities........................................................................ 161

Figure 9. Precipitation pattern at Austin weather station .................................................................. 164

Figure 10. Stream flow at selected gages and precipitation at John Day.......................................... 165

Figure 11. Location in Middle Fork John Day River of GLEAMS model sites............................... 175

Figure 12. 5th field watersheds on the Malheur National Forest ....................................................... 188

Figure 13. Focus watersheds for fisheries analysis........................................................................... 204

Figure A- 1. Watershed Groups........................................................................................................ 356

Figure A- 2. Invasive plants infestation summary ............................................................................ 358

Figure A- 3. North Fork John Day Sub-basin (17070202)................................................................ 359

Figure A- 4. Middle Fork John Day Sub-basin (17070203) ............................................................. 362

Figure A- 5. Upper John Day Sub-basin – Main Stem Portion (17070201)..................................... 368

Figure A- 6. Upper John Day Sub-basin - South Fork Portion (17070201) ..................................... 375

Figure A- 7. Upper Malheur Sub-basin – North Fork Portion (17050116) ...................................... 379

Figure A- 8. Upper Malheur Sub-basin – Main Stem Portion (17050116)....................................... 382

Figure A- 9. Silvies River Sub-basin – 17120002 ............................................................................ 388

Figure A- 10. Silver Creek Sub-basin (17120004) ........................................................................... 395

Figure A- 11. Harney-Malheur Lakes Sub-basin (17120001) .......................................................... 399

Figure A- 12. Deschutes River Basin (170703), South Fork Beaver Creek (1707030305).............. 402

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

List of Acronyms

APHIS Animal and Plant Health Inspection Service

ATV All-terrain vehicle

AUM Animal Unit Month

BA Biological Assessment

BCC Birds of Conservation Concern

BCR Bird Conservation Region

BE Biological Evaluation

BLM Bureau of Land Management

BMP Best Management Practices

BO Biological Opinion

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

CWA Clean Water Act

DBH Diameter Breast Height

DEIS Draft Environmental Impact Statement

DOG Dedicated Old Growth

DN Decision Notice

DPS Distinct Population Segments

DWD Down Woody Debris

EA Environmental Assessment

EDRR Early detection/rapid response

EFH Essential fish habitat

EIS Environmental Impact Statement

EPA Environmental Protection Agency

ESA Endangered Species Act

FACTS Forest Service Activity Tracking System

FEIS Final Environmental Impact Statement

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FOSS Federal OSHA Safety Standard

FP Forest Plan

FS Forest Service

FSH Forest Service Handbook

FSM Forest Service Manual

FWS Fish and Wildlife Service

GIS Geographical information system

GLEAMS Groundwater Loading Effects of Agricultural Management Systems

GPS Global positioning system

HEI Habitat Effectiveness Index

HCB hexachlorobenzene

HQ Hazard quotient

HUC Hydrologic Unit Codes

IDT Interdisciplinary Team

INFISH Inland Native Fish Strategy

IRA Inventoried Roadless Areas

IWM Integrated weed management

LAU Lynx analysis units

LCAS Lynx Conservation Assessment and Strategy

LOAEL Lowest observed adverse effect level

LRMP Land and Resources Management Plan

LWD Large Woody Debris

MCR Middle Colombia River

MIS Management Indicator Species

MNF Malheur National Forest

MPG Major Population Group

MPI Matrix of Pathways and Indicators

MSA Magnuson Stevens Act

NEPA National Environmental Policy Act

NF National Forest

NFMA National Forest Management Act

NFS National Forest System 

NMFS National Marine Fisheries Service

NOA Notice of Availability

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Malheur National Forest Site-Specific Invasive PlantsTreatment Final Environmental Impact Statement

NOAEL No observed adverse effect level

NOI Notice of Intent

NPE Nonylphenol Polyethoxylate

NSA National Scenic Areas

NST National Scenic Trails

NVUM National Visitors Use Monitoring

ODFW Oregon Department of Fish and Wildlife

OHV Off-highway vehicles

ONF Ochoco National Forest

OR Oregon

ORV Outstanding Remarkable Values

OSU Oregon State University

PA Proposed Action

PACFISH Pacific Native Fish Strategy

PCE Primary Constituent Elements

PDF Project design feature

PIF Partner in Flight

PFA Post Fledgling Area

PNW Pacific Northwest

POEA Polyoxyethylene alkylamine

PPE Personal Protective Equipment

R6 Forest Service Pacific Northwest Region Six

RHCA Riparian Habitat Conservation Area

RMO Riparian Management Objectives

RNA Research Natural Areas

ROD Record of Decision

ROG Replacement Old Growth

ROS Recreation Opportunity Spectrum

ROW Right of Way

SERA Syracuse Environmental Research Associates, Inc.

SHPO State Historic Preservation Office

SMU Species Management Units

SOLI Species of local interest

TES Threatened, Endangered and Sensitive

TMDL Total maximum daily load

TNC The Nature Conservancy

USDA United States Department of Agriculture

USDI United States Department of Interior

USFS United States Forest Service

USFWS United States Fish and Wildlife Service

USGS United States Geological Survey

WA Washington

WEPP Water Erosion Prediction Project

WSR Wild and Scenic River

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Summary

Summary

Introduction

Invasive species were identified by the Chief of the Forest Service as one of the four threats to forest 

health (for more information see http://www.fs.fed.us/projects/four-threats/). Invasive plants are currently 

damaging the ecological integrity of lands. They are displacing native plants; increasing the potential for 

soil erosion and potentially destabilizing streams; reducing water quality and the quality of fish and 

wildlife habitat; and degrading natural areas. Invasive plants can have adverse effects on rare or endemic 

species, which could result in listing under state or federal endangered species laws.

Land managers for the Malheur National Forest (Forest) propose to suppress, contain, control, and 

eradicate invasive plants using an integrated approach to treatment methods that includes herbicide,

mechanical, manual, cultural, and biological agents1

. Currently, we estimate that invasive plants occupy 

approximately 2,124 acres on the Malheur National Forest. The infestations are broadly distributed, often 

occurring in areas of high spread-potential (e.g., along roads). Additional invasive plant sites likely exist 

that have not yet been identified, and new invasive plants are likely to be introduced over time.

This final environmental impact statement (FEIS) focuses on treatment of invasive plants and restoration 

of treated sites. It is tiered to the broader scale Pacific Northwest Region Invasive Plant Program 

Preventing and Managing Invasive Plants FEIS (USDA Forest Service 2005a) along with the 

accompanying Record of Decision for Invasive Plant Program Management (USDA Forest Service 

2005b), herein referred to as R6 2005 FEIS and R6 2005 ROD.

Extent of the Primary Target Species and Management Objectives

As of November 2012, we estimate that 2,124 acres currently need to be treated within the Malheur 

National Forest. There are 18 primary target invasive species within 3,070 mapped infested sites (GIS 

polygons). Site-specific integrated treatment objectives and methods (also referred to as common control 

measures) vary depending on the size and density of the infestation, its location and the target species, 

and the design features associated with each action alternative. Invasive plants are scattered throughout 

the infested areas with density ranging from less than 10 percent to 100 percent primary target species.2

We assigned preliminary treatment objectives to each of the primary target species depending on its

potential negative impacts, the size of the infestation, and the values or sensitivity of the infested sites (or 

adjacent lands). These objectives are subject to change as site conditions change over time. Table S- 1

displays our current treatment objectives for the 18 primary invasive species mapped on the Malheur 

National Forest. “Eradication” is our highest priority; all other values being equal, we would treat highest 

priorities first. However, many variables factor into our annual program of work, including funding 

mechanisms and location and timing of neighboring projects. Below are definitions of our invasive plant 

1 This project-level EIS responds to the need for suppression, containment, control and eradication of 18 primary 

invasive species currently found on the Malheur National Forest. It also responds to the need to rapidly treat new 

detections of these or other invasive species found in the future. Our invasive plant management program is 

comprised of several interrelated aspects, including preventing the introduction, establishment, and spread of 

invasive plants on and adjacent to the Forest, and working with other agencies and groups to increase program 

effectiveness. This EIS is tiered to the R6 2005 FEIS, which analyzes other aspects of the invasive plant 

management program.

2 This analysis assumes all sites are 100% occupied by invasive species because this variable is subject to rapid 

change.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

treatment objectives. R6 2005 Standards 12 and 13 require that we identify the desired future condition 

and objectives before implementing integrated treatments.

Eradicate: Eliminate an invasive plant species from a site. This objective generally applies to species that 

are difficult to control and cover small areas. Some occurrences may be on roadsides (Russian knapweed, 

squarrose knapweed) and others may occur in intact native vegetation (yellow starthistle, small 

occurrences of thistles or knapweed, new invaders). This is generally our first priority for treatment.

Control: Reduce the size of the infestation over time; some level of infestation may be acceptable. This 

objective applies to most of the target species (houndstongue, leafy spurge, perennial pepperweed, sulfur 

cinquefoil, whitetop) and large infestations of thistles and knapweeds. This is generally our second 

priority for treatment.

Contain: Prevent the spread of the weed beyond the perimeter of patches or infestation areas mapped 

from current inventories. This objective applies to target species, such as St. Johnswort. This is generally 

our third priority for treatment.

Suppress: Prevent seed production throughout the target patch and reduce the area coverage. Prevent the 

invasive species from dominating the vegetation of the area; low levels may be acceptable. This objective 

applies to target species, such as toadflax, that would be treated mainly with biocontrol agents. This is 

generally our fourth priority for treatment.

Tolerate: Accept the continued presence of established infestations and the probable spread to ecological 

limits for certain species. This category is for species that are so widespread and abundant that the other 

treatment objectives described previously would be extremely difficult to meet. This category includes 

cheatgrass, medusahead, North Africa grass, dandelion, mullein, and bulbous bluegrass. These invasive 

plants have low priority for treatment and would likely only be treated if they happen to be near one of the 

primary target species.

Table S- 1. Current treatment objectives for mapped, primary invasive plant species

Target Species

Category Common Name

Spatial Extent 

(November 2012) Treatment Objective

Sites Acres

Knapweeds

Spotted knapweed 171 82 Eradicate small isolated sites in ecologicallysensitive areas

Control large open sites and linear roadside 

populations

Diffuse knapweed 213 74 Eradicate small isolated sites in ecologicallysensitive areas

Control large open sites and linear roadside 

populations

Russian knapweed 43 4 Eradicate

Squarrose knapweed 3 <1 Eradicate small isolated sites in ecologicallysensitive areas

Control large open sites and linear roadside 

populations

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Summary

Target Species

Category Common Name

Spatial Extent 

(November 2012) Treatment Objective

Sites Acres

Meadow knapweed 2 <1 Eradicate small isolated sites in ecologicallysensitive areas

Control large open sites and linear roadside 

populations

Starthistle Yellow star-thistle 3 1 Eradicate

Thistles

Canada thistle 1,277 1,021 Control

Bull thistle* 0 0 Eradicate small infestations in ecologicallysensitive areas

Control roadside infestations, large open sites 

and forested sites

Scotch thistle 61 23 Eradicate small isolated sites in ecologicallysensitive areas

Control large open sites and linear roadside 

populations

Musk thistle 13 11 Eradicate small infestations in ecologicallysensitive areas

Control roadside infestations, large open sites 

and forested sites

Roadside

Species

Common St. Johnswort 185 120 Contain

Houndstongue 171 340 Control

Sulphur cinquefoil 61 186 Control

Toadflax

Dalmatian toadflax 666 155 Suppress

Yellow toadflax 27 9 Suppress

Mustards Whitetop 148 85 Control

Perennial pepperweed 12 2 Control

Spurge Leafy spurge 14 10 Control

Total 3,070 1,963

*Bull thistle and Canada thistle were cataloged together in our November 2012 invasive plant inventory. However, the precise 

species would be identified to determine the specific treatment objective for a given site.

The underlying purpose of treating invasive plant infestations is to maintain or improve the diversity, 

function, and sustainability of desired native plant communities and other natural resources that can be 

adversely impacted by invasive plant species.

Integrated Control Measures

Table S- 2 lists the integrated control measures effective for the 18 primary target species currently 

mapped on the Malheur National Forest. The first-choice herbicide is the one that is considered most 

effective for each target species. Other effective herbicides and integrated treatment methods may also be 

used, depending on the location of the infestation and the design of each action alternative. Not all 

herbicides are approved in all alternatives; picloram would not be used in alternative C and aminopyralid 

would not be used in alternative D. 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Table S- 2. Common control measures. 

Primary Target Species

First-Choice 

Followed by 

Other Effective 

Herbicides3

Integrated Treatment Notes

Yellow star-thistle

Centaurea solstitialis

(CESO3)

Annual

aminopyralid

clopyralid

glyphosate

picloram

Early detection and treatment increase the chances of control. 

Treatment of small infestations in otherwise healthy sites should be a 

priority.

Biological control agents are available. 

Hand pull when soil is moist and remove all roots and flower and 

seed heads.

Common St. Johnswort

Hypericum perforatum

(HYPE)

Perennial with stolons 

and rhizomes

aminopyralid

glyphosate

metsulfuron 

methyl

picloram

Biological agents are available. 

Small infestations may be controlled by pulling or digging. Repeated 

treatments will be necessary because lateral roots can give rise to 

new plants. Bag and remove all plant parts from site.

Russian knapweed

Acroptilon repens

(ACRE3)

Long-lived creeping 

perennial

aminopyralid

chlorsulfuron

clopyralid

glyphosate

imazapyr

metsulfuron 

methyl

picloram

Hand pulling is effective only in the establishment year. 

Reproduces mainly by vegetative propagation from buds on creeping

roots.

Biocontrol agents being developed.

Cutting or mowing several times per year will control top growth and 

seed production; re-emerging plants will have less vigor.

Lasting control requires an integrated approach; using mechanical or 

cultural measures with herbicide application, especially in late fall, is 

most effective.

Small, isolated infestations should be eradicated first. Then larger 

infestations should be controlled from the perimeter and eradicated 

when possible.

Spotted knapweed

Centaurea stoebe ssp. 

micranthos

(CESTM)

Taprooted perennial

aminopyralid

clopyralid

glyphosate

triclopyr

picloram

Treatment would focus on reducing seed production and preventing 

germination.

Biological agents are available.

Repeated manual pulling and digging may eliminate small 

infestations (2-4 times per year for multiple years). Pull prior to seed 

set. Bag and remove flower and seed heads.

Diffuse knapweed

Centaurea diffusa

(CEDI3)

Short-lived perennial, 

biennial or annual. Often 

with a long, stout taproot

3 Species order does not reflect priority. First choice herbicide is listed in bold followed by other effective herbicides 

in alphabetical order.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Summary

Primary Target Species

First-Choice 

Followed by 

Other Effective 

Herbicides3

Integrated Treatment Notes

Squarrose knapweed

Centaurea virgata ssp. 

squarrosa

(CEVIS2)

Taprooted perennial

Meadow knapweed

Centaurea jacea sensu 

lato

(CEJA)

Taprooted perennial

Canada thistle

Cirsium arvense

(CIAR4)

Rhizomatous perennial

aminopyralid

chlorsulfuron

clopyralid

picloram

Combining mechanical, cultural, biological, and chemical methods is 

best for effective control.

Biological agents are available, but use may affect native thistles. 

Mowing, cutting or pulling can be an effective control if repeated at 

about 1-month intervals throughout the growing season for several 

years. Combining mowing/cutting with herbicides (in the fall) will 

further enhance control of Canada thistle. Covering with plastic tarp 

(solarization) may be effective for small infestations.

Bull thistle*

Cirsium vulgare

(CIVU)

Taprooted biennial

aminopyralid

chlorsulfuron

clopyralid

glyphosate

picloram

triclopyr

Prioritize small infestations in otherwise healthy sites. Prioritize 

prevention of establishment and eliminating plants as soon as they 

are found.

Manually pulling rosettes or cutting stems 2”-4” below the soil surface 

before flower heads develop kills plants and prevents seed 

development. Roots may be left on site to dry; all flower and seed 

heads should be removed.

Covering disturbed sites, particularly small burn areas, with fine to 

medium sized organic matter may prevent or reduce the size of 

infestations. Please note, this was described as the “Canada thistle 

strategy” in the DEIS.

Scotch Thistle

Onopordum acanthium

(ONAC)

Taprooted biennial or 

short-lived perennial

Musk thistle

Carduus nutans

(CANU4)

Taprooted biennial or 

occasional annual

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Primary Target Species

First-Choice 

Followed by 

Other Effective 

Herbicides3

Integrated Treatment Notes

Leafy spurge

Euphorbia esula

(EUES)

Rhizomatous perennial

aminopyralid

glyphosate

imazapic

picloram

Early detection and rapid eradication is important since plant spreads 

rapidly by seeds and rhizomes. Continuous aggressive management 

is necessary to keep infestations under control (5 – 10 years).

Prioritizing treatment of small infestations, then treating large 

infestations from the outside edges is most effective. 

Biological control agents may reduce aboveground stems but do not 

kill root systems. 

Mechanical, cultural, or herbicide methods alone are rarely effective. 

Combinations of several herbicide treatments and planting grass 

seed may provide the best chance of controlling the species. Hand 

pulling and grubbing are not effective because of the extensive root 

system. Cutting and mowing reduce seed production and the plant’s 

competitive ability. Covering with weed cloth, plastic, or thick mulch 

may kill plants. Site can then be planted with native seed. If manual 

methods are used all plant parts should be bagged and removed 

since new plants may form from roots and rhizomes as well as from 

seeds. Plant’s milky sap may be irritating to skin, eyes, and digestive 

tract of humans and other animals.

Houndstongue

Cynoglossum officinale

(CYOF)

Taprooted biennial or 

short-lived perennial

chlorsulfuron

imazapic

metsulfuron 

methyl

Mowing/cutting second year plants during flowering, but before seed 

maturation reduces seed production and may kill the plant. 

Pulling plants or cutting 1-2” below the soil surface have the best 

chance of eliminating plants. Cutting produces less ground 

disturbance than pulling. Bag and remove all flower and seed heads.

Dalmatian toadflax

Linaria dalmatica

(LIDA)

Perennial with taproot 

and extensive system of 

lateral roots

chlorsulfuron

imazapic

metsulfuron 

methyl

picloram

Dalmatian toadflax reproduces primarily by seed and partly by 

adventitious root buds. Yellow toadflax reproduces primarily by 

adventitious root buds on lateral roots.

Biological agents are available and may be very effective. If 

biocontrol agents continue to be effective, herbicide application may 

not be needed.

Manual pulling and digging may not be effective because of the deep 

(4-10 feet) and laterally extensive root systems (to 10 feet from 

plant). If manually removed, all roots and flower and seed heads 

should be bagged and removed. Cutting stems in spring or early 

summer would eliminate seed production, but not the root system.

Yellow toadflax

Linaria vulgare

(LIVU2)

Perennial with taproot 

and extensive system of 

vertical and creeping 

lateral roots

Whitetop

Cardaria draba

(CADR)

Rhizomatous perennial

chlorsulfuron

imazapic

imazapyr

glyphosate

These species are difficult to control because of their deep taproots 

(9 ft.) and ability to sprout from root fragments. Early detection and 

proactive management is most effective since established 

infestations are difficult to control. Frequent monitoring for new sites 

and prioritizing small infestations in otherwise healthy sites is 

important. Next priority would be for corridors, such as waterways 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Summary

Primary Target Species

First-Choice 

Followed by 

Other Effective 

Herbicides3

Integrated Treatment Notes

Perennial pepperweed

Lepidium latifolium

(LELA2)

Perennial with rhizome 

like creeping roots

metsulfuron 

methyl

and irrigations structures that have a high likelihood of spread.

Biological controls are not available.

Repeated pulling may control small, young infestations. Established 

plants are likely to resprout from deep roots. All roots and flower and 

seed heads should be removed. Mowing does not eliminate plants 

but removes thatch.

Sulphur cinquefoil

Potentilla recta

(PORE5)

Taprooted perennial that 

may have several 

shallow, spreading 

branch roots but not 

rhizomes

metsulfuron 

methyl

glyphosate

picloram

triclopyr

Cultural treatments, such as seeding of native plants may be 

effective.

There are no approved biocontrols.

Small infestations may be controlled by hand digging if the entire root 

crown is removed.

For large infestations, selective herbicides are likely the only method 

of effective control (TNC 2004).

Repeated treatments are needed for the first couple of years to 

ensure re-establishment does not occur.

Alternatives

This EIS discloses the direct, indirect, and cumulative environmental impacts that would result from the 

proposed action and alternatives.

Four alternatives are considered: 

Alternative A, the no-action alternative — If alternative A is selected, no invasive plant treatments 

would be authorized under this environmental impact statement. Invasive plant treatments would likely 

continue on state road rights-of-way and easements within the Malheur National Forest because they are 

not subject to Forest Service control. 

Prevention measures, continued to be applied during land uses, would slow (but not stop) the spread of 

invasive plants on the Forest and surrounding lands given the propagule pressure and type of expected 

disturbance associated with surrounding land uses and activities. 

Alternative A addresses some public concerns by eliminating most herbicide use on the Forest. There 

would continue to be low or no risks or impacts from herbicides on human health, non-target vegetation 

and pollinators, soils, water, aquatic organisms, or wildlife. However, threats to the environment from 

invasive plants would continue unabated. Neighbors would continue to be frustrated in their attempts to 

enlist the Forest Service to help with partnerships to implement effective integrated treatments within and 

outside Forest boundaries. 

Alternative B, the proposed action — This alternative is the most cost-effective approach to invasive 

plant treatment while minimizing potential adverse effects of treatment. Alternative B responds to the 

purpose and need for action by authorizing several herbicide and other integrated treatment methods to be 

implemented on the Forest over the next several years. These options are intended to effectively reduce 

the size and density of invasive sites, and abate the adverse effects of invasive plants. The project would 

continue to be implemented each year until the treatments were no longer needed or conditions 

substantially change on the ground to such a degree that the analysis in this EIS is no longer valid. The 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

annual implementation planning process discusses how changed conditions would be evaluated for this 

project over time.

Under alternative B, the herbicide ingredient considered most effective (Table S- 2) would be applied 

initially. Over time, other effective herbicides may also be used depending on treatment results.

We are proposing a Land and Resource Management Plan (LRMP) amendment to add aminopyralid to 

the list of acceptable herbicides for use as part of the integrated treatment toolbox for invasive plants on 

the Malheur National Forest. Aminopyralid (also known by the trade name: Milestone TM) was not 

available during the analysis process for the R6 2005 FEIS. A subsequent risk assessment completed in 

2007 indicates that this herbicide will increase treatment effectiveness and decrease risk of adverse effects 

as compared to other herbicides authorized in the R6 2005 ROD. Thus, we propose to add aminopyralid 

to the list of approved ingredients in invasive plant standard 16 for the Forest (LRMP amendment). All 

other standards and guidelines for invasive plant management would remain the same.

We propose to apply aminopyralid to about 64 percent of the infested acreage for the first treatment entry 

(about 1,350 acres). We would use aminopyralid initially because it is considered the most effective of the 

11 available herbicides for 12 of the 18 primary target species (all except houndstongue, both toadflaxes, 

pepperweed, and whitetop, which have chlorsulfuron as the first-choice herbicide and sulphur cinquefoil, 

that has metsulfuron methyl as the first-choice herbicide) (Table S- 2). Aminopyralid has low toxicity to 

aquatic organisms and is labeled for use up to the edge of surface waters. Alternative B would allow 

broadcasting (boom spraying) of this herbicide to the edge of streams and other water bodies.

We are also proposing to use chlorsulfuron for the first treatment entry on 28 percent of the acres (about 

591 acres), and metsulfuron methyl for one target species, sulphur cinquefoil, that covers an estimated 8 

percent of the acres (about 186 acres). 

Under alternative B, biological control agents would be deliberately redistributed to suppress or contain 

established populations of invasive plants on the Forest. Redistribution or release of biological control 

agents would be done as part of the Oregon Department of Agriculture Biological Control Program and 

meet the requirements of R6 2005 ROD Standard 14. The treated areas would continue to be inventoried 

and monitored to determine the success of the treatments, and when the released biological control agents 

have reached equilibrium with the target species. This EIS is tiered to the R6 2005 FEIS and various and 

ongoing Animal and Plant Health Inspection Service (APHIS) NEPA documents for the release of 

biological control agents. 

Alternative B provides for treatment flexibility and early detection/rapid response by providing a method 

for us to adapt to changes on the ground over time. We expect some populations to increase and others to 

decrease over the life of this project, depending on many unpredictable factors such as weather (droughts 

and wet periods), funding, and the location of wildland fires or other uncontrolled disturbances. Under 

alternative B, we will tailor the prescription to ground conditions at the time of treatment. 

In addition, new or previously undiscovered infestations could be treated using the range of methods 

described in this EIS. An early detection/rapid response (EDRR) approach is needed because 1) the 

precise location of individual target plants, including those mapped in the current inventory, are subject to 

rapid or unpredictable change, and 2) the typical NEPA process does not allow for rapid response to new 

detections; infestations may grow and spread into new areas during the time it usually takes to prepare 

NEPA documentation. The intent of the project early detection/rapid response approach is to treat new 

infestations when they are small so that the likelihood of adverse treatment effects is minimized. If 

alternative B is selected, integrated treatments would be authorized for new infestations detected over the 

next several years, using the treatment methods and project design features evaluated in this EIS. The 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Summary

analysis of alternative B assumes that all of the current infestations are treated in a single year and all pdfs

are properly applied. 

Alternative B responds to public concerns about treatment effectiveness by authorizing a wide range of 

integrated treatment methods that would be prioritized, planned and implemented in cooperation with our 

neighbors. We would start to use herbicides and redistribute biological control agents on the Malheur 

National Forest as soon as practicable after the decision. Alternative B is, by definition, the most costeffective alternative.

Alternative B favorably responds to issues about effects of herbicides on human health, non-target 

vegetation and pollinators, soils, water, aquatic organisms, and wildlife because treatments would be 

implemented according to design features and herbicide-use buffers that minimize the risk of adverse 

effects.

Two action alternatives were developed in response to public issues related to herbicide use:

Alternative C, strict limitations on herbicide use — This alternative was developed in response to 

some public concerns about herbicide use on the Malheur National Forest. Alternative C would impose 

strict limitations on our ability to use herbicides to treat invasive plants. Compared to alternative B, 

alternative C would further address public issues about herbicide impacts to human health, non-target 

vegetation and pollinators, soils, water, aquatic organisms, and wildlife, while still allowing for some 

limited herbicide use. Under alternative C, all of the alternative components for alternative B would be 

followed; however, no broadcasting (boom spraying) of herbicide would be allowed. No herbicide use 

would be allowed within the boundaries of any mapped infested area that at any point is within 100 feet 

of creeks, lakes, ponds and wetlands; or 200 feet of well-source areas. Non-herbicide methods would 

continue to be used within these areas. Picloram would be eliminated from the list of available herbicides. 

About 735 acres would be approved for spot/selective herbicide use, and on the remaining 1,389 acres, no 

herbicide would be used.

Alternative D, no LRMP amendment and no aminopyralid — This alternative was developed to 

evaluate the tradeoffs involved with amending the LRMP to add aminopyralid to the list of available 

herbicides. Alternative D would be similar to alternative B, except a LRMP amendment would not be 

completed and aminopyralid would not be approved for use on the Malheur National Forest. 

Aminopyralid would not be used to treat known sites or new detections. Compared to alternative B, more 

chlorsulfuron, glyphosate, metsulfuron methyl, and picloram would be used in lieu of aminopyralid. As a 

result, infested sites close to streams and other water bodies would be spot treated rather than broadcast. 

Alternative Comparison

The project design features (pdfs) (table 10) minimize the potential impacts of invasive plant treatment. 

These pdfs provide sideboards for treatment of known sites, along with new detections. The pdfs were 

developed to respond to the site-specific resource conditions within the infested areas, including (but not 

limited to) botanical areas; habitat and presence of botanical, wildlife and/or fish species of conservation 

concern; the potential for herbicide delivery to water, and proximity other areas of interest (roads and 

trails, recreation sites, Wilderness/Wild and Scenic Rivers, wildland fire areas). The analysis assumes pdfs

are properly implemented. Herbicide-use buffers (table 11 and table 12 restrict the method of application 

for most of the proposed herbicides depending on their persistence, mobility, and toxicity to aquatic 

organisms and label advisories.

Implementation of pdfs and herbicide-use buffers would be mandatory for all action alternatives, where 

applicable. Alternative C would not allow broadcasting, so pdfs associated with broadcast treatments 

9
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

would not be applicable. In addition, alternative C would not allow any herbicide use within 100 feet of 

streams and other water bodies, so the variations in method of application of the different herbicides 

would not be applicable. Alternative C would eliminate use of picloram so pdfs and herbicide-use buffers 

associated with picloram would not be applicable. 

Alternative D would not amend the Malheur National Forest LRMP, so pdfs associated with aminopyralid 

would not apply. 

The following table displays the primary differences between the alternatives.

Table S- 3. Alternative comparison by activity

Activity Alt A

(No Action)

Alt B

(Proposed Action)

Alt C

(More Restrictive 

Herbicide Use)

Alt D

(No LRMP 

Amendment)

Authorizes EDRR No Yes Yes Yes

Non-herbicide 

treatments None4

Non-herbicide 

treatments would be 

integrated with 

herbicide treatments

Same as Alternative B 

except only nonherbicide treatments 

would be approved 

within 100 feet of 

water bodies

Same as 

Alternative B

Maximum acres of 

proposed herbicide 

treatments during any 

year of 

implementation

0 2,124 735 Same as 

Alternative B

Number of herbicides 

available for use 0 11 10 (no picloram) 10 (no aminopyralid)

Forest LRMP

amendment to 

include aminopyralid

No Yes Yes No

Herbicide Application 

Rate and Method None

Lowest effective 

rate, broadcast

sprayers may be 

used where needed 

according to pdfs

Application rate would 

not exceed 70% of 

typical broadcast rate, 

no boom or broadcast 

sprayers

Same as 

Alternative B, no 

aminopyralid

Biological control 

agents

Biological control 

agents may be 

released or 

redistributed

No biological agents 

would be released 

within the Forest 

boundaries

Same as Alternative B Same as 

Alternative B

Prevention measures Measures applied to 

all land uses to 

prevent the 

introduction and 

spread of invasive 

plants.

Same as Alternative 

B

Same as Alternative B Same as 

Alternative B

4 The analysis in chapter 3 assumes that no action means no invasive plant treatments will occur. Prevention would 

continue, and biological agents distributed in adjacent lands would naturally distribute to host species within the 

Malheur National Forest.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Summary

Table S- 4 displays a comparison of the first year/first choice treatment for each alternative. All action 

alternatives (B-D) would approve a range of treatments on all 2,124 currently infested acres. Alternative 

C is the only action alternative that would disallow herbicide use in specific areas to the degree that nonherbicide treatments would be the only methods allowed for a substantial portion of these sites. Under 

alternative A (no action), no treatments would be approved. Under all alternatives (A-D), approved 

biological controls will continue to be released adjacent to the project area and would help suppress 

toadflax, St. Johnswort and other common invasive species. Biological agents would be redistributed to 

host species within the project area in the action alternatives. 

Table S- 4. Comparison of first year/first choice herbicide by alternative

First Year/First Choice Treatment Alt A

Acres

Alt B

Acres

Alt C

Acres

Alt D

Acres

Broadcast Herbicide Application 0 1,281 0 0

Aminopyralid 0 1,179 0 0

Chlorsulfuron 0 71 0 435

Glyphosate 0 0 0 3

Metsulfuron methyl 0 30 0 69

Picloram 0 0 0 36

Spot/Selective Herbicide Application 0 843 735 1,581

Aminopyralid 0 168 560 0

Chlorsulfuron 0 519 142 595

Glyphosate 0 0 0 722

Metsulfuron methyl 0 156 33 238

Picloram 0 0 0 27

Non-herbicide Only 0 0 1,389 0

Table S- 5 provides a comparison of the alternatives relative to the issue measures described in chapter 1.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Table S- 5. Alternative comparison relative to significant issues

Issue Component Unit of Measurement Alt A

(No Action)

Alt B

(Proposed Action)

Alt C

(More Restrictive 

Herbicide Use)

Alt D

(No LRMP 

Amendment)

1 – Treatment Effectiveness

Restrictions on herbicide 

use reduce treatment 

effectiveness and 

increase treatment costs.

Average Cost per Acre of 

Effective Treatment of 

Known sites (includes retreatments and restoration)

0 $544 $722 $598

Total Cost of Effective 

Treatment of Know Sites 

(includes re-treatments 

and restoration)

0 $1,154,000 $1,472,900 $1,270,500

Ability to meet treatment 

objectives

Will not meet 

objectives

Tools adequate to meet 

treatment objectives

Tools may not be 

adequate to meet 

treatment objectives, 

especially near riparian 

areas

Tools adequate to meet 

treatment objectives, 

however opportunities to 

use most effective 

herbicide or application 

method may be forgone

2 – Herbicide Impacts to Human Health

Human health may be 

harmed by herbicide 

exposure.

Type (rate, method, 

chemical properties) and 

extent of herbicide use that 

could result in harmful 

exposure scenarios to 

people.

None

None of the herbicides

proposed for use are 

associated with harmful 

scenarios to the public.

Pdfs minimize or eliminate 

potential for harmful 

exposure by limiting the 

herbicide ingredient, rate, 

or method of application.

Workers need to take 

specific precautions to 

avoid herbicide exposure. 

Same as Alternative B, 

except that far less 

herbicide would likely 

be sprayed annually. 

The minimal risks 

associated with 

herbicide use under 

Alternative B would be 

further reduced. 

Same as Alternative B.

Where necessary, pdfs

minimize or eliminate 

potential for harmful 

exposure scenarios.

Qualitative assessment 

about the effectiveness of 

herbicide-use buffers and 

other project design 

features to prevent harmful 

herbicide exposure 

scenarios

None

Risk assessments 

demonstrate that the type 

of herbicide use proposed 

poses relatively low risk to 

human health. The 

likelihood of harmful 

exposures is low, thus the 

design features have high 

Alternative C would 

have less risk of 

herbicide exposure 

overall, especially to 

fish and water, due to 

restrictions on herbicide 

use near water. The 

buffers would eliminate 

Same as Alternative B, 

except opportunities to 

use aminopyralid would 

be foregone and in 

some cases, higher risk 

herbicides would be 

used. However, more 

spot treatment and less 

12
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Summary

Issue Component Unit of Measurement Alt A

(No Action)

Alt B

(Proposed Action)

Alt C

(More Restrictive 

Herbicide Use)

Alt D

(No LRMP 

Amendment)

likelihood of eliminating all 

potential adverse impacts 

from herbicide use. 

all potential herbicide 

exposure near streams. 

While this alternative 

includes some 

additional design 

features that would 

comparatively reduce 

risk of harmful herbicide 

exposure, the risk is 

already low.

broadcasting would 

occur, which could result 

in less herbicide 

exposure, partly 

because less herbicide 

can be applied per day 

so the daily treatment 

extent would likely be 

less. For the project as a 

whole, the design 

features minimize 

adverse impacts to 

human health from 

herbicide use. 

Potential for Herbicides to 

Affect Drinking Water None

Drinking water quality 

would not be adversely 

affected. Restrictions on 

herbicide use near drinking 

water and well intakes 

further minimize risk. 

Herbicide transportation 

and handling safety plan 

would minimize potential 

for an herbicide spill.

Same as Alternative B Same as Alternative B

3 – Herbicide Impacts on Non-target Vegetation 

Proposed herbicide use 

may harm non-target 

plants, specifically 

sensitive and other 

species of conservation

concern, cultural use 

plants, and special forest 

products.

Type and extent of 

herbicide use within 100 

feet of botanical special 

species of conservation 

concern, cultural use 

plants, and special forest 

products.

None

Pdfs prohibit broadcast 

herbicide use within 100 

feet of sensitive plant 

populations. Spot

applications will be used 

within 100 feet of sensitive 

plant populations. The pdf 

for use of blue dye will alert 

special forest product 

gatherers of herbicide 

spray areas.

Same as Alternative B, 

less overall herbicide 

use

Same as Alternative B

4 - Herbicide Delivery to Water and Potential Impacts to Fish

Proposed herbicide use 

may result in chemicals 

Type and extent of 

herbicide use within 100 None Aminopyralid could be broadcast up to water’s 

Same as Alternative B, 

except no herbicides 

Same as Alternative B, 

except comparatively 

13
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Issue Component Unit of Measurement Alt A

(No Action)

Alt B

(Proposed Action)

Alt C

(More Restrictive 

Herbicide Use)

Alt D

(No LRMP 

Amendment)

reaching streams and 

other water bodies 

(through drift, leaching 

and/or run off) and may 

adversely fish and their 

habitat. 

feet of streams and other 

water bodies.

edge; however, no adverse 

impacts on fish are 

expected because the 

amount of herbicide that 

may reach streams is 

below a level that could 

harm fish. Herbicide-use 

buffers and other pdfs

reduce the rate, extent, or 

frequency of herbicide use 

that pose potential risks to 

fish.

would be used within 

100 feet of streams and 

other water bodies. 

There potentially could 

be more sediment from 

non-herbicide methods 

required near streams. 

more use of higher-risk 

herbicides relative to 

fish. pdfs minimize risks 

and differences between 

alternatives.

Qualitative assessment 

about whether or not, and 

how fisheries might be 

affected

No impacts

Water concentrations from 

site-specific model runs at 

highest risk sites 

demonstrate that levels of 

herbicide that could reach 

streams and aquatic 

organisms are at least 3 

orders of magnitude less 

than levels of concern for 

fish and habitat. Treatment 

methods may result in 

minor amounts of sediment 

reaching streams.

Same as Alternative B Same as Alternative B

5- Herbicide Impacts on Wildlife and Pollinators

Proposed herbicide 

use may result in 

harmful exposure to 

terrestrial wildlife 

(specifically species of 

conservation concern).

Type and extent of 

herbicide use within 

specific wildlife habitats for 

wildlife of conservation 

concern

None

This alternative has the 

most broadcasting, but the 

first-choice herbicides that 

would be used pose low 

risk to wildlife.

Spot application of 

herbicides would occur 

on 735 acres and the 

first-choice herbicides 

pose low risk to wildlife.

First-choice herbicides 

that pose a low risk to 

wildlife would be applied 

on 1,337 acres whereas 

moderate to risk firstchoice herbicides would 

be used on 787 acres. 

Less broadcasting than 

Alternative B, which 

reduces risk of drift.

Risk of HCB 

(hexachlorobenzene) 

contamination and effects 

None

No HCBs in first-choice

herbicides. Pdfs minimize 

risk to raptors to extremely 

Same as alternative B. 

No use of picloram 

reduces risk. 

Picloram is the firstchoice herbicide on 63 

acres, posing low risk of 

14
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Summary

Issue Component Unit of Measurement Alt A

(No Action)

Alt B

(Proposed Action)

Alt C

(More Restrictive 

Herbicide Use)

Alt D

(No LRMP 

Amendment)

on raptor eggs low level. HCB’s; pdfs minimize 

risk to raptors to 

extremely low level.

Narrative assessment 

about whether or not, and 

how species of 

conservation concern and 

amphibians might be 

affected

None

All first-choice herbicides 

pose a low risk to wildlife. 

Pdfs that restrict timing and 

application of herbicides in 

sensitive habitats will 

minimize or eliminate the 

likelihood for any species 

to receive a harmful 

exposure to herbicides or 

disturbance.

Same as Alternative B, 

except greater risk of 

disturbance from nonherbicide treatments. 

Same as Alternative B, 

except less broadcasting 

and more use of 

herbicides that pose a 

comparatively greater 

risk to wildlife. 

15
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

16
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 1

Chapter 1. Purpose and Need for Action

1.1 Introduction

Land managers for the Malheur National Forest (Forest) propose to suppress, contain, control, 

and eradicate invasive plants using an integrated approach to treatment methods that includes 

herbicides, mechanical, manual, cultural, and biological agents.

5 Currently, we estimate that 

invasive plants occupy approximately 2,124 acres on the Forest. The infestations are broadly 

distributed, often occurring in areas of high spread-potential (e.g., along roads). Additional 

invasive plant sites exist that have not yet been identified, and new invasive plants are likely to 

be introduced over time.

Invasive plants are defined as “non-native plants” whose introduction does or is likely to cause 

economic or environmental harm or harm to human health (Executive Order 13112). Invasive 

plants are distinguished from other non-native plants by their ability to spread (invade) into 

native ecosystems. They spread between National Forest System (NFS) lands and neighboring 

areas, affecting all land ownerships.

Invasive plants are currently damaging the ecological integrity of National Forest System lands.

They are displacing native plants, increasing the potential for soil erosion and potentially 

destabilizing streams, reducing water quality and the quality of fish and wildlife habitat, and 

degrading natural areas. Invasive plants can have adverse effects on rare or endemic species, 

which could result in listing under state or federal endangered species laws.

The Forest Service has prepared this environmental impact statement (EIS) in compliance with 

the National Environmental Policy Act (NEPA) and other relevant federal and state laws and 

regulations. This EIS discloses the direct, indirect, and cumulative environmental impacts that 

would result from the proposed action and alternatives. The document is organized into the 

following chapters:

♦ Chapter 1. Purpose and Need for Action: This chapter includes information on the 

background, and purpose of and need for the project. This section also details how the 

Forest Service informed the public of the proposal and the issues identified through 

public scoping.

♦ Chapter 2: Alternatives, including the Proposed Action: This chapter provides a more 

detailed description of the proposed action as well as alternative methods for meeting the 

need for action. These alternatives were developed based on issues raised by the public 

and other agencies. This section also provides a summary table of the design 

components that compares the relative risks and benefits of each alternative.

♦ Chapter 3: Affected Environment and Environmental Consequences: This chapter 

describes the current condition and the resources that are at risk from invasive plants on 

the Malheur National Forest. It also details the environmental effects of implementing 

the proposed action and other alternatives.

5 This project-level EIS responds to the need for suppression, containment, control and eradication of 18 

targeted invasive species currently found on the Malheur National Forest. It also responds to the need to 

treat new detections rapidly of these or other invasive species found in the future. Our invasive plant 

management program is comprised of several interrelated aspects, including preventing the introduction, 

establishment, and spread of invasive plants on and adjacent to the Forest, and working with other 

agencies and groups to increase program effectiveness. This EIS is tiered to the R6 2005 FEIS, which 

analyzes other aspects of the invasive plant management program (e.g., prevention).

17

 
Chapter 1 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

♦ Chapter 4: Consultation and Coordination: This chapter provides a list of preparers and 

agencies and people consulted during the development of the environmental impact 

statement. Chapter four also includes list of references cited in the document, a glossary, 

a list of definitions for technical terms and acronyms, and an index.

♦ Appendices: The appendices provide more detailed information to support the analyses 

presented in the environmental impact statement.

Site-specific reports addressing botany, soils, hydrology, wildlife, fisheries, range, recreation,

and archeology; and detailed maps for the project may be found in the project record located at 

the Malheur National Forest Headquarters located in John Day, Oregon. 

1.2 Background

On June 26, 2000, the Forest prepared an Environmental Assessment (EA), a Decision Notice

(DN) and a Finding of No Significant Impact (FONSI) for the Noxious Weed Control Project on 

the Malheur National Forest. The project intended to treat weeds using herbicides and other 

methods according to regional direction developed during the 1980s. However, later that year, 

the project was litigated.

In December 2002, U.S. District Court (Blue Mountains Biodiversity Project v. US Forest 

Service, CV 01-703-HA) concluded that the noxious weed control environmental assessment 

was insufficient under NEPA because it was tiered to earlier documents that the court deemed to 

be outdated. Thus, we were “...enjoined from implementing ... the use or application of 

herbicides and biological controls until and unless it considers, evaluates and discloses in an 

environmental impact statement or supplemental environmental impact statement the individual 

and cumulative impacts of herbicide use...” (ibid.). Although that court decision applied 

exclusively to the Malheur National Forest, in 2005 the Pacific Northwest Region 6 Regional 

Forester decided to amend all of the Forest Plans (LRMPs) in the Region based on new herbicide 

risk assessments and information about preventing invasive plant introduction, establishment and 

spread, and restoring treated sites. The R6 2005 FEIS satisfied the intent of the 2002 court order 

but did not approve invasive plant treatments on the ground; site-specific NEPA is required to 

implement treatment projects.

Management direction for invasive plant prevention, treatment and restoration, and monitoring 

was added to the Malheur LRMP as a result of the Record of Decision for the Pacific Northwest 

Region Invasive Plant Program: Preventing and Managing Invasive Plants (USDA Forest 

Service 2005b). This document, referred to herein as the R6 2005 ROD, described the reasons 

why specific management direction was adopted and why alternative strategies (to increase or 

decrease herbicide use or increase emphasis on prevention) were not adopted. These discussions 

are summarized and incorporated where relevant; however, the decisions made in 2005 are not 

being reconsidered here. The action alternatives considered in this EIS are intentionally limited 

in scope to options for implementing updated, effective invasive plant treatments in accordance 

with the R6 2005 ROD.

On March 31, 2006, the Malheur National Forest published a Notice of Intent (NOI) to prepare 

an Environmental Impact Statement (EIS) for an invasive plant treatment project (Federal 

Register Vol. 72, No. 62, pp. 16281 -1628). The Forest Service considered public scoping input 

and initiated an analysis. However, there was a delay in completing the NEPA process, so the 

proposed action was updated and a new NOI was published in the Federal Register on April 5, 

2011, (Federal Register Vol. 76, No.65, pp. 18713-18715) initiating new scoping input. Scoping 

input from both 2006 and 2011 was used to develop issues and alternatives analyzed for this EIS. 

18
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 1

We have continued to collect, update, and analyze site-specific information during the time since 

the court injunction.

In accordance with the injunction, we have been treating invasive plants exclusively using 

manual or mechanical methods on the Malheur National Forest.

6 Manual and mechanical 

treatments are labor intensive and tend to be costly, and in some cases are not effective (see 

common control measures table 9 in chapter 2 for more information). 

1.3 Project Area

The project area encompasses the entire 1,459,422-acre Malheur National Forest and 240,000 

acres of the Ochoco National Forest that are managed by the Malheur Forest (previously known 

as the Snow Mountain Ranger District, now managed as part of the Emigrant Creek Ranger 

District.) for a total of nearly 1.7 million acres located in eastern Oregon (figure 2). These 1.7 

million acres is the acreage considered as the Malheur National Forest for purposes of this 

analysis. The counties included in the analysis area are Grant, Baker and Harney. Small portions 

of Crook and Malheur Counties are also included in the analysis. The Malheur National Forest

shares boundaries with the Umatilla, Wallowa-Whitman and Ochoco National Forests, Bureau of 

Land Management (BLM), state, county, and private lands.7

The following map shows the current extent and distribution of invasive species mapped across 

the project area. The acreage within each 5th field watershed is color-coded; the darker color

indicates more invaded acreage in that watershed.

6 Herbicides have been used in spot treatments totaling 10-20 acres/year along roads on the Snow 

Mountain Ranger District portion of the Emigrant Creek Ranger District – Ochoco National Forest, as 

authorized under the Ochoco National Forest LRMP Amendment # 16, which is outside the area covered 

by the injunction. Biological agents have been released by county and state agencies adjacent to the 

Malheur National Forest boundaries and are active on widespread host species, such as toadflax and St 

Johnswort within the Forest. 

7 Approximately 13,080 acres of private lands have been acquired by the Malheur National Forest in the 

headwaters of the John Day River. These acquired lands automatically become part of the management 

areas within which they are located (36 CFR 254.3 (f)) which includes portions of general forest (MA 1); 

rangeland (MA 2); riparian areas (MA 3); big game winter range (MA 4A); semi-primitive motorized 

recreation (MA 11); visual corridor (MA (14); and wildlife emphasis area (MA 15). Invasive plants could 

be treated on these lands according to the management direction herein. 

19

 
Chapter 1 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Figure 2. Malheur National Forest project area map with infestations

20
Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement – Chapter 1

1.4 Desired Future Conditions

The R6 2005 ROD added the following desired future condition statement to the Malheur National 

Forest Land and Resource Management Plan (LRMP):

“....healthy native plant communities remain diverse and resilient, and damaged ecosystems are 

being restored. High quality habitat is provided for native organisms throughout the [Forest]. 

Invasive plants do not jeopardize the ability of the [Malheur] National Forest to provide goods 

and services communities expect. The need for invasive plant treatment is reduced due to the 

effectiveness and habitual nature of preventative actions, and the success of restoration efforts.”

1.5 Purpose and Need

The most recent Forest invasive plant inventory data includes 2,124 acres of mapped target species that 

need to be suppressed, contained, controlled or eradicated. The underlying purpose of treating invasive 

plant infestations is to maintain or improve the diversity, function, and sustainability of desired native 

plant communities and other natural resources that can be adversely impacted by invasive plant species.

As they become established and spread, invasive plants may affect the recovery trajectory for desired 

plant and soil communities in disturbed areas.

Invasive plants are occupying many special places on the Forest, including dispersed and developed 

recreation sites, wilderness areas and wild and scenic river corridors, fish habitat, and grazing 

allotments. The quality of native plant and wildlife habitat is being degraded across many watersheds 

on the Malheur National Forest (figure 2).

The lack of sufficient methods in the toolbox for treating invasive plants is hampering the agency’s 

ability to meet the desired condition described previously. For example, of 65 knapweed sites analyzed, 

46 sites had a record of previous manual or mechanical treatment. Of these, 70 percent of the previous 

treatments were not effective (Rausch 2013). This suggests that the majority of knapweed infestations 

on the Forest are not effectively treated with manual and mechanical treatment alone.

Aminopyralid is thought to be one of the lowest risk and most effective herbicides for treating 

knapweeds and several other target species on the Forest. A Malheur National Forest Land and 

Resource Management Plan Amendment is needed to add aminopyralid to the list of herbicides 

available for use on the Forest.

Invasive plants are estimated to be spreading at an average rate of 8-12 percent per year; the emphasis 

on prevention may be reducing this rate (potentially to as low as 4 percent per year), but new 

infestations are inevitable (R6 2005 FEIS and ROD). Invasive plant spread is unpredictable and actual 

locations of target species may change abruptly over time. Accordingly, the Forest needs the flexibility 

to adapt to changing conditions, and rapidly respond to invasive plant threats that may currently be 

unknown. Timeliness of action is an important factor because the cost, difficulty, and potential adverse 

effects of controlling invasive plants increases with the size and extent of the population. The smaller 

the population when treated, the more likely the treatment will be effective. The Forest needs a way to 

treat invasive plants effectively as soon as possible after they are detected. 

1.6 Proposed Action

The Forest Service proposes an integrated approach to treatments to suppress, contain, control, or 

eradicate invasive plants. Treatments would be a combination of herbicides, biological agents, 

mechanical and manual techniques. Cultural/restoration treatments, such as mulching, competitive 

seeding, or planting with native species would be implemented when needed to facilitate native plant 

recovery. Existing and new infestations would be treated. New infestations could include invasive plant 

21
Chapter 1 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

species that currently are not found on the Forest. The LRMP would be amended to provide for the use 

of the herbicide aminopyralid that was not available when the R6 2005 ROD was signed in 2005. For a 

full description of the proposed action (alternative B), please see chapter 2.

1.7 Management Direction

This EIS process and documentation has been completed according to direction contained in the 

National Forest Management Act (NFMA), the National Environmental Policy Act (NEPA), the 

Council on Environmental Quality (CEQ) regulations, and the Clean Water and Endangered Species 

Acts. The project is consistent with all applicable federal, state, and local laws. This EIS tiers to the 

Malheur National Forest Land and Resource Management Plan Final Environmental Impact Statement 

and Record of Decision (1990) and incorporates by reference the accompanying Land and Resource 

Management Plan (LRMP) (1990), as amended by the Inland Native Fish Strategy (INFISH 1995a) and 

the Interim Strategies for Managing Anadromous Fish Producing Watersheds (PACFISH 1995), where 

appropriate, also the Pacific Northwest Region Invasive Plant Program: Preventing and Managing 

Invasive Plants Final Environmental Impact Statement, and Record of Decision for the Pacific 

Northwest Region Invasive Plant Program: Preventing and Managing Invasive Plants (USDA Forest 

Service 2005a, USDA Forest Service 2005b).

The Federal Noxious Weed Act of 1974, as amended (7 U.S.C. 2810 et seq.) requires cooperation with 

state, local and other federal agencies in the application and enforcement of all laws and regulations 

relating to management and control of noxious weeds (a summary of this act can be viewed at:

http://ipl.unm.edu/cwl/fedbook/fedweed.html\). This Act directs the Secretary of Agriculture to develop 

and coordinate a management program for control of undesirable plants that are noxious, harmful, 

injurious, poisonous, or toxic on Federal lands under the agency’s jurisdiction, to establish and 

adequately fund the program, to complete and implement the cooperative agreements and/or 

memorandums, and to establish Integrated Weed Management to control or contain species identified 

and targeted under cooperative agreements and/or memorandums.

In 2011, the Chief of the Forest Service authorized Forest Service Manual 2900 (FSM 2900) for 

invasive species management. This project is consistent with this manual direction, which emphasizes 

integrated weed management (IWM) concepts and early detection/rapid response (EDRR). 

1.7.1 Land and Resource Management Plan

Management direction for the treatment of invasive plants on the Malheur National Forest is 

specifically provided by the Malheur National Forest Land and Resource Management Plan (LRMP) 

(1990), and the Ochoco National Forest LRMP (1989). Both plans were amended by the R6 2005 ROD. 

The R6 2005 ROD provided management direction for 1) public education and coordination, 2) 

prevention of the spread of invasive plants during land uses and activities, 3) treatment of target species, 

4) reducing reliance on herbicides over time, and 5) site restoration.

The standards that apply to invasive plant treatment and restoration are shown in table 1. Standards 

related to invasive plant prevention are not duplicated here; all projects on the Malheur National Forest 

include measures to prevent or slow the spread of invasive plants, such as:

♦ Timber sale and other contracts require washing heavy equipment

♦ Weed-free feed requirements in wilderness, later throughout national forests

♦ Weed-free rock source requirements 

♦ Coordination between road maintenance and invasive plant staff to ensure prevention practices 

are incorporated into road work

22
Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement – Chapter 1

♦ All project plans require invasive plant prevention measures to be included

♦ Invasive plant prevention measures are included in special use permits and grazing allotment 

management plans

Table 1. R6 2005 standards and project compliance

Standard # R6 2005 Standard (LRMP) Project Implementation Notes

11 Prioritize infestations of invasive plants for 

treatment at the landscape, watershed or larger 

multiple forest/multiple owner scale. 

The highest priority infestations are those we 

can eradicate. Treatments to contain larger, 

well established populations are lowest priority. 

Areas where we can reduce the density of 

invasive plant populations but not entirely 

eradicate them have medium priority. 

12 Develop a long-term site strategy for 

restoring/revegetating invasive plant sites prior 

to treatment.

The long-term strategy for restoration depends 

on the type of site infested, the target species, 

and location.

13 Native plant materials are the first choice in 

revegetation for restoration and rehabilitation 

where timely natural regeneration of the native 

plant community is not likely to occur. Nonnative, non-invasive plant species may be used 

in any of the following situations: 1) when 

needed in emergency conditions to protect 

basic resource values (e.g., soil stability, water 

quality and to help prevent the establishment of 

invasive species), 2) as an interim, nonpersistent measure designed to aid in the reestablishment of native plants, 3) if native plant 

materials are not available, or 4) in 

permanently altered plant communities. Under 

no circumstances will non-native invasive plant 

species be used for revegetation.

Revegetation (competitive seeding and 

planting) would occur as needed to replace 

invasive plants with native plant communities.

Non-native, non-persistent species may be 

used infrequently as an interim measure to 

control erosion or prevent target species from 

returning on treated sites. Restoration of native 

plant communities through mulching, seeding,

or planting would be considered as a follow up 

to invasive plant treatment.

14 Use only USDA Animal and Plant Health 

Inspection Service (APHIS) and state-approved 

biological control agents. Agents demonstrated 

to have direct negative impacts on non-target 

organisms would not be released.

Agents found to have negative impacts may not 

be distributed on the Forest. The R6 Regional 

Office updates the list regularly. 

15 Application of any herbicides to treat invasive 

plants will be performed or directly supervised 

by a state or federally licensed applicator.

All treatment projects that involve the use of 

herbicides will develop and implement

herbicide transportation and handling safety 

plans.

The elements of herbicide transportation and 

handling safety plans discussed in the project 

design feature section of chapter 2.

23
Chapter 1 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Standard # R6 2005 Standard (LRMP) Project Implementation Notes

16 Select from herbicide formulations containing 

one or more of the following 10 active 

ingredients: chlorsulfuron, clopyralid, 

glyphosate, imazapic, imazapyr, metsulfuron 

methyl, picloram, sethoxydim, sulfometuron 

methyl, and triclopyr. Mixtures of herbicide 

formulations containing 3 or less of these 

active ingredients may be applied where the 

sum of all individual Hazard Quotients for the 

relevant application scenarios is less than 1.0.

All herbicide application methods are allowed 

including wicking, wiping, injection, spot, 

broadcast, and aerial, as permitted by the 

product label. Chlorsulfuron, metsulfuron 

methyl, and sulfometuron methyl will not be 

applied aerially. The use of triclopyr is limited to 

selective application techniques only (e.g., spot 

spraying, wiping, basal bark, cut stump, 

injection).

Additional herbicides and herbicide mixtures 

may be added in the future at either the LRMP

or project level through appropriate risk 

analysis and NEPA/ESA procedures.

No aerial treatment is proposed in any 

alternative. A LRMP amendment would 

accompany a decision to add aminopyralid to 

the list of available herbicides. 

18 Use only adjuvants (e.g. surfactants, dyes) and 

inert ingredients reviewed in Forest Service 

hazard and risk assessment documents such 

as SERA, 1997a, 1997b; Bakke, 2002.

Adjuvants and inert ingredients would be from 

approved lists (see chapter 3.1 for more 

information on adjuvants).

19 To minimize or eliminate direct or indirect 

negative effects to non-target plants, terrestrial 

animals, water quality and aquatic biota 

(including amphibians) from the application of 

herbicide, use site-specific soil characteristics, 

proximity to surface water and local water table 

depth to determine herbicide formulation, size 

of buffers needed, if any, and application 

method and timing. Consider herbicides 

registered for aquatic use where herbicide is 

likely to be delivered to surface waters.

Chapter 3 discusses how risks from herbicide 

use are abated by project design features, 

including buffers and restrictions on herbicide 

use and method of application near botanical 

species of local interest, certain wildlife 

habitats, streams, and other water bodies.

20 Design invasive plant treatments to minimize or 

eliminate adverse effects to species and critical 

habitats proposed and/or listed under the 

Endangered Species Act. This may involve 

surveying for listed or proposed plants prior to 

implementing actions within unsurveyed habitat 

if the action has a reasonable potential to 

adversely affect the plant species. Use sitespecific project design (e.g. application rate 

and method, timing, wind speed and direction, 

nozzle type and size, buffers, etc.) to mitigate 

the potential for adverse disturbance and/or 

contaminant exposure.

Chapter 3 discusses how potential adverse 

effects to Endangered Species and critical 

habitats from herbicide use are minimized.

21 Provide a minimum buffer of 300 feet for aerial 

application of herbicides near developed 

campgrounds, recreation residences, and 

private land (unless otherwise authorized by 

adjacent private landowners).

No aerial application is proposed.

24
Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement – Chapter 1

Standard # R6 2005 Standard (LRMP) Project Implementation Notes

22 Prohibit aerial application of herbicides within 

legally designated municipal watersheds.

No aerial application is proposed.

23 Prior to implementation of herbicide treatment 

projects, National Forest staff will ensure timely 

public notification. Treatment areas will be 

posted to inform the public and forest workers 

of herbicide application dates and herbicides 

used. If requested, individuals may be notified 

in advance of spray dates.

Chapter 2 lists project design features,

including public notification requirements.

The Malheur National Forest LRMP outlines various management areas across the Forest and specific 

environmental standards and guidelines for each area. Table 2 displays the infested acreage within each 

management area. In some cases, the management direction is specifically related to invasive plant 

treatments. 

Table 2. Infested acres

LRMP Management Area (MA) Infested Acres MA Guidance Related to This Project/How Project 

Complies

Big Game Winter Range 

Maintenance

172.3 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1. 

General Forest 6.4 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1.

General Forest-Rangeland 720.3 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1.

Long Creek Municipal Supply 

Watershed

0.1 R6 2005 ROD (Forest LRMP) standards do not allow 

aerial spraying in municipal watersheds (see table 1)

The low level of current infestation likely does not 

require any use of herbicides.

Monument Rock Wilderness 1.1 No motorized equipment or mechanical/motorized 

access allowed. 

Old Growth 342.1 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1.

Old Growth-District 4-18 0.0 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1.

Research Natural Area 0.1 The Forest Supervisor is responsible to “protect 

research natural areas” (FSM 4063.04b). FSM 4063.3 

requires removal of exotic plants or animals to the 

extent practicable.” Treatments within RNAs will be

coordinated with the Pacific Northwest Research 

Station.

Riparian Areas (Anadromous and 

Non-Anadromous Fish Bearing 

Streams)

239.9 PACFISH-INFISH: Treatments in riparian habitats 

designed to follow riparian management objectives. See 

Chapter 3.6.3.

Scenic Area 0.5 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1.

Semi-Primitive Non-Motorized 

Recreation Areas

4.1 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1.

Strawberry Mountain Wilderness 420.0 No mechanical motorized equipment or 

mechanical/motorized access allowed.

Visual Corridors (Foreground) 194.4 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1.

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Chapter 1 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

LRMP Management Area (MA) Infested Acres MA Guidance Related to This Project/How Project 

Complies

Visual Corridors (Middleground) 1.5 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1.

Visual Corridors (Partial Retention) 2.7 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1.

Visual Corridors (Retention) 1.0 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1.

Wild and Scenic River 1.1 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1.

Wildlife Emphasis Area (With NonScheduled Timber Harvest)

0.3 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1.

Wildlife Emphasis Area (With 

Scheduled Timber Harvest)

16.0 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1.

Winter Range 172.3 No specific MA guidance related to invasive plants. See 

Forestwide Standards in table 1.

1.7.2 Additional Guidance

Ochoco LRMP

The Ochoco National Forest LRMP contains some specific invasive plant guidance from a 1995 Forest 

Plan amendment (Amendment #15). This section has been added between DEIS and FEIS to clarify 

that the Ochoco LRMP applies to the portion of the project within the 240,000 acres of the Ochoco 

National Forest that are managed by the Malheur Forest previously known as the Snow Mountain 

Ranger District, now managed as part of the Emigrant Creek Ranger District.

Forest-Wide Standard: Districts will coordinate closely with the respective county weed board to 

ensure sharing of information regarding infestations, treatments, etc. 

How Project Complies: There has been, and will continue to be, coordination with counties on the 

treatment methods and priorities. Local invasive plant management information was obtained from 

Oregon State Department of Agriculture and local county invasive plant management staff. See Chapter 

4. 

Forest-Wide Standard: Provide for ongoing public participation and information, and other agency 

coordination during all noxious weed management activities. Coordinate with county officials and 

others to prevent and control noxious weeds. Identify species and infestation of most concern, and 

opportunities for joint prevention and control activities.

How Project Complies: Public participation has occurred through the planning process and will occur 

during implementation (see Implementation Planning Process Chapter 2.3.2).The public will be 

informed about herbicide treatments that occur over time. There has been, and will continue to be, 

coordination with counties about noxious weed prevention and treatment.

Forest-Wide Standard: Implement integrated noxious weed treatments, including manual, chemical, 

biological, cultural, and mechanical methods, based on site-specific analysis. Maintain documentation 

of annual noxious weed treatments.

How Project Complies: Action alternatives meet this standard. See implementation planning process 

(Chapter 2.3.2). 

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Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement – Chapter 1

Forest-Wide Standard: Inform the public of planned herbicide use locations prior to initiating control 

projects.

How Project Complies: PDFs include public notification (see table 10, Group K)

Forest-Wide Standard: Record annually the quantity of herbicides used; document reduced reliance 

on herbicide use over time

How Project Complies: Action alternatives meet this standard. Recording quantities of herbicides used 

annually is required by Forest Service policy. Reducing reliance on herbicides over time is an objective 

in the R6 2005 ROD.

Wilderness Act

Invasive plant treatment within wilderness areas would be aimed at preserving or protecting wilderness 

character. Treatments using motorized equipment are not generally compatible with wilderness status.

Endangered Species Act

The Forest Service is consulting with the U.S. Fish and Wildlife Service (USFWS) and National Marine 

Fisheries Service (NMFS) to ensure the project would not jeopardize the continued existence of 

federally listed species (or species proposed or considered candidates for listing).

Clean Water Act

A Clean Water Act (National Pollution Discharge Elimination System - NPDES) permit is required for 

herbicide use that may directly enter streams. The permit is needed for herbicide treatments within 3 

feet of streams, wetlands, and other seasonally wet areas when water is present, including conveyances 

with a hydrologic surface connection to a water body (e.g., near a road culvert that runs water to a 

creek). Treatments on small portions of infestations (currently mapped or detected in the future) may 

meet the criteria; however, the type of infestations currently found on the Malheur National Forest are 

not riparian dependent. The current mapping is not refined enough to determine whether a permit will 

ultimately be needed; however, NPDES Pesticide General Permits would be obtained prior to 

implementing any treatments in which herbicide could be directly introduced into surface waters. This 

generally includes treatment within stream banks or for target plants that emerge from or overhang 

water bodies. Pollution control requirements would be satisfied by the project design features in this 

project.

Clean Water Act compliance includes use of best management practices (BMPs). The project design 

features in chapter 2 include BMPs to protect water quality as described in the National Best 

Management Practices Technical Guide (USDA Forest Service 2012). Core objectives for applying 

BMPs to chemical uses on National Forests include:

♦ Use the planning process to develop measures to avoid, minimize, or mitigate adverse effects to 

soil, water quality, and riparian resources from chemical use on NFS lands.

♦ Avoid or minimize the risk of soil and surface water or groundwater contamination by 

complying with all label instructions and restrictions required for legal use.

♦ Avoid or minimize the risk of chemical delivery to surface water or groundwater when treating 

areas near waterbodies.

1.8 Decision to be Made

The Malheur National Forest Supervisor is the responsible official for this EIS and will make the 

following decision:

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Chapter 1 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

♦ Whether or not to authorize site-specific invasive plant treatments using herbicides and other 

methods

♦ Whether or not to amend the Malheur National Forest LRMP

♦ Whether or not to implement an early detection/rapid response process for infestations that are 

detected during the life of the project

♦ What project design features are required

♦ What monitoring will occur

1.9 Public Involvement and Scoping 

Ongoing public involvement has occurred throughout this NEPA process. Tribes have been consulted 

and input from federal and state agencies has been sought. The proposed action was circulated for 

scoping input in 2006 and again in 2011.

Scoping Respondents in 2011 included: Dick Artley, Karen Coulter, Blue Mountains Biodiversity 

Project (BMBP), Doug Heiken (Oregon Wild), the Grant Soil and Water District (GSWD), and the 

National Park Service (NPS).

Scoping Respondents in 2006 included: Karen Coulter (BMBP); Oregon Natural Desert Association 

(ONDA); Center for Tribal Water Advocacy (CTWA); U.S. Environmental Protection Agency (EPA); 

Doug Heiken with others Oregon Natural Resource Council (ONRC); Matt Carter; Walt Gentis, Nancy 

Hafer; Phil Turrell (RMEF); Dan Bishop; Assante Riverwind (Sierra Club); John Day RAC, Jean 

Public; and Gregg Smith.

The Forest Service reviewed scoping responses and identified issues—points of discussion, debate or 

dispute about environmental effects—related to the proposed action. The significant public issues relate 

to the cost-effectiveness of the treatments proposed and the potential adverse effects of herbicide use. 

1.10 Issues

The following significant issues influenced the analysis of alternatives in this EIS: 

♦ Treatment cost-effectiveness 

♦ Herbicide impacts to human health

♦ Herbicide impacts on non-target vegetation and pollinators

♦ Herbicide delivery to water and impacts on fish

♦ Herbicide impacts on wildlife

1.10.1 Treatment Cost-Effectiveness

Issue Statement: Restrictions on herbicide use reduce treatment effectiveness and increase treatment 

costs.

Background: Integrated invasive plant treatments need to be timely and cost-effective to be able to 

result in suppression, containment, control, or eradication of invasive plants. Restrictions on herbicide 

type, timing, extent, rate, and application method (beyond label restrictions and R6 2005 ROD 

standards) limit our ability to effectively treat known and new sites. Treatment costs and need for retreatment are directly affected by the range of effective treatments available in the toolbox for any given 

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Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement – Chapter 1

site. Increased costs and reduced effectiveness decrease the acreage that can be effectively treated with 

limited funding. This issue is directly addressed in chapter 3.1.4.

Issue Measures: 

• Average cost per acre of effective treatment (includes re-treatments and restoration)

• Total cost assuming treatments are fully funded

• Ability to meet treatment objectives

1.10.2 Herbicide Impacts to Human Health

Issue Statement: Human health may be harmed by herbicide exposure.

Background: This issue speaks to general concern about herbicides and the risks to workers and the 

public from proposed herbicide use. For the most part, by following the management direction for 

herbicide use from the R6 2005 ROD, which amended the Malheur National Forest LRMP, herbicide 

use would not result in exposures above conservative thresholds of concern for human health. The risk 

assessment for aminopyralid demonstrates that this herbicide does not pose additional risks to human 

health. At the project level, risks are further minimized through project design features (table 10) and 

herbicide-use buffers (table 11 and table 12) that avoid certain types of exposures. This issue is 

addressed in chapter 3.2. Additional information about drinking water sources is in chapter 3.5.

Issue Measures: 

• Type (rate, method, chemical properties) and extent of herbicide use that could result in toxic 

herbicide exposure to people

• Qualitative assessment about the effectiveness of herbicide-use buffers8 and other project design 

features to prevent toxic herbicide exposure to people

• Potential for herbicides to affect drinking water

1.10.3 Herbicide Impacts on Non-target Vegetation

Issue Statement: Proposed herbicide use may harm non-target plants, specifically sensitive and other 

special status species, cultural use plants, and special forest products. 

Background: Herbicides are designed to kill plants and there is always a risk that herbicide will affect 

non-target botanical species (vascular and non-vascular plants, fungi, algae, lichens, bryophytes, 

liverworts). The presence of special-status species, treatment extent, rate and method of application, and 

the properties of the chemicals proposed influence the degree of risk. This issue is addressed in chapter 

3.3.

Issue Measures: 

• Type and extent of herbicide use within 100 feet of botanical species of conservation concern, 

cultural use plants, and special forest products

• Qualitative assessment about the effectiveness of herbicide-use buffers and other project design 

features to prevent herbicide from harming non-target botanical species and pollinators

8 Herbicide-use buffers are areas near streams and other water bodies where some types of herbicide use are 

restricted.

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Chapter 1 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

1.10.4 Delivery to Water and Potential Herbicide Impacts on Fish

Issue Statement: Proposed herbicide use may result in chemicals reaching streams and other water 

bodies (through drift, leaching, and/or run off) and adversely affect fish and their habitat.

Background: The proposed action will minimize potential for herbicide delivery to streams and other 

water bodies. However, the risk that some chemicals may reach surface waters cannot be eliminated. 

Treatment extent, rate and method of application, and the properties of the chemicals proposed 

influence the degree of risk. Specific concern about picloram use has been expressed due to its potential

mobility and persistence in the soil. The main focus of this issue is the potential for herbicide impacts to 

aquatic species of conservation concern. This issue is addressed in chapter 3.5 and 3.6.

• Type and extent of herbicide use within 100 feet of streams and other water bodies

• Qualitative assessment about whether fisheries might be affected and in what way

1.10.5 Herbicide Impacts on Wildlife

Issue Statement: Proposed herbicide use may result in harmful exposure to terrestrial wildlife,

including pollinators (specifically species of conservation concern). 

Background: Most of the herbicides proposed for use pose no risk to terrestrial wildlife and 

amphibians. The focus of this issue is on the herbicides that pose a small risk, meaning that there are 

some plausible exposure scenarios that exceed the no-effect level. There is limited information about 

effects on amphibians, so pdfs are in place to add an extra layer of caution to protect these species (table 

10). Hexachlorobenzene (HCB), an industrial contaminant within picloram, and to a lesser extent, 

clopyralid, poses potential risks to raptor eggs. This is one reason aminopyralid is the first-choice

herbicide between the three, as no HCBs are present in aminopyralid. This issue is addressed in chapter 

3.7.

Issue Measures: 

• Type and extent of herbicide use within wildlife habitats for wildlife species of conservation 

concern 

• Risk of HCB contamination and effects on raptor eggs 

• Narrative assessment about whether, and how wildlife species of conservation concern and 

amphibians might be affected

1.10.6 Other Issues

Some public concerns expressed in scoping responses are not considered significant issues because they 

are addressed through routine compliance with management direction, are addressed through tiering to 

the R6 2005 FEIS, or are addressed by best available science.

Issues Addressed by Compliance with Management Direction 

Some public concerns are not considered significant issues for analysis but are routinely addressed in 

the course of environmental analysis. Compliance with existing management direction, permits, and 

other requirements associated with the action, and disclosure of findings and determinations associated 

with endangered species act consultation are some of the topics that are covered in this EIS, but are not 

considered significant issues. 

The proposed action will be designed to follow relevant management direction (an LRMP amendment 

is proposed to allow use of aminopyralid, which is intended to meet other standards requiring that 

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Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement – Chapter 1

impacts be minimized through site-specific selection of chemicals and other measures). In addition, we 

are working with tribal governments and others to ensure environmental justice and protection of 

heritage resources and treaty rights. An issue regarding “the spiritual and cultural need to have a source 

of food and medicine available that has not been contaminated with toxins, and the joy and solace in 

gathering plants in their natural setting” was raised in comments to the Draft EIS. This issue is 

addressed by the design of the project which would 1) minimize potential for impact to non-target 

plants; 2) mark treated areas with dye to allow people to see where herbicide has been sprayed; and 3) 

allow the public to identify areas they use for food or medicine gathering to determine whether these 

areas may be sprayed and to ensure these areas are prominently marked or posted. 

Impacts to soils have been resolved through adherence to the R6 2005 ROD standards and additional 

project design features. None of the alternatives pose significant threats to soils given the nature of the 

types of treatments proposed. The approach to soils in this document is to analyze how herbicides are 

filtered through various soil types and their eventual environmental fate, with the main issue ultimately 

being potential effects on fish. 

In addition, we are working with tribal governments and others to ensure environmental justice and 

protection of heritage resources and treaty rights. The sections on human health, botany, and archeology 

offer more information about these topics.

Issues Addressed by Tiering to the R6 2005 FEIS

Some commenters remarked that changes in land uses and other measures should be applied to forest 

activities to prevent or slow the spread of invasive plants. Prevention applied to land uses is not a 

connected action to this project. The R6 2005 FEIS discussed the programmatic relationship between 

prevention, the spread of weeds, and the eventual need for treatment (chapter 4.1.3). Causes and vectors 

of invasive plant spread are specifically addressed in the R6 2005 FEIS (chapter 3 and appendices). 

This treatment project EIS is tiered to the R6 2005 FEIS and relies on these discussions where 

necessary to address the relationship between land uses and invasive plant spread. However, at the 

project level, the need for suppression, eradication, control, and containment of invasive plants will still 

exist regardless of how the prevention standards from the R6 2005 ROD, along with other management 

direction, are implemented. The R6 2005 FEIS acknowledges that invasive plants will continue to 

spread, and treatment will continue to be needed; even with prevention measures applied to land uses 

(R6 2005 FEIS 4.1.3).

Issues Addressed by Best Available Science 

This analysis incorporates peer-reviewed herbicide risk assessments and site-specific risk models, 

which constitute the best available science regarding herbicide toxicity. Some information used in the 

risk assessments may be based on studies conducted by chemical manufacturers. Some people express 

concern about the validity of information supplied by chemical manufacturers; these concerns cannot be 

resolved in this project. Established scientific protocols are followed in studies related to herbicide 

toxicity supplied by manufacturers as part of the herbicide registration process. This information is 

incorporated in the Forest Service risk assessments, with a focus on Forest Service herbicide 

applications. Herbicide exposure worksheets and models quantify degree of risk associated with 

herbicide exposure scenarios that are plausible for the proposed action and alternatives. This 

methodology provides a way to make best available scientific information applicable at the project 

level. 

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Chapter 1 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

1.11 What this Proposal Does Not Include

♦ This action does not include experimental trials of herbicides conducted by the U.S. 

Environmental Protection Agency (EPA) to test new products.

♦ This action does not include activities that could influence invasive plant populations but are 

covered under other programs. Such programs include transportation planning, timber 

management, livestock grazing, etc. Invasive plant prevention and treatment activities are 

incorporated into individual projects carried out under regulation and guidance of these 

programs.

♦ No treatment of aquatic invasive plants is proposed. 

♦ No aerial herbicide application is proposed. 

♦ No mechanical restoration treatments, such as scarification, are proposed. 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Chapter 2. Alternatives, Including the Proposed Action

2.1 Introduction

This chapter summarizes and compares four alternatives for invasive plant treatments including the no-action

alternative. No action for this environmental impact statement (EIS) is defined as not using integrated 

treatment methods and not following updated management direction for invasive plants.

Under alternative A-no action, invasive plant treatments would not be authorized as part of a decision on this 

project-level EIS. Projects similar to the current program would likely be authorized under categorical 

exclusions or connected actions associated with other project decisions. Please see the glossary for a 

definition of categorical exclusions and connected actions. Biological agents would likely continue to find 

their way onto the Malheur National Forest, but none would be deliberately released by Forest personnel. 9

More information about the no-action alternative can be found later in this chapter. 

Alternative B-proposed action provides for effective invasive plant treatments. Project design features 

minimize the possible adverse effects of treatment in accordance with the LRMP for the Malheur National 

Forest (chapter 1, management direction).

2.2 Extent of the Primary Target Species and Management 

Objectives

As of November 2012, approximately 2,124 acres containing target invasive plant species have been mapped

within the project area (figure 2). There are 18 primary target invasive species within 3,070 mapped infested 

sites (GIS polygons). Site-specific integrated treatment objectives and methods (also referred to as common 

control measures) vary depending on the size and density of the infestation, location, the target species, and 

the design features associated with each action alternative. Invasive plants are scattered throughout the 

infested areas with density ranging from less than 10 percent to 100 percent primary target species.10

Preliminary treatment objectives were assigned to each of the primary target species depending on its

potential negative impacts, the size of infestations, and the values or sensitivity of the infested sites (or 

adjacent lands). These objectives are subject to change as site conditions change over time. Table 3 displays 

our current treatment objectives for the 18 primary invasive species mapped on the Malheur National Forest. 

“Eradication” is our highest priority, and “tolerate” represents the lowest priority for integrated treatment and 

restoration. All other things being equal, we would treat highest priorities first. However, many variables 

factor into the annual program of work, including funding mechanisms and location and timing of 

neighboring projects. Below are definitions of our invasive plant treatment objectives. R6 2005 Standards 12 

and 13 require that we identify the desired future condition and objectives before implementing integrated 

treatments.

Eradicate: Eliminate an invasive plant species from a site. This objective generally applies to species that 

pose a greater risk to resources and cover small areas. Some occurrences may be on roadsides (Russian 

knapweed, squarrose knapweed) and others may occur in intact native vegetation (yellow starthistle, small 

occurrences of thistles or knapweed, new invaders). This is generally the first priority for treatment.

Control: Reduce the size of the infestation over time; some level of infestation may be acceptable. This 

objective applies to most of the target species (houndstongue, leafy spurge, perennial pepperweed, sulfur 

9 Invasive plant treatments would likely continue on state road rights-of-way and easements within the Malheur 

National Forest because they are not subject to Forest Service control. 10 This analysis assumes all sites are 100% occupied by invasive species because this variable is subject to rapid change.

33

 
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

cinquefoil, whitetop) and large infestations of thistles and knapweeds. This is generally the second priority 

for treatment.

Contain: Prevent the spread of the weed beyond the perimeter of patches or infestation areas mapped from 

current inventories. This objective applies to target species such as common St. Johnswort. This is generally 

the third priority for treatment.

Suppress: Prevent seed production throughout the target patch and reduce the area coverage. Prevent the 

invasive species from dominating the vegetation of the area; low levels may be acceptable. This objective 

applies to target species, such as toadflax, that would be treated mainly with biocontrol agents. This is 

generally the fourth priority for treatment.

Tolerate: Accept the continued presence of established infestations and the probable spread to ecological 

limits for certain species. This category is for species that are so widespread and abundant that other 

objectives would be extremely difficult to meet. This category includes species, such as cheatgrass, 

medusahead, North Africa grass, dandelion, mullein, and bulbous bluegrass. These invasive plants have low 

priority for treatment and would likely only be treated if they happen to be near one of the primary target 

species.

Table 3. Current treatment objectives for mapped, primary invasive plant species

Target 

Species

Category

Common Name

Spatial Extent 

(November 2012) Treatment Objective

Sites Acres

Knapweeds

Spotted knapweed 171 82

Eradicate small isolated sites in 

ecologically sensitive areas

Control large open sites and linear 

roadside populations

Diffuse knapweed 213 74

Eradicate small isolated sites in 

ecologically-sensitive areas

Control large open sites and linear 

roadside populations

Russian knapweed 43 4 Eradicate

Squarrose knapweed 3 <1

Eradicate small isolated sites in 

ecologically-sensitive areas

Control large open sites and linear 

roadside populations

Meadow knapweed 2 <1

Eradicate small isolated sites in 

ecologically-sensitive areas

Control large open sites and linear 

roadside populations

Starthistle Yellow star-thistle 3 1 Eradicate

Thistles

Canada thistle 1,277 1,021 Control

Bull thistle* 0* 0*

Eradicate small infestations in 

ecologically-sensitive areas

Control roadside infestations, large open 

sites and forested sites

Scotch Thistle 61 23

Eradicate small isolated sites in 

ecologically-sensitive areas

Control large open sites and linear 

roadside populations

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Target 

Species

Category

Common Name

Spatial Extent 

(November 2012) Treatment Objective

Sites Acres

Musk thistle 13 11

Eradicate small infestations in 

ecologically-sensitive areas

Control roadside infestations, large open 

sites and forested sites

Roadside

Species

Common St. Johnswort 185 120 Contain

Houndstongue 171 340 Control

Sulphur cinquefoil 61 186 Control

Toadflax

Dalmatian toadflax 666 155 Suppress

Yellow toadflax 27 9 Suppress

Mustards Whitetop 148 85 Control

Perennial pepperweed 12 2 Control

Spurge Leafy spurge 14 10 Control

Total 1358 941

*Bull thistle and Canada thistle were cataloged together in our November 2012 invasive plant inventory. However, the precise species 

would be identified to determine the specific treatment objective for a given site.

2.3 Alternatives Considered in Detail

2.3.1 Alternative A – No Action

The no-action alternative is a requirement of NEPA (36 CFR 220) to provide a baseline for comparison of 

effects of action alternatives. If the no-action alternative is selected for this project, no invasive plant 

treatments would be authorized. The Malheur National Forest invasive plants treatment program would not 

follow current regional and national invasive plant management direction that allows the application of 

selected herbicides (see alternative 2 description).

Since 2002, when use of biological agents and chemicals for invasive plant control was enjoined by the court 

on the Malheur National Forest, most treatments have been manual (primarily hand pulling and digging) with 

limited mechanical treatment (primarily mowing). 

In 2010, the Malheur National Forest treated about 375 acres with manual and mechanical treatments using 

“Forest Service personnel, County cooperators, and Nature Conservancy volunteers” (R6 2010

accomplishment report). In 2011, the Malheur National Forest treated 203 acres in essentially the same 

manner (R6 2011 accomplishment report). Year 2012 saw a drop in manual and mechanical acres 

accomplished to 39 (R6 2012 accomplishment report). Partners and cooperators in 2012 were the 

Confederated Tribes of the Warm Springs, Harney County, the Nature Conservancy, Oregon Department of 

Agriculture, and Oregon Department of Transportation.

If alternative A-no action is selected, the Forest Service would not treat invasive plants as proposed in the 

action alternatives. Invasive plant treatments would likely continue on state road rights-of-way and 

easements within the Malheur National Forest because they are not subject to Forest Service control. Any 

future treatments would require separate environmental analyses. For example, categorical exclusions may 

be completed to authorize manual and limited mechanical treatments in site-specific areas. Prevention 

measures applied during land management activities would continue to slow (but not stop) the spread of 

invasive plants on the Forest and surrounding lands (see chapter 3.1.5 for more information about the 

potential for spread of invasive plants over time within the Forest) given the propagule pressure and type of 

expected disturbance associated with surrounding land uses and activities. 

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Alternative A addresses some public concerns by eliminating most herbicide use on the Forest. There would 

continue to be low or no risks or impacts from herbicides on human health, non-target vegetation, soils, 

water and aquatic organisms, or wildlife. However, the threats to the environment from invasive plants 

would continue unabated. Neighbors would continue to be frustrated in their attempts to enlist the Forest 

Service to help with partnerships to implement effective integrated treatments within and outside Forest 

boundaries. 

No biological agents were deliberately released within the Malheur National Forest boundaries, because the 

2002 Court Order enjoined the Forest Service from releasing these agents. However, biological agents that 

have been released in surrounding National Forests and lands of other ownerships disperse to new areas on 

their own. The analyses of the environmental effects of biological control agents have already been 

completed under documents developed by Agricultural Plant Health and Insect Service (APHIS) for approval 

of their use. The completed environmental impact statements are available at: 

http://www.aphis.usda.gov/plant_health/ea/index.shtml. These analyses assume the agent may occur 

throughout the range of its host invasive species.

Therefore, although they have not been released by the Malheur National Forest, biological control agents 

are helping to suppress or contain established populations of invasive plants here. Common biological agents 

released on neighboring Forests and adjacent counties and likely already distributed on the Malheur National 

Forest are displayed in the following table. Agents likely to be redistributed on the Forest are discussed under 

the action alternatives. 

Table 4. Biological agents released on neighboring lands

Target Species Agent Mode of Action

Bull Thistle Urophora stylata Larvae form a hard multi-chambered gall in the flower 

receptacle that interferes with seed production.

Canada Thistle Ceutorhunchus litura Larvae mine pith in stems of flowering plants, increasing 

susceptibility to pathogens. Adults feed on leaves.

Canada Thistle Urophora cardui Larvae cause galls on the stems that act as nutrient sinks, 

stressing plants and reducing seed production and growth.

Dalmatian Toadflax Mecinus janthinus Larvae are stem miners; adults can cause damage to 

flowers and young leaves.

Diffuse Knapweed

Spotted Knapweed

Meadow Knapweed

Urophora affinis

Urophora quadrifasciata

Larvae overwinter in the seed heads. Developing larvae 

cause the plant to form a gall around the reproductive parts 

and create a metabolic sink, drawing nutrients from the 

plant that extend beyond the attacked seed head.

Field Bindweed Aceria malherbae

Adult and nymphal mites suck plant juices that deforms 

leaves and developing buds, which interferes with 

flowering, seed production, and reduces plant biomass.

Leafy Spurge

Aphthona cyparissiae, 

Aphthona flava, 

Apthona nigriscutis

Aphthona czwalinae, 

Apthona lacertosa

Adults feed on foliage reducing the plant's production of 

sugars; larvae feed on root hairs and young roots reducing 

the plant's ability to take up water and nutrients.

Leafy Spurge Oberea erythrocephala Larvae bore in the stems and roots of larger plants. Adults 

girdle the top of the stalk before laying eggs in the stem.

Mediterranean Sage Phrydiuchus tau Adults feed on the leaves, and larvae feed in the root crown 

and petioles of large leaves.

Musk Thistle Rhinocyllus conicus1 Larvae eat seeds in primary heads, lateral heads still

produce seed.

Musk Thistle Trichosirocalus horridus

Larvae feed on the root crown, damaging the primary shoot, 

and adults feed on the leaves. Large numbers of larvae can 

kill rosettes.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Target Species Agent Mode of Action

Musk Thistle Urophora solstitialis Larvae cause galls in the seed heads that interfere with 

seed production and dissemination.

Spotted Knapweed Cyphocleonus achates Larvae are root borers and adults feed on the leaves

Spotted Knapweed Metzneria paucipunctella Larvae consume seeds in infested heads.

Spotted Knapweed, 

Diffuse Knapweed Bangasternus fausti

Attacks early buds, and appears to contribute to the 

impacts of Larinus minutus. Larvae consume most of the 

seeds in infested heads.

Spotted Knapweed, 

Diffuse Knapweed Larinus minutus

Larvae feed in the flower head destroying most of the 

seeds. Heavy attack by adults can stunt or kill plants and 

delay flowering.

Spotted Knapweed

Meadow Knapweed

Diffuse Knapweed

Larinus obtusus Larvae consume the seeds and adults can defoliate plants 

when in large numbers.

St Johnswort Chrysolina quadrigemina

Chrysolina hyperici Adults and larvae are foliage feeders.

Tansy Ragwort Longitarsus jacobaeae The larvae feed on the roots of the target plant.

Yellow Starthistle Bangasternus orientalis Larvae feed on seeds and seed heads, reducing the 

number of seeds by 40-60%

Yellow Starthistle Chaetorellia australis Larvae tunnel into the center of the head, where they feed 

on the ovaries and developing seeds.

Yellow Starthistle Chaetorellia succinia1 Larvae tunnel into the center of the head, where they feed 

on the ovaries and developing seeds.

Yellow Starthistle Eustenopus villosus Adults feed on developing buds, causing the buds to die.

Larvae feed on the seed head and developing seeds.

Yellow Starthistle Larinus curtus Adults feed on the flowers and larvae feed on the seed 

head, reducing seed production.

Yellow Starthistle Urophora sirunaseva Larvae feed on flowers and seed heads and cause 

formation of galls.

1

These agents are no longer approved for use in Oregon or Region Six. They do not meet Standard 14. Remnant populations may be 

found on host species in the region. 

2.3.2 Alternative B – Proposed Action

Introduction

Alternative B – proposed action, is our proposal as the most cost-effective approach to invasive plant 

treatment while minimizing the potential adverse effects of treatment according to the Malheur National 

Forest LRMP as amended by the R6 2005 ROD. The Responsible Official has identified alternative B as the 

preferred alternative.

We inventoried the invasive plants across the Malheur National Forest and identified common control 

measures for the 18 primary target species found. The common control measures include a range of 

integrated treatment/restoration methods that could be implemented across a range of infested sites. We will 

identify the specific manual, mechanical, biological, herbicide and cultural/restoration treatments to be 

implemented at the time of treatment (see common control measures table below). 

In addition to the common control measures (table 9), we developed project design features (table 10) and 

herbicide-use buffers (table 11and table 12) for alternative B. The project design features and herbicide-use 

buffers are intended to minimize adverse effects of treatment and follow National Best Management Practice 

Guidelines for Chemical Uses on National Forests (USDA Forest Service 2012).

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

To develop the common control measures, project design features, and herbicide-use buffers, we considered 

the best available scientific information about invasive plant management. The literature cited section of 

chapter 4 documents our commitment to using best available science and high quality data. 

Alternative B responds to the purpose and need for action by authorizing several herbicide and other 

integrated treatment methods to be implemented on the Malheur National Forest. Alternative B is designed to

effectively reduce the size and density of invasive sites and abate the adverse effects of invasive plants.

Aminopyralid would be used initially for about 1,350 acres (64 percent of the total infested acreage). This 

herbicide is likely to be the most effective of the 11 available herbicides for 12 of the 18 primary target 

species (all except houndstongue, both toadflaxes, pepperweed, and whitetop, which have chlorsulfuron as 

the first-choice herbicide; and sulphur cinquefoil, which has metsulfuron methyl as the first-choice

herbicide). 

Other effective herbicides from the approved list could be used as needed over time. The selection of 

herbicide would be informed by many factors including field experience and new scientific information, 

juxtaposition of target species, detection of new target species that require one of the other approved 

herbicides, potential for herbicide resistance over time, and cost.

Alternative B responds to public concerns about treatment effectiveness by authorizing a wide range of 

integrated treatment methods that would be prioritized, planned, and implemented in cooperation with our 

neighbors. We would start to use herbicides and redistribute biological control agents on the Forest as soon as 

practicable after the decision. Alternative B is, by definition, the most cost-effective alternative.

Alternative B favorably responds to issues about effects of herbicides on human health, non-target 

vegetation, soils, water and aquatic organisms, wildlife, pollinators, and special places because treatments 

would be implemented according to design features and herbicide-use buffers that minimize the risk of 

adverse effects.

Changes Made to Alternative B For the Final EIS

Some changes were made to alternative B since release of the Draft EIS. These changes are generally 

intended to help respond to public comments. 

♦ Pdf B1: Explicit mention of coordination to ensure that treatments within municipal watersheds are 

supported by water managers.

♦ Pdf F1: No use of POEA or NPE-based surfactants to further reduce risks to people and the 

environment. 

♦ Pdf E3: Included to reduce potential for sediments to enter aquatic areas, based on consultation with 

the National Marine Fisheries Service and US Fish and Wildlife Service.

♦ Pdf F2: Drop reference to NPE. Limit spot spray of triclopyr to typical rates per acre. Clarify that 

herbicide rates are measured on a per-acre basis. These changes are intended to further reduce risks 

to people and the environment. 

♦ Pdf F4: Apply measures to reduce drift to all application methods (not just broadcast) to further 

minimize the low potential for drift from spot applications. 

♦ Pdf F7: Included to confirm that herbicide use meets local, state, regional, and national requirements 

that may change over time. Added in response to consultation with the National Marine Fisheries 

Service and US Fish and Wildlife Service.

♦ Pdf G1: Clarified to ensure that the quantity of herbicides to be transported to treatment sites are 

limited to the amount needed for a given day.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

♦ Pdf H4: This pdf was modified to decrease the frequency of use for aminopyralid, imazapyr, 

metsulfuron methyl and picloram. Picloram, imazapyr and metsulfuron methyl would only be used 

once every other year on any given treatment site (except to fill in skipped areas during the initial 

treatment). This was changed from once per year. Aminopyralid would be used only once per year

(except to fill in skipped areas during the initial treatment, as long as the total use in a given year 

does not exceed the maximum label rate shown in table 8). Pdf H4 was modified to address concerns 

about potential persistence of these herbicides under some soil/climate conditions.

♦ Pdf H7: Minor clarification.

♦ Pdf H10: Minor clarification. 

♦ Pdf H11: Was removed and combined with a similar pdf (F3). 

♦ Pdf HI4: Minor clarification. Previously it had a redundancy with the H group regarding run off of 

some herbicides. 

♦ Pdf J6-a: Clarify that triclopyr BEE is the only ester formulation proposed for use in this project. 

♦ Pdf J13 was added to provide protection measures for the yellow-billed cuckoo. 

♦ Pdf I4: Minor clarification.

♦ Pdf K1: Minor clarification. 

♦ Pdfs L2-L4: Forest product gathering areas are not mapped so there was concern that these pdfs 

would not be implementable as written in the draft. The changes to these pdfs ensure that areas 

identified by the public will be prominently posted so that they may avoid medicinal/edible plant 

gathering in areas where herbicide has been used. 

♦ Pdfs L2 and L3 were combined into one pdf (L2) and reference to the spiritual dimension related to 

herbicide use and plant collection was added.

Other changes:

• The statement has been added that passive restoration may include keeping cattle away from treated 

areas until the area has recovered and contains desirable vegetation.

• An acreage treatment cap for all treatment methods (except biological controls) has been added to 

ensure that no more than 50 acres per year would be treated within 100 feet of a water body in any 

6th field watershed. Of these, herbicide use would be limited to 10 acres.

• Herbicide use buffers have been modified to include roadside ditches that are hydrologically 

connected to streams, when surface water is present in the ditch.

• The biological control agents table has been updated to 1) explain that a previously released thistle 

agent is not approved for R6, and 2) omit agents that have not been effective in eastern Oregon.

• The risk assessment year and reference has been updated to include 2011 assessments for imazapyr, 

picloram, and triclopyr.

• The 30,000 acre life of the project cap was removed because it did not provide any analytical or 

other value. The analysis assumes no more than 2,124 acres would be treated using herbicide 

annually. The 5-15 year duration of the project was clarified to remove any implication that this is a 

project cap; the duration provides for analytical consistency however this project may be 

implemented over a longer period of time. 

This section has been reorganized for clarity and additional information about treatment methods has been 

included. 

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Land and Resource Management Plan Amendment

We are proposing a Land and Resource Management Plan amendment to add aminopyralid to the list of 

acceptable herbicides for use as part of the integrated treatment toolbox for invasive plants on the Malheur 

National Forest. This amendment would also apply to the former Snow Mountain Ranger District of the 

Ochoco National Forest that is currently managed by the Malheur National Forest. 

Aminopyralid (also known by the trade name: Milestone TM ) was not available during the analysis process 

for the R6 2005 FEIS. The risk assessment completed in 2007 (table 8) indicates that this herbicide will 

increase treatment effectiveness and decrease risk of adverse effects as compared to other herbicides 

authorized in the R6 2005 ROD. Thus, we propose to add aminopyralid to the list of approved ingredients in

invasive plant standard 16 for the Forest (LRMP amendment). All other standards and guidelines for invasive 

plant management would remain the same (see chapter 1).

U.S. EPA (2005) has concluded that the use of aminopyralid as a replacement for other herbicides will 

decrease risk to some non-target species:

Aminopyralid is a Reduced Risk herbicide that provides reliable control of a broad spectrum of 

difficult-to control noxious weeds and invasive plants on rangeland and pastures, rights-of-way, and 

wildlife habitat areas. Aminopyralid is particularly effective for the control of tropical soda apple, 

musk thistle, Canada thistle, spotted knapweed, diffuse knapweed, yellow starthistle and Russian 

knapweed. Aminopyralid has a favorable human health toxicity profile when compared to the 

registered alternatives for these use sites and will be applied at a lower rate. Its residual action should 

alleviate the need for repeat applications, resulting in a reduction in the amount of herbicides applied 

to the environment for the control of these weeds. Aminopyralid has been determined to be practically 

non-toxic to non-target animals at the registered application rates, compared to the alternatives, and is 

less likely to impact both terrestrial and aquatic plants.

Currently Standard 16 reads: 

Select from herbicide formulations containing one or more of the following 10 active ingredients: 

chlorsulfuron, clopyralid, glyphosate, imazapic, imazapyr, metsulfuron methyl, picloram, sethoxydim, 

sulfometuron methyl, and triclopyr...Additional herbicides and herbicide mixtures may be added in 

the future at either the Malheur National Forest LRMP or project level through appropriate risk 

analysis and NEPA/ESA procedures.

We propose to amend Standard 16 to read: 

Select from herbicide formulations containing one or more of the following 11 active ingredients: 

aminopyralid, chlorsulfuron, clopyralid, glyphosate, imazapic, imazapyr, metsulfuron methyl, 

picloram, sethoxydim, sulfometuron methyl, and triclopyr...Additional herbicides and herbicide 

mixtures may be added in the future at either the Malheur National Forest LRMP or project level 

through appropriate risk analysis and NEPA/ESA procedures.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Invasive Plant Treatment Methods Authorized Under Alternative B

The following description summarizes important information about the treatment methods that are proposed 

for alternative B.

Table 5. Proposed treatment methods descriptions

Treatment Method Description

Manual

Includes hand pulling or using hand tools (e.g., grubbing), to remove plants or cut off seed 

heads. Other manual methods could include hot water steaming and solarization techniques,

such as using black plastic to cover invasive plants to shade out and kill pieces of roots (i.e.,

rhizomes). These techniques could be used where minimizing herbicide use is desirable, such 

as streambanks or near sensitive plant populations.

Mechanical

Mechanical methods use power tools and include such actions as mowing, weed whipping, road 

brushing, and root tilling. These activities would typically occur along roadsides, rock sources, or 

other confined disturbed areas and dispersed use areas.

Biological Agents

Biological agents are parasitic insects, mites, nematodes, and pathogens that feed on specific 

parts of invasive plants and inhibit their growth and spread. In some situations, a suite of 

biological control agents is needed to reduce weed density to a desirable level. For instance, a 

mixture of five or more biological control agents may be needed to attack flower or seed heads, 

foliage, stems, crowns and roots all at the same time or during the plant’s life cycle. Typically, 15 

to 20 years are needed to suppress or contain an established population of invasive plants. 

Agents approved by the Animal and Plant Health Inspection Service (APHIS) that are proven 

natural control agents of specific invasive species but do not harm other species may be 

released.

Cultural Methods/

Restoration11

Cultural controls are defined in the R6 2005 FEIS as: “The establishment or maintenance of 

competitive vegetation, use of fertilizing, mulching, prescribed burning, or grazing animals to 

control or eliminate invasive plants” (page 10). In this project, the following cultural treatments 

are not included: livestock grazing, burning, tilling, plowing, and mechanical seed drilling. 

Mulching, seeding, planting would be used to encourage native plant survival and reestablishment, speed reoccupation of a site by native vegetation, and provide erosion protection. 

Restoration of native plant communities through mulching, seeding or planting would be likely to 

occur as a follow up to invasive plant treatment in areas where passive restoration is not 

sufficient. This will be determined as a part of each treatment prescription. The 1,281 acres that 

are of a size and configuration to potentially warrant broadcast spraying are assumed to need 

some sort of restoration in this analysis. Please note that passive restoration could be sufficient 

in many of these areas, or restoration could be needed elsewhere.

Herbicide 

Application: General

Herbicides would be used to contain, control, and eradicate invasive plants that are not costeffectively treated by other methods. When herbicide use is proposed to occur in or near 

sensitive areas, specific design features would be used to insure that vegetation treatments do 

not have an adverse impact on non- target plants or animals. Herbicide treatments, chemical 

mixing, spill prevention, and clean up would be done in accordance with Forest Service policies, 

plans, and product label requirements.

Herbicide 

Application: 

Broadcast Spraying

Broadcast application means that herbicide is applied to a continuous population of invasive 

plants. This method is used when the weed is dense enough that it is difficult to discern 

individual plants and the area to be treated makes spot spraying impractical. Larger and denser 

infestations may require a broadcast spray. In cases where the invasive plant covers more than 

70 percent of an area that is bigger than 0.1 acre, broadcasting may be the most cost-efficient 

method. The analysis assumes all currently infested areas become 100 percent covered with 

invasive plants, which would require the full amount of herbicide to be broadcast on each acre at 

a typical rate. Using this assumption for this analysis, about 1,281 acres would meet the criteria 

for broadcast spraying under alternative B. Many project design features are proposed to avoid 

drift and other risks sometimes associated with broadcast spraying. Broadcast spraying using 

most of the 11 herbicides is not allowed near streams (with the exception of aminopyralid which 

poses little to no risk to the aquatic environment).

11 Grazing would be managed to prevent invasive plant introduction, establishment, and spread and may reduce existing 

populations. These actions would be managed under appropriate grazing management plans. Prescribed burning would 

also address prevention of the spread of invasive plants and could reduce the size of target populations. However, no 

grazing or burning is proposed for this project.

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Treatment Method Description

Herbicide

Application: Spot and 

Selective Spraying

Selective application targets individual plants. Herbicide is usually applied by hand. Spot

spraying targets clumps of plants. Herbicide is usually applied with a backpack sprayer or other 

hand pump system. Spot spraying is also done using a hose off a truck-mounted or ATVmounted tank. The analysis assumes that all currently infested areas become 100 percent 

covered with invasive plants; however, the size of these infestations would not require broadcast 

treatment. Therefore, under this scenario about 843 acres would be treated using selective or 

spot application methods.

Manual and Mechanical Treatments

Manual methods include hand pulling or using hand tools (e.g., grubbing) to remove invasive plants or cut 

off seed heads. Handsaws, axes, shovel, rakes, machetes, grubbing hoes, mattocks, brush hooks, and hand 

clippers may all be used to manually remove invasive plants. Other manual methods could include hot water 

steaming or solarization techniques, such as using black plastic to cover invasive plants to shade out and kill 

pieces of roots (i.e., rhizomes). Manual methods could be used in combination with herbicide methods or 

alone in areas where herbicide use is restricted, such as near sensitive plant populations or surface waters. 

Mechanical methods use power tools and include such actions as mowing, weed whipping, road brushing, 

and root tilling. These activities would typically occur along roadsides, rock sources, or other confined 

disturbed areas and dispersed use areas. Mowing and cutting would be used to reduce or remove above 

ground biomass. Seed heads and cut fragments of species capable of re-sprouting from stem, leaf, or root 

segments would be collected and properly discarded to prevent spreading into non-infested areas.

Cultural Methods/Restoration

Cultural controls are defined in the R6 2005 FEIS as: “The establishment or maintenance of competitive 

vegetation, use of fertilizing, mulching, prescribed burning, or grazing animals to control or eliminate 

invasive plants” (p.10). In this project, the following cultural treatments are not included: livestock grazing,

burning, tilling, plowing, and mechanical seed drilling. 

Restoration and competitive plantings of native flora are essential to long-term control of invasive plants. 

Passive restoration can be accomplished in some areas by removing competition from invasive plants and 

allowing native flora to occupy a site. Other areas would require active restoration, which would include 

mulching, competitive seeding, or planting desirable vegetation. Meadows and forested areas are most likely 

to respond favorably to passive restoration, while roadsides and other highly disturbed areas may require 

active restoration. Passive restoration may include keeping cattle away from treated areas until the area has 

recovered and contains desirable vegetation.

Active restoration (mulching, seeding, and planting) would be used to encourage native plant survival and reestablishment, speed reoccupation of a site by native vegetation, and provide erosion protection. Active 

restoration of native plant communities would likely occur as a follow-up to invasive plant treatment in areas 

where passive restoration is not sufficient. This will be determined as a part of each treatment prescription. 

The intent is to re-establish desirable native vegetation post-treatment to promote resilient habitat conditions 

that are less susceptible to invasive plants.

Recovery of native vegetation after invasive plant treatment cannot be precisely predicted. Restoration would 

be considered following repeated herbicide and other treatment methods, especially in highly disturbed areas 

where native vegetation recovery may not be possible, such as campgrounds. Due to the nature of repeated 

disturbance activities in some areas on the Forest, long-term site objectives focus on containment to prevent 

future spread into other areas of the Forest rather than full restoration to native vegetation.

Appendix M of the R6 2005 FEIS emphasizes the role of competitive seeding in restoration:

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Plan ahead for revegetation. First assess the need for revegetation. It may not always be necessary if a 

healthy native population is already in place. Not every inch of bare ground needs to be revegetated. If 

revegetation is needed, make sure you have materials available to seed or plant treated sites as soon 

after treatment as possible...The planting of competitive desirable species can sometimes be the most 

effective method of control available for an invasive species.

The Malheur National Forest LRMP (as amended by the R6 2005 ROD) Invasive Plant Standard 13 (table 1) 

requires that native species be the first choice for revegetation. No noxious weed or invasive plant species 

would be used for revegetation. A combination of native and desirable non-natives could be an initial mix for 

revegetation. A fast-growing desirable non-native, such as sterile wheatgrass can germinate quickly and start 

filling in bare ground until a slower to germinate native species can start competing effectively.

Evaluation for site restoration will occur before, during, and after herbicide or manual and mechanical 

treatments. Passive site restoration would be favored in areas having a stable, diverse, native plant 

community and sufficient organics in the soil to sustain natural revegetation. If the soils lack sufficient 

organics, mulch, or soil, microbe inoculum from nearby areas could be added. Deep-rooted shrubs may also 

be seeded or planted to more fully utilize resources from the lower soil profile, especially late in the growing 

season. Shrubs allow for easier establishment of understory species by increasing water availability and 

reducing understory temperatures and soil evaporation loss.

The degree of disturbance, as indicated by the proportion of the existing plant cover that consists of desirable 

native species, will also affect revegetation outcome. Ten to 20 percent native cover is considered a minimum 

required to facilitate natural recovery of a site (James 1992, Sheley et al. 1996, Goodwin and Sheley 2003). 

The diversity, abundance, and viability of plant propagules of desirable species in the seed bank or within the 

immediate vicinity are additional important determinants in natural recruitment and recovery. 

The Guidelines for Revegetation of Invasive Plant Sites and Other Disturbed Areas on National Forests and 

Grasslands in the Pacific Northwest (Erickson et al. 2003) provides methods and guidelines for revegetation 

of invasive plant sites and disturbed areas. Steps are outlined for assessing existing and potential site 

conditions, and for developing long-term revegetation strategies that are effective, affordable, and consistent 

with the ecological context and land management objectives of the site and surrounding landscape. This 

document promotes the use of local native plant materials to establish competitive plant cover and meet the 

long-term objective to restore ecosystem functions.

For this project, active restoration is assumed to be a connected action as needed. We estimate that the 1,281 

acres of a size and configuration that might require broadcasting would be the most likely places active 

restoration could be needed.

Biocontrol Agents

The following table lists biological control agents that would be redistributed as needed to suppress or 

contain larger infestations on the Forest. These agents may be used in combination with other treatment 

methods. 

These agents meet Standard 14 of the R6 2005 ROD (Malheur National Forest LRMP), which requires that

biological agents be approved by USDA Animal and Plant Health Inspection Service (APHIS) and the state 

of Oregon. Agents demonstrated to have direct negative impacts on non-target organisms would not be 

released. The R6 Regional Office updates the list, which may allow new agents to be used in the future. 

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Table 6. Biological Control Agents Proposed for Redistribution 

Target Species Agent Mode of Action

Bull Thistle Urophora stylata Larvae form a hard multi-chambered gall in the flower 

receptacle that interferes with seed production.

Canada Thistle Ceutorhunchus litura Larvae mine pith in stems of flowering plants, increasing 

susceptibility to pathogens. Adults feed on leaves.

Canada Thistle Urophora cardui Larvae cause galls on the stems that act as nutrient sinks, 

stressing plants and reducing seed production and growth.

Dalmatian Toadflax Mecinus janthinus Larvae are stem miners; adults can cause damage to 

flowers and young leaves.

Dalmatian Toadflax Gymnetron linariae

Larvae cause galls in the roots, which may act as nutrient

sinks and reduce plant vigor. Adults may cause minor 

damage by feeding on flowers.

Diffuse Knapweed

Spotted Knapweed

Meadow Knapweed

Urophora affinis

Urophora quadrifasciata

Larvae overwinter in the seed heads. Developing larvae 

cause the plant to form a gall around the reproductive parts 

and create a metabolic sink, drawing nutrients from the 

plant that extend beyond the attacked seed head.

Leafy Spurge

Aphthona cyparissiae, 

Aphthona flava, 

Apthona nigriscutis,

Aphthona czwalinae,

Apthona lacertosa

Adults feed on foliage reducing the plant’s production of 

sugars; larvae feed on root hairs and young roots reducing 

the plant’s ability to take up water and nutrients.

Leafy Spurge Oberea erythrocephala Larvae bore in the stems and roots of larger plants. Adults 

girdle the top of the stalk before laying eggs in the stem.

Mediterranean Sage Phrydiuchus tau Adults feed on the leaves, and larvae feed in the root crown 

and petioles of large leaves.

Musk Thistle Urophora solstitialis Larvae cause galls in the seed heads that interfere with 

seed production and dissemination.

Spotted Knapweed

Diffuse Knapweed Cyphocleonus achates Larvae are root borers and adults feed on the leaves

Spotted Knapweed

Diffuse Knapweed Terellia virens The larvae feed on seeds in the flower head.

Spotted Knapweed

Meadow Knapweed

Diffuse Knapweed

Larinus obtusus Larvae consume the seeds and adults can defoliate plants 

when in large numbers.

Spotted Knapweed, 

Diffuse Knapweed Larinus minutus

Larvae feed in the flower head destroying most of the 

seeds. Heavy attack by adults can stunt or kill plants and 

delay flowering. 

St Johnswort Chrysolina quadrigemina

Chrysolina hyperici Adults and larvae are foliage feeders.

Yellow Starthistle Chaetorellia australis Larvae tunnel into the center of the head, where they feed 

on the ovaries and developing seeds.

Yellow Starthistle Eustenopus villosus Adults feed on developing buds, causing the buds to die.

Larvae feed on the seed head and developing seeds.

Yellow Starthistle Larinus curtus Adults feed on the flowers and larvae feed on the seed 

head, reducing seed production.

Yellow Toadflax Gymnetron antirrhini

Adult weevils emerge in late spring or early summer and 

feed primarily on young toadflax shoots and buds. Larvae 

hatch from eggs and feed on seeds.

Herbicide Use

Of the eleven herbicides considered for use, the first choice herbicides are most likely to be used. The 

herbicides picloram, sethoxydim, sulfometuron methyl and triclopyr are the least likely to be used. Table 7 

shows the currently mapped acres that could be effectively treated using the first choice herbicides. 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Broadcast is assumed to be needed on larger infestations, however. Many of the infested areas are sparsely 

covered with invasive plants and where effective, spot or hand treatments would be used.

Table 7. Summary of herbicide use under alternative B

First Year/First Choice Activity Acres Assuming 100 Percent Coverage 

with Invasive Plants

Potential Broadcast Herbicide

Aminopyralid 1,180

Chlorsulfuron 71

Metsulfuron methyl 30

Total Potential Broadcast Application Method 1,281

Potential Spot/Selective Herbicide 

Aminopyralid 168

Chlorsulfuron 519

Metsulfuron methyl 156

Total Potential Spot/Selective 843

The following table shows, for each herbicide, the active ingredient, the SERA risk assessment reference, the 

typical and maximum label rates, and some remarks about the herbicide. Maximum application rates may be 

used if necessary in small areas, but in general, spot and broadcast treatments will use typical or lower 

application rates. The SERA risk assessment reference and year is also given. 

Adjuvants are compounds added to the formulation to improve performance. They can either enhance the 

activity of an herbicide’s active ingredient (activator adjuvant) or offset any problems associated with its 

application (special purpose or utility modifiers). Surfactants are one type of adjuvant that makes the 

herbicide more effective by increasing absorption into the plant. Many of the inert ingredients are proprietary 

in nature and have not been tested on laboratory species. However, confidential business information (i.e.,

the identity of proprietary ingredients) was considered in the preparation of the herbicide risk assessments

completed prior to 2004. Additional information about surfactants is in appendix C.

Inert compounds are those that are intentionally added to a formulation, but have no herbicidal activity and 

do not affect the herbicidal activity. Inerts are added to the formulation to facilitate its handling, stability, or 

mixing. Impurities are inadvertent contaminants in the herbicide, usually present as a result of the 

manufacturing process. The risk assessments describe the impurities and their risks: in this project, 

hexachlorobenzene is a contaminant from manufacturing picloram and clopyralid and is factored into the 

toxicity analysis for these chemicals. 

The following table describes the herbicides authorized for use on the Forest. Most of these herbicides are 

not proposed for use during the first year of treatment for target species currently mapped on the Forest, but 

could be used depending on ongoing field experience and new scientific information, juxtaposition of target 

species, potential for herbicide resistance, and cost. Additional information on herbicide toxicity is in chapter 

3. 

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Table 8. Herbicide descriptions, risk assessment reference, and application rates#

Active 

Ingredient

Risk Assessment Year and 

Reference

Risk 

Assessment 

Typical 

Application 

Rate 

(lb. per ac)*

Highest 

Application 

Rate 

(lb. per ac)

Remarks

Aminopyralid 2007 – SERA TR-052-04-04a 0.078 0.11

This herbicide poses a very low risk to the aquatic environments. We will 

avoid ground water contamination as per label instructions. Aquatic 

formulations are not currently available, but we can use this herbicide up to 

the water’s edge in most situations. Milestone TM does not contain any inert 

ingredients or additives other than water. It is the first-choice herbicide for 

about 64% of the currently infested acres (about 1,346 acres). 

Chlorsulfuron 2004 – SERA TR 04-43-18-01c 0.056 Oregon label 

0.13

This herbicide poses a moderate risk to the aquatic environments and there 

are no aquatic formulations. We will not use this herbicide next to streams or 

on certain soils or near certain non-target plants as per project design 

features. It is the first-choice herbicide for about 28% of the currently infested 

acreage (about 591 acres).

Clopyralid 2004 – SERA TR 04 43-17-03c 0.35 0.5

This herbicide poses a low risk to aquatic environments. We will implement 

some soil restrictions due to its increased mobility in some soil types, and we 

will avoid ground water contamination as per label instructions. It is one of the 

most target-species selective herbicides proposed for use.

Glyphosate 2011 – SERA_TR-052-22-03b 2 8+

This is one of the most common herbicides used in Oregon and has the 

advantage of being effective on a very wide range of target species. 

Formulations of glyphosate have ingredients that may pose higher risk to 

aquatic environments would not be used. It is non-selective and quickly taken 

up by target plants. Some people have expressed concern about “Roundup®

” 

or “”Roundup Ready® GMO crops” and the effect on human health. However, 

the studies that underpin the concerns are not applicable to the proposed 

project 1) they are based on formulations that are not available in the United 

States, 2) rates are often much larger than proposed for this project, and 3) 

the use of glyphosate in this project would be limited to direct application to 

scattered invasive plants that are not used as crops.

Imazapic 2004 – SERA TR 04-43-17-04b 0.13 0.19

This herbicide poses a low risk to aquatic environments and there is no 

aquatic formulation. This herbicide is associated with a concern for non-target 

plants, and we will protect botanical species of conservation concern.

Imazapyr 2004 – SERA TR 04-43-17-05b

2011 – SERA TR-052-29-03a 

0.45 0.7 (on this 

project as per 

pdfs)

This herbicide poses a moderate risk to aquatic environments. An aquatic 

formulation is available. This herbicide is also associated with a concern for 

non-target plants, and we will buffer botanical species of conservation 

concern.

46
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Active 

Ingredient

Risk Assessment Year and 

Reference

Risk 

Assessment 

Typical 

Application 

Rate 

(lb. per ac)*

Highest 

Application 

Rate 

(lb. per ac)

Remarks

Metsulfuron 

Methyl 2003 – SERA TR 04-43-17-01b 0.03 0.075

This herbicide poses a moderate risk to aquatic environments, and no aquatic 

formulations are available. We will buffer streams when using this herbicide.

This herbicide is also associated with a concern for non-target plants and we 

will protect botanical species of conservation concern. It is the first-choice

herbicide for about 8% of the currently infested acreage (about 186 acres).

Picloram 2003 – SERA TR 03-43-16-01b 

2011 – SERA TR-052-27-03a 0.35 1.0

This herbicide poses higher risk to aquatic environments, and there is no 

aquatic label. We will not use this herbicide near streams, especially because 

it is toxic to certain aquatic species and it can be very mobile. It is valued for 

its persistence in the soil; we will not use it on certain soils, and we will use it 

infrequently to protect soil biology.

Sethoxydim 2001 – SERA TR 01-43-01-01c 0.3 0.47

This herbicide poses a moderate risk to aquatic environments, and there is no 

aquatic label. We will not use it near streams. It is very selective (only kills 

grasses). 

Sulfometuron 

Methyl 2004 – SERA TR 03-43-17-02c 0.045 0.38

This herbicide poses a low risk to aquatic environments, and no aquatic 

formulations are available. We will buffer streams when using this herbicide.

This herbicide is also associated with a concern for non-target plants, and we 

will protect botanical species of conservation concern.

Triclopyr 2003 – SERA TR 02-43-13-03b

2011- SERA TR 052-25-03a 1.0 6 (Oregon 

label)

This herbicide poses higher risk to aquatic environments; however, there is 

an aquatic label that reduces (but does not eliminate) the risk. We will not use 

this herbicide near streams. This herbicide poses some risk to herbicide 

applicators and will not be broadcast as per R6 2005 ROD Standard 16. It 

may only be spot or selectively applied and only in limited cases. 

#

Application rates vary by site and target plant – these application rates are for analysis purposes.

* Pounds of active ingredient per acre; if weak acid, numbers are in acid equivalents/acre

+ Limited to maximum of 3.75 lb. per application in the PNW for Aquamaster®, and less than 8 lbs./year

47
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Integrated Treatment Prescriptions (Common Control Measures) For 18 Primary Target 

Species

The following table lists the 18 primary target species currently mapped on the Forest; common and 

scientific names, (scientific code), and growth habit; first-choice and other herbicides known to be 

effective on each species (or group of species) and detailed integrated prescription notes. The order 

species are presented is for the convenience of display and no other meaning should be ascribed. The 

order of other effective herbicides is alphabetical and no other meaning should be ascribed. 

We propose to apply aminopyralid to about 64 percent of the infested acreage for the first treatment entry 

(about 1,350 acres) and chlorsulfuron for the first treatment entry on 28 percent of the acres (about 591 

acres), and metsulfuron methyl for one target species: sulphur cinquefoil that covers an estimated 8 

percent of the acres (about 186 acres). We may use other effective herbicides in future re-treatments 

depending on the effectiveness of the first-choice herbicide. 

Table 9. Common control measures for alternative B

Primary Target Species

First-Choice 

Followed by 

Other Effective 

Herbicides12

Integrated Treatment Notes

Yellow star-thistle

Centaurea solstitialis

(CESO3)

Annual

aminopyralid

clopyralid

glyphosate

picloram

Early detection and treatment increase the chances of control. 

Treatment of small infestations in otherwise healthy sites should be a 

priority.

Biological control agents are available. 

Hand pull when soil is moist and remove all roots and flower and 

seed heads.

Common St. Johnswort

Hypericum perforatum

(HYPE)

Perennial with stolons 

and rhizomes

aminopyralid

glyphosate

metsulfuron 

methyl

picloram

Biological agents are available. 

Small infestations may be controlled by pulling or digging. Repeated 

treatments will be necessary because lateral roots can give rise to 

new plants. Bag and remove all plant parts from site.

Russian knapweed

Acroptilon repens

(ACRE3)

Long-lived creeping 

perennial

aminopyralid

chlorsulfuron

clopyralid

glyphosate

imazapyr

metsulfuron 

methyl

picloram

Hand pulling is effective only in the establishment year. 

Reproduces mainly by vegetative propagation from buds on creeping 

roots.

Biocontrol agents being developed.

Cutting or mowing several times per year will control top growth and 

seed production; re-emerging plants will have less vigor.

Lasting control requires an integrated approach; using mechanical or 

cultural measures with herbicide application, especially in late fall, is 

most effective.

Small, isolated infestations should be eradicated first. Then larger 

infestations should be controlled from the perimeter and eradicated 

when possible.

12 Targe species order does not reflect treatment priority. First choice herbicide is listed in bold followed by other 

effective herbicides in alphabetical order.

48

 
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Primary Target Species

First-Choice 

Followed by 

Other Effective 

Herbicides12

Integrated Treatment Notes

Spotted knapweed

Centaurea stoebe ssp. 

Micranthos

(CESTM)

Taprooted perennial

aminopyralid

clopyralid

glyphosate

triclopyr

picloram

Treatment would focus on reducing seed production and preventing 

germination.

Biological agents are available.

Repeated manual pulling and digging may eliminate small 

infestations (2-4 times per year for multiple years). Pull prior to seed 

set. Bag and remove flower and seed heads.

Diffuse knapweed

Centaurea diffusa

(CEDI3)

Short-lived perennial, 

biennial or annual. Often 

with a long, stout taproot

Squarrose knapweed

Centaurea virgate ssp. 

Squarrosa

(CEVIS2)

Taprooted perennial

Meadow knapweed

Centaurea jacea sensu 

lato

(CEJA)

Taprooted perennial

Canada thistle

Cirsium arvense

(CIAR4)

Rhizomatous perennial

aminopyralid

chlorsulfuron

clopyralid

picloram

Combining mechanical, cultural, biological, and chemical methods is 

best for effective control.

Biological agents are available, but use may affect native thistles. 

Mowing, cutting or pulling can be an effective control if repeated at 

about 1-month intervals throughout the growing season for several 

years. Combining mowing/cutting with herbicides (in the fall) will 

further enhance control of Canada thistle. Covering with plastic tarp 

(solarization) may be effective for small infestations.

Bull thistle*

Cirsium vulgare

(CIVU)

Taprooted biennial

aminopyralid

chlorsulfuron

clopyralid

glyphosate

picloram

triclopyr

Prioritize small infestations in otherwise healthy sites. Prioritize 

prevention of establishment and eliminating plants as soon as they 

are found.

Manually pulling rosettes or cutting stems 2”-4” below the soil surface 

before flower heads develop kills plants and prevents seed 

development. Roots may be left on site to dry; all flower and seed 

heads should be removed.

Covering disturbed sites, particularly small burn areas, with fine to 

medium sized organic matter may prevent or reduce the size of 

infestations. Please note, this was described as the “Canada thistle 

strategy” in the DEIS.

Scotch Thistle

Onopordum acanthium

(ONAC)

Taprooted biennial or 

short-lived perennial

49
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Primary Target Species

First-Choice 

Followed by 

Other Effective 

Herbicides12

Integrated Treatment Notes

Musk thistle

Carduus nutans

(CANU4)

Taprooted biennial or 

occasional annual

Leafy spurge

Euphorbia esula

(EUES)

Rhizomatous perennial

aminopyralid

glyphosate

imazapic

picloram

Early detection and rapid eradication is important since plant spreads 

rapidly by seeds and rhizomes. Continuous aggressive management 

is necessary to keep infestations under control (5 – 10 years). 

Prioritizing treatment of small infestations, then treating large 

infestations from the outside edges is most effective. 

Biological control agents may reduce aboveground stems but do not 

kill root systems. 

Mechanical, cultural, or herbicide methods alone are rarely effective. 

Combinations of several herbicide treatments and planting grass 

seed may provide the best chance of controlling the species. Hand 

pulling and grubbing are not effective because of the extensive root 

system. Cutting and mowing reduce seed production and the plant’s 

competitive ability. Covering with weed cloth, plastic, or thick mulch 

may kill plants. Site can then be planted with native seed. If manual 

methods are used all plant parts should be bagged and removed 

since new plants may form from roots and rhizomes as well as from 

seeds. Plant’s milky sap may be irritating to skin, eyes, and digestive 

tract of humans and other animals.

Houndstongue

Cynoglossum officinale

(CYOF)

Taprooted biennial or 

short-lived perennial

chlorsulfuron

imazapic

metsulfuron 

methyl

Mowing/cutting second year plants during flowering, but before seed 

maturation reduces seed production and may kill the plant. 

Pulling plants or cutting 1-2” below the soil surface have the best 

chance of eliminating plants. Cutting produces less ground 

disturbance than pulling. Bag and remove all flower and seed heads.

Dalmatian toadflax

Linaria dalmatica

(LIDA)

Perennial with taproot 

and extensive system of 

lateral roots

chlorsulfuron

imazapic

metsulfuron 

methyl

picloram

Dalmatian toadflax reproduces primarily by seed and partly by 

adventitious root buds. Yellow toadflax reproduces primarily by 

adventitious root buds on lateral roots.

Biological agents are available and may be very effective. If 

biocontrol agents continue to be effective, herbicide application may 

not be needed.

Manual pulling and digging may not be effective because of the deep 

(4-10 feet) and laterally extensive root systems (to 10 feet from 

plant). If manually removed, all roots and flower and seed heads 

should be bagged and removed. Cutting stems in spring or early 

summer would eliminate seed production, but not the root system.

Yellow toadflax

Linaria vulgare

(LIVU2)

Perennial with taproot 

and extensive system of 

vertical and creeping 

lateral roots

50
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Primary Target Species

First-Choice 

Followed by 

Other Effective 

Herbicides12

Integrated Treatment Notes

Whitetop

Cardaria draba

(CADR)

Rhizomatous perennial

chlorsulfuron

imazapic

imazapyr

glyphosate

metsulfuron 

methyl

These species are difficult to control because of their deep taproots 

(9 ft.) and ability to sprout from root fragments. Early detection and 

proactive management is most effective since established 

infestations are difficult to control. Frequent monitoring for new sites 

and prioritizing small infestations in otherwise healthy sites is 

important. Next priority would be for corridors, such as waterways 

and irrigations structures that have a high likelihood of spread.

Biological controls are not available.

Repeated pulling may control small, young infestations. Established 

plants are likely to resprout from deep roots. All roots and flower and 

seed heads should be removed. Mowing does not eliminate plants 

but removes thatch.

Perennial pepperweed

Lepidium latifolium

(LELA2)

Perennial with rhizome 

like creeping roots

Sulphur cinquefoil

Potentilla recta

(PORE5)

Taprooted perennial that 

may have several 

shallow, spreading 

branch roots but not 

rhizomes

metsulfuron 

methyl

glyphosate

picloram

triclopyr

Cultural treatments, such as seeding of native plants may be 

effective.

There are no approved biocontrols.

Small infestations may be controlled by hand digging if the entire root 

crown is removed.

For large infestations, selective herbicides are likely the only method 

of effective control (TNC 2004).

Repeated treatments are needed for the first couple of years to 

ensure re-establishment does not occur.

*Bull thistle and Canada thistle were cataloged together in our November 2012 invasive plant inventory. However, the precise 

species would be identified before an integrated treatment prescription would be applied.

Project Design Features

The following project design features (pdfs) minimize the potential negative effects of invasive plant 

treatment. These pdfs provide sideboards for treatment of known sites and species and new detections. 

The pdfs were developed to respond to the site-specific resource conditions within the infested areas, 

including (but not limited to) botanical areas; habitat and presence of botanical, wildlife, and/or fish 

species of conservation concern; the potential for herbicide delivery to water; and proximity to other areas 

of interest (roads and trails, recreation sites, Wilderness/Wild and Scenic Rivers, wildland fire areas). 

Implementation of the pdfs would be mandatory. The analysis assumes pdfs are properly implemented. 

The herbicide-use buffers apply horizontal (map) distances. The pdfs and herbicide-use buffers address

Best Management Practices Guidelines for Chemical Uses on National Forests (USDA Forest Service

2012). The project design features associated with alternative B are summarized in the following table.

Table 10. Project Design Features

PDF 

Reference Design Features Purpose of PDF Source of PDF

B – Coordination with Other Landowners/Agencies

B1

Coordinate treatments on neighboring lands 

and within municipal watersheds. For 

neighboring lands, base distances on invasive 

species reproductive characteristics, and 

current use. 

To ensure that neighbors 

are fully informed about 

nearby herbicide use and to 

increase the effectiveness of 

treatments on multiple 

ownerships. 

A variable distance 

based on site and 

species specific 

characteristics was 

chosen because it 

adjusts for various 

conditions that exist in 

these areas. All pdfs

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

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Reference Design Features Purpose of PDF Source of PDF

related to riparian 

areas and buffer 

distances will be 

followed.

C – To Prevent the Spread of Invasive Plants During Treatment Activities

C1

Ensure vehicles and equipment (including 

personal protective clothing) does not 

transport invasive plant materials. 

To prevent the spread of 

invasive plants during 

treatment activities

Common measure.

D – Wilderness Areas 13

D1

No use of black plastic for solarization, no use 

of motor vehicles or other mechanical 

transport for access, and no motorized 

equipment will be used in wilderness areas. 

Manual treatments or those using nonmotorized tools may occur. Herbicide use 

would be approved by the Regional Forester 

via a pesticide use proposal.

To maintain wilderness 

values, e.g., solitude, 

unimpeded natural 

processes—and comply with 

environmental laws and 

policies.

Wilderness Act, 1990 

Malheur National 

LRMP

E – Non-herbicide Treatment Methods

E1

Treatments implemented below the ordinary 

high water mark will be applied from the bank 

and workers will not walk in flowing streams 

regardless of treatment method. 

To reduce the likelihood of 

causing negative impacts to 

fish and fish habitat.

Memorandum of 

Understanding 

between WDFW and 

USDA Forest Service, 

January 2005. 

E2

Fueling of gas-powered equipment with tanks 

larger than 5 gallons would generally not occur 

within 150 feet of surface waters. Fueling of 

gas-powered machines with tanks smaller than 

5 gallons may occur up to 25 feet of surface 

waters.

To protect riparian and 

aquatic habitats. Common measure

E3

Within 15 feet of waterbodies, disturbed soils 

will be tamped down and covered with 

litter/mulch where available.

To reduce sediment entering 

aquatic habitats.

ESA Consultation with 

NMFS and FWS

F – Herbicide Applications

F1

Alkylphenol ethoxylate-based non-ionic (NPE)

and ethoxylated fatty amine (POEA)

surfactants would not be used. Vegetable 

oils/silicone blends that contain alkylphenol 

ethoxylate ingredients may be used. 

To reduce risks associated 

with surfactants 

SERA and Bakke risk 

assessments

F2

The least amount of a given herbicide would 

be applied as necessary to meet control 

objectives. 

In no case will imazapyr use exceed 0.70 lbs. 

a.i./ac. Broadcast application of clopyralid, 

glyphosate, picloram, sethoxydim, or 

sulfometuron methyl will not exceed typical 

rates across any acre. Spot spray of triclopyr 

would not exceed typical rates across any 

acre. 

To minimize herbicide 

exposures of concern to 

human health.

SERA and Bakke risk 

assessments

F3

Do not apply herbicides when local weather 

forecast calls for a ≥ 50% chance of rain, or 

when wind speed at the site is less than 2 mph 

or in excess of 8 mph. During application, 

To reduce potential for drift

and run off. 

These restrictions are 

typical so that 

herbicide use is 

avoided during 

13 Invasive plant eradication within Wilderness meets the “no impact” intent of the Wilderness Act and associated 

land use policies. 

52

 
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

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Reference Design Features Purpose of PDF Source of PDF

weather conditions would be monitored 

periodically by trained personnel. Herbicide 

application would cease during periods of 

unexpected rain.

inversions or windy 

conditions. 

F4

To minimize herbicide drift, use low nozzle 

pressure; apply as a coarse spray, and use 

nozzles that minimize fine droplet spray, e.g., 

nozzle diameter to produce a median droplet 

diameter of 500-800 microns. 

To reduce potential for drift. 

These are typical 

measures to reduce 

drift. The minimum 

droplet size of 500 

microns was selected 

because this size is 

modeled to eliminate 

adverse effects to 

non-target vegetation 

100 feet or further 

from broadcast sites 

(see chapter 3 for 

details).

F5

No use of sulfonylurea herbicides 

(chlorsulfuron, sulfometuron methyl and 

metsulfuron methyl) on dust-laden bare soils.

Avoid bare areas >100 sq. ft. with powdery, 

ashy dry soil, or light sandy soil.

To avoid potential for 

herbicide drift to affect nontarget plants.Label advisory

F6 When herbicides are applied, a non-toxic blue

dye will be used to mark treated areas. 

To ensure treated areas are 

obvious to people and 

prevent accidental ingestion 

by plant collectors.

Common measure

F7

Annually review any changes to herbicide 

regulations nationally, regionally, and locally, 

based on labels and tools such as Salmon 

Mapper (http://www2.epa.gov/endangeredspecies/salmon-mapper).

To ensure herbicide use is in 

accordance with all future 

limitations.

ESA Consultation with 

NMFS and FWS

G – Herbicide Transportation and Handling Safety/Spill Prevention and Containment

An Herbicide Transportation and Handling Safety/Spill 

Response Plan would be the responsibility of the herbicide 

applicator. At a minimum the plan would:

 Address spill prevention and containment.

 Limit the quantity of herbicides transported to treatment 

sites to the amounts estimated to be needed for any 

given day.

 Require that impervious material be placed beneath 

mixing areas in such a manner as to contain small spills 

associated with mixing/refilling.

 Require a spill cleanup kit be readily available for 

herbicide transportation, storage, and application 

(minimum FOSS Spill Tote Universal or equivalent).

 Outline reporting procedures, including reporting spills 

to the appropriate regulatory agency.

 Ensure applicators are trained in safe handling and 

transportation procedures and spill cleanup.

 Require that equipment used in herbicide storage, 

transportation, and handling are maintained in a leak 

proof condition.

 Address transportation routes so that traffic, domestic 

water sources, and blind curves are avoided to the 

extent possible.

 Specify conditions under which guide vehicles would be 

To reduce likelihood of spills 

and contain any spills. FSH 2109.14

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

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Reference Design Features Purpose of PDF Source of PDF

required.

 Specify mixing and loading locations away from water 

bodies so that accidental spills do not contaminate 

surface waters.

 Require that spray tanks be mixed or washed further 

than 150 feet of surface water.

 Ensure safe disposal of herbicide containers.

 Identify sites that may only be reached by water travel 

and limit the amount of herbicide that may be 

transported by watercraft.

H – Soils, Water and Aquatic Ecosystems

H1

Follow herbicide-use buffers shown below. 

Tank mixtures would apply the largest buffer 

as indicated for any of the herbicides in the 

mixture. 

To reduce likelihood that 

herbicides would enter 

surface waters in 

concentrations of concern

and ensure that the project 

does not hamper attainment 

of riparian management 

objectives. 

Herbicide-use buffers 

are based on label 

advisories; SERA risk 

assessments; and 

Berg’s 2004 study of 

broadcast drift and 

run off to streams. 

Herbicide-use buffers

are intended to 

demonstrate 

compliance with R6 

2005 ROD Standards 

19 and 20.

H2

In riparian and aquatic settings, vehicles 

(including all-terrain vehicles) used to access 

invasive plant sites, or for broadcast spraying 

will not travel off roadways, trails, and parking 

areas if damage to riparian vegetation, soil,

and water quality, and aquatic habitat is likely.

To protect riparian and 

aquatic habitats.

Common protection 

measure

H3

Avoid using picloram and/or metsulfuron

methyl on bare or compact soils, and 

inherently poor productivity soils that are highly 

disturbed. Poor soils include shallow soils less 

than 20 inch depth that lack topsoil and 

serpentine soils.

To preserve site recovery 

after disturbance, lessen 

offsite runoff and leaching.

Poor soils will have longer 

residence times with these 

persistent herbicides.

Label advisory

H4

Over any two consecutive calendar years, the 

sum of all applications in an area of imazapyr, 

metsulfuron methyl, or picloram would not 

exceed the maximum application rate for a 

single broadcast spraying. Aminopyralid would 

not be broadcast more than once per year. 

Multiple spot applications are permitted as 

long as the aggregate of applications is at or 

below the broadcast application rate.

Reduce potential for 

accumulation in soil.

SERA Risk 

Assessments. Based 

on quantitative 

estimate of risk from a 

maximum level of 

exposure.

H5

Limit herbicide offsite transport on sites with 

high runoff potential including sites with:

shallow seasonal water tables, saturated soils 

(wet muck and peat soils), steep erosive 

slopes with shallow soils and rock outcrop, or

bare compacted and disturbed soils.

Limit runoff by applying herbicide during the 

dry season with the lowest soil moisture 

conditions, where > 50% groundcover exists 

on shallow slope sites, and > 70% on steep 

slope sites, and/or at reduced rates.

Reduce potential offsite 

runoff transport of 

herbicides.

SERA Risk 

Assessments and 

Label. Based on 

quantitative risk for 

erosion and runoff.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

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Reference Design Features Purpose of PDF Source of PDF

H6

For soils with seasonally high water tables, do 

not use picloram or triclopyr BEE and limit 

glyphosate use to aquatic label only.

Reduce the risk for 

contamination of 

groundwater and offsite 

runoff to aquatic habitat and 

fish.

Label advisory

H7

Do not remove more than 50 percent of the 

vegetative cover or apply herbicides to more 

than half the area within 100 feet of a lake or 

pond in a 30-day period. 

Limit the area treated within 

riparian areas to maintain

refugia habitat for reptiles 

and amphibians.

SERA Risk 

Assessments. Based 

on quantitative 

estimate of risk from 

maximum herbicide 

exposure scenario 

and uncertainty 

regarding effects to 

reptiles and 

amphibians.

H8

Wetlands would be treated when soils are 

driest. If herbicide treatment is necessary 

when soils are wet, use aquatic labeled 

herbicides. Favor hand/selective treatment 

methods where effective and practical. No 

more than 10 contiguous acres or fifty percent 

individual wetland areas would be treated in 

any 30-day period.

To reduce exposure to 

herbicides by providing 

some untreated areas for 

some organisms to use.

SERA Risk 

Assessments. Based 

on quantitative 

estimate of risk from 

maximum herbicide 

exposure scenario 

and uncertainty in 

effects to some 

organisms, and label 

advisories.

H9

Herbicide use would not occur within 100 feet 

of wells or 200 feet of spring developments.

For stock tanks located outside of riparian 

areas, use wicking, wiping or spot treatments 

within 100 feet of the watering source. 

To reduce the potential for 

herbicide delivery to wells 

and springs that provide 

drinking water, and to 

protect watering systems 

used for grazing animals.

Label advisories and 

state drinking water 

regulations

http://www.deq.state.o

r.us/wq/WhpGuide/ch

2.htm.

H10

Use of Triclopyr BEE is only allowed in dry 

upland areas that are not hydrologically 

connected to water bodies.

Reduce the risk for 

contamination of 

groundwater and offsite 

runoff to aquatic habitat and 

fish.

Label and quantitative 

assessment for risk to 

aquatic organisms.

I – Vascular and Non-Vascular Plant and Fungi Species of Concern

I1

A USDA Forest Service botanist would use 

monitoring results/adaptive management to 

refine herbicide-use buffers to adequately 

protect botanical species on the Regional 

Forester’s Sensitive List.

Minimizes repeated effects 

to sensitive botanical 

populations, thereby 

mitigating any long-term 

effects. Uncertainty about 

effects on nonvascular 

plants would be addressed 

through monitoring.

Herbicide-use buffer 

sizes for broadcast of 

most herbicides are 

based on Marrs 1989 

based on tests on 

vascular plants. Spot

and hand/select buffer 

distances are based 

on reports from 

experienced 

applicators.

I2

Botanical surveys will be conducted to 

document locations of sensitive plants if 

suitable habitat is within 100 feet of planned 

herbicide treatments

To ensure sensitive 

botanical species are 

protected and botanical 

surveys are conducted when 

appropriate

Forest Service 

Manual 2670 and 

applicable federally 

listed recovery plans

I3

Sensitive plants located within 100 feet of 

planned ground-based broadcast applications 

would be covered by protective barrier, or 

broadcast application would be avoided in 

To ensure sensitive 

botanical species are 

protected

Forest Service 

Manual 2670 and 

applicable federally 

listed recovery plans

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

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these areas (spot or hand herbicide treatment, 

or non-herbicide methods may be used without 

covering sensitive plants).

I4

hand/selective methods to treat invasive plants 

on wet soils within 10 feet of sensitive plant. 

This design feature does not apply to 

seasonally wet soils that are dry at the time of 

treatment.

To ensure sensitive 

botanical species are 

protected

Forest Service 

Manual 2670 and 

applicable federally 

listed recovery plans

I6

Monitoring prework review would occur before 

implementation to ensure that prescriptions, 

contracts, and agreements integrate 

appropriate project design features.

To ensure sensitive 

botanical species are 

protected

Forest Service 

Manual 2670 and 

applicable federally 

listed recovery plans

I7

Implementation monitoring would occur during 

implementation to ensure project design 

features are implemented as planned. An 

implementation monitoring form will be used to 

document daily field conditions, activities, 

accomplishments, and/or difficulties. Contract 

administration mechanisms would be used to 

correct deficiencies. Herbicide use will be 

reported as required by the Forest Service

Health Pesticide Use Handbook.

To ensure sensitive 

botanical species are 

protected

Forest Service 

Manual 2670 and 

applicable federally 

listed recovery plans

I8

Effectiveness monitoring would occur during 

and after treatment to determine whether 

invasive plants are being effectively controlled 

and to ensure non-target vegetation, especially 

sensitive species are adequately protected. 

To ensure sensitive 

botanical species are 

protected

Forest Service 

Manual 2670 and 

applicable federally 

listed recovery plans

I9

The impacts of herbicide use on some 

sensitive botanical species are uncertain, 

especially non-vascular species. To manage 

this uncertainty, representative samples of 

herbicide treatment sites adjacent to sensitive 

botanical species would be monitored. Nontarget vegetation within 100 feet of herbicide 

broadcast treatment sites and 20 feet of 

herbicide spot and hand treatment sites would 

be evaluated before treatment, immediately 

after treatment, and two to three months later 

as appropriate. Herbicide-use buffers would be 

expanded if damage is found as indicated by: 

•Decrease in the population of the species of 

conservation concern

•Leaf discoloration or chlorophyll change

•Mortality 

Monitoring would continue until three posttreatment visits (at one or more sites near 

each sensitive botanical species) confirm a 

lack of adverse effects.

To ensure species of listed 

interest (SOLI) are protected 

and survey are conducted 

when appropriate

Forest Service 

Manual 2670 and 

applicable federally 

listed recovery plans

J – Wildlife Species of Local Interest

J1 Gray Wolf

J1-a

Treatments within 1 mile of active wolf dens or 

rendezvous sites would only occur outside the 

season of occupancy (April 1 through June 

30).

Reduce impacts to active 

dens or rendezvous sites

Federal Register 

(USDI FWS 2003)

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J2 Bald eagle

J2-a

Noise-producing activity above ambient levels 

would not occur near known winter roosts and 

concentrated foraging areas between October 

31 and March 31 during the early morning or 

late afternoon. Disturbance to daytime winter 

foraging areas would be avoided.

Minimize disturbance and 

energy demands during the 

winter.

Bald Eagle

Management 

Guidelines for OR-WA 

(Dillon 1981); USDI 

FWS 2007, No, 62 

4(d)

J2-b

Treatment of areas within 0.25 mile, or 0.50 

mile line-of-sight, of bald eagle nests would be 

timed to occur outside the nesting/fledging 

season of January 1 to August 31, unless 

treatment activity is within ambient levels of 

noise and human presence (as determined by 

a local specialist). Occupancy of nest sites 

(i.e., whether it is active or not) would be 

determined each year prior to treatments.

Reduce impacts to eagle 

nests and reproduction.

Bald Eagle

Management 

Guidelines for OR-WA 

(Dillon 1981) and, 

USDA Forest Service

2005a

J3 Peregrine Falcon

J3-a

Seasonal restrictions shall apply to all known 

peregrine falcon nest sites for the periods and 

elevations listed below:

a. Low elevation sites (1000-2000 ft.) – Jan 1st 

to July 1st 

b. Medium elevation sites (2001-4000 ft.) –

Jan 15th to July 31st 

c. Upper elevation sites (greater than 4000 ft.) 

– Feb 1st to Aug 15th 

These restrictions may be waived if the site is 

unoccupied or if nesting efforts fail and 

monitoring indicates no further nesting 

behavior. Seasonal restrictions shall be 

extended if monitoring indicates late season 

nesting, asynchronous hatching leading to late 

fledging, or recycle behavior which indicates 

that late nesting and fledging will occur. 

Protection would be provided until at least two 

weeks after all young have fledged.

Reduce disturbance to 

nesting birds and protect 

eggs and nestlings.

Pagel 2006

Peregrine falcon nest 

site data, 1983-2006.

J3-b

All invasive plant treatments would be 

restricted within 0.5 miles of peregrine falcon 

nests (primary nest zone) during the nesting 

season (described above).

Reduce disturbance to 

nesting birds and young.

Pagel 2006

Peregrine falcon nest 

site data, 1983-2006.

J3-c

Invasive plant treatments involving motorized 

equipment and/or vehicles would be 

seasonally prohibited within the secondary 

nest zone (0.5 miles to 1.5 miles of known nest 

sites) during the nesting season. This may 

include activities such as mulching, chainsaws, 

vehicles (with or without boom spray 

equipment) or other mechanically-based 

invasive plant treatment.

Reduce disturbance to 

nesting birds and young.

Pagel 2006

Peregrine falcon nest 

site data, 1983-2006.

J3-d

Non-mechanized or low disturbance invasive 

plant activities (such as spot spray, hand pull, 

etc.) may occur within the secondary nest 

zone (0.5 miles to 1.5 miles of known nests) 

during the nesting season, but would be 

coordinated with the wildlife biologist on a 

case-by-case basis to determine potential 

Reduce disturbance to 

nesting birds and young.

Pagel 2006

Peregrine falcon nest 

site data, 1983-2006.

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disturbance to nesting falcons and identify 

mitigating measures, if necessary.

J3-e

Picloram and clopyralid would not be used 

within 1.5 miles of a peregrine nest more than 

once per year.

Minimize peregrine 

exposure to HCB

Pagel 2006

Peregrine falcon nest 

site data, 1983-2006.

J4 Greater Sage Grouse

J4-a

Glyphosate use would be limited to the typical 

application rate (within greater sage grouse 

habitat).

Minimize exposure to 

herbicides and surfactants 

that could pose a risk.

Malheur Invasive 

Plant Biological 

Evaluation.

J4-b

Human activities within 0.3 mile of leks will be 

prohibited from the period of one hour before 

sunrise until four hours after sunrise and one 

hour before sunset until one hour after sunset 

from February 15 - May 15.

Minimize disturbance to 

breeding grouse

Connelly et al. 2000, 

USDI FWS 2003.

J4-c

Do not conduct any vegetation treatments or 

improvement projects in breeding habitats 

from February 15 – June 30.

Minimize disturbance to 

breeding grouse Connelly et al. 2000

J5 Columbia Spotted Frog

J5-a

Avoid broadcast spraying of herbicides, or spot 

spraying of sulfometuron methyl within 100 

feet of occupied or suitable spotted frog 

habitat. Follow herbicide-use buffers in 

wetlands. Treatment methods, timing and 

location will be coordinated with a local 

biologist prior to implementation.

Reduce impacts to the 

Columbia spotted frog.

Appendix P of the R6 

2005 FEIS; SERA 

2003, 2004; Bakke 

2003

J6 Silver-bordered fritillary

J6-a Within occupied sites, apply sensitive plant

design features to host/nectar plant species.

Reduce the likelihood 

host/nectar plants would be 

affected.

Malheur Invasive 

Plant Biological 

Evaluation.

J6-b

Do not use ester (BEE) formulations of 

triclopyr ester within occupied silver-bordered 

fritillary habitat

Minimize exposure of 

herbicides and surfactants 

that could pose a risk to the 

silver-bordered fritillary.

Malheur Invasive 

Plant Biological 

Evaluation.

J7 Pygmy Rabbit

J7-a

Within suspected burrow areas, activities will 

be restricted to manual techniques. Treatment 

methods, timing, and location will be 

coordinated with a local biologist.

Minimize chances a burrow 

would collapse.

Malheur Invasive 

Plant Biological 

Evaluation.

J8 Upland Sandpiper

J8-a

In order to avoid disturbance or potential 

trampling of nesting upland sandpipers, no 

treatment would occur on sites that have 

historic or recent documentation of upland 

sandpipers during the nesting season (April 

1st to August 1st), unless the site has been 

surveyed and no nesting is occurring.

Minimize likelihood that 

nests would be disturbed 

during treatment.

Malheur Invasive 

Plant Biological 

Evaluation.

J9 Grasshopper Sparrow

J9-a

In order to avoid disturbance or potential 

trampling of nesting birds during the nesting 

season (May 1st to August 1st), no treatment 

would occur on sites where grasshopper 

Minimize likelihood that 

nests would be disturbed 

during treatment.

Malheur Invasive 

Plant Biological 

Evaluation.

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sparrows have been documented.

J10 Harney Basin Duskysnail

J10-a

If an occupied site is proposed for treatment, a 

local biologist would be consulted to determine 

protection measures, if necessary. These 

measures may include limitations on vehicle 

entry, modifications to treatment type or timing, 

or implementation of buffers.

Minimize likelihood that 

snails would be harmed from 

treatment

Malheur Invasive 

Plant Biological 

Evaluation

J11 Featured Species: Raptors and Osprey

J11-a

Active raptor nest sites will be protected during 

implementation. If a raptor nest is found within 

0.50 mile of a site proposed for treatment, a 

wildlife biologist will be consulted to determine 

appropriate seasonal restriction dates and 

buffer distances, if necessary.

Reduce impacts to raptor 

nesting and reproduction.

Malheur and Ochoco 

LRMP

J12 Big game

J12-a

Restrict off-highway vehicle use within MA 41 

(big game winter range) between December 1 

and April 1.

Reduce disturbance to 

wintering elk and deer. Malheur LRMP

J12-b

To prevent harassment in designated calving 

areas, restrict off-highway vehicles and other 

motorized traffic use to designated roads and

trails from May 1 to June 31.

Reduce impacts during elk 

calving. Malheur LRMP

J13 Yellow-billed Cuckoo

J13-a

If a known breeding site is proposed for 

treatment, a biologist will be contacted to 

determine protection measures. These 

measures may include limitations on vehicle 

entry, modifications to treatment type or timing, 

or implementation of buffers. Protection 

measures would be coordinated with the 

USFWS. 

Minimize likelihood that 

nests would be affected by 

treatment

Professional judgment 

K – Public Notification

K1

High use areas, including administrative sites, 

developed campgrounds, visitor centers, and 

trailheads would be posted in advance of 

herbicide application. These areas may remain 

open, or could be closed during and

immediately after herbicide application.

Postings would indicate the date of treatments, 

the herbicide used, and when the areas are 

expected to be clear of herbicide residue.

See also L2 for special products and M1 for 

cultural plants.

To ensure that no 

inadvertent public contact 

with herbicide occurs.

These are common 

measures to reduce 

conflicts. 

K2

The public would be notified about upcoming 

herbicide treatments via the local newspaper 

or individual notification, fliers, and posting 

signs. Forest Service and other websites may 

also be used for public notification. 

To ensure the public is 

informed about upcoming 

herbicide treatments.

R6 2005 ROD 

Standard 23 (see 

table 1). 

L – Special Forest Products

L2 Specific edible/medicinal plant collection 

areas, along with specific areas of cultural or 

To minimize potential for 

public exposure to R6 2005 ROD 

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spiritual value, may be identified by the public. 

These areas would be specifically posted prior 

to spraying. Postings would indicate the date 

of treatments, the herbicide used, and when 

the areas are expected to be clear of herbicide 

residue.

herbicides and acknowledge 

the public’s need to know 

whether herbicide may be 

used in specific areas where 

they harvest medicinal or 

edible plants.

Standard 23

L4

Flyers indicating upcoming herbicide 

treatments and explaining the use of blue dye 

may be included with mushroom and special 

forest product collection permits, in multilingual formats if necessary. See section K.

To minimize potential for 

public exposure to 

herbicides

R6 2005 ROD 

Standard 23

M – American Indian Tribal and Treaty Rights and Archaeology

M1

American Indian tribes would be notified 

annually as treatments are scheduled so that 

tribal members may provide input and/or be 

notified prior to gathering cultural plants. 

Cultural plants in areas identified by tribes 

would be buffered as above for botanical 

species of concern; (see section I2, I3, and I4).

To ensure that no 

inadvertent public contact 

with herbicide occurs and 

that cultural plants are fully 

protected. 

Government to 

government 

agreements between 

American Indian 

tribes and the 

Malheur National 

Forest.

N – Range Resources

N2

Permittees will be notified of annual treatment 

actions at the annual permittee operating plan 

meeting, and/or notified within 2 weeks of 

planned treatments of infestations > 1 acre in 

size.

To ensure permittee has 

knowledge of activities 

occurring within the 

allotment

Common practice 

N3 Follow most current EPA herbicide label for 

grazing restrictions. 

To ensure grazing animals 

are not exposed to 

chemicals

EPA labeling 

requirements

Herbicide-use buffers

Herbicide treatments would become more restrictive as they occur closer to water. Project design features 

and herbicide-use buffers within the aquatic influence zone were developed based on label advisories,

SERA risk assessments, and various studies of drift and runoff to streams such as Berg 2004. Figure 3

shows the water’s edge and bankfull (i.e., high water mark). The further away from these areas, the 

greater the number of options available. 

In general, aquatic labeled herbicides and aminopyralid may be used to the water’s edge, with potential 

additional restrictions, depending on soils or other factors, such as herbicide effectiveness on the target 

species and sensitivity and susceptibility of non-target species.

The assumption under this project is that if any part of an infested area falls within an herbicide-use 

buffer, the buffer restrictions apply to the entire infestation. This assumption is reasonable because of the 

nature of herbicide application; fine distinctions are often difficult to discern on the ground and 

applicators would likely use one tankful to do an entire job rather than switching between tanks during 

treatment.

Table 11 and table 12 display the herbicide-use buffers for each herbicide and application method.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Figure 3. Herbicide-use buffers

Table 11. Herbicide-use buffers (in feet) for streams, wetlands, lakes, ponds and roadside ditches with water 

present at the time of treatment. Measured in feet from the edge of surface water. Herbicides in bold are 

those most likely to be used.

Herbicide

Streams, wetlands, lakes and ponds 

and hydrologically connected roadside ditches with 

surface water present

Broadcast Spot/Hand/Select

Aquatic Glyphosate 50 Water’s edge

Aquatic Imazapyr 50 Water’s edge

Aquatic Triclopyr-TEA Not Allowed 15

Aminopyralid Water’s edge Water’s edge

Clopyralid 100 15

Imazapic 100 15

Metsulfuron Methyl 100 15

Imazapyr 100 50

Sulfometuron Methyl 100 50

Chlorsulfuron 100 50

Picloram 100 50

Sethoxydim 100 50

Glyphosate 100 50

Triclopyr-Bee Not Allowed 150

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Table 12. Herbicide-use buffers (in feet) for stream channels that are dry at the time of treatment. Measured in 

feet from the edge of the channel as defined by the high water (bankfull) mark. Herbicides in bold are those 

most likely to be used.

Herbicide

Intermittent and Ephemeral Streams (Dry at time of 

treatment) 

Broadcast Spot/Hand/Select

Aquatic Glyphosate Bankfull No buffer

Aquatic Imazapyr Bankfull No buffer 

Aquatic Triclopyr-TEA Not Allowed Bankfull

Aminopyralid No Buffer No Buffer

Imazapic 50 Bankfull

Metsulfuron Methyl 50 Bankfull

Clopyralid 50 Bankfull

Imazapyr 50 15

Sulfometuron Methyl 50 15

Chlorsulfuron 50 15

Picloram 100 50

Sethoxydim 100 50

Glyphosate 100 50

Triclopyr BEE Not Allowed 150

Treatment Flexibility and Early Detection/Rapid Response

Alternative B provides for treatment flexibility and early detection/rapid response by providing a method 

for us to adapt to changes on the ground over time. We expect some populations to increase and others to 

decrease over the life of this project, depending on many unpredictable factors such as weather (droughts 

and wet periods), funding, and the location of wildland fires or other uncontrolled disturbances. Under 

alternative B, we will tailor the prescription to ground conditions at the time of treatment.

In addition, new or previously undiscovered infestations could be treated using the range of methods 

described in this EIS. An EDRR approach is needed because 1) the precise location of individual target 

plants, including those mapped in the current inventory, are subject to rapid and/or unpredictable change, 

and 2) the typical NEPA process does not allow for rapid response to new detections; infestations may 

grow and spread into new areas during the time it usually takes to prepare NEPA documentation. The 

intent of the project early detection/rapid response approach is to treat new infestations when they are 

small so that the likelihood of successful treatment is maximized and adverse effects are minimized.

If alternative B is selected, integrated treatments would be authorized for new infestations detected, using 

the treatment methods and project design features evaluated in this EIS. The analysis of alternative B

assumes that all of the current infestations are treated in a single year and all pdfs are properly applied. 

Compared to alternative A, herbicide use would increase as a result of implementing this alternative;

however, we would also reduce reliance on herbicides over time as target invasive plant populations are 

reduced and desirable vegetation is restored. Newly detected invasive plants are high priority for 

treatment and herbicides may be used; however, we do not expect EDRR to require extensive herbicide 

treatments. Our intention is to rapidly respond to new detections and treat them while they are small, 

increasing our chances of success and minimizing the amount of herbicide needed.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Chapter 3.1.5 discusses how the spread of invasive plants is influenced by the intensity and frequency of 

soil disturbance at a given site, along with the invasive plant propagule pressure associated with nearby 

vectors (pathway).

The approach is based on the premise that the impacts of similar treatments are predictable, even though 

the precise location or timing of the treatment may be unpredictable. The project early detection/rapid 

response approach would allow the Forest Service to treat new infestations using approved methods 

anywhere on the Forest that the need exists. The implementation planning process detailed in the 

following section is intended to ensure that pdfs and herbicide-use buffers are appropriately applied and 

that effects are within the scope of those disclosed in this EIS. FSH 1909.15, Chapter 1.8.1, provides 

guidance of review of ongoing projects to determine if the environmental analysis and documentation 

should be corrected, supplemented, or revised.

New species not currently found on the Forest may be treated as long as effective treatment methods that 

follow project design features and herbicide-use buffers are discussed in this EIS. 

Project “Caps” 

These caps provide further sideboards to minimize adverse effects and ensure that the effects of 

treatments authorized under this EIS are consistent with the analysis disclosed in this EIS. Under 

alternative B:

♦ In no case would more than 2,124 acres be treated using herbicides in a single year (based on our 

existing, site-specific inventory).14

♦ No more than 10 percent of the total acres of any 6th field watershed would be treated in a single 

year. 

♦ No more than 50 acres within 100 feet of any water body in a 6th field watershed would be treated 

in a single year, and of these, no more than 10 acres would consist of herbicide use.

15

♦ The project would continue until no more treatments were needed or until conditions otherwise 

changed sufficiently to warrant this EIS outdated.

The following table shows management objectives for additional target species that may be found under 

the project early detection/rapid response portion of the project. These include: 1) new invasive plant 

species that may invade the Forest in the future, 2) invasive species that are known to occur on the Forest, 

but are not mapped due to their ubiquity, 3) noxious weeds that are not invasive, dominating, or persistent 

on the Forest, and 4) non-native species that may be treated only when co-occurring with the 18 primary 

target species we have currently mapped.

14 All caps and limitations on herbicide use would be based on the amount of herbicide actually applied, rather than 

the gross acres in any infested area. 15 Currently, a total of 470 acres of invasive plants lie within 100 feet of a water body. This acreage is scattered 

mainly along roads within several 6th field watersheds. When the entire infested site acreage is included if any part 

of the infested area is within 100 feet of a water body, this acreage rises to 1,389. 

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Table 13. Management objectives under early detection/rapid response

Species Category Examples Treatment 

Objective Notes

New invasive 

species / noxious 

weeds on the Forest

Class A or B noxious 

weeds as designated by the 

State of Oregon or species 

that are new to the state 

and/or North America

Eradicate New sites will be inventoried and eradicated 

using early detection/rapid response (EDRR).

Invasive species / 

noxious weeds / nonnative species that 

are ubiquitous 

across the landscape

Cheatgrass, medusahead, 

Ventenata, intermediate 

wheatgrass, Poa bulbosa, 

dandelion, mullein, etc.

Tolerate

These species are not inventoried. Some 

species may be treated if they co-occur with 

the 18 primary target species, especially where 

active restoration is prescribed. Additionally, 

some of these species may be indirectly 

suppressed with cultural methods on a site 

specific basis. For example, permitted livestock 

grazing may occur in cheatgrass-dominated 

areas in an attempt to suppress the vigor of 

the infestation. However, this would be dealt 

with during Allotment Management Plan 

revision and/or the Annual Operating 

Instructions.

Non-native species / 

noxious weeds that 

occur sporadically on 

the Forest, but are 

not invasive and 

have not been 

observed to 

dominate or persist 

at sites.

Tansy ragwort, rush 

skeletonweed, oxeye daisy, 

etc.

Tolerate & 

Monitor

These species are either not inventoried or the 

existing inventory is incomplete and 

inaccurate. Adjust treatment objectives through 

adaptive management if species are becoming 

invasive (e.g., spreading, displacing native 

species, disrupting ecosystem processes). 

Some may be treated if they co-occur with the 

18 primary target species. Manual treatments 

may occur if sites are encountered during other 

related fieldwork.

Implementation Planning

This section outlines the process that would be used to ensure that the selected alternative is properly 

implemented. The methodology follows integrated weed management principles (R6 2005 FEIS, 3-3) and 

satisfies pesticide use planning requirements atFSM 2150 and FSH 2109.14. It applies to currently known 

infestations and new sites found within or outside currently mapped treatment areas during ongoing 

inventory. Appropriate Forest Service staff would develop annual treatment prescriptions to ensure that 

project design features are appropriately incorporated. This process applies to invasive plant treatments 

planned as a part of other projects (such as a mitigation measure associated with a thinning or road 

decommissioning) or on a stand-alone basis. The priority, strategy, and timing of treatment are influenced 

by the potential for disturbance, especially where seed beds are in the soil and invasive plant growth may 

be triggered by the disturbance. See chapter 3.1.5 for more information about the spread of invasive 

plants along identified vectors. The range of treatment methods considered herein are based on effective 

treatments (common control measures, see table 9) needed for the current inventory of 18 primary target 

species across the Malheur National Forest. New situations could lead to the need for additional 

integrated treatment methods within the scope of the selected alternative.

1. Characterize invasive plant infestations to be treated

1. Identify target species, location, density, and extent. 

2. Identify adjacent land uses and vectors for invasive plant spread 

3. Determine treatment objective and priority. 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

2. Develop site-specific prescriptions 

• Consider whether active restoration may be necessary 

• Review the common control measures and update as needed using Integrated Weed Management

principles. Identify effective integrated treatment method depending on the target species and 

surrounding environment. 

• Determine whether herbicides are needed and which application method is needed based on the 

biology of the target species and size and distribution of the infestations. See figure 4 below 

showing how the decision to use herbicides would be made on a case by case basis. 

• Apply appropriate pdfs based on:

• Past treatment history and response to past treatment 

• Proximity to species of local interest or their habitats

• Proximity to streams, lakes, wetlands

• Proximity to vectors and potential for persistent disturbance;

• Surrounding National Forest land uses and activities 

• Soil conditions

• Municipal watersheds and/or domestic water intakes

• Recreation areas, special forest product and special use areas

• First-choice or other effective herbicide

• Application rate and method 

Once the treatment prescription has been refined, we will: 

• Complete Form FS-2100-2 Pesticide Use Proposal. This form lists treatment objectives, specific 

herbicide(s) that would be used, the rate and method of application, and pdfs that apply. 

• Determine need for pre-project surveys for species of local interest and/or their habitats.

• Coordinate with adjacent landowners, water users, agencies, partners, and tribal governments.

• Initiate public notification 

3. Accomplishment and Compliance Monitoring

• Develop a project work plan for herbicide use as per FSH 2109.14.3. This work plan presents 

organizational and operational details including the precise treatment objectives, equipment, 

materials, and supplies needed; the herbicide application method and rate; field crew organization 

and lines of responsibility; and interagency coordination.

• Ensure contracts and agreements include appropriate prescriptions and that herbicide ingredients 

and application rates meet label requirements, R6 2005 ROD, and site-specific pdfs. Contracts 

and agreements will include the appropriate pdfs, herbicide-use buffers, including herbicide and 

additive limitations.

• Document and report herbicide use and certified applicator information in the National pesticide 

use database, via the Forest Service Activity Tracking System (FACTS). A pesticide use report 

extracts data from FACTS.

4. Post-treatment Monitoring and Recurring Treatments

• Monitoring would occur during implementation to ensure project design features are 

implemented as planned. Post-treatment reviews would occur to determine whether treatments are 

effective and whether or not passive/active restoration is occurring as expected.

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

• Contract administration and other existing mechanisms would be used to correct deficiencies. 

Herbicide use would be reported as required by the FSH 2109.14 and FACTS.

• Post-treatment monitoring would also be used to detect whether pdfs were appropriately applied, 

and whether non-target vegetation impacts were within tolerable levels. 

• Prescriptions would be refined over time based on post-treatment results as long as treatments 

remain within the scope of the EIS. For instance, an invasive plant population treated with a 

broadcast herbicide may be retreated with a spot spray, or later manually pulled, once the size of 

the infestation is sufficiently reduced following the initial treatment. Another example would be 

the use of another herbicide if the first choice is not effective.

• Treatment buffers would be expanded if damage was found outside herbicide-use buffers as 

indicated by a decrease in the size of any non-target plant population, leaf discoloration or 

chlorophyll change, or mortality to individual species of local interest or non-target vegetation.

The findings would be applied to herbicide-use buffers for waterbodies. Herbicide-use buffers

may be adjusted for certain herbicides/application methods and not others, depending on results.

• See discussion about monitoring later in this chapter for additional information.

The Decision to Use Herbicides

The following figure displays a series of questions to be answered during implementation, shows

situations where herbicide would be applied and in general, how pdfs would be considered in the 

prescription process. This figure applies to currently known infestations and new sites found within or 

outside currently mapped treatment areas during ongoing inventory. If the target invasive species 

population is not associated with a size, phenology, density or distribution that warrants herbicide use 

(alone or in combination with other methods), or if herbicide use does not substantially increase treatment 

efficiency (considering the availability of volunteers if needed), non-herbicide methods would be favored. 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Figure 4. Questions that facilitate the decision for using herbicides

The Decision to Use Herbicides 

Is the target invasive species population associated with a size, phenology, density, or 

distribution that warrants herbicide use (alone or in combination with other methods)?

Yes: To determine appropriate herbicide, review common control measures coupled with local 

experience. Use first choice or other effective herbicides based on their properties, risks, label 

directions, and project design features. Consider non-target vegetation surrounding treatment 

sites and use more selective herbicides as appropriate. Consider soil conditions at the treatment 

site. Consider previous treatments that have occurred on the site. Were they effective? Would 

another herbicide or combination of methods be more effective? Consider wildlife habitats in the 

area and implement seasonal restrictions if required. Consider proximity to water and fish 

species of conservation concern.

No: Would use of herbicides substantially increase cost-effectiveness of treatment? Consider 

whether volunteers may be available to reduce the cost of manual treatments.

Yes: To determine appropriate herbicide, review common control measures coupled with 

local experience. Use first choice or other effective herbicides based on their properties, 

risks, label directions, and project design features. Consider non-target vegetation 

surrounding treatment sites and use more selective herbicides as appropriate. Consider soil 

conditions at the treatment site. Consider previous treatments that have occurred on the site. 

Were they effective? Would another herbicide or combination of methods be more 

effective? Consider wildlife habitats in the area and implement seasonal restrictions if 

required. Consider proximity to water and fish species of conservation concern.

No: Use non-herbicide (manual, mechanical biological or cultural) methods.

Process for Prescribing Broadcast Herbicide Application Method 

Do the size, density, and/or distribution of invasive plants warrant broadcast application? 

No: Use application methods other than broadcasting

Yes: Is the Site within 100 feet of streams and water bodies? Does the area provide habitat for 

fish species of conservation concern?

Yes: Apply buffers and other pdfs as appropriate. If broadcast is no longer an acceptable 

method given pdfs, choose an application method other than broadcasting. 

No: Are there botanical species of conservation concern within 100 feet of the proposed 

broadcast site? 

Yes: survey as needed for botanical species of concern within suitable habitats.

Apply botanical buffers as appropriate. Broadcast may still be acceptable if 

botanical species of conservation concern are covered by barriers. Apply 

remaining project design features. If broadcast is no longer an acceptable 

method, choose an application method other than broadcasting.

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Monitoring

Under alternative B, we would continue to monitor invasive plants and treatments according to national 

and regional Forest Service policy. Our monitoring approach is described in the bullets below: 

♦ We would continue to inventory (catalog and map) invasive plant presence using established 

Forest Service protocols (NRM 2013);

♦ We would ensure that treatments of higher-risk16 sites with potential to impact species of 

conservation concern are properly implemented, and that adverse effects are minimized according 

to the R6 2005 invasive plant monitoring framework and subsequent monitoring plans (a copy of 

the current R6 Invasive Plant Monitoring Plan is in the project record); 

♦ We would assess the potential for chemicals and sediment to reach streams and impact water 

quality according to the R6 2005 Monitoring Framework and subsequent monitoring plans along 

with monitoring associated with National Water Quality Best Management Practice (BMPs). We 

would follow established monitoring protocols for chemical use and other projects that may 

impact streams, water, or riparian habitats. We would increase herbicide-use buffers, reduce 

herbicide application rate, or change treatment method should we find unexpected adverse 

effects. 

♦ We would monitor treatment effectiveness as part of our annual accomplishment reporting. In 

accordance with national policy, at least 50 percent of all invasive plant treatments are monitored 

on the ground to determine treatment effectiveness. We would likely revisit most if not all 

treatment sites to determine need for follow up until the site is fully restored to its desired 

condition (depending on the capability of the site, the surrounding land uses, the nature of the 

infestation, and other factors – please see our implementation planning process outlined 

previously in this chapter).

♦ We would ensure that herbicide-use buffers and design features are being properly implemented. 

If not, we would immediately adjust treatments to ensure proper implementation. In addition, if 

we find unexpected adverse effects despite proper implementation, we would adjust the 

herbicide-use buffers and design features until the effects are no longer occurring.

♦ We would follow the “Invasive Species Monitoring Plan; Southern Blues Restoration Coalition” 

(appendix B) to address the question: “What are the trends in the occurrence and distribution of 

invasive plants/noxious weeds at the project and landscape scales?”

2.3.3 Alternative C – Strict Limitations on Herbicide Use

Changes between Draft and Final EIS: Clarification on integrated treatments methods, project design 

features, and buffers for this alternative.

Introduction

We developed alternative C in response to some public concerns about herbicide use on the Malheur 

National Forest. Alternative C would impose strict limitations on our ability to use herbicides to treat 

invasive plants. Compared to alternative B, alternative C would address public concerns about herbicide 

impacts to human health, non-target vegetation, potential water contamination, and herbicide effects on 

16 Higher-risk sites are defined in the Monitoring Plan and for this project would involve any broadcasting of 

herbicides within 100 feet of a stream. 

68

 
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

fish, wildlife, and pollinators while still allowing for some herbicide use. About 735 acres would be 

approved for spot/selective herbicide use and on the remaining 1,389 acres, no herbicide would be used.

17

Land and Resource Management Plan Amendment

Alternative C would include the same LRMP amendment as alternative B. 

Integrated Treatment Methods (Common Control Measures) and Prescriptions

Alternative C would include all of the integrated treatment methods listed for alternative B except 

broadcast treatment would not be authorized and no picloram would be used. Biological controls that 

meet Standard 14 would be released as described under alternative B. Of the ten herbicides considered for 

use, the first choice herbicides are most likely to be used. The herbicides sethoxydim, sulfometuron 

methyl and triclopyr are the least likely to be used, either because they are effective on fewer target 

species found on the Forest than other herbicides or because of the restrictions associated with their use. 

Table 14. Common control measures for alternative C. Species order does not reflect priority. First choice 

herbicide is listed in bold followed by other effective herbicides in alphabetical order.

Primary Target Species

First-Choice Followed 

by Other Effective 

Herbicides

Integrated Treatment Notes

Yellow star-thistle

Centaurea solstitialis

(CESO3)

Annual

aminopyralid

clopyralid

glyphosate

Early detection and treatment increases the chances of 

control. Treatment of small infestations in otherwise 

healthy sites should be a priority.

Biological control agents are available.

Hand pull when soil is moist and remove all roots and 

flower and seed heads.

Common St. Johnswort

Hypericum perforatum

(HYPE)

Perennial with stolons and 

rhizomes

aminopyralid

glyphosate

metsulfuron methyl

Biological agents are available.

Small infestations may be controlled by pulling or 

digging. Repeated treatments will be necessary 

because lateral roots can give rise to new plants. Bag

and remove all plant parts from site.

Russian knapweed

Acroptilon repens

(ACRE3)

Long-lived creeping perennial

aminopyralid

chlorsulfuron

clopyralid

glyphosate

imazapyr

metsulfuron methyl

Hand pulling is effective only in the establishment year.

Reproduces mainly by vegetative propagation from 

buds on creeping roots. Cutting or mowing several 

times per year will control top growth and seed 

production; re-emerging plants will have less vigor.

Biocontrol agents being developed.

Lasting control requires an integrated approach; using 

mechanical or cultural measures with herbicide 

application, especially in late fall, is most effective.

Small, isolated infestations should be eradicated first. 

Then larger infestations should be controlled from the 

perimeter and eradicated when possible.

17 This assumes that no herbicide would be used within the entire infested area if any part of the area is within 100 

feet of a stream or water body, or 200 feet of a drinking water well.

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Primary Target Species

First-Choice Followed 

by Other Effective 

Herbicides

Integrated Treatment Notes

Spotted knapweed

Centaurea stoebe ssp. 

Micranthos

(CESTM)

Taprooted perennial

aminopyralid

clopyralid

glyphosate

triclopyr

Treatment would focus on reducing seed production 

and preventing germination.

Biological agents are available.

Repeated manual pulling and digging may eliminate 

small infestations (2-4 times per year for multiple years). 

Pull prior to seed set. Bag and remove flower and seed 

heads.

Diffuse knapweed

Centaurea diffusa

(CEDI)

Short-lived perennial, biennial 

or annual. Often with a long, 

stout taproot

Squarrose knapweed

Centaurea ulfome ssp. 

Squarrosa

(CEVIS2)

Taprooted perennial

Meadow knapweed

Centaurea jacea sensu lato

(CEJA)

Taprooted perennial

Canada thistle

Cirsium arvense

(CIAR4)

Rhizomatous perennial

aminopyralid

chlorsulfuron

clopyralid

Combining mechanical, cultural, biological, and 

chemical methods is best for effective control.

Biological agents are available.

Mowing, cutting or pulling can be an effective control if 

repeated at about 1-month intervals throughout the 

growing season for several years. Combining 

mowing/cutting with herbicides (in the fall) will further 

enhance control of Canada thistle. Covering with plastic 

tarp (solarization) may be effective for small infestations.

Bull thistle*

Cirsium vulgare

(CIVU)

Taprooted biennial

aminopyralid

chlorsulfuron

clopyralid

glyphosate

triclopyr

Prioritize small infestations in otherwise healthy sites. 

Prioritize prevention of establishment and eliminating 

plants as soon as they are found.

Manually pulling rosettes or cutting stems 2”-4” below 

the soil surface before flower heads develop kills plants 

and prevents seed development. Roots may be left on 

site to dry; all flower and seed heads should be 

removed.

Covering disturbed sites, particularly small burn areas, 

with fine to medium sized organic matter may prevent or 

reduce the size of infestations.

Scotch Thistle

Onopordum acanthium

(ONAC)

Taprooted biennial or shortlived perennial

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Primary Target Species

First-Choice Followed 

by Other Effective 

Herbicides

Integrated Treatment Notes

Musk thistle

Carduus nutans

(CANU4)

Taprooted biennial or 

occasional annual

Leafy spurge

Euphorbia esula

(EUES)

Rhizomatous perennial

aminopyralid

glyphosate

imazapic

Early detection and rapid eradication is important since 

plant spreads rapidly by seeds and rhizomes.

Continuous aggressive management is necessary to 

keep infestations under control (5 – 10 

years).Prioritizing treatment of small infestations, then 

treating large infestations from the outside edges is 

most effective.

Biological control agents may reduce aboveground 

stems but do not kill root systems.

Mechanical, cultural, or herbicide methods alone are 

rarely effective. Combinations of several herbicide 

treatments and planting grass seed may provide the 

best chance of controlling the species.

Hand pulling and grubbing are not effective because of 

the extensive root system. Cutting and mowing reduce 

seed production and the plant’s competitive ability.

Covering with weed cloth, plastic, or thick mulch may kill 

plants. Site can then be planted with native seed. If 

manual methods are used, all plant parts should be 

bagged and removed since new plants may form from 

roots and rhizomes as well as from seeds.

Plant’s milky sap may be irritating to skin, eyes, and 

digestive tract of humans and other animals.

Houndstongue

Cynoglossum officinale

(CYOF)

Taprooted biennial or shortlived perennial

chlorsulfuron

imazapic

metsulfuron methyl

Mowing/cutting second year plants during flowering, but 

before seed maturation reduces seed production and 

may kill the plant.

Pulling plants or cutting 1-2” below the soil surface have 

the best chance of eliminating plants. Cutting produces 

less ground disturbance than pulling.

Bag and remove all flower and seed heads.

Dalmatian toadflax

Linaria dalmatica

(LIDA)

Perennial with taproot and 

extensive system of lateral 

roots

chlorsulfuron

imazapic

metsulfuron methyl

picloram

Dalmatian toadflax reproduces primarily by seed and 

partly by adventitious root buds. Yellow toadflax 

reproduces primarily by adventitious root buds on lateral 

roots.

Biological agents are available and may be very 

effective. If biocontrol agents continue to be effective, 

herbicide application may not be needed.

Manual pulling and digging may not be effective 

because of the deep (4-10 feet) and laterally extensive 

root systems (to 10 feet from plant). If manually 

removed, all roots and flower and seed heads should be 

bagged and removed.

Cutting stems in spring or early summer would eliminate 

seed production, but not the root system.

Yellow toadflax

Linaria vulgare

(LIVU2)

Perennial with taproot and 

extensive system of vertical 

and creeping lateral roots

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Primary Target Species

First-Choice Followed 

by Other Effective 

Herbicides

Integrated Treatment Notes

Whitetop

Cardaria draba

(CADR)

Rhizomatous perennial

chlorsulfuron

glyphosate

imazapic

imazapyr

metsulfuron methyl

These species are difficult to control because of its deep 

taproots (9 ft.) and ability to sprout from root fragments.

Early detection and proactive management is most 

effective since established infestations are difficult to 

control. Frequent monitoring for new sites and 

prioritizing small infestations in otherwise healthy sites is 

important. Next priority would be for corridors, such as 

waterways and irrigations structures that have a high 

likelihood of spread. Biological controls are not 

available.

Repeated pulling may control small, young infestations.

Established plants are likely to resprout from deep 

roots. All roots and flower and seed heads should be 

removed. Mowing does not eliminate plants but 

removes thatch.

Perennial pepperweed

Lepidium latifolium

(LELA2)

Perennial with rhizome like 

creeping roots

Sulphur cinquefoil

Potentilla recta

(PORE5)

Taprooted perennial that may 

have several shallow, 

spreading branch roots but not 

rhizomes

metsulfuron methyl

glyphosate

triclopyr

Cultural treatments such as seeding of native plants 

may be effective.

There are no approved biocontrols.

Small infestations may be controlled by hand digging if 

the entire root crown is removed.

For large infestations, selective herbicides are likely the 

only method of effective control (TNC 2004). Repeated 

treatments are needed for the first couple of years to 

ensure re-establishment does not occur.

Project Design Features

Under alternative C, all of the alternative components project design features for alternative B would be

followed, except that pdfs related to broadcast spraying, use of picloram, and herbicide use within 100 

feet of streams or other water bodies would not be applicable.

Herbicide-Use Buffers

No herbicide use would be allowed within the boundaries of any mapped infested area that at any point is 

within 100 feet of creeks, lakes, ponds, and wetlands; or 200 feet of well source areas. Non-herbicide 

methods would continue to be used within these areas. The buffer tables associated with alternative B 

would become non-applicable since no herbicide use would be allowed within 100 feet of streams. No 

herbicide use would be authorized within 100 feet of hydrologically connected roadside ditches when 

surface water is present. 

Passive and Active Restoration

Restoration would be the same as described for alternative B. 

Treatment Flexibility and Early Detection/Rapid Response

Alternative C would provide for treatment flexibility through the life of the project. Newly detected 

infestations could be treated according to the pdfs associated with this alternative. No broadcast 

treatments, use of herbicides within 100 feet of streams, or use of picloram would be authorized for future 

year treatments. Selective and spot treatment of herbicide would be limited to no more than 735 acres per 

year. No more than 50 acres of non-herbicide treatment (except biological controls) would occur annually 

within 100 feet of a stream or water body with any given 6th field watershed. 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

These restrictions would apply to known sites as they change over time, as well as new detections. The 

implementation planning process would be similar to alternative B; however, the range of treatments that 

would be allowed and the places, types, and amounts of herbicide that may be used would be more 

restrictive. Table 15 summarizes the herbicides ingredients that are likely most effective in alternative C,

based on the target species within the mapped infested areas and the restrictions on herbicide use in this 

alternative.

Implementation Planning and Monitoring

The implementation planning process and monitoring requirements would be similar to alternative B. 

Questions to facilitate the use of herbicides would not include questions leading to decisions about 

whether or not to use the broadcast application method.

Table 15. Summary of herbicide and non-herbicide use under alternative C

First Year/First Choice Activity Acres

Herbicide Active Ingredient

Aminopyralid 560

Chlorsulfuron 142

Metsulfuron methyl 33

Total Spot/Selective Herbicide Application 735

Total Non-herbicide Treatment 1,389

2.3.4 Alternative D – No LRMP Amendment, No Aminopyralid

Introduction

Alternative D was developed to evaluate the tradeoffs involved with adding aminopyralid to the list of 

available herbicides for use on the Malheur National Forest. 

LRMP Amendment

No LRMP amendment is proposed for this alternative.

Integrated Treatment Methods

All treatment methods listed for alternative D would be approved. Biological controls that meet Standard 

14 would be released as described under alternative B.

Integrated Treatment Prescriptions (Common Control Measures) and Methods

Integrated treatment prescriptions for alternative D would be similar to those listed for alternative B 

except that no aminopyralid would be used to treat known sites or new detections. Compared to 

alternative B, more chlorsulfuron, glyphosate, metsulfuron methyl, and picloram would be used in lieu of 

aminopyralid. In some cases, the first choice herbicide would not be approved for use near streams (e.g., 

picloram) and another herbicide (e.g., glyphosate) would become the first choice. 

Table 16. Common Control measures for alternative D. Species order does not reflect priority. First choice 

herbicide is listed in bold followed by other effective herbicides in alphabetical order.

Primary Target Species First-Choice 

Followed by Other 

Effective 

Herbicides

Integrated Treatment Notes

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Primary Target Species First-Choice 

Followed by Other 

Effective 

Herbicides

Integrated Treatment Notes

Yellow star-thistle

Centaurea solstitialis

(CESO3)

Annual

picloram

clopyralid

glyphosate

Early detection and treatment increase the chances of 

control. Treatment of small infestations in otherwise 

healthy sites should be a priority.

Biological control agents are available. 

Hand pull when soil is moist and remove all roots and 

flower and seed heads.

Common St. Johnswort

Hypericum perforatum

(HYPE)

Perennial with stolons and 

rhizomes

metsulfuron methyl

glyphosate

picloram

Biological agents are available. 

Small infestations may be controlled by pulling or 

digging. Repeated treatments will be necessary 

because lateral roots can give rise to new plants. Bag 

and remove all plant parts from site.

Russian knapweed

Acroptilon repens

(ACRE3)

Long-lived creeping perennial

chlorsulfuron

clopyralid

glyphosate

imazapyr

metsulfuron methyl

picloram

Hand pulling is effective only in the establishment year. 

Reproduces mainly by vegetative propagation from 

buds on creeping roots.

Biocontrol agents being developed.

Cutting or mowing several times per year will control top 

growth and seed production; re-emerging plants will 

have less vigor.

Lasting control requires an integrated approach; using 

mechanical or cultural measures with herbicide 

application, especially in late fall, is most effective.

Small, isolated infestations should be eradicated first. 

Then larger infestations should be controlled from the 

perimeter and eradicated when possible.

Spotted knapweed

Centaurea stoebe ssp. micranthos

(CESTM)

Taprooted perennial

picloram

clopyralid

glyphosate

triclopyr

Treatment would focus on reducing seed production 

and preventing germination.

Biological agents are available.

Repeated manual pulling and digging may eliminate 

small infestations (2-4 times per year for multiple 

years). Pull prior to seed set. Bag and remove flower 

and seed heads.

Diffuse knapweed

Centaurea diffusa

(CEDI)

Short-lived perennial, biennial or 

annual. Often with a long, stout 

taproot

Squarrose knapweed

Centaurea ulfome ssp. squarrosa

(CEVIS2)

Taprooted perennial

74
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Primary Target Species First-Choice 

Followed by Other 

Effective 

Herbicides

Integrated Treatment Notes

Meadow knapweed

Centaurea jacea sensu lato

(CEJA)

Taprooted perennial

Canada thistle

Cirsium arvense

(CIAR4)

Rhizomatous perennial

picloram

chlorsulfuron

clopyralid

glyphosate

Combining mechanical, cultural, biological, and 

chemical methods is best for effective control.

Biological agents are available, 

Mowing, cutting or pulling can be an effective control if 

repeated at about 1-month intervals throughout the 

growing season for several years. Combining 

mowing/cutting with herbicides (in the fall) will further 

enhance control of Canada thistle. Covering with plastic 

tarp (solarization) may be effective for small 

infestations.

Bull thistle*

Cirsium vulgare

(CIVU)

Taprooted biennial

chlorsulfuron

clopyralid

glyphosate

picloram

triclopyr

Prioritize small infestations in otherwise healthy sites. 

Prioritize prevention of establishment and eliminating 

plants as soon as they are found.

Biological agents are available

Manually pulling rosettes or cutting stems 2”-4” below 

the soil surface before flower heads develop kills plants 

and prevents seed development. Roots may be left on 

site to dry; all flower and seed heads should be 

removed.

Covering disturbed sites, particularly small burn areas, 

with fine to medium sized organic matter may prevent 

or reduce the size of infestations.

Scotch Thistle

Onopordum acanthium

(ONAC)

Taprooted biennial or short-lived 

perennial

glyphosate

chlorsulfuron

clopyralid

picloram

triclopyr

Musk thistle

Carduus nutans

(CANU4)

Taprooted biennial or occasional 

annual

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Primary Target Species First-Choice 

Followed by Other 

Effective 

Herbicides

Integrated Treatment Notes

Leafy spurge

Euphorbia esula

(EUES)

Rhizomatous perennial

picloram

glyphosate imazapic

Early detection and rapid eradication is important since 

plant spreads rapidly by seeds and rhizomes.

Continuous aggressive management is necessary to 

keep infestations under control (5-10 years). Prioritizing 

treatment of small infestations, then treating large 

infestations from the outside edges is most effective. 

Biological control agents may reduce aboveground 

stems but do not kill root systems. 

Mechanical, cultural, or herbicide methods alone are 

rarely effective. Combinations of several herbicide 

treatments and planting grass seed may provide the 

best chance of controlling the species. 

Hand pulling and grubbing are not effective because of 

the extensive root system. Cutting and mowing reduce 

seed production and the plant’s competitive ability.

Covering with weed cloth, plastic, or thick mulch may 

kill plants. Site can then be planted with native seed. If 

manual methods are used all plant parts should be 

bagged and removed since new plants may form from 

roots and rhizomes as well as from seeds.

Plant’s milky sap may be irritating to skin, eyes, and 

digestive tract of humans and other animals.

Houndstongue

Cynoglossum officinale

(CYOF)

Taprooted biennial or short-lived 

perennial

chlorsulfuron

imazapic

metsulfuron methyl

Mowing/cutting second year plants during flowering, but 

before seed maturation reduces seed production and 

may kill the plant. 

Pulling plants or cutting 1-2” below the soil surface have 

the best chance of eliminating plants. Cutting produces 

less ground disturbance than pulling.

Bag and remove all flower and seed heads.

Dalmatian toadflax

Linaria dalmatica

(LIDA)

Perennial with taproot and 

extensive system of lateral roots

chlorsulfuron

imazapic

metsulfuron methyl

picloram

Dalmatian toadflax reproduces primarily by seed and 

partly by adventitious root buds. Yellow toadflax 

reproduces primarily by adventitious root buds on 

lateral roots.

Biological agents are available and may be very 

effective. If biocontrol agents continue to be effective, 

herbicide application may not be needed.

Manual pulling and digging may not be effective 

because of the deep (4-10 feet) and laterally extensive 

root systems (to 10 feet from plant). If manually 

removed, all roots and flower and seed heads should 

be bagged and removed. 

Cutting stems in spring or early summer would 

eliminate seed production, but not the root system.

Yellow toadflax

Linaria vulgare

(LIVU2)

Perennial with taproot and 

extensive system of vertical and 

creeping lateral roots

Whitetop

Cardaria draba

(CADR)

Rhizomatous perennial

chlorsulfuron

glyphosate

imazapic

These species are difficult to control because of their 

deep taproots (9 ft.) and ability to sprout from root 

fragments. Early detection and proactive management 

is most effective since established infestations are 

difficult to control. Frequent monitoring for new sites 

and prioritizing small infestations in otherwise healthy 

76
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Primary Target Species First-Choice 

Followed by Other 

Effective 

Herbicides

Integrated Treatment Notes

Perennial pepperweed

Lepidium latifolium

(LELA2)

Perennial with rhizome like 

creeping roots

imazapyr

metsulfuron methyl

sites is important. Next priority would be for corridors 

such as waterways and irrigations structures that have 

a high likelihood of spread. Biological controls are not 

available. Repeated pulling may control small, young 

infestations. Established plants are likely to resprout 

from deep roots. All roots and flower and seed heads 

should be removed. 

Mowing does not eliminate plants but removes thatch.

Sulphur cinquefoil

Potentilla recta

(PORE5)

Taprooted perennial that may 

have several shallow, spreading 

branch roots but not rhizomes

metsulfuron methyl

glyphosate

picloram

triclopyr

Cultural treatments, such as seeding of native plants 

may be effective.

There are no approved biocontrols.

Small infestations may be controlled by hand digging if 

the entire root crown is removed.

For large infestations, selective herbicides are likely the 

only method of effective control (TNC 2004). Repeated 

treatments are needed for the first couple of years to 

ensure re-establishment does not occur.

Project Design Features

All of the project design features and herbicide-use buffers associated with alternative B would apply, 

except for those that refer to use of aminopyralid.

The herbicide-use rates, pdfs, and herbicide-use buffers associated with aminopyralid would become nonapplicable. Much of the infested sites near streams and other water bodies would be spot treated rather 

than broadcast as directed by the herbicide-use buffers associated with herbicides other than 

aminopyralid. 

Of the 10 herbicides considered for use under alternative D, the first choice herbicides are most likely to 

be used. The herbicides sethoxydim, sulfometuron methyl, and triclopyr are the least likely to be used. 

Table 17. Summary of herbicide use under alternative D

First Year/First 

Choice Activity

Acres

Broadcast Herbicide 

Chlorsulfuron 435

Glyphosate 3

Metsulfuron 

methyl

69

Picloram 36

Total Broadcast 543

Selective/Spot by First-choice Herbicide 

Chlorsulfuron 595

Glyphosate 721

Metsulfuron 

methyl

238

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

First Year/First 

Choice Activity

Acres

Picloram 27

Total 

Selective/Spot

1581

Passive and Active Restoration

This component of alternative D would be the same as alternative B.

Treatment Flexibility and EDRR

This component of alternative D would be the same as alternative B, except aminopyralid would not be 

authorized for use.

Implementation Planning and Monitoring

This component of alternative D would be the same as alternative B, except aminopyralid would not be 

authorized for use.

2.4 Alternatives Considered but Eliminated from Detailed Study

During scoping, some people suggested alternatives that were considered but eliminated from detailed 

study because they either did not meet the purpose and need for action or were similar to an alternative 

considered in this document. 

2.4.1 Alternative to Evaluate Effectiveness of Past Treatments by a Third 

Party

One commenter suggests that effectiveness of past treatments must be evaluated by a disinterested party 

before new treatments would be implemented. This is an opinion not supported by law or policy and is 

outside the scope of the analysis in the EIS. It would not address the need for treatment flexibility or rapid 

response to newly detected infestations. It would not expand the treatment toolbox or bring the program 

into alignment with Malheur National Forest LRMP guidance. Therefore, this alternative was not 

developed for detailed study.

2.4.2 Limitations on Herbicide-use Rates for All Herbicides

Some people suggested that maximum rates of any herbicide should not be used in any circumstances. 

Limitations on certain herbicide ingredients, rates, and application methods are already part of the action 

alternatives to ensure that the adverse impacts of treatments are minimized. For instance, the lowest 

amount of herbicide necessary to meet treatment objectives is part of the design of all action alternatives 

and in some cases, rates have been specifically limited to address a specific human health or 

environmental concern. However, in some situations, maximum label rates could be needed for timely 

and effective treatment. Thus, a general limit on application rates was not considered for detailed study 

because it would not further minimize adverse effects but could impede treatment effectiveness. 

2.4.3 Mandatory Decline on Herbicide Use Over Time

Some people suggested an alternative requiring a mandatory decline in herbicide use over time. An R6 

2005 ROD objective is to reduce reliance on herbicides over time. This would be accomplished through 

effective treatment and restoration at any given treatment site. Our intent is to effectively treat invasive 

plants across the Forest until target populations are at a level that can be maintained with little or no 

herbicide (see chapter 3.1.4). However, due to uncertainty in funding and workforce capacity, the pattern 

of herbicide use over time cannot be precisely predicted. Thus, a mandatory decline on herbicide use each 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

year at the project level is not possible and would not meet the purpose and need for timely and effective 

treatments. 

2.4.4 Use of Herbicides as a Last Resort

Use of herbicides as a last resort was considered as an alternative in the R6 2005 FEIS and was rejected in 

the R6 2005 ROD (p. 27). This decision need not be reconsidered at the project scale. 

The Pacific Northwest Regional Forester decided to include use of herbicides as part of an integrated 

weed management approach to allow for the most effective possible treatment outcome. The common 

control measures (table 9) display the integrated treatment methods most likely to be effective on the 

target invasive species currently found on the Forest. Use of non-herbicide methods have not resulted in 

eradication, control, or containment of the current infestations. 

2.4.5 Use of Herbicides for Only the Highest Priority Target Species

Priority for treatment is a function of the invasive plant species as well as its size and location. Sitespecific integrated treatment objectives and methods vary depending on the location, size, and density of 

a given infestation. Thus, a prohibition on use of herbicides depending solely on target species would not 

allow effective treatment in all high priority situations. All action alternatives would only utilize 

herbicides as necessary to meet treatment objectives. Herbicides would not likely be used in any 

alternative where target species are widespread, and are effectively suppressed by non-herbicide methods 

such as biological agents. Thus, this alternative was not developed for detailed study. 

2.4.6 No Herbicide Use in a Variety of Areas

Some comments included a number of suggestions about prohibiting herbicide use in a variety of areas 

including: 

• PACFISH/INFISH Riparian Habitat Conservation Areas (RHCA), including wetlands, lakes, 

ponds, bogs, springs, fens, wet meadows, marshes, and in roadside ditches that funnel water to 

these areas; 

• Municipal watersheds; within rock surfaces and late-successional forests; within 100 feet of stock 

tanks; 

• Anywhere near sensitive plants; including non-vascular plants

• Habitats for silver-bordered fritillary; sage grouse; Harney Basin duskysnail; Columbia clubtail; 

lynx; wolverine; Columbia spotted frog, upland sandpiper, greater sage grouse, and pygmy rabbit; 

wolf; and goshawk; 

• Within 500 feet of developed recreation sites; 

• Campgrounds, visitor centers, at trailheads or along trails; 

• Special forest product, cultural plant, medicinal plant gathering areas, other popular plant 

gathering areas (similar areas mentioned are: key areas of human plant consumption, such as 

where there are edible berries, flushes of medicinal herbs, indigenous people’s cultural plant 

gathering sites, and mushroom gathering areas, areas with plants frequently foraged for by 

humans); 

• Wilderness and potential wilderness areas, wild and scenic river corridors, and inventoried 

roadless areas.

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

In addition, comments mention that herbicide should not be used on certain invasive species, including St. 

Johnswort, Canada thistle, and bull thistle. When all of the areas are added together, this becomes an 

alternative very similar to eliminating herbicides from the treatment toolbox and would not meet the 

purpose and need for timely and effective treatment. 

2.4.7 No Early Detection/Rapid Response (EDRR)

Some comments suggested that new detections should be subject to additional NEPA analysis. A variation 

on this alternative is not using herbicide for EDRR, but allowing other treatment methods without 

additional NEPA analysis. An integrated treatment toolbox is necessary for EDRR to be effective. 

Additional NEPA analysis would not meet the need for timely treatments. Thus, this alternative was not 

developed for detailed study. The limitations on treatments, implementation planning process, pdfs, and 

herbicide use buffers proposed in the alternatives provide sufficient protections to ensure that treatments 

under EDRR would have effects within the scope disclosed in the EIS. 

2.4.8 Increase Size of Herbicide Use Buffers

Some comments suggested that the size of herbicide use buffers along streams be increased to take in the 

entire riparian habitat conservation area or up to 300 feet from any stream or water body. The site-specific 

modeling done for the project indicates that buffers of this size are not necessary because the alternatives 

already either minimize or eliminate herbicide from reaching streams, and in no case is the amount of 

herbicide concentration in the streams predicted to exceed a level of concern for fish. Thus, this 

alternative was not developed for detailed study.

2.4.9 No Herbicide Use

Some comments suggested an alternative that would treat invasive plants using all but herbicide methods. 

Alternative A would not approve any treatment, but non-herbicide treatments could continue under 

categorical exclusions and as actions connected to other projects. Alternative C minimizes use of 

herbicides and would require non-herbicide methods across the majority of currently infested sites. It 

includes an annual cap on herbicide use that is much lower than the other action alternatives and 

addresses many of the suggestions expressed in the scoping and DEIS comment letters. Thus, another 

alternative strictly limiting herbicide use was not developed for detailed study because of its similarity to 

alternatives A and C.

Use of non-herbicide methods alone have not resulted in eradication, control, or containment of the 

current infestations. For fish and wildlife habitats, disturbance from non-herbicide methods that require 

more repeated entries could have greater effects than the herbicide use proposed. For instance, nonherbicide methods (e.g., pulling), especially within riparian areas, pose a greater risk of sediment delivery 

due to increased soil disturbance (chapter 3.6 and 3.7).

2.4.10 No Use of Certain Herbicides

Some public comments mentioned specific herbicides that should not be used on this project. These 

include: clopyralid, chlorsulfuron, glyphosate, the Roundup® formulation of glyphosate, imazapic, 

imazapyr, metsulfuron methyl, sethoxydim, sulfometuron methyl, picloram, and triclopyr. All of these 

herbicides were authorized for use in the R6 2005 ROD. 

If these herbicides were not approved, the effectiveness of the herbicide use would be hampered and the 

purpose and need for treatment would not be met. Some of these herbicides are the first choice for target 

invasive plant species found on the Forest (e.g., chlorsulfuron). Some are not the first choice, but are 

effective options should the first choice be found ineffective on some target species or locations (e.g., 

clopyralid, glyphosate, imazapyr, picloram, triclopyr). Some are effective on species that are not among 

the primary target species found on the Forest but may be treated in special places (e.g., sulfometuron 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

methyl is effective on medusahead). The more herbicide choices available, the more likely that the 

treatment will be effective

Picloram would not be used under alternative C. With this exception, the analysis considers the use of all 

of the herbicide choices in all action alternatives. The pdfs and herbicide use buffers provide guidance on 

where and how these herbicides may be used. Limitations on extent, rate, and method of application allow 

for the use of the most effective herbicide choice, while minimizing the potential adverse effect. Thus, 

alternatives to drop use of certain herbicides (with the exception of picloram) were not developed for 

detailed study. 

2.5 Alternatives Compared

Table 18. Alternative comparison by activity

Activity Alt A

(No Action)

Alt B

(Proposed 

Action)

Alt C

(More 

Restrictive 

Herbicide Use)

Alt D

(No LRMP 

Amendment)

Authorizes EDRR No Yes Yes Yes

Non-herbicide 

treatments

None18

Non-herbicide 

treatments 

would be 

integrated with 

herbicide 

treatments

Same as 

Alternative B, 

except only nonherbicide 

treatments would 

be approved 

within 100 feet of 

water bodies

Same as 

Alternative B

Maximum acres of 

proposed herbicide 

treatments during any 

year of 

implementation

0 2,124 735 Same as 

Alternative B

Number of herbicides 

available for use 0 11 10 (no picloram) 10 (no aminopyralid)

Forest LRMP

amendment to include 

aminopyralid

No Yes Yes No

Herbicide application 

rate and method None

Lowest 

effective rate, 

broadcast

sprayers may 

be used where 

needed 

according to 

pdfs

Application rate 

would not exceed 

70% of typical 

broadcast rate, no 

boom or 

broadcast 

sprayers

Same as 

Alternative B

except no 

aminopyralid

Biological control 

agents

Biological 

control 

agents may 

be released 

or 

redistributed

No biological 

agents would 

be released 

within the 

Forest 

boundaries

Same as 

Alternative B

Same as 

Alternative B

18 The analysis in chapter 3 assumes that no action means no invasive plant treatments will occur. Prevention would 

continue, and biological agents distributed in adjacent lands would naturally distribute to host species within the 

Malheur National Forest.

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Activity Alt A

(No Action)

Alt B

(Proposed 

Action)

Alt C

(More 

Restrictive 

Herbicide Use)

Alt D

(No LRMP 

Amendment)

Invasive Plant 

Prevention Measures

Same as 

Alternative 

B

Prevention 

measures are 

included in all 

land use 

assessments 

and projects to 

prevent the 

introduction 

and spread of 

invasive plants.

Same as 

Alternative B

Same as 

Alternative B

Table 19 displays a comparison of the first year/first choice herbicide for each alternative. All action 

alternatives (B-D) would approve a range of treatments on all 2,124 currently infested acres. Alternative 

C is the only action alternative that would disallow herbicide use in specific areas to the degree that nonherbicide treatments would be the only methods allowed for these sites. Under alternative A (no action), 

no treatments would be approved. However, biocontrol agents released on neighboring lands would 

continue to help suppress toadflax, St Johnswort, and other invasive plants on the Forest. 

Table 19. Comparison of first year/first choice herbicide by alternative

First Year/First Choice 

Treatment

Alt A

(No Action)

Acres

Alt B

(Proposed Action)

Acres

Alt C

(More Restrictive 

Herbicide Use)

Acres

Alt D

(No LRMP 

Amendment)

Acres

Total for All Broadcast

Applications

0 1,281 0 0

Aminopyralid 0 1,179 0 0

Chlorsulfuron 0 71 0 435

Glyphosate 0 0 0 3

Metsulfuron

methyl

0 30 0 69

Picloram 0 0 0 36

Total for All Spot/Selective 

Applications

0 843 735 1,581

Aminopyralid 0 168 560 0

Chlorsulfuron 0 519 142 595

Glyphosate 0 0 0 722

Metsulfuron

methyl

0 156 33 238

Picloram 0 0 0 27

No Herbicide Application 0 0 1,389 0

Figure 5 displays how these treatments are distributed within one Forest area. 

Table 20 provides a comparison of the alternatives relative to the issue measures described in chapter 1. 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Figure 5. One area of the Forest showing treatment distribution

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Table 20. Alternative comparison relative to significant issues

Issue Component Unit of Measurement Alt A

(No Action)

Alt B

(Proposed Action)

Alt C

(More Restrictive 

Herbicide Use)

Alt D

(No LRMP 

Amendment)

1 – Treatment Effectiveness

Restrictions on herbicide 

use reduce treatment 

effectiveness and 

increase treatment costs.

Average Cost per Acre of 

Effective Treatment of 

Known sites (includes retreatments and restoration)

0 $544 $722 $598

Total Cost of Effective 

Treatment of Know Sites 

(includes re-treatments 

and restoration)

0 $1,154,000 $1,472,900 $1,270,500

Ability to meet treatment 

objectives

Will not meet 

objectives

Tools adequate to meet 

treatment objectives

Tools may not be 

adequate to meet 

treatment objectives, 

especially near riparian 

areas

Tools adequate to meet 

treatment objectives, 

however opportunities to 

use most effective 

herbicide or application 

method may be forgone

2 – Herbicide Impacts to Human Health

Human health may be 

harmed by herbicide 

exposure.

Type (rate, method, 

chemical properties) and 

extent of herbicide use that 

could result in harmful 

exposure scenarios to 

people.

None

None of the herbicides

proposed for use are 

associated with harmful 

scenarios to the public.

Pdfs minimize or eliminate 

potential for harmful 

exposure by limiting the 

herbicide ingredient, rate, 

or method of application.

Workers need to take 

specific precautions to 

avoid herbicide exposure. 

Same as Alternative B, 

except that far less 

herbicide would likely 

be sprayed annually. 

The minimal risks 

associated with 

herbicide use under 

Alternative B would be 

further reduced. 

Same as Alternative B.

Where necessary, pdfs

minimize or eliminate 

potential for harmful 

exposure scenarios.

Qualitative assessment 

about the effectiveness of 

herbicide-use buffers and 

other project design 

features to prevent harmful 

herbicide exposure 

scenarios

None

Risk assessments 

demonstrate that the type 

of herbicide use proposed 

poses relatively low risk to 

human health. The 

likelihood of harmful 

exposures is low, thus the 

design features have high 

likelihood of eliminating all 

potential adverse impacts 

Alternative C would 

have less risk of 

herbicide exposure 

overall, especially to 

fish and water, due to 

restrictions on herbicide 

use near water. The 

buffers would eliminate 

all potential herbicide 

exposure near streams. 

Same as Alternative B, 

except opportunities to 

use aminopyralid would 

be foregone and in 

some cases, higher risk 

herbicides would be 

used. However, more 

spot treatment and less 

broadcasting would 

occur, which could result

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Issue Component Unit of Measurement Alt A

(No Action)

Alt B

(Proposed Action)

Alt C

(More Restrictive 

Herbicide Use)

Alt D

(No LRMP 

Amendment)

from herbicide use. While this alternative 

includes some 

additional design 

features that would 

comparatively reduce 

risk of harmful herbicide 

exposure, the risk is 

already low.

in less herbicide 

exposure, partly 

because less herbicide 

can be applied per day 

so the daily treatment 

extent would likely be 

less. For the project as a 

whole, the design 

features minimize 

adverse impacts to 

human health from 

herbicide use. 

Potential for Herbicides to 

Affect Drinking Water None

Drinking water quality 

would not be adversely 

affected. Restrictions on 

herbicide use near drinking 

water and well intakes 

further minimize risk. 

Herbicide transportation 

and handling safety plan 

would minimize potential 

for an herbicide spill.

Same as Alternative B Same as Alternative B

3 – Herbicide Impacts on Non-target Vegetation 

Proposed herbicide use 

may harm non-target 

plants, specifically 

sensitive and other 

species of conservation 

concern, cultural use 

plants, and special forest 

products.

Type and extent of 

herbicide use within 100 

feet of botanical special 

species of conservation 

concern, cultural use 

plants, and special forest 

products.

None

Pdfs prohibit broadcast 

herbicide use within 100 

feet of sensitive plant 

populations. Spot

applications will be used 

within 100 feet of sensitive 

plant populations. The pdf 

for use of blue dye will alert 

special forest product 

gatherers of herbicide 

spray areas.

Same as Alternative B, 

less overall herbicide 

use

Same as Alternative B

4 - Herbicide Delivery to Water and Potential Impacts to Fish

Proposed herbicide use 

may result in chemicals 

reaching streams and 

other water bodies 

(through drift, leaching 

and/or run off) and may 

Type and extent of 

herbicide use within 100 

feet of streams and other 

water bodies.

None

Aminopyralid could be 

broadcast up to water’s 

edge; however, no adverse 

impacts on fish are 

expected because the 

amount of herbicide that 

Same as Alternative B, 

except no herbicides 

would be used within 

100 feet of streams and 

other water bodies. 

There potentially could 

Same as Alternative B, 

except comparatively 

more use of higher-risk 

herbicides relative to 

fish. pdfs minimize risks 

and differences between 

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Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Issue Component Unit of Measurement Alt A

(No Action)

Alt B

(Proposed Action)

Alt C

(More Restrictive 

Herbicide Use)

Alt D

(No LRMP 

Amendment)

adversely fish and their 

habitat. 

may reach streams is 

below a level that could 

harm fish. Herbicide-use 

buffers and other pdfs

reduce the rate, extent, or 

frequency of herbicide use 

that pose potential risks to 

fish.

be more sediment from 

non-herbicide methods 

required near streams. 

alternatives.

Qualitative assessment 

about whether or not, and 

how fisheries might be 

affected

No impacts

Water concentrations from 

site-specific model runs at 

highest risk sites 

demonstrate that levels of 

herbicide that could reach 

streams and aquatic 

organisms are at least 3 

orders of magnitude less 

than levels of concern for 

fish and habitat. Treatment 

methods may result in 

minor amounts of sediment 

reaching streams.

Same as Alternative B Same as Alternative B

5- Herbicide Impacts on Wildlife and Pollinators

Proposed herbicide 

use may result in 

harmful exposure to 

terrestrial wildlife 

(specifically species of 

conservation concern).

Type and extent of 

herbicide use within 

specific wildlife habitats for 

wildlife of conservation 

concern

None

This alternative has the 

most broadcasting, but the 

first-choice herbicides that 

would be used pose low 

risk to wildlife.

Spot application of 

herbicides would occur 

on 735 acres and the 

first-choice herbicides 

pose low risk to wildlife.

First-choice herbicides 

that pose a low risk to 

wildlife would be applied 

on 1,337 acres whereas 

moderate to risk firstchoice herbicides would 

be used on 787 acres. 

Less broadcasting than 

Alternative B, which 

reduces risk of drift.

Risk of HCB 

(hexachlorobenzene) 

contamination and effects 

on raptor eggs

None

No HCBs in first-choice

herbicides. Pdfs minimize 

risk to raptors to extremely 

low level.

Same as alternative B. 

No use of picloram 

reduces risk. 

Picloram is the firstchoice herbicide on 63 

acres, posing low risk of 

HCB’s; pdfs minimize 

risk to raptors to 

extremely low level.

Narrative assessment 

about whether or not, and None All first-choice herbicides pose a low risk to wildlife. 

Same as Alternative B, 

except greater risk of 

Same as Alternative B, 

except less broadcasting 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 2

Issue Component Unit of Measurement Alt A

(No Action)

Alt B

(Proposed Action)

Alt C

(More Restrictive 

Herbicide Use)

Alt D

(No LRMP 

Amendment)

how species of 

conservation concern and 

amphibians might be 

affected

Pdfs that restrict timing and 

application of herbicides in 

sensitive habitats will 

minimize or eliminate the 

likelihood for any species 

to receive a harmful 

exposure to herbicides or 

disturbance.

disturbance from nonherbicide treatments. and more use of 

herbicides that pose a 

comparatively greater 

risk to wildlife. 

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Chapter 3. Affected Environment and Environmental 

Consequences

3.1. Introduction 

3.1.1 The Effects Analysis

Chapter 3 discusses the existing condition within the project area and the direct, indirect, and cumulative 

environmental effects of the alternatives. 

• Direct effects are effects that occur at the same time and in the same general location as the activity 

causing the effects. An example of direct effects is the potential for herbicides to harm non-target 

plants during applications.

• Indirect effects are those that occur at a different time or location from the activity causing the effects. 

An example of indirect effects is herbicide that is unintentionally delivered to streams through 

leaching or overland runoff following one or more storms after treatment (see chapter 3.4 Soils and 

3.5 Water Resources).

• Cumulative effects result from the incremental impacts of the proposed actions/alternatives when 

added to other past, present, and reasonably foreseeable actions, on MNF and adjacent lands within 

5th field watersheds in the project area. Chapter 3.1.5 introduces the cumulative effect analysis found 

throughout chapter 3.

• Changes between Draft and Final – Each of the sections of chapter 3 describe modifications made 

since the DEIS was released.

The project area is the 1.7 million-acre Malheur National Forest (Forest), including 240,000 acres of the 

Ochoco National Forest (previously known as the Snow Mountain Ranger District, now managed as part 

of the Emigrant Creek Ranger District). The Strawberry Mountain Range, part of the Blue Mountains, 

extends east to west through the center of the Malheur National Forest. This range splits the Forest into 

two geologic provinces, the Columbia Basin to the north and the Great Basin to the south. The Malheur 

National Forest is bordered by the Wallowa-Whitman National Forest on the east, the Umatilla National 

Forest on the north, and the Ochoco National Forest on the west. Elevations on the Malheur National 

Forest vary from less than 4,000 feet to 9,038 feet on Strawberry Mountain. The result is a diverse and 

productive landscape of grasslands, sage, and juniper; forests of pine, fir, and other tree species; and 

mountain lakes and meadows. The northern part of the Malheur National Forest is drained by the John 

Day River System into the Columbia River Basin. The southern part is drained, principally, by the Silvies 

River System into the Great Basin, and by the Malheur River System into the Snake River. There are 

several lakes and reservoirs on the Malheur National Forest ranging in size from 1 acre to greater than 50

acres.

The project area lies in Grant (1,128,930 acres), Harney (523,066 acres), Baker (46,357 acres), Crook 

(9,726 acres) and Malheur (605 acres) counties. The Malheur National Forest is within a day’s drive from 

Portland, Oregon. Principal access routes are U.S. Road 26 and U.S. Road 395, winding two-lane, rural 

routes. Two main population centers are within the area: the John Day Valley from Dayville to Prairie 

City, and Burns/Hines.

Invasive plants need to be treated on 2,124 acres within the Malheur National Forest. If the Malheur 

National Forest Supervisor selects an action alternative, invasive plant treatments would be implemented 

over several years as funding allows, until no more treatments were needed or until conditions otherwise 

changed sufficiently to warrant this EIS outdated. Site-specific conditions are expected to change within 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

the life of the project; treated infestations would be reduced in size, untreated infestations would continue 

to spread, specific non-target plant or animal species of local interest could change, and/or new invasive 

plants could become established within the project area.

Chapter 3 discloses the effects of a range of treatment options applied to a range of site conditions to 

accommodate the uncertainty associated with project implementation. The analysis assumes that all 2,124 

acres of currently mapped infestations are treated for a period of 4-6 years until control objectives are 

met. However, given funding constraints, we are likely to treat fewer acres each year, and treatments are

likely to be needed over a longer period of time.

Assuming full and immediate treatment of all existing infestations, early detection/rapid response 

(EDRR) would likely be a very small part of the project. However, because the funding level would likely 

be too low to treat all existing acres, and because some of the primary target species are likely to spread 

along existing vectors (mainly roads), some of the lower priority existing infestations will not be treated 

in the near future. Treatment of new detections is one of our highest priorities in all action alternatives.

The common control measures (table 9), project design features (table 10) and herbicide-use buffers

(table 11 and table 12), and the implementation planning process (figure 4) provide sideboards that 

minimize and bound the potential for effects even though the suite of integrated treatments would vary 

each year.

Figure 2 in chapter 2 shows the current extent of invasive plants and their distribution through the 5th field 

HUC watersheds on the Malheur National Forest. Appendix A contains a report showing specific 

locations and descriptions of invasive plants within the 5th field HUC watersheds.

3.1.2 Herbicide Risk Assessments

The effects from the use of any herbicide depend on the toxic properties (hazards) of that herbicide, the 

level of exposure to that herbicide at any given time, and the duration of that exposure. Herbicide risk 

assessments were the basis for analysis in the R6 2005 FEIS, disclosing the potential for effects on nontarget plants, wildlife, human health, soils, and aquatic organisms. Risk assessments were done by 

Syracuse Environmental Research Associates, Inc. (SERA) using peer-reviewed articles from the open 

scientific literature and current Environmental Protection Agency (EPA) documents, including 

Confidential Business Information. Information from laboratory and field studies of herbicide toxicity, 

exposure, and environmental fate was used to estimate the risk of adverse effects to non-target organisms. 

See table 8 in chapter 2 for the list of current SERA risk assessments.

In addition to the analysis of potential hazards to human health from every herbicide active ingredient, 

Forest Service/SERA Risk Assessments evaluated available scientific studies of potential hazards of other 

substances associated with herbicide applications: impurities, metabolites, inert ingredients, and 

adjuvants. There is usually less toxicity data available for these substances (compared to the herbicide 

active ingredient) because they are not subject to the extensive testing that is required for the herbicide 

active ingredients under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

In some cases, toxicity data on inerts and adjuvants is produced to comply with other federal laws that 

regulate non-herbicide uses of these chemicals, such as the Federal Food, Drug, and Cosmetic Act.

The risk assessments considered maximum exposure scenarios including accidental exposures and 

application at maximum label rates. The project design features described in chapter 2 (table 10) abate 

hazards indicated by the assessments. Although the risk assessments have limitations (see R6 2005 FEIS 

pages 3-95 through 3-97), they represent the best science available. The National Academy of Science 

(NAS) stated: 

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

After 30 years of use and refinement, this risk-assessment paradigm has become scientifically 

credible, transparent, and consistent; can be reliably anticipated by all parties involved in decisions 

regarding pesticide use; and clearly articulates where scientific judgment is required and the 

bounds within which such judgment can be applied. The process is used for human-health and 

ecological risk assessments and is used broadly throughout the federal government. Thus, the 

committee concludes that the ... risk assessment ... process is singularly appropriate for 

evaluating risks posed to ecological receptors, such as listed species, by chemical stressors, such 

as pesticides” (NAS 2103).

The risk assessments specifically address forest product consumption; given the project design features, 

limited public exposure would be expected and even if inadvertent consumption occurred, the amount of 

herbicide a person may be exposed to would be below the threshold of concern. 

The risk assessment methodologies and detailed analysis is incorporated into references of conclusions 

about herbicide toxicology in this document.

Herbicide Toxicity Terminology 

The following terminology is used throughout this chapter to describe relative toxicity of herbicides 

proposed for use in the alternatives. Additional terminology has been added to this section since the DEIS 

was published.

Hazard Quotient (HQ)

The hazard quotient is the ratio of the estimated level of exposure to a substance from a specific pesticide 

application, to the level of the acceptable exposure or toxicity. A HQ less than or equal to 1.0 is presumed 

to indicate an acceptably low level of risk for that specific application.

Exposure Scenario

Exposure scenarios consider both the toxicity of a given chemical and the mechanism by which an 

organism may encounter it. The application rate and method influences whether a person, animal, or nontarget plant could be adversely affected by exposure to a particular herbicide.

Plausible Effects

The analysis in chapter 3 focuses on whether effects that are possible based on risk assessments are 

plausible, given site conditions, life history of organisms in an area, herbicide application methods, and 

other project design features. Project design features (table 10) are often used to minimize or eliminate the 

plausibility of effects indicated as possible in the risk assessments.

Lowest Observed Adverse Effect Level (LOAEL) 

The lowest dose of a chemical in a study, or group of studies, that produces statistically or biologically 

significant increases in frequency or severity of adverse effects between the exposed and control 

populations.

No Observable Adverse Effect Level (NOAEL)

Exposure level at which there are no statistically or biologically significant differences in the frequency or 

severity of any adverse effect in the exposed or control populations. 

No Observed Effect Level (NOEL)

Exposure level at which there are no statistically or biologically significant differences in the frequency or 

severity of any effect in the exposed or control populations. The “No Observed Effect Concentration 

(NOEC)” is synonymous with NOEL.

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

Reference Dose (RfD)

The RfD is a numerical estimate of a daily exposure to the human population, including sensitive 

subgroups, such as children, that is not likely to cause harmful effects during a lifetime. Referenced doses 

are generally used for human health effects that are thought to have a threshold or minimum dose for 

producing effects. The reference dose is also referred to as the level of concern, threshold of concern, and 

toxicity index. All of these terms refer to the exposure level or “dose” below which adverse effects are 

unlikely to occur. 

Risk Assessment Worksheet

Risk assessment worksheets are excel spreadsheets that calculate lower, central and upper bound 

estimates of hazard quotients for public and worker health, different types of wildlife, and aquatic 

organisms for project-specific herbicides and application rates and methods. 

Aquatic Label

Some herbicides are labeled by EPA for direct application in water. This project relies on the use of 

aquatic labeled herbicides for most applications within 15 feet of wet streams and other water bodies 

(aminopyralid is labeled for use to the water’s edge). Aquatic labeled herbicides are not necessarily less 

hazardous to aquatic organisms than other herbicides, but have been more extensively tested. Aquatic 

labeled herbicides are generally less hazardous to aquatic organisms than terrestrial formulations of the 

same herbicide. Aquatic labeled herbicides would not be favored over effective non-aquatic labeled 

herbicides that pose lower risk to aquatic organisms, assuming compliance with label requirements.

Bioconcentration (Bioaccumulation)

The increase in concentration of a substance in living organisms as they take in contaminated air, water, 

or food because the substance is very slowly metabolized or excreted (often concentrating in the body 

fat).

Herbicide Comparison Table

Table 21 was prepared by Bautista and Bulkin in 2008 and was updated between the DEIS and FEIS 

based on the project-level assessment using updated risk assessments. Please note that the risk 

comparison table indicates the relative risk of using any of the 11 herbicides proposed. These herbicides

[the 10 analyzed in the R6 2005 FEIS], used in accordance with the R6 2005 standards, pose relatively 

low risks to people and non-target organisms (R6 2005 ROD p. 8). First choice herbicides are in bold. 

The table shows that aminopyralid compares favorably with the other herbicides considered for use on 

this project. It provides a simplified display of the relative risk to people and the environment that does 

not incorporate the project design features, herbicide use buffers and other measures taken in the 

alternatives to reduce risk of herbicide exposure. Many variables influence site-specific degree of risk, 

including extent and location of treatment, application rate, and proximity to habitats of concern.

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Table 21. Herbicide risk comparison

Comparative

Risk Level Public Health Worker Health Non Target 

Plants

Aquatic 

Organisms Wildlife

Low

• aminopyralid

• imazapyr2

• metsulfuron 

methyl

• aminopyralid

• chlorsulfuron

• clopyralid

• glyphosate

• imazapic

• imazapyr

• metsulfuron 

methyl

• picloram5

• sethoxydim

• sulfometuron 

methyl

• clopyralid

• picloram

• sethoxydim

• triclopyr

• clopyralid

• imazapic 

• metsulfuron 

methyl

• aminopyralid

• chlorsulfuron

• clopyralid

• imazapic

• imazapyr

• metsulfuron 

methyl

• aminopyralid

Moderate

• clopyralid

• chlorsulfuron3

• glyphosate

• imazapic

• picloram

• sethoxydim

• sulfometuron 

methyl3

• triclopyr

• aminopyralid

• chlorsulfuron

• imazapic

• imazapyr

(somewhat 

selective)

• metsulfuron 

methyl

• sulfometuron 

methyl

• chlorsulfuron

• imazapyr

• sulfometuron 

methyl

• glyphosate

Higher • triclopyr4 • glyphosate

• sethoxydim

• glyphosate

• picloram

• triclopyr

• triclopyr

• picloram1

1 Picloram was moved from moderate to higher risk in the FEIS, because the updated risk assessment showed that acute and 

chronic effects occurred at the typical and highest application rates. 2 Imazapyr was moved from moderate to lower risk for public health in the FEIS based on updated risk assessment and analysis 3 Chlorsulfuron and metsulfuron methyl were moved from lower to moderate risk for public health in the FEIS based on updated risk 

assessment and analysis. 4

Triclopyr was moved from moderate to higher risk for public health in the FEIS based on updated risk assessment and analysis

5 Picloram was moved from moderate to lower risk for worker health in the FEIS based on updated risk assessment and analysis.

Incomplete and Unavailable Information 

This section was added to the EIS to articulate incomplete and unavailable information related to 

herbicide use. Any project involving herbicide use in a natural setting will contain many sources of 

uncertainty. The range of invasive plant species to be managed is large and compounded by the number of 

non-target species and diversity of ecological conditions in areas where treatment may occur. Data on 

herbicide toxicity and environmental fate is limited to those conditions and species tested for registration 

purposes and investigated by independent researchers. Available data on surfactants, inerts, and dyes is 

even more limited. It is not possible to obtain all the data necessary to significantly reduce this incomplete 

and unavailable information. For example, the sheer number of species and single herbicide test 

combinations is overwhelming.

Each rigorous laboratory test conducted to determine the toxicity of a chemical to an animal is extremely 

expensive. If we add to this data required to more adequately address synergistic, additive, or antagonistic 

effects from chemical combinations, it is not possible to obtain all data that would be relevant to making a 

decision. There is no way to assess all sources of chemical exposure and more precisely determine the 

potential risk of a cumulative effect.

In addition, invasive and native plants, wildlife, soil, and water bodies are dynamic resources that change 

locations and characteristics depending upon time, season, weather patterns, land use activities, random 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

events, and other influences. This limits our ability to precisely predict effects (e.g., amount and duration 

of herbicide exposures, spread, and impact of invasive plants, and nature or amount of background 

contamination) even if more toxicity information was available.

In response to this uncertainty, adverse effects to people and the environment are assumed to occur at 

doses well below lethal levels, using the best available models for predicting herbicide concentrations in 

water using worst-case scenarios, relying on widely used and accepted risk assessment methodology. The 

project design features, herbicide use buffers, and implementation planning process provide additional 

levels of caution in response to uncertainty.

Treatment Effectiveness

Each invasive plant treatment circumstance could respond differently to the integrated treatments 

proposed. The prescription for each site would vary depending on the pdfs, buffers, first choice, and other 

effective herbicides authorized for use, as well as other factors, such as treatment history and objective. 

The differences in treatment effectiveness described in chapter 3.1.4 are based on assumptions about the 

range of treatments available. In addition, treatment costs vary depending on the integrated treatment 

methods, specific chemicals used and their application method, and the size and distribution of the 

various treatment sites. 

Human Health

Toxicity data is not obtained on humans directly, but rather extrapolated from laboratory animals using 

standardized tests required by EPA. Human susceptibility to toxic substances can vary substantially. In 

response to this uncertainty, standard risk assessment methodology assigns uncertainty factors to toxicity 

data to account for extrapolation from laboratory animals and for sensitive individuals. However, some 

individuals may be unusually sensitive so individual susceptibility to the herbicides proposed in this EIS 

cannot be predicted specifically. Factors affecting individual susceptibility include diet, age, heredity, preexisting diseases, and lifestyle. In response to this uncertainty, project design features are proposed to 

reduce the likelihood or amount of exposure.

Plants

Data on the susceptibility of different non-target plant species and families to particular herbicides is 

conducted with agricultural crop species and not those that may better represent non-target plants in the 

natural environment. Specific locations of rare plants, as well as invasive plants, change from year to 

year, making it impossible to precisely predict risk from treatments.

The current analysis uses the best available science on susceptibility, herbicide drift, and risk assessments 

to determine likely effects. Required project design features, monitoring, and practical information and 

expert opinion are utilized in response to uncertainty.

Soil and Water Resources

Herbicide toxicity and fate varies with environmental variables, such as pH, temperature, and presence or 

absence of organic matter. These variables fluctuate widely depending upon season, weather, disturbance, 

adjacent land uses, and other factors, making precise predictions of existing conditions and effects 

impossible. Data on effects to soil organisms is limited and may not reflect the actual community of 

organisms present at any given treatment site.

In response to this uncertainty, the current analysis uses the best available scientific information on soil 

mapping, watershed analysis, water monitoring, and the best available predictive models for potential 

contamination and drift. In addition, project design features are applied to action alternatives to restrict 

herbicide ingredients, application method, and rate on certain soils and in proximity to water.

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Terrestrial and Aquatic Organisms (Fish and Wildlife)

Research has not been conducted on the effects of these herbicides to most free-ranging wildlife species, 

so the relevant data to specifically evaluate effects to different wildlife species is incomplete or 

unavailable. Specifically,

♦ Information about herbicide effects to reptiles, amphibians, and butterflies found in Region 6 is 

limited.

♦ Analysis of effects for any project involving herbicide use relies upon extrapolations from 

laboratory animals to free-ranging wildlife and controlled conditions to the natural environment.

♦ There are more data available for mammals than for birds, which require the use of mammal 

toxicity values in bird exposure scenarios for some of the herbicides considered in this FEIS.

♦ Very few studies are available on sublethal effects to fish from acute exposures. Of studies that 

are available, some indicate temporary effects at low herbicide concentrations (e.g., Tierney et al. 

2006).

Better estimates of risk could be calculated if laboratory data on the toxicity of the herbicides considered 

in this FEIS were available for more groups of animals and more individual species. We would have more 

information on the comparative sensitivities of different wildlife groups and the types of adverse effects 

that may occur in different species.

However, because of the dynamic nature of wildlife and their habitat (e.g., behavior, weather, nutrient 

availability, contaminant presence), significant uncertainties would remain for predicting short- and longterm reactions to herbicide presence in natural settings even if more laboratory data were available. The 

threshold of concern for wildlife and fish is set particularly low (a no effect or no adverse effect level, or a 

fraction of the lethal dose). This accounts for uncertainties about how herbicides affect wildlife and fish 

given multiple stressors. Risks are further minimized by the low extent of treatment, the herbicide use 

buffers and the project design features. 

Limitations notwithstanding, there is substantial scientific data on the toxicity of these herbicides to birds 

and mammals, as well as fish, amphibians and some invertebrates. The data is generated by manufacturers 

to meet EPA regulations before an herbicide may be registered for use, and by independent researchers 

that have published findings in peer-reviewed literature. This data is analyzed according to standard risk 

assessment methodology to reach a characterization of risk for each herbicide. 

3.1.3 Site Types

We stratified the existing invasive plant sites into “site types” to help characterize the pattern of 

infestation and make predictions about future spread (see section 3.1.5 for a discussion about vectors of 

invasive plant spread in the context of cumulative effects analysis). The majority of mapped invasive 

plant sites are within 50 feet of roads. This is due to two primary factors: 1) we often look for invasive 

plants along roads; funding for surveys off roads is limited, and 2) roads are a major vector for the spread 

of invasive plants. In the following table, if any part of an invasive plant site (polygon) meets the criteria, 

then that site falls within the given site type. The table also shows the number of actual acres that meet the 

criteria (portions of invasive plant sites that do not meet the criteria are excluded). Most of the infestations 

near streams are also along roads. About 25 acres of infestations do not occur within any defined sitetype.

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

Table 22. Site type criteria and acres

Site 

Type ID Criteria

Number of 

Infested 

Sites

Total Number Of 

Infested Acres If 

Entire Infested 

Acreage is Included

(within and outside 

criteria)

Number of infested 

Acres that Meet 

Criteria

(portions of infested 

sites)

1 Within 50 ft. of existing, not 

decommissioned roads 

2,252 1,868 1,178

2 Within 100 ft. of existing, not 

decommissioned roads 

2,495 1,950 1,491

3 Within 50 ft. of all roads including 

decommissioned roads

2,301 1,904 1,244

4 Within 100 ft. of all roads including 

decommissioned roads

2,552 1,983 1,572

5 Within 25 ft. of trails 91 94 21

6 Within 25 ft. from all streams and ditches 589 1,199 117

7 Within 100 ft. from all streams and ditches 1,045 1,389 462

8 Within wildfire boundaries < 30 years old 409 451 246

9 BAER Inventory (outside wildfire 

boundaries)

93 38 39

10 Within timber harvest boundaries less than

30 years old

1,467 1,419 729

11 Within 100 ft. of a recreation site 7 20 < 1

3.1.4 Treatment Costs and Effectiveness

This section addresses the cost and effectiveness of treatment and active site restoration under the action 

alternatives. The analysis assumes all infested acres are treated year 1, then re-treated annually until the 

infestation level across all treatment areas is very low. This would result in treatment and restoration of 

current infestations within a 4 to 6 year period. The project is likely to be implemented over a much 

longer time frame due to funding constraints. Changes between the draft and final EIS include clarifying 

assumptions for differences in the cost of the different alternatives and including information about the 

pattern of herbicide use expected at treatment sites.

The design of each alternative influences the cost of eradicating, controlling, and containing invasive 

plants on the Malheur National Forest. The effectiveness of each treatment is influenced by the tools 

available for use; the more tools available, the greater the potential effectiveness of the treatment. If the 

toolbox is restricted and some situations cannot be effectively treated, the percentage of target population 

killed each year can be dramatically decreased. 

On page 4-18, the R6 2005 FEIS notes, “In general, alternatives that have the widest variety of herbicides 

and herbicide families available for use have the greatest potential to result in effective treatments.” In 

contrast, when herbicide use is more restricted, “...fewer acres would likely be achieved at a constant 

budget, and the years to control increases proportionally” (ibid. page 4-21). Thus, a loss of effectiveness 

is likely if the most effective choice is not available for a given site.

Herbicide resistance may occur if one herbicide is used repeatedly in an area over a series of years (R6 

2005 FEIS, p. 3-94). More than one herbicide active ingredient may be needed to ensure that herbicide 

resistance does not occur. The repeated use of one herbicide could allow naturally resistant plants to 

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

survive and reproduce. As the number of resistant plants increases, the efficacy of the herbicide 

diminishes until the herbicide no longer effectively controls the invasive plant populations. To develop 

resistance avoidance strategies, long-term site plans should recognize which of the various herbicide 

families have available and effective herbicides if multiple applications are expected to be necessary. 

Integrated chemical and non-chemical controls are highly effective where feasible, because any surviving 

herbicide-resistant plants can be removed from the site.

A loss of effectiveness and efficiency would be expected where the first-choice herbicide or application 

method are not allowed due to a particular design feature (such as no broadcasting in alternative C and no 

aminopyralid use in alternative D). This would increase costs and could compromise our ability to control 

or eradicate populations of certain aggressive target species, such as thistles and knapweeds. The range of 

treatment options varies between the alternatives most widely in streamside treatment areas. 

Each treatment entry would reduce the size or density of treated populations. Invasive species specialists 

across the region have estimated that in each treatment entry, 80 percent of the existing target plants 

would be removed, assuming fully effective integrated weed management methods including herbicides

are available. This has been validated by experts outside the agency; reduction of around 80 percent of the 

target species is generally expected from forestland herbicide treatments; however, actual results can vary 

widely (Desser 2007, Miller 2014, Peterson 2014).

Results at any treatment site vary depending on factors such as treatment objective, the target species, the 

size of the infestation, and the seed bank in the soil. The estimate of 80 percent reduction each treatment 

entry is intended to provide a cost estimate assuming that on average, four treatment entries would be 

required, and that only a fraction of the existing target population would remain after each treatment 

entry. Remnant target plants and seed banks can remain for several years but after multiple entries, 

invasive plants at any given site would be substantially reduced. For instance, a 100-acre infestation 

effectively treated in year 1 would result in 20 acres needing treatment in year 2. These 20 acres treated in 

year 2 would result in 4 acres still needing treatment in year 3, and so on until the area needing 

retreatment becomes minimal. 

The model is intended to show how limitations on the available tools influences our ability to effectively 

treat invasive plants, and how this limitation results in an increase in time and cost to achieve treatment 

objectives. In some cases, treatment objectives may never be met depending on the degree of limitation 

applied to particular site.

For this analysis, we assume all infested sites are covered with 100 percent invasive plants, because 

density is a variable that changes rapidly and is unpredictable. The 80 percent estimate is not precise and 

the range of results varies widely depending on the target, how long the invasive population has been 

established, the objectives of treatment, and other conditions (monitoring results, funding, topography, 

soils, weather during time of treatment, and many other variables). No data exists to determine the precise 

monetary impact on the project due to various limitations on the treatment toolbox. Based on the available 

information, the estimates for the Malheur National Forest are intended to highlight the differences 

between alternatives relative to their cost-effectiveness.

Alternative B is by definition the most cost-effective alternative because it allows for the widest range of 

treatment tools. A consistent cost of $200 per acre was used regardless of treatment method. The sitespecific combination of methods and their juxtaposition vary depending on many factors and a more 

specific estimate is not available. Many treatments are integrated, and the Malheur National Forest does 

not have recent data on which to compare costs of different methods. In general, herbicide spot treatment 

would tend to be more expensive than broadcast; this cost difference would be magnified in larger areas 

with dense populations of invasive plants. Manual treatments tend to be more costly than herbicide 

treatments; this would be magnified in areas where invasive plants are dense and well-established. 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

Biological and mechanical treatments are the least costly; however, these treatments are often not 

adequate in themselves to meet the treatment objective. 

For this analysis, the difference in cost of the project for each action alternative is a function of the 

effectiveness of each alternative (and the likelihood of repeated treatments needed), rather than the base 

cost per acre of a given treatment method. For those areas in alternative C where herbicide use would not 

be approved, more treatment entries are likely, and the effectiveness (number of acres meeting objectives) 

would be reduced. Alternative C also would not allow broadcast treatment. This would increase the cost 

and number of entries needed to achieve treatment objectives for larger, denser populations of invasive 

plants. Alternative D would not allow for the most effective herbicide (aminopyralid) to be used in some 

areas, which would influence our ability to meet the treatment objectives, especially near streams where 

herbicide use buffers would limit the herbicides that could be used in lieu of aminopyralid. This would 

also amount to an increase in cost/number of treatment entries for some infested areas under alternative 

D.

Alternative Comparison

The alternatives vary as to the first year/first choice herbicides, and these differences influence cost and 

effectiveness over time. The more effective the first year/first choice herbicide, the less retreatment would 

be needed. The estimates of the impact of restrictions on herbicide use are based on professional 

judgment; no information is available to allow for a precise comparison.

The design of alternatives C and D require that non-herbicide, spot or hand treatments may be required 

for areas that would more efficiently be broadcast, which would increase the cost of treatment in that

alternative.19 The primary differences between the alternatives and the influence on cost-effectiveness are: 

1) Whether or not aminopyralid may be used as the first-choice herbicide. Aminopyralid is the 

first-choice herbicide to treat 1,350 acres (64 percent) of the primary target species found on the 

Forest. In alternative B, we could broadcast this herbicide almost everywhere needed on the 

Forest, including to the water’s edge. In alternative C, we would spot apply this herbicide to 560 

acres; however, no herbicide would be used within 100 feet of streams and other water bodies. 

We would not use this herbicide in alternative D. This increases the amount of spot or hand 

treatment required in alternative D due to the herbicide-use buffers associated with herbicides 

other than aminopyralid. The requirement to spot or hand treat, rather than have the broadcast 

tool, is estimated to decrease the effectiveness of each year’s entry from 80 percent to 40 percent.

Broadcast methods accomplish many more acres a day than spot or hand methods. Spot and hand 

treatments tend to require more labor as applicators must walk from spot to spot and then return 

to accommodate skips and gaps that are common with this type of treatment. On neighboring 

Forests, the estimates for cost differences between spot and broadcast treatment costs range from 

spot treatments being 25 percent more costly to more than double the cost (examples from other 

Forests are in the project record). This difference is magnified for places where broadcast is 

needed but prohibited. 

2) Restrictions on herbicide use and method. The herbicide application rates and methods approved 

influence our ability to effectively treat invasive plants. Alternatives B and D approve broadcast 

spraying and some use of herbicide near streams. Alternative C does not approve any broadcast 

spraying and does not allow more than 70 percent of the maximum herbicide label rate to be 

sprayed on a given acre. It also excludes herbicide use within 100 feet of a stream or water body.

19 This assumption leads to the greatest differences between alternatives compounded over time and provides a 

reasonable alternative comparison, but there are too many variables to more precisely predict the costs and 

effectiveness of treating invasive plants on the Forest over time. 

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

This is estimated to reduce effectiveness to 40 percent from 80 percent, in effect doubling the 

time and cost for this alternative. This is because 1) non-herbicide methods tend to be more 

costly and require more treatment entries to meet treatment objectives, particularly for species 

that are well established, more extensive, or more dense, and 2) spot and selective herbicide 

methods tend to be more costly than broadcast and would require more treatment entries to meet 

treatment objectives. On neighboring Forests, the difference in cost for non-herbicide treatments 

varied, with manual treatment being the most costly ($340 per acre in the R6 2005 FEIS). This is 

more than triple the cost of an average herbicide broadcast operation.

The effectiveness would decrease by half on the portion of alternative D that requires spot or 

hand treatment rather than allowing broadcast, due to the elimination of aminopyralid.

3) Whether or not picloram may be used. Alternatives B and D allow picloram and alternative C 

does not. Alternative D includes the use of picloram as the first-choice herbicide on 63 acres (or 

about 3 percent of the total infested acreage). Because alternative C does not approve the use of 

picloram, there will be an unquantifiable loss of effectiveness for those acres where picloram is 

one of the effective herbicides. About 1,697 (80%) of the existing infested acres are occupied by 

target species where picloram is listed as an effective choice (table 9, chapter 2); however, 

picloram would likely be the “second choice” herbicide on some of these acres.

Alternative A 

Under alternative A, no invasive plant treatments would occur, so no funds would be expended. However, 

invasive plants would continue to spread at a rate from 4 to 12 percent per year (R6 2005 FEIS and 

ROD). Prevention measures would be applied to new projects and ongoing activities, and would be 

expected to slow the rate of spread over time (ibid.); however, existing infestations would not be treated 

under this decision. The purpose and need for action would not be met and the degrading impacts of 

invasive plants would continue unabated. 

Isolated populations of invasive plants, particularly the knapweeds, Dalmatian toadflax, and sulphur 

cinquefoil, can quickly spread into adjoining forest lands if the canopy is opened up. Seeds of invasive 

plants can be carried some distance by passing traffic, equipment, wind, and animals. Alternative A 

continues the current risk for invasive plant propagules to spread. Chapter 3.1.5 lists associated activities, 

intensity, and frequency of disturbance and level of noxious weed propagule pressure. Since most of the 

current weed sites occur near roads, the risk for increased spread from lack of treatment is highest along 

these routes. Roads and recreation areas have perpetual disturbance, a non-natural habitat that favors 

opportunistic invasive species and a high rate of propagule pressure.

Alternative B 

Alternative B allows for the most effective, available treatment methods to occur on the existing 

infestations and future detections, thus the first year/first choice treatment for each infested area under 

alternative B is assumed to be 80 percent effective.

The analysis assumes all 2,124 acres within a year of this decision being signed (2015 or year 1). The 

majority of acres would be treated using herbicide; however, non-herbicide treatments would be used in 

combination with herbicide methods or alone, for larger infestations where containment is the treatment 

objective or for very small infestations. The following year 20 percent of the acreage would need to be 

retreated (425 acres in 2016 or year 2). These remaining acres would be subject to spread, so a rate of 10

percent spread per year was applied on the remaining acres. Thus, about 468 acres would be treated and 

given the 80 percent effectiveness on these acres; about 94 acres would need to be treated in 2017 (year 

3). Thus, about 103 acres would be treated in year 3 once 10 percent spread rate is applied. the analysis 

assumes these 103 acres would be reduced to about 21 acres by 2018 (year 4). Active restoration would 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

occur where necessary. Under this treatment assumption, the remaining infestation level would be very 

low after five years. 

Passive restoration would be adequate on most of the treated sites; however, some areas will need to be 

seeded, mulched, or planted once invasive species are removed. that the analysis assumes that cost of 

active restoration (mulching, seeding, planting) would be applied to areas where target species are dense 

and large enough to require broadcast herbicide application. This is a high estimate and passive 

restoration would likely suffice for many of these areas. However, this estimate accurately characterizes 

the potential for high costs of repeat treatments and restoration of invasive species over time. The 

surrounding vector of spread and propagule pressure would influence the need and extent of active 

restoration. Perpetual disturbance associated with recreation, livestock grazing, and roads could 

complicate restoration. 

In some cases, restoration of native vegetation would be part of another ongoing or planned project, such 

as road decommissioning, stream restoration, and restoration of yarding corridors associated with timber. 

Road closures could make restoration and long-term maintenance of invasive plants more difficult. 

Cooperative treatments between neighboring land owners and agencies involved with invasive plant 

management would increase the effectiveness of alternative B and ensure weed spread between land 

ownerships is properly abated. 

Table 23 shows the costs per year, total cost over a 4-year period, and average cost per acre to be applied 

to unpredictable new infestations that could be discovered and treated over the life of the project 

according to common control measures, pdfs, and subject to treatment caps. 

Table 23. Estimated treatment costs for alternative B

Acres 

Treated

Acres Remaining to Be 

Treated

Add 10% spread 

rate Cost Year 1

Year 1 2,124 425 468 $424,800

Year 2 468 94 103 $93,600

Year 3 103 21 23 $20,600

Year 4 – restoration 1,231 Maintenance level NA $615,500

Total $1,154,500.00

Average Cost per Acre with 

all activities included 

$544

Alternative C 

Alternative C restricts available treatment methods for both the existing infestations and future detections 

and thus reduces its effectiveness. The loss of the ability to use herbicides/broadcast spray in this 

alternative is estimated to reduce the effectiveness of treating all existing infestations to half of alternative

B based on these restrictions. This is based on the difference in cost between broadcast spray and other 

treatment methods (25 percent to 300 percent increase in comparative costs based on estimates from 

neighboring Forests) and the likelihood that more treatment entries would be required to meet treatment 

objectives (see discussion above). In addition, the potential effectiveness would be reduced due to the 

lack of picloram in the toolbox. The loss of the use of picloram would reduce our ability to effectively 

adapt to areas that do not effectively respond to aminopyralid or another first year/first choice herbicide.

The analysis assumes that all 2,124 acres within a year of this decision being signed (2015 or year 1). The 

following year, half of this acreage would still need to be treated and would be subject to annual spread.

Table 24 shows how this would compound over time and increase the life of the project cost. Restoration

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

costs are the same across the action alternatives. Cooperative treatments between neighboring land 

owners and agencies involved with invasive plant management would increase the effectiveness of 

alternative C.

Table 24 below shows the costs per year, total cost over a 6-year period, and average cost per acre to be 

applied to unpredictable new infestations that could be discovered and treated over the life of the project 

according to common control measures, pdfs, and subject to treatment caps associated with alternative C. 

Table 24. Estimated treatment costs for alternative C

Acres 

Treated

Acres Remaining 

to Be Treated

Add 10% spread 

rate Cost Year 1

Year 1 2,124 1,062 1,168 $424,800

Year 2 1,168 584 642 $233,600 

Year 3 642 321 353 $128,400

Year 4 353 177 195 $70,600 

Year 5 195 98 108 $39,000

Year 5 108 54 59 $21,600

Year 6 - restoration 1,231 Maintenance level NA $615,500

Total $1,533,500.00

Average Cost per Acre with 

all activities included 

$722

Alternative D 

Alternative D restricts available treatment methods for both the existing infestations and future detections 

and thus reduces its effectiveness. The loss of the ability to use aminopyralid in this alternative is 

estimated to reduce the effectiveness of treating about 1,347 acres. Since aminopyralid can be broadcast 

to the water’s edge and other herbicides cannot, about 738 acres would have to be spot applied in 

alternative D, rather than broadcast. This would increase the time and thus the cost of treating these acres.

The loss of aminopyralid itself would also have an effect on making alternative D less effective but this 

was not included in the economic analysis. The main effect of alternative D that was modeled is the 

difference in spot versus broadcast acreage. Restoration costs would remain the same as alternative B and 

C. 

The economic analysis assumes equal effectiveness between alternatives B and D for 1,386 acres (80% 

effective per year). However, it reduces the effectiveness by half for those 738 acres that must be spot or 

hand treated in alternative D (rather than broadcast sprayed) due to the herbicide-use buffers on 

herbicides other than aminopyralid that restrict broadcast spraying near streams. Spot treatment is 

considered half as effective as broadcast because of the greater amount of time spent by workers walking 

from invasive plant to invasive plant, rather than a uniform application. Where spot treatment is required 

for areas that are 100 percent covered by invasive plants (our analysis assumption for the currently 

mapped infestations), there will also likely be a need for increased entries due to the potential for skips 

and gaps when spot treating (Desser 2008). This reduces the overall effectiveness ranking for alternative 

D to 66 percent meaning that about one-third of the acreage would have to be retreated each year until 

target populations reach a maintenance level and can be restored. 

The analysis assumes all 2,124 acres are treated within a year of this decision being signed (2015 or year 

1). The following year 34 percent of this acreage would still need to be treated and would be subject to 

annual spread. Table 25 shows how this would compound over time and increase the life of the project 

cost and average cost per acre. Restoration costs are the same across the action alternatives. Cooperative 

treatments between neighboring land owners and agencies involved with invasive plant management 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

would increase the effectiveness of alternative D to ensure weed spread between land ownerships is 

properly abated. 

Table 25 below shows the costs per year, total cost over a 5-year period, and average cost per acre to be 

applied to unpredictable new infestations that could be discovered and treated over the life of the project 

according to common control measures, pdfs and subject to treatment caps associated with alternative D.

Table 25. Estimated treatment costs for alternative D

Acres 

Treated

Acres Remaining to Be 

Treated

Add 10% spread 

rate Cost Year 1

Year 1 2124 701 771 $424,800

Year 2 771 254 279 $154,200

Year 3 279 92 101 $55,800

Year 4 101 34 37 $20,200 

Year 5 – restoration 1,231 Maintenance level NA $615,500

Total $1,270,500.00

Average Cost per Acre with 

all activities included 

$598

Alternative Comparison

Table 26. Results of the cost-effectiveness analysis for alternatives 

Issue Indicator Alternative A Alternative B Alternative C Alternative D

Average Cost per Acre of Fully Effective 

Treatment (includes 4-6 years of retreatments and restoration)0 $544 $722 $598

Estimated Cost For Treatment and 

Restoration of 2,1,24 infested acres 0 $1,154,000 $1,472,900 $1,270,500

Ability to Meet Treatment Objectives Will not meet

Tools adequate 

to meet 

treatment 

objectives

Tools may not 

be adequate 

to meet 

treatment 

objectives, 

especially 

near riparian 

areas

Tools 

adequate to 

meet treatment 

objectives, 

however 

opportunities 

to use most 

effective 

herbicide or 

application 

method may 

be forgone

It is unlikely that the Malheur National Forest will be funded to treat all currently infested acres in a 

single year. Only a portion of the 2,124 acres currently needing treatment will likely be treated in year 1 

regardless of action alternative selected. The economic analysis allows a consistent basis to see the impact 

of differences in alternatives and provides an estimate of the cost of fully treating and restoring an acre, 

based on the metrics of existing infestations. The sooner effective treatment of existing infestations

occurs; the less likely large numbers of acres will need to be treated in the future. Funding and workforce 

capacity will dictate how many acres are treated under the auspices of this project.

In the action alternatives, herbicide use is expected to be greatest during the initial entry, and would 

decrease over time as the size and density of invasive plant populations decline. The majority of infested 

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

areas would be treated using herbicide the first year of implementation. However, over time, the 

proportion of non-herbicide to herbicide treatment would increase. This pattern would be most evident 

under alternatives B and D, especially if most or all of the existing invasive plant populations early in the 

life of the project. Under alternative C, less herbicide use would occur in the early years of 

implementation; however, the decline in herbicide use would likely be less pronounced over time because 

more visits would likely be necessary to meet treatment objectives. 

3.1.5 Introduction to the Cumulative Effects Analysis 

Introduction

Cumulative effects are the result of incremental impacts of the proposed actions/alternatives when added 

to other past, present, and reasonably foreseeable future actions, both on National Forest System lands 

and adjacent federal, state, or private lands (40 CFR 1508.7). The baseline for cumulative effects analysis 

is the current condition as described in the affected environment sections throughout chapter 3.

Management activities and actions on neighboring lands contribute to spread or management of invasive 

plants on National Forest System lands, and vice versa. The effectiveness of the proposed invasive plants 

treatment project would be increased if coordination with adjacent landowners treats invasive infestation 

across land ownerships. The cumulative effects analysis assumes that this cooperative, coordinated effort 

will continue, and the release of biological control agents on adjacent lands by the Oregon Department of 

Agriculture, as analyzed by Animal Plant Health Inspection Service (APHIS), will continue, regardless of 

alternative.

Herbicides are commonly applied on lands other than National Forest System lands for a variety of 

agricultural, landscaping, and invasive plant management purposes. Herbicide use occurs on tribal lands, 

state and county lands, private forestry lands, rangelands, utility corridors, road rights-of-way, and private 

property. No requirement or central reporting system exists to compile invasive plant management 

information on or off national forests in Oregon. Accurate accounting of the total acreage of invasive 

plant treatment for all land ownerships is unavailable. The estimates provided in this section are not 

precise and are uncertain given the long project life.

All invasive plant treatment methods have the potential to damage individual non-target plants, including 

sensitive species. Noise and worker activity can disturb wildlife and removal of vegetation can affect their 

habitat. If manual, mechanical, or herbicide treatments create bare soil, erosion can be accelerated. Small 

amounts of herbicide or sediment could reach surface water and impact water quality or aquatic 

organisms. All treatments have the potential to injure a worker or result in other accidents; and all 

treatments would create jobs and cost money. The potential for non-herbicide treatments to result in 

effects of concern to the public is very low and these effects are generally minor, small scale, and of short 

duration. The potential for cumulative effects from such treatments were discussed in the R6 2005 FEIS 

(pages 4-39, 4-50, 4-61 to 62, 4-89 to 4-90, and 4-122 to 123) and are incorporated by reference.

The issues for this project center on the effects of herbicide use or restrictions of herbicide use in the 

alternatives. Some people have expressed concern that herbicide use from this project could combine with 

herbicide use elsewhere and have an additive, synergistic, or other cumulative effect; specifically the 

effects on wildlife, fish, or people exposed to repeated doses of herbicides. The focus of the following 

section is on herbicide use; however, potential cumulative effects of non-herbicide treatment methods and 

other projects and land uses across and adjacent to the Malheur National Forest are discussed throughout 

chapter 3.

The relative scale of this project is so small that it is unlikely to contribute to measurable, detectable 

herbicide concentrations in downstream waters. Multiple herbicide exposures are unlikely to occur in 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

close enough proximity in time or space with other applications to trigger cumulative effects. The small, 

scattered nature of the infestations, the relatively low toxicity and potential to cause adverse effects 

associated with the herbicides proposed for use, the pdfs, herbicide-use buffers and treatment caps that 

limit the extent, intensity and duration of potential adverse effects, and treating invasive plants

cooperatively across administrative boundaries, all serve to minimize the potential for adverse effects to 

accumulate and amount to a measurable impact on people or the environment.

The various sections of chapter 3 address cumulative effects arising from treatment of invasive plant over 

the life of the project. Applications of herbicides and other integrated treatments would occur throughout 

the life of the project in all action alternatives. Chapter 3 discusses how the use of herbicides through the 

life of the project could further affect National Forest System lands on the Forest that are being impacted 

by ground disturbance. 

Counties are responsible for controlling noxious weeds along county roads and other county property 

outside of and within the Malheur National Forest. They also work with conservation districts, weed 

management areas, and watershed councils to control noxious weeds on private property. Three Bureau of 

Land Management (BLM) districts border the Malheur National Forest (Prineville, Burns and Vale). 

Invasive plant management, including herbicide use, occurs annually on the Burns and Vale units. The 

BLM contribution to cumulative effects from herbicide use is relatively low compared to other herbicide

use in Oregon (USDI Bureau of Land Management 2010).

Additive herbicide exposures are possible if herbicide is used on neighboring lands during the same day 

as planned on the Forest. Treatments occurring on National Forest System land, lands of other federal 

agencies, states, and counties would be coordinated so treatment overlaps are unlikely. Any molecules of 

herbicide that leave a treatment site will have time to dilute and degrade before mixing with another 

contaminant. The R6 2005 FEIS (p. 4-10) estimated 3 percent of the herbicide use within Oregon and 

Washington is on National Forest System land.

The R6 2005 FEIS (pages 4-1 to 4-3) and SERA Risk Assessments discussed effects of chronic exposure 

to low levels of herbicides used to treat invasive plants on National Forest System land. Chronic 

exposures do not result in cumulative effects because the herbicides are more rapidly excreted from 

organisms (people, animals, and fish) than would be absorbed from predicted levels of exposure. Thus, an 

animal could encounter herbicide in more than one location over time; however, herbicide exposures are 

unlikely to accumulate in the body of animals.

Statewide Herbicide Use

In 2007, approximately 284,984 reports of pesticide use were reported in Oregon. The top five active 

ingredients, by pounds, for the entire state were:

• Metam-sodium (42%) [soil fumigant]

• Glyphosate (9%) [herbicide]

• Copper naphthenate (7%) [wood preservative]20

• 1,3-dichloropropene (5%) [soil fumigant]

• Aliphatic petroleum hydrocarbons (4%) [insecticide]

Of these, glyphosate is the only herbicide. It was the second most-used active ingredient and accounted 

for 9 percent of all pesticide use reported statewide. The vast majority was agricultural use. Statewide 

20 The statewide pesticide use report for 2008 indicated that this value was overreported; this was the amount of 

diluted product, not the amount of active ingredient used.

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

reported glyphosate use was over 3.5 million pounds. In the John Day Basins alone, nearly 153,000 

pounds of glyphosate were reportedly applied. Glyphosate is quickly taken up by plants or bound up with 

soils so that it is not mobile in the environment soon after application. Effects of glyphosate from invasive 

plant treatments are very limited in time and space to the immediate area of the treatment. If vegetation 

adjacent to or emergent from flowing water is treated, glyphosate may be detected downstream from the 

treatment. However, it is very likely bound to organic matter and not biologically active and very unlikely 

to cause any effect. Therefore, glyphosate use from other lands in the water basins is not likely to cause 

cumulative effects when added to the direct and indirect effects of this project. Many of the proposed 

herbicides have limited mobility in the environment, so effects would be limited to areas immediately 

adjacent to the treatment sites; others, though mobile to some extent, have properties that bind them to 

soil particles or ensure rapid degradation, so do not pose a level of concern. Herbicide toxicity, mobility,

and persistence are managed through the project design features and herbicide-use buffers.

Three other herbicides proposed for use in the action alternatives are within the top 100 reported 

statewide in 2007: imazapyr, sulfometuron methyl, and triclopyr. None of these are first-choice herbicides 

in any alternative.

A pesticide use report was also published in 2009 based on statewide use in 2008. In the John Day basins, 

glyphosate was also the second most used pesticide, and again the only herbicide within the top five. 

Glyphosate accounted for 10 percent of the total pesticide use in the state in 2008, with 1,914,144 total 

pounds reported. In the John Day basins, glyphosate was the top pesticide used with a 105,040 total 

pounds reported, comprising about 44 percent of all pesticide use there. Another herbicide, 2,4-D was the 

second most used pesticide (67,572 pounds total). 

We are proposing a very low level of herbicide use compared to river basin or statewide use. The Forest 

Service contribution to cumulative herbicide use would remain low in all alternatives. No water quality 

issues related to pesticides have been identified in the waters in the project area (none of the streams in 

the area are 303d listed for chemical contamination). The site-specific modeling shown in Chapter 3.5.3 

indicates very small amounts of herbicide potentially reaching the stream. Any herbicide reaching the 

stream would be quickly diluted and as the herbicide moved downstream, it would become less and less 

likely to cause impacts.

NWQAP Pesticide Study

Since 1991, the National Water Quality Assessment Program (NWQAP) has implemented 

interdisciplinary assessments in 51 of the Nation’s most important river basins and aquifers, referred to as 

Study Units, and the High Plains Regional Ground Water Study. The USGS published a report: 

“Pesticides in the Nation’s Streams and Ground Water, 1992–2001” (Gillom and others 2006) that 

presented evaluations of pesticides in streams and ground water based on findings for the first decadal 

cycle of NAWQA. The study found that undeveloped streams had one or more detectable pesticides or 

degrades 65 percent of the time. The study stated that presence of pesticide compounds in predominantly 

undeveloped watersheds may result from past or present uses within the watershed for purposes such as 

forest management or maintenance of rights-of-way; uses associated with small areas of urban or 

agricultural land; or atmospheric transport from other areas. None of the herbicides proposed for use in 

this project were detected in the national samples (however it is acknowledged that glyphosate is widely 

used but was omitted from the study). 

The report discusses the many delivery mechanisms of pesticides to surface and ground water: 

Pesticides are transported to streams and ground water primarily by runoff and recharge. Nonpoint 

sources of pesticides originating from areas where they were applied—rather than point sources 

such as wastewater discharges—are the most widespread causes of pesticide occurrence in streams 

and ground water (Modified from Majewski and Capel 1995.) The atmosphere is often overlooked 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

as a source of pesticides, which return to earth with precipitation and dry deposition and can reach 

streams and ground water. Streams are particularly vulnerable to pesticide contamination because 

runoff from agricultural and urban areas flows directly into streams along with both dissolved and 

particle-associated pesticides. Ground water is most susceptible to contamination in areas where 

soils and the underlying unsaturated zone are most permeable and drainage practices do not divert 

recharge to surface waters.

The study also stated: 

Pesticide occurrence in streams and ground water does not necessarily cause adverse effects on 

aquatic ecosystems or humans. The potential for effects can be assessed by comparing measured 

pesticide concentrations with water-quality benchmarks, which are based on the concentrations at 

which effects may occur. No streams draining undeveloped land, and only one stream in a 

watershed with mixed land uses, had an annual mean concentration greater than a human-health 

benchmark.

This study supports the conclusion that this project, combined with other herbicide use on lands of other 

ownership, would not result in herbicide delivery to streams over a threshold of concern for people or the 

environment. The State of California also conducted monitoring on surface water where 40,631 pounds of 

active ingredient of 13 herbicides and 19 insecticides were applied within the privately-owned watersheds 

upstream of sampled locations. No detectable concentrations of any herbicides were identified (reliable 

detection limits ranged from 0.04 to 2.0 ppb). The analysis included glyphosate and triclopyr. The results 

could have been affected by several months passing between dry weather application and the first rain, 

potentially allowing chemical degradation or adsorption to soil; or dilution of stream flow between 

application and monitoring sites may have contributed to the lack of positive detections (Jones et al.

2000). 

Clackamas River Pesticide Study

Closer to the Forest, a study about the background levels of pesticides in surface waters was done on the 

Clackamas River, part of the Willamette River Basin in western Oregon. The pesticide occurrence and 

distribution in the lower Clackamas River Basin, Oregon, 2000–2005 (Carpenter et al. 2008) was done as 

part of the NWQAP.

The Clackamas study took place from 2000-2005. Within 119 water samples from the Clackamas River 

and its tributaries, 63 pesticide compounds: 33 herbicides, 15 insecticides, 6 fungicides, and 9 pesticides 

degradates were detected. Fifty-seven pesticides or degradates were detected in the tributaries (mostly 

during storms) whereas fewer compounds (26) were detected in samples of source water from the lower 

Mainstem Clackamas River, with fewest (15) occurring in drinking water.

The study stated that the two most commonly detected pesticides were the triazine herbicides simazine 

and atrazine, which occurred in about one-half of samples. It also said that the active ingredients in the 

“common household herbicides” Roundup® (glyphosate) and Crossbow® (triclopyr and 2,4-D) also were 

frequently detected together. These three herbicides often made up most of the total pesticide 

concentration in tributaries throughout the study area. 

The study stated that pesticides were most prevalent in the Clackamas River during storms and were 

present in all storm-runoff samples — averaging 10 individual pesticides per sample from these streams. 

Two tributaries contained 17-18 different pesticides each during a storm in May 2005. These mediumsized streams drain a mix of agricultural land (row crops and nurseries), pastureland, and rural residential 

areas. Two small streams that drain the highly urban and industrial northwestern part of the lower basin 

had the greatest pesticide loads. Streams draining predominantly forested basins contained fewer pesticide 

detections (2-5 pesticides). The study stated that pesticide use on the Mount Hood National Forest, which 

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

comprises most of the Federal land in the upper Clackamas River Basin, was a relatively insignificant 

contribution.

Invasive Plant Spread and Cumulative Effects

Invasive plant target species on the Malheur National Forest are predominantly annual and perennial forb 

species. Scotch broom, an invasive woody shrub, has limited occurrence in this dry habitat, preferring 

higher moisture and cool conditions on the western Cascade forests. Most of the forbs that are invasive on 

the Malheur National Forest have deep taproots to acquire water and nutrients (Kulmatiski et al. 2008). 

Annual plants such as the annual grasses do not penetrate deep into soil, but grow quickly during ample 

moisture and when nutrient levels are high (Eviner and Firestone 2007). Thus, these plants have high 

propensity to grow on disturbed areas where water-holding capacity and organic matter levels are low for 

most of the year except during the short nutrient-burst periods when moisture and cold temperatures are

not limiting.

The majority of the invasive plants on the Malheur National Forest have strong affinity to open light 

conditions and low shade tolerance. Thus, a strong correlation exists for invasive plants in recently 

deforested areas, road corridor openings, and open rangelands. The low shade tolerance of most the weed 

species found on the Malheur National Forest is evident in studies from the Rocky Mountains and eastern 

Washington. Studies of edge environments found substantial drops in weeds moving away from major 

roadways in shaded environments (Hansen and Clevenger 2005, Pauchard and Alaback 2006, Buonopane 

et al. 2013). The central Washington study found that invasive plants, many common to the Forest, on 

average did not penetrate further than 32 feet from the roadside where a forest canopy existed 

(Buonopane et al. 2013). Similarly, a Canadian study in eastern front Rocky Mountains observed 

substantial decrease in invasive plants 32 feet from a roadway in a forested environment as compared to 

about 490 feet in a rangeland environment. Field observations in the Malheur National Forest had a 

similar trend.

Cumulative Disturbance and Invasive Plant Spread

Disturbances that can be subject to weed invasion vary in frequency and intensity (James et al. 2010). A 

forest fire burning at high and moderate severity can completely eliminate the overstory and understory 

plant canopy and bare soil. The combusted organic material leaves a high nutrient load. Though the 

disturbance has high intensity, the spike in nutrient load and amount of exposed bare soil decreases 

rapidly within 5 years as the native vegetation recolonizes the site and the risk of weed invasion declines. 

In contrast, livestock grazing occurs every season. The scale of the disturbance can be much less intense 

than a damaging wildfire since grazing exposes a fraction of soil area compared to wildfire; however, the 

intensity of the grazing increases if cattle are concentrated in specific areas. 

Ground disturbance associated with natural processes, such as wildland fire, and human activities, such as 

road use, may favor the spread of invasive plants and discourage the reestablishment of native species. 

Seastedt et al. 2008 notes that human-caused disturbance can change soil conditions to which native 

species have adapted, resulting in conditions that favor invasive plants. Repeated road clearing and 

graveling, an open gravel pit, or a cleared compacted recreation area create environments that favor 

colonist species or vegetation that can optimize a large volume of soil with a taproot or species that 

germinate quickly, grow, and set seed during the limited growing conditions of the site. Roadside 

environments have coarser texture growing substrate with higher rock content and thus represent growing 

environments that favor invasive plants (Gelbard and Belnap 2003).Generally; disturbed environments 

have greater available resources for invasive plants because of exposed soil, open light, and higher 

nutrient and water availability. Shade under forest canopies substantially limits weed growth. Most of the 

primary target species on the Forest do not invade shaded environments.

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

The relationship between OHV trail use, travel access management, and the introduction, establishment,

and spread of invasive plants was discussed in the R6 2005 FEIS. Off-highway vehicle use can influence 

the spread of invasive plants by disturbing soil and carrying seed several orders of magnitude greater than 

‘conventional’ dispersal methods (R6 2005 FEIS p. 3-15). Vehicle traffic is considered the major vector 

for weed seeds since long stretches of roadways have invasive plants, and vehicles cover large distances 

picking-up and depositing seeds into new areas (Trombulak and Frissell 2000, Zouhar 2008, Flory and 

Clay 2009, Birdsall et al. 2011).

Invasive plant density drops in shaded environments (Hansen and Clevenger 2005, Pauchard and Alaback 

2006, Buonopane et al. 2013). Buonopane et al. (2013) found high rates of noxious weed seeds in the 

topsoil and litter layer well within the Malheur National Forest adjacent to infested roadsides. This 

indicates that invasive plants would be readily introduced to nearby disturbed areas even if no invasive 

plants were visible under the existing forest canopy. Roads and rights-of-way have the highest incidence 

of invasive plants due to perpetual disturbance together with a constant seed source from passing traffic 

(Zouhar 2008, Birdsall et al. 2011). The open light conditions inherent to roads creates ideal habitat since 

most invasive plants on the Forest do not tolerate shade. The road disturbance footprint has gravelly road 

fill emplaced next to dugout ditches, and bared cutslopes, open sites for invasive plants to establish. 

Roadways and railways fragment the landscape, creating edge environments where invasive plants can 

thrive (Hansen and Clevenger 2005).

Roads and traffic are primary vectors for invasive plant spread. Invasive plants are found where vehicle 

traffic congregates; recreation areas, parking lots, and where forest management activities concentrate at 

log landings. Road maintenance activities can also spread invasive plants from mowing and grading 

activities. Transplanted road materials from infested rock pits may carry weed seeds and plant parts into 

more remote locations of the Forest. Measures, such as using weed-free products and timing road 

maintenance to avoid spreading invasive plants, can help prevent invasive plant spread.

Roads vary for risk of invasive plants depending on their level of construction. The construction footprint 

extends from the roadside to the edge where the natural vegetation dominates. Typically, the edge of the 

roadcut demarcates the change when roads cross forests. Gelbard and Belnap (2003) documented an 

average 50-foot novel vegetation width along paved roadways compared to a 6-foot width along fourwheel-drive two tracks. The large unique vegetation span along the paved road coincided with the 

placement of fill and excavation. When comparing level of exotic plants, the researchers found a fourtime increase in cheatgrass along the paved roads versus the two-track road. A paved road also sheds 

water more effectively than low bermed primitive roads, creating high water and nutrient availability for 

exotic plant growth. Other authors report changes away from weedy roadside vegetation at an average 98 

feet in Illinois (Flory and Clay 2009) and 32 feet in east slope Washington (Buonopane et al. 2013) for 

forests along major roadways.

Streams have annual disturbance from fluctuating streamflow. Snowmelt flush bares stream edges leaving 

gravel bars and silt that is primary succession habitat. Invasive plants can easily occupy these sites, but 

the mesic conditions and well-adapted riparian vegetation readily compete to re-occupy these sites. The 

riparian vegetation forms a type of biotic resistance that damps the spread of invasive plants. The seed 

dispersal of invasive plants is periodic, and dispersed by streamwater, birds, and animals along the 

riparian corridor.

Grazing lands experience annual disturbance from livestock along with intermittent vehicle use that can 

bare soils in livestock congregation areas near troughs, salt licks, fences, and waterways. Plant parts may 

stick to animals and be transported into rangelands. The grazing activities on the Forest result in overall 

moderate level of disturbance and occur within a timeframe of less than 6 months per year. The moderate 

level corresponds to the small and distributed amount of disturbance across the allotment. However, some 

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

portions of allotments, including riparian areas, have been more seriously degraded. Disturbance from 

cattle can increase susceptibility to invasive plants. 

Vegetation clearing from fuels and logging activities disturbs soils from log yarding. Temporary 

transportation routes result in severe disturbance but lack annual traffic. The initial soil mixing from 

logging activities can lead to short-term increases in nutrient release (Booth et al. 2004). The available 

nutrients on these disturbed skid trails and lack of competing plants create ripe conditions for noxious 

invasive plants to spread. The sites remain open to infestation while native understory and overstory 

vegetation re-occupy the site in the initial period after logging for 1 to 3 years. However, the propagule 

pressure from vehicle traffic is limited to the logging activity.

Burned areas have conditions that favor invasive plant spread by eliminating competing plants and 

bolstering the nutrient availability (Zouhar 2008, James et al. 2010). The initial nutrient flush is a result of 

the thermal decomposition of burned vegetation combined with the subsequent further decomposition and 

release of nutrients by soil organisms (Hart et al. 2005). These conditions create extremely high invasion 

potential a few years following fire, but risk decreases over time as native vegetation recolonizes and 

nutrient levels drop (Zouhar 2008). Places of high heat from heavy fuels burning may favor invasion by 

Canada thistle and bull thistle. During field surveys of the Malheur National Forest invasive plant sites, 

Canada thistle was found to colonize old burned pile scars; the thistle has high tolerance for the alkaline 

and poor soil conditions associated with these severely burned areas (Korb et al. 2004, Meyer 2009). 

In burned areas, the risk for weed infestation decreases with time much like after timber harvest. The 

initial disturbance has much traffic from fire suppression followed by rehabilitation and possible salvage 

activities; although wildfire typically results in a much higher intensity disturbance than timber harvest 

from complete combustion of forest and shrublands during very dry hot conditions.

Prescribed fire results in low intensity burning that retains vegetation generally across 85 percent of the 

forest floor and leaves less than 15 percent soil cover. These are default values used in the Forest Service 

Water Erosion Prediction Project’s Disturbed WEPP application. Increased nutrient pulses result from 1 to 

2 years (Hart et al. 2005) but fewer disturbances create an overall low risk for invasion.

Table 27 displays potential disturbance frequency and intensity, and invasive plant propagule pressure 

associated with ongoing activities that are vectors for invasive plant spread. Disturbance frequency and 

intensity and propagule pressure strongly influences the rate that invasive plants are likely to spread along 

vectors. The most applicable R6 2005 ROD Standard dealing with preventing the spread of invasive 

plants via each vector is also shown. Prevention is an important aspect of our invasive plant management 

program. National policies and regional and local plans are in place to reduce the potential for invasive 

plants to become introduced, established, or to spread as a result of our activities. See chapter 3.1.4

Treatment Effectiveness for more information about how the location of infestations and surrounding 

vectors influence our treatment and restoration methods.

Table 27. Potential disturbance frequency for invasive plants spread

Vector

Disturbance 

Frequency/ 

Potential

Maximum Intensity

Potential 

Propagule 

Pressure

Most Applicable R6 Management Direction/

Prevention Considerations

Recreation sites 

management, dispersed 

and developed sites; 

campgrounds, hunter 

camps, trailheads

Perpetual/Low High

R6 Goal 1, Objectives 1.2; 2.4, 2.5; Standards

1, 4

outreach and education, travel management, 

recreation management

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

Vector

Disturbance 

Frequency/ 

Potential

Maximum Intensity

Potential 

Propagule 

Pressure

Most Applicable R6 Management Direction/

Prevention Considerations

Livestock grazing; 

Dry open grassland 

steppe, shrub lands, dry 

forestlands

Seasonal/Moderate

to High

Moderate to 

High

R6 Goals 1, 2; Objectives 1.2, 2.1, 2.2; 

Objective 5.3; Standards 4,6

AMPs and annual operating plans

Vegetation management 

(thinning and brushing,

logging, burning)

Periodic/High

(especially yarding 

corridors and 

landings, pile 

burning)

High

R6 Goals 1,2; Objectives 1.1, 2.1, 2.2, 

Standards 1, 2, 3, 13

Covering disturbed sites, particularly small burn 

areas, with fine to medium sized organic matter 

may prevent or reduce the size of some 

infestations, such as Canada thistle (see table 

8)

Wildland fire and 

incident response

Periodic/Low to 

High Moderate

R6 Goals 1, 2; Objectives 1.1, 1.3, 1.5 2.3; 

Standards 1, 2*, 3, 13

*although emergencies like wildland fire are 

explicitly exempt from this equipment cleaning 

standard, Forests report that it happens 

routinely.

Roads 

(road maintenance, 

construction, 

reconstruction, and use)

Perpetual/High High

R6 Goals 1,2; Objectives 1.1, 2.4, 2.5;

Standards 1, 2, 7, 8, 13

Forests report excellent coordination with 

engineering staff , quarries are inspected and 

road materials are weed free

Closing roads Periodic/Low Moderate R6 Goal 2; Objective 2.4; Standards 1, 2, 3, 13

Restoring roads and 

landings

One time/

Low to High Moderate R6 Goals 1, 2; Objective 1.1; 2.1, 2.4; 

Standards 1, 2, 3, 13

Adjacent agriculture Perpetual/Low Low R6 Goal 5; objectives 5.1-5.3

Stream restoration (i.e.,

fish passage and habitat 

projects, riparian 

vegetation restoration), 

Stream flow

Seasonal/High Low

R6 Goals 1, 2; Objectives 1.1, 1.3, 1.5, 2.1, 2.2; 

standards 1, 2 

Keep equipment working near streams clean

Mining, Minerals 

Exploration Low to High Low R6 Goals 1, 2; Objectives 1.1, 1.2, 2.1, 2.2, 

Standards 1, 3, 13

How Prevention Measures Integrated into Land Uses and Activities Influence Invasive Plant 

Spread

Prevention measures are intended to reduce the rate of spread of invasive plants from several vectors, 

including foreseeable future projects and ongoing types of activities described above. Rate of spread 

would be unlikely reach zero because some infestations are too large to be contained and some vectors are 

outside Forest Service control and some infestations. However, the action alternatives can reduce the seed 

sources within the Forest that are subject to invasive plant spread along with prevention measures applied 

to possible vectors of spread would work together to reduce the impact of invasive plants on and off the 

Forest. 

The treatment cost-effectiveness estimates in chapter 3.1.4 used a spread rate of 10 percent (R6 2005 

FEIS) as an average rate. If prevention measures reduce the rate of spread, the cost of each action 

alternative would be reduced because less acreage would need to be treated over time.

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Species and site-specific models do not exist to more precisely predict the rate of spread and the influence 

of prevention measures or the cumulative influence of prevention plus effective treatment. However, the 

R6 2005 FEIS (Chapter 4.2.3) discusses how adherence to the prevention standards along with effective 

treatments would reduce the future extent and impacts of invasive plants. 

Climate Change and Invasive Plant Spread

Global climate change may add stress to the ecosystems within the Malheur National Forest and increase 

susceptibility to invasives. Climate change is predicted to alter precipitation and seasonal temperature 

patterns, as a result of increased levels of atmospheric carbon dioxide (CO2) and other factors (Mote 

2004). Most recent studies on the interaction between climate change and invasive plants conclude that 

climate change is likely to favor invasive plant species to the detriment of native plant species for 

individual ecosystems (Chornesky et al. 2005, Climate Change Science Program 2008, Dukes and 

Mooney 1999, Hellmann et al. 2008, Pyke et al. 2008). In some studies, invasive plant species have 

demonstrated increased growth rates, size, seed production, and carbon content in the presence of 

elevated CO2 levels (Rogers et al. 2008, Rogers et al. 2005, Smith et al. 2000, Ziska 2003). Warming 

climates may remove elevational barriers to invasive plant distribution that currently exist. For instance, 

cheatgrass is becoming established in dry forests in the Intermountain West, particularly after wildfires 

and fuels reduction projects. After these events, native perennial grasses are lost, leaving potential 

cheatgrass habitat, which can increase fire frequency (Tausch 2008). 

Many invasive plants are species that can thrive in the presence of disturbance and other environmental 

stressors, have broad climatic tolerances, large geographic ranges, and possess other characteristics that 

facilitate rapid range shifts. In a simulation experiment, Kremer et al. (1996) found that a less productive, 

invasive grass community would tolerate climate change, whereas a native sagebrush community would 

not survive the increased temperatures. The predicted changes in climate are thought to contribute 

additional stressors on ecosystems, including those on National Forests, making them more susceptible to 

invasion and establishment of invasive plant species (Joyce et al. 2008). 

Climate change may affect invasive species differently. Bradley et al. (2009) found that rather than simply 

enhancing invasion risk, climate change may also reduce invasive plant competitiveness if conditions 

become climatically unsuitable. Climate change could result in both range expansion and contraction for 

some invasive plants in the western United States (potentially introducing invasive species that thrive in 

warmer conditions). Likely future conditions may also make management of invasive species more 

difficult. Treatments used on invasive plants may be less effective under various climate change scenarios 

and/or elevated CO2 (Hellmann et al. 2008, Pyke et al. 2008, Ziska, Faulkner, and Lydon 2004). 

Predicting how climate change will affect invasive plants, and invasive plant management, at the local or 

even regional scale is more difficult to deduce than are these general indications. Anticipated changes in 

the climate for the Pacific Northwest (e.g. more rain, less snow, warmer temperatures) (Mote 2004, Mote 

et al. 1999, National Assessment Synthesis Team 2000) or elevated CO2 may not be realized at a local 

area, particularly within the time frame of this analysis. Growth of invasive plants under elevated CO2

conditions will also be influenced by environmental conditions such as soil moisture, nutrient availability, 

and the plant community in which the invasive species occurs (Cipollini, Drake and Whigham 1993; 

Curtis, Drake, and Whigham 1989; Dukes and Mooney 1999; Johnson et al. 1993; Taylor and Potvin 

1997). The complex interaction of multiple and uncertain variables make site-specific predictions 

speculative. 

Most of the important elements of global change are likely to increase the prevalence of biological 

invaders (Dukes and Mooney 1999, Bradley et al. 2010). The Forest will likely become more vulnerable 

to the establishment of invasive plant infestations, however actual acreage affected by invasive plants 

could increase, and control strategies may become more difficult. Recommended management responses 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

to these predictions are early detection (resulting from regularly scheduled monitoring) followed by a 

rapid response to eradicate initial infestations (Hellmann et al. 2008, Joyce et al. 2008, Tausch 2008). 

Insufficient information exists to discern any meaningful differences between alternatives regarding the 

cumulative effects of the alternatives with respect to climate change. The action alternatives provide for 

early detection and rapid response to new invasives, which would help the Forest Service respond to the 

introduction or spread of invasive plants for the foreseeable future. 

Reasonably Foreseeable Projects on the Malheur National Forest

The Forest Service is proposing a variety of activities throughout the planning area, below is a listing of 

projects that foreseeably could overlap in time and space with invasive plant treatments. Additional 

ongoing projects may overlap with invasive plant treatment (for instance road, trail, and administrative 

site maintenance; and vegetation and habitat management and restoration).

The cumulative effects analysis addresses at the potential for the lingering impacts of invasive plant 

treatments to overlap in time and space with the effects of a particular project and cause additive, 

synergistic, or other impacts. The cumulative effects analysis also considers the ongoing activities 

described in the previous table. 

Table 28. Foreseeable future projects on the Forest with project details, vectors for invasive plant spread, 

watershed(s) affected, and implementation schedule

Project name Project Details Potential Vector Watershed(s) Implementation

Schedule

Bald Butte LO 

Decommission

Remove Lookout with 

explosives

Recreation Site 

Management Middle Silver Creek 2013

Bear Creek Riparian 

Juniper Thinning Thin 47 acres of juniper Vegetation 

Management

Upper South Fork 

John Day River 2014

Blue Mountain 

Snow Park

Clearing trees and leveling 7 

acres and paving parking 

area; construction of warming 

hut, restrooms, and grooming 

shed; construction of pad for 

fuel tank

Recreation Site 

Management

Summit Creek 

(170702030102) 2013

Buck and Rock 

Springs 

Campground 

Hazard Tree 

Removal Project

Remove hazard trees Recreation Site 

management

Upper Silver Creek 

and Wolf Creek 2013

Camp Creek LWD

Felling and placing entire 

trees ranging from 4- 20 

inches in diameter within the 

following streams and their 

associated Riparian Habitat 

Conservation Areas (RHCAs)

Stream 

Restoration

Upper Camp Creek 

(170702030205); 

Lick Creek 

(170702030205)

2013-14

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Project name Project Details Potential Vector Watershed(s) Implementation

Schedule

Campground 

Hazard Tree Project

Remove hazard trees in DLake, Idlewild, Joaquin Miller, 

Yellowjacket, Emigrant 

Creek, Falls Camp

Vegetation 

Management

Upper Silver, Upper 

Silvies, North 

Basin, Emigrant 

Creek

2013

Dairy EA

Commercial harvest, road 

closures and 

decommissioning

Vegetation 

Management Upper Silver Creek

2013-2014 road 

closures may go 

on for years

Damon

RX fire, commercial and noncommercial harvest, road 

closures and 

decommissioning

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings

Van Aspen-Silvies 

River 

(171200020105); 

Lower Scotty Creek 

(171200020104); 

Shirttail Creek 

(171200020301)

FY 11 to FY 13

Dragon's Head 

Plantation PCT thin plantations

Vegetation 

Management -

Ground 

disturbance, open 

canopy

Wolf Creek and 

Upper Silvies River

2013 and 

beyond

Dragon's Hump 

Plantation PCT

PCT and treat slash on 5000 

acres of plantations

Vegetation 

Management

Middle Silvies and 

Emigrant Creek

2013 and 

beyond

Egley Aspen 

Restoration Project

thin and remove conifers up 

to 20.9 inches in 20 acres of 

aspen

Vegetation 

Management Emigrant Creek 2013

Egley/Pine Springs 

Overlook 

Interpretive Display 

Update and Toilet 

Replacement 

project

replace toilet Recreation Site 

Management Middle Silver Creek

unknown, no 

funding, low 

priority

Elk 16

RX fire, commercial and noncommercial harvest, road 

closures and 

decommissioning, aspen 

restoration, aquatic 

restoration

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings, 

Stream 

Restoration

Elk Creek and 

Crane Creek 

Subwatershed

FY 2015

Galena Project

RX fire, commercial and noncommercial harvest, road 

closures and 

decommissioning

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings

Vinegar CreekMFJDR 

(170702030201); 

Little Boulder 

Creek-MFJDR 

(170702030202)

FY 14 to FY 17

Green Ant Project 

(Formerly the Ant 

and Emigrant 

Projects)

Commercial harvest, road 

closures and 

decommissioning

Vegetation 

Management Emigrant Creek 2013 and beyond

Idlewild Snowpark 

Relocation Project Relocate snowpark Recreation Site 

Management North Basin 2013

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Project name Project Details Potential Vector Watershed(s) Implementation

Schedule

Jane Hazardous 

Fuel Reduction 

Project

RX fire, commercial and noncommercial harvest, road 

closures and 

decommissioning

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings

Wolf Creek 2013 and 

beyond

JB Spring 

Development and 

Trough

Develop spring, thin 5 acres 

of juniper

Livestock Grazing,

Vegetation 

Management

Griffin Creek/Upper 

Malheur River 2013

Keeney Meadows 

Aspen

Non-commercial thinning and 

fencing 10 aspen stands

Vegetation 

Management

Bridge Creek 

(170702030105); 

Headwaters Long 

Creek 

(170702030401); 

East Fork Beech 

Creek 

(170702010802); 

Upper Camp Creek 

(170702030205); 

Headwaters Long 

Creek 

(170702030401);

July - Aug 2014

Logan Valley 

Grazing

Authorization

Grazing authorization on the 

Summit Prairie, Logan Valley, 

McCoy Creek, and Lake 

Creek Grazing Allotment

Livestock Grazing

Lake Creek, 

Bosenberg Creek, 

Upper Big Creek, 

Summit Creek 

Subwatershed

FY 2014

Malheur River 

Range Aquatics 

Projects

Extension of the Malheur 

River Drift Fence. Cross 

Springs water source 

reconstruction and extension 

to a second trough.

Development of Dollar Basin 

Spring

Livestock Grazing

Lake Creek and 

Bosenberg Creek 

Subwatershed

FY 2013

Marshall/Devine 

Hazardous Fuel 

Reduction Project

RX fire, commercial and noncommercial harvest, road 

closures and 

decommissioning

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings

Upper Silvies River 

and North Basin

2013-2014 road 

closures may go 

on for years

Murderer's Creek 

Juniper 

Management 

Project

Cutting of juniper and mixed 

conifer, fuel treatment, aspen 

restoration, and watershed 

improvement activities.

Vegetation 

Management; 

Stream 

Restoration

Deardorff Creek 

(170702010502); 

Corner CreekSouth Fork John 

Day River 

(170702010402); 

Lower Murderers 

Creek 

(170702010305); 

Lower Deer Creek 

(170702010206)

FY 2014

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Project name Project Details Potential Vector Watershed(s) Implementation

Schedule

Plantation 

Maintenance 

Fox/Camp Creek

Non-commercial thinning of 

plantations

Vegetation 

Management

Dixie Meadows 

(170702010602); 

Bear Creek 

(17070201603); 

Grub Creek 

(170702010607); 

Upper Beech Creek 

(170702010801); 

East Fork Beech 

Creek 

(170702010802); 

Lower Beech Creek 

(170702010803); 

Birch Creek 

(170702010905); 

Dry Creek-John 

Day River 

(170702010906); 

Belshaw Creek 

(170702011003); 

Cummings Creek 

(170702011005); 

Wiley Creek 

(170702020902); 

McHaley Creek 

(170702020903); 

Lower Fox Creek 

(170702020904); 

Upper Cottonwood 

Creek 

(170702020905); 

Upper Camp Creek 

(170702030205); 

Lick Creek 

(170702030206); 

Lower Camp Creek 

(170702030207)

FY 13 to FY 23

Plantation 

Maintenance Long 

Creek

Non-commercial thinning of 

plantations

Vegetation 

Management

Indian CreekMFJDR 

(170702030303); 

Slide Creek 

(170702030304); 

Granite CreekMFJDR 

(170702030305); 

Headwaters Long 

Creek 

(170702030401); 

Upper Long Creek 

(170702030402); 

Basin Creek 

(170702030404); 

Basin Creek 

(170702030406); 

Upper Deer Creek 

(170702021001); 

Upper Fox Creek 

(170702020901); 

McHaley Creek 

(170702020903)

FY 12 to FY 22

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Project name Project Details Potential Vector Watershed(s) Implementation

Schedule

Sawtooth and 

Emigrant Creek 

Culvert 

Replacement

replace culverts Stream 

Restoration Emigrant Creek

Sawtooth 

complete, 

Emigrant creek 

not, no funding, 

low priority

Sawtooth and Nicoll 

Checkdam 

Modification

modify existing structures Stream 

Restoration

Emigrant Creek 

and Upper Silver 

Creek

unknown, no 

funding, low 

priority

Schurtz Creek 

Story-Fry Riparian 

Restoration Project

Fence and thin conifers less 

than 21 inches

Vegetation 

Management Wolf Creek 2013-2014

Season of Burn 

Research Project Rx burn research units Vegetation Management

Pine Creek and 

Upper Silvies River

2013 and 

beyond

SF John Day 

Culverts 

Replacements

Replace 3 culverts Stream 

Restoration

Upper South Fork 

John Day River

2013 and 

beyond

Soda Bear

RX fire, commercial and noncommercial harvest, road 

closures and 

decommissioning

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings

Middle Bear Creek 

(171200020202); 

Lower Bear Creek 

(171200020204)

FY 13 to FY 15

South Fork John 

Day Riparian 

Juniper Thinning

Thin 90 acres of juniper Vegetation 

Management

Upper South Fork 

John Day River

unknown, no 

funding, low 

priority

Starr Aspen

Commercial and Noncommercial thinning, Rx fire, 

fencing, wood in streams, 

road closures

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings, 

Stream 

Restoration

Starr Creek-Silvies 

River 

(171200020102)

FY 15

Starr HFRA

RX fire, commercial and noncommercial harvest, road 

closures

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings

Starr Creek-Silvies 

River 

(171200020102)

FY 12 to FY 15

Summit

RX fire, commercial and noncommercial harvest, road 

closures and 

decommissioning, aspen 

restoration, aquatic 

restoration

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings, 

Stream 

Restoration

Summit Creek and 

Tureman Creek 

Subwatersheds

FY 2016

Thompson Butte 

SUP Passive 

Reflector Removal

remove reflector Recreation Site 

Management Pine Creek 2013

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Project name Project Details Potential Vector Watershed(s) Implementation

Schedule

UMF Culvert 

Replacement

Replacement of 15 culverts 

located on twelve tributaries 

in two watersheds of the 

Middle Fork John Day River 

subbasin.

Stream 

Restoration

Summit Creek 

(170702030102); 

Bridge Creek 

(170702030105); 

Vinegar CreekMFJDR 

(170702030205); 

Little Boulder 

Creek-MFJDR 

(170702030202); 

Granite BoulderMFJDR 

(170702030203); 

Balance Creek 

(170702030208)

July - Aug 2014

Upper Pine 

Hazardous fuel 

Reduction Project

RX fire, commercial and noncommercial harvest, road 

closures and 

decommissioning

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings

Pine Creek

2014-2015 road 

closures may go 

on for years

Voigt Ditch 

Headgate 

Replacement

Replacing current head gate 

with a new one including a 

measuring device and 

extending pipe down existing 

easement.

Adjacent 

Agriculture

Mill Creek 

(170702030106) July - Aug 2013

Whistle Prescribed

Burn Prescribed Burn 3450 acres

Ground 

Disturbance, open 

canopy

Upper Silver Creek unknown, low 

priority

Access and Travel 

Management

Designating roads available 

for use Road Use All On Hold

Under all action alternatives, some level of invasive plant control would occur on 2,124 acres, and of this, 

1,067 acres occur within watersheds where some future management activity is anticipated. Watersheds 

that contain mapped invasive plants and future management activities are displayed in table 29. However, 

through the life of the project, newly detected infestations in any watershed could be treated according to 

the alternative selected.

Table 29. Watersheds containing planned future activities and invasive plant treatments

Watershed Future

Activity1

Invasive Plant

Acreage2

Birch Creek P 1

Bosenberg Creek G 4

Bridge Creek T, R,G 26

Crane Creek T,B, 12

Deardorff Creek T 11

Dry Cr. John Day River P <1

Elk Creek T,B 24

Emigrant Creek T,R 44

Granite Boulder Creek R,P 120

Long Creek P 1

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Watershed Future

Activity1

Invasive Plant

Acreage2

Indian Creek P 1

Lake Creek G 3

Lick Creek G 8

Little Boulder Creek T,B,R 139

Long Creek P 18

Lower Bear Creek T,B 1

Lower Deer Creek T, 1

Lower Scotty Creek T,B 3

Middle Bear Creek T,B 2

Middle Silvies River R 6

Mill Creek R 145

North Basin T,B,F,R 15

Pine Creek B,R, 79

Slide Creek P 6

Starr Creek T,F,B 16

Summit Creek T,B,G 15

Upper Big Creek G 5

Upper Camp Creek G 14

Upper Deer Creek P 1

Upper Fox Creek P 22

Upper Long Creek P 18

Upper Malheur River P 45

Upper South Fork John Day River T 46

Upper Silver Creek T,B,R 20

Upper Silvies River T,B,F,R,P 56

Van Aspen-Silvies River T,B 15

Vinegar Creek T,B,R 81

Wiley Creek P,B,R 2

Wolf Creek T 38

Total Acreage Invasive Plants 1,067

1 – Activity Codes (T)-Timber harvest, (B)-Burning, (F)-Fuel Reduction, (R)-Recreation/facility, (P)-Plantation thinning, (G)-Grazing

improvements. 2 – Invasive plants that do not occur in watersheds with foreseeable future projects are not displayed.

The various resource sections of chapter 3 address cumulative effects arising from treatment of invasive 

plants over the life of the project given the foreseeable future projects on the Forest. Applications of 

herbicides and other integrated invasive plant treatments would occur throughout the life of the project in 

all action alternatives. The annual treatment caps in all alternatives limit the potential for direct, indirect

and cumulative effects by limiting the extent and intensity of impacts from treatment. Risks from 

herbicide use that may linger over time, such as persistence of herbicides in the soil, are managed through 

the project design features. 

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3.2 Human Health

3.2.1 Introduction

This section has been updated from the DEIS to reflect 1) updated risk assessment information for 

imazapyr, picloram and triclopyr, 2) additional analysis for herbicide application rates and methods that 

are specific to this project and incorporate project design features, 3) changes to project design features in 

response to public comments, and 4) new risk assessment technology that allows examination of 

additional human health exposure scenarios. The DEIS discussed risks associated with exposure to NPE 

surfactants. These risks have been eliminated because this class of surfactant would no longer be 

approved for this project in any alternative (pdf F1).

This chapter summarizes information from the R6 2005 FEIS and accompanying Appendix Q: Human 

Health Risk Assessment, which detailed the potential for health effects from non-herbicide treatments as 

well as the use of 10 of the herbicides proposed for this project, and is incorporated by reference in this 

EIS. Herbicide active ingredients, metabolites, inert ingredients, and adjuvants, and people with particular 

herbicide sensitivity were addressed. The R6 2005 ROD adopted standards to minimize herbicide 

exposures of concern to workers and the public based on the human health risk assessments. The 

herbicide risk assessments are updated on an ongoing basis; the glyphosate, imazapyr, picloram, and 

triclopyr risk assessments were updated in 2011. 

This chapter also discusses the proposal to add a new herbicide, aminopyralid. Aminopyralid poses low 

risk to human health and compares favorably to the herbicides approved in the R6 2005 ROD (table 21, 

chapter 3.1.2). The Aminopyralid Risk Assessment (SERA 2007) is the primary source of toxicological 

information.

Hazards normally encountered while working in the woods (strains, sprains, falls) are possible during 

herbicide and non-herbicide invasive plant treatment operations. Such hazards are mitigated through 

worker compliance with occupational health and safety standards and are not a significant issue for this 

project-level analysis. Non-herbicide treatments are routinely implemented on the Malheur National 

Forest and no extraordinary circumstances have been found requiring the need for additional human 

health analysis for manual, mechanical, biological, or cultural treatments. Although the action alternatives 

may rely on varying levels of non-herbicide treatments, the difference between the exposures to 

occupational hazards are negligible. For more information on potential effects of non-herbicide 

treatments, see the R6 2005 FEIS chapter 4.5.

The use of herbicide in the action alternatives would be according to label requirements, with further 

direction in Malheur National Forest LRMP as amended by the R6 2005 ROD for standards and project 

design features associated with the project. The risk assessments and project-specific risk assessment 

worksheets quantify expected exposures and calculate hazard quotients (HQ). These worksheets provide a 

range of values (lower, central, and upper) rather than rely on a single estimate. The upper exposure 

estimates are based on the maximum estimate for every exposure factor that is considered, which is very 

unlikely to occur in our operations (e.g., maximum application volume, maximum concentration in field 

solution, maximum volume of a spill, maximum residue rates on food items, maximum exposure rates, 

maximum hours worked). The upper exposure estimates are not reflective of the way herbicides would be 

used in this project and the probability of maximum exposures occurring is very low. Thus, the central 

and lower estimates provide more realistic risk assessment results; however, even considering central or 

lower HQ estimates, many of the exposure scenarios for the public are implausible or extremely 

conservative.

Slight exceedances of hazard quotients greater than 1.0 could cause clinically detectable physiologic 

changes, but are unlikely to produce any human health symptoms detectable by a person. Even 

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considering central or lower HQ estimates, many of the exposure scenarios for the public are implausible 

or extremely conservative.

The risk assessments and risk assessment worksheets consider potential impacts to children, women of 

child-bearing age, and men. In some cases, the reference dose (Rfd) varies between these groups. The Rfd 

is far less than the level thought to cause impacts, which provides an additional layer of caution to the 

human health assessment.

Regulatory Framework and Compliance 

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) established the United States system of 

pesticide regulation to protect applicators, consumers and the environment. It is administered by the 

Environmental Protection Agency and the appropriate environmental agencies of the respective states. 

The Federal Insecticide, Fungicide, and Rodenticide Act requires registration for all herbicides, after 

extensive testing, to evaluate whether a pesticide has the potential to cause adverse effects on humans, 

wildlife, fish, and plants, including endangered species and non-target organisms, as well as possible 

contamination of surface water or ground water from leaching, runoff, and spray drift.

When registered, a label is created to instruct the applicator on the proper usage of the material and 

required personal protective equipment. The EPA also must approve the language that appears on each 

pesticide label and the product can only be used legally according to the directions on the labeling 

accompanying it at the time of sale.

The Forest Service is authorized by FIFRA and the Cooperative Forestry Assistance Act to use pesticides 

for multiple-use resource management and maintenance of the quality of the environment as long as the 

actions comply with the National Environmental Policy Act and the Council on Environmental Quality 

regulations. Forest Service Manual (FSM 2150) and Forest Service Handbook (FSH 2109) provide 

direction on safe use of pesticides, including direction on storage and transport, and development of 

safety plans and emergency spill plans.

In addition to label requirements and direction contained in FSM/FSH, the Forest LRMP as amended by 

the R6 2005 ROD, programmatically approves the use of certain herbicides and adopted standards to 

minimize herbicide exposures of concern to workers and the public. See table 1 in chapter 1.7 for a list of 

these standards and chapter 3.1.2 for risk assessment terminology.

All alternatives comply with standards, policies, and laws aimed at protecting worker safety and public 

health. None of the alternatives would result in disproportionate impacts to low income or minority group.

3.2.2 Affected Environment 

The Malheur National Forest lies in a relatively remote part of Oregon; however, people live near, spend 

time in, work in, or depend on forest products from the Malheur National Forest (Forest). Some dispersed 

and developed recreation areas (trailheads, campgrounds, picnic areas, recreation sites) and traditional 

gathering and special forest product collection areas currently occur in or near the vicinity of invasive 

plant sites (please see chapters 3.3, 3.9 and 3.10 for more information). People engaged in forest activities 

could potentially be inadvertently exposed to herbicides from treatment of invasive plants in or near these 

areas. Hunting is by far the greatest recreational use on the Forest (chapter 3.9).

A variety of mushrooms, berries, roots, and herbs, some of which have cultural importance to traditional 

gatherers, occur on the Forest. Cultural plants are used for food and baskets and traditional gathering is 

essential to the maintenance of tribal traditions and culture. Gathering is also economically important. 

Gatherers return to the accustomed gathering areas of their ancestors to tend and harvest plants to be used 

for traditional purposes.

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

The Forest also issues permits for special forest products, such as firewood gathering. The possibility of 

herbicide exposure may be greater for people gathering forest products than the public. Firewood 

gathering often occurs on disturbed roadsides that also contain invasive plants.

Invasive plant infested sites are scattered throughout the Malheur National Forest and occupy about 0.1 

percent of the land area within the Forest. Invasive plant treatments on the Forest are implemented 

through Forest Service contracts or in partnership with county operations. Applicators are generally from 

the communities in and around the Forest, are licensed by the State of Oregon, and are well-trained in safe 

herbicide application and transportation practices. Licensed applicators are required to take ongoing

training in order to remain certified (ODA website 

http://www.oregon.gov/ODA/PEST/pages/licensing_index.aspx).

The Malheur National Forest has several formal agreements for use of drinking water. Chapter 3.5 (Water 

Resources) lists municipal watersheds, springs, and well intakes with formal agreements and the extent of 

invasive plants mapped within or near these areas.

3.2.3 Environmental Consequences

Worker Herbicide Exposure Analysis 

The risk assessments include analysis for both workers and the public. This section focuses on the risks to 

herbicide applicators. Herbicide applicators are more likely than the public to be exposed to herbicides, 

and may handle undiluted herbicide concentrate during mixing and loading. In routine broadcast and spot 

applications, workers may contact and internalize herbicides mainly through exposed skin, but also 

through the eyes, mouth, nose, or lungs. Worker exposure is influenced by the application rate selected for 

the herbicide, the number of hours worked per day, the acres treated per hour, the wearing of personal 

protective equipment (PPE), and variability in human dermal absorption rates.

The herbicides considered for use on this project can cause irritation and damage to the skin and eyes if 

mishandled. Eye or skin irritation would likely be the only overt effect because of mishandling these 

herbicides. These effects can be minimized or avoided by prudent industrial hygiene practices during 

handling. Worker exposure can be effectively managed through ordinary prudent practices, limiting the 

number of hours per day that workers are exposed to herbicide, and limiting the application rates and 

application methods for situations that may affect worker health. Herbicide labels indicate the personal 

protective equipment required for applicators. “Upper bound” hazard quotients for workers are intended 

to represent scenarios where workers are not following typical safety practices (SERA 2011a).

Accidental worker exposures are most likely to involve splashing a solution of herbicides into the eyes or 

on the skin. Two general types of exposure are modeled: one involving direct contact with a solution of 

the herbicide and another associated with accidental spills of the herbicide concentrate onto the surface of 

the skin. Exposure scenarios involving direct contact with herbicide solutions are characterized by 

immersing unprotected hands for 1 minute or wearing contaminated gloves for 1 hour. Workers are not

likely to immerse their hands in herbicide; however, the contamination of gloves or other clothing is 

possible.

Exposure scenarios involving chemical spills onto the skin are characterized by a spill onto the lower legs 

as well as a spill onto the hands. In these scenarios, it is assumed that a solution of the chemical is spilled 

onto a given surface area of skin and that a certain amount of the chemical adheres to the skin. The 

protection provided by clothing is not included in the assessment.

The herbicides proposed for use under all alternatives have little potential to harm workers. In most cases, 

hazard quotient (HQ) values are below the threshold of concern (HQ values are less than 1.0, even given 

unlikely upper bound estimates). For the rates and methods that would be approved in the action 

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alternatives, triclopyr is the one herbicide that is associated with HQ values greater than 1.0 for worker 

health. Triclopyr is not among the first-choice herbicide in any alternative.

For general worker exposure, the upper bound estimates HQ values range from 1.6 (triclopyr TEA) to 6 

(triclopyr BEE). Accidental exposure to triclopyr BEE can also have impacts that are more serious to the 

eyes. An upper bound estimated HQ of 7 was calculated for an applicator wearing gloves saturated with 

triclopyr BEE for one hour.

In addition, two herbicides, picloram and clopyralid, contain an industrial contaminant from the 

manufacturing process that is linked to cancer: hexachlorobenzene (HCB). Picloram contains a higher 

concentration of HCB than does clopyralid. One alternative (D) would use picloram as the first-choice

herbicide for about 63 acres. A worker applying picloram at the maximum application rate, treating 112 

acres in one day, and not wearing any protective clothing resulted in theoretical HCB exposure over the 

cancer risk threshold established by EPA. This is not plausible for this project because picloram would not 

be broadcast at the maximum rate (pdf F2) and personal protective equipment is required by the label. 

Thus, HCB exposure from this project would not increase risk of cancer to workers (SERA 2004b, 

2011c).

Public Herbicide Exposure Analysis

The public is unlikely to be affected by the herbicide use proposed in this project. The risk assessments 

provided hazard quotient estimates for accidental, operational, and chronic exposure scenarios. The 

reference doses for a child, woman, or man are conservative and account for uncertainty and sensitive 

populations. Few plausible scenarios exist that exceed even the most conservative threshold of concern 

for public health and safety. The potential for the public to be exposed to HCBs from the use of clopyralid 

or picloram was also considered; the use of these herbicides as proposed in this project would not result in 

increased cancer risk to the public (SERA 2004b, 2011c). 

Accidental Scenarios

Accidental exposure is unlikely to occur. The risk assessments provide hazard quotient estimates for two 

types of accidental scenarios: 1) direct spray, and 2) exposures from drinking water or eating fish from a 

pond where herbicide has been spilled. Direct spray scenarios include the exposed skin of a woman or 

child being directly sprayed. Spill scenarios include a child drinking out of a pond where spills have 

occurred, a man eating fish out of a pond where a spill has occurred, and a man from a subsistence 

population eating fish as a greater part of their diet from a pond where a spill has occurred. These 

scenarios are implausible because 1) applicators would not directly spray a person and 2) project design 

features limit the amount of herbicide that may be transported to daily amounts. Upper bound estimates a 

200-gallon spill; this is a greater amount than would be transported on the Forest given pdf G1 that limits 

the amount of herbicide that may be transported each day. The central and lower bound estimates include 

a smaller spill (100 and 20 gallons respectively).

Accidental Direct Spray

No person is likely to be directly sprayed given the broadcast, spot, and hand/select methods proposed in 

the action alternatives. An HQ of 1.4 is associated with the upper bound estimate for triclopyr BEE for 

this scenario. No HQ values greater than 1.0 are associated with this scenario for any of the other 

herbicides, even considering upper bound estimates. 

Accidental Spill Scenarios

Aminopyralid, chlorsulfuron, imazapyr, sulfometuron methyl, and metsulfuron methyl do not have HQ 

values that exceed 1.0 for any spill scenario, including a large spill of 200 gallons. HQ values are less 

than 1.0 for all herbicides proposed for use in the action alternatives for smaller spills (20 and 100 gallons 

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respectively). None of the fish consumption scenarios for any herbicide have HQ values greater than 1.0

for any herbicide proposed for use in the action alternatives. 

Some herbicides include upper bound HQ values greater than 1.0 are associated with a child drinking 1 

liter of water out of a pond where 200 gallons of herbicide have been spilled. These include clopyralid 

(HQ =2), glyphosate (HQ = 4), imazapic (HQ = 1.9), picloram (HQ = 1), sethoxydim (HQ = 1.6) and 

triclopyr (both formulations are associated with an HQ of 2 for this scenario).

A spill of this magnitude is not plausible and would be avoided by applying the pdfs, specifically G1 that 

limit the amount of material allowed to be transported to treatment sites, and requires spill planning and 

response. The potential risk of human health effects from any herbicide spill into drinking water would be 

avoided or mitigated by appropriate spill response identified in the spill response plan, periodic 

equipment inspections, and carrying an emergency response kit in vehicles transporting herbicides.

Acute Exposure – Contact with Vegetation

A person could brush up against sprayed vegetation soon after herbicide is applied. Such contact is 

unlikely because spraying occurs during the work-week (not on weekends), and public exposure would be 

discouraged during and after herbicide application through notification or signing. Contact with sprayed 

vegetation would not exceed a level of concern for any herbicide proposed for use in the action 

alternatives, even for the upper bound exposure estimates.

Eating Contaminated Vegetation or Fruit 

A person could be exposed to herbicide if they eat contaminated vegetation or fruit (including berries, 

mushrooms, or other plants). Upper bound estimates for acute exposure assume that a person would eat 

about 0.01 kg of contaminated vegetation or fruit per kg of body weight. Upper bound estimates for 

chronic exposure assume a person eats this amount for 90 days; however, the amount of herbicide residue 

on the vegetation or fruit would decline over time, so the doses received each day for the chronic 

scenarios are less than for the acute scenarios. A person is unlikely to consume this much vegetation 

collected from the Forest in a one-time or chronic basis. A person might eat this much fruit one time;

however, it is less plausible that they would eat this much for 90 days. 

Central estimates assume a person eats about 0.001 kg of contaminated vegetation or fruit per kg of body 

weight in a day (acute) or for a 90-day period (chronic). This amount of consumption is plausible;

however, the likelihood a person would eat any contaminated vegetation remains low given the extent and 

design of the project. These acute and chronic scenarios also approximate the effects of eating other 

contaminated products, such as mushrooms (Durkin and Durkin 2005).

Project design features include use of dye in spray mixes, public notification, posting of treatment sites, 

supplying information during the special forest products permitting process, and coordination with the 

Native American tribes. Contaminated plants would likely show obvious signs of damage over a 

relatively short period of time and are therefore not likely to be consumed (SERA 2007).

Acute scenarios for eating contaminated vegetation exceed HQ = 1.0 for upper bound estimates for 

glyphosate (HQ = 3), sethoxydim (HQ = 1.1), and both formulations of triclopyr (HQ = 4 for fruit, 27 for 

vegetation). HQ values for a person eating this much vegetation for 90 days (chronic) exceed 1.0 for 

upper bound estimates for chlorsulfuron (HQ = 4), clopyralid (HQ = 2), picloram (HQ = 2), and 

sulfometuron methyl (HQ = 4). Both the acute and chronic estimates involve a level of consumption that 

is implausible, especially given the design and extent of this project. These scenarios assume an adult 

consumes more than a pound of contaminated vegetation.

Aminopyralid, imazapic, imazapyr, and metsulfuron methyl are not associated with HQ values greater 

than 1.0 for any acute or chronic vegetation or fruit consumption.

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With the exception of triclopyr, hazard quotients greater than 1.0 for any acute or chronic exposures from 

eating contaminated vegetation or fruit were not found for the herbicides proposed at central estimates. 

The central estimate for triclopyr (TEA and BEE) for the acute scenario of a woman of child bearing age 

eating contaminated vegetation is HQ = 3. The amount of vegetation that would need to be eaten is 

plausible; however, this exposure scenario would be unlikely given the design and extent of the project. 

Drinking Contaminated Water

Acute and long-term exposures from direct contact or consumption of water following herbicide 

application were estimated for herbicide use rates for this project using the risk assessment worksheets. 

Along with the accidental scenarios previously described, risks from a child drinking water from stream 

contaminated with herbicide residues by runoff or leaching from an adjacent herbicide application are 

analyzed. None of the herbicides proposed for use in the alternatives are associated with HQ values 

greater than 1.0 for acute or chronic non-accidental exposure scenarios involving drinking water.

Drinking water sources would be further protected by pdf H9. Herbicide use would not occur within 100 

feet of wells or 200 feet of spring developments. Please see chapter 3.5 for information on drinking water 

sources.

Consuming Contaminated Fish 

Acute and long-term exposure scenarios involving the consumption of contaminated fish were evaluated 

using the herbicide concentrations in the contaminated water scenarios described. Acute exposure was 

based on the assumption that an angler consumes fish taken from contaminated water after adjacent lands 

were sprayed. Chronic exposures are assumed to occur over a lifetime of eating contaminated fish. 

Subsistence groups (e.g., Native Americans) were considered to have higher consumption rates of fish 

(exposure rates) than recreational anglers. Hazard quotients are less than or equal to 1.0 for all herbicides 

and exposure scenarios evaluated, including a lifetime of subsistence fishing. Please see chapters 3.5 and 

3.6 for more information about potential effects to water quality and fish.

Bioconcentration (bioaccumulation) was taken into account when determining exposures and resulting 

dose from eating contaminated fish. Bioconcentration at first increases with the length of exposure, but 

eventually reaches a constant maximum level. It is measured as the ratio of the concentration in the fish 

compared to the concentration in the water, referred to as the bioconcentration factor (BCF). A BCF less 

than or equal to 1 indicates that fish excrete a chemical faster than, or as fast as, they can absorb it and 

therefore no bioconcentration would occur. Of the 11 proposed herbicides, 3 slightly exceed a BCF of 1.0

(chlorsulfuron has a BCF of 1.5; sethoxydim, a BCF of 7; and sulfometuron methyl, a BCF of 7). 

Hexachlorobenzene has a high BCF of 2,000, ranging from 2,000-20,000. The 2011 risk assessment for 

picloram (SERA 2011c) quantitatively assessed chronic risk from HCB using a BCF of 20,000 for 

consumption of contaminated fish by subsistence populations. The HQ for carcinogenicity was 0.4; below 

the level of concern; however, because it occurs at such low levels in picloram (8 parts per million) and 

clopyralid (less than 2.5 parts per million) the risk from bioconcentration is low. The HQ for clopyralid is 

below the level of concern (clopyralid has much less HCB than does picloram) (SERA 2004b).

Swimming

Another exposure scenario is for a woman swimming in a stream adjacent to a sprayed area. None of the 

herbicides proposed for use have an HQ value greater than 1.0 for this scenario. 

Multiple Chemical Sensitivity

The following information was adapted from USDA 2012, Gypsy Moth Management in the United Sates, 

a Cooperative Approach, from public comment responses prepared by SERA. 

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Some people may suffer from Multiple Chemical Sensitivity (MCS), also referred to as Idiopathic 

Environmental Intolerances (IEI). In general, individuals with MCS report a variety of adverse effects 

from very low levels of exposure to chemicals (including herbicides) that are generally tolerated by 

individuals who do not have MCS. 

Forest Service risk assessments incorporate an uncertainty factor of 10 to account for sensitive 

individuals, which may or may not eliminate risk that an individual may suffer symptoms. However, the 

uncertainty factor for sensitive individuals addresses variability in tolerances within a normal population. 

Individuals reporting MCS assert, either explicitly or implicitly, that they are atypically sensitive. There is 

no current consensus on the diagnosis and cause of MCS. Until the etiology and pathogenesis of MCS has 

been clarified, associated symptoms and symptom complexes cannot be entirely ruled out. The Forest 

Service has no way to resolve concerns for MCS at the project level.

Endocrine Disruption

The Environmental Protection Agency has recently worked to establish appropriate tests and benchmarks 

for endocrine disruption effects. In 2009, they released a list of pesticides (based on the high potential for 

human exposure) that will be tested for potential to cause endocrine disruption. Glyphosate was the only 

herbicide considered for use on the Malheur National Forest that was included in the initial EPA testing. 

Current status of these studies indicate that some tier-1 studies for glyphosate have been finished, some 

will not be finished until 2014, and some tier-2 studies have been ordered. Results are not yet available. 

Potential effects to endocrine systems from chemicals are most often studied by evaluating toxic effects to 

estrogen, androgen, and thyroid hormone systems and changes in the structure of major endocrine glands 

(adrenal, hypothalamus, pancreas, parathyroid, pituitary, thyroid, ovary, and testis). In addition, the results 

of multigenerational studies can be indicative of potential endocrine disruption. Studies are lacking for 

most herbicides on the potential to bind to estrogen or androgen receptors. To the extent that data is 

available, the Forest Service risk assessments address endocrine effects for the proposed herbicides and 

are summarized here.

There is no evidence of direct effects to the endocrine system, nor reproductive or developmental effects 

from aminopyralid (SERA 2007), chlorsulfuron (SERA 2004a), imazapic (SERA 2004c), imazapyr 

(SERA 2011b), metsulfuron methyl (SERA 2004d), or picloram (SERA 2011c). One study found that 

chlorsulfuron produced a slight decrease in fertility index in rats in a 3-generation study when rats were 

fed 125 mg/kg/day, but other studies have not found adverse effects on reproductive systems (SERA 

2004a). Clopyralid, sethoxydim, and triclopyr have not been found to cause reproductive effects at doses 

that do not also produce direct maternal toxicity, suggesting a direct toxic effect rather than an effect to 

the endocrine functions (SERA 2001, 2004b, 2011c). Additionally, for imazapyr, EPA states in their 

review of toxicity data that there was no evidence of estrogen, androgen, and/or thyroid agonistic or 

antagonistic activity (US EPA/OPP 2005). Some studies of sulfometuron methyl reported changes in rat 

testes, reproductive performance and in thyroid function (SERA 2004e). In specific reproductive studies 

with dietary exposures, there were no adverse effects to reproduction found (SERA 2004e).

Endocrine disruption and glyphosate was discussed in the updated Glyphosate Risk Assessment (SERA 

2011a). SERA 2011 stated that “some recent studies raise concern that glyphosate and some glyphosate 

formulations may be able to impact endocrine function through the inhibition of hormone synthesis 

(Richard et al. 2005; Benachour et al.2007a, b), binding to hormone receptors (Gasnier et al. 2009), or the 

alteration of gene expression (Hokanson et al. 2007)” (all references as cited in SERA 2011). Evaluation 

of the studies indicates that endocrine disruption effects were indicated for surfactants in the formulations 

rather than glyphosate itself. “Most of the in vitro studies... assayed both glyphosate as well as 

glyphosate formulations, and most of the studies clearly indicate that the biological activity of glyphosate 

is less than that of glyphosate formulations” (SERA 2011). The studies that raise the most concern were 

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from formulations not manufactured in the U.S. Based on the studies using formulations from outside the 

United States, “there is concern that glyphosate formulations may have an impact on these endpoints and 

that some of these effects could be seen under typical application conditions in the United States. In the 

absence of comparable studies on U.S. formulations; however, it is not clear whether the studies on 

glyphosate formulations used outside the United States are applicable to risks posed by U.S. formulations 

of glyphosate” (SERA 2011).

Additionally, there is a lack of specific information on the composition of different surfactants used in 

different formulations of glyphosate, as this information is identified as confidential business information. 

This lack of information limits the hazard identification for some toxic effects (SERA 2011). Given data

limitations, the current practice of risk assessment is to use very protective exposure and dose scenarios, 

which are used in the 2011 glyphosate risk assessment and this analysis. Until more data on surfactants 

becomes available, it is not certain that assessment relies on “the most toxic surfactant in the most 

sensitive species” for the quantitative analysis (SERA 2011).21

The risk for endocrine disruption would be greatly reduced by measures such as required use of proper 

protective equipment, public notification, use of licensed applicators, limiting application rates and other 

relevant pdfs. Results of herbicide risk assessments indicate that there is no evidence to suggest that these 

types of effects will occur from use of the proposed herbicides.

Environmental Justice and Disproportionate Effects

The R6 2005 FEIS suggested that Hispanic forest workers and American Indians may be minority groups 

that could be disproportionately affected by herbicide use. Hispanic and non-Hispanic herbicide 

applicators would be more likely to be exposed to herbicides than other people. Contractors for the Forest 

and/or County would likely implement herbicide treatments. County invasive plant control departments 

do not indicate that they employ any specific population group that could be disproportionately affected 

during invasive plant treatments. Regardless, effects to all County or contract employees engaged in 

invasive plant control would be negligible due to pdfs and compliance with occupational health and safety 

standards. The R6 2005 ROD (Malheur LRMP) requires that all herbicide application crews be 

supervised by a licensed pesticide applicator. 

No environmental justice concerns have been raised during government-to-government consultation with 

American Indian tribes. The likelihood of herbicide exposure to anyone is low, including subsistence 

gatherers. Cultural plants identified by the tribes would be buffered from herbicide use (pdf M1). 

On the Malheur National Forest, people of southeast Asian (Khmer, Khmer Krom, Laotian, and 

Vietnamese) descent are minority groups that tend to gather mushrooms. However, the season that 

matsutake are harvested is generally outside the timeframe that herbicides are used for treatments. 

Mushrooms are not invasive target species. Whenever herbicide treatment is scheduled to occur, the 

Forest will notify plant collectors and the public with media postings, handouts attached to permits, and 

on-the-ground signing. Information about invasive plant treatments may be added to the multi-lingual 

mushroom gathering permit material to eliminate inadvertent exposures. 

Given the design and extent of the project, minority forest workers, subsistence gatherers, and mushroom 

pickers are not likely to be exposed to an herbicide dose that exceeds a threshold of concern on this 

project. 

21 The potential for NPE based surfactants to cause endocrine disruption was discussed in the DEIS. A pdf was 

added to the project that eliminates use of NPE based surfactants (pdf F2). Thus, no potential for endocrine 

disruption from exposure to NPE surfactants would be associated with this project.

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Direct and Indirect Effects of Alternatives

Alternative A – No Action

No invasive plant treatments would be completed under alternative A, so there would be no effects on 

human health from this project. 

Alternative B – Proposed Action

Workers and the public may be exposed to herbicides used to treat invasive plants under this alternative. 

Few exposures exceeding a threshold of concern are predicted and adverse effects to human health are 

unlikely for this alternative. Table 30 lists specific pdfs in alternative B that address human health 

concerns. None of the first choice herbicides in this alternative are associated with HQ values greater than 

1.0. 

Table 30. Project design features in alternative B that minimize potential worker and public exposure to 

herbicides

PDF 

Reference Project Design Feature

B1 Coordinate treatments on neighboring lands and within municipal watersheds. For neighboring lands, base distances 

on invasive species reproductive characteristics, and current use. 

F1 Nonylphenol ethoxylate-based non-ionic (NPE) and ethoxylated fatty amine (POEA) surfactants would not be used. 

Vegetable oils/silicone blends that contain alkylphenol ethoxylate ingredients may be used. 

F2

The least amount of a given herbicide would be applied as necessary to meet control objectives. In no case will 

imazapyr use exceed 0.70 lbs. a.i./ac. Broadcast application of Clopyralid, Glyphosate, Picloram, Sethoxydim, or 

Sulfometuron methyl will not exceed typical rates across any acre. Spot spray of triclopyr would not exceed typical 

rates across any acre. 

F6 When herbicides are applied, a non-toxic blue dye will be used to mark treated areas. 

G

Herbicide Transportation and Handling Safety/Spill Prevention and Containment

 An Herbicide Transportation and Handling Safety/Spill Response Plan would be the responsibility of the 

herbicide applicator. At a minimum the plan would:

 Address spill prevention and containment.

 Estimate and limit the daily quantity of herbicides to be transported to treatment sites.

 Require that impervious material be placed beneath mixing areas in such a manner as to contain small spills 

associated with mixing/refilling.

 Require a spill cleanup kit be readily available for herbicide transportation, storage, and application (minimum 

FOSS Spill Tote Universal or equivalent).

 Outline reporting procedures, including reporting spills to the appropriate regulatory agency.

 Ensure applicators are trained in safe handling and transportation procedures and spill cleanup.

 Require that equipment used in herbicide storage, transportation and handling are maintained in a leak proof 

condition.

 Address transportation routes so that traffic, domestic water sources, and blind curves are avoided to the extent 

possible.

 Specify conditions under which guide vehicles would be required.

 Specify mixing and loading locations away from water bodies so that accidental spills do not contaminate surface 

waters.

 Require that spray tanks be mixed or washed further than 150 feet of surface water.

 Ensure safe disposal of herbicide containers.

Identify sites that may only be reached by water travel and limit the amount of herbicide that may be transported by 

watercraft.

H1 Follow herbicide-use buffers. Tank mixtures would apply the largest buffer as indicated for any of the herbicides in the 

mixture. 

K1

High use areas, including administrative sites, developed campgrounds, visitor centers, and trailheads would be 

posted in advance of herbicide application or closed.

Postings would indicate the date of treatments, the herbicide used, and when the areas are expected to be clear of 

herbicide residue.

See also L2 for special products and M1 for cultural plants.

K2 The public would be notified about upcoming herbicide treatments via the local newspaper or individual notification, 

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PDF 

Reference Project Design Feature

fliers, and posting signs. Forest Service and other websites may also be used for public notification. 

L2

Members of the public, who identify specific forest product collection areas, non-target edible or medicinal species 

they collect, or areas of cultural or spiritual value, will be informed about upcoming use of herbicide in the area. 

Specific edible or medicinal plant collection areas identified by the public would be prominently posted prior to 

spraying.

L4 Flyers indicating upcoming herbicide treatments and explaining the use of blue dye may be included with mushroom 

and special forest product collection permits, in multi-lingual formats if necessary. See section K.

M1

American Indian tribes would be notified annually as treatments are scheduled so that tribal members may provide 

input and/or be notified prior to gathering cultural plants. Cultural plants identified by tribes would be buffered as 

above for botanical species of concern; (see section I2, I3, and I4). 

Alternative C 

Under alternative C, compared to alternative B, there would be less use of herbicides and less risk of 

exposure associated with alternative C. Use of spot or selective treatments (no broadcast) would reduce 

the potential for vegetation or fruit to become contaminated with herbicide. Not using herbicide near 

streams would reduce risk of consuming contaminated drinking water or eating contaminated fish. The 

same project design features listed for alternative B would be implemented. Picloram would not be used, 

so there would be no possible risk to human health (risk is low in alternative B) from exposure to this 

herbicide. 

Alternative D 

Under alternative D, there would be increased use of glyphosate and picloram instead of aminopyralid. 

About 63 acres would be treated with picloram as a first-choice herbicide and about 725 acres of 

glyphosate would be the first-choice herbicide under alternative D. Upper bound estimates for a child 

drinking out of a pond where 200 gallons of herbicide has spilled, and for eating contaminated vegetation 

exceed 1.0 for these herbicides. 

Summary of Worker and Public Exposure Scenarios by Herbicide

Based on the risk assessment worksheets, use of herbicides in this project are associated with HQ values 

greater than 1.0 for the following exposure scenarios. In most cases, only upper bound estimates are 

greater than 1.0, indicating a very low level of risk.

Aminopyralid: This is a first year/first choice herbicide in all action alternatives. No worker or public 

exposure scenarios have HQ values greater than 1.0.

Chlorsulfuron: This is a first year/first choice herbicide in all action alternatives. Upper bound HQ = 4

for chronic consumption of contaminated vegetation, which is an implausible scenario given the extent of 

the project and the pdfs. 

Clopyralid: This is not a first year/first choice herbicide in any alternative. Upper bound HQ = 2 for a 

child drinking from a pond where 200 gallons of herbicide have been spilled. Upper bound HQ = 2 for 

chronic consumption of contaminated vegetation. Both of these scenarios are implausible given the extent 

of this project and the pdfs.

Glyphosate: This is a first year/first choice herbicide in alternative D. Upper bound HQ = 4 for a child 

drinking from a pond where 200 gallons of herbicide have been spilled. Upper bound HQ = 3 for a 

woman eating contaminated vegetation. Both of these scenarios are implausible given the extent of the 

project and the pdfs. 

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Imazapic: This is not a first year/first choice herbicide in any alternative. Upper bound HQ = 1.9 for a 

child drinking from a pond where 200 gallons of herbicide have been spilled. This scenario is implausible 

given the extent of the project and the pdfs. 

Imazapyr: This is not a first year/first choice herbicide in any alternative. No worker or public exposure 

scenarios have HQ values greater than 1.

Metsulfuron methyl: This is a first year/first choice herbicide in all action alternatives. No worker or 

public exposure scenarios have HQ values greater than 1.

Picloram: This is a first year/first choice herbicide in alternative D and it would not be used at all in 

alternative C. Upper bound HQ = 1 for a child drinking from a pond where 200 gallons of herbicide have 

been spilled. Upper bound HQ = 4 for chronic consumption of contaminated vegetation. Both of these 

scenarios are implausible given the extent of this project and the pdfs.

Sethoxydim: This is not a first year/first choice herbicide in any alternative. Upper bound HQ = 1.6 for a 

child drinking from a pond where 200 gallons of herbicide have been spilled. Upper bound HQ = 1.1 for 

consumption of contaminated vegetation. Both of these scenarios are implausible given the extent of this 

project and the pdfs.

Sulfometuron methyl: This is not a first year/first choice herbicide in any alternative. Upper bound HQ 

= 4 for chronic consumption of contaminated vegetation. This scenario is implausible given the extent of 

the project and the pdfs. 

Triclopyr BEE: This is not a first year, first choice herbicide in any alternative. For workers, upper 

bound HQ = 6 for general exposure, and upper bound HQ = 7 for wearing saturated gloves for one hour. 

Upper bound exposures assume no protective clothing and improper safety practices, which is unlikely 

given the pdfs. Upper bound HQ = 1.4 for direct spray of a child, which is an implausible scenario. Upper 

bound HQ = 2 for a child drinking from a pond where 200 gallons of herbicide have been spilled and the 

upper bound HQ = 27 for consumption of contaminated vegetation, which are also implausible scenarios. 

The upper bound HQ = 4 for consumption of contaminated fruit, which is an unlikely scenario. The 

central HQ = 3 for consumption of contaminated vegetation, which is unlikely given the extent of the 

project and pdfs. 

Triclopyr TEA: This is not a first year, first choice herbicide in any alternative. For workers, upper 

bound HQ = 1.6 for general exposure. Upper bound exposures assume no protective clothing and 

improper safety practices, which is unlikely given the pdfs. Upper bound HQ = 2 for a child drinking 

from a pond where 200 gallons of herbicide have been spilled and the upper bound HQ = 27 for 

consumption of contaminated vegetation, which are also implausible scenarios. The upper bound HQ = 4 

for consumption of contaminated fruit, which is an unlikely scenario. The central HQ = 3 for consumption 

of contaminated vegetation, which is unlikely given the extent of the project and pdfs. 

Comparative Risk Assessment

All of the herbicides proposed for use in the project pose relatively low risks to people and the 

environment. None of the herbicides besides triclopyr are associated with HQ values greater than 1.0 for 

worker health. Triclopyr has comparatively greater risk due to upper bound HQ values greater than 1.0 for 

general and accidental exposures. 

Aminopyralid, imazapyr and metsulfuron methyl are lowest risk for public health because no HQ values 

are greater than 1.0 for any exposure scenarios. All other herbicides (except triclopyr) are moderate risk 

due to upper bound HQ values greater than 1.0 for at least one public exposure scenario. Triclopyr is in 

the higher risk category because one central HQ value exceeds 1.0 for a public exposure scenario.

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Cumulative Effects 

Alternative A would not result in any cumulative effects on human health, as there would be no direct or 

indirect effects from no action.

The proposed use of herbicides in all action alternatives could result in multiple doses of the same or 

different herbicides to workers or the public. A person could be exposed to multiple doses within the 

project area or elsewhere. However, there is no evidence that herbicide exposure from this project would 

combine with exposure elsewhere and cause a discernable effect.

The R6 2005 FEIS considered the potential for synergistic effects of exposure to two or more chemicals:

Combinations of chemicals in low doses (less than one tenth of RfD) have rarely demonstrated 

synergistic effects. Review of the scientific literature on toxicological effects and toxicological 

interactions of agricultural chemicals indicate that exposure to a mixture of pesticides is more 

likely to lead to additive rather than synergistic effects (ATSDR, 2004; U.S.EPA/ORD, 2000). 

Based on the limited data available on chemical combinations involving the ... herbicides 

considered in this EIS, it is possible, but unlikely, that synergistic effects could occur as a result of 

exposure to the herbicides considered in this analysis. Synergistic or additive effects, if any, are 

expected to be insignificant (R6 2005 FEIS p. 4-3).

No project-level evidence suggests that significant synergistic or additive effects might occur. 

The risk assessment worksheets indicate that of the herbicides proposed for use on this project, triclopyr 

poses the greatest theoretical risk to workers and/or the public. However, the extent of use on the Forest 

would be very low. Because the potential extent of use is low, and the pdfs minimize the potential for 

exposures that are over a level of concern, the potential for triclopyr use on the MNF to contribute to a 

cumulative effect to a worker or the public is implausible.

Herbicide applicators are more likely than the public to be exposed to multiple doses of herbicide; 

however, there is low risk that a worker would receive multiple exposures during the time period in which 

the herbicide might remain in their body. This project involves the use of relatively low risk herbicides

and none of the central bound estimates for general worker exposure were over a level of concern. The

use of personal protective equipment would minimize the potential for exposure to the levels of herbicide 

analyzed in the risk assessments. In addition, the herbicides proposed for use are associated with low 

bioconcentration factors (see discussion above).

The potential for this project to contribute to cumulative effects on the public is very low. The risk 

assessment worksheet calculations indicate a risk from chronic exposure of some herbicides based on a 

woman eating contaminated vegetation for a 90-day period. HQ values exceed 1.0 for upper bound 

estimates for eating vegetation that has been sprayed with chlorsulfuron (HQ = 4), clopyralid (HQ = 2), 

picloram (HQ = 2), and sulfometuron methyl (HQ = 4). However, the likelihood of a person eating 

contaminated vegetation daily over a 90-day period is implausible.

Theoretically, a person could be exposed to herbicides by more than one scenario; for instance, a person 

could handle, and then consume sprayed berries. The cumulative impact of such cases may be 

quantitatively characterized by adding the HQs for each exposure scenario. An example using the 

herbicide glyphosate was provided in the R6 2005 FEIS Appendix Q. Glyphosate is the most used 

herbicide in Oregon based on Statewide Pesticide Use Reports from 2007 and 2008 (most recent data 

available, see Chapter 3.1.5). The R6 2005 FEIS used central exposure estimates for a woman being 

directly sprayed on the lower legs, staying in contact with contaminated vegetation, eating contaminated 

fruit, and consuming contaminated fish. This resulted in a combined (acute) HQ of 0.012. Using the 

updated risk assessment (2011) worksheet for the maximum application rate in Oregon, a similar 

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calculation resulted in an HQ of 0.322 for a woman contacting then eating contaminated fruit and 

vegetation, still below a threshold of concern for glyphosate exposure.

Triclopyr is associated with the largest HQ values of the herbicides proposed for use in the alternatives. 

However, the extent of use would be too low to result in multiple exposure (triclopyr is not a first choice 

herbicide in any alternative) and LRMP standards restrict application methods so that multiple routes of 

exposure for the public are implausible.

Even if a person was exposed to triclopyr in multiple ways, the herbicides are rapidly excreted or 

metabolized in the human body. The time between dermal exposure caused by harvesting of contaminated 

vegetation and the subsequent eating (oral exposure) would allow the body to metabolize some of the 

initial dose before receiving another exposure, thus reducing the potential for a cumulative dose. 

Additional information about herbicide use on other land ownerships in Oregon and potential for 

cumulative effects is in chapter 3.1.5. The ongoing and foreseeable projects and activities within the 

project area would not combine with this project and cause cumulative effects because even under worst 

case exposure estimates, the doses potentially received would not remain in the body long enough to 

combine and cause a cumulative effect.

3.3 Botany

3.3.1 Introduction

This section summarizes the findings of a biological evaluation and botany specialist report documenting

potential effects from implementing the proposed alternatives to fungal, lichen, and plant species that are 

federally listed as threatened, endangered, or proposed for federal listing under the Endangered Species 

Act of 1973, as amended, and also to fungal, lichen, and plant species identified as sensitive on the 

Regional Forester’s special status species list (USDA Forest Service 2011). These species are collectively 

referred to as sensitive plants. This section also addresses effects on plants that are culturally significant to 

local American Indian tribes, special forest products (non-timber forest products), and plant pollinators. 

These are often referred to as species of concern. Effects on common non-target plants are also discussed.

Endangered Species Act (Federally Listed Species)

The United States Fish and Wildlife Service (USFWS) website indicates that whitebark pine (Pinus 

albicaulis) occurs in Baker and Grant County. This species is currently a candidate for federal listing. 

Whitebark pine is found throughout western North America in subalpine habitats, usually near the 

timberline (above 6,500 feet altitude). The plant association group where it occurs is cold upland 

coniferous forest. Sites are usually fairly dry with thin, rocky, cold soils. It is found from Canada south to 

central California, and east to Wyoming and Colorado. It occurs on all Blue Mountain Forests, including 

at scattered sites on the Malheur NF. Very few documented invasive plant sites occur in high elevation dry 

sites. Therefore, it is unlikely that any invasive plant treatments will occur in areas where whitebark pine 

is found.

The USFWS website indicates that Malheur wire lettuce (Stephanomeria malheurensis) occurs in Harney 

County. This species is federally listed as endangered. It is found in a very limited area 35 miles south of 

the southern boundary of the Malheur National Forest. It grows only on volcanic tuffaceous soils. It is 

highly unlikely that there is any potential habitat for this species on the Malheur National Forest. 

The USFWS website indicates that Howell’s spectacular thelypody (Thelypodium howellii ssp.

spectabilis) occurs in Baker County. This species is federally listed as threatened. It is found in a very 

limited area of the Baker Valley. The closest known population is over 35 miles northeast of the Malheur 

National Forest. This species grows only at relatively low elevations on moist alkaline plains, and in 

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alkaline river valleys. It is usually found with black greasewood (Sarcobatus vermiculatus). All National 

Forest System land located on the Malheur National Forest in Baker County is in relatively high elevation 

in forested or open sub-alpine habitat types; therefore, potential habitat for this species is unlikely to be 

found. The USFWS website does not list any plants for Crook or Malheur Counties. 

For these reasons, consultation with the United States Fish and Wildlife Service regarding federally listed 

plants is not necessary.

Forest Service Designated Sensitive Species

This analysis addresses plant species designated as sensitive on the Pacific Northwest Region 6 Regional 

Forester's Special Status Species List (USDA Forest Service 2011). The list includes vascular plants, 

nonvascular plants (mosses and liverworts), lichens, and fungi. They are referred to here as “sensitive 

plants.” Currently, 88 species of sensitive plants are documented or suspected to occur on the Malheur 

National Forest. All federally proposed, listed endangered or listed threatened plant species (as defined by 

the Endangered Species act of 1973) are included on this list. Effects analysis determinations follow 

definitions as outlined in Forest Service Manual 2672.42.

Although there is a small chance of negative impacts to sensitive plant species from activities proposed in 

any of the action alternatives (MIIH), the potential of negative impacts is relatively small. The areas that 

would be treated are a small percentage of the known populations and potential habitat for sensitive plants 

species. Therefore, although the project may affect individuals and habitats for sensitive plants, 

implementation of any alternative would not result in a trend toward federal listing of any sensitive plant. 

The selection of any action alternative would not lead to a reduction in the long-term viability of any 

sensitive plant species on the Malheur National Forest.

Regulatory Framework and Compliance

All alternatives would allow for the continued viability of native vegetation, sensitive plants, and special 

forest products on the Malheur National Forest. All alternatives comply with the Malheur National Forest 

Land and Resource Management Plan.

3.3.2 Affected Environment

Native Vegetation

The Malheur National Forest, located in east central Oregon, contains a wide diversity of plant species 

and communities due to varying elevation and precipitation zones that occur within eastern Oregon. 

Elevations on the Forest vary from 3,900 feet (at the Forest boundary south of Mt. Vernon, Oregon) to 

9,038 feet on Strawberry Mountain. The result is a diverse and productive landscape of grasslands, sage, 

and juniper; as well as forests of pine, fir, and other tree species, and mountain lakes and meadows. Given 

this combination of physiography and climate, habitats are highly variable and retain a legacy of botanical 

diversity. 

Since the time of the first movement of people into the area and the associated establishment and spread 

of invasive weeds along vectors (highways, railroads, canoes, rafts, and other transportation methods),

invasive plants have altered habitats and vegetation types across the landscape. For example, many areas 

within the forest have become permanently altered by annual grasses, which have become naturalized. In 

certain instances, this permanent alteration of habitat has affected native vegetation (Olson 1999). 

Eastside forests are more susceptible to invasive plants than other forests in the region (R6 2005 FEIS), 

because their grasslands, riparian areas, and relatively dry, open forests (with frequent gaps in the plant 

cover), favor invasive plant establishment (R5 FEIS 2005). The moist forests and high montane areas 

have relatively closed plant cover or have extreme climate or soils, which are tolerated by fewer invasive 

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plant species. Invasive plants tend to colonize disturbed ground along and around developments such as 

roads, highways, utility (powerline) corridors, recreational residences, trails, campgrounds, and quarries. 

These are all places where native vegetation has been removed and disturbance has created areas for

invasive plants to establish. The susceptibility of plant communities to invasion can also be influenced by 

community structure, and the biological traits of the invader species.

Plant communities can be classified by a variety of factors such as vegetation structure, site moisture, 

overstory, and understory. The 2005 FEIS used broad potential vegetation groups (PVGs) to rate the 

susceptibility of vegetation to invasive plant establishment. Table 31 lists potential vegetation groups 

(PVG) found on the Malheur National Forest, their susceptibility to damage from invasive plants, the 

local plant community types that correspond to these broad PVG types, and mapped acres of invasive 

plants within the plant community types. The groups are aggregations of plant associations and represent 

a combination of temperature and moisture regimes for this Forest. Overall, most plant community types 

found on the Malheur National Forest are moderately to highly susceptible to invasion.

Table 31. Potential Vegetation Groups on the Malheur National Forest’s 1.7 million acres and their 

susceptibility to invasive plants

Potential Vegetation Group Percent of Forest Susceptibility to 

Invasion1 Infested acres (all 

species)2

Cold forest 2 Moderate 5

Cold herbland 0.1 Moderate 0.1

Cold shrubland 0.2 Moderate 0.3

Cool-cold riparian forest 0.000007 Moderate-high 0

Cool-cold riparian herbland 0.0002 Moderate-high 0.06

Dry Douglas-fir forest 16 Moderate-high 290

Dry grand-fir forest 24 Moderate-high 503

Dry ponderosa pine forest 21 Moderate-high 457

Hot-dry pine forest 10 Moderate-high 136

Dry herbland 2 High 29

Dry shrubland 6 High 43

Juniper woodland 3 Moderate-high 28

Moist forest 13 Moderate-high 456

Moist herbland 0.55 Moderate-high 18

Moist shrubland 0.8 Moderate 29

Warm-hot riparian herbland 1 High 74

Warm-hot riparian forest 0.00003 Moderate-high 0.3

Warm-hot riparian shrubland 0.0009 High 26

Whitebark pine forest 0.4 Moderate-high 0.4

Total 100.0

1 Susceptibility ratings (derived from R6 2005 FEIS): High = high susceptibility to invasion. Invasive plant species invade the cover 

type successfully and becomes dominant or co-dominant even in the absence of intense or frequent disturbance; Moderate = 

moderate susceptibility to invasion. Invasive plant species is a “colonizer” that invades the cover type successfully following high 

intensity or frequent disturbance that impacts the soil surface or removes the normal canopy; Low = low susceptibility to invasion. 

Invasive weed species does not establish because the cover type does not provide suitable habitat.

2 Some mapping error due to overlap in species occurrences in duplicate potential vegetation groups in GIS database

Sensitive Plants

The following sources of information were used to determine which sensitive plant species, and their 

respective habitats, may occur within the project area.

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

♦ The Regional Forester’s Sensitive Species List (USDA Forest Service 2011)22

♦ The Forest Service’s Natural Resource Manager Database (NRM) – Threatened, endangered, and 

sensitive species geographic information system (GIS) database, and other pertinent GIS mapping 

layers (potential natural vegetation, streams, and wetlands, aerial imagery).

♦ Project GIS layer showing proposed treatment areas.

Table 32. Sensitive plant populations within 100 feet of proposed invasive treatment areas

5th Field Watershed Sensitive Plant Species Invasive Species Distance Between Species

Bridge Creek

1707020301

Blandow’s feather moss

(Helodium blandowii)

Hound’s tongue

(Cynoglossum officinale) 30 feet – 1 site

Fields Creek John 

Day River

1707020110

Colonial luina

(Luina serpentina)

Dalmatian toadflax

(Linaria dalmatica) 57 feet – 1 site

Spotted knapweed

(Centaurea stoebe ssp. 

micranthos)

51 feet – 1 site

Headwaters Silvies 

River

1712000201

Crenulate moonwort

(Botrychium crenulatum)

Canada thistle

(Cirsium arvense) 54 feet – 1 site

Upper Silvies River

1712000203

Idaho sedge

(Carex idahoa)

Canada thistle

(Cirsium arvense) 0 feet – 1 site

Hound’s tongue

(Cynoglossum officinale) 0 feet – 1 site

Deschutes milk vetch

(Astragalus tegetarioides)

Dalmatian toadflax

(Linaria dalmatica) 0 feet – 3 sites

Middle Silvies River

1712000204

Deschutes milk vetch

(Astragalus tegetarioides)

Spotted knapweed

(Centaurea stoebe ssp. 

micranthos)

0 feet – 1 site

White-top

(Cardaria draba) 79 feet – 1 site

Emigrant Creek

1712000205

Peck’s long-bearded sego 

lily (Calochortus 

longebarbatus var. peckii)

Yellow toadflax or

Butter-and-eggs

(Linaria vulgaris)

0 feet – 3 sites

North Basin

1712000101

Deschutes milk vetch

(Astragalus tegetarioides)

Dalmatian toadflax

(Linaria dalmatica) 0 feet – 1 site

Table 33 that follows lists all Region 6 sensitive plant species that are documented or suspected to occur 

on the Malheur National Forest.

22 Forest Service Manual 2670.5 defines sensitive species as those plant and animal species identified by a Regional 

Forester for which population viability is a concern, as evidenced by significant current or predicted downward 

trends in population numbers, density, or habitat capability that would reduce a species existing distribution.

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Table 33. Sensitive plant species documented (D), suspected (S), or having a historical record (H) on the 

Malheur National Forest

Malheur National Forest Sensitive Plant Species

Taxa 

Type Scientific Name Common Name

Occurrence 

on the 

Forest1

Fungus Pseudorhizina californica umbrella false morel S

Lichen Texosporium sancti-jacobi woven spore lichen S

Liverwort Anastrophyllum minutum tiny notchwort S

Liverwort Anthelia julacea alpine silverwort D

Liverwort Barbilophozia lycopodioides giant fourpoint, maple liverwort, greater 

pawwort

S

Liverwort Harpanthus flotovianus great mountain flapwort S

Liverwort Jungermannia polaris Arctic flapwort S

Liverwort Lophozia gillmanii Gillman's pawwort S

Liverwort Peltolepis quadrata shieldscale liverwort S

Liverwort Preissia quadrata blister ribbon, narrow mushroomheaded liverwort

D

Liverwort Ptilidium pulcherrimum lovely fuzzwort, naugahyde liverwort S

Moss Encalypta brevipes candle snuffer moss, stubby 

extinguisher moss

S

Moss Entosthodon fascicularis banded cord-moss, Hasselquist's 

hyssop

S

Moss Helodium blandowii Blandow's feather moss, wet plume 

moss

D

Moss Meesia uliginosa Meesia moss D

Moss Pseudocalliergon trifarium blunt water moss, worm moss S

Moss Schistidium cinclidodonteum schistidium moss S

Moss Schistostega pennata schistostega moss S

Moss Splachnum ampullaceum purple-vased stink moss, small capsule 

dung moss

S

Moss Tetraphis geniculata tetraphis moss S

Moss Tomentypnum nitens tomentypnum moss D

Moss Tortula mucronifolia mucron-leaf tortula moss S

Vascular Achnatherum hendersonii Henderson's ricegrass S

Vascular Achnetherum wallowaense Wallowa ricegrass S

Vascular Artemisia arbuscula ssp. longicaulis Lahontan sagebrush S

Vascular Astragalus tegetarioides Deschutes milkvetch, bastard milkvetch D

Vascular Botrychium ascendens upward-lobed moonwort D

Vascular Botrychium crenulatum crenulate moonwort D

Vascular Botrychium hesperium western moonwort S

Vascular Botrychium lineare slender moonwort S

Vascular Botrychium lunaria common moonwort D

Vascular Botrychium montanum mountain moonwort D

Vascular Botrychium paradoxum twin-spiked moonwort S

Vascular Botrychium pedunculosum stalked moonwort S

Vascular Bupleurum americanum American thorough-wax S

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Malheur National Forest Sensitive Plant Species

Taxa 

Type Scientific Name Common Name

Occurrence 

on the 

Forest1

Vascular Calochortus longebarbatus var. 

longebarbatus long-bearded sego-lily S

Vascular Calochortus longebarbatus var. peckii Peck's long-bearded sego-lily D

Vascular Camissonia pygmaea dwarf evening-primrose S

Vascular Carex atrosquama blackened or brass-fruit sedge S

Vascular Carex cordillerana (Carex backii) cordilleran sedge D

Vascular Carex diandra lesser panicled sedge S

Vascular Carex idahoa Idaho sedge D

Vascular Carex lasiocarpa var. americana slender wooly sedge S

Vascular Carex media Scandinavian sedge S

Vascular Carex micropoda timberline sedge S

Vascular Carex nardina spikenard sedge S

Vascular Carex pelocarpa dusky-seed or new sedge S

Vascular Carex retrorsa retrorse sedge S

Vascular Carex saxatilis russet sedge S

Vascular Carex scirpoidea ssp. stenochlaena Alaska single-spiked sedge D

Vascular Carex subnigricans nearly black or dark alpine sedge S

Vascular Carex vernacula native sedge S

Vascular Chaenactis xantiana desert chaenactis S

Vascular Cheilanthes feei Fee's lip fern S

Vascular Cistanthe rosea(Calyptridum roseum) rosy pussypaws H

Vascular Cryptogramma stelleri Steller's rock-brake S

Vascular Cymopterus nivalis snowline cymopterus D

Vascular Cypripedium fasciculatum clustered lady's-slipper S

Vascular Elatine brachysperma short-seeded waterwort S

Vascular Eleocharis bolanderi Bolander's spike-rush D

Vascular Eriogonum cusikii Cusick's buckwheat S

Vascular Eriogonum salicornioides playa or saltwort buckwheat S

Vascular Heliotropium curassavicum salt heliotrope S

Vascular Kobresia myosuroides Bellard's kobresia S

Vascular Listera borealis northern twayblade D

Vascular Lomatium erythrocarpum red-fruited desert-parsley S

Vascular Luina serpentina colonial luina D

Vascular Lupinus cusickii var. cusickii Cusick's lupine S

Vascular Lycopodium complanatum ground-cedar S

Vascular Mimulus evanescens disappearing monkey-flower H

Vascular Muhlenbergia minutissima annual or little-seed muhly grass S

Vascular Ophioglossum pusillum adder's-tongue S

Vascular Pellaea bridgesii Bridge's cliff-brake S

Vascular Phacelia minutissima least or dwarf phacelia D

Vascular Phlox hendersonii Henderson's phlox S

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Malheur National Forest Sensitive Plant Species

Taxa 

Type Scientific Name Common Name

Occurrence 

on the 

Forest1

Vascular Phlox multiflora many-flowered phlox S

Vascular Pinus albicaulis whitebark pine D

Vascular Pleuropogon oregonus Oregon semaphore grass S

Vascular Potamogeton diversifolius diverse-leaved pondweed S

Vascular Rotala ramosior lowland toothcup S

Vascular Salix farriae Farr's willow S

Vascular Salix wolfii Wolf's willow S

Vascular Saxifraga adscendens ssp. oregonensis wedge-leaved saxifrage S

Vascular Stanleya confertiflora biennial stanleya S

Vascular Thelypodium eucosmum arrow-leaf thelypody D

Vascular Trifolium douglasii Douglas' clover S

Vascular Trollius laxus ssp. albiflorus American globeflower S

Vascular Utricularia minor lesser bladderwort S

Botanical Surveys

Sensitive plant botany surveys have not been completed in most of the areas proposed for invasive species 

treatments. These areas were inventoried for the invasive species, but not for sensitive species. Some 

selected locations targeted for treatment did receive sensitive plant surveys in 2013. No overlap between 

sensitive plant populations and invasive plant populations were found during these surveys (NRM 

database 2013).

Project design features (table 10) stipulate that site-specific surveys for sensitive plants will be conducted 

prior to project implementation. In areas with high potential for sensitive plant species habitat, a Forest 

Service botanist or otherwise qualified person will examine all areas of potential ground disturbance or 

herbicide application at the appropriate time of the year to identify targeted sensitive plant species before 

implementation.

Culturally Significant Plants

Traditional cultural plants such as bitterroot (Lewisia rediviva), biscuitroot (Lomatium spp.), camas 

(Camassia quamash), chokecherry (Prunus emarginata), and huckleberry (Vaccinium membranaceum)

are found in the project area. These and other culturally important plants are collected and used by Native 

American tribal members and the public as food, medicine, or in ceremonial activities. These species 

occur in various habitats across the Malheur National Forest. Specific locations where these species occur 

are not mapped or tracked by the Forest. No permits are required to collect these species for personal use.

Special Forest Products

Special forest products include all non-timber products that require a permit for commercial or personal 

use collecting. This includes firewood, posts and poles, Christmas trees, pine cones, burls, mushrooms, 

and commercial collecting of medicinal or food plants. Also included are permits for collection of seeds, 

cuttings, or whole plants for propagation or landscaping. Decorative rocks and landscaping rocks are also

collected under permit. Permits are not required for small quantities of mushrooms (less than one gallon 

per day), huckleberries, and other roots and fruits. The most common special forest product collected in 

the Malheur National Forest is firewood, followed by posts and poles. Mushroom permits are generally 

sold in quantity after wild fires, when morel mushrooms are in abundance. These activities may occur in 

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the same general vicinity where invasive species treatments may be implemented. Specific locations 

where these species occur are not mapped or tracked by the Malheur National Forest.

3.3.3 Environmental Consequences

Methodology

There is no potential habitat on the Malheur National Forest for any federally listed or proposed plant 

species. All alternatives for this project comply with standards and guidelines in the LRMP and Forest 

Service Manual 2670 for management of sensitive plants and special forest products. Therefore, there is

no effect from any of the alternatives to federally listed threatened, endangered, or plants proposed for 

federal listing. Hence, consultation with the U.S. Fish and Wildlife Service is not necessary for federally 

listed or proposed plants.

The four possible effect calls for sensitive plants are outlined in Forest Service Manual 2670. These 

definitions were used to guide the determination of effects:

 NI - Species that occur in habitats that are not expected to be directly or indirectly affected in any 

way, are given a “No Impact” determination.

 BI - Species and their potential habitats that could be favorably affected by a particular alternative 

are given a determination of “Beneficial Impact”.

 MIIH - Species and potential habitat that could possibly be negatively affected are given a 

determination of “may impact individuals or habitat (MIIH), but will not likely contribute to a trend 

towards federal listing or cause a loss of viability to the population or species.” This call is used in 

cases where there is unsurveyed potential habitat, or where potential impacts are uncertain, or 

considered relatively minor.

This acknowledges that the action could have negative impacts, but due to 1) the complexity of the 

proposed action, 2) the differential impacts across the landscape, and 3) the lack of best available 

science, the degree and consequence of the negative impacts are not known with certainty.

Additionally, this recognizes that even the most substantial impacts of the proposed action will not 

contribute to a trend toward listing the species under the Endangered Species Act. The effects are 

expected to be minor enough that they will not cause a loss of viability of the species in the 

planning area.

 WIFV - Species and habitat that will most likely be negatively affected by the project, a 

determination of “Will impact individuals or habitat with a consequence that the action may 

contribute to a trend towards federal listing, or cause a loss of viability to the population or 

species.” This call is used in cases where negative impacts will clearly occur, and they are of a

magnitude that they may cross a threshold leading to Federal Listing under the Endangered Species 

Act.

Since all of the action alternatives include similar activities and project design features, the analysis will 

focus primarily on a general discussion of potential effects. Then the individual alternatives will be 

compared in relation to the amount of area, and various herbicides proposed for treatment under each 

alternative.

Incomplete and Unavailable Information

Invasive plant sites and known populations of sensitive plant species on the Malheur National Forest have 

typically been mapped with an accuracy of 100 feet, or better. Small mapping errors may mean that sites 

on the ground are actually further apart or closer together than displayed in GIS. Additionally, invasive 

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

species and sensitive plant populations may expand or contract over time. Confirmation of the exact 

location of known sensitive plant sites will occur during planning, treatment, and monitoring of sites.

The only sensitive fungus currently suspected on the Malheur National Forest is the umbrella false-morel 

(Pseudorhizina californica). Fungi only fruit under very specific moisture and temperature conditions.

Therefore, it is very difficult to locate species of fungi because of their ephemeral nature. It is very 

possible that there are undocumented populations of the umbrella false-morel on the Forest.

Some sensitive plant species do not produce above-ground plants every year. These plants include some 

grape-ferns (Botrychium spp.), and many annual species which are dependent upon sufficient early spring 

rains, Some of the annual sensitive species include least phacelia (Phacelia minutissima), disappearing 

monkeyflower (Mimulus evanescens), dwarf evening-primrose (Camissonia pygmaea) annual muhly 

grass (Muhlenbergia minutissima), lowland tooth-cup (Rotala ramosior), and desert chaenactis 

(Chaenactis xantiana).

Some species, such as the least phacelia, annual muhly grass, and grapeferns, are so tiny and difficult to 

find in dense vegetation that even expert botanists may overlook them during surveys. Many of the nonvascular plants are very difficult to identify; it is possible that botanists may also overlook some of these 

species. For these reasons, it is not possible to state with 100 percent certainty that all sensitive plant 

species will be detected during sensitive plant surveys.

Information about the effects of the proposed herbicides on lichens, bryophytes, and fungi is generally 

lacking. Data on the susceptibility of different non-target plant species and families to particular 

herbicides is conducted with agricultural crop species and not those that may better represent non-target

plants in the natural environment.

Spatial and Temporal Context for Effects Analysis

The spatial context for this analysis is the entire area managed by the Malheur National Forest. This scale 

is large enough to identify trends to botanical species of conservation concern that could result from 

implementing this project. The temporal context for effects analysis includes short-term and long-term 

effects. Short-term effects for this analysis are considered to be 1 to 2 years after treatment. Long-term 

effects for this analysis are considered to be longer than 2 years. 

Effects to Sensitive Plants Common to All Action Alternatives

All of the action alternatives allow the use of manual, cultural, and mechanical control of invasive 

species. In addition, all action alternatives allow various amounts of herbicide treatment. Project design 

features for sensitive plants are the same for all action alternatives. The potential direct and indirect 

effects discussed below therefore apply to all alternatives.

Unless otherwise cited, information in this section incorporates by reference analysis discussed in Section 

4.3 and Appendix J of the R6 2005 FEIS (USDA Forest Service 2005a).

All invasive plant treatments are designed to kill or prevent growth and reproduction of target plants.

During treatment implementation, direct effects to adjacent non-target plant species may also occur. In 

most cases, impacts to non-target plants would be minor, and would occur in the immediate vicinity of the 

treated site. To help minimize effects to sensitive plant species, surveys will be conducted in potential 

habitat for sensitive plants before treatments. Monitoring and adaptive management are also important 

components of all alternatives that will allow for improving project implementation as more information 

is collected. In addition, project design features would help to reduce the risk of impacts to sensitive plant 

populations and habitats.

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A beneficial indirect effect of proposed treatments is that non-target plants would increase growth and 

abundance as competition from invasive plants is reduced. This would result in restoration of native plant 

communities as invasive species are controlled or eliminated. Overall, the short-term negative effects of 

treatments are expected to be less than the long-term indirect benefits of removing invasive plants.

Manual and Mechanical Control Effects

All alternatives include manual and mechanical control. Manual control includes hand pulling, grubbing 

with tools such as a shovel or hoe, and removing and bagging seed heads. Mechanical control includes the 

use of equipment such as mowers or string trimmers.

Control of invasive plants using manual or mechanical methods may potentially directly affect non-target 

plants. Direct negative effects may include mortality of individuals, reduced vigor due to trampling or 

removal of above ground parts, and reduced seed production. These effects would be minor with manual 

control and mechanical control using string trimmers. There would be less ability to target individual 

plants with mowing, resulting in greater risk of potential negative effects to non-target plants in the 

treated area.

The project design features for sensitive plants ensure that botanical surveys occur when warranted before 

project implementation, which will greatly reduce the possibility of these activities negatively affecting

sensitive plants. Additional protection will be provided by the pdf that provides for buffers of known 

sensitive plant sites (table 10).

Indirect effects of manual and mechanical methods include soil disturbance and reduced plant cover and 

shading. Depending on the magnitude of the disturbance, indirect effects may also reduce soil

productivity, change the capacity of the soil to hold moisture, and lead to disruption of mycorrhizal and 

bacterial soil activities and increases in soil surface temperatures. These changes may promote 

germination of invasive plant seeds in the seed bank, or provide sites for additional invasive species to 

become established. Because manual controls would be used primarily on small or low-density 

infestations of non-rhizomatous species, and mechanical control would be used on selected sites in 

combination with other methods, these negative effects are likely to be minor. Over time, with repeated

treatments, reduction of invasive species through manual and mechanical control would likely provide 

space for increased germination and growth of native plant species.

Cultural Control Effects

Cultural control techniques proposed in the action alternatives include mulching, seeding, planting, and 

solarization (covering areas with black plastic). Direct and indirect effects from these activities are similar 

to manual and mechanical control effects and are not likely to substantially affect sensitive plants (see R6 

2005 FEIS Appendix J). 

Effects of Biological Control Agents

Biological control agents would be authorized under all action alternatives. Most of the agents available 

for control of invasive species have previously been released in or near the project area, so many are 

already present on the Forest. Under alternative A-no action, biological control agents will not be 

deliberately released. 

The analyses of the environmental effects of biological control agents have been completed under 

documents developed by Agricultural Plant Health and Insect Service (APHIS) for approval of their use. 

The completed environmental impact statements are available at: 

http://www.aphis.usda.gov/ppq/enviro_docs/index.html.

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Even though control agents are reviewed and approved by APHIS prior to release in this country, there is 

a slight risk that an approved agent may unintentionally affect native plants or animals. There also 

remains the possibility that regardless of what the Forest Service does, unapproved agents or agents 

known to affect non-target plants could spread from neighboring lands onto National Forest System lands.

Herbicide Control Effects

Under alternative A-no action, herbicide use will no longer be authorized on the portions of the Ochoco 

National Forest administered by the Malheur National Forest, but may occur along state road rights-ofway and easements as a part of ongoing actions.

All action alternatives include some herbicide control. The action alternatives allow various chemicals 

and levels of chemical use across the Malheur National Forest. The potential for negative effects from 

herbicide use increases directly in relation to how many acres are treated, and the toxicity of various 

chemicals. Effects on non-target plants would vary based on the herbicide properties, application rate,

timing of application, application method, site conditions, and the susceptibility of the non-target plants. 

Use of non-selective herbicides with residual soil activity and relatively high risk for offsite effects could 

result in the most damage to non-target plant species. Use of selective herbicides could shift the 

composition of the plant community, as less tolerant species are replaced by more tolerant species. At 

many herbicide-treated sites, selective herbicides would result in greater impacts to native broad-leaved 

forbs than trees, shrubs, or grasses. 

Forest roads facilitate the spread of invasive plants; they have a substantial effect on the establishment 

and subsequent invasion by providing prime habitat for colonization and serving as corridors for spread.

Additionally, other management activities that create soil disturbance are also closely associated with 

roads. For example, landings, staging areas, and livestock handling facilities, are usually adjacent to 

roads.

In contrast, most sensitive plant sites are not adjacent to roads. Sensitive plants generally require specific 

microsites that are usually not in disturbed habitats. Most of the sensitive plant habitat within the 

treatment areas is currently not infested with invasive plants. The fact that there are only eight known 

populations of sensitive plants within 100 feet of proposed treatment areas illustrates this point. It is 

possible that there are additional undiscovered populations of sensitive plants in areas that may be treated 

during the life of this project. The median distance of mapped invasive plant sites to a road is 4 feet and 

more than 65 percent of known invasive plant sites are within 25 feet of a road center.

The chances of inadvertent spraying of sensitive plant populations would be reduced by project design 

features that restrict herbicide application rates and require pre-treatment assessments to confirm sensitive 

species populations, as well as surveys of high potential sensitive plant habitats and required monitoring. 

Additional protection will be provided by project design features that monitor and can change herbicideuse buffers of known sensitive plant sites. 

Offsite Movement of Herbicides

Although potential for offsite movement varies among herbicides and their application rate, the amounts 

transported offsite are likely to be quite small. Some plant species are so highly sensitive to certain 

herbicides that they may be affected by exposure concentrations 100 to 5,000 times less than the typical 

application rate. The toxicity of herbicides to terrestrial plants is determined by studies of seed 

emergence, seed germination, and post-emergence applications, using crop and forage plants. 

The probability of non-target plants being affected by soil blown from treated sites is low for all 

herbicides, despite the risks described in the previous paragraph. Potential for wind erosion in the project 

area is highest on traveled road surfaces and in large burned areas immediately after a fire. Invasive plants 

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generally do not occur on active road surfaces. While invasive plants do invade burned areas, infestations 

generally arise over a 10-year period, and are not treated the same season as the fire. None of the known 

treatment sites are considered to have high risk of wind erosion.

Drift could potentially affect non-target plants adjacent to treatment sites; the risk would be greatest 

during use of picloram and the sulfonylurea herbicides. Offsite drift is a physical process dependent on 

application rate, droplet size, and weather conditions. To reduce drift, herbicide labels have advisories for 

wind velocity and nozzle pressure/droplet size. The presence of intercepting vegetation at application sites 

can also limit drift. Drift is most associated with broadcast, rather than spot applications. Marrs et al. 

(1989) examined the distances that drift from broadcast applications affected non-target vascular plants 

and found observations consistent with drift deposition models. The maximum safe distance at which no 

lethal effects were found was 20 feet, but for most herbicides, the distance was 7 feet or less. Generally, 

damage symptoms were found at greater distances than lethal effects, but in most cases, there was rapid 

recovery by the end of the growing season. No effects were seen to non-target vascular plants further than 

66 feet from the broadcast treatment zone. Damage to non-target plants outside of treated areas from drift 

has not been observed at sites on the Forest spot treated with glyphosate or picloram in the past.

Pdf I -4 (table 10) restricts use of herbicides to no closer than 100 feet from known sensitive plant 

populations, so would greatly reduce the chance of negative impacts from herbicide drift.

Runoff could potentially affect germinating seedlings of non-target plants down slope of treatment sites.

GLEAMS modeling indicate damage from runoff is most likely to occur under conditions where 

picloram, imazapyr, or sulfonylurea herbicides are applied to sites with clay soils right before a 

thunderstorm. The risk on other soil types is low.

Unintended Direct Spray

Unintended direct spray would result in an exposure level equivalent to the application rate and is much 

more likely than wind erosion, drift, or runoff to cause impacts to non-target plants. The potential for 

damage to non-target plants would be greater during broadcast spraying than during spot spraying or 

wicking, which are much more selective application methods and generally apply less herbicide per acre.

Broadcast applications would be used on dense patches of invasive plants that have few interspersed 

native species; therefore, it is unlikely that substantial impacts to desirable plants would occur. Spot

spraying or wicking could damage plants growing immediately adjacent to or among target invasive 

plants. Monitoring of past spot applications on other forests has found these techniques to be highly 

accurate, with most of the visible damage to non-target plants occurring within less than 10 feet of treated 

plants (Desser 2014).

Residual Soil Activity

Many herbicides have residual soil activity. Root uptake by nearby non-target plants could result in their 

damage or mortality. Some herbicides (especially picloram, aminopyralid, imazapyr, and imazapic) can 

persist and remain active in soil for two or more seasons. This can prevent germination and establishment 

of susceptible plants. As noted above, past spot applications of picloram on other forests have not resulted 

in observable damage to non-target plants outside of the immediate treated area, either from unintended 

direct spray or from residual soil activity. The main desire is to recover desired plant communities, and 

picloram could persist to exclude desired forb type vegetation. However, pdfs eliminate the potential for 

herbicide persistence in the soil to have long-term effects on native plant communities. 

Herbicide Effects to Fungi/Soil Organisms

Herbicides have the potential to affect soil and soil organisms, including fungi. Herbicide effects on soil 

organisms are not well studied. For the proposed herbicides, risk assessments found typical application 

rates of picloram could inhibit soil microbial activity, although the indirect effect this would have on non142
Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

target plants is not known. Existing studies of herbicide effects on formation of mycorrhizal associations 

in forest and nursery settings indicate little effect (Busse et al. 2004). More information on effects on soil 

organisms is in chapter 3.4.

There is only one sensitive fungal species suspected to occur on the Malheur National Forest. The 

umbrella false morel (Pseudorhizina californica, formerly known as Gyromitra californica) is a fungus

that is associated with forest litter, rotting wood and mineral soil. It is found in riparian areas, coniferous 

forests, and sometimes in old logging skid trails (Aurora 1986). Habitat for this species is most likely in 

areas that are not highly susceptible to invasive plant infestations (except in log skidding trails). Although 

the location of the mycelia of these species is not known in many cases, it is unlikely they occur in areas 

that would be treated by application of herbicides.

Herbicide Effects to Bryophytes and Lichens

Little information is available about how herbicides may affect lichens and bryophytes. Concerns have 

been raised about drift from some herbicides decreasing the sustainability, relative long-term abundance, 

and diversity of lichens and bryophytes (Newmaster et al. 1999; R6 2005 FEIS). Lichens and bryophytes 

lack roots and instead obtain moisture and nutrients directly from the atmosphere; therefore, they are 

particularly sensitive and vulnerable to aerosols and contaminants in the atmosphere such as herbicide 

mist. Sensitive bryophyte and lichen species known to occur on the Malheur National Forest are generally 

found in wetlands, on rock surfaces, and in late-successional forest ecosystems.

Potential Effects to Special Forest Products

The main special forest product that is gathered on the Malheur National Forest is firewood. Posts and 

poles are another important non-timber product. All proposed treatments for invasive plant species should 

have no effect to opportunities to gather these products. Any potential negative effect would be human 

exposure to herbicides. The risks of human exposure to herbicides are discussed in other sections of this 

document (chapter 3.2.3).

There is a chance that plants gathered for food and medicinal purposes may be impacted by invasive 

species treatments. Mechanical, cultural, and herbicide treatments should only minimally affect these 

plants. This is due to the relatively small areas of treatment, especially when compared to the amount of 

habitat for these species. The project design feature that dictates the use of blue dye (pdf F6) and public

education about the dye should greatly reduce the risk of human exposure to herbicides when collecting 

special forest products.

The risk of negative impacts to special forest products is low; therefore, the risk from each alternative is 

determined to be minimal. No comparison of the alternatives is needed in terms of effects to special forest 

products. None of the alternatives would result in measurable impacts to special forest products.

Effects on Culturally Significant Plants

Non-herbicide treatment methods are not likely to affect culturally significant plants. Manual methods 

such as weed pulling allow a great deal of plant specificity and reduce the likelihood of impacts to nontarget species. Proposed herbicide treatments have the potential to effect broadleaf varieties and grasses

that could potentially include culturally significant plants. Project design features would help prevent

impacts to non-target vegetation, including fungi, vascular, and non-vascular plants. Project design 

features require consultation with affected Tribes as treatments are scheduled, so that tribal members may 

provide input or be notified prior to gathering culturally significant plants. Individual cultural plants 

identified by Tribes would be buffered as described for botanical species of conservation concern. The 

project design feature that dictates the use of blue dye (pdf F6) and public education about the dye would 

greatly reduce the risk of human exposure to herbicides when collecting culturally significant plants.

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Effects of Alternatives

Alternative A

None of the proposed activities would occur under alternative A-no action, thus, there would be no direct

or indirect effects to botanical resources from invasive plant treatments. Therefore, implementation of the 

no-action alternative would have no impact (NI) to sensitive plants, and would not lead to any direct 

negative impacts to culturally significant plants, or special forest products.

Since invasive plants often out-compete native plants, the risk to sensitive plants from invasive plants 

increases with the number of acres of invasive plant infestation. Alternative A will not achieve the goal of 

reducing acreage or suppressing, containing, controlling or eradicating invasive plants. This alternative 

would not meet the desired future condition “to retain healthy native plant communities that are diverse 

and resilient, and restore ecosystems that are being damaged, and to provide high quality habitat for 

native organisms throughout the forest, and assure that invasive plants do not jeopardize the ability of the 

forest to provide goods and services communities expect.” Invasive species would continue to spread and 

could eventually adversely affect sensitive species. 

Alternative B

Biological control agents must be rigorously tested for host specificity and approved by APHIS prior to 

release in the United States. The agents proposed for release meet the host-specificity requirements of the 

R6 2005 ROD Treatment Restoration Standard 14. There is a slight risk that an approved agent could

attack a closely related non-target plant species. There are currently no known threats from biological 

control agents specific to Malheur NF sensitive species. Therefore, no direct effects from the use of 

biological control agents to sensitive plant species would occur.

Cultural techniques that include seeding and planting native plants may change the species composition at 

treatment sites. Heavy seeding of native or short-lived non-native grasses could delay germination and 

growth of other native plants. However, in areas where competitive seeding may be used, the invasive 

plant infestations are generally so dense that the native plant community has already been drastically 

altered. Reducing the invasive plants and establishing desirable vegetation would improve the probability 

that a native community could reestablish over time. Impurities in seed lots could potentially introduce 

non-native or invasive species, but the requirement to use certified weed-free seed would reduce this risk. 

Project design features that include surveys and buffers for sensitive plants (table 10 pdf group I) would

help to reduce the risk that cultural control methods may negatively impact sensitive plants. Therefore, 

cultural techniques would not have any direct negative impacts to sensitive plant species or habitat.

The use of herbicides could potentially kill common native and sensitive plants. Alternative B proposes 

treating up to 2,124 acres per year with herbicides. Common plants near infested areas could be killed; 

broadcast treatments are the most likely to result in some loss of common native vegetation within 100 

feet of target plants. Spot and hand treatments could also kill common plants that are adjacent to treatment 

sites.

Project design features ensure pre-treatment surveys would be completed for sensitive plant habitat. If any 

sensitive plants are located during these surveys, pdfs and buffers would be applied to protect the 

populations of sensitive plants. No treatments are proposed in aquatic habitats; therefore, there would be 

no direct impact to aquatic sensitive plant species.

Alternative B-proposed action would lead to a reduction in the extent and density of invasive plant 

species in the project area. This would reduce competition and displacement of sensitive plant species 

over the life of the project. Therefore, the indirect long-term effect of implementation of alternative B 

would lead to a beneficial impact to sensitive plant species in the project area (BI). The degree of this 

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beneficial impact is directly correlated with how many acres of invasive species are reduced or 

eliminated.

The sensitive plants survey requirement also provides a large measure of protection for sensitive plant 

species. However, there is always a small possibility that some populations of sensitive plants may be 

overlooked during sensitive plant surveys. For this reason, it is not possible to state with 100 percent

certainty that all sensitive plant species will be detected during sensitive plant surveys. There is a slight 

chance that undetected sensitive plant populations may be negatively impacted by proposed treatments. 

Therefore, the direct effect of alternative B -proposed action on sensitive plant populations and habitat 

potentially found in treatment areas is, the proposed action may impact individuals or habitat (MIIH), but 

will not likely contribute to a trend towards federal listing or cause a loss of viability to the population or 

species.

Early Detection/Rapid Response (EDRR)

The effects of the EDRR process are the same as the direct and indirect effects because the project design 

features, annual caps, and implementation planning process serve to ensure that future treatments are 

similar to those analyzed. The requirement that areas proposed for treatment be surveyed for sensitive 

plants would provide a large measure of protection for sensitive plant species.

Cumulative Effects

In the past, present, and reasonably foreseeable future, there have been and will continue to be projects 

and activities within the planning area that may cause impacts to sensitive plants and their habitats on the 

Malheur National Forest. Projects and activities that reduce native plant cover and create ground 

disturbance increase the risk of invasive plant infestation. Chapter 3.1.5 discusses ongoing activities that 

also may be vectors of spread for invasive plants and foreseeable future projects on the Malheur National 

Forest.

Road construction and recreation developments have permanently removed native plant habitat in parts of 

the planning area, and disturbed roadsides continue to be a major conduit for invasive plant spread. Public 

use of National Forest System lands will likely continue to increase with population growth. This will 

contribute to the spread of invasive plants along roads and in recreation areas.

Historically, people using pack stock brought hay and feed from other areas for their animals. This feed 

often contained invasive plant species seed. This contributed to the introduction of new invasive species 

to the area. As part of the R6 2005 ROD, this potential vector of invasive species was reduced by 

regulations that require the use of certified weed-free feed for all recreational and permitted stock on the 

Malheur National Forest (Directive R6-2009-001). The cumulative effect of these regulations is there 

would be fewer introductions of new invasive weed species and new populations of invasive plants in the 

project area. This would help to reduce the long-term risk to sensitive and other plant species of concern.

Past timber harvest created highly disturbed habitat that has remained open and susceptible to infestation 

for 25-30 years. Current and planned timber harvest on National Forest System lands in the project area 

are mostly thinning treatments with the objective of maintaining mature forest and improving forest 

health. Harvests are often combined with understory fuels treatments. These types of activities are 

designed to restore habitats to historical stand conditions. Current treatments, when compared to past 

clear cutting, are less likely to create unnaturally large openings, which leads to more bare ground, which 

provides good germination sites for invasive species. These vegetation management activities have the 

potential to increase suitable habitat for invasive plant species.

Domestic livestock grazing is a well-documented vector for invasive species seed transport. Livestock 

grazing has occurred in most of the project area for decades and has resulted in changes in plant

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communities, especially in nonforested and riparian areas. Grazing has a direct effect on plants through 

biomass removal and trampling. Grazing can have an indirect effect on plant species by causing soil 

compaction, soil disturbance, and alteration of nutrient cycling. The degree of impact to plant species 

from grazing is related to the timing, duration, and intensity of the grazing action, as well as the 

individual characteristics and habitat requirements of the plant species. Grazing may reduce the 

competitive ability of perennial native grasses in rangeland and meadow habitats and creates localized 

areas of bare ground susceptible to infestation.

The historical abundance and distribution of sensitive species on the Forest is not known. Past activities 

have likely affected their current abundance and distribution. Beginning in approximately 1990, botanical 

surveys and biological evaluations were conducted for most Forest Service projects planned and 

implemented in the project area. These efforts analyzed effects to species included on the Region 6 

sensitive plant list at the time of the analysis. As a result, activities conducted, ongoing, and planned since 

1990 have been designed to reduce impacts to sensitive species.

Chapter 3.1.5 introduces the basis for the cumulative effects analysis and displays tables listing the past

and present vectors of invasive plant spread and reasonably foreseeable future projects within the project 

area.

Alternative C

Direct and Indirect Effects 

The primary difference between alternatives B and C is the amount and types of herbicides used.

Alternative C would not allow the use of picloram and would not allow broad spraying. It also would

prohibit the use of herbicides within 100 feet of water bodies. The maximum number of acres of herbicide 

treatment annually is 735 (as compared with the 2,124 acres proposed in alternative B). The same project 

design features will apply for sensitive plant protection with additional protection provided near streams.

The effects for alternative C would be very similar as alternative B; however, there will be less use of 

herbicide and consequently less risk of negative impacts from herbicides relative to alternative B. There 

would be no herbicide treatments within 100 feet of water bodies, so there would be no risk from 

herbicides to sensitive plants that occur within 100 feet of water bodies. Although the risk to sensitive 

plants is relatively lower under alternative C, the same potential sources of risk still apply. The possibility 

of accidentally treating undiscovered populations of rare plants does exist. Therefore, implementation of 

alternative C may impact individuals or habitat (MIIH), but will not likely contribute to a trend towards

federal listing or cause a loss of viability to the population or species.

Alternative C would lead to a reduction in the extent and density of invasive plant species in the project 

area. This would reduce competition and displacement of sensitive plant species over the life of the 

project. Therefore, the indirect long-term effect of implementation of alternative C would lead to a 

beneficial impact to sensitive plant species in the project area (BI). The degree of this beneficial impact is 

directly correlated with how many acres of invasive species that are reduced or eliminated. For this 

reason, alternative C will not lead to as great of a beneficial impact as alternative B (see chapter 3.1.4 for 

more information about treatment effectiveness).

Early Detection/Rapid Response

The effects of the EDRR process are the same as the direct and indirect effects because the project design 

features, project caps, and implementation planning process serve to ensure that future treatments are 

similar to those analyzed. The requirement that areas proposed for treatment be surveyed for sensitive 

plants would provide a large measure of protection for sensitive plant species. However, the loss of 

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treatment effectiveness due to fewer acres treated compared to alternative B would be magnified over the 

life of the project (chapter 3.1.4).

Cumulative Effects

Cumulative effects for alternative C would be similar as for alternative B. See discussion above.

Alternative D

The difference between alternatives B and D is the first year/first choice herbicides proposed, which 

indirectly influences the herbicide application method. Alternative D would not allow the use of 

aminopyralid, which would increase the use of other herbicides, thereby increasing the acreage that would 

need to be spot or hand treated and changing the herbicide-use buffers required. See chapter 3.1.4 for 

more discussion of the effectiveness of alternative D vs. alternative B. The maximum number of acres of 

herbicide treatment annually is 1,654, which is the same as for alternative B. The same project design 

features will apply for sensitive plant protections.

The risks to sensitive plants from alternative D are similar to alternative B. The same potential sources of 

risk to sensitive plants apply. The greatest potential risk of negative impacts to sensitive plant species is 

due to the possibility of accidentally treating undiscovered populations of rare plants. The fact that less 

broadcasting would likely occur would increase operator control and reduce potential for overspray, drift,

or accidentally affecting sensitive plants. This would also result in less potential risk to common nontarget plants.

Therefore, the direct effect of alternative D on sensitive plant populations and habitat potentially found in 

treatment areas is that implementation of alternative D may impact individuals or habitat (MIIH), but will 

not likely contribute to a trend towards federal listing or cause a loss of viability to the population or 

species.

Alternative D would lead to a reduction in the extent and density of invasive plant species in the project 

area, however it would take more time compared to alternative B (see chapter 3.1.4). This would reduce 

competition and displacement of sensitive plant species over the life of the project. However, indirect 

long-term effects of implementation of alternative D would lead to a beneficial impact to sensitive plant 

species in the project area (BI). The degree of this beneficial impact is directly correlated with how many 

acres of invasive species that are reduced or eliminated. Alternative D is less favorable than alternative B 

in terms of protecting native plant communities because it is more costly and would take longer to 

implement.

Early Detection/Rapid Response (EDRR)

The effects of the EDRR process are the same as the direct and indirect effects because the project design 

features, annual caps, and implementation planning process serve to ensure that future treatments are 

similar to those analyzed. The requirement that areas proposed for treatment be surveyed for sensitive 

plants would provide a large measure of protection for sensitive plant species. However, the loss of 

treatment effectiveness compared to alternative B would be magnified over the life of the project (see 

chapter 3.1.4).

Cumulative Effects

Cumulative effects for alternative D would be similar as for alternative B. See discussion above.

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Summary of Effects to Botanical Resources

Table 34. Summary of effects to sensitive plants and special forest products

Issue and Indicator Alternative A Alternative B Alternative C Alternative D

Type and extent of 

herbicide use within 

100 feet of sensitive 

plants and special 

forest products

none

Pdf prohibits broadcast 

herbicide use within100 

feet of sensitive plant 

populations. Spot

applications will be used 

within 100 feet of sensitive 

plant populations. Pdf for 

use of blue dye will alert 

special forest product 

gatherers of herbicide 

spray areas. 

Same as Alt B Same as Alt B

Effectiveness of 

buffers and project 

design features to 

prevent impacts to 

non-target vegetation

NA

Buffers and pdfs would

substantially reduce the 

chance of herbicide use 

within 100 feet of sensitive 

plant populations.

Same as Alt B Same as Alt B

Compliance with 

existing management 

direction and 

disclosure of findings

Will not achieve goal 

of adequately 

treating invasive 

plants

Meets full compliance Meets full 

compliance

Meets full 

compliance

Determination of 

short-term effects to 

Sensitive Plants

NA

Uncertainties due to 

difficulty of location and 

identification of all 

populations of sensitive 

plants leads to a call of 

may impact individuals 

or habitat (MIIH). Risk is 

directly correlated with 

number of acres treated.

Uncertainties 

due to difficulty 

of location and 

identification of 

all populations 

of sensitive 

plants leads to 

a call of may 

impact 

individuals or 

habitat (MIIH).

Risk is directly 

correlated with 

acres treated.

Slightly lower 

risk than 

alternative B 

due to treating 

fewer acres

with herbicide, 

and not using 

picloram 

(which is more 

persistent in 

the soil).

Uncertainties due to 

difficulty of location 

and identification of 

all populations of 

sensitive plants 

leads to a call of 

may impact 

individuals or 

habitat (MIIH). Risk 

is directly correlated 

with acres treated.

Slightly higher risk 

than alternative B 

due to lower 

effectiveness of 

chemicals other 

than aminopyralid.

Determination of 

long-term effects to 

sensitive plants

Spread of invasive 

plants would lead to 

a long-term negative 

impact to sensitive 

plants.

Reduction in amount and 

extent of invasive plants 

would lead to a long-term 

beneficial impact to 

sensitive plants (BI).

Reduction in 

amount and 

extent of 

invasive plants 

would lead to a 

long- term 

beneficial 

impact to 

sensitive plants 

(BI).

Reduction in 

amount and extent 

of invasive plants 

would lead to a 

long-term beneficial 

impact to sensitive 

plants (BI).

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3.4 Soils 

3.4.1 Introduction

This section describes the potential direct, indirect, and cumulative impacts on soil from proposed 

invasive plant treatments. Herbicides may accumulate in soils and harm soil biology, nutrient cycling, and 

the organisms necessary for decomposition and soil productivity. Soil properties influence the potential 

for herbicide treatments within riparian areas to reach streams.

Soils regulate the fate of herbicide through soil properties. The soil litter and medium itself controls the 

persistence and chance for herbicide to either percolate or runoff to non-target areas. This analysis 

addresses the fate of herbicide within soils considering the unique environment conditions of the Malheur 

National Forest and site-specific characteristics. Factors other than taxonomic soil type usually determine 

the fate of herbicides within the soil, such as of groundcover, compaction, gradient, and biological 

capacity. Biological capacity is the ability of soil organisms to decompose litter and relates directly to 

fertility. Higher amounts of organic matter, water, light, and favorable temperature affects the ability of 

soil organisms to process vegetation and herbicide residue.

Regulatory Framework and Compliance

Proposed treatments in all action alternatives would not lead to detrimental soil disturbance, nor 

substantially add to levels of detrimental disturbance from prior activities. Thus, the Malheur National 

Forest LRMP standard to retain effective cover would be met. Further, most of the invasive plant 

treatments occur on administrative use lands where productivity is not the primary purpose. All 

alternatives would meet Malheur National Forest LRMP objectives (USDA Forest Service 1990, p. 4-21) 

and regional guidance (USDA Forest Service 1998) for soils.

3.4.2 Affected Environment

Geology 

The geology of the Malheur National Forest is amongst the oldest and most complex in Oregon. 

Remnants of a shallow seafloor and sediments thereon were accreted onto the one-time edge of the North 

American tectonic plate (Brooks 1979). Under pressure and heat, these layers were metamorphosed into 

argillites, quartzite, and amphibolites that predominate in the center of the Malheur National Forest, 

Aldrich Mountain, and Bear Valley Basin. This process was concomitant with volcanism, and intrusion of 

oceanic crust, which are the frequent large bodies of serpentine common to the areas mentioned. A thick 

sequence of sediment, eroded from the one-time coast range, approximately where the Blue Mountains 

are today, deposited into the John Day geosyncline. These sediments are the mudstone, shale, greywacke,

and volcanic rocks that overlay the seafloor sedimentary rocks, but now in turn, are often eroded away to 

expose the older rock.

Starting about 35 million years ago, massive volcanism and attendant uplift resulted in widespread and 

thick sequence of basalt and andesite lava flows from vents and fissures, interlayered with pyroclastic 

tuffs, as well as conglomerates and breccia created during erosive periods between bouts of volcanism. 

Much of the Malheur National Forest is covered by the Clarno, John Day, Strawberry, and Columbia 

Group basalts and andesites (Brown and Thayer, 1966; Greene et al, 1972). These rocks frequently 

compose the upper ridges and mountain tops, except in the northeast quadrant where uplift and erosion 

has led to extensive exposure of old seafloor sediments or granitic batholith.

The larger valleys, the John Day, Bear Valley Basin, for example, are filled with recent (Holocene) 

alluvium, but there are also extensive coarse sediment fans of the Pliocene and Pleistocene epoch on 

lower slopes and bottoms of the larger valleys.

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

Climate

The climatic conditions that favor invasive plants on the Malheur National Forest were derived by

associating current invasive plant sites with annual mean minimum temperature and precipitation from 

PRISM 30 meter grid data (Daly et al. 2008). Mean minimum temperature is a good relative measure of 

growing season. Most of the invasive plants occur in areas of the forest with a mean minimum 

temperature above 28 degrees Fahrenheit. Thus, the abundance of invasive plant infestations declines 

substantially above 6000 feet where mean minimum temperatures are less than 28 degrees Fahrenheit and 

a short growing season becomes a limiting factor (figure 6). In terms of growing season, invasive plants 

on the Malheur National Forest tend to establish in areas with 54 to 85 frost-free days. 

Climatic conditions favorable to invasive plants are mostly in the northern and western portions of the 

Malheur National Forest, and around the 5,000-6,000-foot elevation zone, where greater available

moisture and moderate growing temperatures prevail. In contrast, much lower distribution of invasive 

plant sites occur in the southwestern quarter where the climate is colder and dry.

Figure 6. Target invasive plant sites by elevation

Location of Invasive Plants and Soil Conditions

The list of site types in chapter 3 (table 22) shows that most of the invasive plant sites occupy roadside 

settings, with natural soil conditions making up a small portion of the current invasive plant sites. 

Roadside areas provide more available light and less competition for moisture and nutrients, and are 

frequently disturbed, which favor the typical early seral stage invasive plants. Roadsides have compacted 

gravels formed for roadbase that may or may not have a developing litter layer where roadside vegetation 

grows. The soil properties for disturbed roadside environments will be moderate to poor drainage and 

considered to have low fertility. However, open light conditions and pooled water from roadside drainage 

increases water availability for grasses and forbs compared to adjacent natural soils.

Natural soils have disturbed conditions from vegetation management, recreation, grazing, or wildfire that 

compacts, bares the surface, but leaves the soil profile in place. The range of natural soils and more 

importantly the range of soil properties that could influence herbicide movement were derived by 

overlapping the Soil Survey Geographic Database (SSURGO) mapping with invasive plant sites. The 

mapping, however, is complete only for the northern portion of the Malheur National Forest, which

contains 41 percent of the invasive plant sites. The lack of soil mapping is not necessarily an impediment 

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to analysis since the environmental fate of the herbicides is more related to the level of disturbance than 

the soil series, and the diversity of soils series within the mapped area is representative of the relevant soil 

properties across the Malheur National Forest.

The SSURGO mapping has an accuracy of 40 acres for the map units and thus represents a fine scale 

compared to prior soil surveys. This mapping covers the diverse terrain and landforms common to the rest 

of the Malheur National Forest. The exception would be that a higher presence of volcanic ash is found in 

the northern portion of the forest. Table 35 lists soil properties associated with the dominant soil types and 

affiliated geology derived from the northern portion of the forest.

Table 36 lists the soil properties that contrast soil capacity to hold water and provide nutrients. Soil 

properties for organic matter, soil depth, hydrologic conductivity, cation exchange capacity, and pH were 

derived from the NRCS Soil Data Viewer. Strong gradients in fertility are found between grassland and 

forest soils in the project area. Grassland and forb rich soils have high organic matter content along with 

finer textures that hold water longer into the dry season. The parent rock mineralogy affects the soil 

texture, degree of clay, rock content, cation exchange content, pH, and available minerals. With exception 

to the valley bottoms, most of the Malheur National Forest soils have high percent gravel to cobble rock 

fragments. The pH ranges from 6 to 7, having no indication of acidic or alkaline conditions that limit 

productivity.

The cation exchange capacity (CEC) serves as an indicator for fertility and adsorption of applied 

herbicides. The cation exchange capacity is an index of available sites for solutes/ions to attach to soil 

particles. A higher CEC represents increased ability to hold and release various chemical elements – a 

relative higher capacity for holding nutrients. The soils in the project area have CEC of 5 to 35 meq/gram 

of soil for mineral soil horizons (table 36). Humus, highly decomposed organic matter within the soil, has 

the strongest impact on overall CEC since humus itself has CEC in the range of 100 to 200 meq. The clay 

influenced soils have the highest CEC at 35 meq since clay minerals have high surface to volume ratios 

that bolster CEC. Though not listed in table 36 grasslands with deep accumulations of organic matter will 

have CEC in the range of 30 to 50 CEC.

The dominant soil series in the northern half of the project area developed on andesite and basalt rocks 

and range from shallow to very deep soils. These series correlate with 23 percent of the invasive plant 

sites and comprise the Fivebeaver, Wonder, Bigcow, and Rebarrow soil series. Soils derived in these 

volcanic ash materials generally have silt loam textures, gravelly to stony conditions, and clay contents 

less than 20 percent. These soils transmit water effectively at 70 to 97 μm/s except for the shallow 

Fivebeaver series. Higher water availability is found in the Wonder, Bigcow, and Rebarrow soils, which 

have higher ash deposition and deeper soil matrix. Available water in these ash influenced basalt and 

andesite soils has potential 9 to 14 cm; the range for all the mapped soils is 4 to 15 cm. Values below 4 cm 

indicate low available water.

Tuvame and Mellow soils, the dominant soils in valleys, account for 7 percent of the invasive plant sites. 

The poor to very poorly drained soils have seasonal water close to the surface, and support various sedge 

vegetation. These soils have very deep matrix and less rock than the volcanic soil on adjacent hillslopes. 

Available water in these soils depends on the closeness to the drainage. The loam to silt loam textures 

support moderate water movement through the soil profile due to lack of clay to hold water. The available 

water is listed 11 cm; however, the valley bottom position suggests water could be more abundant.

Soils that have inherently high erodibility include those on steep slopes, developed in volcanic tuff. Btree, 

Lamulita, and Humarel soil series occur on tuff and welded pyroclastic flows, correlated to 6 percent of

the invasive plant sites. The duff decomposes easily forming clayey soils. Where deep and welldeveloped, the soil matrix has a high CEC at 35 meq, not including the forest floor. Because of the finer 

texture, the water movement through the soil matrix is reduced compared to the andesite and basalt soils 

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at 47 to 69 μm/s. These soils have values of available water similar to the harder rock volcanic soils at 7

to 14 cm, controlled mostly by soil depth.

The metavolcanic soils, which developed on very hard resistant rock, correlate with 4 percent of the 

invasive plant sites. These include the serpentine derived soils that have inherently poor growing 

conditions. The dominant soil series include the Lemoncreek and Hondu soil series that have ashy topsoil, 

and support mixed conifer forests. These rocky soils have less than 14 percent clay, silt loam to sandy 

loam textures, and have low organic matter within the soil matrix. These soils have a low ability to hold 

water with only 7 cm estimated water.

Granitic derived soils only account for less than 1 percent of the invasive plant sites. Though normally 

well drained, the ash influence increases water holding capacity on these soils. The Gorhamgulch soil 

series is the predominant soil type. Soils support mixed conifer forest. The cation exchange capacity is 

moderate at 15 meq. Available water is high at 15 cm.

Table 35. Most common soil types from SSURGO mapping-ordered from dry to mesic vegetation types

Soil Series Area 

(%) Geology Characteristic Vegetation Where found

Bocker 3.4 Andesite and Basalt Shallow, mollisol Sage steppe Lava plateau

Anatone 2.2 Andesite and Basalt Shallow, mollisol Sage steppe Lava plateau

Fivebeaver 5.0 Andesite and Basalt Shallow, mollisol Ponderosa pine 

and Douglas-fir

Plateaus and 

backslopes

Wonder 6.9 Andesite and Basalt Ashy, rocky 

inceptisol

Mixed conifer 

forest

Montane ridges and 

shoulder slopes

Bigcow 6.2 Andesite and Basalt Ashy, rocky 

inceptisol

Lodgepole pine 

and grand fir Hillslopes

Bennettcreek 4.1 Andesite and Basalt Thick ash, alfic 

forest soil

Ponderosa pine 

and Douglas-fir

Lower hillslopes and 

footslopes

Deardorff 2.2 Andesite and Basalt Thick ash,rocky, 

moist forest soil

Mixed conifer 

forest

Montane ridges and 

shoulder slopes

Rebarrow 5.6 Andesite and Basalt Thick ash,rocky, 

moist forest soil Moist grand fir Mountain valleys

Linecreek 2.2 Basalt Ashy, rocky alfisol Ponderosa pine 

and Douglas-fir

Plateaus, canyons, 

hills

Olot 2.0 Basalt Thick ash, rocky 

forest soil

Mixed conifer 

forest

Mountains and 

plateaus

Tovame 4.0 Valley bottom

Somewhat poorly 

drained, terrace 

soils

Cinquefoil and 

sedges Dry meadows

Melloe 3.2 Valley bottom

Poorly drained, 

aquic soils within 

valley alluvium

Alder and sedge Wet meadows

Btree 2.9 Acidic Tuffs Thick ash, alfic 

forest soil on tuff

Mixed conifer 

forest

Mountains and 

canyons

Lamulita 1.5 tuff breccia

Clay and rock, 

ashey, open forest 

soil on tuff

Grand fir, 

Douglas-fir, and 

ponderosa pine

Plateuas and hillslopes

Humarel 2.0 welded pyroclastic 

flows/ clay rich mafic

Clay and rock, 

ashey, open forest 

soil on tuff

Ponderosa pine 

and Douglas-fir Hillslopes

Lemon-creek 2.3 Metavolcanics 

(serpentine)

Ashy, rocky forest 

soil on 

Mixed conifer 

forest Hillslopes

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Soil Series Area 

(%) Geology Characteristic Vegetation Where found

metavolcanics

Hondu 1.4 argillite and 

metavolcanics

Deep and rocky, 

ashy dry forest soil 

on argillite and 

metavolcanics

Grand fir, 

Douglas-fir, and 

ponderosa pine

Hillslopes

Gorhamgulch 0.5 granite rock Ashy, forest soil on 

granite

Mixed conifer 

forest Hillslopes

*The percent area found within invasive plant mapping.

Table 36. Soil properties of prevalent soil series

Soil Series Depth (in) Dominant Texture Clay (%) OM (%) CEC* Ksat** Available 

Water ***

Bocker Shallow cobbly siltloam 22.2 1.5 15 9 3.71

Anatone Shallow cobbly siltloam 23.2 1.82 21 9 2.61

Fivebeaver Shallow cobbly siltloam 18.4 6.34 21.4 23.56 4.51

Wonder Very Deep gravelly siltloam 6.2 16.45 15 97 9.56

Bigcow Very Deep gravelly siltloam 6.2 16.45 15 97 9.56

Bennettcreek Mod Deep siltloam 6.5 10.67 5 52.68 8.52

Deardorff Very Deep stoney siltloam 8.8 10.42 15 69.4 14.42

Rebarrow Very Deep siltloam 8.8 10.42 15 69.4 14.42

Linecreek Mod Deep extremely cobbly loam 6.5 10.67 5 52.68 10.06

Olot Mod Deep stoney siltloam 10.6 11.2 17 69.4 12.73

Tovame Very Deep siltloam 9 5.25 15 28 10.95

Melloe Very Deep loam 9 5.25 15 28 10.95

Btree Deep siltloam 8.8 11.42 15 69.4 14.86

Lamulita Deep clay loam 26.8 13.38 32.8 47.4 9.91

Humarel Mod Deep very gravelly clay loam 30.8 12.42 35.2 47.4 7.13

Lemoncreek Mod Deep siltloam 13.6 4.64 12.7 23.56 7.13

Hondu Very Deep sandy loam 6.6 4.78 14.7 25.08 7.14

Gorhamgulch Very Deep siltloam over cobbly 

sandy loam

6.2 11.42 15 52.68 15.08

*Cation exchange capacity in meq/100g for top 10 inches of soil

**Saturated hydrologic conductivity in top 20 inches soil (μm/s)

***Available water holding capacity within top 20 inches soil (cm)

3.4.3 Environmental Consequences

Methodology

The R6 2005 FEIS analyzed herbicide effects to soil organisms and this analysis is incorporated by 

reference.

Factors other than taxonomic soil type usually determine the fate of herbicides within the soil, such as 

groundcover, compaction, gradient, and biological capacity. Biological capacity is the ability of soil 

organisms to decompose litter and relates directly to fertility. Higher amounts of organic matter, water, 

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light, and favorable temperature affects the ability of soil organisms to process vegetation and herbicide 

residue.

The main consideration for soils is the ability to filter and degrade herbicide residue depending on surface 

conditions. Site-specific soil and climactic conditions were modeled to examine the depth of percolation 

of herbicides for typical soil conditions.

Soils were characterized using the Terrestrial Ecosystem Unit Inventory (TEUI) that is currently 

completed for a third of the MNF. Older soils information (Carlson 1974) was used to analyze areas not 

mapped with the TEUI.

Spatial and Temporal Context for Effects Analysis

Project duration is 5 to 15 years or longer. Repeated treatments, manual, mechanical, or chemical may be 

necessary in sequential years or the same year on the same ground (generally to treat missed plants during 

initial treatment). All action alternatives may result in repeated treatments through the life of the project. 

Active restoration may occur to reduce the time necessary after treatment to mitigate the effects of soil 

disturbance or persistence of various chemical herbicides.

Effects of Alternative A – No Action

Alternative A would not authorize any invasive plant treatments so would not have direct effects on the 

soil resource. Based on current spread rates (4-12% as per R6 2005 FEIS and ROD), invasive weed 

populations would continue to grow along the main travel corridors leading to higher risk for spread onto 

the Malheur National Forest. The effect on soils is a shift away from natural plant and soil communities as 

invasive plants occupy new sites. Where invasive plants invade newly disturbed sites, such as wildland 

fire areas, the invasive plants can affect the recovery trajectory for desired plant and soil communities.

Effects Common to All Action Alternatives

Direct and Indirect Effects Summary

All action alternatives expand the tools for controlling invasive plants. Non-herbicide treatments would

have negligible effects to soils. Soils would also not be adversely affected from the herbicide treatments

due to the typical rates of application and the prevalence of sites on non-natural surfaces, such as 

roadsides, trailways, and at parking areas. Soil productivity would not be directly affected. Indirect effects 

may include a shift in the composition of plant and soil biota related to use of herbicides. However, the

project design features applied to all action alternatives make this unlikely because restrictions on the rate, 

type, and frequency of specific herbicides (see pdf groups F and H, chapter 2, table 10) would reduce 

herbicide build up in the soil and effects on soil organisms or productivity.

Direct and Indirect Effects from Non-herbicide Treatments

The non-herbicide treatments would have very minor effects on soils. Some soil disturbance could occur 

from pulling invasive plants. Typical treatments result in less than 1 square foot loosened soil as pulling is 

typically used on sparse scattered infestations rather than large, densely infested areas. These disturbances 

do not adversely affect overall site productive capacity since they are small and distributed, and do not 

lead to substantial soil loss. The retained cover of target plant species curtails erosion of loosened soil. 

Sufficient groundcover would ensure low potential erosion on treatment sites.

On treatment sites that are part of the productive landbase, groundcover would likely average at least 40 

percent (USDA 1990, p. IV-40). Groundcover would consist of non-target vegetation stems and leaves, 

leaf litter and residual noxious weed plant material. Ten to twenty percent native cover is considered a 

minimum requirement to facilitate natural recovery (Goodwin et al. 2006). Administrative areas, such as 

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road prisms, would continue to maintain groundcover to reduce erosion. Restoration and rehabilitation 

using mulching, seeding, and planting would occur as needed (see chapter 2.3.2).

Direct and Indirect Effects from Herbicide Treatments

Herbicides would be sprayed directly on target species using ground-based methods (hand, spot, and 

broadcast) in all action alternatives; as per the pdfs, all methods, including broadcast, would be 

implemented in a manner that reduces potential for non-target species and bare soil to be affected. 

However, herbicide is likely to reach the soil surface in some places.

Herbicide application temporarily disturbs soils by altering vegetation cover and reducing the annual 

plant production. The duration of the impact would be less than 10 years following treatment; desired 

vegetation is expected to reoccupy treated sites. Treatments would not result in detrimental soil conditions

or permanent reductions to soil productivity. 

The primary consideration for soils is the ability to filter and degrade herbicide residue depending on 

surface conditions. The major pathway for herbicide degradation is metabolism by soil microbes. Halflives for herbicides range widely depending on the growing conditions for soil microbes. Herbicide 

decays from toxic levels by microbial decomposition, sunlight degradation, and hydrolysis after 

absorption in the soil profile (Bollag and Liu 1990). Most of the recommended herbicides primarily 

degrade by microbes metabolizing the residue (SERA 2004b, d, e, 2007, 2011a-d). Chlorsulfuron and 

metsulfuron methyl also degrade strongly by hydrolysis (SERA 2004a, 2004c). 

Indirect effects of herbicide transport to non-target plants and to groundwater resources are influenced by 

soil properties. Herbicide labels list soil texture as one means to control offsite spread. Herbicide labels 

have broad applications with agricultural settings having bare soil as a prominent use. For the typical 

application on Malheur National Forest, plant cover, groundcover, slope steepness, and condition of the 

soil surface factor into the offsite movement in the Malheur National Forest setting. Also, the degree of 

saturation and compaction contributes to runoff. Leaching corresponds to the position in the valley 

bottom, porosity of soil material, and rainfall that could transport herbicide residue downward along a 

wetting front. To the extent that organic matter and productive soils exist, leaching would largely be 

controlled for in the topsoil as soil microbes metabolize herbicide residue. 

The GLEAMS model (see chapter 3.5 for details) was used to examine the fate of herbicides in the 

rooting zone of the soil and to evaluate the potential for herbicides to run off or leach through soils and 

reach water bodies. The modeling included a scenario for herbicide application on the most common soil 

type along a roadside. Figure 7 displays the results by soil depth versus magnitude of herbicide 

concentration. Dot size represents the level of herbicide concentration (larger dots mean more herbicide 

found in that soil layer). The Wonder soil series was used, having gravelly silt loam topsoil over gravelly 

loam subsoil and developed in andesite and basalt parent material to greater than 80 inch depth. Climate

data was taken from the nearby Austin station and modeled for summer. The GLEAMS modeling shows 

none of the herbicides penetrating deeper than 36 inches using the highest application rates. The faint dot 

of aminopyralid represents small herbicide concentrations. The sharp decrease in herbicide concentration 

with depth illustrates the adsorption of herbicides to soil despite their high solubility. The topsoil organics 

and mineral matrix bind the bulk of the herbicide in the top inches as reflected in the modeling results.

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Figure 7. Concentrations (ppm) of herbicide modeled for Wonder Series soils in the Clear Creek watershed

Despite the low risk for offsite transport by water, a risk for offsite transport by dust was identified for the 

sulfonylurea herbicides where applied to bare soil conditions along roadsides, native surface roads and 

cleared vegetation areas. Chlorsulfuron, sulfometuron methyl, and metsulfuron methyl binds particularly 

tightly to clay particles. Risk to non-target plants from herbicide-laden dust was addressed in the risk 

assessments for these herbicides. To mitigate this risk, these herbicides can only be applied on ashy soil, 

or light sandy soil during moist conditions (pdf F5). Further, application during calm wind conditions

lowers risk for offsite transport (pdf F3).

Direct and Indirect Effects to Soil Organisms

Impacts to soil organisms would be low and transitory due to the type of herbicide, low application rate, 

and Malheur National Forest climate. The R6 2005 ROD (amended Malheur National Forest LRMP) 

limited the use of herbicides to those that are unlikely to affect soil productivity and soil organisms. This 

analysis incorporates by reference the R6 2005 FEIS analysis and findings regarding impacts on soil 

organisms and productivity.

Impacts to soils and soil microbial community would largely be indirect, related to removal of targeted 

vegetation and shift to desired plant species. Changes in vegetation type can shift below ground 

composition of soil organisms (Wardle et al. 2004, Wolf and Klironomos 2005). Indirect boosts in 

decomposition rates may result as soil microbes metabolize dead plant tissue. Slight increases in 

microbial activity may occur as the bacteria break down the herbicide. This effect was observed by 

Ratcliff et al. (2006) where a growth increase in bacteria followed a glyphosate spill; the researchers 

reasoned that the increase is temporary as the bacteria metabolize the herbicide.

Eight of the 10 herbicides approved in the R6 2005 ROD were not found to pose deleterious effects to 

soils. Picloram and sulfometuron methyl had potential affects to soil microbes in laboratory tests but not 

in field studies. These risks were reduced by limiting frequency and rate of application. The project 

proposes use of sulfometuron methyl at rates half that analyzed in the SERA risk assessment. Picloram 

use in alternatives B and D has specific design criteria to avoid use on inherently poor soils and limit 

repeat application (pdf H3 and H4). Picloram would not be used in alternative C.

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Aminopyralid may be used in alternatives B and C. The 2007 SERA Risk Assessment does not indicate 

any risk to soil microbes. However, aminopyralid has a very wide-ranging half-life of 14-343 days as 

reported in the SERA Risk Assessment. Due to plausible persistence from slow microbial decomposition, 

the project has limited broadcast spray to once a year on a given site (pdf H4). Aminopyralid has no 

restriction from poor soils since the herbicide readily breaks down in sunlight. Aminopyralid has a halflife of 61 days when exposed to sunlight, while the half-life drops dramatically to 0.6 days when exposed 

to water and sunlight. Poor soils tend to have open forest conditions.

Using the SERA risk assessments, short-term impacts to soil organisms from picloram, imazapyr, 

metsulfuron methyl, and sulfometuron methyl could occur for high rate applications on poor soils. In 

laboratory assays, short-term decreases for some types of soil microbes are reported with high

concentrations above the amounts expected in soils. The effect of the herbicides decreases with time as 

other microbes, less sensitive to herbicide, decompose the active ingredient. The project microbial 

decomposition of each herbicide can be compared in table 40. Persistent herbicides such as picloram have 

longer half-lives. Impacts to microbes would be least where soils have a high degree of productive 

capacity with adequate organic matter, aeration, and moisture. 

For picloram, the SERA risk assessment cited a slight decrease in the N fixing bacteria Azotobactor for a 

two-week period at picloram concentrations of 10 ppm (see Tu 1994). In general, laboratory assays found 

few detectible changes in microbial activity below 50 ppm soil concentrations (SERA 2011c). Within the 

SERA risk assessment, GLEAMS model results show that for the clay, loam, and sandy soils the soil 

concentration after application would be below 10 ppm. Results for GLEAMS-Driver modeling on the 

Malheur National Forest sites for a typical silt loam soil would have 0.3 ppm of picloram following 

treatment (figure 7). The GLEAMS-Driver is a module that uses climate data specific to an area. Given 

picloram’s persistence (half-live 80 days to 3 years), this project limits application to once every two

years on a given site (pdf H4). Similarly, picloram is excluded from use on poor soils where natural plant 

communities are desired (pdf H3). The emphasis on natural plant community addresses uses on 

administrative sites and roadsides that have unique conditions that favor desired non-native species as 

protective groundcover.

For metsulfuron methyl, findings from one study showed slight growth reduction of common soil 

bacterium above 5 ppm soil concentrations (SERA 2004c). These effects increased with dosage. Modeled 

metsulfuron soil concentrations are 0.06 ppm. As with picloram, metsulfuron methyl is known to be 

persistent with half-live of 120 days (see Hydrology section). In agricultural studies, metsulfuron methyl 

use was linked to damaged rotation or substitution crops from persistence (Yu et al. 2005). The Yu et al. 

(2005) study demonstrated the detoxifying efficacy of a certain fungus that used metsulfuron methyl as a 

carbon source. Given the persistence and reliance of microbial degradation, the proposed action is for half 

the use rate commonly used in USFS applications (see SERA analysis 2004c). The project limits potential 

buildup of this persistent herbicide by limiting to once every other year on a given site, and avoiding use 

on poor soils where decomposition rates are low and native vegetation is desired (pdf H3, H4).

Tests for sulfometuron methyl depressing microbial activity showed mixed results from laboratory studies 

(SERA 2004d). Studies found both no effect and lower microbial biomass using herbicide concentrations 

near the rates evaluated in the SERA risk assessment. Overall, the risk assessment information was 

uncertain on the effects to any particular microbial group. Since herbicide half-life indicates the 

decomposition and thus microbial activity, this provides some indication on the toxicity. Field studies 

suggest the half-life is at 10 to 100 days (SERA 2004d) with higher decomposition in humid climates 

(Anderson and Dulka 1985). The half-life range shows ready decomposition by at least some microbial 

groups.

The proposed application rates for sulfometuron methyl are half of the highest rate used by the SERA risk 

assessment and modeled soil concentrations less than half that used in the environmental fate experiment 

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by Anderson and Dulka (1985). Note, this study showed that soil concentrations of 0.14 ppm followed 

first order decay equations, suggesting that no depression of microbial activity was found. The proposed 

level of sulfometuron methyl would have soil concentrations at 0.11 ppm, slightly lower than that used in 

the study.

The direct effect of herbicides on fungal and bacterial soil microorganisms vary with the herbicide used, 

and even then depend on the residue reaching the soil and the degradation rate, or half-life of the 

chemical. The effect to micro-organisms is usually not gauged by direct measurements, but inferred by 

changes in productivity factors such as respiration (CO2 production) of which microbial activity is one 

cause (SERA, 2011b). However, the measurement of toxicity of herbicides to soil micro-organisms may 

be relevant only in the soil medium itself. Busse et al. (2001) showed that glyphosate, which can be toxic 

to microbes grown directly on the herbicide in the laboratory, had an un-measurable effect on microbes 

when applied directly to soil in the laboratory or in the field. In a follow-up study on glyphosate effects to 

soil microbial community structure, Ratcliff et al. (2006) showed a sizable increase in the bacteria to 

fungal ratio for the spill scenario (100% solution) and not for the diluted field rate. The increase may be 

only temporary as bacteria metabolize the herbicide, a labile carbon source, with an anticipated return to 

normal composition as the active carbon supply returns to natural levels.

Imazapyr has been shown to temporarily depress microbial activity for select organisms. Imazapyr soil 

concentrations over 20 ppm were reported to slow cellulose decomposition by microbes in the lab (SERA 

2011d). For the Malheur National Forest project, predicted soil concentrations are 0.50 ppm, below the 20 

ppm level that effects were found. The reported average half-life of greater than 200 days indicates 

imazapyr can be resistant to decomposition. As with other more persistent herbicides, the project avoids 

the use of imazapyr on poor soils (pdf H3) and limits the frequency of broadcast application to once every 

other year on a given site (pdf H4).

Triclopyr has significantly slowed growth of bacterial and fungal strains in laboratory assays where 

concentrations exceeded 1000 ppm (SERA 2011a). Some fungal strains had detectible changes to growth 

down to as little as 0.1 ppm. When testing natural soil samples, no detectible changes to microbial 

function or community structure was found for a rate of 1.2 lb. a.i./acre (Houston et al. 1998). The typical 

rate for triclopyr on the Malheur National Forest would be 1 lb./acre. Model runs using a high rate at 2

lb./acre show average soil concentrations of 0.6 ppm. At this concentration, triclopyr has very low 

potential for slowing fungal growth. 

The capacity for soil microbes to decompose herbicide residue would be greater on natural soils 

compared to developed environments, such as roads and facility pads. The herbicides have wide-ranging 

half-lives depending on the biological capacity in the soil. The SERA risk assessment for aminopyralid 

lists half- lives of 14-343 days (SERA 2007). Since the microbial decay of herbicide is the primary fate, 

high productivity soils decrease the half- life and thus residency.

Decomposition processes need adequate water supply, air, and carbon, which is highest on natural 

surfaces. Water has been shown the most critical factor for productivity, as microbial activity drops 

substantially when soil moisture content is under ten percent (Davidson et al. 1998). Litter and forest floor 

layers provide a large proportion of CEC capacity that adsorbs herbicide residue. The litter and forest 

floor also reduces water losses to evaporation. 

Eighty three percent of the currently mapped infested acres occur along roadsides and administrative sites 

that are non-natural sites. Since these constructed surfaces lack diverse plants and soil microbes, herbicide 

decay by soil microbes would be reduced. However, herbicides would also decay by photolysis for all 

selected herbicides. Similar effects would apply to compacted and bared soils such as skidtrails, log 

landings, off-road parking, and cattle troughs. 

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Inherently poor soils include shallow, droughty, and serpentine soils. These soils have less capacity for 

decomposition and thus result in longer herbicide residence times. Thin basalt soils are prevalent across 

the Malheur National Forest, but have high concentrations of organic matter in the topsoil that alleviates 

concern. Serpentine soils have isolated locations across the forest. The highest density is within the 

northern portion of forest, which coincides with the fine scale SSURGO mapping. Of the invasive plant 

sites, twenty sites occur on road templates on or adjacent to serpentine soils comprising 62 acres. Mapped 

as either Lemoncreek or Cotay soil series, these soils have ash influence that would ameliorate the poor 

growing conditions associated with serpentine. The Lemoncreek soil has shallow topsoil and thus a higher 

risk than the Cotay soil series. The infestations have primarily Canada thistle and sulphur cinquefoil. The 

sites are situated in the Mosquito Creek-upper Bear watershed that drains to the Middle Fork John Day 

River. Most occur within the old Summit Wildfire burn area. Other sites include Little Boulder CreekDeerhorn and Vinegar Creek subwatersheds of the Middle Fork John Day River. 

Where shallow and disturbed soils exist, the use of picloram and sulfometuron methyl could reduce 

potential revegetation. These herbicides persist and poor soil conditions could lengthen already long 

residency times. The climatic limits, pdfs, and herbicide-use buffers minimize the potential for leaching 

and runoff thereby reducing risk to the extent possible. Picloram application is limited to once every other 

year on a given site, and excluded on poor soils, or shallow soils where productivity may be reduced to 

the extent that decomposition of the herbicide residue would be stalled (pdfs H3, H4). This effectively 

reduces the potential for picloram to build up in the soil and have impacts on soil organisms or 

productivity. 

Effects from Early Detection/Rapid Response

The current invasive plants sites represent the range of environmental conditions expected on the Malheur 

National Forest thereby accounting for potential consequences. These conditions were used to analyze 

and produce project design features that establish a sufficient layer of protection for soil organisms and to 

limit offsite transport to non-target plants and groundwater. 

None of the proposed treatment methods would create large bare areas or result in heavy disturbance to 

the soil surface. Thus, disturbances would not be large enough to contribute measurable levels of erosion 

or sediment delivery to streams. As a result, there is little potential for this project to adversely affect soils 

or contribute to meaningful cumulative effects when combined with past and ongoing Malheur National 

Forest activities.

The potential effect of repeated treatment of herbicides has been considered in the development of the 

pdfs. Relatively low toxicity and low application rates reduce this risk. Imazapyr, picloram and 

metsulfuron methyl have the longest half-lives of the eleven herbicides considered for use (SERA 2011b, 

2004d and 2011c). Using these herbicides could have short-term transient effects that could slow growth 

of select soil microbes. Herbicides half-lives are listed in table 40 in the Hydrology section. The project 

limits use of these persistent herbicides to every other year on any given site to minimize soil buildup (pdf

H4). Since soil conditions determine the buildup potential – a lack of soil microbes equates to lack of 

decomposition – the use of metsulfuron methyl and picloram would be avoided on sites with poor soil 

conditions (pdf H3) where restoration to native vegetation is desired. Gravel pits and parking lots would 

be examples of infertile areas where half-lives may be longer than on areas of productive soil; however,

herbicide buildup would also not have adverse effects in these areas.

Depths of maximum concentration presented in GLEAMS results are between 8 and 12 inches (table 40). 

Although the application of herbicide is likely in successive years on most sites, the time between 

applications and the half-life of the various herbicides will minimize residue accumulations. Applying 

herbicides at typical and not maximum recommended rates will limit the amount of excess residue present 

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on site each year, while the presence of soil microbes and soil temperatures conducive to degrading the 

herbicides will limit the amount of accumulation.

Cumulative Effects Common to All Action Alternatives

None of the alternatives would measurably affect soils or soil productivity, especially given background

conditions and ground disturbance created by ongoing activities. Thus, there is no potential for effects 

from any alternative to contribute to additive, synergistic, or other negative long-term cumulative effects. 

Manual, mechanical, and cultural treatments would likely result in very small disturbances that may 

reduce groundcover down to 40 percent. Treatment scale would not be large enough to cause adverse 

cumulative effects when combined with past and ongoing Forest activities.

Treatment and monitoring of invasive populations would continue through the life of the project. 

Foreseeable management activities on these sites are dispersed recreation travel, prescribed burns, 

wildfire suppression activities, and vegetation management, including timber harvest. Although these 

activities could result in direct detrimental disturbance to the sites, the effects to soils from herbicide 

applications proposed under this project are unlikely to incrementally change soil characteristics enough 

to alter the productivity of any treated sites. Activities proposed under this project are not likely to be 

additive to the impacts of any other activities that could be cumulative to existing conditions on these 

sites. 

The ongoing forest management and recreation activities in addition to natural disturbance from wildfire 

create the potential for increased use of herbicide or other treatments. The proposed herbicide spraying 

assumes a reduction in treatment over time. However, ongoing forest activities may increase the open 

sites available for invasive plants to spread. The risk is controlled by existing prevention measures. 

Timber sale contracts have provisions to wash rigs as do fire suppression activities. Similarly, road 

management has specific contractual agreements that control against invasive plant spread. 

The effects of the herbicide treatments do not harm soil organisms but do change the vegetation 

composition, which results in a minor level of disturbance. Ongoing management activities outlined in 

chapter 3.1.5 create a very large disturbance footprint compared to the effects of any action alternative. A 

list of forestwide projects is scheduled (2013-2015) that will be concurrent with the action alternatives 

(table 28). Most of the activities will involve ground disturbance.

Figure 8 shows the median disturbance acreage for the Malheur National Forest for the past 10 years. 

High severity disturbance results in detrimental soil conditions that reduce native vegetation cover and 

impairs soil function. Detrimental disturbance results when management activities physically alter soils 

and remove organic matter to the extent that soil recovery remains very slow (USDA Forest Service 

1998). Low severity disturbance results in short-term reductions to vegetation cover that last less than ten 

years. Invasive plant treatment would not be considered a high severity disturbance. Invasive plant 

treatment might temporarily slow recovery of native vegetation within some treatment sites, but would 

eventually help restore desired vegetation.

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Figure 8. Disturbance from ongoing forest activities

Road related disturbance accounts for the most extensive disturbance across the forest. Most of the 

existing invasive plants are mapped along road templates (83 percent). The road templates are not 

intended as a part of the productive land base and thus minor changes to plant cover from herbicide 

treatment would not produce adverse effects. The planted roadsides consist primarily of grasses selected 

for stabilization. The grasses resist most of the first choice herbicides that select specifically for invasive 

forbs. However, invasive plant treatment frequency would remain high along roadsides since the 

engineered surface perpetually favors re-colonization by opportunistic plant species. 

Continued road management activities would increase noxious weed treatment needs when ditch clearing 

and road blading remove or bury roadside vegetation. Current best management practices reduce this risk 

by promoting vegetative cover. Road maintenance best management practices reduce the bare soil along 

road sides by limiting the frequency (BMP Road-4, USDA 2012) and establishing plant cover after 

construction and re-construction activities (BMP Road 3, USDA 2012). Passive and active restoration on 

roadsides would help establish desired vegetation and discourage invasive plants (see Chapter 2).

The short-term reduction in vegetation growth that creates minor soil disturbance is a tradeoff. Given the 

large disturbance footprint and continued invasive plant presence along the roads, future additive effects 

from herbicide application and forest activities are reduced if treatment occurs along prominent vectors. 

The proposed methods reduce populations of invasive plants at rock pits and stockpiled road materials.

As per R6 2005 ROD standards, using invasive plant-free road materials (i.e., rock and gravel) also 

reduces the potential spread onto adjoining road prisms and within planned harvest units. Administrative 

sites, campgrounds, roads (areas that have unnatural surfaces and perpetual propagule pressure from 

traffic flow) have the highest risk of invasive plant spread. Many MNF activities (e.g., range, timber, and

recreation management) depend on road access, thus the extent of the road system is an indicator of where 

ground disturbance is most likely.

Vegetation management, including timber harvest, may result in a heavy disturbance, although there 

would be rapid recovery of native vegetation. The Malheur National Forest harvested roughly 7,583 acres 

of timber annually using the median value from the last 10 years. However, together with wildfire, only 6

percent of the invasive plant sites correlate with timber harvest and wildfire events. 

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Livestock grazing requires road access and creates heavy disturbance along fence lines, and around stock 

ponds and troughs. This disturbance has a small footprint; cattle trails typically have 2- to 4-foot width 

and stock troughs may have 0.25 acres of compacted, barren ground. These features are evenly distributed 

across thousands of acres, as opposed to confined disturbance that results from timber harvest or wildfire. 

The distributed nature and seasonal disturbance creates a moderate risk for cumulative effects from 

livestock grazing. 

Multiple herbicide applications over a series of years in this project would not pose a risk to soil microbes 

or soil productivity. Soil microbes are the primary means of decomposing herbicide residue. The 

suppression of sensitive suites of soil microbes is avoided by allowing sufficient time between 

applications, given the half-life of the various herbicides. Pdfs included to apply herbicides at the lowest 

application rate for effective control would limit the amount of excess residue present on site each year. 

Pdf H4 lengthens the re-entry period to two years before herbicides with longer half-lives – imazapyr, 

metsulfuron methyl, and picloram – may be reapplied on a site. As a result, residues remaining in the soil 

when subsequent applications occur are expected to be minimal. Also, the treatment effectiveness of each 

application would reduce the extent of re-treatment needed and would limit that amount of herbicide build 

up that could occur (See chapter 3.1.5). 

Herbicide use adjacent to the MNF could drift onto the Forest, but the amount would be far below a level 

of concern for soils assuming adherence to labels.

Differences between Alternatives

The differences between alternatives would not substantially change their impact on soils because manual 

and herbicide treatments of invasive plants are unlikely to affect soil properties or productivity. Properties 

of soils in the Malheur National Forest limit off-site movement of herbicides through the soil profile. 

Alternative B utilizes the most aminopyralid and allows the most broadcasting of the alternatives. 

Alternative C reduces the amount of herbicide used, and excludes use on sites that fall within 100 feet of 

streams, lakes, ponds, and wetlands. This alternative also excludes use of picloram. Thus, the risk for 

herbicide buildup is reduced in this alternative because less herbicide would be applied and because 

picloram is eliminated. Alternative D would use 440 more acres of chlorsulfuron, 725 more acres of 

glyphosate, and 63 more acres of picloram as first-choice herbicides (table 17). However, the pdfs, 

herbicide-use buffers, and project caps ensure there would be no measurable adverse effects to soil from 

these differences.

3.5 Water Resources

3.5.1 Introduction

This section analyzes the effects to water resources from herbicide and non-herbicide treatment on 2,124

acres where invasive plants have been identified. The Affected Environment section briefly describes the 

existing conditions of water bodies on the Malheur National Forest, as well as the landscape: geology, 

climate, soil, and stream-flow responses, which are important parameters in the model used to determine 

the fate of the chemical herbicides or assessing the relative risk to water quality of particular sites.

Results of modeling for water and soil concentration are reported in milligrams per liter (mg/l), which is 

the same as parts per million (ppm). Sedimentation from manual methods will be analyzed by 

determining probable affected acres within the scope of major watershed area. 

This section has been updated since release of the DEIS. Some sections have been edited for clarity. The 

GLEAMS modeling was refined to provide for more accurate estimates, and includes a ‘worst case” 

scenario assuming maximum treatment within 100 feet of a stream occurred in a contiguous 10-acre area 

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without any buffers. None of the current infestations near streams are this large, and all action alternatives 

include limitations on herbicide use that were not included in the worst-case model. However, this 

example provides an estimate of the effects of the maximum treatment allowed should invasive plants 

spread within riparian zones. In addition, the GLEAMS model runs using size and location data from 

actual treatment sites was updated to improve the statistical validity of the runs by including additional 

years of historic weather data. This resulted in a small increase in the estimate of amount of herbicide 

reaching the stream. 

The results of the updated modeling indicate that some herbicide may reach streams assuming maximum 

application scenarios, especially in the event of a storm soon after application. However, the amounts of 

herbicide predicted to reach streams is less than the amount that would affect beneficial uses of the stream 

or drinking water.

Regulatory Framework and Compliance

All land management activities on National Forest System lands are to be conducted in accordance with 

LRMP standards and guidelines for water quality and other resource protection. Use of Best Management 

Practices (BMPs) in National Forests is required by the National Forest Management Act (NFMA) and 

prescribed in the LRMPs. Consequently, all land management activities, must be implemented using 

BMPs for control of non-point source water pollution (USDA Forest Service 2011).

The anti-degradation EPA policy 40 C.F. R. Section 131.12 states that existing water quality, even when it 

exceeds required levels for stated beneficial uses will be maintained. Potential effects of the proposed 

action, either through surface runoff of sediment and chemicals or chemicals entering water bodies 

through groundwater sources, do not constitute a significant degradation of quality or impair existing 

beneficial uses.

This project would comply with all Oregon water quality standards and requirements set by the Oregon 

Department of Environmental Quality as well as requirements of Oregon Department of Forestry, Forest 

Practices Rules EC1194, including herbicide use buffers as appropriate and Oregon Administrative Rules 

629-620-000 through 629-6200-0800 for mixing chemicals near streams. No 303(d) streams would be 

adversely affected by the project. 

3.5.2 Affected Environment

Climate

The climate of the Malheur National Forest is cold winters, warm summers, and modest total 

precipitation. Annual average precipitation from weather stations in and around the Malheur National 

Forest range from 11-21” per year, at elevations between 3,000 and 4,600 feet (WRCC 2013). 

Precipitation is distributed across the year, most between the months of October and May as snow, with 

relatively dry summer months. However, the occurrence of the largest events varies considerably; 

sometimes occasional summer convective storms bring high intensity rainfall. Figure 9 shows the Austin 

weather station (elevation 4,200’) for select years. The Austin station is near the headwaters of the Middle 

Fork John Day River, within the Forest boundary. A thirty-day moving average was added in order to 

smooth the graph and clearly show seasonal pattern.

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Figure 9. Precipitation pattern at Austin weather station

Stream Flow

There are few gauged streams in the Malheur National Forest, and fewer yet with overlapping records. 

Two gauges are used here for comparison. The Middle Fork John Day at Ritter (USGS station 

#14044000) (USGS 2013) has a drainage area of 515 square miles. The gauge is at an elevation of 2,545

feet. It drains the northeastern portion of the Malheur National Forest. Strawberry Creek (USGS station 

#14037500) drains 7 square miles of the north flank of Strawberry Mountain. The gauge is at 4,900 feet 

elevation.

Figure 10 shows mean daily flow for the period of record overlap. The patterns of flow are nearly 

identical, though Strawberry Creek lags by a month or more in peak flow. Both are snowmelt dominated 

in terms of peak flow and total yield, between the months of March and May for the Middle Fork, and 

typically June and even early July for Strawberry Creek.

The geology of Strawberry Creek watershed is entirely within the Strawberry Formation, basalt and 

andesite lava rock. The Middle Fork has a majority of its drainage in volcanic rock of the Strawberry, 

Columbia River, or Clarno Groups, but also significant amounts of area in granitics and serpentines and 

meta-volcanics of the Canyon Mountain Complex. The precipitation record from the John Day weather 

station is given as well to show the influence of events. Heavy rainfall in the summer or early fall can 

cause minor peaks in the hydrograph, but the occurrence of annual peak flow and most of the flow yield is 

due to snowmelt runoff in late spring-early summer and is typically regardless of precipitation amount.

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Figure 10. Stream flow at selected gages and precipitation at John Day

Water Quality

The anti-degradation EPA policy 40 C.F. R. Section 131.12 states that existing water quality, even when it 

exceeds required levels for stated beneficial uses will be maintained. The Malheur National Forest Land 

and Resource Management Plan stated direction for water quality is to meet state of Oregon standards 

(IV-2) and comply with state requirements in accordance with the Clean Water Act (IV-39); website: 

http://www.fs.usda.gov/detail/malheur/landmanagement/?cid=fsbdev3_033814

Use of water quality and other resource protection BMPs (USDA Forest Service 2012) in National Forests 

is required by the National Forest Management Act (NFMA). Pertinent practices to this project assure 

proper mixing, application, and clean-up as well as evaluation and monitoring of application that guards

against use on unintended targets. Project design features, particularly parts F, G, and H (table 10) 

incorporate BMPs on the handling of chemicals (Section 5, (8-13).

There are 6,220 mapped miles of stream channel on the Malheur National Forest. About 2,788 miles or 45 

percent of the total is mapped as perennial, meaning flow is typically sustained beyond the influence of 

wet season or snowmelt through most of the year.

Section 303(d) of the Clean Water Act (1972) requires that the state list water bodies on biennial basis that 

do not meet minimum requirements for stated beneficial uses. The State of Oregon Department of 

Environmental Quality is the responsible agency for assessing and listing impaired streams. As of this 

writing, the 2012 report was not complete. The 2010 list is referenced 

(http://www.deq.state.or.us/wq/assessment/assessment.htm). Category 5A streams are those listed and 

needing an EPA approved Total Maximum Daily Load (TMDL) of pollutant allowed to meet water 

quality standards. Category 4A streams are those that have approved TMDL, and have subsequently been 

de-listed from the 303(d). 

Category 4A streams within the Malheur National Forest boundary are the John Day River System, 

including the Middle Fork and South Fork and their tributaries with approved TMDL for temperature. 

Issues are water temperature for life stages of red band and cutthroat trout. Category 5A streams are 

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within the Silvies River system and include Hay, Myrtle, and Skull Creeks for water temperature; and 

within Silver Creek system: Nicoll, Claw, Sawmill, Salt Canyon, and Mainstem Silver for water 

temperature. 

Other streams listed that have insufficient information to determine if they violate standards are the 

Middle Fork John Day and the following tributaries: Long Creek, Deadwood, and Vinegar for bio-criteria

and Long and Summit Creeks for sediment; the Silvies River and following tributaries: Camp, Bear 

Canyon, Van Aspen Antelope for bio-criteria; and main stem Silvies for dissolved oxygen. Finally, the 

upper John Day River is listed for bio-criteria, dissolved oxygen, and sediment.

Table 37. Beneficial uses of major streams on the Malheur National Forest

Category 5A Category 4A Insufficient Information

Temperature Temperature Dissolved 

Oxygen Bio-criteria Sediment

Silvies R. and 

Silver Crk.

M. and S. Fk. John 

Day R. and 

tributaries

Up. John Day 

R.; Silvies R.

M. Fk. John Day R. and 

tributaries (Long, Deadwood and 

Vinegar Crks); Up. John Day R.; 

Silvies R. and tributaries

Up. John Day R., 

Long and Summit 

Crks. on M. Fk. John 

Day R.

Table 38. Drinking water sources

Site Name Source NFS acres in 

watershed Comments

Municipal : Streams with Surface Water Intake

Canyon City Byram Gulch 610 Flows directly from Strawberry Mountain Wilderness

Prairie City Dixie Creek 9,300 0.44 acres of infestation, none within 100 feet of stream

Long Creek23 Tributary of 

Long Creek 224 0.1 acres of infestation

Springs with Formal Agreement

Canyon Creek 

Meadow

EF Canyon 

Creek 4,200 0.2 acres of infestation, none within 200 feet of stream

Dixie Campground Trib. Of Bridge 

Creek 470 0.23 acres of infestation, but none upstream of campground

Idlewild 

Campground Devine Canyon 350 About 0.1 acre of infestation within campground, and 1.0 acre along roads on watershed slopes

Magone Lake 

Campground Lake Creek 150

0.36 acre of infestation along shore of the lake 

downstream of campground and none within 100 feet of 

stream.

Parish Cabin 

Campground Bear Creek 14,000

1.5 acre of infestation along roads within watershed. 0.1 

acre within 100 feet of stream about 5 miles above 

campground

Strawberry 

Campground

Strawberry 

Creek 2,300 No infestation in watershed.

Trout Farm 

Campground

Trib. of John 

Day R. 300 No infestation within watershed

Wells with Formal Agreement

Big Creek 

Campground Big Creek 16,400 7.2 acres of infestation along roads within watershed, about 2 acres within 100 feet of stream

23 Long Creek was inadvertently left out of the table in the DEIS. 

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Site Name Source NFS acres in 

watershed Comments

John Day John Day River 100,000 Unknown

Mount Vernon John Day River 200,000

Seneca Silvies River 123,700

Yellowjacket 

Campground

Yellowjacket 

Creek 3,700

About 7.7 acres of infestation within watershed, and 

about 4.7 acres within campground area. About 2.5 acres 

within 100 feet of stream or reservoir.

Austin House 

Restaurant Bridge Creek 11,000 About 12.5 acres of infestation, most along Highway 26

Invasive Plants Near Roads and Streams

Most mapped invasive plants occur along, or near forest roads. Since roads are preferentially routed up 

valley bottoms to access ridges, they are built alongside higher order (3rd and 4th) streams that constitute 

the majority of the Forest’s perennial streams. Equipment, humans, and livestock travelling along the 

roads is the main avenue for seed distribution, and the disturbed ground immediately adjacent to the road 

running surfaces are common locations for invasive plants.

About 1,491 acres of invasive plant sites are within about 100 feet (33 meters) of roads within the project 

area (see site type #2, chapter 3.1.3) when the portion of infested sites that meet the criteria (not the entire 

site) are considered. This amounts to about 70 percent of total infested acreage.

There is a strong association between forest roads and perennial stream channels. About 2,138 miles of 

the Malheur National Forest System roads are within about 300 feet (100 meters) of stream courses (34 

percent of the total stream mileage). Roads are prone to surface runoff from precipitation events; road 

drainage when in close proximity may discharge directly into streams. The close association of invasive 

plants to roads and roads to perennial streams are important considerations in analysis of herbicide 

transport beyond its point of application.

When only portions of infested sites (not the entire infested acreage in the site) are considered, about 471 

acres of mapped weeds are within 100 feet (33 meters) of streams (see site type #7, chapter 3.1.3).

3.5.3 Environmental Consequences 

Methodology 

Analysis for herbicide effects used published assessments (SERA, 2001, 2004a-d, 2005, 2007, and 2011ad), which provided parameters of degradation in various mediums, adsorption in soil, and solubility in 

water. These parameters were used in the GLEAMS model (in the risk assessments) and GLEAMSDriver utility (for site-specific analyses) to assess potential risk of off-site movement of herbicides,

potential effects to water quality, and effectiveness of stream buffers. Assumptions are that herbicide 

application rates would be no more than the maximum rate (table 21). We conducted runs on four sites on 

the Malheur National Forest, using local soil, precipitation, slope, vegetative cover, and streamflow. The 

start date of the model runs was June 15 of any given year. Applications were modeled once a year on that 

date. 

Spatial and Temporal Context for Effects Analysis 

The project is expected to last at least 5 to 15 years. Repeated treatments, manual, mechanical, or 

chemical may be necessary in sequential years or the same year on the same ground. A soil disturbance or 

persistence of various chemical herbicides may affect soils for a period after treatment.

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General Effects of Herbicide Treatment

During the droughty summers typical for the project area, the soil water content is brought down to very 

low levels through evaporation and osmatic pressure. Whatever water had percolated into the soil column 

beyond the rooting depth will tend to stay in place in the drier months because of lack of hydraulic head. 

In the fall, initial dry soil conditions create a sporadic and weak stream flow response. Most infiltrating 

rainwater is simply absorbed by the soil, filling empty pores and binding to soil particles. Even with a 

high volume of rainfall, stream response may be slight until soil pores fill with water and hydraulic head 

builds.

Herbicides that are highly water soluble or strongly adsorbed to soil particles have the potential to move 

off-site following application. Once into solution, herbicides may transport through the soil with 

groundwater flow, potentially reaching natural surface water bodies. However, as groundwater is 

dispersed through a soil there is also increasing chance that chemicals will adsorb to the soil. 

Runoff risk is particularly high for saturated soils during snowmelt, because of low infiltration capacity. 

Spraying in spring when soil moisture is high and groundwater flow active may pose greater risk to 

transport of chemicals than in early fall when soil moisture content is very low, even under the same 

conditions of precipitation. Chemicals move into the soil with infiltrating precipitation; the depth of 

infiltration affects the ability for soil to assist in herbicide decomposition. Herbicides infiltrating into soil 

with high water content and active groundwater flow may quickly percolate beyond the range of most soil 

biota that would degrade the chemical, increasing the half-live in the soil or ground water. 

To limit risk of off-site movement of herbicides, pdfs H5 and H6 limit herbicide spraying in conditions of 

high water table or saturated soils, and H11 provides parameters on allowable weather conditions for 

spraying. Roadside treatments pose the greatest risk to water contamination from herbicide spraying 

because roadsides are more compacted and promote more runoff, and roadside ditches may have direct 

connection to a stream channel. In these circumstances, ditches may effectively circumvent streamside 

buffers. 

Table 40 gives physical and chemical characteristics of the 11 herbicides proposed for use. These 

characteristics are important in the following discussion of alternatives and analysis based on the 

GLEAMS model.

Table 39. Herbicide physical and chemical properties

Herbicide

Toxicity to 

Aquatic 

Organisms

Adsorption

Water 

Solubility 

(ppm)

Degradation

Half-Life in days unless otherwise noted

Soil 

Microbes

Water and 

Sunlight

Groundwater

Aminopyralid low low 205,000 14-343 0.6 127-447

Clopyralid low low 1,000 12-70 8-40 261

Chlorsulfuron low low 27,900 120-180 ? 37-168

Glyphosate moderate strong 12,000 3-130 4-11 50-70

Imazapic No info moderate >2670 25-142 1-2 30

Imazapyr low low 11-13,500 210-21541 500 stable in 

anaerobic 

conditions

N/A

Metsulfuron 

methyl

low low ≈3,000-10,000 

pH neutral

30-126 7-8 35 +

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Herbicide

Toxicity to 

Aquatic 

Organisms

Adsorption

Water 

Solubility 

(ppm)

Degradation

Half-Life in days unless otherwise noted

Soil 

Microbes

Water and 

Sunlight

Groundwater

Picloram low low 200-400,000 18-300 in 

aerobic 

conditions; 

stable in 

anaerobic

2.6 14 aerobic; 

stable in 

anaerobic 

conditions

Sethoxydim low low 4700 @pH7 1-60 the 

high end of 

range is

anaerobic 

conditions

5-43 155+@ pH7

Sulfometuron 

methyl

low low 300 @ pH7 10-100 20-60 44-113

Triclopyr TEA Inhibits 

fungal and 

bacterial 

growth

low 8,100 14-46 2-6 hours 6 hours

Triclopyr (BEE) high strong 2-23 0.2-40 0.5-8.7

Depending on 

pH

≈6

1 Imazapyr half-life is very long in anaerobic conditions that are rare to non-existent on treatment sites on the MNF. These 

conditions may occur in wetlands and wet meadows.

Herbicides would be sprayed or wicked on leaves and stems of target plants or cut stumps. Herbicide that 

falls onto the soil could travel offsite by surface runoff or groundwater flow.

Once in soil, herbicide not directly absorbed into plant roots is typically metabolized by microbes (Bollag 

and Liu 1990) with the exception of triclopyr, which is degraded by hydrolysis or aqueous photolysis. 

Hydrolysis is the process by which the water molecule breaks down a compound into at least two separate 

constituents. Aqueous photolysis means the aminopyralid breaks down in water in the presence of 

sunlight. 

Half-life of herbicides in soil is affected by its rate of adsorption to soil particles or organic matter 

incorporated into the soil. The stronger the adsorption the more likely chemicals will be retained in top 

soil layers for microbial degradation. Organic matter in particular has an affinity for adsorption.

Degradation proceeds rapidly in presence of sunlight, or by soil microbes when soil moisture is ample. 

Soil moisture of less than 10 percent becomes a limiting factor in microbial activity (Davidson 1998). 

Outside these environments—on the soil surface or within the top few inches of the soil where microbial 

activity is high—the half-life of herbicides is measured in months. All but one of the herbicides is 

relatively highly soluble and will readily transport deep into a soil column with percolating water. The 

notable exception is triclopyr BEE, which only disassociates through hydrolysis very quickly to triclopyr 

TEA, which has moderately high solubility. In soil and water, the conversion of triclopyr BEE and TEA to 

triclopyr acid is rapid. Both BEE and TEA hydrolyze quickly in water. Microbial degradation also 

degrades triclopyr in water.

Surface Runoff

Resistance to surface flow on most natural surfaces is amply provided by vegetation and litter cover. Most 

forest soils have very low runoff potential if undisturbed. Rainfall intensity only rarely exceeds 

infiltration capacity of intact soils with cover.

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Invasive plant treatments are unlikely to remove all vegetation from a site. In some cases, dead invasive 

plants would provide an organic cover on the soil. Project design feature H3 (table 10) avoids spray 

treatment on extensive bare areas or obviously poor surface conditions. In the event of surface runoff 

from a treated area, winnowing of sediment laden sheet flow can be as much as 90 percent effective by a 

vegetative buffer of 100 feet in width, even on steep slopes (Castelle et al. 1994, Castelle and Johnson 

2000, Fischer and Fischinich 2004)

Treatment on roads poses a greater risk to eventual surface water contamination because surface runoff 

from bare and or compacted surfaces within the road prism shed precipitation water more readily and 

frequently than natural slopes. In a study at Lake Tahoe, Grismer and Hogan (2005) showed runoff from 

bare road cut slopes have 10 to 50 times the runoff of similar intact native soils. Further and possibly 

more significant, road prism runoff from running surfaces and cut banks is often facilitated with 

engineered ditches and relief pipes. To the extent that drainage may lead onto natural slopes, road surface 

runoff may be buffered. However, road segments that cross streams or penetrate into stream buffers 

provide routes for contaminants to reach streams, whether from rutted running surface, roadside ditches,

or runoff projected onto natural slopes an inadequate distance from the channel for proper buffering.

Surface sheet flow can carry fine grain soil particles of the order of silts and clays (less than 0.0625 mm 

in diameter). Despite high solubility in water of the herbicides, the typical herbicide molecule has a very 

large mass and some attraction to negatively charge soil particles means that transport in water is only 

likely to occur when attached to soil particles that may be moved by shallow sheet flow.

Soil Water (Interstitial) Transport

Ten of the 11 proposed herbicides are soluble in water with solubility greater than 300 mg/l (Bautista and 

Bulkin 2008). Once into solution, herbicides may transport through the soil as subsurface flow, potentially 

reaching natural surface water bodies. However, another possibility remains; as subsurface water is 

dispersed through a soil, there is also increasing chance that chemicals will adsorb to the soil. The depth 

of a wetting front for precipitation events following herbicide application marks the probable depth of 

penetration of chemicals and an accumulation zone from additional applications of herbicides.

Direct foliar application lowers offsite effects for leaching. If rainfall were to occur during application or 

within the first day after, the risk for leaching exists for all the herbicides. Project design feature H11 

(table 10) lowers leaching risk by avoiding treatment within 24 hours of forecasted rainfall.

Runoff risk is particularly high for saturated soils during snowmelt, because of low infiltration capacity. 

Herbicide application of highly soluble chemicals is avoided during snowmelt when soils are likely to be 

saturated (table 10 pdf H5, H6).

General Effects of Non-Herbicide Treatment

Non-herbicide treatments include manual, mechanical, cultural, and biological. Manual treatment has the 

highest likelihood of impact to water resources. Manual methods are hand-pulling or using hand tools. 

Ground disturbance would occur from drawing up a plant by its roots, or digging sufficiently to leverage 

roots out. Other treatments, such as cutting, clipping, mowing, and mulching, do not disturb the ground. 

There is a short-term risk of erosion from disturbed ground, particularly in a highly infested area, if a 

contiguous patch of ground is disturbed sufficiently to initiate surface erosion, such as a road cut bank or 

fill slope. Post-treatment restoration (passive and active planting, seeding, and mulching) would be part of 

all treatment prescriptions and would help treatment sites recover from ground disturbance. 

The Water Erosion Prediction Program (WEPP) (Elliot 2004) was used to assess, quantitatively the 

impact of manual removal of invasive plants on sediment delivery. This model has a disturbed forest 

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

slope, and a forest road application, so that sediment produced from manual treatment and a typical forest 

road may be compared for amount of sediment produced on a unit area basis of an acre.

The WEPP model was used to estimate the amount of sediment that might be produced from manual 

treatment near streams where about 40 percent of the natural cover is retained. Assuming that the area is 

otherwise not compacted or rutted, about 2 pounds of sediment per acre per year was estimated to be 

produced. If the maximum acreage (treatment cap) within a 6th field watershed within 100 feet of a stream 

were manually treated (50 acres), about 100 pounds of sediment (0.05 tons) would be produced. This 

amount would not be detectable or measurable, and would not have significant effects on water resources

or beneficial uses of water.

Effects of Alternatives

Alternative A – No Action

There would be no direct, indirect, or cumulative effects on water resources from the no-action 

alternative. Invasive plants are not expected to impact hydrology or water quality given the scattered 

types of infestations found within the project area. However, over time, invasive plants could out-compete 

desirable vegetation that helps maintain functional riparian areas and stream conditions (see Chapter 3.6 

for more discussion about how invasive plants affect riparian management goals and objectives). 

Alternative B – Proposed Action – Direct and Indirect Effects

The proposed action would allow spraying of herbicides on up to 2,124 acres per year over the life of the 

project. Some non-herbicide treatments would occur in combination with herbicide treatments, but the 

first year/first choice treatment would be aminopyralid, chlorsulfuron, and metsulfuron, with nonherbicide follow up as needed.

Non-Herbicide Treatments

Non-herbicide treatments for alternative B are unlikely to result in substantial impacts to beneficial uses 

of water. Use of herbicides in combination with manual treatments would minimize the potential for 

sediment delivery from the manual treatments. 

The most ground disturbing activity that might occur is manual treatment within 100 feet of a stream. An 

analysis was done to compare the amount of sediment that might be produced assuming that the 

maximum acreage was manually treated (the treatment that might produce the most sediment) to the 

amount of sediment annually produced by forest roads. The following parameters were used for inputs

into WEPP for the forest road application: 0.5 percent grade, 14 feet wide, insloped but not ditched with 

medium traffic.

Idaho Creek-Summit Creek HUC6 was used because it currently has the largest concentration of mapped 

invasive plants at that watershed level within 100 feet of a stream; a total of 51.29 acres. Also within the 

Idaho Creek-Summit Creek watershed is 10.9 miles of forest roads within 100 feet of a stream, or 

approximately 18.5 acres of running surface, which equals 37 tons of sediment per year versus 0.05 ton

from manual treatment. The road surfaces are contributing sediment every year though rates will vary 

widely according to slope and drainage. The cap of 50 acres of treatment per year within 100 feet of a 

stream in a 6th field watershed would ensure that sediment delivery to streams would be minimal.

Herbicide Treatments

The Groundwater Loading Effect of Agricultural Management Systems (GLEAMS) model (Website: 

http://www.tifton.uga.edu/sewrl/Gleams/gleams_y2k_update.htm), was used to examine the fate of 

herbicides in the rooting zone of the soil. It may be modified for site-specific parameters of climate, soils, 

topography, vegetation cover and size, flow rate of natural water bodies, and application rate of 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

herbicides. All runs shown in table 41 and table 42 below used Austin 3S weather station near Austin 

Oregon. The GLEAMS model incorporates climate data from local stations, in this case the station at 

Austin was chosen because it was close to the main area of infested sites on the Forest: the upper Middle 

Fork John Day River. The Cligen program developed by the National Soil Erosion Research Lab uses real 

weather data to generate simulated yearly data (Website: 

http://www.ars.usda.gov/Research/docs.htm?docid=18094), and is uploaded by the GLEAMS program. 

Results of GLEAMS runs are shown for four selected sites (figure 11). The size, shape, configuration and 

field conditions differ between the four sites. Results of GLEAMS runs are shown in table 41 and table 

42 on selected sites. The location of the selected sites is displayed in figure 11. We modeled the results of 

using any of the 11 herbicides at these sites, however, only the first-choice herbicide and other effective 

herbicides described in table 8 would likely be used, unless a new target species were to occupy these 

sites and need treatment under our EDRR proposal. In all model runs, the maximum application rate was 

used to calculate concentrations in the soil and in a non-treated area below the treatment site. The 

GLEAMS model does not explicitly incorporate the effects of treatment distance from a stream; however, 

the amount of herbicide predicted to be delivered to a non-treated area below a treated area can be used to 

predict the amount of herbicide that could eventually reach the stream. One application of chemicals was 

assumed per year. For reported concentrations, 0.001 mg/l is approximately 1 ppb (part per billion) and 

1mg/l is approximately 1 ppm (part per million).

Table 41 describes Site #1 (Ennis Creek). This site was modeled assuming a worst-case scenario for 

alternative B. The modeled run assumed 10 acres are treated to the edge of this 2 cfs stream. The infested 

area is approximately 3 acres; however, the acreage was increased in order to model the maximum 

amount of herbicide that might reach the stream given the EDRR cap of 10 riparian treatment acres within 

a 6th field watershed. The model run assumed that 100 percent of the 10 acres are treated using the 

maximum allowable herbicide use rate. Triclopyr TEA is the formulation used in the model because 

triclopyr BEE would only be used in upland sites far from water. Herbicide use buffers were not explicitly 

modeled for these runs. 

Table 40. Results for GLEAMS model run site 1, alternative B

Dominant soil 

series/map 

location

Soil series/ 

Texture

General 

Surface 

Condition

Herbicide

App’l 

Rate 

(lbs/acre 

a.i.)

Conc. 

At 12”

(Mg/l)

Conc. 

At 

36”

(Mg/l)

Water 

Peak 

Conc.’

(Mg/l)

Invasive: sulphur 

cinquefoil

First choice: 

metsulfuron 

methyl

Location: T12S 

R31E S18,

Road: 

maintenance 

Level 2 Road # 

3940

HUC6: Beech

Stream name: 

Ennis Creek

Model Run 

Humarel soil 

series

Very gravelly 

clay loam, very 

cobbly clay, 

moderately 

deep, 31 inches

Native surface 

road in conifer 

forest with fair 

grass cover, 

high runoff 

potential, poor 

surface condition

Treatment area: 

2800 feet long, 

50 feet wide 

centered on 

road, 0-100 feet 

from stream. Hill 

slope gradient 

20%

Aminopyralid 0.11 0.0192 0.0 0.0000

Chlorsulfuron 0.13 0.0432 0.0 0.0007

Clopyralid 0.5 0.0983 0.0 0.0001

Glyphosate 3.5 0.6283 0.0 0.0000

Imazapic 0.19 0.0566 0.0 0.0014

Imazapyr 0.70 0.1644 0.0 0.0019

Metsulfuron 

Methyl 0.075 0.0240 0.0 0.0030

Picloram 1.00 0.2911 0.0 0.0040

Sethoxydim 0.47 0.0891 0.0 0.0009

Sulfometuron 

methyl 0.38 0.0712 0.0 0.0002

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Dominant soil 

series/map 

location

Soil series/ 

Texture

General 

Surface 

Condition

Herbicide

App’l 

Rate 

(lbs/acre 

a.i.)

Conc. 

At 12”

(Mg/l)

Conc. 

At 

36”

(Mg/l)

Water 

Peak 

Conc.’

(Mg/l)

design flow

2cfs Triclopyr TEA 6.00 1.3363 0.0 0.0045

All values in mg/l (ppm)

The site-specific location and current size of the treatment site was modeled for sites 2 through 4 (table 

42). In Site 2, the road crosses the stream so there is the possibility of runoff from the road surface and the 

treated area adjacent to the road surface entering directly into the stream. Road cuts may intercept 

groundwater flow, which are classified as seeps. Forest soils besides roads may also be areas of 

seasonably high water tables. . 

Table 41. Results for GLEAMS model runs sites 2-4, alternative B 

Dominant soil 

series/map location

Soil series/ 

Texture

General 

Surface 

Condition

Herbicide 

Suite

Conc. In 

Soil 

(12”)

Conc. In 

Soil (36”)

Peak 

Conc. In 

Water**

Site# 2

Invasive: Canada 

thistle

First Choice: 

Aminopyralid

Location: T10S 

R34E S35

Road: Maintenance 

Level 2 Road #7106

HUC6: Camp Creek

Stream name: 

unnamed

Model Run design

flow

2cfs

Five Beaver soil 

series

gravelly silt 

loam/extremely 

cobbly silt loam, 

shallow depth, 14 

inches

Native surface 

road in conifer 

forest with fair 

grass cover, 

high runoff 

potential, poor 

surface 

condition

Treatment area 

1800 feet long 

50 feet wide 

centered on 

road, 350 to 700 

feet from 

stream. Hill 

slope gradient 

27%

aminopyralid

chlorsulfuron

clopyralid

glyphosate

imazapic

imazapyr

metsulfuron

methyl

picloram

sethoxydim

sulfometuron

methyl

triclopyr TEA

0.0334

0.0311

0.1055

0.6486

0.0582

0.0227

0.0248

0.3030

0.0919

0.0807

1.3705

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0002

0.0001

0.0002

0.0001

0.0003

0.0001

0.0001

0.0012

0.0002

0.0003

0.0009

Site#3

Invasive: St. 

Johnswort

First choice: 

aminopyralid

Location: T10S 

R34E S32,

HUC6: Camp Creek

Stream name: 

Granite Boulder 

Melloe soil series

Loam/very cobbly 

sandy clay loam, 

very deep, 79

inches

Conifer forest, 

excellent grass, 

moderate runoff 

potential

Treatment area: 

350 feet X 500 

feet along 

Granite Boulder 

Creek and 

below Road 

4611 Hill slope 

aminopyralid

chlorsulfuron

clopyralid

glyphosate

imazapic

0.0268

0.0302

0.1000

0.6282

0.0570

0.0115

0.0101

0.0348

0.2094

0.0190

0.0000

0.0000

0.0000

0.0000

0.0001

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

Dominant soil 

series/map location

Soil series/ 

Texture

General 

Surface 

Condition

Herbicide 

Suite

Conc. In 

Soil 

(12”)

Conc. In 

Soil (36”)

Peak 

Conc. In 

Water**

Creek, bull trout 

spawning/rearing

Model Run design 

flow 10cfs

3%

imazapyr

metsulfuron

methyl

picloram

sethoxydim

sulfometuron

methyl

triclopyr TEA

0.2086

0.2190

0.2809

0.0892

0.0785

1.3358

0.0697

0.0076

0.0992

0.0297

0.0262

0.4453

0.0002

0.0000

0.0002

0.0000

0.0001

0.0001

Site#4

Invasive: 

houndstongue

First choice: 

chlorsulfuron

Location: T11S 

R35E S34,

Road: maintenance 

Level 2 Road # 2255

HUC6: Clear Creek

Stream name: Clear 

Creek/bull trout 

spawning—rearing

Model Run design 

flow

2cfs

Wonder soil series,

Gravelly silt 

loam/gravelly 

loam, very deep, 

79 inches

Native surface 

road in conifer 

forest with fair 

grass cover, 

high runoff 

potential, poor 

surface 

condition

Treatment area 

1,180 feet long 

and 50 feet wide 

centered on 

road, 180 to 250 

feet from stream

aminopyralid

chlorsulfuron

clopyralid

glyphosate

imazapic

imazapyr

metsulfuron

methyl

picloram

sethoxydim

sulfometuron

methyl

triclopyr*

TEA

0.0216

0.0310

0.0540

0.6484

0.0577

0.2117

0.0246

0.2895

0.0982

0.1126

1.3707

0.0103

0.0104

0.0356

0.2161

0.0192

0.0706

0.0082

0.0976

0.0306

0.0269

0.4659

0.0003

0.0001

0.0001

0.0000

0.0003

0.0008

0.0001

0.0001

0.0002

0.0002

0.0010

All values in mg/l (ppm)

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Figure 11. Location in Middle Fork John Day River of GLEAMS model sites

Purple shaded streams are bull trout spawning and rearing; green shading is invasive plants sites

Results indicate that herbicide concentrations in the water are at least 3 orders of magnitude less than 

levels of concern for fish, amphibians and aquatic invertebrates. However, the threshold of concern for 

aquatic plants was exceeded for the sulfonylurea herbicides (chlorsulfuron, metsulfuron methyl and 

sulfometuron methyl). These exceedances are unlikely to affect the aquatic environment because (1) the 

threshold of concern is at least 10 times less than the amount that killed an aquatic plant, (2) the project 

design features, herbicide use buffers and project caps reduce the potential for the modeled concentration 

to actually reach a water body, and (3) the potential impacts would occur in a single stream reach within a 

6th field watershed. The herbicide use buffers, limitations on broadcast and spot treatments within 100 

feet of streams, and caps on treatments within 6th field watersheds reduce the potential for aquatic plants 

to be killed. Beneficial uses of water would not be adversely affected at any meaningful scale. 

None of the predicted peak concentrations in water exceeds drinking water standards as defined by the 

State of Oregon (2004). Ninety-one different contaminants currently have concentration standards 

including glyphosate (0.7mg/l limit) and picloram (0.5 mg/l). In both cases, predicted water 

concentrations are 3 to 4 orders of magnitude lower than for the chemicals with stated thresholds. The 

EPA has established advisory benchmarks for drinking water for the other nine herbicides proposed for 

use in this project (EPA 2013). The benchmarks are the same as the acute threshold of concern used in the 

SERA Risk Assessments. Use of these herbicides would not exceed these thresholds (e.g., Hazard 

Quotients are less than 1).

Effectiveness of Buffers

Bakke (2001) in a review of monitoring results after herbicide spraying on Eldorado and Stanislaus 

National Forests found that buffers of greater than 20 feet were completely effective in eliminating 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

glyphosate and triclopyr in detectable levels (about 0.5 parts per billion) in adjacent streams. Slight but 

detectable levels (0.5-2.4) were found when buffer widths were 10-15 feet for glyphosate on the 

Stanislaus National Forest.

Berg (2004) in a comprehensive review of Best Management Practices associated with herbicide spraying 

in region 5 and elsewhere in the United States found similar results. Detectable levels of herbicides, such 

as glyphosate, triclopyr, and clopyralid, were found in various locations (Washington, Oregon, New York,

and Florida) mainly as a result of drift from boom broadcast spray or aerial application. An Oregon 

Department of Transportation study sampled runoff from road shoulders after treatment of Glyphosate, 

with no buffers on a stream. Under simulated rainfall of high intensity, they found 100s of ppb could be 

transported off site. In a similar test, under natural rainfall 0.1-1 ppb was detected leaving the road prism.

The results of these studies show that the GLEAMS results for this project are reasonable, and that the 

greatest risk is from roads with direct hydrologic connection to stream channels.

Drinking Water Sources

Sources for public drinking water located in watersheds entirely or partially on the forest are listed in the 

affected environment section. The GLEAMS runs demonstrate that surface and ground sources (streams, 

springs, and wells) would not be contaminated and concentrations of chemicals in water would be well 

below thresholds of concern for human consumption.

Direct and Indirect Effects of Alternative C

Alternative C would have no herbicide use within 100 feet of a stream channel. Providing for increased 

buffer would reduce the amount of herbicide that could reach a stream. The Ennis Site (#1) was run in 

GLEAMS assuming maximum application rates for 10 acres approximately 100 feet above the stream. 

Picloram was not run because it would not be used in this alternative. Aminopyralid and glyphosate were 

not run because the result from an application directly adjacent to the stream resulted in zero

concentration in water. 

Table 42. Results for GLEAMS model run site 1, alternative C

Herbicide App’l Rate 

(lbs/acre a.i.)

Water Peak Conc.

(Mg/l)

Change from 

Alternative B Water 

Peak Conc.

Chlorsulfuron 0.13 0.0000 -0.0007

Clopyralid 0.50 0.0000 -0.0001

Imazapic 0.19 0.0001 -0.0013

Imazapyr 0.70 0.0004 -0.0015

Metsulfuron methyl 0.075 0.0000 -0.0030

Sethoxydim 0.47 0.0001 -0.0039

Sulfometuron methyl 0.38 0.0000 -0.0009

Triclopyr TEA 6.00 0.0000 -0.0002

All values in mg/l (ppm)

The result of this run demonstrates that the 100-foot buffer would reduce the amount of herbicide 

reaching the stream assuming maximum application rates. A 100-foot buffer would effectively eliminate 

chlorsulfuron, clopyralid, metsulfuron methyl, sulfometuron methyl, and triclopyr from reaching Ennis 

Creek. Small amounts (less than 1 ppb) of imazapic, imazapyr, and sethoxydim could reach the stream;

however, all results are under a threshold of concern for aquatic organisms and other beneficial uses. The 

herbicide rate and method restrictions and treatment caps would further reduce the potential for water 

contamination. 

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Alternative C would increase the reliance on non-herbicide methods within 100 feet of streams and other 

water bodies. There is the potential for increases in sediment delivery to streams , however this level of 

activity is well below current delivery rates and likely not at measurable levels in streams which contain 

aquatic resources.

Direct and Indirect Effects of Alternative D

Effects of alternative D would be similar to alternative B, except an LRMP amendment would not be 

completed and aminopyralid would not be approved for use on the Malheur National Forest. 

Aminopyralid would not be used to treat known sites or new detections. Compared to alternative B, more 

picloram, clopyralid, and glyphosate would likely be used in lieu of aminopyralid. Herbicide treatment 

could be up to 2,124 acres per year under this alternative.

Glyphosate has high water solubility, but also has very strong adsorption qualities, and in the GLEAMS

model runs never penetrated beyond 8 inches into the soil. It also has a moderately higher toxicity to 

aquatic organisms than the other chemicals being considered here; however, never in the model runs 

because of adsorption rate did it register detectable limits of concentration in water. Model runs assume 

high maximum application rates of 7 pounds per acre. This is greater than the typical rate of 1 pound per 

acre (typical FS rate in 2011 risk assessment). It is not expected that wider use of glyphosate due to 

selection of this alternative would lead to water concentrations higher than the model results.

Picloram has very high water solubility, low adsorption rate to soil, and is very stable under anaerobic 

conditions, so the chemical has a high ability to transport with groundwater. Otherwise, it has average or 

even low persistence in research studies. Still, its toxicity to fish and invertebrates is relatively high, and 

because of it transportability and persistence in sediments (where anaerobic conditions might prevail), it 

poses one of the greatest environmental risks of the entire suite of chemicals being proposed.

Clopyralid has moderately low solubility and soil absorption rate. Toxicity to aquatic organisms is also 

low with LC50 concentrations many orders of magnitude above modeled runs. Clopyralid, however, has 

high resistance to degradation, particularly in absence of sunlight. Nonetheless, it is not expected that 

increased use of clopyralid will pose greater risk than model results imply.

Cumulative Effects for All Action Alternatives

Water Temperature 

No measurable increases in water temperature are expected to occur as a result of the invasive plant 

treatments proposed. While the high water temperature may be attributed to loss of shade from past 

activities, such as building roads, logging, and grazing, this project does not have the potential to result in 

a loss of shade. The type of plants that would be removed from streamside areas and the treatment caps 

would minimize potential for water temperature increases. All foreseeable future projects would be 

planned to retain shade and would not combine with this project to increase water temperature.

Water Chemistry 

No measurable increases in pH or chlorophyll a or decrease in dissolved oxygen (DO) are expected to 

occur as a result of the invasive plant treatments proposed. There would not be cumulative effects to pH, 

DO, or chlorophyll a. 

Herbicides in Water

Most of the National Forest System lands being analyzed for this FEIS are in headwater areas (upstream 

of other sources of herbicides). Some agricultural use, and therefore probably herbicide use, may occur 

upstream of National Forest System lands. The potential for accumulation downstream would be based on 

the potential for herbicide from agricultural use to reach the water in a measurable amount to where the 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

Forest Service proposes treatment, and then for there to be a measurable amount from Forest Service 

treatments, so the two sources could combine. Several conditions make this highly unlikely. First, 

herbicide use on agricultural lands would have to reach the stream in sufficient quantity to not be diluted 

downstream. Research by Evans and Duseja (1973), however, found picloram concentrations diluted 85 

to 98 percent 100 meters (328 feet) below treatments areas and below detection levels at 1000 meters 

(3281 feet) following a 1.5” rainstorm within the first week of spraying. Application rates were 1 and 2 

lb/ac (3 to 6 times the typical application rate) on test plots ranging from 1 to 2 acres.

The project design features, herbicide use buffers, and treatment caps are likely to prevent herbicide from 

reaching streams in measurable or harmful concentrations. Any herbicide reaching the stream would be 

quickly diluted as it moved downstream. The amount of herbicide potentially reaching a common 

downstream point and combining with chemicals from agricultural uses is very low and would not result 

in cumulative effects. Mixing and dilution of any trace amount of herbicide that may result from invasive 

plant treatment would occur quickly, making it highly unlikely that herbicide concentrations would be 

additive or synergistic with similar treatments at the watershed scale. 

The result of the GLEAMS model runs on various scenarios of sites within the project area is consistent 

with results of several monitoring studies reviewed by Bakke (2001) and Berg (2004). Amounts of 

herbicides in streams are predicted to be below levels of concern for aquatic health. Effect of manual 

treatment on water quality is slight to unmeasurable (R6 FEIS 2005 Appendix J) and adverse impacts 

would be minimal in this alternative. 

Invasive plants are throughout the Malheur National Forest but concentrated in the Middle Fork John Day 

drainage. Half-life period, solubility, or adsorption of each herbicide determines how readily each will 

transport off site. The greatest risk to water contamination is the possibility of transport of residue 

herbicide on roads that have direct connection to a stream channel. In these circumstances, engineered 

drainage features may circumvent buffers. Herbicide half-life period and pdfs that limit retreatments of 

more persistent herbicides largely preclude cumulative effects from multiple treatments over a series of 

years at each site. 

While no other herbicide use would be planned on the Forest, Chapter 3.1.5 describes the herbicide use 

that might occur in surrounding areas. However, the amount of herbicide potentially reaching a common 

downstream point would not be detectable. Thus, there would be no contribution to cumulative effects 

from herbicide delivery to streams. Expected mixing and dilution of any trace amount of herbicide that 

may result from invasive plant treatment would occur quickly, making it highly unlikely that herbicide 

concentrations would be additive or synergistic with other herbicide use at the watershed scale, especially 

considering that no more than 10 acres within 100 feet of any water body in a 6th field watershed would 

be treated with herbicide in a single year.

Sediment Delivery

A list of forestwide projects are scheduled (2013-2015) that will be concurrent with the proposed action 

(table 28). These projects include prescribed burning, plantation thinning, replacing road culverts, road 

decommissioning, snow park relocation, aspen release, juniper thinning, toilet replacement, commercial 

timber harvest, parking lot paving, gate replacement, demolition of a structure by explosion, and fencing. 

Most of the activities will involve a level of ground disturbance and risk increasing sediment delivery to 

streams. However, since the amount of sediment that would reach streams in alternative B is very low in 

comparison to background levels, there would be no potential for sediment to accumulate with sources 

from other projects or activities in the watersheds. 

Livestock grazing near streams may also result in sediment delivery. Surface erosion can result from 

trampling and trailing but the primary affect is to channel condition. Channel condition can be affected by 

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

hoof action (i.e., trampling, hoof shear, post holing) and the reduction and vigor of palatable woody 

streamside vegetation. It is not possible to quantify livestock generated sediment because of the dispersed 

character of the impacts, problems with distinguishing between cattle and wildlife impacts, inability to 

attribute or portion channel affects specifically to livestock, and inability to separate long term (decades) 

affects from past management or events from current management. Allotment management is expected to 

result in increased riparian protection and less sediment production from grazing

3.6 Fisheries

3.6.1 Introduction

Fish species of special conservation concern (e.g., federally listed, USFS sensitive, USFS management 

indicator species) within the aquatic environment analyzed in this report include the native bull trout, 

middle Columbia River steelhead, middle Columbia River Chinook salmon (including essential fish 

habitat), redband (rainbow) trout, and westslope cutthroat trout (table 44). In addition, one USFS sensitive 

aquatic macroinvertebrates and one amphibian species are addressed. All aquatic species of special 

conservation concern (and their habitat) will be analyzed for both effects to individuals and effects to 

habitat.

During public scoping, concerns were raised about the use of herbicides near streams or other surface 

water that may result in herbicide concentrations in water that are harmful to fish (particularly ESA listed 

fish and native fish) and other aquatic organisms. Manual and mechanical treatments can also affect water 

quality, fish, and other aquatic species by disturbing riparian structure or increasing sedimentation. This 

report estimates effects to aquatic species and their habitat from herbicide and non-herbicide treatment 

methods. 

Detailed analyses of federally listed fish species are provided in the project biological assessment (for 

preferred alternative only). USFS sensitive aquatic species are analyzed in the project biological 

evaluation (for all EIS action alternatives).

PACFISH and INFISH are programmatic strategies to help maintain and restore aquatic habitats on the 

Malheur National Forest and other Forests east of the Cascade Mountains. Riparian Management 

Objectives (RMOs) are identified in these strategies and Forest projects are designed to contribute to 

meeting these objectives, or at least not block attainment of RMOs. Our progress toward maintaining and 

restoring good fish habitat is measured at the 3rd to 6th order streams scale, based on measurable indicators 

of good fish habitat.

The indicators are pool frequency, water temperature, amount of large woody debris, lower bank angle of 

the creek, and width to depth ratio. These indicators are addressed through the matrix of pathways and 

indicators discussed for fish species.

Treatments authorized under this invasive plant treatment project could be implemented as part of aquatic 

habitat restoration activities on the Forest. The long-term intent is to restore native plant communities to 

the extent possible. However, treatments near the aquatic environment have the potential for short-term 

adverse impacts. In general, these adverse impacts are very small in comparison to the benefits of 

restoration.

A biological assessment has been prepared and the effects of this action have been discussed with FWS 

and NMFS. Based on the assessment and discussions, including additional or revised project design 

features, the Forest Service has determined that this project will not adversely affect any listed fish 

species or their habitat (see discussion in 3.6.3). A Record of Decision for this project will not be signed 

until the Forest Service receives a letter of concurrence from FWS and NMFS. 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

Regulatory Framework

The Executive Order 12962 of 1995 (aquatic systems and recreational fisheries) requires federal agencies 

to conserve, restore, and enhance aquatic systems to provide for increased recreational fishing 

opportunities nationwide. The Order requires federal agencies to evaluate the effects of federally funded 

actions on aquatic systems and document those effects relative to the purpose of this order.

The two principle laws relevant to fisheries management are the National Forest Management Act of 1976 

(NFMA) and the Endangered Species Act (ESA) of 1973, as amended (16 U.S.C. 1531 et seq.). Direction 

relative to fisheries is as follows:

• NFMA requires the Forest Service to manage fish and wildlife habitat to maintain viable populations 

of all native and desirable non-native wildlife species and conserve all listed threatened or endangered 

species populations (36CFR219.19).

• ESA requires the Forest Service to manage for the recovery of threatened and endangered species and 

the ecosystems upon which they depend. Forests are required to consult with the U.S. Fish and 

Wildlife Service (USFWS) or the National Marine Fisheries Service (NMFS) if a proposed activity 

may affect the population or habitat of a listed species.

The Malheur National Forest Land and Resource Management Plan (LRMP) as amended (USDA Forest 

Service 1990), provides direction to protect and manage resources. The specialist report cites a detailed 

list of the portions of the Forest LRMP relevant to fisheries and fisheries habitat requirements. In 

addition, Forest standards and guidelines along with relevant laws are cited. Of special interest are Forest 

LRMP amendment 29 and PACFISH/INFISH (1995). Recommendations regarding fisheries habitat 

would adhere to this regulatory framework.

Fish-bearing streams are assigned 600-foot-wide (total width) riparian habitat conservation areas 

(RHCAs), as defined within PACFISH/INFISH. RHCA widths along other streams in the Project Area

vary depending on whether streamflow is perennial or intermittent. Treatment within RHCAs would be 

designed to follow PACFISH/INFISH goals and requirements. Specific to this project is 

PACFISH/INFISH standard RA-3: “Apply herbicides, pesticides, and other toxicants, and other chemicals 

in a manner that does not retard or prevent attainment of the Riparian Management Objectives [RMOs] 

and avoids adverse effects on inland native fish (INFISH)/ listed anadromous fish (PACFISH).”

Key Watersheds: The intent of designating Key Watersheds is to provide a pattern of protection across 

the landscape where habitat for fish species of special conservation concern would receive increased 

attention and treatment. Priority within these watersheds would be to protect or restore habitat for listed 

stocks, stocks of special interest or concern, or salmonid assemblages of critical value for productivity or 

biodiversity. Criteria considered to designate Key Watersheds are:

1. Watersheds with stocks listed pursuant to the ESA, or stocks identified in the 1991 American 

Fisheries Society report as “at risk” or subsequent scientific stock status reviews; or 

2. Watersheds that contain excellent habitat for mixed salmonid assemblages; or

3. Degraded watersheds with a high restoration potential

Threatened and endangered species are listed under the ESA whereas sensitive species are identified by 

the Forest Service Regional Forester. An endangered species is an animal or plant species that is in danger 

of extinction throughout all or a significant portion of its range. A threatened species is an animal or plant 

species that is likely to become endangered within the foreseeable future throughout all or a significant 

portion of its range. A sensitive species is an animal or plant species where viability is a concern either a) 

because of current or predicted downward trend in population numbers or density or b) because of current 

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or predicted downward trends in habitat capability that would reduce a species’ existing distribution. 

LRMP Standard 62 (p. IV-32) gives direction to meet all legal and biological requirements for the 

conservation of threatened and endangered plants and animals.

The Magnuson-Stevens Fishery Conservation and Management Act (MSA), as amended by the 

Sustainable Fisheries Act of 1996 (Public Law 104-267), requires the inclusion of Chinook salmon 

Essential Fish Habitat (EFH) descriptions in Federal fishery management plans. In addition, the MSA 

requires Federal agencies to consult with NMFS on activities that may affect EFH.

Management Indicator Species (MIS) are vertebrates and invertebrates whose population changes are 

believed to best indicate the effects of land management activities. Through the MIS concept, the total 

number of species found within the Forest is analyzed using a subset of species that collectively represent 

habitats, species, and associated management concerns. The MIS are used to assess the maintenance of 

populations (the ability of a population to sustain itself naturally) and biological diversity (which includes 

genetic diversity, species diversity, and habitat diversity), and to assess effects on species in public 

demand. LRMP Standard 61 (p. IV-32) lists species and gives direction to provide for habitat 

requirements of MIS species. Aquatic MIS on the Forest include rainbow/redband trout, bull trout, and 

steelhead trout.

3.6.2 Affected Environment

Aquatic Species of Conservation Concern

Table 44 describes aquatic species of conservation concern on the Malheur National Forest. It includes the 

status of each species, whether it is documented or suspected to occur on the Forest, and other specific 

information about the populations that could be affected by forest activities. 

Table 43. Aquatic species of conservation concern

Species Status Occurrence Note

Middle Columbia River steelhead 

(Oncorhynchus mykiss)

Federally threatened, 

designated critical habitat

Documented 

occurrence

Middle Columbia River distinct 

population segment (DPS)

Bull trout (Salvelinus confluentus) Federally threatened, 

designated critical habitat

Documented 

occurrence

John Day and Malheur species 

management units (SMUs)

Middle Columbia River Chinook 

salmon (Oncorhynchus 

tshawytscha)

Essential fish habitat and 

USFS sensitive

Documented 

occurrence Essential fish habitat (EFH)

Redband trout (Oncorhynchus 

mykiss gairdneri) USFS sensitive* Documented occurrence Widespread

Westslope cutthroat trout 

(Oncorhynchus clarkia lewisi ) USFS sensitive* Documented occurrence

Present in John Day River and 

tributaries

Western ridged mussel (Gonidea 

angulata) USFS sensitive* Documented occurrence

Only known in Middle Fork John 

Day River

*From 2011 Region 6 list.

Steelhead

Steelhead (Middle Columbia DPS, MCR steelhead) was listed by NMFS as threatened under the Federal 

Endangered Species Act (ESA) on March 25, 1999 (64 FR 15417). Middle Colombia River steelhead are 

also a Malheur National Forest management indicator species (MIS). Critical habitat for MCR steelhead 

was designated on September 2, 2005 (70 FR 52630). 

Life History (NatureServe 2013): Migrates between freshwater breeding and marine nonbreeding habitats. 

Steelhead typically spend 2 years in fresh water, migrate to marine waters where they spend 2-3 years, 

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then return to natal stream to spawn. Most middle Columbia River steelhead smolt at 2 years and spend 1-

2 years in salt water prior to re-entering fresh water, where they remain up to a year before spawning. 

First-time spawners generally are 4-5 years old. Individuals are capable of spawning more than once 

before they die, though spawning more than twice is rare. Steelhead eggs incubate 1.5-4 months before 

hatching (varies with temperature). Juveniles spend 1-4 (generally 2) years in fresh water before 

migrating to the ocean as smolt.

Steelhead are capable of surviving in a wide range of temperature conditions. They do best where 

dissolved oxygen concentration is at least 7 ppm. In streams, deep low velocity pools are important 

wintering habitats. Freshwater habitat types utilized include big and medium rivers, creeks, low to high 

gradient pools, and riffles. They usually requires a gravel stream riffle for successful spawning. Eggs are 

laid in gravel in a depression made by the female. Salinity of 8 ppt. is the upper limit for normal 

development of eggs and alevins.

John Day River Status (ODFW 2009): The John Day River Major Population Group (MPG) covers 

Oregon’s John Day River drainage. The MPG contains five extant populations (Lower Mainstem John 

Day, North Fork John Day, Middle Fork John Day, South Fork John Day, and Upper Mainstem John 

Day). Steelhead in these populations are exclusively summer steelhead. The MPG is one of the few 

remaining summer steelhead groups in the Interior Columbia basin that has had no intentional influence 

from introduced hatchery steelhead and that has recently been classified as strong or healthy. Spawning is 

widely distributed across tributary and mainstem habitats.

The Lower Mainstem John Day River population includes tributaries to the John Day River downstream 

of the South Fork John Day River. This widespread population is the most differentiated ecologically 

from other populations, occupying the lower, drier, Columbia Plateau ecoregion. The North Fork John 

Day River population occupies the highest elevation, wettest area in the John Day basin. Population 

boundaries include the main stem and tributaries of the North Fork John Day River. The population was 

defined based on habitat characteristics, basin topography, and demographic patterns. The Middle Fork 

John Day River population resides in the Middle Fork John Day and all its tributaries. Spawning areas in 

the Middle Fork John Day River are separated substantially from all other spawning areas; except for 

those in the North Fork John Day, that exhibit different habitat characteristics.

Table 44. Special Status Fish in John Day River Watersheds

Watershed Population Current Risk Status

North Fork John Day Highly viable

Upper Mainstem John Day Moderate risk

Lower Mainstem John Day Moderate risk

Middle Fork John Day Moderate risk

South Fork John Day Moderate risk

The following are major limiting factors for the John Day River MPG:

Main limiting factors and threats:

♦ Degraded tributary habitat

♦ Mainstem passage

♦ Hatchery related effects

♦ Predation/competition/disease in mainstem and estuary

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Within the analysis area, there are approximately 409 miles of designated critical habitat, dispersed 

throughout 15 watersheds (table 44). A detailed biological assessment (BA) will be prepared for the 

preferred alternative and ESA Section 7 Consultation with the National Marine Fisheries Service (NMFS) 

is underway.

Bull Trout

Bull trout were listed by the USFWS as threatened under the Federal ESA on June 10, 1998 (63 FR 

31647). In 2010, critical habitat for bull trout was revised by the U.S. Fish and Wildlife Service, with 

many previously excluded streams within the analysis area becoming designated by the new rule (75 FR 

63898, FWS-R1-ES-2009-0085). Bull trout are also a Malheur National Forest management indicator 

species.

The analysis area includes portions of both the John Day and Malheur bull trout species management 

units (SMUs).

Life History (USDI 2002): Bull trout have more specific habitat requirements than most other salmonid. 

Habitat components that influence bull trout distribution and abundance include water temperature, cover, 

channel form and stability, substrate for spawning and rearing, and migratory corridors. Bull trout are 

found in colder streams and require colder water than most other salmonid for incubation, juvenile 

rearing, and spawning. Spawning and rearing areas are often associated with cold-water springs, 

groundwater infiltration, and/or the coldest streams in a watershed. Throughout their lives, bull trout 

require complex forms of cover, including large woody debris, undercut banks, boulders, and pools. 

Alterations in channel form and reductions in channel stability result in habitat degradation and reduced 

survival of bull trout eggs and juveniles. Channel alterations may reduce the abundance and quality of 

side channels, stream margins, and pools, which are areas bull trout frequently inhabit. Spawning and 

early rearing bull trout require loose, clean gravel relatively free of fine sediments. Because bull trout 

have a relatively long incubation and development period within spawning gravel (greater than 200 days), 

transport of bedload in unstable channels may kill young bull trout. Bull trout use migratory corridors to 

move from spawning and rearing habitats to foraging and overwintering habitats and back. Different 

habitats provide bull trout with diverse resources, and migratory corridors allow local populations to 

connect, which may increase the potential for gene flow and support for refounding of populations. 

Declines in bull trout distribution and abundance are the results of combined effects of the following: 

habitat degradation and fragmentation; the blockage of migratory corridors; poor water quality; angler 

harvest and poaching; entrainment (process by which aquatic organisms are pulled through a diversion 

structure or other device) into diversion channels and dams; and introduced non-native species. Specific 

land and water management activities that continue to depress bull trout populations and degrade habitat 

include dams and other diversion structures, forest management practices, livestock grazing, agriculture, 

road construction and maintenance, mining, and urban and rural development. Some threats to bull trout 

are the continuing effects of past land management activities.

Bull trout are present within both the Malheur River and John Day River drainages. Occupied waters 

within the John Day River drainage include headwaters of the North Fork John Day River, Middle Fork 

John Day River, and upper mainstem John Day River and tributaries, with seasonal use of the mainstem 

river downstream to the vicinity of the town of John Day. The John Day River Recovery Unit Team has 

identified 12 extant local populations in the recovery unit. Within the Malheur River drainage, occupied 

areas include North Fork Malheur River and the Upper Malheur River sub-basins and the Mainstem 

Malheur River from headwaters downstream to Namorf Dam.

There are approximately 202 miles of designated critical habitat within the analysis area, dispersed 

throughout six watersheds within the John Day River and Malheur River drainages.

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Redband Trout

Redband trout are currently on the Forest Service Region 6 sensitive species list, and considered a 

management indicator species on the Malheur National Forest.

Life History: This is a resident form of rainbow trout, and exhibits habitat preferences similar to those for 

steelhead (described above). Redband trout may migrate within river systems, but do not migrate to the 

ocean. Redband trout populations are widely distributed in all/most major stream drainages (and 

tributaries) within the Malheur National Forest, including the John Day River, Malheur River, and Silvies 

River (table 46).

Westslope Cutthroat Trout

Westslope cutthroat trout are currently on the Region 6 Forest Service sensitive species list and are 

considered a MIS species on the Malheur National Forest.

Life History (NatureServe 2013): Habitat includes small mountain streams, main rivers, and large 

natural lakes; requires cool, clean, well-oxygenated water; in rivers, adults prefer large pools and slow 

velocity areas (stream reaches with numerous pools and some form of cover generally have the highest 

fish densities); often occurs near shore in lakes. Juveniles of migratory populations may spend 1-4 years 

in their natal streams, and then move (usually in spring or early summer, and/or in fall in some systems) 

to a main river or lake where they remain until they spawn. Many fry disperse downstream after 

emergence. Juveniles tend to overwinter in interstitial spaces in the substrate. Larger individuals 

congregate in pools in winter. 

Spawns in small tributary streams on clean gravel substrate; mean water depth is 17-20 cm and mean 

water velocity is 0.3-0.4 m/sec; tends to spawn in natal stream. Adfluvial populations live in large lakes in

the upper Columbia drainage and spawn in lake tributaries. Fluvial populations live and grow in rivers 

and spawn in tributaries. Resident populations complete the entire life history in tributaries. All three lifehistory forms may occur in a single basin. Migrants may spawn in the lower reaches of the same streams 

used by resident fishes. Maturing adfluvial fishes move into the vicinity of tributaries in fall and winter 

and remain there until they begin to migrate upstream in spring. Of migratory spawners, some remain in 

tributaries during summer months, but most return to the main river or lake soon after spawning.

Westslope cutthroat trout distribution is not precisely known, but they do occur within the North Fork 

John Day River and upper mainstem John Day River (widely distributed).

Chinook Salmon

Spring Chinook salmon are a Region 6 sensitive species. Essential fish habitat (EFH) for spring Chinook 

salmon has been designated by NMFS in the analysis area. 

Life History (USDA 2008a): Salmon are sensitive to changes in water quality and habitat. Juvenile 

Chinook salmon are generally associated with pool habitats. An increase in sediment lowers spawning 

success and reduces the quantity and quality of pool and interstitial habitat. Other important habitat 

features include healthy riparian vegetation, undercut banks, and large woody debris.

Adult spring Chinook salmon return to the main stem John Day River and Middle Fork John Day River 

during the spring. Spawning occurs within both drainages, with the majority in the Middle Fork John Day. 

Adults hold in deep pools during the summer while sexually maturing. Spawning occurs during fall, 

generally from August through September. Embryos incubate over the winter and emergence occurs the 

following spring. Juveniles generally rear for one year in freshwater. Juveniles use habitats with slower 

water velocities (pools, glides, and side channels). Juveniles overwinter in deep pools with abundant 

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

cover. Smoltification and emigration to the ocean occurs in the spring of their second year. The ocean 

rearing phase lasts from 1 to 3 years.

For this analysis, essential fish habitat (EFH) for Chinook salmon is approximated by the distribution of 

steelhead, which includes most perennial streams within the John Day River drainage. Consultation with 

the National Marine Fisheries Service (NMFS) will be conducted.

Western ridged mussel (Jepsen et al. 2010)

The western ridged mussel (Gonidea angulata) is widely distributed from southern British Columbia to 

southern California, and can be found east to Idaho and Nevada. G. angulata inhabits cold creeks and 

streams from low to mid-elevations. Hardhead, Pit sculpin, and Tule perch are documented fish hosts for

G. angulata in northern California, although little is known about the fish species that serve as hosts for 

this mussel throughout other parts of its range. G. angulata is sedentary as an adult and probably lives for 

20-30 years, and thus can be an important indicator of habitat quality. G. angulata is a filter feeder that 

consumes plankton and other suspended solids, nutrients, and contaminants from the water column. Large 

beds of G. angulata can improve water quality by reducing turbidity and controlling nutrient levels. Some 

Native American tribes historically harvested this animal and used it for food, tools, and adornment. 

Populations of G. angulata have likely been extirpated in central and southern California, and it has 

probably declined in abundance in numerous watersheds, including the Columbia and Snake River 

watersheds in Washington and Oregon. The western ridged mussel belongs to a monotypic genus and thus 

would be considered a high priority for conservation. Lack of information on the western ridged mussel’s 

current and historical abundance and distribution, and a lack of understanding of which host fish species it 

uses will impede conservation efforts.

Western ridged mussels have been documented in the Middle Fork John Day River drainage.

Please note that conclusions from the analysis for fishes will be used to qualitatively estimate effects for 

invertebrates since the aquatic species utilize the same habitat, and detailed distribution and habitat 

requirements are not well known for the invertebrates.

Invasive Plants by Watershed

Table 46 displays fish species of aquatic concern within 5th field watersheds on the Malheur National 

Forest. The table shows the acreage infested within 100 feet of streams within each 5th field watershed 

and the percent of the total acreage within 100 feet of a stream that is infested within that 5th field 

watershed.; total infested acres is approximately 460 acres. Of these, about 117 acres are located within 

25 feet of streams (Appendix A, Rausch 2012).

The watersheds are listed in descending order of the percent (on Forest System lands only) of total nearstream area (within 100 feet) with mapped infestations. This table underscores the fact that most of the 5th

field watersheds have scattered infestations that occupy a very small percentage of the near-stream area. 

Of the 39 5th-field watersheds on the Malheur National Forest, 33 have less than one-half of 1 percent of 

the near-stream area occupied by invasive plants. Figure 12 displays these 5th field watersheds.

Table 45. Invasive Plants and Fish Species in 5th field watersheds

Watershed Name HUC 5 code

Infested acres

within 100’ of a 

stream

(estimated in 2012)

Percent of total 

acreage within 

100’ of a stream 

infested

Fish species*

Upper Middle Fork John 

Day River (Bridge Creek)

1707020301 94.21 1.50 BT, CH, ST, RT

Pine Creek 1705011603 31.01 1.45 RT

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

Watershed Name HUC 5 code

Infested acres

within 100’ of a 

stream

(estimated in 2012)

Percent of total 

acreage within 

100’ of a stream 

infested

Fish species*

Big Creek 1707020303 49.8 1.04 BT, CH, ST, RT

Middle South Fork John 

Day River

1707020103 27.62 0.96 CH, ST, RT, WT

Camp Creek 1707020302 94.96 0.69 BT, CH, ST, RT

North Basin 1712000101 15.97 0.51 RT

Beech Creek 1707020109 21.43 0.48 CH, ST, RT, WT

Upper Malheur River-Griffin 

Creek

1705011605 1.64 0.43 RT

Upper South Fork John Day 

River

1707020101 18.20 0.43 RT

Upper Silvies River 1712000201 19.63 0.39 RT

Wolf Creek 1705011602 13.97 0.33 RT

Little Malheur River 1705011612 4.88 0.22 RT

Trout Creek 1712000203 19.86 0.39 RT

Otis Creek 1705011606 2.15 0.22 RT

Silvies Canyon 1712000205 4.97 0.16 RT

Emigrant Creek 1712000206 9.79 0.11 RT

Bear Creek 1712000202 1.47 0.05 RT

Canyon Creek 1707020107 3.66 0.05 CH, ST, RT, WT

Fields Creek 1707020111 1.52 0.04 CH, ST, RT, WT

Cottonwood Creek 1707020209 3.84 0.13 CH, ST, RT, WT

Upper Silver Creek 1712000403 0.48 0.02 RT

Upper North Fork Malheur 

River

1705011611 6.55 0.10 BT, RT

Long Creek 1707020304 0.64 0.02 CH, ST, RT, WT

Upper John Day River 1707020106 4.69 0.13 BT, CH, ST, RT, WT

Laycock Creek 1707020110 0.87 0.03 CH, ST, RT, WT

Lower North Fork John Day

River

1707020210 0.17 0.00 CH, ST, RT, WT

Murderers Creek 1707020104 1.30 0.02 CH, ST, RT, WT

Upper Malheur River 1705011601 6.50 0.09 BT, RT

Strawberry Creek 1707020108 0.44 0.01 BT, CH, ST, RT, WT

Buck Creek 1707030303 0.00 0.00 RT

Claw Creek 1712000402 0.00 0.00 RT

Desolation Creek 1707020204 0.00 0.00 RT

Granite Creek 1707020202 0.00 0.00 RT

Grindstone Creek 1707030306 0.00 0.00 RT

Headwaters Silver Creek 1712000401 0.17 0.00 RT

Lower South Fork John Day 

River

1707020105 0.00 0.00 CH, ST, RT, WT

South Fork Beaver Creek 1707030307 0.00 0.00 RT

Twelvemile Creek 1707030305 0.00 0.00 RT

Willow Creek 1712000207 0.00 0.00 RT

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Watershed Name HUC 5 code

Infested acres

within 100’ of a 

stream

(estimated in 2012)

Percent of total 

acreage within 

100’ of a stream 

infested

Fish species*

Total: 462

* Estimate of potential presence: BT = bull trout, CH = Chinook salmon, RT – redband trout, ST = steelhead trout, WT = westslope 

cutthroat trout

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

Figure 12. 5th field watersheds on the Malheur National Forest

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

3.6.3 Environmental Consequences

Analysis Methodology

The fisheries analysis is tiered to programmatic documents, such as PACFISH and INFISH, and the R6 

2005 FEIS. At the project scale, the different treatment methods were mapped and overlaid with fish 

distribution to see if potentially harmful treatments might occur in proximity to habitat for aquatic species 

of conservation concern. The analysis on treatments is focused within infested areas that lie within 100 

feet of aquatic habitat.24

Analyses include consideration of effects at the infested site scale as well as at various watershed scales to 

determine relative risk to fish from the project. The SERA Risk Assessments and GLEAMS model (see

Soil and Water section above for details) were used to determine whether herbicide use could result in 

measurable delivery of herbicide to the stream. 

The spatial analysis boundary for aquatics effects are is the administrative boundary of the Malheur 

National Forest. Detectable effects, such as increased turbidity resulting from sediment created by the 

project, are not expected to extend beyond the Malheur National Forest boundary.

“Short-term” effects refer to the time within 2 years of site-specific (e.g., within a watershed) 

implementation, with “long-term” extending from 2-15 years beyond the time of treatment. The spatial 

and temporal boundaries are identical for all effects: direct, indirect, and cumulative.

Incomplete and Unavailable Information 

The distribution of aquatic organisms throughout the entire analysis area (forest administrative boundary)

is not precisely known. The locations of actual treatment could change over time, as new sites of invasive 

plants are discovered or known sites change in size. To ensure that the analysis covers conditions subject 

to change over time (see early detection/rapid response discussion in chapter 2), we developed project 

design features, buffers, and caps. The design features, buffers and caps ensure that the effects of 

treatment can be analyzed despite uncertainties.

Compliance with PACFISH/INFISH

This section discusses how invasive plant treatment will help maintain or restore (or not prevent 

attainment of) riparian and aquatic conditions as described in the following PACFISH/INFISH goals and 

riparian management objectives. 

Goal 1: Maintain or restore water quality, to a degree that provides for stable and productive 

riparian and aquatic ecosystems

Water quality would be maintained in all alternatives. The project design features, herbicide use buffers, 

and treatment caps would prevent herbicide from reaching streams in measurable or harmful 

concentrations in any alternative. Any herbicide reaching the stream would be quickly diluted as it moved 

downstream. The amount of herbicide potentially reaching a common downstream point and combining 

with chemicals from agricultural uses is very low and would not result in cumulative effects. Mixing and 

dilution of any trace amount of herbicide that may result from invasive plant treatment would occur 

quickly, making it highly unlikely that herbicide concentrations would be additive or synergistic with 

similar treatments at the watershed scale. The result of the GLEAMS model runs on various scenarios of 

sites within the project area is consistent with results of several monitoring studies reviewed by Bakke 

(2001) and Berg (2004). Amounts of herbicides in streams are predicted to be below levels of concern for 

24 If any part of the infested area is within 100 feet of a stream or other water body, the entire area is considered a 

“riparian unit” even if only a portion of the infested sites is near the water body.

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

aquatic health. The cap of 10 acres of herbicide treatment per year within 100 feet of a stream would 

prevent the amount of herbicide delivery to streams from reaching a measurable or meaningful 

concentration. Alternatives A and C would result in less potential herbicide exposure to streams, however 

the potential for invasive plants to impact water quality would be greater under these alternatives. 

Goal 2: Maintain or restore stream channel integrity, channel processes, and the sediment regime 

(including the elements of timing, volume, and character of sediment input and transport) under which 

the riparian and aquatic ecosystems developed.

Invasive plants have the potential to outcompete native vegetation with which these systems developed. 

Treating invasive plants would improve riparian stability where invasive plants have colonized along 

stream channels and out-competed native species. For instance knotweed has poor bank holding capacity, 

which may lead to more bank erosion and sedimentation of streams in high winter flows (R6 2005 FEIS). 

Lacey et al. (1989) reported higher runoff and sediment yield on sites dominated by knapweed versus 

sites dominated by native grasses. Alternatives A and C lack effective treatment options in riparian areas 

(see Chapter 3.1.4). 

Invasive plant treatment in all action alternatives may create some sediment, but the cap of 50 acres of 

treatment per year within 100 feet of a stream in a 6th field watershed would ensure that sediment delivery 

to streams would be minimal. 

Goal 3: Maintain or restore instream flows to support healthy riparian and aquatic habitats, the stability 

and effective function of stream channels, and the ability to route flood discharges.

Invasive plant treatments are unlikely to influence stream flow. There is no potential for increased peak 

flows or alteration of the timing, magnitude, duration and spatial distribution of flows as a result of 

treating or not treating invasive plants. This is because of the relatively small size of invasive plant 

infestations (especially adjacent to water), the spatial distribution, staggered timing of treatments, and low 

water use of invasive plants (Deschutes-Ochoco National Forest and Crooked River Grassland 2011

Invasive Plant FSEIS). 

Goal 4: Maintain or restore natural timing and variability of the water table elevation in meadows and 

wetlands.

Invasive plant treatment is unlikely to influence water table elevation. This is because of the relatively 

small size of invasive plant infestations (especially adjacent to water), the spatial distribution, staggered 

timing of treatments, and low water use of invasive plants (Deschutes-Ochoco National Forest and 

Crooked River Grassland 2011 Invasive Plant FSEIS). 

Goal 5: Maintain or restore diversity and productivity of native and desired non-native plant communities 

in riparian zones.

This purpose and need for this project revolves around maintaining and restoring native plant 

communities; and riparian zones are among the highest priority treatment site types. Treatment of 

invasive plants near streams would allow for re-establishment of native riparian plants that typically have 

better root structure (and bank holding capacity) than non-native invasive plants (Deschutes-Ochoco 

National Forest and Crooked River Grassland 2011 Invasive Plant FSEIS).

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Goal 6: Maintain or restore riparian vegetation, to: 

(a) provide an amount and distribution of large woody debris characteristic of natural aquatic and 

riparian ecosystems;

(b) provide adequate summer and winter thermal regulation within the riparian and aquatic zones; 

and

(c) help achieve rates of surface erosion, bank erosion, and channel migration characteristic of those 

under which the communities developed.

Invasive plants do not provide large woody debris to streams. They can adversely influence thermal 

regulation by outcompeting shade-producing vegetation. Some invasive plants have limited soil holding 

capacity and result in accelerated erosion. A good example is knotweed. This invasive plant chokes 

waterways, displaces native plants, and erodes riverbanks (USDA 2015). Knotweed creates its own 

monoculture, leaving stream banks susceptible to increased erosion as it loses its leaves during the rainy 

season (ibid). Removal of knotweed can help promote establishment of more desirable plants, especially 

if active restoration methods are employed (ibid).

Some minor bank erosion may occur from removing invasive plants in locations where invasive plants 

have taken over a stream bank, especially in smaller streams. This is a low risk in all action alternatives, 

especially considering that no heavy equipment work is proposed and because there is a cap on acres of 

treatment within 100 feet of a stream each year within 6th field watersheds. These factors limit the extent 

and intensity of any potential bank erosion from treatment. 

Goal 7: Maintain or restore riparian and aquatic habitats necessary to foster the unique genetic fish 

stocks that evolved within the specific geo-climatic region.

There is no indication that any of the alternatives would influence fishery genetics or the long term 

viability of fisheries on the Forest. 

Goal 8: Maintain or restore habitat to support populations of well-distributed native and desired nonnative plant, vertebrate, and invertebrate populations that contribute to the viability of ripariandependent communities.

Invasive plant treatment would help maintain or restore riparian vegetation threatened by invasive plants. 

Native riparian vegetation plays a key role in forming aquatic habitat for fish and other aquatic species. 

Roots help stabilize stream banks, preventing accelerated bank erosion and providing for the formation of 

undercut banks, important cover for juvenile and adult fish. Native riparian vegetation also provides large 

and small wood to streams, adding to habitat complexity and providing cover and food sources for aquatic 

organisms. 

Invasive plant treatment may have short term impacts on some elements of the riparian ecosystem (there 

is a potential for some common native plants to be killed); however, the impacts would be very small 

scale (limited to the area directly adjacent to treatment) and short term (vegetation would rebound within 

one season). This is based on the characteristics of the herbicides proposed for use, the PDFs that limit 

the application method, Long term benefits to the development of native plants and riparian dependent 

ecosystems are possible from removal of invasive plants. 

Invasive plants degrade diversity and productivity of native plant communities within and outside riparian 

areas. Invasive plant treatment is needed to maintain or restore native plant communities. Without 

effective invasive plant treatment, undesirable non-native vegetation would continue to degrade native 

plant communities and adversely affect riparian and fish habitat development.

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

PACFISH-INFISH Riparian Management Objective (RMOs) 

PACFISH-INFISH Riparian Management Objective (RMOs) were considered to determine whether there 

is any potential effect that could be influenced by invasive plant treatment, specifically herbicide use. RA3 requires the Forest to “Apply herbicides, pesticides, and other toxicants, and other chemicals [within 

Riparian Habitat Conservation Areas] in a manner that does not retard or prevent attainment of Riparian 

Management Objectives and avoids adverse effects on inland native fish.

Progress toward maintaining and restoring good fish habitat is measured at the 3rd to 6th order streams 

scale within 6th field watersheds, based on measurable indicators of good fish habitat. The indicators are 

pool frequency, water temperature, amount of large woody debris, bank stability, lower bank angle of the 

creek, and width to depth ratio. Invasive plant treatments have low potential to affect any of these 

indicators and would complement other habitat restoration actions.

Indicator: Pool Frequency 

Wetted 

Width 

(feet)

10 20 25 50 75 100 125 150 200

Pools 

per mile

96 56 47 26 23 18 14 12 9

The RMO for pool frequency are shown above; the objective for pools per mile varies by stream width. 

There is no possibility that treatment of invasive plants would affect pool area, quality, and frequency. 

The type of treatments proposed would not change stream dynamics that influence pool frequency. 

Indicator: Water Temperature 

The RMO is no measurable increase in maximum water temperature (7-day moving average of daily 

maximum temperature measured as the average of the maximum daily temperature of the warmest 

consecutive 7-day period). INFISH: Maximum water temperatures below 59 degrees F within adult 

holding habitat and below 48 degrees F within spawning and rearing habitats. PACFISH: Maximum water 

temperatures below 64 degrees F within migration and rearing habitats and below 60 degrees F within 

spawning habitats.

Invasive plant treatments would not be capable of changing solar radiation to a degree that would 

measurably affect stream temperature. Over time, removing invasive plants could help promote the 

recovery of shade-producing, native vegetation. 

Indicator: Large Woody Debris 

The RMO for Large Woody Debris in forested ecosystems east of the Cascade Crest: >20 pieces per mile; 

>12 inch diameter, > 35 foot length. 

Treatment of invasive plants in RHCAs would not affect current wood debris in streams. Removal of 

invasive plants could help restore vegetation that produces large woody debris.

Indicator: Bank Stability

Invasive plant treatments have low potential to adversely affect bank stability, especially at a meaningful 

scale, because 1) native vegetation usually provides better bank stability than invasive plants and 2) the 

project design and project caps limit treatment within riparian areas to 50 acres per 6th field watershed (of 

which only ten acres may include herbicide use). Small scale, short term impacts on bank stability would 

not cause any stream currently above 80 percent stable (thus meeting the RMO desired condition) to drop 

below this value. Given these factors, there is little likelihood that invasive plant treatments would 

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

adversely affect bank stability or retard recovery efforts. Neither invasive plants, nor invasive plant 

treatments have the potential to affect bank angle or width to depth ratio and thus would not retard 

recovery of these habitat indicators.

The presence of people or crews with hand-held tools along streambanks could lead to localized, 

sediment/turbidity to fish habitat because of trampling, soil sloughing due to stepping on banks and 

removal of invasive plant roots. However, amounts of potential localized sediment/turbidity would be 

negligible because the invasive plant populations on the Forest are not extensive enough to result in 

significant sediment/turbidity and emergent vegetation will not be treated. Exposed streambanks are 

expected to re-vegetate during the spring/summer following treatment. In addition, site restoration and revegetation methods preclude erosion as a result of herbicide treatment. It is expected that most patches 

would be relatively small and any erosion negligible.

Small scale, short term impacts on bank stability would not cause any stream currently above 80 percent 

stable (thus meeting the RMO desired condition) to drop below this value. Given these factors, there is 

little likelihood that invasive plant treatments would adversely affect bank stability or retard recovery 

efforts. Restoration of native vegetation in riparian areas could improve bank stability because native 

vegetation usually provides better bank stability than invasive plants.

Indicator: Lower Bank Angle

The bank angle RMO requires that less than 75% of a stream have banks that are less steep than 90 

degrees. This project poses no risk of negatively affecting channel condition and dynamics as a result of 

treating invasive plants. Thus, there are no possible adverse effects on lower bank angle. 

Indicator: Width/Depth Ratio

This RMO requires that width of a stream remain less than 10 times as wide as it is deep. There is no risk 

of negatively affecting channel condition and dynamics as a result of treating invasive plants. Thus, there 

are no possible adverse effects on channel condition and dynamics.

Environmental Effects of Alternative A

Since no project activities would occur, there are no project-related direct, indirect, or cumulative effects 

associated with choosing the no-action alternative. Not taking action means that the need for eradication, 

control, containment, and suppression of invasive plants would not occur, and adverse effects on native 

plant communities described previously would continue. Aquatic habitats are harmed when invasive 

species outcompete native vegetation. Native vegetation supports the biotic (e.g., invertebrate 

community) and abiotic (soil stabilization) attributes necessary for high-quality aquatic habitat. Continued 

expansion of invasive plants, as is likely to occur with no action, (see chapter 3.1.4), would change nearstream biotic and abiotic conditions and could degrade aquatic and riparian habitats.

Direct and Indirect Effects of Alternative B

Introduction 

The following analysis discusses the potential direct and indirect effects on near-stream and aquatic 

habitat indicators at the site and small watershed scale. Unless otherwise specified, the analysis of habitat 

indicators is relevant to all fish species (federally listed, USFS Sensitive, and MIS) as they share 

overlapping habitat and have very similar habitat requirements.

In summary, serious adverse effects on aquatic organisms, in the short or long term, are unlikely.

Concentrations of herbicides potentially delivered to any water body on the Forest would remain well 

below levels capable of measurably affecting aquatic organisms (chapter 3.4 GLEAMS model results).

Potential effects due to sediment input are discussed below; while sediment contribution from invasive 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

plant treatments would be relatively minor, treatments in riparian areas could result in minor local 

changes to fish habitat.

Direct and Indirect Effects 

Risk assessment worksheets produced by SERA and based on the comprehensive reports (SERA 2001, 

2004a-d, 2005, 2007, and 2011a-d) list concentration levels deemed at acute or chronic toxicity for 

aquatic organisms potentially at risk from water contamination. Table 47 lists these thresholds. Generally, 

the lowest toxicity index available for the species most sensitive to effects was used. Measured chronic 

data (NOEC) was used when they were lower than 1/20th of an acute LC50 because they account for at 

least some sublethal effects, and doses that are protective in chronic exposures are more certain to be 

protective in acute exposures.

Table 46. Toxicity indices for fish from project herbicides based on the R6 2005 FEIS and 2007 SERA Risk 

Assessment for aminopyralid

Herbicide Duration Endpoint* Dose** Species Effect Noted at LOAEL***

Aminopyralid

Acute NOEC 50mg/l Rainbow 

Trout None available

Chronic NOEC 1.35 mg/l Rainbow 

Trout None available

Chronic NOEC1 3.2 mg/L Brown trout rainbow trout length 

affected at 66mg/L

Chlorsulfuron

Acute NOEC 2 mg/L (1/20th of LC50) Brown trout LC50 at 40 mg/L

Chronic NOEC2 3.2 mg/L Brown trout rainbow trout length 

affected at 66mg/L

Clopyralid

Acute NOEC 5 mg/L (1/20th of LC50) Rainbow trout LC50 at 103 mg/L

Chronic none available

Glyphosate 

(no

surfactant)

Acute NOEC 0.1 mg/L Rainbow trout Olfactory impairment 

(Tierney et al. 2006)

Chronic NOEC 2.57 mg/L2 Rainbow trout

Life-cycle study in 

minnows; LOAEL not 

given

Glyphosate 

with POEA 

surfactant

Acute NOEC 0.065 mg/L (1/20th of 

LC50) Rainbow trout

LC50 at 1.3 mg/L for 

fingerlings (surfactant 

formulation)

Chronic NOEC 0.36 mg/L salmonid

estimated from full lifecycle study of minnows 

(surfactant formulation)

Imazapic

Acute NOEC 100 mg/L all fish at 100 mg/L, no 

statistically sig. mortality

Chronic NOEC 100 mg/L fathead 

minnow

No treatment related 

effects to hatch or growth

Imazapyr

Acute NOEC 5 mg/L (1/20th LC50) trout, catfish, 

bluegill

LC50 at 110-180 mg/L for 

North American species

Chronic NOEC 43.1 mg/L Rainbow

“nearly significant” effects 

on early life stages at 92.4 

mg/L

Metsulfuron 

methyl

Acute NOEC 10 mg/L Rainbow lethargy, erratic swimming 

at 100 mg/L

Chronic NOEC 4.5 mg/L Rainbow standard length effects at 

8 mg/L

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Herbicide Duration Endpoint* Dose** Species Effect Noted at LOAEL***

Picloram

Acute NOEC 0.04 mg/L (1/20th LC50) Cutthroat 

trout LC50 at 0.80 mg/L

Chronic NOEC 0.55 mg/L Rainbow trout body weight and length of 

fry reduced at 0.88 mg/L

Sethoxydim

Acute NOEC 0.06 mg/L (1/20th LC50) Rainbow trout LC50 of Poast® at 1.2 

mg/L

Chronic NOEC none available

Sulfometuron 

methyl

Acute NOEC 7.3 mg/L Fathead 

minnow

No signs of toxicity at 

highest doses tested

Chronic NOEC 1.17 mg/L Fathead 

minnow

No effects on hatch, 

survival or growth at 

highest doses tested

Triclopyr acid

Acute NOEC 0.26 mg/L (1/20th LC50) Chum salmon LC50 at 5.3 mg/L3

Chronic NOEC 104 mg/L Fathead 

minnow

Reduced survival of 

embryo/larval stages at 

140 mg/L

Triclopyr BEE

Acute 0.012 mg/L Bluegill 

sunfish LC50 at 0.25 mg/L

Chronic4 NOEC 104 mg/L Fathead 

minnow

Reduced survival of 

embryo/larval stages at 

140 mg/L

*--NOEC = No Observed Effect Concentration

**--LC50, Lethal Concentration, 50% kill

***--LOAEL—Lowest Observed Adverse Effect Level

Table 47. Toxicity indices for algae from project herbicides based on the R6 2005 FEIS and 2007 SERA Risk 

Assessment for aminopyralid

Herbicide Duratio

n

Concentration Species Effects noted at 

LOAEL

Aminopyralid

acute

6 mg/L Diatoms Cell density chronic

Chlorsulfuron

acute

0.01 mg/L Selanastrum capriconutum Mortality chronic

Clopyralid

acute 6.9 mg/L Selanastrum capriconutum Growth inhibition

chronic Chronic study of duckweed showed EC50 >> sensitive algae (acute)

Glyphosate (most toxic 

formulation)

acute

3 mg/L Duckweed Growth inhibition

chronic

Imazapic

acute

0.05 mg/L *** Various species Growth inhibition

chronic

Imazapyr

acute

0.2 mg/L * Chlorella Growth inhibition

chronic

Metsulfuron Methyl

acute

0.09 mg/L Selanastrum capriconutum

Growth inhibition

Only short-term data 

available chronic

Picloram

acute

0.23 mg/L Diatoms Growth inhibition

chronic

Sethoxydim (based on 

toxicity of commercial 

formulation)

acute

0.2 mg/L* Algae

Mortality– toxicity similar 

for algae and 

macrophytes chronic

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

Herbicide Duratio

n

Concentration Species Effects noted at 

LOAEL

Sulfometuron Methyl

acute

0.0025 mg/L Selanastrum capriconutum Cell density chronic

Triclopyr TEA

All 

exposur

es

5.9 mg/L * Unspecified algae Mortality

* NOEC is estimated from EC50

** NOEC is estimated from EC25

*** NOEC is estimated from LOEC

Table 48. Toxicity indices for aquatic plants from project herbicides based on the R6 2005 FEIS and 2007 

SERA Risk Assessment for aminopyralid

Herbicide Duration Concentration Species Effects noted at 

LOAEL

Aminopyralid

acute

44mg/L Duckweed Frond Density chronic

Chlorsulfuron

acute

0.00047 mg/L * Lemna minor Mortality chronic

Clopyralid See information for algae

Glyphosate (most toxic 

formulation) See information for algae

Imazapic

acute

0.0013 mg/L Lemna gibba Growth inhibition

chronic

Imazapyr

acute

0.013 mg/L ** Lemna gibba Growth inhibition

chronic

Metsulfuron Methyl

acute

0.00016 mg/L Duckweed

Based on chronic 

data

chronic Mortality

Picloram

acute

0.1 mg/L *** Water milfoil Transient inhibition 

chronic of flowering

Sethoxydim (based on 

toxicity of commercial 

formulation)

acute

0.2 mg/L * Algae

Mortality – toxicity 

similar for algae 

and macrophytes chronic

Sulfometuron Methyl All exposures 0.00021 mg/L Lemna gibba Mortality

Triclopyr TEA All exposures 5.9 mg/L * Unspecified algae Mortality

* NOEC is estimated from EC50

** NOEC is estimated from EC25

*** NOEC is estimated from LOEC

Table 49. Toxicity indices for aquatic invertebrates from project herbicides based on the R6 2005 FEIS and 

2007 SERA Risk Assessment for aminopyralid

Herbicide Duration Concentration Species Effects noted at LOAEL

Aminopyralid

acute 98mg/L Daphnia magna No effects observed

chronic 102 mg/L Daphnia magna No effects observed

Chlorsulfuron

acute 10 mg/L daphnid Mortality

chronic 20 mg/L daphnid Mortality

Clopyralid acute 214 mg/L daphnid Mortality

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Herbicide Duration Concentration Species Effects noted at LOAEL

chronic 11.8 mg/L daphnid Mortality

Glyphosate (most 

toxic formulation)

acute 11 mg/L Daphnia magna Mortality

chronic 0.7 mg/L Daphnia magna Estimated from less toxic formulation

Imazapic

acute 100 mg/L Daphnia magna No effect at any concentration

chronic 100 mg/L Daphnia magna No effect at any concentration

Imazapyr

acute 100 mg/L Daphnia magna No effects observed

chronic 97.1 mg/L Daphnia magna No effects observed

Metsulfuron Methyl

acute 420 mg/L Daphnia magna Immobility

chronic 17 mg/L Daphnia magna Growth

Picloram

acute 26.8 mg/L Shrimp Mortality

chronic 3.8 mg/L Oyster larvae Mortality

Sethoxydim

(based on toxicity of 

commercial 

formulation)

acute 2.6 mg/L daphnid Mortality

chronic 2.6 mg/L No data found, acute level used to assess risks

Sulfometuron Methyl

acute 75 mg/L Alonella spp. & 

Cypria spp. Not given

chronic 0.19 mg/L Alonella spp. & 

Cypria spp. Neonate survival

Triclopyr TEA

acute 133 mg/L Not given Mortality

chronic 81 mg/L daphnid Reproduction

Chapter 3.5.3 shows the results of GLEAMS model runs using site-specific soil, slope, surface condition,

and weather information from the project area. One site was run assuming 10 acres were treated adjacent 

to the stream. This provides an indication of the maximum impact that could occur in alternatives B and 

D, given the elements of the project design that could be modeled. The other three sites were run using 

the current configuration (size and location) of current infestations. 

Results indicate that herbicide concentrations in the water are at least three orders of magnitude less than 

levels of concern for fish, amphibians, and aquatic invertebrates. However, the threshold of concern for 

aquatic plants was exceeded for the sulfonylurea herbicides (chlorsulfuron, metsulfuron methyl, and 

sulfometuron methyl). These exceedances are unlikely to affect the aquatic environment because 1) the 

threshold of concern is at least 10 times less than the amount that killed an aquatic plant, 2) the project 

design features, herbicide use buffers and project caps reduce the potential for the modeled concentration 

to actually reach a water body, and 3) the potential impacts would occur in a single stream reach within a 

6th field watershed. The herbicide use buffers, limitations on broadcast and spot treatments within 100 

feet of streams, and caps on treatments within 6th field watersheds reduce the potential for aquatic plants 

to be killed. Individual plants may be adversely affected, but the aquatic food chain is unlikely to be 

affected. Recovery of aquatic plants, if impacts occur, could take up to several weeks. See table 41 in 

chapter 3.5.3 for GLEAMS model results. 

Indirect effects of chemicals used to treat invasive plants on ecosystem structure and function are 

important in determining overall risk to aquatic organisms (Preston 2002). Algae and aquatic plants are 

generally more sensitive than aquatic animals to effects from herbicides. Therefore, herbicides can affect 

the structure of aquatic communities at concentrations below thresholds for fish and aquatic invertebrates. 

Model runs indicate that thresholds for algae would not be approached in any treatment sites. For plants 

(Lemna gibba), models indicate that an exposure threshold could be approached (slightly below) for the 

herbicide sulfometuron methyl. Any potential effects to this aquatic plant community would be spatially 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

isolated, representing much less than 1 percent of total aquatic habitat. Therefore, indirect effects (e.g., 

change to growth rates of macroinvertebrate prey organisms) to aquatic species of special conservation 

concern, resulting from isolated potential aquatic plant impacts, are unlikely to be detectable.

Indirect effects on the aquatic environment are possible from treatment within riparian areas if bare soil 

exists following treatment, due to the potential for erosion and sediment delivery to streams, primarily in 

the period between application and native plant regrowth, when soil may be slightly destabilized. 

Vegetation reduction in near-stream areas could slightly alter the food base for fish by changing habitat 

for terrestrial invertebrates; this potential effect would be short term and affect a small minority of total 

terrestrial habitat. The common control measures (table 9) describe the types of treatments proposed for 

the invasive plant target species currently mapped on the Malheur National Forest. 

The maximum potential treatment scenario, and associated effects, would be restricted by project caps 

that limit treatment to 10 percent of a 6th field watershed, and no more than 50 acres of total treatment 

within 100 feet of water bodies. Even under a maximum manual treatment scenario, ground disturbance 

would only be expected to produce a few pounds of sediment production per acre. For example, Idaho 

Creek-Summit Creek HUC6 currently has the largest concentration of mapped invasive plants within 100 

feet of a stream; a total of 51.29 acres. If this entire site was manually treated using the most ground 

disturbing method (grubbing), approximately 0.06 tons of sediment may be delivered to a stream. This 

amount would not result in measurable adverse effects to fish.

Project design features and project caps would be implemented to minimize or eliminate adverse effects 

at any scale, even assuming the maximum possible treatment that could occur. 

Watershed-based results were extrapolated to the western ridged mussel through the assumption that this 

sympatric species shares most habitat requirements with native fish, and results are logically transferable. 

Assuming that near-stream native vegetation is beneficial to aquatic habitat, the long-term result of this 

project for all aquatic species would be positive as invasive plants are replaced by native species. This 

change would presumably occur within a few years post-treatment in most cases. New infestations are 

expected within both currently infested and uninfested watersheds that could be treated, with a 

corresponding chance of measurable effects. Previously discussed project design features, herbicide use 

buffers, and treatment caps would minimize or eliminate adverse effects.

Effects on Habitat Indicators

Effects on various fish species were discussed previously. The proposed action would have minimal 

effects on habitat for aquatic organisms, including species of conservation concern. Adverse effects have 

been avoided to the extent practicable through pdfs, herbicide use buffers, and project caps. Effects to fish 

and habitat would be short term, and treatment of invasive plants would complement fish habitat 

restoration efforts over the long term. Further discussion about fish habitat indicators is in the sections 

below. Several overlapping types of analysis are done for aquatic organisms, mainly focused on species of 

conservation concern. The following is an analysis of the effects on Steelhead Primary Constituent 

Elements (PCE) for designated critical habitat (NMFS 2005) as determined via analysis of “Matrix of 

Pathways and Indicators” (MPI) analysis. This analysis also covers the Essential Habitat Features of 

Chinook salmon designated critical habitat.

PACFISH-INFISH Riparian Management Objective (RMOs) were considered to determine whether there 

is any potential effect that could be influenced by invasive plant treatment, specifically herbicide use, 

since RA-3 requires that herbicide not retard or prevent habitat from meeting RMOs. RA-3 also requires 

that adverse effects on inland and anadromous fish be avoided. Progress toward maintaining and restoring 

good fish habitat is measured at the 3rd to 6th order streams scale within 6th field watersheds, based on 

measurable indicators of good fish habitat.

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

The indicators are pool frequency, water temperature, amount of large woody debris, bank stability, lower 

bank angle of the creek, and width to depth ratio. Invasive plant treatments have low potential to affect 

any of these indicators, and would complement other habitat restoration actions. Invasive plant treatments 

do not have the potential to influence pool frequency or retard development of pools. Invasive plant 

treatments have no potential to affect recruitment of large woody debris and would complement other 

habitat restoration efforts by removing competition between invasive plants and native woody vegetation. 

Invasive plant treatments have are highly unlikely to measurably or adversely affect water temperature 

because invasive plants provide little or no understory shade, and no overstory shade. Invasive plant 

treatments could help restore native vegetation that provides shade. 

Invasive plant treatments have low potential to adversely affect bank stability, especially at a meaningful 

scale, because 1) native vegetation usually provides better bank stability than invasive plants, and 2) the 

project design and project caps limit treatment within riparian areas to 50 acres per 6th field watershed (of 

which only 10 acres may include herbicide use). Small scale, short term impacts on bank stability would 

not cause any stream currently above 80 percent stable (thus meeting the RMO desired condition) to drop 

below this value. Given these factors, there is little likelihood that invasive plant treatments would 

adversely affect bank stability or retard recovery efforts. 

Project design features and project caps were developed to minimize or prevent a wide range of effect 

types. A selection of those particularly important to chemical contamination and sediment habitat 

indicators includes the following:

• Variable width herbicide-use buffers for all herbicides based on aquatic risk (table 11 and table 12).

• No more than 50 total acres within 100 feet of all water bodies combined within any 6th field 

watershed would be treated in a single year, with no more than 10 of the 50 acres being treated with 

herbicide. 

• In riparian and aquatic settings, vehicles (including all-terrain vehicles) used to access invasive plant 

sites or for broadcast spraying will not travel off roadways, trails, and parking areas.

For the complete list of project design features see table 10.

PCE Crosswalk – Bull Trout

A crosswalk was done between the Bull Trout Matrix of Pathways and Indicators (MPI) and Primary 

Constituent Elements (PCEs) of Critical Habitat. The Matrix of Pathway Indicators (MPI) for bull trout is 

used to evaluate and document baseline conditions and to aid in determining whether a project is likely to 

adversely affect or result in the incidental take of bull trout. The MPI analysis incorporates 4 population 

indicators and 19 physical habitat indicators. Analysis of the habitat indicators can provide a thorough 

evaluation of the existing baseline condition and potential project affects to the PCEs of critical habitat for 

bull trout. Table 51 shows the relationship between the PCEs for bull trout critical habitat and the MPI 

habitat indicators.

The limited ground disturbance and absence of in-stream treatment would limit potential effects to the 

following habitat indicators: temperature, sediment, chemical contaminants/nutrients, large woody debris, 

pool frequency and quality, and riparian conservation areas. The majority of these effects would be of 

very low magnitude, and undetectable in most areas. Treated riparian area vegetation would likely 

experience rapid regrowth, and the majority of near-stream vegetation would not be treated. Stream 

reaches where treatment is concentrated could experience measurable levels of sediment/turbidity 

increase post-project during storm events, but these effects would be spatially restricted, short-term, and 

low-magnitude. PCEs potentially affected (most undetectable) include 1, 2, 3, 4, 5, 6, 7, and 8. 

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Chapter 3 – Malheur National Forest Invasive Plant Treatment Final Environmental Impact Statement

Table 50. Bull trout PCEs and MPI habitat indicators

Diagnostic Pathway 

Indicator

PCE 1 PCE 2 PCE 3 PCE 4 PCE 5 PCE 6 PCE 7 PCE 8 PCE 9

Springs, 

Seeps, 

Groundwater

Migratory 

Habitats

Abundant 

Food Base

Complex 

Habitats

Water 

Temperature

Substrate 

Features

Natural 

Hydrograph

Water 

Quality and 

Quantity

Predators 

Competition

Water Quality

Temperature x x x x

Sediment x x x x

Chemical contaminants 

nutrients

x x x x

Habitat Access

Physical Barriers x x x x

Habitat Elements

Substrate Embeddedness x x x

Large Woody Debris x x

Pool Frequency and Quality x x x

Large Pools x x

Off-Channel Habitat x x

Refugia x x x

Channel Conditions and Dynamics

Wetted Width/Maximum 

Depth Ratio

x x x

Streambank Condition x x x x

Floodplain Connectivity x x x x x x

Flow/Hydrology

Changes in Peak/Base 

Flows

x x x x x

Drainage Network Increase x x x

Watershed Conditions

Road Density and Location x x x

Disturbance History x x x x

Riparian Conservation Areas x x x x x

Disturbance Regime x x x

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Pathway: Water Quality

Indicator: Temperature, PCE Crosswalk: Spawning, Rearing, Migration habitat PCEs

Stream temperature is controlled by many variables at each site. These include topographic shading, 

stream orientation, channel morphology, discharge, air temperature, and interactions with ground water, 

which would not be measurably influenced by invasive plant treatments in the vast majority of treatment 

locations. In a few areas, treatment of invasive plants would change understory and ground vegetation, 

but extent would be limited in quantity by project design features and project “caps.” The majority of 

shade-providing vegetation is expected to be retained. Treatments would not be capable of changing solar 

radiation to a degree that would measurably affect stream temperature. Therefore, direct or indirect effects 

on the temperature indicator would not affect spawning, rearing, or migration PCEs.

Pathway: Water Quality 

Indicator: Chemical Contaminants/Nutrients, PCE Crosswalk: Spawning habitat PCEs

The most likely routes for herbicide delivery to water are potential runoff from a large rain storm soon 

after application, especially from treated roadside ditches. Other concerns, such as drift, overspray, and 

spills, are addressed through project design features that would control drift and overspray. The potential 

risk from accidental spills in RHCAs exists; however, pdf G describes the mechanism to minimize the 

occurrence and restrict highly concentrated chemicals proximity to water.

GLEAMS model results (table 41 and table 42, chapter 3.5.3) indicate that the low amount of herbicide 

that might be delivered to a stream would not exceed levels of concern for any fish, algae, or aquatic 

invertebrate species. Temporary adverse effects to spatially isolated (scattered, infrequent) aquatic plants 

are possible. Effects from chemical contamination would be negligible in all project watersheds.

In summary, alternative B is not likely to adversely affect water quality or result in water contamination 

that could adversely affect fish.

Pathway: Channel Condition & Dynamics

Indicator: Floodplain Connectivity, PCE Crosswalk: Rearing habitat PCE

Some invasive plant treatments can have long-term positive effects on floodplains and streambanks when 

infestations of invasive plants on valley bottom areas are removed. Valley-bottom infestations often 

encroach on floodplains where road-related, grazing, or recreational activities have led to the 

establishment of invasive plant populations. Removal of such infestations is expected to benefit aquatic 

and terrestrial communities in the long-term by increasing floodplain area available for nutrient, sediment 

and large wood storage, and flood flow refugia. Potential localized, short-term, and low-magnitude 

sediment/turbidity increases would not be sufficient to alter channel condition and dynamics. Therefore, 

alternative B is unlikely to affect floodplain connectivity or fish rearing habitat.

Pathway: Habitat Access

Indicator: Physical Barriers, PCE Crosswalk: Migration habitat PCE

Invasive plant treatments would not create physical barriers or otherwise degrade access to aquatic habitat 

since there is no causal mechanism from proposed activities. Habitat access, physical barriers, and 

migration habitat would not be affected by alternative B. 

Pathway: Habitat Elements

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

Indicator: Substrate/Sediment, PCE Crosswalk: Spawning, Rearing habitat PCEs

The alternatives are unlikely to produce measurable sediment in the majority of locations because very 

little ground disturbance would take place, though very minor inputs could conceivably occur during the 

period between plant death and regrowth. Manual labor such as hand pulling may result in localized soil 

disturbance, but increases of sediment to streams would likely be undetectable in most areas. In the few 

areas where more intense treatment could occur, disturbance areas would be limited in quantity by 

herbicide-use buffers, project design features, and project “caps”.

Sediment increases would be limited to short-term (e.g., a few hours/days) inputs during, and 

immediately following, intense precipitation events. A small increase in turbidity is the most likely effect 

and minor increases in surface fines could occur in some pool habitat. The substrate/sediment indicator 

would not be measurably affected over the long-term because treatment of invasive plants would not 

result in a chronic sediment source; fewer disturbances would occur during re-treatment, as the infestation 

density would decrease each treatment entry (see 3.1.4 for more information on treatment effectiveness).

Sediment is unlikely to be large enough to affect spawning and rearing PCEs over the long term. Some 

minor sediment delivery could occur in the short term but it would be unlikely to adversely affect fish.

Indicator: Large Woody Debris, and Pool Area, Quality and Frequency, PCE Crosswalk: Spawning 

habitat PCE

Treatment of invasive plants would not affect pool area, quality, and frequency, as a causal mechanism 

does not exist. Near-stream treatment of invasive plants would not affect current wood debris in streams. 

As the vast majority of native vegetation would be retained in all treatment sites, it is highly unlikely that 

future woody debris recruitment would be affected. Therefore, spawning habitat would not be affected by 

changes to the large woody debris, and pool area, quality and frequency indicators.

Pathway: Flow/Hydrology

Indicator: Change in Peak/Base Flows, PCE Crosswalk: Spawning, Rearing, Migration habitat 

PCEs

A small percentage of each watershed (even small subwatershed) would be treated during a single year; in 

most cases, it would be less than one percent. Project “caps” establish an absolute maximum of 10 percent

of any 6th field watershed per year, but this is highly unlikely to occur given the current level of 

infestation is far lower. The treatments would not affect stream flow or fish migration habitat. In addition, 

no more than 50 acres (10 acres herbicide) of treatment would occur per year within 100 feet of streams 

in any 6th field watershed.

Focus Watersheds

The focus of the effects analysis for aquatic organisms is on the eight 6th-field watersheds where more 

than one-half of 1 percent of the area within 100 feet of streams or other water bodies is infested. 25 These 

include Big Creek, Camp Creek, Middle South Fork John Day River, North Basin, Pine Creek, and Upper 

Middle Fork John Day River. Table 52 lists the infested acreage and percent of near-stream acres infested,

as well as fish species in the focus watersheds. See figure 13 for a display of the location of these 

watersheds in relation to the Malheur National Forest.

25 Treatment of less than one-half of 1 percent of the riparian area in a 6th field watershed is unlikely to have any 

detectable effects to fish or other aquatic organisms based on professional judgment (Mease 2013).

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Table 51. Invasive plants and fish species in focus watersheds

Watershed Name

(alphabetical order)

HUC 5 code Infested 

acres

Percent of total 

near-stream area

Fish species*

Big Creek (Middle Fork John Day River) 1707020303 49.80 1.04% BT, CH, ST, RT

Camp Creek (Middle Fork John Day River) 1707020302 94.96 0.69% BT, CH, ST, RT

Middle South Fork John Day River 1707020103 27.62 0.96% CH, ST, RT, WT

North Basin (Malheur River) 1712000101 15.97 0.51% RT

Pine Creek 1705011603 31.01 1.45% RT

Upper Middle Fork John Day River 1707020301 94.21 1.50% BT, CH, ST, RT

Key for table use: BT = bull trout, CH = Chinook salmon, RT – redband trout, ST = steelhead trout, WT = 

westslope cutthroat trout

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

Figure 13. Focus watersheds for fisheries analysis

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Big Creek Watershed

Approximately 49.80 acres (1.04%) of near-stream treatment is proposed on National Forest System land 

within this watershed. This watershed contains critical habitat for both steelhead and bull trout, and 

essential fish habitat for Chinook salmon. Habitat exists for redband trout, westslope cutthroat trout (not 

currently present), and western ridged mussel. This watershed is an example of “higher” relative risk 

since more treatment is expected and multiple aquatic species of special conservation concern exist.

Based on proximity, detectable sediment effects (e.g., turbidity) could potentially occur in spot locations 

within the following steelhead and/or bull trout critical habitat streams: Middle Fork John Day River, Elk

Creek, Deep Creek, Mosquito Creek, Deadwood Creek, and Swamp Gulch. The areas of highest relative 

risk for measurable sediment effects are along Deep Creek and Mosquito Creek, where, respectively, 

approximately 1 mile (16 acres) and 0.50 mile (5-8 acres) of treatments are proposed. The remainder of 

the units are small and spatially separated. Potential sediment/turbidity effects to fish include, but are not 

limited to, altering behavior (e.g., feeding efficiency), gill trauma, oxygen depletion, reduction in habitat 

quality for multiple life stages, and reduction of food organisms. These segments represent less than 10

percent of stream length within the watershed; therefore, any effects would be low magnitude and short 

term. In addition, no more than 50 acres (10 acres herbicide) of treatment would occur per year within 

100 feet of streams in any 6th field watershed.

Camp Creek Watershed

Approximately 94.96 acres (0.69%) of near-stream treatment is proposed on National Forest System land 

within this watershed. This watershed contains critical habitat for both steelhead and bull trout, and 

essential fish habitat for Chinook salmon. Habitat exists for redband trout, westslope cutthroat trout, 

Columbia spotted frog, and aquatic invertebrates. This watershed is an example of “higher” relative risk

since more treatment is expected and multiple aquatic species of special conservation concern exist.

Infestations are widely distributed throughout this watershed, both along critical habitat and in tributary 

reaches. Based on proximity, detectable sediment effects (e.g., turbidity) could potentially occur in spot 

locations within the following steelhead and/or bull trout critical habitat streams: Camp Creek, 

Cottonwood Creek, Lick Creek, Myrtle Creek, Big Boulder Creek, Badger Creek, Dry Creek, Beaver 

Creek, Ragged Creek, Butte Creek, Little Boulder Creek, Windlass Creek, Tincup Creek, Granite Boulder 

Creek, Vincent Creek, Vinegar Creek, Davis Creek, Placer Gulch, Middle Fork John Day River, Blue 

Gulch, Lemon Creek. The areas of highest relative risk for measurable sediment effects are along Caribou 

Creek and Little Boulder Creek, where approximately 1⁄2-mile of treatment would occur along each 

stream. The remainder of units are small (less than 1⁄4-mile along stream) and spatially separated. Potential 

sediment/turbidity effects to fish include, but are not limited to, altering behavior (e.g., feeding 

efficiency), gill trauma, oxygen depletion, reduction in habitat quality for multiple life stages, and 

reduction of food organisms. In total, segments proposed for treatment represent less than 10 percent of 

stream length within any watershed; therefore, any effects would be low magnitude and short term. In 

addition, no more than 50 acres (10 acres herbicide) of treatment would occur per year within 100 feet of 

streams in any 6th field watershed.

Middle South Fork John Day River

Approximately 27.62 acres (0.96%) of near-stream treatment is proposed on National Forest System land 

within this watershed. This watershed contains critical habitat for steelhead and essential fish habitat for 

Chinook salmon. Habitat exists for redband trout and westslope cutthroat trout.

Most of the treatment proposed in this watershed is along Deer Creek and North Fork Deer Creek, both of 

which are designated critical habitat. Potential sediment/turbidity effects to fishes include, but are not 

limited to, altering behavior (e.g., feeding efficiency), gill trauma, oxygen depletion, reduction in habitat 

quality for multiple life stages, and reduction of food organisms. More than a mile of treatment could 

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

occur along these two streams. Project “caps” would limit total annual treatment to 10% of the 6th field 

watershed (Corral Creek) where a relatively high concentration of sites exists. Because more treatment

could be concentrated in a localized area, sediment/turbidity could be of greater magnitude than other 

areas; however, duration would be short term. In addition, no more than 50 acres (10 acres herbicide) of 

treatment would occur per year within 100 feet of streams in any 6th field watershed.

North Basin

Approximately 15.97 acres (0.51%) of near-stream treatment is proposed on National Forest System land 

within this watershed. There is no critical habitat for federally listed species within this watershed. 

Redband trout may be present.

Based on proximity, detectable sediment effects (e.g., turbidity) could potentially occur in spot locations 

within the following streams: Polson Creek, Devine Canyon, Armstrong Canyon, Cow Creek, Rattlesnake 

Creek, East Fork Rattlesnake Creek, West Fork Rattlesnake Creek, and Middle Fork Rattlesnake Creek. A 

few sites within the Rattlesnake Creek drainage are approximately 1⁄2-mile in length; these sites pose the 

greatest risk of potentially measurable sediment/turbidity effects. Because less than 10 percent of this 

watershed would be treated, any effects that could occur would be of low magnitude and short term. In 

addition, no more than 50 acres (10 acres herbicide) of treatment would occur per year within 100 feet of 

streams in any 6th field watershed.

Pine Creek

Approximately 31.01 acres (1.45%) of near-stream treatment is proposed on National Forest System land 

within this watershed. There is no critical habitat for federally listed species within this watershed. 

Redband trout may be present.

Based on proximity, detectable sediment effects (e.g., turbidity) could potentially occur in spot locations 

within the following streams: Pine Creek and unnamed tributaries, West Fork Pine Creek, and Alkali 

Creek and unnamed tributary. One site along an unnamed tributary in the headwaters of Pine Creek, and a 

site along West Fork Pine Creek, each exceed 1⁄2-mile in length. These areas pose the greatest risk of 

producing measurable sediment/turbidity effects. Potential sediment/turbidity effects to fishes include, but 

are not limited to, altering behavior (e.g., feeding efficiency), gill trauma, oxygen depletion, reduction in 

habitat quality for multiple life stages, and reduction of food organisms. Because less than 10 percent of 

this watershed would be treated, any effects that could occur would be of low magnitude and short term.

In addition, no more than 50 acres (10 acres herbicide) of treatment would occur per year within 100 feet 

of streams in any 6th field watershed.

Upper Middle Fork John Day River

Approximately 94.21 acres (1.50%) of near-stream treatment is proposed on National Forest System land 

within this watershed. This watershed contains critical habitat for steelhead and bull trout, and essential 

fish habitat for Chinook salmon. Habitat exists for redband trout, westslope cutthroat trout (not currently 

present), and western ridged mussel. This watershed is an example of “higher” relative risk since more 

treatment is expected and multiple aquatic species of special conservation concern exist.

Based on proximity, detectable sediment effects (e.g., turbidity) could potentially occur in spot locations 

within the following steelhead and/or bull trout critical habitat streams: Middle Fork John Day River, 

Bridge Creek, Clear Creek, Dry Fork Clear Creek, Mill Creek, Crawford Creek, Summit Creek, Idaho 

Creek, and Squaw Creek. The area of highest relative risk for measurable sediment effects is along 

Crawford Creek, where more than a mile of treatment along the stream is proposed. Project “caps” would 

limit total annual treatment to 10 percent of the 6th field watershed (Mill Creek) where this relatively high 

concentration of sites exists. Because there would be more treatment concentrated in a localized area, 

sediment/turbidity could be of greater magnitude than other areas (low-moderate); however, duration 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

would be short term. In addition, no more than 50 acres (10 acres herbicide) of treatment would occur per 

year within 100 feet of water bodies in any 6th field watershed.

Species of Conservation Concern Determinations 

Based on quantity of proposed treatment near streams, short-term detectable effects were determined to 

be possible in six watersheds (5th field HUC): Big Creek, Camp Creek, Middle South Fork John Day 

River, North Basin, Pine Creek, and Upper Middle Fork John Day River. Measurable effects in other 

watersheds from treatment of currently mapped infestations are not expected. More site-specific 

information about fisheries impacts at the watershed scale (6th field HUC) will be developed through the 

ongoing ESA Section 7 consultation process.

Federally Listed Fishes and their Designated Critical Habitat

For federally listed species (steelhead, bull trout) and essential fish habitat (Chinook salmon), the 

potential for short-term adverse effects is greatest in four watersheds within the project area: Big Creek, 

Camp Creek, Middle South Fork John Day River, and Upper Middle Fork John Day River. Sediment 

produced from treatments in riparian areas, especially manual treatments, may affect listed fish in the 

short term. However, these impacts are expected to be minor and discountable. The effects from sediment 

were further reduced with the addition of pdf E3 that provides for some erosion control in disturbed 

riparian areas. 

Potential effects to habitat indicators are not likely to adversely affect fish and their designated critical 

habitat. Consultation will be completed with U.S. Fish and Wildlife Service and the National Marine 

Fisheries Service on the preferred alternative prior to a final agency decision.

Forest Service Sensitive Species

Forest Service Sensitive species (trout and mussel) exhibit largely overlapping ranges and similar 

vulnerability to effects with the federally listed fishes; therefore, the following determination applies: 

“May impact individuals, but a not likely to cause a trend toward federal listing or loss of viability within 

the planning area.”

Forest Service Management Indicator Species

Forest Service Management Indicator Species (MIS) (resident trout group – e.g., redband) overlap the 

distribution of federally listed fishes, and exhibit similar vulnerability to effects. In summary, there would 

be no reduction in quantity (miles) of stream habitat due to project actions. Habitat quality may be slightly 

reduced in the short-term due to post-implementation sediment input resulting from dead near-stream 

vegetation. This potential effect would occur within a fraction of 1 percent of available habitat; therefore, 

the following determination applies: “May impact individuals, but is not likely to cause a trend toward 

federal listing or loss of viability within the planning area.” In the long term, near-stream conditions 

would be improved as native vegetation re-establishes.

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

Table 52. Determinations for Fish Species of Conservation Concern

Species Status Determination26

Middle Columbia River steelhead 

DPS and designated critical habitat Federally threatened May affect, not likely to adversely 

affect.

Columbia River and Malheur River 

bull trout SMUs and designated 

critical habitat

Federally threatened May affect, not likely to adversely 

affect.

Middle Columbia River Chinook 

salmon 

Essential fish habitat and USFS 

sensitive

No adverse modification of essential 

fish habitat. May affect individuals, 

but is not likely to cause a trend 

toward federal listing or loss of 

viability within the planning area.

Redband trout

USFS sensitive

May impact individuals, but is not 

likely to cause a trend toward federal 

listing or loss of viability within the 

planning area. 

Westslope cutthroat trout

Western ridged mussel

Resident trout group (same effects 

as above for same/other trout 

species)

USFS Management Indicator 

Species (MIS) 

May impact individuals, but is not 

likely to cause a trend toward federal 

listing or loss of viability within the 

planning area. 

PACFISH/INFISH Fish and Habitat at 6th field 

watershed scale

Project would not prevent or retard 

RMO indicators associated with 

PACFISH/INFISH. Adverse effects 

are avoided to the extent practicable 

given the pdfs, herbicide use buffers, 

and project caps.

Land and Resource Management Plan Amendment

The effects of adding aminopyralid to the list of available herbicides would not adversely affect fish. The 

Environmental Protection Agency classified aminopyralid as a “reduced risk” herbicide and stated that 

the use of aminopyralid as a replacement for other herbicides will decrease risk to some non-target

species [including fish] (U.S. EPA 2005 in SERA 2007 Risk Assessment). 

Early Detection/Rapid Response

The early detection/rapid response component of the project would have similar impacts to treatment of 

known sites due to the implementation planning process that would ensure new detections are treated 

according to pdfs, treatment caps, and herbicide-use buffers. The greatest potential impact would be 

localized sediment/turbidity of low-moderate magnitude as discussed above for areas that currently have 

the highest concentration of invasive plants in a subwatershed.

The GLEAMS model run for Ennis Creek assumes that 10 acres of treatment occur adjacent to the creek

because up to 10 acres may be treated using herbicide within 100 feet of a stream in a 6th field watershed 

in a single year. Currently, there are no sites containing 10 contiguous acres of infestation. This run does

not consider the herbicide use buffers and herbicide rate restrictions associated with alternative B (model 

assumes maximum rates and broadcasting to the water’s edge), thus the amount of herbicide that may be 

delivered to the stream is likely less than estimated by the model. 

26 The ESA determinations have been updated in the FEIS based on the Biological Assessment and ESA 

Consultation process. The project design features and other elements of the project have minimized the potential 

impacts on ESA listed fish and their habitat to a discountable level. 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Direct and Indirect Effects of Alternative C

The conclusions from the analysis for alternative B generally apply to alternative C, with the following 

qualitative differences and clarifications.

• The risk of chemical contamination of aquatic habitat from herbicide application associated with 

alternative B would be reduced due to the absence of near-stream herbicide application. See 

GLEAMS model results for alternative C in chapter 3.5.3 indicating reduction in herbicide reaching 

streams due to the prohibition on any herbicide use within 100 feet of streams. In addition, picloram 

would not be used so there would be no potential for this herbicide to reach streams.

• An increase in sediment production could result from alternative C as compared to alternative B due 

to an increase in non-herbicide methods, many of which would produce more soil disturbance and 

associated mobilization into stream channels (see chapter 3.4). Treatments would be less effective and 

would require more treatment entries to reach desired conditions (see chapter 3.1.4) which could 

compound the potential effect on sediment and turbidity. 

• To the extent that the greater costs and time to reach desired conditions associated with alternative C 

(see chapter 3.1.4), there could be less short- and long-term benefit to the aquatic environment.

Direct and Indirect Effects of Alternative D

The conclusions from the analysis for alternative B generally apply to alternative D, with the following 

qualitative differences and clarifications.

The risk of harm to aquatic habitat from herbicide application would increase because of increased use of 

picloram and glyphosate, two of the herbicides posing greatest risk to aquatic organisms. However, 

despite the increased use of these herbicides, GLEAMS model results show a low risk of these herbicides 

reaching streams. Project design features, herbicide-use buffers, and project “caps” provide substantial 

protection, making detectable difference in effects to aquatic organisms and their habitat unlikely, except 

in the case of an unexpected over-application (e.g., spill near water). Due to the greater costs and time to 

reach desired conditions associated with alternative D (see chapter 3.1.4), there could be less short- and 

long-term benefit to the aquatic environment. All other potential effects would be similar to alternative B, 

including sediment from all treatment methods.

Cumulative Effects of All Action Alternatives

The baseline for cumulative effects analysis is the current condition as described in the affected 

environment section. The differences between alternatives in terms of impacts to fisheries are so small 

that cumulative effects would be the same across alternatives. 

Herbicide Application

Herbicides are commonly applied for a variety of agricultural, landscaping, and invasive plant 

management purposes. Herbicide use occurs on tribal, state, county, private forestry, range, utility 

corridor, road rights-of-way, and private property lands. Studies (see chapter 3.1.5) have shown that 

pesticides are commonly found in surface waters in Oregon and throughout the United States. However, 

the studies indicate that herbicide use similar to the type proposed in this project would not result in 

harmful concentrations of herbicide in water. Herbicide concentrations from the project are expected to be 

undetectable or very low in all waterways, and would therefore not contribute to herbicide cumulative 

effects. 

The effect of higher than historic water temperature on fish sensitivity to proposed herbicides is unknown. 

The exposure scenarios likely overestimate the amount of herbicide that may reach streams because they 

do not account for all aspects of project design that minimize the potential for herbicide to reach water 

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

bodies. In addition, the thresholds of concern for fish are conservative; the exposure scenarios and 

thresholds of concern likely account for any potential increased sensitivity due to water temperature. 

Therefore, the project is not expected to add to potential temperature-related effects from other ongoing or 

foreseeable projects. 

Sediment and Turbidity

Sediment production from project actions could add to sources derived from other actions on National 

Forest System lands, tribal lands, state and county lands, private forestry lands, rangelands, utility 

corridors, road rights-of-way, and private property. These potential additions will be analyzed 

qualitatively based on percentage of lands of other ownerships present within specific watersheds where 

effects are potentially measurable. Project caps would similarly limit potential effects in areas where new 

or expanding invasive plant populations are discovered and treated.

Within the six focus watersheds where project-related sediment/turbidity effects are most likely, effects 

would be low magnitude and short term. Streams listed (303(d)) for sediment within the Middle Fork 

John Day and Upper John Day watersheds (see Water Quality section) are not expected to incur any 

detectable long-term sediment additions from project activities; spatially isolated short-term sediment 

effects would be limited to low-magnitude turbidity increases and pool surface-fines.

Table 54 considers the other current and future actions that may contribute sediment to the focus 

watersheds for fisheries, along with manual treatment proposed in this project in both action alternatives. 

Manual treatment would contribute a very small percentage to the total sediment produced. Natural 

background seasonal fluctuation along with sediment/turbidity effects from other actions (e.g., roads, 

timber harvest, grazing) exceeds any potential production from invasive plant treatment by orders of 

magnitude.

Table 53. Cumulative effects, qualitative estimates within focus watersheds for fisheries

Watershed

Name

Currently 

Infested 

acres within 

100’ of water 

bodies

Other current/future 

Federal actions capable 

of contributing sediment

Percent of 

watershed 

private land 

(approximate)

Project-related 

sediment based 

on current 

infestations

LongTerm 

Total

Big Creek

(Middle Fork 

John Day 

River)

50

Road maintenance, 

grazing, dispersed 

camping

60%

Low quantity, short 

duration (<2 years

beyond the time of 

treatment)

Pre-project 

levels

Camp Creek

(Middle Fork 

John Day 

River)

100

Road maintenance,

prescription fire, timber 

harvest, road 

closures/decommissioning, 

culvert replacements, large 

woody debris in-stream 

placement, grazing, 

campgrounds, dispersed 

camping

<5%

Low quantity, short 

duration (<2 years

beyond the time of 

treatment)

Pre-project 

levels

Middle South 

Fork John Day 

River

28

Road maintenance, juniper 

and mixed conifer cutting, 

fuel treatment, aspen 

restoration, watershed

improvement activities, 

grazing, dispersed 

camping, Murder’s Creek 

Wild Horse Territory

75%

Low quantity, short 

duration (<2 years

beyond the time of 

treatment)

Pre-project 

levels

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Watershed

Name

Currently 

Infested 

acres within 

100’ of water 

bodies

Other current/future 

Federal actions capable 

of contributing sediment

Percent of 

watershed 

private land 

(approximate)

Project-related 

sediment based 

on current 

infestations

LongTerm 

Total

North Basin 16

Road maintenance, snow 

park relocation, 

prescription fire, timber 

harvest, road 

closures/decommissioning, 

hazard trees, grazing, 

campgrounds, dispersed 

camping

75%

Very low quantity, 

short duration (<2

years beyond the 

time of treatment)

Pre-project 

levels

Pine Creek

(Malheur River) 31

Road maintenance, 

prescription fire, grazing, 

dispersed camping

60%

Low quantity, short 

duration (<2 years

beyond the time of 

treatment)

Pre-project 

levels

Upper Middle 

Fork John Day 

River

94

Road maintenance, snow 

park, prescription fire, 

timber harvest, road 

closures/decommissioning, 

aspen restoration, aquatic 

restoration, culvert 

replacements, grazing, 

dispersed camping

<5%

Low quantity, short 

duration (<2 years

beyond the time of 

treatment)

Pre-project 

levels

Several other stressors on fish exist, including hydropower development, habitat degradation from human 

activities, direct harvest of fish, and competition from hatchery fish (USDA Forest Service 2008b). These 

are part of the existing condition for aquatic organisms and this project will not influence these 

conditions. The threshold of concern for herbicide impacts has been set deliberately low to accommodate 

uncertainty about how fish respond to herbicide exposure in combination with other stressors. 

The analysis assumes maximum levels of treatment over the life of the project. Even given these unlikely 

treatment levels, project-related additions to existing cumulative effects are likely to be minor or nonexistent. At any given site, direct or indirect adverse effects to aquatic organisms under all alternatives

would be low magnitude, localized, and short term. The potential to affect the aquatic environment is 

limited to a low amount of herbicide or sediment, and minor impacts on native riparian vegetation (see 

previous sections of this EIS). These effects are not of a type or extent that would combine with ongoing 

human activities or foreseeable projects on the Forest and produce long-term, cumulative impacts, even 

considering the vectors of invasive plant spread described in chapter 3.1.5.

3.7 Wildlife

3.7.1 Introduction

National Forest System land on the Malheur National Forest (Forest) provides diverse habitats for 

wildlife including grasslands, sagebrush, and juniper; fir and pine forests; and mountain lakes and 

meadows. These varied habitats provide for a diversity of wildlife including 365 vertebrate species (22 

fish, 9 amphibians, 14 reptiles, 235 birds, and 85 mammals) (Forest LRMP p. III-42). Invasive plants 

have become established and continue to spread, causing a loss of wildlife habitat and posing a risk of 

injury to wildlife on the Malheur National Forest. This section addresses the impacts and benefits of the 

proposed Malheur National Forest Site-Specific Invasive Plants Treatment Project on wildlife and 

wildlife habitat.

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

Regulatory Framework

The following is a summary of regulatory direction specifically applicable to the management of wildlife 

resources on the project area.

• National Environmental Policy Act (NEPA) of 1969 (as amended) - NEPA requires that effects of 

management actions on wildlife be disclosed and requires that management provide for a 

diversity of plant and animal communities (16 USC 1604((g) (3) (B))

• Endangered Species Act (ESA) of 1973 (as amended) - ESA requires the Forest Service to 

manage for the recovery of threatened and endangered species and the ecosystems, upon which 

they depend. Forests are also required to consult with the United States Fish and Wildlife Service 

if a proposed activity may affect the population or habitat of a listed species.

• National Forest Management Act (NMFA) of 1976 (as amended) - NFMA requires the Forest 

Service to manage fish and wildlife habitat to maintain viable populations of all native and 

desirable non-native vertebrate wildlife species and conserve all listed threatened or endangered 

species populations (36 CFR219.19).

• Executive Order 13186 (Migratory Bird Treaty Act) - The MBTA established an international 

framework for the protection and conservation of migratory birds. This Act makes it illegal, 

unless permitted by regulations, to “pursue, hunt, take, capture, purchase, deliver for shipment, 

ship, cause to be carried by any means whatever, receive for shipment, transportation or carriage, 

or export, at any time, or in any manner, any migratory bird.” Within the NEPA process, effects of 

proposed actions on migratory birds will be evaluated and actions will consider approaches to 

identify and minimize take (USDA Forest Service 2008).

• Forest Service Manual Direction regarding wildlife (FSM 2600) - Forest Service Manual 

direction provides guidance related to Threatened, Endangered, and Sensitive (TES) species. It 

requires that the Forest Service identify and prescribe measures to prevent adverse modifications 

or destruction of critical habitat and other habitats essential for the conservation of endangered, 

threatened, and proposed species (FSM 2670.31 (6)). It also requires the Regional Forester to 

identify sensitive species for each National Forest where species viability may be a concern 

(under FSM 2670.32) and mitigate adverse impacts of management activities (FSM 2634).

The Forest LRMP provides comprehensive guidance for wildlife management. The wildlife report details 

specific objectives, standards, and guidelines related to wildlife. This project has very limited impacts to 

wildlife species and most of the Forest LRMP wildlife management direction is not applicable to this 

project.

3.7.2 Affected Environment

Invasive Plants Influence Wildlife Habitat

Invasive plants are thought to generally degrade wildlife habitat, especially for species that require intact 

native plant ecosystems. Some wildlife species use invasive plants for food or cover. For example, 

American goldfinch (Carduelis tristis) and red-winged blackbird (Agelaius phoeniceus) use purple 

loosestrife (Kiviat 1996; and Thompson 1987), and native bighorn sheep will eat cheatgrass (Csuti et al. 

2001). It has been reported that elk, deer, and rodents eat rosettes and seed heads of spotted knapweed.

Doves, hummingbirds, honeybees, and the endangered southwestern willow flycatcher (Empidonax trailii

extimus) are known to use saltcedar (Barrows 1996).

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

The few uses that an invasive plant may provide do not outweigh the adverse impacts to an entire 

ecosystem (Zavaleta 2000). Invasive plants have adversely affected habitat for native wildlife in Oregon

(ODFW 2006). Species of wildlife that depend upon native vegetation for food, shelter, or breeding can 

be adversely affected by invasive plants. Species restricted to very specific habitats, for example ponddwelling amphibians, are more susceptible to adverse effects.

Displacement of native plant communities by non-native plants results in alterations to the structure and 

function of ecosystems and constitutes a principle mechanism for loss of biodiversity at regional and 

global scales (Lacey and Olson 1991). Mills et al. (1989) and Germaine et al. (1998) found that native 

bird species diversity and density were positively correlated with the volume of native vegetation, but 

were negatively correlated or uncorrelated with the volume of exotic vegetation. 

Invasive plants can adversely affect wildlife species by eliminating required habitat components, 

including surface water (Dudley 2000; Horton 1977); reducing available forage quantity or quality 

(Bedunah and Carpenter 1989; Rice et al. 1997; Trammell and Butler 1995); reducing preferred cover 

(Rawinski and Malecki 1984; Thompson et al., 1987); drastically altering habitat composition due to 

altered fire cycles (D’Antonio and Vitousek 1992; Mack 1981; Randall 1996; Whisenant 1990); and 

physical injury, such as that caused by long spines or “foxtails” (Archer 2001). In the case of common 

burdock (Arctium minus), the prickly burs can trap bats and hummingbirds and cause direct mortality to 

individuals (Raloff 1998). Invasive plants that grow large and densely (e.g., giant reed, Himalayan 

blackberry) can act as physical barriers to water sources and essential habitat.

Invasive plants can act as a population sink by attracting a species and then exposing it to increased 

mortality or failed reproduction (Chew 1981). Schmidt and Whelan (1999) reported that native birds 

increased their use of exotic Lonicera and Rhamnus shrubs over native trees, even though nests built in 

the exotic shrubs experienced significantly higher mortality rates.

Some invasive plants, such as knapweed, contain chemical compounds that make the plant unpalatable to 

grazing animals. Chemical compounds in these invasive plants disrupt microbial activity in the rumen or 

cause discomfort after being ingested, resulting in a reduced or avoided consumption of the invasive plant 

(Olson 1999).

Habitats that become dominated by invasive plants are often not used, or are used much less, by native 

and rare wildlife species, and species, such as yellow starthistle and knapweed reduce, wildlife habitat 

(USDA Forest Service 2007, Utah State University 2013), and degrade upland game bird habitat. Some 

hunters and wildlife managers are concerned that invasive plants are degrading the quality of remaining 

habitat for deer and elk, adversely affecting distribution of the animals, and hunting opportunities.

Trammell and Butler (1995) found that deer, elk, and bison avoided sites infested with leafy spurge 

(Euphorbia esula). Tamarisk stands have fewer and less diverse populations of wildlife (Jakle and Gatz 

1985; Olson 1999). Invasion by purple loosestrife makes habitat unsuitable for numerous birds, reptiles, 

and mammals (Kiviat 1996; Lor 2000; Rawinski 1984 and Malecki 1984; and Thompson et al. 1987; 

Weiher and Neely, 1997; Weiher et al. 1996). Reed canarygrass, implicated in the loss of Oregon spotted 

frog habitat, may have contributed to contractions in the range of Oregon spotted frogs in western Oregon 

(Hayes 1997; McAllister and Leonard 1997). Bald eagle mortality in other parts of the U.S. has been 

linked to a toxin produced by cyanobacteria that grow on the invasive aquatic plant, Hydrilla verticillata

(Wilde 2005).

In summary, invasive plants are known or suspected of causing the following effects:

♦ Embedded seeds in animal body parts (e.g., foxtails), or entrapment (e.g., common burdock) 

leading to injury or death.

♦ Scratches leading to infection.

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♦ Alteration of habitat structure leading to habitat loss or increased chance of predation (Schmidt 

and Whelan 1999). 

♦ Change to effective population size through nutritional deficiencies or direct physical mortality.

♦ Poisoning due to direct or indirect ingestion of toxic compounds found on or in invasive plants.

♦ Altered food web and nutrient cycling (Allison and Vitousek 2004; Ehrenfeld 2003; Rimer and 

Evans 2006).

♦ Source-sink population demography, with more demographic sinks than sources.

♦ Lack of proper forage quantity or nutritional value at critical life periods.

Terrestrial Wildlife Species of Conservation Concern

Federally Listed Species

The following section discusses species that have been, are currently, are proposed for, or are candidates 

for listing under the federal Endangered Species Act (ESA). Threatened and endangered species evaluated 

include the Canada lynx (threatened), North American wolverine (proposed for listing), and yellow-billed 

cuckoo (proposed for listing). The yellow-billed cuckoo was proposed for listing in October 2013 

(USFWS 2013c) and has subsequently been added to the FEIS. Three species, the bald eagle, peregrine 

falcon, and gray wolf (Rocky Mountain Distinct Population Segment (DPS)) have been delisted (USFWS 

2007a, USFWS 20011a) and are currently managed as Region 6 sensitive species. The gray wolf outside 

the Rocky Mountain DPS, which is federally endangered, does not occur within the project area and will 

not be evaluated in detail in this analysis. The project area is within the range of and provides habitat for 

the Columbia spotted frog and greater sage grouse. Because they have not been formally listed, these two

species are analyzed as Forest Service sensitive species.

Table 54. ESA species (listed, proposed, candidate, delisted)

Common Name Scientific Name Conservation Status Species 

Presence

Canada Lynx Lynx Canadensis Threatened Not Present

North American Wolverine Gulo gulo luscus Proposed Threatened Suspected

Yellow-billed Cuckoo Coccyzus americanus Threatened Suspected

Gray Wolf (Rocky Mountain DPS)1 Canis lupus Delisted-Sensitive Suspected

Gray Wolf outside Rocky Mountain 

DPS Canis lupus Endangered Not Present

Bald Eagle1 Haliaeetus leucocephalus Delisted-Sensitive Documented

American Peregrine Falcon1 Falco peregrinus anatum Delisted-Sensitive Documented

Greater Sage Grouse1 Centrocercus urophasianus Candidate-Sensitive Documented

Columbia spotted frog1 Rana luteiventris Candidate-Sensitive Documented

1

Evaluated as a Region 6 sensitive species (USDA Forest Service 2011)

The following is a brief description of the species’ life history, threats, and generally recognized species 

protection measures. The species status and available habitat on the project area and the amount of habitat 

currently affected by known invasive plant sites are also discussed. Additional information on federally 

listed species can also be found in the biological assessment prepared for the R6 2005 FEIS, which is 

incorporated by reference into this analysis. 

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Canada lynx

Status, Life History and Habitat Description - The population, distribution, life history, habitat status and 

recovery objectives for Canada lynx are detailed in Ruggiero et al. (1999), Ruediger et al. (2000), USDI 

Fish and Wildlife Service (2006) and USDI Fish and Wildlife Service (2007c). The following is a 

summary of lynx habitat preferences and biology.

Lynx are highly specialized predators of snowshoe hare (Lepus americanus) and habitat can generally be 

described as moist boreal forests that have cold, snowy winters and a snowshoe hare prey base (USDI 

Fish and Wildlife Service 2006). Lynx habitat generally consists of lodgepole pine, subalpine fir, and 

Engelmann spruce whereas dry forest types (e.g., ponderosa pine and climax lodgepole pine) generally do 

not provide suitable habitat (Ruediger et al. 2000).

Snow conditions also determine the distribution of lynx (Ruggiero et al. 1999) as lynx are adapted for 

hunting snowshoe hares and surviving in areas that have cold winters and deep, fluffy snow for extended 

periods. Because of the patchiness and temporal nature of high quality snowshoe hare habitat, lynx 

populations require large boreal forest landscapes to ensure that sufficient high-quality snowshoe hare 

habitat is available at any point in time so that lynx may move freely among patches of suitable habitat 

and among subpopulations of lynx (USDI Fish and Wildlife Service 2009a). 

Lynx are highly mobile and long-distance movements (greater than 60 miles) are characteristic (Aubry et 

al. 2000 in Ruggiero et al. 1999). Lynx disperse primarily when snowshoe hare populations decline. Subadults also disperse when prey is abundant and lynx make exploratory movements outside their home 

range (USDI Fish and Wildlife Service 2009a). 

Lynx den sites are located where coarse woody debris, such as downed logs and windfalls, in older 

regenerating stands or in mature forest is available (USDI Fish and Wildlife Service 2007c). Lynx 

productivity is highly dependent on the quantity and quality of winter snowshoe hare habitat, which is a 

limiting factor for lynx persistence. 

Threats - Risk factors for lynx include direct human threat (shooting, trapping, vehicle collisions), as well 

as changes in forage and denning habitat. Lynx have evolved a competitive advantage in deep snow 

environments due to their large paws that allow them to hunt prey where other predators cannot because 

of snow conditions. There is a concern that compacted snow routes allow these other predators access into 

isolated areas that are normally used exclusively by lynx (Wisdom et al. 2000). This increased access can 

also increase lynx vulnerability to harvest, collision, or harassment. These concerns have not been 

conclusively verified, however. Fire suppression and logging have altered the mosaic of habitats needed 

for prey species and denning sites (ibid.). Invasive plants have not been identified as a threat to lynx.

Project Area Status - The Blue Mountains represent the southern extent of lynx distribution, which would 

explain the rarity of this species on the periphery of its range both historically and now (USDI FWS 

2005). Lynx habitat in northeast Oregon is categorized as “peripheral area”. Only four relatively recent 

specimens are known, one from Wallowa County in 1964, Benton County in 1974, Harney County in 

1993 (McKelvey et al. 2000), and near Burns in 1994. Self-maintaining populations of lynx in Oregon 

have not existed historically (Verts and Carraway 1998). Based on limited verified records, lack of 

evidence of reproduction, and occurrences in atypical habitat that correspond with cyclic highs, lynx have 

never maintained resident populations, although they are considered an infrequent and casual visitor by 

the state of Oregon (Ruediger et al. 2000, pp. 4-7).

Winter track surveys for lynx and wolverine were conducted by the Forest from 1991-1994 and no 

confirmed lynx tracks were found. Hair snares were used to survey for lynx, according to the National 

Lynx Survey, during the summers of 1999-2001. There were no lynx detections confirmed from this 

survey effort. It is unknown whether lynx are currently present on the Forest, but there are no verified 

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records and there is no evidence of occupation or reproduction that would indicate colonization or 

sustained use by lynx. 

Occupied lynx habitat includes lands that either 1) have had at least two verified lynx observations or 

records since 1999 or 2) where there is evidence of lynx reproduction on the national forest (USDI FWS 

2006a). The project area is considered unoccupied lynx habitat because neither of these conditions exists.

Lynx habitat within the project area was mapped using the vegetation and environmental conditions for 

the Northern Rocky Mountains geographic area, and more specifically, the Blue Mountain Section, 

including northeast Oregon and west-central Idaho. Primary vegetation was based on the direction 

provided in the Canada Lynx Conservation Assessment and Strategy (LCAS) (Ruediger et al. 2000), and 

follow-up guidance from the Forest Service Regional Office and the Lynx Biology Team. Sixth code 

Hydrologic Unit Codes (HUC), were used as the basis for delineating lynx habitat across the Malheur 

National Forest. Although the Lynx Conservation Agreement (May 2006), states that the LCAS does not 

apply to forests that are considered as having unoccupied habitat, the lynx analysis units (LAU) acreage 

was used to identify potential lynx habitat on the MNF. Suitable lynx habitat occurs in the Strawberry, 

Glacier, and Indian Lynx Analysis Units. 

Table 56 identifies the total amount and type of suitable lynx habitat within project area LAUs, as defined 

in the LCAS, as well as known invasive plant infestations within suitable habitat. 

Currently, 16 acres of suitable lynx habitat are affected by invasive plants. Roads serve as one of the 

primary vectors for the spread of invasive plants. Lynx prefer remote habitat within forested areas, 

therefore, only a few acres of invasive weeds have been identified within suitable habitat.

Table 55. Acres of Lynx habitat in the project area

Habitat Denning(ac) Foraging(ac) Total(ac)

Suitable Lynx Habitat 26,849 14,158 41,007

Habitat Affected by Invasive Plants 8 8 16

Wolverine

Status Life History and Habitat Description - The wolverine is now a proposed threatened species, per 

findings of the USDI Fish and Wildlife Service, 50 CFR Part 17, 78 FR 7864, Endangered and Threatened 

Wildlife and Plants: Threatened Status for the Distinct Population Segment of the North American 

Wolverine Occurring in the Contiguous United States, dated February 4, 2013, found at 

http://federalregister.gov/a/2013-0148. It has a global rank of G4 and is a State threatened species.

Wolverine is a solitary and highly mobile species that tends to inhabit remote areas and occurs at 

relatively low densities (Banci 1994). Wolverines range widely from subalpine talus slopes to big game 

winter ranges, occupying higher ranges in the summer and riparian habitats in the spring. Ruggiero et al.

(1999) found that wolverines used higher elevations in the snow-free season to avoid high temperatures 

and human activity. Wolverine habitat is best defined in terms of adequate year-round food supplies in 

large sparsely inhabited areas, rather than in terms of particular types of topography or plant associations. 

No particular habitat components or habitat management techniques can presently be singled out for 

wolverine and success of wolverine may relate to the availability of large areas of remote, rugged uplands 

that are difficult to access by humans (Hatler 1989). Wolverines occur in low densities in all places they 

have been studied (Ruggiero et al. 1994). This is generally attributed to naturally low reproductive rates 

and delayed sexual maturity of the species. 

Wolverines are opportunistic feeders and consume a variety of foods depending on availability. They 

primarily scavenge carrion, but they also prey on small mammals and birds and eat fruits, berries, and 

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insects (USDI Fish and Wildlife Service 2010). In both Montana and Idaho, big game carrion appears to 

be the major food source with snowshoe hare, squirrels, and small mammals making up the rest of their 

diet (Hornocker and Hash 1981). Large mammal carrion is an important dietary component, particularly 

in winter when other prey is scarce (Banci 1994, Pasitschniak and Lariviere 1995), and wolverine rely 

heavily on the presence of other predators. Wolverines will also search for caches made by itself, other 

wolverines, or other carnivores during the winter.

Female wolverines use two kinds of dens for reproduction. Females use natal (birthing) dens to give birth 

and raise kits early postpartum, prior to weaning. They are excavated in snow and persistent, stable snow 

greater than 5 ft. in depth appears to be a requirement for natal denning, (USDI Fish and Wildlife Service 

2013a). In Montana, natal dens occur above 7,874 feet and are located on north aspects in avalanche 

debris typically in alpine habitats near timberline (USDI Fish and Wildlife Service 2013a). Prior to 

weaning, females may move kits to one or multiple alternate den sites, referred to as maternal dens. The 

movement of kits from natal to maternal dens may be a response by the female to den disturbance, better 

food availability in the new location, predation risk, or deteriorating den conditions in the natal den 

(Magoun and Copeland 1998). 

Post-weaning dens are called rendezvous sites. These dens may be used through early July. Females leave 

their kits at rendezvous sites while foraging, and return periodically to provide food for the kits. These

sites are characterized by natural (unexcavated) cavities formed by large boulders, downed logs 

(avalanche debris), and snow (Inman et al. 2007). They may also occur in talus or coniferous riparian 

zones.

Wolverine home ranges are generally extremely large and the availability and distribution of food is likely 

the primary factor in determining wolverine movements and home range. Home ranges of adult 

wolverines range from less than 38.5 square miles to 348 square miles (USDI Fish and Wildlife Service 

2010). Home ranges of adult males and females overlap extensively with the range of one male covering 

the ranges of two to six females, which is considered one reproductive unit. Witmer et al. (1998) 

suggested long-term conservation of wolverine can be achieved through maintenance of large, remote 

areas of habitat, and engaging in management activities that do not decrease ungulate prey density.

Threats - Wolverines have few natural predators although both interspecific and intraspecific mortalities 

have been documented. Wolverines are susceptible to mortality through hunting and trapping and human 

caused disturbances near den sites (Banci 1994, Hornocker and Hash 1981, Copeland 1996). Wolverine

naturally occur at low densities (Hornocker and Hash 1981, Copeland 1996).

In their proposed rule to list the wolverine as threatened (USDI Fish and Wildlife Service 2013a), it was 

determined that the impacts of climate change constitute a threat to the contiguous U.S. DPS of the 

wolverine. Wolverine populations in the remaining U.S. range appear to be at numbers so low that their 

continued existence could be at risk. These risks come from three main factors: 1) small total population 

size, 2) effective population below that needed to maintain genetic diversity and demographic stability, 

and 3) fragmented nature of wolverine habitat in the contiguous United States that results in smaller, 

isolated island patches separated by unsuitable habitats. Other threats are secondary and only rise to the 

level of threats to the DPS as they may work in concert with climate changes to affect the third risk factor; 

habitat. In their finding on the wolverine DPS, the USFWS discussed a variety of impacts to wolverine 

habitat including: 1) climate change, 2) human use and disturbance, 3) dispersed recreational activities, 4) 

infrastructure development, 5) transportation corridors, and 6) land management. The primary impact of 

climate change on wolverines is expected to be changes to the availability and distribution of wolverine 

habitat.

Project Area Status - Prior to 1973, wolverines were classified as furbearers in Oregon. Numerous 

animals have been collected or sighted around the northwest. A query of the Oregon Natural Heritage 

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database reveals that there are about 150 observations of wolverines in Oregon, with most occurring in 

the mountainous northeast (Baker, Grant, Umatilla, Union, and Wallowa Counties) region (ODFW 2013).

Although recent sightings, tracks and a road kill document their presence (Csuti et al. 2001), they are 

considered rare throughout all of Oregon, Washington, Idaho, and California.

Periodically throughout the 1990s, wolverine surveys were conducted across the Forest. Records for 

eastern Oregon include a partial skeleton and tufts of fur found near Canyon Mountain, Grant County 

(1992), tracks and a possible denning site discovered in the Strawberry Mountain Wilderness (1997), 

tracks that were noted in the Monument Rock Wilderness (1997), and hair and track collection on Snow 

Mountain Ranger District, Ochoco National Forest (1992). There have been additional unconfirmed 

sightings reported periodically on the Forest although there are no recent verified locations or physical 

evidence of their occurrence. Sightings are mostly from wilderness, or more remote, high-elevation areas.

In the Blue Mountains, source habitat for wolverine occurs primarily in wilderness and large roadless 

areas; although no den sites have been identified. Areas of low human impacts, low human disturbance, 

and high deer and elk concentrations are preferred. The best source habitat is located in the Strawberry 

Mountain Wilderness, Monument Rock Wilderness, Vinegar Hill-Indian Rock Scenic Area, the Jump Off 

Joe, Dixie Butte and Dry Cabin Wildlife Emphasis Areas, and the Shaketable, McClellan Mountain, 

Aldrich Mountain Roadless, and Baldy Mountain Roadless Areas.

Collectively, the Malheur National Forest includes approximately 82,555 acres of wilderness and 

approximately 180,822 acres of roadless areas, and these lands are most likely to be used for denning or 

dispersal. Using the forest GIS habitat layer, potentially suitable den habitat exists on approximately 

1,200 acres forest-wide, with 430 acres occurring in more remote wilderness or roadless areas. Of this, 

almost 80 percent occurs in the Strawberry wilderness. Because deep, persistent snow is characteristic of 

dispersal habitat (Schwartz et al. 2009), wolverine dispersal habitat is more likely to occur on upper 

elevation ridges and mountains whereas potential foraging habitat occurs across much of the Forest.

Invasive plants have not been identified as a primary threat to wolverine. Of the 1,200 acres of den

habitat, known infestations of invasive plants occur on less than one acre. The low level of invasive 

weeds is likely a result of the low management/use levels associated with wilderness/roadless areas, 

although extensive surveys have not been conducted in remote areas of the Forest.

Yellow-billed Cuckoo

Status, Life History, and Habitat Description - The yellow-billed cuckoo in the western United States 

was accorded federal candidate status in July 2001. On October 3, 2013, the Western U.S. DPS was 

proposed as a threatened species under the Endangered Species Act (USDI FWS 2013b). Historical 

records for the state show that breeding cuckoos were most often sighted in willow bottoms along the 

Willamette and Columbia Rivers (USDI FWS 2013b).

Western yellow-billed cuckoos breed in dense willow and cottonwood stands in river floodplains. They 

are migratory—arrive in Oregon in mid-May—and fly south to their wintering grounds in September. 

Cuckoos eat large insects, including caterpillars and cicadas, and occasionally small frogs and lizards. 

Breeding coincides with the emergence of cicadas and tent caterpillar (USDA FWS 2013b). In California, 

caterpillars and katydids appeared to be preferred food whereas white tree frogs and grasshoppers were 

utilized more while raising young (California PIF 1998).

Western cuckoos breed in large blocks of riparian habitats, particularly woodlands, cottonwoods (Populus 

fremontii), and willows (Salix sp.). Dense understory foliage appears to be an important factor in nest site 

selection, while cottonwood trees are an important foraging habitat. At the landscape level, the amount of 

cottonwood/willow-dominated vegetation cover and the width of riparian habitat appeared to influence 

cuckoo distribution and abundance. Although yellow billed cuckoos occasionally lay eggs in the nests of 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

other birds (USDI FWS 2011, USDI FWS 2001), unlike other cuckoos, they often build their own nests. 

Nests are usually loose platforms of twigs lined with leaves or finer material and in the West are often 

placed in willows, cottonwoods, and shrubs (Washington Dept. of Fish and Wildlife 2012). Cuckoos 

require horizontal branches for nesting, and nest tree height varies from approximately 10 to 25 feet 

above the ground with dense understories (Center for Biodiversity 1998, California PIF). 

The cuckoo is likely even more sensitive to habitat loss than other riparian obligate species, such as the 

willow flycatcher, because it is dependent on the combination of a dense willow understory for nesting, a 

cottonwood overstory for foraging, and large patches of habitat in excess of 50 acres (Center for 

Biodiversity 1998). It is also not known to utilize non-native vegetation in the majority of its range 

(Center for Biodiversity 1998).

Threats - Historically, the yellow-billed cuckoo bred throughout much of North America. Available data 

suggests that within the last 50 years the species’ distribution west of the Rocky Mountains has declined 

substantially, although this species probably was never common in Oregon (USDI FWS 2013b). Loss of 

streamside habitat is regarded as the primary reason for the population decline. The greatest threat to the 

species is reported to be loss of riparian habitat, and it is estimated that 90 percent of the cuckoo's streamside habitat has been lost. Habitat loss in the west is attributed to agriculture, dams and river-flow 

management, overgrazing, and competition from exotic plants, such as tamarisk. Activities that alter or 

destroy riparian habitat are of particular concern, including unmanaged cattle grazing, which contributes 

to the loss of sub-canopy vegetation and cottonwood regeneration (USDI FWS 2013b).

Project Area Status - In Oregon, the last confirmed breeding records were in the 1940s. However, four 

cuckoo sightings were made west of the Cascade Mountains between 1970 and 1994, and at least 20 

records east of the Cascades. A survey in eastern Oregon and Klamath County in 1988 located no birds, 

but identified potential breeding habitat along the lower Owyhee River (Littlefield 1988, p. 34 In USDI 

FWS 2011). Most recent records were from May and June of 1999 (Johnson and O’Neil 2001, pp. 460–

461) and a single yellow-billed cuckoo was sited during the breeding season (June 26-27 1999) along 

Bonita Road in Malheur County (approximately 15 miles east of the project area) (USDI FWS 2011). 

Recent records of cuckoos from eastern Oregon are at the Malheur National Wildlife Refuge in Harney 

County, approximately 30 miles south of the project area, and from Malheur and Deschutes counties 

(USDI FWS 2013b).

Suitable habitat was identified by using Oregon GAP data including cottonwood riparian woodlands and 

willow riparian floodplain habitat. Approximately 2,136 acres of suitable habitat was identified along the 

Middle Fork of the John Day River. Approximately 28 acres of this suitable habitat is proposed for 

treatment.

Gray Wolf

Habitat and Threats - The gray wolf is a habitat generalist inhabiting a variety of plant communities, 

typically containing a mix of forested and open areas with a variety of topographic features (Verts and 

Carraway 1998, Witmer et al. 1998). Habitat can include forests of all types, rangelands, brushland, 

steppes, agricultural lands, wetlands, deserts, tundra, and barren ground areas, although the gray wolf

appears to be more prey dependent than cover dependent. Prey species include white-tailed and mule 

deer, moose, elk, woodland caribou, bighorn sheep, mountain goat, beaver, and snowshoe hare, with small 

mammals, birds, and large invertebrates sometimes being taken, although ungulates comprise 90 percent 

or more of their diet (USDI FWS 1987). They are also opportunistic feeders and will prey on carrion 

when it is available (Witmer et al. 1998).

Wisdom et al. (2000) suggested four major challenges to wolf conservation within the Interior Columbia 

Basin: excessive mortality from humans, mortality related to roads, displacement from habitat by human 

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

activities and population isolation. Consequently, the ability of wolves to persist will be determined 

largely by the degree of human tolerance for the species (Oregon DFW 2005). 

Project Area Information - In Oregon, wolves have increased steadily since re-introduction and wolf 

numbers are currently well above recovery objectives. In northeastern Oregon suitable habitat includes 

Eagle Cap, Wenaha-Tucannon, North Fork John Day, Strawberry Mountain wilderness areas, Hells 

Canyon NRA, designated roadless areas on public lands, and areas characterized by low density of open 

roads. Such areas would be characterized as highly suitable because human densities and activity levels 

are low whereas ungulate numbers are considered adequate to support wolves (Oregon DFW 2005). 

The Idaho wolf population has been increasing steadily, and dispersal into the Blue Mountains is expected 

to continue (Oregon DFW 2005). In July 2008, a wolf pack that includes both adults and pups was 

confirmed in a forested area of northern Union county and was the first evidence of multiple wolves and 

wolf reproduction in Oregon. By the end of 2012, Oregon’s minimum wolf count was 53 wolves 

including seven packs and at least five breeding pairs. Another breeding pair was added in February 2013

(Oregon DFW 2013b). 

While occasional wolf sightings are reported, the gray wolf has not been confirmed within the project 

area. Wolf sighting information to date seems to indicate transient or lone individuals that are not part of a 

resident pack. However, the project area provides suitable remote forest habitat and supports large 

populations of big game (Oregon DFW 2005). As a result and considering a pack has been documented 

approximately 75 miles northeast in Union county, it is likely that wolf use could occur within the project 

area. 

Although foraging or dispersal habitat is relatively widespread, remote habitat suitable for denning or 

rendezvous sites is restricted to relatively un-roaded areas. Consequently, suitable wolf habitat largely 

occurs within wilderness and roadless areas, which make up almost 263,377 acres on the Forest. 

Currently only 16 acres of the wilderness/roadless lands on the Forest have documented infestations of 

invasive plants. However, as described under wolverine, due to the lack of surveys in these remote areas, 

infestations may be larger than is currently documented. Although not a threat to wolves, invasive plants 

may adversely affect the quality of habitat for big game populations. 

Forest Service (R6) Sensitive Species

Several terrestrial mammals, birds, amphibians, and invertebrate species found or suspected to be on the 

Malheur National Forest are Forest Service Sensitive Species (Table 57, Regional Forester’s Sensitive 

Species List 2011 (USDA Forest Service 2011a)). Management of Forest Service Sensitive Species is a 

proactive approach for meeting the Agencies obligations under the Endangered Species Act and the 

National Forest Management Act (NFMA), and National Policy direction as stated in the 2670 section of 

the Forest Service Manual and the U.S. Department of Agriculture Regulation 9500-4. The primary 

objectives of the Sensitive Species program are to ensure species viability throughout their geographic 

ranges and to preclude trends toward endangerment that would result in a need for federal listing. Species 

identified by the Fish and Wildlife Service as “candidates” for listing under the ESA, as well as species 

that have been de-listed from ESA are managed as R6 Sensitive Species (USDA Forest Service 2011a).

Other species of regional and local conservation concern are also managed as Sensitive Species. This 

section contains a general description of the species’ life history, project area habitat, and threats. The two 

woodpeckers shown below are also Management Indicator Species (discussed in the next section below). 

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Table 56. Forest Service sensitive species in the project area

Common Name Scientific Name Species

Status2 Project Area

Documentation1

Mammals

Gray wolf (Northern Rocky Mtn. DPS) Canis lupus DL east of 

Hwy 395, S S

Pygmy rabbit Brachylagus idahoensis S S

Townsend’s big-eared bat Corynorhinus townsendii S D

Pallid bat Antrozous pallidus S S

Fringed myotis Myotis thysanodes S S

Birds

Bald eagle Haliaeetus leucocephalus DL, S D

American peregrine falcon Falco peregrinus anatum DL, S D

Grasshopper sparrow Ammodramus savannarum S S

Wallowa rosy finch Leucosticte tephrocotis wallowa S S

Greater sage grouse Centrocercus urophasianus C, S D

Bufflehead Bucephala albeola S D

Upland sandpiper Bartramia longicauda S D

Bobolink Dolichonyx oryzivorus S D

Lewis’ woodpecker Melanerpes lewis S, D

White-headed woodpecker Picoides albolarvatus S, D

Amphibians

Columbia spotted frog Rana luteiventris C, S D

Invertebrates

Shortface lanx Fisherola nuttalli S S

Johnson hairstreak Callophrys johnsoni S S

Silver-bordered fritillary Boloria selene S D

Harney basin duskysnail Colligyrus depressus S D

Columbia clubtail Gomphus lynnae S S

1 D - species had been recently documented, S - species thought to occur or that may have suitable habitat

2 C - candidate for ESA listing, DL - delisted from ESA, S - Region 6 Sensitive Species

Pygmy Rabbit

Habitat and Threats - Oregon populations of pygmy rabbits are listed as a species of concern under the 

Endangered Species Act (USDI Fish and Wildlife Service 2013b). They typically occur in areas of tall, 

dense, sagebrush (Artemisia spp.) cover and are highly dependent on sagebrush to provide food, cover,

and protection from predators throughout the year (USDI Fish and Wildlife Service 2005c, USDI Fish and 

Wildlife Service 2013b). The winter diet of pygmy rabbits is up to 99 percent sagebrush. While big 

sagebrush is the main food of this species, native grasses and forbs are also eaten in mid-late summer. 

Additionally, there is evidence that pygmy rabbits prefer native grasses as forage over other foods during 

this period (USDI Fish and Wildlife Service 2005c).

These rabbits may be active at any time of the day or night, although most activity occurs during midmorning (USDI Fish and Wildlife Service 2005c). Pygmy rabbits dig their own burrows and need deep 

loose textured soils for burrow construction, although they occasionally make use of burrows abandoned 

by other species. As a result, they may occur in areas of shallower or more compact soils that support 

sufficient shrub cover (USDI Fish and Wildlife Service 2013b). 

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Pygmy rabbits are slow and subject to predation in open areas. Predation is the primary cause of mortality 

among adults and juveniles and can be as high as 50 percent in the first five weeks of life (USDI FWS b). 

Accordingly, pygmy rabbits tend to stay close to their burrows and have small home ranges, although 

home range size and movement distance is variable (U.S. Fish and Wildlife Service 2005c). Loss of 

sagebrush is the main reason for decline of pygmy rabbit populations (USDA Forest Service 2013b).

Agriculture, livestock grazing and associated developments, type conversions of big sagebrush to 

livestock forage, prescribed and wild fires, invasive plants, and roads also degrade their habitat. The 

invasive cheatgrass (Bromus tectorum) is of particular concern because it invades the understory of big 

sagebrush shrubs making a critical habitat site unsuitable for the rabbit (Weiss and Verts 1984).

Cheatgrass and other invasive plants replace important forage species, introduce a perpetuating fire cycle 

into big sagebrush habitat (Whisenant 1990), may reduce predator detection, impede movement, and limit 

dispersal of the pygmy rabbit. McAdoo et al. (2004) stated that weed control is an example of the highest 

priority habitat treatments for sagebrush-associated wildlife and invasive plants are considered a threat to 

the rabbit’s habitat (USDI FWS 2013b). Finally, due to its dependence on cover and limited dispersal 

ability, fragmentation of sagebrush habitat is considered a threat to this species (USDI FWS 2005c). 

Project Area Information - The project area is near the northern boundary of this species range (USDI 

FWS 2005c) and historically, pygmy rabbits have been collected from Deschutes, Klamath, Crook, Lake, 

Grant, Harney, Baker, and Malheur Counties in Oregon. However, the range of the pygmy rabbit in 

Oregon may have decreased and boundaries of the current distribution are not known (USGS 2007). Not 

all potentially suitable sites appear to be occupied and populations are susceptible to rapid declines and 

local extirpation (Weiss and Verts 1984). Historical and suitable pygmy rabbit habitat was surveyed on 

State, Bureau of Land Management (BLM) and private land in Malheur, Harney, Lake and Deschutes 

Counties in 2004/2005 (USGS 2007). Sighting within Harney County indicate that this species occurs 

mainly in the sagebrush basin south of Burns Oregon. Also, an active burrow was documented southeast 

of Burns, approximately 17 miles south of the Forest boundary (USGS 2007). 

While there have been no surveys conducted on the Malheur National Forest, and pygmy rabbits have not 

been documented within the project area, suitable habitat exists. Using GIS and Oregon GAP data for big 

sagebrush communities, suitable pygmy rabbit habitat was identified on approximately 24,715 acres 

within the project area. However, it is recognized that this is likely an overestimate of the acres of suitable 

habitat since many sites would not have preferred cover and soil conditions. Currently less than 10 acres 

of invasive plants have been documented in suitable habitat.

Townsend’s Big-eared Bat

Habitat and Threats - Townsend’s big-eared bats inhabit a wide variety of habitats from old-growth 

forests to desert. They roost in caves, mines, rock crevices, buildings, bridges, and hollows of trees, but 

they are primarily cave-dependent. The Townsend’s big-eared bat is a moth specialist with over 90 

percent of its diet composed of moths. It captures prey in flight or by gleaning from foliage (Csuti et al. 

2001). They forage in edge habitats along streams and woodlands, and within a variety of wooded types. 

They can travel long distances while foraging, including movements of over 90 miles during a single 

evening (WBWG 2005).

The primary threat to the Townsend’s big eared bat is disturbance and/or destruction of roost sites (e.g.,

recreational caving, mine exploration, mine reclamation) and studies in Oregon and Washington have 

reported sizeable reduction in numbers due to human visitation and mining (WBWG 2005). Invasive 

plants are not considered a threat to Townsend’s big-eared bats or their habitat.

Project Area Information - Townsend’s big eared bats have been documented from all five project area 

counties (NatureServe 2013). Also, they have been recently documented on the Emigrant Creek district, 

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and from caves in Dayville and the John Day fossil beds, approximately ten miles east of the project area 

(Reames 2013).

Due to the variety of habitat utilized, foraging habitat occurs across the forest whereas roost and 

hibernacula occurs in buildings, bridges, or other structures scattered across the project area. Suitable 

Townsend’s big-eared foraging habitat includes forested and shrub habitat scattered across the project 

area, and of this, approximately 1,975 acres have documented infestations of invasive plants. Invasive 

plants do not pose direct threats to this species.

Pallid Bat

Habitat and Threats - The Pallid bat is a year-round resident and most commonly inhabits arid deserts 

and grasslands often near rock outcrops and water and is less abundant in conifer and mixed forests. This 

bat usually roosts in rock crevices or buildings, and less frequently roosts in caves, tree hollows, and 

mines. It prefers narrow crevices in caves for hibernation and shows strong fidelity to roosts both within 

and between years (NatureServe 2013). Pallid bats are opportunistic generalists that glean a variety of 

arthropod prey from surfaces, as well as capture insects on the wing (WBWG 2005). Food items include 

flightless arthropods, crickets, moths, beetles, and may eat small vertebrates (NatureServe 2013, WBWG 

2005). They forage over open shrub-steppe grasslands, oak, savannahs, open ponderosa pine forest, talus 

slopes, gravel roads, and orchards (WBWG 2005). 

Pallid bats tend to roost gregariously and are sensitive to disturbance. Loss of modification of foraging 

habitat due to prescribed fire, urban development, agriculture, or pesticide use pose potential threats 

(WBWG 2005). Approximately 1,043 acres of preferred riparian, woodland, shrub, and grassland habitats 

are known to contain invasive plants. Invasive plants do not pose a direct threat to this species.

Project Area Information - The pallid bat has been documented from Haney, Grant, and Malheur 

Counties (NatureServe 2013), including Goose Rocks and the Palisades (John Day Fossil Beds), 

approximately 10 miles east of the project area. Suitable cliffline habitat occurs along the Malheur River 

canyon, Devine Canyon down to Burns, Oregon, along Middle Fork and Coyote Bluff, and this species 

has been documented at three mine sites in the Vinegar Hill area in 2009 and 2010 (Reames 2013). 

Potential roost and hibernacula occur in cliffline habitat along primary river corridors and in buildings or 

structures scattered across the forest. Pallid bat foraging habitat includes open canopy ponderosa pine 

stands, woodlands, grassland and shrub habitats, which occur on approximately 361,000 acres across the 

Forest. Invasive plants have been documented on 428 acres of this. Invasive plants are not a direct threat 

to this species.

Fringed Myotis

Habitat and Threats - The fringed myotis is a year-round resident in Oregon (NatureServe 2013). While 

distribution is patchy, it is most common in drier woodlands (oak, pinyon juniper, and ponderosa pine), 

but it is found in a variety of habitats including desert scrub, mesic coniferous forest, grassland, and sagegrass steppe (WBWG 2005). This species roosts in buildings, underground mines, rocks, cliff faces, and 

bridges, although roosting in large decadent trees and snags is common. Maternity roosts are colonial 

whereas males are thought to roost singly or in small groups. Hibernation occurs in caves, mines, and 

buildings (WBWG 2005). 

The fringed bat feeds on a variety of invertebrate taxa and the relative importance of prey items may vary 

according to prey availability, geography, and season. The two most important items commonly reported 

in its diet are beetles (Coleoptera) and moths (Lepidoptera); however, flightless taxa such as crickets and 

spiders have been reported. This species is adapted to foraging within the forest interior, as well as along 

forest edges. Modification or loss of roosting habitat is the primary threat, including human impacts to 

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caves and hibernacula as well as reduction in forest and suitable snags. Chemicals that affect bats or their 

prey are also a threat (WBWG 2005). 

Project Area Information - The fringed myotis has been documented from Haney and Grant Counties 

(NatureServe 2013), including at the Dunstan Preserve (Middle Fork John Day). Due to the variety of 

habitat utilized, foraging habitat occurs across the forest whereas roost habitat occurs within mature 

forested habitat, as well as in caves and buildings and along clifflines. While invasive plants are not 

considered a direct threat to this species, approximately 2,124 acres of suitable foraging/roost habitat 

currently contain invasive plants.

Bald Eagle

Habitat and Threats - Bald eagles are protected under the migratory bird treaty act (USDI FWS 2008) 

and the Bald and Golden Eagle Protection Act (USDI FWS 1999b). Management direction is outlined in 

the Bald and Golden Eagle Protection Act. 

Bald eagles are most common along coasts, major rivers, lakes and reservoirs (U.S. Fish and Wildlife

Service 1986), and require accessible prey and trees for suitable nesting and roosting habitat (Stalmaster 

1987). Food availability, such as aggregations of waterfowl or salmon runs, is a primary factor attracting 

bald eagles to wintering areas and influences the distribution of nests and territories (Stalmaster 1987).

Bald eagles feed primarily on fish during the breeding season, and eat waterfowl, seabirds, and carrion 

during the winter (U.S. Fish and Wildlife Service 1995).

Bald eagles usually nest in trees near water, but are known to nest on cliffs and (rarely) on the ground.

Nest sites are usually in large trees along shorelines in relatively remote areas that are free of disturbance.

Adults tend to use the same breeding areas year after year, and often the same nest, though a breeding 

area may include one or more alternative nests (U.S. Fish and Wildlife Service 1999a). Wintering eagles 

can be found concentrated at salmon spawning areas and waterfowl wintering areas, and a communal 

winter roost generally hosts several eagles each evening at the same site. Winter roosts also tend to offer 

more protection from the weather than diurnal roosts (USDI 1986). Isolation is an important feature of 

winter and night roosts, which are usually located in remote areas with less human disturbance.

A current threat to bald eagles is mortality caused by a new disease, avian vacuolar myelinopathy (AVM) 

(U.S. Fish and Wildlife Service 1999a). A recent hypothesis implicates a type of cyanobacteria that grows 

on the invasive aquatic plant, Hydrilla verticillata (Wilde 2004). The cyanobacteria are thought to 

produce a neurotoxin that is fatal to herbivorous birds and their avian predators. Mortalities caused by 

AVM can have localized impact on bald eagles, but there is currently no evidence that the overall 

recovery of the population is affected (U.S. Fish and Wildlife Service 1999a). The invasive aquatic plant 

Hydrilla verticillata is not known to occur within the project area. 

Bald eagles are still protected by The Bald and Golden Eagle Protection Act, The Lacey Act, and the 

Migratory Bird Treaty Act whereas management direction is provided in the National Bald Eagle 

Management Guidelines (USFWS 2007b). The guidelines contain recommendations for avoiding 

disturbance to nesting, roosting, and foraging eagles. Agencies are also directed by the Recovery Plan to 

address the issues of forested habitat management, prey species management, forest insect risk 

management, and contingency planning for wildfire risks to eagle habitat.

Project Area Information - The Malheur National Forest has four known bald eagle nest sites, including 

two nests on the Emigrant Ranger District (Silvies River and Delintment Nests) and two nests on the Blue 

Mountain District (Galena and Bear Valley). Also two nests occur immediately south of the proclamation 

boundary on Bureau of Land Management (BLM) administered lands (personal communication between 

Clark Reams and Howard Richburg 2013). The Silvies River and Delintment Lake territories fall within 

the Harney Basin/Warner Mountains recovery zone (RZ21), which has a habitat management goal of 16 

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nesting territories and a population goal of 10 breeding pairs of bald eagles. The Blue Mountain nests fall 

within the Blue Mountains recovery zone (RZ9), which has a habitat management goal of 14 nesting 

territories and a population goal of 8 breeding pairs of bald eagles.

Four designated bald eagle winter roosts on the Forest (Management Area 5) cover a total 2,507 acres.

Eagles typically arrive in early November and depart about the end of April. The birds often utilize 

private lands in the valleys during the day and fly to different roost areas on the Forest in the evening. The 

Rattlesnake and Coffeepot roosts are located on the Emigrant Creek District along the southern edge of 

the Forest. Roosts on the Blue Mountain Ranger District are on the perimeter of Bear Valley. Winter bird 

count surveys are conducted annually; the Emigrant Creek roost sites get consistent high use, peaking at 

about 50 to 70 birds. The Blue Mountain roost sites are used annually, but they only support a few eagles.

The LRMP establishes management area direction for communal winter roost areas, which includes 

maintaining the integrity of the roost sites, maintaining large diameter trees, and minimizing or avoiding 

disturbance during roosting periods. Seasonal closures are typically applied to management activities 

from December 1st through April 1st to help minimize disturbance.

Invasive plants do not pose a threat to the bald eagle. Infestations have been mapped within 3 acres of 

designated winter roost, and 9 acres of infestations are mapped within one-half mile of the Bear Valley 

nest. 

American Peregrine Falcon

Habitat and Threats - Peregrine falcons inhabit cliffs located generally within approximately 0.5 miles of 

riparian habitat (source of prey). Peregrines are aerial predators who feed mostly on birds. Much of the 

prey consists of species the size of pigeons and doves; however, avian prey ranges in size. Disturbance by 

human activity during the nesting season can cause nest sites and new territories to be abandoned, egg 

breakage, or diversion of adult attention. Peregrine falcons in the Pacific Northwest are most affected by 

bio-accumulation of contaminants, and direct disturbance (Pagel 2006). Invasive plants do not adversely 

affect peregrine falcons.

Project Area Information - While there are no known nests, peregrine falcons have been observed on the

Malheur National Forest. Use occurs seasonally as individuals migrate through the area in the spring and 

fall.

In 1992, surveys to identify probable nest sites were conducted on the Malheur National Forest. Cliff 

systems were rated high, medium, or low potential as hack sites or cross-foster locations. Sixteen cliff 

systems were surveyed. Locations included Aldrich Mountain, Baldy Mountain, Canyon Mountain, 

Coyote Bluffs, Fields Peak, Nipple Butte/Lake Butte, Malheur River Canyon/Black Canyon, McClellen 

Creek, Moon Mountain, Riley Creek, Ragged Rocks, Silvies Canyon, and multiple cliff systems in and 

around Strawberry Lakes. Most of the cliff systems are located along the series of mountain ranges that 

parallel the John Day Valley on the south side of the valley, primarily the Aldrich and Strawberry 

Mountains on the Blue Mountain and Prairie City Ranger Districts. Coyote Bluffs and Ragged Rocks are 

located in the Middle Fork John Day River drainage on the Blue Mountain Ranger District. Silvies 

Canyon is located south on the Emigrant Creek District. The Malheur River Canyon cliffs are located on 

the Prairie City Ranger District. Strawberry Lakes was rated high potential for nesting habitat; Ragged 

Rocks and Black Canyon were rated medium to high potential. The remaining cliff systems were rated 

medium to low potential. Sites have been periodically surveyed but no nesting peregrines have been 

identified at any of the sites. While there are no nest sites known to occur on the Forest, suitable foraging

habitat occurs across the project area.

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Grasshopper Sparrow

Habitat and Threats - Although this species has a widespread distribution, it often breeds locally and is 

considered rare or uncommon in much of its range (Slater 2004). In Oregon, it is considered one of the 

more enigmatic and erratic birds and a small population may appear in an area, persist for a few years, 

and then disappear, only to return in the future. Suitable habitat in the state is concentrated north of the 

project area in Morrow, Umatilla, and Gillam Counties, although suitable grassland habitat occurs in both 

Harney and Malheur Counties (OSU 2013).

The grasshopper sparrow is found in a variety of open grassland types, but it is area sensitive, and large 

tracks of grassland are more likely to support populations (Slater 2004, PIF 2000, Dechant 2002a). They 

prefer grasslands of intermediate height, often associated with clumped vegetation interspersed with 

patches of bare ground. Other habitat requirements include moderately deep litter and sparse coverage of 

woody vegetation and shrubs (NatureServe 2013, Slater 2004, Oregon DFW 2013, Janes 1983, Dechant 

2002a). In Morrow County, the grasshopper sparrow occurs at low densities, and Holmes and Miller 

(2010) found that grasshopper sparrows were most numerous in perennial grasslands and least abundant 

in depleted sagebrush and sagebrush/annual grass communities.

The grasshopper sparrow forages almost exclusively on bare ground and eats insects, other small 

invertebrates, grain, and seeds (NatureServe 2013). During the breeding season, grasshoppers 

(Orthoptera) have been documented comprising the majority (greater than 60 percent) of their diet with 

seeds taken secondarily (Slater 2004). The greatest threats to grassland species, such as the grasshopper 

sparrow, include continued habitat loss due to encroachment of woody vegetation (Oregon DFW 2013, 

Slater 2004), habitat fragmentation, and habitat degradation from grazing and fire (Slater 2004).

Conservation issues specific to the grasshopper sparrow in the Columbia basin (Altman and Holmes 

2000) include; 1) conversion of bunchgrass habitat to agriculture, 2) alteration of bunchgrass habitat from 

intensive grazing and exotic grass/forb invasions, 3) vulnerability due to agricultural use, 4) shrub 

encroachment from overgrazing and fire suppression, and 5) early season mowing.

Project Area Information - While the grassland sparrow has not been documented on the Forest, larger 

grassland habitat greater than 20 acres in size exists on 46,523 acres and of this, 71 acres are infested with 

invasive plants. However, this would be considered an overestimate of suitable habitat because not all 

acres would have the structural characteristics preferred (i.e., clumped vegetation of intermediate height 

with patches of bare ground). Also in many areas, they have been documented preferring grasslands 

greater than 75 acres in size (NatureServe 2013).

Wallowa Rosy Finch

Habitat and Threats - This species is restricted to the Wallowa Mountains in Northeast Oregon and 

winters to West-Central Nevada (Clements 2012). Like Leucosticte tephrocotis, the Wallowa rosy-finch 

breeds on the highest alpine peaks, as well as in barren cirques below timbered peaks on the Wallowa 

Mountains. Young remain with adults until fall and they move to lower altitudes and latitudes during the 

winter (OSU 2013). Nests are usually in rock crevices or holes in cliffs. Foraging occurs on the ground 

for seeds and in the spring they glean wind-transported insects from snow. Later in the season, they may 

glean insects from vegetation or may chase flying insects in the air (NatureServe 2013). While most high 

elevation habitats are protected, this species can be most benefitted by monitoring and protection of 

known sites.

Project Area Information - Habitat locations for this species have not been mapped on the Malheur 

National Forest. However, habitats are not likely to be infested with invasive plants because they lie in 

remote, high elevation areas that are distant from primary invasive plant vectors. Thus, potentially 

suitable habitat is not likely to be infested with invasive plants, and invasive plants are not a direct threat 

to the Wallowa rosy finch.

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Greater Sage Grouse

Status and Habitat Description - A Greater Sage Grouse and Sagebrush Habitat Conservation Team, 

consisting of state and federal agencies, private landowners, conservation groups, and academics, was 

established in 2001 to craft a comprehensive set of planning guidelines for sage grouse and sagebrush 

habitats in Oregon. The primary goal of the guidelines is to maintain existing sagebrush-steppe habitats in 

order to sustain sage grouse populations and protect options for future management.

Sage grouse breed on sites called leks (strutting grounds) in March-April. The same lek sites tend to be 

used year after year and are established in open areas surrounded by sagebrush, which is used for escape 

and protection from predators (Connelly et al. 1991). Optimum sage grouse nesting habitat consists of a 

healthy sagebrush ecosystem including sagebrush plants and an herbaceous understory composed of 

grasses and forbs.

Sage grouse nesting and early brood-rearing occurs in April-June, which is considered a critical time for 

sage grouse. Early brood-rearing generally occurs relatively close to nest sites; however, movements of 

individual broods may be highly variable (Connelly 1982). Hens with broods tend to select habitats 

having a wide diversity of plant species that support an equivalent diversity of insects that are important 

chick foods. In June and July, as sagebrush habitats dry and herbaceous plants mature, hens usually move 

their broods to moister sites in or adjacent to sagebrush cover where more succulent vegetation is 

available (Connelly and Markham 1983, Connelly et al. 1988). Examples of such habitats include low 

sagebrush (Artemisia nova; A. arbuscula) plant communities, wet meadows, and riparian areas (Connelly 

et al. 1988, Connelly and Markham 1983).

Major threats to the species are habitat conversion and degradation. Declines in sage grouse populations 

have been linked to agricultural conversion, rangeland conversion, livestock management, wildfire, 

prescribed fire, fire rehabilitation, structure and infrastructure development, juniper expansion, and 

invasions of exotic species (Blus et al. 1989; Braun 1987, Braun 1998, Connelly et al. 2000, Quigley and, 

Swensen et al. 1987, Wisdom et al. 2000, USDI Fish and Wildlife Service 2003c).

Cheatgrass (Bromus tectorum) invasion has particularly degraded sage grouse habitat by altering fire 

cycles in the sagebrush-steppe ecosystem (Crawford et al. 2004). Cheatgrass fills voids between shrubs 

and facilitates frequent fires. The frequent fires prohibit re-establishment of the big sagebrush and create 

cheatgrass monocultures that are unsuitable for sage grouse. Additional threats include herbicide and 

insecticide use (Crawford et al. 2004). Insecticide application to alfalfa fields in Idaho resulted in 

mortality to sage grouse that fed on contaminated insects (Blus et al. 1989, Connelly and Blus 1991).

Herbicides were commonly used in sage grouse habitat until the1980s to reduce cover of sagebrush and 

increase livestock forage, and these habitat alterations created areas unsuitable for sage grouse.

Project Area Information - The largest sagebrush habitats are located on the Emigrant Creek and Prairie 

City Ranger Districts, particularly along the southern boundary of the Forest where sagebrush shrublands 

extend off the Forest and on to BLM lands. Habitat on National Forest System land is often considered 

marginal when compared to larger expanses of habitat located on Bureau of Land Management (BLM) 

and private lands to the south of the Forest and in larger valleys, such as Bear Valley and Silvies Valley. 

On the northern half of the Forest, sagebrush habitats are small and highly fragmented. There have been 

incidental sightings of sage grouse on the Forest, but sightings are uncommon. There are no documented 

leks or key brood-rearing habitat identified. Sage grouse use appears to be occasional and random within 

suitable habitat.

In 1993, Oregon Department of Fish and Wildlife (ODFW) biologists estimated that Bear Valley had 

about 60 birds and a stable population. In 2003, ODFW decreased the 1993 grouse population estimates,

indicating the decline was primarily due to predation (coyotes), but also because of livestock grazing and 

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agricultural conversion. Approximately 139,500 acres of suitable habitat have been mapped on the 

Malheur National Forest and 79 acres of invasive plants have been mapped within this habitat.

Bufflehead

Habitat and Threats - The bufflehead is a tree-nesting, diving duck whose population has declined in 

some of its range (Marshall et al. 2003). For nesting, it uses mountain lakes surrounded by woodlands 

with snags (mostly aspen, but it will use ponderosa pine and Douglas-fir). Buffleheads are common in 

parts of Oregon and Washington during winter, but are rare during the breeding season. Buffleheads eat 

animal matter, with common diet items including aquatic insects and larvae, physid snails, fish, and 

sometimes herring eggs or salmon carrion. They also eat seeds of aquatic plants, such as smartweed, 

alkali bulrush, and sago pondweed (Marshall et al. 2003). Although no threats to buffleheads were 

identified, the lack of suitable breeding habitat (tree cavities adjacent to lakes) would be limiting in many 

areas. 

Project Area Information - Although breeding has not been documented in eastern Oregon, the Forest 

provides stopover habitat during migration and buffleheads have been documented adjacent to the Forest 

in Bear Valley. Suitable habitat includes Forest lakes and wetlands, which occur on approximately 350 

acres Forest-wide, and these areas could be used as “stopover” habitat during migration. Currently less 

than an acre of suitable Bufflehead habitat is known to be infested with invasive plants. Invasive plants 

have been identified as a threat to waterfowl (Blossey 1999).

Upland Sandpiper

Habitat and Threats - Upland sandpipers are a rare breeder in large montane meadows within forests of 

eastern Oregon and are almost never observed away from their breeding grounds (Oregon DFW 2013). 

They generally nest in extensive, open tracts of short grassland habitat, including native prairie, dry 

meadows, pastures, domestic hayfields, and short-grass savanna, plowed fields along highway rights-ofways, and on airfields. Preferred habitat includes large areas of short grass for feeding and courtship with 

interspersed or adjacent taller grasses for nesting and brood cover (Dechant 2002b).

In the Blue Mountains, upland sandpiper habitat is large, flat or gently rolling expanses of grassland in 

mountain valleys and open uplands with small creek drainages and wet to dry meadows. Use areas have a 

wide diversity of plants, and forb abundance is particularly important. Occurrence of upland sandpipers is 

positively correlated with patch size and they often utilize meadows, which are generally at least 125 

acres in size. They selectively nest where the vegetation is between 6 and 13 inches tall and avoid fields 

containing relatively uniform stands of grass, tall undisturbed stands of grass, or those seeded to smooth 

brome. Upland sandpipers have strong site fidelity, returning to the same area about the same time each 

year. Other key habitat features near nest sites are loafing and feeding areas that have shorter, sparser 

vegetation than nesting areas and the proximity of a small shrub or tree. Sandpipers are very secretive and 

easily disturbed by humans (Altman 2000).

Upland sandpipers feed primarily on insects, but also eat berries and seeds of grasses and forbs (Csuti et 

al. 2001). They prefer upland sites that have higher soil moisture than adjacent areas and foraging sites 

often had surface water during spring. A moderate threat to upland sandpiper habitat exists from declines 

associated with plowing of natural grasslands, degradation and fragmentation of habitat due to increased 

urbanization, farming practices, and forest succession (NatureServe 2013).

Project Area Information - From the 1980s through 1991, Oregon had the largest population of nesting 

sandpipers west of the Rockies. Seven locations make up the Oregon population, and two of those areas 

are Bear Valley and Logan Valley on the Malheur National Forest. In Bear Valley and Logan Valley, 

numbers of nesting upland sandpipers have been declining since the mid-1980s.

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Bear Valley and Logan Valley locations accounted for over half of the sandpipers in the state in 1984, 

when 23 pair (7 nests) and 3 singles were found in Bear Valley, and 12 pair (2 nests) and 6 singles were 

found in Logan Valley. Nests have been found along ditches or near moist areas, often adjacent to 

sagebrush. Both Bear Valley and Logan Valley have areas of short grasses mixed with forbs and scattered 

sagebrush patches. The removal of sagebrush and the seeding of non-native grasses have altered the 

habitat in Bear Valley east of Highway 395, where upland sandpipers nested in the 1980s. Although bird 

numbers have declined, management has not changed in the rest of Bear Valley, which contains the 

majority of the occupied habitat. Logan Valley management has apparently changed and lodgepole pine 

has encroached in the valley. Water regimes and drainage patterns have also changed, which have affected 

the character of the habitat

Potential upland sandpiper habitat includes all grassland and shrubland habitat that is 125 acres in size or 

more and on slopes of less than 25 percent (Dechant 2002b). Approximately 78,669 acres exist Forestwide, although due to the height and structural preferences, preferred habitat would be less. Of the larger 

grassland/shrub habitats that provide potentially suitable habitat, 72 acres are currently infested with 

invasive weeds.

Bobolink

Habitat and Threats - The bobolink is a bird of open prairies, grasslands, wet meadows, pastures, and 

grain crops. In Oregon, there are only a few disjunct populations that breed in irrigated hay meadows 

fringed with willows or in wet, grassy meadows with local growths of forbs and sedges. Many of these 

areas are mowed and/or grazed, which facilitates nesting of bobolinks. Bobolinks eat grass and forb seeds,

as well as insects. During the breeding season, more insects are included in the diet, especially 

caterpillars. Keys to management are to provide large areas of suitable habitat (native and tame grasslands 

of moderate height and density with adequate litter, controlling succession, and protecting nesting habitat 

from disturbance during the breeding season (early May to mid-July) (Dechant et al. 2001).

Project Area Information - Limited habitat exists in areas that have grasslands, wet meadows, willows,

or other water-loving shrubs. Oregon GAP data was used to identify potential bobolink habitat, which 

includes all, grasslands, wetlands, wet meadows, and willow bottoms. These areas total 17,080 acres and 

50 acres of invasive plants are known to occur on these lands.

Lewis’ Woodpecker

Status and Habitat Description - Breeding habitat includes open forest and woodland, often logged or 

burned, including oak, coniferous forest (primarily ponderosa pine), riparian woodland, orchards, and less 

commonly pinyon-juniper (Millen-McLean 2012d, NatureServe 2013). Important habitat features include 

an open tree canopy, a brushy understory with ground cover, large dead trees, and downed woody debris 

(DWD). They prefer open ponderosa pine at high elevations and open riparian vegetation at low 

elevations (NatureServe 2013, Altman and Holmes 2000, Thomas et al. 2009).

Unlike other woodpeckers, this species seldom excavates its own cavity for nesting and greatest densities 

often occur in areas of high snag density, such as burned areas (Mellen-Mclean 2012a). In late summer, 

wandering flocks move from valleys into mountains, and in winter, this species uses oak woodlands and 

fruit orchards. Lewis’ woodpeckers feed on adult emergent insects in summer and ripe fruit and nuts in 

the fall and winter. Unlike other woodpeckers, this species does not bore for insects but will take insects 

aerially (hawking), glean insects from tree branches or trunks, or drop from perch to capture insects on 

the ground (NatureServe 2013). Within the Columbia Plateau, historical levels of source habitat have 

declined by 95 percent (Altman and Holmes 2000) and this species has been locally extirpated in parts of 

its range (Altman et al. 2000).

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Project Area Information - While the Lewis’ woodpecker has been documented from three counties 

within the project area (Grant, Crook, and Baker) (NatureServe 2013), most of the existing sightings have 

occurred in burned areas. However, scattered sightings have also occurred within ponderosa pine 

woodland and cottonwood riparian communities in the northern portion of the project area. Habitat for 

this species was identified by looking at dry ponderosa pine with large snags and open canopies, 

cottonwood/willow communities, and more recent post fire (since 1990) habitat. Currently approximately 

275 acres of invasive plants have been mapped within the 311,700 acres of post-fire suitable habitat. 

Invasive plants are not considered a direct threat to forested habitat preferred by this species.

White-heated Woodpecker

Habitat and Threats - White-headed woodpeckers occur mainly in open ponderosa pine or mixed-conifer 

forests dominated by ponderosa pine, usually in old-growth or in stands with old-growth components.

They excavate cavities in snags, as well as stumps, logs, and dead tops of live trees. Pine seeds are a 

major part of its diet in the fall and winter, although they also probe, glean, and pry off loose bark for 

insects and catch insects in the air. Over the course of the year, pine seeds and insects make up 60 percent 

and 40 percent of its diet respectively (NatureServe 2013). Populations in Oregon are decreasing due to 

fragmentation and a loss of forest cover (Audubon 2013).

Project Area Information - The white-headed woodpecker is currently documented from over 60 

locations across the forest with nesting confirmed in ponderosa pine woodland. Habitat for this species 

was identified by selecting dry ponderosa, Douglas fir, and dry pine communities with an open canopy 

(10-40%) and tree sizes greater than or equal to 21 inches dbh. Using this criteria, there are currently 

21,509 acres of white-headed woodpecker habitat scattered across the project area. Of this acreage, 

invasive plants are known to occur on approximately 10 acres. Invasive plants are not considered a direct 

threat to forested habitat preferred by this species.

Columbia Spotted Frog

Status and Habitat Description - The Great Basin Distinct Population Segment (DPS) of the Columbia 

spotted frog is a federal candidate species and is found in Oregon, Idaho, and Nevada. It has been 

documented on the Malheur, Ochoco, Umatilla, and Wallowa-Whitman National Forests. Columbia 

spotted frogs are highly aquatic and usually stay near permanent, quiet water along the grass and sedge 

margins of streams, lakes, ponds, springs, and marshes. Breeding habitats include a variety of relatively 

exposed, shallow-water (less than two feet), emergent wetlands, such as sedge fens, riverine over-bank 

pools, beaver ponds, and the wetland fringes of ponds and small lakes. Vegetation in the breeding pools 

generally is dominated by herbaceous species, such as grasses, sedges, and rushes, and froglets and adults 

live in well-vegetated ponds, marshes, or slow, weedy streams that meander through meadows (Corkran 

and Thomas 2006). Springs may be used as over-wintering sites for local populations (Hayes et al. 1997).

After breeding, adults often disperse into adjacent wetland, riverine, and lacustrine habitats. Columbia 

spotted frogs are capable of long movements, including across uplands (Bull and Hayes 2001).

Larvae have a diet of algae, plant material, and other organic debris. Adults eat arthropods (ants, beetles, 

mosquito larvae, spiders, and grasshoppers), mollusks, tadpoles, crayfish, and other invertebrate prey 

(NatureServe 2013, Hayes et al. 1997, Csuti et al. 2001). Threats to the species include mining, livestock 

grazing, road construction, agriculture, and direct predation by bullfrogs and non-native fishes. Also,

environmental stressors, such as pesticides, herbicides, fertilizers, and heavy metals may slow reactions or 

cause behavioral changes that make spotted frog tadpoles more vulnerable to predation (Lefcort et al. 

1998, Rosenshield et al. 1999, Marco et al. 1999, Bridges 1999b, Bridges and Semlitsch 2000).

Project Area Information - Columbia spotted frogs are believed to be in all sub-basins of the project area 

and this species is often found in natural ponds and lakes, rock pits, old mining ponds, livestock 

stockponds, and slow moving streams that retain water year-round. Spotted frog surveys have been 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

conducted periodically since the 1980’s, and although not all areas of the Forest were surveyed, they did 

confirm that the species is fairly well distributed, but occurs at low levels. Most spotted frogs on the 

Forest have been found in small pools along perennial streams or in mining ponds and small lakes.

Suitable breeding habitat was estimated using existing wetland habitat, sedge meadow habitat from 

Oregon GAP data and all lands within 300 feet of forest water bodies and springs. This totals 

approximately 58,700 acres and has 52 acres of documented invasive plants. This species could be 

affected by invasive plants, especially in wetland habitats.

Shortface Lanx

Status and Habitat Description - Shortface lanx are a non-migrant freshwater snail that can be found in 

the main channel of fast flowing streams and rivers. This species is sporadically distributed in the 

Columbia River and a few major tributaries in Oregon, Washington, Montana, and Idaho. In Oregon, 

healthy populations of shortface lanx persist in the Deschutes River and smaller populations occur in the 

John Day and Imnaha Rivers (USDA Forest Service 2010a).

Habitat includes unpolluted, cold, well-oxygenated streams and rivers between approximately 100 ft. and 

300 ft. in width. They feed by scraping algae and diatoms from rock surfaces and require streams/rivers 

with a cobble/boulder substrate (USDA Forest Service 2010a). Habitat loss and pollution are the primary 

threats to this species. Populations have been lost from most tributaries and almost all the Columbia River 

due to impoundments and the loss of rocky substrate (USDA Forest Service 2010a).

Project Area Information - In Oregon, the shortface lanx has been documented on the Wallowa Whitman 

National Forest and is suspected on the Malheur and Ochoco Forests (USDA Forest Service 2010a). 

Suitable habitat includes approximately 16 miles of river habitat associated with the John Day and 

Malheur Rivers. Invasive plants are not considered a direct threat to this species, and there are no 

documented invasive plants within 100 feet of suitable habitat.

Johnson Hairstreak

Status and Habitat Description – This butterfly has been reported in Oregon from the Cascades Coast 

Range, Siskiyou Mountains, Blue Mountains, and Wallowa Mountains (USDA Forest Service 2011b) and 

is associated with old growth and mature forests. Habitats include clearings among conifer forests, 

especially mature ponderosa pine, although lodgepole pine, true fir, Douglas fir and western larch are also 

utilized (Pyle 2002). Larvae feed exclusively on aerial shoots of dwarf mistletoe (Arceuthobium species) 

and adults feed on the nectar of flowers in several families. All sightings in Washington and Oregon have 

been in coniferous forests (Pyle 2002).

Threats to this species include habitat loss, pesticides, such as Bacillus thuringiensis, and herbicides that 

are applied to flowering plants that this species visits. Also, there is some evidence of hybridization with 

the thicket hairstreak (C. spinetorum) (USDA Forest Service 2011b). 

Project Area Information - While there have been no surveys on the Forest and this species has not been 

documented, Johnson’s hairstreak has been documented from Baker County (Oregon Biodiversity 2010) 

and use is possible. While suitable habitat for this species was not identified, it could occur in coniferous 

forest containing host plants. Invasive plants are not considered a direct threat to habitat for this species.

Silver-Bordered Fritillary

In Oregon, these butterflies have been found in Big Summit Prairie in Crook County, from the Strawberry 

Mountains in Grant County, and from Baker County (USDA Forest Service 2010b, Oregon Biodiversity 

2010). Habitat for this species can be found in bogs, open riparian areas, and in marshes containing large 

amounts of Salix and larval food plants (Warren 2005 In USDA Forest Service 2010b). Adults lay eggs on 

or near violets, usually marsh violet (Viola palustris) and bog violet (V. nephrophylla). Adults feed on 

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

nectar of various composites. Sunny habitats encourage adult flight and in Baker County annual broods 

are likely to occur from mid to late May whereas Grant County populations fly between early June and 

Mid-August (USDA Forest Service 2010b).

The silver-bordered fritillary is dependent upon maintenance of wet meadow habitat and its associated 

food plants. Downcutting of creeks and subsequent draining and drying out of meadow habitat, due in 

part to loss of beaver populations, loss of native plant species due to livestock grazing, and invasion of 

non-native grasses are threats to this species.

Project Area Information - While not documented on National Forest System lands, silver-bordered 

fritillary have been documented on adjacent private land and use of suitable wet meadow habitat on the 

forest is likely. Suitable habitat, includes riparian/wetland non-forest communities identified from the 

forest wetland and vegetation GIS layers, combined with Oregon GAP wet/sedge meadow habitat.

Currently there are approximately 22,100 acres of potentially suitable habitat and with 34 acres known to 

contain invasive plants.

Harney Basin Duskysnail

Status and Habitat Description - To date in Oregon this species is only documented from the Silvies 

River drainage in Harney County and from the Fremont Winema National Forest in Lake County (USDA 

Forest Service 2013). Little is known about the feeding habitats, growth, reproduction, or life span of this 

recently described species. Hydrobiidae snails, in general, feed on algae, diatoms, and detritus. Habitat 

includes shallow, cold springs and runs at elevations between approximately 4,480 and 4,670 feet with 

surrounding vegetation of sage scrub (Deixis MossuscDB 2009, Hershler 1999 In USDA Forest Service

2013). While abundance estimates of this species have not been conducted, the Forest Service noted very 

high abundance at one large spring site and most rocks had many snails attached; thousands of individuals 

were thought to be present (2013).

Any modification of the cold-water spring environment where this species lives could be a potential threat 

to its survival. A number of habitat threats have been identified for this species, including livestock 

grazing, water and site degradation associated with recreation, and wildfire and retardant chemicals. 

Conservation strategies include protecting known sites and maintenance of water quality and substrate 

conditions (USDA Forest Service 2013).

Project Area Information - This species has been documented on the Malheur National Forest and is 

suspected on the Ochoco National Forest and adjacent BLM land (USDA Forest Service 2013). The 

Malheur National Forest site (Spring Creek) where this species occurs is a large cold-water perennial 

spring flowing out of a lava cliff. The springs create a fast, cold flow, are about 15 ft. wide and one to 

eight inches deep. Fish are present, and yellow monkey flower (Mimulus sp.), water cress (Nasturtium 

sp.), and other aquatic and riparian plants are prevalent. Spring Creek is one of the larger springs in a 

complex of springs and appears to be a secure habitat for this species due to a lava boulder field offering 

protection from grazing; however, part of the site is a favorite local recreational site that receives a high 

level of riparian disturbance and recreation (USDA Forest Service 2013).

There are no known invasive plants at the Spring Creek site, although invasive plants are mapped in the 

surrounding watershed. Invasive plants are not considered a direct threat to this species.

Columbia Clubtail

Status and Habitat Description - In Oregon, the Columbia clubtail is known to occur over a somewhat 

short stretch (about 15 miles) of the John Day River in Wheeler and Grant Counties and from a single 

location on the Owyhee River near Rome in Malheur County. Although this dragonfly is fairly common 

in areas where it is found, it has one of the most restricted ranges of any North American odonate (USDA 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Forest Service 2012). This non-migratory dragonfly can be found in a variety of river habitats, which can 

range from sandy or muddy to rocky, shallow rivers with occasional gravelly rapids. Water flow tends to 

be slow moving and larval river habitat is most critical. Eggs are laid in the water, and after hatching,

larvae burrow in the mud and overwinter. After emerging from the water, adults forage among shrubs 

from mid-June to mid-August (USDA Forest Service 2012). Threats include activities that affect siltation 

or runoff and introduction of predatory fish (ibid.).

Project Area Information - While not documented on the Forest, it has been documented below the 

Forest boundary in the John Day River and suitable habitat is present. Forestwide there are approximately 

100 miles of riverine habitat, which may provide breeding and winter habitat. There are currently 51 acres 

of invasive plants within 300 feet of Forest riverine habitat. This species is not adversely affected by 

invasive plants.

Management Indicator Species

Management Indicator Species (MIS) are selected species whose welfare is believed to be an indicator of 

the welfare of other species using the same habitat, or a species whose condition can be used to assess the 

impacts of management actions on a particular area (Thomas et al. 1979). Management Indicator Species 

on the Forest are identified in table 58 and are grouped into three categories including 1) big game 

(commonly hunted species), 2) old growth, and 3) primary cavity excavators (PCE’s). The following 

section discusses MIS by the habits they represent

Table 57. Management Indicator Species on the Malheur NF and Ochoco NF

Representing Species Habitat/Indicator

Big Game (commonly hunted 

species) Rocky Mountain Elk General forest habitat conditions and winter range

Old Growth

Primary Cavity Excavator Pileated Woodpecker Late-successional coniferous forests with dense canopy, high basal area, and large diameter snags

Old Growth Pine Marten Mature and old growth mesic coniferous forest with 

high structural diversity in the understory

Old Growth Three-toed 

Woodpecker Old growth lodgepole pine

Primary Cavity Excavator Primary Cavity 

Nesters

Dead/down (snag) habitat

Big Game

Rocky Mountain Elk - Rocky Mountain elk was selected as an indicator species in the LRMP to represent 

general forest habitat and winter ranges. Concern arises from its importance as a game species. Habitat 

quality for elk is evaluated in terms of forage, cover (satisfactory and marginal), elk screening, and open 

road density. The Habitat Effectiveness Index (HEI) model (Thomas et al. 1988) was not applied as the 

model is not a suitable tool for evaluating invasive plant management effects on elk. In addition, there 

would be no change in cover or road density; therefore, the habitat effectiveness index would not change 

from the existing condition from invasive species management. Treatments may increase forage; 

however, no treatment area is large enough to meaningfully change the habitat effectiveness index. 

The presence of humans degrades elk habitat by causing animal stress and hunting vulnerability. This is 

primarily associated with motorized use of open roads and the availability of vegetation (live and dead) to 

screen elk. Elk preferentially select habitats based on increasing distance from open roads (Rowland et al. 

2000). Vulnerability and hunting mortality have been found to be higher in forested stands with greater 

road densities and less vegetation to provide screening (Weber et al. 2000).

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

Elk habitat on the Forest was mapped as part of a cooperative effort sponsored by the Rocky Mountain 

Elk Foundation. This effort concluded that the project area contains an estimated 624,673 acres of elk 

winter range whereas the entire forest is used during the summer. Invasive plants have been documented 

on approximately 582 acres of the forest winter range and 2,124 acres of elk summer range. Of this, 517 

acres (89 percent) of the winter range infestations and 1,860 acres (88 percent) of the summer range 

infestations are adjacent to roads. Approximately 500 acres of elk-calving habitat also occur on the 

Malheur National Forest, although there are currently no known invasive plants on these lands.

Invasive plant management is not expected to affect Oregon State Management Objectives or hunting 

permits at this time. However, invasive plants probably affect deer and elk more than any other species 

analyzed in this section and can out-compete and replace native forage plants for these ungulates. 

Consequently, eradicating, controlling, and/or containing invasive plants would improve elk and deer 

habitat.

Old Growth

Forest LRMP management area 13 (MA-13) provides for the management of old growth through a 

network of dedicated old growth (DOG) areas and replacement old growth (ROG) areas. Forestwide, a 

total of 104,453 acres occur in the DOG/ROG network, which is managed in part to provide habitat for 

old growth MIS, including the pileated woodpecker, pine marten, and three-toed woodpecker. There are 

98 acres of invasive plants known to occur within the Forest DOG/ROG network.

Pileated Woodpecker - Pileated woodpeckers prefer late successional stages of coniferous or deciduous 

forest. Because they nest in large diameter snags, roost in large diameter hollow trees, and use large logs 

and snags for foraging, pileated woodpeckers primarily associate with older stands. Approximately 80 

percent of the pileated woodpecker foraging in northeastern Oregon occurs in dead trees and dead and 

down logs (Mellen-Mclean 2012a).

The pileated woodpecker is fairly common throughout the Malheur National Forest in mature and latesuccessional mixed-conifer forest, and this species is documented in suitable habitat across the Forest. 

Forest-wide, pileated woodpecker habitat was identified using two sources, including old growth stands 

that are being emphasized for pileated woodpecker habitat, as well as stands that have the species and 

structural conditions characteristic of nesting, roosting, and foraging (i.e., multi-story stands (OFMS), 

including an average overstory diameter of 20 inches dbh. or greater. There are approximately 224,197 

acres of suitable pileated woodpecker habitat forestwide, and of this, invasive plants are known to occur 

on 247 acres. When looking only at pileated woodpecker habitat within MA 13 old-growth areas (e.g.,

DOGs and ROGs), suitable habitat exists on approximately 87,880 acres, and of this, approximately 78 

acres are known to contain invasive plants.

Pine Marten - Pine (American) marten have a wide, year-round distribution across the Blue Mountains 

(Mellen-McLean 2012b). Pine marten associate with late-seral coniferous forests characterized by closed 

canopies, large trees, and abundant standing and downed woody material. Of particular importance is the 

quantity of downed debris on the forest floor as it provides protection from predators, access to the under 

snow environment for hunting and resting, and thermal protection from heat and cold (Ruggiero et al. 

1994). Marten also show a strong preference for riparian habitat (Baldwin and Bender 2008). They eat a 

variety of small mammals, particularly squirrels, as well as voles, mice, pica, and rabbits and do not 

tolerate concentrated human use or habitat modification (Maser et al. 1981).

The historical and current density and distribution of marten in the Forest is unknown, but they are 

thought to occur in low numbers. Suitable pine marten habitat occurs on 314,134 acres across the project 

area and includes primary habitat or multi-structure forest greater than 20 inches dbh., as well as 

secondary habitat, or multi-structure forest between 15 inches and 20 inches dbh. Of the total habitat, 355 

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acres currently have invasive plants. Approximately 15,523 acres of old growth lands (DOGs and ROGs) 

within the project area are managed for pine marten, and invasive plants are known to occur on 

approximately 18 acres within these habitats. Invasive plants do not pose a direct threat to this species or 

its habitat.

Three-toed Woodpecker - The tree-toed woodpecker is an indicator for lodgepole pine and mixed conifer 

forests. Primary habitat includes higher elevation lodgepole pine, fir/hemlock, and Douglas-fir mixed 

(Marshall et al. 2003). They are associated with mature and overmature stands with elevated levels of 

dead and dying wood associated with insect and disease related mortality or stand replacing wildfire 

(Wisdom et al. 2000). They are locally abundant in areas of insect outbreaks, and their populations are 

irruptive as they follow outbreaks across the landscape. When available, post fire habitat is preferred, 

although numbers of nests decrease between three and five years post fire. They specialize on bark beetles 

(Scolytidae) versus the black-backed woodpecker, which specializes on wood boring beetles 

(Cerambycidae) (Leonard 2001).

Potentially suitable habitat was identified by taking stands with a higher density of snags, greater than 10 

inches dbh. of preferred nesting and foraging cover types (Mellon-Mcleanon 2012c), and recent post-fire 

habitat. Approximately 360,000 acres of suitable habitat exists, and of this, 428 acres are currently 

infested with invasive plants. No invasive plants have been mapped within the 631 acres of old growth 

habitat managed for this species. Invasive plants do not pose a direct threat to this species.

Primary Cavity Nesters (Snags and Dead Wood)

Primary cavity excavators, include Lewis’ woodpecker, yellow-bellied sapsucker, red-breasted sapsucker, 

Williamson’s sapsucker, downy woodpecker, hairy woodpecker, white-headed woodpecker, three-toed 

woodpecker, black-backed woodpecker, pileated woodpecker, and northern flicker. Table 59 identifies 

preferred habitat for those species not discussed above as MIS or sensitive species whereas a discussion 

of suitable habitat for these species is below. Collectively these species utilize a variety of habitats, 

although they all depend upon dead trees and down logs for reproduction and foraging.

Virtually all of the forested land provides potentially suitable habitat because primary cavity nesting 

species utilize a wide variety of snag species and size classes. Although native plant infestations occur 

within sites containing snags, because invasive plants do not affect standing dead or downed wood 

habitat, they are not adversely affecting cavity nesting species or their habitat.

Table 58. Habitat for Cavity Nesters (MIS)

MIS Cavity Nesting 

Species

Habitat

Red-naped Sapsucker Riparian habitat, especially aspen, cottonwoods, and pine forest communities.

Red-breasted Sapsucker Mature, moist coniferous and mixed deciduous-coniferous forest. Typically nest in 

large trees. 

Williamson’s Sapsucker

Open, late-successional lower montane forests (Douglas fir, western larch, grand fir, 

white fir, and ponderosa pine) and aspen and cottonwood stands with high densities 

of snags. 

Downy Woodpecker Riparian habitat and lowland deciduous forest at low to mid elevations consisting of a 

mixture of grasses, shrubs, and hardwoods.

Hairy Woodpecker Ponderosa pine forest at low to mid elevations with trees 10 to 20 inches diameter.

Black-backed Woodpecker Post fire habitat, and forest with insect and disease related mortality. Associated with 

high densities of smaller diameter snags (9 to 15 inches dbh.)

Northern Flicker Habitat generalist that prefers open areas such as open woodlands, meadows, fields,

and regeneration sites. Nests in large snags.

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Red-naped and Red-breasted Sapsucker - Source habitat for the red-naped sapsucker consists of riparian 

habitats, especially aspen, cottonwoods, alder, and pine, although habitat is less abundant in mixed 

conifer forest (Marshall et al. 2003, Wahl et al. 2005). Nest trees most common are aspen with heart rot, 

but ponderosa pine are also selected. Red-naped sapsuckers are considered common within suitable 

habitat across the Forest.

Williamson’s Sapsucker - In northeastern Oregon, this species occurs in mature and old-growth mixedconifer forests at approximately 3,500 to 6,500 ft. in elevation. Preferred habitat is comprised of open, 

later seral stages of montane and lower montane forest (Douglas fir, western larch, grand/white fir, 

ponderosa pine, aspen, and cottonwood) (Wisdom et al. 2000, Wahl et al. 2005, Marshall et al. 2003).

Both live and dead trees are used for nesting, although snags are a critical component of breeding habitat 

(Bull et al. 1980). Williamson’s sapsuckers feed at sapwells in ponderosa pine and Douglas-fir and glean 

insects from the bark of trunks and limbs (Marshall et al. 2003). Home range size is estimated at 10 to 22 

acres (Johnson and O’Neil 2001). Williamson’s sapsuckers are fairly common across the Forest.

Downy Woodpecker - In Oregon, the downy woodpecker is widely distributed in low to moderate 

elevation habitat deciduous riparian woodlands and lowland deciduous forest (Marshall et al. 2003). 

These woodpeckers are also found in parks and orchards. Territory size ranges from five to nine acres and 

nesting occurs in trees and snags greater than eight inches dbh. Downy woodpeckers have been 

documented across the Forest.

Hairy Woodpecker - Habitat for this species includes dry and wet coniferous forest at low to midelevations, as well as deciduous forest and riparian areas. The hairy woodpecker uses all ages of forest, 

although older stands are often preferred for nesting. Nesting occurs in moderately decayed snags,

primarily in ponderosa pine trees between 10 and 20 inches dbh. Highest densities occur in un-salvaged 

forests and recent (1 to 5 years) post-fire habitat with moderate to high densities of snags. Older burns do 

no support high levels of wood-boring beetles used for foraging (Saab et al. 2007). Home range size has 

been reported at between 22 and 37 acres (Marshall et al. 2003). This species is frequently detected at 

point count surveys across the Forest.

Black-backed Woodpecker - This species is largely restricted to post fire habitat (Saab and Dudley 1998).

In the Blue Mountains, it is associated with high elevation boreal and montane coniferous forest, 

especially recent (less than 5 years) post-fire habitat (Dixon and Saab 2000). However, it is occasionally 

observed in mixed conifer, lodgepole pine, Douglas fir, and spruce-fir forests (Hutto 1995). Observations 

of this species on the Forest occur primarily in areas of large stand-replacing wildfires.

Northern Flicker - The northern flicker is a common resident woodpecker in Oregon. It is a habitat 

generalist, although it is most abundant in open forests and forest edges. This species utilizes coniferous 

and deciduous forest, riparian woodlands, and urban areas (Marshall et al. 2003, Wahl et al. 2005). 

Nesting typically occurs in open areas with snags that exhibit some decay and Marshall et al. (2003) 

found that 71 percent of the nest trees had broken tops. Northern flickers are detected on a fairly regular 

basis during breeding bird surveys across the Forest, particularly in post-fire habitat.

Featured Species

Featured species identified in the Malheur and Ochoco LRMPs include species that require special 

protection. These species and their preferred habitat are displayed in table 60. Some of these species have 

already been discussed and narrative affected environment discussion is not repeated here.

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Table 59. Habitat for Featured Species

Featured Species Habitat

Northern goshawk Mature mixed conifer forest with predominantly closed-canopy conditions for nesting and 

a diversity of forest and non-forest conditions for foraging

Blue grouse

Coniferous forests (Douglas-fir, grand fir, subalpine fir) with a mixture of deciduous trees 

and shrubs near edges and clumps, and mistletoe infected Douglas-fir located on ridge 

tops or upper slope positions 

Sage grouse See Sensitive Species Section.

Osprey Large, old trees with dead tops or large snags suitable for nesting adjacent to large rivers 

or lakes. 

Pronghorn antelope Open grasslands with low sagebrush being an important component.

California bighorn sheep Alpine desert grasslands associated with mountains, cliffs, foothills, and river canyons. 

Upland sandpiper See Sensitive Species Section. 

Northern Goshawk

The northern goshawk can be found in landscapes that contain large blocks of mature forest, large trees 

for nesting, and abundant prey (squirrels, grouse, hares, larger songbirds). They use broad landscapes that 

incorporate multiple spatial scales, including more closed-canopy stands for nesting, foraging, and postfledging habitat (PFA). Nest stands are typically composed of large trees, closed canopies, and multiple 

canopy layers (McGrath et al. 2003, Reynolds et al. 1982) whereas PFAs typically include a variety of 

forest types and conditions, including young forest and openings (Reynolds et al. 1992). Goshawks are 

classified as prey generalists (Squires and Reynolds 1997) and forage for small birds and mammals in 

open understories below the forest canopy and along small forest openings (Reynolds et al. 1992).

Foraging areas are usually more open than nesting areas, but would contain large trees, snags, down logs, 

vegetative layering, and other structural elements important to prey species (Reynolds et al. 1992).

There are 142 goshawk nests and associated post-fledgling areas across the Forest. Nesting and foraging 

habitat occurs on approximately 400,700 acres; invasive plants have been mapped within about 567 acres 

of these habitats. Post-fledgling areas cover approximately 27,000 acres; invasive plants have been 

mapped within 18 acres of this habitat. Because of its preference for closed-canopy forest, invasive plants 

are not considered a direct threat to the goshawk.

Blue (Dusky) Grouse

Blue grouse prefer coniferous forest (Douglas fir, grand fir, and sub-alpine fir) with a mixture of 

deciduous trees and shrubs near edges and. They utilize large, mistletoe infected Douglas fir trees, 

generally located within the upper third of slopes as winter roosts whereas dense coniferous thickets of 

small trees, stumps, and down logs are used by blue grouse for resting, drumming, and escape cover. They 

also utilize dense deciduous areas in riparian corridors. Blue grouse home ranges are typically 1.25 to 5 

acres, and are usually associated with openings and rocky areas. The food items of blue grouse vary from 

a simple winter diet of primarily coniferous needles to a summer diet consisting of a variety of green 

leaves, fruits, seeds, flowers, animal matter, and conifer needles. While vegetation makes up over 90 

percent of their diet, young birds feed almost exclusively on insects (Schroeder 1984). 

Blue grouse occur across the Malheur National Forest. Winter roost habitat occurs on approximately 

6,800 acres. Invasive plants do not pose a direct threat to this species. Invasive plants have been mapped 

on approximately 1,870 acres of suitable coniferous forest habitat. One acre of invasive plants has been 

mapped within winter roost habitat. Invasive plants are not considered a direct threat to blue grouse.

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Bighorn Sheep

Bighorn sheep generally inhabit open areas of rocky slopes, ridges, rim rocks, cliffs, and canyon walls 

with adjacent grasslands or meadows, and few trees (Verts and Carraway 1998). Dense forest 

communities are avoided. Their primary diet consists of bunchgrass, but also includes significant amounts 

of forbs and shrubs during the growing seasons. In the spring, they will also utilize cheatgrass, which is 

an invasive annual plant. Most bighorn sheep use forage areas within one-half mile, but up to 1 mile of 

escape terrain. Summer and winter range must provide freedom from disturbance and a proper 

juxtaposition of forage, escape terrain, and water.

California bighorn sheep were introduced into the Strawberry Mountain Wilderness and near Aldrich 

Mountain. Excellent summer range and adequate quality winter range have contributed to an expanding 

or stable population. The Aldrich Mountain herd unit totals 69,060 acres and contains 13 acres of known 

invasive plants whereas less than an acre is known to occur in the 58,688 acres Strawberry Mountain unit.

Based on known infestations, invasive plants are not currently affecting bighorn sheep or their habitat. 

Osprey

Osprey are highly migratory raptors that typically breed and nest along larger rivers, lakes, and reservoirs. 

Osprey feed almost exclusively on fish and documented nests in Oregon are almost always located close 

to water with adequate fish populations. Osprey have been documented on the Forest and suitable nesting 

and foraging habitat exists along rivers and lakes. Currently 67 acres of invasive plants are mapped within 

300 feet of waterbodies or rivers that may be used for nesting or foraging. Invasive plants are not a direct 

threat to osprey.

Pronghorn Antelope

In Oregon, pronghorn antelope habitat includes sagebrush steppe, as well as areas occupied by widely 

spaced juniper or ponderosa pine. For most of the year, water is essential and animals are seldom found 

far from available sources, with most herds within 2.5 and 5 miles of water. In spring and summer, broad 

leaved herbaceous vegetation is the preferred food, although pronghorn will browse on tips of sagebrush 

in winter and occasionally eat some grasses. Common food plants include longleaf phlox, wallflower, and 

balsamroot. Pronghorn are fairly common in the open valley areas on the Forest and adjoining private, 

state, and federal lands. Populations appear to be increasing slightly. 

Approximately 78,000 acres of pronghorn habitat occur adjacent to larger blocks of habitat on private 

lands. Approximately 122 acres of invasive plants are mapped within this habitat. Invasive grasses can 

reduce habitat for local populations of antelope (California Department of Fish and Game 2013).

Landbirds

Landbirds evaluated in this analysis include focal species associated with priority or unique habitats 

identified in the Partner in Flight (PIF) Conservation Strategy for Landbirds of the Northern Rocky 

Mountains of Eastern Oregon and Washington (Altman 2000) and for the Columbia Plateau of Eastern 

Oregon and Washington (Altman and Holmes 2000). These focal species and their habitat are displayed in 

the following tables

Table 60. Northern Rocky Mountain Habitat Types - Landbird Focal Species and Their Habitats

Habitat Habitat Feature Focal Species

Priority Habitats

Dry Forests Large patches of old forest with large trees/snags White-headed Woodpecker1

Old Forest with grassy openings and dense thickets Flammulated Owl

Open understory with regenerating pines Chipping Sparrow

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Habitat Habitat Feature Focal Species

Patches of burned old forest Lewis’ Woodpecker1

Mesic Mixed Conifer

(Late Successional)

Large snags Vaux’s Swift

Overstory canopy closure Townsend’s Warbler

Structurally diverse, multi-layered Varied Thrush

Dense shrub layer in forest openings or understory MacGillivray’s Warbler

Edges and openings created by wildfire Olive-sided Flycatcher

Riparian Woodland Large snags Lewis’ Woodpecker1

Canopy foliage and structure Red-eyed Vireo

Understory foliage and structure Veery

Riparian Shrub Willow/alder shrub patches Willow Flycatcher

Unique Habitats

Sub-alpine Meadows Hermit Thrush

Montane Meadows (wet/dry) Upland Sandpiper1

Steppe Shrublands Vesper Sparrow

Aspen Red-naped Sapsucker

Alpine Gray-crowned Rosy Finch

1 – Also evaluated as an MIS or featured species

Table 61. Columbia Plateau Habitat Types - Landbird Focal Species and Their Habitats

Habitat Habitat Feature Focal Species

Priority Habitats

Steppe-Grassland Native bunchgrass cover Grasshopper Sparrow1

Steppe-Shrubland Interspersion of tall shrubs and openings Loggerhead Shrike

Burrows Burrowing Owl

Deciduous trees and shrubs Sharp-tailed Grouse

Sagebrush Large areas with diverse understory Sage Grouse1

Large contiguous patches Sage Sparrow

Sagebrush cover Brewer’ Sparrow

Sagebrush height Sage Thrasher

Shrublands Ecotonal edges of herb, shrub and tree habitat Lark Sparrow

Upland sparsely vegetated desert shrub Black-throated Sparrow (BR and OW 

only)

Juniper-Sage Steppe Scattered mature juniper trees (savannah) Ferruginous Hawk

Riparian Woodland Large snags (cottonwood) Lewis’ Woodpecker1

Large canopy trees Bullock’s Oriole

Subcanopy foliage Yellow Warbler

Dense shrub layer Yellow-breasted Chat

Large structurally diverse patches Yellow-billed Cuckoo1

Riparian Shrub Dense shrub patches Willow Flycatcher

Shrub-herbaceous interspersion Lazuli Bunting

Unique Habitats

Aspen Large trees and snags with regeneration Red-naped Sapsucker

Agricultural Fields Mesic Conditions Bobolink

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Habitat Habitat Feature Focal Species

Cliffs and Rimrock Undeveloped foraging areas Prairie Falcon

Juniper Woodland Mature trees with regeneration Gray Flycatcher

Mountain Mahogany Large diameter trees with regeneration. Virginia’ Warbler

1 – Also evaluated as an MIS, federally proposed sensitive or featured species

Nationwide Birds of Conservation Concern

In an effort to conserve bird species of concern and comply with the Migratory Bird Treaty Act, the 

United States Fish and Wildlife Service developed a Nationwide Birds of Conservation Concern (BCC) 

list in 2002. This BBC list was updated in 2008 (USFWS-2008) and identifies species, sub-species, and 

populations of migratory and non-migratory birds in need of additional conservation action. These species 

are deemed the highest priority for conservation actions and would be considered prior to taking 

management actions. Bird Conservation Regions (BCRs) were developed based on similar geographic 

parameters and each BCR identifies species of concern. The project area includes BCR 10, (Northern 

Rockies) and table 63 lists bird species of concern within this region.

Table 62. Birds of Conservation Concern

Bird Species Preferred Habitat

Bald Eagle1 Forest with Large Trees Near Open Water

Swainson’s Hawk Elevated Nest Sites In Open Country

Ferruginous Hawk Elevated Nest Sites In Open Country

Peregrine Falcons1 Cliffs, Wide Range Of Habitats

Upland Sandpipers1 Grasslands

Long-Billed Curlew Grasslands

Yellow-Billed Cuckoos Dense Riparian Cottonwoods

Flammulated Owl Open Ponderosa Pine Forests

Black Swift Cliffs Associated With Waterfalls For Nesting, Forage In Forest 

and Open Areas

Calliope Hummingbird Open Forest And Shrubs At Higher Elevations And Riparian 

Areas.

Lewis’s Woodpeckers1 Mature Open Forest With Large Snags

Williamson’s Sapsucker1 Coniferous Forest and Aspen With Snags

White-Headed Woodpeckers1 Old Open Forest With Large Snags.

Olive-Sided Flycatcher Edges And Openings Within Forest

Willow Flycatcher Dense Shrub Patches

Loggerhead Shrike Grasslands, Open Woodlands, Juniper/Sage

Sage Thrasher Large Patches Of Sagebrush

Brewer’s Sparrow Dense Sagebrush

Sage Sparrow Large Patches Of Sagebrush

McCown’s Longspur Sparse Grasslands

Black Rosy-Finch Above Timberline In Bare Rock, Cirques, Cliffs

Cassin’s Finch Open Mature Coniferous Forest

1 – Also evaluated as an MIS, federally proposed sensitive or featured species

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Gamebirds below Desired Condition

This list includes species whose populations are below long-term averages or management goals, or for 

which there is evidence of declining population trends (USDI Fish and Wildlife Service 2013c). Table 64

displays gamebirds below desired condition (GBBDC) species that may occur within the project area 

(Cornell Lab of Ornithology 2013) with feeding strategies and preferred habitat. 

Table 63. Gamebirds below desired condition

Species Habitat

Canvasback Wetlands, ponds, and lakes (plants and aquatic insects)

Mourning Dove Open forest and woodlands (seeds)

Ring-necked Duck Marshes and ponds; open water wetlands (plants and aquatic invertebrates)

Wood Duck Swamps, ponds, and wetlands with snags (insects, seeds and fruit, acorns)

Mallard Wetlands, ponds, and lakes; roadside ditches (aquatic plants and insects)

Northern Pintail Open country with shallow wetlands (insects and seeds)

Redhead Lakes and ponds (plants)

Lesser Scaup Lakes and ponds (aquatic insects and plants)

American Wigeon Wetlands, ponds, marshes, and rivers (aquatic insects and plants)

Pollinators

A reduction or shift in pollinator species could lead to changes in plant species composition or diversity 

(USDA Forest Service 2005a, 4-27). Native pollinators have co-evolved with the plants they visit, such 

that their physiology is matched to most efficiently exploit the nectar and pollen resources of the flowers 

upon which they specialize. It is highly likely that reduced species diversity from invasive plants has 

indirect negative effects on pollinators.

Many invasive plants are early successional species, meaning they colonize areas that have been recently 

disturbed. Since invasive plants have the ability to deplete available resources to lower levels than native 

vegetation can tolerate, they can quickly dominate disturbed sites and displace native vegetation. When 

invasive plants dominate native plant communities, native plant species diversity is decreased. The North 

American Pollinator Protection Campaign (2006) determined that invasive plants, left untreated, shift 

species composition and affect pollinated plants by disrupting the structure and function of ecosystems.

Colony Collapse Disorder

Pesticides are one of several factors thought to possibly contribute to catastrophic losses of honey bees,

known as “colony collapse disorder” (CCD), reported since 2006. Thus, a discussion of the possible 

connection of herbicide use proposed for the action alternatives and CCD is warranted.

The European honey bee (Apis mellifera) was introduced by European settlers in the 1600s and is not 

native to the American continents. It is widely distributed and commercially produced in the U.S. with 

escaped feral colonies formerly present across most of the country (parasitic mites have destroyed most of 

the feral honey bees across the United States (CCD Steering Committee 2007). The honey bee is used to 

pollinate agricultural crops and produce honey. The honey bee adds about $15 billion in value to 

agricultural crops each year (Morse and Calderone 2000). 

In 2006-2007, commercial honey bees in North America and other parts of the world experienced 

alarming declines characterized by the disappearance of adult bees from the hives with no or few dead 

bees near the hive; healthy, capped brood; food reserves that have not been robbed; minimal evidence of 

wax moth or hive beetle damage; and a laying queen with immature bees and newly emerged attendants 

(CCD Steering Committee 2007, Winfree et al. 2007). This phenomenon has been termed “colony 

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collapse disorder.” By 2007, almost 30 percent of beekeepers in the U.S. reported losses of up to 90 

percent of their colonies (Cox-Foster et al. 2007; Winfree et al. 2007). Colony collapse disorder has not 

been reported in wild native bees (Winfree et al. 2007).

Suspected causes of CCD include the following factors, alone or in combination: 1) environmental and 

nutritional stress; 2) new and/or re-emerging pathogens; 3) pests that attack bees; and 4) pesticides (CCD 

Steering Committee 2007). Several major setbacks to honey bee populations over the last 2 decades have 

increased stress on remaining hives as they are moved and worked for their pollination services over 

longer seasons and larger geographic areas. Climate change, drought, and unseasonably cold weather 

combine to create increased stress on bee populations. Commercial bees are often fed high fructose corn 

syrup, which may contribute to some nutritional deficiencies. Nutritional deficiencies are thought to make 

the bees more susceptible to attack from pathogens, and anecdotal evidence indicates that hives fed 

nutritional supplements over the winter are more resistant to CCD (Anonymous 2009).

Pathogens are primary suspect because CCD is transmissible to other hives through the reuse of 

equipment from CCD-affected colonies, and such transmission can be broken by irradiation of the 

equipment before use (Pettis et al. 2007). A recent paper using current gene technology has indicated that 

Israeli acute paralysis virus is strongly correlated with CCD and is a current leading candidate for its 

cause, alone or in combination with other factors (Cox-Foster et al. 2007, Kaplan 2008). Another recent 

paper implicates an infection from the parasite Nosema ceranae, but losses from CCD in hives treated for 

this parasite may differ between European and American hives (Higes et al. 2009, Goodman 2009).

Pests, including the varroa mite, small hive beetle, wax moth and others, stress bees and may harbor 

infectious agents. In particular, the varroa mite has been responsible for catastrophic losses of 50 to 100 

percent in many beekeeping operations and has eliminated most feral bee colonies. In addition, the varroa 

mite is known to carry pathogens transmitted to bees and is thought to suppress the immunity of honey 

bees (Shen et al. 2005). 

Pesticide exposure may affect bees through direct toxicity or by adding additional stress. Beekeepers treat 

hives with miticides and fungicides, and bees may be exposed to pesticides while foraging on agricultural 

crops. Currently, the classes of pesticides thought to be the most likely contributors to CCD, and being 

researched for correlation with CCD, include insecticides, miticides, and fungicides (CCD Steering 

Committee 2007). Recent research has found higher-than-expected levels of miticides and traces of a 

wide variety of agricultural chemicals in bee hives, but no consistent pattern in levels or types of 

chemicals has been identified (Kaplan 2008). 

3.7.3 Environmental Consequences

This section evaluates effects to wildlife and wildlife habitat discussed in section 3.7.2 and includes an 

analysis for each of the alternatives considered, as well as an evaluation of effects to threatened,

endangered, regionally sensitive, management indicator, and featured species, as well as birds of 

conservation concern.

Analysis Methodology

The Forest Service contracts with Syracuse Environmental Research Associates, Inc. (SERA) to conduct 

ecological risk assessments for herbicides proposed for use on National Forest System lands. The 

information contained in this document relies on these risk assessments and interpretations from the R6

2005 FEIS. 

To determine potential effects, representative wildlife and data from existing laboratory and field studies 

were used to discover which species might be at greatest risk from herbicide use. The general categories 

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analyzed and exposure scenarios developed depended upon available toxicity data and species of concern 

in Oregon. 

An exposure scenario was developed, when enough data was available, and a quantitative estimate of 

dose received by the animal type in the scenario was calculated (SERA 2007). The scenarios used to 

calculate doses include direct spray of small mammals; birds and mammals eating vegetation or insects 

sprayed with herbicide; predatory mammals and birds eating small mammals or fish; and small mammals 

drinking contaminated water. The risk assessments prepared by SERA (2001a, b; 2003a-d; 2004a-f; 2007; 

2011a-d) contain detailed analysis of the potential effects of each herbicide. Portions of risk assessments 

pertaining to wildlife are summarized in Appendix P of the R6 2005 FEIS. 

The quantitative estimates of dose were compared to available toxicity data to determine potential adverse 

effects. For this analysis, the most sensitive response (i.e., a sub-lethal effect that occurred at the lowest 

dose) from the most sensitive species was used to determine “toxicity indices” for each herbicide. When a 

calculated dose was greater than the toxicity index, the analysis stated that there was a potential for 

adverse effects. This approach assumes maximum potential effects of herbicides even though the pdfs and 

herbicide-use buffers would minimize potential exposure.

The toxicity index acts as a threshold; doses below the index would result in no known (or discountable) 

effect, and doses substantially above a threshold could pose some risk. The level of risk depends on how 

far above the threshold a particular dose is estimated to be. Due to the nature of the toxicity data, doses 

only slightly above the toxicity index would still be considered to pose no likely risk (Hazard Quotients of 

2-10).

To analyze potential effects from proposed invasive plant treatments on the project area, each species of 

conservation concern was assigned to an exposure scenario category (e.g., small insectivorous bird, large 

herbivorous mammal, etc.). Results of risk assessments for each herbicide were then applied to each 

species within the exposure scenario category to evaluate risk of each herbicide or surfactant.

Professional judgment was used to evaluate the life history traits (e.g., diet, habitat, activity patterns, 

seasonal occurrence, etc.) of each wildlife species to determine the likelihood of exposure to herbicides or 

surfactant used to treat invasive plants. The combinations of likelihood of exposure, dose estimated from 

exposure scenarios, and GIS wildlife location data for the Malheur National Forest was used to determine 

the risk of effect from herbicide treatments.

Effects of herbicide and non-herbicide treatments were evaluated using professional judgment and 

knowledge related to the life history of the species evaluated; local knowledge and documentation of 

Forestwide wildlife; available research and literature on treatments and species ecology; and information 

provided in the R6 2005 Invasive Weed EIS.

Data Limitations

Compared to data available for mammals and birds, available data is not sufficient to conduct quantitative 

estimates of exposure and toxicity data for amphibians for most herbicides. The Forest Service/SERA 

Risk Assessments use information from the literature, when available, and the calculated concentrations 

of herbicide in water from runoff or accidental spill to determine risk to amphibians. When data on 

amphibians were not available, fish were used as surrogate species. Data suggest that amphibians may be 

as sensitive to herbicides as fish (Berrill et al. 1994; Berrill et al. 1997; Perkins et al. 2000). For the 

purposes of this analysis, herbicides that pose potential risk to fish (as determined by the quantitative 

estimates from exposure scenarios) were also considered to pose a risk to amphibians.

Data is limited regarding the potential effects of herbicides on mollusks. Only glyphosate and picloram 

have been tested on a terrestrial mollusk, the brown garden snail (Helix aspersa). Neither glyphosate nor 

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picloram appeared to pose a risk to the snail (USDA Forest Service 2005e). Relyea (2005b) found no 

effect to three species of aquatic snails from the glyphosate formulation Roundup®.

Insufficient data is available in many cases to allow for a quantitative risk assessment. For instance, there 

is no quantitative scenario for a predatory bird that eats primarily other birds, such as the peregrine falcon, 

so the “fish-eating bird” scenario was used as a surrogate. This scenario likely overestimates the dose to 

the peregrine falcon because the hypothetical fish consumed are from a pond contaminated by a large spill 

of herbicide. These hypothetical fish likely have higher concentrations of herbicide in their bodies (and 

thus a higher dose to the predatory bird) than would a small bird that incidentally ingested herbicide 

before it was preyed upon. Data was insufficient to assess risk of chronic exposures for insect-eating birds 

and mammals for several herbicides. 

Direct spray of small mammals and consumption of small mammals that have been directly sprayed by 

predatory birds or mammals exceed the toxicity indices for a few herbicides. However, these scenarios, 

while possible, were determined to not be plausible. Many small mammals are nocturnal and spend 

daylight hours in burrows or in trees or seek cover if disturbed, reducing the likelihood that they would be 

directly sprayed. In the case of predatory birds or mammals, the predator would have to consume an 

entire day’s diet worth of directly sprayed small mammals to receive the dose that exceeded the toxicity 

index.

Research has not been conducted on the effect of proposed herbicides to most free-ranging wildlife, so the 

relevant data to specifically evaluate effects to different wildlife species is incomplete or unavailable. 

Specific relevant data that is lacking includes:

♦ For several herbicide/species group combinations, both NOAEL and LOAEL values have not 

been determined.

♦ There is insufficient data to assess risk of chronic exposures for large grass-eating birds or small 

insect-eating birds and mammals.

♦ The toxicity of the herbicides to amphibians, reptiles, terrestrial invertebrates, birds, and other 

animals found in Region 6 is either unknown or limited, and cannot be fully characterized with 

the available data on surrogate species.

♦ Analysis of effects for any project involving herbicide use relies on extrapolations from 

laboratory animals to free-ranging wildlife and controlled conditions to the natural environment. 

♦ There is less data available for birds than mammals, so mammal toxicity values must be used in 

bird exposure scenarios for some of the herbicides considered. 

Limitations notwithstanding, a substantial amount of scientific data on the toxicity of proposed herbicides 

to birds and mammals, and some amphibians and invertebrates exist. The data is generated by 

manufacturers to meet EPA regulations before an herbicide may be registered for use and by independent 

researchers that publish findings in peer-reviewed literature. So while some data is lacking, adequate 

information exists to assess potential impacts of the herbicides proposed on wildlife.

Effects of Alternative A (No Action)

Under alternative A, no proposed project activities would occur, and therefore, no direct or indirect 

treatment-related effects would occur. While current levels of invasive plant control may continue on 

lands of other ownership, invasive plants would continue to establish and spread within the project area at 

the rate of approximately 8 to 12 percent per year (R6 2005 FEIS) (consistently applied prevention 

measures since 2005 assume this rate to be reduced by half (R6 2005 ROD)). Native plants and habitats 

would increasingly be threatened by invasive plants. Effects on wildlife would vary. For closed-canopy 

forest species (e.g., goshawk) or species that are not affected by invasive plants (e.g., woodpeckers or 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

bats), or species that occupy habitat away from invasive plant vectors (e.g., Wallowa rosy finch), there 

would be little effect to existing or future habitat. 

Due to their proximity to invasive plant vectors and more open canopy conditions, habitats, such as 

grassland/meadows, sagebrush, open-canopied forest (e.g., savannah) and many wetland/riparian areas,

would continue to be affected by invasive plants. Wildlife dependent on these communities would have a 

reduced cover or forage as native habitat is replaced by non-natives. Infestations that become so well 

established that future treatment is cost-prohibitive could result in permanent loss of habitat (Asher 2002).

For example, habitat loss via invasive plant infestation has been reported to occur in Oregon spotted frog 

habitat that is invaded by reed canarygrass (Hayes 1997). Sage grouse and pygmy rabbits could be 

displaced if invasive plants expand into native rangeland (Connelly et al. 2000, Weiss and Verts 1984) and 

foraging habitat for elk and other big game could decrease (Rice et al. 1997). The spread of invasive 

wetland plants can also reduce waterfowl nesting habitat (Blossey 1999).

Consequently under alternative A, the long-term loss of native vegetation and habitat due to continued 

encroachment of invasive plants would adversely affect species, such as elk, antelope, grasshopper 

sparrow, greater sage grouse, upland sandpiper, bobolink, Columbia spotted frog, silver-bordered fritillary 

and several migratory birds of concern.

Effects Common to all Action Alternatives

This section discusses general effects on wildlife that are common to all action alternatives and is based 

on effects of invasive plant treatments to wildlife that are evaluated in detail in the R6 2005 FEIS, the 

corresponding Biological Assessment (USDA Forest Service 2005c), project files, and SERA risk 

assessments.

General Effects of Treatment

All treatment methods have the potential to disturb, temporarily displace, or directly harm various wildlife 

species. Conversely, successful control of invasive plant infestations provides long-term benefits to 

wildlife, by restoring native habitats. Potential adverse effects to wildlife are determined largely by the 

potential for exposure to treatment. Because most invasive species are shade intolerant, the majority of 

treatments occur in openings, early structural habitat, or in forested habitat with a relatively open canopy.

Consequently, species that occur primarily in closed-canopy forests are less likely to be affected by 

proposed treatments. Conversely, species that prefer or require relatively open habitats are more likely to 

be adversely affected by both invasive plants and treatments. 

The effects of invasive plant treatments on wildlife are relative to the size and locations of existing and 

future invasive plant infestations, the type of treatment used, and the timing and duration of the 

treatments. Treatments along disturbed roadsides are not likely to substantially affect terrestrial wildlife 

populations since this vegetation type does not provide essential habitat for native wildlife species and it 

consists of long, narrow areas spread over large distances. Treatment of large areas may create more 

disturbances for longer periods than treatment of small infestations. Treatment of dense infestations can 

create bare ground, which may reduce cover and expose certain species to increased predation. However, 

dense infestations of invasive plants do not typically occur in areas of the Malheur National Forest that 

provide suitable habitat for most wildlife species.

For the most part, invasive plant treatments would not alter habitat structure or composition for terrestrial 

wildlife species. Most of the invasive plants on the Malheur National Forests are forbs, thus woody 

species, and shrubs and trees would not likely be affected by treatments. Impacts to non-target forbs and 

grasses would generally be minor and occur within treated areas or within short distances of treated areas 

(less than 100 feet, 15 feet for spot treatment). In some cases, removal of invasive plants could cause a 

localized decrease in vegetative cover provided. However, due to the patchy nature of invasive plant 

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

infestations, there would be little cover lost. Unlike other management activities (i.e., timber harvest), 

invasive plant treatments are not likely to reduce available habitat or prey availability.

Manual and Mechanical Treatments

Disturbance from manual and mechanical treatments is likely to pose greater risks to terrestrial wildlife 

species than herbicide or cultural methods (USDA Forest Service 2005e). Small species that lack rapid 

mobility (e.g., amphibians, mollusks) and ground nesting birds are vulnerable to crushing or injury from 

people or equipment. Manual treatments can take longer to implement than other methods, increasing the 

length of time of disturbance. Manual treatments are often used at small sites, where the potential to affect

wildlife would be minimal, but may also be used in large areas with scattered invasive plants. In these 

situations, crews of 3-5 people may be in an area for more than a day. Bare ground is likely to be patchy 

in distribution with this method and less likely to interfere with animal movement or dispersal. 

Mechanical methods can generate more noise disturbance than other methods. Hand held mechanical 

equipment like chainsaws and trimmers can be used very selectively on target plants and may be less 

likely than larger equipment to harm wildlife. Use of vehicle mounted equipment, like mowers, is less 

selective and more likely to directly affect small animals than use of hand operated equipment, such as 

string trimmers. 

Biological Control

Biological control is proposed on sites that are either too large to be sprayed with herbicides, where 

invasive plant species are so abundant that other methods would not be practical, or where the biological 

control agent is effective on the target plant species and treatment can reduce or eliminate the need for 

herbicides.

Biological control will not directly affect native wildlife species; however, recent studies have found that 

native rodents may take advantage of the food source provided by biological control agents (Pearson et al. 

2000). Effects include short-term disturbance similar to that described under manual treatment during 

release. Although some bio control agents available have adverse effects to non-target wildlife, only 

APHIS and State-approved biological control agents would be used. Also, agents demonstrated to have 

direct negative impacts on non-target organisms would not be released. As a result, there are no adverse 

effects to wildlife anticipated under any of the action alternatives. 

Due to the maintenance of native vegetation and habitat, indirect effects of biological control include 

reducing invasive plant populations and providing a supplemental food source, both of which can have 

long-term benefits to wildlife. 

Cultural/Restoration

Restoration or reclamation of sites infested with invasive plants follow treatment restoration standard 13 

(USDA Forest Service 2005b) and incorporate guidelines for re-vegetation of invasive weed sites and 

other disturbed areas on National Forests and Grasslands in the Pacific Northwest (Erickson et al. 2003). 

On degraded sites where reproducing individuals of desirable species are absent or in low abundance, revegetation with well-adapted, competitive, native grasses, forbs, and legumes can be used to direct and 

accelerate plant community recovery, reduce erosion, and restore native wildlife habitat conditions. 

Restoration treatments proposed under the action alternatives include mulching, seeding, and planting. 

Effects on wildlife are similar to those described under manual treatments and include short-term 

avoidance of the site during treatment. Due to the small amount of treatment proposed, scattered nature of 

proposed sites, widespread availability of unaffected habitat, and with implementation of pdfs to protect 

species of conservation concern, effects to wildlife would be limited to short-term disturbance of the site 

during treatment.

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Herbicide Effects to Wildlife

Results of numerous field studies indicate the likelihood for direct adverse effects to wildlife from 

herbicide use is low (Marshall and Vandruff 2002, Dabbert et al. 1997, Fagerstone et al. 1977, Rice et al. 

1997, Sullivan et al. 1998, Cole et al. 1997, Cole et al. 1998, Johnson and Hansen 1969, Nolte and 

Fulbright 1997, McMurry et al. 1993a, and McMurry et al. 1993b); however, use of herbicides to treat 

invasive plants does have the potential to harm free-ranging wildlife (USDA Forest Service 2005b p. 1-

11). Herbicides can also cause some malformation or mortality to amphibians that have been exposed to 

herbicides or surfactants in water (Relyea 2005).

Risk from herbicide exposure was determined using data and methods outlined in the SERA risk 

assessments. A quantitative estimate of dose was compared to toxicity indices (table 65 and table 66). If a 

dose exceeded the toxicity index, then it was determined to have potential for an adverse effect. 

Quantitative estimates of dose for each animal group for each herbicide are contained in the project file 

worksheets. Wildlife species evaluated were placed into groups based on taxa type (e.g., bird, mammal), 

body size, and diet (e.g., insect-eater, fish-eater, or plant-eater). Exposure scenarios for the various 

groupings were used to quantitatively estimate dose and characterize risk at both the typical and highest 

application rate for each herbicide/surfactant. Exposure scenario results were evaluated in terms of 

whether or not they exceeded the NOAEL (no observed adverse effect level) for an acute exposure (i.e.,

consumed contaminated prey exclusively during a 24-hour period) or chronic exposure (i.e., consumed 

contaminated prey for 90 days). Table 65 and table 66 display the toxicity indices for birds and mammals 

used in this analysis whereas table 67 displays exposure scenarios results. Toxicity indices represent the 

most sensitive endpoint from the most sensitive species for which adequate data are available. Toxicity 

results are discussed in more detail in Appendix P of the R6 2005 FEIS.

Changes between the DEIS and FEIS related to herbicide exposure were based on information in the 

updated risk assessments for imazapyr, picloram glyphosate and triclopyr (SERA 2011). Changes include 

updated toxicity indices that are displayed in table 65 and table 66, and updated exposure scenarios that 

are displayed in table 67. Changes in table 67 also include adding an exposure scenario for small birds. 

While there was no change in updated exposure scenarios for imazapyr, there were changes in the updated 

assessments for glyphosate, picloram, and triclopyr. In all cases, changes in the updated risk assessments 

were associated with the consumption of contaminated vegetation, particularly by small mammals and 

birds consuming grasses that contain the highest concentration of picloram. The following summarizes 

results and changes for the updated exposure scenarios presented in table 67:

• Glyphosate – In the DEIS, a large mammal (acute exposure) and large bird (chronic exposure) 

consuming vegetation exceeded the toxicity index at the highest application rate. In the updated 

assessment, in addition to the large bird and large mammal consuming vegetation, small mammals 

and small birds consuming vegetation (chronic and acute exposures) also exceeded the toxicity index 

at the highest application rate. There was no change in typical application rates between the original 

and updated assessment.

• Picloram –In the DEIS, only a large mammal consuming vegetation (acute exposure) exceeded the 

toxicity index at the highest application rate. In the updated assessment for acute exposures, the large 

mammal consuming vegetation did not exceed the toxicity index at any application rate whereas 

small mammals and small birds consuming vegetation exceeded the toxicity index at the highest 

application rate. For long-term scenarios (i.e., chronic), small mammals and birds consuming 

vegetation exceeded the toxicity index at both the typical and highest application rates.

• Triclopyr – In the DEIS, only a large bird (acute and chronic) and large mammal (chronic only) 

consuming vegetation exceeded the toxicity at the typical and highest application rate. In the updated 

assessment, all animal groups consuming vegetation (acute and chronic) exceeded the toxicity index 

at the typical and highest application rate. 

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The FEIS also includes changes in pdfs that are designed to reduce toxicity risk including: 1) broadcast 

application of glyphosate and spot application of triclopyr would be limited to at or below the typical 

application rate, 2) picloram, imazapyr and metsulfuron methyl could be used every other year, and 3) 

aminopyralid could be used once a year. Additionally because NPE and POEA based surfactants have 

been dropped in the FEIS, associated risks that were identified in the DEIS have been eliminated. Other 

changes in the FEIS related to herbicide exposure and risk include updated information on invertebrates 

and mollusks, which are discussed in the pollinator and species-specific sections of this analysis.

Ultimately, the risk for adverse effects depends on a number of factors, such as wildlife feeding strategy, 

seasonal activity, and types and amounts of herbicides used. Also, implementation of pdfs, herbicide-use 

buffers, and treatment limits reduce risk. As a result and considering none of the first year/first choice 

herbicides under alternatives B and C would result in adverse effects from herbicide exposure, wildlife 

would not receive an acute or chronic exposure or concern under any alternative.

Table 64. Toxicity indices for birds

Herbicide Duration Endpoint Dose

(mg/kg/day) Species Effects Noted at LOAEL

Aminopyralid

Acute NOAEL 14 Quail Ruffled appearance at 23 mg/kg

Chronic NOEC 184* Mallard No adverse effects to adults or offspring 

at highest dose tested (184 mg/kg/day)

Chlorsulfuron

Acute NOAEL 1686 Quail No significant effects at highest dose

Chronic NOAEL 140 Quail No significant effects at highest dose

Clopyralid

Acute NOAEL 670 Mallard & 

Quail

No signs of toxicity reported, LOAEL not 

determined

Chronic1 NOAEL 15 Rat Thickening of gastric epithelium at 150 

mg/kg/day

Glyphosate

Acute NOAEL 540 Mallard & 

Quail No significant effects

Chronic NOAEL 43 Quail Decreased body weight and changes in 

bone composition

Imazapic

Acute NOAEL 1100 Quail No effects at highest dose

Chronic NOAEL 113 Quail Decreased weight gain in chicks at 170 

mg/kg/day

Imazapyr

Acute NOAEL 2510 Mallard & 

Quail No effects at highest dose

Chronic NOAEL 610 Mallard & 

Quail No signs of toxicity

Metsulfuron 

methyl

Acute NOAEL 1043 Quail No significant effects at highest dose

Chronic NOAEL 120 Mallard & 

Quail No significant effects at highest dose

Picloram

Acute NOAEL 1600 Mallard No effects to adults. Low mortality to 

young at highest dose

Chronic1 NOAEL 65 Quail Decreased body weight of chicks. 

LOAEL 127 mg/kg/day

Sethoxydim

Acute NOAEL >500 Mallard & 

Quail

No or low mortality at highest doses 

tested. LOAEL not available.

Chronic LOAEL2 10 Mallard Decreased number of normal hatchlings 

at 10 mg/kg/day

Sulfometuron 

methyl Acute NOAEL 312 Mallard Decreased weight gain at 625 mg/kg/day

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Herbicide Duration Endpoint Dose

(mg/kg/day) Species Effects Noted at LOAEL

Chronic1 NOAEL 2 Rat Effects on blood and bile ducts at 20 

mg/kg/day

Triclopyr

Acute NOAEL 126 Quail

LOAEL 350 mg/kg. Incoordination, 

lethargy (based on gavage exposure, 

which is extreme and more toxic than 

dietary exposure)

Chronic NOAEL 7.5 Mallard & 

Quail

Reduced eggshell thickness at 15 

mg/kg/day

* The chronic toxicity index is higher than the acute toxicity index because the acute value is based on a gavage study and the 

chronic value is based on a dietary exposure study. There are substantial differences in effects from the different dose methods. 

Effects from gavage dosing were rapidly reversed, but are used in the assessment of risk to be conservative. This may lead to a 

gross overestimate of acute risk (SERA 2007, p. 96-97).

1 Chronic toxicity studies in birds are not available, so the value from mammal studies is used.

2 Based on one study in which a NOAEL was not determined, so the LOAEL is used.

Sources: SERA 1998, 2001, 2003, 2004, 2007; 2011, Bakke 2003;

Table 65. Toxicity indices for mammals

Herbicide Duration Endpoint Dose

(mg/kg/day) Species Effect Noted at LOAEL

Aminopyralid

Acute NOAEL 104 Rabbit Weight loss and in coordination at 260 mg/kg

Chronic NOAEL 50 Rat Cecal enlargement at 500 mg/kg/day

Chlorsulfuron

Acute NOAEL 75 Rabbit Decreased weight gain at 200 mg/kg

Chronic NOAEL 5 Rat Weight changes at 25 mg/kg/day

Clopyralid

Acute NOAEL 75 Rat Decreased weight gain at 250 mg/kg

Chronic NOAEL 15 Rat Thickening of gastric epithelium at 150 

mg/kg/day

Glyphosate

Acute NOAEL 500 Rabbit Diarrhea at 350 mg/kg

Chronic NOAEL 500 Rabbit Diarrhea at 350 mg/kg

Imazapic

Acute NOAEL 350 Rabbit Decreased body weight at 500 mg/kg

Chronic NOAEL2 45 Dog Microscopic muscle effects at 137 mg/kg

Imazapyr

Acute NOAEL 250 Dog No effects at highest doses tested

Chronic NOAEL 250 Dog No effects at highest doses tested

Metsulfuron 

methyl

Acute NOAEL3 25 Rat Decreased weight gain at 500 mg/kg

Chronic NOAEL 25 Rat Decreased weight gain at 125 mg/kg

Picloram

Acute NOAEL 200 Rabbit Decreased weight gain at 172 mg/kg

Chronic NOAEL 20 Dog Increased liver weight at 35 mg/kg4

Sethoxydim

Acute NOAEL 1604 Rabbit Reduced number of viable fetuses, some dam 

mortality at 480 mg/kg

Chronic NOAEL 9 Dog Mild anemia at 18 mg/kg/day

Sulfometuron 

methyl

Acute NOAEL 87 Rat Decreased body weight at 433 mg/kg

Chronic NOAEL 2 Rat Effects on blood and bile ducts at 20 mg/kg/day

Triclopyr

Acute NOAEL 100 Rat Malformed fetuses at 300 mg/kg

Chronic NOAEL 5 Dog Effect on kidney at 2.5 mg/kg/day

2 Imazapic – NOAEL calculated from a LOAEL of 137 mg/kg/day and application of a safety factor of 3 to extrapolate from a LOAEL 

to a NOAEL.

3 The acute NOAEL of 24 mg/kg is very close to the chronic NOAEL, so chronic value is used for acute exposures.

4 Source of the value used by EPA (180 mg/kg) is not well documented, so the lower value of 160 mg/kg from a rabbit study is used 

as the toxicity index for this analysis.

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Source: SERA 1998, 2001, 2003, 2004, 2007, 2011 and Bakke, 2003.

Symbol meanings for the following table are as follows:

-- Exposure scenario results in a dose below or equivalent to the toxicity index.

 Exposure scenario results in a dose that exceeds the toxicity index at typical and highest application 

rates.

♦ Exposure scenario results in a dose that exceeds the toxicity index at highest application rates only.

Table 66. Exposure scenario results from FS risk assessments for mammals, birds, and honeybees, using 

the typical and highest application rates and assuming upper residue rates

Animal/Scenario

Aminopyralid

Chlorsulfuron

Clopyralid

Glyphosate

Imazapic

Imazapyr

Metsulfuron 

methyl

Picloram

Sethoxydim

Sulfometuron 

methyl

Triclopyr

Acute Exposures

Direct spray, bee -- -- -- ♦ -- -- -- -- -- -- --

Direct spray, sm. mammal -- -- -- -- -- -- -- -- -- -- --

Consume contaminated vegetation

small mammal -- -- -- ♦1,4 -- -- -- ♦1,4 -- -- 1,4

large mammal -- -- -- ♦ -- -- -- --2,4 -- -- 1,4

large bird -- -- -- -- -- -- -- -- -- -- 

small bird --3 unk --3 ♦4 --3 --4 --3 ♦4 -

3

- --3 4

Consume contaminated water

Spill, sm. mammal -- -- -- -- -- -- -- -- -- -- --

Consume contaminated insects

small mammal -- -- -- ♦ -- -- -- ♦ -- -- --

small bird2 -- unk -- ♦ -- -- -- -- -- -- 

Consume contaminated prey

carnivore (sm. mammal) -- -- -- -- -- -- -- -- -- -- --

predatory bird (sm. mammal) -- -- -- -- -- -- -- -- -- -- --

predatory bird (fish) -- -- -- -- -- -- -- -- -- -- --

Chronic Exposures

Consume contaminated vegetation

small mammal, on site -- -- -- ♦1,4 -- -- -- 1,4 -- -- 1,4

lg. mammal, on site -- -- -- -- -- -- -- -- -- ♦ 

lg. bird, on site -- -- -- ♦ -- -- -- -- ♦ ♦ 

small bird on site --3 unk --3 ♦1,4 --3 --4 --3 1,4 --3 --3 1,4

Consume contaminated water

small mammal -- -- -- -- -- -- -- -- -- -- --

Consume contaminated insects#

small mammal -- -- unk unk* -- -- -- unk unk unk unk

small bird -- -- unk unk -- -- -- unk unk unk unk

Consume contaminated prey

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Animal/Scenario

Aminopyralid

Chlorsulfuron

Clopyralid

Glyphosate

Imazapic

Imazapyr

Metsulfuron 

methyl

Picloram

Sethoxydim

Sulfometuron 

methyl

Triclopyr

carnivore (sm. mammal)# -- -- -- -- -- -- -- -- -- -- 

predatory bird (sm. mammal)# -- -- -- -- -- -- -- -- + -- --

predatory bird (fish) -- -- -- -- -- -- -- -- -- -- --

# Data are lacking regarding chronic exposures, so effects are assumed by comparing acute dose vs. chronic NOAEL, which will 

likely over-estimate actual risk.

unk – unknown; insufficient data to assess risk.

*unknown only at highest rates; typical rates pose no apparent risk.

+ Previous versions of this table showed an exceedance at high application rate for a chronic scenario. That is not shown here, 

because the actual estimated dose is equivalent to the toxicity index, rather than an exceedance.

1 – The DEIS showed no toxicity at typical or highest application rate.

2 – The DEIS showed the toxicity index was exceeded at the highest application rate.

3 – Based on available risk data, did not exceed the toxicity index at the typical and highest application rate

4 – Based on updated risk assessment results

While the amount of each herbicide/surfactant applied varies, many of the pdfs were specifically designed 

to ensure that any application rates used were below levels that would result in an exposure of a nontarget species that exceeded the NOAEL.

Standards in the Malheur National Forest LRMP require that adverse effects to wildlife from invasive 

plant treatment be minimized or eliminated through project design and implementation. All action 

alternatives were designed to comply with these standards. Project design features (pdfs) and herbicideuse buffers place restrictions on how and where herbicides are applied.

Results of the herbicide analysis indicate that birds and mammals consuming vegetation or insects that 

have been sprayed with some of the herbicides have the most potential to receive doses above the toxicity 

index, although other scenarios occasionally exceeded the toxicity index. While all proposed herbicides 

are considered low risk, in order to compare toxicity risks, proposed herbicides/surfactants were placed 

into the following four categories of “relative risk”. 

♦ Herbicides that Do Not Pose a Risk – These include herbicides that do not pose a risk to 

wildlife at either typical or highest application rates and include aminopyralid, clopyralid, 

chlorsulfuron, imazapic, imazapyr and metsulfuron methyl. There are no exposure scenarios 

anticipated that would result in adverse effects to wildlife from application of these herbicides.

♦ Lower Risk Herbicides – Sethoxydim, and sulfometuron methyl do not pose a risk to wildlife at 

typical application rates, but do pose a risk to some species at the highest application rate. While 

data is lacking to fully assess chronic impacts to an insectivorous small mammal or bird, with 

implementation of pdf F2, these herbicides would not be applied above the typical application 

rate. This minimizes the potential for exceeding the threshold of concern for wildlife to be 

exposed to harmful levels of these herbicides. 

♦ Moderate Risk Herbicides – Glyphosate does not pose a risk at typical application rates, but 

does pose an acute and chronic risk for some groups at the highest application rate. While data is 

lacking to fully assess chronic impacts to an insectivorous small mammal or bird, with 

implementation of pdf F2, this herbicide would not be applied above the typical application rate.

♦ Higher Risk Herbicides– These include herbicides that pose a risk to one or more groups at both 

the typical and highest application rate and include triclopyr and picloram. Picloram is also more 

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

persistent in some soil types. While data is lacking to fully assess chronic impacts to an 

insectivorous small mammal or bird, with implementation of the Malheur National Forest LRMP 

standard, triclopyr is limited to spot/selective methods only. Additionally pdf H3 restricts use of 

picloram on certain soil types whereas pdf H4 limits retreatment using picloram to every other 

year. As a result and considering the small amount of picloram proposed for broadcast application 

(alternative D), it is unlikely that these herbicides would pose a risk to wildlife. 

Adherence to invasive plant treatment standards and pdfs; actual animal behavior and feeding strategies; 

and/or seasonal presence/absence within treatment area reduce these risks. As a result and considering the 

limited spatial extent of infestation (over 80 percent of sites are 0.25 acres or less), the likelihood that

wildlife would be exposed to harmful levels of herbicides is reduced. The categories or risk in the FEIS 

are the same as those presented in the DEIS, except that picloram has been moved from moderate to 

higher risk, because the updated exposure scenario exceeded the toxicity index for small mammals and 

birds (chronic exposure) at the typical and highest application rate. 

As described above, effects to wildlife vary depending on the type of herbicide application proposed or 

the use of non-herbicide treatments. In addition, the effectiveness of the action alternatives at controlling 

or containing invasive plants varies by treatment. Table 68 displays the first year/first choice treatments 

that would occur in each action alternative and identifies alternative treatments within wildlife habitats 

that are considered to be “at risk” from invasive plants. The information presented is used in the 

alternative analysis to compare the extent and type of treatment within habitats affected and to help assess 

the effectiveness of each of the alternatives at controlling invasive plants.

Table 67. First year/first choice treatments by habitat type and action alternative

Habitat Invasive 

Plant 

Acres

Alternative B Acres Alternative C Acres Alternative D Acres

Herbicide No 

Herbicide

Herbicide No 

Herbicide

Herbicide No 

Herbicide Bcast Spot Bcast Spot Bcast Spot

Dry Forest4 1,386 845 541 0 0 532 854 390 996 0

Mesic Mixed 

Conifer

355 219 136 0 0 109 246 87 268 0

Riparian 

Woodland1,3

678 367 312 0 0 34 644 19 660 0

Riparian 

Shrub1,3

64 29 35 0 0 2 62 1 63 0

Montane 

Meadow

47 30 18 0 0 16 31 14 34 0

Steppe 

Shrubland2,3

72 43 29 0 0 27 45 19 53 0

Sagebrush3 79 14 65 0 0 22 57 14 65 0

Juniper 

Woodland

28 14 14 0 0 8 20 5 23 0

Grassland3 122 73 49 0 0 25 97 20 102 0

Wetland3 69 38 31 0 0 5 64 3 66 0

1 – Some of the riparian habitats are also included as other forest or non-forest communities

2 – Some inclusions of sagebrush are included in steppe shrublands

3 – Habitats that are considered to be most “at risk” from invasive plants

4 – Understory vegetation within open canopy dry forest can be adversely affected by invasive plants.

Herbicide Effects to Pollinators

The honey bee is a standard test subject for required toxicity testing of pesticides, so there is data on risk 

to bees in the risk assessments for all herbicides included in this project. Considering the herbicides 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

proposed for use in this project, only glyphosate and triclopyr at the highest application rate pose a 

potential risk to bees. Consequently, pdf F2 requires that broadcast application of glyphosate and spot 

treatment of triclopyr be limited at or below the typical application rate (See table 10).

For glyphosate, a relatively large number of acute toxicity studies have been conducted on bees and other 

species of terrestrial insects, using technical grade glyphosate as well as various glyphosate formulations, 

for contact spray and dietary exposures (Appendix 4 in SERA 2011). Contact spray of glyphosate does 

not pose a risk of mortality to bees. Consumption of contaminated food can pose a risk to terrestrial 

invertebrates at the highest application rate (at typical rate no HQs are greater than 1). For glyphosate 

without the POEA surfactant (which is the case for this project), only the upper bound estimates at the 

highest application rate exceeded the NOAEL (HQ= 2-4).

Imazapyr poses no risk to bees even at the highest application rate proposed in this project. The EPA 

classifies imazapyr as practically non-toxic to bees, and results of the Forest Service risk assessment state 

that this conclusion is clearly justified. Neither contact nor estimated oral doses exceeded the NOAEL 

(HQ <1), even at the highest application rate and upper exposure estimates.

Similarly, chlorsulfuron, clopyralid, imazapic, picloram, sethoxydim or sulfometuron methyl, at the 

highest application rate and upper exposure estimates did not exceed the NOAEL (HQ<1) for bees in 

direct contact or estimated dietary exposures.

Triclopyr TEA and BEE at the highest application rates and upper exposure estimates exceed the NOAEL 

for dietary exposures (HQ = 2-5). Central estimates of exposure, even at the highest application rates are 

equivalent to the NOAEL. Direct spray scenarios do not pose a risk to bees (SERA 2011).

None of the herbicides indicated a risk to bees in the risk assessment. With implementation of pdf F2,

which restricts broadcast application of glyphosate and triclopyr to the typical application rate (or less for 

triclopyr), and Malheur LRMP standards that limit application of triclopyr to spot techniques only, it is 

not expected that bees or pollinators would be exposed to toxic levels of herbicide under any action 

alternative.

Effects of Alternative B

Direct and Indirect Effects

Under alternative B, a total of 2,124 acres would be treated with herbicides, including 1,281 acres of 

broadcast application and 843 acres of spot treatments during the first year of treatment. Future treatments 

would be determined by the effectiveness of the initial herbicide treatments. Due to the ability to use 

aminopyralid and thus broadcast spray more area, Alternative B is expected to include less future manual 

and mechanical treatments than alternatives C or D. See Chapter 3.1.4 for a discussion about how 

alternatives C and D may result in more repeated entries.

Effects of manual, mechanical, and biocontrol treatments would be similar to those described previously 

in the Effects Common to All Action Alternatives section. Because alternative B would have fewer 

manual/mechanical treatments and considering these treatments pose a greater risk of disturbance to 

wildlife than herbicides, the likelihood of disturbance or mortality during treatment is reduced under this 

alternative. The likelihood of direct effects are further reduced, when you consider that 1 percent or less 

of the affected habitats would be treated (table 68), existing sites are small and scattered, and 

approximately 88 percent of known sites occur along open roads, which provide less preferred habitat for 

many wildlife species. Finally, using the implementation process described under section 2.4.2., Forest 

Service personnel would develop annual treatment prescriptions for all existing and new (EDRR 

described below) invasive plant infestations. This would include identification of wildlife species of local 

interest or their habitats and implementation of appropriate pdfs, including modification of treatment 

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methods/timing if necessary to reduce potential risks. Collectively for these reasons, the likelihood of 

mortality for any wildlife species is low and any disturbance would be short-term in nature. 

Effects of herbicide application would be similar to those described previously in the Effects Common to

All Alternatives section. None of the first-choice herbicides would result in an acute or chronic dose that 

exceeds the toxicity index for any group of wildlife species. While other herbicides could be used in 

subsequent years to achieve objectives, there are no adverse effects from herbicide exposure anticipated 

under this alternative with implementation of pdfs, Forest standards and treatment buffers, and

considering annual treatment prescriptions would identify species/habitats of concern and modify 

treatment type and timing if necessary.

Effects to habitat vary by the size of the infestation and effectiveness of treatment. For example, while 

bare ground can be created in dense patches of invasive plants, effects to wildlife would be reduced 

because these areas do not provide preferred habitat. Considering approximately 250 acres have 50 

percent infestation or more, cover would be retained on all sites. Alternative B includes a full range of 

treatment options, including broadcast spraying and use of aminopyralid near standing water, wetlands,

and across riparian areas; therefore, it is estimated that treatment effectiveness would be approximately 80 

percent. Also alternative B would be most effective at controlling larger infestations should they be 

detected in the future. As a result, alternative B would effectively control invasive plants and promote the 

long-term maintenance of native vegetation and wildlife, including “at risk” habitat identified in Chapter 

3.7.2.

Malheur National Forest Land and Resource Management Plan (LRMP) Amendment

The proposed LRMP amendment to add aminopyralid would likely improve the effectiveness of treatment 

(chapter 3.1.4). This would result in neutral or positive impacts to wildlife on the Malheur National Forest 

because aminopyralid poses no likely risk to wildlife and would effectively treat invasive plants, which 

can degrade habitat. 

Early Detection/Rapid Response

In addition to proposed treatments, alternative B would allow treatment of new detections (EDRR), as 

long as the treatment method is within the scope of this EIS. The treatment of newly found sites adds 

additional risk factors to wildlife just by adding additional exposure areas. This also expands the 

treatment into areas that may not have been originally anticipated. However, the implementation planning 

process identified in chapter 2 would be used with each new infestation site to determine treatment. Also,

the pdfs provide layers of caution, so even if the exact locations are not known, the potential for adverse 

effects are minimized. Implementation of pdfs and herbicide-use buffers and treatment limits would work 

together to provide sideboards to deal with the uncertainty of treating new sites (USDA Forest Service 

2008b) and ensure that direct and indirect effects are consistent with those anticipated in the FEIS.

Alternative B would be most effective at controlling infestations detected in the future (see chapter 3.1.4).

Effects of Alternative C 

Direct and Indirect Effects

Under alternative C, non-herbicide treatments would be increased on 1,389 acres, and more repeated 

manual/mechanical treatments would occur in subsequent years (see chapter 3.1.4 for discussion about 

why more repeated treatments would be necessary for alternative C). Effects of non-herbicide treatments 

would be similar to those discussed previously in the Treatment Effects Common to All Action 

Alternatives section. The likelihood of direct effects is increased somewhat under this alternative because 

manual/mechanical treatments can increase the likelihood of disturbance to less mobile species. Like 

alternative B, when you consider that 1 percent or less of the affected habitats would be treated (table 68), 

existing sites are small and scattered, and approximately 88 percent of the known sites occur along open 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

roads, which provide less preferred habitat for many wildlife species, the likelihood of direct effects are 

low. Potential for effects are further reduced when you consider implementation of pdfs, and that annual 

treatment prescriptions would be prepared for all new infestations that would identify wildlife species of 

local interest or their habitats, and modify treatment methods if necessary to reduce potential risks. 

Treatment risks are increased somewhat under this alternative, due to the increased use of 

manual/mechanical treatments, but collectively for these reasons the likelihood of mortality for any 

wildlife species is low and any disturbance would be short term. 

Effects of herbicide treatments would be similar to those discussed previously in the Treatment Effects 

Common to All Action Alternatives section. Like alternative B, none of the first year/first choice

herbicides resulted in an acute or chronic dose that exceeded the toxicity index for any wildlife species. 

While other herbicides could be used in subsequent years to achieve objectives, there are no adverse 

effects to wildlife from herbicide exposure anticipated with implementation of pdfs, Forest standards and 

treatment buffers, and considering annual treatment prescriptions would identify species/habitats of 

concern and modify treatment type and timing if necessary.

Like alternative B, cover would be retained on all treatment sites and there would be little change in 

wildlife habitat conditions in the short-term. However, requiring only non-herbicide treatments on much 

of the infested areas would reduce effectiveness compared to using herbicides in combination with nonherbicide treatments (see chapter 3.1.4), and overall treatment effectiveness would be reduced by almost 

half from that of alternative B. Therefore, while implementation of alternative C would help contain or 

control invasive plants, it would be less effective than alternatives B or D. 

Malheur National Forest Land and Resource Management Plan (LRMP) Amendment

The proposed LRMP amendment to add aminopyralid would likely improve the effectiveness of treatment 

(chapter 3.1.4). This would result in neutral or positive impacts to wildlife on the Malheur National 

Forest. 

Early Detection/Rapid Response

Like alternative B, alternative C would allow treatment of new detections (EDRR) as long as the 

treatment method is within the scope of this EIS. The treatment of newly found sites adds additional risk 

factors to wildlife just by adding additional exposure areas. This also expands the treatment into areas that 

may not have been originally anticipated. However, the implementation planning process identified in 

chapter 2 would be used with each new infestation site to determine treatment and reduce risks. The pdfs

provide layers of caution so that even if the exact locations are not known, the potential for adverse 

effects are minimized. Implementation of pdfs, buffers and treatment limits all work together to provide 

sideboards to deal with the uncertainty of treating new sites (USDA Forest Service 2008b) and ensure that 

direct and indirect effects are consistent as discussed in the alternative and species-specific analysis 

presented. Alternative C would be the least effective of the action alternatives at controlling future 

infestations due to the restrictions on treatment.

Effects on Alternative D 

Direct and Indirect Effects

Alternative D is similar to alternative B, except that aminopyralid would not be approved for use. As a 

result, use of chlorsulfuron (a lowest risk herbicide) would increase and some moderate risk (glyphosate) 

to higher risk (picloram) herbicides would be used as first year/first choice treatments. Use of herbicides 

other than aminopyralid would also require increased use of spot application within all habitats except 

sagebrush. Effects of treatment would be similar to those described previously in the Effects Common to

All Action Alternatives section. While more spot application would increase risks of direct effects from 

those of alternative B, when you consider 1 percent or less of any of the affected habitats would be treated 

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

(table 68), existing sites are small and scattered, and approximately 88 percent of the known sites occur 

along open roads, the likelihood of direct effects are low. Potential for effects are further reduced with

implementation of pdfs and considering annual treatment prescriptions would be prepared for all existing 

and new infestations that would modify treatment methods and timing if necessary to reduce potential 

risks. Treatment risks are increased somewhat under this alternative; however, like the other action 

alternatives, with implementation of pdfs, the likelihood of mortality for any wildlife species is low.

Use of moderate to higher risk herbicides would occur on approximately 788 acres or 37 percent of 

infested acres treated during the first year. However, no adverse effects to wildlife from herbicide 

exposure are anticipated because of implementation of pdfs; following Forest standards and treatment 

buffers; and development of annual treatment prescriptions that identify species/habitats of concern and 

modify treatment type and timing if necessary,.

Proposed treatments would reduce existing infestation of invasive plants across the project area and 

promote native wildlife habitat. Like alternatives B and C, reductions in cover would be small and 

scattered and there would be little change in the availability of wildlife habitat. Because aminopyralid is 

not approved under this alternative, treatment effectiveness of the sites would be approximately 66 

percent of the sites treated. Much of the reduction in effectiveness would occur along streamsides due to 

increased buffers if aminopyralid were not approved. While alternative D would be effective at reducing 

invasive plants, it would be less effective at promoting the long-term maintenance of native vegetation 

and wildlife habitat than alternative B.

Malheur National Forest Land and Resource Management Plan (LRMP) Amendment

No amendment is proposed for alternative D.

Early Detection/Rapid Response

Like alternative B, alternative D would allow treatment of new detections (EDRR), as long as the

treatment method is within the scope of this EIS. While treatment would add additional risks to wildlife, 

annual prescriptions would be developed and treatment timing/methods modified if necessary. Like the 

other action alternatives, project design features, annual prescriptions, and herbicide-use buffers all work 

together to provide sideboards to deal with the uncertainty of treating new sites (USDA Forest Service 

2008b) and ensure that direct and indirect effects are consistent with those anticipated. Alternative D 

would be less efficient in reducing invasive plants than alternative B.

Cumulative Effects of the Action Alternatives

Ongoing and future projects, including the relationship between land management and invasive plants are 

discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. Potential 

cumulative effects to wildlife are assessed for each of the action alternatives evaluated in the EIS, as well 

as for the individual species evaluated. Future projects can be reasonably predicted for about a decade for

potential cumulative effects evaluation. 

Past management activities on the Forest in combination with only manual/mechanical invasive plant 

treatments has resulted in an increase in invasive plant infestation across the Forest. Ongoing and future 

actions will continue to promote the spread of invasive plants. Activities on NFS lands that could further 

increase the spread of invasive plants and affect wildlife habitat include prescribed burning; timber 

harvest and reforestation treatments; fuel reduction; plantation thinning; road closures; maintenance and 

decommissioning; facility/recreation projects; and grazing. These activities will occur forestwide, are 

spread out over 60 6th field watersheds (HUC6), and would be implemented over the next 10 years. Other 

activities that may occur outside of these watersheds include mineral development and access/travel 

management. A complete list of future activities can be found in table 28. Treatments that do not result in 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

disturbance would result in little increase in the spread of invasive plants. Implementation of Forest 

standards that require re-seeding with native vegetation; use of weed free hay; and equipment cleaning 

provisions would reduce the likelihood invasive plants would spread due to recreation/facility 

construction activities. Consequently of the anticipated future activities, timber harvest, prescribed 

burning, recreation, mineral development, and grazing have the most potential to increase the spread of 

invasive plants.

While future management activities would comply with Forest standards designed to reduce the spread of 

invasive plants (e.g., equipment cleaning clauses and use of weed-free seed during re-vegetation), 

disturbance and increased levels of light would promote establishment of invasive plants on many of the 

lands affected by management. While it is not anticipated that grazing use would change, ongoing grazing 

would also continue to promote the spread of invasive plants, particularly in dry forest and shrub-steppe 

habitats. Continued grazing could also reduce wildlife cover and forage. On NFS lands, range 

administration adjustments, such as changes in livestock movement patterns, alterations of season of use, 

adherence to allowable use standards, and delayed re-introduction following wildfire would be used to 

reduce grazing impacts. Passive restoration may include keeping cattle away from treated areas until the 

area recovers with native vegetation; therefore, it is expected that wildlife cover and forage conditions 

would be maintained following treatment.

Disturbance associated with mining could also increase the spread of invasive plants, although per LRMP 

direction, special use permits are managed to prevent the spread of invasive plants. Recreational activity 

on NFS land is expected to increase and ongoing activities across all ownerships would continue to cause 

ground disturbances that can contribute to the introduction, spread, and establishment of invasive plants 

on NFS lands (USDA Forest Service 2005a). While access/travel management may result in disturbance 

associated with road restoration, any future development would include provisions to reduce the spread of 

invasive plants.

Under all action alternatives, some level of invasive plant control would occur on 2,124 acres and of this, 

1,067 acres occur within watersheds where some future management activity is anticipated. Watersheds 

that contain both invasive plant treatments and future management activities are displayed in table 69.

Table 68. Watersheds containing planned future activities and invasive plant treatments

Watershed Future Activity1 Invasive Plant Treatment Acres2

Birch Creek P 1

Bosenberg Creek G 4

Bridge Creek T,R,G 26

Crane Creek T,B, 12

Deardorff Creek T 11

Dry Cr. John Day River P <1

Elk Creek T,B 24

Emigrant Creek T,R 44

Granite Boulder Creek R,P 120

Long Creek P 1

Indian Creek P 1

Lake Creek G 3

Lick Creek G 8

Little Boulder Creek T,B,R 139

Long Creek P 18

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Watershed Future Activity1 Invasive Plant Treatment Acres2

Lower Bear Creek T,B 1

Lower Deer Creek T 1

Lower Scotty Creek T,B 3

Middle Bear Creek T,B 2

Middle Silvies River R 6

Mill Creek R 145

North Basin T,B,F,R 15

Pine Creek B,R, 79

Slide Creek P 6

Starr Creek T,F,B 16

Summit Creek T,B,G 15

Upper Big Creek G 5

Upper Camp Creek G 14

Upper Deer Creek P 1

Upper Fox Creek P 22

Upper Long Creek P 18

Upper Malheur River P 45

Upper South Fork John Day River T 46

Upper Silver Creek T,B,R 20

Upper Silvies River T,B,F,R,P 56

Van Aspen-Silvies River T,B 15

Vinegar Creek T,B,R 81

Wiley Creek P,B,R 2

Wolf Creek T 38

Total Invasive Plant Treatment 1,067

1 – Activity Codes (T)-Timber harvest, (B)-Burning, (F)-Fuel Reduction, (R)-Recreation/facility, (P)-Plantation thinning, (G)-Grazing

improvements.

2 – Invasive plant treatments that do not occur in watersheds with future treatments are not displayed.

Thirty-nine watersheds would receive invasive plant treatments, as well as future management. While all 

activities have the potential to increase invasive plants, the likelihood of spread is reduced by 

implementation of LRMP standards designed to reduce invasive plant infestation. Measures are included 

in all special use and grazing permits that help prevent the spread of invasive plants, and grazing use 

would be modified following treatment to ensure establishment of native vegetation. Finally as described 

in section 2.3.2, we would continue to monitor invasive plants and treatments according to National and 

Regional Forest Service policy to ensure treatment and pdf effectiveness. Therefore, potential impacts 

from invasive plants to wildlife and wildlife habitat would be reduced. 

All ongoing or future activities (identified in table 28) would increase human access and, therefore,

disturbance to wildlife, although effects vary by species. Approximately 88 percent of the treatments 

currently occur close to open roads, so there would be little increase in human access due to proposed 

activities. In addition, pdfs are in place that reduce or restrict access to sensitive wildlife habitat. 

Treatment would be limited to a few days a year at any site, and 1 percent or less of any watershed would 

be affected. Therefore, any disturbance associated with herbicide or non-herbicide treatments would be 

short term, and there are no long-term adverse effects associated with increased access. 

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All ongoing and future activities would alter wildlife habitat; however, timber harvest and associated 

reforestation treatments, prescribed burning, and plantation thinning would result in the greatest change in 

habitat. These activities would reduce the overstory canopy, create more open understory conditions 

within forested stands, or alter woody/herbaceous vegetation within non-forest. Effects to wildlife vary by 

species and are discussed in part in the individual species analysis presented in the following sections. 

Potential effects to wildlife are also determined by the amount of habitat affected, effects to species 

considered at risk or threatened, endangered, and sensitive species, and the availability of unaffected 

habitat. As shown in table 69, these activities would occur across 32 watersheds that also contain invasive 

plant treatments. When you consider 1) project pdfs are in place to protect at risk species from herbicide 

and non-herbicide treatments, 2) forest plan standards will reduce impacts from future management on 

many at risk wildlife species and sensitive wildlife habitats, 3) future management actions would maintain 

or improve wildlife habitat for fire dependent species, species that utilize open understories, and 

aspen/shrubland steppe dependent species, 4) proposed treatments would reduce the spread of invasive 

plants, and 5) one percent or less of any watershed would be affected by proposed activities, 

implementation of anticipated future activities combined with proposed activities for the action 

alternatives is not expected to reduce the availability of wildlife habitat or significantly affect wildlife.

In addition to proposed treatments, all action alternatives would allow treatment of new detections 

(EDRR), as long as the treatment method is within the scope of this EIS. The treatment of newly found 

sites adds additional risk factors to wildlife just by adding additional exposure areas. This also expands 

the treatment into areas that may not have been originally anticipated. The decision process identified in 

section 2.3.2 of the EIS would be used with each new infestation site to determine treatment. In addition, 

pdfs have been set up to provide layers of caution so that even if the exact locations are not known, the 

potential for adverse effects are minimized. Implementation of pdfs, buffers, and treatment limits (i.e.,

leaving stream corridors untreated) all work together to provide sideboards to deal with the uncertainty of 

treating new sites (USDA Forest Service 2008b).

Since wildlife move and migrate, some species could be exposed to herbicides on NFS lands, as well as 

adjacent lands that are within their home range or along travel corridors. Consequently, species could be

exposed to the same herbicide on multiple ownerships, or a combination of different herbicides. Wildlife

could also be exposed to other chemicals, such as insecticides, rodenticides, fungicides, and others. While 

potential for multiple herbicide exposures to wildlife exists, the risk that adverse effects would occur 

depends on a number of factors, such as wildlife feeding strategy, seasonal activity, and the types and 

amounts of herbicides used. The following considerations collectively reduce potential impacts from 

herbicide exposure on wildlife: 

• While total acres of herbicides proposed on lands of other ownerships are not available, counties are 

responsible for controlling noxious weeds along county roads and other county property outside of 

and within the Forest. They also work with conservation districts, weed management areas, and 

watershed councils to control noxious weeds on private property. So while additive herbicide 

exposures are possible if herbicide is used on neighboring lands during the same day as NFS land are 

treated, activities occurring on the Forest Service, other federal agencies, states, and counties would 

be coordinated, making treatment overlaps unlikely.

• The herbicides proposed for use do not significantly bio-accumulate (R6 2005 FEIS). For additive 

doses to occur, two exposures would have to occur at approximately the same time. At proposed 

application rates and with implementation of pdfs, it is unlikely that any species would receive 

additive doses beyond those evaluated for chronic and acute exposures in the USDA Forest Service 

risk assessments. 

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

• The likelihood that wildlife would receive a toxic level of herbicides are reduced because herbicides 

used are excreted within 48 hours and herbicide persistence is reduced through implementation of 

pdfs.

• While pdfs add a measure of protection for non-target wildlife on NFS lands, wildlife may be more 

vulnerable on lands of other ownerships where protective measures are unknown. However,

treatments are spread out over 100 HUC 6 watersheds, which vary in size between 10,000 and 38,000 

acres, and therefore 1 percent or less of all affected watersheds would be proposed for treatment. The 

widely scattered nature of proposed treatments, combined with the small size of infestations (over 80 

percent are less than one-quarter acre) and availability of unaffected habitat, reduce the likelihood that 

any wildlife species utilizing multiple ownerships would be exposed to toxic levels of herbicide from

proposed treatments.

• The management direction included in all action alternatives, as well as the environmental conditions 

and animal behavior, would tend to minimize actual impacts for EDRR. Prior to implementation,

treatments could be planned to avoid situations that may harm to wildlife. For example, certain 

herbicides could be avoided in specific areas or times of the year where/when species that utilize 

grass, such as amphibians may be at risk, or more specific application methods could be used. 

As a result, it is unlikely that proposed treatments would measurably contribute to any other activities on 

private land that would result in significant effects to wildlife.

Effects to Federally Listed Species

Effects determinations for federally listed species are shown in the following table.

Table 69. Findings and determinations for ESA-listed wildlife species in the project area

Species Action Alternative

Determination

Reason

Canada Lynx No Effect Lynx have not been documented on the Forest and suitable 

habitat would be unaffected by treatments.

North American 

Wolverine

No Effect Wolverine use of the project area is low and use would not occur 

within treatment sites.

Yellow-billed Cuckoo No Effect Yellow-billed cuckoo have not been documented on the Forest. 

Little riparian habitat is proposed for treatment and pdfs would 

protect breeding birds should they become established.

Canada Lynx

Direct, Indirect, and Cumulative Effects, and Determination

The Malheur National Forest is categorized as a “peripheral area” based on the Draft Lynx Recovery 

Outline (USDI FWS 2005a) and there is no documentation of lynx reproducing in the state of Oregon.

The Forest has not had a verified lynx observation since 1999; therefore, the Forest is considered 

“unoccupied” habitat (USDI FWS 2006a). Currently only eight acres of foraging and den habitat are 

proposed for treatment. Due to the small amount of suitable habitat affected and considering the project 

area is not considered occupied lynx habitat, there would be no direct, indirect, or cumulative effects and 

implementation of the action alternatives would have No Effect on lynx.

North American Wolverine

Direct, Indirect, and Cumulative Effects, and Determination

Wolverines occur in remote areas and have not been recently documented on the Forest. In addition, there 

is less than an acre of invasive plants proposed for treatment within potential den habitat. Wolverine

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

utilize higher elevations during the snow free period to avoid high temperatures and human activity 

(Ruggiero et al. 1999), thus direct effects to wolverine from proposed treatments are not anticipated.

Similarly, because they prefer closed-canopy forest habitat at upper elevations, wolverine habitat would 

not be adversely affected by invasive plants. As a result, there are no direct, indirect, or cumulative effects 

to this species anticipated, and implementation of alternatives B through D would have No Effect on the 

wolverine. 

Yellow-billed Cuckoo

Direct and Indirect Effects

Approximately 2,136 acres of riparian woodland habitat occurs on the Forest. Of this, 28 acres are 

proposed for treatment with herbicides, including 27 acres with broadcast application and 1 acre of spot 

application. Aminopyralid and chlorsulfuron are the proposed herbicides.

Treatment – Effects of manual and mechanical treatments are discussed above and potential effects 

include disturbance to nesting birds by people, equipment, or noise. Yellow-billed cuckoo nest in large 

riparian areas in shrubs or trees approximately 10 to 16 feet off the ground (Washington DFW 2012, 

Center for Biodiversity 1998). Because woody vegetation is not targeted for treatment, it is unlikely nests 

would be affected, although nesting birds could be disturbed or displaced during treatment. In order to 

reduce the likelihood that breeding birds, nests, or young are harmed, the following project design feature 

would be implemented. 

• J13-a - If a known breeding site is proposed for treatment, a biologist will be contacted to determine 

necessary protection measures. These measures may include limitations on vehicle entry, 

modifications to treatment type or timing, or applying buffers. Protection measures would be 

coordinated with the USFWS.

With implementation of this design feature, treatment within occupied habitat would be modified or 

deferred to protect nesting birds. Disturbance to migrating birds could occur, although effects would 

involve short-term (a few days) displacement and unaffected suitable habitat would continue to be 

available. 

Herbicides - Risk of effects from herbicide exposure was evaluated using the insectivorous bird scenario. 

Aminopyralid is the first year/first choice herbicide on all sites and no adverse effects from herbicide 

exposure are anticipated. 

Of the herbicides approved, triclopyr exceeded a dose of concern for an acute exposure at the typical and 

highest application rates whereas glyphosate exceeded the NOAEL at the highest application rate. Data 

was lacking to evaluate a chronic exposure of clopyralid, glyphosate, picloram, sethoxydim, sulfometuron 

methyl, and triclopyr on small birds consuming insects.

Triclopyr is restricted to spot techniques and pdf J2 restricts broadcast application of clopyralid, 

glyphosate, picloram, sethoxydim, and sulfometuron methyl to typical application rates whereas triclopyr 

is restricted to the typical application rate or less. With implementation of these design features, the 

likelihood of herbicide exposure is reduced. The cuckoo’s feeding strategy further reduces risk in that it 

forages over a large area (California PIF 1998); sites proposed for treatment are small and scattered.

Much of its foraging takes place on woody vegetation (Birds of North America 2013, California Partner 

In Flight 1998), which would not be targeted for treatment. As a result and considering the small amount 

of habitat proposed for treatment, it is unlikely that a bird would receive an acute (consume nothing but 

contaminated prey for an entire day) or chronic exposure (consume nothing but contaminated prey for 90 

days) of concern. Finally, with implementation of pdf J13-a, which protects known breeding sites, there 

are no adverse effects from herbicide exposure anticipated. 

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Cumulative Effects

Ongoing/future projects, including the relationship between land management and invasive weeds, are 

discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. While riparian 

habitat on NFS land would be maintained with implementation of LRMP direction and standards, there 

could be a reduction in suitable yellow-billed cuckoo habitat on other ownerships within the project area 

due to future development or changes in vegetation. This species prefers dense understory vegetation, so 

overgrazing could also reduce habitat. On NFS lands, range administration adjustments, such as changes 

in livestock movement patterns, alterations of season of use, adherence to allowable use standards, and 

delayed re-introduction following wildfire, would be used to reduce grazing impacts to riparian vegetation 

and suitable yellow-billed cuckoo habitat. 

Herbicides are commonly applied on lands of other ownerships for a variety of agricultural, landscaping,

and invasive plant management purposes and it is possible that birds could be exposed to the same 

herbicide on multiple ownerships, or a combination of different herbicides. While potential for multiple 

herbicide exposures exists, the risk that adverse effects would occur are reduced when you consider that 

1) coordinated efforts make treatment overlap unlikely, 2) proposed herbicides do not significantly bioaccumulate (R9 2005 FEIS), 3) proposed herbicides are excreted within 48 hours, and 4) the small 

amount of habitat proposed for treatment. As a result and considering pdfs would protect breeding birds 

from treatments, there are no adverse effects from herbicide exposure anticipated, and implementation of 

the proposed action would not measurably contribute to any other past, ongoing, or foreseeable future 

activity and result in adverse effects to the yellow-billed cuckoo.

Summary and Determination 

Yellow-billed cuckoos have not been documented within the project area, although suitable habitat exists. 

Based on the above analysis and the following rationale, a No Effect determination is made for the 

yellow-billed cuckoo.

♦ Breeding yellow-billed cuckoos have not been documented within the project area.

♦ Only one percent of the suitable project area habitat is proposed for treatment.

♦ Should breeding occur in the future, project design features would ensure that breeding birds are 

not adversely affected.

♦ Any disturbance to migrating birds would be short-term. 

♦ At proposed application rates and with implementation of pdfs, there are no adverse effects from 

herbicide exposure anticipated. 

♦ Proposed actions would reduce the spread of invasive plants into riparian vegetation and help to 

maintain native habitat.

Effects to Forest Service Sensitive Species

Table 70. Sensitive Species determinations and rationale

Species

Action 

Alternative 

Determination1 Rationale

Gray Wolf MIIH Unlikely to be present in treatment areas. Future den and rendezvous sites 

protected. See section above for details.

Pygmy Rabbit MIIH

Not documented within the project area and unlikely to be present in treatment 

areas. Pdfs minimize potential effects from herbicide exposure and treatment. 

Treatment would promote native habitat.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Species

Action 

Alternative 

Determination1 Rationale

Townsend’s Bigeared Bat No Impact

Not present during treatment. Due to foraging behavior and with 

implementation of pdfs, no adverse effects from herbicide exposure are 

anticipated.

Pallid Bat No Impact

Not present during treatment. Due to foraging behavior and with 

implementation of pdfs, no adverse effects from herbicide exposure are 

anticipated

Fringed Myotis No Impact

Not present during treatment. Due to foraging behavior and with 

implementation of pdfs, no adverse effects from herbicide exposure are 

anticipated

Bald Eagle No Impact

Few invasive plant acres near suitable nesting, foraging, or roost habitat. Pdfs

effectively reduce potential impacts to nesting or roosting birds. At proposed 

application rates and methods, no adverse effects from herbicide exposure 

are anticipated.

American 

Peregrine 

Falcon

No Impact

No known nests within the project area. Project design features effectively 

reduce potential impacts to nesting birds. At proposed application rates and 

methods, no adverse effects from herbicide exposure are anticipated.

Grasshopper 

Sparrow No Impact Not documented within the project area. Pdfs restrict activities within occupied habitat and make herbicide exposure unlikely. Suitable habitat maintained.

Wallowa Rosy 

Finch No Impact Not present in treatment areas. Suitable habitat not proposed for treatment.

Greater Sage 

Grouse

MIIH

Nesting not documented within the project area. Pdfs restrict activities to 

breeding birds and reduce the likelihood of disturbance or herbicide exposure. 

Suitable habitat maintained.

Bufflehead No Impact Not present in treatment areas. Pdfs make herbicide exposure highly unlikely. 

Suitable habitat maintained.

Upland 

Sandpiper MIIH

Nesting not recently documented on the Forest. Pdfs reduce treatment and 

herbicide exposure effects within occupied habitat. Suitable habitat 

maintained. 

Bobolink No Impact Not documented within the project area. Pdfs minimize potential for effects 

and make herbicide exposure highly unlikely. Suitable habitat maintained.

Lewis’ and 

White-headed 

Woodpeckers

MIIH

Nest habitat would not be affected. Foraging behavior and project design 

features make herbicide exposure unlikely. Low likelihood of disturbance. 

Columbia 

Spotted Frog

MIIH

Low likelihood of disturbance. Pdfs restrict treatment in suitable breeding 

habitat and make herbicide exposure unlikely. Suitable breeding habitat 

maintained.

Shortface Lanx No Impact Not present in treatment areas.

Johnson’s 

Hairstreak No Impact Not present in treatment areas.

Silver-bordered 

Fritillary MIIH

Occurrence within the project area is unlikely. Pdfs restrict treatment within 

occupied habitat and make herbicide exposure unlikely. Suitable habitat 

maintained. 

Haney Basin 

Duskysnail MIIH Not present in treatment areas. Pdfs protect future sites and make herbicide exposure highly unlikely. 

Columbia 

Clubtail No Impact Not documented in the project area. Pdfs restrict treatment within breeding habitat and herbicide exposure highly unlikely.

1 – MIIH – may impact individuals or habitat (MIIH), but will not likely contribute to a trend towards federal listing or cause a loss of 

viability to the population or species

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Gray Wolf

Direct and Indirect Effects

Treatment - No known denning or rendezvous sites exist on or near the Malheur National Forest. While 

no packs have become established, transient individuals may occasionally travel through looking for new 

territory or mates, and there is potential for wolves to become established on the project area in the future. 

Direct effects from invasive plant treatments include disturbance caused by noise, people, and vehicles. 

However, invasive plant projects involve very short-term disturbance with few people and often only a 

few visits in the same growing season. Although wolves will travel over large distances, they are most 

likely to occur in wilderness and roadless areas, away from human disturbance. These areas tend to have 

minimal invasive plant infestations, so the likelihood of disturbance is low. Additionally, project design 

features are in place that prevent invasive plant treatments occurring in close proximity to den or 

rendezvous sites. As a result, it is unlikely individual animals would be affected by treatment and if 

disturbance were to occur, it would be limited to short-term avoidance by foraging or transient 

individuals. 

While proposed treatments would help maintain habitat for elk, deer, or other prey species, there would be 

little change in gray wolf habitat. 

Herbicides - None of the proposed herbicides would result in an acute exposure that exceeds the toxicity 

index; however, chronic exposures to carnivores could occur at the typical and highest application rate 

with triclopyr or at the highest application rate for picloram. A Malheur National Forest LRMP standard 

limits triclopyr to selective applications (no broadcast) whereas pdf F2 restricts application of picloram 

and triclopyr to typical application rates (or less for triclopyr). Few treatments are proposed within 

preferred wolf habitat. Wolves forage over large areas and would not forage exclusively on contaminated 

prey; there are no adverse effects from herbicide exposure anticipated under any alternative. 

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. Anticipated 

activities could result in disturbance to wolves, although with implementation of pdf J1-a, any future den 

and rendezvous sites would be protected. Therefore, while future treatments could result in disturbance to 

foraging or transient individuals, effects would be short term and limited to a few days at any site. Also 88 

percent of the proposed activities occur close to open roads, which would be avoided by wolves. Finally,

many of the future management actions (e.g., harvest and prescribed burning) would be expected to 

maintain or improve big game habitat through aspen restoration and increases in forage on both summer 

and winter range. As a result and considering adverse effects from herbicide exposure are not anticipated, 

none of the alternatives would measurably contribute to any other past, ongoing, or foreseeable future 

activity and result in significant effects to the wolf.

Summary and Determination 

To date gray wolves have not been confirmed on the Malheur National Forest, although use is likely and 

it is possible that short-term disturbance could occur from proposed treatments. As a result, the project 

May Impact, may impact individuals or habitat, but will not likely contribute to a trend towards federal 

listing or cause a loss of viability to the population or species. 

♦ Project design features would prevent disturbance to any den or rendezvous sites established on 

the Forest.

♦ At proposed application rates and with implementation of pdfs, there are no adverse effects from 

herbicide exposure anticipated. 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

♦ Invasive plants and invasive plant treatments are less likely to occur in preferred remote habitat. 

♦ Any disturbance from invasive plant treatment would be short-term in nature. 

♦ Treatment would help maintain native plant communities and preferred big game habitat.

Pygmy Rabbit

Direct and Indirect Effects

Treatment - Pygmy rabbits are not known to occur on the project area. Should rabbits occupy the forest in 

the future, all proposed treatments have the potential to result in disturbance during implementation. 

Because less mobile young would be in burrows underground, there is no direct mortality anticipated. 

Implementing pdf J-6c and coordinating the timing, location, and method of treatment with a biologist in 

suspected use areas would limit any direct effects to short-term disturbance during treatment. 

Loss of habitat for the pygmy rabbit could occur with expansion of invasive plants on rangelands (Weiss 

and Verts 1984); therefore, proposed invasive plant treatments would result in a beneficial effect to 

pygmy rabbit habitat by reducing the future spread of invasive plants and a possible loss of habitat. 

Herbicides - Exposures of concern could occur at the typical and highest application rates for picloram 

and triclopyr and the highest application rate for glyphosate. The likelihood of exposure is reduced with 

implementation of the LRMP standard that restricts use of triclopyr to selective techniques, with pdf F2 

that restricts glyphosate to typical application rates, and with implementation of pdfs that restrict use of 

picloram to certain soil types (H3) and restrict use to a single application on any area within two calendar 

years (H4). Finally, within occupied habitat, treatment type and timing would be modified and activities 

would be restricted to manual techniques (J7-a). As a result, there are no adverse effects from herbicide 

exposure anticipated. 

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. Because of 

the small size of their home range (Heady and Laundre 2005), it is unlikely pygmy rabbits would be 

affected by herbicide treatment on lands of other ownerships as well as NFS lands. Most of the treatments 

identified in table 28 occur in forested stands or on unsuitable pygmy rabbit habitat, although continued 

grazing and allotment improvements could affect this species. As described under alternative effects, 

allotments are managed to prevent invasive plant introduction and to promote restoration of native 

vegetation by deferring livestock following treatment if necessary. As a result and considering that 

proposed activities would maintain suitable habitat, none of the alternatives would measurably contribute 

to any other past, ongoing, or foreseeable future activity and result in significant effects to the pygmy 

rabbit.

Summary and Determination

The pygmy rabbit has not been documented on the forest. While short-term effects from treatment are 

possible should they become established in the future, based on the above analysis and the following 

rationale, implementation may impact individuals or habitat (MIIH), but will not likely contribute to a 

trend towards federal listing or cause a loss of viability to the population or species.

♦ First-year treatment would affect 10 acres of suitable habitat.

♦ Pygmy rabbits have not been documented on the project area. Should use on the forest occur in 

the future, project design features would modify treatment if necessary to reduce potential 

impacts. 

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

♦ Proposed treatments would contain or control invasive weed infestations and help to maintain 

native sagebrush habitat over the long-term. 

Townsend’s Big-eared Bat, Pallid Bat and Fringed Myotis

Direct and Indirect Effects

Treatment - Since bats roost either in structures or in snag crevices during the day and forage at a time 

when treatment would not occur, the likelihood that a bat would be affected by treatment is remote, even 

though suitable habitat exists. 

Herbicides - Acute exposures of concern to insectivorous mammals could occur with use of picloram or 

glyphosate at the highest application rate. Neither herbicide would be broadcast sprayed above the typical 

application rate, so no adverse acute exposure would occur. Chronic exposures from these herbicides 

could occur at the typical and highest application rate, although effects are greatly reduced when you 

consider 1) neither is a first choice herbicide under alternatives B and C, 2) under alternative D, picloram 

would only be broadcast sprayed as a first choice herbicide on 36 acres, 3) triclopyr is restricted to 

selective techniques, and 4) pdfs F2, H3 and H4 all restrict use of picloram. As a result and considering 

bat foraging behavior (i.e., forage over large areas in a single evening) that essentially eliminates the 

possibility that bats would consume nothing but contaminated prey for 30 days, there are no adverse 

effects from herbicide exposure anticipated.

Cumulative Effects

Anticipated cumulative effects are discussed by alternative above and include increased exposure to 

herbicides on lands of other ownership, and reduction of suitable foraging habitat due to future timber 

harvest. Less than 1 percent of the watersheds where future treatments would occur are proposed for 

management. Proposed activities would not modify suitable bat habitat and unaffected habitat would be 

available within all affected watersheds. As a result, and considering that bats forage over large areas and 

would not be exposed to toxic levels of herbicides, none of the alternatives would measurably contribute 

to any past, ongoing, or foreseeable future activity and result in significant effects to the pallid bat, 

fringed myotis, or Townsend’s big-eared bat.

Summary and Determination

All alternatives would treat invasive plants in suitable bat habitat. However, roosting bats would be 

unaffected, and it is unlikely foraging bats would occur in treatment sites or be adversely affected by 

herbicides. As a result, implementation of the action alternatives would have No Impact on the pallid bat, 

fringed myotis, or Townsend’s big-eared bat. 

Bald Eagle

Direct and Indirect Effects

Treatment - Bald eagles are sensitive to human disturbance during the breeding season, particularly 

within sight distance of nest sites. Consequently human and vehicle presence can cause the birds to leave 

nests or stay away from the nest long enough to have detrimental effects to eggs or young (USDI FWS 

1986). Mechanical methods are more likely to cause effects at greater distances than other treatment 

methods, because machinery creates louder noise than other methods. 

While there are 3 acres of invasive plants treatment proposed within winter roost habitat and 9 acres fall 

within one-half mile of an eagle’s nest, implementation of the following pdfs would reduce or eliminate 

noise and disturbance to nesting, roosting, and foraging eagles.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

♦ pdf J2-a – Activities above ambient levels would not occur between October 31st and March 31st

during early morning or late afternoon near known winter roosts and concentrated foraging areas. 

Distance to daytime foraging areas would also be avoided. 

♦ pdf J2-b – Invasive plant treatments would not occur within 0.25 mile, or 0.50 mile line-of-sight,

during the nesting/fledging season (January 1st through August 31st).

With implementation of these pdfs there are no direct impacts to eagle nests or reproduction anticipated. 

While disturbance to roosting or foraging eagles is possible, given the small amount of land along 

waterbodies proposed for treatment (67 acres), the likelihood of disturbance is remote.

Herbicides - The results of exposure scenarios indicate that no herbicide or surfactant proposed poses a 

plausible risk to birds from eating contaminated fish. All expected doses for all herbicides to fish-eating 

birds are well below any known no-observable-adverse-effect-level (NOAEL) (see Appendix P of the R6 

2005 FEIS). Herbicide would not reach the upper canopies of mature trees where bald eagles nest, and 

with implementation of pdf J2-a, eagles would not be directly sprayed or encounter vegetation that has 

been sprayed. As a result, there are no adverse effects from herbicide exposure anticipated. 

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. Anticipated 

cumulative effects include possible herbicide exposure on multiple land ownerships, disturbance from 

proposed future activities, or modification of nest habitat due to proposed timber harvest. All future 

activities would comply with bald eagle and golden eagle management guidelines (USDI Fish and 

Wildlife Service 2007b) and no impacts to nesting birds or reproduction are anticipated. While it is 

possible that eagles could be exposed to herbicides on lands of other ownerships, even if a bird fed for a 

lifetime upon fresh water fish that had been contaminated by an accidental spill of herbicide, they would 

not receive a dose that exceeded any known NOAEL. As a result, and considering that that the risk of 

adverse effects from proposed treatment have been effectively eliminated through implementation of pdfs

J2-a and J2-b, no alternative would measurably contribute to any other past, ongoing, or future activity 

and result in significant effects to the bald eagle.

Summary and Determination

Invasive plant treatments are proposed in 3 acres of eagle winter roost habitat and on 9 acres within onehalf mile of known nests. Based on the above analysis and the following rationale, implementation of the

action alternatives will have No Impact to bald eagles:

♦ Implementation of project design features would effectively eliminate the likelihood that nesting 

or winter roosting eagles would be affected by disturbance associated with invasive plant 

treatment. 

♦ Invasive plant treatments would not result in the removal of bald eagle nests or roost trees, or 

affect foraging habitat.

♦ With implementation of pdfs, there are no adverse effects to eagles from herbicide exposure 

anticipated. 

♦ Projects conducted that are more than a 0.25 mile from a nest, or 0.5 mile line of sight distance 

from a nest, and do not result in the modification of eagle habitat, or result in noise above ambient 

levels, should have no effect on bald eagles (FWS 2003a).

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American Peregrine Falcon

Direct and Indirect Effects

Treatment - While suitable habitat exists, there are no known peregrine falcon nests on the Malheur 

National Forest. Because peregrine falcons nest on cliffs away from any known invasive plants, future 

nests would not be impacted by any of the proposed treatments. The following pdfs were designed to 

reduce the possibility that nesting birds or their young would be affected by proposed activities:

♦ J3-a – Seasonal restrictions, which are based on elevation and proximity to the nest, will be 

applied near known nest sites and will be implemented until at least 2 weeks after all young have 

fledged.

♦ J3-b – All invasive plant treatments would be restricted within 0.5 miles of peregrine falcon nest 

during the nesting season (based on J3-a).

♦ J3-c – Invasive plant treatments involving motorized equipment or vehicles would be seasonally 

prohibited between 0.5 miles and 1.5 miles of known nests during the nesting season (based on 

J3-a).

♦ J3-d – Non-mechanized or low-disturbance invasive plant treatment activities may occur between 

0.5-1.5 miles of known nests during the nesting season, but would be coordinated with a wildlife 

biologist to identify mitigation measures, if necessary.

♦ J3-e – Picloram and clopyralid would not be used within 1.5 miles of a peregrine nest more than 

once per year.

With implementation of the above pdfs, there are no effects to nesting birds or their young from proposed 

treatments anticipated. Also, due to the small amount of habitat proposed for treatment and widespread 

availability of unaffected habitat, the likelihood that foraging birds would be affected is remote. 

Herbicides - There is no quantitative scenario for a predatory bird that eats primarily other birds, such as 

the peregrine falcon, so the “fish eating bird” and “mammal eating bird” were used as surrogate scenarios. 

The fish eating bird scenario likely overestimates the dose to the peregrine falcon because the 

hypothetical fish consumed are from a pond contaminated by a large spill of herbicide. These hypothetical 

fish likely have higher concentrations of herbicide in their bodies (and thus a higher dose to the predatory 

bird) than would a small bird that incidentally ingested herbicide before it was preyed upon. Also, the 

small mammal in the “mammal-eating bird scenario” is directly sprayed.

It would be practically impossible to directly spray a bird that a peregrine falcon would then immediately 

prey upon. Except for triclopyr (small mammal scenario), which cannot be broadcast sprayed, no 

herbicide dose exceeded the toxicity indices for fish-eating or mammal-eating birds even at highest 

application rates. As a result, no adverse effects from herbicide exposure are anticipated.

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. It is not 

expected that future treatments would adversely affect nest sites, although disturbance to foraging birds 

could occur. With implementation of pdfs (J3-a through J3-e) proposed treatments would not adversely 

affect nesting birds, although as described above, effects include possible herbicide exposure on lands of 

other ownerships. Also, hexachlorobenzene (HCB), the contaminant in picloram and to a lesser extent 

clopyralid, does bio-accumulate in animal tissue; however, it is present in very small amounts (picloram, 

8 parts per million and clopyralid, less than 2.5 parts per million). The risk of bio-accumulation of HCB 

from picloram and clopyralid use is, therefore, very low. The R6 2005 FEIS states that HCB is a 

ubiquitous and persistent chemical in the environment and the amount released from Forest Service use 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

would be inconsequential in comparison to existing background levels and annual releases from 

manufacturing. However, use of picloram and clopyralid in remote locations could constitute the primary 

source of HCB in those areas. Monitoring of peregrine falcons in the Pacific Northwest has revealed HCB 

in their blood samples, and peregrine populations in the Pacific Northwest appear to continue to be 

affected by contaminants, although not HCB specifically. Eggshell thinning induced by DDE, the 

metabolite of DDT, affect populations in the Pacific Northwest and elsewhere, and residual levels of DDE 

continue to be detected in some peregrines (Henny et al. 1996). Reproductive failure at peregrine nests 

has also occurred in Oregon due to eggshell thinning (Peterson 2006). However, with implementation of 

pdf J3-e, the use of picloram and clopyralid within secondary nest zones would be restricted whereas pdfs 

H3 and H4 restrict the use of picloram. Broadcast application would be restricted to the typical 

application rate, and implementing pdfs to protect the nest sites makes the likelihood for HCB 

contamination remote and discountable. 

None of the herbicides proposed would result in a level of concern and no alternative would measurably 

contribute to any other past, ongoing, or future activity and result in significant effects to the peregrine 

falcon. 

Summary and Determination

There are currently no known nest sites on the Forest. Should a nest become established in the future, 

implementation of project design features would ensure that nesting peregrine falcons would not be 

adversely affected by treatments or be exposed to toxic levels of herbicide. Implementation of the action 

alternatives would have No Impact to peregrine falcons.

Grasshopper Sparrow

Direct and Indirect Effects

Treatment - Grasshopper sparrows are not known to occur within the project area. Should they become 

established in the future, pdf J9-a restricts treatment within occupied habitat and there are no impacts to 

nesting birds or young anticipated. It is unlikely that foraging or migrating birds would be affected

because of the small amount of habitat proposed for treatment (71 acres).

Invasive plants can adversely affect habitat for some grassland birds, such as the grasshopper sparrow 

(Scheiman et al. 2003). Treatments under the action alternatives would help to contain or control existing 

as well as future infestations and maintain native grassland habitat. 

Herbicides - Risk of effects from herbicide exposure was evaluated using the insectivorous bird scenario.

For an acute exposure at typical and highest application rates, triclopyr exceeded a dose of concern 

whereas glyphosate exceeded the NOAEL at the highest application rate. Data was lacking to evaluate a 

chronic exposure of clopyralid, glyphosate, picloram, sethoxydim, sulfometuron methyl, and triclopyr on 

small birds consuming insects. The likelihood of exposure is reduced with implementation of the Malheur 

National Forest LRMP standard that restricts use of triclopyr to spot techniques only; pdf F2 that restricts 

broadcast application of clopyralid, glyphosate, picloram, sethoxydim, sulfometuron methyl, and triclopyr 

to typical application rates; and pdfs H3 and H4 that restrict the frequency and use of picloram. With 

implementation of these design features and considering the small size and scattered nature of proposed 

treatments sites (scattered across 40 watersheds), it is highly unlikely that a bird would receive an acute or 

chronic exposure. As a result, there are no adverse effects from herbicide exposure anticipated under any 

alternative.

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. With the 

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exception of continued grazing and water development, few ongoing and future management activities 

would occur within suitable grasshopper sparrow habitat. As described under the alternative effects, 

grazing use is not expected to change, grazing will be deferred following invasive weed treatments until 

native vegetation is established, and continued grazing is not expected to reduce grassland habitat. While 

individuals could be exposed to herbicides applied on lands of other ownerships, due to the small and 

scattered nature of treatment sites and small amount of habitat proposed for treatment, it is unlikely a bird 

would receive multiple exposures. As a result, and considering treatment would not occur within occupied 

habitat during the nesting season, none of the alternatives would measurably contribute to any other past, 

ongoing, or future activity and result in significant effects to the grasshopper sparrow.

Summary and Determination

Proposed treatment would contain and control existing and future infestations of invasive plants and help 

maintain native grassland communities and suitable grasshopper sparrow habitat over the long term. 

While suitable grasshopper sparrow habitat is proposed for treatment, nesting has not been documented 

on the forest. Project design features are in place that restricts treatment if habitat becomes occupied;

therefore, implementation of the action alternatives would have No Impact on the grasshopper sparrow. 

Wallowa Rosy Finch

Direct, Indirect, and Cumulative Effects

The Wallowa rosy finch occupies upper elevation sites away from primary invasive weed vectors. As a 

result, there are no treatments proposed within suitable habitat, and it is unlikely they would be affected 

by future treatments. As a result, there are no direct, indirect, or cumulative effects from treatment 

anticipated under any alternative.

Summary and Determination

The Wallowa rosy finch has not been documented on the Forest, and it is unlikely that high elevation 

habitat would be affected by invasive plants or treatment. As a result, implementation of the action 

alternatives would have No Impact to this species. 

Greater Sage Grouse

Direct and Indirect Effects

Treatment - While there are no known leks or brood rearing habitats on the Forest, sage grouse are known 

to use the project area. Documentation of use is incidental and scattered. About 79 acres of mapped 

infestations are within the 139,500 acres of suitable habitat for sage grouse within the project area. 

Sage grouse are sensitive to disturbance caused by noise, people, and vehicles. All treatment methods 

could cause some disturbance to sage grouse. Should a lek be discovered, the following project design 

features would reduce adverse impacts to nesting birds. 

♦ pdf J4-a - Glyphosate use would be limited to the typical application rate (within greater sage 

grouse habitat).

♦ pdf J4-b - Human activities within 0.3 mile of leks will be prohibited from the period of one hour 

before sunrise until four hours after sunrise and one hour before sunset until one hour after sunset 

from February 15-May 15.

♦ pdf J4-c - Do not conduct any vegetation treatments or improvement projects in breeding habitats 

from February 15-June 30.

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With implementation of these pdfs and considering the marginal nature of sage grouse breeding habitat on 

NFS lands, no effects to breeding birds or reproduction is expected. 

Disturbance to foraging birds could occur. However due to the small size and widely scattered nature of 

treatment sites, and widespread availability of adjacent unaffected habitat, disturbance effects would be 

minimal and short-term (one day). Sage grouse would likely avoid of the site during treatment. 

Loss of habitat for sage grouse by invasive plant expansion on rangelands can occur (Connelly et al. 

2000). Because all alternatives would contain or control existing and future invasive plant infestations, 

native sagebrush communities and suitable sage grouse habitat would be maintained. 

Herbicides - Adult sage grouse consume vegetation, and chicks rely heavily on insects; thus, herbicide 

exposure was evaluated using a large vegetation-eating bird as well as a small bird consuming insects. 

For adult birds and chicks at typical application rates, only triclopyr (if broadcast sprayed) exceeded the 

acute toxicity thresholds whereas glyphosate exceeded a dose of concern at the highest rate for small birds 

consuming insects. A Malheur National Forest LRMP standard restricts application to triclopyr to 

selective techniques or spot treatment whereas pdf F2 limits glyphosate broadcast and all use of triclopyr 

to typical rates or less per acre. As a result, it is unlikely adult birds or chicks would receive an acute 

exposure of concern. 

Chronic exposures were also evaluated at the typical application rate for large birds consuming 

vegetation. Triclopyr exceeded a dose of concern whereas sethoxydim, sulfometuron methyl, and 

glyphosate exceeded the toxicity threshold at the highest application rate. Data is lacking to evaluate a 

chronic exposure of clopyralid, glyphosate, picloram, sethoxydim, sulfometuron methyl, and triclopyr on 

small birds consuming insects. While exposure from these herbicides are possible, when you consider that

1) pdf F2 restricts broadcast application of clopyralid, glyphosate, picloram, sethoxydim and 

sulfometuron methyl to typical application rates (and all use of triclopyr to typical rates) per acre, 2) 

triclopyr is restricted to spot techniques, 3) Only 79 acres of invasive plant treatment are proposed in 

suitable habitat and sites are small and scattered across 20 watersheds, and 4) the use of the project area 

by sage grouse is scattered and incidental, it is unlikely that birds would consume all of their diet from 

contaminated insects/vegetation for 90 days and receive a chronic dose of concern. As a result, there are 

no adverse effects from herbicide exposure anticipated under any alternative. 

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive plants are 

discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. Other than 

continued grazing and water development, there are few future management activities anticipated within 

suitable sage grouse habitat. On NFS lands, range administration adjustments, such as changes in 

livestock movement patterns, alterations of season of use, adherence to allowable use standards, and 

delayed re-introduction following wildfire, would be used to reduce grazing impacts. Passive restoration 

may include keeping cattle away from treated areas until the area recovers with native vegetation. As a 

result, it is expected that grassland habitat would be maintained following treatment.

Suitable habitat occurs on NFS lands, as well as adjacent private and BLM lands, so potential cumulative 

effects include possible herbicide exposure or disturbance on all ownerships. Due to the small amount of 

habitat proposed for treatment, treatment restrictions within breeding habitat, and reduced risk of 

herbicide exposure, none of the alternatives would measurably contribute to any past, ongoing, or future 

activity and result in significant effects to sage grouse.

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Summary and Determination

While no sage grouse leks have been documented in the project area, sage grouse use has been 

documented, and birds could be affected by treatment. Based on the above analysis and following 

rationale, implementation of the action alternatives may impact individuals or habitat (MIIH), but will not 

likely contribute to a trend towards federal listing or cause a loss of viability to the population or species.

♦ There are no sage grouse leks known to occur on the Forest and National Forest System lands do 

not provide quality nesting habitat similar to that on adjacent lands. Should a lek be established in 

the future, pdfs would restrict treatment during the nesting season.

♦ Sage grouse would not be exposed to toxic levels of herbicides.

♦ Disturbance-related effects to grouse will be short term and unaffected habitat is available. 

♦ Proposed treatment would contain and control existing and future infestations of invasive plants 

and help maintain native sagebrush habitat.

Bufflehead

Direct and Indirect Effects

Treatment - Bufflehead nest in tree cavities and rarely breeds in Oregon. Considering the small amount of 

habitat proposed for first-year treatments, there are no direct effects from treatment anticipated.

Herbicides - These ducks eat aquatic invertebrates and fish, so risk from herbicide exposure was 

evaluated using a “fish-eating bird” scenario. Based on available data, no herbicide exceeded a dose of 

concern for any exposure (acute or chronic) at any application rate. As a result, no adverse effects from 

herbicide exposure are anticipated under any alternative.

Cumulative Effects

There are no direct or indirect effects associated with treatment; therefore, none of the alternatives would 

measurably contribute to any other past, ongoing, or future activity and result in significant effects to 

bufflehead. 

Summary and Determination

Buffleheads have not been documented breeding within the project area and are unlikely to occur within 

treatment sites. As a result, and considering that none of the herbicides exceeded a dose of concern, 

implementation of the action alternatives would have No Impact to the Bufflehead. 

Upland Sandpiper

Direct and Indirect Effects

Treatment - Approximately 79,000 acres of potentially suitable upland sandpiper habitat occurs on the 

Malheur National Forest and of this, 72 acres are currently known to contain invasive plants. Broadcast

application would occur on 50 percent and 25 percent of the sites under alternatives B and D respectively 

whereas manual/mechanical treatments would occur on 68 percent of the sites under alternative C. 

Potential effects of invasive plant treatment on upland sandpipers are mainly associated with disturbance 

that may occur during the nesting season caused by noise, people, and vehicles. If birds were to be in the 

immediate vicinity of treatment, they could be temporarily displaced. In addition, the cryptic nests of 

upland sandpipers are susceptible to crushing or trampling by people or vehicles. In order to reduce the 

likelihood that nests, eggs, or young are harmed, the following design feature would be implemented:

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♦ pdf J8-a - No treatment would occur on sites that have historic or recent documentation of upland 

sandpipers during the nesting season (April 1st to August 1st), unless the site has been surveyed 

and no nesting is occurring.

Upland sandpiper would not receive a toxic dose of herbicide under any alternative. While all action 

alternatives would reduce invasive weeds, alternative B would provide the most effective control of 

invasive plants (see chapter 3.1.4).

With implementation of the above pdf, there are no impacts to nesting birds or their young anticipated. 

However, short-term disturbance to foraging birds outside the nesting season is possible. 

Herbicides - Effects of herbicides are the same as those described under grasshopper sparrow, and there 

are no adverse effects anticipated under any alternative 

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. With the 

exception of continued grazing and water development, few future management activities would occur 

within suitable upland sandpiper habitat. As described under the alternative effects, grazing use is not 

expected to change, grazing will be deferred following invasive weed treatments until native vegetation is 

established, and continued grazing is not expected to reduce wildlife cover and forage or upland sandpiper 

habitat. While they could be exposed to herbicides applied on lands of other ownerships, due to the small 

and scattered nature of treatment sites and small amount of habitat proposed for treatment, it is unlikely a 

bird would receive multiple exposures. As a result, and considering treatment would not occur within 

occupied nest habitat, none of the alternatives would measurably contribute to any past, ongoing, or future 

activity and result in significant effects to the upland sandpiper.

Summary and Determination

Upland sandpipers have not been documented breeding on the Forest, but use on adjacent private lands 

does occur and use of suitable habitat on the Forest is possible. Based on the above analysis and the 

following rationale, implementation of the action alternatives may impact individuals or habitat (MIIH), 

but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population 

or species.

♦ Breeding upland sandpipers have not been documented on the Forest.

♦ Should a nest be documented, project design features are in place that restricts treatment during 

the breeding season. 

♦ Given the type of herbicides proposed and with implementation of pdfs, none of the alternatives 

are expected to result in adverse effects from herbicide exposure. 

♦ Proposed treatment would contain and control existing and future infestations of invasive plants 

and help maintain native grassland habitat required by upland sandpipers.

Lewis and White-headed Woodpeckers 

Direct and Indirect Effects

Treatment - Approximately 275 acres of Lewis’s woodpecker and 10 acres of white-headed woodpecker 

habitat are proposed for treatment. No snags or trees would be removed, so nest habitat would be 

unaffected. Foraging birds, particularly the Lewis woodpecker, which frequently forages on the ground,

could be affected by the noise and disturbance associated with herbicide or non-herbicide treatments 

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under all alternatives. Both species forage over large areas and considering the availability of unaffected 

habitat, direct effects would be limited to short-term disturbance at the treatment site. 

Herbicides - At typical application rates, triclopyr could pose an acute risk to birds that eat insects. 

Glyphosate poses an acute risk at the highest application rate whereas data is lacking to fully assess 

chronic exposures of clopyralid, glyphosate, picloram, sethoxydim, sulfometuron methyl, and triclopyr on 

small birds consuming insects. Broadcast application of triclopyr is restricted to spot techniques whereas 

pdf F2 limits broadcast clopyralid, glyphosate, picloram, sethoxydim and sulfometuron methyl, and all 

use of triclopyr to typical application rates or less. As a result, the likelihood that a bird would be exposed 

to toxic levels of herbicide is reduced. 

The likelihood of exposure is further reduced when you consider that birds forage over large areas and 

that many of the insects utilized occur within dead wood, under bark, or are taken from areas not exposed 

to herbicides. As a result, birds are not likely to consume an entire day’s diet of contaminated insects 

(acute exposure) or forage exclusively on contaminated insects for 90 days (chronic exposure) and there 

are no adverse effects from herbicide exposure anticipated under any alternative. 

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. These 

species could be affected by any activity that reduces snags or downed wood or modifies the overstory, 

particularly timber harvest and prescribed burning. As discussed previously, timber harvest and invasive 

plant treatments would occur within 39 watersheds, which include approximately 1,100 acres of 

treatment. Timber harvest would reduce habitat for some species due to reductions in the overstory. With 

implementation of Forest standards, a component of snags and downed wood would be retained on all 

sites. Proposed treatments would not reduce suitable habitat. As a result, and considering the low risk of 

herbicide exposure, none of the alternatives would measurably contribute to any other past, current, or 

foreseeable activity and there are no significant cumulative effects to snag- or downed-wood-dependent 

species anticipated.

Summary and Determination

Lewis Woodpecker and White-headed Woodpecker - Approximately 275 and 10 acres of Lewis and 

white-headed woodpecker habitats are proposed for first-year treatment. No direct effects to nesting birds 

or reproduction are anticipated and suitable habitat would be unchanged. Since treatment could cause

short-term disturbance to foraging, implementation of the action alternatives may impact individuals or 

habitat (MIIH), but will not likely contribute to a trend towards federal listing or cause a loss of viability 

to the population or species.

Columbia Spotted Frog

Direct and Indirect Effects

Treatment – Invasive plants have been mapped within 52 acres of suitable breeding habitat of the 

Columbia spotted frog. Broadcast application of herbicides is proposed on 23 and 4 acres under 

alternatives B and D respectively whereas 48 acres of manual treatment would occur under alternative C.

Adult frogs, eggs, and larvae are not likely to be disturbed by invasive plant treatments during the 

breeding season because they are restricted to aquatic habitat. After breeding, however, adults will 

disperse into adjacent wetland and riparian/upland habitats utilized by frogs. While trampling and direct 

mortality could occur under all alternatives, with implementation of pdf J5-a, treatment methods, timing 

and location would be coordinated with a biologist prior to implementation when working in occupied 

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habitat. As a result, and considering that frogs are less likely to inhabit areas infested with invasive plants, 

the likelihood of mortality or short-term disturbance is low. 

Herbicides - Data on herbicide effects to amphibians is limited. There is some data to suggest that 

amphibians may be as sensitive to herbicides as fish (Berrill et al. 1994, Berrill et al. 1997, Perkins et al.

2000). Consequently, herbicides that pose potential risk to federally listed fish (as determined by the 

quantitative estimates from exposure scenarios) will also be considered to pose a risk to amphibians. 

The likelihood of amphibian exposure to herbicides depends on the application method, habitat treated, 

and season of application. Although potential for exposure exist, adverse effects to amphibians are further 

reduced by implementation of pdfs that restrict herbicide application rates, restrict use of moderate to high 

risk herbicides, and require herbicide-use buffers. More specifically 1) project design features (F1, F2, 

H1, H2, H5, and H8-H10) reduce the likelihood for herbicide delivery to waterways in a concentration of 

concern, 2) herbicide restrictions on certain soil types (H3 and H6) reduce potential for runoff and 

leaching, 3) restrictions on extent of treatment in a given site (H4, H5 and H7) ensure herbicides would 

not be delivered in amounts greater than the SERA risk assessment scenarios and unsprayed areas would 

be retained to provide refugia, 4) herbicide use buffers would be modified to include roadside ditches that 

are hydrologically connected to streams when surface water is present in the ditch, 5) spills are extremely 

unlikely to occur given the many safety precautions in place, and 6) when working within occupied or 

suitable spotted frog habitat, use of herbicides that pose a risk would be restricted, and treatment methods, 

timing, and location would be coordinated with a wildlife biologist. Collectively these pdfs in 

combination with the use of low risk first year/first choice herbicides make it unlikely that the Columbia 

spotted frog would be adversely affected by herbicides. 

Adult frogs could be dermally exposed to herbicides by moving through treated vegetation or soil. There 

is insufficient data to quantify the dose received from exposure to contaminated vegetation or soil, but it 

is likely to be much less than if the frog was in contaminated water and could easily absorb the solution 

through its skin. The likelihood of exposure is further reduced when you consider that the herbicide-use 

buffers restrict broadcast application of herbicides within breeding habitat, require that unsprayed areas be 

provided to serve as refugia for amphibians (H7 and H8) when treating lakes, ponds, or wetlands, and 

restricts herbicide use nears wells, springs, and stockponds (H9). 

Results from exposure scenarios indicate that aminopyralid, chlorsulfuron, clopyralid, imazapic, 

imazapyr, metsulfuron methyl, and picloram pose a very low to no risk to amphibians, while the 

herbicides glyphosate, sulfometuron methyl, sethoxydim and triclopyr and some surfactants may pose 

some risk to fish and amphibians. However, these risks are minimized by the herbicide use buffers, the 

restrictions on surfactant use, and the herbicide use rates reduce the risk of adverse impacts to 

amphibians. PDF J5- a also includes a restriction on broadcasting of any herbicide within 100 feet of 

occupied habitat, and includes an additional restriction on use of sulfometuron methyl. Collectively, these 

measures would minimize the potential for any harmful exposures of herbicide to Columbia spotted frog. 

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. There would 

be few if any effects to breeding habitat from ongoing or future timber harvest, burning or fuel treatments 

and implementation of LRMP standards would ensure that breeding habitat is maintained during any 

construction, water development, or restoration projects. Disturbance from activities at upland sites from 

future activities or recreational use could occur. While proposed treatments could further disturb 

individuals, when working in occupied habitat, treatment methods, timing and location would be 

coordinated with a biologist prior to implementation (pdf J5-a) and modified if necessary to reduce 

potential impacts.

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Due to their restricted movement, frogs are unlikely to be exposed to herbicides on lands of other 

ownerships. Also, as described under direct and indirect effects, with implementation of pdfs and 

herbicide use buffers that restrict moderate to higher risk herbicides, there are no adverse effects from 

herbicide exposure anticipated. As a result, none of the alternatives would measurably contribute to any 

past, ongoing or future activity and result in significant effects to the Columbia spotted frog. 

Summary and Determination

Disturbance to Columbia spotted frog eggs, larvae, or adults during invasive plant treatment would be 

minor and short term. Implementation of any action alternative may impact individuals or habitat (MIIH), 

but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population 

or species. Adult frogs, eggs, and larvae are not likely to be disturbed by invasive plant treatments during 

the breeding season because they are restricted to aquatic habitat. Due to the relatively low toxicity of 

most herbicides proposed, the low herbicide concentrations in water that could occur under normal 

operations, and implementation of pdfs, it is unlikely frogs, eggs, or larvae would be exposed to toxic 

levels of herbicide. If occupied habitat were proposed for treatment, the site would be reviewed by a local 

biologist and treatment methods modified if necessary to avoid adverse impacts. Proposed treatment 

would contain and control existing and future infestations of invasive plants and help maintain 

riparian/wetland habitat.

Shortface Lanx and Harney Basin Duskysnail

Direct and Indirect Effects

Treatment - The shortface lanx is a non-migrant freshwater snail that can be found in the main channel of 

fast flowing streams and rivers. There would be no mortality or disturbance to the shortface lanx because 

it is aquatic and inhabits larger streams and rivers. 

The Harney basin duskysnail (HBD) inhabits cold springs and runs as well as adjacent sagebrush habitat. 

There are no treatments proposed within the Spring Creek watershed that contains the only known 

documentation of the Harney basin duskysnail within the project area. While it is possible that a site could 

be affected in the future, with implementation of the pdf J10-a and considering that treatment would not 

likely occur within a cold water spring habitat where this species would be found, it is not expected that 

the Harney basin duskysnail would be directly affected by treatment under any alternative. 

♦ pdf J10-a - If an occupied site is proposed for treatment, a local biologist would be consulted to 

determine protection measures, if necessary. These measures may include limitations on vehicle 

entry, modifications to treatment type or timing, or implementation of herbicide-use buffers.

Invasive plant treatments would not remove or alter habitat or result in changes to the hydrologic regime. 

As a result, suitable habitat would be unchanged.

Herbicides– There is limited data on herbicide effects to aquatic snails. Relyea (2005a) found no effect to 

three species of aquatic snails from the glyphosate formulation Roundup®. Mona et al. (2013) reported 

gene damage in aquatic snails exposed to 5 mg/L (ppm), but not 0.5 mg/L, glyphosate, presumably from 

the formulations used in Egypt mentioned in the paper. However, the Mona et al. paper does not specify if 

they used technical glyphosate alone, or the formulations mentioned. Given the numerous papers that 

attribute adverse effect of glyphosate-based formulations to the surfactants present (e.g., Relyea 2005b, 

Relyea 2012, Diamond and Durkin 1997), we cannot determine if the effects noted in Mona et al. are 

from glyphosate itself or the formulation mixture with surfactants. Tate et al. (1997) reared three 

generations of aquatic snails in different sub-lethal concentrations of technical grade glyphosate. 

Glyphosate had little effect on the first and second generations, but for the third generation, growth rates 

of snail embryos and egg-laying capacity increased in the presence of glyphosate while hatching was 

inhibited and some abnormalities were observed at 0.1 mg/L and higher. Griselia et al. (2004) tested

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imazapyr and a Brazilian formulation of Arsenal® (which contains imazapyr and the surfactant 

nonylphenol ethoxylate) to find the LC50 to the aquatic snail Biomphalaria tenagophila. The LC50 for 

imazapyr was 45.9 mg/L and for Arsenal was 20.1 mg/L. Back et al. (2012) looked at aquatic snail and 

algal assemblages in eutrophic wetland plots treated with glyphosate (Aqua-Neat®) or imazapyr 

(Habitat®). Glyphosate plots were erroneously treated with concentrations 6-times higher than approved 

label rates (Back et al. 2013). Eight species of snails were recovered from the plots. Diversity of snail 

species was similar across treated and untreated plots, while snail densities were higher in herbicidetreated plots. The higher snail densities in herbicide-treated plots were attributed to increased light 

availability creating higher algal growth. No negative impacts to snail species were reported.

The GLEAMS model was run on four sites within the project area that had the greatest potential for 

herbicide delivery to water near fish habitat. Results indicate that herbicide concentrations in the water are 

at least three orders of magnitude less than levels of concern for fish, amphibians, and aquatic 

invertebrates (table 38, chapter 3.5.3). Very little herbicide would reach water even in an unbuffered 

scenario. The greatest amount of herbicide reaching streams in the GLEAMS model results was 

0.0011ppm (same as mg/l) for imazapyr. The acute threshold of concern for this herbicide is 5 mg/l,

several orders of magnitude larger than the expected peak concentration in water even in the unbuffered, 

high-risk sites.

Herbicides and Terrestrial Snails - Limited data regarding herbicide toxicity to land snails exists. There

are studies conducted on brown garden snails (Helix aspersa) exposed to picloram and glyphosate. In 

Schuytema et al. (1994), snails were fed food contaminated with the herbicides at concentration up to 

5000 mg/kg for 14 days. Neither glyphosate nor picloram appeared to pose a risk to the snail. The effect 

on hatching success and embryo development of H. aspersa snail eggs was tested for glyphosate along 

and a European formulations of Roundup® containing glyphosate and a commercial nonylphenol 

polyethoxylate (NPE) surfactant (Agral®) (Druart et al. 2010). After 14 days of exposure, hatching 

success for glyphosate alone was equivalent to controls, indicating that glyphosate itself had no effect. 

The Roundup® formulation completely inhibited hatching at 225 mg/l. Hatching response to NPE was 

quite variable, with EC50 (50% reduction in hatching success) ranging from 26-85 mg/l. Druart et al. 

(2010) observed the embryo development of non-hatched eggs from the hatching success studies. They 

report “embryos exposed to glyphosate were blocked late in their development...”.This result is 

presumably from Roundup® since glyphosate itself did not alter hatching success.

Based on the limited data available, glyphosate and picloram do not appear to pose a risk to terrestrial 

snails. It appears unlikely that herbicides would pose serious toxic risk to terrestrial snails, but this 

conclusion is made with reservation due to extremely limited data. The likelihood is further reduced with 

implementation of pdf J10-a, which restricts treatment within occupied Harney basin duskysnail habitat.

With implementation of this pdf and considering there are no first-year treatments proposed near the 

Spring Creek site where this species has been documented, there are no adverse effects from herbicide 

exposure to the Harney basin duskysnail anticipated.

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. Of the 

activities anticipated, few treatments within suitable habitat would occur. In addition, LRMP standards are 

in place to reduce potential impacts to streams, rivers, and springs. While future grazing may adversely 

affect the Harney basin duskysnail or its habitat, as described under alternative effects, grazing use is not 

expected to change and upland and riparian habitat would be maintained. As a result and because 

proposed treatments would not alter existing habitat or likely result in exposure to harmful levels of 

herbicide, none of the alternatives would measurably contribute to any past, ongoing, or future activity 

and result in significant effects to these species.

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Summary and Determination

Shortface Lanx – Based on the above analysis and the following rationale, there are no effects to the 

shortface lanx anticipated, and implementation of alternatives B, C, and D would have No Impact on this 

species. 

♦ No effects of exposure have been noted in short-term exposures at concentrations predicted from 

the proposed project.

♦ If herbicide were to get into the water, contact time in flowing streams would be a matter of 

minutes, not hours or days, and certainly not for multiple generations of aquatic mollusks.

♦ No effects to aquatic snails were noted in generations 1 and 2.

♦ Glyphosate and imazapyr treatments in wetlands can increase aquatic snail populations and do 

not adversely affect food availability.

♦ Glyphosate is inactivated rather quickly by adsorption to soil and microbial breakdown in soil and 

water.

♦ The size and distribution of the invasive plant populations (relatively small and scattered), 

frequency of occurrence (patchy), environmental fate of glyphosate (not persistent), and size of 

the rivers make it impossible to achieve the predicted concentration over three snail generations.

♦ There are very limited acres of invasive plants, relative to uninfested land, adjacent to snail 

habitats, so only a small portion of the habitat would be treated.

Harney Basin Duskysnail – No treatments are proposed at the documented Harney basin duskysnail site.

Project design features would modify treatment or timing if necessary should an occupied site be 

proposed for treatment in the future. As a result, and considering herbicide use buffers would further 

protect spring and seeps, the action alternatives may impact individuals or habitat (MIIH), but will not 

likely contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Johnson Hairstreak

Direct, Indirect, Cumulative Effects and Determination

Johnson hairstreak has not been documented within suitable coniferous-forest habitat within the project 

area, and it is unlikely they would occur within treatment areas. Consequently, there would be no direct, 

indirect, or cumulative effects anticipated, and implementation of the action alternatives would have No 

Impact on this species. 

Silver-bordered Fritillary

Direct and Indirect Effects

Treatment - Of the approximately 22,000 acres of potentially suitable habitat, approximately 34 acres of 

riparian/wet meadow habitat are known to contain invasive weeds and are proposed for treatment. These 

sites are generally small and scattered across 45 watersheds.

Mechanical, manual, and herbicide treatment could harm eggs or larvae due to physical disturbance on 

the site. In order to reduce potential impacts, pdf J6-b requires that a local wildlife biologist be contacted 

if treatment is proposed on sites where the silver-bordered fritillary has been documented. Since butterfly 

populations fluctuate among meadows and between years, the local biologist can provide advice on where 

to prioritize treatments and to modify timing/treatment methods if necessary to reduce impacts. 

Consequently, the potential for adverse effects would be reduced. With implementation of this pdf and 

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considering the small amount of habitat proposed for treatment, the likelihood that treatments would 

directly affect the silver-bordered fritillary is reduced.

The silver-bordered fritillary is dependent upon wet meadow habitat, and invasive plants can reduce the 

abundance and/or cover of larval food and nectar plants (violet). All action alternatives would promote 

native plant communities and help sustain silver-bordered fritillary habitat over the long term. 

Herbicides - Data on herbicide effects to butterflies is limited with few studies in peer-reviewed literature. 

Where data is lacking, risk assessments rely on data from the honeybee and other insects as surrogates.

Herbicides could affect butterflies directly or through affects to adult nectar plants or caterpillar host 

plants. Russell and Schultz (2009) tested the toxicity of sethoxydim (in the formulation Poast®) to the 

larvae of Puget blue butterfly (Icaricia icarioides blackmorei), a Washington species of concern, and the 

non-native small white or cabbage white butterfly (Pieris rapae). Larvae were directly sprayed or fed

sprayed food plants, mimicking a spring application. Poast® contains a petroleum solvent, which could 

be an important factor in the toxicity results. Due to issues with the exposure methodology for the 

cabbage white butterfly (larvae were placed in plastic cups and sprayed, which would create pooling of 

liquid around larvae and prevented foliar interception) and because it is a non-native species, results 

discussed will focus on results for the native Puget blue. Poast® did not alter percent survival of larvae, 

biomass of pupae, adult biomass, or morphological characteristics, but it did cause earlier emergence 

from the pupae and smaller wing sizes in adults. The effects of the sethoxydim formulation to the Puget 

blue butterfly were all sublethal (Russell and Schutlz 2009). The authors suggest that applications made in 

late summer and fall would reduce effects to species like the Puget blue since they stop feeding in 

summer and larvae retreat to ground litter.

Labar (2009) conducted a field study on effects of sethoxydim to the Puget blue butterfly applied on a 

Washington prairie. Plots were sprayed with Poast® mixed with the surfactant Agridex® in April of 2007

and 2008. Results of the field trial indicated the herbicide had very little to no impact on larval survival, 

flower species, or Puget blue oviposition, while adult butterflies spent significantly less time in sprayed 

plots than in controls. Labar (2009) also recorded habitat use of sprayed and unsprayed plots for silvery 

blue (Glaucopsyche lygdamus), ochre ringlet (Coenonympha tullia), and wood nymph (Cercyonis pegala) 

butterflies. Adults of these butterflies also avoided sprayed plots. The formulation Poast® contains a 

petroleum solvent that has a strong odor, so perhaps this contributed to the avoidance of sprayed plots by 

butterflies.

Stark et al.(2012) tested the toxicity of triclopyr BEE (in the formulation Garlon 4 Ultra®), sethoxydim 

(in the formulation Poast®), and imazapyr (in the formulation Stalker®) to Behr’s metalmark butterfly 

(Apodemia virgulti) by directly spraying the larvae and their food. All three herbicide formulations 

reduced the number of individuals reaching the pupae stage. If larvae did reach the pupae stage, there was 

100 percent emergence to the adult stage. For Garlon 4 Ultra®, pupae weight was significantly larger and 

adult abdomen length significantly longer than controls. Poast® and Stalker® did not affect other 

parameters measured. The authors suggest that the effects were likely caused by the inert ingredients,

combinations of inert ingredients, or effects of the formulations on food plant quality because the 

herbicide active ingredients tested all have different modes of action (Stark et al. 2012).

For chlorsulfuron and metsulfuron methyl, Kjaer and Heimbach (2001) evaluated survival and growth of 

the large white butterfly (Pieris brassicae) when host plants were treated for four consecutive days. Rates 

applied were up to 0.8 g a.i./ha (about 0.0007 lb/ac) for chlorsulfuron (in the formulation Glean®), and up 

to 0.003 lbs a.i./acre for metsulfuron methyl (in the formulation Ally®) (all European formulations). No 

significant effects on survival or growth rate occurred for either herbicide (Kjaer and Heimbach 2001). 

Using data from other insects, the FS risk assessments for chlorsulfuron and metsulfuron (SERA 2004a,

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b) concluded that there were no likely adverse effects to invertebrates at typical and maximum application 

rates used by the Forest Service.

There is apparently no data for effects to butterflies for clopyralid, imazapic, or sulfometuron methyl. 

Using the honey bee or other insect data as a surrogate for butterflies, typical or highest application rates 

of clopyralid, imazapic, and sulfometuron methyl do not appear to pose a risk.

Sucoff et al. (2001) studied effects of herbicides on host plants, eggs, and larvae of the Karner blue 

butterfly (Lycaeides Melissa) from treatments with glyphosate, glyphosate-sulfometuron methyl mix, and 

glyphosate-triclopyr mix. Treatment did not inhibit flowering of the larval food plant. Glyphosate, 

triclopyr, and glyphosate-sulfometuron methyl mix treatments did not significantly reduce egg hatching, 

pupation of larvae, emergence of adults, pupae size, rate of development, or percent of eggs that produced 

adults. The glyphosate-triclopyr mix did significantly reduce egg hatching. Pdf (F2) restricting application 

rates of these herbicides should reduce toxic exposures. Effects are further reduced when you consider 

that triclopyr is not among the first-choice herbicides in any alternative and is restricted to spot 

application.

Effects on populations in field applications may be different from individual toxicity tests. Bramble et al. 

(1997) conducted a series of studies on the effects of using commercial formulations of herbicides 

(including glyphosate, picloram, triclopyr, and metsulfuron methyl with various surfactants) in rights-ofway maintenance, compared with mechanical maintenance, and observed no significant or substantial 

differences in butterfly populations.

The likelihood that individuals would be affected by herbicides depends on the likelihood that host plants 

would be affected or that they would be contaminated by drift. Implementation of pdf J6-a, will ensure 

that buffers would be implemented on any sites that contain host/nectar plants, reducing the likelihood of 

herbicide exposure or mortality to host plants. Additionally, J6-b requires that treatment in occupied 

habitat be coordinated with a biologist, so that the type or timing of treatment can be modified if 

necessary to reduce potential impacts. Also, use of ester formulations of herbicide in known silverbordered fritillary habitat would be prohibited. Although data is limited, it is unlikely that adverse effects 

from herbicide exposure would occur to adults, pupae, or eggs under any alternative because of project 

design features to protect suitable host plants and occupied sites; the small amount of suitable habitat 

proposed for treatment (less than1 percent of the suitable habitat affected); and the low risk of preferred 

herbicides.

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. This species 

occupies non-forested riparian/wetland habitat, so other than continued grazing and recreational use, few 

of the anticipated ongoing and future activities would occur within suitable habitat. In addition, LRMP 

standards are in place to protect and maintain suitable wet meadow habitat. Since they are known to 

occupy adjacent private land, it is possible that adults could be exposed to herbicides on all land 

ownerships. The toxicity of proposed herbicides to invertebrates is low, and pdfs applied for activities on 

NFS lands further reduce the likelihood of multiple herbicide exposures. As a result and considering the 

small amount of habitat proposed for treatment within any watershed, it is unlikely that treatment on 

National Forest System land would result in toxic levels of herbicides to adult butterflies or measurably 

contribute to any past, ongoing or future activity and result in significant effects to this species.

Summary and Determination

Silver-bordered fritillary is not documented within the project area, although it is documented adjacent to 

the Malheur National Forest so use on the Forest is likely. Following the rationale of the above analysis, 

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invasive plant treatments in any of the action alternatives may impact individuals or habitat (MIIH), but 

will not likely contribute to a trend towards federal listing or cause a loss of viability to the population or 

species.

♦ Within occupied habitat, project design features are in place that would protect host/nectar plants, 

and minimize the likelihood of adverse effects from treatment.

♦ Based on available data and with implementation of project design features, it is unlikely that 

proposed herbicides would adversely affect terrestrial invertebrates.

♦ Approximately 35 acres of preferred habitat are proposed for treatment (including 20 acres of 

spot application). Due to small amount of habitat affected and with application of pdfs that 

modify treatment type and timing, it is unlikely an occupied site would be affected.

♦ Proposed treatments would reduce invasive plants and help to maintain native riparian grassland 

habitat.

Management Indicator Species

Table 71. Treatment effects determinations for management indicator species (MIS)

Species Treatment Effects Determination

Rocky 

Mountain Elk

Treatment effects limited to short-term disturbance. Herbicide exposure unlikely. Grassland habitat 

and local elk populations maintained. Implementation of any of the action alternatives would not 

contribute to a negative trend in viability for this species within the Malheur National Forest.

Pileated 

Woodpecker

No treatment or herbicide effects to nesting birds. Disturbance to foraging birds possible. No 

herbicide exposure anticipated. Suitable habitat and local populations maintained. Implementation 

of any of the action alternatives would not contribute to a negative trend in viability for this species 

within the Malheur National Forest.

Pine 

(American) 

Marten

Not likely to occur in treatment areas. Suitable habitat and local populations maintained. 

Implementation of any of the action alternatives would not contribute to a negative trend in viability 

for this species within the Malheur National Forest.

Three-toed 

Woodpecker

No treatment effects to nesting birds. Disturbance to foraging birds possible. No herbicide 

exposure anticipated. Suitable habitat and local populations maintained. Implementation of any of

the action alternatives would not contribute to a negative trend in viability for this species within the 

Malheur National Forest.

MIS cavity 

excavators

No treatment effects to nesting birds. Disturbance to foraging birds possible. No herbicide 

exposure anticipated. Suitable habitat and local populations maintained. Implementation of any of

the action alternatives would not contribute to a negative trend in viability for this species within the 

Malheur National Forest.

Rocky Mountain Elk

Approximately 2,124 acres of elk summer range are known to contain invasive plants. Of this, 

approximately 1,860 acres (88 percent) are adjacent to open roads. While there are no invasive plant 

treatments proposed within elk calving areas, approximately 517 acres of the elk winter range is currently 

known to contain invasive plant species. Treatment would occur across 100 watersheds (HUC 6) ranging 

in size from 10,000 to 40,000 acres. While six watersheds have 100 acres or more proposed for treatment 

(120 to 170 acres), one percent or less of all watersheds would be treated.

Direct and Indirect Effects

Treatment - Elk are sensitive to human disturbance, so proposed treatments can adversely affect big game 

due to increased human access. About 88 percent of proposed treatments are close to open roads, which 

are less likely to be used as habitat (Thomas 1979). In addition, treatments within any drainage would be 

short term (a few days) and unaffected habitat is available. As a result, disturbance would likely result in 

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animals avoiding areas during treatment. Also with implementation of the following design features, the 

likelihood of disturbance during sensitive or key periods would be reduced:

♦ pdf J12-a –To reduce stress during the winter, restrict off-highway vehicle use within MA 41 (big 

game winter range) between December 1st and April 1st.

♦ pdf J12-b – To prevent harassment in designated calving areas, restrict off-highway vehicles and 

other motorized traffic use to designated roads and trails from May 1st to June 31st. 

Invasive plants can reduce forage quality and quantity for big game (Rice et al. 1997, Bedunah and 

Carpenter 1989, Trammel and Butler 1996). As a result, treatment of invasive plants would beneficially 

affect elk (and deer) by preserving native forage species and maintaining the long-term suitability of 

foraging habitat.

Herbicides – Mammals, such as elk, that eat vegetation (primarily grass) that has been sprayed with 

herbicide have relatively greater risk for adverse effects because herbicide residue is higher on grass than 

it is on other herbaceous vegetation or seeds (Kenaga 1973, Fletcher et al. 1994, Pfleeger et al. 1996). 

At the highest application rates, glyphosate and picloram exceeded levels of concern at acute exposures.

Chronic exposure levels of concern resulted from sethoxydim applied at the highest rate and triclopyr at 

the typical and highest rates. The likelihood of exposure is reduced because triclopyr is restricted to spot 

techniques, pdf F2 prevents glyphosate and picloram from being broadcast sprayed above typical 

application rates, and pdfs H3/H4 restrict use of picloram on sensitive soils and frequency of application. 

The likelihood of exposure is further reduced when considering that elk forage over large areas and are 

not likely to consume an entire days diet of contaminated vegetation (acute exposure) or forage 

exclusively on contaminated vegetation for 90 days (chronic exposure). As a result and considering that 

88 percent of the proposed treatments occur close to open roads that are less likely to be used by elk 

(Thomas 1979), it is unlikely that elk would be adversely affected by herbicide exposure.

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. As 

described, ongoing and future activities would be implemented on 60 watersheds forestwide. Proposed 

timber harvest would reduce elk cover, while adhering to Forest LRMP standards related to habitat 

effectiveness and hiding and thermal cover. In addition, much of the harvest, as well as prescribed fire and 

plantation thinning would improve elk forage on summer, winter, and transition ranges. As a result and 

considering that proposed treatments would help to maintain native forage over the long term, elk habitat 

would be maintained in all affected watersheds. While proposed treatments could increase disturbance to 

elk on summer range, effects would be short term. As a result and considering that 88 percent of proposed 

treatments occur close to roads where elk are less likely to occur, there are no long-term disturbance 

related effects anticipated. 

Since elk utilize all land ownerships, anticipated cumulative effects include possible exposure to 

herbicides on state, private, and BLM land if applications occur at approximately the same time.

Regardless, negative effects are unlikely since the herbicides proposed are rapidly eliminated and do not 

significantly bio-accumulate (USDA Forest Service 2005a). The risk of herbicide exposure over a level of 

concern would be avoided by implementation of pdfs that restrict herbicide application rates; provide 

herbicide-use buffers along streams, waterbodies, springs, and riparian areas; and minimize drift from 

broadcast application. The risk of exposure is further reduced when you consider that 1 percent or less of 

any watershed would be affected by treatment and that most treatment occurs in less preferred habitat 

adjacent to open roads. Collectively for these reasons, none of the alternatives would measurably 

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contribute to any other past, current, or foreseeable activity related to herbicide exposure and there are no 

significant cumulative effects to elk anticipated. 

Summary and Determination

There are no adverse effects from herbicide exposure anticipated. Proposed treatments may result in 

short-term disturbance during treatment. Ultimately, treatment would reduce invasive plants and help to 

maintain native big game range. As a result, local populations of elk and hunting opportunities would be 

maintained. Implementation of the action alternatives would not contribute to a negative trend in viability 

for elk on the Malheur National Forest. 

Pine (American) Marten

Direct, Indirect, and Cumulative Effects

Marten prefer closed-canopy forest away from open roads (where 88 percent of proposed treatment sites 

are); therefore, it is unlikely they would be found in treatment sites. In addition, invasive plant treatments 

would not alter forested habitat. Considering no herbicide exceeded a level of concern for carnivores 

eating contaminated small mammals, proposed treatments would not adversely affect marten or alter their 

habitat under any alternative. 

Summary and Determination

There are no direct, indirect, or cumulative effects to marten anticipated and implementation of the action 

alternatives would not contribute to a negative trend in viability for this species on the Malheur National 

Forest. 

Cavity Nesters and Species Dependent on Downed Wood

Because they occupy similar habitats and have similar threats, cavity nesting species or species that 

require standing dead (snags) and downed woody debris are discussed collectively.27 These species 

include pileated woodpecker, northern three-toed woodpecker, northern flicker, red-naped sapsucker, redbreasted sapsucker, Williamson’s sapsucker, downy woodpecker, hairy woodpecker, and black-backed 

woodpecker.

Direct and Indirect Effects

Treatment - No snags or trees would be removed; therefore, nest habitat would be unaffected. 

Disturbance to foraging birds would occur, particularly to species, such as the pileated woodpecker or 

northern flicker that forage on the ground or in more open canopy conditions. Sites are small and 

scattered, so unaffected habitat is available and effects would be limited to short-term disturbance during 

treatment. Cavity nesting species are not at risk from herbicides and existing habitat would be unchanged.

Herbicides - Species that forage and nest in trees are not likely to be exposed to herbicides because 

woody vegetation would not be treated and no aerial application is proposed. Species, such as the pileated 

woodpecker and northern flicker, that feed on the ground or in low shrubs may consume contaminated 

insects. 

Effects of herbicide exposure are the same as those described under the Lewis’ and white-headed 

woodpecker. With implementation of pdfs, the likelihood of herbicide exposure is reduced. The likelihood 

of exposure is further reduced when you consider that birds forage over large areas and that many of the 

insects utilized occur within dead wood, under bark, or from areas not exposed to herbicides. As a result,

27 Findings and determinations for the Lewis and white-headed woodpeckers were discussed previously in the Forest 

Service Sensitive Species section.

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birds are not likely to consume exclusively contaminated insects, and there are no adverse effects from 

herbicide exposure anticipated under any alternative.

Cumulative Effects - Ongoing and future projects, including the relationship between land management 

and invasive weeds, are discussed under section 3.1.5 whereas alternative cumulative effects are 

discussed above. These species could be affected by any activity that reduces snags or downed wood, or 

modify the overstory, particularly timber harvest and prescribed burning. Timber harvest and invasive 

plant treatments would occur within 39 watersheds, which include approximately 1,100 acres of 

treatment. While timber harvest would reduce habitat for some species, habitat for others would be 

improved. Implementing Forest standards would retain a component of snags and downed wood on all 

sites. As a result, the proposed treatments would not modify suitable habitat or adversely affect species 

from herbicide exposure. None of the alternatives would measurably contribute to any other past, current,

or foreseeable activity, and there are no significant cumulative effects to snag or downed wood dependent 

species anticipated.

Summary and Determination

Suitable habitat for MIS and sensitive cavity nesting species overlap with mapped infestations proposed 

for treatment. It is unlikely nesting birds would be affected and any disturbance to foraging birds would 

be short-term (usually one day or less). Suitable nesting habitat would be unaffected by treatment and 

implementation of the action alternatives would not contribute to a negative trend in viability for cavity 

nesting or downed wood dependent species on the Malheur National Forest. 

Effects to Featured Species

California Bighorn Sheep

Direct and Indirect Effects

Treatment - Less than 14 acres of bighorn sheep habitat is proposed for treatment and the likelihood of 

disturbance is remote. Should future treatments be proposed within occupied habitat, treatment 

modifications/timing would be made if necessary during preparation of annual prescriptions to ensure 

sheep are not disturbed and all alternatives comply with LRMP standard 55. Due to the small amount of 

habitat known to contain invasive plants, suitable habitat would be unchanged.

Herbicides - Effects from herbicide exposure would be similar to those described under elk. With 

implementation of pdfs, the small amount of habitat proposed for treatment, and that sheep are not likely 

to consume exclusively contaminated vegetation, the likelihood of exposure is reduced. As a result, there 

are no adverse effects from herbicide exposure anticipated under any alternative. 

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. Other than 

grazing and recreation, there are few ongoing and future activities within suitable habitat anticipated. As 

described under alternative cumulative effects, it is not anticipated that grazing use will change and 

bighorn forage conditions would be maintained. Considering the small amount of habitat proposed for 

treatment, and low likelihood of herbicide exposure, none of the alternatives would measurably contribute 

to any past, current, or foreseeable activity, and there are no significant cumulative effects anticipated.

Summary and Determination

Due to the small amount of habitat proposed for treatment and that there are no adverse effects from 

herbicide exposure, local populations of bighorn sheep and their habitat would be maintained under all 

alternatives. 

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Northern Goshawk

Direct and Indirect Effects

Treatment - There are 567 acres of goshawk nesting/foraging habitat and 18 acres of post fledgling 

habitat proposed for treatment. Invasive plants prefer a more open canopy habitat. The northern goshawk 

prefers closed-canopy, mature forest for nesting and foraging; therefore, its habitat is not at risk from 

invasive plants. With implementation of pdf J11-a that restricts activity within 0.50 mile of known nest 

sites, there are no effects to nesting goshawks anticipated. Foraging goshawks could be disturbed during 

treatment, although unaffected habitat is available and any disturbance would be short-term. Proposed 

treatments would not alter existing habitat.

Herbicides - At the typical application rate, no herbicide or surfactant exceeded the toxicity index for an 

acute or chronic exposure whereas sethoxydim equaled the NOAEL at the highest application rate. Project 

design feature F2 restricts broadcast application of sethoxydim to the typical application rate. As a result,

and considering that goshawk forage over large areas and are unlikely to feed exclusively on 

contaminated prey, there are no adverse effects from herbicide exposure anticipated.

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. While 

activities such as timber harvest and prescribed burning would modify goshawk nesting and foraging 

habitat, LRMP standards would protect nest sites and PFA areas. Consequently, stand and landscape-level 

prey diversity would likely increase. Similarly, plantation thinning and reforestation treatments would 

increase understory and prey diversity. While there would be some road use changes resulting from access 

and travel management, with implementation of plan standards, nest habitat would be maintained. 

Mineral exploration could result in a long-term reduction in nest habitat whereas short-term disturbance 

could occur from future structural or instream restoration work. Disturbance from recreation would 

continue, although high use areas would continue to be avoided. While there may be a localized reduction 

in habitat from some ongoing and future activities, most anticipated activities would maintain nest habitat 

and maintain or improve foraging habitat. Since proposed actions would not modify habitat or result in 

adverse effects from herbicide exposure, none of the alternatives would measurably contribute to any 

past, current, or foreseeable activity, and there are no significant cumulative effects anticipated.

Summary and Determination

Suitable goshawk habitat would be maintained and any effects from treatment would be minor and short 

term. Local populations of northern goshawk and their habitat would be maintained under all alternatives. 

Blue Grouse

Direct and Indirect Effects

Treatment - Blue grouse winter at upper elevations in habitat that is largely unaffected by invasive plants 

or treatment. They breed within openings at lower elevations, and treatments within open canopy forest 

and grassland/shrub habitats near forest could disturb grouse or result in mortality to nests or chicks. 

There are approximately 125 acres proposed for treatment in mountain meadow, step shrublands, or 

riparian/shrub habitats. Due to the small size of treatment sites and widespread availability of unaffected 

habitat, the likelihood of adverse impacts is low. This species is not at risk from invasive plants and 

suitable winter and summer habitat would be unchanged. 

Herbicides - Adult blue grouse forage primarily on shrubs and herbaceous vegetation during the summer 

months, and chicks consume large quantities of insects. Thus, risk of effects from herbicide exposure was 

evaluated using the insectivorous bird scenario and the large bird consuming vegetation. 

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For adult birds and chicks at typical application rates, only triclopyr (if broadcast sprayed) exceeded the 

acute toxicity thresholds. Glyphosate exceeded a dose of concern at the highest rate for small birds 

consuming insects. Triclopyr is restricted to spot techniques. Project design feature F2 limits broadcast 

spray of glyphosate and triclopyr to the typical rate (or less for triclopyr). As a result, it is unlikely that 

adult birds or chicks would receive an acute exposure of concern. 

Triclopyr exceeded a chronic dose of concern at the typical and highest application rate whereas 

sethoxydim, sulfometuron methyl, and glyphosate exceeded the toxicity threshold at the highest 

application rate. With implementation of pdf F2, which restricts broadcast application of clopyralid, 

glyphosate, picloram, sethoxydim, sulfometuron methyl, and triclopyr to typical application rates, and the 

Malheur National Forest LRMP standard that prevents broadcast application of triclopyr, the likelihood of 

exposure is reduced. Triclopyr is not a first-choice herbicide in any alternative. As a result of the small 

size and scattered nature of treatments sites, birds would not be expected to forage exclusively on 

contaminated insects or plants and be exposed to herbicides at levels of concern. 

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. 

Approximately 125 acres of summer habitat could be affected by treatment. Activities that could occur in 

suitable riparian or uplands shrub habitat include prescribed burning, hazard tree removal, aspen 

restoration, spring development, stream restoration, or grazing. Activities in riparian habitat would be 

restricted with implementation of LRMP standards, and although there may be localized changes in 

vegetation, this community would be maintained. Continued grazing could reduce vegetation within 

upland shrub habitat, although use is not expected to change, and adherence to allowable use standards 

and modifications of livestock numbers or use following treatment would maintain vegetative structure 

and diversity. While prescribed burning could result in short-term impacts to understory vegetation, 

treatment would promote the maintenance of shrub diversity over the long term. Similarly, proposed 

treatments would help to reduce invasive plants and maintain native shrub, grass, and forb diversity. 

Therefore, none of the alternatives would measurably contribute to any past, current, or foreseeable 

activity and result in significant cumulative effects.

Summary and Determination

Proposed activities would not modify suitable habitat and no long-term effects from treatment are 

anticipated. As a result, suitable habitat and local populations of blue grouse would be maintained. 

Osprey

Direct and Indirect Effects

Treatment - There are no known osprey nests on the Forest; however, pdf J11-a protects osprey nests 

should one become established in the future. Accordingly, there would be no effects to nesting birds or 

reproduction. Osprey forage and nest over standing water, so neither birds nor their habitat would be 

affected by treatment. 

Herbicides - While osprey would not be directly sprayed, they could consume fish exposed to herbicides. 

Doses were estimated assuming that birds ate nothing but fish contaminated by a spill of 200 gallons into 

a 0.25 acre pond, over a lifetime. All expected doses to fish-eating birds for all herbicides are well below 

any known no-observable-adverse-effect-level (NOAEL) and the weight of evidence suggests that 

adverse effects to this species group from herbicides included in the action alternatives are not plausible.

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Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. Because 

osprey nest and forage exclusively over water, proposed activities on NFS lands are not expected to 

adversely affect osprey. While birds could be exposed to herbicides on lands of other ownerships, for 

adverse effects to occur, the two exposures would have to occur at approximately the same time. This is 

unlikely since the herbicides proposed are rapidly eliminated and do not significantly bio-accumulate 

(USDA Forest Service 2005a). Also with implementation of pdfs that limit the application rate, method,

and frequency for higher-risk herbicides; provide herbicide buffers along streams, waterbodies, and 

riparian areas; and minimize drift from broadcast application, the risk of herbicide exposure is further 

reduced. As a result, none of the alternatives would measurably contribute to any past, current, or 

foreseeable activity related to herbicide exposure, and there are no significant cumulative effects to 

osprey anticipated. 

Summary and Determination

Osprey and their habitat would be unaffected by invasive plants or proposed treatments and local 

populations would be maintained. 

Pronghorn Antelope

Direct and Indirect Effects

Treatment - Approximately 122 acres of invasive plants would be treated within sagebrush habitat 

adjacent to private lands and suitable pronghorn habitat. This would occur across 25 watersheds with 70 

(alternative B) to 83 (alternative D) percent of the herbicide application occurring as spot treatment.

Under alternative C, 75 percent of the treatments would be with manual/mechanical methods. 

Although pronghorn occupy more open habitat, the potential effects of invasive plant treatment to 

pronghorns would be similar to those discussed under the rocky mountain elk. Both species graze 

herbaceous plants, graze over large areas, and are sensitive to human disturbance. Direct effects would be 

limited to short-term disturbance during treatment and all alternatives comply with LRMP standard 52. 

Because treatments would contain or control invasive plants, pronghorn habitat would be maintained 

under all action alternatives. 

Herbicides - Effects of herbicide use would be the same as those described for elk. While exposures of 

concern are possible, with implementation of the Malheur National Forest LRMP standard that restricts 

use of triclopyr to spot techniques and pdf F2 that prevents glyphosate and triclopyr from being broadcast 

sprayed above typical application rates, the likelihood of exposure is reduced. Considering that pronghorn 

forage over large areas and are not likely to consume exclusively contaminated vegetation, it is unlikely 

that antelope would be adversely affected by herbicide exposure.

Cumulative Effects

Ongoing and future projects, including the relationship between land management and invasive weeds,

are discussed under section 3.1.5 whereas alternative cumulative effects are discussed above. Future 

activities that could affect pronghorn include grazing, livestock water development, and juniper 

management. While disturbance from water development and juniper management could occur, habitat 

would be maintained. Continued grazing could reduce forage, but use is not expected to change and 

livestock would be deferred following treatment if necessary to ensure establishment of native vegetation. 

As a result, suitable pronghorn habitat would likely be maintained. Animals could be exposed to 

herbicides on lands of other ownerships; however, as described under the alternative cumulative effects 

for elk, there are no adverse effects from herbicide exposure anticipated, and none of the alternatives 

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would measurably contribute to past, current, or foreseeable activity and result in significant cumulative 

effects.

Summary and Determination

While proposed treatments may result in short-term disturbance during treatment, habitat would be 

maintained or improved and there are no adverse effects from herbicide exposure anticipated. As a result, 

local populations of pronghorn would be maintained.

Effects to Birds of Conservation Concern

This section evaluates effects to landbirds, birds of conservation concern, and game birds below desired 

condition identified in section 3.72. Table 73 displays species not evaluated previously grouped into 

similar feeding strategies for analysis. 

Table 72. Exposure groups, habitat and species included in each group

Animal/Diet Group Habitat Species

Predatory Birds

(small mammals)

Grassland, Shrub-steppe, Dry 

Forest, Juniper-steppe, Rimrock-cliff

Swainson’s hawk, prairie falcon, burrowing owl, 

Ferruginous hawk, flammulated owl

Insectivorous Birds Dry Forest, Mesic Mixed Conifer, 

Riparian Woodland and Shrub, 

Shrub-steppe, Alpine, Sagebrush, 

Juniper Woodland, open 

water/wetland.

chipping sparrow, Vaux’s swift, Townsend’s warbler, 

varied thrush, MacGillivay’s warbler, red-eyed vireo, 

veery, willow flycatcher, hermit thrush, vesper 

sparrow, gray-crowned rosy finch, loggerhead shrike, 

lark sparrow, black-throated sparrow, Bullock’s oriole, 

yellow warbler, yellow-breasted chat, yellow-billed 

cuckoo, lazuli bunting, gray flycatcher, Virginia 

warbler, yellow-billed cuckoo, olive-sided flycatcher, 

sage sparrow, Brewer’ sparrow, sage thrasher, sage 

sparrow, black swift, calliope hummingbird, 

Williamson’s sapsucker, McCown’s longspur, black 

rosy finch, Cassins finch, long billed curlew.

Herbivorous

birds

Shrub-steppe sharp-tailed grouse,

Waterfowl Wetlands, riparian areas and open 

water habitats

canvasback, ring-necked duck, wood duck, mallard, 

northern pintail, redhead, lesser scaup, American 

widgeon

Predatory Birds 

Direct and Indirect and Cumulative Effects

With implementation of pdf J11-a, raptor nests would be protected, and no adverse effects to nesting birds 

or reproduction is anticipated under any alternative. LRMP standards are also in place to protect hawk and 

owl nests from other management activities. While foraging birds could be affected, the short-term (1 day 

or less), low magnitude, and limited extent (usually 1 acre or less scattered over larger areas) of 

disturbance that would occur with invasive plant treatments would not adversely affect species in this 

group.

Effects of herbicide exposure would be similar to those described for northern goshawk and peregrine 

falcon and as described, there are no adverse effects from herbicide exposure anticipated.

Cumulative effects would be similar to those described under northern goshawk.

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Insectivorous Birds 

Direct, Indirect, and Cumulative Effects

Effects to these species will vary. There would be little effect to forested species, such as the Townsend’s 

warbler, that utilize closed-canopy forest and nest off the ground. However, for species, such as the veery 

or Brewer’s sparrow, which nest on or near the ground or in shrubs, effects include possible mortality 

associated with trampling of the nest. Due to the small size of treatment sites and widespread availability 

of unaffected habitat, the likelihood of mortality is low. Direct effects would include short-term 

disturbance during treatment.

Risk of effects from herbicide exposure was evaluated using the insectivorous bird scenario and effects 

would be similar to those described for the grasshopper sparrow. While use of some herbicides could 

result in an adverse effect, implementation of the Malheur National Forest LRMP standard that restricts 

use of triclopyr to spot methods only and pdf F2 that restricts broadcast application of clopyralid, 

glyphosate, picloram, sethoxydim, sulfometuron methyl, and triclopyr to typical application rates, the 

likelihood of herbicide exposure is low. Exposure is further reduced when you consider the small and 

scattered nature of the treatment sites and availability of unaffected habitat, which would reduce the 

likelihood that birds would forage exclusively on contaminated insects. As a result, there are no adverse 

effects from herbicide exposure anticipated under any alternative.

Cumulative effects would be similar to those described under grasshopper sparrow.

Herbivorous Birds 

Direct, Indirect, and Cumulative Effects

The Columbia sharp-tailed grouse has not been documented on the Forest, and there are no direct effects 

from treatment anticipated. If use within treatment sites is documented, necessary treatment modification 

would be made as part of the annual review and monitoring process, and it is unlikely that the Columbia 

sharp-tailed grouse would be directly affected by herbicide or non-herbicide treatments. While all 

alternatives would control invasive plants within sagebrush communities, alternative B would be the most 

effective because it has the widest range of treatment options, particularly with larger infestations.

Effects from herbicide exposure would be similar to those described under sage grouse. For adult birds 

consuming vegetation and chicks consuming insects, only triclopyr (if broadcast sprayed) exceeded the 

acute toxicity threshold at typical and highest application rates whereas glyphosate exceeded a dose of 

concern at the highest rate for small birds consuming insects and large birds consuming vegetation. 

Because triclopyr is restricted to spot application and with implementation of pdf F2 that limits both 

herbicides to typical application rates (less for triclopyr), it is not expected that adult birds or chicks 

would receive an acute exposure of concern. 

For chronic exposures to adult birds, triclopyr exceeded a dose of concern at the typical and highest 

application rate whereas sethoxydim, sulfometuron methyl, and glyphosate exceeded the toxicity 

threshold at the highest application rate. Data is lacking to evaluate a chronic exposure of clopyralid, 

glyphosate, picloram, sethoxydim, sulfometuron methyl, and triclopyr on small birds consuming insects. 

While exposure from these herbicides are possible, when you consider that 1) pdf F2 restricts broadcast 

application of clopyralid, glyphosate, picloram, sethoxydim, and sulfometuron methyl to typical 

application rates (and all use of triclopyr to typical rates), 2) triclopyr is restricted to spot techniques, 3) 

the use and frequency of picloram is restricted (H3 and H4), 4) the small amount of habitat proposed for 

treatment that is scattered across 20 watersheds, and 5) birds would be unlikely to consume 100 percent of 

their diet from contaminated insects/vegetation for 90 days and receive a chronic dose of concern, there 

are no adverse effects from herbicide exposure anticipated under any alternative. 

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Cumulative effects would be similar to those described under sage grouse and upland sandpiper 

Waterfowl

Direct, Indirect, and Cumulative Effects

While all alternatives would help to contain and control invasive plants, treatments proposed under 

alternatives C and D are less effective (see chapter 3.1.4); therefore, treatment effectiveness of invasive 

plants within wetland and riparian habitat would best be achieved under alternative B. Risk of disturbance 

is also greater under alternatives C and D because more repeated treatments may be necessary increasing

use of spot herbicide application and manual/mechanical treatments.

Disturbance to waterfowl could occur under any alternative from herbicide or non-herbicide methods. 

With implementation of herbicide-use buffers, retention of untreated areas near water (H7-H9) and 

considering the small and scattered nature of treatment sites within suitable habitat, the likelihood of 

direct effects to nesting birds is low. 

The diet of these species varies; species, such as the redhead, eat primarily plant material, and the 

canvasback, ring-necked duck, mallard, pintail, lesser scaup, and American widgeon eat a combination of 

plants and insects. Also, some species, such as the wood duck and pintail, eat vegetation or insects away 

from water within woodlands or open habitat. As a result, effects of herbicide exposure to waterfowl were 

evaluated using the insectivorous and herbaceous bird scenarios, as well as by evaluating the likelihood 

aquatic organisms would be affected.

Effects to aquatic invertebrates and plants were evaluated under the fisheries analysis and as described, 

concentrations of herbicides potentially delivered to any water body on the Malheur National Forest 

would remain well below levels capable of measurably affecting aquatic organisms, including: fish, 

amphibians, or aquatic invertebrates. Herbicide exposures to birds consuming insects or plant material 

would be similar to those described above (i.e., insectivorous and herbivorous birds) and the following 

pdfs reduce the likelihood that waterfowl would be exposed to toxic levels of herbicide. 

♦ The Malheur National Forest LRMP restricts use of triclopyr to selective and spot techniques 

only.

♦ Project design feature F2 restricts broadcast application of clopyralid, glyphosate, picloram, 

sethoxydim, and sulfometuron methyl to typical application rates whereas triclopyr is restricted to 

the typical application rate per acre or less.

♦ Project design features (H1, H2, H5, and H8-H10) would reduce the likelihood for herbicides to 

be delivered to wetlands, lakes, ponds, wells, springs, or stock tanks.

♦ Restrictions on extent of treatment in a given site (H4, H5, and H7) ensure that herbicides would 

not be delivered in amounts greater than the SERA risk assessment scenarios and that unsprayed 

areas around wetlands, lakes, and ponds would be retained.

The likelihood of exposure to herbicide would be further reduced because of herbicide-use buffers and the 

application of pdfs around streams, wetlands, lakes, ponds, intermittent and ephemeral streams (table 11). 

Collectively, these measures in combination with the use of low risk herbicides will greatly reduce the 

likelihood that waterfowl would be exposed to toxic levels of herbicide. Considering that birds would 

unlikely forage exclusively on contaminated prey/plant material, there are no adverse effects from 

herbicide exposure anticipated. 

Cumulative effects would be similar to those discussed under bufflehead and osprey. 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Migratory Bird Summary

Migratory birds and their habitats, including species with viability concern, regional landbirds, birds of 

conservation concern and gamebirds below the desired condition were evaluated. While short-term effects 

to some migratory bird species may occur, the likelihood of mortality is low. Mitigation measures have 

been included to reduce effects and there are no long-term adverse effects from treatment anticipated, nor 

is it likely that migratory birds would be exposed to toxic levels of herbicide. There would be no 

reduction in native vegetation, and all alternatives would help to reduce invasive plants and maintain 

migratory bird habitat. All action alternatives are consistent with the Migratory Bird Treaty Act and 

Executive Order 13186. 

3.8 Range

3.8.1 Introduction

This section discusses the effects of alternatives on range resources, with emphasis on the herbicide 

treatments proposed. The analysis addresses effects of the alternatives on livestock and the need for 

specific grazing administration during and after herbicide use.

Regulatory Framework and Compliance

Several of the goals, objectives, standards, and guidelines from the R6 2005 ROD are about grazing and 

range management. This invasive plant treatment project complies with the treatment and restoration 

standards and assumes compliance with the prevention standards. Prevention of invasive plants on 

grazing allotments is part of grazing projects and compliance with prevention standards is assumed for 

this analysis.

Table 73. Standards from the R6 2005 ROD and their relationship to range management

R6 2005 

ROD 

Standard

Text of Standard Relationship to Range Management

Prevention

Standard

1

Prevention of invasive plant introduction, 

establishment, and spread will be addressed in 

grazing allotment and vegetation management 

plans.

Direction from Forest LRMP, the 2001 Guide to 

Noxious Weed Prevention Practices, and the 2005 

ROD addressed in all projects.

Prevention

Standard

2

Actions conducted or authorized by written 

permit by the Forest Service that will operate 

outside the limits of the road prism... require the 

cleaning of all heavy equipment... prior to 

entering National Forest System Lands.

Private lands associated with permittees are 

periodically surveyed to determine the presence of 

invasive species and the need for washing of 

vehicles, such as water trucks and ranch vehicles,

before entry onto National Forest System Lands.

Water trucks are generally restricted to roads or 

“haul routes” that like roads are compacted and 

disturbed. Destinations are water set areas used 

year after year.

Prevention

Standard

3

Use weed-free straw and/or mulch for all 

projects, conducted or authorized by the Forest 

Service, on National Forest System lands. If 

state certified straw and/or mulch is not available, 

individual Forests should require sources 

certified to be weed-free using the North 

American Weed Free Forage Program standards 

(see Appendix O) or a similar certification 

process.

Where straw and/or mulch may be used as 

bedding for livestock operations and/or restoration 

projects. 

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

R6 2005 

ROD 

Standard

Text of Standard Relationship to Range Management

Prevention

Standard

4

Use only pelletized or certified weed free feed on 

all National Forest System Lands. If State 

certified weed free feed is not available, 

individual Forests should require feed certified to 

be weed free using the North American Weed 

Free Forage Program standards or a similar 

certification processes Choose weed-free project 

staging areas, livestock and packhorse corrals, 

and trailheads.

Would use weed free feed and hay by permittees 

on all allotments. Hay and other feeds are 

occasionally used to gather or attract livestock, 

generally in preparation for a move. Would have 

permittees avoid those areas that become 

infested with invasive plants for livestock 

operations, such as gather, herding, the staging of 

vehicles, and livestock watering. The bigger 

concern would be where the permittee transports 

horses onto the allotment and brings hay products 

in with the trailer or if the permittee stays overnight 

and feeds horses at a line camp. Standard 

conforms to Order No. R6-2009-001.

Prevention

Standard

5

Retain native vegetation consistent with site 

capability and integrated resource management 

objectives to suppress invasive plants and 

prevent their establishment and growth.

Compliments CDO. Land and resource 

management plans, standards, and guidelines 

that call for maintaining or improving vegetation 

conditions on allotments.

Prevention

Standard

6

Use available administrative mechanisms to 

incorporate invasive plant prevention practices 

into rangeland management. Examples of 

administrative mechanisms include, but are not 

limited to, revising permits and grazing allotment 

plans, providing annual operating instructions, 

and adaptive management. Plan and implement 

practices in cooperation with the grazing permit 

holder.

Accomplished long term through environmental 

analysis projects that lead to new allotment 

management plans and grazing permits.

Cooperate with grazing permittee on an annual 

basis to incorporate invasive species prevention 

practices in annual operation plans and use 

adaptive management to recognize changing 

science and ecosystem conditions.

Treatment

Restoration

Standard

11

Prioritize infestations of invasive plants for 

treatment at the landscape, watershed, or larger 

multiple forest/multiple owner scale.

Provides an opportunity to focus on local problem 

areas and establish “community” based solutions 

that might include, but is not limited to, multiple 

ranches, state, and/or BLM lands.

Treatment

Restoration

Standard

23

Prior to implementation of herbicide treatment 

projects, National Forest system staff will ensure 

timely public notification. Treatment areas will be 

posted to inform the public and forest workers of 

herbicide application dates and herbicides used.

If requested, individuals will be notified in 

advance of spray dates.

Permittees will be notified upon request of specific 

treatment dates. Permittees will be notified of 

invasive plant treatment areas and the potential 

for treatment by herbicides as needed on an 

annual basis. The most appropriate method would 

be during annual operating meetings.

3.8.2 Affected Environment

Currently, more than 99 percent of the Malheur National Forest is incorporated into cattle grazing range 

allotments (1,695,228 acres, based on GIS data for the Malheur National Forest). The Malheur National 

Forest administers 106 grazing allotments, of which 98 are active and 8 are vacant. There are currently 

invasive plant infestations mapped on 86 of these allotments (81%) including on five of the vacant 

allotments. Infested sites range in size from one plant to numerous plants scattered over large acreages.

Over 90 percent of inventoried sites are less than 1 acre in size and an additional one percent of the sites 

are less than 5 acres in size. See table 75 below showing the extent of mapped invasive species within 

each allotment. 

Certain invasive plants are known to be toxic to various classes of permitted livestock. Canada thistle has 

the potential to concentrate nitrates and cause nitrate poisoning in ruminants. Russian knapweed and 

yellow starthistle both produce a unique poisoning of horses that is generally fatal. Leafy spurge can 

cause excessive salivation and diarrhea in cattle; however, it does not appear to affect sheep and goats 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

(USDA Forest Service 2012c). Houndstongue and tansy may cause liver problems in livestock, 

particularly cattle and horses.

Table 74. Invasive plant species information by allotment

Allotment Name

Status

Active (A)

Vacant (V)

District

Forest land 

allotment 

acres

Number of 

mapped invasive

plant sites 

Number of mapped

invasive plant sites

mapped 

Acres of 

mapped 

Invasive 

plants

Aldrich A BM 20572 1 1 8

Alkali A EC 26753 106 5 71

Allison A EC 21156 11 4 1.5

Antelope (Silvies) A BM 29381 7 5 1

Antelope (Upper 

Malheur)

A PC 5512 2 1 0.14

Austin V BM 672 4 3 9

Balance Creek A BM 365 0 0 0

Bear Creek A BM 1532 9 3 18

Beech Creek A BM 3756 10 3 14

Biggs On/Off A BM 166 0 0 0

Big Sagehen A EC 21612 56 8 8

Blue Creek A EC 16738 39 7 6

Blue Mountain V BM 22709 196 8 243

Bluebucket A PC 23436 11 3 5

Bridge Creek A 8354 13 3 1.5

Buck Mountain A EC 41479 2 2 0.14

Calamity A BM 23204 66 6 25

Camp Creek (Silvies) A BM 14958 10 4 13

Central Malheur A EC 11377 22 3 5

County Road A BM 0 0 0 0

Crooked Creek A BM 5076 10 3 1

Dark Canyon A BM 31808 40 9 5.29

Deadhorse A BM 15527 5 4 0.52

Deardorff A PC 11927 24 4 11

Deer Creek A BM 2998 2 2 0.21

Devine A EC 25390 146 6 26

Dixie A BM 26875 14 5 2

Dollar Basin A PC 16396 5 3 5

Donaldson A BM 8008 14 5 10

Donnelly A EC 56083 30 4 24

Emigrant Creek V EC 1609 2 1 0.20

Fawn Spring A BM 6615 18 6 4

Ferg A BM 478 1 1 0.10

Fields Peak A BM 30735 47 7 6

Flag Prairie A PC 28775 33 6 18

Flagtail A BM 14978 19 6 32

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Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Final Environmental Impact Statement

Allotment Name

Status

Active (A)

Vacant (V)

District

Forest land 

allotment 

acres

Number of 

mapped invasive

plant sites 

Number of mapped

invasive plant sites

mapped 

Acres of 

mapped 

Invasive 

plants

Fox A BM 26589 63 7 30

Frenchy A BM 525 0 0 0

Green Butte A EC 45265 9 4 2

Hamilton A BM 3410 7 4 0.71

Hanscomb A BM 9105 4 3 0.74

Herberger V BM 553 0 0 0

Highway A BM 905 0 0 0

Hot Springs A PC 4693 0 0 0

House Creek A EC 3252 15 3 1

Hughet Valley A EC 1877 0 0 0

Hunter Cabin A BM 15892 0 0 0

Indian Creek A PC 2593 1 1 0.10

Indian Ridge A BM 3440 20 8 2.50

Izee A EC 22219 22 5 15

Jack Creek A BM 10358 55 8 17

Joaquin A BM 38 0 0 0

Justice A BM 825 0 0 0

Keeney Meadows A BM 450 1 1 0.08

Koehler A BM 1002 0 0 0

King A BM 2237 0 0 0

Lake Creek V PC 10195 15 5 7

Lewis Creek A BM 2604 0 0 0

Little Mowich A EC 317 0 0 0

Logan Valley A PC 3780 6 3 0.61

Lonesome A EC 32085 30 4 32

Long Creek A BM 50241 83 10 57

Lower Middle Fork A BM 59120 195 12 247

Lower Nicoll A EC 3966 0 0 0

Mcclellan A BM 2814 1 1 0.10

Mccoy Creek A PC 980 1 1 0.10

Mccullough V BM 627 5 2 13

Mt. Vernon / John Day A BM 50466 58 7 27

Muddy A EC 6621 13 3 1

Murderers Creek A BM 67075 20 11 53

Myrtle A EC 29407 32 5 7

Ninety Six A BM 300 0 0 0

North Fork A PC 31044 109 9 38

Ott A PC 29991 158 7 25

Pearson A BM 190 0 0 0

Pine Creek A 40328 222 4 81

Poison A BM 74 0 0 0

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

Allotment Name

Status

Active (A)

Vacant (V)

District

Forest land 

allotment 

acres

Number of 

mapped invasive

plant sites 

Number of mapped

invasive plant sites

mapped 

Acres of 

mapped 

Invasive 

plants

Rail Creek A PC 27135 2 2 0.20

Rainbow A 30707 25 6 8

Reynolds Creek A PC 24028 261 7 42

Rosebud A BM 6912 34 5 44

Roundtop A BM 13708 44 7 12.5

Sawmill A EC 21461 2 2 0.09

Sawtooth A 17724 43 7 237.1

Scatfield A EC 2327 0 0 0

Scotty Creek A BM 35817 7 2 13

Seneca A BM 19321 23 6 2

Silver Creek A EC 34716 6 3 1

Silvies A EC 8789 5 2 8

Slide Creek A BM 25540 32 5 27

Smoky A BM 9264 1 1 0.11

Snow Mountain A EC 12362 26 7 2

Snowshoe A BM 6386 2 1 0.20

Spring Creek A PC 57772 60 6 39

Star Glade A PC 1999 0 0 0

Story-Fry A EC 619 3 2 0.22

Sugarloaf A 39879 43 10 6

Sullens V PC 46426 316 7 171

Summit Prairie A PC 25369 42 7 15

Upper Middle Fork A BM 54808 218 13 338

Van A 6684 15 3 11

War Canyon A BM 541 0 0 0

West Malheur A 22938 52 4 7

West Myrtle A EC 8541 25 4 6.50

Williams Pasture A BM 1146 0 0 0

Windy Point V BM 1306 0 0 0

Wolf Mountain A 31608 28 6 12

York A BM 929 5 2 1

Table 75. Allotment use and invasive plants

Allotment 

Use Allotment Acres

Percent of Total 

Forest Land Infested Acres

Percent of Allotment 

Acreage Occupied by 

Invasive Plants

Active 1,614,599 95.01% 1682 0.10%

Vacant 80,629 4.74% 442 0.50%

Total 1,695,228 99.75% 2124 0.13%

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Grazing and Invasive Plant Spread

Seed dispersal for many species, including diffuse knapweed, Canada thistle, scotch thistle, and whitetop, 

is largely by wind (Bullock and Clarke 2000, CWMA 2007, USDA Forest Service 2012a, USDA Forest 

Service 2012b, Zouhar 2004); however, these seeds and seeds of other invasive plants present in the 

Malheur National Forest range allotments can also be spread by vehicles, water transport, and animals 

(fur, hooves, and gastrointestinal ingestion and redistribution).

In areas where invasive species are interspersed with desirable forage, it is likely that seeds would either 

attach to fur or mud on hooves or be ingested and dispersed in feces. Some weed seeds are destroyed 

within the gastrointestinal tract; however, leafy spurge and spotted knapweed seeds can pass through 

sheep, goats, and mule deer and some of the seeds remain viable (Lacey et al. 1992). Leafy spurge seed 

was shown to be viable in feces 10 days post ingestion by mule deer. Long-lived seeds and hard seeded 

species of dicots and grasses consumed by grazers have been reported to survive passage through 

gastrointestinal tracts of cows and grizzly bears (Janzen 1984).

Cattle congregate along fence lines and around water developments, which can result in disturbed areas 

for plant species establishment. More than half the acreage five feet on either side of mapped fences in the 

GIS data set overlap with invasive plant infestations. This indicates a high potential for weed spread from 

cattle trailing along fence lines. Five water developments mapped in the GIS data set are within 25 feet of 

invasive plant infestations. Not all fence lines and water developments are mapped, so these are likely to 

be low estimates. 

3.8.3 Environmental Consequences 

Introduction

This section addresses the effects of the alternatives on grazing allotment administration and range 

resources (livestock and forage). The effect of invasive plant treatments on range administration is not a 

significant issue identified in Chapter 1. 

As project design feature N2 suggests (Table 10), range administration adjustments to protect range 

resources from invasive plant treatments could be necessary and would be addressed through existing 

administrative mechanisms, such as grazing allotment management plans and grazing permits. Potential 

adjustments that could be used to address invasive plants or potential introductions may include:

♦ Changes in livestock movement patterns that require additional labor or may reduce outputs for 

certain allotments 

♦ Alterations to season of use (length, turn-on, turn-off, etc.) and intensity of use that could reduce 

outputs and could include resting of pastures resulting in reduction of livestock use and output 

♦ Passive restoration of native plant communities could require allotment resting for one to two 

seasons potentially reducing livestock use and output. In some cases, fencing can be used to 

mitigate impacts. 

♦ Delayed reintroduction of livestock following wildfires resulting in reduced livestock use and 

outputs over time

The effects spatial area is the project area and nearby private, state and other federal lands. The time 

frame of the analyses includes the past 20 years and the next 15 years. Invasive species have been present 

on the Forest for over 20 years with variable management efforts. Over this time, the recognition of the 

ecologic implications of invasive plants has grown, so older documents, such as the Land Resource 

Management Plan, do not recognize specific details of invasive plant management.

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Effects Common to Action Alternatives on the Range Resource by Treatment Method

Herbicide Use

Compared to the no-action alternative, more chemicals would be used in the environment while 

effectively treating invasive species in the three action alternatives. The potential for a spill to occur 

during herbicide operations would be greater than under the no-action. Minimal to no effects are 

anticipated to grazers or operators due to strict adherence to label handling directions and spill 

containment protocols.

Livestock grazing is a known cause of invasive plant spread (DiTomaso 2000). Removal of livestock 

would reduce one of the vectors of invasive species spread, but this is not proposed in this project. No 

studies have rigorously tested this hypothesis or the effects of wild ungulates in spreading non-native 

plant species. Scientific support is growing for the hypothesis that large herbivores facilitate the invasion 

and establishment of invasive plants; however, substantial controversy exists about the specific process in 

time and space and the associated predictions of effects. See the Introduction to Cumulative Effects 

section in chapter 3.1.5 for a discussion of the relative influence of grazing compared to other potential 

vectors on the Malheur National Forest.

Label Restrictions Relative to Range

Table 77 describes the herbicide label restrictions relevant to grazing management. 

Table 76. Herbicide label restrictions relevant to range

Herbicide Restriction Remarks

Aminopyralid Grasses treated in the preceding 18 months CAN NOT be moved 

off the farm or ranch where harvested unless allowed by 

supplemental labeling.

Hay treated in the preceding 18 months CAN NOT be used for 

silage, haylage, bailage and green chop unless allowed by 

supplemental labeling.

Do not use hay or straw from areas treated within the preceding 18 

months or manure from animals feeding on treated hay in compost.

Do not use grasses treated within the preceding 18 months for 

seed production.

May be used up to the water’s 

edge.

Chlorsulfuron None for grazing or range administration --

Clopyralid Redeem: Do not graze treated areas until plants are dry and no 

longer palatable to livestock. Withdraw livestock from grazing 

treated grass at least 3 days prior to slaughter.

See label for cropland grazing 

restrictions post treatment in 

pastures. Redeem: Herbicide 

application may increase 

palatability of treated plants.

Glyphosate None for grazing or range administration Roundup®

: ingestion of this 

product or large amounts of 

freshly sprayed vegetation 

may cause temporary 

gastrointestinal irritation.

Imazapic Plateau: None.

Plateau DG: Do not use on areas to be grazed.

--

Imazapyr Arsenal: none.

Chopper: none.

Stalker: none.

--

Metsulfuron 

methyl

None for grazing or range administration --

Sethoxydim None for grazing or range management. --

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Herbicide Restriction Remarks

Sulfometuron 

methyl

None for grazing or range management. --

Picloram Tordon 101/22K/K: allow one week of grazing/feeding in nonexposure area before moving livestock onto broadleaf cropland. 

Tordon 22K: herbicide application may increase palatability of 

treated plants. Don’t graze treated areas until plants are dry and no 

longer palatable. Meat animals grazing for up to 2 weeks after 

treatment should be removed from treated areas 3 days prior to 

slaughter.

--

Triclopyr Garlon 4: Do Not allow lactating dairy animals to graze treated 

areas until the following growing season after treatment.

Do not harvest hay for 14 days after treatment.

Withdraw livestock from grazing treated areas at least 3 days 

before slaughter.

Treating pastures that are currently in rest due to grazing management rotations would eliminate any 

potential effects. If movement of livestock is not possible and pastures or allotments require treatment 

while animals are present, all label use restrictions would be followed in addition to pdfs that require 

permittee notification prior to any proposed application. In addition, timely notification and coordination 

would occur during annual operating instruction/plan meetings and by posting/signing areas to be treated 

prior to and after treatment (R6 FEIS 2005).

Herbicides that may adversely affect grazing animals (clopyralid, triclopyr, and picloram) have label 

restrictions on grazing after herbicide treatment (table 77). These herbicides would have more potential 

for adverse effects to livestock than the first-choice herbicides: however, use of label restrictions and pdfs

would minimize potential effects.

Other Treatment Methods

Manual treatments would be used in small areas and would not likely affect livestock, except to remove 

the invasive plants, including possibly toxic species, and potentially increase the amount of forage.

Mechanical treatment would most likely involve mowing along roadsides. Mechanical treatments would 

not likely affect livestock use. It would temporarily remove invasive plants, but would not eliminate them. 

Biological controls would reduce amounts of invasive plants and allow for native species to expand.

Cultural controls would be used in very small areas and would not likely affect livestock.

An actual reduction in Animal Unit Month (AUM) attributed to invasive plant management cannot be 

quantified at the project scale due to unavailable data, variability between allotments, and the ongoing 

process of Allotment Management Plan revision. All action alternatives would include restoration, where 

needed, to facilitate recovery of native plants.

Early Detection/Rapid Response

In addition, new or previously undiscovered infestations could be treated using the range of methods 

described in this EIS. An early detection/rapid response (EDRR) approach is needed because 1) the 

precise location of individual target plants, including those mapped in the current inventory, are subject to 

rapid and/or unpredictable change and 2) the typical NEPA process does not allow for rapid response to 

new detections since infestations may grow and spread into new areas during the time it usually takes to 

prepare NEPA documentation. The intent of the project’s early detection/rapid response approach is to 

treat new infestations when they are small so that the likelihood of successful treatment is maximized and 

adverse effects are minimized. 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

The action alternatives would allow treatment of new detections (EDRR), as long as the treatment method 

is within the scope of this EIS. The implementation planning process identified in Chapter 2 would be 

used with each new infestation site to determine treatment. The pdfs have been set up to provide layers of 

caution so that even if the exact locations are not known, the potential for adverse effects are minimized. 

Implementation of pdfs and herbicide-use buffers and treatment limits would work together to provide 

sideboards to deal with the uncertainty of treating new sites (USDA Forest Service 2008b).

Direct, Indirect, and Cumulative Effects of Alternative A

Implementation of alternative A means there would be no treatment and no direct, indirect, or cumulative

effects on range. Invasive plants would continue to degrade livestock forage and could spread into 

neighboring rangelands. Alternative A would not meet the purpose and need or comply with current 

management direction relative to invasive plants and range. 

Direct and Indirect Effects of Alternative B

Effective invasive plant treatments on grazing allotments would help retain and increase the native 

vegetation that provides livestock forage. Livestock exposure to toxic weed species would be reduced.

First-choice herbicides proposed for alternative B are expected to have no adverse effects to livestock.

Other herbicides that may be used have some potential impacts on livestock as discussed above but risks

would be minimized by pdfs that keep rates low and coordination with permittees that ensures label 

requirements for moving livestock during spraying are followed (table 10, N Group).

There are no restrictions on livestock use for the first-choice herbicides. There are restrictions on uses of 

grass, hay, and straw sprayed with aminopyralid, but none for livestock grazing. There are grazing 

restrictions with use of clopyralid, imazapic, picloram, and triclopyr. Project design features would be 

adequate to prevent effects to livestock. 

Given the relatively short half-lives, the low rates of application proposed, and the minimal effects of the 

first-choice herbicides proposed under alternative B, it is not likely that repeated applications in the same 

areas would have effects to livestock. Herbicide risk assessments considered chronic exposure, and even 

under those scenarios, effects were below the established thresholds.

Management options include timing and duration of grazing, patterns of use, requirements to use only 

weed-free feed, and the potential of quarantine periods if these activities are implemented on allotments.

Operators may experience a slight loss of grazing opportunity; however, many of the grazing strategies 

within allotments have deferred rotations and by focusing invasive weed treatments to the pastures during 

the resting phase would avoid most or all potential impacts to operators.

Alternative B would be more effective at reducing invasive plants (80 percent) than the other alternatives 

and restoration may begin sooner, so benefits of invasive weed treatment would be experienced earlier 

under alternative B.

Direct and Indirect Effects of Alternative C

This alternative would result in fewer acres of herbicide use; no broadcast herbicide application; no 

herbicide use within 100 feet of streams and within 200 feet of wells; and no use of Picloram. Impacts to 

livestock operators would be similar to those described in alternative B. The potential for exposure of 

livestock and livestock managers would be slightly decreased as less chemical would be used within 

riparian areas. Livestock would not be exposed to effects from picloram.

Manual and mechanical treatments would increase. Approximately 1,389 acres would be treated solely 

with non-herbicide methods. Non-herbicide treatments would not affect livestock, but treatments in 

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riparian areas where cattle congregate could result in short periods of bare soils that could result in 

increased erosion and sedimentation with cattle use. As noted in chapters 3.4 and 3.5, sediment delivery 

from this project would be minimal. 

Direct and Indirect Effects of Alternative D

Compared to alternative B, more chlorsulfuron, glyphosate, metsulfuron methyl, and picloram, would be 

used instead of aminopyralid. The herbicide use rates, pdfs, and herbicide-use buffers associated with 

aminopyralid would become non-applicable. Alternative D would have less broadcast spraying and more 

spot spraying, so there would be less potential for damaging or destroying non-target vegetation and 

forage. Alternative D would use picloram on 27 acres. Picloram has the potential for adverse effects to 

livestock, but project design features and label restrictions would lower risks. When picloram is used, 

grazing would be eliminated during herbicide treatment until treated plants are dry and no longer 

palatable. Meat animals grazed for up to two weeks in areas treated with Tordon 22k should be removed

three days prior to slaughter. Project design features are adequate to prevent harmful herbicide exposure 

to livestock. Permittees would be notified of herbicide application and would be required to move cattle 

to follow pdfs and herbicide label restrictions.

Cumulative Effects of Action Alternatives

Long-term effects of the action alternatives would be beneficial to range resources. Implementation of 

action alternatives would gradually reduce the extent and abundance of invasive plant species on range 

allotments. Coordination with neighbors would increase overall weed control effectiveness because 

treatments would reduce invasive infestations on National Forest system land, weed seeds, and invasive 

plants spreading onto neighboring lands. As the spread of invasive species on National Forest System 

lands decreases, the likelihood of weeds spreading onto private, tribal, state, and lands of other 

ownerships would also decrease. Over time, this could reduce herbicide use on National Forest and 

adjacent land ownerships.

Since grazing allotments cover essentially the entire Malheur National Forest, any activities that produce 

ground disturbance on the Forest may increase the spread of invasive plants and reduce the amount of 

forage available for livestock. Therefore, although treatments proposed under alternative B would reduce 

invasive infestations and all management activities follow guidelines to prevent or reduce the spread of 

weeds, new infestations or spread of remaining infestations would continue to occur. As a result, 

herbicide applications would likely continue to be needed over time. We expect, however, that after 

current infestations are reduced or eradicated with initial treatments, follow-up treatments and treatments 

of new infestations would require less herbicide over smaller areas. Herbicide treatment of invasive 

species on lands near or adjacent to the Forest would likely continue, and amounts, types, and methods of 

application cannot be anticipated.

The action alternatives all include the EDRR component allowing treatment of newly detected 

infestations; however, other landowners may or may not have the flexibility, funds, or staffing to 

implement EDRR. Because the extent of future treatment programs on lands of other ownerships is 

unknown, the effect this would have on invasive plants migrating onto National Forest System lands is 

also unknown. 

Table 28 and table 29 list projects and activities that are ongoing or foreseeable on the Malheur National 

Forest. The other projects do not involve weed treatment or herbicide use. Since no direct or indirect 

effects to livestock or range management are expected, this project would not add to any effects from 

those projects and activities. Therefore, there would be no adverse, cumulative effects to range resources 

from this project. In the long term, all action alternatives would favor re-establishment of desirable plant 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 3

communities within the project area and across ownership boundaries, especially where coordinated 

treatments occur.

3.9 Recreation and Special Places

3.9.1 Introduction

Introduction of invasive species can have notable impacts on recreational resources and activities. These 

impacts may have a range of effects depending on species, plant architecture, plant chemical composition, 

and/or associated environmental alteration.

Invasive species may be introduced at developed campgrounds, dispersed camp sites, trailheads, snow 

parks i.e., recreation parking areas for unloading/loading snow machines, boat launch areas, visitor 

centers, or interpretive sites. Even more insidious is when invasive species are introduced along trails or 

at remote wild and scenic, wilderness, or other back country areas. In these special designated areas,

detection, mapping, and treatments may often present a greater challenge. Wilderness or Wild River 

special areas typically prohibit use of motorized equipment for treatment, and often may restrict other 

treatments commonly used in other areas, such as biological control.

This section of the EIS discusses potential herbicide effects on people and animals when used in areas 

frequented by recreationists, such as campgrounds, dispersed camping sites, interpretive sites, and trail 

systems. It also addresses the effects of herbicide use changing the wild character of roadless areas 

(IRAs), Wildernesses, Wild and Scenic Rivers (WSR), National Scenic Areas (NSA), National Scenic 

Trails (NST), and Research Natural Areas (RNA).

The public has expressed concerns about herbicide use in these special areas, as well as preventing or 

controlling invasive species vectors associated with recreational uses, including OHV travel, recreation 

stock use, and other traditional recreation uses, such as site seeing, recreational driving, hiking, camping, 

and picnicking.

The Forest Service uses a nationally recognized classification system called the Recreational Opportunity 

Spectrum (ROS) to describe different recreation settings, opportunities, and experiences that help guide 

recreation management decisions and activities on National Forest lands (USDA Forest Service 1986).

ArcGIS 9.3.1 geographic information system (GIS) was used to analyze the proposed activities in regards 

to recreation use and facilities, dispersed recreation sites, and the recreation opportunity spectrum (ROS) 

classes within the project area. The recreation analysis considered the area within the project area, unless 

otherwise noted. Estimates of recreation use are derived from the National Visitor Use Monitoring

(NVUM) inventories done on the Malheur NF in 2003-04 and 2009-10. These inventories are conducted 

for all national forests on a 5-year cycle. These two NVUM surveys are the basis for estimating present 

recreation use and demand and for projecting the growth of recreation use on the Malheur NF.

Data Gaps and Limitations

The NVUM inventory process has limitations that should be understood. Visitor use is measured at 

specific predetermined recreation sites falling into high, medium, or low use categories. Small or 

infrequently used sites are not included in the inventories. However, they may represent a significant 

contribution to a given recreational pursuit and not be adequately represented in the data. In addition, 

participation is voluntary and some visitors, or activities, may better lend themselves to interviewing. For 

example, a party pulling a pack string may be less inclined to participate because the disruption may 

provide opportunity for the string to get into trouble. Consequently, the data is collected from a segment 

that is willing or able to participate and extrapolated to represent visitor use as a whole.

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Invasive species survey data for Wilderness Areas, Wild portions of the Wild and Scenic Rivers, and for 

the Scenic Area are limited. Invasive species surveys in these more remote areas with limited access 

makes surveying for invasive species a more time and funding intensive workload.

3.9.2 Affected Environment

Recreation Uses

Recreation use was inventoried on the Malheur National Forest during the years 2004 and 2010. There 

was a dramatic decrease in the total number of forest visitors between the two sample dates. In 2004,

Forest visits were estimated at 422,666 person days compared to only 261,400 person days in 2010, 

nearly a 40% decline in the number of forest visits between the two sample years.

The NVUM system was used to capture the data. The Recreation Report provides detailed data showing

that hunting is a major use on the Forest, along with driving for pleasure, camping, hiking, relaxing and 

viewing wildlife. Most of these activities necessitated the use of motorized vehicles to access all or part of 

the activity. This consistent association between recreation activities and motorized use is an important 

consideration for successful invasive species management on the Forest.

Wilderness

The Forest contains two wilderness areas: Strawberry Mountain (68,700ac.) and Monument Rock (12,620 

acres, see maps in the recreation report). The Wilderness Act prohibits the use of motor vehicles, 

motorized equipment, motorboats, landing of aircraft, use of mechanical transport, and structures or 

installations within wilderness. These restrictions limit many of the major invasive species vectors.

However, recreators, pets, pack stock, livestock grazing, wildlife, and natural seed dispersal have 

successfully introduced invasive plants into these areas.

Current invasive species surveys have documented 2.2 acres of invasive plant infestations at 8 locations in 

the wildernesses. The wilderness surveys are not considered complete and ongoing awareness and 

additional surveying will be essential for managing invasive species within these special areas. In 

addition, invasive plant sites occur at or near some of the wilderness trail heads and on roads leading to, 

and adjacent to, the wilderness areas. It is likely more infestations will arise in the future. Higher use 

levels, such as near trail heads, along trails, in riparian areas, in recent burns, or in concentrated use 

campsites are known vectors for spread (see Chapter 3.1).

Wild and Scenic Rivers

Two congressionally designated wild & scenic rivers (WSR) lie within the Forest, the Malheur River 

WSR and the North Fork of the Malheur WSR (see maps in the recreation report). The Malheur River 

WSR is 12 miles long with 6 miles designated as Wild and 6 miles designated as Scenic. The WSR 

corridor is comprised of 2,961 acres designated wild and 797 acres designated scenic totaling 3,758 acres.

The North Fork of the Malheur River WSR is designated a scenic WSR for 22.9 miles with the corridor 

encompassing 7,034 acres. ) The Malheur National Forest LRMP, as amended by their respective Malheur 

and North Fork Malheur WSR Plans, generally prohibits motorized use off Forest system roads and trails 

within both the Scenic and Wild boundaries of both rivers. These motorized access restrictions will aid in 

reducing the risk of introducing invasive plant species. There remain other vectors associated with 

recreational uses (e.g., dispersed campsites, hiking, horseback riding, and livestock grazing) in some 

areas, which may serve as vectors for invasive plant species. Current invasive plant surveys in the WSRs 

indicate infestations totaling 0.9 acres. Additional infestation will most likely be associated with areas of 

heavier use, such as near trail heads, along the river riparian zones, along trails, in concentrated 

campsites, and in recent burns.

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Inventoried Roadless areas (IRA)

Inventoried Roadless Areas (IRA) were identified under the 2001 Roadless Area Conservation Rule.

Nineteen IRAs are designated on the Malheur National Forest (maps in the recreation report). These IRAs 

have a total of 188,000 acres of National Forest System land. The LRMP recognizes these special areas as 

combined portions of the Semi-Primitive Non-Motorized, Semi-Primitive Motorized, and Wild and 

Scenic River Management Areas (MAs 10, 11, and 22). The motorized vehicle restrictions in portions of 

the IRAs are somewhat similar to restrictions in Wild and Scenic Rivers corridors and Semi-Primitive 

Non-Motorized management areas. This will aid in reducing the likelihood of invasive species 

introduction and spread within IRAs via motorized recreation activities. The Semi-Primitive motorized 

IRA would have reduced motorized access and hence less potential for infestation spread by motor 

vehicle access, but not quite to the extent enjoyed by Wilderness and Wild Rivers areas. Current IRA 

invasive plant infestations total 25 acres comprised of 50 known locations. Additional infestations will 

most likely occur in areas receiving heavier visitor use, such as along trails, in riparian zones, in 

concentrated campsites, and in recent burns.

Table 77. Acres of Inventoried Roadless Areas

Inventoried Roadless Areas Acres

Aldrich Mountain 4,924.72

Baldy Mountain 6,415.93

Cedar Grove 113.98

Dixie Butte 12,207.98

Dry Cabin 12,273.64

Flag Creek 7,716.41

Fox Creek 5,845.93

Glacier Mountain 19,568.38

Greenhorn Mountain 15,927.16

Jumpoff Joe 3,889.62

Malheur River 7,282.54

McClellan Mountain 21,213.02

Myrtle Silvies 11,678.69

Nipple Butte 11,353.90

North Fork Malheur 18,068.60

Pine Creek 5,461.57

Shaketable 6,763.89

Silver Creek 7,948.20

Utley Butte 9,699.11

Total IRA Acreage 188,353.26

National Scenic Areas

The Malheur National Forest has one National Scenic Area, the Vinegar Hill – Indian Rock Scenic Area 

comprised of 17,234 acres (see map in recreation report). The management direction for Scenic Areas is 

to manage this area to preserve and protect outstanding natural esthetics. Current known invasive plant 

infestations total 2.4 acres. Motorized travel is restricted within the NSA to winter use only. As with other 

special areas that prohibit or restrict motorized access, which is a major source of invasive introductions, 

the likelihood of introducing or spreading invasive species is commensurately reduced. Additional 

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infestations will most likely occur in areas receiving heavier visitor use, such as along trails, in riparian 

zones, in concentrated campsites, and in recent burns.

Other Semi-Primitive Areas

Recreation opportunities on the Malheur NF are focused toward meeting forest management objectives as 

identified in the Malheur LRMP. However, the rise in motorized activity over the past two decades 

represents a substantial change with profound potential toward affecting opportunities within the full 

(recreation opportunity spectrum) ROS. An increase in motorized activity in the more primitive ROS 

holds the potential for introducing and spreading invasive species into less frequented areas, hence 

decreasing the likelihood of implementing EDRR (early detection/rapid response).

Maintaining a road infrastructure in the face of shrinking budgets is increasingly problematic and has 

resulted in an increase in the number of “challenging” and rugged roads on the Forest, e.g., Deer Creek or 

Crane Crossing. In addition, management presence has diminished generally across the Forest as budgets 

for field going personnel and signing has diminished. When considered in combination, the extensive 

road system, predominant importance of road based recreation activities, and low Forest Service presence 

increase the opportunity for invasive species establishment and overall diminish the success of 

implementing an effective EDRR strategy. Protection of primitive areas is of particular interest and 

concern.

3.9.3 Environmental Consequences

Introduction 

Table 79 below shows the number of invasive plant sites currently within recreation resource areas and 

how many acres are proposed for herbicide treatment based on the current inventory. 

Table 78. Invasive Plants Sites that may be Treated by Recreation Resource Area: No Action Compared to 

Action Alternatives

Recreation Resource Areas Number of known 

sites

Acres Alternative

A

Acres Action 

Alternatives

Wilderness Acres 8 0 2.2

Wild and Scenic Rivers 15 0 0.9

Scenic Areas 4 0 2.4

Other Semi-Primitive Areas (ROS) 15 0 4.2

IRAs 50 0 61.2

Within 500 meters of developed recreation sites 108 0 121

The analysis area encompasses these types of recreation areas.

Alternative A – No Action

Under the no-action alternative, there would be no direct effects to the Malheur National Forest recreation 

resource areas of Wilderness, Wild and Scenic Rivers, Scenic Areas, Semi-Primitive Non-Motorized ROS 

areas, IRAs, and developed and dispersed recreation sites.

The current infestations would most likely continue to expand and new infestation sites would establish.

Over time, it would be expected that the Wilderness character and values would be negatively affected by 

expanding infestations. The Wild and Scenic River Outstanding Remarkable Values (ORV) would be 

negatively affected by expanding infestations. The Scenic Area outstanding natural esthetics would be 

negatively affected by expanding invasive species infestations. Over time, the SPNM and IRA area’s 

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natural environments would be negatively affected by expanding infestations. This degradation would 

further reduce the natural beauty and character of the SPNM and IRA areas. 

Dispersed recreation also occurs throughout the Malheur National Forest. Dispersed recreation includes a 

wide variety of activities including hunting, fishing, driving for pleasure, firewood cutting, horseback

packing and riding, road and mountain biking, camping, picnicking, wild plant collecting (mushrooms, 

camas, ferns, etc.), and OHV riding. Over time, it would be expected that the scenic and natural appearing 

forest character of dispersed recreation sites would be impaired depending on the particular recreation 

activity and the nature of the invasive infestation.

Direct and Indirect Effects of Action Alternatives

All action alternatives provide for some level of effective invasive species treatments. These alternatives 

differ in that alternative C imposes strict limitations on herbicide application and alternative D, while 

similar to alternative B, would not provide for application of aminopyralid. Alternative C would eliminate 

broadcast spraying, eliminate picloram and prohibit herbicide use within 100 feet from creeks, lakes, 

ponds, and wetlands.

Wilderness Areas

Invasive species would continue to be pulled by hand or hand tools where practical. Cultural, mechanical,

and motorized control methods would not be utilized in wilderness areas. Herbicide application would be 

used in accord with the pdf D1 using non-motorized methods, such as spot spraying with backpack or 

mule packed application equipment.

Infestations that would affect wilderness character and values would be evaluated for treatment and if 

suitable given a high priority for treatment. New sites would be evaluated for suitable treatment(s) using 

the EDRR process. In order to conduct treatments other than hand pulling a minimum decision analysis 

would be conducted and documented.

The use of herbicides in wilderness areas may reduce the wilderness experience for some users in the 

short term, but active treatment provides the best protection of wilderness character and values. The 

purpose and need for invasive plant treatment is not driven primarily by convenience or administrative 

cost. In addition, invasive plants have an adverse effect by disrupting natural processes. Invasive species 

may alter native plant communities and have indirect effects with wildlife species that rely on the native 

plant communities. Invasive species may also alter fire regimes that may ultimately alter wilderness 

ecological processes.

By following the pdfs, it is anticipated invasive species infestations would be reduced or eliminated, and 

the rate of spread retarded. This would result in recovery or protection of wilderness character and values.

It is likely that most sites discovered in wilderness in the future would be relatively small infestations and 

the effects of treatment would be minor. The visual impact of the short-lived blue dye may result in visual 

impacts to the recreation experience of some visitors. However, these effects would be short term and 

limited to the vicinity of the treated site. Compared with implementing alternative B, alternatives C and D 

would have less cost effectiveness (see Chapter 3.1.5).

Wild and Scenic Rivers

Infestation sites in the Wild and Scenic River corridors would be treated. Depending on the chosen 

alternative, the treatment method would vary among alternative by the method and herbicide used.

Compared with implementing alternative B, alternative D is estimated to decrease cost effectiveness.

Under alternative C, no herbicide would be used within 100 feet of streams (treatment there would consist 

of hand pulling, biological, cultural, and mechanical methods). Alternative C would be less effective 

overall in treating infestations (see Chapter 3.1.5).

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The use of herbicides in Wild and Scenic Rivers may reduce the ‘wild’ experience for some users in the 

short term especially in the Wild designated corridor, but active treatment provides the best protection of 

the outstanding and remarkable values. Treating Wild and Scenic River infestations would have shortterm adverse effects by introducing human manipulation, but would result in long-term beneficial effects 

to wilderness character and values by restoring natural conditions.

By utilizing the appropriate pdf treatment methods, it is anticipated invasive species infestations would be 

eliminated, reduced, and the rate of spread retarded. This would result in recovery or protection of Wild 

and Scenic ORVs. It is likely that most sites discovered within the Wild and Scenic River corridors in the 

future would be relatively small infestations and the effects of treatment would be minor. The visual 

impact of the short-lived blue dye may result in visual impacts to the recreation experience of some 

visitors. However, these effects would be short term and limited to the vicinity of the treated site.

Scenic Areas

Infestation sites in the Scenic Area would be treated by hand pulling, mechanical, motorized (where 

accessible), cultural, and herbicide application. Depending on the chosen alternative, the treatment 

method would vary among alternative by the method and herbicide used. Under alternative C, no 

herbicide would be used within 100 feet of streams, including Wild and Scenic Rivers.

By following the pdfs, it is anticipated invasive plants infestations would be reduced or eliminated. This

would result in recovery or protection of the outstanding natural esthetics of the Scenic Area. It is likely 

that most sites discovered within the Scenic Area in the future would be relatively small infestations and 

the effects of treatment would be minor. The visual impact of the short-lived blue dye may result in visual 

impacts to the recreation experience of some visitors. However, these effects would be short term and 

limited to the vicinity of the treated site.

ROS Semi-Primitive Non-Motorized (SPMN) and Inventoried Roadless IRAs

Infestation sites in the SPMN and IRA areas would be treated by hand pulling, mechanical, motorized 

(where accessible), cultural, and herbicide application. Depending on the chosen alternative, the treatment 

method would vary among alternative by the method and herbicide used.

By following the pdfs, it is anticipated invasive species infestations would be reduced or eliminated, and 

the rate of spread retarded. This would result in recovery or protection of the native species. It is likely 

that most sites discovered within the SPNM and IRA areas in the future would be relatively small 

infestations and the effects of treatment would be minor. The visual impact of the short-lived blue dye 

may result in visual impacts to the recreation experience of some visitors. However, these effects would 

be short term and limited to the vicinity of the treated site.

Recreation Sites

Infestation sites in and near recreation sites would be treated by hand pulling, mechanical, motorized 

(where accessible), cultural, and herbicide application. Depending on the chosen alternative, the treatment 

method and herbicide used would vary. It is estimated using alternative C and D would be less effective 

overall in treating infestations due to the limitations on herbicide type and allowed use.

By following the pdfs, it is anticipated invasive plant infestations would be reduced or eliminated. This

would result in recovery or protection of the scenic and natural appearing forest character. It is likely that 

most sites discovered within and near the recreation sites in the future would be relatively small 

infestations, and the effects of treatment would be minor. The visual impact of the short-lived blue dye 

may result in visual impacts to the recreation experience of some visitors. However, these effects would 

be short term and limited to the vicinity of the treated site. Recreation sites undergoing treatment would 

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be marked and forest visitors would be discouraged from recreating near recently treated sites and may 

choose to relocate to alternative recreation sites. However, this effect would be of short duration.

Dispersed Recreation

Infestation sites in and near dispersed recreation sites would be treated by hand pulling, mechanical, 

motorized (where accessible), cultural, and herbicide application. Depending on the chosen alternative,

the treatment method and herbicide used would vary. It is estimated using alternative C and D would be 

less effective overall in treating infestations due to the limitations on herbicide type and allowed use.

Dispersed recreation occurs throughout the Malheur National Forest. Dispersed recreation includes a wide 

variety of activities including hunting, fishing, driving for pleasure, firewood cutting, horseback packing 

and riding, road and mountain biking, camping, picnicking, wild plant collecting (mushrooms, camas, 

ferns, etc.) and OHV riding. Dispersed recreation most likely will occur in all of the treatment areas to 

some extent. By following the pdfs, it is anticipated invasive species infestations would be reduced or 

eliminated, and the rate of spread retarded. This would result in recovery or protection of the scenic and 

natural appearing forest character. It is likely that most sites discovered within and near dispersed 

recreation sites in the future would be relatively small infestations and the effects of treatment would be 

minor. The visual impact of the short-lived blue dye may result in visual impacts to the recreation 

experience of some visitors. However, these effects would be short term and limited to the vicinity of the 

treated site. Dispersed recreation sites undergoing treatment would be temporarily marked and forest 

visitors would be discouraged from recreating near recently treated sites. Visitors may relocate to 

alternative recreation sites. This impact would be of short duration.

Cumulative Effects

There are some foreseeable projects in recreation special uses that most likely will have additional 

invasive species effects. In 2011, the Forest completed implementation of the 2007 revised OutfitterGuide policy. It is likely the Malheur National Forest will issue a minor number of special use permits for 

providing recreation services on Forest lands. The public has expressed interest or obtained temporary 

special use permits for activities, such as backpacking trips in the wilderness areas, ice climbing, road 

biking tourism, mountain biking tours, hunting, and horse day rides. As with current recreational 

activities, these additional services have the potential to act as invasive species infestation vectors.

It is also likely the Malheur National Forest will implement the 2005 Travel Management Rule in the 

foreseeable future. Two likely effects of addressing former Chief Bosworth’s four threats including 

“unmanaged recreation” (http://www.fs.fed.us/projects/four-threats/) are an increased use of OHVs on 

some Forest System roads and a dramatic reduction in cross-country OHV use. It is likely any increased 

recreation use on roads will commensurately increase the likelihood of invasive species infestations.

However, eliminating uncontrolled cross-country travel is anticipated to significantly reduce the risk of 

invasive species infestations along closed roads and in the general forest area (GFA) no longer accessible 

to unmanaged OHV travel. Heightening public awareness of common pathways for invasive plant spread 

will help reduce that risk.

Because the effects of invasive plant treatments on recreation and scenic resources are minimal, limited, 

localized, and short-term, there is very little chance this project would accumulate with effects brought on 

by past, present, or future management activities. 

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Table 79. Summary of Potential Cumulative Effects on Recreation

Foreseeable 

Project Category Potential Cumulative Effects on Recreation

Vegetation and 

Fuels 

Management 

Projects

Invasive plant treatments on the Forest may overlap in time and space with vegetation 

management projects. Vegetation management plans include measures to protect recreation 

and scenic resources, where applicable. Impacts from invasive plant treatments to recreation 

and scenic resources are limited to minor, short term visual effects and temporary closing of 

recreation sites. Measures protect the public from herbicide exposures that would exceed 

thresholds of concern. The impacts of invasive plant treatment are not likely to add to vegetation 

management impacts on recreation and scenic resources in any discernible way.

Allotment 

Management 

Plans and Grazing

Projects

Impacts from invasive plant treatments to recreation and scenic resources are limited to minor, 

short term visual effects and temporary closure of recreation sites. Measures protect the public 

from herbicide exposures that would exceed thresholds of concern. Less than 1% of the acres 

in active allotments would be treated in a given year. The impacts of invasive plant treatment 

are not likely to add to grazing impacts on recreation and scenic resources in any discernible 

way.

Recreation 

Projects

Invasive plant treatments on the Forest may overlap in time and space with recreation projects. 

Impacts from invasive plant treatments to recreation and scenic resources are limited to minor, 

short term visual effects and temporary closing of recreation sites. Measures protect the public 

from herbicide exposures that would exceed thresholds of concern. Invasive plant treatment 

may improve the condition of recreation sites over the long term, contributing to the benefit of 

recreation projects.

Special Uses

Invasive plant treatments on the Forest may overlap in time and space with special use projects. 

Special use permits include measures to prevent the spread of invasive plants and protect 

recreation and scenic resources, where applicable. Major projects like pipelines and road 

realignments include restoration plans. Impacts from invasive plant treatments to recreation and 

scenic resources are limited to minor, short-term visual effects and temporary closures of 

recreation sites. Measures protect the public from herbicide exposures that would exceed 

thresholds of concern. The impacts of invasive plant treatment are not likely to add to the 

impacts of special use projects on recreation and scenic resources in any discernible way.

Aquatic and 

Riparian Habitat 

Restoration

Projects

Invasive plant treatments on the Forest may overlap in time and space with aquatic and riparian 

habitat restoration. Restoration projects are often designed to promote native riparian 

vegetation, which may improve recreation and scenic values. Impacts from invasive plant 

treatments to recreation and scenic resources are limited to minor, short term visual effects and 

temporary closure of recreation sites. Measures protect the public from herbicide exposures that 

would exceed thresholds of concern. Invasive plant treatments will aid in restoration of riparian 

areas and are not likely to add to the impacts of restoration projects on recreation and scenic 

resources in any discernible way.

Travel 

Management Rule 

Implementation

Invasive plant treatments on the Forest will overlap in time and space with the Travel 

Management project. Impacts from invasive plant treatments to recreation and scenic resources 

are limited to minor, short term visual effects and temporary closures of recreation sites. 

Measures protect the public from herbicide exposures that would exceed thresholds of concern. 

Invasive plant treatments are not likely to add to the impacts of Travel Management on 

recreation and scenic resources in any discernible way.

3.10 Archeological Resources

3.10.1 Introduction

This section focuses on archaeological resources. The USDA Forest Service Advisory Council on Historic 

Preservation (ACHP) and the Oregon State Historic Preservation Office (SHPO) have a 2004 

programmatic agreement addressing the management of cultural resources on national forests in the State 

of Oregon. There are several actions that were determined to have no potential to affect historic 

properties, including invasive plant species eradication through the application of herbicides and hand 

removal (including hand tools, such as shovels to dig up roots); recurrent brushing (hand, machine, 

chipping) activities to control vegetation within clearing limits of existing roads, trails, parking lots, and 

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power line corridors; mulching and re-vegetating bare, erosion-prone surfaces, such as cuts and fills; and 

re-introduction of endemic or native floral species into their historic habitats.

Specific treatments that would be classified as actions with no potential to affect cultural resources, and 

therefore subject to Forest Specialist approval, on behalf of SHPO, include the following:

♦ Herbicide Application Methods (selective/hand, spot, and broadcast spray)

♦ Biological agents

♦ Cultural Methods limited to stock grazing

♦ Manual/Mechanical Methods (mowing, weed whipping, and hand pulling)

♦ Manual/Mechanical Methods (grubbing and wrenching) in areas that occur on landslides, flood 

deposits, previously surveyed areas where no archaeological sites occur, skid trails, landings, and 

road cuts and fill.

3.10.2 Affected Environment

The Malheur National Forest lies at the interface between the Columbia Plateau and Great Basin Culture 

Areas, and has been used by native peoples for thousands of years. To date, more than 5,000 

archaeological sites have been identified within the Forest. Site-specific information regarding 

archaeological, historical, and traditional cultural resources is not presented in this document. The 

potential for impact is minor and short term to non-existent so site-specific archaeological information is 

not needed to make an informed decision. Comprehensive Archaeological Resource information is on file 

at the Malheur National Forest Headquarters in John Day, Oregon. 

3.10.3 Environmental Consequences

Introduction

Effects to archaeological resources are assessed for each treatment method: manual, mechanical, cultural, 

and herbicide. Most of the proposed treatment areas have been previously disturbed by present day human 

activities, such as road construction and use (shoulders, cuts and fills). Archaeological sites are sometimes 

bisected by high use areas, such as roads, and thus could overlap invasive plant infestations. Geographic 

areas proposed for treatment include roadsides, quarries, administrative sites, campgrounds, parking 

areas, artificial clearings, meadows, and forested areas. Archaeological resources may occur in all of these 

locations although they may not be affected by the project, depending on the ground-disturbing potential 

of the action.

Alternative A – No Action

No action means that no treatments would take place and thus, no direct, indirect, or cumulative impacts 

on archaeological resources would occur.

Action Alternatives

Most of the treatment methods are not ground disturbing and therefore would have no direct or indirect 

effect on archaeological (cultural) resources. The sole exception may be weed wrenching and grubbing, 

manual techniques that have potential to disturb archaeological resources to a minor degree.

Should any action alternative be implemented, project design features would minimize or eliminate 

potential impacts, which are already of a minor nature. If weed wrenching and grubbing with a shovel is 

planned in areas that are outside landslides, flood deposits, previously surveyed areas, skid trails, 

landings, road shoulders, cut, and fills, the Forest Service archaeologist would have an opportunity to 

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review treatment locations to determine if archaeological resources could be affected. Weed wrenching 

and grubbing techniques will not be used in known archaeological sites. Alternative treatment methods 

will be selected from those that would have low potential to affect archaeological resources. With 

application of the pdf, no significant direct or indirect adverse effects to archaeological resources are 

anticipated, and no contribution to cumulative adverse effects would occur.

Tribal Consultation and Treaty Rights

The Forest Service has communicated by letter with three affected tribes: The Confederated Tribes of the 

Warm Springs, the Confederated Tribes of the Umatilla Indian Reservation, and the Burns Paiute Tribe.

The Forest Service outlined the project details and potential effects to archaeological resources.

The Warm Springs and Umatilla tribes signed treaties with the federal government in 1855 and later 

ratified by Congress. These treaties ceded to the United States legal title to millions of acres of land, and 

reserved and guaranteed certain rights exercised by Indian people to fishing, hunting, gathering roots and 

berries, and other activities. An 1868 treaty with the Burns Paiute Tribe was never ratified by Congress.

Executive Order 12898 directs federal agencies to consider patterns of subsistence hunting and fishing if 

an action will affect fish and wildlife. Under the proposed action, no adverse effects to treaty fishing sites, 

traditional cultural plant gathering areas, traditional plants, or subsistence related activities would occur.

The risk associated with direct herbicide contact and with ingesting contaminated fish, berries, or other 

plants is discussed in Section 3.2 Human Health. Given the types of treatments considered and the project 

design features (pdfs), no direct, indirect, or cumulative adverse effects on tribal or treaty rights would 

occur.

3.11 Specifically Required Disclosures

3.11.1 Irreversible or Irretrievable Impacts

No irreversible or irretrievable uses of resources are associated with this project. This project restores 

native vegetation in areas where non-native plants have been introduced. Herbicide treatments in 

accordance with the alternatives would have relatively short-lived impacts; effects on non-target species 

would be minimized; and effects would not be permanent. No adverse impacts on roadless areas or 

degradation of roadless area quality would occur. 

3.11.2 Long-term Productivity

Soils would be protected in this project and no loss of long-term productivity is predicted. The no-action 

alternative could have negative impacts on long-term productivity if invasive plants become so dense as 

to change soil characteristics, and capacity for restoration to desirable plant communities is lost. The 

natural resources issues associated with this project have been resolved through adherence to project 

design feature (pdfs) that reduce or eliminate the potential for adverse effects. However, some adverse 

effects are inherent to invasive plant treatments and cannot be avoided. These include:

♦ Taxpayers will likely be responsible for the costs of some if not all of the treatments.

♦ Herbicide toxicity exceeding thresholds of concern are unlikely, but possible in the event of a 

large herbicide spill. The pdfs make the potential for a large spill extremely unlikely.

♦ Minor to moderate physical injuries during forestry work are possible.

♦ There may be temporary local effects on some groups of soil micro-organisms that are sensitive 

to certain herbicides. However, the pdfs address the potential for long-term impact to soil 

organisms or productivity. 

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♦ Some common non-target plants are likely to be killed by their close proximity to treatments. 

This is most likely with broadcast herbicide treatments and less likely (but possible) for all other 

treatment methods. The adverse effects of the invasive plants themselves far outweigh the 

potential for adverse effects of treatment.

3.11.3 Energy Requirements and Conservation Potential

No unusual energy requirements are associated with this project. No unusual equipment would be used.

3.11.4 Non-significant Land and Resource Management Plan (LRMP) 

Amendment

An amendment to the Malheur National Forest LRMP is proposed in Alternatives B and C to allow the 

use of aminopyralid. This is a non-significant amendment based on the National Forest Management Act 

implementing regulation for plans prepared under the 1982 Planning Rule (36 CFR 219.17)28. The 

proposed amendment would add one word (aminopyralid) to the existing standard 16 from the R6 2005 

ROD that approved use of ten other herbicides. The risk assessment for aminopyralid was completed after 

a decision was made on the R6 2005 ROD. If the Forest Plan is amended, aminopyralid could be used for 

any invasive plant treatment on the Forest in accordance with this EIS.

Changes to the land management plan that are not significant can result from: 

1. Actions that do not significantly alter the multiple-use goals and objectives for long-term land and 

resource management. 

2. Adjustments of management area boundaries or management prescriptions resulting from further onsite analysis when the adjustments do not cause significant changes in the multiple-use goals and 

objectives for long-term land and resource management. 

3. Minor changes in standards and guidelines 

4. Opportunities for additional projects that contribute to achieving the management prescription. 

Multiple Use Goals and Objectives

The proposed LRMP amendment does not affect multiple use goals and objectives and is intended to help 

the Forest Service achieve these goals on the Malheur National Forest. 

Management Areas 

The proposed amendment does not affect the boundaries or management direction for any management 

areas outlined in the LRMP. 

Standards and Guidelines

The proposed LRMP amendment would approve use of an herbicide, aminopyralid, that is not currently 

listed among the ten approved by the Regional Forester in 2005 (R6 2005 ROD). The Risk Assessment 

(SERA 2007) for aminopyralid demonstrates that use of this herbicide would not pose new or significant 

risks compared to the ten already approved. Table 21 (chapter 3.1.2) shows a comparison between 

28 Under the 2012 Planning Rule (Title 36, Code of Federal Regulations, Part 219–Planning), the responsible official 

may complete and approve the plan revision in conformance with the provisions of the prior planning regulation, 

including the transition provisions of the reinstated 2000 rule (36 CFR part 299, published at 36 CFR parts 200 to 

299, revised as of July 1, 2010). The transition provisions allow the use of the 1982 planning procedures (See CFR 

parts 200 to 299, Revised as of July 1, 2000). See the following hyperlink for the 1982 planning procedures 

http://www.fs.fed.us/emc/nfma/includes/nfmareg.html

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aminopyralid and the herbicides already approved. Aminopyralid is generally a lower risk herbicide, and 

the proposed use would not pose additional risks to human health or the environment. 

Additional Project Opportunities

The proposed LRMP amendment would allow more effective and efficient treatment of invasive plants by 

adding aminopyralid, an herbicide that is very effective on most of the invasive species found in the 

project area. It was developed specifically for wildland use and is effective at low rates. It requires less 

restrictions than most of the other herbicides already approved in the LRMP (for instance it can be 

broadcast sprayed to the water’s edge, which would improve treatment effectiveness and efficiency 

relative to other herbicides). 

3.11.5 Floodplains and Wetlands

Floodplains and wetlands would not be adversely affected by this project. As discussed in chapters 3.4, 

adverse effects to water quality and beneficial uses of water would be negligible. The extent of treatment 

and potential for water contamination is low, and all alternatives are designed to protect water resources. 

3.11.6 Prime Farmlands

No prime farmlands would be adversely affected by this project. There could be a beneficial impact to the 

extent that the alternatives reduce the potential for invasive plant spread from the Malheur National Forest 

to prime farmlands. 

3.11.6 Permits and Licenses

The R6 2005 ROD Standard 15 requires that application of any herbicides to treat invasive plants will be 

performed or directly supervised by a state or federally licensed applicator.

As discussed in Chapter 1.7.2, a Clean Water Act (National Pollution Discharge Elimination System -

NPDES) permit is required for herbicide use that may directly enter streams (streambanks, target 

vegetation hanging over water bodies, treatment sites generally within three feet from a water body). 

Treatments on small portions of riparian infestations (currently mapped or detected in the future) may 

meet the criteria; however, the target invasive species on the Malheur National Forest are not riparian 

dependent. The current mapping is not refined enough to determine whether a permit will ultimately be 

needed; however, NPDES Pesticide General Permits would be obtained prior to implementing any 

treatments in which herbicide could be directly introduced into surface waters.

As discussed in Chapter 2 for the Implementation Planning Process that apply to all action alternatives, 

Form FS-2100-2 Pesticide Use Proposal, would be developed prior to herbicide treatment. In addition, as 

per FSH 2109.14.3, a pesticide use plan would be developed.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 4

Chapter 4. Consultation and Coordination

List of Preparers and Consultation

Archer, Vince – Soils Scientist

Bautista, Shawna – Pesticide Use Coordinator; Herbicide Toxicology Analyst 

Brooks, Paula J – Botanist

Carsey, Kathy S – Invasive Plant Specialist; Range Specialist 

Desser, Rochelle – Region Six Invasive Plant NEPA and Monitoring Coordinator

Laliberte, John – Engineer

McClure, Rick – Archaeologist

Mease, Christopher S – Fisheries Biologist

Moser, Eric – Hydrologist

Rapp, Whitney – Invasive Plant Specialist

Rausch, Joseph H – Invasive Plant Program Manager

Reitz, Scott – Wildlife Biologist

Schultz, Janice N – Writer/Editor

St. John, Rob – Recreation Specialist

Unthank, Amy – Fisheries Biologist

A variety of specialists and managers from the Malheur National Forest and the Pacific Northwest 

Regional Office contributed information. Local invasive plant management information was obtained 

from Oregon State Department of Agriculture and local county invasive plant management staff. 

Consultation is ongoing with Native American Indian tribes, including the Confederated Tribes of the 

Warm Springs, the Confederated Tribes of the Umatilla Indian Reservation, and the Burns Paiute Tribe; 

the United States Fish and Wildlife Service; and the National Marine Fisheries Service. Several 

individuals and interest groups submitted comments during scoping periods in 2006 and 2011 (see chapter 

1).

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List of People to Whom This EIS has been Sent

Agencies and members of the public expressing interest in the project received notice that the Final EIS is 

available on request and on the web http://www.fs.fed.us/nepa/nepa_project_exp.php?project=35614.

Hard copies or CD-ROM versions of the FEIS have been mailed directly to:

Individuals

Dick Artley

John D. George 

Organizations, Industry, and Local Agencies

Executive Director Northwest Coalition for Alternatives to Pesticides

Doug Heiken Oregon Wild

Kristin Ruether Oregon Natural Desert Association

Phil Turrell Rocky Mountain Elk Foundation, Harney County Chapter

Harold Shepard Center for Tribal Water Advocacy

Oregon Eastside Forest Committee Juniper Group Sierra Club

Dan Bishop Prairie Wood Products

John Day, Snake Resource Advisory Committee

Karen Coulter League of Wilderness Defenders, Blue Mountains Biodiversity 

Project

Jason Kehrberg Grant Soil and Water Conservation District

Oregon State Agencies

Oregon Department of Fish and Wildlife

Federal Agencies

Director, NEPA Policy and Compliance, Department of Energy

U.S. Environmental Protection Agency, Region 10, EIS Review Coordinator

U.S. Fish and Wildlife Service

Local Officials

Judge Steve Grasty Harney County Court

Judge Scott Meyers Grant County Court

Tribal Contacts

Honorable Les Minthorn Confederated Tribes of the Umatilla Indian Reservation

Honorable Diane Teeman Burns Paiute Tribe

Honorable Ron Suppah Confederated Tribes of Warm Springs

Honorable Stanley ‘Buck’ Smith Confederated Tribes of Warm Springs

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Glossary 

Active ingredient (a.i.) - In any pesticide product, the component (a chemical or biological substance) 

that kills or otherwise controls the target pests - Pesticides are regulated primarily on the basis of active 

ingredients. The remaining ingredients are called “inerts.”

Acute effect - An adverse effect on any living organism in which severe symptoms develop rapidly and 

often subside after the exposure stops.

Acute exposure - A single exposure or multiple brief exposures occurring within a short time (e.g., 24 

hours or less in humans). The classification of multiple brief exposures as “acute” is dependent on the life 

span of the organism. (See also, chronic exposure and cumulative exposure.)

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Acute toxicity - Any harmful effect produced in an organism through an acute exposure to one or more 

chemicals.

Additive effect - A situation in which the combined effects of exposure to two chemicals simultaneously 

is equal to the sum of the effect of exposure to each chemical given alone. The effect most commonly 

observed when an organism is exposed to two chemicals together is an additive effect.

Adaptive management - A continuing process of action-based planning, monitoring, researching, 

evaluating, and adjusting with the objective of improving implementation and achieving the goals of the 

standards and guidelines

Adjuvant(s) - Chemicals that are added to pesticide products to enhance the toxicity of the active 

ingredient or to make the active ingredient easier to handle or mix.

Adsorption - The tendency of one chemical to adhere to another material such as soil. 

Affected Environment - Existing biological, physical, social, and economic conditions of an area subject 

to change, both directly and indirectly, as the result of a proposed human action.

Agent - Any substance, force, radiation, organism, or influence that affects the body. The effects may be 

beneficial or injurious.

Agency for Toxic Substances and Disease Registry (ATSDR) - Federal agency within the Public Health 

Service charged with carrying out the health-related analyses under Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA) and Superfund Amendments and Reauthorization 

Act (SARA).

Alluvial deposits may occur after a heavy rain storm.

Ambient - Usual or surrounding conditions.

Amphibian - Any of a class of cold-blooded vertebrates (including frogs, toads, or salamanders) that are 

intermediate in many characteristics between fishes and reptiles and having gilled aquatic larvae and airbreathing adults.

Anadromous - Fish that spend their adult life in the sea but swim upriver to fresh water spawning 

grounds to reproduce.

Anaerobic - Life or process that occurs in, or is not destroyed by, the absence of oxygen. (See also, 

aerobic.)

Anions - Negatively charged ions in solution e.g., hydroxyl or OH- ion. (See also, cations)

Annual - A plant that endures for not more than a year. A plant that completes its entire life cycle from 

germinating seedling to seed production and death within a year.

Bacteria - Microscopic living organisms that metabolize organic matter in soil, water, or other 

environmental media. Some bacteria can also cause human, animal and plant health problems.

Best Management Practices (BMP) - A practice or combination of practices determined by a state or an 

agency to be the most effective and practical means (technological, economic, and institutional) of 

controlling point and non-point source pollutants at levels compatible with environmental quality.

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Bioaccumulation - The increase in concentration of a substance in living organisms as they take in 

contaminated air, water, or food because the substance is very slowly metabolized or excreted (often 

concentrating in the body fat.)

Bioconcentration - The accumulation of a chemical in tissues of a fish or other organism to levels greater 

than in the surrounding water or environment.

Bioconcentration Factor (BCF) - The concentration of a compound in an aquatic organism divided by 

the concentration in the ambient water of the organism.

Biological control - The use of natural enemies, including invertebrate parasites and predators (usually 

insects, mites, and nematodes,) and plant pathogens to reduce populations of non-native, invasive plants.

Biological magnification - The process whereby certain substances such as pesticides or heavy metals 

increase in concentration as they move up the food chain.

Broadcast application - Herbicide treatment method generally used along roads; boom truck spray is 

directed at target species. Broadcast methods are used for larger infestations where spot treatments would 

not be effective.

Bryophytes - Plants of the phylum Bryophyta, including mosses, liverworts, and hornworts; 

characterized by the lack of true roots, stems, and leaves.

Herbicide Use Buffer - A strip of land near a waterway or other environmentally sensitive area where a 

particular chemical and method of application is restricted, depending on the herbicide ingredient. 

Candidate species - Those plant and animal species that, in the opinion of the Fish and Wildlife Service 

(FWS) or National Oceanic and Atmospheric Administration (NOAA) Fisheries, may qualify for listing 

as “endangered” or “threatened.” The FWS recognizes two categories of candidates. Category 1 

candidates are taxa for which the FWS has on file sufficient information to support proposals for listing. 

Category 2 candidates are taxa for which information available to the FWS indicates that proposing to list 

is possibly appropriate, but for which sufficient data are not currently available to support proposed rules.

Carcinogen - A chemical capable of inducing cancer.

Categorical Exclusion – A category of actions which do not individually or cumulatively have a

significant effect on the human environment and which have been found to have no such effect in 

procedures adopted by a Federal agency in implementation of these regulations (§1507.3) and for which, 

therefore, neither an environmental assessment nor an environmental impact statement is required. (40 

CFR 1508.4)

Cations - Positively charged ions in a solution. (See also, anion.)

Cation Exchange Capacity (CEC) - An indicator for fertility and adsorption of applied herbicides. The 

Cation Exchange Capacity (CEC) is an index of available sites for solutes/ions to attach to soil particles. 

A higher CEC represents increased ability to hold and release various chemical elements – a relative 

higher capacity for holding nutrients

Characteristic Landscape - The naturally established landscape within a scene or scenes being viewed.

Chemical Control - The use of naturally derived or synthetic chemicals called herbicides to eliminate or 

control the growth of invasive plants.

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Chronic exposure - Exposures that extend over the average lifetime or for a significant fraction of the 

lifetime of the species (for a rat, chronic exposure is typically about two years). Chronic exposure studies 

are used to evaluate the carcinogenic potential of chemicals and other long-term health effects. (See also, 

acute and cumulative exposure.)

Chronic Reference Dose (RfD) - An estimate of a lifetime daily exposure level (in mg/kg/day) for the 

human population, including sensitive subpopulations, that is likely to be without an appreciable risk of

deleterious effects. Chronic RfDs are specifically developed to be protective for long-term exposure to a 

compound (seven years to lifetime.)

Chronic toxicity - The ability of a substance or mixture of substances to cause harmful effects over an 

extended period, usually upon repeated or continuous exposure sometimes lasting for the entire life of the 

exposed organism.

Code of Federal Regulations (CFR) - Document that codifies all rules of the executive departments and 

agencies of the federal government. It is divided into fifty volumes, known as titles. Title 40 of the CFR 

(referenced as 40 CFR) lists all environmental regulations, including regulations for EPA pesticide 

programs (40 CFR Parts 150-189).

Competitive Seeding – A treatment method that is intended to reduce the potential for invasive plants to 

become introduced or to reoccupy a site once target populations have been reduced. This method is often 

combined with other treatment methods.

Common Control Measures – Integrated weed treatment methods used for a given target invasive plant 

species. The R6 2005 FEIS contains Appendix N, “Common Control Measures,” a compendium of 

treatment methods for invasive plants known in Oregon and Washington. These methods were updated as 

a part of development of the Malheur Invasive Plant Treatment EIS. 

Congressionally Designated Areas - Areas that require Congressional enactment for their establishment, 

such as National Parks, Wild and Scenic Rivers, National Recreation Areas, National Monuments, and 

Wilderness. Also referred to as Congressional Reserves. Includes similar areas established by Executive 

Order, such as National Monuments.

Connected Actions – An action that would occur at the same time and place, or would be required to 

occur, in order to implement a proposed action, and therefore would be analyzed in a single NEPA 

document. 

Contaminants - For chemicals, impurities present in a commercial grade chemical. For biological agents, 

other agents that may be present in a commercial product.

Cultural control - The establishment or maintenance of competitive vegetation, use of fertilizing, 

mulching, prescribed burning, or grazing animals to control or eliminate invasive plants.

Cumulative Effect (CE) - The impact on the environment that results from the incremental impact of the 

action when added to other past, present, and reasonably foreseeable future actions—regardless of what 

agency (federal or non-federal) or person undertakes such other actions. Cumulative impacts can result 

from individually minor, but collectively significant, actions taking place over a period of time (40 CFR 

1508.7). 

Cumulative exposure - Exposure resulting from one or more activities that are repeated over a period of 

time. (See also, acute and chronic exposure.)

Detritus - Loose fragments, particles, or grains formed by the disintegration of organic matter or rocks.

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Disturbance - An effect of a planned human management activity, or unplanned native or exotic agent or 

event that changes the state of a landscape element, landscape pattern, or regional composition.

Dosage/Dose - 1) The actual quantity of a chemical administered to an organism or to which it is exposed. 

2) The amount of a substance that reaches a specific tissue (e.g., the liver). 3) The amount of a substance 

available for interaction with metabolic processes after crossing the outer boundary of an organism. 

Dose Response - Changes in toxicological responses of an individual (such as alterations in severity of 

symptoms) or populations (such as alterations in incidence) that are related to changes in the dose of any 

given substance.

Drift - The portion of a sprayed chemical that is moved by wind off of a target site.

Early Detection/Rapid Response (EDRR) – Treatment of invasive plants over the life of the project 

according to the implementation planning process. 

Endangered Species - Any species listed in the Federal Register as being in danger of extinction 

throughout all, or a significant portion, of its range.

Endangered Species Act (ESA) - A law passed in 1973 to conserve species of wildlife and plants, 

determined by the Director of the U.S. Fish and Wildlife Service or the NOAA Fisheries to be endangered 

or threatened with extinction in all or a significant portion of its range. Among other measures, ESA 

requires all federal agencies to conserve these species and consult with the Fish and Wildlife Service or 

NOAA Fisheries on federal actions that may affect these species or their designated critical habitat.

Endemic - A species or other taxonomic group that is restricted to a particular geographic region due to 

factors such as isolation or response to soil or climatic conditions. (Compare to “Indigenous” and 

“Native.”)

Environmental justice - Executive Order 12898 of February 11, 1994 requires federal agencies, to the 

greatest extent practicable and permitted by law, to make achieving environmental justice part of its 

mission by identifying and addressing, as appropriate, disproportionately high and adverse human health 

or environmental effects of its programs, policies, and activities on minority populations and low-income 

populations in the United States and its territories and possessions, the District of Columbia, the 

Commonwealth of Puerto Rico, and the commonwealth of the Mariana Islands.

Exposure assessment - The process of estimating the amount of contact with a chemical or biological 

agent that an individual or a population of organisms will receive from a pesticide application conducted 

under specific, stated circumstances.

Exotic – Non-native species; introduced from elsewhere, but not completely naturalized. (See also alien 

and introduced species.)

Federal Insecticide and Rodenticide Act (FIFRA) Pesticide Ingredient - An ingredient of a pesticide 

that must be registered with EPA under the Federal Insecticide, Fungicide, and Rodenticide Act. Products 

making pesticide claims must submit required information to EPA to register under FIFRA and may be 

subject to labeling and use requirements.

Fertilization - Treatment method involving adding of nutrients that could improve the success of 

desirable species; may be limited, depending on species/soil characteristics.

First-choice Herbicides – First-choice herbicides are those that would be used during the first year of 

treatment of a given primary target species. It is likely be most effective, given the options associated with 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement – Chapter 4

a given action alternative. First-choice herbicides are often used in combination with non-herbicide 

methods. 

Flora - Plant life, especially all the plants found in a particular country, region, or time regarded as a 

group. Also, a systematic set of descriptions of all the plants of a particular place or time. 

Forage - Food for animals. In this document, term applies to both availability of plant material for 

wildlife and domestic livestock.

Formulation - A commercial preparation of a chemical including any inerts and/or contaminants.

Fungi - Molds, mildews, yeasts, mushrooms, and puffballs, a group of organisms that lack chlorophyll 

and therefore are not photosynthetic. They are usually non-mobile, filamentous, and multi-cellular. 

Game fish - Species like trout, salmon, or bass, caught for sport. Many of them show more sensitivity to 

environmental change than non-game fish.

Geographical Information System (GIS) – Maps and data showing location and attributes for natural 

resources found within a project area.

Grazing animals - Treatment method which requires matching the invasive species with the appropriate 

grazer for best success. 

Groundwater - The supply of fresh water found beneath the Earth's surface, usually in aquifers, which 

often supply wells and springs.

Groundwater Loading Effects of Agricultural Management Systems (GLEAMS) - A model that 

displays herbicide concentrations in streams under a variety of soil, climate, and vegetative conditions.

Habitat - The place where a population (e.g., human, animal, plant, microorganism) lives and its 

surroundings, both living and non-living.

Half-life - The time required for the concentration of the chemical to decrease by one-half.

Hand/Selective application - Herbicide treatment of individual plants through wicking, wiping, injecting 

stems, etc., with low likelihood of drift or delivery of herbicides away from treatment sites. This method 

ensures no herbicide directly contacts soil.

Hand-pulling/Grubbing - Treatment method that is labor-intensive but effective on single plants or on 

small, low-density infestations.

Hazard Quotient (HQ) - The ratio of the estimated level of exposure to a substance from a specific 

pesticide application to the RfD for that substance, or to some other index of acceptable exposure or 

toxicity. A HQ less than or equal to one is presumed to indicate an acceptably low level of risk for that 

specific application.

Hazard identification - The process of identifying the array of potential effects that an agent may induce 

in an exposed of humans or other organisms.

Herbaceous - A plant that does not develop persistent woody tissue above the ground (annual, biennial, 

or perennial.) Herbaceous vegetation includes grasses and grass-like vegetation, and broadleaved forbs.

Herbicide - A chemical preparation designed to kill plants, especially weeds, or to otherwise inhibit their 

growth. May or may not include an additive (adjuvant) such as a surfactant. 

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Herbicide Application Rate – The amount of herbicide active ingredient that would be used on a treated 

acre. The maximum rate is the amount allowed by an herbicide label. Typical rate is the average rate used 

by the Forest Service for invasive plant treatment projects. Lowest rate (or lowest effective rate) is the 

least amount of herbicide needed to reach treatment objectives. The lowest effective rate is determined by

many variables including formulation, location, target species, and potential for herbicide resistence..

Herbicide Treatment – Any use of herbicide to meet treatment objectives. Herbicide treatments are part 

of the integrated weed management toolbox. Herbicide treatment may be combined with non-herbicide 

treatments to meet treatment objectives. 

Herbicide Use Buffer – An area adjacent to a stream or other water body where herbicide ingredient or 

application methods are restricted. 

Humus - Organic portion of the soil remaining after prolonged microbial decomposition.

Tribal and Treaty Rights - Native American treaty and other rights or interests recognized by treaties, 

statutes, laws, executive orders, or other government action, or federal court decisions.

Indian Tribe - Any American Indian or Alaska Native tribe, band, nation, pueblo, community, rancheria, 

colony, or group meeting the provisions of the Code of Federal Regulations Title 25, Section 83.7 (25 FR 

83.7), or those recognized in statutes or treaties with the United States. 

Indigenous - An indigenous species is any that were or are native or inherent to an area. (See also, 

native.)

Inerts - Anything other than the active ingredient in a pesticide product; not having pesticide properties.

Infested area or site - A contiguous area of land occupied by, in this case, invasive plant species. An 

infested area of land is defined by drawing a line around the actual perimeter of the infestation as defined 

by the canopy cover of the plants, excluding areas not infested. Generally, the smallest area of infestation 

mapped will be 1/10th (0.10) of an acre or 0.04 hectares.

Integrated Weed Management (IWM) - An interdisciplinary weed management approach for selecting 

methods for preventing, containing, and controlling noxious weeds in coordination with other resource 

management activities to achieve optimum management goals and objectives.

Interdisciplinary Team (IDT) - A group of individuals with varying areas of specialty assembled to 

solve a problem or perform a task. The team is assembled out of recognition that no one scientific 

discipline is sufficiently broad enough to adequately analyze the problem and propose action.

Introduced species - An alien or exotic species that has been intentionally or unintentionally released 

into an area as a result of human activity. (See also exotic, invasive, and noxious.)

Introduction - “The intentional or unintentional escape, release, dissemination, or placement of a species 

into an ecosystem as a result of human activity” (Executive Order 13122, 2/3/99).

Invasive plant species - An alien plant species whose introduction does or is likely to cause economic or 

environmental harm or harm to human health (Executive Order 13122, 2/3/99) (See also exotic and 

introduced species)

Irreversible effect - Effect characterized by the inability of the body to partially or fully repair injury 

caused by a toxic agent.

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Irritant - Non-corrosive material that causes a reversible inflammatory effect on living tissue by 

chemical action at the site of contact as a function of concentration or duration of exposure.

LC50 (Lethal Concentration50) - A calculated concentration of a chemical in air or water to which 

exposure for a specific length of time is expected to cause death in 50 percent of a defined experimental 

animal population.

LD50 (Lethal Dose50) - The dose of a chemical calculated to cause death in 50 percent of a defined 

experimental animal population over a specified observation period. The observation period is typically 

14 days.

Label - All printed material attached to, or part of, the pesticide container.

Land allocation – A management area designated in a Land and Resource Management Plan associated 

with certain desired conditions, objectives and standards.

Landscape - An area composed of interacting ecosystems that are repeated because of geology, land 

form, soils, climate, biota, and human influences throughout the area. Landscapes are generally of a size, 

shape, and pattern that is determined by interacting ecosystems. 

Landscape Character - Particular attributes, qualities, and traits of a landscape that give it an image and 

make it identifiable or unique.

Landscape Setting - The context and environment in which a landscape is set; a landscape backdrop. It is 

the combination of land use, landform, and vegetation patterns that distinguish an area in appearance and 

character from other areas.

Leaching - The process by which chemicals on or in soil or other porous media are dissolved and carried 

away by water, or are moved into a lower layer of soil.

Level of Concern (LOC) - The concentration in media or some other estimate of exposure above which 

there may be effects.

Lichens - Complex thallophytic plants comprised of an alga and a fungus growing in symbiotic 

association on a solid surface (such as a rock.)

Littoral zone - 1) That portion of a body of fresh water extending from the shoreline lakeward to the 

limit of occupancy of rooted plants. 2) The strip of land along the shoreline between the high and low 

water levels.

Lowest-Observed-Adverse-Effect Level (LOAEL) - The lowest dose of a chemical in a study, or group 

of studies, that produces statistically or biologically significant increases in frequency or severity of 

adverse effects between the exposed and control populations.

Manual Control - The use of any non-mechanized approach to control or eliminate invasive plants (e.g.,

hand-pulling, grubbing)

Material Safety Data Sheet (MSDS) - A compilation of information required under the OSHA 

Communication Standard on the identity of hazardous chemicals, health and physical hazards, exposure 

limits, and precautions.

Mechanical Control - The use of any mechanized approach to control or eliminate invasive plants (e.g.,

mowing, weed whipping).

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Microorganisms - A generic term for all organisms consisting only of a single cell, such as bacteria, 

viruses, protozoa and some fungi.

Minimum tool - Use of a weed treatment alternative that would accomplish management objectives and 

have the least impact on resources

Modification - A visual quality objective meaning human activities may dominate the characteristic 

landscape but must, at the same time, utilize naturally established form, line, color, and texture. It should 

appear as a natural occurrence when viewed in foreground or middleground.

Mollusks - Invertebrate animals (such as slugs, snails, clams, or squids) that have a soft, un-segmented 

body, usually enclosed in a calcareous shell; representatives found on National Forest System land 

include snails, slugs, and clams.

Monitoring - A process of collecting information to evaluate if objectives and anticipated or assumed 

results of a management plan are being realized or if implementation is proceeding as planned.

Morbidity - Rate of disease, injury or illness.

Mowing - Invasive plant treatment method which is limited to level/gently-sloping smooth-surface 

terrain. Treatment timing is critical, and must be conducted for several consecutive years.

National Environmental Policy Act (NEPA) - An Act passed in 1969 to declare a national policy that 

encourages productive and enjoyable harmony between humankind and the environment, promotes efforts 

that prevent or eliminate damage to the environment and biosphere, stimulates the health and welfare of 

humanity, enriches the understanding of the ecological systems and natural resources important to the 

nation, and establishes a Council on Environmental Quality.

National Forest Management Act (NFMA) - A law passed in 1976 as an amendment to the Forest and 

Rangeland Renewable Resources Planning Act, requiring preparation of Forest Plans and the preparation 

of regulations to guide that development.

National Marine Fisheries Service (NMFS) - The federal agency that is the listing authority for marine 

mammals and anadromous fish under the ESA.

National Pollutant Discharge Elimination System (NPDES) - As authorized by the Clean Water Act, 

the National Pollutant Discharge Elimination System (NPDES) permit program controls water pollution 

by regulating point sources that discharge pollutants into waters of the United States. Point sources are 

discrete conveyances such as pipes or man-made ditches. Individual homes that are connected to a 

municipal system, use a septic system, or do not have a surface discharge do not need an NPDES permit; 

however, industrial, municipal, and other facilities must obtain permits if their discharges go directly to 

surface waters. 

National Visitor Use Monitoring (NVUM) - A permanent, ongoing sampling system that measures 

national forest visitor demographics, experiences, preferences, and impressions. A stratified random 

sample is done for 25 percent of the National Forest System each year according to a national research 

protocol. NVUM responds to the need to better understand the use and importance of, and satisfaction 

with, National Forest System recreation opportunities.

National Wilderness Preservation System (NWPS) - The Wilderness Act of 1964 established the 

national Wilderness Preservation System to ensure that certain federally owned areas in the United States 

would be preserved and protected in their natural condition. The Act defines a wilderness area, in part, as 

an area that generally appears to have been affected primarily by the forces of nature, with the imprint of 

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man’s work substantially unnoticeable. Areas included in the system are administered for the use and 

enjoyment of the American people in such manner as to leave them unimpaired for future use and 

enjoyment as wilderness.

Native species - With respect to a particular ecosystem, a species that, other than as a result of an 

introduction, historically occurred or currently occurs in that ecosystem (Executive Order 13122, 2/3/99).

Naturalized - Applied to a species that originally was imported from another country but that now 

behaves like a native in that it maintains itself without further human intervention and has invaded native 

populations.

Non-target species - Any plant or animal that is not the intended organism to be controlled by a pesticide 

treatment.

No-Observed-Adverse-Effect level (NOAEL) - Exposure level at which there are no statistically or 

biological significant differences in the frequency or severity of any adverse effect in the exposed or 

control populations

No-Observed-Effect-Level (NOEL) - Exposure level at which there are no statistically or biological 

significant differences in the frequency or severity of any effect in the exposed or control populations.

Noxious weed - “Any living stage (including but not limited to, seeds and reproductive parts) of any 

parasitic or other plant of a kind, or subdivision of a kind, which is of foreign origin, is new to or not 

widely prevalent in the United States, and can directly or indirectly injure crops, other useful plants, 

livestock, or poultry or other interests of agriculture, including irrigation, or navigation or the fish and 

wildlife resources of the United States or the public health” (Public Law 93-629, January 3, 1975, Federal 

Noxious Weed Act of 1974).

Outstandingly Remarkable Value (ORV) - A characteristic of rivers or sections of rivers in the national 

Wild and Scenic River System. In order for a river to be included in the system, it must possess at least 

one “outstandingly remarkable” value, such as scenic, recreational, geologic, fish, wildlife, historic, 

cultural, or other similar features. Outstandingly Remarkable Values are values or opportunities in a river 

corridor which are directly related to the river and which are rare, unique, or exemplary from a regional or 

national perspective.

Partial Retention - A visual quality objective where human activities may be evident but must remain 

subordinate to the characteristic landscape.

Pathogen - A living organism, typically a bacteria or virus that causes adverse effects in another 

organism.

Percolation - Downward flow or filtering of water through pores or spaces in rock or soil.

Perennial Plant- A plant species having a life span of more than 2 years.

Persistence - Refers to the length of time a compound, once introduced into the environment, stays there.

Personal Protective Equipment (PPE) - Clothing and equipment worn by herbicide mixers, loaders and 

applicators and re-entry workers worn to reduce their exposure to potentially hazardous chemicals and 

other pollutants.

Pest - An insect, rodent, nematode, fungus, weed or other form of terrestrial or aquatic plant or animal life 

that is classified as undesirable because it is injurious to health or the environment.

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Pesticide - Any substance used for controlling, preventing, destroying, repelling, or mitigating any pest. 

Includes fungicides, herbicides, fumigants, insecticides, nematicides, rodenticides, desiccants, defoliants, 

plant growth regulators, etc.

pH - The negative log of the hydrogen ion concentration. A high pH (greater than 7) is alkaline or basic 

and a low pH (less than 7) is acidic.

Population - A group of individuals of the same species in an area.

Project “Caps” – Limitations on the acreage that may be treated annually through the life of the project. 

Project Design Features (pdf) – Measures that are part of project implementation to ensure that the 

project is done according to environmental standards and adverse effects are within the scope of those 

predicted in this Environmental Impact Statement.

Proposed species - Any plant or animal species that is proposed by the Fish and Wildlife Service or 

NOAA Fisheries in a Federal Register notice to be listed as threatened or endangered.

Recreational Rivers - A classification within the national Wild and Scenic River System. Recreational 

rivers are those rivers, or sections of rivers, that are readily accessible by road or railroad, that may have 

some development along their shorelines, and that may have undergone some impoundment or diversion 

in the past.

Reference Dose (RfD) - The RfD is a numerical estimate of a daily exposure to the human population, 

including sensitive subgroups such as children, that is not likely to cause harmful effects during a lifetime. 

RfDs are generally used for health effects that are thought to have a threshold or minimum dose for 

producing effects.

Registered Pesticides - Pesticide products that have been approved for the uses listed on the label.

Registration - Formal licensing with EPA of a new pesticide before it can be sold or distributed. Under 

the Federal Insecticide, Fungicide, and Rodenticide Act, EPA is responsible for registration (pre-market 

licensing) of pesticides based on data demonstrating no unreasonable adverse effects on human health or 

the environment when applied according to approved label directions.

Restoration - Ecological restoration is the process of assisting the recovery and management of 

ecological integrity. Ecological integrity includes a critical range of variability in biodiversity, ecological 

processes and structures, regional and historical context, and sustainable cultural practices. Restoration 

may be passive (passing of time to allow for site recovery) or active (in this project, active restoration 

includes seeding, mulching and planting after invasive plants are removed). 

Retention - A visual quality objective where human activities are not evident to the casual forest visitor.

Revegetation - The re-establishment of plants on a site - The term does not imply native or non-native; 

does not imply that the site can ever support any other types of plants or species and is not at all 

concerned with how the site ‘functions’ as an ecosystem.

Riparian Area - A geographic area containing an aquatic ecosystem and adjacent upland areas that 

directly affect it.

Riparian Habitat Areas - Areas along live and intermittent streams, wetlands, ponds, lakes, and unstable 

and potentially unstable areas where riparian-dependent resources receive primary emphasis. Riparian 

Habitat Areas are important to the terrestrial ecosystem as well, serving as dispersal habitat for certain 

terrestrial species.

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Risk - The chance of an adverse or undesirable effect, often measured as a percentage.

Risk Assessment - The qualitative and quantitative evaluation performed in an effort to estimate the risk 

posed to human health and/or the environment by the presence or potential presence and/or use of specific 

chemical or biological agents.

Scenery Management - The art and science of arranging, planning, and designing landscape attributes 

relative to the appearance of places and expanses in outdoor settings.

Scenic - Of or relating to landscape scenery; pertaining to natural or natural-appearing scenery; 

constituting or affording pleasant views of natural landscape attributes or positive cultural elements.

Scenic Rivers - A classification within the national Wild and Scenic River System. Scenic rivers are those 

rivers, or sections of rivers, that are free of impoundments, with shorelines or watersheds still largely 

primitive and shorelines largely undeveloped, but accessible in places by roads.

Seen Area - The total landscape area observed based upon landform screening. Seen-areas may be 

divided into zones of immediate foreground, foreground, middleground, and background. Some 

landscapes are seldom seen by the public.

Sensitive Species – Sensitive species are identified by a Regional Forester for which population viability 

is a concern, as evidenced by significant current or predicted downward trends in population numbers or 

density and habitat capability that would reduce a species’ existing distribution (FSM 2670.5). 

Management of sensitive species “must not result in a loss of species viability or create significant trends 

toward federal listing” (FSM 2670.32).

Species of Conservation Concern - Threatened, endangered and proposed species; Regional Forester’s 

Sensitive species, management indicator species, and other identified native species.

Species - “A group of organisms, all of which have a high degree of physical and genetic similarity, 

generally interbreed only among themselves, and show persistent differences from members of allied 

groups of organisms.” (Executive Order 13122, 2/3/99).

Spot application - Herbicide treatment involving use of a backpack sprayer or other means. Application 

is aimed at specific target species, with methods of prevention (such as barriers,) to control damage to 

non-target species.

Standards and guidelines - The rules and limits governing actions, as well as the principles specifying 

the environmental conditions or levels to be achieved and maintained

Sub-chronic exposure - An exposure duration that can last for different periods of time (5 to 90 days), 

with 90 days being the most common test duration for mammals. The sub-chronic study is usually 

performed in two species (rat and dog) by the route of intended use or exposure.

Sub-chronic toxicity - The ability of one or more substances to cause effects over periods from about 90 

days but substantially less than the lifetime of the exposed organism. Sub-chronic toxicity only applies to 

relatively long-lived organisms such as mammals.

Surface water - All water naturally open to the atmosphere (rivers, lakes, reservoirs, streams, 

impoundments, seas, estuaries, etc.) and all springs, wells, or other collectors that are directly influenced 

by surface water.

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Surfactant - A surface-active agent; usually an organic compound whose molecules contain a hydrophilic 

group at one end and a lipophilic group at the other. Promotes solubility of a chemical, or lathering, or 

reduces surface tension of a solution. 

Synergistic effect - Situation in which the combined effects of exposure to two chemicals simultaneously 

is much greater than the sum of the effect of exposure to each chemical given alone.

Take - "The term 'take' means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, 

or to attempt to engage in any such conduct." (Title 16, Chapter 35, Section 1532, Endangered Species 

Act of 1973)

Threatened species - Plant or animal species likely to become endangered throughout all, or a significant 

portion of, its range within the foreseeable future. A plant or animal identified and defined in accordance 

with the 1973 Endangered Species Act and published in the Federal Register.

Threshold - The maximum dose or concentration level of a chemical or biological agent that will not 

cause an effect in the organism.

Tolerances - Permissible residue levels for pesticides in raw agricultural produce and processed foods. 

Whenever a pesticide is registered for use on a food or a feed crop, a tolerance (or exemption from the 

tolerance requirement) must be established. EPA establishes the tolerance levels, which are enforced by 

the Food and Drug Administration and the Department of Agriculture.

Toxicity - The inherent ability of an agent to affect living organisms adversely. Toxicity is the degree to 

which a substance or mixture of substances can harm humans or animals.

Toxicology - The study of the nature, effects, and detection of poisons in living organisms. Also, 

substances that are otherwise harmless but prove toxic under particular conditions. The basic assumption 

of toxicology is that there is a relationship among the dose (amount), the concentration at the affected site, 

and the resulting effects.

Treatment Objectives: Treatment objectives reflect the desired outcome depending on the extent, 

distribution and priority for treating a given invasive plant species.

• Eradicate: Eliminate an invasive plant species from a site. This objective generally applies to species 

that are difficult to control and cover small areas. Some occurrences may be on roadsides (Russian 

knapweed, squarrose knapweed) and others may occur in intact native vegetation (yellow starthistle, 

small occurrences of thistles or knapweed, new invaders). This is generally our first priority for 

treatment.

• Control: Reduce the size of the infestation over time; some level of infestation may be acceptable. 

This objective applies to most of the target species (houndstongue, leafy spurge, perennial 

pepperweed, sulfur cinquefoil, whitetop) and large infestations of thistles and knapweeds. This is 

generally our second priority for treatment.

• Contain: Prevent the spread of the weed beyond the perimeter of patches or infestation areas mapped 

from current inventories. This objective applies to target species such as common St. Johnswort. This 

is generally our third priority for treatment.

• Suppress: Prevent seed production throughout the target patch and reduce the area coverage. Prevent 

the invasive species from dominating the vegetation of the area; low levels may be acceptable. This 

objective applies to target species such as toadflax that would be treated mainly with biocontrol 

agents. This is generally our fourth priority for treatment.

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• Tolerate: Accept the continued presence of established infestations and the probable spread to 

ecological limits for certain species. This category is for species that are so widespread and abundant 

that other treatment objectives would be extremely difficult to meet. This category includes species 

such as cheatgrass, medusahead, North Africa grass, dandelion, mullein, and bulbous bluegrass. 

These invasive plants have low priority for treatment and would likely only be treated if they happen 

to be near one of the primary target species.

U.S. Fish and Wildlife Service (United States Department of the Interior Fish and Wildlife Service, 

USDI FWS, USFWS) - The federal agency that is the listing authority for species other than marine 

mammals and anadromous fish under the Endangered Species Act.

USDA Forest Service (United States Department of Agriculture Forest Service, FS or USFS) - The 

federal agency responsible for management of the Nation’s National Forest System lands

Viability - Ability of a wildlife or plant population to maintain sufficient size to persist over time in spite 

of normal fluctuations in numbers, usually expressed as a probability of maintaining a specific population 

for a specified period.

Viable Population - A wildlife or plant population that contains an adequate number of reproductive 

individuals appropriately distributed on the planning area to ensure the long-term existence of the species.

Viewshed - Total visible area from a single observer position, or the total visible area from multiple 

observer position. Viewsheds are accumulated seen-areas from highways, trails, campgrounds, towns, 

cities, or other viewer locations. Examples are corridor, feature, or basin viewsheds.

Visual Quality Objective - A desired level of excellence based on physical and sociological 

characteristics of an area. Refers to degree of acceptable alteration of the characteristic landscape.

Well-distributed - Distribution sufficient to permit normal biological function and species interactions, 

considering life history characteristics of the species and the habitats for which it is specifically adapted.

Wetland - An area that is regularly saturated by surface or ground water and subsequently is 

characterized by a prevalence of vegetation that is adapted for life in saturated soil conditions. Examples 

include swamps, bogs, fens, marshes, and estuaries.

Wild and Scenic River System - The Wild and Scenic Rivers Act of 1968 established a system of 

selected rivers in the United States, which possess outstandingly remarkable values, to be preserved in 

free-flowing condition. Within the national system of rivers, three classifications define the general 

character of designated rivers: Wild, Scenic, and Recreational. Classifications reflect levels of 

development and natural conditions along a stretch of river. Classifications are used to help develop 

management goals for the river.

Wilderness - Areas designated by Congressional action under the 1964 Wilderness Act. Wilderness is 

defined as undeveloped federal land retaining its primeval character and influence without permanent 

improvements or human habitation. Wilderness areas are protected and managed to preserve their natural 

conditions, which generally appear to have been affected primarily by the forces of nature with the 

imprint of human activity substantially unnoticeable; have outstanding opportunities for solitude or for a 

primitive and confined type of recreation; include at least 5,000 acres, or are of sufficient size to make 

practical their preservation, enjoyment, and use in an unimpaired condition; and may contain features of 

scientific, educational, scenic, or historical value as well as ecological and geologic interest.

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Wild Rivers - A classification within the national Wild and Scenic River System. Wild rivers are those 

rivers, or sections of rivers that are free of impoundments and generally inaccessible except by trail, with 

watersheds or shorelines essentially primitive and waters unpolluted.

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Malheur National Forest, Invasive Plants Treatment Final Environmental Impact Statement – Chapter 4

Index

A

Amphibian, 300, 323

Antelope, 150, 221, 222, 271, 277, 367, 368, 374, 375

B

Bat, 205, 206, 207, 247, 250, 321

Beneficial Uses, 309

Best Management Practices, xi, 147, 160, 300, 318, 323

Big Game, 9, 217

Bighorn Sheep, 221, 222, 268

Biological Control, 8, 124, 230, 303

Bobolink, 205, 213, 223, 247, 303

Botany, 115, 306, 307, 314, 321

Broadcast, 11, 25, 29, 36, 45, 46, 61, 66, 111, 126, 256, 

258, 324

Bryophytes, 127, 324

Bufflehead, 205, 212, 247, 256

Bull Trout, 167, 183, 320, 353

C

Cavity Nesters, 219, 267, 301, 306, 308, 321

Chinook Salmon, 168

Clean Water Act, xi, 6, 11, 149, 330

Climate, 95, 134, 139, 147, 300, 321

Climate Change, 95, 300

Clubtail, 205, 216, 318

Colony Collapse Disorder, 316

Common Control Measures, 32, 325

Cultural, 7, 5, 25, 35, 44, 56, 61, 104, 112, 124, 128, 230, 

282, 289, 293, 325, 465

Culturally Significant Plants, 121, 127

Cutthroat Trout, 168

D

Dispersed Recreation, 291

Duskysnail, 43, 205, 216, 260, 303, 318

E

Eagle, 41, 204, 208, 250, 311, 319, 320

Early Detection and Rapid Response, 46, 64, 129, 130, 131, 

173, 192, 282, 326

Elk, 97, 101, 189, 217, 218, 241, 265, 298, 312, 315, 349, 

364, 365

Endangered Species Act, xi, 6, 8, 11, 115, 122, 164, 165, 

196, 198, 204, 205, 316, 326, 334, 335

Endocrine Disruption, 109

Environmental Justice, 110

ESA, xi, 8, 24, 163, 164, 165, 167, 191, 196, 198, 204, 205, 

244, 326, 330

F

Falcon, 41, 209, 224, 252, 310

Federally Listed, 115, 191, 198, 244

Fisheries, xi, 11, 163, 164, 165, 167, 169, 191, 297, 317, 

324, 326, 330, 332

Flicker, 219, 220

Floodplains and Wetlands, 296

Foreseeable Projects, 96

Forest Plan, xi, 9, 2, 5, 6, 8, 9, 36, 43, 53, 57, 122, 147, 165, 

217, 220, 286, 287, 288, 316, 330

Frog, 42, 214, 258, 305, 308

G

GLEAMS model, xi, 126, 139, 141, 151, 157, 159, 160, 161, 

173, 177, 185, 193, 315, 327

Goshawk, 221, 269, 313

Grasshopper Sparrow, 42, 205, 210, 223, 247, 253, 303, 

305, 306, 313

Gray Wolf, 40, 198, 203, 205, 246, 248, 319, 320

Grazing, 92, 98, 102, 130, 242, 280, 317, 327, 344, 345, 

347, 348, 349, 351, 353, 354, 355, 356, 357, 358, 360, 

361, 362, 364, 365, 367, 368, 369, 370, 371, 373, 374, 

375, 376, 377, 378, 380, 381, 382, 384, 385, 387

Grouse, 221, 223, 269, 272

H

Habitat Indicators, 182

Hairstreak, 205, 215, 262, 310, 318

Herbicide Toxicity, 75

Human Health, 13, 68, 103, 294, 314, 315

Hydrology, 105, 141, 184, 186, 304

I

Implementation Planning, 48, 57, 62

Integrated Weed Management, 6, 49, 313, 328

Invasive Plant Spread, 91, 280

Invertebrate, 306, 308, 330

L

Land and Resource Management Plan, ii, 8, 5, 6, 24, 116, 

149, 164, 192, 238, 239, 240, 295, 316, 329

Landbirds, 222, 299, 310

Lanx, 215, 260, 318

Lichens, 127, 329

Long-term Productivity, 294

LRMP, ii, xi, 8, 9, 10, 6, 7, 8, 9, 12, 13, 14, 17, 21, 24, 57, 62, 

65, 103, 104, 133, 140, 161, 164, 195, 196, 209, 218, 

235, 238, 239, 240, 248, 266, 268, 270, 271, 275, 295, 

296

LRMP Amendment, 57

Lynx, xi, 198, 199, 200, 244, 312, 316, 317, 319, 320

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Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

M

Management Area, 9, 209, 287, 295

Management Indicator Species, xi, 165, 191, 192, 204, 217, 

265, 322

Management Objectives, xii, 1, 17, 163, 218

Manual, xi, 6, 3, 6, 25, 34, 39, 40, 55, 60, 104, 116, 118, 

122, 124, 127, 163, 186, 196, 204, 230, 282, 283, 293, 

305, 316, 317, 329

Marten, 217, 218, 267, 308, 322

Matrix of Pathways and Indicators, xi, 182, 183

Mechanical, 6, 25, 34, 55, 60, 124, 127, 230, 250, 262, 282, 

293, 329

Monitoring, xii, 40, 49, 52, 57, 62, 123, 126, 253, 285, 299, 

303, 304, 317, 318, 330

Multiple Chemical Sensitivity, 108, 109

Myotis, 205, 207, 247, 250

N

Native Vegetation, 116

O

Osprey, 43, 221, 222, 270, 271

P

Pesticide Study, 89, 90

Pollinators, 14, 13, 69

Prime Farmlands, 296

Project Area, 3, 164, 199, 201, 204, 205, 206, 207, 208, 

209, 210, 211, 212, 213, 214, 215, 216, 217

Project Design Features, 9, 35, 49, 56, 61, 303, 332

R

Recreation, xii, 9, 49, 93, 96, 97, 100, 102, 242, 285, 286, 

288, 290, 325, 344, 345, 347, 348, 349, 351, 353, 354, 

355, 356, 357, 358, 360, 361, 362, 364, 365, 367, 368, 

369, 370, 371, 373, 374, 375, 376, 377, 378, 380, 381, 

382, 384, 385, 387

Recreation Opportunity Spectrum, xii

Regulatory Framework, 104, 116, 133, 147, 164, 196, 275

Restoration, 7, 25, 56, 62, 84, 85, 96, 97, 98, 100, 101, 128, 

230, 276, 301, 306, 311, 332, 344, 345, 347, 348, 349, 

351, 353, 354, 355, 356, 357, 358, 360, 361, 362, 364, 

373

RHCA, xii, 164

RMO, xii

Roadless Area, xi, 202, 287, 317

Rosy Finch, 205, 210, 223, 247, 254

S

Sage Grouse, 42, 198, 205, 211, 221, 223, 254

Sandpiper, 42, 205, 212, 221, 256, 303

Sapsucker, 219, 220, 223

Sensitive Plants, 117, 123, 132

Sensitive Species, 116, 118, 191, 204, 205, 221, 246, 267, 

318, 322, 333

Soil Organisms, 126, 140

Special Forest Products, 43, 121, 127

Species of Conservation Concern, 165, 191, 192, 198, 333

Spot, 11, 14, 15, 26, 29, 39, 45, 46, 57, 61, 62, 66, 69, 70, 

85, 126, 128, 132, 236, 333

Steelhead, 165, 166, 182, 310, 345, 351, 353

Stream Flow, 148

T

Target Species, 1, 2, 4, 17, 18, 20, 28, 32, 53, 57, 63, 279

Toxicity, 152, 161, 231, 232, 233, 310, 334

Treatment Cost-Effectiveness, 12

Treatment Methods, 25, 36, 53, 57, 282

W

Water Quality, 52, 73, 89, 149, 184, 185, 194, 309, 318, 

322

Watershed, 9, 96, 101, 118, 166, 169, 182, 184, 187, 189, 

194, 241, 317, 339, 340, 341, 344, 345, 347, 348, 349, 

350, 351, 353, 354, 355, 356, 357, 358, 360, 361, 362, 

364, 365, 367, 368, 369, 370, 371, 373, 374, 375, 376, 

377, 378, 380, 381, 382, 384, 385, 387

Wetlands, 335

Wild and Scenic Rivers, 9, 35, 285, 286, 287, 288, 289, 290, 

320, 321, 325, 335

Wilderness Act, 11, 36, 286, 330, 335

Wilderness Area, 36, 286, 289

Wildlife, xi, xii, 15, 10, 11, 14, 40, 70, 77, 116, 122, 164, 

191, 195, 196, 198, 199, 200, 201, 202, 204, 205, 206, 

208, 211, 224, 225, 231, 243, 251, 297, 298, 299, 300, 

302, 303, 305, 306, 307, 308, 309, 310, 311, 312, 314, 

315, 316, 317, 318, 319, 320, 324, 326, 332, 335

Wolverine, 198, 200, 201, 244, 299, 302, 305, 306, 307, 

313, 316

Woodpecker, 213, 214, 217, 218, 219, 220, 258, 299, 307, 

308

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Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Appendix A

Appendix A – Invasive Plant Inventory Watershed

Analysis for the Malheur National Forest

Prepared by Joseph H. Rausch

December 3, 2012

This report presents an analysis of known invasive plants sites by watershed (HUC 5). Also included are 

other important attributes or concerns about the watersheds that may be associated with the treatment of 

invasive plants. The analysis is presented in watershed groups of the same basin (HUC 3), sub-basin 

(HUC4), or portions of sub-basins. 

The map below and the corresponding figures on the following pages show the geographic extent of the 

watershed groups and the levels of infestations, respectively.

355
Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Figure A- 1. Watershed Groups

356
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Summary of Invasive Plant Infestations by Watershed

In figure A- 2 that follows, colors represent the watershed group as presented in figure A- 1 on the 

previous page; the first column indicates the watershed group (by basin, sub-basin, or a portion thereof), 

and the second column indicates the 5th field HUC. The individual watershed summaries that follow are 

generally presented in the order shown above.

357
Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Figure A- 2. Invasive plants infestation summary

358
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

North Fork John Day Sub-basin (17070202)

Cottonwood Creek (1707020209)

Lower North Fork John Day River (1707020210)

Figure A- 3. North Fork John Day Sub-basin (17070202)

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Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Cottonwood Creek (1707020209)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 32,994

Special land uses: none

Major streams and water bodies: Fox Creek

Recreation: dispersed campsites

Grazing allotments: Fox, Highway, King, Indian Ridge, Donaldson, Beech Creek, Mt. 

Vernon/John Day, Ferg, Deep Creek

Watershed regional priorities: within Whole Watershed Restoration Initiative (WWRI) Priority Basin 

(John Day)

Major roads and/or infested roads: US-395, 3945, 3940, 3970, 3950

TES species of concern: steelhead

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 31 28

Scotch thistle 1 0.1

Dalmatian toadflax 4 0.5

St. Johnswort 5 1

leafy spurge 10 9

sulphur cinquefoil 2 0.2

spotted knapweed 4 0.4

diffuse knapweed 4 2

squarrose knapweed 1 0.1

TOTAL 62 41

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 8 4 6 1

Leafy spurge 2 0.1 1 0.07

TOTAL 10 4 7 1 0 – 0

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Lower North Fork John Day River (1707020210)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 3,632

Special land uses: None

Major streams and water bodies: Deer Creek

Recreation: Dispersed Campsites

Grazing allotments: Hamilton, Deep Creek, King

Watershed regional priorities: Within Whole Watershed Restoration Initiative (WWRI) Priority Basin 

(John Day)

Major roads and/or infested roads: None

TES species of concern: Steelhead

Comments: None

Species Watershed Total

Sites Acres

Canada thistle 4 0.4

diffuse knapweed 1 0.1

TOTAL 5 0.5

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 2 0.2 1 0.07

TOTAL 2 0.2 1 0.07 0 – 0

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Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Middle Fork John Day Sub-basin (17070203)

Bridge Creek- Middle Fork John Day River (1707020301)

Camp Creek- Middle Fork John Day River (1707020302)

Big Creek- Middle Fork John Day River (1707020303)

Long Creek (1707020304)

Figure A- 4. Middle Fork John Day Sub-basin (17070203)

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Bridge Creek- Middle Fork John Day River (1707020301)

Ranger district: Blue Mountain RD, Prairie City RD

County: Grant

Total FS acreage: 75,877

Special land uses: None

Major streams and water bodies: Middle Fork John Day River, Crawford Creek, Clear Creek, Lunch Creek, 

Bridge Creek, Summit Creek, Crawford Creek

Recreation: Dixie CG, Sumpter Valley Interpretive Site, Dispersed Campsites

Grazing allotments: Sullens, Blue Mountain, Austin, Upper Middle Fork

Watershed regional priorities: Within Whole Watershed Restoration Initiative (WWRI) Priority Basin 

(John Day)

Major roads and/or infested roads: US-26, OR-7, 2620, 2622, 1940, 1940-275, 1940-220, 1940-281, 1940-

552, 2645, 2645-019, 2645-017, 2645-025, 2645-011, 2645-299, 2646, 

2646-410, 2646-435, 2646-284, 2640, 2635, 2600-343, 2600-503 (closed)

TES species of concern: steelhead, bull trout, Helodium blandowii

Comments: A large portion of the Journey Through Time Scenic Byway (US-26, OR-7) 

traverses this watershed; major grazing allotments in this area are vacant 

or are in non-use

Species Watershed Total

Sites Acres

Canada thistle 163 273

Scotch thistle 2 0 .3

Dalmatian toadflax 95 24

St. Johnswort 36 19

houndstongue 68 153

sulphur cinquefoil 1 0 .1

spotted knapweed 14 10

diffuse knapweed 39 24

whitetop 2 0 .2

TOTAL 420 504

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 69 66 45 14

Scotch thistle 1 0 .1 1 0 .007

Dalmatian toadflax 16 2 9 0 .5

St. Johnswort 14 3 7 1

houndstongue 21 12 12 2 1 30 ft. Helodium blandowii

sulphur cinquefoil 1 0 .1 1 0 .03

spotted knapweed 8 4 3 1

diffuse knapweed 16 6 11 0.9

TOTAL 146 94 89 20 1 – 1

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Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Camp Creek- Middle Fork John Day River (1707020302)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 119,047

Special land uses: Vinegar Hill-Indian Rock Scenic Area, Dixie Mountain Proposed Research 

Natural Area

Major streams and water bodies: Middle Fork John Day River, Vinegar Creek, Vincent Creek, Little Boulder 

Creek, Granite Boulder Creek, Ruby Creek, Big Boulder Creek, Lick 

Creek, Camp Creek

Recreation: Camp Creek CG, Middle Fork CG, Middle Fork Day Use Site, Deerhorn 

CG, dispersed campsites

Grazing allotments: Upper Middle Fork, Lower Middle Fork, Long Creek, Slide Creek, Camp 

Creek, Balance Creek

Watershed regional priorities: Focus Watershed within Priority Basin (John Day) of the Whole Watershed 

Restoration Initiative (WWRI)

Major roads and/or infested roads: County Road-20, 2045, 2050, 2055, 2055-518 (closed), 2055-364 

(closed), 2055-432 (closed), 2010, 2614, 2000-120, 2000-139 (closed), 

2000-612 (closed), 3600, 3650, 3660, 3670, 3675, 4500, 4550, 4555, 

4557, 4559, 4559-283, 4559-284

TES species of concern: steelhead, bull trout, Phacelia minutissima (no known invasive plants 

within 100 ft.)

Comments: None

Species Watershed Total

Sites Acres

Canada thistle 149 326

Scotch thistle 5 2.0

musk thistle 9 8.0

Dalmatian toadflax 26 10.0

yellow toadflax 5 0.5

St. Johnswort 39 70.0

houndstongue 2 0.6

leafy spurge 1 0.1

sulphur cinquefoil 12 15.0

spotted knapweed 33 14.0

diffuse knapweed 16 11.0

squarrose knapweed 1 0.1

meadow knapweed 1 0.1

yellow star-thistle 2 1.0

perennial 

pepperweed

1 0.1

whitetop 6 16.0

Total 308 475

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Invasive Species Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 65 63 42 21

musk thistle 2 0 .1

Dalmatian toadflax 11 1 7 0 .3

yellow toadflax 4 0 .4 1 0 .07

St. Johnswort 16 15 13 4

houndstongue 1 0 .05

sulphur cinquefoil 6 3 3 0 .2

spotted knapweed 17 5 11 1

diffuse knapweed 4 1 3 0 .2

squarrose knapweed 1 0 .07

meadow knapweed 1 0 .1 1 0 .01

yellow star-thistle 1 0 .1

perennial 

pepperweed

1 0 .03

whitetop 1 5 1 2

Total 133 95.0 82 29 0 – 0

Big Creek- Middle Fork John Day River (1707020303)

Ranger District: Blue Mountain RD

County: Grant

Total FS acreage: 45,722

Special land uses: Vinegar Hill-Indian Rock Scenic Area

Major streams and water bodies: Middle Fork John Day River, Deep Creek, Big Creek, Slide Creek, Elk

Creek, Mud Lake

Recreation: Dispersed Campsites

Grazing allotments: Slide Creek, York, Lower Middle Fork, Camp Creek, Bear Creek

Watershed regional priorities: Within Whole Watershed Restoration Initiative (WWRI) Priority Basin 

(John Day)

Major roads and/or infested roads: County Road-20, 2000-893, 2000-621, 2000-893, 2000-978 (closed), 

2090, 2090-048, 2090-519, 2090-521 (closed), 3690, 3514, 4500, 4560, 

4560-155 (closed), 4560-570 (closed)

TES species of concern: steelhead, bull trout

Comments: None

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Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Species Watershed Total

Sites Acres

Canada thistle 23 28.0

Scotch thistle 3 0.4

Dalmatian toadflax 1 0.2

St. Johnswort 39 22.0

sulphur cinquefoil 15 153.0

spotted knapweed 9 15.0

diffuse knapweed 4 2.0

Total 94 221

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 12 5 9 1

Dalmatian toadflax 1 0 .2 1 0 .01

St. Johnswort 18 7 9 1

sulphur cinquefoil 11 36 10 7

spotted knapweed 3 2 2 0 .3

diffuse knapweed 1 0 .1 1 0 .7

TOTAL 46 50 32 10 0 – 0

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Long Creek (1707020304)

Ranger District: Blue Mountain RD

County: Grant

Total FS acreage: 29,911

Special land uses: Long Creek Municipal Water Supply

Major streams and water bodies: Long Creek

Recreation: dispersed campsites

Grazing allotments: Long Creek, War Canyon, Highway, Fox, Keeney Meadows, Mt. 

Vernon/John Day

Watershed regional priorities: Within Whole Watershed Restoration Initiative (WWRI) Priority Basin 

(John Day)

Major roads and/or infested roads: County Road-18, County Road-35, 3945, 3946

TES species of concern: Steelhead

Comments: None

Species Watershed Total

Sites Acres

Canada thistle 33 11

Dalmatian toadflax 2 0 .2

St. Johnswort 5 0 .7

leafy spurge 2 0 .2

sulphur cinquefoil 4 4

spotted knapweed 7 1

diffuse knapweed 5 0 .5

Russian knapweed 1 0 .1

Total 59 18

Invasive Species Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 6 0 .4 1 0 .04

St. Johnswort 1 0 .007

sulphur cinquefoil 1 0 .09 1 0 .0003

diffuse knapweed 2 0 .1 1 0 .04

Russian knapweed 1 0 .07

Total 11 1 3 0 .08 0 – 0

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Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Upper John Day Sub-basin – Main Stem Portion (17070201)

Reynolds Creek-John Day River (1707020105)

Grub Creek-John Day River (1707020106)

Canyon Creek (1707020107)

Beech Creek (1707020108)

Laycock Creek-John Day River (1707020109)

Fields Creek-John Day River (1707020110)

Figure A- 5. Upper John Day Sub-basin – Main Stem Portion (17070201)

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Reynolds Creek-John Day River (1707020105)

Ranger district: Prairie City RD, Blue Mountain RD

County: Grant

Total FS acreage: 54,573

Special land uses: Strawberry Mountain Wilderness

Major streams and water bodies: John Day River, Reynolds Creek, Deardorff Creek, Roberts Creek, Rail 

Creek, Call Creek

Recreation: Trout Farm CG, Crescent CG, Sunshine Flat TH, Deardorff TH, Reynold 

Creek TH, dispersed campsites

Grazing allotments: Reynolds Creek, Deardorff, Hot Springs, Rail Creek, Dixie

Watershed regional priorities: Within Whole Watershed Restoration Initiative (WWRI) Priority Basin 

(John Day)

Major roads and/or infested roads: US-26, County Road-62, 2600-306, 2600-272 (closed), 2600-390 (closed), 

2600-392 (closed), 1300, 1344, 2635, 2635-629

TES species of concern: Steelhead, Bull Trout

Comments: None

Species Watershed Total

Sites Acres

Canada thistle 16 2

Dalmatian toadflax 114 34

yellow toadflax 1 0 .1

St. Johnswort 14 2

houndstongue 4 10

spotted knapweed 5 0 .6

diffuse knapweed 49 7

meadow knapweed 1 0 .2

TOTAL 204 56

Invasive Species Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 1 0 .05

Dalmatian toadflax 28 3 17 0 .6

St. Johnswort 7 0 .6 4 0 .1

houndstongue 1 0 .5 1 0 .1

spotted knapweed 1 0 .1 1 0 .06

diffuse knapweed 10 0 .7 5 0 .1

meadow knapweed 1 0 .2 1 0 .1

Total 49 5 29 1 0 – 0

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Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Grub Creek-John Day River (1707020106)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 50,089

Special land uses:

Strawberry Mountain Wilderness, Strawberry Mountain Proposed 

Research Natural Area, Baldy Mountain Proposed Research Natural Area, 

Dixie Mountain Proposed Research Natural Area

Major streams and water bodies: Strawberry Creek, Indian Creek, Pine Creek, Dixie Creek, Bear Creek, 

Grub Creek, Strawberry Lake, Slide Lake, Little Slide Lake

Recreation:

Strawberry Campground, Slide Creek, CG, McNaughton Spring CG, Slide 

Horse Camp, Slide Creek TH, Onion Creek TH, Strawberry Basin TH, 

Indian Creek TH, dispersed campsites

Grazing allotments: Dixie, Roundtop, Indian Creek

Watershed regional priorities: within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: County Road-18, 3670, 5401, 6001

TES species of concern: steelhead, bull trout, Thelypodium eucosmum (no know invasive plants 

within 100 ft.), Luina serpentina (no know invasive plants within 100 ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 3 0.3

Dalmatian toadflax 9 1

St. Johnswort 2 0.2

spotted knapweed 3 0.4

diffuse knapweed 1 0.1

TOTAL 18 2

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 1 0.006

Dalmatian toadflax 1 0.2 1 0.1

spotted knapweed 3 0.3 1 0.07

TOTAL 5 0.5 2 0.2 0 – 0

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Canyon Creek (1707020107)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 59,583

Special land uses: Strawberry Mountain Wilderness, Canyon Creek Research Natural Area

Major streams and water bodies: Canyon Creek, West Fork Canyon Creek, Middle Fork Canyon Creek, 

Canyon Meadows Reservoir

Recreation: Wickiup CG, Canyon Meadows CG, dispersed campsites

Grazing allotments: Seneca, Dark Canyon, Williams Pasture, Joaquin, Fawn Spring

Watershed regional priorities:

Within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: US-395, County Road-65, 1500, 6510, 3920, 1516, 1520, 1530

TES species of concern: steelhead, Thelypodium eucosmum (no know invasive plants within 100 

ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 2 0.2

Scotch thistle 6 0.6

Dalmatian toadflax 22 3

St. Johnswort 1 0.1

houndstongue 1 0.1

leafy spurge 1 0.3

sulphur cinquefoil 6 0.7

spotted knapweed 6 0.6

diffuse knapweed 14 4

Russian knapweed 3 0.3

squarrose knapweed 1 0.1

whitetop 3 0.3

TOTAL 66 10

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 2 0 .2 1 0 .06

Scotch thistle 2 0 .2 1 0 .1

Dalmatian toadflax 11 0 .04 4 0 .2

houndstongue 1 0 .04

sulphur cinquefoil 2 0 .2

spotted knapweed 2 0 .2 1 0 .04

diffuse knapweed 5 2 2 0 .4

Russian knapweed 1 0 .1 1 0 .01

squarrose knapweed 1 0 .1 1 0 .08

whitetop 1 0 .02

TOTAL 28 4 11 1 0 – 0

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Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Beech Creek (1707020108)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 40,568

Special land uses: none

Major streams and water bodies: Beech Creek, Clear Creek, Lake Creek, Tinker Creek, Magone Lake

Recreation: Magone Lake Recreation Area, Beech Creek CG, Raddue Forest Camp, 

dispersed campsites

Grazing allotments: Fox, Mt. Vernon/John Day, Beech Creek, McCullough, Herberger, 

Roundtop

Watershed regional priorities: within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: US-395, County Road-32, 3600, 3618, 3620, 3940, 3900-131

TES species of concern: steelhead

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 17 12

Scotch thistle 5 0.7

Dalmatian toadflax 13 2

St. Johnswort 11 2

sulphur cinquefoil 6 9

spotted knapweed 26 27

diffuse knapweed 8 10

Russian knapweed 2 0.2

TOTAL 88 63

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 7 0 .6 3 0 .1

Scotch thistle 4 0 .3 1 0 .05

Dalmatian toadflax 9 1 5 0 .3

St. Johnswort 3 0 .6 1 0 .1

sulphur cinquefoil 3 3 3 0 .4

spotted knapweed 15 8 12 2

diffuse knapweed 6 8 6 3

Russian knapweed 2 0 .2 1 0 .01

TOTAL 49 21 32 6 0 – 0

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Laycock Creek-John Day River (1707020109)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 30,473

Special land uses: none

Major streams and water bodies: Riley Creek, Laycock Creek, Birch Creek

Recreation: dispersed campsites

Grazing allotments: Deadhorse, Hanscomb, Seneca, McClellan, Field Peak

Watershed regional priorities: within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: 4900, 2190

TES species of concern: steelhead, Thelypodium eucosmum (no know invasive plants within 100 

ft.), Luina serpentina (no know invasive plants within 100 ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 3 0.3

Dalmatian toadflax 6 0.8

yellow toadflax 1 0.1

St. Johnswort 1 0.1

spotted knapweed 4 0.6

diffuse knapweed 2 0.2

whitetop 3 0.5

TOTAL 20 3

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 2 0 .2 1 0 .06

Dalmatian toadflax 2 0 .2 1 0 .07

spotted knapweed 1 0 .05

diffuse knapweed 1 0 .1 1 0 .08

whitetop 2 0 .3 1 0 .06

TOTAL 8 1 4 0 .3 0 – 0

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Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Fields Creek-John Day River (1707020110)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 25,296

Special land uses: Cedar Grove Botanical Special Interest Area

Major streams and water bodies: Fields Creek, Belshaw Creek

Recreation: Billy Fields CG, Cedar Grove TH, dispersed campsites

Grazing allotments: Fields Peak, Aldrich

Watershed regional priorities: within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: 2100, 2140, 3955, 3955-486, 3955-417

TES species of concern: steelhead, Luina serpentina

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 5 3

Dalmatian toadflax 12 1

yellow toadflax 1 0.1

St. Johnswort 8 1

sulphur cinquefoil 5 0.5

spotted knapweed 7 0.7

diffuse knapweed 6 0.6

TOTAL 44 7

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 2 0.2 1 0.08

Dalmatian toadflax 7 0.5 2 0.1 1 57 ft. Luina serpentina

yellow toadflax 1 0.02

St. Johnswort 2 0.2 2 0.07

sulphur cinquefoil 2 0.1

spotted knapweed 5 0.4 2 0.01 1 51 ft. Luina serpentina

diffuse knapweed 2 0.1

TOTAL 21 2 7 0.4 2 – 1

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Upper John Day Sub-basin – South Fork Portion (17070201)

Upper South Fork John Day River (1707020101)

Middle South Fork John Day River (1707020102)

Murderers Creek (1707020103)

Figure A- 6. Upper John Day Sub-basin - South Fork Portion (17070201)

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Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Upper South Fork John Day River (1707020101)

Ranger district: Blue Mountain RD, Emigrant Creek RD

County: Grant, Harney

Total FS acreage: 63,396

Special land uses: none

Major streams and water bodies: South Fork John Day River, Bear Creek, Lonesome Creek, Lewis Creek, 

Spoon Creek

Recreation: dispersed campsites

Grazing allotments: Izee, Lonesome, Smoky, Lewis Creek, Snowshoe, Rosebud

Watershed regional priorities: within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: County Road-63, 4700, 3160, 3150, 4785, 6370

TES species of concern: Calochortus longibarbatus var. peckii (no know invasive plants within 100 

ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 33 21

Dalmatian toadflax 4 0.4

St. Johnswort 1 0.1

Russian knapweed 1 0.1

whitetop 6 25

TOTAL 45 47

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 20 14 13 10

Dalmatian toadflax 2 0 .2 1 0 .08

St. Johnswort 1 0 .1 1 0 .08

Russian knapweed 1 0 .1

whitetop 3 2 1 0 .2

TOTAL 27 18 16 11 0 – 0

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Middle South Fork John Day River (1707020102)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 34,966

Special land uses: Murderer’s Creek Wild Horse Territory

Major streams and water bodies: Deer Creek, Buck Creek, Corral Creek, Vester Creek

Recreation: dispersed campsites

Grazing allotments: Murderer’s Creek, Frenchy, Rosebud, Poison

Watershed regional priorities: within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: 2400, 2400-338, 6370, 6370-407

TES species of concern: steelhead

Comments: none

Species Watershed Total

Sites Acres

musk thistle 2 0.2

Dalmatian toadflax 1 0.1

St. Johnswort 1 0.2

houndstongue 2 99

sulphur cinquefoil 1 0.8

spotted knapweed 3 0.6

diffuse knapweed 2 5

Russian knapweed 1 0.1

whitetop 20 6

TOTAL 33 112

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

musk thistle 1 0 .1 1 0 .1

houndstongue 2 23 2 1

sulphur cinquefoil 1 0 .02

spotted knapweed 1 0 .3 1 0 .2

whitetop 11 4 10 2

TOTAL 16 28 14 3 0 – 0

377
Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Murderers Creek (1707020103)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 65,101

Special land uses: Shaketable Research Natural Area, Murderer’s Creek Wild Horse Territory

Major streams and water bodies: Murderer’s Creek, Tex Creek, South Fork Murderer’s Creek, Thorn Creek

Recreation: Murderer’s Creek GS, Deer Creek GS, dispersed campsites

Grazing allotments: Murderer’s Creek, Fields Peak, Aldrich

Watershed regional priorities: Priority Terrestrial Restoration and Conservation Watershed (TRACS), 

within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: 2100, 2160, 2150, 2170, 2180, 2490, 2480

TES species of concern: steelhead, Luina serpentina (no know invasive plants within 100 ft.),

Phacelia minutissima (no know invasive plants within 100 ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 1 8

Dalmatian toadflax 6 0.6

St. Johnswort 5 1

sulphur cinquefoil 3 0.3

spotted knapweed 5 0.5

diffuse knapweed 3 0.4

Russian knapweed 2 0.2

yellow star-thistle 1 0.1

perennial pepperweed 1 0.1

whitetop 2 0.2

TOTAL 29 11

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Dalmatian toadflax 3 0 .2 2 0 .05

St. Johnswort 3 0 .2

spotted knapweed 2 0 .2 2 0 .02

diffuse knapweed 2 0 .3 2 0 .1

Russian knapweed 2 0 .1

yellow star-thistle 1 0 .07

perennial pepperweed 1 0 .03

whitetop 1 0 .1 1 0 .03

TOTAL 15 1 7 0 .2 0 – 0

378
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Upper Malheur Sub-basin – North Fork Portion (17050116)

Upper North Fork Malheur River (1705011611)

Little Malheur River (1705011612)

Figure A- 7. Upper Malheur Sub-basin – North Fork Portion (17050116)

379
Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Upper North Fork Malheur River (1705011611)

Ranger district: Prairie City RD

County: Grant, Baker

Total FS acreage: 96,732

Special land uses: Monument Rock Wilderness, North Fork Malheur Wild and Scenic River, 

Dugout Research Natural Area

Major streams and water bodies: North Fork Malheur River, Crane Creek, Little Crane Creek, Bear Creek, 

Elk Creek, Flat Creek, Swamp Creek, Spring Creek, Cow Creek, Sheep 

Creek

Recreation: Short Creek CG, Elk Creek CG, Little Crane CG, North Fork Malheur CG, 

Crane Crossing CG, Crane Prairie CG, North Fork TH, Crane Creek TH, 

Sheep Creek TH, Elf Flat TH, dispersed campsites

Grazing allotments: Spring Creek, Ott, Flag Prairie, Crane Prairie, North Fork

Watershed regional priorities: Priority Terrestrial Restoration and Conservation Watershed (TRACS)

Major roads and/or infested roads: 1300, 1400, 1600, 1370, 1675,1665, 1663

TES species of concern: bull trout

Comments: Significant groundwater dependent ecosystems throughout watershed

Species Watershed Total

Sites Acres

Canada thistle 70 47

Scotch thistle 2 1

Dalmatian toadflax 6 0.8

St. Johnswort 1 0.2

houndstongue 17 21

spotted knapweed 2 0.3

diffuse knapweed 10 5

whitetop 4 1

TOTAL 112 76

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 10 4 7 1

Scotch thistle 1 0 .09

Dalmatian toadflax 1 0 .01

houndstongue 7 2 5 0 .5

spotted knapweed 1 0 .04

diffuse knapweed 1 0 .2 1 0 .06

whitetop 2 0 .2 1 0 .01

TOTAL 23 7 14 2 0 – 0

380
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Little Malheur River (1705011612)

Ranger district: Prairie City RD

County: Grant, Baker, Malheur

Total FS acreage: 31,525

Special land uses: Monument Rock Wilderness

Major streams and water bodies: Little Malheur River, Camp Creek, Squaw Creek

Recreation: Elk Flat Spring CG, Little Malheur TH, Horse Creek TH, Table Rock TH, 

dispersed campsites

Grazing allotments: Spring Creek, North Fork, Flag Prairie

Watershed regional priorities: none

Major roads and/or infested roads: 1600, 1672, 1370

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 26 7

Scotch thistle 4 0.7

musk thistle 2 3

St. Johnswort 2 0.4

houndstongue 36 9

spotted knapweed 1 1

diffuse knapweed 1 0.2

whitetop 6 2

TOTAL 78 23

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 6 0.6 1 0.1

Scotch thistle 1 0.2 1 0.06

musk thistle 1 2 1 0.6

St. Johnswort 1 0.2 1 0.1

houndstongue 11 2 5 0.2

spotted knapweed 1 0.09

TOTAL 21 5 9 1 0 – 0

381
Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Upper Malheur Sub-basin – Main Stem Portion (17050116)

Headwaters Malheur River (1705011601)

Wolf Creek (1705011602)

Pine Creek (1705011603) Otis Creek (1705011606)

Griffin Creek-Upper Malheur River (1705011605)

Figure A- 8. Upper Malheur Sub-basin – Main Stem Portion (17050116)

382
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Headwaters Malheur River (1705011601)

Ranger district: Prairie City RD, Emigrant Creek RD

County: Grant, Harney

Total FS acreage: 111,947

Special land uses: Strawberry Mountain Wilderness, Malheur Wild and Scenic River, Fergy 

Spruce Grove Proposed Botanical Special Interest Area

Major streams and water bodies: Malheur River, McCoy Creek, Summit Creek, Big Creek, Lake Creek, 

Crooked Creek, Bosenberg Creek, Mud Lake, Little Mud Lake, High Lake

Recreation: Big Creek CG, Murray CG, Lake Creek Organizational Camp, Malheur 

Ford CG, Huddleston SnoPark, Hog Flat TH, Malheur Ford TH, Lake 

Creek TH, Meadow Fork TH, Big Creek/Snowshoe TH, Skyline TH, 

Huddleston TH, Starvation TH, dispersed campsites

Grazing allotments: Summit Prairie, Lake Creek, Logan Valley, McCoy Creek, Dollar Basin, 

Star Glade, Bluebucket, Central Malheur, Antelope

Watershed regional priorities: none

Major roads and/or infested roads: County Road-62, 1600, 1640, 1648, 1649, 1651, 1647, 1643, 1630, 1560, 

1400, 1450

TES species of concern: bull trout

Comments: Significant groundwater dependent ecosystems in Logan Valley

Species Watershed Total

Sites Acres

Canada thistle 71 26

Scotch thistle 1 0.1

bull thistle 1 0.1

Dalmatian toadflax 9 3

yellow toadflax 2 0.4

St. Johnswort 5 0.5

houndstongue 3 3

sulphur cinquefoil 2 5

spotted knapweed 9 4

diffuse knapweed 9 1

perennial pepperweed 1 0.6

whitetop 2 0.2

TOTAL 115 44

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 14 2 7 0.6

Dalmatian toadflax 1 0.3 1 0.1

yellow toadflax 1 0.2 1 0.1

St. Johnswort 1 0.1 1 0.006

sulphur cinquefoil 1 2 1 0.6

spotted knapweed 3 1 2 0.4

diffuse knapweed 1 0.02

whitetop 1 0.1 1 0.02

TOTAL 23 6 14 2 0 – 0

383
Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Wolf Creek (1705011602)

Ranger district: Emigrant Creek RD

County: Grant, Harney

Total FS acreage: 70,865

Special land uses: none

Major streams and water bodies: Wolf Creek, Calamity Creek

Recreation: Rock Springs CG, dispersed campsites

Grazing allotments: Antelope, Wolf Mountain, West Malheur, Van, Calamity, Muddy

Watershed regional priorities: none

Major roads and/or infested roads: 1500, 1700, 1630, 1710, 1712, 1705, 1705-378, 1780, 1550-804

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 93 25

Dalmatian toadflax 12 4

houndstongue 3 0.2

diffuse knapweed 2 0.1

Russian knapweed 5 0.4

perennial pepperweed 1 0.1

whitetop 18 9

TOTAL 134 39

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 43 8 30 3

Dalmatian toadflax 6 1 5 0.3

Russian knapweed 3 0.2 1 0.001

perennial pepperweed 1 0.009

whitetop 8 5 6 1

TOTAL 61 14 42 4 0 – 0

384
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Pine Creek (1705011603)

Ranger district: Emigrant Creek RD

County: Harney

Total FS acreage: 32,021

Special land uses: none

Major streams and water bodies: Pine Creek

Recreation: dispersed campsites

Grazing allotments: Calamity, Alkali, Pine Creek

Watershed regional priorities: none

Major roads and/or infested roads: 2800, 2850, 2855, 2800-189, 2850-262, 2850-951 (closed), 2850-265 

(closed), 2800-336 (closed)

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 68 67

Scotch thistle 1 0.1

Dalmatian toadflax 26 11

spotted knapweed 1 0.1

whitetop 6 0.6

TOTAL 102 79

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 19 30 9 10

Dalmatian toadflax 4 0.7 2 0.1

TOTAL 23 31 11 10 0 – 0

385
Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Griffin Creek-Upper Malheur River (1705011605)

Ranger district: Emigrant Creek RD

County: Harney

Total FS acreage: 7,343

Special land uses: none

Major streams and water bodies: Muddy Creek

Recreation: dispersed campsites

Grazing allotments: Muddy, Alkali, Pine Creek

Watershed regional priorities: none

Major roads and/or infested roads: 1705, 2850, 2850-135

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 11 3

Dalmatian toadflax 1 0.1

diffuse knapweed 1 0.1

whitetop 7 0.7

TOTAL 20 4

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 3 2 2 0.5

whitetop 2 0.2 1 0.1

TOTAL 5 2 3 0.6 0 – 0

386
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Otis Creek (1705011606)

Ranger district: Prairie City RD

County: Grant, Harney

Total FS acreage: 20,025

Special land uses: none

Major streams and water bodies: Cottonwood Creek

Recreation: dispersed campsites

Grazing allotments: Ott, Spring Creek

Watershed regional priorities: none

Major roads and/or infested roads: 1400, 1420, 1663

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 120 14

Scotch thistle 16 3

houndstongue 1 0.1

perennial pepperweed 1 0.1

whitetop 1 1

TOTAL 139 18

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 11 0.7 3 0.1

Scotch thistle 3 1 2 0.6

perennial pepperweed 1 0.1 1 0.03

TOTAL 15 2 6 0.07 0 – 0

387
Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Silvies River Sub-basin (17120002) 

Headwaters Silvies River (1712000201)

Bear Creek (1712000202)

Upper Silvies River (1712000203)

Middle Silvies River (1712000204)

Emigrant Creek (1712000205)

Sage Hen Creek (1712000206)

Figure A- 9. Silvies River Sub-basin – 17120002

388
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Headwaters Silvies River (1712000201)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 61,343

Special land uses: none

Major streams and water bodies: Silvies River, Scotty Creek, Wickiup Creek

Recreation: Starr Ridge CG, dispersed campsites

Grazing allotments: Scotty Creek, Jack Creek, Snowshoe, Flagtail, Deadhorse, Hanscomb, 

Seneca, County Road, Windy Point, Hunter Cabin, Pearson

Watershed regional priorities: Priority Terrestrial Restoration and Conservation Watershed (TRACS)

Major roads and/or infested roads: US-395, County Road-63, 2400, 3100, 2100, 4900, 2195, 2400-011, 2400-

017, 2400-022, 3780-274, 3780-070 (closed)

TES species of concern: Botrychium crenulatum, Carex idahoa (no know invasive plants within 100 

ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 19 3

Scotch thistle 11 14

Dalmatian toadflax 32 4

yellow toadflax 11 2

St. Johnswort 2 0.2

houndstongue 10 29

sulphur cinquefoil 1 0.1

spotted knapweed 6 2

diffuse knapweed 6 0.6

Russian knapweed 1 0.1

perennial pepperweed 1 0.1

whitetop 4 0.6

TOTAL 104 56

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 9 1 6 0.3 1 54 ft. Botrychium crenulatum

Scotch thistle 2 8 1 2

Dalmatian toadflax 8 0.6 3 0.2

yellow toadflax 5 0.6 1 0.0005

houndstongue 4 9 4 2

spotted knapweed 1 0.1

perennial pepperweed 1 0.1 1 0.02

whitetop 3 0.4 2 0.02

TOTAL 33 20 18 4 1 – 1

389
Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Bear Creek (1712000202)

Ranger district: Blue Mountain RD, Emigrant Creek RD

County: Grant

Total FS acreage: 52,344

Special land uses: Strawberry Mountain Wilderness

Major streams and water bodies: Bear Creek, Antelope Creek

Recreation: Parish Cabin CG, dispersed campsites

Grazing allotments: Dark Canyon, Antelope, Wolf Mountain, Bridge Creek, Hunter Cabin

Watershed regional priorities: none

Major roads and/or infested roads: 1600, 1500, 1601,1619, 1710

TES species of concern: Carex idahoa (no know invasive plants within 100 ft.), Thelypodium 

eucosmum (no know invasive plants within 100 ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 5 0.5

Scotch thistle 1 0.1

Dalmatian toadflax 20 3

yellow toadflax 1 0.1

St. Johnswort 3 0.4

sulphur cinquefoil 2 0.2

spotted knapweed 5 0.5

diffuse knapweed 4 0.4

whitetop 1 0.1

TOTAL 42 5

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 1 0.09

Dalmatian toadflax 9 0.3 4 0.2

St. Johnswort 3 0.1 1 0.002

sulphur cinquefoil 1 0.02 1 0.04

diffuse knapweed 2 0.2 1 0.08

TOTAL 16 0.7 7 0.3

390
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Upper Silvies River (1712000203)

Ranger district: Emigrant Creek RD, Blue Mountain RD

County: Grant, Harney

Total FS acreage: 80,687

Special land uses: none

Major streams and water bodies: Silvies River, Bridge Creek, Camp Creek, Crooked Creek, Trout Creek

Recreation: Joaquin Miller CG, dispersed campsites

Grazing allotments: Scotty Creek, Camp Creek, Koehler, Antelope, Bridge Creek, Silvies, 

Crooked Creek, House Creek, Calamity, Big Sagehen, Alkali, Devine, Pine 

Creek

Watershed regional priorities: none

Major roads and/or infested roads: US-395, 3700, 2800, 2700, 3935, 2800-021, 3700-843, 3700-115, 3700-

841, 3700-855, 3765-932, 3765-868, 3765-912

TES species of concern: Astragalus tegetarioides, Carex idahoa

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 69 28

Dalmatian toadflax 42 7

houndstongue 15 15

sulphur cinquefoil 1 0.1

spotted knapweed 3 0.3

diffuse knapweed 5 1

Russian knapweed 1 0.1

whitetop 5 0.5

TOTAL 141 52

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 30 11 21 2 1 0 ft. Carex idahoa

Dalmatian toadflax 20 2 4 0.4 3 0 ft. Astragalus tegetarioides

houndstongue 5 6 2 0.7 1 0 ft. Carex idahoa

sulphur cinquefoil 1 0.1 1 0.01

diffuse knapweed 1 0.3 3 0.1

Russian knapweed 3 0.03

whitetop 1 0.1

TOTAL 62 20 31 3 5 – 2

391
Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Middle Silvies River (1712000204)

Ranger district: Emigrant Creek RD

County: Harney, Grant

Total FS acreage: 61,529

Special land uses: none

Major streams and water bodies: Silvies River, Myrtle Creek, Sage Hen Creek

Recreation: West Myrtle TH, dispersed campsites

Grazing allotments: Myrtle, Scatfield, Big Sagehen, West Myrtle, Scotty Creek, Crooked Creek, 

Silvies

Watershed regional priorities: none

Major roads and/or infested roads: 3100, 3700, 3765, 3130, 3125, 3120, 3140

TES species of concern: Astragalus tegetarioides, Carex idahoa (no know invasive plants within 

100 ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 47 12

Dalmatian toadflax 12 2

St. Johnswort 1 0.1

houndstongue 1 0.2

spotted knapweed 5 1

Russian knapweed 9 1

whitetop 21 3

TOTAL 96 19

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 17 3 9 1

Dalmatian toadflax 4 1 4 0.2

spotted knapweed 2 0.02 1 0.006 1 0 ft. Astragalus tegetarioides

Russian knapweed 1 0.07

whitetop 6 0.4 3 0.1 1 79 ft. Astragalus tegetarioides

TOTAL 30 5 17 1 2 – 2

392
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Emigrant Creek (1712000205)

Ranger district: Emigrant Creek RD

County: Harney, Grant

Total FS acreage: 130,885

Special land uses: Stinger Creek Proposed Research Natural Area

Major streams and water bodies: Emigrant Creek, Hay Creek, Yellowjacket Creek, Sawtooth Creek, Whisky Creek, 

Crowsfoot Creek, Yellowjacket Lake

Recreation: Yellow Jacket CG, Emigrant CG, Falls CG, Pendleton Spring CG, Alder Springs 

CG, Donnelly CG, dispersed campsites

Grazing allotments: Rainbow, West Myrtle, Sawtooth, Blue Creek, Hughet Valley, Snow Mountain, 

Allison, Donnelly, Green Butte

Watershed regional priorities: none

Major roads and/or infested roads: 3700, 4700, 4300, 4100, 3746, 3745, 3740, 4780, 4781, 4770, 4357, 4360, 4356, 

4370, 4341, 4340, 4334, 4335, 4320, 4332, 4140

TES species of concern: Calochortus longibarbatus var. peckii

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 67 27

Dalmatian toadflax 40 7

yellow toadflax 5 6

St. Johnswort 3 0.3

houndstongue 2 3

spotted knapweed 7 0.8

diffuse knapweed 11 1

Russian knapweed 11 0.9

perennial pepperweed 4 0.4

whitetop 9 0.8

TOTAL 159 47

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 28 6 12 0.9

Dalmatian toadflax 15 0.8 3 0.1

yellow toadflax 3 2 3 0.6

3 0 ft. Calochortus longibarbatus var. peckii

spotted knapweed 3 0.2 2 0.08

diffuse knapweed 3 0.2 2 0.1

Russian knapweed 3 0.1 1 0.05

perennial pepperweed 2 0.06

whitetop 4 0.3 2 0.1

TOTAL 61 10 25 2 3 – 1

393
Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Sage Hen Creek (1712000206)

Ranger district: Emigrant Creek RD

County: Harney

Total FS acreage: 2,075

Special land uses: none

Major streams and water bodies: none

Recreation: dispersed campsites

Grazing allotments: Donnelly

Watershed regional priorities: none

Major roads and/or infested roads: County Road-127, 4100

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 1 0.1

Dalmatian toadflax 3 0.2

spotted knapweed 1 0.5

TOTAL 5 1

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

None

TOTAL 0 0 0 0 0 – 0

394
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Silver Creek Sub-basin (17120004)

Claw Creek (1712000401)

Upper Silver Creek (1712000402)

Middle Silver Creek (1712000403)

Figure A- 10. Silver Creek Sub-basin (17120004)

395
Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Claw Creek (1712000401)

Ranger district: Emigrant Creek RD

County: Harney

Total FS acreage: 29,620

Special land uses: Dry Mountain Research Natural Area

Major streams and water bodies: Wickiup Creek, Claw Creek

Recreation: dispersed campsites

Grazing allotments: Silver Creek, Donnelly, Green Butte

Watershed regional priorities: none

Major roads and/or infested roads: 4100, 4335, 4130

TES species of concern: Astragalus tegetarioides (no know invasive plants within 100 ft.)

Comments: none

Species Watershed Total

Sites Acres

Dalmatian toadflax 2 0.7

houndstongue 1 0.1

TOTAL 3 1

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

None

TOTAL 0 0 0 0 0 – 0

396
Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Upper Silver Creek (1712000402)

Ranger district: Emigrant Creek RD

County: Harney, Crook

Total FS acreage: 96,071

Special land uses: Silver Creek Proposed Research Natural Area

Major streams and water bodies: Silver Creek, Sawmill Creek, Nicoll Creek, Delintment Creek, Delintment 

Lake

Recreation: Buck Springs CG, Tip Top Spring CG, Delintment Lake CG, dispersed 

campsites

Grazing allotments: Allison, Silver Creek, Sawmill, Buck Mountain, Lower Nicoll

Watershed regional priorities: none

Major roads and/or infested roads: 4100, 4500, 4170, 4160, 4175, 4161, 4545, 4535, 4510, 4525

TES species of concern: Astragalus tegetarioides (no know invasive plants within 100 ft.), 

Calochortus longibarbatus var. peckii (no know invasive plants within 100 

ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 4 0.3

Dalmatian toadflax 5 1

houndstongue 1 0.1

spotted knapweed 1 0.2

diffuse knapweed 4 1

whitetop 2 0.1

TOTAL 17 3

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 1 0.04 1 0.0003

Dalmatian toadflax 1 .09

whitetop 1 .04

TOTAL 3 0.2 1 0.0003 0 – 0

397
Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Middle Silver Creek (1712000403)

Ranger district: Emigrant Creek RD

County: Harney

Total FS acreage: 28,376

Special land uses: Dry Mountain Research Natural Area

Major streams and water bodies: none

Recreation: Pine Springs Overlook, dispersed campsites

Grazing allotments: Green Butte, Donnelly

Watershed regional priorities: none

Major roads and/or infested roads: 4100, 4107, 4120, 4126

TES species of concern: Astragalus tegetarioides (no know invasive plants within 100 ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 4 15

Scotch thistle 1 0.1

Dalmatian toadflax 7 4

whitetop 1 0.2

TOTAL 13 19

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 2 0.2

Scotch thistle 1 0.1

Dalmatian toadflax 1 0.2

TOTAL 4 0.5 0 0 0 – 0

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Harney-Malheur Lakes Sub-basin (17120001)

North Basin (1712000101)

Malheur Slough (1712000102)

Figure A- 11. Harney-Malheur Lakes Sub-basin (17120001)

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Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

North Basin (1712000101)

Ranger district: Emigrant Creek RD

County: Harney

Total FS acreage: 32,979

Special land uses: none

Major streams and water bodies: Rattlesnake Creek, Poison Creek

Recreation: Idlewild CG, dispersed campsites

Grazing allotments: Myrtle, Devine, Pine Creek

Watershed regional priorities: none

Major roads and/or infested roads: US-395, 2800, 2800-480, 2810, 2810-478, 2810-482 (closed), 2820, 2820-

216, 2820-028, 3935, 3900-958,

TES species of concern: Astragalus tegetarioides

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 80 21

Scotch thistle 2 0.2

Dalmatian toadflax 112 26

houndstongue 4 0.6

spotted knapweed 4 0.8

diffuse knapweed 6 1

Russian knapweed 5 0.4

perennial pepperweed 2 0.9

whitetop 14 15

TOTAL 229 66

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 14 7 9 2

Dalmatian toadflax 30 3 14 0.3 1 0 ft. Astragalus tegetarioides

houndstongue 4 0.5 2 0.07

spotted knapweed 1 0.03 1 0.02

diffuse knapweed 3 0.2 1 0.02

Russian knapweed 2 0.2 1 0.03

whitetop 6 5 3 0.4

TOTAL 60 16 31 3 1 – 1

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

Malheur Slough (1712000102)

Ranger district: Emigrant Creek RD

County: Harney

Total FS acreage: 13,732

Special land uses: none

Major streams and water bodies: Cow Creek

Recreation: Call Meadows SnoPark, dispersed campsites

Grazing allotments: Pine Creek

Watershed regional priorities: none

Major roads and/or infested roads: 2800, 2820, 2810, 2850, 2830, 2815, 2820-499, 2815-700

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 37 22

Dalmatian toadflax 23 6

Russian knapweed 1 0.1

whitetop 5 0.3

TOTAL 66 28

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 2 0.2 2 0.04

TOTAL 2 0.2 2 0.04 0 – 0

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Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Deschutes River Basin (170703)

South Fork Beaver Creek (1707030305)

Figure A- 12. Deschutes River Basin (170703), South Fork Beaver Creek (1707030305)

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix A

South Fork Beaver Creek (1707030305)

Ranger district: Emigrant Creek RD

County: Harney, Grant

Total FS acreage: 7,428

Special land uses: none

Major streams and water bodies: Freeman Creek

Recreation: dispersed campsites

Grazing allotments: Sawmill, Allison, Little Mowich

Watershed regional priorities: none

Major roads and/or infested roads: 4100

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 1 0.1

TOTAL 1 0.1

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

None

TOTAL 0 0 0 0 0 – 0

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix B

Appendix B - Invasive Species Monitoring Plan 

Southern Blues Restoration Coalition CFLRP

Malheur National Forest

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix B

1. Introduction

1.1. Background

Invasive plants are non-native species whose introduction does or is likely to cause economic or 

environmental harm or harm to human health. Invasive plants have the potential to displace native plant 

communities, increase fire hazards, negatively affect fish and wildlife habitat, degrade rangeland forage, 

compete with rare and culturally-significant plants, increase soil erosion, and adversely affect scenic 

beauty and recreational opportunities. Because of their competitive abilities, invasive plants can spread 

rapidly across the landscape, unconstrained by administrative or ownership boundaries.

Often the terms “invasive plants” and “noxious weeds” are used interchangeably; however, there are 

subtle differences in meaning. Noxious weeds are invasive or otherwise undesirable plants that have been 

designated by the State of Oregon as being injurious to public health, agriculture, recreation, wildlife, or 

any public or private property. Species which are identified as invasive, and which are also designated by 

the state as being noxious weeds, are the focus of treatment and monitoring on the Malheur National 

Forest. Here, the terms “invasive plants” and “noxious weeds” are essentially used interchangeably.

1.2. Monitoring Question

What are the trends in the occurrence and distribution of invasive plants/noxious weeds at the project and 

landscape scales?

1.3. Collaborators

Blue Mountain Forest Partners (BMFP)

Harney County Restoration Collaborative (HCRC)

Malheur National Forest (MNF)

North Fork John Day Watershed Council (NFJDWC)

Rocky Mountain Elk Foundation (RMEF) *

Grant Soil and Water Conservation District (GSWCD) *

Harney County Weed Control (GSWCD) *

Oregon Department of Transportation (ODOT) *

Permittees of MNF livestock grazing allotments *

* Partnerships are currently being developed with these entities

2. Methods and Protocols

2.1. Types of treatments to be monitored

The occurrence and distribution of invasive plants can be affected by management activities in three 

major ways: (1) active and deliberate efforts to treat infestations within the CFLRP landscape and project 

areas (e.g. mechanical, chemical, and biological control efforts), (2) active prevention of invasive species 

establishment through preventative management practices and revegetation with native plants, and (3) 

unintentional spread of invasive species due ground-disturbing activities within specific project areas (e.g. 

spread due vegetation management and restoration efforts). Specific treatments and activities of these two 

major management activities are discussed below:

Active weed treatments – The purpose of active weed treatment is to control, suppress, and/or eradicate 

noxious weed infestations at the landscape and project levels. Such activities include manual and 

mechanical treatments, release of biological control agents†

, cultural control methods (e.g. solarization, 

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Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

livestock use, etc.), and spraying of herbicides†. Monitoring of these efforts will focus on the 

effectiveness of such treatments in reducing invasive plant infestations.

Preventative revegetation – In many cases, native plant seed is used to preemptively revegetate disturbed 

sites using native plant seed. The purpose of this is to provide locally adapted, genetically appropriate 

native plant seed for restoration of disturbed areas prior to invasive plants becoming established at the 

site. Native plants can provide ground cover at the site and offer a competitive advantage by becoming 

established before invasive plant gain a foot-hold. Monitoring of these efforts will focus on the 

effectiveness of such treatments in establishing native vegetation and reducing invasive plant infestations.

Possible unintentional spread – Many of the proposed project-level activities are designed to restore 

native communities to desired conditions and to provide economically valuable forest products. These 

often result in ground-disturbing activities that have the potential to unintentionally facilitate the 

establishment and spread of invasive plant species. Examples of such activities include logging and 

thinning operations (e.g. skid trails, landings, temporary road construction); pile burning, culvert 

replacements, stream channel restoration, and road decommissioning. Results of these activities will be 

monitored to determine if they are inadvertently causing an increase in invasive plant occurrence and 

distribution.

† These treatment methods are contingent upon successful completion of the Malheur National Forest Site-Specific Invasive 

Plants Treatment Environmental Impact Statement

2.2. Implementation of monitoring

In most cases monitoring will be accomplished concurrently with invasive species treatments. Monitoring 

is an inherent process of effectively treating invasive species infestations. Successful control and/or 

eradication of invasive species populations require numerous multi-year visits to the sites in order to 

assess the effectiveness of previous treatments and to implement follow-up treatments of residual 

infestations. Furthermore, it is more efficient and cost-effective to accomplish both implementation and 

monitoring simultaneously.

Currently, monitoring and data collection will be accomplished by the MNF’s noxious weeds survey and 

treatment crews, the MNF’s native plant materials restoration staff, and the NFJDWC’s youth crews. 

Future monitoring efforts may include other interested citizens and groups as partnerships are developed 

and time and funding permit.

Monitoring will be conducted at three spatial scales: (1) the CFLRP landscape scale, (2) within individual 

project areas, and (3) at selected treatment areas or disturbed sites.

Monitoring crews will determine the number of invasive plant sites present within and adjacent to the 

project areas prior to, during, and after project implementation. All known information on existing and 

historical infestations will be collected and provided prior to the monitoring effort.

2.3. Methods for Data Collection

Invasive plant population data will be collected prior to, during, and following implementation. Data 

collection will follow the USDA Forest Service invasive species survey protocol; at a minimum, collected 

data will include the following mandatory information: physical location, which species are present, the 

size and extent of the infestation, and the density of infestation (percent cover per species). Additional 

data will include a basic site description, the types of disturbance that may have been historically 

impacting the site, and what type of vegetation management or restoration activity that will or has 

occurred. Data will be recorded either on a standardized invasive plant record/treatment data sheet or an 

electronic field data recorder.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix B

Species which are identified as invasive by the Forest Service, and which are also designated by the state 

as being noxious weeds, will be the primary focus of the monitoring effort. However, some invasive 

species that are not designated as noxious, and which are not targets for treatment on the MNF, will also 

be monitored when necessary. For example, cheatgrass (Bromus tectorum) and African wire-grass 

(Ventenata dubia) are not identified as noxious weeds by the state and are not targets of treatment for the 

MNF, but are species of concern if prevention measures are ineffective and/or management actions are 

inadvertently causing invasion and spread into new areas.

Additionally, a subset of selected sites will be intensively monitored not only to determine the 

effectiveness of invasive plant treatments, but also to determine the degree of native species recovery at 

the site (either through natural recovery or deliberate revegetation efforts). In addition to recording the 

minimum mandatory information, these intensive monitoring areas will also collect standard ecological 

data as indicators of biodiversity: native species richness, native species diversity indices, potential 

natural vegetation, and a description of the ecological “state” as described in published state and transition 

models.

2.4. Data Management

Data management will be accomplished by the MNF. Monitoring crews shall submit hard copy data 

sheets or electronic files for any new invasive plant infestations found and updates to any existing 

infestations. Forest Service personnel will enter all monitoring/treatment data into the Invasive Species 

Inventory/Treatment GIS module of the Natural Resource Information System (NRIS) and the Forest 

Activities Tracking System (FACTS); these are the databases of record for all invasive species activities 

and inventories on national forest lands. 

2.5. Data Analysis

Forest Service personnel will analyze all new and old data by site and project area to determine (1) the 

effectiveness of invasive plant treatments by species, site type, and treatment type, and (2) impacts (if 

any) of the vegetation management, restoration, and revegetation activities on invasive plant spread, 

persistence, and density. This will be accomplished by comparing the extent, cover, and species 

composition of existing sites prior to implementation to new and existing sites during and following 

implementation.

Additionally, the resulting effect on native biodiversity as a result of invasive plant treatments and 

subsequent native plant revegetation efforts will be analyzed by comparing measures of native species 

biodiversity before the treatments to those recoded after implementation of the treatments.

2.6. Indicators and metrics 

Project-Level and Landscape Indicators – A number of metrics will be used to determine the trends in the 

occurrence and distribution of invasive plants/noxious weeds at the project and landscape scales. Data 

will be collected and reported on a project by project basis. In the future these will be summarized to 

address the CFLRP area as a whole. Metrics will be compared after implementation to those prior to 

implementation; these include:

• Total number of infestations (by species)

• Total acres infested (by species) 

• Total percent of acres infested (by species).

• Effectiveness of invasive plant treatments by treatment type (e.g. mechanical, manual, herbicide, 

biological) as measured by percent decrease in invasive plants.

• Effectiveness of preventative native plant seeding treatments as measured by number of new 

infestations.

• Impact of vegetation management and restoration activities by type of activity (e.g. pile burning, 

underburning, skidding, decking, culvert replacement, channel restoration, etc.)

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Appendix B-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Site-Specific Indicators – A subset of selected sites within each project area will be intensively monitored 

to determine how invasive plant treatments are affecting biological diversity at the sites. Metrics will be 

compared after implementation to those prior to implementation, these include:

• Native species richness (total number of native species at site)

• Invasive species richness (total number of invasive species at site)

• Native species diversity indices (accounts for the number, abundance, and distribution of species)

• Ecological state (from published state and transition models, when available)

2.7. Plan for data management

Original monitoring data (hard copy and electronic) will be held with the MNF. Most of the data will be 

stored in the Forest Service’s national databases of record for invasive plant inventory and treatments: the 

Natural Resource Information System (NRIS) and the Forest Activities Tracking System (FACTS). Data 

that cannot be stored in these databases will be kept in MS Excel or MS Access databases stored on the 

Forest Service’s centralized corporate hard drives (O-Drive).

3. Deliverables

3.1. Reporting of Results

Results of the invasive species monitoring will be presented in an annual summary of monitoring 

accomplishments. This annual report will focus on expenditures, project areas monitored, number of sites 

monitored, partnership development, and other basic information.

Detailed reports that analyze and summarize monitoring data will be provided at years three, five, and ten 

after final initiation of the monitoring program. These reports will focus on (1) the effectiveness of 

invasive plant treatments, (2) the effectiveness of native plant revegetation at preventing invasion, (3) the 

degree of unintentional spread due to restoration and vegetation management activities, and (4) the impact 

of treating invasive plants on the native biodiversity of the sites.

3.2. Responsibility for providing final products.

Malheur National Forest’s Invasive Plant Program will be responsible for providing the final reports and 

products.

4. Adaptive management

4.1. How will the data be used?

Results of the monitoring program will be used to inform the planning and implementation of future 

proposed activities. Invasive species prevention and control measures will be reassessed and modified, if 

necessary, depending on the results of the monitoring program. 

4.2. At what spatial scale will the results apply and when will they provide meaningful feedback?

Results of the monitoring will be applicable at the site-specific, the general project area, and the CFLRP 

landscape levels. Results should start providing some meaningful feedback after the first year of 

implementation. However, long-term results (at years three, five, and ten) will provide much more quality 

information that can be used in an adaptive management and long-term planning context. 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix B

409

Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix C

Appendix C - Adjuvant/Surfactant Information

(Excerpted from Analysis of Issues Surrounding the Use of Spray Adjuvants With Herbicides, David 

Bakke 2002, revised 2007. Please note that this project would not use POEA or NPE based adjuvants.)

Adjuvants are spray solution additives that are mixed with an herbicide solution to improve performance 

of the spray mixture. Adjuvants can either enhance activity of an herbicide’s active ingredient (activator 

adjuvant) or offset any problems associated with spray application, such as adverse water quality or wind 

(special purpose or utility modifiers). Activator adjuvants include surfactants, wetting agents, stickerspreaders, and penetrants. This paper deals mainly with commonly used activator adjuvants used in 

herbicide applications in forestry.

Adjuvants are not under the same registration guidelines as are pesticides. The U.S. Environmental 

Protection Agency (U.S. EPA) does not register or approve the labeling of spray adjuvants. All adjuvants 

are generally field tested by the manufacturer with several different herbicides against many weeds, and 

under different environments. Surfactants, or surface-acting agents, are a broad category of activator 

adjuvants that facilitate and enhance the absorbing, emulsifying, dispersing, spreading, sticking, wetting, 

or penetrating properties of herbicides.

Surfactants, by their very nature, are intended to increase the effect of a pesticide by increasing the 

amount of pesticide that is in contact with the target (by reducing surface tension). This is not synergism, 

but more accurately is a reflection of increased dose of the herbicide active ingredient into the plant. 

Although there is not much data in the technical literature, the references included in Bakke’s 2007 hazard 

assessment indicate a lack of synergistic effects between surfactants and pesticides.

Adjuvant Types 

Wetter/Spreaders

Wetter/Spreaders are most often used with herbicides to help it spread over and penetrate the waxy cuticle 

(outer layer) of a leaf or to penetrate through the small hairs present on the leaf surface. Because of the 

high surface tension of water, spray mixture droplets can maintain their roundness and sit on the leaf hairs 

or waxy surface without much of the herbicide actually contacting the leaf. The primary purpose of a 

wetter/spreader is to reduce the surface tension of the spray solution to allow more intimate contact 

between the spray droplet and the plant surface. They may also act to change the permeability of the leaf 

surface.

Most wetter/spreaders used with herbicides are considered non-ionic surfactants. This means that these 

compounds have no electrical charge and are compatible with most pesticides. There are cationic 

(positive charge) and anionic (negative charge) surfactants, but they are not as commonly used, with the 

exception of the cationic surfactant in the Roundup® formulation of glyphosate. Wetter/spreaders have the 

physical characteristics of both oil and water. Most wetter/spreader molecules contain a water-loving 

(hydrophilic) head and a long-chain hydrocarbon oil-loving (lipophilic) tail. 

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Appendix C-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

There are several different basic chemistries of wetter/spreaders.29

Ethoxylated fatty amines (Cationic)

Examples:

• EntryTM II (Monsanto Company)

• POEA - Roundup® has 15 percent POEA 

Alkylphenol ethoxylate-based wetter/spreaders (non-ionic)

Examples: 

• R-11® Spreader Activator (Wilbur-Ellis Company)

• Activator 90 (Loveland Products)

• X-77® (Loveland Products)

• Pro-Spreader Activator (Target Specialty Products, Inc.)

• Latron AG-98TM (N) (Dow AgroSciences LLC)

• Latron AG-98TM (Dow AgroSciences LLC)

These surfactants usually include an alcohol as a solvent (isopropanol (Pro-Spreader Activator, AG-98TM), 

butanol (R-11®, AG-98TM (N)), glycol (AG-98TM (N), Activator 90)), a silicone defoamer 

(polydimethylsiloxane), and water.

Examples:

• Alcohol ethoxylate-based wetter/spreaders (non-ionic)

• Activator N.F. (Loveland Products) – may no longer be available

• Silicone-Based wetter/spreaders

Also known as organosilicones, these are increasing in popularity because of their superior spreading 

ability. This class contains a polysiloxane chain. Some of these are a blend of non-ionic surfactants (NIS) 

and silicone while others are entirely silicone. The combination of NIS and a silicone surfactant can 

increase absorption into a plant so that the time between application and rainfall can be shortened. This is 

known as rainfastness. The surfactants extreme spreading ability may lead to droplet coalescence and 

subsequent runoff if applied at inappropriately high rates.

Examples:

• Sylgard® 309 (Wilbur-Ellis Company) –silicones 

• Freeway® (Loveland Products) –silicone blend 

• Dyne-Amic® (Helena Chemical Company) - silicone blend

• Silwet L-77® (Loveland and Helena) – silicones

29 The use of product names is for illustrative purposes only and is not intended as a recommendation for use or an 

endorsement of these products by the USDA Forest Service.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix C

• Kinetic (Helena Chemical Company) – silicone blend

Blends normally include an alcohol ethoxylate, a defoamer, and propylene glycol.

Sticker/Spreaders

A sticker can perform three types of functions. It can increase the adhesion or "stickiness" of solid 

particles that otherwise might be easily dislodged from a leaf surface. It can also reduce evaporation of 

the pesticide. The third function can be to provide a waterproof coating. Many of the stickers contain 

surfactants as their principal functioning agent and are sold as spreader-stickers, which give both a sticker 

action and a wetter-spreader action. These will perform the first two functions quite well. Since the 

surfactants that provide wetter-spreader action must be somewhat water soluble, they may not provide 

good protection from rain. This will be provided by products that contain latex (rubber), polyethylene 

(plastic), resins (rosin), polymenthenes (rosin-like), or other waterproofing agents.

Examples:

• Bond® Spreader Sticker Deposition Aid (Loveland Products)

• TacticTM Sticker – Organosilicone surfactant – deposition agent (Loveland Products)

• R-56® Spreader Sticker (Wilbur-Ellis Co.)

• Cohere® Nonionic Spreader Sticker (Helena Chemical Co.)

Oils

Adjuvants that are primarily oil-based have been gaining in popularity especially for the control of grassy 

weeds. Oil additives function to increase herbicide absorption through plant tissues and increase spray 

retention. They are especially useful in applications of herbicides to woody brush or tree stems to allow 

for penetration through the bark. Oil adjuvants are made up of either petroleum, vegetable, or methylated 

vegetable or seed oils plus an emulsifier for dispersion in water.

Vegetable Oils – The methylated seed oils are formed from common seed oils, such as canola, soybean, or 

cotton. They act to increase penetration of the herbicide. These are comparable in performance to crop oil 

concentrates. In addition, silicone-seed oil blends are also available that take advantage of the spreading 

ability of the silicones and the penetrating characteristics of the seed oils. 

The U.S. Food and Drug Administration (FDA) considers methyl and ethyl esters of fatty acids produced 

from edible fats and oils to be food grade additives (CFR 172.225). Because of the lack of exact 

ingredient statements on these surfactants, it is not always clear whether the oils that are used in them 

meet the U.S. FDA standard.

Examples:

• MSO® Concentrate Methylated Seed Oil (Loveland Products)

• Hasten® (Wilbur-Ellis Company)

• The surfactant in PathfinderTM II (a triclopyr formulation)

• Improved JLB Oil Plus (Brewer International)

• Cide-Kick and Cide-Kick II (Brewer International)

• Cygnet Plus Spray Adjuvant (Brewer International)

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Appendix C-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Blends of vegetable oils and silicone-based surfactants

• Syl-tacTM (Wilbur-Ellis Company) 

• PhaseTM (Loveland Products)

Crop Oils and Crop Oil Concentrates - These are normally derivatives of paraffin-based petroleum oil.

Crop oils are generally 95-98 percent oil with 1-2 percent surfactant/emulsifier. Crop oils also promote 

the penetration of a pesticide spray. Traditional crop oils are more commonly used in insect and disease 

control than with herbicides. Crop oil concentrates are a blend of crop oils (80-85 percent) and a nonionic 

surfactant (15-20 percent). The purpose of the nonionic surfactant in this mixture is to emulsify the oil in 

the spray solution and lower the surface tension of the overall spray solution.

Examples:

• kerosene (found in the triclopyr formulation Garlon 4), 

• Agri-dex® (Helena Chemical Co. or Setre Chemical Co.)

• Red-Top Mor-Act® (Wilbur-Ellis Company)

• Herbimax (Loveland Products)

Fertilizer/Surfactant Mixtures

Nitrogen fertilizers (ammonium sulfate and ammonium nitrate) have been added to adjuvants to increase 

herbicide activity. These fertilizer solutions have improved the performance consistency on some weeds. 

Herbicides that appear to benefit from the addition of ammonium are the relatively polar, weak acid 

herbicides such as glyphosate, the sulfonylureas (Oust, Escort, Telar, etc.), and the imidazolinones 

(Arsenal, Plateau, Chopper, etc.). Velvetleaf and some grassy annual weeds in particular have been 

responsive to the addition of nitrogen fertilizer in the spray mix. Some broadleaves and grasses show little 

or no response with the inclusion of ammonium fertilizer solutions. Ammonium-based fertilizers and, in 

particular, ammonium sulfate (AMS) are being promoted to reduce potential antagonism with hard water.

Examples:

• First Choice® Exciter Activator (Western Farm Service)

• Magnify Activator – Penetrant (Monterey AgResources)

• Class Act® Next Generation (Agrilliance, LLC)

• Intensify Activator/Penetrant (West Link Ag)

Special Purpose or Utility Adjuvants

The special purpose or utility adjuvants are used to offset or correct certain conditions associated with 

mixing and application such as impurities in the spray solution, extreme pH levels, and drift. These 

adjuvants include acidifiers, buffering agents, water conditioners, anti-foaming agents, compatibility 

agents, and drift control agents.

The pH of most solutions is not high or low enough for important herbicide breakdown in the spray tank.

Acidifiers (example LI-700® and Tri-fol®) are sometimes recommended for use with herbicides because 

of greater absorption of weak acid type herbicides when the spray solution is acidic. 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix C

Examples:

• LI-700® Surfactant Penetrant Acidifier (Loveland Products)

• Tri-fol® Acidifier and Buffering Agent (Wilbur Ellis Company)

Drift reduction agents will generally increase the average droplet size to reduce the amount of fine 

droplets that are especially susceptible to drift.

Examples:

• In-Place® Deposition and Drift Management Agent (Wilbur Ellis Company)

• Sinker Polymer Carrier and Drift Retardant (Helena Chemical Company)

Defoamers are used to reduce the foaming that might occur during agitation of the spray mixture. They 

typically contain a silicone compound (dimethylpolysiloxane) as their principal active ingredient. Some 

also include small amounts of silicon. The silicone compound acts to reduce the surface tension of the 

mixture, so foaming is eliminated or reduced. The silicon particles physically burst air bubbles.

Examples:

• FoaminatorTM Dry (Agrilliance, LLC)

• No Foam (Wilbur Ellis Company)

• No Foam Dry (Wilbur Ellis Company)

• No Foam® B (Creative Marketing and Research)

Colorants

Colorants are added to an herbicide mixture prior to application so that the actual treated area can be 

readily determined. This helps to prevent skips and overlaps. It can also be useful for reducing human 

exposures to recently treated vegetation.

Examples:

• Hi-LightTM Blue (Becker-Underwood, Inc.)

• Colorfast® Purple (Becker-Underwood, Inc.)

Hazards

Of the adjuvants discussed in this paper, only two carry the Danger signal word 30 (EntryTM II and LI700®), which is due to the potential effects to the eyes (severely irritating or corrosive). The bulk of the 

remainder carry the Caution signal word, while several carry the Warning signal word (again because of 

potential irritant effects to the skin or eyes). None of these adjuvants carry the poison symbol. All of the 

adjuvants discussed here are no more than slightly toxic when ingested, inhaled, or absorbed through the 

skin (Acute Toxicity Categories III or IV).

30 Signal words are required on pesticide and registered adjuvant labels, and provide an overall view of the acute 

toxicity, or effects to eyes or skin, of the product. There are three signal words used by U.S. EPA, Danger, Warning, 

and Caution, to signify decreasing levels of this toxicity. In addition, the Danger signal word can be accompanied by 

the skull and crossbones symbol if the product is an acute poison. Refer to the table on Page 44. 

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Appendix C-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

The bulk of these adjuvants do not contain ingredients found on U.S. EPA’s inerts list 1 or 2. This is either 

based on the identified ingredients, or if these ingredients are not sufficiently identified, by information 

given by the manufacturers. The assessment of hazards for these adjuvants is limited by the proprietary 

nature of the formulations. Unless the U.S. EPA classifies a compound in the formulation as hazardous, 

the manufacturer is not required to disclose its identity. At the current time, the disclosure of whether a 

material is hazardous is based primarily on acute toxicity. There are two products listed that include 

ingredients on U.S. EPA’s inerts list 2 (Herbimax® Petroleum Oil-Surfactant Adjuvant (Loveland 

Products, Inc.) and In-Place® Deposition and Drift Management Agent (Wilbur-Ellis Co.).

The primary summary statement that can be made is that the more common risk factors for the use of 

these adjuvants are through skin or eye exposure. These adjuvants all have various levels of irritancy 

associated with skin or eye exposure. This points up the need for good industrial hygiene practices while 

utilizing these products, especially when handling the concentrate, such as during mixing. The use of 

chemical resistant gloves and goggles, especially while mixing, should be observed.

There is little toxicity testing done on these adjuvants. Most of the adjuvants have had some acute toxicity 

testing, as well as skin and eye irritation studies. 

Examples:

• Ethoxylated Fatty Amines

• EntryTM II (POEA)

Danger signal word (EntryTM II); Roundup® (includes POEA) signal word is either Warning or Caution, 

depending upon the formulation. Skin irritant, may be allergen. EntryTM II is severely irritating to 

corrosive to eyes (I31).

For a comprehensive look at POEA as a surfactant in the Roundup® formulation, refer to SERA 1997a 

and SERA 2003a. As EntryTM II is the same formulation as the POEA surfactant in Roundup®, these same 

references can be used.

EntryTM II and POEA both contain ethoxylated ingredients. Ethoxylates are formed by reactions of 

ethylene oxide. In the manufacturing process, some unreacted ethylene oxide as well as the contaminant 

1,4-dioxane can become part of the final formulation. Both of these chemicals are considered likely 

human carcinogens. For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, refer to 

Borrecco and Neisess 1991. For a comprehensive look at the risks of ethylene oxide in ethoxylated 

surfactants, refer to USDA, 2003.

Alkylphenol-ethoxylate-based wetter/spreaders

Examples:

• R-11® Spreader Activator (Wilbur-Ellis Co.)

Caution signal word. May cause skin irritation (III). Mildly irritating to the eyes (III).

• Activator 90 and X-77® (Loveland Products, Inc.)

The active ingredient in R-11® Spreader Activator, nonylphenol polyethoxylate, has been linked to 

estrogenic effects in wildlife, including aquatic species, such as fish and amphibians. For a 

31 The Roman numeral refers to the US EPA toxicity category (I, II, III, or IV) with I representing the category of 

highest toxicity and IV being the lowest. Refer to 40 CFR 156.62.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix C

comprehensive look at the nonylphenol ethoxylate surfactants, refer to USDA, 2003. Butanol and 

compounded silicone are both on EPA list 4B. Butanol is slightly more orally acutely toxic than the 

nonylphenol polyethoxylate. The compounded silicone is practically non-toxic on an acute oral basis (rat 

LD50 >17 g/kg).

Activator 90 has a Caution signal word while X-77® has a Warning signal word. Based on 

communications with the manufacturer, both products are fairly similar in formulation, and indeed, they 

consider the testing data between the two to be bridgeable (S. Baker, Loveland Products, Personal 

Communication 6/19/02, 8/15/02). Both may cause minor skin irritation (III). Both may cause severe 

reddening and swelling of the conjunctiva, with possible chemical burns (II). Both did not result in skin 

sensitization when administered to guinea pigs. It is likely that the signal word for Activator 90 should be 

changed to Warning, based on its effects to the eyes.

The MSDS describes a toxicity test involving guppies (not further described). Whether this refers to the 

freshwater aquarium fish Poecilia reticulata is not known. In this acute toxicity test, the 96-hour LC50 

was determined to be 12.7 mg/L, with a corresponding 96-hour NOEC of 5.8 mg/L. This is comparable to 

effects of other nonylphenol polyethoxylate-based surfactants on frogs (USDA 2003).

One of the active ingredients, nonylphenol polyethoxylate, has been linked to estrogenic effects in 

wildlife, including aquatic species, such as fish and amphibians. For a comprehensive look at the 

nonylphenol ethoxylate surfactants, refer to USDA 2003.

Tall oil fatty acid is a mixture of oleic, linoleic, and rosin acids derived from the hydrolysis of tall oil, a 

byproduct of wood pulp. Tall oil fatty acid is included in various cosmetics, such as hair dyes and 

bleaches, shampoos, skin cleansing preparations, and a shaving cream. Tall oil fatty acid is approved for 

use as an indirect food additive. When fed to rats as 15 percent of the total caloric intake, tall oil fatty acid 

was nontoxic; however, it had a growth-retarding effect. No treatment-related effects were observed in 

rats fed diets containing 5 percent and 10 percent tall oil fatty acid over two generations. Liquid soap 

formulations containing up to 12 percent tall oil fatty acid did not cause dermal irritation, sensitization, or 

photosensitization in human subjects. One study in rats indicated that this compound had little effect on 

reproduction. For further information, refer to Anonymous (1989).

The compounded silicone is practically non-toxic on an acute oral basis (rat LD50 >17 g/kg).

Diethylene glycol is practically nontoxic with an acute oral LD50 value in the rat of 12.5 g/kg.

The linear alcohol is not adequately described to say anything definite about its toxicology.

Activator 90 and X-77® contain ethoxylated ingredients. Ethoxylates are formed by reactions of ethylene 

oxide. In the manufacturing process, some unreacted ethylene oxide as well as the contaminant 1,4-

dioxane can become part of the final formulation. Both of these chemicals are considered likely human 

carcinogens. For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, refer to 

Borrecco and Neisess 1991. For a comprehensive look at the risks of ethylene oxide in ethoxylated 

surfactants, refer to USDA 2003.

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Example:

• Pro-Spreader Activator (Target Specialty Products)

Pro-Spreader Activator has a Caution signal word. It may cause skin irritation (III) and is mildly irritating 

to the eyes (III).

One of the active ingredients in Pro-Spreader Activator, nonylphenol polyethoxylate, has been linked to 

estrogenic effects in wildlife, including aquatic species, such as fish and amphibians. For a 

comprehensive look at the nonylphenol ethoxylate surfactants, refer to the USDA, 2003.

Pro-Spreader Activator contains ethoxylated ingredients. Ethoxylates are formed by reactions of ethylene 

oxide. In the manufacturing process, some unreacted ethylene oxide as well as the contaminant 1,4-

dioxane can become part of the final formulation. Both of these chemicals are considered likely human 

carcinogens. For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, refer to 

Borrecco and Neisess 1991. For a comprehensive look at the risks of ethylene oxide in ethoxylated 

surfactants, refer to USDA, 2003.

Example:

• Latron AG-98® (N) and Latron AG-98® (Rohm and Haas)

Both Latron AG-98® (N) and Latron AG-98® have a Warning signal word. Latron AG-98® (N) is 

considered moderately irritating to the skin, based on the nonylphenol ethoxylate and butanol ingredients.

Latron AG-98® is considered severely irritating to skin. Latron AG-98® (N) is severely irritating to the 

eyes, possibly resulting in conjunctivitis. Latron AG-98® is considered irritating to the eyes.

The active ingredients, nonylphenol polyethoxylate and octylphenol polyethoxylate, have been linked to 

estrogenic effects in wildlife, including fish and amphibians. For a comprehensive look at the 

nonylphenol ethoxylate surfactants, refer to USDA, 2003. For purposes of evaluation, the OPE surfactants 

can be considered equivalent to the NPE surfactants of the same ethoxylate number.

Butanol and compounded silicone (polydimethylsiloxane) are both on EPA list 4B. Butanol is slightly 

more orally acutely toxic than the nonylphenol polyethoxylate. The compounded silicone is practically 

non-toxic on an acute oral basis (rat LD50 >17 g/kg).

Latron AG-98® (N) and Latron AG-98® contain ethoxylated ingredients. Ethoxylates are formed by 

reactions of ethylene oxide. In the manufacturing process, some unreacted ethylene oxide as well as the 

contaminant 1,4-dioxane can become part of the final formulation. Both of these chemicals are considered 

likely human carcinogens. For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, 

refer to Borrecco and Neisess 1991. For a comprehensive look at the risks of ethylene oxide in 

ethoxylated surfactants, refer to USDA 2003.

Alcohol ethoxylate-based wetter/spreader

Example:

• Activator N.F. (Loveland Products)

Activator N.F. has a Caution signal word. This material may irritate the skin, and may cause eye injury.

Acute toxicity information was not available for this surfactant.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix C

Activator NF contains an ethoxylated linear alcohol; however, its exact composition is not specified.

Several of the articles discussed in the issue questions at the end of this paper concern ethoxylated 

alcohols.

Compounded silicone (polydimethylsiloxane) is on EPA list 4B. The compounded silicone is practically 

non-toxic on an acute oral basis (rat LD50 >17 g/kg).

Activator NF contains ethoxylated ingredients. Ethoxylates are formed by reactions of ethylene oxide. In 

the manufacturing process, some unreacted ethylene oxide as well as the contaminant 1,4-dioxane can 

become part of the final formulation. Both of these chemicals are considered likely human carcinogens.

For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, refer to Borrecco and 

Neisess 1991. For a comprehensive look at the risks of ethylene oxide in ethoxylated surfactants, refer to 

USDA 2003.

The large percentage of inert ingredients (74.75 percent) in this formulation is troublesome. It is unknown 

if this is all or mostly water or made up of other ingredients.

Silicone-based wetter/spreaders

Example:

• Sylgard® 309 (Wilbur-Ellis Co.)

Sylgard® 309 has a Warning signal word. It is considered slightly irritating to the skin and is considered 

severely irritating to the eyes. It is not a skin sensitizer. Besides the acute toxicity data displayed in Table 

1, the MSDS describes a 28-day oral dosing study in rats, in which rats were fed doses of 0, 33, 300, or 

1,000 mg/kg/day. No significant findings of biological relevance were seen in females, while males 

showed some effects at highest dose (body weight gain, and changes in food consumption). This would 

indicate a subchronic NOEL of 300 mg/kg/day.

There has been concern expressed about the toxicity of silicone-based surfactants on terrestrial insects.

Refer to issue discussion 2 on page 46.

Example:

• Freeway® (Loveland Products, Inc.)

Freeway® has a Caution signal word. Freeway® is mildly or non-irritating to the skin (Category IV), and 

is considered slightly irritating to the eyes (Category III).

The exact identity of the silicone-based components of Freeway® is unspecified. Whether it is of the 

same toxicity as the active ingredient in Sylgard® 309 is unknown, however these silicone based 

compounds are generally of low acute toxicity.

There has been concern expressed about the toxicity of silicone-based surfactants on terrestrial insects.

Compounded silicone (polydimethylsiloxane) is on EPA list 4B. The compounded silicone is practically 

non-toxic on an acute oral basis (rat LD50 >17 g/kg).

Propylene glycol is practically nontoxic to mammals, with an acute oral LD50 in rats of 20 g/mg.

Propylene glycol is generally regarded as safe (GRAS) by the US Food and Drug Administration, and is 

an additive in foods and personal care products (21 CFR 184.1666).

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Freeway® contains an ethoxylated alcohol; however, its exact composition is unknown. Several of the 

articles discussed in the issue questions at the end of this paper concern ethoxylated alcohols.

Freeway® contains ethoxylated ingredients. Ethoxylates are formed by reactions of ethylene oxide. In the 

manufacturing process, some unreacted ethylene oxide as well as the contaminant 1,4-dioxane can 

become part of the final formulation. Both of these chemicals are considered likely human carcinogens.

For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, refer to Borrecco and 

Neisess 1991. For a comprehensive look at the risks of ethylene oxide in ethoxylated surfactants, refer to 

USDA, 2003.

Example:

• Silwet L-77® (Helena Chemical Co.)

Silwet L-77® has a Warning signal word for both Loveland and Helena Chemical Company formulations.

Silwet L-77® may be slightly irritating to the skin, and is not a skin sensitizer. In a repeated skin 

application study with rats, this material caused moderate skin irritation that resolved during a postapplication recovery period. There was no evidence for cumulative or specific organ damage to the skin 

or other organs, and no effect on male or female reproductive systems. It is a severe eye irritant.

Based on information on one of the MSDSs, this material is not a mutagen, based on the Ames bacterial 

assay and three separate mammalian assays (Chinese hamster ovary gene mutation assay, a micronucleus 

cytogenetic assay in mice, and in an in vitro mammalian cytogenetic test).

Findings from a 14-day dietary feeding study with rats (no dosage specified) showed that repeated high 

doses caused reversible adverse effects on the male and female reproductive tracts. Other effects seen 

were increased liver weight, altered blood cytology/chemistry, and thyroid enlargement. Evidence of 

partial or complete recovery was seen over a 28-day recovery period.

In addition to the acute toxicity information in Table 1, the MSDS also lists a 96-hour EC50 (growth) for 

green algae of 5.5 mg/L, with a corresponding 96-hour NOEC of 1 mg/L.

There has been concern expressed about the toxicity of silicone-based surfactants on terrestrial insects.

Example:

• Kinetic Molecular Zippering ActionTM Brand (Helena Chemical Co.)

Kinetic has a Caution signal word. This material may be mildly irritating to the skin and eyes.

Kinetic is a mixture of a silicone-based surfactant and poloxalene. 

The exact identity of the silicone-based components of Kinetic is unspecified. Whether it is of the same 

toxicity as the active ingredient in Sylgard® 309 is unknown, however these silicone based compounds 

are generally of low acute toxicity. There has been concern expressed about the toxicity of silicone-based 

surfactants on terrestrial insects.

Poloxalene is of low toxicity on an acute oral basis, with an LD50 value in rats, mice and rabbits 

exceeding 3 g/kg (III). It is used as an oral veterinary treatment in cattle to cure legume bloat or as a 

feeding supplement to prevent bloat.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix C

Polyoxypropylene oleate butyl ether is probably a minor component of Kinetic, used as an antifoam 

agent. It is a product recognized by the US Food and Drug Administration as being generally safe when 

used as an antifoam agent in food packaging (21 CFR 176.200).

Sticker/Spreaders

Example:

• Bond® Spreader Sticker Deposition Aid (Loveland Products, Inc.)

Bond® has a Caution signal word. This material may be a slight skin irritant but is not a skin sensitizer 

and is a moderate eye irritant.

In addition to the aquatic toxicity test involving Daphnia, the current MSDS also describes a toxicity test 

involving guppies (not further described). In communications with the company, this description of a 

toxicity test involving fish is in error and should be deleted from the MSDS. The only aquatic test with 

Bond® involves Daphnia.

Bond® is a mixture of synthetic latex and a linear alcohol, along with 45 percent inert ingredients (not 

otherwise specified). The exact composition of the synthetic latex is not specified; it is likely acrylic latex.

The exact composition of the linear alcohol is not specified. Several of the articles discussed in the issue 

questions at the end of this paper concern ethoxylated linear alcohols.

The large percentage of inert ingredients (45 percent) in this formulation is troublesome. It is unknown if 

this is all or mostly water or made up of other ingredients.

Example:

• TacticTM Sticker – Organosilicone surfactant – deposition agent (Loveland Products, Inc.)

TacticTM has a Caution signal word. It may be a slight skin irritant, but is not a skin sensitizer. TacticTM is 

a mild to moderate eye irritant.

TacticTM is a blend of synthetic latex and a silicone-based wetter/spreader, along with a linear alcohol.

The exact composition of the synthetic latex is not specified; it is likely acrylic latex. The exact 

composition of the linear alcohol is not specified. Several of the articles discussed in the issue questions at 

the end of this paper concern ethoxylated linear alcohols.

The exact identity of the silicone-based components of TacticTM is unspecified. Whether it is of the same 

toxicity as the active ingredient in Sylgard® 309 is unknown, however these silicone based compounds 

are generally of low acute toxicity. There has been concern expressed about the toxicity of silicone-based 

surfactants on terrestrial insects. Refer to issue discussion 2 on page 46.

Propylene glycol is practically nontoxic to mammals, with an acute oral LD50 in rats of 20 g/mg.

Propylene glycol is generally regarded as safe (GRAS) by the US Food and Drug Administration, and is 

an additive in foods and personal care products (21 CFR 184.1666).

TacticTM contains ethoxylated ingredients. Ethoxylates are formed by reactions of ethylene oxide. In the 

manufacturing process, some unreacted ethylene oxide as well as the contaminant 1,4-dioxane can 

become part of the final formulation. Both of these chemicals are considered likely human carcinogens.

For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, refer to Borrecco and 

Neisess 1991. For a comprehensive look at the risks of ethylene oxide in ethoxylated surfactants, refer to 

USDA 2003.

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Appendix C-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Example:

• R-56® Spreader Sticker (Wilbur-Ellis Co.)

R-56® has a Caution signal word. This material may be irritating to the eyes (protective eyewear is 

required by the label). The MSDS states that ingestion may cause nausea, but that no chronic effects are 

known. There is little else toxicological information on this product.

R-56® is made up of a nonylphenol polyethoxylate of unknown ethoxylate length and an organic polymer 

that acts as the sticker. The exact identity of this polymer is not specified.

One of the active ingredients in R-56®, nonylphenol polyethoxylate, has been linked to estrogenic effects 

in wildlife, including aquatic species, such as fish and amphibians. For a comprehensive look at the 

nonylphenol ethoxylate surfactants, refer to the USDA, 2003.

R-56® contains ethoxylated ingredients. Ethoxylates are formed by reactions of ethylene oxide. In the 

manufacturing process, some unreacted ethylene oxide as well as the contaminant 1,4-dioxane can 

become part of the final formulation. Both of these chemicals are considered likely human carcinogens.

For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, refer to Borrecco and 

Neisess 1991. For a comprehensive look at the risks of ethylene oxide in ethoxylated surfactants, refer to 

USDA 2003.

Example:

• Cohere® Nonionic Spreader Sticker (Helena Chemical Co.)

Cohere® has a Warning signal word. The label states that eye exposure causes substantial but temporary 

eye injury; protective eyewear is required when handling.

Cohere® is made up of anionic alkanolamine and alkylaryl sulfate surfactants, which are not further 

identified. The most commonly used alkanolamine forms in surfactants are ethanolamine and 

triethanolamine, but it is unknown whether Cohere® contains these or another form. The descriptions on 

the label and MSDS are insufficient to further characterize these ingredients.

Propylene glycol is practically nontoxic to mammals, with an acute oral LD50 in rats of 20 g/mg.

Propylene glycol is generally regarded as safe (GRAS) by the US Food and Drug Administration, and is 

an additive in foods and personal care products (21 CFR 184.1666).

Oils

Example:

• MSO® Concentrate Methylated Seed Oil (Loveland Products, Inc.)

MSO® Concentrate Methylated Seed Oil has a Caution signal word. This material may be slightly 

irritating to the skin and to the eyes. The product is of low acute oral and dermal toxicity.

MSO® Concentrate Methylated Seed Oil is made up of an esterified vegetable oil and a linear alcohol 

wetter/spreader. The ethoxylated alcohol is an 11 carbon chain linear alcohol. Several of the articles 

discussed in the issue questions at the end of this paper concern ethoxylated linear alcohols.

Tall oil fatty acid is a mixture of oleic, linoleic, and rosin acids derived from the hydrolysis of tall oil, a 

byproduct of wood pulp. Tall oil fatty acid is included in various cosmetics, such as hair dyes and 

bleaches, shampoos, skin cleansing preparations, and a shaving cream. Tall oil fatty acid is approved for 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix C

use as an indirect food additive. When fed to rats as 15 percent of the total caloric intake, tall oil fatty acid 

was nontoxic; however, it had a growth-retarding effect. No treatment-related effects were observed in 

rats fed diets containing 5 percent and 10 percent tall oil fatty acid over two generations. Liquid soap 

formulations containing up to 12 percent tall oil fatty acid did not cause dermal irritation, sensitization, or 

photosensitization in human subjects. One study in rats indicated that this compound had little effect on 

reproduction. For further information, refer to Anonymous (1989).

MSO® Concentrate Methylated Seed Oil contains ethoxylated ingredients. Ethoxylates are formed by 

reactions of ethylene oxide. In the manufacturing process, some unreacted ethylene oxide as well as the 

contaminant 1,4-dioxane can become part of the final formulation. Both of these chemicals are considered 

likely human carcinogens. For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, 

refer to Borrecco and Neisess 1991. For a comprehensive look at the risks of ethylene oxide in 

ethoxylated surfactants, refer to USDA, 2003.

Example:

• Hasten® (Wilbur-Ellis Co.)

Hasten® has a Caution signal word. Hasten® may be mildly irritating to the skin and to the eyes. The 

product is of low acute oral and dermal toxicity.

The main ingredient in Hasten® is identified in Wilbur-Ellis product information as ethylated corn, 

canola, and soybean oil. This is combined with sorbitan alkylethoxylate ester as a nonionic surfactant.

The polyoxyethylene dialkylester is not sufficiently identified to say anything definite about its 

composition or toxicity.

Recently the Hasten formulation has been changed to remove the nonylphenol polyethoxylate and replace 

it with a sorbitan alkylethoxylate ester. This is not further identified.

Hasten® contains ethoxylated ingredients. Ethoxylates are formed by reactions of ethylene oxide. In the 

manufacturing process, some unreacted ethylene oxide as well as the contaminant 1,4-dioxane can 

become part of the final formulation. Both of these chemicals are considered likely human carcinogens.

For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, refer to Borrecco and 

Neisess 1991. For a comprehensive look at the risks of ethylene oxide in ethoxylated surfactants, refer to 

USDA, 2003.

Example:

• PathfinderTM II surfactant (Dow AgroSciences)

PathfinderTM II herbicide is a ready-to-use material that contains triclopyr herbicide in the butoxyethyl 

ester formulation combined with oil for use in treating woody plants. The surfactant is not identified 

except as a ‘naturally occurring non-petroleum diluent’. Based on information from the manufacturer, this 

diluent is on EPA list 4.

PathfinderTM II has a Caution signal word. It may cause skin irritation and slight eye irritation. From the 

MSDS, the 96-hour oral LD50 for rats is 1000 mg/kg (females), while the dermal LD50 for rabbits is 

>2,000 mg/kg. These values are not appreciably different from those for the butoxyethyl ester form of 

triclopyr alone. For information on the hazards and risks of using triclopyr herbicide, refer to SERA 

2003b as well as U.S. EPA 1998.

Example:

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Appendix C-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

• Improved JLB Oil Plus (Brewer International)

Improved JLB Oil Plus has a Caution signal word. It is a mild skin irritant, but is a severe eye irritant. 

Considered a mixture of all natural oils, it is made up of natural vegetable oils (unspecified) and limonene 

(as a penetrant). It is intended to be used in place of diesel or kerosene in stem basal applications. Some 

information from the manufacturer from the early 1990’s indicated the oil as being sunflower seed oil, if

this is indeed what is still in the formulation, this would be considered a food-grade additive. Limonene is 

a derivative of plant oils, particularly lemon, orange, caraway, dill, and bergamot. It is used as a food 

additive in chewing gum. For a comprehensive look at the use of limonene in surfactants, refer to USDA 

1992.

Example:

• Cide-Kick and Cide-Kick® IITM (Brewer International)

These adjuvants contain NPE (nonylphenol ethoxylate) and would not be used on the Malheur National 

Forest Invasive Plant project. 

Example:

• Cygnet Plus Spray Adjuvant for Pesticides (Brewer International)

Vegetable Oils and Silicone Blends

Example:

• Syl-tacTM (Wilbur-Ellis Co.)

Syl-tacTM has a Caution signal word. It may cause slight skin and eye irritation. Syl-tacTM is of low acute 

oral and dermal toxicity (refer to table 1). Syl-tacTM is a mixture of two other products (Hasten® and 

Sylgard® 309). Refer to the discussions of those two products.

Example:

• PhaseTM (Loveland Products, Inc.)

• PhaseTM has a Caution signal word. It may cause skin and eye irritation.

The exact identity of the silicone-based components of PhaseTM is unspecified. Whether it is of the same 

toxicity as the active ingredient in Sylgard® 309 is unknown, however these silicone based compounds 

are generally of low acute toxicity. There has been concern expressed about the toxicity of silicone-based 

surfactants on terrestrial insects.

PhaseTM contains an ethoxylated linear alcohol; however, its exact composition is not specified. Several 

of the articles discussed in the issue questions at the end of this paper concern ethoxylated alcohols.

PhaseTM contains ethoxylated ingredients. Ethoxylates are formed by reactions of ethylene oxide. In the 

manufacturing process, some unreacted ethylene oxide as well as the contaminant 1,4-dioxane can 

become part of the final formulation. Both of these chemicals are considered likely human carcinogens.

For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, refer to Borrecco and 

Neisess 1991. For a comprehensive look at the risks of ethylene oxide in ethoxylated surfactants, refer to 

USDA 2003.

Example:

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix C

• Dyne-Amic® (Helena Chemical Co.)

Dyne-Amic® has a Caution signal word. Dyne-Amic® is mildly or non-irritating to the skin (Category 

IV), and may be slightly irritating to the eyes (Category IV).

Dyne-Amic® is a mixture of a silicone-based surfactant, esterified vegetable oil, and an alkylphenol 

ethoxylate; however, the exact formulation of these ingredients is unknown. It is likely that the 

alkylphenol ethoxylate is nonylphenol ethoxylate, but that is not certain.

The exact identity of the silicone-based components of Dyne-Amic® is unspecified. Whether it is of the 

same toxicity as the active ingredient in Sylgard® 309 is unknown, however these silicone based 

compounds are generally of low acute toxicity. There has been concern expressed about the toxicity of 

silicone-based surfactants on terrestrial insects.

Nonylphenol polyethoxylate has been linked to estrogenic effects in wildlife, including fish and 

amphibians. For a comprehensive look at the nonylphenol ethoxylate surfactants, refer to USDA 2003.

Poloxalene is of low toxicity on an acute oral basis, with an LD50 value in rats, mice and rabbits 

exceeding 3 g/kg (III). It is used as an oral veterinary treatment in cattle to cure legume bloat or as a 

feeding supplement to prevent bloat. It could be used here as an anti-foam agent or as a nonionic 

surfactant.

Polyoxypropylene oleate butyl ether is probably a minor component of Dyne-Amic®, likely used as an 

antifoam agent. It is a product recognized by the US Food and Drug Administration as being generally 

safe when used as an antifoam agent in food packaging (21 CFR 176.200).

Dyne-Amic® contains ethoxylated ingredients. Ethoxylates are formed by reactions of ethylene oxide. In 

the manufacturing process, some unreacted ethylene oxide as well as the contaminant 1,4-dioxane can 

become part of the final formulation. Both of these chemicals are considered likely human carcinogens.

For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, refer to Borrecco and 

Neisess 1991. For a comprehensive look at the risks of ethylene oxide in ethoxylated surfactants, refer to 

USDA 2003.

Crop Oils and Crop Oil Concentrates

Example: 

• Kerosene 

Kerosene is included in Garlon 4 formulations of triclopyr. It is on EPA list 3. For a comprehensive look 

at kerosene, refer to SERA 2003b and USDA 1992.

Example:

• Agri-dex® (Helena Chemical Co.) and Red-Top Mor-Act® Adjuvant (Wilbur-Ellis Co.)

• Agri-dex® and Red-Top Mor-Act® both have a Caution signal word. They may be mildly 

irritating to the skin and eyes.

Although both materials are from different manufacturers, the identified ingredients are generically 

similar to discuss together.

The primary ingredient in both products is paraffin base oil. The paraffin base petroleum oil in Agri-dex® 

(83 percent of the formulation) is described as a solvent refined paraffinic distillate containing a mixture 

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Appendix C-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

of hydrocarbons having carbon numbers predominantly in the range C20-C50 (heavy paraffinic) or C15-

30 (light paraffinic). The light paraffin oil is also identified as horticultural spray oil. It is of low oral and 

dermal acute toxicity. The paraffin oil mixtures are not on the U.S. EPA inerts list, although other 

paraffinic oils are on List 2 and List 3. The oil mixture in Red-Top Mor-Act® (83 percent of formulation) 

is on U.S. EPA list 3. It is also referred to as mineral oil, with low acute oral toxicity (LD50 of 24 g/kg).

This oil is also used in many personal care products such as baby oil and cosmetics. The reason why 

certain paraffinic oils are on the U.S. EPA inerts list and others are not is not apparent (SERA 1997a).

The name polyol fatty acid ester refers to unspecified fatty acid esters of unspecified alcohols. Similarly, 

the name polyethoxylated polyol fatty acid ester refers to a group of chemicals that consist of unspecified 

fatty acid esters of unspecified polyethoxylated alcohols (SERA 1997a). Without further identity, no 

definitive statements can be made concerning the toxicity of these compounds.

Agri-dex® and Red-Top Mor-Act® contain ethoxylated ingredients. Ethoxylates are formed by reactions 

of ethylene oxide. In the manufacturing process, some unreacted ethylene oxide as well as the 

contaminant 1,4-dioxane can become part of the final formulation. Both of these chemicals are considered 

likely human carcinogens. For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, 

refer to Borrecco and Neisess 1991. For a comprehensive look at the risks of ethylene oxide in 

ethoxylated surfactants, refer to USDA 2003.

Example:

• Herbimax® Petroleum Oil-Surfactant Adjuvant (Loveland Products, Inc.)

• Herbimax® has a Caution signal word. This product may be mildly irritating to the skin and 

moderately irritating to the eyes.

The primary ingredient in Herbimax® is a light paraffin base oil and an oil-based solvent. The paraffin 

base petroleum oil in Herbimax® is described as a light paraffinic petroleum distillate. It is of moderate to 

low toxicity (acute oral LD50 > 5 g/kg, dermal LD50 >2 g/kg). The oil-based solvent is also referred to as 

light aliphatic solvent naphtha. High levels of acute naphtha exposure can result in central nervous system 

depression; studies have shown that chronic exposures are no more hazardous than the acute exposures.

Naphtha is a flammable material. Both the paraffin oil and the naphtha solvent are on EPA List 2 of 

potentially toxic inert ingredients.

The label and MSDS identify an alkylphenol ethoxylate as a minor component. This is likely to be a 

nonylphenol ethoxylate. Nonylphenol polyethoxylate has been linked to estrogenic effects in wildlife, 

including fish and amphibians. For a comprehensive look at the nonylphenol ethoxylate surfactants, refer 

to USDA, 2003.

The label and MSDS also identify tall oil fatty acid as a minor component. Tall oil fatty acid is a mixture 

of oleic, linoleic, and rosin acids derived from the hydrolysis of tall oil, a byproduct of wood pulp. Tall oil 

fatty acid is included in various cosmetics, such as hair dyes and bleaches, shampoos, skin cleansing 

preparations, and a shaving cream. Tall oil fatty acid is approved for use as an indirect food additive. 

When fed to rats as 15 percent of the total caloric intake, tall oil fatty acid was nontoxic; however, it had a 

growth-retarding effect. No treatment-related effects were observed in rats fed diets containing 5 percent

and 10 percent tall oil fatty acid over two generations. Liquid soap formulations containing up to 12

percent tall oil fatty acid did not cause dermal irritation, sensitization, or photosensitization in human 

subjects. One study in rats indicated that this compound had little effect on reproduction. For further 

information, refer to Anonymous (1989).

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix C

Herbimax® contains ethoxylated ingredients. Ethoxylates are formed by reactions of ethylene oxide. In 

the manufacturing process, some unreacted ethylene oxide as well as the contaminant 1,4-dioxane can 

become part of the final formulation. Both of these chemicals are considered likely human carcinogens.

For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, refer to Borrecco and 

Neisess 1991. For a comprehensive look at the risks of ethylene oxide in ethoxylated surfactants, refer to 

USDA, 2003.

Fertilizer/Surfactant Mixtures

Examples:

• First Choice® Exciter Activator – Penetrant (Western Farm Service, Inc.)

• Magnify Activator – Penetrant (Monterey AgResources)

• Class Act® Next Generation (Agrilliance, LLC)

• Intensify Activator/Penetrant (West Link Ag)

All four of these products are sufficiently similar so that they can be discussed together. All four have a 

Caution signal word. They are considered mildly irritating to the skin and eyes. It is assumed in this 

review that any toxicity data for the full formulations should be able to be used interchangeably with 

these four products. Class Act® may be an exception because of the differences with the ammonium 

compounds.

The wetter/spreader specifically identified in First Choice® is a corn syrup derivative, referred to as alkyl 

polyglycoside. It is assumed this is the same material used in the other three. This same surfactant product 

is sold under the trade name of Dow Triton CG-110. According to the MSDS for Dow Triton CG-110, this 

material is of low acute toxicity (oral LD50 > 5 g/kg, dermal LD50 >5 g/kg), although it is an eye irritant.

It is used as a detergent and wetter/spreader in personal care products such as shampoo and skin cream 

because of its mild skin effects. It is of low aquatic toxicity, with a 48-hour NOEC for Daphnia of 150 

mg/L and a 96-hour NOEC for fathead minnow of 125 mg/L.

The Class Act® label specifically identifies corn syrup as a component of the product. The other products 

list unidentified oligosaccharides, which could be corn syrup, or some other mix of simple sugars. It is 

unclear of the purpose of these sugars although these are listed as part of the surfactant mixture. Corn 

syrup is a common ingredient in foods.

The sources of nitrogen in these products are ammonium sulfate (in all four) and ammonium nitrate 

(found in all but Class Act®). Both chemicals are on EPA List 4B. Both are commonly used fertilizers in 

commercial garden products.

Ammonium sulfate is a water soluble compound. It is mildly irritating to the skin and eyes. It is of low 

oral toxicity, with a mouse LD50 of 640 mg/kg (III). In limited testing ammonium sulfate has not been 

shown to be a mutagen or carcinogen. It is of low aquatic toxicity, with a rainbow trout 96-hour LC50 of 

173 mg/L, a 96-hour EC50 for Daphnia of >100 mg/L, and an 18-day EC50 for green algae of 2,700 

mg/L. A recent study with three amphibian species showed that ammonium sulfate was more toxic to 

amphibians than the tested fish, with a 10-day NOEAC of 17 to 83 mg/L ammonium-nitrogen equivalent 

for the amphibians and 67 to 134 mg/L for fathead minnow (Nebeker and Schuytema 2000).

Ammonium nitrate is also a water soluble compound. In its dilute form as found in these products, it is 

mildly irritating to the eyes and skin; in its concentrated form, it can cause chemical burns. Ammonium 

nitrate has gained some notoriety as a component of low cost but dangerous explosive mixtures. It is of 

low acute toxicity , with an oral (rat) LD50 of >2 g/kg (III) and a dermal LD50 (rabbit) of >5 g/kg (III).

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Appendix C-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Hazards of oral ingestion include interference with the oxygen carrying capacity of the blood., respiratory 

irritation, and low blood pressure. It has not been demonstrated as a carcinogen, mutagen, or teratogen.

The dilute solution (20 percent) is of low aquatic toxicity with a fish (Chinook salmon, rainbow trout, 

bluegill) 96-hour LC50 of 420-1,360 mg ammonium-nitrogen equivalent/L. The Daphnia EC50 is 555 

mg/L. It can encourage algae growth, which may affect water quality. A recent study with red-legged frog 

embryos and larvae showed that ammonium nitrate was more toxic to this species of frog than the tested 

fish, with a 16-day LC50 of 72 mg/L and a 16-day NOEAC of 6.4 mg/L ammonium-nitrogen equivalent 

(Schuytema and Nebeker 1999).

The large percentage of inert ingredients (about 49 percent) in these products is troublesome. It is 

unknown if this is all or mostly water or made up of other ingredients.

Acidifiers

Example:

• LI-700® (Loveland Products, Inc.)

LI-700® has a Danger signal word, because of its corrosiveness (toxicity category 1 for both dermal and 

ocular effects) that is primarily due to the presence of methylacetic acid, also referred to as propionic 

acid. LI-700® is not exceptionally acutely toxic orally, dermally, or via inhalation. It is commonly used as 

an acidifier in pesticide mixtures.

The name phosphatidylcholine refers to a group of chemicals that consist of unspecified fatty acid 

diglycerides linked to the choline ester of phosphoric acid. This group includes the naturally occurring 

lecithins, which are prominent phospholipids in biological cell membranes. Soya lecithins are used as 

emulsifiers in a wide variety of food products (SERA 1997a). 

The nonionic surfactant contained in LI-700® is identified as alkyl polyoxyethylene ether, which is likely 

an ethoxylated linear alcohol; however, its exact composition is not specified. Several of the articles 

discussed in the issue questions at the end of this paper concern ethoxylated alcohols.

LI-700® may contain ethoxylated ingredients. Ethoxylates are formed by reactions of ethylene oxide. In 

the manufacturing process, some unreacted ethylene oxide as well as the contaminant 1,4-dioxane can 

become part of the final formulation. Both of these chemicals are considered likely human carcinogens.

For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, refer to Borrecco and 

Neisess 1991. For a comprehensive look at the risks of ethylene oxide in ethoxylated surfactants, refer to 

USDA 2003.

Examples:

• Tri-Fol Acidifier and Buffering Agent (Wilbur-Ellis Co.)

• Tri-Fol has a Caution signal word. It is an eye irritant and a mild skin irritant.

The acidifier in Tri-Fol is citric acid (25 percent of the formulation). Citric acid is of low oral toxicity 

(mouse LD50 > 3 g/kg (III)). Citric acid is used in many personal care products and is found in foods, 

although not to the concentration found in Tri-Fol. Citric acid in concentrated form can be severely 

irritating to the eyes and can cause skin sensitization.

Calcium chloride is of low oral toxicity (LD50 0.9 to 2.1 g/kg (III)). In concentrated liquid forms, it can 

be very irritating to the skin and eyes, and in its solid form if swallowed can react with water in an 

exothermic reaction that can cause burns. As a solid, it is not particularly toxic dermally (LD50 >5 g/kg, 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix C

III). It is of low aquatic toxicity with an LC50 in bluegill of 8,350 – 10.650 mg/L and an LC50 of 759 

mg/L with Daphnia. It is used in small amounts in some foods as a substitute for salt, or as part of 

electrolyte drinks. It is used as a de-icer for roads.

The large percentage of inert ingredients (66 percent) in this product is troublesome. It is unknown if this 

is all or mostly water or made up of other ingredients.

Drift Reduction Agents

Example:

• In-Place® Deposition and Drift Management Agent (Wilbur-Ellis Co.)

In-Place® has a Caution signal word. It is an eye irritant, and a mild skin irritant. None of the ingredients 

are sufficiently identified on the label or MSDS to characterize their risk. In older communications with 

the company, the Forest Service was told that the amine salts of organic acids were on EPA List 3 and 

were slight skin and eye irritants. The Forest Service was told that the aromatic acid is on EPA List 4 and 

is on the FDA’s list of materials generally recognized as safe.

Recently, the company has informed the Forest Service that the petroleum distillate (Stoddard solvent that

is on EPA’s List 2) has been replaced by a combination of a modified seed oil and a mineral oil. Both have 

been identified as being on EPA List 3. Neither is identified sufficiently to characterize their risk.

Example:

• Sinker Polymer Carrier and Drift Retardant (Helena Chemical Co.)

Sinker has a Caution signal word. It is a mild skin and eye irritant. The principal active ingredient cannot 

be identified exactly from the label or MSDS, however it might be polyacrylamide, which is of low oral 

toxicity and is used in many personal care products. While the label calls the active ingredient 

polyacrylamide, the MSDS calls the ingredient a blend of polyacrylamide polymers, so this 

characterization may not be accurate.

The large percentage of inert ingredients (70 percent) in this product is troublesome. It is unknown if this 

is all or mostly water or made up of other ingredients.

Defoamers

Example:

• FoaminatorTM Dry Antifoaming/Defoaming agent (Agrilliance, LLC)

FoaminatorTM has a Warning signal word. It is an eye irritant; the label calls for protective eyewear when 

handling. The label states that the material is harmful if swallowed, although no acute toxicity figures are 

available.

Compounded silicone (polydimethylsiloxane) is on EPA list 4B. The compounded silicone is practically 

non-toxic on an acute oral basis (rat LD50 >17 g/kg).

Polypropylene glycol (PPG) is a generic name for a large class of polymers. The exact size of the 

polypropylene glycol in FoaminatorTM is not specified. PPG is commonly used in personal care products 

such as shampoo. PPG is of low acute toxicity, with oral LD50 values from 2 to >15 g/kg (III-IV) and 

acute dermal LD50 values >10 g/kg (III).

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Appendix C-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Silicon dioxide is identified as part of the active ingredients in FoaminatorTM, although it is more 

commonly used as an inert carrier. It does have some insecticidal properties, but this is through physical 

abrasion of protective oils, causing desiccation rather than through direct insect toxicity. It is of low acute 

toxicity, with an oral LD50 value of 3 g/kg (III). Silicon dioxide is a processed food additive (an 

anticaking agent) allowed by US FDA (21 CFR 172.480). 

The large percentage of inert ingredients (84.5 percent) in this product is troublesome. As this is a dry 

formulation, this inert fraction is not water.

Examples:

• No Foam Defoamer (Wilbur-Ellis Co.)

• No Foam Dry Defoamer (Wilbur-Ellis Co.)

These two products contain the same active ingredients so can be discussed together. Both have a Caution 

signal word. Both are moderate eye irritants

The formulation of compounded silicone (polydimethylsiloxane) found in these two products is on EPA 

list 4B. The compounded silicone is practically non-toxic on an acute oral basis (rat LD50 >17 g/kg). On 

the No Foam label, this is identified as “food grade” active silicone.

The large percentage of inert ingredients (90 percent) in these products is troublesome. As No Foam Dry 

is a dry formulation, this inert fraction is not water. It is identified on the label as an inorganic/organic 

carrier. The inert in No Foam may be water.

Example:

• No Foam® B (Creative Marketing & Research, Inc.)

No Foam® B has a Caution signal word. No Foam® B is mildly irritating to the skin and eyes; the label 

requires waterproof gloves when handling. It is of low oral toxicity, with an LD50 value of >5 g/kg (IV).

The primary active ingredient in No Foam® B is the nonionic surfactant nonylphenol polyethoxylate. The 

older sample labels available on-line identify this as an octylphenol polyethoxylate whereas the newer 

MSDS identifies it as nonylphenol polyethoxylate. Nonylphenol polyethoxylate has been linked to 

estrogenic effects in wildlife, including aquatic species, such as fish and amphibians. For a 

comprehensive look at the nonylphenol ethoxylate surfactants, refer to the USDA 2003.

No Foam® B contains dodecylbenzene sulfonate, otherwise known as dodecylbenzene sulfonic acid.

Dodecylbenzene sulfonic acid is probably the compound meant to serve as a buffer in this product. It is of 

low oral toxicity, with an LD50 value of 650 mg/kg (III). In its concentrated form, being an acid, it is 

extremely irritating to the eyes and skin, as well as the respiratory tract.

There is an anionic surfactant, ethanolamine, that is identified on the No Foam® B label. It is of low acute 

oral toxicity with oral LD50 values ranging from 620 to 1720 mg/kg (III) and is moderately toxic 

dermally with an LD50 value of 1 g/kg (II). It is commonly used as an ingredient in personal care 

products, such as hand lotions and hair care products. In its concentrated form, it is a strong eye and skin 

irritant, and is moderately basic (pH of 10). Based on chronic tests, ethanolamine may be a reproductive 

and developmental toxicant. 

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix C

Sodium xylene sulfonate is included in No Foam® B as a minor component, probably to help the various 

ingredients stay dissolved in water. It is of low acute toxicity, with an oral LD50 of >5 g/kg (IV). It is of 

low aquatic toxicity with minnow and Daphnia acute NOECs of 1,000 mg/L. 

No Foam® B contains ethoxylated ingredients. Ethoxylates are formed by reactions of ethylene oxide. In 

the manufacturing process, some unreacted ethylene oxide as well as the contaminant 1,4-dioxane can 

become part of the final formulation. Both of these chemicals are considered likely human carcinogens.

For a comprehensive look at the risks of 1,4-dioxane in the POEA surfactant, refer to Borrecco and 

Neisess 1991. For a comprehensive look at the risks of ethylene oxide in ethoxylated surfactants, refer to 

USDA 2003.

The large percentage of inert ingredients (75 percent) in this product is troublesome. It is unknown if this 

is all or mostly water or made up of other ingredients.

Colorants

Example:

• ColorfastTM Purple

ColorfastTM Purple dye is not required to be registered, therefore it has no signal word associated with it.

It is mildly irritating to the skin, but because of the acetic acid content, can be severely irritating to the 

eyes, and can cause permanent damage. The label requires the use of acid-resistant gloves and goggles to 

prevent unnecessary exposures. It would likely be considered a Category 1 material and have a Danger

signal word if it carried one.

Acetic acid is the ingredient in household vinegar, although vinegars are normally 4-10 percent acetic 

acid whereas ColorfastTM Purple contains 23.4 percent by weight. Acetic acid is a very strong eye and 

skin irritant, and eye exposure can be very hazardous, with permanent damage a possibility.

Gentian Violet is the dye component of ColorfastTM Purple. Gentian Violet is used as an antifungal or 

antibacterial medication for dermal or mucous membrane infections. Gentian Violet is a suspected 

carcinogen, based on tests in mice. It is of moderate acute toxicity, with a LD50 value of 96 mg/kg (II).

For a comprehensive look at ColorfastTM Purple dye, including a risk assessment of the suspected 

carcinogen Gentian Violet, refer to SERA 1997b. 

Dipropylene glycol is of low acute and chronic toxicity. It is found in many personal care products. It is 

minor skin and eye irritant. It is not a carcinogen or a teratogen. The acute oral LD50 is 10.6 g/kg (IV) 

and the acute dermal LD50 is 20.5 g/kg (IV). At high (multi-gram) chronic doses, effects are seen to the 

kidney and liver. It is of low aquatic toxicity.

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Appendix C-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Example:

• Hi-Light® Blue

Hi-Light® Blue dye is not required to be registered as a pesticide; therefore it has no signal word 

associated with it. It is mildly irritating to the skin and eyes. It would likely be considered a Category III 

or IV material and have a Caution signal word if it carried one.

Hi-Light® Blue is a water-soluble dye that contains no listed hazardous substances. It is considered 

virtually non-toxic to humans. Its effect on non-target terrestrial and aquatic species is unknown, however 

its use has not resulted in any known problems. The dye used in Hi-Light® Blue is commonly used in 

toilet bowl cleaners and as a colorant for lakes and ponds (SERA 1997b).

Table C- 1. Standard Mammalian Acute Toxicity Testing Results32

Name Oral LD50 Dermal LD50 Inhalation LC50

Ethoxylated fatty amines

EntryTM II, POEA 1.2 to 14 g/kg (III) NA NA

Alkylphenol ethoxylate-based wetter/spreaders

R-11® >3.7 g/kg (NPEO) (III) >2 g/kg (NPEO) (III) >25 mg/L (est.) (IV)

Activator 90 3.87 to 5.0 g/kg (III) >2 g/kg (III) >1.33 mg/L in males (lowest) 

(III)

X-77® 3.87 to 5.0 g/kg (III) >2 g/kg (III) >1.33 mg/L in males (lowest) 

(III)

Pro-Spreader 

Activator >3.3 g/kg (III) >2 g/kg (III) NA

Latron AG-98® 

(N)

>5 g/kg (NPE) (IV)

0.79 g/kg (butanol) (III)

>3 g/kg (NPE) (III)

3.4 g/kg (butamol) (III) NA

Latron AG-98® 2 g/kg (III) 3 g/kg (III) NA

Alcohol ethoxylate-based wetter-spreader

Activator N.F. NA NA NA

Silicone-based wetter/spreaders

Sylgard® 309 >2 g/kg (III) >2 g/kg (III) NA

Freeway® >2 g/kg (III) >2 g/kg (III) NA

Dyne-Amic® >5.05 g/kg (IV) >2.02 g/kg (III) NA

Silwet L-77® >2.0 g/kg (III) >2 g/kg (III) NA

Kinetic 3.3 g/kg (III) >2 g/kg (III) NA

Sticker/Spreaders

Bond® >5 g/kg (IV) >2 g/kg (III) 4.73 mg/L (III)

TacticTM >5 g/kg (IV) >2 g/kg (III) >0.19 mg/L (4 hr)

R-56® NA NA NA

Cohere® NA NA NA

Oils

MSO® >5 g/kg (IV) > 4 mg/kg (III) NA

Hasten® >5 g/kg (IV) >5 g/kg (III) 5.79 ml/L (III)

32 NA indicates data was not available. Roman numerals in parentheses indicate the corresponding toxicity category 

(refer to page 41)

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix C

Name Oral LD50 Dermal LD50 Inhalation LC50

Improved JLB Oil 

Plus

>5 g/kg (IV) >3.16 g/kg (III) NA

Cide-Kick® >5 g/kg (IV) NA >5.16 mg/L (III)

Cide-Kick® IITM >5 g/kg (IV) >2 g/kg (III) >90.04 mg/L (IV)

Cygnet Plus NA NA NA

Blends of vegetable oils and silicone-based surfactants

Syl-tacTM >5 g/kg (IV) >5 g/kg (III) >2.07 ml/L (III)

PhaseTM >5 g/kg (IV) >2 g/kg (III) >0.19 mg/L

Crop Oils and Crop Oil Concentrates

Kerosene 28 g/kg (IV) >2 g/kg (III) NA

Agri-dex® >5.01 g/kg (IV) >2.02 g/kg (III) NA

Mor-Act® >5 g/kg (IV) NA NA

Herbimax® >5 g/kg (IV) >2 g/kg (III) NA

Fertilizer/Surfactant Mixtures

First Choice® 

Exciter

NA NA NA

Magnify NA NA NA

Class Act® Next 

Generation NA NA NA

Intensify NA NA NA

Acidifiers

LI-700® >5 g/kg (IV) >5 g/kg (III) >6.04 mg/L (III)

Tri-Fol NA NA NA

Drift Reduction Agents

In-Place® NA NA NA

Sinker >9.8 g/kg >9.8 g/kg NA

Defoamers

FoaminatorTM NA NA NA

No Foam NA NA NA

No Foam Dry NA NA NA

No Foam® B >5 g/kg (IV) NA NA

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Appendix C-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Table C- 2. Standard Acute Aquatic Species Toxicity Testing Results

Name Rainbow Trout 96-hour 

LC50 Bluegill 96-hour LC50 Daphnia 48-hour EC50

Ethoxylated fatty amines

EntryTM II, POEA 4.2 mg/L 1.3 – 2.9 mg/L 2.0 mg/L

Alkylphenol ethoxylate-based wetter/spreaders

R-11®

3.8 – 6 mg/L

NOEC 1 mg/L

4.2 mg/L

NOEC 1 mg/L

5.7 - 19 mg/L

NOEC (population size) 0.25 

mg/L

Activator 90 NA Guppy (Poecilia reticulata?) 

12.7 mg/L, NOEC 5.8 mg/L

5.2 mg/L (24 hour)

NOEC 1 mg/L

X-77®

NA 5 mg/L;

Guppy (Poecilia reticulata?) 

12.7 mg/L, NOEC 5.8 mg/L

5.2 mg/L (24 hour)

2.0 -16.4 mg/L (48 hour) (zero 

population growth con’c = 13 

mg/L)

Pro-Spreader 

Activator

3.3 mg/L

NOEC < 1.0 mg/L

6.0 mg/L

NOEC 1.8 mg/L

7.3 mg/L

NOEC 3.2 mg/L

Latron AG-98® 

(N)

NA NA NA

Latron AG-98® 10 mg/l 11 mg/l 21 mg/l

Alcohol ethoxylate-based wetter-spreader

Activator N.F. NA NA NA

Silicone-based wetter/spreaders

Sylgard® 309

NA Fathead minnow >4.6 mg/L 22.9 to >41 mg/L (zero 

population growth con’c = 18 

mg/L)

Freeway® NA 29.7 mg/L NA

Dyne-Amic® NA 26.9 mg/L NA

Silwet L-77®

NA Zebrafish 2.75 mg/L NOEC 

0.56 mg/L

6.2 – 23.4 mg/L (zero 

population growth con’c = 28 

mg/L)

NOEC 10 mg/L

Kinetic

NA 19.8 mg/L 111 mg/L (zero population 

growth con’c = 25 mg/L)

Sticker/Spreaders

Bond®

NA NA 614 mg/L (zero population 

growth con’c = 450 mg/L)

TacticTM NA NA NA

R-56® NA NA NA

Cohere® NA NA NA

Oils

MSO® NA NA NA

Hasten® 74 mg/L NA >50 mg/L 

Improved JLB Oil 

Plus

NA NA NA

Cide-Kick® 11 mg/l 10.2 - 18 mg/l 3.9 mg/l

Cide-Kick® IITM NA NA NA

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix C

Name Rainbow Trout 96-hour 

LC50 Bluegill 96-hour LC50 Daphnia 48-hour EC50

Cygnet Plus NA 30.2 mg/L NA

Blends of vegetable oils and silicone-based surfactants

Syl-tacTM >5 mg/L NA >5 mg/L

PhaseTM NA NA NA

Crop Oils and Crop Oil Concentrates

Kerosene NA NA NA

Agridex® 271 mg/L >1000 mg/L >1000 mg/L

Mor-Act® NA NA NA

Herbimax® NA NA NA

Fertilizer/Surfactant Mixtures

First Choice® 

Exciter

NA NA NA

Magnify >100 mg/L

NOEC 100 mg/L

NA 7.7 mg/L

Class Act® Next 

Generation

NA NA NA

Intensify NA NA NA

Acidifiers

LI-700® 17 - 130 mg/L 60.8 - 210 mg/L 170-190 mg/L

NOEC 100 mg/L

Tri-Fol NA NA NA

Drift Reduction Agents

In-Place® NA NA NA

Sinker NA NA NA

Defoamers

FoaminatorTM NA NA NA

No Foam NA NA NA

No Foam Dry NA NA NA

No Foam® B NA NA NA

Literature Cited In Bakke 2007

Anonymous. 1989. Final report on the safety assessment of tall oil acid. Journal of the American College 

of Toxicology. 8(4):769-776.

Borrecco, J., Neisess, J. 1991. Risk assessment for the impurities 2-butoxyethanol and 1,4-dioxane found 

in Garlon 4 and Roundup herbicide formulations. Pacific Southwest Region, Forest Pest 

Management. Report No. R91-2. 33 pages.

California Department of Fish and Game. 2003. An assessment of the hazard of a mixture of the herbicide 

Rodeo and the non-ionic surfactant R-11 to aquatic invertebrates and larval amphibians. Office of 

Spill Prevention and Response. Administrative Report 2003-002, written by Joel Trumbo Staff 

Environmental Scientist. December 2003. 17 pages.

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Appendix C-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Carr, K. 2001. Personal Communication. E-mail between Katherine Carr, Environmental Assessment 

Specialist, Monsanto Company, and Mike Taylor, Forest Botanist, Eldorado National Forest, 

February 5, 2001.

Haller, W.T., R.K. Stocker. 2003. Toxicity of 19 adjuvants to juvenile Lepomis macrochirus (bluegill 

sunfish). Environmental Toxicology and Chemistry. 22(3):615-619.

Nebeker, A.V., G.S. Schuytema. 2000. Effects of ammonium sulfate on growth of larval northwestern 

salamanders, red-legged and Pacific treefrog tadpoles, and juvenile fathead minnows. Bulletin of 

Environmental Contamination and Toxicology. 64(2):271-278.

Rice, Peter. 2003. Personal Communication. (University of Montana), 10/10/03

Schuytema G.S., A.V. Nebeker. 1999. Effects of ammonium nitrate, sodium nitrate, and urea on redlegged frogs, Pacific treefrogs, and African clawed frogs. Bulletin of Environmental 

Contamination and Toxicology. 63(3):357-364.

SERA (Syracuse Environmental Research Associates, Inc.). 1997a. Effects of surfactants on the toxicity 

of glyphosate, with specific reference to Rodeo. February 6, 1997. SERA TR 97-206-1b. 32 

pages.

SERA (Syracuse Environmental Research Associates, Inc.). 1997b. Use and assessment of marker dyes 

used with herbicides. December 21, 1997. SERA TR 96-21-07-03b. 47 pages.

SERA (Syracuse Environmental Research Associates, Inc.) 2003a. Glyphosate – Human Health and 

Ecological Risk Assessment – Final Report. March 1, 2003. SERA TR 02-43-09-04a. 281 pages.

SERA (Syracuse Environmental Research Associates, Inc.) 2003b. Triclopyr – Revised Human Health 

and Ecological Risk Assessments – Final Report. March 15, 2003. SERA TR 02-43-13-03b. 264 

pages.

Smith, B.C., C.A. Curran, K.W. Brown, J.L. Cabarrus, J.B. Gowan, J.K. McIntyre, E.E., Moreland, V.L. 

Wong, J.M. Grassley, C.E. Grue. 2004. Toxicity of four surfactants to juvenile rainbow trout: 

Implications for use over water. Bulletin of Environmental Contamination and Toxicology.

72(3):647-654.

Stark, J.D., W.K. Walthall. 2003. Agricultural adjuvants: Acute mortality and effects on population 

growth rate of Daphnia pulex after chronic exposure. Environmental Toxicology and Chemistry.

22(12):3056-3061.

United States Department of Agriculture (USDA), Forest Service. 1992. Risk Assessment for Herbicide 

Use in Forest Service Regions 1, 2, 3, 4, and 10 and on Bonneville Power Administration Sites.

September, 1992. 

USDA Forest Service, 2003. Human and ecological risk assessment of nonylphenol polyethoxylate-based 

(NPE) surfactants in Forest Service herbicide applications. Unpublished Report, written by David 

Bakke, Pacific Southwest Region Pesticide-Use Specialist. May 2003. 182 pages.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix D

Appendix D – Comments on the DEIS and Forest 

Service Responses

Introduction

This section describes the method used to process and evaluate public comments received at the Malheur

National Forest during the 45-day comment period for review of the Malheur National Forest SiteSpecific Invasive Plant Treatment Draft Environmental Impact Statement. Table D- 1 lists the 

commenters that responded to the DEIS in the order received and the comment number. Table D- 2 lists 

the comment number, comment, and Forest Service response.

Following the tables are the entire letters, in order received, from the United States Department of the 

Interior, United States Environmental Protection Agency, and Grant Soil and Water Conservation District.

Processing and Evaluating Public Comments

All letters and comments received about the Draft EIS were reviewed in their entirety. Comments were 

processed using the content analysis method, which consolidates substantive comments by subject, and 

helps resource specialists (e.g., wildlife biologists, hydrologists) respond to comments in their area of 

expertise. Substantive comments are those that relate specifically to the proposed project. Only the 

portions of comments that provided the main points or key issues are included here. Responses to 

comments are focused on comments raising issues, concerns, or problems. All comment letters are located 

in the project record.

Table D- 1. List of commenters

ID # First Name Last Name Organization Name City State

01 Dick Artley Grangeville ID

02 Dana Henze Denver CO

03 Allison O’Brien U.S. Department of 

Interior Portland OR

04 Doug Heiken Oregon Wild Eugene OR

05 Alese Colehour Eugene OR

06 Peter Garcia Eugene OR

07 Kyle Miskell Seattle WA

08 Karen Looney

09 Robert Marsh University of Washington Carnation WA

10 Maria Farinacci Fungi For the People

11 Christine Reichgott U.S. Environmental 

Protection Agency Seattle WA

12 Karen Coulter Blue Mountains 

Biodiversity Project Fossil OR

13 Denise Keenan Brighton CO

14 Matt

Jason

Wenick

Kehrberg

Grant Soil and Water 

Conservation District John Day OR

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Appendix D-Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement

Comment Response Regulations

This appendix is consistent with NEPA, 40 CFR 1503.4a: 

(a) An agency preparing a final environmental impact statement shall assess and consider comments both 

individually and collectively, and shall respond by one or more of the means listed below, stating its 

response in the final statement. Possible responses are to:

1. Modify alternatives including the proposed action.

2. Develop and evaluate alternatives not previously given serious consideration by the agency.

3. Supplement, improve, or modify its analyses.

4. Make factual corrections.

5. Explain why the comments do not warrant further agency response, citing the sources, authorities, or 

reasons that support the agency's position and, if appropriate, indicate those circumstances that would 

trigger agency reappraisal or further response.

One or more possible response types (1-5 above) are used for each comment in Table D- 2 that follows.

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Malheur National Forest Site-Specific Invasive Plants Treatment Final Environmental Impact Statement-Appendix D

Table D- 2. Commenter ID number, Comment and Forest Service Response

Commenter 

ID # Comment Forest Service Response

General Comments

07

It is also a large fault that the current plan does not make 

special consideration for areas containing the most herbicide 

vulnerable species, such as fish, pronghorn, and pollinators. I 

still want to be able to see and photograph young red band trout 

and songbirds when I hike these areas, and not miss them due 

to the influence of toxic herbicides.

Special consideration for fish and wildlife influenced the selection of herbicides in the 

R6 2005 Record of Decision and design of the Malheur EIS alternatives. Herbicideuse buffers for the Malheur project are based on the relative toxicity of various 

herbicides to fish, and project design features (pdfs) that would limit the use of certain 

herbicides to minimize adverse effects to fish (see pdfs H1 to H11 for Soils, Water, 

and Aquatic Ecosystems). Additional project design features would minimize impacts 

on pollinators, pronghorn, and songbirds; for instance, there are rate and spray 

method restrictions on some herbicides and project caps. A very small part of the 

Forest would be affected in any given year, and population viability of these species 

would not be affected by the project. See Chapters 3.3 (pollinators), 3.6 (fish) and 3.7 

(pronghorn and songbirds). 

12 There is a typo under Alternative B on page 63: (PCBs should 

be HCB) Thank you for pointing out this typo, which has been corrected in the FEIS. 

08

The health of our public lands must be preserved in order to 

protect the health of local and global human populations. In 

order to work toward this goal, we must re-think and limit the 

use of herbicides in the Malheur National Forest.

This is a general statement of opinion. Limitations on herbicide use have been 

included in the alternatives to minimize the potential for adverse effects, while still 

allowing for effective treatment of invasive plant management. The desired condition 

is for healthy native plant communities to remain diverse and resilient. 

05

Land management agencies have a legal mandate to conduct 

its affairs in an ecologically and socially sustainable manner. 

Threatened non-human species have a right to protection just 

as Oregon residents have a right to consume local sources of 

water, air, plants and animals without fearing risk to their health. 

Lack of herbicide reporting, limited laboratory testing, and 

disregard for non-timber forest product consumption is 

unacceptable.

The project is intended to be conducted in an ecologically and socially sustainable

manner. It follows management direction developed with years of public involvement. 

In the short term, individual, common, non-target plants are likely to be killed or 

reduced in population size where they are intermixed with invasive plants. However, 

in the long term, the project is intended to restore desirable native plant communities. 

Potential risk to public health is very low. 

Herbicide use is reported annually on National Forests. Laboratory studies have 

limitations (see DEIS pages 66, 200). However, they constitute best available 

science. The National Academy of Sciences recently found that “After 30 years of 

use and refinement, this risk-assessment paradigm has become scientifically 

credible, transparent, and consistent; can be reliably anticipated by all parties 

involved in decisions regarding pesticide use; and clearly articulates where scientific 

judgment is required and the bounds within which such judgment can be applied. The 

process is used for human health and ecological risk assessments and is used 

broadly throughout the federal government. Thus, the committee concludes that the 

... risk assessment ... process is singularly appropriate for evaluating risks posed to 

ecological receptors, such as listed species, by chemical stressors, such as 

pesticides” (NAS 2013). 

The risk assessments specifically address forest product consumption. Given the 

project design features, limited public exposure would be expected. Even if 

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Commenter 

ID # Comment Forest Service Response

inadvertent consumption occurred, the amount of herbicide a person may be 

exposed to would be below the threshold of concern. 

05

[The] timber industry in Oregon is not required to report timing, 

quantity or coverage of aerial spraying. This means area 

residents have no warning to take precautionary measures if 

they are concerned about chemical contamination around their 

homes, schools, and recreation areas. Furthermore, legal limits 

of herbicide use surpass our neighbors to the north and east, 

causing further concern for our public’s safety (Arkin, 2013). In 

2011, the Oregon Health Authority opened an investigation in 

the Hwy 36 corridor in response to formal complaints from area 

residents who were concerned when Atrazine, a commonly 

used herbicide in the timber industry, turned up in their urine 

The investigation failed to determine the source of the chemical 

contamination and furthermore, failed to carry out urine testing 

for other herbicides because there were no laboratories found 

that can test for these chemicals in human urine 

(http://public.health.oregon.gov/HealthyEnvironments/TrackingA

ssessment/EnvironmentalHealthAssessment/Hwy36/Document

s/Highway%2036%20PHA%20summary%20FS_final.pdf).

No aerial spraying is proposed. All pesticide use on the Malheur National Forest 

would be reported. No atrazine use is proposed. The amount of herbicide use for this 

project is very low compared to agricultural/timber industry use (DEIS pages 76-77). 

The types of herbicides proposed for use are not those associated with the concerns 

expressed in the Arkin or Hwy 36 citations. Concerns about legal limits are outside 

the scope of a Forest Service project. This Malheur National Forest project would 

follow Land and Resource Management Plan (LRMP) standards and guidelines for 

herbicide use and pdfs K1 and K2. High use areas, including administrative sites, 

developed campgrounds, visitor centers, and trailheads would be either posted in 

advance of herbicide application or closed. Postings would indicate the date of 

treatments, the herbicide used, and when the areas are expected to be clear of 

herbicide residue. The public would be notified about upcoming herbicide treatments 

via the local newspaper or individual notification, fliers, and posting signs. Forest 

Service and other websites may also be used for public notification. (DEIS page 41). 

05

The time has come for land management agencies to listen to 

the people, who represent critical components to Oregon’s 

ecosystems, and whose health is in danger when decisions are 

made without sufficient science demonstrating the safety of 

these chemicals, without access to laboratory testing when 

accidental ingestion is suspected, and without public 

knowledge, not to mention consent, of when and where them 

chemicals are deposited.

Best available scientific information forms the basis for the risk assessment 

information used in analysis for this project. Although the risk assessments have 

limitations (see R6 2005 FEIS pages 3-95 through 3-97), they represent the best 

science available. High use areas, including administrative sites, developed 

campgrounds, visitor centers, and trailheads would be posted in advance of herbicide 

application or closed. Postings would indicate the date of treatments, the herbicide 

used, and when the areas are expected to be clear of herbicide residue. The public 

would be notified about upcoming herbicide treatments via the local newspaper or 

individual notification, fliers, and posting signs. Forest Service and other websites 

may also be used for public notification (pdfs K1 and K2, DEIS page 41).

05

Aerial spraying and clear-cut of old-growth is out of fashion and 

directly violate federal mandates for ecologically and socially 

sustainable forestry.

This project does not propose aerial spraying or cutting timber. 

02

It is hard to agree with the use of herbicides especially since it 

would be broadcasted across vast areas, but compared to the 

harmful effects of invasive species on the natural ecosystem 

and its inhabitants the proposed treatment is the most cost 

effective, there has been large amounts of research done while 

choosing the herbicide that should be used and alternatives to 

the proposition.

This project does not involve broadcast treatment over vast areas. Most of the 

treatment sites are small (average size is less than an acre). The DEIS assumed that 

broadcast spraying would occur in infestations larger than 0.1 acre (DEIS, page 24). 

Best available scientific information has been used in the analysis. 

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Commenter 

ID # Comment Forest Service Response

01

As you already know, corporations will do anything for profit, 

including misrepresenting the safety of a toxic chemical they 

manufacture.

SERA Risk Assessments use best available scientific information, including 

independent studies, and are not prepared or paid for by any corporations.

12

Not necessarily do additional restrictions on herbicide use limit 

ability to effectively manage known and new sites, and besides 

if they do, these are acceptable trade-offs where protecting 

human health, water quality, soil productivity, native plant and 

wildlife viability, fish species, air quality, etc. should trump short 

or even long term invasive plant control effectiveness.

Treatment effectiveness is influenced by how many choices are available for any 

given infestation. Page 69 of the DEIS incorporated discussion from the R6 2005 

FEIS regarding treatment effectiveness: “In general, alternatives that have the widest 

variety of herbicides and herbicide families available for use have the greatest 

potential to result in effective treatments.” In contrast, when herbicide use is more 

restricted, “...fewer acres would likely be achieved at a constant budget, and the 

years to control increases proportionally” (ibid. page 4-21). This project is designed to 

protect human health, human health, water quality, soil productivity, native plant and 

wildlife viability, and fish species. This project does not have any impacts on air 

quality (see project design features table 10). 

12

We greatly appreciate and support this DEIS not including 

treatment of aquatic invasive plants, or use of aerial spraying, 

or scarification.

These treatment methods were not considered necessary for cost-effective treatment 

of invasive plants on the Malheur National Forest. 

12 Based on our field experience, many invasive plants have been 

introduced [by the vectors listed in table 24].

The cumulative effects analysis throughout the DEIS addressed the potential for 

invasive plants to be spread from these vectors and the interaction between these 

activities and effects from this project. 

12

Re: table 26: It makes sense to focus site-specific/projectspecific invasive plant surveys, prevention and monitoring on 

areas proposed for multiple ground disturbing activities in 

Silvies River, North Basin, and other areas with 2 or 3 activities 

and larger acreages of invasive plants. Create and apply 

adaptive management based on learning in these areas for 

future projects if funding is not adequate to give all upcoming 

projects site-specific intensive ground surveys, prevention plans 

and monitoring.

All of the projects planned by the Forest Service will include prevention measures 

and consideration of invasive plant spread as per the R6 2005 Record of Decision. 

“Intensive ground surveys” already occur in areas where invasive plants are most 

likely to be found. Invasive plant surveys occur each year and are influenced by 

ground-disturbing activities and events such as wildland fire. Monitoring also will 

occur, under the auspices of the invasive plant treatment project, with other projects 

planned throughout the Forest, and as a part of broader scale monitoring programs. 

The Implementation Planning Process and monitoring sections of the Invasive Plant 

Treatment DEIS made clear that the project is designed to allow invasive plant 

managers to adapt to changing conditions on the ground and that the integrated 

control measures are subject to change based on learning over time. The document 

also discussed priorities and objectives for invasive plant treatment, which are 

influenced by a variety of factors, including likelihood of ground disturbance in the 

area. Monitoring and adaptive management for invasive species will also occur under 

the auspices of the Collaborative Forest Landscape Restoration Approach (Appendix 

B).

12

Why should we be put in the position of not trusting the purity of 

plants, water, bushes, etc. in our cultural, recreational, spiritual, 

and economy-related food and medicine gathering on public 

and treaty lands? Where else can we go to gather native edible, 

medicinal, and cultural plants without fear of toxin 

The purpose and need of the project was explained on page 5 of the DEIS; which 

answers the question of why the Forest Service is proposing to use herbicides as a 

part of integrated invasive plant treatments. Many project design features are in place 

to help people avoid areas that have been sprayed. The project meets LRMP 

standards and guidelines, as well as other relevant management direction. A very 

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Commenter 

ID # Comment Forest Service Response

contamination if not public and treaty lands? These areas and 

periodic flushes can be easily identified and avoided. The 

statement that people who harvest these plants may be 

exposed to herbicide deeply offends me. We reject the idea that 

people should be forced to accept the poison of our public and 

treaty lands food and medicine.

small portion of the Forest would be affected by chemical use. 

12

The EPA is well known to have a revolving door syndrome 

whereby CEO’s and other executives of polluting corporations 

take shifts of working for the EPA, the fox watching the 

henhouse.

This comment is beyond the scope of the project. The R6 2005 Record of Decision 

provided direction for use of herbicides to treat invasive plants as part of an 

integrated weed management approach. 

12

Limiting the use of herbicides and not using herbicides in areas 

of high human exposure would be more effective than fallible 

pdfs.

The DEIS discussed how herbicide use has been limited to pose comparatively low 

risk to people and the environment. Not using herbicides would not meet the need to 

treat invasive plants using integrated treatment methods in cooperation with our 

neighbors and in accordance with current management direction, to reduce the 

extent and impact of invasive plants (DEIS page 5). The R6 2005 Record of Decision 

(Malheur Forest LRMP) standards require that the Forest Service minimize or 

eliminate direct or indirect negative effects to non-target plants, terrestrial animals, 

water quality and aquatic biota (including amphibians) from the application of 

herbicide... and to use site-specific project design (e.g., application rate and method, 

timing, wind speed and direction, nozzle type and size, buffers, etc.) to mitigate the 

potential for adverse disturbance and/or contaminant exposure (DEIS pages 8-9). 

This is the purpose of the pdfs and herbicide-use buffers. Trade-offs were examined 

in the DEIS. 

12 There should be no transportation of herbicides by watercraft.

Transportation by watercraft could be necessary for locations that are otherwise 

inaccessible. The pdfs (Group G, H2) provide adequate protection should this be 

necessary. 

12

We never run across a project with a finding that it will 

contribute to a trend toward federal listing. The “May Impact 

Individual or habitat (MIIH)” finding in practice is a rubber stamp 

determination. Rare and listed species are steadily declining to 

the point of extirpation due to logging, roading, grazing, and 

other common actions proposed on the Malheur National 

Forest, like bull trout, Chinook salmon, lynx, wolverine, marten, 

goshawk, amphibians, rare plants, etc. So the “MIIH” 

determination clearly understates the potential for cumulative 

extirpations and uplistings.

There is no indication that this project will lead to ESA listing or extirpation of any 

species of conservation concern. Determinations under the ESA and sensitive 

species policy apply to specific projects and are not intended to account for all 

cumulative impacts. However, projects planned on the Malheur National Forest are 

designed to minimize impacts to species of conservation concern and restore 

conditions that are outside the range of natural variability. While not all impacts to 

individuals can be guaranteed, and thus “may affect” or “may impact” findings and 

determinations are given to listed or sensitive species, the DEIS found that treatment 

of invasive plants in the action alternatives for this project would benefit native plant 

communities and wildlife habitats over the long term. For instance, page 108 of the 

DEIS stated, “a beneficial indirect effect of proposed treatments is that non-target 

plants would increase growth and abundance as competition from invasive plants is 

reduced.” Page 118 stated that action alternatives would benefit sensitive plant 

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Commenter 

ID # Comment Forest Service Response

species, while no action would have a long-term negative impact to sensitive plants. 

Page 147, regarding fish, stated, “treatments near the aquatic environment have the 

potential for short-term adverse impacts. In general, these adverse impacts are very 

small in comparison to the beneficial impact of the restoration [from effectively 

removing invasive plants].” Page 208 stated that “successful control of invasive plant 

infestations provides long-term benefits to wildlife, by restoring native habitats.” The 

DEIS considered whether this project, when combined with other foreseeable or 

ongoing projects, might have a cumulative effect. 

12

We remain unconvinced that notification and signing will not 

miss people in the area who were not notified or do not see 

signing.

In addition to notification and signing, colored dye would be used to mark treated 

areas. However, there is no way to guarantee that no inadvertent herbicide exposure 

would occur. However, the human health analysis found that there is very low risk of 

impact to the public because the amount of herbicide a person could be exposed to 

is predicted to be below the level thought to cause harm. Pdf L2 has been updated in 

the FEIS to ensure that specific edible/medicinal plant collection areas, along with 

specific areas of cultural or spiritual value, identified by the public are specifically 

posted prior to spraying. Postings would indicate the date of treatments, the herbicide 

used, and when the areas are expected to be clear of herbicide residue.

12 Use of vague, unquantified terms such as “minimal” do not 

qualify as adequate analysis.

These terms help characterize the extent and magnitude of effects, often along with 

measurements. 

12

It is my understanding that Canada thistle and St. Johnswort 

are not high priority for eradication (also sulfur cinquefoil). So 

why use herbicides for these plants in the first place? Especially 

with slopes with high runoff potential and creeks. Herbicides 

should not be used near bull trout and other listed fish streams, 

creeks and rivers.

Herbicides could be used to treat invasive plants as part of a strategy to suppress, 

contain, control or eradicate various populations of target plants. The pdfs are 

intended to minimize the adverse effects of using herbicides while still allowing for 

cost-effective treatments. Project design features and project caps are proposed to 

minimize the potential for herbicide introduction within the habitat of listed fish 

species. Model results for areas that both contain listed fish species, and with the 

highest concentrations of near-stream invasive plants in the project area, indicate 

that herbicide levels would remain well below levels of concern for all fish species.

12

Page 142-143 says that application within riparian zone would 

be direct to stems of invasive plants. Why is this only mentioned 

here?

This statement has been edited in the FEIS because it may have been misleading. 

Herbicide-use buffers allow foliar treatments within riparian areas. 

12 What are the public concerns about aminopyralid?

Aminopyralid is a new and potent herbicide. However, the 2007 risk assessment 

indicates it poses comparatively less risk to people and the environment than other 

herbicides approved in the R6 2005 Record of Decision. It may be more effective on 

broadleaf species; and can be used up to the water’s edge, allowing for effective 

treatments in riparian habitats. Alternative D was developed to show trade-offs 

associated with adding an herbicide to the list approved in the R6 2005 Record of 

Decision. 

12 What herbicides would not be buffered from streams?

The DEIS described the herbicide-use buffers on page 43. The buffers vary 

depending on the potential risks to the aquatic environment and other characteristics 

of each herbicide. Herbicide-specific buffers were developed for this analysis based 

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Commenter 

ID # Comment Forest Service Response

on risk assessment results regarding toxicity, persistence, and environmental fate. 

Herbicides were grouped by characteristics such as mobility and potential effects to 

fish and other aquatic organisms based on SERA risk assessments. Aminopyralid 

may be broadcast to the water’s edge or through dry stream channels because it 

poses such low risk to aquatic organisms. Aquatic labeled glyphosate and aquatic 

labeled imazapyr may be spot sprayed or applied in a hand/selective manner to the 

water’s edge or through dry channels. The intent is to allow for timely, effective 

treatments while minimizing adverse effects. 

11 We are also pleased to note that aerial application of herbicide 

is not among the alternatives considered.

Aerial application was not considered necessary to meet the needs of this project. 

Therefore, it was not included. 

11 Based on our review, we are rating the DEIS as LO (Lack of 

Objections). Thank you for your comments. 

13

According to your invasive plant treatment objectives standards 

12 and 13, you must identify the future desired conditions of the 

area before implementing a treatment. Control of the infestation 

rather than eradication is a viable and ecologically mindful 

solution.

DEIS table 1 (pages 7-8) described how standards 12 and 13 would be met with this 

project. The determination of treatment objective (eradicate, control, contain or 

suppress) is dependent on many factors. DEIS pages 17-18 described the reasoning 

for the control objectives for target species known on the Malheur National Forest. 

Passive and active restoration would be used to help restore desirable plant species 

on treated sites. 

11

The EPA supports treating invasive plant infestations in order to 

maintain or improve the diversity, function and sustainability of 

desired native plan communities and other natural resources 

that can be adversely impacted by invasive plant species. In our 

scoping May 2006 scoping comments, we recommended that 

the DEIS look across jurisdictional boundaries, include an early 

detection/rapid response plan, and adopt an Integrated Weed 

Management approach to addressing invasive plants. We 

believe the DEIS does an admirable job of incorporating these 

ideas.

Thank you for this comment. 

11

We appreciate the incorporation of “integrated treatment notes” 

within Table 8 (common control measures), as well as the 

robust structure of the project design features (pdfs) in Table 9. 

In particular, it is helpful to have a reference source for each of 

the project design features.

Thank you for this comment 

14

The Directors and Staff of the Grant Soil and Water 

Conservation District (District) are very pleased to learn the 

Malheur National Forest (Forest) is moving forward in 

completing the Environmental Impact Statement to authorize 

the Forest’s use of specific herbicides to treat noxious weeds. 

The District is confident that through the strategic and 

responsible application of these herbicide products, the Forest 

The DEIS discussed the cost-effectiveness of the alternatives and we concur that 

cooperative and continuous efforts will be needed to successfully reach control 

objectives laid out in the DEIS. 

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Commenter 

ID # Comment Forest Service Response

will experience much greater efficiency and effectiveness 

associated with their noxious weed control efforts. Upon 

authorization of the DEIS, the District is looking forward to 

sharing our expertise and capacity with the Forest to assist in 

the rapid advancement of their noxious weed control program. 

Successful containment and long term control of noxious weeds 

can only be realized through a continuous obligation from both 

private and public land managers. To that end, the District is 

very supportive of the Malheur National Forest Site-Specific 

Invasive Plant Treatment Project and will be looking forward to 

working cooperatively with the Forest on invasive plant 

management projects soon.

14

Implementation of the proposed control measures will provide 

direct protection to desired native plant communities, reduce 

noxious weed seed sources that can migrate to neighboring 

lands, and contribute positively to sustaining essential 

watershed functions of the Forest.

The DEIS discussed the cost-effectiveness of the alternatives and recognized that 

unless action is taken, “neighbors would continue to be frustrated in their attempts to 

enlist the Forest Service to help with partnerships to implement effective integrated 

treatments within and outside Forest boundaries (DEIS page 20). DEIS page 72 also 

acknowledged, “Cooperative treatments between neighboring land owners and 

agencies involved with invasive plant management would increase the effectiveness 

of alternative B and ensure weed spread between land ownerships is properly 

abated.” 

Prevention

12

There is not enough site-specific consideration of prevention 

measures that need to be taken to stop introduction and 

dispersal of invasive plants on the Malheur.

Prevention will continue to be a high priority regardless of alternative selected. The 

Malheur National Forest LRMP includes prevention goals, objectives and standards 

that apply to activities on the Malheur National Forest. The agency puts a high priority 

on prevention of invasive species. Page 7 of the DEIS outlined prevention measures 

that are being implemented on the Malheur National Forest.

12

The Forest Service needs to be dealing with the root causes of 

[invasive plants] in all their aspects and consider the sitespecific factors that may be key to preventing invasive plant 

introduction and dispersal.

12

Since both roads and streams disperse invasive plant seed, this 

suggests the need to close significant mileage of roads within 

300 feet of streams. This is doable but requires political will and 

education.

12

The DEIS fails to ask why invasive plants are concentrated in 

the Middle Fork John Day drainage and whether the answers to 

this could suggest site-specific prevention measures.

Reasons that invasive plants are concentrated in the Middle Fork of the John Day 

drainage include: 1) this area contains lower elevation lands where invasive plants 

are most prevalent; 2) this area has had a comparatively greater extent and intensity 

of ground disturbance, including grazing, mining, and logging; 3) this area has 

numerous private land inholdings, some of which have facilitated spread of invasive 

plants onto national forest system land; 4) the Forest Service has acquired some of 

the private land inholdings and their existing invasive plant infestations; 5) the density 

of roads and relatively high recreation use have resulted in the greater extent of 

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ID # Comment Forest Service Response

invasive plants; 6) large wildland fires in this area have created habitat for invasive 

plants; and 7) due to high public interest and use, this area may have had a greater 

number of invasive plant location reports than lesser used areas. Site-specific 

prevention measures are included in all projects that could lead to the spread of 

invasive plants (Invasive Plant Management Standard 1). 

04

We share the FS’ concern about invasive plants and we urge 

the FS to take aggressive action (including the use of effective 

and least-toxic chemicals) to remove them and reduce their 

spread. We however remain concerned that the increased 

emphasis on chemical treatment will lead the FS to become 

complacent about prevention. Avoiding conditions that allow 

weeds to spread (and minimizing the need for toxic chemical 

applications) should be the agency’s top priority.

Prevention will continue to be a high priority regardless of alternative selected. The 

Malheur National Forest LRMP includes prevention goals, objectives and standards 

that apply to activities on the Malheur National Forest. Page 7 of the DEIS outlined 

prevention measures that are being implemented on the Malheur National Forest. 

The need for suppression, eradication, control, and containment of invasive plants 

will still exist regardless of how the prevention standards from the R6 2005 Record of 

Decision, along with other management direction, are implemented. The R6 2005 

FEIS acknowledged that invasive plants will continue to spread, and treatment will 

continue to be needed; even with prevention measures applied to land uses (R6 

2005 FEIS 4.1.3). 

04 Better integration of objectives related to forest management 

and weeds will result in better outcomes.

The R6 2005 Record of Decision (Malheur National Forest LRMP) requires that weed 

prevention be integrated into all Forest Service activities in the Pacific Northwest 

Region. Table 24 of the DEIS (page 82) noted the prevention measures related to 

activities that may lead to the spread of invasive plants. 

08

I believe further research and analysis into controlling the root 

causes of invasive species will turn up more long-term and less 

toxic methods than herbicides.

This can be done regardless of alternative selected and is outside the scope of this 

document. 

12

So what will be done to reduce livestock introduction and 

dispersal of invasive plants along with ATV use? If nothing is 

done with this plan, other project staff will say its outside the 

scope of their project, passing the buck.

This is outside the scope of this invasive plant treatment project. Potential effects on 

invasive plants and prevention measures are considered for all projects on the 

Malheur National Forest. 

12

Re: table 24: AMPs and annual operating plans have been 

inadequate to control livestock vector influence. There is a lot of 

houndstongue by streams and we think it is due to livestock.

Allotment management plans and annual grazing instructions include prevention 

measures for invasive plants. Treatment of houndstongue would reduce potential 

seed source in allotments. Restoration may include keeping cattle away from treated 

areas until the area has recovered and contains desirable vegetation. Invasive plant 

treatment would be designed to improve riparian vegetation conditions on the 

Malheur National Forest. However, there is damage to riparian areas from livestock 

that would not be addressed by invasive plant treatment alone. Restoration of 

riparian areas damaged by grazing is outside the scope of the EIS. The FEIS has 

been edited to note that some portions of allotments, including riparian areas, have 

been more seriously degraded from cattle and that disturbance from cattle can 

increase susceptibility to invasive plants. Follow-up seeding and planting of native 

plants in treated areas would help to reduce the chances of re-infestation of invasive 

plant species.

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12 Is road maintenance being timed to avoid spreading invasive 

plants?

Yes, road maintenance activities are coordinated with invasive plant specialists to 

reduce the spread of weeds caused by road maintenance and rock removal from 

rock pits. Most road blading is done before or after seed emergence, limiting seed 

spread. Current blading techniques include depositing ditch material in designated 

sites to help prevent the spread of weeds to other road systems. Rock pits are 

inventoried for presence of invasive plants and would be treated before any rock is 

extracted for use in road maintenance or construction.

12 What is being done through this site-specific plan to reduce and 

control paved road vectors for invasive plants?

Treatment of invasive plants along paved roads and at designated ditch material 

disposal sites will help control the spread of invasive plants. Road maintenance 

activities would also help prevent the spread of invasive plants on roads. Road 

maintenance activities are coordinated with invasive plant specialists to reduce the 

spread of weeds caused by road maintenance and rock removal from rock pits. Most 

road blading is done before or after seed emergence limiting seed spread. Current 

blading techniques include depositing ditch material in designated sites to help 

prevent the spread of weeds to other road systems. Rock pits are inventoried for 

presence of invasive plants and would be treated before any rock is extracted for use 

in road maintenance or construction.

12 Re: table 24: The prevention considerations for the vector of 

roads does not deal with vehicles as vectors.

The DEIS discussed vehicle traffic as a vector for invasive plant spread (see page 

80). 

12

It sounds like Camp Creek HUC 5 roads by streams should be 

decommissioned to reduce both sediment and road to stream 

transport of invasive plant seeds. Why is this not considered in 

the DEIS analysis of prevention? Are there reasons that Camp 

Creek has such a high percentage of mapped invasive plants 

that should be considered and remedied?

Decommissioning roads is outside the scope of this project. Future projects planned 

in the Camp Creek watershed will consider measures to minimize the spread of 

invasive plants from these projects. Access and travel management planning will 

consider road closures and decommissioning. 

12 Re: table 24: What is the Canada thistle strategy? Why only 

Canada thistle?

Canada thistle often is introduced after vegetation management treatments, 

particularly within burn pile scars. The Canada thistle strategy highlights a part of the 

common control measures (Table 8) that advances soil biologic and physical 

recovery. Applied mulch leaches nutrients and can advance the succession of 

diverse soil microbes towards levels prior to burning. The slash amends the soil 

conditions to support a wider spectrum of vegetation. See discussion on page 81 in 

the DEIS.

12 Re: table 24: Cleaning equipment before entering the Forest 

should be not be exempt for emergency situations.

This is a standard from the R6 2005 Record of Decision that is incorporated into the 

Malheur National Forest LRMP. Changing this standard is outside the scope of this 

project. However, forests report that equipment cleaning is occurring in wildland fire 

situations (see Desser 2014 monitoring write-up). 

12

What about washing stations and educational signs at national 

Forest entrances, campgrounds, and administrative sites with 

pull outs and washing equipment and directions. The problem 

These suggestions are outside the scope of an invasive plant treatment project. 

Washing stations and educational signs could be considered as a part of prevention 

associated with travel management or other activities. 

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runs deeper than road construction materials.

12 The effects of prescribed fire in increasing suitable habitat for 

invasives needs to be addressed. Burning was included in table 24 (DEIS page 82). 

12

Part of invasive plant prevention and native plant restoration on 

the Malheur needs to be not logging so heavily as to provide 

ideal habitat for invasive plants, yet this is not discussed or 

proposed. Likewise, roads should be decommissioned and 

reforested and we need to get cattle and sheet overgrazing 

ended, but these are not proposed either. Instead, the Malheur 

Forest Service is busy escalating the pace of heavy logging 

across the forest and is not cancelling livestock allotment 

permits not meeting grazing standards. Why is this Malheur 

plan not proposing to do more to reduce livestock and logging 

conditions that encourage invasive plants? Analysis should lead 

to recommendations for actions to reduce impacts of 

disturbance that encourage invasive plants.

Prevention will continue to be a high priority regardless of the alternative selected. 

The Malheur National Forest LRMP includes prevention goals, objectives and 

standards that apply to activities on the Malheur National Forest. The agency puts a 

high priority on prevention of invasive species. Page 7 of the DEIS outlined 

prevention measures that are being implemented on the Malheur National Forest. 

The need for suppression, eradication, control, and containment of invasive plants 

will still exist regardless of how the prevention standards from the R6 2005 Record of 

Decision, along with other management direction, are implemented. The R6 2005 

FEIS acknowledged that invasive plants will continue to spread, and treatment will 

continue to be needed; even with prevention measures applied to land uses (R6 

2005 FEIS 4.1.3). Page 15 of the DEIS noted that programs including transportation

planning, timber management, and livestock grazing are required to implement 

prevention actions. Table 24 of the DEIS specifically noted the prevention measures 

related to activities that may lead to the spread of invasive plants. Page 115 

acknowledged that some forest activities could continue to spread weeds, 

recognizing that current forest management methods have reduced this potential. 

Prevention measures are included in allotment management plans and annual 

operating instructions, logging and other vegetation management plans, road 

construction plans and access and travel management plans. Some recent examples 

include the Soda Bear thinning project that includes several site-specific invasive 

plant prevention measures, the Summit Logan Valley Allotment Management Plan 

that includes prevention measures related to spring development and makes specific 

reference to reducing soil disturbance, and the Galena vegetation management that 

considers roads as a vector for invasive plant spread as a key issue for analysis. A 

review of several other projects found that invasive plant prevention was sitespecifically considered.

12

We are concerned that though prevention is identified as 

important, there is no serious attempt to reduce logging, 

livestock, ATV and road vector influence on a site-specific basis 

for spreading invasives.

12

How will this plan reduce and control logging and temporary 

road disturbance [that is] introducing and distributing invasive 

plants on the Malheur? The R6 2005 FEIS does not deal with 

prevention on a site-specific basis and does not adequately 

address livestock, roads, ATVs and logging as vectors. All the 

dumping of herbicides will not stop the problem of invasive 

plants continuing to be introduced and dispersed. There is a list 

in this DEIS of upcoming and ongoing timber sales, livestock 

grazing and road work. Without site-specific prevention 

measures, these projects will introduce and disperse more 

invasive plants. EIS analysis is intended by NEPA to suggest 

and lead to on-the-ground site-specific remedies to ecological 

damage problems.

12 Fire suppression and salvage logging as vectors can and 

should be reduced with this and other plans.

12

Re: table 25: How will vectors for invasive plant spread from 

proposed projects be managed to prevent spread of invasive 

plants? Specifically, blasting associated with decommissioning 

Bald Butte lookout, logging such as Soda Bear, Elk 16 and 

Galena, grazing allotment management, plantation thinning, 

Page 15 of the DEIS noted that programs including transportation planning, timber 

management, and livestock grazing are required to implement prevention actions. 

Prevention measures are included in allotment management plans and annual 

operating instructions, logging and other vegetation management plans, road 

construction plans and access and travel management plans. Some recent examples 

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ID # Comment Forest Service Response

fuel reduction projects. Why are new projects not discussed 

site-specifically in this [invasive plant treatment] DEIS to build in 

site-specific prevention plans?

include the Soda Bear thinning project that includes several site-specific invasive 

plant prevention measures, the Summit Logan Valley Allotment Management Plan 

that includes prevention measures related to spring development and makes specific 

reference to reducing soil disturbance, and the Galena vegetation management that 

considers roads as a vector for invasive plant spread as a key issue for analysis. A 

review of several other projects found that invasive plant prevention was sitespecifically considered.

12

How is the Forest Service going to prevent perpetual propagule 

pressure from traffic flow that spreads and causes the majority 

of invasive plant sites. Why is this not addressed on a sitespecific basis in this DEIS, despite our lawsuit over this subject 

in 2002? The R6 prevention measures are not site-specific 

enough to stop this traffic introduction and dispersal of invasive 

plants. General road traffic (public traffic) is still an issue. In 

Figure 8, page 130, roads are found to be the biggest source of 

ground disturbance. So what is the Forest Service going to do 

to prevent invasive plant introduction and dispersal via roads 

with 79% of current invasive plant sites there? This brings us 

back to our original concern that gave rise to our (successful) 

2002 lawsuit. Where is this addressed on a site-specific basis in 

this DEIS?

12

Livestock use, logging, road construction and use must be 

considered in this plan as vectors for introduction and dispersal 

of invasive plants and addressed sites specifically for planning 

effective prevention and control methods.

Prevention measures are included in allotment management plans and annual 

operating instructions, logging and other vegetation management plans, road 

construction plans and access and travel management plans. Some recent examples 

include the Soda Bear thinning project that includes several site-specific invasive 

plant prevention measures, the Summit Logan Valley Allotment Management Plan 

that includes prevention measures related to spring development and makes specific 

reference to reducing soil disturbance, and the Galena vegetation management that 

considers roads as a vector for invasive plant spread as a key issue for analysis. A 

review of several other projects found that invasive plant prevention was sitespecifically considered. 

06 / 10

The new [2005] Region 6 Invasive Plant Management Plan 

includes measures to prevent introduction and dispersal of 

invasive plants. However the Region 6 plan does not provide 

adequate site-specific prevention plans to stop the spread of 

invasive plants through ATVs (all-terrain vehicles), livestock, 

and roads as vectors, so the Malheur project must consider 

site-specific entry and dispersal points for invasive exotic plants 

and stop their introduction and dispersal through these vectors.

The invasive plant treatment DEIS acknowledged that prevention will slow but not 

stop the spread of invasive plants (page 71). Most of the invasive plants are 

associated with roads. DEIS page 110 noted that the median distance of mapped 

invasive plant sites to a road is 4 feet and more than 65 percent of known invasive 

plant sites are within 25 feet of a road center. The Malheur Access and Travel 

Management Plan is the appropriate place for this issue to be addressed. Prevention 

associated with livestock would be addressed in allotment management plans and 

annual operating plans. Prevention measures are included in allotment management 

plans and annual operating instructions, logging and other vegetation management 

plans, road construction plans and access and travel management plans. Some 

recent examples include the Soda Bear thinning project that includes several sitespecific invasive plant prevention measures, the Summit Logan Valley Allotment 

Management Plan that includes prevention measures related to spring development 

and makes specific reference to reducing soil disturbance and the Galena vegetation 

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management that considers roads as a vector for invasive plant spread as a key 

issue for analysis. A review of several other projects found that invasive plant 

prevention was site-specifically considered.

04

The spread of weeds is often caused by active management 

that disturbs soil and removes native vegetation, such as 

logging, roads, grazing, active fire suppression, and OHVs. The 

FS needs to integrate weed prevention principles into every 

single activity they conduct. All forest management activities 

should be adjusted in order to reduce soil disturbance and 

reduce vegetation disturbance. Undisturbed soil and native 

vegetation cover should be considered important values to be 

protected, but the FS too often disturbs soil and native 

vegetation in the pursuit of other management objectives (e.g. 

timber production, fuel reduction, livestock grazing) that are not 

adequately tempered by a concern for avoiding the spread of 

weeds.

The R6 2005 Record of Decision (Malheur National Forest LRMP) requires that weed 

prevention be integrated into all Forest Service activities in the Pacific Northwest 

Region. Page 15 of the DEIS noted that programs including transportation planning, 

timber management, and livestock grazing are required to implement prevention 

actions. Table 24 of the Malheur Invasive Plant Treatment DEIS specifically noted the 

prevention measures related to activities that may lead to the spread of invasive 

plants. Page 115 acknowledged that some forest activities could continue to spread 

weeds, recognizing that current forest management methods have reduced this 

potential. Page 130 noted that most of the existing invasive plants are mapped along 

road templates (83 percent). Page 131 noted that 6 percent of the [known] invasive 

plant sites correlate with timber harvest and wildfire events. Prevention measures are 

included in allotment management plans and annual operating instructions, logging 

and other vegetation management plans, road construction plans and access and 

travel management plans. Some recent examples include the Soda Bear thinning 

project that includes several site-specific invasive plant prevention measures, the 

Summit Logan Valley Allotment Management Plan that includes prevention measures 

related to spring development and makes specific reference to reducing soil 

disturbance and the Galena vegetation management that considers roads as a vector 

for invasive plant spread as a key issue for analysis. A review of several other 

projects found that invasive plant prevention was site-specifically considered.

08

Controlling other factors that contribute to the spread of 

invasives – such as ATVs, roads, and livestock – may have a 

more long-term impact. Livestock especially act to spread 

invasive plants, damage riparian areas, and remove grazing 

from native animals, as they are invasive species themselves. 

Prevention is a part of the integrated invasive plant management program but 

changing land uses is outside the scope of a treatment project. The R6 2005 FEIS, to 

which this analysis is tiered, addressed the factors that contribute to the spread of 

invasive plants and resulted in LRMP standards for integrating prevention into all land 

uses and activities. The Malheur National Forest site-specific DEIS also discussed 

vectors for the spread of invasive plants, including livestock. Prevention may slow the 

spread of invasive plants but would not suppress, contain, control or eradicate 

existing populations or sites detected in the future. Prevention measures are included 

in allotment management plans and annual operating instructions, logging and other 

vegetation management plans, road construction plans and access and travel 

management plans. Some recent examples include the Soda Bear thinning project 

that includes several site-specific invasive plant prevention measures, the Summit 

Logan Valley Allotment Management Plan that includes prevention measures related 

to spring development and makes specific reference to reducing soil disturbance, and 

the Galena vegetation management that considers roads as a vector for invasive 

plant spread as a key issue for analysis. A review of several other projects found that 

invasive plant prevention was site-specifically considered.

Alternatives

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06 / 10

There is an inadequate range of alternatives in that there is no 

alternative that would control exotic plants without any herbicide 

use—since this is seen as not effective enough and has already 

been tried on the Malheur since 2002.

If alternative A-no action is selected, the Forest Service would not treat invasive 

plants using herbicides. Alternative A would not approve any treatment, but nonherbicide treatments could continue under categorical exclusions and as actions 

connected to other projects. Alternative C minimizes use of herbicides and would 

require non-herbicide methods across the majority of currently infested sites. It 

includes an annual cap on herbicide use that is much lower than the other action 

alternatives and addresses many of the suggestions expressed in the scoping and 

DEIS comment letters. Thus, another alternative strictly limiting herbicide use was not 

developed for detailed study because of its similarity to alternatives A and C. Use of 

non-herbicide methods alone have not resulted in eradication, control, or 

containment of the current infestations. For fish and wildlife habitats, disturbance 

from non-herbicide methods that require more repeated entries could have greater 

effects than the herbicide use proposed. Discussion about why the Forest Service did 

not develop a “no herbicide” alternative for detailed study is in the FEIS. 

11

Overall, we .support the proposed alternative (Alternative B). 

Our comfort with Alternative B is enhanced by the inclusion of 

herbicide-use buffers and treatment caps. These features will 

limit the extent, intensity and duration of any potential adverse 

effects. We also support the inclusion of Figure 4 on page 50 of 

the DEIS, which lays out a series of questions to help determine 

whether, where, how, and under what pdfs herbicides should be 

applied.

Rationale for the selected alternative will be in the Record of Decision.

11

With regard to aminopyralid, we recognize this is a relatively 

new herbicide, and effective against a broad spectrum of plants. 

We maintain, however, that the best risk assessment 

information available (SERA 2007) 

concludes that:

“...Aminopyralid has a favorable human health toxicity profile 

when compared to the registered alternatives for these use 

sites and will be applied at a lower rate. Its residual action 

should alleviate the need for repeat applications, resulting in a 

reduction in the amount of herbicides applied to the 

environment for the control of these weeds. Aminopyralid has 

been determined to be practically non-toxic to non-target 

animals at the registered application rates, compared to the 

alternatives, and is less likely to impact both terrestrial and 

aquatic plants. “ Because the inclusion of aminopyralid within

the suite of herbicides available to the Forest would potentially 

reduce overall herbicide footprint on the Forest, we support the 

proposed LRMP amendment under Alternative B.

The DEIS compared the trade-offs associated with the LRMP amendment to allow for 

use of aminopyralid. 

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12 Alternative C still has too many acres of herbicide use allowed 

[over the life of the project].

The annual project caps limit the amount of acres that would be treated each year. 

Risk of adverse effects from herbicide use would not linger from year to year or 

accumulate over time given the project design features, herbicide use buffers and 

herbicide characteristics. This is discussed throughout Chapter 3 of the EIS. The life 

of the project cap has been removed. 

12 Some wildlife habitats need to be avoided with herbicide use 

such as riparian zone habitats.

The DEIS described limitations on herbicide use in all action alternatives to minimize 

adverse effects to wildlife habitats. In alternatives B and D, no more than 10 acres of 

herbicide use would occur per year within 100 feet of streams in any 6th field 

watershed. In alternative C, no herbicide would be used within 100 feet of any 

stream. Chapter 3.7 discussed the potential effects on wildlife, concluding that project 

design features restrict timing or application in sensitive habitats and minimize or 

eliminate likelihood for any species to receive harmful exposure to herbicide or 

disturbance. The rationale for selected alternative will be in the Record of Decision. 

12

We strongly support Alternative C with some protective 

modifications (see other comments). The inclusion of alternative 

C indicates that not using herbicides within 100 feet of water 

bodies, not using picloram, and not broadcast spraying and 

using much less herbicide overall constitutes a viable action 

alternative and the most ecologically benign or preferable 

alternative. We support alternative C because it would have 

less risk of herbicide exposure overall.

Trade-offs associated with the action alternatives were disclosed in the DEIS. While 

alternative C would allow for some herbicide use, it is less cost-effective due to 

restrictions on treatments near streams. The analysis did not demonstrate that these 

restrictions are necessary to protect people or the environment or to meet 

management direction for treating invasive plants. 

12 Alternative C does not eliminate human health risks but reduces 

them greatly.

Trade-offs associated with the action alternatives were disclosed in the DEIS. The 

restrictions in alternative C reduce the potential extent of herbicide exposure. 

However, the overall risk to human health is low in all alternatives. 

12

Alternative C is not the same as the other alternatives re: 

drinking water contamination; it is more effective in protecting 

streams.

Trade-offs associated with the action alternatives were disclosed in the DEIS. All 

alternatives protect drinking water. In all alternatives, drinking water sources would 

be buffered (pdf H9 prohibits herbicide use within 100 feet of wells or 200 feet of 

spring developments). Pdfs and herbicide-use buffers also limit herbicide offsite 

transport on sites with high runoff potential, restrict herbicide use rates, and buffers 

minimize potential for herbicide to reach streams in all alternatives. The amount of 

herbicide that could reach streams would be below a conservative threshold of 

concern for drinking water in all alternatives. The risk assessments assumed a child 

drinks water from a stream next to an unbuffered herbicide application. Even under 

this extreme and implausible scenario, the amount of herbicide that would reach the 

water was not above a threshold of concern for human health. 

12 Alternative C is not the same as the other alternatives; it is 

especially beneficial to non-target plants and pollinators.

Trade-offs associated with the action alternatives were disclosed in the DEIS. 

Alternative C is not as effective as the other action alternatives in treating invasive 

plants (see Chapter 3.1.4). 

12 Alternative C is more protective of wildlife than the other Trade-offs associated with the action alternatives were disclosed in the DEIS. 

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alternatives because it uses less herbicide. Alternative C is not as effective as the other action alternatives in treating invasive 

plants. (see Chapter 3.1.4).

12

We support Alternative C with some more protection and 

prevention modification. Alternative D uses too much herbicide 

that is highly toxic and persistent in the soil.

The rationale for the selected alternative will be in the Record of Decision. The 

“modifications” to alternative C suggested by this commenter were considered but not 

developed for detailed study because they would result in an alternative similar to the 

no action alternative. See Chapter 2.

12 Riparian zones are the source of highest levels of biodiversity 

on the forest-toxic poisoning should be prohibited.

Alternative C would not allow any herbicide use within 100 feet of streams or other 

water bodies. Alternatives B and D would allow some herbicide use in this area (up to 

10 acres per year within any 6th field watershed). In alternatives B and D, herbicideuse buffers would not allow broadcast treatments within 50 to 100 feet of the stream, 

and for some herbicides, spot, selective or hand treatments would not occur within 15 

feet of a stream. The trade-offs were discussed throughout the DEIS and alternatives 

were compared on pages 60 – 63 regarding the issues identified for this project. In 

addition, action alternatives include limitations (caps) on non-herbicide treatments 

other than biological control: No more than 50 acres within 100 feet of streams would 

be treated annually within any 6th field watershed). In alternatives B and D, of the 50 

acres, no more than 10 may be treated using herbicide. 

12

Re: table 42, low percentages of invasive plant acres by 

streams indicate alt C is a viable alternative. [We favor] no 

broadcast spraying and herbicide buffer of 100 feet.

Your comments will be considered in the Record of Decision, along with the analysis 

in the EIS that compares the trade-offs associated with each alternative. 

12 The extra safety and benign environmental effects of alternative 

C is well worth the extra cost and time to achieve objectives.

The DEIS considered the risks, benefits and trade-offs associated with the 

alternatives. The rationale for selected alternative will be in the Record of Decision. 

13

It is my hope that you will consider Alternative C as your 

recommended plan of action for control of invasive plant 

species. Use of bomb spraying techniques as well as the use of 

Picloram will only disrupt and degrade the forest ecosystem and 

have negative long term effects. As you review the EIS, I, along 

with other conservation biologists hope that you decide to utilize 

Alternative C in your approach to controlling invasive plant 

species in Malheur Forest. With alternative C, herbicides would 

not be used at any point within 100 feet of lakes, creeks, ponds 

or wetlands. This will limit leaching of any toxins into the fresh 

water systems. This will also limit application of the established 

10 herbicides to 30% of the proposed amount in alternative A. 

Alternative C will also disallow the use of the new herbicide 

ingredient Picloram. Invasive species are a threat to our 

national parks and all established ecosystems. The ability to 

control invasive species is a concern that is ever-present, but 

use of herbicides in a non-controlled system or bomb spraying 

will greatly affect the native plant and animal species in a 

No “bomb” spraying techniques are proposed in any alternative. The commenter 

likely is referring to “boom” spraying. Boom, or broadcast spraying, would be done in 

a controlled manner. Project design features specify how and under what conditions 

broadcast spraying may occur. 

Also, alternative A is the no action alternative, the commenter is likely referring to 

alternative B, which allows for use of picloram (not as a first-choice herbicide but an 

option should the first choice prove ineffective) and allows for some herbicide use 

near streams, according to herbicide-use buffers based on the potential mobility and 

toxicity of each herbicide proposed for use. The DEIS compared and contrasted the 

trade-offs from not allowing boom (broadcast) spraying and the use of picloram and 

the rationale for the selected alternative will be in the Record of Decision. 

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negative way. Alternative A is not a safe option for control of 

invasive plant species, and could alter the ecosystem as a 

whole in a negative way.

13

Picloram is a herbicide used to control noxious weeds in 

intermountain and forest regions. The usual administration is 

between 1.1-2.2. Kg/ha. The difficulty with this herbicide is that 

it tends to stay in the soil for long durations, and also is very 

susceptible to leaching into nearby structures such as 

neighboring trees, rivers and ponds. A study in Wyoming 

evaluated concentrations of Picloram were 2.7 and 1.8 mg. /I at 

distances as far as 10 meters from original point of 

administration. This represents significant leaching into nearby 

biota. Contamination of runoff water also persisted for up to 50 

days after initial application of Picloram. Alternative C will 

eliminate Picloram from being used, which will help conserve 

and preserve native plant, tree and animal species in Malheur 

Forest.

The DEIS discussed the potential mobility and persistence of picloram along with the 

other herbicides proposed for use. Project design features and herbicide-use buffers 

were proposed to ensure that if picloram is used, potential adverse effects would be 

minimized. Alternative A would not use any herbicide, including picloram. Alternative 

B does not specify picloram as a first-year, first-choice herbicide. Alternative C would 

eliminate the use of picloram, and alternative D would include some use of picloram 

for the first year of treatment. The DEIS discussed the trade-offs between 

alternatives. The comment did not cite the Wyoming study so it could not be 

evaluated by the IDT. 

13

With widespread herbicide use or bomb sprayingtechniques,

the ecological impact as well as human hazard is not 

minimized.

No “bomb” spraying techniques are proposed in any alternative. The commenter 

likely is referring to “boom” spraying. Alternatives B and D include broadcast spraying 

where it would be the most cost-effective method given the size, density and

distribution of target plants. The assumption that all known treatment sites were 

currently 100 percent infested was used to estimate the amount of broadcast 

spraying that could be needed. However, most sites are not 100 percent infested and 

more spot spraying would be likely in alternatives B and D than the boom spraying 

analyzed in the DEIS. The pdfs and herbicide-use buffers minimize the ecological 

impact and human hazard of all application methods. The DEIS compared and 

contrasted the trade-offs from not allowing boom (broadcast) spraying and the 

rationale for the selected alternative will be in the Record of Decision.

12 We support spot or hand application of herbicides over 

broadcast spraying and use less herbicide more selectively.

Alternative C does not allow any broadcast application. The rationale for the final 

selection of alternative will be in the Record of Decision. 

06 / 10

Alternative C seems to constitute a large reduction in herbicide 

use per year based on reserving herbicide use for the most 

difficult invasive plant species to eradicate or control otherwise 

that are also high priority for control or eradication. Alt. C is also 

preferable to the other herbicide use alternatives in that it 

avoids many herbicide impacts by not allowing broadcast 

spraying, herbicide use in riparian areas or near water, and not 

allowing the use of Picloram as a first choice herbicide.

Alternative C is not the preferred alternative because it is the least effective at 

meeting the purpose and need for action, and is the most expensive due to the need 

for more treatment entries. The analysis in the DEIS did not show alternative C to 

provide substantially greater benefits to any resource despite the decreased use of 

herbicide. 

12 The Alternative Comparison table is misleading because 

aminopyralid is not the only herbicide proposed in alternative B.

The “alternative comparison relative to significant issues” tables in the summary and 

in chapter 2 have been edited in the FEIS in response to this comment. Other 

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ID # Comment Forest Service Response

herbicides (than the first-year, first-choice) may be used depending on the sitespecific situation at the time of treatment. Over time, integrated treatments may 

change depending on lessons learned each year. However, the implementation 

planning process ensures that site-specific treatments follow project design features, 

herbicide-use buffers, and treatment caps

12 Wouldn’t alternative C be more protective to drinking water? 

This is not clear in issue comparison table.

All alternatives protect drinking water. The additional buffers and restrictions in 

alternative C would result in less possible herbicide exposure. However, this would 

not result in a substantial difference to drinking water impacts. 

12

We are opposed to alternative D because of the use of 

picloram, broadcast spraying, and greater use of more toxic 

herbicides such as chlorsulfuron, metsulfuron methyl, and more 

use of herbicides in general, instead of prioritizing non-chemical 

methods.

Alternative D, along with the other action alternatives, would use non-herbicide 

methods where cost-effective. Alternative D would not require a LRMP amendment 

approving use of aminopyralid. However, as a result, relatively more picloram may be 

used. 

07

I am also greatly disturbed by your lack of alternative plans that 

do not rely on toxic herbicide use. While it is true that 

Alternative C proposes the use of less herbicides, and I am 

happy that it does not allow spraying in riparian areas, 

broadcast spraying, and Picloram as first choice, it still plans to 

spray in areas with plants frequently foraged for by humans. 

The no action alternative would not approve any herbicide use on the Malheur 

National Forest. As stated in the DEIS on pages 17, “Under alternative A-no action, 

invasive plant treatments would not be authorized as part of a decision on this 

project-level EIS; projects similar to the current program would likely be authorized 

under categorical exclusions or connected actions associated with other project 

decisions.” Page 19 stated that under the no action alternative, “categorical 

exclusions may be completed to authorize manual and limited mechanical treatments 

in site-specific areas.” 

12

There should be another alternative besides no action that does 

not use herbicides. Since non-herbicides methods are in use on 

the Forest, a true no action alternative would continue their use.

Page 17 of the DEIS noted that under alternative A-no action, invasive plant 

treatments would not be authorized as part of a decision on this project-level EIS. 

However, “projects similar to the current program would likely be authorized under 

categorical exclusions or connected actions associated with other project decisions.” 

All action alternatives would continue to use non-herbicide methods in combination 

with herbicides. Discussion about why the Forest Service did not develop a “no 

herbicide” alternative for detailed study is in the FEIS.

08

If herbicides are to be used, there should be a mandatory 

tapering of their use over time; for example, an 80% reduction 

of herbicide use at 5 years out, 20% more reduction after 8 

years, 90% reduction by 10 years, no herbicide use by 15 years 

from the beginning of this project’s implementation, with full 

public disclosure of progress and setbacks and public 

involvement in deciding how to address failures to meet goals.

This idea is not implementable at the project scale due to the uncertainty of funding 

over time. However, the desired condition is that the need for invasive plant treatment 

is reduced due to the effectiveness and habitual nature of preventative actions, and 

the success of restoration efforts. Reduced reliance on herbicides would be expected 

at effectively treated sites (see section 3.1.4, Treatment Effectiveness). The more 

effective the integrated treatment, the less need for herbicide in the future. See DEIS 

page 59. 

06 / 10

Members of the public asked for consideration of several 

alternatives that could have been considered as part of 

proposed alternatives, yet were eliminated from “detailed study” 

consideration. These included:

Evaluate effectiveness of invasive plant control by disinterested third party before 

new control measures are adopted: 

This alternative was considered but not developed for detailed study because it “is an 

opinion not supported by law or policy and is outside the scope of the analysis in the 

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--evaluating the effectiveness of past invasive plant control by a 

disinterested third party before new control measures were 

adopted.

--limitations on herbicide-use rates for all herbicides to avoid the 

riskiest maximum rates

--a mandatory decline of herbicide use over time—e.g. an 80% 

reduction of herbicide use at 5 years out,, 20% more reduction 

after 8 years, 90% reduction by 10 years, no herbicide use by 

15 years from the beginning of this project’s implementation, 

with full public disclosure of progress and setbacks and public 

involvement in deciding how to address failures to meet goals. 

We think this is necessary for accountability.

--use of herbicides as the last resort (this was rejected in the 

Region 6 plan)

--use of herbicides for only the highest priority target species 

(partially met by alt. C)

--No herbicide use in a variety of areas—e.g. fish habitat, 

riparian areas, municipal watersheds, wildlife habitat, areas with 

edible plants, cultural plant gathering areas, roadless and 

undeveloped areas, and in developed areas like campsites and 

along trails.

--No early detection/rapid response use of herbicides. While we 

remain concerned that newly discovered invasive plant sites 

should be analyzed for site-specific effects from control 

measures, the Forest Service feels this would prevent timely 

control of new infestations, when they are most susceptible to 

eradication.

At least some of these public proposals should have been 

thoroughly analyzed and considered as part of proposed 

alternatives or as separate alternatives to address concerns.

EIS. It would not address the need for treatment flexibility or rapid response to newly 

detected infestations. It would not expand the treatment toolbox or bring the program 

into alignment with Malheur National Forest LRMP guidance.” (DEIS page 54). 

However, the public is welcome to work with us to evaluate effectiveness of invasive 

plant control. History at treated sites is part of the Implementation Planning Process 

discussed on pages 48-51 in the DEIS. 

Limitations on herbicide use rates for all alternatives to avoid the riskiest maximum 

rates:

As explained on page 55 of the DEIS, “Limitations on certain herbicide ingredients, 

rates, and application methods are already part of the action alternatives to ensure 

that the adverse impacts of treatments are minimized.” The lowest amount of 

herbicide necessary to meet treatment objectives is part of the design of all action 

alternatives (pdf F2) and in some cases, rates have been specifically limited to 

address a specific human health or environmental concern. However, a general limit 

on application rates was not considered for detailed study because it would not 

further minimize adverse effects and could impede treatment effectiveness. 

A mandatory decline in herbicide use over time:

This idea is not implementable at the project scale due to the uncertainty of funding 

over time. However, the desired condition is that the need for invasive plant treatment 

is reduced due to the effectiveness and habitual nature of preventative actions, and 

the success of restoration efforts. Reduced reliance on herbicides would be expected 

at effectively treated sites (see section 3.1.4, Treatment Effectiveness). The more 

effective the integrated treatment, the less need for herbicide in the future. See DEIS 

page 59. 

Full disclosure of setbacks and public involvement in deciding how to address 

failures:

This idea could be integrated into any treatment alternative. We are willing to involve 

the public in evaluating progress on this project and can provide information by 

request. The implementation planning process presented in the DEIS considers past 

treatment history when developing integrated treatment prescriptions (see DEIS page 

48).

The use of herbicides as a last resort:

The Forest Service needs the ability to implement treatment actions to more 

effectively contain and reduce the extent of invasive plants at existing inventoried 

sites, and rapidly respond to new or expanded invasive plant sites as they may occur 

in the future. The purpose and need for the project involves using integrated 

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treatment methods in cooperation with our neighbors and in accordance with current 

management direction, to reduce the extent and impact of invasive plants. Current 

management direction does not require the use of herbicides as a last resort. As 

noted, in the R6 2005 Record of Decision, the Regional Forester considered but 

rejected this alternative, partially because using herbicides as a tool of last resort 

would have deviated from integrated weed management principles (R6 2005 Record 

of Decision page 6, page 27). However, herbicides would only be used where 

necessary. The DEIS noted (page 49), “If the target invasive species population is 

not associated with a size, phenology, density or distribution that warrants herbicide 

use (alone or in combination with other methods), or if herbicide use does not 

substantially increase treatment efficiency (considering the availability of volunteers if 

needed), then non-herbicide methods would be favored.”

No use of herbicides in a variety of areas:

Alternative C includes some of these suggestions by eliminating herbicide use near 

streams and other water bodies. Taken in total, this suggestion would be 

commensurate with no action, since all of the Forest provides some sort of wildlife 

habitat. As stated in the DEIS on pages 17, “Under alternative A-no action, invasive 

plant treatments would not be authorized as part of a decision on this project-level 

EIS; projects similar to the current program would likely be authorized under 

categorical exclusions or connected actions associated with other project decisions.” 

Page 19 stated that under the no action alternative, “categorical exclusions may be 

completed to authorize manual and limited mechanical treatments in site specific 

areas.” However, the current lack of sufficient methods in the toolbox for treating 

invasive plants is hampering the agency’s ability to meet the desired condition for 

healthy native plant communities. 

No early detection/rapid response:

This idea would not meet the need to effectively treat invasive plants as soon as 

possible after they are detected. As stated on page 6 of the DEIS, “Invasive plant 

spread is unpredictable and actual locations of target species may change abruptly 

over time. Accordingly, the Forest needs the flexibility to adapt to changing 

conditions, and rapidly respond to invasive plant threats that may currently be 

unknown. Timeliness of action is an important factor because the cost, difficulty, and 

potential adverse effects of controlling invasive plants increases with the size and 

extent of the population. The smaller the population when treated, the more likely the 

treatment will be effective. The Forest needs a way to effectively treat invasive plants 

as soon as possible after they are detected.”

12 Which is the preferred alternative? This should have been 

disclosed in the DEIS.

A preferred alternative was not determined by the time the DEIS was published. After 

reviewing the public and interagency comments, and discussing them with the IDT, 

the responsible official has determined that alternative B, with some modifications, is 

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the preferred alternative.

12

The conclusion that alternative C would have less beneficial 

impact than other alternatives is biased, ignoring the potential 

for non-herbicide controls to reduce or eliminate invasive plants; 

it would just take a little longer with alternative C.

Alternative C would cost more and take longer to achieve control objectives, and in 

some cases, objectives would not be able to be met due to restrictions on all 

herbicide use near streams. The treatment effectiveness section 3.1.4 of the DEIS 

acknowledged the potential effectiveness of alternative C. Alternative C would be 

more effective than the no action alternative but less effective than alternatives B or 

D because it would not allow integrated treatment methods that include herbicides 

within 100 feet of streams. This would increase the expense as well as the time taken 

to reach treatment objectives.

12

Even if the differences in impact between alternative C and 

alternative B are not measurable, it could be a very real impact, 

as with radiation poisoning, where there is no safe level of 

radiation exposure.

The toxicity and risk associated with the herbicides used in the action alternatives are 

not comparable to radiation exposure. Risk assessments are best available science 

and herbicides proposed for use pose relatively low risk. The scale of the project and 

the pdfs together make the potential for adverse effects very low to people and the 

environment. 

Common Control Measures/Integrated Invasive Plant Treatment Prescriptions

12

Prioritize non-herbicide treatment for the thistles...they are 

easily controlled. Concern about biological controls affecting 

native thistles is not warranted because they are usually not in 

the same place as invasive thistles.

Non-herbicide methods would continue to be used in all action alternatives where 

they would cost-effectively meet treatment objectives. Bull and musk thistles can be 

effectively hand pulled and this would continue to be done for small infestations. 

Approved biological controls would be released in all action alternatives. Additional 

treatments may be necessary in addition to biological controls to eradicate, control or 

contain infestations that are threatening native plant habitats. The discussion about 

biological controls affecting native thistles has been edited in the FEIS to 

acknowledge that an agent found to affect native thistles (Rhinocyllus conicus) has 

been released in Eastern Oregon, but is not currently approved and would not be 

redistributed on the Malheur National Forest because it would not meet LRMP 

Invasive Plant Treatment Standard 14. The FEIS contains updated information about 

which biological controls would be redistributed under the action alternatives. 

12 Yellow star thistle – Use biological controls for large infestations

Current infestations of yellow star thistle may not be effectively treated by biological 

controls because they are small and scattered. If treated effectively, infestations of 

this invasive species would not become large. 

12 Sulphur cinquefoil – Why is metsulfuron methyl preferred? Use 

glyphosate as first choice herbicide.

County weed managers have found that metsulfuron methyl is the most effective 

herbicide to treat sulphur cinquefoil. Picloram has also been found to be effective, but 

would not be the first choice in any alternative (and would not be used at all in 

alternative C). Scarce information exists about the effectiveness or timing of 

glyphosate treatments for sulfur cinquefoil. The plant’s tendency to grow and develop 

late in the season suggests that late summer or fall treatments with glyphosate with a 

good surfactant may be effective. 

12 Drop picloram, metsulfuron methyl, Roundup®

, clopyralid, try 

hand pulling first in the establishment year.

The R6 2005 FEIS and the Malheur Site-Specific Invasive Plant Treatment DEIS 

addressed the risks and benefits of using herbicides as part of the integrated weed 

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treatments. The design features in the FEIS for all action alternatives include a 

project design feature (F1) that prohibits the use of POEA surfactant, which is an 

ingredient in Roundup®

. Thus, this product would not be used. 

12

For knapweeds, drop use of picloram, clopyralid, triclopyr, 

round up. Use biological agents for large infestations and 

repeated manual pulling/digging on small infestations.

Aminopyralid is the first-choice herbicide for knapweeds under alternatives B and C 

and picloram (or aquatic-labeled glyphosate near streams) would be the first choice 

in alternative D if aminopyralid is not available. Handpulling would be part the 

integrated treatment prescription, especially for smaller infestations or in combination 

with herbicides as larger infestations become smaller. The FEIS includes a project 

design feature (F1) that prohibits the use of POEA surfactant, which is an ingredient 

in Roundup®

. Thus, this product would not be used. 

12 For thistles, drop use of clopyralid, chlorsulfuron, picloram. Aminopyralid is the first-choice herbicide for thistles under alternatives B and C and 

chlorsulfuron would be the first choice in alternative D if aminopyralid is not available.

12 For Canada thistle – combine methods, use solarization for 

small infestations, biocontrols for large infestations. 

All action alternatives include a combination of treatment methods solarization and 

biocontrols will be used as part of the integrated treatment prescription where costeffective to meet treatment objectives. 

12 For Bull thistle – no clopyralid, chlorsulfuron, picloram, triclopyr 

or round up formulation of glyphosate

Aminopyralid is the first-choice herbicide for thistles under alternatives B and C and 

chlorsulfuron would be the first choice in alternative D if aminopyralid is not available. 

The FEIS includes a project design feature (F1) that prohibits the use of POEA 

surfactant, which is an ingredient in Roundup®

. Thus, this product would not be used. 

Glyphosate may be used if other herbicides are found ineffective or if they are not 

allowed due to pdfs or herbicide-use buffers. However, it is not one of the most 

effective herbicides for thistles. 

12 For leafy spurge – no picloram or round up formulation of 

glyphosate

Aminopyralid is the first-choice herbicide for leafy spurge under alternatives B and C 

and picloram (or aquatic labeled glyphosate near streams) would be the first choice 

in alternative D if aminopyralid is not available. Picloram would not be used in 

alternative C. 

12 For houndstongue – emphasize pulling, cutting, mowing. Drop 

chlorsulfuron, and metsulfuron methyl.

Chlorsulfuron is the most effective herbicide for this target species. Non-herbicide 

methods would be used in combination with herbicides in all action alternatives. The 

R6 2005 FEIS and Malheur DEIS analyzed the impacts of using these herbicides. 

12 For toadflaxes – Use biological agents for large infestations, 

drop use of chlorsulfuron, metsulfuron methyl and picloram

Sulfonylurea herbicides are the most effective for this target species. Biological 

controls have been effective in containing large infestations and are an important part 

of the integrated treatment prescription. 

12

We need more detailed information comparing the toxicity, 

mobility and persistence of chlorsulfuron and imazapic and their 

effectiveness for controlling target invasive species.

The R6 2005 FEIS discussed these herbicides in detail and the Malheur DEIS 

discussed the site-specific impacts of using these herbicides. Chlorsulfuron is among 

the lowest risk herbicides to people and wildlife, and poses comparatively moderate 

risk to aquatic organisms and non-target plants. Imazapic is among the lowest risk 

herbicides to workers, aquatic organisms and wildlife, and poses comparatively 

moderate risk to public health and non-target plants. Neither of these herbicides are 

associated with human health hazard quotients greater than HQ = 1 for any of the 

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conservative exposure scenarios analyzed. Persistence and mobility are discussed in 

Chapter 3.4.

12

For whitetop and perennial pepperweed – Drop use of 

chlorsulfuron, metsulfuron methyl and round-up formulation of 

glyphosate

Sulfonylurea herbicides are the most effective for these target species. The more 

herbicides available for use, the more likely treatments will effectively eradicate, 

control and contain infestations. The FEIS includes a project design feature (F1) that 

prohibits the use of POEA surfactant, which is an ingredient in Roundup®

. Thus, this 

product would not be used. 

04

We are concerned that the analysis in this EIS is a bit too 

generic. The proposed action describes a variety of treatment 

methods and a DEIS lists a number of locations where 

treatments may occur, but which treatments and which location 

is unclear. This is supposed to be a site specific DEIS, so there 

should be more detailed discussion of the ecological 

sensitivities at the individual proposed treatment sites. Are they 

near water, or near sensitive botanical sites or wildlife habitat or 

recreation areas? How will impacts be limited and mitigated at 

these sensitive sites? Maybe the FEIS can highlight certain 

areas of concern where treatments may impact sensitive 

resource values.

A large spreadsheet (in the project record) describes the proposed actions at each 

invasive plant treatment location and is available on request. Appendix A 

summarized the location of invasive plants within each 5th field watershed and 

provides target species, locations, and lists special land uses, major streams and 

water bodies, recreation areas, grazing allotments, and threatened/endangered 

species there. 

In the DEIS, sensitive sites were addressed site-specifically. Table 29 noted the 

invasive plant species locations within 100 feet of sensitive plants, table 35 noted 

infestations and their proximity to drinking water sources, and table 38 described the 

sites with the greatest potential to impact streams and supplied site-specific model 

results indicating the low likelihood of herbicide reaching streams for this project. 

Figure 11 showed these locations on a map. The analysis related to aquatic 

organisms disclosed the eight 6th-field watersheds where more than one-half of 1 

percent of the area within 100 feet of streams or other water bodies is proposed for 

treatment. The wildlife analysis similarly addressed whether or not invasive plants are 

within specific wildlife habitats and whether or not the type of treatment could have an 

impact on each species, (e.g., page 225 stated approximately 79,000 acres of 

potentially suitable upland sandpiper habitat occurs on the Malheur National Forest 

and of this, 72 acres are currently known to contain invasive plants. Broadcast 

application would occur on 50 percent and 25 percent of the sites under alternatives 

B and D respectively whereas manual/mechanical treatments would occur on 68 

percent of the sites under alternative C). The interdisciplinary team noted how the 

project design features, herbicide-use buffers and treatment caps would minimize 

impacts to recreation areas and sensitive resource locations. 

Off Road Travel for Project

12 Just require all vehicles to stay on roads, trails and parking 

areas. No cross country travel.

ATVs may be necessary to provide access to some invasive plant sites. Forest 

Service policy direction and LRMP management direction would be followed if this is 

done. Vehicles and equipment (including personal protective clothing) would be 

cleaned so they do not transport invasive plants (pdf C1).

Restoration

02 My only concern is once one native species is removed it The DEIS described the process that would be used to ensure that desirable 

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usually gives rise to a new exotic species that was once being 

controlled by the previous species, “complete removal of 

invasives sometimes triggers unanticipated effects, such as 

spread of previously undetected exotic plants following removal 

of invasives,” (Cristescu et al. 2013). I feel as though the 

treatment plan doesn’t really address this problem except by 

stating several times that in fact this would happen and the plan 

would need to be revised or the need for a new plan would 

need to come into place. It would be helpful the plan had more 

detail about this issue.

vegetation would occupy treatment sites over time. As much detail as possible was 

provided based on information known at this time. Page 45 stated, “Recovery of 

native vegetation after invasive plant treatment cannot be precisely predicted. 

Restoration would be considered following repeated herbicide and other treatment 

methods, especially in areas where recovery to native vegetation may not be 

possible such as campgrounds and other highly disturbed areas. . . Evaluation for 

site restoration will occur before, during and after herbicide, manual and mechanical 

treatments. Passive site restoration would be favored in areas having a stable, 

diverse, native plant community and sufficient organics in the soil to sustain natural 

revegetation.” 

If the soils lack sufficient organics, mulch and/or soil microbe inoculum from nearby 

areas could be added. Deep-rooted shrubs may also be seeded or planted to more 

fully utilize resources from the lower soil profile, especially late in the growing season. 

Shrubs allow for easier establishment of understory species by increasing water 

availability and reducing understory temperatures and soil evaporation loss.

Restoration was also addressed in the Implementation Planning Process (DEIS 

pages 48 and 49) and the Treatment Cost Effectiveness section (DEIS page 72, for 

instance, added $500 per acre to the treatment cost estimate for seeding, mulching

or planting on 1,231 acres that are of a size and distribution that could require 

broadcast spraying and therefore have the greatest potential need for restoration). 

12

We are generally supportive of passive and active restoration 

with native plants. Sterile non-native species should only be 

used in disturbed sites when necessary.

R6 2005 Record of Decision (Malheur National Forest LRMP) Standard 13 for use of 

native species for restoration will be followed. This means that native plant materials 

are the first choice in revegetation for restoration and rehabilitation where timely 

natural regeneration of the native plant community is not likely to occur. Non-native, 

non-invasive plant species may be used in any of the following situations: 1) when 

needed in emergency conditions to protect basic resource values (e.g., soil stability, 

water quality and to help prevent the establishment of invasive species); 2) as an 

interim, non-persistent measure designed to aid in the re-establishment of native 

plants; 3) if native plant materials are not available; or 4) in permanently altered plant 

communities. Under no circumstances will non-native invasive plant species be used 

for revegetation.

EDRR

12

So if the intent of EDRR is to control invasive plants when 

infestations are small, non-herbicide methods should be used 

first. 

The decision to use herbicide (DEIS, figure 4) described how the Forest Service will 

determine the need for herbicide use. The intent is to have a range of cost-effective 

tools for timely treatment. 

12

Why would non-first choice herbicides be used on newly 

detected infestations? We ask that first choice herbicides be 

used on newly detected infestations for first time herbicide use 

and only if non-chemical control methods would not be 

effective.

This section (Chapter 2.3.2) has been edited in the FEIS to clarify herbicides other 

than those identified as “first-year, first-choice” could be used if the first year’s choice 

is found to be ineffective on existing or new target species found during the life of the 

project. New target species that are Class A or B listed by the State of Oregon could 

be treated during the life of the project, according to treatment methods (including 

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herbicides), project design features, and herbicide-use buffers analyzed in the EIS. 

Monitoring

12 We support all monitoring requirements, prior, during and after 

implementation Thank you for your comment. 

12

Higher risk projects with potential to impact species of 

conservation concern should necessarily be changed to no

longer cause impacts to these species

The term “high risk” project comes from the R6 2005 Record of Decision monitoring 

framework. It is defined as broadcast spraying near streams and aerial spraying. No 

high risk projects have been implemented across the region since 2005 (see Desser 

Monitoring Update 2014). In general, pdfs and herbicide-use buffers avoid higher 

risks. 

12 Monitoring of most or all herbicide use sites should be required.

The DEIS stated on page 49: “Monitoring would occur during implementation to 

ensure Project Design Features are executed as planned. Post-treatment reviews 

would occur to determine whether treatments are effective and whether or not 

passive/active restoration is occurring as expected... post-treatment monitoring 

would also be used to detect whether pdfs were appropriately applied, and whether 

non-target vegetation impacts were within tolerable levels.” 

12 BMPs have usually not been adequately monitored or proven to 

be effective, so use of BMPs is not protective enough

The Forest Service has emphasized development and monitoring of Best 

Management Practices (BMPs) listed in the National Best Management Practices for 

Water Quality Management on National Forest System Lands.

Volume 1: National Core BMP Technical Guide (FS-990a) was published April 2012. 

The draft National Core BMP Monitoring Technical Guide is currently in review and 

publication is expected in Fiscal Year 2014. The Forest Service is currently testing 

BMP monitoring protocols, including BMPs for chemical use. 

12

By the time unexpected, adverse effects are discovered, the 

damage is already done. Adverse effects need to be avoided 

for already severely damaged streams and water quality.

Page 49 of the DEIS stated that monitoring would occur during implementation to 

ensure pdfs are executed as planned. Post-treatment monitoring would also be used 

to detect whether pdfs were appropriately applied. Impacts such as some non-target 

plant damage could occur. However, severe damage to streams and water quality is 

not likely due to the layers of caution associated with the project. 

Treatment Cost Effectiveness

02

With regards to the alternatives requiring action against the 

invasive species Alternative D was the most cost effective in 

regards to the total cost of Most Ambitious Treatment Scenario 

at $1,270,500 where alternative B was $1,154,000.But 

alternative B, the proposed alternative, was the most cost 

effective in cost per acre at $544 per acre than alternative D at 

$598 per acre. The problem with alternative D is that it excludes 

the use of aminopyralid but still promotes the notion to 

broadcast or boom spray the area with more toxic herbicides.

Alternative B is slightly less costly ($1,154,000 is about $120,000 less than 

$1,270,00) and is why the cost per acre is less. Broadcast spraying would tend to 

have the best results in both alternatives due to the ability to consistently treat a 

larger area without skips and gaps associated with spot spraying. Broadcast 

treatments also tend to go faster. However, no differential in dollars per acre was 

reflected in the model. The DEIS addressed the differences in alternatives. The use 

of aminopyralid would increase effectiveness and decrease risk compared to some of 

the other herbicides. Since alternative D does not use aminopyralid, other herbicides 

such as glyphosate and picloram would become the first choice. 

02 Alternative B the proposed project is the best option, although it Alternative B is the Forest Service’s preferred alternative. The use of aminopyralid as 

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allows broadcasting of herbicides the studies that were done on 

non-target species and human toxicity showed very low levels 

of impact. 

the first-choice herbicide in most situations would result in low risk to human health. 

However, table 18 (pages 67-68 of the DEIS) noted that aminopyralid poses 

moderate risk to non-target plant species. 

12 Assumptions [that all infestations would be treated in a single 

year and all pdfs would be applied] are probably unrealistic. 

Project design feature compliance is mandatory and must be assumed. We 

recognize that all infestations are unlikely to be treated in a single year. This 

assumption allows for consistent alternative comparison and a way to estimate the 

cost of an effectively treated acre. DEIS pages 74-75 explained that only a portion of 

the total acreage would likely be treated each year given funding and workforce 

limitations. 

12

The treatment effectiveness issue component regarding 

unnecessary restrictions on herbicide use does not consider 

costs of loss of ecological values, loss of biodiversity, loss of 

ecological integrity.

The analysis of botany, wildlife, soils, water, and fish discuss how ecological values 

are affected by the alternatives. The cost-effectiveness issue focuses on the tools 

that would be available to treat invasive plants and the likelihood that these tools 

would be effective. Restrictions on tools available, including flexibility in using the 

most effective herbicide, necessarily increase cost and reduce effectiveness. 

12

There is no explanation (quantification, assumptions used) why 

alternative C is assumed to have only half the control 

effectiveness of alternative B.

DEIS page 79 explained that the effectiveness of each treatment is influenced by the 

tools available for use. The more tools available, the greater the potential 

effectiveness of the treatment. Page 80 explained that alternative C does not 

approve any broadcast spraying and excludes herbicide use over much of the 

infested area. Page 80 also noted that broadcast methods accomplish many more 

acres a day than spot or hand methods. Spot and hand treatments tend to require 

more labor as applicators must walk from spot to spot and then return to 

accommodate skips and gaps that are common with this type of treatment. This 

would increase the number of entries needed and increase the amount of time 

needed to reach invasive plant control objectives. These are the reasons for the 

assumption that alternative C would cost more and be less effective in treating 

invasive plants. No specific information exists on how the restrictions in alternative C 

would influence the cost or effectiveness of treatment at a given site or in total. The 

estimates in the DEIS were based on professional judgment of weed management 

specialists. The FEIS has been edited to clarify the assumptions related to treatment 

effectiveness. 

12

Define unnecessary restrictions on dumping poisons on plants, 

soils, water, air, wildlife, etc. [re: treatment effectiveness, page 

12]

This sentence referred to herbicide-use buffers that are wider than necessary, rate 

and application method restrictions that are more stringent than necessary, and 

limitations on herbicide ingredients that go beyond those necessary to minimize 

adverse effects on people and the environment and meet the R6 2005 Record of 

Decision (Malheur National Forest LRMP) standards. This issue has been edited in 

the FEIS for clarity. 

Herbicides, Herbicide Impacts, Herbicide Toxicity

08

I am primarily concerned about the use of toxic herbicides as a 

method of invasive plant control, as this will likely cause 

damage to a number of species in the Malheur, as well as 

Herbicide toxicity was addressed in the DEIS and will be considered in the final 

decision for this project. The project is designed to minimize adverse effects on nontarget plant species, people, fish, wildlife, soil and water. Impacts to soil, water, 

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impact the water and soil that so many plants and animals are 

dependent on.

wildlife and aquatic species were addressed in the DEIS. 

12

Prohibit herbicide use in the spring which is a time of greater 

risk of transport of toxic chemicals to streams and a time of 

greater risk to [wildlife] reproductive success.

The pdfs include seasonal restrictions where needed to protect wildlife. The timing of 

invasive plant treatment would be based on when it is most effective, in accordance 

with the pdfs. 

08

I would also like there to be no broadcast spraying of herbicides 

anywhere in this project or future projects, as this allows the 

herbicides to spread too easily.

Alternative C does not allow broadcast treatment methods. The rationale for selected 

alternative will be in the Record of Decision. 

12 Even though triclopyr does not bioaccumulate “to a great 

extent” it does bioaccumulate.

Triclopyr would not accumulate in the tissues of animals or magnify up the food 

chain. It has a bioconcentration factor that is less than 1 (DEIS page 91), meaning 

that it would be excreted faster than it could be absorbed. Thus, it would not be 

concentrated from contaminated water into the tissues of fish. 

12

It is really disturbing that repeated chemical applications may 

persist up to 15 years! on the same ground, including repeated 

spraying with the same year. This makes it imperative to 

analyze synergistic, cumulative, and chronic effects of repeated 

herbicide use over a long time period, on site-specific locations. 

Why is this not analyzed in this DEIS? This is inadequate 

analysis.

Chronic and cumulative impacts are discussed in the risk assessments and in the 

DEIS. The pdfs address herbicide impacts and add layers of caution to make sure 

impacts are limited in extent and duration. There is no evidence that herbicide use 

would continue on the same acreage each year or persist for 15 years. The analysis 

in the EIS assumes that the project may be implemented over a 5 to 15 year period; 

this provides analytical consistency given that levels of funding and treatment 

effectiveness are highly variable. The project would continue until no more treatments 

were needed or until conditions otherwise changed sufficiently to warrant the EIS 

outdated. Herbicide use would be expected to decline each year of treatment as 

target population is reduced following treatment (see Chapter 3.1.4). The DEIS 

disclosed that “combinations of chemicals in low doses (less than one tenth of RfD) 

have rarely demonstrated synergistic effects.”

12

Why are studies that underpin concerns about GMO and round 

up ready crops not applicable to the proposed project? Who 

updated the glyphosate risk assessment and based on what 

new information?

This discussion (DEIS table 7) has been updated in the FEIS. This statement referred 

to studies that are not applicable to the proposed project because they are based on 

1) formulations that are not available in the United States and rates are often much 

higher than proposed for this project; and 2) the use of glyphosate in this project 

would be limited to direct application to scattered invasive plants that are not used as 

crops. The risk assessments focus on the type of herbicide use proposed by the 

Forest Service, rather than use on edible crops. An independent third party risk 

assessor updated the glyphosate risk assessment based on information available in 

the open literature.

08

Herbicide use can cause losses to native biodiversity as well as 

affect the safety and enjoyment of humans who hike, camp, 

hunt, and otherwise recreate in the Malheur National Forest.

The DEIS addressed impacts of herbicide use proposed on the Malheur National 

Forest. The intent is to protect healthy native plant communities. The type and extent 

of herbicide use proposed is unlikely to adversely affect human health and safety. 

Effects on recreation were disclosed in the DEIS. 

08 I believe herbicides should only be used as a last resort in 

controlling invasive species and that a thorough analysis of the 

The DEIS addressed short- and long-term impacts of the alternatives. Treatment 

control methods would be developed on a site-specific basis. Current management 

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short-term and long-term effects of any herbicide proposed 

must be made with respect to the health and biodiversity of the 

entire forest. If herbicides are used, I would like there to be 

specific protection plans put in place for species most 

vulnerable to the herbicides. Invasive plant control measures 

should be site-specific and strategic so as to cause the least 

harm.

direction does not require the use of herbicides as a last resort. As noted, in the R6 

2005 Record of Decision, the Regional Forester considered but rejected this 

alternative, partially because using herbicides as a tool of last resort would have 

deviated from integrated weed management principles (R6 2005 Record of Decision 

page 6, page 27). However, herbicides would only be used where necessary. The 

DEIS noted (page 49), “If the target invasive species population is not associated 

with a size, phenology, density or distribution that warrants herbicide use (alone or in 

combination with other methods), or if herbicide use does not substantially increase 

treatment efficiency (considering the availability of volunteers if needed), then nonherbicide methods would be favored.”

09

I am writing to voice my opinion that no herbicides be used to 

reduce invasive species. I am deeply concerned about the 

routine use of herbicides where it is often the synergistic effect 

and long term reliance on this mechanism which is poses the 

greatest unforeseeable risk to both humans and the 

ecosystems where they are used. For the Malheur project, I am 

urging that herbicides are phased out over time completely, with 

full public transparency, that they are used as a last resort after 

thorough testing, and that they are not used in sensitive areas 

such as riparian habitat. 

This comment is unclear about what synergistic effects are of concern. Synergistic 

effects were discussed in the SERA risk assessments and the R5 2005 FEIS. Pages 

98-99 of the Malheur National Forest Invasive Plants Treatment DEIS discussed 

synergistic effects, “The R6 2005 FEIS considered the potential for synergistic effects 

of exposure to two or more chemicals: “Combinations of chemicals in low doses (less 

than one tenth of RfD) have rarely demonstrated [emphasis added] synergistic 

effects. Review of the scientific literature on toxicological effects and toxicological 

interactions of agricultural chemicals indicate that exposure to a mixture of pesticides 

is more likely to lead to additive rather than synergistic effects” (ATSDR, 2004; 

U.S.EPA/ORD, 2000). Based on the limited data available on chemical combinations 

involving the twelve herbicides considered in this EIS, it is possible, but unlikely, that 

synergistic effects could occur as a result of exposure to the herbicides considered in 

this analysis. Synergistic or additive effects, if any, are expected to be insignificant” 

(R6 2005 FEIS p. 4-3). Additional information about herbicide use on other land 

ownerships in Oregon and potential for cumulative effects is in Chapter 3.1.5. The 

project is not anticipated to have long-term herbicide impacts. The project design 

features, treatment caps, and the focus on effective integrated treatments and 

restoration of desirable plant species are intended to minimize need for repeated 

spraying over a long period of time (see DEIS chapter 3.1.4). Less herbicide would 

be required at treated sites as target species populations become small enough to 

treat manually (ibid). It is unclear what full public transparency means. Herbicide risk 

assessments use best available scientific information and real world studies, 

considered to be adequately thorough to support findings in the DEIS. Alternative C 

does not use herbicides in riparian areas, providing a basis for comparison between 

alternatives. 

07

I know that when I am hiking and find a tasty mushroom I want 

the only poisoning I have to worry about to be from misidentification on my part, not toxic herbicides sprayed onto it. 

Herbicides should not be sprayed in these areas.

The risk assessments specifically used best available science to study the acute and 

chronic risks to people eating contaminated fruits and vegetation. Given the amount 

of herbicide that would possibly be absorbed and the toxicity of the individual 

herbicides, no exposures over a threshold of concern were found (DEIS page 93). 

Also, treatment sites would be posted and marked with dye, so that herbicide use 

would be known before a person would forage in such an area. Most of the invasive 

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plants known on the Malheur National Forest are directly adjacent to roads. Plants 

growing in these areas are subject to additional pollutants such as exhaust from 

vehicles and dust. Morels are the main mushroom species collected on the Malheur 

National Forest. These fruit in the spring whereas most herbicide treatments would 

occur in mid to late summer. 

12 Drop use of roundup, the surfactant still concerns us, toxic to 

fish, etc.

The FEIS includes a project design feature (F1) that prohibits the use of POEA 

surfactant, which is an ingredient in Roundup®

. The Roundup® formulation of 

glyphosate would not be used for this project. 

12

We are opposed to the use of picloram and clopyralid due to 

the threat of HCB to raptor reproduction, as well as other 

reasons re: picloram.

Picloram and clopyralid were approved in the R6 2005 Record of Decision. 

Alternative C would prohibit the use of picloram. Alternatives B and D include pdfs 

and herbicide-use buffers to minimize the potential adverse impact of picloram. 

Clopyralid is not a first-choice herbicide in any alternative. However, it is among the 

lowest risk herbicides for worker health and the environment (DEIS table 18). There 

are no exposure scenarios over a threshold of concern for public health with the use 

of clopyralid and it contains much less hexachlorobenzene (HCB) than picloram 

(DEIS page 94). 

12 Drop use of metsulfuron methyl.

The DEIS analysis does not indicate that metsulfuron methyl should be omitted from 

the list of herbicides. It is the first-choice herbicide for about 8 percent of the currently 

infested acreage (about 186 acres). It is among the lowest risk herbicides relative to 

human health, aquatic resources and wildlife (DEIS table 18). Restrictions on the use 

of herbicides approved in the R6 2005 Record of Decision would increase cost and 

decrease treatment effectiveness. 

12 Drop use of triclopyr. High toxicity to applicators, aquatic 

ecosystems, etc. Not necessary to use.

Triclopyr is not among the first-choice herbicides in any alternative but would be 

effective on several target species in the project area. Project design features and 

herbicide-use buffers are in place to ensure that it is used in an appropriate manner 

that would meet R6 2005 Record of Decision (Malheur National Forest LRMP) 

standards. Restrictions on the use of herbicides approved in the R6 2005 Record of 

Decision would increase cost and decrease treatment effectiveness, especially over 

time if first-choice herbicides are found to be ineffective.

06 / 10

We are asking that the most toxic herbicides not be used at all: 

triclopyr (which poses the greatest risk to humans) and picloram 

(which contains carcinogenic hexaclorabenzene, and spreads 

readily through soils and water). We are also concerned by the 

first choice proposed use of Chlorsulfuron and Metsulfuron 

methyl, (both proposed for broadcast spraying) and proposed 

use of Sulfometuron methyl. These herbicides are acutely toxic 

and should not be used in broadcast spray applications. We are 

opposed to the use of the “Roundup” formula of glyphosate as it 

has a very toxic surfactant and of Clopyralid, as it has a 

carcinogenic impurity—Hexachlorobenzene.

All of the herbicides mentioned in this comment were approved for use by the R6 

2005 Record of Decision. For the Malheur project, the DEIS disclosed the risks of 

using these herbicides on sites within the Malheur National Forest. Several project 

design features were developed to respond to risks associated with these herbicides. 

Triclopyr is not a first-year, first-choice herbicide in any alternative. However, it is an 

effective herbicide on many target species. It would not be broadcast sprayed as per 

the R6 2005 Record of Decision (Malheur National Forest LRMP). 

Alternative C does not allow the use of picloram. Picloram is one of the first-choice 

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herbicides in alternative D. Page 92 of the DEIS noted that “One operational 

exposure scenario resulted in HCB exposure above the cancer risk threshold: boom 

broadcast application of picloram at the maximum application rate, treating 112 acres 

in one day, and not wearing any protective clothing. Required personal protective 

equipment and pdfs (Group F) would make it unlikely for any workers to actually 

receive the maximum exposure and thus, use of this herbicide would not result in 

measurable cancer risks to workers.” The amount of HCB in clopyralid is below a 

threshold of concern, even given the extreme scenario described. 

It is unclear what “acutely toxic means” in regards to chlorsulfuron, metsulfuron 

methyl and sulfometuron methyl. They are among the lowest risk herbicides to 

people, the aquatic environment and wildlife. 

The action alternatives have been modified so that POEA surfactant, which is an 

ingredient in Roundup®, will not be used. 

06 / 10 There’s no sufficient reason to use high or moderate risk 

herbicides when there are safer alternatives available.

DEIS Table 18 listed the comparative risks of herbicides proposed for use in the 

alternatives (not considering pdfs or site-specific situations on the Malheur National 

Forest). This table has been edited in the FEIS based on updated risk assessment 

results. The intent of the proposed action is to use the most effective-least risk 

herbicide for each target species. None of the comparatively “higher risk” herbicides 

(considering public health, worker health, non-target plants, aquatic organisms and 

wildlife) are first-year, first-choices for alternatives B or C. The 10 herbicides 

analyzed in the R6 2005 FEIS, used in accordance with the R6 2005 standards, pose 

relatively low risks to people and non-target organisms (R6 2005 Record of Decision 

p. 8). Aminopyralid compares favorably with the other herbicides considered for use 

on this project. 

06 / 10

We remain concerned by the lack of adequate testing for the 

effects of herbicide impurities, metabolites, “inert” ingredients, 

and adjuvants, as well as for the synergistic and chronic effects 

of multiple ingredients in a single herbicide formula.

The analysis in the DEIS utilized best available scientific information based on 

herbicide risk assessments written by an independent third party contractor. These 

risk assessments consider the differences in risk from various formulations of 

herbicide when possible (including additives). The Forest Service has also prepared 

risk assessments on surfactants. The comment is unclear as to what would constitute 

adequate testing. This concern cannot be resolved in a project-level EIS. Additional 

information on herbicide adjuvants is in the FEIS. 

08

Ideally, high and moderate risk herbicides would not be used at 

all in this project. There are a number of other effective 

methods of controlling invasive species without the toxicity risk. 

I especially advocate for the herbicides Triclopyr and Picloram 

not to be used in this project. Triclopyr poses great risk to 

humans and carcinogenic Picloram easily spreads and poisons 

soil and water. Furthermore, the proposed use of Chlorsulfuron 

All of the herbicides mentioned in this comment were approved for use by the R6 

2005 Record of Decision. For the Malheur project, the DEIS disclosed the risks of 

using these herbicides on sites within the Malheur National Forest. Several project 

design features were developed to respond to risks associated with these herbicides. 

Triclopyr is not a first-year, first-choice herbicide in any alternative. However, it is an 

effective herbicide on many target species. It would not be broadcast sprayed as per 

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and Metsulfuron methyl, as well as Sulfometuron methyl, seems 

dangerous given the acute toxicity of these substances. They 

should not be used in broadcast spraying. Clopyralid, which 

contains a carcinogenic impurity, and “Roundup” formula 

glyphosate, which has a highly toxic surfactant, should also not 

be used in our National Forests. Herbicides should also not be 

used in any riparian areas, particularly the Long Creek 

Municipal Watershed, nor in or near sensitive or rare plant 

species populations or botanical species of conservation 

concern. Neotropical songbirds, elk, deer, pronghorn, fish, 

amphibians, raptors, scavengers, and small mammals are all 

threatened by the use of these herbicides. In order to protect 

the integrity of our forests, I would like to see the use above 

listed herbicides dropped altogether.

the R6 2005 Record of Decision (Malheur National Forest LRMP). 

Alternative C does not allow the use of picloram. Picloram is one of the first-choice 

herbicides in alternative D. Page 92 of the DEIS noted that “One operational

exposure scenario resulted in HCB exposure above the cancer risk threshold: boom 

broadcast application of picloram at the maximum application rate, treating 112 acres 

in one day, and not wearing any protective clothing. Required personal protective 

equipment and pdfs (Group F) would make it unlikely for any workers to actually 

receive the maximum exposure and thus, use of this herbicide would not result in 

measurable cancer risks to workers.” The amount of HCB in clopyralid is below a 

threshold of concern, even given the extreme scenario described. 

It is unclear what “acutely toxic means” in regards to chlorsulfuron, metsulfuron 

methyl and sulfometuron methyl. They are among the lowest risk herbicides to 

people, the aquatic environment and wildlife. 

The action alternatives have been modified so that POEA surfactant, which is an 

ingredient in Roundup®

, is not approved for use (see pdf F1).

The analysis in the DEIS displayed the effects of using these herbicides as proposed, 

and alternative C included restrictions on the use of picloram, along with not broad 

spraying any herbicide. 

Chlorsulfuron and metsulfuron methyl are the first-choice herbicides for several target 

species on the Malheur National Forest. 

Clopyralid, sulfometuron methyl and triclopyr are not the first-choice herbicide for any 

of the target species currently found on the Malheur National Forest. However, they 

are listed as an effective herbicide for several target species and may be used if the 

first choice proved ineffective. 

Glyphosate is one of the first-choice herbicides in alternative D. However, only 3 

acres in this alternative are likely to require broadcast application. It is an effective 

herbicide for many target species. The FEIS includes a project design feature (F1) 

that prohibits the use of POEA surfactant, which is an ingredient in Roundup®

. Thus, 

this product would not be used. Currently, Long Creek Municipal Watershed has 0.1 

acre of invasive plants and herbicides are unlikely to be needed to be used for the 

infestation there (DEIS page 9). 

The project design features and herbicide-use buffers are intended to respond to 

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specific risks indicated by risk assessments applied to the types of treatments 

proposed and habitats found on the Malheur National Forest. 

07

I feel this plan is faulty is because it so heavily relies on 

herbicides known to be highly toxic, such as Picloram and the 

“Roundup” formula of glyphosate, which we know have 

carcinogenic components, and Triclopyr which creates a health 

risk for recreationists who come into contact with it. The first 

choice proposed use of Chlorsulfuron, Metsulfuron methyl, and 

Sulfometuron methyl are also highly concerning for similar 

reasons, especially considering that two of these would be 

broadcast sprayed.

The DEIS acknowledged that a known carcinogen HCB is an industrial by product 

inherent in the manufacture of picloram and clopyralid (DEIS page 92). This is one 

reason alternative B proposes to add aminopyralid to the list of herbicides to be used, 

since it does not contain this contaminant. However, the amount of HCB exposure 

would be below a threshold of concern given the amount of picloram or clopyralid 

proposed in any alternative. Project design features restrict the broadcast application 

rate of picloram that reduces the potential for HCB exposure over a threshold of 

concern. Glyphosate is not considered a carcinogen (SERA 2011 Glyphosate Risk 

Assessment, page 61). Risk of cancer from contaminants in the surfactant in 

“Roundup®

” were also quantitatively evaluated in the 2011 glyphosate risk 

assessment. Results conclude that the upper bound risk is equivalent to a cancer risk 

of 1 in about 1.5 million, well below the EPA threshold of concern. (ibid, p. 86). 

Triclopyr is associated with some exposures over a threshold of concern for public 

health given worst case scenarios that are unlikely to be encountered with this 

project. The risk assessments for picloram, triclopyr and glyphosate were updated in 

2011 and the FEIS has been edited to incorporate findings in these newer 

assessments. The three sulfonylurea herbicides mentioned (chlorsulfuron, 

metsulfuron methyl, and sulfometuron methyl ) do not pose any human health risks, 

even given worst-case scenarios that are not plausible for this project. 

12

Imazapyr, triclopyr and sulfometuron methyl should not be 

used.

These herbicides were approved in the R6 2005 Record of Decision. However, none 

would be first-year, first-choice. The pdfs and herbicide-use buffers minimize the 

potential adverse impacts of using these herbicides, in accordance with R6 2005 

Record of Decision (Malheur Forest LRMP) standards. 

12

Drop proposed use of picloram, sulfometuron methyl, clopyralid, 

chlorsulfuron, and sethoxydim. The most toxic herbicides are 

generally a problem for multiple receptors, human health, fish, 

native plants, etc. and should be dropped from use.

None of the herbicide proposed on the Malheur National Forest should be 

characterized as “the most toxic herbicides.” The R6 2005 Record of Decision 

approved use of these herbicides because they were of relatively low toxicity 

compared with many pesticides. Table 18 of the DEIS showed the comparative risks 

of the herbicides. The risks of using these herbicides on the Malheur National Forest 

were described throughout the DEIS. The pdfs and herbicide-use buffers minimize 

the potential adverse impacts of using these herbicides, in accordance with R6 2005 

Record of Decision (Malheur Forest LRMP) standards. 

12 Don’t use picloram, chlorsulfuron, sulfometuron methyl, or NPE 

surfactants (rather than limiting rates).

The risks of using these and other chemicals on the Malheur National Forest were 

described throughout the DEIS. The pdfs and herbicide-use buffers minimize the 

potential adverse impacts of using these chemicals. In the FEIS, the action 

alternatives have been modified to prohibit use of nonylphenol ethoxylate-based 

surfactants (NPE) (pdf F1). Given the design of the alternatives, use of these 

chemicals would pose minimal risk to people and the environment.

12 Dropping the use of picloram, metsulfuron methyl, sulfometuron The no action alternative would not allow use of any herbicides. The use of picloram 

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methyl, triclopyr and imazapyr is far more protective of soils and 

other ecological indicators than reliance on multiple pdfs that 

may not be implementable or fully effective.

would not be allowed under alternative C. Effects on soils from the alternatives were 

disclosed in the DEIS. Dropping use of these herbicides in total would reduce the 

effectiveness of the project. The pdfs are expected to be implementable and effective 

in reducing risk. 

12 Drop use of sulfonylurea herbicides. 

Sulfonylurea herbicides are effective on many target species on the Malheur National 

Forest and were approved in the R6 2005 Record of Decision based on the best 

available scientific information. The project design features would reduce the risks of 

using these herbicides. 

12 Drop all use of triclopyr.

Triclopyr is not among the first-choice herbicides in any alternative but would be 

effective on several target species in the project area. Project design features and 

herbicide-use buffers are in place to ensure that it is used in an appropriate manner 

that would meet R6 2005 Record of Decision (Malheur National Forest LRMP) 

standards. Restrictions on the use of herbicides approved in the R6 2005 Record of 

Decision would increase cost and decrease treatment effectiveness, especially over 

time if first-choice herbicides are found to be ineffective.

12 Drop chlorsulfuron and metsulfuron methyl from broadcast 

spraying along with other sulfonylurea herbicides.

Alternative C does not allow any broadcast application. Rate restrictions and 

herbicide-use buffers minimize adverse effects of broadcast spraying these 

herbicides in alternatives B and D. 

12 Drop use of sulfometuron methyl.

Sulfometuron methyl was approved in the R6 2005 Record of Decision. However, it 

would not be used first-year, first-choice. The pdfs and herbicide-use buffers 

minimize the potential adverse impacts of using this herbicide, in accordance with R6 

2005 Record of Decision (Malheur Forest LRMP) standards.

12 Drop use of chlorsulfuron. For what invasive plant species is it 

the first choice?

Chlorsulfuron is the first-choice herbicide for houndstongue, toadflax, whitetop and 

pepperweed in all action alternatives, and is the first choice for Russian knapweed 

and bull thistle in alternative D (as a substitute for aminopyralid). The analysis in the 

DEIS does not indicate that chlorsulfuron should be omitted from the list of 

herbicides. Unnecessary restrictions on the use of herbicides approved in the R6 

2005 Record of Decision would increase cost and decrease treatment effectiveness.

12 Drop the use of clopyralid which contains pentachlorophenol, a 

dioxin.

Clopyralid does not contain pentachlorophenol. This has been corrected in the FEIS. 

Technical grade clopyralid contains HCB and pentachlorobenzene as contaminants. 

Nominal or average concentrations of HCB are less than 2.5 ppm. Nominal or 

average concentrations of pentachlorobenzene are less than 0.3 ppm (Clopyralid risk 

assessment page xii.) The U.S. EPA has derived RfDs for both pentachlorobenzene 

and HCB and a cancer potency factor for HCB.

Based on the levels of contamination of technical grade clopyralid with these 

compounds and the relative potencies of these compounds to clopyralid, this 

contamination is not significant in terms of potential systemic-toxic effects (ibid, page 

xiv).

12 Drop use of clopyralid (HCB contaminant). Clopyralid is not a first-choice herbicide for any of the target species found on the 

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Malheur National Forest. However, it is effective on many of these species and is 

among the lowest risk herbicides for worker health and the environment (DEIS table 

18). There are no exposure scenarios over a threshold of concern for public health 

with the use of this herbicide and it contains much less HCB than picloram (DEIS 

page 94). The fewer herbicide choices available for different situations, the less likely 

treatments will be effective. The analysis in the DEIS does not indicate that clopyralid 

should be omitted from the list of herbicides. Unnecessary restrictions on the use of 

herbicides approved in the R6 2005 Record of Decision would increase cost and 

decrease treatment effectiveness.

01

When dealing with health issues like this that involve the 

unaware public it’s better to be safe than sorry. As the 

Responsible Official please do not direct your staff to prepare 

denial or ‘it doesn’t apply to this project” statements. Most 

reasonable managers would not take the chance of killing 

someone even if the probability of it occurring were low. Are 

you ready to take this risk?

The Responsible Official will carefully consider the risk of using herbicides (including 

glyphosate, the herbicide of concern mentioned in the comment letter) on the 

Malheur National Forest in making a decision. No evidence suggests that a person or 

animal will be killed as a result of any of the proposed alternatives. Much of the 

material supplied in fact does not apply to this project.

01

The DEIS at page 94 states: “Endocrine disruption and 

glyphosate was discussed in the updated Glyphosate Risk 

Assessment (SERA 2011a). SERA 2011 stated that “some 

recent studies raise concern that glyphosate and some 

glyphosate formulations may be able to impact endocrine 

function through the inhibition of hormone synthesis (Richard et 

al. 2005; Benachour et al.2007a, b), binding to hormone 

receptors (Gasnier et al. 2009), or the alteration of gene 

expression (Hokanson et al. 2007)” (all references as cited in 

SERA 2011). Evaluation of the studies indicates that endocrine 

disruption effects were indicated for surfactants in the 

formulations rather than glyphosate itself.” All glyphosate 

containing herbicides contain these harmful surfactants.

DEIS page 95 noted: “The studies that raise the most concern were from 

formulations not manufactured in the U.S.” Page 95 acknowledged, “there is concern 

that glyphosate formulations may have an impact on these endpoints and that some 

of these effects could be seen under typical application conditions in the United 

States. In the absence of comparable studies on U.S. formulations, however, it is not 

clear whether the studies on glyphosate formulations used outside the United States 

are applicable to risks posed by U.S. formulations of glyphosate” (SERA 2011). Also, 

as stated on page 96 of the DEIS, “While the potential for the proposed herbicides to 

cause endocrine disruption effects is a current data gap, the potential for these 

effects to actually occur are greatly reduced by measures such as required use of 

proper protective equipment, public notification, use of licensed applicators, limiting 

application rates and other relevant pdfs.” In addition Page 96 stated, “The potential 

for these effects to actually occur are evaluated and accounted for by using 

protective thresholds (or toxicity values). Results of all herbicide risk assessments 

indicate that there is no evidence to suggest that these types of effects will occur 

from the proposed herbicide.” 

01

As your DEIS states at page 94, the EPA is testing herbicides 

with the potential for causing endocrine disruption. Glyphosate 

is among the chemicals being tested. The EPA will not 

complete the testing until 2014, thus the “results are not yet 

available.” No professional, caring public servant would even 

consider taking the risk of applying a glyphosate-containing 

herbicide before the results of the EPA testing.

DEIS page 95 noted: “The studies that raise the most concern were from 

formulations not manufactured in the U.S.” Page 95 acknowledged, “there is concern 

that glyphosate formulations may have an impact on these endpoints and that some 

of these effects could be seen under typical application conditions in the United 

States. In the absence of comparable studies on U.S. formulations, however, it is not 

clear whether the studies on glyphosate formulations used outside the United States 

are applicable to risks posed by U.S. formulations of glyphosate” (SERA 2011). Also, 

as stated on page 96 of the DEIS, “While the potential for the proposed herbicides to 

cause endocrine disruption effects is a current data gap, the potential for these 

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effects to actually occur are greatly reduced by measures such as required use of 

proper protective equipment, public notification, use of licensed applicators, limiting 

application rates and other relevant pdfs.” In addition Page 96 stated, “The potential 

for these effects to actually occur are evaluated and accounted for by using 

protective thresholds (or toxicity values). Results of all herbicide risk assessments 

indicate that there is no evidence to suggest that these types of effects will occur 

from the proposed herbicide.” The risk assessments account for uncertainty 

(including risk of endocrine disruption) by using protective (cautious) toxicity values,

which are compared to potential operational and accidental exposures. The project 

design features include additional layers of caution. Glyphosate is not one of the firstchoice herbicides in alternatives B or C. It is the first-choice herbicide for 

approximately 724 acres (3 of these acres are potential broadcast acres) in 

alternative D.

01

Glyphosate kills aquatic life even if the concentrations of the 

chemical in water are very low. The fish deaths will occur in the 

streams in the project area and a few miles downstream. 

Herbicide mist should never be allowed to contact water ... 

even so-called aquatic-safe herbicides.

The 2011 risk assessment and site-specific modeling do not indicate that fish deaths 

will occur. Sub-lethal impacts are addressed. The potential exists for very low 

amounts of herbicide to reach water. However, project-specific modeling (see pages 

140-142 in the DEIS) indicates that glyphosate will not enter water at all (one model 

run suggested 1/1000th of a part per billion, which is orders of magnitude below a 

concentration that could cause an impact to fish; a non-lethal potential for olfactory 

interference at 1 ppb). Drift will be managed through herbicide-use buffers that 

prevent broadcast treatments near streams, and limitations on the weather conditions 

under which spray would occur.

01 Glyphosate is persistent and remains active for several days 

after being applied.

Glyphosate is rapidly taken up by an invasive plant and any glyphosate that contacts 

organic material in the soil is rendered inactive. Page 77 of the DEIS stated, 

“Glyphosate is quickly taken up by plants or bound up with soils so that it is not 

mobile in the environment soon after application.” Page 77 also stated, “Effects of 

glyphosate from invasive plant treatments are very limited in time and space to the 

immediate area of the treatment.” 

01

[G]lyphosate-containing herbicides are likely to cause bee 

Colony collapse disorder (CCD) that’s currently driving bees 

extinct [several citations attached].

The attached articles to do not provide scientific information that was not previously 

reviewed by SERA or the Forest Service. Colony collapse disorder was addressed in 

the DEIS at page 113, with the conclusion, “implementation of any of the action 

alternatives would not have adverse effects on honey bees or contribute to the 

potential cause(s) of CCD.” The section on colony collapse disorder has been moved 

to Chapter 3.7 (Wildlife) in the FEIS.

12 Drop all use of picloram, triclopyr and imazapyr. Risks associated with herbicide use were discussed in the risk assessments, the R6 

2005 FEIS and in the Malheur Invasive Plant Treatment DEIS. 

12 Drop the use of NPE due to its potential for endocrine disruption 

and other harmful effects.

The action alternatives have been modified to prohibit the use of NPE-based 

surfactants (pdf F1).

12 No broadcast of picloram or sulfometuron methyl. Sulfometuron methyl would be approved for use (including broadcast) in alternatives 

B and D, but is not a first-choice herbicide for the target species found on the 

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Malheur National Forest. Picloram is a first-choice herbicide for about 63 acres in 

alternative D. Of these, about 36 acres are of a size that may require broadcast 

spraying. Picloram would not be used, nor would any herbicide be broadcast in 

alternative C. The alternatives were compared throughout the DEIS, and rationale for 

the decision will be in the Record of Decision for this project. 

12 Drop use of picloram, too mobile, too persistent, has HCB

Alternative C would not include use of picloram, and picloram is not a first-choice 

herbicide in alternative B. It is a first-choice herbicide if aminopyralid is not available. 

The DEIS did not find that restrictions in alternative C were necessary to meet 

management direction for herbicide use. Unnecessary restrictions on the use of 

herbicides approved in the R6 2005 Record of Decision would increase cost and 

decrease treatment effectiveness.

12 Triclopyr should not be used for many reasons, including 

toxicity to aquatic organisms and soils.

Triclopyr is not a first-choice herbicide in any alternative. Herbicide-use buffers would 

avoid use of the more toxic ester formulation of triclopyr near streams. Herbicide 

application of highly soluble chemicals would be avoided during snowmelt when soils 

are likely to be saturated (DEIS table 9, pdf H5, H6).

12 We are opposed to any broadcast spraying near streams. Alternative C does not allow any broadcast application, nor does it allow any 

herbicide use within 100 feet of streams and other water bodies.

07

[T]here are multiple other areas which I feel would be greatly 

harmed by the reliance on herbicides in this plan [such as] Long 

Creek municipal watershed.

Currently, 0.1 acres of invasive plants are mapped within Long Creek Municipal 

Watershed. Table 2 of the DEIS indicated that herbicides were unlikely to be needed 

to treat this infestation.

07

There also should be a greater buffer for riparian areas, at least 

100 feet from high water table areas, and 300 feet near major 

streams and rivers

Alternative C would virtually eliminate the potential for herbicides to reach streams 

and other water bodies. There is no evidence that a large buffer would be necessary. 

The rationale for selected alternative will be in the Record of Decision.

04

Near water and other sensitive sites, we urge the Forest 

Service to apply precautions that go above and beyond the 

minimum requirements on the label.

The project design features and buffers for alternatives B, C and D provide 

precautions beyond label requirements, based on the potential for herbicides to 

adversely affect resources of concern. Examples include pdf F2, which limits 

herbicide application rates below label maximums, pdf F4 that sets strict guidelines 

for nozzle size to reduce potential for drift, pdf F5 that limits use of sulfonylurea 

herbicides in certain areas (page 34). Project design feature Group H on pages 35 

and 36 and the herbicide-use buffers on page 43 also go beyond label advisories to 

protect soil and water. Project design feature Group I go beyond the label to protect 

botanical species of concern (page 36-38). Project design feature Group J goes 

beyond the label to protect wildlife species of concern (pages 38-40).

08

The use of herbicides could result in myself and people who 

also pursue edible plants, mushrooms, or animals who 

consume them to suffer poisoning in treated areas... They 

[herbicides] should not be used in key areas of human plant 

consumption, such as in native people’s cultural plant gathering 

sites, berry patches, mushroom foraging areas, or areas with 

The herbicide exposure scenarios analyzed in the risk assessments, the R6 2005 

FEIS and the Malheur National Forest Site-Specific Invasive Plant Treatment Project 

DEIS considered the potential impacts on people and animals who may inadvertently 

consume contaminated vegetation (including mushrooms) and fruit. Given the project 

design features, the type and extent of herbicide use proposed, and the risk 

assessment findings, the likelihood of adverse effects to people and wildlife is 

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medicinal herbs. relatively low. High [public] use areas, including administrative sites, developed 

campgrounds, visitor centers, and trailheads would be posted in advance of herbicide 

application or closed (pdf K1, page 41). The DEIS noted that postings would indicate 

the date of treatments, the herbicide used, and when the areas are expected to be 

clear of herbicide residue. The public would be notified about upcoming herbicide 

treatments via the local newspaper or individual notification, fliers, and posting signs. 

Forest Service and other websites may also be used for public notification (pdf K2, 

page 41). Project design features L2-L4 have been modified so that forest product 

gathering areas identified by the public will be prominently posted. Cultural plants in 

areas identified by tribal members would be buffered similarly to other botanical 

species of concern (pdf M1, page 41). Taken together, these pdfs provide a high 

level of protection so that people would not become exposed to herbicides used for 

the project. The human health analysis found that the threshold of concern for people 

would not be exceeded even if a person ate contaminated vegetation or fruit, based 

on relatively extreme exposure scenarios, such as a person consuming a pound of 

contaminated berries (DEIS page 93). Morels are the main mushroom species 

collected on the Malheur National Forest. These fruit in the spring, most herbicide 

treatments will occur in mid- to late-summer. 

12

Don’t use herbicides in campgrounds, visitor centers, at 

trailheads or along trails. Many people are chemically sensitive 

and children and elders are particularly vulnerable.

The human health risk assessment included layers of caution to account for chemical 

sensitivity. Project design features include public notification and posting of public 

use areas. Taken together, all of the restrictions suggested in this comment letter 

would be commensurate to no herbicide use as reflected in the no action alternative. 

12

The public has a right to find and use uncontaminated edible 

and medicinal plants in National Forests. All of these areas 

[special forest products, cultural plants] should be off-limits to 

herbicide use, including also known and large flush locations of 

medicinal plants. Our supporters, staff, and volunteers use 

medicinal and edible plants gathered from the National Forests. 

We don’t want to be poisoned.

The low extent of herbicide use across the Malheur National Forest indicates that 

uncontaminated edible and medicinal plants would remain throughout the Forest. 

Morels are the main mushroom species collected on the Malheur National Forest. 

These fruit in the spring, most herbicide treatments will occur in mid to late summer. 

Project design features L2-L4 have been modified so that forest product gathering 

areas identified by the public will be prominently posted. . Use of dye, posting and 

notification would be helpful to keep people from inadvertently visiting sprayed areas. 

12

Herbicide use should not be allowed close to water. We support 

the assumption that herbicide use buffer would cover entire 

infestation if any part is within the buffer distance, but larger 

buffers should constitute no herbicide zones. No herbicide 

spraying should be allowed near riparian areas. 100 feet is not 

a sufficient buffer to avoid spray drift or runoff effects. We are 

opposed to the use of herbicides to the water’s edge or within 

PACFISH/INFISH buffers.

Alternative C includes restrictions on all herbicide use near water. Buffer distances 

are based on best available information regarding the persistence, mobility and 

relative toxicity to the aquatic environment of proposed herbicides. DEIS pages 143-

144 discussed studies that were used to develop the buffer distances. 

PACFISH/INFISH buffers are not based on herbicide information, but on surface 

disturbance from timber harvest, and thus would not be appropriate to use as 

herbicide-use buffers. 

Site-specific model runs are updated in the FEIS. The model runs suggest that the 

buffers are sufficient to minimize adverse impacts to the aquatic environment. The 

amount of herbicide that could reach streams in all alternatives is below a threshold 

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of concern for fish. 

12

Broadcast spraying should be avoided within 100 feet of 

streams and water bodies. Or more if botanical species of 

conservation concern as physical barriers would be insufficient 

to prevent plant uptake of herbicides through roots or surface 

run-off.

Alternative C does not allow any broadcast application, nor does it allow any 

herbicide use within 100 feet of streams and other water bodies. Alternatives B and D 

do not allow broadcast spraying of most herbicides within 50 to 100 feet of wet 

streams (except for aminopyralid, which may be broadcast to the waters’ edge, and 

poses very low risk to aquatic resources). 

12

We are opposed to herbicide use in Wilderness Areas, Wild and 

Scenic River Corridors, Inventoried Roadless Area, potential 

wilderness areas, and areas within 500 meters of developed 

recreation sites.

This suggestion was considered as an alternative, but was not developed for detailed 

study. The no action alternative would not approve herbicide use in these areas. 

Taken together, all of the various suggestions for areas to avoid herbicide use are 

tantamount to no herbicide use (i.e., no action). Non-herbicide treatment could be 

done using categorical exclusions or as an action connected to another project. 

Herbicide use in these areas would follow management direction specific to these 

areas. 

12 Do not use herbicide in wilderness areas. Use handpulling and 

mechanical if necessary.

Herbicide could be used in wilderness areas in all action alternatives. Herbicide use 

would have to be approved by the Regional Forester via a pesticide use proposal. A 

minimum decision analysis would be conducted and documented for treatments other 

than hand pulling. The intent is to maintain wilderness values that are threatened by 

invasive plants. Mechanical treatments (motorized and mechanized equipment) are 

not allowed in wilderness areas. The use of herbicides in wilderness areas may 

reduce the wilderness experience for some users in the short term, but active 

treatment provides the best protection of wilderness character and values (DEIS 

page 257). 

08

Herbicides should not be used within 100 feet of streams or 

areas with high water tables, or within 300 feet of major rivers 

and creeks.

There is no evidence that a large buffer would be needed to protect water quality or 

aquatic organisms. The GLEAMS model runs have been updated for the FEIS and 

include a hypothetical “worst-case” scenario for alternatives B and D assuming that 

the maximum annual herbicide application occurs (10 acres in a 6th field watershed) 

without any herbicide use buffer. This same scenario was run for alternative C with a 

100 foot buffer imposed. In all alternatives, peak water concentrations were far below 

any levels of concern for fish. 

06 / 10 We are opposed to the use of herbicides in the Long Creek 

municipal watershed.

Currently, 0.1 acres of invasive plants are mapped within this municipal watershed. 

Table 2 of the DEIS indicated that herbicides were unlikely to be needed to treat this 

infestation. Use of herbicides in municipal watersheds would be coordinated with 

water use managers and would follow pdfs and herbicide-use buffers (see pdf Group 

H). Drinking water would not be adversely affected. 

12

How does pdf H4 manage the persistence of picloram, which 

can last up to 3 years, yet annual reapplication would still be 

allowed. This could really raise soil concentrations and keep 

native plants suppressed. The soil pdfs do not effectively 

reduce the potential for picloram to build up in the soil and have 

Project design feature H3 would avoid use of picloram on bare or compact soils, and 

inherently poor productivity soils that are highly disturbed. Poor soils include shallow 

soils less than 20 inch depth that lack topsoil and serpentine soils. As described in 

Chapter 3.4, herbicide half-life is shortened when soil microbes help break down the 

herbicide. The action alternatives were modified in the FEIS to limit reapplication of 

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impacts on soil organisms, since it has a half-life of 3 years. picloram to once every two years.

12

We do not agree that the potential for toxic effects to actually 

occur are accounted for by using very protective thresholds 

(toxicity values). Especially regarding NPE, which is known to 

cause endocrine disruption. The more protection is based on 

multiple pdfs; the more pdfs, the more unreliable the use of 

pdfs.

The toxicity values (threshold of concern used to determine hazard quotient) are 

much lower than the rate known to cause human health effects. This helps account 

for uncertainties. The intent of the design features is to minimize risk to the extent 

possible, while still allowing for a range of effective treatments over a range of 

treatment situations. In response to this and other comments, the alternatives were 

modified in the FEIS to prohibit use of NPE-based surfactants (pdf F1).

12 Vehicles transporting herbicides should not go near drinking 

water sources or major rivers, creeks and lakes.

There is no realistic way for vehicles not to use roads that cross rivers. However, pdf 

G requires consideration of herbicide transportation and handling safety. The quantity 

of herbicides to be transported to treatment sites would be limited to the amounts that 

are estimated to be needed for any given day. No significant spills or incidents that 

require reporting at the state or national level have occurred in the region. 

07

A plan must be made that relies on herbicides only as a last 

resort, with proper explanation of why this is so, that includes a 

mandatory decline in herbicide use, that does not spray in the 

above mentioned areas of concern, that contains no early 

detection/rapid response use of herbicides, and that is based 

behind more adequate testing of herbicides, such as the effects 

of herbicide impurities, and synergistic effects when multiple 

herbicide are sprayed in the same areas. Without this, I feel that 

the Forest Service is putting human health and the health of the 

forest I love at great risk. Please take these comments into 

consideration and work to develop a plan that controls invasive 

plants without poisoning our forest.

Herbicides are proposed as part of an integrated pest management approach. 

Current management direction does not require the use of herbicides as a last resort. 

As noted, in the R6 2005 Record of Decision, the Regional Forester considered but 

rejected this alternative, partially because using herbicides as a tool of last resort 

would have deviated from integrated weed management principles (R6 2005 Record 

of Decision page 6, page 27). However, herbicides would only be used where 

necessary. The DEIS noted (page 49), “If the target invasive species population is 

not associated with a size, phenology, density or distribution that warrants herbicide 

use (alone or in combination with other methods), or if herbicide use does not 

substantially increase treatment efficiency (considering the availability of volunteers if 

needed), then non-herbicide methods would be favored.” A mandatory decline in 

herbicide use is not implementable at the project scale due to the uncertainty of 

funding over time. However, the desired condition is that the need for invasive plant 

treatment is reduced due to the effectiveness and habitual nature of preventative 

actions, and the success of restoration efforts. Reduced reliance on herbicides would 

be expected at effectively treated sites (see section 3.1.4, Treatment Effectiveness). 

The more effective the integrated treatment, the less need for herbicide in the future. 

See DEIS page 59. Early detection/rapid response using herbicides is needed to 

allow the Forest Service flexibility to treat invasive plants in a timely and costeffective manner. While there are data limitations, risk assessments contain the best 

available scientific information.

12

It doesn’t matter that agency herbicide use is low compared to 

private lands use; agencies should set the tone for promoting 

alternatives to herbicides.

The low amount of comparative herbicide use is part of the reason why the 

contribution toward cumulative effects of herbicide use is low with this project. No 

herbicides have been used on the Malheur National Forest for many years. 

Categorical exclusions would likely authorize manual and mechanical treatments in 

the future if the no action alternative is selected. 

12 Glyphosate is only one of the top 5 pesticides in use on private 

and state lands. What other herbicides are in use and how 

The effects of herbicides approved for agriculture and other uses off Forest Service 

land have not been specifically analyzed. Total amount of herbicide use in the river 

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ID # Comment Forest Service Response

mobile, soluble, and persistent are they? basins adjacent to the Malheur National Forest is not known. However, as stated in 

Chapter 3.1.5, the relative scale of this project is so small that it is unlikely to 

contribute to measurable, detectable herbicide concentrations in downstream waters. 

Multiple herbicide exposures are unlikely to occur in close enough proximity in time or 

space with other applications to trigger cumulative effects. The small, scattered 

nature of the infestations, the relatively low toxicity and potential to cause adverse 

effects associated with the herbicides proposed for use, the pdfs, herbicide-use 

buffers and treatment caps that limit the extent, intensity and duration of potential 

adverse effects, and treating invasive plants cooperatively across administrative 

boundaries, all serve to minimize the potential for adverse effects to accumulate and 

amount to a measurable impact on people or the environment.

12

First paragraph (on page 77) glosses over differences in toxicity 

and mobility of herbicides proposed for use in the project by 

stating that “most of the herbicides proposed for use would not 

persist in the environment for more than a few weeks or 

months, and those that would remain longer have pdfs limiting 

the frequency of use so that effects do not accumulate at the 

treatment site.”

More discussion about persistence of each herbicide was provided in the DEIS 

Chapter 3.4. The section referenced in this comment was intended to provide a 

general introduction and has been edited in the FEIS. 

12

Given uncertainties in the risk assessments, and actual 

combined or chronic levels of exposure and synergistic and 

chronic herbicide effects, exposure should be limited by greatly 

restricting herbicide use or keeping herbicide out of areas of 

high public use, or involving consumption or handling of plants.

Toxicity values are much lower than the rate known to cause human health effects. 

This helps account for uncertainties. Project design features are intended to further 

add layers of caution where possible. The R6 2005 Record of Decision (Malheur 

National Forest LRMP) standard requires that design features minimize risk to the 

extent possible, while allowing for effective treatments. 

12 Is there a pdf requiring that herbicide not be used at maximum 

rates? If not, there should be.

Maximum herbicide use rates would not be used in general. Project design feature 

F2 includes the following language: “The least amount of a given herbicide would be 

applied as necessary to meet control objectives.” This applies to all action 

alternatives. Project design feature F2 also restricts broadcast spraying to typical 

rates for clopyralid, glyphosate, picloram, sethoxydim, and sulfometuron methyl. The 

lowest effective rate would be used in any given situation. 

12

High run-off potential sites also cover a lot of the ground on the 

Malheur. This is a good reason not to use maximum herbicide 

use rates in general and to use herbicides as little as possible.

Project design feature F2 requires that the least amount of a given herbicide would 

be applied as necessary to meet control objectives. This applies to all action 

alternatives. Alternatives B and D include broadcasting), however broadcast 

application of clopyralid, glyphosate, picloram, sethoxydim, or sulfometuron methyl 

will not exceed typical application rates. Imazapyr has additional rate restrictions in all 

action alternatives.

12 We are not convinced that the aquatic label herbicides are safe 

for aquatic life.

Aquatic labeled herbicides pose less risk to the aquatic environment than their 

terrestrial counterparts. The effects of using these herbicides were discussed 

throughout the DEIS. 

12 All of the notification methods could easily be missed by casual 

visitors and recreationists hiking, camping in user created 

The use of colored dye would be difficult to miss, in addition to the other notification 

methods. The human health analysis in Chapter 3.2 discussed the low potential for 

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camps, eating berries, etc. public exposure to herbicide to exceed a threshold of concern, using conservative 

toxicity values that are far below a level of concern for human health. 

12 We are opposed to herbicide use for eradication of native plant 

species considered noxious such as poison water hemlock. This project would only authorize treatment of invasive plants.

12

The first question [in the decision to use herbicides figure 4] 

should have its own broken down decision tree to guide 

decision-making whether or not to use herbicides. As it is, the 

answers to the question could be very subjectively based.

Figure 4 was developed to demonstrate the way that herbicide use would be 

approached as part of the integrated treatment prescription for a given site. Page 49 

of the DEIS (paragraph preceding figure 4) stated, “If the target invasive species 

population is not associated with a size, phenology, density or distribution that 

warrants herbicide use (alone or in combination with other methods), or if herbicide 

use does not substantially increase treatment efficiency (considering the availability 

of volunteers if needed), then non-herbicide methods would be favored.” The factors 

of target population species, size, phenology, density, and distribution are evaluated 

together to determine whether herbicide use is warranted. These factors are 

interdependent and there are no specific go/no thresholds that can be outlined in a 

decision tree.

12

We are opposed to using cost-effectiveness as a criterion for 

using herbicides as that will often be used to justify herbicide 

use as an easier, more convenient method, when most 

ecological impacts are usually avoided by not using herbicides. 

Asking whether use of herbicides substantially increase costeffectiveness biases the decision toward herbicide use and 

could increase herbicide impacts. Ecological costs should be 

factored in.

Ecological impacts were factored into the pdfs, herbicide-use buffers, and effects 

analysis in the DEIS. Cost and effectiveness are important factors in the decision to 

use herbicides. 

12

Couldn’t chlorsulfuron and metsulfuron methyl be replaced by a 

more ecologically benign herbicide in alternative C? Pro’s and 

Con’s, what about using glyphosate or imazapic instead or 

prioritizing non-chemical control methods. 

Glyphosate and imazapic are not the best choices for several target species nor are 

they necessarily “more benign” (see DEIS table 18). All of the herbicides proposed 

for use (except aminopyralid) were analyzed and approved in R6 2005 Record of 

Decision. The objective is to use the most effective integrated treatment option 

available while following pdfs to minimize adverse effects. 

12 We are wary of mixing different herbicides as the 

combined/synergistic effects have not been analyzed.

The R6 2005 Record of Decision Standard 16 requires that the Hazard Index be less 

than 1 for any tank mixtures to ensure low risks. This precaution accounts for data 

gaps regarding synergistic effects of different chemicals. In addition, tank mixtures 

would apply the largest buffer as indicated for any of the herbicides in the mixture 

(pdf H1). The common control measures do not currently include tank mixtures. 

However, they may be included in future treatments. 

12

Cost effectiveness should not be the primary considering a 

decision tree: when to use herbicides. [Use of herbicides] 

should be based on other methods not working.

Cost-effectiveness is an important consideration regarding the decision to use 

herbicides. The DEIS noted (page 49), “If the target invasive species population is 

not associated with a size, phenology, density or distribution that warrants herbicide 

use (alone or in combination with other methods), or if herbicide use does not 

substantially increase treatment efficiency (considering the availability of volunteers if 

needed), then non-herbicide methods would be favored.” In the R6 2005 Record of 

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Decision, the Regional Forester considered but rejected an alternative to use 

herbicides as a “last resort,” partially because using herbicides as a tool of last resort 

would have deviated from integrated weed management principles (R6 2005 Record 

of Decision page 6, page 27). The pdfs and herbicide-use buffers are intended to 

allow invasive plant managers the latitude to use the most cost-effective method 

available while minimizing adverse effects. 

01

My uncle lives in Seneca Oregon. He hikes, camps and fishes 

on the Malheur National Forest with his 2 children. I beg you, 

please do not approve the application of dangerous herbicides 

to Malheur National Forest land. Killing fish, birds and mammals 

(including human visitors to the forest) isn’t worth the risk to 

deal with invasive plants.

Scientific herbicide risk assessments do not indicate that any of the herbicides 

proposed for use on the Malheur National Forest will kill fish, birds or mammals. The 

potential for sub-lethal effects to fish and wildlife are discussed in the DEIS (Chapters 

3.6 and 3.7). These are not likely to occur given the nature of the project, the type of 

herbicides proposed for use, and the project design features associated with their 

use. There are low risks of impacts to human health (Chapter 3.2). Herbicide 

applicators and the public are not likely to be exposed to herbicide at a level that 

would cause human health impacts.

05 If Oregon needs more jobs, why not manually remove invasive 

species?

Manual removal of invasive plants has occurred on the Malheur National Forest for 

decades and would continue in the proposed alternatives. However, greater reliance 

on manual treatment is expensive and increases the time necessary to eradicate, 

control, and/or contain invasive plants (see DEIS Chapter 3.1.4). Some target 

species cannot be adequately treated using manual methods (see DEIS table 8). 

07

My problems with this plan are...centered around the heavy use 

of toxic herbicides, which would threaten wildlife and human 

health, damage fragile riparian areas, and which does not stop 

the spread of invasive plants, through carriers such as ATVs 

and livestock.

We do not consider the treatment of about 2,000 acres per year within nearly 1.7 

million acres of the Malheur National Forest as heavy use. Herbicides are intended to 

be toxic to the target invasive plants to be eradicated, controlled, contained or 

suppressed. Threats to wildlife and human health are low. Treated riparian area 

vegetation would likely experience rapid regrowth, and the majority of near-stream 

vegetation would not be treated. (DEIS at page 158). The DEIS acknowledged that it 

would not stop the spread of invasive plants. However, the amount of acreage 

subject to spread would be reduced with effective treatments (DEIS Chapter 3.1.4.). 

Vectors for invasive plant spread are acknowledged and discussed in section 3.1.5 

and the various cumulative effects sections in the DEIS. 

12

Which herbicides had risk assessments after 2004 [when the 

identity of confidential business information stopped being 

available to risk assessor]? This raises doubts re: the extent 

and nature of their full toxic effects.

Risk assessments for glyphosate, imazapyr, picloram and triclopyr were updated in 

2011. All available information from the previous risk assessments, along with new 

information was considered in the DEIS. The risk assessments provide the best 

available scientific information regarding the use of herbicides on National Forests. 

The risk assessments, LRMP management direction, and the project design 

features/herbicide-use buffers all add layers of caution that account for data gaps 

and uncertainty. 

Human Health

01

Literature authored by independent scientists not connected 

with Monsanto or the USFS indicates mammals that eat 

contaminated foliage and humans that might brush against 

SERA Risk assessments use best available scientific information, including 

independent studies. The risk assessments include analysis of impacts from direct 

contact and vegetation/fruit consumption, along with other exposure scenarios. None 

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contaminated foliage or eat contaminated berries have been 

known to suffer from the following as a result of glyphosate 

contact: birth defects, non-Hodgkin’s lymphoma, mitochondrial 

damage, cell asphyxia, miscarriages, attention deficit disorder 

endocrine disruption, DNA damage, skin tumors, thyroid 

damage, hairy cell leukemia, Parkinson disease, premature 

births, decrease in the sperm count, harm to the immune 

system in fish death of liver cells, severe reproductive system 

disruptions and chromosomal damage.

of the above effects noted by the commenter are indicated from the analysis of the 

proposed glyphosate, or other herbicide use.

01

The results of independent, unbiased research on glyphosatecontaining herbicides indicate this chemical is causing: birth 

defects, non-Hodgkin’s lymphoma, mitochondrial damage, cell 

asphyxia, miscarriages, attention deficit disorder, endocrine 

disruption, DNA damage, skin tumors, thyroid damage, hairy 

cell leukemia, Parkinson disease, premature births, decrease in 

the sperm count, harm to the immune system in fish, death of 

liver cells, severe reproductive system disruptions and 

chromosomal damage [several web links attached]. 

All of the websites provided by Respondent #01 were reviewed. Studies linking 

glyphosate to cancer, neurological diseases, birth defects, and other health concerns 

generally are for herbicide use rates, formulations, or uses that are dissimilar to this 

project. Some of the websites refer to cellular level studies that are not applicable to 

real world exposure risks. Research conducted on whole organisms (e.g., rats, quail, 

etc.) using plausible exposure routes (e.g., dietary, direct spray) with glyphosate 

provide the best available science regarding risk from Forest Service applications. 

Whole organism studies have been conducted, have been reviewed by the EPA, are 

included in Forest Service risk assessments, and form the basis of our conclusions. 

The risk assessments and other information in this EIS constitute best available 

science. 

The websites cite studies that either are flawed or opinionated reports about scientific 

studies that were evaluated or included in the Forest Service risk assessments. 

Disagreement about how herbicides are labeled and the risk assessment process are 

outside the scope of a project level EIS, which is based on current best available 

science. Risks associated with the use of glyphosate are addressed in the DEIS and 

the SERA risk assessment for glyphosate was updated in 2011 to ensure best 

available scientific information was considered. Several invasive target species are 

effectively treated with glyphosate. The pdfs and herbicide-use buffers are designed 

to minimize or eliminate risks of herbicide use, including glyphosate. 

12

There is obviously less effect to humans using special forest 

protects (i.e. native plants) if there is less overall herbicide use 

and plant gathering areas are not sprayed.

There is very low likelihood that any member of the public would be exposed to 

harmful levels of herbicide in this project. This is why effects to people are considered 

the same in all alternatives. 

12

Re: the finding that on page 97 that the difference in impact on 

human health from the restrictions in alternative C are not 

meaningful or measurable: Let the public determine if the 

difference in human health impact are measurable or 

meaningful – after all, we are the ones on the receiving end and 

with no economic stake biasing us toward using herbicides. The 

analysis is not accounting for the spiritual and cultural need to 

The Forest Service has the responsibility to compare alternatives. An interdisciplinary 

team comprised of resource professionals made the comparisons. The rationale for 

the selected alternative will be in the Record of Decision.

The human health impacts consider ingestion of sprayed vegetation. However, the 

pdfs minimize the potential for effects to non-target vegetation. 

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have a source of food and medicine available that has not been 

contaminated with toxins, and the joy and solace in gathering 

plants in their natural setting.

The human health analysis does not consider spiritual or cultural needs. Cultural 

plants identified by tribes would be buffered as botanical species of concern. 

Individual medicinal and edible plants may be affected by adjacent treatments. 

However, the vast majority of medicinal and edible plants would not occur in the 

vicinity of invasive plant treatments. 

12 Human health issue should include anything people consume 

including wildlife and livestock, edible plants, soils.

Effects on the potential for people to consume contaminated vegetation, fruit and fish 

were addressed in the DEIS Chapter 3.2. 

12 Herbicide exposure for people can be indirect as well as direct. The human health analysis in Chapter 3.2 considered direct and indirect routes of 

herbicide exposure. 

12

See our other comments already submitted for human health on 

R6 2005 FEIS since you are summarizing analysis for the R6 

2005 FEIS.

Comments submitted to the R6 2005 DEIS were addressed in Appendix A of the R6 

2005 FEIS. Comments specific to the Malheur National Forest Invasive Plant DEIS 

are addressed herein. 

12

We are very concerned re: human health impacts and disregard 

for cultural and spiritual values about planned herbicide 

poisoning of edible and medicinal plants, including indigenous 

cultural plants like Biscuitroot, Cous, Camus and others.

The EIS has been edited to acknowledge that some people may feel that any 

herbicide use degrades the spiritual value of plant collection on the Malheur National 

Forest. No “herbicide poisoning” is “planned” for cultural plants. Cultural plants 

identified by tribes would be protected as botanical species of concern (pdf M1). 

Treatment areas would be posted and treated plants would be marked with colored 

dye. Damage to non-target plants would be obvious soon after spraying. People are 

unlikely to ingest sprayed vegetation, and if they do, the amount would likely be too 

low to cause human health impacts. 

12

The public may eat contaminated edible plants and use 

contaminated medicinal plants (e.g. berries, nettles, arnica, 

Oregon grape, edible mushrooms, arrowleaf balsamroot, 

lomatiums and others.)

None of the species mentioned in the comment would be intentionally sprayed so 

any herbicide contact would be incidental. Damage to non-target plants would be 

avoided to the extent possible. Treatment areas would be posted and treated plants 

would be marked with colored dye. Treatment areas would be posted and treated 

plants would be marked with colored dye. Damage to non-target plants would be 

obvious soon after spraying. 

12

We are concerned that workers conscripted from prisons are 

not fully aware of the risks they are facing from herbicide 

exposure and not be adequately protected.

All workers would be supervised by a licensed pesticide applicator. Federal, state 

and county employees and professional contractors are the workers most likely to 

apply herbicides on the Malheur National Forest. 

12

Worker health can best be protected by not using the herbicides 

with highest human health risks, such as triclopyr, and greatly 

reducing herbicide use (modified alternative C).

All workers would be supervised by a licensed pesticide applicator and safety 

measures would be emphasized. Triclopyr is not a first-choice herbicide for any 

target species in any alternative. However, it would be used in the event that other 

herbicides were not effective. 

12 Worker use of protective clothing and other protective gear 

should be monitored and enforced.

All herbicide applications in the Pacific Northwest Region of the National Forest 

System must be supervised by a licensed applicator. Job Hazard Analyses and 

Safety Plans that are required by Forest Service policy include discussions of 

personal protective equipment. Forest Service compliance with required safety 

measures is part of ongoing Environmental Compliance audits. Safety violations have 

been noted during contract inspections (see Desser 2014 monitoring write-up). 

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OSHA also inspects and monitors worker health and safety. 

12

Drop triclopyr due to high HQ values. Drop picloram and 

clopyralid due to HCB cancer risk. Who decides what is an 

acceptable risk for cancer? The workers are usually not 

consulted or these days are desperate for any work and should 

not be exposed to this risk.

The EPA establishes thresholds for cancer risk. None of the proposed herbicides are 

associated with a risk of cancer over the EPA threshold. The human health analysis 

does not indicate significant risks from this project to workers. Risk assessment 

thresholds of concern are far below levels known to affect human health, the upper 

bound estimates that indicate risks to workers are unlikely to actually occur, and pdfs 

appropriately reduce risk. The project would meet R6 2005 Record of Decision 

(Malheur LRMP) standards. 

12

We also do not trust risk assessments to be fully accurate as 

usually only the active ingredients are tested in isolation, not in 

combination with other herbicides or with formula-incorporated 

inert ingredients, metabolites, impurities, etc. Nor are they 

tested for synergistic or most chronic effects...we do not trust 

this theoretically “low” risk [of hazard quotient being below 1]. 

How do we know the Hazard Quotient method of analysis is 

sufficiently protective?

Risk assessments constitute best available scientific information. While there are 

limitations on available data, each of the Forest Service risk assessments address 

inert ingredients, metabolites, impurities and adjuvants, and contain information 

about chronic exposures to people and the environment. Data regarding synergistic 

effects is limited and identified as such in the EIS (Incomplete and Unavailable 

Information). Concerns about risk assessment methods are beyond the scope of a 

project level analysis. The National Academy of Sciences recently noted, “After 30 

years of use and refinement, this risk-assessment paradigm has become scientifically 

credible, transparent, and consistent; can be reliably anticipated by all parties 

involved in decisions regarding pesticide use; and clearly articulates where scientific 

judgment is required and the bounds within which such judgment can be applied. The 

process is used for human-health and ecological risk assessments and is used 

broadly throughout the federal government. Thus, the committee concludes that the 

risk-assessment paradigm reflected in the ecological risk assessment (ERA) process 

is singularly appropriate for evaluating risks posed to ecological receptors, such as 

listed species, by chemical stressors, such as pesticides.”(NAS 2013). 

One benefit of using the formulation of aminopyralid called MilestoneTM is that it 

does not contain inert or added ingredients other than water.

12

Many people (including myself) have been exposed to multiple 

toxins, increasing overall sensitivity. This is an increasing 

concern as more people live in cities and industrial areas and 

our environment becomes more polluted. The Forest Service 

can better meet Multiple Chemical Sensitivity by greatly 

reducing herbicide use, not using maximum application rates, 

and not using herbicides in areas frequented by people, such 

as campsites, trailheads, and edible/medicinal plant gathering 

areas). Yet this analysis looks at the effects of herbicide 

contamination in isolation, not considering cumulative human 

exposures to toxins and carcinogens.

Multiple chemical sensitivity was addressed in the DEIS on page 94. EPA and Forest 

Service risk assessments incorporate an uncertainty factor of 10 to account for 

sensitive individuals when establishing the human health level of concern, which may 

or may not eliminate risk that an individual may suffer symptoms. However, the 

uncertainty factor for sensitive individuals addresses variability in tolerances within a 

normal population. The cumulative exposure to toxins in cities and industrial areas is 

outside the scope of this project. 

12

Why is it assumed that the public will not be directly sprayed? 

Broadcast spraying could result in public exposure. We are out 

on the Forest during weekdays.

Workers applying herbicides using ground broadcast, backpack, and selective 

treatments would be able to avoid directly spraying a person. Direct contact is not 

likely to result in herbicide exposure to the public over a threshold of concern, given 

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the project design. 

12

Analysis of bioaccumulation seems suspect. Explain how HCB 

carcinogenicity can be characterized as low when 

bioaccumulation has such a high factor (20,000).

The bio-concentration factor is high but the amount of HCB in picloram and clopyralid 

is very low. Human exposure to picloram and clopyralid is also very low. HCB is a 

ubiquitous environmental contaminant, but the contribution from picloram and 

clopyralid is not significant. Cancer risk due to use of picloram and clopyralid is below 

the EPA threshold.

12

Surfactants and herbicides associated with endocrine disruption 

should not be used. Studies are lacking for most herbicides on 

the potential to bind with estrogen or androgen receptors. 

Chlorsulfuron and sulfometuron methyl effects on 

fertility/reproduction in some studies indicate our reasons for 

concern. 

Endocrine disruption is addressed in the Forest Service risk assessments and 

considered when establishing a level of concern for each herbicide. Endocrine 

disrupting effects often occur only at doses higher than other more sensitive 

endpoints used in our analysis, such as weight loss or effects to organs. None of the 

proposed herbicides pose a risk of endocrine disruption effects from exposures due 

to Forest Service use of the herbicides.

12

Glyphosate formulas should not be used in areas of high public 

exposure due to data gaps about surfactants and other 

ingredients. Hazards have not been identified due to lack of 

information on surfactants in different glyphosate formulas so 

they should not be used. 

There is quite a large body of data available on risk of glyphosate formulations 

containing surfactants, relative to other pesticides. The 2011 glyphosate risk 

assessment quantitatively evaluated the differences in risk from glyphosate 

formulations versus the active ingredient. No applications will result in high public 

exposure due to the proposed application methods, public notification, and other 

pdfs. 

12

Additive doses could happen because people could eat 

contaminated berries, mushrooms, fish and use medicinal 

plants as a usual or major component of their diet or health 

care, as with people using herbs repeatedly in doses for an 

illness or consuming the same food plants until they are gone 

(e.g. many mushrooms per meal). The net additive effects can 

be harmful and most risk assessments only study individual 

ingredients and do not look for synergistic effects. 

Chapter 3.2 discussed the potential for additive doses of herbicide. Chronic exposure 

from the consumption of contaminated fruit, vegetation, and fish were quantitatively 

evaluated in the risk assessments. There is no evidence that the herbicide use 

proposed for this project would pose a risk to human health from chronic exposures. 

Theoretically, additive acute doses from multiple routes could add up to an exposure 

of concern. However, the amount of fish, vegetation and fruit that would have to be 

consumed would be implausibly large given the scale of the project. No 

contamination of food products is expected to occur due to application methods, pdfs 

and herbicide-use buffers. Synergistic effects are unlikely from chemicals with low 

acute toxicity (DEIS page 98). 

12

Hard to believe that glyphosate would not have greater impacts 

than disclosed when a boy suffered anaphylactic shock from 

one glyphosate exposure.

Risk assessments cannot incorporate all allergic or chemical sensitivities. 

Anaphylaxis is well-documented from many common food items. Reviews of 

available data do not indicate any likely adverse effects from Forest Service use of 

glyphosate to control invasive plants.

12 The use of the glyphosate example for adding HQ’s does not 

account for higher HQ’s associated with other herbicides.

The FEIS has been modified to provide more information about why additive doses 

are implausible given the type of herbicide use proposed in this project.

12

It is unfair and a form of discrimination for some minority groups 

to be disproportionately exposed to herbicides based on their 

being forest workers, special forest product or subsistence 

gatherers. BMBP staff, supporters and volunteers are in this 

minority group. We may be exposed to herbicides over a 

No person is likely to be exposed to herbicides over a threshold of concern in this 

project. Herbicide applicators and those who spend the most time in the Forest would 

have a greater risk of exposure than the public. However, harmful exposure to 

herbicide is not likely for workers, assuming they follow typical occupational health 

and safety practices. For others, the pdfs (Groups K, L and M) require posting, 

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threshold of concern, and in doses greater than casual, onetime visitors who do not use plants or fish from the Forest. The 

effects of chronic exposures have not been well studied.

notification, information sharing, consultation with tribes, and minimizing herbicide 

use rates (pdf F2) to reduce potential exposure. Effects of chronic exposure are 

considered in the herbicide risk assessments, including estimates for people who 

subsist on fish and vegetation from the forest. There is little potential for the public to 

be exposed to herbicides over a threshold of concern and there is little potential for 

this project to create a chronic source of herbicide exposure for any member of the 

public or any minority group. 

Botany

12

This is more highly biased and unprofessional analysisapproved biological agents COULD weaken or kill a non-target 

plant, so it can’t be concluded that no direct effects could occur 

to sensitive plant species.

Biological control agents that are currently approved have been rigorously tested for 

their potential to affect native species. Only those that would not affect native species 

are currently approved. In the past, some biocontrols were released that were known 

to affect native thistles (Rhinocyllus conicus). This agent is no longer approved for 

use in Oregon or in Region Six of the National Forest System, and would not be 

redistributed on the Malheur National Forest. 

07

[T]here are multiple other areas which I feel would be greatly 

harmed by the reliance on herbicides in this plan. These areas 

contain those with threatened, sensitive, or rare botanical 

species. 

The pdfs in Group I (DEIS pages 36-38) were developed to protect botanical species 

of conservation concern. Rare plant surveys before project implementation, buffers, 

and training of implementation personnel would likely prevent impacts to sensitive 

plant populations and habitats. Most invasive plant infestations are in disturbed areas 

with very low probability of rare plant occurrence.

12 Avoid herbicide use anywhere near non-vascular sensitive 

listed plants due to effects uncertainty for these plants.

Sensitive non-vascular plants would be appropriately buffered. Monitoring is intended 

to address the uncertainty of effects of herbicides on non-vascular plants. Adverse 

effects on these plants have not been reported from other similar projects. 

12

Avoid broadcast spraying within 150 or more feet from sensitive 

plants due to spray drift and inadequacy of protective barriers to 

prevent toxicity from soil and water uptake. Don’t use herbicides 

on saturated or wet soils or on plants within 100-150 feet of 

sensitive plants. There should be no herbicide use on aquatic 

plants.

No broadcast spraying would occur in alternative C. The pdfs associated with 

surveying and buffering rare plants are expected to effectively protect them. No 

evidence of adverse effects on these plants has been reported from other similar 

projects. Project design feature I8 includes monitoring to ensure that no damage to 

rare plants is occurring. 

12

If the Malheur National Forest has less than one percent of its 

acreage covered by invasive plants and most sites are along 

roads, surely invasive plant sites in edible, medicinal and 

cultural plant gathering areas and in flushes or quantities of 

these plants could be avoided and protected from herbicide 

contamination as this area would be a very small subset of the 

total.

“Edible, medicinal and cultural plant gathering areas” are not mapped on the Malheur 

National Forest, so it is unknown to what extent there is overlap between these areas 

and invasive plant treatment sites. The design features for these areas have been 

changed in the FEIS to make them more implementable and to respond to public 

concerns about these areas. The new pdfs allow members of the public to identify 

specific gathering areas to make sure the people know whether these areas might be 

sprayed and so the areas can be posted prominently. In addition, the colored dye 

that will be used with the herbicides will act as a warning to people who may be 

gathering edible or medicinal plants. 

12 The botany section appears to involve a lot of rubber stamping 

rather than adequate detailed analysis on a site-specific level, 

Site-specific information included locations of invasive plants and rare plants, 

discussion about specific risks and benefits of treatment, and comparison of 

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even though this DEIS calls this a site-specific project. alternatives.

12

We want all sensitive plants fully buffered from any herbicide 

use. Most of these plant populations are probably mapped but 

not adequately addressed to determine that there would be no 

reduction in long-term viability from herbicide use affecting 

them.

The analysis in the DEIS demonstrated that there is little overlap between rare plants 

and invasive plants on the Malheur National Forest. Botanical surveys will be 

conducted to document locations of sensitive plants if suitable habitat is within 100 

feet of planned herbicide treatments. Before use of herbicides near known rare plant 

sites, treatment sites will be assessed to establish adequate buffers. 

12

The conclusion [that the project would not result in a trend 

toward federal listing of any sensitive plant or reduce long-term 

viability of any plant] is unsubstantiated with no analysis 

backing it up about how much their populations could be 

reduced or their range and numbers on the Malheur. There is 

insufficient information on which to base this optimistic 

conclusion. Herbicides kill plants are could in fact cause a trend 

toward listing of sensitive plants. Of course herbicides could 

lead to a reduction in long-term viability of some the sensitive 

plants.

The analysis in the DEIS demonstrated that there is little overlap between rare plants 

and invasive plants on the Malheur National Forest. The project design features were 

designed to protect rare plants (pdf Group I).

12

Re table 29: Handpull or use other nonchemical cultural control 

methods that won’t uproot, poison, or damage sensitive plants 

within 100 feet of [invasive plants].

Handpulling would be done if effective under all alternatives. Effectiveness of 

treatment is an important consideration for the protection of sensitive plants, as 

discussed in the DEIS in Chapter 3.3. 

12

When will sensitive plant surveys be done for areas proposed 

for invasive species treatment. It is essential prior to 

implementation.

Surveys would be done prior to implementation. Many of the sites identified in this 

analysis were visited in the summer of 2013 to better assess the relationships 

between the locations of the invasive and sensitive plants. This information has been 

entered into the Forest Service’s corporate database (NRM).

12

Will sensitive plant surveys be done prior to implementation in 

areas that are not considered to have high potential for 

sensitive plants but which may nonetheless have sensitive 

plants as yet not documented?

Surveys will be done prior to implementation where there is the potential to harm 

sensitive plants. 

12

Because information about the effects on non-vascular plants is 

lacking, and because it is not possible to state with 100 percent 

certainty that all sensitive plants will be detected during 

surveys, the less herbicide use, the better.

The DEIS considered the tradeoffs between no action and various levels of herbicide 

use. The project design features are a reasonable response to uncertainty, including 

monitoring. No losses of sensitive plants have been reported from similar projects 

across the region. 

12 We support restriction of use of herbicides within 100 feet of 

sensitive plants.

Pdf group I were developed to protect sensitive plants. Pdf I3 states that sensitive 

plants located within 100 feet of planned ground-based broadcast applications would 

be covered by protective barrier, or broadcast application would be avoided in these 

areas (spot or hand herbicide treatment, or non-herbicide methods may be used 

without covering sensitive plants). Pdf I4 states that when sensitive plants are within 

10 feet of saturated or wet soils at the time of herbicide application, only hand 

methods of herbicide application (wiping, stem injection,) would be used. These 

measures would protect the viability of sensitive plants. 

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12

Because little information is available about how herbicides may 

affect lichens and bryophytes, and because they occur in 

wetlands, rock surfaces and in late-successional forest 

ecosystems, do not use herbicides in these places.

Non-herbicide treatment could be done using categorical exclusions or as an action 

connected to another project. In the action alternative, would protect vascular and 

non-vascular plants and other botanical resources.

12

“Immeasurable” effects is an evasion of any quantification and 

way to seemingly minimize potential negative effects. 

Pollinators and native plant diversity are far too important to not 

take a precautionary approach.

Not all risks can be quantified. Professional biologists have used their expertise to 

make informed judgments about the likelihood of impacts. “Immeasurable” in this 

context is intended to mean “nearly non-existent. “

12

Canada and bull thistles should not be prioritized for herbicide 

spraying, they are not high priority for eradication and they 

attract pollinators. Honeybees will likely use invasive plants 

such as thistles and be killed or disoriented (indirectly harmed).

Canada and bull thistles are invasive plants and the objective of the project is to 

eradicate, control, contain or suppress these plants in a cost-effective manner that 

meets current management direction. The intent is to restore native plant 

communities in areas infested with invasive plants. Invasive plants threaten native 

plant diversity. Canada and bull thistle would not be treated while blooming – they 

would be treated at the rosette stage before any bees would be attracted to them. 

06 / 10

We are opposed to using herbicides near botanical species of 

conservation concern and in or near sensitive or rare plant 

populations.

The DEIS noted the places where invasive plants are within 100 feet of rare plant 

populations. Project design features in Group I (page 37-38) protect botanical 

resources while still allowing for removal of the invasive plants. Monitoring and 

adaptive management is proposed to ensure that the pdfs adequately protect 

botanical species of conservation concern (pdfs I6, I7, I8 and I9). 

Cultural, Edible, Medicinal Plants

12

It is very insulting that tribal members can provide input or be 

notified, but not stop the contamination of cultural revered 

plants, tainting ancestral gathering areas, and potentially 

harming those who use the plants! If individual plants of cultural 

significance will be buffered, why not prohibit herbicide use in 

the cultural plant gathering areas and other popular plant 

gathering areas for the rest of the public. This is absurd!

No tribal members have expressed concern about the project. There is no evidence 

that culturally revered plants will be contaminated, ancestral gathering areas will be 

tainted, or anyone using cultural plants will be harmed by the project. Cultural plant 

gathering areas have not been mapped so the overlap between these areas and 

invasive plants is not known, however cultural plants would be treated similarly to 

sensitive plants in areas identified by tribal members (pdf M1) Use of blue dye will 

warn all people where spraying has occurred.

06 / 10 / 12

[In Alternative C], the Forest Service is still planning to use 

herbicides in key areas of human plant consumption such as 

where there are edible berries, flushes of medicinal herbs, 

indigenous people’s cultural plant gathering sites, and 

mushroom gathering areas. We are asking for there to be no 

herbicide use in these areas. Culturally significant plants and 

special forest product gathering areas are known by local 

people and it would be possible to map and protect at least 

popular, large populations and gathering areas. These should 

be protected from herbicides. The public has a reasonable 

expectation that edible and medicinal forest plants and 

gathering areas will not be poisoned or contaminated by toxic 

High [public] use areas, including administrative sites, developed campgrounds, 

visitor centers, and trailheads would be either posted in advance of herbicide 

application or closed (pdf K1, page 41). The public would be notified about upcoming 

herbicide treatments via the local newspaper or individual notification, fliers, and 

posting signs. Forest Service and other websites may also be used for public 

notification (pdf K2, page 41). The Forest Service has not mapped culturally 

significant plants and medicinal/edible plant gathering areas. To respond to concerns 

about these areas, pdf L2 has been modified in the FEIS to read: “Specific 

edible/medicinal plant collection areas, along with specific areas of cultural or spiritual 

value, may be identified by the public. These areas would be specifically posted prior 

to spraying. Postings would indicate the date of treatments, the herbicide used, and 

when the areas are expected to be clear of herbicide residue. “In addition, cultural 

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chemicals. plants in areas identified by American Indian tribal members would be buffered 

similarly to other botanical species of concern. In addition, blue dye would be used to 

mark any area sprayed with herbicide (pdf M1). These pdfs would allow people to 

avoid plant gathering in sprayed areas. The human health analysis found that the 

threshold of concern for people would not be exceeded even if a person ate 

contaminated vegetation or fruit, based on relatively extreme exposure scenarios, 

such as a person consuming a pound of contaminated berries (DEIS page 93). 

Pollinators

12 How do you plan to avoid harming pollinators?

Invasive plants would not likely be treated when pollinators are present, thus they are 

unlikely to be affected by herbicide use. Page 105 of the DEIS noted, “The North 

American Pollinator Protection Campaign (2006) determined that invasive plants, left 

untreated, shift species composition and affect pollinated plants by disrupting the 

structure and function of ecosystems.” The discussion of colony collapse disorder 

and pollinators has been moved from section 3.3 to 3.7 in the FEIS. 

12 Pollinators may be decimated by herbicide use.

No evidence exists to indicate that pollinators would be decimated by herbicide use 

from this project, as suggested by the commenter. The timing of treatments, 

treatment acreage limitations and pdfs that restrict the use of glyphosate and 

triclopyr, and other pdfs would limit herbicide exposure and minimize any harm to 

pollinators. Effects of herbicide application on pollinators was discussed in the DEIS 

on page 105-106, and 112 to 113. The discussion of colony collapse disorder and 

pollinators has been moved from section 3.3 to 3.7 in the FEIS.

12 As native wild bees do not seem to be affected by colony 

collapse disorder, it is important to fully protect them as much 

as possible from herbicides and uncontrolled invasive plants. 

Exotic honey bees are economically important to protect and 

have been more exposed to agricultural toxins.

Invasive plants would not likely be treated during the blooming stage when pollinators 

would be attracted to them, thus they are unlikely to be affected by herbicide use. 

Implementation of the action alternatives would not have adverse effects on honey 

bees or contribute to the potential causes of CCD (DEIS p 113). The discussion of 

colony collapse disorder and pollinators has been moved from section 3.3 to 3.7 in 

the FEIS. 12 Direct herbicide application to plants [using any rate or method] 

could easily expose bees who crawl into blossoms.

12

The optimistic and biased conclusion that the action alternatives 

would not have adverse effects on bees or colony collapse 

disorder is not supported by the evidence presented in the 

DEIS.

The comment is unclear about what evidence in the DEIS does not support our 

conclusions. The discussion of colony collapse disorder and pollinators has been 

moved from section 3.3 to 3.7 in the FEIS.

Soil, Water, Sediment

12

Riparian sedges and shrubs may also provide significant shade, 

especially in drier forest types [thus it is not true that lack of 

impact on large woody shrubs would protect shade].

Invasive plants do not provide significant shade and no impact to water temperature 

would be predicted. 

12 Fueling of machines with tanks smaller than 5 gallons should 

also be restricted to not within 150 feet of surface waters. 

This design feature would apply to chain saws and mowers that are commonly used 

on the Malheur National Forest. Adverse effects to riparian areas would not be likely 

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from refueling small tanks. 

12

Why is the amount of sediment produced in alternative so low 

that there would be no potential for cumulative effects to 

sediment delivery?

DEIS page 145 discussed WEPP model results indicating the amount of sediment 

that could be produced from grubbing (which would be the most ground disturbing of 

the activities proposed). The amount of sediment that could be produced is low and 

inconsequential considering ongoing sediment inputs from natural processes, roads, 

and other Forest activities. The alternatives have been modified in the FEIS to cap 

the amount of manual grubbing that may occur within 100 feet of a stream to less 

than 50 acres per year.

12

Page 166: [For Upper Middle Fork John Day River, because 

there would be more treatment concentrated in a localized area, 

and sediment/turbidity could be of greater magnitude than other 

areas (low-moderate)] why is there no attempt made in this 

DEIS to quantify sediment impacts to these streams and 

analyze the impacts of this to fish?

DEIS page 145 concluded, “There is the potential for increase in sediment delivered 

to streams because of manual treatment within the [stream] buffers. However, this 

level of activity is well below current delivery rates and likely not at measurable levels 

in streams which contain known aquatic resources.” This conclusion was based on 

WEPP modeling and a manual grubbing scenario. WEPP modeling estimated that 

grubbing could generate about 2 pounds of sediment per acre. This is a very low 

amount compared to existing sediment delivery from natural processes and human 

activities. A 50-acre cap on the amount of grubbing that would be approved within 

100 feet of streams has been added to all alternatives. This would prevent potential 

adverse effects from sediment generated from this project. 

12

pdf H7 sounds incredibly inadequate to protect lake and pond 

quality and ecosystems. We are concerned by uncertainty re: 

herbicide risks to reptiles and amphibians. Pdf H8 is inadequate 

to protect wetlands. We are strongly opposed to any herbicide 

use in wetlands and lake, pond, river, and stream buffers. There 

is no guarantee that leaving some untreated areas will protect 

organisms

The need to protect reptiles and amphibians from treatment was recognized and a 

number of project design features are in place to reduce risks. As described on page 

228 of the DEIS, project design features F2, H1, H2, H5, H9, and H10 reduce the 

likelihood that for herbicides to be delivered to waterways in concentrations of 

concern. Herbicide restrictions on certain soil types (H3 and H6) reduce potential for 

runoff and leaching, and restrictions on extent of treatment on a given site (H4, H5, 

H7 and H8) ensure that herbicides would not be delivered in amounts greater than 

the SERA risk assessment and that unsprayed areas will be retained to provide 

refugia. Collectively these pdfs in combination with use of low risk first-year, firstchoice herbicides reduce the likelihood that adverse effects from herbicide exposure 

would occur to reptiles or amphibians. The GLEAMS model was run on four sites 

within the project area that had the greatest potential for herbicide delivery to water 

near fish habitat. Results indicate that herbicide concentrations in the water would be 

very low and less than levels of concern for fish, amphibians and aquatic 

invertebrates (chapter 3.5.3). 

12

There is ongoing heavy extensive logging on the Malheur, 

creating even more areas of disturbed soils (there are a lot 

already), so runoff is a big concern. Therefore there should be 

at least 100 foot buffers protecting streams and other surface 

waters from herbicides as in alternative C.

The GLEAMS modeling displayed on pages 140 and 144 of the DEIS considered 

site-specific conditions, including disturbed soils. This modeling was redone to 

increase the number of weather years included to better characterize the effects of a 

large storm after treatment, and to better characterize the differences between 

alternatives. The results of the modeling indicate that 100 foot buffers would reduce 

the potential for herbicide to reach the stream. Alternative C may require more 

extensive manual treatment in already disturbed areas, however a limitation on non488
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ID # Comment Forest Service Response

herbicide treatments within 100 feet of streams would minimize the potential for 

sediment delivery. Project design feature H5 limits runoff in all alternatives by 

applying herbicide during the dry season with the lowest soil moisture conditions, 

where greater than 50 percent groundcover exists (greater than 70 percent 

groundcover on steep slope sites), and/or at reduced rates. This pdf is intended to 

reduce potential offsite runoff transport of herbicides. Additional project design 

features, herbicide use buffers in all alternatives, and project caps would reduce the 

potential for herbicide to reach streams. 

12

How were the buffers determined for wells? Was surface runoff, erosion, leaching, and heavy rain on snow events taken into 

consideration?

There is currently no state restriction in effect for the use of herbicides within a 

specified distance of public water wells. The distance of 200 feet is precautionary 

considering the potential for herbicides to enter ground water. 

12 Avoid planning any control measures that could introduce 

herbicides into surface water tables.

The analysis in the DEIS discussed the potential for herbicide to enter water. The 

project design features and herbicide-use buffers were developed to minimize 

herbicide concentrations in surface waters. Site-specific model runs and past 

monitoring studies indicate that alternative C would keep herbicide from reaching 

surface waters. Table 39 has been updated in the FEIS to remove picloram from the 

list of herbicides since it would be prohibited in this alternative. 

12

RE: DEIS page 76: What studies demonstrate that herbicide 

use similar to the type proposed in this project will not result in 

harmful concentrations of herbicides in water?

This statement on page 76 referred to the National Water Quality Assessment 

Program and Clackamas River studies discussed further in this section of the DEIS. 

Additional information on water quality monitoring was discussed on page 143 (Berg 

2004 and Bakke 2001). The risk assessments also refer to multiple studies to 

determine the level of herbicide in water that could cause harm to people and the 

environment, and the potential amount estimated to be delivered to streams. 

12

[Re: statement on page 144 that pdfs largely preclude 

cumulative effects from multiple treatments at a single site]: 

Define “largely” in quantitative terms and with regard to aquatic 

impact consequences.

“Largely precluded” means that the likelihood of cumulative effects is very low and 

not measurable. 

12

[Re: statement on page 144 that adverse effects would be 

minimal]: Define “minimal” in quantitative terms, what are the 

effects to water quality and aquatic life of such minimal adverse 

effects?

“Minimal” means that likelihood of impacts is very low and has been mitigated to the 

extent practical via pdfs and herbicide-use buffers. In alternatives that allow some 

herbicide use within 100 feet of streams, no more than 10 acres within 100 feet of 

any water body in a 6th field watershed would be treated with herbicide in a single 

year. 

12

The cumulative effects brief discussion does not consider the 

contribution of logging, livestock, and road building to 

increasing invasive plant sites over time.

This was discussed in the introduction to cumulative effects on (DEIS Chapter 3.1.5). 

The project caps, pdfs, and herbicide-use buffers ensure that no additional impacts to 

water quality would be expected even if invasive plants spread over time. Prevention 

measures would slow the spread of invasive plants associated with forest activities. 

12

303d listed streams for temperature and those suspected of 

having water temperatures above standards should not be put 

at risk of losing existing shade.

Invasive plants rarely reach a height that would provide shade to streams and taller 

native vegetation that provides shade would not be treated. In addition, the amount of 

riparian area that would be treated is a fraction of total riparian vegetation. Thus, 

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existing shade is not likely to be adversely affected and the project would not 

contribute to increasing water temperatures. The project would have a beneficial 

impact to the extent that invasive plants are competing with shade-producing 

vegetation. 

12

How is it determined that [water quality would be maintained]? 

Alternatives B and D would definitely introduce toxic chemicals 

into surface waters through application of herbicides to the 

waters’ edge, surface run-off transporting herbicides within 100 

feet of surface water to the water, and broadcast spray and drift 

in riparian areas. This would violate standards. Just saying [it 

would comply with standards] does not make it true or 

substantiate these claims.

This comment was made to the introductory paragraph of the water quality section of 

the DEIS. The chapter discussed the potential for herbicide and sediment delivery in 

supporting the conclusion that beneficial uses of water would be maintained. 

12

Would 303d listed streams have broadcast spraying within 100 

feet of the stream or up to the water’s edge with alternatives B 

and D? Is there herbicide spraying with 100 feet of any category 

5A streams proposed? Is there herbicide use proposed within 

100 feet of any streams or rivers [that have insufficient 

information for the 303d list]? If so, this would be another legal 

violation, as this would...result in...toxic chemicals entering the 

stream and degrading water quality. 

None of the predicted peak concentrations in water would exceed drinking water 

standards as defined by the State of Oregon (State of Oregon 2004) (DEIS page 

142). Peak water concentrations predicted are far below the levels of concern for fish 

by several orders of magnitude. Riparian application [of herbicides] is not of the 

extent to affect riparian vegetation that shades water and maintains water 

temperatures (ibid). None of the streams on the Malheur National Forest have been 

303d listed for chemical contamination. 

12 Don’t use herbicides in municipal watersheds.

Approximately 0.1 infested acres are mapped in the Long Creek Municipal 

Watershed Management Area. As noted on page 9, “The low level of current 

infestation likely will not require any use of herbicides.” All drinking water sources 

would be appropriately buffered from herbicide use. 

12

We are strongly opposed to the use of herbicides within 100 

feet of streams and other water bodies. In some cases 150-300 

feet from waterways and water bodies may be needed. Use 

PACFISH/INFISH Buffers.

As noted on DEIS page 42, “herbicide-use buffers ...were developed based on label 

advisories, SERA risk assessments, and various studies of drift and runoff to streams 

such as Berg 2004.” Alternative C would prohibit herbicide use within 100 feet of 

streams. No more than 10 acres within 100 feet of any water body in a 6th field 

watershed would be treated with herbicide in a single year in alternatives B and D. 

No evidence exists that larger buffers are necessary to keep herbicide out of water 

bodies. PACFISH/INFISH buffers are larger than necessary to keep herbicide out of 

water bodies. 

12

We are concerned also by proposed herbicide use for dry 

stream channels since subsequent precipitation events or soil 

movement (e.g. landslides or bank trampling) could move 

herbicide contamination into contact with surface water and 

vulnerable aquatic plants, insects, amphibians, and fish. 

Applying herbicide to run-off ditches should also be avoided

due to surface run-off hydrological connections to streams or 

saturated wetlands.

Herbicide-use buffers are included for dry streams to limit use/application method for 

herbicides with moderate-high risk to fisheries. (DEIS table 11). These apply to 

roadsides approaching stream crossings. In addition the herbicide use buffer table 

(see alternative B description) was updated to include buffers on hydrologically 

connected ditches when surface water is present in the ditch. 

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12

[The result of the Berg review of BMPs] provides good reason 

not to broadcast spray in riparian areas, as with alternative C, 

and not allow herbicide spraying in road ditches hydrologically 

connected to streams.

The herbicide-use buffers in alternatives B and D limit most broadcast spraying within 

100 feet of streams. Aquatic labeled herbicides and herbicides that pose lower risk to 

fish may be broadcast as close as 50 feet from streams. Aminopyralid poses very low 

risk to aquatic resources, thus broadcast spraying is allowed to the water’s edge. 

Treatments along roadsides would comply with these buffers. The alternatives have 

been modified to add hydrologically connected ditches to the list of places where 

herbicide-use buffers would apply when surface water is present in the ditch (see

herbicide use buffers for alternative B). 

12

How will the Forest Service act to prevent herbicides being 

transported by road runoff and hydrological connected ditches 

into streams? Why is this not addressed in the DEIS and given 

site-specific consideration?

DEIS page 137 noted, “Roadside treatments pose the greatest risk to water 

contamination from herbicide spraying because roadsides are more compacted and 

promote more runoff and roadside ditches may have direct connection to a stream 

channel. In these circumstances ditches may effectively circumvent streamside 

buffers.” Page 139 noted, “road segments that cross streams or penetrate into 

stream buffers provide routes for contaminants to reach streams, whether from rutted 

running surface, roadside ditches or runoff projected onto natural slopes an 

inadequate distance from the channel for proper buffering... Results from modeling 

are shown in table 38 and include a treatment along roads. These results agree well 

with monitoring results from applications on roads in Oregon’s Willamette Valley by 

the Oregon Department of Transportation (Berg 2004).” Page 160 noted, “The most 

likely routes for herbicide delivery to water are potential runoff from a large rain storm 

soon after application, especially from treated roadside ditches. The FEIS clarifies 

that herbicide-use buffers apply to hydrologically connected ditches that carry surface 

water at the time of spraying (see herbicide use buffers for alternative B). 

12

Does modeling that indicates the amount of herbicides that 

could reach streams is below a level of concern [relative to 

fisheries impact in issue comparison table] account for 

herbicides traveling through soils, and surface runoff or along 

hydrologically- connected roads?

Yes, the site-specific modeling and risk assessment findings consider soil conditions, 

leaching and run off. Hydrologically connected roadside ditches would be buffered to 

mitigate potential herbicide delivery to streams.

12

Herbicide should not be used in road ditches or on road 

segments that cross streams or penetrate into stream buffers. 

This does not seem to be included in pdfs and should be.

DEIS page 137 noted, “Roadside treatments pose the greatest risk to water 

contamination from herbicide spraying because roadsides are more compacted and 

promote more runoff and roadside ditches may have direct connection to a stream 

channel. In these circumstances ditches may effectively circumvent streamside 

buffers.” Page 139 noted, “road segments that cross streams or penetrate into 

stream buffers provide routes for contaminants to reach streams, whether from rutted 

running surface, roadside ditches or runoff projected onto natural slopes an 

inadequate distance from the channel for proper buffering... Results from modeling 

are shown in table 38 and include a treatment along roads. These results agree well 

with monitoring results from applications on roads in Oregon’s Willamette Valley by 

the Oregon Department of Transportation (Berg 2004).” Page 160 noted, “The most 

likely routes for herbicide delivery to water are potential runoff from a large rain storm 

soon after application, especially from treated roadside ditches The FEIS clarifies that 

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herbicide-use buffers apply to hydrologically connected ditches that carry surface 

water at the time of spraying. 

12

There is a trend in this DEIS of identifying vectors and 

vulnerable times when herbicides are more likely to be 

transported then not follow through in analysis with prevention 

measure ideas and pdfs...We support pdfs [that safeguard 

against spraying under conditions of active infiltration or 

obvious saturated conditions]. But what about very persistent 

herbicides applied prior to snow remaining to be transported 

through snowmelt runoff, e.g. picloram, imazapyr?

The herbicide-use buffers, along with pdfs, manage the persistence, mobility and 

toxicity of herbicide ingredients. The analysis in DEIS Chapter 3 indicated that levels 

of herbicide that may reach streams would be below a threshold of concern for fish 

and drinking water. 

06 / 10

We are strongly opposed to the use of herbicides within 100 

feet (or within 300 feet for major creeks and rivers) of streams 

and areas with high water tables such as bogs, springs, fens, 

wet meadows, and marshes, and in roadside ditches that funnel 

water to these areas.

Alternative C would virtually eliminate the potential for herbicides to reach streams 

and other water bodies. There is no evidence that a large buffer would be needed to 

protect water quality or aquatic organisms. The FEIS included GLEAMS modeling

showing a treatment scenario of 10 acres with maximum application rates for all 

herbicides and compared this to a scenario where the same treatment occurred with 

a 100 foot buffer. This shows that the 100 foot buffer effectively reduces the potential 

for herbicides to enter a stream. The results of even the unbuffered scenario showed 

that impacts on the aquatic environment would be limited to possible effects on 

aquatic plants from use of sulfonylurea herbicides. However, this modeled example 

did not consider the herbicide use buffers, nor did it consider broadcast and other 

rate restrictions associated with the alternatives. In addition, the modeled example 

includes 10 contiguous riparian acres treated with herbicide and currently none of the 

streamside infestations are that large. The alternatives have also been modified to 

include herbicide-use buffers for hydrologically connected roadside ditches when 

surface water is present.

12

We are opposed to creating sediment/turbidity impacts that 

would be likely to adversely affect federally listed fish and their 

designated critical habitat. How is it assumed that these 

impacts would not cause a trend toward federal listing or a loss 

of viability for MIS and aquatic sensitive species?

The triggers for findings under the Endangered Species Act are very conservative. 

The amount of sediment that would be produced is expected to be very low. 

However, we are engaging in formal consultation with the regulatory agencies 

because sediment effects cannot be completely discounted. Compared to natural 

background levels, sediment produced from invasive plant treatments would not be 

measurable and recovery would be rapid. Herbicide treatments in combination with 

manual treatments would reduce the sediment production compared to manual 

treatments alone. The greatest amount of sediment would come from digging up 

invasive plants near streams. DEIS page 145 quantified the amount of sediment that 

could be produced from the most ground disturbing activity proposed in the project 

(grubbing). The action alternatives have been modified to include a limitation on nonherbicide treatments within 6th field watersheds (with the exception of biological 

controls). The FEIS has been modified to include a treatment cap all non-herbicide 

treatment methods except biological agents. The FEIS states that no more than 50 

acres within 100 feet of any water body in a 6th field watershed would be treated in a 

single year. 

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12 Pdfs should mitigate potential for sediment impacts under 

EDRR.

Passive and active restoration is included in all alternatives to ensure that desirable 

vegetation reoccupies treated sites (pages 44-45 in the DEIS). The action 

alternatives have been modified to include a limitation on non-herbicide treatments 

within 6th field watersheds (with the exception of biological controls). The FEIS states 

that no more than 50 acres within 100 feet of any water body in a 6th field watershed 

would be treated in a single year. 

12

[Increased sediment due to reliance on non-herbicide methods 

near streams in alternative C] could be mitigated so that little or 

no sediment enters water.

Herbicide treatments in combination with manual treatments would reduce the 

sediment production compared to manual treatments alone. The action alternatives 

have been modified to include a limitation on non-herbicide treatments within 6th field 

watersheds (with the exception of biological controls. The FEIS has been modified to 

include a treatment cap on all non-herbicide treatment methods except biological 

agents. The FEIS states that no more than 50 acres within 100 feet of any water 

body in a 6th field watershed would be treated in a single year. This applies to all 

action alternatives. 

12

[In table 47], “low quantity” of project-related sediment needs to 

be quantified and analyzed re: potential impacts to fish and 

other aquatic life.

DEIS page 145 quantified the amount of sediment that could be produced from the 

most ground disturbing activity proposed in the project (grubbing). The action 

alternatives have been modified to include a limitation on non-herbicide treatments 

within 6th field watersheds (with the exception of biological controls). No more than 50 

acres within 100 feet of any water body in a 6th field watershed would be treated in a 

single year. In alternatives B and D no more than 10 of these acres would consist of 

herbicide use. Project acreage caps would therefore limit maximum annual sediment 

production to approximately 80 to 100 pounds per year within any 6th field watershed. 

However, this limitation is based on an area that currently has a comparatively high 

concentration of invasive plants near streams. The amount of sediment that would 

likely be generated in any 6th field watershed in any given year is likely much lower 

than this maximum and would not be detectable compared to background levels. 

12 Herbicide impacts to soils should be an issue.

Page 14 of the DEIS discussed why impacts to soils were not considered a 

significant issue. “Impacts to soils have been resolved through adherence to the R6 

2005 Record of Decision standards and additional project design features. None of 

the alternatives pose significant threats to soils given the nature of the types of 

treatments proposed. The approach to soils in this document is to analyze how 

herbicides are filtered through various soil types and their eventual environmental 

fate, with the main issue ultimately being potential effects on fish [which is a 

significant issue]. Impacts on soils are discussed in Chapter 3.4 and otherwise 

addressed throughout the DEIS. 

12

We are very concerned about herbicide persistence in soils of: 

aminopyralid, imazapyr, picloram, chlorsulfuron, imazapic, 

glyphosate and sulfometuron methyl. Use of imazapyr and 

picloram should be stopped. We are very concerned about 

herbicide persistence in water of: aminopyralid, chlorsulfuron, 

The pdfs and herbicide-use buffers in the action alternatives minimize adverse 

impacts of herbicide use. Toxicity, mobility and persistence were all considered in the 

analysis and development of the project design. Formulations of glyphosate 

containing POEA surfactants would not be used. 

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clopyralid, sethoxydim and glyphosate. The use of 

chlorsulfuron, the round up version of glyphosate, clopyralid 

and sethoxydim should be discontinued for many reasons, 

including persistence in water. The same herbicides keep 

coming up as posing the most problems through toxicity and 

persistence. These herbicides should not be used: triclopyr, 

imazapyr and picloram, and to a lesser extent, glyphosate, 

which has conflating factors.

12

In reference to impacts on soils having been resolved by 

adherence to standards/pdfs: This is all very optimistic but 

seems unlikely...impacts to soils also includes native plants 

taking up herbicides through their root system, killing or 

contaminating the plants, with secondary indirect impacts to 

insects, amphibians, and other wildlife species and humans.

Direct impact on soil productivity is not a significant issue and effects on soil 

productivity do not vary between alternatives. Effects on non-target plants from 

uptake through the soil are considered, as is the potential for herbicides to move 

offsite through the soils. Impacts to soils may result in impacts to other resources 

such as native plants, which is discussed in the botany section of the DEIS (Chapter 

3.3). 

12

This [the conditions covered by pdf H3, including bare, compact 

soils, and poor productivity soils that are highly disturbed] 

covers most soil conditions on the Malheur, so don’t use 

picloram or metsulfuron methyl. Persistence is another good 

reason not to use these herbicides.

The R6 2005 Record of Decision standards require that the use of these herbicides 

be done in a manner that minimizes adverse effects. This is why pdfs are associated 

with the project that go beyond the label. Soil conditions would be considered in the 

implementation planning process. We do not agree that these conditions would 

preclude all use of these herbicides according to this pdf. Picloram would not be used 

in alternative C. 

12

There are a lot of clay soils on the Malheur, drop proposed use 

of picloram, imazapyr, and sulfonylurea herbicides because 

runoff on clay soils could damage non-target plants downslope. 

The pdfs were developed to reduce the potential for adverse effects from off-site 

movement of herbicides in clay soils. 

12

Residual soil activity is a reason to limit use of certain 

herbicides, including aminopyralid and not use picloram, 

imazapyr, and imazapic. It is not clear that pdfs would eliminate 

the potential for herbicide persistence in the soils to have longterm effects on native plant communities.

Herbicide persistence in the soils was addressed in the DEIS and the pdfs would limit 

herbicide build up that could have long-term effects on native plant communities. 

Over the long term, herbicide treatment would help reduce invasive plants that 

threaten native plant communities.

12 Drop the use of picloram because risk assessments found 

typical rates could inhibit soil microbial activity.

Picloram is not a first-choice herbicide in the preferred alternative B. It would only be 

used if first-year, first-choice herbicides were found to be ineffective. Picloram is 

effective on knapweeds, yellow star thistle and leafy spurge and would be used for 

these species if aminopyralid was not available (as in alternative D) or if it was found 

to be ineffective. If alternative D were selected, picloram would be the first-year, firstchoice for about 63 acres. The amount of land that would be affected is small and the 

impact on soils would not lead to long-term adverse effects., Picloram would not be 

used at all in alternative C, which would reduce the potential effectiveness of this 

alternative. Several pdfs (H group) are proposed to reduce the potential impact of 

picloram on soil organisms. 

12 There could be triclopyr induced changes to fungal growth at 

predicted soil concentrations for the Malheur (0.5 ppm 

DEIS pages 126-127 discussed the potential for triclopyr to affect fungal strains in a 

lab setting. However, this was not found in the field. Based on best available scientific 

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predicted) only 0.1 ppm needed or changes in some fungal 

strains.

information, spot spraying of triclopyr at typical rates “has very low potential for 

slowing fungal growth.”

12

The conclusion that there is little potential for this project to 

adversely affect soils or contribute to meaningful cumulative 

effects is not well substantiated as long as picloram, triclopyr, 

chlorsulfuron, metsulfuron methyl, sulfometuron methyl, and 

imazapyr are proposed for use-especially with repeat 

applications!

The soils analysis considered the impacts of each of the herbicides proposed for use. 

The more effective the initial treatment, the less herbicide would need to be used for 

repeat applications (DEIS Chapter 3.1.4). All of these herbicides are effective on 

target species found on the Malheur National Forest. 

12

The conclusions on page 129 do not acknowledge long halflives of picloram and aminopyralid and repeated applications 

and long persistence in poor soils...picloram has a half-life up 

to 3 years, not just 90 days.

The FEIS has been edited for consistency. Half-lives of individual herbicides vary 

widely depending on soil and weather conditions. 

12

Re: metsulfuron methyl: how long does the impact have to last 

to seriously degrade or destroy soil fertility and native plant 

growth? A 100 day half-life could be long enough to do this.

As discussed in the DEIS on page 127, “For metsulfuron methyl, findings from one 

study showed slight growth reduction of common soil bacterium above 5 ppm soil 

concentrations (SERA 2004c). Modeled metsulfuron soil concentrations are 0.06 

ppm.” Page 129 noted, “the project limits use of metsulfuron methyl to once a year to 

minimize soil buildup (pdf H4). Since soil conditions determine the buildup potential –

a lack of soil microbes equates to lack of decomposition – the use of metsulfuron 

methyl ... would be avoided on sites with poor soil conditions (pdf H3) where 

restoration to native vegetation is desired.” Thus, the use of metsulfuron methyl 

would not degrade or destroy soil fertility or native plant growth. 

12

The soils cumulative effects analysis is inadequate. Why 

wouldn’t activities under this project be likely to add to the 

impacts of other activities creating bare soils, such as logging 

and grazing.

The amount of soil disturbance from removal of invasive plants by all methods is 

likely to be small and would not measurably add to other activities that disturb soils 

(see Soils Cumulative Effects). The invasive plant treatments on areas of the 

productive land base would comply with LRMP minimum groundcover requirements 

to avoid erosion (USDA 1990, p. IV-40). Adequate groundcover not only stabilizes 

the site but promotes the microbial activity that decomposes residual herbicide 

residue.

12 The statement that soil organisms would not be harmed is not 

consistent with previous analysis.

Page 126 of the DEIS explained that most of the 10 herbicides approved in the R6 

2005 Record of Decision were not found to pose deleterious effects to soils. Picloram 

and sulfometuron methyl had potential to affect soil microbes in laboratory tests but 

not in field studies. These risks were reduced in the project by limiting frequency and 

rate of application of these herbicides. The project proposes use of sulfometuron 

methyl at rates half that analyzed in the SERA risk assessment. Picloram use in 

alternatives B and D has specific design criteria to avoid use on inherently poor soils 

and limit repeat application (pdfs H3 and H4). 

12

Changes to plant cover by roads should be considered adverse 

effects as bare ground will encourage invasive plants to reestablish.

Passive and active restoration would occur on roadsides to help establish desirable 

vegetation and discourage re-establishment of invasive plants (see DEIS Chapter 2). 

Roadsides are managed as administrative areas and not for productive purposes. 

Road management stabilizes road bases using plant cover during reconstruction or 

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construction (Road 3, USDA 2012). The plant cover provides some level of 

resistance to weed invasion. Road management limits the disturbance that can 

further open up bare surfaces for weeds to establish by blading and cleaning ditches 

only when necessary to insure adequate drainage for storm flow (Road 4, USDA 

2012). However, roadsides may always be prone to weed invasion due to the 

unnatural gravel surface that favors colonization by opportunistic plant species.

12 The paragraphs under figure 8 seem contradictory. This section of the EIS has been edited for clarity. 

12

Dust as a means of offsite transport is another reason not to 

use sulfonylurea herbicides (chlorsulfuron, sulfometuron methyl 

and metsulfuron methyl). This is of concern because the 

invasive plant sites are along roads and susceptible to offsite 

transport by dust. The pdf that these herbicides be applied 

during moist conditions will lead to offsite transport by water. 

Off-site transport by water would not necessarily occur during “moist” conditions. A 

pdf (H11) limits herbicide use when rainfall is predicted. Herbicide-use buffers apply 

to hydrologically connected roadside ditches when water is present. 

12

Effects on soil microbes provide more reasons not to use 

picloram or sulfometuron methyl. A lot of the Malheur has poor 

soils.

As explained in the DEIS, these risks were reduced by limiting frequency and rate of 

application. The project proposes use of sulfometuron methyl at rates half that 

analyzed in the SERA risk assessment. Picloram use in alternatives B and D has 

specific design criteria to avoid use on inherently poor soils and limit repeat 

application (pdf H3 and H4).

12 Drop use of imazapyr also. Soil fertility is important and 

imazapyr poses other concerns also.

Imazapyr would not pose risks to soil fertility. Page 126 noted that soil impacts would 

be short-term and associated with high use rates, which are not proposed in this 

project. Project design feature F2 limits the rate of imazapyr to 0.7 pounds per acre. 

Imazapyr is not a first-year, first-choice herbicide in any alternative.

Fish and Aquatic Organisms

12

This is disturbing that there is no info on toxicity to aquatic 

organisms for imazapic. Therefore it should not be used near 

streams, lakes, ponds, and rivers.

Information about impact to aquatic organisms is available and included in the FEIS. 

Based upon risk assessment information and R6 2005 FEIS, imazapic poses low risk 

to the aquatic environment (table 18). Herbicide-use buffers in alternatives B and D 

would not allow broadcast spraying with imazapic to within 100 feet of wet streams or 

50 feet of dry streams. The buffers would not allow spot or selective use of imazapic 

within 15 feet of wet or dry streams. 

12 Why are the project BA and Biological Evaluation for listed and 

sensitive aquatic species not included in the DEIS?

The BA is based on the preferred alternative, which had not been designated prior to 

receiving public comment. The Biological Evaluation was summarized in the DEIS. 

12

There is no guarantee that adverse herbicide impacts to 

biodiverse aquatic environments would not outweigh benefits.

An accidental spill near a creek or the extirpation of a rare plant 

or amphibian would be disastrous.

The DEIS discussed the risks and benefits of invasive plant treatments. The nature of 

the project, pdfs, and herbicide-use buffers minimize the potential for adverse effects, 

which is why we believe herbicide impacts would not outweigh benefits. Accidental 

spills of a type that would extirpate an amphibian or rare plant have not occurred for 

any Forest Service invasive plant project. A damaging spill would be prevented by 

the herbicide transportation and handling plan and other pdfs. 

12 There is no analysis really supporting the conclusion that The finding that herbicide impacts would be short-term is based on the type and 

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herbicide adverse impacts would only be short term for aquatic 

environments, as herbicides can kill invertebrates (fish prey), 

pollinators, native and rare plants, and amphibians.

extent of herbicide use and the pdfs and herbicide-use buffers associated with the 

project. While herbicides can affect elements of the aquatic environment, this 

depends on how much herbicide exposure occurs. Toxicity tables showing adverse 

effects levels for invertebrates, algae and aquatic plants are added to the FEIS. The 

amount of herbicide exposure has been minimized to the point where impacts are 

expected to be minor, with rapid recovery. The magnitude of any potential impacts is 

expected to be very low given the project design, caps, and buffers. Lethal effects on 

aquatic organisms are not expected, and potential sub-lethal effects are expected to 

be infrequent or non-existent.

12

We are particularly concerned by low dose levels causing acute 

effects and fish death for use of picloram, glyphosate, 

sethoxydim and triclopyr (see table 43).

The amount of herbicide that would reach streams (based on risk assessment and 

site-specific modeling) does not indicate that the concentrations in streams would kill 

any fish. The herbicide-use buffers restrict application methods near streams for 

these herbicides (except aquatic glyphosate, which is less toxic to fish than the 

terrestrial formulations). The pdfs provide additional layers of caution to minimize risk 

of herbicides reaching streams in concentrations beyond the threshold of concern for 

fish. 

12

Isn’t it dangerous to assume that toxicity testing for fish would 

be adequately protective for little or no testing on amphibians or 

invertebrates?

Data gaps were discussed in the DEIS and the R6 2005 FEIS. The R6 2005 FEIS 

noted, “Toxicity data and exposure scenarios for fish provide a reasonable surrogate 

for effects on amphibians because several studies have found that amphibians are 

less sensitive, or about as sensitive, as fish to some herbicides (Berrill et al. 1994; 

Berrill et al. 1997; Perkins et al. 2000).” Comparison of toxicity values for fish and 

amphibians for the herbicides analyzed indicate similar sensitivities (see Forest 

Service/SERA risk assessments). The R6 2005 FEIS also noted, “Limitations 

notwithstanding, a substantial amount of scientific data on the toxicity of these 

herbicides to birds and mammals, and some amphibians and invertebrates exist. The 

data are generated by manufacturers to meet EPA regulations before an herbicide 

may be registered for use, and by independent researchers that have published 

findings in peer-reviewed literature. This data is then analyzed according to standard 

risk assessment methodology to reach a characterization of risk for each herbicide.” 

Site-specific modeling was conducted on four sites within the project area that had 

the greatest potential for herbicide delivery to water near fish habitat. Results indicate 

that herbicide concentrations in the water are at least 3 orders of magnitude less than 

levels of concern for fish, amphibians and aquatic invertebrates (page 157 and table 

38, chapter 3.5.3).

12 Our primary concerns to fish from herbicide use include runoff 

after a storm, and accidental spills as discussed on page 160.

Effects to fish and the aquatic environment were addressed in the DEIS. The risk 

assessment and site-specific GLEAMS model results estimate effects from run off. 

The effect of an accidental spill would be minimized by pdfs that do not allow large 

amounts of herbicide to be transported and for herbicide mixing to be done away 

from streams (pdf Group G). The herbicide-use buffers, pdfs and project caps 

together minimize the potential for adverse impacts to the aquatic environment or 

fish. 

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12

We are concerned by implicit potential for water bodies to have 

detectable effects from herbicide use [as shown in table 45]. 

We are concerned by proposed use of herbicides near these 

creeks and rivers, especially as most of them have multiple 

federally and state listed fish. Sublethal effects, decimation of 

fish prey, synergistic effects with other stressors, and 

decimating accidental chemical spills are still possible with 

proposed herbicide use-especially with proposed repeated 

herbicide use on the same ground. We are also concerned by 

adding any potential toxicity impacts to already greatly 

diminished remaining fish runs. Any project impacts could have 

cumulative effects with [several other stressors on fish], why is 

this not discussed?

DEIS page 169-170 addressed cumulative effects on fish. The DEIS noted that 

several other stressors on fish exist, including hydropower development, habitat 

degradation from human activities, direct harvest of fish, and competition from 

hatchery fish (USDA Forest Service 2008b). These are part of the existing condition 

for aquatic organisms and this project will not worsen these conditions. At any given 

site, direct or indirect adverse effects to aquatic organisms under all alternatives 

would be low magnitude, localized, and short-term. These short-term, low-magnitude 

effects are not of a type or extent that would combine with ongoing human activities 

or foreseeable projects on the Malheur National Forest and produce long-term, 

cumulative impacts, even considering the vectors of invasive plant spread described 

in chapter 3.1.5 The threshold of concern for wildlife and fish is set particularly low (a 

no effect or no adverse effect level, or a fraction of the lethal dose). This accounts for 

uncertainties about how herbicides affect wildlife and fish given cumulative stressors.

The amount of herbicide that might reach streams over the life of the project is very 

low. There is no evidence that this project would contribute to chronic effects to fish 

from herbicide use. 

12

We are concerned by the potential cumulative contamination of 

waters with toxic chemicals through repeated herbicide use and 

by synergistic or combined chronic effects to fish already 

stressed by high water temperatures, and high sediment 

loadings and lack of adequate prey species and refugia from 

effects of grazing, logging, roading, mining, other human 

impacts to local rivers, streams, and creeks. Also takes by 

dams and fishing.

12

More reasons for our concerns re: less predictable herbicide 

loss of native plants near streams (especially as herbicide can 

travel through water and soils) and sedimentation effects [as 

described on pages 164-166]. What steps would be taken to 

reduce sediment contribution to these areas?

The integrated treatments proposed are not likely to lead to substantial losses of nontarget vegetation. On projects across the region, minimal losses of non-target 

vegetation have been reported (Desser 2014). Sediment would be low for all 

treatment methods. Integrated treatment methods that include herbicides are less 

likely to disturb ground than manual or mechanical treatments alone. The action 

alternatives have been modified to include a limitation on non-herbicide treatments 

within 6th field watersheds (with the exception of biological controls). No more than 

50 acres within 100 feet of any water body in a 6th field watershed would be treated 

in a single year, and in alternatives B and D of these, no more than 10 acres would 

consist of herbicide use.

12

We want access [to more site-specific information that will be 

developed at the 6th field watershed scale] through the ongoing 

ESA Section 7 consultation process.

The Biological Assessment will be part of the public record and available on request 

before the FEIS is published. The Biological Opinion from the National Marine 

Fisheries Service and Fish and Wildlife Service will be available before the Record of 

Decision is published. 

12 Do peak concentrations in water exceed the toxicity thresholds 

for fish, aquatic invertebrates or amphibians?

Toxicity indices for aquatic invertebrates, macrophytes, and aquatic plants have been 

added to the FEIS with discussion about how herbicides may influence these 

components of the aquatic environment. Fish are used as a surrogate for amphibians 

as discussed in the DEIS on page 200: “Data suggest that amphibians may be as 

sensitive to herbicides as fish (Berrill et al. 1994; Berrill et al. 1997; Perkins et al. 

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2000).” Model results indicate that toxicity thresholds would not be exceeded (or 

closely approached) for fishes, amphibians, and aquatic macroinvertebrates.

12 Aquatic species of concern need macro-invertebrate prey that 

could be killed by herbicide use near surface waters.

The analysis in the DEIS considered the impacts of treatments on the aquatic 

environment. Effects on aquatic macro-invertebrates were considered in the analysis. 

The aquatic risk rankings in table 18 considered these effects. The pdfs and 

herbicide-use buffers minimize adverse impacts. Model results indicate that toxicity 

thresholds would not be exceeded (or closely approached) for fishes, amphibians, or 

aquatic macroinvertebrates.

12 Not acceptable for badly threatened fisheries to be further 

destroyed by toxic herbicide use.

Effects on fisheries were discussed in Chapter 3.5. There is no evidence that the 

herbicide use proposed would destroy fisheries. The analysis concluded that any 

impacts to fishes would be short-term and of low-magnitude (e.g., sub-lethal).

12

How would herbicide use within RHCAs and riparian zones 

meet PACFISH and INFISH RMO’s? Obviously herbicide use in 

riparian areas would remove native plant cover, likely reduce 

native plant diversity, and could remove native plants 

contributing shading or stream bank stability, as well as 

contaminate water used by fish or indirectly contaminate water 

or increase water temperature downstream.

DEIS page 158 noted that the PACFISH –INFISH habitat indicators are pool 

frequency, water temperature, amount of large woody debris, lower bank angle of the 

creek, and width to depth ratio. Treatment of invasive plants on the Malheur National 

Forest is not likely to measurably affect any of these indicators. These indicators 

were further discussed on pages 158-162. The project is intended to restore native 

plant communities; invasive plants are more likely to threaten native plant diversity 

than treatments. DEIS page 105 noted: “invasive plants have the ability to deplete 

available resources to lower levels than native vegetation can tolerate, they can 

quickly dominate disturbed sites and displace native vegetation. When invasive 

plants dominate native plant communities, native plant species diversity is 

decreased.” DEIS page 160 noted: the small percentage near-stream areas needing 

treatment would not be capable of changing solar radiation to a degree that would 

measurably affect stream temperature. Effects from chemical contamination are 

expected to be negligible in all project watersheds (ibid). 

Wildlife

04

Birds appear to be more sensitive to aminopyralid than 

mammals. The FS should take this into consideration. Birds 

might be more exposed to this chemical in a wildland/forest 

setting than in a farm setting.

The potential effect of herbicide exposure on birds was considered and is 

summarized on pages 203-207 of the DEIS. Table 58 displayed the herbicide toxicity 

indices used to determine the threshold of concern (amounts below this rate would

not be expected to result in adverse effects, including non-lethal effects) whereas 

table 60 displayed the herbicide exposure scenarios for wildlife considered in the risk 

assessments developed specifically for the Forest Service. The exposure scenarios 

included consumption of contaminated vegetation, insects, fish, and other prey. 

Based on the best available information, none of these scenarios would result in 

birds being exposed to aminopyralid at levels over the threshold of concern. The 

likelihood of exposure on forest habitats was also considered. Aminopyralid is one of 

the herbicides that would “not pose a risk” to birds or mammals. As shown in table 

61, one percent or less of wildlife habitats would be treated and infested sites are 

small and scattered. As a result, large areas of unaffected nesting and foraging 

habitat would be available, reducing the likelihood of herbicide exposure. Alternative 

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D would not include the use of aminopyralid. Page 211 notes that alternative D could 

increase treatment risks compared to alternative B, and it could be less effective in 

reducing invasive plants and promoting the long-term maintenance of wildlife habitat. 

Information presented in the DEIS utilizes the best information available (SERA 

2007) related to the toxicity of aminopyralid to birds and wildlife. As described, 

aminopyralid has a favorable human health toxicity profile when compared to the 

registered alternatives for these use sites and will be applied at a lower rate. Its 

residual action should alleviate the need for repeat applications, resulting in a 

reduction in the amount of herbicides applied to the environment for the control of 

these weeds. Aminopyralid has been determined to be practically non-toxic to nontarget animals at the registered application rates, compared to the alternatives, and is 

less likely to affect both terrestrial and aquatic plants. The EPA commented that 

aminopyralid would potentially reduce overall herbicide footprint on the Malheur 

National Forest. Finally, EPA cited the SERA 2007 risk assessment that 

“aminopyralid has been determined to be practically non-toxic to non-target animals 

at the registered application rates.”

06 / 10

The Forest Service needs to plan specific protection measures 

for species most vulnerable to herbicides, including pollinators, 

Neotropical songbirds, amphibians, fish, invertebrates, native 

ungulates (elk, deer, and pronghorn), scavengers, raptors, and 

small mammals.

The DEIS incorporated the R6 2005 FEIS and SERA risk assessments, using best 

available scientific information about potential effects of herbicides on wildlife. Project 

design features (DEIS table 9) provide specific protection measures for wildlife 

species of conservation concern and restrict herbicide use to reduce effects to 

terrestrial and aquatic species. The analysis in the DEIS does not indicate that 

additional protection measures are warranted.

12 Highly questionable that herbicides proposed for use pose no 

risk to terrestrial wildlife species.

Risk from herbicide exposure was determined using data and methods outlined in the 

SERA risk assessments, and exposure scenarios for wildlife were described on 

pages 203 to 207 of the DEIS. The findings in the DEIS considered a variety of 

exposure scenarios, and risks from herbicide exposure on wildlife varies. With 

implementation of the pdfs, use of herbicides in the action alternatives would not 

result in herbicides exposures over a threshold of concern. None of the first choice 

herbicides in alternatives B and C would pose any risk to wildlife. Pdfs limit the rate 

that moderate or higher risk herbicides may be used in all action alternatives. 

Herbicide use caps limit the extent of treatment.

12

PDFs J2a and b do not address impacts to bald eagles by 

herbicide contamination of prey species or indirect reduction of 

prey species from herbicide food chain impacts.

As described on page 220 of the DEIS, potential effects to bald eagle from prey 

contamination were evaluated. The results of exposure scenarios indicate that no 

herbicide or surfactant proposed for use poses a plausible risk to birds from eating 

contaminated fish. All expected doses to fish-eating birds are well below any known 

no-observable-adverse-effect-level (NOAEL). Consequently, at proposed application 

rates and methods, no adverse effects for herbicide exposure to the bald eagle are 

anticipated (DEIS p. 221).

12 Re: PDF J3a - Protection for only 2 weeks post-fledgling does 

not protect peregrine falcons from herbicide impacts to 

Pdfs restrict herbicide use near active nests and ensure that herbicides would be 

applied at rates that would not cause adverse effects to peregrine falcons. This 

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reproductive fledgling success from herbicide reduction of 

insects and birds and bioaccumulation of toxins in the parent 

falcons. Disturbance is not the only or main negative effect to 

raptors from herbicide use.

project design feature has been implemented on similar projects across the region 

and the commenter provides no evidence that proposed restrictions are not adequate 

to protect nesting birds from disturbance. As described on page 221 of the DEIS, 

potential effects to nesting birds and fledglings from herbicide application were 

evaluated using both a fish and small mammal scenario. Potential effects are 

reduced with implementation of project design features that restrict the use of 

herbicides and surfactants (J3e, F2) and Malheur LRMP standard restricting the 

broadcast application of triclopyr. Also as described, because the herbicides 

proposed for use are rapidly excreted from prey and do not bioaccumulate, no 

adverse effects from herbicide exposure to nesting birds or their young are 

anticipated.

12

Re: PDF J3b - Some herbicides are persistent in soils for over a 

year, leading to effects into the nesting season even from 

spraying that was done outside the nesting season.

12

Re: PDF J3e – Eliminate use of picloram and clopyralid due to 

threats to raptor reproduction and other reasons. 

There are no known peregrine falcon, goshawk or bald eagle nests near proposed 

treatment sites. Project design features would protect these and other raptor nests, 

should treatment be proposed near nest sites in the future. Thus, exposure to 

herbicides is unlikely and no adverse effects to raptor reproduction are anticipated. 

Pages 221-222 of the DEIS discussed the reasons why HCB in picloram and triclopyr 

are unlikely to affect peregrine falcons and there is no evidence that use of picloram 

and clopyralid, as proposed, would threaten raptor reproduction.

12

Don’t use herbicides in active Greater Sage Grouse habitat. 

Herbicides can kill plants and insects needed by sage grouse 

young. Sage grouse are endangered and have lost most of their 

suitable habitat and populations. 

Re: PDF J4e: Effects of herbicide use to plant species 

composition and insects used by sage grouse would persist 

past the reproductive season.

With implementation of project design features that restrict herbicide application and 

treatment in breeding/foraging habitat, no adverse effects from herbicide exposure 

are anticipated (DEIS p. 223-224). As discussed on DEIS page 223, no effects to 

breeding birds or reproduction are expected due to the marginal nature of breeding 

habitat on the Malheur National Forest and implementation of protective pdfs. Page 

224 noted, “While exposure from these herbicides/surfactants are possible, when you 

consider that; 1) NPE would not be used (pdf F1), 2) pdf F2 restricts broadcast 

application of clopyralid, glyphosate, picloram, sethoxydim and sulfometuron methyl 

to typical application rates, 3) The Malheur National Forest LRMP prevents broadcast 

application of triclopyr, 4) Only 79 acres of invasive plant treatment are proposed in 

suitable habitat and sites are small and scattered across 20 watersheds, and 5) the 

use of the project area by sage grouse is scattered and incidental, it is unlikely that 

birds would consume 100 percent of their diet from contaminated insects/vegetation 

for 90 days and receive a chronic dose of concern. As a result, there are no adverse 

effects from herbicide exposure anticipated under any alternative.”

12 There should be no herbicide impacts allowed to affect greater 

sage grouse. 

12

Sage grouse are also very vulnerable to herbicide use. Based 

on the effects analysis, we have concerns about herbicide 

impacts to sage grouse. Drop all use of triclopyr and NPE 

surfactants and maximum rates of glyphosate. Drop herbicide 

use in 79 acres of suitable sage grouse habitat!

12

Re: PDF J5a: Drop all use of glyphosate with POEA surfactant, 

sulfometuron methyl, and NPE surfactants and all use of

herbicides in or near wetlands, streams, lakes, ponds, etc.

Potential effects to amphibians and aquatic-dependent species from herbicide 

application were recognized and a number of pdfs and herbicide-use buffers near 

streams were proposed to minimize risks. Taken together, these restrictions and 

buffers minimize risks to aquatic-dependent species such as the Columbia frog. 

Herbicide use buffers for wet streams have been modified to include protection for 

hydrologically connected ditches. The action alternatives have been modified to 

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prohibit use of POEA and NPE-based surfactants (pdf F1). 

The need to protect reptiles and amphibians from treatment was recognized and a 

number of project design features are in place to reduce risks. As described on page 

228 of the DEIS, project design features F2, H1, H2, H5, H9, and H10 reduce the 

likelihood that for herbicides to be delivered to waterways in concentrations of 

concern. Herbicide restrictions on certain soil types (H3 and H6) reduce potential for 

runoff and leaching, restrictions on extent of treatment on a given site (H4, H5, H7 

and H8) ensure that herbicides would not be delivered in amounts greater than the 

SERA risk assessment and that unsprayed areas will be retained to provide refugia. 

Collectively these pdfs in combination with use of low risk first-year, first-choice 

herbicides reduce the likelihood that adverse effects from herbicide exposure would 

occur to reptiles or amphibians. Finally, The GLEAMS model was run on four sites 

within the project area that had the greatest potential for herbicide delivery to water 

near fish habitat. Results indicate that herbicide concentrations in the water are 

below levels of concern for fish, amphibians and aquatic invertebrates. 

12 There should be no herbicide impacts allowed to affect 

Columbia spotted frog.

Effects of herbicide application to the Columbia spotted frog are discussed on pages 

227-228 of the DEIS. Potential adverse effects are greatly reduced with 

implementation of pdfs and herbicide-use buffers. Refugia would be retained near 

breeding habitat. Finally, if occupied habitat is proposed for treatment, the site would 

be reviewed by a local biologist and treatment methods modified if necessary to 

avoid adverse impacts. Collectively, these pdfs in combination with the use of low risk 

first-year, first-choice herbicides reduces the likelihood that the Columbia spotted frog 

would be adversely affected by herbicides.

12 Don’t use herbicides in known or potential and actual Columbia 

Clubtail habitat.

Under no action, herbicide use would not be approved in these areas. Non-herbicide 

treatment could be done using categorical exclusions or as an action connected to 

another project.

12 Re: PDF J6b: What are the ester formulations of herbicide and 

what are their impacts?

This pdf refers to the ester formulation of triclopyr (BEE) which is the more toxic 

terrestrial formulation. The impacts of triclopyr BEE were discussed throughout the 

DEIS. The wildlife section of the FEIS has been edited to better describe why this pdf 

would reduce impacts to the silver-bordered fritillary. 

12

Columbia spotted frogs could be directly and indirectly affected 

by herbicide use within 300 feet of surface water and in rock 

pits.

Pdf J5-a on page 39 of the DEIS was specifically included to protect the frogs. Other 

pdfs and the herbicide-use buffers provide additional protection. DEIS page 216 

noted, “Project design features restrict treatment in suitable breeding habitat and 

make herbicide exposure unlikely.” Thus, suitable breeding habitat would be 

maintained, and proposed herbicide use within 300 feet of surface water or in rock 

pits would not have effects on the frogs beyond what is described in the DEIS. 

12 Drop all use of herbicides within known or suspected habitat for 

the silver bordered fritillary. Drop all use of NPE based 

Effects to the silver-bordered fritillary are discussed on pages 230 to 231 of the DEIS. 

This species is dependent on wet meadow habitat and currently invasive plants are 

known to occur on 34 acres of suitable habitat. Also, these sites are scattered across 

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surfactants in general. 45 watersheds. Although data on herbicide exposure to butterflies is limited (SERA 

2007, Bramble 1997, USDA Forest Service 2005a), impacts on butterflies are not 

expected to occur on this project considering 1) the small scattered nature of habitat 

proposed for treatment, 2) that herbicides would be applied with spot application on 

20 of the 34 acres proposed, 3) that preferred herbicides under alternatives B and C 

(aminopyralid, chlorsulfuron and metsulfuron methyl) are not likely to result in toxic 

levels to this species, 4) that use of ester formulations of herbicide in known silverbordered fritillary habitat would be prohibited (J6b), and 5) that pdf J6a will protect 

host/nectar plant species, it is unlikely this species or its habitat would be adversely 

affected by proposed herbicides, and 6) NPE-based surfactants would not be used in 

any alternative (pdf F1). Potential effects are further reduced when you consider that 

pdf J6-b also requires that treatment in occupied habitat would be coordinated with a 

biologist, so that the type or timing of treatment can be modified if necessary to 

reduce potential impacts. Additional information on herbicide effects has been added 

to the FEIS.

12 Don’t use herbicide in 34 acres [of silver bordered fritillary 

habitat] or on wet meadow habitat in general.

Under no action, herbicide use would not be approved in these areas. Non-herbicide 

treatment could be done using categorical exclusions or as an action connected to 

another project. 

12

Don’t use any herbicides within known occupied or suspected 

habitat for pygmy rabbit, upland sandpiper, grasshopper 

sparrow, or other rare birds and Harney Basin Duskysnail, and 

other rare mollusks.

Adverse effects on these species have been minimized while still allowing for 

effective treatment of invasive plants, as per the R6 2005 Record of Decision 

(Malheur National Forest LRMP) standards. In addition, the following species-specific 

design features would be implemented: 1) avoid treatment in on sites where 

grasshopper sparrows have been documented (J9-a), 2) protection of burrows and 

treatment methods, timing and location would be coordinated with a wildlife biologist 

in suspected pygmy rabbit habitat (J7-a), 3) modifying or avoiding treatment in sites 

with historic or recent documentation of upland sandpipers (J8-a), and 4) 

coordination of treatment timing, methods and buffers with a wildlife biologist in sites 

where the Harney basin duskysnail has been documented (J10-a). With 

implementation of these pdfs and treatment restrictions, and considering sites 

proposed for treatment would be reviewed by a biologist prior to treatment, no 

adverse effects from herbicide exposure to these or other rare species are 

anticipated. 

12 Don’t use herbicides in potential and actual Harney Basin 

Duskysnail habitat.

Under no action, herbicide use would not be approved in these areas. Non-herbicide 

treatment could be done using categorical exclusions or as an action connected to 

another project.

12

Re: PDF J12 – How would big game species be protected from 

toxic herbicide contamination from grazing and from 

bioaccumulation of herbicide toxins. These PDFs are typical 

human disturbance PDFS, mostly without adequate analysis or 

remedies to protect herbicide exposure and toxic 

Effects of herbicide exposure on big game are discussed on pages 232 to 233 of the 

DEIS. As described, while glyphosate and picloram, could result adverse effects at or 

above the typical application rate, with implementation of pdfs, these herbicides 

would not be applied at levels that would result in acute or chronic doses of concern. 

Effects of exposure are further reduced when you consider that elk forage over large 

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contamination. areas and are not likely to consume an entire day’s diet of contaminated vegetation 

(acute exposure) or forage exclusively on vegetation for 90 days (chronic exposure). 

As a result and considering that 88 percent of the proposed treatments occur close to 

open roads, which are less likely to be used by elk (Thomas 1979), it is unlikely that 

elk would be adversely affected by herbicide exposure. In addition, NPE-based 

surfactants have been prohibited from use in the project (pdf F1). 

12

Wildlife considerations for herbicide use/selection should not be 

limited to just seasonal restrictions designed to control/reduce 

human disturbance. Likewise, not just fish species of 

conservation concern should be considered, but also their prey 

species.

We agree that seasonal restrictions alone may not adequately reduce potential 

effects from herbicide exposure. That is why many of the pdfs proposed for 

implementation limit application and place restrictions on higher risk 

herbicides/surfactants (pdfs F1-F5, LRMP standards, and pdfs J3-e, J4-a, J5-a, and 

J6-b). Implementation of these pdfs/standards reduce effects to conservation species 

of concern, as well as other terrestrial and aquatic species and require coordination 

with a wildlife biologist to modify the treatment type, timing and buffers, or avoid 

treatment if necessary to reduce potential effects (pdfs J5-a, J6-b, J7-a, J8-a, J9-a 

and J10a). Collectively these pdfs, as well as other considerations described in the 

DEIS (e.g., foraging behavior of wildlife and the small and scattered nature of

treatment sites) reduce the likelihood of herbicide exposure to terrestrial and aquatic 

species.

12 Clopyralid contains HCB, so alternative C does not eliminate all 

risk of HCB contamination to raptors.

The FEIS has been corrected to indicate that alternative C reduces risk of HCB 

contamination due to use of picloram, but does not eliminate all risk due to allowing 

use of clopyralid. Clopyralid is not a first-choice herbicide in any of the alternatives. In 

all alternatives, the pdfs reduce the potential for peregrine falcons to be exposed to 

HCBs. 

12 Poisoning is more harmful to wildlife than disturbance.

The DEIS analysis disclosed both risks from herbicide use and general disturbance 

to wildlife habitat from all treatments. In many cases, herbicide use would not affect a 

given wildlife species whereas disturbance would. See Chapter 3.7 for more 

information. 

12

What analysis supports the statement [DEIS page 76] that there 

would be “no possibility for this project to result in exposures 

that could cause a cumulative effect in animals.”

The DEIS page 76 noted that the risk assessments evaluated chronic exposures to 

herbicides and found that cumulative effects are unlikely because the herbicides 

would be more rapidly excreted than they would be absorbed from predicted levels of 

exposure. Pages 214-215 of the DEIS provided further reasoning for why the 

potential for exposure to cause a cumulative or chronic exposure is implausible. The 

FEIS has been edited for clarity. 

12

Because data for amphibians is more limited than mammals 

and birds, and data is limited regarding effects of herbicides on 

mollusks, and because data was insufficient to assess risk of 

chronic exposures for some surfactants and herbicides, and 

other relevant data limitations, less herbicide should be used 

overall, and the most toxic or persistent herbicides should not 

be used, and herbicides should not be used near riparian areas.

This comment is noted and the risks, data limitations and uncertainty of herbicide 

treatment to wildlife were recognized throughout the DEIS. In fact, it is these risks 

and data limitations that led to the development of project design features (see table 

9) and herbicide-use buffers. These design features/buffers not only reduce potential 

impacts to species of concern, but also limit use of higher risk herbicides/surfactants 

and reduce treatment effects to all terrestrial and aquatic species. Alternative C 

provides a basis for comparison for eliminating all herbicide use within 100 feet of wet 

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and dry streams. In alternatives B and D, while herbicide may be used within 100 

feet of streams, herbicide-use buffers restrict methods of application near stream for 

some of the herbicides and a cap of 10 acres per year within 100 feet of a stream in 

any 6th field watershed would minimize riparian impacts from herbicides. Additional 

pdfs restrict rates and methods of application to reduce potential for adverse effects.

12

[re: statement that small mammals would likely not be directly 

sprayed then consumed by other animals because they are 

generally nocturnal] is not true of squirrels, etc.

We recognize that not all small mammals are nocturnal. However, many mammals 

are nocturnal and this behavior, combined with the fact that many preferred habitats 

(e.g., burrows, and trees) would not be treated, reduces the likelihood of direct spray. 

The risk assessments consider the effects of consumption of prey that has been 

exposed to herbicides. Acute and chronic herbicide exposure over a long period of 

time would be far below the “no effect” level. The fact that many small mammals are 

nocturnal and therefore would not be exposed to herbicide during operations adds 

another layer of caution. 

12 We are concerned about herbicide impacts to wildlife because 

herbicides can cause malformation or mortality to amphibians.

Effects to amphibians are discussed on pages 227-228 of the DEIS and potential 

impacts are minimized with implementation pdfs and herbicide-use buffers. Potential 

effects to amphibians and aquatic-dependent species from herbicide application were 

recognized and a number of pdfs and herbicide-use buffers near streams were 

proposed to minimize risks. Taken together, these restrictions and buffers minimize 

risks to aquatic-dependent species such as the Columbia frog. Further protection for 

hydrologically connected ditches has been added. The action alternatives have been 

modified to prohibit use of POEA and NPE-based surfactants (pdf F1). The need to 

protect reptiles and amphibians from treatment was recognized and a number of 

project design features are in place to reduce risks. As described on page 228 of the 

DEIS, project design features F2, H1, H2, H5, H9, and H10 reduce the likelihood that 

for herbicides to be delivered to waterways in concentrations of concern. Herbicide 

restrictions on certain soil types (H3 and H6) reduce potential for runoff and leaching, 

and restrictions on extent of treatment on a given site (H4, H5, H7 and H8) ensure 

that herbicides would not be delivered in amounts greater than the SERA risk 

assessment and that unsprayed areas will be retained to provide refugia. Collectively 

these pdfs in combination with use of low risk first-year, first-choice herbicides reduce 

the likelihood that adverse effects from herbicide exposure would occur to reptiles or 

amphibians. Finally, The GLEAMS model was run on four sites within the project 

area that had the greatest potential for herbicide delivery to water near fish habitat. 

Results indicate that herbicide concentrations in the water are less than levels of 

concern for fish, amphibians and aquatic invertebrates.).

12

Table 60 illustrates additional reasons (wildlife impacts) to 

completely stop the use of triclopyr, NPE surfactant, picloram, 

sulfometuron methyl, and not to use maximum rates of 

glyphosate and sethoxydim.

Potential effects to wildlife from herbicide application are discussed in section 3.73 of 

the DEIS. The analysis concluded that adherence to invasive plant treatment 

standards and pdfs, actual animal behavior and feeding strategies, and/or seasonal 

presence/absence within treatment areas would reduce risks. As a result and 

considering the limited spatial extent of infestation (over 80 percent of sites are 0.25 

acres or less), the DEIS concluded that wildlife is not likely to be exposed to harmful 

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levels of herbicides or surfactants under the action alternatives. NPE-based 

surfactants have been prohibited from use in the project (pdf F1). 

12

Drop the use of herbicides in the 8 acres of lynx foraging and 

denning habitat. We have seen lynx (good sightings) on the 

Ochoco NF and near the Umatilla NF in about 2003 and 2010.

The no action alternative would not approve herbicide use in these areas. Nonherbicide treatment could be done using categorical exclusions or as an action 

connected to another project. Potential effects to lynx are discussed on page 215 of 

the DEIS. As described, lynx are not expected to be adversely affected because of 

their infrequent occurrence and small amount of habitat proposed for treatment (8 

acres).

12 Drop the < 1 acre of herbicide use and disturbance to wolverine 

denning habitat.

The no action alternative would not approve herbicide use in these areas. Nonherbicide treatment could be done using categorical exclusions or as an action 

connected to another project. Potential effects to wolverine were discussed on page 

215 of the DEIS. As described, wolverine are not expected to be adversely affected 

because of their infrequent occurrence, small amount of habitat proposed for 

treatment, and considering they prefer remote areas that are less likely to be affected 

by invasive plants or treatment.

12

Drop the use of triclopyr and NPE based surfactants to help 

protect gray wolves (and bears, cougars, coyote, foxes, lynx, 

bobcats, etc.). Drop all herbicide use in preferred wolf habitat.

The DEIS acknowledged risks associated with triclopyr and NPE surfactants (the 

alternatives have been modified to prohibit use of NPE-based surfactants)(pdf F1). 

Potential effects to wolves are discussed on page 217-218 of the DEIS. As 

described, wolves are not likely to be affected because pdfs would protect den or 

rendezvous sites; and at proposed application rates and with implementation of pdfs, 

no adverse effects from herbicide exposure are anticipated. 

12 Drop use of NPE surfactants and picloram to help protect bat 

species. Keep glyphosate below maximum rates.

Effects to bats are discussed on page 219 of the DEIS. As described, no roost sites 

would be affected, pdfs restrict herbicide use, and bat foraging behavior makes it 

unlikely they would be adversely affected by proposed herbicides. As a result, no 

adverse effects from herbicide exposure are anticipated. NPE-based surfactants 

would not be used (pdf F1). 

12 This cumulative effects discussion [about bats] fails to consider 

the effects of white nose syndrome and human disturbance

To date, white nose syndrome has not been documented northwest of Oklahoma 

(Butchkowski 2013). While it is possible, it could be documented at some point in the 

future, this is speculative and it is unlikely to occur on the Malheur National Forest 

during the analysis period. Also, the Pacific Northwest Region is actively engaged 

with prevention methods and public awareness efforts identified by the Fish and 

Wildlife Service http://www.fs.usda.gov/detail/r6/forestgrasslandhealth/invasivespecies/?cid=stelprdb5302193 and Western Bat Working 

Group recommendations (WBWG 2010).

12

Drop the use of NPE surfactants, picloram and clopyralid (re: 

HCB) to reduce herbicide risks to peregrine falcons, bald 

eagles, northern goshawk and other raptors.

The DEIS analysis concluded that the pdfs sufficiently minimize risks to falcons, 

eagles, and goshawk in all action alternatives. NPE-based surfactants would not be 

used (pdf F1). 

12 [Discussion about peregrine falcon] provide more reasons for 

our concerns re: risks to peregrine falcons and other birds of 

The DEIS analysis concluded that no peregrine falcon nest sites are known on the 

Malheur National Forest and that implementation of project design features would 

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prey. ensure that any future nesting peregrine falcons would be not be adversely affected 

by treatments or be exposed to toxic levels of herbicide. The DEIS also found that the 

likelihood for HCB contamination is remote and discountable. 

12 No use of NPE surfactants, triclopyr, picloram, clopyralid, nor 

high rates of glyphosate also helps neotropical songbirds.

Effects to birds of conservation concern, including many neotropical songbirds, were

discussed on pages 238 to 241 of the DEIS. Considering the small amount of habitat 

proposed for treatment, reduced risk due to foraging behavior, and pdfs, no adverse 

effects from herbicide exposure to songbirds are anticipated. The action alternatives 

have been modified to prohibit use of NPE-based surfactants (pdf F1). 

12 Inadequate cumulative effects analysis re: effects of livestock 

combined with potential herbicide effects, etc. to sage grouse.

Grazing was considered as a cumulative effect under the action alternatives in the 

DEIS (page 211-215), as well as under the analysis for sage grouse (page 224). It 

was recognized that continued grazing could promote the spread of invasive plants 

and reduce wildlife cover and forage conditions, particularly in dry forest and shrub 

steppe habitats. Because grazing use is not expected to change, and with 

implementation of allotment management plan and allowable use standards, it is 

expected that existing habitat would be relatively unchanged. While it was recognized 

that continued grazing could adversely affect sage grouse habitat by promoting 

invasive weeds, because proposed treatments (including EDRR) are expected to 

control future expansion of invasive plants, proposed actions would help to maintain 

sage grouse habitat. Herbicide exposure was also considered in the cumulative effect 

analysis and is described on page 214. Due to the small amount of habitat proposed 

for treatment, treatment restrictions within breeding habitat, and reduced risk of 

herbicide exposure, none of the alternatives would measurably contribute to any 

other past, ongoing or future activity and result in consequential effects to sage 

grouse

12

[The statement that sage grouse would not be exposed to toxic 

levels of herbicide] is not certain given the data gaps noted 

previously.

While some data are lacking as explained on page 224 of the DEIS, the conclusion 

that sage grouse would not be exposed to toxic levels of herbicide was made for a 

number of reasons including: 1) NPE will not be used 2) pdf F2 restricts broadcast 

application of clopyralid, glyphosate, picloram, sethoxydim and sulfometuron methyl 

to typical application rates, 3) The Malheur National Forest LRMP prevents broadcast 

application of triclopyr, 4) Only 79 acres of invasive plant treatment are proposed in 

suitable habitat and sites are small and scattered across 20 watersheds, and 5) the 

use of the project area by sage grouse is scattered and incidental, thus it is unlikely 

that birds would consume 100 percent of their diet from contaminated 

insects/vegetation for 90 days and receive a chronic dose of concern. The effect 

determination that sage grouse are not likely to be exposed to toxic levels of 

herbicide is based collectively on these considerations. 

12 Drop herbicide use on upland sandpiper habitat. The analysis in the EIS does not indicate that herbicides would adversely affect 

upland sandpiper habitat.

12 Don’t use herbicides in deer and elk fawning and calving 

habitat.

The analysis in the EIS does not indicate that herbicides would adversely affect deer 

and elk fawning and calving habitat. Most herbicide treatments would occur later in 

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the summer than when calving occurs. 

12

Statements about invasive plants in goshawk habitat are 

contradictory (567 acres of nesting/foraging habitat, and 18 

acres within post-fledgling habitat are proposed for treatment, 

versus the statement that northern goshawk prefers closed 

canopy mature forest so its habitat is not at risk from invasive 

plants.)

Goshawk prefer closed canopy forest for nesting, thus nesting habitat is generally not 

at risk from invasive plants. However, as described in the DEIS, post-fledgling and 

foraging can occur in non-forest and more open forests areas where some invasive 

plants can be found. Suitable goshawk habitat would be maintained and any effects 

from treatment would be minor and short-term.

12

Don’t use herbicides within goshawk nesting and foraging 

habitat including PFAs that are declining from cumulative FS 

management impacts. Timber sales are routinely degrading 

PDFAs on the Malheur and are rending them as unsuitable for 

PFA habitat, so there are cumulative reproductive effects to 

consider. What about cumulative effects to raptor eggs?

Anticipated cumulative effects, including timber harvest were displayed in DEIS table 

62. Invasive plant treatment would occur on approximately 519 acres that would also 

be harvested. As described on page 235, while ongoing and future activities would 

modify goshawk nesting and foraging habitat, existing LRMP standards would protect 

nest sites and PFA areas. As a result, none of the alternatives would measurably 

contribute to any other past, current or foreseeable activity and there are no 

consequential cumulative effects anticipated. 

Range

12 Ungulates can bioaccumulate herbicides. There should be no 

herbicide use within 100 feet of stock tanks.

The herbicides proposed for use would not bioaccumulate in grazing animals. Using 

spot or selective methods of herbicide application would provide an additional layer 

of caution to protect water sources for grazing animals. 

12

Re: PDF group N: Avoid use of bioaccumulating toxic herbicide 

ingredients and formulas listed on herbicide labels as having 

potential to contaminate ungulate milk or meat.

Label guidance related to grazing animals would be followed in all alternatives as 

described in the DEIS range section. The herbicides approved for use do not 

bioaccumulate in the bodies of mammals. Hexaclorabenzene, a contaminant in 

clopyralid and picloram, does bioaccumulate. However, the amount that would be 

used is very small. Hexaclorabenzene is ubiquitous in the environment. Milk and 

meat would not be contaminated. 

12

Discussion about clopyralid, chlorsulfuron, metsulfuron methyl, 

picloram, surfactants, and triclopyr provide reasons for 

concerns about cattle. Wouldn’t altered liver and kidney weights 

constitute pathological effects to specific organs from use of 

picloram? The use of triclopyr should be discontinued as it is 

highly toxic to large mammals.

This information reflects general hazards associated with the herbicides and 

additives but does not consider the exposure scenarios that would be plausible for 

this project. Given the limited extent of herbicide use and the pdfs, impacts to grazing 

animals are not expected. Triclopyr would be used infrequently in this project. It is not 

one of the first-choice herbicides in any alternative for any target species. The 

grazing section has been updated to focus on plausible risks to grazing animals. 

Cumulative Effects

04

The rate of active forest management seems likely to increase 

in the coming years to address a legacy of past high-grading, 

fire suppression, and livestock grazing abuses. We are 

concerned that this EIS may not fully consider the cumulative 

effects of long-term widespread chemical treatments, especially 

in light of the possibility that some of these treatments could be 

avoided with less intensive and/or less extensive active 

management.

The cumulative effects analysis in the DEIS specifically addressed the ongoing and 

foreseeable future projects and the cumulative impact of treatment, in light of the 

potential to spread invasive plants. The pdf limitations and treatment caps are 

intended to ensure that the adverse effects of chemical treatments are minimized so 

they will not add up to additional cumulative effects. As discussed in the previous 

comment, most of the invasive plants on the Malheur National Forest are along 

roads, rather than being related specifically to forest practices or fire suppression. 

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12

Cumulative effects analysis is not adequate. What are the 

consequences of multiple stressors plus herbicide poisoning on 

fish, amphibians, pollinators, Neo-tropical songbirds, raptors, 

ungulates, etc.

Cumulative effects were addressed in the DEIS for all resources and the analyses 

have been augmented in the FEIS. Because the scale of the project is so small 

compared to the amount of habitat available, and because impacts from the project 

have been minimized, the project would not add stress to wildlife or fish species or 

contribute to cumulative effects. Stressors on species are described and accounted 

for in the analysis.

12 Additive effects are by definition cumulative effects. Additive effects were considered in the DEIS. 

12

Terms such as “unlikely to be measurable or detectable” remain 

unsupported by analysis and unquantified. This does not 

account for the combined or synergistic effects of multiple 

herbicide applications (potentially of different herbicides) 

repeated on the same sites over time.

The herbicide risk assessments and site-specific analysis provide analysis measures 

as available. As discussed on pages 98-99 of the DEIS, the R6 2005 FEIS noted, 

“combinations of chemicals in low doses have rarely demonstrated synergistic 

effects.... synergistic or additive effects, if any, are expected to be insignificant.” 

DEIS Chapter 3.1.4 explained how each treatment entry would reduce invasive plant 

density, and thus, less herbicide would be needed over time on any given site. The 

pdfs, herbicide-use buffers and annual caps also limit the amount of herbicide used 

overall. 

12

The cumulative effects analysis does not adequately address 

additive, synergistic, and chronic effects regarding overlapping 

combined effects of repeated herbicide applications and 

combined effects of various projects; veg, livestock grazing 

near roads, livestock grazing in timber sale areas, ATV use 

introducing invasive plants, then logging creating suitable 

habitat for them, etc.

The cumulative effects analysis throughout the DEIS addressed the potential for 

invasive plants to be spread from land use activities and the interaction between 

these activities and effects from this project. 

12

[Re: statement that median logging acreage is 8,000 acres per 

year for the last ten years]: Now the acreage logged on the 

Malheur is much more than 8,000 acres and has been for a few 

years.

All vegetation management projects include prevention measures to address the 

potential for invasive plants to spread from ground disturbing activity. 

12

We find it very hard to believe that only 2 percent of the 

invasive plant sites correlate with livestock grazing and only 6 

percent with logging and wildfire based on our experience on 

the Malheur. It’s hardly only a moderate risk of invasive plant 

dispersal from livestock grazing. May the Forest Service is not 

seeing a lot of what we’re seeing because we spend most of 

our time away from the roads in timber sale units. Livestock and 

logging as invasive plant introduction and dispersal vectors 

should have been addressed in depth by this DEIS regarding 

site –specific information that could help determine effective 

site-specific prevention. Keep livestock out of riparian areas and 

areas of concentrated ground disturbance where water acts to 

further disperse invasive plants and enables their 

establishment. Check gate entrance areas to determine which 

Tables 68 and 69 displayed invasive plant acreage within allotments on the Malheur 

National Forest. Invasive plants are mapped on about 1/10th of 1 percent of active 

allotment acreages. Allotment management plans consider conditions within the 

allotments and include prevention measures to prevent the spread of invasive plants 

there. Cattle may be kept away from treated areas until the area has recovered and 

contains desirable vegetation as a part of post-treatment site restoration. For 

instance, the Summit Logan Valley Allotment Management Plan includes prevention 

measures related to spring development and makes specific reference to reducing 

soil disturbance. Invasive plant treatment would be designed to improve riparian 

vegetation conditions on the Malheur National Forest. However, there is damage to 

riparian areas from livestock that would not be addressed by invasive plant treatment 

alone. Restoration of riparian areas damaged by grazing is outside the scope of the 

EIS. The FEIS has been edited to note that some portions of allotments, including 

riparian areas, have been more seriously degraded from cattle and that disturbance 

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herds are bringing in invasives. Which allotments have more 

invasive plants? Keep cattle out of existing infestations.

from cattle can increase susceptibility to invasive plants. Follow-up seeding and 

planting of native plants in treated areas would help to reduce the chances of reinfestation of invasive plant species.

12

Table 34 illustrates the cumulative impacts already degrading 

habitat conditions and water quality in major rivers and creeks 

on the Malheur. These streams are already severely degraded 

by livestock use, logging, roading and in some cases, mining. 

All in ways detrimental to fish. Adding herbicide contamination 

is a cumulative effect that could threaten fish viability. Already 

reduced fish runs of listed species...cannot take more 

degradation of streams and river conditions without it affecting 

their viability.

The project design features and herbicide-use buffers for this project minimize the 

likelihood that herbicide would affect streams and degrade fisheries. Given all of the 

project design features, herbicide-use buffers, and annual treatment caps, no 

degradation of streams or river conditions would likely occur. 

12

First paragraph of cumulative effects section on page 144 does 

not acknowledge persistent herbicides like picloram and 

imazapyr.

The soil cumulative effects analysis discussed persistence of herbicides noting that 

“herbicide half-life period and pdfs that limit re-treatments of more persistent 

herbicides largely preclude cumulative effects from multiple treatments at a single 

site.” Herbicides have variable rates of decay primarily depending on the soil capacity 

for microbial decomposition and secondarily due to solubility, and exposure to 

sunlight. Laboratory studies cited in the SERA risk assessments address sensitive 

types of bacteria and fungi to herbicide concentrations. One type of microbial 

sensitivity does not translate to overall microbial sensitivity with concomitant adverse 

effects to soil fertility. To expand the layers of caution against herbicide buildup, the 

timeframe for reapplication of herbicides was increased to once every two years for 

picloram, imazapyr and metsulfuron methyl. The time frame for reapplication of 

aminopyralid has been limited to once a year because of its relatively long half-life. 

Please note that aminopyralid has high decay rates in sunlight. 

12

How many streams, river reaches in the John Day River has 

enough pesticides in it to give me toxic symptoms. How many 

streams have actually been tested for chemical contamination?

This is unknown. None of the streams within the project area have been 303d listed 

for chemical contamination, based on monitoring conducted by the Oregon State 

Department of Environmental Quality. 

12

Re previous studies (discussed on page 77): Aren’t these 

Western Cascades studies, i.e. areas with more water flow? 

There’s a lot of nuances being lost here.

No local studies exist. However, site-specific modeling done for highest risk situations 

on the Malheur National Forest using small streams (about 2 cubic feet per second) 

found that the amount of herbicide that would reach streams would be below a 

threshold of concern for fish (DEIS table 38). Lower flow streams would show greater 

effect (higher concentration) than higher flow streams.

12

Re NWQAP Pesticide Study: Conclusion [of the study] indicates 

lack of dilution and degradation of pesticides or the degradation 

constituents in streams, contrary to prior DEIS assurances that 

herbicides in streams would be diluted and unlikely to cause 

impacts.

The risk assessments discussed the potential for the herbicides proposed for use in 

this project to reach streams. Site-specific modeling indicated that the amount of 

herbicide that would reach streams would be below a threshold of concern. 

Parameters for climate and stream flow used in model runs were derived from local 

sources and reasonable estimates based on knowledge of local conditions and 

channel size.

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12

Re; page 78: Vector/pathways for pesticide transport [runoff, 

leaching] are operational on the Malheur. Why are these not 

discussed?

This comment was made in reference to a study quoted on page 78 in the 

introduction to cumulative effects, which was not specific to this project or the 

Malheur National Forest. Runoff and leaching in relation to this project was 

specifically discussed on DEIS pages 93, 125-126, 128, 136-137, and 139-143. 

12

[Study on page 78 talks about human health benchmarks]. Yet 

human health is not the only or main concern with stream 

contamination. What about benchmarks for effects to 

invertebrates, fish or amphibians? It’s is a lower threshold of 

concern for fish, amphibians, and aquatic invertebrates than for 

humans, much lower.

Benchmarks (toxicity indices, thresholds of concern) were discussed in the DEIS for 

fish and wildlife. The risk assessments and R6 2005 FEIS contain additional 

information. The Malheur National Forest Invasive Plant Treatment FEIS includes 

additional information about the toxicity indices for aquatic invertebrates, aquatic 

plants and algae. 

12

[The Clackamas River Study] fails to convince me that the 

Forest Service should go ahead and add more herbicide to the 

National Forest because there are less herbicides there than 

industrial and agricultural studies.

This information was provided for context. Herbicide use for this project would be 

very low in comparison to total herbicide use off National Forest land. There is no 

indication that the herbicide use proposed would measurably add to herbicide use 

downstream. 

12

The description of allotment conditions is biased and deceptive. 

Disturbance is artificially diluted by averaging it across the 

allotment. Actually, livestock have been creating bare soils and 

denuded stream banks in riparian areas, with severe soil and 

native plant damage, setting up perfect conditions for invasive 

plant establishment. There are a lot of invasive plants in riparian 

corridors damaged by livestock on the Malheur, based on our 

field experience.

Invasive plant treatment would be designed to improve riparian vegetation conditions 

on the Malheur National Forest. However, there is damage to riparian areas from 

livestock that would not be addressed by invasive plant treatment alone. Restoration 

of riparian areas damaged by grazing is outside the scope of the EIS. The FEIS has 

been edited to note that some portions of allotments, including riparian areas, have 

been more seriously degraded from cattle and that disturbance from cattle can 

increase susceptibility to invasive plants. Follow-up seeding and planting of native 

plants in treated areas would help to reduce the chances of re-infestation of invasive 

plant species.

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