EA for Integrated Treatment of Exotic Invasive Plants on the Tonto National Forest 1

Appendix G: Herbicide Project Design 

Features to Mitigate Potential Effects to 

Federally-listed and Sensitive Plant and 

Animal Species on the Tonto National Forest

General Project BMPs

1. Implement Integrated Weed Best Management Practices.

2. Use native species for seeding.

3. FS will test for Forest-listed weed species for all seed and mulch used on the Forest, to 

ensure they are free of weed species that are of concern to the Forest.

4. Work cooperatively with adjacent landowners, managers, and local weed management

entities to manage noxious and invasive weeds to prevent their spread into or from NFS 

lands.

5. Always follow herbicide label instructions.

All Species

1. Where two or more species’ habitats occur, the more restrictive measures will take 

priority.

2. Consult with Forest Service Botanist and Wildlife Biologist prior to use of herbicides on 

a project, to determine mitigation measures needed for federally-listed species.

Animal Species

1. Where specified, species breeding season timing restrictions are applicable to all

treatment methods that are not commensurate with the designated uses.

Plant Species Habitat

1. Survey potential habitats before treatments occur.

2. Train field treatment crews in proper identification of listed species to avoid damage to 

the plants.

3. Where buffer areas are required, use hand or mechanized treatments adjacent to 

federally-listed species.

4. No mowing in federally-listed plant species habitat.

5. Where prescribed fire is to be employed, construct fire lines around plant groups or avoid 

areas with high densities of listed plants.

6. When using livestock in listed plant habitat, use timing, a herder, and/or utilization 

monitoring to minimize impacts to non-target plant species.

7. Avoid listed plants if using steaming to control weeds.

Mitigation measures for use of herbicides have been adopted directly from the U.S. Fish and 

Wildlife Service document, “Recommended protection measures for pesticide applications in 

Region 2 of the U.S. Fish and Wildlife Service” (USDI, USFWS, 2007a), (referred to in the text 

as RPMPA),or as noted below:
Appendix G: Herbicide Project Design Features to Mitigate Potential Effects to Federally-listed 

and Sensitive Plant and Animal Species on the Tonto National Forest

2 EA for Integrated Treatment of Exotic Invasive Plants on the Tonto National Forest

Arizona cliffrose:

1. Treatment crew members will be trained to identify Arizona cliffrose and associated 

sensitive species, and will be supervised by a botanist.

2. A Forest Service Botanist trained in use of herbicides will approve the herbicide for the 

project within cliffrose habitat.

3. Any project area within cliffrose habitat will be surveyed for seedlings prior to project 

initiation. Buffers of 20 feet for spot treatments (60 feet for mechanized treatments) will 

be created to protect groups of seedlings.

Gila chub, Gila topminnow, speckled dace, Gila trout in small riparian 

habitats:

1. After a survey has been conducted, no restrictions on pesticide applications if USFWS 

concurs that habitat is unoccupied by the species (RPMPA p. 73)

2. Herbicides would be applied per guidelines in RPMPA (p. 73) with the following 

modifications:

a. Approved herbicides (aquatic formulations only): Glyphosate, Imazapic, 

Imazapyr, Triclopyr (amine formulation) may be used within the riparian zone 

adjacent to the aquatic habitat.

b. For pool habitats, no pesticide applications may occur near pools when there is 

no surface flow of water in and out of pool or pools. Per the RPMPA, a 30-foot 

buffer would apply when there is no surface flow of water.

c. When stream flows exceed 100 cfs (cubic feet per second), may apply guidelines 

for large riparian habitats (RPMPA pp. 76-79).

Colorado pikeminnow, loach minnow, razorback sucker, spikedace in large 

riparian habitats:

1. Herbicides will be applied per guidelines in RPMPA pp. 76-79.

Southwestern willow flycatcher:

1. No biological control of saltcedar may be conducted until further NEPA analysis and 

ESA Section 7 compliance is documented.

2. Herbicides will be applied per guidelines in RPMPA pp. 64-68.

3. Forest Service Wildlife Biologist will determine patch size for nesting areas and identify 

sites on the ground prior to treatments.

4. Forest Service Wildlife Biologist will confirm occupancy during the breeding season 

(April through August) (USDI, 2002)

5. Saltcedar removal treatments will not occur within the conservation spaces of Horseshoe 

and Roosevelt Lakes where existing Habitat Conservation Plans are established and large 

populations of nesting flycatchers occur.

6. Treatment of non-saltcedar noxious weeds by mechanical, manual, and biological 

methods will not target plans the flycatcher relies upon, nor is expected to occur within 

its habitat resulting in any direct or indirect effects to the flycatcher or its habitat.

7. The amount of saltcedar removal is limited to approximately 11 acres per year in 

designated and proposed critical habitat, will occur gradually over the life of the project. 
Appendix G. Herbicide Project Design Features to Mitigate Potential Effects to Listed 

Species

EA for Integrated Treatment of Exotic Invasive Plants on the Tonto National Forest 3

As a result, riparian vegetation removal is only temporary and is expected to become reestablished by native vegetation.

8. On Tonto Creek, treatment to remove saltcedar will only be conducted upstream of 

Gisela (figure 3). Consequently, no critical habitat will be impacted on Tonto Creek.

9. On the Salt River, three areas of potential habitat for the flycatcher will be excluded 

from saltcedar treatment (figures 2a through c). This will reduce any potential impacts to 

SWFL and their habitat along the Salt River.

10. We will not treat saltcedar of known SWFL territory that has been occupied within the 

last 3 years of proposed treatment date. If the extent of the SWFL territory is unknown, 

we will not treat within a quarter mile of the average location of a breeding SWFL 

individual. Migratory SWFLs are not included in this conservation measure. This 

measure applies to all SWFL habitat regardless of whether the habitat is within or outside 

of designated SWFL critical habitat.

11. We will treat saltcedar in SWFL Critical Habitat from September to March when SWFL 

are absent from the area. 

12. We will not remove saltcedar monocultures greater than 0.25 acres. In all other areas, we 

will only treat saltcedar in those areas where the canopy of tamarisk consists of less than 

10 percent of the total area within a 50-foot radius circle (NOTE: saltcedar seedlings less 

than 3 feet tall are not used in this estimation; we will remove unlimited amounts of 

saltcedar seedlings.

Yellow-billed cuckoo:

1. Herbicides will be applied per guidelines in RPMPA p. 64-68.

2. A Forest Service Wildlife Biologist will determine patch size for nesting areas and 

identify sites on the ground prior to treatments.

3. A Forest Service Wildlife Biologist will confirm occupancy during the breeding season 

(May through August).

4. Applications adjacent to occupied breeding areas would occur outside the time of 

occupancy.

Bald eagle:

1. Breeding season is December 1 through June 30. (B.E.R.T., 1982)

2. Nest occupancy will be determined by a Forest Service Wildlife Biologist.

3. Herbicides may be applied as spot treatments (and not from motorized equipment) within 

breeding areas during the breeding season, when working in coordination with USFWS 

on a case-by-case basis.

Mexican spotted owl:

1. Breeding season is March 1 through August 30.

2. No treatments may occur within occupied “No Activity Centers.” Forest Service Wildlife 

Biologist to determine occupancy.

3. Only specified herbicides may be applied (and not from motorized equipment) within 

MSO PACs during the breeding season (see list).

4. Specified herbicides may be applied during the breeding season to the remainder of the 

MSO PAC outside of the “No Activity Center” by non-motorized methods.
Appendix G: Herbicide Project Design Features to Mitigate Potential Effects to Federally-listed 

and Sensitive Plant and Animal Species on the Tonto National Forest

4 EA for Integrated Treatment of Exotic Invasive Plants on the Tonto National Forest

Yuma clapper rail:

1. Herbicides will be applied per guidelines in RPMPA pp. 64-68.

2. A Forest Service Wildlife Biologist will determine nesting areas and identify the site on 

the ground prior to treatment.

3. A Forest Service Wildlife Biologist will confirm occupancy during the breeding season 

(March through July).

4. Applications adjacent to breeding areas will occur outside the time of occupancy.

Cactus ferruginous pygmy owl:

1. A Forest Service Wildlife Biologist will determine nesting areas and identify these on the 

ground prior to treatment.

2. A Forest Service Wildlife Biologist will confirm occupancy during the breeding season 

(February through June).

3. Herbicides will be applied per guidelines in RPMPA pp. 125 – 128.

Lesser long-nosed bat:

1. A Forest Service Wildlife Biologist will determine roosting sites and identify these on the 

ground prior to treatment.

2. Herbicides will be applied per guidelines in RPMPA pp. 57 – 60.

Chiricahua leopard frog:

1. Herbicides will be applied per guidelines in RPMPA pp. 136 – 140.

2. If there is a high probability (80 percent chance) of local moderate rain (0.25 inches or 

less within 24 hours), then applications will only occur when it is anticipated that there 

shall be sufficient time (at least four hours) for the application to dry before rainfall 

occurs. If rainfall of more than a moderate amount (more than 0.25 inches) is predicted 

locally within 48 hours, applications will be discontinued until predictable local 

conditions improve. When plant cover is wet from recent rain, heavy dew, or frost, 

applications will be delayed until conditions are nearly dry.