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AA. Question sent to the other National Forests in Arizona: Would you say your forest is
experiencing some successes in using an IVM program?

Response from the Coconino National Forest, a Forest with one of the largest herbicide
programs in the state:

Yes. In seven years we have:

Treated 22 miles of river corridor with an average of 85% effectiveness using chemical and
manual control. (This is on both the Prescott and Coconino NFs)

Reduced a 125 acre population of Mediterranean sage to less than 5 acres with manual coniroi.
Reduced a widespread leafy spurge population (gross orea >1000 acres) to 10 % of original
acreage with chemical, mechanical and biolegical control.

Reduced density and seed production of diffuse knapweed populations along a highway by 75%
using bio-control and chemical control.

Response from the Coronado: We are in the beginning of our integrated weed control program
and it is too early to tell.

Response from the Kaibab, who accomplishes the most weed control acres of any other Forest

in Arizona:
We employ early detection/rapid response on R3’s more problematic weeds, so it is hard to

measure success. However, because we don’t have big issues with these species, | am assuming
that it has been successful.

8B. Estimated acres of each weed species were added to Table 1.

CC. Addition of topo lines to maps of this scale would render them unreadable. Some features were
labeled, and other modifications were made to assist those unfamiliar with the Tonto in using
the maps. All map symbols were checked to assure they are included in map legends.

DD. See section on monitoring page 14, Chapter 1. Effects on habitat will be monitored. Weed
treatment protocols require effectiveness monitoring a month or two post-treatment. If weed
control treatments result in an increase in bare ground, a cultural treatment such as
revegetation could be used as the next step in the integrated vegetation management for that
site.

EE. Mitigation measures on pages 72 and 73 of the EA, Best Management Practices (Appendix D of
the EA}, a National Pollutant Discharge Elimination System (NPDES) permit through the state of
Arizona, and Appendix G (Herbicide Project Design Features to Mitigate Potential effects to
Federally-listed and Sensitive Plant and Animal Species on the Tonto National Forest) address
the potential for non-target of off-site runoff or herbicide drift to aquatic areas near treatment
sites. Drift from backpack sprayers under conditions that are allowed according to this EA are
minimal, Drift from mobile ground sprayers such as ATVs, UTVs and trucks is slightly higher and
is addressed by the above design features and mitigation measures.

FF, See Table 7: Potential for surface runoff and leaching for proposed herbicides, for limited
probability of most herbicides to runoff into adjacent waters. Also Appendix G: Herbicide


Subchronic Studies

Subchronic tests provide information on health hazards that may arise from repeated exposures
over a limited period of time. They provide information on target organs and accumulation
potential. The resulting data are also useful in selecting dose levels for chronic studies and for
establishing safety criteria for human exposure. These tests are not capable of detecting those
effects that have a long latency period for expression (@.g., carcinogenicity).

Chronic Studies

Chronic toxicity (usually conducted by feeding the test substance to the test species) studies are
intended to determine the effects of a substance in a mammalian species following prolonged
and repeated exposure. Under the conditions of this test, effects that have a long latency period
or are cumulative should be detected. The purpose of long-term carcinogenicity studies is to
observe test animals over most of their life span for the development of neoplastic lesions
during or after exposure to various doses of a test substance by an appropriate route of
administration.

Data from Studies that Determine Hazard to Nontarget Organisms

The information required to assess hazards to nontarget organisms are derived from tests to
determine pesticidal effects on birds, mammals, fish, terrestrial and aquatic invertebrates, and
plants, These tests include short-term acute, subacute, reproduction, simulated field, and full
field studies arranged in a hierarchical or tier system that progresses from the basic laboratory
tests to the applied field tests. The results of each tier of tests must be evaluated to determine
the potential of the pesticide to cause harmful effects and to determine whether further testing
is required. A purpose common to all data requirements is to help determine the need for (and
appropriate wording for) precautionary label statements to minimize the potential harm to
nontarget organisms.

Acute and Subacute Studies
The short-term acute and subacute laboratory studies provide basic toxicity information that
serves as a starting point for the hazard assessment. These data are used to:

establish acute toxicity levels of the active ingredient to the test organisms;

compare toxicity information with measured or estimated pesticide residues in the environment
in order to assess potential effects on fish, wildlife, plants, and other nontarget organisms; and
indicate whether further laboratory and/or field studies are needed.

Chronic and Field Studies

Additional studies (L.e., avian, fish, and invertebrate reproduction; life cycle studies; and plant
field studies) may be required when basic data and environmental conditions suggest possible
problems. Data from these studies are used to:


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Q. Asection on herbicide use in the Pinals in the late 1960’s is included in the EA. We could find no
documentation that people died “on the spot”.

R. The 2007 Canadian study this commenter refers to was reviewed, and the major author (Dr.
Frank Gobas) was contacted with questions about his research. This research is based upon
insecticides, which are much more toxic to humans and animals than herbicides. A review of
Risk Assessments for each of the herbicides proposed for use documents research regarding
bioconcentration. The following scenario was used in the risk assessment to estimate
bioconcentration hazard to wildlife and humans: An accidental spill of 200 gallons of a field
solution of the herbicide is spilled into a pond that has an average depth of 1 m anda surface
area of 1000 square meters, or about one-quarter acre . No dissipation or degradation is
considered. The assumption is made that bioconcentration will reach equilibrium. This probably
overestimates exposure and subsequent risk.

Aminopyralid: No bioconcentration

Chlorsulfuron: May accumulate to a slight degree in channel catfish viscera, not muscle tissue,
and only over long-term exposure. Does not bioconcentrate in bluegill. See description of this
herbicide in the EA, and mitigation measures required for its use.

Clopyralid: Does not bioconcentrate. A contaminant that is present at levels of 2.5 parts per
million in technical grade clopyralid in does bioconcentrate. See description of this herbicide in
the EA, and mitigation measures required for its use.

Dicamba: No bioconcentration

Glyphosate: One study showed very low bioconcentration. This was later determined to be due
to the fact that, since radioactivity was used to track glyphosate, it was detecting binding of
glyphosate metabolites, such as mineralized carbon, to fish. All other studies showed no
bioconcentration.

imazapic: No bioconcentration

imazapyr: No bioconcentration

Metsulfuron methy!: No bioconcentration

Picloram: Like clopyralid, picloram itself does not bioconcentrate. The same contaminant that
is in clopyralid is also in picloram, at concentrations of 8-50 parts per million. This contaminant
does bioconcentrate. See description of this herbicide in the EA, and mitigation measures
required for its use.

Sethoxydim: Slightly bioconcentrates in fish — both bluegill and channel catfish. See description
of this herbicide in the EA, and mitigation measures required for its use.

Sulfometuron methyl: No bioconcentration in bluegill. Slight bioconcentration in channel
catfish, in both viscera and edible tissue. See description of this herbicide in the EA, and
mitigation measures required for its use.

Triclopyr: No bioconcentration in fish. Very slight concentration in crayfish and clams.

5. By the same token, all people should be prohibited from entering the Tonto National Forest.
And ail vehicles should be prohibited from travelling on highways through the forest. Vehicles


Project Design Features to Mitigate Potential Effects to Federally-listed and Sensitive Plant and
Animai species on the tonto National Forest, for buffer areas assigned especially to deal with
federally-listed aquatic animals. Also see BAE for buffer areas for federally-listed aquatic species
~ where there is different buffer area, the more restrictive one applies where federailly-listed
species or their habitat is concerned. if there are no federally-listed ar sensitive species in the
aquatic area, herbicides may be applied to water’s edge. When using herbicides close to the
water, aquatic-rated herbicides will be used, No aquatic herbicide treatments are included in
this proposal or assessment.


To Forest Weed ID Team:

Buck
Anne
Karyn
Kathy
Norm
Tammy
Emily
Scott
Vinnie
Mike R.
Bob ‘
Connie
Mike H.

Ce:

Paul

Eddie
Caroline R.

Ihave made copies for each of you, of the comments received on the scoping letter that
was mailed out in May. Not very many, considering the size of the mailing list.

This will give you time to go over them, think about how they will influence our analysis,
and categorize them. At our next meeting (July 21 at 9:30 at the SO), we will
collectively decide which are significant & which are not. We will need to document the
reason for a decision to classify a comment as not significant.

Please review the NEPA schedule. Your Desired Condition and Affected Environment
for your resource should be written by the meeting date (July 21).

We can discuss initial alternatives I will develop, along with possible mitigation
measures & monitoring requirements for each. If the altematives I have come up with
need to be changed, or new ones added, we can do that at this meeting.

I have sent each of you notes about a couple of other NEPA documents that are out (both

EIS’s) that we can use — one for the Santa Fe/Carson, the other for the
Beaverhead/DeerLodge NF. Use them for ideas on how we can do ours.

Patti


G.

mechanical, prescribed burning or flaming, cultural controls such as revegetation with native
species, and biological control. See definition of integrated vegetation management in the
description of proposed action in the EA.

information was added to the EA about glyphosate testing by the EPA. 2,4-D is not being
proposed for use, and 2,4,5-T and Agent Orange (the combination of 2,4-D and 2,4,5-T) are
banned by the EPA for use in this country. The article referred to on the website was outdated
and inaccurate and has been pulled. There is an extensive section in this EA about use of these
chemicals in the Pinal Mountains in the mid to late 1960’s. See Short History of Herbicide Use
on the Tonto National Forest, in the section titled Social Concerns.

This comment is outside the scope of this environmental analysis.

‘The adaptive management section of this EA (Adaptive Management Strategy, in the Proposed
Action section, page 21) allows for the Forest to be able to use new herbicides as they become
available, provided their impacts are equal to or less than herbicides already evaluated. Some
of these newer herbicides are more species-specific, such as one named “MAT 28” (active
ingredient aminocyclopyrachlor) and Matrix (active ingredient rimsulfuron), which prevent
annual grasses from germinating but have no adverse effect on native perennial grasses. (Dr.
John Brock, personal communication)

Herbicides will not be used indiscriminately, but will be spot sprayed to target invasive species.
Invasive species typically are of no use for food or cover to native animals, and tend to crowd
out plants that native animals have evolved with and use. Studies referred to by this
cormmenter were conducted after clearcutting in timber, which is not proposed by this action; in
agricultural situations in Great Britain, and after “heavy use” of herbicides in neotropical
agricultural areas. Agricultural situations are totally different from wildland situations where
the Tonto National Forest will be controlling invasive plants. In crop situations, ail of the plants
that wildlife normally used have been removed and replaced with a crop monoculture. Weedy
plants may provide the only source of food left. The article about agricultural weed control
affecting bird species in Great Britain cites a number of factors that have adversely affected
birds in that country, one of which is removal of weed seeds which have become a primary food
component of some birds. Other factors cited Included draining of wetlands, mowing during
nesting, and removal of hedgerows that provided habitat. Invasive plants on the Tonto NF have
not increased to the point that they are a critical food component of any animal species. One of
the reasons for control of invasive plants is to maintain a healthy habitat (food and cover) for
wildlife species.

See Table 3 in Chapter 2 for a summary of estimated acreage of various types of weed control
far each alternative,


q fo 00 F

Responses to public comments:

A. Criteria that require documentation in an EIS, as opposed to an EA: If an environmental
assessment determines that the environmental consequences of a proposed federal
undertaking may be significant, an EIS is required.

This EA approaches an EIS in its detailed analysis of the proposed action. Also, like an EIS, this
document contains a purpose and need statement, a range of alternatives, a description of the
affected environment, environmental consequences of the proposed action and alternatives, a
list of preparers, and appendix material. Unlike an EIS, this EA documents research and
coordination with other agencies in the development of sideboards that keep environmental
effects to a non-significant level.

Acres that will be treated with herbicides per year was reduced to 5000.

B. This document cites Risk Assessments that have been completed for the range of herbicides
proposed for use. These Risk Assessments are summaries and analyses of research and current
knowledge for each of the herbicides. Much of the literature that was submitted in public
comments was cited in these risk assessments. Further, a Fish and Wildlife Service publication,
Recommended Protection Measures for Pesticide Applications in Region 2 of the U.S. Fish and
Wildlife Service (White 2004 citation in the EA), and informal consultation with the Fish and
Wildlife Service were used extensively to develop sideboards and mitigation measures to
prevent effects to animals and non-target plants.

C. Asection of the EA is devoted to a discussion of vectors of noxious weed dispersal. Measures
that address these vectors are often administrative in nature, or are best addressed in
environmental assessments for specific actions, such as mining plans of operation or allotment
management plans. The focus of this assessment is control of invasive plants once they are
growing on the Forest.

D. According to this comment, the Tonto should suspend all grazing by domestic livestock, whether

it is in infested areas, “ecologically susceptible areas” or areas with intact native vegetation.

This would be the entire Forest. This comment is outside the range of this assessment. Grazing

is addressed in environmental assessments for specific allotments. If invasive plants are an issue

on the allotment, they are described in the “affected environment” section of the EA, and
addressed by one or more alternatives.

This comment is outside the scope of this evaluation.

The Tonto and any permit holder on the Tonto are now required to use certified weed-free hay.

For the last several years, the Arizona Dept. of Transportation has been using only weed-free

mulch for highway projects that run through the Forest. The SW Regional Office of the Forest

Service has determined that a Federal Register notification is an appropriate first step in

development of a weed-free order for all National Forests in the Region. The Tonto has been

directed to wait for a Region-wide closure order, for several reasons: 1) weed-free feed is not
generally available at this time, 2) for consistency, and understanding by the public, it is best for

om


The EA cites another study that found 75% of jointed goatgrass seed that had passed
through a cow’s rumen was still viable (Lyon et al 2003).

While horses are probably not a major vector of weed spread, they are one factor.
Coordination among land management agencies, state agencies and cooperators who
manage weed-free certification, equestrian groups, growers of feed, feed store
operators, and others will be necessary to develop a reasonable and workable program
to prevent weed spread from animal feed.

CC. The Tonto strategy with regard to buffelgrass and fountain grass has been changed in the EA.

DD. This change has been made.

EE. This EA is an evaluation of the local situation on the Tonto. It proposes a strategy that is
economically feasible and ecologically sound. It evaluates the proposal and each of two
alternatives according to effects on human safety, effect on soils, ground and surface water
quality, vegetation communities and fire regimes, invasive plants, wildlife, range management
and heritage resources. The EA uses current scientific data as a basis for evaluation of
alternatives.

FF. See the section on Tonto Strategy for tree of heaven.

GG. Not sure which web site the commenter is referring to. The USDA website,
http://www. invasivespeciesinfo.gov/plants/main.shtml, has a list of noxious weeds. With the
list is a disclaimer: “Listed below are the plant species for which we have completed species
profiles - general information about plant species commonly known as invasive. This is not a list
of all invasive plant species, nor does it have any regulatory implications. These profiles are
provided as an educational informational tool.”

Different areas have different invasive species, so no two state weed lists will be the same. Each
of the national forests in Arizona has a slightly different list. The important thing is that the
entity creating the list has a solid and scientific basis for why species are on that list. The Tonto
list cites the rationale for listing of each species. Many were ranked by a group of weed experts
in Arizona according to a set of objective criteria, such as seed production and dispersal
capability, rate at which local infestations grow, age at which new plants are able to produce
seed, and many other factors.

HH. In the March 2009 issue of the journal Evolutionary Ecology Research, Dr. Rosenzweig, the
editor In the March 2009 issue of the journal Evolutionary Ecology and a professor in the
Department of Ecology and Evolutionary Biology at the University of Arizona, challenged the

revailing view that invasive alien species reduces biodiversity. The exotics increase the number
of species in the environment, he wrote. Even if alien species cause extinctions, the extinction
phase will eventually end and new species may then begin to evolve, he explained. Ecologists
should focus on managing the environments that include exotic immigrants, according to Dr.
Rosenzweig, and creating new ones where necessary to enhance species’ survival and
biodiversity.


The EA states that Best Management Practices will be followed. This includes the requirement
that the certified applicator conducting the spray operation consult weather predictions and
monitor weather during application to ensure the project begins and remains within a
prescription which accounts for terrain and that specifies the following: spray exclusion areas,
buffer zones, and factors such as formulation, equipment, droplet size, spray height, application
pattern, flow rate, and the limiting factors of wind speed and direction, temperature, and
relative humidity.

Spray drift will be minimized by the above practices, and in addition no aerial spraying is
proposed (see description of proposed action, and Issues and Concerns addressed through
Project Design section in the EA).

Sections on safety are included in the EA in the sections on ground water and social concerns.
The environmental consequences section on ground water discusses studies on herbicides
leaching in soil.

Herbicides are designed to kill plants. The following is quoted from a paper on herbicide toxicity
by a Forestry professor at Auburn University (McNabb 1997):

“How can a chemical with such low toxicity be so effective at killing plants? Imazapyr, for
example, has an LD50 above 5,000 mg/kg, making it practically non-toxic. Yet this compound
is a very effective herbicide and can control many of the largest trees. The secret to
understanding this apparent contradiction comes from realizing that herbicides work on
biochemical pathways that are specific to plants. For example, only plants photosynthesize
(produce food from carbon dioxide and water), so, if a compound inhibits one or several of
the steps in the long biochemical pathway that is photosynthesis, that compound is then
toxic to plants. At the same time, this compound may have no effect on animal systems
because the biochemical pathway for photosynthesis does not exist in animals. As another
example, some herbicides work on amino acid pathways that are specific to plants and not
found in animals. All of these types of compounds can be very effective herbicides yet are
safe for animals because the biochemical basis for toxicity does not exist.”

A section on range management environmental consequences was added.

Weed science is the basis for this proposal. More specifically, “integrated Vegetation
Management is a decision-making and management process that uses knowledge from a broad
base of expertise, a combination of treatment methods, and a monitoring and evaluation
system to achieve vegetation management goals. The objective of the IVM process is to achieve
effective, long-term weed prevention and management compatible with both the legal mandate
to contro! noxious weeds and the needs of humans, animals, plants, and environmental
resources at and beyond the treatment site.” {Drlik et al 1998)

Risk Assessments for each herbicide cite extensive scientific research.


K. The following was copied from the Environmental Protection Agency's website section on what
is required for registration of a new pesticide. EPA requires that the producer of the chemical
conduct the studies, but they are to be conducted to scientific standards by accepted
laboratories. http://www.epa.gov/pesticides/regulating/data_requirements.htmistudy_type

Types of Studies Required
The following sections describe the reasons for each type of test and the kind of information

EPA obtains from the results of each test.

Product Performance

Requirements to develop data on product performance provide a mechanism to ensure that
pesticide products will contro! the pests listed on the label and that unnecessary pesticide
exposure to the environment will not occur as a result of the use of ineffective products. Specific
performance standards are used to validate the efficacy data in the public health areas,
including disinfectants used to control microorganisms Infectious to humans in any area of the
inanimate environment and those pesticides used to control vertebrates (such as rodents, birds,
bats, and skunks) and invertebrates (ticks, mosquitoes, etc.) that may directly or indirectly
transmit diseases to humans.

Data from Studies that Determine Hazard to Humans and Domestic Animals

Data required to assess hazards to humans and domestic animals are derived from a variety of
acute, subchronic, and chronic toxicity tests, and tests to assess mutagenicity and pesticide
metabolism.

Acute Studies

Determination of acute oral, dermal, and inhalation toxicity is usually the initial step in the
assessment and evaluation of the toxic characteristics of a pesticide. These data provide
information on health hazards likely to arise soon after, and as a result of, short-term exposure.
Data from acute studies serve as a basis for classification and precautionary labeling. For
example, acute toxicity data are used to calculate farm worker reentry intervals and to develop
precautionary label statements pertaining to protective clothing requirements for applicators.
They also:

provide information used in establishing the appropriate dose levels in subchronic and other
studies;

provide initial information on the mode of toxic action(s) of a substance;

determine the need for child-resistant packaging; and

determine the need to restrict use of the pesticide to trained applicators or in other ways to
minimize human and environmental hazards.

information derived from primary eye and primary dermal irritation studies serves to identify
possible hazards from exposure of the eyes, associated mucous membranes, and skin.


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10

. Monitoring should be conducted for a minimum of 5 years following treatment. There

is no maximum time limit during which vigilance should be maintained.

_ Restoration efforts should also include merely allowing the natives to return after the

invasives have been eliminated. This avoids questions of genetic appropriateness
when replanting is conducted

Coordination, cooperation & education should also include local stakeholders, and not
just agencies & landowners, Volunteer efforts can go a long ways in abatement
efforts, and they also allow activities to proceed without a heavy layer of bureaucracy
stifling them. Stakeholders can also be valuable eyes upon the land, allowing
identification of pests at the earliest possible moment, when eradication is feasible

. Cultural treatment methods should be expanded to specifically include restoration, in

addition to revegetation. Restoration emphasizes the long-term sustainability of
replanting projects, while revegetation may not be sustainable. Restoration also
implies the use of plants that will not become invasive; revegetation projects have
introduced seemingly innocuous plants that have proved over time to be invasive

. Mechanical mitigations may not always need to include seeding of native species.

Cultural mitigations should read “genetically appropriate” native plants will be used
for restoration.
ADOT & FS should cooperate in weed treatments along federal & state highways.

Jurisdiction should be irrelevant, since treatment of infestations is in the interest of
both agencies

E, Vince Lujan, Assistant General Counsel
Fort McDowell Yavapai Nation

Sending response letter, telling us they will send comments within 30 days [of June 15,
2004).

F. Bradley S. Traver, Superintendent
Tonto National Monument
USDI National Park Service

Support for the proposal to control & eradicate noxious weeds & invasive plants

Request written results of our work be made available to them, fo help in their efforts
to eradicate noxious weeds & invasive plants.

Suggest adding the following species to our list, which have been observed on the
Tonto Basin Ranger District in the vicinity of Tonto National Monument:

Russian thistle (Salsola kali)

Horehound (Marrubium vulgare)

Annual yellow sweetclover (Melilotus indicus)


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Appendix L Part 4

Comments from 2012 Comment Period


c. Approves of species list, esp. fountain grass, buffelgrass, salt cedar, Russian olive
& tree of heaven. (ADOT)
d. The list should clearly state that it was made on a certain date, and that invasions
of new species will continue. (MOB)
Nicotiana glauca is not on the list.
f. Suggested additions to the list (these have been identified on the Tonto National
Monument): (TNM)
i. Russian thistle (Sa/sola kali)
ii. Horehound (Marrubium vulgare)
iii. Annual yellow sweetclover (Melilotus indicus)
g. Number of acres of weeds underestimated. * (LH, TWMA)

2

7. Monitoring
a. Should be done for a min. 5 years following treatment. (MOB)
b. Provide written results of our work to Tonto Nat. Monument, to help in their
efforts to eradicate noxious weeds & invasive plants. (TNM)

8. Restoration
a. Should include allowing natives to return after elimination of invasives. (MOB)
b. Cultural treatment should specifically include restoration, in addition to
revegetation. This emphasizes long-term sustainability of replanting projects.
Also implies use of plants that will not become invasive. Use “genetically
appropriate” native plants for restoration. (MOB)

9. Coordination with others
a. Coordination, cooperation & education should include local stakeholders & not
just agencies & landowners. Use volunteers. (MOB)
b. ADOT & FS should cooperate in weed treatments along federal & state highways.
(MOB)
c. Provide written results of our work to Tonto National Monument, to help with
their efforts. (TNM)
d. ANPS recently identified invasive species as their top conservation priority &
supports the TNF in this proposal. (ANPS)
e. Consult the National Invasive Species Council’s Invasive Species Management
Plan, to ensure the proposed noxious weeds management program is consistent with
& helps further the recommendations made in that plan. (EPA)
f. Communicate with other land managers regarding our experiences with eradicating
species on our list & which techniques have proven most effective while minimizing
any unnecessary environmental or biological consequences. (MOB)
g. A communication system should be set up for Indian tribes and other individuals
who gather basket weaving or other materials along transportation & utility corridors
to be notified of when & where spraying will occur. (EPA)
h. EA must show how Forest weed control efforts will be coordinated with other
Jurisdiction weed control efforts immediately adjacent to NF lands. Efforts should be
designed so they are not at cross purposes or overlapping. * (WMI)
i. Seek volunteer labor to attack problem of salt cedar. * (WMI)
j. Identified Tonto Weed Management Area as the key “clearinghouse” for noxious
weed management organization that the FS will work with to manage noxious weeds.
Work with them to map weeds.* (LH)


Tonto NF Proposal for Integrated Vegetation Management
Summary of comments received during scoping, by category
(including comments received during earlier scoping in November 2001)
September 2004

1. Timing of the proposal
a. Deal with the problem before it gets out of control. (JS, WMI)
b. Infestations should be eliminated as soon as identified without further review.
(MOB)
2. Give consideration to cultural & economic factors which allowed noxious weed
infestations in the first place. (YAN)

3. Modern land use practices have resulted in eradicating or setting back several
species of plants used historically by western Apache & Yavapai, such as Emory
Oak. (YAN)

4, Concerns about herbicides

a. Health hazard of chemicals to the public
i. Will there be on-site notification of treated areas? Is use of chemical
defoliants & other contaminants more of a hazard than the existing
problem? (YAN)
ii. Any pesticides should be registered with EPA. Use according to label.
iii. Concerned about surfactants’ toxicity.
iv. Each herbicide has a different potential impact on the environment &
needs to be evaluated separately. (EPA)
vy. Don’t use herbicides. “Don’t forget Pinal Mountain disaster. Many
people died from it”. Use only hand tools. * (PB et al)

b. Aerial application of herbicides - This tool should not be eliminated from
consideration. (JS)

c. Include a section in the document describing chemicals, their characteristics,
registration status, potential toxicity to the environment, exp. aquatic organisms,
& sites/pests for which they are registered. (EPA)

d. Concemed about potential effects of herbicide use on aquatic systems and
sensitive T&E species habitat. Use measures set out in EPA “Interim Measures”
pamphlets by county.(EPA)

e. Concern about application of herbicides along SR88 & SR188 drifting onto Tonto
Nat. Monument * (TNM)

f. Number of acres treated each year should be more like 1000 — 2000 than for 100 —
200. * (LH)

5, Concerns with burning of weeds
a. Burning may not meet air quality standards, may affect ambient conditions, and
may have air quality impacts. (EPA)
b. Burning weeds within areas with approved air quality implementation plants
(non-attainment areas) must meet CAA requirements (EPA)

6. Comments relating to the weed list
a. Control of brome grasses may be ver
OK to include experimental control
of jointed goatgrass is considerabl
though]

‘ficult if not impossible to accomplish.
s.(J8)

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A. Jim Sprinkle
Gila County Cooperative Extension

1, Supports the proposal to deal with the weed problem before it gets out of control

2. Eliminating aerial application of herbicides from this proposal may reduce the
effectiveness of control measures.

3. Control of brome grasses may be very difficult if not impossible to accomplish. This is
not to say that experimental control of Bromes should not be attempted.

4. Estimated acres of jointed goatgrass is probably considerably underestimated. The entire
valley of Pine and Strawberry & probably other communities in the higher elevations of
the Tonto are infested by this species. It has probably spread into meadows in the NF
surrounding these communities.

B. Jackie LeNoble
ADOT
1. Approves of list of target species for control. Especially fountain grass, buffel grass,
salt cedar, Russian olive, and Tree of Heaven

C. Vincent Randall & Chris Coder
Yavapai-Apache Nation
l. Has any consideration been given to cultural & economic factors which allowed
noxious weed infestations in the first place?

2. Several species of plants used historically and prior to contact by Western Apache &
Yavapai have been virtually eradicated or severely set back by modern land use
practices. Cattle have had a negative impact on Emory Oak.

Concerned that people gathering various plant materials along roadsides within the

forests could come in contact with dangerous chemical compounds or residual toxins
and be poisoned. ~ Will there be on-site notification of treated areas within the project

area?

we

4. Is the FS satisfied that use of multiple chemical defoliants and other potential
contaminants is not more of a hazard than the problem as it now stands?

D. Michael L. O’Brien
Landscape Architect in Los Angeles, CA
1, The list of invasive plants should clearly state that it is a list as of a certain date, and
that invasions will continue.

Nicotiana glauca is not on the weed list

— even one individual of a fo
hey are identified, without fur

3. Infestati
minute that

ecies — should be attached (sic) the
eview being necessary


AA.

BB.

are known to transport weed propagules. Domestic livestock are one possible vector of spread
of weeds. There are many others, such as hikers, hunters, wildlife, mountain bicyclists, off-
highway vehicles, river rafters, outfitter-guides using horses and mules, equipment operators
who are maintaining roads, to name a few. These are all valid uses of the public lands.
Mitigation measures are recommended to prevent spread from each of these activities.
Definitions have been added to the EA’s Background chapter, and also to Appendix B, Acronyms
and Terms. The objective of this proposal is to remove those plants which are termed invasive;
in other words, those that cause ecological harm. Although many invasive plants are non-
native, not all non-native plants are invasive. Nearly all of the listed noxious weeds for the
Tonto National Forest are non-native plants.

2,4-D is not proposed for use.

Prescribed fire will only be used when conditions fall within prescriptions that are set for safety
and to protect environmental resources.

. Responded to this commenter, telling her we would give her time to submit comments. She

never sent further comments.
The commenter provides no documentation of this statement. Soil microorganisms that break

down chemicals exist at 5500’ elevation in Antarctica. There are doubtless microorganisms in
Arizona at elevations over 4000’ that do the same. While herbicides break down more slowly in
dry or cold soils, or those without much organic material, there are microbes in soils that will

break down herbicides.

The proposal and detailed description of Tonto strategy for each noxious weed species comprise
a comprehensive plan for weed management on the Tonto National Forest.

See Tonto strategy for contro! of Vinca populations, in Chapter 3.

Acreages were added to the proposal to reflect the greatest number of acres anticipated
annually for all treatment methods.

A representative of the Arizona Horseman’s Society commented that they had current and
scientific evidence that any noxious weed that is eaten by a horse is not viable after it passes
through the horse's digestive tract. None of this evidence was submitted.

A literature search found the following articles, presentations, and websites that had
information and cited studies that contradict this statement.

http://www. frontrangefrenzy.com/horse-information/horse-manure-management.html -- A
commercial horse owner and care site from the Front Range in Colorado:
“One of the disadvantages of using non-composted horse manure is that it is more likely
to contain weed seed and/or pathogens “

http://www.canr.uconn.edu/ansci/ext/manuremanagement.htm -- This website is from the
Department of Animal Science, University of Connecticut:
“Composting is a way to handle manure that should be considered. Composting will
increase the value of manure, kill parasites and weed seeds, and decrease the volume of

waste.”


Appendix L Part 1

Comments from 2001 Scoping


6. Recommend consulting the National Invasive Species Council’s Invasive Species
Management Plan, to ensure the proposed Noxious Weeds Management Program is
consistent with and helps further the recommendations made in the Plan.


G. Carianne Funicelli, Conservation Committee Chair
The Arizona Native Plant Society

1. ANPS Conservation Committee has recently identified invasive species as their top
conservation priority, and supports the TNF in this proposal.

2. Request that the TNF presents species-specific management guidelines that are based
on the biology and phenology for each species. In order to do this, will need to
communicate with other land managers regarding their experiences with eradicating
these species & which techniques have proven most effective while minimizing any
unnecessary environmental or biological consequences.

H. Amy Mikailov

1. No more read closures of any kind, except temporary fire danger closures. Wants
roads left open for 4WD enthusiasts to use

I. Laura Fujii, Federal Activities Office
US Environmental Protection Agency, Region IX in San Francisco, CA
1. Any pesticides used must be registered with EPA. Sites & pests for the intended use
must also be on the pesticide label. The pesticide must be used in accordance with
label directions.

i)

. Of specific concern are potential effects of herbicide use on aquatic systems and
sensitive, T& E species habitat. Active ingredients in Rodeo (glyphosate) and
Arsenal {imazapy) have very low aquatic toxicity to fish & invertebrates, Active
ingredients of other identified herbicides may not

3. Of additional concern are unidentified surfactants, since there are surfactants more
toxic than identified active ingredients (for example, certain alkyl/arylphenols).

4. NEPA document should include a speciFic section describing the control chemicals
which may be used. This section should describe the characteristics of the chemicals,
their registration status, their potential toxicity to the environment, esp. aquatic
organisms, and the sites/pests for which they are registered. Chemical compounds
should be evaluated separately and not lumped. For instance, provide a separate
evaluation for different types of surfactants such as alkylphenols and arylphenols.

PA document should provide a discussion of air quality standards, ambient
‘onditions, and potential air quality impacts for the noxious weeds management
program, Cumulative & indirect impacts should be evaluated. Federal agencies are
required by the Clean Air Act to assure that actions conform to an approved air
quality implementation plant. If the proposed project area is in a nonattainment area,
the FS may need to demonstrate compliance with conformity requirements of the
Clean Air Act [Section 176©]. General Conformity Regulations can be found in 40
CFR Parts 51 & 93 (58 Federal Register, page 63214, Nov. 30, 1993). These
regulations should be examined for applicability to the proposed project

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10. Comply with laws

Comply with EPA in use of pesticides. (EPA)

Clean Air Act (Section 176c, if the project area is in a nonattainment area. (EPA)
General Conformity Regulations — 40 CFR Parts 51 & 93 (EPA)

Maricopa County Rules 310 & 310.01 regarding air contaminants & dust (ADEQ)
Arizona Administrative Code R18-2-604 through 607 & Article 15, Forest &
Range Management of Title 18 Chapter 2. (ADEQ)

eee oF

11. Use species-specific guidelines (base treatment on biology & phenology for each
species) (MOB)

12. Do not close any roads. Leave them open for 4WD enthusiasts. (BAM)
13. List of adaptive management practices lacks controlled burning. * (TWMA)

14. There is a lack of leadership on the Tonto to accomplish the EA and weed control. *
(TWMA)

15. Ground Disturbance
a. Methods to combat weeds should not result in significant soil disturbance &

create a bigger weed invasion problem. * (WMD

* Comment received from first scoping letter in 2001.

Key to abbreviations for commentors:

ADEQ Az. Dept of Environmental Quality

ADOT Jackie LeNoble, Az. Department of Transportation

ANPS Carianne Funicelli, Arizona Native Plant Society

BAM Bill & Amy Mikailov

JS Jim Sprinkle, University of Arizona

LH ** Larry Howery, University of Arizona

MOB Michael O’Brien

PBetal ** Peter Bigfoot, Jeremy Maxwell, Dexter Gillett, Jatta Morris, & Hirsh Jans
TNM Bradley Traver, Tonto National Monument

TWMA ** Tonto Weed Management Area
WMI ** Len Carpenter, Wildlife Management Institute
YAN Vincent Randall & Chris Coder, Yavapai Apache Nation

** Commented in 2001; no comments received from scoping in 2004.


N.

all Forests to initiate closure orders at the same time, 3) publication in the Federal Register
allows for public comment, and 4) there are many facets to weed-free closure orders, and the
issue is complex. The Forests need time to work with their publics to develop closures that will
be logistically feasible and comprehensible.

in May 2009, the Regional Office issued a Manual Supplement (R3 Supplement 2000-2009-1)
requiring that Forest Service personnel and their contractors use only certified weed-free hay
and seed on the National Forest. Use of weed-free products by the Forests and their
contractors should help to build up a demand so that feed stores will begin to carry the product

Off-road vehicle use is cited in the Vectors section as one activity that has great potential to
spread invasive plants. The EA states that an environmental assessment for Forest-wide travel
management is being conducted at this time.

Herbicides are tested on representative species. Results from these species are extrapolated to
other animals. It is not practical or even possible to conduct herbicide trials on every species.
Risk Assessments and the Fish and Wildlife Service document referred to in Response A evaluate
testing on a wide variety of organisms, including mammals, birds, amphibians, fish, aquatic
plants, terrestrial plants, invertebrates, and soil microorganisms.

Also see sections in the EA on Wildlife.

All references to the 1992 Bonneville Risk Assessments have been deleted.

2,4-D is not on the list of herbicides proposed for use. Dicamba is a widely used non-restricted
herbicide. it will be used according to label instructions by certified applicators. Both 2,4-D and
dicamba are on the list of herbicides used on every other National Forest in Arizona, and also
along Arizona Dept. of Transportation rights-of-way through all Arizona National Forests.
Cumulative effects to each of the following resources was analyzed: soil; water quality;
vegetation, including invasive plants, endangered, threatened, candidate and sensitive plants;
fire regimes; range management; wildlife, including neotropical migratory birds, endangered,
threatened, proposed, candidate and sensitive fish and wildlife; social concerns; heritage
resources, including archeological resources and native American plant gathering traditions;
wilderness; roadless areas, and environmental justice. See section on environmental
consequences.

A list of the Tonto invasive species is included in Chapter 3. Information was added in the
section on noxious weed strategy for each weed, describing what control measures have been
conducted on the Tonto to date, and their success.

. Biocontrol agents are not proposed for use on salt cedar.

Mitigation measures are explained in detail in the Biological Assessment and Evaluation. These
measures are based upon extensive research, as documented in Risk Assessments that have
been completed for each herbicide. They were also developed using as guidance the Fish and
Wildlife Service document Recommended Protection Measures for Pesticide Applications in
Region 2 of the U.S. Fish and Wildlife Service.


The Agency can estimate the amount and nature of residues likely to be present in food or
animal feed because of a proposed pesticide usage by evaluating information on:

the chemical identity and composition of the pesticide product;
the amounts, frequency, and time of pesticide application; and
test results on the amount of residues remaining on or in the treated food or feed.

Older studies were cited in the section of the document that discusses historical herbicide use
on the Tonto, especially in the situation in the foothills of the Pinal Mountains south of Globe.
Risk Assessments that summarize scientific knowledge about each of the herbicides proposed
for use are current: publication dates for these documents are from 2001 to 2011. See
Appendix F.

. Cultural vegetation management is one of the tools proposed in this assessment. If use of
herbicides or manual removal is anticipated to leave large areas of bare ground, revegetation
with native species is an option, In most cases, weeds are not so dense that revegetation is
necessary.

. Weed species proposed for biocontrol are starthistles, knapweeds, bull thistle, and toadflax.
While some of these plants may grow in riparian areas, they are mainly upland species. Effects
of non-treatment of these species are widely and well understood ~ their populations spread,
replacing native plants.

. A total of 68 weed species are listed in the EA. The Forest has proposed use of biocontrol agents
for six of them. Release sites will be selected that are near large dense populations of the target
weed. The Forest will work with experienced professionals at APHIS (Animal and Plant Health
Inspection Service), the agency who regulates biocontrol agents, in selecting release sites and
monitoring them. This information was included in the BAE. After this comment was received,
the table with this information was copied into the EA.

Timing is critical to effective use of herbicides. For forbs, grasses, and shrubs, herbicides must
be applied when plants are actively growing but before they initiate flowers or fruit
development. Trees are best treated when they are translocating fluids to their roots in the fail.
Limiting use of herbicides to the dry season would render most of them ineffective, as plants
must be actively growing to absorb and translocate the chemical. Most herbicides proposed for
use have little residual effect, although it has recently been found during herbicide trials that
Milestone VM has some residual effect on germination of starthistle seedlings the year following
application. The herbicide glyphosate (active ingredient In Round Up) is inactivated when it hits
the soil.

Treatment of Arundo is not discussed in the BAE because there are no effects to federally-listed
species from any treatment proposed for Arundo.


R. ADOT is instructed not to use dicamba at stream crossings; this is a mitigation clause included
on every Pesticide Use Proposal,

S$. This report is cited in the EA,

T. issues will also continue due to presence of people, vehicles, wildlife, presence of nearby
communities, wildfire, road construction, and countless other potential vectors of weed
introductions. See the section on vectors. Activities such as these are dealt with by using
mitigation measures to reduce probability of weed propagule introduction. See section entitled
Vectors of Spread, in the section on Invasive Plants Affected Environment, page 99.

U. We are not proposing to return the landscape to the way it looked at any specific point in time.
What this assessment is about is a decision to remove species that did not evolve with the
ecosystems they are in, if they are disrupting ecclogical processes or causing problems, such as
livestock/wildlife poisoning, replacement of plants required by wildlife for food and/or cover, or
providing a fine fuel groundcover to carry an intense fire through the Sonoran desert.

V, See Table 6 for half-life of each herbicide.

Sprayer tanks will not be filled by creek, lake, spring, seep, or stock tank water. These water
sources are far too dirty to use for mixing herbicides.

=

X. The Forest does not support this either.

y. The document is programmatic. It was written to describe the various methods that may be
used to contro! the range of weeds we anticipate seeing on the Forest over the next 10 years.
Built-in mitigation measures and sideboards, along with monitoring and adaptive management
to select from the range of integrated vegetation management tools will create a responsive
program to be able to quickly control infestations while they are still small, while protecting
associated resources. USFWS requested a sample year of projects during the consultation
process — this was not meant to stand as a permanent listing of weeds that will be treated in any
one year. It is the nature of weeds to establish unexpectedly, and the FS must be able to act
quickly to control small infestations as they are found.

Z. The Forest Hydrologist and Forest Soil Scientist have agreed that water tables of 40 inches or
shallower in the area of the Tonto National Forest are indicated by riparian plant species.
Distance above and below habitat for various fish species where buffer zones will be used will
be determined by the Forest Fish Biologist. Riparian buffers for other wildlife species habitat
will be determined by forest biologists.


JJ.

KK.

In another paper Dr. Rosenzweig explored claims of reduced biodiversity resulting from invasive
species. He stated that any reduced biodiversity is not necessarily a bad thing. “The words
‘good’ and ‘bad’ constitute value judgements and so lie beyond the bounds of science. If what
we do were to turn the whole Earth into a cinder, no science could judge that a bad outcome.
Were exotic species to reduce diversity by 30%, no ecologist could test whether that loss of
species would be a bad thing.”

In his conclusions, however, he does state: “Finally, | note that individual exotic species have
certainly created problems for ecosystems and for human beings, problems that have nothing to
do with diversity at any level. Undeniably, some exotic species have done and are doing
substantial, objective ecological damage.” And: “Exotic species may not threaten overall
species diversity, but they have proven again and again that we have other reasons to fear
them.”

These articles have not been dismissed by the Forest Service as not relevant. They give the
broad view of a developmental ecologist on the issue of invasive species. He calls for weed
management to be based upon objective science rather than value judgments. He also
recognizes that some plants cause ecological damage. This EA strives to establish an objective
strategy for dealing with those plants that are causing problems on the Tonto, or those that
have shown that they cause problems in areas that neighbor the Forest.

This suggestion was added in the section on Desired Condition. Coordination with all
landowners in the vicinity of the Tonto National Forest (this includes grazing permittees, since
they are required to own base property) is listed as a part of the proposed action. Coordination
with other agencies is also mentioned in the proposed action description.

Revegetation is included as a part of the proposed action.

The commenter is correct. Release of dioxin from forest fires is not a commonly known
phenomenon. Dioxin is a class of compounds which vary greatly in toxicity. The report cited
below does not differentiate among which dioxins are released during forest fires.

The study is described in detail on the website:
http://www.dioxinfacts.org/sources_trends/forest_fires.html

it states that “new research suggests that forest fires are a major and natural source of dioxins.
in fact, in 2002, forest fires probably emitted nearly as much dioxin to the environment as did all
other Environmental Protection Agency (EPA)-quantified sources combined.” The study cited is:

Gullett, B.K. and Touati, A. (2003). PCDD/F emissions from forest fire simulations, Atmospheric
Environment 37, p. 803-13.

The study demonstrates that dioxin emissions from forest fires originate predominantly from
biomass combustion, and not simply from the vaporization of dioxin compounds bound to

vegetation.
Any prescribed burning of weed infestations is very small scale. If anything, conducting small
scale burns to reduce weed infestations could prevent occurrence of larger wildfires caused by

accumulation of invasive plants.

Prevention of dioxin release through forest fires is beyond the scope of this analysis.


Appendix L Part 2

Comments from 2004 Comment Period


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Some of the scientific names of noxious weeds listed in the proposed action letter are
misspelled.

6. Tonto Weed Management Area (Shawn Evans)

The Forest underestimated acres of noxious weeds in its proposed action letter.
The list of adaptive management practices lacks controlled burning.

Lack of leadership on the Tonto to accomplish the EA and weed control.
Treatment of noxious weeds is an urgent problem, which the Forest has
underestimated.


estimate the potential for chronic effects, taking into account the measured or estimated
residues in the environment; and

determine if additional field or laboratory data are necessary to further evaluate hazards.
Simulated field and/or field data are used to examine acute and chronic adverse effects on
captive or monitored fish and wildlife populations under natural or near-natural environments.
Such studies are required only when predictions as to possible adverse effects in less extensive
studies cannot be made, or when the potential for harmful effects is high.

Post-Application Exposure Studies

Data required to assess hazard to farm employees resulting from reentry into areas treated with
pesticides are derived from studies on toxicity, residue dissipation, and human exposure.
Monitoring data generated during exposure studies are used to determine how much pesticide
people may be exposed to after application and to establish how long workers must wait before
reentering a treated area.

Applicator/User Exposure Studies

EPA requires applicator/user exposure data for all pesticides to evaluate the potential risks to
people applying the pesticide, i.e., those who may be exposed to higher concentrations of the
pesticide through handling, including mixing or applying.

Pesticide Spray Drift Evaluation

Data required to evaluate pesticide spray drift are derived from studies on the range of droplet
sizes and spray drift field evaluations. These data contribute to development of the overall
exposure estimate. Along with data on toxicity for humans, fish, and wildlife, or plants, data on
spray drift are used to assess the potential exposure of these organisms to pesticides. A purpose
common to all these tests is to provide data to help determine the need (and appropriate
wording) for precautionary labeling to minimize the potential harm to nontarget organisms.

Environmental Fate
EPA uses the data generated by environmental fate studies to:

assess the presence of widely distributed and persistent pesticides in the environment that may
result in loss of usable land, surface water, ground water, and wildlife resources;

assess the potential environmental exposure of other nontarget organisms, such as fish, wildlife,
and plants, to pesticides; and

help estimate expected environmental concentrations of pesticides in specific habitats where
threatened or endangered species or other wildlife populations at risk are found,

Residue Chemistry

EPA uses residue chemistry data to estimate the exposure of the general population to pesticide
residues in food and for setting and enforcing tolerances for pesticide residues in food or feed.


http://equineextension.colostate.edu/content/view/170/57/ -- A website of Colorado State
University Dept. of Animal Sciences:
“Manure has contributed to weed problems where it has been applied to

cropland. Use composted manure to avoid these problems.”

Dominican University of California article, describing a study being conducted to
determine if noxious weed seeds germinate from horse manure, at the website

http: //www.dominican.edu/dominicannews/weeds.html:

This study found that seeds did germinate from horse manure. “Of 90 pots, 34
plants germinated in 21 pots of which 12 represented dry and nine represented wet
samples respectively.” None of the plants happened to be noxious weeds. While
these results may prove that noxious weed seeds, unlike other plant seeds, do
not survive the digestive tract of a horse, it more probably indicates that the
horses had not consumed noxious weed seeds prior to this study.

http://www.cal-ipc.org/symposia/archive/pdf/2006/EDQuinn.pdf This website contains a
powerpoint presentation, “Does Horse Manure Harbor Invasive Plants?”, about the study
conducted by Quinn, Davis, Kolipinski and Ghosh at the Dominican University of California.

information given:
“Equestrian trails in Illinois had more weeds than trails that didn’t allow horses”

“In one Montana study, equestrian camps had greater invasive plant cover than
backpacker camps, but another study showed no difference.”

“In a diet manipulation study, 23-45% of weed seeds germinated after digestion [by
horses]”

Manure collection studies showed the following:
23 non-native species in an Illinois study

29 non-native species in an Australian study

10 non-native species in a Colorado study

in the authors’ study in the San Francisco area, four species on the California Invasive
Plant list germinated from horse manure. In a second trial, 10 species on the list
germinated. Their conclusion: “Yes, invasive plants can germinate after passing through
a horse gut.” They recommended an MOU between federal and state agencies
requiring use of certified weed-free feed.


Summary of Comments on Forest-wide Integrated Weed Management Proposal
Dated November 2001

1. USDI National Park Service, Tonto Nat. Monument (Lee Baiza, Superintendent)

They are about to finish 5-year project of mapping non-native plants within the

monument.
Concern about application of herbicides along SR88/188 & drift onto the monument.

2. Wildlife Management Institute (Len Carpenter, SW Field Representative)

It is important the Forest take an aggressive approach.

It is important that the method chosen to combat weeds does not result in significant
soil disturbance & thus create a bigger weed invasion problem.

Critical that sufficient human and fiscal resources be allocated to the problem so that
progress can be made.

EA must indicate how the Forest weed control efforts will be coordinated with other
jurisdiction weed control efforts immediately adjacent to NF lands. E fforts should be
designed so they are not at cross purposes or overlapping

Encourages the Forest to seck volunteer labor to help attack the problem of salt cedar

& plants like it.

3. Peter Bigfoot, Jeremy Maxwell, Dexter Gillett, Jatta Morris (sp?), Hirsh Jans
(sp?)

Don’t forget Pinal Mtn disaster. Opposed to mass poisoning. If it’s a small

infestation, use hand tools. It it’s too big for hand tools, it’s too big to safely spray.

Don’t use herbicides. “Just because an herbicide is said to be approved does not

convince us that it is in fact harmless. The herbicide on Pinal Mtn. was ‘approved’

also. Many people died from it.”

4, U of A Cooperative Extension, Gila County, Payson Office (Jim Sprinkle)

In support of the proposed action, including use of herbicides.

# of acres to be treated each year should be more like 1000-2000 (proposal was for
100-200)

FS underestimated # of acres currently infested.

Aggressive suppression efforts should be considered.

Chris Jones, Shawn Evans, Larry Howery, Lufkin Hunt, Ron Christiansen, & Jim
Sprinkle never received a copy of the proposal. A cc was sent to Bill Frost, formerly
of Gila County Extension, who has not lived in Gila County since 1995.

5. UofA (Larry Howery)

Did not receive a copy of the proposal.

Identify the TWMA as the key “clearinghouse” noxious weed management
organization that the USFS will work with to manage noxious weeds on the Tonto.
The proposal underestimates the numiber of acres that are infested by noxious weeds.
Work with the TWMA to map weeds in the project area.


A

Responses to public comments

Malta starthistle is classified as a “C” species on the Tonto National Forest (see Table 1). This
means that this species has probably spread beyond our ability to totally eradicate it. While it is
still a high priority to contain this plant where it currently grows, and reduce the number and
size of infestations, it is not realistic to claim that we will be able to eradicate it from the Forest
over the next 10 years.

Signing an area to be sprayed with herbicides gives the public the option of avoiding the area if
they are sensitive to those chemicals, or choose not to be in the area where herbicides are
applied for any reason.

This document cites Risk Assessments that have been completed for the range of herbicides
proposed for use. These Risk Assessments are summaries and analyses of research and current
knowledge for each of the herbicides. Much of the literature that was submitted in public
comments was cited in these risk assessments. Further, a Fish and Wildlife Service publication,
Recommended Protection Measures for Pesticide Applications in Region 2 of the U.S. Fish and
Wildlife Service (USFWS 2007 citation in the EA), and informal consultation with the Fish and
Wildlife Service were used extensively to develop sideboards and mitigation measures to
prevent effects to animals and non-target plants.

The five other National Forests in Arizona have been applying herbicides for up to 12 years, with
no reports of adverse health effects to humans or wildlife (personal communication with Jason
Stevens, Kaibab NF Noxious Weed Program Manager; Laura Moser, Coconino NF Noxious Weed
Program Manager; Sharon Biedenbender, Coronado NF Noxious Weed Program Manager,
Mitchel White, Apache/Sitgreaves NF Forest Planner). On the Prescott NF, one person
complained that the Forest was using backpack sprayers too close to their residence (Kelly
Spleiss, Prescott NF Noxious Weed Program Manager)

Best Management Practices will be followed, that include: “Require all herbicide applicators to
use appropriate personal protective equipment (PPE).” Required PPE is stated on each
herbicide label. FS applicators often wear more than is required.

Causes and increasing spread of noxious weeds on the Tonto National Forest are considered in
sections of the EA titled “Adaptive Management Strategy”, and the section under Invasive Plants
titled “Vectors of Spread”.

A full range of treatment options for noxious weed control were considered in the proposed
action, and one of the alternatives considered all control options except the use of herbicides.
The proposed action calls for a strategy called “integrated vegetation management” , which
provides for use of the most efficient control method available. Tools available include manual,


LL. Programmatic weed management plans such as this proposal are in effect for most national
forests, and many states. They provide a strategic framework to manage weed infestations,
rather than addressing each situation piecemeal.

Even with the limited program on the Tonto, we have had some success with controlling weeds:
--A 2-acre Dalmatian toadflax infestation at the Payson Ranger District hot-shot base has been
significantly reduced after several years of manual control and one year of herbicide treatment
--A Malta starthistle infestation at the Cave Creek Ranger District horse pasture has been nearly
completely controlled, over a period of years of both manual and herbicidal control.

--The Town of Star Valley used both manual and herbicide treatments to remove yellow
starthistle from many acres of road right-of-way through town. The town educated
homeowners, who were provided with bags to contain yellow starthistle plants from their
property. The Forest Service and a volunteer group managed a site where homeowners could
deliver these bags of weeds for burning.

--An infestation of Dalmatian toadflax in the right-of-way of State Highway 87 from Payson to
Rye has been significantly reduced through joint efforts of the Forest Service and ADOT, over a
period of many years. Most of the control was done with herbicides. Some manual control has
also been done.

The key to success of a programmatic plan such as ours (in addition to sufficient funding, of
course) is persistence. Once work has begun on a weed infestation, work must continue year
after year until it is completely gone.

Drlik, T., |. Woo, and S. Swiadon, Editors. 1998. Integrated vegetation management guide. Bio-Integral
Resource Center, Berkeley, CA. 16pp.

McNabb, Ken. 1997. Environmental Safety of Forestry Herbicides. ANR-846, Auburn University


Appendix L Part 3

Comments from 2007 Comment Period


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