Biological Assessment/Evaluation

Of the Integrated Treatment of Noxious or 

Invasive Plant Program for the 

Tonto National Forest

U.S. Forest Service

Southwestern Region

Tonto National Forest

Gila, Yavapai, Maricopa & Pinal

Counties, Arizona

Contact Person: 

Gregg Dunn

Tonto National Forest

28079 N. AZ Hwy 188

Roosevelt, AZ 85545

(928) 467-3218

June 4, 2012

Table of Contents

Summary................................................................................................................. 1

Introduction............................................................................................................. 3

Legal and Regulatory Framework.............................................................................................. 3

Consultation History .................................................................................................................... 5

Description of the Proposed Action........................................................................... 7

Summary of Treatments ............................................................................................................ 17

Conservation Measures (Project Design Features).............................................................. 17

Herbicide Risk Assessment:..................................................................................................... 21

Project Area Description.......................................................................................... 24

Effects of the Proposed Action on Threatened, Endangered, and Proposed 

Species.................................................................................................................. 29

Arizona Cliffrose (Purshia subintegra) ................................................................................... 29

Arizona Hedgehog Cactus (Echinocereus triglochidiatus var. arizonicus)...................... 30

Yuma Clapper Rail (Rallus longirostris yumanensis) .......................................................... 41

Mexican Spotted Owl (Strix occidentalis lucida)................................................................... 41

Yellow-billed Cuckoo (Coccyzus americanus occidentalis)............................................... 46

Lesser Long-nosed Bat (Leptonycteris curasoae yerbabuenae)....................................... 47

Chiricahua Leopard Frog (Rana chiricahuensis).................................................................. 48

Northern Mexican garter snake (Thamnophis eques megalops) ....................................... 51

Desert Pupfish (Cyprinodon macularius macularius).......................................................... 52

Gila Chub (Gila intermedia)....................................................................................................... 52

Headwater Chub (Gila nigra)..................................................................................................... 55

Spikedace (Meda fulgida).......................................................................................................... 56

Woundfin (Plagopteris argentissimus) ................................................................................... 58

Gila Topminnow (Poeciliopsis occidentalis occidentalis)................................................... 58

Colorado Pikeminnow (Ptychocheilus lucius)....................................................................... 59

Loach minnow (Tiaroga cobitis)............................................................................................... 60

Razorback Sucker (Xyrauchen texanus) ................................................................................ 62

Impacts from Biological Control Agents to Listed Plants within Arizona........................ 65

Cumulative Effects...................................................................................................................... 69

Literature Cited and other Reference Materials............................................................ 71

Appendix 1............................................................................................................. 85

Biological Assessment of the Integrated Treatment of Noxious Plant Program Page 1

Summary

Tonto National Forest proposes to remove non-native plants through the use of herbicide, manual, 

mechanical, and biological methods. In addition, we plan to restore areas that are barren as a 

result of the proposed removal methods through the use of seeding and erosion control. The 

project area is located within Tonto National Forest, Arizona.

We have determined that the proposed action will have the effects for the species and critical 

habitats shown in table 1. 

Table 1. Proposed action effects on species and critical habitats

Species/Critical Habitat Forest Service Determination

Arizona cliffrose Likely to adversely affect

Arizona hedgehog Likely to adversely affect

Chiricahua leopard frog Not likely to adversely affect

 Chiricahua leopard frog proposed critical

 Habitat Not likely to adversely affect

Colorado pikeminnow (non-essential experimental 

population) Not likely to adversely affect

Desert pupfish Not likely to adversely affect

Gila chub Not likely to adversely affect

 Gila chub critical habitat Not likely to adversely affect

Gila topminnow Not likely to adversely affect

Lesser long-nosed bat Not likely to adversely affect

Loach minnow Not likely to adversely affect

 Loach minnow proposed critical habitat Not likely to adversely affect

Mexican spotted owl Not likely to adversely affect

 Mexican spotted owl critical habitat Not likely to adversely affect

Razorback sucker Not likely to adversely affect

 Razorback sucker critical habitat Not likely to adversely affect

Southwestern willow flycatcher Likely to adversely affect

 Southwestern willow flycatcher critical habitat Likely to adversely affect

 Southwestern willow flycatcher proposed critical habitat Likely to adversely affect

Spikedace Not likely to adversely affect

 Spikedace Proposed Critical Habitat Not likely to adversely affect

Woundfin Not likely to adversely affect

Yuma clapper rail Not likely to adversely affect

Biological Assessment of the Integrated Treatment of Noxious Plant Program Page 3

Introduction

The spread of invasive species threatens the health of native ecosystems by causing changes in 

the composition and functioning of native plant communities that are the foundation for native 

ecosystems. According to a recent survey by the U.S. Department of the Interior, noxious weeds 

have invaded over 17 million acres of public lands in the West, more than quadrupling their range 

from 1985 to 1995 (Westbrooks, 1998). When invasive species such as cheatgrass, red brome and 

medusahead are included, there are 100 million acres of moderately to heavily infested land. A 

report assembled by 17 different federal agencies (the Federal Interagency Committee for the 

Management of Noxious and Exotic Weeds) concluded that non-native species pose an ongoing 

threat to nearly two thirds of all endangered species (Westbrooks, 1998). Only direct habitat 

destruction poses a greater threat to federally listed species. 

Invasive plants have characteristics that permit them to rapidly invade and dominate new areas, 

out-competing other vegetation for light, moisture and nutrients. Invasive plants are often spread 

by human activities associated with vehicles and roads, agricultural practices, urban development, 

contaminated livestock feed, contaminated seed, and poor range management practices (Belsky 

and Gelbard, 2000). 

The Tonto National Forest is proposing to implement a 10-year forestwide invasive exotic (nonnative) plant management program. The purpose of the proposed action is to protect native plant 

communities on the forest by preventing the introduction of invasive exotic plants and controlling 

or eliminating existing populations of invasive exotic plants. This action is needed because of the 

occurrence of invasive exotic plants on and adjacent to the forest, and to meet the requirements of 

law, regulations and policy. 

Legal and Regulatory Framework

The Federal Noxious Weed Act (7 U.S.C. § 2801-2814) and Executive Order 13112 authorize 

Federal agencies to initiate control and eradication actions against incipient infestations of 

invasive exotic species that are introduced into this country. Further, the Endangered Species Act 

of 1973 (ESA) requires Federal agencies to utilize their authorities to conserve endangered and 

threatened species and to insure that any action authorized, funded or carried out is not likely to 

jeopardize the continued existence of listed species (ESA Section 7(a)(1) and 7(a)(2)). Federal 

actions such as noxious weed and invasive species eradication or control projects must be 

analyzed to determine the potential environmental consequences (National Environmental Policy 

Act of 1969). An Environmental Assessment (EA) for this program has been prepared. This 

Biological Assessment and Evaluation (BAE) addresses the effects of the EA proposed action on 

Federally listed and proposed threatened and endangered species and Forest Service Sensitive 

Species. 

This action responds to the following goals and objectives outlined in the Tonto National Forest 

Plan. 

Hazard Protection: “Through integrated pest management, manage resources to prevent or 

reduce serious, long lasting hazards.” 

Noxious weed infestations can be a hazard to human and animal health. Some species increase 

fire occurrence in ecosystems that are otherwise not adapted to frequent fires, subjecting forest 

users in desert areas, and residents who live nearby to increased hazard from wildfires. Other 

weeds, such as Russian knapweed and yellow and Malta starthistles, are toxic to horses.
Appendix J

Page 4 Biological Assessment of the Integrated Treatment of Noxious Plant Program

Visual and recreation resource: “Maintain and enhance visual resource values by 

increasing opportunities for a variety of developed and dispersed experiences. Emphasize 

visual quality objectives in all resource planning and management activities.” 

Noxious weed infestations detract from visual quality of the landscape by turning diverse and 

interesting landscapes into monocultures of often spiny or poisonous plants. Noxious weeds outcompete native wildflowers, eliminating photographic and viewing opportunities. Plants such as 

Malta starthistle can form dense groundcovers in recreation sites, rendering those sites 

inhospitable for camping and picnicking. 

Wildlife habitat: “All resource planning and management activities will be coordinated to 

provide for species diversity and greater wildlife and fish populations through improvement 

of habitat. Ensure that fish and wildlife habitats are managed to maintain viable 

populations of existing native vertebrate species.” 

Uncontrolled infestation by noxious weeds reduces biodiversity, displaces plants that are used by 

wildlife for forage and cover, and ultimately causes deterioration of wildlife habitat. 

Threatened & endangered species recovery: “Prevent destruction or adverse modification 

of critical habitats for threatened and endangered species and manage for a goal of 

increasing population levels that will remove them from federal lists.” 

Noxious weeds can devastate riparian and aquatic habitat for federally listed fish and amphibians 

by increasing water runoff and soil erosion, inducing higher sediment loads in streams, rivers, and 

lakes. Upland species can be affected by changes in fire regime or other ecosystem function 

induced by noxious weeds. 

Restore rangeland: “The goal of the Forest range management program is to bring the 

permitted grazing use in balance with the forage allocated for use by domestic livestock, 

and to have all allotments under appropriate levels of management during the third time 

period (2005 to 2015). 

Improve range forage, watershed & wildlife habitat conditions.”

Noxious weeds out-compete native plants and reduce the amount of forage available to grazing 

livestock. In addition, some noxious weed species contain toxins that can cause death to grazing 

animals.

Erosion control, water quality & quantity: “Meet minimum air and water quality 

standards, emphasize improvement of soil productivity, air & water quality, augment water 

supplies when compatible with other resources, and enhance riparian ecosystems.”

Soil stability, water quality and quantity suffer when native plants that have fibrous root systems 

are replaced by noxious weeds with deep tap roots.

Wilderness: “Emphasize a wilderness management program which is interdisciplinary in 

approach, and which is directed towards achieving the intent of the Wilderness Act of 1964

and FSH 2320.” 
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Biological Assessment of the Integrated Treatment of Noxious Plant Program Page 5

When noxious weeds invade wilderness areas, they destroy the quality described in the 

Wilderness Act as “untrammeled by man.” Congress also directed that wilderness areas be 

managed in such manner as will leave them “unimpaired for future use.”

The National Invasive Species Council defines “invasive species” as a species that is 1) nonnative (or alien) to the ecosystem under consideration and 2) whose introduction causes or is 

likely to cause economic or environmental harm or harm to human health (Executive Order 

13112).

Arizona Administrative Codes R3-4-244 & R3-4-245 (Arizona Dept. of Agriculture, 1999) 

regulate certain invasive species in the state: “A noxious weed is defined as any species of plant 

that is detrimental or destructive and difficult to control or eradicate and includes plant organisms 

found injurious to any domesticated, cultivated, native or wild plant.”

Consultation History

• September 22, 2008: Tonto National Forest requests informal consultation with 

U.S.F.W.S.. Tonto National Forest determined that the proposed action was not likely to 

adversely affect all federally listed species and Critical Habitat occurring within Tonto 

National Forest.

• October 22, 2008: U.S.F.W.S. requests an additional 60 days to complete an initial 

review due to workload constraints, a wide variety of plant and animal species possibly 

affected, and the need to include review from the contaminants program and other species 

specialists. U.S.F.W.S. assigns the consultation # AESO/SE 22410-2009-I-0018 to this 

project.

• 27 October 27, 2008: FS grants U.S.F.W.S. 60 additional days to complete an initial 

review of the proposed action.

• January 14, 2009: U.S.F.W.S. could not concur with FS’s determinations. In addition, 

U.S.F.W.S. needed more specific information describing location, methods, herbicide 

type, treatments, and monitoring to complete the consultation.

• March 24, 2009: Patti Fenner, Fred Wong, Greg Beatty, and Carrie Marr met at 

U.S.F.W.S. Phoenix Office to discuss a variety of issues including: reasons why 

U.S.F.W.S. could not concur with FS’s determination, how tamarisk is an important 

component to flycatcher habitat, and what other information was necessary to complete 

the consultation.

• March 26, 2009: Greg Beatty sent an e-mail to Fred Wong summarizing the issues 

talked about in the previous meeting.

• April 2, 2010: U.S.F.W.S. receives Biological Assessment and the Tonto NF’s request 

for formal consultation.

• August 17, 2010: U.S.F.W.S. requests extension to complete Biological Opinion.

• August 29, 2010: Tonto NF clarifies proposed action for: 1) the buffer size in MSO 

habitat when using the herbicide compound dicamba; 2) use of torching techniques in 

hedgehog and cliffrose habitat; 3) implementation of conservation measures in flycatcher 

habitat when treating tamarisk, and 4) application of techniques in and around Spikedace 

and loach minnow habitat.

• November 20, 2010: U.S.F.W.S. sends partial draft BO to Tonto NF. 

• August 10, 2011: Greg Beatty, Debra Bills, and Gregg Dunn meet to discuss revised 

proposed action.

Appendix J

Page 6 Biological Assessment of the Integrated Treatment of Noxious or Invasive Plant Program

Description of the Proposed Action

The Forest Service (FS) proposes eradication, containment, and/or control of noxious weed and 

invasive plant species on parts of the Cave Creek, Globe, Mesa, Payson, Pleasant Valley, and 

Tonto Basin ranger districts. Known noxious weed infestations cover only a small percentage of 

the total National Forest acres, but new infestations could be found anywhere within the nearly 3 

million acres of the forest. Noxious weed treatment methods include: manual, mechanical, 

torching, cultural methods such as planting of native species, use of biological control agents, and 

use of herbicides. 

This program will be reviewed and updated after ten years. 

We propose to implement an integrated vegetation management strategy consisting of two 

phases: removal and restoration. The removal phase will consist of manual, mechanical, 

biological (livestock & invertebrate releases), torching, or chemical methods of control, and 

usually some combination of these methods. The restoration phase will consist of cultural and 

erosion control actions. 

Removal

Manual – digging by hand, using hand tools, selectively removing noxious weeds from a native 

plant population. This method is very labor-intensive, and ineffective on some types of weeds. It 

is a very effective method to quickly control new infestations of many weeds. This control 

method will be used on up to 400 acres each year.

Examples of manual work include:

• One 8-person crews for a period of five days to remove musk thistle using pickmattocks and pulaskis.

• Volunteer groups of 15 to 30 using shovels to grub Malta starthistle.

Mechanical – Using motorized equipment to cut or clip. This control method will be used on up 

to 500 acres each year.

Examples of mechanical work include:

• Use of a Stihl FS-450 brush saw to cut thickets of oleander or tree of heaven

• Use of a chainsaw to cut tamarisk outside wilderness areas

Torching – Torching is an inexpensive and often very effective method to remove large 

quantities of seed of annual weeds. It can be used very effectively, in combination with other 

treatments, as an integral part of multi-year strategy, especially for annual weeds. This control 

method will be used on up to 1,000 acres each year. Burn projects will be conducted with 

backpack propane torches, and will target specific invasive weed individual plants (figure 1 - 

picture). Large-scale burns that carry fire will not be used. 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Figure 1. Backpack torch at work

Many of the non-native plants we plan to treat respond positively to fire. Therefore, we will 

mitigate their response to burning with the measures shown in table 2.

Table 2. Burning treatment mitigation

Invasive Plant Scientific Name Burn Response

Jointed goatgrass Aegilops cylindrica

Burning promotes germination 

of the following year’s crop. A 

follow-up plan is needed for 

the year after the burn.

Globe-podded hoary cress, 

hairy white-top Cardaria draba, C. pubescens Will not burn.

Knapweeds Centaurea diffusa, C. 

biebersteinii, Acroptilon repens

Crown resprouts and increased 

seedling germination may 

eliminate any benefits from 

burning.

Oleander Nerium oleander Will not burn due to toxic 

smoke

Buffelgrass Pennisetum ciliare

Burning may be a good tool to 

use in combination with use of 

herbicides to remove the bulk 

of decadent growth that could 

prevent good herbicide contact 

with growing leaves.

Fountain grass Pennisetum setaceum Will combine with herbicide

Mediterranean grass Schismus arabicus, S. barbatus Will not burn.

Saltcedar Tamarix parviflora, t. 

chinensis, t. ramosissima.

May burn in some locations, 

in combination with other 

treatments, such as foliar 

herbicide application.
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Biological Assessment of the Integrated Treatment of Noxious Plant Program

Herbicidal – Application of approved chemicals to noxious weeds. Herbicides would be used to 

treat up to 5,000 acres per year (less than 0.2 percent of the National Forest). Amount of 

treatment would be limited by funding each year. Annual weed management efforts will be 

coordinated with treatment efforts undertaken by other Federal, State, and local governments to 

maximize effectiveness. The majority of treatments will occur along roads and other travel 

corridors. There will be no aerial application of herbicide.

We propose to use the 12 active ingredients and 11 adjuvants shown in table 3. 

Table 3. List of proposed active ingredients and adjuvants

Name Type Examples of 

brand name Notes

Aminopyralid Active 

Ingredient Milestone 

Treats Malta starthistle, globe 

chamomile, yellow starthistle, 

scotch thistle, bull thistle, musk

thistle, Canada thistle, Vinca, 

Russian knapweed 

Chlorsulfuron Active 

Ingredient

Telar, Glean, 

Corsair Broadleaf weeds 

Clopyralid Active 

Ingredient

Transline, 

Stinger, Reclaim Broadleaf weeds

Dicamba Active 

Ingredient

Banvel, Oracle, 

Vanquish

Broadleaf weeds, pre-and postemergent

Glyphosate (aquatic and 

non-aquatic formulations)

Active 

Ingredient

Roundup & 

Razor Pro (nonaquatic), Rodeo 

(aquatic)

Broad spectrum (both monocots 

and dicots) 

Imazapic Active 

Ingredient

Impose, 

Panoramic, 

Plateau

Annual & perennial grasses, 

broadleaf weeds & vines

Imazapyr (aquatic and 

non-aquatic formulations)

Active 

Ingredient Habitat, Arsenal

For riparian & terrestrial 

vegetation growing in & around 

surface water 

Metsulfuron methyl Active 

Ingredient

Escort XP, 

Manor

Annual & perennial broadleaf 

weeds & woody plants

Picloram Active 

Ingredient Tordon Broadleaf weeds, woody plants and vines

Sethoxydim Active 

Ingredient Poast Annual & perennial grasses

Sulfometuron methyl Active 

Ingredient Oust Annual and perennial grasses and broadleaf weeds

Triclopyr Active 

Ingredient

Garlon, 

Pathfinder Woody and herbaceous weeds
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Name Type Examples of 

brand name Notes

Mixture of alkyl 

polyoxyethylene ether, 

fatty acids & water

Surfactant Activator 90

Alkylaryl alkoxylate, nbutyl alcoholNonionic 

surfactant APSA 80

Blend of salts of 

polylacrylic, hydroxy 

carboxylic, propionic 

acids, phosphate ester and 

ammonium sulfate

Water 

conditioner Choice

Phosphatidylcholine, 

methylacetic acid & alkyl 

polyoxyethylene ether

Penetrant, 

Acidifier, 

Deposition Aid, 

Drift Control 

Agent

LI-700

Modified Vegetable Oil 

concentrate

Non-ionic 

surfactant MSO

Unknown (proprietary) Polymeric 

Colorant Blazon Blue

Unknown (proprietary) Colorant Hi-Light

Alkyl polyglycoside, 

Ammonium sulfate and 

Ammonium nitrate

Activator, 

Penetrant Magnify

Alcohol ethoxylate, 

Phosphatidylcholine and 

Methylacetic acid

Surfactant, 

Penetrant, 

Deposition Aid, 

Acidifier

Monterrey Super 

Seven

Polyetherpolymethylpolysiloxanecopolymer, polyether

Surfactant Silicone Super 

Wetter

Silicone polyether 

copolymer Surfactant Slither

The herbicide industry is continually developing new herbicides and adjuvants with lower 

ecotoxicity ratings. After an analysis that documents a new chemical’s environmental effects are 

equal to or less than the chemicals included in this document.

We will apply these herbicides in a variety of ways including:

• Backpack sprayers

• Hand spray applicators

• ATV sprayers

• Trailer/truck-mounted tanks
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Tamarisk treatment. The primary proposed tamarisk treatment area is the Verde River. We also 

propose to treat tamarisk to a lesser degree on the Salt River and Tonto Creek, and at very small 

sites where there are springs, seeps, stock tanks, or runoff from roads and highways (table 4). 

On rivers, treatments will be normally be carried out by river rangers with either volunteers or 

youth corps groups floating down the river, and stopping in areas where tamarisk occur. Trees 

will be sawn off near ground level and an aquatic-rated herbicide will be immediately applied 

directly to the cut stump using a hand applicator. We estimate that 90 percent of the treatment 

areas typical consist of tamarisk individuals intermingled with native vegetation (>90 percent). 

The other ten percent consists of sites with a larger percentage of tamarisks that are one tree wide 

stringers. We will remove unlimited amounts of saltcedar seedlings (plants less than three feet in 

height). An aquatic-rated foliar spray may be used on patches of small seedlings.

Verde River Tamarisk Treatment. The treatment area is from the section of river managed by 

the Prescott and Coconino national forests downstream to Isner Flat; and from Horseshoe Dam 

downstream to the Fort McDowell Reservation (figure 1 - map). We propose to treat a maximum 

of three river miles per year along the Verde River above Horseshoe Reservoir, and up to 1 mile 

annually along the Lower Verde River downstream of Horseshoe Reservoir. With an average 

100-foot band on either side of the river, this translates to a treatment area of 72.7 acres per year 

on the Upper Verde, and 24 acres of treatment area on the Lower Verde. If saltcedar comprises up 

to10 percent of this area, this equates to a maximum of 7.3 acres of tamarisk on the Upper Verde, 

and 2.4 acres on the Lower Verde per year. 

Salt River Tamarisk Treatment. The treatment area begins at the Salt River Canyon Wilderness 

western boundary and continues east along the Salt River until it leaves Tonto NF (figure 2). We 

have identified 4 areas (figures 2a through e) that are potential SWFL habitat: Horseshoe Bend, 

Gleason Flat, Redmond Flat, and Nail Creek. These areas are excluded from the treatment area.

We propose to treat no more than ten acres annually along the Salt River. Since saltcedar can be a 

dominant tree on the Salt River, this could equate to as much as ten acres of tamarisk treated per 

year along Salt River. The areas that we will be focusing on are those that are used in dispersed 

camping, where tamarisk is encroaching on camping spots along the river.

Tonto Creek Tamarisk Treatment. The treatment area begins upstream of Gisela and continues 

north to Tonto Spring (figure 3). This area is outside of flycatcher critical habitat. We propose to 

treat no more than ten acres along Tonto Creek. This amounts to no more than one acre of 

tamarisk treated per year along Tonto Creek.

Table 4. Tamarisk treatment acres by area

Treatment Area 

Name

Acres of evaluated for 

tamarisk treatment

Acres of Tamarisk 

Treated

Critical 

Habitat

Upper Verde River 72.7 7.3 Yes and No

Lower Verde River 24 2.4 Yes

Salt River 10 1 Yes and No

Tonto Creek 10 1 No

Biological – Use grazing animals (sheep, goats, and cattle), approved insects and pathogens to 

control weeds. Biological treatments are usually used when the objective is control and not 

eradication. The biological agent and the weed co-exist to the extent that spread of the weed is 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

limited. Once biological control agents such as insects or plant pathogens are released, they may 

cover a large number of acres if there is a continuous infestation of their target weed plant.

Biological control agents include approved insects and pathogens that undergo a rigorous testing 

procedure prior to being available for release. Initial testing occurs in quarantined laboratories 

abroad and in the United States. The agents are tested for their effectiveness in controlling the 

target organism and for their host specificity. Testing includes potential effects on human health, 

economic crops, rare plants, and similar species found in North America. An agent can be 

released only after is has been determined that it is unlikely that the agent will feed or cause 

injury to any native or agronomic species. It generally takes between 10 and 15 years for an agent 

to be cleared for release. Agricultural Plant Health Inspection Service (APHIS) now prepares an 

Environmental Assessment before release of new agents. This has not always been the case. For 

any agent that has been released, APHIS has conducted host specificity studies. Upon release of 

new biocontrol agents, APHIS assumes that these agents will spread throughout North America to 

wherever the target species exists or will exist in the future. It is intended that this analysis will 

satisfy the intent of NEPA for the release and distribution of the agent in the United States. 

All of the agents proposed for release on the Tonto NF have already been released in Arizona.

The only action the Forest Service is taking by releasing an agent is changing the location and 

influencing the rate of spread of the agent. We propose to use the following invertebrates for 

biological control (table5). 

Table 5. Biological control agent and target species list

Scientific 

Name of 

Biocontrol 

Agent

Common 

Name of 

Biocontrol 

Agent

Target 

Species 

Common 

Name

Target 

Species 

Scientific 

Name

Notes

Agapeta 

zoegana

moth Spotted 

knapweed

Centaurea 

biebersteinii

First released in the United States in 

1984. Has been released in Arizona, 

California, Colorado, Idaho, 

Minnesota, Montana, Nebraska, 

Nevada, North Dakota, Oregon, South 

Dakota, Utah, Washington, 

Wisconsin, and Wyoming. The moth 

has established in these states.

Bangasternus 

fausti

Flower 

weevil

Spotted 

knapweed, 

diffuse 

knapweed

Centaurea 

biebersteinii, 

Centaurea 

diffusa

First released in the United States in 

1991. The weevil has been released in 

California, Colorado, Idaho, 

Minnesota, Montana (established), 

Nebraska (established), Oregon 

(established), South Dakota, 

Washington, and Wyoming. Also

released in Arizona.
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Biological Assessment of the Integrated Treatment of Noxious Plant Program

Scientific 

Name of 

Biocontrol 

Agent

Common 

Name of 

Biocontrol 

Agent

Target 

Species 

Common 

Name

Target 

Species 

Scientific 

Name

Notes

Bangasternus 

orientalis

Yellow 

starthistle 

bud weevil

Yellow and 

Malta 

starthistles

Centaurea 

solstitialis, 

C. melitensis

Releases were made in California. 

Washington. Idaho, and Oregon in 

1985 and it became established in all 

states in 1989. Widely distributed in 

starthistle-infested areas of the 

western United States, particularly 

California, Oregon, Washington and 

Idaho (Wilson, et al., 2003).

Cyphocleonus 

achates

weevil Spotted 

knapweed,

diffuse 

knapweed

Centaurea 

biebersteinii,

Centaurea 

diffusa

First released in the United States in 

1987. Has been released in Arizona, 

California, Colorado, Idaho, 

Minnesota, Montana, Nebraska, 

Nevada, Oregon, South Dakota, Utah, 

Washington, and Wyoming as part of 

a program to control spotted and 

diffuse knapweed. Populations are 

established in Colorado, Montana, and 

Wyoming, and individuals have been 

recovered in Oregon. It has also 

become established in Minnesota.

Eustenopus 

villosus

Yellow 

starthistle 

hairy weevil

Yellow and 

Malta 

starthistles

Centaurea 

solstitialis, 

C. melitensis

Widely distributed in starthistleinfested areas of the western United 

States, particularly California, Oregon, 

Washington and Idaho. (Wilson, et al.,

2003) Introduced on Coconino NF 

2008, 2009.

Larinus 

minutus

weevil Spotted 

knapweed, 

diffuse 

knapweed

Centaurea 

biebersteinii, 

Centaurea 

diffusa

Cleared and first released in the 

United States in 1991. The weevil has 

been released in Arizona, California, 

Colorado, Idaho, Minnesota, Montana 

(established), Nebraska, Oregon 

(established), South Dakota, Utah, 

Washington (established), and 

Wyoming (established).

Larinus 

obtusus

weevil Spotted 

knapweed, 

diffuse 

knapweed

Centaurea 

biebersteinii, 

Centaurea 

diffusa

Approved and first released in 1993 in 

the United States. This weevil has 

been released in Idaho, Minnesota, 

Montana (established), Nebraska, 

Oregon, and Washington Also 

released in Arizona.

Mecinus 

janthinus

Stem-mining 

weevil

Dalmatian 

toadflax

Linaria 

dalmatica

Approved for release in the U.S. in 

1995. Introduced on Coconino NF in 

2008 & 2009.
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Biological Assessment of the Integrated Treatment of Noxious Plant Program

Scientific 

Name of 

Biocontrol 

Agent

Common 

Name of 

Biocontrol 

Agent

Target 

Species 

Common 

Name

Target 

Species 

Scientific 

Name

Notes

Sphenoptera 

jugoslavica

buprestid 

beetle

Diffuse 

knapweed

Centaurea 

diffusa

First released in the U.S. in 1979. Has 

been released in Arizona, Colorado, 

Idaho, Montana, Nebraska, Nevada, 

Oregon, South Dakota, Utah, 

Washington, and Wyoming. It is 

established in Colorado, Idaho, 

Montana, Oregon, South Dakota, 

Washington, and Wyoming, and is 

being collected for redistribution in 

Colorado, Montana, Oregon, and 

Washington.

Urophora 

affinis

seed head 

flies

Spotted 

knapweed, 

diffuse 

knapweed

Centaurea 

biebersteinii, 

Centaurea 

diffusa

First released in the United States in 

1971. Has been released in Arizona, 

California, Colorado, Idaho, 

Michigan, Minnesota, Montana, 

Nebraska, Nevada, North Dakota, 

Oregon, South Dakota, Utah, 

Washington, Wisconsin, and 

Wyoming. Populations have been 

established in all of these states but 

Nevada.

Urophora 

quadrifasciata

seed head 

flies

Spotted 

knapweed, 

diffuse 

knapweed 

Centaurea 

biebersteinii, 

Centaurea 

diffusa

Approved for release in 1988. Has 

been released and established in 

Arizona, California, Colorado, Idaho, 

Michigan, Minnesota, Montana, 

Nebraska, North Dakota, South 

Dakota, Utah, Washington, 

Wisconsin, and Wyoming. 

Establishment has been confirmed in 

Indiana, Maryland, New York, 

Pennsylvania, Vermont, New 

Hampshire, Massachusetts, Rhode 

Island, Connecticut, and New Jersey

Information in the above table is from Kok & Gassmann, 2002; Wilson, et al., 2003; and Weeden, et al.,

2010. 

Restoration

Erosion Control

In areas where there are large concentrations of an invasive species, where treatment would result 

in expanses of bare ground, restore native vegetation following treatment. Restoration efforts 

would involve erosion control (installing silt fence, straw bales, and wattles/fiber rolls).
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Cultural – Seeding with native plants that prevent infestation by invasive plants. Establishing 

native plants is essential to preventing areas of bare ground created by construction or other 

activities from being vulnerable to infestation of weeds. Fertilizers or mycorrhizal inoculants will 

be included in some revegetation projects to increase establishment success. This method will be 

used on up to 2,000 acres each year.

Biological Assessment of the Integrated Treatment of Noxious or Invasive Plant Program

Summary of Treatments

Table 6. Summary of treatment types and acreages

Type of Treatment Maximum Acres

Manual (hand tools) 400

Mechanical (motorized equipment) 500

Torching 1,000

Biological control (livestock) 1,000

Biological control (invertebrates) Maximum release sites: 100 sites/year

Herbicidal 5,000

Cultural 2,000

Total 9,900

Conservation Measures (Project Design Features)

RPMPA refers to the Recommended Protection Measures for Pesticide Applications in Region 2 

of the U.S. Fish and Wildlife Service authored by J. Allen White, April 2007. For this project, the 

RPMPAs were the starting point for the conservation measures. The list table below summarizes 

how the conservation measures deviate from the RPMPAs and the rationale for that deviation. 

See appendix 1 for summary of RPMPA and adjustments. See appendix 2 for a summary of 

where the adjuvants may be used.

1. All herbicide label requirements will be followed. 

2. All applications will be under the direction of a Certified Pesticide Applicator. 

3. Herbicides will be applied only by ground-based equipment, including backpack 

sprayers, and spray units on ATVs, trucks, etc. 

4. All Best Management Practices (BMPs) will be followed 

5. Clopyralid, dicamba, picloram, and the sulfonylurea herbicides will not be used where 

the water table is within 6 feet of the surface or where soil permeability is conducive to 

water contamination. 

6. Glyphosate, and amine formulations of 2,4-D and triclopyr labeled for aquatic use will be 

the materials used within designated buffer zones along streams and bodies of water 

(1992 Risk Assessment, pages III-F-32 and 39). Imazapic, imazapyr, and triclopyr may 

be used in buffer zones as long as they are not directly applied to water. 

7. Applicators are required to wear appropriate personal protective equipment as required 

on the label. 

8. All requirements in a Safety and Spill Plan (attached) will be followed.

9. The public would be able to access ADOT’s timing and location of treatments along 

roadways by calling the following toll free number 1-800-546-6591. 

When any herbicide is applied, best management practices will be used to ensure maximum 

safety.

Pre-spray BMPs 

1. Determine the necessity for weed management by scouting the area for weed density. 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

2. The Forest Service recognizes the significance of protecting Native American ethnobotany locations, and each forest will coordinate and consult with interested tribes to 

protect the integrity of sites where native plants may be collected. 

3. Use herbicides only when they will provide the most effective control relative to the cost 

and potential hazard of other management techniques. 

4. Choose the most effective herbicide that requires the least number of applications. 

5. Choose the lowest effective rate of application. 

6. Scout the area and identify sensitive situations like residential structures, campgrounds 

that will be used by the public, etc. 

7. Read approved HUP prior to conducting any herbicide project. Pay special attention, and

adhere to required restrictions for federally-listed or sensitive species, or for sensitive 

areas. 

8. Plan to leave an appropriate buffer zone (at least 30 feet on relatively level ground) 

around bodies of water, and adjacent sensitive areas, and populations of threatened, 

endangered, or sensitive species. Buffer zones will be marked as needed to guide 

herbicide applicators. 

Herbicide Spraying BMPs 

1. Ensure meteorological conditions are favorable. Do not spray when winds are over 

10 mph, or during inversions. 

2. Highway rights-of-way are closed areas to the pedestrian public, and it is illegal to stop 

on the highway except in emergency situations. 

3. Post informational signs at designated pullouts and rest areas and place signs on spray 

vehicles listing the herbicide being used. 

4. Use the lowest pressure, largest droplet size, and largest volume of water permitted by the 

label to obtain adequate treatment success. 

5. Use the lowest spray boom and release height possible consistent with operator safety. 

6. Spot applications of triclopyr, glyphosate, imazapic, and imazapyr may be done to the 

edge of some bodies of water in compliance with label requirements. 

7. Broadcast applications of glyphosate and other broad spectrum herbicides will not be 

considered where threatened, endangered, and sensitive plant species are known to occur. 

8. Buffer zones will be marked around any populations of threatened, endangered, and 

sensitive (TES) plant species, and undesirable plant control in buffer zones will include 

spraying with selective herbicides that will not affect the TES plants, or spot applications 

of individual weeds with backpack sprayers, daubing, or hand grubbing with no herbicide 

use. We will not use dicamba within 1/4 mi of MSO PACs

9. Require all herbicide applicators to use appropriate personal protective equipment (PPE). 

10. Only those herbicides labeled for use to the edge of bodies of water or with aquatic 

labeling shall be used within buffer zones and aquatic situations. 

Herbicide Post-Spray BMPs

1. Periodically scout treated areas to assess efficacy. 

2. Monitor populations of threatened, endangered, or sensitive species to ensure there were 

no adverse effects.
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

General Project BMPs:

1. Implement Integrated Weed Best Management Practices.

2. Survey T&E species’ habitats to determine and prioritize the occupied and potential 

habitats that would be most vulnerable to encroachment of invasive and noxious weeds.

3. Use native species for seeding and planting during revegetating. An exception is the use 

of sterile hybrid grasses after careful analysis to provide immediate ground cover after 

wildfires.

4. FS will review “weed-free” certifications for seed and mulch to ensure they are “free” of 

the weed species to be controlled in the action area.

5. Treatments that are not within these design features would require additional analysis and 

may require additional coordination with the U.S.F.W.S. (U.S. Fish and Wildlife 

Service).

6. Work cooperatively with adjacent landowners to manage noxious and invasive weeds to 

prevent their spread into NFS (National Forest System) lands.

All species:

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

priority.

2. Noxious and invasive weed treatment methods during the breeding seasons for birds 

would be commensurate with designated uses (non-motorized, motorized, livestock, etc.) 

in the treatment areas.

3. Adjuvants including surfactants would be used or applied according to the adjuvant 

summary table (appendix 2).

4. Forest Service would submit to the U.S.F.W.S. an annual report of herbicide treatments 

occurring within T&E species’ habitat.

Arizona cliffrose

1. No torching of weeds where cliffrose are found. Manual treatments will be used.

2. No biological control (i.e., livestock grazing) will be used where plants occur.

Arizona hedgehog cactus

1. No torching of weeds where cactus is found instead manual treatments (pulling weeds) 

will be used

2. No biological control (i.e., livestock grazing) will be used where plants are known to 

occur.

3. When noxious weed control will be done and experienced person with Arizona hedgehog 

cactus will be present to make sure plants are not being harmed.

Southwestern willow flycatcher:

1. 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.

2. 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.
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

3. 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.

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

are absent from the area. 

5. No treatment of tamarisk will occur in the Habitat Conservation Plan boundaries of 

Roosevelt and Horseshoe Lakes.

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

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

ten percent of the total area within a 50-foot radius circle (Note: tamarisk seedlings less 

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

saltcedar seedlings.

Mexican spotted owl:

1. Herbicide will have the following buffer zones from the perimeter of an occupied PAC or 

MSO habitat that has not been surveyed. These standards apply only to non-ROW 

situations.

2. Within both an existing ROW and a PAC, we will apply herbicides during the MSO 

breeding season (but at least 1⁄4 mile from the nest). We will use: 1) coarse droplet sizes 

or nontoxic drift retardants, 2) non-persistent herbicide, and 3) vegetable oil carrier.

3. We will not use dicamba within a quarter mile of MSO PACs. 

4. No treatments may occur within 1⁄4 mile of occupied nests.

Chiricahua leopard frog:

1. In Chiricahua leopard frog (CLF) habitat, 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.

2. Water will not be drafted from riparian areas with CLF frog populations.

3. We will avoid contamination of CLF frog habitat by roadside herbicide application by 

not spraying in ditches, riparian areas and springs.

4. If bare soil results from control of streamside invasive weeds, replace with native 

vegetation to improve soil stability.

5. We will not use tripoclyr (ester formulations) within 500 feet of a CLF protected area or 

an area where we know northern garter snakes appear.

Yuma clapper rail:

1. Herbicides would be applied per guidelines in RPMPA pg. 64 (see summary table – 

appendix 1). 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

2. FS biologist will determine nesting areas and identify the site on the ground prior to 

treatment.

3. FS biologist would confirm occupancy during the breeding season (March through July).

4. In occupied breeding areas, treatments adjacent to breeding areas would occur outside the 

time of occupancy.

Gila chub, Gila topminnow, and desert pupfish in small streams with 

adjacent riparian habitat: 

1. When stream flows are 100 cfs or greater, herbicides would be applied per guidelines for 

large aquatic habitats in RPMPA pg. 76 (see summary table). 

2. When stream flows are less than 100 cfs, herbicides would be applied per guidelines in 

RPMPA pg. 73 with the following modifications (see summary table): 

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

may be used within the riparian zone adjacent to but not in the aquatic habitat. 

b. Spot applications to individual plants are permitted within the buffer zone. 

c. 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 ft. buffer 

would apply when there is no surface flow of water. 

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

large riparian habitats (see summary table). 

Colorado pikeminnow, loach minnow, razorback sucker, spikedace, and 

woundfin in large streams with adjacent riparian habitats: 

1. When stream flows are 100 cfs. or greater, herbicides would be applied per guidelines for 

large aquatic habitats in RPMPA pg. 76 (see summary table). 

2. When stream flows are less than 100 cfs., herbicides would be applied per guidelines in 

RPMPA pg. 73 with the following modifications (see summary table): 

a. Approved Herbicides (Aquatic formulations only): Glyphosate, Imazapic, Imazapyr 

may be used within the riparian zone adjacent to but not in the aquatic habitat. 

b. Spot applications to individual plants are permitted within the buffer zone. 

c. 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 ft. buffer 

would apply when there is no surface flow of water. 

Herbicide Risk Assessment:

The herbicides proposed for use include aminopyralid, chlorsulfuron, clopyralid, dicamba, 

glyphosate, imazapic, imazapyr, metsulfuron methyl, picloram, sulfometuron methyl, and 

triclopyr. These herbicides are marketed under a variety of trade names. The U.S. Environmental 

Protection Agency (EPA) has registered all of these herbicides and the various product labels 

include requirements and restrictions.

Animals and plants have different metabolic pathways so a compound that is toxic to plants can 

be relatively non-toxic to animals. The EPA classifies all of the herbicides proposed for use, as 

slightly toxic (Category III) to almost non-toxic (Category IV) to humans. 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

The risk assessment is a common method for analyzing potential effects of various chemicals on 

humans and non-target species. It uses generally accepted standards of safety to quantify the 

long-term risks from an action. In addition, specific risk assessments are available for all of the 

herbicides being considered (http://www.fs.fed.us/foresthealth/pesticide/risk_assessments). 

A series of risk assessments were written by Syracuse Environmental Research Association on 

herbicides proposed for use in this document (appendix F). The following discussion on herbicide 

effects to wildlife in the project area is based on a comparison to these risk assessments.

The non-target species hazard analysis summarized laboratory and field study findings that 

evaluated toxicity of the herbicides and carriers to wildlife and aquatic species. In many cases, 

toxicity studies with laboratory animals were used in this risk assessment because of the lack of 

specific wildlife studies. The results of laboratory animal studies are considered to be 

representative of the effects that would occur in similar species in the wild.

Wildlife doses were calculated for a group of wildlife species representative of those typically 

found in areas supporting rangeland, forest land, or riparian vegetation found in the West. These 

species represent a range of phylogenetic classes, body sizes, and diets for which biological 

parameters are generally available. Typical and extreme acute dose estimates were determined for 

each representative species for each of the three major exposure routes—dermal, ingestion, and 

inhalation. Since the herbicides degrade relatively rapidly and sites are normally treated only once 

per year, no analysis of chronic wildlife dosing was performed. Because the herbicides show little 

tendency to bioaccumulate (although several tend to bioconcentrate in aquatic environments), 

long-term persistence in food chains and subsequent toxic effects were not considered a problem 

and were not examined in the risk assessment.

The results of the risk analysis indicate that potential risks to individual animals are low for most 

of the herbicides. Estimated doses for typical exposures result in a low risk from all herbicides 

and carriers.

Dicamba is moderately toxic to insects at high doses. However, in the field it would only be 

applied in low doses. Triclopyr can be moderately toxic to guinea pig and mice. It does not 

bioaccumulate and the Garlon formulations are considered only slightly toxic. All the other 

herbicides proposed for use have low toxicity.

The above information can be applied to animals found on the Tonto NF covered by this 

proposal. For threatened, endangered and sensitive species (TE&S) and Management Indicator 

Species (MIS), under typical exposures, no species are at risk. Though dicamba and triclopyr may 

have adverse impacts on the animals listed above if directly sprayed on the animals, the 

likelihood of this occurring is very low. Dicamba could potentially be used on several species, 

including Malta starthistle and spotted knapweed. Triclopyr and imazapyr will be used almost 

exclusively for the treatment of tree of heaven, Russian olive, saltcedar, and Siberian elm. The 

method of application will be cut and daub or injections into the bark, with no broadcast spraying 

involved. The chances of impacting any native wildlife or non-target vegetation by this method of 

application are very remote.

We do not anticipate any adverse impacts on wildlife species from a toxicological standpoint. We 

project that the low incidence of use and prescribed rate below what is recommended from the 

risk assessment will limit the risk to wildlife relating to toxicological impacts.
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Most weed populations are small and scattered, so treatments that occur under this alternative will 

be localized. Therefore, treatments would only impact a minor portion of any wildlife species 

population at one time. Less than one percent of the land area on the Tonto NF would be treated 

with herbicide. As described above, treatments may create a short-term disturbance, while people 

are in the area working. For weeds with large populations, like saltcedar or the starthistles, only a 

portion of the population will be treated at one time, so the impacts on native wildlife are similar 

to some of the small populations of weeds.

Proposed application rates are typically well below the recommended amounts as disclosed in the 

risk assessment. We anticipate that this situation, in combination with the low amounts of 

National Forest to be treated in any given year, would reduce the potential for any toxicological 

problems to very low levels. In fact, successful treatment of invasive species will improve habitat 

conditions for the TE&S and MIS species. This includes elk, deer, turkey, Mexican spotted owl, 

and pronghorn.

The herbicides proposed for use all have low aquatic toxicity under typical case water 

concentrations .The only exception is triclopyr not labeled for aquatic application, which may 

present a high risk for trout in streams and a moderate risk for trout in lakes. All herbicides would 

be used in accordance with label directions so triclopyr would not be used where it might enter 

water. Picloram and dicamba formulations that are not labeled for aquatic applications may 

present a moderate risk under extreme water concentration, but this case seems highly unlikely 

under the conditions of proposed application. Nevertheless, these herbicides would not be used 

where they might enter water. Clopyralid, dicamba, and glyphosate are roughly 1/5 to 1/50 as 

toxic to various aquatic organisms, so under conditions of proposed application they are highly 

unlikely to pose a risk to aquatic organisms (appendix A, U.S. Forest Service, 2003). 

For threatened, endangered, or sensitive aquatic organisms, triclopyr products not labeled for 

aquatic use may present an unacceptable risk to cold-water fish under the typical case scenario. 

However, in accordance with label directions, these products would not be used in aquatic 

applications. It must be noted that the assessment was made using aerial application as the 

treatment approach realizing that aerial application poses the potential risk of inadvertent 

application to water. The herbicide applications near water would be hand backpack applications 

by spot application to single plant or plant clusters using hand-operated equipment and a back 

pack tank, and this would result in minimal risk of contamination to surface water. Leaching of 

herbicides through soil is not a significant process. Herbicides do have the potential for overland 

flow during heavy rainstorms, but the likelihood of such movement on infiltration-dominated 

sites makes water contamination unlikely. Mitigation measures and BMPs would reduce the 

potential for possible adverse effects to aquatic organisms.
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Project Area Description

The project area includes the entire Tonto National Forest. The Action area also includes the arbitrary 

boundary of Arizona, where biological invertebrate agents may spread. 

Existing Condition/Environmental Baseline

While most infestations on the Tonto NF are at low population levels now, in very little time, they can 

grow beyond any control efforts, as evidenced many times in many other places. For example, spotted 

knapweed was introduced into Montana in the 1920s – today it occupies over 7.2 million acres in nine 

states and two Canadian provinces (Beck, 1994). Noxious weeds have adverse effects on ecosystems, 

ecosystem function, and human values associated with ecosystems. Bunchgrass sites invaded by spotted 

knapweed exhibit increases in soil erosion of 192 percent and higher (Lacey, et al., 1990). Invasive exotic 

species often replace preferred wildlife forage species, forming monocultures inhospitable to native 

wildlife. Plants such as Dalmatian toadflax, Scotch and bull thistles, and oxeye daisy replace native 

grasses and forbs used by deer, turkey, elk, and many other native wildlife species, and are not used by 

any native wildlife species. Leafy spurge produces a sap that causes a severe skin rash in humans, and is 

poisonous to most grazing animals. Saltcedar grows along banks of rivers such as the Colorado River, so

densely that it is difficult for kayaks to land their boats. Adverse effects of these and other invasive 

species are described in detail in the Environmental Assessment.

Control of noxious weeds will promote ecosystem health of forest, range, and aquatic habitat by 

maintaining or improving cover of native forbs, grass and woody species. This, in turn, will prevent loss 

of wildlife habitat and species diversity. 

Several invasive plant species have increased dramatically in abundance on the Tonto NF and in areas 

surrounding the Tonto National Forest over the last several years. Twenty five years ago, very few acres 

were infested by invasive plants. At that time, yellow starthistle and diffuse knapweed were discovered on 

private land in the town of Young (Cline, 2004). Today there are an estimated 10,000 acres of yellow 

starthistle in Gila County alone. Thirty years ago, there was no Malta starthistle growing along 

Highway 188. Today, rights-of-way along more than 25 miles of this highway are covered with this plant, 

and the infestation extends to approximately 38,000 acres in Tonto Basin on both sides of Roosevelt 

Lake. Smaller infestations are being found regularly on all lower elevation districts. Malta starthistle has 

been identified growing throughout the Phoenix, Scottsdale, Cave Creek/Carefree, and Tempe, Gisela, 

Superior, Apache Junction, Mesa, and Punkin Center areas, mainly in small localized infestations of less 

than a few acres. Fountain grass has been used for ornamental plantings in the greater Phoenix 

metropolitan area, and has naturalized along highways throughout most of the lower elevation districts of 

the forest. Buffelgrass is moving up to the Tonto NF from southern Arizona at an alarming rate.

Although there are fewer acres of weeds on the Tonto National Forest than on many other national forests 

in the west, weed populations are growing rapidly here. History has repeatedly demonstrated that invasive 

weed populations do not remain small for long. Growth rates are typically exponential, with an apparent 

lag time between initial infestation and subsequent extensive infestations that are beyond control.
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Invasive Species

Table 7 lists invasive species occurring on or near the Tonto National Forest. Please refer to the 

Environmental Assessment for the Integrated Treatment of Noxious or Invasive Plants for descriptions of 

invasive species. 

Table 7. List of Invasive Plant Species for the Tonto National Forest

Scientific name Common 

name

AZ Dept. of 

Agriculture 

Weed List*

APHIS 

Weed 

List

On 

neighboring 

states' weed 

lists?

Tonto NF

category**

AZWIPW

G class 

***

Acroptilon repens

Russian 

knapweed P, Res. CA, CO, NM, NV,UT A H 

Aegilops 

cylindrica

Jointed 

goatgrass P, Res. CA, CO, NM B L 

Ailanthus 

altissima Tree of heaven B 

Alhagi maurorum Camelthorn P, Res. CA, CO, NM, 

NV, A M 

Arundo donax Giant reed B H

Asphodelus 

fistulosus Onionweed x NM A L 

Avena fatua Wild oats CO C M

Brassica nigra Black mustard B

Brassica 

tournefortii Asian mustard C M 

Bromus 

catharticus Rescuegrass C 

Bromus diandrus Ripgut brome C M

Bromus japonicus Japanese 

brome C 

Bromus rubens Red brome C H

Bromus tectorum Downy brome CO C H

Cardaria draba Globe-podded 

hoary cress P, Res. CA, CO, NM, NV UT A M 

Cardaria 

pubescens

Hairy whitetop

P CA, A M 

Carduus 

acanthoides

Plumeless 

thistle P CA, CO A 

Carduus nutans Musk thistle CA, CO, NM, 

NV, UT A M 

Cenchrus 

echinatus

Southern 

sandbur P, Reg. CA, A 

Cenchrus spinifex Field sandbur P, Reg. CA, A
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Scientific name Common 

name

AZ Dept. of 

Agriculture 

Weed List*

APHIS 

Weed 

List

On 

neighboring 

states' weed 

lists?

Tonto NF

category**

AZWIPW

G class 

***

Centaurea 

biebersteinii

Spotted 

knapweed P, Res. CA, CO, NM, NV, UT A M 

Centaurea diffusa Diffuse 

knapweed P, Res. CA, NM, NV, UT B M 

Centaurea 

melitensis

Malta 

starthistle NM, NV C M 

Centaurea 

solstitialis

Yellow 

starthistle P, Res. CA, CO, NM, NV, UT B H 

Chondrilla juncea Rush 

skeletonweed P CA, CO, NV A M 

Chorispora 

tenella Blue mustard CA, CO A 

Cirsium arvense Canada thistle P CA, CO, NM, 

NV, UT A M 

Cirsium vulgare Bull thistle CO, NM C

Convolvulus 

arvensis

Field 

bindweed P, Reg. CA, CO, NM, UT C M 

Dimorphotheca 

cuneata

White bietou A 

Dipsacus fullonum Common 

teasel CO, NM B 

Eleagnus 

angustifolia Russian olive CO, NM A H 

Elymus repens Quackgrass P, Res. CA, CO, UT B L

Eragrostis curvula Weeping 

lovegrass C L 

Eragrostis 

Lehmanniana

Lehmann's 

lovegrass C H 

Euphorbia esula Leafy spurge P CA, CO, NM, 

NV, UT A H 

Euryops 

subcarnosus

Sweet 

resinbush A H 

Isatis tinctoria Dyer's woad P CA, CO, NM, 

NV, UT A 

Kochia scoparia Kochia A

Leucanthemum 

vulgare Oxeye daisy CO A L 

Linaria dalmatica Dalmatian 

toadflax P, Res. CA, CO, NM, NV A M 

Linaria vulgaris Yellow 

toadflax CO, NM, NV A M 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Scientific name Common 

name

AZ Dept. of 

Agriculture 

Weed List*

APHIS 

Weed 

List

On 

neighboring 

states' weed 

lists?

Tonto NF

category**

AZWIPW

G class 

***

Lythrum salicaria Purple 

loosestrife P CA, CO, NM, NV, UT A 

Melilotus 

officinalis

Yellow 

sweetclover C M 

Nerium oleander Oleander B

Oncosiphon 

piluliferum

Globe 

chamomile B 

Onopordum 

acanthium Scotch thistle P, Res. CA, CO, NM, NV, UT B L 

Peganum harmala African rue P CA, CO, NM, 

NV A 

Pennisetum ciliare Buffelgrass P, Reg. B H 

Pennisetum 

setaceum Fountain grass B H 

Pentzia incana Karoo bush A

Polygonum 

cuspidatum

Japanese 

knotweed CA, A 

Potentilla recta Sulfur 

cinquefoil CO, NV A 

Pyracantha sp. Pyracantha B

Rhus lancea African sumac B M

Salsola kali & S. 

tragus

Russian thistle C 

Salvia aethiopis Mediterranean 

sage CA, CO, NV A 

Schismus arabicus Arabian 

schismus C M 

Schismus barbatus Mediterranean 

grass C M 

Sinapis arvensis Wild mustard CO B

Tamarix chinensis Five-stamen 

tamarisk NM C H 

Tamarix 

parviflora

Smallflower 

tamarisk CO, NM, NV C H 

Tamarix 

ramosissima Saltcedar CO, NM, NV C H 

Ulmus pumila Siberian elm NM A M

Vinca major Periwinkle B M

Definitions: *Arizona State Dept. of Agriculture Weed List: P= Prohibited. These weeds are prohibited from entry 

into the state. 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Reg. = Regulated. These weeds MAY be controlled or quarantined if found within the state, to prevent further 

infestation. Res. = Restricted. These weeds SHALL be controlled or quarantined if found within the state. 

**Tonto NF Weed List: Class A weeds are of limited distribution in Arizona, or unrecorded in the state. They pose 

a serious threat. Management goal is eradication. Class B weeds are of limited distribution in Arizona, common in 

some places in the state. Management goal is to contain their spread, decrease population size, then eliminate. 

Class C weeds have spread beyond our capability to eradicate them. Management goal is to contain spread to 

present size; then decrease the population if possible. 

***AZ-WIPWG = Arizona Wildland Invasive Plant Working Group rating. (SWEPIC 2005) H = High. These 

species have severe ecological impacts on ecosystems; invasiveness attributes are conducive to moderate to high 

rates of dispersal and establishment; species are usually widely distributed. M = Medium. These species have 

substantial and apparent ecological impacts on ecosystems; invasiveness attributes are conducive to moderate to 

high rates of dispersal, often enhanced by disturbance; ecological amplitude and distribution range from limited to 

widespread. L = Low. These species have minor yet detectable ecological impacts; invasiveness attributes result in 

low to moderate rates of invasion; ecological amplitude and distribution are generally limited, but the species can 

be problematic locally.

 = Additional designation for some species whose current ecological amplitude and distribution are limited.

Species are capable of invading unexploited natural communities, based on initial, localized observations or 

behavior in similar ecosystems/communities elsewhere.
Biological Assessment of the Integrated Treatment of Noxious or Invasive Plant Program Page 

Effects of the Proposed Action on 

Threatened, Endangered, and Proposed 

Species

Arizona Cliffrose (Purshia subintegra) 

Background: Arizona Cliffrose is a low, straggling perennial shrub, growing from 3-6 feet tall 

and generally wider than tall. Mature plants are capable of producing many seeds per year. Plants 

begin blooming in late March and continue through early May. Normally, hundreds of flowers are 

produced on each mature plant. Native bees and introduced honeybees are the main pollinators. 

The flowers are primarily cross-pollinated, but are partially self-compatible. Cross-pollinated 

flowers produce significantly more seeds than self-pollinated flowers. Most fruits develop during 

April and are dispersed during the summer when rains dislodge the seeds. The timing of seed 

germination and seedling establishment is unknown (U.S.F.W.S., 1994). As a genus, cliffroses 

are morphologically variable and this can create identification problems when P. subintegra occur 

in proximity to P. stansburiana (e.g., Verde Valley and Horseshoe areas). This species is 

restricted to nutrient-deficient, calcareous limy-tuff soils derived from Tertiary lacustrine 

deposits, and their habitat can be clearly delineated on aerial photography (figure 4). Crucifixionthorn is the most common plant associate. 

The only known occurrences of Arizona Cliffrose on the Tonto National Forest are at the 

Horseshoe Lake at elevations between 2,100 and 2,700 feet (figure 4). No critical habitat was 

identified or designated for this taxon at the time of listing. Listing occurred under the former 

genus Cowania. A Recovery Plan was developed for this species in 1994. It did not address the 

threat of invasive species (USFWS, 1994).

Analysis of effects: Surveys to identify locations of Arizona cliffrose plants in relation to noxious 

and invasive weed plants will be conducted in potential habitat before treatments occur. The best 

way to avoid infestation of the Arizona cliffrose habitat by any noxious and invasive weeds is by 

controlling or containing infestations in surrounding areas. If noxious and invasive weeds do 

enter the forest in Arizona cliffrose habitat, it would be very important to control and eradicate 

the weeds immediately because the effects of non-treatment would be much more detrimental to 

Arizona cliffrose and its habitat than the potential adverse effects of treatments. Without 

treatment, yellow starthistle, Malta starthistle, and Russian knapweeds could grow unimpeded. It 

is likely that these noxious and invasive weeds would then directly out-compete seedlings of the 

Arizona cliffrose and kill some of the associated species that provide protective niches for 

Arizona cliffrose seedlings. Since Russian knapweed and yellow starthistle can form 

monocultures, virtually eliminating any other species in an area by their allelopathic chemicals, 

they could also kill adult plants of Arizona cliffrose. The effects discussed below are therefore 

addressing the scenarios of treatments within Arizona cliffrose habitat on national forest lands in 

the case of such eventuality. 

Malta starthistle infestations in the Horseshoe area have been identified and mapped in close 

proximity to endangered Arizona cliffrose populations. The Cave Creek Complex Fire of 2005 

only stopped short of burning through this species’ habitat because the white substrate where they 

grow does not support a dense vegetative groundcover (Fenner, 2005). However, Malta starthistle 

may grow well even on the white Tertiary lakebed sediment where the cliffrose populations grow.
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Fire is a non-specific treatment. Any plant, regardless of status, can be damaged or destroyed 

during fire 

Specific herbicides have been selected for use in or near populations of listed plants to have the 

least impacts to the plant of concern. Decisions were based on the known effects of the herbicides 

and based on the species they are known to control. The herbicides were selected based on the 

taxonomic relationship between the weed species and the plant. For example, if the weed species 

to be controlled and the plant are in the same taxonomic family or a closely related family, the 

assumption is that herbicides that would affect one would also affect the other. Herbicides were 

selected to have minimum or moderate impacts to the Threatened, Endangered, Candidate and 

Sensitive plants.

Determination of effects: The proposed action will reduce the likelihood of new infestations of 

non-native, competing plants within cliffrose habitat, and therefore the proposed action will have 

long-term beneficial effects. However, we believe there is still a possibility that buffers may not 

make the effects discountable from herbicides that target dicots.

I conclude, therefore, that the implementation of the project may affect, likely to adversely 

affect Arizona cliffrose. 

Arizona Hedgehog Cactus (Echinocereus triglochidiatus var. 

arizonicus)

Background: The Arizona hedgehog cactus was listed as endangered on October 25, 1979, 

without critical habitat designation. No recovery plan has been established for the cactus. The 

Arizona Native Plant Law protects Arizona cacti and the species is also protected from 

international trade by the Convention on International Trade in Endangered Species of Wild 

Fauna and Flora (CITES, 2008). 

The Arizona hedgehog cactus is a large succulent perennial. Mature stems average 8 to 10 cm in 

diameter. Young plants have a single stem and mature plants can have up to 10 stems. There are 

1 to 3 gray or pinkish central spines, the largest deflexed, and 5 to 11 shorter radial spines per 

spine cluster. Flowers are bright red, produced along the side of the stem, and appear in April 

through mid-May.

This species can be difficult to distinguish from other closely related species. Current taxonomic 

work defines the populations in the Miami-Superior area as belonging to this species (USFS, 

1996). 

This cactus occurs in the Interior Chaparral community at elevations of 1,000 to 1,400 m. It is 

often found on relatively open, rocky slopes and steep fissured cliffs, although it may occur in 

fairly dense chaparral. The species seems to be associated with Schultze Granite and Apache 

Leap Tuff, both igneous in origin (USFS, 1996). The species is known from Pinal and Gila 

counties on the Tonto NF and possibly private lands. There is limited information on the status of 

the cactus on the Tonto NF. Surveys conducted on the Tonto NF in conjunction with the Carlota 

Mine Project detected 1,150 plants (USFS, 2004a). These surveys determined a recruitment ratio 

of 1.65 new recruits to each loss showing that the population was both healthy and increasing 

during the 1992 to 1994 surveys (USFS, 1996). Threats to the plant include trampling by 

livestock, mining activities, and wildfire.
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Further description, legal status, distribution and abundance, habitat, life history, population 

dynamics, status in action area and the factors affecting the Arizona hedgehog cactus are 

published in several publications: Heritage Data Management System (AGFD), BO for on-going 

grazing (USFWS, 2002a), BA for Pinaladera Fuels Project (USFS, 2005c), and the programmatic 

biological opinion for the Forest Plan (USFWS, 2005a). The environmental baseline discussions 

contained in these publications are still current and are referenced as the baseline for this 

assessment. The conservation measures included in the programmatic BO have been reviewed 

and incorporated where appropriate.

Analysis of effects: Effects of herbicides to hedgehog cactus are expected to be insignificant and 

discountable, with implementation of mitigation measures. Manual treatments will be used in 

buffer areas where herbicides will not be used. There is a slight probability that young plants 

could be mistaken for weeds, trampled, or inadvertently pulled. Presence of a person on the 

project knowledgeable of identification of the plant’s characteristics at all life stages will 

minimize this risk.

Biological control agents are tested by APHIS for effects to non-target plants prior to being 

permitted in the U.S. Livestock will not be used for invasive plant control in sites where Arizona 

hedgehog cactus is growing.

Implementation of the most aggressive and comprehensive program possible (within budgetary 

constraints) is our best course of action to protect federally-listed and sensitive plants and their 

habitat. This program will include all tools for treatment including herbicides, manual and 

mechanical removal, prescribed fire, cultural treatments, and biological control. A sound 

prevention program that includes every activity on the forest is an important part of this 

alternative.

Arizona Department of Transportation’s program to manage roadside vegetation using herbicides 

was evaluated and approved by a Decision Notice in 2004 (USFS, 2004c). Under this program, 

rights-of-way along federal and state highways within national forests in Arizona may be treated 

with 16 different herbicides: chlorsulfuron, clopyralid, 2,4-D, dicamba, fluroxypyr, glyphosate, 

imazapyr, imazapic, isoxaben, metsulfuron methyl, pendimethalin, picloram, sethoxydim, 

sulfometuron methyl, tebuthiuron, and triclopyr. ADOT expects to use herbicide on less than 

three percent of these rights-of-way annually (5,000 acres), most of this on the northern forests, 

who have the greatest problem with invasive plants. Highways on the Tonto NF that are approved 

for herbicide treatments by ADOT are State Highways 77, 87, 88, 177, 188, 260, 288, and U.S. 

Highways 60 and 70. Under the proposed action, weed infestations that extend beyond the rightof-way for up to 200 feet beyond the ROW will be allowed to be treated by herbicide also, so that 

rights-of-way will be less likely to be re-infested from National Forest lands. Total herbicide use 

will not be greatly increased, as the Tonto NF is proposing annual herbicide use on less than 

0.3 percent of its land. 

The Arizona hedgehog cactus grows within the right-of-way of U.S. Highway 60, from Top of 

the World to the east slope of Pinto Creek Canyon. Hedgehog cactus has been demonstrated to be 

susceptible to direct application of a number of herbicides. In testing by Frank Crosswhite of the 

Boyce Thompson Arboretum in 1995, direct application of one-half to full maximum label rates 

of clopyralid and dicamba to species of hedgehog cactus did not affect survival, but did have an 

adverse effect on plant vigor and growth. Direct application of picloram and tebuthiuron to 

another species of hedgehog cactus adversely affected plant survival (Crosswhite, et al., 1995). 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Effects of herbicide to this plant are currently mitigated by conducting survey for these plants and 

maintenance of buffer areas around each one. The Tonto NF herbicide proposal includes this 

same buffer area for hedgehog cactus. Invasive plant infestation along this highway is currently at 

a very low level in the vicinity of the Arizona hedgehog cactus. With ADOT’s current program of 

herbicide application, and also general character of the habitat (granite boulders), weed 

infestations are not expected to grow in Arizona hedgehog habitat.

Road construction and maintenance by ADOT will continue to be potential threats to Arizona 

hedgehog cactus. Mitigation will be needed for any authorized activities in the part of U.S. 60 

between Top of the World to Pinto Creek. Other potential threats listed in the Conservation 

Assessment and Plan is mining activities and removal by collectors.

Determination of effects: The proposed action will reduce the likelihood of new infestations of 

non-native, competing plants within hedgehog habitat, and therefore the proposed action will 

have long-term beneficial effects. However, we believe there is still a possibility that buffers may 

not make the effects discountable from herbicides that target dicots.

Therefore, the implementation of the project may affect, likely to adversely affect Arizona 

hedgehog cactus. 

Southwestern Willow Flycatcher (Empidonax traillii extimus)

Background: The Southwestern willow flycatcher (flycatcher) was listed as endangered 

March 29, 1995. Critical habitat was designated for the flycatcher on November 18, 2005. One of 

four currently recognized willow flycatcher subspecies (Phillips, 1948; Unitt, 1987), the 

flycatcher is a Neotropical migrant that breeds in the Southwestern United States and migrates to 

Mexico, Central America, and extreme northern South America during the nonbreeding season 

(Phillips, 1948). This subspecies begins arriving on breeding grounds in Arizona and New 

Mexico in late April and early May (Maynard, 1994; Sferra, et al., 1995). Flycatchers generally 

leave the United States by mid-September. It is an insectivorous bird and hunts by perching on a 

branch and making short, direct flights to capture flying insects. Nesting begins in late May and 

early June, and renesting attempts can continue into late July (with late fledging to mid-August). 

Flycatchers lay three to four eggs (smaller clutch sizes with successive renests) and incubate for 

12 to 13 days. Fledging occurs in 12 to 15 days.

Habitat for the flycatcher can be qualified as either occupied, indicating it is currently used for 

breeding; suitable, indicating it contains all the components of breeding habitat but flycatchers 

have not been detected in the area or the area has not been surveyed; potential, indicating the area 

is likely to develop into suitable habitat but is not currently suitable; or migratory, indicating the 

area is likely used by flycatchers migrating into or out of the area. 

The flycatcher is a riparian obligate, nesting along rivers, streams, and other wetlands where 

dense growths of willow (Salix spp.), seep willow (Baccharis salicifolia), buttonbush 

(Cephalanthus occidentalis), boxelder (Acer negundo), saltcedar (Tamarix spp.) or other plants 

are present, often with a scattered overstory of cottonwood (Populus spp.) and/or willow. Canopy 

covers are consistently high throughout its range (Spencer, et al., 1996). Historic nest locations of 

the flycatcher throughout its range are not well known. It is not known whether the habitats where 

they are located today are representative of all the different habitat types they could use for 

nesting. The flycatcher’s use of dense saltcedar at the inflows or perimeter of human-made lakes 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

in Arizona, along with canopy use of mature box elders along water ditches in Southwestern New 

Mexico, are indicative of how this subspecies uses a variety of habitats. Understanding the full 

range of potential flycatcher habitats is complicated by human-caused watershed changes, patchy 

flycatcher distribution, and low flycatcher population numbers.

As populations recover, flycatchers could occupy riparian habitats that today might be considered 

marginal or unsuitable. Patches of dense, multi-storied vegetation found on broad portions of 

otherwise steep, narrow creeks, and can become secondary habitat for nesting flycatchers after 

preferred habitats are occupied. Applying rigid requirements for flycatcher potential habitat based 

on current understanding may not be the most appropriate way to recover the species. The 

following habitat descriptions should be used as guidance, due to the need for further information 

about factors that lead to flycatcher site occupation.

The flycatcher nests in dense riparian vegetation that is generally taller than 3 to 4 meters, 

depending on elevation and vegetation types, with a high percentage of canopy cover, and often 

along rivers, streams, swamps, seeps, irrigation ditches, or other wetlands. Perennial flow, surface 

water, or saturated or moist soil is usually located in, adjacent to, or nearby nesting areas from 

April through September. The distance between the nest and these hydrologic conditions is 

documented to be as far as 120 to 150 m., especially when subsurface flow is keeping soils moist 

around the site. More typically, the nest is within 50 to 100 m. of these hydrologic conditions. 

Farther distances have also been observed, especially in situations where reservoirs have receded 

(USFWS, 2002c).

In Arizona, the flycatcher historically ranged along major river systems and probably major 

tributaries. Historical records exist from the Colorado River near Lee's Ferry and near the Little 

Colorado River confluence (A. Phillips, pers. comm., cited in Unitt, 1987), the Santa Cruz River 

near Tucson (Swarth, 1914; Phillips, 1948), the Verde River at Camp Verde (Phillips, 1948), the 

Gila River at Fort Thomas (W.C. Hunter, pers. comm., cited in Unitt, 1987), the White River, the 

upper and lower San Pedro River (Willard, 1912; Phillips, 1948), and the Little Colorado River 

headwaters area (Phillips, 1948). Currently, resident flycatchers occur along 12 drainages in 

Arizona, including the Colorado, Bill Williams, Verde, Salt, Tonto Creek, Big Sandy, Gila, San 

Pedro, Santa Maria, Little Colorado, San Francisco, and Hassayampa drainages (Paradzick, et al.,

2000; Sferra, et al., 1995; Spencer, et al., 1996). The flycatcher occurs in Arizona on the ApacheSitgreaves and Tonto NFs, and on private land near the Prescott and Coconino NFs.

The Southwestern Willow Flycatcher Recovery Plan describes two Flycatcher Management Units 

on the Tonto National Forest: Verde and Roosevelt (USFWS, 2002c). These units comprise 

flycatcher critical habitat on the Tonto NF. The Verde Management Unit is composed of two 

segments of the mainstream Verde River: one from the East Verde confluence downstream to the 

conservation space boundary of Horseshoe Reservoir, and the other from immediately below 

Horseshoe Reservoir downstream to the USGS gauging station above Bartlett Reservoir. Habitat 

patches at the downstream end of Horseshoe lakebed are mainly 25 to 30 foot tall Gooding’s 

willow surrounded by shorter 3 to 10 foot tall saltcedar interspersed with willow. Farther 

upstream habitat is comprised of 40 to 50 foot tall Gooding’s willow in thin stringers on both 

sides of the lake. Territories upstream of Chalk Mountain are composed mainly of older saltcedar

(30 to 36 feet tall) interspersed with 36 to 45 foot tall Gooding’s willow. The one territory 

upstream of Ister Flat is 30 foot tall Gooding’s willow with 30 to 36 foot tall saltcedar on a higher 

bank adjacent (Dockens, 2007). Habitat along the Verde River between Horseshoe and Bartlett 

Lakes is either stringers of young Gooding’s willow (30 feet tall) up to 10 trees in width or large 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

cottonwood galleries in old river channels away from the current channel with no understory 

(Dockens & Ashbeck, 2006). 

For the Horseshoe Reservoir willow flycatcher territories, surveys conducted since 2002 have 

documented fluctuations of number of adults, territories and pairs. Table 8 shows the trends from 

2002 to 2007 for each year: 

Table 8. Horseshoe Southwestern willow flycatcher data

Year # of adults # of territories # pairs

2002 16 10 6

2003 17 18 18

2004 24 23 15

2005 38 17 7

2006 30 8 to 10 6

2007 16 10 10

Surveys along the Verde River from Childs to Sheep Bridge from the mid-1990s to 2006 have 

documented only one flycatcher. This flycatcher at OK Flat, approximately three miles 

downstream of the Red Creek confluence, responded once to a taped call in May 1999 (Ross, 

1999; Ellis, et al., 2008; Willard, 2009). Flycatchers have not been documented at this site since 

that tentative sighting, although it may provide the best habitat to be found on the Verde River 

between Childs and Horseshoe Lake (Willard, 2009). According to the 1999 survey report, the 

OK Flat site consisted of a long stringer of mature Gooding’s willow 25 to 30 feet in height, 

adjacent to a backwater bordered by cattails. This site also has some depth, with older mature 

cottonwood and willow trees located up to one-eighth mile back from the river. Saltcedar, if it is 

found at this site, occupies much less than five percent of the vegetation canopy.

Survey data from the last two decades is summarized on figure 1. Each dot represents a start or 

stop point of a standardized survey from Ellis and others (2008). The color of the dot represents 

flycatcher absence (green), presence during non-breeding season (yellow), or detections 

exhibiting territorial behavior (red). During river monitoring trips, sites that could potentially 

become suitable habitat for nesting were identified. There are six sites along the Verde River 

(within the Tonto National Forest) that provide suitable or potential habitat for the Southwestern 

willow flycatcher: OK Flat, river left downstream of the East Verde confluence, river right 

upstream of Red Creek, Wet Bottom just upstream of its confluence with the Verde, and two sites 

at Pete’s Cabin Mesa (Todd Willard, personal communications).

The Horseshoe Habitat Conservation Plan emphasizes importance of the area within the 

Horseshoe Reservoir maximum flood pool as habitat for the Southwestern willow flycatcher, 

since there is a limited amount of flycatcher habitat available along the Verde River. (ERO 

Resources Corp & SRP, 2008) Further, the Roosevelt Lake Habitat Conservation Plan, in its 

section about the Verde River, states that studies have shown that the high gradient of the Verde 

both below Horseshoe Dam down to Needle Rock and in the naturally flowing river upstream of 

Horseshoe is too high to support a dense and wide riparian vegetation community (SRP, 2002). 

Surveys in 2009 to 2011 along the Verde River between Horseshoe and Bartlett Reservoirs 

identified the following data on Southwestern willow flycatchers (table 9).
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Table 9. Mesquite & Davenport Areas Southwestern willow flycatcher data (between

Horseshoe & Bartlett Reservoirs) (Silva, 2011). 

Year # of adults # of territories # of pairs

2009 4 4 0

2010 6 6 1

2011 9 7 3

One nest was found in the 2011 survey at Davenport. This nest was in a coyote willow (Silva, 

2011). 

The Roosevelt Management Unit exists along the two arms of inflows into Roosevelt Lake: Tonto 

Creek from its confluence with Rye Creek to the high water mark of Roosevelt Lake; and the Salt 

River from the Cherry Creek confluence to the high water mark of Roosevelt Lake. Critical 

habitat was not designated in the bed of Roosevelt Lake, though this area does contain occupied 

habitat and is important habitat for the flycatcher. The Roosevelt Habitat Conservation Plan 

covers this area and as a result of the protections provided from the Habitat Conservation Plan 

and by the Tonto NF, the area was originally excluded from critical habitat designation. Extensive 

surveys have been conducted at Roosevelt Lake since 1996. Survey information from the 2004 

field season resulted in observations of 41 pairs along Tonto Creek from the Bar X crossing to the 

Orange Peel campground, and 80 pairs on the Salt River (Newell, et al., 2005; Munzer, et al., 

2005). Survey data from 2005 indicates there were 63 pairs on Tonto Creek and 48 pairs on the 

Salt River (English, et al., 2006). 2007 surveys detected 84 resident Southwestern willow 

flycatchers in 53 territories at 10 sites within the Roosevelt MU (USFS, 2007b). 

Roosevelt Lake provides breeding habitat for one of the largest populations of flycatchers in the 

state of Arizona. In this area occupied and suitable habitat for the flycatcher consists of dense 

riparian vegetation, which can contain native willow and cottonwood stands, mixtures of native 

willow/cottonwood and exotic saltcedar, and stands comprised mostly of exotic saltcedar. Native, 

mixed, and non-native vegetation types are all used as breeding habitat by the flycatcher (Sogge, 

et al., 2003). Lake fluctuations due to drought, reservoir draw downs or climatic events make 

available nesting habitat in and around the Roosevelt Lake bottom spatially dynamic. At the Salt 

River inflow to the lake dense riparian vegetation and occupied habitat occurs from the edge of 

the lake upstream to the area of Meddler Point. Traveling upstream on the Salt River from 

Meddler Point, suitable habitat occurs in patches within the floodplain of the river. 

At the Tonto Creek inflow to the lake dense riparian vegetation and occupied habitat occurs from 

the edge of the lake upstream to the A Cross road. Traveling upstream on Tonto Creek from the A 

Cross road, occupied habitat occurs in patches within the floodplain of the creek up to Punkin 

Center. Suitable habitat continues upstream in patches from Punkin Center to Gisela. Greenback 

Creek, which flows into Tonto Creek approximately one mile upstream from Roosevelt Lake, 

contains potential habitat for the flycatcher. Rye Creek, which flows into Tonto Creek 

approximately 22 miles upstream from Roosevelt Lake, contains a narrow band of suitable 

habitat.

The Roosevelt Lake Habitat Recovery Plan covers management within the lakebed of Roosevelt 

Lake, up to its maximum pool elevation of 2,151 feet. Since flycatchers are nesting within 

thickets of saltcedar on both arms of Roosevelt Lake, no removal of saltcedar is proposed for 

these areas. 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Recovery actions recommended in the Southwestern Willow Flycatcher Recovery Plan (USFWS, 

2002c) include the following measures that apply to this invasive plant management program:

1. Manage/reduce exotic species that contribute to increased fire incidence.

2. Coordinate exotic species management efforts with neighboring land and resource 

management agencies

3. Retain native riparian vegetation in floodplains or channels

4. At native dominated sites, retain saltcedar in occupied flycatcher habitat and, where 

appropriate, in suitable but unoccupied habitat, unless there is a trend for steady increase of 

saltcedar

5. Remove exotics in occupied, suitable but unoccupied, and potentially suitable habitats 

dominated by exotics only if: a) underlying causes for dominance of exotics have been 

addressed, b) there is evidence that the exotic species will be replaced by vegetation of higher 

functional value, and c) the action is part of an overall restoration plan.

6. In suitable and potential habitats where exotic species are to be removed through 

chemical or mechanical means, use a temporally staged approach to clear areas so some 

suitable or mature habitat remains throughout the restoration period for potential use by 

flycatchers.

Analysis of effects: Saltcedar, which can provide flycatcher habitat, is an undesirable plant.

Undesirable effects include crowding out native plants, forming mono-typical stands, changing 

river morphology, creating a continuous flammable layer of vegetation, and forming impenetrable 

thickets along riverbanks making it difficult to land river boats. It is targeted for removal as a 

noxious weed in this project, with limitations that will mitigate effects to flycatchers.

Implementing mitigation measures in the will minimize any impacts from treatments that might 

either disturb flycatchers or damage their habitat. These measures include timing restrictions to 

avoid disturbance and/or the use of selective herbicides or hand application of herbicides to 

remove only noxious weeds and leave desirable vegetation. 

Flycatchers prefer to forage over riparian or marshy areas where prey insects are abundant. There 

is virtually no chance that flycatchers would come in contact with herbicides through direct 

application or through brushing against freshly sprayed vegetation as applications near known 

flycatcher habitat would occur outside of the breeding season. It is unlikely flycatcher would 

ingest herbicides that are on insect prey because herbicide applications would be very infrequent, 

and also outside the breeding season. In the rare instance that some herbicides were consumed, 

the risk analysis indicates a low risk from this amount of ingestion. 

Conservation measures reduce likelihood of impact to Southwestern willow flycatcher. In 

addition, saltcedar removal will be timed to avoid the breeding season of the flycatcher (late 

March to September). Because we expect native riparian vegetation to move into niches left by 

the removal of saltcedar, Southwestern willow flycatchers will be assured of continuing nest sites 

and habitat. The combination of low herbicide toxicity, low potential for herbicide exposure, and 

application of the special conservation measures makes the possibility of direct effects to the 

flycatcher from the proposed program of noxious and invasive weed treatments discountable.

However, impacts to flycatcher habitat are likely to adversely affect the flycatcher in the shortterm.

Fire is recognized as a threat to the Southwestern willow flycatcher in the Southwestern Willow 

Flycatcher Recovery Plan (USFWS, 2002c). It is well known that monotypic saltcedar thickets 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

burn with a great intensity that usually leaves a completely burned landscape. In 2005, a patch of 

saltcedar on the Verde River at Davenport Wash burned in a wildfire. This site had been occupied 

by nesting flycatchers the previous year. Flycatchers have not been documented at that site since 

the wildfire. (ERO Resources Corp & SRP, 2008). Fire in riparian areas of the southwest was 

probably a rare event until the advent of saltcedar (Busch & Smith, 1993). A study on the Lower 

Colorado River floodplain found that fire was more prevalent in the saltcedar-dominated areas 

than in areas dominated by mesquite or cottonwood/willow (Busch, 1995). Removal of saltcedar

so that cottonwood and willow can successfully perpetuate a native riparian community will serve 

to prevent wildfire from burning any Southwestern willow flycatcher nesting habitat that may 

develop. This also fulfills a recommendation of the Recovery Plan to reduce exotic species that 

contribute to fire incidence.

In accordance with the threat of fire there is another threat to saltcedar and that threat is the salt 

cedar beetle (Diorhabda elongate). This beetle is spreading from Utah, Nevada, and Texas. There 

is no timetable on when it will arrive in Central Arizona. This will have a substantial effect on 

saltcedars within the Tonto National Forest. The Salt River and Roosevelt Lake will sustain the 

onslaught of this beetle due to the high number and density of tamarisk.

Increasing abundance of saltcedar has been observed on the Verde River and other smaller 

streams (Dexter Allen, Laura Moser, Patti Fenner, Douglas Green, Don Sullivan, personal 

communications). Even on unregulated streams, saltcedar is able to out-compete native riparian 

trees, as its seed dispersal season is at least four times as long, continuing through summer 

monsoon months when occasional high stream flows lay down new beds of sediment conducive 

to germination.

Sites intended for saltcedar removal will not need restoration, as there are still abundant native 

riparian trees that will naturally re-occupy them. A three-forest program will be in effect once the 

Tonto NF begins saltcedar control on the Verde River. The Coconino and Prescott national 

forests have been controlling saltcedar and Arundo on the Verde upstream of the Tonto NF for 

three years. Low budgets and limited time and season for river rangers to treat saltcedar guarantee 

a temporally-staged treatment for removal of saltcedar on the Verde River. 

Both the Recovery Plan and the Verde Wild and Scenic River Comprehensive Management Plan 

call for coordinated exotic species management efforts among the three forests that manage the 

Verde River (USFWS, 2002c & U.S. Forest Service, 2004d). Management direction for invasive 

exotic species given in the Verde Wild and Scenic River CMP is: “Invasive plant species should 

be managed so they do not displace or diminish native plant species.” The Coconino and Prescott 

national forests have an active program to remove saltcedar from along the Verde River upstream 

from the Tonto NF. In order to conduct consistent management on this river, the Tonto NF

proposes to treat saltcedar on the Verde below these two national forests using the same methods 

and mitigation measures.

Most smaller streams that are occupied by saltcedar are not completely infested, but still have 

significant native tree components. 

The conservation measures for the flycatcher listed above would protect insect prey in aquatic 

environments. 

Certain sites occupied extensively by flycatchers, which are characterized by saltcedar thickets, 

pose a unique situation on the Tonto NF. Saltcedar thickets have developed at both Tonto Creek
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

and Salt River inflows into Roosevelt Lake, as a result of fluctuating water levels and operation 

of the dam. No saltcedar control is proposed for either of these areas, due to the fact that it is 

important habitat for this endangered bird, and the futility of native vegetation recovery following 

any saltcedar removal. The Verde River inflow into Horseshoe Reservoir has retained a riparian 

vegetation community dominated by native tree species since dam construction was completed in 

1946. This could be due to the fact that, since Horseshoe is such a shallow reservoir, it is not 

often used for water storage. For this reason, fluctuating water levels have not affected vegetation 

at the upstream end of the reservoir to the extent they have at Roosevelt. Cottonwood and willow 

are still the dominant vegetation. 

Proposed Critical Habitat: These are new areas that are being proposed within the Tonto 

National Forest.

Pinal Creek: 5.7 km (3.5 mi.) essential segment of Pinal Creek that occurs downstream of 

the water treatment plant north of the Town of Globe. 

Roosevelt Lake Bed and Horseshoe Lake Bed

Proposed Primary Constituent Elements:

1. Riparian vegetation. Riparian habitat in a dynamic river or lakeside, natural or manmade 

successional environment (for nesting, foraging, migration, dispersal, and shelter) that is 

comprised of trees and shrubs (that can include Goodding’s willow, coyote willow, 

Geyer’s willow, arroyo willow, red willow, yewleaf willow, pacific willow, boxelder, 

tamarisk, Russian olive, buttonbush, cottonwood, stinging nettle, alder, velvet ash, poison 

hemlock, blackberry, seep willow, oak, rose, sycamore, false indigo, Pacific poison ivy, 

grape, Virginia creeper, Siberian elm, and walnut) and some combination of: 

a. Dense riparian vegetation with thickets of trees and shrubs that can range in height 

from about 2 m to 30 m (about 6 to 98 ft.). Lower-stature thickets (2 to 4 m or 6 to 13 

ft. tall) are found at higher elevation riparian forests and tall-stature thickets are 

found at middle- and lower-elevation riparian forests; 

b. Areas of dense riparian foliage at least from the ground level up to approximately 4 

m (13 ft.) above ground or dense foliage only at the shrub or tree level as a low, 

dense canopy; 

c. Sites for nesting that contain a dense (about 50 percent to 100 percent) tree or shrub 

(or both) canopy (the amount of cover provided by tree and shrub branches measured 

from the ground); 

d. Dense patches of riparian forests that are interspersed with small openings of open 

water or marsh or areas with shorter and sparser vegetation that creates a variety of 

habitat that is not uniformly dense. Patch size may be as small as 0.1 ha. (0.25 ac.) or 

as large as 70 ha (175 ac.); 

2. Insect prey populations. A variety of insect prey populations found within or adjacent to 

riparian floodplains or moist environments, which can include: flying ants, wasps, and 

bees (Hymenoptera); dragonflies (Odonata); flies (Diptera); true bugs (Hemiptera); 

beetles (Coleoptera); butterflies, moths, and caterpillars (Lepidoptera); and spittlebugs 

(Homoptera). 

Analysis of effects on Primary Constituent Elements: Newly proposed PCEs are very 

similar to existing PCEs and will be analyzed with existing PCEs.
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

1. Riparian habitat in a dynamic successional riverine environment (for nesting, foraging, 

migration, dispersal, and shelter) that comprises:

a. Trees and shrubs that include Gooding’s willow (Salix gooddingii), coyote willow 

(Salix exigua), Geyer’s willow (Salix geyerana), arroyo willow,(Salix lasiolepis), red 

willow (Salix laevigata), yewleaf willow (Salix taxifolia), Pacific willow (Salix 

lasiandra), boxelder (Acer negundo), tamarisk (Tamarix ramosissima), Russian olive 

(Eleagnus angustifolia), buttonbush (Cephalanthus occidentalis), cottonwood 

(Populus fremontii), stinging nettle (Urtica dioica), alder (Alnus rhombifolia, Alnus 

oblongifolia, Alnus tenuifolia), velvet ash (Fraxinus velutina), poison hemlock 

(Conium maculatum), blackberry (Rubus ursinus), seep willow (Baccharis 

salicifolia, Baccharis glutinosa), oak (Quercus agrifolia, Quercus chrysolepis), rose 

(Rosa californica, Rosa arizonica, Rosa multiflora), sycamore (Platinus wrightii), 

false indigo (Amorpha californica), Pacific poison ivy (Toxicodendron 

diversilobum), grape (Vitus arizonica), Virginia creeper (Parthenocissus 

quinquefolia), Siberian elm (Ulmus pumila), and walnut (Juglans hindsii).

Tamarisk, the species targeted for removal, is only one of the species listed in this PCE. We 

estimate that 90 percent of the treatment area is tamarisk intermingled among natives also 

listed in this PCE (Salix, Baccharis, and Populus being the most abundant species). We 

expect native vegetation to occupy space within one to two years. This is termed “passive 

restoration” in appendix H of the Recovery Plan (USFWS, 2002c). Removal of saltcedar

complies with recommendations in the Southwestern Willow Flycatcher Recovery Plan.

Because we are removing plants from a species listed in this PCE, the proposed action will 

adversely affect this PCE.

b. Dense riparian vegetation with thickets of trees and shrubs ranging in height from 

2 m to 30 m (6 to 98 ft.). Lower-stature thickets (2 to 4 m. or 6 to 13 ft. tall) are 

found at higher elevation riparian forests and tall-stature thickets are found at middleand lower elevation riparian forests; 

We estimate that we will remove some tamarisk plants that are in the range 6 to 15 feet. These 

plants comprise a very small percentage of the vegetation. Their removal is recommended in 

the Recovery Plan (see discussion above). Removal of individuals of this species will cause 

an adverse effect of this PCE in the short term. 

c. Areas of dense riparian foliage at least from the ground level up to approximately 

4 m. (13 ft.) above ground or dense foliage only at the shrub level, or as a low, dense 

tree canopy; 

The proposed action will reduce riparian foliage density in a maximum of 10.7 acres of 

critical habitat annually in the short term. Consequently, the proposed action will be likely to 

adversely affect this PCE.

d. Sites for nesting that contain a dense tree and/or shrub canopy (the amount of cover 

provided by tree and shrub branches measured from the ground) (i.e., a tree or shrub 

canopy with densities ranging from 50 percent to 100 percent); 

Because some tamarisk we propose to remove can reach up to 30 feet, we expect to adversely 

affect this PCE in the short term.
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

e. Dense patches of riparian forests that are interspersed with small openings of open 

water or marsh, or shorter/sparser vegetation that creates a mosaic that is not 

uniformly dense. Patch size may be as small as 0.1 ha (0.25 ac.) or as large as 70 ha. 

(175 ac.);

Although we expect to reduce the density of some riparian forests, we will not uniformly 

reduce all density of patches, nor would we expect to change the mosaic nature of the riparian 

forests. We expect that 90 percent of the treatment area consists of tamarisk intermingled 

within native vegetation. The proposed action will reduce the density of these patches. In the 

other 10 percent of treated areas, there may be denser patches of tamarisk that consist no more 

than 0.25 of an acre. Because the proposed action will not uniformly reduce the density of 

vegetation patches and because we do not expect to impact tamarisk patch sizes larger than 

0.25 acres, we will not approach the scale where we would expect to negatively impact this 

PCE.

2. A variety of insect prey populations found within or adjacent to riparian floodplains or 

moist environments, including: flying ants, wasps, and bees (Hymenoptera); dragonflies 

(Odonata); flies (Diptera); true bugs (Hemiptera); beetles (Coleoptera); butterflies/moths 

and caterpillars (Lepidoptera); and spittlebugs (Homoptera). 

A number of studies have investigated insect prey availability for generalist insectivores such as 

the Southwestern willow flycatcher, in various riparian habitat types. Several researchers 

observed that saltcedar, like many introduced plants, often sustains a relatively depauperate 

assemblage of insects and other arthropods, compared to the native cottonwood and willow. This 

is due to the fact that it was transported to this country without many of its associated herbivores.

(Shafroth, et al., 2005; Liesner, 1971; Stevens, 1985; &Miner, 1989). Some data from the lower 

Colorado River suggested abundances of several of the most common insect families in riparian 

areas occurred in comparable or greater abundance on saltcedar than on most native vegetation.

However this same study found few native insects that fed on saltcedar (Anderson, et al., 2004). 

However, tamarisk supports a wide variety of insect pollinators, which include honey bees and 

wasps (Hymenoptera), and detritus-feeding flies (Diptera) (Wiesenborn, et al., 2008), which 

compose this PCE. Removing tamarisk is likely to reduce pollinating hymenoptera and Diptera. 

Willow also supports an impressive array of insects, spiders and caterpillars (Arizonensis, 2009). 

Cottonwood supports leaf beetles, a variety of Lepidoptera, leaf miners, grasshoppers, bagworms, 

webworms, cutworms, midges, and a wide variety of borer insects, aphids, spittlebugs, tree 

crickets, and cicadas (Ostry, et al., 1988). 

A study conducted at Roosevelt Lake from 2000 to 2004 found that although arthropod 

communities varied among riparian habitats (exotic, native, and mixed), differences in the diet of 

Southwestern willow flycatcher were detected in only one year in five. The greatest difference in 

arthropods in habitat type was that Araneae (spiders) and Lepidoptera were more prevalent in 

native habitats and Cicadellidae (leaf hoppers) in exotic habitats. They suspected this was due to 

the prevalence of the saltcedar-obligate tamarisk leafhopper in the exotic riparian habitat (Durst, 

et al., 2008). 

Because we propose to remove tamarisk, it would effectively reduce pollinating hymenoptera and 

Diptera listed in this PCE. Other native species may have pollinators, but it may not be in quality 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

of quantity of tamarisk pollinators. Therefore, the proposed action is likely to adversely affect this 

particular PCE.

Determination of effects: Implementation of the Noxious Weed Plan likely adversely affect 

Southwestern willow flycatcher .

Implementation of the Noxious Weed Plan is likely to adversely affect Southwestern willow 

flycatcher critical habitat and proposed critical habitat because it adversly affected many 

components of the PCEs.

Yuma Clapper Rail (Rallus longirostris yumanensis) 

Background: The Yuma clapper rail is one of seven subspecies of Rallus longirostris. The bird 

was listed as Endangered in 1967 with a recovery plan finalized in 1983. No critical habitat is 

designated. From about 1970 through 1983, an estimated 1,700 breeding Yuma clapper rails 

occurred from the Colorado River delta to Arizona, including the birds around the Salton Sea in 

California. More recent data estimates 500 to 1,100 birds in the lower Colorado River Basin, 

including 9 to 55 birds on the Gila River near Phoenix, Arizona. Yuma clapper rail observations 

on the Tonto NF are from long ago. Limited habitat exists along the lower Salt and Verde rivers.

Occasional sightings have been reported at Roosevelt Lake.

Affected habitat description: The elusive rail occupies marsh-like situations around rivers, 

ponds, and bogs where emergent vegetation such as cattails, bulrush, and reed grass occur 

(Eddleman, 1989; Todd, 1977). Densities of rails are highest in light cattail stands, followed in 

descending order by light bulrush stands, dense bulrush stands, and dense cattail stands. Stands 

dissected with narrow channels of flowing water have higher densities of birds. The bird begins 

nesting in February, with egg-laying occurring from March to July. Clutch size is typically 6 to 8 

eggs, and young are precocial.

Analysis of effects: The Yuma clapper rail climbs around on flattened, floating materials and 

feeds mainly on crayfish although other invertebrates, arthropods, and fish are eaten as well 

(Radd, 1998). Nests can be found in a variety of situations within emergent wetland habitats as 

long as stable substrates are available (USFWS, 1996). The general mitigations and BMPs for this 

program will protect food sources in aquatic environments. By only applying aquatic approved 

herbicides and limiting the timing of application based on the possibility of precipitation, the 

likelihood of any Yuma clapper rail being impacted by any herbicide applications is discountable

Determination of effects: The proposed action is not likely to adversely affect the Yuma 

clapper rail.

Mexican Spotted Owl (Strix occidentalis lucida)

Background: The Mexican spotted owl was listed as a threatened species in 1993. The primary 

reasons for listing were the threat of even-aged timber harvest and threat of catastrophic wildfire. 

On August 31, 2004, critical habitat for the Mexican spotted owl was designated. The U.S.F.W.S.

appointed the Mexican Spotted Owl Recovery Team in 1993, which produced the Recovery Plan 

for the Mexican spotted owl in 1995 (USFWS, 1995a). 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

The Mexican spotted owl is distinguished from the California and northern subspecies chiefly by 

plumage and geographic distribution. The Mexican owl is mottled in appearance with irregular 

white and brown spots on its abdomen, back, and head. The spots are larger and more numerous 

than in the other two subspecies, giving it a lighter appearance. Unlike most owls, spotted owls 

have dark eyes. The Mexican subspecies has the largest geographic range of the three. It extends 

from the southern Rocky Mountains in Colorado and the Colorado Plateau in southern Utah, 

southward through Arizona and New Mexico, and discontinuously through the Sierra Madre 

Occidental and Oriental to the mountains at the southern end of the Mexican Plateau.

Owls breed sporadically and do not nest every year. This owl’s reproductive chronology varies 

somewhat across its range. In Arizona, courtship apparently begins in March with pairs roosting 

together during the day and calling to each other at dusk (Ganey, 1988). Eggs are laid in late 

March or typically early April. Incubation begins shortly after the first egg is laid, and is 

performed entirely by the female (Ganey, 1988). The incubation period for the owl is assumed to 

be 30 days (Ganey, 1988). During incubation and the first half of the brooding period, the female 

leaves the nest only to defecate, regurgitate pellets, or receive prey from the male, who does all or 

most of the foraging (Forsman, et al., 1984; Ganey, 1988). Eggs usually hatch in early May, with 

nestling owls fledging 4 to 5 weeks later, and then dispersing in mid-September to early October 

(Ganey, 1988).

The owl's range covers much of the Southwestern U.S. and Mexico, but owls do not occur 

uniformly throughout this area. They occur in disjunct localities that correspond to isolated 

forested mountain systems, canyons, and in some cases steep rocky canyon lands. Surveys have 

revealed that the species has an affinity for older well-structured forests in what is otherwise a 

diverse array of landscapes.

Spotted owls nest, roost, forage, and disperse in an array of biotic communities. Mixed conifer 

forests are commonly used throughout most of the range. In general, these forests are dominated 

by Douglas-fir and/or white fir, with codominant species including Southwestern white pine, 

limber pine, and ponderosa pine. The understory often contains the above coniferous species as 

well as broadleaved species such as Gambel oak, maples, boxelder, and New Mexico locust. In 

southern Arizona and Mexico, Madrean pine-oak forests are also used commonly. These forests 

are typically dominated by an overstory of Chihuahua and Apache pines in conjunction with 

species such as Douglas-fir, ponderosa pine, and Arizona cypress. Evergreen oaks are typically 

prominent in the understory (USFWS, 1995a). 

Habitat-use patterns vary throughout the range and with respect to owl activity (nesting, roosting, 

or foraging). In the northern part of the range, including southern Utah, southern Colorado, and 

far northern Arizona and New Mexico, owls occur primarily in steep-walled, rocky canyons. 

Along the Mogollon Rim in Arizona and New Mexico, habitat use is less restricted, and spotted 

owls occur in mixed-conifer forests, ponderosa pine-Gambel oak forests, rocky canyons, and 

associated riparian forests. South of the Mogollon Rim and into Mexico a still wider variety of 

habitat types are used, including mixed-conifer, Madrean pine-oak, and Arizona cypress forests, 

encinal oak woodlands, and associated riparian forests. Much of this regional variation in habitat 

use likely results from differences in regional patterns of habitat and prey availability (USFWS, 

1995a). 

The Tonto NF encompasses the lower watersheds of the Salt and Verde Rivers and is split 

between two MSO recovery units; the Upper Gila Mountain Recovery Unit (41 Protected 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Activity Centers, or PACs) and the Basin and Range West Recovery Unit (31 PACs). Most PACs 

are associated with the Mogollon Rim and the Mazatzal, Sierra Ancha, and Pinal mountain ranges 

(USFWS, 2002a). 

A detailed account of the taxonomy, biology, and reproductive characteristics of the spotted owl 

is found in the final rule listing it as a threatened species (USFWS, 1993) and in the Recovery 

Plan for the Mexican Spotted Owl (USFWS, 1995a). 

Mexican Spotted Owl Critical Habitat

Critical habitat for the Mexican spotted owl was designated on February 1, 2001. No critical 

habitat areas were designated on national forests in Arizona (USFWS, 2001a). However, under an 

October 10, 2003, court decision, the U.S.F.W.S. reopened comments on the original proposal 

upon which the February 1, 2001, designation was based (USFWS, 2003). This proposal

contained 3,287,339 acres of National Forest System lands in Arizona. Within that area, actual 

critical habitat is limited to areas that meet the definition of protected and restricted habitat in the 

Mexican Spotted Owl Recovery Plan. Some of the critical habitat areas are within the action area 

for this program. The final rule for MSO critical habitat designation was issued in 2004 (USFWS, 

2004e). In determining which areas to propose as critical habitat, the U.S.F.W.S. is required to 

consider those physical and biological features (primary constituent elements) that are essential to 

conservation of the species and that may require special management considerations or 

protection. The U.S.F.W.S. determined the primary constituent elements for Mexican spotted owl 

from studies of their habitat requirements and the information provided in the Mexican Spotted 

Owl Recovery Plan (U.S.F.W.S., 1995a and references therein). Since owl habitat can include 

both canyon and forested areas, the U.S.F.W.S. identified primary constituent elements in both 

areas. 

Analysis of effects: The potential herbicide exposure scenario for MSO would involve an owl 

consuming a prey species that had previously consumed treated vegetation. No risk assessment 

has been accomplished for MSO, but the Risk Assessment calculated the potential exposure for 

American kestrel, another bird of prey. The estimated risk to birds from all herbicides in the risk 

assessment was well below the hazard quotient of 1.0, with the exception of dicamba, which will 

not be used in MSO PACs. As stated above, the herbicides evaluated show little tendency to bioaccumulate, so long-term persistence in the food chain is not considered to be a significant 

potential effect. 

Roads and trails in the action area pass through suitable Mexican spotted owl habitat and owls, as 

PAC designations indicate, can occupy habitats directly adjacent to these travel ways. These 

travel ways are typically the routes by which noxious and invasive plants enter the PAC habitat 

whether on a hiker’s boot, a dog’s fur, an ATV tire tread, or a horse’s hoof or coat. Most weed 

treatments would be concentrated along these travel ways where the undesirable plants occur. 

However, there is virtually no chance that Mexican spotted owls would come in contact with 

herbicides either from direct application or from brushing against freshly sprayed vegetation 

because owls are nocturnal and spraying would be done in the daytime. Also, restricting 

treatments to occur at least 1⁄4 mile from occupied nests during the breeding season reduces the 

potential for any MSO to come in contact with freshly sprayed herbicides or to be disturbed by 

treatment activities. Likewise, the prey of owls, mostly rodents, tends to be nocturnal and they 

also are unlikely be directly sprayed. Therefore, owls would probably not ingest herbicides that 

are on prey they capture in rights-of way. Some areas may have herbicide treatments up to six 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

times a year if a variety of weeds occur within the same area. The herbicide risk analysis indicates 

a low risk to either the owl or its prey from this amount of herbicide exposure. Owls in or near 

treatment areas are likely habituated to noise from passing vehicles, hikers, livestock, or ATVs 

(all-terrain vehicles) and would not likely be disturbed from the brief presence of people with 

spray equipment. 

The herbicides that will be used within MSO PACs are those with low (Class 0 or 1) ecotoxicity 

rating and those with no eye irritation to predatory avian. However, dicamba has a ecotoxitiy 

rating of Class 2, and we plan to use it outside of PACs. But because we plan to spray during the 

day when MSO are inactive, the effects of dicamba on MSO eyes are discountable. 

But because there are no buffers with plants that may provide seeds and fruits for MSO prey (see 

Primary Constituent Analysis), the proposed action’s effects due to herbicide on MSO food prey 

are neither discountable nor insignificant.

Noxious and invasive weed treatments reduce existing weed populations and allow for native 

plant species populations to develop that would be favorable for prey species habitat. Therefore, 

the proposed action may improve Mexican spotted owl foraging habitat.

Surveys would be done to determine the extent of noxious weed infestations in and treatments 

would be limited to the areas needed to control these infestations. These spot applications would 

be done with low pressure vehicle-mounted systems, backpack sprayers, and other hand-held 

devices that would keep herbicide effects within the target area. All of the targeted noxious weeds 

are annuals or herbaceous perennials. These plants generally grow in open disturbed habitats and 

not in the areas of 40 percent canopy cover that characterize Mexican spotted owl primary 

constituent elements. However, noxious weeds may occur in herbaceous communities that 

provide for the needs of some Mexican spotted owl prey species. Here, noxious weeds reduce 

species diversity and habitat quality for prey species. The removal of noxious weeds would 

benefit habitat for prey species and therefore have a beneficial effect on the primary constituent 

element of adequate levels of residual plant cover to maintain fruits, seeds, and allow plant 

regeneration. Treatments are not expected to have any impact on the primary constituent elements 

of canyon habitat. 

Effects Analysis to Primary Constituent Elements of MSO Critical Habitat 

The proposed action affects the Primary Constituent Elements related to forest structure in the 

following ways:

(1) A range of tree species, including mixed conifer, pine-oak, and riparian forest 

types, composed of different tree sizes reflecting different ages of trees, 30 to 

45 percent of which are large trees with a trunk diameter of 12 inches (0.3 meters) or 

more when measured at 4.5 feet (1.4 meters) from the ground; 

The proposed action will not likely affect the above Primary Constituent Element. There is 

a small possibility that even with direct application on the target weed species, some 

neighboring trees may be negatively affected by the herbicide. However, the scale of effect 

for this affect is likely to be insignificant to affect the range of tree species.

(2) A shade canopy created by the tree branches covering 40 percent or more of the 

ground; and 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

The proposed action will not likely affect the above Primary Constituent Element. See 

“range of species” PCE.

(3) Large dead trees (snags) with a trunk diameter of at least 12 inches (0.3 meters) 

when measured at 4.5 feet (1.4 meters) from the ground.

The proposed action will have no effect to the above Primary Constituent Element.

The proposed action affects the Primary Constituent Elements related to maintenance of adequate 

prey species in the following ways:

(1) High volumes of fallen trees and other woody debris; 

The proposed action will have no effect to the above Primary Constituent Element.

(2) A wide range of tree and plant species, including hardwoods; and 

The proposed action will not likely affect the above Primary Constituent Element. There is 

a small possibility that even with direct application on the target weed species, some 

neighboring trees may be negatively affected by the herbicide. However, the scale of effect 

is likely to be insignificant to affect the range of tree species.

(3) Adequate levels of residual plant cover to maintain fruits, seeds, and allow plant 

regeneration. 

The proposed action will likely adversely affect this Primary Constituent Element. There 

are no buffers that would protect common plants that may produce fruits or seeds for prey.

Consequently, plants adjacent to the target weeds could be impacted by the herbicide.

However, in the long term, eradicating the weed could reduce the overall competition from 

non-natives and could benefit this Primary Constituent Element.

The proposed action affects the Primary Constituent Elements related to canyon habitat in the 

following ways:

(1) Presence of water (often providing cooler and often higher humidity than the 

surrounding areas); 

The proposed action will not likely affect the above Primary Constituent Element.

Although we intend to draft water for backpack sprayers, it will not approach the scale to 

where we would remove all the water and impact the humidity of the surrounding area.

(2) Clumps or stringers of mixed conifer, pine-oak, piñyon-juniper, and/or riparian 

vegetation; 

The proposed action will not likely affect the above Primary Constituent Element. There is 

a small possibility that even with direct application on the target weed species, some 

adjacent riparian vegetation may be negatively affected by the herbicide. However, the 

scale of effect for this affect is likely to be insignificant to entire clumps or stringers of 

riparian vegetation.

(3) Canyon wall containing crevices, ledges, or caves; and 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

The proposed action will have no effect on the above Primary Constituent Element.

(4) High percent of ground litter and woody debris.

The proposed action will have no effect on the above Primary Constituent Element.

Determination of effects: The preferred alternative for noxious and invasive weed treatments 

with the conservation measures may affect, but not likely to adversely affect the Mexican 

spotted owl and its habitat.

Implementation of the Noxious Weed Plan may affect, but not likely to adversely affect

Mexican spotted owl critical habitat.

Yellow-billed Cuckoo (Coccyzus americanus occidentalis)

Background: The Distinct Population Segment (DPS) of yellow-billed cuckoo that lives in the 

western U.S. was retained by the Fish and Wildlife Service as Candidate for federal listing in 

2001 (USFWS, 2001b). It was, however, given only Priority 6 for listing, due to “non-imminent 

threats of high magnitude” to its continued existence. Threats to the cuckoo streamside habitat 

included “conversion to agriculture, [unmanaged] grazing, and competition from nonnative plants 

such as saltcedar, river management, including altered flow and sediment regime, and flood 

control practices, such as channelization and bank protection” (USFWS, 2001b). In 2007, a 

higher priority for listing was assigned, and the list of threats modified to include use of 

pesticides on adjacent agricultural lands and groundwater pumping (USFWS, 2007c). Pesticides 

were listed as a threat in this situation due to direct poisoning of nestlings, and reduction in prey 

populations that occurs with widespread spraying of pesticides. 

The western yellow-billed cuckoo is a late migrant and summer resident requiring large tracts of 

undisturbed riparian deciduous forests where willow, cottonwood, sycamore, or alder occur. 

Cuckoo nests have also been found in areas of tall mesquite with isolated cottonwood trees. 

Cuckoos prefer dense vegetation, which creates a humid environment. Nests are loose twig 

structures built on a horizontal limb of trees, shrubs, and sometimes vines. Nests are in thick 

undergrowth or in trees, typically 4 to 8 feet above ground. The yellow-billed cuckoo feeds on 

cicadas, katydids, caterpillars, and other large prey. The breeding season for this bird begins 

around June 15 and lasts until the middle to end of August. They have been found along the 

Verde River and low elevation, small streams (AGFD, 2002a). During the 2007 season 

Southwestern willow flycatcher surveys, cuckoos were detected near the Tonto Creek inflow into 

Roosevelt Lake, and near the Cherry Creek confluence with the Salt River (USFS, 2007b). 

Analysis of effects: Over time, if weeds were allowed to spread unchecked, tree structure 

along riparian areas could change from cottonwoods, willows, and other associated species to a 

near monoculture of tamarisk. This would reduce nest areas and forage for the yellow-billed 

cuckoo. Reduction in native riparian tree habitat and its conversion to saltcedar monocultures is 

listed as a threat to the cuckoo (USFWS, 2001b). 

Breeding season timing restrictions and buffers around nesting areas would make any disturbance 

or toxicity impacts to the yellow billed cuckoo from weed treatments unlikely to occur. Treatment 

of saltcedar within cuckoo habitat will be conducted using cut-stump spot treatments, so drift of 

herbicide is very unlikely to occur. 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

The herbicides that will be used within riparian areas that would be habitat for yellow-billed 

cuckoo are those with low (Class 0 or 1) ecotoxicity rating and those with no eye irritation to 

avian species. The combination of low herbicide toxicity, low potential for herbicide exposure, 

and low likelihood of direct disturbance makes the possibility of adverse affects to the yellowbilled cuckoo insignificant and discountable.

FS seeks any additional conservation recommendations for the yellow-billed cuckoo.

Lesser Long-nosed Bat (Leptonycteris curasoae yerbabuenae)

Background: On September 30, 1988, the lesser long-nosed bat was listed as an endangered 

species under the ESA. Critical habitat has not been designated for the species. A recovery plan 

for the lesser long-nosed bat (LLNB) was signed March 4, 1997. According to the Recovery Plan 

for this species, considerable controversy has developed between members of the scientific 

community familiar with the lesser long-nosed bat since the listing in 1988. The debate among 

scientists regarded the actual population size and the listing status for this species (USFWS, 

2005a). 

The lesser long-nosed bat is a medium-sized bat, about 2.8 to 3.8 inches in length. Suitable day 

roosts and associated concentrations of food plants are crucial for the lesser long-nosed bat 

(USFWS, 1995b). Caves and mines are used as day roosts. Factors that make roost sites useable 

have not yet been identified. The species seems sensitive to human disturbance and alternate roost 

sites may be critical when disturbance occurs. There is potential for routes maintained as part of 

grazing management activities to facilitate public access to roosts. Recreationists or others that 

access active roosts can displace bats, temporarily or permanently. 

The lesser long-nosed bat flies long distances from roosts to forage. Night flights from maternity 

colonies to food have been documented in Arizona at 15 miles and in Mexico at 25 miles and 

38 miles one way (Dalton, et al., 1994; V. Dalton, Tucson, pers. comm., 1997). A substantial 

portion of the lesser long-nosed bats at the Pinacate Cave in Sonora fly 25 to 31 miles each night 

to forage in Organ Pipe Cactus National Monument (USFWS, 1995b). Horner, et al., found that 

these bats flew 30 to 36 miles round trip between an island maternity roost and the mainland in 

Sonora; the authors suggested the bats regularly flew at least 50 to 63 miles each night (1990). 

The lesser long-nosed bat consumes nectar and pollen of paniculate agave flowers and the nectar, 

pollen, and fruit produced by columnar cacti. The agaves include Palmer's agave (Agave 

palmeri), Parry's agave (A. parryi), desert agave (A. deserti), and amole (A. schotti). Amole is 

considered to be an incidental food source. The cacti include saguaro (Carnegiea giganteus) and 

organ pipe cactus (Stenocereus thurberi). If forage resources are limiting at certain times or 

places, it is anticipated that numbers of bats may be reduced or bats may have to fly farther from 

roosts to obtain sufficient resources. 

No records exist for lesser long-nosed bat on the Tonto NF. The nearest confirmed records are 

from the Phoenix area and a possible record in the McDowell Mountains, the former record was 

20 to 30 miles west and the later approximately ten miles west of the Tonto NF. The Phoenix 

records are of immature females, August 30 (Phoenix) and September 16 (Glendale), while the 

McDowell Mountains record was an undetermined sex on July 26. The records are all late in the 

season, which suggests the bats were transients. The nearest known roost is in the Picacho 

Mountains, which is greater than 40 miles south-southeast from the action area.
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Biological Assessment of the Integrated Treatment of Noxious Plant Program

Analysis of effects: Project impacts that would potentially affect lesser long-nosed bat are 

those that would significantly reduce the abundance or availability of paniculate agaves. Direct 

application of herbicide to agaves could kill or injure individual plants, as could mechanical 

treatments. Agaves potentially occur in the proximity of weed treatment sites at lower elevations 

on the forest; however, proposed treatments will be directed at individual weed plants. Agaves are 

conspicuous and can be easily avoided. Indirect exposure to bats as a result of consuming 

accidentally treated plant parts is unlikely because flowers and fruits are borne at the tips of the 

flowering stalks, well above the ground. Due to the low likelihood of occurrence on the Tonto 

NF, no disturbance effects to LLNB are anticipated as a result of the proposed action. Since no 

direct or indirect effects are identified, no cumulative effects are anticipated.

Determination of effects: The proposed action “may affect, not likely to adversly affect” due 

to discountable effects. 

Chiricahua Leopard Frog (Rana chiricahuensis) 

Background: The Chiricahua leopard frog was listed as Threatened in June 2002 (67 FR 

40790). AGFD biologists conducted 871 surveys at 679 localities, 98 of them historical. To date, 

the Chiricahua leopard frog appears absent from 82 percent of the historical localities surveyed 

since 1990 (http://biology.usgs.gov). Chiricahua leopard frogs were observed in 21 northern sites 

from 1994 to 2001 (USFWS, 2002b). Numerous surveys were conducted all over the Tonto NF in 

1992 and 1993 by AGFD (Sredl, et al., 1994). Since the frog was listed in 2002, the Tonto NF has 

conducted extensive surveys for this species. Four extant populations are found on the Pleasant 

Valley Ranger District and Payson Ranger District possibly has one extant population. Two 

additional sites on the Pleasant Valley Ranger District were repatriated with frogs in 2006 and it 

appears that one of these sites continues to support frogs. There are no known extant populations 

of Chiricahua leopard frog on Globe, Mesa, or Tonto Basin ranger districts (USFWS, 2005a). 

Northern populations of the Chiricahua leopard frog along the Mogollon Rim and in the 

mountains of west-central New Mexico are disjunct from those in southeastern Arizona, 

Southwestern New Mexico, and Mexico.

The Chiricahua leopard frog is distinguished from other members of the Rana pipiens complex by

a combination of characters, including a distinctive pattern on the rear of the thigh consisting of 

small, raised, cream-colored spots or tubercles on a dark background; dorsolateral folds that are 

interrupted and deflected medially; stocky body proportions; relatively rough skin on the back 

and sides; and oftentimes green coloration on the head and back. Leopard frogs as a group are 

habitat generalists that can adapt to a variety of wetland situations. Chiricahua leopard frog 

habitat includes lakes, rivers, streams, springs, ponds, and man-made structures such as 

reservoirs, stock tanks, and acequias (Sredl & Jennings 2005). This frog is found at elevations of 

3,281 to 8,890 ft. It is occasionally found in livestock drinkers, irrigation sloughs and acequias, 

wells, abandoned swimming pools, backyard ponds, and mine adits. On the Tonto NF, this 

species occurs at elevations of 3,281 to 6,600 ft. On other Arizona national forests, the frog 

occurs at elevations of 3,540 to 8,280 ft. The frog uses permanent or nearly permanent pools and 

ponds for breeding. Breeding season is from May to August at upper elevations and March to 

June at lower elevations. Most sites that support populations of this frog will hold water yearlong 

in most years. Time from hatching to metamorphosis is shorter in warm water than in cold water; 

water permanency is probably more important at higher elevations and in the northern portion of 

the species’ range. The species is rarely found in aquatic sites inhabited by non-native fish, 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

bullfrogs, or crayfish. In complex systems or large aquatic sites, this species may occur in the 

presence of low densities of non-native predators. 

More comprehensive reviews of Chiricahua leopard frog life history, status, conservation, and 

range can be found in U.S.F.W.S. (2002b to 2005a). 

Proposed Critical Habitat: These are the areas being proposed for critical habitat on the 

Tonto National Forest:

Unit 24: Crouch, Gentry, and Cherry Creeks, and Parallel Canyon: Included as proposed 

critical habitat are Trail Tank, HY Tank, Carroll Spring, West Prong of Gentry Creek, 

Pine Spring, and portions of Cherry and Crouch Creeks, all of which provide breeding or 

potential breeding habitat

1. Cherry Creek from Rock Spring upstream to its confluence with an unnamed drainage,

upstream in that drainage and across a saddle, then downstream in an unnamed drainage 

to Trail Tank; 

2. Crouch Creek from its headwaters just south of Highway 288 downstream to an unnamed 

drainage leading to Pine Spring, to include Cunningham Spring and Carroll Spring, then 

upstream in that unnamed drainage from Crouch Creek to Pine Spring; 

3. From HY Tank downstream in an unnamed drainage to Cherry Creek, to include Bottle 

Spring; 

4. From Cunningham Spring east across a low saddle to West Prong of Gentry Creek where 

the creek turns southwest; 

5. from Bottle Spring south over a low saddle to the headwaters of Crouch Creek

Unit 25: Ellison and Lewis Creeks: This unit includes 83 ac (34) of Tonto National Forest 

lands in Gila County, Arizona.

1. Unnamed tributary to Ellison Creek from its confluence with an unnamed drainage 

downstream to Ellison Creek; 

2. then directly west across the Ellison Creek floodplain and over a low saddle to Lewis 

Creek below Pyle Ranch; 

3. then downstream in Lewis Creek to its confluence with an unnamed drainage; 

4. then upstream in that unnamed drainage to Low Tank.

Primary Constituent Elements: 

1. Aquatic breeding habitat and immediately adjacent uplands exhibiting the following 

characteristics: 

a. Standing bodies of fresh water (with salinities less than five parts per thousand, 

pH greater than or equal to 5.6, and pollutants absent or minimally present), 

including natural and manmade (e.g., stock) ponds, slow-moving streams or 

pools within streams, off-channel pools, and other ephemeral or permanent water 

bodies that typically hold water or rarely dry for more than a month. During 

periods of drought, or less than average rainfall, these breeding sites may not 

hold water long enough for individuals to complete metamorphosis, but they 

would still be considered essential breeding habitat in non-drought years. 
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Biological Assessment of the Integrated Treatment of Noxious Plant Program

b. Emergent and or submerged vegetation, root masses, undercut banks, fractured 

rock substrates, or some combination thereof, but emergent vegetation does not 

completely cover the surface of water bodies. 

c. Nonnative predators (e.g., crayfish (Orconectes virilis), American bullfrogs 

(Lithobates catesbeianus), nonnative predatory fishes) absent or occurring at 

levels that do not preclude presence of the Chiricahua leopard frog. 

d. Absence of chytridiomycosis, or if present, then environmental, physiological, 

and genetic conditions are such that allow persistence of Chiricahua leopard 

frogs. 

e. Upland areas that provide opportunities for foraging and basking that are 

immediately adjacent to or surrounding breeding aquatic and riparian habitat. 

2. Dispersal and nonbreeding habitat, consisting of areas with ephemeral (present for only a 

short time), intermittent, or perennial water that are generally not suitable for breeding, 

and associated upland or riparian habitat that provides corridors (overland movement or 

along wetted drainages) for frogs among breeding sites in a metapopulation with the 

following characteristics: 

a. Are not more than 1.0 mile (1.6 kilometers) overland, 3.0 miles (4.8 kilometers) 

along ephemeral or intermittent drainages, 5.0 miles (8.0 kilometers) along 

perennial drainages, or some combination thereof not to exceed 5.0 miles (8.0 

kilometers). 

b. In overland and nonwetted corridors, provides some vegetation cover or 

structural features (e.g., boulders, rocks, organic debris such as downed trees or 

logs, small mammal burrows, or leaf litter) for shelter, forage, and protection 

from predators; in wetted corridors, provides some ephemeral, intermittent, or 

perennial aquatic habitat. 

c. Are free of barriers that block movement by Chiricahua leopard frogs, including, 

but not limited to, urban, industrial, or agricultural development; reservoirs that 

are 50 acres (20 hectares) or more in size and contain predatory nonnative fishes, 

bullfrogs, or crayfish; highways that do not include frog fencing and culverts; 

and walls, major dams, or other structures that physically block movement.

Analysis of effects: The special conservation measures for Chiricahua leopard frog listed 

above would protect Chiricahua leopard frogs and their environments. By only applying aquatic 

approved herbicides and limiting the timing of application based on the possibility of 

precipitation, the likelihood of any Chiricahua leopard frogs being impacted by any herbicide 

applications is discountable. None of the herbicides being used will bioaccumulate in body 

tissues. In the Region 3 risk assessment (USFS, 2001), the toxicity effects regarding many aquatic 

invertebrates and plants showed no sublethal effects. The controlled exposures were higher than 

what the conservation measures will allow in the forest. 

Use of herbicides will not be used in or near known occupied habitat. 

The impacts of herbicide use on the forest would be insignificant with the protection measures in 

place. These conservation measures and low herbicide toxicity and protection from disturbance 

makes the possibility of effects to the Chiricahua leopard frog from the proposed program of 

noxious and invasive weed treatments insignificant and discountable.
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Biological Assessment of the Integrated Treatment of Noxious Plant Program

Determination of effects: The preferred alternative for noxious and invasive weed treatments 

with the conservation measures may affect, but is not likely to adversely affect the Chiricahua 

leopard frog or its proposed critical habitat.

Northern Mexican garter snake (Thamnophis eques megalops)

Background: This species occurs up to about 8,500 feet in elevation, but is most frequently 

found between 3,000 and 5,000 ft. The Mexican gartersnake uses three general habitat types in 

Arizona: 1) source area ponds and cienegas; 2) lowland river riparian forests and woodlands; and 

3) upland stream gallery forests. This species uses densely vegetated cienegas, cienega-streams, 

and stock tanks in the southern part of its distribution in Mexico and within its historical 

distribution in New Mexico.

An important component to suitable Mexican gartersnake habitat is a stable native prey base. The 

Mexican gartersnake is surface-active at ambient temperatures ranging from 71° F to 91° F and 

forages along the banks of water bodies feeding primarily upon native fish (e.g., Gila topminnow, 

desert pupfish, etc.) and adult and larval native ranid frogs (e.g., lowland leopard frog, Chiricahua 

leopard frog, etc.). It may also supplement its diet with earthworms and vertebrates such as 

lizards, small rodents, salamanders, and hylid frogs (tree frogs). In some populations, adult 

Mexican gartersnakes will prey upon juvenile nonnative bullfrogs and/or bullfrog tadpoles where 

they co-occur.

Sexual maturity in male Mexican gartersnakes occurs at two years, and in two to three years in 

females. Mexican gartersnakes are ovoviviparous. The species mates in April and May in their 

northern distribution and gives live birth to between seven and 26 neonates (average is 13.6) in 

July and August. Only half of the sexually mature females within a population reproduce in any 

one season.

Within Tonto National Forest, lower and middle Tonto Creek support Mexican gartersnake, but 

recruitment is likely in decline (U.S.F.W.S. FR Vol. 73 # 228, page 71791). Arizona Game and 

Fish Heritage Data Management System also indicate records of Mexican garter snake in Horse 

Creek (6 miles north of Horseshoe Dam), Juniper Creek (Sierra Ancha), Sycamore Creek (West 

of Sugarloaf Mountain), and Houston Creek (Verde River). 

Analysis of effects: If we follow the special conservation measures for Chiricahua leopard 

frog listed above, the effects on the northern Mexican gartersnake and its environment would be 

limited. By only applying aquatic approved herbicides and limiting the timing of application 

based on the possibility of precipitation, the likelihood of any Northern Mexican gartersnakes 

being impacted by any herbicide applications are discountable. None of the herbicides being used 

will bioaccumulate in body tissues. In the Region 3 risk assessment (USFS, 2001), the toxicity 

effects regarding many aquatic invertebrates and plants showed no sublethal effects. The 

controlled exposures were higher than what the conservation measures will allow in the forest. 

The impacts of herbicide use on the forest would be insignificant with the protection measures in 

place. These conservation measures and low herbicide toxicity and protection from disturbance 

makes the possibility of effects to the northern Mexican gartersnake from the proposed program 

of noxious and invasive weed treatments insignificant and discountable.
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Biological Assessment of the Integrated Treatment of Noxious Plant Program

The preferred alternative for noxious and invasive weed treatments with the Chiricahua leopard 

frog conservation measures is likely to minimize the negative impacts to the continued existence 

of the northern Mexican gartersnake. 

FS seeks any additional conservation recommendations for this candidate species.

Desert Pupfish (Cyprinodon macularius macularius)

Background: Desert pupfish once were once widely distributed in Arizona and California in the 

Colorado River Basin. The distribution of this formerly widespread species has been drastically 

reduced due to dewatering and predation by invasive species. The species is listed as Endangered 

by the U.S.F.W.S. Desert pupfish had been extirpated, since the inception of the Tonto NF. 

Recently they have been repatriated. Pupfish inhabit springs, ponds, cienegas and low gradient 

riverine habitats. They prefer habitats where solar insulation is high and can tolerate temperatures 

up to 100o F and high levels of salinity. The species breeds in spring and summer. Breeding males 

aggressively defend their territories.

Desert pupfish occur in two locations on the Tonto NF – Mud Spring and Walnut Spring on the 

Mesa Ranger District.

Analysis of Effects: There would be no direct effects to desert pupfish because there would be 

no treatments within the aquatic habitat. Noxious weed treatments could occur up to the water’s 

edge of aquatic habitat. Application of herbicides near occupied habitat would follow U.S.F.W.S. 

2007e guidelines. These guidelines restrict use of herbicides and adjuvants to those that have 

been determined to be practically nontoxic to fish species. In addition, application methods are 

restricted to spot applications of liquid formulations to minimize spray drift and/or surface runoff 

of herbicides. Implementing U.S.F.W.S. 2007e guidelines would minimize the toxicity and 

exposure of herbicides to such small immeasurable levels as to have an insignificant effect to the 

species or its habitat. Use of manual, mechanical, or cultural treatments in upland and riparian 

areas would result in short-term, localized impacts to vegetation and soil. Implementing BMPs 

(Best Management Practices) would minimize runoff and soil erosion off of treatment areas so

that any sediment moving into pupfish habitat would be such small immeasurable amounts as to 

have an insignificant effect to the species or its habitat. No cumulative effects are anticipated.

Determination of Effects: Effects to desert pupfish and their habitat would be insignificant 

and discountable. Therefore, the implementation of the Noxious Weed Plan may affect, but is 

not likely to adversely affect desert pupfish or its habitat.

Gila Chub (Gila intermedia) 

Background: On November 2, 2005, the U.S.F.W.S. published a final rule listing the Gila chub 

as endangered and designating 160 miles of streams in Arizona and New Mexico as critical 

habitat (USFWS, 2005d). Portions of Mineral Creek and Silver Creek on the Tonto NF are 

included in the critical habitat designation. The designation identifies the stream habitats that are 

believed essential to help recover the species. Gila chub is a member of the minnow family 

(Cyprinidae) that can achieve lengths up to ten inches. Its body is chunky with large scales. 

Overall coloration is dark, sometimes lighter on the belly. Breeding males have red or orange on 

the lower cheeks, posterior parts of the lips, paired fin bases, and on the lower sides of the body. 

Breeding colors of the males seem more intense than in other Arizona chubs, culminating in the 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

entire ventro-lateral surface becoming fire-red, and the eye becoming yellow to yellow-orange. 

Gila chub typically occupies pools in small streams, marshes, cienegas, and other quiet waters, 

although it may have occurred in larger, more complex habitats. It is highly secretive, remaining 

in deeper waters near cover (Minckley, 1973). Foods include both terrestrial and aquatic 

invertebrates, small fishes, algae, and organic debris. Breeding in streams seems to be sporadic 

throughout the spring and summer, while in constant temperature springs breeding lasts through 

late winter, spring, and summer months, and perhaps into early autumn. Breeding occurs over 

beds of aquatic plants. Females achieve lengths of ten inches; males rarely grow longer than six

inches. 

In Arizona, Gila chub was widely distributed in isolated habitats, occurring in the headwaters of 

essentially all the major tributaries to the Gila River, including the Verde, Agua Fria, Aravaipa, 

San Pedro, and Santa Cruz drainages (USFWS, 2005d). It has recently been rediscovered in the 

San Pedro drainage in Sonora, Mexico, where it had not been collected since 1857. It occurs in 

Silver Creek on BLM lands immediately downstream of the Tonto NF. Chub formerly occurred 

in watered reaches of Mineral Creek adjacent to the Tonto NF; it was extirpated from Cave Creek 

and Seven Springs Wash during fish renovation efforts in the early 1970s. Immediately after the 

Cave Creek Complex Fire of 2005, 200 to 400 chub were salvaged from Silver Creek on the 

Tonto National Forest, in anticipation of extreme siltation of their pool habitat after fire had 

removed much of the vegetation on the upland slopes above the creek. The pools did silt in, but 

are recovering well at this time. Gila chub are expected to move back into the National Forest 

reach of Silver Creek as the system recovers and pools deepen once more (Silva, 2011). 

Threats to the species arise from several sources. Gila chub is becoming rare, especially where 

land use practices such as overgrazing lead to incision of floodplains and lowering of water 

tables, which, in turn, drain marshlands and other stream-associated habitats. Efforts to maintain 

and restore cienega type habitats are needed to ensure the survival of the species. Populations of 

Gila chub have been quickly eliminated following stocking of largemouth bass into their habitat. 

The spread of nonnative fish in waters in Arizona continues to be disastrous for the native fish 

fauna of the state. Reintroduction of Gila chub into suitable habitats is an appropriate 

management action.

Gila Chub Critical Habitat

The following are primary constituent elements of critical habitat for Gila chub:

1. Perennial pools, areas of higher velocity between pool areas, and areas of shallow water 

among plants or eddies all found in small segments of headwaters, springs, or cienegas of 

smaller tributaries. 

2. Water temperatures for spawning ranging from 62.6 to 75.2 degrees F with sufficient 

dissolved oxygen, nutrients, and any other water related characteristics needed. 

3. Water quality with reduced levels of contaminants, including excessive levels of 

sediments adverse to Gila chub health, and adequate levels of pH (e.g., ranging from 6.5 

to 9.5), dissolved oxygen (e.g., ranging from 3.0 to 10.0) and conductivity (e.g., 100 to 

1000 mmhos).

4. Food base consisting of invertebrates (e.g., aquatic and terrestrial insects) and aquatic 

plants (e.g. diatoms and filamentous green algae).

5. Sufficient cover consisting of downed logs in the water channel, submerged aquatic 

vegetation, submerged large tree root wads, undercut banks with sufficient overhanging 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

vegetation, large rocks and boulders with overhangs, a high degree of streambank 

stability, and a healthy, intact riparian vegetation community.

6. Habitat devoid of nonnative aquatic species detrimental to Gila chub or habitat in which 

detrimental non-natives are kept at a level that allows Gila chub to continue to survive 

and reproduce.

7. Streams that maintain a natural flow pattern including periodic flooding.

Proposed critical habitat (CH) in or near the project area includes the following stream reaches 

and a 300-foot width from each streambank:

Silver Creek: 5.3 miles of creek extending from a spring on FS lands downstream onto 

BLM lands, all of which is located above a natural waterfall/barrier located 2.5 miles 

above the confluence with the Agua Fria River.

Mineral Creek: Critical habitat within Mineral Creek consists of 8.9 miles of creek 

extending from the confluence with Devil’s Canyon upstream to its headwaters.

The earliest record of Gila chub collected in Silver Creek was in 1980. Due to high recruitment of 

young-of-the-year, Silver Creek was the source of Gila chub that were translocated to Larry 

Creek and Lousy Canyon in July 1995. Gila chub were salvaged from Silver Creek to protect the 

population from the Cave Creek Complex Fire in 2005 (Calamusso, 2008). Silver Creek contains 

one or more of the primary constituent elements, including perennial pools and the necessary 

vegetation that provides cover (Calamusso, 2008). Land ownership is Tonto National Forest and 

BLM.

AGFD documented Gila chub in Mineral Creek in 2000 (Weedman, D. Personal comm.) But the 

species has not been detected in recent surveys. Mineral Creek contains one or more of the 

primary constituent elements, including perennial pools, the necessary vegetation that provides 

cover, and adequate water quality. Mineral Creek does not contain suitable habitat downstream of 

a mine, where it has been contaminated by mining activities in the past. 

Analysis of effects: There would be no direct effects to Gila chub because no treatments 

would occur within the aquatic habitat. Noxious weed treatments could occur up to the water’s 

edge of aquatic habitat. Application of herbicides near occupied habitat would follow U.S.F.W.S. 

2007e guidelines. These guidelines restrict use of herbicides and adjuvants to those that have 

been determined to be practically nontoxic to fish species. In addition, application methods are 

restricted to spot applications of liquid formulations to minimize spray drift and/or surface runoff 

of herbicides. Implementing U.S.F.W.S. 2007e guidelines would minimize the toxicity and 

exposure of herbicides to such small immeasurable levels as to have an insignificant effect to the 

species or its habitat. Use of manual, mechanical, or cultural treatments in riparian and upland 

areas would result in short-term, localized impacts to vegetation and soil. Implementing BMPs 

would minimize runoff and soil erosion off of treatment areas so that any sediment moving into 

Gila chub habitat would be such small immeasurable amounts as to have an insignificant effect to 

the species or its habitat. 

Treatments would occur within and adjacent to designated CH. Use of manual, mechanical, 

cultural, or herbicidal treatments in riparian and upland areas would result in short-term, localized 

impacts to vegetation and/or soil. Implementing BMPs would minimize runoff and soil erosion 

off of treatment areas so that any sediment moving into CH would be such small immeasurable 

amounts as to have an insignificant effect to CH. Implementing U.S.F.W.S. 2007e guidelines 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

would minimize the toxicity and exposure of herbicides to such small immeasurable levels as to 

have an insignificant effect to water quality of CH. These treatments would have insignificant 

short-term impacts to the CH primary constituent elements of presence of perennial pools, 

adequate food base of invertebrates and aquatic plants, water temperature and quality, and 

absence of non-native aquatic species. Treatment of invasive weeds in the adjacent riparian 

community may help to retain primary constituent elements #5 and 7, a healthy riparian 

community and streams with a natural flow pattern.

Determination of effects: Effects to Gila chub and their CH would be insignificant and 

discountable. Thus, implementation of the Noxious Weed Plan may affect, but is not likely to 

adversely affect Gila chub or its critical habitat.

Headwater Chub (Gila nigra)

Background: This species occupies upper reaches of tributaries throughout the Colorado River 

Basin. It occurs in upper Tonto Creek and tributaries, the East Verde, and Deadman Creek 

(tributary to the Verde River) on the Tonto National Forest (HDMS, 2005). It is often found in 

association with roundtail chub. Headwater chub is most commonly a pool inhabitant, with 

associated cover in the form of undercut banks, root wads and boulders, and containing sand/gravel 

substrates. This type of cover is a key habitat component for headwater chub.

Headwater chub is an omnivorous fish, consuming a wide variety of aquatic and terrestrial 

insects. Larger individuals are piscivorous.

Similar to roundtail chub, this species spawns in May when water temperatures reach about 72o F.

Spawning occurs in pool-riffle habitats or in riffles immediately above pools. Fecundity is agedependent, with five-year-old females producing over 30,000 eggs. Young grow to 2.75 inches in 

their first year. Growth rate appears to be directly proportional to habitat (pool) size. 

Introduced, predatory sport fishes are perhaps the greatest threat to the species. Other threats include 

alteration and loss of habitat due to poor land use practices.

Analysis of effects: There would be no direct effects to headwater chub because no treatments 

would occur within the aquatic habitat. Noxious weed treatments could occur up to the water’s 

edge of aquatic habitat. Application of herbicides near occupied habitat would follow U.S.F.W.S. 

2007e guidelines. These guidelines restrict use of herbicides and adjuvants to those that have 

been determined to be practically nontoxic to fish species. In addition, application methods are 

restricted to spot applications of liquid formulations to minimize spray drift and/or surface runoff 

of herbicides. Implementing U.S.F.W.S. 2007e guidelines would minimize the toxicity and 

exposure of herbicides to such small immeasurable levels as to have an insignificant effect to the 

species or its habitat. Use of manual, mechanical, or cultural treatments in riparian and upland 

areas would result in short-term, localized impacts to vegetation and soil. Implementing BMPs 

would minimize runoff and soil erosion off of treatment areas so that any sediment moving into 

headwater chub habitat would be such small immeasurable amounts as to have an insignificant 

effect to the species or its habitat. 

We seek any additional conservation recommendations for this candidate species.
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Spikedace (Meda fulgida)

Background: Spikedace is a member of the minnow family and was common and locally 

abundant throughout the upper Gila River basin of Arizona and New Mexico. Its distribution was 

widespread in large and moderate sized rivers and streams in Arizona, including the Gila, Salt, 

and Verde rivers and their major tributaries upstream of present day Phoenix, and the Agua Fria, 

San Pedro, and San Francisco river systems. Breeding of Spikedace is apparently initiated in 

April to June in response to a combination of declining stream discharge and increasing water 

temperatures. Gametes are presumably expelled into the water column. Ova are adhesive and 

demersal, and likely adhere to the substrate. Fecundity of individual females ranges from 90 to 

150 ova of about 1/16-inch diameter. Younger females will spawn once and older females will 

spawn twice each year. No specific information on incubation times or size at hatching is 

available.

Spikedace now is restricted to less than six percent of the historic range. The species distribution 

is much reduced range wide due to predation by invasive species and loss of habitat. It now only

occurs in Fossil Creek on the Tonto and Coconino national forests, although Salt and Verde rivers 

and Tonto Creek are historical collection sites.

Analysis of Effects: Currently, Spikedace only occur in Fossil Creek. No direct effects to 

Spikedace are expected because there would be no treatments within the aquatic habitat. Noxious 

weed treatments could occur up to the water’s edge of aquatic habitat. Application of herbicides 

near occupied habitat would follow RPMPA guidelines. These guidelines restrict use of 

herbicides and adjuvants to those that have been determined to be practically nontoxic to fish 

species. In addition, application methods are restricted to spot applications of liquid formulations 

to minimize spray drift and/or surface runoff of herbicides. Implementing RPMPA guidelines 

would minimize the toxicity and exposure of herbicides to such small immeasurable levels as to 

have an insignificant effect to the species or its habitat. Use of manual, mechanical, or cultural 

treatments in upland and riparian areas would result in short-term, localized impacts to vegetation 

and soil. Implementing BMPs (Best Management Practices) would minimize runoff and soil 

erosion off of treatment areas so that any sediment moving into Spikedace habitat would be such 

small immeasurable amounts as to have an insignificant effect to the species or its habitat. No 

cumulative effects are anticipated.

Proposed Critical Habitat: 

Physical and Biological Features (PBFs)

1. Habitat to support all egg, larval, juvenile, and adult spikedace. This habitat includes 

perennial flows with a stream depth generally less than 1 m (3.3 ft.), and with slow to 

swift flow velocities between 5 and 80 cm per second (1.9 and 31.5 in. per second). 

Appropriate stream microhabitat types include glides, runs, riffles, the margins of pools 

and eddies, and backwater components over sand, gravel, and cobble substrates with low 

or moderate amounts of fine sediment and substrate embeddedness. Appropriate habitat 

will have a low gradient of less than approximately 1.0 percent, at elevations below 2,100 

m (6,890 ft.). Water temperatures should be in the general range of 8.0 to 28.0 °C (46.4 to 

82.4 °F); 

2. An abundant aquatic insect food base consisting of mayflies, true flies, black flies, 

caddisflies, stoneflies, and dragonflies; 

3. Streams with no or no more than low levels of pollutants; 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

4. Perennial flows, or interrupted stream courses that are periodically dewatered but that 

serve as connective corridors between occupied or seasonally occupied habitat and 

through which the species may move when the habitat is wetted; 

5. No nonnative aquatic species, or levels of nonnative aquatic species that are sufficiently 

low as to allow persistence of spikedace; and 

6. Streams with a natural, unregulated flow regime that allows for periodic flooding or, if 

flows are modified or regulated, a flow regime that allows for adequate river functions, 

such as flows capable of transporting sediments. 

Proposed CH in or near the project area includes the following stream reaches and a 300-foot 

width from each streambank:

Tonto Creek: 47.8 km (29.7 mi.) extending from the confluence with Greenback Creek 

upstream to the confluence with Houston Creek. 

Greenback Creek: 15.1 km (9.4 mi.) from the confluence with Tonto Creek to Lime 

Springs. 

Rye Creek: 2.8 km (1.8 mi.) extending from the confluence with Tonto Creek to the 

confluence with Brady Canyon. 

Spring Creek: 27.2 km (16.9 mi.) extending from the confluence with the Tonto Creek

upstream to the confluence with Seven Mile Canyon. 

Rock Creek: 5.8 km (3.6 mi.) extending from the confluence with Spring Creek 

upstream to the confluence with Buzzard Roost Canyon. 

Fossil Creek: 7.5 km (4.7 mi.) extending from the confluence with the Verde River 

upstream to the confluence with an unnamed tributary from the northwest in Township 

11.5 North, Range 7 East, center of section 29.

Effects Analysis to Primary Biological Features: 

Treatments would occur within and adjacent to designated CH. Use of manual, mechanical, 

cultural, or herbicidal treatments in riparian and upland areas would result in short-term, localized 

impacts to vegetation and/or soil. Implementing BMPs would minimize runoff and soil erosion 

off of treatment areas so that any sediment moving into CH would be such small immeasurable 

amounts as to have an insignificant effect to CH. Implementing U.S.F.W.S. 2007e guidelines 

would minimize the toxicity and exposure of herbicides to such small immeasurable levels as to 

have an insignificant effect to water quality of CH. These treatments would have insignificant 

short-term impacts to the CH primary constituent elements of presence of perennial pools, 

adequate food base of invertebrates and aquatic plants, water temperature and quality, and 

absence of non-native aquatic species. Treatment of invasive weeds in the adjacent riparian 

community may help to retain primary constituent elements #3 and 6, a healthy riparian 

community and streams with a natural flow pattern.

Determination of Effects: Effects to Spikedace and their habitat would be insignificant and 

discountable. Therefore, the implementation of the Noxious Weed Plan will may affect, but is 

not likely to adversely affect spikedace or its proposed critical habitat.
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Woundfin (Plagopteris argentissimus)

Background: Woundfin likely occurred in larger streams throughout the lower Colorado River 

Basin. Specimens were taken from near the confluence of the Salt and Verde rivers, to the mouth 

of the Gila at Yuma, and thence upstream into the Virgin River. It is entirely probable that the 

species occurred further upstream on the Verde, Salt, and Gila rivers.

Currently it is restricted to the Virgin River in Arizona, Nevada, and Utah. Attempts to increase 

its range have included transplanting into the Hassayampa, Pariah, and Salt Rivers, and Sycamore 

Creek in the Agua Fria drainage. None have been successful. It does not currently occur on the 

Tonto NF.

This species is in jeopardy due to extreme stress caused by alterations in its ecosystem. Nonnative 

fishes have brought disease and parasites, and they compete for food and space and prey on 

young of woundfin. Extremes of water flow and degraded quality contributed to loss of range.

Dams and diverting of water from streambeds, and groundwater pumping have caused many 

areas formerly capable of supporting the species to desiccate. Other land uses that result in a 

decrease in the amount of surface water have also contributed to their decline.

Analysis of effects: Woundfin does not occur on the Tonto National Forest, but it is evaluated 

in this document in case a decision is made to stock it at sites within the forest. There would be 

no direct effects to woundfin because there would be no treatments within the aquatic habitat.

Noxious weed treatments could occur up to the water’s edge of aquatic habitat. Application of 

herbicides near occupied habitat would follow U.S.F.W.S. 2007e guidelines. These guidelines 

restrict use of herbicides and adjuvants to those that have been determined to be practically 

nontoxic to fish species. In addition, application methods are restricted to spot applications of 

liquid formulations to minimize spray drift and/or surface runoff of herbicides. Implementing 

U.S.F.W.S. 2007e guidelines would minimize the toxicity and exposure of herbicides to such 

small immeasurable levels as to have an insignificant effect to the species or its habitat. Use of 

manual, mechanical, or cultural treatments in upland and riparian areas would result in shortterm, localized impacts to vegetation and soil. Implementing BMPs (Best Management Practices) 

would minimize runoff and soil erosion off of treatment areas so that any sediment moving into 

Woundfin habitat would be such small immeasurable amounts as to have an insignificant effect to 

the species or its habitat. No cumulative effects are anticipated.

Determination of effects: Effects to woundfin and its habitat would be insignificant and 

discountable. Therefore, the implementation of the Noxious Weed Plan may affect, but is not 

likely to adversely affect woundfin or its habitat.

Gila Topminnow (Poeciliopsis occidentalis occidentalis)

Background: Habitat requirements of Gila topminnow are broad; it prefers shallow, warm, and 

quiet waters, but can adjust to a wide range of conditions, living in quiet to moderate currents, 

depths to 3 ft., and water temperatures from a constant 80o F springs to streams that naturally 

fluctuating from 43 to 99o F. Topminnows can live in a wide variety of waters such as springs, 

cienegas, marshes, permanent or interrupted streams, and along the edges of large rivers. 

Preferred habitat contains dense mats of algae and debris, usually along stream margins or below 

riffles, with sandy substrates sometimes covered with organic mud and debris. Topminnows can 

withstand a wide range of water chemistries, with recorded pHs of 6.6 to 8.9 in existing habitats, 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

dissolved oxygen readings of 2.2 to 11 ppm, and salinities that range from tap water to seawater 

(USFWS, 1998a). 

Today, the Tonto NF contains 10 out of the 13 populations of Gila topminnow that exist on 

National Forest System lands in Arizona. Stocked sites include Charlebois (Mesa RD), 

Cottonwood (Mesa RD), Cottonwood-Artesian (Tonto Basin RD), Hidden Water (Mesa RD), 

Mud (Mesa RD), Walnut (Mesa RD), Kayler (Tonto Basin RD) and Dutchman Grave (Cave 

Creek RD) springs; Campaign (Tonto Basin RD) and Lime Creeks (Cave Creek RD) and Lime 

Creek Spring (Cave Creek RD; and a tributary to Tortilla Creek (Mesa RD) on the Tonto NF. 

Nearly all other occupied Gila topminnow sites closely adjoin National Forest System lands 

(Weedman, 1998). 

Analysis of Effects: There would be no direct effects to Gila topminnow because there would 

be no treatments within the aquatic habitat. Noxious weed treatments could occur up to the 

water’s edge of aquatic habitat. Application of herbicides near occupied habitat would follow 

U.S.F.W.S. 2007e guidelines. These guidelines restrict use of herbicides and adjuvants to those 

that have been determined to be practically nontoxic to fish species. In addition, application 

methods are restricted to spot applications of liquid formulations to minimize spray drift and/or 

surface runoff of herbicides. Implementing U.S.F.W.S. 2007e guidelines would minimize the 

toxicity and exposure of herbicides to such small immeasurable levels as to have an insignificant 

effect to the species or its habitat. Use of manual, mechanical, or cultural treatments in upland 

and riparian areas would result in short-term, localized impacts to vegetation and soil. 

Implementing BMPs would minimize runoff and soil erosion off of treatment areas so that any 

sediment moving into topminnow habitat would be such small immeasurable amounts as to have 

an insignificant effect to the species or its habitat. No cumulative effects are anticipated.

Determination of Effects: Effects to Gila topminnow and their habitat would be insignificant 

and discountable. Therefore, the implementation of the Noxious Weed Plan may affect, but is 

not likely to adversely affect Gila topminnow or its habitat.

Colorado Pikeminnow (Ptychocheilus lucius) 

Background: Adults require pools, deep runs, and eddy habitats maintained by high spring 

flows (U.S. Fish and Wildlife Service, 1991). These high spring flows maintain channel and 

habitat diversity, flush sediments from spawning areas, rejuvenate food production, form gravel 

and cobble deposits used for spawning, and rejuvenate backwater nursery habitats. Spawning 

occurs after spring runoff at water temperatures typically between 64 and 73 degrees F. After 

hatching and emerging from spawning substrate, larvae drift downstream to nursery backwaters 

that are restructured by high spring flows and maintained by relatively stable base flows. Strong 

year classes of Colorado pikeminnow have been linked to years immediately following wet 

hydrologic conditions resulting in high spring-runoff flows. 

Populations within the Verde and Salt Rivers are considered “Experimental non-essential” under 

Section 10J of the Endangered Species Act (U.S. Fish and Wildlife Service, 1991). There is no 

critical habitat designated in the Verde or Salt Rivers. A total of 10,852 large Colorado 

pikeminnow have been stocked in the lower Verde River from 1994 to 2003 (Jahrke & Clark, 

1999). A small population occurs in the lower Verde River from stockings of hatchery-raised fish. 

There has been a steady increase in the number of Colorado pikeminnow recaptured in annual 

monitoring (Jahrke & Clark, 1999; Weedman, 2001, 2002). No evidence of reproduction or 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

recruitment has been documented. The annual goal of the reintroduction program is to stock 

2,000 large (>12 inch) individuals into the Verde River system (Jahrke & Clark 1999). Threats to 

the species include potential habitat loss from urban development and water withdrawals in the 

watershed above occupied habitat, and competition and predation by nonnative fish species. 

Analysis of Effects: There would be no direct effects to Colorado pikeminnow because no 

treatments would occur within the aquatic habitat. Noxious weed treatments could occur up to the 

water’s edge of aquatic habitat. Application of herbicides near occupied habitat would follow 

U.S.F.W.S. 2007e guidelines. These guidelines restrict use of herbicides and adjuvants to those 

that have been determined to be practically nontoxic to fish species. In addition, application 

methods are restricted to spot applications of liquid formulations to minimize spray drift and/or 

surface runoff of herbicides. Implementing U.S.F.W.S. 2007e guidelines would minimize the 

toxicity and exposure of herbicides to such small immeasurable levels as to have an insignificant 

effect to the species or its habitat. Use of manual, mechanical, or cultural treatments in riparian 

and upland areas would result in short-term, localized impacts to vegetation and soil. 

Implementing BMPs would minimize runoff and soil erosion off of treatment areas so that any

sediment moving into pikeminnow habitat would be such small immeasurable amounts as to have 

an insignificant effect to the species or its habitat. No cumulative effects are anticipated.

Determination for non-essential expermimental population: non-essential 

expermimental populations located outside a National Park or National Wildlife Refuge System 

unit is treated as a proposed species. By definition, a "non-essential experimental population" is 

not essential to the continued existence of the species. Therefore no proposed action impacting a 

population so designated could lead to a jeopardy determination for the entire species.

Determination of Effects: Effects to Colorado pikeminnow and their habitat would be 

insignificant and discountable. Therefore, the implementation of the Noxious Weed Plan may 

affect, but is not likely to adversely affect Colorado pikeminnow or its habitat.

Loach minnow (Tiaroga cobitis)

Background: Loach minnow a small minnow native to the Gila River basin in Arizona, New 

Mexico, and Sonora, Mexico. The species is now restricted to a few small tributaries and the 

mainstream of the Gila River. The species inhabits low gradient stream reaches and is found in 

high gradient riffles in those reaches. The fish is secretive and uses the interstitial. Loach minnow 

were recently stocked into Fossil Creek which is co-managed by the Tonto and Coconino national 

forests. We believe that there would be no direct effects because there would be no treatments 

within the aquatic habitat. Noxious weed treatments could occur up to the water’s edge of aquatic 

habitat. Application of herbicides near occupied habitat would follow RPMPA guidelines. These 

guidelines restrict use of herbicides and adjuvants to those that have been determined to be 

practically nontoxic to fish species. In addition, application methods are restricted to spot 

applications of liquid formulations to minimize spray drift and/or surface runoff of herbicides. 

Implementing RPMPA guidelines would minimize the toxicity and exposure of herbicides to such 

small immeasurable levels as to have an insignificant effect to the species or its habitat. Use of 

manual, mechanical, or cultural treatments in upland and riparian areas would result in shortterm, localized impacts to vegetation and soil. Implementing BMPs would minimize runoff and 

soil erosion off of treatment areas so that any sediment moving into topminnow habitat would be 

such small immeasurable amounts as to have an insignificant effect to the species or its habitat.

No cumulative effects are anticipated.
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Proposed Critical Habitat: 

Physical and Biological Features (PBFs)

1. Habitat to support all egg, larval, juvenile, and adult loach minnow. This habitat includes 

perennial flows with a stream depth of generally less than 1 m (3.3 ft.), and with slow to 

swift flow velocities between 0 and 80 cm per second (0.0 and 31.5 in. per second). 

Appropriate microhabitat types include pools, runs, riffles, and rapids over sand, gravel, 

cobble, and rubble substrates with low or moderate amounts of fine sediment and 

substrate embeddedness. Appropriate habitats have a low stream gradient of less than 

2.5 percent, are at elevations below 2,500 meters (8,202 ft.). Water temperatures should 

be in the general range of 8.0 to 25.0 °C (46.4 to 77 °F.); 

2. An abundant aquatic insect food base consisting of mayflies, true flies, black flies, caddis 

flies, stoneflies, and dragonflies; 

3. Streams with no or no more than low levels of pollutants; 

4. Perennial flows, or interrupted stream courses that are periodically dewatered but that 

serve as connective corridors between occupied or seasonally occupied habitat and 

through which the species may move when the habitat is wetted; 

5. No nonnative aquatic species, or levels of nonnative aquatic species that are sufficiently 

low to allow persistence of loach minnow; and 

6. Streams with a natural, unregulated flow regime that allows for periodic flooding or, if 

flows are modified or regulated, a flow regime that allows for adequate river functions, 

such as flows capable of transporting sediments. 

Proposed CH in or near the project area includes the following stream reaches and a 300-foot 

width from each streambank:

Fossil Creek: 7.5 km (4.7 mi.) extending from the confluence with the Verde River 

upstream to the confluence with an unnamed tributary from the northwest in Township 

11.5 North, Range 7 East, center of section 29.

Effects Analysis to Primary Biological Features: 

Treatments would occur within and adjacent to designated CH. Use of manual, mechanical, 

cultural, or herbicidal treatments in riparian and upland areas would result in short-term, localized 

impacts to vegetation and/or soil. Implementing BMPs would minimize runoff and soil erosion 

off of treatment areas so that any sediment moving into CH would be such small immeasurable 

amounts as to have an insignificant effect to CH. Implementing U.S.F.W.S. 2007e guidelines 

would minimize the toxicity and exposure of herbicides to such small immeasurable levels as to 

have an insignificant effect to water quality of CH. These treatments would have insignificant 

short-term impacts to the CH primary constituent elements of presence of perennial pools, 

adequate food base of invertebrates and aquatic plants, water temperature and quality, and 

absence of non-native aquatic species. Treatment of invasive weeds in the adjacent riparian 

community may help to retain primary constituent elements #3 and 6, a healthy riparian 

community and streams with a natural flow pattern.

Analysis of Effects: No direct effects to Loach minnow are expected because there would be 

no treatments within the aquatic habitat. Noxious weed treatments could occur up to the water’s 

edge of aquatic habitat. Application of herbicides near occupied habitat would follow RPMPA 

guidelines. These guidelines restrict use of herbicides and adjuvants to those that have been 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

determined to be practically nontoxic to fish species. In addition, application methods are 

restricted to spot applications of liquid formulations to minimize spray drift and/or surface runoff 

of herbicides. Implementing RPMPA guidelines would minimize the toxicity and exposure of 

herbicides to such small immeasurable levels as to have an insignificant effect to the species or its 

habitat. Use of manual, mechanical, or cultural treatments in upland and riparian areas would 

result in short-term, localized impacts to vegetation and soil. Implementing BMPs would 

minimize runoff and soil erosion off of treatment areas so that any sediment moving into 

Spikedace habitat would be such small immeasurable amounts as to have an insignificant effect to 

the species or its habitat. No cumulative effects are anticipated.

Determination of Effects: Effects to loach minnow and their habitat would be insignificant 

and discountable. Therefore, the implementation of the Noxious Weed Plan will have may affect, 

but is not likely to adversely affect loach minnow or its proposed critical habitat.

Razorback Sucker (Xyrauchen texanus)

Background: Habitats required by adults in rivers include deep runs, eddies, backwaters, and 

flooded off-channel environments in spring; runs and pools often in shallow water associated 

with submerged sandbars in summer; and low-velocity runs, pools, and eddies in winter 

(Minckley, 1973). Spring migrations of adult razorback sucker were associated with spawning in 

historic accounts and a variety of local and long-distance movements and habitat-use patterns 

have been documented. Spawning in rivers occurs over bars of cobble, gravel, and sand substrates 

during spring runoff (January through April) at widely ranging flows and water temperatures 

(typically greater than 57 degrees F.). Razorback sucker are broadcast spawners that scatter 

adhesive eggs over cobble substrate. Eggs incubate in interstitial spaces (small, narrow spaces 

between rocks or other substrates). Young require nursery environments with quiet, warm, 

shallow water such as tributary mouths, backwaters, or inundated floodplain habitats in rivers, 

and coves or shorelines in reservoirs. 

Razorback sucker reintroductions into the upper Verde River, made from 1981 to 1992, failed to 

establish any self-sustaining populations (Hendrickson, 1993). A total of 19,363 large razorback 

suckers have been stocked into the lower Verde River from 1994 to 2003 (Jahrke & Clark, 1999). 

A small population occurs in the lower Verde River from stockings of hatchery-raised fish. There 

has been a steady increase in the number of razorback sucker recaptured in annual monitoring and 

survival over several years has been documented (Jahrke & Clark, 1999; Weedman, 2001 and

2002). Some fish have been found in spawning condition but no evidence of reproduction or 

recruitment has been documented. The annual goal of the reintroduction program is to stock 

2,000 large (>12 inch) individuals into the Verde River system (Jahrke & Clark, 1999). Threats to 

the species in the Verde River include potential habitat loss from urban development and water 

withdrawals in the watershed, and competition and predation by nonnative fish species

CH (Critical habitat) in or adjacent to the project area includes 85 miles of the Verde River and its 

100-year floodplain from Perkinsville (T. 18. N., R. 2 E., section 31) downstream to Fossil Creek 

(U.S.F.W.S. 1998). The majority of the upper Verde River from Perkinsville to Clarkdale (19

miles) is in Forest Service ownership. The majority of the lands along the river in the Verde 

Valley from Clarkdale to below Camp Verde (45 miles) are in private ownership. The river is in 

Forest Service ownership below Camp Verde to the confluence with Fossil Creek (21 miles). 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Razorback Sucker Critical Habitat

The Primary constituent elements for razorback sucker Critical Habitat are:

1. Water. This includes a quantity of water of sufficient quality (i.e., temperature, 

dissolved oxygen, lack of contaminants, nutrients, turbidity, etc.) that is delivered 

to a specific location in accordance with a hydrologic regime that is required for 

the particular life stage for each species.

2. Physical Habitat. This includes areas of the Colorado River system that are 

inhabited or potentially habitable by fish for use in spawning, nursery, feeding, and 

rearing, or corridors between these areas. In addition to river channels, these areas 

also include bottom lands, side channels, secondary channels, oxbows, backwaters, 

and other areas in the 100-year flood plain, which when inundated provide 

spawning, nursery, feeding and rearing habitats, or access to these habitats.

3. Biological Environment. Food supply, predation, and competition are important 

elements of the biological environment and are considered components of this 

constituent element. Food supply is a function of nutrient supply, productivity, and 

availability to each life stage of the species. Predation and competition, although 

considered normal components of this environment, are out of balance due to 

introduced nonnative fish species in many areas.

4. Presence of known or suspected wild spawning populations, although recruitment 

may be limited or nonexistent.

5. Areas where juvenile razorback suckers have been collected or which could 

provide suitable nursery habitat (backwaters, flooded bottom lands, or coves).

6. Areas presently occupied or that were historically occupied that are considered 

necessary for recovery and that have the potential for reestablishment of razorback 

suckers. 

7. Areas and water required to maintain range wide fish distribution and diversity 

under a variety of physical, chemical, and biological conditions.

8. Areas that need special management or protection to insure razorback survival and 

recovery. These areas once met the habitat needs of the razorback sucker and may 

be recoverable with additional protection and management.

Treatments could occur within and adjacent to designated CH of the Verde and Salt Rivers. Use 

of manual, mechanical, cultural, or herbicidal treatments in riparian and upland areas would result 

in short-term, localized impacts to vegetation and/or soil. Implementing BMPs would minimize 

runoff and soil erosion off of treatment areas so that any sediment moving into CH would be such 

small immeasurable amounts as to have an insignificant effect to CH. Implementing U.S.F.W.S. 

2007e guidelines would minimize the toxicity and exposure of herbicides to such small 

immeasurable levels as to have an insignificant effect to water quality of CH. These treatments 

would have insignificant short-term impacts to the CH primary constituent elements of spawning, 

nursery, feeding, and rearing habitats, or access to these habitats when inundated. Long-term 

benefits to CH floodplain and its riparian vegetation include improved function due to return to 

native riparian vegetation. No cumulative effects are anticipated.

Analysis of Effects: There would be no direct effects to razorback sucker because no 

treatments would occur within the aquatic habitat. Noxious weed treatments could occur up to the 

water’s edge of aquatic habitat. Application of herbicides near occupied habitat would follow 

U.S.F.W.S. 2007e guidelines. These guidelines restrict use of herbicides and adjuvants to those 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

that have been determined to be practically nontoxic to fish species. In addition, application 

methods are restricted to spot applications of liquid formulations to minimize spray drift and/or 

surface runoff of herbicides. Implementing U.S.F.W.S. 2007e guidelines would minimize the 

toxicity and exposure of herbicides to such small immeasurable levels as to have an insignificant 

effect to the species or its habitat. Use of manual, mechanical, or cultural treatments in riparian 

and upland areas would result in short-term, localized impacts to vegetation and soil. 

Implementing BMPs would minimize runoff and soil erosion off of treatment areas so that any 

sediment moving into razorback sucker habitat would be such small immeasurable amounts as to 

have an insignificant effect to the species or its habitat. 

Determination of Effects: Effects to razorback sucker and designated critical habitat would be 

insignificant and discountable. Therefore, the implementation of the Noxious Weed Plan may 

affect, but is not likely to adversely affect razorback sucker or its critical habitat.
Biological Assessment of the Integrated Treatment of Noxious or Invasive Plant Program Page 

Impacts from Biological Control Agents to 

Listed Plants within Arizona 

We expect the action area of the invertebrate biological control agents to be outside of Tonto 

National Forest, but within the State of Arizona because insects used for biological control agents 

(for example, tamarisk beetle) can spread 100 miles in 8 years in contiguous suitable habitat 

(Greg Beatty, personal communications). We also assume that the biological control agents are 

hosted specific to at least the family level. Typically, biocontrol agents are specific to at least 

genus 

The following plant species are listed as endangered, threatened, or candidate species within 

Arizona (table 10).

Table 10. Endangered, threatened, or candidate species within Arizona

Common Name Family Scientific Name Status

Proposed 

Invertebrate 

Biological 

Control Agent 

that targets 

species within the 

T&Es family

Cochise 

pincushion 

cactus

Cactaceae Coryphantha robbinsorum Threatened none 

Kearney's blue 

star Apocynaceae Amsonia kearneyana Endangered none 

Welsh's 

milkweed Asclepiadaceae Asclepias welshii Threatened none 

Fickeisen plains 

cactus Cactaceae Pediocactus peeblesianus var. fickeiseniae Candidate none 

Holmgren milkvetch Fabaceae Astragalus holmgreniorum Endangered none 

Lemmon 

fleabane

Asteraceae 

(Compositae) Erigeron lemmonii Candidate all

San Francisco 

Peaks ragwort

Asteraceae 

(Compositae) Packera franciscana Threatened all

Brady 

pincushion 

cactus

Cactaceae Pediocactus bradyi Endangered none 

Huachuca water 

umbel Apiaceae Lilaeopsis schaffneriana ssp. recurva Endangered none 

Peeble’s Navajo 

cactus Cactaceae Pediocactus peeblesianus var. peeblesianus Endangered none 

Sentry milkvetch Fabaceae Astragalus cremnophylax 

var. cremnophylax Endangered none 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Common Name Family Scientific Name Status

Proposed 

Invertebrate 

Biological 

Control Agent 

that targets 

species within the 

T&Es family

Zuni (rhizome) 

fleabane

Asteraceae 

(Compositae) Erigeron rhizomatus Threatened all

Canelo Hills 

ladies' tresses

Orchidaceae Spiranthes delitescens Endangered none 

Gierisch mallow Malvaceae Sphaeralcea gierischii Candidate none

Jones' 

Cycladenia Apocynaceae Cycladenia humilis var. jonesii Threatened none 

Navajo sedge Cyperaceae Carex specuicola Threatened none

Pima pineapple 

cactus Cactaceae Coryphantha scheeri var robustispina Endangered none 

Siler pincushion 

cactus Cactaceae Pediocactus sileri Threatened none 

Two federally-listed species and one candidate species are within Asteraceae, which are within 

the same family as the target host species. However, based on a high degree of host specificity of 

biological control agents (especially within the same tribe), we believe that they pose no risk to 

Zuni (rhizome) fleabane, lemmon fleabane, and San Francisco Peaks ragwort.

Prior to 1994, APHIS did not complete environmental analyses under NEPA for release of 

biocontrol agents (Hansen, 2010; Horner, 2010). Most biocontrol agents that target diffuse 

knapweed and starthistles were so widespread by 1994 that APHIS determined conducting a 

NEPA analysis for their release would not serve any purpose (Horner, 2010). 

APHIS’s TAG (Technical Advisory Group) was formed in 1957 to provide an independent 

recommendation of experts regarding releases of specific biocontrol agents. TAG’s charter is to 

review petitions for introduction of biocontrol agents, to evaluate risk to agriculture, human 

health and the environment. 

The Tonto NF has conducted thorough literature searches and has contacted APHIS staff at all 

levels of that agency to obtain TAG environmental testing documentation for proposed biocontrol 

species. The Tonto NF has reviewed all applicable background documents provided by APHIS 

and is satisfied that proposed biocontrol agents will have no effect on federally listed species for 

the following reasons: 

1. Technical Advisory Group research documents were located, that state that these 

biocontrol agents are host-specific: Agapeta zoegana, Bangasternus fausti, B. orientalis, 

Chaetorellia acrolophus, Cyphocleonus Achates, Larinus minutus, L. obtusus, Mecinus 

janthinus, and Urophora quadrifasciata.

2. All of the proposed biocontrol agents have already been introduced into Arizona. Some 

of them may already be on sites within the Tonto National Forest (Hansen, 2010). 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

3. Centaurea is the target host for all of the proposed biocontrol agents except Mecinus 

janthinus, which targets toadflax, and Urophora stylata, which targets bull thistle. There 

are only two native Centaurea species in Arizona (C. Americana and C. rothrockii) – 

both of these are “basket flowers” , and are sufficiently genetically dissimilar from 

introduced weedy Centaurea species that biocontrol agents introduced to this country for 

knapweed and starthistle control do not infest these native plant species (Rees & Story, 

1991). Neither of these Centaurea species is federally listed. 

We proceed to analyze the host specificity of species, and focus on agents that may target 

Cirsium because many of the North American rare thistle species belong to Cirsium. 

Host Specificity Review of Proposed Biological Control Agents 

Agapeta zoegana. Muller and others (1988) exposed A. zoegana to 56 plant species (including 

two Cirsium spp, 1 Erigeron sp, ) in five families, and showed A. zoegana was restricted to a few 

closely related species in Centaurea. A. zoegana infected eight species from genus Centaurea, 

two species from other genera but within the same tribe of Cynarae. 

Coombs and others (2004) have found no reports that indicate that the agent attacks non-target 

plants.

Bangasternus fausti. Maddox and Sobhian (1987) tested host specificity for only eight species of 

plants. They tested species from Cirsium (1 spp.), Cynara (1 spp.), Carthamus (2 spp.) and 

Centaurea (4 spp.), and found B. fausti infected only 2 Centaurea species (184 eggs on C. 

solstitialis, 3 eggs on C. calcitrapa).

Coombs and others (2004) have found no reports that indicate that the agent attacks non-target 

plants, but comment that the larvae will attack any other insects occupying the flower head.

Bangasternus orientalis. Maddox and Sobhian (1987) tested host specificity for only eight

species of plants, all belonging to Asteraceae. They tested species from Cirsium (1 spp.), Cynara

(1 spp.), Carthamus (2 spp.) and Centaurea (4 spp.), and found B. fausti infected only 2 

Centaurea species. B. orientalis only infected only 2 Centaurea spp. (38 eggs on C. diffusa, 9 

eggs on C. calcitrapa).

Coombs and others (2004) have found no reports that indicate that the agent attacks non-target 

plants.

Cyphocleonus Achates. Stinson (1987) tested 71 plant species, and found 36 species were not 

attacked and insignificant amounts of feeding were recorded on 15 species (mainly in the tribe 

Cynareae). Moderate or heavy grazing was restricted to the sub tribe Centaurinae, especially to 

the Centaurea subgenus Acrolophus, C. solstitialis, C. jacea, C. nigra, C. nigrescens, C. cyanus, 

C. macrocephala, and Plectocephalus americanus. Stinson stated that between 1979 and 1985, C. 

achates was found attacking only Centaurea diffusa and C. maculosa, but was not attacking 

closely related knapweeds, including Cirsium arvense. Stinson was not able to test Cirsium 

crassicaule, which is a host that members of the subfamily Cleoninae, which C. achates, are a 

part of. Therefore, no Cirsium species were tested to determine Cirsium species would be 

impacted by the agent.
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Coombs and others (2004) have found no reports that indicate that the agent attacks non-target 

plants.

Eustenopus villosus. Coombs and others (2004) have found no reports that indicate that the agent 

attacks non-target plants.

Larinus minutus. Groppe and others (1990) exposed L. minutus to 7 species in the Asteraceae 

family, which included Carthamus (1), Centaurea (3), Cirsium (1), Cynara (1), and Helianthus

(1). L. minutus were found only on the 3 species from Centaurea. 

Groppe (1990) also tested L. minutus adult feeding, oviposition, and larval development on 44, 

48, and 71 plant species, respectively, and found that it had a limited host range with a preference 

for species in the Centaurea subgenera Acrolophus and Jacea. 

Coombs and others (2004) have found no reports that indicate that the agent attacks non-target 

plants.

Larinus obtusus. Coombs and others (2004) have found no reports that indicate that the agent 

attacks non-target plants.

Groppe (1992) tested adult feeding, oviposition, and larval development test on 78, 74, and 64 

plant species respectively, and found L. obtusus has a limited host range with a preference for 

Centaurea species in the subgenera Acrolophus and Jacea.

Mecinus janthinus. Breiter and Seastedt (2007) tested this against seven species of North 

American native species from Scrophulariaceae family (same family as targeted toadflaxes), and 

they found no larvae developing from non-target natives.

Jeanneret and Schroeder (1992) tested this biological control agent on 38 species in 13 families, 

and found that M. janthinus is restricted to the genus Linaria. 

Coombs and others (2004) have found no reports that indicate that the agent attacks non-target 

plants.

1994 Environmental Assessment recommended release of M. PFedijanthinus into Canada and 

North America, after concluding there are no adverse effects to human health or the environment, 

including federally listed species (Nowierski, 1994). 

Sphenoptera jugoslavica. Coombs and others (2004) have found no reports that indicate that the 

agent attacks non-target plants.

Urophora affinis. Coombs and others (2004) have found no reports that indicate that the agent 

attacks non-target plants. However, because deer mice feed heavily on the fly larvae, the flies 

may contribute to an increase in deer mice in knapweed-infested areas.

Urophora quadrifasciata. Rees and Story (1991) tested U. quadrifasciata against two native 

knapweed Centaurea Americana (found in south-central U.S.), Centaurea rothrockii (found in 

mountains in Arizona), and safflower (Carthamus tinctorius), and found no infection of these 

three non-target species.
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

Coombs and others (2004) have found no reports that indicate that the agent attacks non-target 

plants. However, because deer mice feed heavily on the fly larvae, the flies may contribute to an 

increase in deer mice in knapweed-infested areas.

Cumulative Effects

Cumulative effects include the effects of future State, Tribal, local or private actions that are 

reasonably certain to occur in the action area considered in this biological assessment. Future 

Federal actions that are unrelated to the proposed action are not considered in this section because 

they will be subject to separate consultation pursuant to section 7 of the Act.

There are no cumulative effects.

Approved by:

Gregg Dunn Wildlife Biologist

Tonto Basin Ranger District

Tonto National Forest

Biological Assessment of the Integrated Treatment of Noxious or Invasive Plant Program

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Biological Assessment of the Integrated Treatment of Noxious Plant Program

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Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

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Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

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candidates for listing as endangered or threatened; annual notice of findings on resubmitted 

petitions; annual description of progress on listing actions. Federal Register Vol. 66. No 210.

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AZ Ecological Services Field Office. 208 pp.

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67(114):40790-40811.

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210 pp., Appendices A-O 

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to the razorback sucker recovery plan. U.S. Fish and Wildlife Service, Mountain-Prairie 

Region (6), Denver, Colorado.

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analysis area wildland urban interface fuels treatment analysis within the Payson Ranger 

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pupfish, the continued use of a 10-year term permit to graze livestock on the Cross F 

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Consultation #02-21-95-F-0303 R1. 24 pp. 

-----(2004e). Endangered and threatened wildlife and plants; Final designation of critical habitat 

for the Mexican spotted owl. Final Rule. Federal Register 69, No. 168. p. 53182 – 53230. 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

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the land and resource management plans for the eleven national forests and national 

grasslands of the Southwestern region. Albuquerque, New Mexico. 1,010 pp.

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rule. Federal Register 70: 60866-61009. 

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species with critical habitat. Federal Register Nov. 2, 2005: p.66663 – 66721. 

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lower 48 states from the list of endangered and threatened wildlife; Final rule; Endangered 

and threatened wildlife and plants; Draft post-delisting and monitoring plan for the bald eagle 

(Haliaeetus leucocephalus) and proposed information collection: Notice. Federal Register:

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candidates for listing as endangered or threatened; Annual notice of findings on resubmitted 

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15 through 18, 2001. Region 6, Arizona Game and Fish Department, Mesa, Arizona. 
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

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14-17, 2002. Region 6, Arizona Game and Fish Department, Mesa, Arizona.

Weedman, D. (2008). Fish Biologist. Arizona Department of Game & Fish. Personal 

communication. 

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Interagency Committee for the Management of Noxious and Exotic Weeds (FICMNEW), 

Washington, D.C., 109 pp.

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among breeding populations in different habitats. Wilson Journal of Ornithology 119: 547-

557. 

Wiesenborn, W. D., Heydon, S. L., & Lorenzen, K. (2008). Pollen loads on adult insects from 

tamarisk flowers and inferences about larval habitats at Topock Marsh, Arizona. Journal of 

the Kansas Entomological Society 81: 50-60. 

Whitfield, M. J., & Sogge, M. K. (1999). Range-wide impact of brown-headed cowbird 

parasitism on the Flycatcher (Empidonax traillii extimus), pp. 182-190, In: Research and 

management of the brown-headed cowbird in western landscapes, M. L. Morrison, L. S. Hall, 

S. K. Robinson, S. I. Rothstein, D. C. Hahn and T. R. Rich, eds. Studies in Avian Biology 

No. 18. 

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of Science 38: 233-250. 

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Willard, Todd. (2009). Wildlife Biologist, Cave Creek Ranger District, Tonto National Forest.

Personal commuication.

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yellow starthistle. USDA Forest Service FHTET-1998-17. 2nd ed. 

Winston, R., Hansen, R., Schwarzlander, M., Coombs, E., Randall, C. B., & Lym, R. (2008). 

Biology and biological control of exotic true thistles. Forest Service Report FHTET-2007-05. 

U.S. Forest Service. (2004, May). Environmental assessment for management of noxious weeds 

and hazardous vegetation on public roadways on National Forest Service System Lands in 

Arizona

Biological Assessment of the Integrated Treatment of Noxious or Invasive Plant Program

Appendix 1

2011 Annual Plan for the Treatment of Noxious and Invasive Plants Tonto National Forest

011 Weed Treatment Plan

Fig.

Treatment

Acres

Weed Treatment Type Active Ingredient Month Application Method T&E hab.? T&E Acres 

Impacted

T&E Critical 

Habitat 

Impacted

Note# 

none 10 PESE3 Herbicide glyphosate 

(terrestrial) August T-M sprayer none none none 1 

none 15 PESE3 Burn January PT none none none 1

none 10 PESE3 Burn November PT none none none 1

A1 10 PESE3 Herbicide glyphosate 

(terrestrial) August T-M sprayer SWFL? none none 2 

none 2 AIAL Herbicide Imazapyr October CUT-STUMP none none none 3

none 4 PAAC Herbicide Imazapyr October CUT-STUMP none none none 3

none 2 ULPU Herbicide Imazapyr October CUT-STUMP none none none 4

none 8 VIMA Herbicide aminopyralid July BP none none none 5

none 2 CEME2 Burn January PT none none none 6 

none 1 PESE3 Herbicide glyphosate 

(terrestrial) July BP none none none 6 

A2 1 TACH2 Herbicide Imazapyr August CUT-STUMP SWFL? 1 (SWFL) none 7

A2 0.9 TACH2 Herbicide Imazapyr CUT-STUMP SWFL? 0.9 (SWFL) none 8

A2 0.6 TACH2 Herbicide Imazapyr CUT-STUMP SWFL? 0.6 (SWFL) none 8

A2 1.2 TACH2 Herbicide Imazapyr CUT-STUMP SWFL? 1.2 (SWFL) none 8

A2 1.7 TACH2 Herbicide Imazapyr CUT-STUMP SWFL? 1.7 (SWFL) none 8 

A2 0.7 TACH2 Herbicide Imazapyr CUT-STUMP SWFL? 0.7 (SWFL) none 8

A3 25 CEME2 Herbicide aminopyralid February ATV SWFL? 26.2 (SWFL) 0.36 (SWFL) 9

none 2 CEME2 Herbicide aminopyralid February BP none none none 10

none 1 ONPI February none none none 11
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

011 Weed Treatment Plan

Fig.

Treatment

Acres

Weed Treatment Type Active Ingredient Month Application Method T&E hab.? T&E Acres 

Impacted

T&E Critical 

Habitat 

Impacted

Note# 

none 1 PESE3 Manual January none none none 12

A4 3 TACH2 Herbicide Imazapyr November CUT-STUMP BAEA, NMGS, 

ROCH, SWFL 3 (SWFL) 0.4 SWFL 13

none 1 ARDO4 Herbicide Imazapyr November CUT-STUMP none none none 14

none 1 NEOL Herbicide Imazapyr September CUT-STUMP none none none 14

none 10 ONPI Herbicide aminopyralid December ATV, BP none none none 14

none 34 CEME2 Herbicide aminopyralid January ATV, BP none none none 15

none 22 CEME2 Herbicide aminopyralid January ATV none none none 16

none 10 CEME2 Herbicide aminopyralid December ATV none none none

none 10 EUSU Herbicide Metsulfuron methyl January BP, ATV none none none 17

none 20 EUSU Herbicide Metsulfuron methyl December BP none none none 17

none 20 EUSU Manual January none none none 17

A5 10 AIAL Herbicide Imazapyr October CUT STUMP AZHE? 10 (AZHE) none 18

A6 3 EUSU Herbicide Metsulfuron methyl December BP none none none 19

A6 5 EUSU Manual January none none none 19

A7 5 EUSU Herbicide Metsulfuron methyl December ATV AZHE? 5 (AZHE) n/a 20

A8 1 AIAL Herbicide Imazapyr November CUT-STUMP BAEA, ROCH, 

SWFL 1 (SWFL) none 21

none 3 CEME2 Herbicide aminopyralid January BP none none none

none 2 NEOL Herbicide Imazapyr September CUT-STUMP none none none

A8a 1 CEME2 Herbicide aminopyralid January BP AZHE? 1 (AZHE)? none 22

none 20 PECI Herbicide glyphosate 

(terrestrial) August BP none none none

none 1 ACRE3 Herbicide aminopyralid August BP none none none

none 10 CEME2 Herbicide aminopyralid February BP, ATV none none none 23

none 5 CEME2 Herbicide aminopyralid January T-M, ATV none none none 24
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

011 Weed Treatment Plan

Fig.

Treatment

Acres

Weed Treatment Type Active Ingredient Month Application Method T&E hab.? T&E Acres 

Impacted

T&E Critical 

Habitat 

Impacted

Note# 

none 4 PECI Herbicide glyphosate 

(terrestrial) July ATV none none none 25

A9 2 PESE3 Herbicide glyphosate (aquatic) July T-M none none none 26

A9 10 PESE3 Herbicide glyphosate (aquatic) July T-M none none none 26

none 20 PECI Herbicide glyphosate 

(terrestrial) July BP none none none

none 1 ARDO4 Herbicide Imazapyr November CUT-STUMP none none none 27

none 2 LIDA Herbicide glyphosate 

(terrestrial) May BP none none none

none 11 CEME2 Herbicide aminopyralid February ATV, T-M none none none 28

A10 6 CANU4 Herbicide aminopyralid May BP none none none 29

A10 10 CIVU Herbicide aminopyralid May ATV MSO? MSO(10) none 30

A10 20 CIVU Herbicide aminopyralid June ATV MSO? MSO(20) none 30

none 2 ONAC Herbicide aminopyralid February BP, ATV none none none 31

none 8 CEME2 Herbicide aminopyralid February T-M, ATV none none none 32

none 8 CEME2 Herbicide aminopyralid March T-M, ATV, BP none none none

none 2 ONAC Herbicide aminopyralid February BP none none none

none 2 ONAC Herbicide aminopyralid March BP none none none

none 8 CESO3 Herbicide aminopyralid February ATV, BP none none none

none 8 CESO3 Herbicide aminopyralid March BP, ATV none none none

A11 10 CIVU Herbicide aminopyralid June BP MSO MS0(10) MSO(10) 33

none 4 CIAR4 Herbicide aminopyralid May ATV none none none 34

A11a 3 CEDI3 Herbicide glyphosate 

(terrestrial) March BP MSO MSO(3) MSO(3) 35

none 5 CESO3 Herbicide aminopyralid March ATV none none none

none 5 CEDI3 Manual April none none none

A12 10 CIVU Herbicide aminopyralid May BP MSO MSO (10) MSO (10) 36
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

011 Weed Treatment Plan

Fig.

Treatment

Acres

Weed Treatment Type Active Ingredient Month Application Method T&E hab.? T&E Acres 

Impacted

T&E Critical 

Habitat 

Impacted

Note# 

none 20 CEME2 Herbicide aminopyralid February ATV, T-M none none none 37

none 6 EUSU Herbicide Metsulfuron methyl January BP none none none

none 10 CEME2 Herbicide aminopyralid January ATV, BP none none none 38

none 7 CEME2 Herbicide aminopyralid January ATV none none none

none 18 CEME2 Herbicide aminopyralid January ATV none none none

none 8 CEME2 Herbicide aminopyralid February BP none none none

none 20 CEME2 Herbicide aminopyralid January ATV, BP none none none

Key: 

Application Method

ATV: All-terrain vehicle

BP: Back-pack

PT: Propane torch

T-M: Trailer-mounted
Biological Assessment of the Integrated Treatment of Noxious or Invasive Plant Program

2011 Weed Treatment Plan Notes

Note # Comments

1 Nearby: bat colony on Roosevelt; Fish Creek rock daisy; plains black-headed snake

2

Gila monster within polygon; desert tortoise nearby; SWFL habitat appears 

marginal; Bartlett BAEA 1.6 to 1.7 miles; sighting; RTCH 1.6 downstream; will 

remove fountain grass outside of nesting SWFL season (August)

3 Speckled and longfin dace 0.5 miles away

4 Speckled and longfin dace 0.1 miles away

5 Zone-tailed hawk within 0.1 mile

6 lowland leopard frog less than 1 mile away

7

New River tamarisk, but polygon appears in upland, and appears sparse; probably 

not SWFL habitat; larger riparian trees about 0.01 miles away, but even that looks 

pretty sparse

8 New River tamarisk, but vegetation appears sparse; probably not SWFL habitat; 

9 These areas are near, Arizona cliffrose habitat, razorback sucker critical habitat, and 

Southwestern willow flycatcher habitat; see figure A3

10 Within 0.2 miles of SWFL habitat; within 0.3 miles of SWFL critical habitat

11 Within project areas of figure A2

12 Within 0.03 miles of razorback sucker critical habitat

13 Bald eagle, Northern Mexican gartersnake, roundtail chub, Southwestern willow 

flycatcher critical habitat and habitat (figure A4)

14 Speckle dace and longfin dace nearby; zone-tailed hawk nearby

15 Sonoran Desert tortoise nearby

16 Upland sites; speckled dace, longfin dace, gila topminnow, lowland leopard frog 

about .8 miles away

17 Arizona hedgehog habitat 1.22 miles away; MSO critical habitat 1.33 miles away; 

not MSO habitat; 3 lane, paved highway about .2 miles; away.

18 Arizona hedgehog habitat 0.6 miles away; AZHE potential habitat? figure A5

19

0.2 miles from MSO critical habitat; between 2 developments; does not appear like 

MSO habitat, but similar to MSO CH; ReGap MSO model does not indicate as 

habitat; figure A5

20 0.45 miles from AZHE habitat; figure A7

21 Desert tortoise, peregrine falcon, longfin face, pale Thompson's big-eared bat; 

BAEA in area and susceptible to disturbance; A8

22 0.27 miles from AZHE habitat; A8a

23 Lobed fleabane and Alamos deer vetch 0.75 miles away

24 Cactus ferruginous owl within treatment area
Appendix J

Biological Assessment of the Integrated Treatment of Noxious Plant Program

2011 Weed Treatment Plan Notes

Note # Comments

25 Bats and tortoise maybe nearby

26 BAEA, bats, suckers, peregrine falcon nearby; figure A9

27 0.03 miles from razorback sucker critical habitat; 0.33 miles upstream of East Verde 

BA closure area

28 Longfin dace .11 miles away

29 Deforested area; not MSO habitat; figure A10 (smaller polygon)

30 Draws with concentrated vegetation may support MSO; figure A10 (larger polygon)

31 Two polygons within designated MSO CH, but within human development; lacks all 

PCEs

32 Roundtail chub record 0.01 miles away, but appears dry.

33 Fish Hatchery nearby; 2 PACs about 0.3 to 0.5 miles away; figure A11

34 In open fields; lacks any MSO PCE; 0.2 mi from PAC

35 Sparse vegetation, but still MSO; figure A11a

36 Throughout a PAC (031205002)! figure A12

37 Gila topminnow in tank 0.2 mi from 1 site, and lowland leopard frog 0.3 mi away.

38 Lowland leopard frog within treatment area; drainage empties into Roosevelt