CHAPTER 2

ALTERNATIVES

ALTERNATIVES

CHAPTER 2

ALTERNATIVES

Introduction

Introductory and background information pertinent to 

BLM herbicide treatment programs were provided in 

the 2007 PEIS (USDOI BLM 2007a:2-1 to 2-14). This 

information is still applicable, and is pertinent to the 

three herbicides addressed in this PEIS in terms of BLM 

programs that implement herbicide treatments, planning 

and management of vegetation treatments, and the 

integration and selection of treatment methods within 

treatment projects.

The BLM’s overarching goals for vegetation 

management are to improve biological diversity and 

ecosystem function, promote and maintain native and 

resilient plant communities, and reduce invasive 

vegetation and the risk of wildfire. Public lands are 

administered under the principles of multiple use and 

sustained yield. Thus, vegetation must be managed to 

protect and enhance the health of the land.

Under all three action alternatives, the BLM would be 

able to use the new herbicides immediately after the 

signing of a ROD. Site-specific NEPA analyses would 

be required prior to on-the-ground use of the new 

herbicides. The new active ingredients would be 

integrated into the BLM’s vegetation treatment 

activities. They could be used anywhere on BLM lands, 

subject to any applicable restrictions on their usage, 

such as those identified on the individual pesticide label 

and by each state’s pesticide regulatory agency. 

Herbicide Active Ingredients 

Evaluated Under the Proposed 

Alternatives 

The BLM proposes to add three new herbicide active 

ingredients—aminopyralid, fluroxypyr, and 

rimsulfuron—to its approved herbicide list. All three of 

these herbicides have been registered by the USEPA 

and deemed effective in controlling vegetation, and 

have minimal effects on the environment and human 

health if used in accordance with label instructions.

The new active ingredients were selected based on: 1) 

input from BLM field offices on types of vegetation 

needing control; 2) studies indicating that these active 

ingredients would be more effective in managing 

noxious weeds and other unwanted vegetation than 

active ingredients currently used by the BLM; 3) 

USEPA approval for use on rangelands, forestlands, 

and/or aquatic environments; 4) input from herbicide 

manufacturers regarding herbicides not currently 

approved for use on public lands that may be 

appropriate to manage vegetation; 5) the effectiveness 

of the active ingredients on a variety of target species on 

BLM lands; 6) the level of risk of the herbicidal 

formulations to human health and the environment; and 

7) the funds available to the BLM to conduct HHRAs 

and ERAs of the proposed herbicides. 

All three of the new active ingredients would be used to 

help reduce the spread of noxious weeds and other 

invasive plants to reduce the buildup of hazardous fuels,

reduce the loss of wildlife habitat, help stabilize and 

rehabilitate sites impacted by fire, and restore native and 

desirable plant communities.

Aminopyralid

Aminopyralid, primarily used for the management of 

broadleaf weeds, is a selective herbicide that is used to 

manage invasive annual, biennial, and perennial 

herbaceous species, along with woody species. It is 

applied either aerially or using ground application 

equipment. It is mobile in both the xylem and phloem of 

the target plant, and accumulates in leaf and root 

meristematic tissue. Species targeted by this herbicide 

include, but are not limited to: Russian knapweed, musk 

thistle, spotted knapweed, yellow starthistle, Russian 

thistle, and tansy ragwort (Lee 2013). These species are 

rangeland weeds that displace native plant species.

Aminopyralid is registered under the USEPA’s reduced 

risk initiative, indicating that the USEPA believes that it 

poses less risk to human health and the environment 

than existing herbicide options (USEPA 2012a). 

Aminopyralid may be used instead of picloram in 

certain situations. Although not currently registered for

aquatic use, it is likely that aminopyralid will receive an 

aquatic registration in the near future that would allow 

BLM Vegetation Treatments Three New Herbicides 2-1 January 2016

Final Programmatic EIS
ALTERNATIVES

for incidental overspray of this herbicide during 

treatment of vegetation within close proximity to 

wetland and riparian areas. Aminopyralid is appropriate 

for use at rangeland, forestland, recreation, and cultural 

resource sites; along rights-of-way (ROWs); and at 

energy and mineral sites. It would be used to manage 

noxious weeds and other invasive plants to restore 

native plant communities and wildlife habitat, 

predominantly on rangelands.

Fluroxypyr

Fluroxypyr is a selective, post-emergence herbicide that 

is used to manage certain annual and perennial weeds, 

including broadleaf species that are resistant to 

sulfonylurea herbicides, such as kochia. It can be used 

to manage invasive plants while maintaining native 

rangeland grass species. It is applied to actively growing 

plants using either aerial or ground-based equipment. 

Fluroxypyr’s mode of action is by mimicking auxins 

and disrupting plant cell growth. It is mobile in the 

xylem of the plant, and to a lesser extent the phloem. 

Fluroxypyr can be tank-mixed with other active 

ingredients to improve its ability to manage difficult-tocontrol weeds such as invasive pricklypear cactus. 

Other invasive plant species targeted by fluroxypyr 

include marestail and black henbane. The BLM has 

indicated that the use of fluroxypyr can help reduce the 

amount of other herbicide products used in treatments. 

It is appropriate for use at rangeland, forestland, 

recreation, and cultural resource sites; along ROWs; and 

at energy and mineral sites (Lee 2013). Fluroxypyr 

would be used to manage noxious weeds and other 

invasive plants to restore native plant communities and 

wildlife habitat, predominantly on rangelands. It would 

also be used to control weeds in disturbed and cleared 

areas, such as oil and gas sites.

Rimsulfuron

Rimsulfuron is a selective, ALS-inhibiting herbicide 

that inhibits the biosynthesis of certain amino acids. It is 

applied both pre- and post-emergence, by ground or 

aerial methods. Rimsulfuron is active in both the xylem 

and the phloem of the plant, but primarily the phloem. 

Species targeted by this herbicide include winter annual 

grasses, such as cheatgrass (downy brome) and 

medusahead rye. Rimsulfuron has been observed to be 

more effective than imazapic in certain areas and under 

certain conditions. It is appropriate for use at rangeland, 

forestland, recreation and cultural resource sites; along 

ROWs; and at energy and mineral sites. Rimsulfuron 

would be used predominantly on ROWs and rangelands 

to reduce the buildup of hazardous fuels, and to restore 

native plant communities.

Herbicide Formulations Used by the 

BLM and Tank Mixes

The BLM generally uses several formulations of each 

active ingredient approved for use on public lands. 

Current USEPA-registered formulations of the three 

herbicides proposed for use are shown in Table 2-1, 

which includes the registration number of each 

formulation, the concentration of the active ingredient, 

and the herbicide resistance code.

Additionally, the three new herbicides could be used in 

tank mixes with one or more of the previously approved 

herbicides. Both aminopyralid and fluroxypyr can be 

tank mixed with numerous other active ingredients, 

including 2,4 dichlorophenoxyacetic acid (2,4-D), 

chlorsulfuron, clopyralid, dicamba + diflufenzopyr, 

glyphosate, metsulfuron methyl, picloram, sulfometuron 

methyl, and triclopyr. Fluroxypyr would most 

commonly be used with clopyralid, picloram, and 

triclopyr. Rimsulfuron would usually be applied on its 

own as a pre-emergent herbicide, but could be tank 

mixed with chlorsulfuron for certain applications, along 

with other herbicides registered for the same site of 

application, unless prohibited by the label instructions.

Description of the Alternatives

Four alternatives have been developed for evaluation in 

this PEIS, including the Preferred Alternative and the 

No Action Alternative. Alternative actions are those that 

could be taken to feasibly attain or approximate the 

BLM’s objectives for herbicide use, as expressed in its 

programs, policies, and land use plans.

Alternatives were developed based on the alternatives in 

the 2007 PEIS. These alternatives address many of the 

concerns raised during scoping for the 2007 PEIS, as 

well as concerns raised during scoping for this PEIS (in 

particular concerns about aerial spraying).

Under all alternatives, the BLM would continue to 

follow all of the herbicide treatment SOPs and 

mitigation measures stipulated in the ROD for the 2007

PEIS. General herbicide treatment SOPs would pertain 

to treatments with the currently approved active 

ingredients, as well as any new active ingredients added 

under the various action alternatives. The BLM would 

also continue to follow the monitoring requirements in

BLM Vegetation Treatments Three New Herbicides 2-2 January 2016

Final Programmatic EIS
ALTERNATIVES

TABLE 2-1

Formulations of the Three Herbicides Proposed for Use on Public Lands 

Active 

Ingredient Trade Name Manufacturer

USEPA 

Registration 

Number

Concentration WSSA Herbicide 

Resistance CodeP

1

Aminopyralid Milestone Dow AgroSciences, L.L.C. 62719-519 2.0 lb a.e./gal Group 4

Milestone VM Dow AgroSciences, L.L.C. 62719-537 2.0 1b a.e./gal Group 4

Aminopyralid + 

2,4-D

GrazonNext Dow AgroSciences, L.L.C. 62719-587 0.33+2.67 lb a.e./gal Groups 4 + 4

GrazonNext HL Dow AgroSciences, L.L.C. 62719-628 0.41+3.33 lb a.e./gal Groups 4 + 4

ForeFront HL Dow AgroSciences, L.L.C. 62719-630 0.41+3.33 lb a.e./gal Groups 4 + 4

ForeFront R&P Dow AgroSciences, L.L.C. 62719-524 0.33+2.67 lb a.e./gal Groups 4 + 4

PasturAll Dow AgroSciences, L.L.C. 62719-579 0.075+2.67 lb a.e./gal Groups 4 + 4

PasturAll HL Dow AgroSciences, L.L.C. 62719-629 0.1+3.54 lb a.e./gal Groups 4 + 4

Aminopyralid + 

Clopyralid Sendero Dow AgroSciences, L.L.C. 62719-645 0.5 + 2.3 lb a.e./gal Groups 4 + 4

Aminopyralid +

Metsulfuron 

Methyl

Opensight Dow AgroSciences, L.L.C. 62719-597 0.525+0.0945 % a.i. Groups 4 + 2

Chaparral Dow AgroSciences, L.L.C. 62719-597 0.525+0.0945% a.i. Groups 4 + 2

Aminopyralid + 

Triclopyr

Milestone VM Plus Dow AgroSciences, L.L.C. 62719-572 0.1+1.0 lb a.e./gal Groups 4 + 4

Capstone Dow AgroSciences, L.L.C. 62719-572 0.1+1.0 lb a.e./gal Groups 4 + 4

Rimsulfuron Matrix DuPont Crop Protection 352-556 25 % a.i. Group 2

Fluroxypyr Comet Nufarm Americas, Inc. 71368-87 1.5 lb a.e./gal Group 4

Fluroxypyr Herbicide Alligare, L.L.C. 66330-385-

81927 2.8 lb a.e./gal Group 4

Vista XRT Dow AgroSciences, L.L.C. 62719-586 2.8 lb a.e./gal Group 4

Fluroxypyr + 

Clopyralid Truslate Nufarm Americas, Inc. 71368-86 0.75+0.75 lb a.e./gal Groups 4 + 4

Fluroxypyr + Surmount Dow AgroSciences, L.L.C. 62719-480 0.67+0.67 lb a.e./gal Groups 4 + 4

Picloram Trooper Pro Nufarm Americas, Inc. 228-599 1.0+1.0 lb a.e./gal Groups 4 + 4

Fluroxypyr + PastureGard Dow AgroSciences, L.L.C. 62719-477 0.5+1.5 lb a.e./gal Groups 4 + 4

Triclopyr PastureGard HL Dow AgroSciences, L.L.C. 62719-637 1.0+3.0 lb a.e./gal Groups 4 + 4

P

1

P Resistance codes: Group 2 = Inhibition of acetolactate synthase, and Group 4 = growth regulators.

lb a.e./gal = pounds of acid equivalent per gallon; % a.i. = percent active ingredient; and WSSA = Weed Science Society of America.

the ROD to ensure that SOPs and mitigation measures 

are implemented appropriately. New SOPs and 

mitigation measures that have been developed for the 

action alternatives will be discussed, as appropriate, 

elsewhere in this document. SOPs, mitigation measures, 

and monitoring requirements that carry over from the 

2007 PEIS can be found in Chapter 2 and Appendix B 

of the ROD, as well as Chapter 2 of the 2007 PEIS 

(USDOI BLM 2007a:2-22 to 2-56).

Alternative A – Continue Present 

Herbicide Use (No Action Alternative) 

This alternative describes an integrated vegetation 

management program for resource management and 

habitat enhancement, with only the herbicides approved 

in the ROD for the 2007 PEIS used to manage

competing and unwanted vegetation. This alternative 

corresponds to Alternative B of the 2007 PEIS, which 

estimated that approximately 932,000 acres in the 

western U.S. would be treated annually using 

herbicides. As shown in Figure 2-1, total treatment 

acreages using all herbicides have remained well below 

this number. 

Between 2006 and 2012, the BLM treated an average of

315,000 acres per year using herbicides. During this 

time period, the annual acreage has ranged from about 

260,000 to 436,000, with acres treated largely 

dependent on funding. Increases in funding are typically 

tied to incidence of wildfire. It is projected that the 

acreage of public lands treated using herbicides will 

increase from current levels, but will not exceed the 

932,000-acre estimate from the 2007 PEIS. Therefore, 

the maximum annual treatment area of 932,000 acres is 

carried over to this PEIS for the purposes of analysis.

BLM Vegetation Treatments Three New Herbicides 2-3 January 2016

Final Programmatic EIS
ALTERNATIVES

Figure 2-1. Summary of Acres Treated Using 

Herbicides During 2006 to 2012.

Under this alternative, the BLM would continue to use 

the 18 active ingredients currently approved for use, 

which are listed in Table 2-2. The majority of 

treatments would continue to occur in New Mexico, 

Idaho, and Wyoming, as inferred from Table 2-3. The 

projected use of each of the 18 approved herbicides 

under the No Action Alternative is shown in Table 2-4. 

The most widely used herbicides would be clopyralid, 

glyphosate, imazapic, tebuthiuron, and triclopyr. 

Estimates of herbicide use are based on the BLM’s 

assessment of future needs as far as vegetation 

treatment is concerned. Usage may vary from year to 

year and percentages may change based on the total 

acreage treated. Therefore, projected use of a particular 

herbicide under the No Action Alternative does not 

necessarily reflect historic usage of that herbicide.

Alternative B – Allow for Use of Three 

New Herbicides in 17 Western States 

(Preferred Alternative)

This alternative would allow the BLM to expand its 

vegetation management program by permitting the use 

of three new herbicide active ingredients to manage

competing and unwanted vegetation. Although the 

BLM would likely treat more acres with herbicides than 

it is currently, the projected maximum treatment acres 

would remain at 932,000 acres annually.

Under the Preferred Alternative, the BLM would be 

able to use, in 17 western states, the 18 active 

ingredients that were approved for use in the 2007 PEIS 

ROD, as well as aminopyralid, fluroxypyr, and 

rimsulfuron.

These active ingredients could only be applied for uses, 

and at application rates, specified on the label and in 

accordance with the ROD. Under this alternative, 

herbicides could be applied using ground or aerial 

methods. Herbicides could be used individually, or tank 

mixed with previously approved herbicides, as 

applicable and in accordance with the individual 

herbicide label. 

The projected use of each of the new herbicides, as a 

percent of use by all approved herbicides, is shown in 

Table 2-4. It is estimated that aminopyralid would make 

up 10 percent, fluroxypyr would make up 1 percent, and 

rimsulfuron would make up 16 percent of the total 

herbicide use on BLM-administered lands. As a result 

of adding these new active ingredients, use of other 

herbicides is expected to decrease, particularly 

glyphosate, imazapic, and picloram.

Alternative C – No Aerial Application 

of New Herbicides

This alternative would allow the BLM to use only 

ground-based techniques to apply the three new 

herbicides. Projected maximum treatment acres would 

remain at 932,000 acres annually. This alternative 

would be similar to Alternative B, except that aerial 

application (by helicopter or fixed-wing aircraft) of the 

three new herbicides would not be allowed. The BLM 

would be restricted to only ground-based methods for 

applying these herbicides, including by vehicle or on 

foot with manual application devices. However, aerial 

application of the 18 previously approved active 

ingredients, where identified on individual active 

ingredient labels, and in accordance with BLM policy,

would still be able to occur. Herbicides could be used 

individually, or tank mixed with previously approved 

herbicides, as applicable. These active ingredients could 

only be applied for uses, and at application rates, 

specified on the label, and in accordance with the ROD. 

The projected amount of use of the new herbicides 

under this alternative is shown in Table 2-4. It is 

estimated that aminopyralid would make up 6 percent, 

fluroxypyr would make up less than 1 percent, and 

rimsulfuron would make up 3 percent of the total 

projected herbicide use on BLM-administered lands. 

Under this alternative, substantially less rimsulfuron 

would be used than under Alternative B, as this 

herbicide would not be applied aerially for large-scale 

projects to control invasive annual grasses. 

Aminopyralid use would also be less than under 

Alternative B. However, all three herbicides would be

BLM Vegetation Treatments Three New Herbicides 2-4 January 2016

Final Programmatic EIS
BLM Vegetation Treatments Three New Herbicides

2-5 January 2016

Final Programmatic EIS

ALTERNATIVES

TABLE 2-2

Herbicides Approved and Proposed for Use on Public Lands

Herbicide Herbicide Characteristics and Target Vegetation

Areas Where Registered Use is Appropriate

Rangeland Forestland

Riparian 

and 

Aquatic

Oil, Gas, 

and 

Minerals

ROW

Recreation 

and Cultural 

Resources

Herbicides Approved for Use on Public Lands

2, 4-D Selective; foliar absorbed; postemergent; annual/perennial broadleaf weeds. Key 

species treated include annual kochia, mustard species, and Russian thistle. • • • • • •

Bromacil

Non-selective; inhibits photosynthesis; controls wide range of weeds and brush. Key 

species treated include annual grasses and broadleaf weeds, annual kochia, and 

Russian thistle. • • •

Chlorsulfuron Selective; inhibits enzyme activity; broadleaf weeds and grasses. Key species treated 

include biennial thistles and annual and perennial mustards. • • • •

Clopyralid Selective; mimics plant hormones; annual and perennial broadleaf weeds. Key 

species treated include knapweeds, mesquite, and starthistle and other thistles. • • • • •

Dicamba Growth regulator; annual and perennial broadleaf weeds, brush, and trees. Key 

species treated include knapweeds, annual kochia, and Russian and other thistles. • • • •

Diflufenzopyr + 

Dicamba

Postemergent; inhibits auxin transport; broadleaf weeds. Key species treated include 

knapweeds, annual kochia, and Russian thistle and other thistles. • • • •

Diquat Non-selective and foliar applied. Key species treated include giant salvinia, waterthyme, and watermilfoils. • ◘ ◘ ◘

Diuron Preemergent control; annual and perennial broadleaf weeds and grasses. Key species 

treated include annual grasses and broadleaf weeds, kochia, and Russian thistle. • • •

Fluridone Aquatic herbicide to control submersed aquatic plants. Key species treated include 

water-thyme and watermilfoils. •

Glyphosate

Non-selective; annual and perennial grasses and broadleaf weeds, sedges, shrubs, and 

trees. Key species treated include annual, biennial, and perennial grasses and 

broadleaf weeds and woody shrubs. • • • • • •

Hexazinone Foliar or soil applied; inhibits photosynthesis; annual /perennial grasses and broadleaf 

weeds, brush, and trees. Key species treated include mesquite and scrub oak. • • • • •

Imazapic Selective postemergent herbicide; inhibits broadleaf weeds and some grasses. Key 

species treated include cheatgrass, leafy spurge, medusahead rye, and mustards. • • • • •

Imazapyr

Non-selective; preemergent and postemergent uses; absorbed through foliage and 

roots; annual and perennial broadleaf weeds, brush, and trees. Key species treated 

include saltcedar. • • • • • •

Metsulfuron methyl

Selective; postemergent; inhibits cell division in roots and shoots; annual and 

perennial broadleaf weeds, brush, and trees. Key species treated include annual and 

perennial mustards and biennial thistles. • • • • •

Picloram

Selective; foliar and root absorption; mimics plant hormones; certain annual and 

perennial broadleaf weeds, vines, and shrubs. Key species treated include knapweeds, 

leafy spurge, and starthistle. • • • • •

Sulfometuron methyl

Broad-spectrum preemergent and postemergent control; inhibits cell division; grasses 

and broadleaf weeds. Key species treated include cheatgrass, annual and perennial 

mustards, and medusahead rye. • • • •

Tebuthiuron

Relatively non-selective soil activated herbicide; preemergent and postemergent 

control of annual and perennial grasses, broadleaf weeds, and shrubs. Key species 

treated include creosote bush, oak, Russian olive, and sagebrush (thinning). • • • •
BLM Vegetation Treatments Three New Herbicides

2-6 January 2016

Final Programmatic EIS

ALTERNATIVES

TABLE 2-2 (Cont.)

Herbicides Approved and Proposed for Use on Public Lands

Herbicide Herbicide Characteristics and Target Vegetation

Areas Where Registered Use is Appropriate

Rangeland Forestland

Riparian 

and 

Aquatic

Oil, Gas, 

and 

Minerals

ROW

Recreation 

and Cultural 

Resources

Triclopyr Growth regulator; broadleaf weeds and woody plants. Key species treated include 

mesquite and saltcedar. • • • • • •

Herbicides Proposed for Use on Public Lands

Aminopyralid

Selective herbicide; plant growth regulator; applied postemergence, either aerially or 

using ground application equipment; mobile in both the xylem and phloem, 

accumulating in leaf and root meristematic tissue; limited residual activity; microbial 

degradation. Targeted species include, but are not limited to: Russian knapweed, 

musk thistle, spotted knapweed, yellow starthistle, Russian thistle, and tansy ragwort.

• • • • •

Fluroxypyr

Selective; plant growth regulator; disruption of plant cell growth - auxin mimicking; 

applied to actively growing plants aerially or using ground application equipment; 

mobile in the phloem, and to a lesser extent the xylem; microbial degradation; 

management of several annual and perennial broadleaf species, including ALSresistant kochia biotypes; provides synergistic activity when tank mixed with certain 

active ingredients, improving the management of selected species, including 

pricklypear cactus.

• • • • •

Rimsulfuron

Selective; ALS-inhibiting herbicide, resulting in the inhibition of the biosynthesis of 

the branched amino acids isoleucine, leucine, and valine; applied both preemergence 

and postemergence using ground and aerial application equipment; mobile in both the 

xylem and phloem, but primarily in the phloem; limited residual activity; chemical 

degradation. Target species include cheatgrass and medusahead rye.

• • • • •

• = areas where USEPA approved registration exists and the BLM has approval or proposes to use on public lands, and ◘ = areas where USEPA approved registration exists, but where the BLM does not 

propose to use on public lands. 

Source: Lee 2013.
ALTERNATIVES

applied using ground-based methods in various 

treatment scenarios. As a result of adding the new 

herbicides, it is predicted that use of other herbicides—

particularly glyphosate and imazapic—would decrease 

compared to the No Action Alternative, although not as 

much as under Alternative B.

Under this alternative, the BLM would develop new 

SOPs for aminopyralid, fluroxypyr, and rimsulfuron 

that restrict application by aerial methods.

TABLE 2-3

Average Acreage Treated Annually for Each 

BLM State Jurisdiction During 2006 to 2012 

State Acres Treated 

Annually

Percentage of 

All Public 

Lands Treated

Alaska 0 0.0

Arizona 5,621 1.8

California 1,525 0.5

Colorado 7,842 2.5

Idaho 35,401 11.2

Montana, North Dakota, 

and South Dakota 8,857 2.8

Nevada 11,860 3.8

New Mexico, Oklahoma, 

and Texas 189,654 60.1

Oregon and Washington 12,663 4.0

Utah 8,788 2.8

Wyoming and Nebraska 33,096 10.5

Total 315,307 100.0

Alternative D – No Use of New

Acetolactate Synthase-Inhibiting 

Active Ingredients (No Rimsulfuron)

This alternative would allow the BLM to utilize the two 

new herbicide active ingredients that do not belong to 

the sulfonylurea, or the acetolactate synthase-inhibiting, 

group of herbicide active ingredients. Aminopyralid and 

fluroxypyr would be approved for use, but rimsulfuron 

would not. 

Under this alternative, the BLM would be able to use a 

total of 20 herbicide active ingredients (the 18 

previously approved active ingredients, plus 

aminopyralid and fluroxypyr) on public lands in 17 

western states. These active ingredients could only be 

applied on sites, and at application rates, specified on 

the individual label. Under this alternative, herbicides 

could be applied using ground or aerial methods. 

Herbicides could be used individually or in tank mixes 

with previously approved active ingredients, in 

accordance with label directions. The projected 

maximum annual treatment acreage under this 

alternative would remain at 932,000 acres.

Under this alternative, it is estimated that aminopyralid 

would make up 10 percent of the total projected 

herbicide use on BLM-administered lands, and 

fluroxypyr would make up 1 percent of the total 

projected herbicide use, similar to Alternative B (Table 

2-4). As rimsulfuron would not be approved for use 

under this alternative, the amount of glyphosate and 

imazapic used would be greater than under Alternatives 

B and C, and similar to levels under the No Action 

Alternative. 

Alternatives Considered but Not 

Analyzed Further

The BLM based the alternatives being considered in this 

PEIS on the alternatives that were identified for the 

2007 PEIS. As herbicide treatments on public lands 

have already been approved in the 2007 PEIS, 

Alternative C from that document (No Use of 

Herbicides) is not applicable and does not meet the 

current project purpose and need. Based on a review of 

scoping comments and the current alternatives, no 

additional alternatives were considered for analysis in 

this PEIS. 

Herbicide Treatment Standard 

Operating Procedures and 

Guidelines

Under all of the alternatives, the BLM would follow 

SOPs designed to minimize risks to human health and 

the environment from herbicide treatment actions. 

Standard operating procedures are management controls 

and performance standards that are required of all 

herbicide treatments. They are intended to protect and 

enhance natural resources that could be affected by 

herbicide treatments. The 2007 PEIS (USDOI BLM 

2007a:2-22 to 2-35) provides a detailed discussion of 

these SOPs, which include the following:

• Prevention measures during project planning, 

development, and revegetation phases to 

minimize the risk of introducing or spreading 

noxious weeds.

• Herbicide treatment planning, which includes 

evaluation of the need for chemical treatments 

BLM Vegetation Treatments Three New Herbicides 2-7 January 2016

Final Programmatic EIS
ALTERNATIVES

and their potential for impact on the 

environment, and development of an 

operational plan that includes herbicide buffers 

near water bodies, information on project 

specifications, key personnel responsibilities 

and communication, safety, spill, and response, 

and emergency procedures.

• Procedures specific to site revegetation after 

treatments to promote establishment and/or 

recovery by the native plant community.

• Special precautions to minimize impacts to 

special status species, wilderness areas, and 

cultural resources.

• Standard operating procedures for applying 

herbicides (listed in the 2007 PEIS; USDOI 

BLM 2007a:Table 2-8, 2-30 to 2-35), both 

general and designed to protect specific 

resource elements (air quality, soils, water 

resources, wetlands and riparian areas, 

vegetation, pollinators, fish and other aquatic 

organisms, wildlife, listed species, livestock, 

wild horses and burros, cultural and 

paleontological resources, visual resources, 

wilderness and other special areas, recreation, 

social and economic values, ROWs, and 

human health and safety).

TABLE 2-4

Historic Use of Herbicides by the BLM and Projected Future Use of Herbicides by the BLM Under Each 

Alternative (as a percentage of all acres treated using herbicides) 

Active Ingredient Historic Use 

(2006-2012)

Projected Use Under Each Alternative

No Action 

Alternative

Preferred 

Alternative

Alternative C

(no aerial)

Alternative D

(no ALS inhibiting)

Herbicides Approved for Use on Public Lands

2,4-D 9.3 6 5 6 5

Bromacil 1.1 <1 <1 <1 <1

Chlorsulfuron 2.0 2 1 2 1

Clopyralid 18.3 13 14 14 14

Dicamba 1.9 1.5 <1 1 <1

Diflufenzopyr + 

Dicamba <1 <1 <1 1 <1

Diquat <1 <1 <1 <1 <1

Diuron 1.9 2 <1 <1 <1

Fluridone <1 <1 <1 <1 <1

Glyphosate 8.9 12 5 9 11

Hexazinone <1 <1 <1 <1 <1

Imazapic 1.5 20 10 15 20

Imazapyr 1.7 2 1 1 1

Metsulfuron methyl 2.7 4 1 1 1

Picloram 7.1 8 4 7 4

Sulfometuron methyl 0.2 1 <1 <1 <1

Tebuthiuron 22.5 13 15 15 15

Triclopyr 20.8 15 16 16 16

Herbicides Proposed for Use on Public Lands

Aminopyralid 0 0 10 6 10

Fluroxypyr 0 0 1 <1 1

Rimsulfuron 0 0 16 3 0

BLM Vegetation Treatments Three New Herbicides 2-8 January 2016

Final Programmatic EIS
ALTERNATIVES

All applicable SOPs (i.e., pertaining to herbicide 

treatments) listed in the 2007 PEIS would be followed 

during treatments with aminopyralid, fluroxypyr, and 

rimsulfuron under all of the alternatives considered in 

this PEIS. Additionally, all applicable mitigation 

measures that were identified in the ROD for the 2007

PEIS (USDOI BLM 2007b:Appendix B) would be 

followed, as applicable. Many of these mitigation 

measures are specific to the 18 herbicides covered in the 

2007 PEIS, and therefore would not apply to treatments 

with the three new herbicides unless other herbicides 

were also involved.

Monitoring

Monitoring of vegetation treatments is used to identify 

whether treatments are implemented appropriately and 

determine their effectiveness. The regulations at 43 

CFR 1610.4-9 require that land use plans establish 

intervals and standards for monitoring and evaluating 

land management actions. Specific monitoring protocols 

or studies for vegetation treatment projects are

developed and implemented at the local level. BLM 

manuals, handbooks, and other technical documents 

provide additional information on monitoring of 

specific resources. A list of applicable reference 

manuals and handbooks can be found in Appendix F of 

the 2007 PEIS.

The BLM Assessment, Inventory, and Monitoring 

(AIM) Strategy outlines the BLM monitoring program, 

including monitoring for the vegetation resources found 

on BLM-administered lands and monitoring of the 

effects of treatments on these resources. The AIM

strategy addresses the BLM’s multiple-use and 

sustainable yield mission, and ensures the collection of 

defensible data to inform BLM managers and the public 

about key ecological processes for maintaining 

sustainable ecosystems. The AIM strategy establishes a 

monitoring framework that is consistent and compatible 

across scales, programs, and administrative boundaries. 

The framework includes 1) use of core quantitative 

indicators and consistent methods; 2) implementation of 

a statistically valid, scalable sampling framework; 3) 

application and integration of remote sensing 

technologies; 4) implementation of electronic field data 

collectors and enterprise data management; and 5) 

capture of legacy data in a digital format (Toevs et al. 

2011). As of November 2014, the AIM Strategy has 

adopted core indicators and methods for terrestrial and 

in-stream aquatic resources. Work is ongoing to 

establish indicators and methods that will inform the 

status and trends of other resources the BLM manages.

The BLM has adopted an ecosystem-based management 

approach, which is applied to projects at the sitespecific level. The ecosystem-based management

framework ensures that local level decisions about 

management goals and targets are informed and adapted 

from learning based on science (monitoring) and local 

knowledge.

The 2007 PEIS (USDOI BLM 2007a:2-35 to 2-39) 

provides additional discussion of vegetation treatments 

monitoring, including BLM guidance, procedures for 

implementation, monitoring methods, and dissemination 

of results.

Coordination and Education

As indicated during public scoping for this PEIS and the 

earlier 2007 PEIS, the public has an interest in the 

BLM’s vegetation treatment activities, particularly 

individuals that live in close proximity to public lands, 

have commercial operations that are dependent on 

vegetation on or adjacent to public lands, or use public 

lands for recreation. The BLM strives to keep the public 

informed about its vegetation treatment activities 

through regular coordination and communication. The 

BLM also encourages the public to participate in the 

environmental review process during the development 

and analysis of local vegetation management programs. 

The 2007 PEIS (USDOI BLM 2007a:2-39) summarizes 

the ways in which the public can participate in this 

process, as well as other applicable coordination efforts 

between the BLM and the public.

Prior to herbicide treatments, the BLM posts entry 

points onto public lands where the herbicide application 

will take place. Information provided in the posting 

includes the name of the herbicide product to be 

applied, active ingredients, USEPA registration number, 

application date, the period of time that must elapse 

before a person without protective clothing may enter a 

treatment site, and other warnings or information 

required to ensure the safety of the public. Postings 

remain at treatment sites for as long as necessary to 

protect the public.

Mitigation

This PEIS identifies measures that the BLM proposes to 

implement to mitigate adverse environmental impacts 

identified in Chapter 4 (Environmental Consequences). 

These measures are summarized in Table 2-5. As 

defined by CEQ regulation 1508.20, mitigation 

includes: 1) avoiding the impact altogether by not 

BLM Vegetation Treatments Three New Herbicides 2-9 January 2016

Final Programmatic EIS
ALTERNATIVES

TABLE 2-5

Mitigation Measures

Resource Mitigation Measures

Air Quality None proposed.

Soil Resources None proposed.

Water Resources and Quality None proposed. 

Wetland and Riparian Areas None proposed.

Vegetation

• Establish herbicide-specific buffer zones around downstream water bodies, and nearby 

habitats and non-target plant species/populations of interest for aminopyralid, fluroxypyr, and 

rimsulfuron. Consult the ERAs for more specific information on appropriate buffer distances 

under different soil, moisture, vegetation, and application scenarios. 

• To protect special status plant species, implement all conservation measures for plants 

presented in the Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron 

on Bureau of Land Management Lands in 17 Western States Biological Assessment (USDOI 

BLM 2015). Apply these measures to all special status plant species.

Fish and Other Aquatic Organisms

• To protect special status fish and other aquatic organisms, implement all conservation 

measures for aquatic animals presented in the Vegetation Treatments Using Aminopyralid, 

Fluroxypyr, and Rimsulfuron on Bureau of Land Management Lands in 17 Western States 

Biological Assessment (USDOI BLM 2015).

Wildlife Resources

• When conducting herbicide treatments in or near habitats used by sensitive and listed 

terrestrial arthropods, design treatments to avoid the use of fluroxypyr, where feasible.

• To protect special status wildlife species, implement conservation measures for wildlife 

presented in the Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron 

on Bureau of Land Management Lands in 17 Western States Biological Assessment (USDOI 

BLM 2015). 

Livestock None proposed. 

Wild Horses and Burros None proposed.

Paleontological and Cultural 

Resources None proposed.

Visual Resources None proposed.

Wilderness and Other Special 

Areas

Mitigation measures that may apply to wilderness and special area resources are associated with 

human and ecological health and recreation. Please refer to the Vegetation, Wildlife Resources, and 

Recreation sections of Chapter 4.

Recreation Mitigation measures that may apply to recreational resources are associated with ecological health. 

Please refer to the Vegetation and Wildlife Resources sections of Chapter 4.

Social and Economic Values None proposed.

Human Health and Safety None proposed.

taking a certain action or parts of an action; 2) 

minimizing impacts by limiting the degree or magnitude 

of the action and its implementation; 3) rectifying the 

impact by repairing, rehabilitating, or restoring the 

affected environment; 4) reducing or eliminating the

impact over time by preservation and maintenance 

operations during the life of the action; and 5) 

compensating for the impact by replacing or providing 

substitute resources or environments.

The analysis presented in this PEIS assumes that all of 

the applicable SOPs identified in the 2007 PEIS 

(USDOI BLM 2007a:Table 2-8) would be followed 

during herbicide treatments with the three new active 

ingredients. Additionally, it assumes that all applicable 

mitigation measures developed in the 2007 PEIS and 

included in the ROD for that document (USDOI 

BLM2007b:Table 2-4) would be followed. Therefore, 

only new mitigation measures specific to aminopyralid, 

fluroxypyr, and rimsulfuron are presented in this PEIS.

Summary of Impacts by 

Alternative

Table 2-6 summarizes the likely effects of vegetation 

treatments using aminopyralid, fluroxypyr, and 

rimsulfuron for each alternative. Information contained 

in this table is discussed in more detail in Chapter 4 

(Environmental Consequences).

BLM Vegetation Treatments Three New Herbicides 2-10 January 2016

Final Programmatic EIS
BLM Vegetation Treatments Three New Herbicides

2-11 January 2016

Final Programmatic EIS

ALTERNATIVES

TABLE 2-6

Summary and Comparison of Effects on Resources by Alternative

No Action Alternative Preferred Alternative Alternative C Alternative D

EFFECTS ON AIR QUALITY

General Effects: None of the predicted 

emissions by pollutant or state would 

exceed Prevention of Signification 

Deterioration (PSD) annual emissions 

significance thresholds. Particulate matter 

concentrations from treatments are 

expected to be substantially lower than 

National Ambient Air Quality Standard 

(NAAQS) thresholds, based on modeling. 

Treatments would result in approximately 

206 tons per year (tpy) of total suspended 

particulates (TSP), 62 tpy of carbon 

monoxide (CO), and 45 tpy of particulate 

matter less than 10 microns in diameter 

(PMR

10R). Estimated GHG emissions would 

be 3,350 metric tons COR

2R equivalents per 

year (MTCOR

2R e/yr). Reduction in wildfire 

risk would benefit air quality.

General Effects: Air quality impacts 

would be similar to those under the other 

alternatives, as the treatment acreage under 

all alternatives would be similar. None of 

the predicted annual emissions by pollutant 

or state would exceed PSD annual 

emissions significance thresholds. 

Treatments would result in approximately 

206 tpy of TSP, 62 tpy of CO, and 45 tpy 

of PMR

10R. Estimated GHG emissions would 

be 3,350 MTCOR

2Re/yr. Benefits to air 

quality associated with a reduction in 

wildfire risk would be similar to those 

under the other alternatives.

General Effects: Air quality impacts 

would be similar to those under the other 

alternatives, as the treatment acreage under 

all alternatives would be similar. None of 

the predicted annual emissions by pollutant 

or state would exceed PSD annual 

emissions significance thresholds. 

Emissions of criteria pollutants and GHGs 

would be similar to those under the other 

alternatives. 

General Effects: Air quality impacts 

would be similar to those under the other 

alternatives, as the treatment acreage under 

all alternatives would be similar. None of 

the predicted annual emissions by pollutant 

or state would exceed PSD annual 

emissions significance thresholds. 

Emissions of criterial pollutants and GHGs 

would be similar to those under the other 

alternatives.

Cumulative Effects: The cumulative effects of air quality pollutants from wildfire and prescribed fire, vehicle exhaust, commercial and industrial land uses, and residential heating, 

among other sources, have contributed to deterioration in air quality. Despite these factors, air quality in the U.S. has continued to improve since the early 1980s. Pollutants of primary 

concern continue to be particulate matter and ozone. Greenhouse gas emissions in the U.S., however, continue to increase. The acreage and average size of wildfires also continues to 

increase, contributing larger amounts of air quality pollutants each year. In the future, sources of air quality pollutants will continue to contribute to cumulative air quality emissions, 

and contributions of GHG emissions will also be cumulative, potentially contributing to climate change. Efforts by the BLM to restore historical fire regimes, native vegetation, and 

natural ecosystem processes that reduce the frequency and intensity of wildfire should help reduce the future contribution of wildfire pollutants to cumulative air quality impacts. All 

alternatives would contribute a similar amount to cumulative air quality effects.

EFFECTS ON SOIL RESOURCES

Herbicides would be used on 

approximately 932,000 acres annually. 

None of the herbicides likely to be used 

would result in substantial effects to soil. 

Minor effects to soil and soil organisms 

could occur, but treatments would 

potentially help reduce populations of 

invasive species and reduce wildfire risk. 

Beneficial effects to soil would include 

improved soil productivity and reduced soil 

erosion. 

Herbicides would be used on 

approximately 932,000 acres annually. 

Effects to soil would be similar to those 

under the No Action Alternative. The new 

herbicides are not known to cause 

substantial impacts to soil or soil

organisms. With the addition of the new 

active ingredients, there may be a reduction 

in use of active ingredients that are 

relatively persistent in the soil. Beneficial 

effects to soil would be similar to those 

under the No Action Alternative, and could 

be slightly greater if efficacy of treatments 

is increased.

Herbicides would be used on 

approximately 932,000 acres annually. 

Effects to soil would be similar to those 

under the other alternatives. Use of new 

herbicides would be less than under the 

Preferred Alternative, and use of persistent 

herbicides would be between the No 

Action and Preferred Alternatives. Benefits 

to soil resources could be slightly greater 

than under the No Action Alternative and 

slightly less than under the Preferred 

Alternative.

Herbicides would be used on 

approximately 932,000 acres annually. 

Effects to soil would be similar to those 

under the other alternatives. Overall 

persistence of herbicides in soil and 

benefits as a result of treatments would be 

similar to those under the No Action 

Alternative.
BLM Vegetation Treatments Three New Herbicides

2-12 January 2016

Final Programmatic EIS

ALTERNATIVES

TABLE 2-6 (cont.)

Summary and Comparison of Effects on Resources by Alternative

No Action Alternative Preferred Alternative Alternative C Alternative D

Cumulative Effects: Past effects to soil resources in the western states are predominantly associated with natural resource extraction, grazing, road construction, timber harvesting, 

recreation, agriculture, development, wildland fire, and natural disturbances. These factors have resulted in soil erosion and loss of soil productivity on public lands and throughout the 

West. Future effects associated with these factors are expected to occur, but would be offset, to some degree, by watershed-level restoration treatments by the BLM and other agencies, 

as well as by other conservation programs. All alternatives would contribute a similar amount to impacts to soil resources. Countervailing effects associated with long-term 

improvement in soil function and productivity would also be similar under all the alternatives. The number of herbicides used by the BLM with the potential to impact soil resources 

would be greatest under the Preferred Alternative and Alternative C, and slightly lower under the other alternatives.

EFFECTS ON WATER RESOURCES AND QUALITY

Herbicide treatments would continue to 

have minor impacts on water resources 

through movement into surface water and 

groundwater from treatment sites. 

Herbicides of greatest concern for 

groundwater contamination are 2,4-D, 

diquat, bromacil, dicamba, diuron, 

hexazinone, and picloram. Minor concerns 

are associated with the use of glyphosate 

and tebuthiuron. Treatments to manage

invasive species and reduce wildfire risk 

would continue to benefit watersheds.

There would be similar risks to water 

quality, over the same geographic area, as 

under the other alternatives. Based on 

projected amounts of herbicide use, the use 

of known drinking water contaminants 

would decrease by 11 percent, and use of a 

possible groundwater contaminant 

(imazapic) would decrease by 10 percent.

The Preferred Alternative would be similar 

to the other alternatives in terms of level of 

benefit to watersheds. 

There would be similar risks to water 

quality, over the same geographic area, as 

under the other alternatives. Use of known 

drinking water contaminants and possible 

groundwater contaminants would decrease 

by 9 percent relative to the No Action 

Alternative (1 percent less than under the 

Preferred Alternative). Alternative C would 

be similar to the other alternatives in terms 

of level of benefit to watersheds.

There would be similar risks to water 

quality, over the same geographic area, as 

under the other alternatives. Use of known 

drinking water contaminants and possible 

groundwater contaminants would decrease 

by 4 percent relative to the No Action 

Alternative (6 percent less than under the 

Preferred Alternative). Alternative D would 

be similar to the other alternatives in terms 

of level of benefit to watersheds.

Cumulative Effects: Past effects to water resources are predominantly associated with mining activities, exploration and development of oil resources, agriculture (including use of 

pesticides), industry, and other human activities. Activities that contribute to water quality pollution and depletion will likely continue in the western U.S. These effects will be offset, in 

part, by efforts by the BLM and other land management agencies to improve water quality and restore degraded wetland/riparian areas. All of the alternatives would contribute a similar 

amount to cumulative effects to water quality, as the amount of herbicides applied during treatments would be the same, although there would be some variability in the potential for

different herbicides to reach surface water and groundwater. Under the action alternatives, the number of herbicides used by the BLM would be slightly greater than under the No 

Action Alternative. Countervailing effects associated with herbicide treatments would include long-term improvements in the function of wetlands, riparian areas, streams, and other 

water bodies. 

EFFECTS ON WETLAND AND RIPARIAN AREAS

Approximately 10,000 acres of wetland 

and riparian areas would be treated 

annually. Herbicide use would continue to 

be associated with risks for contamination 

of water and soil, as well as risks to nontarget plant species. Wetlands and riparian 

areas would continue to benefit from 

herbicide treatments that target invasive 

plants, resulting in improvement in 

functions. 

Approximately 10,000 acres of wetland 

and riparian areas would be treated 

annually. Herbicide use would continue to 

be associated with risks for contamination 

of water and soil, as well as risks to nontarget plant species. Use of glyphosate near 

wetlands and in riparian areas would likely 

be reduced with the introduction of 

aminopyralid. The degree of improvement 

to the functions of wetland and riparian 

areas as a result of herbicide treatments 

would be similar under all alternatives.

Approximately 10,000 acres of wetland 

and riparian areas would be treated 

annually. Herbicide use would continue to 

be associated with risks for contamination 

of water and soil, as well as risks to nontarget plant species. Use of glyphosate near 

wetlands and in riparian areas would likely 

be reduced with the introduction of 

aminopyralid. The degree of improvement 

to the functions of wetland and riparian 

areas as a result of herbicide treatments 

would be similar under all alternatives.

Approximately 10,000 acres of wetland 

and riparian areas would be treated 

annually. Herbicide use would continue to 

be associated with risks for contamination 

of water and soil, as well as risks to nontarget plant species. Use of glyphosate near 

wetlands and in riparian areas would likely 

be reduced with the introduction of 

aminopyralid. The degree of improvement 

to the functions of wetland and riparian 

areas as a result of herbicide treatments 

would be similar under all alternatives.
BLM Vegetation Treatments Three New Herbicides

2-13 January 2016

Final Programmatic EIS

ALTERNATIVES

TABLE 2-6 (cont.)

Summary and Comparison of Effects on Resources by Alternative

No Action Alternative Preferred Alternative Alternative C Alternative D

Cumulative Effects: Past effects to wetland and riparian areas in the western U.S. have occurred as a result of natural resource extraction, recreation, dams and diversions, road 

construction, agriculture, urbanization, and fire exclusion, among other factors. While these factors continue, to varying degrees, ongoing efforts to protect wetlands and riparian areas 

have reduced their level of impact. Vegetation treatment programs by the BLM and Forest Service, as well as efforts by other agencies, private landowners, and conservation groups, 

continue to improve the condition of degraded wetland and riparian habitat. Restoring natural fire regimes and native vegetation, and controlling invasive vegetation, would improve 

wetland and riparian habitat and function, with benefits similar under all the alternatives. Under all alternatives, some herbicides would be released into wetland and riparian areas, and 

removal of vegetation could have short-term impacts to the functions of these areas. Contributions to cumulative effects would be similar under all alternatives. 

EFFECTS ON VEGETATION

The BLM would continue to implement 

vegetation treatments using herbicides that 

would have the goal of restoring native and 

desirable plant communities and natural 

fire regimes. Short-term adverse effects to 

non-target vegetation could occur, and 

treatment design would need to consider 

special status species and populations. 

Long-term benefits would include a 

reduction in the spread of invasive plants

and a reduction in the risk of future 

wildfire.

Herbicide treatments would be 

implemented in similar locations and with 

similar goals as under the No Action 

Alternative, but with more options for 

managing invasive plants in terms of active 

ingredients used. Short-term adverse 

effects to non-target vegetation and risks to 

sensitive species and populations would be 

similar to those under the other alternatives. 

The efficacy of some herbicide treatments 

could be improved through use of the new 

active ingredients, which may be more 

effective at managing target species than 

currently approved herbicides, and may 

improve control of populations that have 

developed a resistance to currently 

approved herbicides. Therefore, long-term

benefits may be greater than under the No 

Action Alternative.

Herbicide treatments would be 

implemented in similar locations and with 

similar goals as under the other 

alternatives, but with more herbicide 

options for ground-based control of 

invasive plants than under the No Action 

Alternative. There would be fewer options 

for aerial control than under the Preferred 

Alternative. Short-term adverse effects to 

non-target vegetation and risks to sensitive 

species and populations would be similar to 

those under the other alternatives. The 

efficacy of some herbicide treatments could 

be improved through use of the new active 

ingredients, but only for ground-based 

treatments. Long-term benefits associated 

with ground-based treatments would be 

similar to those under the Preferred 

Alternative.

Herbicide treatments would be 

implemented in similar locations and with 

similar goals as under the other 

alternatives. Options for managing invasive 

plants would be greater than under the No 

Action Alternative but less than under the 

Preferred Alternative, as rimsulfuron would 

not be approved for use, so there would be 

fewer options for management of annual 

grasses such as cheatgrass and medusahead

rye. Short-term adverse effects to nontarget vegetation and risks to sensitive 

species and populations would be similar to 

those under the other alternatives. The 

efficacy of some herbicide treatments could 

be improved through use of the new active 

ingredients, but likely less than under the 

Preferred Alternative. Long-term benefits 

may be greater than under the No Action 

Alternative, but less than under the other 

action alternatives.

Cumulative Effects: Past effects to vegetation and native plant communities are predominantly associated with exclusion of fire and alteration of natural disturbance regimes, timber 

harvest, reseeding and planting programs, and grazing. Human activities have altered native plant communities, and have led to the introduction and spread of invasive plants. Many of 

these same human activities will continue to do so in the future, with populations of invasive plants continuing to spread and altered disturbance regimes continuing to contribute to

large wildfires that further alter vegetation. Herbicide treatments under all alternatives would kill target and non-target species, but would benefit vegetation by controlling invasive 

plants, restoring native plant communities, and reducing wildfire risk. The types of adverse and beneficial effects would be similar under all alternatives, although the action alternatives 

may allow the BLM to be more successful at reaching treatment goals by providing additional herbicide options. 
BLM Vegetation Treatments Three New Herbicides

2-14 January 2016

Final Programmatic EIS

ALTERNATIVES

TABLE 2-6 (cont.)

Summary and Comparison of Effects on Resources by Alternative

No Action Alternative Preferred Alternative Alternative C Alternative D

EFFECTS ON FISH AND OTHER AQUATIC ORGANISMS

There would continue to be toxicological 

risks to fish and other aquatic organisms 

(including sensitive species) associated 

with use of herbicides, with buffers and 

other SOPs required to protect these 

organisms from harm. Long-term 

beneficial effects to aquatic organisms 

would include habitat improvements 

through management of invasive plants in 

aquatic habitats, wetlands, and riparian 

areas, and reduced sedimentation through 

treatments to reduce the risk of wildfire.

With the introduction of the three new 

active ingredients, there would be a 

potential for reduced toxicological risks to 

fish and other aquatic organisms, relative to 

the No Action Alternative, from BLM 

herbicide treatments. Aminopyralid, 

fluroxypyr, and rimsulfuron have a very 

low toxicological risk to fish. In some 

circumstances they would be used instead 

of currently approved active ingredients 

with a greater risk, such as picloram and 

glyphosate. Long-term beneficial effects to 

aquatic organisms through habitat 

improvement and reduced fire risk would 

be similar to those under the other 

alternatives.

Toxicological risks to fish and other 

aquatic organisms could be slightly lower 

than under the No Action Alternative, as 

there would be slightly less glyphosate and 

picloram used than under the No Action 

Alternative, but more use than under the 

Preferred Alternative. Long-term beneficial 

effects to aquatic organisms through habitat 

improvement and reduced fire risk would 

be similar to those under the other 

alternatives.

Toxicological risks to fish and other 

aquatic organisms would be similar to 

those under the No Action Alternative, as 

the breakdown of herbicide use would be 

similar, with only a slight reduction in the 

use of most of the currently approved 

active ingredients. Long-term beneficial 

effects to aquatic organisms through habitat 

improvement and reduced fire risk would 

be similar to those under the other 

alternatives.

Cumulative Effects: Past effects to fish and other aquatic organisms are predominantly associated with natural resource extraction; recreation; fire exclusion; construction of roads, 

dams, and hydropower facilities; agriculture; and urbanization. In Alaska, oil and gas development, and subsistence and recreational fishing, have been the primary factors affecting fish 

and aquatic resources. These activities will continue into the future, and will continue to contribute to the degradation aquatic habitats and other adverse cumulative effect to fish. These

adverse effects will be offset, to some degree, by protective regulations and restoration efforts, driven by goals to improve water quality and regain the proper functioning condition of 

riparian areas. Additionally, efforts to remove dams and other blockages to fish passage will continue to benefit fish populations. The contribution to cumulative effects would be 

similar under all of the alternatives. Herbicide treatments would pose toxicological risks to fish and could alter aquatic habitats, but countervailing effects would be associated with 

long-term improvement in function of aquatic habitats. The action alternatives would entail use of a slightly greater number of active ingredients than under the No Action Alternative. 

EFFECTS ON WILDLIFE

Herbicide treatments would continue to 

benefit wildlife, with goals that include 

improving wildlife habitat, restoring native 

plant communities, and reducing wildfire 

risk. There would continue to be 

toxicological risks to wildlife (including 

sensitive species) associated with herbicide 

use, with the greatest concern associated 

with 2,4-D, bromacil, diquat, and diuron. 

Their use would account for 10 percent of 

acres treated.

Benefits to wildlife would be similar to 

those under the other alternatives, since the 

total acreage of wildlife habitat treated 

would be similar. Some increased efficacy 

of treatments is possible with the 

introduction of the three new active 

ingredients. Overall toxicological risks to 

wildlife could be slightly lower than under 

the No Action Alternative. Use of active 

ingredients with the greatest concern for 

toxicological effects would account for 

approximately 8 percent of acres treated.

Benefits to wildlife would be similar to 

those under the other alternatives, since the 

total acreage of wildlife habitat treated 

would be similar. Some increased efficacy 

of treatments is possible with the 

introduction of the three new active 

ingredients, but less than under the 

Preferred Alternative since aerial 

treatments of the new herbicides would not 

be allowed. Use of active ingredients with 

the greatest concern for toxicological 

effects would account for approximately 9 

percent of acres treated.

Benefits to wildlife would be similar to 

those under the other alternatives, since the 

total acreage of wildlife habitat treated 

would be similar. Some increased efficacy 

of treatments is possible with the 

introduction of the three new active 

ingredients, but less than under the 

Preferred Alternative since use of 

rimsulfuron would not be allowed.

Use of active ingredients with the greatest 

concern for toxicological effects would 

account for approximately 8 percent of 

acres treated, which is the same as under 

the Preferred Alternative, and slightly 

lower than under the other alternatives.
BLM Vegetation Treatments Three New Herbicides

2-15 January 2016

Final Programmatic EIS

ALTERNATIVES

TABLE 2-6 (cont.)

Summary and Comparison of Effects on Resources by Alternative

No Action Alternative Preferred Alternative Alternative C Alternative D

Cumulative Effects: The primary factors contributing to habitat loss and modification in the western U.S. include land conversion to agriculture, pastureland, and residential, 

commercial, industrial and other development; grazing by domestic livestock and wild horses and burros; timber management; fire suppression; and invasion by weeds and other 

undesirable vegetation. Many of these activities will continue to occur into the future, and will continue to contribute to loss, modification, and fragmentation of habitat, potentially 

increasing the likelihood of local extirpations of wildlife populations and loss of species diversity. Actions to protect sensitive species and their habitat, restore native plant communities 

and disturbance regimes, control the spread of invasive species, and reduce the risk of wildfire would all be expected to help offset some of the adverse impacts to wildlife and their 

habitat. Under all alternatives, herbicide treatments would contribute to cumulative effects to wildlife through habitat modifications and release of herbicides into occupied habitat. 

Countervailing long-term effects associated with restoration of native plant communities and disturbance regimes would also be similar under all the alternatives. By allowing the BLM 

the flexibility to use additional herbicides, the action alternatives would result in the release of a larger number of active ingredients. As the three herbicides have a very low risk to 

wildlife, a cumulative effect of adding these active ingredients could be a reduction in overall risk to wildlife associated with herbicide treatments, as herbicides with a greater risk to 

wildlife would potentially be used less.

EFFECTS ON LIVESTOCK

Herbicide treatments would continue to 

have some risk for toxicological effects to 

livestock that graze in treated rangelands. 

Beneficial effects of herbicide treatments 

would include long-term improvements to 

rangeland vegetation through management

of noxious weeds, reduction of wildland 

fire risk, and on some rangelands the 

seeding of non-target species after the 

herbicide treatment.

The overall toxicological risk to livestock 

could be lower than under the No Action 

Alternative; approximately 7 percent fewer 

acres would be treated with herbicides that 

have some level of risk to livestock. 

Beneficial effects to livestock from 

improvement of rangeland condition would 

be similar to those under the No Action 

Alternative. The new active ingredients 

could increase the efficacy of certain 

herbicide treatments. 

The overall toxicological risk to livestock 

could be lower than under the No Action 

Alternative; approximately 5 percent fewer 

acres would be treated with herbicides that 

have some level of risk to livestock. 

Beneficial effects to livestock from 

improvement of rangeland condition would 

be similar to those under the No Action 

Alternative. The new active ingredients 

could increase the efficacy of certain 

herbicide treatments, although not to the 

same degree as under the Preferred 

Alternative, since aerial applications of the 

new herbicides would not be allowed.

The overall toxicological risk to livestock 

could be lower than under the No Action 

Alternative. Similar to the Preferred 

Alternative, approximately 7 percent fewer 

acres would be treated with herbicides that 

have some level of risk to livestock. The 

new active ingredients could increase the 

efficacy of certain herbicide treatments, 

although not to the same degree as under 

the Preferred Alternative, since use of 

rimsulfuron would not be allowed.

Cumulative Effects: Past effects to livestock are predominantly associated with a decrease in the ability of public lands to support livestock grazing, which has occurred as a result of 

changes in fire regimes and the spread of noxious weeds. Past livestock grazing has contributed to these adverse effects, as have mineral extraction, recreation, and other activities. 

Many of these factors are ongoing and will continue to impact the quality of rangelands utilized by livestock. These effects will be minimized or offset by ongoing management 

programs designed to restore ecosystem processes and maintain livestock populations in balance with the health of rangelands. Under all of the alternatives, herbicide treatments would 

contribute short-term adverse effects by removing large areas of vegetation and non-target species used by livestock as forage. Countervailing effects of treatments would include 

improvement in the quality of rangeland forage and controlling noxious weeds that are unpalatable or toxic to livestock. All of the alternatives would be similar as far as the level of 

their effects. Under the action alternatives, the toxicological risks to livestock associated with herbicide treatments could potentially decrease, as there would be less use of more 

potentially harmful active ingredients.
BLM Vegetation Treatments Three New Herbicides

2-16 January 2016

Final Programmatic EIS

ALTERNATIVES

TABLE 2-6 (cont.)

Summary and Comparison of Effects on Resources by Alternative

No Action Alternative Preferred Alternative Alternative C Alternative D

EFFECTS ON WILD HORSES AND BURROS

Herbicide treatments would continue to 

have some risk for toxicological effects to 

wild horses and burros that graze in treated 

rangelands. Herbicide treatments would 

continue to benefit wild horses and burros 

through improvements in the quality of 

forage on rangelands.

Compared to the No Action Alternative, 

approximately 7 percent fewer acres would 

be treated with herbicides that have some 

level of risk to wild horses and burros. 

Long-term benefits to rangelands used by 

wild horses and burros would be similar to 

those under the No Action Alternative. The 

addition of the new active ingredients may 

allow the BLM to more effectively control 

invasive species and reduce fire risk in 

certain areas.

Compared to the No Action Alternative, 

approximately 5 percent fewer acres would

be treated with herbicides that have some 

level of risk to wild horses and burros. 

Long-term benefits to rangelands used by 

wild horses and burros would be similar to 

those under the other alternatives. The 

addition of the new active ingredients may 

allow the BLM to more effectively control

invasive species and reduce fire risk in 

certain areas, although they would not be 

used for aerial applications.

Compared to the No Action Alternative, 

approximately 7 percent fewer acres would 

be treated with herbicides that have some 

level of risk to wild horses and burros, 

similar to the Preferred Alternative. Longterm benefits to rangelands used by wild 

horses and burros would be similar to those 

under the other alternatives. The addition of 

the new active ingredients may allow the 

BLM to more effectively control invasive 

species and reduce fire risk in certain areas, 

although use of rimsulfuron would be 

prohibited.

Cumulative Effects: Populations of wild horses and burros decreased drastically in the 1930s and 1940s as a result of capture and removal activities, which were later halted. Presently, 

the BLM attempts to maintain populations at levels that can be supported by the available resources, but populations continue to be well above that level. Development, grazing, and 

building of fences and other structures that impede herd movements have all contributed to cumulative adverse effects to wild horses and burros by reducing the quantity or value of 

available forage. The BLM will continue management efforts to keep wild horse and burro populations in balance with the condition of rangelands, which will require continued 

removal and adoption of animals, as well as measures to control reproduction. Under all of the alternatives, herbicide treatments would contribute short-term adverse effects by 

removing large areas of vegetation and non-target species used by wild horses and burros as forage. Countervailing effects of treatments would include improvement in the quality of 

rangeland forage and controlling noxious weeds that are unpalatable or toxic to wild horses and burros. All of the alternatives would be similar as far as the level of their effects. Under 

the action alternatives, the toxicological risks to wild horses and burros associated with herbicide treatments could potentially decrease, as there would be less use of more harmful 

active ingredients.

EFFECTS ON PALEONTOLOGICAL AND CULTURAL RESOURCES

Herbicide use would continue to have risks 

for adversely affecting fossils and cultural 

resources through chemical exposure and 

vehicle travel. Native Americans would be 

at risk for exposure to herbicides through 

dermal contact, ingestion of treated 

materials, or swimming in a treated water 

body. Currently approved herbicides 

associated with risks to Native Americans

(2,4-D, diquat, and hexazinone) would 

account for approximately 8 percent of all 

acres treated. Non-target plants and other 

subsistence or traditional use resources

could potentially be impacted, but there 

would be long-term benefits to these 

resources through restoration of native 

habitats and reduction of fire risk. 

Risks to paleontological and cultural 

resources, including subsistence resources, 

would be similar to those under the other 

alternatives. The new active ingredients are 

not associated with human health risks to 

Native Americans. Use of currently 

approved herbicides associated with risks 

to these receptors would account for 

approximately 7 percent of all acres treated 

(just 1 percent lower than the No Action 

Alternative). Long-term benefits to 

resources of importance to Native 

Americans would be similar to those under 

the other alternatives. 

Risks to paleontological and cultural 

resources, including subsistence resources, 

would be similar to those under the other 

alternatives. Use of currently approved 

herbicides associated with risks to these 

receptors would be the same as under the 

No Action Alternative (8 percent; slightly 

higher than under the Preferred 

Alternative). Long-term benefits to 

resources of importance to Native 

Americans would be similar to those under 

the other alternatives.

Risks to paleontological and cultural 

resources, including subsistence resources, 

would be similar to those under the other 

alternatives. Use of currently approved 

herbicides associated with risks to these 

receptors would be the same as under the 

Preferred Alternative (7 percent). Longterm benefits to resources of importance to 

Native Americans would be similar to 

those under the other alternatives.
BLM Vegetation Treatments Three New Herbicides

2-17 January 2016

Final Programmatic EIS

ALTERNATIVES

TABLE 2-6 (cont.)

Summary and Comparison of Effects on Resources by Alternative

No Action Alternative Preferred Alternative Alternative C Alternative D

Cumulative Effects: Past exploration and development in the western U.S. has led to legal and illegal collection of paleontological resources and inadvertent damage of these 

resources. Many cultural resources have been lost or damaged by the exposure to the elements and by collection or destruction of cultural sites. These losses are permanent, but have 

been slowed by legislation designed to protect these resources from damage and removal. While the widespread loss and damage of paleontological and cultural resources has been

slowed, ground disturbing activities with the potential to disturb undiscovered resources continue to occur in the western U.S. These activities include resource extraction, livestock 

grazing, and motorized recreation, among others. Over time, additional buried resources may be exposed naturally through erosion, increasing their susceptibility to damage or 

collection. Additionally, wildfires and invasive species have altered native plant communities, and continue to displace native plants and animals that provide traditional lifeway values 

to Native peoples. The contribution of herbicide treatments to adverse effects would be similar under all alternatives, with countervailing effects associated with managing invasive 

species and reducing the risk of wildfire, which would improve conditions for native plants and animals that provide traditional lifeway values. Potential human health risks to Native 

peoples would be similar under all alternatives, with low use of herbicides with a toxicological risk to humans, and SOPs implemented to prevent exposure.

EFFECTS ON VISUAL RESOURCES

Herbicide treatments would continue to 

have short-term adverse effects on visual 

resources by removing vegetation and 

creating a visual contrast to green, 

untreated vegetation. Long-term benefits to 

visual resources would be associated with 

removal of noxious weeds, restoration of 

native plant communities, and reduction in 

visual impacts associated with wildfire.

Short-term adverse effects and long-term 

beneficial effects to visual resources would 

be similar to those under the other 

alternatives, as the geographic locations 

and size of treatments would be similar. 

Short-term adverse effects and long-term 

beneficial effects to visual resources would 

be similar to those under the other 

alternatives, as the geographic locations 

and size of treatments would be similar.

Short-term adverse effects and long-term 

beneficial effects to visual resources would 

be similar to those under the other 

alternatives, as the geographic locations 

and size of treatments would be similar.

Cumulative Effects: Humans have altered the visual character of lands in the western U.S. through activities such as resource extraction, agriculture, road construction, urbanization 

and other development, timber harvesting, livestock grazing, introduction of exotic species, and exclusion of fire. As a result, landscapes have changed, and are now marked by 

different vegetation composition, structure, and pattern. These activities continue to influence visual characteristics and the scenic quality of landscapes. Ongoing vegetation treatment 

programs would alter the visual quality of public lands over the short term by removing vegetation, and in some cases creating large areas of open, browned, or blackened landscapes. 

However the BLM’s long-term goals to restore degraded lands and reinstate properly functioning ecosystem processes will likely help improve the visual character of public lands. All 

of the alternatives would have the same degree of effect to visual resources, and the same level of contribution to visual effects. None of the alternatives would alter land uses on public 

lands, or introduce long-term changes that would be in conflict with the BLM’s visual resource management goals. Over the long term, all of the alternatives would be expected to 

contribute positively to scenic qualities of public lands. Additionally, all of the alternatives would help reduce the risk of wildfire that has a visual impact on public lands and other 

scenic lands in the western U.S.

EFFECTS ON WILDERNESS AND OTHER SPECIAL AREAS

Herbicide treatments would continue to 

result in some disturbance to wilderness 

and other special areas, as well as shortterm site closures. Long-term benefits 

would include a reduction in the 

establishment and spread of invasive 

species in these areas, which would

improve the naturalness component of 

wilderness character, and a reduced risk of 

loss of pristine areas to wildfire. 

Adverse effects and long-term beneficial 

effects to wilderness and other special areas 

would be similar to those under the other 

alternatives, as the areas receiving 

treatments and the goals of treatments 

would be similar. Treatments would 

improve the naturalness component of 

wilderness character.

Adverse effects and long-term beneficial 

effects to wilderness and other special areas 

would be similar to those under the other 

alternatives, as the areas receiving 

treatments and the goals of treatments 

would be similar. Treatments would 

improve the naturalness component of 

wilderness character.

Adverse effects and long-term beneficial 

effects to wilderness and other special areas 

would be similar to those under the other 

alternatives, as the areas receiving 

treatments and the goals of treatments 

would be similar. Treatments would 

improve the naturalness component of 

wilderness character.
BLM Vegetation Treatments Three New Herbicides

2-18 January 2016

Final Programmatic EIS

ALTERNATIVES

TABLE 2-6 (cont.)

Summary and Comparison of Effects on Resources by Alternative

No Action Alternative Preferred Alternative Alternative C Alternative D

Cumulative Effects: Factors that degrade the unique qualities of wilderness and other special areas include invasive species, wildland fire suppression, loss of water and deterioration 

in water quality, fragmentation and isolation, loss of threatened and endangered species, deterioration in air quality, motorized and mechanical equipment trespass and use, increasing 

commercial and public recreation use, adjacent land uses, and urbanization and encroachment. These threats are ongoing, and will continue to impact the unique qualities of wilderness 

and other special areas. Increases in population and pressure to utilize protected areas for resource extraction may result in further loss or degradation of these areas. Vegetation 

treatment programs in and near these areas that aim to control the spread of noxious weeds and restore natural fire regimes, if successful, would help reduce some of the threats to 

wilderness and other special areas, but not others. All of the alternatives would contribute short-term adverse effects associated with site closures and disturbances during herbicide 

treatments. Countervailing effects associated with slowing future degradation of these areas or improving them through management of invasive species and restoration of native 

habitats and disturbance regimes would also be the same under all the alternatives.

EFFECTS ON RECREATION

Herbicide treatments would continue to be 

associated with temporary closures of 

recreation sites and potential human health 

risks to visitors if accidental exposures 

occur. Beneficial effects would include 

improving the condition of sites used for 

recreation and resources sought during 

recreation, and reducing risk of wildland 

fire and associated longer-term adverse 

effects to recreation in burned areas.

Adverse effects and long-term beneficial 

effects to recreation would be similar to 

those under the other alternatives, as the 

areas receiving treatments and the goals of 

treatments would be similar. 

Adverse effects and long-term beneficial 

effects to recreation would be similar to 

those under the other alternatives, as the 

areas receiving treatments and the goals of 

treatments would be similar. 

Adverse effects and long-term beneficial 

effects to recreation would be similar to 

those under the other alternatives, as the 

areas receiving treatments and the goals of 

treatments would be similar. 

Cumulative Effects: The BLM provides opportunities for outdoor recreation for millions of visitors annually. However, other uses of BLM lands, such as livestock grazing, timber 

harvesting, and oil and gas activities, have limited recreation opportunities in certain locations. Additionally, the spread of invasive plants and wildfires have adversely affected 

recreation opportunities. With the growth of the population in the West and a continued interest in recreation, the amount of use that BLM lands receive by the public will likely 

continue to increase. Existing lands and recreational facilities will be used more intensively, potentially reducing the recreation experience in certain areas and resulting in degradation 

of recreational facilities. Vegetation management programs to improve wildlife habitat quality, control the spread of invasive species, and reduce wildfire risk, will continue to offset

some of the impacts caused by recreationists, as well as improve the quality of recreational opportunities on public lands. All alternatives would contribute the same amount to 

cumulative effects. Short-term adverse effects associated with temporary closures of recreation sites would be offset by long-term beneficial effects associated with management of 

invasive species, reduction of wildfire risk, and restoration of native plant communities, which would potentially improve recreational experiences.

EFFECTS ON SOCIAL AND ECONOMIC VALUES

Social and economic benefits and impacts 

from herbicide treatments would be similar 

to what has occurred during the past 

several years. Herbicide treatments would 

continue to generate some employment in 

the geographic areas affected by the 

treatments. Ongoing consultation with 

Indian tribes about the location and timing 

of future treatments would be used to 

prevent environmental justice effects.

Estimated costs to treat vegetation would 

be approximately $89.1 million per year. 

Herbicide treatments would continue to 

Social and economic benefits and impacts 

from herbicide treatments would be similar 

to those under other the other alternatives. 

Based on estimates of herbicide costs and 

amount of future use, costs to treat the 

same amount of vegetation could be 1 to 2 

percent lower per year than under the No 

Action Alternative. 

Social and economic benefits and impacts 

from herbicide treatments would be similar 

to those under the other alternatives. Based 

on estimates of herbicide costs and amount 

of future use, costs to treat the same 

amount of vegetation could be less than 1 

percent lower per year than under the No 

Action Alternative.

Social and economic benefits and impacts 

from herbicide treatments would be similar 

to those under other the other alternatives. 

Based on estimates of herbicide costs and 

amount of future use, costs to treat the 

vegetation would be similar to those under 

the No Action Alternative.
BLM Vegetation Treatments Three New Herbicides

2-19 January 2016

Final Programmatic EIS

ALTERNATIVES

TABLE 2-6 (cont.)

Summary and Comparison of Effects on Resources by Alternative

No Action Alternative Preferred Alternative Alternative C Alternative D

provide economic benefits by reducing loss 

of property to wildfire. Commercial 

activities that occur on public lands would 

continue to be impacted a minor amount by 

herbicide treatments. There would be a risk 

that herbicide treatments could impact 

private property and result in damage to 

crops or other non-target plants of 

economic value.

Cumulative Effects: Social and economic factors that are important from the perspective of public lands include the continued population growth in the western U.S., environmental 

justice concerns associated with communities with high densities of Native Americans and other minority populations, the importance of jobs and industries associated with natural 

resources and resource extraction, increasing wildfire risks and associated risks to private property, and economic benefits from activities conducted on BLM lands, such as grazing, 

harvest of timber and other forest products, and oil and gas development. It is expected that populations in the western U.S. will continue to increase, and that use of BLM-administered 

lands by the public will also continue to increase. Population growth is cumulative, and actions on public lands and elsewhere will continue to affect greater numbers of people, 

including larger minority and low income populations. BLM lands will continue to provide a source of land for the federal government and local economies, with a possible low-level 

increase in those benefits through activities to improve the condition of rangelands and other public lands. Oil and gas and mineral resource extraction on public lands are expected to 

continue to be important sources of income into the future. Recreation is also likely to continue to be an important source of income, with vegetation treatments that improve the quality 

of public lands for recreation likely to benefit recreational opportunities. It is expected that effects to private property from activities on public lands will be an increasing concern, 

although efforts by the BLM, Forest Service, and other agencies to reduce wildfire risk may have an overall benefit to private property over the long term if incidence and severity of 

wildfire is reduced, particularly in the wildland-urban interface. The contribution to cumulative effects to social and economic resources would be similar under all the alternatives, with 

slight differences in the costs of herbicide treatments.

EFFECTS ON HUMAN HEALTH AND SAFETY

Use of herbicides would continue to be 

associated with some amount of risk to the 

human health of herbicide applicators and 

the public. Currently approved herbicides 

with the greatest amount of associated risk 

include 2,4-D, bromacil, diquat, fluridone, 

hexazinone, tebuthiuron, and triclopyr. 

These herbicides would account for an 

estimated 38 percent of the total treatment 

acres under the No Action Alternative. 

Benefits associated with herbicide 

treatments would include reductions in the 

occurrence of noxious weeds and a reduced 

risk of wildfire, which is associated with 

smoke-related health risks and loss of life 

and property.

The three new active ingredients have no to 

low risk to human health (except for 

accidental occupational exposures to 

rimsulfuron). However, projected use of 

higher risk currently approved herbicides 

would increase slightly, to approximately 

40 percent of all treated acres. Benefits 

associated with herbicide treatments would 

be similar to those under the other 

alternatives.

Projected use of herbicides with the 

greatest amount of human health risk 

would increase slightly, to approximately 

41 percent of all treated acres. Benefits 

associated with herbicide treatments would 

be similar to those under the other 

alternatives.

Projected use of herbicides with the 

greatest amount of human health risk 

would increase slightly, to approximately 

40 percent of all treated acres, similar to the 

Preferred Alternative. Benefits associated 

with herbicide treatments would be similar 

to those under the other alternatives.
BLM Vegetation Treatments Three New Herbicides

2-20 January 2016

Final Programmatic EIS

ALTERNATIVES

TABLE 2-6 (cont.)

Summary and Comparison of Effects on Resources by Alternative

No Action Alternative Preferred Alternative Alternative C Alternative D

Cumulative Effects: The public and workers have been exposed to human health and safety risks associated with a wide variety of factors, including use of equipment and tools, 

exposures to chemicals, and wildfire, among others. These will continue to be concerns in the future. Many occupations (such as firefighting and operation of heavy equipment) will 

continue to be associated with some level of risk, although ongoing actions to reduce health and safety risks will likely help reduce the incidence of injury and illness. The public will 

continue to be exposed to various pollutants; the cumulative effects of these exposures could include development of cancer and health conditions. Vegetation management programs 

by the BLM and other agencies to reduce catastrophic fire risk would continue to offset some of the health risk associated with exposure to smoke/wildfire in targeted areas, such as the 

wildland-urban interface where the most people are likely to be affected. Under all of the alternatives, herbicides with some risk to human health would be applied in similar locations 

on public lands, although the number of herbicides used and the amounts of usage would vary among the alternatives. Under the action alternatives, two or three new active ingredients 

would be used, in addition to currently approved herbicides, resulting in a cumulative increase in the number of ingredients used on public lands. The new herbicides have no to very 

low risk to human health via various exposure scenarios. The potential for synergistic human health effects associated with mixtures of multiple ingredients is not known. Benefits to 

human health from herbicide treatments would be similar under all the alternatives. Treatments would help reduce wildfire risk and associated risks to human health. Over the long 

term, restoration of natural fire regimes and improvement in ecosystem health should reduce risks to human health from activities originating on public lands and affecting public land 

users or those living near public lands.