United States Department of Agriculture

Draft Record of Decision

Forest-wide Site-Specific

Invasive Plant Management

Environmental Impact Statement

Okanogan, Chelan, Yakima, and Kittitas Counties in Washington

for the greatest good

August 2016
Cover photo: Field of whitetop.

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Table of Contents

Introduction ...................................................................................................................................................2

Location and Area.....................................................................................................................................2

Background ...............................................................................................................................................4

Tribal Consultation and Public Involvement.................................................................................................4

Purpose and Need..........................................................................................................................................5

Reasons for my Decision...............................................................................................................................6

Compliance with Policies and Management Direction Related to Invasive Plant Management...................9

Other Alternatives Considered ....................................................................................................................10

Alternative 1 – No Action.......................................................................................................................11

Why Alternative 1 was not selected ....................................................................................................11

Alternative 3 – Reduced Herbicide Use..................................................................................................12

Why Alternative 3 was not selected ....................................................................................................12

Findings Required by Laws and Regulations..............................................................................................18

National Forest Management Act ...........................................................................................................18

Endangered Species Act of 1973 ............................................................................................................19

Plants...................................................................................................................................................19

Fish ......................................................................................................................................................19

Wildlife................................................................................................................................................19

Wilderness Act of 1964...........................................................................................................................20

Roadless Area Conservation Rule...........................................................................................................20

Wild and Scenic Rivers Act....................................................................................................................20

National Historic Preservation Act of 1966............................................................................................20

Migratory Bird Treaty Act of 1918 and Executive Order 13186............................................................20

Irreversible or Irretrievable Impacts........................................................................................................20

Long-term Productivity...........................................................................................................................20

Energy Requirements and Conservation Potential..................................................................................21

Prime Farmlands.....................................................................................................................................21

Executive Orders 11988 and 11990: Floodplains and Wetlands ............................................................21

Executive Order 13112: Invasive Species...............................................................................................21

Executive Order 12898: Environmental Justice......................................................................................21

Executive Order 13443: Facilitation of Hunting Heritage and Wildlife Conservation...........................22

Environmentally Preferred Alternative .......................................................................................................22

Pre-Decisional Administrative Review or Objection Opportunities...........................................................22

Implementation............................................................................................................................................24

Contact Person.............................................................................................................................................25

ATTACHMENT 1 ......................................................................................................................................27

Current Range of Treatment Method Options For Known Species ....................................................27

Project Design Features (Mitigation Measures)..................................................................................37
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DRAFT Record of Decision

Okanogan-Wenatchee National Forest Forest-wide Site-Specific Invasive 

Plant Management

Environmental Impact Statement

Okanogan, Chelan, Yakima, and Kittitas Counties in Washington

Introduction

This Record of Decision (ROD) documents my decision and rationale for selecting Alternative 2

of the Okanogan-Wenatchee National Forest Forest-wide Site-specific Invasive Plant 

Management Project. Alternative 2 is the environmentally preferred alternative. My decision

authorizes a range of integrated invasive plant treatment and restoration methods that will be 

implemented across the Okanogan-Wenatchee National Forest for the next 5 to 15 years or 

longer.

My decision includes a non-significant amendment to both the Okanogan-Wenatchee National 

Forest Land and Resource Management Plans (Forest Plans), adding aminopyralid to the list of 

herbicides for use as part of the integrated treatment toolbox for invasive plants on the OkanoganWenatchee National Forest (OKAWEN).

In arriving at my decision, I have considered the analysis that is documented in the OkanoganWenatchee National Forest Forest-wide Site-specific Invasive Plant Management Final 

Environmental Impact Statement (FEIS) (USDA Forest Service 2016), information in the project 

file, and input received from the public during the course of the analysis of this project as 

required by the National Environmental Policy Act (NEPA) of 1969.

This ROD was developed according to requirements of the National Environmental Policy Act of 

1969 (42 USC §§ 4321-4370), the Council of Environmental Quality’s implementing regulations 

(40 CFR §§ 1500-1508), Forest Service NEPA regulations (36 CFR Part 220), and Forest Service 

policy in Forest Service Manual 1900, Chapter 1950, and Forest Service Handbook 1909.15.

Location and Area

The project area includes the entire 4.1 million acre Okanogan-Wenatchee National Forest (see 

Vicinity Map) within Okanogan, Chelan, Kittitas and Yakima Counties and a small portion of 

Skagit County (Okanogan-Wenatchee National Forest lands west of the Cascade crest are 

included in the project area including the area along Highway 20 west of the Cascade crest and 

east of Ross Lake that is administered by the Okanogan-Wenatchee National Forest and located in 

Skagit County). In addition, this project also includes acreage east of the Cascade crest within 

Yakima County that are administered by the Mount-Baker Snoqualmie National Forest.
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Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Background

Invasive plants are “non-native plants whose introduction does or is likely to cause economic or 

environmental harm or harm to human health” (Executive Order 13112). Invasive plants are 

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

ecosystems. Invasive plants include but are not limited to noxious weeds identified on state lists.

On the Okanogan-Wenatchee National Forest (OKAWEN or the Forest), about 50 species of 

invasive plants have been mapped within 5,528 sites, totaling approximately 16,281 infested 

acres. The project area includes the entire Okanogan-Wenatchee National Forest, totaling about 

4.1 million acres. Currently, we are treating invasive plants as approved in several different 

decision notices (see FEIS Chapter 2.2, no action, for a full listing). Across the OKAWEN as a 

whole, we lack a consistent treatment approach that uses up to date integrated methods and 

available tools.

Tribal Consultation and Public Involvement

Tribal and public scoping on this Proposed Action was initiated in summer, 2009. The Notice of 

Intent to prepare an EIS was published in the Federal Register on August 13, 2009. 

The scoping record (available on file) includes government-to-government consultation with 

American Indian tribes. Prior to the initiation of public scoping, government-to-government 

consultation letters were sent to the Yakama Nation and Confederated Tribes of the Colville 

Reservation on August 10, 2009. Neither government raised any concerns relating to the project

during scoping or the DEIS comment period.

During the 2009 scoping period, approximately 1,700 postpaid postcards were mailed out asking 

if the recipient wished to be included on the e-mail or hard copy mailing list for the project. 

Approximately 800 people responded and indicated an interest in the project. The Proposed 

Action was posted on the Forest website and a scoping letter, dated August 12, 2009, was sent to 

798 individuals and organizations who responded to the original postcard inquiry. We received 

17 comment letters about the proposed action. Scoping outreach and responses are in the Project 

Record. An alternative that minimized herbicide use was developed for detailed study as a result 

on some of the scoping input. 

The Okanogan Wenatchee invasive plant treatment DEIS was circulated for comment in April 

2016. We received 15 letters containing about 120 comments regarding the project and its 

impacts. The greatest number of comments expressed opposition to the use of herbicides, 

specifically glyphosate. However, several comments expressed support for the project. Appendix 

G contains the specific comments and our responses. 

In response to the comments, we prepared a newsletter addressing common questions and 

concerns and sent it to those who commented on the DEIS. We also met with some people from 

the Carlton community to hear their concerns. The Forest Service agreed to keep them informed 

about upcoming treatments and coordinate volunteer efforts in the Libby Creek watershed to help 

minimize herbicide use there. 

We made a few changes to the Final EIS in response to the comments. We added some 

information about monitoring; clarified the way the annual cap was developed and used in the 

analysis; and adjusted the prescription on 2.3 acres of knotweed to avoid use of glyphosate as a 

first choice herbicide. 
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Purpose and Need

The Okanogan-Wenatchee National Forest needs to expand treatment options and expand the 

treatment area to the entire National Forest to effectively suppress, contain, control and/or 

eradicate invasive plant species. The purpose of the project is to cost-effectively treat invasive 

plants, while minimizing risks from treatment. 

Current treatment projects are expiring and are not necessarily consistent with current 

management direction, and do not provide an adequate range of tools to effectively control 

invasive plants, while minimizing treatment risks. There is a need to amend the Forest Plans to 

allow use of a new herbicide that reduces risk and increases effectiveness of herbicide treatment. 

In addition, there is a need to provide for a Forest-wide system for the early detection and rapid 

response (EDRR) for finding and treating new invaders and new infestations. There is currently 

no Forest-wide mechanism to effectively address new infestations. 

Invasive plant treatment is intended to help meet the following Desired Future Condition (2005

R6 PNW ROD): 

In National Forest lands across Region Six, healthy native plant communities remain 

diverse and resilient and damaged ecosystems are being restored. High quality habitat is 

provided for native organisms throughout the region. Invasive plants do not jeopardize 

the ability of the National Forests to provide goods and services communities expect. 

The need for invasive plant treatment is reduced due to the effectiveness and habitual 

nature of preventive actions and the success of restoration efforts.

Currently, invasive plants on the Forest are displacing native plants, reducing forage and habitat 

for wildlife and livestock, threatening native plant communities; contributing to increased soil 

erosion and reduced water quality; altering the physical and biological properties of soil, affecting 

the intensity and frequency of fires, and degrading the quality of recreational experiences. 

Fifty different invasive plant species are known to occur within the boundaries of the OkanoganWenatchee National Forest. Existing infestations vary in size and extent across the Forest; some 

infestations occupy small areas of less than an acre while others involve hundreds of acres. 

Currently, 5,528 invasive plant sites have been mapped, covering 16,281 acres (or 0.4% of the 

total Forest acres). The target species of greatest concern include (in no particular order): 

Dalmatian toadflax, common crupina, yellow starthistle, whitetop, St. John’s wort, Japanese and 

Bohemian knotweed, hawkweeds, houndstongue, hoary alyssum and spotted and diffuse 

knapweed. A full listing of invasive plant species mapped on the Okanogan-Wenatchee National 

Forest can be found in Chapter 3.2, Invasive Plant Management and Treatment Effectiveness. 

Additional infestations have likely not yet been discovered, and these, as well as known sites, will 

continue to expand and spread every year without effective treatment. New infestations can be 

discovered at any time; new infestations are high priority for treatment. R6 PNW ROD Standard 

16 lists 10 herbicides approved for use on the Forest (see 1.7 below). Standard 16 also allows 

consideration of new herbicides as needed to meet program goals.

On the Forest, there is a need to consider use of aminopyralid to better meet R6 PNW ROD Goal 

3 to protect the health of people (and to).....identify, avoid, or mitigate potential human health 

effects from invasive plants and treatment, and Goal 4 to implement invasive plant treatment 

strategies that protect sensitive ecosystem components....while minimizing adverse effects from 
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treatment projects. An Herbicide Risk Assessment was prepared by an independent contractor 

“Syracuse Environmental Research Associates, Inc.” (SERA). The Risk Assessment for 

aminopyralid (SERA 2007) indicates that use of this herbicide would reduce risks associated with 

some of the other herbicides approved in the R6 PNW ROD.

Reasons for my Decision

Based on the analysis disclosed in the FEIS and project record, I have decided to select

Alternative 2, the proposed action, for the Okanogan-Wenatchee National Forest Forest-wide 

Site-specific Invasive Plant Management Project. This alternative is the most cost-effective 

approach to invasive plant treatment while minimizing the potential adverse effects of treatment 

according to the Okanogan and Wenatchee National Forest Plans as amended by the R6 2005 

ROD.

Under Alternative 2, invasive plant treatments will be completed according to integrated 

treatment prescriptions (see Attachment 1, table 1-1) and Project Design Features (PDFs, see 

Attachment 1, table 1-2). Treatments would be adapted to changing conditions over time 

following an Early Detection and Rapid Response (EDRR) and implementation planning process.

My decision includes monitoring to ensure that the treatments are implemented properly and 

adverse effects are minimized. See FEIS Chapter 2.2 for a detailed description of the Proposed 

Action/Selected Alternative.1

Alternative 2 would be the most effective in containing, controlling, or eradicating invasive 

plants. It would best meet the purpose and need for action because under Alternative 2, the 

treatment objectives of control and eradication would be possible. The availability of all treatment 

methods and herbicide choices would increase the ability to match treatments to the species and 

conditions at a site, and improve the ability to effectively control invasive plants (FEIS Chapter 

3.2.4).

Alternative 2 also has flexibility to take advantage of special projects or funding opportunities, 

and respond to changing conditions. For example, all sites in/near an area burned by a recent 

wildfire could be treated with the most effective method to prevent spread into any newly created 

high-risk (disturbed) habitat (ibid.). 

Alternative 2 will allow use most of the new herbicides programmatically approved by the R6 

PNW ROD, plus one additional herbicide with a completed risk assessment (aminopyralid). The 

herbicides vary in selectivity, residual soil activity, and their effectiveness in controlling broadleaved invasive plants at low concentrations. Each herbicide would be used where it would 

provide the most effective treatment (and is allowed by label or alternative design restrictions) 

with the least potential environmental effects, depending on the invasive species and 

environmental conditions present at the site. Using the most effective herbicide would reduce the 

number of repeat treatments needed, and minimize the total cost of treatment (ibid.). 

Multiple years of herbicide treatment, or herbicide treatment in combination with other methods, 

would likely be needed to accomplish a control or eradicate management objective. Given current 

budgets, Alternative 2 would take at least 6 years or longer to achieve treatment objectives. Only 

a portion of the existing infestations would likely be treated each year and treatment of new 

 1

This decision includes National Forest system acreage east of the Cascade crest within Yakima County 

that are administered by the Mount-Baker Snoqualmie National Forest. 
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infestations would often take priority. However, over the life of the project, the objectives for 

invasive plant treatment could be met. Given the 15-year (or longer) timeframe of this project 

and the high mobility of invasive plants, having maximum flexibility to make adjustments and 

adapt to changes adds to the effectiveness of Alternative 2 (ibid.). 

I recognize that some individual non-target plants may be killed or harmed during 

implementation of this project. An individual rare plant may be damaged or die. Effects on nonvascular plants and fungi are particularly uncertain. The potential exists for non-target plants to be 

inadvertently damaged or killed, especially adjacent to broadcast operations. However, the 

Project Design Features minimize the potential for native plants to be adversely affected (FEIS 

Chapter 3.3.4).

Alternative 2 allows for the greatest treatment effectiveness and includes the ability to use 

herbicides throughout all soil types. This alternative would provide the greatest potential benefit 

to long-term soil site productivity by restoring native vegetation to more acres and improving soil 

conditions. Herbicides would be used according to the PDFs. Risks from herbicide use are abated 

by the PDFs, and serious adverse effects to soils are not expected from treatments in either 

alternative. 

I acknowledge that soil restrictions have been identified on about 679 acres where certain 

herbicides might otherwise be used. These restrictions would apply to about 1,400 acres within 

treatment analysis areas where invasive species are not currently mapped but are likely to be 

found. However, effective treatments may still be completed in these areas. Effects of the 

proposed herbicide treatments on soils would not be measurable at the Forest scale due to the low 

percent of area impacted. Impacts are restricted to localized and short-term effects on soil 

microorganisms and soil productivity, which are addressed by PDFs and therefore unlikely to be 

serious or lingering (FEIS Chapter 3.4.4).

Some of the treatments may occur in riparian areas. The Project Design Features limit the 

potential for herbicides to enter water in the action alternatives. The 2013 Aquatic Restoration 

Biological Opinion (ARBO2) design features for invasive plant treatments that may affect critical 

riparian and aquatic habitats for species listed under the Endangered Species Act are incorporated 

in full in the project PDFs. These include design features to minimize drifting and leaching, and 

herbicide use buffers for perennial and intermittent water bodies. In addition to the ARBO2 

design features PDF H-6 restricts the amount of herbicide treatment allowed around a lake or 

pond within a 30 day period, PDF H-7 provides a timing restriction and treatment limitation near 

wetlands, and PDF H-8 limits herbicide use near domestic wells and spring developments. The 

PDFs and herbicide use buffers have a high degree of effectiveness and likely eliminate risk of 

the project having serious adverse effects on water resources or beneficial uses of water. 

Treatments under EDRR would be also completed in a manner that follows Water Quality BMPs 

and protects water resources. The Forest Plan amendment allowing for use of aminopyralid would 

help reduce use of glyphosate and picloram and thus minimize risks to fish and other beneficial 

uses. Alternative 2 includes the most flexibility in terms of herbicide use, including near streams 

and other water bodies. This alternative has the greatest potential treatment benefit, compared to 

the other alternatives. Beneficial uses of water are not expected to be adversely affected (FEIS 

Chapter 3.5.4). 

I recognize that Alternative 2 “May Impact” sensitive aquatic species, but would not affect the 

viability of any species or cause any sensitive species to be listed under the Endangered Species 

Act (FEIS Chapter 3.6.4). Alternative 2 would result in long-term restoration where natural plant 
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communities and disturbance regimes have been altered by invasive plants. Alternative 2 has the 

greatest potential to benefit aquatic resources by effectively treating invasive plants (ibid.). 

Project Design Features, which include all design features from ARBO2, would minimize the 

potential for adverse effects on fish and habitat. None of the chemicals proposed for use would 

result in long-term adverse alteration of aquatic habitat. The impacts of invasive plants on the 

environment can last decades, while the impacts of treatment tend to be short term (weeks or 

less). Active restoration at selected sites would accelerate native vegetative recovery in treated 

areas (ibid). Herbicide use buffers in the alternative would substantially limit the amount of 

herbicide potentially coming in contact with water. The potential amount of herbicide coming in 

contact with water after application of herbicide use buffers would be minimized to near nondetectable levels (ibid).

I acknowledge that wildlife may be exposed to herbicides, however the risk from this project to 

free-ranging wildlife is very low, because 1) the invasive plant sites are relatively small and 

scattered across many watersheds and habitat areas; 2) invasive plants are concentrated on roads 

and other disturbed areas that do not provide optimum wildlife habitat value; and 3) the intensity 

of change to habitat features of value to these species is low. The herbicides proposed for use are 

not likely to adverse effect or impact any wildlife species. In contrast, no treatment, or ineffective 

treatment of invasive plants could result in adverse effects to habitats if current infestations 

continue to spread into riparian areas, late-successional forests, meadows and other valuable 

habitat areas. (FEIS Chapter 3.7.4).

Treatments on grazing allotments would help maintain and restore forage on treated sites and 

adjacent lands. I acknowledge that my decision may result in short term effects to allotment 

management such as adjustments to pasture rotations.

I acknowledge that herbicide applicators and other people may be exposed to the herbicides used 

to treat invasive plants under Alternative 2. The nature of the project and the type of treatments 

proposed; the PDFs; the Forest Plan/R6 PNW standards; and the Forest Service pesticide use 

policy together minimize potential for worker and public exposure. 

Triclopyr poses a greater level of risk than the other herbicides proposed, given comparative risk 

assessments, if people were to consume sprayed vegetation. The R6 PNW ROD limited triclopyr 

to selective/spot treatment (no broadcasting with triclopyr). This herbicide ingredient is necessary 

for effective treatment of some woody plants. 

In both action alternatives, triclopyr is the first choice herbicide for about 90 acres of scotch 

broom, scattered across 30 sites. Treatment of scotch broom using triclopyr would pose a low 

level of risk to the public. There is little chance that the public would eat sprayed scotch broom. 

Public notification of planned treatments, including extra posting of notices at recreation and 

other developed sites, would allow the public to completely avoid areas treated with triclopyr 

(posting would occur for all herbicides as per PDF K-1). 

The addition of aminopyralid would likely be a positive factor relative to human health. 

Aminopyralid is not associated with any worker or public exposures over the threshold of concern 

(for aminopyralid, all calculated Hazard Quotient (HQ) values, even for upper estimates and 

maximum rates, are below 1). 

With the exception of consuming vegetation sprayed with triclopyr, there are no plausible acute or 

chronic exposure scenarios where people might be exposed to harmful levels of herbicide from 
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this project, where via direct contact; swimming in contaminated water; or consuming 

contaminated water, fish, fruit or vegetation (FEIS Chapter 3.8.4). 

Some comments to the Draft EIS expressed concern about the herbicide glyphosate. Many people 

express concerns about glyphosate use on food crops around the world. My decision will not 

affect this use, which is outside the scope of this project. 

The use of glyphosate on this project would be limited. We can avoid use of glyphosate in most 

situations, but it is a necessary ingredient in our toolbox. I have instructed my staff to avoid use of 

glyphosate, remove it as a first choice for current infestations, and to use it sparingly if other 

herbicides are ineffective. Glyphosate may increase the effectiveness of a tank mix partner such 

as imazapyr; I authorize this use if needed in specific situations (for the 2.3 acres of knotweed, we 

will try imazapyr first, however we may follow up with glyphosate or a tank mix). 

Eradication of invasive plants would allow vegetation within wilderness areas to evolve in a more 

natural way, which would promote the untrammeled character of wilderness. I understand that the 

use of herbicides in wilderness areas may reduce the wilderness experience for some users in the 

short term, but active treatment provides the best protection of wilderness character and values

(FEIS Chapter 3.10.4). Adverse effects to outstandingly remarkable values on Wild and Scenic 

Rivers would be minimal given the PDFs and herbicide use buffers. In the long run, treatment of 

invasive plant and restoration of treated areas would enhance wilderness and Wild and Scenic 

River values. Alternative 2 would be more favorable to wilderness and Wild and Scenic River 

values because of the increased effectiveness and selectivity associated with use of aminopyralid.

Invasive plant treatments are unlikely to adversely affect heritage sites (FEIS Chapter 3.11.4).

Alternative 2 would treat all existing acres of invasive plants using the widest range of methods 

and herbicide ingredients. Under an unlimited budget, assuming an average annual cost of $100 

per treatment acre and an average annual effectiveness of 80 percent per year, total cost of fully 

meeting all treatment objectives over a five year period is estimated at $2,055,500. This amounts 

to a total cost per effectively treated/restored acre over a five year period of about $126 per acre

Alternative 2 could provide up to 39 seasonal jobs for any given 130 day year, assuming an 

unlimited budget. 

Alternative 2 would not likely be acceptable to those who disagree with herbicide use. 

Glyphosate would be used in Alternative 2, but would not be the first choice herbicide for any 

known infestation. Alternative 2 is my selected alternative given the low likelihood of serious 

adverse effects. Alternative 2 has the greatest potential for positive benefits from treatment. 

Compliance with Policies and Management 

Direction Related to Invasive Plant Management

Forest Service policies and management direction related to invasive plant treatment clearly 

supports taking action to contain or reduce density of invasive plants on National Forests. 

Prevention, early detection and rapid response, invasive plant control measures, restoration and 

organizational collaboration are all addressed in the Forest Service 2900 Manual. 

The R6 PNW ROD also provides management direction for this project. The R6 PNW ROD lays 

out several objectives for invasive plant management including: 
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Objective 1.3: Detect new infestations of invasive plants promptly by creating and 

maintaining complete, up-to-date inventories of infested areas, and proactively 

identifying and inspecting susceptible areas not infested with invasive plants.

Objective 1.4: Use an integrated approach to treating areas infested with invasive plants. 

Utilize a combination of available tools including manual, cultural, mechanical, 

herbicides, biological control.

Objective 1.5: Control new invasive plant infestations promptly, suppress or contain 

expansion of infestations where control is not practical, conduct follow up inspection of 

treated sites to prevent reestablishment.

Objective 3.1: Avoid or minimize public exposure to herbicides, fertilizer, and smoke.

Objective 3.2: Reduce reliance on herbicide use over time in Region Six

Objective 4.1: Maintain water quality while implementing invasive plant treatments.

Objective 4.2: Protect non-target plants and animals from negative effects of both 

invasive plants and applied herbicides. Where herbicide treatment of invasive plants is 

necessary within the riparian zone, select treatment methods and chemicals so that 

herbicide application is consistent with riparian management direction.

Objective 4.3 - Protect threatened, endangered, and sensitive species habitat threatened by 

invasive plants. Design treatment projects to protect threatened, endangered, and sensitive 

species and maintain species viability.

Recently, the Forest Service published a National Strategic Framework for Invasive Species 

Management (FS-1017, August 2013). The framework is intended to increase the effectiveness of 

Forest Service invasive species management and improve the health and productivity of forests 

and grasslands. The framework acknowledges that invasive species are among the most important 

environmental and economic threats facing public lands. The framework notes that estimated 

economic damage from invasive species has totaled more than $1.4 trillion worldwide, about 5 

percent of the world’s economy. Early detection and rapid response to new detections, effective 

control of invasive species, and restoration of treated sites are important objectives of the 

framework.

I find that the design of Alternative 2 will help us meet these objectives. The objective of 

reducing herbicide use over time is best met by implementing effective, integrated treatments that 

may include chemical use, as has been proposed in Alternative 2. Alternative 2 is by definition 

the most cost-effective alternative because it allows for the widest range of treatment tools. 

Other Alternatives Considered

In addition to the selected alternative, we analyzed two other alternatives: no action (Alternative 

1) and one action alternative (Alternative 3). Table 1 summarizes the activities included in each 

alternative analyzed in detail compared to the selected alternative. 
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Table 1. Activities Included in Alternatives

Element/Indicator 

(where to find more 

information on this 

topic)

Alternative 2

(Selected Alternative)

Alternative 1 

(No Action)

Alternative 3

Invasive Plant 

Treatment Methods

All treatment methods 

would be included: manual, 

mechanical, biological, 

cultural, chemical. 

Herbicide use would be 

allowed in most situations 

as part of an integrated 

prescription on 15,602 

acres. Currently, about 679 

acres would likely be 

treated using non-herbicide 

methods; otherwise, 

herbicide may be used in 

combination with other 

treatment methods. 

No new actions; Forest 

would complete current 

projects including about 

6,000 acres of integrated 

projects. All treatment 

methods are included: 

manual, mechanical, 

biological, cultural, 

chemical. Limited suite of 

herbicides are currently 

approved.

All treatment methods. About 

4,946 acres would include 

herbicide use. 10,785 acres 

of current infestations would 

not meet include herbicide 

use; these areas would be 

treated using non-herbicide 

methods. 

Annual Treatment 

Cap

16,281 acres None 16,281 acres

Early Detection 

Rapid Response

Yes, future infestations 

treated according to PDFs

No Yes, future infestations 

treated according to PDFs, 

herbicide use restricted to 

criteria; 

Forest Plan 

Amendment to Add

Aminopyralid to List 

of Approved 

Herbicide 

Ingredients

Yes No Yes

Alternative 1 – No Action

Invasive plant treatments are currently occurring from several Forest-wide and individual 

invasive plant treatment NEPA decisions. Under the No-Action Alternative, some invasive plant 

treatments would continue to occur under existing documents. The Forest-wide treatment 

projects would be phased out and within a couple years, existing individual projects and 

connected actions would be completed. Invasive plant treatments would not otherwise be 

conducted except as authorized under future NEPA decisions. 

On the Okanogan National Forest, invasive plant treatment has occurred via three Forest-wide 

decisions (1997, 1999 and 2000) approving use of picloram and glyphosate on specific sites. On 

the Wenatchee National Forest, invasive plant treatment has occurred via one Forest-wide 

decision approving dicamba, picloram, triclopyr, glyphosate on specific sites. The use of dicamba 

was discontinued when the R6 PNW ROD was signed in 2005.

Why Alternative 1 was not selected

I did not select Alternative 1 because our ability to meet objectives to eradicate, control or contain 

invasive plants would be severely limited on the majority of sites due to the limitations in the 

existing NEPA documents and the lack of adequate coverage of known sites (FEIS Chapter 3.2.4). 

Threats to native vegetation would have been greatest in this alternative. Those native plant 

communities most vulnerable to invasive plants (dry forest and shrub steppe) and those near very 
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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aggressive invasive plants (such as whitetop) would be most adversely affected through direct 

competition for water and resources, changes in microhabitat, and direct suppression and 

mortality (FEIS Chapter 3.3.4). The No Action alternative could result in a substantial loss of 

habitat over time for several wildlife species (FEIS Chapter 3.7.4.). As habitats become more and 

more dominated by invasive plants, they would not be used, or used less, by native and rare 

wildlife species. 

Under Alternative 1 many high priority riparian sites would continue to be occupied by invasive 

plants, degrading the riparian condition. No EDRR would be authorized, jeopardizing timely and 

effective treatment on new sites, potentially in riparian areas (FEIS Chapter 3.5.4). Lack of 

response to current and expanding invasive plant populations would lead to increasing risk from 

invasive plants to important aquatic habitats (FEIS Chapter 3.6.4).

Alternative 1 would allow about 6,000 acres to be treated as authorized under current NEPA. The 

majority of infested acres of invasive plants would not be treated and would likely continue to 

spread. Many of the acres treated under existing decisions are within grazing allotments and as 

invasive species continue to spread via common dispersal methods, rangeland resources could 

become more degraded (FEIS Chapter 3.6.4).

Many of the known invasive plant populations are located in areas where recreation is 

concentrated and the ground is disturbed. If invasive plants spread throughout these heavily used 

recreational areas, they would replace native plants with invasive species. Thus, many areas 

would not meet the Visual Quality Objectives set in the Forest Plans (FEIS Chapter 3.10.4). 

Because of the current infestations of invasive species along roads and at wilderness trailheads, it 

is likely that new populations and species would be introduced in to wilderness, similarly 

degrading wilderness character, scenery and recreational experience. 

After 5 years of treatment under Alternative 1 about 12,960 acres are predicted to remain (FEIS 

Chapter 3.12.4). The Forest Service would not meet objectives and policies regarding invasive 

plant management (ibid.).

I acknowledge that Alternative 1 involves the least potential extent of herbicide use since no 

additional treatments would occur. However, the risks associated with herbicide use remain low 

in the action alternatives. And, herbicides with lower potential for environmental effects than 

those allowed under Alternative 1 are available under the action alternatives.

Alternative 3 – Reduced Herbicide Use 

Alternative 3 is described in detail in Chapter 2.2.2 of the FEIS. Alternative 3 was developed to 

evaluate the tradeoffs involved with restricting the use of herbicides based on invasive plant 

biology, availability of biocontrols, and infestation size.

All of the PDFs, herbicide use rates, and herbicide-use buffers associated with Alternative 2

would have been applied.

Why Alternative 3 was not selected

Alternative 3 would increase treatment options on a portion of the current inventory, but herbicide 

would not be used for the majority of current infestations. This would increase the relative cost 

of treatment and allow for fewer acres to be treated assuming a constant budget. While 

Alternative 3 allows for EDRR, the restrictions in herbicide use would increase cost of treatment 

and reduce potential EDRR effectiveness. Given current budgets, Alternative 3 could take 20 
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

13

years or longer to achieve treatment objectives. Without additional funding, the objectives for 

invasive plant treatment would not have been met over the life of the project (FEIS Chapter 

3.2.4). If sufficient funding is not available, Alternative 3 would be more similar to No Action 

than Alternative 2, with the majority of infested acres untreated. 

If treatments are not effective, habitat occupied by invasive plants would continue to reduce the 

amount of habitat available to natives, and invasive plants growing next to native plants would be 

directly competing for resources. If less effective treatments would be used because herbicides 

are not allowed, a reduction of habitat, direct competition for resources leading to reduction in 

health, vigor and reproduction, changes in habitat (shading reduction, soil temperature increase, 

reduced moisture availability, allelopathy) and possible mortality to botanical species of concern 

could occur (FEIS Chapter 3.3.4). Ineffective treatment could mean that the adverse effects of 

invasive plants would continue over most infested riparian areas. Many high priority riparian sites 

would continue to be occupied by invasive plants, degrading the riparian condition (Chapter 

3.5.4). This could eventually degrade fish habitat (Chapter 3.6.4).

I am not selecting Alternative 3 because it would have been more costly and less effective, and 

would not meaningfully reduce risk to people and the environment from herbicides. Alternative 3 

would deviate from integrated weed management concepts by eliminating some necessary tools 

for effective treatment. I acknowledge that compared to Alternative 2, less acres would be subject 

to herbicide application. However, over time, I believe the higher treatment costs associated with 

Alterantive 3 will result in more acres going untreated, which could lead to increased invasive 

plant spread and greater treatment needs, including herbicide, in the future. I believe that treating 

with the most effective method that minimizes risk of adverse effect (Alternative 2) is the most 

prudent course of action. 

The following table compares the alternatives in terms of response to the public issues identified 

from scoping and shows where in the EIS more information on this topic is available.

Table 1.1: Alternative Comparison Table

Issue 

ID

Element/

Indicator 

(where in EIS to 

find more 

information on 

this topic)

Alternative 1 

(No Action)

Alternative 2

(Proposed Action)

Alternative 3

1A Exposure 

scenarios that 

result in hazard 

quotient values 

greater than 1 

for worker and 

public health

(Chapter 3.9.4)

None, limited use of triclopyr HQ > 1 for public based on 

consumption of vegetation 

contaminated with triclopyr. This is 

very unlikely to occur, triclopyr is 

the first choice herbicide for about 

90 acres of scotch broom, 

scattered across 30 sites. People 

are unlikely to consume 

contaminated scotch broom. 

Same as 

Alternative 2

1A Measures to 

reduce public 

and worker 

exposure to 

herbicides 

(Chapter 2.2.2)

Existing herbicide use follows 

applicable laws, policies and 

plans; limited herbicide use, 

older chemistry

Limited herbicide use rates; 

herbicide use buffers near streams, 

wells and springs; and public 

notification. Use of aminopyralid 

poses very low risk, comparable or 

less relative risk to human health 

when compared to herbicides used 

under No Action

Same as 

Alternative 2, 

less use of 

herbicides 

overall (about 

one-third of 

infestations 

meet criteria). 
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Issue 

ID

Element/

Indicator 

(where in EIS to 

find more 

information on 

this topic)

Alternative 1 

(No Action)

Alternative 2

(Proposed Action)

Alternative 3

1A Human Health 

Risk Ranking 

(Chapter 3.9.4)

Very Low Risk – low acreage 

treated using herbicides and 

no additional herbicide use

Low Risk – risk abated by project 

design, adherence to policy, Forest 

Plan standards 

Very Low Risk –

low acreage 

treated using 

herbicides and 

risk would be 

further abated 

by project 

design, 

adherence to 

policy, Forest 

Plan standards. 

1B Extent of 

herbicide use 

associated with 

hazard quotient 

values greater 

than 1 for 

Wildlife

(Chapter 3.7.4) 

(Table 2.3)

. 

HQ > 1 for plausible exposure 

scenarios for birds and 

mammals exposed to triclopyr 

and glyphosate. Limited use 

of herbicides on small, 

scattered sites over 6,000 

acres. 

HQ > 1 for plausible exposure 

scenarios for birds and mammals 

exposed to triclopyr and 

glyphosate. Triclopyr is the first 

choice herbicide for about 90 acres 

of scotch broom, scattered across 

30 sites. This small amount of 

selective treatment (no broadcast) 

is unlikely to result in adverse 

wildlife exposure. Glyphosate is not 

the first choice for any acres, and 

any future use is unlikely to result 

in adverse wildlife exposure. 

Same as 

Alternative 2, 

criteria to 

reduce potential 

herbicide use by 

only using 

herbicide on 

larger 

infestations and 

specific target 

species.

1B Measures to 

reduce wildlife 

exposure to 

herbicides 

(Chapter 2.2.2)

Existing herbicide use follows 

applicable laws, policies and 

plans; limited herbicide use, 

older chemistry

Project design features for riparian 

protection (ARBO II); limited 

herbicide use rates; managing 

chemical persistence in the soil; 

maintaining refugia in lake and 

wetland habitats; herbicide use 

buffers near streams, wells and 

springs; protection of non-target 

plants; minimizing disturbance to 

wildlife

Same as 

Alternative 2, 

criteria to 

reduce potential 

herbicide use by 

only using 

herbicide on 

larger 

infestations and 

specific target 

species.

1B Wildlife Risk 

Ranking 

(Chapter 3.7.4)

Very Low Risk, Lowest 

Benefit (low acreage treated, 

highest potential for spread)

Low Risk, Greatest Benefit (PDFs 

protect wildlife, most cost-effective 

treatment)

Low Risk, 

Moderate to 

Low Benefit 

(PDFs protect 

wildlife, less 

cost-effective 

treatment)

1B Effects on 

special status 

species 

(Chapter 3.7.5)

No new effects, no new 

consultation

This project may affect (but is not 

likely to adversely affect) the 

following federally listed species: 

wolf, lynx, bear, owl and murrelet. 

This project may impact (but not 

jeopardize viability of) several 

special status invertebrate species. 

Same as 

Alternative 2
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Issue 

ID

Element/

Indicator 

(where in EIS to 

find more 

information on 

this topic)

Alternative 1 

(No Action)

Alternative 2

(Proposed Action)

Alternative 3

1C Measures to 

reduce risk to 

non-target 

plants (Chapter 

2.2.2)

All existing projects include 

measures to protect nontarget plant species. 

Project Design Features I-2 and I-3 

protect non-target plants, 

particularly species of botanical 

concern. 

Same as 

Alternative 2

1C Botanical 

Resource Risk 

Ranking 

(Chapter 3.2.4)

(Chapter 3.3.4)

Risk to native plants and 

plant communities greater 

from invasive plants than 

treatment, thus no action with 

least effective treatment 

poses greatest risk to 

botanical resources.

Greatest potential benefit to native 

plants and plant communities via 

effective treatment of invasive 

plants. Low risk of harm from 

treatment methods. 

Moderate 

potential benefit 

to native plants 

and plant 

communities 

where 

treatments are 

effective; 

however less 

than Alternative 

2 because it is 

less likely to be 

cost-effective 

and fewer acres 

would be 

treated 

assuming a 

limited budget. 

1D Measures to 

prevent 

herbicides from 

building up in 

soil 

(Chapter 2.2.2) 

No issues with herbicide build 

up in soil observed as a result 

of implementing existing 

treatments.

PDF’s provide guidance on 

treatment frequency to reduce 

potential for herbicide to build up in 

soil. 

Same as 

Alternative 2, 

less herbicide 

use overall

1D Relative risk to 

soils biology

(Chapter 3.5.4)

No impact to soil biology 

observed as a result of 

implementing existing 

treatments.

Low risk to soil biology due to 

methods and herbicide ingredients 

approved and PDFs; likely no 

impact. 

Same as 

Alternative 2

1D, E Measures to 

prevent 

herbicide from 

entering water 

and affecting 

beneficial uses 

and aquatic 

organisms

(Chapter 2.2.2)

Herbicide use buffers are 

associated with treatment of 

existing infestations

Alternative incorporates herbicide 

use buffers and other design 

features associated with ARBO II, 

limiting broadcast and use of 

herbicides posing higher risk to the 

riparian/aquatic environment near 

streams. In addition, PDFs protect 

wetlands, lakes, ponds springs and 

wells. 

Same as 

Alternative 2, 

less herbicide 

use in riparian 

and other areas

1D Relative risk to 

beneficial uses 

of water 

(Chapter 3.6.4)

Current treatments have not 

resulted in adverse effects to 

beneficial uses.

Low to no risk to beneficial uses; 

drinking water, aesthetic value and 

fisheries protected

Same as 

Alternative 2, 

less herbicide 

use in riparian 

and other areas
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Issue 

ID

Element/

Indicator 

(where in EIS to 

find more 

information on 

this topic)

Alternative 1 

(No Action)

Alternative 2

(Proposed Action)

Alternative 3

1E Relative Risk to 

Fish

(Chapter 3.7.4)

Glyphosate, picloram and 

triclopyr are all associated 

with greater risk to fish. 

These herbicides are 

approved in current NEPA 

documents. Current 

treatments have not resulted 

in adverse effects to fish or 

the aquatic environment. 

Completing current projects is 

unlikely to adversely affect 

the aquatic environment. 

Low to no risk to the aquatic 

environment. Following ARBO II 

terms and conditions would 

minimize risk of adverse effects to 

fish. Glyphosate, picloram and 

triclopyr are all associated with 

greater risk to fish. These would 

be used less frequently compared 

to other herbicides. Invasive plant 

treatments within the range of 

federally listed fish species fall 

under a class of actions that may 

affect and are likely to adversely 

affect the listed species (LAA). The 

ARBO II covers expected take and 

all activities in this project would be 

conducted consistent with ARBO II 

terms and conditions. Effects to 

critical habitat of listed fish species 

is expected to be negligible.

Same as 

Alternative 2, 

less herbicide 

use in riparian 

and other areas

2A Known Acres 

that may not be 

effectively 

treated given 

limitations on 

herbicide use or 

NEPA coverage 

(Chapter 3.2.4)

16,281 679 10,785 

2A Known Acres 

where All Tools 

are Available

6,000 15,602 4,946

2A, B Acres 

Remaining after 

Five Years with 

Unlimited 

Funding 

(Chapter 3.2.4)

(Chapter 

3.12.4)

12,960 27 337

Please note that 

this alternative 

costs over 3 

times as much 

as Alternative 2.

Assuming 

current funding 

levels, this 

alternative 

would take 20 

years to 

accomplish.
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

17

Issue 

ID

Element/

Indicator 

(where in EIS to 

find more 

information on 

this topic)

Alternative 1 

(No Action)

Alternative 2

(Proposed Action)

Alternative 3

2A, B Years to Meet 

Treatment 

Objectives 

(Known Sites) 

Assuming 

Current 

Funding 

(Chapter 3.2.4) 

(Chapter 

3.12.4)

Treatment objectives would 

not be met on the majority of 

known sites.

Given current budgets, the 

Proposed Action would take at 

least 6 years or longer to achieve 

all goals. The initial years of 

implementation, only a portion of 

the existing infestations would likely 

be treated, especially if treatment 

of new infestations takes priority. 

However, over the life of the 

project, the objectives for invasive 

plant treatment could be met.

Given current 

budgets, 

Alternative 3 

could take 20 

years or longer 

to achieve 

treatment 

objectives. 

Without 

additional 

funding, the 

objectives for 

invasive plant 

treatment would 

not likely be met 

over the life of 

the project. The 

project 

effectiveness 

would be 

commensurate 

with no action if 

treatments are 

not affordable.

2B Estimated cost 

of fully treating 

existing 

infestations 

assuming 

unlimited 

funding

(Chapter 3.2.4)

(Chapter 

3.12.4)

$1,199,900 for 6,000 acres 

covered under current NEPA. 

10,281acres would be left 

untreated.

$2,055,500 for all 16,281 acres $7,115,400 for 

all 16,281 acres

2B Estimated 

Average Cost 

Per Fully 

Treated Acre 

(includes retreatment)

(Chapter 3.2.4)

(Chapter 

3.12.4)

$200 $126 $437

3 Number of 

seasonal jobs 

to treat all acres 

in a single year 

(unlimited 

funding)

(3.12.4)

14 39 86
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Issue 

ID

Element/

Indicator 

(where in EIS to 

find more 

information on 

this topic)

Alternative 1 

(No Action)

Alternative 2

(Proposed Action)

Alternative 3

4 Ranking of 

alternatives 

relative to 

scenic value

(3.11.4)

Short term, least browning of 

target plants visible along 

roads and in special areas. 

Long term, most risk of 

degradation of scenic quality 

from spread of invasives. 

Short term, most likely to result in 

browned target plants visible along 

roads and in special areas. Long 

term, best chance of restoration of 

native vegetation and maintenance 

of scenic quality. 

Similar to 

Alternative 1 

under a limited 

budget, Similar 

to Alternative 2 

under an 

unlimited 

budget.

Findings Required by Laws and Regulations

This decision to implement the Okanogan-Wenatchee National Forest Forest-wide Site-specific 

Invasive Plant Management Project is consistent with the intent of the forest plans' long term 

goals and objectives listed in the Wenatchee Forest Plan and the Okanogan Forest Plan, and in 

amendments to the Forest Plans since 1990: 

• Final Supplemental Environmental Impact Statement on Management of Habitat for Late 

Successional and Old-growth Forest Related Species Within the Range of the Northern 

Spotted Owl, as adopted and modified by the April 1994 Record of Decision, which 

provides additional standards and guidelines (USDA FS, USDI BLM 1994), and 

commonly known as the ROD, or the Northwest Forest Plan (NWFP).

• Record of Decision for the Pacific Northwest Region Invasive Plant Program: Preventing 

and Managing Invasive Plants (R6 2005 ROD).

National Forest Management Act

A Forest Plan amendment would be implemented with this decision. The 2012 Planning Rule (36 

CFR Part 219) allows plan amendments to be made using the procedures from the 1982 planning 

regulations during the 3-year transition period (36 CFR § 219.14 (b)(2)). Under the 1982 

planning regulations, four factors are to be used when determining whether a proposed change to 

a Forest Plan is a significant amendment. The four factors are:

1. Actions that do not significantly alter the multiple-use goals and objectives for long-term land 

and resource management.

2. Adjustments of management area boundaries or management prescriptions resulting from 

further on-site analysis when the adjustments do not cause significant changes in the 

multiple-use goals and objectives for long-term land and resource management.

3. Minor changes in standards and guidelines.

4. Opportunities for additional projects or activities that will contribute to achievement of the 

management prescription.
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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This Forest Plan amendment enhances the agency’s ability to address invasive species

management objectives but does not alter multiple-use goals and objectives on the OKAWEN 

National Forest to any extent. This Forest Plan amendment does not change any Forest Plan 

management area boundaries or management prescriptions on the OKAWEN National Forest. 

The Forest Plan amendment authorizes the use of a registered herbicide, aminopyralid. This 

herbicide is not currently listed among the ten herbicides approved by the Regional Forester in 

2005 (R6 2005 ROD). The Risk Assessment for aminopyralid (SERA 2007) was completed 

subsequently and demonstrates that use of this herbicide will not pose new or significant risks 

compared to the ten already approved. Aminopyralid is generally a lower risk herbicide and the 

proposed use will not pose additional risks to human health or the environment. This Forest Plan 

amendment allows more effective and efficient treatment of invasive plants by adding 

aminopyralid to the list of approved herbicides on the OKAWEN National Forest. Aminopyralid 

is an herbicide that is very effective for many of the invasive plant species found within the 

OKAWEN National Forest. It was developed specifically for wildland use and is effective at low 

rates. Authorizing the use of aminopyralid will not foreclose on opportunities for additional 

projects or activities that will contribute to achievement of the management prescription. It will 

make those projects more effective in controlling invasive plants.

Endangered Species Act of 1973

My decision is consistent with the Endangered Species Act of 1973, as amended (16 U.S.C. 1531-

1544, 87 Stat. 884). Consultation has been completed with the NMFS and is nearing completion 

with USFWS.

Plants

The Botanist found that the proposed action “May Affect but is Not Likely to Adversely Affect” 

Hackelia venusta, Sidalcea oregana ssp. oregana var. calva, and Spiranthes diluvialis. The 

botanist found “No Adverse Effects” to critical habitat for Sidalcea oregana ssp. oregana var. 

calva and “No Effect” to Howelia aquatilis. The proposed action is “Not Likely to Jeopardize the 

continued existence” of Pinus albicaulis.

Fish

Consultation with the US Fish and Wildlife Service and National Marine Fisheries is under the 

2013 Aquatic Restoration Biological Opinion (ARBO2 II). Invasive plant treatments within the

range of federally listed fish species fall under a class of actions that may affect and are likely to 

adversely affect the listed species (LAA). ARBO II notes that the best available indicators for the 

extent of take due to the proposed invasive plant control is the extent of treated areas, i.e., less 

than, or equal to, 10% of the acres with a Riparian Reserve or RHCA within a 6th-field HUC/year 

(pg 172). ARBO II findings about take assume we will follow the design features and monitoring 

protocols described in the FEIS.

Wildlife

In consideration of the direct, indirect, and cumulative effects, the proposed activities, the wildlife 

biologist found that the project “May Affect, but are not Likely to Adversely Affect “ the 

northern spotted owl, Canada lynx, marbled murrelet, grizzly bear, and gray wolf. The project 

has a low likelihood of herbicide exposure to wildlife and low level of disturbance from human 

activities. The wildlife biologist found “No Effect” to designated critical habitat for the northern 

spotted owl and Canada lynx. There will be no jeopardy to the North American wolverine.
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Wilderness Act of 1964

My decision is consistent with the Wilderness Act of 1964 (16 U.S.C. 1131-1136; 78 Stat. 890).

Roadless Area Conservation Rule

My decision is consistent with the Forest Service’s Roadless Area Conservation Rule (36 CFR 

Part 294, Subpart B, 66 FR 9, pp. 3244-3273, 1/12/2001). By utilizing the appropriate project 

design feature and treatment methods, it is anticipated invasive species infestations in inventoried 

roadless areas will be eliminated, reduced, and the rate of spread retarded. 

Wild and Scenic Rivers Act

My decision is consistent with the Wild and Scenic Rivers Act (16 USC 1271-1287; 82 Stat. 906).

National Historic Preservation Act of 1966

My decision is consistent with the National Historic Preservation Act of 1966 (16 U.S.C. 470 et 

seq.; 80 Stat. 915) because it will have no potential to affect historic resources. 

Migratory Bird Treaty Act of 1918 and Executive Order 

13186

My decision is consistent with the Migratory Bird Treaty Act (16 U.S.C. 703-712; Ch. 128; 40 

Stat. 755) and Executive Order 13186. There will be no reduction in native vegetation, and all 

alternatives will help to reduce invasive plants and maintain migratory bird habitat.

Irreversible or Irretrievable Impacts

No irreversible or irretrievable uses of resources are associated with this project. This project 

restores native vegetation in areas where non-native plants have been introduced. Herbicide 

treatments in accordance with the alternatives will have relatively short-lived impacts; effects on 

non-target species will be minimized; such effects will not be permanent. No adverse impacts on 

roadless areas or degradation of roadless area quality will occur. 

Long-term Productivity 

Soils will be protected in this project and no loss of long-term productivity is predicted. The noaction alternative could have negative impacts on long-term productivity if invasive plants 

become dense enough to change soil characteristics, and capacity for restoration to desirable plant 

communities is lost. 

The natural resources issues associated with this project have been resolved through adherence to 

project design feature (PDFs) that reduce or eliminate the potential for adverse effects. However, 

some adverse effects are inherent to invasive plant treatments and cannot be avoided. These 

include:

• Taxpayers will likely be responsible for the costs of some if not all of the treatments.

• Herbicide toxicity exceeding thresholds of concern are unlikely, but possible in the event of a 

large herbicide spill. The PDFsmake the potential for a large spill extremely unlikely.

• Minor to moderate physical injuries during forestry work are possible.
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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• There may be temporary local effects on some groups of soil micro-organisms that are 

sensitive to certain herbicides. However, the PDFs address the potential for long-term impact 

to soil organisms or productivity. 

• Some common non-target plants are likely to be killed by their close proximity to treatments. 

This is most likely with broadcast herbicide treatments and less likely (but possible) for all 

other treatment methods. The adverse effects of the invasive plants themselves far outweigh 

the potential for adverse effects of treatment.

Energy Requirements and Conservation Potential

No unusual energy requirements are associated with this project. No unusual equipment will be 

used.

Prime Farmlands

No prime farmlands will be adversely affected by this project. There could be a beneficial impact 

to the extent that the alternatives reduce the potential for invasive plant spread from the Mt. 

Baker-Snoqualmie National Forest to prime farmlands.

Executive Orders 11988 and 11990: Floodplains and 

Wetlands

Floodplains and wetlands will not be adversely affected by this project. As discussed in Chapter

3.4 of the FEIS, adverse effects to water quality and the beneficial uses of water will be 

negligible. The extent of treatment and potential for water contamination is low, and all 

alternatives are designed to protect water resources on the Mt. Baker-Snoqualmie National Forest. 

Executive Order 13112: Invasive Species

This project specifically addresses the duties of federal agencies to manage invasive plants. 

Specifically:

Sec. 2 (a)(2) (i) prevent the introduction of invasive species; (ii) detect and respond 

rapidly to and control populations of such species in a cost-effective and 

environmentally sound manner; (iii) monitor invasive species populations 

accurately and reliably; (iv) provide for restoration of native species and habitat 

conditions in ecosystems that have been invaded; (v) conduct research on invasive 

species and develop technologies to prevent introduction and provide for 

environmentally sound control of invasive species; and (vi) promote public 

education on invasive species and the means to address them; and (3) not authorize, 

fund, or carry out actions that it believes are likely to cause or promote the 

introduction or spread of invasive species in the United States or elsewhere unless, 

pursuant to guidelines that it has prescribed, the agency has determined and made 

public its determination that the benefits of such actions clearly outweigh the 

potential harm caused by invasive species; and that all feasible and prudent 

measures to minimize risk of harm will be taken in conjunction with the actions.

Executive Order 12898: Environmental Justice

Executive Order #12898, Federal Actions to Address Environmental Justice in Minority 

Populations and Low Income Populations, directs federal agencies to address effects accruing in a 
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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disproportionate way to minority and low income populations. FEIS, Chapter 3.2.3 discusses the 

potential impacts of this project on these groups. The R6 2005 FEIS noted that some minority 

groups may be disproportionately exposed to herbicides, either because they are 

disproportionately represented in the pool of likely forest workers, or in the pool of special forest 

product or subsistence gatherers. The R6 2005 FEIS suggested that Hispanic/Latino forest 

workers and American Indians are minority groups that could be disproportionately affected by 

herbicide use. On the Mt. Baker-Snoqualmie National Forest, Asian matsutake mushroom pickers 

and others who collect or use special forest products may also be disproportionately affected. 

The potential exposures and effects to minority groups who apply herbicides or gather or use 

forest products are the same as those evaluated above under the worker and public herbicide 

exposure analysis sections of the FEIS (Chapter 3.2). Even given plausible inadvertent acute or 

chronic exposures, minority forest workers, special forest product harvesters, and subsistence 

gatherers are not likely to be exposed to a dose that exceeds a threshold of concern. MR/MM

requiring public and tribal notification, use of dye in spray mixes, on-the-ground signing, and 

restrictions on herbicide and surfactant use will further reduce the potential for exposure.

Executive Order 13443: Facilitation of Hunting Heritage and 

Wildlife Conservation

This order was signed on August 16, 2007 and directs Federal agencies that have programs and 

activities that have a measurable effect on public land management, outdoor recreation, and 

wildlife management, including the Department of the Interior and the Department of Agriculture, 

to facilitate the expansion and enhancement of hunting opportunities and the management of 

game species and their habitat. The project is consistent with this order by improving wildlife 

habitat through the reduction of invasive plant infestations and the maintenance of native 2rowse.

Environmentally Preferred Alternative

Alternative 2 is the environmentally preferred alternative in accordance with Council on 

Environmental Quality (CEQ) regulations (40 CFR Part 1505.2 (b)). Alternative 2 is preferable 

because it will most effectively reduce the presence and influence of invasive plants on National 

Forest System lands. It will also do the most to protect and allow for re-establishment of native 

plant ecosystems that have been or are in danger of displacement by invasive plant populations. 

The FEIS acknowledges that this alternative most aggressively uses herbicides and herbicide 

application methods to accomplish the project purpose and need. This FEIS also prescribes PDFs, 

herbicide use buffers and other limitations necessary to ensure protection of the natural and 

human environment.

Pre-Decisional Administrative Review or 

Objection Opportunities

My decision selects a project or activity implementing a land management plan that is not 

authorized under the Healthy Forests Restoration Act of 2003 (Pub. L. 108-148, 117 Stat 1887). 

Therefore, my decision is subject to pre-decisional administrative review and objection pursuant 

to 36 CFR Part 218, subparts A and B. My decision includes a Forest Plan Amendment. 
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

23

The Okanogan-Wenatchee National Forest Forest-wide Site-specific Invasive Plant Management

Project was originally scoped under the provisions of 36 CFR Part 215. For this project, 

individuals or organizations who submitted specific, written comments in response to scoping 

conducted under 36 CFR Part 215 or provided comments to the draft environmental impact 

statement will be considered to have standing to object under 36 CFR Part 218, Subparts A and B.

Issues raised in objections must be based on previously submitted timely, specific written 

comments regarding the proposed project unless the issue is based on new information arising 

after the designated comment opportunities.

The following address should be used for objections sent by regular mail: Objection Reviewing 

Officer, USDA Forest Service, Pacific Northwest Region, Pacific Northwest Region, USDA 

Forest Service, Attn: 1570 Appeals and Objections, PO Box 3623, Portland, OR 97208-3623. 

Objections delivered by mail must be received before the close of the fifth business day after the 

objection filing period. 

Objections sent by private carrier or hand delivery must go to: Objection Reviewing Officer, 

USDA Forest Service, Pacific Northwest Region, 1220 SW 3rd Avenue, Portland, OR 97204. 

Hand deliveries can occur between 8:00 AM and 4:30 PM, Monday through Friday except legal 

holidays.

Objections can be faxed to the Objection Reviewing Officer, Attn: 1570 Objections at (503)-808-

2339. The fax coversheet must include a subject line with “Okanogan-Wenatchee National Forest 

Forest-wide Site-specific Invasive Plant Management Project” and should specify the number of 

pages being submitted.

Electronic objections must be submitted to the Objection Reviewing Officer via email to 

objections-pnw-regional-office@fs.fed.us. with “Okanogan-Wenatchee National Forest Forestwide Site-specific Invasive Plant Management Project” in the subject line. Electronic submissions 

must be submitted in a format that is readable with optical character recognition software (e.g., 

MS Word, PDF, Rich Text Format) and be searchable. An automated response should confirm 

your electronic objection has been received.

The objection must meet the content requirements of 36 CFR § 218.8(d), and include the 

following information: 1) the objector’s name and address, with a telephone number or email 

address, if available; 2) a signature or other verification of authorship upon request (a scanned 

signature for email may be filed with the objection); 3) when multiple names are listed on an 

objection, identification of the lead objector as defined in 36 CFR § 218.2 (verification of the 

identity of the lead objector shall be provided upon request); 4) the name of the project being 

objected to, the name and title of the responsible official, and the name of the National Forest and 

Ranger District on which the project will be implemented; 5) a description of those aspects of the 

project addressed by the objection, including specific issues related to the project and, if 

applicable, how the objector believes the environmental analysis or decision specifically violates 

law, regulation, or policy; suggested remedies that would resolve the objection; and supporting 

reasons for the reviewing officer to consider; and 6) a statement that demonstrates the connection 

between prior specific written comments on the particular project or activity and the content of 

the objection, unless the objection concerns an issue that arose after the designated opportunity 

for formal comment. With certain exceptions (36 CFR § 218.8(b)), all documents referenced in 

the objection must be included with the objection.
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

24

Objections, including attachments, must be filed within 45 days from the publication date of a 

“Legal Notice of the Opportunity to Object” for this project in the Wenatchee World, the 

newspaper of record (78 FR 241, p. 76101, 12/16/2013). Attachments received after the 45-day 

objection period will not be considered. The publication date in the newspaper of record is the 

exclusive means for calculating the time to file an objection. Those wishing to object this project 

should not rely upon dates or timeframe information provided by any other source.

It is the objector’s responsibility to ensure timely filing of a written objection with the reviewing 

officer pursuant to 36 CFR § 218.9. All objections are available for public inspection during and 

after the objection process. Responses that do not adhere to these requirements make review of 

an objection difficult and are conditions under which the reviewing officer may set aside an 

objection pursuant to 36 CFR § 218.10.

Implementation 

The Okanogan-Wenatchee National Forest Forest-wide Site-specific Invasive Plant Management

Project may be implemented after the completion of the objection process and immediately upon 

my issuance of a signed Record of Decision. I will notify interested or affected parties of the 

availability of this ROD as soon as practicable after signing (36 CFR § 220.5(g)).
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

25

Contact Person

For additional information concerning this decision, the Forest Service pre-decisional 

administrative review and objection process, or to request additional copies of the FEIS or ROD, 

contact Brigitte Ranne, Project Coordinator by e-mail at invasiveplants@fs.fed.us or by telephone 

at 509-682-4941.

MICHAEL WILLIAMS [DATE]

Forest Supervisor

Okanogan-Wenatchee National Forest
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

27

ATTACHMENT 1

Current Range of Treatment Method Options For Known Species

The Treatment Methods table (Table 1-1) displays the acreages and number of sites infested with 

each priority species, the range of effective treatment options, the preferred selected method or 

combination of methods and site-specific considerations important to the final prescription. The 

Treatment Methods table is based on “Common Control Methods” Appendix B, R6 PNW FEIS; 

information in Pacific Northwest Weed Management Handbook, Extension Services of Oregon 

State University, Washington State University, and the University of Idaho, 2008; and Nature 

Serve (www.natureserve.org). 

Of the 9 herbicides proposed for use in this project, imazapic is not listed in the Treatment 

Methods table (Table 2.5) because currently, the Forest does not have an invasive plant species 

where imazapic would be the preferred herbicide. Imazapic would still be approved should a 

species which requires its use (such as leafy spurge) be located in the future. Other herbicides are 

not expected to be needed for current target species or likely new invaders. 

Prior to treatment, a treatment prescription would be developed considering the target species and 

location. The appropriate integrated treatment methods, including herbicide ingredient and 

application methods, would be determined and appropriate design features would be incorporated 

into the prescription. 

Table 1-1: Treatment Methods – Range of Effective Treatment Options and Site Specific 

Considerations by Target Species 

Target Species 

Common Name

(USDA PLANTS 

database code)

Acres and 

Number of 

Sites

Range of Effective

Treatment Options

Baby’s Breath

(GYPA)

Gysophila 

paniculata

Perennial

All effective 

(IWM) 

methods 

available. 

Herbicide 

treatment is 

the preferred 

method:

.2 acres

2 sites

Manual/Mechanical treatment can be effective on small 

populations by severing the crown from the roots by 

cultivation or hand-cutting to several inches below the soil. 

No biocontrols are available.

Herbicide treatment is most effective with following 

priority:

1. Triclopyr TEA and Clopyralid

2. Glyphosate (aquatic formulation)

Riparian acres: 0

Effective herbicides within the aquatic influence zone: 

Aquatic Glyphosate

Bull Thistle 

(CIVU)

Cirsium vulgare

Biennial

All effective 

IWM 

methods 

available. 

Herbicide is 

the preferred 

method 

Manual, mechanical and herbicide control are effective. 

Eliminating seed production is the most effective 

manual/mechanical control technique. Close mowing or 

cutting twice during the growing season or cutting plants 

with a sharp shovel at 1” to 2” below the soil surface 

before flowering is effective. 
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Target Species 

Common Name

(USDA PLANTS 

database code)

Acres and 

Number of 

Sites

Range of Effective

Treatment Options

491 acres

413 sites

Biological controls exist but are very limited in 

Washington. Not expected to be available. 

Herbicide treatment is most effective.

1. Aminopyralid

2. Picloram or Clopyralid

3. Metsulfuron methyl

Riparian areas: 30 acres within 234 sites are proposed 

for chemical treatment in riparian areas. Effective 

herbicides within the aquatic influence zone: 

Aminopyralid, Aquatic Glyphosate 

Canada Thistle

(CIAR4)

Cirsium arvense

Perennial

All effective 

IWM 

methods 

available. 

Herbicide is 

the preferred 

method:

960 acres

425 sites

The only effective manual technique is hand cutting of 

flower heads, which only suppresses seed production. 

Covering with a plastic tarp may also work for small 

infestations. 

Biocontrols are available but with limited effectiveness.

Herbicide treatment is most effective.

1. Aminopyralid

2. Clopyralid

Riparian areas: 73 acres within 275 sites are proposed 

for chemical treatment in riparian areas. Effective 

herbicides within the aquatic influence zone: 

Aminopyralid, Aquatic Glyphosate

Common 

burdock

(ARLA3)

(ARMI2)

Arctium minus

Biennial

All effective 

IWM 

methods 

available. 

Herbicide is 

the preferred 

method:

3 acres

23 sites 

Seedlings may be dug when the taproot is small. Seeds 

must be bagged or burned.

No biocontrols are currently available.

1. Metsulfron methyl

2. Picloram

Riparian areas: 1.1 acres within 14 sites are proposed 

for chemical treatment in riparian areas. Effective 

herbicides within the aquatic influence zone: Metsulfron 

methyl, Aquatic Glyphosate

Common 

Crupina

(CRVU2)

Crupina vulgaris

Annual

All effective 

IWM 

methods 

available. 

Herbicide is 

the preferred 

method:

Manual/Mechanical – hand-pulling is effective on small 

infestations prior to seed set. 

No biocontrols are available.

Herbicide treatment is preferred for dense infestations. 

1. Aminopyralid 
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Target Species 

Common Name

(USDA PLANTS 

database code)

Acres and 

Number of 

Sites

Range of Effective

Treatment Options

93 acres

15 sites

2. Clopyralid 

3. Picloram

Herbicide Treatment in Riparian areas: 3.1 acres 

within 4 sites. Effective herbicides within the aquatic 

influence zone: Aminopyralid, Aquatic Glyphosate

Common Tansy 

(TAVU)

Tanacetum 

vulgare

Perennial

All effective 

IWM 

methods 

available. 

Herbicide is 

the preferred 

method:

76 acres

84 sites

Repeated tillage or digging can be effective, but must be 

done frequently. . Effective manual control requires 

complete removal of the roots when soil is loose or moist.

No biocontrols are available at this time.

Herbicide treatment is most effective.

1. Metsulfuron methyl

2. Aminopyralid

Riparian areas: 7.1 acres within 43 sites are proposed 

for chemical treatment in riparian areas. Effective 

herbicides within the aquatic influence zone: Metsulfuron 

methyl, Aminopyralid. 

Dalmatian/ 

Yellow Toadflax 

(LIDA)

(LIVU2)

Linaria dalmatica, 

Linaria vulgaria

Perennial

All effective 

IWM 

methods 

available. 

Herbicide is 

the preferred 

method:

Biocontrols 

may be used 

on larger 

sites in 

combination 

with 

herbicide 

use on the 

perimeters. 

1589 acres 

337 sites

Hand-pulling or digging can be effective.

Cutting stems in spring or early summer would eliminate 

plant reproduction through seed, but not the infestation.

To be effective non-herbicide treatments require long term 

persistence and are only feasible on relatively small 

infestations. 

Biocontrols are available. 

Herbicide treatment is most effective.

1. Picloram

2. Chlorsulfuron 

Hairy cat’s ear

(HYRA3)

Hypochaeris

radicata L.

All effective 

IWM 

methods 

available. 

Herbicide is 

the preferred 

method:

Hand-pulling or digging is difficult as this plant has a deep 

taproot with several fibrous roots. No known biological 

controls currently available. 

Herbicide treatment is most effective.

1. Aminopyralid

2. Clopyralid
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Target Species 

Common Name

(USDA PLANTS 

database code)

Acres and 

Number of 

Sites

Range of Effective

Treatment Options

Perennial

448 acres

57 sites

3. Glyphosate (aquatic formulation)

Riparian areas: 30 acres within 38 sites are proposed for 

chemical treatment in riparian areas. Effective herbicides 

within the aquatic influence zone: Aminopyralid, Aquatic 

Glyphosate

Hoary alyssum

(BEIN2)

Berteroa incana

annual, winter 

annual, biennial, 

or a short-lived 

perennial

All effective 

IWM 

methods 

available. 

Herbicide is 

the preferred 

method:

135 acres

13 sites

Hand-pulling or digging prior to flowering may be effective 

for small infestations. No known biological controls 

currently available. Herbicide treatment is most effective.

1. Chlorsulfuron

2. Metsulfuron methyl

3. Imazapyr

Riparian areas: 5.8 acres within 9 sites are proposed for 

chemical treatment in riparian areas. Effective herbicides 

within the aquatic influence zone: Metsulfuron methyl, 

Aquatic Glyphosate

Hounds tongue

(CYOF)

Cynoglossum 

officinale

Biennial

All effective 

IWM 

methods 

available. 

Herbicide is 

the preferred 

method:

2,588 acres

87 sites

Digging root crown 1-2 inches below soil surface can be 

effective. Cutting stems prevents seed production. No 

biocontrols are currently available in the United States. 

Herbicide treatment is most effective.

1. Metsulfuron methyl

2. Chlorsulfuron 

3. Picloram 

4. Glyphosate (aquatic formulation) 

Riparian areas: 132 acres within 60 sites are proposed 

for chemical treatment in riparian areas. Effective 

herbicides within the aquatic influence zone: Metsulfuron 

methyl, Aquatic Glyphosate

Japanese 

knotweed 

(POCU6)

Cultivated 

knotweed

(POPO5)

Bohemian 

knotweed

Polygonum 

cuspidatum

Perennial

All effective 

IWM 

methods 

available. 

Herbicide 

treatment 

part of initial 

method on 

all sites.

2.3 acres

3 sites

Cutting in combination with herbicide, or herbicide stem 

injection is most effective. 

No biocontrols are available.

1. Imazapyr

2. Glyphosate (aquatic formulation)

Riparian areas: 0.1 acres within 1 site are proposed for 

chemical treatment in riparian areas. Effective herbicides 

within the aquatic influence zone: Imazapyr, Aquatic 

Glyphosate

Knapweeds All effective 

IWM 

Hand pulling/digging before seed production may be 

effective for small populations, however the entire root 
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Target Species 

Common Name

(USDA PLANTS 

database code)

Acres and 

Number of 

Sites

Range of Effective

Treatment Options

Spotted 

knapweed

(CEBI2, CEMA4)

Centaurea 

biebersteinii

Diffuse 

knapweed 

(CEDI)

Centaurea 

diffusa

Meadow 

knapweed

(CEPR2, CEDE5, 

CENI3)

Centaurea 

debeauxii

Tap rooted 

Biennials, or 

Perennials

methods 

available. 

Herbicide is 

the preferred 

method, may 

be used in 

combination 

with 

biocontrols 

on larger 

sites.

CEBI2, 

CEMA4: 

963 acres

285 sites

CEDI:

4835 acres

1295 sites

CEPR2, 

CEDE5, 

CENI3:

137 acres

35 sites

crown or the taproot must be removed. Digging rosettes in 

the spring can be effective. Biocontrols available for some 

knapweed species (R6 PNW FEIS Appendix H and White 

Paper-Spiegel, 2006)

Herbicide with manual and mechanical treatment. 

Revegetate with desirable species, at high priority sites 

when possible. 

1. Aminopyralid

2. Clopyralid, or Picloram 

3. Glyphosate (aquatic formulation)

Riparian areas: 543 acres within 1051 sites are 

proposed for chemical treatment in riparian areas. 

Effective herbicides within the aquatic influence zone: 

Aminopyralid, Aquatic Glyphosate

Kochia

(KOSC)

(BASC5)

Kochia scoparia

Annual

All effective 

IWM 

methods 

available. 

Herbicide is 

the preferred 

method:

1 acre

1 sites

Pull or hoe prior to seed set. Mowing may be effective on 

smaller plants if all the above ground tissue is removed. 

No biocontrols are available. Herbicide treatment is most 

effective.

1. Chlorsulfuron

2. Metsulfuron methyl 

Riparian acres: 0

Effective herbicides within the aquatic influence zone: 

Metsulfuron methyl, Aquatic Glyphosate

Leafy Spurge

(EUES)

Euphorbia esula

Rhizomatous 

perennial

All effective 

IWM 

methods 

available. 

Herbicide 

treatment is 

the preferred 

method on 

all sites.

0 acre

Hand pulling is usually ineffective even for small isolated 

infestations. Repeated mowing or hand cutting may be 

used as a control of seed production, but it must be used 

in conjunction with herbicides for adequate control of 

stand expansion. Grazing by domestic goats or sheep

may help control leafy spurge when long term grazing is a 

possibility. Biocontrols are available. 

Herbicide treatment is most effective. It is possible to 

eradicate small early detected populations with herbicides. 

Larger well established populations would require a long-
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Target Species 

Common Name

(USDA PLANTS 

database code)

Acres and 

Number of 

Sites

Range of Effective

Treatment Options

0 sites term integrated management program requiring a 

combination of chemical, cultural, and biocontrol. Multiple 

treatments per year are required. 

1. Picloram (initial treatment)

2. Glyphosate or Imazapic (follow up treatments)

Riparian acres: 0

Effective herbicides within the aquatic influence zone: 

Aquatic Glyphosate

Orange 

Hawkweed

(HIAU)

(HIPR)

(Hieracium 

pratense)

Meadow

Hawkweed

(HICA10)

Hieracium 

caespitosum

Perennial

All effective 

IWM 

methods 

available.

Herbicide 

treatment on 

all sites:

HIAU

161 acres

62 sites 

HICA 

102 acres

53 sites

Manual control is ineffective. Hand seed with native 

species. No biocontrols are available.

Herbicide treatment is most effective.

1. Aminopyralid

2. Clopyralid

3. Glyphosate 

Riparian areas: 8 acres within 27 sites are proposed for 

chemical treatment in riparian areas. Effective herbicides 

within the aquatic influence zone: Aminopyralid, Aquatic 

Glyphosate 

Oxeye Daisy

(LEVU)

Leucanthemum 

vulgare

Perennial

All effective 

IWM 

methods 

available. 

Herbicide 

treatment on 

all sites:

901 acres

341 sites

Repeated hand pulling, digging, or mowing is effective to 

prevent seed production. Mowing must be repeated in the 

same growing season. Herbicide treatment or a 

combination of manual and herbicide treatment can be 

effective. No biocontrols are available.

 

1. Aminopyralid

2. Clopyralid

Riparian areas: 80 acres within 199 sites are proposed 

for chemical treatment in riparian areas. Effective 

herbicides within the aquatic influence zone: Aminopyralid, 

Aquatic Glyphosate

Puncture vine 

(TRTE)

Tribulus terrestris

Annual

All effective 

IWM 

methods 

available. 

Herbicide is 

preferred 

method:

0 acres

0 sites

Manual, mechanical or herbicide application can be 

effective. Biocontrol available.

1. Chlorsulfuron

2 Imazapic 

3. Glyphosate 

Riparian areas: 0

Effective herbicides within the aquatic influence zone: 

Aquatic Glyphosate
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Target Species 

Common Name

(USDA PLANTS 

database code)

Acres and 

Number of 

Sites

Range of Effective

Treatment Options

Bio-control 

on larger 

sites.

0 acres

0 sites

Purple 

loosestrife 

(LYSA2) 

Lythrum salicaria

Yellow

loosestrife

(LYSIM)

Lysimachia sp.

Perennial

All effective 

IWM 

methods 

available. 

Herbicide 

treatment on 

all sites, in 

combination 

with biocontrol on 

larger sites:

6 acres

1 site

Hand-removal is only recommended for small populations 

or isolated stems as the entire rootstock must be pulled 

out. A combination of manual/mechanical and herbicide 

treatments is most effective. Biocontrols available.

1. Imazapyr 

2. Glyphosate (aquatic formulation)

Riparian acres: 6 

Effective herbicides within the aquatic influence zone: 

Aquatic Imazapyr, Aquatic Glyphosate

Rush 

Skeletonweed

(CHJU)

Chondrilla juncea

Perennial

All effective 

IWM 

methods 

available. 

Herbicide 

treatment on 

all sites.

0 acres

0 sites

Mechanical damage to plants stimulates new growth 

resulting in satellite plants. Manual, methods are not 

recommended. Rush skeletonweed is a deep rooted, 

rhizomatous perennial considered tolerant to herbicides. 

Therefore, an aggressive follow up program with repeated 

applications would be necessary. Difficult to apply 

herbicides because of small leaves. Biocontrols available.

1. Aminopyralid 

2. Clopyralid 

Riparian areas: 0 

Effective herbicides within the aquatic influence zone: 

Aminopyralid, Aquatic Glyphosate

Russian 

Knapweed

(CERE6)

(ACRE3)

Acroptilon

repens

Perennial with

adventitious

shoots

All effective 

IWM 

methods 

available. 

Herbicide in 

combination 

with 

mechanical, 

manual, and 

competitive 

planting is 

Hand pulling is very difficult due to the extensive root 

system, but can be effective for small infestations during 

the establishment year only when the soil is wet and 

before seeds have formed. Lasting control requires an 

integration of techniques: mechanical, manual, herbicide 

and competitive plantings. No biocontrols are currently 

available.

1. Aminopyralid

2. Picloram 

3. Clopyralid 
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Target Species 

Common Name

(USDA PLANTS 

database code)

Acres and 

Number of 

Sites

Range of Effective

Treatment Options

preferred 

method:

4 acres

10 sites

Riparian areas: 0.2 acres within 3 sites are proposed for 

chemical treatment in riparian areas. Effective herbicides 

within the aquatic influence zone: Aminopyralid, Aquatic 

Glyphosate

Russian thistle 

(SATR12 or 

SAIB) 

Salsola tragus

Annual

All effective 

IWM 

methods 

available. 

Herbicide is 

the preferred 

method:

4 acres 

1 site

Manual or mechanical removal of plant prior to seed set 

can be effective in small populations. Repeat visits to 

areas previously infested likely required. Herbicides are 

the most effective treatment. No effective biocontrols are 

available.

1. Chlorsulfuron

2. Metsulfuron methyl

Riparian acres: 0

Effective herbicides within the aquatic influence zone: 

Metsulfuron methyl, Aquatic Glyphosate

Scotch Broom

(CYSC4)

Cytisus scoparius

Perennial woody 

shrub

All effective 

IWM 

methods 

available. 

Herbicide is 

the 

preferred 

method, with 

bio-control 

on larger 

sites

89 acres

28 sites

Hand pulling may be used to destroy seedlings or plants 

up to 1.5 meters tall after a rain when the soil is loose 

when the root system can be removed in its entirety. 

Where herbicides are used, manual treatments could be 

used for follow-up. 

Re-vegetate with desirable species.

Biocontrols available.

1. Hand application of Triclopyr TEA

2. Picloram

Riparian areas: 3.5 acres within 10 sites are proposed 

for chemical treatment in riparian areas. Effective 

herbicides within the aquatic influence zone: Aquatic

Glyphosate 

Scotch/Musk 

Thistle

(ONAC)/(CANU4)

Onopordum 

acanthium

Biennial

All effective 

IWM 

methods 

available. 

Herbicide is 

the preferred 

method:

143 acres

237 sites

Mowing can be effective when combined with revegetation 

of native species. Repeated mowing, in combination with 

other management methods, often is necessary for longterm control. Manual removal is effective when entire 

above ground plant growth is removed. No biocontrols are 

currently available in United States. Herbicide treatment is 

the most effective control.

1. Aminopyralid

2. Clopyralid

Riparian areas: 7.8 acres within 34 sites are proposed 

for chemical treatment in riparian areas. Effective 

herbicides within the aquatic influence zone: Aminopyralid, 

Aquatic Glyphosate

St John’s Wort

(HYPE)

All effective 

IWM 

Hand pulling or digging of young plants in small, isolated 

infestations may be effective. Repeated treatments would 
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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Target Species 

Common Name

(USDA PLANTS 

database code)

Acres and 

Number of 

Sites

Range of Effective

Treatment Options

Hypericum 

perforatum

Perennial

methods 

available. 

Herbicide is 

the preferred 

method, 

used with 

bio-control 

on larger 

sites

1334 acres

347 sites

be necessary because lateral roots can give rise to new 

plants. Pulled or dug plants must be removed from the 

area and burned to prevent vegetative re-growth. Mowing 

is ineffective, but may discourage the spread of the plant if 

done before seeds form. Biocontrols available. 

Herbicide treatment is the most effective control.

1. Metsulfuron methyl 

2. Aminopyralid

3. Picloram

Riparian areas: 113 acres within 183 sites are proposed 

for chemical treatment in riparian areas. Effective 

herbicides within the aquatic influence zone: Metsulfuron 

methyl, Aminopyralid

Sulphur 

cinquefoil

(PORE5)

Potentilla recta

Perennial

All effective 

IWM 

methods 

available. 

Herbicide 

treatment is 

the preferred 

method on 

all sites:

501 acres

224 sites

Hand-pulling and mowing are not effective. No biocontrols 

are available. Herbicide treatment is the only effective 

control.

1. Aminopyralid 

2. Picloram

Riparian areas: 36 acres within 114 sites are proposed 

for chemical treatment in riparian areas. Effective 

herbicides within the aquatic influence zone: Aminopyralid, 

Aquatic Glyphosate

Tansy ragwort

(SEJA)

Senecio 

jacobaea

and other 

Senecio spp. 

Tansy: Biennial 

or short-lived 

perennial 

Woodland: 

Annual

All effective 

IWM 

methods 

available. 

Herbicide 

treatment on 

all sites, 

used in 

combination 

with biocontrol on 

larger sites

18 acres

19 sites

Hand pulling is effective if done when soils are moist and 

the hole left behind is mulched. Mowing can prevent 

flowering, but may also increase rosette density

Biocontrols available. 

Herbicide treatment is most effective.

1. Aminopyralid

2. Clopyralid 

Riparian areas: 0.6 acres within 9 sites are proposed for 

chemical treatment in riparian areas. Effective herbicides

within the aquatic influence zone: Aminopyralid, Aquatic 

Glyphosate

Whitetop

(CADR)

Cardaria draba

Perennial

All effective 

IWM 

methods 

available. 

Herbicide 

treatment is 

the preferred 

Hand pulling of above ground plant parts is ineffective. No 

biocontrols are available.

Herbicide treatment is most effective.

Revegetate with desirable species. 
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Target Species 

Common Name

(USDA PLANTS 

database code)

Acres and 

Number of 

Sites

Range of Effective

Treatment Options

method on 

all sites:

16 acres

56 sites

1. Chlorsulfuron

2. Metsulfuron methyl

3. Imazapyr (aquatic formulation)

Riparian areas: 1.8 acres within 28 sites are proposed 

for chemical treatment in riparian areas. Effective 

herbicides within the aquatic influence zone: Metsulfuron 

methyl, Aquatic Glyphosate

Yellow 

starthistle

(CESO3)

Centaurea 

solstitialis

Annual

All effective 

IWM 

methods 

available. 

Herbicide is 

the preferred 

method.

1.5 acres 

3 sites

Manual removal is only effective in small patches or in 

maintenance programs where plants are sporadically 

located. All above ground stem material must be 

detached. The best time for manual removal is after 

plants have bolted but before they produce viable seed 

(early flowering). Mowing can be useful but timing is 

critical.

Biocontrol available. 

Revegetate high priority sites if needed with desirable 

species. 

Herbicide treatment is most effective.

1. Aminopyralid

2. Clopyralid or picloram

Riparian acres: 0

Effective herbicides within the aquatic influence zone: 

Aminopyralid, Aquatic Glyphosate

Changes to treatment methods within known invasive plant sites are expected over time. Different 

combinations of treatment may be appropriate depending on the site conditions and treatment 

strategy at the time of treatment. Some sites may grow in size or density if treatment is deferred 

or is ineffective; other sites presumably would be reduced in size or density due to effective 

treatment. Field conditions at the time of treatment influences the choice of integrated treatment 

method. As long as the treatment method has been described in this EIS and the project design 

features, herbicide use buffers, and annual treatment caps are properly applied, treatments within 

or outside currently infested areas anywhere on the Forest may be treated. Treatment caps would 

include treatment of existing and new sites. 

New species of invasive plants may be located in the project area in the future. As long as 

treatment methods described above are effective, and the project design features are appropriately 

applied, new species (within existing or new sites) may be treated.

Widespread species such as cheatgrass would not be prioritized for treatment and are not included 

in the acreage estimates. However, these species would not be considered non-target species and 

may be treated as long as all other project design features are followed and annual caps are 

observed. This would likely occur in special areas such as wilderness, or in conjunction with 

adjacent invasive plant treatments for higher priority target species. 
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Project Design Features (Mitigation Measures) 

The Project Design Features (PDFs) were developed to minimize the potential adverse impacts of 

invasive plant treatments, and provide a framework for the EDRR strategy. 

PDFs define a set of conditions or requirements that an activity must meet to avoid or minimize 

potential effects on sensitive resources. The PDFs were designed to mitigate impacts as a result 

of site-specific resource conditions within currently infested areas. PDFs are an integral 

component of the alternative, except where specifically noted, and therefore, when conditions 

dictate, implementation would be mandatory. Under the EDRR strategy, the applicable PDFs 

would also be applied to newly discovered infestations that are treated. The PDFs provide 

sideboards to ensure that the effects of treating new sites are similar to the effects of treating 

existing sites. The Okanogan-Wenatchee National Forest Herbicide Safety Plan (2005) would 

continue to be followed for all treatments.

Chemical label requirements and common best management practices for herbicide applicators 

are assumed to be followed and are not repeated herein. 

ARBO II Design Features

The Aquatic Restoration Biological Opinion (II) was issued in 2013 (ARBO II, USFWS, NMFS); 

this document includes specific direction for invasive plant treatments that may affect critical 

riparian and aquatic habitats for species listed under the Endangered Species Act. This project 

incorporates ARBO II in full, although not all of the project design criteria and reporting 

requirements are repeated in this section. Unless otherwise indicated, these design features apply 

to the entire project area (as indicated below) 

Project design features that are covered within the ARBO II include:

1. Use herbicides only in an integrated weed or vegetation management context where all 

treatments are considered and various methods are used individually or in concert to 

maximize the benefits while reducing undesirable effects. Non-native invasive plant 

control projects will not exceed 10% of acres within a Riparian Reserve under the 

Northwest Forest Plan (USDA and USDI 1994a) or RHCA under PACFISH/INFISH 

(USDA and USDI 1994b) within a 6th field watershed annually. 

2. Carefully consider herbicide impacts to fish, wildlife, non-target native plants, and other 

resources when making herbicide choices.

3. Treat only the minimum area necessary for effective control. Herbicides may be applied 

by selective, hand-held, backpack, or broadcast equipment in accordance with state and 

federal law and only by certified and licensed applicators to specifically target invasive 

plant species.

4. Herbicide application rates will follow label direction, unless site- specific analysis 

determines a lower maximum rate is needed to reduce non-target impacts.
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5. An herbicide safety/spill response plan is required for all projects to reduce the likelihood 

of spills, misapplication, reduce potential for unsafe practices, and to take remedial 

actions in the event of spills. Spill plan contents will follow agency direction.2

6. Pesticide applicator reports must be completed within 24 hours of application. 

7. Herbicide adjuvants – When recommended by the label, an approved aquatic surfactant 

would be used to improve uptake. When aquatic herbicides are required, the only 

surfactants and adjuvants permitted are those allowed for use on aquatic sites, as listed by 

the Washington State Department of Ecology: 

http://www.ecy.wa.gov/programs/wq/pesticides/regpesticides.html. (Oregon Department 

of Agriculture also often recommends this list for aquatic site applications). The 

surfactants R-11, Polyethoxylated tallow amine (POEA), and herbicides that contain 

POEA (e.g., Roundup) will not be used. More information about adjuvants is in Chapter 

3.1.3

8. Herbicide carriers – Herbicide carriers (solvents) are limited to water or specifically 

labeled vegetable oil.

9. Herbicide mixing – Herbicides will be mixed more than 150 feet from any natural 

waterbody to minimize the risk of an accidental discharge. Impervious material will be 

placed beneath mixing areas in such a manner as to contain any spills associated with 

mixing/refilling. Spray tanks shall be washed further than 300 feet away from surface 

water. All hauling and application equipment shall be free from leaks and operating as 

intended.

10. Herbicide application methods – Liquid forms of herbicides will be applied as follows:

a) Broadcast spraying using booms mounted on ground-based vehicles.

b) Spot spraying with hand held nozzles attached to back pack tanks or vehicles and 

hand-pumped sprayers to apply herbicide directly onto small patches or 

individual plants.

c) Hand/selective through wicking and wiping, basal bark, frill (“hack and squirt”), 

stem injection, or cut-stump.

d) Dyes or colorants, (e.g., Hi-Light, Dynamark) will be used to assist in treatment 

assurance and minimize over-spraying within 100 feet of live water.

11. Minimization of herbicide drift and leaching – Herbicide drift and leaching will be 

minimized as follows:

a) Do not spray when wind speeds exceed 10 miles per hour to reduce the 

likelihood of spray/dust drift. Winds of 2 mph or less are indicative of air 

 2 See the 2004 Forestwide Okanogan and Wenatchee Forest Herbicide Application Safety Plan in the 

project record. 3 Please note that R-11 is a surfactant that contains NPE. NPE is not proposed for use anywhere within the 

project area. POEA is also not proposed for use anywhere within the project area. Additional surfactants 

beyond those approved for aquatic use on the Washington state list may be used in upland areas.
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

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inversions. The applicator must confirm the absence of an inversion before 

proceeding with the application whenever the wind speed is 2 mph or less.

b) Be aware of wind directions and potential for herbicides to affect aquatic habitat 

area downwind.

c) Keep boom or spray as low as possible to reduce wind effects.

d) Avoid or minimize drift by utilizing appropriate equipment and settings (e.g., 

nozzle selection, adjusting pressure, drift reduction agents). Select proper 

application equipment (e.g., spray equipment that produces 200-800 micron 

diameter droplets [Spray droplets of 100 microns or less are most prone to drift]).

e) Follow herbicide label directions for maximum daytime temperature permitted 

(some types of herbicides volatilize in hot temperatures).

f) Do not spray during periods of adverse weather conditions (snow or rain 

imminent, fog, etc.). Wind and other weather data will be monitored and reported 

for all pesticide applicator reports.

g) Herbicides shall not be applied when the soil is saturated or when a precipitation 

event likely to produce direct runoff to fish-bearing waters from a treated site is 

forecasted by NOAA National Weather Service or other similar forecasting 

service within 48 hours following application. Soil-activated herbicides can be 

applied as long as label is followed. Do not conduct any applications during 

periods of heavy rainfall.

12. Herbicide buffer distances – The following no-application buffers— which are measured 

in feet and are based on herbicide formula, stream type, and application method—will be 

observed during herbicide applications (Table 1-2). Herbicide applications based on a 

combination of approved herbicides will use the most conservative buffer for any 

herbicide included. Buffer widths are measured as map distance perpendicular to the bank 

full for streams, the upland boundary for wetlands, or the upper bank for roadside ditches. 

A buffer of 0 means that there is no buffer. 

Table 1-2: Herbicide Use Buffers from ARBO II

Herbicide

Perennial Streams and Wetlands, and

Intermittent Streams and Roadside Ditches

with flowing or standing water present

Dry Intermittent Streams, Dry

Intermittent Wetlands, Dry

Roadside Ditches

Broadcast

Spraying

Spot

Spraying

Hand

Selective

Broadcast

Spraying

Spot

Spraying

Hand

Selective

Distance from surface water in feet

Labeled for Aquatic Use
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Herbicide

Perennial Streams and Wetlands, and

Intermittent Streams and Roadside Ditches

with flowing or standing water present

Dry Intermittent Streams, Dry

Intermittent Wetlands, Dry

Roadside Ditches

Broadcast

Spraying

Spot

Spraying

Hand

Selective

Broadcast

Spraying

Spot

Spraying

Hand

Selective

Distance from surface water in feet

Aquatic 100 waterline waterline 50 0 0

Aquatic Imazapyr 100 waterline waterline 50 0 0

Aquatic TriclopyrTEA

Not allowed 15 waterline Not Allowed 0 0

Low Risk to Aquatic Organisms

Aminopyralid 100 waterline waterline 50 0 0

Imazapic 100 15 bankfull

elevation 50 0 0

Clopyralid 100 15 bankfull

elevation 50 0 0

Metsulfuron-methyl 100 15 bankfull

elevation 50 0 0

Moderate Risk to Aquatic Organisms

Imazapyr 100 50 bankfull

elevation 50 15 bankfullelevation

Chlorsulfuron 100 50 bankfull

elevation 50 15 bankfullelevation

High Risk to Aquatic Organisms

Picloram 100 50 50 100 50 50

Additional Project Design Features

Project design features have been in development for several years and have been refined over the 

years based on learning from other projects and incorporation of the 2013 ARBO II. However, the 

intent of the design features remains consistent and focused on meeting the R6 PNW ROD 

standards associated with invasive plant treatment. 

The numbering conventions have been retained where possible for ease of tracking earlier 

iterations. Gaps in numbering have occurred where previous PDFs have been removed (generally 

because they are redundant with ARBO II or have been combined/refined based on regional 

experience). 

B-1. Coordination with Others

To ensure that neighbors are fully informed about nearby treatments (particularly herbicide use) 

and to increase the effectiveness of treatments being undertaken on adjacent ownerships, work 

 4 Lower risk formulations of glyphosate that do not contain POEA need not be labeled for aquatic use for 

infestations further than 100 feet of streams or other water bodies as defined in this table. 
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with owners and managers of neighboring lands to respond to invasive plants that occur across 

multiple ownerships. Coordinate treatments within appropriate distances based on invasive plant 

species reproductive characteristics, and current use of area. Enlist cooperation of permittees and 

discuss treatment plans on active allotments before treatment. 

C-1. Invasive Plant Prevention

Clean vehicles and equipment that will leave the road prism before entering National Forest. 

Ensure that invasive plant materials are not transported between treatment areas. 

E-2. Mechanical Equipment

Fueling of gas-powered equipment with tanks would not occur inside the RHCAs or Riparian 

Reserves (RRs) unless there is no other alternative.

F-4. Herbicide Use Rates

Table 1-3 lists the maximum rates of herbicide active ingredient that may be used. This provides 

the upper limit for the analysis in Chapter 3. The amount of herbicide applied to any given acre is 

likely to be less than this maximum depending on the size and density of the target species in the 

area. Local knowledge will be used to determine appropriate rates for each situation. 

Table 1-3: Maximum Rate per Acre for Each Herbicide Active Ingredient

Active Ingredient Pounds per Acre Maximum (per 

year)

Aminopyralid 0.09

Chlorsulfuron 0.09

Clopyralid 0.50

Glyphosate 4.00

Imazapic 0.13

Imazapyr 1.25

Metsulfuron methyl 0.075

Picloram 1.00

Triclopyr 2.00

H-5. Manage Herbicide Persistence in Soil

Do not use more than one application of imazapyr, metsulfuron methyl, or picloram on a given 

area in any two calendar years, except to treat areas missed during the initial application. 

Aminopyralid would not be broadcast in any area more than once per year. This would ensure 

that more persistent herbicides will not build up in the soil. 

H-6. Lakes and Ponds

No more than half the perimeter or 50 percent of the vegetative cover or 10 contiguous acres 

around a lake or pond would be treated with herbicides in any 30-day period. This provides some 

untreated areas for some organisms to use as refugia.

H-7. Wetlands
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Wetlands would be treated when soils are driest. If herbicide treatment is necessary when soils 

are wet, use aquatic labeled herbicides. Favor wicking or wiping treatment methods where 

effective and practical. No more than 10 contiguous acres or fifty percent of individual wetland 

areas would be treated in any 30-day period. This provides some untreated areas for some 

organisms to use as refugia.

H-8. Wells and Springs

Herbicide use would not occur within 100 feet of domestic wells or 200 feet of domestic spring 

developments. Use wicking, wiping or spot treatments within 100 feet of the water source for 

stock tanks. This protects water quality and grazing animals. 

I-2. Surveys for Botanical Species of Concern

The Regional Forester’s Special Status Species (RFSSS) list (2011) includes federally listed, 

federally proposed, sensitive and strategic species. In addition, many Northwest Forest Plan 

Survey and Manage species occur on the Forest. Together, RFSSS and Survey and Manage 

species are sometimes referred to as botanical species of concern, or special status species. 

Surveys would be conducted prior to treatment within suitable habitat for botanical species of 

concern. If surveys are not conducted, suitable habitat would be managed assuming the species of 

concern was present.

This is intended to meet policy for protecting native plants as per Forest Service Manual 2670 and 

applicable federally listed recovery plans; and the Northwest Forest Plan as amended.

I-3. Buffers for Botanical Species of Concern

Precautions would be taken to avoid any contact with botanical species of concern. Minimize 

trampling of native vegetation, especially within habitat for botanical species of concern. 

Herbicide would not be applied using the broadcast method within 100 feet of botanical species 

of concern. No spot treatment would be permitted within 10 feet of botanical species of concern 

(limited hand application may be approved). This is intended to meet Forest Service Manual 

2670; recovery plans for federally listed species; and the Northwest Forest Plan, as amended.

These buffers are expected to fully protect botanical species of concern. The buffers will be 

monitored and increased if damage to special status species is observed. See monitoring section 

below.

I-4. Picloram Use within 50 Feet of Botanical Species of Concern

Picloram would not be used within 50 feet of botanical species of concern to ensure protection of 

emerging seedlings and potential non-target plant root uptake due to herbicide soil persistence.

J-1. Wolves, Lynx and Grizzly Bears

Treatments within 1 mile of active wolf and lynx dens would be timed to occur outside the season 

of occupancy (wolf-April 1 through June 30; lynx-May 1 through August 30). Treatments within 

0.50 mile of occupied wolf rendezvous sites would be timed to occur outside the season of 

occupancy (April 1 through August 31) unless treatment activity is within acceptable ambient 

noise levels and human presence would not cause wolves to abandon the site (as determined by a 

local specialist). In grizzly bear core area, motorized vehicle (including ATVs) use will only be 
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permitted on open system roads. This PDF would minimize disturbance/impacts to wolves, lynx 

and bears. 

J-2 Northern Spotted Owl

Project activity that creates noise above ambient levels (i.e. weed-eaters, mowers, etc.) would not 

take place within 1⁄4 mile of a northern spotted owl nest site or an activity center whose status is 

unknown or un-surveyed nesting habitat within 1⁄4 mile of maintenance level 1 roads between 

March 1 and July 31. Local knowledge may be used to adjust dates to site-specific conditions. 

This condition may be waived in a particular year if nesting or reproductive success surveys 

reveal that spotted owls are not nesting or no young are present that year (as determined by a 

local specialist). Waivers are valid only until March 1 of the following year. This would 

minimize disturbance to nesting spotted owls and protect eggs and nestlings.

J-3 Marbled Murrelet

Project activity that creates noise above ambient levels (i.e. weed-whackers, mowers, etc.) would 

not take place within 1⁄4 mile of a marbled murrelet nest site or an activity center whose status is 

unknown or un-surveyed nesting habitat within 1⁄4 mile of maintenance level 1 roads between 

April 1 and September 15. Local knowledge may be used to adjust dates to site-specific 

conditions. This condition may be waived in a particular year if nesting or reproductive success 

surveys reveal that marbled murrelets are not nesting or no young are present that year. Waivers 

are valid only until April 1 of the following year. 

J-4 Bald Eagle 

Treatment of areas generally within 450 meters of bald eagle nests would be timed to occur 

outside the nesting/fledgling season, which is generally January 1 to August 15. Local knowledge 

may be used to adjust dates, size and shape of distance buffers, to site-specific conditions. This 

only applies to treatment activity that creates noise above ambient levels and human presence that 

would cause eagles to abandon the nest (as determined by a local specialist). Occupancy of nest 

sites would be determined each year prior to treatment. This would minimize disturbance to 

nesting bald eagles and protect eggs and nestlings

Noise-producing activity above ambient levels would not occur between October 31 and March 

31 during early morning or late afternoon within 450 meters of known bald eagle winter roosts 

and concentrated foraging areas. Disturbance to daytime winter foraging areas would be 

prohibited. This would minimize disturbance and reduce energy demands during stressful winter 

season.

J-5 Peregrine Falcon

Within 1.5 miles of nest sites, clopyralid and picloram use would be limited to once per year and 

once every other year respectively. This is intended to minimize risk of exposure to 

hexachlorobenzene (HCB).

Treatment of areas generally within 0.5 mile of peregrine nest would be timed to occur outside 

the nesting/fledgling period, which is generally March 1 through June 30. Local knowledge may 

be used to adjust dates, size and shape of distance buffers, to site-specific conditions. This only 

applies to treatment activity that creates noise above ambient levels and human presence that 

would cause peregrines to abandon the nest (as determined by a local specialist). Occupancy of 
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nest sites would be determined each year prior to treatment. This would minimize disturbance to 

nesting peregrine falcons and protect eggs and nestlings.

J-7 Larch Mountain Salamander (Plethodon larselli), Puget Oregonian (Cryptomastix devia), 

Shiny Tightcoil (Pristiloma wascoense) Chelan Mountain snail (Oreohelix n. sp.) Grand Coulee 

Mountain snail (Orehelix juni).

Within mapped high potential suitable habitat for Larch Mountain salamanders, Puget 

Oregonians, Shiny tightcoils, Chelan Mountain snails and Grand Coulee Mountain snails, do not 

broadcast spray herbicide; rather, utilize wiping, wicking and spot spraying methods. No 

broadcasting within 1⁄4 mile of suitable un-surveyed habitat, rocky outcrops and talus. 

Do not apply herbicides within occupied habitat for Larch Mountain salamanders, Puget 

Oregonians, Shiny tightcoils, Chelan Mountain snails and Grand Coulee Mountain snails (USDA 

Forest Service and USDI Bureau of Land Management 2008 and Burke 1999a and b).

These criteria are intended to reduce herbicide exposure to amphibians and mollusks.

Limit time of year invasive plant treatment occurs in occupied and un-surveyed habitat for Larch 

Mountain salamanders, Puget Oregonians, Shiny tightcoils, Chelan Mountain snails and Grand 

Coulee Mountain snails to when species are subterranean (restrict season to cold and dry times). 

This is intended to avoid trampling and applies to all treatment methods. 

J-8 Masked Duskysnail (Lyogyrus n. sp. 2) Zigzag Darner (Aeshna sitchensis) and Subarctic 

Darner (Aeshna subarctica)

Do not broadcast spray herbicides within 100 feet of Fish Lake on the Wenatchee River Ranger 

District. Coordinate treatment method, timing annually with local biologist prior to invasive plant 

treatment in occupied habitat. This is intended to minimize herbicide exposure and trampling. 

J-10 Mardon Skipper, Peck’s Skipper, Tawny-edge Skipper, Meadow Fritillary, and Great Basin 

Fritillary

Do not use of ester formulations of herbicide and do not broadcast any herbicide in known 

Mardon, Peck’s and tawny-edge Skippers, and meadow and Great Basin fritillary habitat. Use 

herbicides on no more than 50% of known sites in any one year. Coordinate treatment method, 

timing, locations, amount of habitat treated annually with local biologists. This is intended to 

minimize exposure to herbicides, surfactants, and trampling while effectively protecting and 

improving habitat.

J-11 Raptors

Active raptor nest sites should be protected from disturbance above ambient noise levels during 

the dates specified. Local biologists would determine appropriate distances for planned 

operations prior to implementation. This is intended to prevent disturbance to nesting raptors 

during the following periods: 

Golden eagle February 15 – September 1

Osprey April 1 – August 31

Red-tailed hawk March 1 – August 31
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Northern goshawk March 1 – September 31

Cooper’s hawk April 1 – August 31

Sharp-shinned hawk April 1 – August 31

Prairie falcon March 1 – June 30

Great gray owl March 1 – July 31

Long-eared owl April 1 – July 15

Great horned owl February 15 – July 15

K-1 Public Notification

Notify the public about upcoming herbicide treatments via one or more of the following 

techniques: newspaper; Forest Service website, individual contact with sensitive individuals on 

the state list as requested; and signs posted in picnic areas, roadsides and campgrounds near 

treatment sites. Extra postings would occur when triclopyr is being applied in areas suspected to 

be special forest product or wild food gathering areas. This is intended to meet public notification 

requirements regarding herbicide use on National Forest and to specifically minimize inadvertent 

(and unlikely) public exposure to triclopyr (see Chapter 3.8). 

L-1 Heritage Resources

A Forest Heritage Resource Specialist would assess whether manual or mechanical treatments 

have the potential to affect heritage resources on a site basis. Unless previously surveyed or in an 

area of previous ground disturbance, field inventories would be conducted in accordance with the 

Forest’s heritage resource probability model and/or where heritage resources have been 

documented. Manual or mechanical treatments within the boundary of a heritage resource site 

would be monitored and documentation of each project would be in accordance with the Forest’s 

1997 Section 106 programmatic agreement. This is intended to avoid adverse impacts to heritage 

resources from manual and mechanical treatments. 

Early Detection and Rapid Response Approach 

New sites would be treated using integrated methods, anywhere within the project area, over the 

life of the project, according to the project design features and herbicide use buffers described in 

Chapter 2.2.2.Invasive plants are expected to spread at a rate that would theoretically result in an 

additional 17,566 acres of invasive plant infestations on the Forest over the next 15 years, for a 

cumulative total of 33,847 acres (when added to the existing mapped inventory).

Most spread is expected to occur near known infestations; however invasive species may spread 

to other locations on the Forest. The location of new sites is not predictable, however, the effects 

of treatment are predictable because similar treatments on similar sites would be expected to have 

similar effects, and the project design features, herbicide use buffers, and annual caps provide 

sideboards on the extent and intensity of treatment. 
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Combined treatment of known sites and sites added through EDRR would not exceed 16,281 

infested acres per year, which are the current known acres of infestation. Defining this acreage 

“cap” allows the analysis in the EIS to proceed within well-defined parameters. 

New infestations would be recorded and documented as discovered. Treatment methods for new 

infestations would be the same as those described for known infestations. Newly discovered 

infestations or sites would receive a high priority for treatment for eradication while the 

infestation is small and treated most effectively.

New invasive species that are not currently found may be detected within or outside currently 

infested areas. Treatment of new species may occur as long as the treatment method is similar to 

those described in this EIS for known species and PDFs/buffers are followed.

Treatments of new sites or species would be within scope of this project as long as the type of 

treatment has been analyzed and PDFs can be effectively applied. 

Forest Plan Amendment 

The first sentence of treatment and restoration standard 16 from the R6 PNW ROD would be 

amended to add aminopyralid to the list of allowed herbicides on the Okanogan-Wenatchee 

National Forest only, thereby amending both the Okanogan-Wenatchee National Forest’s Forest 

Plans to allow use of aminopyralid under this decision. 

Adding aminopyralid through a non-significant forest plan amendment is consistent with the 

goals of the R6 PNW ROD and was anticipated by standard #16, which states that “Additional 

herbicides and herbicide mixtures may be added in the future at either the Forest Plan or project 

level through appropriate risk analysis and NEPA/ESA procedures.” 

An herbicide risk assessment was completed in 2007 for aminopyralid (SERA 2007). 

Aminopyralid is one of the most effective herbicide on many target plants in the composite 

family, and has a lower potential for environmental and human health effects than the other 

broadleaf selective herbicides approved in the R6 PNW ROD (Bautista and Bulkin 2011). 

Monitoring and Adaptive Management 

The inventory and monitoring framework included in the R6 PNW ROD will be used. This 

framework describes the monitoring needed to assure that desired future conditions and treatment 

strategies are achieved. The framework includes implementation/compliance and effectiveness 

monitoring components. In addition, water quality best management practices for chemical uses 

near streams would be monitored according to national protocols. Monitoring would include the 

effectiveness of the treatments and their potential adverse effects. Various methods and 

combinations of methods may be tried over time until invasive plants are effectively treated and 

treatment sites are appropriately restored. Treatment prescriptions would be adjusted if 

unexpected adverse impacts are observed. 

Implementation Planning

The following outlines the process that will be used to ensure that the selected alternative is 

properly implemented. It applies to invasive plant sites known and identified for treatment in the 

EIS as well as new sites found during inventory (Early Detection/Rapid Response). An invasive 

plant assessment review team will be assembled on each Ranger District as needed to ensure 

consistent and effective treatment is applied, appropriate Project Design Features are 

implemented, and necessary monitoring and reporting are completed. Team members and a team 
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leader will be assigned by the District Rangers, and will include fish and wildlife biologists, range 

conservationists and botanists as needed. 

In order to find new invaders and new infestations each District will annually inventory road, 

trails, and vulnerable and disturbed areas. Employees would be trained to identify invasive 

plants and asked to report them to the invasive plant managers. Invasive plant surveys would be 

conducted project areas with planned ground disturbance, and in burned areas. New infestations 

would be recorded in the USFS NRIS database. Creation of volunteer weed watcher programs 

would be encouraged. Information about invasive plant infestations would be requested and 

collected from all Forest users including grazing permittees, recreationists, and hunters. Invasive 

plant managers would work closely with county weed boards to be kept apprised of infestations 

on private lands that could spread onto the forest.

For new sites to be treated under EDRR, describe density, type and number of species, and their 

extent using NRIS data forms. Ensure new invasive plant sites are entered into the NRIS 

database. Ensure that treatment prescriptions and site conditions are similar to those analyzed in 

this EIS. 

For all treatment sites, identify and implement pre-treatment surveys as needed (e.g. survey and 

manage or TES plants). Develop prescriptions based on: � Criteria associated with the selected 

alternative including limitations on herbicide use, � Size of infestation, treatment history and 

response to past treatments; � Proximity to sensitive species or habitats; � Proximity to streams, 

lakes, or wetlands; � Soil conditions; � Domestic water intakes or position in municipal 

watershed; � Recreation or special forest product uses, and � Mineral Material source (in use or 

planned for use).

Early on, consider if active restoration (seeding of native species) will be required. The need for 

active restoration will be re-assessed during post-treatment monitoring. For active restoration 

sites, ensure acceptable plant are available before implementation. 

Implementation/Compliance Monitoring

Implementation/compliance monitoring answers the question, “Did we do what we said we would 

do?” At the forest level, this would entail tracking of compliance with R6 PNW ROD treatment 

and restoration standards, compliance with the PDFs in this document, and implementation of the 

EDRR screening process. Monitoring steps include:

• Maintain and update the Forest inventory in the NRIS (or replacement) database.

• Document the EDRR evaluation and review process for new sites. 

• Prepare a project work plan and pesticide use proposal (Form FS2100-2) as described in 

FSH 2109.14. 

• Ensure contracts and agreements include appropriate prescriptions, herbicide ingredients 

and application rates label requirements, R6 PNW ROD standards 16 and 18, and PDFs. 

• Obtain National Pollution Discharge Elimination System (NPDES) permits as needed to 

comply with the Clean Water Act. 

• Document acres treated in riparian areas (total and as a percent of each 6th field 

watershed) and total acres treated each year on the Forest.
Draft Record of Decision – OKAWEN N.F. Forest-wide Site-specific Invasive Plant Mngmt EIS

48

• Document invasive plant treatment accomplishments, implementation monitoring and 

herbicide use and certified applicator information in the National Pesticide Use Database, via the 

FACTS (or replacement) database. 

Compliance monitoring would occur before implementation to ensure that prescriptions, contracts 

and agreements integrate appropriate Project Design Features. This would be done via a prework review. 

Implementation monitoring would occur to ensure Project Design Features are implemented as 

planned. Contract administration mechanisms would be used to correct deficiencies. Pesticide 

use reports would be filed as required.

Effectiveness Monitoring and Adaptive Response

Effectiveness monitoring answers the question, “Were treatment and restoration activities 

effective?” At the Forest level, post treatment reviews would be used to determine whether 

invasive plant site objectives (eradicate, control, contain, or suppress) are being met, and whether 

passive or active restoration has occurred as expected.

At the Regional level, sample monitoring would evaluate the effectiveness of various measures, 

including R6 PNW ROD standards and PDFs designed to reduce potential adverse effects that 

pose a high risk to federally listed species. High risk projects are defined as those using aerial 

application of herbicide and the use of heavy equipment or broadcast application in riparian areas 

containing, or connected to, habitat for listed fish species, or in proximity to listed plants or 

butterfly habitat. No aerial treatment, heavy equipment use, or broadcast within 100 feet of 

streams is proposed in this project, therefore treatments meeting the high risk criteria would not 

occur. Limitations on annual extent of treatment and the scattered nature of the infestations 

further reduce risk as defined in the R6 PNW ROD Monitoring Framework and subsequent 

Monitoring Plan (USFS 2012). 

The target for post-treatment monitoring is 50% of the acres treated. Treatments and treatment 

effectiveness would be recorded in the FACTS database. Forest-level monitoring also includes 

maintaining and updating the Forest inventory in the NRIS database, which would help track if 

infestations are spreading and if new infestations are found.

Retreatment and active restoration would be implemented based on post-treatment results. 

Changes in herbicide or non-herbicide methods would occur based on results. For instance, an 

invasive plant population treated with a broadcast herbicide may be retreated with a spot spray, or 

later manually pulled, once the size of the infestation is sufficiently reduced following the initial 

treatment. 

Effectiveness monitoring would occur to ensure treatments have been effective and non-target 

vegetation was not impacted. Monitoring would occur before, during and after treatment to 

determine whether invasive plants are being effectively controlled and to ensure non-target 

vegetation, especially botanical species of concern are adequately protected. Treatment buffers 

would be expanded for the monitored site and all future treatment sites if damage or mortality is 

found. 

Additional monitoring may be done as part of the R6 effectiveness monitoring program, 

Okanogan-Wenatchee National Forest annual monitoring plan, or other ongoing programs such as 

state water quality monitoring. 

for the greatest good

PENALTY FOR PRIVATE USE, $300OFFICIAL BUSINESSWenatchee, WA 98801215 Melody LaneOkanogan-Wenatchee National ForestForest ServiceUnited States Department of Agriculture