Pacific Northwest Region 

October 2005 

Invasive Plant Program 

 Preventing and Managing Invasive Plants 

Record of Decision 

USDA Forest Service 

Pacific Northwest Region 

States of Oregon and Washington, Including Portions of Del Norte and Siskiyou Counties in 

California, and Portions of Nez Perce, Salmon, Idaho, and Adams Counties in Idaho 

Lead Agency: USDA Forest Service 

Responsible Official: Linda Goodman, Regional Forester 

Pacific Northwest Region

333 SW First Ave. 

PO Box 3623 

Portland, OR 97208 

For More Information: IPEIS, c/o Douglas Daoust 

PO Box 3623 

Portland, OR 97208 

Ph: (503) 808-2913 

Fax: (503) 808-2469 

Email: r6_IPEIS@fs.fed.us

www.fs.fed.us/r6/invasiveplant-eis 

Summary: This Record of Decision documents the Regional Forester’s selection of 

Proposed Action from the Invasive Plant Program FEIS, with some modifications. This 

decision adds invasive plant management direction to all National Forest Land and Resource 

Management Plans in the Pacific Northwest Region (Region Six). The management direction 

includes invasive plant prevention and treatment/restoration standards intended to help 

achieve stated desired future conditions, goals and objectives. The management direction is 

expected to result in decreased rates of spread of invasive plants, while protecting human 

health and the environment from the adverse effects of invasive plant treatment. 
"The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and 

activities on the basis of race, color, national origin, age, disability, and where applicable, sex, 

marital status, familial status, parental status, religion, sexual orientation, genetic information, 

political beliefs, reprisal, or because all or part of an individual’s income is derived from any 

public assistance program. (Not all prohibited bases apply to all programs.) Persons with 

disabilities who require alternative means for communication of program information (Braille, 

large print, audiotape, etc.) should contact USDA's TARGET Center at (202) 720-2600 (voice 

and TDD). To file a complaint of discrimination, write to USDA, Director, Office of Civil 

Rights, 1400 Independence Avenue, S.W., Washington, DC 20250-9410, or call (800) 795-

3272 (voice) or (202) 720-6382 (TDD). USDA is an equal opportunity provider and 

employer.” 
Record of Decision 

Table of Contents 

Background......................................................................................................................................... 1 

Decision .............................................................................................................................................. 2 

Details of the Decision ................................................................................................................... 3 

Alternatives Considered...................................................................................................................... 5 

No Action Alternative .................................................................................................................... 5 

Proposed Action ............................................................................................................................. 5 

Alternative B................................................................................................................................... 6 

Alternative D .................................................................................................................................. 7 

Rationale for the Decision................................................................................................................... 8 

The Selected Alternative as a Whole.............................................................................................. 8 

Desired Future Condition, Goals and Objectives ........................................................................... 9 

Prevention Standards.................................................................................................................... 10 

Treatment/Restoration Standards.................................................................................................. 20 

Inventory and Monitoring Plan Framework ................................................................................. 32 

Public Involvement ........................................................................................................................... 33 

Environmentally Preferable Alternative ........................................................................................... 34 

Findings Required by Laws and Regulations.................................................................................... 35

Civil Rights and Environmental Justice ....................................................................................... 35

National Environmental Policy Act (NEPA)................................................................................ 35 

National Forest Management Act (NFMA).................................................................................. 36 

Endangered Species Act (ESA).................................................................................................... 36 

Clean Water Act ........................................................................................................................... 37 

Valid Existing Rights.................................................................................................................... 37 

Implementation ................................................................................................................................. 37 

Appendix 1 – Full Text Added to Forest Plans in R6..................................................... Appendix 1-1 

Appendix 2 – Alternative Comparison/Decision Factors ............................................... Appendix 2-1 

i
Table of Tables 

Table 1 Key Features of the Alternatives...................................................................................7 

Table S-2 Alternative Comparison/Decision Factors..................................Appendix 2-1

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Preventing and Managing Invasive Plants Record of Decision September 2005 

Record of Decision 

Pacific Northwest Region 

Invasive Plant Program 

Preventing and Managing Invasive Plants 

USDA Forest Service 

Pacific Northwest Region 

States of Oregon and Washington, Including Portions of Del Norte and Siskiyou Counties in 

California, and Portions of Nez Perce, Salmon, Idaho, and Adams Counties in Idaho 

Background 

An estimated 420,000 acres of National Forest System lands in the Pacific Northwest Region 

(Region Six) are currently infested with invasive plants1

. These plants are damaging 

biological diversity and ecosystem integrity within and outside the National Forests. Invasive 

plants lead to many adverse environmental effects, including: displacement of native plants; 

reduction in habitat and forage for wildlife and livestock; loss of threatened, endangered, and 

sensitive species; increased soil erosion and reduced water quality; reduced soil productivity; 

and changes in the intensity and frequency of fires. Invasive plants can spread between 

National Forest System lands to neighboring areas, affecting all land ownerships. 

Current management direction for invasive plants comes from the 1988 Record of Decision 

for Managing Competing and Unwanted Vegetation (1988 ROD) and 1989 Mediated 

Agreement. These documents were integrated into Land and Resource Management Plans 

(Forest Plans) in Region Six and they remain the overriding management direction for use of 

herbicides. The 1988 ROD specified and limited the tools available for the treatment of 

competing and unwanted vegetation, but did not provide administrative mechanisms for 

adapting their requirements and adopting new technologies. For example, herbicides 

approved for use by the Forest Service in the 1988 ROD were developed before 1980. Since 

that time new herbicides have been developed and registered for use. The new herbicides 

have advantages for invasive plant control, such as greater selectivity, less harm to desired 

vegetation, reduced application rates, and lower toxicity to animals and people. Collectively, 

the Forest Plans, as they are currently written, do not provide sufficient direction, nor 

adequate tools for effectively responding to the invasive plant threat. 

 

1 Invasive plants are defined here as “a non-native plant whose introduction does or is likely to cause economic

or environmental harm or harm to human health” (Executive Order 13122). Invasive plants are distinguished

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

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Preventing and Managing Invasive Plants Record of Decision September 2005 

Thus, I identified the need for: 

(1) Forest Plan level management direction that will reduce the extent and rate of 

spread of invasive plants and help prevent new infestations; 

(2) Release from the Forest Plan direction established by the 1988 ROD and 1989 

Mediated Agreement so that new practices, technologies, and formulations of 

herbicides are available for use in invasive plant management; 

(3) An updated list of herbicides available for use by the Forests. 

The Final Environmental Impact Statement for the Invasive Plant Program - Preventing and 

Managing Invasive Plants (FEIS) considered three action alternatives to meet these needs: the 

Proposed Action, Alternative B and Alternative D. The Proposed Action met these needs 

while minimizing risks to non-target organisms and the public. Alternative B increased the 

emphasis on invasive plant prevention and non-herbicide methods of treatment. Alternative D 

increased the emphasis on cost-effectiveness and management flexibility. 

I am selecting the Proposed Action from the FEIS, with modifications. Under this decision, 

invasive plant management direction will be added to all National Forest Plans in the Region 

(see Appendix 1 for full text to be added to Forest Plans). 

 The Proposed Action was identified as the Preferred Alternative in the EIS and remains the 

basis for my Selected Alternative. I am modifying or omitting some standards as presented in 

the FEIS (see explanations below), however the Selected Alternative is similar to the 

Proposed Action in terms of intent and expected outcomes. 

Decision

Under this decision, all National Forests in the Region will be released from direction 

established by the1988 Record of Decision for Managing Competing and Unwanted 

Vegetation (ROD) and 1989 Mediated Agreement for invasive plant management. Parts of 

the 1988 ROD and 1989 Mediated Agreement that apply to unwanted native vegetation are 

not affected by this decision. Invasive plant management direction stemming from these 

documents will be replaced by new direction, in the form of: 

− Desired Future Condition (DFC) statement, 

− 

− 

− 

− 

Goals and objectives statements, 

Standards for preventing the introduction, establishment and spread of invasive plants 

Standards for invasive plant treatment and site restoration 

An inventory and monitoring framework. 

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Preventing and Managing Invasive Plants Record of Decision September 2005 

By separate letter, I am requesting that the Department of Justice take any necessary steps in 

Northwest Coalition for Alternatives to Pesticides, et al v Lyng, CV 83-6272, to confirm 

release from the 1989 Order and Mediated Agreement. 

The purpose of the new management direction is to facilitate subsequent actions to eliminate 

or control invasive plants so that: (1) desired conditions on National Forest System lands can 

be attained; (2) federal land managers’ ability to provide goods and services from the National 

Forest System lands is maintained; and (3) the Forest Service’s ability to cooperate with 

similar efforts across other ownerships is improved. 

Management direction related to invasive plants (beyond the 1988 ROD and 1989 Mediated 

Agreement) is also established by Forest Service Manuals, letters of Regional policy and 

individual Forest Plan standards in Region Six. The Selected Alternative adds new direction, 

but does not vacate existing invasive plant management direction beyond the 1988 ROD and 

1989 Mediated Agreement. Inconsistencies between new and existing standards will be 

reconciled on a Forest-by-Forest basis, as Forest Plans are amended or revised or specific 

projects are planned. 

This decision, in itself, does not approve any site-specific projects. Site-specific treatment 

decisions will be based on location, biology and size of the target invasive plant species, site 

conditions, and integrated resource objectives. Invasive plant treatment projects will be 

subject to future National Environmental Policy Act (NEPA) and Endangered Species Act 

(ESA) analysis before being implemented. 

The Selected Alternative will not be retained as a Regional-scale decision; rather it will 

become part of the individual Forest Plans. Over time, decision makers for individual 

National Forests may modify the decisions that result from this EIS in accordance with 

planning laws, policies and regulations. 

Details of the Decision 

I am adopting the desired future condition statement, and goals and objective statements 

explicitly as written in the Proposed Action in the FEIS. 

I am also adopting most of the standards as presented in the FEIS Proposed Action, with the 

following modifications: 

a) I am selecting Standard 4 from Alternative B, which will adopt weed-free feed 

requirements for all National Forest System lands in the region. Forests will phase

in enforcement of this standard, starting with wilderness areas first. 

b) I am modifying Standard 6 to read: 

Use available administrative mechanisms to incorporate invasive plant prevention 

practices into rangeland management. Examples of administrative mechanisms include, 

but are not limited to, revising permits and grazing allotment management plans, 

providing annual operating instructions, and adaptive management. Plan and implement 

practices in cooperation with the grazing permit holder. 

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Preventing and Managing Invasive Plants Record of Decision September 2005 

c) I am not adopting Standard 10 (adopt OHV policy) or Standard 17 (document 

rationale for herbicide use). 

d) I am modifying Standard 13 to read: 

Native plant materials are the first choice in revegetation for restoration and rehabilitation 

where timely natural regeneration of the native plant community is not likely to occur. 

Non-native, non-invasive plant species may be used in any of the following situations: 1) 

when needed in emergency conditions to protect basic resource values (e.g., soil stability,

water quality and to help prevent the establishment of invasive species), 2) as an interim,

non-persistent measure designed to aid in the re-establishment of native plants, 3) if native 

plant materials are not available, or 4) in permanently altered plant communities. Under 

no circumstances will non-native invasive plant species be used for revegetation. 

e) I am modifying Standard 19 to read: 

To minimize or eliminate direct or indirect negative effects to non-target plants, terrestrial 

animals, water quality and aquatic biota (including amphibians) from the application of 

herbicide, use site-specific soil characteristics, proximity to surface water and local water 

table depth to determine herbicide formulation, size of buffers needed, if any, and 

application method and timing. Consider herbicides registered for aquatic use where 

herbicide is likely to be delivered to surface waters. 

f) I am modifying Standard 20 to read: 

Design invasive plant treatments to minimize or eliminate adverse effects to species and 

critical habitats proposed and/or listed under the Endangered Species Act. This may

involve surveying for listed or proposed plants prior to implementing actions within 

unsurveyed habitat if the action has a reasonable potential to adversely affect the plant 

species. Use site-specific project design (e.g. application rate and method, timing, wind 

speed and direction, nozzle type and size, buffers, etc.) to mitigate the potential for 

adverse disturbance and/or contaminant exposure.

g) I am modifying Standard 23 to read: 

Prior to implementation of herbicide treatment projects, National Forest system staff will 

ensure timely public notification. Treatment areas will be posted to inform the public and 

forest workers of herbicide application dates and herbicides used. If requested, 

individuals may be notified in advance of spray dates. 

I am also making minor edits to the inventory and monitoring framework to clarify that 1) 

effectiveness monitoring will only be required for a representative sample of invasive plant 

treatment projects that may pose a “high risk” to federally listed species; 2) the definition of 

“Interagency” includes but is not limited to the U. S. Forest, U.S. Fish and Wildlife and 

National Marine Fisheries Services; and 3) effectiveness monitoring results will be reported 

on a regular schedule, to be determined as part of the monitoring protocol. 

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Preventing and Managing Invasive Plants Record of Decision September 2005 

In making this decision, I considered each alternative as a whole, as well as each alternative’s 

component parts (desired future condition statement, goals, objectives, standards, inventory 

and monitoring framework). I am blending some components of Alternatives B and D with 

the Proposed Action to increase prevention effectiveness and reduce the potential for 

undesirable consequences on existing land uses, human health and the environment. 

Alternatives Considered 

Four alternatives were considered in detail: No Action, Proposed Action, Alternative B and 

Alternative D. All the alternatives followed the Integrated Weed Management (IWM)2

approach (FEIS Chapter 2.3). The “action alternatives” (Alternatives B and D) were 

developed to meet the underlying need for action and resolve the issues with the Proposed 

Action that were identified in Chapter 1. 

No Action Alternative 

The No Action alternative represented no change from the current direction. Existing Forest 

Plans would have continued to direct invasive plant management. FEIS Chapter 2.3 described 

the existing management direction in detail. 

Projects attempting to follow these plans would continue to be subject to litigation because 

analysis deficiencies associated with these plans would not be resolved. 

I did not choose No Action because it does not meet the need for action, and has greater 

potential adverse effects on human health and the environment than the Selected Alternative. 

No Action would be expected to cost more per acre and be less effective in preventing and 

treating invasive plants. 

Proposed Action 

The Proposed Action represented the Forest Service’s original proposal for managing invasive 

plants. As displayed in the FEIS, the Proposed Action would have applied the weed-free feed 

Standard 4 to Wilderness Areas and Wilderness trailheads in the Region (rather than all 

National Forest System lands). It also would have included two standards (10 and 17) that I 

am not adopting in this decision. Otherwise, the modifications are minor, clarifying edits that 

do not change the intent or effect of the Proposed Action. 

The reasons I decided to adopt Standard 4 from Alternative B, and not adopt Standards 10 and 

17 are explained in the Rationale for the Decision section. 

 

2 Integrated Weed Management (IWM) - An interdisciplinary weed management approach for selecting methods

for preventing, containing, and controlling noxious weeds in coordination with other resource management

activities to achieve optimum management goals and objectives (FSM 2080.5). 

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Preventing and Managing Invasive Plants Record of Decision September 2005 

Alternative B 

Alternative B responded to issues and suggestions received during scoping, including those 

received from a coalition of citizen’s groups interested in prevention and management of 

invasive plants on National Forest System lands. The coalition developed an alternative for 

consideration in this EIS (the “Restore Native Ecosystems Alternative). Many elements of

the coalition’s alternative are incorporated into the action alternatives, particularly Alternative 

B. 

Alternative B would have increased emphasis on reducing conditions related to land uses and 

activities on National Forest System lands that contribute to invasive plant introduction, 

establishment and spread. The standards included in Alternative B tended to be stricter and 

less flexible than in the other alternatives. 

Under Alternative B, invasive plant treatment tools associated in the scientific literature with 

human and/or ecological harm would have been avoided where possible and herbicides would 

have been a “tool of last resort3

.” 

Many members of the public advocated that I select Alternative B due to its precautionary 

approach and emphasis on non-herbicide treatment methods. I acknowledge that Alternative 

B would have increased emphasis on prevention and potentially reduced rates of spread more 

than the Selected Alternative (see FEIS Chapter 4.2). Specifically, Standards 2, 5, 6, 7, 9, and 

10 in Alternative B would likely have increased prevention effectiveness as compared to 

Selected Alternative. I did not choose to adopt all of these prevention standards from

Alternative B because of their potential to result in unintended adverse consequences to land 

management activities and land uses (see FEIS Chapter 4.6). 

I also did not select Alternative B because it deviates from IWM principles to “select methods 

for preventing, containing, and controlling noxious weeds in coordination with other resource 

management activities to achieve optimum management goals and objectives (FSM 2080.5).” 

Invasive plant treatments would have cost more per acre under Alternative B than any other 

alternative considered in detail. Among the alternatives considered in detail, land 

management activities were most likely to be affected by restrictions based on invasive plant 

management concerns under Alternative B. I do not believe that Alternative B represents the 

appropriate approach to invasive plant management because its cost is too high, especially 

given its lack of treatment effectiveness. 

 

3 “Tool of last resort” means that tool will be used only if all other methods for managing invasive plants are 

ineffective or too expensive.

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Preventing and Managing Invasive Plants Record of Decision September 2005 

Alternative D 

Alternative D was similar to the Proposed Action with greater emphasis on maintaining 

planning and operational flexibility at the Forest/Ranger District level. Greater flexibility was 

intended to reduce the treatment costs and impacts on land uses and user groups. 

Alternative D also included the use of two effective, less expensive and potentially more risky 

herbicides (2,4-D and dicamba). In addition, as Alternative D placed greater emphasis on 

reducing treatment costs, the use of broadcast and aerial application of herbicides was

expected to be greatest under Alternative D. 

Many members of the public advocated I select Alternative D because it would have been the 

most cost-effective alternative. However, Forest Service risk assessments consistently place 

2,4-D and dicamba in higher risk categories for human beings, large mammal and birds (see 

FEIS Chapter 4.4 and 4.5). 

At the regional scale, I am not aware of any situations that cannot be otherwise effectively 

treated. Site-specific Forest Plan amendments could be contemplated to allow use of these 

herbicides if local land managers find them necessary. Such amendments would be projectspecific and analyzed in future NEPA decisions. 

Table 1 displays key features of the alternatives. 

Table 1 Key Features of the Alternatives 

Key Feature No Action Proposed Action Alternative B Alternative D 

Overall 

Approach 

Adaptive 

management 

focusing on

prevention, early 

detection, and 

early treatment 

of invasive 

plants. 

Adaptive 

management, with

increased emphasis 

on prevention,

updated treatment

tools, restoration and 

long-term site 

management goals. 

Similar to the 

Proposed Action, 

increases the 

emphasis on

reducing the 

conditions that

contribute to

invasive plants. 

Similar to the 

Proposed Action, 

with a less 

“prescriptive”

approach to 

prevention and more

flexibility in the use 

of herbicides. 

Inventory 

Emphasizes 

early detection. 

Emphasizes early 

detection and

requires inventories 

be consistent with

nationally accepted 

data structures. 

Same as the 

Proposed Action. 

Same as the 

Proposed Action. 

Prevention 

Direction for 

prevention is 

provided

primarily by the 

1988 EIS/ROD 

and the 1989

Mediated 

Agreement 

Requires the use of a 

suite of invasive 

plant prevention 

standards. 

Similar to the 

Proposed Action 

with additional,

more prescriptive

prevention 

standards. 

Similar to the 

Proposed Action, 

with fewer and less 

prescriptive 

prevention standards.

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Preventing and Managing Invasive Plants Record of Decision September 2005 

Table 1 Key Features of the Alternatives 

Key Feature No Action Proposed Action Alternative B Alternative D 

Treatment 

Treatment 

methods, 

including five 

herbicides. 2,4-

D is a tool of 

“last resort”. 

Treatment methods

include ten 

herbicides, but not

2,4-D or dicamba. 

Emphasis is on 

non-chemical 

methods. 

Includes four 

herbicides and they 

are considered

“tools of last

resort”. 

Treatment methods

include twelve 

herbicides, including

2,4-D. 

Restoration 

Favors the use of

native plants and 

allows the use of 

non-native plants

in certain 

situations. 

Favors the use of

native plants for 

restoration, allows 

use of non-invasive 

non-native plants in 

certain situations. 

Requires use of

native species for 

restoration, except 

as an intermediate 

step toward native 

restoration. 

Requires the use of

plant species that do 

not invade or persist.

Rationale for the Decision 

The Selected Alternative as a Whole 

I have decided to select the Proposed Action with modifications (hereby referred to as the 

Selected Alternative) because it provides appropriate and effective Forest-level management 

direction regarding prevention practices while maintaining management flexibility; it provides 

updated treatment options; and it emphasizes restoration and long-term site management 

goals. Selected Alternative is expected to reduce the extent and rate of spread of invasive 

plants and help prevent new infestations. It requires that inventories be consistent with 

nationally accepted data structures to provide for early detection, therefore increasing our 

ability to allow for more timely response when populations are small. It restricts herbicide 

use to formulations containing one or more of ten active ingredients - chlorsulfuron, 

clopyralid, glyphosate, imazapic, imazapyr, metsulfuron methyl, picloram, sethoxydim,

sulfometuron methyl, and triclopyr. These herbicide formulations, used in accordance with 

the standards, pose relatively low risks to people and non-target organisms. 

The FEIS stated the factors for my decision: 

1. How well the alternative meets the underlying need for action, 

2. The potential effects to human health and the environment, 

3. The effects on existing uses/management activities on the National Forest System

lands, and 

4. The associated costs. 

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Preventing and Managing Invasive Plants Record of Decision September 2005 

Based on the FEIS analysis, I find that the standards associated with the Selected Alternative 

a) adequately address the need for management direction that will prevent the introduction, 

establishment and spread of invasive plants; b) include an appropriate list of herbicides for 

use on National Forest System lands in Region Six; and c) release land managers from 

complying with the 1988 ROD and 1989 Mediated Agreement when dealing with invasive 

plants. 

I am choosing the prevention standards in the Selected Alternative because I believe they will 

result in reduced rates of spread of invasive plants, while still maintaining the Forest Service’s 

ability to provide for existing uses and management activities on National Forest System 

lands. 

I am choosing the specific list of herbicides in the Selected Alternative because these pose 

relatively low risk to people and the environment. I am adopting treatment standards that will 

further protect human health and non-target organisms. 

Another of my decision factors is the monetary cost of the invasive plant treatment program. 

Average costs per acre of treatment was estimated in the FEIS and used to predict acreage 

treated at a static budget (Chapter 4.6.2). An average treatment acre would cost 

approximately $160 under the Selected Alternative, as compared to $120 per acre under 

Alternative D (lowest cost alternative). Costs were predicted to be higher under No Action 

($192 per acre) and Alternative B ($240 acre). The Selected Alternative provides a balance 

between cost-effectiveness and risk of adverse effects. 

Table S-2 from the FEIS is included as Appendix 2 in this Record of Decision. Table S-2 

compares specific aspects of the alternatives in terms of the decision factors. The following 

sections provide rationale for my decision based on these decision factors. 

Desired Future Condition, Goals and Objectives 

The Selected Alternative includes the Desired Future Condition, Goals and Objectives 

statements as written in the Proposed Action in the FEIS. These statements emphasize 

prevention of invasive plant introduction, establishment and spread; protection of ecosystems 

and human health; and collaboration with our partners and the public. The full text to be 

added to Forest Plans in the Region is shown in Appendix 1. 

The Desired Future Condition Statement and Goals and Objectives were similar between the 

Proposed Action and action alternatives. Alternative D differed from the other action 

alternatives by not including an objective to reduce reliance on herbicide use over time. I am

not choosing Alternative D, because I believe this objective is appropriate given the strong 

public concern about herbicide use. I am optimistic that the new tools provided by my

decision will lead to more effective treatments that will reduce the need to for repeated 

herbicide use and will ultimately reduce reliance on herbicides. 

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Preventing and Managing Invasive Plants Record of Decision September 2005 

I did not choose the No Action Alternative because it would not have included new Desired 

Future Condition, Goal, or Objective Statements and thus would not have clarified the 

reasoning behind the standards. No Action would not have contributed to meeting the need 

for new management direction regarding invasive plants (decision factor 1). 

Prevention Standards 

Prevention Standard 1 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action/

Selected Alternative 

Alternative B Alternative D 

1 

(Objectives 

1.1, 1.2, 2.3,

2.4, 2.5)

Prevention of invasive plant

introduction, establishment 

and spread will be addressed 

in watershed analysis; roads 

analysis; fire and fuels 

management plans, Burned

Area Emergency Recovery 

Plans; emergency wildland 

fire situation analysis; 

wildland fire implementation

plans; grazing allotment 

management plans, recreation

management plans, vegetation

management plans, and other 

land management assessments. 

Same as Proposed Action, plus:

These documents will address the 

conditions that spread invasive 

plants and emphasize 

maintaining/restoring healthy

ecosystems as the first line of 

defense against their spread. 

Same as Proposed 

Action. 

Rationale for Selected Standard 

I am selecting Prevention Standard 1 from the Proposed Action because it increases 

prevention effectiveness compared to No Action (no standard), but avoids cost increases or 

land use limitations possible with Alternative B (FEIS Chapters 4.6.3). 

I did not choose No Action because it would not contribute to meeting the need for action 

(decision factor 1). I did not choose Alternative B because the words: “emphasize healthy 

ecosystems as the first line of defense against their [invasive plants] spread” have the 

potential to make compliance with this standard difficult for land managers. There is no fully 

accepted definition of a healthy ecosystem. Restoration of healthy ecosystems cannot be 

promised at all spatial and temporal scales; for instance administrative sites, quarries and road 

corridors are examples of areas where restoration of a healthy ecosystem may not be possible 

or desired. Thus, I am not choosing Standard 1 from Alternative B because its additional 

requirement could lead to adverse effects on existing land uses or management activities, or 

increase the costs of invasive plant management (decision factors 3 and 4). These additional 

requirements do substantially change the intent or effectiveness of the standard in preventing 

invasive plants (FEIS Chapter 4.2.3). 

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Preventing and Managing Invasive Plants Record of Decision September 2005 

Prevention Standard 2 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action/

Selected Alternative 

Alternative B Alternative D 

2 

(Objectives 

1.1, 1.2, 2.3)

Actions conducted or

authorized by written permit 

by the Forest Service that 

will operate outside the 

limits of the road prism

(including public works and

service contracts), require 

the cleaning of all heavy 

equipment (bulldozers,

skidders, graders, backhoes, 

dump trucks, etc.) prior to

entering National Forest 

System Lands. This 

standard does not apply to

initial attack of wildland

fires, and other emergency

situations where cleaning 

would delay response time. 

Actions conducted or authorized by written

permit by the Forest Service that will 

operate outside the limits of the road prism

(including public works and service 

contracts), require the cleaning of all 

equipment and vehicles prior to entering

National Forest System land for all projects, 

and before leaving the project site, when

operating in areas where invasive plants

have been identified as present at a level

where transport of invasive plant seed or 

vegetation propagules (root fragments) is

likely and a concern. 

This standard would not apply to initial 

attack of wildland fires, and other 

emergency situations where cleaning would 

delay response time. 

Same as 

Proposed

Action. 

Rationale for Selected Standard 

I am selecting Prevention Standard 2 from the Proposed Action because it increases 

prevention effectiveness compared to No Action (no standard), but avoids but avoids potential 

adverse effects on land use activities associated with Alternative B. I recognize that Standard 

2, as written under Alternative B, was ranked as having higher effectiveness than the 

Proposed Action. However, this standard may be difficult to implement or enforce (FEIS 

Chapters 4.2.3, 4.6.3). These difficulties could result in reduced effectiveness of this 

standard. 

Wash stations are not currently available away from populated area and administration costs 

may be cost prohibitive (for instance, contract field inspection to ensure washing is done 

between sites). Until such stations are available, this standard in Alternative B may not be 

operationally feasible. 

The costs of implementing this standard could lead to less heavy equipment work because 

costs may become prohibitive. Administrative costs for timber, other vegetation 

management, roads, livestock grazing, fire, fuels, recreation, and minerals and mining 

programs and projects in infested areas under Alternative B could increase to the point where 

programs and projects could not be funded. 

I am not adopting this standard from Alternative B because the additional expense and

implementation (decision factors 3 and 4) outweigh its potential prevention value. At the 

project-specific scale, managers have the option to consider stronger prevention practices 

such as washing equipment before leaving infested sites. 

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Preventing and Managing Invasive Plants Record of Decision September 2005 

Prevention Standard 3 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action/

Selected Alternative 

Alternative 

B 

Alternative 

D 

3 

(Objectives 

1.1, 2.3) 

Use weed-free straw and mulch for all projects, conducted 

or authorized by the Forest Service, on National Forest 

System Lands. If State certified straw and/or mulch is not 

available, individual Forests should require sources 

certified to be weed free using the North American Weed 

Free Forage Program standards (see Appendix O) or a 

similar certification process. 

Same as 

Proposed 

Action. 

Same as 

Proposed 

Action. 

Rationale for Selected Standard 

I am selecting Prevention Standard 3 from the Proposed Action because it increases 

prevention effectiveness (decision factor 1) compared to No Action. This standard would 

serve to further minimize the potential spread of non-natives from mulching. Tons of 

straw/mulch potentially providing invasive seed could be eliminated (FEIS Chapter 4.2.3). 

This standard is not expected to be costly (FEIS Chapter 4.2.6) because weed-free straw and 

mulch is widely available and in use across the Region. Most ground disturbing projects 

already have similar requirements for weed free straw and mulch in place. 

Prevention Standard 4 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action Alternative B /

Selected Alternative 

Alternative D 

4 

(Objectives 

1.1, 2.5) 

Use only pelletized or 

certified weed free feed in 

wilderness and wilderness 

trailheads. If state 

certified weed free feed is 

not available, individual 

Forests should require feed 

certified to be weed free 

using North American 

Weed Free Forage Program

standards or a similar 

certification process. 

Use only pelletized or certified weed 

free feed on all National Forest 

System lands. If state certified weed 

free feed is not available, individual 

Forests should require feed certified 

to be weed free using North American 

Weed Free Forage Program standards 

or a similar certification process. 

Choose weed-free project staging 

areas, livestock and packhorse 

corrals, and trailheads. 

No standard. 

 

12
Preventing and Managing Invasive Plants Record of Decision September 2005 

Rationale for Selected Standard 

I am selecting Prevention Standard 4 from Alternative B because it increases prevention 

effectiveness compared to all other alternatives (decision factor 1). As written for Alternative 

B, this standard was ranked as having the highest effectiveness of all alternatives because of 

its comprehensive coverage of National Forest System lands (FEIS Chapter 4.2.3). 

Many pack stock users already comply with weed-free feed requirements as a part of special 

use permits on National Forests within and outside the Region. In Oregon, Wallowa County 

has a working weed-free feed certification program and the Eagle Cap Ranger District and 

Hells Canyon National Recreation Area also prohibit use of uncertified weed free feed. 

Weed-free feed certification is also currently available in the three states that share borders 

with Region Six, as well as 9 other western states. The Forest Service requires that only 

certified weed free seed be used on National Forest System lands in Idaho and Nevada. 

California is currently working on a certification program for National Forest System lands. 

I acknowledge this standard may have some adverse effects on pack stock users by requiring 

weed-free feed (currently difficult to obtain) or pelletized feed (difficult for some pack 

animals to digest). Weed free feed requirements can increase the cost of using pack stock 

because weed free feed is generally more expensive to purchase and distribution locations for 

weed free feed are limited, potentially resulting in additional purchase, travel and 

transportation costs to the user. These issues are discussed in FEIS Chapters 4.6.3 and 4.6.5. 

I am not selecting any other alternative because I believe it is important to eliminate spread of 

invasive plants into remote areas that can occur from pack stock (includes horse or mule trail 

riding, as well as livestock used for packing) use. Currently, invasive plants can find their way 

onto National Forest System lands in weed-infested feed brought along for pack animals. 

These seeds are often deposited near disturbed areas such as trailheads, trails, watering holes, 

roads, horse camps, and other disturbed areas where invasive plants are best suited to grow. 

Invasive plant seeds can also be spread in the manure of pack animals (FEIS Chapter 3.1.3). 

I understand that many people, particularly those who recreate with pack stock, are concerned 

about establishing weed-free feed requirements in National Forests in the Region. I also 

know that many people are worried that this decision will increase the cost of using pack 

stock. I recognize that weed-free feed is generally more expensive to purchase and 

distribution locations for weed free feed are limited, potentially resulting in additional 

purchase, travel and transportation costs to the user. Many pack stock users are concerned 

about how difficult this may be to implement and enforce. Public comments also refer to the 

lack of current weed-free feed certification programs in Oregon and Washington. Following 

are excerpts of public comments regarding weed-free feed requirements: 

 “A simple system needs to be instituted to get the proper certification of hay. For 

example have the County Agent certify a local farmer's fields. Then a certificate 

would go with the hay sold off these fields. Many horses cannot tolerate the pelleted 

feed causing colic and behavioral problems.” 

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Preventing and Managing Invasive Plants Record of Decision September 2005 

“(1) Oregon State has no certification program for noxious weed free hay. Agencies, 

which I have contacted, have no interest in developing such programs at present. 

These include the county extension agencies and the Oregon Seed Certification 

Program. (2) Wallowa County uses Idaho's certification. Some hay is available 

sometimes in Wallowa County. Some alfalfa hay is trucked in from Idaho and 

available locally in La Grande. This is very limited availability compared to needs at 

the many trail heads. No certified grass hay which some of us horsemen feed instead 

of alfalfa is available that I know of at present. (3) Most horsemen will be very 

reluctant to feed the available pelleted or cubed feed rather than hay at trailheads, as 

equines do not change diets and forms of feed readily. 

Once in the wilderness area, processed feeds usually are used only to supplement the 

natural forages as needed. Therefore, I find the requirement of certified noxious weed 

free feeds unreasonable to implement until certified hay, both alfalfa and grass is 

commonly available at prices close to good quality noxious weed free hay currently 

available in the state of Oregon.” 

“Our members are concerned as there are currently no certifying agents/programs for 

“weed free feed" or "weed free hay" available in the state of Oregon. We understand 

and practices the use of "weed free feed" when required. We want the Forest Service 

to note that before this recommendation should go into effect a system for certifying 

"weed free feed" that includes hay must be established. The development of certifying 

system needs to set reasonable standards to reduce the potential of "weed free feed" 

production becoming too costly for individuals to purchase. If this recommendation 

became policy before the establishment of available certifying agents it could create a

hardship for not only our members, but also the many other equine organizations 

through out the Pacific Northwest Region.” 

“Requiring horse owners to use weed-free feed will clearly increase the cost of using

saddle and pack stock because such feed is more expensive to produce and distribution 

locations are limited, resulting in additional purchase and transportation costs to the 

riders and stock providers. This additional requirement will also increase the cost to 

the Forest Service for enforcement of the weed-free feed standards.” 

In consideration of these viewpoints, enforcement of weed-free feed requirements standard 

will be phased in as appropriate certification processes and weed-free feeds become

reasonably available. This will allow pack stock users time to comply with the standard, and 

will allow time for weed-free feed certification processes to become established. 

I intend to work with user groups to ensure that adverse effects on them are minimized. I will 

work with the counties or states in the region to develop weed free feed certification 

programs. I intend to enforce the pelletized or weed-free feed standard within wilderness 

areas and wilderness trailheads first, then expand enforcement to other National Forest 

System lands, as processes to certify weed-free feed become available. 

14
Preventing and Managing Invasive Plants Record of Decision September 2005 

This is the final NEPA decision related to this standard. Closure Orders on individual Forests 

will trigger enforcement of the weed-free feed requirements. Closure orders requiring

pelletized or weed-free feed for all Wilderness Areas and Wilderness trailheads in the Region 

will be in place as of January 1, 2007, providing phase-in time for user groups. Use of 

pelletized and/or weed-free feed will be encouraged throughout the National Forest and 

enforced once closure orders have been filed. Closure orders for remaining National Forest 

System lands in the Region will be filed on Forest-by-Forest basis as certified weed-free feed 

becomes available. 

Prevention Standard 5 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action /

Selected Alternative 

Alternative B Alternative D 

5 

(Objective 

2.2) 

No corollary standard. 

(Addressed as Objective 

2.2 and in the USDA 

Forest Service Guide to 

Noxious Weed 

Prevention Practices) 

Consistent with project objectives, 

retain native vegetation in an around 

project locations and minimize 

creating soil conditions that promote 

the establishment and spread of 

invasive plants. 

Same as 

Proposed 

Action 

Rationale for Selected Standard 

I am not selecting this standard (only associated with Alternative B) because it would have 

required that forest canopy be retained and soil disturbance minimized. I recognize this could 

have increased prevention effectiveness as compared to the Proposed Action, but potentially 

at the expense of other land management objectives. This standard may have limited the 

Forest Service’s ability to manage fuels in response to changing fire condition classes and 

conflict with achieving the goals of the Healthy Forests Restoration Act of 2003 (FEIS Table 

4-51). 

 I am adding Objective 2.2 to Forest Plans across the Region Six: “Retain native vegetation 

consistent with site capability and integrated resource management objectives to suppress 

invasive plants and prevent their establishment and growth.” This objective is intended to 

result in adequate protection of native vegetation. 

15
Preventing and Managing Invasive Plants Record of Decision September 2005 

Prevention Standard 6 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Selected Alternative Proposed Action Alternative B Alternative 

D 

6 

(Objectives 

1.1, 5.1, 

5.3) 

Use available administrative 

mechanisms to incorporate 

invasive plant prevention 

practices into rangeland 

management. Examples of 

administrative mechanisms 

include, but are not limited to, 

revising permits and grazing 

allotment management plans, 

providing annual operating 

instructions, and adaptive 

management. Plan and 

implement practices in 

cooperation with the grazing 

permit holder. 

Through annual 

operating 

instructions, and the 

revision of grazing 

allotment 

management plans, 

incorporate invasive 

plant prevention 

practices that reduce 

the spread of invasive 

plants. Plan and 

implement practices 

in cooperation with 

the grazing permit 

holder. 

Same as Proposed 

Action, plus: 

Document 

consideration of 

the prevention 

practices included 

in the grazing 

management 

section of the 

USDA Forest

Service Guide to 

Noxious Weed 

Prevention 

Practices, 

(Appendix E). 

Same as 

Proposed 

Action. 

Rationale for Selected Standard 

The Selected Alternative is similar to the Proposed Action/Alternative D, and has the same

intent and impact. I am modifying the wording of this standard to improve its clarity and 

consistency with rangeland management direction. I am selecting this standard because 

incorporating invasive plant prevention practices into rangeland permit management will help 

reduce the risk of introduction, establishment and spread of invasive plants from grazing (as 

compared to No Action). I recognize that this standard may result in changes in grazing 

locations, timing, intensity, and outputs (FEIS Chapter 4.6.3). These adjustments would be 

implemented using existing rangeland administration mechanisms (FSH 2209.13). 

Alternative B would have additionally required that the consideration of the USDA Forest 

Service Guide to Noxious Weed Prevention Practices (Appendix E) be documented. The 

FEIS found that Alternative B would be more likely to effectively reduce invasive plants on 

grazing allotments than the alternative version of this standard (FEIS Chapter 4.2.3). 

However, I believe that requiring documentation of managers’ consideration of the USDA 

Forest Service Guide to Noxious Weed Prevention Practices could actually be counterproductive to preventing the introduction, establishment and spread of invasive plants 

(decision factor 1). The guide may change over time, or may not be appropriate under all 

circumstances. I do not believe the additional documentation requirement would lead to 

better rangeland management practices. 

16
Preventing and Managing Invasive Plants Record of Decision September 2005 

Prevention Standard 7 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action/

Selected Alternative 

Alternative B Alternative D 

7 

(Objectives 

1.1, 1.2, 

1.3) 

Inspect active gravel, fill, sand 

stockpiles, quarry sites, and borrow 

material for invasive plants before 

use and transport. 

Treat or require treatment of 

infested sources before any use of 

pit material. 

Use only gravel, fill, sand, and rock 

that is judged to be weed free by

District or Forest weed specialists. 

Same as Proposed Action, 

plus: 

Strip and stockpile and treat 

infested sources before any

use of material. 

Inspect active gravel, fill, 

sand stockpiles, quarries, 

and borrow material 

annually for invasive 

plants. 

Same as 

Proposed 

Action. 

Rationale for Selected Standard 

I am adopting the Proposed Action for this standard because it will ensure that rock sources 

are appropriately inspected and treated before use. This will increase the effectiveness of this 

prevention practice compared to No Action (no standard). 

Alternative B would have required that rock quarries and other sources be inspected annually. 

This would have increased the likelihood that new infestations would be caught in early 

stages since a system of stockpiling contaminated fill for treatment will be in place. I

acknowledge Alternative B was more likely to prevent invasive plant spread than the 

Proposed Action/Alternative D (FEIS Chapter 4.2.3). However, I weighed the value of this 

standard in prevention (decision factor 1) against the implementation costs (decision factor 5). 

I am choosing not to adopt the Alternative B version of this standard because I believe the 

Selected Alternative will adequately prevent this vector of invasive plant spread and the 

expense of requiring annual inspections, stripping and stockpiling could become exorbitant 

(FEIS Chapter 4.6.3). I do not expect to receive the funding necessary to comply with such a 

standard. 

17
Preventing and Managing Invasive Plants Record of Decision September 2005 

Prevention Standard 8 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action/

Selected Alternative 

Alternative B Alternative D 

8 

(Objectives 

1.1, 1.2, 

5.1) 

Conduct road blading,

brushing and ditch 

cleaning in areas with 

high concentrations of 

invasive plants in 

consultation with 

District or Forest-level 

invasive plant

specialists, incorporate 

invasive plant

prevention practices as 

appropriate. 

Same as Proposed Action, plus: 

Where possible, postpone this work until

the invasive plants have been treated. In 

situations where road safety 

considerations dictate action, work from

the edges of the infestation toward the 

center to avoid spreading invasive plants

to relatively uninfested areas. Inspect and 

clean road graders, mowers, and other 

road blading, brushing and ditch cleaning 

equipment after operating in infested 

areas to remove plant seed and 

propagules. 

Same as 

Proposed 

Action. 

Rationale for Selected Standard 

I am selecting the Proposed Action because it elevates the importance of considering invasive 

plants in planning for road maintenance activities compared to No Action (no standard), while 

allowing flexibility that best suits local site conditions, ecology, and desired future conditions. 

All action alternatives would better prevent invasive plants than No Action (decision factor 

1). Alternative B includes additional language highlighting particular practices, but does not 

change intent or effects of this standard as quantifiable at the Regional level (FEIS Chapter 

4.2). I am not choosing Alternative B because I prefer the flexibility afforded by the 

Proposed Action (decision factor 4). 

Prevention Standard 9 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed

Action/Selected

Alternative 

Alternative B Alternative D 

9 

(Objectives 

1.1, 2.4) 

No standard. Close or decommission non-essential roads 

where roads analysis indicates that the presence, 

type, use and location of roads may increase the 

introduction and spread of invasive plants; and 

such introduction adversely affect native plant 

and animal species and ecosystem function. 

Retain administrative access as needed for 

invasive plant treatment and site restoration. 

No standard. 

18
Preventing and Managing Invasive Plants Record of Decision September 2005 

Rationale for Selected Standard 

I am not adopting this standard in the Selected Alternative. I recognize that the Selected 

Alternative may be less effective in preventing the spread of invasive plants because it lacks 

this standard (FEIS Chapter 4.6.3). I decided against adopting Standard 9 because its 

potential adverse effects on access and road management (decision factor 4) outweighed the 

potential benefit in reducing the spread of invasive plants (decision factor 2). I am concerned 

that the requirements in Standard 9 could elevate invasive plant management beyond other 

considerations. Consideration of this vector of invasive plant spread in roads analysis is 

required per Standard 1. I believe Standard 1 provides sufficient emphasis on invasive plant 

management in roads management, along with existing management direction regarding road 

closure and decommissioning. 

Prevention Standard 10 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action Alternative B Alternative D/ 

Selected Alternative 

10 

(Objectives 

1.1, 2.4, 

2.5) 

Require the establishment of a system of 

roads, trails, and areas designated for motor 

vehicle use; and prohibit the use of motor 

vehicles off the designated system that is not 

consistent with the classes of motor vehicles 

and if applicable, the time of year, designated 

for use. 

Same as 

Proposed 

Action. 

No standard. 

Rationale for Selected Standard 

I am not adopting the standard as written for the Proposed Action/Alternative B because it has 

not yet been adopted at the national scale. I am concerned that implementing this standard at 

the Regional scale may result in future conflicts between regional and national management 

direction, timing and/or interpretation. The FEIS described how the national policy would 

contribute to preventing the introduction, establishment and spread of invasive plants (FEIS 

Chapter 4.2.3). While I recognize that this would increase the effectiveness of the invasive 

plant management program (decision factor 1), this benefit is outweighed by the potential for 

adverse effects on land management activities from differences in the draft and final policy or 

other possible conflicts. 

19
Preventing and Managing Invasive Plants Record of Decision September 2005 

Treatment/Restoration Standards 

Treatment Restoration Standard 11 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action Alternative B Alternative D 

11 

(Objectives 

1.5, 5.1) 

Prioritize infestations of invasive plants for 

treatment at the landscape, watershed or

larger multiple forest/multiple owner scale. 

Same as 

Proposed 

Action. 

Same as Proposed 

Action. 

Rationale for Selected Standard 

I am selecting Standard 11 from all action alternatives because it ensures that the most 

important and urgent needs are met first, and that preferred treatments methods are 

appropriately prioritized. Deciding what and where treatments should occur first, given 

limited budgets, is a crucial first step in the integrated weed management program (decision 

factor 1). Current management direction (No Action) does not require that priorities be 

addressed. Without prioritization, treatments may be less effective in meeting land 

management goals and/or supporting cooperative programs (FEIS Chapter 4.2.3). 

Treatment Restoration Standard 12 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action/Selected Alternative Alternative B Alternative D 

12 

(Objectives 

1.1, 5.1) 

Develop a long-term site strategy for

restoring/revegetating invasive plant sites 

prior to treatment. 

Same as 

Proposed 

Action. 

Same as Proposed 

Action. 

Rationale for Selected Standard 

I am selecting Standard 12 (same in all action alternatives) because this ensures that planning 

for revegetation or restoration needs is completed early in the process better than No Action 

(no standard). Long-term planning allows for timely development of adequate quantities of 

non-invasive plant materials for site restoration. Having the materials on hand immediately 

after treatment could make the difference in effectively deterring re-infestation (FEIS Chapter 

4.2.3). This will also help reduce the need for repeated herbicide or other treatments (decision 

factors 1 and 2). 

20
Preventing and Managing Invasive Plants Record of Decision September 2005 

Treatment Restoration Standard 13 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Selected Alternative Proposed Action Alternative B Alternative D

13 

(Objectives 

1.1, 1.4) 

Native plant materials are 

the first choice in 

revegetation for restoration

and rehabilitation where 

timely natural regeneration

of the native plant 

community is not likely to

occur. Non-native, noninvasive plant species may

be used in any of the 

following situations: 1)

when needed in emergency 

conditions to protect basic 

resource values (e.g., soil 

stability, water quality and 

to help prevent the 

establishment of invasive

species), 2) as an interim,

non-persistent measure 

designed to aid in the reestablishment of native 

plants, 3) if native plant

materials are not available, 

or 4) in permanently altered 

plant communities. Under 

no circumstances will nonnative invasive plant species

be used for revegetation.

Native plant materials are 

the first choice in 

revegetation for 

restoration and 

rehabilitation where 

timely natural 

regeneration of the native 

plant community is not

likely to occur. Nonnative, non-invasive plant 

species may be used

when: 1) needed in 

emergency conditions to

protect basic resource 

values (e.g., soil stability, 

water quality and to help 

prevent the establishment 

of invasive species), 2) as 

an interim, non-persistent 

measure designed to aid 

in the re-establishment of

native plants, 3) native 

plant materials are not 

available, and 4) in

permanently altered plant 

communities. Under no

circumstances will nonnative invasive plant

species be used. 

Use local 

native seed

and seedlings

in revegetation 

of invasive 

plant sites, fire 

lines and 

burned areas. 

If native 

seeds/plants 

are not 

available, 

revegetation 

projects will 

rarely be

undertaken

until native

plant seed or

plants become

available, 

except as an

intermediate 

step toward 

native 

restoration. 

In revegetation 

efforts use

plant species 

that will not 

invade or

persist. Use 

persistent nonnatives, such

as crested 

wheatgrass, 

clover and

range alfalfa, 

if necessary, 

on degraded

sites, where 

less persistent

species have

been shown to 

be 

unsuccessful 

in competing 

with invasive

plants. 

Rationale for Selected Standard 

The Selected Alternative is similar to the Proposed Action, but includes minor clarifying 

modifications. I am selecting this standard because it will ensure non-native plants are used 

appropriately, thus reducing spread of invasive plants better than No Action (no standard) or 

Alternative D. I am not selecting No Action/Alternative D for this standard because it does 

not adequately emphasize the use of native plants where possible, thus reducing the 

effectiveness of invasive plant treatment and site restoration (decision factor 1). 

Alternative B would not have explicitly acknowledged that non-natives serve a purpose 

towards restoration. Non-native, non-invasive species revegetation with desirable non-natives 

can be appropriate for disturbed areas or in areas needing immediate erosion control or 

revegetation. 

21
Preventing and Managing Invasive Plants Record of Decision September 2005 

Mixing non-persistent, non-native annuals with native species, for example, may rapidly 

control erosion and reduce invasion potential until slower germinating natives occupy a site. 

The restrictive language in Alternative B may have resulted in delays and/or reduced 

effectiveness in restoration (Chapter 4.2.3). 

Thus, I am not choosing Alternative B because it would be less effective in 

preventing/treating invasive plants and restoring treated areas (decision factor 1). 

Treatment Restoration Standard 14 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action/Selected Alternative Alternative B Alternative D 

14 

(Objectives 

1.4, 4.1, 

4.2) 

Use only APHIS and State-approved biological 

control agents. Agents demonstrated to have direct 

negative impacts on non-target organisms would not

be released. 

Same as 

Proposed 

Action. 

Same as 

Proposed 

Action. 

Rationale for Selected Standard 

I am selecting this standard from the Proposed Action (applied to all action alternatives) 

because it reduces the chances of unintended non-target impacts because of the APHIS testing 

procedures. It also provides for adaptive management if unexpected non-target impacts are 

discovered. Adopting this standard will address decision factors 1 and 2 better than No 

Action (no standard). 

Treatment Restoration Standard 15 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action/Selected Alternative Alternative B Alternative D 

15 

(Objectives 

1.4, 3.1, 

4.1, 4.2) 

Application of any herbicides to treat invasive plants 

will be performed or directly supervised by a State or 

Federally licensed applicator. All treatment projects 

that involve the use of herbicides will develop and 

implement herbicide transportation and handling 

safety plans. 

Same as 

Proposed 

Action. 

Same as 

Proposed 

Action. 

Rationale for Selected Standard 

I am selecting this standard from the Proposed Action (also would have applied to all action 

alternatives) because this measure will ensure that herbicides are properly and safely applied 

better than No Action (no standard). This addresses decision factor 2 better than No Action. 

22
Preventing and Managing Invasive Plants Record of Decision September 2005 

Treatment Restoration Standard 16 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action/

Selected Alternative 

Alternative B Alternative D 

16 

(Objectives 

1.4, 3.1, 

4.1, 4.2) 

Select from herbicide formulations 

containing one or more of the

following 10 active ingredients: 

chlorsulfuron, clopyralid, 

glyphosate, imazapic, imazapyr, 

metsulfuron methyl, picloram, 

sethoxydim, sulfometuron methyl, 

and triclopyr. Mixtures of 

herbicide formulations containing

3 or less of these active ingredients 

may be applied where the sum of 

all individual Hazard Quotients for 

the relevant application scenarios 

is less than 1.0. 3

All herbicide application methods 

are allowed including wicking, 

wiping, injection, spot, broadcast

and aerial, as permitted by the 

product label. Chlorsulfuron,

metsulfuron methyl, and 

sulfometuron methyl will not be

applied aerially. The use of

triclopyr is limited to selective 

application techniques only (e.g.,

spot spraying, wiping, basal bark, 

cut stump, injection). 

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.

Select from herbicide 

formulations containing one

or more of the following 4 

active ingredients: 

clopyralid, glyphosate,

sethoxydim, and triclopyr. 

No mixture of these 

herbicide formulations is 

permitted.

All herbicide application

methods are allowed 

including wicking, wiping, 

injection, spot, broadcast

and aerial, as permitted by

the product label. The use 

of triclopyr will be limited

to selective application

techniques only (e.g. spot

spraying, wiping, basal

bark, cut stump, injection). 

Additional herbicides, with 

the exception of picloram, 

sulfonylurea herbicides and

acetolactate synthaseinhibiting herbicides, may 

be added in the future at

either the Forest Plan or

project level through 

appropriate risk analysis and 

NEPA/ESA procedures.

Select from herbicide 

formulations containing one

or more of the following 12

active ingredients: 2,4-D,

chlorsulfuron, clopyralid, 

dicamba, glyphosate, 

imazapic, imazapyr, 

metsulfuron methyl, 

picloram, sethoxydim,

sulfometuron methyl, and

triclopyr. Mixtures of

herbicides formulations 

containing these active 

ingredients may be applied 

where the sum of all 

individual Hazard Quotients 

for the relevant application

scenarios is less than 1.0. 3

All herbicide application

methods are allowed 

including wicking, wiping, 

injection, spot, broadcast

and aerial, as permitted by

the product label. 

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.

Rationale for Selected Standard 

I am selecting the Proposed Action for Standard 16 because it allows for use of a wide range 

of herbicides that: 

a) Are likely to treat all situations known across the Region (see FEIS Chapter 4.2). 

b) Do not have the risks associated with use of 2,4-D or dicamba (see FEIS Chapters 

4.3, 4.4, 4.5 and 4.7). 

23
Preventing and Managing Invasive Plants Record of Decision September 2005 

This is one of the primary components of the need for action (decision factor 1): need for an 

updated list of herbicides for use on National Forest System lands in Region Six. The No 

Action Alternative would not have provided new herbicides for use, severely restricting 

treatment effectiveness and resulting in the rates of spread currently known. 

I did not choose Alternative B for this standard because the herbicides that would be approved 

are not fully effective in treating invasive plant situations known in the Region (FEIS Chapter 

4.2.3) and would increase the costs of treatments more than any other alternative (FEIS 

Chapter 4.6.2). I am not selecting Alternative B because the limitations in herbicides would 

have been less effective in treating invasive plants (decision factor 1) and would have higher 

costs (decision factor 4). I recognize that Alternative B had less potential for direct adverse 

effects of herbicides to non-target species and public health and safety because of this 

standard (decision factor 2). 

I did not choose Alternative D for this standard because the addition of 2,4-D and dicamba 

would have increased the potential for harm to non-target species, workers and the public. I 

recognize the FEIS estimated that these additional herbicides would result in less expensive 

treatments and increased acreage treated annually given a static budget (decision factor 4). 

However, these herbicides do not treat any invasive plant that cannot be treated with the suite 

of ten herbicides included in the Proposed Action, nor do they provide any advantage in terms 

of herbicide resistance (see FEIS Chapter 4.2). 

Many people argued that 2,4-D and dicamba should be allowed, either for widespread or more 

limited use. Three comments are indicative of the range of comments received. In most 

cases, those who expressed that these chemicals should be allowed were invasive plant 

treatment practitioners. 

“Dicamba and/or 2,4-D should be allowed, they might be critical to the successful 

management of Leafy Spurge, Whitetop, and Rush Skeletonweed. One other important 

issue is that these two chemicals are many times the most cost effective tools 

available.” 

 “2,4-D and dicamba can be very cost-effective depending on the application rate and 

target species. With shrinking budgets and rising application costs, eliminating an 

inexpensive herbicide has the probability of reducing the number of infestations or 

acreage treated annually. The one two punch of 2,4-D and dicamba are growthregulating herbicides readily absorbed and translocated from either roots or foliage. 

These two chemicals are used largely for noxious weed control on County right of 

ways. 2,4-D and dicamba have been commonly used by millions of homeowners and 

landscapers in landscaping situations for many years.” 

24
Preventing and Managing Invasive Plants Record of Decision September 2005 

“Eliminating 2,4-D and dicamba reduces the number of options for control of given 

weeds. For example, herbicides recommended for use on Dalmatian toadflax (PNW

Weed Management Handbook) are dicamba, picloram, picloram+2,4-D, and 

chlorsulfuron (Idaho and Washington only). Under the proposed alternative, the only 

herbicide option in Oregon is picloram alone. This needlessly eliminates options that 

may be more appropriate for certain situations, especially because picloram should not 

be used where it can leach to nontarget locations, as it has a longer soil residual, which 

might make it less desirable if the target species is intermingled with susceptible 

species. 

Detrimental effects from too heavy reliance on picloram and clopyralid on legumes 

could be mitigated by use of 2,4-DB and non-residual and short-residual chemicals 

(2,4-D and dicamba). Not that they would be used in every case, but there may be 

situations where their use would be advantageous. These two herbicides would reduce 

risk of developing herbicide resistance in target species, by having more options for 

rotating different chemical families. Dicamba and 2,4-D are among the herbicides 

with lowest risk for developing resistance in target species. In some cases, adding 2,4-

D in a mix with one of the other approved herbicides greatly increases the 

effectiveness and allows a lower rate of application, which not only decreases costs, 

but environmental effects as well. Use of a lower cost herbicide may free up more 

money to be spent on use of native species in restoration work, if there is a fixed 

budget for a given project.” 

I recognize the cost-effectiveness of 2,4-D and dicamba. It has been commonly and widely 

used on both private and public lands for the last several decades. At the Regional scale, 

however, no situations were found where these herbicides would be absolutely necessary. 

These herbicides are inherently more risky than the ten I am approving for use. Forest Service 

risk assessments consistently place these two herbicides in higher risk categories for human 

beings, large mammal and birds (see FEIS Chapter 4.4 and 4.5). 

One favorable aspect of 2,4-D is its low cost; this is the main reason why Alternative D is 

predicted to treat 25 percent more acreage at the same cost as the Proposed Action (See FEIS 

Chapter 4.2). Widespread use of 2,4-D would have been required to achieve this result. 

Many people suggested I impose limitations on the use of 2,4-D and dicamba, rather than 

eliminate their use altogether. Such limitations would tend to increase the cost of using these 

chemicals and reduce the acres that can be treated at a static budget. 

Therefore, I am not approving 2,4-D or dicamba for widespread use across the Region. At 

this scale, I am not aware of any situations that cannot be otherwise effectively treated. Sitespecific Forest Plan amendments could be contemplated to allow use of these herbicides if 

local land managers find them necessary. Such amendments would be project-specific and 

analyzed in future NEPA decisions. The FEIS provides evidence that the methods approved 

in the Selected Alternative will effectively treat all invasive plant species known in the 

Region (FEIS Chapter 4.2). I am choosing the Proposed Action because the herbicides 

approved in Standard 16 can effectively treat known invasions (decision factor 1) without the 

risks associated with widespread use of 2,4-D and dicamba (decision factor 2). 

25
Preventing and Managing Invasive Plants Record of Decision September 2005 

Support for my position was also noted in the public comments, as demonstrated by these 

examples: 

“The chemical list in the Purposed Action is reasonable and will support a successful 

Integrated Pest Management program.” 

“We also support the Proposed Action because it allows limited use of herbicides. 

While we are sensitive to public concern over widespread use of herbicides such as 2-

4D, such as it proposed in alternative D, we also recognize that it is unlikely that an 

effective control program can be implemented without treatment with some herbicide. 

The Proposed Action avoids the use of the most controversial of herbicides and avoids 

the fallacy that manual or mechanical treatment alone is always sufficient to control or 

contain noxious weeds. It is a cost effective and culturally acceptable alternative.” 

“I am extremely opposed to the use of 2,4-D since it has been proven to adversely 

impact all wildlife and to pollute the streams and rivers, salmon and to stay in the 

environment for a lasting negative impact on people. It has been proven to cause 

cancer and I for one am extremely opposed to any further destruction of out 

ecosystems. There are no invasive weeds that warrant the use of such toxic methods.” 

“The National Environmental Defense Council (NEDC) strongly suggests that the 

Forest Service avoid implementation of Alternative D, as it poses the most risk to nontarget plant species. By permitting use of 2,4-D and more aggressive aerial spraying, 

native plant populations will be harmed. Without implementing a monitoring program

required by NFMA, the Forest Service may not become aware of the damage until 

native plant populations are significantly reduced. In addition, as the Forest Service 

points out, pollinators may be affected by the application of 2,4- D, which in turn will 

impact the vitality of the native species populations. NEDC does not believe that the 

Forest Service should implement a plan that permits use of a chemical that has the 

potential to reduce pollinator species populations, which in turn reduces viability of 

native plant populations when the goal of the project is to increase native plant species 

numbers.” 

The Environmental Protection Agency recently released a Reregistration Eligibility Decision 

for 2,4-D (June 2005). One finding in the assessment is that non-aquatic use of 2,4-D exceeds 

levels of concern for endangered mammals, birds and non-target terrestrial plants. The 

Eligibility Decision is under review to determine whether it contains information pertinent to 

my decision. Any new information regarding 2,4-D will be included in an updated Forest 

Service risk assessment. Standard 16 allows for 2,4-D (or other herbicides) to be added in the 

future at either the Forest Plan or project level after following appropriate risk assessment and 

NEPA/ESA procedures. 

26
Preventing and Managing Invasive Plants Record of Decision September 2005 

Treatment Restoration Standard 17 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action Alternative B Alternative D/ 

Selected Alternative 

17 

(Objective 

3.4) 

When herbicide 

treatments are 

chosen over other 

treatment methods, 

document the 

rationale for 

choosing 

herbicides. 

Choose non-herbicide treatment methods 

over herbicides, unless non-herbicide 

methods are known to be ineffective or 

unfeasible. Use herbicides as a tool of last 

resort. 

Reduce herbicide use over time at both the 

regional and local scale. 

No standard. 

Rationale for Selected Standard 

I am not adopting this standard in the Selected Alternative because I do not believe that it is 

appropriate for the Forest Plans in the Region. Managers’ rationales for project scale 

decisions (such as whether or not to use herbicides) are documented through the NEPA 

process. I do not believe a standard requiring additional documentation (as required by the 

Proposed Action) will result in better decisions. Standard 17 was not found to specifically 

contribute to the effectiveness of any alternative in meeting the purpose and need (FEIS 

Chapter 4.6.3). 

I am not adopting Alternative B for this standard because it would deviate from the IWM 

principles that are part of Forest Service manual direction (FSM 2080.5), by requiring that 

herbicides be used as a tool of last resort, rather than as a part of a safe, integrated prescription 

aimed at achieving optimum results. This undermines the ability of treatments under 

Alternative B to be effective (decision factor 1). Alternative B would also have incorporated 

the objective of reducing reliance on herbicides (objective 3.4) as a Forest Plan standard. This 

could be interpreted to mean declining amounts of herbicide use over time; this would not be 

appropriate given the uncertainty of budgets, new invasions, and monitoring results. There 

may be cases where an increase in herbicide use does not reflect greater reliance on 

herbicides; rather it may reflect an increase in funding or changed ground conditions. 

Treatment Restoration Standard 18 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action/Selected Alternative Alternative B Alternative D 

18 

(Objectives 

3.1, 4.1, 

4.2) 

Use only adjuvants (e.g. surfactants, dyes) 

and inert ingredients reviewed in Forest 

Service hazard and risk assessment 

documents such as SERA, 1997a, 1997b; 

Bakke, 2003.

Use only adjuvants and 

herbicide formulations 

for which all ingredients 

have been publicly

identified. 

Same as 

Proposed 

Action. 

27
Preventing and Managing Invasive Plants Record of Decision September 2005 

Rationale for Selected Standard 

I am selecting the Proposed Action (also would have applied to Alternative D) for Standard 

18 because it ensures that appropriate risk assessment is completed for adjuvants and inert 

ingredients. I believe this will provide appropriate protection of public and environmental 

health (decision factor 2). I did not select No Action because it does not include a mechanism

for determining whether or not a new ingredient could be used. 

Alternative B would have required that only publicly identified ingredients be used. I am not 

selecting Alternative B because this may put an undue burden on those implementing 

herbicide projects. Some ingredients are not publicly identifiable, due to non-disclosure 

provisions included in the regulations that implement the Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA). 

I acknowledge that some members of the public advocated for the wording in Alternative B 

because of their concerns for their health and safety. 

I believe that the risk assessments will adequately address public health concerns and allow 

for reasonable use of herbicides (decision factors 1 and 2). 

Treatment Restoration Standard 19 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Selected Alternative Proposed Action Alternative B Alternative

D 

19 

(Objective 

4.1) 

To minimize or eliminate 

direct or indirect negative 

effects to non-target plants, 

terrestrial animals, water 

quality and aquatic biota 

(including amphibians) from

the application of herbicide, 

use site-specific soil 

characteristics, proximity to

surface water and local 

water table depth to

determine herbicide 

formulation, size of buffers 

needed, if any, and 

application method and 

timing. Consider 

herbicides registered for

aquatic use where 

herbicide is likely to be

delivered to surface waters.

To reduce or eliminate 

direct or indirect negative 

effects to non-target 

plants, terrestrial animals, 

water quality and aquatic 

biota (including

amphibians) from the 

application of herbicide, 

use site-specific soil 

characteristics, proximity 

to surface water and local 

water table depth to

determine herbicide 

formulation, size of

buffers needed, if any,

and application method 

and timing. Only 

consider those herbicides 

and herbicide mixtures 

registered for aquatic use 

when evaluating herbicide 

use near streams or 

surface water. 

Same as Proposed 

Action, plus: 

Minimize 

application of 

herbicides and

prohibit broadcast 

spraying in the 

riparian reserve 

land allocation and

in known aquatic 

and terrestrial 

amphibian habitat,

including breeding, 

rearing, and 

overland dispersal

areas. Avoid 

application of 

herbicides with 

adverse effects on 

aquatic species and 

amphibians. 

Same as 

Proposed

Action. 

28
Preventing and Managing Invasive Plants Record of Decision September 2005 

Rationale for Selected Standard 

The Selected Alternative is similar to the Proposed Action, but includes minor clarifying 

modifications. The clarifying text is shown in bold italics. I am selecting this standard from

the Proposed Action (also would have applied to Alternative D) because it ensures that 

herbicide use is done in a manner that considers local conditions to minimize or eliminate 

harm to non-target species (decision factor 2). 

FEIS Chapter 4 discusses how adverse effects to non-target species, habitats, soils and water 

can be minimized or avoided by choice of herbicide or application method. For instance, drift 

can be minimized in sensitive areas by use of selective herbicide application methods or 

specific formulations or application rates. 

This standard, as written for the Proposed Action and Alternative D, used the word “reduce” 

rather than “minimize,” in reference to potential adverse effects on non-target species. This 

change is at the request of NOAA Fisheries to ensure that non-target aquatic species are 

adequately protected. The terms “minimize” and “reduce” are used interchangeably in the 

FEIS in reference to this standard. 

I am also clarifying the requirement to use herbicides registered for aquatic use near streams 

and surface waters. The intent of the standard is to select herbicide formulations that are 

effective, while eliminating or minimizing the risk of adverse effects on non-target species. 

The intent is not to require aquatic-labeled herbicides in all riparian areas. 

Aquatic labeling does not necessarily equal low risk to aquatic species. Risks to non-target 

organisms may be minimized or eliminated within riparian zones with certain non-aquatic 

labeled herbicides. Thus, the standard now requires that manager consider whether or not to 

use aquatic-labeled herbicides, depending on the risk of herbicide actually entering the water. 

This change is consistent with the interpretation and analysis of Standard 19 in the FEIS. 

Alternative B would have added requirements to minimize application of herbicides and 

prohibit broadcast spraying in the riparian reserve land allocation and in known aquatic and 

terrestrial amphibian habitat, including breeding, rearing, and overland dispersal areas. 

Application of herbicides with adverse effects on aquatic species and amphibians would also 

have been avoided by standard. 

Alternative B may be overly restrictive by prohibiting broadcast spraying in the full riparian 

reserve land allocation. Riparian reserve land allocations may be larger than the buffers 

needed to reduce potential risks to surface water from broadcast spraying. This would have 

eliminated some necessary options for safe and effective herbicide treatments and reduced 

this alternative’s potential effectiveness (FEIS Chapter 4.2.3). 

Therefore, I am choosing the modified Proposed Action because it is more effective in 

treating invasive plants than No Action or Alternative B (decision factor 1). I am also 

choosing the Propose Action because it minimizes adverse effects on the environment 

inherent in No Action (decision factor 2). 

29
Preventing and Managing Invasive Plants Record of Decision September 2005 

Treatment Restoration Standard 20 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Selected Alternative Proposed Action Alternative 

B 

Alternative

D 

20 

(Objectives 

4.1, 4.2, 

4.3)

Design invasive plant

treatments to minimize or

eliminate adverse effects to

species and critical habitats 

proposed and/or listed under 

the Endangered Species Act. 

This may involve surveying 

for listed or proposed plants

prior to implementing actions

within unsurveyed habitat if 

the action has a reasonable 

potential to adversely affect 

the plant species. Use sitespecific project design (e.g. 

application rate and method, 

timing, wind speed and 

direction, nozzle type and size, 

buffers, etc.) to mitigate the 

potential for adverse

disturbance and/or

contaminant exposure. 

Design invasive plant

treatments to reduce or

eliminate adverse effects to

species and critical habitats 

proposed and/or listed under 

the Endangered Species Act. 

This may involve surveying 

for listed or proposed plants

prior to implementing actions

within unsurveyed habitat if 

the action has a reasonable 

potential to adversely affect 

the plant species. Use sitespecific project design (e.g. 

application rate and method, 

timing, wind speed and 

direction, nozzle type and size, 

buffers, etc.) to mitigate the 

potential for adverse

disturbance and/or

contaminant exposure. 

Same as 

Proposed

Action. 

Same as 

Proposed

Action. 

Rationale for Selected Standard 

The Selected Alternative is similar to the Proposed Action, but includes minor clarifying 

modifications. The clarifying text is shown in bold italics. This standard, as written for all 

action alternatives, used the word “reduce” rather than “minimize,” in reference to potential 

adverse effects on species and critical habitats proposed and/or listed under the Endangered 

Species Act. This change is at the request of NOAA Fisheries to ensure that aquatic species 

are adequately protected. The terms “minimize” and “reduce” are used interchangeably in the 

FEIS in reference to this standard. 

I am choosing to adopt this standard because it provides more protection for threatened and 

endangered species than No Action (decision factor 2). Effects determinations for threatened 

and endangered plants, animals and fish are discussed in FEIS Chapter 4.6. Table 4-51 

discusses ways effects on these species may be minimized. 

30
Preventing and Managing Invasive Plants Record of Decision September 2005 

Treatment Restoration Standard 21 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action/Selected Alternative Alternative B Alternative 

D 

21 

(Objectives 

3.1, 4.2) 

Provide a minimum buffer of 300 feet 

for aerial application of herbicides 

near developed campgrounds, 

recreation residences and private land 

(unless otherwise authorized by

adjacent private landowners). 

Same as Proposed Action, plus: 

Provide buffers to adequately 

protect culturally significant plant 

and wildlife resources during 

broadcast application of 

herbicides. 

Same as 

Proposed 

Action. 

Rationale for Selected Standard 

I am choosing the Proposed Action (would have also applied to Alternative D) because it 

addresses human health concerns about effects from aerial drift better than No Action (no 

standard). The risk assessments and analysis in the FEIS demonstrate that the public health 

hazards from herbicides in the Proposed Action are low (decision factor 2). 

Alternative B would have required that buffers be provided to adequately protect culturally 

significant plant and wildlife resources during broadcast application of herbicides. The 

Alternative B version of the standard is unclear, which may lead to unintentional 

consequences on other programs (decision factor 3) or increase treatment costs (decision 

factor 4). Culturally significant plants and animals will be adequately protected by 

management direction included in the other standards and existing policy of tribal 

consultation (decision factor 2). Therefore, I am not selecting Alternative B. 

Treatment Restoration Standard 22 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Proposed Action/Selected Alternative Alternative B Alternative D 

22 

(Objectives 4.1)

Prohibit aerial application of herbicides within 

legally designated municipal watersheds. 

Same as 

Proposed Action. 

Same as 

Proposed Action. 

Rationale for Selected Standard 

I am selecting this standard from the Proposed Action (applied to all action alternatives) 

because it protects drinking water (decision factor 2) better than No Action (no standard). 

Additional requirements may apply in specific municipal watershed plans. 

31
Preventing and Managing Invasive Plants Record of Decision September 2005 

Treatment Restoration Standard 23 

Alternatives Considered 

Standard 

(Objective 

Addressed) 

Selected Alternative Proposed Action Alternative 

B 

Alternative

D 

23 

(Objective 

3.1

Prior to 

implementation of 

herbicide treatment 

projects, National 

Forest system staff 

will ensure timely

public notification. 

Sign treatment areas 

to inform the public, 

and forest workers of 

herbicide application 

dates and herbicides 

used. If requested, 

individuals will be 

notified in advance of 

spray dates. 

Prior to implementation of 

treatment projects, each Forest will 

develop a public information plan. 

The plan will ensure (at a 

minimum) that timely (normally 15 

days) public notification will occur. 

Warning and information signs will 

be placed at appropriate locations 

(defined in the public information 

plan) to inform the public, and 

forest workers of herbicide 

application dates and herbicide 

used. If requested, individuals may

be notified in advance of spray

dates and times. 

Same as 

Proposed 

Action. 

Same as 

Proposed 

Action. 

Rationale for Selected Standard 

I am choosing the Proposed Action with modifications. The new wording is similar to the 

Proposed Action, but not exactly the same. It would have the same effect as the standard as 

written in the FEIS, but emphasizes action more than planning, which I expect will yield 

similar or better results. I am choosing to adopt this standard because it addresses public 

concerns about notification of potential exposure to herbicides better than No Action (no 

standard). This will serve to fully protect public health and safety (decision factor 2). 

Inventory and Monitoring Plan Framework 

I have decided to add the inventory and monitoring plan framework in Appendix M of the 

FEIS to all Forest Plans in the Region (same for all action alternatives), with three minor 

modifications. These modifications do not change the intent or effect of the Proposed Action 

as described in the FEIS. This inventory and monitoring framework was part of all action 

alternatives. 

1. A clarification that effectiveness monitoring would occur on a representative sample 

of “high risk” projects, to avoid a misinterpretation that effectiveness monitoring is 

required for any/all projects of this type. 

2. A clarification that effectiveness monitoring results will be reported. 

3. A clarification that interagency includes (but is not limited to): USDA Forest Service,

U.S. Fish and Wildlife Service, and National Marine Fisheries Service. 

32
Preventing and Managing Invasive Plants Record of Decision September 2005 

I am choosing to adopt this framework because it builds on existing inventory and monitoring 

processes (No Action), but provides an updated approach. This will improve invasive plant 

prevention practices and treatment effectiveness (decision factor 1). 

Public Involvement 

Hundreds of individuals, agency representatives and groups participated throughout the 

process. Methods used to solicit comment included: Notice of Intent filed in the Federal 

Register (August 28, 2002); public meetings; a project website; and a direct mailing to 

approximately 3,000 interested members of the public, organizations, governments, and 

tribes. Outreach yielded 275 letters of comment and a compendium of input from the public 

meetings. The letters were reviewed and significant issues were identified. 

The DEIS was circulated for public review and comment in August 2004. The Forest Service 

received approximately 300 responses during the comment period. The Forest Service 

responded to the comments in a variety of ways: modifying alternatives (changing language 

in the DFC, goals, objectives or standards), supplementing the analysis, and making 

correction to the analysis. Appendix A to the FEIS includes more detailed public involvement 

information, including public comments and agency responses. 

Issues 

The following issues were the basis for effects analysis in Chapter 4. One reason I am 

choosing the Selected Alternative is because I believe it adequately resolves public issues. 

Issue 1: Strategies to prevent and control invasive plants can vary in effectiveness.

The Selected Alternative has moderate to high potential for reducing rate of spread of 

invasive plants. While Alternative B would have more likely reduced the rate of spread of 

invasive plants through prevention, it would not have been as effective in treating some

invasive species. Therefore, control of invasive plants was predicted to take longer than the 

Proposed Action (see FEIS Chapter 4.2). Alternative D would have been the most effective 

alternative, especially if stronger prevention standards were added, however the reason for the 

effectiveness is the low cost of 2,4-D and dicamba, which would have been associated with 

greater potential environmental and human health risks. 

Issue 2: Invasive plant treatments may harm non-target plants and native plant communities.

Chapter 4.3 of the FEIS and the summary/comparison tables demonstrate that the potential for 

herbicides to harm non-target plants and plant pollinators are likely to be resolved through 

adherence to the standards in the Selected Alternative. The Selected Alternative includes 

fewer herbicides that may harm non-target plants and communities than Alternative D or No 

Action. Alternative B would have best resolved this issue (fewest herbicides that may harm

non-target plants), but at too high a cost and loss of effectiveness. 

33
Preventing and Managing Invasive Plants Record of Decision September 2005 

Issue 3: Application of certain herbicides may harm some vegetation-eating or insect-eating 

birds and mammals and/or amphibians.

Chapter 4.4 of the FEIS and the summary/comparison tables demonstrate that the potential for 

herbicides to harm free-ranging wildlife, vegetation-eating or insect-eating birds, mammals, 

and/or amphibians are likely to be resolved through adherence to the standards in the Selected 

Alternative. The Selected Alternative includes fewer plausible herbicide exposure scenarios 

that may harm birds and mammals than Alternative D or No Action. Alternative B would 

have best resolved this issue (fewest plausible exposure scenarios), but at too high a cost and 

loss of effectiveness. 

Issue 4: Invasive plant treatments may result in risks to human health, including 

contamination of drinking water.

Chapter 4.5 of the FEIS and the summary/comparison tables demonstrate that the potential for 

harm to the health and safety of forestry workers and the public will be adequately resolved 

through adherence the standards in the Selected Alternative. No Action and Alternative D is 

associated with greater risks to human health than the Selected Alternative. Alternative B was 

associated with fewest risks, but the differences are minimal, and the costs of the restrictions 

associated with Alternative B are great. None of the alternatives, with the exception of 

Alternative D, are associated with plausible scenarios for drinking water contamination, 

unless there is an accidental spill of a tanker containing herbicide. Adherence to the standards 

in the Selected Alternative will eliminate most harmful public exposure scenarios. 

Public notification, spill planning, and adherence to OSHA safety standards will adequately 

protect public and worker health. 

Issue 5: Cost of treatments and effects on land uses.

Chapter 4.6 of the FEIS and the summary/comparison tables demonstrate that the Selected 

Alternative is relatively cost-effective, without unreasonable effects on existing land uses. 

Alternative D was the least expensive alternative; however, this resulted in higher risks to 

human health and the environment. Alternative D had the least adverse effects on land uses, 

but at the expense of effective prevention. Alternative B had the opposite effects; cost and 

adverse effects on land use were greatest. 

The Selected Alternative provides a blend of treatment cost-effectiveness, prevention 

effectiveness, and reasonable adverse consequences. 

Environmentally Preferable Alternative 

All of the alternatives protect the biological and physical environment. The Selected 

Alternative is environmentally preferable because it allows for effective treatment while 

emphasizing prevention and protecting public, worker and environmental health. 

34
Preventing and Managing Invasive Plants Record of Decision September 2005 

Alternative B would have required reduced levels of herbicide use, with a loss of

effectiveness. This reduces its ability to protect the environment, because the threats from

invasive plants largely outweigh the risks associated with treatment. Alternative B would 

have emphasized prevention, with adverse impacts to land management programs, including 

those aimed at environmental restoration. Alternative D would have resulted in the greatest 

invasive plant treatment effectiveness, but the risk of harmful herbicide exposures would be 

much greater. 

Thus, the Selected Alternative is the Environmentally Preferable Alternative. It is likely to be 

effective in controlling invasive plants, while minimizing adverse impacts to the biological 

and physical environment from treatment. The Selected Alternative is not likely to adversely 

affect land management activities aimed at protecting and enhancing the environment. 

Findings Required by Laws and Regulations 

My decision is consistent with all current laws, regulations and policies guiding invasive plant 

programs and other management activities on National Forest System lands. Specific findings 

and rationales required by law follow: 

Civil Rights and Environmental Justice 

The FEIS addresses civil rights and environmental justice. American Indians and Hispanics 

are groups that may be disproportionately affected by the standards proposed in the action 

alternatives. American Indian tribes may be disproportionately affected because they are 

dependent on native plants for cultural and traditional uses and because they may consume 

more fish (that could be contaminated with herbicides) than the general public. Hispanics 

may be more likely than the general population to be injured during manual treatments or 

exposed to chemical treatments because they may be disproportionately represented on some

work crews (see Chapter 4.5). 

No specific cases of disparate effects to these communities were identified at the regional 

scale. Environmental justice issues will be further considered at the site-specific level and 

outreach to tribes and Hispanic communities will occur as a part of project planning.

National Environmental Policy Act (NEPA) 

Implementing regulations for NEPA (40 CFR 1909.15) were followed in preparing this EIS. 

The range of alternatives was adequate to understand and analyze significant public issues. 

My decision amends existing Forest Plans but does not specifically affect action plans for 

individual administrative units. It does not authorize any habitat-disturbing activities. 

The Selected Alternative adopts all practical means to avoid and/or minimize adverse effects 

to the environment that are relevant to this planning scale. FEIS Table 4-51 describes the 

measures the Forest Service expects to take to further reduce the risk of adverse effects during 

future implementation. 

35
Preventing and Managing Invasive Plants Record of Decision September 2005 

I am choosing the Selected Alternative given the consideration of cumulative effects 

addressed throughout the FEIS. FEIS Chapter 4.1.1 specifically addressed the basis for 

cumulative effects analysis and its relevance to the choice between alternatives. The effects 

of herbicide use are of greatest concern to the public and are the focus of cumulative effects 

analysis in the FEIS. This is consistent with the Guidance on Consideration of Past Actions 

in Cumulative Effects Analysis provided by the Council on Environmental Quality (June 24, 

2005). 

In general, the Forest Service contribution to overall herbicide use is very small, and the 

effects of herbicide use that complies with the Selected Alternative are limited both spatially 

and temporally. Thus, there is low potential for significant cumulative effects to be triggered 

by this decision. 

The Environmental Protection Agency published their Final Reregistration Eligibility 

Decision (RED) for 2,4-D in the Federal Register in August 2005. Information on 2,4-D in 

the RED (as it pertains to its land management programs, including invasive plant treatment) 

will be analyzed in an updated Forest Service risk assessment. Standard 16 allows for 

additional herbicides including 2,4-D to be added in the future at either the Forest Plan or 

project level to adapt to new information, after following appropriate risk assessment and 

NEPA/ESA procedures. 

National Forest Management Act (NFMA) 

This Forest Plan amendment was developed consistent with procedural requirements for 

National Forests. The applicable planning regulations under the National Forest Management 

Act (NFMA) were published in the Federal Register on January 5, 2005. This Forest Plan 

amendment decision is made during the transition period described in 36 C.F.R. Section 

219.14(e)(2005). Therefore, the provisions of the planning regulations in effect prior to 

November 9, 2000, apply, except as otherwise provided in 36 C.F.R. Section 219.14(f)(2005). 

This decision is a non-significant amendment to Forest Plans in Region Six. The Forest 

Service Manual (FSM 1922.51 and .52) provides specific direction for determining the 

significance of a plan amendment. Significant amendments include: 

• Changes that would significantly alter the long-term relationship between levels of 

multiple-use good and services originally projected (36 CFR 219.10(e)); or 

• Changes that may have an important effect on the entire forest plan or affect land and 

resources throughout a large portion of the planning area during the planning period. 

This decision does not affect projections of goods and services; rather it will help maintain the 

ability of the Forest Service to manage land for desired conditions and outputs. The 

management direction that would be added does not conflict with existing goals and 

objectives for forest management. 

Endangered Species Act (ESA) 

Consultation with regulatory agencies has been conducted and completed. The National 

Marine Fisheries Service issued their Biological Opinion on September 9, 2005. The U.S. 

Fish and Wildlife Service issued their Biological Opinion on September 7, 2005. 

36
Preventing and Managing Invasive Plants Record of Decision September 2005 

Both agencies concurred that no species listed under the federal Endangered Species Act are 

likely to be jeopardized by the Proposed Action/Selected Alternative (modifications were 

reviewed by the regulatory agencies). No incidental take is involved. 

FEIS Chapter 4.7 discloses detailed analysis of potential effects on listed species from

invasive plant treatments. 

Further consultation will occur at the project scale where listed species may be affected. The 

final Biological Opinions are available by request or on the Internet at: 

www.fs.fed.us/r6/invasiveplant-eis. 

Clean Water Act 

This decision does not directly affect water quality. No site-specific projects are authorized. 

Water quality will be improved if invasive plants are controlled in riparian areas (FEIS 3.1.2). 

Protection of Tribal Treaty Rights and Trust Resources 

This decision does not change, restrict or abrogate treaty reserved rights or Executive Orders. 

Implementation of the standards may affect natural resources on which the tribes depend. 

Government-to-Government consultation with tribal governments will occur during sitespecific project planning so that adverse effects to traditional uses and treaty and other rights 

are avoided or appropriately mitigated. 

Valid Existing Rights 

Valid existing rights are those rights or claims to rights that pertain to mining claims, mineral 

or energy easements, rights-of-way, reciprocal rights-of-way, leases, agreements, permits and 

water rights. Private individuals or companies may hold other Federal, State or local 

government agencies or valid existing rights. 

This decision does not affect any existing rights; however, the prevention standards may 

result in adjustments to operating plans and permits over time. Appeal rights will be provided 

to permittees under 36 CFR 251 before specific permits are adjusted. 

Implementation 

The management direction in this Record of Decision will be added to Forest Plans in the 

Region with implementation beginning March 1, 2006. Some of the standards have a longer 

phase-in period (see Appendix 1 for an implementation schedule for each standard). 

Existing direction related to the 1988 ROD and 1989 Mediated Agreement will be vacated for 

invasive plant management starting March 1, 2006, assuming legal procedures related to 

vacating this agreement are completed. 

37
Preventing and Managing Invasive Plants Record of Decision September 2005 

Administrative Review and Appeal Opportunities 

This decision may be appealed in accordance with 36 CFR 217 by filing a written notice of 

appeal, in duplicate, within 45 days of the publication of the legal notice. An appeal notice 

must be in writing clearly stating that it is a Notice of Appeal being filed in pursuant to 36 

CFR 217. Appeals must be filed with the Chief of the Forest Service at either of the following 

addresses: 

Regular Mail: 

USDA, Forest Service, 

Attn: EMC, Appeals 

Mail Stop 1104 

1400 Independence Ave, SW 

Washington, DC 20250-1104 

Courier, UPS, Fed-ex: 

USDA, Forest Service 

Attn: EMC, Appeals 

Yates Building, 3CEN 

201 14th Street SW 

Washington, DC 20024 

Complete instructions for appellants are given at 36 CFR 217.9. At a minimum, a written 

notice of appeal filed with the Reviewing Officer must: 

1. State that the document is a Notice of Appeal filed pursuant to 36 CFR part 217; 

2. List the name, address, and telephone number of the appellant; 

3. Identify the decision about which the requester objects; 

4. Identify the document in which the decision is contained by title and subject, date of 

the decision, and name and title of the Deciding Officer. 

5. Identify specifically that portion of the decision or decision document to which the 

requester objects; 

6. State the reasons for objecting, including issues of fact, law, regulation, or policy, and, 

if applicable, specifically how the decision violates law, regulation, or policy; and 

7. Identify the specific change(s) in the decision that the appellant seeks. 

 

38
Preventing and Managing Invasive Plants Record of Decision September 2005 

Contact Person 

For additional information concerning this decision or the Forest Service appeal process, 

contact: 

Doug Daoust 

USDA Forest Service 

PO Box 3623 

Portland, OR 97208 

Ph: (503) 808-2913 

Fax: (503) 808-2469 

Email: r6_IPEIS@fs.fed.us

www.fs.fed.us/r6/invasiveplant-eis 

___________________________________ _____________________

Linda Goodman, Regional Forester [DATE] 

Pacific Northwest Region 

39
Preventing and Managing Invasive Plants Record of Decision September 2005 

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40
Preventing and Managing Invasive Plants Record of Decision September 2005 

Appendix 1 – Full Text Added to Forest Plans in R6 

Desired Future Condition

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 preventative 

actions, and the success of restoration efforts. 

Goals and Objectives 

Goal 1 - Protect ecosystems from the impacts of invasive plants through an integrated approach that 

emphasizes prevention, early detection, and early treatment. All employees and users of the National 

Forest recognize that they play an important role in preventing and detecting invasive plants.

Objective 1.1

Implement appropriate invasive plant prevention practices to help reduce the 

introduction, establishment and spread of invasive plants associated with 

management actions and land use activities.

Objective 1.2 Educate the workforce and the public to help identify, report, and prevent 

invasive plants

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.

Goal 2 - Minimize the creation of conditions that favor invasive plant introduction, establishment and 

spread during land management actions and land use activities. Continually review and adjust land 

management practices to help reduce the creation of conditions that favor invasive plant 

communities.

Objective 2.1

Reduce soil disturbance while achieving project objectives through timber 

harvest, fuel treatments, and other activities that potentially produce large 

amounts of bare ground

Objective 2.2

Retain native vegetation consistent with site capability and integrated resource 

management objectives to suppress invasive plants and prevent their 

establishment and growth

Objective 2.3

Reduce the introduction, establishment and spread of invasive plants during fire 

suppression and fire rehabilitation activities by minimizing the conditions that 

promote invasive plant germination and establishment.

Appendix 1-1
Preventing and Managing Invasive Plants Record of Decision September 2005 

Goals and Objectives 

Objective 2.4

Incorporate invasive plant prevention as an important consideration in all 

recreational land use and access decisions. Use Forest-level Access and Travel 

Management planning to manage both on-highway and off-highway travel and 

travel routes to reduce the introduction, establishment and spread of invasive 

plants.

Objective 2.5

Place greater emphasis on managing previously “unmanaged recreation” (OHVs,

dispersed recreation, etc.) to help reduce creation of soil conditions that favor 

invasive plants, and reduce transport of invasive plant seeds and propagules.

Goal 3 - Protect the health of people who work, visit, or live in or near National Forests, while 

effectively treating invasive plants. Identify, avoid, or mitigate potential human health effects from

invasive plants and treatments.

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

Goal 4 – Implement invasive plant treatment strategies that protect sensitive ecosystem components, 

and maintain biological diversity and function within ecosystems. Reduce loss or degradation of

native habitat from invasive plants while minimizing adverse effects from treatment projects.

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, 

contained in Pacfish, Infish, and the Aquatic Conservation Strategies of the 

Northwest Forest Plan.

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.

Goal 5 – Expand collaborative efforts between the Forest Service, our partners, and the public to 

share learning experiences regarding the prevention and control of invasive plants, and the protection 

and restoration of native plant communities.

Objective 5.1

Use an adaptive management approach to invasive plant management that 

emphasizes monitoring, learning, and adjusting management techniques. 

Evaluate treatment effectiveness and adjust future treatment actions based on the 

results of these evaluations.

Objective 5.2 Collaborate with tribal, other federal, state, local and private land managers to 

increase availability and use of appropriate native plants for all land ownerships.

Objective 5.3

Work effectively with neighbors in all aspects of invasive plant management: 

share information and resources, support cooperative weed management, and 

work together to reduce the inappropriate use of invasive plants (landscaping, 

erosion control, etc.).

Appendix 1-2
Preventing and Managing Invasive Plants Record of Decision September 2005 

Standards 

The following standards and an implementation schedule are included in the Selected 

Alternative. 

Standard # 

Text of Standard Implementation Schedule 

1 

 

Prevention of invasive plant introduction, 

establishment and spread will be addressed in

watershed analysis; roads analysis; fire and fuels 

management plans, Burned Area Emergency Recovery

Plans; emergency wildland fire situation analysis; 

wildland fire implementation plans; grazing allotment 

management plans, recreation management plans,

vegetation management plans, and other land

management assessments. 

This standard will apply to all 

assessments and analysis 

documents started or underway as 

of March 1, 2006; this standard

does not apply to assessments and

analysis documents signed or

completed by February 28, 2006. 

2 

 

Actions conducted or authorized by written permit by

the Forest Service that will operate outside the limits of

the road prism (including public works and service 

contracts), require the cleaning of all heavy equipment 

(bulldozers, skidders, graders, backhoes, dump trucks,

etc.) prior to entering National Forest System Lands. 

This standard does not apply to initial attack of 

wildland fires, and other emergency situations where 

cleaning would delay response time. 

This standard will apply to permits 

and contracts issued after March 1, 

2006. Ongoing permits/contracts 

issued before this date may be 

amended, but are not required to be

amended, to meet this standard. 

This standard will apply to Forest 

Service force account operations

starting March 1, 2006. 

3 

 

Use weed-free straw and mulch for all projects, 

conducted or authorized by the Forest Service, on 

National Forest System Lands. If State certified straw 

and/or mulch is not available, individual Forests should 

require sources certified to be weed free using the

North American Weed Free Forage Program standards 

(see Appendix O) or a similar certification process. 

Forests are already applying this 

standard on an informal basis; 

weed-free straw and mulch will be

required as available, starting 

March 1, 2006. 

4 Use only pelletized or certified weed free feed on all 

National Forest System lands. If state certified weed

free feed is not available, individual Forests should

require feed certified to be weed free using North

American Weed Free Forage Program standards or a 

similar certification process. This standard may need

to be phased in as a certification processes are 

established. 

National Forest managers will

encourage the use of weed-free 

feed across the National Forests in 

the Region. Pelletized feed or 

certified weed-free feed will be 

required in all Wilderness areas 

and Wilderness trailheads starting 

January 1, 2007. Pelletized or 

certified weed-free feed will be 

required on all National Forest 

System lands when certified feed is 

available (expected by January 1, 

2009). Weed-free (or pelletized) 

feed requirements will be listed in 

individual Forest Closure orders. 

5 

 

No standard. N/A 

Appendix 1-3
Preventing and Managing Invasive Plants Record of Decision September 2005 

Standard # 

Text of Standard Implementation Schedule 

6 

 

Use available administrative mechanisms to 

incorporate invasive plant prevention practices into 

rangeland management. Examples of administrative 

mechanisms include, but are not limited to, revising

permits and grazing allotment management plans,

providing annual operating instructions, and adaptive

management. Plan and implement practices in

cooperation with the grazing permit holder. 

This standard will apply to grazing

permits beginning March 1, 2006. 

7 

 

Inspect active gravel, fill, sand stockpiles, quarry sites, 

and borrow material for invasive plants before use and 

transport. 

Treat or require treatment of infested sources before 

any use of pit material. 

Use only gravel, fill, sand, and rock that is judged to be

weed free by District or Forest weed specialists. 

This standard will apply to rock

source management beginning 

March 1, 2006. 

8 

 

Conduct road blading, brushing and ditch cleaning in

areas with high concentrations of invasive plants in 

consultation with District or Forest-level invasive plant 

specialists, incorporate invasive plant prevention 

practices as appropriate. 

This standard will apply to all road

blading, brushing and ditch 

cleaning projects beginning March

1, 2006. 

9 No standard. N/A 

10 No standard. N/A 

11 

 

Prioritize infestations of invasive plants for treatment at 

the landscape, watershed or larger multiple 

forest/multiple owner scale. 

This standard will apply to

invasive plant treatment projects

with NEPA decisions signed after 

March 1, 2006. 

12 

 

Develop a long-term site strategy for 

restoring/revegetating invasive plant sites prior to

treatment. 

This standard will apply to

invasive plant treatment projects

with NEPA decisions signed after 

March 1, 2006. 

13 

 

Native plant materials are the first choice in

revegetation for restoration and rehabilitation where 

timely natural regeneration of the native plant 

community is not likely to occur. Non-native, noninvasive plant species may be used in any of the 

following situations: 1) when needed in emergency 

conditions to protect basic resource values (e.g., soil 

stability, water quality and to help prevent the 

establishment of invasive species), 2) as an interim,

non-persistent measure designed to aid in the reestablishment of native plants, 3) if native plant 

materials are not available, or 4) in permanently altered

plant communities. Under no circumstances will nonnative invasive plant species be used for revegetation. 

This standard will apply to

restoration and rehabilitation

projects beginning March 1, 2006. 

14 Use only APHIS and State-approved biological control

agents. Agents demonstrated to have direct negative

impacts on non-target organisms would not be

released. 

This standard will apply to

biological control projects 

beginning March 1, 2006. 

Appendix 1-4
Preventing and Managing Invasive Plants Record of Decision September 2005 

Standard # 

Text of Standard Implementation Schedule 

15 

 

Application of any herbicides to treat invasive plants 

will be performed or directly supervised by a State or 

Federally licensed applicator. 

All treatment projects that involve the use of herbicides 

will develop and implement herbicide transportation 

and handling safety plan. 

This standard will apply to

herbicide treatment projects as of 

March 1, 2006. 

16 

 

Select from herbicide formulations containing one or

more of the following 10 active ingredients: 

chlorsulfuron, clopyralid, glyphosate, imazapic, 

imazapyr, metsulfuron methyl, picloram, sethoxydim, 

sulfometuron methyl, and triclopyr. Mixtures of

herbicide formulations containing 3 or less of these

active ingredients may be applied where the sum of all 

individual Hazard Quotients for the relevant

application scenarios is less than 1.0. 1

All herbicide application methods are allowed

including wicking, wiping, injection, spot, broadcast

and aerial, as permitted by the product label. 

Chlorsulfuron, metsulfuron methyl, and sulfometuron

methyl will not be applied aerially. The use of 

triclopyr is limited to selective application techniques 

only (e.g., spot spraying, wiping, basal bark, cut stump, 

injection). 

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. 

This standard will be applied to

invasive plant projects with NEPA

decisions signed after March 1, 

2006. 

17 

 

No standard. N/A 

18 

 

Use only adjuvants (e.g. surfactants, dyes) and inert

ingredients reviewed in Forest Service hazard and risk

assessment documents such as SERA, 1997a, 1997b; 

Bakke, 2003. 

This standard will apply to

invasive plant treatment projects

with NEPA decisions signed after 

March 1, 2006. 

19 

 

To minimize or eliminate direct or indirect negative 

effects to non-target plants, terrestrial animals, water 

quality and aquatic biota (including amphibians) from

the application of herbicide, use site-specific soil 

characteristics, proximity to surface water and local 

water table depth to determine herbicide formulation,

size of buffers needed, if any, and application method 

and timing. Consider herbicides registered for aquatic

use where herbicide is likely to be delivered to surface 

waters. 

This standard will apply to

invasive plant treatment projects

with NEPA decisions signed after 

March 1, 2006. 

Appendix 1-5
Preventing and Managing Invasive Plants Record of Decision September 2005 

Standard # 

Text of Standard Implementation Schedule 

20 

 

Design invasive plant treatments to minimize or

eliminate adverse effects to species and critical habitats 

proposed and/or listed under the Endangered Species

Act. This may involve surveying for listed or proposed

plants prior to implementing actions within unsurveyed

habitat if the action has a reasonable potential to

adversely affect the plant species. Use site-specific 

project design (e.g. application rate and method,

timing, wind speed and direction, nozzle type and size, 

buffers, etc.) to mitigate the potential for adverse 

disturbance and/or contaminant exposure. 

This standard will apply to

invasive plant treatment projects

with NEPA decisions signed after 

March 1, 2006. 

21 

 

Provide a minimum buffer of 300 feet for aerial

application of herbicides near developed campgrounds,

recreation residences and private land (unless 

otherwise authorized by adjacent private landowners). 

This standard will apply to

invasive plant treatment projects

with NEPA decisions signed after 

March 1, 2006. 

22 

 

Prohibit aerial application of herbicides within legally 

designated municipal watersheds. 

This standard will apply to

invasive plant treatment projects

with NEPA decisions signed after 

March 1, 2006. 

23 

 

Prior to implementation of herbicide treatment projects, 

National Forest system staff will ensure timely public 

notification. Treatment areas will be posted to inform

the public and forest workers of herbicide application

dates and herbicides used. If requested, individuals

may be notified in advance of spray dates.

This standard will apply to

invasive plant treatment projects

with NEPA decisions signed after 

March 1, 2006. 

1. ATSDR, 2004. Guidance Manual for the Assessment of Joint Toxic Action of Chemical Mixtures. U.S.

Department Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease 

Registry. 

Appendix 1-6
Preventing and Managing Invasive Plants Record of Decision September 2005 

Inventory and Monitoring Framework 

(APPENDIX M from the Invasive Plant Final EIS) 

It is assumed every Forest in Region Six has an invasive plants coordinator and is maintaining 

an up-to-date invasive plant inventory using NRIS/Terra, the nationally accepted protocol. 

The inventory will be the primary means to plan and prioritize treatments. The inventory will 

be used as the main vehicle for tracking treatment effectiveness both regionally and on a sitespecific basis. 

In addition to the monitoring that is already required under various Forest Plans, this 

inventory and monitoring plan framework is part of all action alternatives in this 

Environmental Impact Statement (EIS). The framework would guide the development of 

detailed monitoring plans at the site-specific project scale. Invasive plant treatment and 

restoration actions are likely to be complex, involve multiple land ownerships and will take 

years to implement, due to the nature of invasive plant problems. It is likely that a site will be 

treated multiple times over the years. Tracking these efforts and subsequent progress will be 

crucial to determining success. 

A good monitoring program will be well thought out and have a high probability of detecting 

change in the resource being monitored (NPS, 2002). The Field Guide to Invasive Plant 

Inventory, Monitoring and Mapping (USDA FS, 2002) has been developed to guide 

monitoring efforts in conjunction with NRIS/Terra. It suggests a monitoring regime may start 

with annual monitoring for the first 3-5 years, decreasing in frequency to every other year for 

the next 5-10 years and further decreasing monitoring frequency to every 3 years for the next 

ten years until the seed source has been exhausted (i.e. no new germination taking place). 

Monitoring regimes may vary in time and space depending on the species; for example, those 

that reproduce vegetatively may require a longer span of annual monitoring. The monitoring 

categories described in this framework (implementation/compliance, and effectiveness (of 

treatments in meeting project objectives, and effectiveness of protection measures) can be 

used to implement a long-term adaptive management strategy. By implementing an adaptive 

management approach, managers will identify and respond to changing conditions and new 

information on an ongoing basis, and assess the need to make changes to treatment and 

restoration strategies. 

Appendix 1-7
Preventing and Managing Invasive Plants Record of Decision September 2005 

Implementation/Compliance Monitoring

Implementation/compliance monitoring answers the question, “Did we do what we said we 

would do?” This question needs to be answered on a Regional scale, because adaptive 

management strategies require determination that actions are taking place as described in the 

Invasive Plants EIS. 

If an action alternative is selected, each Forest Supervisor will be directed to assess 

compliance with the Invasive Plant Program EIS Record of Decision as a part of Forest Plan 

Implementation monitoring. Regional Office staff will periodically aggregate this 

information as a part of program oversight. 

An implementation/compliance checklist database, such as the Pacfish/Infish Biological 

Opinion Implementation Monitoring module database for the eastside, could be used as a 

template to input and analyze implementation/compliance monitoring data. The use of a 

consistent reporting format will allow for aggregation of information at various scales. Such 

as system will be used to determine patterns of compliance. 

Listed Species -- An implementation/compliance monitoring database would track invasive 

plant treatment projects that are the subject of Section 7 consultations under the Endangered 

Species Act (ESA), generate annual reporting of compliance for use by the Services (NOAA 

Fisheries, U.S. Fish and Wildlife) and Forest Service (FS), and allow for common reporting of 

data on individual projects. As a minimum, on each project requiring consultation, reporting 

will be required on compliance with Standards 16, 18, 19, and 20 in the Invasive Plant EIS. 

Additional standards could be included, as appropriate, for the individual ecoregions, Forests, 

or projects. For example, Northwest Forest Plan (NWFP) riparian standards relevant to 

herbicide use or invasive plant control projects could be included in the database for those 

Forests in the NWFP-covered areas.

Effectiveness Monitoring 

Effectiveness monitoring, relative to project objectives, answers the question, “Were 

treatment and restoration projects effective?” This question could be answered on either a 

regional or a project-level scale. Invasive plant infestations require pre-project inventories to 

determine how, when, and where treatments are to be applied, and post-treatment monitoring 

to assess the effectiveness (treatment) in meeting project objectives (e.g. restoring structure 

and composition of native vegetation). 

A goal of the Effectiveness Monitoring component in the Regional Invasive Plant Program is 

to answer the following questions: 

Have the number of new invasive plant infestations increased or decreased in the 

Region or at the project level?

What changes in distribution, amount and proportion of invasive plant infestations 

have resulted due to treatment activities in the region or at the project level?

Has the infestation size for a targeted invasive plant species been reduced regionally or 

at the project level?

Appendix 1-8
Preventing and Managing Invasive Plants Record of Decision September 2005 

Which treatment methods, separate or in combination, are most successful for specific 

invasive species?

Which treatment methods have not been successful for specific invasive species? 

The nation-wide NRIS/Terra database, and the upcoming FACTS database, provide common 

reporting formats to input information and provide a mechanism for addressing the above 

questions. In addition, current long-term ecological monitoring networks will assist the FS in 

determining trends of invasive plant infestations at the Regional level. 

The NRIS/Terra database could be sorted to answer the above questions because it tracks size

and species of infestations as well as treatment methods. The Forest Inventory and Analysis 

Network (FIA) or the Forest Health Monitoring plots associated with the FIA network could 

be used to follow invasion trends. Such networks could be used to track trends in the spread 

or reduction in spread of the more dominant invasive plants in the region. Monitoring 

programs developed at the Forest level would answer more project specific questions. 

Listed Species - Monitoring that addresses the effectiveness of various measures designed to 

reduce potential adverse effects from the project, including standards in the EIS, “project 

design criteria”, “design features”, and “protection measures” may also need to be conducted. 

This type of monitoring will only be required for a representative sample of invasive plant 

treatment projects that pose a “high risk” to federally listed species. “High risk” projects are 

defined as projects with the potential to affect listed species, in the following situations: 

• Any project involving aerial application of herbicide. 

• 

• 

• 

• 

• 

• 

• 

Projects involving the use of heavy equipment or broadcast application of herbicide 

(e.g. boom spray or backpack spraying that is not limited to spot sprays) that occur in 

1) riparian areas (as defined in NWFP, Pacfish, or Infish, as applicable), ditches or 

water corridors connected to habitat for listed fish; or, 2) proximity to federally listed 

plants or butterfly habitat. 

For the purposes of determining the need for protection measure effectiveness monitoring, 

invasive plant treatment methods that are not considered “high risk” can include, but are not 

limited to, the following: 

Broadcast application of herbicide and use of heavy equipment that occurs outside of, 

1) riparian areas, ditches or water corridors connected to water bodies, or, 2) areas in 

proximity to federally listed plants or butterfly habitat. 

Manual methods including hand-pulling, grubbing, stabbing, pruning, cutting, etc. 

Mechanical methods using small equipment like chainsaws, or equipment rarely used 

and not often in proximity to listed fish habitat, like flamers, foamers, hot steam, etc. 

Prescribed fire used expressly for invasive plant control and which occurs outside of 

riparian areas or habitat for federally listed plants or butterflies. 

Herbicide applications using spot spray (used with a shield near listed plant locations) 

with a backpack sprayer, cut stump, injection, wicking wiping, basal bark applications, 

or other highly selective methods. 

Minor uses of fertilizer to encourage native plant competition or growth. 

Appendix 1-9
Preventing and Managing Invasive Plants Record of Decision September 2005 

Biological controls used in habitat areas for terrestrial wildlife or fish. Use in 

proximity to listed plants or butterflies should be evaluated on a case-by-case basis. 

• 

• Broadcast applications (except aerial) using clopyralid, imazapic, and metsulfuron 

methyl in proximity to habitat for listed fish or listed terrestrial wildlife. 

 A collection of several of these low risk projects in close proximity to each other and in 

proximity to habitat for listed species may constitute a “high risk” project, but this should be 

evaluated on a case-by-case basis. 

Monitoring for “high risk” invasive plant treatments that may affect ESA-listed species or 

designated critical habitat should determine if standards and/or protection measures were 

effective at reducing potential effect pathways (e.g. disturbance, sedimentation, exposure to 

herbicides) and results should be applicable elsewhere. Unique, individual monitoring efforts 

and protocols have not provided information that is applicable to other areas or projects. 

Therefore, a Regional approach is outlined in this framework that will help address the needs 

for protection measure effectiveness at a broader scale. The regional approach will be

developed in consultation with other agencies, including but not limited to National Marine 

Fisheries Service and U.S. Fish and Wildlife Service. 

For example, Japanese knotweed is a serious invader of riparian areas and has the potential to 

alter ecosystems upon which listed salmon depend. The Region may have several Japanese 

knotweed treatment projects over the next several years and each one may have the potential 

to adversely affect listed salmon or designated critical habitat if adequate measures are not 

part of the treatment plan or are not complied with during implementation. Designing 

consistent monitoring protocol will allow a more efficient and effective evaluation of the 

project protection measures. 

To meet the objective of being able to evaluate standards and measures applied at the 

Regional, sub-Regional, and project level for protection of ESA-listed species and/or 

designated critical habitat in “high risk” projects, an interagency monitoring protocol and 

reporting schedule will be developed by 2007. The expectation being that this protocol 

would be applied to high risk projects to determine the effectiveness of Regional EIS 

standards, and additional standards or protection measures applied at finer scales, in reducing 

potential effect pathways (e.g. disturbance, sedimentation, exposure to herbicides, etc.) for 

listed species. 

In the interim, information obtained from implementation/compliance monitoring reports for 

“high risk” projects will be reviewed in 2005 and 2006 to inform the development of a 

consistent monitoring protocol for ensuring that standards and protection measures were 

effective. This 2-3 year lag time before protocol are developed and effectiveness monitoring 

is implemented does not apply to aerial application of herbicides. All projects with aerial 

applied herbicide will include a monitoring plan to assess the effectiveness of measures in 

protecting ESA-listed species and/or designated critical habitat. 

Until a Regional, interagency effectiveness monitoring protocol for ESA-listed species and/or 

designated critical habitat is developed (2007), the need for effectiveness monitoring on “high 

risk” projects will be evaluated by Level 1 or other interagency technical teams during 

Section 7 consultation. 

Appendix 1-10
Preventing and Managing Invasive Plants Record of Decision September 2005 

Recommendations for additional effectiveness monitoring beyond that described in this 

framework will require that Level 2 or other appropriate interagency management team agree 

to the recommendations of the technical or Level 1 team for the project. This process will 

help lead the Region toward efficient and reliable data collection and allow statistical analysis 

of the data gathered. 

References

USFS (U.S. Forest Service). 2001. Invasive Plant Management Decisions and 

Environmental Analysis. USDA Forest Service 

USFS (U.S. Forest Service). 2002. Field Guide – Invasive Plant Inventory, Monitoring and 

Mapping Protocol. USDA Forest Service. 

NPS (National Park Service). 2002. Invasive Plants Inventory and Monitoring Guidelines, 

National Park Service. 

Appendix 1-11
Preventing and Managing Invasive Plants Record of Decision September 2005 

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Appendix 1-12
Preventing and Managing Invasive Plants Record of Decision September 2005 

Appendix 2 – Alternative Comparison/Decision Factors Appendix 2 is Table S-2 from the FEIS. The table compares the alternatives in terms of my decision factors. 

Table S-2 Alternative Comparison/Decision Factors 

Factor for 

Comparison 

Current Direction/ 

No Action Proposed Action Alternative B 

How Well the Alternative Meets the Underlying Need for Action Reduce the Extent and Rate of Invasive Plant Spread 

Does not include new prevention standards. Control may never be reached. 

Moderate to high potential for reducing rate of spread fromadherence to new prevention standards. Control may bereached within 32 years assuming effective annual treatment of 30,000 acres and spread reduced by half. 

Highest potential for reducing rate of spread from adherence to new prevention standards. Control may be reached within 47 years if 20,000 acres are effectively treated annually and spread is reduced to 4 percent. 

Morate to nCo21 effspr

Appendix 2-1 
Preventing and Managing Invasive Plants Record of Decision September 2005 

Table S-2 Alternative Comparison/Decision Factors 

Factor for 

Comparison 

Current Direction/ 

No Action Proposed Action Alternative B 

Release from Forest Plan Direction so that new practices/ technologies/ and herbicides are available; provides an updated list of herbicides 

Maintains current Forest Plan management direction, no new tools available. 

High potential to result in effective treatments because it provides for a suite of tools(including herbicides) that are adequate to effectively treat all known infestations. 

Alternative B lacks sufficient variety of tools for adapting to different environmental circumstances. For example, 

Alternative B provides only one tool, sethoxydim, for invasive grass control. Success using sethoxydim on different grasses varies from good when treating reed canarygrass to no effectiveness on quackgrass (Tu et al, 2001). Alternative B maynot be effective in remote, difficult to access terrain due to restrictions on aerial spray. Herbicide resistance may increase under Alternative B because there are fewer herbicide choices. 

SamaddAltsamProaddAlther

Potential Effects to Human Health and The Environment 

Appendix 2-2 
Preventing and Managing Invasive Plants Record of Decision September 2005 

Table S-2 Alternative Comparison/Decision Factors 

Factor for 

Comparison 

Current Direction/ 

No Action Proposed Action Alternative B 

Potential to harm non-target plants 

Herbicide use on an estimated 13,000 acres annually includes four herbicides with potential to harmnon-target plants: picloram, glyphosate, triclopyr, dicamba 

Herbicide use on an estimated 8,500 acres annually includes three herbicides that have potential to harm non-target plants: picloram, glyphosate, and imazapyr. Less risk to non-target plants than No Action, more than Alternative B. Implementing Standard #16 would mitigate potential effects of chlorsulfuron, metsulfuron methyl, sulfometuron methyl, and triclopyr. 

Herbicide use on an estimated 2,000 acres annually includes one herbicides with greater potential to harm non-target plants: glyphosate Least risk to non-target plants. Implementing Standard #16would mitigate potential effect of triclopyr. 

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Number of herbicides included in each alternative that have known potential to cause toxic effects to honey bees 

Current herbicide list includes three herbicides with potential to harmpollinators (honeybees): 2,4-D, glyphosate and triclopyr. 

Herbicide list includes two herbicides with potential to harmpollinators (honeybees): glyphosate and triclopyr. Less risk to pollinators than No Action, more than Alternative B 

Herbicide list includes one herbicide with potential to harmpollinators (honeybees): glyphosate. Least risk to pollinators 

Sam

Appendix 2-3 
Preventing and Managing Invasive Plants Record of Decision September 2005 

Table S-2 Alternative Comparison/Decision Factors 

Factor for 

Comparison 

Current Direction/ 

No Action Proposed Action Alternative B 

Effects on birds and mammals Please note that the number of exposure scenarios is not influenced by the estimated acres treatedannually.

There are 25 plausible scenarios where herbicide exposure could harmindividual animals. Use of herbicides associated with these harmful exposure scenarios occurs on approximately 13,646acres annually 

There are 21 plausible scenarios where herbicide exposure could harm individual animals. Reduced risk to birds and mammals as compared to No Action. Use of herbicides associated with these scenarios is predicted to occur on about 9,000 acres annually

There are 12 plausible scenarios where herbicide exposure could harm individual animals. Reduced risk to birds and mammals as compared to Proposed Action. Use of herbicides associated with these scenarios is predicted to occur on about 2,500 acres annually.

ThwhharIncmaAcUswitpre27,

Number of herbicides included that may harm amphibians 

Three herbicides approved for use currently are known to potentially harmamphibians. 

Reduces herbicides from 3 to 1 known to potentially harmamphibians. 

Reduces herbicides from 3 to 1 known to potentially harmamphibians 

Sam

Worker exposure to manual treatment hazards 

Approximately 36,500 worker daysof exposure annuallyfrom manual treatments. 

Approximately 30,500 worker days of exposure annually frommanual treatments. Reduces potential for exposure as compared to No Action. 

Approximately 45,000 worker days of exposure annually frommanual treatments. Increases potential for exposure as compared to No Action. 

Apdaymapotcom

Appendix 2-4 
Preventing and Managing Invasive Plants Record of Decision September 2005 

Table S-2 Alternative Comparison/Decision Factors 

Factor for 

Comparison 

Current Direction/ 

No Action Proposed Action Alternative B 

Worker exposure to harmful doses of herbicide and/or NPE 

No plausible scenarios for harm to workers applying herbicides at typical application rates. Current Herbicide use is associated with an estimated 13 plausible scenarios that could harmworkers at maximumlabel rates. These scenarios are associated with herbicide use that occurs annually on about 12,281 acres. 

No plausible scenarios for harmto workers applying any approved herbicides at typical application rates. Projected herbicide use is associated with an estimated 11 plausible scenarios that could harm workers at maximum labelrates (less than No Action). These scenarios are associated with herbicide use that is projected to occur annually on about 4,960 acres under this alternative. 

No plausible scenarios for harmto workers applying any approved herbicides at typical application rates. Projected herbicide use is associated with an estimated 7 plausible scenarios that could harm workers at maximum labelrates (less than Proposed Action and No Action). These scenarios are associated with herbicide use projected to occur annually on about 508 acres under this alternative. 

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Appendix 2-5 
Preventing and Managing Invasive Plants Record of Decision September 2005 

Table S-2 Alternative Comparison/Decision Factors 

Factor for 

Comparison 

Current Direction/ 

No Action Proposed Action Alternative B 

Public Exposure to Harmful Doses of Herbicides and/or NPE (other than through drinking water contamination) 

No plausible scenarios for harm to the public fromherbicides applied at typical application rates. Currentherbicide use is associated with an estimated 9 plausible scenarios that could harm people when applied at maximumlabel rates. These scenarios are associated with herbicide use that occurs annually on about 591 acres. 

No plausible scenarios for harmto the public from herbicides applied at typical application rates. Herbicides allowed are associated with an estimated 4 plausible scenarios that could harm people when applied at maximum label rates (less than No Action). These scenarios are associated with herbicide use that is projected to occur on about 1,000 acres each year. 

No plausible scenarios for harmto the public from herbicides applied at typical application rates. Herbicides allowed are associated with an estimated 4 plausible scenarios that could harm people when applied at maximum label rates (same as Proposed Action). These scenarios are associated with herbicide use that is projected to occur on about 500 acres each year. 

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Potential for Drinking Water Contamination 

No scenarios known for herbicide to reach harmful concentrations in drinking water fromdrift. 

No scenarios known for herbicide to reach harmful concentrations in drinking water from drift. 

No scenarios known for herbicide to reach harmful concentrations in drinking water from drift. 

Onfor conwawooccann

Potential for drinking water contaminated by tanker spill into pond 

A tanker spill into a pond could reach harmful concentration; four plausible scenarios. 

A tanker spill into a pond could reach harmful concentration; seven plausible scenarios, morethan No Action. 

A tanker spill into a pond could reach harmful concentration; three plausible scenarios. 

A treanintha

Appendix 2-6 
Preventing and Managing Invasive Plants Record of Decision September 2005 

Table S-2 Alternative Comparison/Decision Factors 

Factor for 

Comparison 

Current Direction/ 

No Action Proposed Action Alternative B 

Effects on Existing uses/management activities on National Forest Estimated percentage increase in cost of heavy equipment work 

No increase. 2% increase in cost of heavy 

equipment work from adoption of prevention standards. 

11% increase in cost of heavyequipment work from adoption of prevention standards. 

Sam

Tendency for standards to result in road closures and loss of offhighway vehicle access 

No Direct Effect. New restrictions on OHV* use may occur from new national policy.

No new road closures expected from invasive plant prevention standards. OHV use allowed onlyon specifically designated roads, trails, and areas, based on implementation of draft National Policy. 

Tendency for more roads to be closed or decommissioned due to wording of standards. OHV use allowed only on specifically designated roads, trails, and areas, based on implementation of draft National Policy.

No resocc(Sa

Tendency for standards to affect grazing locations, timing, intensity and outputs

Reduces grazing levels, due to rangeland grazing capacities being diminished by invasive plants. 

Reduces grazing levels, due to more consistent applications of prevention measures. 

Highest tendency to reducegrazing levels, due to more rigid and consistent applications of prevention measures. 

Sam

Acres of National Forest where weed free feed would be required 

2.5 million 4.6 million (Wilderness Areas 

only)Increases costs of obtaining feed for pack stock, increases recreation administration costs accordingly.

24.9 million (all National Forests in the Region) Increases costs of obtaining feed for pack stock, increases recreation administration costs more than the Proposed Action. 

2.5 

Associated Costs 

Appendix 2-7 
Preventing and Managing Invasive Plants Record of Decision September 2005 

Appendix 2-8 

Table S-2 Alternative Comparison/Decision Factors 

Factor for 

Comparison 

Current Direction/ 

No Action Proposed Action Alternative B 

Average Cost of Treatment 

Approximately 25,000 acres per year can be treated given the current $4.1 million annual budget. 

Reduces average costs of treatment compared to No Action, so 5,000 more acres can be effectively treated each year. 

Increases average cost of treatment compared to No Action, so 5,000 fewer acres can be effectively treated each year. 

RedtreaAccan yea

* Off-Highway Vehicle Recreation – In this document, the term off-highway vehicle (OHV) refers to vehicles used for off-h

include 3 and 4 wheelers, motorcycles, dune buggies, 4x4 vehicles, and other motorized vehicles.