for the greatest good

Mt. Baker-Snoqualmie National 

Forest Invasive Plant Treatment

Draft Record of Decision

Whatcom, Skagit, Snohomish, King, and Pierce Counties, Washington 

March 2015

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Table of Contents

Introduction ...................................................................................................................................................1

Location and Area .........................................................................................................................................1

Background ...................................................................................................................................................3

Desired Condition .....................................................................................................................................4

Purpose and Need......................................................................................................................................4

Scoping..........................................................................................................................................................5

Decision.........................................................................................................................................................5

Policies and Management Direction Related to Invasive Plant Management...........................................8

Other Alternatives Considered ......................................................................................................................9

Alternative 1 – No Action.......................................................................................................................10

Why Alternative 1 was not Selected ...................................................................................................10

Alternative 3 – No Forest Plan Amendment, No Aminopyralid.............................................................11

Why Alternative 3 was not Selected ...................................................................................................11

Tribal Consultation and Public Involvement...............................................................................................11

Issues...........................................................................................................................................................12

Findings Required by Laws and Regulations..............................................................................................14

National Forest Management Act ...........................................................................................................15

Endangered Species Act of 1973 ............................................................................................................15

Plants...................................................................................................................................................15

Fish ......................................................................................................................................................16

Wildlife................................................................................................................................................16

Wilderness Act of 1964...........................................................................................................................16

Roadless Area Conservation Rule...........................................................................................................16

Wild and Scenic Rivers Act....................................................................................................................16

National Historic Preservation Act of 1966............................................................................................17

Migratory Bird Treaty Act of 1918 and Executive Order 13186............................................................17

Irreversible or Irretrievable Impacts........................................................................................................17

Long-term Productivity...........................................................................................................................17

Energy Requirements and Conservation Potential..................................................................................17

Prime Farmlands.....................................................................................................................................18

Executive Orders 11988 and 11990: Floodplains and Wetlands ............................................................18

Executive Order 13112: Invasive Species...............................................................................................18

Executive Order 12898: Environmental Justice......................................................................................18

Executive Order 13443: Facilitation of Hunting Heritage and Wildlife Conservation...........................19

Environmentally Preferred Alternative .......................................................................................................19

Pre-Decisional Administrative Review or Objection Opportunities...........................................................19

Implementation............................................................................................................................................21

Contact Person.............................................................................................................................................21

Attachment 1 ...............................................................................................................................................22

Post-Treatment Restoration (Revegetation) ........................................................................................27

Management Requirements and Mitigation Measures (MR/MM)......................................................27

Early Detection Rapid Response .........................................................................................................36

Implementation Planning Process .......................................................................................................37

Monitoring...........................................................................................................................................39

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

List of Tables

Table 1. Activities Included in Alternatives___________________________________________________________ 9

Table 2. Alternative Comparison, Issue Indicators ____________________________________________________ 12

Table 1- 1. Integrated Treatment Prescriptions – Selected Alternative____________________________________ 22

Table 1- 2. Management Requirements and Mitigation Measures_______________________________________ 27

Table 1- 3. Herbicide Use Buffers _________________________________________________________________ 36

List of Figures

Figure 1. Project area vicinity map _________________________________________________________________ 2

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Draft Record of Decision

Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment 

Environmental Impact Statement

Whatcom, Skagit, Snohomish, King, and Pierce Counties in Washington

Introduction

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

of the Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment Project. Alternative 2 is 

the environmentally preferred alternative. My decision authorizes a range of integrated invasive 

plant treatment and restoration methods that will be implemented across the Mt. BakerSnoqualmie National Forest for the next 5 to 15 years or longer.

My decision includes a non-significant amendment to the Mt. Baker-Snoqualmie National Forest 

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

for use as part of the integrated treatment toolbox for invasive plants on the Mt. BakerSnoqualmie National Forest (MBS).

In arriving at my decision, I have considered the analysis that is documented in the Mt. BakerSnoqualmie National Forest Invasive Plant Treatment Project Final Environmental Impact 

Statement (FEIS) (USDA Forest Service 2015), information in the project file, and input received 

from the public during the course of the analysis of this project as required by the National 

Environmental Policy Act (NEPA) of 1969.

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

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

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

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

Location and Area

The project area includes the entire Mt. Baker-Snoqualmie National Forest, wherever invasive 

plants are found now or into the future. Figure 1 displays the vicinity of the project within the Mt. 

Baker –Snoqualmie National Forest. 

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Figure 1. Project area vicinity map

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Background

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

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

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

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

On the Mt. Baker-Snoqualmie National Forest (MBS or the Forest), about 40 species of invasive 

plants have been mapped within 936 sites, totaling approximately 4,0001 infested acres. The 

project area includes the entire Mt. Baker-Snoqualmie National Forest, totaling about 1,724,229

acres. 

In 2005, the Mt. Baker-Snoqualmie Environmental Assessment and Decision Notice for 

Treatment of Invasive Plants and New Invaders Strategy (MBS 2005 EA/DN) were published. At 

that time, 90 invasive plant sites were mapped on the Forest, and most of the sites were smaller 

than 0.1 acre. The more than ten-fold increase in invasive species is partly due to increased 

awareness and mapping, however, this is also because the MBS 2005 DN has not resulted in 

effective treatment of the existing invasive plants. Since 2005, invasive plants have been located 

in wilderness areas on the MBS.

Soon after the MBS 2005 DN was signed, the Regional Forester signed the Pacific Northwest 

Region Invasive Plant Program, Preventing and Managing Invasive Plants Record of Decision 

(R6 2005 ROD). The R6 2005 ROD added management direction for invasive plants to the MBS 

Land and Resource Management Plan (Forest Plan 1990), including a list of approved herbicides. 

Since the publication of the R6 2005 ROD, a new herbicide, aminopyralid, has been found to 

have lower risk to aquatic organisms than previously approved herbicides and higher 

effectiveness on many broadleaf invasive plant species found on the Forest. 

In 2008, the Skiyou Island Invasive Weeds Decision Notice was signed (MBS 2008 DN). This 

project allowed for broadcast of glyphosate and metsulfuron methyl (one of the herbicides 

analyzed in the R6 2005 FEIS), as a part of a vegetation restoration project at Skiyou Island in the 

Skagit River drainage. Also in 2008, the Forest Supervisor found that use of two additional 

herbicides analyzed in the R6 2005 FEIS (clopyralid and imazapyr) as a replacement for aquatic 

glyphosate on some sites would not result in adverse effects beyond the scope of the MBS 2005 

DN, based on a supplemental information report (MBS 2008 SIR). 

1 When acres are counted for each invasive plant target species, the total acreage is 4,878 (about 20 percent 

of the infested areas contain more than one invasive plant species). Since treatment options and timing of 

treatment vary by target species, this document frequently cites the amount of treatment acres as 4,878. 

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Desired Condition

The desired condition relative to invasive plant management in the R6 2005 ROD is:

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.

To meet this desired condition, invasive plants would be contained, controlled or eradicated,2 and 

desirable vegetation would be restored on approximately 4,000 infested acres of National Forest 

System land. New or spreading invasive plants would be treated as quickly as possible after 

detection. Invasive plant treatments would be conducted in a manner that minimizes or eliminates 

human health and environmental risks from treatment activities. Reaching this desired condition 

could take 5 to 15 years depending on funding and site-specific response to treatment. 

Purpose and Need

In this project, the Forest Service is responding to the underlying need for timely containment, 

control, or eradication of invasive plants, including those that are currently known and those 

discovered in the future. The purpose of the project is to achieve the desired condition in the most 

cost-effective manner possible, while meeting R6 2005 ROD and other Forest Plan management 

direction and minimizing adverse impacts to people and the environment. The more cost-effective 

the treatments considered, the more likely that the purpose and need will be met. 

Treatments and planning processes that are currently authorized in the 2005 MBS DN lack 

sufficient tools and efficiency to achieve timely eradication, containment and control of invasive 

plants. The following are examples of how the current program has not met treatment needs: 

The herbicides approved in the MBS 2005 DN are not always effective on the invasive 

plant target species here. For example, glyphosate has been repeatedly applied to 

hawkweed (in the sunflower family) along the Mountain Loop Highway, yet this target 

species continues to increase. Additional herbicide options are needed to most effectively 

treat several invasive species found on the Forest. 

Since the publication of the R6 2005 ROD, a new herbicide, aminopyralid, has been found 

to have lower risk to aquatic organisms than previously approved herbicides and higher 

effectiveness on some aggressive broadleaf invasive plant species, such as hawkweeds and 

knapweeds. A Forest Plan amendment is needed to add this herbicide to the list of 

approved ingredients for invasive plant treatment.

The MBS 2005 DN did not authorize broadcast spraying; however, spot treatments are not 

effective in treating some higher density or larger invasive sites.The broadcast spray 

method is needed to increase the effectiveness of herbicide applications in some locations.

2 A spreadsheet showing the treatment objective for each infested area is available on line at 

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=34208. “Eradication” means that invasive plants 

are completely removed from a site. “Control” means that invasive plants have been reduced to low levels 

on a site. “Containment” means that an invasive plant treatment site is not growing larger. 

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

New sites have been detected in wilderness areas since 2005. The MBS 2005 DN did not 

explicitly address treatments of new invaders in wilderness areas. The ability to treat 

wilderness infestations is needed to minimize the potential for invasive plants to spread 

within wilderness areas. Currently, six sites in three wilderness areas are in the mapped 

inventory. About 34 miles of old roads in the Wild Sky Wilderness are unsurveyed but 

likely contain invasive plants (a recent survey indicates invasive plants are present that 

were not previously mapped.). Many more trails have not been surveyed but may contain 

invasive plants. These areas are a high priority to treat to maintain native plant 

communities within the wilderness. Rapid treatment of wilderness infestations while they 

are small improves the chances of successfully controlling or eradicating invasive plants 

in the wilderness, and reduces the potential for impact on wilderness character. 

The MBS 2005 DN did not authorize any mechanical mowing or motorized string 

trimmers. This method is needed as part of the effective integrated treatment program.

The strategy for new invaders in the MBS 2005 DN did not provide rapid enough 

response, for example, common comfrey invaded a log deck and waste rock disposal site 

in 2008 and tripled in density within 1 year. Increased efficiency in early detection and 

rapid response to new invaders is needed to reduce the potential for them to become 

established or spread.

Scoping

Public scoping on this Proposed Action was initiated during fall 2010. In spring 2012, additional 

scoping was conducted to include additional invasive plant populations and wilderness sites. At 

this point in the analysis, the Forest Supervisor decided that an Environmental Impact Statement 

(EIS) would be appropriate to document potential effects of the proposed treatment so a Notice of 

Intent to prepare an EIS was published in the Federal Register on February 28, 2012. 3

During the 2010 scoping period, comments were received from 1 agency, 2 organizations and 3 

other people. During the 2012 scoping period, comments were received from 4 agencies, 1 

organization, 1 American Indian Tribal member (see above), and 10 other people. Scoping 

outreach and responses are in the Project Record. 

Decision

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

Alternative 2, the proposed action for the Mt. Baker-Snoqualmie National Forest Invasive Plant 

Treatment Project. This alternative is the most cost-effective approach to invasive plant treatment 

while minimizing the potential adverse effects of treatment according to the Mt. BakerSnoqualmie National Forest Plan as amended by the R6 2005 ROD.

Invasive plant treatments will be completed according to integrated treatment prescriptions (see 

Attachment 1, Table 1- 1) and Management Recommendations /Mitigation Measures (MR/MM, 

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

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

3 Scoping in 2012 included 195 acres in the Yakima River watershed that were removed from analysis in 

the MBS Invasive Plant Treatment EIS, but will be addressed by planning conducted on the OkanoganWenatchee National Forest. The scoping proposal in 2012 also contained a 113.1-acre site (Treatment 

Analysis Area 54) that was later found to not contain invasive plants, so was dropped from the analysis. 

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

(Chapter 2.4.6 and 2.4.7). My decision includes monitoring to ensure that the treatments are 

implemented properly and adverse effects are minimized. See Attachment 1 for a detailed 

description of the elements of Alternative 2. 

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

plants. It would allow the most effective treatment method and herbicide ingredient on all known 

infestations. Alternative 2 has the best chance of controlling and eradicating populations of 

invasive plants, including the largest, densest and most aggressive noxious weeds sites on the 

MBS. The total cost of treating known infestations and restoring favorable vegetation in a 4-year 

period would be least for this alternative. The average cost per restored acre is least. Given a fixed 

budget and current funding levels, Alternative 2 is estimated to take 12 to 13 years or more to 

accomplish (MBS FEIS 3.2.3).

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

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

proposed; the MR/MM; the Forest Plan standards; and the Forest Service pesticide use policy 

together minimize potential for worker and public exposure. The herbicide triclopyr is associated 

with relatively greater risks. This herbicide is the first choice for about 15 acres of current 

infestations (thus very little of this herbicide is likely to be used). Risks are mitigated by 

restrictions on the method of application (no broadcast of triclopyr) and extra caution relative to 

use around edible fruit (e.g., blackberries); given the low extent and mitigation measures, risks 

would not be substantially increased over the No-Action Alternative (FEIS Chapter 3.3.3)

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

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

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

maximum rates, are below 1). Use of aminopyralid could reduce the potential for human health 

effects compared to the other alternatives, especially where it could be effective as an alternative 

to triclopyr (ibid.).

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

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

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

Management Requirements and Mitigation Measures project minimizes the potential for native 

plants to be adversely affected (FEIS 3.4.3).

Invasive plant treatments proposed under Alternative 2 would not alter habitat structure or 

composition for terrestrial wildlife species (FEIS Chapter 3.5.3). The project would be beneficial 

to wildlife. Negative impacts to wildlife, including species of local interest, are far more likely 

with invasive plants than with the treatments proposed. The current infestations amount to 

approximately 0.3 percent of the Mt. Baker-Snoqualmie National Forest. The Forest is 1.7 million 

acres in western Washington, and treatments are limited to no more than 5,000 acres per year 

total. This cap, along with realistic budget constraints, further limits the size of treatments in any 

one location in sensitive wildlife habitats. Infestations, and therefore treatments, are primarily 

along roadsides and other disturbed sites, which do not provide quality habitat for most wildlife. 

While some infestations do occur in important wildlife habitat like early seral stage vegetation or 

wetlands, MR/MM and herbicide use buffers minimize which the potential for adverse exposure 

so much that there is virtually no potential for exposures to accumulate and cause harm to any 

habitat or species (FEIS Chapter 3.5.3).

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Invasive plant treatments will not adversely affect soil biology or productivity. Restrictions on the 

rate, type, and frequency of specific herbicides would reduce herbicide build up in the soil and 

impacts on soil organisms or productivity (FEIS Chapter 3.6.3). Most of the herbicides adsorb to 

soil within the top 20 inches; below 40 inches, only trace amounts remain (ibid). Picloram, 

imazapyr, and metsulfuron methyl have very slow decay rates once they move below the 

biologically active soil layer. The application of these herbicides is limited to once every other 

year to limit risk for accumulating these herbicides in groundwater. Aminopyralid can have a 

moderately slow degradation rate and thus would be limited to one application per year to avoid 

buildup in groundwater.

None of the alternatives are likely to have substantial impacts on water resources. Some 

herbicides may reach water but no beneficial uses of water would be adversely affected; effects 

would be positive to the extent that riparian habitat is improved (FEIS Chapter 3.7.3). 

Herbicide use in accordance with the herbicide use buffers and the MR/MM would keep 

herbicides from reaching streams to a minimum, and no adverse effects to beneficial uses are 

expected. The use of aminopyralid would improve the Forest Service’s ability to treat invasive 

plants near water, which would help restore riparian habitats (ibid.). 

MR/MM limit the potential for herbicides to enter water in the action alternatives, including: 

MR/MM 7 (weather conditions and nozzle size); MR/MM 8 (herbicide transportation and 

handling safety); MR/MM 19 (limitations on acreage treated annually within riparian reserves); 

MR/MM 22 (restrictions on mixing of herbicides near streams); MR/MM 25 (restrictions on use 

of herbicides on seasonally high water tables); and MR/MM 27 (limits herbicide use on sites 

more prone to run off). Treatments would not add measurable amounts of organic matter or 

nutrients to streams or lakes or further degrade water chemistry due to the discontinuity of the 

treatments, limited spatial scale, and required mitigation measures (ibid.).

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

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

Act (FEIS Chapter 3.8.3). Alternative 2 would result in long-term restoration where natural plant 

communities and disturbance regimes have been altered by invasive plants. Alternative 2 has the 

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

MR/MM would minimize the potential for adverse effects on fish and habitat. None of the 

chemicals proposed for use would result in long-term adverse alteration of aquatic habitat. The 

impacts of invasive plants on the environment can last decades, while the impacts of treatment 

tend to be short term (weeks or less). Active restoration at selected sites would accelerate native 

vegetative recovery in treated areas (ibid). Herbicide use buffers in the alternatives would 

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

amount of herbicide coming in contact with water after application of herbicide use buffers would 

be minimized to near non-detectable levels (ibid).

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

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

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

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

(FEIS Chapter 3.9.3). Adverse effects to outstandingly remarkable values on Wild and Scenic 

Rivers would be minimal given the MR/MM and herbicide use buffers. In the long run, treatment 

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

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

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

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

Invasive plant treatments are unlikely to adversely affect heritage sites (FEIS Chapter 3.10.3).

Alternative 2 is my selected alternative given the low likelihood of serious adverse effects. 

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

Policies and Management Direction Related to Invasive 

Plant Management

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

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

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

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

The R6 2005 ROD (Mt. Baker-Snoqualmie National Forest Plan) also provides management 

direction for this project. The R6 2005 ROD lays out several objectives for invasive plant 

management including: 

Objective 1.3: Detect new infestations of invasive plants promptly by creating and 

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

and inspecting susceptible areas not infested with invasive plants.

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

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

biological control.

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

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

treated sites to prevent reestablishment.

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

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

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

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

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

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

is consistent with riparian management direction.

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

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

species and maintain species viability.

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

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

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

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

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Other Alternatives Considered

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

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

alternative analyzed in detail compared to the selected alternative. 

Table 1. Activities Included in Alternatives

No Action 

(Alternative 1)

Proposed Action 

(Alternative 2)

No Aminopyralid 

(Alternative 3)

Treatment 

Methods

Manual, biological and 

chemical (herbicide)

Manual, mechanical, cultural, 

biological, and chemical 

(herbicide)

Manual, mechanical, cultural, 

biological, and chemical 

(herbicide)

Herbicides 

Approved

Clopyralid

Aquatic glyphosate

Aquatic imazapyr 

Metsulfuron methyl 

(Skiyou Island only)

Aminopyralid

Chlorsulfuron

Clopyralid

Glyphosate

Imazapic

Imazapyr

Metsulfuron methyl

Picloram

Sulfometuron methyl

Triclopyr

Chlorsulfuron

Clopyralid

Glyphosate

Imazapic

Imazapyr

Metsulfuron methyl

Picloram

Sulfometuron methyl

Triclopyr

Risk From 

Invasive Plants

Invasive plants may 

continue to threaten 

native plant 

communities, wildlife 

habitats and riparian 

areas.

Most likely to reduce threats 

from invasive plants

Less likely to reduce threats 

from invasive plants because 

aminopyralid would not be 

approved for use.

Forest Plan

Amendment No Yes No

Application 

Methods

Selective and spot 

(broadcast at Skiyou 

Island only)

Broadcast, spot and selective Broadcast, spot and selective

Potential 

Broadcast Acres 

(Known Sites, 

First Year 

Treatment)

About 212 at Skiyou 

Island using 

glyphosate and 

metsulfuron methyl

2,470 using aminopyralid, 

clopyralid, glyphosate and 

metsulfuron methyl

2,407 using clopyralid, 

glyphosate and metsulfuron 

methyl

Treatment 

Acreage 

Limitations

None

5,000 per year, 13,500 over 

the life of the project, 18% of 

the area within 150 feet of a 

stream annually

5,000 per year, 13,500 over 

the life of the project, 18% of 

the area within 150 feet of a 

stream annually

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

No Action 

(Alternative 1)

Proposed Action 

(Alternative 2)

No Aminopyralid 

(Alternative 3)

EDRR Approach Annual pre-season list

Develop site prescriptions and 

address any resources of 

concern. Use criteria in 

“decision to use herbicide” to 

determine preferred method. 

Integrate MR/MM into 

implementation prescription 

based on site conditions. 

Treat as soon as possible after 

finding new sites. Treatments 

would not be limited to those 

identified in a pre-season 

report.

Develop site prescriptions and 

address any resources of 

concern. Use criteria in 

“decision to use herbicide” to 

determine preferred method. 

Integrate MR/MM into 

implementation prescription 

based on site conditions. 

Treat as soon as possible after 

finding new sites. Treatments 

would not be limited to those 

identified in a pre-season 

report.

Alternative 1 – No Action

Under the No-Action Alternative, the MBS 2005 DN and 2008 Skiyou Island Invasive Weeds 

Decision Notice (2008 Skiyou Island DN) would continue to guide invasive plant treatments 

within the project area (Forest). These decisions authorized the following treatments: 

Pulling, cutting, or digging by hand or with non-motorized tools

Use of biological control agents 

Cultural treatments such as competitive seeding and tarping

Restoration of treated sites

Spot and selective herbicide using aquatic glyphosate, imazapyr, or clopyralid

Limited broadcast at Skiyou Island, using glyphosate and metsulfuron methyl

Use of the surfactant Agri-Dex®

Why Alternative 1 was not Selected

The FEIS describes why the No-Action Alternative (Alternative 1) is the least effective 

alternative (FEIS Chapter 3.2.3). Alternative 1 would not have been likely to result in eradication 

and/or control of dense or large infestations. It would have likely been the most costly 

alternative, with the least favorable results. Ground disturbance in close proximity to already 

infested ground would have been at highest risk for invasive plant spread (FEIS Chapter 3.6.3). 

Threats to native vegetation would have been greatest in this alternative (FEIS Chapter 3.4.3). 

Habitat for a variety of wildlife could have degraded to a point that it becomes unsuitable. 

Infestations could have become so well-established that future treatment would have been costprohibitive, eventually resulting in a permanent loss of wildlife habitat (FEIS Chapter 3.5.3).

Alternative 1 would have included the most extensive use of glyphosate, especially within 

riparian areas (FEIS Chapter 3.7.3). Under Alternative 1, invasive plants would have continued to 

grow and spread in wilderness and along the Wild and Scenic Rivers, which would have the 

potential to disrupt natural processes. The scenic integrity could be reduced and wilderness 

character could be adversely impacted by invasive plant expansion into native plant communities. 

Treatments that are currently approved have not kept up with treatment needs, which may result 

in reduced plant diversity and a loss of scenic value (FEIS Chapter 3.9.3).

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

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

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

the action alternatives. 

Alternative 3 – No Forest Plan Amendment, No Aminopyralid

Alternative 3 is described in detail in Chapter 2.3.4 of the FEIS. Alternative 3 was developed to 

evaluate the tradeoffs involved with adding aminopyralid to the list of available herbicides for use 

on the Mt. Baker-Snoqualmie National Forest. Under this alternative, no aminopyralid would 

have been used, and the Forest Plan would not have been amended. More clopyralid, metsulfuron 

methyl and triclopyr would have likely been used in comparison to Alternative 2. 

All of the MR/MM and herbicide-use buffers associated with Alternative 2 would have applied, 

except for those that refer to use of aminopyralid. The herbicide-use rates, MR/MM and 

herbicide-use buffers associated with aminopyralid would have become non-applicable. 

Why Alternative 3 was not Selected

I did not select Alternative 3 because it would have been less effective and more costly, and 

would not have reduced risks associated with herbicide use. It would have reduced our ability to 

eradicate, control or contain invasive plants. It would not have reduced environmental risks 

compared to Alternative 2. 

Alternative 3 would have reduced options for effectively treating about 274 acres near streams. If 

Alternative 3 were selected, more triclopyr (about 150 acres in Alternative 3 versus 15 acres in 

Alternative 2) would likely need to be used. Triclopyr may be associated with greater risks to 

human health than other herbicides proposed for use (FEIS Chapter 3.3.3). 

Tribal Consultation and Public Involvement

Government to Government consultation letters regarding the project were sent to the following 

local Tribes on 2/24/2012: Lummi Nation, Muckleshoot Indian Tribe, Nisqually Indian Tribe, 

Nooksack Indian Tribe, Puyallup Tribe, Samish Tribe, Sauk-Suiattle Tribe, Snoqualmie Tribe, 

Stillaguamish Tribe, Suquamish Tribe, Swinomish Indian Tribal Community, the Upper Skagit 

Tribe, the Tulalip Tribes and the Yakama Tribe. Follow up calls were made to the tribes to seek 

comments.

The Snoqualmie Tribe responded (4/16/2012) with a concern that herbicide treatment might occur 

near traditional harvest areas. No other replies were received from American Indian Tribal 

governments regarding this project. 

Public scoping on this Proposed Action was initiated during fall 2010. In spring 2012, additional 

scoping was conducted to include additional invasive plant populations and wilderness sites. At 

this point in the analysis, the Forest Supervisor decided that an Environmental Impact Statement 

(EIS) would be appropriate to document potential effects of the proposed treatment so a Notice of 

Intent to prepare an EIS was published in the Federal Register on February 28, 2012. 

During the 2010 scoping period, comments were received from 1 agency, 2 organizations and 3 

other people. During the 2012 scoping period, comments were received from 4 agencies, 1 

organization, 1 American Indian Tribal member (see above), and 10 other people. Scoping 

outreach and responses are in the Project Record.

11
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Issues

Two key issues were identified: 

Treatment effectiveness

Herbicide toxicity 

Table 2 displays the comparison of alternatives in terms of issue indicators.

Table 2. Alternative Comparison, Issue Indicators

Issue and Indicator Alternative 1 Alternative 2 Alternative 3

Cost-Effectiveness: 

Estimated total cost in 

dollars for treating known 

sites known sites 

treatment plus restoration

2,719,000 2,535,600 2,630,400

Cost-Effectiveness: 

Estimated average cost per

treated/restored acre in 

dollars

557 520 539

Cost-Effectiveness: Years 

to effectively treat known 

sites assuming annual 

budget of $200,000 per 

year

14 12-13 13

Cost-Effectiveness: 

Estimated maximum cost 

in dollars, assuming 

average cost treatment 

plus restoration applied to 

known sites plus 13,500 

acres of EDRR sites

NA 9.5 million 10 million

Cost-Effectiveness: 

Estimated acres where 

ability to control or 

eradicate target species 

may be compromised due 

to broadcasting restrictions 

1,200 0 274

Herbicide Toxicity/Human 

Health: Number and 

character of “plausible 

exposure scenarios” where 

“Hazard Quotient” may be 

greater than 1 for 

herbicide applicators 

(workers)

none

Triclopyr HQ = 1.5 for a 

worker wearing 

contaminated gloves 

(15 “first year/first 

choice” acres)

Triclopyr HQ = 1.5 for a 

worker wearing 

contaminated gloves 

(143 “first year/first 

choice” acres)

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Issue and Indicator Alternative 1 Alternative 2 Alternative 3

Herbicide Toxicity/Human 

Health: Number and 

character of “plausible 

exposure scenarios” where 

“Hazard Quotient” may be 

greater than 1 for the 

public 

none

Triclopyr HQ = 7.8 for 

consumption of 

contaminated 

vegetation (15 “first 

year/first choice” acres)

Triclopyr HQ = 7.8 for 

consumption of 

contaminated 

vegetation (143 “first 

year/first choice” acres)

Herbicide Toxicity/Human 

Health: Character and 

effectiveness of 

Management 

Requirements and 

Mitigation Measures 

(MR/MM) intended to 

minimize or eliminate risk 

to human health

MR/MM minimize 

risks; herbicide 

ingredients pose low 

risks to human health

MR/MM minimize risks; 

risk is greater than 

Alternative 1 due to 

inclusion of triclopyr, 

less than Alternative 3

due to inclusion of 

aminopyralid.

MR/MM minimize risks; 

risk is greater than 

Alternative 1 due to 

inclusion of triclopyr.

Herbicide Toxicity/Botany: 

Relative risk to botanical 

species of conservation 

concern from herbicide use

Very Low, no 

broadcast near rare 

plants. Non-selective 

herbicide use may be 

needed near water 

(glyphosate). 

Very Low; broadcast 

treatments are 

proposed in 7 TAAs 

where botanical species 

of conservation concern 

are located, however 

MR/MM would 

minimize risk. Use of 

aminopyralid is likely to 

decrease risk compared 

to non-selective 

herbicide use. 

Low; broadcast 

treatments are 

proposed in 7 TAAs 

where botanical species 

of conservation concern 

are located, however 

MR/MM would 

minimize risk. Nonselective herbicide use 

may be needed near 

water (glyphosate).

Herbicide Toxicity/Wildlife: 

Relative risk to wildlife 

from herbicide use

Invasive plant 

treatments are 

primarily along 

roadsides and other 

disturbed sites, 

which do not provide 

quality habitat for 

most wildlife. 

MR/MM minimize 

the potential for 

adverse exposure.

Same as Alternative 1 Same as Alternative 1

13
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Issue and Indicator Alternative 1 Alternative 2 Alternative 3

Herbicide Toxicity/Aquatic 

Organisms: Relative risk to 

aquatic organisms from 

herbicide use

Herbicide use poses 

relatively low risk of 

impact to aquatic 

organisms. Aquatic 

glyphosate poses risk 

of non-lethal impact 

to fish, however the 

MR/MM minimize 

the potential for 

herbicide to reach 

streams. 

Same as Alternative 1. Same as Alternative 1

Herbicide Toxicity/Aquatic 

Organisms: First year/first 

choice use of aquatic 

glyphosate or triclopyr 

within aquatic influence 

zones

961 acres of aquatic 

glyphosate

926 acres of aquatic 

glyphosate

939 acres of aquatic 

glyphosate and 12 acres 

aquatic triclopyr

Findings Required by Laws and Regulations

This decision to implement the Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment 

Project is consistent with the intent of the forest plan's long term goals and objectives listed on 

page 4-135 of the Mt. Baker-Snoqualmie Forest Plan and in amendments to the Forest Plan since 

1990: 

Final Supplemental Environmental Impact Statement on Management of Habitat for Late

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

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

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

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

Best Management Practices for Prevention of Noxious Weeds (MBS 1999, 2005)

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

and Managing Invasive Plants (R6 2005 ROD).

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

National Forest Management Act

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

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

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

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

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

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

and resource management.

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

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

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

3. Minor changes in standards and guidelines.

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

management prescription.

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

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

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

management area boundaries or management prescriptions on the MBS National Forest.. The 

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

is not currently listed among the ten herbicides approved by the Regional Forester in 2005 (R6 

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

and demonstrates that use of this herbicide will not pose new or significant risks compared to the 

ten already approved. FEIS table 21 (Chapter 3.1.2) shows a comparison between aminopyralid 

and the herbicides already approved. Aminopyralid is generally a lower risk herbicide and the 

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

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

aminopyralid to the list of approved herbicides on the MBS National Forest. Aminopyralid is an 

herbicide that is very effective for most of the invasive plant species found within the MBS

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

requires less restrictions than most of the other herbicides already approved in the LRMP (for 

instance it can be broadcast sprayed to the water’s edge, which will improve treatment 

effectiveness and efficiency relative to other herbicides). Authorizing the use of aminopyralid 

will not foreclose on opportunities for additional projects or activities that will contribute to 

achievement of the management prescription. It will make those projects more effective in 

controlling invasive plants.

Endangered Species Act of 1973

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

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

with USFWS. 

Plants

No botanical species are federally listed as threatened, endangered or proposed for listing.

15
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Fish

Consultation with the US Fish and Wildlife Service and National Marine Fisheries concluded that 

the proposed action “may affect and is likely to adversely affect” (LAA), but will not jeopardize 

the continued existence of, Puget Sound Chinook salmon, Puget Sound steelhead, Bull trout or 

result in the destruction or adverse modification of their designated or proposed critical habitat. 

Analysis and discussion of the impacts resulting in the conclusions of LAA for effects to ESAlisted fish species and LAA for effects to critical habitat are found in the Biological Assessment 

(BA). In summary: 

1. Impacts to Baseline Conditions for Matrix Indicators: Riparian area invasive plant 

treatment will be conducted in a manner as to “Maintain” long-term water quality with 

respect to chemical contamination and nutrients, with limited short-term adverse effects. 

While best management practices will minimize adverse effects, modeling from the 

worst case scenario suggests that some short term impact could occur to aquatic plants 

and thus affect primary production for fish species. 

2. Effects to Individual ESA-listed Fish: The combination of application methods, low 

toxicity herbicides, project design criteria and mitigation measures are likely to restrict 

adverse effects from herbicide exposures on listed fish to infrequent, short-term 

occurrences. While the exposure is infrequent and short term, some adverse impacts to 

fish could not be ruled out. 

3. Effects to Critical Habitat: The analysis of effects to habitat indicators corresponding to 

water quality indicate that some short term impact could occur to aquatic plants that may 

affect primary production and subsequent ecosystem processes for listed fish species. 

These impacts again are expected to be short term and limited in any adverse effects. 

Wildlife

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

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

northern spotted owl, marbled murrelet, grizzly bear, and gray wolf. The project has a low 

likelihood of herbicide exposure to wildlife and low level of disturbance from human activities. 

The wildlife biologist found “No Effect” to designated critical habitat for the northern spotted owl 

and marbled murrelet.

Wilderness Act of 1964

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

Roadless Area Conservation Rule

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

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

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

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

Wild and Scenic Rivers Act

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

16
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

National Historic Preservation Act of 1966

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

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

Migratory Bird Treaty Act of 1918 and Executive Order 

13186

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

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

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

Irreversible or Irretrievable Impacts

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

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

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

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

roadless areas or degradation of roadless area quality will occur. 

Long-term Productivity

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

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

communities is lost. 

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

project design feature (MR/MM) that reduce or eliminate the potential for adverse effects. 

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

These include:

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

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

large herbicide spill. The MR/MM make the potential for a large spill extremely unlikely.

Minor to moderate physical injuries during forestry work are possible.

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

sensitive to certain herbicides. However, the MR/MM address the potential for long-term 

impact to soil organisms or productivity. 

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

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

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

the potential for adverse effects of treatment.

Energy Requirements and Conservation Potential

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

used.

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Prime Farmlands

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

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

Baker-Snoqualmie National Forest to prime farmlands.

Executive Orders 11988 and 11990: Floodplains and 

Wetlands

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

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

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

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

Executive Order 13112: Invasive Species

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

Specifically:

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

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

environmentally sound manner; (iii) monitor invasive species populations 

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

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

invasive species and develop technologies to prevent introduction and provide for 

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

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

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

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

unless, pursuant to guidelines that it has prescribed, the agency has determined 

and made public its determination that the benefits of such actions clearly 

outweigh the potential harm caused by invasive species; and that all feasible and 

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

actions.

Executive Order 12898: Environmental Justice

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

Populations and Low Income Populations, directs federal agencies to address effects accruing in a 

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

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

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

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

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

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

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

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

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

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

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

18
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

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

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

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

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

Executive Order 13443: Facilitation of Hunting Heritage and 

Wildlife Conservation

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

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

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

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

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

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

Environmentally Preferred Alternative

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

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

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

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

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

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

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

MR/MM, herbicide use buffers and other limitations necessary to ensure protection of the natural 

and human environment.

Pre-Decisional Administrative Review or 

Objection Opportunities

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

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

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

to 36 CFR Part 218, subparts A and B. My decision includes a Forest Plan Amendment. 

The Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment Project was originally 

scoped under the provisions of 36 CFR Part 215. For this project, individuals or organizations 

who submitted specific, written comments in response to scoping conducted under 36 CFR Part 

215 or provided comments to the draft environmental impact statement will be considered to have 

standing to object under 36 CFR Part 218, Subparts A and B.

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

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

after the designated comment opportunities.

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

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

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

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

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

objection filing period. 

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

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

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

holidays.

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

2339The fax coversheet must include a subject line with “Mt. Baker-Snoqualmie National Forest 

Invasive Plant Treatment Project” and should specify the number of pages being submitted.

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

objections-pnw-regional-office@fs.fed.us. with “Mt. Baker-Snoqualmie National Forest Invasive 

Plant Treatment Project” in the subject line. Electronic submissions must be submitted in a format 

that is readable with optical character recognition software (e.g., MS Word, PDF, Rich Text

Format) and be searchable. An automated response should confirm your electronic objection has 

been received.

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

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

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

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

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

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

objected to, the name and title of the responsible official, and the name of the national forest and 

ranger district on which the project will be implemented; (5) a description of those aspects of the 

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

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

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

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

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

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

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

the objection must be included with the objection.

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

“Legal Notice of the Opportunity to Object” for this project in the Everett Herald, the newspaper 

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

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

means for calculating the time to file an objection. Those wishing to object this project should not 

rely upon dates or timeframe information provided by any other source.

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

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

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

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

objection pursuant to 36 CFR § 218.10.

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Implementation 

The Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment Project may be 

implemented after the completion of the objection process and immediately upon my issuance of 

a signed Record of Decision. I will notify interested or affected parties of the availability of this 

ROD as soon as practicable after signing (36 CFR § 220.5(g)).

Contact Person

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

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

contact Phyllis Reed, Project Coordinator by e-mail at plreed@fs.fed.us or by telephone at 360-

436-2332.

JENNIFER EBERLIEN [DATE]

Forest Supervisor

Mt. Baker-Snoqualmie National Forest

21
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Attachment 1 

Table 1- 1. Integrated Treatment Prescriptions – Selected Alternative 

Target species 

(Common Name)

Approx. 

Number 

of Sites

Approx. 

Acreage 

Infested

1

First Choice 

Herbicide (those 

NOT available in 

current program are 

bolded)

Other Possible Herbicides (those 

NOT available in current 

program are bolded)

Effective Non-Herbicide Treatments (alone 

or in combination with herbicide use)

Absinth wormwood 1 2 Aminopyralid Clopyralid

Glyphosate Non-herbicide treatments are not effective.

Birds-foot trefoil 2 22 Clopyralid

Aminopyralid

Triclopyr

Glyphosate

Manual digging. Removing flowering plants, 

non-flowering can be left on site to dry.

bittersweet nightshade 1 <1 Glyphosate

Imazapyr

Triclopyr

Imazapic

Manual digging. All plant parts should be 

removed from site.

Black locust 1 <1 Triclopyr Glyphosate Hand cutting

Bull thistle 107 63 Aminopyralid

Glyphosate

Triclopyr

Clopyralid

Effective biological control agents. Manual 

pulling and digging. Leave roots on site to dry, 

bag seed heads if present

Butterfly bush 15 22 Glyphosate Triclopyr

Imazapyr

Effective biological control agents. Manual 

pulling, digging and cutting. Rhizomatous, 

suckering plants, remove all plant parts from 

site.

Canada thistle 159 404 Aminopyralid

Picloram

Clopyralid

Glyphosate

Chlorsulfuron

Effective biological control agents.

Common burdock 2 <1 Triclopyr

Clopyralid

Glyphosate

Aminopyralid

Manual pulling and digging. Seeds to be 

removed from site, all other plant parts can 

remain on site.

Common comfrey 3 <1 Glyphosate Clopyralid Non-herbicide treatments are not effective.

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Target species 

(Common Name)

Approx. 

Number 

of Sites

Approx. 

Acreage 

Infested

1

First Choice 

Herbicide (those 

NOT available in 

current program are 

bolded)

Other Possible Herbicides (those 

NOT available in current 

program are bolded)

Effective Non-Herbicide Treatments (alone 

or in combination with herbicide use)

Common groundsel 4 <1 Clopyralid Glyphosate

Manual pulling and digging Non-flowering 

plants can be left on site, remove plants that 

are in bud/flowering stage.

Common periwinkle 4 <1 Glyphosate Triclopyr

Picloram

Manual pulling, raking and digging. Can be left 

on site to dry.

Common tansy 19 73

Metsulfuron methyl

(Approved Currently 

At Skiyou Island)

Chlorsulfuron

Glyphosate

Manual digging. Remove all flower/seed heads 

from site, all other plant parts can be left at 

site.

Common teasel 1 <1

Triclopyr

Clopyralid\

Glyphosate

Metsulfuron methyl

Chlorsulfuron

Imazapic

Non-herbicide treatments are not effective.

Cutleaf blackberry 12 32 Triclopyr Glyphosate Manual pulling and digging. All plant parts can 

be left on site to dry.

Dalmatian toadflax 8 24 Chlorsulfuron

Picloram

Imazapic

Metsulfuron methyl

Glyphosate

Effective biological control agents. Manual 

pulling and digging. All parts except seeds can 

be left on site.

Diffuse knapweed 3 41 Aminopyralid

Clopyralid

Triclopyr

Glyphosate

Picloram

Effective biological control agents. Manual 

pulling and digging. All plant parts except 

flower/seed heads can remain on site.

Elephant ear/Japanese 

sweet coltsfoot 2 <1 Glyphosate Glyphosate Manual digging. Plant parts can be left on site to dry.

English holly 4 <1 Glyphosate Glyphosate Manual pulling and digging. Mechanical 

cutting. Plants can be left on site to dry.

English ivy 3 <1 Triclopyr Glyphosate

Manual pulling and digging. Seeds if present, 

to be removed, all other plant parts can be left 

on site to dry

European lily of the 

valley 1 <1 Glyphosate Metsulfuron methyl

Chlorsulfuron

Manual digging. Remove all plant parts from 

site.

23
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Target species 

(Common Name)

Approx. 

Number 

of Sites

Approx. 

Acreage 

Infested

1

First Choice 

Herbicide (those 

NOT available in 

current program are 

bolded)

Other Possible Herbicides (those 

NOT available in current 

program are bolded)

Effective Non-Herbicide Treatments (alone 

or in combination with herbicide use)

Field bindweed 4 <1 Glyphosate Triclopyr

Picloram Effective biological control agents.

Giant hogweed 1 <1 Glyphosate Triclopyr

Manual pulling and digging. Plant can be left 

on site, but should be removed in areas where 

the public may encounter the plant.

Hairy cat’s ear 2 159 Clopyralid Glyphosate

Picloram

Manual digging. Competitive seeding. All but 

flower/seed heads can be left on site.

hawkweed – Non-native 

(common, orange, 

yellow, spotted, smooth, 

tall)

140 1,233 Aminopyralid

Clopyralid

Triclopyr

Glyphosate

Effective biological control agents. Manual 

pulling and digging. All plant parts should be 

removed from site.

Hedge false bindweed 4 <1 Glyphosate Triclopyr

Picloram Non-herbicide treatments are not effective.

Herb Robert 126 850 Glyphosate Glyphosate Manual pulling and digging. Plants not in 

flower can be left on site, all others removed.

Himalayan blackberry 14 55 Triclopyr Glyphosate Manual pulling and digging. All plant parts can 

be left on site to dry.

Jewelweed 1 3 Glyphosate Triclopyr

Metsulfuron methyl

Manual pulling. Plants in flower should be 

removed.

Knotweed (Bohemian, 

giant, Japanese) 74 892 Glyphosate

Imazapyr

Glyphosate

Imazapyr Non-herbicide treatments are not effective.

Meadow knapweed 3 11 Aminopyralid

Clopyralid

Triclopyr

Glyphosate

Picloram

Effective biological control agents. Manual 

digging. All plant parts except flower/seed 

heads can remain on site.

Oxeye daisy 3 156 Aminopyralid

Clopyralid

Picloram

Glyphosate

Manual pulling and digging. All plant parts 

except flowers can be left on site.

Poison hemlock 1 <1 Glyphosate Metsulfuron methyl

Triclopyr

Manual pulling and digging. Plant parts except 

seeds can be left on site.

24
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Target species 

(Common Name)

Approx. 

Number 

of Sites

Approx. 

Acreage 

Infested

1

First Choice 

Herbicide (those 

NOT available in 

current program are 

bolded)

Other Possible Herbicides (those 

NOT available in current 

program are bolded)

Effective Non-Herbicide Treatments (alone 

or in combination with herbicide use)

Policeman’s helmet 1 <1 Glyphosate Triclopyr

Metsulfuron methyl

Manual pulling and digging. Remove flower 

heads/seed from site.

Reed canary grass 3 121 Glyphosate Sulfometuron methyl

Imazapyr

Approved non-herbicide methods are not 

effective.

Rhubarb 1 <1 Glyphosate Imazapyr

Clopyralid Manual digging. Plant can be left on site to dry.

Scotch broom 73 141 Aminopyralid Glyphosate

Triclopyr

Effective biological control agents. Manual 

pulling and digging and mechanical cutting. All 

plants parts except those with seed pods can 

be left on site.

Spotted knapweed 32 173 Aminopyralid

Picloram

Triclopyr

Clopyralid

Glyphosate

Effective biological control agents. Manual 

pulling and digging. All plant parts except 

flower/seed heads can remain on site.

St. Johnswort 1 2 Aminopyralid

Picloram

Metsulfuron methyl

Glyphosate

Effective biological control agents. Manual 

pulling and digging. Remove all plant parts 

from site.

Sulphur cinquefoil 12 75 Metsulfuron methyl

Picloram

Glyphosate

Triclopyr

Aminopyralid

Manual pulling and digging. All plant parts 

except seeds can be left on site.

Tansy ragwort 75 319 Aminopyralid

Picloram

Metsulfuron methyl

Clopyralid

Glyphosate

Triclopyr

Effective biological control agents. Manual 

pulling and digging. All flowering parts, 

including those not yet in bloom, removed from 

site.

Wild carrot 4 2

Metsulfuron methyl

(Approved Currently 

At Skiyou Island)

Chlorsulfuron

Triclopyr

Glyphosate

Manual pulling. Remove flower/seeds from 

site.

Woolly hedgenettle 1 <1 Glyphosate Triclopyr

Imazapyr

Manual pulling and digging. Remove all plant 

parts from site.

25
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Target species 

(Common Name)

Approx. 

Number 

of Sites

Approx. 

Acreage 

Infested

1

First Choice 

Herbicide (those 

NOT available in 

current program are 

bolded)

Other Possible Herbicides (those 

NOT available in current 

program are bolded)

Effective Non-Herbicide Treatments (alone 

or in combination with herbicide use)

Yellow archangel 6 <1 Glyphosate

Triclopyr

Imazapyr

Metsulfuron methyl

Manual pulling and digging. Remove all plant 

parts from site.

Yellow flag iris 1 <1 Imazapyr Glyphosate Manual pulling and digging. Remove rhizomes 

and seeds from site.

Estimated Total1 935 4,878

1

Infested acreage is imprecise and likely to far overestimate the extent of inventoried target species. Some of the target species co-occur within infested acres.

26
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Post-Treatment Restoration (Revegetation) 

Revegetation would occur following treatment if needed to restore native plant communities. 

Each treatment site was classified into one of five categories: 

1. None. These are areas where revegetation is either not desirable, or not realistic, or 

inappropriate. For instance, revegetation would not be desirable in a naturally unvegetated 

area such as a gravel bar. Revegetation would not be realistic if the area is constantly being 

graded or cleared such as a gravel pit. Revegetation would not be appropriate in cases such as 

a tree climbing vine like ivy or clematis. 

2. Passive Revegetation. Site is expected to revegetate naturally because there are enough 

native species (or desirable non-natives such as within lawns in administrative sites) in the 

immediate vicinity to colonize once the weeds are killed. Site types include vegetated road 

shoulders and small areas in forested sites. 

3. Seed and Mulch. This is the prescription for use where there are not enough native species in 

the immediate vicinity to colonize once the weeds are killed but planting is not prescribed. 

Examples include areas targeted for broadcast treatment. Use local native seed mix if 

possible, otherwise use MBS non-invasive non-native species (per Potash and Aubry 1999, as 

amended in 2003). 

4. Plant Rooted Stock. For specific restoration projects or where the weed has to be excavated 

in order to control it (i.e. first-choice/ first-year treatment is dig or where large areas of shrublike weeds occur). 

5. Planted in the Past. Some examples include portions of Marblemount Boat Launch, Ovenell 

Property, Kaaland Acquisition, Skiyou Island. 

Please see FEIS Appendix B for a list of treatment sites and proposed restoration activities. 

Management Requirements and Mitigation Measures (MR/MM)

The Proposed Action would include the Management Requirements and Mitigation Measures 

(MR/MM) listed in Table 1- 2. 

Table 1- 2. Management Requirements and Mitigation Measures

MR/MM 

ID Management Requirements and Mitigation Measures Objective

General

1 Coordinate herbicide use within 1000 feet (slope distance) of 

known water intakes with the water user or manager.

To ensure that water users

are informed about nearby 

herbicide use. 

2

Coordinate herbicide use with Municipal Water boards. Herbicide 

use or application method may be excluded or limited in some 

areas.

To ensure that water users

are informed about nearby 

herbicide use and standards 

for municipal watersheds 

are met. 

3

Pretreatment briefings would be conducted with all herbicide 

applicators to emphasize safety requirements, clarify treatment 

objectives and all mitigation measures, and to clarify 

identification of both target and non-target species.

To ensure applicators are 

aware of project 

requirements.

27
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

MR/MM 

ID Management Requirements and Mitigation Measures Objective

4

Lowest effective herbicide use rates would be used for each 

treatment situation. Nonylphenol ethoxylate-based non-ionic 

(NPE) and POEA surfactants would not be used. Vegetable oils 

and silicone blends that contain alkylphenol ethoxylate 

ingredients may be used.

To minimize possible 

herbicide or surfactant 

exposures of concern to 

human health. 

5

After working in invasive plant sites, all tools, equipment, and 

gear must be cleaned (power wash or high pressure spraying) 

before leaving the area. Any mulch used must be approved as 

invasive plant free. Non-invasive plants (preferably native plants) 

would be used for restoration where needed. 

To prevent the spread of 

invasive plants during 

treatment operations. 

6 Herbicide mixture would be colored with a bright, non-toxic 

vegetable dye before application.

To (a) minimize the 

possibility of accidentally 

applying herbicide to nontarget species; (b) minimize 

the amount of herbicide 

used, by avoiding reapplication to plants that 

have already been treated; 

and (c) assist anyone who 

might be gathering forest 

products or near a treatment 

area (public or Tribe) in 

identifying plants and areas 

that should be temporarily 

avoided.

7

Do not apply herbicides when local weather forecast calls for a ≥ 

80% chance of rain. Do not broadcast spray when wind speed at 

the site is in excess of 5 mph. Weather conditions would be 

monitored periodically during operations. To minimize herbicide 

application drift during broadcast operations, use low nozzle 

pressure; apply as a coarse spray, and use nozzles designed for 

herbicide application that do not produce a fine droplet spray, 

e.g., nozzle diameter to produce a median droplet diameter of 

500-800 microns.

To reduce potential for offsite herbicide drift and run 

off. 

28
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

MR/MM 

ID Management Requirements and Mitigation Measures Objective

8

Herbicide Transportation and Handling Safety/Spill 

Prevention and Containment

An Herbicide Transportation and Handling Safety/Spill Response 

Plan would be the responsibility of the herbicide applicator. At a 

minimum the plan would:

ü Address spill prevention and containment.

ü Require that impervious material be placed beneath 

mixing areas in such a manner as to contain small spills 

associated with mixing/refilling.

ü Require a spill cleanup kit be readily available for 

herbicide transportation, storage and application 

(minimum FOSS Spill Tote Universal or equivalent).

ü Outline reporting procedures, including reporting spills 

to the appropriate regulatory agency.

ü Ensure applicators are trained in safe handling and 

transportation procedures and spill cleanup.

ü Require that equipment used in herbicide storage, 

transportation and handling are maintained in a leak 

proof condition.

ü Address transportation routes so that traffic, domestic 

water sources, and blind curves are avoided to the 

extent possible.

ü Specify conditions under which guide vehicles would be 

required.

ü Ensure safe disposal of herbicide containers.

ü Identify sites that may only be reached by water travel 

and limit the amount of herbicide that may be 

transported by watercraft.

ü Workers would carry only enough herbicide daily to 

cover the proposed treatment for that day.

ü See soil, water and fisheries MR/MMs for additional 

measures

To reduce likelihood of spills 

and contain any spills.

Botanical

9

Surveys would be conducted for botanical species of 

conservation concern prior to invasive plant treatments if: (1) the 

area has not already been surveyed for these species, (2) if the 

area contains likely habitat for any of these species, and (3) if the 

proposed treatments are likely to have a negative impact to 

individual plants. Surveys would be conducted in the area within 

30 feet from where use of herbicides is planned. If species of 

concern are located, then mitigation measures for that species 

and that herbicide will be applied.

To ensure surveys are 

conducted for botanical 

species of conservation 

concern when 

circumstances warrant.

10

Follow mitigation measures for botanical species of conservation 

concern known to be within 30 feet of invasive plant treatment 

sites (see Table 31 in Chapter 3.3). Site-specific mitigation 

measures would be developed for unknown newly discovered 

botanical species of conservation concern within 30 feet of 

treatment sites.

To ensure appropriate steps 

are taken to protect 

botanical species of 

conservation concern when 

herbicide is being used to 

treat invasive plants. 

11

A botany specialist will coordinate with applicators to ensure 

botanical species of conservation concern are protected. 

Treatments will be monitored for efficacy and refined as needed.

Ensure that botanical 

species of conservation 

concern are not adversely 

affected by treatments. 

12

For herbicide treatment, use protective measures such as lowpressure spot-spray, directed spray applications, backpack 

applications, and/or protective barrier for botanical species of 

conservation concern. If buffers are needed to protect botanical 

species of conservation concern, the following guidance will be 

Minimize likelihood of 

herbicides inadvertently 

reaching botanical species 

of conservation concern.

29
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

MR/MM 

ID Management Requirements and Mitigation Measures Objective

followed: 

Greater than 30 feet: All application methods permitted. 

All herbicides are permitted.

Between 30 and 0 feet: No use of chlorsulfuron, 

imazapic, metsulfuron methyl, sulfometuron methyl, or 

picloram permitted. Clopyralid, aminopyralid, and 

triclopyr may be used if plant is not susceptible to these 

selective herbicides. Spot spray of glyphosate may be 

used if the rare plant is shielded or covered and botanist 

is on site. 

13

Do not apply imazapic to areas treated within the previous 18 

months with chlorsulfuron, metsulfuron methyl, sulfometuron 

methyl, or imazapyr in areas where reseeding of susceptible 

species is to occur.

To avoid damage to nontarget plants. Label caution 

states “for the previous 

year”. 18 months provides 

higher level of protection.

14

In order to protect botanical species of conservation concern in 

saturated or wet soils at the time of application, do not use 

picloram or imazapyr due to their mobility.

Under saturated or wet soil conditions present at the time of 

treatment, only hand application of herbicide is permitted within 

10 feet of botanical species of conservation concern.

Protect botanical species of 

conservation concern from 

impacts of certain 

herbicides.

15 Do not broadcast sulfonylurea herbicides within 50 feet of 

botanical species of conservation concern.

Protect botanical species of 

conservation concern from 

impacts from sulfonylurea 

herbicides through air (drift).

Soils, Water and Fisheries (includes Water Quality Best 

Management Practices)

16

The following treatment methods are shown in order of 

preference (if effective and practical), within roads that have

higher risk of herbicide delivery to fish habitat and adjacent 

alluvial floodplains: 

(1) Non-herbicide (e.g., hand pulling).

(2) Application of aminopyralid, clopyralid, imazapic, and 

metsulfuron methyl, aquatic glyphosate, aquatic triclopyr, aquatic 

imazapyr.

(3) Application of chlorsulfuron, imazapyr, sulfometuron methyl.

(4) Application of non-aquatic glyphosate. 

No picloram or non-aquatic triclopyr BEE would be used on 

roads that have a higher risk of herbicide delivery to fish habitat.

To protect aquatic 

organisms by favoring lower 

risk methods where 

effective on roads that have 

a higher risk of herbicide 

delivery to fish habitat. 

Appendix D displays a list 

and maps of roads 

considered higher risk. 

Roads are considered 

higher risk for herbicide 

delivery to fish bearing 

streams if any portion of the 

road segment comes within 

200 feet of a fish bearing 

stream. 

17

Only aquatic glyphosate, aquatic imazapyr, aminopyralid, 

clopyralid, imazapic, and metsulfuron methyl may be applied with 

a broadcast method on roads that have a higher risk of herbicide 

delivery to fish bearing streams. Portions of high risk roads may 

be cleared for use of picloram or non-aquatic triclopyr or 

broadcast spraying of chlorsulfuron, imazapyr, sulfometuron 

methyl based on a site review by an aquatics specialist to ensure 

the roadside ditches are not hydrologically connected to streams.

To ensure herbicide is not 

delivered to streams in 

concentrations that exceed 

levels of concern. 

30
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

MR/MM 

ID Management Requirements and Mitigation Measures Objective

18

The following herbicides may be spot or hand/selectively applied 

within 15 feet of any wet roadside ditch: Aquatic labeled 

glyphosate, aquatic labeled imazapyr, aquatic labeled triclopyr, 

aminopyralid, imazapic, clopyralid and metsulfuron methyl. No 

use of chlorsulfuron, picloram or sulfometuron methyl would 

occur within 15 feet of a wet roadside ditch. 

To ensure herbicide is not 

delivered to streams in 

concentrations that exceed 

levels of concern. 

19 Total treatment area would not exceed 10% of Riparian 

Reserves within a 6th field sub-watershed in any given year.

Limits the extent of

treatment near water so that 

effects are within the scope 

of analysis.

20

Lakes and Ponds – No more than half the perimeter or 50 

percent of the vegetative cover or 10 contiguous acres around a 

lake or pond would be treated with herbicides in any 30-day 

period.

To reduce exposure to 

herbicides and uncertainty 

regarding effects to reptiles 

and amphibians by 

providing some untreated 

areas for some organisms 

to use. 

21 Equipment fueling sites would be at least 150 feet from lakes, 

wetlands, or stream channels.

To minimize risk of fuel 

entering water. Width 

incorporates aquatic 

influence zone.

22

All herbicide storage, chemical mixing, refilling and postapplication equipment cleaning would be performed at least 300 

feet from live water, domestic wells, or domestic spring boxes, 

and in such a manner as to prevent the potential contamination 

of any riparian area, perennial or intermittent waterway, 

ephemeral waterway, wetland, or drinking water.

Reduce potential for 

adverse effects from 

accidental spills. 300 feet 

includes largest Riparian 

Reserve. Incorporates 

Washington State wellhead 

protection protocol.

23

POEA would not be used. Select from the list of surfactants 

approved by the Dept. of Ecology for use in aquatic 

environments for treatments within 100 feet of streams (see 

Appendix E). 

Eliminates use of higher risk 

surfactant. 

24

Avoid using picloram, imazapyr and/or metsulfuron methyl 

sulfometuron methyl on bare or compact soils that are highly 

disturbed.

To preserve site recovery 

after disturbance, lessen 

offsite runoff and leaching.

Poor soils will have longer 

residence times with these 

persistent herbicides.

25 For soils with seasonally high water tables, do not use picloram 

or triclopyr BEE and limit glyphosate use to aquatic label only.

Reduce the risk for 

contamination of 

groundwater and offsite 

runoff to aquatic habitat and 

fish.

26

Do not use more than one application of imazapyr, metsulfuron 

methyl, or picloram on a given area in any two calendar years, 

except to treat areas missed during the initial application. 

Aminopyralid would not be broadcast in any area more than once 

per year. Avoid application of persistent herbicides on anaerobic 

soils or saturated duff layers within 100 feet of streams. 

Reduce potential for 

herbicide accumulation in 

soil.

27

Limit herbicide offsite transport on sites with high runoff potential 

including sites with:

shallow seasonal water tables,

saturated soils (wet muck and peat soils),

steep erosive slopes with shallow soils and rock 

outcrop, or

bare compacted and disturbed soils.

Limit runoff by applying herbicide:

during the dry season with the lowest soil moisture 

conditions

Reduce potential offsite 

runoff transport of 

herbicides.

31
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

MR/MM 

ID Management Requirements and Mitigation Measures Objective

where > 50% groundcover exists on shallow slope sites 

and > 70% on steep slope sites, and/or

at reduced rates.

28

Areas of gouging or soil displacement resulting from manual

treatment methods (digging or pulling) within 35 feet of water 

courses with surface water present will be treated to prevent rill 

and gully erosion and possible sediment delivery to steam 

courses. Erosion control treatment will include scattering seed 

and mulch (straw) to create flow disruption and surface soil 

stability.

Minimize short- and longterm soil, hydrologic and 

water quality impacts.

29

Herbicide use buffers have been established for perennial and 

wet intermittent steams; dry streams; and lakes and wetlands. 

Buffers vary by herbicide ingredient and application method.

Tank mixtures would apply the largest buffer as indicated for any 

of the herbicides in the mixture. 

To reduce likelihood that 

herbicides would enter 

surface waters in 

concentrations of concern.

Comply with R6 2005 ROD 

Standards 19 and 20.

30

Apply erosion control measures (e.g. silt fences or shut down 

periods) and native re-vegetation (e.g., mulching, native grass 

seeding, planting) for manual treatment where soil disturbance or 

de-vegetation may result in the delivery of measurable levels of 

fine sediment to federally listed fish species’ critical habitat.

Minimize short- and longterm soil, hydrologic and 

water quality impacts.

Wildlife

31

Treatment of areas within 0.25 mile, or 0.5 mile line-of-site of 

bald eagle nests would be timed to occur outside the nesting 

season of January 1 – August 15 unless treatment activity is 

within ambient levels of noise and human presence (as 

determined by a local specialist). This seasonal restriction may 

be waived if a biologist determines by appropriate surveys that 

nest sites are not active that year.

To minimize disturbance to 

nesting bald eagles and 

protect eggs and nestlings

32

Noise-producing activity above ambient levels would not occur 

between October 31 and March 1 within 0.25 mile, or 0.50 mile 

line-of-sight, of known bald eagle winter roosts and concentrated 

foraging areas. Disturbance to daytime winter foraging areas 

would be avoided.

To minimize disturbance 

and reduce energy 

demands during stressful 

winter season.

33

Treatment of areas within 1.0 mile line-of-site of known grizzly 

bear dens would be timed to occur outside the denning season of 

October 30 – April 30.

To minimize disturbance 

and reduce energy 

demands to denning grizzly 

bear.

34

Treatment of areas within 1.0 mile line-of-site of known wolf dens 

would be timed to occur outside the denning season of April 1 –

June 30.

To minimize disturbance 

and reduce energy 

demands to denning 

wolves.

35

Treatment of areas within 0.5 mile line-of-site of occupied

rendezvous site would be timed to occur outside the season of 

April 1 – August 31, unless treatment activity is within acceptable 

ambient noise levels and human presence would not cause 

wolves to abandon the site (as determined by local specialist) .

To minimize disturbance 

and reduce energy 

demands to gray wolves.

36

Seasonal restrictions would apply during the periods listed below 

based on the following elevations within 0.5 miles of peregrine 

nest sites (primary nest zone):

Low elevation sites (1000-2000 ft.) 01 Jan - 01 July

Medium elevation sites (2001-4000 ft.) 15 Jan - 31 July

Upper elevation sites (4001+ ft.) 01 Feb - 15 Aug

Seasonal restrictions would be waived within primary and 

secondary nest zones if the site is unoccupied or if nesting efforts 

To reduce disturbance to 

nesting falcons and protect 

eggs and nestlings.

32
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

MR/MM 

ID Management Requirements and Mitigation Measures Objective

fail and monitoring indicates no further nesting behavior.

Seasonal restrictions would be extended if monitoring indicates 

late season nesting, asynchronous hatching leading to late 

fledging, or recycle behavior which indicates that late nesting and 

fledging would occur.

37

Invasive plant treatments involving motorized equipment and/or 

vehicles would be seasonally prohibited within 1.5 miles of 

known nest sites (secondary nest zones). This may include 

activities such as mulching, chainsaws, vehicles (with or without 

boom spray equipment) or other mechanically based invasive 

plant treatment. 

Non-mechanized or low disturbance invasive plant activities 

(such as spot spray, hand pull, etc.) may occur within the 

secondary nest zone, but would be coordinated with the wildlife 

biologist on a case-by-case basis to determine potential 

disturbance to nesting falcons and identify mitigating measures, if 

necessary. 

Seasonal restrictions would be waived within primary and 

secondary nest zones if the site is unoccupied or if nesting efforts 

fail and monitoring indicates no further nesting behavior.

Seasonal restrictions would be extended if monitoring indicates 

late season nesting, asynchronous hatching leading to late 

fledging, or recycle behavior which indicates that late nesting and 

fledging would occur.

To reduce disturbance to 

nesting falcons and protect 

eggs and nestlings.

38

Clopyralid would not be used within 1.5 miles of peregrine nest 

more than once per year. 

Picloram would not be used more than once every 2 years.

To reduce exposure to 

hexachlorobenzene (HCB). 

39

Active nest sites should be protected from disturbance above 

ambient levels during the dates specified. Local biologist will 

determine appropriate distances for planned operations prior to 

implementation.

To minimize or eliminate 

disturbance to nesting 

raptors.

40

Avoid broadcast spraying of herbicide in talus or rocky outcrops, 

springs, seeps or stream margins to protect Van Dyke’s and 

Larch Mountain salamanders. Utilize aquatic design features for 

suitable habitat in riparian areas, streams, and rivers.

To reduce likelihood of 

exposure to herbicides or 

additives from contaminated 

soil or water.

41

Avoid broadcast spraying of herbicide in known sites or high 

potential suitable mollusk habitat outside of roadside treatment 

locations when soil moisture is high (generally late fall to early 

spring).

To reduce likelihood of 

trampling and herbicide 

exposure.

42

Mower or motorized equipment use within 65 yards, of any nest 

site, activity center, or un-surveyed suitable habitat will be timed 

to occur outside the early nesting season of March 1 to July 15, if 

the project will last more than 1 day at a single location. Short 

duration projects using mowing or motorized equipment for less 

than 1 day or transient mowing equipment (such as road 

brushing) may occur in the early season. There is no seasonal 

restriction on the use of roadside broadcast sprayers.

To minimize disturbance to 

nesting spotted owls and 

protect eggs and nestlings.

33
Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

MR/MM 

ID Management Requirements and Mitigation Measures Objective

43

Mower or motorized equipment use within 110 yards, of any 

known occupied site or un-surveyed suitable habitat will be timed 

to occur outside the nesting season of April 1 to September 23, if 

the project will last more than 1 day at a single location. Short 

duration projects using mowing or motorized equipment for less 

than 1 day or transient mowing equipment (such as road 

brushing) may occur in the early season. There is no seasonal 

restriction on the use of roadside broadcast sprayers.

To minimize disturbance to 

nesting marbled murrelets 

and protect eggs and 

nestlings

44

After April 1 and before September 24, activities generating noise 

above 92 dB may occur within the disturbance distances listed 

above, but must still be conducted between 2 hours after sunrise 

and 2 hours before sunset.

To minimize disturbance to 

marbled murrelets returning 

to nest tree during the 

breeding season.

Recreation

45

Administrative Sites: Notify Forest employees of upcoming 

herbicide treatment in advance through e-mail. At the site, post 

specific treatment methods, herbicide ingredients to be used, and 

precise treatment location 1 day prior to treatment. Posting to 

remain on site for 1 week following treatment. 

To avoid exposing people to 

herbicides in administrative 

sites. 

46

Recreation Residence Permit Holders: Notify permit holders of 

upcoming herbicide treatment in advance through the mail. At the 

entrance to the recreation residential area, post specific 

treatment methods, herbicide ingredients to be used, and precise 

location 1 day prior to treatment. Posting to remain on site for 1

week following treatment.

To avoid exposing 

recreation residence permit 

holders to herbicides.

47

Campgrounds: Provide information about upcoming herbicide 

treatment in advance through the campground reservation 

system. At the campground, post specific treatment methods, 

herbicide ingredients to be used, and precise location 1 day prior 

to treatment. Posting to remain on site for 1 week following 

treatment. To the extent possible, treat campgrounds early part 

of the work week. 

To avoid exposing 

campground users to 

herbicides

48

Trailheads, Picnic Areas and Viewpoints: Alert the public about 

upcoming herbicide treatments on the Forest website. At the 

picnic area, viewpoint or trailhead, post specific treatment 

methods, herbicide ingredients to be used, and precise location 

at the time of treatment. Posting to remain on site for 1 week 

following treatment.

To avoid exposing 

trailhead/picnic 

area/viewpoint users to 

herbicides. 

49

Boat Launches not associated with picnic areas or campgrounds: 

Alert the public about upcoming herbicide treatments on the 

Forest website. At the boat launch, post specific treatment 

methods, herbicide ingredients to be used, and precise location 

at the time of treatment. Posting to remain on site for 1 week 

following treatment.

To avoid exposing boaters 

to herbicides. 

50

Other treatment areas not listed (including wilderness): Alert the 

public about upcoming herbicide treatments on the Forest 

website. At logical locations (for instance, on roadside entry 

points to treatment areas) post specific treatment methods, 

herbicide ingredients to be used, and precise location at the time 

of treatment.

To avoid exposing Forest 

users to herbicides. 

51

Do not apply triclopyr to edible target plants (berries) when fruit is 

present. To avoid exposing Forest 

users to triclopyr. 

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

MR/MM 

ID Management Requirements and Mitigation Measures Objective

Heritage Resources

52

If a heritage resource is discovered during implementation, or if 

an identified resource is affected in an unanticipated way, stop 

work and secure find; notify Forest Service Heritage Specialist 

and adhere to Programmatic Agreement (PA). Redesign the 

project to ensure that resources are avoided as determined by 

the Heritage Specialist, until the discovery is adequately 

considered pursuant to the PA. 

Protect historic properties

53

If Indian human remains or specified cultural items are 

discovered, stop work, secure find. Make appropriate notification 

& adhere to regulatory process.

Protect American

Indian burials and cultural 

items. 

54 Tribal Government to Government notification will occur annually. 

EDRR notification will occur on a case by case basis.

Allow tribal members to 

provide input and/or be 

notified prior treatment.

55

Provide an information packet “Guide to Protecting Heritage 

Resources” to all personnel involved in the invasive plant

treatment prior to project implementation. The packet will contain 

information on heritage resource identification (e.g. railroad 

grades, prehistoric artifacts, etc.) and instructions for any historic 

or prehistoric resources that may be found.

Protect historic properties

56

Ensure that a heritage specialist reviews treatment and 

restoration proposals for new invasive plant sites not identified in 

this EIS prior to implementation.

Protect historic properties

57

Provide Invasive Plant prescriber(s) with a list of invasive sites at 

which treatment / restoration may proceed; and a second list of 

invasive sites at which treatments may proceed, but require 

further consideration prior to hand planting restoration. All other 

treatment and or restoration sites not on these lists require a 

Heritage Specialist to determine if protection, survey, monitoring, 

or further mitigation is warranted.

Protect historic properties

58

If the treatment differs from the “first year/first choice” or the 

restoration differs from what has been analyzed, the heritage 

specialist will be contacted to review the changes and determine 

if additional survey, monitoring or mitigation is warranted. 

Protect historic properties 

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Table 1- 3. Herbicide Use Buffers

Herbicide

Perennial Streams and Wetlands, and

Intermittent Streams and Roadside 

Ditches with flowing or standing water 

present

Dry Intermittent Streams and

Wetlands

Broadcast 

Spraying

Spot 

Spraying

Hand 

Selective

Broadcast 

Spraying

Spot 

Spraying

Hand 

Selective

Labeled for Aquatic Use

Aquatic Glyphosate 60 waterline waterline 60 0 0

Aquatic Imazapyr 60 waterline waterline 60 0 0

Aquatic triclopyr-TEA 

(acid)

Not Allowed 15 waterline Not Allowed 0 0

Low Risk to Aquatic Organisms

Aminopyralid waterline waterline waterline 0 0 0

Imazapic 100 15 bankfull 60 0 0

Clopyralid 100 15 bankfull 60 0 0

Metsulfuron methyl 100 15 bankfull 60 0 0

Moderate Risk to Aquatic Organisms

Imazapyr 100 50 bankfull 60 15 bankfull 

Sulfometuron methyl 100 50 5 60 15 bankfull 

Chlorsulfuron 100 50 bankfull 60 15 bankfull 

Higher Risk to Aquatic Organisms 

Picloram 100 50 50 100 50 50

Glyphosate that is not 

labeled for aquatic 

use

100 50 50 100 50 50

Triclopyr (BEE) (ester) Not Allowed 50 50 Not Allowed 50 50

Early Detection Rapid Response

Early Detection/Rapid Response (EDRR) is aimed at treating new infestations that are small in 

size thus decreasing cost and the need for repeated herbicide applications. The existing “new 

invader” strategy would be modified to:

Increase the treatment methods available for selection to be those included in the Record 

Decision for this EIS, along with all Management Requirements and Mitigation Measures.

Facilitated treatment as soon as possible after detection. 

Add an annual herbicide application cap of 5,000 acres and an EDRR herbicide 

application cap at 13,500 acres. 

Add an implementation planning process.

Before treating new or existing sites, treatments would be prescribed based on the biology of the 

target species and size of the infestation. Relevant Management Requirements and Mitigation 

Measures (MR/MM) and herbicide use buffers would be integrated into the implementation 

prescription based on site conditions. Pre-treatment surveys would occur as per the MR/MM. 

Treatment would occur as soon as possible after finding new sites. This process would also apply 

to existing sites that have changed either because they have grown larger or because they have 

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

been reduced in size due to treatment. Coordination with adjacent landowners, water users, 

agencies, and partners would also occur prior to treatment. Government to government 

consultation with tribes would occur. Public notification would occur according to the MR/MM. 

Reporting items would be implemented as part of Section 7 ESA Consultation. 

Implementation Planning Process

This section outlines the process that would be used to ensure that the selected alternative is 

properly implemented. The methodology follows integrated weed management principles (R6 

2005 FEIS, 3-3) and satisfies pesticide use planning requirements at FSH 2109.14. It applies to 

currently known infestations and new sites found within or outside treatment analysis areas 

during ongoing inventory. Treatment prescriptions would be developed to ensure that MR/MM

and herbicide use buffers are appropriately incorporated.

New detections and changes to known invasive plant sites are likely to be found during the course 

of implementing this project. Known sites could spread and become larger, or become smaller 

from effective treatment. Changes to site conditions over time would be considered in the context 

of Forest Service NEPA Handbook: FSH 1909.15 Chapter 18.1, which provides guidance on the 

“Review and Documentation of New Information Received After A Decision Has Been Made.” 

Treatments that are not specifically excluded (for instance: aerial spray, treatment of submerged 

or floating invasive plants, treatment of native plants) and that incorporate appropriate MR/MM, 

herbicide use buffers and treatment caps would be within the scope of the project and 

supplemental effects analysis would not be necessary. 

1. Characterize invasive plant infestations to be treated

Identify target species, location, density, and extent. 

Identify adjacent land uses and vectors for invasive plant spread 

Determine treatment objective and priority. 

2. Develop site-specific prescriptions 

Identify effective integrated treatment method (Table 1- 1). Determine whether herbicides 

are needed and which application method is needed based on the herbicide use decision 

criteria shown below. 

Apply appropriate MR/MM based on:

♦ Past treatment history and response to past treatment 

♦ Proximity to species of local interest or their habitats

♦ Proximity to streams, lakes, wetlands

♦ Proximity to vectors and potential for persistent disturbance;

♦ Surrounding National Forest land uses and activities 

♦ Soil conditions

♦ Municipal watersheds and/or domestic water intakes

♦ Recreation areas, special forest product and special use areas

♦ First-choice or other effective herbicide

♦ Application rate and method 

Once the treatment prescription has been refined: 

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

♦ Complete Form FS-2100-2 Pesticide Use Proposal. This form lists treatment 

objectives, specific herbicide(s) that would be used, the rate and method of 

application, and MR/MM that apply. 

♦ Determine need for pre-project surveys for species of local interest and/or their 

habitats.

♦ Coordinate with adjacent landowners, water users, agencies, partners, and tribal 

governments.

♦ Initiate public notification.

♦ Obtain EPA National Pollution Discharge Elimination System (NPDES) permit for 

herbicide use on stream banks; on invasive plants that hang over streams; or 

treatments within 3-5 feet of live streams or other water bodies. 

3. Accomplishment and Compliance Monitoring

Develop a project work plan for herbicide use as per FSH 2109.14.3. This work plan 

presents organizational and operational details including the precise treatment objectives, 

equipment, materials, and supplies needed; the herbicide application method and rate; 

field crew organization and lines of responsibility; and interagency coordination.

Ensure that contracts and agreements include the appropriate integrated prescriptions that 

are consistent with MR/MM and the herbicide use buffers.

Document and report herbicide use and certified applicator information in the National 

pesticide use database, via the Forest Service Activity Tracking System (FACTS). The 

national pesticide use report extracts data from FACTS.

4. Post-treatment Monitoring and Recurring Treatments

Monitoring would occur during implementation to ensure project MR/MM are 

implemented as planned. Post-treatment reviews would occur to determine whether 

treatments are effective and whether or not passive/active restoration is occurring as 

expected. Not all sites would be visited annually, but most would be visited at some time 

during or after treatment. 

Contract administration and other existing mechanisms would be used to correct 

deficiencies. Herbicide use would be reported as required by the FSH 2109.14 and 

FACTS.

A sample of sites would be evaluated after treatment to determine whether MR/MM were 

appropriately applied, and whether non-target vegetation impacts were within tolerable 

levels. 

Prescriptions would be refined over time based on post-treatment results as long as 

treatments remain within the scope of the EIS. For instance, an invasive plant population 

treated with a broadcast herbicide may be retreated with a spot spray, or later manually 

pulled, once the size of the infestation is sufficiently reduced following the initial 

treatment. Another example would be the use of another herbicide if the first choice is not 

effective. 

Treatment buffers would be expanded if damage was found outside herbicide-use buffers 

as indicated by a decrease in the size of any non-target plant population, leaf discoloration 

or chlorophyll change, or mortality to individual species of local interest or non-target 

vegetation. The findings would be applied to herbicide-use buffers for water bodies. 

Herbicide-use buffers may be adjusted for certain herbicides/application methods and not 

others, depending on results.

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Draft Record of Decision – Mt. Baker Snoqualmie National Forest Invasive Plant Treatment

Monitoring

Monitoring for the Proposed Action includes assessment before, during and after implementation 

(see implementation planning process). Before implementation, a project work plan for herbicide 

use would be developed as described in FSH 2109.14.3. This plan presents organizational and 

operational details including treatment objectives, the equipment, materials, and supplies needed; 

the herbicide application method and rate; field crew organization and lines of responsibility, and 

a description of interagency coordination. The plan would also include a job hazard analysis to 

assure applicator safety. Before treatment, relevant MR/MM would be identified. 

During implementation, a sample of treatment sites would be inspected to ensure that MR/MM 

were properly implemented. The MR/MM for soils, water and fish include Best Management 

Practices for water quality. These would be monitored using national protocols during (and after 

implementation). Deficiencies would be corrected immediately.

Herbicide use would be documented and reported in the National Pesticide Use Database, via the 

Forest Service Activity Tracking System (FACTS) and Natural Resource Information System 

(NRIS) databases annually. Applicator information would be tracked through the Washington 

Department of Agriculture Pesticide licensing database. Records would be maintained to track 

treatment extent within the annual and life of the project caps.

Post-treatment reviews would be conducted over time to determine whether treatments were 

effective and what additional treatments, including active restoration, are needed. Most sites 

would be revisited to determine whether treatment objectives have been met. The process 

described under EDRR above would be followed for re-treatment of existing sites. Treatment 

prescriptions would be adapted to site conditions that change over time. 

A sample of sites would also be reviewed to determine whether damage to botanical species of 

conservation concern is occurring. MR/MM would be adjusted if unexpected impacts to botanical 

species of conservation concern are found. Additional monitoring may be done as part of the R6 

2005 ROD Monitoring Framework or implementation of BMP monitoring protocols.

39


Everett, WA 98201

2930 Wetmore Ave, Suite 3AAttn.: PHYLLIS REED, PROJECT COORDINATORMount Baker Snoqualimie Invasive Plant Treatment Project