for the greatest good

Mt. Baker-Snoqualmie 

National Forest 

Invasive Plant Treatment

Final Environmental Impact Statement

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

March 2015

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Mount Baker-Snoqualmie National Forest Invasive Plant Treatment

Final Environmental Impact Statement

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

Lead Agency: USDA Forest Service

Responsible Official: JENNIFER EBERLIEN FOREST SUPERVISOR 

2930 Wetmore Ave, Suite 3A,

Everett, WA 98201 

For Information Contact: PHYLLIS REED, PROJECT COORDINATOR 

2930 Wetmore Ave, Suite 3A,

Everett, WA 98201

360-436-2332 

The FEIS can be viewed and downloaded from the internet at the website address: 

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=34208. The FEIS and other information for this 

project is posted under the project name: Invasive Plant Treatment Project. The FEIS is also available 

as an electronic copy on a CD or as a hard copy upon request. 

Abstract: This Final Environmental Impact Statement (FEIS) discloses the effects of treating invasive 

plants in the Mt. Baker-Snoqualmie National Forest (MBS). The Proposed Action would update the 

current treatment program to more cost-effectively contain, control, and eradicate invasive plants on the 

MBS. Currently, 936 sites, totaling approximately 4,000 infested acres are mapped within the MBS. 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 a cost-effective manner, while 

minimizing adverse impacts to people and the environment.

The Proposed Action would increase the number of herbicides and application methods available for use 

on the ground. A Forest Plan amendment would add aminopyralid to the list of acceptable herbicides. The 

broadcast method of herbicide application methods would be authorized. Mechanical treatments such as 

mowing and use of string trimmers would be authorized in combination with other treatment methods. 

Invasive plants removal in wilderness areas would be authorized. New detections of invasive plants 

would be treated in a timely manner. All treatments would be done according to Management 

Requirements and Mitigation Measures (MR/MM), intended to minimize risk and maximize treatment 

effectiveness. 

The FEIS discusses three alternatives: Alternative 2 is the Proposed Action, which is the preferred 

alternative. Alternative 1 is the No-Action Alternative, which would continue to implement invasive plant 

treatments approved in the Mount Baker-Snoqualmie Decision Notice for Treatment of Invasive Plants 

and New Invaders Strategy (MBS 2005 DN). Alternative 3 would approve all elements of the Proposed 

Action, except that aminopyralid would not be added to the list of available herbicides; the MBS Forest 

Plan would not be amended. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS

Figure 1. Project area vicinity map

ii
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS

Acronym List

AI Active Ingredient

ACS Aquatic Conservation Strategy

APHIS Animal and Plant Health Inspection Service

BA

BCF

Biological Assessment

Bioconcentration Factor

BLM Bureau of Land Management

BMP

CFR

Best Management Practices

Code of Federal Regulations

EA Environmental Assessment

EDRR Early Detection / Rapid Response

DEIS Draft Environmental Impact Statement

DN Decision Notice

EIS

EPA

Environmental Impact Statement

U.S. Environmental Protection Agency

ESA Endangered Species Act

FEIS Final Environmental Impact Statement

HUC Hydrologic Unit Code

GIS Geographical information System

GLEAMS Groundwater Loading Effects of Agricultural Management Systems

HCB Hexachlorobenzene

MR/MM

MBS

Management Requirements and Mitigation Measures

Mount Baker-Snoqualmie National Forest

IDT Interdisciplinary Team

IWM Integrated Weed (Invasive Plant) Management

NEPA National Environmental Policy Act

NF National Forest

NFMA National Forest Management Act

NMFS National Marine Fisheries Service

NHPA National Historic Preservation Act

NOA Notice of Availability

NOI Notice of Intent

NOAA National Oceanic and Atmospheric Administration

NPE Nonylphenol Polyethoxylate

NPDES National Pollution Discharge Elimination System

NRIS Natural Resource Information Systems

NWFP Northwest Forest Plan

PNW Pacific Northwest

ROD Record of Decision

RR Riparian Reserve

SHPO State Historic Preservation Office

TES Threatened, Endangered, Sensitive

USDA U.S. Department of Agriculture

USDI U.S. Department of Interior

USFS U.S. Forest Service

USFWS U.S. Fish and Wildlife Service

WCM Water Concentration Model

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS

Table of Contents

Summary___________________________________________________________________ S-1

S.1 Background___________________________________________________________________ S-1

S.2 Purpose and Need _____________________________________________________________ S-1

S.3 Proposed Action (Alternative 2) __________________________________________________ S-2

S.4 Key Issues ____________________________________________________________________ S-2

S.5 Alternatives __________________________________________________________________ S-2

S.6 Alternative Comparison _________________________________________________________ S-2

Chapter 1. Purpose and Need ___________________________________________________ 1

1.1 Background_________________________________________________________________ 1

1.2 Desired Condition____________________________________________________________ 2

1.3 Purpose and Need ___________________________________________________________ 2

1.4 Management Direction _______________________________________________________ 3

1.4.1 Land and Resource Management Plan (Forest Plan) Direction________________________________ 3

1.4.2 Additional Guidance (Laws, Directives and Agreements) ____________________________________ 7

1.5 Proposed Action _____________________________________________________________ 9

1.6 Decision Framework__________________________________________________________ 9

1.7 Tribal Consultation and Public Involvement ______________________________________ 10

1.8 Issues_____________________________________________________________________ 10

1.8.1 Key Issue #1: Treatment Cost-Effectiveness _____________________________________________ 11

1.8.2 Key Issue #2: Herbicide Toxicity _______________________________________________________ 11

Chapter 2. Alternatives Including the Proposed Action ______________________________ 13

2.1 Introduction _______________________________________________________________ 13

2.2 Invasive Plant Treatment Methods Common to All Alternatives______________________ 13

2.3 Alternative 1 – No Action_____________________________________________________ 15

2.3.1 Introduction ______________________________________________________________________ 15

2.3.2 Integrated Treatment Prescriptions____________________________________________________ 16

2.3.3 Management Requirements and Mitigation Measures (MR/MM)____________________________ 20

2.3.4 Early Detection Rapid Response_______________________________________________________ 23

2.3.5 Monitoring _______________________________________________________________________ 23

2.4 Alternative 2 – Proposed Action _______________________________________________ 25

2.4.1 Introduction ______________________________________________________________________ 25

2.4.2 Forest Plan Amendment_____________________________________________________________ 26

2.4.3 Integrated Treatment Prescriptions____________________________________________________ 26

2.4.4 Post-Treatment Restoration (Revegetation) _____________________________________________ 32

2.4.5 Management Requirements and Mitigation Measures (MR/MM)____________________________ 32

2.4.6 Early Detection Rapid Response_______________________________________________________ 40

2.4.7 Implementation Planning Process _____________________________________________________ 41

2.4.8 Monitoring _______________________________________________________________________ 44

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS

2.5 Alternative 3 – No Aminopyralid _______________________________________________ 45

2.5.1 Introduction ______________________________________________________________________ 45

2.5.2 Integrated Treatment Prescriptions____________________________________________________ 45

2.5.3 Post-Treatment Restoration__________________________________________________________ 45

2.5.4 Management Requirements and Mitigation Measures (MR/MM)____________________________ 45

2.5.5 Early Detection and Rapid Response ___________________________________________________ 46

2.5.6 Implementation Planning Process _____________________________________________________ 46

2.5.7 Monitoring _______________________________________________________________________ 46

2.6 Alternatives Not Considered in Detail___________________________________________ 52

2.6.1 Hand Treatments Only, Using a Large Workforce (paid or volunteer) _________________________ 52

2.6.2 Use of Alternative Products __________________________________________________________ 52

2.6.3 Avoid Use of Certain Herbicides Approved in the R6 2005 ROD______________________________ 52

2.6.4 No Broadcasting ___________________________________________________________________ 53

2.6.5 Integrate Prevention into Alternatives _________________________________________________ 53

2.6.6 Goat Grazing ______________________________________________________________________ 53

2.7 Alternatives Compared ______________________________________________________ 53

Chapter 3. Affected Environment and Environmental Consequences ___________________ 63

3.1 Introduction _______________________________________________________________ 63

3.1.1 Treatment Analysis Areas____________________________________________________________ 63

3.1.2 Site Characterization________________________________________________________________ 71

3.1.3 Treatment Assumptions and Scenarios _________________________________________________ 71

3.1.4 Climate Change and Invasive Plants____________________________________________________ 72

3.1.5 Introduction to Herbicide Toxicity Analysis ______________________________________________ 73

3.1.6 Introduction to the Cumulative Effects Analysis __________________________________________ 81

3.2 Treatment Cost-Effectiveness _________________________________________________ 88

3.2.1 Introduction ______________________________________________________________________ 88

3.2.2 Alternative 1 - No Action ____________________________________________________________ 90

3.2.3 Alternative 2 – Proposed Action ______________________________________________________ 91

3.2.4 Alternative 3 ______________________________________________________________________ 91

3.2.5 Effect of Alternatives on Invasive Plant Treatment Objectives_______________________________ 92

3.2.6 Effectiveness of Early Detection and Rapid Response (EDRR)/”New Invader” Approach __________ 93

3.2.7 Cumulative Effects on Treatment Effectiveness __________________________________________ 95

3.2.8 Alternative Comparison, Cost-Effectiveness _____________________________________________ 95

3.3 Human Health______________________________________________________________ 96

3.3.1 Introduction ______________________________________________________________________ 96

3.3.2 Affected Environment_______________________________________________________________ 98

3.3.3 Environmental Consequences ________________________________________________________ 98

3.3.4 Consistency with Regulations, Policies and Plans ________________________________________ 107

3.4 Botany___________________________________________________________________ 108

3.4.1 Introduction _____________________________________________________________________ 108

3.4.2 Affected Environment______________________________________________________________ 108

3.4.3 Environmental Consequences _______________________________________________________ 111

3.4.4 Consistency with Regulations, Policies and Plans ________________________________________ 118

3.5 Wildlife __________________________________________________________________ 118

3.5.1 Introduction _____________________________________________________________________ 118

3.5.2 Affected Environment______________________________________________________________ 118

3.5.3 Environmental Consequences to Wildlife ______________________________________________ 136

3.5.4 Consistency with Regulations, Policies and Plans ________________________________________ 158

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS

3.6 Soil _____________________________________________________________________ 159

3.6.1 Introduction _____________________________________________________________________ 159

3.6.2 Affected Environment______________________________________________________________ 159

3.6.3 Environmental Consequences _______________________________________________________ 164

3.6.4 Consistency with Regulations, Policies and Plans ________________________________________ 173

3.7 Water Resources __________________________________________________________ 173

3.7.1 Introduction _____________________________________________________________________ 173

3.7.2 Affected Environment______________________________________________________________ 174

3.7.3 Environmental Consequences _______________________________________________________ 183

3.7.4 Consistency with Regulations, Policies and Plans ________________________________________ 197

3.8 Fish and Aquatic Organisms__________________________________________________ 197

3.8.1 Introduction _____________________________________________________________________ 197

3.8.2 Affected Environment______________________________________________________________ 198

3.8.3 Environmental Consequences _______________________________________________________ 207

3.8.4 Consistency with Regulations, Policies and Plans ________________________________________ 221

3.9 Recreation, Wilderness and Wild & Scenic Rivers ________________________________ 226

3.9.1 Introduction _____________________________________________________________________ 226

3.9.2 Affected Environment______________________________________________________________ 227

3.9.3 Environmental Consequences _______________________________________________________ 230

3.10 Heritage Resources_________________________________________________________ 233

3.10.1 Introduction ___________________________________________________________________ 233

3.10.2 Affected Environment ___________________________________________________________ 236

3.10.3 Environmental Consequences _____________________________________________________ 239

3.10.4 Consistencies with Regulations, Policies and Plans ____________________________________ 240

3.11 Other Required Disclosures __________________________________________________ 240

3.11.1 Environmental Justice and Civil Rights ______________________________________________ 240

3.11.2 Irreversible and Irretrievable loss of Resources _______________________________________ 241

3.11.3 Prime farmland, Rangeland and Forestland __________________________________________ 241

3.11.4 Potential Conflicts with Plans or Policies of other Jurisdictions ___________________________ 241

3.11.5 Permits and Licenses ____________________________________________________________ 241

3.11.6 Non-significant Land and Resource Management Plan Amendment_______________________ 242

Chapter 4. List of Preparers, Consultation and Coordination with Others (Tribes, Agencies) 245

4.1 List of Preparers ___________________________________________________________ 245

4.2 Consultation with Regulatory Agencies ________________________________________ 247

4.3 Consultation with Tribal Governments _________________________________________ 247

4.4 Consultation with Counties and Municipal Water Boards __________________________ 247

4.5 Consultation with Others/FEIS Distribution _____________________________________ 247

Chapter 5. Literature Cited, Glossary and Index ___________________________________ 249

5.1 Literature Cited____________________________________________________________ 249

5.2 Glossary _________________________________________________________________ 275

5.3 Index ____________________________________________________________________ 289

Appendix A - Treatment Analysis Area Atlas Example ______________________________ 291

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS

Appendix B – Restoration/Revegetation Strategy for Each Infested Site _______________ 299

Appendix C – Susceptibility of Rare Plants to Herbicides ____________________________ 335

Introduction ____________________________________________________________________ 335

Appendix D – Road Segments that Pose Higher Risk of Herbicide Delivery to Fish Habitat _ 349

Appendix E – Additives, Impurities And Inert Ingredients ___________________________ 361

Introduction ____________________________________________________________________ 361

Appendix F - Recently Completed, Currently Being Implemented, Ongoing and Foreseeable 

Future Projects _____________________________________________________________ 367

Appendix G – Invasive Plant Treatment DEIS Comments and Forest Service Responses ___ 377

Summary of Comments Received ___________________________________________________ 377

Agency Letters in Full _____________________________________________________________ 412

King County Noxious Weed Control Program __________________________________________________ 412

City of Seattle Major Watersheds ___________________________________________________________ 416

United States Department of the Interior_____________________________________________________ 417

Washington Native Plant Society____________________________________________________________ 418

U. S. Environmental Protection Agency_______________________________________________________ 420

List of Tables

Table S- 1. Alternative Components _______________________________________________________________ S-3

Table S- 2. Comparison of the Management Requirements and Mitigation Measures currently approved under the

No Action and Action alternatives ________________________________________________________________ S-4

Table S- 3. Comparison of New Invader (EDRR) Approach between No Action and Action Alternatives__________ S-8

Table S- 4. How the Alternatives Respond to the Issues _______________________________________________ S-9

Table 1. Forest Plan Designation and Relevant Standards ______________________________________________ 4

Table 2. R6 2005 ROD Standards and Project Compliance ______________________________________________ 5

Table 3. Herbicide application methods and descriptions ______________________________________________ 13

Table 4. Biological control agents found on the MBS _________________________________________________ 14

Table 5. Integrated treatment prescriptions - Alternative 1 (No Action) __________________________________ 17

Table 6. Integrated Treatment Prescriptions – Alternative 2 (Proposed Action) ____________________________ 27

Table 7. Total acres for each first year/first choice treatment under Alternative 2 __________________________ 31

Table 8. Herbicide active ingredient and estimated broadcast acres _____________________________________ 31

Table 9. Management Requirements and Mitigation Measures_________________________________________ 33

Table 10. Herbicide Use Buffers __________________________________________________________________ 40

Table 11. Integrated Treatment Prescriptions – Alternative 3 (No Aminopyralid) ___________________________ 47

Table 12. Total Acres by First Year/First Choice Treatment for Alternative 3 _______________________________ 51

Table 13. Herbicide active ingredient and estimated broadcast acres for Alternative 3 ______________________ 51

Table 14. Comparison of Alternative Components____________________________________________________ 54

Table 15. Comparison of the Management Requirements and Mitigation Measures currently approved under the no 

action and action alternatives ___________________________________________________________________ 55

Table 16. New Invader (EDRR) Approach ___________________________________________________________ 59

Table 17. Comparison of the alternatives based on issue indicators______________________________________ 60

Table 18. Infested Acres, Number of Sites and Target species within Treatment Analysis Areas _______________ 65

Table 19. Acreage and Number of Known Sites by Site Type____________________________________________ 71

Table 20. Risk assessments for herbicides and surfactants considered in this EIS ___________________________ 74

Table 21. Summary of Properties and Risks Associated with Herbicides Proposed for Use on the MBS __________ 75

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS

Table 22. Risk of Invasive Plant Spread by Site Descriptions ____________________________________________ 84

Table 23. Potential for Invasive Plant Spread from Projects and Activities_________________________________ 85

Table 24. Comparison between Objectives for No Action and the Action Alternatives _______________________ 93

Table 25. Comparison of EDRR/New Invader Strategy between No-Action and Action Alternatives ____________ 93

Table 26. Summary of the Treatment Cost-Effectiveness Analysis _______________________________________ 95

Table 27. Scenarios and herbicides where hazard quotients (HQ) exceeded 1.0 for human health. ____________ 101

Table 28. Summary Table for Effects Related to Human Health and Herbicide Use_________________________ 106

Table 29. Invasive Plants that Pose the Greatest Threat to Native Plant Habitats of Concern ________________ 109

Table 30. Botanical Species of Conservation Concern Within 30 feet of Invasive Plant Treatment Analysis Areas_ 109

Table 31. Mitigation for botanical species of conservation concern within 30 feet of treatment sites __________ 112

Table 32. Non-target Plant Considerations for the 10 Herbicides Proposed For Use in Alternative 2 ___________ 114

Table 33. Federally listed and candidate wildlife species on Mt. Baker-Snoqualmie National Forest ___________ 120

Table 34. Occurrence of Forest Service Sensitive Species on MBS_______________________________________ 125

Table 35. Terrestrial Management Indicator Species on MBS__________________________________________ 131

Table 36. Survey and Manage Species on the MBS __________________________________________________ 133

Table 37. Impact Determinations for Sensitive Species _______________________________________________ 150

Table 38. Acreage of Invasive plant Sites __________________________________________________________ 160

Table 39. Common soil types for the Snoqualmie NF (NRCS 2003) ______________________________________ 163

Table 40. Compiled herbicide properties for mobility in soil and water transport from SERA risk assessments ___ 167

Table 41. Estimated Infested Acres in HUC-10 Watersheds ___________________________________________ 174

Table 42. MBS water bodies listed as impaired under 303(d) of the Clean Water Act_______________________ 178

Table 43. Acres of invasive plants in municipal watersheds on the MBS _________________________________ 180

Table 44. Number of sites and acres of invasive plants in Key Watersheds _______________________________ 181

Table 45. Estimated infested acres by Treatment Analysis Area and in Riparian Reserves ___________________ 181

Table 46. “First Choice” treatments common to all alternatives within the Aquatic Influence Zones ___________ 184

Table 47. First Choice Treatments within the Aquatic Influence Zones by Alternative_______________________ 184

Table 48. Central, lower and upper estimates for peak concentration of herbicides in water when used adjacent to 

streams ____________________________________________________________________________________ 191

Table 49. Species listed under the ESA and their critical habitat (if applicable) within the project area_________ 199

Table 50. General life cycle timing of federally listed fish species in the project area _______________________ 202

Table 51. Infested areas within 150 feet of with ESA Listed Fish Species_________________________________ 204

Table 52. Regional Forester's Sensitive Species within the MBS ________________________________________ 206

Table 53. Toxicity Indices for Fish ________________________________________________________________ 211

Table 54. Toxic Indices for Algae_________________________________________________________________ 212

Table 55. Toxicity Indices for Aquatic Plants (Macrophytes) ___________________________________________ 213

Table 56. Toxicity Indices for Aquatic Invertebrates _________________________________________________ 214

Table 57. Relative Risk to Fish, Aquatic Invertebrates, Algae and Aquatic Plants From Riparian Use of Herbicides at 

MBS Rates __________________________________________________________________________________ 216

Table 58. Crosswalk of PCE elements and MPI indicators _____________________________________________ 224

Table 59. Miles of documented presence on the MBS by management indicator fish species ________________ 225

Table 60. MIS and habitat description for the analysis area ___________________________________________ 226

Table 61. Infested acreage and numbers of sites within Recreation Areas________________________________ 228

Table A- 1. Invasive Plant Species Mapped Within Treatment Analysis Area 11 ___________________________ 291

Table B- 1. Invasive plant species location and revegetation strategy ___________________________________ 300

Table C- 1. Susceptibility to Herbicide for Botanical Species of Conservation Concern on the MBS_____________ 335

Table D- 1. Roads that Pose Higher Risk of Herbicide Delivery to Fish-Bearing Streams _____________________ 349

Table E- 1. Adjuvants Approved for use in Aquatic Environments, Washington 2012 _______________________ 364

Table F- 1. Cumulative effects projects – recently completed projects (2010-2014) with overlap of invasive plant 

action area__________________________________________________________________________________ 367

Table F- 2. Ongoing/Current Projects that Overlap Treatment Analysis Areas_____________________________ 369

Table F- 3. Foreseeable Future Projects that Overlap with Invasive Plant Treatment Analysis Areas ___________ 373

Table G- 1. List of commenters __________________________________________________________________ 377

Table G- 2. DEIS comments and the Forest Service responses__________________________________________ 381

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS

List of Figures

Figure 1. Project area vicinity map _________________________________________________________________ ii

Figure 2. Treatment Analysis Areas Locator Map ____________________________________________________ 64

Figure 3. Invasive plant sites by elevation range ____________________________________________________ 160

Figure 4. Relative Concentrations (ppb) For Proposed Herbicides in Soil Modeled for Forest Site with Wet and Cool 

Conditions __________________________________________________________________________________ 170

Figure 5. Precipitation map of Washington State ___________________________________________________ 176

Figure 6. Mean daily flow for Three Gages ________________________________________________________ 177

Figure A -1. Treatment Analysis Area 11 Overview Map ______________________________________________ 294

Figure A -2. Map of Treatment Analysis Area 11 Eastern Portion_______________________________________ 295

Figure A -3. Map of Treatment Analysis Area 11 Central Portion _______________________________________ 296

Figure A -4. Map of Treatment Analysis Area 11 Western Portion ______________________________________ 297

Figure D- 1. Invasive plant treatment project area overview map for roads with higher risk of herbicide delivery to 

fish-bearing streams __________________________________________________________________________ 353

Figure D- 2. Roads with higher risk of herbicide delivery to fish bearing streams (map reference 1). Fish bearing 

stream road crossings are indicated______________________________________________________________ 354

Figure D- 3. Roads with higher risk of herbicide delivery to fish bearing streams (map reference 2). Fish bearing 

stream road crossings are indicated______________________________________________________________ 355

Figure D- 4. Roads with higher risk of herbicide delivery to fish bearing streams (map reference 3). Fish bearing 

stream road crossings are indicated______________________________________________________________ 356

Figure D- 5. Roads with higher risk of herbicide delivery to fish bearing streams (map reference 4). Fish bearing 

stream road crossings are indicated______________________________________________________________ 357

Figure D- 6. Roads with higher risk of herbicide delivery to fish bearing streams (map reference 5). Fish bearing 

stream road crossings are indicated. _____________________________________________________________ 358

Figure D- 7. Roads with higher risk of herbicide delivery to fish bearing streams (map reference 6). Fish bearing 

stream road crossings are indicated______________________________________________________________ 359

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Summary

Summary

S.1 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. On the Mt. BakerSnoqualmie National Forest (MBS), 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. BakerSnoqualmie National Forest, totaling about 1,724,229 acres. 

In 2005, the Mount 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, invasive 

plant inventories indicated there were 90 individual sites, and most of the sites were smaller than 0.1 acre. 

The more than ten-fold increase in invasive species sites indicates that the current program has not kept 

up with the treatment need. This is partly because of increased awareness and mapping, however, this is 

also because the treatment tools and new invader strategy authorized in the MBS 2005 DN has not 

resulted in effective invasive plant treatment. 

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).2

The R6 2005 ROD amended the MBS Land and Resource Management Plan (Forest Plan 1990) by 

adding management direction for invasive plant prevention, treatment and restoration. The R6 2005 ROD 

authorized additional herbicide ingredients that could increase treatment effectiveness compared to those 

authorized by the MBS 2005 DN. The Proposed Action is intended to increase the effectiveness of our 

invasive treatments by using some of these additional 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 some broadleaf invasive plant species. The 

Proposed Action would amend the Forest Plan to authorize the use of aminopyralid. Since 2005, invasive 

plants have been found in wilderness areas on the MBS. The Proposed Action would allow invasive plant 

treatment in these areas. In addition, the Proposed Action would allow for use of mechanical equipment 

(mowers and string trimmers) outside of wilderness areas. 

S.2 Purpose and Need 

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

and/or eradication of invasive plants, including those that are currently known and those discovered in the 

future. Invasive species can adversely affect the diversity and resilience of native plant communities. The 

Forest Service lacks adequate tools for effective treatment. The purpose of the project is to treat invasive 

plants in the most cost-effective manner possible, while meeting 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. 

1 Some sites contain more than one target species; when each species is tallied separately, the total acreage is 4,878. 

2 The R6 2005 FEIS and ROD are available on line at 

http://www.fs.usda.gov/detail/r6/forest-grasslandhealth/invasivespecies/?cid=stelprdb5302157. 

S - 1 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Summary

This project follows the Standards and Guidelines in the R6 2005 ROD and Mount Baker-Snoqualmie 

Land and Resource Management Plan (Forest Plan). The project may occur within any Forest Plan 

designation (management area allocation) on the MBS.

S.3 Proposed Action (Alternative 2) 

The Proposed Action (Alternative 2) would allow for use of herbicides in combination with mechanical 

and other invasive plant treatment methods (manual, biological, cultural) according to specific 

management requirements and mitigation measures. It would amend the MBS Forest Plan to allow for use 

of the herbicide aminopyralid. The broadcast method of application would be approved where needed, 

however, most of the proposed herbicides would not be broadcast near streams and other water bodies or 

in other sensitive areas. The Proposed Action (Alternative 2) would include an Early Detection, Rapid 

Response (EDRR) process to ensure that treatment prescriptions and MR/MM are appropriately applied 

to new sites.

S.4 Key Issues 

Two key issues were identified for analysis in this EIS. The issues are treatment cost-effectiveness and 

herbicide toxicity. 

S.5 Alternatives

This EIS considers two alternatives to the Proposed Action. Under Alternative 1, No Action, the current 

invasive plant treatment approach would continue. This would mean that most treatments on the Forest 

would be done using one of four herbicides currently approved for use on the MBS (clopyralid, imazapyr 

glyphosate and metsulfuron methyl ), primarily using a backpack sprayer or other selective method. 

Alternative 3 would include the use of the nine herbicides approved in the R6 2005 ROD, the broadcast 

treatment method would be approved, and mechanical treatments would also be included. Alternative 3 

would not amend the Forest Plan to authorize the use of aminopyralid. 

S.6 Alternative Comparison

Table S- 1 compares components of each of the alternatives. Table S- 2 compares the management 

requirements and mitigation measures for no action and the action alternatives. Table S- 3 compares the 

approach to new invaders (early detection rapid response) for no action and the action alternatives. Table 

S- 4 compares the how each alternative responds to the key issues. 

S - 2 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Summary

Table S- 1. Alternative Components

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 acres 

of new detections over the life 

of the project, 18% of the area 

within 150 feet of a stream 

annually

5,000 per year, 13,500 acres of 

new detections over the life of the 

project, 18% of the area within 150 

feet of a stream annually

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.

S - 3 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Summary

Table S- 2. Comparison of the Management Requirements and Mitigation Measures currently approved under 

the No Action and Action alternatives

No Action (2005 EA) Action Alternatives

General

1. In treating any/all infestations, all applicable management 

requirements and practices, included in the Forest Plan

Prevention Strategy, Best Management Practices (BMPs) for 

invasive plants will be followed.

Forest-wide prevention measures (BMPs) have 

been developed and would be followed regardless 

of alternative selected. 

2. In particular, after working in invasive plant sites, all tools, 

equipment, and gear must be cleaned (power wash or high 

pressure spraying) before leaving the area, in order to avoid 

spreading the infestation further (Forest Plan, BMPs). 

This measure is included in the action 

alternatives. 

3. All invasive species management must be coordinated with 

all other site or area resources objectives.

This measure is replaced by specific coordination 

requirements in the MR/MM for the action 

alternatives. 

4. Biocontrol treatments will use only those control agents that 

have been approved by the U.S. Department of Agriculture 

Animal and Health Inspection Service and permitted by the 

State of Washington.

This measure is Standard 14 from the R6 2005 

ROD and would be followed regardless of 

alternative selected. 

5. Any mulch used must be approved as invasive plant free, 

meeting the Forest Plan, Forest-wide Standards and 

Guidelines, Prevention Strategy and BMPs.

This measure is Standard 3 from the R6 2005 

ROD and would be followed regardless of 

alternative selected. 

General Herbicide Use

6. No broadcast spraying (aerial or boom) will occur. 

The 2008 Skiyou Island DN approved 

broadcasting for that one area. Both action 

alternatives would approve additional 

broadcasting where needed, according to MR/MM 

and herbicide use buffers.

7. Any preparation, transport, or application of herbicide will be 

done by trained workers with a current Washington State 

pesticide applicators license.

All alternatives follow the R6 2005 ROD Standard 

15 that requires that people who apply herbicides 

be licensed or directly supervised by a licensed 

applicator. 

8. Only the aquatic formulation of glyphosate will be used, and 

at the lowest effective rate as per manufacturer label 

specifications, which is estimated to be 2 1⁄2 to 5 percent 

solution of the aquatic formulation of glyphosate diluted in 

water (3 ounces manufacturer’s concentrate per gallon of 

water). Refer to Mitigation Measure #19, below, for application 

via stem injection. 

This measure is not carried forward into the action 

alternatives. The lowest effective rate would be 

used based on the label and invasive plant being 

treated. Maximum rates for foliar application for 

the herbicides proposed in Alternative 2 are 

shown in Table 20 in chapter 3.1. Alternative 3 

would use the same rates (but does not include 

aminopyralid). 

9. If needed, the only surfactant that will be used is Agri-Dex®.

This measure is not carried forward into action 

alternatives. Action alternatives would allow for 

surfactant use that follows R6 2005 ROD 

Standard 18. See Appendix E for more 

information on surfactant. No NPE-based or 

POEA surfactants would be used. For herbicide 

applications within 100 feet of streams and other 

water bodies, surfactants approved by the Dept. 

of Ecology for use in aquatic environments would 

be required. 

10. Pretreatment briefings will 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. 

This measure is specifically included in the action 

alternatives.

S - 4 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Summary

No Action (2005 EA) Action Alternatives

Herbicide and Surfactant Transport, Mixing, Use

11. Materials Safety Data Sheets, and Forest Service 

Information covering glyphosate and Agri-Dex® must be 

carried in each vehicle at all treatment times, and made 

available to interested members of the public, on-site.

These measures have been replaced with the 

following Herbicide Transportation and Handling 

Safety/Spill Prevention and Containment 

measures in the action alternatives. 

An Herbicide Transportation and Handling 

Safety/Spill Response Plan would be the 

responsibility of the herbicide applicator. At a 

minimum the plan would:

§ Address spill prevention and containment.

§ Estimate and limit the daily quantity of 

herbicides to be transported to treatment 

sites.

§ Require that impervious material be placed 

beneath mixing areas in such a manner as to 

contain small spills associated with 

mixing/refilling.

§ Require a spill cleanup kit be readily available 

for herbicide transportation, storage and 

application (minimum FOSS Spill Tote 

Universal or equivalent).

§ Outline reporting procedures, including 

reporting spills to the appropriate regulatory 

agency.

§ Ensure applicators are trained in safe 

handling and transportation procedures and 

spill cleanup.

§ Require that equipment used in herbicide 

storage, transportation and handling are 

maintained in a leak proof condition.

§ Address transportation routes so that traffic, 

domestic water sources, and blind curves are 

avoided to the extent possible.

§ Specify conditions under which guide vehicles 

would be required.

§ Ensure safe disposal of herbicide containers.

§ Identify sites that may only be reached by 

water travel and limit the amount of herbicide 

that may be transported by watercraft.

§ Workers will carry only enough herbicide daily 

to cover the proposed treatment for that day.

12. Glyphosate and Agri-Dex® containers must be secured 

and prevented from tipping during transport.

13. Workers will carry only enough herbicide daily to cover the 

proposed treatment for that day.

14. Mix only the amount of solution needed to complete daily 

treatments.

15. Workers will follow all herbicide label guidelines.

16. Containment mats will be used during mixing, to further 

avoid the risk of a spill.

17. Do not mix glyphosate or glyphosate with Agri-Dex® within 

300 feet of riparian areas, wetlands, or surface water.

18. When glyphosate (with Agri-Dex®) is administered via 

wand-backpack spray, hand wiped, or painted on cut stems, 

the applicator will use the lowest effective rate. 

All alternatives would require use of the lowest 

effective rate of any herbicide used in a given 

situation. Maximum application rates per acre for 

the 10 herbicides proposed in Alternative 2 are 

shown in Table 20. 

19. For stem injection: only the lowest effective dose will be 

used on the MBS. The current recommended effective dose is 

100 percent of the manufacturer’s concentrate. Trial studies 

suggest that 2 to 3 milliliters per stem can be effective (The 

Nature Conservancy 2004, Clallam County 2004). New 

preliminary research has found that 2.5 milliliters per stem is 

effective (personal communication, Dr. Timothy Miller, 

Washington State University Extension Service. Mt. Vernon, 

WA, May 2005)

All alternatives would require use of the lowest 

effective rate of any herbicide used. Stem 

injection require higher concentrations of 

herbicide than foliar treatments. 

20. Stem injection method would only be used on very small, 

high-priority infestations with difficult access.

This measure is not carried forward into the action 

alternatives. However, stem injection could be 

used where cost-effective. 

S - 5 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Summary

No Action (2005 EA) Action Alternatives

21. No applications using wand-backpack spray will occur 

when wind speed exceeds five miles per hour, to lessen drift, 

or when precipitation is expected within 24 hours.

This measure is part of the action alternatives for 

broadcast herbicide application methods. Drift is 

not anticipated for spot applications. No herbicide 

applications would occur if there is a greater than 

80 percent change of precipitation within 24 

hours. 

22. No hand wiping of leaves with the aquatic formulation of 

glyphosate with Agri-Dex® will be done when precipitation is 

expected within 24 hours.

No herbicide applications would occur if there is a 

greater than 80 percent change of precipitation 

within 24 hours. 

23. Application will occur only outside of timing constraints for 

wildlife, and when the chance of rain after application is very 

low.

This measure has been replaced by specific 

wildlife MR/MM in the action alternatives. 

24. Herbicide mixture (aquatic formulation of glyphosate with 

or without Agri-Dex®) will be colored with a bright, non-toxic 

vegetable dye before application. This will (a) minimize the 

possibility of accidentally applying herbicide to non-target 

species; (b) minimize the amount of herbicide used, by 

avoiding re-application 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.

In the action alternatives, herbicide mixtures will 

be colored with a bright, non-toxic vegetable dye 

before application. 

Soils/Water/Fisheries

25. Soil disturbance (from hand digging, grubbing, pulling, etc.) 

will be minimized to the extent possible. Restoration of treated 

areas will follow the restoration treatment proposed for each 

site.

This measure is not part of the action alternatives; 

however restoration is part of the action 

alternatives (see Chapter 2.4.4). Mitigation for soil 

disturbance near streams is included. 

26. As noted above [measure 17], all herbicide spray mixtures 

(aquatic formulation of glyphosate with or without Agri-Dex®) 

would not be prepared within 300 feet of riparian areas, 

wetlands, or surface water.

For the action alternatives, no herbicide mixing 

would occur within 300 feet of streams. 

27. Containment mats will be used during mixing to further 

avoid the risk of a spill.

For the action alternatives, an impervious material 

would be placed beneath mixing areas in such a 

manner as to contain small spills associated with 

mixing/refilling.

28. Any mulch used must be approved as invasive plant free, 

meeting the Forest Plan, Forest-wide Standards and 

Guidelines, Prevention Strategy and BMPs.

This measure is included in the action alternatives

as per R6 2005 ROD standard 3. 

Wildlife

29. From January 1 through August 15, restrict all treatment 

activity in known or suspected bald eagle nest territories.

These measures have been replaced in their 

entirety in the action alternatives. 

30. Baker River Inlet to Baker Lake, Site 106: from November 

1 through March 31, restrict all treatment activity near known, 

occupied eagle roost sites or key eagle foraging areas.

31. From March 1 through July 15, restrict activities generating 

noise above ambient levels within 35 yards of suitable spotted 

owl nesting habitat.

32. From April 1 through August 5, restrict activities generating 

noise above ambient levels within 35 yards of suitable marbled 

murrelet nesting habitat. 

33. For infestation treatments located within or adjacent to 

suitable nesting habitat for murrelet, leaving of any garbage or 

trash in the area is prohibited.

S - 6 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Summary

No Action (2005 EA) Action Alternatives

Vegetation, Plants

34. MBS Botanists will consistently provide training to 

contractors, state-wide, to educate them on accurate 

identification of invasive plants, so that only target species are 

treated and other desirable species are left unharmed. These measures have been replaced in their 

entirety in the action alternatives. 35. If any previously undiscovered rare plants are found within 

the project area, work will be halted until the USFS botanist is 

consulted and necessary mitigation measures are enacted.

Heritage Resources

36. An information packet will be provided to all personnel 

involved in the invasive plant treatment prior to project 

implementation. The packet will contain information on 

heritage resource identification (such as railroad grades, how 

to identify prehistoric artifacts, etc.) and instructions for any 

historic or prehistoric resources that may be found.

These measures have been replaced in their 

entirety in the action alternatives.

37. If a previously unidentified resource is discovered during 

project implementation—under any treatment method—or if at 

any time a resource that may be eligible for the National 

Historic

Register of Historic Places is affected, in an un-anticipated 

way, reasonable steps will be taken to avoid or minimize harm 

to the resource until the Forest Service can fulfill its 

consultation requirements in accordance with the 

Programmatic Agreement for Heritage Resources (1997; see 

project files).

Recreation, Public Use

38. For any site with where recreation use/activity is high and 

invasive plant infestations are located other than along the 

peripheral (such as edges of parking lots, along road 

shoulders, etcetera), any treatment using the aquatic 

formulation of glyphosate (with or without Agri-Dex®) will 

occur only during the week, and not on weekends or 3-day 

holiday weekends. Sites will be signed and flagged, as noted 

above. These measures have been replaced in their 

entirety in the action alternatives. 39. The only two examples among the 91 specific sites 

proposed for treatment are Gold Creek Pond (polygon # 48) 

and Buck Creek Camp (polygon # 148). While Buck Creek 

Camp is not operating for the 2005 season (camp is for sale), 

any treatment using the aquatic formulation of glyphosate (with 

or without Agri-Dex®) will be contingent upon scheduling with 

the Camp management, and/or the care-taker.

Worker and Public Health and Safety

40. All workers will comply with Occupational Health and 

Safety Administration (OSHA) standards, Forest Service 

Health and Safety Code Handbook, and other guidelines, 

BMPs, and manufacturers’ recommendations to reduce the 

risk of injury to workers.

This measure is required as a matter of Forest 

Service policy and would be followed regardless 

of alternative selected.

S - 7 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Summary

Table S- 3. Comparison of New Invader (EDRR) Approach between No Action and Action Alternatives

No Action Action Alternatives

Based on the previous year’s surveys, new invasive plant 

infestations would be documented [using the forms in 

Appendix D of the 2005 EA]. 

Invasive plant sites and treatment plans would be 

mapped according to Forest Service policy. Data 

bases such as NRIS and FACTS are used to track 

invasive plant populations and treatments.

New infestation sites would be prioritized. No change. Priority would be determined in 

cooperation with implementation partners. 

The current “set” of high-priority sites would be included in 

each year’s prioritization, which could result in a newlydiscovered site being ranked as a higher priority for treatment. 

New and known sites would be treated according 

to priority, with some exceptions, for instance, if a 

medium or lower-priority infestation can be treated 

as part of another planned project, or as part of a 

suite of restoration projects within a watershed. 

Once a new site is ranked as a high priority, an initial proposed 

treatment and restoration plan would be selected, based on 

the type of invasive plant, size of infestation, and location. 

Tools to make this assessment would include, but not be 

limited to: the biology of each invasive plant species and their 

control history [Appendix C of the 2005 MBS EA]; and MBS 

specific experience with treating invasive species [Appendix B, 

of the 2005 MBS EA]. The only treatment methods available 

for selection would be those included in the [2005 MBS] EA, 

along with all Management Requirements and Mitigation 

Measures. 

The implementation planning process includes 

developing integrated treatment prescriptions 

according to MR/MM based on a comprehensive 

list of site considerations. This project does not 

include herbicide application directly to water, 

aerial application of herbicides, use of any 

pesticides other than herbicides, treatment of 

aquatic invasive plants (floating and submerged), 

treatment of native plants, and changes in land 

uses to slow or prevent the spread of invasive 

plants. Otherwise, treatments according to all of 

the design features (MR/MM, herbicide use 

buffers, treatment caps), would be considered in 

the scope of the action alternatives.

A new annual newsletter would be produced each spring, 

listing the new sites. It would be mailed to all interested 

parties, including agencies (such as U.S. Fish and Wildlife 

Service (USFWS), and NOAA Fisheries), Tribes, and others. 

Comments would be solicited.

No annual newsletter required. Notification would 

occur as per the MR/MM. Consultation with tribes 

and ESA regulatory agencies would occur as 

agreed. 

For each new, high-priority site: the effects on other resources 

from treatment/restoration would be estimated. This 

information would be included in the newsletter.

No additional effects analysis is required for 

treatments within the scope of the action 

alternatives. Treatments according to all of the 

design features (MR/MM, herbicide use buffers, 

treatment caps), would be considered in the 

scope of the action alternatives.

If the effects are found to be within the scope of this EA, and 

USFWS and NOAA Fisheries concur through informal Section 

7 (ESA) consultation, sites would be added as addenda.

Report as agreed as a result of Section 7 

Consultation.

All treatments would be accomplished as funding is available. No change. 

S - 8 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Summary

Table S- 4. How the Alternatives Respond to the Issues

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: Estimated 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 

Applied to Known Sites and EDRR Acres

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)

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. Nonselective 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 nonselective herbicide 

use. 

Low; broadcast 

treatments are 

proposed in 7 

TAAs where 

botanical species 

of conservation 

concern are 

located, however 

MR/MM would 

minimize risk. 

Non-selective 

herbicide use 

may be needed 

near water 

(glyphosate).

S - 9 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Summary

Issue and Indicator Alternative 1 Alternative 2 Alternative 3

Herbicide Toxicity/Wildlife: Relative risk 

to wildlife from herbicide use

Low risk of herbicide 

exposure to wildlife. The 

effects analysis 

assumes that an animal 

is directly sprayed, 

consumes an entire 

days’ diet of 

contaminated food, or 

drinks contaminated 

water for an entire day. 

These scenarios far 

overestimate actual 

exposure levels. The 

management 

requirements and 

mitigation measures 

would further reduce the 

potential impacts on 

wildlife.

3

Same as 

Alternative 1

Same as 

Alternative 1

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

3 This section was edited for clarity between the draft and final EIS.

S - 10 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 1

Chapter 1. Purpose and Need

1.1 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 Mount Baker-Snoqualmie National Forest (MBS or the Forest), about 40 species of invasive 

plants have been mapped within 936 sites, totaling approximately 4,0004 infested acres. The project area 

includes the entire Mount Baker-Snoqualmie National Forest, totaling about 1,724,229 acres. 

In 2005, the Mount 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 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). 5

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). 

4 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. 

5 The R6 2005 FEIS and ROD are available on line at 

http://www.fs.usda.gov/detail/r6/forest-grasslandhealth/invasivespecies/?cid=stelprdb5302157. 

1 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 1

1.2 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,6 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 or 

longer, depending on funding and site-specific response to treatment. 

1.3 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. 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.

6 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. 

2 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 1

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 previously not 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.

1.4 Management Direction

Several laws, policies and plans provide management direction for invasive plant management. The 

Federal Invasive Plant Act (1974), as amended (7 U.S.C 2801 et seq.) requires cooperation with state, 

local, and other federal agencies in the application and enforcement of all laws and regulations relating to 

management and control of invasive plants (a summary of this act can be viewed at: 

http://ipl.unm.edu/cwl/fedbook/fedinvasive plant.html) Executive Order 13112 (1999) also directed 

federal agencies to reduce the spread of invasive plants. 

In 2004, R6 issued a Policy for Invasive Plant Prevention that directed National Forests to complete 

environmental analysis for treating invasive plants (as funding allows), conduct timely treatment of 

priority infestations, develop invasive plant prevention practices, analyze the potential risks of grounddisturbing activities on the introduction and spread of invasive plants and design and incorporate 

prevention measures for these activities, and document this analysis in project files (USDA Forest Service

2004c). 

The Forest Service Manual 2900 (2011) directs the Forest Service to use an integrated invasive plant 

management approach to eradicate, control and contain the spread of invasive plants within the National 

Forest.

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

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

invasive species management and improve the health and productivity of forests and grasslands. The 

framework acknowledges that invasive species are among the most important environmental and 

economic threats facing public lands. The framework notes that estimated economic damage from 

invasive species has totaled more than $1.4 trillion worldwide, about 5 percent of the world’s economy. 

Early detection and rapid response to new detections, effective control of invasive species, and restoration 

of treated sites are important objectives of the framework. 

1.4.1 Land and Resource Management Plan (Forest Plan) Direction 

This Environmental Impact Statement has been prepared in accordance with regulations for implementing 

the National Environmental Policy Act of 1969 (NEPA), located at 40 CFR 1500-1508. It is tiered to the 

3 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 1

Final Environmental Impact Statement (FEIS) for the Mt. Baker-Snoqualmie Land and Resource 

Management Plan (USDA Forest Service 1990), as amended. 

Forest Plan amendments since 1990 include: 

Final Supplemental Environmental Impact Statement on Management of Habitat for Late 

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

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

standards and guidelines (USDA FS, USDI BLM 1994), and commonly known as the ROD, or 

the Northwest Forest Plan (NWFP).

Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage 

Protection Buffer, and Other Mitigation Measure Standards and Guidelines (USDA, USDI 

2001). 

Record of Decision to Clarify Provisions Relating to the Aquatic Conservation Strategy

Amending Resource Management Plans (USDA FS, USDI BLM 2004) 

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

Managing Invasive Plants (R6 2005 ROD). 

The 1994 ROD includes seven land allocations, which amended the allocations in the 1990 Forest Plan. 

There is considerable overlap among some allocations, and more than one set of standards and guidelines 

may apply. The 1994 Forest Plan amendment also includes Forest-wide Standards and Guidelines and an 

Aquatic Conservation Strategy (ACS) designed to help improve the health of the aquatic ecosystem. 

This project may occur within any Forest Plan designation (management area allocation) on the MBS. 

Table 1 lists the management area allocations that have specific management area direction pertaining to 

invasive plant management or herbicide use. The R6 2005 ROD (MBS Forest Plan) standards that apply 

to invasive plant treatment and restoration are in Table 2. The R6 2005 ROD (MBS Forest Plan) includes 

additional standards to prevent the spread of invasive plants from land uses and activities. 

Table 1. Forest Plan Designation and Relevant Standards

Forest Plan

Designation Type of Area Specific Management Area Direction For Invasive Plants 

Northwest Forest Plan

(1994)

Riparian Reserves

(C-30)

Herbicides, insecticides, and other 

toxicants, and other chemicals shall be 

applied [within riparian reserves] only in a 

manner that avoids impacts that retard or 

prevent attainment of Aquatic 

Conservation Strategy objectives.

Northwest Forest Plan

(1994) Late-Successional Reserve

General Guideline – non-silvicultural 

activities located inside Late-Successional 

Reserves that are neutral or beneficial to 

the creation and maintenance of late 

successional habitat are allowed (C-10). 

Non-native Species - Evaluate impacts of 

non-native species (plant and animal) 

currently existing within reserves, and 

develop plans and recommendations for 

eliminating or controlling non-native

species that are inconsistent with LSR 

objectives (C-19).

4 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 1

Forest Plan

Designation Type of Area Specific Management Area Direction 

For Invasive Plants 

MBS Management 

Area 12

Mature and Old-growth Wildlife Habitat (pine 

marten, pileated woodpecker)

Integrated pest management concepts 

are permitted, except where use of 

pesticides conflicts with old growth habitat 

management

MBS Management 

Area 14 Deer and Elk Winter Range

Integrated pest management concepts 

are permitted, except where use of 

pesticides conflicts with objectives of 

managing winter range and specialized 

habitats

MBS Management 

Area 17 Timber Management Emphasis

Use of mechanical, chemical, or manual 

methods to maintain the stocking level of 

desirable trees is permitted.

MBS Management 

Area 15 Mountain Goat Habitat

Utilize integrated pest management

techniques, except where use of chemical 

pesticides conflicts with objectives of 

managing winter range

MBS Management 

Area 21A Green River Municipal Watershed

Integrated pest management concepts 

are permitted, except where use of 

pesticides conflicts with water quality 

objectives.

MBS Management 

Area 22B Sultan River Municipal Watershed

Integrated pest management permitted 

except where use of pesticides conflicts 

with water quality objectives.

Table 2. R6 2005 ROD Standards and Project Compliance

Standard # R6 2005 Standard Project Compliance

11

Prioritize infestations of invasive plants for treatment at 

the landscape, watershed or larger multiple 

forest/multiple owner scale. 

Infestations with the objective of 

eradication are generally highest priority; 

infestations with the objective of control are 

medium priority; and infestations with the 

objective of containment are lower priority.

12

Develop a long-term site strategy for 

restoring/revegetating invasive plant sites prior to 

treatment.

The long term strategy for restoration 

depends on the type of site infested, the 

target species, and location.

13

Native plant materials are the first choice in 

revegetation for restoration and rehabilitation where 

timely natural regeneration of the native plant 

community is not likely to occur. Non-native, noninvasive plant species may be used in any of the 

following situations: 1) when needed in emergency 

conditions to protect basic resource values (e.g., soil 

stability, water quality and to help prevent the 

establishment of invasive species), 2) as an interim, 

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

materials are not available, or 4) in permanently altered 

plant communities. Under no circumstances will nonnative invasive plant species be used for revegetation.

Revegetation (competitive seeding and 

planting) would occur as needed to replace 

invasive plants with native plant 

communities. Non-native, non-persistent 

species may be used infrequently as an 

interim measure to control erosion or 

prevent target species from returning on 

treated sites.

5 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 1

Standard # R6 2005 Standard Project Compliance

14

Use only USDA Animal and Plant Health Inspection 

Service (APHIS) and State-approved biological control 

agents. Agents demonstrated to have direct negative 

impacts on non-target organisms would not be 

released.

Agents found to have negative impacts 

may not be distributed on MBS. The R6 

Regional Office updates the list regularly. 

15

Application of any herbicides to treat invasive plants 

will be performed or directly supervised by a State or 

Federally licensed applicator. All treatment projects that 

involve the use of herbicides will develop and 

implement herbicide transportation and handling safety 

plans.

The elements of herbicide transportation 

and handling safety plans discussed in the 

management requirements/mitigation 

measure section of Chapter 2. 

16

Select from herbicide formulations containing 1 or more 

of the following 10 active ingredients: chlorsulfuron, 

clopyralid, glyphosate, imazapic, imazapyr, metsulfuron 

methyl, picloram, sethoxydim, sulfometuron methyl, 

and triclopyr. Mixtures of herbicide formulations 

containing 3 or less of these active ingredients may be 

applied where the sum of all individual Hazard 

Quotients for the relevant application scenarios is less 

than 1.0. All herbicide application methods are allowed 

including wicking, wiping, injection, spot, broadcast and 

aerial, as permitted by the product label. Chlorsulfuron, 

metsulfuron methyl, and sulfometuron methyl will not 

be applied aerially. The use of triclopyr is limited to 

selective application techniques only (e.g., spot 

spraying, wiping, basal bark, cut stump, injection).

Additional herbicides and herbicide mixtures may be 

added in the future at either the Forest Plan or project 

level through appropriate risk analysis and NEPA/ESA 

procedures.

Management requirements and mitigation 

measures, including no-broadcast and noherbicide buffers add layers of caution and 

minimize or eliminate adverse effects 

related to use of herbicides. 

No aerial treatment is proposed in any 

alternative. 

18

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

ingredients reviewed in Forest Service hazard and risk 

assessment documents such as SERA 1997a, 1997b; 

Bakke, 2002.

Adjuvant use would be consistent with this 

standard. Please see Chapter 3.1 and 

Appendix E for more information on 

adjuvants. 

19

To minimize or eliminate direct or indirect negative 

effects to non-target plants, terrestrial animals, water 

quality and aquatic biota (including amphibians) from 

the application of herbicide, use site-specific soil 

characteristics, proximity to surface water and local 

water table depth to determine herbicide formulation, 

size of buffers needed, if any, and application method 

and timing. Consider herbicides registered for aquatic 

use where herbicide is likely to be delivered to surface 

waters.

Chapter 2 discusses management 

requirements, mitigation measures, and 

herbicide use buffers that would apply to 

the proposed project. Chapter 3 discusses 

how risks from herbicide use are abated by 

Management Requirements and Mitigation 

Measures that restrict herbicide use in near 

botanical species of conservation concern, 

certain wildlife habitats, and streams and 

other water bodies. 

20

Design invasive plant treatments to minimize or 

eliminate adverse effects to species and critical 

habitats proposed and/or listed under the Endangered 

Species Act. This may involve surveying for listed or 

proposed plants prior to implementing actions within 

unsurveyed habitat if the action has a reasonable 

potential to adversely affect the plant species. Use sitespecific project design (e.g. application rate and 

method, timing, wind speed and direction, nozzle type 

and size, buffers, etc.) to mitigate the potential for 

adverse disturbance and/or contaminant exposure.

Chapter 3 discusses how potential adverse 

effects to Endangered Species and critical 

habitats from herbicide use are minimized. 

6 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 1

Standard # R6 2005 Standard Project Compliance

21

Provide a minimum buffer of 300 feet for aerial 

application of herbicides near developed campgrounds, 

recreation residences and private land (unless 

otherwise authorized by adjacent private landowners).

No aerial application is proposed.

22 Prohibit aerial application of herbicides within legally 

designated municipal watersheds.

No aerial application is proposed.

Coordination with water users would occur 

in accordance with Municipal Watershed

Plans (more information in Chapter 3). 

23

Prior to implementation of herbicide treatment projects, 

National Forest staff will ensure timely public 

notification. Treatment areas will be posted to inform 

the public and forest workers of herbicide application 

dates and herbicides used. If requested, individuals 

may be notified in advance of spray dates.

Chapter 2 lists Management Requirements 

and Mitigation Measures, including public 

notification requirements. 

1.4.2 Additional Guidance (Laws, Directives and Agreements)

This project follows the National Forest Management Act (NFMA), the National Environmental Policy 

Act (NEPA), and the Council on Environmental Quality regulations. The project is consistent with all 

applicable Federal, State and local laws, regulations and agreements, including (but not limited to): 

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Cooperative Forestry 

Assistance Act. The Forest Service is authorized by FIFRA and the Cooperative Forestry Assistance Act 

to use pesticides for multiple-use resource management and maintenance of the quality of the 

environment as long as the actions comply with the National Environmental Policy Act and the Council 

on Environmental Quality regulations. Forest Service Manual (FSM 2150) and Forest Service Handbook 

(FSH 2109) provide direction on safe use of pesticides, including direction on storage and transport, and 

development of safety plans and emergency spill plans. 

Wild and Scenic Rivers Act. Treatment of invasive plants is consistent with preservation of the scenery 

and natural character of a Wild and Scenic river. 

Wilderness Act. Invasive plant treatment within wilderness would preserve wilderness character.

Treatments using mechanized equipment and broadcast herbicide spraying is not proposed in wilderness. 

Roadless Rule. Invasive plant treatment areas are primarily along roads. The proposed treatments would 

be consistent with roadless area management direction. 

Endangered Species Act. The Forest Service is consulting with the US Fish and Wildlife Service (FWS) 

and National Marine Fisheries Service (NMFS) to ensure that the proposed invasive plant treatments 

would not jeopardize the continued existence of federally listed species (or species proposed or 

considered candidates for listing). 

Clean Water Act. A Clean Water Act National Pollution Discharge Elimination System (NPDES) permit 

is required for herbicide use that may directly enter streams. Treatment along stream banks or for target 

plants that emerge from or overhang water bodies likely would require a permit. 

Clean Water Act compliance includes use of Best Management Practices (BMPs). Specific BMPs are 

required for chemical use on National Forests (National BMP Technical Guide - USDA Forest Service 

2012). The Management Requirements and Mitigation Measures (MR/MM - Table 9) in Chapter 2 

integrate the national BMPs. Core objectives for chemical uses on National Forests are provided in the 

technical guide. These include:

7 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 1

Use the planning process to develop measures to avoid, minimize, or mitigate adverse effects to soil, 

water quality, and riparian resources from chemical use on NFS lands.

Avoid or minimize the risk of soil and surface water or groundwater contamination by complying with all 

label instructions and restrictions required for legal use.

Avoid or minimize the risk of chemical delivery to surface water or groundwater when treating areas near 

water bodies. 

The Migratory Bird Treaty Act (MBTA)/Landbird Conservation Plan (Presidential Executive 

Order 13186, and FS/FWS MOU, Jan. 2001). This act requires federal agencies to assess project 

actions that may affect avian species covered by these doctrines and their habitats. The MBTA outlines 

responsibilities of federal land management agencies relative to landbird conservation, and the MOU 

provides interim direction on implementation of the MBTA. The Forest Service will collaborate with the 

U.S. Fish and Wildlife Service, as needed, if project actions produce measurable impacts to avian 

resources.

Grizzly Bear Recovery Memorandum of Understanding(MOU). A MOU between Forest Service and 

U.S. Fish and Wildlife Service stipulates that there is to be no net loss of core grizzly bear habitat (1997). 

Magnuson-Stevens Fishery Conservation and Management Act (16 U.S.C. 1801 et seq.), as amended 

by the Sustainable Fisheries Act of 1996, and its implementing regulations (50 CFR Part 600). The 

Magnuson-Stevens Fishery Conservation and Management Act as amended by the Sustainable Fisheries 

Act of 1996, requires Federal action agencies to consult with the Secretary of Commerce (via the NMFS) 

regarding certain actions. Consultation is required for any action or proposed action authorized, funded, 

or undertaken by the agency that may adversely affect essential fish habitat (EFH) for species managed in 

Federal Fishery Management Plans. For this project, the Pacific Coast Salmon Plan manages for Chinook, 

coho, and pink salmon. EFH regulations, 50 CFR section 600.920(a)(1), enable Federal agencies to use 

existing consultation and environmental review procedures to satisfy EFH consultation requirements. 

The Antiquities Act of 1906. The Antiquities Act (P.L. 59-209, 16 U.S.C. 431-433) authorizes a permit 

system for investigation of archaeological sites on federal lands and allows the President to establish 

national monuments on federal lands in order to protect them. 

Historic Sites Act of 1935 (16 USC 461). The Historic Sites Act declares national policy to preserve for 

public use historic sites, buildings, and objects of national significance for the inspiration and benefit of 

the people of the United States. 

The National Historic Preservation Act of 1966, as amended in 1992 (NHPA). The NHPA (P.L. 102-

575; 16 U.S.C. 470) extends the policy of the Historic Sites Act to state and local historic sites as well as 

those of national significance. The Mt. Baker-Snoqualmie National Forest (MBSNF) fulfills its 

responsibilities under the NHPA through a programmatic agreement (USDA Forest Service 1997) 

regarding cultural resources management on National Forests in the state of Washington, developed in 

consultation with the Advisory Council on Historic Preservation (ACHP) and the State Historic 

Preservation Office (SHPO), pursuant to Section 800.13 of the regulations (36 CFR 800 [1986]). 

Native American Policies. The Forest Service's Native American polices are described in Forest Service 

Manual 1563 and Forest Service Publication FS-446 and FS-600. These policies include maintaining a 

governmental relationship with federally-recognized tribal governments, implementing programs and 

activities in a way that honors Indian treaty rights and fulfills legally-mandated trust responsibilities to the 

extent that they apply to National Forest system lands.

8 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 1

Watershed Analysis. Watershed analysis documents prepared since 1995 were reviewed. A summary of 

findings from watershed analysis reports that are relevant to invasive plant management is in the Project 

Record. The design of this project is consistent with the recommendations in the watershed analysis 

reports. 

Late-Successional Reserves. Invasive plant populations threaten native plant communities, particularly 

along roads and other disturbed areas within Late-Successional Reserves. Removal of invasive plants are 

revegetation with native plants would help meet Late Successional Reserve objectives. See Wildlife 

Chapter 3.5 for information about how invasive plants affect wildlife species associated with older 

forests. 

Additional laws, direction, and broader-scale analyses are discussed in the Specialist Reports in the 

Project Record, which are incorporated by reference in this Environmental Impact Statement. Prevention 

of the spread of invasive plants from land uses is addressed in the R6 2005 ROD, the MBS 2005 DN, the 

MBS Forest Plan and Forest Service policies. 

1.5 Proposed Action

The Proposed Action would update the current treatment program to more cost-effectively contain, 

control, and eradicate invasive plants on the Forest. The Proposed Action has six components: (1) use of 

any of 10 herbicides and approved additives, (2) a Forest Plan amendment to add aminopyralid to the list 

of available herbicides on the Forest, (3) broadcast herbicide application methods would be used 

(generally on contiguous infestations that have more than 70 percent coverage with invasive plants), (4) 

invasive plants would be treated in wilderness areas using all treatment methods except mechanical and 

broadcast herbicide, (5) the new invader strategy would be modified, and 6) mechanical treatments would 

be approved for use outside of wilderness areas. More information about the Proposed Action is in 

Chapter 2. 

This project does not include (and additional NEPA would be required for): 

Herbicide application directly to water 

Aerial application of herbicides 

Use of any pesticides other than herbicides

Treatment of aquatic invasive plants (floating and submerged)

Treatment of native plants

Use of mechanical equipment or broadcast spraying in wilderness

Changes in land uses to slow or prevent the introduction or spread of invasive plants

1.6 Decision Framework 

Based on the environmental analysis, the Forest Supervisor will decide: 

Whether to continue to implement the current invasive plant treatment program or authorize 

changes, including treatment of invasive plants in wilderness areas and use of additional herbicide 

ingredients. 

Whether or not to amend the MBS Forest Plan to include the use of aminopyralid

What management requirements, mitigation measures, and monitoring should be applied to 

invasive plant treatments.

9 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 1

1.7 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. 7

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. 

1.8 Issues 

The Forest Supervisor reviewed public comments received during scoping and the preliminary 

environmental effects identified by the ID Team assigned to the project. One purpose of the review was to 

determine if there were any key issues to be addressed, based on criteria for issues in the Council on 

Environmental Quality (CEQ) regulations at 40 CFR 1501.7. Non-key issues are defined as those:

§ Outside the scope of the proposed action

§ Already decided by law, regulation, Forest Plan, or other higher level decisions 

§ Irrelevant to the decision to be made 

§ Conjectural and not supported by scientific or factual evidence

Issues may be “key” due to the extent of their geographic distribution, the duration of their effects, or the 

intensity of public interest or resource conflict. Two key issues were identified: 

§ Treatment effectiveness

§ Herbicide toxicity 

The key issues were used to (1) improve the project design to better minimize adverse impacts and 

improve treatment effectiveness; (2) develop alternatives to the proposed action and (3) focus the EIS 

analysis in Chapter 3. 

Chapter 3 also includes analysis to address the following topics: 

7 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 Okanogan-Wenatchee 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. 

10 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 1

§ Findings and determinations for the Endangered Species Act

§ Compliance with Clean Water Act, Clean Water Act Permits

§ Compliance with management direction, especially MBS Forest Plan Standards and 

Guidelines 

§ Impacts on soil and water resources

§ Impacts on scenery and recreation

§ Cultural and archeological impacts

1.8.1 Key Issue #1: Treatment Cost-Effectiveness

This key issue encompasses comments received relating to the cost-effectiveness of the treatment. 

Comments included questions about the cost of the project and its ability to effectively treat invasive 

plants, the effectiveness of hand pulling and other non-chemical methods, the need to use broadcast 

treatments, the need for flexibility in the “new invader” strategy (also referred to as Early Detection and 

Rapid Response - EDRR), the need for native plant revegetation on treated sites, and the need for an 

adaptive management strategy to allow for effective repeated treatments over time. The following 

indicators are used to compare alternatives in this EIS8

: 

Estimated Total Cost for Treating Known Sites in 5 years 

Estimated Average Cost Per Acre

Estimated Maximum Cost in Dollars, Assuming Average Cost Treatment Plus Restoration Applied 

to Known Sites and EDRR Acres

Estimated Years to Effectively Treat Known Sites Assuming Annual Budget of $200,000 per year 

Acres Where Ability to Control or Eradicate Target Plants May be Compromised

1.8.2 Key Issue #2: Herbicide Toxicity

Comments about the effects of herbicide on human health, botany, wildlife and fish herbicide use were 

lumped into one key issue: herbicide toxicity. The following indicators are used to compare alternatives in 

this EIS: 

Human Health: Number and character of “plausible exposure scenarios” where “Hazard 

Quotient” may be greater than 1 for herbicide applicators (workers)

Human Health: Number and character of “plausible exposure scenarios” where “Hazard 

Quotient” may be greater than 1 for the public 

Human Health: Character and effectiveness of Management Requirements and Mitigation 

Measures (MR/MM) intended to minimize or eliminate risk to human health

Botany: Relative risk to botanical species of conservation concern from herbicide use

Wildlife: Relative risk to wildlife/habitat from herbicide use (may also find an indicator similar to 

the one used for fish) 

Fish: Relative risk to fish/habitat from herbicide use

8 Indicators have been edited for clarity. 

11 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 1

Fish: First year/first choice use of aquatic glyphosate or triclopyr within aquatic influence zones

(two herbicides that may be used near water and are associated with hazard quotients greater than 

1 for fish). 

The following concerns expressed in the scoping responses are not considered key issues because they are 

addressed by laws, policies and the R6 2005 ROD/MBS Forest Plan: 

How invasive plant prevention measures are applied to land uses 

Monitoring Protocols 

Findings/uncertainty/credibility of herbicide risk assessment and registration process 

Philosophical objections to or new requirements for herbicide use on the MBS 

Labor source (volunteer, other) and job creation

Effects from non-herbicide treatments

Objections to treating invasive plants. 

12 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Chapter 2. Alternatives Including the Proposed Action

2.1 Introduction 

Chapter 2 describes and compares the alternatives considered in detail for implementation of the Mount 

Baker-Snoqualmie National Forest Invasive Plant Treatment project. This chapter includes a description 

of actions common to all alternatives, and actions for each alternative considered. It also compares the 

alternatives, defining the differences between each alternative and providing a clear basis for choice 

among options to be considered by the decision maker. Chapter 2 describes the existing invasive plant 

treatment approach and alternative ways to increase treatment effectiveness, while minimizing adverse 

effects. All of the alternatives, including no action, would treat invasive plants using manual, chemical, 

and biological methods. Both action alternatives would increase the number of herbicide options and 

would authorize mechanical treatments, however Alternative 3 would not include use of aminopyralid. 

2.2 Invasive Plant Treatment Methods Common to All 

Alternatives 

Manual, cultural, chemical and biological methods are currently being used, and would continue to be 

used, to treat invasive plants on the MBS. Restoration of treated sites is also included in all alternatives. 

Manual treatment refers to hand pulling and digging with tools such as a shovel or hoe to remove plants 

or cut off seed heads. Cultural treatments include tarping and competitive seeding. Chemical herbicides 

are used to kill plants and/or prevent seeds from germinating. Herbicide additives (adjuvants) such as 

surfactants may be used to improve effectiveness.

Table 3 shows the herbicide application methods currently approved. 

Table 3. Herbicide application methods and descriptions

Application 

Method Description

Selective 

spraying Targets individual plants. Herbicide is usually applied by hand.

Spot 

Spraying

Targets individual to small clumps of plants. Herbicide is usually applied with a backpack sprayer or 

other hand pump system. Spot spraying is also done using a hose off a truck-mounted or ATVmounted tank.

Broadcast 

spraying

Herbicide is applied to larger areas of invasive plants. This method is used when the invasive plant

is dense enough that it is difficult to discern individual plants and the area to be treated makes spot 

spraying impractical. This method is currently approved for Skiyou Island only. Broadcast spraying 

is most often applied via a truck or ATV mounted hose or boom. 

Biological control agents (biocontrols), generally insects, are distributed to help suppress or contain larger 

infestations. These agents attack and weaken targeted invasive plants and reduce their competitive or 

reproductive capacity. Biological control agents have been distributed locally for the following host 

species: Dalmatian toadflax, meadow and spotted knapweed, field bindweed, hawkweed, scotch broom, 

and St Johnswort. Table 4 displays the biological control agents (insects) currently occupying host species 

on the MBS.

Biological control agents are likely to suppress or contain an established population of invasive plants; 

however, other integrated treatments are usually necessary to control or eradicate populations over the 

long term. 

13 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

United States Department of Agriculture-Agricultural Plant Health Inspection Service (USDA-APHIS) 

approves each step in the importation and release of biological control agents in the United States. 

Biological control agents undergo a rigorous testing procedure prior to being available for release. Initial 

testing occurs in quarantine laboratories abroad and in the United States. The agents are tested for their 

effectiveness in controlling the target organism, and for their host specificity. 

NEPA decisions for the release and distribution of the agent in the United States (Beard and Carbone 

2001), assuming that biological control agents would be distributed throughout North America to 

wherever the target species exists. Local redistribution of biological control agents is tiered to USDA - 

APHIS NEPA analysis. Release of biological control agents is not considered a site-specific action 

because “these agents are expected to occupy invasive plant hosts on National Forests regardless of any 

action the Forest Service may take (Beard and Carbone 2001).”For more information on biological 

control agents, please see the R6 2005 FEIS and its Appendix J. 

Table 4. Biological control agents found on the MBS

Invasive Plant Scientific Name

Biocontrol Agent

bull thistle Urophora stylata

Canada thistle

Urophora cardui

Hadroplontus litura (formerly: Ceutorhynchus litura)

field bindweed 

Tyta luctuosa

Aceria malherbae

knapweeds

Bangasternus fausti

Chaetorellia acrolophi

Cyphocleonus achates

Terellia virens

Larinus minutus

Larinus obtusus

Urophora affinis

Pelochrista medullana

Pterolonche inspersa

Sphenoptera jugoslavica

Agapeta zoegana

orange hawkweed Aulacidea subterminalis

Scotch broom

Bruchidius villosus

Exapion fuscirostre

14 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Invasive Plant Scientific Name

Biocontrol Agent

St. Johnswort

Chrysolina hyperici

Chrysolina quadrigemina

Agrilus hyperici

Aplocera plagiata

tansy ragwort Longitarsus jacobaeae

toadflax

Mecinus janthinus

Brachypterolus pulicarius

Calophasia lunula

Gymnetron antirrhini

2.3 Alternative 1 – No Action

2.3.1 Introduction

2.3.1.1 Alternative 1 at a Glance

Treatment Methods Manual, biological, and chemical (herbicide)

Herbicides Approved Clopyralid, aquatic glyphosate and aquatic imazapyr. Metsulfuron methyl at 

Skiyou Island only.

Application Methods

Generally, selective or spot treatments with a backpack or hand tools.

Broadcast is approved at Skiyou Island for glyphosate and metsulfuron 

methyl.

Acreage Limitation No explicit acreage limitation.

EDRR Approach A new annual newsletter is produced each spring, listing the new sites.

Under the No-Action Alternative , the MBS 2005 DN9 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

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

§ Use of the surfactant Agri-Dex®

9 In 2008, based on a supplemental information report (2008 MBS SIR) the Forest Supervisor determined that use of 

two of the herbicides analyzed in the R6 2005 FEIS (clopyralid and imazapyr, in lieu of aquatic glyphosate on some 

sites) would not result in adverse effects outside of the scope of the 2005 MBS DN. 

15 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

§ broadcast application of glyphosate and metsulfuron methyl at Skiyou Island only 

§ restoration of treated sites

2.3.2 Integrated Treatment Prescriptions

Table 5 displays the common names of target species mapped on the MBS, the number of sites and total 

estimated acreage occupied by that species, herbicides currently approved for use, and the non-herbicide 

treatments that are likely to be used in combination with herbicide use or alone where effective.

16 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Table 5. Integrated treatment prescriptions - Alternative 1 (No Action)

Common Name

Approximate 

Number of 

Sites 

Approximate 

Acreage

Infested

Herbicides Currently 

Approved

Effective Non-Herbicide Treatments (Alone or in 

Combination with Herbicide Use)

Absinth wormwood 1 2.2 clopyralid, aquatic glyphosate Non-herbicide treatments are not effective.

Birds-foot trefoil 2 22 clopyralid, aquatic glyphosate Manual digging. Removing flowering plants, non-flowering 

can be left on site to dry.

Bittersweet nightshade 1 <1 aquatic glyphosate, aquatic 

imazapyr

Manual digging. All plant parts should be removed from 

site.

Black locust 1 <1 aquatic glyphosate Hand cutting.

Bull thistle 107 63 aquatic glyphosate, clopyralid

Effective biological control agents. Manual pulling and 

digging. Leave roots on site to dry, bag seed heads if 

present

Butterfly bush 15 22 aquatic glyphosate, imazapyr

Effective biological control agents. Manual pulling, digging 

and cutting. Rhizomatous, suckering plants, remove all 

plant parts from site. 

Canada thistle 159 404 clopyralid, aquatic glyphosate Effective biological control agents. 

Common burdock 2 <1 clopyralid, aquatic glyphosate Manual pulling and digging. Seeds to be removed from 

site, all other plant parts can remain on site.

Common comfrey 3 <1 clopyralid, aquatic glyphosate Non-herbicide treatments are not effective.

Common groundsel 4 <1 clopyralid, aquatic 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 aquatic glyphosate Manual pulling, raking and digging. Can be left on site to 

dry.

Common tansy 19 73

aquatic glyphosate, 

metsulfuron methyl at Skiyou 

Island

Manual digging. Remove all flower/seed heads from site, 

all other plant parts can be left at site.

Common teasel 1 <1 clopyralid

aquatic glyphosate Non-herbicide treatments are not effective.

Cutleaf blackberry 12 32 aquatic glyphosate Manual pulling and digging. All plant parts can be left on 

site to dry.

Dalmatian toadflax 8 24 aquatic glyphosate Effective biological control agents. Manual pulling and 

digging. All parts except seeds can be left on site.

17 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Common Name

Approximate 

Number of 

Sites 

Approximate 

Acreage

Infested

Herbicides Currently 

Approved

Effective Non-Herbicide Treatments (Alone or in 

Combination with Herbicide Use)

Diffuse knapweed 3 41 clopyralid, glyphosate

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 aquatic glyphosate Manual digging. Plant parts can be left on site to dry.

English holly 4 <1 aquatic glyphosate Manual pulling and digging. Mechanical cutting. Plants 

can be left on site to dry.

English ivy 3 <1 aquatic glyphosate Manual pulling and digging. Seeds removed, all other 

plant parts can be left on site to dry

European lily of the valley 1 <1 aquatic glyphosate Manual digging. Remove all plant parts from site.

Field bindweed 4 <1 aquatic glyphosate Effective biological control agents. 

Giant hogweed 1 <1 aquatic glyphosate

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, aquatic glyphosate Manual digging. Competitive seeding. All but flower/seed 

heads can be left on site.

Hawkweed- Non-native 

(common, orange, yellow, 

spotted, smooth)

140 1,233 clopyralid, aquatic glyphosate Effective biological control agents. Manual pulling and 

digging. All plant parts should be removed from site.

Hedge false bindweed 4 <1 aquatic glyphosate Non-herbicide treatments are not effective.

Herb Robert 126 850 aquatic glyphosate Manual pulling and digging. Plants not in flower can be left 

on site, all others removed.

Himalayan blackberry 14 55 aquatic glyphosate Manual pulling and digging. All plant parts can be left on 

site to dry.

Jewelweed 1 3 aquatic glyphosate Manual pulling. Plants in flower should be removed.

Knotweed (Bohemian, 

giant, Japanese) 74 892 aquatic glyphosate, aquatic imazapyr Non-herbicide treatments are not effective.

Meadow knapweed 3 11 clopyralid, aquatic glyphosate Effective biological control agents. Manual digging. All 

plant parts except flower/seed heads can remain on site.

Oxeye daisy 3 156 clopyralid, aquatic glyphosate Manual pulling and digging. All plant parts except flowers 

can be left on site.

18 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Common Name

Approximate 

Number of 

Sites 

Approximate 

Acreage

Infested

Herbicides Currently 

Approved

Effective Non-Herbicide Treatments (Alone or in 

Combination with Herbicide Use)

Poison hemlock 1 <1 aquatic glyphosate Manual pulling and digging. Plant parts except seeds can 

be left on site.

Policeman’s helmet 1 <1 aquatic glyphosate Manual pulling and digging. Remove flower heads/seed 

from site.

Reed canary grass 3 121 aquatic glyphosate, aquatic 

imazapyr Approved non-herbicide methods are not effective. 

Rhubarb 1 <1 aquatic glyphosate, imazapyr, 

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

Scotch broom 73 141 aquatic glyphosate

Effective biological control agents. Manual pulling and 

digging. All plants parts except those with seed pods can 

be left on site.

Spotted knapweed 32 173 clopyralid, aquatic glyphosate

Effective biological control agents. Manual pulling and 

digging. All plant parts except flower/seed heads can 

remain on site.

St. Johnswort 1 2 aquatic glyphosate Effective biological control agents. Manual pulling and 

digging. Remove all plant parts from site.

Sulphur cinquefoil 12 75 aquatic glyphosate Manual pulling and digging. All plant parts except seeds 

can be left on site.

Tansy ragwort 75 319

clopyralid, aquatic glyphosate, 

metsulfuron methyl at Skiyou 

Island

Effective biological control agents. Manual pulling and 

digging. All flowering parts, including those not yet in 

bloom, removed from site.

Wild carrot 4 2 aquatic glyphosate Manual pulling. Remove flower/seeds from site.

Woolly hedgenettle 1 <1 aquatic glyphosate, aquatic 

imazapyr

Manual pulling and digging. Remove all plant parts from 

site.

Yellow archangel 6 <1 aquatic glyphosate, aquatic 

imazapyr

Manual pulling and digging. Remove all plant parts from 

site.

Yellow flag iris 1 <1 aquatic glyphosate, aquatic 

imazapyr

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.

19 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

2.3.3 Management Requirements and Mitigation Measures (MR/MM)

The following Management Requirements and Mitigation Measures (MR/MM) would continue to apply 

to invasive plant treatments. 

General

1. In treating any/all infestations, all applicable management requirements and practices, included in the 

Forest Plan Prevention Strategy, Best Management Practices (BMPs) for invasive plants will be 

followed.10

2. In particular, after working in invasive plant sites, all tools, equipment, and gear must be cleaned 

(power wash or high pressure spraying) before leaving the area, in order to avoid spreading the 

infestation further.

3. All invasive species management must be coordinated with all other site or area resources objectives.

4. Biocontrol treatments will use only those control agents that have been approved by the U.S. 

Department of Agriculture Animal and Health Inspection Service and permitted by the State of 

Washington. 

5. Any mulch used must be approved as invasive plant free, meeting the Forest Plan, Forestwide 

Standards and Guidelines, Prevention Strategy and BMPs.11

General Herbicide Use

6. No broadcast spraying (aerial or boom) will occur. 

7. Any preparation, transport, or application of herbicide will be done by trained workers with a current 

Washington State pesticide applicators license.

8. Only the aquatic formulation of glyphosate will be used, and at the lowest effective rate as per 

manufacturer label specifications, which is estimated to be 2.5 to 5 percent solution of the aquatic 

formulation of glyphosate diluted in water (3 ounces manufacturer’s concentrate per gallon of water). 

Refer to Mitigation Measure #19, below, for application via stem injection.12 

9. If needed, the only surfactant that will be used is Agri-Dex®. 

10. Pretreatment briefings will 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. 

Herbicide and Surfactant Transport, Mixing, Use

11. Materials Safety Data Sheets, and Forest Service Information covering glyphosate and Agri-Dex® 

must be carried in each vehicle at all treatment times, and made available to interested members of 

the public, on-site.

12. Glyphosate and Agri-Dex® containers must be secured and prevented from tipping during transport. 

13. Workers will carry only enough herbicide daily to cover the proposed treatment for that day. 

10 This Forest Plan guidance was updated by the R6 2005 ROD Standards. 11 This Forest Plan guidance was updated by the R6 2005 ROD standards. 12 In 2008, the Forest Supervisor authorized use of two additional herbicides (clopyralid and imazapyr), finding that 

use of these herbicides would have effects within the scope of the MBS 2005 DN. 

20 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

14. Mix only the amount of solution needed to complete daily treatments.

15. Workers will follow all herbicide label guidelines.

16. Containment mats will be used during mixing, to further avoid the risk of a spill. 

17. Do not mix glyphosate or glyphosate with Agri-Dex® within 300 feet of riparian areas, wetlands, or 

surface water.

18. When glyphosate (with Agri-Dex®) is administered via wand-backpack spray, hand wiped, or painted 

on cut stems, the applicator will use the lowest effective rate 

19. For stem injection: only the lowest effective dose will be used on the MBS. The current 

recommended effective dose is 100 percent of the manufacturer’s concentrate. Trial studies suggest 

that 2 to 3 milliliters per stem can be effective (The Nature Conservancy 2004, Clallam County 

2004). New preliminary research has found that 2.5 milliliters per stem is effective (personal 

communication, Dr. Timothy Miller, Washington State University Extension Service. Mt. Vernon, 

WA. May 2005) 

20. Stem injection method would only be used on very small, high-priority infestations with difficult 

access.

21. No applications using wand-backpack spray will occur when wind speed exceeds five miles per hour, 

to lessen drift, or when precipitation is expected within 24 hours. 

22. No hand wiping of leaves with the aquatic formulation of glyphosate with Agri-Dex® will be done 

when precipitation is expected within 24 hours. 

23. Application will occur only outside of timing constraints for wildlife, and when the chance of rain 

after application is very low. 

24. Herbicide mixture aquatic formulation of glyphosate with or without Agri-Dex® will be colored with 

a bright, non-toxic vegetable dye before application. This will (a) minimize the possibility of 

accidentally applying herbicide to non-target species; (b) minimize the amount of herbicide used, by 

avoiding re-application 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. 

Soils/Water/Fisheries

25. Soil disturbance (e.g., hand digging, grubbing, pulling) will be minimized to the extent possible. 

Restoration of treated areas will follow the restoration treatment proposed for each site. 

26. As noted above [measure 17], all herbicide spray mixtures (aquatic formulation of glyphosate with or 

without Agri-Dex®) would not be prepared within 300 feet of riparian areas, wetlands, or surface 

water.

27. Containment mats will be used during mixing to further avoid the risk of a spill. 

28. Any mulch used must be approved as invasive plant free, meeting the Forest Plan, Forest-wide 

Standards and Guidelines, Prevention Strategy and BMPs.13

13 This standard was updated by the R6 2005 ROD. 

21 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Wildlife

29. From January 1 through August 15, restrict all treatment activity in known or suspected bald eagle 

nest territories.

30. Baker River Inlet to Baker Lake, Site 106: from November 1 through March 31, restrict all treatment 

activity near known, occupied eagle roost sites or key eagle foraging areas.

31. From March 1 through July 15, restrict activities generating noise above ambient levels within 35 

yards of suitable spotted owl nesting habitat.

32. From April 1 through August 5, restrict activities generating noise above ambient levels within 35 

yards of suitable marbled murrelet nesting habitat. 

33. For infestation treatments located within or adjacent to suitable nesting habitat for murrelets, leaving 

garbage or trash in the area is prohibited.

Vegetation, Plants

34. MBS Botanists will consistently provide training to contractors, state-wide, to educate them on 

accurate identification of invasive plants, so that only target species are treated and other desirable 

species are left unharmed.

35. If any previously undiscovered rare plants are found within the project area, work will be halted until 

the Forest Service botanist is consulted and necessary mitigation measures are enacted.

Heritage Resources 

36. An information packet will be provided 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, how to identify prehistoric artifacts) and instructions for any historic or 

prehistoric resources that may be found. 

37. If a previously unidentified resource is discovered during project implementation—under any 

treatment method—or if at any time a resource that may be eligible for the National Historic Register

of Historic Places is affected in an unanticipated way, reasonable steps will be taken to avoid or 

minimize harm to the resource until the Forest Service can fulfill its consultation requirements in 

accordance with the Programmatic Agreement for Heritage Resources (1997) (see project files).

Recreation, Public Use 

38. For any site where recreation use or activity is high and invasive plant infestations are located other 

than along the peripheral (e.g., edges of parking lots, along road shoulders), any treatment using the 

aquatic formulation of glyphosate (with or without Agri-Dex®) will occur only during the week, and 

not on weekends or 3-day holiday weekends. Sites will be signed and flagged.

39. The only two examples [requiring special mitigation for recreation/public use] among the 91 specific 

sites proposed for treatment are Gold Creek Pond (polygon # 48) and Buck Creek Camp (polygon # 

148). While Buck Creek Camp is not operating for the 2005 season (camp is for sale), any treatment 

using the aquatic formulation of glyphosate (with or without Agri-Dex®) will be contingent upon 

scheduling with the Camp management, or the care-taker.

Worker and Public Health and Safety

40. All workers will comply with Occupational Health and Safety Administration (OSHA) standards, 

Forest Service Health and Safety Code Handbook, and other guidelines, BMPs, and manufacturers’ 

recommendations to reduce the risk of injury to workers.

22 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

2.3.4 Early Detection Rapid Response

The MBS 2005 EA included the following elements in a “New Invader Strategy”:

§ Based on the previous year’s surveys, new invasive plant infestations would be documented 

[using the forms in Appendix D of the 2005 EA]. 

§ New infestation sites would be prioritized. 

§ The current “set” of high-priority sites would be included in each year’s prioritization, which 

could result in a newly-discovered site being ranked as a higher priority for treatment. 

§ Once a new site is ranked as a high priority, an initial proposed treatment and restoration plan 

would be selected, based on the type of invasive plant, size of infestation, and location. Tools 

to make this assessment would include, but not be limited to: the biology of each invasive 

plant species and their control history [Appendix C of the 2005 MBS EA]; and MBS specific 

experience with treating invasive species [Appendix B, of the 2005 MBS EA]. The only 

treatment methods available for selection would be those included in the [2005 MBS] EA, 

along with all Management Requirements and Mitigation Measures. 

§ A new annual newsletter would be produced each spring, listing the new sites. It would be 

mailed to all interested parties, including agencies (such as USDI Fish and Wildlife Service 

(FWS), and NOAA Fisheries14), Tribes, and others. Comments would be solicited. 

§ For each new, high-priority site: the effects on other resources from treatment/restoration 

would be estimated. This information would be included in the newsletter. 

§ If the effects are found to be within the scope of this EA, and USFWS and NOAA Fisheries 

concur through informal Section 7 (ESA) consultation, sites would be added as addenda.

§ All treatments would be accomplished as funding is available.

2.3.5 Monitoring

Under the No-Action Alternative, treatment effectiveness monitoring would continue following national 

protocols established under the Forest Service National Resource Inventory System (NRIS). 

14 Currently, this agency is referred to as National Marine Fisheries Service (NMFS). 

23 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

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24 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

2.4 Alternative 2 – Proposed Action

2.4.1 Introduction

2.4.1.1 Alternative 2 at a Glance

Treatment Methods Manual, mechanical, cultural, chemical (herbicide) and biological. Restoration of 

treated sites. 

Herbicides Approved

Herbicide formulations containing 1 or more of the following 10 active ingredients: 

aminopyralid, chlorsulfuron, clopyralid, glyphosate, imazapic, imazapyr, metsulfuron 

methyl, picloram, sulfometuron methyl, and triclopyr. Of these, aminopyralid, 

triclopyr, and metsulfuron methyl are first year/first choice herbicides that are not 

currently in use on the MBS1. 

Forest Plan

Amendment Yes, to add aminopyralid to the list of authorized herbicides. 

Application Methods Selective, spot, or broadcast treatments. 

Treatment Acreage 

Limitations 

Annually, treatment using herbicide would not exceed about 5,000 infested acres 

per year and no more than 13,500 acres of new detections would be treated with 

herbicide over the life of the project (based on approximately 10 percent spread per 

year for 10 years).15 

No more than 18% of the area within 150 feet of any flowing stream would be 

treated with herbicide annually (10 acres per 1.5 miles of stream). 

EDRR Approach 

Develop site prescriptions and address any resources of concern. Follow herbicide 

use decision criteria 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 preseason report. 

1

Metsulfuron methyl is currently approved for use at Skiyou Island based on the 2008 Invasive Weed Treatment DN. 

Alternative 2 (Proposed Action) includes: 

Use any of nine herbicides that were analyzed in the R6 2005 FEIS, alone or in combination with 

manual, mechanical, biological and cultural methods. 

Management requirements and mitigation measures (MR/MM). 

Amendment of the MBS Forest Plan to allow for use of an additional herbicide, aminopyralid 

(Milestone®; Milestone VM®), to increase treatment effectiveness. 

Approval of the broadcast method of application where needed. Most of the proposed herbicides 

would not be broadcast near streams and other water bodies or in other sensitive areas. 

Allow for invasive plant treatment in wilderness areas using any of the treatment methods except 

broadcast herbicide application and mechanical removal. 

Allow for mechanical (mowing and string trimming) treatments where appropriate outside 

wilderness. 

Alternative 2 would replace the “new invader strategy” with an Early Detection, Rapid Response (EDRR) 

process. The EDRR process would ensure that treatment prescriptions and MR/MM are appropriately 

applied to new sites.

15 The 13,500 acre limit applies specifically to new detections found during the life of the project. It does not 

infested areas that are currently mapped. This measure has been edited for clarity. 

25 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Table 6 details proposed integrated treatment prescriptions for each invasive species. Additional 

information about each invasive species site is on file at the Mount Baker-Snoqualmie National Forest 

Headquarters. Treatments are often a combination of methods, such as herbicide/manual or 

cultural/manual. More herbicide options may be available for any given site with the action alternatives, 

compared to No Action, and there might be more flexibility in the method of application. However, all 

treatments would be done according to the Management Requirements and Mitigation Measures 

(MR/MM) listed in Table 9 and would follow the herbicide use buffers near streams and other water 

bodies shown in Table 10. 

2.4.2 Forest Plan Amendment 

The Proposed Action would add aminopyralid to the list of approved ingredients in Standard 16 for the 

MBS NF (non-significant Forest Plan amendment). All other standards and guidelines for invasive plant 

management would not change. 

Currently Standard 16 reads: 

Select from herbicide formulations containing 1 or more of the following 10 active 

ingredients: chlorsulfuron, clopyralid, glyphosate, imazapic, imazapyr, metsulfuron 

methyl, picloram, sethoxydim, sulfometuron methyl, and triclopyr...Additional 

herbicides and herbicide mixtures may be added in the future at either the Forest Plan

or project level through appropriate risk analysis and NEPA/ESA procedures.

Standard 16 would be amended to read (additions/changes in italics): 

Select from herbicide formulations containing 1 or more of the following 11 active 

ingredients: aminopyralid, chlorsulfuron, clopyralid, glyphosate, imazapic, imazapyr, 

metsulfuron methyl, picloram, sethoxydim, sulfometuron methyl, and 

triclopyr...Additional herbicides and herbicide mixtures may be added in the future at 

either the Forest Plan or project level through appropriate risk analysis and 

NEPA/ESA procedures.

2.4.3 Integrated Treatment Prescriptions 

No single treatment method is ideal for all invasive plant control situations. The Proposed Action would 

include a combination of effective and practical integrated treatments depending on the target species, 

location and other site conditions. Treatment options for each target species would be increased compared 

to Alternative 1; in addition to chemicals already in use on the MBS, a wider variety of herbicides and 

adjuvants could be used. Mechanical mowers and string trimmers could be used as in areas outside of 

wilderness. 

Table 6 displays the herbicides that are likely to be effective for each known target species on the Forest. 

Table 7 totals acres for each of the first year/first choice treatments. The “first choice” herbicides would 

generally be the preferred entry for the first year on each known site. However, during implementation, 

the “other possible herbicides” may be used in place of the first choice, depending on site conditions at 

the time of treatment. Regardless of whether a given herbicide is the first choice or among the other 

effective choices, the Management Requirements and Mitigation Measures (MR/MM - Table 9) and 

herbicide use buffers that apply to the herbicide selected for use would be implemented. As long as the 

MR/MM and herbicide use buffers were followed, any of the 10 proposed herbicides may be used at any 

site. 

26 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Table 6. Integrated Treatment Prescriptions – Alternative 2 (Proposed Action)

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.

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.

27 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

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 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.

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.

28 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

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)

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.

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.

29 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

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)

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.

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.

30 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Table 7. Total acres for each first year/first choice treatment under Alternative 2

First Year/First Choice Treatment Total Acres

biocontrol 80

manual 101

aminopyralid 2,368

clopyralid 180

chlorsulfuron 24

glyphosate 1,068

glyphosate/imazapyr mix 892

metsulfuron methyl 150

triclopyr 15

Approximately 2,470 acres of known sites are currently of a size or density great enough to warrant 

broadcast application. The first year/first choice herbicides for broadcast sites in the current inventory 

include aminopyralid, clopyralid, glyphosate, and metsulfuron methyl (Table 8). Over time, other 

herbicides may be broadcast if needed, as long as MR/MM and herbicide use buffers are followed. In 

accordance with the R6 2005 ROD Standard #16, no broadcast of triclopyr would be authorized. This 

acreage does not consider the influence of MR/MM and herbicide use buffers (Table 9 and Table 10) that 

prohibit broadcasting of herbicides near streams and other sensitive areas (for example “roads that have a 

higher risk of herbicide delivery to fish bearing streams”). 

Table 8. Herbicide active ingredient and estimated broadcast acres 

First Year/First Choice Herbicide Active

Ingredient/Target species

Estimated Broadcast Acres for Known Sites

Aminopyralid

Canada thistle 293.7

Common hawkweed 599.9

Diffuse knapweed 9.9

Meadow hawkweed 143.4

Orange hawkweed 159.0

Oxeye daisy 155.2

Scotch broom 62.7

Smooth hawkweed 62.5

Spotted hawkweed 31.5

Spotted knapweed 46.7

St. Johnswort 1.6

Tansy ragwort 107.4

Yellow hawkweed 138.6

Acres Broadcast Aminopyralid 1,812.1

Clopyralid

Hairy cat's ear 158.4

Acres Broadcast Clopyralid 158.4

Glyphosate

31 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

First Year/First Choice Herbicide Active

Ingredient/Target species

Estimated Broadcast Acres for Known Sites

Cutleaf blackberry 24.9

Herb Robert 167.3

Himalayan blackberry 46.1

Reed canarygrass 120.3

Acres Broadcast Glyphosate 358.6

Metsulfuron methyl

Common tansy 67.5

Sulphur cinquefoil 73.7

Acres Broadcast Metsulfuron Methyl 141.2

Total Estimated Acres-Broadcast 2,470.3

2.4.4 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 shrub-like weeds 

occur). 

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

Property, Kaaland Acquisition, Skiyou Island. 

Please see Appendix B for a list of treatment sites and the restoration that would be applied to each site.

Active restoration is recommended for about 2,636 acres. 

2.4.5 Management Requirements and Mitigation Measures (MR/MM) 

The Proposed Action would include the Management Requirements and Mitigation Measures (MR/MM)

listed in Table 9. Some of the MR/MM have been refined or clarified between issuance of the draft and 

final EIS documents. One substantive change is elimination of use of POEA surfactants. 

32 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Table 9. 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. 

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 non-target 

species; (b) minimize the 

amount of herbicide used, by 

avoiding re-application 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 off-site 

herbicide drift and run off. 

33 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

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 

followed: 

Minimize likelihood of 

herbicides inadvertently 

reaching botanical species of 

conservation concern.

34 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

MR/MM 

ID Management Requirements and Mitigation Measures Objective

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 non-target 

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. 

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.

35 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

MR/MM 

ID Management Requirements and Mitigation Measures Objective

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 post-application 

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

where > 50% groundcover exists on shallow slope sites and >

70% on steep slope sites, and/or

at reduced rates.

Reduce potential offsite runoff 

transport of herbicides.

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 long-term 

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.

36 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

MR/MM 

ID Management Requirements and Mitigation Measures Objective

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-ofsight, 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 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.

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 

To reduce disturbance to 

nesting falcons and protect 

eggs and nestlings.

37 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

MR/MM 

ID Management Requirements and Mitigation Measures Objective

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.

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.

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 

To avoid exposing 

campground users to 

38 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

MR/MM 

ID Management Requirements and Mitigation Measures Objective

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. 

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. 

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 

39 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Table 10. 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 

use16 

100 50 50 100 50 50

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

2.4.6 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 

16 The alternatives have been modified since the release of the DEIS; no POEA surfactant would be used in any 

alternative.

40 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

(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 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. 

2.4.7 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 6).

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

41 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

§ Application rate and method 

Once the treatment prescription has been refined: 

§ 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. 

See discussion about monitoring later in this chapter for additional information. 

42 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

The Decision to Use Herbicides

The following series of questions to be answered apply to currently known infestations and new sites 

found within or outside treatment analysis areas during ongoing inventory. If the target species population 

is not associated with a size, phenology, density or distribution that warrants herbicide use (alone or in 

combination with other methods), or if herbicide use does not substantially increase treatment efficiency 

(considering the availability of volunteers if needed), then non-herbicide methods would be favored. 

Herbicide Use Decision Criteria

1. Is the target population associated with a size, phenology, density or distribution that warrants herbicide 

use (alone or in combination with other methods)? Consider whether or not herbicides are required for 

treatment effectiveness and/or whether or not the use of herbicides substantially increases costeffectiveness of treatment? Consider whether volunteers may be available to implement of manual 

treatments.

Yes (potentially use herbicides): List potential herbicide choices and integrated prescription. 

Review label directions and project design criteria. Consider non-target vegetation surrounding 

treatment sites and use selective herbicides as appropriate. Consider soil conditions at the 

treatment site. Consider previous treatments that have occurred on the site. Were they effective?

Would another herbicide or combination of methods be more effective? Also note that triclopyr 

may not be used in areas of known special forest product or subsistence collection. Go to 2. 

No: Use non-herbicide methods. 

2. Do the size, density and/or distribution of invasive plants warrant the broadcast application method?

Would another herbicide besides triclopyr be effective? (Please note that triclopyr may not be broadcast)

Yes: Could the treatment site be within no broadcast buffers for effective herbicides? Is the site in 

a wildlife habitat that has specific restrictions to broadcasting? Is this site within a wilderness 

area? Go to 3a. 

No: Go to 3b. 

3a. Apply surface water buffers as appropriate. Is this site within an area where broadcasting is 

prohibited? 

Yes: Do not broadcast. Go to 4. 

No: Go to 3b. 

3b. Are there botanical species of local interest/suitable habitat near the proposed broadcast site? 

Yes: Survey as needed within suitable habitats. Apply botanical buffers as appropriate. Go to 4. 

No: Broadcasting is an acceptable treatment method for herbicides except triclopyr. 

4. Will spot and/or selective methods be reasonably effective in this situation? 

Yes: Apply spot/selective buffers and use aquatic labeled herbicides as appropriate.

No: Consider additional project planning for an effective treatment. 

43 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

2.4.8 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. 

44 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

2.5 Alternative 3 – No Aminopyralid 

2.5.1 Introduction

2.5.1.1 Alternative 3 at a glance

Treatment Methods Manual, mechanical, cultural, chemical (herbicide) and biological. Restoration 

of treated sites. 

Herbicides Approved

Herbicide formulations containing 1 or more of the following 9 active 

ingredients: chlorsulfuron, clopyralid, glyphosate, imazapic, imazapyr, 

metsulfuron methyl, picloram, sulfometuron methyl, and triclopyr. Of these, 

chlorsulfuron, metsulfuron methyl,17 and triclopyr are first year, first choice 

herbicides that are not currently in use on the MBS.

Forest Plan

Amendment No.

Application Methods Selective, spot, or broadcast treatments. 

Treatment Acreage 

Limitations 

Annually, treatment using herbicide would not exceed about 5,000 infested 

acres per year and no more than 13,500 acres of new infestations would be 

treated using herbicide over the life of the project (based on approximately 10

percent spread per year for 10 years). 

No more than 18% of the area within 150 feet of any flowing stream would be 

treated with herbicide annually (10 acres per 1.5 miles of stream). 

EDRR Approach

Develop site prescriptions and address any resources of concern. Follow 

herbicide use decision criteria 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 3 was developed in response to concerns about aminopyralid being a relatively newer 

herbicide with less of a history than the other herbicides proposed for use. Alternative 3 would be the 

same as Alternative 2 minus the use of aminopyralid (trade name: Milestone® or Milestone VM®). 

Alternative 3 would therefore not amend the MBS Forest Plan. 

2.5.2 Integrated Treatment Prescriptions

Under this alternative, slightly fewer acres would be proposed for broadcast treatment than under the 

Proposed Action. Table 11 shows the first choice and other effective herbicides and integrated treatment 

methods that would be used for target species found on the MBS under Alternative 3. More clopyralid, 

metsulfuron methyl and triclopyr would likely be used in comparison to Alternative 2. 

2.5.3 Post-Treatment Restoration

Post-treatment restoration would be the same as for Alternative 2.

2.5.4 Management Requirements and Mitigation Measures (MR/MM)

All of the Management Requirements/Mitigation Measures (MR/MM) and other components of 

Alternative 2 would also apply to Alternative 3, except for MR/MM and herbicide use buffers that apply 

to aminopyralid. Project caps would be the same as for Alternative 2. 

17 With the exception of Skiyou Island where metsulfuron methyl is currently approved (2008 Skiyou Island 

Invasive Weed Treatment DN)

45 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

2.5.5 Early Detection and Rapid Response

The Early Detection and Rapid Response process would be the same as for Alternative 2. 

2.5.6 Implementation Planning Process

The Implementation Planning Process would be the same as for Alternative 2.

2.5.7 Monitoring

All of the monitoring that applies to Alternative 2 would be incorporated into Alternative 3. 

46 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Table 11. Integrated Treatment Prescriptions – Alternative 3 (No Aminopyralid)

Target species

(Common Name)

Approximate

Number of 

Sites 

Approximate 

Acreage 

Infested1

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 2.2 Clopyralid Glyphosate Non-herbicide treatments are not 

effective.

Birds-foot trefoil 2 22 Clopyralid 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 Clopyralid Glyphosate

Triclopyr

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 Clopyralid

Picloram

Glyphosate

Chlorsulfuron

Effective biological control agents. 

Common burdock 2 <1 Triclopyr Clopyralid

Glyphosate

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.

Common groundsel 4 <1 Clopyralid Glyphosate

Manual pulling and digging Nonflowering 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.

47 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Target species

(Common Name)

Approximate

Number of 

Sites 

Approximate 

Acreage 

Infested1

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 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

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 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.

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.

48 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Target species

(Common Name)

Approximate

Number of 

Sites 

Approximate 

Acreage 

Infested1

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)

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 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 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 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.

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.

49 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Target species

(Common Name)

Approximate

Number of 

Sites 

Approximate 

Acreage 

Infested1

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)

Scotch broom 73 141 Triclopyr Glyphosate

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 Clopyralid

Picloram

Glyphosate

Triclopyr

Effective biological control agents. 

Manual pulling and digging. All plant 

parts except flower/seed heads can 

remain on site.

St. Johnswort 1 2 Metsulfuron methyl Picloram

Glyphosate

Effective biological control agents. 

Manual pulling and digging. Remove all 

plant parts from site.

Sulphur cinquefoil 12 75 Metsulfuron methyl

Picloram

Glyphosate

Triclopyr

Manual pulling and digging. All plant 

parts except seeds can be left on site.

Tansy ragwort 75 319

Metsulfuron methyl

(Approved Currently At 

Skiyou Island)

Picloram

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

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.

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.

50 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Table 12. Total Acres by First Year/First Choice Treatment for Alternative 3

First Year/First Choice Treatment Total Acres Comparison to Alternative 2 

biocontrol 80 Same as Alternative 2

manual 101 Same as Alternative 2

aminopyralid 0 2,368 fewer acres than Alternative 2

clopyralid 2,202 2,122 more acres than Alternative 2

chlorsulfuron 24 Same as Alternative 2

glyphosate 1,068 Same as Alternative 2

glyphosate/imazapyr mix 892 Same as Alternative 2

metsulfuron methyl 368 168 more acres than Alternative 2

triclopyr 143 128 more acres than Alternative 2

About 2,407 infested acres are of a density or size large enough to warrant broadcast application. This 

acreage does not consider the influence of MR/MM and herbicide use buffers that prohibit broadcasting 

of certain herbicides near streams and other sensitive areas (such as roads having higher risk of herbicide 

delivery to fish bearing streams). Table 13 shows the first year/first choice acreage likely to require 

broadcast application. 

Table 13. Herbicide active ingredient and estimated broadcast acres for Alternative 3

Herbicide Active Ingredient

Target species Alternative 3 Estimated Broadcast Acres

Clopyralid

Canada thistle 293.7

common hawkweed 599.9

diffuse knapweed 9.9

hairy cat's ear 158.4

meadow hawkweed 143.4

orange hawkweed 159.0

oxeye daisy 155.2

smooth hawkweed 62.5

spotted hawkweed 31.5

spotted knapweed 46.7

yellow hawkweed 138.6

Total Acres Broadcast Clopyralid 1,798

Glyphosate

cutleaf blackberry 24.9

herb Robert 167.3

Himalayan blackberry 46.1

reed canarygrass 120.3

Total Acres Broadcast Glyphosate 358.6

Metsulfuron Methyl

common tansy 67.5

St Johnswort 1.6

51 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Herbicide Active Ingredient

Target species Alternative 3 Estimated Broadcast Acres

sulphur cinquefoil 73.7

tansy ragwort 107.4

Total Acres Broadcast Metsulfuron Methyl 250.2

Total Estimated Acres-Broadcast 2,406.8

2.6 Alternatives Not Considered in Detail 

Federal agencies are required by NEPA to rigorously explore and objectively evaluate all reasonable 

alternatives and to briefly discuss the reasons for eliminating any alternatives that were not developed in 

detail (40 CFR 1502.14(a)). Several alternatives were suggested during the public scoping process and 

were examined by the Interdisciplinary Team. Five alternatives were considered but not evaluated in 

detail. 

2.6.1 Hand Treatments Only, Using a Large Workforce (paid or volunteer)

This alternative would have required that invasive plant be treated using only hand tools (manual). A 

large work force (paid or volunteer) would have been required. All alternatives, including No Action, 

could authorize volunteers or paid crews to pull invasive plants and accomplish other treatments by hand. 

However, several target species would not be effectively contained, controlled or eradicated using hand 

tools and the cost of managing and implementing such an alternative (even with volunteers) would be 

prohibitive. 

2.6.2 Use of Alternative Products

An alternative was suggested that the Forest Service should use vinegar and dish soap, clove oil or other 

homemade or commercial “non-toxic” substances in lieu of herbicides to treat invasive plants. 

Herbicide/additive use is limited to products with Forest Service risk assessments. These products 

suggested have not been assessed and the amount that would need to be used would likely have serious 

environmental consequences (for instance, vinegar could adversely affect soil pH). Steam application was 

also suggested. The equipment for steam application is very expensive and is not widely available. 

2.6.3 Avoid Use of Certain Herbicides Approved in the R6 2005 ROD

An alternative that avoided using specific herbicides approved in the R6 2005 ROD was considered but 

not developed for detailed study. Some of these herbicides (glyphosate, clopyralid, imazapyr and 

metsulfuron methyl) are already in use on the MBS. The Forest Service has assessed the risks of using 

these herbicides and the R6 Regional Forester decided to approve their use. Limitations on herbicide 

choices would tend to reduce the potential cost-effectiveness of the treatment project. The first year/first 

choice herbicides were selected for their relatively high effectiveness and relatively low risk. Having 

other effective herbicides available increases the likelihood of treatment effectiveness over time. This 

alternative was not carried forward for full analysis because it would not meet the purpose of the project 

to treat invasive plants in the most cost-effective manner possible, while meeting Forest Plan standards

that minimize risk. The risks from herbicide use would be minimized by Management Requirements and 

Mitigation Measures, herbicide use buffers, and project caps.

52 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

2.6.4 No Broadcasting

An alternative that would have required spot or selective herbicide application (no broadcasting) was 

considered but not developed for detailed study. Preliminary analysis for this alternative was conducted 

and the IDT found that the herbicide use buffers and Management Requirements and Mitigation Measures

effectively minimized the risks of broadcasting. Thus, this alternative would have reduced effectiveness 

without providing any additional resource protection so it was not developed for detailed study. 

An alternative was suggested that eliminated broadcasting within wilderness areas. Broadcast spraying is 

not proposed within wilderness areas in any alternative. 

2.6.5 Integrate Prevention into Alternatives

An alternative that integrated invasive plant prevention measures into land uses was considered but not 

developed for detailed study. Prevention is already part of the MBS invasive plant management program 

and measures for preventing invasive plants are already integrated into land use activities. The purpose 

and need for this project is limited to meeting treatment objectives on existing and newly detected 

invasive plants found on the MBS. Prevention is routine on the MBS and would occur regardless of 

alternative in this EIS, including No Action (Alternative 1). 

2.6.6 Goat Grazing

During the comment period to the DEIS, one comment letter mentioned that use of goats to eat invasive 

plants should be considered. Goats can be an effective means of reducing biomass associated with 

invasive plants. Goats must remain on a site for a long period and a goat herder must remain on site full 

time to ensure safety and environmental protection (Briana Murphy presentation at the Oregon Vegetation 

Management Association 2014 Conference). Grazing to manage weeds on roadsides, trailheads, and 

larger infestations on the forest is limited because of the difficulty of maintaining and managing the 

animals. Invasive plants can compensate quickly after the grazing pressure is removed because their seeds 

are long-lived in the soil, and because they can rapidly increase flower stem production once grazing 

pressure is removed (R6 2005 FEIS page 3-84). 

The Forest Service could consider using goats as an invasive plant treatment method in the future if an 

appropriate site is identified. This alternative was not developed for detailed study in this EIS because no 

sites appropriate for grazing have been identified and thus, no site-specific effects analysis could be 

conducted. 

2.7 Alternatives Compared 

This section summarizes and compares the alternatives by the activities proposed, and how each responds 

to the issues and the related effects on the issue indicators, based on the analysis in Chapter 3. Table 14 

compares the components of each alternative. Table 15 compares Management Requirements and 

Mitigation Measures currently in use under No Action to those that would be included in the action 

alternatives. Table 16 compares the existing and proposed new invader/EDRR strategy. Table 17 

compares the alternatives in terms of their response to the issues listed in Chapter 1 and analyzed in 

Chapter 3. 

53 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Table 14. Comparison of Alternative Components

Alternative 

Component

No

Action (Alternative 1)

Proposed

Action (Alternative 2)

No Aminopyralid 

(Alternative 3)

Treatment 

Methods

Manual, biological, cultural 

and chemical (herbicide). 

Restoration of treated 

sites.

Same as Alternative 1, with the addition of 

mechanical methods (mowing/string 

trimming).

Same as Alternative 

1, with the addition 

of mechanical 

methods 

(mowing/string 

trimming).

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)

Selective, spot, broadcast Selective, spot, 

broadcast

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

Herbicide 

Application

Acreage 

Limitations

None

5,000 per year, 13,500 new acres 

detected under EDRR, 18% of the area 

within 150 feet of a stream annually

Same as Alternative 

2 

EDRR Approach

Annual pre-season list for 

treatment of new invaders. 

Treatments may only 

occur on 1) high priority 

sites and 2) only after 

soliciting comments from 

interested parties, 

agencies and tribes.

Develop site prescriptions and address 

any resources of concern. Follow 

herbicide use decision criteria to 

determine preferred method. Integrate 

MR/MM (including coordination and 

notification requirements) into

implementation prescription. Treat as 

soon as possible after finding new sites. 

Treatments would not be limited to those 

identified in a pre-season report. Consult 

and report as agreed through tribal 

consultation and ESA Section 7 

consultation.

Same as Alternative 

2 

54 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Table 15. Comparison of the Management Requirements and Mitigation Measures currently approved under 

the no action and action alternatives

No Action (2005 EA) Action Alternatives

General

1. In treating any/all infestations, all applicable 

management requirements and practices, included in the 

Forest Plan Prevention Strategy, Best Management 

Practices (BMPs) for invasive plants will be followed.

Forest-wide prevention measures (BMPs) have been 

developed and would be followed regardless of 

alternative selected. 

2. In particular, after working in invasive plant sites, all 

tools, equipment, and gear must be cleaned (power wash 

or high pressure spraying) before leaving the area, in 

order to avoid spreading the infestation further (Forest 

Plan, BMPs). 

This measure is included in the action alternatives. 

3. All invasive species management must be coordinated 

with all other site or area resources objectives. This measure is replaced by specific coordination 

requirements in the MR/MM for the action alternatives. 

4. Biocontrol treatments will use only those control 

agents that have been approved by the U.S. Department 

of Agriculture Animal and Health Inspection Service and

permitted by the State of Washington.

This measure is Standard 14 from the R6 2005 ROD and 

would be followed regardless of alternative selected. 

5. Any mulch used must be approved as invasive plant 

free, meeting the Forest Plan, Forest-wide Standards 

and Guidelines, Prevention Strategy and BMPs.

This measure is Standard 3 from the R6 2005 ROD and 

would be followed regardless of alternative selected. 

General Herbicide Use

6. No broadcast spraying (aerial or boom) will occur. 

The 2008 Skiyou Island DN approved broadcasting for 

that one area. Both action alternatives would approve 

additional broadcasting where needed, according to 

MR/MM and herbicide use buffers.

7. Any preparation, transport, or application of herbicide 

will be done by trained workers with a current 

Washington State pesticide applicators license.

All alternatives follow the R6 2005 ROD Standard 15 that 

requires that people who apply herbicides be licensed or 

directly supervised by a licensed applicator. 

8. Only the aquatic formulation of glyphosate will be 

used, and at the lowest effective rate as per 

manufacturer label specifications, which is estimated to 

be 2 1⁄2 to 5 percent solution of the aquatic formulation of 

glyphosate diluted in water (3 ounces manufacturer’s 

concentrate per gallon of water). Refer to Mitigation 

Measure #19, below, for application via stem injection. 

This measure is not carried forward into the action 

alternatives. The lowest effective rate would be used 

based on the label and invasive plant being treated.

Maximum rates for foliar application for the herbicides 

proposed in Alternative 2 are shown in Table 20 in 

chapter 3.1. Alternative 3 would use the same rates (but 

does not include aminopyralid). 

9. If needed, the only surfactant that will be used is AgriDex®.

This measure is not carried forward into action 

alternatives. Action alternatives would allow for surfactant 

use that follows R6 2005 ROD Standard 18. See 

Appendix E for more information on surfactant. No NPEbased or POEA surfactants would be used. For herbicide 

applications within 100 feet of streams and other water

bodies, surfactants approved by the Dept. of Ecology for 

use in aquatic environments would be required. 

10. Pretreatment briefings will 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. 

This measure is specifically included in the action 

alternatives.

55 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

No Action (2005 EA) Action Alternatives

Herbicide and Surfactant Transport, Mixing, Use

11. Materials Safety Data Sheets, and Forest Service 

Information covering glyphosate and Agri-Dex® must be 

carried in each vehicle at all treatment times, and made 

available to interested members of the public, on-site.

These measures have been replaced with the following 

Herbicide Transportation and Handling Safety/Spill 

Prevention and Containment measures in the action 

alternatives. 

ü 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 Estimate and limit the daily quantity of 

herbicides to be transported to treatment sites.

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 will carry only enough herbicide daily to 

cover the proposed treatment for that day.

12. Glyphosate and Agri-Dex® containers must be 

secured and prevented from tipping during transport.

13. Workers will carry only enough herbicide daily to 

cover the proposed treatment for that day.

14. Mix only the amount of solution needed to complete 

daily treatments.

15. Workers will follow all herbicide label guidelines.

16. Containment mats will be used during mixing, to 

further avoid the risk of a spill.

17. Do not mix glyphosate or glyphosate with Agri-Dex® 

within 300 feet of riparian areas, wetlands, or surface 

water.

18. When glyphosate (with Agri-Dex®) is administered 

via wand-backpack spray, hand wiped, or painted on cut 

stems, the applicator will use the lowest effective rate. 

All alternatives would require use of the lowest effective 

rate of any herbicide used in a given situation. Maximum 

application rates per acre for the 10 herbicides proposed 

in Alternative 2 are shown in Table 20. 

20. Stem injection method would only be used on very 

small, high-priority infestations with difficult access.

This measure is not carried forward into the action 

alternatives. However, stem injection could be used 

where cost-effective. 

21. No applications using wand-backpack spray will 

occur when wind speed exceeds five miles per hour, to 

lessen drift, or when precipitation is expected within 24 

hours.

This measure is part of the action alternatives for 

broadcast herbicide application methods. Drift is not 

anticipated for spot applications. No herbicide 

applications would occur if there is a greater than 80 

percent change of precipitation within 24 hours. 

22. No hand wiping of leaves with the aquatic formulation 

of glyphosate with Agri-Dex® will be done when 

precipitation is expected within 24 hours.

No herbicide applications would occur if there is a greater 

than 80 percent change of precipitation within 24 hours. 

56 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

No Action (2005 EA) Action Alternatives

23. Application will occur only outside of timing 

constraints for wildlife, and when the chance of rain after 

application is very low.

This measure has been replaced by specific wildlife 

MR/MM in the action alternatives. 

24. Herbicide mixture (aquatic formulation of glyphosate 

with or without Agri-Dex®) will be colored with a bright, 

non-toxic vegetable dye before application. This will (a) 

minimize the possibility of accidentally applying herbicide 

to non-target species; (b) minimize the amount of 

herbicide used, by avoiding re-application 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.

In the action alternatives, herbicide mixtures will be 

colored with a bright, non-toxic vegetable dye before 

application. 

Soils/Water/Fisheries

25. Soil disturbance (from hand digging, grubbing, 

pulling, etc.) will be minimized to the extent possible. 

Restoration of treated areas will follow the restoration 

treatment proposed for each site.

This measure is not part of the action alternatives; 

however restoration is part of the action alternatives (see 

Chapter 2.4.4). Mitigation for soil disturbance near 

streams is included. 

26. As noted above [measure 17], all herbicide spray 

mixtures (aquatic formulation of glyphosate with or 

without Agri-Dex®) would not be prepared within 300 feet 

of riparian areas, wetlands, or surface water.

For the action alternatives, no herbicide mixing would 

occur within 300 feet of streams. 

27. Containment mats will be used during mixing to 

further avoid the risk of a spill.

For the action alternatives, an impervious material would 

be placed beneath mixing areas in such a manner as to 

contain small spills associated with mixing/refilling.

28. Any mulch used must be approved as invasive plant 

free, meeting the Forest Plan, Forest-wide Standards 

and Guidelines, Prevention Strategy and BMPs.

This measure is included in the action alternatives as per 

R6 2005 ROD standard 3. 

Wildlife

29. From January 1 through August 15, restrict all 

treatment activity in known or suspected bald eagle nest 

territories.

These measures have been replaced in their entirety in 

the action alternatives. 

30. Baker River Inlet to Baker Lake, Site 106: from 

November 1 through March 31, restrict all treatment 

activity near known, occupied eagle roost sites or key 

eagle foraging areas.

31. From March 1 through July 15, restrict activities 

generating noise above ambient levels within 35 yards of 

suitable spotted owl nesting habitat.

32. From April 1 through August 5, restrict activities 

generating noise above ambient levels within 35 yards of 

suitable marbled murrelet nesting habitat. 

33. For infestation treatments located within or adjacent 

to suitable nesting habitat for murrelets, leaving of any 

garbage or trash in the area is prohibited.

Vegetation, Plants

34. MBS Botanists will consistently provide training to 

contractors, state-wide, to educate them on accurate 

identification of invasive plants, so that only target 

species are treated and other desirable species are left 

unharmed.

These measures have been replaced in their entirety in 

the action alternatives.

57 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

No Action (2005 EA) Action Alternatives

35. If any previously undiscovered rare plants are found 

within the project area, work will be halted until the USFS 

botanist is consulted and necessary mitigation measures 

are enacted.

Heritage Resources

36. An information packet will be provided to all 

personnel involved in the invasive plant treatment prior to 

project implementation. The packet will contain 

information on heritage resource identification (such as 

railroad grades, how to identify prehistoric artifacts, etc.) 

and instructions for any historic or prehistoric resources 

that may be found.

These measures have been replaced in their entirety in 

the action alternatives.

37. If a previously unidentified resource is discovered 

during project implementation—under any treatment 

method—or if at any time a resource that may be eligible 

for the National Historic

Register of Historic Places is affected, in an unanticipated way, reasonable steps will be taken to avoid 

or minimize harm to the resource until the Forest Service 

can fulfill its consultation requirements in accordance 

with the Programmatic Agreement for Heritage 

Resources (1997; see project files).

Recreation, Public Use

38. For any site with where recreation use/activity is high 

and invasive plant infestations are located other than 

along the peripheral (such as edges of parking lots, along 

road shoulders, etcetera), any treatment using the 

aquatic formulation of glyphosate (with or without AgriDex®) will occur only during the week, and not on 

weekends or 3-day holiday weekends. Sites will be 

signed and flagged, as noted above. These measures have been replaced in their entirety in 

39. The only two examples among the 91 specific sites the action alternatives.

proposed for treatment are Gold Creek Pond (polygon # 

48) and Buck Creek Camp (polygon # 148). While Buck 

Creek Camp is not operating for the 2005 season (camp 

is for sale), any treatment using the aquatic formulation 

of glyphosate (with or without Agri-Dex®) will be 

contingent upon scheduling with the Camp management, 

and/or the care-taker.

Worker and Public Health and Safety

40. All workers will comply with Occupational Health and 

Safety Administration (OSHA) standards, Forest Service 

Health and Safety Code Handbook, and other guidelines, 

BMPs, and manufacturers’ recommendations to reduce 

the risk of injury to workers.

This measure is required as a matter of Forest Service 

policy and would be followed regardless of alternative 

selected.

58 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Table 16. New Invader (EDRR) Approach

No Action Action Alternatives

Based on the previous year’s surveys, new invasive plant 

infestations would be documented [using the forms in 

Appendix D of the 2005 EA]. 

Invasive plant sites and treatment plans would be mapped 

according to Forest Service policy. Data bases such as NRIS 

and FACTS are used to track invasive plant populations and 

treatments.

New infestation sites would be prioritized. No change. Priority would be determined in cooperation with 

implementation partners. 

The current “set” of high-priority sites would be included in 

each year’s prioritization, which could result in a newlydiscovered site being ranked as a higher priority for 

treatment. 

New and known sites would be treated according to priority, 

with some exceptions, for instance, if a medium or lowerpriority infestation can be treated as part of another planned 

project, or as part of a suite of restoration projects within a 

watershed. 

Once a new site is ranked as a high priority, an initial 

proposed treatment and restoration plan would be selected, 

based on the type of invasive plant, size of infestation, and 

location. Tools to make this assessment would include, but 

not be limited to: the biology of each invasive plant species 

and their control history [Appendix C of the 2005 MBS EA]; 

and MBS specific experience with treating invasive species 

[Appendix B, of the 2005 MBS EA]. The only treatment 

methods available for selection would be those included in 

the [2005 MBS] EA, along with all Management 

Requirements and Mitigation Measures. 

The implementation planning process includes developing 

integrated treatment prescriptions according to MR/MM 

based on a comprehensive list of site considerations. This 

project does not include herbicide application directly to 

water, aerial application of herbicides, use of any pesticides 

other than herbicides, treatment of aquatic invasive plants 

(floating and submerged), treatment of native plants, and 

changes in land uses to slow or prevent the spread of 

invasive plants. Otherwise, treatments according to all of the 

design features (MR/MM, herbicide use buffers, treatment 

caps), would be considered in the scope of the action 

alternatives. 

A new annual newsletter would be produced each spring, 

listing the new sites. It would be mailed to all interested 

parties, including agencies (such as U.S. Fish and Wildlife 

Service (USFWS), and NOAA Fisheries), Tribes, and 

others. Comments would be solicited.

No annual newsletter required. Notification would occur as 

per the MR/MM. Consultation with tribes and ESA regulatory 

agencies would occur as agreed. 

For each new, high-priority site: the effects on other 

resources from treatment/restoration would be estimated. 

This information would be included in the newsletter.

No additional effects analysis is required for treatments within 

the scope of the action alternatives. Treatments according to 

all of the design features (MR/MM, herbicide use buffers, 

treatment caps), would be considered in the scope of the 

action alternatives. 

If the effects are found to be within the scope of this EA, 

and USFWS and NOAA Fisheries concur through informal 

Section 7 (ESA) consultation, sites would be added as 

addenda.

Report as agreed as a result of Section 7 Consultation.

All treatments would be accomplished as funding is 

available. No change. 

59 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Table 17. Comparison of the alternatives based on 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 new detections

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)

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 nonselective 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

Low risk of herbicide exposure 

to wildlife. The effects analysis 

assumes that an animal is 

directly sprayed, consumes an 

entire days’ diet of 

Same as Alternative 1 Same as Alternative 1

60 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2

Issue and Indicator Alternative 1 Alternative 2 Alternative 3

contaminated food, or drinks 

contaminated water for an 

entire day. These scenarios 

far overestimate actual 

exposure levels. The 

management requirements 

and mitigation measures 

would further reduce the 

potential impacts on wildlife.

18

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 nonlethal 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

18 This section was edited for clarity between the draft and final EIS.

61 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 2 

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62 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Chapter 3. Affected Environment and Environmental 

Consequences

3.1 Introduction 

Chapter 3 of this EIS summarizes the environments of the affected project area (existing conditions) and 

the potential changes to those environments due to implementation of the alternatives discussed in 

Chapter 2 (environmental consequences). It also presents the scientific and analytical basis for the 

comparison of alternatives presented. For ease in presentation and comparison, the analysis discussions 

are separated into individual resources areas.

This Environmental Impact Statement (EIS) incorporates by reference (as per 40 CFR 1502.21) the 

Project Record, including specialist reports and other technical documentation used to support our 

analysis and conclusions. The record documents our various public outreach efforts. Analysis was 

completed for treatment effectiveness, human health, botany, soils, water resources, fisheries, soils, 

wildlife, recreation and scenery and heritage resources. 

Biological Evaluations (BE) and Biological Assessments (BA) were also prepared in compliance with the 

requirements of Forest Service Manual (FSM) 2670, 2671, FSM W.O. Amendments 2600-95-7, and the 

Endangered Species Act (ESA of 1973, as amended. A Biological Assessment (BA) has been prepared in 

compliance with the requirements of Forest Service Manual (FSM) 2630.3, FSM 2672.4 and the 

Endangered Species Act of 1973 (Subpart B: 402.12, Section 7 Consultation, as amended) on actions and 

programs authorized, funded, or carried out by the Forest Service to assess their potential for effect on 

threatened and endangered species, and species proposed for federal listing (FSM 2670.1). The biological 

evaluations are in the Project Record and summarized in Chapter 3. 

3.1.1 Treatment Analysis Areas 

Known infestations were divided into larger geographic area known as a Treatment Analysis Area (TAA). 

This is the area where the known infestation is most likely to spread in the next 5 to 10 years if the 

original site is left untreated. Each TAA is within a single 5th field watershed and contain one or several 

invasive plant sites. 

The Interdisciplinary Team developed the Management Requirements and Mitigation Measures 

(MR/MM) and described the Affected Environment based on the range of conditions within the TAAs. 

Figure 2 shows the location of the TAAs. Maps and information about the infested areas within the TAAs 

is available on line at http://www.fs.fed.us/nepa/nepa_project_exp.php?project=34208. Appendix A 

provides an example of maps and information associated with the TAAs in the Project Record (and 

available on line). 

Table 18 shows the infested acreage and number of sites estimated to currently grow within each 

treatment analysis area (TAA). Please note that these estimates provide a snapshot of the inventory 

prepared in 2012. This inventory is based on a variety of sources and not all sites have been validated by 

an invasive plant specialist. Validation by an invasive plant specialist would occur before treatment of any 

site. Invasive plants sites are subject to rapid change and may become larger or smaller during the 

analysis and implementation periods. Additional invasive plant sites that have not been inventoried or

mapped are expected to occur within and outside the treatment analysis areas. 

63 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Figure 2. Treatment Analysis Areas Locator Map

64 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Table 18. Infested Acres, Number of Sites and Target species within Treatment Analysis Areas 

Treatment 

Analysis Area

Number

Treatment Analysis Area Name Infested 

Acres

Number 

of Sites Target species

01 Evans Creek 2.9 2 Tansy ragwort

02 W. Fork White River 102.5 119

Bull thistle

Canada thistle

Common groundsel

Common hawkweed

Common tansy

Cutleaf blackberry

Diffuse knapweed

Herb Robert

Himalayan blackberry

Meadow knapweed

Scotch broom

Spotted knapweed

Tansy ragwort

03 Greenwater River 518.4 104

Bull thistle

Canada thistle

Common groundsel

Common hawkweed

Common tansy

Diffuse knapweed

Herb Robert

Scotch broom

Smooth hawkweed

Spotted knapweed

Tansy ragwort

Wild carrot

04 The Dalles 697.5 74

Bird's foot trefoil

Bohemian knotweed

Bull thistle

Canada thistle

Common hawkweed

Hairy cat's ear

Herb Robert

Oxeye daisy

Scotch broom

Spotted knapweed

St Johnswort

Tansy ragwort

05 Ranger Creek 0.4 7 

Bull thistle

Common groundsel

European lily of the valley

Scotch broom

Tansy ragwort

06 Crystal Mountain Blvd 3.0 1 Tansy ragwort

07 Sunday Creek 11.2 6 

Sulphur cinquefoil

Spotted knapweed

Tansy ragwort

08 Road 52 6.2 3 

Canada thistle

Spotted knapweed

Tansy ragwort

65 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Treatment 

Analysis Area

Number

Treatment Analysis Area Name Infested 

Acres

Number 

of Sites Target species

1019 I-90 Corridor Kittitas County 0.1 1 Dalmatian toadflax

11 I-90 Corridor King County 114.2 49

Absinth wormwood

Bohemian knotweed

Common hawkweed

Dalmatian toadflax

Herb Robert

Meadow hawkweed

Meadow knapweed

Orange hawkweed

Scotch broom

Spotted knapweed

Sulphur cinquefoil

Tansy ragwort

Woolly hedgenettle

Yellow archangel

12 Middle Fork Snoqualmie River 119.5 34

Butterfly bush

Common comfrey

Common periwinkle

Common tansy

Field bindweed

Hedge false bindweed

Herb Robert

Rhubarb

Scotch broom

Tansy ragwort

13 Bessemer Road System 0.1 2 Bohemian knotweed

14 Snoqualmie Point 95.2 5 

Butterfly bush

Cutleaf blackberry

Himalayan blackberry

Scotch broom

Tansy ragwort

15 Martin Creek-Tye River 45.0 17

Bohemian knotweed

Bull thistle

Common tansy

Dalmatian toadflax

Giant hogweed

Herb Robert

Orange hawkweed

Tansy ragwort

Yellow hawkweed

16 Lower Beckler River 161.1 49

Bohemian knotweed

Bull thistle

Canada thistle

Common hawkweed

Herb Robert

Himalayan blackberry

Japanese knotweed

19 In the 2012 scoping package, Treatment Analysis Area 10 contained approximately 160 acres on the OkanoganWenatchee National Forest that are administered by the Mt. Baker-Snoqualmie National Forest. These acres were 

dropped from consideration in this EIS because they are in the Yakima Watershed and would have required a 

separate Endangered Species Act consultation (a small portion of the TAA remains). Treatment Analysis Area 09 

contained 35 acres in the Yakima River Watershed that were also dropped from consideration. Planning for these 

areas will be completed on the Okanogan-Wenatchee National Forest. 

66 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Treatment 

Analysis Area

Number

Treatment Analysis Area Name Infested 

Acres

Number 

of Sites Target species

Orange hawkweed

Scotch broom

Spotted knapweed

Sulphur cinquefoil

Tall hawkweed

Tansy ragwort

Wild carrot

Yellow hawkweed

17 Upper Beckler River 9.2 26

Bull thistle

Canada thistle

Common tansy

Himalayan blackberry

Orange hawkweed

Scotch broom

Sulphur cinquefoil

Yellow hawkweed

18 Rapid River 0.5 2 Herb Robert

Orange hawkweed

191 North Fork Skykomish River 42.2 18

Bird's foot trefoil

Bohemian knotweed

Bull thistle

Common hawkweed

Common tansy

Diffuse knapweed

Hairy cat's ear

Herb Robert

Orange hawkweed

Oxeye daisy

Spotted hawkweed

Yellow hawkweed

20 Highway 2 Corridor & Miller River 291.9 53

Bohemian knotweed

Butterfly bush

Canada thistle

Dalmatian toadflax

English holly

English ivy

Giant knotweed

Herb Robert

Jewelweed

Orange hawkweed

Scotch broom

Smooth hawkweed

Tansy ragwort

Yellow archangel

Yellow hawkweed

21 Money Creek 26.2 5 

Bohemian knotweed

Butterfly bush

Herb Robert

22 Sultan River 1.5 13 

Bull thistle

Canada thistle

Cutleaf blackberry

Herb Robert

Himalayan blackberry

Oxeye daisy

Reed canarygrass

Scotch broom

67 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Treatment 

Analysis Area

Number

Treatment Analysis Area Name Infested 

Acres

Number 

of Sites Target species

23 South Fork Stillaguamish River 441.8 31

Bohemian knotweed 

Common hawkweed

Common periwinkle

Herb Robert

Meadow hawkweed

Orange hawkweed

Policeman's helmet

Yellow archangel

24 Fall Creek 326.8 5 

Bohemian knotweed

Japanese knotweed

Scotch broom

Spotted knapweed

Tansy ragwort

25 Sauk-Whitechuck Confluence 0.1 1 Bohemian knotweed

26 White Chuck River Road 23 3.2 5 

Herb Robert

Orange hawkweed

Tansy ragwort

27 Darrington South 351.8 7 

Bohemian knotweed

Herb Robert

Japanese knotweed

Orange hawkweed

28 Squire Creek 0.1 1 Bohemian knotweed

29 Sauk Prairie 19.7 21

Bohemian knotweed

Canada thistle

Cutleaf blackberry

Hedge false bindweed

Herb Robert

Orange hawkweed

Scotch broom

Sulphur cinquefoil

Tansy ragwort

Yellow archangel

30 Dan Creek 6.4 19

Bull thistle

Canada thistle

Herb Robert

Meadow hawkweed

Orange hawkweed

Tansy ragwort

31 Prairie Mountain 3.3 14

Canada thistle

Herb Robert

Meadow hawkweed

Orange hawkweed

Tansy ragwort

32 Circle Creek-Suiattle River 273.1 18

Canada thistle

Common burdock

Common tansy

Herb Robert

Orange hawkweed

Scotch broom

Sulphur cinquefoil

33 Big Creek-Tenas Creek 125.5 28

Canada thistle

Common tansy

Herb Robert

Meadow hawkweed

Orange hawkweed

Scotch broom

Sulphur cinquefoil

68 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Treatment 

Analysis Area

Number

Treatment Analysis Area Name Infested 

Acres

Number 

of Sites Target species

Tansy ragwort

Yellow hawkweed

34 Segelsen Pass Road 18 71.7 12

Bull thistle

Common hawkweed

Meadow hawkweed

Orange hawkweed

Scotch broom

Spotted knapweed

Yellow hawkweed

36 Sedro Woolley 364.0 25

Bittersweet nightshade

Bohemian knotweed

Butterfly bush

Canada thistle

Common burdock

Common periwinkle

Common tansy

Common teasel

English holly

Herb Robert

Himalayan blackberry

Poison hemlock

Reed canarygrass

Scotch broom

Tansy ragwort

Yellow hawkweed

37 Crevice Creek 0.1 1 Yellow hawkweed

38 Finney Creek 132.7 8 

Butterfly bush

Herb Robert

Meadow hawkweed

Yellow hawkweed

39 South of Rockport 16.7 5 

Bull thistle

Canada thistle

Common comfrey

Cutleaf blackberry

Yellow flag iris

40 Concrete to Rockport 65.1 16

Bohemian knotweed

Bull thistle

Butterfly bush

Canada thistle

Common tansy

Herb Robert

Himalayan blackberry

Meadow hawkweed

Orange hawkweed

Tansy ragwort

41 Suiattle Mountain 0.1 3 

Bull thistle

Canada thistle

Orange hawkweed

43 Baker Lake 8.9 62

Black locust

Bohemian knotweed

Bull thistle

Butterfly bush

Canada thistle

Common tansy

English ivy

Giant knotweed

Hawkweed non-native

Herb Robert

69 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Treatment 

Analysis Area

Number

Treatment Analysis Area Name Infested 

Acres

Number 

of Sites Target species

Japanese knotweed

Reed canarygrass

Scotch broom

Spotted knapweed

Sulphur cinquefoil

Tansy ragwort

Wild carrot

44 Glacier Creek Rd 39 1.1 1 Canada thistle

45 Mt. Baker Highway 542 231.3 32

Bohemian knotweed

Bull thistle

Common comfrey

Common periwinkle

Elephant ear

English ivy

Hedge false bindweed

Herb Robert

Himalayan blackberry

Meadow hawkweed

Orange hawkweed

Spotted knapweed

Tansy ragwort

Wild carrot

Yellow archangel

46 Canyon Creek 1.6 2 Canada thistle

Orange hawkweed

47 Monte Cristo Townsite 0.1 1 Common hawkweed

48 South of Dan Creek 0.4 7 

English holly

Herb Robert

Orange hawkweed

49 Tonga Ridge 111.4 4 

Herb Robert

Spotted knapweed

Yellow hawkweed

50 North Bend compound 56.5 2 Bohemian knotweed

Orange hawkweed

51 Diobsud Creek 8.9 9 

Bohemian knotweed

Canada thistle

Common tansy

Himalayan blackberry

Scotch broom

52 Marblemount Boat Launch 7.3 5 

Bohemian knotweed

Canada thistle

Common tansy

Hedge false bindweed

Scotch broom

53 Sulphur Creek 0.2 1 Herb Robert

5420 Johnson Ridge 0.0 0 scotch broom and others likely

Total Acres 4,878 936 

20 Treatment Analysis Area (TAA) 54 was thought to contain 113 acres of oxeye daisy, which was included in the 

2012 scoping package. This was later determined to be a misidentification; no oxeye daisy is growing in the 

Scorpion Mountain meadow. However, scotch broom was seen on a trail (old road) within TAA 54. 

70 

 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

3.1.2 Site Characterization

Each invasive plant infestation lies within one or more site types. The number of sites and acreage of 

invasive plants that are currently mapped within each site type is shown in Table 19. Approximately 44 

percent of the total infested acreage occurs on road shoulders, 25 percent of the infested acreage lies along 

stream banks, and 18 percent of the infested acreage is within or adjacent to plantations. The remaining 

acreage is a mix of forest land, wilderness, dispersed and developed recreation sites, administrative sites 

and other areas. 

Table 19. Acreage and Number of Known Sites by Site Type

Type of Site Number of Sites Acreage

Administrative 25 60.4

Developed recreation 68 337.8

Dispersed recreation 6 50.6

Forested 278 332.6

Lake shore 15 1.7

Pasture/open space 50 481.6

Plantation 20 904.9

Powerline 3 12.0

Recreation residence 8 0.3

Road shoulder 435 2,212.2

Rockpit/stockpile 48 61.3

Ski slope 1 0.2

Stream bank 53 1255.3

Wilderness 6 4.0

3.1.3 Treatment Assumptions and Scenarios 

The analysis in this chapter of the EIS is based on the assumption that none of the treatments would be 

considered 100 percent effective immediately after the initial entry. While initial entries in year 1 are 

estimated to eliminate 80 – 95 percent of the invasive plants at a site, maintenance entries would be 

required over subsequent years. 

The following assumptions are relevant to the analysis in Chapter 3.

In most cases, herbicide treatment would precede manual or non-herbicide because the nonherbicide treatments will be most effective when populations have been substantially reduced 

through the use of herbicides. In some cases, manual and mechanical treatments would occur in 

advance of herbicide treatments. 

The most ambitious treatment scenario for analysis purposes would be for all sites to have an 

initial treatment in the first year. The benefits and adverse impacts of treatment are likely to be less 

than predicted for the most ambitious scenario because funding and other constraints would limit 

the amount treated in any 1 year.

Broadcast application refers to foliar application on dense (greater than 70 percent coverage) 

invasive plant populations. Spot/selective herbicide application means that backpack and hand 

equipment would be used to treat foliage or stems (e.g. cut stump, injection). Spot and selective 

treatments would generally occur where invasive plants cover less than 70 percent of a given acre. 

71 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Spills are unlikely to occur and would be of small scale. Management Requirements/Mitigation 

Measure (MR/MM) 8 outlines the requirements of a spill reduction plan. The type of spills 

modeled in the risk assessments for the upper bound hazard quotient estimates (i.e. 200 gallons of 

herbicide mix spilling into a small pond) are not possible. No reportable spills have occurred on 

similar projects in Region Six (Desser 2013).

This project would be implemented over the next 5 to 15 years, as funding allows, or until conditions 

have changed sufficiently to warrant this EIS outdated. No more than 5,000 acres annually, or 13,500 

acres of new detections found over the life of the project, would be treated with herbicide. Site-specific 

conditions are expected to change within the life of the project: treated infestations would be reduced in 

size, untreated infestations would continue to spread, and/or new invasive plants could become 

established within the project area.

3.1.4 Climate Change and Invasive Plants

Global climate change is predicted to alter precipitation and seasonal temperature patterns, as a result of 

increased levels of atmospheric carbon dioxide (CO2) and other factors (Mote 2004). Most recent studies 

on the interaction between climate change and invasive plants conclude that climate change is likely to 

favor invasive plant species to the detriment of native plant species for individual ecosystems (Chornesky 

et al. 2005, Climate Change Science Program 2008, Dukes and Mooney 1999, Hellmann et al. 2008, Pyke 

et al. 2008). In some studies, invasive plant species have demonstrated increased growth rates, size, seed 

production, and carbon content in the presence of elevated CO2 levels (Rogers et al. 2008, Rogers et al. 

2005, Smith et al. 2000, Ziska 2003). Warming climates may remove elevation barriers to invasive plant 

distribution that currently exist. For instance, cheatgrass is becoming established in dry forests in the 

Intermountain West, particularly after wildfires and fuels reduction projects. After these events, native 

perennial grasses are lost, leaving potential cheatgrass habitat, which can increase fire frequency (Tausch 

2008). 

Many invasive plants are species that can thrive in the presence of disturbance and other environmental 

stressors, have broad climatic tolerances, large geographic ranges, and possess other characteristics that 

facilitate rapid range shifts. In a simulation experiment, Kremer et al. (1996) found that a less productive, 

invasive grass community would tolerate climate change, whereas a native sagebrush community would 

not survive the increased temperatures. The predicted changes in climate are thought to contribute 

additional stressors on ecosystems, including those on National Forests, making them more susceptible to 

invasion and establishment of invasive plant species (Joyce et al. 2008). 

Climate change may affect invasive species differently. Bradley et al. (2009) found that rather than simply 

enhancing invasion risk, climate change may also reduce invasive plant competitiveness if conditions 

become climatically unsuitable. Climate change could result in both range expansion and contraction for 

some invasive plants in the western United States (potentially introducing invasive species that thrive in 

warmer conditions). Likely future conditions may also make management of invasive species more 

difficult. Treatments used on invasive plants may be less effective under various climate change scenarios 

and/or elevated CO2 (Hellmann et al. 2008, Pyke et al. 2008, Ziska, Faulkner, and Lydon 2004). 

Predicting how climate change will affect invasive plants, and invasive plant management, at the local or 

even regional scale is more difficult to deduce than are these general indications. Anticipated changes in 

the climate for the Pacific Northwest (e.g. more rain, less snow, warmer temperatures) (Mote 2004, Mote 

et al. 1999, National Assessment Synthesis Team 2000) or elevated CO2 may not be realized at a local 

area, particularly within the time frame of this analysis. Growth of invasive plants under elevated CO2

conditions will also be influenced by environmental conditions such as soil moisture, nutrient availability, 

and the plant community in which the invasive species occurs (Cipollini, Drake and Whigham 1993; 

72 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Curtis, Drake, and Whigham 1989; Dukes and Mooney 1999; Johnson et al. 1993; Taylor and Potvin 

1997). The complex interaction of multiple and uncertain variables make site-specific predictions 

speculative. 

Current science is insufficient to precisely determine a cause and effect relationship between climate 

change and the Proposed Action for the project area. A general conclusion, based on the preponderance of 

current literature, suggests that “most of the important elements of global change are likely to increase the 

prevalence of biological invaders” (Dukes and Mooney 1999, Bradley et al. 2010). The MBS will likely 

become more vulnerable to the establishment of invasive plant infestations, actual acreage affected by 

invasive plants could increase, and control strategies may become more difficult. Recommended 

management responses to these predictions are early detection (resulting from regularly scheduled 

monitoring) followed by a rapid response to eradicate initial infestations (Hellmann et al. 2008, Joyce et 

al. 2008, Tausch 2008). 

Many of the invasive species on the MBS have originated in Eurasia and tend to thrive in warm sunny 

microsites (e.g. species in the sunflower family, Asteracea). Conversely most of the TES or S&M species 

on the MBS prefer cold, wet sites, are more common in Alaska and are either disjunct or at the southern 

extent of their range on the Mt. Baker-Snoqualmie National Forest. 

Given that action alternatives include control of invasive plants with an early detection/rapid response 

component, and the large uncertainties regarding effects of climate change at any specific location over 

the time frame of this project, there is insufficient information to discern any meaningful differences 

between alternatives. All actions are consistent with recommendations for management response in the 

face of potential influences of climate change on invasive plants.

3.1.5 Introduction to Herbicide Toxicity Analysis

The effects from the use of any herbicide depends on the toxic properties (hazards) of that herbicide, the 

level of exposure to that herbicide at any given time, and the duration of that exposure. Risk assessments 

were completed by Syracuse Environmental Research Associates, Inc. (SERA) using peer-reviewed 

articles from the open scientific literature and current Environmental Protection Agency (EPA) 

documents, including Confidential Business Information to which SERA had clearance. Information from 

laboratory and field studies of herbicide toxicity, exposure, and environmental fate was used to 

characterize the risk of adverse effects to non-target organisms.

The risk assessments consider a variety of exposure scenarios including accidental exposures and 

application at maximum rates over relatively large areas. Although the risk assessments have limitations 

(see R6 2005 FEIS pages 3-95 through 3-97), they represent the best science available. “After 30 years of 

use and refinement, this risk-assessment paradigm has become scientifically credible, transparent, and 

consistent; can be reliably anticipated by all parties involved in decisions regarding pesticide use; and 

clearly articulates where scientific judgment is required and the bounds within which such judgment can 

be applied. The process is used for human-health and ecological risk assessments and is used broadly 

throughout the federal government. Thus, the committee concludes that the ... risk assessment ... process 

is singularly appropriate for evaluating risks posed to ecological receptors, such as listed species, by 

chemical stressors, such as pesticides” (NAS 2103). . 

The risk assessments provide a range of human health and ecological impact results including lower, 

central and upper estimates. The upper value in the range would generally correspond to a “worst-case” 

value unlikely to actually occur for this project. For instance, workers would have to be exposed to 

maximum rates over the course of an 8-hour day; 200 gallons of herbicide would have to be spilled into a 

pond for accidental drinking water exposure scenarios; a woman would have to eat a pound of 

73 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

contaminated fruit; an animal would have to feed on nothing but contaminated vegetation over the course 

of a day; a fish would be exposed to herbicide following 10 acres of broadcast spray at maximum rates 

directly adjacent to a small stream. The central estimates also include assumptions that are unlikely to 

actually occur given the MR/MM associated with this project and the scattered nature of invasive plant 

applications. 

Risk assessments have a high degree of uncertainty in interpretation and extrapolation of data. 

Uncertainty may result from a study design, questions asked (and questions avoided), data collection, data 

interpretation, and extreme variability associated with aggregate effects of natural and synthesized 

chemicals on organisms, including humans, and with ecological relationships. Due to data gaps, 

assessments rely heavily on extrapolation from laboratory animal tests (USFS 2005a). 

Regardless of disadvantages and limitations of ecological and human health risk assessments, risk 

assessments can determine (given a particular set of assumptions) whether there is a basis for asserting 

that a particular adverse effect is possible. The bottom line for all risk analyses is that absolute safety can 

never be proven and the absence of risk can never be guaranteed (SERA 2007). Limited information on 

surfactants, adjuvants, and inert ingredients is available in Bakke 2007 and various risk assessments. 

Since risk assessments have not been completed for most surfactants, adjuvants and inert ingredients, 

information regarding the toxicity and effects of these chemicals is largely unavailable. 

Herbicide risk assessments are available online at http://www.fs.fed.us/foresthealth/pesticide/risk.shtml

and herbicide labels are available at http://www.fs.fed.us/foresthealth/pesticide/labels.shtml. Table 20

displays the risk assessment references associated with each herbicide proposed for use, and the 

maximum amount that would be applied via broadcast, spot or selective foliar sprays to effectively treat 

target species found on the forest. Infrequently, a greater concentration of herbicide may be selectively 

applied as per label guidance for stump cut or stem injection methods. 

Table 20. Risk assessments for herbicides and surfactants considered in this EIS

Herbicide Date Final Risk Assessment 

Reference

Maximum Pounds active 

ingredient per acre per

year (for target species on 

the MBS)

Aminopyralid June 28, 2007 SERA TR-052-04-04a 0.09

Chlorsulfuron November 21, 2004 SERA TR 04-43-18-01c 0.09

Clopyralid December 5, 2004 SERA TR 04 43-17-03c 0.50 

Glyphosate March 25, 2011 SERA TR-052-22-03b 4.00

Imazapic December 23, 2004 SERA TR 04-43-17-04b 0.13

Imazapyr December 16, 2011 SERA TR-052-29-03a 1.25

Metsulfuron methyl December 9, 2004 SERA TR 04-43-17-01b 0.075

Picloram September 29, 2011 SERA TR-052-27-03a 1.00

Sulfometuron methyl December 14, 2004 SERA TR 03-43-17-02c 0.2

Triclopyr May 24, 2011 SERA TR 052-25-03a 2.00

Table 21 summarizes information about each of the herbicides proposed for use in one or more 

alternatives. 

74 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Table 21. Summary of Properties and Risks Associated with Herbicides Proposed for Use on the MBS

Active Ingredient

Selected Herbicide Brand Names and 

Mode of Action

Properties Risks

Aminopyralid 

(Milestone®

, Milestone VM®) 

Mimics Auxin Plant growth hormone

Selective for most broadleaf 

species. 

Post emergent herbicide.

Grasses are tolerant.

Potential to kill non-target broadleaf 

plants. Low risk to aquatic 

organisms. Milestone® formulations

contain no inert ingredients other 

than water and triisopropanolamine

(active ingredient in aminopyralid). 

Chlorsulfuron

(Telar®

, Glean®, Corsair®) 

Sulfonylurea-Interferes with enzyme 

acetolactate synthase with rapid 

cessation of cell division and plant 

growth in shoots and roots.

Glean -Selective pre-emergent or 

early post-emergent

Telar – Selective pre- and postemergent.

Both are for many annual, 

biennial and perennial broadleaf 

species.

Safe for most perennial grasses, 

conifers. Some soil residue.

Moderate risk to aquatic organisms.

Clopyralid

(Transline®

) 

Synthetic auxin -Mimics natural plant 

hormones.

A highly trans-located, selective 

herbicide active primarily through 

foliage of broadleaf species. Little 

effect on grasses.

Contains hexachlorobenzene 

(persistent carcinogen) in amounts 

below a threshold of concern; this 

chemical is ubiquitous in the 

environment.

Highly mobile, but does not degrade 

in water. Lower risk to aquatic 

organisms. 

Glyphosate

(35 formulations, including RoundUp®

, 

Rodeo®

, Accord XRT®, Aquamaster®, 

etc.)

Inhibits three amino acids and protein 

synthesis.

A broad spectrum, non-selective 

trans-located herbicide with no 

apparent soil activity.

Adheres to soil which lessens or 

retards leaching or uptake by 

non-targets.

Non-selective.

Greater risk to aquatic organisms.

Imazapic

(Plateau®

) 

Inhibits the plant enzyme acetolactate, 

which prevents protein synthase. 

Used for the control of some 

broadleaf plants and some 

grasses. 

More potential to kill non-target 

vegetation.

Lower risk to aquatic organisms.

Imazapyr

(Arsenal®

, Arsenal AC®, Chopper®, 

Stalker®

, Habitat®) 

Inhibits the plant enzyme acetolactate, 

which prevents protein synthesis.

Broad spectrum, non-selective 

pre- and post-emergent for 

annual and perennial grasses and 

broadleaved species.

More potential to kill non-target 

vegetation.

Moderate risk to aquatic organisms.

Human health hazard associated 

with higher label rates.

More mobile.

75 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Active Ingredient

Selected Herbicide Brand Names and 

Mode of Action

Properties Risks

Metsulfuron methyl

(Escort XP®

) 

Sulfonylurea -Inhibits acetolactate 

synthesis, protein synthesis inhibitor, 

and block formation of amino acids.

Used for the control of many 

broadleaf and woody species. 

Most susceptible crop species in 

the lily family (i.e. onions).

Safest sulfonylurea around nontarget grasses.

More potential to kill non-target 

vegetation.

Lower risk to aquatic organisms. 

Picloram

(Tordon K®

, Tordon 22K®) 

Restricted Use Herbicide

Synthetic auxin - Mimics natural plant 

hormones.

Selective, systemic for many 

annual and perennial broadleaf 

herbs and woody plants.

Most mobile, but persistent in soil.

Contains hexachlorobenzene 

(persistent carcinogen) in amounts 

below a threshold of concern; this 

chemical is ubiquitous in the 

environment.

More potential to kill non-target 

vegetation.

Greater risk to aquatic organisms.

Human health hazard associated 

with higher label rates.

Sulfometuron methyl

(Oust®

, Oust XP®) 

Sulfonylurea -Inhibits acetolactase 

synthase; a key step in branch chain 

amino acid synthesis.

Broad spectrum pre- and postemergent herbicide for both 

broadleaf species and grasses.

More potential to kill non-target 

vegetation.

Moderate risk to aquatic organisms.

Human health hazard associated 

with higher label rates.

Triclopyr

(Garlon 3A®

, Garlon 4®, Forestry Garlon 

4®

) 

Synthetic auxin - Mimics natural plant 

hormones.

A growth regulating selective, 

systemic herbicide for control of

woody and broadleaf perennial 

invasive plants.

Little or no impact on grasses. 

Greatest risk to aquatic organisms.

Exposure may exceed thresholds of 

concern for workers and the public.

3.1.5.1 Impurities, Metabolites, Inert Ingredients, and Adjuvants

Forest Service risk assessments also include evaluated studies of potential hazards of other substances 

associated with herbicide applications: impurities, metabolites, inert ingredients, and adjuvants such as 

food coloring dyes. There is usually less toxicity data available for these substances (compared to the 

herbicide active ingredient) because they are not subject to the extensive testing that is required for the 

herbicide active ingredients under FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act). 

Information on adjuvants and surfactants is tiered to the R6 2005 FEIS and incorporates updated 

information from Analysis of Issues Surrounding the Use of Spray Adjuvants with Herbicides (Bakke 

2002, 2007), and the Summary of Aquatic Acute Toxicity Data for Spray Adjuvants Allowed for Use on 

Aquatic Sites in Washington (WSDA 2009). The SERA risk assessments also include information about 

additives that are part of herbicide formulations. NPE-based surfactants would not be used for this 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

project, however alkylphenol ethoxylate ingredients may be used in oil and/or silicone blends. POEA 

surfactants would not be used.21

Many of the concerns expressed by the public about use of herbicides reflect hazards that could occur 

with chemical use or exposures that are beyond the scope of this project. This project tiers to the R6 2005 

FEIS and incorporates the most recent SERA Risk Assessment for toxicology information. Concerns 

about the registration process, about chemical use at higher rates or about different pesticide formulations 

cannot be addressed in this project level document. This document does not reconsider findings and 

decisions made in the R6 2005 FEIS and ROD, however, it does incorporate findings from updated risk 

assessments. Additional information about surfactants is in Appendix E. 

3.1.5.2 Herbicide Toxicology Terminology

The following terminology is used throughout this chapter to describe relative toxicity of herbicides 

proposed for use in the alternatives. 

Aquatic Label: Some herbicides are labeled by EPA for direct application in water. While no direct 

application would occur in any alternative for this project, aquatic formulations may be required by the 

label or the buffers described in Table 10. Aquatic labeled herbicide formulations have been more 

extensively tested and tend to be less hazardous to aquatic organisms than the same herbicide in terrestrial 

formulations). However, aquatic labeled herbicide formulations may pose greater risk to aquatic 

organisms than some other herbicides that do not have aquatic labels. For instance, aminopyralid poses 

less risk to fish than aquatic labeled glyphosate. 

Bioaccumulation: The increase in concentration of a substance in living organisms as they take in 

contaminated air, water, or food because the substance is very slowly metabolized or excreted (often 

concentrating in the body fat). 

Exposure Scenario: The mechanism (for example, by skin or ingestion) by which an organism (person, 

animal, fish) may be exposed to herbicides active ingredients or additives. The application rate and 

method influences the amount of herbicide to which an organism may be exposed. 

Threshold of Concern: A level of exposure below which there is a low potential for observable adverse 

effects to an organism. The No-observed-adverse-effect level (NOAEL) is the exposure level at which no 

statistically or biologically significant differences in the frequency or severity of any adverse effect in the 

exposed or control populations exists.22 When a hazard quotient is less than 1, risk is extremely low for 

any observable adverse effects due to the particular exposure scenario, and it is considered below the 

threshold of concern. Exposure scenarios are very conservative and therefore the risk characterization or 

threshold of concern is sufficiently protective. This level was further reduced in the R6 2005 FEIS to add 

a margin of safety to the risk assessment process for Threatened and Endangered species. Lower 

threatened and endangered species thresholds were applied to all wildlife, fish and other aquatic 

organisms.

21 POEA surfactant use was eliminated from the alternatives in response to public comments. This means that higher 

risk glyphosate formulations would not be used. 

22 The laboratory tests include organ/tissue examination/dissection, lethal and non-lethal effects (i.e., behavior 

changes and weight loss).

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Hazard Quotient (HQ): The Hazard Quotient (HQ) is the amount of herbicide or additives to which an 

organism may be exposed (dose) divided by the exposure threshold of concern (No Observable Adverse 

Effect Level – NOAEL). An HQ less than or equal to 1 indicates an extremely low level of risk. 

Lowest Observed Adverse Effect Level (LOAEL): The lowest dose of a chemical in a study, or group 

of studies, that produces statistically or biologically significant increases in frequency or severity of 

adverse effects between the exposed and control populations. 

No Observable Adverse Effect Level (NOAEL): Exposure level at which no statistically or biologically 

significant differences in the frequency or severity of any adverse effect in the exposed or control 

populations exists. 

No Observed Effect Concentration (NOEC): Synonymous with NOEL. 

No Observed Effect Level (NOEL): Exposure level at which there are no statistically or biologically 

significant differences in the frequency or severity of any effect in the exposed or control populations.

Reference Dose (RfD): The RfD is a numerical estimate of a daily exposure to the human population, 

including sensitive subgroups such as children, that is below a level thought to cause harmful effects 

during their lifetime. RfDs are generally used for health effects that are thought to have a threshold or 

minimum dose for producing effects. The reference dose is also referred to as the level of concern, 

threshold of concern, and toxicity index. All of these terms refer to the exposure level or “dose” below 

which adverse effects are unlikely to occur.

Risk Assessment Worksheet: A spreadsheet that provides lower, central and upper estimates of hazard 

quotients for public and worker health, different types of wildlife, and aquatic organisms, using projectspecific application rates and methods. 

3.1.5.3 Incomplete and Unavailable Information Related to Herbicides

Any project involving herbicide use in a natural setting will contain many sources of uncertainty. The 

range of invasive plant species to be managed is large and compounded by the number of non-target 

species and diversity of ecological conditions in areas where treatment may occur. Data on herbicide 

toxicity and environmental fate is limited to those conditions and species tested for registration purposes 

and investigated by independent researchers. Available data on surfactants, inert ingredients, and dyes is 

even more limited. It is not possible to obtain all the data necessary to substantially reduce this 

information gap. For example, the sheer number of species and single herbicide test combinations would 

be overwhelming. 

Each rigorous laboratory test conducted to determine the toxicity of a chemical to an animal is extremely 

expensive. If we add to this data required to more adequately address synergistic, additive, or antagonistic 

effects from chemical combinations, it is not possible to obtain all data that would be relevant to making a 

decision.

In addition, invasive and native plants, wildlife, soil and water bodies are dynamic resources that change 

locations and characteristics depending upon time, season, weather patterns, land use activities, random 

events, and other influences. This limits our ability to precisely predict effects (e.g. amount and duration 

of herbicide exposures, spread and impact of invasive plants, nature and amount of background 

contamination, etc.) even if more toxicity information was available. 

For risk assessments considering adjuvants, surfactants and inert ingredients in herbicide mixtures, the 

information within the risk assessment may not be complete. SERA (2007) discussed how the risk 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

assessments apply generally accepted scientific and regulatory methodologies to encompass these 

uncertainties in predictions of risk. SERA risk assessments identify and evaluate incomplete and 

unavailable information that is potentially relevant to human health and ecological risks. Each risk 

assessment identifies and evaluates missing information for that particular herbicide and its relevance to 

risk estimate. Such missing information may involve any of the three elements needed for risk 

assessments: hazard, exposure, or dose-response relationships. A peer-review panel of subject matter 

experts reviewed the assumptions, methodologies and analysis of significance of any such missing 

information. The SERA Risk Assessments incorporate the findings of this peer review. 

The Forest Service responds to this uncertainty by: 

1. Assuming adverse effects to organisms occur at doses well-below lethal levels

2. Using the best available models for predicting herbicide concentrations in water

3. Using worst case scenarios

4. Relying on widely used and accepted risk assessment methodology

5. Including MR/MM that restrict certain applications

6. Monitoring effects of higher risk treatments

Treatment Effectiveness

Each invasive plant treatment situation could respond differently to the integrated treatments proposed. 

The prescription for each site would vary depending on the MR/MM, buffers, first choice and other 

effective herbicides authorized for use, and other factors such as treatment history and objective. The 

differences in treatment effectiveness are based on assumptions about the range of treatments available. In 

addition, treatment costs vary depending on the integrated treatment methods, specific chemicals used and 

their application method, and the size and distribution of the various treatment sites. 

Human Health

Toxicity data is not obtained on humans directly, but rather extrapolated from laboratory animals using 

standardized tests required by EPA. Human susceptibility to toxic substances can vary substantially. In 

response to this uncertainty, standard risk assessment methodology assigns uncertainty factors to toxicity 

data to account for extrapolation from laboratory animals and for sensitive individuals. However, some 

individuals may be unusually sensitive so individual susceptibility to the herbicides proposed in this EIS 

cannot be predicted specifically. Factors affecting individual susceptibility include diet, age, heredity, preexisting diseases, and lifestyle. In response to this uncertainty, management requirements and mitigation 

measures are proposed to reduce the likelihood or amount of exposure. 

Botanical Resources

Data on the susceptibility of different non-target plant species and families to particular herbicides is 

conducted with agricultural crop species and not those that may better represent non-target plants in the 

forest environment. Specific locations of rare plants, as well as invasive plants, change from year to year, 

making it impossible to precisely predict risk from treatments. 

The current analysis uses the best available science on susceptibility, herbicide drift, and risk assessments 

to determine likely effects. Required management requirements and mitigation measures, monitoring, and 

practical information and expert opinion are utilized in response to uncertainty.

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Soil and Water Resources

Herbicide toxicity and fate varies with environmental variables such as pH, temperature, and presence or 

absence of organic matter. These variables fluctuate widely depending upon season, weather, disturbance, 

adjacent land uses, and other factors, making precise predictions of existing conditions and effects 

impossible. Data on effects to soil organisms is limited and may not reflect the actual community of 

organisms present at any given treatment site. 

In response to this uncertainty, the current analysis uses the best available scientific information on soil 

mapping, watershed analysis, water monitoring, and the best available predictive models for potential 

contamination and drift. In addition, management requirements and mitigation measures are applied to 

action alternatives to restrict herbicide ingredients, application method, and/or rate on certain soils and in 

proximity to water.

Terrestrial and Aquatic Organisms (Fish and Wildlife)

Research has not been conducted on the effects of these herbicides to most free-ranging wildlife species, 

so the relevant data to specifically evaluate effects to different wildlife species is incomplete or 

unavailable. Specifically: 

§ Information about herbicide effects to reptiles, amphibians and butterflies found in Region 

Six is limited.

§ Analysis of effects for any project involving herbicide use relies upon extrapolations from 

laboratory animals to free-ranging wildlife and controlled conditions to the natural 

environment. 

§ There are more data available for mammals than for birds, which require the use of mammal 

toxicity values in bird exposure scenarios for some of the herbicides considered in this FEIS.

§ Very few studies are available on sub-lethal effects to fish from acute exposures. Of studies 

that are available, some indicate temporary effects at low herbicide concentrations (e.g. 

Tierney et al. 2006). 

Better estimates of risk could be calculated if laboratory data on the toxicity of the herbicides considered 

in this EIS were available for more groups of animals and more individual species. We would have more 

information on the comparative sensitivities of different wildlife groups and the types of adverse effects 

that may occur in different species.

However, because of the dynamic nature of wildlife and their habitat (behavior, weather, nutrient 

availability, contaminant presence, etc.), significant uncertainties would remain for predicting short- and 

long-term reactions to herbicide presence in natural settings even if more laboratory data were available.

Limitations notwithstanding, there is substantial scientific data on the toxicity of these herbicides to birds 

and mammals, as well as amphibians and some invertebrates. The data is generated by manufacturers to 

meet EPA regulations before an herbicide may be registered for use, and by independent researchers that 

have published findings in peer-reviewed literature. This data is analyzed according to standard risk 

assessment methodology to reach a characterization of risk for each herbicide. The summary of the 

available scientific evidence and our evaluation of reasonably foreseeable impacts are detailed in the 

following sections. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

3.1.6 Introduction to the Cumulative Effects Analysis

3.1.6.1 Introduction

The Council on Environmental Quality (CEQ) regulations for the implementation of NEPA define 

cumulative effects as the “impact on the environment that results from the incremental impact of the 

action when added to other past, present, and reasonably foreseeable future actions...” 40 CFR 1508.7. 

Cumulative effects are discussed where there is an effect to the environment which results from the 

incremental effect of the action when added to other past, present, or reasonably foreseeable future 

actions (40 CFR 1508.7). As is discussed throughout Chapter 3, the risks of direct and indirect adverse 

impacts from this project are relatively small in any one location or time. The project covers a large 

geographical area and would occur over approximately 15 years. The specific location of invasive plant 

treatments and the timing and location of other activities in relation to invasive plant treatments are 

uncertain. 

This section is provided as a basis for cumulative effects analysis found in each individual resource 

section of Chapter 3. CEQ regulations do not require the consideration of the individual effects of all past 

actions to determine the present effects of past actions. Cataloging past actions and specific information 

about the direct and indirect effects of their design and implementation could in some contexts be useful 

to predict the cumulative effects of the proposal. The CEQ regulations, however, do not require agencies 

to catalogue or exhaustively list and analyze all individual past actions. Simply because information about 

past actions may be available or obtained with reasonable effort does not mean that it is relevant and 

necessary to inform decision making (40 CFR 1508.7). The baseline for cumulative effects analysis is 

expressed in descriptions of the No-Action Alternative. 

All invasive plant treatment methods have the potential to damage individual non-target plants. Noise and 

worker activity can disturb wildlife and removal of vegetation can affect their habitat. If manual, 

mechanical or herbicide treatments create bare soil, erosion can be accelerated. Small amounts of 

herbicide or sediment could reach surface water and impact water quality/aquatic organisms. All 

treatments have the potential to injure a worker or result in other accidents; and all treatments would 

create jobs and cost money. There is little disagreement that the potential adverse impacts of nonherbicide invasive plant treatments are minor, small scale, and of short duration. The potential for nonherbicide treatments to result in effects of concern to the public is very low. The potential for cumulative 

effects from such treatments were discussed in the R6 2005 FEIS (Chapter 4-39, 4-50, 4-61 to 62, 4-89 to 

4-90, and 4-122 to 123) and are incorporated by reference. 

Aside from the cost-effectiveness of non-herbicide treatments, public issues focus on the effects of 

herbicide use in the alternatives. Some people have expressed concern that herbicide use from this project 

could combine with herbicide use elsewhere and have an additive, synergistic, or other cumulative effect; 

specifically the effects on wildlife, fish or people exposed to repeated doses of herbicides. 

The focus of the following section is on the cumulative effects from proposed herbicide use combined 

with herbicide use elsewhere, however cumulative effects of vegetation management, recreation and other 

activities are also addressed in the resource cumulative effects sections. 

3.1.6.2 Other Herbicide Use Within and Adjacent to the Project Area 

The following section discusses what is known about herbicide use on other land ownerships adjacent to 

the project area, including adjacent federal, tribal, state, and private lands. Precise information about 

herbicide use off National Forest is not available; there is no requirement for land owners or counties to 

report herbicide use or other invasive plant treatment information, thus an accurate accounting of the total 

81 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

acreage of invasive plant treatment for all land ownerships is unavailable (R6 2005 FEIS page 4-1). 

Herbicide use within National Forests comprises less than 3 percent of overall herbicide use in Oregon 

and Washington (ibid). All herbicide use would follow label guidance and Washington state law. A recent 

report found that all agencies take extra care when herbicides are used in or near sensitive habitats (2004 

Puget Sound Non-agricultural Pesticide Use Report). 

The effectiveness of the prevention, treatment and restoration program on the MBS has the potential to 

influence treatments off the National Forest. Over time, more herbicide use may be required by other land 

owners and managers if invasive plants are not controlled on the MBS. 

Sarah Callaghan, former Forest Invasive Plant Specialist obtained the following information regarding 

herbicide treatments made by federal, state, and county agencies adjacent to the MBS in 2013. Herbicide 

use on these lands would vary from year to year throughout the life of the project. 

Federal

Herbicides are used on Mount Rainier National Park. Approximately 16 infested acres were treated in 

2013. Manual and mechanical integrated with spot herbicide on small targeted infestations using 

aminopyralid, clopyralid, glyphosate, imazapyr and triclopyr. 23 National Park staff also report using 

fluroxypyr, an herbicide that is not 1 of the 10 currently approved in the R6 2005 ROD. 

The Bonneville Power Administration conducts manual, mechanical and herbicide treatments on right-ofways near the MBS. Herbicide use includes low volume foliar spray of glyphosate and triclopyr. 

Approximately 250-400 acres are treated annually with herbicide. 

State

The Washington State Department of Transportation uses a variety of herbicides along state highways 

(approximately 146 acres were treated along highways that cross the MBS in 2013; of these about 113 

acres were within the project area). Many of the herbicides used by the Department of Transportation are 

not 1 of the 10 currently approved in the R6 2005 ROD. 

The Washington State Department of Natural Resources-North Bend area treated 95 aces containing 18 

invasive plant species in 2013. The treatments included manual control and herbicides. Glyphosate, 

clopyralid and triclopyr were the herbicides used on state lands. Approximately 727 acres on 40 miles of 

road adjacent to the MBS were treated within Iron Horse Trail State Parks. Herbicides used include 

aminopyralid, 2,4-D, picloram, and triclopyr. 

Counties

Counties are responsible for controlling invasive plants along county roads and other county property 

outside of and within the MBS. They also work with conservation districts, invasive plant management 

areas, and watershed councils to control invasive plants on private property. 

Snohomish County mainly uses mowing to control invasive plants on roadsides adjacent to the MBS.

Less than 1 acre was treated using glyphosate in 2013. Kittitas County sprayed 2 to 3 acres using 

aminopyralid and clopyralid on lands adjacent to the MBS in 2013. King County treated about 100 acres 

adjacent to the MBS using herbicides and manual controls in 2013. 

23 This information was corrected based on comments from the Department of the Interior. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Other Herbicide Use

Herbicides may also be used on tribal lands, private timber lands, on agricultural lands and within 

residential areas. Information about herbicide use on these lands is unknown. 

3.1.6.3 Invasive Plant Spread and Cumulative Effects

Ground disturbance associated with natural processes such as wildland fire, and human activities, such as 

road use, may favor the spread of invasive plants and discourage the reestablishment of native species. 

Seastedt et al. 2008, notes that human caused disturbance can change soil conditions to which native 

species have adapted, which further results in conditions that favor invasive plants. Repeated road 

clearing and graveling, an open gravel pit, or a cleared compacted recreation area create environments 

that favor colonists species or vegetation that can optimize a large volume of soil with a taproot or species 

which germinate quickly, grow and set seed during the limited growing conditions of the site. Roadside 

environments have coarser texture growing substrate with higher rock content and thus represent growing 

environments that favor invasive plants (Gelbard and Belnap 2003). 

Generally, disturbed environments have greater available resources for invasive plants because of exposed 

soil, open light, and higher nutrient and water availability. Shade under forest canopies substantially limits 

invasive plant growth. However, some of the invasive species on the MBS do invade shaded 

environments (for example, herb Robert). 

Vehicle traffic is considered the major vector for invasive plant seeds since long stretches of roadways 

have invasive plants and vehicles cover large distances that can pick up and deposit seeds into new areas 

(Trombulak and Frissell 2000, Zouhar 2008, Flory and Clay 2009, Birdsall et al 2011). 

Past and ongoing projects and activities on the MBS National Forest have the potential for inducing 

invasive plant spread where soils are disturbed. Table 22 discusses the site types where invasive plants are 

currently found and the risk of spread in these areas. Table 23 discusses types of land uses and activities 

that have the potential for spreading invasive plants. All projects on the MBS include measures to prevent 

the spread of invasive plants and many include active restoration to help native plant communities resist 

infestation. 

Roadsides have the highest greatest potential for invasive plants to become established and spread

because vehicle traffic provides a constant source of invasive plant seeds onto disturbed road fill and 

cutslopes. Rock pits have high hazard for spreading invasive plants since the pits have barren, open sites 

for growing invasive plants and materials moved to new construction sites. 

The MBS NF has ongoing program for decommissioning roads. This program fluctuates with program 

dollars available. Invasive plants pose issues with road decommissioning (Switalski et al. 2004) from both 

the invasive plant seeds persisting from prior use and the reclaimed ground having open sites for 

occupation by invasive plants. The initial 1 to 10 years of reclamation would have high potential for 

invasive plants establishing, while thereafter forest canopy and brush species would gradually secure and 

limit the available site for invasive plants to establish. Invasive plant treatments on these roads become 

more difficult as the vegetation closes and access is limiting.

Recreation areas have ongoing risk for invasive plants from outside transport on vehicles and recreation 

traffic. Approximately 8 percent of the area has invasive plant infestations at recreation sites. Compact 

soils from trampling limit natural vegetation growth, allowing openings for invasive plants to grow. 

However, large soil displacement is rare from construction activities as opposed to ongoing grading and 

mowing along roads. Thus, this risk is less than for roadsides. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

In contrast, timber harvest activities pose primarily periodic to one-time hazards for introducing invasive 

plants. Forest harvest activities have invasive plants that can come in on equipment, workers and animals. 

The disturbance is one-time for most of the harvest openings, although bare skid trails, log landings and 

burn piles can re-vegetate at slower rates creating open sites for invasive plants to colonize. Invasive 

plants often occupy disturbed skid trails and log landing sites (Birdsall et al. 2011). Burn piles on the log 

landings and within the timber site favor exotic invasive plant establishment with higher alkalinity, higher 

available nutrients and open sites for occupation (Meyer et al. 2009). 

Effective treatment coupled with prevention can greatly reduce invasive plant persistence in these areas. 

As opposed to roads with ongoing traffic spreading invasive plants, the threat for continued invasive plant 

spread decreases in logged areas as the forest canopy closes and understory shrubs and tree regeneration 

compete for soil resources.

Grassy areas comprise about 8 percent of the acreage within mapped infestations. Disturbed grassy areas

are susceptible to invasive plant spread, although grass cover can effectively outcompete invasive plants. 

Invasive plants can take advantage of the nutrient-rich soil biological community within grassy areas. 

Powerline rights-of-way make up a small percentage of the invasive plant sites, covering 0.2 percent of 

the current inventoried invasive plant infestations. The maintained open canopy and erosive slopes 

associated with minimal engineered road access create open site conditions. The robust shrub cover and 

natural understory do deter invasive plants. Incursion may follow the road access disturbance. The limited 

access compared to open roads lessens continued invasive plant spread.

High elevation sites such as ski areas and wilderness are less susceptible to invasive plant invasion since 

their climate is outside the growth range of most of the listed invasive plants. However, invasive plants 

have been found along access roads (roads, trails) and other disturbed high elevation areas. These areas 

may become more susceptible to infestation over time as a response to climate change. 

Table 22. Risk of Invasive Plant Spread by Site Descriptions

Type of Site Acreage Risk Reasons

Road shoulder 2,212 Very High High annual seed from vehicles where busy, disturbed surface

Rockpit/stockpile 61 Very High Bare open surface, seeds transported to bare roads

Recreation and 

administrative sites 360 Very High Annual seed dispersal from people and vehicles on disturbed, 

impaired soils

Stream bank and 

lakeshores 1,270 High Annual water and animal seed dispersal on semi disturbed 

surface from water fluctuation

Plantation and 

forests 909 Moderate

One-time invasive plant dispersal from timber harvest and 

planting activities, periodic from animal dispersal on initial 

disturbed surface and longer term disturbed roads and landings

Grassy Areas 482 Moderate Periodic dispersal on altered soils from historic land use

Powerline Rights of 

Way 12 Moderate Periodic dispersal from tree clearing, maintenance work along access roads

Wilderness 4 Low Annual dispersal along trails and campsites, although low overall 

since high elevation sites outside most invasive plant's range. 

Ski slope <1 Low

Periodic dispersal from maintenance on highly erosive open 

slopes, but high elevation sites outside most invasive plant's 

range

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Table 23 displays the potential disturbance frequency and intensity and invasive plant propagule pressure 

associated with various pathways of invasive plant spread. Disturbance frequency and intensity and 

propagule pressure strongly influence the rate that invasive plants are likely to spread along vectors. The 

most applicable R6 2005 ROD standard dealing with preventing the spread of invasive plants via each 

vector is also shown.

Table 23. Potential for Invasive Plant Spread from Projects and Activities

Project Type that 

could impact nontarget vegetation

Disturbance 

Frequency/ 

Potential 

Maximum 

intensity

Most Applicable R6 

Management 

Direction/

Prevention 

Considerations

Restoration 

Considerations

Cumulative Effect 

Considerations

Recreation Projects 

(other than road 

use)

Perpetual/ low

R6 Goal 1, Objectives 

1.2; 2.4, 2.5; 

Standards 1, 4

nOutreach and 

education

nTravel management

nRecreation 

management

Perpetual disturbance 

could make restoration 

of native vegetation 

difficult; implement 

mitigation in recreation 

projects to decrease 

risk of impacts to 

desirable vegetation. 

Areas with heavy 

recreation impacts are 

also most likely to 

have re-infestation of 

invasive plants. 

Road maintenance, 

construction, 

reconstruction and 

use. Rock pit 

management. 

Perpetual/ 

High

R6 Goals 1, 2; 

Objectives 1.1, 1.3, 1.5 

2.3; Standards 1, 2, 3, 

13

Consider seeding and 

mulching, and/or 

planting to encourage 

desirable vegetation 

where invasive pressure 

and potential for 

recovery is greatest. 

Ensure that rock used 

on roads within the 

National Forest is free 

of invasive plant seeds. 

These activities have 

direct impacts to nontarget vegetation 

through ground 

disturbance (clearing) 

of plants and indirect 

effect by increasing the 

potential for 

introduction of noxious 

invasive plants, which 

displace desirable 

species. 

Closing roads Periodic/ Low

R6 Goals 1, 2; 

Objectives 1.1, 2.4, 

2.5; Standards 1, 2, 7, 

8, 13

nCoordination with 

engineering staff, 

quarries are inspected 

and road materials are 

invasive plant free

Consider seeding, 

mulching, and planting 

to establish desirable 

vegetation during to 

road closure process. 

Cumulative benefit to 

road closure, less 

potential for vectoring; 

access limitations can 

complicate invasive 

treatment. Conversely, 

closing roads would 

tend to have a 

cumulative benefit to 

prevention of invasive 

spread.

Restoring roads 

and landings

One time/

Low

R6 Goal 2; Objective 

2.4; Standards 1, 2, 3, 

13

Consider seeding, 

mulching, and planting 

to establish desirable 

vegetation.

Cumulative benefit to 

restoration, less 

potential for invasive 

spread; access 

limitations can 

complicate invasive 

treatment. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

Project Type that 

could impact nontarget vegetation

Disturbance 

Frequency/ 

Potential 

Maximum 

intensity

Most Applicable R6 

Management 

Direction/

Prevention 

Considerations

Restoration 

Considerations

Cumulative Effect 

Considerations

Stream Restoration 

(e.g. fish passage 

and habitat 

projects, riparian 

vegetation 

restoration). 

Seasonal/ High R6 Goal 5; objectives 

5.1-5.3

Encourage riparian 

vegetation 

Restoration projects 

such as installation of 

fish structures have 

the potential to impact 

(remove) riparian 

vegetation and/or 

introduce invasive 

plants through 

contaminated 

equipment. 

Stream restoration 

would tend to have a 

cumulative benefit to 

invasive spread

Vegetation 

Management 

(Thinning and 

brushing, logging, 

burning) 

Periodic/ 

High 

(especially 

within skid 

trails, yarding 

corridors, 

landings, and 

areas of slash 

pile burning)

R6 Goals 1,2; 

Objectives 1.1, 2.1, 

2.2; Standards 1, 2, 3, 

13

Skid trails and yarding 

corridors may need to 

be mulched, seeded or 

planted. General 

forestlands usually have 

an abundant native 

plant seed source. 

Off-road equipment 

can spread invasive 

plants but prevention 

intended to minimize 

impact. 

Mining and Mine 

Restoration

Periodic/ 

Moderate

R6 Goal 2, Objectives 

2.1, 2.2; Standards 1, 

2, 3, 7, 8, 10

Ensure that reclamation 

and mine cleanup

activities do not result in 

spread of invasive 

plants.

Mining and mine 

restoration can spread 

invasive plants but 

prevention measures 

and reclamation are 

intended to minimize 

impact. 

3.1.6.4 Other Ongoing or Foreseeable Projects in the Planning Area

Several projects are occurring or are being planned within the MBS National Forest. Information about 

projects that were recently completed, are being implemented or are ongoing, or are planned to be 

implemented in the foreseeable future are displayed in Appendix F. 

Recently completed projects on the MBS include closing and restoring roads; road construction, 

reconstruction and maintenance; vegetation management (mainly thinning); and recreation development 

and maintenance. These projects occur within treatment analysis areas mapped within the project area 

(TAA 4, 15, 19, 23, 26, 27, 41, 43, 44, and 45) where invasive plant treatment sites occur within or near 

the recently completed projects. Several projects are currently being implemented or are ongoing on the 

MBS. These include mining; a variety of recreation projects; road repair, closure, 

reconstruction/improvement, decommissioning and maintenance; stream restoration; and vegetation 

management (thinning and created openings). Projects are being implemented in TAA 2, 3, 4, 5, 6, 11 15, 

16, 17, 20, 23, 27, 30, 32, 33, 36, 41, 43, 45, 47, 49 and 53. 

Several projects are planned to be implemented in the foreseeable future. These include recreation and 

site maintenance; road closure, repair and reconstruction; vegetation management (mainly thinning and 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

some created openings) and stream restoration. The projects overlap invasive plant treatments proposed in 

TAA 2, 4, 6, 11 14, 19, 23, 32, 33, 38, 32, 43, and 45. These projects may last for several years. 

Most of these projects have the potential to contribute to conditions that favor invasive plants, however 

integrated weed management principles and prevention measures would slow or eliminate their spread. 

Prevention measures are routine, enforceable and effective in vegetation management projects. Cleaning 

equipment, protecting invasive plant sites from disturbance, and reseeding skid trails and landings have 

reduced the spread of aggressive invasive plant species on the MBS. 

Although invasive plant spread may be associated with some of these projects, the cumulative impact of 

EDRR treatment within the scope of this project is limited by the Management Requirements and 

Mitigation Measures listed in Table 9. The EDRR strategy would play a critical role in keeping new 

infestations small. The predictions in Chapter 3.2 regarding invasive plant spread over the life of the 

project incorporate assumptions about introductions of invasive plants from forest use and other human 

activities on and off the MBS. The effects of recent past, current, ongoing and foreseeable future projects 

are unlikely to combine with the effects of this project, because the impacts from the invasive plant 

treatments are small and are dispersed in time and space. 

3.1.6.5 Summary of the Basis for Cumulative Effects Analysis

While this project may occur throughout the MBS and over an extended period of time, the risk of 

adverse impacts on people and the environment from invasive plant treatment at any one time and place is 

low. This limits the potential for this project to combine with another project and cause cumulative 

adverse effects on people, animals, or the environment. 

The cumulative effects analysis assumes that legal use of herbicides is occurring on the other ownerships 

described above. Treatments on other ownerships are influenced by the effectiveness of treatments on the 

MBS and thus, increased treatment on the MBS might not equate to more invasive plant treatment 

overall. Mark Boyar of the Middle Fork Coalition on behalf of several environmental interest groups 

noted in their DEIS comment letter that if treatments are ineffective on the MBS, herbicides “will be used 

anyway, but likely in greater quantities than would have been necessary had the infestations been 

controlled at their source.” 

The acreage proposed for treatment is relatively small and the invasive plants to be treated are widely 

scattered. This dilutes the potential for the impacts of this project to overlap with impacts of other 

projects. The effects of herbicide use are mainly limited to the site of application. Drift from broadcast 

treatments is unlikely to harm non-target vegetation more than 100 feet away from treated areas. Spot and 

selective treatments are far less likely to move off site (7-15 feet for lethal effects to native vegetation). 

The invasive plant sites are scattered throughout the Forest and the project would be implemented over 10 

to 15 years, thus, there is likely to be spatial and temporal with other projects. However, the risk of direct 

and indirect adverse effects of invasive plant treatments have been minimized, thus there is little potential 

for the effects of this project to overlap in time and space with effects of other projects. Herbicides are 

unlikely to drift, leach or run off into surface waters and harm aquatic organisms, given the herbicide use 

buffers described in Table 10. 

The cumulative effects analysis assumes that invasive plants will be treated on lands adjacent to the MBS

and herbicide applicators would likely be repeatedly exposed to herbicides. People and animals could be 

exposed to repeated doses of herbicides. However, risk assessments and the R6 2005 FEIS (pages 4-1 to 

4-3) found that repeated exposures would not result in cumulative effects because the herbicides proposed 

for use are rapidly eliminated from the bodies of people and animals. For effects of repeated exposures to 

be additive, the repeated exposure would have to be simultaneous, such as a person contacting herbicide 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Introduction

directly, while eating sprayed vegetation and drinking contaminated water. In summary, factors that limit 

the potential for cumulative effects from herbicide use proposed in the action alternatives include the 

following: 

The risk of adverse effects of invasive plant treatments in all action alternatives has been 

minimized by the MR/MM, treatment caps and herbicide use buffers applicable to known sites and 

new detections. Predicted herbicide exposures are very small compared to likely background 

downstream conditions, and are not likely to trigger cumulative adverse effects to neither people 

nor the environment. 

In general, invasive plant sites are small and scattered. 

Herbicide residues from past treatments in most locations would be broken down or adhered to 

organic matter or soil particles within less than 1 year of application. Herbicides such as 

aminopyralid, imazapyr, metsulfuron methyl and picloram can persist for more than 1 year under 

some conditions and may result to some accumulation in soils at the invasive plant treatment site. 

This is managed through MR/MM 26 that limits repeated applications of persistent herbicides. 

Early detection rapid response is part of Alternatives 2 and 3, and is considered in the direct, 

indirect and cumulative effects analysis. Effects of treatments each year under early detection

rapid response, by definition, would not exceed the annual and life of the project caps. Treatment 

caps further restrict the spatial and temporal extent of impacts from this project. 

Multiple herbicide exposures on National Forest System land are unlikely to occur in close enough 

proximity in time or space with other applications to combine and cause cumulative effects. 

Infestations that cross ownership boundaries are often treated cooperatively so the effects are 

limited to the existing infestation and immediately surrounding areas. 

The R6 2005 FEIS (pp. 4-1 to 4-3) and SERA Risk Assessments discussed effects of chronic 

exposure to low levels of herbicides used to treat invasive plants on National Forest System land. 

Chronic exposures do not result in cumulative effects because the herbicides are more rapidly 

excreted from organisms (people, animals and fish) than would be absorbed from predicted levels 

of exposure. Thus, an animal could encounter herbicide in more than one location over time; 

however there would be no possibility for this project to result in exposures that could cause a 

cumulative effect. 

3.2 Treatment Cost-Effectiveness 

3.2.1 Introduction

This section discusses how the design of each alternative influences the cost and likelihood of success 

eradicating, controlling, and containing invasive plants on the MBS. The cost-effectiveness of each 

alternative is influenced by the tools available for use; the more tools available, the greater the potential 

effectiveness of the treatment. If the toolbox is restricted and some situations cannot be effectively 

treated, the percentage of target population killed each year can be dramatically decreased. On page 4-18, 

the R6 2005 FEIS notes that “alternatives that have the widest variety of herbicides and herbicide families 

available for use have the greatest potential to result in effective treatments.” In contrast, when herbicide 

use is more restricted, “fewer acres would likely be achieved at a constant budget and the years to control 

increases proportionally” (ibid. p. 4-21). Thus, a loss of effectiveness is likely if the most effective 

herbicide choice is not available for a given site. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Cost-Effectiveness

Herbicide resistance may occur if one herbicide is used repeatedly in an area over a series of years (R6 

2005 FEIS p. 3-94). More than one herbicide active ingredient may be needed to ensure that herbicide 

resistance does not occur. The repeated use of one herbicide could allow naturally resistant plants to 

survive and reproduce. As the number of resistant plants increases, the efficacy of the herbicide 

diminishes until the herbicide no longer effectively controls the invasive plant populations. To develop 

resistance avoidance strategies, long-term site plans should recognize which of the various herbicide 

families have available and effective herbicides if multiple applications are expected to be necessary. 

Integrated chemical and non-chemical controls are highly effective where feasible because any surviving 

herbicide resistant plants can be removed from the site. If timely and effective integrated treatments 

methods are implemented, reliance on herbicides would decrease over time.

In Alternative 2, the most effective herbicide and treatment method is proposed. Treatment effectiveness 

would be increased compared to Alternative 1, because in Alternative 1, the broadcast application method 

is not available for about 2,470 acres and the first choice herbicide is not available on an additional 357 

acres. Compared to Alternative 2, Alternative 3, would also be less effective, because the first choice 

herbicide is not available on about 2,455 acres. Less effectiveness would increase costs and could 

compromise the ability to control or eradicate populations of some aggressive target species, such as 

hawkweeds and knapweeds. Limitations on application method and herbicide selection would compound 

over time. Herbicide use could have to be repeated on more acres or over a longer time for Alternatives 1 

and 3. 

Alternative 2 (Proposed Action) utilizes all available tools and thus is assumed to reduce populations by 

80 percent per year. Effective treatment on a given site would be about 80 percent effective, meaning that 

there would be 80 percent fewer invasive plants in the treated area the year following treatment, assuming 

fully effective integrated weed management methods are used. A reduction of about 80 percent of the 

target species is generally expected from forestland herbicide treatments, however actual results can vary 

widely (Desser 2008, Dr. Tim Miller, Washington State University, personal communication 2014; 

Vanelle Peterson, Dow Chemicals, personal communication 2014). 

Results at any treatment site vary depending on factors such as treatment objective, the target species, the 

size of the infestation, and the seed bank in the soil. The estimate of 80 percent reduction assumes that 

about 20 percent of the existing target population would remain after each treatment entry and that on 

average, four treatment entries would be required. Remnant target plants and seed banks can remain for 

several years but after four entries, invasive plants at any given site would be substantially reduced. The 

cost estimate assumes that all known infestations are treated the first year following a decision on this 

project, and then treated in three subsequent entries over a total of 4 years. 

The 80 percent effectiveness concept is expressed as a decrease in the number of acres estimated to need 

treatment each year. For instance, a 100 acre infestation effectively treated in Year 1 would result in 20 

acres needing treatment in Year 2. These 20 acres treated in Year 2 would result in 4 acres still needing 

treatment Year 3. Although this assumption is applied to acres; more likely there would be 80 percent less 

density of invasive plants within the infested area, rather than 80 percent fewer acres. 

If the toolbox is restricted, fewer invasive plants would be effectively removed each treatment entry. 

Alternative 1 would be less effective on each treatment entry because it would not include broadcast 

treatment, nor would the first choice (most effective) herbicide be available for some acres. In Alternative 

1, effectiveness is estimated to be reduced from 80 to 60 percent on about 2,470 acres that are proposed 

for broadcast application in Alternative 2. Spot treatments in these areas would likely leave gaps, 

increasing the acreage that would need to be re-treated each year. Also, where broadcast treatments are 

warranted but not allowed, successful control or eradication would be unlikely, and containment would be 

likely the best outcome expected. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Cost-Effectiveness

Under Alternative 1, effectiveness would also be reduced on an additional 357 acres where the first choice 

herbicide is not currently approved. Effectiveness would be reduced from an estimated 80 percent to 70 

percent per year on these acres. 

For Alternative 3, aminopyralid would not be available, resulting in an estimated 10 percent loss of 

effectiveness per year. This would apply to about 2,455 acres where aminopyralid would be the most 

effective choice. In addition, the herbicide use buffers for streams would be larger (e.g. spot treatments 

would be required) on approximately 274 acres that could no longer be broadcast because aminopyralid is 

the only herbicide that could be broadcast to the water’s edge. Treatment effectiveness would be reduced 

to 60 percent per year on these acres.

Treatment costs are estimated to range from about $110 per acre for mechanical treatment to about $200 

per acre for manual treatment. For herbicide use, broadcast acres cost an average of $120 per acre and 

spot/selective treatments cost about $185 per acre. (Callaghan July 2012 personal communication). In this 

analysis, each treatment acre, whether spot or broadcast herbicide or a non-herbicide method, is assumed 

to cost $200 to accommodate the full range of treatment options at any given site. 

Planting, seeding and/or mulching is recommended for 2,636 acres (Potash Botany Report 2012). While 

specific costs would vary, an average of $500 per planted, seeded, or mulched acre was used (USDA 

2008a and 2008b). The analysis assumes that by the fourth treatment entry, planting, seeding and 

mulching recommended for restoration would be completed (see Appendix B for restoration needs for 

currently known sites, based on their 2012 condition). 

The analysis does not include the costs of planning, monitoring or overhead. The analysis assumes each 

infestation is treated separately, however because about 20 percent of the infested acreage is co-located, 

some efficiencies may be gained if more than one target species is treated at the same time. 

3.2.2 Alternative 1 - No Action 

The No-Action Alternative (Alternative 1) is the least effective alternative. Some herbicide ingredients 

and mechanical methods would not be used. The broadcast application method would be restricted to 

Skiyou Island only, which would reduce potential effectiveness from 80 percent of the invasive plant 

population per year to 60 percent on about 2,470 acres, due to increased potential for skipped areas 

associated with spot treatment. The first year/first choice herbicide would not be available for an 

additional 337 acres, reducing effectiveness to 70 percent on these acres. Effectiveness would be the same 

for the remaining 2,071 acres where treatments would be the same as Alternative 2 (80 percent). Thus, 

Alternative 1 would have a weighted average effectiveness of 69 percent. The total cost estimate 

(assuming adequate budget to treat all infestations in a single year, then retreating remaining infestations 

each year for 4 years) would follow the pattern described below: 

Year 1, all 4,878 acres are treated. At $200 per acre, the cost year for year 1 amounts to about 

$975,600. About 31 percent of the acreage would need re-treatment, or about 1,512 acres 

remaining. 

Year 2, 1,512 acres are treated. At $200 per acre, the cost for year 2 amounts to about $302,400. 

About 31 percent of this acreage would need re-treatment, or about 469 acres remaining. 

Year 3, 469 acres are treated. At $200 per acre, the cost for year 3 amounts to about $93,800. 

About 31 percent of this acreage would need re-treatment, or about 146 acres remaining. 

Year 4, 146 acres are treated. At $200 per acre, the cost for year 4 amounts to about $29,200. 

About 31 percent of this acreage would need re-treatment, or about 45 acres remaining. Some 

areas may not be fully controlled or eradicated. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Cost-Effectiveness

Restoration is assumed to occur in year 5 for 2,636 acres for a total cost of $1,318,000. 

Total cost of Alternative 1 over the 5 year period is $2,719,000. Average cost of each 

treated/restored acre amounts to about $557 per acre. 

Given current budgets estimated at $200,000 per year (Callaghan personal communication, 2013), 

Alternative 1 would take an estimated 14 years to meet treatment objectives possible under Alternative 1. 

Alternative 1 would not be likely to result in eradication and/or control of dense or large infestations. 

3.2.3 Alternative 2 – Proposed Action 

The Proposed Action, Alternative 2, would allow the most effective treatment method and herbicide 

ingredient on all known infestations, with an 80 percent reduction in invasive plant acreage each 

treatment entry. An estimated average of about 20 percent of the infestation would need to be retreated 

each year due to lingering seedbank and missed areas. The total cost estimate (assuming adequate budget 

to treat all infestations in a single year, then retreating remaining infestations each year for 4 years) would 

follow the pattern described below: 

Year 1, all 4,878 acres are treated. At $200 per acre, the cost year for Year 1 amounts to about 

$975,600. About 20 percent of the acreage would need re-treatment, or about 976 acres remaining. 

Year 2 976 acres are treated. At $200 per acre, the cost for Year 2 amounts to about $195,200. 

About 20 percent of this acreage would need re-treatment, or about 195 acres remaining. 

Year 3, 195 acres are treated At $200 per acre, the cost for Year 3 amounts to about $39,000. . 

About 20 percent of this acreage would need re-treatment, or about 39 acres remaining. 

Year 4, 39 acres are treated. At $200 per acre, the cost for Year 4 amounts to about $7,800. About 

20 percent of this acreage would need re-treatment, or about 8 acres remaining. This is considered 

“maintenance level” and likely to be treated with limited use of herbicide for particularly 

aggressive species or established seedbanks.

Restoration is assumed to occur in Year 5 for 2,636 acres for a total cost of $1,318,000. 

Total cost of Alternative 2 over the 5-year period is $2,535,600. Average cost of each 

treated/restored acre amounts to about $520 per acre. 

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 

would take at least 12 to 13 years to effectively treat currently mapped sites. 

Alternative 2 is estimated cost about $520 per restored acre. Alternative 2 would not exceed about $7.5 

million assuming all known sites are effectively treated, along with 13,500 additional EDRR acres 

detected over the life of the project. 

3.2.4 Alternative 3 

Alternative 3 would not approve aminopyralid, which is the most effective treatment method and 

herbicide ingredient on about 2,369 acres of known infestations. Because aminopyralid would not be 

approved, the potential effectiveness would be reduced by an estimated 10 percent, down from 80 percent 

per year to 70 percent per year on these acres (professional judgment). Of these acres, spot treatments 

would be required on approximately 274 acres that could no longer be broadcast because aminopyralid is 

the only herbicide that could be broadcast to the water’s edge (see table 48 in Water Resources Chapter 

3.7 for more information about treatments within the aquatic influence zone), reducing the potential 

treatment effectiveness to 60 percent. About 2,509 acres would have the same treatment as Alternative 2, 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Cost-Effectiveness

with the same estimate of effectiveness (80 percent reduction of invasive plants per year). The weighted 

average effectiveness amounts to about 74 percent, based on about 2095 acres estimated at 70 percent 

effective (due to loss of aminopyralid as the first choice), about 274 acres estimated at 60 percent 

effective (due to loss of aminopyralid broadcasting near streams), and about 2,509 acres estimated as 80 

percent effective (because they include the same first choice herbicide as Alternative 2). Approximately 

26 percent of the treated population is estimated to remain after treatment, (as compared to 31 percent in 

Alternative 1 and 20 percent in Alternative 2). 

Alternative 3 would not be likely to result in full eradication and/or control of dense or large infestations 

that are near streams. This would mean that our objective would become containment, rather than control 

or eradication, on about 274 acres. 

The total cost estimate (assuming adequate budget to treat all infestations in a single year, then retreating 

remaining infestations each year for 4 years) would follow the pattern described below: 

Year 1, all 4,878 acres are treated. At $200 per acre, the cost year for Year 1 amounts to about 

$975,600. About 26 percent of the acreage would need re-treatment, or about 1,268 acres 

remaining. 

Year 2, 1,268 acres are treated. At $200 per acre, the cost for Year 2 amounts to about $253,600. 

About 26 percent of this acreage would need re-treatment, or about 330 acres remaining. 

Year 3, 330 acres are treated. At $200 per acre, the cost for Year 3 amounts to about $66,000. 

About 26 percent of this acreage would need re-treatment, or about 86 acres remaining. 

Year 4, 86 acres are treated. At $200 per acre, the cost for Year 4 amounts to about $17,200. About 

26 percent of this acreage would need re-treatment, or about 22 acres remaining. Some areas may 

not be fully controlled or eradicated. 

Restoration is assumed to occur in year 5 for 2,636 acres for a total cost of $1,318,000. 

Total cost of Alternative 3 over the 5-year period is $2,630,400. Average cost of each 

treated/restored acre amounts to about $539 per acre. 

Given a fixed budget and current funding levels, Alternative 3 would take about 13 years to accomplish. 

Alternative 3 is estimated cost about $539 per restored acre. The average cost per acre would be increased 

by about 4 percent compared to Alternative 2 (Proposed Action). Assuming all known sites are effectively 

treated, along with 13,500 additional EDRR acres detected over the life of the project, the project could 

cost up to 10 million dollars. 

3.2.5 Effect of Alternatives on Invasive Plant Treatment Objectives

Treatment objectives have been identified for each site, based on the target species, size of the infestation, 

and location. Restrictions in the treatment toolbox would influence whether or not the objectives can be 

effectively met. If all tools are available, including use of aminopyralid and broadcasting where needed 

(Alternative 2), invasive plants could be eradicated on about 220 acres, controlled on about 3,321 acres 

and contained on about 1,481 acres. 

Under the No-Action Alternative (Alternative 1), treatment objectives would not likely be met on all 

acreage because the most effective herbicide choices would not be available in all situations, and 

broadcasting would not be allowed (except for Skiyou Island). This would tend to decrease acreage that 

may be controlled or eradicated, and increase acreage that may be contained. Under Alternative 3, no 

aminopyralid would be used, therefore broadcasting would not be allowed to the water’s edge. This could 

influence whether or not infestations could be controlled on about 274 acres. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Cost-Effectiveness

Table 24. Comparison between Objectives for No Action and the Action Alternatives 

Treatment Objective 

Acres 

Alternative 1 

Acres 

Alternative 2 

Acres 

Alternative 3 

Contain 2,504 1,368 1,642

Control 2,284 3,290 3,016

Eradicate 90 220 220

Estimated acres where ability to control or eradicate 

target species may be compromised due to 

broadcasting restrictions (containment could still be 

achievable)

1,200 0 274

3.2.6 Effectiveness of Early Detection and Rapid Response (EDRR)/”New 

Invader” Approach

The alternatives differ in the process for treating newly detected invasive plants and responding to 

changes in the size or condition within known sites. The intention of the action alternatives is to reduce 

the time between detection of new of changed sites and their treatment compared to the current new 

invader strategy. 

Table 25. Comparison of EDRR/New Invader Strategy between No-Action and Action Alternatives

No Action Action Alternatives Effectiveness

Based on the previous year’s surveys, 

new invasive plant infestations would be 

documented [using the forms in 

Appendix D of the 2005 EA]. 

Invasive plant sites and 

treatment plans would be 

mapped according to Forest 

Service policy. Data bases 

such as NRIS and FACTS 

are used to track invasive 

plant populations and 

treatments.

The action alternatives do not require 

“previous year surveys.” New 

detections could be treated rapidly as 

long as the implementation planning 

process is followed and the treatment 

is consistent with MR/MM, herbicide 

use buffers and project caps. 

New infestation sites would be 

prioritized.

All sites proposed for 

treatment would be 

prioritized depending on the 

potential for adverse effects 

on the environment from the

invasive plant. Priority would 

be determined in 

cooperation with federal, 

state and county agency 

partners and other 

interested parties. 

The more high priority areas treated, 

the greater the effectiveness of the 

project. 

The current “set” of high-priority sites 

would be included in each year’s 

prioritization, which could result in a 

newly-discovered site being ranked as a 

higher priority for treatment. 

New and known sites would 

be treated according to 

priority, with some 

exceptions, for instance, if a 

medium or lower-priority 

infestation can be treated as 

part of another planned 

project, or as part of a suite 

of restoration projects within 

a watershed. 

The more high priority areas treated, 

the greater the effectiveness of the 

project. Treatment of medium or lower 

priority infestations would also help 

restore desired vegetation in treated 

areas. Treating new detections before 

they are well established would 

increase project effectiveness. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Cost-Effectiveness

No Action Action Alternatives Effectiveness

Once a new site is ranked as a high 

priority, an initial proposed treatment 

and restoration plan would be selected, 

based on the type of invasive plant, size 

of infestation, and location. Tools to 

make this assessment would include, 

but not be limited to: the biology of each 

invasive plant species and their control

history [Appendix C of the 2005 MBS 

EA]; and MBS specific experience with 

treating invasive species [Appendix B, 

of the 2005 MBS EA]. The only 

treatment methods available for 

selection would be those included in the 

[2005 MBS] EA, along with all 

Management Requirements and 

Mitigation Measures. 

The implementation 

planning process includes 

developing integrated 

treatment prescriptions 

according to MR/MM based 

on a comprehensive list of 

site considerations. This 

project does not include 

herbicide application directly 

to water, aerial application of 

herbicides, use of any 

pesticides other than 

herbicides, treatment of 

aquatic invasive plants 

(floating and submerged), 

treatment of native plants, 

and changes in land uses to 

slow or prevent the spread 

of invasive plants. 

Otherwise, treatments that 

are consistent with MR/MM, 

herbicide use buffers, and 

treatment caps would be 

considered in the scope of 

the action alternatives.

In the action alternatives, the MR/MM 

and herbicide use buffers are intended 

to minimize adverse effects of 

treatment without impeding the 

Forest’s ability to rapidly and costeffectively treat invasive plants. 

A new annual newsletter would be 

produced each spring, listing the new 

sites. It would be mailed to all interested 

parties, including agencies (such as 

U.S. Fish and Wildlife Service 

(USFWS), and NOAA Fisheries), 

Tribes, and others. Comments would be 

solicited.

No annual newsletter 

required. Notification would 

occur as per the MR/MM. 

Consultation with tribes and 

ESA regulatory agencies 

would occur as agreed. 

The intent of the action alternatives is 

to minimize the paperwork necessary 

to treat new detections, and to avoid 

having to wait for an annual newsletter 

to be produced before treatment can 

occur on the ground. 

For each new, high-priority site: the 

effects on other resources from 

treatment/restoration would be 

estimated. This information would be 

included in the newsletter.

No additional effects 

analysis is required for 

treatments within the scope 

of the action alternatives. As 

long as MR/MM, herbicide 

use buffers, and project 

caps are properly applied, 

any treatment that is not 

specifically excluded may be 

implemented. 

Cost-effectiveness of treatment would 

be increased by not having to 

“estimate” effects that have already 

been disclosed in this NEPA 

document.

If the effects are found to be within the 

scope of this EA, and USFWS and 

NOAA Fisheries concur through 

informal Section 7 (ESA) consultation, 

sites would be added as addenda.

Report as agreed as a result 

of Section 7 Consultation.

All alternatives would include 

coordination and reporting to ESA 

regulatory agencies. No change in 

cost-effectiveness would be expected. 

All treatments would be accomplished 

as funding is available. No change. 

Cost-effectiveness is influenced by 

funding. Infestations that are not 

treated due to funding constraints are 

likely to continue to spread or become 

more dense and expensive to treat.

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Cost-Effectiveness

3.2.7 Cumulative Effects on Treatment Effectiveness

Chapter 3.1.6 describes the what is known about invasive plant treatments occurring on lands adjacent to 

the MBS. The efforts of several county, state and federal agencies would complement effective treatments 

and restoration occurring on the MBS. The cumulative effect of treatments within and adjacent to the 

MBS would be beneficial because invasive plants can spread between different land ownerships and 

management agencies. The more acres effectively treated, the less potential for spread.

Implementation of prevention measures would have a beneficial impact on treatment effectiveness. 

Prevention reduces the rate of spread of invasive plants; however it is unlikely that rate of spread could 

ever reach zero because some vectors are outside Forest Service control and some infestations are already 

so large that they cannot be rapidly controlled or contained. 

A cumulative benefit would be expected from implementing effective prevention measures and effective 

treatments. This would reduce the acreage of invasive plants subject to spreading along with reducing the 

rate of spread. Species and site-specific models do not exist to more precisely predict the rate of spread 

and the influence of prevention. An integrated invasive plant management program is considered the most 

effective way to meet invasive plant objectives and follow policies, standards and guidelines. 

3.2.8 Alternative Comparison, Cost-Effectiveness

A summary of the information described above, along with the life of the project estimated costs are

shown in Table 26. 

Table 26. Summary of the Treatment Cost-Effectiveness Analysis

Treatment Acres and Costs No Action

Alternative 1

Proposed 

Action

Alternative 2

No 

Aminopyralid

Alternative 3

Acres Treated Year 1 4,878 4,878 4,878

Cost Year 1 in Dollars 975,600 975,600 975,600

Acres Treated Year 2 1,512 976 1,268

Cost Year 2 in Dollars 302,400 195,200 253,600

Acres Treated Year 3 469 195 330

Cost Year 3 in Dollars 93,800 39,000 66,000

Acres Treated Year 4 146 39 86

Cost Year 4 in Dollars 29,200 7,800 17,200

Restoration Cost Year 5 1,318,000 1,318,000 1,318,000

Total Cost in Dollars Known Sites Treatment Plus 

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

Average Cost Per Treated/Restored Acre in Dollars 557 520 539

Years to Effectively Treat Known Sites given budget 

estimate of $200,000 per year 14 12-13 13

Maximum Cost in Dollars, Assuming Average Cost 

Treatment Plus Restoration applied to known sites plus 

13,500 EDRR acres.

NA 9.5 million 10 million

Estimated acres where ability to control or eradicate target 

species may be compromised due to broadcasting 

restrictions (containment could still be achievable)

1,200 0 274

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Human Health

3.3 Human Health 

3.3.1 Introduction

This section focuses on the health effects to workers and the public from herbicide use proposed in the 

alternatives. The R6 2005 FEIS and its Appendix Q: Human Health Risk Assessment detailed the 

potential for health effects from manual and mechanical treatments as well as the use of 10 of the 

herbicides proposed for this project and is incorporated by reference in this EIS. Four of the risk 

assessments that were incorporated into the R6 2005 FEIS were updated in 2011 (imazapyr, glyphosate, 

picloram, and triclopyr). This section includes findings from the new risk assessments based on herbicide 

application rates proposed for this project. 

The Proposed Action would also add a new herbicide, aminopyralid, which is likely to be more effective 

on many of the target species found on the MBS, with less risk of adverse effects. The risk assessment for 

aminopyralid (SERA 2007) is the primary source of toxicological information about that herbicide. 

Herbicide active ingredients, metabolites, inert ingredients, and adjuvants and people with herbicide 

sensitivity are addressed in the risk assessments and the R6 2005 FEIS.

Hazards normally encountered while working in the woods (strains, sprains, falls, etc.) are possible during 

herbicide and non-herbicide invasive plant treatment operations. Such hazards are mitigated through 

worker compliance with occupational health and safety standards and are not at issue for this project-level 

analysis. No unusual circumstances have been found requiring the need for additional human health 

analysis for non-herbicide treatments. For more information on potential hazards associated with nonherbicide treatments, see the R6 2005 FEIS Chapter 3.5. 

Herbicide toxicity (herbicide impact on human health) is a key issue, even though herbicide use is already 

approved on the MBS and risk assessments indicate that herbicide exposures as a result of this project are 

unlikely to harm human health. This conclusion is based on facts about chemistry of the herbicides 

considered for use and the mechanisms by which exposures of concern might occur. Impacts to worker 

and public health would only be expected under extreme and unlikely exposure scenarios, such as a child 

drinking water from a pond contaminated by a spill, or a worker ignoring routine safe herbicide handling 

and application practices. 

The use of herbicide in the action alternatives would be according to label requirements, with further 

restrictions in the R6 2005 ROD (MBS Forest Plan) standards. For example, treatment restoration 

standard 15 requires application be performed or directly supervised by a licensed applicator; standard 16 

includes restrictions on tank mixtures; and standard 23 requires timely public notification and signing of 

treatment areas. Project-specific Management Requirements and Mitigation Measures (MR/MM) also are 

intended to reduce risk of herbicide exposure to the public. 

Invasive plant infested sites are scattered throughout the MBS and occupy less than 1 percent of National 

Forest System lands on the Forest. Invasive plant treatments on the MBS are implemented through Forest 

Service contracts or in partnership with county crews. Applicators are generally from the communities in 

and around the MBS and are well-trained in safe herbicide handling and transportation practices. No 

environmental justice issues have been raised for this project. 

Regulatory Framework

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) establishes the US system of pesticide 

regulation to protect applicators, consumers and the environment. It is administered by the Environmental 

Protection Agency (EPA) and the appropriate environmental agencies of the respective states. FIFRA 

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requires registration for all herbicides, after extensive testing to evaluate whether a pesticide has the 

potential to cause adverse effects on humans, wildlife, fish, and plants, including endangered species and 

non-target organisms, as well as possible contamination of surface water or ground water from leaching, 

runoff, and spray drift. 

When registered, a label is created to instruct the applicator on the proper usage of the material and 

required personal protective equipment. EPA also must approve the language that appears on each 

pesticide label and the product can only be used legally according to the directions on the labeling 

accompanying it at the time of sale.

The Forest Service is authorized by FIFRA and the Cooperative Forestry Assistance Act to use pesticides 

for multiple-use resource management and maintenance of the quality of the environment as long as the 

actions comply with the National Environmental Policy Act and the Council on Environmental Quality 

regulations. Forest Service Manual (FSM 2150) and Forest Service Handbook (FSH 2109) provide 

direction on safe use of pesticides, including direction on storage and transport, and development of 

safety plans and emergency spill plans.

Analysis Methodology

This analysis incorporates analysis in the R6 2005 FEIS and scientific risk assessments completed by 

Syracuse Environmental Research Associates, Inc. (SERA). Appendix Q of the R6 FEIS summarizes 

information about the human health hazards associated with herbicide use. The risk assessments include 

peer-reviewed articles from the open scientific literature and current EPA documents, including 

Confidential Business Information. Along with active ingredients, the assessments also reviewed 

herbicide additives, inert ingredients, and impurities, where information was available. 

Hexachlorobenzene (present as an impurity in picloram at 8 parts per million, and in clopyralid at much 

lower levels) was also evaluated. 

To assess human health risks this analysis compares the dose of herbicide received by a worker or a 

member of the public under each exposure scenario with the corresponding herbicide “Reference Dose” 

(RfD) established by EPA or by the Forest Service/SERA risk assessment for acute and/or chronic 

exposures. If doses from estimated exposures for a specific Forest Service herbicide application are less 

than the RfDs, there would be no indication of a risk of health effects. 

RfDs are established by taking the no observable adverse effect level (NOAEL) for each herbicide and 

then adjusting it to compensate for uncertainty. Most frequently, a RfD is 1/100th of the lowest NOAEL, 

but it may be even lower in some cases. The RfD is also referred to as the toxicity threshold or threshold 

of concern. The Hazard Quotient (HQ) is the ratio of the estimated level of exposure compared to the 

RfD. When a predicted dose is less than the RfD, then the HQ (dose/RfD) is less than 1, and toxic effects 

are unlikely for that specific herbicide application (i.e., the use is presumably safe). No chemical is 

studied for all possible effects and the use of data from laboratory animals to estimate hazard or the lack 

of hazard to humans of other species is an uncertain process. Thus, prudence dictates that normal and 

reasonable care should be taken in the handling of any chemical.

The risk assessments and project specific risk assessment worksheets quantify expected exposures and 

calculate the HQ’s. These worksheets provide a range of values (lower, central and upper) rather than rely 

on a single estimate. The upper exposure estimates are based on the maximum estimate for every 

exposure factor that is considered, which is very unlikely to occur in our operations (e.g., maximum 

application volume, maximum concentration in field solution, maximum volume of a spill, maximum 

residue rates on food items, maximum exposure rates, maximum hours worked). The upper exposure 

estimates are not reflective of the way herbicides would be used in this project and the probability of 

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maximum exposures occurring is very low. Thus, the central and lower estimates provide more realistic 

risk assessment results and are reported here. Three of the herbicides proposed in one or more alternatives 

(aminopyralid, imazapyr and metsulfuron methyl) did not have any HQ values greater than 1, even for the 

upper estimates. HQ values for the upper estimates are available in the project files, however, they are not 

considered plausible for this project and are not discussed further in the human health analysis. 

Even considering central or lower HQ estimates, many of the exposure scenarios for the general public 

are implausible or extremely conservative. The general public is unlikely to be directly exposed treated 

areas. Estimates of longer-term consumption of contaminated water are based on estimated application 

rates throughout a watershed; however, only small portions of a watershed would be treated. Exposure 

scenarios based on longer-term consumption of contaminated vegetation assume that an area of edible 

plants is inadvertently sprayed and that these plants are consumed by a person over a 90-day period. 

While such inadvertent contamination might occur, it is extremely unlikely to happen as a result of 

directed applications (e.g., backpack applications). Even in the case of boom (broadcast) spray operations, 

the spray is directed at target vegetation and the possibility of inadvertent contamination of cultivated or 

edible vegetation would be low. In addition, for herbicides and other phytotoxic compounds, it is likely 

that the contaminated plants would show obvious signs of damage over a relatively short period of time 

and would therefore not be consumed (SERA 2007). 

3.3.2 Affected Environment 

Many people live near, spend time in, work in, or depend on forest products from the Mount BakerSnoqualmie National Forest. Some dispersed and developed recreation areas (e.g., trailheads, 

campgrounds, picnic areas, recreation sites, boat ramps) and traditional gathering and special forest 

product collection areas currently occur in or near the vicinity of invasive plant sites. People engaged in 

these activities could potentially be inadvertently exposed to herbicides from treatment of invasive plants 

in or near these areas. Invasive plants are most prevalent along roads that provide access for a variety of 

public uses. 

Several species of mushrooms, berries, roots, and herbs, some of which have cultural importance to 

traditional gatherers, occur on the MBS. Cultural plants are used for food and baskets and traditional 

gathering is essential to the maintenance of tribal traditions and culture. Gathering is also economically 

important. Gatherers return to the accustomed gathering areas of their ancestors to tend and harvest plants 

to be used for traditional purposes. Passing these traditions on to future generations preserves 

conservation ethics and ecosystem stewardship that have evolved over generations.

3.3.3 Environmental Consequences

3.3.3.1 Worker Herbicide Exposure Analysis 

The risk assessments include analysis for both workers and the general public. This section focuses on the 

risks of proposed herbicide application to applicators themselves. Herbicide applicators are more likely 

than the general public to be exposed to herbicides, and may handle undiluted herbicide concentrate 

during mixing and loading. In routine broadcast and spot applications, workers may contact and 

internalize herbicides mainly through exposed skin, but also through the eyes, mouth, nose or lungs. 

Worker exposure is influenced by the application rate selected for the herbicide, the number of hours 

worked per day, the acres treated per hour, and variability in human dermal absorption rates. 

All herbicides can cause irritation and damage to the skin and eyes if mishandled. Eye or skin irritation 

would likely be the only overt effect because of mishandling these herbicides. These effects can be 

minimized or avoided by prudent industrial hygiene practices during handling. Worker exposure can be 

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effectively managed through ordinary prudent practices and use of personal protective equipment (PPE) 

required for applicators. 

Appendix Q: Human Health Risk Assessment of the R6 2005 FEIS, the 2007 Aminopyralid Risk 

Assessment, and the updated 2011 Risk Assessments summarize risks for backpack and broadcast 

spraying under normal application and maximum exposures. Exposure levels that were evaluated range 

from predicted average exposure to worst-case exposure. Risks from accidental/incidental exposures are 

also displayed. Backpack spray exposures assume that workers on average treat a little more than four 

acres per day (ranging from 1.5 to 8 acres per day) and broadcast spray exposures assume that workers 

average 112 acres per day (ranging from 66 to 168 acres per day). For all scenarios, it is assumed that the 

workers do not receive any protection from exposure provided by clothing. 

Accidental worker exposures are most likely to involve splashing a solution of herbicides into the eyes or 

on the skin. Two general types of exposure are modeled: one involving direct contact with a solution of 

the herbicide and another associated with accidental spills of the herbicide concentrate onto the surface of 

the skin. Exposure scenarios involving direct contact with herbicide solutions are characterized by 

immersing unprotected hands for 1 minute or wearing contaminated gloves for 1 hour. Workers are not 

likely to immerse their hands in herbicide; however, the contamination of gloves or other clothing is 

possible. 

Exposure scenarios involving chemical spills onto the skin are characterized by a spill onto the lower legs 

as well as a spill onto the hands. In these scenarios, it is assumed that a solution of the chemical is spilled 

onto a given surface area of skin and that a certain amount of the chemical adheres to the skin.

The maximum rates proposed for use on the MBS were evaluated for this EIS. Most of the herbicides 

proposed for use under all alternatives have low potential to harm workers. In most cases, even when 

maximum rates and upper exposure estimates were considered, HQ values were below the threshold of 

concern (HQ values below 1). The only herbicide that resulted in HQ values that exceed 1 is triclopyr. 

Triclopyr is unique among the herbicides considered for this project in that it has two different 

formulations that are commonly used; a triethylamine salt (TEA) version and a butoxyethyl ester (BEE) 

version. This is relevant to human health risks because esters are much more readily absorbed through 

human skin than are amine formulations. Therefore, the risk analysis for triclopyr was conducted for both 

versions. 

For triclopyr, at the maximum application rates that could be used for this project, only one scenario 

exceeded HQ values greater than 1 at the central estimate. Triclopyr BEE at the central estimate of 

workers using contaminated gloves for an hour slightly exceeded the threshold of concern with an HQ of 

1.5. This is considered an accidental, rather than operational exposure, because it does not comply with 

standard safety practices. This is a small exceedance of the level of concern, but is still nearly 100 times 

less than the NOAEL and does not approach any known toxicity concern. No HQ greater than 1 was

calculated for workers using central estimates for triclopyr TEA.

In addition to herbicides, the contaminant HCB was quantitatively assessed. The cancer risk from all the 

worker operational exposures to HCB in picloram or clopyralid are at least two orders of magnitude 

below the risk standard of one chance in a million, which indicates an inconsequential risk. 

3.3.3.2 Public Herbicide Exposure Analysis 

The general public is unlikely to be exposed to high levels of any herbicides used in the implementation 

of this project. The SERA Risk Assessments considered several exposure scenarios including direct 

contact, consumption of sprayed vegetation, consumption of drinking water adjacent to a spray operation, 

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and consumption of fish in water adjacent to a spray operation. Accidental exposures including drinking 

water from a pond contaminated by a large spill were also considered. No reportable spills have occurred 

on similar projects in Region Six (Desser 2013).

Direct Contact: Exposure is quantified from direct spray and contact with sprayed vegetation scenarios.

At the maximum application rates proposed in any alternative, low risk to human health are indicated 

from direct contact. No scenarios for direct spray or contact with sprayed vegetation resulted in HQs 

greater than 1. The MR/MM include specific notification and posting requirements for administrative and 

recreation sites to further reduce the possibility of inadvertent direct spray of a member of the public. 

Indirect Contact: Quantitative estimates of exposure were conducted for an adult female swimming for 1 

hour in water contaminated by runoff from a treated 10-acre slope. All herbicides had HQs orders of 

magnitude below 1 for this scenario, indicating no plausible risk to the public from this exposure.

Eating Contaminated Vegetation or Fruit: The public could be exposed to herbicide if they eat 

contaminated vegetation or fruit after spraying, such as berries, mushrooms, or other plants. Directly 

sprayed plant materials would likely show signs of either dye or herbicide damage, reducing the 

likelihood they would be consumed. Non-target berries or mushrooms could also be contaminated by drift 

or uptake from the soil, which would result in lower herbicide residues than direct spraying. The R6 2005 

FEIS and the risk assessments considered both one-time acute exposure (eating 1 pound) and chronic 90 

day consumption scenarios for eating contaminated vegetation and fruit. These scenarios also 

approximate the effects of eating other contaminated products, such as mushrooms (Durkin and Durkin 

2005). At the central estimate, only triclopyr resulted in a HQ greater than 1 for either acute or chronic 

exposures from eating contaminated vegetation, berries or other forest products. For both the triclopyr 

TEA and BEE formulations, acute consumption of contaminated vegetation had an HQ of 6. 

Consumption of fruit did not exceed an HQ of 1. 

An additional analysis was done for triclopyr for public scenarios involving ingestion of contaminated 

food or water. Triclopyr has a metabolite, 3,5,6-trichloro-2-30 pyridinol (TCP), which is more toxic to 

mammals than triclopyr. TCP and its relevance to human health risk are discussed in detail in the 

Triclopyr Risk Assessment (SERA 2011). For TCP, acute consumption of contaminated vegetation is the 

only scenario that exceeded the threshold of concern, with an HQ of 1.8. Assuming dose addition for 

triclopyr and its metabolite, the total HQ for consumption of sprayed vegetation would be 7.8. 

The total HQ of 7.8 is based on reproductive risks to females. Adverse developmental effects in mammals 

have been observed during laboratory experiments at doses that cause obvious signs of maternal toxicity. 

No epidemiology studies or case reports have associated human exposures to triclopyr at proposed rates 

with maternal or developmental effects. 

Drinking Contaminated Water: Acute and long-term exposures from consumption of contaminated 

water were evaluated in the R6 2005 FEIS and the risk assessments. Risks from drinking contaminated 

water were evaluated for an accidental spill as well as water contaminated by runoff. The risk assessments 

also evaluated an accidental exposure scenario where a small child drinks 1 liter of water from a quarteracre pond, into which the contents of a 200-gallon tank that contains herbicide solution is spilled, 

immediately following a spill. 

No herbicides resulted in HQs greater than 1 for drinking contaminated water in either acute or chronic 

scenarios. All calculated HQs were many orders of magnitude below the threshold of concern. 

Consuming Contaminated Fish: Both acute and long-term exposure scenarios involving the 

consumption of contaminated fish were evaluated using the herbicide concentrations in the contaminated 

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water scenarios described above. Acute exposure was based on the assumption that an angler consumes 

fish taken from contaminated water shortly after an accidental spill into a pond. Chronic exposures were 

assumed to occur over a lifetime of eating contaminated fish. People who subsist on fish (for example 

Native American Indians) could have higher exposure rates than recreational anglers. However, based on 

a lifetime of subsistence fish consumption, no HQ values greater than 1 are associated with the herbicide 

use proposed in any alternative. 

The risk assessments for picloram (SERA 2011) and clopyralid (SERA 2004) also quantitatively assessed 

chronic risk from HCB for consumption of contaminated fish by subsistence populations. The HQ for 

carcinogenicity for picloram was 0.4; below the level of concern. Likewise, the HQ for clopyralid is 

below the level of concern (clopyralid has much less HCB than does picloram). 

The HQs for TCB for consumption of contaminated fish are all orders of magnitude below the level of 

concern, and do not approach 1, even if added to the HQs for triclopyr.

Summary

The response to quantitative results of HQ’s greater than 1 has been to more fully develop actions to limit 

and reduce the exposures that led to the increased risk. As required by herbicide labels, workers are 

expected to wear required PPE and follow standard industrial hygiene practices, like replacing gloves 

should they become contaminated. The R6 2005 ROD (MBS Forest Plan) prohibits broadcast spraying of 

triclopyr, which reduces the chance of non-target edible vegetation from becoming contaminated. Public 

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

sites would allow the public to avoid treated areas. In addition, triclopyr would not be applied to edible 

target plants (berries) when fruit are present. All relevant MR/MM are discussed below by alternative.

Surfactants or other adjuvants could be used according to label and Standard 18. Many surfactants could 

cause eye irritation. 

Table 27 shows HQ values greater than 1 for worker and public exposure scenarios. 

Table 27. Scenarios and herbicides where hazard quotients (HQ) exceeded 1.0 for human health. 

Exposure Scenarios HQ Central Estimates

Accidental– Worker Contaminated Gloves for 1 Hour Triclopyr BEE 

HQ = 1.5

Acute – Consumption of Contaminated Vegetation Triclopyr TEA & BEE

HQ = 6

Acute - Consumption of Contaminated Vegetation TCP

HQ=1.8

Endocrine Disruption

The potential for the proposed herbicides to cause endocrine disruption effects was addressed in each risk 

assessment. 

The United States Environmental Protection Agency has determined that there is no evidence to suggest 

that clopyralid or metsulfuron methyl has an effect on the endocrine system (SERA 2004). Based on the 

chronic bioassays and several additional subchronic bioassays in mice, rats, dogs, and rabbits, there is no 

basis for asserting that aminopyralid would cause adverse effects on the immune system or endocrine 

function (SERA 2007). No evidence for chlorsulfuron producing direct effects on the endocrine system 

was found (SERA 2004). 

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The glyphosate risk assessment (SERA 2011) stated that “some recent studies raise concern that 

glyphosate and some glyphosate formulations may be able to impact endocrine function through the 

inhibition of hormone synthesis (Richard et al. 2005; Benachour et al.2007a,b), binding to hormone 

receptors (Gasnier et al. 2009), or the alteration of gene expression (Hokanson et al. 2007)” (all references 

as cited in SERA 2011). Evaluation of the studies indicates that endocrine disruption effects were 

indicated for surfactants in the formulations rather than glyphosate itself. A commercial surfactant would 

be added to glyphosate when preparing the solution for application, but the surfactant type of choice is 

methylated seed oil/crop oil concentrate, which is typically a corn oil derivative and not implied in 

causing endocrine effects. No POEA or NPE based surfactants would be used. 

In the review of the mammalian toxicity data on imazapyr, U.S. EPA Office of Pesticide Programs

concluded that “there was no evidence of estrogen, androgen and/or thyroid agonistic or antagonistic 

activity shown.” SERA found that this conclusion was reasonable, based on their review of current 

information in the 2011 imazapyr risk assessment.

For imazapic, available toxicity studies have not reported any histopathologic changes in endocrine 

tissues that have been examined as part of the standard battery of tests. Extensive data are available on the 

reproductive performance and development of experimental animals exposed to imazapic indicates that 

effects occur at doses higher than that for effects to skeletal muscles. The RfD is based on the effect to 

muscles and should be protective of endocrine effects; HQ’s for Imazapic are orders of magnitude below 

1 and do not indicate any risk.

For picloram, a two-generation reproduction study in CD rats reported no endocrine effects at doses as 

high as 1000 mg/kg/day (SERA 2003). Endocrine effect endpoints examined in this study included 

reproductive outcomes, histopathological examination of tissues. Other studies reviewed in this risk 

assessment found no evidence for picloram producing direct effects on the endocrine system. 

Sulfometuron methyl appears to have the potential to produce changes in thyroid function at 100 

mg/kg/day (SERA 2004). No adverse effects on reproductive parameters were observed in rats exposed to 

dietary sulfometuron methyl at dietary concentrations up to 5000 ppm (Wood et al. 1980). The acute and 

chronic RfDs for sulfometuron methyl are 0.87 mg/kg for a decrease in maternal and fetal weight gain 

and 0.02 mg/kg for effects to blood parameters, respectively. The very low RfDs should encompass risks 

to thyroid function. Using those RfDs, all HQ’s for sulfometuron methyl were well below 1.0, and often 

orders of magnitude below 1. Considering available data and analysis results, there is no indication of a 

risk of endocrine effects from proposed use of sulfometuron methyl. 

Triclopyr has not undergone evaluation for its potential to interact or interfere with the estrogen, 

androgen, or thyroid hormone systems (i.e., assessments on hormone availability, hormone receptor 

binding, or post-receptor processing). However, extensive testing in experimental animals provides 

reasonably strong evidence that triclopyr is not an endocrine disruptor. No epidemiological studies of 

health outcomes of triclopyr have been reported, and there is no clinical case literature on human triclopyr 

intoxication. Several long-term experimental studies in dogs, rats, and mice have examined the effects of 

exposure to triclopyr on endocrine organ morphology, reproductive organ morphology, and reproductive 

function; treatment-related effects on these endpoints were not observed.

While the potential for the proposed herbicides to cause endocrine disruption effects is a current data gap, 

the potential for these effects are to actually occur are greatly reduced by measures such as required use of 

proper protective equipment, public notification, use of licensed applicators, limiting application rates and 

other relevant MR/MM. 

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Environmental Justice and Disproportionate Effects 

The R6 2005 FEIS noted that people of Hispanic/Latino descent and American Indians may be 

disproportionately exposed to herbicides because they are more likely to be forestry workers (herbicide 

applicators) than other groups. On the MBS, invasive plant treatments on the Forest are implemented in 

partnership with the local counties. Crews generally live in the communities in and around the Forest and 

are not associated with any discrete minority or low-income population. Herbicide treatment applicators 

are well trained in safe herbicide handling and transportation practices. The worker health analysis above 

applies to any herbicide applicator.

Effects to minority groups (such as American Indians) who or gather or use plants, animals or are the 

same as those evaluated above for public herbicide exposure. People gather special forest products such 

as blackberries, huckleberries, salal, mushrooms, ferns, bear grass, and herbs for personal use and 

commercial sale. Special forest product harvesters may have more contact with contaminated vegetation 

than the general public. An unpublished study of commercial permit holders on Pacific Northwest Forests 

reported that the largest ethnic groups involved with forest product gathering were Hispanics, and 

Southeast Asians. However, these groups are unlikely to be more affected by herbicide exposure than the 

results provided for the general public, given the assumptions in the public health analysis. Chronic 

exposures to some of the herbicides proposed for use exceeded a threshold of concern, but with the 

exception of triclopyr, HQ values were less than 1 for all but unlikely upper estimates (which are not 

realistic even for people who spend the most time gathering forest projects). Posting of treatment sites, 

especially if triclopyr is used, would be especially important in areas of special forest product or berry 

gathering. 

Multiple Chemical Sensitivity

The following information was adapted from USDA 2012, Gypsy Moth Management in the United 

States, a Cooperative Approach. 

Some people feel that they suffer from Multiple Chemical Sensitivity (MCS), which is sometimes 

referred to as Idiopathic Environmental Intolerances (IEI). In general, individuals with MCS report that 

they experience a variety of adverse effects as a result of very low levels of exposure to chemicals 

(including herbicides) that are generally tolerated by individuals who do not have MCS. 

Forest Service risk assessments incorporate an uncertainty factor of 10 to account for sensitive 

individuals, which may or may not eliminate risk that an individual may suffer symptoms. However, the 

uncertainty factor for sensitive individuals addresses variability in tolerances within a normal population. 

Individuals reporting MCS assert, either explicitly or implicitly, that they are atypically sensitive. There is 

no current consensus on the diagnosis and cause of MCS. 

Until the etiology and pathogenesis of MCS has been clarified, an organic cause of the MCS-associated 

symptoms and symptom complexes cannot be entirely ruled out. The Forest Service has no way to resolve 

concerns for MCS at the project level.

3.3.3.3 Direct and Indirect Effects of the Alternatives

Alternative 1 – No Action

Human health risks are very low for Alternative 1 given the small scale of treatment proposed, the limited 

suite of herbicides that are approved, the limitations on herbicide application methods and the MR/MM 

associated with the currently approved project. The MR/MM that serve to reduce risk of harmful 

herbicide/surfactant exposure to people include: 

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6. No broadcast spraying (aerial or boom) will occur. 

7. Any preparation, transport, or application of herbicide will be done by trained workers with a 

current Washington State pesticide applicators license.

8. Only the aquatic formulation of glyphosate will be used. 

9. If needed, the only surfactant that will be used is Agri-Dex®.

10. Pretreatment briefings will be conducted with all herbicide applicators to emphasize safety 

requirements. 

11. Materials Safety Data Sheets, and Forest Service Information covering glyphosate and AgriDex® must be carried in each vehicle at all treatment times, and made available to interested 

members of the public, on-site.

12. Glyphosate and Agri-Dex® containers must be secured and prevented from tipping during 

transport.

13. Workers will carry only enough herbicide daily to cover the proposed treatment for that day. 

14. Mix only the amount of solution needed to complete daily treatments. 

15. Workers will follow all herbicide label guidelines. 

16. Containment mats will be used during mixing, to further avoid the risk of a spill. 

18. When glyphosate (with Agri-Dex®) is administered via wand-backpack spray, hand wiped, or 

painted on cut stems, the applicator will use the lowest effective rate. 

21. No applications using wand-backpack spray will occur when wind speed exceeds five miles per 

hour, to lessen drift, or when precipitation is expected within 24 hours. 

24. Herbicide mixture (aquatic formulation of glyphosate with or without Agri-Dex®) will be colored 

with a bright, non-toxic vegetable dye before application. 

38. For any site where recreation use/activity is high and invasive plants are located other than along 

the peripheral....treatment will occur only during the week...Sites will be signed and flagged. 

These measures minimize or eliminate human health risks. Workers and the general public are unlikely to 

be exposed to herbicides above a threshold of concern. Drinking water would not be adversely affected. 

No triclopyr would be used. 

Alternative 2 – Proposed Action

Human health risks are low for Alternative 2. Although a greater variety of herbicides may be used and 

broadcast spraying is proposed, human health risks are minimal due to the type of herbicides proposed for 

use, the MR/MMs associated with treatment and the fact that HQ values greater than 1 are limited to 

upper worst case estimates and unlikely exposure scenarios. The use of aminopyralid is not associated 

with an HQ greater than 1, even for extreme or accidental exposure scenarios. 

Triclopyr is associated with the greatest risks to workers and the public, and is the only herbicide where 

“central” estimates indicate hazard quotients greater than 1. Triclopyr is currently the first choice 

herbicide for about 15 acres in Alternative 2. This indicates that triclopyr is less likely to be used than 

many of the other herbicides proposed. Over time, additional acres may be treated using triclopyr, 

however MR/MM would minimize risk of harmful exposure. The MR/MM that reduce risk of any 

harmful herbicide/surfactant exposure to people include: 

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1. Coordinate herbicide use within 1000 feet (slope distance) of known water intakes with the water 

user or manager. 

2. Coordinate herbicide use with Municipal Water boards. Herbicide use or application method may 

be excluded or limited in some areas.

3. Pretreatment briefings will be conducted with all herbicide applicators to emphasize safety 

requirements. 

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. 

6. Herbicide mixture will be colored with a bright, non-toxic vegetable dye before application. 

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.

8. An Herbicide Transportation and Handling Safety/Spill Response Plan would be the responsibility 

of the herbicide applicator. 

23. POEA surfactant would not be used. 

29. Herbicide use buffers have been established for perennial and wet intermittent steams; dry 

streams; and lakes and wetlands. See Table 10. 

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. 

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.

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. 

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. 

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.

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.

51. Triclopyr would not be applied to edible target plants (berries) when fruit are present. 

105 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Human Health

These measures, along with other MR/MM, Forest Plan standards and Forest Service pesticide use policy, 

minimize potential for worker and public exposure and risks would not be substantially increased over the 

No-Action Alternative. 

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 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. 

Alternative 3 

Human health risks for Alternative 3 are similar to Alternative 2, except that more acreage would likely 

be treated with triclopyr in lieu of aminopyralid. Triclopyr is the first choice herbicide for about 153 acres 

in Alternative 3. The MR/MM in this alternative are the same as for Alternative 2 and are likely to 

effectively mitigate for the few exposure scenarios that are over a threshold of concern for workers and 

the general public. 

Table 28 compares the potential impacts to worker and public health from herbicide use proposed in the 

alternatives. 

Table 28. Summary Table for Effects Related to Human Health and Herbicide Use 

Issue Alternative 1 Alternative 2 Alternative 3

Impact to Worker 

Health

No worker health 

concerns associated 

with use of herbicides 

in this alternative. 

The only herbicide that resulted in 

HQ values that exceed 1 is 

triclopyr. Triclopyr is the first 

choice herbicide for about 15 

acres in this alternative. MR/MM 

would mitigate for worker 

exposure to this herbicide. 

The only herbicide that resulted 

in HQ values that exceed 1 is 

triclopyr. Workers may be 

exposed to more triclopyr in this 

alternative because it is the first 

choice herbicide for 153 acres. 

MR/MM would mitigate for 

worker exposure to this 

herbicide.

Impact to Public 

Health 

Given the type and 

extent of herbicide 

use, and the MR/MM 

associated with this 

project, no harmful 

exposures are likely. 

Triclopyr is the only herbicide with 

HQ values greater than 1 at 

central estimates. However, given 

the type and extent of herbicide 

use, and the MR/MM associated 

with this project, no harmful 

exposures are likely. Aminopyralid 

is not associated with any harmful 

exposure scenarios and is the first 

choice for the majority of target 

species. 

Triclopyr is the only herbicide 

with HQ values greater than 1 

at central estimates. However, 

given the type and extent of 

herbicide use, and the MR/MM 

associated with this project, no 

harmful exposures are likely.

This alternative would use more 

triclopyr than the other 

alternatives. 

3.3.3.4 Cumulative Effects of All Alternatives

Workers and the public may be exposed to the herbicides used to treat invasive plants under all 

alternatives in this project. Cumulative doses are possible within the context of this project, or when 

combined with herbicide use on adjacent lands or home use by a worker or member of the general public. 

However, the risk is very small that a person would receive additive exposures during the time period in 

which the herbicide remained in their body.

The MR/MM, herbicide use buffers, and project caps for the action alternatives would apply to any 

herbicide use on the Forest, whether as a stand-alone project or in conjunction with other land uses (for 

106 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Human Health

instance treatment along a road intended to be used for a vegetation management project). The SERA 

Risk Assessments evaluated chronic exposure scenarios that would involve the public, including repeated 

drinking of contaminated water, repeated consumption of contaminated berries, and repeated consumption 

of contaminated fish. 

The potential for cumulative human health effects from any herbicide use proposed in this EIS, combined 

with other potential herbicide applications in the analysis area, would be encompassed in the health risks 

estimated for chronic exposure scenarios. These herbicides do not bio-accumulate in people and are 

rapidly eliminated from the body. Chronic (daily over 90-days) worker exposure was considered in SERA 

Risk Assessments and did not result in HQ values greater than 1 for any “central” estimate.

A person could be exposed to herbicides by more than one scenario; for instance, a person handling, and 

then consuming sprayed berries. The cumulative impact of such cases may be quantitatively characterized 

by adding the HQs for each exposure scenario. A MR/MM would restrict the use of triclopyr, the first 

choice herbicide for woody vegetation such as berries, to times when fruit is not present. Thus, this type 

of additive exposure is not likely. 

Chapter 3.1.6 describes the ongoing use of herbicides and other methods to treat invasive plants by other 

federal, state, and county agencies adjacent to the MBS. Of the known herbicide use on adjacent lands, 

some may pose greater risk to workers or the public than the herbicide use proposed for this project, 

especially on State Highways. However, the potential contribution to cumulative pesticide use by any 

alternative is not significant. The small and scattered nature of the infestations make it unlikely that 

exposures exceeding a level of concern would occur from simultaneous herbicide treatments on Forest 

Service and other lands. 

As noted previously, chronic exposure to triclopyr by workers is a concern. Triclopyr has been reportedly 

used by Mount Rainier National Park, Washington State Department of Natural Resources, Bonneville 

Power Administration, Washington State Parks, Washington State Department of Transportation, and 

King County. The MR/MM for this project minimize the potential for harmful exposures, however 

workers who may be applying triclopyr elsewhere are advised to limit their exposure (reduce hours of 

application per day or number of days in a row that this herbicide is used). 

The R6 2005 FEIS considered the potential for synergistic effects of exposure to two or more chemicals:

“Combinations of chemicals in low doses (less than one tenth of RfD) have rarely demonstrated 

synergistic effects. Review of the scientific literature on toxicological effects and toxicological 

interactions of agricultural chemicals indicate that exposure to a mixture of pesticides is more likely to 

lead to additive rather than synergistic effects (ATSDR, 2004; U.S.EPA/ORD, 2000). Based on the limited 

data available on chemical combinations involving the twelve herbicides considered in this EIS, it is 

possible, but unlikely, that synergistic effects could occur as a result of exposure to the herbicides 

considered in this analysis. Synergistic or additive effects, if any, are expected to be insignificant.”(R6 

2005 FEIS p. 4-3). 

Workers may be exposed to typical hazards from working in the woods from all treatment methods, 

especially those using chain saws and other motorized tools. Accidents are correlated with hours worked. 

3.3.4 Consistency with Regulations, Policies and Plans

All alternatives comply with standards, policies, and laws aimed at protecting worker safety and public 

health. This project would not result in disproportionate impacts to low income or minority groups. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Botany

3.4 Botany 

3.4.1 Introduction

The MBS contains a wide variety of plant species and plant communities including a vast network of 

riparian areas and wetlands, ranging from deeply shaded old-growth forests in the Western Hemlock 

Zone, to open meadows in the subalpine Parkland Zone (Henderson et al. 1992). The 51 Treatment 

Analysis Areas (TAA) include a wide range of natural communities; however, most of the infested acres 

occur in highly disturbed areas such as road shoulders. Invasive plant sites and botanical species of 

conservation concern may occur in the same vicinity; however invasive plants are not likely to overlap

occupied habitat for botanical species of conservation concern. Invasive plants are centered along roads, 

quarries, or other highly disturbed sites that are less likely to contain botanical species of conservation 

concern. 

The following section focuses on the risks of using aminopyralid (especially using the broadcast 

application method) near botanical species of conservation concern, since this information has not been 

considered in previous documents such as the R6 2005 FEIS and the MBS 2005 DN. This chapter also 

discusses the character and effectiveness of Management Requirements and Mitigation Measures

(MR/MM) intended to minimize or eliminate risk to botanical species of conservation. 

Many laws, regulations and policies provide management direction for protection of botanical species of 

conservation concern. The 1990 MBS Forest Plan, the 1991 M.O.U. between Region 6 and the 

Washington State Department of Agriculture for the management of invasive plants (RCW 17.10), the 

1994 Northwest Forest Plan, the R6 2005 ROD, and the MBS 2005 DN all provide vegetation 

management direction specific to this project. 

Potential conflicts between invasive plant treatments and botanical species of conservation concern were 

determined through a Geographical Information System (GIS) analysis. Botanical species of conservation 

concern were identified and overlain with known infestations. Known sites for botanical species of 

conservation concern are based on field surveys that are assumed to have been conducted in suitable 

habitats where ground disturbing projects have been proposed. . The surveys are documented in the US 

Forest Service Natural Resource Inventory System (NRIS) database. Surveys for are generally not 

conducted within road prisms (including cut and fill slopes) because suitable rare plant habitat is not 

present in these areas. 

This EIS herby incorporates by reference the Botany Specialist Report (40 CFR 1502.21). The Botany 

Specialist Report is located in the Project Record and contains the detailed data, tables, maps, Affected 

Environment, analysis, references, reports, and technical documentation supporting the conclusions in this 

section of the EIS. 

3.4.2 Affected Environment 

Eleven invasive plant target species pose the greatest threat to native plant habitats of concern on the 

MBS (see Table 29 below). 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Botany

Table 29. Invasive Plants that Pose the Greatest Threat to Native Plant Habitats of Concern

Common Name Native Plant Habitat of Concern

Bittersweet nightshade Riparian areas/wetlands

Butterfly bush Riparian areas/wetlands

English holly Lower elevation deciduous/coniferous forest, including oldgrowth forests

English ivy Lower elevation deciduous/coniferous forest, including oldgrowth forests

Hawkweed- Non-native (common, orange, yellow, 

spotted, smooth)

Mid-montane to subalpine meadows

Herb Robert Lower elevation deciduous/coniferous forest, including oldgrowth forests

Knotweed (Bohemian, giant, Japanese) Riparian areas/wetlands

Spotted knapweed Mid-montane to subalpine meadows

Sulphur cinquefoil Mid-montane to subalpine meadows, talus slopes

Tansy ragwort Mid-montane meadows

Yellow archangel Lower elevation deciduous/coniferous forest, including oldgrowth forests

Currently, surveys for 56 botanical species of conservation concern are conducted whenever suitable 

habitat is suspected and habitat disturbing management projects are proposed. Protection is required for 

302 species if they are discovered, even though most are not targeted for surveys. No botanical species 

are federally listed as threatened, endangered or proposed for listing. 

Forest Service Sensitive Plants include vascular plants, bryophytes, lichens, and fungi on the December 

2011 Regional Forester’s Sensitive Species List. Survey and Manage plants (hereafter referred to as S&M 

plants) include vascular plants, bryophytes, lichens, and fungi in the 2001 Record of Decision for 

Amendments to the Survey and Manage, Protection Buffer and other Mitigation Measures Standards and 

Guidelines. Two botanical species of conservation concern have been identified by Washington state: 

boreal jewelweed (Impatiens noli-tangere), is listed as Threatened, and yellow sedge (Carex flava), is 

listed as Sensitive by the Washington Natural Heritage Program. In addition, one additional S&M species 

not on the 2001 list but on the 2003 and 2011 S&M species lists) is discussed: Nephroma bellum.

Information about botanical species that do not overlap with TAAs can be found in the Botany Specialist 

Report and Biological Evaluation. The report also includes lists of botanical species of conservation 

concern that may occur, but have not been documented on the MBS. 

Table 30 displays the botanical species of conservation concern within TAAs.

Table 30. Botanical Species of Conservation Concern Within 30 feet of Invasive Plant Treatment Analysis 

Areas 

TAA 

# 

Sensitive or S&M Plant

Scientific Name, Plant Code, Listing Status and 

NRIS ID

Rare Plant Site 

Name

Weed Common Name, 

Plant Family, NRIS ID

2 Pseudocyphellaria rainierensis. PSRA3. S&M category 

A (manage all known sites). NRIS # 6050500359. 

Upper White Thin 

Unit 14

Canada thistle. 

Asteraceae. NRIS # 

6050500262

2 Peltigera pacifica. PEPA48. S&M category E (manage 

all known sites). NRIS # 6050500372

Upper White Thin 

Unit 28

Bull thistle. Asteraceae. 

NRIS # 06050500330

2 Peltigera pacifica. PEPA48. S&M category E (manage Upper White Thin Bull thistle. Asteraceae. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Botany

TAA 

# 

Sensitive or S&M Plant

Scientific Name, Plant Code, Listing Status and 

NRIS ID

Rare Plant Site 

Name

Weed Common Name, 

Plant Family, NRIS ID

all known sites). NRIS # 6050500376 Unit 34 NRIS # 06050500346

11

Galium kamtschaticum. GAKA. S&M category A 

(manage all known sites) south of Snoqualmie Pass 

only24. NRIS # 6050500005

Denny Creek Rec. 

Residence #4

Yellow archangel. 

Lamiaceae. 

NRIS # 05-TF-023

11

Galium kamtschaticum. GAKA. S&M category A 

(manage all known sites) south of Snoqulmie Pass 

only. NRIS # 6050500302

Denny Creek Road

Dalmation toadflax. 

Scrophulariaceae. 

NRIS # 05-LP-083

16 Peltigera pacifica PEPA48. S&M category E (manage 

all known sites). NRIS # 6050600050 Eagle Ck

Herb Robert. 

Geraniaceae. NRIS # 

6050600059

16 Nephroma bellum. NEBE60. S&M category E (manage 

all known sites). NRIS # 6050600051 Eagle Ck

Herb Robert. 

Geraniaceae. NRIS # 06-

KW-012

16 Nephroma bellum. NEBE60. Concern. NRIS # 

6050600054 Eagle Ck

Herb Robert. 

Geraniaceae. NRIS # 06-

KW-012

16 Nephroma bellum. NEBE60. Concern. NRIS # 

6050600106 Beckler Thin Unit #51

Tansy ragwort. 

Asteraceae. NRIS # 06-

KW-011

16 Nephroma bellum. NEBE60. Concern. NRIS # 

6050600106 Beckler Thin Unit #51

Herb Robert. 

Geraniaceae. NRIS # 

6050600162

16

Platanthera orbiculata var. orbiculata. PLOR4. S&M 

category C (manage high priority sites). NRIS # 

USFS0600-EO-00543-50200055

Beckler Thin Unit 51 Bull thistle. Asteraceae. 

NRIS # 6050600165

19

Platanthera orbiculata var. orbiculata. PLOR4. S&M 

category C (manage high priority sites). NRIS # 

USFS0600-EO-27197_1816500

Trouble-some Ck 

Camp-ground

Common hawkweed. 

Asteraceae. 

NRIS # 06-KW-008.

23 Fritillaria camschatcensis. FRCA5. Sensitive. NRIS # 

6050200006 Beaver Creek

Orange hawkweed. 

Asteraceae. 

NRIS # 02-LP-004.

23 Fritillaria camschatcensis. FRCA5. Sensitive. NRIS # 

6050200174 Big Four

Orange hawkweed. 

Asteraceae.

NRIS # 02-LP-004.

23 Fritillaria camschatcensis. FRCA5. Sensitive. NRIS # 

6050200174 Big Four

Orange hawkweed. 

Asteraceae.

NRIS # 6050200045

23 Fritillaria camschatcensis. FRCA5. Sensitive. NRIS # 

6050200174 Big Four

Common hawkweed. 

Asteraceae. 

NRIS # 6050200051

34 Carex magellanica. CAMA7. WA-Sensitive. NRIS # 

6050100076 Cumberland Pass

Meadow hawkweed. 

Asteraceae. 

NRIS # 10-AR-079.

24 GAKA is in S&M category A (manage all known sites) south of Snoqualmie Pass (i.e. Interstate 90). The Denny 

Creek site is more or less at the I-90 dividing line, and could be genetically important because it is the almost the 

southernmost population in the range of the species. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Botany

TAA 

# 

Sensitive or S&M Plant

Scientific Name, Plant Code, Listing Status and 

NRIS ID

Rare Plant Site 

Name

Weed Common Name, 

Plant Family, NRIS ID

34 Carex magellanica. CAMA7. WA-Sensitive. NRIS # 

6050100242. Cumberland Pass

Meadow hawkweed. 

Asteraceae. 

NRIS # 10-AR-079.

38

Hypogymnia duplicata. HYDU. S&M category A 

(manage high priority sites). NRIS # 

060501EO_ECOPLOT0605-33021

0605-33021

Herb Robert. 

Geraneaceae. NRIS # 01-

AR-080.

43

Platanthera orbiculata var. orbiculata. PLOR4. S&M 

category C (manage high priority sites). NRIS # 

6050100030

Baker Lake Rd

Canada thistle. 

Asteraceae. NRIS # 01-

JA-006.

43 Carex flava. CAFL4. Concern. NRIS # 6050100085 and 

# 6050100134

Near Baker River 

Inlet into Baker Lake

Reed canarygrass. 

Poaceae. 

NRIS # 01-LP-027

44 Gentiana glauca. GEGL. R6 Sensitive. NRIS # 

6050100100 Skyline Divide

Canada thistle. 

Asteraceae. 

NRIS # 01-AR-011.

45 Cetrelia cetrarioides. CECE4. S&M category E 

(manage all known sites). NRIS # 6050100049

North Fork Nooksack 

River, stream gage

Bohemian knotweed. 

Polygonaceae. 

NRIS # 01-AR-065.

45 Cetrelia cetrarioides. CECE4. S&M category E 

(manage all known sites). NRIS # 6050100073

North Fork Nooksack, 

across from Douglas 

fir CG

Herb Robert. 

Geranicaceae. 

NRIS # 01-AR-001.

45 Cetrelia cetrarioides. CECE4. S&M category E 

(manage all known sites). NRIS # 6050100073

North Fork Nooksack, 

across from Douglas 

fir CG

Tansy ragwort. 

Asteraceae. 

NRIS # 01-LP-001.

45 Impatiens noli-tangere. IMNO. Concern. NRIS # 

6050100144

Glacier Public 

Service Center

Japanese sweet coltsfoot. 

Asteraceae. 

NRIS # 01-AR-055. 

45 Impatiens noli-tangere. IMNO. Concern. NRIS # 

6050100144

Glacier Public 

Service Center

Herb Robert. 

Geraniaceae. 

NRIS # 01-AR-056. 

3.4.3 Environmental Consequences

All invasive plant treatment methods have the potential to damage individual non-target plants. Manual, 

cultural and use of biological control agents pose the least risk of adverse effects to non-target vegetation. 

Mechanical treatment poses slightly more risk to non-target plants than manual. Herbicide risk depends 

on the herbicide used, application method and distance from non-target plants. 

In this project, the differences between alternatives regarding risk from invasive plant treatment to nontarget plants are not significant. While some non-target vegetation may be damaged, removed or killed 

due to invasive plant treatments in all alternatives, the MR/MM associated with the project would 

minimize the extent, magnitude, and duration of these impacts. Thus, none of the alternatives would cause 

loss of viability or cause a significant trend toward listing for any botanical species. 

The risk to native plant communities from competition from invasive plants is greater than the risk of 

treatment. The net effect of all alternatives would be positive due to the removal of invasive plants that 

threaten native vegetation. Alternative 1 is the least cost-effective alternative (see Chapter 3.2). This 

means that the threats to native vegetation from invasive plants are greatest in this alternative. The more 

111 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Botany

quickly invasive plants can be controlled, the better the chances for long-term survival and viability of 

native plant communities, including botanical species of conservation concern. 

Alternatives 2 and 3 allow for a greater variety of herbicides to be used and include the broadcast method 

of application. Broadcast spray poses the greatest risk to non-target plants compared to other treatment 

methods because the area affected tends to be larger and there is greater potential for overspray and drift 

than spot or hand treatments. In Alternatives 2 and 3, broadcast spraying is proposed within TAAs # 2, 11, 

15, 19, 23, 34 and 38 where botanical species of conservation concern have been found. 

The differences in potential effects are most important in three treatment analysis areas where hawkweed 

grows close to botanical species of conservation concern. In TAA 19, common hawkweed grows in close 

proximity to Platanthera orbiculata var orbiculata (Orchidaceae family). Alternative 2 would be more 

effective and less risky than Alternatives 1 or 3 because the use of aminopyralid is effective on hawkweed 

but does not affect members of the Orchidaceae family. Alternatives 1 and 3 allow fewer options for 

effective treatment, especially within close proximity to water. Glyphosate is non-selective and thus poses 

some risk to this species in Alternatives 1 and 3. In TAA 23, hawkweed grows near four Fritillaria 

camschatcensis (Lilliaceae family) sites. Alternative 2 would be more effective and less risky than 

Alternatives 1 or 3 because the use of aminopyralid is effective on hawkweed but does not affect 

members of the Lilliaceae family. Alternatives 1 and 3 allow fewer options for effective treatment, 

especially within close proximity to water. Glyphosate is non-selective and thus poses some risk to this 

species in Alternatives 1 and 3. 

In TAA 34, hawkweed grows near Carex magellanica (Cyperaceae family, grass) in two locations in close 

proximity to water. Glyphosate is non-selective and thus poses some risk to this species in Alternatives 1 

and 3. Aminopyralid is the first year/first choice herbicide for hawkweed under Alternative 2. 

Aminopyralid does not target grass species, so Alternative 2 would likely pose less risk than the other 

alternatives. 

Site-specific mitigation measures have been developed for botanical species of conservation concern that 

are within 30 feet of infested areas (Table 31). This is a subset of the locations shown in Table 30, which

list botanical species of conservation concern that are in TAAs but are not close to infested sites. 

Table 31 lists the MR/MM that would be applied to each of these sites. Botanical species of conservation 

concern would be protected in all alternatives assuming these measures are followed. 

Table 31. Mitigation for botanical species of conservation concern within 30 feet of treatment sites

TAA # Site Name Rare plant scientific name 

and NRIS ID

Invasive plant 

common name 

and NRIS ID

Site Specific Prescription

2 Upper White

Thin Unit 28

Peltigera pacifica (PEPE50) 

6050500372

Bull thistle 

06050500330

Measures B2 and B4. In addition, log 

where the PEPE50 grows should be 

flagged and any thistles within 5 feet of 

this lichen should be hand pulled.

11

Denny 

Creek Rec. 

Residence 

#4

Galium kamtschaticum

(GAKA) 6050500005

Yellow 

archangel

05-TF-023

Measures B2, B4. Because GAKA 

almost always grows in saturated soils, 

item B6 applies here. In addition, any 

yellow archangel within 5 feet of the 

GAKA should be hand pulled.

16 Eagle Creek Peltigera pacifica (PEPE50) 

6050600050

Herb Robert 

(GERO) 

6050600059

Measures B2 and B4. In addition, site 

where the PEPE50grows should be 

flagged and any herb Robert within 5 

feet of this lichen should be hand pulled.

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Botany

TAA # Site Name Rare plant scientific name 

and NRIS ID

Invasive plant 

common name 

and NRIS ID

Site Specific Prescription

16 Beckler Thin 

Unit 51

Nephroma bellum 

(NEBE60) 6050600106

Herb Robert

6050600162

Measures B2 and B4. In addition, site 

where the NEBE60 grows should be 

flagged and any herb Robert within 5 

feet of this lichen should be hand pulled.

23 Beaver 

creek

Fritillaria camschatcensis

(FRCA5)

6050200006

Orange 

hawkweed

02-LP-004

See B2. Under B4, this treatment is 

acceptable to within 30 feet of the 

FRCA5 but there is concern about 

mechanical damage if boom height is 

lower than FRCA5 height. Also FRCA5 

frequently grows in saturated soils (see 

B6). Flag individual FRCA5 in springtime 

when they are in flower. Since 

hawkweed is not effectively controlled by 

hand-pulling, apply aminopyralid by 

hand methods within 10 feet of FRCA5. 

Botanist must be on site during 

treatments. 

23 Big Four

Fritillaria camschatcensis

(FRCA5)

6050200174

Orange 

hawkweed

02-LP-004

Same weed site, different rare plant 

location as previous row. See B2. Under 

B4, this treatment is acceptable to within 

30 feet of the FRCA5 but there is 

concern about mechanical damage if 

boom height is lower than FRCA5 

height. Also FRCA5 frequently grows in 

saturated soils (see B6). Flag individual 

FRCA5 in springtime when they are in 

flower. Since hawkweed is not 

effectively controlled by hand- pulling, 

hand-apply aminopyralid within 10 feet 

of FRCA5. Botanist must be on site 

during treatments. 

23 Big Four

Fritillaria camschatcensis

(FRCA5)

6050200174

Orange 

hawkweed

6050200045

B2. Flag individual FRCA5 in springtime 

when they are in flower. FRCA5 

frequently grows in saturated soils (see 

B6). Flag individual FRCA5 in springtime 

when they are in flower. Since 

hawkweed is not effectively controlled by 

hand pulling, hand apply aminopyralid 

within 10 feet of FRCA5. Botanist must 

be on site during treatments.

23 Big Four

Fritillaria camschatcensis

(FRCA5) 

6050200174

Common 

hawkweed 

6050200051

B2. Under B4, this treatment is 

acceptable to within 30 feet of the 

FRCA5 but there is additional concern 

about mechanical damage if boom 

height is lower than FRCA5 height. Also 

FRCA5 frequently grows in saturated 

soils (see B6). Flag individual FRCA5 in 

springtime when they are in flower.

Since hawkweed is not effectively 

controlled by hand pulling, hand apply 

aminopyralid within 10 feet of FRCA5. 

Botanist must be on site during 

treatments.

38

Finney 

Creek 

bridge

Hypogymnia duplicata 

(HYDU60) 

060501EO_ECOPLOT0605-

Herb Robert

01-AR-80

B2. Per B4 – spot spray glyphosate if 

within 30’ of the HYDU60. Hand-pull all 

Herb Robert within 5 foot radius of the 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Botany

TAA # Site Name Rare plant scientific name 

and NRIS ID

Invasive plant 

common name 

and NRIS ID

Site Specific Prescription

33021 Hypogymnia. 

43 Baker Lake 

inlet

Carex flava

(CAFL4) 

0605010008 & 

60501001345 

Reed 

canarygrass

01-LP-027

Site specific mitigation is detailed in a 

stand-alone management and 

monitoring strategy for CAFL4, Article 

#510 under Puget Sound Energy Baker 

River hydroelectric relicensing project. 

45

Mt. Baker 

Highway 

542

Impatiens noli-tangere 

(IMNO)

6050100144

Reed 

canarygrass

01-LP-027

Glyphosate acceptable to within 30’ from 

IMNO. Dig all Japanese sweet coltsfoot 

within 30’ of IMNO and around plants 

themselves. Botanist must be on site 

during treatments.

45

Mt. Baker 

Highway 

542

Impatiens noli-tangere 

(IMNO)

6050100144

Reed 

canarygrass

01-LP-027

Glyphosate acceptable to within 30’ from 

IMNO. Hands pull all herb Robert within 

30’ of IMNO and around plants 

themselves. Botanist must be on site 

during treatments.

3.4.3.1 Effects on Non-target Vegetation under EDRR

All alternatives, including No Action, allow for treatment of new invaders. In all alternatives, an 

individual rare plant may be damaged or die. Effects on non-vascular 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 are 

intended to provide a high degree of protection for botanical species of conservation concern. The design 

of the project minimizes the potential for native plants to be adversely affected. 

Table 32 displays characteristics of the 10 herbicides proposed for use that have influence on potential 

impact to rare plants, and which of these may be used in each alternative. Appendix C displays the 

botanical species of conservation concern likely to be found on the MBS and whether or not the 

herbicides proposed for use could adversely affect that species. 

Table 32. Non-target Plant Considerations for the 10 Herbicides Proposed For Use in Alternative 2 

Herbicide Non-target Plant Considerations Applicable 

Alternative

Aminopyralid Targets Asteraceae, Fabaceae, Polygonaceae, Solanaceae 

plant families 2 

Chlorsulfuron Protect individual plants from direct spray, drift, runoff, wind 

erosion 2, 3

Clopyralid Targets Asteraceae, Fabaceae, Polygonacea, Solanaceae 

plant families 1, 2, 3

Glyphosate Non-selective; protect from direct spray; runoff not a concern. 1, 2, 3

Imazapic Protect from direct spray, drift, runoff & timing after use of 

other herbicides 2, 3

Imazapyr Non-selective; protect plants from direct spray, drift, runoff 1, 2, 3

Metsulfuron methyl Protect individual plants from direct spray, drift, runoff, wind 

erosion.

1 (Skiyou Island only), 

2, 3

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Herbicide Non-target Plant Considerations Applicable 

Alternative 

Picloram

Targets Asteraceae, Fabaceae, Polygonaceae, Solanaceae 

plant families. Protect from direct spray drift, runoff. 

Scrophulariaceae, Brassicacea, and Liliaceae less 

susceptible. Grasses not affected.

2, 3

Sulfometuron methyl Non-selective; Protect plants from direct spray, drift, runoff, 

wind erosion 2, 3

Triclopyr Effective on woody plants. R6 2005 FEIS limits use of 

triclopyr to selective application techniques 2, 3

3.4.3.2 Cumulative Effects (All Alternatives)

The following assumptions apply to the Botany Cumulative Effects Analysis:

Invasive plants will spread at a rate of 4-12 percent over the life of the project. Effective treatment 

will reduce the acreage subject to spread. Prevention will slow but not stop spread. Some 

introductions and events are not controllable. 

Agricultural land managers and other neighbors (BLM, Park Service, County and State) are 

effectively managing invasive plants and helping to prevent their spread to National Forest. 

The spatial extent of the analysis area for cumulative effects on the botanical resources is the 52 

Treatment Analysis Areas. 

The temporal extent of cumulative effects on non-target vegetation is the duration of the invasive 

plant treatment period. 

The treatment period is usually from 1 to 5 years, depending on the site. 

Non-target vegetation could potentially be impacted within a 15-foot radius of spot treatments 

when a non-selective herbicide is used. Non-target vegetation could potentially be impacted within 

a 100 foot radius of broadcast treatments when a non-selective herbicide is used. The loss of nontarget vegetation from incidental treatment impact is less than displacement (loss) of non-target 

vegetation from competition from invasive plants. 

The more acres of invasive plants treated both on and off National Forest System land, the more nontarget plant damage and mortality is possible, especially from broadcast spraying. However, given the 

MR/MMs and buffers, potential for direct and indirect effects to non-target plants from invasive plant 

treatments in any alternative is low, even when the potential actions on land of other ownerships are 

considered. The potential negative effects of past, present and foreseeable future treatments on non-target 

plants, when combined with the effects of any of the alternatives, would be minor and short term. 

In younger forest plantations, developing forest canopy will eventually shade out shade-intolerant species 

such as tansy ragwort that thrive in full sun. However, without treatment, during the decades it takes for 

forest shade to recover, invasive plants could continue to spread, often beyond the boundaries of the 

plantations. 

The road system on the MBS has been shrinking over time in conjunction with a decline in funding for 

maintenance. Closed roads will eventually be decommissioned or revegetate naturally over time, thus 

reducing their susceptibility to invasive plant infestations. Ongoing and reasonably foreseeable future 

(Forest Service) actions would be subject to MBS Forest Plan standards guidelines. Currently these 

standards direct that project impacts be evaluated and described during environmental analysis. Forest 

Service policy is not to approve projects where the effects to botanical species of conservation concern 

would create a trend toward federal listing (under the ESA) or cause a loss of population viability. 

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Recently completed projects on the MBS include closing and restoring roads; road construction, 

reconstruction and maintenance; vegetation management (mainly thinning); and recreation development 

and maintenance. These projects occur within treatment analysis areas mapped within the project area 

(TAA 4, 15, 19, 23, 26, 27, 41, 43, 44, and 45) where invasive plant treatment sites occur within or near 

the recently completed projects. 

Several projects are currently being implemented or are ongoing on the MBS. These include mining; a 

variety of recreation projects; road repair, closure, reconstruction/improvement, decommissioning and 

maintenance; stream restoration; and vegetation management (thinning and created openings). Projects 

are being implemented in TAA 2, 3, 4, 5, 6, 11 15, 16, 17, 20, 23, 27, 30, 32, 33, 36, 41, 43, 45, 47, 49 and 

53. 

Several projects are planned to be implemented in the foreseeable future. These include recreation and 

site maintenance; road closure, repair and reconstruction; vegetation management (mainly thinning and 

some created openings) and stream restoration. The projects overlap invasive plant treatments proposed in 

TAA 2, 4, 6, 11 14, 19, 23, 32, 33, 38, 32, 43, and 45 and may last for several years. 

The recent past, current, ongoing and foreseeable future projects listed in Appendix F were reviewed to 

determine whether they might have impacts on botanical species of conservation concern that could 

combine with the impacts of this project. The focus of this analysis is areas that may be broadcast sprayed 

since this is where the likelihood of drift is greatest. Examples of recent past, on-going or foreseeable 

projects that overlap areas that may be potentially broadcast sprayed include: TAA # 2 (Upper White 

River Vegetation and Restoration Project), TAA 11 (Denny Creek Franklin Falls trails and parking lot), 

TAA 15 (Geothermal Exploration and the Stevens Pass Master Plan Development) TAA 19 (Beckler 

Thin), TAA 23 (Mountain Loop Scenic Byway Trailhead Enhancements), TAA 34 (Segelsen Ridge 

Huckleberry Enhancement), and TAA 38 (Finney AMA Timber Project). All of the projects have been or 

would be designed to protect botanical species of conservation concern. Monitoring has demonstrated that 

mitigation associated with current and/or completed projects has effectively protected botanical species. 

Thus, the potential for cumulative effects to botanical species of conservation concern is low to nonexistent, and the magnitude of adverse impacts would be minor. 

Recreation 

The low intensity of the disturbance related to recreation activities and maintenance of recreation sites 

generally have had limited impact on botanical resources of concern. However, recreation activities can 

be vectors of invasive plant spread and are likely new areas that will be detected and need to be treated 

through the life of the project. 

The impacts of repeated treatments would not likely accumulate because the MR/MM associated with 

invasive plant treatment would limit the extent, duration and intensity of impacts. Invasive plant 

populations would become smaller each treatment entry, so the risk to botanical resources from repeated 

treatments would tend to decline. The MR/MM along with monitoring and native plant restoration 

associated with the project would be expected to help reduce the potential for re-infestation over time.

Vegetation Management

Vegetation management can result in light to heavy ground disturbance depending on the type of project. 

These projects can have both positive and negative effects on non-target vegetation. Botanical species of 

conservation concern would be protected through design features and layout, reducing the potential for 

impacts to botanical species of conservation concern. Impacts would be incidental and limited to 

individual plants rather than populations. 

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Logging sites have historically been areas where invasive plants have become established, primarily 

because MR/MM associated with invasive plants was not consistently included in NEPA documents or 

contract specifications in the 1980s and early 1990s. Since then, prevention measures reduce the potential 

for these projects to result in the spread of invasive plants. Treatment of invasive plants prior to ground 

disturbance and other measures (such as washing equipment and using weed free mulch) help limit the 

potential for spread. Should invasive plants be introduced in vegetation management project areas, the 

impacts of repeated treatments would not likely accumulate because the MR/MM associated with 

invasive plant treatment limit the extent, duration and intensity of impacts. The impacts of repeated 

treatments of currently known infested areas would likely be smaller in extent than initial treatments since 

invasive plant populations are expected to decline.

Road Repair, Reconstruction and Maintenance 

Road repair, reconstruction and maintenance is ongoing and can be a vector for invasive plant spread if 

equipment picks up invasive plant materials and moves them to non-infested areas. Prevention measures 

are intended to reduce this risk. Road maintenance can damage desirable non-target plants, however 

roadside vegetation growth is generally very vigorous and damage to forbs, shrubs and deciduous trees 

(such as red alder or cottonwood) is short lived. Botanical species of conservation concern are far less 

likely to occur within the road prisms than other areas. Thus there is low likelihood that road maintenance 

projects would combine with invasive plant treatments and cause a cumulative impact to rare plants.

Road Closure and Restoration

The initial activities associated with road closure and restoration may be ground disturbing, however 

prevention measures such as inventorying and treating invasive plants before the roads are closed, 

washing equipment, and use of weed-free mulch and revegetation with native plants would reduce the risk 

of introducing invasive plants. Road closure and restoration would reduce the potential for invasive plant 

spread over time. The likelihood of cumulative impacts to botanical species of conservation concern from 

invasive plant treatment combined with road closure and restoration is low. 

Stream Restoration Projects

As with road closure, the initial activities associated with stream restoration such as building structures or 

removing culverts may be ground disturbing but prevention measures such as inventorying and treating 

invasive plants before the project is implemented, washing equipment, and use of weed-free mulch, and 

revegetation with native plants would reduce the risk of introducing invasive plants. 

Land Management Adjacent to the MBS

Of all the types of activities and projects listed above, activities or projects associated with adjacent land 

management may be the most likely to contribute towards cumulative effects on non-target vegetation. 

This is because R6/MBS Forest Plan direction and mitigation does not apply to activities outside the 

Forest. Chapter 3.1.6 describes what is known about herbicide use adjacent to the MBS National Forest 

boundary. These treatments are unlikely to affect invasive plants within the TAAs but may have impacts 

on botanical species of conservation concern outside the MBS. The extent of possible effects on botanical 

species of conservation concern outside the project area is not known. 

The MBS coordinates with adjacent land owners to reduce impacts of their actions on invasive plant

spread and non-target vegetation. The MBS participates in 7 Cooperative Weed Management Areas 

(CWMAs) including the Green-Duwamish CWMA, Middle Fork Snoqualmie CWMA, Skagit CWMA, 

Skykomish CWMA, Stillaguamish CWMA, and Yakima CWMA (which includes Snoqualmie Pass Ski 

Area and several other areas west of the Cascade crest). 

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Most populations of botanical species of conservation concern are too distant from National Forest to be 

affected by actions off the national forest. Drift associated with herbicide treatments near National Forest 

is possible, and adjacent land owners would not necessarily add as many layers of caution to herbicide 

use; however, the analysis assumes all herbicide use would conform to label guidance. The risks to nontarget vegetation and botanical species of conservation concern from treatments off forest would be 

outweighed by the benefit of reducing invasive plant populations adjacent to National Forest System 

lands 

3.4.4 Consistency with Regulations, Policies and Plans

All of the alternatives are consistent with the MBS Forest Plan (amended) and other laws and regulations 

regarding protection of botanical resources. Alternative 1 does not utilize all of the herbicides available 

for use and thus misses opportunities for more effective treatments. In addition, all alternatives comply 

with the Northwest Forest Plan, as amended (USDA, USDI 1994). The Survey and Manage mitigation 

measure from the Northwest Forest Plan has been litigated and modified since 1994. All alternative 

comply with the most recent Settlement Agreement (April 25, 2013). 

3.5 Wildlife 

3.5.1 Introduction

The Mt. Baker-Snoqualmie National Forest (MBS) provides diverse habitats, ranging from subalpine 

forest to wet meadows, and from late-successional temperate rainforest of Douglas-fir, hemlock and cedar 

to mixed conifer plantations, for a diverse array of wildlife species, including amphibians and reptiles. 

The MBS is located within the Pacific Flyway, which is a major migratory route for thousands of birds. 

Many species that are not permanent residents on the Forest may be found here during migration.

The MBS provides important wildlife habitat for one federally listed endangered species and three 

federally listed threatened species. One candidate species occurs on the Forest.

Invasive plant species have become established on the MBS and continue to spread, which may impact

wildlife habitat and pose a risk of injury to wildlife. Methods used to treat invasive plants have the 

potential to have adverse effects to individual animals as well as wildlife habitat. The following wildlife 

analysis focuses on potential effects of treatment on terrestrial Species of Local Interest including Survey 

and Management species; Listed and Proposed Threatened and Endangered Species, Regional Forester 

Sensitive Species and Management Indicator Species (MIS). Effects on MIS species indicate welfare of 

other species using the same habitat (Thomas 1979). Birds of Conservation Concern are also discussed. 

This EIS herby incorporates by reference the Wildlife Specialist Report (40 CFR 1502.21). The Wildlife 

Specialist Report is located in the Project Record and contains the detailed data, tables, maps, affected 

environment, analysis, references, reports, and technical documentation that the project ID Team’s

Wildlife Biologist relied upon to reach the conclusions in this EIS. 

3.5.2 Affected Environment

3.5.2.1 Invasive Plants and Wildlife Habitat

Some wildlife species utilize invasive plants for food or cover. For example, American goldfinch 

(Carduelis tristis), and red-winged blackbird (Agelaius phoeniceus) utilize purple loosestrife (Kiviat

1996; Thompson, Stuckey, and Thompson 1987), and native bighorn sheep will utilize cheatgrass (Csuti 

et al. 2001). It has been reported that elk, deer and rodents eat rosettes and seed heads of spotted 

knapweed. However, the few uses that an invasive plant may provide do not outweigh the adverse 

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impacts to an entire ecosystem (Zavaleta 2000). More detailed information on the effects of invasive 

plants to wildlife is reported in the R6 2005 FEIS. 

Invasive plants have adversely impacted habitat for native wildlife (Washington Department of Fish and 

Wildlife 2003). Any species of wildlife that depends upon native understory vegetation for food, shelter, 

or breeding, is or can be adversely affected by invasive plants. In the case of common burdock (Arctium 

minus), the prickly burs can trap bats and hummingbirds and cause direct mortality to individuals (Raloff 

1998, USDI 1999). Species restricted to very specific habitats, for example pond-dwelling amphibians, 

are more susceptible to adverse effects of invasive plants.

Displacement of native plant communities by non-native plants results in alterations to the structure and 

function of ecosystems (MacDonald et al. 1989), and constitutes a principal mechanism for loss of 

biodiversity at regional and global scales (Lacey and Olsen 1991; Risser 1988 as cited in Johnson et al. 

1994). Mills et al. (1989) and Germaine et al. (1998) found that native bird species diversity and density, 

were positively correlated with the volume of native vegetation, but were negatively correlated or 

uncorrelated with the volume of exotic vegetation. Invasive plants can adversely affect wildlife species by 

eliminating required habitat components, including surface water (Brotherson and Field 1987; Dudley

2000; Horton 1977), reducing available forage quantity or quality (Bedunah and Carpenter 1989; Rice et 

al. 1997; Trammell and Butler 1995); reducing preferred cover (Rawinski and Malecki 1984; Thompson 

et al. 1987); drastically altering habitat composition due to altered fire cycles (D’Antonio and Vitousek

1992; Mack 1981; Randall 1996; Whisenant 1990); and physical injury, such as that caused by long 

spines or “foxtails” (Archer 2001). Invasive plants that grow large and densely (e.g., giant reed, 

Himalayan blackberry) can act as physical barriers to water sources and essential habitat (Callaghan

2014).

Invasive plants can act as a population sink by attracting a species and then exposing them to increased 

mortality or failed reproduction (Chew 1981). For example, Schmidt and Whelan (1999) reported that 

native birds increased their use of exotic Lonicera and Rhamnus shrubs over native trees, even though 

nests built in the exotic shrubs experienced significantly higher mortality rates.

Some invasive plants (such as knapweed) contain chemical compounds that make the plant unpalatable to 

grazing animals. Chemical compounds in these invasive plants disrupt microbial activity in the rumen, or 

cause discomfort after being ingested, resulting in a reduced or avoided consumption of the invasive plant 

(Olson 1999). 

Habitats that become dominated by invasive plants are often not used, or used much less, by native and 

rare wildlife species. Washington Department of Fish and Wildlife (2003) identified noxious weeds as 

threats to upland game bird habitat. Some hunters and wildlife managers are concerned that invasive 

plants are degrading the quality of remaining habitat for deer and elk and are adversely affecting the 

animal’s distribution and hunting opportunities. Trammell and Butler (1995) found that deer, elk, and 

bison avoided sites infested with leafy spurge (Euphorbia esula). Tamarisk stands have fewer and less 

diverse populations of mammals, reptiles, and amphibians (Jakle and Gatz 1985; Olson 1999). Invasion 

by purple loosestrife makes habitat unsuitable for numerous birds, reptiles and mammals (Kiviat 1996; 

Lor 1999; Rawinski 1984; Thompson, Stuckey, and Thompson 1987; Weihe and Neely 1997; Weiher et 

al. 1996). Reed canarygrass has been implicated in the loss of Oregon spotted frog habitat may have 

contributed to contractions in the range of the Oregon spotted frogs in western Oregon (Hayes 1997, 

McAllister and Leonard 1997, Watson 2003). 

Of the federally listed and other species of concern that occur on the MBS, none are known to be 

adversely affected by invasive plants within the project area. Bald eagle mortality in other parts of the 

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U.S. has been linked to a toxin produced by a cyanobacterium that grows on the invasive aquatic plant, 

Hydrilla verticillata (Wilde 2005). 

Some invasive species could adversely affect bald eagle foraging areas by creating dense patches of tall 

vegetation in and around streams or rivers that could hinder access to salmon. This speculation is based 

on observations of some invasive species that grow along rivers and streams in Region 6. 

In summary, invasive plants are known or suspected of causing the following effects to wildlife: 

Embedded seeds in animal body parts (e.g. foxtails), or entrapment (e.g. common burdock) 

leading to injury or death

Scratches leading to infection

Alteration of habitat structure leading to habitat loss or increased chance of predation 

Change to effective population through nutritional deficiencies or direct physical mortality 

Poisoning due to direct or indirect ingestion of toxic compounds found on or in invasive plants 

Altered food web, perhaps due to altered nutrient cycling 

Source-sink population demography, with more demographic sinks than sources 

Lack of proper forage quantity or nutritional value at critical life periods

3.5.2.2 Threatened, Endangered, Sensitive, and Management Indicator Species

Federally Listed Species

Several species listed as “threatened” under the Endangered Species Act (ESA) of 1973 (as amended) are 

found on The MBS. In addition, the U.S. Fish and Wildlife Service (USFWS) maintains a list of 

“candidate” species. Candidate species are those taxa that the USFWS has on file, and includes sufficient 

information on biological vulnerability and threats to support issuance of a proposal to list, but issuance 

of a proposed rule is currently precluded by higher priority listing actions (USDI 1996). Listed and 

candidate species of terrestrial wildlife found on the MBS are included in Table 33. 

Table 33. Federally listed and candidate wildlife species on Mt. Baker-Snoqualmie National Forest

Common Name Scientific Name Status Critical Habitat

Birds

Northern Spotted Owl Strix occidentalis caurina Threatened Designated

Marbled Murrelet Brachyramphus marmoratus Threatened Designated

Mammals

Grizzly Bear Ursus arctos Threatened None

Gray Wolf Canis lupus Endangered None

Wolverine Gulo gulo Candidate None

The single candidate species found on the MBS is also included in the Regional Forester’s Sensitive 

Species List and is discussed in the section titled “Forest Service Sensitive Species.” Detailed species 

accounts prepared for the Biological Assessment prepared for the R6 2005 FEIS are incorporated by 

reference. Information regarding the environmental baseline and critical habitat in the project area for 

federally listed species can be found in the Programmatic Biological Assessment for Forest Management 

Mt. Baker -Snoqualmie Terrestrial (USDA Forest Service 2002). This information is incorporated by 

reference and is summarized below.

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Northern Spotted Owl

Detailed accounts of the taxonomy, range, and habitat requirements of northern spotted owls (spotted owl) 

may be found in the 1987 and 1990 Fish and Wildlife Service Status Reviews (USDI 1987, 1990a); the 

1989 Status Review Supplement (USDI 1989), and the Interagency Scientific Committee Report (Thomas 

et al. 1990). Spotted owls were listed as federally threatened in June of 1990 (USDI 1994). 

Spotted owl home ranges on the MBS are fairly large and encompass large amounts of late-successional 

forest. The median home range size is 6,651 acres (1.8 mile radius) and the median amount of old-growth 

and mature forest within the home range is 3,281 acres (USDI 1992). 

The biology of this species is summarized in Thomas et al (1990). Available information suggests that 

owls on the Forest begin nesting activities in March, when establishment of nest territories begins. 

Incubation of eggs occurs from March through May, feeding and care of nestlings from May through 

June, and fledging occurring in June or early July. Juvenile dispersal is expected from September 

throughout the fall. 

For impacts analysis purposes of this EIS, the breeding season for spotted owls is divided into an early 

season, March 1 through July 15, and a late season, July 16 through September 30. There is ongoing 

discussion as to whether or not spotted owls are negatively affected from noise disturbance at any point in 

their breeding cycle. Nest fidelity of owls during incubation of the eggs to when the young fledge is high, 

with reproductive pairs actively pursuing prey items to feed the young. Adult fidelity to feeding young is 

noted in the spotted owl survey protocol, and is the basis to determine reproductive success. 

If susceptible to noise disturbance, spotted owls are more likely to be disturbed during the early breeding 

season, when adults are producing and incubating eggs up to when the young become strong fliers. Once 

young owls become strong fliers they are unlikely to be adversely disturbed by noise. Therefore, spotted 

owls are less likely to be susceptible to noise disturbance during the late breeding season (July 16 to 

September 30). 

Detailed accounts of the habitat requirements of the northern spotted owl may be found in the 1987, 1989, 

and 1990 Fish and Wildlife Service Status Reviews (USDI 1987, 1989, 1990b) and the Interagency 

Scientific Report (Thomas et al. 1990). The northern spotted owl is a predatory species feeding primarily 

on forest-dwelling mammals. The primary spotted owl prey species in Washington State is the northern 

flying squirrel (Glaucomys sabrinus). Additionally, prey species include a number of arboreal and 

terrestrial mammals associated with mature and over-mature forest stands.

Suitable habitat for the northern spotted owl must provide for the nesting, roosting, and foraging needs of 

the bird as well as for dispersal. Suitable habitat is characterized by moderate to high canopy closure (60-

80 percent); a multi-layered, multi-species canopy with large (greater than 30 inches d.b.h.) overstory 

trees; a high incidence of large trees with various deformities, cavities, broken tops, mistletoe infections 

and other evidence of decay; large snags; large accumulations of fallen trees and other woody debris on 

the ground, and sufficient open space below the canopy for the owls to fly (Thomas et al. 1990). 

In the western Washington Cascade Mountains, spotted owls used mature, older forests dominated by 

trees greater than 20 inches d.b.h. with greater than 60 percent canopy closure, more often than expected 

for roosting during the non-breeding season. Spotted owls used young-forest trees 8 inches to 20 inches

d.b.h. with more than 60 percent canopy closure, less often than expected based on availability (Herter et 

al. 2002). 

On the MBS, northern spotted owls use mature and old-growth forest habitat within the western hemlock 

and Pacific silver fir vegetation zones. Habitat includes old-growth forest stands for nesting and foraging, 

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mid- to late-seral stands for foraging, and immature to old-growth stands for dispersal. A review of 

spotted owl pairs with the highest reproductive success on the Forest found that the higher reproductive 

pairs occur mostly in the western hemlock/sword fern Plant Association Groups (PAGs)(p<0.01, Iverson 

Unpublished data). The total number of spotted owls occurring on the Forest is unknown, since all 

suitable habitat has not been surveyed (less than 55 percent of the habitat as of 1995), and the majority of 

surveys which have been conducted occurred prior to 1994. There is approximately 482,550 acres of 

suitable spotted owl nesting habitat on the Forest. 

The Final Revised Recovery Plan for the Northern Spotted Owl (USDI 2011) recommends retaining all 

occupied and unoccupied, high quality spotted owl habitat on all lands to the maximum extent possible. 

This plan does not include specific recommendations on a network of management areas for spotted owl 

habitat, since the U.S. Fish and Wildlife Service (USFWS) is in the process of conducting a rangewide, 

multi-step modeling process to design, assess, and inform designation of a habitat conservation network 

that will help address the recovery of the spotted owl. 

Northern Spotted Owl Critical Habitat 

A Final Rule to designate revised critical habitat for the spotted owl was published in the Federal 

Register, November 21, 2012 (USDI 2012). Primary constituent elements for owl critical habitat consist 

of habitat features that support nesting, roosting, foraging, and dispersal. 

The MBS has 648,542 acres of designated revised critical habitat comprised of portions from two critical 

habitat units. The West Cascades North Unit consists of 542,274 acres, which except for 798 acres of 

State land, is comprised of federal lands managed by the Mt. Baker-Snoqualmie and Wenatchee National 

Forests. The West Cascades Central Unit consists of 909,687 acres, which except for 825 acres of State 

land, is comprised of lands managed by the Mt. Baker-Snoqualmie, Gifford Pinchot, and Wenatchee 

national forests. 

The successional stages of forest occurring within the boundaries of the CHUs range from non-habitat 

(e.g., young plantations) to high-quality habitat (e.g., large blocks of old-growth forest). On the MBS, 

portions of the critical habitat include forest associations that are not thought to provide suitable habitat 

(Pacific silver-fir, mountain hemlock, and parkland zones). Many of the proposed invasive plant treatment 

sites would occur in designated spotted owl critical habitat units. Proposed treatments are located 

primarily along roads and limited to invasive plants only and would not affect native understory or 

overstory vegetation that comprises critical habitat. 

Marbled Murrelet

The marbled murrelet (murrelet) has been listed as federally threatened since October 1992 (USDI 1994). 

The murrelet uses inland forest sites for nesting from Alaska to Northern California (Marshall 1988). 

Detailed accounts of the taxonomy, range and habitat requirements of the marbled murrelet may be found 

in the 1988 Status Review (Marshall 1988), the Final Rule designating murrelets as threatened (USDI 

1992b), the designation of revised critical habitat for the species (USDI 2011), the U.S. Forest Service's 

general technical report on ecology and conservation of the marbled murrelet (Hamer and Nelson 1995a), 

and the Recovery Plan for the Marbled Murrelet (USFWS 1997). 

Nesting occurs over an extended period from late March to mid-September. Studies in Washington 

indicate that incubation usually begins by April 26 and extends to July 30. Both sexes incubate the egg for 

about 30 days, and the nestling period runs from May 26 through August 27. The young fledge at about 

30 days of age. Total length of breeding season was 124 days (Hamer and Nelson 1995a). These dates and 

numbers are approximations based on a small sample size. Adults feed the chicks generally twice a day, 

most often at dusk and dawn. Other than a 1-3-day brooding period, adults leave the chicks alone on the 

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nest except when actively feeding. A fledgling’s first flight is presumed to be from the nest directly to the 

marine environment (Nelson and Hamer 1995). 

The nesting season in Washington was redefined as the period from April 1 to September 23 (USDI 

2012). Daily operating restrictions limiting noise generating activities to occur 2 hours after sunrise to 2 

hours before sunset are believed to be beneficial in in reducing exposure of nesting murrelets to 

disturbance during these times. However, due to a proportion of feeding that occurs in the middle of the 

day, the implementation of this restriction would not completely avoid potential adverse effects to 

murrelets, eggs, or chicks. 

Suitable nesting habitat for the marbled murrelet is considered to be mature to old-growth coniferous 

stands, or those younger stands with interspersed large trees which may provide nesting opportunities. 

Generally, the habitat characteristics associated with murrelet nesting are large trees with large lateral 

branches, mistletoe infection, witches brooms and a mature understory that extends into the canopy. These 

elements provide nesting substrate, which are associated with trees 200 to 250 years of age. Currently, 

available nesting habitat on the Forest is estimated at 297,262 acres. 

Marbled Murrelet Critical Habitat 

A Final Rule to designate revised critical habitat for the marbled murrelet was published in the Federal 

Register, October 5 2011 (USDI 2011). The MBS contains approximately 783,253 acres of designated 

revised critical habitat, less than one-half of which is considered suitable murrelet nesting habitat. On the 

MBS, portions of the critical habitat include forest associations that are not thought to provide suitable 

habitat (silver-fir, mountain hemlock, and parkland zones). Many of the infested areas occur in designated 

murrelet critical habitat units. Proposed treatments are located primarily along roads and limited to 

invasive plants. Native trees and understory vegetation are not likely to be affected. 

Grizzly Bear

The North Cascade Grizzly Bear Recovery Zone on the MBS occurs on National Forest System lands 

north of Interstate 90. The North Cascade Mountains still has a small population of grizzly bear (Servheen

1997). Estimates range from less than 20 to 50 animals (Almack et al. 1993) to fewer than 12 

(MacCracken and O’Laughlin 1998). 

The last reported kill of a grizzly bear in the North Cascade Mountains occurred in 1967 (Servheen 1997). 

Since 1983, there have been 2 confirmed and 11 probable grizzly bear detections on the MBS. Despite 

intensive efforts, less than one confirmed, or probable detections occur per year. A bear photograph, taken 

in 2010 by a hiker just off the Forest in the North Cascades Park, was confirmed a grizzly bear by 

biologists. The previous confirmed or probable grizzly bear detection in the North Cascades Recovery 

Area occurred on the MBS in 1996. There are no known den sites. 

Potential habitat in the North Cascades Recovery Area is believed to provide sufficient habitat to support 

200 to 400 grizzly bears (Servheen et al. 1991, MacCracken and O’Laughlin 1998). Despite a lack of 

known mortality, the population does not appear to have grown. The lack of grizzly bear population 

growth in the absence of known human-caused mortality could indicate that the likelihood of opposite sex 

encounters is very low, or that genetic problems are limiting cub survival. 

The MBS, and other federal land management agencies in the recovery zone, currently maintain options 

for grizzly bear recovery by following an interim no net loss of core area policy. This interim policy is 

expected to remain in effect until the recovery area subcommittee adopts a new policy based on a habitat 

assessment to be completed by the technical team.

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Grizzly bears hibernate in the winter and excavate dens in which to hibernate, with the denning season 

occurring from October 30 to April 30. Grizzlies are omnivorous and opportunistic feeders. They may eat 

carrion, grasses, riparian forbs, berries, bulbs, insects, whitebark pine nuts, fish, ungulates, ground 

squirrels, roots, bulbs, fungi, tree cambium, and even garbage (Cole 1972; Hamer 1974; Hamer et al. 

1977 as cited in USDI 1993a; Martinka 1972; Murie 1944; Pearson 1975; and Singer 1978). In some 

areas grizzlies may be almost entirely herbivorous, and they rely on plants that have recently emerged, 

when crude protein levels are highest (USDI 1993). Foods high in protein and carbohydrates that allow 

for significant fat deposition prior to hibernation are essential for the grizzly’s survival. 

The search for food has a prime influence on grizzly bear movements. Upon emergence from the den they 

seek the lower elevations, drainage bottoms, avalanche chutes, and ungulate winter ranges where their 

food requirements can be met. From late spring to early summer they follow plant green-up back to the 

higher elevations. In late summer and fall, the bears will transition to fruits and nuts as a food source. 

Gray Wolf 

Wolves are habitat generalists (Mladenoff et al. 1995), occurring in all vegetation types except tropical 

rain forests and arid deserts (Mech 1970). Pelts traded with the Hudson Bay Company indicate that 

wolves historically occurred at low density in the Puget Sound Region, with higher densities in eastern 

Washington (Laufer and Jenkins 1989). 

Gray wolves are sensitive to human disturbance, particularly around denning and rendezvous sites. 

Security habitat for this species, defined as all habitat types containing less than 1.0 mile per square mile 

density of open road, is a measurement indicator for assessing project-level effects. Security habitat is 

typically evaluated in terms of the relative level of human influence within a fifth-field watershed area 

(Gaines et al. 2003). Gaines et al. (2003) defined levels of human influence by the following: 

§ low level = greater than 70 percent of watershed contains security habitat

§ moderate level = 50 to 70 percent of watershed contains security habitat

§ high level = less than 50 percent of the watershed contains security habitat 

Human influence on wolf security habitat varies on the MBS from low levels in wilderness areas to high 

levels along roads, campgrounds, trails, and other high human use areas. However, to assess impacts to 

dispersing wolves, the MBS often uses changes in open road density and grizzly core habitat as a proxy 

for wolf security habitat. Denning season occurs from April 1 to June 30, and use of rendezvous sites 

occurs until August 31. 

Until recently, gray wolves have not existed at population levels capable of breeding in Washington State. 

Dispersing individuals from populations in Idaho, Montana, and British Columbia have been documented, 

an occurrence that has become more common since 2005 as these populations have become reestablished. In July of 2008, a pack with pups was discovered in western Okanogan and northern Chelan 

Counties (WDFW 2008). As of 2014, 13 packs have been documented in eastern Washington; with more 

suspected (WDFW 2014).

A rendezvous site was reported along the Cascade Crest in the Glacier Peak Wilderness in 1991. In the 

early 1990s, Gaines et al. (1995) reported a lone wolf and one pack responding to simulated wolf howls 

on the Okanogan-Wenatchee National Forest. In 1990, a wolf pack was reported in the Hozomeen area of 

the North Cascades National Park. Although Hozomeen is west of the Cascade Crest, it is in the rain 

shadow of numerous mountains and supports dry forest vegetation similar to east-side forests. Wolf 

activity in these areas has been transient with no occurrence since the initial detection. 

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Howling surveys were conducted on the MBS throughout the 1990s. Since the surveys were concentrated 

in areas where unconfirmed wolf sightings were most common and no responses were detected, it is most 

likely that the reported wolf sightings were transient wolves. It is important to note that these 1990s 

surveys occurred when ungulate populations were more than twice the size of current populations 

(WDFW 2002). 

Transient wolves, including packs, have been confirmed in dry forests of the North Cascade Mountains

where ungulate populations are relatively high. Despite howling surveys in areas of suspected wolf 

activity in years when ungulate populations were substantially higher, no wolves have been confirmed 

west of the Cascade Crest. As a result, there is no indication that resident animals currently occupy the 

area west of the Cascade Crest. Occasional dispersal may occur from populations on the east side of the 

Cascade Mountains or from Canada. 

With wolves possibly colonizing habitats with higher ungulate abundance east of the Cascade Crest, 

dispersing wolves may occur on the MBS. That portion of the MBS adjacent to the Cascade Crest and 

those areas with remnant elk populations may be important for wolf dispersal; facilitating colonization of 

other suitable areas in eastern Washington. With territorial packs established east of the Cascade Crest, 

attempts at colonization west of the crest may occur; portions of the MBS may be included in wolf 

territories. When these conditions develop, additional consultation regarding project effects on gray wolf 

will be needed. 

Forest Service Sensitive Species

Terrestrial wildlife species found or suspected on the MBS that are included in the Region’s “Special 

Status/Sensitive Species Program” are listed in Table 34. The “Special Status/Sensitive Species Program” 

which includes the Regional Forester’s Sensitive Species List is a proactive approach for meeting the 

Agency’s obligations under the Endangered Species Act and the National Forest Management Act 

(NFMA), and National Policy direction as stated in the 2670 section of the Forest Service Manual and the 

U.S. Department of Agriculture Regulation 9500-4. The primary objectives of the Sensitive Species 

program are to ensure species viability throughout their geographic ranges and to preclude trends toward 

endangerment that would result in a need for federal listing. Species identified by the FWS as 

“candidates” for listing under the ESA, and meeting the Forest Service criteria for protection, are included 

on the Regional Forester’s Sensitive Species Lists. Documented/Suspected: Documented means that an 

organism that has been verified to occur in or reside on an administrative unit. Suspected means that an 

organism that is thought to occur, or that may have suitable habitat, on National Forest System land or a 

particular administrative unit, but presence or occupation has not been verified.

Table 34. Occurrence of Forest Service Sensitive Species on MBS

Common Name Scientific Name Occurrence on National 

Forest System Lands

Birds

American Peregrine Falcon Falco peregrinus anatum Documented

Common Loon Gavia immer Documented

Bald Eagle Haliaeetus leucocephalus Documented

Harlequin Duck Histrionicus histrionicus Documented

Amphibians

Larch Mountain Salamander Plethodon larselli Documented

Van Dyke’s Salamander Plethodon vandykei Suspected

Mammals

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Common Name Scientific Name Occurrence on National 

Forest System Lands

Townsend’s Big-eared Bat Corynorhinus townsendii Documented

North American Wolverine Gulo gulo Documented

Mountain Goat Oreamnos americanus Documented

Terrestrial Invertebrates

Broadwhorl Tightcoil Pristiloma johnsoni Documented

Shiny Tightcoil Pristiloma wascoense Documented

Johnson’s Hairstreak Callophyrs johnsoni Documented

Valley Silverspot Speyeria zerene bremnerii Suspected

Peregrine Falcon 

This species usually uses cliffs for nesting and forages prey (shorebirds, waterfowl, and songbirds) from 

riparian areas. The usually nest on ledges or small caves on high vertical cliffs overlooking plains or 

bodies of water (Welty 1975) and are aerial predators who feed mostly on birds. Much of the prey 

consists of species the size of pigeons and doves; however avian prey ranges in size from hummingbirds 

to Aleutian Canada geese (Pagel 2004-2006). There is a high density of both potential nesting habitat and 

riparian foraging areas on the Forest. However, snow and other climatological factors may limit the 

suitability of these sites for nesting. 

Two nest sites have been located on the Forest and another adjacent to it. Peregrines lay 2-4 eggs in 

March-May, eggs hatch after an incubation period of 31-33 days. Fledging occurs when the young are 

between 37 and 45 days of age (56 days at the upper end). Juveniles continue to be fed and protected by 

the adults until they disperse, which can range from 3 weeks to 3 months (ibid.).

Peregrine falcons can be disturbed by human activity during the nesting season (ibid.). Disturbance can 

cause: nest sites and new territories to be abandoned; active nesting attempts to fail due to egg breakage; 

or divert adult attention from opportunities to forage and feed nestlings (ibid.).

Peregrine falcons were delisted in 1999 and the USFWS has committed to monitor populations 

nationwide five times at 3-year intervals and report results. Invasive plants do not directly affect peregrine 

falcons. Peregrine falcons in the Pacific Northwest are most affected by bioaccumulation of contaminants, 

and direct disturbance to their nesting at known or suspected nest sites; both which have caused numerous 

nesting failures during the previous 20 years of observation (ibid.).

Common Loon 

Common loons typically breed on forest lakes with deep inlets or bays and numerous islands (McIntyre 

and Barr 1997). During migration, they aggregate on rivers, reservoirs, and lakes. They tend to winter in 

shallow, sheltered marine waters. In all situations, loons require water bodies with ample prey 

populations. 

Size of lakes ranges between 19 and 7,800 acres (4-3150 ha), and maximum water depth ranges from 11 

to 320 ft. In western Washington, loons nest on lakes and reservoirs between 200 ft. and 2800 ft.in 

elevation. 

There is no known nesting activity by loons on the Forest. 

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Bald Eagle 

Bald eagle habitat consists of nesting and wintering habitat that is often separated by hundreds to 

thousands of miles. Bald eagles prefer large trees for nesting (Stalmaster et al. 1985). Bald eagle nests are 

usually built in trees that dominate the surrounding area and have large horizontal branches. Trees 

selected for nesting are usually near water, for easy access to food. During the winter, bald eagles often 

roost in large groups (Stalmaster et al. 1985). Roosting areas are used at night although some eagles may 

remain there throughout the day. The eagles may congregate in specific trees, or staging areas, before 

flying to the roost area (Stalmaster et al. 1985). Winter roosts may be located in coniferous forests, which 

offer the most protection from the weather, or in deciduous forests (Stalmaster et al. 1985). Roost trees are 

usually larger than other trees in the stand.

There are currently two nest sites on the Forest at Baker Lake, although only one is usually active. 

Wintering bald eagles concentrate on and move between several Washington rivers to feed on salmon 

carcasses, including the Skagit, Nooksack, Stillaguamish, Skykomish, Nisqually, Okanogan, upper 

Columbia, and Spokane. The Skagit River usually attracts the highest numbers, with up to severalhundred eagles gathering in the river basin to feed primarily on chum salmon, but also coho and steelhead 

(Taylor 1989; Dunwiddie and Kuntz 2001). 

Some nesting eagles are sensitive to disturbance (USDI 1986). The critical period in Washington when 

human activities could disturb occupied nest sites extends from January 1 until August 15 (USDI 2003, p. 

9). Nest initiation, including courtship and nest building, occurs in January through March. Incubation 

occurs from March until late May, and young are in nests from early April through mid-August. Young 

usually remain in the nest area throughout August. 

Wintering eagles on the Forest can be sensitive to disturbance from October 31 to March 31 (USDI 2003, 

p. 9). The Forest utilizes a winter limited operating periods near foraging and roosting bald eagles from 

October 31 to March 15. 

Harlequin Duck

Harlequin ducks nest along fast-flowing rivers and mountain streams in the Cascade Range of Oregon and 

Washington. It is hunted in Washington and Oregon. Harlequin ducks forage heavily on caddis flies, and 

will also eat some mayflies and stoneflies (Marshall et al. 2003). They apparently eat fish only rarely.

This species uses numerous drainages on the Forest (including but not limited to: Sauk, Suiattle, North 

Fork Stillaguamish, and White Chuck). Nests are built along stream edges in mature and large conifer 

forest or mixed forest within riparian zones of Class 1 through 3 streams. Maintenance of water quality 

and down wood is important for caddis flies, a major food source. Down wood also provides potential 

nesting and hiding sites within riparian areas. 

Larch Mountain Salamander

Larch Mountain salamanders occur in a wide array of habitat types including: (1) old-growth forests; (2) 

younger naturally regenerated forests in gravelly/cobble soils with residual late successional features 

(snags and large down logs); (3) scree and talus (forested and un-forested); and (4) lava tube entrances 

where debris (e.g., pieces of lava, wood, fine organic and inorganic particles) has accumulated. In a large 

portion of the species range, late-seral forest conditions appear to be crucial to the species existence. In 

other areas, combinations of rocky substrates, soils, and vegetation provide suitable cool, moist 

microhabitat conditions necessary for Larch Mountain salamanders to exist. 

The Larch Mountain salamander is found along a 36-mile stretch of the Columbia River Gorge and in 

isolated populations to the north in the Washington Cascade Range and to the south in the Oregon 

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Cascade Range. In Washington, they occur to about 120 mi) north of the Columbia River Gorge in Clark, 

Cowlitz, Skamania, Lewis, King, Pierce, Klickitat, and Kittitas Counties. The northern extent of its range 

is suspected to be Highway 2. Despite years of survey on the MBS since 1997, in apparently suitable 

habitat, the species has been found only in the southeast portion of King County. 

Most of its life is spent in the subterranean environment and it is surface-active about 20 to 90 days a 

year, depending on location and conditions. Surface activity is triggered whenever moisture and 

temperature regimes are appropriate, primarily in the spring and fall. In the Columbia River Gorge this 

tends to be mid-February through late-May and in the fall from late September through late-November. In 

the Cascade Range, the activity period is approximately April through late June and late September to late 

November. Ideal conditions are when temperatures are between 4 degrees and 14 degrees C and soil is 

saturated to a depth of about 30 cm. Breeding takes place in the autumn and spring months. There is no 

free-living larval stage (Hallock and McAllister 2005a). Mites and springtails have been found to be 

common prey. 

Van Dyke’s Salamander

Habitat affinities are poorly understood for this species and habitat associations for the Cascade Range 

populations have not been assessed. In some respects, this species appears a generalist, because it may be 

found in a variety of habitats at a large range of elevations (sea level to over 5,000 feet). This species has 

been found along streams (Wilson et al. 1995), in upland forests (Slater 1933), talus (Herrington 1988), 

along lake shores (Crisafulli 2004) at cave entrances (Aubry et al. 1987), and at seeps (Leonard et al.

1993). Within the different habitat types, this species tends to seek out cool and moist or wet cover.

The salamander is endemic to the State of Washington (Leonard et al. 1993). The distribution is disjunct, 

even among populations in the Cascade Range. It is known from three population centers: the Cascade, 

Willapa, and Olympic Mountain Ranges. In the Cascade Range, it is known from only 28 sites west of the 

crest to the Puget Trough. Along the axis of the range, it is known from central Skamania County to the 

south, to the north end of Mount Rainier, Pierce County, to the north. Populations may be small and 

disjunct from one another and much potential habitat appears to be unoccupied (Wilson et al. 1995). The 

northern extent of its range is suspected to be Highway 2. Despite years of survey on the MBS since 

1997, in apparently suitable habitat, the species has not been found. 

Most surface activity takes place in the spring after snowmelt and before summer drought and in the fall 

after the onset of fall rains and before temperatures approach freezing. More specifically, most surface 

activity occurs when soil moisture is high (moist or wet) and soil temperatures are between 4 degrees to 

14 degrees C (Hallock and McAllister 2005b). Because this species may occupy wet habitats, it is 

sometimes surface active even in the summer. Nests found on the Olympic Peninsula (elevations below 

700 meters) were laid in early May and development was completed by early October (Hallock and 

McAllister 2005b). Females brood and guard the eggs during the summer. 

Townsend’s Big-eared Bat

The Townsend’s big-eared bat is a non-migratory species dependent on caves, or cave-like structures 

including mines year-round. These caves occur in a wide variety of habitat types and elevations from sea 

level to 10,000 feet (NatureServe 2011, Siemers 2002). Townsend’s will also use rock crevices, rock 

faces/cliffs, buildings, tunnels, bridges, and trees as day or night roost sites (Dobkin et al. 1995, Ellison et 

al. 2003, Mazurek 2004). 

One young is born from April to July (Maser et al. 1981). Big-eared bats hibernate in winter and are not 

known to migrate long distances. These bats are very intolerant of human disturbance at either winter 

hibernacula or summer roosts (Csuti et al. 1997). 

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In addition to cave or cave like habitat, primary components include suitable foraging habitat that 

provides insect prey and water sources for both drinking and foraging. Considered a moth specialist, 

preferred prey items include small moths 0.23-0.47 inches from the families Noctuidae, Geometridae, 

Notodontidae, and Sphingidae, with opportunistic foraging on beetles and flies (Pierson et al. 1999). 

Although Townsend’s are considered moth specialists, they can be considered habitat generalists in terms 

of foraging as they appear to forage successfully in a wide range of habitats, and particularly in edge 

habitat. 

They forage in riparian areas, intermittent streams (Seidman and Zabel 2001), wetlands, and lakes, and 

along forest/shrub edges, ridges, or canopy, where insects concentrate (Burford and Lacki 1998, Clark et 

al. 1993). They also glean insects directly from foliage or other substrates. Although they appear to avoid 

large, open areas (Pierson et al. 1999), and areas of dense, regenerating forests, estimates of canopy 

coverage necessary to create suitable foraging conditions are unknown. Clark et al. (1993) found foraging 

in open, uncluttered areas enhanced the ability of Ozark big-eared bats to navigate and distinguish insects 

but it increased their risk to predation. Woodland edge habitat offered a less cluttered environment, some 

cover, and a high prey density. 

Wolverine 

In California, Oregon, and Washington, the wolverine inhabits various forest types in remote wildernesses 

with adequate food (Banci 1994). Wolverines inhabit dense coniferous forests and use open sub-alpine 

forests up to and above the timberline. Typically, they use high elevation alpine wilderness areas in the 

summer and montane forest habitats in the winter. Prey items include small and medium-sized mammals, 

birds and their eggs, insects, fish, roots, berries, and carrion. Wolverines are known to regularly avoid 

human-generated disturbance, and are sensitive to any disturbance; they will move natal den-sites several 

miles if disturbed. 

In the 19th century, wolverines were found throughout the Cascade Mountains, Rocky Mountains, Central 

Great Plains, Great Lakes, Upper Midwest, and the northeast United States. Currently, the U.S. population 

is estimated at 250 to 300 individuals, mostly concentrated in the northern Rocky Mountain Range, with 

some occurring in the Pacific Cascade Region. Populations in Canada and Alaska do not appear to be in 

decline. In recent years there have been documented sightings of wolverines on the MBS. 

Mountain Goat

Goats are native to the North Cascade Mountains and are often found in areas with cliffs that provide 

security and escape cover from predators. 

Using the 2008 WDFW statewide estimates, and updating this data with more recent survey information, 

there are an estimated 1,098 mountain goats on the MBS. This total includes animals that are known to 

spend most of their time on the Wenatchee National Forest, and animals from Mount Rainier and North 

Cascades National Parks that spend at least some of the winter on the MBS. 

Broadwhorl Tightcoil 

The range of this species is from southwestern British Columbia through the north Cascade Range in 

western Washington, and south to northwestern Oregon. It is reported from many widely separate 

locations, although relatively few sites have been recorded in any region. The species appears to be more 

or less coastal, although it occasionally occurs at inland sites (e.g. the western slope of the Cascades) 

(Frest 2005). Sites in British Columbia include Vancouver Island near the towns of Nanaimo and Duncan. 

Washington sites include the Cascades, the San Juan Islands, and the Olympic Peninsula, including 

Clallam, Jefferson, King, Kitsap, Pacific, Pierce, San Juan, Snohomish, and Whatcom Counties (Branson 

1977 and 1980, Dall 1895, Pilsbry 1946, Deixis 2009, Burke 2009, pers. comm.) Since this species has 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Wildlife

been rarely found/documented, habitat associations given are general. Sites are generally very moist, with 

coastal influence. Typical site descriptions include abundant ground cover (e.g., salal, oxalis, sword fern, 

and grasses), conifer or hardwood overstory, and moderate to deep litter. Despite years of survey on the 

MBS since 1997, in apparently suitable habitat, the species has not been found. 

Shiny Tightcoil

This species is reported from many widely separate (but often imprecise) historic locations. It is known 

from the Washington and Oregon Cascade Range (Branson 1977, Frest and Johannes 1999, Branson 

1980). It is also reported from the Blue Mountains in Oregon (Wallowa Valley above Wallowa Lake in 

Wallowa County) and from several counties in Idaho (Washington, Adams, Boise, and Shoshone) (Pilsbry 

1946, Frest and Johannes 1999). A historic record from Marion County, near Salem, suggests possible 

Coast Range occurrence (Frest and Johannes 1999). Various sites in the Washington Cascades (Mount 

Rainier National Park) have revealed this or a very similar species; specimens from this area are in need 

of further survey and study, and should be compared to the original P. wascoense material (Burke 2009). 

A site in Olympic National Park originally reported appears to be in error (Burke 2011). 

Sites are generally in Ponderosa Pine/Douglas fir plant associations at moderate-high elevations. Other 

Pristiloma species in the ecoregion are known to prefer moist microsites such as basalt talus 

accumulations, usually with riparian influence. There is maybe potentially suitable habitat for this species 

in the immediate vicinity of the project area. Despite years of survey on the MBS since 1997, in 

apparently suitable habitat, the species has not been found. 

Johnson’s Hairstreak 

These butterflies occur within coniferous forests which contain the mistletoes of the genus Arceuthobium, 

commonly referred to as dwarf mistletoe. These plants are highly specialized and are known to occur on a 

number of different conifers (Schmitt and Spiegel 2008). Dwarf mistletoe-infected conifers are common 

in northeastern Oregon, and current dwarf mistletoe levels are not believed to be substantially less than 

historic levels in this area. It is likely that surveys have not been numerous enough to reveal all locations 

of breeding populations and the range of the species is probably more widespread. 

It has been speculated that old-growth forests are particularly suitable to this species of butterfly, although 

Arceuthobeium mistletoes also occur in younger forests as well, where there is an absence of recent largescale disturbance (Schmitt and Spiegel 2008). Larsen et al. (1995) states that old-growth and latesuccessional second-growth forests provide the best habitat for this butterfly, although younger forests 

where dwarf mistletoe is present also supports hairstreak populations. All sightings in both Washington 

and Oregon have been in coniferous forests. Perhaps one reason for infrequent sightings of this butterfly 

could be the species spending a majority of its time in the top of the forest canopy (Scott 1986; Pyle 

2002). 

In Washington, Johnson’s hairstreak has been documented from the Olympic National Forest, Mt. BakerSnoqualmie National Forest, and the Gifford Pinchot National Forest. There are 42 Washington records 

for Johnson's hairstreak (Hinchliff 1996). Forty-one of the 42 WA records are from less than or equal to 

2,100 feet elevation—they range from 0-2,100 feet—and the outlier is from 2,700 feet from southern 

Skamania County (Potter 2005). Most Washington records are old, they range from 1891 to 1995; 

however, most are pre-1970 when there was considerably more low-elevation old-growth forests. 

(Hinchliff 1994; Potter 2005). 

Evidence of a declining range with populations is very localized and scarce. Many records of this insect 

tend to be old, those from Washington range from 1891–1995, with many being pre-1970 when there 

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were more old-growth forests at lower elevations (Hinchliff 1994; Potter 2005; cited by Xerces Society 

2009). 

Valley Silverspot 

This subspecies is historically known from southwestern British Columbia south to west-central Oregon. 

In British Columbia, it occurs on Vancouver Island and Salt Spring Island, although recent searches of 

these islands found only a few surviving populations (GEORT 2003). It has also been recorded in British 

Columbia’s Lower Mainland but these are likely strays or historical populations that are now extirpated 

(GEORT 2003). In Washington this species occurs on the San Juan Islands, along the Washington Coast 

Range, and in the Puget Trough (Pyle 2002). Viola adunca var. adunca is known as a larval food plant of 

this subspecies in Oregon; in British Columbia (Vancouver Island) the larvae are reported to feed on V. 

palustris (reviewed in Warren 2005). Males may be found visiting mud or patrolling sunny areas, with the 

exception of hilltops. This subspecies inhabits windy peaks with nearby forest openings. It is also found 

in native prairies and grasslands, often tending towards more mesic sites (Pyle 2002, Hammond 2006). 

Management Indicator Species

Management Indicator Species (MIS) are selected species whose welfare is believed to be an indicator of 

the welfare of other species using the same habitat or a species whose condition can be used to assess the 

impacts of management actions on a particular area (Thomas et al. 1979). Selected habitat types and the 

representative terrestrial management indicator species from the MBS Forest Plan (USDA 1990) are 

displayed in Table 35. 

Table 35. Terrestrial Management Indicator Species on MBS

Species Preferred Habitats MIS Habitat 

Category

Habitat Present in 

Analysis Area

Species Present

or Suspected in 

Analysis Area

Bald Eagle

Roost, nest habitat 

and forage areas near 

lakes, reservoirs, 

rivers with readily 

available food source 

(fish and carrion)

Threatened and 

Endangered Species 

Habitat

Y Y 

American Peregrine 

Falcon Cliff habitat for nesting

Threatened and 

Endangered Species 

Habitat

Y Y 

Gray Wolf

Security habitat > 300 

m from road and high 

use trails

Threatened and 

Endangered Species 

Habitat

Y Y 

Grizzly Bear

Core habitat > 300 m 

from road and high 

use trails

Threatened and 

Endangered Species 

Habitat

Y Y 

Mountain goat

Rocky slopes >40 

degrees adjacent to 

forage and cover

Big-game Sensitive 

Species Winter 

Range

Y Y 

Northern Spotted Owl

Mature, old-growth 

forests (nesting, 

roosting, foraging). 

Second-growth used 

for dispersal

Threatened and 

Endangered OldGrowth Forest 

Habitat

Y Y 

American Marten

Mature, old-growth 

forest >40% fir and 

canopy closure >50%

Old-Growth and 

Mature Forest Y Y 

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Species Preferred Habitats MIS Habitat 

Category

Habitat Present in 

Analysis Area

Species Present

or Suspected in 

Analysis Area

Pileated Woodpecker Mature, old-growth 

forest

Old-Growth and 

Mature Forest Y Y 

Other Primary Cavity 

Excavators

Snags and downed 

logs in forested 

habitats

Snags and Downed 

Logs Y Y 

Additional information and monitoring efforts on the population and habitat trends for MIS on the Forest 

can be found in the MBS Management Indicator Species Assessment (USDA 2011). The following 

paragraphs describe MIS species, except for Threatened, Endangered, and Sensitive species that were 

described previously (Bald eagle, peregrine falcon, gray wolf, grizzly bear, mountain goat and Northern 

spotted owl). 

Pileated Woodpecker 

Pileated woodpeckers are primary excavator species that inhabit mature coniferous forest habitats on the 

MBS, and are evaluated in regards to snag abundance and size class. The pileated woodpecker is the 

largest woodpecker species in the western United States and nests in cavities of large trees or snags. 

Pileated woodpeckers use mature and older, closed canopy stands for nesting and roosting, but may use 

younger (40-70 years), closed-canopy stands for foraging if large snags are available; large snags and 

decadent trees are critical habitat components for pileated woodpeckers; down logs do not appear to be an 

important foraging substrate for pileated woodpeckers on the west side of Oregon and Washington 

(Hartwig et al. 2004, Mellen et al. 1992, Raley and Aubry 2006). 

It is a denizen of mature forests, relying on dead and decaying trees for foraging and nesting. Pileated 

woodpeckers can act as a keystone habitat modifier by excavating large numbers of cavities that are 

depended upon by several other species, and by influencing ecosystem processes such as decay and 

nutrient cycling (Aubry and Raley 2002). Pileated woodpeckers will return to areas after timber 

harvesting (Ehrlich 1988), however, past management in the Pacific Northwest has led to relatively few 

snags and down logs, especially of large diameters, remaining in many watersheds. Previous timber 

harvest, as opposed to wildfire events, has had the greatest effect on the availability of large diameter 

standing dead trees on the MBS. 

American Marten 

This is a Management Indicator Species that is associated with older forests, in the Pacific silver fir forest

association. Marten occur in forests containing snags and down logs, which provide suitable denning 

sites. Marten are most closely associated with heavily forested east and north-facing slopes that contain 

numerous windfalls (Maser 1998). They tend to avoid areas that lack overhead protection and the young 

are born in nests within hollow trees, stumps, or logs. Although marten may be found in all forested 

zones, higher densities of marten are primarily found in the Pacific silver fir and mountain hemlock forest 

zones. Marten may occur in and around the proposed activities. 

Other Primary Cavity Excavators 

A large number of species rely on cavities in trees for shelter and nesting. The MBS has designated a 

group of species for this Management Indicator category. This group of species represents snag-dependent 

cavity nesters, and includes animals dependent on dead or dying trees for nest sites. Primary cavity 

excavators comprise a broad group of species associated with standing dead trees or snags and down logs, 

and that excavate their own nests. 

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Downy woodpecker, hairy woodpecker, northern flicker, red-breasted nuthatch and red-breasted 

sapsucker are cavity nesters common on the MBS. Pileated woodpeckers also rely on snag habitat. 

Survey and Manage Species

The Survey and Manage species list considered conforms to the 2001, 2002, & 2003 Annual Species 

Review changes and meets the provisions of the 2001 Record of Decision and Standards and Guidelines 

for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards 

and Guidelines. Survey and Species associated with the MBS as of the 2003 Annual Species Review are 

listed in Table 36. 

The 2001 decision amended the Survey and Manage direction and reorganized Survey and Manage 

species into six species categories (Categories A-F) based on rarity and survey practicality (USDA Forest 

Service and USDI Bureau of Land Management 2001). Categories A and C require that site-specific, predisturbance surveys be conducted prior to signing NEPA decisions or decision documents for habitatdisturbing activities. Habitat-disturbing activities are defined as those disturbances likely to have a 

significant negative impact on the species’ habitat, its life cycle, microclimate, or life support 

requirements.

Pre-disturbance surveys are not necessary or required prior to invasive plant treatments for Survey and 

Manage vertebrate and mollusk species. The invasive plant treatments proposed do not create habitatdisturbance or have a significant negative impact on species’ habitat, life cycle, microclimate, or life 

support requirements. The following analysis provides the rationale for why the invasive plant treatments 

are not habitat disturbing.

Table 36. Survey and Manage Species on the MBS

Common Name Scientific Name Survey and Manage

Category Management Direction

Larch Mountain 

Salamander Plethodon larselli

A (Rare, Predisturbance surveys 

practical)

Manage All Known Sites, 

Project Level Surveys Prior 

to Habitat Disturbing 

Activities, Strategic Surveys

Van Dyke’s 

Salamander Plethodon vandykei

A (Rare, Predisturbance surveys 

practical)

Manage All Known Sites, 

Project Level Surveys Prior 

to Habitat Disturbing 

Activities, Strategic Surveys

Puget Oregonian Cryptomastix devia

A (Rare, Predisturbance surveys 

practical)

Manage All Known Sites, 

Project Level Surveys Prior 

to Habitat Disturbing 

Activities, Strategic Surveys

Larch Mountain and Van Dyke’s salamander were previously discussed in the above section on Forest 

Service Sensitive species.

Puget Oregonian 

The Puget Oregonian snail is found from southern Vancouver Island, B.C. south through the Puget Trough 

and western Cascade Range in Washington to the Oregon side of the Columbia River Gorge. This species 

may be found in low- to mid-elevation mature or old-growth forest habitat (less than1500 feet elevation), 

typically this snail’s habitat consists of mature to late-successional moist forest and riparian zones, 

springs, and seeps where canopy cover is generally high. Rocks and talus, which are cool and moist 

beneath, may also be used. The Puget Oregonian hides under logs, moss, leaf litter, and/or talus; often 

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under, near, or on large (greater than 20 inches d.b.h.) big-leaf maple (Acer macrophyllum) and vine 

maple (Acer circinatum). However, despite surveying in apparently suitable habitat over the past 14 years, 

the species has not been detected in on the MBS. 

January 2001 Survey and Manage ROD and Standards and Guidelines - Protection Buffer Species 

These Protection Buffer species includes the white-headed woodpecker, black-backed woodpecker, 

pygmy nuthatch, and flammulated owl. These species are not known to occur on the MBS. 

Bat Roost Sites – The Northwest Forest Plan Standards and Guidelines calls for protection of caves, and 

abandoned mines, wooden bridges and buildings that may be used as roost sites by bats, specifically 

fringed myotis, silver-haired bat, long-eared myotis, long-legged myotis, pallid bat, and Townsend’s bigeared bat. These roost site features maybe located at or near the project sites.

Birds of Conservation Concern and Migratory Birds/Landbird Conservation

The MBS lies within Bird Conservation Region Five (Northern Pacific Forests). Within this region, the 

MBS provides significant habitat within Region Five, based on range maps in NatureServe Explorer 

(NatureServe 2005, Ridgely et al. 2003) and forest survey information for five species listed by the 

United States Department of Interior Fish and Wildlife Service (FWS) as “Birds of Conservation 

Concern.” These species include black swift (Cypseloides niger), rufous hummingbird (Selasphorus 

rufus), olive-sided flycatcher (Contopus cooperi) bald eagle (Haliaeetus leucocephalus), and peregrine 

falcon (Falco peregrinus).

In 1999, Partners in Flight released a conservation strategy for landbirds in coniferous forests of western 

Oregon and Washington (Altman 1999). The strategy identifies a select group of focal species and their 

associated habitat attributes that can be used to identify desired forest landscapes. All of the focal species 

identified (Altman 1999, Table 3, p. 20) are found on the Mt. Baker-Snoqualmie National Forest. The 

strategy is intended to help facilitate land management planning for healthy populations of native 

landbirds. The document focuses on landscape-scale forest management, with emphasis on habitat 

structure. The conservation options recommended in the strategy are not relevant to invasive plant 

treatments because the treatments proposed do not involve modifying forest habitat structure or any other 

modifications to native habitat. 

Some land bird (song bird) species on the MBS, including neo-tropical migratory birds, use mixed 

conifer/deciduous forests for nesting and foraging. Suitable nesting and foraging habitat is likely adjacent 

or near to proposed activities. The proposed activities are located in the area covered by the OregonWashington Partners in Flight Bird Conservation Plan for west side coniferous forests. The vegetation 

throughout the Forest provides habitat for focal species. Young and old forest habitat is represented on the 

Forest and considered adequate for conservation of priority bird species. Lists of landbirds common to the 

MBS are available in the Wildlife Biologist’s Specialist Report.

Additional Wildlife Concerns

Big Game: Deer and Elk 

These two species are known throughout the MBS. Deer and elk provide recreational, aesthetic, spiritual, 

and subsistence values to residents of northwestern Washington. There are two established herds of elk 

that reside on the Forest as year-round residents, as well as a few individuals that are migratory.

Deer occur throughout the forest, and both species use a combination of habitats comprised of cover and 

forage areas that are not too fragmented by road systems. Taber and Raedeke (1980) reported that winter 

mortality, legal harvest, and poaching were the primary causes of elk mortality. Poaching is the second 

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leading cause of mortality to elk in Washington State (WDFW 2004). As one might expect, a high density 

of roads can have a negative impact on elk with increased disturbance from legal hunting and poaching 

(CEMG 1999). 

Numbers of deer and elk have decreased in size over the past 15 years. Foraging habitat may be a limiting 

factor at present, and the availability of forage in the future is a concern. 

The MBS has a Limited Operating Period restriction for projects in winter range from December 1 to 

April 1. The calving area Limited Operating Period is May 15 to July 1. 

Amphibians and Amphibian Decline 

Many species of amphibians in many parts of the world have experienced alarming population declines in 

the past 2 decades. International task forces have been formed and scientists have researched causes. A 

number of studies have documented declines, even in relatively undisturbed habitats (Drost and Fellers 

1996, Lips 1998), while other studies have found some populations to be stable (Pechmann et al. 1991). 

However, detecting actual population declines in amphibian populations is difficult due to the extreme 

annual variation in populations caused by environmental factors, such as drought (Pechmann et al. 1991, 

Reed and Blaustein 1995). 

Potential causes of amphibian declines investigated include ultraviolet radiation (Starnes et al. 2000, 

Adams et al. 2001), pesticides (Bridges and Semlitsch 2000), global warming (Blaustein et al. 2001, 

Crump 2005) habitat loss, non-native predators (e.g. Drost and Fellers 1996, Knapp and Matthews 2000), 

and disease (Muths et al. 2003, Berger et al. 1998, Berger et al. 1999), among others. Results of studies 

are variable and some populations are in decline while others are not. There is no “smoking gun” and all 

the causes are implicated to some degree (Halliday 2005). 

Hayes et al. (2003, 2006) found that exposure to the herbicide atrazine caused hermaphroditism and 

testicular oocytes in African clawed frogs and wild leopard frogs and suggested that this could be concern 

in regard to amphibian declines. Population level effects to amphibians from atrazine exposure are 

unclear as wild leopard frogs were abundant at collection sites for the Hayes et al. study (2003).

Honeybees and Colony Collapse Disorder

The European honey bee (Apis mellifera) is not native to the American continents, but was introduced by 

European settlers in the 1600s. It is widely distributed and commercially produced in the U.S. with 

escaped feral colonies formerly present across most of the country (parasitic mites have destroyed most of 

the feral honey bees across the United States (CCD Steering Committee 2007)). The honey bee is used to 

pollinate agricultural crops and produce honey. The honey bee adds about $15 billion in value to 

agricultural crops each year (Morse and Calderone 2000). 

In 2006-2007, commercial honey bees in North America and other parts of the world experienced 

alarming declines characterized by the disappearance of adult bees from the hives with no or few dead 

bees near the hive; healthy, capped brood; food reserves that have not been robbed; minimal evidence of 

wax moth or hive beetle damage; and a laying queen with immature bees and newly emerged attendants 

(CCD Steering Committee 2007, Winfree et al. 2007). This phenomenon has been termed “colony 

collapse disorder.” By 2007, almost 30 percent of beekeepers in the U.S. reported losses of up to 90 

percent of their colonies (Cox-Foster et al. 2007; Winfree et al. 2007). CCD has not been reported in wild 

native bees (Winfree et al. 2007). 

Suspected causes of CCD include the following factors, alone or in combination: (1) environmental and 

nutritional stress; (2) new and /or re-emerging pathogens; (3) pests that attack bees; and (4) pesticides 

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(CCD Steering Committee 2007). Several major setbacks to honey bee populations over the last 2 decades 

have combined to increase stress on the remaining hives, as they are moved and worked for their 

pollination services over longer seasons and larger geographic areas. Climate change, drought, and 

unseasonably cold weather combine to create increased stress on bee populations. Commercial bees are 

often fed high fructose corn syrup, which may contribute to some nutritional deficiencies. Nutritional 

deficiencies are thought to make the bees more susceptible to attack from pathogen and anecdotal 

evidence indicates that hives that are fed nutritional supplements over the winter are more resistant to 

CCD (Anonymous 2009). 

Pathogens are primary suspect because CCD is transmissible to other hives through the reuse of 

equipment from CCD-affected colonies, and such transmission can be broken by irradiation of the 

equipment before use (Pettis et al. 2007). A recent paper using current gene technology has indicated that 

Israeli acute paralysis virus is strongly correlated with CCD and is a current leading candidate for its 

cause, alone or in combination with other factors (Cox-Foster et al. 2007, Kaplan 2008). Another recent 

paper implicates an infection from the parasite Nosema ceranae, but losses from CCD in hives treated for 

this parasite may differ between European and American hives (Higes et al. 2009, Goodman 2009). 

Pests including the varroa mite, small hive beetle, wax moth, and others stress bees and may harbor 

infectious agents. In particular, the varroa mite has been responsible for catastrophic losses of 50 to 100 

percent in many beekeeping operations and has eliminated most feral bee colonies. In addition, the varroa 

mite is known to carry pathogens transmitted to bees and is thought to suppress the immunity of honey 

bees (Shen et al. 2005). 

Pesticide exposure may affect bees through direct toxicity or by adding additional stress. Beekeepers treat 

hives with miticides and fungicides and bees may be exposed to pesticides while foraging on agricultural 

crops. Currently, the classes of pesticides thought to be the most likely contributors to, and being 

researched for correlation with, CCD include insecticides, miticides, and fungicides (CCD Steering 

Committee 2007). Recent research has found higher-than-expected levels of miticides and traces of a 

wide variety of agricultural chemicals in bee hives, but no consistent pattern in levels or types of 

chemicals identified (Kaplan 2008). 

3.5.3 Environmental Consequences to Wildlife

3.5.3.1 Introduction

The following section is a general overview of the potential impacts to federally listed wildlife from all 

herbicide treatment methods included in the proposed action. Impacts are described for federally listed 

threatened and candidate species, Regional Forester’s Sensitive Species, management indicator species, 

USFWS Birds of Conservation Concern, and Landbirds. For all methods of treatment, Management 

Requirements and Mitigation Measures (MR/MM) could be used to mitigate the majority of these 

impacts.

The MR/MM listed in Chapter 2.4 fulfill R6 2005 ROD Standards 19 and 20 to minimize or eliminate 

adverse effects to wildlife species of concern. These MR/MM are part of the proposed action and are 

mandatory in order to stay within the scope of this effects analysis. 

Effects of invasive plant treatment methods to wildlife were evaluated and discussed in detail in the R6 

2005 FEIS Appendix P, the corresponding Biological Assessment (USDA Forest Service 2005d), project 

files, and SERA risk assessments (2001, 2003, 2004, 2007, 2011). Risk assessments for glyphosate, 

imazapyr, triclopyr, and picloram were updated in 2011 (SERA 2011a-d). These documents indicate that 

disturbance from manual and mechanical treatment pose greater risks to terrestrial wildlife species of 

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local interest than herbicide use. Exposure scenarios used to analyze potential effects from herbicides are 

discussed in Appendix P of the R6 2005 FEIS (pp. 15-17). The potential effects to birds from herbicides 

are listed in Table 4-9 of the R6 2005 FEIS. Some additional exposure scenarios over a threshold of 

concern were identified, however, given the R6 2005 ROD standards and MR/MM associated with this 

project, along with the type of infestations and their location in relationship to wildlife habitats, the 

updated risk assessments do not lead to new findings related to wildlife impacts for this project. 

A summary of direct and indirect effects to terrestrial wildlife species of concern follows:

For spotted owls and marbled murrelets, loud and sudden noises above background or ambient levels 

(those above 92 dB) can cause disturbance that might flush a bird off the nest or abort a feeding attempt. 

Vehicles used to spray roadside vegetation with herbicides do not make noise above 92 dB, based on 

recent field measurements, so no “injury” or “harassment” from noise will occur. Other mechanical 

devises proposed for use on invasive plants include brushing machines, mowers, chainsaws, and string 

trimmers. These tools have the potential to create noise above background levels that may disturb owls or 

murrelets if used close to nests during the early nesting season. Bald eagles and peregrine falcons could 

be disturbed by these same tools, as well as human presence, but eagles and falcons are quite variable in 

their responses to activity and noise in the vicinity of their nests or roosts. 

Small species that lack rapid mobility (e.g., mollusks and salamanders) are vulnerable to crushing or 

injury from people or equipment. 

Invasive plant treatments as proposed would not alter native habitat structure or composition for terrestrial 

wildlife species, including MIS, or bird species included in Birds of Conservation Concern (USDI 2002) 

or the Partners in Flight strategy for landbirds (Altman 2000). In some cases, removal of invasive plants 

could cause a much localized decrease in the amount of vegetative cover provided. Due to the patchy 

nature of the invasive plant infestations, the amount of cover lost would be so small that it is not 

measurable in a meaningful manner. Unlike other management activities, such as timber harvest, invasive 

plant treatments do not reduce habitat available to native wildlife. Likewise, prey availability would not 

be reduced because invasive plants are located in relatively small patches, or along narrow road corridors, 

within and adjacent to the much larger natural habitats in which the prey reside.

Risk from herbicide exposure was determined using data and methods outlined in the SERA risk 

assessments. Tables 8 and 9 in the Biological Assessment for the R6 2005 FEIS (USDA Forest Service 

2005d, pp. 138-140) list the toxicity indices used as the thresholds for potential adverse effects to 

mammals and birds (respectively) from each herbicide. A quantitative estimate of dose using a “worst 

case” scenario was compared to these toxicity indices. There is insufficient data on species-specific 

responses to herbicides for free-ranging wildlife, so wildlife species were placed into groups based on 

taxa type (e.g. bird, mammal), body size, and diet (e.g. insect eaters, fish eaters, herbivores). Quantitative 

estimates of dose for each animal grouping for each herbicide are contained in the project file worksheets.

Data is very limited or lacking on potential adverse effects of herbicides to mollusks and amphibians. 

There is some data to suggest that amphibians may be as sensitive to herbicides as fish (Berrill et al. 1994; 

Berrill et al. 1997; Perkins et al. 2000), so for this analysis, herbicides that pose potential risk to federally 

listed fish (as determined by the quantitative estimates from exposure scenarios) will also be considered 

to pose a risk to amphibians. Glyphosate, picloram, and sethoxydim (not proposed for use in this project)

were identified as posing potential risks to fish in the aquatic species BA (USDA Forest Service 2005d). 

Sulfometuron methyl was specifically tested on amphibians and it may cause malformations, but only at 

very high application rates. Triclopyr used in a broadcast spray scenario may pose a risk to fish and 

amphibians, but a Standard in the Forest Plan restricts triclopyr to selective application methods only, 

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minimizing the opportunity for exposure. In addition, MR/MM were specifically developed to eliminate 

exposure and provide additional protection to mollusks, amphibians and other aquatic species. 

Relyea (2005) found no effect to three species of aquatic snails from the glyphosate formulation 

Roundup. Only glyphosate and picloram have been tested on a terrestrial mollusk; the brown garden snail 

(Helix aspersa). Neither glyphosate nor picloram appeared to pose a risk to the snail (see USDA Forest

Service 2005d, Appendix B). 

Under “worst case” scenarios, mammals and birds that eat insects or grass may be harmed by some 

herbicides and surfactants. Amphibians also appear to be at higher risk of adverse effects due to their 

permeable skin and aquatic or semi-aquatic life history. The 2011 glyphosate risk assessment indicates 

that use of POEA surfactants may be associated with greater impacts that use of glyphosate alone. 

The “worst case” exposure scenarios do not account for factors such as timing and method of application, 

animal behavior and feeding strategies, seasonal presence or absence within a treatment area, and/or 

implementation of MR/MM. Therefore, risk is overestimated when compared to actual applications 

proposed in this EIS. POEA surfactants would not be used in this project. 

Nonetheless, caution in the design and implementation of the project is warranted. In many cases, 

insufficient data is available to allow for a quantitative risk assessment. For instance, there is no 

quantitative scenario for a predatory bird that eats primarily other birds, such as the peregrine falcon, so 

the “fish-eating bird” scenario was used as a surrogate. This scenario likely overestimates the dose to the 

peregrine falcon because the hypothetical fish consumed are from a pond contaminated by a large spill of 

herbicide. These hypothetical fish likely have higher concentrations of herbicide in their bodies (and thus 

a higher dose to the predatory bird) than would a small bird that incidentally ingested herbicide before it 

was preyed upon. Also, data was insufficient to assess risk of chronic exposures for insect-eating birds 

and mammals for several herbicides. 

The limited spatial extent of infestations, which are limited primarily to disturbed roadsides (see Chapter 

2.5), and the limits placed on herbicide applications will reduce exposure of wildlife to herbicides. 

Standards 19 and 20 adopted in the R6 2005 ROD require that adverse effects to wildlife species of local 

interest from invasive plant treatments be minimized or eliminated through project design and 

implementation. In addition, Standard 16 restricts broadcast use of triclopyr, which eliminates plausible 

exposure scenarios. All action alternatives must be designed to comply with these standards.

To account for uncertainty, the Mitigation Measures and Management Requirements (MR/MM) place 

restrictions on how and where herbicides are applied. For example, MR/MM eliminate most broadcast 

herbicide treatments near perennial streams; minimize disturbance to certain habitats during certain times 

of the year; and limit the amount or proportion of certain habitats that may be treated in a 30-day period. 

The Forest Plan Standards and MR/MM ensure that no alternative adversely affects federally listed 

species; results in a trend toward listing of any sensitive species; nor adversely impacts the habitat of 

Management Indicator Species, landbirds, or Birds of Conservation Concern. 

3.5.3.2 Direct and Indirect Effects of Alternative 1 – No-Action Alternative 

Environmental analysis for existing projects (2005 MBS EA and the 2008 Skiyou Island EA) concluded 

that there would be no adverse effects to any federal listed, Forest Service Sensitive, or Management 

Indicator Species. 

Under the No-Action Alternative, herbicide use would be restricted to small sites and few formulations. 

Some infestations would not be effectively treated and would likely continue to expand. See Chapter 3.2 

for more information on the reasons that the No-Action Alternative is not fully effective. Habitat for a 

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variety of wildlife could likely degrade to a point that it becomes unsuitable. Infestations that become so 

well-established that future treatment is cost-prohibitive may result in a permanent loss of wildlife habitat 

(Asher 2000). 

3.5.3.3 Direct and Indirect Effects of Action Alternatives on Threatened and 

Endangered Species

The majority of the treatments proposed would occur in areas that are low quality or non-habitat of the 

wildlife species considered with approximately 44 percent of the treatment site acreages occurring on 

road shoulders, and 18 percent in plantations. There would be 25 percent of the sites along stream 

banks/lake shorelines, with the remaining acreage occurring in a mix of forest lands, wilderness, 

dispersed and developed recreation sites, administrative sites, and other areas. 

Alternative 2 would permit the additional use of aminopyralid, including broadcasting to the water’s edge 

on some larger infestations, but otherwise, it would permit the same amount and types of invasive plant 

treatments as Alternative 3. Aminopyralid is not associated with any herbicide exposure scenarios over a 

threshold of concern to wildlife, whereas, some of the other herbicides pose risks under some, albeit 

unlikely, scenarios. 

However, the effects to wildlife are not substantially different between the alternatives because either 

adverse effects from herbicide exposure are unlikely or not plausible, required MR/MM avoid or 

minimize adverse effects from manual and mechanical techniques, the species are not limited to riparian 

habitats, or the wildlife species are not present within project area units or likely to be present in future 

areas treated under EDRR. 

In regards to noise disturbance, required MR/MM will avoid or minimize adverse effects to most species.

A small amount of noise disturbance due to mechanical mowing may impact nesting northern spotted owl 

and marbled murrelet. 

Endangered Species consultation is underway with the USFWS for all of the federally listed species 

present on the MBS. Consultation for the MBS would use the same MR/MM for northern spotted owl and 

marbled murrelet found in the USFWS Biological Opinion for Effects to Northern Spotted Owls, Critical 

Habitat for Northern Spotted Owls, Marbled Murrelets, Critical Habitat for Marbled Murrelets, Bull 

Trout, and Critical Habitat for Bull Trout from Selected Programmatic Forest Management Activities (Ref 

# 13410-2009-F-0388) for the Olympic National Forest (USDI 2012). 

The Section 7 ESA finding associated with the two federally listed bird species is “may affect, not likely 

to adversely affect,” mainly due to the noise disturbance that may occur using mechanical treatment. 

There is a very low likelihood that herbicide exposure under this project would adversely affect birds. The 

finding for the two mammals (grizzly bear and gray wolf) is “may affect, not likely to adversely affect” 

because the likelihood of adverse impact is minimal. 

Exposure scenarios used to analyze potential effects from herbicides are discussed in the 2005 R6 FEIS 

(Appendix P, pp. 15-17). Site-specific analysis was also conducted for this project, using the MBS 

application rates and updated risk assessments. 

Northern Spotted Owl 

Disturbance: The noise and activities associated with treatment actions have the potential to affect spotted 

owls in the project area. The response of spotted owls to project noise and activities is not well defined 

and is variable among individual owls. Spotted owl responses to noise disturbance range from no 

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apparent reaction, to an alert response where the owls are attentive for the duration of the activity, to a 

flush response (Delaney et al. 1999, p.68). 

Direct effects from invasive plant treatment include disturbance caused by noise, people, vehicles, and 

equipment. The potential for visual disturbance to cause harassment of spotted owls is low. Noisegenerating activities above ambient could potentially cause enough disturbance to result in harassment of 

northern spotted owls during the breeding season. Noise or visual stimuli may interrupt or preclude 

essential nesting and feeding behaviors, cause flushing from the nest or missed feedings of young (USDI 

2012). 

Spotted Owl Responses to Chainsaws and Motorized Equipment: Delaney et al. (1999) reported that 

Mexican spotted owls exposed to chainsaw noise flushed when chainsaws were operated within a distance 

of 344 feet and the Equivalent Average Sound Level (LEQ; average sound level over time) for chainsaws 

was greater than or equal to 46 dBA LEQ (Delaney et al. 1999, p. 68). This sound level (46 dBA) was 

approximately 20–25 dBA above the natural background ambient levels (Delaney et al. 1999, p. 68). 

However, only 2.8 percent (1 of 36) of the chainsaw trials at distances greater than 197 feet resulted in a 

flush response, but over 70 percent of chainsaw trials at distances less than or equal to 197 feet resulted in 

a flush response (Delaney et al. 1999, p. 67). The sound levels associated with the chainsaw tests were in 

the range of 54 to 61 dBA at 197 feet (Delaney et al. 1999 p. 69). 

Delaney and Grubb (2003, p. 22) reported that a northern spotted owl flushed in response to motorcycles 

passing within a distance of 220 feet. Spotted owls did not flush from nests or roosts when motorcycles 

were greater than 230 feet from their location (p. 22) and motorcycle noise was less than 75 dB SEL, 

unweighted (less than 62 dBA SEL, p. 34). The sounds associated with the motorcycle tests were readily 

distinguishable from ambient background levels, which varied from 30 to 38 dBA SEL (Delaney and 

Grubb 2003, p. 35). 

Not all spotted owls exposed to chainsaw or motorcycle noise in these studies flushed, and spotted owls 

that were previously exposed to chainsaw noise were less likely to flush during subsequent exposures, 

suggesting some spotted owls have the ability to tolerate or habituate to such disturbances (Delaney et al.

1999, p. 69). Spotted owls also did not flush from nests during incubation or brooding of nestlings, 

suggesting that spotted owls are reluctant to leave the nest during the early stages of the breeding cycle 

(Delaney et al. 1999, p. 71; Delaney and Grubb 2003, p. 22). However, the researchers in the Mexican 

spotted owl study did not challenge incubating spotted owls with chainsaw noise at distances of less than 

197 feet due to the high flush rates observed for non-nesting birds exposed to chainsaw noise at less than 

197 feet (Delaney et al. 1999, p. 65). Although the samples sizes in these studies were small, there was no 

difference in the reproductive success or the number of young fledged for spotted owls exposed to 

experimental disturbance when compared with non-manipulated owls (Delaney et al. 1999 p. 66; Delaney 

and Grubb 2003, p. 21). 

Temple and Guttiérez (2003, p. 698) conducted experimental chainsaw tests at a distance of 328 feet from 

non-nesting California spotted owls (S. occidentalis). Chainsaw operations at this distance did not induce 

a significant behavioral response in any of the owls (Temple and Guttiérez 2003, p. 700). After looking in 

the direction of the sound, most owls quickly resumed their previous behavior, such as sleeping or 

preening. Consistent with these observations, there was no difference detected in fecal corticosterone 

levels (a hormone that increases with physiological stress) in owls exposed to chainsaw noise and the 

control group (Temple and Guttiérez 2003, p. 700). 

Disruption Distances for Spotted Owls from Chainsaws and Motorized Equipment: The experimental 

disturbance trials indicate that the combination of noise and human activity can cause nesting spotted 

owls to flush in certain situations, even at relatively low levels of noise above the background ambient 

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conditions. Sound levels have been reported for many types of construction equipment (e.g., dump trucks, 

excavators) (FHWA 2006, section 9). However, sound attenuation rates are highly variable based on 

weather, vegetation, and terrain (Pater et al. 2009, p. 792). For example, sound levels recorded in the 

forest canopy are consistently higher than sounds measured at ground level due to a higher a rate of sound 

attenuation at ground level (Delaney and Grubb 2003, pp. 25-26). 

Due to the variability of spotted owl responses to ground-based disturbances and the potential problems 

associated predicting sound attenuation, 195 feet is estimated to be a reasonable distance to assume a 

flush response is likely to occur from ground-based, motorized activities, even for activities that generate 

sound levels that are less than 92 dBA within a distance of 195 feet (e.g., chainsaws and most heavy 

equipment). 

On the MBS, an unknown amount of spotted owl activity centers are located within 195 feet of treatment 

areas where brushing or mowing is currently prescribed. There is also an abundance of un-surveyed 

suitable habitat on the MBS where spotted owls could nest. Mowing and brushing uses machinery that 

can create louder noise, so treatment areas with these methods may disturb owls. Mowing within the Dan 

Creek (TAA-24) and Green Mountain (TAA-32) treatment analysis areas are near suitable habitat. 

Approximately 1.1 acres of suitable habitat at Dan Creek and 1.6 acres at Green Mountain could be 

disturbed during the breeding season. 

However, under this consultation, the majority of individual project areas exposed to disruptive activities 

are small (less than 2 acres), and the duration of the exposure is expected to be brief (hours to 1 day) at 

any one location (e.g., use of mowers, brushing machinery). Individual and roadside sites present a 

relatively low risk to spotted owls due to the limited area exposed to noise and visual disturbance, and the 

short duration of the activities. 

For other areas, the mandatory MR/MM for spotted owls requires that these methods, or others that 

generate sufficient noise (greater than 92 dB), to be conducted farther away than 195 feet, or outside the 

breeding season. This MR/MM will minimize effects to spotted owls because it minimizes or eliminates 

the source of disturbance near nests or suitable habitat.

Therefore, noise from mechanical and manual methods to control invasive plants, including equipment 

used to mow and spray roadside vegetation, “may affect, but is not likely to adversely affect” spotted 

owls. 

Effects of Biological Control: No biological control agent that is currently present in the project area is 

adversely affecting northern spotted owls or their habitat. Future biological control agents used for 

invasive plant control are not likely to target or inadvertently affect habitat or prey of northern spotted 

owls, because they would not affect forest trees nor influence prey availability.

Effects of Herbicides: Exposure scenarios used to analyze potential effects from herbicides are discussed 

in R6 2005 FEIS, Appendix B, p. 461. None of the herbicides proposed for use applied at MBS 

application rates, pose a risk to northern spotted owls. 

Spotted owls are not likely to be directly sprayed, or encounter vegetation that has been directly sprayed, 

because no aerial applications are proposed. Ground applications of herbicide would not reach the upper 

canopies of mature trees where the owls nest and forage.

Spotted owls within Douglas-fir/hemlock forests prey on flying squirrels, which are nocturnal and chiefly 

arboreal. Flying squirrels feed primarily on fungi and lichen. Arboreal owls or their prey are unlikely to 

be exposed to herbicides used within their activity centers in this forest type. 

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However, a worst-case exposure scenario for the spotted owl was conducted using consumption of prey 

that had been directly sprayed and assuming 100 percent absorption of the herbicide. The following 

interpretations of the exposure scenario results are made with the reservation that toxicity data was 

generated from laboratory animals which may not accurately represent potential effects to free-ranging 

wildlife.

At MBS application rates, the estimated doses from the exposure scenarios are all less than the reported 

NOAELs (no-observable adverse effect levels) for all herbicides. Therefore, adverse effects to spotted 

owls from the herbicides considered are not plausible.

Critical Habitat: Invasive plant treatments do not remove or modify any of the primary constituent 

elements that define critical habitat. The action alternatives would have “no effect” to critical habitat for 

the northern spotted owl. 

Marbled Murrelet 

Disturbance: Invasive plant treatments are associated with disturbance that may occur during the marbled 

murrelet nesting season. Direct effects from invasive plant treatment include disturbance caused by noise, 

people, equipment, and vehicles. However, the potential for visual disturbance to cause harassment of 

marbled murrelet is low.

Mowing and brushing uses machinery that can create louder noise, so treatment areas with these methods 

may disturb murrelets. There are an unknown amount of marbled murrelet sites within 100 yards of 

treatment areas that are currently prescribed for brushing or mowing. Noise-generating activities above 92 

dB could potentially cause enough disturbance to result in harassment during the breeding season (USDI 

2012). Vehicles used to spray roadside vegetation with herbicides do not make noise above 92 dB, based 

on the measurements taken, so no adverse effects to the marbled murrelet from noise disturbance will 

occur. Within 10 yards of a nest or un-surveyed suitable habitat, roadside spraying could create a brief 

noise of notice to marbled murrelets (e.g., slightly above 70 dB), but not loud enough to create 

disturbance resulting in “harassment” or “injury” (USDI 2012). 

Mowing and brushing uses machinery that can create louder noise, so treatment areas with these methods 

may disturb owls. Mowing within the Dan Creek (TAA-24) and Green Mountain (TAA-32) treatment 

analysis areas are near suitable habitat. Approximately 1.1 acres of suitable habitat at Dan Creek and 1.6 

acres at Green Mountain could be disturbed during the breeding season. The majority of individual 

project areas exposed to disruptive activities are small (less than 2 acres), and the duration of the exposure 

is expected to be brief (hours to 1 day) at any one location. 

These individual and roadside sites present a relatively low risk to murrelets due to the limited area 

exposed to noise and visual disturbance, and the short duration of the activities. However, as described 

above, with a low average number of daily feedings, there is low potential for a missed feeding that 

disrupts normal growth and results in injury or developmental risk to a chick. 

Murrelets would be exposed to noise and visual disturbance associated with treatment activities despite 

the low extent of treatments adjacent to habitat. The project includes MR/MM that all noise generating 

treatment activities that occur within or adjacent to murrelet nesting habitat would only occur 2 hours 

after official sunrise, and would cease 2 hours prior to official sunset during the murrelet nesting season 

(April 1 to September 23). This restriction reduces the potential to disrupt murrelets during their daily 

peak activity periods for feeding and incubation exchanges, but it does not ensure that all murrelets would

be protected from disturbance under all circumstances. 

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For other areas, mandatory MR/MM for marbled murrelets requires that these methods, or others that 

generate sufficient noise, be conducted farther away than 100 yards, or outside the breeding season. This 

would minimize any potential disturbance. This MR/MM would minimize effects marbled murrelets 

because it minimizes or eliminates the source of disturbance near nests or suitable habitat. 

Therefore, noise from mechanical and manual methods to control invasive plants, including equipment 

used to mow or spray roadside vegetation, “may affect, but is not likely to adversely affect” marbled 

murrelets. 

Effects of Biological Control: No biological control agent that is currently present in the project area is 

adversely affecting marbled murrelet or their habitat. Future biological control agents used for invasive 

plant control are not likely to target or inadvertently affect habitat of marbled murrelet, because they 

would not affect forest trees. Since murrelets forage in the marine environment biological control agents 

would not influence prey availability.

Effects of Herbicide: None of the herbicides proposed for use, applied at proposed MBS application rates, 

pose a risk to marbled murrelets. Marbled murrelets are not likely to be directly sprayed, or encounter 

vegetation that has been directly sprayed. The proposed ground applications of herbicide would not reach 

the upper canopies of mature trees where murrelets nest.

Murrelets feed on marine fish, which would not be exposed to herbicides from control of invasive plants 

on lands administered by the Forest Service. It is not plausible for their primary prey to be exposed to 

herbicides considered in this analysis. However, some murrelets in some locations have been reported to 

feed upon some freshwater fish (Carter and Sealy 1986). Therefore, in order to investigate a worst-case 

scenario for exposure, a scenario involving the consumption of contaminated fish was analyzed. The 

potential for the herbicides included in the action alternatives to adversely affect marbled murrelets was 

determined using quantitative estimates of exposure from worst-case scenarios. The dose estimates for 

fish-eating birds were calculated using herbicide concentrations in fish that have been contaminated by an 

accidental spill of 200 gallons into a small pond.

Assumptions used include no dissipation of herbicide, bio-concentration is equilibrium with water, 

contaminant level in whole fish is used, and upper estimate assumes 15 percent of body weight eaten/day. 

For chronic exposures, a bird is assumed to consume fish from water contaminated by an accidental spill 

over a lifetime. All estimated doses used in effects analysis were the upper levels reported in the Forest 

Service/SERA risk assessments.

The following interpretations of the exposure scenario results are made with the reservation that toxicity 

data was generated from laboratory animals that may not accurately represent potential effects to freeranging wildlife. The results of the exposure scenarios indicate that herbicide use for this project would 

not pose any plausible risk to birds from eating contaminated fish. All expected doses to fish-eating birds 

for all herbicides are well below any known NOAEL (see R6 2005 ROD, Appendix B). Even if they fed, 

for a lifetime, upon fresh-water fish that had been contaminated by an accidental spill of herbicide, they 

would not receive a dose that exceeds any known NOAEL. Therefore, marbled murrelets would not be 

adversely affected by herbicide use in any proposed alternative. 

Critical Habitat: Invasive plant treatments do not remove or modify any of the primary constituent 

elements that define critical habitat. The action alternatives would have no effect to critical habitat for the 

marbled murrelet.

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Grizzly Bear

Based on past records, grizzly bear may occur in remote areas of the Mt. Baker-Snoqualmie National 

Forest. The herbicide exposure scenario for large mammals consuming contaminated vegetation was used

for the grizzly bear analysis. The foraging habits of grizzly make it possible for them to consume 

vegetation that has been sprayed with herbicide. Quantitative estimates of risk using “worst-case” 

scenarios (upper estimates) found three of the proposed herbicides (clopyralid, picloram, and triclopyr) 

have potential for chronic doses to exceed a threshold of concern, however there is low likelihood of such 

exposures for this project because of the little amount of habitat that would actually be affected compared 

to available habitat. Thus, chronic exposure is not plausible. 

Triclopyr exceeds the toxicity index in an acute scenario (worst case, upper estimates). The grizzly bear 

would have to consume an entire day’s diet of contaminated grass in order to receive this dose. Triclopyr 

would not be broadcast sprayed. Herbicide use would not occur proposed over large areas in which 

grizzly bear would forage. Grizzly bears are unlikely to forage exclusively on treated invasive plants, 

which are not their preferred forage. Also, the patchy nature of the applications makes it unlikely that the 

grizzly bear would forage exclusively on the scattered treated patches.

Invasive plant treatments in suitable habitat would be rare and located primarily along roads. Because it is 

highly unlikely that invasive plant treatments would coincide with grizzly bear presence, there would be 

no adverse effects to them regardless of alternative chosen.

Gray Wolf 

Gray wolves do not likely occur with any regularity on the MBS. For the gray wolf the herbicide 

exposure scenario of a carnivore consuming a contaminated small mammal was used. No herbicide 

exceeded a level of concern in the scenario of carnivore consuming contaminated small mammals. 

Invasive plant treatments in suitable habitat would be rare and located primarily along roads. Invasive 

plant treatments in suitable habitat would be rare and located primarily along roads. Because it is highly 

unlikely that invasive plant treatments would coincide with gray wolf presence, there would be no adverse 

effects to them regardless of alternative chosen.

3.5.3.4 Direct and Indirect Effects of Action Alternatives on Regional Forester Sensitive 

Species

Under all alternatives, two primary effects on sensitive wildlife species are plausible: (1) disturbance and 

trampling from machinery or people treating invasive plants; and (2) risk from herbicide contact, 

particularly to species for which data is not sufficient to allow quantitative estimates of risk. 

Sensitive species’ habitat would be protected in all alternatives because invasive plant treatments do not 

remove suitable habitat for any species, and the majority of infestations occur along highly disturbed 

roadsides that do not provide suitable habitat. The extent of suitable habitat along highly disturbed 

roadsides is very low relative to the amount of suitable habitat that is not within a road corridor.

Results of the analysis indicate that mortality to Forest Service Sensitive Species is highly unlikely and 

effects are primarily limited to very short-term disturbance. No native habitat would be removed. The 

potential for trampling of mollusks is assumed in the analysis, but they are not known to occur in the 

target vegetation or treatment sites and it is not possible to quantify an effect to their population. In the 

absence of clear adverse effects to Forest Service Sensitive Species, no threat to viability of populations 

exists and population-level viability analysis is unnecessary. Treatment of invasive plants would prevent 

loss of habitat and improve habitat that may currently be degraded.

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American Peregrine Falcon

Disturbance: Potential effects of invasive plant treatment methods on falcons are associated with 

disturbance that may occur during the nesting season. Direct effects from invasive plant treatment include 

disturbance caused by noise, people and vehicles. Effects from mechanical methods (e.g., tractors, 

bulldozers, chainsaws, or string trimmers) may occur at greater distances from the project site, because 

machinery creates louder noise.

The critical period in Washington when human activities could disturb occupied nests extends from 

January 1 to August 15 (USDI 2003, p.9). Peregrine falcons are sensitive to human disturbance during 

this time, particularly within sight distance of nest sites. Invasive plant treatments would avoid 

conducting projects that create noise or disturbance above ambient levels in proximity to an occupied nest 

during the nesting season, as required by MR/MM. 

Invasive plant treatments would not result in the removal of falcon nests or suitable habitat, because 

invasive plants do not provide habitat. Projects could occur within suitable habitat. 

Biological Control: No biological control agent that is currently present in the project area is adversely 

affecting peregrine falcon or their habitat. Future biological control agents used for invasive plant control 

are not likely to target or inadvertently affect habitat or prey of peregrine falcons, because they would not 

affect forest trees nor influence prey availability.

Herbicides: There is no quantitative scenario for a predatory bird that eats primarily other birds, such as 

the peregrine falcon, so the “fish-eating bird” scenario and the “mammal-eating bird” were used as 

surrogate scenarios. The fish eating bird scenario likely overestimates the dose to the peregrine falcon 

because the hypothetical fish consumed are from a pond contaminated by a large spill of herbicide. These 

hypothetical fish likely have higher concentrations of herbicide in their bodies (and thus a higher dose to 

the predatory bird) than would a small bird that incidentally ingested herbicide before it was preyed upon. 

Also, the small mammal in the “mammal-eating bird scenario” is directly sprayed. It would be practically 

impossible to directly spray a bird that a peregrine falcon would then immediately prey upon. Herbicide 

analysis indicates that no herbicide dose exceeded the toxicity indices for fish-eating or mammal-eating 

birds even at highest application rates in the “worst-case” scenarios. 

In reality, a peregrine falcon feeding on a bird would not receive a high dose from its prey (as estimated 

by the scenarios) because the herbicides proposed in this EIS are rapidly excreted from animals and do 

not bioaccumulate. In the fish scenario, the fish are still within the contaminated water and therefore have 

some herbicide in their tissues. In the mammal prey scenario the prey has been directly sprayed and is 

covered with herbicide. So, if birds were exposed to herbicides and then subsequently preyed upon and 

consumed by peregrine falcons, the amount of herbicide that the peregrine would be exposed to is likely 

less than that modeled in the “worst case” scenarios using contaminated fish or small mammals.

The mandatory MR/MM would avoid disturbance, and no herbicide exceeded the toxicity indices for fisheating birds even in a “worst case” scenario, so there would be “no impact” to peregrine falcons 

regardless of alternative chosen.

Common Loon

The loon is currently not known to nest on the MBS. They may winter as visitors but are not known as 

breeding residents. Invasive plant treatments are planned to be a combination of herbicide and manual 

techniques and would occur during spring and summer. No dose of herbicide exceeded toxicity indices 

even in a “worst case” scenario. Since the treatments would occur when loons are not likely to be present, 

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and herbicide effects are not plausible, there would be “no impact” to common loons from proposed 

treatments, regardless of alternative chosen. 

Bald Eagle 

There are a total of two bald eagle sites within 0.5 mile of treatment analysis areas. All sites would 

involve the presence of operators or crews. No sites within 0.25 mile propose the use of mechanical 

equipment (motorized string trimmers). The proposed treatments within 0.5 miles of eagle sites are 

primarily along roads that have infestations of invasive plants.

Disturbance: Potential effects of invasive plant treatment methods on bald eagles are associated with 

disturbance that may occur during the nesting season. Direct effects from invasive plant treatment include 

disturbance caused by noise, people and vehicles. Human and vehicle presence can disturb bald eagles 

during the breeding season, causing the birds to leave nests, or stay away from the nest long enough to 

have detrimental effects to eggs or young (USDI 1986). Effects from mechanical methods (e.g. tractors, 

bulldozers, chainsaws, or string trimmers) may be more likely to occur at greater distances from the 

project site, because machinery creates louder noise.

The critical period in Washington when human activities could disturb occupied nests extends from 

January 1 to August 15 (USDI 2003, p.9). Bald eagles are sensitive to human disturbance during this time, 

particularly within sight distance of nest sites. Invasive plant treatments would avoid conducting projects 

that create noise or disturbance above ambient levels in proximity to an occupied nest during the nesting 

season, as required by MR/MM. 

Invasive plant treatments would not result in the removal of bald eagle nest or roost trees, or suitable 

habitat, because invasive plants do not provide habitat. Projects could occur within suitable habitat. 

Two bald eagle nests occur within 0.25 mile of proposed TAAs. Because disturbance is a plausible 

occurrence, all action alternatives may affect bald eagle. However, the MR/MM included in all 

alternatives would minimize the likelihood that disturbance to nesting eagles would actually occur. 

Wintering bald eagles on the MBS can be sensitive to disturbance from October 31 to March 31 (USDI

2003, p. 9). Disturbance near winter roost sites is not likely to occur in any alternative because invasive 

plant treatments generally do not occur during the winter and MR/MM would minimize or eliminate the 

source of disturbance near winter roosts.

Biological Control: No biological control agent that is currently present in the project area is adversely 

affecting bald eagles or their habitat. Future biological control agents used for invasive plant control are 

not likely to target or inadvertently affect habitat or prey of bald eagles, because they would not affect 

forest trees nor influence prey availability.

Herbicides: Herbicides and surfactants applied according to MR/MM, pose no risk to bald eagles. Bald 

eagles are not likely to be directly sprayed, or encounter vegetation that has been directly sprayed, 

because no aerial application is proposed. No ground applications of herbicide would reach the upper 

canopies of mature trees where bald eagles nest.

The potential for the herbicides to adversely affect bald eagles was determined using quantitative 

estimates of exposure from worst-case scenarios. The dose estimates for fish-eating birds were calculated 

using herbicide concentrations in fish that have been contaminated by an accidental spill of 200 gallons 

into a small pond. Assumptions used include no dissipation of herbicide, bioconcentration is equilibrium 

with water, contaminant level in whole fish is used, and upper estimate assumes 15 percent of body 

weight eaten/day. For chronic exposures, we used a scenario where the bird consumes fish from water 

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contaminated by an accidental spill over a lifetime. All estimated doses used in effects analysis were the 

upper levels reported in the Forest Service SERA Risk Assessments. 

The following interpretations of the exposure scenario results are made with the reservation that toxicity 

data was generated from laboratory animals, which may not accurately represent potential effects to freeranging wildlife.

The results of these exposure scenarios indicate that no herbicide poses plausible risk to birds from eating 

contaminated fish. Expected doses to fish-eating birds for all herbicides are well below any known No 

Observable Adverse Effect Level (NOAEL - see R6 2005 FEIS, Appendix B). The weight of evidence 

suggests that adverse effects to bald eagles from NPE or the herbicides included in the action alternatives 

are not plausible.

The MR/MM would avoid disturbance, and no herbicide exceeded the toxicity indices for fish-eating 

birds even in a “worst case” scenario, so there would be “no impact” to bald eagles, regardless of 

alternative chosen.

Harlequin Duck 

Harlequin ducks nest along fast-flowing rivers and mountain streams in the Cascade Range. Invasive 

plant treatments along fast-flowing sections of river and mountain streams are likely to be rare for a 

variety of reasons. Infestations of invasive plants are less likely along swift sections and higher gradient 

streams than in slower river bottom habitat. It is more difficult for seeds and propagules of invasive plants 

to become established in swift water. If invasive plants become established along some swift water areas, 

they may not be treated because terrain and swift water limit access to the infestation. However, some 

invasive plant infestations could be treated in potential harlequin duck habitat with moderate flow. 

Invasive plants may degrade duck habitat if left untreated. 

Disturbance to nesting ducks could occur along the shore from people treating invasive plants either 

manually, with string trimmers (weed whackers), or with herbicides. Manual and mechanical treatments 

are likely to cause more disturbance and of longer duration than treatments with herbicide. However, most 

herbicide treatment projects involve a component of manual or mechanical treatment, so there would be 

some disturbance regardless of the technique used. Duration of disturbance from any method is expected 

to be a maximum of 3 to 4 hours in a single day and only occurring once during the nesting season. 

These ducks eat aquatic invertebrates and fish, so risk from herbicide exposure is evaluated using a “fisheating bird” scenario. A quantitative estimate of dose was calculated for a bird eating contaminated fish 

for 1 day (acute) and for a lifetime (chronic). The fish are from a pond (1000 m2 by 1 m deep) that has 

been contaminated by a spill of 200 gallons of herbicide. No herbicide exceeded a dose of concern for any 

exposure (acute or chronic) at any application rate (typical or highest). Based on available data, adverse 

effects to fish-eating birds from the herbicides in this analysis are not likely.

While harlequin ducks only rarely eat fish, there is not sufficient data to quantitatively estimate dose from 

consuming contaminated insects. Because harlequin ducks are found along swift water, any herbicide that 

inadvertently entered the water would be rapidly diluted and moved downstream. This would greatly 

reduce exposure of this duck and its prey to herbicide. The fish-eating bird scenario seems an appropriate 

“worst case scenario” to use as a surrogate for analysis. Results from this scenario indicate that herbicides 

would not pose a risk of adverse effects to harlequin ducks.

Differences in potential effects between the alternatives would be minor and based on the degree and 

duration of disturbance. However, because some disturbance would still occur with herbicide treatment 

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and herbicide treatments often include manual or mechanical treatments as well; potential differences in 

effects are not substantial enough to differentiate between alternatives. 

The magnitude and duration of any disturbance or herbicide exposure is low level and short term. 

Therefore, treatments proposed “may impact individuals, but are not likely to lead to a trend toward 

federal listing” for harlequin ducks for all action alternatives.

Larch Mountain Salamander

According to database records, Larch Mountain salamander is documented on the Mt. Baker-Snoqualmie 

National Forest. A single detection occurs within a proposed treatment site (33-07r4). There is also 

additional suitable, but un-surveyed, habitat on the forest. Some un-surveyed habitat occurs in forest 

blocks adjacent to roadside treatments. The salamander MR/MM would minimize exposure of this species 

to the herbicides most likely to have adverse effects. Limiting broadcast application of herbicides within 

potential salamander habitat reduces the likelihood and amount of herbicide that could contaminate water, 

soil or rocks used by salamanders. In addition, there is little overlap between the habitat for these 

salamanders and locations of infestations to be treated. Because there is minimal overlap between actual 

treatment sites and salamander habitat, and project design criteria minimize exposure to herbicides, this 

project “may impact individuals, but is not likely to lead to a trend toward federal listing” of these 

salamanders for all action alternatives.

Van Dyke’s Salamander

Mechanical treatments near streams and springs can create ground disturbance that could introduce silt 

into salamander habitat, potentially clogging the gills of the salamanders and resulting in mortality. Little 

is known about the effects of herbicides other than the potential for some herbicides to cause mortality or 

result in malformations of amphibian larvae. Effects of herbicides to amphibians are discussed in the R6 

2005 FEIS (Appendix P, pp. 28-31). 

The aquatic and salamander MR/MM that limit broadcast application of herbicides and apply to all 

alternatives would minimize exposure of salamanders to the herbicides most likely to have adverse

effects. Limiting most broadcast application of herbicides within potential salamander habitat reduces the 

likelihood and amount of herbicide that could contaminate water, soil or rocks used by salamanders. In 

addition, there is little overlap between the habitat for these salamanders and locations of infestations to 

be treated, as suggested by the aquatic influence zone acres described above. Most invasive plants occur 

in more open, drier, and previously disturbed sites. Because there is minimal overlap between actual 

treatment sites and salamander habitat, and MR/MM minimize exposure to herbicides, this project “may 

impact individuals, but is not likely to lead to a trend toward federal listing” of these salamanders for all 

action alternatives.

Wolverine 

Based on past records, wolverines occur in remote areas of the MBS. For the wolverine the herbicide 

exposure scenario of a carnivore consuming a contaminated small mammal was used. No herbicide 

exceeded a level of concern in the scenario of carnivore consuming contaminated small mammals. 

Invasive plant treatments in suitable habitat would be rare and located primarily along roads. Because it is 

highly unlikely that invasive plant treatments would coincide with wolverine presence, there would be no 

adverse effects to them regardless of alternative chosen. Low intensity invasive plant treatments are 

unlikely to disturb wolverines. Therefore, treatments would have “no impact” to California wolverine for 

all action alternatives.

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Mountain Goat

Even though the foraging habits of mountain goats make it very unlikely for them to consume vegetation 

that has been sprayed with herbicide, the herbicide exposure scenario of large mammals consuming 

contaminated vegetation was used. Quantitative estimates of risk using “worst-case” scenarios found that 

chronic exposure to clopyralid and picloram at MBS rates would exceed the toxicity index. Acute 

exposure to triclopyr at MBS rates could exceed the toxicity index. However, mountain goat would have 

to consume an entire day’s diet of contaminated grass in order to receive this dose. Herbicide use is not 

proposed over large areas in which mountain goat would forage. Spot spraying and roadside broadcast

spraying of invasive plants are not likely to mountain goats to harmful levels of herbicide because they 

are unlikely to forage exclusively on treated invasive plants, which are not their preferred forage. Also, 

the patchy nature of the applications makes it unlikely that the mountain goat would forage exclusively on 

the scattered treated patches.

Low intensity invasive plant treatments are unlikely to disturb mountain goats. Therefore, treatments 

would have “no impact” to mountain goat for all action alternatives. 

Townsend’s big-eared bat

This bat is known to have roosts on bridges within or near treatment analysis areas. Traffic along the 

roads and the bridges used for roosting was well-established when the bats colonized the bridges.

Roadside treatments typically consist of a boom or nozzle spray attached to a pick-up truck, or a person 

with a backpack sprayer conducting spot sprays of plants. Both treatment methods only take a couple 

minutes to conduct, do not generate noise much beyond the background noise of the road and bridge use, 

and do not occur in close proximity to the bats themselves. Therefore, the likelihood of disturbing 

roosting bats during treatment of roadside invasive plants is remote. Invasive plants near bridges known 

to be utilized by Townsend’s big-eared bats are not likely to adversely impact Townsend’s big-eared bats.

The bats forage over large areas catching insects (primarily moths) in flight or by gleaning from 

vegetation. The small amount of acreage proposed for treatment, scattered in small patches, make it 

unlikely that the bats would forage within treated areas and on insects that have been inadvertently 

sprayed by herbicides. If contaminated insects were ingested, triclopyr and glyphosate could result a dose 

that exceeds the toxicity index. In order to receive this dose, the bat would have to consume nothing but 

contaminated insects for an entire nights feeding. Given the bats foraging habits, it is unlikely that bats 

would be exposed to this amount of herbicide. In addition, because the bats roost in crevices well above 

ground level during the day, it is not plausible that they could be directly exposed to spray of herbicides. 

Data is lacking on risk from chronic exposure to contaminated insects. The likelihood of a chronic 

exposure to contaminated insects is remote, given the small acreages treated and the relatively large areas 

in which bats forage. 

The bats are not likely to forage exclusively within treated areas over a 90-day period (the chronic 

exposure) so there does not appear to be a plausible risk from chronic exposure. Therefore, treatments 

would have “no impact” to Townsend’s big-eared bats for all action alternatives.

Broadwhorl and Shiny Tightcoil

Habitat for these mollusks and any unknown populations would occur off the roads in adjacent suitable 

habitat. The majority of the proposed treatment analysis areas are along disturbed roadsides that do not 

provide suitable habitat for these mollusks. Roadside conditions are more dry and harsh than is suitable 

for mollusks. 

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No invasive plant treatments would remove habitat for mollusks nor would treatments cause large-scale 

microclimate changes within their suitable habitat. Habitat components for mollusks such as down logs 

would remain in place on treatment sites.

In all action alternatives, MR/MM require that treatments avoid known sites or high potential habitat 

when soil moisture is high and these mollusks are most likely to be at or near the surface. This would 

minimize their exposure to herbicides and reduce the risk of mortality by trampling. 

These mollusks are not known within any treatment analysis areas, so there would be “no impact” to these 

mollusk species from any alternative.

Johnson’s Hairstreak

These butterflies occur within coniferous forests which contain dwarf mistletoe. It has been speculated 

that old-growth forests containing mistletoe are particularly suitable for this species although younger 

forests with mistletoe are also suitable. Manual treatments would have no effect. The Johnson’s hairstreak 

is unlikely to be exposed to herbicides because no trees would be treated and no aerial application, which 

could create drift over large trees, is proposed. Invasive plant treatments would have “no impact” on this 

species or its habitat for all action alternatives.

Valley Silverspot 

Invasive plant treatments in suitable habitat or near unknown populations would be rare and located 

primarily along roads. Because it is highly unlikely that invasive plant treatments would coincide with 

valley silverspot presence, it is likely there would be any negative effects to them regardless of alternative 

chosen. Invasive plant treatments “may affect individuals, but is not likely to create a trend towards 

federal listing” for this species for all action alternatives.

Summary of Impact Determinations for Sensitive Species

Table 37 summarizes the reasons for impact determinations for Sensitive Species. 

Table 37. Impact Determinations for Sensitive Species

Common Name Impact 

Determination Reason

American Peregrine 

Falcon No Impact MR/MM minimize potential for disturbance; adverse effects from 

disturbance or herbicides highly unlikely

Common Loon No impact Not likely present in treatment analysis areas; adverse effects 

from disturbance or herbicides highly unlikely

Bald Eagle No Impact MR/MM minimize potential for disturbance; adverse effects from 

disturbance or herbicides highly unlikely

Harlequin Duck

May Impact, not likely 

to lead to federal 

listing (MINL)

May be present in only a few treatment analysis areas, potential 

disturbance is short term and low magnitude, herbicide effect 

highly unlikely

Larch Mountain 

Salamander MINL Low likelihood of disturbance, adverse effects from herbicide 

unlikely, MR/MM minimize potential for effects

Van Dyke’s Salamander MINL Low likelihood of disturbance, adverse effects from herbicide 

unlikely, MR/MM minimize potential for effects

Townsend’s Big-eared 

Bat MINL Not likely present in treatment analysis areas; herbicide effects 

highly unlikely, disturbance unlikely

North American 

Wolverine No Impact Not likely present in treatment analysis areas; herbicide effects 

highly unlikely, disturbance unlikely

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Common Name Impact 

Determination Reason

Mountain Goat No Impact Not likely present in treatment analysis areas; herbicide effects 

highly unlikely, disturbance unlikely

Broadwhorl Tightcoil MINL Low likelihood of disturbance, adverse effects from herbicide 

unlikely, MR/MM minimize potential for effects

Shiny Tightcoil MINL Low likelihood of disturbance, adverse effects from herbicide 

unlikely, MR/MM minimize potential for effects

Johnson’s Hairstreak No Impact Not likely present in treatment analysis areas; herbicide effects 

highly unlikely, disturbance unlikely

Valley Silverspot MINL Low likelihood of disturbance, adverse effects from herbicide 

unlikely, MR/MM minimize potential for effects

3.5.3.5 Direct and Indirect Effects of Action Alternatives on Management Indicator 

Species

The invasive plant treatments proposed in all action minimize or eliminate effects to non-target native 

vegetation. These treatments would not remove native trees or alter native habitat structure. Proposed 

treatments would improve cover of native plants within treated areas. Habitat for pine marten, mountain 

goat, pileated woodpecker, and primary cavity excavators is not substantially affected by invasive plants, 

nor would it be affected by invasive plant treatments. Results of the analysis indicate that mortality to 

Forest Service MIS is highly unlikely and effects are primarily limited to very short-term disturbance. No 

native habitat would be removed. In the absence of clear adverse effects to all MIS, no threat to viability 

of populations exists and population-level viability analysis is unnecessary. Treatment of invasive plants 

would prevent loss of habitat and improve habitat that may currently be degraded. 

Pileated Woodpecker

To analyze the effects of herbicides to the pileated woodpecker the scenario of birds consuming insects 

was used. There project area units that are in forested habitat or wildfire areas where herbicides could be 

used for invasive plant treatment. Species that forage and nest in trees are not likely to be exposed to 

herbicides because no trees would be treated and no aerial application, which could create drift over large 

trees, is proposed. However, the pileated woodpecker may feed on the ground or in low shrubs or on logs 

for a substantial portion of their diet. They may encounter contaminated insects. No herbicides except 

triclopyr (which cannot be broadcast sprayed) are a concern at typical application rates. MR/MM restricts 

application of triclopyr to the lowest effective rate. In addition, triclopyr would primarily be used for 

control of scotch broom and Himalayan blackberry, species that do not provide nesting or foraging habitat 

for the pileated woodpecker. 

Given the varied diet and movement of these birds, it is very unlikely that they’d forage exclusively 

within one patch of treated invasive plants and actual doses exceeding levels of concern are unlikely. This 

species is not susceptible to the low magnitude, extent, and duration of disturbance caused by treating 

patches of invasive plants. Invasive plant treatments would not cause adverse effects to these species as a 

result of human or mechanical disturbance. No likely adverse effects from disturbance or herbicide 

exposure would occur in any alternative. Invasive plant treatments would not contribute to a negative 

trend in viability (negatively impact ability to meet the target population levels or habitat goals) the 

pileated woodpecker on the MBS. 

Marten

Invasive plants are not typically found in the mature forest habitat types preferred by the marten. No 

herbicide exceeded a level of concern in the scenario of carnivores consuming contaminated small 

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mammals. Invasive plant infestations are unlikely to occur in marten habitat except along disturbed 

roadsides, so disturbance to martens from manual or mechanical treatments are not likely to occur. Since 

there are no likely adverse effects from disturbance or herbicide exposure, there is no appreciable 

difference in effects between alternatives. Invasive plant treatments would not contribute to a negative 

trend in viability (negatively impact the ability to meet target population levels or habitat goals) of the 

American marten on the MBS.

Primary Cavity Excavators 

To analyze the effects of herbicides to the primary cavity excavator group the scenario of birds consuming 

insects was used. 

Herbicides may be used forested habitat or wildfire areas. However, primary cavity excavators are not 

likely to be exposed to herbicides because trees are would not be treated. Aerial spraying that could create 

drift over large trees is not proposed. Glyphosate and triclopyr (which cannot be broadcast sprayed) are a 

concern at MBS application rates under unlikely “worst case” estimates. Invasive plants do not provide 

nesting or foraging habitat of any of the species within the primary cavity excavator group. 

Given the varied diet and movement of these birds, it is very unlikely that they would forage exclusively 

within one patch of treated invasive plants and actual doses exceeding levels of concern for any herbicide 

or surfactant are unlikely. None of these species are susceptible to the low magnitude, extent, and duration 

of disturbance caused by treating patches of invasive plants. Invasive plant treatments would not cause 

adverse effects to these species as a result of human or mechanical disturbance. Since there are no likely 

adverse effects from disturbance or herbicide exposure, there is no appreciable difference in effects 

between alternatives. Invasive plant treatments would not contribute to a negative trend in viability 

(negatively impact ability to meet the target population levels or habitat goals) of any primary cavity 

excavator on the National Forest. 

3.5.3.6 Direct and Indirect Effects of Action Alternatives on Survey and Manage

Species

The Larch Mountain and Van Dyke’s salamanders are addressed above as Sensitive species.

The single Survey and Manage mollusk (Puget Oregonian) is associated with a variety of moist forest and 

they retreat into down wood, leaf litter, and moist areas during the dry summer months (May or June 

through September). Mollusk habitat and any unknown populations would occur off the roads in adjacent 

suitable habitat. The majority of the proposed treatment analysis areas are along disturbed roadsides that 

do not provide suitable habitat for this mollusk. Roadsides conditions are more dry and harsh than is 

suitable for mollusks. 

Invasive plant treatments would not remove habitat for mollusks nor cause large-scale microclimate 

changes within their suitable habitat. Habitat components for mollusks such as down logs would remain 

in place on treatment sites.

In all action alternatives, MR/MM require that treatments avoid known sites or high potential habitat 

when soil moisture is high and these mollusks are most likely to be at or near the surface. This would 

minimize their exposure to herbicides and reduce the risk of mortality by trampling. 

This mollusk is not known within any treatment analysis areas, and likely does not occur on the MBS. 

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3.5.3.7 Direct and Indirect Effects of Action Alternatives on Other Species of Concern

Elk and Deer

The effects of herbicides to deer and elk were evaluated using the scenario of large mammals consuming 

contaminated vegetation. The grazing and browsing habits of elk and deer make it possible for them to 

consume vegetation that has been sprayed with herbicide. Quantitative estimates of risk using “worstcase” estimates (upper end) found that chronic exposure to clopyralid and picloram at MBS rates could 

exceed the toxicity index. Acute exposure to triclopyr at MBS rates could exceed the toxicity index.

However, deer or elk would have to consume an entire day’s diet of contaminated grass in order to receive 

this dose. No broadcast spraying is proposed over large areas in which deer or elk would forage. Spot 

spraying and roadside broadcast spraying of invasive plants are not likely to expose deer or elk to harmful 

levels of herbicide because they are unlikely to forage exclusively on treated invasive plants, which are 

not their preferred forage. Also, the patchy nature of the applications makes it unlikely that the deer or elk 

would forage exclusively on the scattered treated patches. Treatments would occur primarily during the 

summer months, a period when deer and elk are not typically found in the winter range or key elk area 

management areas, so they would be very unlikely to be exposed to these treatments.

Invasive plant treatments can create some disturbance, but the level of disturbance would be short term, 

low intensity, and limited extent. The majority of treatment analysis areas are along roads (>70%) where 

existing ambient disturbance occurs regularly. The level of disturbance would not create negative effects 

for these very mobile and wide-ranging species. Invasive plant treatments will have no negative effect on 

deer or elk. Since there are no likely adverse effects from disturbance or herbicide exposure, there is no 

appreciable difference in effects between alternatives. Invasive plant treatments would not contribute to a 

negative trend in viability or negatively impact ability to meet target population levels on the National 

Forest, or the ability to meet the State’s population management objectives. 

Treatment of invasive plants in winter range and key elk management areas, as well as all other areas 

including meadows and along roadsides in meadow habitat would beneficially affect deer and elk by 

preserving native forage species, maintaining or improving nutritional value, and maintaining the longterm suitability of the habitat. Invasive plants can reduce the ability of an area to support deer and elk 

(Rice et al. 1997). Maintaining and improving native herbaceous plants and shrubs would increase the 

nutritional value in these areas and contribute to increased animal health and ability of critical areas such 

as winter range and key elk habitat to support deer and elk. 

Birds of Conservation Concern

The short term (1 day or less), low magnitude, and limited extent (usually 1 acre or less scattered over 

larger areas) of disturbance that would occur with invasive plant treatments would not cause negative 

effects to populations of birds in this category. In addition, raptors in this category are further protected 

from disturbance by MR/MM. 

Effects to bald eagle and peregrine falcon have been discussed previously in the Forest Service Sensitive 

Species sections. Similar to the discussion for MIS, risks of herbicide exposure to the remainder of the 

Birds of Conservation Concern were evaluated by placing them into groups based on diet. 

Insectivorous birds include the black swift and olive-sided flycatchers are not likely to consume enough 

contaminated insects to exceed a level of concern. Invasive plant treatments would have no negative 

effects to these species from either disturbance or herbicide exposure.

Rufous Hummingbird: The rufous hummingbird inhabits open areas and meadows, catching insects and 

sipping nectar. A small amount of exposure to herbicides could amount to a dose of concern because of 

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the very small body size of the rufous hummingbird. These hummingbirds could forage in open areas 

where invasive plants have been treated and possibly glean contaminated insects. It is unlikely that they 

would forage exclusively within a patch of invasive plants. These hummingbirds are not known to heavily 

utilize invasive plants for a nectar source and they prefer tubular flowers where the nectar is deep inside 

the corolla. Native forage plants would not be treated so the nectar is unlikely to be contaminated with 

herbicide. Rufous hummingbirds breed from Alaska south to Oregon. The patchy nature of the invasive 

plant infestations and the multi-state breeding range for this bird indicate that while adverse effects to 

some individual birds cannot be ruled out, there is not likely to be any population-level effect to the 

species from proposed invasive plant treatments on the MBS.

Invasive plant treatments would have no negative effect on Birds of Conservation Concern. Since there 

are no likely adverse effects from disturbance or herbicide exposure, there is no appreciable difference in 

effects between alternatives. Control of invasive plants would protect and improve important habitat for 

many of the birds included in this category. 

Landbirds: Invasive plant treatments proposed on the MBS would not remove habitat of the focal species 

for coniferous forests. No trees would be removed and forest structure would not be altered by proposed 

treatments. Only species that forage or nest near the ground are likely to be exposed to disturbance from 

treatments or herbicides. Of the coniferous forest focal species identified in Altman (1999), the following 

species are most likely to forage or nest near the ground: varied thrush, winter wren, black-throated gray 

warbler, Hutton’s vireo, olive-sided flycatcher, western bluebird, orange-crowned warbler, rufous 

hummingbird (Source: Altman 1999, Marshall et al. 2003). Because these species are not reported to nest 

in invasive plant species targeted for treatment, manual and mechanical treatments are not likely to 

disturb nests of these species.

As discussed above for Primary Cavity Excavators, analysis in the 2005 R6 FEIS (Appendix P) indicated 

herbicide exposures resulting in a dose of concern do not appear plausible for the proposed treatments, as 

detailed above for Primary Cavity Excavators, although risk to some individual birds cannot be ruled out. 

In conclusion, invasive plant treatments would not alter habitat for focal species in the Partner’s In Flight 

land bird conservation strategy. Manual and mechanical treatments are not likely to disturb nests of focal 

species. Some individuals of focal species could be exposed to herbicides by foraging on contaminated 

insects, but the likelihood of any dose of concern is remote. 

3.5.3.8 Direct and Indirect Effects of Action Alternatives on Amphibian Decline

Information on the effect of pesticides on amphibian populations is limited, and the studies that are 

available often focus on the most toxic compounds like insecticides (e.g. Taylor et al. 1999, Bridges and 

Semlitsch 2000, Boone and Semlitsch 2001, Relyea and Mills 2001). Some herbicides are known to have 

adverse effects on amphibians (Hayes 2002, Wojtaszek et al. 2005). 

To date, atrazine is the only herbicide active ingredient that has been implicated in overall amphibian 

declines (Hayes 2002). This herbicide is not proposed for use in this project.

Relyea (2005) implicate the glyphosate formulation Roundup in amphibian decline, but the formulation 

studied contains a toxic surfactant (POEA) that would not be used for this project. Numerous previous 

studies have attributed the toxicity of this formulation to the surfactant and not the glyphosate active 

ingredient (Mann and Bidwell 1999; Perkins et al. 2000). 

The pesticides investigated (e.g., carbaryl, PCB’s, atrazine) all have much higher propensity to 

accumulate in the fatty tissues than the herbicides proposed in this document. For example, Atrazine has 

an octanol/water partition coefficient (Kow) of 481 while the proposed herbicides have a KOW ranging 

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from 2.1 to much less than 1. There is a substantial data gap regarding effects of the herbicides included 

in this analysis and the potential for effects to amphibian populations, but current data on these herbicides 

do not suggest a risk to amphibian populations because they do not accumulate in animal tissues and are 

less persistent, less mobile, and less widely used than pesticides that have been implicated in amphibian 

declines.

Management requirements, mitigation measures and herbicide use buffers have been proposed that 

respond to uncertainty about effects to amphibians from herbicide exposure. Broadcast spraying is 

prohibited and selective application methods are specified near streams, and the herbicide ingredients that 

can be used are limited within certain distances of amphibian habitat.

Direct and Indirect Effects of Action Alternatives on Colony Collapse Disorder

Herbicides have a low likelihood of being implicated in Colony Collapse Disorder (CCD). Other 

pesticides (e.g. miticides) may contribute to conditions that favor CCD. None of the herbicides included 

in the proposed action or alternatives exceeded toxicity values for honey bees at typical application rates. 

At highest application rates, only glyphosate caused any mortality, and this necessitated a direct spray at 

the highest rate. Herbicides are not typically used directly on the agricultural crops that honey bees 

pollinate because they would have a high likelihood of adversely affecting the agricultural crop (unlike on 

grass crops where selective herbicides are used on the crop directly). However, herbicides are used near 

these crops to control invasive plants. 

Herbicides used in the proposed action or alternatives have a very low probability to cause any affect to 

honey bees or contribute to CCD because: (1) treatments on the forest are often in remote locations far 

from commercial bee hives; (2) treatments in the vicinity of bee hives would only entail treatment of 

patches of invasive plants and not a widespread application likely to expose honey bees; (3) these 

herbicides have a low toxicity to honey bees; (4) effects to bees from these herbicides only occurred for 

one herbicide at the highest application rate, which is not applied in a spray application (in practice, 

highest application rates of glyphosate are used in wicking, wiping, or injection applications which are 

unlikely to expose bees). 

Currently, the pathogen Israeli acute paralysis virus and the parasite Nosema ceranae are the leading 

candidates for cause of CCD. In addition, recent studies (Cameron et al. 2011) show that the declining 

species have been reported to have lower genetic diversity and higher infection rates from the pathogen 

Nosema bombi than co-occurring species that are not declining. Causes for the higher susceptibility of 

declining species are unknown, but current research has not suggested that herbicides are a factor. In 

conclusion, neither the proposed action nor any alternatives are likely to have adverse effects on honey 

bees or contribute to the potential cause(s) of CCD.

3.5.3.9 Cumulative Effects of All Alternatives on Wildlife

All project alternatives 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 basis for cumulative effects is discussed in Chapter 3.1.6. Current and proposed invasive plant 

treatments are generally very small (less than 1 acre and often less than 0.1 acre) with patches widely 

scattered across the landscape. 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 limit the size of treatments in any one location in sensitive wildlife habitats.

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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 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.

The analysis assumes that possible repeated treatments within the same season do not overlap in time, or 

result in a cumulative effect. If repeated treatments are necessary it is usually a result of missed plants 

during the first herbicide application or manual treatment effort. In the first instance a second herbicide 

application would not overlap spatially or in time, and in the second scenario, the duration of manual 

treatment and resulting effects are small. See direct and indirect effects for analysis of repeated human 

disturbance to Northern spotted owl and bald eagles. 

The herbicides proposed for use would have no potential to bioaccumulate in any individual animal, and 

the potential for acute exposure is very small. The potential for an animal to be exposed to herbicide is 

limited to the area immediately adjacent to the application site (15-150 feet) and a short window of time 

(24 hours or less). Mobility, persistence, and toxicity are all managed through MR/MM.

Recently completed projects on the MBS include closing and restoring roads; road construction, 

reconstruction and maintenance; vegetation management (mainly thinning); and recreation development 

and maintenance. These projects occur within treatment analysis areas mapped within the project area 

(TAA 4, 15, 19, 23, 26, 27, 41, 43, 44, and 45) where invasive plant treatment sites occur within or near 

the recently completed projects. 

Several projects are currently being implemented or are ongoing on the MBS. These include mining; a 

variety of recreation projects; road repair, closure, reconstruction/improvement, decommissioning and 

maintenance; stream restoration; and vegetation management (thinning and created openings). Projects 

are being implemented in TAA 2, 3, 4, 5, 6, 11 15, 16, 17, 20, 23, 27, 30, 32, 33, 36, 41, 43, 45, 47, 49 and 

53. 

Several projects are planned to be implemented in the foreseeable future. These include recreation and 

site maintenance; road closure, repair and reconstruction; vegetation management (mainly thinning and 

some created openings) and stream restoration. The projects overlap invasive plant treatments proposed in 

TAA 2, 4, 6, 11 14, 19, 23, 32, 33, 38, 32, 43, and 45. These projects may last for several years. 

Negative cumulative effects to any wildlife species considered in this document are unlikely to remove or 

degrade wildlife habitat, pose substantial herbicide risks to wildlife, nor disturb wildlife. Thus, invasive 

plant treatments would not contribute to negative effects even when considering past, present, ongoing 

and foreseeable actions. 

The herbicide use reported for invasive plant treatment near the MBS (see Chapter 3.1.6) is also unlikely 

to affect wildlife on the MBS. The scattered nature of invasive plant treatment would limit the potential 

effects on habitat or individual animals. 

A discussion of cumulative effects to specific species or species groups follows.

Northern Spotted Owl and Marbled Murrelet

Northern spotted owls and marbled murrelets are also exposed to disturbance from vehicle traffic, 

recreation, timber harvest activities, development, and other potential sources of disturbance and habitat 

loss. Projects that are within the range of the northern spotted owl and marbled murrelet that are ongoing 

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or reasonably foreseeable include commercial thinning, road maintenance, road repair, trail maintenance, 

and recreational use.

It is unlikely that there would be negative cumulative effects to northern spotted owls or marbled 

murrelets from the No-Action Alternative or action alternatives when added to past, present or reasonably 

foreseeable actions. Invasive plant treatments would create discountable or no effects from disturbance or 

herbicide exposure, and treatments do not remove or degrade habitat for northern spotted owl or marbled 

murrelet, thus, invasive plant treatments would not contribute additive effects to past, present or 

foreseeable actions. 

Invasive plant treatments involve sites that are small patches, occur primarily along roads, create noise 

that is primarily within ambient noise levels, that would be treated in a matter of minutes, and likely 

repeated only once or twice, if at all, during the treatment season. Invasive plant treatments and activities 

associated with the previously mentioned vegetation management projects would be required to limit 

disturbance when in proximity to known owl nest sites. The probability of an effect from most activities 

in the No Action or either of the action alternatives is so low that it could not be added to other activities 

in a meaningful way. Even the small amount of noise disturbance from mechanical mowing at two 

infested sites, when considered across the landscape, is expected to have an indistinguishable contribution 

to cumulative effects to northern spotted owls or marbled murrelets.

Forest Service Sensitive Species

There would be no cumulative effects to the sensitive species Common loon, bald eagle, Townsend’s bigeared bat, North American wolverine, mountain goat, and Johnson hairstreak. This is because none of the 

proposed invasive plant treatment alternatives would result in any effects to these species that could 

contribute to cumulative effects. 

Invasive plant treatments involve relatively small, well-defined spatial areas. Most treatments are 

confined to patches infested with invasive plants while leaving interspersed native vegetation intact. 

Native wildlife habitat is not removed, modified, or degraded, nor are any hydrologic regimes affected. 

Treatments occur one to three times during a season, generally from late spring to mid-fall. Treatments 

are low intensity and of small magnitude and generally short duration (1 day or less). Given the spatial 

and temporal scale of invasive plant treatments, potential for cumulative effects is low.

Harlequin ducks could be disturbed by recreational activity as well as other activities occurring in riparian 

areas. Many riparian areas on the Forest receive intensive recreation use. Invasive plant treatments could 

add to the disturbance, but are such low magnitude, short duration, and low intensity that no significant 

cumulative effect is likely to occur. Cumulative exposure of harlequin ducks to herbicides could only 

occur for birds that move between the National Forest and other ownerships. Because the herbicides 

proposed for use in this project are rapidly excreted, do not bioaccumulate, and pose low risk to the birds, 

even if exposures occurred from multiple ownerships, they are unlikely to result in any cumulative toxic 

effect to these birds. The upper estimates for chronic exposure in the SERA Risk Assessments account for 

herbicide use on multiple ownerships. Based on available data, this project would not contribute to 

cumulative adverse effects to harlequin ducks. 

Some individual salamanders could be trampled during invasive plant treatments. The magnitude and 

extent of trampling from invasive plant treatments is very low, however, and restricted to a few 

individuals present adjacent to invasive plant species. Trampling from invasive plant treatments are 

unlikely to add significantly to trampling or disturbance from other activities such as recreational 

activities. The alternatives would not contribute to adverse cumulative effects to salamanders because (1) 

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minimal overlap exists between actual treatment sites and salamander habitat, and (2) MR/MM minimize 

potential salamander exposure to herbicides. 

Some individual mollusks could be trampled during invasive plant treatments. The magnitude and extent 

of trampling from invasive plant treatments is very low, however, and restricted to a few individuals 

present adjacent to invasive plant species. Trampling from invasive plant treatments are unlikely to add 

significantly to trampling or disturbance from other activities such as recreational activities. Herbicide use 

and other treatments are unlikely to affect mollusks, this this project does not have the potential to 

contribute to cumulative effects to sensitive mollusks.

The valley silverspot can be found in areas containing a large amount of larval food plants (violets). Few 

invasive plants have been found in areas the valley silverspot may occur. None of the alternatives are 

likely to contribute to adverse cumulative effects to the valley silverspot because few past, current, 

ongoing or future projects overlap silverspot areas, and effects from invasive plant treatments are 

unlikely. 

Management Indicator Species (MIS)

Results of the analysis indicate that mortality to Forest Service MIS is highly unlikely and effects are 

primarily limited to very short-term disturbance. No native habitat would be removed. In the absence of 

clear adverse effects to all MIS, no threat to viability of populations exists and population-level viability 

analysis is unnecessary. Treatment of invasive plants would prevent loss of habitat and improve habitat 

that may currently be degraded. Ongoing and reasonably foreseeable projects including vegetation 

management projects, road maintenance, road repair, trail maintenance, and ongoing recreational use 

would not contribute to cumulative effects to any of the MIS. Therefore, the effects from invasive plant 

treatments would not add to effects from past, present, or future projects. 

Landbirds and Birds of Conservation Concern

Landbirds and Birds of Conservation Concern are negatively impacted primarily by habitat loss and 

fragmentation. Invasive plant treatments do not alter native habitat. Some birds can be harmed by 

insecticide applications, but the current and proposed herbicides have very low toxicities and are not 

expected to add to or accumulate with other herbicide exposures because they are not retained or stored in 

the body. None of the birds or their habitats are significantly affected by invasive plant treatments. Even 

effects to individuals have a very low probability of occurring. In many cases, there would be no effect at 

all to the birds or their native habitats. Therefore, the effects from invasive plant treatments would not add 

to effects from past, present, or future projects to create significant cumulative effects. 

3.5.4 Consistency with Regulations, Policies and Plans

All alternatives would be consistent with the MBS Forest Plan. In addition, all alternatives comply with 

the Northwest Forest Plan (USDA, USDI 1994). The Survey and Manage mitigation measure from the 

Northwest Forest Plan has been litigated and modified since 1994. All alternative comply with the most 

recent Settlement Agreement (July 6, 2011). The alternatives also comply with specific provisions of the 

Endangered Species Act and Migratory Bird Treaty Act. 

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3.6 Soil 

3.6.1 Introduction

The soils analysis focuses on herbicide application and the environment fate depending on site 

characteristics. Soil analysis topics include (1) the risks to soil organisms from treatments, (2) potential 

changes in vegetation cover that could result in soil erosion, (3) changes to plant and soil communities, 

and (4) risk for offsite herbicide transport. 

A primary focus of the site-specific analysis for this project was developing Management Requirements 

and Mitigation Measures (MR/MM) to ensure compliance with the MBS Forest Plan (as amended by the 

R6 2005 ROD). Herbicide risk assessments by the Syracuse Environmental Research Associates, Inc. 

(SERA 2004a-d, 2007, 2011a-d) were used to identify pertinent characteristics of herbicide chemicals 

such as adsorption to soil, solubility in water and half-life of degradation. These herbicide characteristics 

were considered in relation to site-specific soil properties and treatment sites in proximity to streams and 

roads that are hydrologically connected to streams. 

The Groundwater Loading Effect of Agricultural Management Systems (GLEAMS) model was used to 

approximate risk for transport through soil, leaching, and runoff using site physical characteristics 

(available [ONLINE] @ http://www.tifton.uga.edu/sewrl/Gleams/gleams_y2k_update.htm). GLEAMS 

simulations were parameterized for a woodland forested site in fair condition with moderate runoff 

potential. Soils were characterized as loam over sandy loam subsurface that represents the most common 

soil type on the MBS. The highest proposed herbicide application rates were used for the modeling. 

3.6.2 Affected Environment

Invasive plants are most common within disturbed soil environment where light, water and soil nutrients 

are available along with a lack of plant competition (James et al. 2010). Invasive plants have traits that 

enable quick colonization and readily utilize the soil and water resources (Sutherland 2004). Roads have 

high rates of invasive plant establishment from the disturbed right of way and high seed spread from 

passing vehicles (Zouhar 2008, Birsall et al. 2011). Invasive plant spread is common on regularly used 

routes and along less traveled roads such as utility corridors. Much of the spread occurs from road 

maintenance activities including mowing and grading. The road disturbance footprint has gravelly road 

fill emplaced next to dugout ditches, and bared cut slopes. The right-of-ways generally have open light 

conditions to enable vehicle site distance. The seed rain from passing vehicle traffic along with 

transplanted road materials that carry invasive plant seeds creates a constant seed source for invasive 

plants (Zouhar 2008). Vehicle traffic congregation at recreation areas, parking lots and where forest 

management activities have a high potential for spreading invasive plant seeds. 

Within the MBS current invasive plant sites, roadways and past forest management areas make up 76

percent of the invasive plant sites (Table 38). Invasive plants tend to spread on roads, skid trails, and log 

landings that occur within otherwise forested areas that are susceptible to shade tolerant invasive species. 

Recreation areas and administrative sites make up 8 percent of the invasive plant sites. Riparian areas 

account for 5 percent of total invasive plant sites, especially in areas with dynamic seasonal water flow

that create open areas susceptible to invasive plant colonization. Pasturelands comprise 5 percent of total 

known invasive plant sites, including parcels recently acquired by the MBS. Pasturelands can be 

predisposed to invasive plants due to disturbance from past farming, grazing and intensive use around 

outbuildings. Wilderness infestations comprise less than 1 percent of the known sites, probably because

high elevation environments resist invasive plant species growth and public access is more limited in 

wilderness. 

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Table 38. Acreage of Invasive plant Sites 

Sites Percent

Road 44.0

Forest management 28.0

Pasture/open space 5.0

Administrative 3.5

Power lines 0.3

Recreation 6.0

Waterways 5.3

Wilderness 0.7

Other 2.0

The Forest is located along the western Cascade mountain range and has a marine climate with cool 

conditions and abundant moisture from 90 to over 130 inches precipitation annually. Summers and 

relatively mild and dry, and winters are relatively cool and wet. The driest months are July and August, 

which may have a few inches or less of rain. In contrast, winter precipitation averages more than 20 

inches a month. Snowfall is light in the lower elevations and heavy in the mountains (WRCC 2012). 

Most the known weed occurrences on the MBS are below 5,000 feet elevation where the growing season 

is 100 to 160 days or more (NRCS 2003). Saturated conditions from snow-melt or rain limits the invasive 

plant growth, and cold conditions limit the extent of invasive plant spread. Invasive plant populations 

decline below 3,000 feet (Figure 3). Some invasive plants persist in high elevations, including Canada 

thistle, scotch broom and meadow hawkweed. 

Figure 3. Invasive plant sites by elevation range

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One of the dominant site conditions that determine invasive plant presence is the amount of sunlight. 

Shade intolerance is an important limiting growth variable as about 80 percent of the invasive plant 

species found on the MBS are shade intolerant Thus, edge habitats such as roadways, stream banks and 

lakesides favor invasive plants. However, shade tolerant species include periwinkle, elephant ear, holly, 

ivy, lily of the valley, herb Robert, three knotweeds, and jewelweed are particularly problematic as they 

can thrive under a forest canopy. 

Disturbed areas create fertile conditions for invasive plants to thrive. Disturbing soil can increase mineral 

nutrient availability by churning and mixing soil. The churning breaks up organic matter for decomposers 

and stimulates nutrient production much like turning a compost pile. Pasturelands and moderately 

disturbed natural forest and grasslands are known to produce high nutrient levels (Smith et al. 2006). 

Disturbed areas in the lower elevations can be prone to invasive plant growth since nutrient production 

will be higher. Nutrient availability in soil depends on sufficient warmth and moisture (Davidson et al. 

1998, Booth et al. 2004). 

Conditions that resist invasive plants will be less fertile habitat. The natural forest setting may resist 

invasive plants due to the acidic soil conditions. Natural ecosystems are thought to resist invasion where 

native plants have unique relationships with soil organisms to survive stressful growing conditions. 

Spodic soils, common to the MBS from the high rate of leaching, have very low pH at 4.5 to 5.5. The 

acidic conditions favor fungal decomposers which can facilitate plant access to nutrients (Klironomos 

2002, Kulmatiski et al. 2008). 

3.6.2.1 Geological and Soil Context

The relatively recent action of glaciers has limited soil formation across the MBS. Soils need sufficient 

time to advance weathering of the parent rock into subsurface strata. The time since last glaciation was 

end of the Pleistocene, roughly 10,000 years ago. Large river valleys were sculpted from mountain terrain 

when ice sheets covered the MBS. Glaciers left thick beds of unconsolidated sediments filling the basins 

that then became the foundation for soils. Deposits on the mountain sides remain unstable and the 

sloughing action as slopes seek a lower angle of repose continues to inhibit soil formation. Soils have 

formed on somewhat stable surfaces on slopes, valley bottoms and ridge tops. 

The mountainous landscape resulted from plate tectonics that created uplift and volcanism. Western 

Washington has been the leading edge of the North American plate since the early Paleozoic time (540 

million years ago (Ma)), sliding over oceanic plates. The subducted edge of the oceanic plates was pushed 

far beneath the surface, experienced melt, and led to rising magma bodies that eventually expressed as the 

volcanoes of the Cascade Range. Subsequent accretion of islands and micro-continents to the continental 

edge have formed a belt of sedimentary and metamorphic rocks called a terrane (WSDNR 2010). 

The metamorphic rocks that form the terrane dominates the northern part of the MBS, while extrusive 

andesite flows form the bedrock in the southern MBS. The Tertiary age andesite flows center around the 

Rainier strato-volcano. Adjacent to these flows, large areas of volcano-clastic rock such as ashfall tuffs 

and mudflow lahars form the bedrock. Snoqualmie batholith granites and granodiorites, roughly the same 

age as the volcanics, or upper Tertiary in age, become common north of the tertiary volcanics near Mount 

Stuart. The northern half or more of the MBS transitions to schist and gneiss that are part of accreted 

terrane that include large areas of marine sedimentary and ultra-mafic rocks (WSDNR 2010). The shift 

from volcanic to meta-sedimentary and sedimentary rocks is in the vicinity of the North Fork 

Stillaguamish River, along Highway 530. 

The wide river valleys juxtapose with steep rising hill slopes representing the glacial carving and 

considerable uplift of the Cascade Range. For soil development and fertility, accumulated slope materials 

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from surface and mass erosion advance chemical weathering of the parent material. Thus, the foot slope 

deposits have higher fertility than upper slopes. In the southern portion of the MBS, the foot slopes can 

accumulate large fan deposits from landslides and mudflows from the lahar. In the north, deposits may 

accumulate more as foot slope fans. The complex faulting from subduction and resulting volcanism 

creates raw bedrock scarps in this region. These slopes have too steep an angle of repose to hold eroding 

slope material and thus accumulate mainly foot slope material. 

Loess and ash from the Cascade volcanic activity form fertile soils by providing a fine matrix that holds 

water for plant and soil biologic activity (McDaniel and Wilson 2007). An ash mantle persists on leeward 

mountain sides and where slopes remain somewhat stable. Ash and pumice deposits enhance soil depth 

beyond which natural soil formation would have occurred. 

Table 39 shows dominant soil types (NRCS 2003) within the Snoqualmie NF portion of the MBS where 

invasive plant treatments are planned. This information was correlated with older survey data for the 

northern (Mt. Baker) portion of the Forest. The soil types are arranged from valley bottom to highest 

elevation to illustrate the change in growing condition and potential for growth. 

The majority of the invasive plant sites occur on valley bottom and foot slope soils. Soil series on valley 

bottoms include the Snoqualmie, Skykomish, Grotto and Larrupin Series. The growing environment has a 

sustained mean annual temperature (MAT) of at least 44 degree F. Valley bottoms have well developed 

spodosol soils (Grotto Series) on stable old terraces and deeply developed ash rich, andisols on old 

mudflows (Larrupin Series), and less developed inceptisols and entisols where ash overlies till 

(Skykomish Series) and floodplains have recent river deposits (Snoqualmie Series). 

Soils with fewer weed sites occur on spodosols along montane foot lopes and side slopes that have 

slightly colder MAT. These spodosols have very acidic conditions with pH in the range of 4.5 to 5.5. 

Optimum plant growth typically is around 6 to 7 pH. Higher elevations have spodosol soils with these 

similar characteristics, but colder temperatures and snow restrict invasive plant survival.

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Table 39. Common soil types for the Snoqualmie NF (NRCS 2003)

Geomorphic Surface Parent Material Soil Series and 

Taxonomy

Precipitation 

(inches)

MAT* 

(inches) pH Growing Season (days)

Valley bottoms alluvium on low river terraces Snoqualmie Dystric 

Xerothents 50-90 48 6 130-180

Valley bottoms glacial outwash terraces Skykomish Typic 

Vitrixerands 50-80 45 5 130-160

Valley bottom river terraces and 

alluvium terraces/mixed alluvium/glacial till Grotto 

Valley bottom and sideslopes Typic Haplorthods 60-100 45 5.9 130-

160 1600-2800

Valley bottom and colluvial side 

slopes ash over mudflow Larrupin

Mountain slopes Typic Vitixerand 60-90 44 6.4 130-

160 1700-2800

Cirques on lateral moraines ash/cinders mixed with extrusive 

igneous colluvium Pitcher

Mountain slopes Andic Dystroxerepts 55-80 44 6 130-

160 1600-2800

Mountain back slopes ash/ pumice mixed with andesite 

colluvium or till Kaleetan

Mountain slopes Typic Haplohumods 90-130 44 4.6 130-

160 1600-2800

Mountain slopes - cool slopes on 

lower elevations ash/coll/till over till Philippa orstein Humic 

Haplorthods 90-140 44 4.6 150-170

Broad ridges, cirque basin, 

benches ash/pumice over gran/medimorph Teneriffe Typic 

Haplorthods 90-130 44 5.4 130-160

Ridges and mountain side slopes ash and loess over colluv/dense till Kindy 

Ridge crest and mountain slopes orstein Andic Duricryod 75-90 43 5 90-

120 1800-3000

* MAT = mean annual temperature

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3.6.3 Environmental Consequences

3.6.3.1 Spatial and Temporal Context for Effects Analysis 

The analysis area for direct, indirect, and cumulative effects on the soil resource is the treatment analysis 

areas that include the currently known sites along with areas of expected spread (road and stream 

corridors). Treatment of new sites may occur anywhere on the Forest. 

The project duration is approximately 10 to 15 years. Repeated treatments of manual, mechanical or 

chemical methods may be necessary in the same year or sequentially. Effects may last up to 10 years 

depending on degree of soil disturbance or persistence of various chemical herbicides. The proposed 

action also provides for treatment of new infestations or changes to existing infestations during the life of 

the project. 

3.6.3.2 Direct and Indirect Effects from Alternative 1 – No-Action Alternative 

Effects on Soil Organisms

No long-term adverse effects on soil organisms would result from Alternative 1. The effects of the 

herbicide applications were analyzed for the soil resource in the MBS 2005 DN and the 2008 MBS 

supplemental information report and determined to meet a Finding of No Significant Impact for soils. 

Similarly, rates of herbicide application are within the range analyzed and approved in the R6 2005 ROD. 

No adverse effects to soil biological organisms are associated with the use of herbicides under No Action 

(SERA 2004b, 2011b, 2011d). Soil microbes are the primary degradation pathway for these herbicides by 

metabolic decomposition (Anderson and Dulka 1985, Bollag and Liu 1990, Radcliff et al. 2006, Gish et 

al. 2007, also see SERA 2004b, 2011b, 2011d). 

Vegetation Cover and Erosion 

Ongoing manual treatments may lead to small soil disturbance from wrenching invasive plants. Typical 

treatments result in less than 1 square foot loosened soil. Extracting Scotch broom, Himalayan blackberry 

and butterfly bush may lead to larger disturbance up to 2.5 square feet. These disturbances do not 

adversely affect overall site productive capacity since they are small and distributed, and do not lead to 

substantial soil loss. The retained cover of target plant species curtails erosion of loosened soil. Bare soils 

usually remain below 10 percent areal extent for a treatment site.

Changes to Plant and Soil Communities

Alternative 1 would indirectly affect soils since treatments would not be as effective as the action 

alternatives. Ground disturbance in close proximity to already infested ground has high risk for invasive 

plant spread. Isolated populations of invasive plants can quickly spread onto adjoining forest lands where 

the forest canopy is opened up. Seeds of invasive plants can be carried some distance by wind, animals, 

equipment, or even on clothing and shoes. In the absence of effective treatments, invasive weed 

populations would continue to grow along main travel corridors and increase spread risk onto adjacent 

forestland where disturbed. 

Invasive plant colonization of disturbed soil would not directly lower soil productivity, but potentially 

shift the composition of soil organisms and perpetuate early successional conditions. Invasive plants can 

slow plant community development into late seral plants on disturbed ground, which interferes with the 

expected recovery within plantations and other managed areas. 

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Most of the MBS invasive plants are forbs or vines that cover large areas quickly and lessen the diversity 

of native grasses and forbs. Changes away from natural plant communities are accompanied by changes 

in the soil communities (Wardle et al. 2004, Wolfe and Klironomos 2005). Research in the Northeast US 

shows a general tendency for invasive plants to increase the available nitrogen in soil and produce litter 

that’s easier to decompose, shifting the nutrient availability (Ehrenfield 2001, 2003). Since invasive plants 

do well in nutrient rich environments (Bashkin et al. 2003, James et al. 2010), then Ehrenfield’s research 

demonstrates how invasive plants can perpetuate conditions that they thrive in. In contrast, natural forest 

communities have low available nitrogen (Hart et al. 2005), and rely on higher order fungal symbiotic 

relationships to access nutrients. Within the current invasive plant sites, changes away from the natural 

environment would be most substantial for the coniferous forest environments. MBS lands ceded from 

old pasturelands have already moved to a novel microbial community and thus undesired invasive plants 

have less potential to change these soil communities. 

Soil Regulation of Offsite Herbicide Transport 

A tradeoff of using herbicides is the potential risk for treating non-target vegetation from drift and runoff. 

Compact soils or engineered fill within campgrounds or along roads can induce herbicide runoff if a 

rainstorm occurs following treatment. Though dilute, adjacent non-target vegetation can receive herbicide 

laden runoff. Mitigation is in place from prior decisions to lower risk for runoff. A primary measure 

avoids treatment during wet periods and potential rainfall within the following 24 hours to substantially 

reduce offsite transport (SERA 2004b). Clopyralid has higher runoff potential and is effective at lower 

rates, while also having higher solubility. The risk drops dramatically with time since soils adsorb 

herbicide and decompose residues. 

3.6.3.3 Direct and Indirect Effects from Alternatives 2 and 3

The effects of the action alternatives on soils are similar. The only difference between alternatives (use of 

aminopyralid or not) does not result in substantial differences in effects on soils. MR/MM minimize 

impact on soils regardless of herbicide choice. 

Direct adverse effects from the selected herbicides and application rates are not expected for either action 

alternative. Impacts to soils and soil microbial community would largely be secondary, related to removal 

of targeted vegetation and shift to desired plant species. Indirect effects of herbicide runoff and leaching 

would be reduced by soil physical properties that adsorb herbicide residue and decrease surface wash, and 

the level of decomposition in soil to degrade herbicide concentrations. For the MBS, factors such as 

extent of groundcover, compactness of soil, slope percent, and the biological capacity of soil largely 

determine herbicide fate rather than soil type.

Direct Effects on Soil Organisms

The SERA Risk Assessments do not indicate that the proposed herbicides are toxic to the soil microbes at 

the rates proposed for use. The direct effect of herbicides on fungal and bacterial soil microorganisms 

vary with the herbicide used, and even then depend on the residue reaching the soil and the degradation 

rate, or half-life of the chemical. The effect to micro-organisms is usually not gauged by direct 

measurements, but inferred by changes in productivity factors such as respiration (CO2 production), of 

which microbial activity is one cause (SERA 2003a). However, toxicity of herbicides to soil microorganisms may be relevant only in the soil medium itself. Busse et al. (2001) showed that glyphosate, 

which can be toxic to microbes grown directly on the herbicide in the laboratory, had an unmeasurable 

effect on microbes when applied directly to soil in the laboratory or in the field. In a later study on 

glyphosate effects to soil microbial community structure, Ratcliff et al. (2006) showed a sizable increase 

in the bacteria to fungal ratio for the spill scenario (100% solution) and not for the diluted field rate. The 

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increase may be only temporary as bacteria metabolize the herbicide, a labile carbon source, with an 

anticipated return to normal composition as the active carbon supply returns to natural levels.

Of the 10 herbicides approved in the R6 2005 ROD, picloram and sulfometuron methyl were noted to 

have potential affects to soil microbes in laboratory tests but not in field studies (R6 2005 FEIS). The 

action alternatives reduce these risks by limiting frequency and rate of application. Thus, impacts to the 

soil microbial community would largely be indirect, related to removal of targeted vegetation and shift to 

desired plant species. Indirect boosts in decomposition rates may result as soil microbes metabolize dead 

plant tissue. Slight increases in microbial activity may occur as the bacteria break down the herbicide.

The SERA risk assessments identified potential short term decreases in select soil microbes for picloram, 

imazapyr, metsulfuron methyl, and sulfometuron methyl that could occur for higher rate applications than 

the action alternatives propose. The effects were reported from laboratory assays using soil concentrations 

above the amounts expected in soils given the low application rates and the Forest's abundant rainfall. The 

herbicides effects decrease with time as other microbes, less sensitive to herbicide, decompose the active 

ingredient. Table 40 contrasts the microbial decomposition of each herbicide using half-life. Persistent 

herbicides such as picloram have longer half-lives. Impacts to microbes would be least where soils have a 

high degree of productive capacity with adequate organic matter, aeration and moisture. 

Aminopyralid may be used in Alternative 2. The 2007 SERA Risk Assessment does not indicate any risk 

to soil microbes. However, aminopyralid has a very wide range half-life of 14-343 days as reported in the 

SERA Risk Assessment. Due to plausible persistence from slow microbial decomposition, the project has 

limited broadcast spray to once a year (MR/MM 26). Aminopyralid readily breaks down in sunlight with 

a half-life of 61 days (Table 40). The half-life drops dramatically to less than 1 day when exposed to 

water and sunlight, but extends up to 400 days when in groundwater. 

For picloram, the SERA risk assessment cited a slight decrease in the N fixing bacteria Azotobactor for a 

2-week period at picloram concentrations of 10 ppm (see Tu 1994). In general, laboratory assays found 

little detectible changes in microbial activity below 50 ppm soil concentrations (SERA 2011c). Within the 

SERA risk assessment, results from a groundwater loading effects model (GLEAMS) show that for the 

clay, loam and sandy soils the soil concentration after application would be below 10 ppm. GLEAMS 

modeling of picloram application on a MBS sandy-loam soil would result in 0.5 ppm picloram soil 

concentration following treatment. However, the SERA risk assessment indicated acid soils may decrease 

the decomposition rate. Given the acid soils across the MBS because of the abundant rainfall and 

spodosol soils, picloram may have slightly longer residence times. Two mitigation measures address the 

possible picloram buildup in soil. First, repeat applications would be limited to every other year (MR/MM 

26). Second, picloram would not be used on poor soils where microbial decomposition is low (MR/MM 

27). 

For metsulfuron methyl, findings from one study showed slight growth reduction of common soil 

bacterium above 5 ppm (SERA 2004c). These effects increased with dosage. Modeled metsulfuron soil 

concentrations are 0.03 ppm. As with picloram and imazapyr, metsulfuron methyl is known to be 

persistent. The persistence may be desired as a pre-emergent to inhibit weed seeds within a growing 

season. However, evidence exists in agricultural studies that metsulfuron methyl can persist at high 

enough levels to damage the following year’s crops (Yu et al. 2005). Despite the persistence, one of the 

surprising findings of this study was the demonstrated ability of a fungus to rapidly detoxify metsulfuron 

methyl. On the MBS, the persistence of metsulfuron methyl would be lower than the SERA analysis since 

the maximum broadcast rates are less than a quarter the rate used in the SERA report. Furthermore, 

application would be limited to once every other year and avoid poor soils where decomposition rates are 

low (MR/MM 26, 27). This mitigation would prevent herbicide build-up in the soil. 

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Sulfometuron methyl was identified as potentially depressing soil microbial growth from laboratory 

studies (SERA 2004d). Other studies found both no effect and lower impacts to microbial biomass using 

herbicide concentrations near the rates evaluated in the SERA risk assessment. The risk assessment shows 

mixed results with uncertain effects to any particular microbial group. Since herbicide half-life indicates 

the decomposition and thus microbial activity, this provides some indication as to toxicity. Field studies 

demonstrate the half-life ranges from 10 to 100 days (SERA 2004d) with higher decomposition in humid 

climates (Anderson and Dulka 1985). 

The use of sulfometuron methyl would not adversely affect soil microbes since the highest level of 

application is 0.2 lb. a.i./acre, which is half the rate evaluated in the SERA risk assessment where findings 

produced mixed results from the laboratory experiments. An environmental fate study of sulfometuron 

methyl showed that low concentrations in soil followed first order decay equations, suggesting that no 

depression of microbial activity was found (Anderson and Dulka 1985). Soil concentrations in the study 

were 0.14 ppm while modeled soil concentrations of sulfometuron methyl would be 0.03 ppm. The lower 

soil concentration would have even less potential of depressing microbial activity. 

Imazapyr was shown to temporarily depress microbial activity, but again at application rates well above 

proposed rates (SERA 2011a, 2011d). Concentrations of imazapyr in the soil over 20 ppm were reported 

to slow cellulose decomposition by microbes (SERA 2011d). For the MBS, spraying imazapyr could lead 

to soil concentrations up to 0.3 ppm; far lower than the threshold of concern. The reported half-life of 

greater than 200 days indicates imazapyr may resist decomposition. As with other more persistent 

herbicides, the project avoids the use of imazapyr on poor soils and limits the frequency of broadcast 

application to once every other year (MR/MM 26 and 27). 

Triclopyr has reportedly affected fungal and bacterial strains in soil, but at use rates above 10 times the 

intended rate (SERA 2011a). Some fungal strains had detectible changes to growth down to as little as 0.1 

ppm herbicide soil concentrations. When testing natural soil samples, no detectible changes to microbial 

function or community structure was found for a rate of 1.2 lb. a.i./acre (Houston et al. 1998). The typical 

rate for triclopyr on the MBS is 1 lb./acre. Model runs using a high rate at 2 lb./acre show average soil 

concentrations of 0.4 ppm. At this concentration, triclopyr has very low potential for slowing fungal 

growth. 

Table 40. Compiled herbicide properties for mobility in soil and water transport from SERA risk assessments

Herbicide Toxicity to 

Soil Microbes1 Adsorption

Water 

Solubility 

(mg/l)

Degradation

Half-Life (days)

Soil 

Microbes

Water and 

Sunlight

Groundwater

Aminopyralid Low Low 205,000

pH 7 14-343 0.6 127-447

Clopyralid Low Low 1,000 12-70 8-40 261

Chlorsulfuron Low Low; very low 

in clay soils

27,900

pH 7 120-180 Not Known 37-168

Glyphosate Low Strong 12,000 3-130 4-11 50-70

Imazapic No info Moderate >2,670 mg/l 25-142 1-2 30

Imazapyr Slight Low 13,100

210-2154 

(longest in 

anaerobic 

soils)

2-20,

325-500 in 

anaerobic 

conditions

325

Metsulfuron Moderate for Very low 2,790 120 1 1213

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Herbicide Toxicity to 

Soil Microbes1 Adsorption

Water 

Solubility 

(mg/l)

Degradation

Half-Life (days)

Soil 

Microbes

Water and 

Sunlight

Groundwater

Methyl high application 

rates on poor 

soils

Picloram

Moderate for 

high application 

rates on poor 

soils

Very low 200,000 80 to 360 3-14 none

Sulfometuron 

Methyl Low Low 300 10-100 1-14 113

Triclopyr TEA 

(salt) Low Low 8,100 mg/l 14-46 2-6 hours 6 hours

Triclopyr BEE

(ester) Low Moderate 7.4 mg/l 40 0.5-9 No data

1 Reported temporary depressed effects to some microbial groups for imazapyr, metsulfuron methyl, picloram, sulfometuron methyl, 

and triclopyr. Categorical risk is assigned based on proposed use rate compared to laboratory studies outlined in the SERA risk 

assessments.

Vegetation Cover And Soil Erosion

Herbicide application temporarily disturbs soils by altering vegetation cover and reducing the annual 

plant production. The resultant decrease in vegetation cover could increase erosion potential with less 

vegetation canopy to intercept rainfall. Remaining stems and litter from treated plants and existing non 

vegetation would provide groundcover to counter erosion generation. The effect is low and temporary 

since most of the sites susceptible to erosion are administrative. Administrative sites such as roadsides 

and facilities have inherent erosion from compact, engineered surfaces that resist infiltration. The 

treatment of weeds on these sites would not likely increase erosion where designed to shed water.

Treatment of forbs and vines within natural forest area would have retained grasses to counter against 

erosion. These targeted surfaces include skid trails, log landings and haul routes. 

The action alternatives include non-herbicide treatments that generally would have the same risks and 

impacts as the No-Action Alternative. The action alternatives would allow for mechanical treatments such 

as mowing and string trimming would not result in soil disturbance. The action alternatives would also 

add another layer of protection against erosion from manual treatments by requiring seed and mulch for 

manual treatments within 35 feet of water courses. Passive and active restoration would also occur for 

selected areas (see Chapter 3.4 and the Botany Resource Report).

Changes to Plant and Soil Communities

Changes to soil biology from herbicide spraying could occur where plant community composition shifts. 

Dead decaying plant litter would increase microbial decomposition. Where desired plant species increase 

growth after treatment, an antecedent change in soil microbial community could occur. 

Soil Regulation of Offsite Herbicide Transport

Risk for runoff and leaching is low since treatments generally occur during the dry season when about 15 

percent of annual precipitation occurs. Since rain storms increase the risk for runoff, herbicide application 

is avoided if the forecast is for rain. A study by the USFS on road shoulder runoff found that risk for 

runoff is highest during the first day of rainfall (Wood 2001). Herbicide laden runoff decreases as 

herbicide adsorbs to vegetation and soils. 

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Risk for offsite transport of herbicide laden dust is very low from moist conditions on the MBS that 

lowers risk for wind transport. 

Soil conditions on the MBS determine herbicide runoff and leaching more than soil type. Herbicide labels 

list soil texture as a main factor to consider for offsite spread, but the labels refer to agricultural settings 

that have extensive bare soil. However, for the typical application on MBS sites, the main factors that 

regulate herbicide movement include plant cover, groundcover, slope steepness and condition of the soil 

surface. Additional site factors that dictate herbicide transport are the degree of saturation and 

compaction. While soil properties such as texture relate to risk to leaching, in the montane setting 

leaching risks correspond more to the position in the valley bottom, and amount of rainfall that can 

transport herbicide residue downward along a wetting front. 

The model runs for soils displayed in the SERA risk assessments demonstrate the low sensitivity to soil 

parameters. A sensitivity test was done to further investigate the influence of soil type on herbicide 

transport using a variety of soil textures and depths based on local soils data. These results showed that 

most of the offsite transport was controlled by runoff efficiency rather than soil type. Topography, 

resistance to infiltration from compaction or saturation, groundcover and plant interception of rainfall 

influenced runoff more strongly than soil type. 

The highest runoff potential occurs on compact surfaces at forest administration sites and along roads.

Sloped areas with thin soils and bedrock near the surface force lateral soil throughflow to the soil surface 

that then can produce runoff. Cut slopes along roads with rock faces and rocky thin soils on hill slopes are 

circumstances with high potential runoff. Outside of these disturbed or steep thin soil sites, most natural 

forested areas have well drained soils consisting of loam to loamy sand textures and high rock contents in 

excess of 35 percent that facilitate rapid drainage.

Saturated conditions also promote runoff found along valley bottoms and swales, most prominent 

following spring precipitation. Application in late spring could have higher risk for encountering saturated 

conditions after spring snowmelt. Management Requirements and Mitigation Measures (MR/MM)

emphasize herbicide application during the driest conditions. 

Valley bottom and alluvial fan areas that accumulate water draining from adjoining hill slopes have the 

highest potential for leaching. Heavy rainfall following spring would have a higher likelihood of 

transporting contaminants downward since moist antecedent conditions would facilitate percolation. 

Successive rainfall events that transport contaminants downward are rarer during the main period of 

treatment, June through September. The risk for downward percolation is highest for herbicides that have 

a higher residency time and are fairly stable in water. Picloram, imazapyr, and metsulfuron methyl have 

very slow decay rates once they move below the biologically active soil layer (Table 40). 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. 

GLEAMS modeling in the SERA risk assessments showed a relative drop in herbicide concentration as 

herbicides move down into the soil column with most retaining in the top 12 inches where biologic 

activity of decomposers are most active. Similarly, Forest Service monitoring for triclopyr and glyphosate 

in California found that most herbicide adsorbed and decayed in the active soil layer, towards the top 

(Bakke 2000). These findings also were reported by the California Department of Pesticide Regulation 

(Ganapathy 1997). Aminopyralid, though much less concentrated, can reach lower depths given its high 

solubility and low absorption (Table 40). Using the SERA assessments to compare the highly soluble 

herbicide aminopyralid with the less soluble glyphosate, concentrations of aminopyralid in soil were a 

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magnitude lower than glyphosate. However, the SERA analysis predicted trace amounts of aminopyralid 

at depths below glyphosate. 

GLEAMS modeling was done to study the movement of herbicides into the soil column assuming the 

maximum application rates for the project. Figure 4 displays the GLEAMS modeling results for a typical 

forest site. The results also showed the decrease in herbicide concentration with depth, similar to the 

SERA results. In the figure, dot size represents the concentration of herbicide – large dots correlate to 

higher concentration. Dot size does not directly correlate to effects on soil organisms or plants. For 

example, aminopyralid and clopyralid kill plants at lower concentrations than glyphosate or triclopyr. 

However, the relative drop in herbicide concentration with soil depth indicates a decrease in effect for an 

individual herbicide. 

Figure 4 illustrates that most of the herbicides adsorb to soil within the top 20 inches, despite all having 

moderate to high solubility. Below 40 inches, only trace amounts remain. Amounts of aminopyralid are so 

small that they do not show up in the graph. The trace levels shown in Figure 4 for all of the herbicides 

are below detectible levels in the Forest Service field studies reported by Bakke (2000). The topsoil 

organics and mineral matrix bind the bulk of the herbicide in the top inches as reported in monitoring in 

California (ibid.). 

Figure 4. Relative Concentrations (ppb) For Proposed Herbicides in Soil Modeled for Forest Site 

with Wet and Cool Conditions

All the herbicides would have soil concentrations less than the levels of concern for drinking water in the 

upper soil and any leaching into groundwater would be minimal. Percolation of the more soluble 

herbicides could follow a wetting front—most common during spring and fall coinciding with the 

heaviest rainfall. The risk is low because herbicide treatment would be predominantly in summer during 

drier conditions when soils have less chance for leaching (MR/MM 7 and 27). 

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The action alternatives also reduces risk for herbicide buildup on low productivity sites that decay more 

slowly avoiding use of more persistent herbicides on bare or compacted surfaces (MR/MM 24). MR/MM 

26 avoids 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, and aminopyralid 

would not be broadcast in any area more than once per year. This also reduces the potential for herbicide 

build up in the soil. 

Early Detection Rapid Response (EDRR)

The treatment analysis areas represent the range of environmental conditions expected on the MBS, 

thereby accounting for potential consequences. These conditions were used to analyze and produce 

MR/MMs that establish a sufficient layer of protection to limit offsite transport to non-target plants and 

groundwater. New or previously undiscovered infestations of invasive plants would be treated using the 

range of methods described in chapters 2 of the EIS, and in accordance with the MR/MM’s.

EDRR (USDA 2003) is an essential component of the proposed action because the precise location of 

target plants is subject to change, and new infestations may grow substantially in area during the time 

taken to prepare new NEPA documents. The highest risk is for spread along infested roadways from 

disturbed roadways that provide open sites for weeds and high propagule pressure from passing traffic. 

The current use of project design measures and direct spray applications would limit offsite effect from 

runoff, erosion transport and leaching as outlined above. 

3.6.3.4 Cumulative Effects of All Alternatives 

The risk for additive effects from past and ongoing forest management activities is reduced since all 

alternatives retain the current prevention and restoration program. Recent past, ongoing and foreseeable 

future projects on the MBS could affect the soil resource. However, the contribution to potential 

cumulative effects from this project is very low because the extent, magnitude, and duration of the direct 

and indirect effects are low. 

None of the alternatives would adversely affect soils or soil productivity. Thus, there is no potential for 

effects from the action alternatives to contribute to additive, synergistic, or other negative long term 

cumulative effects on soils.

Many of the recent past, current, ongoing and foreseeable future projects outlined in Appendix F create a 

very large disturbance footprint compared to the effects of invasive plant treatments. Recently completed 

projects on the MBS include closing and restoring roads; road construction, reconstruction and 

maintenance; vegetation management (mainly thinning); and recreation development and maintenance. 

These projects overlap with portions of TAA 4, 15, 19, 23, 26, 27, 41, 43, 44, and 45. The potential for 

cumulative effects would limited to areas where invasive plant treatment sites occur within or near the 

recently completed projects. 

Projects that are currently being implemented or are ongoing on the MBS, include mining; a variety of 

recreation projects; road repair, closure, reconstruction/improvement, decommissioning and maintenance; 

stream restoration; and vegetation management (thinning and created openings). These projects overlap 

with portions of TAA 2, 3, 4, 5, 6, 11 15, 16, 17, 20, 23, 27, 30, 32, 33, 36, 41, 43, 45, 47, 49 and 53. 

Foreseeable future projects include recreation and site maintenance; road closure, repair and 

reconstruction; vegetation management (mainly thinning and some created openings) and stream 

restoration. The projects could overlap with invasive plant treatments proposed in TAA 2, 4, 6, 11 14, 19, 

23, 32, 33, 38, 32, 43, and 45. These projects may last for several years. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Soil

Some of these projects include heavy equipment operation that results in soil excavation, compaction and 

soil displacement. However, because there would be no detrimental disturbance25 associated with invasive 

plant treatments, regardless of the disturbance footprint of overlapping projects, the low level of soil 

disturbance associated with invasive plant treatment would not contribute to cumulative detrimental 

disturbance. Invasive plant treatment would have very low disturbance since although live vegetation 

cover is reduced, ground cover would be conserved by retention of non-target species, litter and rock. The 

groundcover protects against erosion. Invasive plant treatment may temporarily depress native vegetation 

cover within some treatment sites, but the objective is to increase desired plant vegetation cover. 

Administrative maintenance on roadways and facilities would have frequent overlap with invasive plant 

treatments due to the engineered surface that attracts noxious weed species and the propagule pressure 

from passing road traffic. Continued road management activities would have regular invasive plant 

treatment needs with ditch clearing and road blading that transplants or buries roadside vegetation.

Current best management practices reduce this risk by promoting vegetative cover. Road maintenance 

best management practices reduce the bare soil along road sides by limiting the frequency (BMP Road-4, 

USDA 2012b) and establishing plant cover after construction and re-construction activities (BMP Road 3, 

USDA 2012b). The MBS’s invasive plant prevention program further reduces risk for overlap of 

herbicide treatments with road maintenance activities and therefore any potential additive effects (see 

MBS 2005 Invasive Plants EA/DN Best Management Practices (USDA 2005c). 

Administrative actions planned that would have one time actions that could interact with invasive plant 

treatments include rehabilitating a campground, removing river riprap and hydro- electric facilities, and 

replacing a utility line. These activities would follow prescriptions to prevent and rehabilitate the sites that 

decrease invasive plant presence. Initially, the actions may involve compacting and excavating soils to 

complete these projects. The overlap would be highest directly after the projects’ completion, tailing off 

as vegetation recovers. Vegetation reductions from treating invasive plants would not result in compaction 

or heavy soil disturbance. 

Treatment of invasive plants would beneficially affect recovery of native plant communities following 

vegetation and road management projects, and effective treatment would prevent invasive plants from 

diverting natural succession of understory species. Within the ongoing timber harvest sites, invasive plant 

treatments would be concentrated along skid trails and log landing sites (Birsall et al. 2011) where revegetation takes longer and weeds readily colonize. These areas typically result in detrimental disturbance 

and cover less than 20 percent of a harvest unit. Timber roads and log landings may remain a hazard for 

weeds to colonize for up to 10 years since these have a disturbed soil footprint. Decommissioned roads 

would also have high initial overlap with invasive plant treatments. Burn piles within timber harvest areas 

attract Canada thistle. Concentrated burning leaves alkaline conditions from the ash, along with abundant 

nutrients and open sites for the thistle to colonize (see Meyer et al. 2009).

25 “Detrimental disturbance” is defined as management activities that physically alter soil and remove organic 

matter, to the extent that soil recovery remains very slow (USDA 1998). In contrast, “low disturbance” is defined as 

short term reductions to vegetation cover that lasts less than ten years (ibid.).

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Forest actions with very low to negligible overlap include maintaining the high elevation ski areas and 

ongoing recreation use at wilderness trailheads and trails. These areas have very small infestations since 

their climate is outside the growth range of most of the listed invasive plants. The Mt. Baker, Stevens 

Pass, Snoqualmie Pass and Crystal Mountain ski areas have bare cut slopes from access roads along the 

open ski slopes with high erosion hazard, leaving barren open areas for invasive plant colonization. 

Despite the bare slopes, only one invasive plant site is recorded within these high elevation areas. 

3.6.4 Consistency with Regulations, Policies and Plans

All alternatives comply with regulations, policies and plans related to protection of the soil resource. 

3.7 Water Resources 

3.7.1 Introduction

The effect of invasive plant treatment on soils and water is a primary public issue. Federal and state laws, 

policies and regulations control the use of herbicides on National Forest System (NFS) lands, including 

the Clean Water Act and the Federal Water Pollution Control Act. Section 208 of the 1972 amendments to 

the Federal Water Pollution Control Act (Public Law 92-500) specifically mandated identification and 

control of non-point source pollution. The Clean Water Act (1972) and Executive Orders 11988, 11990, 

and 12088 provide protection of water resources. Clean Water Act Section 303(d) directed the State of 

Washington to list Water Quality Limited Waterbodies (303(d) listed streams) and develop Total 

Maximum Daily Loads (TMDL) to control the non-point source pollutant causing loss of beneficial uses. 

A National Pollutant Discharge Elimination System (NPDES) permit is required for herbicide use into 

water or adjacent conveyances with a hydrologic surface connection to water at the time of herbicide 

application to satisfy Section 402 of the Clean Water Act. This requirement applies to creeks, rivers, lakes, 

riparian areas, wetland, and other seasonally wet areas when water is present. MR/MM and buffers are 

intended to minimize any pollution discharge to the extent practicable, thus this project conforms to 

current pollution control requirements. This 2300-A general permit would be obtained annually when 

herbicide is used near surface waters (generally within 3 feet of waters of the state or within 3 feet of 

flowing ditches that are connected to the waters of the state 

(http://www.deq.state.or.us/wq/wqpermit/indinfo.htm)). 

The MBS National Forest Plan (USDA 1990, amended by the 1994 Northwest Forest Plan ROD and by 

the R6 2005 ROD for invasive plants) provides direction to protect and manage resources on NFS lands. 

Additional scientific guidance and background information is available within various Watershed

Assessments and the General Water Quality Best Management Practices (1988). The Water Resources 

Specialist Report is incorporated by reference in its entirety.

Waters on the MBS are considered extraordinary under State of Washington 173-201A-600 list. 

Beneficial uses for these waters include: 

§ Core summer salmonid habitat 

§ Salmonid migration, rearing, spawning, and harvesting. 

§ Water Supply (Domestic, Industrial, Agricultural) 

§ Stock Watering

§ Commerce and Navigation

§ Wildlife habitat

§ Recreation (Extraordinary primary contact)

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§ Fish harvesting

The proposed herbicide use in Alternatives 2 and 3 would be done according to State and Federal laws, 

EPA label requirements, SERA Risk Assessments, and standards in the R6 2005 ROD. Site-specific 

mitigation measures would further minimize or eliminate the risks and effects of herbicide applications to 

water resources. 

3.7.2 Affected Environment

3.7.2.1 Watersheds

Watersheds are natural divisions of the landscape and the basic functioning unit of the hydrologic system. 

Watersheds are hierarchical – smaller ones nested within larger ones. Environmental changes commonly 

accumulate and appear on a watershed basis. For the purpose of analyzing and summarizing aquatic and 

vegetative data a hierarchy of watersheds and watershed boundaries was developed by the region using 

U.S. Geological Survey (USGS) protocols. The MBS is entirely located within the Puget Sound basin, 

which represents the largest type of watershed in the hierarchy. The headwaters begin along the Cascade 

Mountains and all water drains down through several watersheds to ultimately be released into the Puget 

Sound, which represents the beginning of the Pacific Ocean with its saline waters and estuaries. While the

general flow pattern through these watersheds is from east to the Puget Sound in the west, there are more 

finite intricacies of smaller watersheds that vary greatly in terms of geology and geomorphic processes. At 

least one treatment analysis area is mapped within every HUC-10 (10 digit hydrological units) watershed 

on the MBS. 

Table 41 shows the estimated infested acres within each watershed located in the MBS and the estimated 

infested acres within aquatic influence zones. The aquatic influence zone is roughly approximated by half 

the distance of a riparian reserve (defined in the Northwest Forest Plan), which vary in width between 50 

foot adjacent to small, intermittent channels and up to over 200 feet in areas of large trees adjacent to fishbearing waters. Treatment within aquatic influence zones present the highest risk of delivery of sediment 

and other contaminants. 

An estimated 53 percent of the infested acreage lies within riparian reserves and 34 percent are located 

within aquatic influence zones. Watershed analyses were conducted between 1995 and 2009 for all 

watersheds on the forest, and these documents were reviewed so that recommendations regarding invasive 

plants were considered in the design of this project. 

Table 41. Estimated Infested Acres in HUC-10 Watersheds 

HUC-10

Watershed

Number

HUC-10

Watershed Name

No. of HUC 12 SubWatersheds 

Containing 

Treatment Analysis 

Areas

Estimated 

Infested 

Acres

Estimated 

Infested Acres 

Within Aquatic 

Influence Zones

1711000101 Upper Chilliwack River 1 0 0

1711000102 Middle Chilliwack River 1 0 0 

1711000401 Upper North Fork Nooksack River 7 233 213

1711000403 Middle Fork Nooksack River 1 0 0 

1711000404 South Fork Nooksack River 2 0 0 

1711000505 Diobsud Creek-Skagit River 4 9 1

1711000506 Cascade River 2 7 3 

1711000507 Baker River 6 9 5

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

HUC-10

Watershed

Number

HUC-10

Watershed Name

No. of HUC 12 SubWatersheds 

Containing 

Treatment Analysis 

Areas

Estimated 

Infested 

Acres

Estimated 

Infested Acres 

Within Aquatic 

Influence Zones

1711000508 Illabot Creek-Skagit River 4 63 7

1711000601 Upper Sauk River 4 330 246

1711000602 Upper Suiattle River 4 0.2 0 

1711000603 Lower Suiattle River 6 235 16

1711000604 Lower Sauk River 6 393 268

1711000701 Finney Creek-Skagit River 4 361 32

1711000801 North Fork Stillaguamish River 6 74 14

1711000802 South Fork Stillaguamish River 6 435 127

1711000901 Tye River 5 156 34

1711000902 Beckler River 3 167 41

1711000903 South Fork Skykomish River 4 309 56

1711000904 North Fork Skykomish River 4 41 20

1711000905 Sultan River 2 1 0.4

1711000906 Wallace River-Skykomish River 1 0.1 0.1

1711000907 Woods Creek-Skykomish River 1 0 0 

1711001001 North Fork Snoqualmie River 1 0 0

1711001002 Middle Fork Snoqualmie River 5 119 61

1711001003 South Fork Snoqualmie River 3 114 25

1711001004 Upper Snoqualmie River 1 50 0

1711001005 Tolt River 1 0 0 

1711001101 Pilchuck River 2 0 0

1711001201 Cedar River 2 0 0 

1711001301 Upper Green River 4 20 7 

1711001302 Middle Green River 1 0 0

1711001401 Carbon River 3 3 0.2

1711001402 Upper Puyallup River 2 0 0

1711001403 Upper White River 8 774 168

1711001404 Lower White River 2 0 0 

Totals 119 3,9031 1,347

1

About 978 acres include more than one invasive plant target species; target species would be treated together where possible.

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

3.7.2.2 Climate and Precipitation

The climate of the northern Cascades is cool and relatively dry summers, mild and wet winters. The driest 

months are July and August, which may have only a few inches or less recorded rain. Winter months on 

the other hand may average over 20 inches. Snowfall is light in the lower elevations and heavy in the 

mountains (WRCC 2012). The precipitation map shown in Figure 4 displays the rainfall averages in the 

northern Cascades, at 60 to 120 inches per year with relatively uniform gradients (WRCC website). The 

low lands lying between the Forest and Puget Sound is in the rain shadow of the Olympic Peninsula, and 

average precipitation is as low as 30 inches or less. 

Figure 5. Precipitation map of Washington State

3.7.2.3 Stream Flow

Daily stream flow from three gages26 located below the MBS with overlapping records and no diversions 

or impoundments are shown in Figure 5. In recent decades, the number of stream gage sites has been 

reduced; in many watersheds only those measuring streams with impounded or diverted flow remain 

operational. For these reasons the years of record shown in the figure are water years 1965-1969. The 

watersheds above the gages are succeeding orders of magnitude—7, 68 and 540 square miles, 

respectively for Hancock Creek, North Fork of the Snoqualmie River and the North Fork Nooksack River. 

Each flows through areas of predominately different rock types. Despite these differences in geology and 

scale the streams responses to precipitation events are very similar suggesting steep terrain and the 

26 Note: Nooksack is 538 square miles, NF Snoqualmie and Hancock, 68 and 7.3 square miles, respectively. Rock 

type for each, noted in map legend, is predominate for the watershed.

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

proximity of steep terrain to the gage sites are the most significant factors in runoff, from large 4th and 

5th order stems to local scale of first and second order channels forming a headwater source. 

Response to precipitation events from the various scale watersheds is close in time, and between them 

nearly identical, with increasing lag between the event and the gage site with increasing watershed size. 

However, the overall pattern is also nearly identical. A short “dry” season is typically June—September, 

with relatively more widely spaced and smaller rainfall. Stream flow drops off steadily toward a base 

flow condition by August, where streams are maintained by groundwater flow by gravity influence alone. 

In the fall, more frequent rainfall quickly “ramps” up stream flow as soil moisture increases. Infiltrating 

precipitation from each succeeding storm builds depth of water stored in the soil, creating a pressure head 

that drives water downward in the soil column until an impeding layer is reach. In low gradient areas, 

valley bottoms, or where underlying rock strata may be horizontal, a water table aquifer is built. On hill 

slopes where soils are typically shallow, the impeding layer is usually the underlying bedrock. Depending 

on amount of fracturing water may either percolate into rock members or flow parallel to bedrock surface.

A mid-winter dip in stream flow occurs January—March, probably because precipitation at higher 

elevations is snow, held there until air temperatures warm. 

Figure 6. Mean daily flow for Three Gages 

3.7.2.4 Water Quality Parameters

The primary water quality parameters that are assessed in this analysis are those parameters that may be 

directly and/or indirectly influenced by invasive plant treatments at any location across the forest, which 

are water temperature, stream turbidity, and the water chemistry parameters of pH and dissolved oxygen. 

These parameters are used as an analysis measure to compare and contrast the effects among the 

alternatives within the document. The analysis of the potential for alternative treatments to affect plants, 

animals, and humans is not located in the water resources chapter but can be found elsewhere in this 

document. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

The objective of the Clean Water Act (CWA) is to restore and maintain the chemical, physical, and 

biological integrity of all waters. The Forest Service responsibilities under the Clean Water Act are 

defined in a 2000 Memorandum of Agreement (MOA) between Washington Department of Ecology and 

the Forest Service. The MOA designates the Forest Service as management agency for the State on 

National Forest System Lands. 

Approximately 17,650 miles of streams flow on the Forest. Approximately 30 percent are perennial and 

70 percent are intermittent. Section 303(d) of the Clean Water Act requires a list be developed of all 

impaired or threatened waters within each state. The Washington State 303(d) list of water quality limited 

streams identifies segments of 6 streams on the Forest as being impaired as of 2008, most of which are 

listed for temperature (Table 42).

Table 42. MBS water bodies listed as impaired under 303(d) of the Clean Water Act

Water Bodies Listed as Impaired Under Section 303(d) of the Clean Water Act

Clearwater River Temperature

Dorothy Lake Dioxin

Gallup Creek Temperature

Huckleberry Creek Temperature

North fork Nooksack River Fine Sediment

South fork Nooksack River Temperature

Skagit River Temperature

Summit Lake pH

While no streams within the project area are listed due to chemical contaminants, Dorothy Lake is listed 

for a chemical contaminant (dioxin) that was found in the tissues of brook trout in 200027 . The source of 

the dioxins is unknown. Brook trout are not native to the area and the fish found in Dorothy Lake were 

most likely stocked there when it served as a fish hatchery. 

The 303(d) list also includes Summit Lake for decreasing pH due to acid rain loading28 (pH is a measure 

of the hydrogen ion activity in water). It is controlled naturally by the carbonate system consisting of 

carbon dioxide, carbonic acid, bicarbonate ions, and carbonate ions. It is a very important factor in the 

chemical and biological systems of water because of its role in affecting the degree of dissociation of 

weak acids and bases and therefore, the toxicity of many compounds and nutrient availability. It

concentrations in streams vary seasonally and during the day due to biological activity. The Washington 

State water quality standard for pH is 6.5 to 8.5. A pH range of 6.0 to 9.0 appears to provide protection for 

the life of freshwater fish and bottom dwelling invertebrates; pH concentrations outside this range can 

affect fish and other aquatic organisms by allowing acids or bases to penetrate external membranes 

causing physiological stresses (KY Water Watch 2005). The listing of Summit Lake is due to pH values 

less than 6.5. These values have been attributed to acid rain conditions that result from coal burning 

power plants (USDA Forest Service 1998). 

The Washington Department of Ecology (WADOE) is responsible for compiling the 303(d) list, assessing 

data, and submitting the 303(d) list to the Environmental Protection Agency (EPA) for federal approval. 

27 Study can be found at http://water.epa.gov/scitech/swguidance/fishstudies/results.cfm

28 Eilers et al. (1996) documented sensitivity to acid rain loading. pH has steadily declined from 5.92 in 1985 to 5.30 

in 1995 and 1996. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

WADOE and EPA typically develop a Total Maximum Daily Load (TMDL) and a Water Quality

Restoration Plan (WQRP) for 303(d) listed water bodies. The TMDL and WQRP address a value of the 

maximum amount of a pollutant that a body of water can receive while still meeting water quality 

standards. WQRP’s (including TMDL’s) have been prepared for Sediment and Stream Temperature in the 

Upper White River (WADOE 2003, WADOE 2007) and for Temperature in the Stillaguamish River Basin 

(WADOE 2004, WADOE 2006). WADOE is just beginning the development of a Temperature TMDL in 

the Skykomish River watershed, and EPA is developing a Temperature TMDL for all NFS lands within 

Western Washington that would protect and restore water temperature conditions in streams 

3.7.2.5 Water Temperature 

The majority of the streams listed as impaired under Section 303(d) of the Clean Water Act within the Mt. 

Baker-Snoqualmie National Forest are listed for temperature. Water temperature is an important factor 

which influences aquatic productivity. Temperature changes may result from natural climatic conditions, 

surface water - groundwater interactions, or human manipulation of in-stream flow and the riparian 

environment. Water temperature is a function of flow, surface area, solar input, air temperature, and other 

variables. Physiological stress in fish would increase as temperatures increase (Beschta 1997). 

The State standard applicable to water ways within or adjacent to the project area is a floating 7-day 

maximum average of 16.0  ̊C and for bull trout spawning and juvenile rearing 12.0  ̊C. 

3.7.2.6 Sediment and Turbidity

Suspended sediment is a measure of suspended sand, silt, clay and organic matter which settle to the 

stream bottom. Sediment may adversely affect fish by filling in pools, reducing bottom fauna, and silting 

in spawning gravels. Sediment delivery to streams is dependent on the degree of soil erosion, slope, 

distance to a stream, amount of exposed soil (effective ground cover), and intensity and continuity of 

disturbance. Invasive plant sites have been found to be more susceptible to erosion than native vegetation 

(Lacey, Marlow, & Lane 1998), although this effect has not been observed in the project area specifically. 

Turbidity is the measure of the ability of light to pass through water. Changes in turbidity may be due to 

the presence of suspended matter such as clay, silt, organic debris, plankton, various effluents. Excessive 

turbidity reduces light penetration into water and therefore, reduces photosynthesis by phytoplankton, 

algae, and submerged vegetation. Turbidity is often used as a surrogate to indicate changes in suspended 

sediment.

State water quality standards applicable to all water ways on NFS lands are established under WAC 173-

201A-200 (1)(e) that directs that turbidity levels should not exceed background levels by 5 

“nephelometric turbidity units” (NTU) when the background is less 50 NTU or less or no more than 10 

percent when the background turbidity is more than 50 NTU. There can be a close correlation between 

turbidity and suspended sediment in a given stream, but this correlation may change as organic material 

increases over the summer or if the percent of sediment from different sources in the drainage changes. 

Turbidity does not measure the amount of sediment being transported as bed load. There is no state 

quantitative standard for suspended sediment, bed load, or total sediment. When streams repeatedly 

exceed state water quality standards for turbidity or other water quality parameters, they become listed as 

impaired water under Section 303(d) of the Clean Water Act. As of the 2008, the North Fork Nooksack 

River is the only stream listed as impaired for fine sediment under Section 303(d) of the Clean Water Act 

(WADOE 2012). 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

3.7.2.7 Municipal Watersheds and Domestic Water Supplies

Ten municipal watersheds are either located within the MBS or capture water that drains off the forest 

(Table 43). Herbicide use within all municipal watersheds would be coordinated with watershed 

managers. 

Approximately 22 acres are currently infested with invasive plants within municipal watersheds, 

primarily along roads and within other disturbed areas (quarries, campsites). None of the infested sites are 

within 1,000 feet of any water intake. 

In addition to the municipal watersheds, special use permits for several surface water intakes are on file 

for individual homes. There are approximately six small water supply systems on the Forest that are 

supplied from well water; the largest of which serves approximately 7,500 people annually at the Alpental 

Ski Area, as well as one small spring that is supplied to the town of Index. All campgrounds use wells as 

water sources.

Table 43. Acres of invasive plants in municipal watersheds on the MBS

Municipal Watershed Name Infested Acres Water Source

Alta Crystal Resort 0 Deep Creek (tributary to White River)

Bellingham 0 Middle Fork Nooksack River

Buckley 0 South Prairie Creek

City of Seattle 0 South fork Tolt River

City of Tacoma 20.1 Green River

Crystal Mountain Ski Area 0 Elizabeth Creek

Everett 1.5 Sultan River

Mt. Baker Ski Area 0 Razor Hone Creek

Scenic (UNINCORPORATED) 0 Scenic Creek

Stevens Pass 0 Tye River

Total infested acres 21.6

3.7.2.8 Aquatic Conservation Strategy

The Aquatic Conservation Strategy (ACS) is an integral part of the 1994 Northwest Forest Plan. The ACS 

was developed to restore and maintain the ecological health of watersheds and aquatic ecosystems within 

public lands. The ACS is intended to meet several objectives toward meeting the goal of healthy 

ecosystems and watersheds. Aquatic Conservation Strategy Objectives are applied over time at site-scale, 

watershed-scale, and broader scales. Effects from invasive plants were considered along with effects from 

treatment. More information about the Aquatic Conservation Strategy is in Chapter 3.8. 

Key Watersheds 

The Aquatic Conservation Strategy also established a system of Key Watersheds to protect areas of high 

water quality and habitat for wild fish populations. Key Watersheds are intended to serve as refugia for at 

risk stocks of native and anadromous fish. Activities to protect and restore aquatic habitat in Key 

Watersheds are higher priority than similar activities in other watersheds. 

Number of known sites and existing estimated acreage of invasive plants within key watersheds on the 

MBS are listed in Table 44. About 73 percent of the invasive plant sites are within Key Watersheds, and 

the spatial extent of these sites add up to about 0.4 percent of the Key Watershed areas.

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

Table 44. Number of sites and acres of invasive plants in Key Watersheds 

Key Watersheds Total Watershed

Area (Acres) 

Spatial extent of 

Inventoried Invasive 

Plant Sites (Acres)

Number of Inventoried 

Invasive Plant Sites

North Fork Nooksack River 103,718 604 32

South Fork Nooksack River 22,176 0 0 

Deer Creek 22,602 47 6 

North Fork Stillaguamish River 51,857 16 6 

Suiattle River 207,297 218 47

Sauk River 201,003 1,137 73

South Fork Stillaguamish River 84,066 433 29

Skykomish River 323,104 1,034 168

White River 103,395 771 294

Middle Fork Snoqualmie River 88,538 134 36

Total 1,207,755 4,394 691 

Invasive Plant Species in Riparian Reserves

Native riparian vegetation plays a key role in forming aquatic habitat for fish and other aquatic species. 

The roots of native vegetation help stabilize stream banks; the forest canopy provides large wood and 

protects streams from solar radiation in the summer. Invasive plants in riparian areas can cause a loss of 

functional riparian communities, loss of rooting strength and protection against erosion, and subsequent 

impacts on water quality (Donaldson 1997). 

Table 45 displays the estimated infested acres, by treatment analysis area (TAA), located within riparian 

reserves and aquatic influence zones. The aquatic influence zone is used to highlight the areas where 

treatment is more likely to risk of delivery of sediment and other contaminants than upslope areas. 

Treatment analysis areas range from fewer than 10 acres (distinct invasive plant population) to more than 

3,300 acres (roadsides or stream banks). The average size of a TAA is about 570 acres. Riparian reserves 

are estimated to average 41 percent of TAA acreage, and about half the acreage of invasive plants are in 

riparian reserves. Currently, invasive plants cover an average of 16 percent of each TAA, scattered within

riparian and upland areas. 

Table 45. Estimated infested acres by Treatment Analysis Area and in Riparian Reserves

Treatment 

Analysis 

Area ID

Treatment Area Name

Total Treatment 

Analysis Area

Acres

Treatment Analysis 

Area Acres

in Riparian 

Reserves

Estimated 

Infested 

Acres

Estimated 

Infested 

Acres in 

Riparian 

Reserves

TAA_01 Evans Creek 420 96 3 < 1 acre

TAA_02 W. Fork White River 923 360 68 39

TAA_03 Greenwater River 1,611 664 396 221 

TAA_04 The Dalles 598 156 295 59

TAA_05 Ranger Creek 166 72 15 2 

TAA_06 Crystal Mountain Blvd 179 106 < 1 acre < 1 acre

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

Treatment 

Analysis 

Area ID

Treatment Area Name

Total Treatment 

Analysis Area

Acres

Treatment Analysis 

Area Acres

in Riparian 

Reserves

Estimated 

Infested 

Acres

Estimated 

Infested 

Acres in 

Riparian 

Reserves

TAA_07 Sunday Creek 271 183 14 12

TAA_08 Road 52 58 37 6 4 

TAA_11 I-90 Corridor King 1,967 1,145 86 62. 

TAA_12 Middle Fork Snoqualmie 

River

644 532 119 107

TAA_13 Bessemer Road System 76 30 < 1 acre < 1 acre

TAA_14 Snoqualmie Point 53 0 50 0 

TAA_15 Martin Creek-Tye River 429 227 45 17

TAA_16 Lower Beckler River 761 305 157 84

TAA_17 Upper Beckler River 183 50 9 1

TAA_18 Rapid River 74 59 < 1 acre < 1 acre

TAA_19 North Fork Skykomish 

River

658 419 41 31

TAA_20 Highway 2 Corridor & 

Miller River

1,000 510 283 127

TAA_21 Money Creek 89 73 26 20

TAA_22 Sultan River 170 53 1 < 1 acre

TAA_23 South Fork Stillaguamish 

River

1,124 586 438 231

TAA_24 Fall Creek 382 332 327 315

TAA_25 Sauk-Whitechuck 

Confluence

3 1 < 1 acre < 1 acre

TAA_26 White Chuck River Road 

23

205 146 3 2 

TAA_27 Darrington South 1,502 812 352 309

TAA_28 Squire Creek 37 26 < 1 acre < 1 acre

TAA_29 Sauk Prairie 214 100 18 6 

TAA_30 Dan Creek 180 45 6 < 1 acre

TAA_31 Prairie Mountain 194 43 3 < 1 acre

TAA_32 Circle Creek-Suiattle 518 207 125 32

TAA_33 Big Creek-Tenas Creek 731 188 107 27

TAA_34 Segelsen Pass Road 18 393 154 72 29

TAA_36 Sedro Woolley 3,373 306 229 3

TAA_37 Crevice Creek 255 99 < 1 acre < 1 acre 

TAA_38 Finney Creek 1,478 652 131 53

TAA_39 South of Rockport 180 132 15 8 

TAA_40 Concrete to Rockport 929 295 64 17

TAA_41 Suiattle Mountain 64 20 < 1 acre < 1 acre 

TAA_43 Baker Lake 1,906 476 9 7 

TAA_44 Glacier Creek Rd 39 126 48 1 < 1 acre

TAA_45 Mt. Baker Highway 542 951 517 2310 220

TAA_46 Canyon Creek 165 71 20 1 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

Treatment 

Analysis 

Area ID

Treatment Area Name

Total Treatment 

Analysis Area

Acres

Treatment Analysis 

Area Acres

in Riparian 

Reserves

Estimated 

Infested 

Acres

Estimated 

Infested 

Acres in 

Riparian 

Reserves

TAA_47 Monte Cristo Townsite 110 52 < 1 acre < 1 acre 

TAA_48 South of Dan Creek 102 28 < 1 acre < 1 acre 

TAA_49 Tonga Ridge 417 147 1110 71

TAA_50 North Bend compound 28 0 280 < 1 acre

TAA_51 Diobsud Creek 2,143 820 90 5 

TAA_52 Marblemount Boat 49 24 70 4

TAA_53 Sulphur Creek 146 108 < 1 acre < 1 acre 

TAA_54 Johnson Ridge 50 2 0 0 

Totals 28,286 11,514 3,906 2,128 

The following treatment analysis areas have infestations that cover more than 10 percent of their riparian 

reserve acreage: TAA 2, 3, 4, 8, 12, 16, 20, 21, 23, 24, 27, 32, 33, 34, 45, 49, 52, and 54. TAA 3, 12, 20, 

23, 24, 27 and 45 have greater than 100 acres of infestation within riparian reserves (TAA 24 has 315 

acres, the greatest amount of all the TAAs).

3.7.2.9 Roads Having Higher Potential for Herbicide Delivery

Roads are the primary conduit for invasive plants to enter the forest. The R6 2005 FEIS describes 

roadside ditches as an herbicide delivery mechanism; potentially posing a higher risk of herbicides 

reaching concentrations of concern for listed aquatic species. Ditches may function as an intermittent or 

perennial stream, extending the stream network. Roadside ditches can act as delivery routes or 

intermittent streams during high rainfalls or as settling ponds following rainfall events. 

GIS was used to identify roads that pose higher risk to fish-bearing streams. Roads located within valley 

bottoms and within 200 feet of fish-bearing streams are considered to pose the highest threat from 

herbicide delivery from herbicide use within the road prism (includes cut and fill slopes). A map and list 

of these roads is in Appendix D. Approximately 1,217 acres (about 30 percent of the infested sites) lie 

within 25 feet of these roads. 

Invasive plants are most common along roads, within compacted ditch lines, disturbed soil and thin soils 

near exposed bedrock. Roadside soils are assumed to function with a high runoff rate due to compaction. 

3.7.3 Environmental Consequences

3.7.3.1 Introduction

The effects analysis is tiered to R6 2005 FEIS for quantitative information related to potential 

concentrations of herbicides in water (except for aminopyralid, which is addressed in the SERA Risk 

Assessment and discussed herein). The analysis is focused on expected effects within treatment analysis 

areas.

3.7.3.2 Treatment Methods Near Water

The treatments proposed within the aquatic influence zone are expected to have the most effects on water 

resources. Approximately 1,354 acres are currently infested within aquatic influence zones. As described 

in the alternative descriptions of Chapter 2, a “first year/first choice” treatment is proposed for all 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

currently infested acres throughout the project area, and a summary of these treatments and their relative 

distribution and difference between alternatives can help provide context to the potential effects of the 

alternatives. Nearly all of the first year/first choice treatments involve herbicide use. 

Approximately 67 percent of proposed first year/first choice treatments within aquatic influence zones are 

the same in all alternatives, including No Action. These treatments are found in Table 46. In all 

alternatives, aquatic formulations of imazapyr and glyphosate may be spot treated up to the waterline of 

perennial water bodies and within dry or intermittent stream channels if water is not present. 

Table 46. “First Choice” treatments common to all alternatives within the Aquatic Influence Zones 

"First Choice" Treatment in all 

Alternatives

Infested Acres to be Treated 

within Aquatic Influence Zones 

(acres)

Percent of all Currently Infested Acres 

within Aquatic Influence Zones

Imazapyr/glyphosate 727.2 54

Glyphosate 170.1 13

Hand-pull 8.9 1 

Table 47 compares the acreage for first year/first choice prescriptions within 99 percent of the currently 

infested areas in aquatic influence zones for each alternative, including the 67 percent of treatments 

common to all alternatives described above. This table is shaded to show similarities and differences 

between first year/first choice treatments within aquatic influence zones under each alternative. During 

implementation, other effective herbicides may be used in place of the first choice, even during the first 

year’s entry. All treatments would follow MR/MM and comply with herbicide use buffers to minimize 

potential for impacts to water resources from herbicide use within the aquatic influence zones. 

Table 47. First Choice Treatments within the Aquatic Influence Zones by Alternative

"First Choice" Treatment in each Alternatives1 Infested Acres 

to be treated 

within Aquatic 

Influence 

Zones (acres)

Percent of all 

Currently 

Infested Acres 

within Aquatic 

Alternative 1 Alternative 2 Alternative 3 Influence Zones

Imazapyr/

glyphosate

Imazapyr/

glyphosate

Imazapyr/

glyphosate 727.2 54%

Glyphosate Glyphosate Glyphosate 170.1 13%

Hand-pull Hand-pull Hand-pull 8.9 1%

Glyphosate Broadcast-glyphosate Broadcast-glyphosate 29.1 2%

Glyphosate Chlorsulfuron Chlorsulfuron 5.6 0.4%

Clopyralid Broadcast-aminopyralid Broadcast-clopyralid 194.1 14%

Clopyralid Aminopyralid Triclopyr/ 

clopyralid 71.2 5%

Clopyralid Aminopyralid Clopyralid 31.6 3%

Biocontrol/

clopyralid

Biocontrol/

broadcast aminopyralid

Biocontrol/

broadcast clopyralid 33.9 2%

Glyphosate/

clopyralid Broadcast-aminopyralid Broadcast-metsulfuron methyl 12.5 1%

Glyphosate Broadcast-aminopyralid Triclopyr 11.8 1%

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

"First Choice" Treatment in each Alternatives1 Infested Acres 

to be treated 

within Aquatic 

Influence 

Zones (acres)

Percent of all 

Currently 

Infested Acres 

within Aquatic 

Alternative 1 Alternative 2 Alternative 3 Influence Zones

Clopyralid/

hand-pull

Broadcast 

aminopyralid/

broadcast clopyralid/

hand-pull

Broadcast clopyralid/

broadcast metsulfuron 

methyl/

hand-pull

8.2 1%

Clopyralid Aminopyralid/

chlorsulfuron

Chlorsulfuron/

clopyralid 6.9 1%

Glyphosate/

clopyralid

Broadcast 

aminopyralid/

broadcast clopyralid/

hand-pull

Broadcast glyphosate/

broadcast clopyralid 6.9 1%

Glyphosate/

clopyralid Aminopyralid Metsulfuron methyl 4.8 0.4%

Imazapyr/

glyphosate Aminopyralid Imazapyr/glyphosate 4.4 0.3%

Clopyralid Broadcast-aminopyralid

Broadcast metsulfuron 

methyl/

clopyralid

3.1 0.2%

Clopyralid Broadcast-aminopyralid Broadcast clopyralid 3.1 0.2%

1 Shading denotes which alternatives would approve the proposed treatment: Green = first choice treatment is a currently approved 

method; orange = first choice treatment is proposed in both Alternatives 2 and 3; yellow = first choice treatment is proposed only in 

Alternative 2.

3.7.3.3 Early Detection-Rapid Response (EDRR) 

Effects of early detection-rapid response treatments would be the same as those analyzed below in 

Environmental Consequences. In order for a new infestation to be controlled outside of an established 

Treatment Analysis area, the range of treatment methods must be the same, and each year an 

Interdisciplinary Team would meet to review all proposed EDRR treatments to determine if site locations 

and treatments are within the parameters of this project analysis. All EDRR treatments would follow the 

mitigation measures and management requirements (MR/MM) including: 

Annual limitations on the amount of herbicide treatments within riparian reserves of 6th field subwatersheds (less than 10% of riparian reserve areas), 

Monthly limitations on the amount of herbicide treatments around a lake or pond (No more than 

half the perimeter or 50 percent of the vegetative cover or 10 contiguous acres), 

Only allowing herbicide application where groundcover exists (more than 50 percent groundcover 

on shallow slopes and 70 percent on steep slopes), and 

By apply erosion control measures and native revegetation to areas of gouging or soil 

displacement resulting from manual treatment methods (digging or pulling) within 35 feet of water 

courses with surface water present or in areas where soil disturbance or de-vegetation may result 

in the delivery of measurable levels of fine sediment to federally listed fish species’ critical 

habitat. 

These limitations are expected to keep the direct, indirect and cumulative effects to the water resource 

within the bounds of this analysis. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

3.7.3.4 Effects on Water Quality

Water Temperature 

Pulling and killing invasive plants can reduce shade which can increase the amount of solar input into 

streams. Dead vegetation, if not removed, would continue to provide shade. The influence of riparian 

vegetation on stream shading varies with vegetation height, location, density, and is further affected by 

stream width, orientation, and slope steepness in the adjacent uplands. Due to their generally short nature, 

most invasive plants provide little or no shade to streams. Most non- invasive plants identified in this 

document are less than 4 feet tall and do not contribute measurably to stream shading. Water temperature 

is most typically driven by terrain slope and tree height in the northern Cascades, thus removal of short, 

stream-adjacent vegetation is expected to have minimal and indiscernible effect on water temperature. 

The treatment of aquatic emergent invasive plants has been identified in similar projects as potentially 

affecting channel conditions due to the proximity of treatments to the waterways. 

The only known aquatic emergent invasive plant currently located on the forest is reed canarygrass, of 

which there is only one known infestation. This infested area is located in on a reclaimed parcel called the 

Kaaland Property that was acquired in support of the Skagit Wild & Scenic River Corridor management. 

Herbicide treatments are expected to merely control this infestation along the stream bank of the Skagit 

River and would have no effect on water temperature in the Skagit River, since the river measures over 

750 feet across the main channel at this location. With a channel that wide, current vegetation is expected 

to have no solar shading effect on the stream, thus the removal of this vegetation would have no impact 

on water temperature. In cases where other infestations are found, the project includes mitigation 

measures and revegetation techniques that would further address any likelihood of effect. Any riparian 

areas that are found to have a dense monoculture of reed canarygrass would be revegetated with native 

sedges, grasses, forbs, and shrubs. Any loss of stream shade that occurs from this vegetation removal is 

expected to be temporary, and the anticipated revegetation techniques that are employed would shorten 

the length of time when stream-adjacent areas are lacking small, herbaceous cover. 

All alternatives would have no effect on streams or water bodies listed for water temperature under 

section 303(d) of the Clean Water Act since they are all expected to have indiscernible effects to water 

temperature at the site scale or broader. All alternatives would comply with the Clean Water Act, State 

water temperature standards, and the Aquatic Conservation Strategy Objectives of the NWFP that relate to 

water temperature. 

Sediment and Turbidity 

Sediment delivery to streams is dependent on the erosivity of the soil, slope, distance to a stream, amount 

of exposed soil (effective ground cover), and intensity and continuity of disturbance. All alternatives treat 

invasive plants and thus temporarily reduce ground cover, but the extent and continuity of is expected to 

be small in all alternatives. 

The method of treatment influences the potential for impacts on sediment delivery to streams. The 

proposed treatments other than manual would not cause measurable increases in erosion or turbidity 

because dead vegetation would be left in place, thus maintaining effective ground cover (i.e., there is no 

ground disturbance). 

The treatment method with the most potential to affect sediment and turbidity is manual treatment, which 

is included in all alternatives in this project. Manual treatment normally consists of invasive plant pulling, 

but may include invasive plant wrenching, cutting the root off or breaking them free with a shovel or 

186 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

Polaski. This treatment can result in some ground disturbance and the potential for increasing erosion and 

sediment delivery to streams. 

Disturbed ground within 35 feet of waterways that have surface water present would be seeded and 

mulched to reduce erosion and sediment delivery. The combination of these mitigation measures is 

expected to reduce, but not eliminate, the amount of erosion and sediment delivery that results from 

manual treatments. Increases in stream turbidity are expected to be highest during post-treatment 

precipitation events that occur before native and seeded vegetation becomes rooted. 

The extent and continuity of manual treatments is expected to be small in this project and isolated to areas 

where herbicides cannot be used or are ineffective. In most cases, herbicide use is considered a more 

cost-effective treatment method for control or eradication of many invasive species, thus herbicide use is 

expected to be used most often. Minimal sediment is expected to be delivered to streams as a result of the 

small anticipated amount of manual treatments that would occur in close proximity (within 100 feet) to 

streams in all considered alternatives. 

Alternatives 2 and 3 provide further protection than Alternative 1 by requiring that areas of gouging or 

soil displacement resulting from manual treatment methods (e.g., digging or pulling) within 35 feet of 

water courses with surface water present be treated to prevent rill and gully erosion and possible sediment 

delivery to steam courses. Erosion control treatment would include scattering seed and mulch (straw) to 

create flow disruption and surface soil stability. This measure would help initiate the establishment of 

native species and further dissipate erosion and reduce the likelihood of sediment delivery to streams. 

Turbidity levels generated by manually pulling reed canary grass adjacent to a stream channel would be 

reduced by dilution and mixing as it moves downstream. Turbidity generated from pulling reed canary 

grass from lake areas may take even longer to dissipate. Again, erosion control measures would be 

applied within 35 feet of water bodies with water present to mitigate any potential sediment from reach 

water bodies. 

Treating invasive plants would improve riparian stability where invasive plants such as knotweed plants 

have colonized along stream channels and out-competed native species. All invasive plant treatments 

carry some risk that removing invasive plants could exacerbate stream instability; however mulching, 

competitive seeding and planting would be implemented as needed to revegetate riparian and other treated 

areas. Disturbed areas within 35 feet of waterways would be re-vegetated with a minimum of seeding and 

mulch immediately following treatment as described in the mitigation measures of this project to ensure 

water quality is protected from sediment delivery. Treatments within the aquatic influence zone could 

result in negligible amounts of sediment due to erosion related to the minor ground disturbance associated 

with manual, mechanical and to a lesser extent, plant death due to herbicide treatments. 

While modification of surface ground cover can also change the timing of run-off, infested areas comprise 

such a small portion of any watershed that effects to stream flows are implausible.

Water Chemistry

Herbicides used under the existing NEPA decisions could enter water through spray drift, surface water 

runoff, percolation into groundwater, and windblown transport of herbicide attached to soil particles. The 

routes for herbicide to contaminate water are; direct application, drift into streams from spraying, runoff 

from a large rain storm soon after application, and leaching through soil into shallow ground water or into 

a stream. No direct application of herbicide to water is intended in any alternative. However, runoff from 

treatments within riparian areas and hydrologically connected ditches is possible.

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

Drift, including inadvertent overspray, is the most likely vector for herbicides coming in contact with 

water from riparian area or aquatic emergent vegetation treatment sites. The potential for drift varies with 

the herbicide application method. Spot and hand/selective application methods substantially reduce the 

potential for drift. Drift associated with broadcast treatments is minimized by MR/MM 7 which does not 

allow broadcast spray when wind speed at the site is in excess of 5 mph, and requires use of low nozzle 

pressure; and use of nozzle diameter to produce a median droplet diameter of 500-800 microns (coarse 

spray). 

Label restrictions; restrictions on application rate, type of herbicide, and application method; buffers; and 

the use of adjuvants all factor in to limiting the potential amount and effects of drift. 

Herbicide can move from the treatment location into adjacent areas through runoff. Some runoff can enter 

streams either through road or slope drainage. Roadside ditches can act as herbicide delivery routes to 

streams during high rainfalls or as settling ponds following rainfall events. Roads that have a higher 

potential for herbicide delivery to fish bearing streams have been identified and have added restrictions, 

such as no broadcasting of certain herbicides. About 30 percent (1,217 acres) of the current infestations 

are mapped within 25 feet of these roads. Although there would be no herbicide applied directly to the 

water column for purposes of treating submerged vegetation, there may be some fine droplets from 

herbicide applications near streams or along higher risk roads.

Herbicides affect lakes and wetlands differently than streams. Dilution by flow or tributary inflow is 

generally less effective in lakes. Dilution is partially a function of lake size, but dilution could be rapid in 

small lakes with large water contributing areas. Decreases in herbicide concentration in lakes, ponds, and 

other lentic water bodies are largely a function of chemical and biological degradation processes rather 

than of dilution. Evaporation of water from a lake’s surface can concentrate chemical constituents. As 

vegetation emerging from water dies the oxygen level within a lake or wetland can decrease.

Multiple treatments may occur in 1 year, however this analysis assumes that only a subset of the areas 

would be treated multiple times in one growing season, that repeat treatments would occur about a month 

apart, and most of these areas would be treated no more than three times within one growing season.

In some cases, a mix of herbicide ingredients is the most effective treatment for invasive plants. For 

instance imazapyr mixed with glyphosate is more effective on knotweed plant than either herbicide is 

alone. 

Combinations of chemicals in low doses have rarely demonstrated synergistic effects. Review of the 

scientific literature on toxicological effects and toxicological interactions indicate that exposure to a 

mixture of pesticides is more likely to lead to additive rather than synergistic effects (ATSDR 2004.; 

U.S.EPA/ORD 2000). Synergistic or additive [adverse] effects, if any, are expected to be insignificant (R6 

2005 FEIS, pg. 4-3).

Previous Monitoring Results

The United States Geological Service, in partnership with the Oregon Department of Transportation, 

studied runoff of herbicides along roads (Wood 2001). The study was conducted on runoff associated with 

sulfometuron methyl and glyphosate along a road in western Oregon. Water (simulated rainfall) was 

applied at 0.33 inches an hour at 1, 7 and 14 days after treatment. Samples were collected at the shoulder 

of the road and found concentrations of several hundred ppb of sulfometuron-methyl and nearly 1,000 

ppb of glyphosate that could potentially leave the road shoulder. In the fall, the road was again sprayed 

and the ditch line of the road was checked during natural rainstorms for 3 months. Sulfometuron-methyl 

was found in concentrations of 0.1 to 1 parts per billion (ppb) along the shoulder and from 0.3 to 0.1 ppb 

in the ditch line, but below detectable limits in the stream. Glyphosate was not found at the shoulder, ditch 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

line or stream. This study indicates that the greatest risk of herbicides moving off site is from large storms 

soon after herbicide application. There was about a 1.5 order of magnitude decline from results within 24 

hours of application to results from test plots taken the second week after application. In addition, this 

study also indicates that sulfometuron methyl may persist in the environment as it was detectable along 

the shoulder of the road (but not in the stream) the entire duration (3 months) of the study. The highest 

risk of herbicide applications in dry channels and hydrologically connected road ditches is from broadcast 

spraying covering larger areas.

Berg (2004) compiled monitoring results for broadcast herbicide treatments given various buffers along 

water bodies. The results showed that any buffer helps lower the concentration of herbicide in streams 

adjacent to treated areas. In California, when buffers between 25 and 200 feet were used, herbicides were 

not detected in monitored streams (detection limits of 1to 3 mg/m3) (ibid). Triclopyr was detected 

following the first runoff event within 90 days of application. This detection was attributed to runoff 

picking up the chemical in an ephemeral stream reach which was sprayed while it was dry. 

In South Carolina, buffers of 30 meters (comparable to 100 feet) during ground applications of the 

herbicides imazapyr, picloram and triclopyr resulted in no detectable concentrations of herbicide in 

monitored streams (ibid). No detection limits were given.

Even smaller buffers have successfully protected water quality. For example, where imazapyr was aerial 

sprayed without a buffer, the stream concentration was 680 mg/ml. With a 15-meter buffer, the 

concentration was below detectable limits (ibid.). No detection limits were given.

Berg also reported that herbicide applied in or along dry ephemeral or intermittent stream channels may 

enter streams through run-off if a large rainstorm occurred soon after treatment. This risk is minimized if 

intermittent and ephemeral channels are buffered (ibid.). Risk may also be minimized by limitations on 

herbicide selection and application method. If a large rainstorm occurs sediment contaminated by 

herbicide could be carried into streams. As most ditch lines on the National Forest and Scenic Area are 

heavily vegetated, this is less likely to occur than in a drier environment. 

The Washington State Department of Agriculture (WSDA 2004, 2005 and 2006) monitored residual 

concentrations of aquatic labeled herbicides for treatment of aquatic emergent invasive plants. Ten out of 

the sixteen sites sampled between the years 2003 and 2005 showed residual herbicide levels that were 

below a level of concern for drinking water. The rest showed no detectable level of herbicide.

Additional monitoring studies of herbicide drift and runoff results are summarized here. An 8 month posttreatment study of herbicide spray applications of picloram, triclopyr, and imazapyr, in power line rightsof-way was conducted in eastern New York (Environmental Consultants, Inc. 1991:III-43). Sites were 

selected with sandy or sandy loam soils to be the most likely to allow herbicide leaching. Buffer widths 

ranged from 10 to 100 feet. Samples were collected immediately downstream at 6 hour intervals until the 

streams froze and resumed with the spring thaw. Most of the samples collected did not have detectable 

levels of herbicide. Of those that did, samples containing detectable levels of imazapyr and picloram were 

collected shortly after application (indicating drift) or after the first significant rainfall event and one 

sample in the spring after autumn application. The highest concentrations of herbicide detected were 2 

ppb for triclopyr, 1 ppb for picloram, and 6 ppb for imazapyr. 

Watershed scale monitoring was completed for 13 herbicides (including glyphosate and triclopyr) in 

California in the late 1990’s. Samples were taken on the Klamath, Trinity, and Scott Rivers, and Elk, Pine, 

and Supply Creeks partially in conjunction with runoff events (Jones et al. 2000a). Active ingredients 

totaling 40,631 pounds of 13 herbicides plus 19 insecticides were applied upstream of the monitoring 

sites. Samples collected in dry weather in September 1998 served as background. Samples in October of 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

1998 and 1999 sampled storm runoff and samples collected in June 1999 corresponded to the end of the 

heaviest pesticide application season. No detectable concentrations of any herbicides were identified 

(reliable detection limits ranged from 0.04 to 2.0 ppb). The lack of positive detections is probably 

attributable to chemical degradation, absorption to soil, dilution in stream flow between the application 

and monitoring sites. 

A detailed discussion about herbicide delivery and fate are contained in the herbicide risk assessments 

completed by The Syracuse Environmental Research Associates, Inc. (SERA).

Studies by Evans and Duseja (1973) and Johnsen and Warskow (1980) showed rapid dilution after 

herbicide entered the water. Evans and Duseja sprayed picloram at 1 to 2 lbs./ac (2.9 to 5.7 times the 

typical application rate) on 1 to 2-acre plots. They took samples 5, 10, 100, and 1000 meters (16, 33, 328, 

and 3,281 feet) below the treated areas in a drainage ditch with no base flow after a 1.5 inch rainstorm 

occurred within a week of the treatment. Picloram concentrations were diluted by 85 to 98 percent within 

100 meters (328 feet) and were diluted to below detection levels at all but one site within 1000 meters 

(3281 feet). Within 12 weeks all concentrations were at or below 0.001 ppm and within a year it was not 

detectable. Johnsen and Warskow injected 1.5 pounds of picloram directly into a 1.3 cfs stream in 

Arizona. The original 6.258 ppm solution was diluted to 96 percent by the time it reached 1600 meters 

(about a mile) downstream. Two days after the treatment, concentrations were near the point of detection 

at the 400 and 1600 meter (1312 and 5249 feet) below the treated area. The original concentration was 

about 560 times the highest application concentration analyzed by the herbicide risk assessment 

completed by SERA for the R6 2005 FEIS. 

Effects from Riparian Treatment (Site Scale) 

Best Management Practices (BMPs) would be employed to help assure that water quality is not degraded. 

Relevant Water Quality BMPs were incorporated into the MR/MM. The objectives of the MR/MM is to 

keep herbicide residues in surface and ground water below levels that may be harmful, may chemically 

change to harmful forms, or that may accumulate in sediments or bio-accumulate in aquatic life to levels 

that adversely affect public health, aquatic life, wildlife, or other designated beneficial uses. Measures to 

reduce the risk of herbicide entering the hydrologic system include limiting drift, limiting runoff, reducing 

potential for and effects from accidental spills, applying buffers around water bodies, soils, water quality, 

fisheries and aquatic organism protection, and using only the lowest effect rate. 

In Alternatives 2 and 3, application of herbicides directly on target plant near water’s edge poses a very 

low risk of delivering of herbicide to adjacent waters. Herbicides with low potential to affect beneficial 

uses of water may be applied near streams. Herbicide use buffers would prevent herbicide from reaching 

streams or other water bodies in concentrations over a threshold of concern. 

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. Alternatives 2 and 3 both allow for herbicide application on seasonally 

intermittent streams when they are dry, thus there is a risk of elevated herbicide concentration associated 

with precipitation runoff events. However, management requirements have been developed to mitigate 

this small potential primarily by limiting treatments prior to forecast precipitation.

Clopyralid, glyphosate and imazapyr would be proposed for use in aquatic influence zones in all 

alternatives including No Action. Use of glyphosate would be the first choice for comparatively more 

acreage in Alternative 1 than Alternative 2 and 3. Aminopyralid would be used in Alternative 2 only. 

Comparatively less clopyralid and glyphosate would be used as a first choice option within aquatic 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

influence zones. Triclopyr TEA and metsulfuron methyl would be the first choice on a portion of infested 

acreage within the aquatic influence zone in Alternative 3 only. 

The human health and fisheries analyses (see Chapters 3.3 and 3.8) consider the effects of herbicide use 

based on the unbuffered/unmitigated scenarios for water contamination in the SERA risk assessments. 

Peak concentration of herbicide in water based on MBS maximum herbicide use rates are shown in Table 

48 for the first year/first choice herbicides proposed for use within aquatic influence zones, based on 

GLEAMS model results in the SERA risk assessments. 

The influence of the MR/MM and herbicide use buffers has not be quantified, but would likely reduce the 

amount of herbicide that may reach streams compared to the upper and central estimates in the SERA risk 

assessments. The GLEAMS model results in the risk assessments, shown in Table 48, do not differentiate 

between application method. These results indicate that use of herbicide near streams may result in small 

amounts of herbicide reaching water, but beneficial uses of water would be maintained. The herbicide use 

buffers that restrict broadcasting and spot treatment of some of the herbicides within the aquatic influence 

zone would help reduce the amount of herbicide potentially entering streams. 

The MR/MM that limit the potential for herbicides to enter water in the No-Action Alternative include 

MR/MM 21 and 22 (weather restrictions); and MR/MM 17 and 27 (spill control). 

The MR/MM that limit the potential for herbicides to enter water in the action alternatives include 

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); MR/MM 27 that limits herbicide use on sites more prone to run off and 

MR/MM 29 that references the herbicide use buffers. 

Table 48. Central, lower and upper estimates for peak concentration of herbicides in water when used 

adjacent to streams

Herbicide

Peak Concentration in 

Water, SERA Risk 

Assessments, Central 

Estimate (mg/l or ppm)

Peak Concentration in 

Water, SERA Risk 

Assessments, Lower 

Estimate (mg/l or ppm)

Peak Concentration in 

Water, SERA Risk 

Assessments, Upper 

Estimate (mg/l or ppm)

Metsulfuron methyl 0.00015 0.0000075 0.00075

Clopyralid 0.01 0.0025 0.035

Aminopyralid 0.0009 0.000018 0.0054

Glyphosate 0.044 0.0052 0.332

Triclopyr TEA 0.006 0.000002 0.48

Imazapyr 0.025 0.00001125 0.325

3.7.3.5 Effects from Treatment on Roads with High Risk of Herbicide Delivery to Fish 

Bearing Streams

Roadside ditches have high run off potential and treatments along roads may deliver herbicide to streams. 

However, treatments along roads are unlikely to result in concentrations of herbicide reaching streams in 

amounts likely to harm drinking water (see Chapter 3.3 for more information on human health and 

drinking water) nor would concentrations be great enough to harm fish or habitat (see Chapter 3.8 for 

more information on effects on aquatic resources). MR/MM 16, 17 and 18 would minimize the potential 

for harmful herbicide delivery from roadside treatments. MR/MM 16 prioritizes non-herbicide or lower 

risk herbicide treatments on roads that are within 200 feet of fish bearing streams. Use of aminopyralid, 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Water Resources

clopyralid, imazapic, and metsulfuron methyl, aquatic glyphosate, aquatic triclopyr, and aquatic imazapyr 

would be prioritized over other herbicides and no picloram or non-aquatic triclopyr BEE would be used 

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

MR/MM 17 ensures that 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. MR/MM 18 ensures that non-aquatic herbicides, chlorsulfuron, 

picloram or sulfometuron methyl would not be used within 15 feet of any wet roadside ditch.

3.7.3.6 Accidental Spills 

Accidental spills are not considered a direct or indirect effect of treatments in any of the alternatives. 

MR/MM would reduce the potential for spills to occur. An herbicide transportation and handling plan 

would limit the amount of herbicide transported on the Forest, which would reduce the magnitude of a 

spill. MM/RR in the project require a spill kit, spill response plan, and immediate action in the case of a 

spill. The potential for a spill is further reduced around water through MR/MM that limit the amount of 

herbicide that can be carried near water and require that fueling and mixing be done away from water. 

The SERA risk assessments evaluated the amount of herbicide a small child might consume after drinking 

from a quarter-acre pond shortly after a 200 gallon spill without containment measures being taken. 

MR/MM 8 includes measures to reduce the potential for a spill and increase the likelihood of 

containment. MR/MM 8 ensures that workers would carry only enough herbicide daily to cover the 

proposed treatment for that day, which is likely to less than 200 gallons of herbicide. No reportable spills 

have occurred on similar projects in Region Six (Desser 2013). 

The concentration of herbicide in the water as a result of an accidental spill depends on the rate of 

application and the streams’ ratio of surface area to volume. The persistence of the herbicide in water 

depends on the length of stream where the accidental spill took place, velocity of stream flow, and 

hydrologic characteristics of the stream channel. The concentration of herbicides would decrease rapidly 

down-stream because of dilution and interactions with physical and biological properties of the stream 

system (Norris et al. 1991). 

3.7.3.7 Streams and Lakes on the 303(d) List 

This project uses the most current 303(d) list for freshwater in the State of Washington which was 

published in 2008. MR/MM mitigate potential effects to water quality. This project would have no effect 

on streams and lakes listed under Section 303(d) of the Clean Water Act. 

The following analysis explains why no effects are likely, including to streams listed for water 

temperature or fine sediment. 

1. This project would primarily treat non-emergent vegetation or emergent vegetation in areas where no 

surface water is present. 

2. Treatments of non-emergent vegetation within 100 feet of 303(d) streams would not add measurable 

amounts of organic matter or nutrients to streams or lakes or further degrade pH, chlorophyll a, or 

dissolved oxygen (DO) due to the scale of treatments discussed under the alternatives. While there is 

a very small potential for chemical treatment of emergent vegetation (reed canary grass and yellow 

flag iris) to affect pH, DO, and chlorophyll a, in adjacent waters with high levels of algae, these 

conditions have never been documented and are assumed to not exist in the project area

3. The proposed herbicides do not contain dioxins that would further degrade the water chemistry levels 

in Dorothy Lake.

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4. Spot and hand spraying within riparian areas would reduce potential for drift compared to broadcast 

treatments and. 

Table 48 shows results from this analysis for the herbicides that may be used within 100 feet of wet 

streams. Effects from drift, runoff and leaching were considered in the SERA Risk Assessments assuming 

broadcast treatment occurred directly adjacent to streams. The Groundwater Loading Effects of 

Agricultural Management Systems (GLEAMS) model was used to estimate the amount of herbicide that 

could potentially reach a reference stream via runoff, drift and leaching in a 96 hour period, assuming 

broadcast treatments on a 50-foot strip along about 1.6 miles of a small perennial stream, 1.8 cfs. The 

herbicide use buffers (Table 10) consider the toxicity, mobility and label requirements to minimize the 

risk and impact of herbicide delivery to streams and other water bodies. The moderating effect of the 

herbicide use buffers was not modeled. 

3.7.3.8 Groundwater and Geology

As described in the soils effects section, GLEAMS modeling was done to study the movement of 

herbicides into the soil column assuming the maximum application rates for the project. GLEAMS 

modeling showed a relative drop in herbicide concentration as herbicides move down into the soil column 

with most retaining in the top 12 inches where biologic activity of decomposers are most active. Figure 4

illustrates that most of the herbicides adsorb to soil within the top 20 inches, despite all having moderate 

to high solubility. Below 40 inches, only trace amounts remain, and depending on the depth to 

groundwater, these trace amounts have some potential to reach groundwater. 

Localized discharge of groundwater can occur above the regional aquifers where lenses of impermeable 

rock or soil are present. The possible presence of herbicide residues in these waters is very low due to the 

lack of treatment sites present in the upper elevation recharge areas, the requisite percolation through soil 

and bedrock capable of adsorbing residues, and a large dilution factor within the flow. The possible influx 

of herbicide residues into these surface waters is also low due to application buffers around springs and 

other riparian water sources. 

Leaching is associated with areas that experience a wetting front that can transport herbicide residue 

below ground. Valley bottom and alluvial fan areas that accumulate water from adjoining hill slopes have 

the highest potential for leaching. Heavy rainfall following spring would have a higher likelihood of 

transporting contaminants downward since moist antecedent conditions would facilitate percolation. 

Successive rainfall events that transport contaminants downward are rarer during the main period of 

treatment, June through September. The risk for downward percolation is highest for herbicides that have 

a higher residency time and fairly stable in water. 

MR/MM for the project would reduce the risk of generating excess herbicide residues capable of being 

transported vertically through the soil profile. These include restricted application rates of all proposed 

herbicides to minimize excess residues, restricted application of highly mobile herbicides, restricted 

timing of application prior to forecasted precipitation, and restricted application within intermittent stream 

channels. Application of herbicides would also occur during drier times of the year, which reduces 

movement of herbicide through the soil and allows the targeted plants to uptake the herbicide. Soils 

adsorb and degrade herbicide residues, which minimizes leaching into groundwater. 

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3.7.3.9 Water Resource Alternatives Comparison

Alternative 1

Alternative 1 poses relatively low risk to water resources, however some riparian areas would not be 

effectively treated and thus the quality of riparian habitat may be reduced. However, no adverse effects on 

beneficial uses of water would occur. 

Alternative 2

Alternative 2 poses relatively low risk to water resources. Herbicide use in accordance with the herbicide 

use buffers shown in Table 10 and the MR/MM would keep herbicide 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. 

Alternative 3

Alternative 3 poses relatively low risk to water resources. The herbicide use buffers shown in Table 10

would keep herbicide from reaching streams to a minimum, and no adverse effects to beneficial uses are 

expected. While treatments in some riparian areas may be less effective than Alternative 2, these 

differences are not significant to water resources. 

3.7.3.10 Cumulative Effects of all Alternatives

Introduction

None of the alternatives are likely have substantial impacts on the water resource. Some herbicide 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. Pesticides are likely to be found at some level in streams and 

rivers within and adjacent to the MBS. At the current time, beneficial uses of surface waters within the 

project area are not adversely affected by pesticide use. The baseline for cumulative effects analysis is the 

current condition. 

Cumulative Effects of Herbicide Use

Chapter 3.1.6.2 discusses the other herbicide use conducted by federal, state and county agencies. 

Treatments are unlikely to occur in close enough proximity to mix and cause concentrations greater than 

those disclosed in the risk assessments for acute or chronic exposure. Infestations that cross ownership 

boundaries are often treated cooperatively so multiple areas are unlikely to be treated simultaneously, 

though it is possible that herbicide use by these agencies could occur simultaneously with herbicide use 

proposed in the alternatives. The infested areas are small and scattered across the watersheds and 

treatments by all agencies comprise a small fraction of watershed area. The small percentage of any 

watershed currently infested and the MR/MM and caps would serve to reduce the potential for herbicides 

to reach streams from any alternative. Thus even if simultaneous herbicide use occurred within a 6th field 

watershed, herbicide use on National Forest is unlikely to contribute to cumulative adverse effects. All 

agencies would obtain Clean Water Act permits for herbicide use that is likely to reach water. 

Most of the national forest system lands being analyzed for this EIS are upstream of other sources of 

herbicides. By the time the water leaves the Forest, the small amount of herbicide that might reach the 

stream would be diluted. The potential for accumulation downstream would be based on the potential for 

herbicide from agricultural use to reach the water in a measurable amount to where the forest service 

proposes treatment and then for there to be a measurable amount from forest service treatments, so the 

two sources could combine. This is unlikely, because MR/MM minimize the potential for herbicide to 

accumulate in water. 

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Mixing and dilution of any trace amount of herbicide that may result from invasive plant treatment would 

occur quickly, making it highly unlikely that herbicide concentrations would be additive or synergistic 

with downstream herbicide use. Given the scattered nature of treatments, and dilution over time and space 

by mixing and addition of inflow downstream, the amount of herbicide that may be delivered to a 

common point downstream is very small to non-existent. Private lands are mainly downstream of the 

project area and any herbicide delivered to water from this project would be rapidly diluted, and thus 

would not contribute to cumulative downstream effects from pesticide use there. 

The following two studies discuss cumulative pesticide residues present in surface waters in the United 

States. 

NWQAP Pesticide Study

Since 1991, the National Water Quality Assessment Program (NWQAP) has implemented 

interdisciplinary assessments in 51 of the Nation’s most important river basins and aquifers, referred to as 

Study Units, and the High Plains Regional Ground Water Study. The USGS published a report: 

“Pesticides in the Nation’s Streams and Ground Water, 1992–2001” (Gillom et al. 2006) that presented 

evaluations of pesticides in streams and ground water based on findings for the first decadal cycle of 

NAWQA. The study found that undeveloped streams had one or more detectable pesticides or degradates 

65 percent of the time. The study stated that presence of pesticide compounds in predominantly 

undeveloped watersheds29 may result from past or present uses within the watershed for purposes such as 

forest management or maintenance of rights-of-way, uses associated with small areas of urban or 

agricultural land, or atmospheric transport from other areas. None of the herbicides proposed for use in 

this project were detected in the national samples (however it is acknowledged that glyphosate is widely 

used but was omitted from the study). 

The report discusses the many delivery mechanisms of pesticides to surface and ground water: 

Pesticides are transported to streams and ground water primarily by runoff and 

recharge. Nonpoint sources of pesticides originating from areas where they were 

applied—rather than point sources such as wastewater discharges—are the most 

widespread causes of pesticide occurrence in streams and ground water (Modified from 

Majewski and Capel 1995). The atmosphere is often overlooked as a source of 

pesticides, which return to earth with precipitation and dry deposition and can reach 

streams and ground water. Streams are particularly vulnerable to pesticide 

contamination because runoff from agricultural and urban areas flows directly into 

streams along with both dissolved and particle-associated pesticides. Ground water is 

most susceptible to contamination in areas where soils and the underlying unsaturated 

zone are most permeable and drainage practices do not divert recharge to surface 

waters.

The study also stated: 

Pesticide occurrence in streams and ground water does not necessarily cause adverse 

effects on aquatic ecosystems or humans. The potential for effects can be assessed by 

comparing measured pesticide concentrations with water-quality benchmarks, which 

are based on the concentrations at which effects may occur. No streams draining 

undeveloped land, and only one stream in a watershed with mixed land uses, had an 

annual mean concentration greater than a human-health benchmark. 

29 Refers to urban and rural developments; roads and forest management activities may be occuring in these areas.

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Clackamas River Pesticide Study

A study about the background levels of pesticides in surface waters was done on the Clackamas River, 

part of the Willamette River Basin in western Oregon. The Pesticide occurrence and distribution in the 

lower Clackamas River Basin, Oregon, 2000–2005 (Carpenter, K.D et al. 2008) was done as part of the 

NWQAP. 

The Clackamas study took place from 2000–2005. Within 119 water samples from the Clackamas and its 

tributaries, 63 pesticide compounds: 33 herbicides, 15 insecticides, 6 fungicides, and 9 pesticides 

degradates were detected. Fifty-seven pesticides or degradates were detected in the tributaries (mostly 

during storms), whereas fewer compounds (26) were detected in samples of source water from the lower 

mainstem Clackamas River, with fewest (15) occurring in drinking water.

The study stated that the two most commonly detected pesticides were the triazine herbicides simazine 

and atrazine, which occurred in about one-half of samples. It also said that the active ingredients in the 

“common household herbicides” RoundUp® (glyphosate) and Crossbow® (triclopyr and 2,4-D) also 

were frequently detected together. These three herbicides often made up most of the total pesticide 

concentration in tributaries throughout the study area. 

The study stated that pesticides were most prevalent in the Clackamas River during storms, and were 

present in all storm-runoff samples — averaging 10 individual pesticides per sample from these streams. 

Two tributaries contained 17-18 different pesticides each during a storm in May 2005. These mediumsized streams drain a mix of agricultural land (row crops and nurseries), pastureland, and rural residential 

areas. Two small streams that drain the highly urban and industrial northwestern part of the lower basin 

had the greatest pesticide loads. Streams draining predominantly forested basins contained fewer pesticide 

detections (2-5 pesticides). The study stated that pesticide use on the Mount Hood National Forest, which 

comprises most of the Federal land in the upper Clackamas River Basin, was a relatively insignificant 

contribution. 

Study Interpretation 

These studies support the conclusion that this project, combined with other herbicide use off Forest, 

would not result in herbicide concentrations to streams over a threshold of concern for people and/or the 

environment. 

Overlap with Projects on the MBS

Appendix F provides information about the projects that have been recently completed, currently being 

implemented or are ongoing, and foreseeable future projects on the MBS. None of these projects propose 

additional pesticide use. 

The greatest potential for cumulative effects on water resources would be from overlapping activities in 

TAA 2, 3, 4, 16, 20, 23, 27, 32, 33, 45, and 49. Of these, TAA 3, 20, 23, 27 and 45 have more than 100 

acres of invasive plant treatment proposed within riparian reserves that could overlap with recently 

completed, current, ongoing, or foreseeable future projects. The other TAAs have much lower potential 

for impacts that could combine with other projects on the MBS because so little of the riparian reserve 

would be proposed for treatment in all alternatives, or there would not likely be overlap within the TAA 

that could cause a cumulative impact to water resources. 

Vegetation management in TAA 2, 3, 4, and 16, may overlap with invasive plant treatments in riparian 

reserves. Riparian reserve conditions would be maintained where invasive plant treatment would help 

restore native plant communities disturbed by the vegetation management. Sediment delivery could occur 

from these projects; however mitigation would reduce the potential for adverse impacts to water. 

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Recreation management projects in TAA 23, 27, 33, 45, and 49 are unlikely to adversely affect water 

resources or combine with invasive plant treatments to cause any cumulative impacts to water. These 

projects would be managed to maintain water quality. 

Road projects (mainly repair and closure) in TAA 20, 23, 32, 33, 45 and 49 would help improve water 

quality over the long run. The effects of invasive plant management would not combine with the effects of 

the road projects to cause any adverse cumulative effects. Stream restoration in TAA 32 would also serve 

to improve watershed condition and invasive plant treatment would contribute to beneficial cumulative 

effects by helping to restore native plant communities in riparian reserves. 

Some sediment may also be delivered to streams, especially from manual treatment methods in all 

alternatives. The sediment could combine with sediment generated from other projects and reach streams.

However, sediment is not likely to accumulate and impact water resources because (1) native vegetation 

would be retained on all sites and impacts from the project to any stream system would be minimal and 

short-lived and (2) sediment delivery is mitigated in other Forest Service projects. 

Cumulative Effects Summary

None of the alternatives considered for this project would affect water temperature, dissolved oxygen, pH 

or chlorophyll a, thus cumulative effects on these water quality indicators are not possible. Invasive plant 

treatment in all alternatives could result in small amounts of herbicide and/or sediment reaching streams. 

The risk of adverse effects to water resources is low, and the risk of contributing to adverse cumulative 

effects is low. Invasive plant treatment could overlap with projects being implemented on the MBS. 

However, the effects of invasive plant treatment are unlikely to combine with effects of other projects and 

cause an adverse cumulative effect to water resources. The possibility that herbicides used on this project 

would mix with herbicide used on other lands within the watersheds is low given the low risk of herbicide 

delivery and rapid dilution of the small amount of herbicide that may reach streams from the project. 

3.7.4 Consistency with Regulations, Policies and Plans

This project would comply with the MBS Forest Plan and requirements detailed in Water Quality

Standards for the State of Washington, Chapter 173-201A WAC 1997 & 2003, and Forest Chemicals 

Chapter 222-38 WAC.

3.8 Fish and Aquatic Organisms 

3.8.1 Introduction

This chapter summarizes the effects to fish and their habitats. It discusses management and laws related to 

the effects on fisheries. Fish distribution was determined from WDFW published GIS data and local 

biologist knowledge, bull trout critical habitat for lakes and streams was provided by USFWS, Chinook 

salmon critical habitat data provided by NMFS. Occupied Puget Sound steelhead habitat was assumed to 

be similar to bull trout critical habitat except for Baker River above Lake Shannon and Gold Creek above 

Keechelus Lake where steelhead are blocked by large dams and known to be absent.

The effects analysis tiers to the R6 2005 FEIS. Effects methodology follows previous fisheries analyses as 

published in the Gifford Pinchot and Olympic National Forests Invasive Plant Treatment EIS’s. 

Specific management direction for aquatic habitats can be found in the 1990 MBS Forest Plan; the 1994 

Northwest Forest Plan; regulatory requirements associated with Section 7 of the ESA; the Magnuson197 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Fish and Aquatic Organisms

Stevens Fishery Conservation and Management Act (16 U.S.C. 1801 et seq.), as amended by the 

Sustainable Fisheries Act of 1996, and its implementing regulations (50 CFR Part 600). 

3.8.2 Affected Environment

3.8.2.1 Effects of Invasive Plants on Aquatic Ecosystems 

Invasive plants found growing adjacent to or within aquatic influence areas can invade, occupy, and 

dominate riparian areas and indirectly impact aquatic ecosystems and fish habitat. Studies show that 

species-rich riparian communities that receive an intermediate level of disturbance (fire, flood, herbivory) 

have more resources available for invading species (Planty-Tabacchi et al. 1996; Stohlgren et al.1999). 

Riparian habitats, while making up a relatively small area across the Northwest, have significant 

ecological, cultural, and economic importance (Parks et al. 2005). Target species such as knotweed plant 

and blackberry can choke streams, become sediment traps and cause stream aggradation. Spawning 

gravels locked up in the root masses are unavailable for fish, and the stream areas around the root masses 

have such accelerated flows that gravels aren’t retained, resulting in a net loss of fish habitat.

Invasive plants can change stand structure and alter future inputs of wood and leaves that provide the 

basic foundation of the aquatic ecosystem food webs. Native vegetation growth may change as a result of 

invasive plant infestation, and the type and quality of litter fall, and quality of organic matter may decline, 

which can alter or degrade habitat for aquatic organisms. Primary and secondary consumers that form the 

basic food source for fish and other aquatic organisms may be indirectly affected. 

3.8.2.2 Aquatic Species of Conservation Concern

The MBS has many aquatic Species of conservation concern including species noted in the Aquatic 

Species Listed as Threatened Under The Endangered Species Act (Table 49) and the Regional Forester’s 

Sensitive Species list (December 2012, see Table 51). No fish species on the MBS are currently proposed 

for listing under the endangered species act or are listed as endangered.

Fish distribution data is from WDFW and local Forest fish biologists. Information related to life history 

and status of populations at the Evolutionary Significant Unit (ESU) or Distinct Population Segment 

(DPS) scale can be found in the following sources: 

§ R6 2005 FEIS Fisheries Biological Assessment (BA), Environmental Baseline 

§ NMFS and USFWS Federal Register documents (http://www.nwr.noaa.gov/ESA-SalmonListings/Salmon-Populations/Index.cfm), (http://www.fws.gov/pacific/bulltrout/), 

§ Shared Strategy for Puget Sound for Puget Sound Chinook Salmon, and bull trout population 

in the Puget Sound area (http://www.sharedsalmonstrategy.org/plan) 

Federally Listed Fish Species

Puget Sound (PS) Chinook salmon, Puget Sound steelhead and Coastal/Puget Sound bull trout are known 

to occur on the Mt. Baker –Snoqualmie National Forest and are listed as Threatened under the Federal 

Endangered Species Act (ESA). Critical habitat has also been designated for PS Chinook salmon and PS 

bull trout. Table 49 gives the status and watersheds providing habitat for local fish species listed under the 

ESA. Table 50 provides basic life cycle information on these species. 

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Table 49. Species listed under the ESA and their critical habitat (if applicable) within the project area

Species

DPS or 

Critical 

Habitat

Status/Federal 

Register

Reference

5th Field Watersheds on 

MBS (Critical Habitat) Habitat and Life History

Steelhead Puget Sound Threatened/

72 FR 26722

5/11/07

Upper North Fork Nooksack 

River

Middle Fork Nooksack River

South Fork Nooksack River

Baker River

Skagit River/Diobsud Creek

Skagit River/Illabot Creek

Middle Skagit River/Finney 

Creek

Cascade River

Upper Suiattle River

Lower Suiattle River

Upper Sauk River

Lower Sauk River

North Fork Stillaguamish River

South Fork Stillaguamish River

Pilchuck River

Sultan River

Skykomish River/Wallace 

River

North Fork Skykomish River

South Fork Skykomish River

Tye River

Beckler River

Upper Green River

Upper White River

Carbon River

The most widespread run type of steelhead on Mt. Baker National Forest is 

the winter (ocean-maturing) steelhead. Winter steelhead are found in nearly 

all coastal rivers of Washington. Impassable barriers in streams on Mt. 

Baker-Snoqualmie National Forest limit their distribution. Winter run 

steelhead typically enter streams for spawning between November and April 

(Wydoski and Whitney 2003). Fry emerge in April through June and 

generally spend 1 to 2 years in freshwater, preferring riffle areas in the 

summer and occupying pools during the rest of the year (ibid). 

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Species

DPS or 

Critical 

Habitat

Status/Federal 

Register

Reference

5th Field Watersheds on 

MBS (Critical Habitat) Habitat and Life History

Chinook 

Salmon

Puget Sound Threatened/

64 FR 14308

3/24/99

Upper North Fork Nooksack 

River

Middle Fork Nooksack River

Baker River

Skagit River/Diobsud Creek

Skagit River/Illabot Creek

Cascade River

Upper Suiattle River

Lower Suiattle River

Upper Sauk River

Lower Sauk River

North Fork Stillaguamish River

South Fork Stillaguamish River

Pilchuck River

North Fork Skykomish River

Skykomish River/Wallace 

River

South Fork Skykomish River

Tye River

Beckler River

Upper Green River

Upper White River

Carbon River

Because of the size of Chinook salmon, they prefer spawning habitats that 

includes deeper water and larger gravels than for most other salmon 

species. Two life history types – ocean and stream – are recognized in 

Chinook salmon, based upon the length of time the juvenile fish spend 

rearing in streams and rivers. Juvenile ocean-type Chinook salmon outmigrate relatively quickly into saltwater following emergence. Some fry enter 

marine environments almost immediately, but most inhabit the shallow side 

margins and estuary areas for up to 2 months. It is unlikely that ocean-type 

Chinook salmon (fall run Chinook) on Mt. Baker-Snoqualmie National Forest 

would be exposed to disturbance and herbicides from near stream 

vegetation treatments. Juvenile stream-type Chinook salmon may 

overwinter in fresh water, typically migrating to the ocean the following 

spring. 

Puget Sound 

Critical 

Habitat

Designated/

70 FR 52629

09/02/05

Bull Trout Coastal 

Puget-Sound

Threatened/

64 FR 58910

11/01/99

Upper North Fork Nooksack 

River

Middle Fork Nooksack River

South Fork Nooksack River

Baker River

Skagit River/Diobsud Creek

Skagit River/Illabot Creek

Middle Skagit River/Finney 

Creek

Cascade River

Upper Suiattle River

Bull trout move upstream in summer and early fall to spawn in September 

and October – or in November at higher elevations (Wydoski and Whitney 

2003). Extended incubation periods (4 to 5 months) make eggs and fry 

particularly susceptible to increases in fine sediments. Fry remain in the 

streambed for up to 3 weeks before emerging. Fry are typically found in 

shallow, backwater side channels and eddies in proximity to instream cover.

Juveniles are typically found in interstitial spaces in the substrate, and 

subadults in deeper pools of streams or in the deep water of lakes.

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Species

DPS or 

Critical 

Habitat

Status/Federal 

Register

Reference

5th Field Watersheds on 

MBS (Critical Habitat) Habitat and Life History

Coastal 

Puget-Sound 

Critical 

Habitat

Designated/

75 FR 63898

10/18/10

Lower Suiattle River

Upper Sauk River

Lower Sauk River

North Fork Stillaguamish River

South Fork Stillaguamish River

Pilchuck River

Sultan River

Skykomish River/Wallace 

River

North Fork Skykomish River

South Fork Skykomish River

Tye River

Beckler River

Upper Green River

Upper White River

Carbon River

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Life Cycle Timing for Federally Listed Fish Species

Table 50. General life cycle timing of federally listed fish species in the project area

Stock Migration Spawning Incubation Rearing

Puget Sound 

Chinook salmon

August to

September (Ocean 

type)

March to June 

(Stream type)

September to 

November

September to 

February

Saltwater

(Ocean type)

Year round 

(Stream type)

Coastal/ Puget 

Sound bull trout

Mid-June to 

November

Mid-September 

through

November

MidSeptember to 

June

Year round

Puget Sound 

steelhead

Late November to 

April 

December to

June

December to 

August Year round

Designated Critical Habitat for Pacific Salmon

Critical habitat was designated for Puget Sound Chinook salmon on February 16, 2000 (65 FR 7764), but 

vacated by court order on April 30, 2002. Critical Habitat for this species was proposed on December 14, 

2004 (69 FR 74572) and designated on September 2, 2005 (70 FR 52629). 

Fifth field watersheds on Mt. Baker-Snoqualmie National Forest with designated Chinook salmon critical 

habitat are the North Fork Nooksack River, Upper North Fork Nooksack River, Middle Fork Nooksack 

River, South Fork Nooksack River, Baker River, Skagit River/Diobsud Creek, Skagit River/ Illabot Creek, 

Middle Skagit River/ Finney Creek, Cascade River, Upper Suiattle River, Lower Suiattle River, Upper 

Sauk River, Lower Sauk River, North Fork Stillaguamish River, South Fork Stillaguamish River,

Skykomish River/Wallace River, Skykomish River Forks, Tye and Beckler Rivers, Upper White River 

and Carbon River. 

NMFS designates critical habitat based on physical and biological features that are essential to the listed 

species. Essential features of designated critical habitat are: (1) substrate, (2) water quality, (3) water 

quantity, (4)water temperature, (5) water velocity, (6) cover/shelter, (7) food for juveniles, (8) riparian 

vegetation, (9) space, and (10) safe passage conditions (50 CFR 226.212). The three freshwater primary 

constituent elements of critical habitat are: 

1. Freshwater spawning sites with water quantity and quality conditions and substrate supporting 

spawning, incubation and larval development 

2. Freshwater rearing sites with water quantity and floodplain connectivity to form and maintain 

physical habitat conditions and support juvenile growth and mobility; water quality and forage 

supporting juvenile development; and natural cover such as shade, submerged and overhanging large 

wood, log jams and beaver dams, aquatic vegetation, large rocks and boulders, side channels, and 

undercut banks

3. Freshwater migration corridors free of obstruction with water quantity and quality conditions and 

natural cover such as submerged and overhanging large wood, aquatic vegetation, large rocks and 

boulders, side channels, and undercut banks supporting juvenile and adult mobility and survival 

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Designated critical habitat on the Mt. Baker-Snoqualmie National Forest includes the stream channels in 

each designated reach, and a lateral extent as defined by the ordinary high water line (Sept. 2, 2005; 70 

FR 52629). The primary constituent elements essential for conservation of listed ESUs are those sites and 

habitat components that support one or more fish life stages, including freshwater spawning sites, 

freshwater rearing sites, and freshwater migration corridors.

Designated Critical Habitat for Coastal Puget Sound Bull Trout 

The USFWS proposed critical habitat for the Coastal Puget Sound DPSs on January 14, 2010 (75 FR 

2269) and a final ruling was made on October 18, 2010 (75 FR 63898) to designate bull trout critical 

habitat for the Klamath River, Columbia River, Jarbridge River, Coastal Puget Sound, and Saint MaryBelly River populations of bull trout in the coterminous United States. 

Fifth field watersheds on Mt. Baker-Snoqualmie National Forest with designated critical habitat are the 

North Fork Nooksack River, Upper North Fork Nooksack River, Middle Fork Nooksack River, South 

Fork Nooksack River, Baker River, Skagit River/Diobsud Creek, Skagit River/ Illabot Creek, Middle 

Skagit River/ Finney Creek, Cascade River, Upper Suiattle River, Lower Suiattle River, Upper Sauk 

River, Lower Sauk River, North Fork Stillaguamish River, South Fork Stillaguamish River, Skykomish 

River/Wallace River, Skykomish River Forks, Tye and Beckler Rivers, Upper White River and Carbon 

River. 

Critical habitat extends from the bankfull elevation on one side of the stream channel to the bankfull 

elevation on the opposite side. Adjacent floodplains are not proposed as critical habitat. The lateral extent 

of proposed lakes and reservoirs is defined by the perimeter of the water body as mapped on standard 

1:24,000 scale maps.

The USFWS critical habitat designation identified those physical and biological features of the habitat 

that are essential to the conservation of the species and that may require special management 

consideration or protection. These physical and biological features include, but are not limited to: space 

for individual and population growth, and for normal behavior; food, water, or other nutritional or 

physiological requirements; cover or shelter; sites for breeding, reproduction, or rearing of offspring; and 

habitats that are protected from disturbance or are representative of the historic geographical and 

ecological distribution of a species. 

All areas listed as critical habitat for bull trout are within the historic geographic range of the species and 

contain one or more of these physical or biological features essential to the conservation of the species.

The USFWS also included a list of known primary constituent elements with the critical habitat 

description. The primary constituent elements may include, but are not limited to, features such as 

spawning sites, feeding sites, and water quality or quantity. 

The USFWS determined the primary constituent elements for bull trout from studies of their habitat 

requirements, life-history characteristics, and population biology, as outlined above. These primary 

constituent elements are:

1. Permanent water having low levels of contaminants such that normal reproduction, growth and 

survival are not inhibited. 

2. Water temperatures ranging from 2 to 15 °C (36 to 59 °F), with adequate thermal refugia available for 

temperatures at the upper end of this range. Specific temperatures within this range vary depending 

on bull trout life history stage and form, geography, elevation, diurnal and seasonal variation, shade, 

such as that provided by riparian habitat, and local groundwater influence.

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3. Complex stream channels with features such as woody debris, side channels, pools, and undercut 

banks to provide a variety of depths, velocities, and instream structures.

4. Substrates of sufficient amount, size, and composition to ensure success of egg and embryo 

overwinter survival, fry emergence, and young-of-the-year and juvenile survival. A minimal amount 

of fine substrate less than 0.63 cm (0.25) in diameter and minimal substrate embeddedness are 

characteristic of these conditions.

5. A natural hydrograph, including peak, high, low and base flows within historic ranges or, if regulated, 

a hydrograph that demonstrates the ability to support bull trout populations. 

6. Springs, seeps, groundwater sources, and subsurface water connectivity to contribute to water quality 

and quantity. 

7. Migratory corridors with minimal physical, biological, or chemical barriers between spawning, 

rearing, overwintering, and foraging habitats, including intermittent or seasonal barriers induced by 

high water temperatures or low flows.

8. An abundant food base including terrestrial organisms of riparian origin, aquatic macroinvertebrates, 

and forage fish. 

9. Few or no predatory, interbreeding, or competitive non-native species present.

Infested Sites Near Streams with Listed Fish 

Mapped infestations within 150 feet of listed critical habitat, for PS Chinook salmon and PS bull trout, or 

within 150 feet of streams with suspected occupancy by PS steelhead are shown in Table 51. 

Table 51. Infested areas within 150 feet of streams with ESA Listed Fish Species

Fifth Field Watershed Name Stream Name

NRIS 

Infestation 

Identification

Listed Fish 

Species1

Upper North Fork Nooksack 

River

Glacier and Falls Creek 01-AR-011 PSS , PSC, BT

North Fork Nooksack River 01-AR-065 PSS, PSC, BT

Baker River Sulphur Creek 01-LP-028 BT 

Baker River 01-LP-041 BT 

Skagit River/ Illabot Creek Illabot Creek 01-AR-059 BT 

Middle Skagit River/ Finney 

Creek Skagit River 01-AR-014

01-AR-046 PSC, PSS, BT

Cascade River Cascade River 01-AR-51 PSC, PSS, BT

Lower Suiattle River

Suiattle River and Buck Creek 060502001055 PSC, PSS, BT

Straight Creek

Circle Creek 060502001054 PSC, PSS, BT

Upper Sauk River Sauk River/ Owl Creek 02-AR-018

02-LB-005 PSC, PSS, BT

Lower Sauk River Sauk River 01-AR-041

02-LP-059 PSC, PSS, BT

South Fork Stillaguamish River

Buck Creek 06050200044

06050200051 PSS, BT

Beaver Creek 02-LP-004 PSS, BT

South Fork Stillaguamish River 02-AR-004 PSC, PSS, BT

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Fifth Field Watershed Name Stream Name

NRIS 

Infestation 

Identification

Listed Fish 

Species1

Tye and Beckler Rivers Tye River 06-DL-002 PSC, PSS, BT

Beckler River 06-KW-12 PSC, PSS, BT

South Fork Skykomish River South Fork Skykomish River

06050600204

06-KW-005

06-KW-015

06-KW-016

06-SJ-009

PSC, PSS, BT

Money Creek 06-KW-001

06050600197 PSC, PSS, BT

Miller River 06050600196 PSC, PSS, BT

Rapid River 06-SJ-003 PSC, PSS, BT

Troublesome Creek 06050600125 PSC, PSS, BT

Upper White River

Huckleberry Creek 06050500262 PSC, PSS, BT

Wrong Creek 06050500330

06050500342 PSC, PSS, BT

Viola Creek 06050500339 PSC, PSS, BT

White River 05-KW-028 PSC, PSS, BT

Greenwater River

05-LP-010

05-LP-087

05-VW-056

05-TF-010

06050500061

PSC, PSS, BT

Kachess River- Yakima River Gold Creek

Keechelus Lake 05-KW-059 BT 

1 PSC = Puget Sound chinook; PSS = Puget Sound steelhead; BT = Coastal/Puget Sound bull trout. 

Essential Fish Habitat (Magnuson-Stevens Act)

The Magnuson-Stevens Fishery Conservation and Management Act (MSA), as amended by the 

Sustainable Fisheries Act of 1996 (Public Law 104-267), established procedures designed to identify, 

conserve, and enhance essential fish habitat (EFH) for those species regulated under a Federal fisheries 

management plan. 

Essential Fish Habitat is defined in the Act as “those waters and substrate necessary to fish for spawning, 

breeding, feeding, or growth to maturity.” Essential Fish Habitat includes all freshwater streams 

accessible to anadromous fish (Chinook, coho, and pink salmon), marine waters, and inter-tidal habitats.

The geographic extent of EFH on the Mt. Baker Snoqualmie National Forest is specifically defined as all 

currently viable waters and most of the habitat historically accessible to Chinook, coho, and pink salmon 

within the watersheds identified in Table 52. Salmon EFH excludes areas upstream of longstanding 

naturally impassible barriers (i.e., natural waterfalls in existence for several hundred years). Salmon EFH 

includes aquatic areas above all artificial barriers.

The EFH regulations at CFR Section 600.920(e)(l)(i) enable Federal agencies to use existing 

consultation/environmental review procedures to satisfy EFH consultation requirements if they meet the 

following criteria: (1) The existing process must provide the NOAA Fisheries (National Marine Fisheries 

Service – NMFS) with timely notification (60-90 days) of actions that may adversely affect EFH; (2) 

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Notification must include an assessment of impacts of the proposed action as discussed in Section 

600.920(g), and (3) NMFS must have made a “finding” pursuant to section (e)(3) that the existing process 

satisfies the requirements of section 305 (b)(2) of the Magnuson-Stevens Act.

Regional Forester Sensitive Aquatic Species

Table 52 identifies Regional Forester’s Sensitive species in the project area. Regional Forester’s Sensitive 

Species are managed to maintain species viability.

Table 52. Regional Forester's Sensitive Species within the MBS

Species ESU or DPS 5th Field Watersheds on MBS Habitat and Life History

Coho 

Salmon

Puget 

Sound/

Strait of 

Georgia

North Fork Nooksack River

Upper North Fork Nooksack River

Middle Fork Nooksack River

South Fork Nooksack River

Baker River, Skagit River/Diobsud 

Creek

Skagit River/Illabot Creek

Middle Skagit River/Finney Creek

Cascade River

Upper Suiattle River

Lower Suiattle River

Upper Sauk River

Lower Sauk River

North Fork Stillaguamish River

South Fork Stillaguamish River

Skykomish River/Wallace River

Skykomish River Forks

Tye and Beckler Rivers

Upper White River

Carbon River

Coho salmon are found in a broader diversity of 

habitats than any other anadromous salmonid, from 

small tributaries of coastal streams to inland 

tributaries of major rivers (Meehan and Bjornn 

1991). In the autumn, as water temperatures 

decrease, juvenile coho move into available side 

channels, spring-fed ponds and other off-channel 

sites to avoid winter floods. Streams with more 

structure (logs/root wads, boulders, undercut banks) 

support more coho salmon because they provide 

both food and cover. 

Chum 

Salmon

Puget 

Sound/

Strait of 

Georgia

North Fork Nooksack River

Upper North Fork Nooksack River

Middle Fork Nooksack River

South Fork Nooksack River

Baker River

Skagit River/Diobsud Creek

Skagit River/Illabot Creek

Middle Skagit River/Finney Creek

Cascade River

Upper Suiattle River

Lower Suiattle River

Upper Sauk River

Lower Sauk River

North Fork Stillaguamish River

South Fork Stillaguamish River

Skykomish River/Wallace River

Skykomish River Forks

Tye and Beckler Rivers

Upper White River

Carbon River

Freshwater migration in the Pacific Northwest is 

typically short in distance (<50 miles). Chum salmon 

utilize low gradient (1-2%), sometimes tidallyinfluenced reaches of streams for spawning, which 

limits their spawning distribution on Mt. BakerSnoqualmie National Forest. Most tidally-influenced 

areas have been disturbed in some form, which has 

introduced invasive species, such as knotweed plant 

along the stream banks or gravel bars. 

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Species ESU or DPS 5th Field Watersheds on MBS Habitat and Life History

Sockeye 

Salmon

Baker Lake 

Sockeye

Baker River

Middle Skagit River/Finney Creek

Many sockeye salmon that return to the Baker Lake 

watershed are artificially spawned and reared at a 

hatchery facility. Sockeye salmon that return in 

excess of hatchery needs are passed to Baker Lake 

where sockeye salmon spawning occurs in rivers 

and streams that are tributaries to lakes, but often 

sockeye salmon spawn along lake shores in areas 

where ground water percolates through gravel. 

Generally, sockeye salmon utilize areas along lake 

shores where the gravel is small enough to be 

readily dislodged by digging. Sockeye, however, 

may also utilize lake shore areas with other 

substrate types and sizes, depending largely on the 

presence or absence of upwelling. 

Coastal 

Cutthroat 

Trout

Puget Sound North Fork Nooksack River

Upper North Fork Nooksack River

Middle Fork Nooksack River

South Fork Nooksack River

Baker River

Skagit River/Diobsud Creek

Skagit River/Illabot Creek

Middle Skagit River/Finney Creek

Cascade River

Upper Suiattle River

Lower Suiattle River

Upper Sauk River

Lower Sauk River

North Fork Stillaguamish River

South Fork Stillaguamish River

Skykomish River/Wallace River

Skykomish River Forks

Tye and Beckler Rivers

North Fork Snoqualmie River

Middle Fork Snoqualmie River

South Fork Snoqualmie River

Upper White River

Carbon River

Coastal cutthroat trout exhibit diverse life histories 

with four distinct life history patterns. The life history 

patterns include anadromous populations, which 

migrate to the ocean or estuary for usually less than 

1 year before returning to freshwater; fluvial 

populations that migrate between small spawning 

tributaries and main rivers downstream; adfluvial 

populations migrate between spawning tributaries 

and lakes or reservoirs; and non-migratory resident 

forms (Quigley and Arbelbide 1997). In Washington, 

the anadromous cutthroat is typically referred to as 

“searun” cutthroat and is widely distributed in the 

lower Columbia River and the Coastal and Puget 

Sound drainages. Cutthroat trout typically spawn in 

small streams with juveniles remaining in 

freshwater. The anadromous juveniles undergo the 

morphological, physiological and behavioral 

changes required for migration and adaptation to 

salt water. In Washington, most coastal cutthroat 

trout spawn from January up to July, depending on 

life form. Spawning occurs in riffles where the water 

depth is about 15 to 45 cm, in areas of low gradient 

and low flow (WDFW 2000). Newly-emerged fry 

move quickly to low velocity water at stream margins 

and backwaters and remain there through the 

summer to feed. However, in the presence of coho 

salmon juveniles, which emerge earlier and at a 

larger size, cutthroat are often driven into highervelocity waters. Juveniles tend to move to log jams 

and overhanging banks to shelter during winter. 

They tend to remain in small streams for about a 

year then begin to migrate over longer distances 

within their natal river system. 

3.8.3 Environmental Consequences

3.8.3.1 Introduction

Concern has been expressed about the effects of herbicide use on fish and the aquatic ecosystem. Many 

laws, policies, standards and guidelines relate to aquatic ecosystems and activities near streams. The 

discussion below focuses on the potential effects on fish and their habitat that may occur with 

implementation of an alternative. The analysis relies upon and complements findings of the Soil and 

Water Resources sections. As referred to in the following analysis “fish” include fish species listed under 

the ESA, fish species designated as sensitive by the Regional Forester, and Management Indicator Species

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as designated in the MBS Forest Plan. “Fish habitat” includes critical habitat designated under the ESA, 

Essential Fish Habitat as designated under the Magnuson-Stevens Fishery Conservation Act and all other 

aquatic habitats occupied by fish. 

All alternatives (including No Action) “May Impact” sensitive aquatic species, but none would affect the 

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

alternatives would result in long-term restoration where natural plant communities and disturbance 

regimes have been altered by invasive plants. None of the chemicals proposed for use would result in 

long-term adverse alteration of aquatic habitat.

The following section discusses effects from non-herbicide and herbicide treatment methods occurring 

near streams that provide habitat for fish. Several lengthy documents are incorporated by reference 

including the R6 2005 FEIS and accompanying Fisheries Biological Assessment, Biological Opinions, 

and SERA Risk Assessments (1997a, 1997b, 1999a, 1999b, 2001a, 2001c, 2003a, 2003b, 2003c, 2003d, 

2003e, 2003f, 2011a, 2011b, 2011c, 2011d). The SERA Risk Assessment scenarios were used as 

indicators of situations where mitigation measures would be necessary to minimize adverse effects on the 

aquatic ecosystem.

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.

3.8.3.2 Effects from Non-Herbicide Treatments

Manual and mechanical treatments can result in increased bank erosion, stream sedimentation, and 

disturbance to aquatic organisms if carried out over a large, contiguous area in close proximity to 

occupied stream habitat. Sedimentation can cover eggs or spawning gravels, reduce prey availability, and 

irritate fish gills. 

Sediment generated at the localized scale would be very minor under all alternatives because of the small 

acreage treated with manual and mechanical methods. These impacts were found to be short term and 

insignificant (see Appendix J of the R6 2005 FEIS). Effective near stream invasive plant treatment and 

restoration of treated sites would improve the function of riparian areas and lead to improved fish habitat 

conditions in the years following passive and active restoration.

Removal of stream shade increases exposure to solar radiation often resulting in elevated water 

temperatures. There are no known areas on the MBS where invasive plant treatments may decrease 

riparian vegetative shading, thereby increasing the amount of solar radiation striking the water. Acres of 

very tall target vegetation along a stream would need to be removed (without any shade-producing 

vegetation remaining) for water temperature to increase. This situation is unlikely to occur and there are 

no known invasive plants providing important riparian shade. 

3.8.3.3 Herbicides in Aquatic Ecosystems 

Herbicide treatments along streams and roadside ditches may result in herbicide reaching water bodies 

through drift, runoff, and/or leaching. The movement, persistence, and fate of an herbicide in the 

environment determine the likelihood and the nature of the exposure fish and aquatic habitat may receive.

Important determinants of exposure of herbicide to fish are proximity to habitat, herbicide properties, 

precipitation amount and timing, application rate, extent of application, and application timing. 

Herbicides can alter the structure and biological processes of aquatic ecosystems; these effects of 

herbicides may have more profound influences on communities of fish and other aquatic organisms than 

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direct lethal or sub-lethal toxic effects (Norris et al. 1991). Stream and lake sediments may be 

contaminated with herbicides by deposition of soils carrying adsorbed herbicides from the land or by 

adsorption of herbicides from the water. Reductions in cover, shade, and sources of food from riparian 

vegetation could result from herbicide deposition in a streamside zone (Norris et al. 1991). 

Residues in food sources from direct spraying are most likely to occur during and shortly after 

application. Drift from herbicides considered for use may affect aquatic vegetation at low concentrations, 

however it shows little tendency to bioaccumulate and is likely to be rapidly excreted by organisms as 

exposure decreases (Norris et al. 1991).

Herbicide Risks to Fish and Fish Habitat 

Most toxicological effects of the proposed action on salmon and steelhead are likely to be from sub-lethal 

exposure to herbicides, rather than outright mortality from herbicide exposure. Effects such as fish killed 

as a result of sub lethal changes impairing normal behavioral patterns, otherwise known as ecological 

death could occur. 

Some exposed fish would not respond in any observable or measurable way. It is important to note that 

many sub-lethal toxicological endpoints or biomarkers may harm fish in ways that are not readily 

apparent. When small changes in the health or performance of individual fish are observed (e.g. a small 

percentage change in the activity of a certain enzyme, an increase in oxygen consumption, the formation 

of pre-neoplastic hepatic lesions, etc.), it may not be possible to infer an impaired normal behavioral 

pattern, even in circumstances where a significant loss could occur. Where sub-lethal tests have been 

conducted, they are typically reported for individual test animals under laboratory conditions that lack 

predators, competitors, certain pathogens, and other hazards found in the natural environment that affect 

the survival and reproductive potential of individual fish. 

The lethal endpoint has little predictive value for assessing whether pesticide exposure may cause sublethal neurological and behavioral disorders in wild salmon (Scholz et al. 2000), but in most cases, the 

LC50 is the only toxicity data available. Although little information is available on the sub-lethal effects 

of the herbicides on listed fish, there can be subtle sub-lethal effects that can potentially affect the survival 

or reproduction of large population segments. Recent studies (Fairchild et al. 2008, Fairchild et al. 2009 

and Stehr et al. 2009) have shed considerable light on effects of herbicides to early life histories and 

chronic effects to sensitive trout and salmon found in the Pacific Northwest. 

Tierney et al. (2006) studied the effects of five herbicides, including aquatic glyphosate, on coho salmon 

olfaction (i.e. smell). Coho salmon olfaction ability was reduced within 10 minutes of exposure to 1.0 

mg/L of aquatic glyphosate, and more rapidly to higher concentrations. There was no effect to olfaction 

ability when the aquatic glyphosate concentration was reduced to 0.1 mg/L. No concentrations were 

tested between 1.0 and 0.1 mg/L, which means that the true NOEC value may have been anywhere 

between 1.0 and 0.1 mg/L. This NOEC value is based on laboratory studies of pure water and thus may 

not be applicable to stream situations where soil is present in the water.

The Tierney et al. 2006 paper described the reaction of fish to glyphosate added directly to water in a 

tank, with no consideration given to the behavior of glyphosate in the environment. Glyphosate binds 

readily to soil, even in water, so the olfactory effects may not be applicable to actual field conditions.

The ecological significance of sub-lethal toxicological effects on individual fish depends on the degree to 

which essential behavior patterns are impaired, and the number of individuals exposed to harmful effects. 

Sub-lethal effects could compromise the viability and genetic integrity of wild populations if the effects 

are widespread across an entire DPS or ESU, or if localized exposures result in the concentrated impact to 

fish in a geographic area occupied by a local population with unique genetic traits. The likelihood of 

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population effects from sub-lethal effects of the chemicals in the proposed action are largely 

undocumented, but appreciable population effects can be ruled out if the potential exposure to harmful 

effects is limited to small numbers of fish and a spatial pattern that is not likely to cause the loss of a 

unique genetic stock. 

Weis et al. (2001) reviewed published literature on consequences of changes in behavior of fish from 

exposure to contaminants and noted studies reporting impaired growth and population declines from 

altered feeding behavior and impaired predator avoidance. Potential sub-lethal effects, such as those 

leading to a shortened lifespan, reduced reproductive output, or other deleterious biological outcomes are 

a potential threat to listed species from the considered actions.

The toxicological endpoints identified below are possible for a variety of herbicides and are generally 

considered to be important for the fitness of salmonids and other fish species. They include:

Direct mortality at any life history stage

An increase or decrease in growth

Changes in reproductive behavior 

A reduction in the number of eggs produced, eggs fertilized, or eggs hatched

Developmental abnormalities, including behavioral deficits or physical deformities

Reduced ability to osmoregulate or adapt to salinity gradients

Reduced ability to tolerate shifts in other environmental variables (e.g. temperature or increased 

stress)

An increased susceptibility to disease

An increased susceptibility to predation 

Changes in migratory behavior 

Most of these endpoints have not been investigated for the herbicides used in the proposed action. 

The risk of adverse effects on listed salmonids and their habitat was evaluated in terms of hazard quotient 

(HQ) values. Hazard quotient values are calculated by dividing the expected environmental concentration 

(expected exposure) by the effects threshold concentration (identified threshold). For fish, the effects 

threshold was the no-observed-effect concentration (NOEC) used by the R6 2005 Biological Opinion 

(NMFS 2006). The NOEC is defined as representing the threshold of acute sub-lethal effects. Thus, when 

the HQ value is greater than 1, then adverse effects on fish, in the form of acute sub-lethal effects, are at a 

higher risk to occur.

Toxicity Indices for Fish and Habitat

Table 53 shows the toxicity indices for fish. Concentrations of herbicides below this amount would be 

below a level of concern for fish. The indices represent the most sensitive endpoint from the most

sensitive species for which adequate data are available. Where acute NOEC concentrations are not 

available, 1/20th of published LC50 concentrations (SERA risk assessments) are used. Numbers in bold 

indicate the toxicity index used in calculating the hazard quotient for exposures to listed fish. Generally, 

the lowest toxicity index available for the species most sensitive to effects was used. Measured chronic 

data (NOEC) was used when they were lower than 1/20th of an acute LC50 because they account for at 

least some sub-lethal effects, and doses that are protective in chronic exposures are more certain to be 

protective in acute exposures.

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Table 53. Toxicity Indices for Fish

Herbicide Duration End-point Concentration Species Effect Noted at LOAEL

Aminopyralid

Acute NOEC 50 mg/L Rainbow 

trout

Partial loss of equilibrium at 100 

mg/L1

Chronic NOEC 1.36 mg/L Fathead 

minnow

Reductions in fry weight, length, 

larval survival, and % normal 

larvae at 2.44 mg/L

Chlorsulfuron

Acute NOEC 2 mg/L (1/20th of 

LC50) Brown trout LC50 at 40 mg/L

Chronic NOEC2 3.2 mg/L Brown trout rainbow trout length affected at 

66mg/L

Clopyralid

Acute NOEC 5 mg/L (1/20th of 

LC50)

Rainbow 

trout LC50 at 103 mg/L 

Chronic NOEC 10 mg/L Daphnia Estimated from Daphnia NOEC

Glyphosate (no 

surfactant)

Acute NOEC 0.1 mg/L3

 Coho 

salmon Olfactory impairment 

Chronic NOEC 2.57 mg/L4 Rainbow 

trout

Life-cycle study in minnows; 

LOAEL not given

Imazapic

Acute NOEC 100 mg/L All fish at 100 mg/L, no statistically sig. 

mortality

Chronic NOEC 100 mg/L Fathead 

minnow

No treatment related effects to 

hatch or growth

Imazapyr

Acute NOEC 5 mg/L (1/20th

LC50)

Trout, 

catfish, 

bluegill

LC50 at 110-180 mg/L for North 

American species

Chronic NOEC 43.1 mg/L Rainbow “nearly significant” effects on early 

life stages at 92.4 mg/L

Metsulfuron 

methyl

Acute NOEC 10 mg/L Rainbow lethargy, erratic swimming at 100 

mg/L

Chronic NOEC 4.5 mg/L Rainbow standard length effects at 8 mg/L

Picloram

Acute NOEC 0.04 mg/L (1/20th

LC50)

Cutthroat 

trout LC50 at 0.80 mg/L

Chronic NOEC 0.55 mg/L Rainbow 

trout

body weight and length of fry 

reduced at 0.88 mg/L

Sulfometuron 

methyl

Acute NOEC 7.3 mg/L Fathead 

minnow

No signs of toxicity at highest 

doses tested

Chronic NOEC 1.17 mg/L Fathead 

minnow

No effects on hatch, survival or 

growth at highest doses tested

Triclopyr (TEA)

Acute NOEC 0.26 mg/L (1/20th

LC50)

Chum 

salmon LC50 at 5.3 mg/L5

Chronic NOEC 104 mg/L Fathead 

minnow

Reduced survival of embryo/larval 

stages at 140 mg/L

1 Partial loss of equilibrium was not statistically significant, did not occur in exposures less than 96 hours, and did not occur in 

another study. EPA set the NOEC at 100 mg/L for rainbow trout. 2 Chronic value for brown trout (sensitive sp.) was estimated using relative potency in acute and chronic values for rainbow trout, 

and the acute value for brown trout.

3 Using values that impaired olfactory function in coho salmon from Tierney et al. 2006.

4 Estimated from minnow chronic NOEC using the relative potency factor method (SERA Glyphosate 2011). 5 Using Wan et al. (1989) value for lethal dose.

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In addition to effects of direct exposure on listed fish, indirect effects of reduced food sources through the 

effects herbicides on aquatic non-target species, primarily in the form of reduced algae production and 

reduced aquatic macrophyte production can occur. The likelihood of adverse indirect effects is dependent 

on environmental concentrations, bioavailability of the chemical, and persistence of the herbicide in 

aquatic habitat. For most pesticides, including the chemicals in the proposed action, there is limited 

information available on environmental effects such as negative impacts on primary production, nutrient 

dynamics, or the trophic structure of macroinvertebrate communities. 

Most available information on potential environmental effects must be inferred from laboratory assays 

conducted on a specific target endpoint; although a few observations of environmental effects are reported 

in the literature. Due to the paucity of information, there are uncertainties associated with the following 

factors: 1) The fate of herbicides in natural streams; 2) the specific effects on, and resiliency and recovery 

of aquatic communities; 3) the site-specific foraging habits of salmonids and the vulnerability of key prey 

taxa and 4) the mitigating or exacerbating effects of local environmental conditions.

Benthic algae (Table 54) are important primary producers in aquatic habitats and are thought to be the 

principal source of energy in many mid-sized streams (Vannote et al. 1980; Murphy 1998). Herbicides 

cause shifts in the composition of benthic algal communities at concentrations as low as in the low parts 

per billion. Herbicides can elicit significant effects on aquatic microorganisms at concentrations that may 

occur with normal usage under the label instructions (De Lorenzo et al. 2001). In most cases the 

sensitivities of algal species to herbicide formulations and their response to herbicide formulations are not 

known. However, human activities that modify the physical or chemical characteristics of streams can 

change the trophic system that ultimately reduces salmonid productivity (Bisson and Bilby 1998). 

Consequently, herbicides have the potential to affect salmonid productivity through their effects on the 

biotic community.

Table 54. Toxic Indices for Algae

Herbicide Duration Concentration Species Effects noted at 

LOAEL

Aminopyralid

Acute 

6 mg/L Diatoms Cell density Chronic

Chlorsulfuron

Acute 

0.01 mg/L Selanastrum 

capriconutum Mortality Chronic

Clopyralid

Acute 6.9 mg/L Selanastrum 

capriconutum Growth inhibition

Chronic Chronic study of duckweed showed EC50 >> sensitive algae (acute)

Glyphosate

(most toxic 

formulation)

Glyphosate appears to be about equally toxic to algae and aquatic plants; see aquatic 

plants table

Imazapic

Acute 0.05 mg/L *** Various species Growth inhibition

Chronic

Imazapyr

Acute 

0.2 mg/L * Chlorella Growth inhibition

Chronic

Metsulfuron methyl

Acute 

0.09 mg/L Selanastrum 

capriconutum

Growth inhibition

Chronic Only short-term data 

available

Picloram

Acute 0.23 mg/L Diatoms Growth inhibition

Chronic 0.23 mg/L

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Herbicide Duration Concentration Species Effects noted at 

LOAEL

Sulfometuron methyl

Acute 

0.0025 mg/L Selanastrum 

capriconutum Cell density Chronic

Triclopyr TEA All exposures 5.9 mg/L * Unspecified algae Mortality

* NOEC is estimated from LC50. 

** NOEC is estimated from EC10.

*** NOEC estimated from LOEC. 

Indirect effects of chemicals used to treat invasive plants on ecosystem structure and function are a key 

factor in determining a toxicant’s complete risk to aquatic organisms (Preston 2002). Aquatic plants 

(Table 55) are generally more sensitive than fish to acute toxic effects of herbicides. Therefore, chemicals 

can potentially affect the structure of aquatic communities, at the primary production level, at 

concentrations below thresholds for direct impairment in fish. 

Indirect effects resulting from the proposed action are expected to be of varying duration (days to weeks). 

Degraded water quality, reflected by primary and secondary productivity loss, may occur for a very short 

time (hours). Recovery of algae and aquatic macrophytes, if impacts occur, could take up to several 

weeks.

Table 55. Toxicity Indices for Aquatic Plants (Macrophytes)

Herbicide Duration Concentration Species Effects noted at 

LOAEL

Aminopyralid Acute 44mg/L Duckweed Frond Density

Chronic

Chlorsulfuron Acute 0.00047 mg/L * Lemna minor Mortality

Chronic

Clopyralid See information for algae

Glyphosate

(most toxic formulation)

Acute 3 mg/L Duckweed Growth inhibition

Chronic

Imazapic Acute 0.0013 mg/L Lemna gibba Growth inhibition

Chronic

Imazapyr Acute 0.013 mg/L ** Lemna gibba Growth inhibition

Chronic

Metsulfuron methyl Acute 0.00016 mg/L Duckweed Based on chronic data

Chronic Mortality 

Picloram Acute 0.1 mg/L *** Water milfoil Transient inhibition of 

flowering Chronic

Sulfometuron methyl All exposures 0.00021 mg/L Lemna gibba Mortality

Triclopyr TEA All exposures 5.9 mg/L * Unspecified algae Mortality

* NOEC is estimated from EC50

** NOEC is estimated from EC25

*** NOEC is estimated from LOEC

Juvenile salmonids feed on a diverse array of aquatic invertebrates, with aquatic insects, and crustaceans 

comprising the large majority of the diets of fry and parr in all salmon species (Levings et al. 1995). 

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Prominent taxonomic groups in the diet include Chironomidae (midges), Ephemeroptera (mayflies), 

Plecoptera (stoneflies), Tricoptera (caddisflies), and Simuliidae (blackfly larvae) as well as amphipods, 

harpacticoid copepods, and daphniids. Chironomids in particular are an important component of the diet 

of nearly all freshwater salmon fry (Levings et al. 1995). With a few exceptions (e.g. daphniids), the 

impacts of pesticides on salmonid prey taxa have not been widely investigated. Available studies suggest 

that aquatic invertebrates (Table 56) are relatively resistant to lethal effects of herbicides however sublethal effects may affect invertebrate populations at the site scale. 

Availability of food is essential to rearing and migrating fish and is an essential element of those PCEs of 

critical habitat. The decrease in primary productivity of streams and rivers resulting from herbicide 

applications would vary in space and in time. Detrimental effects on primary production could be linked 

to decreases in aquatic invertebrates.

Factors affecting prey species are likely to affect the growth of salmonids, which is largely determined by 

the availability of prey in freshwater systems. Food supplementation studies (Mason 1976) have shown a 

clear relationship between food abundance and the growth rate and biomass yield of juveniles in streams. 

Therefore, herbicide applications that reduce the abundance of aquatic plants (macrophytes) and 

macroinvertebrates in streams can also reduce the energetic efficiency for growth in salmonids. These 

considerations are important because juvenile growth is a critical determinant of survival (Baldwin et al. 

2009). A study on size-selective mortality in Chinook salmon from the Snake River (Zabel and Williams 

2002) found that naturally reared wild fish did not return to spawn if they were below a certain size 

threshold when they migrated to the ocean. There are two primary reasons mortality is higher among 

smaller salmonids. First, fish that have a slower rate of growth suffer size-selective predation during their 

first year in the marine environment (Healey 1982; Beamish and Mahnken 2001). Growth-related 

mortality occurs late in the first marine year and may determine, in part, the strength of the year class 

(Beamish and Mahnken 2001). Second, salmon that grow more slowly may be more vulnerable to 

starvation or exhaustion (Sogard 1997).

Table 56. Toxicity Indices for Aquatic Invertebrates

Herbicide Duration Concentration Species Effects noted at 

LOAEL

Aminopyralid

Acute 98mg/L

102 mg/L Daphnia magna No effects observed

Chronic

Chlorsulfuron

Acute 10 mg/L

20 mg/L Daphnid Mortality Chronic

Clopyralid

Acute 214 mg/L

11.8 mg/L Daphnid Mortality Chronic

Glyphosate

(most toxic formulation)

Acute 11 mg/L

0.7 mg/L Daphnia magna

Mortality

Estimated from less 

toxic formulation Chronic

Imazapic

Acute 100 mg/L

100 mg/L Daphnia magna No effect at any 

Chronic concentration

Imazapyr

Acute 100 mg/L

97.1 mg/L Daphnia magna No effects observed

Chronic

Metsulfuron methyl

Acute 420 mg/L

17 mg/L Daphnia magna Immobility

Chronic Growth

Picloram Acute 26.8 mg/L Shrimp Mortality

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Herbicide Duration Concentration Species Effects noted at 

LOAEL

Chronic 3.8 mg/L Oyster larvae

Sulfometuron methyl

Acute 75 mg/L Alonella spp. & 

Cypria spp.

Not given

Chronic 0.19 mg/L Neonate survival

Triclopyr TEA

Acute 133 mg/L Not given Mortality

Chronic 81 mg/L Daphnid Reproduction

NOEC is estimated from LC50. 

** NOEC is estimated from LOEC (lowest observable effect concentration. 

*** estimated from subchronic study. 

Inert Ingredients-Adjuvants, Impurities and Surfactants

Inert ingredients, including adjuvants, impurities and surfactants, were studied as a part of SERA risk 

assessment for most herbicides. POEA surfactant may be toxic to aquatic species. The 2011 SERA Risk 

Assessment for glyphosate considered the differences in toxicity to the aquatic ecosystem of glyphosate 

with and without this surfactant. Other surfactants did not influence the risk assessment findings. The 

MR/MM in the alternatives have been modified to eliminate use of POEA. This would eliminate potential 

risks associated with POEA. 

Herbicide Application to Ditches and Intermittent Channels

Herbicides applied within ditches and intermittent stream channels may be delivered to places where fish 

or their food might be exposed by leaching into soil, dissolving directly into ditch or stream channel flow 

(when present), and erosion of exposed soil. Important determinants of exposure risk from ditch or 

intermittent channel treatments are herbicide properties, application rate, extent of application, application 

timing, precipitation amount and timing, and proximity to aquatic habitat. 

The MR/MM and herbicide use buffers limit the amount of any herbicide that may enter the ditch; 

however an unexpected rainstorm immediately after application may result in a minor amount being 

delivered downstream. Fish may be exposed at the delivery point for a short amount of time before 

herbicides are diluted to undetectable levels.

Relative Risk to Fish and Habitat from Herbicides

Every risk assessment models the amount of chemical that can reach water under several different 

scenarios, then compares model results to existing monitoring data to check the accuracy of the model. 

Effects from drift, runoff and leaching were considered in the SERA (2001, 2003, 2004, 2011) herbicide 

risk assessments, prepared for the R6 2005 FEIS (USDA 2005a), assuming broadcast treatments 

occurring directly adjacent to streams. The GLEAMS model used to estimate the amount of herbicide that 

may potentially reach a reference stream via runoff, drift and leaching in a 96 hour period, assuming 

broadcast treatments on a sparsely vegetated 50-foot strip along about 1.6 miles of a 1.8 cfs perennial 

stream. 

Dissipation, degradation and other environmental processes are considered to predict chronic exposure for 

aquatic species (SERA Worksheet F09 and Tables 3-1 and 3-2, all risk assessments). Calculations are 

detailed in worksheets, which can be duplicated using site-specific information to predict potential 

concentrations of chemicals in surface water. This information can then be used to evaluate the potential 

effects to aquatic organisms and water quality. The effect of MR/MM and herbicide use buffers in 

reducing predicted HQ values under SERA risk assessment scenarios have not been quantified. SERA 

worksheets are available to refine some site-specific parameters (such as application rate); however the 

effect of the mitigation measures in restricting the timing, extent, location, herbicide selection, and 

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application rate cannot be precisely modeled. Table 57 displays which herbicides may exceed HQ of 1 

under the SERA modeled acute exposure scenario assuming herbicide treatment of 10 acres adjacent to a 

small stream. Table 48 in Chapter 3.7 shows the central, upper and lower estimates of concentrations of 

herbicides predicted to reach streams for herbicides that may be applied within 100 feet of a wet stream. 

Table 57. Relative Risk to Fish, Aquatic Invertebrates, Algae and Aquatic Plants From Riparian Use of 

Herbicides at MBS Rates Aminopyralid

Chlorsulfuron

Clopyralid

Glyphosate no 

surfactant

Glyphosate with 

POEA surfactant4

Imazapic

Imazapyr

Metsulfuron 

methyl

Picloram

Sulfometuron 

methyl

Triclopyr TEA

Fish -- -- -- Ù1 Ù2 -- -- -- Ù2 -- Ù1

Aquatic 

invertebrates -- -- -- -- -- -- -- -- -- -- -- 

Algae -- Ù1 -- -- -- -- Ù1 -- -- Ù1 Ù1

Aquatic 

plants -- Ù3 -- -- -- Ù1 Ù2 Ù1 Ù1 Ù2 Ù1

-- Predicted concentrations are less than the estimated or measured ‘no observable effect concentration’.

Ù Predicted concentrations greater than the estimated or measured ‘no observable effect concentration’ at MBS proposed 

application rates without mitigation.

1 At the MBS application rate, the toxicity index is exceeded only in the upper exposure assumptions. 2 At the MBS application rate, the toxicity index is exceeded in the central and upper exposure assumptions. 3 Lower, central and upper exposure estimates exceed the toxicity index at the MBS application rates.

4 POEA surfactant would not be used in this project 

Actual proposed treatments contain untreated buffers; or distances within which only spot spray or hand 

application is allowed. The 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 almost non-detectable 

levels. Table 40 in Chapter 3.6 (Soils) shows that most of the herbicide that is applied is taken up by the 

target plant or remains in the upper 12 inches of the soil profile. 

Photo-degradation, hydrolysis, adsorption to particles in the water column and along the channel side and 

bottom, dilution resulting from influx of additional water (either subsurface or surface), and accretion of 

volume would together minimize potential effects on fish and aquatic habitats. Herbicides coming in 

contact with water, if any, would either be well below levels of concern or non-detectable under the

proposed alternatives. 

Accidental Spills

Accidental spills have the potential to introduce larger amounts of herbicide into streams and other water 

bodies. Risks are minimized by only carrying the amount of herbicide that would be applied in 1 day and 

performing all mixing operations well away from any water bodies. The Forest Service has not had a 

significant or reportable skill in R6 since the implementation of the R6 2005 ROD (Desser 2013). 

3.8.3.4 Direct, Indirect and Cumulative Effects by Alternative 

The alternatives vary as to the degree of risk to aquatic organisms from herbicide and non-herbicide 

treatments. All alternatives implement mitigation measures to minimize or avoid adverse effects. None of 

the alternatives are expected to result in measureable adverse impacts to fish or their habitat. 

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Alternative 1 (No Action)

The No-Action Alternative would continue the currently approved use of herbicides on the MBS. Aquatic 

labeled glyphosate, aquatic-labeled imazapyr and clopyralid may be applied within a set of mitigation 

measures designed to limit the exposure to aquatic habitats and fish. 

The greatest risk to the aquatic environment is the potential for a spill of the undiluted concentrate of the 

aquatic formulation of glyphosate directly into a stream or wetland. To alleviate this risk: herbicide spray 

mixtures would not be prepared within 300 feet of riparian areas, wetlands, or surface water, and 

containment mats must be used during mixing to further avoid the risk of a spill. 

The aquatic formulation of glyphosate (with Agri-Dex® added, where a surfactant would be needed) was 

specifically chosen as the herbicide for use on the MBS, not because of its effectiveness per se, but rather 

because of the lack of effects on the aquatic environment. Washington State Department of Ecology has 

approved use of glyphosate for use in aquatic environments for treating aquatic invasive plants 

(Washington State DOE 2001). However, SERA modeling shows that the project has potential to exceed 

the rate that has shown sub-lethal effects to fish under laboratory conditions. Under the No-Action 

Alternative, the application methods (no broadcast spraying), plus the limited amount of herbicide that 

would be used in primarily small infestations and with the prescribed mitigation measures, the risk that 

the aquatic formulation of glyphosate would reach a measurable level in the aquatic environment is 

essentially alleviated.

After an extensive literature review, in which the three commonly used surfactants were evaluated for 

potential use (LI-700®, R-11®, and Agri-dex®), Agri-Dex® was determined to be the least toxic 

surfactant (SERA 1997). Given the low toxicity of the chemical to fish and the low probability of the 

chemical reaching fish-bearing water, no effects on fish would be expected from the described treatment 

methods using this surfactant. 

The use of tested and approved, host-specific biological control agents would not be expected to have any 

effects on fish.

Direct and Indirect Effects to Fish Habitat Including Designated Critical Habitat and Essential Fish 

Habitat 

Of the herbicides evaluated for this alternative, imazapyr was modeled in the SERA worksheets to have 

the potential to adversely affect algae and aquatic plants at the MBS application rate. If a spill or 

unexpected rainstorm were to wash imazapyr directly into fish habitat there is some potential that algae or 

aquatic plants could be affected with isolated reductions of primary productivity occurring. The isolated 

cases of reduction of the freshwater rearing forage also are not likely to decrease the conservation value 

of critical habitat, nor detrimentally affect the productivity of the freshwater life cycle.

Physical changes to fish habitat are not likely to occur under Alternative 1 because the type of treatments 

currently approved are unlikely to result in meaningful erosion or habitat disturbance. 

Direct and Indirect Effects to ESA listed, Sensitive and Management Indicator Fish

Of the herbicides evaluated for this alternative, glyphosate was modeled in the SERA worksheets to have 

the potential to exceed the no effect concentration level for fish at the MBS application rate. In some 

circumstances, herbicides may wash into streams from rainfall occurring during or shortly after herbicides 

are applied along road ditches or on low permeability soils. Rainstorms are likely to occur within the 

watersheds containing listed salmonids. In such instances, adverse effects on fish could occur particularly 

in small tributary streams where the flows would be diluted more slowly. On certain occasions when 

rainfalls occur during or soon after herbicide application, fish could be exposed to glyphosate 

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concentrations leading to the occurrence of sub-lethal effects. Outright mortality of fish from herbicide 

exposure is highly unlikely. While it is possible that individuals would express impaired normal 

behavioral patterns these outcomes would be limited because exposures would be too intermittent, based 

on the expected action and its incorporated mitigation measures. As a result, these outcomes are not likely 

to produce an observable change in the abundance, distribution, diversity, or productivity of fish species 

at either the population or species level. 

Minor disturbance to a small number of individual fish is possible due to human presence from treatments 

within aquatic influence zones. The effect of this disturbance is expected to be short lived and not have 

any measureable effect on individuals or populations. 

New Invader Strategy (Early Detection and Rapid Response) 

The effects to the aquatic environment from treating unknown future populations would be similar to the 

effects of treating the known inventory. MR/MM and an annual screening process ensure that effects are 

within the scope of the analysis of known sites. 

Alternative 2 (Proposed Action)

Alternative 2 has the greatest potential to benefit aquatic resources by effectively treating invasive plants. 

MR/MM would minimize the potential for adverse effects on fish and habitat. 

Direct and Indirect Effects To Fish Habitat Including Designated Critical Habitat and Essential 

Fish Habitat 

Of the herbicides evaluated for this alternative, several were modeled in the SERA worksheets to have the 

potential to adversely affect algae and aquatic plants at the MBS application rate. These herbicides 

include chlorsulfuron, imazapic, imazapyr, metsulfuron methyl and triclopyr. Mitigation measures allow 

only aquatic labeled versions of imazapyr and triclopyr to be applied to the waterline of aquatic systems; 

all others are to be used above the bankfull elevation only. Broadcast applications (with the exception of 

aminopyralid, which poses little risk to fish) require at least a 60 to 100 foot herbicide use buffer. No

broadcast spraying of triclopyr is approved. 

Localized effects to algae and aquatic plants are possible as a result of treatments that occur within the 

bankfull channel. These localized effects would not disrupt aquatic ecosystem function of the aquatic food 

web because of the low potential to reach toxicity levels for each trophic level under spot and hand/select 

applications with aquatic labeled imazapyr or triclopyr. Some aquatic plants could be damaged at the 

immediate spot spray locations if enough herbicide comes in contact with the aquatic plant. Not be 

enough herbicide would contact water to result in aquatic plant mortality. 

The amount of herbicide that would be available for runoff, leaching and/or drift is necessarily limited by 

restrictions on broadcast use. Spot and hand/select treatments have lower potential to deliver herbicide 

because the treatments are directed at target vegetation and herbicide would not be applied to large 

contiguous areas. 

Physical changes to fish habitat are not likely to occur under Alternative 2 because the type of treatments 

currently approved are unlikely to result in meaningful erosion or habitat disturbance. 

Direct and Indirect Effects to ESA Listed, Sensitive and Management Indicator Fish 

Of the herbicides evaluated for this alternative, glyphosate, picloram, and triclopyr were modeled in the 

SERA worksheets to have the potential to exceed the no effect concentration level for fish at the MBS 

application rates. Herbicide use buffers have been established based on the persistence, mobility and 

toxicity of each herbicide and whether or not it has been labeled for aquatic use. The probability that fish 

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would be exposed to harmful concentrations of herbicide is very low due to MR/MM and herbicide use 

buffers. 

In some circumstances, herbicides are likely to wash into streams from rainfall occurring during or shortly 

after herbicides are applied along road ditches or on low permeability soils. Rainstorms are likely to occur 

within the watersheds containing listed salmonids. In such instances, adverse effects on fish could occur 

particularly in small tributary streams where the flows would be diluted more slowly. On certain 

occasions when rainfalls occur during or soon after herbicide application, listed fish are likely to be 

exposed to herbicide concentrations leading to the occurrence of sub-lethal effects. Outright mortality of 

fish from herbicide exposure as a result of the proposed action is highly unlikely. In some circumstances, 

isolated reductions of primary productivity could occur. While it is possible that individuals will express 

impaired normal behavioral patterns, these outcomes would be limited because exposures would be 

intermittent, based on the proposed action and incorporated MR/MM. As a result, herbicide use under this 

alternative is not likely to produce an observable change in the abundance, distribution, diversity, or 

productivity of fish species at either the population or species level.

Aquatic organisms may be briefly exposed to measurable levels of glyphosate or other herbicide 

compounds if an unexpected rainfall event occurs shortly after an application. To be exposed, individuals 

would need to be near the confluence where a ditch or intermittent stream channel is located when the 

“first flush” event occurred.

In general, juvenile and adult fish would avoid the presence of human beings and would more than likely 

swim away from predator like shadows overcasting water bodies. The possibility of a fish being present 

in the immediate water column where spot spray applications may be taking place up to the water’s edge 

is low. However, fry avoid faster flows and tend to rear along the shoreline or around large 

substrate/wood where flow is slower. Fry tend to avoid overcasting shadows as well but can return to their 

previous location after being disturbed if a human stands still enough near the stream margin. 

Fish in the mainstem of rivers and streams would have substantially less risk of exposure because of a 

river’s large flow and the relatively low proportion of fish that occur immediately along a river’s edge.

Smaller streams however, do not have as much flow and may not dilute herbicides as quickly. Fish in 

smaller streams tend to be juveniles and fry. Although there would be no herbicide applied directly to the 

water column for purposes of treating submerged vegetation, there may be some fine droplets from spot 

applications coming in contact with water as a result of treating near shore vegetation. 

Early Detection and Rapid Response

The effects to the aquatic environment from treating unknown future populations would be similar to the 

effects of treating the known inventory. MR/MM, herbicide use buffers, and project caps would ensure 

that effects are within the scope of the analysis of known sites.

Alternative 3 (No Aminopyralid) 

Alternative 3 would have similar effects to aquatic habitat and fish as Alternative 2 except herbicides 

posing greater relative risk to fish would be the first year/first choice on 10.5 percent more acreage of 

known infestations within the aquatic influence zone. With proper application of MR/MM, herbicide use 

buffers and project caps, herbicide use in Alternative 3 would pose a low risk to aquatic habitats and fish. 

3.8.3.5 Cumulative Effects for All Alternatives

While some commonly used herbicides are associated with hazards to aquatic organisms, harmful 

amounts of herbicides coming in contact with water as a result of Forest Service applications are not 

likely to occur for all existing inventory sites and for future treatments within the scope of this project.

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The annual limitation on extent of treatment for within 6th field watersheds further reduces the potential 

for effects at a meaningful scale. Herbicides coming in contact with water via drift or runoff at the 

immediate application site would dissipate rapidly and become non-detectable or below levels of concern. 

Cities, counties, and Washington state all have ongoing invasive plant treatment programs operating in the 

region that can affect conditions in the action area (see Chapter 3.1.6). These programs are assumed to 

have effective aquatic protection measures. Invasive plants are treated along road rights-of-way annually 

by city, state, and county transportation departments, sometimes several times a year. Any herbicide 

contamination that occurs from the proposed project could potentially combine with contaminants from 

other non-Federal activities, and contribute to formation of chemical mixtures or concentrations that could 

kill or harm listed steelhead or salmon. In addition, fish stressed by elevated sediment and temperatures 

and limited habitat due to lack of accessibility are more likely to be susceptible to toxic effects of 

herbicides. 

The Management Requirements and Mitigation Measures, along with the herbicide use buffers, reduce 

the potential for herbicide to reach a level of concern at any scale. There would be no potential for 

herbicide to accumulate with use downstream and reach a threshold of concern. This is because the 

amount of treatment proposed compared to the size of the watershed and extent of the aquatic ecosystem 

is very low and effects to habitat are likely to be negligible. State monitoring data for treatment of aquatic 

emergent vegetation has either resulted in no detections or below State drinking water standards, which 

are more restrictive than the levels of concern for fish used for this analysis. See Chapter 3.7 for citations 

and information about this monitoring. 

Activities within riparian reserves in TAA 2, 3, 4, 16, 20, 23, 27, 32, 33, 45, and 49 (especially TAA 3, 20, 

23, 27 and 45 that have more than 100 acres of invasive plant treatment proposed within riparian reserves) 

have the most potential to overlap with recently completed, current, ongoing, or foreseeable future 

projects that may affect aquatic resources. The other TAAs have much lower potential for impacts that 

could combine with other projects on the MBS because so little of the riparian reserve would be proposed 

for treatment in all alternatives, or there is no overlap within the TAAs that could cause a cumulative 

impact. 

Vegetation management in TAA 2, 3, 4, and 16, may overlap with invasive plant treatments in riparian 

reserves. Riparian reserve conditions would be maintained and invasive plant treatment would help 

restore native plant communities disturbed by the vegetation management. Short term and localized 

adverse impacts to fisheries could occur from these projects, however projects would not jeopardize any 

aquatic species. Recreation management projects in TAA 23, 27, 33, 45, and 49 are unlikely to adversely 

affect aquatic organisms or combine with invasive plant treatments to cause any cumulative impacts to 

fish. 

Road projects (mainly repair and closure) in TAA 20, 23, 32, 33, 45 and 49 would help improve fish 

habitat recovery over the long run. The effects of invasive plant management would not combine with the 

effects of the road projects to cause any adverse cumulative effects on fish. Stream restoration in TAA 32 

would also serve to improve fish habitat and invasive plant treatment would contribute to beneficial 

cumulative effects. 

Some sediment may also be delivered to streams, especially from manual treatment methods in all 

alternatives. The sediment could combine with sediment generated from other projects and reach streams. 

However, sediment is not likely to accumulate and impact water resources because (1) native vegetation 

would be retained on all sites and impacts from the project to any stream system would be minimal and 

short-lived and (2) sediment delivery is mitigated in other Forest Service projects.

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3.8.4 Consistency with Regulations, Policies and Plans

All alternatives would be consistent with regulations, policies and plans associated with management of 

aquatic organisms and aquatic habitats. 

3.8.4.1 Aquatic Conservation Strategy

Treatment of invasive plants is consistent with recommendations in watershed analysis done for 

watersheds on the Mt. Baker-Snoqualmie National Forest. Invasive plant treatments in the scope of this 

document are not likely to retard achievement of ACS objectives because the scale of treatment is small 

and the potential for harm is low. Chemical treatment within riparian reserves (approximately 2,140 

acres) would not prevent attainment of ACS objectives and would the requirement that herbicide sand 

other chemicals be applied in a manner that avoids impacts that retard or prevent attainment of Aquatic 

Conservation Strategy objectives.

Approximately 4,000 acres of the MBS across all watersheds (1.2 million acres) are currently 

infested. 

Less than 250 acres of MBS within any single 5th field watershed are currently infested. 

An analysis of each alternative relative to ACS objectives is in the following section.

Aquatic Conservation Objectives

The following discussion is focused on the existing condition relative to invasive plants in the treatment 

analysis areas and their impact on meeting ACS objectives. 

1. Maintain and restore the distribution, diversity, and complexity of watershed and landscape-scale 

features to ensure protection of the aquatic systems to which species, populations and communities are 

uniquely adapted. 

All alternatives would restore the diversity of watershed scale features by removing invasive plants 

found growing adjacent to or within aquatic influence areas. Alternatives 2 and 3 would be more 

effective due to a broader range of tools available to treat invasive plants. 

2. Maintain and restore spatial and temporal connectivity within and between watersheds. Lateral, 

longitudinal, and drainage network connections include floodplains, wetlands, upslope areas, headwater 

tributaries, and intact refugia. These network connections must provide chemically and physically 

unobstructed routes to areas critical for fulfilling life history requirements of aquatic and ripariandependent species. 

All alternatives would not likely affect chemical or physical routes to areas critical for fulfilling life 

history requirements of aquatic and riparian-dependent species. The amount of treatment in any given 

watershed is small. 

Some invasive plant treatments can have positive effects on floodplains and stream banks when 

infestations of invasive plants on valley bottom areas are removed. Valley-bottom infestations often 

encroach floodplains where road-related and recreational activities have led to the establishment of 

invasive plant populations. Removal of such infestations is expected to benefit aquatic and terrestrial 

communities in the long term by increasing floodplain area available for nutrient, sediment and large 

wood storage, and flood flow refugia. 

Invasive plant treatments would not create physical barriers or otherwise degrade access to aquatic 

habitat. 

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3. Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and 

bottom configurations. 

All alternatives would restore the physical integrity of shorelines and stream banks by replacing 

invasive plants with native plant communities. The types of treatments proposed could result in minor 

stream bank erosion, but since no heavy equipment would be used, impacts would be localized and 

short-lived. There is no risk of negatively impacting channel condition and dynamics as a result of 

treating invasive plants.

4. Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland 

ecosystems. Water quality must remain within the range that maintains the biological, physical, and 

chemical integrity of the system and benefits survival, growth, reproduction, and migration of individuals 

composing aquatic and riparian communities. 

The extent and range of infestations currently found in aquatic influence zones is relatively small. No 

more than 10 acres would be treated within any 1.5 miles of stream. The amount of treatment that 

could occur annually in aquatic influence zones is limited by mitigation measures so that future 

treatments under EDRR would not result in greater potential effects. Some herbicide may enter 

water bodies, but not in quantities sufficient to reduce water quality at any scale.

5. Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the 

sediment regime include the timing, volume, rate, and character of sediment input, storage, and transport.

Treatment of invasive plants has a low probability for producing sediment because very little ground 

disturbance would take place when invasive plants are treated with spot-spray or hand applications. 

Manual, mechanical, and restoration treatments are extremely unlikely to contribute sediment. The 

integration of manual/mechanical/herbicide treatments would limit the potential for excessive 

trampling and not solely rely on manual labor. Manual labor such as hand pulling and the use of 

mechanical equipment to control invasive plants may result in localized soil disturbance, but 

increases of sediment to streams would likely be undetectable. Not all vegetation in a treated area 

would be pulled or removed, so some ground cover plants would remain. Hand pulling is very labor 

intensive and costly. Thus, few acres per year could be treated using this technique across a 

watershed. The amount of sediment created by manual, mechanical, and restoration treatments is 

anticipated to be insignificant because the methods of treatments do not include ground disturbing 

activities by heavy equipment. When compared to the total acres within a watershed, project-related 

soil disturbance from hand pulling would be negligible. 

6. Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic, and wetland 

habitats and to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, 

and spatial distribution of peak, high, and low flows must be protected. 

Invasive plants can change stand structure and alter future inputs of wood and leaves that provide the 

basic foundation of the aquatic ecosystem food webs. Hydrologic changes from invasive plant 

treatments would never be large enough to cause effects at a sub-watershed scale. There is no risk of 

increasing water yield at any scale as a result of treating invasive plants.

Removal of invasive plants and replacement with native plant communities would restore future 

inputs of wood and leaves that provide the basic foundation of the aquatic ecosystem food webs. 

Treatment of invasive plants in riparian reserves would not impact current wood debris in streams. 

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7. Maintain and restore the timing, variability, and duration of floodplain inundation and water table 

elevation in meadows and wetlands.

Removal of invasive plants and replacement with native plant communities would restore floodplain 

habitat and water table elevation in meadows and wetlands. 

8. Maintain and restore the species composition and structural diversity of plant communities in riparian 

areas and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, 

appropriate rates of surface erosion, bank erosion, and channel migration and to supply amounts and 

distributions of coarse woody debris sufficient to sustain physical complexity and stability.

Removal of invasive plants and replacement with native plant communities would restore species 

composition and structural diversity in riparian areas and wetlands. Herbicide application near 

streams may result in some minor non-target vegetation impacts at the site scale; however, the 

amount of herbicide that could contact streams would not be enough to alter non-target species or 

structural diversity. 

9. Maintain and restore habitat to support well-distributed populations of native plant, invertebrate and 

vertebrate riparian-dependent species.

Native vegetation growth may change as a result of infestation, and the type and quality of litter fall, 

and quality of organic matter may decline, which can alter or degrade habitat for aquatic organisms. 

Removal of invasive plants and replacement with native plant communities would restore habitat for 

species dependent on riparian and aquatic habitats. The use aquatic glyphosate, aquatic imazapyr, 

and aminopyralid near wet streams may result in some minor non-target vegetation impacts at the 

site scale. However, the amount necessary to affect to affect habitat for populations of plants, 

invertebrates and vertebrates in riparian areas is not possible with spot-spray applications. 

3.8.4.2 Key Watersheds 

Invasive plant treatment is proposed to occur in many Tier 1 Key Watersheds on the MBS. Key 

watersheds were designated under the Northwest Forest Plan to highlight areas that are necessary refugia 

for at risk fish species. 

3.8.4.3 ESA Listed Fish and Habitat

Due to the minor ground disturbance and potential to disturb an individual fish, all alternatives “may 

affect” federally listed fish species (or those proposed for listing) or their designated critical habitat.30 

The following section summarizes analysis relevant to this ESA finding. 

Primary Constituent Elements (PCE) were analyzed for critical freshwater habitats include spawning 

sites, rearing sites, and migration corridors. In 1996, NMFS developed a methodology for making ESA 

determinations for individual or grouped activities at the watershed scale, termed the “Habitat Approach”.

A Matrix of Pathways and Indicators (MPI) was also recommended under the Habitat Approach to assist 

with analyzing effects to listed species.

30 Results of the biological assessment indicates that invasive Plant Treatment on the Mt. Baker Snoqualmie 

National Forest may affect and is likely to adversely affect bull trout, Puget Sound Chinook salmon, Puget Sound 

steelhead and their designated or proposed critical habitat. The draft EIS erroneously indicated that the ESA 

determination was “not likely to adversely affect” for some listed species. 

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When using the MPI, project effects to the “Pathways and Indicators” (numeric ratings or narrative 

descriptors for each Pathway) are used to determine whether proposed actions would damage habitat or 

retard the progress of habitat recovering towards properly functioning condition. The Habitat Approach’s 

MPI has numerous habitat-associated Indicators that closely “cross-walk” with the PCE’s associated with 

designated critical habitat (Sept. 2002 designation letter). Table 58 displays the PCE – MPI Crosswalk. 

Table 58. Crosswalk of PCE elements and MPI indicators

Primary Constituent Elements Matrix of Pathways and Indicators

Spawning Habitat, as defined by water 

quality, water quantity, substrate

Water Quality: Temperature, Suspended Sediment, Substrate, Chemical 

Contaminants and Nutrients

Flow/Hydrology: Change in Peak/Base flows

Habitat Elements: Substrate/Embeddedness

Rearing as defined by adequate water 

quantity and floodplain connectivity

Channel Conditions and Dynamics: Floodplain connectivity

Flow/Hydrology: Change in Peak/Base flow

Rearing as defined by adequate water 

quality and forage

Water Quality: Temperature, Substrate

Habitat Elements: Large Woody Debris, Pool Frequency and Quality, Offchannel Habitat

Rearing as defined by adequate natural 

cover

Habitat Elements: Large Woody Debris, Pool Frequency and Quality, 

Large Pools, Off-channel Habitat

Migration as defined by habitat free of 

artificial obstructions, and adequate 

water quality, water quantity, and natural 

cover

Habitat Access: Physical Barriers

Water Quality: Temperature

Flow/Hydrology: Change in Peak/Base flow

Habitat Elements: Large Woody Debris, Pool Frequency and Quality, 

Large Pools

All of these aquatic ecosystem components were evaluated in detail in the BA. The results of the detailed 

analysis indicate that there would be no detectable changes to temperature, floodplain connectivity, 

stream flow, pool frequency and quality, wood routing, or substrate from the treatments proposed.

Invasive plant treatments may result in minor ground disturbance and localized sedimentation (see 

Chapter 3.4), but the amount of sediment is expected to be negligible and within the range of natural 

variability. Herbicide treatments may result in herbicide drift, run-off or leaching to streams, but the 

potential amount is very low given the MR/MM and buffers. The MR/MM and buffers minimize the risk 

of herbicide delivery to streams and limit the extent, intensity and frequency of treatment to reduce the 

likelihood of adverse effects actually occurring.

Invasive plants have some negative impacts on these aquatic ecosystem components (see discussion under 

Affected Environment). However, invasive plant treatments would have many beneficial effects on 

critical habitat for federally listed fish species by increasing native vegetation growth, cover and food.

Invasive plant treatments conducted in riparian areas would help restore or maintain the native riparian 

vegetation that is essential in maintaining the PCE of critical habitat in the long-term.

Consultation has been completed with the NMFS for Puget Sound chinook and steelhead and is underway 

with the USFWS for bull trout. A decision for this project will not be signed until consultation has been 

completed. 

3.8.4.4 Effects on Essential Fish Habitat

The Magnuson-Stevens defines adverse effects as any impact, which reduces the quality and/or quantity 

of Essential Fish Habitat (EFH). Non-herbicide and herbicide treatment methods would not impact those 

waters necessary for spawning, breeding, feeding, or growth to maturity because there is no treatment of 

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submerged invasive plants and the predicted amount of herbicide coming in contact with water is 

expected to be below levels of concern or non-detectable. The quantity of EFH would not be reduced and 

the quality of EFH would be maintained by all alternatives.

3.8.4.5 Effects on Sensitive Fish Species

Coho salmon. Some herbicide treatments could occur alongside channels or ponds while juvenile coho 

are rearing. However, there is low potential for herbicide exposure above a level of concern to coho. Nonlethal effects to juvenile fish from low-level exposure is not well understood. 

Coastal cutthroat trout. Herbicides would not be applied during peak spawning periods because these 

occur in winter and invasive plant treatments do not occur this time of year. Some disturbance and loss of 

individual non-target plants could occur in smaller streams. The extent of treatment along stream margins 

containing coastal cutthroat trout would be small compared to the available habitat for this species.

3.8.4.6 Effects on Management Indicator Species Fishes

The MBS Forest Plan identifies a number of fish species as Management Indicator Species (MIS) for 

healthy stream/riparian habitats. These include the coastal cutthroat trout, rainbow trout, bull trout, 

steelhead, Chinook, coho, sockeye, chum and pink salmon (USDA Forest Service 1990). 

Riparian ecosystems occur at the margins of standing and flowing water, including intermittent stream 

channels, ephemeral ponds, and wetlands. The aquatic MIS were selected to indicate healthy stream and 

riparian ecosystems across the landscape. Attributes of a healthy aquatic ecosystem includes: cold and 

clean water; clean channel substrates; stable stream banks; healthy streamside vegetation; complex 

channel habitat created by large wood, cobles, boulders, streamside vegetation, and undercut banks; deep 

pools; and waterways free of barriers. Healthy riparian areas maintain adequate temperature regulation, 

nutrient cycles, natural erosion rates, and provide for in stream wood recruitment. 

Habitat for each MIS species exists within the analysis area. Table 60 describes the MIS, the habitat they 

represent, and whether they are present in the project analysis area.

Table 59. Miles of documented presence on the MBS by management indicator fish species

Management Indicator Fish Species Miles of Documented Presence on the MBS1

Chinook salmon (Oncorhynchus tshawytscha) 106

Bull trout (Salvelinus confluentus) 560

Steelhead (Oncorhynchus mykiss) 379

Coho salmon (Oncorhynchus kisutch) 524

Pink salmon (Oncorhynchus gorbuscha) 220

Chum salmon (Oncorhynchus keta) 121

Sockeye salmon (Oncorhynchus nerka) 158

Coastal cutthroat trout (Oncorhynchus clarkii) 763

Rainbow trout (Oncorhynchus mykiss) 503

1 WDFW 2002; does not include miles on National Forest System land with “suspected” occupancy, or on other land ownerships.

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Table 60. MIS and habitat description for the analysis area

Management Indicator 

Fish Species Habitat Description Habitat Present in 

Analysis Area

Species Present in 

Analysis Area

Coastal cutthroat trout Streams/riparian habitats Yes Yes

Rainbow trout Yes Yes

Steelhead Yes Yes

Chinook salmon Yes Yes

Coho salmon Yes Yes

Sockeye salmon Yes Yes

Chum salmon Yes Yes

Pink salmon Yes Yes

Bull trout Yes Yes

Source: WDFW (2002). 

In general, all of the aquatic MIS selected for the MBS have similar stream and riparian ecosystem 

requirements. However, they do represent a range of minor differences in habitat conditions found and 

utilized across the forest. As an example, bull trout require slightly colder water when compared to 

rainbow trout. Because the habitat requirements for each species are generally similar and often overlap, 

they were collectively chosen to represent healthy stream and riparian ecosystems. 

Applications of aquatic glyphosate aminopyralid (Alternative 2 only), clopyralid, imazapic, aquatic 

imazapyr and metsulfuron methyl may be applied within ditches and dry intermittent channels. Based on 

the information presented above, it is reasonable to assume that aquatic organisms may be briefly exposed 

to higher levels of glyphosate or other herbicide compounds if an unexpected rainfall event occurs shortly 

after an application. To be exposed, individuals would need to be near the confluence where a ditch or 

intermittent stream channel is located when the “first flush” event occurred.

Even under the unlikely event that MIS fishes were exposed under the above scenario, effects would be 

limited to individuals. Mitigation measures that limit the extent of treatment within any given 6th field 

sub-watershed would ensure that large scale effects that could influence MIS fish at the population level 

could not occur.

3.9 Recreation, Wilderness and Wild & Scenic Rivers 

3.9.1 Introduction

The analysis area for direct, indirect, and cumulative effects on the recreation, wilderness and Wild & 

Scenic River System resources is the current observed invasive plant sites along with expected spread 

within road corridors, recreation sites, administrative sites, wilderness areas, and portions of river 

passages, including the Skagit Wild and Scenic River System. 

The project duration is 10 years or longer with the potential for repeated treatments (manual, mechanical 

or chemical) in sequential years or the same year on the same ground. There is the potential, under the 

proposed action that a given site would be impacted for at least 10 years and whatever recovery time 

necessary after that to mitigate the effects of soil disturbance or persistence of various chemical 

herbicides. The proposed action also provides for additional treatment of new infestations. 

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Recreation, Wilderness and Wild and Scenic River System analysis focuses primarily on the recreational 

environment and visitors. The herbicides proposed for use have a very low potential to cause human 

health issues at the concentrations and amounts which are proposed (see Chapter 3.3). The relatively 

small number of scoping responses for this project may indicate that people are not opposed to use of 

herbicides for invasive plant treatment on the MBS. Many people use various “weed killers” on their own 

properties at levels and frequencies much higher than is being proposed here. Nonetheless, some people 

have expressed concern about herbicide exposure and do not support herbicide use on the MBS. 

Notification would be tiered based on the possibility of exposure to the public from the use of herbicides. 

For example, virtually the entire length of the Skagit River system is lined by invasive species of one type 

or another. However, public use of the shoreline is relatively low and dispersed. Some users float the river 

in boats so their exposure is limited to put-ins and take-outs. In contrast, people may live at their 

recreation residence for much of the year. Since all of the recreation residences are under permit, the 

owners can be easily contacted and informed of the timing and effects of a treatment. On the other hand, 

the angler who is passing through a riverside knotweed plant patch in a general forest area would be very 

difficult to contact ahead of time, other than posting notices on the internet, or near the treatment site. 

With this in mind, notification would be provided as indicated in the Management Requirements and 

Mitigation Measures table. 

3.9.2 Affected Environment

3.9.2.1 Wilderness Areas

The MBS is home to nine wilderness areas covering about 830,000 acres. Approximately 48 percent of 

the Forest is within designated wilderness. The MBS shares administration of the Norse Peak, Alpine 

Lakes, Henry M. Jackson, and Glacier Peak Wildernesses with the Okanogan and Wenatchee National 

Forests. While large portions of these areas are relatively free of invasive plants, the trail systems and old 

roads and logging area landings within wilderness are likely to have invasive plants. Invasive plants have 

the potential to cause adverse impacts to wilderness character by disrupting the natural processes and 

untrammeled nature for which these areas were designated. Volunteers are helping the Forest Service 

inventory invasive plants throughout Mt. Baker-Snoqualmie wilderness areas.

Six infested sites are located in wilderness areas, within two Treatment Analysis Areas (TAA). One site is 

in the Glacier Peak Wilderness and five are in Wild Sky Wilderness. 

TAA #19 has three sites within the Wild Sky Wilderness. The sites are along a segment of the North Fork 

Skykomish Road 63 which is now part of the North Fork Skykomish Trail # 1051. 

TAA #53 extends along the Suiattle Trail into the Glacier Peak Wilderness Area. A known site occurs 

within the Wilderness boundary at an old trailhead that has been highly disturbed by stock use, beyond the 

junction with the Milk Creek trail. 

Four other TAAs extend into Wilderness Areas, but do not have any mapped sites at this time. 

TAA #16 includes about 1 mile of Road # 6510-210 that extends about 1 mile into the Wild Sky 

Wilderness .

TAA #17 includes 0.75 mile of the end of road 6546 that is in Wild Sky Wilderness. 

TAA #18 includes about 1 mile of the end of road 6530 that is in Wild Sky Wilderness. Recently, 

oxeye daisy, birdsfoot trefoil, and foxglove were recently identified on the disturbed roadside. 

These infestations are not included in the infested acreage within Treatment Analysis Areas (Table 

18).

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TAA #54 includes the Johnson Ridge Trail # 1067 and spur to Joan Lake#1067.1. No invasive 

plant sites are mapped along these trails (which are in the Wild Sky and Henry Jackson Wilderness 

Areas). However, Scotch broom, St. Johnswort, common tansy and birdsfoot trefoil were recently 

identified along the first half-mile of the trail. These invasive species have the potential to spread 

further along onto the Johnson Ridge trail and into the Wild Sky Wilderness on NFS Trail # 1067. 

These infestations are not included in the infested acreage within Treatment Analysis Areas (Table 

18).

The designation of Wild Sky Wilderness in 2008 included within its borders approximately 34 miles of 

system roads, some that were drivable in a passenger vehicle. Additional roads and railroad grades that 

had previously been removed from the road system cover many more miles. Most of the old roads within 

the Wild Sky Wilderness have not been surveyed for invasive plants. About 10 logging landings have 

been identified within the area now designated as wilderness which could potentially contain more 

invasive plant sites. Within the Mt. Baker Wilderness, 1.2 miles of the Lone Jack Mine road have also not 

been surveyed. 

3.9.2.2 Skagit Wild and Scenic River System

The only designated Wild and Scenic River system designated on the Forest is the Skagit. The Skagit 

system includes portions of the Skagit, Cascade, Sauk and Suiattle Rivers and covers approximately 150 

river miles. Most of the other major river systems on the Forest have been determined to be eligible for 

inclusion in the Wild and Scenic River System in the Forest Plan. At present, legislation is pending in 

Congress that would add both the Illabot and Pratt Rivers to the system. 

The location of roads along nearly the entire river corridor has allowed for numerous invasive plants to 

become established. Approximately 93 infested sites (1,433 acres) have been mapped within the Skagit 

Wild and Scenic River System. The overriding resource value being managed for all of the river segments 

is scenery. A River Management Plan was developed for the Skagit River and incorporated into the Forest 

Plan. The Plan does not speak directly to non-native vegetation. However, since preservation of the 

scenery and natural character of the river is paramount, it is assumed that protection of the native plant 

species is desirable. 

3.9.2.3 Recreation Areas

Municipal watersheds, dispersed and developed recreation areas (trailheads, campgrounds, picnic areas, 

boat ramps, ski areas, public service centers, recreation residences, etc.) and special forest product 

collection areas currently occur in the vicinity of invasive plant sites. Infested sites are scattered and 

occupy about one-third of 1 percent of the MBS. The number of infested sites and acreage within various 

types of recreation areas is shown in Table 61. 

Table 61. Infested acreage and numbers of sites within Recreation Areas

Site Type Number of sites (all species) Infested Acres

Administrative Site 31 70.5

Recreation Residence 9 0.3

Campground 24 44.8

Picnic Area 8 122.9

Viewpoint 6 97.2

Lake Shore 14 1.3

Boat Launch 1 0.2

Trailheads 12 7.8

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Site Type Number of sites (all species) Infested Acres

Trails - Wilderness 6 4 

Wild and Scenic River 93 1,433

Total 205 1,896 

Note: Co-located invasive species are tallied separately.

Forest Product Gathering

All kinds of people gather special forest products such as blackberries, huckleberries, salal, mushrooms, 

ferns bear grass and herbs for personal use and commercial sale. Some of these products are invasive 

species, such as blackberries and St. Johnswort, but most are not. 

Trails

The Forest Trail system comprises a total of about 1,600 miles. Less than half is open to use by stock 

animals and the majority of the stock accessible trails are located with wilderness. About 10 percent is 

open to motorized use and this is largely confined to the Evans Creek area at the extreme southern edge of 

the Forest. Much of the maintained portion of the trail system receives very heavy use by hikers that 

extends throughout the year on some trails that have low elevation access. Stock users comprise fewer 

than 5 percent of the total trail users. Trail maintenance along with invasive plant treatments would reduce 

source populations and therefore the spread and amount of resources expended in containing invasive 

species expansion.

Use of the trail system has been increasing with the growing population in the Puget Sound area. Most of 

the increase has been in day hiking, though interest and demand for mountain biking is rising. Near the 

major paved highway corridors there are also expanding networks of user, or boot built, trails developing 

that access mountain peaks, lakes and viewpoints. The relationship between OHV, trail use, travel 

management, and the introduction, establishment and spread of invasive plants was discussed in the R6 

2005 FEIS (Chapter 3.1.3, Mechanisms of Invasion), and recognized that OHV use can influence the 

spread of invasive plants by disturbing soil and carrying seed several orders of magnitude greater than 

‘conventional’ dispersal methods (R6 2005 FEIS p. 3-15). Available resources for maintenance, storm 

damage, and other factors limit annual maintenance to about half of the total system. Recent field visits 

by a botanist revealed unmapped invasive plants along some wilderness trails.

Motorized Access

Heavy vegetation and steep terrain throughout the Forest effectively constrains motorized use to the 

existing road system, a handful of trails, and an even smaller group of cross country areas. Forest Orders 

have been in place for many years that prohibit use of OHV’s to a limited trail system. The Motor Vehicle 

Use Map (MVUM) designated roads and trails that are open to motorized use. No motorized use is 

allowed outside these areas. The MVUM also prohibits use of motor vehicles beyond 150 feet from the 

centerline of Forest Roads. 

The road system on the Forest has been shrinking since its peak in the late 1980s. This is due, largely, to 

the scaling back of the timber program and reduced funding for road maintenance. Growth of native 

vegetation over Maintenance Level 1 roads has reduced access along several hundred miles of those 

roads. Damage from major storms have also reduced access to large portions of several major drainages 

including the Suiattle, White Chuck, Canyon Creek (Stilly), North Fork Skykomish, and West Fork White 

Rivers. While some access has been restored, and more will be, these road networks will not be restored 

to their previous extents. Currently, the Forest road system includes about 2,600 miles. About 800 miles 

have been closed or are in storage. Funding is available to maintain about 33 percent of the open-road 

system. 

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3.9.3 Environmental Consequences

3.9.3.1 Direct and Indirect Effects of Alternative 1 – No Action

Effects on Wilderness and Skagit Wild and Scenic River

No herbicide treatment would occur in the wilderness under Alternative 1. Some manual treatment may 

occur. Invasive plants would likely continue 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. Of the three alternatives, No Action has the greatest potential to affect wilderness 

values because wilderness would not be treated effectively. 

No Action may also not be sufficient to fully maintain the native species in the Wild and Scenic River 

System. 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. 

Recreation and Scenic Resources

Invasive plant treatments that are currently approved may affect scenic resources. Visitors may note 

temporary impacts to scenery if large numbers of target plants are treated at once and are seen in the 

dying or dead phase. By the following growing season, no evidence would remain when the residual live, 

green, native vegetation once again dominates the view. No adverse effects on recreation users or 

recreation/scenic resources have been reported from invasive plant treatments that have been 

implemented since 2005. Recreation users do not appear to have been displaced by treatments, and the 

treatments have not led to visual impacts in the form of large areas of dead plants or de-vegetated zones 

along visually sensitive road corridors. Forest product gatherers have not reported negative effects of 

current treatments. Human health would not be adversely affected by herbicide use under No Action (see 

Chapter 3.3). 

With No Action, invasive plants would not be effectively treated in some recreation areas. Potential 

effects on scenic views could result from invasive plant spread shifting the landscape character to a more 

homogeneous species composition. This impact on species composition within particular areas and in the 

forest understory could be inconsistent with the valued landscape character in places where invasive 

plants are not effectively treated. The No-Action Alternative has not effectively kept up with invasive 

plant spread, reducing habitat quality for native plants (see Chapter 3.3), wildlife (Chapter 3.5) and fish 

(Chapter 3.8). 

The holders of special use permits for recreation residences on the Forest are familiar with the problem of 

invasive plants like English ivy and knotweed and have been actively engaged in efforts to control the 

plants around their cabins. 

3.9.3.2 Direct and Indirect Effects of Alternatives 2 and 3

Effects on Wilderness Areas and Skagit Wild and Scenic River

Effects to wilderness areas and the Skagit Wild and Scenic River are similar between Alternatives 2 and 3. 

The Forest Plan Amendment to add aminopyralid in Alternative 2 would increase treatment costeffectiveness and minimize adverse effects to fish and wildlife compared to Alternative 3, however at the 

project scale, this would be unlikely to result in substantial differences in effects to wilderness or the 

Skagit Wild and Scenic River area. 

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Spot and selective herbicide applications, along with manual treatments such as hand pulling, would 

occur as needed in wilderness areas in Alternatives 2 and 3. These treatment methods would affect 

wilderness character, both enhancing and potentially distracting from the untrammeled nature desired 

within wilderness. Wilderness visitors may notice vegetation that has been browned by treatment, yet for 

many it may not be obvious. A visitor’s sense of solitude may be affected if they encounter an invasive 

plant worker pulling or spraying invasive plants. These encounters would be brief, and no mechanized 

treatment methods would be approved for wilderness application. 

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. Both action alternatives would more 

effectively treat invasive plants in wilderness and wild and scenic river areas than No Action. The use of 

aminopyralid in Alternative 2 would increase the effectiveness of treatment for many target species, 

especially near streams (Chapter 3.3). 

Invasive plant treatments could also affect scenery within the Skagit Wild and Scenic River system, 

especially if the entire area is treated at one time. However, these effects would be temporary and by the 

following growing season, native vegetation would recover. 

Use of more selective herbicides (e.g., aminopyralid in Alternative 2, chlorsulfuron in both action 

alternatives) could reduce the potential damage to common non-target plants growing with the invasive

plants compared to No Action. Effects to outstandingly remarkable values would be minimal given the 

MR/MM and herbicide use buffers (Chapters 3.4, 3.5, 3.7 and 3.8). In the long run, treatment of invasive 

plant and restoration of treated areas would enhance wilderness and Wild and Scenic River values. 

Alternative 2 would be more favorable to Wild and Scenic River values because of the increased

effectiveness and selectivity associated with use of aminopyralid.

Effects on Recreation and Scenic Resources

Both action alternatives would maintain or improve recreation and scenic resources. Compared to No 

Action, more effective treatment would better maintain scenic values by supporting a diverse visual 

mosaic of native grasses, forbs, and shrubs consistent with the ecological setting. The additional herbicide 

choices in both action alternatives would leave more of the native vegetation intact than would be likely 

with non-selective herbicides such as glyphosate (Chapter 3.4). Existing visual quality objectives would 

be met and changes to the scenic integrity and stability would be minimized. Dead vegetation that would 

be visible for at least one growing season and could result in short-term negative effects to the scenery. 

The unnatural appearance of mowed and brushed areas seen from immediate foreground distances (300 

feet) would also be a short-term negative effect. Some treatment areas stretch for miles along the sides of 

roads. However, in the long run, compared to No Action, more effective restoration of native vegetation 

would better maintain or increase scenic integrity. 

Herbicide and manual treatments of invasive plants would continue in campground and recreation 

residence tracts. The Forest would utilize a notification process so people know in advance what plants 

are to be treated, so that people can avoid areas that have been sprayed. A potential negative effect 

anticipated is if some forest visitors feel they must go elsewhere to avoid herbicides that have been 

applied to invasive plants in their favorite recreation spot. 

No adverse effects to the recreating public are anticipated from changes to the herbicide use proposed in 

the action alternatives. The use of triclopyr in both action alternatives poses minor risk to forest product 

gatherers or other Forest visitors, however, the MR/MM reduce the potential for these effects to actually 

occur (Chapter 3.3). 

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3.9.3.3 Cumulative Effects of All Alternatives

The cumulative effects are the same in all alternatives. Recreation use on the Forest is projected to 

increase, which both creates more potential for spreading of invasive plants and potential for impacts to 

recreation users from invasive plant treatment. 

The use of herbicides off National Forest could result in multiple or additive doses of the same or 

different herbicides to the recreating public. Forest visitors or workers could conceivably be exposed to 

herbicides in more than one place on the Forest, or elsewhere. However, the herbicides proposed for use 

do not bioaccumulate in humans and are rapidly eliminated from the body, thus cumulative effects to the 

public are not likely (Chapter 3.3 - Human Health). Use of herbicides off national forest would not 

contribute to adverse cumulative effects on recreation or scenic resources within the Forest. 

The list of recently completed, current or ongoing, and foreseeable future projects on the Forest was 

reviewed. While many projects overlap with dispersed recreation sites, the effects are unlikely to combine 

with this project and cause a cumulative effect. None of these recently completed, currently being 

implemented, ongoing or foreseeable future projects on the MBS involve the use of herbicide, thus they 

would not contribute to cumulative herbicide exposure or herbicide effects on recreation or scenic 

resources. 

Effective invasive plant treatment would reduce invasive species source populations and assist in 

maintaining desired resource values on the Forest. This beneficial impact could combine with other 

beneficial activities on recreation and scenic resources. 

Wilderness and Wild and Scenic River Values

About 830,000 acres (48 percent) of the MBS are designated as wilderness. About 600 miles of trail 

traverse these areas, of which about 340 miles are currently open to stock animals. Due to storm damage, 

reductions in wilderness trail maintenance and less use by stock animals, the system available to stock 

animals is near an historic low. Introduction of invasive plants to wilderness areas may have preceded 

their designation as wilderness and occurred during a time when use of the Forest by stock animals, 

including grazing allotments, was far greater than at present. As many of the best grazing areas were near 

the Cascade Crest, trails which accessed those allotments passed through most of the Forest to reach 

them. Some invasive plants were likely introduced in this manner.

In recent decades elimination of commercial grazing allotments, reduced use of pack stock on trails along 

with benign neglect, has likely reduced the quantity of seeds being transported into the wilderness and 

backcountry areas of the Forest. While wilderness management activities would continue, the likelihood 

of invasive plants spreading further from management activities with the proposed control mechanisms is 

not expected. 

No cumulative effects to wild and scenic river values are anticipated. All projects proposed in wild and 

scenic rivers would be designed to maintain the outstandingly remarkable values for which the river has 

been designated. 

Habitat restoration could overlap with invasive plant treatments in wilderness in rapid response actions 

that would be relatively small site specific projects less than 1 acre in size (campsite restoration or trail 

reconfiguration). Habitat restoration would overlap with invasive treatments on the Skagit Wild and 

Scenic River at boat launches or other sites with invasive weeds. No negative cumulative impacts on 

wilderness, recreation or Wild and Scenic River values can be discerned when impacts from this project 

are combined with impacts of habitat restoration. Reduced invasive populations on trails would assist in 

maintaining wilderness character and Wild and Scenic River values.

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Roads and Trails

Forest Service projections suggest increased Forest recreation use of open roads and trails, both motorized 

and non-motorized which would continue to be conduits for the distribution of invasive plants. It is likely 

that a somewhat reduced system of roads and trails will minimize that portion of the Forest where 

invasive plants could be introduced, along with management actions such as the Regional requirement 

that any fee for stock animals be certified weed-free on all national forests in the Pacific Northwest 

Region. Future foreseeable actions include site-specific trail improvement projects. This work would 

primarily be trail restoration, bridge replacement and intensive maintenance work. Currently, an average 

of two new major trail bridges may be built each year along with 2 miles of relocated trails. While trail 

maintenance would continue to provide distribution avenues for invasive species, the proposed treatments 

would reduce current source populations of known invasive species, and limit the future spread and 

amount of resources expended in containing invasive species expansion. 

While designated routes open to motorized use and dispersed camping would continue, the likelihood of 

invasive plants spreading further from these sites with the proposed control mechanisms is not expected

(Chapter 3.3 - Botany). Cumulatively, open roads and road maintenance operations would continue to 

provide a conduit for invasive species introduction, with invasive plant treatments reducing the current 

source populations and therefore the spread of invasive species. This would allow for fewer resources 

needed for treatment in the future. 

Administrative and Recreation Sites 

Administrative and recreation site management projects would overlap with the Invasive Plant project.

The cumulative effects analysis area contains all administrative, developed and dispersed recreation sites 

on the Forest. No negative cumulative impacts on users or environmental values can be discerned when 

impacts from this project are combined with impacts of site management. Coordination between invasive 

plant treatments and administrative and recreation site management would occur to reduce the potential 

adverse effects to Forest visitors. 

Consistency with Regulations, Policies and Plans

This project is consistent with regulations, policies and plans associated with recreation management. 

3.10 Heritage Resources 

3.10.1Introduction

Many laws, policies, regulations and agreements provide specific management direction for protection of 

prehistoric and historic resources and tribal treaty rights. 

The Antiquities Act of 1906. The Antiquities Act (P.L. 59-209, 16 U.S.C. 431-433) authorizes a permit 

system for investigation of archaeological sites on federal lands and allows the President to establish 

national monuments on federal lands in order to protect them. 

Historic Sites Act of 1935 (16 USC 461). The Historic Sites Act declares national policy to preserve for 

public use historic sites, buildings, and objects of national significance for the inspiration and benefit of 

the people of the United States. 

The National Historic Preservation Act of 1966, as amended in 1992 (NHPA). The NHPA (P.L. 102-

575; 16 U.S.C. 470) extends the policy of the Historic Sites Act to state and local historic sites as well as 

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those of national significance. It established the federal government’s policy and programs on historic 

preservation, including the National Register of Historic Places (NRHP).

The Archaeological Resources Protection Act of 1969 (ARPA). The ARPA prohibits disturbance or 

removal of archaeological resources from federal lands without a permit from the responsible land 

manager. ARPA applies to both NRHP-eligible and non-eligible sites that are at least 100 years old.

The American Indian Religious Freedom Act of 1978 (AIRFA). The AIRFA protects the rights of 

American Indian people to believe, express, and exercise their traditional religions. AIRFA allows access 

to sites, use and possession of sacred objects, and freedom of worship through traditional ceremonies and 

practices. It also requires a review, in consultation with American Indian leaders, of federal agency 

policies and programs to determine changes necessary to protect and preserve religious and cultural 

practices of American Indians.

The Native American Graves Protection and Repatriation Act of 1990 (NAGPRA). The NAGPRA 

establishes the rights of lineal descendants and members of Indian tribes to certain human remains and 

precisely defined cultural items recovered from federal or Indian lands. NAGPRA also establishes 

procedures and consultation requirements for intentional excavation or accidental discovery of American 

Indian remains or cultural items on federal or tribal lands. 

Native American Graves Protection and Repatriation Regulations (43 CFR 10 Subpart B Human 

Remains, Funerary Objects, Sacred Objects, or Objects of Cultural Patrimony from Federal or 

Tribal Lands). These regulations carry out provisions of the NAGPRA of 1990. The regulations pertain 

to the identification and appropriate disposition of human remains, funerary objects and objects of 

cultural patrimony, and pertain whether they are inadvertently discovered or excavated intentionally under 

a federal permit (Antiquities Act or ARPA). 

Executive Order 11593. The order directs federal agencies to inventory cultural resources under their 

jurisdiction, nominate all federally owned properties that meet the criteria of the NRHP, use due caution 

until the inventory and nomination processes are completed, and assure that federal plans and programs 

contribute to preservation and enhancement of non-federally owned properties. 

Executive Order 13007. This order directs executive branch agencies to accommodate access to and 

ceremonial use of American Indian sacred sites by Indian religious practitioners and to avoid adversely 

affecting the physical integrity of such sacred sites on federal lands to the extent practicable, permitted by 

law, and not clearly inconsistent with essential agency functions. The agencies are further directed to 

ensure that reasonable notice is provided of proposed land actions or policies that may restrict future 

access to or ceremonial use of, or adversely affect the physical integrity of sacred sites.

Executive Order 13175. Consultation and coordination with Indian tribal governments – requires federal 

agencies such as the USDA Forest Service to develop an accountable process to ensure the meaningful 

and timely input by tribal officials in the development of regulatory policies that have substantial direct 

effects on one or more Indian tribes, on the relationship between the federal government and the Indian 

tribes, or on the distribution of power and responsibilities between the federal government and Indian 

tribes.

Executive Order 13287 – Preserve America. Issued in March of 2003, Executive Order 13287 

established federal policy to provide leadership in preserving America’s heritage by actively advancing 

the protection, enhancement and contemporary use of the historic properties owned by the federal 

government. The order encourages agencies to seek partnerships to make more efficient and informed use 

of historic properties for economic and other recognized public benefits. 

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Protection of Historic Properties 36 CFR 800. These regulations implement the NHPA Section 106 and 

define how federal agencies take into account the effects of their undertakings on historic properties. The 

regulations identify consulting parties, and identify the goal of consultation: to identify historic properties 

potentially affected by the undertaking, assess its effects, and seek ways to avoid, minimize or mitigate 

any adverse effects on historic properties (36 CFR 800.1). 

National Register of Historic Places (36 CFR 60). These regulations establish the National Register of 

Historic Places as a planning tool to help federal agencies evaluate cultural resources in consultation with 

the State Historic Preservation Officer and the Advisory Council on Historic Preservation. 36 CFR 60.4 

provides the criteria for determining whether cultural resources are eligible for listing on the NRHP. 

Protection of Archaeological Resources Uniform Regulations (36 CFR 296). These regulations 

implement the ARPA by establishing uniform definitions, standards and procedures for federal land 

managers to follow in providing protection for archaeological resources located on public lands. The 

regulations define prohibited acts, and requirements for issuing permits under the authority of the ARPA. 

U.S. Forest Service's Native American Policies. The Forest Service's Native American polices are 

described in Forest Service Manual 1563 and Forest Service Publication FS-446 and FS-600. The Forest 

Service’s Native American policies include maintaining a governmental relationship with federallyrecognized tribal governments, implementing programs and activities in a way that honors Indian treaty 

rights and fulfills legally-mandated trust responsibilities to the extent that they apply to National Forest 

system lands (NFSL), administering programs and activities to address and be sensitive to traditional 

native religious beliefs and practices, and providing research, transfer of technology, and technical 

assistance to tribal governments. 

The Federal Trust Responsibility. The trust responsibility is the U.S. government’s permanent legal 

obligation to exercise statutory and other legal authorities to protect tribal land, assets, resources, and 

treaty rights, as well as a duty to carry out the mandates of federal law with respect to American Indian 

and Alaska Native tribes (USDA Forest Service Publication FS-600). The Forest Service must carry out 

this responsibility to tribes while at the same time carrying out the intent of other federal laws, which the 

Forest Service has a similar duty to follow.

Treaties. The Point Elliott and Medicine Creek Treaties were negotiated by Territorial Governor Isaac 

Stevens with various western Washington native people in 1854-55. Lands administered by the MBS were 

ceded to the United States under these treaties. Courts have recognized certain rights as being “reserved” 

by tribes. Indian reserved rights continue to be exercised by tribes and their members today under tribal 

regulation and remain enforceable under the supremacy clause of the Constitution until extinguished by 

express congressional action. The Treaties of Point Elliott and Medicine Creek contain identical language 

describing off-reservation treaty-reserved rights:

The right of taking fish at usual and accustomed grounds and stations is further secured 

to said Indians in common with all citizens of the territory, and of erecting temporary 

houses for the purpose of curing, together with the privilege of hunting and gathering 

roots and berries on open and unclaimed lands. Provided, however, that they shall not 

take shellfish from any beds staked or cultivated by citizens.

Yakama Treaty: The Mt. Baker-Snoqualmie administers some lands in Kittitas County (e.g. the Gold 

Creek Pond area) ceded to the United States under the Yakama Treaty. The Yakama Indian Nation 

reserved certain rights, similar to the rights reserved in the Treaties of Point Elliott and Medicine Creek, 

with the addition of the right of “pasturing their horses and cattle upon open and unclaimed land.” In 

addition, the Yakama Indian Nation’s usual and accustomed fishing places have been adjudicated by the 

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Court in United States v Washington, and include lands between the Skykomish River Basin and Mt. 

Rainer National Park that are administered by the MBS (USDI BIA 1978). 

The Programmatic Agreement regarding cultural resource management on National Forests in the State of 

Washington was negotiated between USDA Forest Service Region 6, the Washington State Historic 

Preservation Officer (SHPO), and the Advisory Council on Historic Preservation (ACHP) (USDA Forest 

Service 1997). The Invasive Plant EIS project was reviewed under the terms of the Programmatic 

Agreement.

No field surveys were conducted for this analysis. This analysis addresses only invasive sites that were 

analyzed under this Invasive Plant EIS and treatment and restoration methods proposed as first year/first 

choice. If the treatment differs from the first year/first choice or the restoration differs from what is 

proposed and analyzed in the EIS, then the changes must be reviewed by a heritage specialist, and 

approved pursuant to the terms of the 1997 Programmatic Agreement (PA 1997). 

Application of herbicides qualifies for review under the Appendix A of the Programmatic Agreement and 

may proceed without further consideration or consultation with the State Historic Preservation Officer 

(SHPO) (USDA Forest Service 1997: Appendix A). 

Hand pulling of invasive plants also qualifies for review under Appendix A of the Programmatic 

Agreement, when the treatment site was in a plantation, road shoulder, or rock pit/stockpile location. At 

these locations, hand pulling may proceed without further consultation with the SHPO (USDA Forest 

Service 1997: Appendix A). 

3.10.2Affected Environment

This section describes the cultural setting, heritage resources, and reserved treaty rights as they relate to 

the project area. 

3.10.2.1 Cultural Setting 

Prehistoric Context

Evidence for human activity in inland western Washington starts approximately 10,000 to 12,000 years 

before present (B.P.), with no sites in Cascadia that are indisputably dated before about 13,000 B.P. 

(Ames & Maschner 1999:64). Due to highly acidic sediments, faunal remains, and bone and stone 

implements are not preserved, and sites from the riverine sector are characterized primarily by flaked 

stone artifacts (Nelson 1990). One proposed cultural sequence for the western Cascades is presented by 

Hollenbeck (1987:27-30), from which the following is drawn. 

From 12,000-5,000 before present (B.P.), generalized hunting and gathering occurred. Following the 

glacial retreat, the landscape became available to highly mobile hunters and gatherers. People lived in 

small groups, occupying low or mid-elevations of the major river valleys during the colder months. For 

the remainder of the year settlement is postulated to have consisted of a semi-nomadic foraging pattern. 

Small groups established temporary base camps where they processed food and manufactured tools. From 

these camps they moved into the uplands of the Cascades, hunting, gathering, and possibly fishing. 

From 5,000-2,500 B.P., development of specialized resource use was occurring. Differences between 

cultural development along the coast and the mountain regions become more pronounced as people adapt 

to varied resource availability and needs. An inland orientation develops in the Cascades, which is 

influenced by or related to cultural development in the Plateau region. Artifact styles similar to those of 

eastern Washington become more common, and this similarity continues through late prehistoric and 

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ethno-historic times. A more complex system of trade is apparent. Increased contact and exchange with 

people from across the mountains during this period has been suggested. 

From 2,500-250 B.P., specialized resource utilization occurred. By about 2,500 B.P., the climate became 

comparable to present conditions. Sites assigned to this period are considered to be representative of the 

fully developed subsistence activities of the ethnographic reports. In the Cascade foothills, these would 

include anadromous fishing of the major drainages, and land mammal hunting and plant gathering of most 

of the species used by the beginning of the ethno-historic period. 

250 B.P – Present, was the ethno-historic period. This period is characterized in the material 

archaeological record by the addition of objects of European and Euro-American manufacture. Many 

traditional tools were replaced by imported ones. Some tools were rendered unnecessary by the 

introduction of manufactured goods, while other tools exhibited a melding of native and imported 

materials.

Ethno-historic Context

The following section is modified from Hollenbeck (1987:111,191). 

At least eleven federally recognized Indian Tribes have occupied and regularly used the lands and 

resources which are now part of the Mt. Baker-Snoqualmie National Forest, including the Nooksack, 

Lummi, Samish, Swinomish, Upper Skagit, Sauk-Suiattle, Stillaguamish, Tulalip Tribes, Snoqualmie, 

Muckleshoot, and Puyallup. However, the lands of the Forest were not limited to the exclusive use of 

these tribes. This project also includes lands east of the Cascade crest that are part of the OkanoganWenatchee National Forest (administered by the Mt. Baker-Snoqualmie) that were utilized by the 

Yakama. Others, including residents of the inland Columbia Plateau, shared in the occupancy of these 

lands and the use of the resources. 

The Native Americans of this region took part in a seasonal round of settlement and subsistence patterns 

that included visits to Puget Sound, the upriver environments, the mountain slopes and across the 

Cascades to fulfill social and economic requirements. There were optimum times for the exploitation of 

resources, and these determined the seasonal activities. Spring, summer and fall were the busiest times, 

when many species of plants, animals, and fish were available in quantity. Where several resources were 

available during the same time of year, the most efficient use of the procurement excursions was made.

Hunting and gathering trips to the mountainous regions of the Cascades were often combined. Deer, elk, 

and goat hunting took place in the higher elevations in the fall. The gathering of huckleberries in the open 

areas of the mountain slopes and ridge tops was also a fall activity. Fish, the primary resource of western 

Washington tribes, were caught in the lakes, rivers and streams of the Forest. 

Tribal territory was viewed as the land and resources regularly used by a particular group. The social and 

kinship ties, strengthened by the high frequency of intermarriage between the tribes, served to open up 

wider territory, and thus a greater variety and quantity of resources, to those who maintained them. The 

resource exchange was an integral part of the social and economic system.

In March 2, 1853 the Washington Territory was separated from Oregon Territory by an act of Congress, 

and Isaac Stevens took office as Territorial Governor and ex-officio Superintendent of Indian Affairs. One 

of the first tasks assigned to the new Governor was to extinguish all Indian title to the land, through the 

negotiation of treaties with the various Indian bands (Hollenbeck 1987:107). This ultimately resulted in 

the Treaty of Point Elliott, The Medicine Creek Treaty, and The Yakama Treaty, which among other items, 

created tribal reservations, and ceded all other lands occupied by Indian tribes and bands to the United 

States Government. However, certain rights were reserved for signatories to the treaty. Reserved treaty 

rights are discussed below in the Reserved Treaty Rights section.

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Historic Context

The following section is modified from Hollenbeck (1987:317). 

The history of the land that became the MBS begins in the early 1800s. The first reported non-native to 

pass through the forest was fur trapper and explorer Alexander Ross, who crossed the mountains at 

Cascade Pass in 1814. With the founding of Fort Nisqually in 1833, the Hudson Bay Trading Company 

had increasing influence in the Puget Sound Region and inland river drainages. Fur hunters and trappers 

were likely the only non-native visitors to the Forest for many decades. By the mid-1800s, EuroAmerican settlement of the Puget Sound Region was increasing. 

Efforts to convert existing Indian and fur trapper trails into roads across the passes were launched (e.g. 

Naches Pass Wagon Road in 1850). In 1854, the President and the Secretary of War in Washington, D.C., 

authorized the railroad surveys. The earliest miners probably reached the area in the 1860s, eventually 

discovering and establishing 10 Mining Districts. By the late 1800’s, the Forest was increasingly explored

and settled by Euro-Americans. Mining and logging were the two main industries. 

In 1897 the Washington Forest Reserve was established in the North Cascade Mountains and managed 

under the Department of the Interior. In 1905 they were transferred to the Department of Agriculture, and 

by 1908 the Forest Reserve was divided into two forests; the Washington National Forest (the name was 

later changed to Mt. Baker) and the Snoqualmie National Forest. Following the Great Depression, the 

Civilian Conservation Corps was established, and they worked within the forest from 1934 to 1942 on 

creating improvements in the forest, including new roads and trails, campgrounds, fire lookouts and 

reforestation projects. In 1973, the Mt. Baker National Forest was merged with the Snoqualmie National 

Forest into the Mt. Baker-Snoqualmie National Forest. 

3.10.2.2 Cultural Resources Identified

GIS analysis revealed 104 heritage sites overlapping with 515 of the known invasive plant infestations. 

Thirty-three of these heritage sites were already determined not eligible for the National Register of 

Historic Places (NRHP). The remaining 71 invasive plant sites are within or near eligible or potentially 

eligible heritage sites. An additional 178 heritage sites are outside known infestations, but within 

Treatment Analysis Areas. Of these, 46 were already determined not eligible for the NRHP; the remaining 

132 sites are eligible or potentially eligible for the NRHP. 

Of the 71 heritage locations within infestations, 5 were identified as having some concern that one of the 

treatment types or restoration methods could potentially affect the resource. Of the 132 eligible or 

potentially eligible heritage locations outside of infestations, but within Treatment Analysis Areas, 80 

were identified as having some concern that one of the proposed treatment types or restoration methods 

could potentially affect the resource. 

The Forest’s GIS layer for Native American religious use, practices, localities, and resources (Blukis Onat 

and Hollenbeck 1981), was compared to the Treatment Analysis Areas. Nine Treatment Analysis Areas 

were found to contain spiritual bathing sites. 

3.10.2.3 Reserved Treaty Rights

The proposed project is located on lands ceded to the United States under the Treaty of Point Elliott, and 

the Medicine Creek Treaty. Treaty rights include rights specifically reserved in treaties signed by 

American Indian groups with the federal government as well as other rights not specifically taken away 

by treaty. They include, but are not limited to, the reserved rights to “fish at usual and accustomed 

grounds and stations” and “erecting temporary houses for the purpose of curing, together with the 

privilege of hunting and gathering roots and berries on open and unclaimed lands.” Although “open and 

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unclaimed lands” is not clearly defined, federal courts have ruled that certain federal public lands not set 

aside for uses incompatible these rights, such as National Forest System lands, are considered open and 

unclaimed for these purposes. Usual and accustomed grounds and stations have been adjudicated in court 

for federally recognized Indian tribes with reserved rights under these treaties, as well as the Yakama 

Treaty, on the Mt. Baker-Snoqualmie National Forest. 

These reserved rights reflect the subsistence, medicinal and spiritual aspects of the traditional lifestyle of 

Northwest Indian people. They are as important to Indian Tribes today as they were when their ancestors 

reserved these rights in the Treaties. In addition, resources such as cedar, fish, large game, and 

huckleberries, have ceremonial importance and are central to the identity of American Indian Tribes. 

3.10.3Environmental Consequences

The analysis area for direct and indirect effects on Heritage Resources is the infested areas within the 

Treatment Analysis Areas. The area of analysis for reserved treaty rights is defined by the locations of 

specific resources such as salmon, wildlife and plants, discussed in various resource reports for this 

project.

3.10.3.1 Direct and Indirect Effects 

Alternative 1- No Action

Under the No-Action Alternative , the MBS 2005 Decision Notice (MBS 2005 DN) would continue to 

guide invasive plant treatments and restoration within the project area. 

Direct and Indirect Effects to Heritage Resources. The analysis for the MBS 2005 DN determined that 

the proposed treatments in 91 specific treatment sites had little to no potential to affect historic properties 

because each specific treatment action is reviewed by the heritage specialist pursuant to the PA (USDA 

Programmatic Agreement 1997). In the future, if expanded to the proposed 952 infestation sites of the 

current undertaking as well as the other areas within the Treatment Analysis Units, effects to historic 

properties would continue to be reviewed by the Heritage Specialist under the terms of the PA. 

Direct and Indirect Effects to Reserved Treaty Rights. Treaty rights would remain unchanged under 

Alternative 1. The Forest sends an annual newsletter to Tribes to notify them of current treatment plans 

and new treatment locations. Since this process was implemented in 2005, the Forest has not received any 

objections or concerns from Tribes. Removal of invasive plant species increases the availability of 

indigenous species, a goal generally supported and encouraged by Tribal governments. Salmon and other 

fish, certain flora, and large game are treaty resources central to the culture of the Indian tribes and are 

discussed in detail in specific resource reports for this project. 

Alternative 2- Proposed Action

Alternative 2 is the Proposed Action to update the current program and effectively contain, control or 

eradicate known invasive plants and those found in the future. Ground-disturbing treatments such as 

digging, pulling or restoration planting would be screened by a cultural resource specialist to ensure that 

no impact on cultural resources occurs. Digging is planned at 4 sites, hand pulling at 136 sites, and posttreatment restoration involving digging and planting vegetation at 44 sites. Two digging locations require 

survey prior to treatment, 1 hand pulling location requires survey prior to treatment, and 38 post-treatment 

planting locations need survey or further analysis prior to digging to plant vegetation. These sites are 

identified in the Project Record. 

Direct and Indirect Effects to Heritage Resources. No direct or indirect effects to heritage resources 

were identified as a result of this analysis. This project was reviewed under the terms of the Programmatic 

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Agreement (PA), and excluded from case by case review by the SHPO (USDA Forest Service 1997; 

Appendices A & B). Mitigation measures reduce the likelihood that heritage resources would be affected 

during implementation of the project. 

Direct and Indirect Effects to Reserved Treaty Rights. Treaty rights would remain unchanged under 

Alternative 2. Tribal notification and coloration of herbicides would reduce the potential for concerns 

regarding tribal gathering and invasive plant treatments. Effects to salmon and other fish, certain flora, 

and large game are discussed in detail in specific resource reports for this project. 

Alternative 3 – No Aminopyralid (Milestone®) 

Alternative 3 to responds to concerns about aminopyralid being a newer herbicide with less of a history 

than the others we propose to use. The available treatment would expand to follow the R6 2005 ROD 

standards and more effectively treat invasive plants but we would not amend the MBS Forest Plan and we 

would not use aminopyralid (trade name Milestone®). All of the Management requirements/Mitigation 

Measures, the Early Detection and Rapid Response approach and monitoring that are associated with the 

Proposed Action (Alternative 2) would apply to Alternative 3 except buffers and other measures that 

apply to aminopyralid. 

Direct and Indirect Effects to Heritage Resources. The Direct and Indirect effects in Alternative 3 are 

the same as Alternative 2.

Direct and Indirect Effects to Reserved Treaty Rights. The effects in Alternative 3 are the same as 

Alternative 2. 

3.10.3.2 Cumulative Effects

The affected area for an analysis of cumulative effects to heritage resources is the invasive plant sites. The 

affected area for cumulative effects to treaty rights and other tribal uses is the treatment analysis areas.

The affected areas for specific resources such as salmon, wildlife and plants, are discussed in specific 

resource reports prepared for this project.

Cumulative Effects to Heritage Resources. None of the alternatives would adversely affect historic 

properties. Therefore, either of these alternatives, together with all previous projects, would not contribute 

to cumulative effects to heritage resources.

Cumulative Effects to Treaty Rights. Treaty reserved rights under the Treaty of Point Elliott are 

unaltered; therefore none of the alternatives would contribute to cumulative effects to treaty rights. 

3.10.4Consistencies with Regulations, Policies and Plans

This project is consistent with regulations, policies and plans associated with cultural resources.

3.11 Other Required Disclosures 

3.11.1Environmental Justice and Civil Rights

Low income and minority groups would see no change to their use of the MBS under this alternative. 

There currently are no disparate effects on these populations by forest management activities.

Executive Order 12898 directs federal agencies to identify and address the problem of adverse 

environmental effects by agency programs on minority and low income populations. 

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Employees or contractors for the MBS and/or one of the counties would likely implement herbicide 

treatments. County invasive plant control departments do not indicate that they employ any specific 

population group that could be disproportionately affected during invasive plant treatments. Regardless, 

licensed herbicide applicators are required to supervise work crews and proper personal protective 

equipment would be used. In addition, the MR/MM minimize potential effects on human health. These 

measures restrict rates, application methods, and extent of herbicide use so that even those who consume 

fish, meat or vegetation from the forest would not be adversely affected. 

3.11.2 Irreversible and Irretrievable loss of Resources

Irreversible commitments of resources are those that cannot be regained, such as the extinction of species 

or the removal of mined ore. Irretrievable commitments are those that are lost for a period of time, such as 

the temporary loss of timber productivity in forested areas that are kept clear for use as a power line rightof-way or road. 

No irreversible or irretrievable uses of resources are associated with this invasive plant treatment project. 

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

treatments in accordance with the alternatives would have relatively short-lived impacts, as effects on 

non-target species would be minimized by project management requirements, thus such effects would not 

be permanent. 

3.11.3Prime farmland, Rangeland and Forestland

No prime farmland, rangeland, or forestland exists in the project area; therefore, there would be no effects 

to these. Under the No-Action Alternative , continued spread and incidence of invasive plants on National 

Forest System lands could impact adjacent private lands which could be considered prime farmland or 

rangeland. Invasive plant treatments on lands adjacent to National Forest are discussed in Chapter 3.1.6. 

Alternative 2 would be the most effective in reducing the potential of invasive plants to spread to private 

lands adjacent to the National Forest, because of reduced costs and more herbicide options available to 

treat invasive plants on the Forest (also see discussion in Chapter 3.2, Treatment Effectiveness).

3.11.4 Potential Conflicts with Plans or Policies of other Jurisdictions

No conflicts with existing plans have been noted for this project. Based on information received during 

scoping, none of the alternatives would conflict with existing plans or policies of other jurisdictions. The 

invasive plant treatments on neighboring lands are described in Chapter 3.1.6. These treatments would not 

necessarily follow the MR/MM for this project but would follow applicable laws and herbicide label 

requirements. 

3.11.5 Permits and Licenses

The R6 2005 ROD Standard 15 requires that application of any herbicides to treat invasive plants will be 

performed or directly supervised by a state or federally licensed applicator.

A Clean Water Act (National Pollution Discharge Elimination System - NPDES) permit is required for 

herbicide use that may directly enter streams (streambanks, target vegetation hanging over water bodies, 

treatment sites generally within three feet from a water body). Treatments on small portions of riparian 

infestations (currently mapped or detected in the future) may meet the criteria; however, the target 

invasive species on the Malheur National Forest are not riparian dependent. The current mapping is not 

refined enough to determine whether a permit will ultimately be needed; however, NPDES Pesticide 

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General Permits would be obtained prior to implementing any treatments in which herbicide could be 

directly introduced into surface waters.

As discussed in Chapter 2 for the Implementation Planning Process that apply to all action alternatives, 

Form FS-2100-2 Pesticide Use Proposal, would be developed prior to herbicide treatment. In addition, as 

per FSH 2109.14.3, a pesticide use plan would be developed. 

3.11.6 Non-significant Land and Resource Management Plan Amendment

 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 onsite 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 NF to any extent. This Forest 

Plan amendment does not change any Forest Plan management area boundaries or management 

prescriptions on the MBS NF. Amending the standard will not change the multiple-use goals and 

objectives for long-term land and resource management of the MBS NF. 

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

not currently listed among the ten herbicides approved by the Regional Forester in 2005 (R6 2005 ROD). 

The Risk Assessment for aminopyralid (SERA 2007) was completed subsequently and demonstrates that 

use of this herbicide will not pose new or significant risks compared to the ten already approved. 

Aminopyralid is generally a lower risk herbicide and the proposed use will not pose additional risks to 

human health or the environment. U.S. EPA (2005) has concluded that the use of aminopyralid as a 

replacement for other herbicides will decrease risk to some non-target species:

Aminopyralid is a Reduced Risk herbicide that provides reliable control of a broad spectrum of 

difficult-to control noxious weeds and invasive plants on rangeland and pastures, rights-of-way, and 

wildlife habitat areas. Aminopyralid is particularly effective for the control of tropical soda apple, 

musk thistle, Canada thistle, spotted knapweed, diffuse knapweed, yellow starthistle and Russian 

knapweed. Aminopyralid has a favorable human health toxicity profile when compared to the 

registered alternatives for these use sites and will be applied at a lower rate. Its residual action 

should alleviate the need for repeat applications, resulting in a reduction in the amount of herbicides 

applied to the environment for the control of these weeds. Aminopyralid has been determined to be 

practically non-toxic to non-target animals at the registered application rates, compared to the 

alternatives, and is less likely to impact both terrestrial and aquatic plants. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Chapter 3-Other Required Disclosures

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 NF. Aminopyralid is an herbicide that is very 

effective for most of the invasive plant species found within the MBS NF. 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 Forest Plan (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.

Based on these factors, adding aminopyralid to the list of herbicides approved for use treating invasive 

plants on the MBS would not be a significant amendment to the Forest Plan.

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Chapter 4

Chapter 4. List of Preparers, Consultation and 

Coordination with Others (Tribes, Agencies)

4.1 List of Preparers 

The following people were the primary authors of this FEIS. Many other Forest Service employees and 

others reviewed the document and provided input. 

Vincent Archer -Soil Scientist, USDA Forest Service, Enterprise Program, Above and Beyond 

Ecosystems.

Contribution: Effects analysis for soils. 

Education: B.S., Environmental Science, Chico State Univ. 1994; M.S. Resource Conservation, Soils 

Emphasis, Univ. of Montana, 2001 

Shawna L. Bautista, Region 6 Pesticide Use Coordinator and Invasive Plant Program Manager, US 

Forest Service, Forest Health Protection, Portland, OR 

Contributions: Herbicide effects analysis techniques, technical review of documents

Education: B.S. Wildlife Management, Humboldt State University, 1985; M.S. Zoology and 

Physiology, University of Wyoming, 1988 

Carl Burdick – Archeologist, USDA Forest Service, Mt. Baker-Snoqualmie National Forest

Contribution: Effects analysis for Heritage Resources & Reserved Treaty Rights. 

Education: B.A., Anthropology, California State University, Fresno 1994; M.A., Anthropology, 

University of Alaska, Fairbanks 1997 

Sarah Callaghan - Invasive Plant Specialist, USDA Forest Service, Mt. Baker-Snoqualmie National 

Forest.

Contribution: ID Team botany analysis and invasive plants, Co-Team Leader January to March 2014

Education: B.S. Biology, Washington State University-Vancouver, 2005 

Rochelle Desser, Invasive Plant NEPA and Monitoring Coordinator – USDA Forest Service, Pacific 

Northwest Region

Contribution: Team Co-Leader, NEPA Coordination, Economic Analysis 

Education: A.S. Flathead Valley College, 1985; Interdisciplinary Studies Sonoma State University 

Loren I Everest– Forest Fisheries Program Manager, USDA Forest Service, Mt. Baker-Snoqualmie 

National Forest.

Contribution: Effects analysis for Fisheries, Fisheries ESA consultation.

Education: B.S. Fisheries, Humboldt State Univ. 1991 

Amy Lieb – Soil/Water Program Manager, USDA Forest Service, Mt. Baker-Snoqualmie National 

Forest

Contribution: Effects analysis for Water Resources.

Education: B.S. Hydrology, University of New Hampshire, 1999; Masters of Public Administration, 

University of Colorado at Denver, 2006 

Shauna Hee – North Zone Botanist, USDA Forest Service, Mt. Baker-Snoqualmie National Forest

Contribution: Effects analysis for botany. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Chapter 4

Education: B.S., Plant Biology, University of California, Davis

Tasha Lo Porto – USDA Forest Service, Washington Office

Contribution: Former Assistant Team Leader. 

Education: B.A., Political Science & B.S., Conservation Resource Studies, Univ. of California, 

Berkeley

Theresa Mathis - Environmental Coordinator/Wildlife Biologist USDA Forest Service, Mt. BakerSnoqualmie National Forest. 

Contribution: Assist with development of Cumulative Effects Tables 

Education: B.S. Biology, BAE Secondary Education, Eastern Washington University; 1999; M.S., 

Wildlife Biology, Eastern Washington University, 2004 

Gary Paull – Forest Trails and Wilderness Coordinator, USDA Forest Service, Mt. BakerSnoqualmie National Forest

Contribution: Effects analysis for Wilderness, Wild and Scenic River and Recreation

Education: 1980 University of Washington, BS General Studies, Paleo environmental Analysis; 1987 

University of Washington, Secondary Teaching Certificate Earth Sciences 

Jesse J Plumage – Forest Wildlife Program Manager, USDA Forest Service, Mt. Baker-Snoqualmie 

National Forest.

Contribution: Effects analysis for terrestrial wildlife.

Education: B.S. Wildlife Management, Humboldt State University, 1991. 

Laura Potash, Botany Program Manager (retired) – USDA Forest Service, Mt. Baker-Snoqualmie 

National Forest

Contribution: Effects analysis for botany, Forest Team leader from 2010-2013. 

Education: M.S. from U of Washington 1989 in Plant Ecology. 

Phyllis Reed, Environmental Coordinator/Wildlife Biologist - USDA Forest Service, Mt. BakerSnoqualmie National Forest

Contribution: Forest Team Coordinator and Co-Leader, 2014. 

Education: B.S. Forest Resources, Iowa State University, M.S. Forest Biology, University of 

Washington 1983 

Ann Risvold (retired) - North Zone Botanist, USDA Forest Service, Mt. Baker-Snoqualmie National 

Forest, Darrington and Mt. Baker Ranger Districts. 

Contribution: Botany Affected Environment 

Education: Bachelor of Science, Forest Management, University of Washington, 1983 

Master of Science, Plant Ecology, Western Washington University, 1997 

Maple Taylor – USDA Forest Service, TEAMS Enterprise Unit

Contribution: Editorial Assistance 

Education: M.S., Wildlife Ecology, Texas Tech University; B.S., Wildlife Science, New Mexico 

State University.

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Chapter 4

4.2 Consultation with Regulatory Agencies

The Forest Service consulted with the U.S. Fish and Wildlife Service (USFWS) and National Marine 

Fisheries Service (NOAA Fisheries, NMFS) regarding potential adverse effects on federally listed or 

proposed Threatened or Endangered Species. The process and results of consultation are discussed in 

Chapter 3.3 and 3.5. Consultation records are part of the Project Record. 

4.3 Consultation with Tribal Governments

Government to government consultation is ongoing with 14 tribes including: the 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 Tulalip Tribes, the Upper Skagit and the Yakama Tribe. Letters have been sent to all 

tribal chairs, and follow-up calls or meetings have occurred at the request of the tribes.

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.

4.4 Consultation with Counties and Municipal Water Boards 

The Forest Service consulted with County Weed Boards on invasive plant treatments proposed adjacent to 

and on county roads within the boundaries of the Forest. The Forest Service also contacted other federal 

and state agencies in regards to their known use of herbicides, including the National Park Service, the 

Bonneville Power Administration, Washington State Department of Transportation and Washington State 

Department of Natural Resources (see Chapter 3.1.6.2). 

4.5 Consultation with Others/FEIS Distribution 

Scoping has occurred on this project since 2010. The public has been apprised of project progress through 

the newspaper, direct mailings, Notices of Intent published in the Federal Register in 2012, the Forest 

Schedule of Proposed Actions, informal meetings and discussions, and other media. The full FEIS and 

Appendices are available electronically on the Forest website: 

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=34208

Agencies and members of the public expressing interest in the project received notice that the Final EIS is 

available on request and on the website noted above. Hard copies and CD-ROM versions of the 

documents were mailed directly to: 

Individuals 

William (Bill) Lider 

Dick Artley

Eileen Maloney

Eric Olsen

Ben and Nancy Brodie 

Dennis Clark 

Brooke Thompson 

Matt Bell 

Organizations 

Pilchuck Audubon 

Middle Fork Outdoor Recreation Coalition 

Northwest Coalition for Alternatives to Pesticides

Sierra Club 

Agencies

Environmental Protection Agency 

United States Department of Agriculture

Northwest Power Planning 

Federal Energy Regulatory Commission 

King County Noxious Weed Board 

Seattle Major Watersheds

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Chapter 4

North Cascades National Park 

U.S. Fish and Wildlife Service Tribal Governments

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 Tulalip Tribes

The Upper Skagit 

The Yakama Tribe

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Chapter 5

Chapter 5. Literature Cited, Glossary and Index

5.1 Literature Cited

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attenuation of ultraviolet-b radiation in montane ponds. Oecologia, 128(4), 519-525. 

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Human Services. 2004. Guidance Manual for the Assessment of Joint Toxic Action of 

Chemical Mixtures. U.S. Department of Health and Human Services, Public Health 

Service, ATSDR, Division of Toxicology. 62 pp. plus appendices. 

Almack, J. A., W. L. Gaines, P. H. Morrison, J. R. Eby, R. H. Naney, G. F. Wooten, S. H. Fitkin, 

and E. R. Garcia. 1993. North Cascades grizzly bear ecosystem evaluation. Denver, CO: 

Final Report. 169 p. 

Altman, B. 1999. Conservation Strategy for Landbirds in Coniferous Forests of Western Oregon 

and Washington.

Ames, Kenneth and Herbert Maschner.1999. Peoples of the Northwest Coast: Their Archaeology 

and Prehistory. Thames and Hudson Ltd, New York 

Anderson, J.J. and J.J. Dulka. 1985. Environmental fate of sulfometuron methyl in aerobic soils. 

J. Agric. Food Chem. 33: 596-602 

Archer, A.J. 2001. Taeniatherum caput-medusae [Web Page]. Located at: 

http://www.fs.fed.us/database/feis. Accessed 2003 Aug 11.

Asher, J. 2000. War on weeds: wining it for wildlife. Paper presented at North American Wildlife 

and Natural Resources conference. Rosemont, Illinois. March 27. 17 pp. 

Aubry, K.B., and C.M. Raley. 2002. Selection of nest and roost trees by pileated woodpeckers in 

coastal forests of Washington. J. Wildl. Manage. 66(2):392-406. 

Aubry, K.B.; Senger, C.M.; Crawford, R.L. 1987. Discovery of Larch Mountain salamanders 

(Plethodon larselli) in the central Cascade Range of Washington. Biological Conservation 

42: 147-152. 

Bakke, D. 2000. A review and assessment of the results of water monitoring for herbicide 

residues for the years 1991 to 1999. Unpublished Internal Forest Service Report. USDA 

Forest Service, USFS Region 5. Vallejo, CA. 38p. 

Bakke, David. 2003. Human and Ecological Risk Assessment of Nonylphenol Polyethoxylatebased (NPE) Surfactants in Forest Service Herbicide Applications. Unpublished report by 

the Forest Service Pacific Southwest Regional Pesticide Use Specialist. 

249 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Chapter 5

Bakke, David. 2002, 2007. Analysis of issues surrounding the use of spray adjuvants with 

herbicides. Unpublished report by the Forest Service Pacific Southwest Regional 

Pesticide Use Specialist. 

Banci, V. 1994. Wolverine. Pp. 99-127 In Ruggiero, L.F.; K.B. Aubry; S.W. Buskirk; L.J. Lyon; 

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Fisher, Lynx, and Wolverine in the Western United States, RM-GTR-254. Fort Collins, 

Colorado. USDA Forest Service, Rocky Mountain Research Station. 184 pp. 

BASF. 2002. Chopper herbicide (imazapyr). BASF Corporation. Research Triangle Park, NC. 7 

pp. 

BASF. 2003. Plateau herbicide (imazapic). BASF Corporation. Research Triangle Park, NC. 16 

pp. 

Bashkin, M., T.J. Stohlgren, Y. Otsuki, m. Lee, P. Evangelista, and J. Belnap. 2003. Soil 

characteristics and plant exotic species invasions in the Grand Staircase-Escalante 

national Monument, Utah, USA. Applied Soil Ecology. 22(1): 67-77 

Beard, R., and Carbone, J. 2001. Invasive Plant Management—Decisions and Environmental 

Analyses. USDA. Forest Service. Fifth in a series of five discussion papers on the 

National Environmental Policy Act of 1969 (NEPA) and invasive plant management. 

2001 November: 26p. 

Bedunah, D., and Carpenter, J. 1989. Plant community response following spotted knapweed 

(Centaurea maculosa) control on three elk winter ranges in western Montana Plant &Soil 

Department and Extension Service/ Montana State University. 1998 - Knapweed 

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Berg, N. 2004. Assessment of Herbicide Best Management Practices: Status of Our Knowledge 

of BMP Effectiveness. Unpublished. Pacific Southwest Research Station, USDA Forest 

Service, Albany CA. 194p. 

Berger, L., R. Speare, P. Daszak, D.E. Green, A.A. Cunningham, C.L. Goggin, R. Slocombe, 

M.A. Ragan, A.D. Hyatt, K.R. McDonald, H.B. Hines, K.R. Lips, G. Marantelli, H. 

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declines in the rain forests of Australia and Central America. Proceedings of the National 

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Berger, L., R. Speare, A.D. Hyatt. 1999. Chytrid fungi and amphibian declines: overview, 

implications and future directions. A. Campbell, Ed. Declines and disappearances of 

Australian frogs. Canberra.: Environment Australia. p. 23-33 

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Larvae. Herpetological Conservation 1:233-45. 

Beschta, R. L. 1997. Riparian Shade and Stream Temperature: An Alternative Perspective. 

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250 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Chapter 5

Birdsall, J.L., W. McCaughey, and J.B. Runyon. 2011. Roads impact the distribution of noxious 

weeds more than restoration treatments in a lodgepole pine forest in Montana, U.S.A. 

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Blaustein, A.R., L.K. Belden, D.H. Olson, D.M. Green, T.L. Root, and J.M. Kiesecker. 2001. 

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Use, Practices, Localities, and resources: Study Area on the Mt. Baker-Snoqualmie 

National Forest Washington State. Institute of Cooperative Research, Seattle, 

Washington, April 1981

Blukis Onat, Astrida, Lee Bennett and Jan Hollenbeck. 1980. Cultural Resource Overview and 

Sample Survey of the Skagit Wild and Scenic River. Study area on the Mt. BakerSnoqualmie National Forest, Washington State. 3 Volumes. Institute of Cooperative 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Chapter 5

Cameron, S. A., Lozier, J. D., Strange, J. P., Koch, J. B., Cordes, N., Solter, L. F., & Griswold, T. 

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document. June 1999. Cooperative Elk Management Group. 54 pp. 

Chew, F.S. 1981. Coexistence and local extinction in two Pieris butterflies. American Naturalist 

118: p.655-72. 

Clark, B.S., D.M. Leslie, Jr., and T.S. Carter. 1993. Foraging activity of adult female Ozark bigeared bats (Plecotus townsendii ingens) in summer. Journal of Mammalogy 74(2):422-

427. 

Cox-Foster, D.L., Conlan, S., Holmes, E.C., Palacios, G., Evans, J.D., Moran, N.A., Quan, P., 

Briese, T., Hornig, M., Geiser, D.M., Martinson, V., vanEngelsdorp, D., Kalkstein, A.L., 

Drysdale, A., Hui, J., Zhai, J., Cui, L., Hutchison, S.K., Simons, J., Egholm, M., Pettis, 

J.S., Lipkin, W. 2007. A metagenomic survey of microbes in honey bee colony collapse 

disorder. Science. 318:283-287. 

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D.H. Olson 2004. Conservation Assessment for the Van Dyke's Salamander (Plethodon 

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Crump, M.L. 2005. Why are some species in decline but others not? Pp. 7-9 In M. Lannoo, ed. 

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Deixis MolluscDB database. 2009. An unpublished collection of mollusk records maintained by 

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foraging activity of Townsend’s big-eared bat (Plecotus townsendii) in central Oregon. 

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Dow AgroSciences. 2001. Specimen Label – Forestry Garlon 4 Specialty Herbicide (triclopyr).

Revised 02-26-01. Dow AgroSciences LLC, Indianapolis, IN. 7 pp 

Dow AgroSciences. 2000. Specimen Label – Tordon 22K (picloram). Revised 05-24-00. Dow 

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Bossard, C.C., Randall, J.M., and Hoshousky, MC, eds. Invasive plants of California 

wildlands. Berkeley, CA: Univ. of California Press. p.53-8. 

Dunwiddie, P. W. and R. C. Kuntz II. 2001. Long-term trends of bald eagles in winter on the 

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DuPont. DuPont Telar DF herbicide (chlorsulfuron). 2002. E.I. du Pont de Nemours and 

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Ehrenfield, J.G. 2003. Effects of exotic plant invasions on soil nutrient cycling processes. 

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5.2 Glossary 

Active ingredient (a.i.) - In any pesticide product, the component (a chemical or biological substance) that 

kills or otherwise controls the target pests - Pesticides are regulated primarily on the basis of active 

ingredients. The remaining ingredients are called “inerts.” 

Activity center (northern spotted owl) - The core of an owl’s territory and the focal point of protection 

measures. Most frequently located in or near the highest concentration of remaining suitable habitat.

Acute effect - An adverse effect on any living organism in which severe symptoms develop rapidly and 

often subside after the exposure stops. 

Acute exposure - A single exposure or multiple brief exposures occurring within a short time (e.g., 24 

hours or less in humans). The classification of multiple brief exposures as “acute” is dependent on the life 

span of the organism. (See also, chronic exposure and cumulative exposure.)

Acute toxicity - Any harmful effect produced in an organism through an acute exposure to one or more 

chemicals.

Additive effect - A situation in which the combined effects of exposure to two chemicals simultaneously 

is equal to the sum of the effect of exposure to each chemical given alone. The effect most commonly 

observed when an organism is exposed to two chemicals together is an additive effect.

Adaptive management - A continuing process of action-based planning, monitoring, researching, 

evaluating, and adjusting with the objective of improving implementation and achieving the goals of the 

standards and guidelines

Adjuvant(s) - Chemicals that are added to pesticide products to enhance the toxicity of the active 

ingredient or to make the active ingredient easier to handle or mix. 

Adsorption - The tendency of one chemical to adhere to another material such as soil. 

Affected Environment - Existing biological, physical, social, and economic conditions of an area subject 

to change, both directly and indirectly, as the result of a proposed human action. 

Agent - Any substance, force, radiation, organism, or influence that affects the body. The effects may be 

beneficial or injurious.

Agency for Toxic Substances and Disease Registry (ATSDR) - Federal agency within the Public Health 

Service charged with carrying out the health-related analyses under Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA) and Superfund Amendments and Reauthorization 

Act (SARA).

Ambient - Usual or surrounding conditions. 

Amphibian - Any of a class of cold-blooded vertebrates (including frogs, toads, or salamanders) that are 

intermediate in many characteristics between fishes and reptiles and having gilled aquatic larvae and airbreathing adults. 

Anadromous (Fish) - Fish that spend their adult life in the sea but swim upriver to fresh water spawning 

grounds to reproduce.

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Annual - A plant that endures for not more than a year. A plant which completes its entire life cycle from 

germinating seedling to seed production and death within a year. 

Annual and Life of the Project Caps – The project caps are limitations on the acreage that may be treated 

annually and over the life of the project. 

Bacteria - Microscopic living organisms that metabolize organic matter in soil, water, or other 

environmental media. Some bacteria can also cause human, animal and plant health problems.

Bankfull (elevation) – The elevation of water in a stream or river where it just fills the channel to the top 

of its banks and at a point where water begins to flow onto a floodplain. 

Bear Management Unit (BMU) - The area assessed for carrying capacity of a sow grizzly bear and cub.

Best Management Practices (BMP) - A practice or combination of practices determined by a state or an 

agency to be the most effective and practical means (technological, economic, and institutional) of 

controlling point and non-point source pollutants at levels compatible with environmental quality. 

Bioaccumulation - The increase in concentration of a substance in living organisms as they take in 

contaminated air, water, or food because the substance is very slowly metabolized or excreted (often 

concentrating in the body fat.) 

Bioconcentration - The accumulation of a chemical in tissues of a fish or other organism to levels greater 

than in the surrounding water or environment. 

Bioconcentration Factor (BCF) - The concentration of a compound in an aquatic organism divided by the 

concentration in the ambient water of the organism.

Biological control - The use of natural enemies, including invertebrate parasites and predators (usually 

insects, mites, and nematodes,) and plant pathogens to reduce populations of non-native, invasive plants.

Broadcast application - Herbicide treatment method generally used along roads; boom truck spray is 

directed at target species. Broadcast methods are used for larger infestations where spot treatments would 

not be effective.

Herbicide Use Buffer - A strip of land near a waterway or other environmentally sensitive area where a 

particular chemical and method of application is restricted, depending on the herbicide ingredient. 

Candidate species - Those plant and animal species that, in the opinion of the Fish and Wildlife Service 

(FWS) or National Oceanic and Atmospheric Administration (NOAA) Fisheries, may qualify for listing 

as “endangered” or “threatened.” The FWS recognizes two categories of candidates. Category 1 

candidates are taxa for which the FWS has on file sufficient information to support proposals for listing. 

Category 2 candidates are taxa for which information available to the FWS indicates that proposing to list 

is possibly appropriate, but for which sufficient data are not currently available to support proposed rules. 

Carcinogen - A chemical capable of inducing cancer.

Chemical Control - The use of naturally derived or synthetic chemicals called herbicides to eliminate or 

control the growth of invasive plants. 

Chronic exposure - Exposures that extend over the average lifetime or for a significant fraction of the 

lifetime of the species (for a rat, chronic exposure is typically about 2 years). Chronic exposure studies 

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are used to evaluate the carcinogenic potential of chemicals and other long-term health effects. (See also, 

acute and cumulative exposure.) 

Chronic toxicity - The ability of a substance or mixture of substances to cause harmful effects over an 

extended period, usually upon repeated or continuous exposure sometimes lasting for the entire life of the 

exposed organism 

Code of Federal Regulations (CFR) - Document that codifies all rules of the executive departments and 

agencies of the federal government. It is divided into fifty volumes, known as titles. Title 40 of the CFR 

(referenced as 40 CFR) lists all environmental regulations, including regulations for EPA pesticide 

programs (40 CFR Parts 150-189). 

Competitive Seeding – A treatment method that is intended to reduce the potential for invasive plants to 

become introduced or to reoccupy a site once target populations have been reduced. This method is often 

combined with other treatment methods. 

Congressionally Designated Areas - Areas that require Congressional enactment for their establishment, 

such as National Parks, Wild and Scenic Rivers, National Recreation Areas, National Monuments, and 

Wilderness. Also referred to as Congressional Reserves. Includes similar areas established by Executive 

Order, such as National Monuments. 

Connected Actions – An action that would occur at the same time and place, or would be required to 

occur, in order to implement a proposed action, and therefore would be analyzed in a single NEPA 

document. 

Contaminants - For chemicals, impurities present in a commercial grade chemical. For biological agents, 

other agents that may be present in a commercial product.

Critical Habitat (for threatened or endangered species under the Endangered Species Act – (i) the specific 

areas within the geographical area occupied by the species, at the time it is listed in accordance with the 

provisions of section 4 of this Act, on which are found those physical or biological features (I) essential to 

the conservation of the species and (II) which may require special management considerations or 

protection; and (ii) specific areas outside the geographical area occupied by the species at the time it is 

listed in accordance with the provisions of section 4 of this Act, upon a determination by the Secretary 

that such areas are essential for the conservation of the species. The USFWS and the NMFS formally 

designate what is “critical habitat” for their respective species. Critical habitat includes the stream 

channels with a lateral extent defined by the ordinary high-water line [33 CFR 319.11]). Critical habitat: 

can include an area not currently occupied by the species, which is itself essential to the conservation of 

the species. As defined in the ESA “conservation” means any and all methods and procedures, and the use 

of those, needed to bring a species to recovery—the point at which the protections of the ESA are no 

longer needed. 

Cultural control - The establishment or maintenance of competitive vegetation, use of fertilizing, 

mulching, prescribed burning, or grazing animals to control or eliminate invasive plants. 

Cultural Items - From section 2 of the Native American Graves Protection and Repatriation Act 

(NAGPRA) (25 U.S.C. 3001 et seq.) which includes Associated Funerary Objects, Unassociated Funerary 

Objects, Sacred Objects, and Objects of Cultural Patrimony. The term “cultural items” does not include 

human remains. 

Cumulative Effect - The impact on the environment that results from the incremental impact of the action 

when added to other past, present, and reasonably foreseeable future actions—regardless of what agency 

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(federal or non-federal) or person undertakes such other actions. Cumulative impacts can result from 

individually minor, but collectively significant, actions taking place over a period of time (40 CFR 

1508.7). 

Depressed Stock (fish) - A stock of fish whose production is below expected levels based on available 

habitat and natural variations in survival rates, but above the level where permanent damage to the stock 

is likely.

Disturbance - An effect of a planned human management activity, or unplanned native or exotic agent or 

event that changes the state of a landscape element, landscape pattern, or regional composition.

Dosage/Dose - (1) The actual quantity of a chemical administered to an organism or to which it is 

exposed. (2) The amount of a substance that reaches a specific tissue (e.g. the liver). (3) The amount of a 

substance available for interaction with metabolic processes after crossing the outer boundary of an 

organism. 

Dose Response - Changes in toxicological responses of an individual (such as alterations in severity of 

symptoms) or populations (such as alterations in incidence) that are related to changes in the dose of any 

given substance.

Drift - The portion of a sprayed chemical that is moved by wind off of a target site.

Early Detection and Rapid Response (EDRR) – Treatment of invasive plants over the life of the project 

according to the implementation planning process. 

Endangered Species - Any species listed in the Federal Register as being in danger of extinction 

throughout all, or a significant portion, of its range. 

Endangered Species Act (ESA) - A law passed in 1973 to conserve species of wildlife and plants, 

determined by the Director of the U.S. Fish and Wildlife Service or the NOAA Fisheries to be endangered 

or threatened with extinction in all or a significant portion of its range. Among other measures, ESA 

requires all federal agencies to conserve these species and consult with the Fish and Wildlife Service or 

NOAA Fisheries on federal actions that may affect these species or their designated critical habitat.

Endemic - A species or other taxonomic group that is restricted to a particular geographic region due to 

factors such as isolation or response to soil or climatic conditions. (Compare to “Indigenous” and 

“Native.”)

Environmental justice - Executive Order 12898 of February 11, 1994 requires federal agencies, to the 

greatest extent practicable and permitted by law, to make achieving environmental justice part of its 

mission by identifying and addressing, as appropriate, disproportionately high and adverse human health 

or environmental effects of its programs, policies, and activities on minority populations and low-income 

populations in the United States and its territories and possessions, the District of Columbia, the 

Commonwealth of Puerto Rico, and the commonwealth of the Mariana Islands. 

Essential Fish Habitat - Waters and substrate necessary to fish for spawning, breeding, feeding, or growth 

to maturity.

Exotic – Non-native species; introduced from elsewhere, but not completely naturalized. (See also alien 

and introduced species.)

Extirpated – An organism that is eliminated from a local area.

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Fish-Bearing Streams - Any stream containing any species of fish for any period of time. 

Federal Insecticide and Rodenticide Act (FIFRA) Pesticide Ingredient - An ingredient of a pesticide that 

must be registered with EPA under the Federal Insecticide, Fungicide, and Rodenticide Act. Products 

making pesticide claims must submit required information to EPA to register under FIFRA and may be 

subject to labeling and use requirements.

Fertilization - Treatment method involving adding of nutrients that could improve the success of desirable 

species; may be limited, depending on species/soil characteristics.

First-choice Herbicides – First-choice herbicides are those that would be used during the first year of 

treatment of a given primary target species. It is likely be most effective, given the options associated with 

a given action alternative. First-choice herbicides are often used in combination with non-herbicide 

methods. 

Flora - Plant life, especially all the plants found in a particular country, region, or time regarded as a 

group. Also, a systematic set of descriptions of all the plants of a particular place or time. 

Forage - Food for animals. In this document, term applies to both availability of plant material for wildlife 

and domestic livestock.

Forest Service Sensitive Species - For Region 6 of the Forest Service, those plant and animal species 

identified by the Regional Forester for which population viability is a concern, as evidenced by significant 

current or predicted downward trends in population numbers or density and habitat capability that would 

reduce a species’ existing distribution (FSM 2670.5). 

Formulation - A commercial preparation of a chemical including any inerts and/or contaminants.

Fragmentation - The degree to which the landscape is broken into distinct patch types.

Fungi - Molds, mildews, yeasts, mushrooms, and puffballs, a group of organisms that lack chlorophyll 

and therefore are not photosynthetic. They are usually non-mobile, filamentous, and multi-cellular. 

Geographical Information System (GIS) – Maps and data showing location and attributes for natural 

resources found within a project area. 

Groundwater - The supply of fresh water found beneath the Earth's surface, usually in aquifers, which 

often supply wells and springs. 

Groundwater Loading Effects of Agricultural Management Systems (GLEAMS) - A model that displays 

herbicide concentrations in streams under a variety of soil, climate, and vegetative conditions.

Habitat - The place where a population (e.g., human, animal, plant, microorganism) lives and its 

surroundings, both living and non-living.

Half-life - The time required for the concentration of the chemical to decrease by one-half.

Hand/Selective application - Herbicide treatment of individual plants through wicking, wiping, injecting 

stems, etc., with low likelihood of drift or delivery of herbicides away from treatment sites. This method 

ensures no herbicide directly contacts soil.

Hand-pulling/Grubbing - Treatment method which is labor-intensive but effective on single plants or on 

small, low-density infestations. 

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Hazard Quotient (HQ) - The ratio of the estimated level of exposure to a substance from a specific 

pesticide application to the RfD for that substance, or to some other index of acceptable exposure or 

toxicity. A HQ less than or equal to 1 is presumed to indicate an acceptably low level of risk for that 

specific application. 

Hazard identification - The process of identifying the array of potential effects that an agent may induce 

in an exposed of humans or other organisms. 

Healthy Stock - A stock of fish experiencing production levels consistent with its available habitat and 

within the natural variations in survival for the stock.

Herbaceous - A plant that does not develop persistent woody tissue above the ground (annual, biennial, or 

perennial.) Herbaceous vegetation includes grasses and grass-like vegetation, and broadleaved forbs.

Herbicide - A chemical preparation designed to kill plants, especially weeds, or to otherwise inhibit their 

growth. May or may not include an additive (adjuvant) such as a surfactant. 

Herbicide Application Rate – The amount of herbicide active ingredient that would be used on a treated 

acre. The maximum rate is the amount allowed by an herbicide label. Typical rate is the average rate used 

by the Forest Service for invasive plant treatment projects. Lowest rate (or lowest effective rate) is the 

least amount of herbicide that could be used to reach treatment objectives. 

Herbicide Treatment – Any use of herbicide to meet treatment objectives. Herbicide treatments are part of 

the integrated weed management toolbox. Herbicide treatment may be combined with non-herbicide 

treatments to meet treatment objectives. 

Herbicide Use Buffer – An area adjacent to a stream or other water body where herbicide ingredient or 

application methods are restricted. 

Hibernacula - Sites where hibernation occurs.

Human influence zone -Areas of human activity (recreation sites, roads, trails, buildings, mines, 

hydropower operations, etc.) buffered by one-third mile around trails and one-half mile around roads and 

other sites.

Ordinary high water line – see bankfull.

Indian Tribe - Any American Indian or Alaska Native tribe, band, nation, pueblo, community, rancheria, 

colony, or group meeting the provisions of the Code of Federal Regulations Title 25, Section 83.7 (25 FR 

83.7), or those recognized in statutes or treaties with the United States. 

Indigenous Species - An indigenous species is any which were or are native or inherent to an area. (See 

also, native.)

Inert Ingredient - Anything other than the active ingredient in a pesticide product; not having pesticide 

properties. 

Infested area or site - A contiguous area of land occupied by, in this case, invasive plant species. An 

infested area of land is defined by drawing a line around the actual perimeter of the infestation as defined 

by the canopy cover of the plants, excluding areas not infested. Generally, the smallest area of infestation 

mapped will be 1/10th (0.10) of an acre or 0.04 hectares. 

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

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

management activities to achieve optimum management goals and objectives.

Interdisciplinary Team (IDT) - A group of individuals with varying areas of specialty assembled to solve a 

problem or perform a task. The team is assembled out of recognition that no one scientific discipline is 

sufficiently broad enough to adequately analyze the problem and propose action. 

Introduced species - An alien or exotic species that has been intentionally or unintentionally released into 

an area as a result of human activity. (See also exotic, invasive, and noxious.)

Introduction - “The intentional or unintentional escape, release, dissemination, or placement of a species 

into an ecosystem as a result of human activity” (Executive Order 13122, 2/3/99). 

Invasive plant - An alien plant species whose introduction does or is likely to cause economic or 

environmental harm or harm to human health (Executive Order 13122, 2/3/99) (See also exotic and 

introduced species) 

Irreversible effect - Effect characterized by the inability of the body to partially or fully repair injury 

caused by a toxic agent.

LC50 (Lethal Concentration 50) - A calculated concentration of a chemical in air or water to which 

exposure for a specific length of time is expected to cause death in 50 percent of a defined experimental 

animal population. 

LD50 (Lethal Dose 50) - The dose of a chemical calculated to cause death in 50 percent of a defined 

experimental animal population over a specified observation period. The observation period is typically 

14 days. 

Label - All printed material attached to, or part of, the pesticide container.

Land allocation – An management area designated in a Land and Resource Management Plan associated 

with certain desired conditions, objectives and standards. 

Landscape - An area composed of interacting ecosystems that are repeated because of geology, land form, 

soils, climate, biota, and human influences throughout the area. Landscapes are generally of a size, shape, 

and pattern which is determined by interacting ecosystems. 

Landscape Character - Particular attributes, qualities, and traits of a landscape that give it an image and 

make it identifiable or unique.

Landscape Setting - The context and environment in which a landscape is set; a landscape backdrop. It is 

the combination of land use, landform, and vegetation patterns that distinguish an area in appearance and 

character from other areas.

Large woody debris - Pieces of wood larger than 10 feet long and 6 inches in diameter. 

Late-successional forest - Late-successional forests are those forest seral stages that include mature and 

old-growth age classes. (ROD USDA-USDI, Standards and Guidelines 1994, B-1) 

Leaching - The process by which chemicals on or in soil or other porous media are dissolved and carried 

away by water, or are moved into a lower layer of soil.

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Level of Concern (LOC) - The concentration in media or some other estimate of exposure above which 

there may be effects.

Lichens - Complex thallophytic plants comprised of an alga and a fungus growing in symbiotic 

association on a solid surface (such as a rock.)

Lowest-Observed-Adverse-Effect Level (LOAEL) - The lowest dose of a chemical in a study, or group of 

studies, that produces statistically or biologically significant increases in frequency or severity of adverse 

effects between the exposed and control populations.

Manual Control - The use of any non-mechanized approach to control or eliminate invasive plants (i.e. 

hand-pulling, grubbing) 

Material Safety Data Sheet (MSDS) - A compilation of information required under the OSHA 

Communication Standard on the identity of hazardous chemicals, health and physical hazards, exposure 

limits, and precautions.

Mechanical Control - The use of any mechanized approach to control or eliminate invasive plants (i.e. 

mowing, weed whipping). 

Microorganisms - A generic term for all organisms consisting only of a single cell, such as bacteria, 

viruses, protozoa and some fungi. 

Minimum tool - Use of a weed treatment alternative that would accomplish management objectives and 

have the least impact on resources

Modification - A visual quality objective meaning human activities may dominate the characteristic 

landscape but must, at the same time, utilize naturally established form, line, color, and texture. It should 

appear as a natural occurrence when viewed in foreground or middleground. 

Mollusks - Invertebrate animals (such as slugs, snails, clams, or squids) that have a soft, un-segmented 

body, usually enclosed in a calcareous shell; representatives found on National Forest System land 

include snails, slugs, and clams. 

Monitoring - A process of collecting information to evaluate if objectives and anticipated or assumed 

results of a management plan are being realized or if implementation is proceeding as planned.

Most Ambitious Conceivable Treatment Level – The most ambitious treatment scenario would treat all 

known infestations during the first year of implementation and then retreated until management objectives 

are met. It includes treatments, re-treatments over a series of years, and passive or active restoratino. It is 

an assumption that allows for a consistent analysis comparing alterantives given that Forest Service 

ability funding over the life ofthe project is unknown. 

Mowing - Invasive plant treatment method which is limited to level/gently-sloping smooth-surface 

terrain. Treatment timing is critical, and must be conducted for several consecutive years.

National Environmental Policy Act (NEPA) - An Act passed in 1969 to declare a national policy that 

encourages productive and enjoyable harmony between humankind and the environment, promotes efforts 

that prevent or eliminate damage to the environment and biosphere, stimulates the health and welfare of 

humanity, enriches the understanding of the ecological systems and natural resources important to the 

nation, and establishes a Council on Environmental Quality. 

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National Forest Management Act (NFMA) - A law passed in 1976 as an amendment to the Forest and 

Rangeland Renewable Resources Planning Act, requiring preparation of Forest Plans and the preparation 

of regulations to guide that development. 

National Marine Fisheries Service (NMFS) - The federal agency that is the listing authority for marine 

mammals and anadromous fish under the ESA. 

National Pollutant Discharge Elimination System (NPDES) - As authorized by the Clean Water Act, the 

National Pollutant Discharge Elimination System (NPDES) permit program controls water pollution by 

regulating point sources that discharge pollutants into waters of the United States. Point sources are 

discrete conveyances such as pipes or man-made ditches. Individual homes that are connected to a 

municipal system, use a septic system, or do not have a surface discharge do not need an NPDES permit; 

however, industrial, municipal, and other facilities must obtain permits if their discharges go directly to 

surface waters. 

National Wilderness Preservation System (NWPS) - The Wilderness Act of 1964 established the national 

Wilderness Preservation System to ensure that certain federally owned areas in the United States would 

be preserved and protected in their natural condition. The Act defines a wilderness area, in part, as an area 

which generally appears to have been affected primarily by the forces of nature, with the imprint of man’s 

work substantially unnoticeable. Areas included in the system are administered for the use and enjoyment 

of the American people in such manner as to leave them unimpaired for future use and enjoyment as 

wilderness.

Native species - With respect to a particular ecosystem, a species that, other than as a result of an 

introduction, historically occurred or currently occurs in that ecosystem (Executive Order 13122, 2/3/99). 

Neotropical migrants birds - Birds that migrate from North America to regions south of the Tropic of 

Cancer (latitude 23 1/2 degrees north) to winter. 

Non-target species - Any plant or animal that is not the intended organism to be controlled by a pesticide 

treatment.

No-Observed-Adverse-Effect level (NOAEL) - Exposure level at which there are no statistically or 

biological significant differences in the frequency or severity of any adverse effect in the exposed or 

control populations

No-Observed-Effect-Level (NOEL) - Exposure level at which there are no statistically or biological 

significant differences in the frequency or severity of any effect in the exposed or control populations.

Noxious weed - “Any living stage (including but not limited to, seeds and reproductive parts) of any 

parasitic or other plant of a kind, or subdivision of a kind, which is of foreign origin, is new to or not 

widely prevalent in the United States, and can directly or indirectly injure crops, other useful plants, 

livestock, or poultry or other interests of agriculture, including irrigation, or navigation or the fish and 

wildlife resources of the United States or the public health” (Public Law 93-629, January 3, 1975, Federal 

Noxious Weed Act of 1974).

Omnivore - An animal that feeds on both plants and animals.

Outstandingly Remarkable Value (ORV) - A characteristic of rivers or sections of rivers in the national 

Wild and Scenic River System. In order for a river to be included in the system, it must possess at least 

one “outstandingly remarkable” value, such as scenic, recreational, geologic, fish, wildlife, historic, 

cultural, or other similar features. Outstandingly Remarkable Values are values or opportunities in a river 

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corridor which are directly related to the river and which are rare, unique, or exemplary from a regional or 

national perspective.

Partial Retention - A visual quality objective which in general means human activities may be evident but 

must remain subordinate to the characteristic landscape.

Pathogen - A living organism, typically a bacteria or virus that causes adverse effects in another organism.

Percolation - Downward flow or filtering of water through pores or spaces in rock or soil. 

Perennial Plant- A plant species having a life span of more than 2 years.

Persistence - Refers to the length of time a compound, once introduced into the environment, stays there. 

Personal Protective Equipment (PPE) - Clothing and equipment worn by herbicide mixers, loaders and 

applicators and re-entry workers worn to reduce their exposure to potentially hazardous chemicals and 

other pollutants.

Pest - An insect, rodent, nematode, fungus, weed or other form of terrestrial or aquatic plant or animal life 

that is classified as undesirable because it is injurious to health or the environment. 

Pesticide - Any substance used for controlling, preventing, destroying, repelling, or mitigating any pest. 

Includes fungicides, herbicides, fumigants, insecticides, nematicides, rodenticides, desiccants, defoliants, 

plant growth regulators, etc.

pH - The negative log of the hydrogen ion concentration. A high pH (greater than 7) is alkaline or basic 

and a low pH (less than 7) is acidic.

Population - A group of individuals of the same species in an area.

Project “Caps” – Limitations on the acreage that may be treated annually and through the life of the 

project. 

Proposed species - Any plant or animal species that is proposed by the Fish and Wildlife Service or 

NOAA Fisheries in a Federal Register notice to be listed as threatened or endangered.

Recreational Rivers - A classification within the national Wild and Scenic River System. Recreational 

rivers are those rivers, or sections of rivers, that are readily accessible by road or railroad, that may have 

some development along their shorelines, and that may have undergone some impoundment or diversion 

in the past.

Redd –A spawning nest made by a fish, especially a salmon or trout. 

Reference Dose (RfD) - The RfD is a numerical estimate of a daily exposure to the human population, 

including sensitive subgroups such as children, that is not likely to cause harmful effects during a lifetime. 

RfDs are generally used for health effects that are thought to have a threshold or minimum dose for 

producing effects. 

Registered Pesticides - Pesticide products which have been approved for the uses listed on the label. 

Restoration - Ecological restoration is the process of assisting the recovery and management of ecological 

integrity. Ecological integrity includes a critical range of variability in biodiversity, ecological processes 

and structures, regional and historical context, and sustainable cultural practices. Restoration may be 

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passive (passing of time to allow for site recovery) or active (in this project, active restoration includes 

seeding, mulching and planting after invasive plants are removed). 

Revegetation - The re-establishment of plants on a site - The term does not imply native or non-native; 

does not imply that the site can ever support any other types of plants or species and is not at all 

concerned with how the site ‘functions’ as an ecosystem.

Riparian Area (or zone) - Those terrestrial areas where the vegetation complex and microclimate 

conditions are products of the combined presence and influence of perennial and/or intermittent water, 

associated high water tables, and soils that exhibit some wetness characteristics. Normally used to refer to 

the zone within which plants grow rooted in the water table of these rivers, streams, lakes, ponds, 

reservoirs, springs, marshes, seeps, bogs, and wet meadows.

Riparian Reserve - Areas along live and intermittent streams, wetlands, ponds, lakes, and unstable and 

potentially unstable areas where riparian-dependent resources receive primary emphasis. Riparian 

Reserves are important to the terrestrial ecosystem as well, serving as dispersal habitat for certain 

terrestrial species.

Risk - The chance of an adverse or undesirable effect, often measured as a percentage.

Risk Assessment - The qualitative and quantitative evaluation performed in an effort to estimate the risk 

posed to human health and/or the environment by the presence or potential presence and/or use of specific 

chemical or biological agents.

Scenic Rivers - A classification within the national Wild and Scenic River System. Scenic rivers are those 

rivers, or sections of rivers, that are free of impoundments, with shorelines or watersheds still largely 

primitive and shorelines largely undeveloped, but accessible in places by roads.

Security habitat - Habitat defined as 0.25 mile from open road or outside of human influence zones for 

mountain goats, 0.3 mile for grizzly bear core and wolf security habitat. 

Sensitive Species – Sensitive species are identified by a Regional Forester for which population viability 

is a concern, as evidenced by significant current or predicted downward trends in population numbers or 

density and habitat capability that would reduce a species’ existing distribution (FSM 2670.5). 

Management of sensitive species “must not result in a loss of species viability or create significant trends 

toward federal listing” (FSM 2670.32). 

Seral -Of or pertaining to the series of stages in the process of ecological succession.

Spawn - to deposit fish eggs or sperm directly into the water.

Species of Conservation Concern (aka Concern Species) - Threatened, endangered and proposed species; 

Regional Forester’s Sensitive species, management indicator species, and other identified native species 

of concern to biologists on the MBS. 

Species - “A group of organisms, all of which have a high degree of physical and genetic similarity, 

generally interbreed only among themselves, and show persistent differences from members of allied 

groups of organisms.” (Executive Order 13122, 2/3/99).

Spot application - Herbicide treatment involving use of a backpack sprayer or other means. Application is 

aimed at specific target species, with methods of prevention (such as barriers) to control damage to nontarget species.

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Standards and guidelines - The rules and limits governing actions, as well as the principles specifying the 

environmental conditions or levels to be achieved and maintained.

Stock —The fish spawning in a particular lake or stream(s) at a particular season, which fish to a 

substantial degree do not interbreed with any group spawning in a different place, or in the same place at 

a different season.

Suitable habitat - Habitat in which an animal or plant can meet all or some of its life history requirements.

Surface water - All water naturally open to the atmosphere (rivers, lakes, reservoirs, streams, 

impoundments, seas, estuaries, etc.) and all springs, wells, or other collectors which are directly 

influenced by surface water.

Surfactant - A surface active agent; usually an organic compound whose molecules contain a hydrophilic 

group at one end and a lipophilic group at the other. Promotes solubility of a chemical, or lathering, or 

reduces surface tension of a solution. 

Synergistic effect - Situation in which the combined effects of exposure to two chemicals simultaneously 

is much greater than the sum of the effect of exposure to each chemical given alone.

Take - "The term 'take' means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or 

to attempt to engage in any such conduct" (Title 16, Chapter 35, Section 1532, Endangered Species Act of 

1973). 

Threatened species - Plant or animal species likely to become endangered throughout all, or a significant 

portion of, its range within the foreseeable future. A plant or animal identified and defined in accordance 

with the 1973 Endangered Species Act and published in the Federal Register. 

Threshold of Concern - The maximum dose or concentration level of a chemical or biological agent that 

will not cause an effect in the organism.

Toxicity - The inherent ability of an agent to affect living organisms adversely. Toxicity is the degree to 

which a substance or mixture of substances can harm humans or animals.

Toxicology - The study of the nature, effects, and detection of poisons in living organisms. Also, 

substances that are otherwise harmless but prove toxic under particular conditions. The basic assumption 

of toxicology is that there is a relationship among the dose (amount), the concentration at the affected site, 

and the resulting effects.

Treatment Objectives: Treatment objectives reflect the desired outcome depending on the extent, 

distribution and priority for treating a given invasive plant species. 

§ Eradicate: Eliminate an invasive plant species from a site. This objective generally applies to 

species that are difficult to control and cover small areas. Some occurrences may be on 

roadsides (Russian knapweed, squarrose knapweed) and others may occur in intact native 

vegetation (yellow starthistle, small occurrences of thistles or knapweed, new invaders). This 

is generally our first priority for treatment.

§ Control: Reduce the size of the infestation over time; some level of infestation may be 

acceptable. This objective applies to most of the target species (houndstongue, leafy spurge, 

perennial pepperweed, sulfur cinquefoil, whitetop) and large infestations of thistles and 

knapweeds. This is generally our second priority for treatment. 

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§ Contain: Prevent the spread of the weed beyond the perimeter of patches or infestation areas 

mapped from current inventories. This objective applies to target species such as common St. 

Johnswort. This is generally our third priority for treatment. 

§ Suppress: Prevent seed production throughout the target patch and reduce the area coverage. 

Prevent the invasive species from dominating the vegetation of the area; low levels may be 

acceptable. This objective applies to target species such as toadflax that would be treated 

mainly with biocontrol agents. This is generally our fourth priority for treatment. 

§ Tolerate: Accept the continued presence of established infestations and the probable spread to 

ecological limits for certain species. This category is for species that are so widespread and 

abundant that other objectives would be extremely difficult to meet. This category includes 

species such as cheatgrass, medusahead, North Africa grass, dandelion, mullein, and bulbous 

bluegrass. These invasive plants have low priority for treatment and would likely only be 

treated if they happen to be near one of the primary target species.

Tribal and Treaty Rights - Native American treaty and other rights or interests recognized by treaties, 

statutes, laws, executive orders, or other government action, or federal court decisions. 

Unknown Stock – A description applied to stocks where there is insufficient information to identify stock 

origin or stock status with confidence. 

U.S. Fish and Wildlife Service (United States Department of the Interior Fish and Wildlife Service, USDI 

FWS, USFWS) - The federal agency that is the listing authority for species other than marine mammals 

and anadromous fish under the Endangered Species Act. 

USDA Forest Service (United States Department of Agriculture Forest Service, FS or USFS) - The federal 

agency responsible for management of the Nation’s National Forest System lands

Viability - Ability of a wildlife or plant population to maintain sufficient size to persist over time in spite 

of normal fluctuations in numbers, usually expressed as a probability of maintaining a specific population 

for a specified period. 

Viable Population - A wildlife or plant population that contains an adequate number of reproductive 

individuals appropriately distributed on the planning area to ensure the long-term existence of the species.

Viewshed - Total visible area from a single observer position, or the total visible area from multiple 

observer position. Viewsheds are accumulated seen-areas from highways, trails, campgrounds, towns, 

cities, or other viewer locations. Examples are corridor, feature, or basin viewsheds.

Visual Quality Objective - A desired level of excellence based on physical and sociological characteristics 

of an area. Refers to degree of acceptable alteration of the characteristic landscape.

Waterline – the edge of surface water at the current time.

Well-distributed population- Distribution sufficient to permit normal biological function and species 

interactions, considering life history characteristics of the species and the habitats for which it is 

specifically adapted.

Wetland - An area that is regularly saturated by surface or ground water and subsequently is characterized 

by a prevalence of vegetation that is adapted for life in saturated soil conditions. Examples include 

swamps, bogs, fens, marshes, and estuaries.

287 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Chapter 5

Wild and Scenic River System - The Wild and Scenic Rivers Act of 1968 established a system of selected 

rivers in the United States, which possess outstandingly remarkable values, to be preserved in freeflowing condition. Within the national system of rivers, three classifications define the general character 

of designated rivers: Wild, Scenic, and Recreational. Classifications reflect levels of development and 

natural conditions along a stretch of river. Classifications are used to help develop management goals for 

the river.

Wilderness - Areas designated by Congressional action under the 1964 Wilderness Act. Wilderness is 

defined as undeveloped federal land retaining its primeval character and influence without permanent 

improvements or human habitation. Wilderness areas are protected and managed to preserve their natural 

conditions, which generally appear to have been affected primarily by the forces of nature with the 

imprint of human activity substantially unnoticeable; have outstanding opportunities for solitude or for a 

primitive and confined type of recreation; include at least 5,000 acres, or are of sufficient size to make 

practical their preservation, enjoyment, and use in an unimpaired condition; and may contain features of 

scientific, educational, scenic, or historical value as well as ecological and geologic interest.

Wild Rivers - A classification within the national Wild and Scenic River System. Wild rivers are those 

rivers, or sections of rivers that are free of impoundments and generally inaccessible except by trail, with 

watersheds or shorelines essentially primitive and waters unpolluted.

Wolf rendezvous sites - Temporary resting sites used for several days at a time by a wolf pack during 

summer months while the pups are developing.

288 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Chapter 5

5.3 Index 

A

American Marten, 131, 132, 250

Aquatic Conservation Strategy, v, 4, 180, 186, 221

B

Bald Eagle, 125, 127, 131, 146, 150, 267, 270

Broadwhorl Tightcoil, 126, 129, 151

C

Climate, 72, 136, 176, 273

Climate Change, 72

Common Loon, 125, 126, 145, 150, 259

Critical Habitat, 120, 122, 123, 139, 142, 143, 199, 200, 

201, 202, 203, 217, 218, 277

Cumulative Effects, 81, 83, 87, 95, 106, 115, 155, 171, 194, 

197, 216, 219, 232, 240, 246, 255

D

Decision Framework, 9

Desired Condition, 2

Domestic Water, 180

E

Early Detection Rapid Response, 23, 40, 171

Environmental Justice, 103, 240

Essential Fish Habitat, 205, 208, 217, 218, 224, 260, 278

F

Federally Listed Fish Species, 198, 202

Forest Plan, iii, v, 1, 2, 3, 4, 6, 1, 2, 3, 4, 6, 9, 10, 11, 12, 20, 

21, 25, 26, 45, 52, 54, 55, 57, 96, 101, 106, 108, 115, 

117, 118, 131, 134, 137, 138, 158, 159, 173, 174, 180, 

197, 208, 223, 225, 228, 230, 240, 268, 269, 283

G

Gray Wolf, 120, 124, 131, 144

Grizzly Bear, 8, 120, 123, 131, 144, 263, 264

H

Harlequin Duck, 125, 127, 147, 150

Heritage Resources, 7, 22, 39, 58, 233, 239, 240, 245

I

Issues, 2, 10, 76 

K

Key Watershed, 180, 181, 223

L

Larch Mountain Salamander, 125, 127, 133, 148, 150

M

Management Indicator Species, 118, 120, 131, 132, 138, 

151, 158, 207, 225, 269

Marbled Murrelet, 120, 122, 123, 139, 142, 156, 255, 270, 

271 

Monitoring, 42

Mountain Goat, 5, 126, 129, 149, 151

Municipal Watersheds, 180

N

Non-target Vegetation, 114

Northern Spotted Owl, 4, 120, 121, 122, 131, 139, 156, 

267, 268, 270, 271

P

Peregrine Falcon, 125, 126, 131, 145, 150, 261

Pileated Woodpecker, 132, 151

prevention, 5

Primary Cavity Excavators, 132, 152, 154

Public Involvement, 10

Puget Oregonian, 133, 152

Purpose and Need, 1, 2

R

Riparian Reserves, 4, 35, 181, 285

Risk Assessment, 266

S

Sediment, 178, 179, 186, 196, 208, 224, 257

Sensitive Aquatic Species, 206

Sensitive Species, 109, 118, 120, 125, 131, 136, 144, 150, 

153, 157, 198, 206, 269, 279, 285

Shiny Tightcoil, 126, 130, 149, 151

Species of Conservation Concern, 109, 198, 285

Survey and Manage, 4, 109, 118, 133, 134, 152, 158

T

Temperature, 178, 179, 186, 224, 250, 257, 258, 261

289 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Chapter 5

Threatened, Endangered, Sensitive, and Management 

Indicator Species, 120

Treatment Analysis Area, 10, 63, 64, 65, 66, 70, 108, 109, 

115, 174, 181, 227, 228, 238, 239

Turbidity, 179, 186, 187

V

Valley Silverspot, 126, 131, 150, 151, 255

Van Dyke’s Salamander, 125, 128, 133, 148, 150

W

Water Quality, 35, 173, 177, 179, 186, 190, 195, 197, 224, 

258, 267, 268, 269, 272

Water Quality Limited, 173

Watershed, 5, 7, 9, 66, 173, 174, 180, 181, 189, 204, 257, 

258, 261, 268

Wolverine, 120, 126, 129, 148, 150, 250

290 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix A 

Appendix A - Treatment Analysis Area Atlas Example

Appendix A provides information about Treatment Analysis Area 11 to demonstrate the type of 

information available for each Treatment Analysis Area. Maps and information about all of the Treatment 

Analysis Areas on the MBS are available online at: 

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=34208. 

For each treatment analysis area, total infested acreage within the Treatment Analysis Area (TAA), a 

description of the area, and the 5th field watershed within which the TAA resides are identified. Infested 

acreage is the sum of acreage for each species (please note that about 20 percent of the sites overlap 

within the project area and these overlaps are not accounted for in the acreage total). 

For each mapped invasive plant (NRIS) site, the species, name of the site, acreage, treatment objective 

(contain, control, or eradicate), and first year/first choice treatment to meet the objective is designated. 

The first year/first choice treatment method in this example and in the full TAA atlas is based on the 

Proposed Action.

Maps have been developed to show each NRIS site within a Treatment Analysis Area. 

Treatment Analysis Area: 11

Treatment Analysis Area Name: I-90 Corridor in King County

Infested acres: 114.8 

Description: Upper South Fork of Snoqualmie River watershed from about McClellan Butte east to the 

county line. Although the polygon encompasses I-90 is, the treatment sites do not include the I-90 road 

prism itself, which is the responsibility of WSDOT and the Federal Highway Department. 

5th Field Watershed: South Fork Snoqualmie River 171100103 

Table A- 1. Invasive Plant Species Mapped Within Treatment Analysis Area 11

Species NRIS ID Site Name

2012 

approximate 

Infested

Acres

Objective

First Year/First Choice 

Treatment Method for 

the Proposed Action

(in parenthesis if method 

is already approved)

orange hawkweed 6050500016 Alpental roads 9040 

& PCT lots 2.4 eradicate aminopyralid

spotted knapweed 6050500023 Granite Mtn.

trailhead 0.3 eradicate aminopyralid

orange hawkweed 6050500024 Alpental ski area 0.2 control aminopyralid

Bohemian knotweed 6050500060 Road 9031 milepost 

2.8 0.8 eradicate

(imazapyr/glyphosateaquatic)

absinth wormwood 6050500062 Denny Creek Road 2.2 control aminopyralid

orange hawkweed 6050500071 Denny Creek Road 13.6 control aminopyralid

meadow hawkweed 6050500072 Denny Creek Road 13.6 control aminopyralid

common hawkweed 6050500073 Denny Creek Road 3.3 control aminopyralid

yellow archangel 05-AR-073 Denny Ck Rec Res 

#4 0.1 eradicate (glyphosate-aquatic)

291 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Appendix A

Species NRIS ID Site Name

2012 

approximate 

Infested

Acres

Objective

First Year/First Choice 

Treatment Method for 

the Proposed Action

(in parenthesis if method 

is already approved)

spotted knapweed 05-DL-001 Asahel Curtis 

trailhead 0.3 eradicate aminopyralid

Bohemian knotweed 05-KB-049

Mason Ck; Menke 

acquisition(a.k.a. I90 Exit42)0.7

eradicate

(imazapyr/

glyphosate-aquatic)

Scotch broom 05-KM-007 Bandera/Rd 

5510&110 spur 4.0 contain aminopyralid

Scotch broom 05-KM-008 Bandera; Rd 5510-

160 5.0 contain broadcast-aminopyralid

Scotch broom 05-KM-077 Road 9030 3.0 control broadcast-aminopyralid

dalmatian toadflax 05-KM-078 RR tracks @ 

Humpback Ck 8.7 control chlorsulfuron

orange hawkweed 05-KM-079

"I-90 below 

underpass, Wbound 

lanes

0.8

control

aminopyralid

tansy ragwort 05-KW-002 Pratt R. stockpile/ 

borrow pit 0.2 eradicate aminopyralid

herb Robert 05-KW-003 Pratt R. stockpile/ 

borrow pit 0.2 eradicate glyphosate

sulphur cinquefoil 05-KW-004 Pratt R. stockpile/ 

borrow pit 0.2 eradicate metsulfuron methyl

Scotch broom 05-KW-005 Pratt R. stockpile/ 

borrow pit 0.2 eradicate (hand-pull) 

orange hawkweed 05-KW-006 Pratt R. stockpile/ 

borrow pit 0.2 eradicate aminopyralid

spotted knapweed 05-KW-007 Pratt R. stockpile/ 

borrow pit 0.2 eradicate aminopyralid

Scotch broom 05-KW-013 John Wayne Trail 0.6 control (hand-pull)

dalmatian toadflax 05-KW-014 John Wayne Trail 0.6 control chlorsulfuron

spotted knapweed 05-KW-015 John Wayne Trail 0.1 eradicate aminopyralid

sulphur cinquefoil 05-KW-022 McClellan Butte 

Trailhead 0.1 eradicate metsulfuron methyl

herb Robert 05-KW-023 Tinkham 

Campground 9.6 eradicate (hand-pull) 

tansy ragwort 05-KW-024 S Fk Snoqualmie 

Gravel Bars 1.9 contain aminopyralid

spotted knapweed 05-KW-025 S Fk Snoqualmie 

Gravel Bars 1.9 control aminopyralid

spotted knapweed 05-KW-026 Snow Lake parking 

lot 7.2 eradicate aminopyralid

orange hawkweed 05-KW-027 Snow Lake 

Trailhead 0.1 eradicate aminopyralid

tansy ragwort 05-KW-037 Rd 5510-310 0.1 contain aminopyralid

woolly hedgenettle 05-KW-038 Rd 5510-410, sec 

21 0.1 eradicate glyphosate

292 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Appendix A

Species NRIS ID Site Name

2012 

approximate 

Infested

Acres

Objective

First Year/First Choice 

Treatment Method for 

the Proposed Action

(in parenthesis if method 

is already approved)

tansy ragwort 05-KW-039 Rd 5510 Hansen 

Creek 0.1 contain (hand-pull) 

spotted knapweed 05-KW-040 Rd 5510-410, sec 

28 0.1 eradicate (hand-pull) 

Bohemian knotweed 05-LP-021 Mason Lake Rd 0.1 eradicate

(imazapyr/glyphosateaquatic)

dalmatian toadflax 05-LP-083 I-90 m.p. 38 to MBS 

boundary 13.1 control chlorsulfuron

meadow knapweed 05-TF-001 Road 5800 0.1 eradicate aminopyralid

tansy ragwort 05-TF-002 Road 5800 0.1 contain (hand-pull) 

spotted knapweed 05-TF-003 Road 5800 East 

(revisit) 13.6 control aminopyralid

orange hawkweed 05-TF-004 Road 5800/9040 

junction 0.1 control aminopyralid

herb Robert 05-TF-005 McClellan Butte TH 1.9 eradicate (glyphosate-aquatic)

spotted knapweed 05-TF-006 McClellan Butte TH 1.9 eradicate (hand-pull) 

common hawkweed 05-TF-015 Road 9020 0.1 control aminopyralid

Scotch broom 05-TF-016 Road 9020, 

milepost 7.6 0.1 control aminopyralid

yellow archangel 05-TF-023 Denny Ck Rec Res 

#4 0.1 eradicate (glyphosate-aquatic)

Bohemian knotweed 05-TF-040 9030 Rd 0.1 eradicate imazapyr/glyphosate

dalmatian toadflax 05-TF-076 Pratt R. stockpile/ 

borrow pit 0.2 eradicate chlorsulfuron

orange hawkweed 05-VW-074 Commonwealth 

Campground 0.6 eradicate aminopyralid

293 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Appendix A

Figure A -1. Treatment Analysis Area 11 Overview Map

294 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Appendix A

Figure A -2. Map of Treatment Analysis Area 11 Eastern Portion

295 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Appendix A

Figure A -3. Map of Treatment Analysis Area 11 Central Portion

296 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS –Appendix A

Figure A -4. Map of Treatment Analysis Area 11 Western Portion 

297 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix A 

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298 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B 

Appendix B – Restoration/Revegetation Strategy for 

Each Infested Site

Revegetation of treated invasive plant sites is proposed for the action alternatives, based on the following 

assumptions: Revegetation might not occur after first year if we are going to repeat treatments in 

consecutive years. Planting or seeding will be timed to avoid any temporary risk that might be impact 

desirable species according to label specifications, and/or the species being planted is not affected by the 

herbicide being used (e.g. grasses being used for revegetation in area where the herbicide only targets 

composites). 

Each treatment site is classified into one of five categories: 

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

species (or desirable non-natives (e.g. lawns in administrative sites) in the immediate vicinity to 

colonize once the weeds are killed. Site types include vegetated road shoulders, small areas in 

forested sites. 

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

relevant/inappropriate. Not desirable because the area is naturally unvegetated such as a gravel bar. 

Not realistic if the area is constantly being graded or cleared such as boneyards or gravel pits. 

Inappropriate in cases such as a tree climbing vine like ivy or clematis where it would be 

inappropriate to replace the tree climbing species with a different species. 

12. 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). 

13. Plant Rooted Stock. For specific restoration projects, or where the weed has to be excavated in order 

to control it (where first-choice/first-year treatment is dig or where there’s big areas of shrub-like 

weeds). Some sites are already treated and planted. 

14. Planted. Past tense. Some examples include portions of Marblemount Boat Launch, Ovenell 

property, Kaaland acquisition, Skiyou Island. 

299 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B 

Table B- 1. Invasive plant species location and revegetation strategy

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation Strategy 

TAA 01 Evans Creek tansy ragwort 05-LP-037 Rd 7920 Sec 8 passive

TAA 01 Evans Creek tansy ragwort 05-LP-038 Rd 7920 Sec 19 passive

TAA 02 W Fk White River spotted knapweed 6050500078 Rd 7400-130 staging passive

TAA 02 W Fk White River bull thistle 6050500163 Upper White, Rd 7400-050 passive

TAA 02 W Fk White River Canada thistle 6050500164 Upper White, Rd 7510-410 passive

TAA 02 W Fk White River common hawkweed 6050500165 Upper White, Rd 7510-410 passive

TAA 02 W Fk White River Canada thistle 6050500166 Upper White, Rd 7510-710 passive

TAA 02 W Fk White River common hawkweed 6050500167 Upper White, Rd 7510-710 passive

TAA 02 W Fk White River Canada thistle 6050500168 Upper White, Rd 7510-300 passive

TAA 02 W Fk White River Canada thistle 6050500169 Upper White, Rd 7510-310 passive

TAA 02 W Fk White River common hawkweed 6050500170 Upper White, Rd 7510-310 passive

TAA 02 W Fk White River Canada thistle 6050500183 Upper White, Rd 7400-050 passive

TAA 02 W Fk White River Canada thistle 6050500193 Upper White, Rd 7315-310 passive

TAA 02 W Fk White River Canada thistle 6050500194 Upper White, Rd 7315-310 passive

TAA 02 W Fk White River Canada thistle 6050500195 Upper White, Rd 7315-310 Seed and Mulch

TAA 02 W Fk White River bull thistle 6050500196 Upper White, Rd 7315-310 passive

TAA 02 W Fk White River bull thistle 6050500197 Upper White, Rd 7315-310 passive

TAA 02 W Fk White River bull thistle 6050500198 Upper White, Rd 7315-310 passive

TAA 02 W Fk White River herb Robert 6050500200 Upper White, Rd 7315-310 passive

TAA 02 W Fk White River Canada thistle 6050500203 Upper White, Rd 7322 passive

TAA 02 W Fk White River Canada thistle 6050500204 Upper White, Rd 7322 passive

TAA 02 W Fk White River bull thistle 6050500205 Upper White, Rd 7322 passive

TAA 02 W Fk White River bull thistle 6050500206 Upper White, Rd 7322 passive

TAA 02 W Fk White River Scotch broom 6050500207 Upper White, Rd 7322 passive

TAA 02 W Fk White River Himalayan blackberry 6050500208 Upper White, Rd 7322 Plant rooted stock

TAA 02 W Fk White River Canada thistle 6050500210 Upper White, Rd 7500-246 passive

TAA 02 W Fk White River bull thistle 6050500211 Upper White, Rd 7500-246 passive

TAA 02 W Fk White River common hawkweed 6050500212 Upper White, Rd 7500-241 passive

TAA 02 W Fk White River Canada thistle 6050500213 Upper White, Rd 7500-412 passive

TAA 02 W Fk White River bull thistle 6050500214 Upper White, Rd 7500-412 passive

TAA 02 W Fk White River common hawkweed 6050500215 Upper White, Rd 7500-410 passive

TAA 02 W Fk White River Canada thistle 6050500216 Upper White, Rd 7500-410 passive

TAA 02 W Fk White River bull thistle 6050500217 Upper White, Rd 7500-430 passive

TAA 02 W Fk White River Canada thistle 6050500218 Upper White, Rd 7500-430 passive

300 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 02 W Fk White River Canada thistle 6050500219 Upper White, Rd 7500-510 passive

TAA 02 W Fk White River bull thistle 6050500220 Upper White, Rd 7500-550 passive

TAA 02 W Fk White River common hawkweed 6050500221 Upper White, Rd 7500-550 passive

TAA 02 W Fk White River Canada thistle 6050500237 Upper White Unit 3 passive

TAA 02 W Fk White River common hawkweed 6050500238 Upper White Unit 3 passive

TAA 02 W Fk White River bull thistle 6050500239 Upper White Unit 3 passive

TAA 02 W Fk White River bull thistle 6050500240 Upper White Unit 4 passive

TAA 02 W Fk White River bull thistle 6050500241 Upper White Unit 4 passive

TAA 02 W Fk White River Canada thistle 6050500242 Upper White Unit 4 passive

TAA 02 W Fk White River Canada thistle 6050500243 Upper White Unit 4 passive

TAA 02 W Fk White River herb Robert 6050500244 Upper White Unit 4 passive

TAA 02 W Fk White River common hawkweed 6050500245 Upper White Unit 4 passive

TAA 02 W Fk White River tansy ragwort 6050500246 Upper White Unit 4 passive

TAA 02 W Fk White River bull thistle 6050500252 Upper White Unit 11 passive

TAA 02 W Fk White River Canada thistle 6050500255 Upper White Unit 12 passive

TAA 02 W Fk White River Canada thistle 6050500257 Upper White Unit 12 passive

TAA 02 W Fk White River bull thistle 6050500258 Upper White Unit 14 passive

TAA 02 W Fk White River bull thistle 6050500259 Upper White Unit 14 passive

TAA 02 W Fk White River bull thistle 6050500260 Upper White Unit 14 passive

TAA 02 W Fk White River Canada thistle 6050500261 Upper White Unit 14 passive

TAA 02 W Fk White River herb Robert 6050500263 Upper White Unit 14 passive

TAA 02 W Fk White River bull thistle 6050500264 Upper White Unit 15 passive

TAA 02 W Fk White River Canada thistle 6050500265 Upper White Unit 16 passive

TAA 02 W Fk White River Canada thistle 6050500276 Upper White Unit 16 passive

TAA 02 W Fk White River Canada thistle 6050500277 Upper White Unit 16 passive

TAA 02 W Fk White River common tansy 6050500279 Upper White Unit 16 passive

TAA 02 W Fk White River bull thistle 6050500280 Upper White Unit 16 passive

TAA 02 W Fk White River cutleaf blackberry 6050500281 Upper White Unit 17 passive

TAA 02 W Fk White River Canada thistle 6050500282 Upper White Unit 17 passive

TAA 02 W Fk White River Canada thistle 6050500283 Upper White Unit 17 passive

TAA 02 W Fk White River Canada thistle 6050500284 Upper White Unit 19 passive

TAA 02 W Fk White River Scotch broom 6050500285 Upper White Unit 19 passive

TAA 02 W Fk White River Canada thistle 6050500287 Upper White Unit 20 passive

TAA 02 W Fk White River Canada thistle 6050500288 Upper White Unit 21 passive

TAA 02 W Fk White River Canada thistle 6050500289 Upper White Unit 21 passive

TAA 02 W Fk White River Canada thistle 6050500295 Upper White Unit 21 passive

301 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 02 W Fk White River bull thistle 6050500296 Upper White Unit 22 passive

TAA 02 W Fk White River Canada thistle 6050500298 Upper White Unit 23 passive

TAA 02 W Fk White River Canada thistle 6050500307 Upper White Unit 23 passive

TAA 02 W Fk White River Scotch broom 6050500310 Upper White Unit 23 passive

TAA 02 W Fk White River Scotch broom 6050500311 Upper White Unit 24 passive

TAA 02 W Fk White River Scotch broom 6050500315 Upper White Unit 24 passive

TAA 02 W Fk White River common groundsel 6050500316 Upper White Unit 24 passive

TAA 02 W Fk White River Canada thistle 6050500317 Upper White Unit 24 passive

TAA 02 W Fk White River bull thistle 6050500318 Upper White Unit 26 passive

TAA 02 W Fk White River bull thistle 6050500319 Upper White Unit 26 passive

TAA 02 W Fk White River Scotch broom 6050500320 Upper White Unit 26 passive

TAA 02 W Fk White River Canada thistle 6050500321 Upper White Unit 26 passive

TAA 02 W Fk White River herb Robert 6050500322 Upper White Unit 26 passive

TAA 02 W Fk White River common hawkweed 6050500323 Upper White Unit 26 passive

TAA 02 W Fk White River common groundsel 6050500324 Upper White Unit 26 passive

TAA 02 W Fk White River Canada thistle 6050500325 Upper White Unit 27 passive

TAA 02 W Fk White River tansy ragwort 6050500326 Upper White Unit 28 passive

TAA 02 W Fk White River Canada thistle 6050500327 Upper White Unit 28 passive

TAA 02 W Fk White River Scotch broom 6050500331 Upper White Unit 28 passive

TAA 02 W Fk White River Scotch broom 6050500332 Upper White Unit 28 passive

TAA 02 W Fk White River Scotch broom 6050500333 Upper White Unit 28 passive

TAA 02 W Fk White River Canada thistle 6050500334 Upper White Unit 29 passive

TAA 02 W Fk White River bull thistle 6050500335 Upper White Unit 29 passive

TAA 02 W Fk White River Scotch broom 6050500336 Upper White Unit 29 passive

TAA 02 W Fk White River common hawkweed 6050500337 Upper White Unit 29 passive

TAA 02 W Fk White River Canada thistle 6050500338 Upper White Unit 30 passive

TAA 02 W Fk White River Canada thistle 6050500339 Upper White Unit 30 passive

TAA 02 W Fk White River common hawkweed 6050500341 Upper White Unit 30 passive

TAA 02 W Fk White River bull thistle 6050500342 Upper White Unit 30 passive

TAA 02 W Fk White River herb Robert 6050500343 Upper White Unit 33 passive

TAA 02 W Fk White River herb Robert 6050500344 Upper White Unit 33 passive

TAA 02 W Fk White River bull thistle 6050500347 Upper White Unit 35 passive

TAA 02 W Fk White River Canada thistle 6050500348 Upper White Unit 37 passive

TAA 02 W Fk White River bull thistle 6050500349 Upper White Unit 37 passive

TAA 02 W Fk White River meadow knapweed 05-LP-039 Road 74, mp 4.5 to Rd 75 jct passive

TAA 02 W Fk White River spotted knapweed 05-LP-084 Rd 74, mp 4.5 to Rd 75 jct Seed and Mulch

302 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 02 W Fk White River tansy ragwort 05-TF-020 Rd 74, mp 4.5 to Rd 75 jct Seed and Mulch

TAA 02 W Fk White River diffuse knapweed 05-TF-021 Road 74, mp 4.5 to Rd 75 jct Seed and Mulch

TAA 02 W Fk White River tansy ragwort 05-TF-022 Rd 74, mp 2.6 & beyond passive

TAA 02 W Fk White River Scotch broom 05-VW-058 Rd 74, mp 2.6 & beyond passive

TAA 02 W Fk White River meadow knapweed 05-VW-059 Road 74 near Thirsty Ck passive

TAA 02 W Fk White River Scotch broom 05-VW-061 Road 74 passive

TAA 02 W Fk White River Scotch broom 05-VW-062 Road 74 passive

TAA 02 W Fk White River Scotch broom 05-VW-063 Road 7415-405 passive

TAA 02 W Fk White River tansy ragwort 05-VW-064 Road 75 passive

TAA 02 W Fk White River tansy ragwort 05-VW-066 Road 74 near watertanks passive

TAA 02 W Fk White River tansy ragwort 05-VW-067 Road 74 near Palisades passive

TAA 02 W Fk White River spotted knapweed 05-VW-077 Road 74 near Thirsty Ck passive

TAA 02 W Fk White River Canada thistle 6050500262 Upper White Unit 14 passive

TAA 02 W Fk White River bull thistle 6050500330 Upper White Unit 28 passive

TAA 02 W Fk White River bull thistle 6050500346 Upper White Unit 34 passive

TAA 03 Greenwater River herb Robert 6050500009 Elk Forage, old spur 7200-

226 passive

TAA 03 Greenwater River tansy ragwort 6050500010 Elk Forage, old spur 7200-

226 passive

TAA 03 Greenwater River bull thistle 6050500011 Elk Forage, Rd 70 @ MP 5 passive

TAA 03 Greenwater River common hawkweed 6050500012 Elk Forage, Rd 70 @ MP 5 passive

TAA 03 Greenwater River Scotch broom 6050500013 Elk Forage, Rd 70 @ MP 5 passive

TAA 03 Greenwater River Scotch broom 6050500018 Lower 28 mile rock pit None

TAA 03 Greenwater River Scotch broom 6050500019 Upper 28 mile stock pile None

TAA 03 Greenwater River common hawkweed 6050500020 Road 70 and 7080 Seed and Mulch

TAA 03 Greenwater River herb Robert 6050500061 Grnwtr Chinook acclimation 

pond passive

TAA 03 Greenwater River Canada thistle 6050500068 Elk Forage Unit 51 passive

TAA 03 Greenwater River Canada thistle 6050500069 Elk Forage Unit 52 passive

TAA 03 Greenwater River Canada thistle 6050500070 Elk Forage Unit 54 passive

TAA 03 Greenwater River spotted knapweed 6050500076 70 Road upper passive

TAA 03 Greenwater River Canada thistle 6050500077 Road 70 &70-210 passive

TAA 03 Greenwater River Canada thistle 6050500079 Elk Forage Unit 55 passive

TAA 03 Greenwater River bull thistle 6050500080 Elk Forage Unit 55 passive

TAA 03 Greenwater River bull thistle 6050500081 Elk Forage Unit 55 passive

TAA 03 Greenwater River spotted knapweed 6050500082 Rd 7030 MP 0.3 passive

303 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 03 Greenwater River Canada thistle 6050500083 Elk Forage Unit 56 passive

TAA 03 Greenwater River bull thistle 6050500084 Elk Forage Unit 56 passive

TAA 03 Greenwater River common hawkweed 6050500085 Elk Forage Unit 56 passive

TAA 03 Greenwater River Canada thistle 6050500086 Elk Forage Unit 58 passive

TAA 03 Greenwater River common hawkweed 6050500087 Elk Forage Unit 58 passive

TAA 03 Greenwater River Canada thistle 6050500088 Elk Forage Unit 59 passive

TAA 03 Greenwater River Scotch broom 6050500089 Elk Forage Unit 59 passive

TAA 03 Greenwater River common hawkweed 6050500090 Elk Forage Unit 59 passive

TAA 03 Greenwater River common hawkweed 6050500091 Elk Forage Unit 59 passive

TAA 03 Greenwater River bull thistle 6050500093 Elk Forage Unit 59 passive

TAA 03 Greenwater River Canada thistle 6050500094 Elk Forage Unit 60 passive

TAA 03 Greenwater River tansy ragwort 6050500095 Elk Forage Unit 60 passive

TAA 03 Greenwater River Canada thistle 6050500096 Elk Forage Unit 62 passive

TAA 03 Greenwater River bull thistle 6050500097 Elk Forage Unit 62 passive

TAA 03 Greenwater River common hawkweed 6050500098 Elk Forage Unit 62 passive

TAA 03 Greenwater River Canada thistle 6050500100 Elk Forage Unit 64 passive

TAA 03 Greenwater River common hawkweed 6050500101 Elk Forage Unit 64 passive

TAA 03 Greenwater River Canada thistle 6050500102 Elk Forage Unit 65 passive

TAA 03 Greenwater River bull thistle 6050500103 Elk Forage Unit 65 passive

TAA 03 Greenwater River Canada thistle 6050500104 Elk Forage Unit 66 passive

TAA 03 Greenwater River bull thistle 6050500105 Elk Forage Unit 66 passive

TAA 03 Greenwater River common groundsel 6050500106 Elk Forage Unit 66 passive

TAA 03 Greenwater River Canada thistle 6050500107 Elk Forage Unit 67 passive

TAA 03 Greenwater River common hawkweed 6050500108 Elk Forage Unit 67 passive

TAA 03 Greenwater River Canada thistle 6050500109 Elk Forage Unit 68 passive

TAA 03 Greenwater River bull thistle 6050500110 Elk Forage Unit 68 passive

TAA 03 Greenwater River herb Robert 6050500111 Elk Forage Unit 68 passive

TAA 03 Greenwater River common hawkweed 6050500112 Elk Forage Unit 68 passive

TAA 03 Greenwater River tansy ragwort 6050500113 Elk Forage Unit 68 passive

TAA 03 Greenwater River Canada thistle 6050500114 Elk Forage Unit 69 passive

TAA 03 Greenwater River bull thistle 6050500115 Elk Forage Unit 69 passive

TAA 03 Greenwater River bull thistle 6050500116 Elk Forage Unit 69 passive

TAA 03 Greenwater River Scotch broom 6050500117 Elk Forage Unit 69 passive

TAA 03 Greenwater River herb Robert 6050500118 Elk Forage Unit 69 passive

TAA 03 Greenwater River common hawkweed 6050500119 Elk Forage Unit 69 passive

TAA 03 Greenwater River common tansy 6050500120 Elk Forage Unit 69 passive

304 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 03 Greenwater River Canada thistle 6050500121 Elk Forage Unit 71 passive

TAA 03 Greenwater River bull thistle 6050500122 Elk Forage Unit 71 passive

TAA 03 Greenwater River common hawkweed 6050500123 Elk Forage Unit 71 passive

TAA 03 Greenwater River Canada thistle 6050500124 Elk Forage Unit 72 passive

TAA 03 Greenwater River bull thistle 6050500125 Elk Forage Unit 72 passive

TAA 03 Greenwater River herb Robert 6050500126 Elk Forage Unit 72 passive

TAA 03 Greenwater River common hawkweed 6050500127 Elk Forage Unit 72 passive

TAA 03 Greenwater River Canada thistle 6050500128 Elk Forage Unit 73 passive

TAA 03 Greenwater River bull thistle 6050500129 Elk Forage Unit 73 passive

TAA 03 Greenwater River Scotch broom 6050500130 Elk Forage Unit 73 passive

TAA 03 Greenwater River Scotch broom 6050500131 Elk Forage Unit 73 passive

TAA 03 Greenwater River common hawkweed 6050500132 Elk Forage Unit 73 passive

TAA 03 Greenwater River common hawkweed 6050500133 Elk Forage Unit 73 passive

TAA 03 Greenwater River common hawkweed 6050500134 Elk Forage Unit 73 passive

TAA 03 Greenwater River Canada thistle 6050500135 Elk Forage Unit 74 passive

TAA 03 Greenwater River bull thistle 6050500136 Elk Forage Unit 74 passive

TAA 03 Greenwater River spotted knapweed 6050500137 Elk Forage Unit 75 passive

TAA 03 Greenwater River wild carrot 6050500138 Elk Forage Unit 75 passive

TAA 03 Greenwater River Canada thistle 6050500139 Elk Forage Unit 79 passive

TAA 03 Greenwater River bull thistle 6050500140 Elk Forage Unit 79 passive

TAA 03 Greenwater River common hawkweed 6050500141 Elk Forage Unit 79 passive

TAA 03 Greenwater River Canada thistle 6050500142 Elk Forage Unit 80 passive

TAA 03 Greenwater River Canada thistle 6050500146 Elk Forage Unit 81 passive

TAA 03 Greenwater River Canada thistle 6050500147 Elk Forage Unit 82 passive

TAA 03 Greenwater River Canada thistle 6050500148 Elk Forage Unit 83 passive

TAA 03 Greenwater River Canada thistle 6050500149 Elk Forage Unit 84 passive

TAA 03 Greenwater River Canada thistle 6050500150 Elk Forage Unit 84 passive

TAA 03 Greenwater River Canada thistle 6050500151 Elk Forage Unit 85 passive

TAA 03 Greenwater River Canada thistle 6050500152 Elk Forage Unit 86 passive

TAA 03 Greenwater River Canada thistle 6050500153 Elk Forage Unit 86 passive

TAA 03 Greenwater River Canada thistle 6050500154 Elk Forage Unit 87 passive

TAA 03 Greenwater River Canada thistle 6050500155 Elk Forage Unit 88 passive

TAA 03 Greenwater River herb Robert 05-KW-001 Road 70 passive

TAA 03 Greenwater River tansy ragwort 05-KW-016 Road 7012/7020 passive

TAA 03 Greenwater River tansy ragwort 05-LP-010 Road 7010 passive

TAA 03 Greenwater River Scotch broom 05-LP-087 Greenwater gravel bar, None

305 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

banks, old rd 70

TAA 03 Greenwater River Canada thistle 05-SJ-001 Road 7012-360 passive

TAA 03 Greenwater River bull thistle 05-SJ-002 Road 7012-360 passive

TAA 03 Greenwater River Canada thistle 05-SJ-003 Road 7020-110 passive

TAA 03 Greenwater River bull thistle 05-SJ-004 Road 7020-110 passive

TAA 03 Greenwater River spotted knapweed 05-TF-008 Road 70 and gravel bar passive

TAA 03 Greenwater River tansy ragwort 05-TF-009 Road 70/Road 410 junction Seed and Mulch

TAA 03 Greenwater River smooth hawkweed 05-TF-010 Road 70 Seed and Mulch

TAA 03 Greenwater River spotted knapweed 05-TF-011 Greenwater gravel bar, 

banks (revisit) None

TAA 03 Greenwater River spotted knapweed 05-TF-028 Old Rd 70 passive

TAA 03 Greenwater River tansy ragwort 05-VW-055 Road 72, sec 34 passive

TAA 03 Greenwater River diffuse knapweed 05-VW-056 Road 70 passive

TAA 03 Greenwater River tansy ragwort 05-VW-057 Road 70 & 7080 passive

TAA 03 Greenwater River spotted knapweed 05-VW-075 Road 70 Seed and Mulch

TAA 03 Greenwater River tansy ragwort 05-VW-076 Road 70 passive

TAA 04 The Dalles Scotch broom 6050500008 Mather Pkwy, Mt. Rainier 

viewpoint passive

TAA 04 The Dalles bull thistle 6050500014 Boundary Creek compound None

TAA 04 The Dalles Scotch broom 6050500015 Cow Flats stockpile None

TAA 04 The Dalles Canada thistle 6050500063 Elk Forage Unit 50 passive

TAA 04 The Dalles Canada thistle 6050500064 Elk Forage Unit 50 passive

TAA 04 The Dalles bull thistle 6050500065 Elk Forage Unit 50 passive

TAA 04 The Dalles bull thistle 6050500066 Elk Forage Unit 50 passive

TAA 04 The Dalles common hawkweed 6050500067 Elk Forage Unit 50 passive

TAA 04 The Dalles Canada thistle 6050500173 Upper White, Rd 7305 Seed and Mulch

TAA 04 The Dalles tansy ragwort 6050500174 Upper White, Rd 7305 passive

TAA 04 The Dalles bull thistle 6050500176 Upper White, Rd 7305 passive

TAA 04 The Dalles Scotch broom 6050500179 Upper White, Rd 7305 passive

TAA 04 The Dalles common hawkweed 6050500180 Upper White, Rd 7305 passive

TAA 04 The Dalles Canada thistle 6050500181 Upper White, Rd 7305-110 passive

TAA 04 The Dalles bull thistle 6050500182 Upper White, Rd 7305-110 passive

TAA 04 The Dalles tansy ragwort 6050500184 Upper White, Rd 7305-110 passive

TAA 04 The Dalles Canada thistle 6050500185 Upper White, Rd 7305-210 passive

TAA 04 The Dalles bull thistle 6050500186 Upper White, Rd 7305-210 passive

TAA 04 The Dalles Scotch broom 6050500187 Upper White, Rd 7305-210 passive

306 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 04 The Dalles Canada thistle 6050500192 Upper White, Rd 7315-160 passive

TAA 04 The Dalles Canada thistle 6050500193 Upper White, Rd 7315-310 passive

TAA 04 The Dalles bull thistle 6050500196 Upper White, Rd 7315-310 passive

TAA 04 The Dalles Scotch broom 6050500199 Upper White, Rd 7315-310 passive

TAA 04 The Dalles tansy ragwort 6050500201 Upper White, Rd 7315-310 passive

TAA 04 The Dalles herb Robert 6050500222 Upper White, Rd 7150-210 passive

TAA 04 The Dalles Canada thistle 6050500223 Upper White, Rd 7146 passive

TAA 04 The Dalles Canada thistle 6050500224 Upper White, Rd 7146 passive

TAA 04 The Dalles bull thistle 6050500225 Upper White, Rd 7146 passive

TAA 04 The Dalles herb Robert 6050500226 Upper White, Rd 7146 passive

TAA 04 The Dalles herb Robert 6050500227 Upper White, Rd 7146 passive

TAA 04 The Dalles Scotch broom 6050500228 McCullough Seed Orchard passive

TAA 04 The Dalles Scotch broom 6050500229 McCullough Seed Orchard passive

TAA 04 The Dalles Canada thistle 6050500230 McCullough Seed Orchard passive

TAA 04 The Dalles Canada thistle 6050500231 McCullough Seed Orchard passive

TAA 04 The Dalles bull thistle 6050500232 McCullough Seed Orchard passive

TAA 04 The Dalles bull thistle 6050500241 Upper White Unit 4 passive

TAA 04 The Dalles Canada thistle 6050500242 Upper White Unit 4 passive

TAA 04 The Dalles Canada thistle 6050500247 Upper White Unit 5 passive

TAA 04 The Dalles herb Robert 6050500248 Upper White Unit 5 passive

TAA 04 The Dalles Canada thistle 6050500249 Upper White Unit 6 passive

TAA 04 The Dalles Canada thistle 6050500250 Upper White Unit 6 passive

TAA 04 The Dalles Canada thistle 6050500251 Upper White Unit 10 passive

TAA 04 The Dalles herb Robert 6050500253 Upper White Unit 11 passive

TAA 04 The Dalles Canada thistle 6050500254 Upper White Unit 11 passive

TAA 04 The Dalles common hawkweed 6050500380 Upper White Thin Unit 9 passive

TAA 04 The Dalles Canada thistle 6050500381 Puyallup Thin Unit 9 passive

TAA 04 The Dalles common hawkweed 05-KW-028 McCullough Seed and Mulch 

Orchard Seed and Mulch

TAA 04 The Dalles Scotch broom 05-KW-029 McCullough Seed Orchard passive

TAA 04 The Dalles Canada thistle 05-KW-030 McCullough Seed Orchard passive

TAA 04 The Dalles bull thistle 05-KW-031 McCullough Seed Orchard passive

TAA 04 The Dalles bird's foot trefoil 05-KW-032 McCullough Seed Orchard passive

TAA 04 The Dalles hairy cat's ear 05-KW-033 McCullough Seed and Mulch 

Orchard Seed and Mulch

TAA 04 The Dalles oxeye daisy 05-KW-034 McCullough Seed and Mulch Seed and Mulch

307 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

Orchard

TAA 04 The Dalles St John's wort 05-KW-035 McCullough Seed and Mulch 

Orchard Seed and Mulch

TAA 04 The Dalles tansy ragwort 05-KW-041 McCullough Seed Orchard passive

TAA 04 The Dalles Scotch broom 05-LP-040 Huckleberry Army Camp 

(revisit) Seed and Mulch

TAA 04 The Dalles Bohemian knotweed 05-TF-012 Huckleberry Army Camp passive

TAA 04 The Dalles tansy ragwort 05-TF-013 Road 72, sec 5 passive

TAA 04 The Dalles spotted knapweed 05-TF-014 Road 7305-200 passive

TAA 04 The Dalles tansy ragwort 05-TF-026 The Dalles Rec Residence 

#27 Plant rooted stock

TAA 04 The Dalles tansy ragwort 05-TF-030 Elk forage unit #31western passive

TAA 04 The Dalles tansy ragwort 05-TF-031 Elk forage unit #31 middle passive

TAA 04 The Dalles tansy ragwort 05-TF-032 Elk forage unit #31 eastern passive

TAA 04 The Dalles Scotch broom 05-TF-039 Boundary Ck Boneyard &

Stockpile None

TAA 04 The Dalles tansy ragwort 05-VW-054 Minnehaha Seed and Mulch

TAA 04 The Dalles Scotch broom 05-VW-065 Road 73/7305 junction passive

TAA 05 The Dalles tansy ragwort 6050500188 Upper White, Rd 7305-210 passive

TAA 05 The Dalles common hawkweed 6050500233 Upper White Unit 2 passive

TAA 05 Ranger Creek Scotch broom 05-LP-089 Ranger Creek Airstrip Seed and Mulch

TAA 05 Ranger Creek tansy ragwort 05-TF-007 Buck Creek Camp passive

TAA 05 The Dalles tansy ragwort 05-TF-017 Road 7200-011 passive

TAA 05 Ranger Creek spotted knapweed 05-TF-018 Ranger Creek Airstrip Seed and Mulch

TAA 05 Ranger Creek Bohemian knotweed 05-TF-025 Silver Springs Rec 

Residence #122 Plant rooted stock

TAA 05 Ranger Creek Rhododendron 05-TF-027 Silver Springs Rec 

Residence #122 Plant rooted stock

TAA 05 Ranger Creek European lily of the valley 05-TF-029 Silver Springs Rec 

Residence #93 passive

TAA 05 Ranger Creek tansy ragwort 05-TF-033 Silver Springs Rec 

Residence #86 Plant rooted stock

TAA 06 The Dalles common groundsel 6050500189 Upper White, Rd 7305-210 passive

TAA 06 The Dalles bull thistle 6050500234 Upper White Unit 2 passive

TAA 06 Crystal Mountain Blvd bull thistle 05-LP-088 Crystal Mtn Parking area passive

TAA 07 The Dalles bull thistle 6050500190 Upper White, Rd 7315-410 passive

TAA 07 The Dalles Scotch broom 6050500235 Upper White Unit 2 passive

308 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 07 Sunday Creek tansy ragwort 05-AR-072 Road 54 Stampede Pass Seed and Mulch

TAA 07 Sunday Creek tansy ragwort 05-KM-009 Stampede Pass, Rd 50 Seed and Mulch

TAA 07 Sunday Creek spotted knapweed 05-KM-080 Rd 54 Stampede Pass 

(revisit) None

TAA 07 Sunday Creek tansy ragwort 05-KW-019 Road 54 Stampede Pass passive

TAA 07 Sunday Creek tansy ragwort 05-KW-020 Road 54 Stampede Pass passive

TAA 07 Sunday Creek spotted knapweed 05-KW-036 Road 54 Stampede Pass, 

mp 11.9 Seed and Mulch

TAA 08 Road 52 sulphur cinquefoil 6050500021 Rd 52, Tacoma Pass 

stockpile None

TAA 08 Road 52 spotted knapweed 6050500022 Rd 52, Pioneer Creek None

TAA 08 The Dalles Canada thistle 6050500236 Upper White Unit 2 passive

TAA 08 Road 52 tansy ragwort 05-AR-071 Road 52 near Tacoma Pass Seed and Mulch

TAA 11 I-90 Corridor King 

County orange hawkweed 6050500016 Alpental roads 9040 & PCT lots passive

TAA 11 I-90 Corridor King 

County spotted knapweed 6050500023 Granite Mtn. trailhead None

TAA 11 I-90 Corridor King 

County orange hawkweed 6050500024 Alpental ski area passive

TAA 11 I-90 Corridor King 

County Bohemian knotweed 6050500060 Road 9031 milepost 2.8 passive

TAA 11 I-90 Corridor King 

County absinth wormwood 6050500062 Denny Creek Road passive

TAA 11 I-90 Corridor King 

County orange hawkweed 6050500071 Denny Creek Road passive

TAA 11 I-90 Corridor King 

County meadow hawkweed 6050500072 Denny Creek Road passive

TAA 11 I-90 Corridor King 

County common hawkweed 6050500073 Denny Creek Road passive

TAA 11 I-90 Corridor King 

County yellow archangel 05-AR-073 Denny Ck Rec Res #4 Plant rooted stock

TAA 11 I-90 Corridor King 

County spotted knapweed 05-DL-001 Asahel Curtis trailhead passive

TAA 11 I-90 Corridor King 

County Bohemian knotweed 05-KB-049 Mason Ck; Menke acquisition(a.k.a. I-90 Exit42) None

TAA 11 I-90 Corridor King 

County Scotch broom 05-KM-007 Bandera/Rd 5510&110 spur passive

309 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 11 I-90 Corridor King 

County Scotch broom 05-KM-008 Bandera; Rd 5510-160 Seed and Mulch

TAA 11 I-90 Corridor King 

County Scotch broom 05-KM-077 Road 9030 Seed and Mulch

TAA 11 I-90 Corridor King 

County dalmatian toadflax 05-KM-078 RR tracks @ Humpback Ck passive

TAA 11 I-90 Corridor King 

County orange hawkweed 05-KM-079 "I-90 below underpass,Wbound lanes passive

TAA 11 I-90 Corridor King 

County tansy ragwort 05-KW-002 Pratt R. stockpile/ borrow pit None

TAA 11 I-90 Corridor King 

County herb Robert 05-KW-003 Pratt R. stockpile/ borrow pit None

TAA 11 I-90 Corridor King 

County sulphur cinquefoil 05-KW-004 Pratt R. stockpile/ borrow pit None

TAA 11 I-90 Corridor King 

County Scotch broom 05-KW-005 Pratt R. stockpile/ borrow pit None

TAA 11 I-90 Corridor King 

County orange hawkweed 05-KW-006 Pratt R. stockpile/ borrow pit None

TAA 11 I-90 Corridor King 

County spotted knapweed 05-KW-007 Pratt R. stockpile/ borrow pit None

TAA 11 I-90 Corridor King 

County Scotch broom 05-KW-013 John Wayne Trail None

TAA 11 I-90 Corridor King 

County dalmatian toadflax 05-KW-014 John Wayne Trail None

TAA 11 I-90 Corridor King 

County spotted knapweed 05-KW-015 John Wayne Trail passive

TAA 11 I-90 Corridor King 

County sulphur cinquefoil 05-KW-022 McClellan Butte Trailhead passive

TAA 11 I-90 Corridor King 

County herb Robert 05-KW-023 Tinkham Campground passive

TAA 11 I-90 Corridor King 

County tansy ragwort 05-KW-024 S Fk Snoqualmie Gravel Bars None

TAA 11 I-90 Corridor King 

County spotted knapweed 05-KW-025 S Fk Snoqualmie Gravel Bars None

TAA 11 I-90 Corridor King 

County spotted knapweed 05-KW-026 Snow Lake parking lot Seed and Mulch

TAA 11 I-90 Corridor King orange hawkweed 05-KW-027 Snow Lake Trailhead passive

310 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

County

TAA 11 I-90 Corridor King 

County tansy ragwort 05-KW-037 Rd 5510-310 passive

TAA 11 I-90 Corridor King 

County woolly hedgenettle 05-KW-038 Rd 5510-410, sec 21 passive

TAA 11 I-90 Corridor King 

County tansy ragwort 05-KW-039 Rd 5510 Hansen Creek passive

TAA 11 I-90 Corridor King 

County spotted knapweed 05-KW-040 Rd 5510-410, sec 28 passive

TAA 11 I-90 Corridor King 

County Bohemian knotweed 05-LP-021 Mason Lake Rd passive

TAA 11 I-90 Corridor King 

County meadow knapweed 05-TF-001 Road 5800 passive

TAA 11 I-90 Corridor King 

County tansy ragwort 05-TF-002 Road 5800 passive

TAA 11 I-90 Corridor King 

County spotted knapweed 05-TF-003 Road 5800 East (revisit) passive

TAA 11 I-90 Corridor King 

County orange hawkweed 05-TF-004 Road 5800/9040 junction passive

TAA 11 I-90 Corridor King 

County herb Robert 05-TF-005 McClellan Butte TH passive

TAA 11 I-90 Corridor King 

County spotted knapweed 05-TF-006 McClellan Butte TH passive

TAA 11 I-90 Corridor King 

County common hawkweed 05-TF-015 Road 9020 passive

TAA 11 I-90 Corridor King 

County Scotch broom 05-TF-016 Road 9020, milepost 7.6 passive

TAA 11 I-90 Corridor King 

County Bohemian knotweed 05-TF-040 9030 Rd passive

TAA 11 I-90 Corridor King 

County dalmatian toadflax 05-TF-076 Pratt R. stockpile/ borrow pit none

TAA 11 I-90 Corridor King 

County orange hawkweed 05-VW-074 Commonwealth Campground passive

TAA 11 I-90 Corridor King 

County dalmatian toadflax 05-LP-083 I-90 m.p. 38 to MBS boundary passive

TAA 11 I-90 Corridor King 

County yellow archangel 05-TF-023 Denny Ck Rec Res #4 plant rooted stock

311 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 12 Middle Fork Snoqualmie 

River Scotch broom 05-BS-001 Mid Fk Snoq Rd, .5 mi from end passive

TAA 12 Middle Fork Snoqualmie 

River common tansy 05-KC-011 MidFk Snoq - Taylor River bridge passive

TAA 12 Middle Fork Snoqualmie 

River Scotch broom 05-KC-028 MidFk Snoq - FS Rd 210 passive

TAA 12 Middle Fork Snoqualmie 

River common comfrey 05-KC-029 MidFk Snoq - FS Rd 210 passive

TAA 12 Middle Fork Snoqualmie 

River field bindweed 05-KC-030 MidFk Snoq - FS Rd 210 passive

TAA 12 Middle Fork Snoqualmie 

River common periwinkle 05-KC-033 MidFk Snoq - FS Rd 210 passive

TAA 12 Middle Fork Snoqualmie 

River common tansy 05-KC-036 MidFk Snoq - Quarry .8 mi from Goldmeyer turnoff None

TAA 12 Middle Fork Snoqualmie 

River rhubarb 05-KC-042 MidFk Snoq - 520 Rd closure Plant rooted stock

TAA 12 Middle Fork Snoqualmie 

River field bindweed 05-KC-043 MidFk Snoq - 520 Rd closure passive

TAA 12 Middle Fork Snoqualmie 

River Scotch broom 05-KC-113 MidFk Snoq - 510 Rd corridor passive

TAA 12 Middle Fork Snoqualmie 

River tansy ragwort 05-KC-123 MidFk Snoq - mid Fk trailhd, old cmp ground passive

TAA 12 Middle Fork Snoqualmie 

River butterfly bush 05-KC-124 MidFk Snoq - 4 mi from concrete bridge passive

TAA 12 Middle Fork Snoqualmie 

River Scotch broom 05-KC-141 MidFk Snoq - btween campsite and CCC rd passive

TAA 12 Middle Fork Snoqualmie 

River butterfly bush 05-KC-142 MidFk Snoq - near CCC trailhead passive

TAA 12 Middle Fork Snoqualmie 

River butterfly bush 05-KC-143 MidFk Snoq - milepost 4.3-4.6 (from concrete bridge) passive

TAA 12 Middle Fork Snoqualmie 

River tansy ragwort 05-KC-214

MidFk Snoq - btwn mid fk 

trailhead and taylor river 

bridge

passive

TAA 12 Middle Fork Snoqualmie 

River tansy ragwort 05-KC-241 MidFk Snoq - 1.25 mi E of FS Rd 210 passive

TAA 12 Middle Fork Snoqualmie 

River tansy ragwort 05-KC-247 MidFk Snoq - 0.15 mi W of FS Rd 210 passive

312 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 12 Middle Fork Snoqualmie 

River tansy ragwort 05-KC-261 MidFk Snoq - 0.1 mi W of FS Rd 210 passive

TAA 12 Middle Fork Snoqualmie 

River tansy ragwort 05-KC-271 MidFk Snoq - 0.2 mi W of Rd 210 near CCC trailhead passive

TAA 12 Middle Fork Snoqualmie 

River butterfly bush 05-KC-282 MidFk Snoq - 0.26 mi W of CCC road passive

TAA 12 Middle Fork Snoqualmie 

River butterfly bush 05-KC-288 MidFk Snoq - 0.4 mi W of CCC road passive

TAA 12 Middle Fork Snoqualmie 

River butterfly bush 05-KC-293 MidFk Snoq - 0.5 mi W of CCC road passive

TAA 12 Middle Fork Snoqualmie 

River common tansy 05-KC-373 MidFk Snoq - 7 mi E of Dingford trailhead passive

TAA 12 Middle Fork Snoqualmie 

River Scotch broom 05-KC-374 MidFk Snoq - 7.1 mi E of Dingford trailhead passive

TAA 12 Middle Fork Snoqualmie 

River Scotch broom 05-KC-375 MidFk Snoq - 7.2 mi E of Dingford trailhead passive

TAA 12 Middle Fork Snoqualmie 

River common tansy 05-KC-377 MidFk Snoq - Dutch Miller trailhead passive

TAA 12 Middle Fork Snoqualmie 

River field bindweed 05-KC-389 MidFk Snoq - 1.9 mi w of Dingford trailhead passive

TAA 12 Middle Fork Snoqualmie 

River tansy ragwort 05-KC-423 MidFk Snoq - btwn CCC Rd and campsite area passive

TAA 12 Middle Fork Snoqualmie 

River hedge false bindweed 05-KC-426 MidFk Snoq - 1.4 mi E of Moore prop access passive

TAA 12 Middle Fork Snoqualmie 

River herb Robert 05-LP-075 E of Dingford Ck Trailhead passive

TAA 12 Middle Fork Snoqualmie 

River butterfly bush 05-LP-085 Mid Fork Snoqualmie Road, milepost 9.2 passive

TAA 12 Middle Fork Snoqualmie 

River herb Robert 05-LP-086 Mid Fork Snoqualmie Road, near milepost 9.2 passive

TAA 12 Middle Fork Snoqualmie 

River field bindweed 05-TQ-069 Mid Fork Snoqualmie Road, near milepost 16 (revisit) passive

TAA 13 Bessemer Road System Bohemian knotweed 6050500074 Bessemer Roaddecommissioned passive

TAA 13 Bessemer Road System Bohemian knotweed 6050500075 Bessemer Road passive

TAA 14 Snoqualmie Point butterfly bush 05-TF-034 Snoqualmie Point 

Stewardship Plant rooted stock

313 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 14 Snoqualmie Point Scotch broom 05-TF-035 Snoqualmie Point 

Stewardship Plant rooted stock

TAA 14 Snoqualmie Point Himalayan blackberry 05-TF-036 Snoqualmie Point 

Stewardship Plant rooted stock

TAA 14 Snoqualmie Point cutleaf blackberry 05-TF-037 Snoqualmie Point 

Stewardship Plant rooted stock

TAA 14 Snoqualmie Point tansy ragwort 05-TF-038 Snoqualmie Point 

Stewardship passive

TAA 15 Martin Creek-Tye River common tansy 6050600019 Rd 6710230/Kelley Creek 

Trail passive

TAA 15 Martin Creek-Tye River yellow hawkweed 6050600053 Rd 6710 passive

TAA 15 Martin Creek-Tye River orange hawkweed 6050600054 Rd 6710 passive

TAA 15 Martin Creek-Tye River tansy ragwort 6050600055 Rd 6710-236 passive

TAA 15 Martin Creek-Tye River bull thistle 6050600072 Sky-Beckler Thin Unit 63 passive

TAA 15 Martin Creek-Tye River yellow hawkweed 06-AR-085 Road 6066/6067 Seed and Mulch

TAA 15 Martin Creek-Tye River Bohemian knotweed 06-BS-001 Hwy 2, milepost 52.5 passive

TAA 15 Martin Creek-Tye River Bohemian knotweed 06-BS-002 Rd 67, milepost 3.5 passive

TAA 15 Martin Creek-Tye River Bohemian knotweed 06-DL-002 Tye River Plant rooted stock

TAA 15 Martin Creek-Tye River dalmatian toadflax 06-SJ-010 WSDOT avalanche control, 

Road 2 passive

TAA 15 Martin Creek-Tye River giant hogweed 06-LP-035 Hwy 2 near Deception falls passive

TAA 15 Martin Creek-Tye River dalmatian toadflax 06-SJ-001 WSDOT stockpile, Road 2 None

TAA 15 Martin Creek-Tye River herb Robert 06-SJ-013 Hwy 2 stabilization Tye River passive

TAA 15 Martin Creek-Tye River Bohemian knotweed 06-SM-001 Rd 67, milepost 2.6 passive

TAA 15 Martin Creek-Tye River Bohemian knotweed 06-SM-002 Rd 67, milepost 3.0 passive

TAA 15 Martin Creek-Tye River Bohemian knotweed 06-SM-003 Rd 67, milepost 3.2 passive

TAA 15 Martin Creek-Tye River Bohemian knotweed 06-SM-004 E of Scenic in RR yard passive

TAA 16 Lower Beckler River Japanese knotweed 6050600008 Rd 65, opposite Beckler 

River CG None

TAA 16 Lower Beckler River Himalayan blackberry 6050600009 Rd 6500-104 stockpile None

TAA 16 Lower Beckler River Japanese knotweed 6050600010 Rd 6500-104 stockpile None

TAA 16 Lower Beckler River herb Robert 6050600036 Beckler Pit None

TAA 16 Lower Beckler River sulphur cinquefoil 6050600037 Beckler Pit None

TAA 16 Lower Beckler River Canada thistle 6050600038 Beckler Pit None

TAA 16 Lower Beckler River yellow hawkweed 6050600047 6514 Rd passive

TAA 16 Lower Beckler River Himalayan blackberry 6050600048 6514 Rd passive

TAA 16 Lower Beckler River herb Robert 6050600049 Sky-Beckler Thin Unit 51 passive

314 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 16 Lower Beckler River common hawkweed 6050600050 6514 Rd passive

TAA 16 Lower Beckler River tall hawkweed 6050600051 6514 Rd passive

TAA 16 Lower Beckler River yellow hawkweed 6050600052 Road 6514-409 passive

TAA 16 Lower Beckler River herb Robert 6050600079 Sky-Beckler Thin Unit65 passive

TAA 16 Lower Beckler River herb Robert 6050600135 Beckler Thin Unit 51 passive

TAA 16 Lower Beckler River bull thistle 6050600136 Beckler Thin Unit 55A passive

TAA 16 Lower Beckler River bull thistle 6050600137 Beckler Thin Unit 55A passive

TAA 16 Lower Beckler River bull thistle 6050600138 Beckler Thin Unit 55A passive

TAA 16 Lower Beckler River bull thistle 6050600139 Beckler Thin Unit 55A passive

TAA 16 Lower Beckler River herb Robert 6050600142 Beckler Thin Unit 55B passive

TAA 16 Lower Beckler River herb Robert 6050600143 Beckler Thin Unit 55B passive

TAA 16 Lower Beckler River bull thistle 6050600144 Beckler Thin Unit 55B passive

TAA 16 Lower Beckler River bull thistle 6050600166 Beckler Thin Unit 51 passive

TAA 16 Lower Beckler River herb Robert 6050600167 Beckler Thin Unit 51 passive

TAA 16 Lower Beckler River herb Robert 6050600168 Beckler Thin Unit 51 passive

TAA 16 Lower Beckler River bull thistle 6050600178 Beckler Thin Unit 51 passive

TAA 16 Lower Beckler River spotted knapweed 6050600202 Road 6514 passive

TAA 16 Lower Beckler River Bohemian knotweed 06-KW-014 Rd 6522 @ Johnson Creek passive

TAA 16 Lower Beckler River herb Robert 06-KW-020 Rd 6500-104 stockpile None

TAA 16 Lower Beckler River Canada thistle 06-KW-021 Rd 6500-104 stockpile None

TAA 16 Lower Beckler River bull thistle 06-KW-022 Rd 6500-104 stockpile None

TAA 16 Lower Beckler River spotted knapweed 06-KW-025 Road 6520 passive

TAA 16 Lower Beckler River herb Robert 6050600059 Sky-Beckler Thin Unit 55 passive

TAA 16 Lower Beckler River herb Robert 6050600162 Beckler Thin Unit 51 passive

TAA 16 Lower Beckler River tansy ragwort 06-KW-011 Road 65, milepost 5.3 passive

TAA 16 Lower Beckler River herb Robert 6050600140 Beckler Thin Unit 55A passive

TAA 16 Lower Beckler River bull thistle 6050600165 Beckler Thin Unit 51 passive

TAA 16 Lower Beckler River herb Robert 06-KW-012 Beckler River Rd, first 3 

miles passive

TAA 16 Lower Beckler River spotted knapweed 06-LP-030 Rd 6514 passive

TAA 16 Lower Beckler River Scotch broom 06-LP-031 Rd 6512-105 (Sky Forks 

sale) passive

TAA 16 Lower Beckler River Scotch broom 06-LP-033 REVISIT to Road 6520 passive

TAA 16 Lower Beckler River bull thistle 06-SJ-004 Road 6516-510 decom passive

TAA 16 Lower Beckler River bull thistle 06-SJ-005 Road 6512-210 decom passive

TAA 16 Lower Beckler River bull thistle 06-SJ-006 Road 6512 passive

315 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 16 Lower Beckler River wild carrot 06-SJ-007 Road 6512 passive

TAA 16 Lower Beckler River Bohemian knotweed 06-SS-050 Beckler Rd, 500' up passive

TAA 16 Lower Beckler River orange hawkweed 06-SS-051 Beckler Rd, Bolt Ck crossing Seed and Mulch

TAA 16 Lower Beckler River sulphur cinquefoil 06-SS-068 Beckler River Road 6500 passive

TAA 16 Lower Beckler River Bohemian knotweed 06-TF-001 Hwy 2, Rd 6500 jct (Sky 

Forks sale) passive

TAA 16 Lower Beckler River Bohemian knotweed 06-TF-002 Rd 6500 milepost 3.6 

(revisit) passive

TAA 17 Upper Beckler River common tansy 6050600025 Sky-Beckler Thin Unit 5 passive

TAA 17 Upper Beckler River Scotch broom 6050600026 Sky-Beckler Thin Unit 5 passive

TAA 17 Upper Beckler River bull thistle 6050600145 Beckler Thin Unit 69 passive

TAA 17 Upper Beckler River bull thistle 6050600146 Beckler Thin Unit 69 passive

TAA 17 Upper Beckler River bull thistle 6050600147 Beckler Thin Unit 69 passive

TAA 17 Upper Beckler River bull thistle 6050600148 Beckler Thin Unit 69 passive

TAA 17 Upper Beckler River Canada thistle 6050600149 Beckler Thin Unit 69 passive

TAA 17 Upper Beckler River Canada thistle 6050600150 Beckler Thin Unit 69 passive

TAA 17 Upper Beckler River Canada thistle 6050600151 Beckler Thin Unit 69 passive

TAA 17 Upper Beckler River Canada thistle 6050600152 Beckler Thin Unit 7 passive

TAA 17 Upper Beckler River Canada thistle 6050600153 Beckler Thin Unit 7 passive

TAA 17 Upper Beckler River Canada thistle 6050600154 Beckler Thin Unit 10 passive

TAA 17 Upper Beckler River Canada thistle 6050600155 Beckler Thin Unit 10 passive

TAA 17 Upper Beckler River bull thistle 6050600156 Beckler Thin Unit 10 passive

TAA 17 Upper Beckler River Canada thistle 6050600157 Beckler Thin Unit 19 passive

TAA 17 Upper Beckler River Canada thistle 6050600158 Beckler Thin Unit 19 passive

TAA 17 Upper Beckler River Canada thistle 6050600159 Beckler Thin Unit 19 passive

TAA 17 Upper Beckler River Canada thistle 6050600160 Beckler Thin Unit 19 passive

TAA 17 Upper Beckler River bull thistle 6050600161 Beckler Thin Unit 27 passive

TAA 17 Upper Beckler River Himalayan blackberry 6050600163 Beckler Thin Unit 30 passive

TAA 17 Upper Beckler River Canada thistle 6050600164 Beckler Thin Unit 30 passive

TAA 17 Upper Beckler River orange hawkweed 06-KW-017 Rd 65, milepost 10.9 passive

TAA 17 Upper Beckler River sulphur cinquefoil 06-KW-018 Rd 65, milepost 11.0 passive

TAA 17 Upper Beckler River yellow hawkweed 06-KW-019 Rd 6550-610 stockpile None

TAA 17 Upper Beckler River orange hawkweed 06-KW-024 Rd 65, milepost 11.0 passive

TAA 17 Upper Beckler River Scotch broom 06-SJ-002 Road 6560 decomm passive

TAA 18 Rapid River herb Robert 6050600162 Beckler Thin Unit 51 passive

TAA 18 Rapid River orange hawkweed 06-SJ-003 Road 6530 passive

316 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 19 North Fork Skykomish 

River common tansy 6050600012 Sky Forks Thin, Rd 6334 MP 2.8 passive

TAA 19 North Fork Skykomish 

River common tansy 6050600025 Sky-Beckler Thin Unit 5 passive

TAA 19 North Fork Skykomish 

River bird's foot trefoil 6050600039 North Fork Skykomish Trail #1051 None

TAA 19 North Fork Skykomish 

River hairy cat's ear 6050600040 North Fork Skykomish Trail #1051 None

TAA 19 North Fork Skykomish 

River oxeye daisy 6050600041 North Fork Skykomish Trail #1051 None

TAA 19 North Fork Skykomish 

River bull thistle 6050600043 North Fork Skykomish Trail 1051 None

TAA 19 North Fork Skykomish 

River common tansy 6050600044 North Fork Skykomish Trail 1051 None

TAA 19 North Fork Skykomish 

River spotted hawkweed 6050600125 Road 6300 east of San Juan campground Seed and Mulch

TAA 19 North Fork Skykomish 

River common hawkweed 6050600179 6330 rd passive

TAA 19 North Fork Skykomish 

River herb Robert 06-KW-007 San Juan Campground passive

TAA 19 North Fork Skykomish 

River herb Robert 06-KW-009 Troublesome Ck Campground passive

TAA 19 North Fork Skykomish 

River orange hawkweed 06-KW-013 Rd 63, milepost 2.1 passive

TAA 19 North Fork Skykomish 

River yellow hawkweed 06-KW-019 Rd 6550-610 stockpile None

TAA 19 North Fork Skykomish 

River Bohemian knotweed 06-KW-026 Rd 63, 2.2 mi w of Rd 65 passive

TAA 19 North Fork Skykomish 

River diffuse knapweed 06-KW-027 Rd 6334, mile 2.8 (Sky Forks sale) passive

TAA 19 North Fork Skykomish 

River Bohemian knotweed 06-KW-028 Rd 6300-310 spur passive

TAA 19 North Fork Skykomish 

River Bohemian knotweed 06-KW-030 Rd 63, 3.3 mi E of Hwy 2 passive

TAA 19 North Fork Skykomish 

River common hawkweed 06-KW-008 Troublesome Ck Campground passive

TAA 20 Highway 2 Corridor & English ivy 6050600007 Lowe Creek Rd 6030 @ MP passive

317 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

Miller River 0.3

TAA 20 Highway 2 Corridor & 

Miller River orange hawkweed 6050600032 Maloney Creek passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 6050600033 Maloney Creek passive

TAA 20 Highway 2 Corridor & 

Miller River orange hawkweed 6050600034 Lake Serene trailhead passive

TAA 20 Highway 2 Corridor & 

Miller River jewelweed 6050600035 Lake Serene Trail passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 6050600042 Cable Drop Trail Repair passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 6050600071 Sky-Beckler Thin Unit 63 passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 6050600073 Sky-Beckler Thin Unit 63 passive

TAA 20 Highway 2 Corridor & 

Miller River Scotch broom 6050600074 Sky-Beckler Thin Unit 63 passive

TAA 20 Highway 2 Corridor & 

Miller River orange hawkweed 6050600134 Skykomish Boneyard None

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 6050600140 Beckler Thin Unit 55A passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 6050600196 Road 6410 passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 6050600198 Road 6028 passive

TAA 20 Highway 2 Corridor & 

Miller River tansy ragwort 6050600199 Road 6028 @ MP 0.3 passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 6050600200 Road 6000-267 passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 6050600201 Road 6066-060 passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 6050600204 Road 68 passive

TAA 20 Highway 2 Corridor & 

Miller River English holly 6050600205 Road 6000-267 passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 6050600206 Road 6024-102 passive

318 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 20 Highway 2 Corridor & 

Miller River smooth hawkweed 06-AR-084 Hwy 2; m.p. 38-39 passive

TAA 20 Highway 2 Corridor & 

Miller River yellow hawkweed 06-AR-085 Road 6066/6067 Seed and Mulch

TAA 20 Highway 2 Corridor & 

Miller River Bohemian knotweed 06-DK-001 Old Cascade Hwy, w of RR Track passive

TAA 20 Highway 2 Corridor & 

Miller River orange hawkweed 06-DL-001 end of Thelma Street None

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 06-KW-001 Lowe Creek Road passive

TAA 20 Highway 2 Corridor & 

Miller River Bohemian knotweed 06-KW-005 Skykomish River Plant rooted stock

TAA 20 Highway 2 Corridor & 

Miller River tansy ragwort 06-KW-006 BPA right-of-way passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 06-KW-012 Beckler River Rd, first 3 miles passive

TAA 20 Highway 2 Corridor & 

Miller River Bohemian knotweed 06-KW-015 Skykomish River, mile 48 Plant rooted stock

TAA 20 Highway 2 Corridor & 

Miller River Bohemian knotweed 06-KW-016 Miller River Plant rooted stock

TAA 20 Highway 2 Corridor & 

Miller River tansy ragwort 06-KW-029 Rd 6022, no-name spur passive

TAA 20 Highway 2 Corridor & 

Miller River Bohemian knotweed 06-KW-031 Rd 6020, entry to Mt Index riversites passive

TAA 20 Highway 2 Corridor & 

Miller River Bohemian knotweed 06-KW-032 Rd 6020, jct w Hwy 2 passive

TAA 20 Highway 2 Corridor & 

Miller River butterfly bush 06-KW-033 Rd 6022, 3.0 mi from Rd 63 passive

TAA 20 Highway 2 Corridor & 

Miller River tansy ragwort 06-KW-034 Rd 6020 powerline, 4 mi from Rd 63 passive

TAA 20 Highway 2 Corridor & 

Miller River orange hawkweed 06-LP-019 Skykomish District Office None

TAA 20 Highway 2 Corridor & 

Miller River Scotch broom 06-LP-031 Rd 6512-105 (Sky Forks sale) passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 06-LP-034 SkyForks timbersale passive

TAA 20 Highway 2 Corridor & herb Robert 06-LP-036 Apex Mill passive

319 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

Miller River

TAA 20 Highway 2 Corridor & 

Miller River Canada thistle 06-LP-037 Rd 6512-015 (Sky Forks sale) passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 06-SJ-008 Berschinski driveway passive

TAA 20 Highway 2 Corridor & 

Miller River Bohemian knotweed 06-SJ-009 Berschinski driveway passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 06-SJ-011 Hwy 2 stabilization milepost 46 passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 06-SJ-012 Hwy 2 stabilization stream bridge passive

TAA 20 Highway 2 Corridor & 

Miller River Bohemian knotweed 06-SS-050 Beckler Rd, 500' up passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 06-TD-044 Baring; Rd 6028 MP 0.5 passive

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 06-TD-045 Miller River Rd 6410, 1/4 mile up passive

TAA 20 Highway 2 Corridor & 

Miller River Bohemian knotweed 06-TD-046 Lake Serene Trail passive

TAA 20 Highway 2 Corridor & 

Miller River Bohemian knotweed 06-TF-001 Hwy 2, Rd 6500 jct (Sky Forks sale) passive

TAA 20 Highway 2 Corridor & 

Miller River Bohemian knotweed 06-TF-060 Money Creek Campground Plant rooted stock

TAA 20 Highway 2 Corridor & 

Miller River herb Robert 06-TF-061 Money Creek Campground passive

TAA 20 Highway 2 Corridor & 

Miller River yellow archangel 06-TF-062 Skykomish District Office Plant rooted stock

TAA 20 Highway 2 Corridor & 

Miller River dalmatian toadflax 06-VW-081 Hwy 2 near Canyon falls passive

TAA 20 Highway 2 Corridor & 

Miller River giant knotweed 06-VW-082 Mt Index Road 6020-10 passive

TAA 21 Money Creek Bohemian knotweed 6050600020 Money Cr Rd 6420 2.3 miles 

E of Lk Elizabeth passive

TAA 21 Money Creek Bohemian knotweed 6050600194 Road 6420 @ MP 1.1 passive

TAA 21 Money Creek butterfly bush 6050600195 Road 6420 @ MP 0.7 passive

TAA 21 Money Creek herb Robert 6050600197 Road 6420 passive

TAA 21 Money Creek Bohemian knotweed 06-RB-001 Rd 6420, milepost 4.3 passive

320 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 22 Sultan River reed canarygrass 6050600013 Jackson relicensing, Stringer 

bridge Seed and Mulch

TAA 22 Sultan River cutleaf blackberry 6050600014 Jackson relicensing, Stringer 

bridge passive

TAA 22 Sultan River Canada thistle 6050600015 Jackson relicensing, Stringer 

bridge passive

TAA 22 Sultan River herb Robert 6050600016 Jackson relicensing, Stringer 

bridge passive

TAA 22 Sultan River bull thistle 6050600017 Jackson relicensing, Stringer 

bridge passive

TAA 22 Sultan River Himalayan blackberry 06-AR-073 Jackson relicensing Road 

6122, second clearing passive

TAA 22 Sultan River Canada thistle 06-AR-074 Jackson relicensing Road 

6122, second clearing passive

TAA 22 Sultan River oxeye daisy 06-AR-076 Jackson relicensing Road 

6122, second clearing passive

TAA 22 Sultan River Canada thistle 06-AR-079 Jackson relicensing Road 

6122, first clearing passive

TAA 22 Sultan River Scotch broom 06-AR-082 Jackson relicensing Road 

6122, first clearing passive

TAA 22 Sultan River cutleaf blackberry 06-AR-083 Jackson relicensing Road 

6122, first clearing Seed and Mulch

TAA 22 Sultan River Canada thistle 06-AR-088 Jackson relicensing, Rd 

6122 river access trail passive

TAA 22 Sultan River cutleaf blackberry 06-AR-089 Jackson relicensing, Rd 

6122 river access trail Seed and Mulch

TAA 23 South Fork 

Stillaguamish River herb Robert 6050200052 Hemple Creek picnic area passive

TAA 23 South Fork 

Stillaguamish River Bohemian knotweed 6050200056 Mt Loop Hwy, 1.1 miles east of Gold Basin CG passive

TAA 23 South Fork 

Stillaguamish River common hawkweed 6050200057 Verlot PSC Seed and Mulch

TAA 23 South Fork 

Stillaguamish River common periwinkle 6050200124 Camp Silverton Seed and Mulch

TAA 23 South Fork 

Stillaguamish River yellow archangel 6050200130 Road 4020 passive

TAA 23 South Fork common hawkweed 6050200131 Road 4020 Seed and Mulch

321 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

Stillaguamish River

TAA 23 South Fork 

Stillaguamish River common hawkweed 6050200132 Road 41 @ MP 13.3 passive

TAA 23 South Fork 

Stillaguamish River common hawkweed 6050200133 Road 41 Seed and Mulch

TAA 23 South Fork 

Stillaguamish River meadow hawkweed 6050200134 Rd 41 MP 11.9 passive

TAA 23 South Fork 

Stillaguamish River meadow hawkweed 6050200135 Rd 41 MP 13.2 to the end Seed and Mulch

TAA 23 South Fork 

Stillaguamish River meadow hawkweed 6050200137 Rd 41 MP 12.9 passive

TAA 23 South Fork 

Stillaguamish River orange hawkweed 6050200138 Rd 41 MP 11.7 passive

TAA 23 South Fork 

Stillaguamish River meadow hawkweed 6050200139 Rd 41 MP 11.4 passive

TAA 23 South Fork 

Stillaguamish River herb Robert 6050200201 Mt. Pilchuck Road @ MP 0.5 passive

TAA 23 South Fork 

Stillaguamish River herb Robert 02-AR-003 Dick Sperry Picnic Site passive

TAA 23 South Fork 

Stillaguamish River herb Robert 02-AR-004 Coal Creek CG passive

TAA 23 South Fork 

Stillaguamish River herb Robert 02-AR-006 Red Bridge CG passive

TAA 23 South Fork 

Stillaguamish River herb Robert 02-AR-007 Tulalip Mill CG passive

TAA 23 South Fork 

Stillaguamish River Bohemian knotweed 02-AR-029 Mountain Loop E of Wiley Ck passive

TAA 23 South Fork 

Stillaguamish River Bohemian knotweed 02-AR-033 Schweitzer 2: Rd 4020 Rockpit None

TAA 23 South Fork 

Stillaguamish River policeman's helmet 02-AR-036 Road 41 @ MP 13.1-13.4 passive

TAA 23 South Fork 

Stillaguamish River herb Robert 02-AR-042 Verlot PSC boneyard None

TAA 23 South Fork 

Stillaguamish River Bohemian knotweed 02-AR-047 Boardman Lake Trailhead passive

TAA 23 South Fork 

Stillaguamish River Bohemian knotweed 02-LP-016 Mt. Pilchuck Rd, Mile 2.1&2.2 (revisit) passive

322 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 23 South Fork 

Stillaguamish River Bohemian knotweed 02-LP-017 Schweitzer Ck Rd 4021 (revisit) passive

TAA 23 South Fork 

Stillaguamish River Bohemian knotweed 02-LP-018 The Sinkhole passive

TAA 23 South Fork 

Stillaguamish River herb Robert 02-LP-057 River Road 4037 passive

TAA 23 South Fork 

Stillaguamish River orange hawkweed 6050200045 Big 4 culvert passive

TAA 23 South Fork 

Stillaguamish River common hawkweed 6050200051 Mt. Loop Hwy from Dick Sperry to Barlow Pass Seed and Mulch

TAA 23 South Fork 

Stillaguamish River orange hawkweed 02-LP-004 Mtn Loop Hwy btwn Perry and Martin Cks Seed and Mulch

TAA 23 South Fork 

Stillaguamish River common hawkweed 6050200044 Buck Creek Br (Mt. Loop Hwy) passive

TAA 24 Fall Creek Scotch broom 02-AR-041 Road 2083 @ MP 0.5 passive

TAA 24 Fall Creek tansy ragwort 02-KW-002 Road 2083 passive

TAA 24 Fall Creek Bohemian knotweed 02-LB-005 Sauk Floodplain (TNC patch 

A141) Plant rooted stock

TAA 24 Fall Creek spotted knapweed 02-LP-053 Road 2083 passive

TAA 24 Fall Creek Japanese knotweed 02-LP-059 Upper River Sauk Corridor passive

TAA 25 Sauk-Whitechuck 

Confluence Bohemian knotweed 02-LB-008 Road 2200-013 passive

TAA 26 White Chuck River 

Road 23 herb Robert 6050200126 Whitechuck Bench Trail passive

TAA 26 White Chuck River 

Road 23 orange hawkweed 02-AR-018 Whitechuck Road #23 passive

TAA 26 White Chuck River 

Road 23 tansy ragwort 02-KW-012 Road 23 passive

TAA 26 White Chuck River 

Road 23 herb Robert 02-KW-013 Road 2311 passive

TAA 26 White Chuck River 

Road 23 herb Robert 6050200043 Whitechuck Rd 23 from MP 0 to 3.4 passive

TAA 27 Darrington South orange hawkweed 6050200191 Road 2420 #3 passive

TAA 27 Darrington South orange hawkweed 02-AR-002 Roads 2070, 2073 passive

TAA 27 Darrington South orange hawkweed 02-AR-005 Road 2060 passive

TAA 27 Darrington South herb Robert 02-AR-026 Gold Hill ERFO passive

TAA 27 Darrington South Bohemian knotweed 02-KW-008 Gold Hill Road 24 passive

323 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 27 Darrington South orange hawkweed 02-LP-003 Mtn Loop Hwy near 

Darrington Seed and Mulch

TAA 27 Darrington South Japanese knotweed 02-LP-059 Upper River Sauk Corridor passive

TAA 28 Squire Creek Bohemian knotweed 02-AR-030 Squire Ck Rd 2040 passive

TAA 29 Sauk Prairie hedge false bindweed 6050200053 Road 24 @ MP 0.3 passive

TAA 29 Sauk Prairie Scotch broom 6050200140 Queensgate passive

TAA 29 Sauk Prairie cutleaf blackberry 6050200141 Queensgate passive

TAA 29 Sauk Prairie cutleaf blackberry 6050200142 Queensgate passive

TAA 29 Sauk Prairie sulphur cinquefoil 6050200143 Queensgate passive

TAA 29 Sauk Prairie cutleaf blackberry 6050200144 Queensgate passive

TAA 29 Sauk Prairie cutleaf blackberry 6050200145 Queensgate passive

TAA 29 Sauk Prairie herb Robert 6050200146 Queensgate passive

TAA 29 Sauk Prairie Canada thistle 6050200147 Queensgate passive

TAA 29 Sauk Prairie herb Robert 6050200148 Queensgate passive

TAA 29 Sauk Prairie herb Robert 6050200155 Suiattle Road 26 Seed and Mulch

TAA 29 Sauk Prairie cutleaf blackberry 6050200161 Queensgate passive

TAA 29 Sauk Prairie yellow archangel 6050200194 Road 24 @ MP 0.3 passive

TAA 29 Sauk Prairie cutleaf blackberry 02-AR-027 Dan Creek Horse Pasture passive

TAA 29 Sauk Prairie Canada thistle 02-AR-028 Dan Creek Horse Pasture passive

TAA 29 Sauk Prairie tansy ragwort 02-AR-031 Dan Creek Rd 24 mile 0.3 passive

TAA 29 Sauk Prairie Bohemian knotweed 02-AR-040 Road 24 @ MP0.1 passive

TAA 29 Sauk Prairie herb Robert 02-AR-048 Dan Creek Horse Pasture passive

TAA 29 Sauk Prairie orange hawkweed 6050200046 DRD bunkhouse lawn None

TAA 29 Sauk Prairie sulphur cinquefoil 6050200047 Dan Creek horse pasture passive

TAA 29 Sauk Prairie Bohemian knotweed 6050200048 Dan Creek Rd 24 @ MP 0.3 passive

TAA 30 Dan Creek meadow hawkweed 6050200055 Road 2435 @ MP 6.1 passive

TAA 30 Dan Creek orange hawkweed 6050200206 Road 2435 @ MP 2.7 passive

TAA 30 Dan Creek meadow hawkweed 6050200207 Road 2435 MP 3.1 passive

TAA 30 Dan Creek orange hawkweed 02-AR-032 Rd 2435 #2 passive

TAA 30 Dan Creek orange hawkweed 02-LP-029 Conn Ck, Rd 2435 Seed and Mulch

TAA 30 Dan Creek herb Robert 02-LP-054 Decline Thin herb Robert passive

TAA 30 Dan Creek tansy ragwort 02-LP-055 Decline Thin tansy passive

TAA 30 Dan Creek Canada thistle 02-SJ-001 Decline Ck drainage passive

TAA 30 Dan Creek Canada thistle 02-SJ-002 Decline Ck drainage passive

TAA 30 Dan Creek Canada thistle 02-SJ-003 Decline Ck drainage passive

TAA 30 Dan Creek Canada thistle 02-SJ-004 Decline Ck drainage passive

324 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 30 Dan Creek bull thistle 02-SJ-005 Decline Ck drainage passive

TAA 30 Dan Creek herb Robert 02-SJ-006 Decline Ck drainage passive

TAA 30 Dan Creek bull thistle 02-SJ-007 Decline Ck drainage passive

TAA 30 Dan Creek Canada thistle 02-SJ-008 Decline Ck drainage passive

TAA 30 Dan Creek herb Robert 02-SJ-009 Decline Ck drainage passive

TAA 30 Dan Creek Canada thistle 02-SJ-010 Decline Ck drainage passive

TAA 30 Dan Creek Canada thistle 02-SJ-011 Decline Ck drainage passive

TAA 30 Dan Creek bull thistle 02-SJ-012 Decline Ck drainage passive

TAA 31 Prairie Mountain herb Robert 02-AR-008 Road 2141 passive

TAA 31 Prairie Mountain herb Robert 02-AR-009 Road 2140 north passive

TAA 31 Prairie Mountain herb Robert 02-AR-010 Road 2140 south passive

TAA 31 Prairie Mountain Canada thistle 02-AR-011 Road 2140-014 passive

TAA 31 Prairie Mountain Canada thistle 02-AR-012 Road 2140 south passive

TAA 31 Prairie Mountain Canada thistle 02-AR-013 Road 2140 north passive

TAA 31 Prairie Mountain tansy ragwort 02-AR-014 Road 2141 tansy passive

TAA 31 Prairie Mountain tansy ragwort 02-AR-015 Road 2140 east tansy passive

TAA 31 Prairie Mountain tansy ragwort 02-AR-016 Road 2140 west tansy passive

TAA 31 Prairie Mountain tansy ragwort 02-AR-017 Road 2140-020 passive

TAA 31 Prairie Mountain tansy ragwort 02-AR-043 Road 2430 past the road 

end passive

TAA 31 Prairie Mountain orange hawkweed 02-AR-044 Road 2430 past the road 

end passive

TAA 31 Prairie Mountain meadow hawkweed 02-AR-045 Road 2430 past the road 

end passive

TAA 31 Prairie Mountain Canada thistle 02-AR-046 Road 2430 past the road 

end passive

TAA 32 Circle Creek-Suiattle 

River Scotch broom 6050200149 Green Mountain horse pasture passive

TAA 32 Circle Creek-Suiattle 

River common burdock 6050200150 Green Mountain horse pasture passive

TAA 32 Circle Creek-Suiattle 

River common tansy 6050200153 Green Mountain horse pasture Seed and Mulch

TAA 32 Circle Creek-Suiattle 

River herb Robert 6050200154 South Suiattle Road 25 passive

TAA 32 Circle Creek-Suiattle 

River herb Robert 6050200155 Suiattle Road 26 Seed and Mulch

TAA 32 Circle Creek-Suiattle herb Robert 6050200163 Rd 27 from MP 0.0 to 1.8 passive

325 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

River

TAA 32 Circle Creek-Suiattle 

River Canada thistle 6050200173 Road 2703 @ MP 0.7 passive

TAA 32 Circle Creek-Suiattle 

River orange hawkweed 6050200176 Road 2703 @ MP 4.0 passive

TAA 32 Circle Creek-Suiattle 

River orange hawkweed 6050200177 Road 27 from MP 4.5 to 6.5 Seed and Mulch

TAA 32 Circle Creek-Suiattle 

River sulphur cinquefoil 6050200195 Darrington Seed and Mulch Orchard Seed and Mulch

TAA 32 Circle Creek-Suiattle 

River Canada thistle 6050200197 Darrington Seed and Mulch Orchard Seed and Mulch

TAA 32 Circle Creek-Suiattle 

River orange hawkweed 6050200198 Darrington Seed and Mulch Orchard Seed and Mulch

TAA 32 Circle Creek-Suiattle 

River orange hawkweed 02-AR-001 Harriet Creek passive

TAA 32 Circle Creek-Suiattle 

River sulphur cinquefoil 02-AR-019 Green Mountain Horse Pasture passive

TAA 32 Circle Creek-Suiattle 

River herb Robert 02-AR-024 Huckleberry Mountain Trail passive

TAA 32 Circle Creek-Suiattle 

River orange hawkweed 02-KW-003 Suiattle Guard Station None

TAA 32 Circle Creek-Suiattle 

River Scotch broom 02-KW-011 Road 2680 passive

TAA 32 Circle Creek-Suiattle 

River Canada thistle 02-LP-028 Green Mountain Horse Pasture passive

TAA 33 Big Creek-Tenas Creek Canada thistle 6050200033 Road 2650 west passive

TAA 33 Big Creek-Tenas Creek Canada thistle 6050200034 Road 2650 east passive

TAA 33 Big Creek-Tenas Creek herb Robert 6050200035 Road 2650 passive

TAA 33 Big Creek-Tenas Creek Canada thistle 6050200036 Road 2660 west passive

TAA 33 Big Creek-Tenas Creek Canada thistle 6050200037 Road 2660 east passive

TAA 33 Big Creek-Tenas Creek herb Robert 6050200038 Road 2660 passive

TAA 33 Big Creek-Tenas Creek orange hawkweed 6050200039 Road 2660 passive

TAA 33 Big Creek-Tenas Creek herb Robert 6050200154 South Suiattle Road 25 passive

TAA 33 Big Creek-Tenas Creek herb Robert 6050200155 Suiattle Road 26 Seed and Mulch

TAA 33 Big Creek-Tenas Creek common tansy 6050200156 All Creek gravel pit None

TAA 33 Big Creek-Tenas Creek orange hawkweed 6050200167 Road 25 @ MP 2.45 passive

TAA 33 Big Creek-Tenas Creek meadow hawkweed 6050200178 Road 26 @ MP 7.6 passive

326 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 33 Big Creek-Tenas Creek orange hawkweed 6050200202 Suiattle Road 26 @ MP 6.0 passive

TAA 33 Big Creek-Tenas Creek orange hawkweed 6050200203 South Suiattle Road 25 @ 

MP 2.2 passive

TAA 33 Big Creek-Tenas Creek orange hawkweed 6050200204 Suiattle Road 26 @ MP 8.5 passive

TAA 33 Big Creek-Tenas Creek yellow hawkweed 02-AR-025 Grade Creek Road 2642 Seed and Mulch

TAA 33 Big Creek-Tenas Creek tansy ragwort 02-AR-035 Suiattle Rd 26 near Tenas 

Ck passive

TAA 33 Big Creek-Tenas Creek orange hawkweed 02-AR-039 Road 2642 #2 passive

TAA 33 Big Creek-Tenas Creek Scotch broom 02-KW-005 Road 2640 passive

TAA 33 Big Creek-Tenas Creek Scotch broom 02-KW-006 Road 2640 passive

TAA 33 Big Creek-Tenas Creek orange hawkweed 02-KW-007 Road 2642 passive

TAA 33 Big Creek-Tenas Creek herb Robert 02-KW-010 Rd 2510 passive

TAA 33 Big Creek-Tenas Creek tansy ragwort 02-LP-002 Grade Ck Rd 2640 & 2642 passive

TAA 33 Big Creek-Tenas Creek sulphur cinquefoil 02-LP-027 All Ck gravel pit None

TAA 33 Big Creek-Tenas Creek Scotch broom 02-LP-056 All Ck gravel pit None

TAA 33 Big Creek-Tenas Creek herb Robert 02-LP-058 All Ck gravel pit None

TAA 33 Big Creek-Tenas Creek Scotch broom 6050200040 Road 2661 passive

TAA 33 Big Creek-Tenas Creek herb Robert 6050200042 Rd 2640 from MP 0 to 1.1 

(2.1 now) Seed and Mulch

TAA 34 Segelson Pass Road 18 common hawkweed 6050200220 Road 1855 @ MP 1.0 passive

TAA 34 Segelson Pass Road 18 yellow hawkweed 01-AR-009 Rd 1750, DeForest Ck passive

TAA 34 Segelson Pass Road 18 spotted knapweed 01-LP-026 Road 18 near the 025 spur passive

TAA 34 Segelson Pass Road 18 yellow hawkweed 01-LP-074 Little Deer Peak Rockpit None

TAA 34 Segelson Pass Road 18 bull thistle 01-LP-075 Little Deer Peak Rockpit None

TAA 34 Segelson Pass Road 18 yellow hawkweed 02-AR-020 Road 18 milepost 7.7-15 Seed and Mulch

TAA 34 Segelson Pass Road 18 Scotch broom 02-AR-021 Road 1855 Segelson 

Communication Site passive

TAA 34 Segelson Pass Road 18 Scotch broom 02-AR-022 Road 18 Segelson 

Communication Site passive

TAA 34 Segelson Pass Road 18 Scotch broom 02-AR-037 Road 18 @ MP 8.4 & 8.9 passive

TAA 34 Segelson Pass Road 18 yellow hawkweed 02-AR-038 Road 1855 Seed and Mulch

TAA 34 Segelson Pass Road 18 meadow hawkweed 01-AR-079 Road 17 Seed and Mulch

TAA 34 Segelson Pass Road 18 orange hawkweed 6050200050 Road 18 from MP 3.0 to 3.1 passive

TAA 36 Sedro Woolley herb Robert 6050100010 Baker River Ranger Station passive

TAA 36 Sedro Woolley English holly 6050100011 Baker River Ranger Station passive

TAA 36 Sedro Woolley common periwinkle 6050100012 Baker River Ranger Station plant rooted stock

TAA 36 Sedro Woolley Himalayan blackberry 6050100025 Kaaland Property plant rooted stock

327 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 36 Sedro Woolley butterfly bush 6050100133 Kaaland Property plant rooted stock

TAA 36 Sedro Woolley Scotch broom 6050100135 Kaaland Property passive

TAA 36 Sedro Woolley Bohemian knotweed 6050100136 Kaaland Property plant rooted stock

TAA 36 Sedro Woolley common tansy 6050100137 Kaaland Property Seed and Mulch

TAA 36 Sedro Woolley common teasel 6050100138 Kaaland Property passive

TAA 36 Sedro Woolley Canada thistle 6050100139 Kaaland Property Seed and Mulch

TAA 36 Sedro Woolley poison hemlock 6050100140 Kaaland Property Plant rooted stock

TAA 36 Sedro Woolley bittersweet nightshade 6050100141 Kaaland Property Plant rooted stock

TAA 36 Sedro Woolley common burdock 6050100142 Kaaland Property passive

TAA 36 Sedro Woolley reed canarygrass 6050100143 Kaaland Property Seed and Mulch

TAA 36 Sedro Woolley Himalayan blackberry 01-AR-005 Skiyou Island north 

perimeter Plant rooted stock

TAA 36 Sedro Woolley Bohemian knotweed 01-AR-013 Skiyou Island southwest 

corner passive

TAA 36 Sedro Woolley Bohemian knotweed 01-AR-014 Deadman Island passive

TAA 36 Sedro Woolley Bohemian knotweed 01-AR-015 Giligan Island Plant rooted stock

TAA 36 Sedro Woolley Bohemian knotweed 01-AR-046 Kaaland acquisition Plant rooted stock

TAA 36 Sedro Woolley butterfly bush 01-AR-061 Skiyou Island southwest 

corner

Plant rooted stock

TAA 36 Sedro Woolley Canada thistle 01-AR-062 Skiyou Island, whole thing Seed and Mulch

TAA 36 Sedro Woolley common tansy 01-AR-081 Skiyou Island Seed and Mulch

TAA 36 Sedro Woolley tansy ragwort 01-AR-082 Skiyou Island passive

TAA 36 Sedro Woolley yellow hawkweed 01-LP-024 Iron Mtn sec 30 passive

TAA 36 Sedro Woolley yellow hawkweed 01-LP-025 Iron Mtn sec 32 passive

TAA 37 Crevice Creek yellow hawkweed 02-AR-023 Road 28 passive

TAA 38 Finney Creek butterfly bush 6050100130 Road 17 @ MP 4.75 passive

TAA 38 Finney Creek yellow hawkweed 01-AR-010 Rd 18 near Rd 17 passive

TAA 38 Finney Creek yellow hawkweed 01-LP-071 1715-011 Pit None

TAA 38 Finney Creek yellow hawkweed 01-LP-072 1722 Pit None

TAA 38 Finney Creek yellow hawkweed 01-LP-073 Finney Flat Pit None

TAA 38 Finney Creek yellow hawkweed 02-AR-020 Road 18 milepost 7.7-15 Seed and Mulch

TAA 38 Finney Creek meadow hawkweed 01-AR-079 Road 17 Seed and Mulch

TAA 38 Finney Creek herb Robert 01-AR-080 Road 17 from MP 0.0 to 13 Seed and Mulch

TAA 39 South of Rockport yellow flag iris 6050100015 W&SR acquisition, Shaffer 

property passive

TAA 39 South of Rockport common comfrey 6050100028 W&SR acquisition, Shaffer 

property passive

328 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 39 South of Rockport Canada thistle 01-AR-041 W&S acquisition - Shaffer 

property Seed and Mulch

TAA 39 South of Rockport cutleaf blackberry 01-AR-087 W&SR acquisition - Schaffer 

property passive

TAA 39 South of Rockport bull thistle 01-AR-088 W&SR acquisition - Schaffer 

property passive

TAA 40 Concrete to Rockport Bohemian knotweed 6050100019 W&SR acquisition, Ovenell 

property plant rooted stock

TAA 40 Concrete to Rockport Himalayan blackberry 6050100021 W&SR acquisition, Ovenell 

property planted

TAA 40 Concrete to Rockport Himalayan blackberry 6050100023 W&SR acquisition, Larsen 

memorial plant rooted stock

TAA 40 Concrete to Rockport tansy ragwort 6050100027 Sauk Mtn Road 1030 seed and mulch

TAA 40 Concrete to Rockport herb Robert 6050100126 Illabot Rd 16 @ MP 15.4 passive

TAA 40 Concrete to Rockport orange hawkweed 6050100127 Illabot Rd 16 @ MP 12.5 passive

TAA 40 Concrete to Rockport meadow hawkweed 6050100128 Illabot Rd 16 @ MP 15.0 passive

TAA 40 Concrete to Rockport tansy ragwort 6050100129 Road 17 @ MP 0.45 passive

TAA 40 Concrete to Rockport butterfly bush 6050100132 Illabot Rd 16 MP 11.9 passive

TAA 40 Concrete to Rockport Canada thistle 01-AR-007 Ovenell property W&S river 

acquisition Seed and Mulch

TAA 40 Concrete to Rockport Bohemian knotweed 01-AR-012 Larsen Memorial Seed and Mulch

TAA 40 Concrete to Rockport Canada thistle 01-AR-059 Illabot Creek Rd #16 passive

TAA 40 Concrete to Rockport bull thistle 01-AR-060 Illabot Creek Rd #16 passive

TAA 40 Concrete to Rockport herb Robert 01-AR-080 Road 17 from MP 0.0 to 13 Seed and Mulch

TAA 40 Concrete to Rockport common tansy 01-AR-085 W&S acquisition - Ovenell 

property Plant rooted stock

TAA 40 Concrete to Rockport bull thistle 01-AR-086 W&SR acquisition - Ovenell 

property planted

TAA 41 Suiattle Mountain Canada thistle 01-AR-059 Illabot Creek Rd #16 passive

TAA 41 Suiattle Mountain bull thistle 01-AR-060 Illabot Creek Rd #16 passive

TAA 41 Suiattle Mountain orange hawkweed 01-LP-011 Suiattle Mountain area passive

TAA 43 Baker Lake giant knotweed 6050100016 Road 12 @ MP 3.95 passive

TAA 43 Baker Lake herb Robert 6050100118 Rd 11/Rd 1106 junction passive

TAA 43 Baker Lake butterfly bush 6050100119 Rd 11/Rd 1106 junction passive

TAA 43 Baker Lake wild carrot 6050100120 Rd 11/Rd 1106 junction passive

TAA 43 Baker Lake Canada thistle 6050100121 Rd 11/Rd 1106 junction passive

TAA 43 Baker Lake common tansy 6050100122 Rd 11/Rd 1106 junction passive

329 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 43 Baker Lake black locust 6050100123 Baker Lake Resort passive

TAA 43 Baker Lake herb Robert 6050100124 Baker Lake Resort passive

TAA 43 Baker Lake tansy ragwort 01-AR-003 Baker L - West Bluff of 

Anderson Point passive

TAA 43 Baker Lake tansy ragwort 01-AR-053 Bkr Lake Rd at Forest 

boundary passive

TAA 43 Baker Lake spotted knapweed 01-AR-071 Baker Lake Road @ MP 0.9 passive

TAA 43 Baker Lake sulphur cinquefoil 01-AR-073 Koma Kulshan Guard 

Station passive

TAA 43 Baker Lake Canada thistle 01-AR-074 Koma Kulshan Guard 

Station passive

TAA 43 Baker Lake bull thistle 01-JA-001 Baker Lake Road/Panorama 

Pt CG passive

TAA 43 Baker Lake bull thistle 01-JA-002 Baker Lake Road passive

TAA 43 Baker Lake bull thistle 01-JA-003 Baker Lake Road passive

TAA 43 Baker Lake bull thistle 01-JA-004 Baker Lake Road passive

TAA 43 Baker Lake hawkweed non-native 01-KB-001 Baker Lake Road, int w Rd 

1114 passive

TAA 43 Baker Lake Bohemian knotweed 01-KB-002 Baker Lake Road, north of 

Rd 1122 passive

TAA 43 Baker Lake herb Robert 01-KB-003 Baker Lake Road passive

TAA 43 Baker Lake tansy ragwort 01-KB-004 Baker Lake Road/Road 1118 passive

TAA 43 Baker Lake Japanese knotweed 01-LP-012 Baker Lake Rd, Little Sandy 

Ck passive

TAA 43 Baker Lake Bohemian knotweed 01-LP-013 Bkr Lk Rd Little Shannon Ck 

(revisit) passive

TAA 43 Baker Lake Canada thistle 01-LP-028 Bkr Hydro: Sulphur Creek passive

TAA 43 Baker Lake Canada thistle 01-LP-029 Bkr Hydro: Rocky Creek passive

TAA 43 Baker Lake bull thistle 01-LP-031 Bkr Hydro: W of Upper Bkr 

Dam passive

TAA 43 Baker Lake bull thistle 01-LP-032 Bkr Hydro: E of 

KomoKulshan Guard Stn passive

TAA 43 Baker Lake Canada thistle 01-LP-033 Bkr Hydro:NW shore 

Depression Lk passive

TAA 43 Baker Lake bull thistle 01-LP-034 Bkr Hydro:Welker Ck Inlet passive

TAA 43 Baker Lake bull thistle 01-LP-035 Bkr Hydro:N of Maple Grove 

campground passive

330 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 43 Baker Lake herb Robert 01-LP-036 Bkr Hydro:Chadwick Ck @ 

Bkr Lk Rd passive

TAA 43 Baker Lake herb Robert 01-LP-038 Bkr Hydro:south shore opp 

Shannon Ck CG passive

TAA 43 Baker Lake herb Robert 01-LP-039 Bkr Hydro:south shore passive

TAA 43 Baker Lake Canada thistle 01-LP-040 Bkr Hydro:west of spawning 

beach passive

TAA 43 Baker Lake bull thistle 01-LP-041 Bkr Hydro:Bkr River inlet passive

TAA 43 Baker Lake Scotch broom 01-LP-042 Bkr Hydro:Park Creek passive

TAA 43 Baker Lake Canada thistle 01-LP-043 Bkr Hydro:Swift Creek passive

TAA 43 Baker Lake bull thistle 01-LP-044 Bkr Hydro:Park Creek passive

TAA 43 Baker Lake bull thistle 01-LP-046 Bkr Hydro:Bkr River inlet passive

TAA 43 Baker Lake Canada thistle 01-LP-047 Bkr Hydro:Bkr River inlet passive

TAA 43 Baker Lake English ivy 01-LP-048 Bkr Hydro:Bkr River inlet None

TAA 43 Baker Lake herb Robert 01-LP-049 Bkr Hydro:Upper Bkr Dam passive

TAA 43 Baker Lake herb Robert 01-LP-051 Bkr Hydro:Upper Bkr Dam passive

TAA 43 Baker Lake herb Robert 01-LP-052 Bkr Hydro:Upper Bkr Dam passive

TAA 43 Baker Lake herb Robert 01-LP-054 Bkr Hydro:Upper Bkr Dam passive

TAA 43 Baker Lake tansy ragwort 01-LP-055 Bkr Hydro:SE corner Bkr Lk passive

TAA 43 Baker Lake Canada thistle 01-LP-056 Bkr Hydro: Sulphur Creek passive

TAA 43 Baker Lake bull thistle 01-LP-057 Bkr Hydro:Bkr Lk Dam Road passive

TAA 43 Baker Lake herb Robert 01-LP-058 Bkr Hydro:Chadwick Ck passive

TAA 43 Baker Lake bull thistle 01-LP-060 Bkr Hydro:Bkr Lk Dam Road passive

TAA 43 Baker Lake bull thistle 01-LP-061 Bkr Hydro:fish tank on Bkr 

Lk Dam Rd passive

TAA 43 Baker Lake bull thistle 01-LP-062 Bkr Hydro: Sulphur Creek passive

TAA 43 Baker Lake herb Robert 01-LP-063 Bkr Hydro:Welker Ck by 

campground passive

TAA 43 Baker Lake herb Robert 01-LP-064 Bkr Hydro:Upper Bkr Dam passive

TAA 43 Baker Lake Canada thistle 01-LP-066 Bkr Hydro:Bkr River inlet passive

TAA 43 Baker Lake Canada thistle 01-LP-067 Bkr Hydro:Bkr Lk Dam Road passive

TAA 43 Baker Lake herb Robert 01-LP-076 Bkr Hydro:Maple Grove CG passive

TAA 43 Baker Lake Scotch broom 01-LP-079 Bkr Hydro:Baker Lk Dam Rd passive

TAA 43 Baker Lake Scotch broom 01-LP-080 Bkr Hydro: Sulphur Creek passive

TAA 43 Baker Lake Canada thistle 01-LP-082 Bkr Hydro: near Baker Lk 

Lodge passive

TAA 43 Baker Lake reed canarygrass 01-LP-027 Bkr Hydro: near Bkr River Seed and Mulch

331 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

Inlet 

TAA 43 Baker Lake Canada thistle 01-JA-006 Baker Lake Road passive

TAA 44 Glacier Creek Rd 39 Canada thistle 01-AR-011 Glacier Creek Rd 39 passive

TAA 45 Mt. Baker Highway 542 herb Robert 6050100009 Deadhorse Rd pit @ MP 1.5 none

TAA 45 Mt. Baker Highway 542 common comfrey 6050100013 SR542 rockpit @ MP 36.3 none

TAA 45 Mt. Baker Highway 542 orange hawkweed 6050100014 SR 542 across from the 

Glacier PSC passive

TAA 45 Mt. Baker Highway 542 yellow archangel 6050100020 Glacier FS house passive

TAA 45 Mt. Baker Highway 542 hedge false bindweed 6050100022 Glacier FS house passive

TAA 45 Mt. Baker Highway 542 bull thistle 6050100026 Deadhorse Rd pit @ MP 1.5 none

TAA 45 Mt. Baker Highway 542 orange hawkweed 6050100125 SR542 @ Road 3071 passive

TAA 45 Mt. Baker Highway 542 herb Robert 01-AR-002 Excelsior CG intersection passive

TAA 45 Mt. Baker Highway 542 elephant ear 01-AR-004 Glacier Rec Residence Plant rooted stock

TAA 45 Mt. Baker Highway 542 herb Robert 01-AR-006 Excelsior CG passive

TAA 45 Mt. Baker Highway 542 orange hawkweed 01-AR-008 Glacier Ck Rd 39 milepost

0.4 passive

TAA 45 Mt. Baker Highway 542 herb Robert 01-AR-049 N Fk Nooksack stream gage passive

TAA 45 Mt. Baker Highway 542 Bohemian knotweed 01-AR-054 Hwy 542/3060 Jct. passive

TAA 45 Mt. Baker Highway 542 elephant ear 01-AR-055 Glacier Public Service 

Center Plant rooted stock

TAA 45 Mt. Baker Highway 542 herb Robert 01-AR-056 Glacier Public Service 

Center passive

TAA 45 Mt. Baker Highway 542 orange hawkweed 01-AR-063 Mt Baker Hwy, mile 35.3 passive

TAA 45 Mt. Baker Highway 542 Bohemian knotweed 01-AR-064 USFS residence near 

Glacier passive

TAA 45 Mt. Baker Highway 542 English ivy 01-AR-066 Glacier FS house None

TAA 45 Mt. Baker Highway 542 common periwinkle 01-AR-067 Glacier FS house passive

TAA 45 Mt. Baker Highway 542 Himalayan blackberry 01-AR-070 Glacier FS house Plant rooted stock

TAA 45 Mt. Baker Highway 542 Bohemian knotweed 01-AR-072 Glacier FS house, east passive

TAA 45 Mt. Baker Highway 542 meadow hawkweed 01-AR-075 Miners Quarry (Rd 3700-011 

pit) None

TAA 45 Mt. Baker Highway 542 spotted knapweed 01-AR-076 Miners Quarry (Rd 3700-011 

pit) None

TAA 45 Mt. Baker Highway 542 herb Robert 01-AR-077 SR 542 Rock pit @ MP 36.3 None

TAA 45 Mt. Baker Highway 542 Himalayan blackberry 01-AR-078 SR 542 Rock pit @ MP 36.3 None

TAA 45 Mt. Baker Highway 542 Bohemian knotweed 01-LP-014 Mt Bkr Hwy near Barometer 

Ck (revisit) passive

332 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 45 Mt. Baker Highway 542 wild carrot 01-LP-068 Miner's Quarry None

TAA 45 Mt. Baker Highway 542 bull thistle 01-LP-069 Miner's Quarry None

TAA 45 Mt. Baker Highway 542 bull thistle 01-LP-070 Shuksan Pit None

TAA 45 Mt. Baker Highway 542 herb Robert 01-AR-001 Douglas Fir CG passive

TAA 45 Mt. Baker Highway 542 Bohemian knotweed 01-AR-065 North Fork Nooksack River Plant rooted stock

TAA 45 Mt. Baker Highway 542 tansy ragwort 01-LP-001 Mt Baker Hwy passive

TAA 46 Canyon Creek Canada thistle 01-AR-057 Canyon Creek Rd 31 passive

TAA 46 Canyon Creek orange hawkweed 01-LP-023 Canyon Ck Rd 3140 passive

TAA 47 Monte Cristo Townsite common hawkweed 6050200123 Monte Cristo townsite None

TAA 48 South of Dan Creek English holly 6050200028 Dan Creek Thin Unit 1 passive

TAA 48 South of Dan Creek herb Robert 6050200029 Dan Creek Thin Unit 1 passive

TAA 48 South of Dan Creek English holly 6050200030 Dan Creek Thin Unit 3 passive

TAA 48 South of Dan Creek herb Robert 6050200031 Dan Creek Thin Unit 3 passive

TAA 48 South of Dan Creek herb Robert 6050200032 Dan Creek Thin Unit 3 passive

TAA 48 South of Dan Creek orange hawkweed 6050200054 Road 2420 @ MP 3.2 passive

TAA 48 South of Dan Creek orange hawkweed 6050200189 Road 2420 #2 passive

TAA 49 Tonga Ridge spotted knapweed 6050600192 Road 6830 @ MP 2.6 passive

TAA 49 Tonga Ridge herb Robert 6050600193 Road 6830 passive

TAA 49 Tonga Ridge yellow hawkweed 6050600203 Road 6846 passive

TAA 49 Tonga Ridge herb Robert 6050600204 Road 68 passive

TAA 50 North Bend compound orange hawkweed 05-KW-018 NBRD compound None

TAA 50 North Bend compound Bohemian knotweed 05-LP-020 North Bend Compound None

TAA 51 Diobsud Creek Himalayan blackberry 6050100017 Mouth of Diobsud Creek plant rooted stock

TAA 51 Diobsud Creek Scotch broom 6050100018 Peterson acquisition & rd 

access

Seed and Mulch

TAA 51 Diobsud Creek Himalayan blackberry 6050100024 Marblemount boat launch plant rooted stock

TAA 51 Diobsud Creek Bohemian knotweed 01-AR-021 Hideaway Lane (Peterson) passive

TAA 51 Diobsud Creek Canada thistle 01-AR-051 Marblemount Boat Launch, 

whole area planted

TAA 51 Diobsud Creek Scotch broom 01-AR-068 Taylor spawning channel passive

TAA 51 Diobsud Creek Canada thistle 01-AR-069 Taylor spawning channel passive

TAA 51 Diobsud Creek common tansy 01-AR-083 Marblemount boat launch, 

entire area Seed and Mulch

TAA 51 Diobsud Creek Bohemian knotweed 01-LP-022 Marblemount boat launch, 

west end planted

TAA 52 Marblemount Boat 

Launch Bohemian knotweed 01-AR-050 Marblemount Boat Launch, east end planted

333 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix B

TAA # TAA Name Invasive Plant Species Invasive Plant NRIS 

# Invasive Plant Site Name Revegetation 

Strategy 

TAA 52 Marblemount Boat 

Launch Canada thistle 01-AR-051 Marblemount Boat Launch, whole area planted

TAA 52 Marblemount Boat 

Launch hedge false bindweed 01-AR-052 Marblemount Boat Launch, east end planted

TAA 52 Marblemount Boat 

Launch common tansy 01-AR-083 Marblemount boat launch, entire area Seed and Mulch

TAA 52 Marblemount Boat 

Launch Scotch broom 01-AR-084 Marblemount boat launch, near east pkg area planted

TAA 53 Sulphur Creek herb Robert 6050200227 Suiattle Trail & trailhead None

TAA 54 Johnson Ridge oxeye daisy 6050600045 Scorpion Mountain meadow None

334 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix C

Appendix C – Susceptibility of Rare Plants to Herbicides

Introduction 

Table C- 1 displays the botanical species of conservation concern and their susceptibility to the various herbicides proposed for use in this 

project. Botanical species of conservation concern include (1) Botanical species that are listed under the federal Endangered Species Act 

(ESA) as threatened or endangered (or those species candidate/proposed for federal listing); (2) Species on the Regional Forester’s 

Sensitive Species List (R6-Sensitive because they are considered rare throughout the Pacific Northwest Region; (3) Species on the 

Washington state Se. WA-Sensitive = species that are considered rare in Washington but not Oregon. 

Table C- 1. Susceptibility to Herbicide for Botanical Species of Conservation Concern on the MBS

TES or S&M 

Plant Species

Scientific 

Name; Plant 

Family; 

Management 

Status

Aminopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae 

plant families

Chlorsulfuron

Protect 

individual 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Clopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae 

plant families

Glyphosate

Nonselective; 

protect 

from direct 

spray; 

runoff not 

a concern.

Imazapic

Protect 

from direct 

spray, 

drift, 

runoff & 

timing 

after use 

of other 

herbicides

Imazapyr

Nonselective; 

protect 

plants 

from 

direct 

spray, 

drift, 

runoff

Metsulfuron 

methyl

Protect 

individual 

plants from 

direct 

spray, drift, 

runoff, wind 

erosion.

Picloram

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Protect 

from direct spray 

drift, runoff.

Scrophulariaceae, 

Brassicacea, 

Liliaceae less 

susceptible. 

Grasses not 

affected.

Sulfometuron 

methyl

Nonselective; 

Protect 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Triclopyr 

Regional 

FEIS limits 

use of 

triclopyr to 

selective 

application 

techniques

Bartramiopsis 

lescurii

Polystrichaceae 

WA-Sensitive

No concern – 

Polystrichacea 

family not target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly

No concern – 

Polystrichacea 

family not target

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly

No concern – 

Polystrichacea 

family not target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly

Botrychium 

ascendens

Ophioglossace

WA Sensitive

No concern;

Ophioglossaceae 

family not target

Concern

No concern;

Ophioglossaceae

family not target

Concern Concern Concern Concern

No concern;

Ophioglossaceae 

family not target

Concern Concern

Botrychium 

montanum

Ophioglossace

S&M category D

No concern;

Ophioglossaceae 

family not target

Concern

No concern;

Ophioglossaceae 

family not target

Concern Concern Concern Concern

No concern;

Ophioglossaceae 

family not target

Concern Concern

335 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix C

TES or S&M 

Plant Species

Scientific 

Name; Plant 

Family; 

Management 

Status

Aminopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae 

plant families

Chlorsulfuron

Protect 

individual 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Clopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae 

plant families

Glyphosate

Nonselective; 

protect 

from direct 

spray; 

runoff not 

a concern.

Imazapic

Protect 

from direct 

spray, 

drift, 

runoff & 

timing 

after use 

of other 

herbicides

Imazapyr

Nonselective; 

protect 

plants 

from 

direct 

spray, 

drift, 

runoff

Metsulfuron 

methyl

Protect 

individual 

plants from 

direct 

spray, drift, 

runoff, wind 

erosion.

Picloram

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Protect 

from direct spray 

drift, runoff.

Scrophulariaceae, 

Brassicacea, 

Liliaceae less 

susceptible. 

Grasses not 

affected.

Sulfometuron 

methyl

Nonselective; 

Protect 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Triclopyr 

Regional 

FEIS limits 

use of 

triclopyr to 

selective 

application 

techniques

Botrychium 

peduncluosum

Ophioglossace

R6 Sensitive

No concern;

Ophioglossaceae 

family not target

Concern

No concern;

Ophioglossaceae 

family not target

Concern Concern Concern Concern

No concern;

Ophioglossaceae 

family not target

Concern Concern

Bridgeoporus 

nobilissimus

Polypore 

Polyporaceae

S&M category A

No concern;

Polyporaceae 

family not target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

No concern;

Polyporaceae 

family not target

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly

No concern;

Polyporaceae family 

not target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly

Bryoria tortuosa

Parmeliaceae

S&M Category A

No concern;

Parmeliaceae 

family not target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

No concern;

Polyporaceae 

family not target

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly

No concern;

Polyporaceae family 

not target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly

Campanula 

lasiocarpa

Campanulaceae

WA-Sensitive

No concern; 

Campanulaceae 

not a target.

Concern

No concern; 

Campanulaceae 

not a target.

Concern Concern Concern Concern

No concern; 

Campanulaceae not a 

target.

Concern Concern

Carex comosa

Cyperaceae

R6-Sensitive

No impact 

expected. 

Grasses are not 

impacted, so it is 

assumed Carex 

species are not 

impacted. Trials 

should be 

conducted first 

before this 

herbicide is used 

near these rare 

species.

No concern. 

This species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

No concern.

This species of 

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

No concern.

This species 

of Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

Concern

No concern. 

This species 

of Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

No concern. This 

species of Carex

occurs along water’s 

edge where this 

herbicide would not 

be used.

No concern. 

This species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern

336 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix C

TES or S&M 

Plant Species

Scientific 

Name; Plant 

Family; 

Management 

Status

Aminopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae 

plant families

Chlorsulfuron

Protect 

individual 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Clopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae 

plant families

Glyphosate

Nonselective; 

protect 

from direct 

spray; 

runoff not 

a concern.

Imazapic

Protect 

from direct 

spray, 

drift, 

runoff & 

timing 

after use 

of other 

herbicides

Imazapyr

Nonselective; 

protect 

plants 

from 

direct 

spray, 

drift, 

runoff

Metsulfuron 

methyl

Protect 

individual 

plants from 

direct 

spray, drift, 

runoff, wind 

erosion.

Picloram

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Protect 

from direct spray 

drift, runoff.

Scrophulariaceae, 

Brassicacea, 

Liliaceae less 

susceptible. 

Grasses not 

affected.

Sulfometuron 

methyl

Nonselective; 

Protect 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Triclopyr 

Regional 

FEIS limits 

use of 

triclopyr to 

selective 

application 

techniques

Carex flava

Cyperaceae

Removed from R6 

list but remains a 

species of concern 

on the MBSNF

No impact 

expected. 

Grasses are not 

impacted, so it is 

assumed Carex 

species are not 

impacted. Trials 

should be 

conducted first 

before this 

herbicide is used 

near these rare 

species.

No concern. 

This species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

No concern.

This species of 

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

No 

concern.This 

species of

Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

Concern.

No concern. 

This species 

of Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

No concern. This 

species of Carex

occurs along water’s 

edge where this 

herbicide would not 

be used.

No concern. 

This species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

Carex 

macrochaeta

Cyperaceae

R6-Sensitive

No impact 

expected. 

Grasses are not 

impacted, so it is 

assumed Carex 

species are not 

impacted. Trials 

should be 

conducted first 

before this 

herbicide is used 

near these rare 

species.

No concern. 

This species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

No concern. 

This species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

No concern. 

This species 

of Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

Concern.

No concern. 

This species 

of Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

No concern. This 

species of Carex

occurs along water’s 

edge where this 

herbicide would not 

be used.

No concern. 

This species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

337 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix C

TES or S&M 

Plant Species

Scientific 

Name; Plant 

Family; 

Management 

Status

Aminopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae 

plant families

Chlorsulfuron

Protect 

individual 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Clopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae 

plant families

Glyphosate

Nonselective; 

protect 

from direct 

spray; 

runoff not 

a concern.

Imazapic

Protect 

from direct 

spray, 

drift, 

runoff & 

timing 

after use 

of other 

herbicides

Imazapyr

Nonselective; 

protect 

plants 

from 

direct 

spray, 

drift, 

runoff

Metsulfuron 

methyl

Protect 

individual 

plants from 

direct 

spray, drift, 

runoff, wind 

erosion.

Picloram

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Protect 

from direct spray 

drift, runoff.

Scrophulariaceae, 

Brassicacea, 

Liliaceae less 

susceptible. 

Grasses not 

affected.

Sulfometuron 

methyl

Nonselective; 

Protect 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Triclopyr 

Regional 

FEIS limits 

use of 

triclopyr to 

selective 

application 

techniques

Carex 

magellanica ssp.

irrigua.

Cyperaceae. WASensitive

No impact 

expected. 

Grasses are not 

impacted, so it is 

assumed Carex 

species are not 

impacted. Trials 

should be 

conducted first 

before this 

herbicide is used 

near these rare 

species.

No concern. 

This species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

No concern. 

This species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

No concern. 

This species 

of Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

Concern.

No concern.

This species 

of Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

No concern. This 

species of Carex

occurs along water’s 

edge where this 

herbicide would not 

be used.

No concern. 

This species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

Carex pauciflora

Cyperaceae. WASensitive

No impact 

expected. 

Grasses are not 

impacted, so it is 

assumed Carex 

species are not 

impacted. Trials 

should be 

conducted first 

before this 

herbicide is used 

near these rare 

species.

No 

concern.This 

species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

No concern.This 

species of Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

No concern. 

This species 

of Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

Concern.

No 

concern.This 

species of

Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

No concern. This 

species of Carex

occurs along water’s 

edge where this 

herbicide would not 

be used.

No concern. 

This species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

338 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix C

TES or S&M 

Plant Species

Scientific 

Name; Plant 

Family; 

Management 

Status

Aminopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae 

plant families

Chlorsulfuron

Protect 

individual 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Clopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae 

plant families

Glyphosate

Nonselective; 

protect 

from direct 

spray; 

runoff not 

a concern.

Imazapic

Protect 

from direct 

spray, 

drift, 

runoff & 

timing 

after use 

of other 

herbicides

Imazapyr

Nonselective; 

protect 

plants 

from 

direct 

spray, 

drift, 

runoff

Metsulfuron 

methyl

Protect 

individual 

plants from 

direct 

spray, drift, 

runoff, wind 

erosion.

Picloram

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Protect 

from direct spray 

drift, runoff.

Scrophulariaceae, 

Brassicacea, 

Liliaceae less 

susceptible. 

Grasses not 

affected.

Sulfometuron 

methyl

Nonselective; 

Protect 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Triclopyr 

Regional 

FEIS limits 

use of 

triclopyr to 

selective 

application 

techniques

Carex rostrata

Cyperaceae. WASensitive

No impact 

expected. 

Grasses are not 

impacted, so it is 

assumed Carex 

species are not 

impacted. Trials 

should be 

conducted first 

before this 

herbicide is used 

near these rare 

species.

No concern. 

This species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

No concern. 

This species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

No concern. 

This species 

of Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

Concern.

No concern. 

This species 

of Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

No concern. This 

species of Carex

occurs along water’s 

edge where this 

herbicide would not 

be used.

No concern. 

This species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

Carex scirpoidea 

ssp. scirpoidea

Cyperaceae. WASensitive

No impact 

expected. 

Grasses are not 

impacted, so it is 

assumed Carex 

species are not 

impacted. Trials 

should be 

conducted first 

before this 

herbicide is used 

near these rare 

species.

N/A. This 

species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

N/A. This 

species of Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

N/A. This 

species of

Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

Concern.

N/A. This 

species of

Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

N/A. This species of

Carex

occurs along water’s 

edge where this 

herbicide would not 

be used.

N/A. This 

species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

339 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix C

TES or S&M 

Plant Species

Scientific 

Name; Plant 

Family; 

Management 

Status

Aminopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae 

plant families

Chlorsulfuron

Protect 

individual 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Clopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae 

plant families

Glyphosate

Nonselective; 

protect 

from direct 

spray; 

runoff not 

a concern.

Imazapic

Protect 

from direct 

spray, 

drift, 

runoff & 

timing 

after use 

of other 

herbicides

Imazapyr

Nonselective; 

protect 

plants 

from 

direct 

spray, 

drift, 

runoff

Metsulfuron 

methyl

Protect 

individual 

plants from 

direct 

spray, drift, 

runoff, wind 

erosion.

Picloram

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Protect 

from direct spray 

drift, runoff.

Scrophulariaceae, 

Brassicacea, 

Liliaceae less 

susceptible. 

Grasses not 

affected.

Sulfometuron 

methyl

Nonselective; 

Protect 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Triclopyr 

Regional 

FEIS limits 

use of 

triclopyr to 

selective 

application 

techniques

Carex stylosa

Cyperaceae. WASensitive

No impact 

expected. 

Grasses are not 

impacted, so it is 

assumed Carex 

species are not 

impacted. Trials 

should be 

conducted first 

before this 

herbicide is used 

near these rare 

species.

N/A. .This 

species of

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

N/A. This 

species of Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

N/A. This 

species of 

Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

Concern.

N/A. This 

species of 

Carex

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

N/A. This species of 

Carex

occurs along water’s 

edge where this 

herbicide would not 

be used.

N/A. This 

species of 

Carex

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

Castilleja 

cryptantha

Scrophulariaceae.

WA-Sensitive

No concern;

Scrophulariaceae 

not targeted by 

this herbicide.

Concern. No.

Scrophulariaceae 

not target

Concern. Concern. Concern. Concern.

Possible concern but

Scrophulariaceae 

less susceptible than 

other families to 

impacts from this 

herbicide.

Concern Concern.

Chaenactis 

thompsonii.

Scrophulariaceae.

WA-Sensitive

No concern;

Scrophulariaceae 

not targeted by 

this herbicide.

Concern

No concern;

Scrophulariaceae 

not targeted by 

this herbicide.

Concern Concern Concern Concern

Possible concern but

Scrophulariaceae 

less susceptible than 

other families to 

impacts from this 

herbicide.

Concern Concern

Cladonia 

norvegica. 

Cladoniaceae.

S&M Category C

No concern; 

Cladoniaceae 

family not 

targeted by this 

herbicide.

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

No concern; 

Cladoniaceae 

not target

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly.

No concern; 

Cladoniaceae not 

target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

340 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix C

TES or S&M 

Plant Species

Scientific 

Name; Plant 

Family; 

Management 

Status

Aminopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae 

plant families

Chlorsulfuron

Protect 

individual 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Clopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae 

plant families

Glyphosate

Nonselective; 

protect 

from direct 

spray; 

runoff not 

a concern.

Imazapic

Protect 

from direct 

spray, 

drift, 

runoff & 

timing 

after use 

of other 

herbicides

Imazapyr

Nonselective; 

protect 

plants 

from 

direct 

spray, 

drift, 

runoff

Metsulfuron 

methyl

Protect 

individual 

plants from 

direct 

spray, drift, 

runoff, wind 

erosion.

Picloram

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Protect 

from direct spray 

drift, runoff.

Scrophulariaceae, 

Brassicacea, 

Liliaceae less 

susceptible. 

Grasses not 

affected.

Sulfometuron 

methyl

Nonselective; 

Protect 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Triclopyr 

Regional 

FEIS limits 

use of 

triclopyr to 

selective 

application 

techniques

Coptis 

aspleniifolia

Ranunculaceae. 

WA-Sensitive and 

S&M Category A

No concern.

Ranunculaceae 

family not 

targeted by this 

herbicide.

Concern

No

Ranunculaceae 

not target

Concern Concern Concern Concern

No

Ranunculacea not

target

Concern Concern

Coptis trifolia

Ranunculaceae. 

S&M Category A

No concern.

Ranunculaceae 

family not 

targeted by this 

herbicide.

Concern

No

Ranunculaceae 

not target

Concern Concern Concern Concern

No

Ranunculacea not 

target

Concern Concern

Cypripedium 

fasiculatum

Orchidaceae.

S&M Category C

No concern.

Orchidaceae 

family not 

targeted by this 

herbicide.

Concern

No

Orchidaceae not 

target

Concern Concern Concern Concern

No

Orchidaceae not 

target

Concern Concern

Cypripedium 

montanum

Orchidaceae.

S&M Category C

No concern.

Orchidaceae 

family not 

targeted by this 

herbicide

Concern

No

Orchidaceae not 

target

Concern Concern Concern Concern

No

Orchidaceae not 

target

Concern Concern

Corydalis aquaegelidae

Fumariaceae.

S&M Category C

No concern.

Fumariaceae 

family not 

targeted by this 

herbicide

Concern

No

Fumariaceae not 

target

Concern Concern Concern Concern

No

Fumariaceae not 

target

Concern Concern

Dendriscocaulon 

intricatulatum

Lobariaceae.

S&M Category A

No concern – 

Lobariaceae 

family not 

targeted by this 

herbicide.

Not sure; 

assume worst 

case

No concern – 

this family not 

target

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly.

No concern – this 

family not target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

341 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix C

TES or S&M 

Plant Species

Scientific 

Name; Plant 

Family; 

Management 

Status

Aminopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae 

plant families

Chlorsulfuron

Protect 

individual 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Clopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae 

plant families

Glyphosate

Nonselective; 

protect 

from direct 

spray; 

runoff not 

a concern.

Imazapic

Protect 

from direct 

spray, 

drift, 

runoff & 

timing 

after use 

of other 

herbicides

Imazapyr

Nonselective; 

protect 

plants 

from 

direct 

spray, 

drift, 

runoff

Metsulfuron 

methyl

Protect 

individual 

plants from 

direct 

spray, drift, 

runoff, wind 

erosion.

Picloram

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Protect 

from direct spray 

drift, runoff.

Scrophulariaceae, 

Brassicacea, 

Liliaceae less 

susceptible. 

Grasses not 

affected.

Sulfometuron 

methyl

Nonselective; 

Protect 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Triclopyr 

Regional 

FEIS limits 

use of 

triclopyr to 

selective 

application 

techniques

Dryas 

drummondii var.

drummondii

Rosaceae.

WA-Sensitive

No concern - 

Rosaceae family 

not targeted by 

this herbicide.

Concern

No

Rosaceae not 

target

Concern Concern Concern Concern No

Rosaceae not target Concern Concern

Erigeron salishii

Asteraceae.

WA-Sensitive

Concern -

Asteraceae is 

targeted by this 

herbicide.

Concern

Concern - 

Asteraceae is 

target

Concern Concern Concern Concern Concern - 

Asteraceae is a target Concern Concern

Eucephalis vialis

Asteraceae.

S&M Category A

Concern -

Asteraceae is 

targeted by this 

herbicide.

Concern

Concern - 

Asteraceae is 

target

Concern Concern Concern Concern Concern - 

Asteraceae is a target Concern Concern

Eurybia merita

Asteraceae.

WA-Sensitive

Concern -

Asteraceae is 

targeted by this 

herbicide.

Concern

Concern - 

Asteraceae is 

target

Concern Concern Concern Concern Concern - 

Asteraceae is a target Concern Concern

Fritillaria 

camschatcensis

Liliaceae.

R6-Sensitive

No concern. 

Liliaceae not 

targeted by this 

herbicide.

Concern

No concern. 

Liliaceae not 

targeted by this 

herbicide.

Concern Concern Concern Concern

Lesser concern. This 

herbicide targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Liliaceae 

less susceptible.

Concern Concern

Galium 

kamtschaticum

Rubiaceae.

S&M category A, 

south of 

Snoqualmie Pass 

only.

No concern.

Rubiaceae 

family

not targeted by 

this herbicide.

N/A because 

this species 

occurs

in saturated 

soils where this 

herbicide would 

not be used.

N/A because this 

species occurs

in saturated soils 

where this 

herbicide would 

not be used.

Concern

N/A because 

this species 

occurs

in saturated 

soils where 

this 

herbicide 

would not be 

used.

Concern. 

Aquatic 

Imazapyr 

could be 

used; Apply 

MR and 

MMs

N/A because 

this species 

occurs

in saturated 

soils where 

this herbicide 

would not be 

used.

No

Rubiaceae

not target.

N/A because 

this species 

occurs

in saturated 

soils where this 

herbicide would 

not be used.

Concern

342 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix C

TES or S&M 

Plant Species

Scientific 

Name; Plant 

Family; 

Management 

Status

Aminopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae 

plant families

Chlorsulfuron

Protect 

individual 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Clopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae 

plant families

Glyphosate

Nonselective; 

protect 

from direct 

spray; 

runoff not 

a concern.

Imazapic

Protect 

from direct 

spray, 

drift, 

runoff & 

timing 

after use 

of other 

herbicides

Imazapyr

Nonselective; 

protect 

plants 

from 

direct 

spray, 

drift, 

runoff

Metsulfuron 

methyl

Protect 

individual 

plants from 

direct 

spray, drift, 

runoff, wind 

erosion.

Picloram

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Protect 

from direct spray 

drift, runoff.

Scrophulariaceae, 

Brassicacea, 

Liliaceae less 

susceptible. 

Grasses not 

affected.

Sulfometuron 

methyl

Nonselective; 

Protect 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Triclopyr 

Regional 

FEIS limits 

use of 

triclopyr to 

selective 

application 

techniques

Gaultheria 

hispidula

Ericaceae.

WA-Sensitive

No concern.

Ericaceae family

not targeted by 

this herbicide.

Concern

No

Ericaceae

not target

Concern Concern Concern Concern

No

Ericaceae

not target

Concern Concern

Gentiana 

douglasiana

Gentianaceae.

WA-Sensitive

No concern - 

Gentianaceae

not target.

N/A because 

this species 

usually

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

N/A because this 

species usually

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

N/A because 

this species 

usually

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

Concern. 

Aquatic 

Imazapyr 

could be 

used; Apply 

MR and 

MMs

N/A because 

this species 

usually

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

No. Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae plant 

families.

N/A because 

this species 

usually

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern. If 

Aquatic 

Triclopyr 

used, apply 

MR and 

MMs

Gentiana glauca

Gentianaceae

WA-Sensitive

No concern;

Gentianaceae

not targeted by 

this herbicide.

Concern

No

Gentianaceae

not target

Concern Concern Concern Concern

No

Gentianaceae

not target

Concern Concern

Hypogymnia 

duplicata

Parmeliaceae.

S&M Category C

No – 

Parmeliaceae 

family not 

targeted by this 

herbicide.

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

No – 

Parmeliaceae not 

target

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly.

No – Parmeliaceae 

not target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Leptogium 

burnetiae var.

hirsutum

Collemataceae.

S&M Category A

No concern; 

Collemataceae 

family not 

targeted by this 

herbicide.

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

No – concern. 

Collemataceae 

family not 

targeted by this 

herbicide.

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly.

No – this family not 

target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

343 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix C

TES or S&M 

Plant Species

Scientific 

Name; Plant 

Family; 

Management 

Status

Aminopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae 

plant families

Chlorsulfuron

Protect 

individual 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Clopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae 

plant families

Glyphosate

Nonselective; 

protect 

from direct 

spray; 

runoff not 

a concern.

Imazapic

Protect 

from direct 

spray, 

drift, 

runoff & 

timing 

after use 

of other 

herbicides

Imazapyr

Nonselective; 

protect 

plants 

from 

direct 

spray, 

drift, 

runoff

Metsulfuron 

methyl

Protect 

individual 

plants from 

direct 

spray, drift, 

runoff, wind 

erosion.

Picloram

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Protect 

from direct spray 

drift, runoff.

Scrophulariaceae, 

Brassicacea, 

Liliaceae less 

susceptible. 

Grasses not 

affected.

Sulfometuron 

methyl

Nonselective; 

Protect 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Triclopyr 

Regional 

FEIS limits 

use of 

triclopyr to 

selective 

application 

techniques

Leptogium 

cyanescens

Collemataceae.

S&M Category A

No concern; 

Collemataceae 

family not 

targeted by this 

herbicide.

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

No – concern. 

Collemataceae 

family not 

targeted by this 

herbicide.

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly.

No – this family not 

target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Lobaria linita var. 

tenuoir

Lobariaceae

S&M Category A 

(south of 

Snoqualmie Pass 

only)

No concern; 

Lobariaceae

family not 

targeted by this 

herbicide.

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

No concern. 

Lobariaceae

family not 

targeted by this 

herbicide.

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly.

No – this family not 

target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Loiseleuria 

procumbens

Ericaceae

WA-Sensitive

No concern.

Ericaceae family

not target

Concern

No

Ericaceae

not target

Concern Concern Concern Concern

No

Ericaceae

not target

Concern Concern

Luzula arcuata 

ssp. unalaskensis

Juncaceae.

R6-Sensitive

No concern;

Juncaceae

not target

Concern

No

Juncaceae

not target

Concern Concern Concern Concern

No. Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae plant 

families.Grasses not 

affected, so assume 

Juncaceae

also not affected.

Concern Concern

344 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix C

TES or S&M 

Plant Species

Scientific 

Name; Plant 

Family; 

Management 

Status

Aminopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae 

plant families

Chlorsulfuron

Protect 

individual 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Clopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae 

plant families

Glyphosate

Nonselective; 

protect 

from direct 

spray; 

runoff not 

a concern.

Imazapic

Protect 

from direct 

spray, 

drift, 

runoff & 

timing 

after use 

of other 

herbicides

Imazapyr

Nonselective; 

protect 

plants 

from 

direct 

spray, 

drift, 

runoff

Metsulfuron 

methyl

Protect 

individual 

plants from 

direct 

spray, drift, 

runoff, wind 

erosion.

Picloram

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Protect 

from direct spray 

drift, runoff.

Scrophulariaceae, 

Brassicacea, 

Liliaceae less 

susceptible. 

Grasses not 

affected.

Sulfometuron 

methyl

Nonselective; 

Protect 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Triclopyr 

Regional 

FEIS limits 

use of 

triclopyr to 

selective 

application 

techniques

Lycopodiella 

inundata

Lycopodiaceae.

R6-Sensitive

No concern;

Lycopodiaceae

not targeted by 

this herbicide.

Concern

No 

Lycopodiaceae

not target and 

Lycopodiella 

inundata

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern

No. 

Lycopodiella 

inundata

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

Concern.

No. 

Lycopodiella 

inundata

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

No

Lycopodiaceae

not target

No. 

Lycopodiella 

inundata

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern. If 

Aquatic 

Triclopyr 

used, apply 

MR and 

MMs

Lycopodium 

dendroidium

Lycopodiaceae.

WA-Sensitive

No concern;

Lycopodiaceae

not targeted by 

this herbicide.

Concern

No

Lycopodiaceae

not target

Concern Concern Concern Concern

No

Lycopodiaceae

not target

Concern Concern

Microseris 

borealis

Asteraceae.

WA-Sensitive

No Concern -

Asteraceae is not 

targeted by this 

herbicide.

Concern

Concern - 

Asteraceae is 

target

Concern Concern Concern Concern Concern - 

Asteraceae is a target Concern Concern

Montia diffusa

Portulacaceae.

WA-Sensitive

No concern; 

Portulacaceae

family not a 

targeted by this 

herbicide.

Concern

No. 

Portulacaceae

not a target.

Concern Concern Concern Concern No. Portulacaceae

not a target. Concern Concern

Niebla cepahlota

Ramalinaceae.

S&M Category A

No concern; 

Ramalinaceae

family not a 

targeted by this 

herbicide.

Not sure; 

assume worst 

case

No – 

Ramalinaceae 

not target

Concern

Not sure; 

assume 

worst case

Not sure; 

assume 

worst case

Not sure; 

assume worst 

case

No – Ramalinaceae 

not target

Not sure; 

assume worst 

case

Not sure; 

assume 

worst case

Nephroma 

occultum

Nephromataceae.

S&M Category A

No concern; 

Nephromataceae

family not a 

targeted by this 

herbicide.

Not sure; 

assume worst 

case

No – 

Nephromataceae 

not target

Concern

Not sure; 

assume 

worst case

Not sure; 

assume 

worst case

Not sure; 

assume worst 

case

No – 

Nephromataceae not 

target

Not sure; 

assume worst 

case

Not sure; 

assume 

worst case

345 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix C

TES or S&M 

Plant Species

Scientific 

Name; Plant 

Family; 

Management 

Status

Aminopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae 

plant families

Chlorsulfuron

Protect 

individual 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Clopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae 

plant families

Glyphosate

Nonselective; 

protect 

from direct 

spray; 

runoff not 

a concern.

Imazapic

Protect 

from direct 

spray, 

drift, 

runoff & 

timing 

after use 

of other 

herbicides

Imazapyr

Nonselective; 

protect 

plants 

from 

direct 

spray, 

drift, 

runoff

Metsulfuron 

methyl

Protect 

individual 

plants from 

direct 

spray, drift, 

runoff, wind 

erosion.

Picloram

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Protect 

from direct spray 

drift, runoff.

Scrophulariaceae, 

Brassicacea, 

Liliaceae less 

susceptible. 

Grasses not 

affected.

Sulfometuron 

methyl

Nonselective; 

Protect 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Triclopyr 

Regional 

FEIS limits 

use of 

triclopyr to 

selective 

application 

techniques

Packera porteri

Asteraceae

WA-Sensitive

No concern; 

Asteraceae

family not a 

targeted by this 

herbicide.

Concern

Concern - 

Asteraceae is 

target

Concern Concern Concern Concern Concern - 

Asteraceae is a target Concern Concern

Pedicularis 

rainierensis

Scrophulariaceae.

WA-Sensitive

No.

Scrophulariaceae 

not target

Concern. No.

Scrophulariaceae 

not target

Concern. Concern. Concern. Concern.

No.

Scrophulariaceae 

less susceptible

Concern Concern.

Pellaea breweri

Polypodiaceae

WA-Sensitive

No.

Polypodiaceae

not target

Concern. No.

Polypodiaceae

not target

Concern. Concern. Concern. Concern.

No.

Polypodiaceae

less susceptible

Concern Concern.

Pinus albicaulis

Pinaceae

R6-Sensitive

No.

Pinaceae

not target

Concern. No.

Pinaceae

not target

Concern. Concern. Concern. Concern.

No.

Pinaceae

less susceptible

Concern Concern.

Platanthera 

chorisiana

Orchidaceae.

WA-Sensitive

No

Orchidaceae not 

target

No. This 

species usually

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

No.

Orchidaceae not 

target and this 

species usually

occurs along 

water’s edge 

where this 

herbicide would 

not be used.

Concern.

No. This 

species 

usually

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

Concern. 

Aquatic 

Imazapyr 

could be 

used; Apply 

MR and 

MMs

No. This 

species 

usually

occurs along 

water’s edge 

where this 

herbicide 

would not be 

used.

No. Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae plant 

families.

No. This 

species usually

occurs by 

water’s edge 

where this 

herbicide would

not be used.

Concern. If 

Aquatic 

Triclopyr 

used, apply 

MR and 

MMs

Platanthera 

obtusata

Orchidaceae.

R6-Sensitive

No

Orchidaceae not 

target

Concern

No

Orchidaceae not 

target

Concern Concern Concern Concern

No

Orchidaceae not 

target

Concern Concern

Platanthera 

orbiculata var. 

orbiculata

Orchidaceae.

S&M Category C

No

Orchidaceae not 

target

Concern

No

Orchidaceae not 

target

Concern Concern Concern Concern

No

Orchidaceae not 

target

Concern Concern

346 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix C

TES or S&M 

Plant Species

Scientific 

Name; Plant 

Family; 

Management 

Status

Aminopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae 

plant families

Chlorsulfuron

Protect 

individual 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Clopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae 

plant families

Glyphosate

Nonselective; 

protect 

from direct 

spray; 

runoff not 

a concern.

Imazapic

Protect 

from direct 

spray, 

drift, 

runoff & 

timing 

after use 

of other 

herbicides

Imazapyr

Nonselective; 

protect 

plants 

from 

direct 

spray, 

drift, 

runoff

Metsulfuron 

methyl

Protect 

individual 

plants from 

direct 

spray, drift, 

runoff, wind 

erosion.

Picloram

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Protect 

from direct spray 

drift, runoff.

Scrophulariaceae, 

Brassicacea, 

Liliaceae less 

susceptible. 

Grasses not 

affected.

Sulfometuron 

methyl

Nonselective; 

Protect 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Triclopyr 

Regional 

FEIS limits 

use of 

triclopyr to 

selective 

application 

techniques

Platanthera 

sparsiflora

Orchidaceae.

R6-Sensitive

No

Orchidaceae not 

target

Concern

No

Orchidaceae not 

target

Concern Concern Concern Concern

No

Orchidaceae not 

target

Concern Concern

Platismatia 

lacunosa

Parmeliaceae.

S&M Category C

No – 

Parmeliaceae 

family not 

targeted by this 

herbicide.

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

No – 

Parmeliaceae not 

target

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly.

No – Parmeliaceae 

not target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Pseudocyphellaria 

rainierensis

Lobariaceae. 

S&M Category A

No concern; 

Lobariaceae

family not 

targeted by this 

herbicide.

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

No concern. 

Lobariaceae

family not 

targeted by this 

herbicide.

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly.

No – this family not 

target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Ramalina thrausta

Ramalinaceae.

S&M Category A

No concern; 

Ramalinaceae

family not 

targeted by this 

herbicide.

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

No concern. 

Ramalinaceae

family not 

targeted by this 

herbicide.

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly.

No – this family not 

target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Ranunculus 

coolayae

Ranunculaceae. 

WA-Sensitive

No

Ranunculaceae 

family not 

targeted by this 

herbicide.

Concern

No

Ranunculaceae 

not target

Concern Concern Concern Concern

No

Ranunculacea not 

target

Concern Concern

Schistostega 

pennata

Schistostegaceae.

S&M Category A

No concern; 

Schistostegaceae

family not 

targeted by this 

herbicide.

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

No concern. 

Schistostegaceae

family not 

targeted by this 

herbicide.

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly.

No – this family not 

target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

347 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix C

TES or S&M 

Plant Species

Scientific 

Name; Plant 

Family; 

Management 

Status

Aminopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae 

plant families

Chlorsulfuron

Protect 

individual 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Clopyralid

Targets 

Asteraceae, 

Fabaceae, 

Polygonacea, 

Solanaceae 

plant families

Glyphosate

Nonselective; 

protect 

from direct 

spray; 

runoff not 

a concern.

Imazapic

Protect 

from direct 

spray, 

drift, 

runoff & 

timing 

after use 

of other 

herbicides

Imazapyr

Nonselective; 

protect 

plants 

from 

direct 

spray, 

drift, 

runoff

Metsulfuron 

methyl

Protect 

individual 

plants from 

direct 

spray, drift, 

runoff, wind 

erosion.

Picloram

Targets 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae plant 

families. Protect 

from direct spray 

drift, runoff.

Scrophulariaceae, 

Brassicacea, 

Liliaceae less 

susceptible. 

Grasses not 

affected.

Sulfometuron 

methyl

Nonselective; 

Protect 

plants from 

direct spray, 

drift, runoff, 

wind erosion

Triclopyr 

Regional 

FEIS limits 

use of 

triclopyr to 

selective 

application 

techniques

Teloschistes 

flavicans

Teloschistaceae. 

S&M Category A

No concern; 

Tetraphidaceae

family not 

targeted by this 

herbicide.

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

No concern. 

Tetraphidaceae

family not 

targeted by this 

herbicide.

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly.

No – this family not 

target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Tetraphis 

geniculata

Tetraphidaceae. 

S&M Category A

No concern; 

Tetraphidaceae

family not 

targeted by this 

herbicide.

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

No concern. 

Tetraphidaceae

family not 

targeted by this 

herbicide.

Concern

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

Unknown 

impact; 

assume worst 

case and 

mitigate 

accordingly.

No – this family not 

target

Unknown 

impact; assume 

worst case and 

mitigate 

accordingly.

Unknown 

impact; 

assume 

worst case 

and mitigate 

accordingly.

348 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix D 

Appendix D – Road Segments that Pose Higher Risk 

of Herbicide Delivery to Fish Habitat

Roads are the primary conduit for invasive plants to enter the Forest. Treatments along roadsides may 

deliver herbicide to streams via roadside ditches. Ditches may function as an intermittent or perennial 

stream, extending the stream network. Roadside ditches can act as delivery routes or intermittent streams 

during high rainfalls or as settling ponds following rainfall events. 

Geographical Information System (GIS) was used to identify roads that pose higher risk of herbicide 

delivery to fish-bearing streams. Roads located within 200 feet of fish-bearing streams are considered to 

pose the highest threat from herbicide delivery from treatment within the road prism (includes cut and fill 

slopes). At least one segment of each of the roads in Table D- 1 come within 200 feet of a fish bearing 

stream. Please note that not all roads are named. 

About 1,200 acres of invasive plants lie within 25 feet of roads that pose higher risk of herbicide delivery 

to fish bearing streams. 

Maps of the roads segments identified as higher risk follow. Fish bearing stream crossings are also shown. 

Table D- 1. Roads that Pose Higher Risk of 

Herbicide Delivery to Fish-Bearing Streams

Road ID Road Name

1040000 OLSON CR

1050000 DIOBSUD CR

1060000 BACON CR

1060020 SETTLER

1064000 W BACON CR

1065000 S BACON

1100000 BAKER LAKE HWY

1100013 SHAKE BOLT

1100017 KOMO POWERHOUSE

1105011 DEPRESSION LAKE

1107000 ANDERSON

1107011 SIDEHILL

1118000 DRY CR

1118012 HORSESHOE COVE CG

1118013 NORTH BAY VIEW CG

1122000 LOWER SANDY CR

1122011 LOWER SANDY BRANCH

1125000 W SANDY CR

1130000 MARTEN LAKE

1137000-A

PANOROAMA PT CG BOAT 

RAMP

Road ID Road Name

1140000 TARR PIT

1142000-A RESORT SPUR-A

1142000-B RESORT SPUR-B

1144000 MOROVITZ CR

1144012 MOROVITZ CG

1148000 OLD LAKE

1150000-A SHANNON CR CG-A

1160000 E SHANNON CR

1200000 LOOMIS NOOKSACK

1200011 LOWER ROCKY CR

1260000 SISTERS MTN

1400000 JACKMAN-THUNDER

1500020 WITHDRAWAL

1530000 MARBLE CR CG

1550000 IRENE CR

1570000 FOUND CREEK

1571000 SONNY BOY

1600000 ILLABOT

1610000 WEST BOUNDARY

1700000 FINNEY-CUMBERLAND

1715000 SUTTER MTN

1730000 CLENDENEN CR

1740111 FINNEY GS

1749000 VERRILL

349 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix D

Road ID Road Name

1750000 DEFOREST CR

1755000 LITTLE DEER PEAK

1800000 SEGELSEN

1820000 WESTSIDE HIGGINS

1820015 TALUS

1840000 HAWKINS LAKE

1850000 CONEY PASS RD 3403

1870000 SEGEL

2000000 MOUNTAIN LOOP HIGHWAY

2010000 FRENCH CR

2010011 FRENCH CR CG

2020000 LITTLE FRENCH CREEK

2030000 MOOSE CR

2040000 SQUIRE CR

2060000 CLEAR CREEK

2079000 2079

2080000 FALLS CR

2130000 N SIDE DANS CR

2200000 NORTH SIDE SAUK RIVER

2200012 BOAT LAUNCH

2200110 2200110

2300000 WHITECHUCK

2300016 OWL CR CG

2430000 DECLINE

2435000 UPPER DECLINE

2500000 S SIDE SUIATTLE

2500016 STRAIGHT CR CG

2500017 WET SWAMP -SEED ORCHARD2500019 CAPTIAN MOSES SEED ORCH*

2509000 ALL CREEK PIT SITE

2520000 OLD STRAIGHT

2530000 INDIAN SPUR

2540000 HARRIET CREEK

2540012 LOWER MARSH

2600000 SUIATTLE ROAD

2600014 W BUCK CR CG

2600016 SUIATTLE GUARD STA

2600016-A SUIATTLE GUARD STA LOOP A

2600025 SULPHUR CR CG

2600025-A SULPHUR CR CG-A

2600027 SUIATTLE TRAIL HEAD

Road ID Road Name

2640000 GRADE CR

2642000 W GRADE CR

2670000 DOE CR

2700000 STRAIGHT CR

2800000 NORTH FORK STILLY

2810000 NORTH MTN

2820000 N FK STILLAGUAM

3010035 GALLOP CR

3018000 HUMPY

3020000 DOUGLAS FIR CG

3020000-A DOUGLAS FIR CG-A

3030000 NOOKSACK CG

3030000-A NOOKSACK CG SPUR-A

3035000 FOURMILE

3045000 EXCELSIOR CG

3066000 SWAMP CR

3070000 RAZOR HONE

3071000 ANDERSON CR

3100000 CANYON CR

3130000 KIDNEY CR

3140000 CANYON RIDGE

3142000 BANYON

3160000 WHISTLER CR

3170000 BEARPAW

3200000 HANNEGAN

3200015 NANNY GOAT

3200024 SEFRIT

3300000 WELLS CR

3400000 NO FK NOOKSACK

3700000 DEADHORSE

3700030 TAIL HOLD

3722000 BRIDGE CAMP

3800000 MID FK NOOKSACK

3800023 RIDLEY CR

3900000 GLACIER CR

3910000 THOMPSON CR

3914000 BEAVER CR

3940000 SMITH-BASIN

4000040 ESWINE CG

4000043 DICK SPERRY CG

4000045 SPERRY IVERSON PARKING

350 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix D

Road ID Road Name

4000050 MARBLE GULCH PARKING

4000060 COAL CR BAR CG

4000064 BEAVER CR CG

4002000 TURLO CR CG

4004000 VERLOT CG

4004000-A VERLOT CG SPUR -A

4008000 HEMPLE CR CG

4009000 HEMPLE CR

4012000 LOWER HEMPLE

4030000 MALLARDY CR

4031000 BENDER CR

4032000 BOARDMAN RIDGE

4036000 RED BRIDGE CG

4037000 RIVER ROAD

4041000 SILVER

4052000 DEER CREEK

4059000 BIG FOUR TRAILHEAD

4060000 COAL LAKE

4062000 BEAVER CR

4065000 SUNRISE MINE

4110014 LOWER GREEN MTN

4111000 CANYON LAKE

4150000 N FK CANYON CR

4200000 PILCHUCK

4210000 LOWER PILCHUCK

4220000 JODE

4900000 SLOAN CREEK

4900020 SLOAN CR CG

5000000 CEDAR MAINLINE

5200000 TACOMA PASS

5200210 --

5230000 PIONEER CR.

5400000

STAMPEDE PASS/GREEN RIVER 

RD

5400610 BORUP

5403000 LIZARD LAKE/BORUP

5403108 --

5415000 LAST CHANCE

5460000 SMAY CREEK

5460510 --

5500000 TINKHAM

Road ID Road Name

5500210 --

5500410

POWERLINE ACCESS-HANSEN 

CR

5500411 SOUTHFORK THIN

5501000 TINKHAM CG

5600000 MIDDLE FORK/GOLDMEYER

5600520 TAYLOR RIVER CG

5640000 QUARTZ CREEK

5640101 TAYLOR RIVER

5700000 CO. RD.

5710000 CALLIGAN LAKE

5720000 SUNDAY CREEK

5730000 NORTH FORK ROAD

5800000 DENNY CREEK

5810000 DENNY CREEK CG

5830000 FRANKLIN FALLS TRAILHEAD

6000610 2691 RIVERVIEW CG

6000700 --

6000820 2634 DECEPTION CR

6020000 276 LK SERENE

6020312 HUC

6024000 278 BARCLAY CR

6024210 278-C BARCLAY STUB

6024510 HUC

6030000 2612 LOW CR

6030110 --

6126110 --

6126120 --

6200000 NORTH FORK TOLT RD 261

6220000 2701 PROCTOR CR.

6260000 SOUTH FORK TOLT

6300000 290 N. FK. SKYKOMISH

6300390 --

6300410

TROUBLESOME CR CG-BOTH 

LOOPS

6300440 2807 SAN JUAN CG

6300510 GARLAND HOT SPRINGS

6300750 --

6300820 2829 DEER FALLS

6305000 LEWIS CREEK/N HAYBROOK TS

6330000 282 SALMON CR.

351 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix D

Road ID Road Name

6335000 291 MINERAL CITY

6340000 2863 SILVER CRK.

6400110 2606 MONEY CR CG

6410000 2516 MILLER RIV

6410210 2516-B CASHMAN

6412000 2522 E.F. MILLER RIVER

6420000 2601 MONEY CR

6420350 TRAMWAY

6422000 2633 TEMPLE MTN

6422105 --

6435000 260-A MALONEY CR.

6500000 280 BECKLER RIVER

6500104 PAT'S KNOB

6510000 2632 BOLT CRK

6510050 SEC 18

6520000 273 JOHNSON CR

6530000 270 RAPID RIVER

6550000 280 BECKLER RIV

6800000 2622 FOSS RIV

6810000 2622-A E FK FOSS

6830000 2605 TONGA RDG.

6835000 W FORK FOSS

7000000 GREENWATER

7000118 HUC

7000119 HUC

7010000 MIDNIGHT CREEK

7010110 FORTUNE

7013000 FOSS CREEK

7015000 UPPER FOSS CREEK

7020000 SLIDE WEST

7020110 --

7030000

HIMES/TWIN CAMP/WHISTLER 

CREEK

7030110 LOWER HIMES CAMP

7031000 SKIN ALLEY

7033000 GREENWATER LAKES TRAIL

7138000 HUC

Road ID Road Name

7140000 OLD TWIN CAMP

7148000 DALLES CG

7150000 DALLES SUMMER HOMES

7160000 BUCK CREEK

7160130 --

7180000 SILVER SPRINGS CG

7180000-A SILVER SPRINGS CG-A

7180000-C SILVER SPRINGS CG-C

7190610 CRYSTAL MTN SPUR

7200000 TWENTY-EIGHT MILE CREEK

7200148

WEST TWENTY EIGHT MILE 

CREEK

7220000 ECHO LAKE

7300000 HUCKLEBERRY CREEK

7300160 LOST CREEK

7300195 LOWER ELEANOR CREEK

7305000 DICKMAN

7320000 WEST HUCKLEBERRY

7400000 WEST FORK/MARTIN GAP

7400050

MALATNITCH PARK/HAZARD 

CREEK

7410000

WRONG CREEK/W FORK 

WHITE RIVER

7415000 WEST VALLEY/HAZZARD CREEK

7415210 HAZZARD SEED

7415212 --

7430000 VIOLA CREEK

7500000 JIM CREEK/HALLER PASS

7500301 HANK CREEK

7550000 EAST VALLEY

7810000 CAYADA CREEK

9031000 MASON LAKE TRAILHEAD

9035000 ASAHEL CURTIS

9040000 ALPENTAL

352 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix D

Figure D- 1. Invasive plant treatment project area overview map for roads with higher risk of 

herbicide delivery to fish-bearing streams

353 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix D

Figure D- 2. Roads with higher risk of herbicide delivery to fish bearing streams (map reference 1). 

Fish bearing stream road crossings are indicated

354 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix D

Figure D- 3. Roads with higher risk of herbicide delivery to fish bearing streams (map reference 2). 

Fish bearing stream road crossings are indicated

355 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix D

Figure D- 4. Roads with higher risk of herbicide delivery to fish bearing streams (map reference 3). 

Fish bearing stream road crossings are indicated

356 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix D

Figure D- 5. Roads with higher risk of herbicide delivery to fish bearing streams (map reference 4). 

Fish bearing stream road crossings are indicated

357 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix D

Figure D- 6. Roads with higher risk of herbicide delivery to fish bearing streams (map reference 5). 

Fish bearing stream road crossings are indicated.

358 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix D

Figure D- 7. Roads with higher risk of herbicide delivery to fish bearing streams (map reference 6). 

Fish bearing stream road crossings are indicated

359 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix D

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360 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix E 

Appendix E – Additives, Impurities And Inert 

Ingredients

Introduction 

Inert compounds (inerts) are those that are intentionally added to a formulation, but have no herbicidal 

activity and do not affect the herbicidal activity. Inerts are added to the formulation to facilitate its 

handling, stability, or mixing. Impurities are inadvertent contaminants in the herbicide, usually present as 

a result of the manufacturing process. 

Adjuvants are compounds added to the formulation to improve its performance. They can either enhance 

the activity of an herbicide’s active ingredient (activator adjuvant) or offset any problems associated with 

its application (special purpose or utility modifiers). Surfactants are one type of adjuvant that makes the 

herbicide more effective by increasing absorption into the plant. Many of the inert ingredients are 

proprietary in nature and have not been tested on laboratory species. However, confidential business 

information (i.e. the identity of proprietary ingredients) was used this information in the preparation of the 

herbicide risk assessments.

The following types of surfactants have been reviewed in risk assessments and may be used to help 

herbicides adhere to target plants (Bakke 2003, 2007). Examples of trade names are also provided. 

Surfactants help reduce drift and abate risk of off-site movement of herbicides. The effects of using these 

ingredients, along with other inerts and metabolites, have been disclosed in the R6 2005 FEIS (Chapters 

4.4, 4.5, 4.7 along with Appendices P and Q; and the Biological Assessment prepared for ESA 

consultation). 

Limitations are proposed for use of some surfactants associated with potential adverse effects on human 

health, wildlife and aquatic ecosystem elements (see discussions in Chapter 3). 

Ethoxylated fatty amines (Cationic) 

§ EntryTM II (Monsanto Company) 

POEA (Polyethoxylated Tallow Amine - Roundup® (non-aquatic glyphosate) has 15% 

POEA. The POEA is associated with adverse effects on aquatic ecosystems. These risks are 

abated by project design criteria. 

Alkylphenol and Alcohol ethoxylate-based surfactants (non-ionic) 

§ R-11® Spreader Activator (Wilbur-Ellis Company) 

§ Activator 90 (Loveland Industries) 

§ X-77® (Loveland Industries) 

§ Latron AG-98TM (N) (Dow AgroSciences LLC)

§ Cide-kick®, Cide-kick® IITM (Brewer International)

These surfactants usually include an alcohol as a solvent (isopropanol (X-77®, AG-98TM), 

butanol (R-11®, AG-98TM (N)), glycol (AG-98TM (N), Activator 90)), a silicone defoamer 

(polydimethylsiloxane), and water. 

§ Activator N.F. (Loveland Industries) 

361 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix E 

Nonylphenol Polyethoxylate (NPE) is a common non-ionic surfactant associated with some 

risks to human health and the environment. This ingredient would not be used on this 

project. 

Silicone-Based Surfactants

§ Sylgard® 309 (Wilbur-Ellis Company) –silicones 

§ Freeway® (Loveland Industries) –silicone blend 

§ Dyne-Amic® (Helena Chemical Company) - silicone blend

§ Silwet L-77® (Loveland and Helena) - silicones

Also known as organosilicones, these are increasing in popularity because of their superior 

spreading ability. This class contains a polysiloxane chain. Some of these are a blend of 

non-ionic surfactants (NIS) and silicone while others are entirely silicone. The combination 

of NIS and a silicone surfactant can increase absorption into a plant so that the time 

between application and rainfall can be shortened. Blends normally include an alcohol 

ethoxylate, a defoamer, and propylene glycol. 

Oils

Surfactants that are primarily oil-based have been gaining in popularity especially for the control of 

grassy weeds. Oil additives function to increase herbicide absorption through plant tissues and increase 

spray retention. They are especially useful in applications of herbicides to woody brush or tree stems to 

allow for penetration through the bark. Oil adjuvants are made up of either petroleum, vegetable, or 

methylated vegetable or seed oils plus an emulsifier for dispersion in water. 

Vegetable oils 

The methylated seed oils are formed from common seed oils, such as canola, soybean, or cotton. They act 

to increase penetration of the herbicide. These are comparable in performance to crop oil concentrates. In 

addition, silicone-seed oil blends are also available that take advantage of the spreading ability of the 

silicones and the penetrating characteristics of the seed oils.

The U.S. Food and Drug Administration (FDA) consider methyl and ethyl esters of fatty acids produced 

from edible fats and oils to be food grade additives (CFR 172.225). Because of the lack of exact 

ingredient statements on these surfactants, it is not always clear whether the oils that are used in them 

meet the U.S. FDA standard. 

§ MSO® Concentrate Methylated Seed Oil (Loveland Industries)

§ Hasten® (Wilbur-Ellis Company)

§ The surfactant in PathfinderTM II (a triclopyr formulation) 

§ Improved JLB Oil Plus (Brewer International) 

§ Cide-Kick and Cide-Kick II (Brewer International) 

Blends of vegetable oils and silicone-based surfactants

§ Syl-tacTM (Wilbur-Ellis Company)

§ PhaseTM (Loveland Industries)

Crop oils and crop oil concentrates 

These are normally derivatives of paraffin-based petroleum oil. Crop oils are generally 95-98 percent oil 

with 1-2 percent surfactant/emulsifier. Crop oils also promote the penetration of a pesticide spray. 

362 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix E 

Traditional crop oils are more commonly used in insect and disease control than with herbicides. Crop oil 

concentrates are a blend of crop oils (80-85 percent) and a nonionic surfactant (15-20 percent). The 

purpose of the nonionic surfactant in this mixture is to emulsify the oil in the spray solution and lower the 

surface tension of the overall spray solution. Kerosene is found in the triclopyr formulation Garlon IV. 

This formulation would not be broadcast nor used within 150 feet of surface water bodies or wetlands. 

Adjuvants Approved For Aquatic Environments

Adjuvants that are approved for used in aquatic environments in Washington State (see Table E- 1 below) 

meet the following criteria: 

The product must fulfill all requirements for registration of a food/feed use spray adjuvant in 

Washington 

The spray adjuvant must be either slightly toxic or practically non-toxic to freshwater fish (such as 

rainbow trout, coho salmon or other cold water species) 

The spray adjuvant must be moderately toxic, slightly toxic or practically non-toxic to aquatic 

invertebrates (such as Daphnia spp.) 

The spray adjuvant formulation must contain less than 10 percent alkylphenol ethoxylates 

(including phosphate esters) 

Herbicide applications within the aquatic influence zone for the MBS invasive plant treatment project 

would only include adjuvants that are approved for aquatic use in Washington. 

363 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix E 

Table E- 1. Adjuvants Approved for use in Aquatic Environments, Washington 2012

Product name Registrant Principal 

Functioning Agents

Acute toxicity - 

rainbow trout

Acute toxicity - 

daphnids

Agri-Dex Helena Chemical 

Company

Petroleum oil, 

polyoxyethylene 

sorbitan fatty acid 

ester, sorbitan fatty 

acid ester

LC50 (96 hour) 

>1000 mg/l, 

Practically nontoxic

LC50 (48 hour) 

>1000 mg/l, 

Practically non-toxic

AquaSurf Monterey 

AgResources

Petroleum oil, 

polyoxyethylene 

sorbitan fatty acid 

ester

LC50 (96 hour) 

>100 mg/l, 

Practically nontoxic

LC50 (48 hour) 

>100 mg/l, 

Practically non-toxic

Bond CPS Loveland 

Products

Synthetic latex, 

alcohol ethoxylate

LC50 (96 hour) 

190 mg/l, 

Practically nontoxic

LC50 (48 hour) 614 

mg/l, Practically 

non-toxic

Bronc Max Wilbur-Ellis 

Company

Ammonium sulfate, 

dodecylbenzenesulfonic acid sodium 

salt, citric acid, 

dimethylpoly-siloxane

LC50 (96 hour) 

≥100 mg/l, Slightly 

toxic to Practically 

non-toxic

LC50 (48 hour) 

>100 mg/l, 

Practically non-toxic

Bronc Plus Dry-EDT Wilbur-Ellis 

Company

Ammonium sulfate, 

urea, polyoxyethylenepolyoxypropylene 

copolymer, citric acid, 

polyacrylamide, 

dimethylpoly-siloxane

LC50 (96 hour) 

382.9 mg/l, 

Practically nontoxic

LC50 (48 hour) 

223.6 mg/l, 

Practically non-toxic

Class Act NG Winfield Solutions

Ammonium sulfate, 

saccharides, alkyl 

polyglycoside

LC50 (96 hour) 

447 mg/l, 

Practically nontoxic

EC50 (48 hour) 377 

mg/l, Practically 

non-toxic

Competitor Wilbur-Ellis 

Company

Modified vegetable 

(seed) oil, 

polyethylene glycol 

fatty acid ester, 

polyoxyethylene 

sorbitan fatty acid 

ester

LC50 (96 hour) 95 

mg/l, Slightly toxic

LC50 (48 hour) 

>100 mg/l, 

Practically non-toxic

Cut Rate Wilbur-Ellis 

Company

Ammonium sulfate, 

citric acid

LC50 (96 hour) 

782.2 mg/l, 

Practically nontoxic

LC50 (48 hour) 

223.6 mg/l, 

Practically non-toxic

Cygnet Plus Brewer International

Limonene, modified 

vegetable (seed) oil, 

alcohol ethoxylate

EC50 (96 hour) 45 

mg/l, Slightly toxic

EC50 (48 hour) 6.6 

mg/l, Moderately 

toxic

Destiny HC Winfield Solutions

Modified vegetable 

(seed) oil, 

saccharides, sorbitan 

fatty acid ester

LC50 (96 hour) 

21.71 mg/l, 

Slightly toxic

LC50 (48 hour) 

28.63 mg/l, Slightly 

toxic

Dyne-Amic Helena Chemical 

Company

Modified vegetable 

(seed) oil, 

polysiloxane polyether 

copolymer, 

alkylphenol ethoxylate

LC50 (96 hour) 

23.2 mg/l, Slightly 

toxic

LC50 (48 hour) 60 

mg/l, Slightly toxic

364 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix E 

Product name Registrant Principal 

Functioning Agents

Acute toxicity - 

rainbow trout

Acute toxicity - 

daphnids

Exciter CPS Western Farm 

Service 

Ammonium sulfate, 

ammonium nitrate, 

alkyl polyglycoside

LC50 (96 hour) 

>100 mg/l, 

Practically nontoxic

EC50 (48 hour) 7.7 

mg/l, Moderately 

toxic

Fraction Kalo Ammonium sulfate, 

citric acid

LC50 (96 hour) 

782.2 mg/l, 

Practically nontoxic

LC50 (48 hour) 

223.6 mg/l, 

Practically non-toxic

InterLock Winfield Solutions

Modified vegetable 

(seed) oil, 

polyoxyethylene 

sorbitan fatty acid 

ester, vegetable 

(seed) oil

LC50 (96 hour) 

>100 mg/l, 

Practically nontoxic

LC50 (48 hour) 

>100 mg/l, 

Practically non-toxic

Kinetic Helena Chemical 

Company

Polysiloxane polyether 

copolymer, 

polyoxypropylenepolyoxyethylene 

copolymer

LC50 (96 hour) 

13.9 mg/l, Slightly 

toxic

LC50 (48 hour) 60.7 

mg/l, Slightly toxic

Level 7 Winfield Solutions Ammonium sulfate, 

citric acid, saccharides

LC50 (96 hour) 

>100 mg/l, 

Practically nontoxic

EC50 (48 hour) 

>100 mg/l, 

Practically non-toxic

LI 700 CPS Loveland 

Products

Lecithin, propanoic 

(propionic) acid, 

alkylphenol ethoxylate

LC50 (96 hour) 

130 mg/l, 

Practically nontoxic

LC50 (48 hour) 170 

mg/l, Practically

Liberate Loveland Products

Lecithin, alcohol 

ethoxylate, modified 

vegetable (seed) oil.

LC50 (96 hour) 

17.6 mg/l Slightly 

toxic

EC50 (48 hour)

9.3 mg/l. Moderately 

toxic

Magnify Monterey 

AgResources

Ammonium sulfate, 

ammonium nitrate, 

alkyl polyglocoside.

LC50 (96 hour) > 

100 mg/l, 

Practically nontoxic

EC50 (48 hour)

7.7 mg/l. Moderately 

toxic

One-AP XL Kalo 

Ammonium sulfate, 

urea, polyoxyethylenepolyoxypropylene 

copolymer, citric acid, 

polyvinyl polymer 

(polyacrylamide), 

dimethylpoly-siloxane

LC50 (96 hour) 

382.9 mg/l, 

Practically nontoxic

LC50 (48 hour) 

223.6 mg/l, 

Practically non-toxic

Pro AMS Plus Activator 

Penetrant IAP 

Ammonium sulfate, 

ammonium nitrate, 

alkyl polyglycoside

LC50 (96 hour) 

>100 mg/l, 

Practically nontoxic

EC50 (48 hour) 7.7 

mg/l, Moderately 

toxic

Sinker Helena Chemical 

Company

Polyvinyl polymer 

(Polyacrylamide), 

alkylphenol 

ethoxylate, sorbitan 

fatty acid ester

LC50 (96 hour) 

750 mg/l, 

Practically nontoxic

LC50 (48 hour) 

>1000 mg/l, 

Practically non-toxic

Spray-Rite J R Simplot Ammonium sulfate, 

citric acid

LC50 (96 hour) 

782.2 mg/l, 

Practically nontoxic

LC50 (48 hour) 

223.6 mg/l, 

Practically non-toxic

365 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix E 

Product name Registrant Principal 

Functioning Agents

Acute toxicity - 

rainbow trout

Acute toxicity - 

daphnids

Superb HC Winfield Solutions

Petroleum Oil, 

saccharides, 

polyoxyethylene, 

sorbitan fatty acid 

ester

LC50 (96 hour) 

45.0 mg/l, Slightly 

toxic

LC50 (48 hour) 

>1004 mg/l, 

Practically non- toxic

Tactic CPS Loveland 

Products

Synthetic latex, 

propylene glycol, 

alcohol ethoxylate, 

polysiloxane polyether 

copolymer

LC50 (96 hour) 

>100 mg/l, 

Practically nontoxic

EC50 (48 hour) 310 

mg/l, Practically 

non-toxic

Tronic Kalo 

Vegetable (seed) oil 

ethoxylate, tall oil fatty 

acids

LC50 (96 hour) 

>200 mg/l, 

Practically nontoxic

EC50 (48 hour) 28.9 

mg/l, Slightly toxic

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix F

Appendix F - Recently Completed, Currently Being Implemented, Ongoing 

and Foreseeable Future Projects

Table F- 1. Cumulative effects projects – recently completed projects (2010-2014) with overlap of invasive plant action area

Recent Past Project 

Name

Project Type/Could this 

type of project contribute 

to invasive plant spread?

Project Description When 

Completed

General Location/ TRS/ and invasive 

plant Treatment Analysis Area

Baker Lake ATM Road 

System

Restoring roads and 

landings/ closing roads/yes

Decommission, close, seasonally close, or upgrade 

various portions of the 1100 and 1106 road system. 2011

Baker Lake watershed, Sandy Creek 

and Rocky Creek T37N, R8E and 

T37N, R9E. TAA #43. 

WSDOT Pedestrian 

Walkway and Turn Lane

Roads (maintenance, 

construction, reconstruction 

and use)/yes

Construction of a turn lane and pedestrian bridge on 

and over US 2 at crest of Stevens Pass 2011

Stevens Pass Ski Area, ~12 miles E of 

Skykomish in Tye River watershed. 

TAA #15. 

White Chuck – ERFO 

Road Repair

Roads (maintenance, 

construction, reconstruction 

and use)/yes

Repair 2003 and 2006 flood damage to Road 23; 

decommission upper portion of Road 23 2010

Road 23

T31N; R11E; Sec. 13-18

T31N; R12E; Sec. 19. TAA #26

Road 1106 Reroute and 

decommission Closing roads/yes

Decommissioned 0.34 mile of Road 1106 and rerouted 

dam access road on Road 1112 and 015 spur, with 

500 ft. of connector road.

2010 Between Komo Kulshan guard station 

and Baker Lake/ T37N, R8E, TAA #43. 

Troublesome Creek 

Bridge Replacement

Roads (maintenance, 

construction, reconstruction 

and use)/ no

Replace flood damaged bridge 2013 T28N; R11E; Sec. 21 TAA#19

Road 11 Sulphur Creek 

Bridge Replacement 

Roads (maintenance, 

construction, reconstruction 

and use)/ yes

Whatcom County bridge replacement project. 2011 Baker Lake, Komo Kulshan vicinity. 

T37N, R8E, sec PB42. TAA #43. .

Relocate road 542 

Roads (maintenance, 

construction, reconstruction 

and use)/ yes

Relocate road away from high erosion area, replace 

existing culvert with bridge 2010 T40N; R7E; Sec. 36 TAA #45

WSDOT US 2 Slope 

Stabilization Road maintenance/yes

Project activities include: scaling, trim blasting, 

installation of rock bolts, rock dowels, cable net, and 

shotcrete, installation of horizontal drains with slotted 

PVC pipe and removal of hazard trees along the slope 

crest and existing rock slope face

2013

~10 miles east of Skykomish, Tye 

River watershed. US 2 – Section 1 

(MP 62.60 – 63.00), Section 2 (MP 

63.00 – 63.20), Section 3 (MP 63.90 – 

64.10). TAA # 15. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix F

Recent Past Project 

Name

Project Type/Could this 

type of project contribute 

to invasive plant spread?

Project Description When 

Completed

General Location/ TRS/ and invasive 

plant Treatment Analysis Area

Mountain Loop Marten 

Creek Buttress

Roads (maintenance, 

construction, reconstruction 

and use)/no

remove and replace existing buttress with benched in 

buttress 2010 T30N; R9E; Sec. 23 SE 1⁄4 

TAA#23 

Excelsior Campground 

Road Reconstruction

Roads (maintenance, 

construction, reconstruction 

and use)/yes

build 380’ long bypass road, reconfigure existing road, 

parking areas and turnaround area 2012 T40N; R8E; Sec. 31 SE 1⁄4 SW 1⁄4 

TAA#41 

Road 39

(Glacier Ck Rd)

Roads (maintenance, 

construction, reconstruction 

and use)/yes

Repair 60’ of road damaged due to slide 2013 T39N; R7E; Sec. 21

TAA #44

Forgotten Thin Plus Vegetation 

management/yes 400 acres of thinning, no riparian treatment 2013

Sauk River watershed

T31N; R10E; Secs. 13 TAA #25) , 23-

25 (TAA #24)

T31N; R11E; Secs. 30-32. (TAA #24)

PSE Pole Replacement Vegetation 

Management/yes

Replacement of two utility poles; necessitated 

relocating the alignment further from White River and 

cutting ~50 trees. 

2010 Adjacent to White River. T19N, R10E, 

Secs. 30 & 31. TAA#4. 

Baker Lake Resort 

Redevelopment (Swift 

Creek Campground) Recreation/yes

Decommission Baker Lake Resort and construct 30-50 

unit campground 2011 Northwest shore of Baker Lake

T37N, R9E, Sec. 5. TAA #43. 

Old Sauk Trailheads 

and Trail Reconstruction Recreation/yes

reconstruct 2 trailheads and construct barrier free 

interpretive trail loop, additional parking, toilets and 

trailhead facilities

2012 T31N; R10E; Secs. 4, 5 & 9 TAA#27

T32N; R10E; Sec. 31 TAA#27

Stevens Pass Ski Area 

Master Development 

Plan Phase I

Recreation/yes

Construct ~7.2 miles of mountain bike trails and 

replace existing water treatment facility at Ski Area. 

Partially complete, continuing implementation

2012

~12 miles E of Skykomish in Tye River 

watershed 

T26N; R14E; Secs. 13 & 14. TAA #15. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix F

Table F- 2. Ongoing/Current Projects that Overlap Treatment Analysis Areas

Currently Being 

Implemented or 

Ongoing Project 

Name

Project Type/Could this 

type of project contribute 

to invasive plant spread?

Project Description

Currently In 

Progress or 

Ongoing Project

General Location/ TRS/ and invasive 

plant Treatment Analysis Area

Apex Mine Mill Site Mining & geothermal / Yes Reopen portal & mine ore In progress South Fk Skykomish River watershed. 

Mill: T26N; R11E; Sec.21.TAA #20.

Campground Rental 

and Maintenance Recreation / yes Maintenance activities associated with rental 

of campgrounds located on NFS lands Ongoing

Buck Creek CG T32N; R11E: Sec 13 

TAA #32).

Sulphur Creek CG T32N; R12E; Sec. 

24 (TAA #53). 

Suiattle Guard Station T32N; R11E; 

Sec. 18 (TAA #33). 

Monte Cristo CERCLA 

Clean-up

Recreation and 

administrative sites/yes

superfund site – clean up at mining town site

reconstruct 4.5 miles of road to site In progress T29N; R11E; Sec. 21TAA#47 

Mt Loop Gateway & 

Beaver Lake Trailhead 

Enhancement

Recreation/ yes

Construct visitor info station and reconstruct 

Beaver Lake Trailhead and trail. Install 

interpretive signs

In progress T31N; R10E; Secs. 5 & 14

TAA #27

Baker Lake Dispersed 

Campsite Hardening Recreation/ yes

Plan to harden 3-6 dispersed campsites on 

both sides of Baker Lake, various locations, 

including parking spot hardening (mitigation 

measure for Baker Lake Hydro relicense).

In progress Various locations on Baker Lake. TAA 

#43.

White River Recreation 

Residence Well and 

Septic SUPs

Recreation/ yes

Install community well and septic systems 

for existing recreation residences in Silver 

Creek vicinity

In progress Hwy 410, Silver Springs Campground. 

TAA #5. 

Kelly Creek Horseshoe 

Tunnel Trail Recreation/ yes Relocate Kelly Creek TH and construct 3.0 

miles of trail In progress T26N; R12E; Secs. 12, 13, 24

T26N; R13E; Sec. 18 TAA# 15

Stevens Pass Ski Area 

Master Development 

Plan Phase II 

Recreation/yes

Additional lift development and base area 

facilities; new mountain bike trails and 

parking facilities

In progress ~12 miles east of Skykomish in Tye 

River watershed. TAA #15. 

Excelsior Campground 

Maintenance Recreation/yes Vegetation brushing, cleaning, painting, and 

hazard tree removal Ongoing Mt Baker Hwy, Excelsior Campground. 

T40N; R8E; Sec. 31. TAA #45. 

Crystal, Stevens Pass, 

The Summit, Mt Baker 

Ski Area Maintenance

Ski Area/yes

Parking lot maintenance, snow remove, 

ditchline cleaning, construct waterbars, clear 

ski runs, vegetation management

Ongoing

T24N; R14E; Secs. 13 & 14 No TAA

T23N; R11E; Secs. 29, 32 & 33 

TAA#11 

T22N; R11E; secs. 4, 16 & 22 TAA#11

T39N; R9E; Secs. 18-20 No TAA

T26N; R13E, Sec.14-15, 22-23

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix F

Currently Being 

Implemented or 

Ongoing Project 

Name

Project Type/Could this 

type of project contribute 

to invasive plant spread?

Project Description

Currently In 

Progress or 

Ongoing Project

General Location/ TRS/ and invasive 

plant Treatment Analysis Area

TAA#15

T17N; R10E; sec 19&30 TAA#06

T17N; R11E secs. 24-26 TAA#06

SF Snoqualmie Road 

Storage Road closures/ yes

Convert 20.5 miles of road to trails; Store 

2.7 miles; reduce 2.1 miles from ML 3 to ML 

2; construct 0.96 mile of new trail

Ongoing

T22N; R9E Secs. 1-4, 9, 10, 12 & 13 

TAA#11 

T22N; R10E; Secs. 7,8,15, 17-22 & 27-

29

TAA#11 

South Fork Skykomish 

Road Decommission Road closure/ yes

Decommission ~18 miles and close ~19 

miles of roads in the South Fork Skykomish 

drainage

In progress Lower Beckler, Miller and Foss 

watersheds. TAAs #16,20,49. 

Suiattle Access and 

Travel Management Road closure/ yes

Maintain 66 miles of road as open, close 23 

miles of road, and decommission 51 miles of 

road

In progress Suiattle River watershed. TAA #41. 

SF Skykomish Roads Road closure/ yes

store 14 miles of road

decommission 19 miles of road (road 6025 

and its spurs, spurs off of roads 6020, 6024, 

6030, 6835, & 6846)? Other TRS?

In progress

T27N; R10E

T26N; R10E

T26N; R11E

T26N; R12E

TAA#20, TAA#49

Grizzly bear closures Road closures/ yes

Decommission Road 1107 and spurs to 

expand core habitat (measures for Baker 

Lake Hydro relicense).

In progress East side of Baker Lake, TAA #43. 

ERFO Road Repair Roads -Restoring roads 

and reconstruction / yes

Repair 2006 flood damage to Road 26 at 

several mileposts. Includes reroute using 

Road 2670. 

On-going Lower Suiattle Watershed. T32N, R11E. 

TAA #32 and 33.

Annual Road and Trail 

Maintenance

Roads (maintenance, 

construction, reconstruction 

and use). yes

Routine road and trail maintenance on open 

roads and accessible trails in watershed

Road maintenance work (brushing, blading, 

grading) on Road 26. 

Rock Pit maintenance.

Ongoing-Occurs 

annually.

Brushing every 3 

years; Glade and 

blade 2 times per 

year

Suiattle River watershed. T33 N, R10 

and 11 E. T 32N, R11 and 12E. 

Forest Road 26 and vicinity. TAA #33. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix F

Currently Being 

Implemented or 

Ongoing Project 

Name

Project Type/Could this 

type of project contribute 

to invasive plant spread?

Project Description

Currently In 

Progress or 

Ongoing Project

General Location/ TRS/ and invasive 

plant Treatment Analysis Area

Annual Road 

Maintenance

Roads (maintenance, 

construction, reconstruction 

and use)/ yes

Highway 410 maintained by WA Dept. of 

Transportation and Crystal Mountain Blvd 

maintained by Pierce County, with Crystal 

Mountain Ski Area responsible for snow 

removal Forest Roads maintained by MBS. 

Maintenance may include culvert and ditch 

cleanout, surface blading, and vegetation 

clearing within the rights-of-way. 

Ongoing-Occurs 

annually

Highway 410, Crystal Mountain 

Boulevard, and Forest Road segments 

within project area. TAA #6. 

Waldheim Slide

Roads (maintenance, 

construction, reconstruction 

and use)/yes

road repair & slide restoration

Repair complete – 

restoration is In 

progress

T30N; R9E; Sec. 23 TAA#23

Canyon Creek Rd 

Repair and Storage

Roads (maintenance, 

construction, reconstruction 

and use)/yes

Upgrade road 31 to MP 8.4, improve 

drainage Rd 4140 to MP 1.7, and place 

approx. 16 miles of road in storage 

In progress T31N; R8E; 

TAA#23 

Silver Springs 

Campground Fish 

Passage Culvert 

Replacement

Stream restoration/ yes

Replace existing corrugated metal pipe with 

open bottom arch culvert under campground 

loop road to improve fish passage

In progress Hwy 410, Silver Springs Campground. 

TAA #5. 

Sulphur Creek 

Hatchery Slide Stream restoration/ yes Slope stabilization In progress T37N: R9E; Sec 31 TAA#43

Spawning Beach 

Decommission Stream restoration/ yes

Removing all concrete pool structures, 

asbestos piping, and pumphouse; recontour 

area to be a natural stream channel (mit. 

measure for Baker Lake Hydro relicense).

In progress

At headwaters of Baker Lake, below 

mouth of river, past Channel Creek

T38N; R25E; Sec. 25 SE 1⁄4 and Sec. 36 

NE 1⁄4. TAA #43. 

Beckler Thin

(two sakes: Johnson 

Creek and 4th of July

Vegetation Management 

And Road closure/ yes

Commercial thinning of ~797 acres; 

regeneration harvest of ~117 acres, 

decommissioning (as needed) and removal 

of FS Roads 6546-110 (1.0 mile), 6548-110 

(2.45 miles), 6560 (1.2 miles), and 

restoration of fish passage at Road 65 (MP 

5.0, 5.23, and 5.4)

In progress

N and NE of Skykomish.

T28N, R12E; Sec. 31. T26N, R11E; 

Sec. 13 & 24. T26N, R12E; Secs. 5, 18 

& 19.

T27N, R12E, Secs. 6, 7, 16,17, 19,20, 

29, 32. TAAS #16 and 17. 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix F

Currently Being 

Implemented or 

Ongoing Project 

Name

Project Type/Could this 

type of project contribute 

to invasive plant spread?

Project Description

Currently In 

Progress or 

Ongoing Project

General Location/ TRS/ and invasive 

plant Treatment Analysis Area

Upper White River 

Vegetation 

Management

Two sales: White 

Water and Thirsty 

Mule

Vegetation Management/

yes

Commercial variable-density thinning on 

~1,962 acres of under-80-year-old conifer 

stands in the Huckleberry Creek and West 

Fork White River watersheds. Total thinned 

area ~1,413 acres (excluding buffers)

White Water is In 

progress 

Thirsty Mule soon to 

be advertised

West Fork White River and Huckleberry 

Creek watersheds. TAA #2. 

T18N, R9E, Secs. 1, 3,8-10, 12-14, 15-

17, 20 & 21.

T10N, R10E, Secs. 6, 7 & 18. TAA # 2.

Kaaland Restoration

Vegetation management/ 

No because invasive plant 

treatment is part of project

increase riparian forest, diversity of ungulate 

forage, reduce noxious weeds In progress

T35N; R5E; Sec. 26 NW 1⁄4 & NW 1⁄4 of 

SW 1⁄4 

T35N; R5E; Sec. 27 E 1⁄2 of NE 1⁄4 

TAA#36 

I-90 Corridor thin Vegetation management/ 

Yes

Commercially thin 350 acres (348 acres 

commercial thin 2 acres clear cut) construct 

1.5 miles of temporary roads

In progress

T22N; R9E; Sec. 1 & 12

T22N; R10E; Secs. 5,6, 7, 9-11, 14 & 

15

TAA#11 

Dan Thin Timber Sale Vegetation management/ 

Yes Commercially thin 238 acres In progress T32N; R10E; Secs. 16, 20, 21, 27 & 28’

TAA#48 & TAA#30

Greenwater Elk 

Forage Management 

Project 

Vegetation management/ 

Yes 135 acre clear cut for forage opening In progress

T19N; R9E; Secs. 13, 14 & 21 TAA#3

T19N; R10E; Secs. 16-23 & 31

TAA#3 & TAA#4

Gov’t Meadows 

(Muckleshoot Tribe) 

Huckleberry 

Enhancement CCS

Vegetation management/ 

Yes

thinning approx. 47 acres to promote 

huckleberry enhancement and planting of 

huckleberry and other native shrubs

In progress T19N; R11E; Sec. 33

TAA#3 

Decline Thin Vegetation Management/ 

yes 400 acres of thinning In progress T32N; R10E; Secs. 22, 23 & 27. TAA# 30

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix F

Table F- 3. Foreseeable Future Projects that Overlap with Invasive Plant Treatment Analysis Areas

Foreseeable future 

Project Name

Project Type/Could this type of project 

contribute to invasive plant spread? Project Description

Foreseeable 

Implementation 

Time Frame

General Location/ 

TRS/ and invasive 

plant Treatment 

Analysis Area

Camp Silverton Building 

Removal & Permit 

Termination

Recreation and administrative sites/yes remove buildings from Camp Silverton 2014-2015 T30N; R9E; Sec. 23 

TAA#23 

Crystal Mountain Master 

Development Plan 

Amendment #1

Recreation/ yes Replace the High Campbell chairlift; 2014-2108

Crystal Mountain Ski 

Area 

T17N; R10E; Sec. 24. 

TAA #6. 

Upper Baker Visitor 

Information Services Recreation/ yes

Construct visitor information station with 

existing parking and add kiosks and 

restrooms. 

2014-2015

Near Komo Kulshan 

Guard Station, Baker 

lake area, TAA #43. 

Bayview Campground 

Redevelopment Recreation/ yes Rehabilitate 28 unit fee campground. 2014-2015 On west shore of Baker Lake; TAA #43. 

Hwy 542 recreation 

enhancements Recreation/ yes

improve trail from parking area to NF 

Nooksack river, install interpretive 

signs, restroom remodel, install CXT 

toilet, place barrier rocks

2014 -2015 T39N; R7E; Sec. 3 

TAA#45 

Panorama Boat Ramp 

Reconstruction and Parking 

lot expansion

Recreation/ yes

pave and redo boat ramp subgrade

add 10-15 vehicle and boat parking 

spaces

2015 T37N; R9E; Sec. 5. 

TAA#43 

Road 2540 Removal Road closure/ yes Decommission first 1.23 miles after 

Marsh Pond treatment

2014-2015

T32N, R11E 

Secs. 14 & 23

Marsh Pond, Suiattle 

River drainage. TAA 

#32.

PSE Greenwater Electric 

System SUP Renewal Road closure/ yes

convert overhead electric distribution to 

underground distribution system, 

decommission road 7300-101 on both 

sides of washout and 0.5 mile of road 

7190 

2014

T19N; R10E; Sec. 30 

TAA#4 TAA#3

T18N; R10E; Secs. 5-8, 

17, 20, 21,27, 28, 34, & 

35 TAA#4, TAA#5

T17N; R11E; Sec. 19 & 

30

TAA#6 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix F

Foreseeable future 

Project Name

Project Type/Could this type of project 

contribute to invasive plant spread? Project Description

Foreseeable 

Implementation 

Time Frame

General Location/ 

TRS/ and invasive 

plant Treatment 

Analysis Area

Index/Galena County Road 

Flood Repair

Roads (maintenance, construction, 

reconstruction and use)/ yes

Snohomish County to reconstruct flood 

damaged sites on Road 6300

2014 possible 

start 

~3 miles north of South 

Fork Skykomish 

drainage in North Fork 

Skykomish River 

watershed. TAA #19. 

Crystal Mountain Boulevard 

Resurfacing

Roads (maintenance, construction, 

reconstruction and use)/ yes

Resurfacing of Crystal Mountain 

Boulevard to repair weather and traffic 

related damage. Project would also 

include the repair of damaged guard 

rails, the replacement of worn culverts, 

rockslide protection, and replacement of 

96-inch-diameter culverts with concrete 

box culverts

2014

Crystal Mountain 

Boulevard from 

Highway 410 to the 

Crystal Mountain Ski 

Area. TAA #6.

Suiattle Rd ERFO 6.0-14.4 Roads (maintenance, construction, 

reconstruction and use)/yes

Remove debris, excavate and construct 

embankment, place aggregate base 

and asphalt surfacing, place topsoil, 

seed, and mulch on disturbed areas

2014-2015 T32N; R11E

TAA#33 & TAA#32

Marsh Pond Fish Passage 

Restoration Stream restoration/ yes

Remove outdated fish ladder, modify 

berm at outlet of Marsh Pond and outlet 

channel to improve fish passage.

2014-2015

Marsh Pond, Suiattle 

River drainage. T32N, 

R11E, Sec.14. TAA#32. 

Finney AMA Timber Project Vegetation management/ yes

1,256 acres commercial thinning in 39 

stands, 6 miles road re-opened, 54 

miles reconstruction, 4.6 miles 

temporary road, 3.6 miles road

decommissioning

2014 – 2016 

Finney Creek drainage, 

tributary to 

Skagit River

T34N, R8E, Secs. 2, 3, 

10, 11, 14, 15, 19-22, & 

26-33. TAA #38. 

Suiattle Seed Orchard 

Plantings Vegetation management/ Yes Maintain/replant 5 acres of plantings in eroded riparian reserves 2014-2015 T32N; R11E; Secs. 9 & 16. TAA #32. 

Snoqualmie Point Vegetation management/ Yes clearcut and commercial thin 2014

T23N; R7E; sec 1

T23N; R8E Sec. 6

TAA#14 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix F

Foreseeable future 

Project Name

Project Type/Could this type of project 

contribute to invasive plant spread? Project Description

Foreseeable 

Implementation 

Time Frame

General Location/ 

TRS/ and invasive 

plant Treatment 

Analysis Area

Hansen Creek Timber/Veg 

Mgmt Vegetation management/ Yes

1800 acres timber management 

includes clearcut, thinning and precommercial thinning

2015-2018

T23N; R9E; Secs. 34 & 

35

T22N; R9E; Secs. 1, 2 

& 12

T22N; R10E; Secs. 6-

18

TAA#11 

Upper White River 

Vegetation and Restoration 

Project 

Vegetation management/yes

Commercially thin about 1,400 acres, 

change use level on 7.6 miles of road, 

decommission 13 miles of road.

Start planned for 

2014 and 

continue for 

about 5 years

West Fork White River 

watershed.

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment DEIS – Appendix F

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376 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

Appendix G – Invasive Plant Treatment DEIS 

Comments and Forest Service Responses

Summary of Comments Received 

The Forest Service received 18 individual pieces of correspondence (table G- 1) in response to 

distribution of the Draft EIS for comment. Of the 18, the content of the first 4 were questions or requests 

that did not contain comments. Two letters containing comments were received from federal agencies, 

two letters containing comments were received from county agencies, one letter containing comments 

received from the city of Seattle, three letters containing comments were received from various 

environmental interest groups, and six letters containing commenter were from individuals. The letters 

from agencies are reproduced in total and the other letters are in the project record and available on 

request. 

Table G- 1. List of commenters

ID # Name Organization

01 Dick Artley

02 Eileen Maloney

03 William (Bill) Lider

04 Kathy Johnson

05 Matt Bell

06 Eric Olsen

07 Ben and Nancy Brodie

08 Dennis Clark

09 Brooke Thompson

10 Sally Nickerson City of Seattle 

11 Dick Artley

12 Steve Burke King County

13 Scott Moore King County Weed Board

14 Rebecca Chaney Washington Native Plant Society

15 Mark Boyar and others Middle Fork Coalition and others

16 Megan Dunn and others Northwest Coalition for Alternatives to Pesticides and others

17 Allison O’Brien Department of the Interior 

18 Christine Reichgott Environmental Protection Agency

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

The comments generally cover the following topic areas: 

1. Concern about the risks to public and applicator health from chemical use

2. Concern about the effectiveness of the proposed action and alternatives in treating invasive plants

3. Concern about how ongoing land uses may result in the spread of invasive plants

Comments and written responses are shown in Table G- 2 below. 

Comment Response Regulations 

The NEPA regulations at 40 CFR 1503.4a require that an agency preparing a final environmental impact 

statement shall assess and consider comments both individually and collectively, and shall respond by one 

or more of the means listed below, stating its response in the final statement. Possible responses are to:

1. Modify alternatives including the proposed action.

2. Develop and evaluate alternatives not previously given serious consideration by the agency.

3. Supplement, improve, or modify its analyses.

4. Make factual corrections.

5. Explain why the comments do not warrant further agency response, citing the sources, authorities, or

reasons which support the agency's position and, if appropriate, indicate those circumstances which

would trigger agency reappraisal or further response.

New or Modified Alternatives 

The following were suggestions provided by commenters for new alternatives or modifications of 

alternatives. The suggestions for new alternatives or modifications to existing alternatives were generally 

intended to reduce herbicide use or exposure.

1. Treat these plants with a more costly, safer alternative–mechanical and biological means.

2. The “No Action” alternative should compare the action alternatives to a true “no action” alternative,

where no chemical herbicide weed control measures are used.

3. Analyze a 4th action alternative in detail that would prohibit glyphosate application anywhere on the

forest for any reason.

4. The DEIS should examine other alternatives that would use non-herbicide methods first.

These comments were considered and found to not warrant agency response with the development of new 

or modified alternatives, based on the following information provided in the DEIS. See DEIS Chapter 2.6

for alternatives considered and information about those not developed in detail. 

Non-herbicide methods are used, and would continue to be used under all alternatives. Our experience 

implementing the current program, along with information in the R6 2005 FEIS and in the 2007 

Aminopyralid Risk Assessment, prompted the Forest Service to seek additional tools to improve the costeffectiveness of treatment. 

A No-Action Alternative with no chemical treatment would not meet the purpose and need of the project 

to respond with timely containment, control and/or eradication of invasive plants. FSH 1909.15 Chapter 

14.2 discusses two interpretations of “no action”, including the case where no action equates to no change 

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

from current management direction or level of management intensity. As noted in CEQ’s 40 most asked 

questions: “To construct an alternative that is based on no management at all would be a useless academic 

exercise. Therefore, the "no action" alternative may be thought of in terms of continuing with the present 

course of action until that action is changed.” Thus, in the present EIS, the no-action alternative would 

continue the present treatment approach. A no herbicide alternative was considered and rejected in the 

MBS 2005 DN. 

Some of the comments suggested alternatives that would remove tools from the existing toolbox or 

impose greater restrictions on herbicide use than are necessary to follow Forest Service policies and the 

MBS Forest Plan. Alternatives that would have avoided use of all or specific herbicides were considered, 

but not further developed for detailed study as per the discussion in Chapter 2.6.3 – page 52 of the DEIS. 

Alternatives that would remove tools or otherwise would decrease cost-effectiveness would not meet the 

purpose and need and are properly not considered in detail. The analysis in the DEIS and our experience 

with treating invasive plants has not indicated a need to remove chemicals from the toolbox. 

One commenter provided several pages of linked website references intended to support his position that 

glyphosate should not be used on the MBS National Forest. All websites were reviewed (except those that 

could not be opened). In general, the web references duplicated information that has already been 

incorporated into the SERA 2011 Risk Assessment and DEIS; or contained unsubstantiated opinion 

pieces, or were not relevant to the project (e.g. about food crops, US pesticide policies). A change was 

made to the alternatives in response to this comment; POEA surfactants that increase toxicity of 

glyphosate will not be used. This means that only lower risk glyphosate formulations (SERA 2011) would 

be used in any all alternatives. 

One comment letter suggested ways to make treatments more cost-effective, including a suggestion to 

increase the treatment caps and duration of the project, and making sure that personnel who can identify 

invasive plants are not restricted to Forest Service specialists. These comments did not result in changes 

to the alternatives. The specified project caps and duration allow for a consistent analysis across resource 

areas and are based on reasonable assumptions. The caps would not likely to inhibit treatment of invasive 

plants, given the expected funding. If the project caps or duration became impediments to effective 

treatment, additional analysis could be done to identify effects of a modification. The alternatives already 

allow qualified people outside the Forest Service to identify invasive plants. The 13,500 acre life of the 

project herbicide use cap has been clarified to include only acres that are not currently mapped. 

Additional or Modified Analysis

A few of the comment letters indicated that additional analysis should be prepared to address topics that 

were not adequately addressed in the DEIS. Prevention of invasive plants by changing land uses, the 

adequacy of the wildlife analysis, and analysis about glyphosate were questioned. 

Prevention is addressed by tiering to the R6 2005 FEIS and the MBS 2005 EA, including the prevention 

best management practices established by the MBS. The cumulative effects analysis (pages 78-86) 

discussed the relationship between land uses and the potential spread of invasive plants and how 

prevention influences the spread of invasive plants. The different vectors or ways that invasive plants are 

spread and how prevention is integrated into land uses was discussed in Chapter 3, the affected 

Environment and Environmental Consequences and is also covered in Chapter 2 (2.3.3 Management 

Requirements and Mitigation Measures , pages 32 to 42 of the DEIS). 

The inadequacies described for the wildlife analysis were based on one summary statement, however 

Chapter 3.5 provides additional information. The summary statement has been edited for accuracy and 

clarity. 

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One commenter expressed that the analysis was inadequate because it did not include information about 

“opposing views” concerning risks of glyphosate use. Several website links and excerpts under the 

heading “opposing views” were attached to the comment letter. 

Some of the articles are related to GMO agriculture and concerns about crops designed to resist 

glyphosate. Concerns about GMO agriculture are not relevant to effects of using glyphosate for invasive 

plant treatment. 

Some of the articles are reiterations of studies that were reviewed and cited in the SERA 2011 Risk 

Assessment on glyphosate. These studies are cited in the narrative and sometimes integrated into the 

quantitative data about human health hazards or environmental fate of glyphosate in the risk assessment 

(and Chapter 3 of the DEIS). 

Some of the articles express opinions about Monsanto as a company; international policies about pesticide 

use and registration; or how studies are funded. These issues are outside the scope of this project. The 

project is designed to comply with all laws, policies, standards and guidelines related to pesticide use. The 

analysis incorporates best available scientific information. 

Corrections 

The comments resulted in a few corrections to the DEIS. 

Explanations

Table G- 2 below lists all comments to the DEIS and Forest Service responses. The responses generally 

fall into category 5 with explanations provided where warranted. 

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Table G- 2. DEIS comments and the Forest Service responses

ID Comment 

Number Comment Forest Service Response

5 1 Good! Glad to hear that the USFS is going to be addressing the 

control of non-indigenous plant species with effective current 

technology.

This comment does not warrant changes to the project or analysis or 

further explanation. 

6 1 When I recreate in our beautiful WA backwoods and draw water 

while camping, my expectation has always been that it will be the 

cleanest, unspoiled water commensurate with my surroundings. 

Now I have a concern that Ranger Rick, being concerned that the 

Speckled Vagina Fern is being decimated by Aggressive Dick 

Weed or some such, has been allowed to spray herbicide in our 

otherwise pristine backwoods, which may end up in my drawn 

water. Unless there is risk that all the evergreens will be wiped out 

by the Dick Weeds, my vote is to keep meddling mittens away 

from mother nature and let her take her course. We already have 

corporations infecting our environment with chemicals from every 

direction, can’t we at least leave our pristine backwoods alone? I 

would be much more concerned for the wildlife out there (which 

on occasion is chemically-sensitive me and family) with wellintended chemical/herbicide sprayers than I would be about some 

aggressive plants left alone.

Here’s a test: If I’m out camping and see herbicide sprayers, I’ll 

rinse some leaves off and pour it into a cup and ask them to drink 

it. If they’re not cool with that, then it’s a stupid idea since I’ll be 

drawing water nearby myself.

It’s my strong opinion that us humans need to wise-up and stop 

reaching for chemical “solutions” to fix problems (imagined or 

otherwise). If it’s that big of a problem, find another way that 

doesn’t violate commonsense by spraying poison in the 

wilderness.

This comment does not warrant changes to the project or analysis. 

Drinking water quality would not be adversely affected by this project. 

Clean water is valued on the MBS. While we would not recommend 

drinking unfiltered water from streams on the MBS, the proposed use of 

herbicides would not make the water less safe to drink. 

The DEIS discussed worst case scenarios for drinking water and the 

amount of herbicide that could possibly reach water bodies on the MBS 

would be far below any level of concern for human health (DEIS page 

98). DEIS page 169 discussed how levels of herbicide in soil adjacent to 

treatment are lower than amounts that would exceed drinking water 

thresholds if present in adjacent streams. DEIS page 187 cited 

Washington State Department of Agriculture monitoring (WSDA 2004, 

2005 and 2006) for residual concentrations of herbicides for treatment of 

invasive plants in aquatic-emergent habitats. Ten out of the sixteen sites 

sampled between the years 2003 and 2005 showed residual herbicide 

levels that were below a level of concern for drinking water. The rest 

showed no detectable level of herbicide. DEIS page 189 noted that 

treatments along roads are unlikely to result in concentrations of 

herbicide reaching streams in amounts likely to harm drinking water. The 

cautious thresholds of concern and maximum herbicide exposure 

scenarios studied are intended to account for chemical sensitivity and 

posting and public notification are intended to help people avoid even 

implausible exposure. 

The impacts of invasive plants are often subtle, but can seriously 

degrade the environment. DEIS page 109-110 noted that the risk to 

native plant communities from competition from invasive plants is 

greater than the risk of treatment and that the more quickly invasive 

plants can be controlled, the better the chance for long term survival and 

viability of native plant communities. DEIS pages 117-118 detailed the 

adverse effects on wildlife from invasive plants. Page 137 noted that 

wildlife habitats would become degraded over time under the No-Action 

Alternative. Page 196 discussed the adverse impacts of invasive plants 

on riparian and fish habitats. Page 225 stated that invasive plants 

degrade wilderness values. 

Remote areas on the MBS (e.g. backwoods) are not pristine in the 

sense that human activities have resulted in the introduction of invasive 

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ID Comment 

Number Comment Forest Service Response

plants while also disturbing land and thus increasing susceptibility to 

invasive plant spread. Invasive plants have found their way even to 

wilderness areas. Removal of invasive plants would help restore the 

pristine quality of remote areas including wilderness. 

Forest Service management direction includes early detection and rapid 

response to invasive plants before their adverse impacts become 

obvious. Thus, the Forest Service does not have the option of leaving 

aggressive invasive plants alone. Invasive species management on 

public lands is required by Executive Order 13112. The 2013 Forest 

Service National Strategic Framework for Invasive Species Management 

noted that invasive species are among the most important 

environmental threats. Invasive species were identified by a recent Chief 

of the Forest Service as one of the four threats to forest health. Invasive 

plants are displacing native plants, potentially destabilizing streams, 

reducing the quality of fish and wildlife habitat; and degrading natural 

areas. 

Herbicides are an important part of integrated invasive plant treatments. 

Impacts of herbicide use would be mitigated to the greatest extent 

possible while still allowing for cost-effective treatments. The DEIS 

acknowledged the concerns people have about the potential impacts of 

herbicide use on water, wildlife, human health and other ecosystem 

components. DEIS Page 86 summarized the reasons why adverse 

impacts would be minimal. 

7 1 We support the DEIS for the Mt. Baker-Snoqualmie National 

Forest Invasive Plant Management Project.

This comment does not warrant changes to the project or analysis or 

further explanation.

8 1 I strongly support the preferred alternative for managing invasive 

plants in the Mt. Baker-Snoqualmie NF. I have spent over 200 

hours controlling invasive plants (mainly English ivy) on public 

lands using mechanical means. I also have used herbicide to 

control knotweed. 

I think that herbicide control is an environmentally-acceptable tool 

when applied at appropriate times, places, and appropriate target 

species. The drawbacks associated with further invasive plant 

spread far outweigh the drawbacks associated with herbicide use. 

I support USFS’s preferred alternative.

This comment does not warrant changes to the project or analysis or 

further explanation.

9 1 Regarding your plans to use chemical control on Forest Service 

land. I hike year-round on the Olympic Trail Systems. I am a 

chemically sensitive person registered with the State of 

Washington. I came across a sign by the Little Quilcene Trailhead 

warning that it had been sprayed with glyphosphate [sic] on 

This letter was forwarded to the Olympic National Forest. Invasive plant 

managers on that Forest responded with a letter to this commenter 

explaining the notification process. The comment does not warrant 

changes to the proposed project or analysis. The proposed MBS project 

includes mitigation measures 45-50 including detailed notification 

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ID Comment 

Number Comment Forest Service Response

10/1/14. My group and I arrived to hike that trail 10/2/14. Those of 

us who are negatively affected by chemicals choose outdoor 

activities specifically to avoid exposure to things that make us ill. 

We come to the forest with the expectation of a chemical-free 

experience. My friends and I had no way of being warned to stay 

off that trail. We were exposed just by being there to read the 

warning sign.

Herb Robert and thistle were listed as the target of the 

glyphosphate [sic]. These two are non-toxic weeds, common to 

our state. However, the glyphosphate [sic] used to kill them is a 

harmful toxin. The MSDS for Round-up states that is hazardous to 

fish, and the Little Quilcene River runs alongside that trail that was 

sprayed. This is not how I expect the Forest Service to administer 

our tax dollars. Please respond to this query with information 

regarding use of chemical controls on weeds in recreation areas.

procedures for a variety of sites (DEIS pages 33-39). The cautious 

thresholds of concern and maximum herbicide exposure scenarios 

studied are intended to account for chemical sensitivity and posting and 

public notification are intended to help people avoid even implausible 

exposure. The fact that the commenter saw the sign on the Olympic 

National Forest indicates the notification system worked to alert this 

person to the potential for inadvertent exposure. DEIS page 229 

disclosed the potential negative effect if forest visitors feel they must go 

elsewhere to avoid herbicides that have been applied to invasive plants 

in their favorite recreation spot.

10 1 I strongly support the Forest Service adopting the Proposed 

Action (Alternative 2). Invasive species pose one of the greatest 

risks to native ecosystem functioning, especially in the face of 

climate change. Neither Alternative 1 nor Alternative 3 will allow 

the Forest Service to adequately treat current and new invasive 

plants in a timely or cost-effective way, meaning that desired 

future conditions will be virtually impossible to achieve.

The addition of aminopyralid to the list of approved herbicides is a 

good one. It is extremely effective against many of the most 

invasive plants, including hawkweeds and thistles. Yet it poses 

lower risk to non-target organisms than me herbicides currently in 

use.

The use of broadcast spray is the only cost-effective way to treat 

large patches. The careful use of broadcast spray from a small 

truck-mounted sprayer is effective and safe. Integrating these 

additional tools into the integrated pest management approach 

will help increase the chance of success in controlling these nonnative invasive plants that are often changing and degrading 

natural ecosystem functions, including wildlife habitat.

Treating invasive species in wilderness areas should be one of

the highest priorities for the program. If invasions are allowed to 

continue, the value and function of the wilderness areas will be 

considerably degraded.

The use of EDRR and allowing staff to move quickly to develop 

site prescriptions and treating newly found patches as soon as 

possible is the only way that the Forest Service will ultimately 

This comment does not warrant changes to the project or analysis or 

further explanation.

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ID Comment 

Number Comment Forest Service Response

control species that spread quickly. It greatly increases cost to 

wait for a year or more to initiate treatment.

11 1 My family grew up in Darrington. We hiked and fished at various 

locations in the Mount Baker-Snoqualmie National Forest. Your 

proposal to kill wildlife, fish and human visitors by applying poison 

to the foliage of invasive plants is clearly out of line. Your DEIS 

did not indicate the acceptable number of deaths per acre of 

noxious weed eradicated.

This comment does not warrant changes to the project or analysis. 

There is no proposal to kill wildlife, fish or human visitors. The risks 

associated with invasive plant treatment are discussed throughout the 

EIS, including potential impacts to non-target plants, habitat, and nonlethal impacts to fish and wildlife (DEIS Chapter 3). Plausible impacts 

are informed by herbicide risk assessments that represent the best 

available science regarding risks of herbicides proposed for use on the 

MBS (DEIS page 71). The effects analysis based on best available 

science does not indicate that ANY wildlife, fish or people will be killed

from this project. 

11 4 How did you convince a wildlife biologist to lead a project that will 

kill wildlife? How did you convince Ms. Reed to look the other way 

when confronted with science showing that herbicides containing 

glyphosate are potentially lethal to wildlife ... especially birds?

This comment does not warrant changes to the project or analysis. No 

evidence indicates that birds or other wildlife species would be killed by 

the ongoing or proposed glyphosate use in this project. DEIS pages 

134-135 noted that “disturbance from manual and mechanical treatment 

pose greater risks to terrestrial wildlife species [including birds] of local 

interest than herbicide use.” There is a very low likelihood that herbicide 

exposure under this project would adversely affect birds (DEIS page 

137).

11 5 Incredibly, Mr. Everest chooses to ignore the fact that fish and 

other aquatic organisms are killed instantly when the 

concentration of glyphosate is as small as 1 part per billion.

This comment does not warrant changes to the project or analysis. 

Glyphosate “coming into contact with water would be well below a 

threshold of concern, or non-detectable (DEIS page 214).” Mitigation 

measures and herbicide use buffers restrict application methods and 

formulations in areas near streams and along roadside ditches. The 

threshold of concern (toxicity index) for glyphosate is based on nonlethal impact (DEIS page 209). Laboratory studies indicate the olfactory 

sense of salmon is affected at concentrations greater than 1 part per 

million (1 mg/L). On certain occasions when rainfalls occur during or 

soon after herbicide application, fish could be exposed to glyphosate 

concentrations leading to the occurrence of sub-lethal effects. Outright 

mortality of fish from herbicide exposure is highly unlikely. While it is 

possible that individuals would express impaired normal behavioral 

patterns these outcomes would be limited because exposures would be 

too intermittent, based on the expected action and its incorporated 

mitigation measures. As a result, these outcomes are not likely to 

produce an observable change in the abundance, distribution, diversity, 

or productivity of fish species at either the population or species level 

(DEIS pages 215-216). 

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ID Comment 

Number Comment Forest Service Response

11 6 Analyze a 4th action alternative in detail that would prohibit 

glyphosate application anywhere on the forest for any reason. 

Indeed, this 4th alternative would meet the P&N. Why? The P&N 

says nothing about using a specific herbicide.

This comment does not warrant changes to the project or analysis. 

Under the No-Action Alternative, glyphosate would remain the herbicide 

used on the greatest number of acres and sites on the MBS (DEIS at 

table 5). The proposed action would use comparatively less glyphosate 

because new treatment options would be available; however glyphosate 

would remain the first choice herbicide for about 40 percent of known 

target plant acreage. 

No evidence suggests that there is a need to eliminate use of 

glyphosate to meet Forest Plan or other management direction. The 

Proposed Action would reduce the relative amount of glyphosate use by 

authorizing use of a wider variety of herbicide. The project design and 

mitigation measures associated with all alternatives would reduce the 

potential impact of glyphosate on the environment.

DEIS Chapter 2.6 (page 52) discussed dropping glyphosate in the 

alternatives considered but not developed for detailed study. 

11 7 Try to value life more than you value the need to participate in the 

USDA’s criminal support of Monsanto. Federal officials who 

knowingly take action that will place public health and safety in 

jeopardy by “concealing” important information violate 18 U.S.C. § 

1001 and are thus subject to up to 8 years in prison.

This comment does not warrant changes to the project or analysis. 

Public health and safety would not be placed in jeopardy and important 

(relevant, credible) information is disclosed. The DEIS discussed the 

potential health effects to workers and public from herbicide use 

proposed in the alternatives (DEIS Chapter 3.3. page 94-105.

11 2, 8 Page S-2 indicates you currently apply herbicides on the forest 

that contain glyphosate. Your proposed action indicates you will 

continue to spew this poison on the forest. Glyphosate is a toxic 

poison and must never be applied to public land where families 

recreate. 

This comment does not warrant changes to the project or analysis. No 

Action and all action alternatives retain use of glyphosate. Glyphosate 

properties and potential risks to human health were discussed on DEIS

pages 71-78 and 94-105 and in SERA 2011. This herbicide has been 

subject to scrutiny and analysis for decades. It is one of the herbicides 

included in Standard 16 (see DEIS table 2) based on the R6 2005 FEIS 

to which this document is tiered. The R6 2005 FEIS and ROD are 

available in the project record. 

Glyphosate has many characteristics that are beneficial; it is quickly 

absorbed into target plants. It also readily binds with organic material 

and becomes biologically inactive. It is effective on many target species, 

however it is non-selective. Use of glyphosate as proposed poses low 

risk to human health. Management requirements and mitigation 

measures minimize risks associated with chemical uses.

11 10 There is information widely available that discusses the dangers 

and toxicity of some herbicide products sold over-the-counter in 

America. Other countries protect their citizens by taking the vast 

amount of scientific information seriously. If these products (in this 

case herbicides) provide profit for the corporation that 

manufactures the product, the corporation will stop at nothing to 

This comment does not warrant changes to the project or analysis. The 

pesticide use approval process differs in other countries from the 

process in the USA. The formulations approved for use and the product 

labels also may differ. The pesticide registration process is outside the 

scope of a Forest Service project. The analysis is based on best 

available scientific information, including a detailed risk assessment for 

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ID Comment 

Number Comment Forest Service Response

prove their product is safe. Incredibly, some government 

regulatory agencies (FDA, EPA etc.) choose to look the other way 

when confronted by these dangers. This is the case with 

Monsanto and their herbicides that contain glyphosate. There are 

scores of brand names for herbicides that contain glyphosate. 

Roundup is the most popular.

various formulations containing glyphosate (SERA 2011).

11 11 There is a reason the United States is currently having a cancer 

epidemic much worse than other industrialized countries. Even 

casual exposure to herbicides that contain glyphosate is shown in 

the lab to cause cancer in mammals. Of course now you are 

wondering what you can do to disprove these science 

conclusions. You might not even believe that glyphosate is 

unsafe. I suggest you search the WEB for the 2 words 

“glyphosate” and “cancer.” When you do you will get 79,600 hits. 

Most of the human and non-human animal deaths caused by 

glyphosate exposure will be cancer-related.

This comment does not warrant changes to the project or analysis. 

Glyphosate is not considered a carcinogen. The 2011 glyphosate risk 

assessment noted that some “equivocal” evidence of carcinogenic or 

mutagenic potential have raised concerns, at least in terms of risk 

perception (e.g., Cox 1998a, 2004; Watts 2010). However, given the 

marginal mutagenic activity of glyphosate, the failure of several chronic 

feeding studies to demonstrate a dose-response relationship for 

carcinogenicity, and the limitations in the available epidemiology studies 

on glyphosate, the risk assessment found that the “Group E 

classification in U.S. EPA/OPP (1993a, 2002) appears to be 

reasonable.” Group E classification means that there is no evidence of 

carcinogenicity for humans. Many web articles were supplied by the 

commenter to support the contention that there is a link between 

glyphosate use and occurrence of cancer. The web articles were 

reviewed and no relevant new scientific information was presented in the 

articles; the results of the review are in the project record and available 

electronically. 

11 13 Hundreds of well respected Ph.D. scientists [have described] their 

research findings on the safety of herbicides containing 

glyphosate. Their research indicates glyphosate containing 

herbicides clearly kill fish at very small concentrations and are 

linked to the following health problems in mammals (including 

humans): 

• birth defects, 

• non-Hodgkin’s lymphoma (a form of cancer),

• mitochondrial damage,

• cell asphyxia,

• miscarriages,

• attention deficit disorder,

• endocrine disruption,

• DNA damage,

• skin tumors,

• thyroid damage,

This comment does not warrant changes to the project or analysis. The 

linked articles and reports submitted as part of this comment letter were 

reviewed by Forest Service pesticide use specialists (except where the 

links provided could not be opened). The Forest Service review of the 

list of linked articles is available in the project record. 

Studies linking glyphosate to cancer, neurological diseases, birth 

defects, and other health concerns generally are for herbicide use rates, 

formulations, or uses that are dissimilar to this project. Some of the 

websites refer to cellular level studies that are not applicable to real 

world exposure risks. Research conducted on whole organisms (e.g., 

rats, quail, etc.) using plausible exposure routes (e.g., dietary, direct 

spray) with glyphosate provide the best available science regarding risk 

from Forest Service applications. Whole organism studies have been 

conducted, have been reviewed by the EPA, are included in Forest 

Service risk assessments, and form the basis of our conclusions. 

The herbicide risk assessments used by the Forest Service are based 

on a compendium of scientific research and have been peer reviewed 

and are considered best available science. The risk assessment 

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ID Comment 

Number Comment Forest Service Response

• hairy cell leukemia (another cancer),

• Parkinson disease,

• premature births,

• decrease in the sperm count,

• harm to the immune system in fish

• death of liver cells,

• severe reproductive system disruptions

• chromosomal damage.

There are thousands of sites on the web that clearly indicate 

glyphosate is potentially lethal. Incredibly, you depend on a single 

document endorsed by the USDA declaring that glyphosate is 

safe.

incorporated the findings of credible studies in the open literature. 

Chapter 3.1.4 described herbicide toxicity analysis of proposed 

herbicides in the project (DEIS pages 71-78). Chapter 3.3 discussed 

potential health effects to workers and public from herbicide use 

proposed in the alternatives (DEIS page 94-105).The toxicity data on 

technical grade glyphosate are extensive, including both a standard set 

of toxicity studies submitted to the U.S. EPA/OPP in support of the 

registration of glyphosate as well as a robust open literature consisting 

of numerous and diverse in vivo and in vitro studies. As with any 

complex collection of studies, the studies on technical grade glyphosate 

may be subject to differing interpretations. The preponderance of the 

available data, however, clearly indicates that the mammalian toxicity of 

glyphosate is low, and very few specific hazards can be identified. 

Doses of technical grade glyphosate that exceed around 300 mg/kg bw 

may cause signs of toxicity, including decreased body weight gain, 

changes in certain biochemical parameters in blood as well as tissues, 

and inhibition of some enzymes (i.e., P450) involved in the metabolism 

of both endogenous and exogenous compounds. At doses from about 

1000 to 5000 mg/kg body weight, glyphosate can cause death. There is 

no indication that technical grade glyphosate causes birth defects. For 

comparison, the largest potential dose (in mg/kg) a person might receive 

based on this project would be a child drinking water from a pond in 

which 200 gallons of glyphosate has been spilled. The estimate dose of 

glyphosate under this implausible scenario would be about 8 mg/kg 

body weight (SERA 2011).

11 14 Several countries have banned or are considering a ban on 

glyphosate. Thus, the Forest Service should not use this chemical 

for invasive plant control. Please respond. This is not a rhetorical 

question. Would you apply a chemical to your yard where children 

play in the grass that was banned in Denmark 10 years ago 

because of its lethal effects? Would you apply a chemical to your 

yard where children play in the grass that the Institute of Science 

in Society based in London England calls for banning in England? 

Would you apply a chemical to your yard where children play in 

the grass that Italy wants banned for use in the country? Would 

you apply a chemical to your yard where children play in the grass 

that El Salvador banned in October 2013? Would you apply a 

chemical to your yard where children play in the grass that Sri 

Lanka banned in March 2014? 

This comment does not warrant changes to the project or analysis. The 

DEIS describes how herbicide use proposed on the MBS would follow 

applicable policies, plans, standards and guidelines. The Forest Service 

has assessed the use of glyphosate for decades. The R6 2005 ROD 

approved the use of this herbicide on National Forests in Oregon and 

Washington. Updated information in the 2011 SERA Glyphosate Risk 

Assessment was incorporated into the DEIS. The legality of herbicide 

use in other countries in not relevant to herbicide use proposed on the 

MBS. The several web articles that were linked to this comment were 

reviewed and no additional relevant scientific information was found that 

has not already been considered in the risk assessment and analysis 

results documented in the DEIS. Many of the articles are related to 

genetically modified agriculture and not relevant to this project. The 

literature review is electronically available in the project record.

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Number Comment Forest Service Response

11 15 Ask yourself why Congress included Section 735 in the 2013 

spending bill (HR 933) that was signed by President Obama. 

Section 735 is known by many as the "Monsanto Protection Act." 

This comment does not warrant changes to the project or analysis. 

Section 735 expired with the 2013 spending bill. Section 735 related to 

genetically modified agriculture. 

11 16 We know glyphosate-containing herbicides are potentially lethal... 

but there is more. Within the last few days new research results 

have been made public. Roundup is responsible for the massive 

monarch butterfly population reduction.

This comment does not warrant changes to the project or analysis. The 

research results cited are about how the loss of milkweed has 

contributed to butterfly decline. The relationship to glyphosate is that this 

herbicide is used to kill unwanted milkweed. No native plants important 

for butterfly habitat on the MBS would be treated in this project. 

11 17 Glyphosate causes children to be born with birth defects: “Farm 

families that applied pesticides to their crops in Minnesota were 

studied to see if their elevated exposure to pesticides caused birth 

defects in their children. The study found that two kinds of 

pesticides -- fungicides and the herbicide Roundup -- were linked 

to statistically significant increases in birth defects. Roundup was 

linked to a 3-fold increase in neurodevelopmental (attention 

deficit) disorders.” [EHP Supplement 3, Vol. 110 (June 2002), pgs. 

441-449.] 

This comment does not warrant changes to the project or analysis. 

Studies about birth defects and attention deficit disorder were 

considered in the 2011 Glyphosate Risk Assessment. There is no 

indication that technical grade glyphosate causes birth defects (SERA 

2011). A study found a tentative association between attention deficit 

disorder and use of glyphosate, however since the time of this 

publication in 2002, no additional studies further clarifying this 

association have been published (ibid.). 

11 18 The establishment of the World Health Organization (WHO) 

Acceptable Daily Intake (ADI) is based on limited studies using 

limited parameters which do not account for vulnerable groups 

such as children, the elderly, the sick and other groups that might 

have increased susceptibility to glyphosate exposure.

This comment does not warrant changes to the project or analysis. The 

threshold of concern is based on sensitive subgroups such as women of 

child bearing age and children. Forest Service risk assessments 

incorporated an uncertainty factor of 10 to account for sensitive 

individuals (DEIS page 101). 

11 19 Would the Journal of Environmental Research and Public Health 

have reason to publish a story that is not true? “Abstract: The 

current chronic kidney disease epidemic, the major health issue in 

the rice paddy farming areas in Sri Lanka has been the subject of 

many scientific and political debates over the last decade. 

Although there is no agreement among scientists about the 

etiology of the disease, a majority of them has concluded that this 

is a toxic nephropathy. None of the hypotheses put forward so far 

could explain coherently the totality of clinical, biochemical, 

histopathological findings, and the unique geographical 

distribution of the disease and its appearance in the mid-1990s. A 

strong association between the consumption of hard water and 

the occurrence of this special kidney disease has been observed, 

but the relationship has not been explained consistently. Here, we 

have hypothesized the association of using glyphosate, the most 

widely used herbicide in the disease endemic area and its unique 

This comment does not warrant changes to the project or analysis. The 

linked article discusses kidney disease in Sri Lanka and other countries. 

The article appears to be similar to previous citations and relates to 

extensive agriculture uses of glyphosate and the amount and 

formulations used are not clear in the study. The Sri Lanka epidemic 

started before use of glyphosate and there is no evidence that similar 

problems are occurring from the type of glyphosate use proposed for 

this project.

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metal chelating properties. The possible role played by 

glyphosate-metal complexes in this epidemic has not been given 

any serious consideration by investigators for the last two 

decades. Furthermore, it may explain similar kidney disease 

epidemics observed in Andra Pradesh (India) and Central 

America. Although glyphosate alone does not cause an epidemic 

of chronic kidney disease, it seems to have acquired the ability to 

destroy the renal tissues of thousands of farmers when it forms 

complexes with a localized geo environmental factor (hardness) 

and nephrotoxic metals.”

11 20 Would the International Agency for Research on Cancer have 

reason to publish a story that is not true? These studies indicate 

that glyphosate doubles the risk of non-Hodgkin’s lymphoma. 

This comment does not warrant changes to the project or analysis. The

glyphosate risk assessment (SERA 2011) discussed studies related to 

glyphosate and non-Hodgkin’s lymphoma. Studies on the potential 

carcinogenicity of glyphosate in humans are based on self-reports of 

exposure to glyphosate by individuals with cancer [including nonHodgkin’s lymphoma] (ibid). The association between glyphosate and 

non-Hodgkin’s lymphoma was not always statistically relevant and EPA 

has found that the epidemiologic evaluations cited do not establish a 

definitive link to cancer (ibid).

11 21 Would the USGS have reason to publish a false report in 

Environmental Toxicology and Chemistry? [The attached article 

discusses persistence of glyphosate in air and water in the 

Mississippi Delta Region].

This comment does not warrant changes to the project or analysis. The 

information in the attached article does not appear to be relevant to the 

MBS use of herbicides. The data is from Mississippi Delta region, a 

huge agricultural area, thus the type of herbicide use proposed on FS 

land is not similar. The DEIS acknowledged that herbicides, including 

glyphosate, may be transported by drift (air), leaching through the soil, 

or surface runoff (DEIS pages 185-186). The DEIS described the soil 

properties that influence chemical mobility in the environment (DEIS 

page 167). The proposed action includes management requirements 

and mitigation measure to reduce potential for herbicides to move off 

site (DEIS page 169, 188). 

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11 23 In Californians for Alternatives to Toxics, et al. v. Michael 

Dombeck, Civ. S-00-2016 LKK/JFM (2001), Judge Lawrence 

Karleton presiding in the United States District Court for the 

Eastern District of California made the following findings:

“The Forest Service cannot proceed with the plan until it assesses 

how use of the herbicides would affect the spread of noxious 

weeds and considers new information that calls into question 

earlier Forest Service findings that use of the herbicides would not 

harm humans and wildlife."

This comment does not warrant changes to the project or analysis. The 

R6 2005 FEIS explored various management alternatives that included 

different herbicide ingredients and different standards for their use, and 

considered how these standards might affect the spread of invasive 

plants. The MBS DEIS Chapter 3.1.5 discussed the relationship 

between land uses and the spread of invasive plants. Chapter 3.2 

discussed the effectiveness of each alternative in treating invasive 

plants, given their expected continued spread. The Forest Service has 

assembled updated scientific information about the effects of herbicides, 

including risk assessments completed by SERA.

11 24 You must act according to NLRB rules. Private industry must 

notify workers when they will be required to work under conditions 

that are potentially fatal. Please make hardcopies of this section 

of these comments and Opposing Views Attachment #9a and give 

them to the people who will be applying the herbicides that 

contain glyphosate. Also, mail them to the worker’s family.

This comment does not warrant changes to the project or analysis. The 

Forest Service follows appropriate worker safety laws and regulations. 

Forest Service Pesticide Use Manual 2150 states that:

In managing and coordinating the use of pesticides, it is Forest Service 

policy to:

1. Conduct all pesticide-use activities using an integrated pest 

management approach to improve overall treatment effectiveness and to 

reduce pesticide risk(s) for both humans and the environment. 

2. Conduct all Forest Service pesticide-use activities in full compliance 

with applicable Federal laws, regulations, and other authorities including, 

but not limited to, the Federal Insecticide, Fungicide, and Rodenticide 

Act, the National Environmental Policy Act, and the Endangered Species 

Act. Relevant State and local laws pertaining to the use of pesticides will 

be followed when not in conflict with Forest Service management 

authorities and objectives.

3. Require that all pesticide-use activities conducted by non-Forest 

Service personnel on the National Forest System, or other areas 

administered by the Forest Service, be in compliance with applicable 

EPA pesticide label restrictions and other applicable Federal and State 

laws and regulations including the Federal and State laws and 

regulations that apply to personnel training and licensing.

4. Require that all Forest Service personnel who use any biopesticide or 

general-use chemical pesticide (other than household pesticides) on 

terrestrial or aquatic areas of the National Forest System be trained in 

the proper, safe, and effective use of the respective pesticides being 

applied for the management activity. Pesticide-use training and 

certification for Forest Service employees who use, or directly supervise 

the use of, restricted-use pesticides will be accomplished through an 

appropriate EPA-approved State program or a national Forest Service 

certification program.

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5. Incorporate pertinent pesticide-use policy and related handbook 

guidance into all management activities on the National Forest System 

and other lands, waters, or facilities administered by the Forest Service; 

including but not limited to procurement activities, contracts, permits, 

leases, and agreements to foster the safe and effective use of 

pesticides.

As discussed in the DEIS table 2, all herbicide applicators would be 

licensed or directly supervised by a licensed applicator. The Forest 

Service conducts job hazard analysis and communicates risks of various 

kinds of projects to works.

11 25 Syracuse Environmental Research Associates updated of their 

2006 report addressing glyphosate safety in 2011. It is titled 

“Glyphosate Human Health and Ecological Risk Assessment” was 

completed on March 25, 2011 under USDA Forest Service 

Contract: AG-3187-C-06-0010 and submitted to Paul Mistretta, 

COR USDA/Forest Service, Southern Region.

The report points out not all glyphosate formulations are the 

same. Table 2: Glyphosate Formulations Identified by the Forest 

Service (pages 281 and 282) identifies 53 different herbicide 

formulations containing glyphosate. Table 5: Classification of 

formulations (page 287) shows the toxicity of the different 

formulations presented by toxicity levels and confidence.

Unfortunately, Supervisor Eberlien you indicate glyphosate will be 

applied without describing the specific formulation that will be 

applied. According to SERA there are 11 formulations of 

glyphosate-containing herbicides that are “low toxicity.” Please 

apply one of the 11 glyphosate formulations that (according to 

SERA) are low toxicity and indicate the specific formulation that 

will be applied. 

Higher risk formulations of glyphosate were dropped from the 

alternatives in response to this comment. The higher risk rating is based 

on the presence of POEA surfactants; these would not be approved for 

use in the alternatives.

11 26 Congress intended for federal agencies to make their responses 

to responsible opposing views available to the public to read. 

Simply placing a hardcopy of the Responsible Official’s opposing 

views responses in the project file located at the district hides the 

information from the American public. How will the judge react 

when he/she finds out you expected the public to fly thousands of 

miles to examine a document that legally must be available to the 

public? Include an electronic response to each responsible 

opposing view contained in the Opposing Views Attachments and 

post these responses online for the public to examine. The only 

legal way to avoid responding is to explain why the opposing view 

is irresponsible. Professionals do not selectively choose literature 

This comment does not warrant changes to the project or analysis. The 

web links supplied in the comment letter often contain duplicative, 

misleading, irrelevant or sensationalized information. The R6 2005 FEIS 

(project record); SERA 2011 Glyphosate Risk Assessment (project 

record) and the MBS DEIS listed literature cited in the analysis. There is 

no requirement to provide reference material via clickable links. The 

comment letter, the attached articles themselves and the Forest Service 

review of the articles are in the project record and available on request, 

including electronically.

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citations that support their case and systematically exclude those 

that don’t. Supervisor Eberlien, there are hundreds of references 

listed in the 24-page Literature Cited section. There are 99 

sources for the opposing views of Ph.D. scientists quoted in 

Opposing Views Attachments #9a.

Even random selection of science literature related to herbicide 

safety would have included several of the documents cited in the 

Opposing Views Attachment #9a. None of this literature is listed in 

the Literature Cited section. Include some source documents from 

the Opposing Views Attachment #9a in the Literature Cited 

section. Also, cite the specific quotes included in the source 

literature chosen by this member of the public in the text of the 

EIS. Finally, include clickable links to the source documents you 

choose to include in your reference section.

11 27 Supervisor Eberlien, you have consciously selected literature for 

the Literature Cited section that excludes science describing how 

logging will adversely affect non-timber natural resources in the 

sale area. 

The project is not about logging, thus this comment is not specific to the 

proposed action and no response is warranted. 

11 28 Reasonable people would have doubts about the wisdom of their 

proposed action that best science predicts will likely create major 

adverse impacts to the forested ecosystem.

Best science predicts that if invasive plants are not effectively treated, 

they will create major impacts to the forested ecosystem. In contrast, the 

project proposed by the Forest Service to effective treat invasive plants 

involve minimal risks, as discussed throughout DEIS Chapter 3. 

11 29 You know the effects disclosures [in the DEIS] are inconsistent 

with the research conclusions of several hundred Ph.D. scientists 

[see excerpts in Attachment #9a]. 

This comment does not warrant changes to the project or analysis. The 

effects discussed in the DEIS are consistent with best available science. 

Many of the attached web citations are opinion pieces or news reports 

and do not contain scientific information. 

11 3, 9, 22 Invasive plants are a major problem in our public lands. Treat 

these plants with a more costly, safer alternative – mechanical 

and biological means. I understand that natural vegetation and the 

resources that depend on the health of the natural vegetation will 

be significantly harmed if the non-native invasive plants are not 

eradicated. I also know there are effective (although more costly) 

alternatives to killing these plants other than herbicides. If most 

Americans knew of the tragic results stemming from contact with 

some herbicides they would insist that the USFS spend the extra 

money on these safer alternatives. Any reasonable, thinking, 

ethical person with this knowledge would deal with noxious weeds 

with the slightly more expensive alternatives to chemicals.

This comment does not warrant changes to the project or analysis. All 

action alternatives would approve mechanical and biological treatment 

(see DEIS 13-23). Biological treatments are relatively inexpensive, and 

biological agents help suppress or contain larger populations of some 

invasive plants. Mechanical treatments are also appropriate to contain 

some invasive plant populations; however mechanical treatment alone 

would not be effective on many target species. Absinth wormwood, 

comfrey, bindweed, and knotweeds are examples of invasive plants that 

cannot be effectively treated without herbicides (DEIS table 6). Costeffectiveness is also an important factor in determining an appropriate 

course of treatment given funding limitations. The influence of treatment 

effectiveness compounds over time and more herbicide or other plant 

treatments may need to be used at a later date if the most effective 

treatment methods are not used earlier.

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11 12, 22 Supervisor Eberlien, please don’t tell the public everything will be 

fine since you plan to apply the herbicide according to label 

directions. Monsanto would not dare to say anything that might 

indicate to the public there are health issues associated with their 

products. The label directions must not be trusted. Monsanto pays 

other chemical labs to do the safety research on their glyphosatecontaining herbicides. These labs know what Monsanto wants. 

The label directions printed and composed by Monsanto are 

based on this type of so-called safety evaluation. It should not be 

necessary to explain further. Monsanto composes and prints the 

label directions! If you believe the outdated, biased USFS sources 

that show herbicides containing glyphosate are safe you will live 

the rest of your life wondering. The USFS has no mandate to 

prop-up Monsanto does it? Corporations like Monsanto, whose 

GMO-agriculture inventions (Bt corn; Roundup herbicide) now 

threaten human and environmental health alike, have moved 

beyond the stage of simply denying or minimizing the science 

revealing the harm being done by their products (there is too 

much science now to maintain this strategy!); rather, they are now 

investing in the burgeoning, multi-billion dollar industry practice 

known as "check book" science: find willing researchers, research 

institutions, and journals to create and publish information 

favorable to the company writing the check, and you're in 

business.

This comment does not warrant changes to the project or analysis. The 

mitigation measures and herbicide use buffers go beyond the label to 

reduce the potential for impacts. The analysis was informed by herbicide 

risk assessments prepared by an independent analyst (DEIS page 72, 

Table 20). The risk assessments were informed by peer-reviewed 

articles from the open scientific literature and current EPA documents 

and were discussed at length in the DEIs (pages 71-78). 

The herbicide registration and labeling process is outside the scope of 

the project EIS. The Forest Service use of glyphosate or any other 

herbicide is very small compared to the use of these chemicals in 

general (the R6 2005 FEIS estimated that Forest Service use comprises 

about 3 percent of the total use of herbicides in Oregon and 

Washington). The decision made on this project would not affect 

Monsanto.

14 1 As an organization committed to protecting Washington’s native 

plants and their habitats, we are writing in support of Forest 

Invasive Plant Treatment DEIS Alternative 2, the preferred 

alternative analyzed in the Mount Baker-Snoqualmie National 

Forest (MBS) Draft Environmental Impact Statement. As Forest 

Service analysis indicates that this alternative provides the best 

protection for native plants within the forest, we believe it is the 

appropriate choice to ensure that the Forest Service has the 

ability to carry out its mission to “sustain the health, diversity, and 

productivity of the nation’s forests and grasslands to meet the 

needs of present and future generations.” We are assuming that 

the principles of Integrated Pest Management will be followed as 

part of this proposal. Sustaining the health and diversity of the 

forest requires controlling invasive plants and current methods 

used within the Snoqualmie-Mount Baker National Forest are not 

equal to the task, as evidenced by the increasing numbers of sites 

and acreage affected.

This comment does not warrant changes to the project or analysis. The 

project follows integrated weed management (IWM) principles. 

Integrated treatment prescriptions according to MR/MM would be 

developed based on a comprehensive list of site considerations (see 

DEIS pages 41-43).

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14 2 Washington Native Plant Society members monitor native plants 

and their habitats within the MBS. Our members participate in 

Weed Watcher programs and have observed increases of 

invasive species within the forest. We support adequately funding 

agencies that protect the health of the forest and are concerned 

about whether the Forest Service has the resources to ensure 

that validation of sites by invasive plant specialists, as specified in 

the DEIS, will be possible. We encourage the Forest Service to 

handle this concern in a way that ensures validation will be carried 

out in an expeditious manner as this will be critical to the overall 

success of the management plan.

Studying plants in their native habitats, known as botanizing, is an 

activity that has a long history. Rooted in the oral traditions of our 

state’s First Peoples (predating the historical record), documented 

in the journal of botanist and explorer David Douglas, and 

continuing today on the web with the meticulous records of the 

Burke Herbarium and the citizen-science compiled WNPS plant 

lists, botanizing is a discipline worthy of recognition and protection 

on our federal lands. 

The observations of botanizers have contributed to the human 

knowledge base and across cultures for thousands of years. 

Ensuring the health of native plant habitats of our public forest 

lands is critical to the need of our members to carry on this worthy 

pursuit. 

It is the mission of the Washington Native Plant Society to 

appreciate and protect the native plants of Washington. We 

advocate for the removal of introduced species that threaten 

native plants. We understand that invasive species management 

on public lands is required by Executive Order 13112 and 

appreciate the Forest Service actively responding to this problem. 

We appreciate the chance to work together on this important 

issue.

This comment does not warrant changes to the project or analysis The 

requirement for “validation by an invasive plant specialist” is intended to 

ensure that invasive plants are properly identified before they are 

treated. Any credible source could provide this validation. Under any 

alternative, the MBS supports expansion of the weed watcher program, 

and is committed to proper surveys to ensure early detection following 

ground disturbing activities. Surveys are accomplished through a variety 

of mechanisms and funding sources. 

15 1 As organizations committed to stewardship of the natural 

resources of the Mt. Baker Snoqualmie National Forest (MBS), we 

are writing to express our support for Forest Invasive Plant 

Treatment DEIS Alternative 2, the preferred alternative. Measures 

proposed by Alternative 2 would greatly improve the capacity of 

the MBS to control invasive plants.

Although invasive plants pose a grave threat to habitat throughout 

the Forest, the existing control program is handicapped by 

inadequate funding and outdated tools. Therefore, we support 

This comment does not warrant changes to the project or analysis or 

further explanation. The Record of Decision will explain the Forest 

Supervisor’s rationale for the decision. 

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implementation of Alternative 2, including the following measures:

Allow use of all Region-6 approved herbicides, and aminopyralid

In a perfect world, mechanical and manual control would be 

sufficient to limit the spread of invasive plants. However, such 

methods are often inadequate even for small infestations, let 

alone for large infestations widely dispersed across a National 

Forest. Especially on this landscape scale, herbicides are the only 

effective tool to control yellow archangel, yellow hawkweed, 

Bohemian knotweed, spotted knapweed, and many other species 

– aggressive invaders that if left alone, would eventually choke 

out habitat throughout the MBS.

With the broader list of approved herbicides, the MBS control 

program will have access to the most effective, least-risk 

herbicide for each targeted species. Currently, for many species 

that “ideal” herbicide isn’t an option. As a result, greater volumes 

of less effective herbicides are applied.

Allow broadcast herbicide application 

For some species, spot spraying of dense infestations is 

ineffective. For example, spot spraying dense yellow hawkweed 

infestations will leave uncontrolled the seedlings and stolons 

growing between treated plants. As a result, treatments often 

must be repeated. For such infestations; broadcast application is 

superior both for control and for lessening the overall use of 

herbicide.

Outside of Wilderness areas, allow mechanical control

For some invasive plants, mowing and string trimming machines 

can be important nonchemical components of an integrated 

treatment program. For example, these methods can be effective 

for dense roadside stands of Himalayan blackberry, reed canary 

grass, and Scotch broom.

Inside of Wilderness areas, allow all control methods except 

mechanical, broadcast

Because remote infestations can be exceedingly difficult to 

access, we’re fortunate that our Wilderness areas are relatively 

free of invasive plants. With access so difficult and time 

consuming, control must be effective the first time; this means 

using herbicides when needed. English holly and other invasive 

plants are showing up in remote trail-less areas and it will be a 

struggle to control them in the first place, let alone to return for 

follow-up control; therefore herbicides must be part of the control 

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toolkit.

Establish an Early Detection and Rapid Response (EDRR) 

process

Timely control of new infestations is essential for effective weed 

control. Replacing the current cumbersome review process with a 

streamlined Early Detection and Rapid Response process is a 

critical step for the MBS control program. Currently, it can take 

one or more years from the time an infestation is reported to the 

time it is approved for control. Many invasive weeds spread 

rapidly, and this bureaucratic process can turn simple, 

inexpensive control projects into costly multi-year efforts. For 

example, about 15 years ago a butterfly bush infestation took root 

on the Middle Fork Road and spread to multiple sites along the 

Middle Fork Snoqualmie River (a single butterfly bush can 

produce hundreds of thousands of lightweight seeds that are 

easily dispersed by wind and water). These infestations could only 

be accessed by kayak or raft, or by fording the river in late 

summer. It took annual visits spread over 10 years to eliminate all 

infestations. Early control would have saved a great deal of work.

When trained personnel locate an infestation that requires 

herbicide, and are equipped with the appropriate equipment and 

herbicide, they should have the authority to make a decision to 

control the infestation while still on site. Immediate control will 

prevent further spread of the plant and greatly increase the speed 

and effectiveness of control work overall.

Washington State and county land managers already have EDRR 

programs with such policies in place. Until such a program is 

active on the MBS, its overall control program will be hobbled.

15 2 Alternative 2 - Concerns and suggestions

Maximum 5,000 acres treated per year and 13,500 for life of 

project

The DEIS analysis is based on the existing data, as it should be. 

Measures proposed in Alternative 2 are an excellent response to 

what is known about weeds on the MBS.

However, we believe those data paint an incomplete picture of the 

current state of weed infestations across the MBS, simply 

because most of the MBS has not been surveyed due to years of 

inadequate funding. We believe that the 10-fold increase from 

2005 to 2014 in number of reported infestations is largely due to 

the vigorous citizen science survey programs created in that 

This comment resulted in a minor clarification about the project caps. 

The project caps help us characterize the extent and significance of 

environmental impacts. The 5,000 acre per year project cap is based on 

the assumption that all currently infested sites are treated in a single 

year. This is an ambitious level that would require far more funding than 

we historically receive. It allows for analytical site-specificity and 

consistency. 

The 13,500 acre cap applies to new infestations detected over the life of 

the project. 

The annual and life of the project caps appear to be great enough to 

accommodate expected needs within the capacity of the Forest Service. 

Supplemental analysis could address changed conditions over time, 

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period, as well as expanded surveys by non-profit partners (work 

supported by the MBS, WA DNR, King County, and other 

agencies). In other words, the infestations already existed, but no 

one had been looking! While these surveys have been invaluable, 

they only covered a small percentage of trails, trailheads and 

other disturbed sites on the MBS, and even less of our river 

corridors and vast trail-less areas (or forests between trails). For 

example, two off-trail surveys this summer in the Middle Fork 

Snoqualmie Valley found more English holly sites than listed in 

DEIS table 5 for the entire MBS.

We understand that the DEIS proposals must be based on 

existing data. However, given the limits of these data, and the 

strong likelihood that known infestations are the tip of the iceberg, 

we suggest that you allow adjustments to these acreage limits if 

new surveys uncover significantly more infestations

including consideration of an adjustment to project caps if need be.

15 2a Duration of project 

Again, we understand that a DEIS analysis must be based on 

reasonable parameters, including number of years until 

completion. However, weed control will always be an ongoing 

process, especially for a National Forest adjacent to a huge 

metropolitan area and crossed by major highways. Whether 

invasive weeds are spread by vehicles, wind, or birds, they will 

continue to pose a major challenge. If the time limit can’t be 

removed, there should be a mechanism to extend the period as 

needed.

Budget projections 

The proposed budget indicates a commitment to a muchexpanded control program. However, the estimated treatment 

costs don’t seem to factor in the cost of controlling remote 

infestations. While “$200 per acre to accommodate the full range 

of treatment options at any given site” may be sufficient for 

roadside infestations, many newly reported infestations are in 

remote areas of the forest. To survey, control, and monitor sites 

that are far from roads and even from trails - the far end of 

decommissioned roads, campsites deep in the Alpine Lakes 

Wilderness, riverbanks reached by kayak or fording – will require 

significant staff time. Budgets must factor in full-day or multi-day 

trips to visit such sites.

Related to this issue is the statement on DEIS page 61, under 

3.1.1 “Treatment Analysis Areas”:

“This inventory is based on a variety of sources and not all sites 

Duration of Project

The 10 to 15 year life of the project estimate is also based on the current 

inventory, along with assumptions about budget and treatment. It is not 

intended to be a cap. This project may be implemented as long as 

similar conditions and treatment needs exist. 

Budget Projections

The costs of inventory, planning and monitoring were not factored into 

the analysis. The analysis focused on differences in effectiveness 

between the alternatives. The cost estimates provided in the DEIS were 

not intended to reflect the full cost of managing invasive plants on the 

MBS. This EIS is not intended to precisely evaluate the cost of 

accessing remote sites. The cost of prevention is outside the scope of 

the alternatives and is not addressed in the EIS.

The costs of treatment vary widely. Access is one consideration. In 

general, the cost of treatment would be greatest in places where 

eradication is desired. 

The requirement for “validation by an invasive plant specialist” is 

intended to ensure that invasive plants are properly identified before 

they are treated. Any credible source could provide this validation. 

Under any alternative, the MBS supports expansion of the weed watcher 

program, and is committed to proper surveys to ensure early detection 

following ground disturbing activities. Surveys are accomplished through 

a variety of mechanisms and funding sources. 

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have been validated by an invasive plant specialist. Validation by 

an invasive plant specialist would occur before treatment of any 

site.” This seems to imply that only MBS invasive plant specialists 

may validate sites. Due to the limited number of MBS staff who 

can do this work, such a requirement would create a significant 

bottleneck for the EDRR program. We urge you to allow partners 

working under agreements with the MBS to validate sites as well.

We urge you to expand support for the citizen “Weed Watcher” 

programs that have been active in the Upper Snoqualmie Valley 

for the last ten years. They’ve proven to be very effective, and 

provide a low-cost, enthusiastic survey team for the MBS, WA 

DNR, and King County weed control programs.

To limit future infestations, we believe budgets for all grounddisturbing projects should support post-project surveys. MBS 

weed control protocols for construction equipment and materials 

are good, but it’s inevitable that some weeds will be introduced. 

Without follow up surveys, weeds introduced by these projects 

can go undetected and uncontrolled for years.

15 3 No-Action Alternative – comments

A No Action decision, or a decision that eliminates key measures 

proposed in Alternative 2, would cause serious harm to the 

environment. Restricting control to the current set of approved 

herbicides would mean continued use of a higher volume of lesseffective herbicides. Forbidding broadcast spray will have a 

similar effect, making it necessary to repeat spot spray application 

over multiple seasons. If an EDRR program isn’t approved (or 

only a limited program is approved), easily controlled infestations 

will continue to grow into large, difficult-to-control infestations.

When infestations aren’t controlled on MBS lands, they quickly 

spread to neighboring city, county, and state public lands where 

all of these methods are generally allowed. So in the end, they will 

be used anyway, but likely in greater quantities than would have 

been necessary had the infestations been controlled at their 

source.

The ineffectiveness and potential adverse effects of the No-Action 

Alternative are acknowledged throughout the DEIS. The effectiveness of 

the prevention, treatment and restoration program on the MBS has the 

potential to influence treatments off the National Forest. Over time, more 

herbicide use may be required by other land owners and managers if 

invasive plants are not controlled on the MBS. Discussion about how No 

Action may affect invasive plants on lands adjacent to the MBS has 

been added to the FEIS. 

16 1 We applaud the Department of Agriculture and National Forest

Service’s recognition of the extent to which pesticides in forests

impact our economic and public health. This letter serves to

provide additional information on the treatment plan and

encourage the use of alternatives to harmful pesticides. We agree

that treatments for invasive plants should be conducted in a 

manner that minimizes or eliminates human health and

This comment does not warrant changes to the project or analysis. 

This project follows Forest Service policies and the MBS Forest Plan. 

The general concern about overuse of herbicides was addressed in the 

R6 2005 FEIS (project record), resulting in Forest Plan goals, objectives, 

standards and guidelines that direct invasive plant management on the 

MBS. Table 2 in the DEIS listed invasive plant treatment and restoration 

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environmental risks. Although pesticides are scientifically linked to 

a wide range of human health and environmental issues, they are 

too often the tool of choice.

standards that apply to this project. Herbicide toxicity is a key issue 

addressed in the DEIS (DEIS page 11). 

16 2 The three alternatives studied do not adequately address

concerns with pesticide use in our national forests. A fourth

alternative to the Invasive Treatment Plan should focus on manual

or least toxic chemical weed control, include prevention

techniques specific to forests, and study the failures of the current 

plan to explain the large increase in invasive species.

This comment does not warrant changes to the project or analysis. An 

integrated invasive plant management program is considered the most 

effective way to meet invasive plant objectives and follow policies, 

standards and guidelines. The more cost-effective the treatments 

considered, the more likely that the purpose and need for action will be 

met. 

The 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. Alternatives that 

reduce the tools or cost-effectiveness of treatment would not help us 

achieve the purpose and need for action. 

All alternatives allow for manual treatment and “focus on the least toxic 

chemical weed control.” Cost-effective manual treatments would 

continue, often in combination with mechanical, cultural and herbicide 

methods, but sometimes as a stand-alone treatment. 

In 2005, the Regional Forester determined that ten herbicides were 

appropriate for use treating invasive plants throughout R6 (R6 2005 

ROD page 9). Used in accordance with the R6 2005 ROD standards, 

these herbicide ingredients pose relatively low risks to people and nontarget organisms (R6 2005 ROD page 8). Alternatives that would have 

further limited herbicide options (and increased emphasis on invasive 

plant prevention) was considered but not selected. The R6 2005 ROD 

discusses the Regional Forester’s reasons selecting the various invasive 

plant management standards. 

To increase cost-effectiveness while minimizing risk of adverse effects, 

the Proposed Action would also use aminopyralid. Aminopyralid 

compares favorably to the herbicides approved in the R6 2005 ROD. 

Forest-wide invasive plant prevention measures (BMPs) have been 

developed and would be followed regardless of alternative selected. 

These measures are specific to land uses on the MBS. 

New invasive plant detections are inevitable over time, despite our best 

efforts at implementing prevention measures. DEIS page 93 noted that 

species and site-specific models do not exist to more precisely predict 

the rate of spread and the influence of prevention measures. DEIS page 

113 indicated that invasive plants would continue to spread at a rate of 

4-12 percent over the life of the project. DEIS table 23 discussed 

ongoing land uses and activities that have the potential for spreading 

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invasive plants. 

Effective integrated invasive plant management involves prevention, 

early detection and rapid response, and effective treatment and 

restoration. 

16 3 Support continued strict controls on the use of herbicides on

forestlands.

Herbicide use would adhere to all policies and plans, including specific 

standards, guidelines, management requirements and mitigation 

measures as described in the DEIS (pages 32-40). 

16 4 Use herbicides only as a last resort when other options are not 

feasible. Furthermore, they should only be used within an 

integrated program that emphasizes prevention, early detection 

and control.

Herbicide use would adhere to all policies and plans, in accordance with 

strict management requirements and mitigation measures. Herbicide 

use would be done in the context of an integrated program that 

emphasizes prevention, early detection and control. Non-chemical 

methods would continue to be used. (see management requirements #4 

–“lowest effective herbicide use rates would be used for each treatment 

situation” – DEIS page 33). 

The Proposed Action would include a combination of effective and 

practical integrated treatments depending on the target species, location 

and other site conditions (DEIS page 26). 

The concept of using chemicals only as a last resort was discussed at 

length in the R6 2005 FEIS and the Regional Forester chose not to 

require that herbicides be used as a tool of last resort for invasive plant 

treatment in R6 (R6 2005 ROD page 27). Timely use of herbicide as 

needed would serve to reduce the total amount needed; waiting to prove 

that non-chemical methods are infeasible could result in greater use of 

herbicides in the long run.

The R6 2005 ROD includes the objective to reduce reliance on 

herbicide use over time. DEIS page 42 noted that if the target species 

population is not associated with a size, phenology, density or 

distribution that warrants herbicide use (alone or in combination with 

other methods), or if herbicide use does not substantially increase 

treatment efficiency, then non-herbicide methods would be favored. 

The invasive plant treatment program on MBS includes prevention, early 

detection, integrated control methods, restoration and monitoring. 

16 5 Use herbicides in a very limited and targeted way when nonherbicidal options are not feasible; do not use any broadcast 

applications but instead spot applications. Furthermore, sensitive 

sites including endangered species habitat and waterways should 

be avoided.

This comment does not warrant changes to the project or analysis. 

Herbicides would continue to be used in a limited and targeted way. An 

alternative was considered that eliminated broadcasting (DEIS page 53). 

Preliminary analysis for this alternative was conducted and the IDT 

found that the herbicide use buffers and Management Requirements 

and Mitigation Measures effectively minimized the risks of broadcasting. 

This alternative would have reduced treatment effectiveness without 

providing any additional resource protection so it was not developed for 

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detailed study. 

Protection of streams, water quality and riparian habitats is addressed 

through the herbicide use buffers. Effective treatment is very important 

within these areas and the current program has not kept up with 

treatment needs. The project would be beneficial to wildlife. Negative 

impacts to fish and wildlife, including species of local interest, are more 

likely with invasive plants than with the treatments proposed (see DEIS 

Chapter 3.5 and 3.8). 

16 6 Make avoidance of activities that spread weeds a high priority. 

Activities that increase soil disturbance and decrease cover of 

native vegetation are the biggest problems, including: roads, 

logging, grazing, OHV use, fire suppression, altered fire regimes, 

and mining. 

This comment does not warrant changes to the project or analysis. 

R6 2005 ROD (MBS Forest Plan) included the objective to reduce soil 

disturbance while achieving project objectives through timber harvest, 

fuel treatments, and other activities that potentially produce large 

amounts of bare ground. Another objective was to retain native 

vegetation consistent with site capability and integrated resource 

management objectives to suppress invasive plants and prevent their 

establishment and growth. The RF selected specific prevention 

standards to reduce the rates of spread of invasive plants, while still 

maintaining the Forest Service’s ability to provide for existing uses and 

management activities on National Forest System land (see R6 2005 

ROD page 9). In addition, Forest Service Manual 2070 notes that the 

Forest Service intends to maintain, restore or rehabilitate native 

ecosystems so that they are resistant to invasion by non-native invasive 

species.

16 7 Fully disclose weed spreading consequences of land 

management activities such as logging, roads, fuel treatments, 

grazing, OHVs, mining, fire suppression, and altered fire regimes. 

Furthermore, explore limiting these activities as a way to avoid the 

spread of weeds.

This comment does not warrant changes to the project or analysis. The 

R6 2005 FEIS (in the project record) specifically discussed vectors of 

invasive plant spread, including the land management activities 

mentioned in the comment. The R6 2005 ROD (in the project record) 

amended the MBS Forest Plan by adding management direction 

including prevention standards and guidelines. All land use activities on 

the MBS must incorporate invasive plant prevention measures. Sitespecific land use decisions are the appropriate place document “weed 

spreading consequences” and prevention measures related to MBS 

projects. The RF considered, but chose not to adopt a standard to retain 

native vegetation and minimize creating soil conditions that promote the 

establishment and spread of invasive plants (see R5 2005 ROD page 

15). However, the objective to: “retain native vegetation consistent with 

site capability and integrated resource management objectives to 

suppress invasive plants and prevent their establishment and growth” 

were included in the ROD. 

Chapter 3.1.6.3 in the DEIS disclosed that ground disturbance 

associated with natural processes and human activities may favor the 

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spread of invasive plants and discourage the reestablishment of native 

species. It noted that past and ongoing projects and activities on the 

MBS National Forest have the potential for inducing invasive plant 

spread where soils are disturbed. Table 22 discussed the site types 

where invasive plants are currently found and the risk of spread in these 

areas. Table 23 discussed types of land uses and activities that have the 

potential for spreading invasive plants.

16 8 Consider alternatives to herbicides at all stages of decision-making: program, plan, and project.This comment does not warrant changes to the project or analysis. 

Non-herbicide methods have been fully considered at the program and 

planning scale, and will be considered during the implementation 

planning process. DEIS page 42 noted that if the target species 

population is not associated with a size, phenology, density or 

distribution that warrants herbicide use (alone or in combination with 

other methods), or if herbicide use does not substantially increase 

treatment efficiency (considering the availability of volunteers if needed), 

then non-herbicide methods would be favored. 

16 9 Evaluate the risks of all herbicide ingredients, including all “inert” 

ingredients.

Furthermore, these ingredients should be disclosed to the public.

This comment does not warrant changes to the project or analysis. 

This issue was discussed at length in the R6 2005 FEIS. The Forest 

Service does not have the ability to disclose all ingredients of herbicide 

formulations to the public however all ingredients are evaluated in risk 

assessments to the extent possible. The R6 2005 ROD requires that 

additives be addressed in Forest Service Risk Assessments. Information 

about additives and inert ingredients was provided in the DEIS. 

16 10 We urge the Forest Service to do even more to prevent the 

spread of noxious and invasive species, including a review of the 

current monitoring plan for prevention. The Forest Service should 

take steps to determine the underlying causes for the 400% 

increase in invasive sites. The proposed change to map the sites 

and treatment are an important step forward and we support this 

development. While the DEIS strives to limit the adverse effects of 

noxious and invasive weeds, the current General Requirements 

fail to fully address the root causes that spread noxious and 

invasive weeds. These root causes include land management 

practices that disturb soil and native vegetation and a use of some 

products, such as straw hay—which, even if certified weed-­ free, 

may be exacerbating the problem of invasive plants.

This comment does not warrant changes to the project or analysis. The 

“underlying causes” of weed spread are discussed and addressed in R6 

2005 ROD, and the spread of weeds are considered in the cumulative 

effects discussions in the DEIS (Chapter 3). The MBS implements 

Forest-specific best management practices to limit the spread of 

invasive plants (MBS 2005 EA). The R6 2005 ROD requires that 

prevention measures be addressed in all land use assessments. 

The R6 2005 FEIS acknowledged that invasive plants would continue to 

spread even though prevention measures are implemented. Existing 

treatment options have not consistently resulted in effective treatments. 

As described on pages 2 and 3 of the DEIS, the treatments currently 

approved has not been consistently effective and the Forest Service has 

not been able to respond rapidly enough to dynamic invasive plant 

populations. 

The use of certified weed-free straw and wood products for mulch are 

not likely to exacerbate invasive plant problems. 

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16 11 The Forest Service should reconsider the use of straw hay in light 

of studies by Washington Department of Ecology, which found 

straw hay encourages the propagation of weed species 

(Washington Dept. of Ecology). 

The Washington Dept. of Ecology (Ecology) Stormwater 

Management Manual for Western Washington, 2005 edition, 

(SWMMWW ) Volume II, Table 4.7 states: 

“Straw, however, has several deficiencies that should be 

considered when selecting mulch materials. It often introduces 

and/or encourages the propagation of weed species and it has no 

significant long-­ term benefits. Straw should be used only if 

mulches with long-­ term benefits are unavailable locally. It should 

also not be used within the ordinary high-­ water elevation of 

surface waters (due to flotation).”

The Ecology SWMMWW BMP 230 also states that:

“Straw bales are among the most used and least effective BMPs.” 

And “Under no circumstances should straw bale barriers be 

constructed in streams, channels, or ditches.” 

In lieu of using straw hay products that are likely to contain 

noxious weeds, more effective erosion controls such as wood 

straw, wood bark mulch, chipped native vegetation, or compost 

socks/berms where the compost has been commercially prepared 

and uniformly heated to a temperature capable of killing all seed 

germination should be used. These erosion control materials are 

intrinsically weed free.

This comment does not warrant changes to the project or analysis. 

General requirements associated with the use of straw as an erosion 

control or mulch is outside the scope of this project. The R6 2005 ROD 

(MBS Forest Plan) requires all straw hay and mulch used on the 

National Forest in R6 must be certified as weed free. The certification 

process involves field inspection to determine whether any invasive 

plants are present before the hay is baled. The intent is to minimize the 

risk of transporting seed or reproductive parts of invasive plants. The R6 

2005 FEIS (page 3-22) noted that use of non-native straw has been 

observed to introduce invasive plants to the Biscuit Fire area in Southern 

Oregon. Field certification for weed free status is considered highly 

effective in reducing the potential for invasive plants to become 

introduced through straw bales (R6 2005 FEIS page 4-10). However, it 

does not reduce risk to zero. 

In the action alternatives, MR/MM 28 (page 36) requires areas of 

gouging or soil displacement resulting from manual treatment methods 

(digging or pulling) within 35 feet of water courses with surface water 

present be treated to prevent rill and gully erosion and possible 

sediment delivery to steam courses. Erosion control treatment includes 

scattering seed and mulch (straw) to create flow disruption and surface 

soil stability. MR/MM 5 (page 33) reiterates that any mulch used must be 

free of weeds. This mitigation would not involve straw bales placed 

within any streams. The MBS may use other weed free mulches such as 

wood bark if it is available. 

16 13 The use of goats to simply eat the targeted invasive plants can be 

an effective means of weed control. Other less toxic herbicides 

such as vinegar, which has stopped invasion of unwanted species 

targeted in the DEIS, are available. Contact NCAP for 

suggestions on, blackberries, English ivy, knapweed and other 

unwanted plants.

This comment resulted in consideration of use of goats as a cultural 

invasive plant treatment alternative. Goats can be an effective means of 

reducing biomass associated with invasive plants. Goats must remain 

on a site for a long period and a goat herder must remain on site full 

time to ensure safety and environmental protection (Briana Murphy 

presentation at the Oregon Vegetation Management Association 2014 

Conference). 

Grazing to manage weeds on roadsides, trailheads, and larger 

infestations on the forest is limited because of the difficulty of 

maintaining and managing the animals. Invasive plants can compensate 

quickly after the grazing pressure is removed because their seeds are 

long-lived in the soil, and because they can rapidly increase flower stem 

production once grazing pressure is removed (R6 2005 FEIS page 3-

84). 

The Forest Service could consider using goats as an invasive plant 

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treatment method in the future if an appropriate site is identified. This 

alternative was not developed for detailed study in this EIS because no 

sites appropriate for grazing have been identified and thus, no sitespecific effects analysis could be conducted. 

A Forest Service Risk Assessment has not been prepared for the use of 

vinegar, and there are several reasons why this chemical could have 

unacceptable impacts: 1. Potential negative impacts on soil pH. 2. Not 

selective. 3. The amount needed to kill roots would likely affect root 

systems of adjacent plants and soil organisms. 4. Dish soap is often 

recommended to make vinegar more effective; dish soap is not an 

acceptable additive and does not meet Standard 18 (DEIS table 2). 

16 14 USDA Forest Service should adequately consider the use of non-

­ herbicidal controls or least toxic herbicides. Alternative weed 

control methods should be expanded in the EIS. Control 

techniques vary depending on the weed species being addressed. 

The Forest Service should consider implementing non-­ herbicidal 

alternatives. Most of the target invasive species noted in Table 5 

& 6 can be effectively controlled by non-­ herbicide treatments. 

We encourage the use of alternatives, in additional to cultural, 

biological and mechanical weed control. Several alternative 

methods have been proven to produce positive results in stopping 

noxious weeds and other invasive species. For example, manual 

removal, as well as the use of tools and other machines, has 

fewer unforeseen impacts than herbicide application. 

This comment does not warrant changes to the project or analysis. 

Consideration of non-herbicide methods has been given in the R6 2005 

FEIS and the MBS 2005 EA, along with the current analysis ( see 

Chapter 2 – invasive plant treatments common to all alternatives, DEIS 

pages 13-14, and alternatives descriptions, page 15-53) The MBS DEIS 

incorporated best available information on effective, integrated 

treatments for the target species found on the Forest. The integrated 

treatment notes discusses the non-herbicide methods that would be 

used alone or in combination with herbicides to effectively treat invasive 

plants. The focus on herbicide selection comes from the fact that most of 

the other methods were already studied and approved for use in the 

MBS 2005 EA. The MR/MM are intended to minimize risks and many 

layers of caution have been added to ensure that there will not be any 

unforeseen impacts. The intent is for the Forest Service to use the most 

cost effective combination of methods according to MR/MM that 

minimize risks from treatment and according to an implementation 

planning process that ensures treatment prescriptions will be 

appropriately applied on the ground. DEIS page 42 noted that if the 

target species population is not associated with a size, phenology, 

density or distribution that warrants herbicide use (alone or in 

combination with other methods), or if herbicide use does not 

substantially increase treatment efficiency, then non-herbicide methods 

would be favored. MR/MM 16 specifically favors hand pulling on 

roadsides posing higher risk of herbicide delivery to fish habitat and 

adjacent alluvial floodplains. 

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16 15 The failure of the DEIS to present a full range of alternatives 

violates the National Environmental Policy Act (NEPA). The two 

action alternatives differ only in the use of aminopyralid. The DEIS 

should examine other alternatives that would use non-­ herbicide 

methods first.

This comment does not warrant changes to the project or analysis. The 

DEIS Chapter 2 described the range of alternatives considered, 

including 5 alternatives that were considered and not developed in detail 

(DEIS, pages 52-53).The scope of the analysis and range of alternatives 

is influenced by the purpose and need. An alternative requirement the 

use of non-herbicide methods first would not address the need for 

additional herbicide ingredients and application methods as described in 

DEIS Chapter 1. This EIS is tiered to the R6 2005 FEIS that considered 

a range of programmatic approaches to invasive plant management and 

specifically rejected the concept of “herbicides as a last resort.” Nonherbicide methods would continue regardless of alternative selected, 

including no action (with the exception of mechanical treatment that was 

not addressed in the MBS 2005 EA. 

16 16 The “No Action” alternative should compare the action alternatives 

to a true “no action” alternative, where no chemical herbicide 

weed control measures are used. The two action alternatives are 

not sufficiently different from one another to represent a “rigorous 

exploration of all reasonable alternatives,” and therefore the 

USFS has violated NEPA.

This comment does not warrant changes to the project or analysis or 

further explanation. 

A “No Action” alternative was analyzed in the DEIS. FSH 1909.15 

Chapter 14.2 discusses two interpretations of no action, including the 

case where no action equates to no change from current management 

direction or level of management intensity. As noted in CEQ 40 most 

asked questions: “To construct an alternative that is based on no 

management at all would be a useless academic exercise. Therefore, 

the "no action" alternative may be thought of in terms of continuing with 

the present course of action until that action is changed.” Thus, in the 

present EIS, the No-Action Alternative would continue the present 

treatment approach. A no herbicide alternative was considered and 

rejected in the MBS 2005 DN 

16 17 Full disclosure and analysis of all herbicide ingredients must be 

included in the EIS. Increased transparency will protect public 

health. We urge the Forest Service to analyze the risks of the inert 

ingredients in the herbicide formulas proposed for use. Have the 

effects of these inert ingredients been analyzed in order to comply 

with NEPA?

See section 3.1.5.1 and Appendix E for information about inert 

ingredients. Effects of surfactants were considered in the R6 2005 FEIS 

and have been considered in the DEIS effects analysis. Standard 18 

requires that the Forest Service use adjuvants (e.g. surfactants, dyes) 

and inert ingredients reviewed in Forest Service hazard and risk 

assessments. Many of the inert ingredients are proprietary in nature and 

have not been tested on laboratory species. However, confidential 

business information (i.e. the identity of proprietary ingredients) was 

considered in the preparation of the herbicide risk assessments 

completed prior to 2004. Bakke’s adjuvant hazard assessment was 

updated in 2007. One reason that the milestone formulation of 

aminopyralid is proposed and preferred is that labeled formulations 

contain no inert ingredients other than water and triisopropanolamine 

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(chemical name for the active ingredient in aminopyralid). 

16 18 We support the proposal to post all herbicide treated areas. 

Plastic signs not less than 8.5” x 11” in size with 1” high red letters 

on yellow background should be posted at all locations where 

pesticides have been applied. The signs should be mounted at 

least 12” above the ground on 2” x 2” wood stakes driven 6” into 

the ground or stapled to trees larger than 12”in diameter (dbh). 

These signs should be spaced at all public access points to 

treated areas and along roads at a spacing not less than 1 sign 

per 100’ of roadway. The signs should state: THE AREA BEHIND 

THIS SIGN HAS BEEN TREATED WITH name of the herbicide 

APPLIED ON ___ date. For more information contact the name of 

___ District Ranger Station.

The underlined italics in the sign wording above may be 

completed in the field printing neatly, using red indelible 

permanent felt tip ink pens (Sharpie Fine Pont or equal) by the 

field crew.

This comment does not warrant changes to the project or analysis. 

Adequate signing is required by standard 23. Warning and information 

signs will be placed at appropriate locations (defined in the public 

information plan) to inform the public, and forest workers of herbicide 

application dates and herbicide used. The distribution and frequency of 

signs would be determined by the location of the invasive plant 

treatment site. MR/MM 45-50 include notification and posting 

requirements for administrative and recreation sites (DEIS pages 38-39). 

16 19 Modify timber harvest and construction contracts to monitor for 

noxious weeds. All timber sales and construction projects should 

require the contractor to monitor and remove noxious weeds for a 

minimum of 5-­ years and provide a written report certified by an 

approved botanist or State licensed horticulturist on the success 

of noxious weed control. This monitoring should continue until the 

site has stabilized and trees have been re-­ established to 

sufficient height to shade out and out-compete noxious weeds. Do 

timber harvest and construction contracts currently monitor for 

noxious weeds?

This comment does not warrant changes to the project or analysis. This 

recommendation is outside the scope of this treatment project. The MBS 

Best Management Practices for invasive plant prevention includes 

measures for survey and removal of invasive plants after ground 

disturbing activities. In some cases, this is part of a contract and in other 

cases is done by other means (e.g., KV plans). Post-treatment 

monitoring and relationship to invasive plant treatment is discussed in 

each project plan. Regardless of contract or other mechanism for project 

implementation, invasive plant treatments would be done according to 

the design, management requirements and mitigation measures for the 

selected alternative. 

16 20 The DEIS does not adequately address effects on wildlife. On p. 

S-­ 10 the DEIS dismisses effects on wildlife toxicity by stating the 

herbicides would be used in roadside areas where wildlife density 

is lower. Wildlife species would experience exposure on 

roadsides, and pesticides can leach into soil and contaminate 

water supplies and persist in soil for years.

The summary statement has been modified to clarify the conclusions of 

the wildlife effects analysis. The effects analysis assumes that an animal 

is directly sprayed, consumes an entire days’ diet of contaminated food, 

or drinks contaminated water for an entire day. These scenarios far 

overestimate actual exposure levels. The management requirements 

and mitigation measures would further reduce the potential impacts on 

wildlife. The location of invasive plants (primarily on roads and within 

disturbed areas away from preferred habitats) may also reduce potential 

exposure to wildlife. 

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16 21 According to the Material Safety Data Sheet for Clearview, which 

includes the herbicide aminopyralid as a main ingredient, this 

chemical has complications with fire and these concerns need to 

be addressed before proceeding with any application. For this 

reason, input is needed from fire and fire safety departments 

regarding this chemical application and fire dangers in Mt Baker-Snoqualmie. Specifically, the Material Safety Data Sheet for 

Clearview included warnings for Fire Fighting Measures and 

hazards arising from this substance or a mixture of this 

substance. The Forest Service should confirm that the fire safety 

departments are

aware of this hazard.

This comment does not warrant changes to the project or analysis. 

Clearview is a Canadian formulation and would not be approved for use 

on the MBS. The MSDS includes warnings for firefighters about 

chemical fires, similar to other herbicides in use in Canada. Modeling 

assessments coupled with laboratory experiments have shown that the 

risk of airborne herbicide residues to workers is insignificant, even is the 

fire occurs immediately after herbicide application. McMahon, Charles 

and Parshall B. Bush. 1992. Forest Worker Exposure to Airborne 

Herbicide Residues in Smoke from Prescribed Fires in the Southern 

United States. Am. Ind. Hyg. Assoc. J. (53).

16 22 Requirement #3 (Table 9 page 33), pre-­ treatment briefings 

should not replace IPM trainings and/or pesticide applicator 

training. Applicators should be fully aware of health risk 

associated with pesticide use. We oppose the proposal to allow 

non-­ licensed applicators to apply pesticides under supervision 

by licensed applicators. All applicators should be licensed and 

properly supervised.

Requirement #7 (Table 9, page 33), No herbicide applications 

would occur if there is a greater than 80 percent change of 

precipitation within 24 hours. Guidelines on precipitation should 

be based on the product label and/or third party scientific peer 

review studies in forest areas. Pesticide labels and safety data 

sheets may suggest a different recommendation regarding 

potential for rain. Consideration for public and wildlife safety 

should be considered along with product efficacy.

This comment does not warrant changes to the project or analysis. 

Forest Service policy requires that all Forest Service personnel who use 

apply general-use chemical pesticides on terrestrial or aquatic areas of 

the National Forest System be trained in the proper, safe, and effective 

use of the respective pesticides being applied for the management 

activity. Pesticide-use training and certification for Forest Service 

employees who use, or directly supervise the use of, restricted-use 

pesticides will be accomplished through an appropriate EPA-approved 

State program or a national Forest Service certification program. The R6 

2005 ROD standard goes beyond this policy by requiring that herbicide 

applications to treat invasive plants in R6 must be conducted or directly 

supervised by a licensed applicator. 

Requirement #3 would not replace pesticide applicator training or 

certification requirements. 

Requirement #7 goes beyond the labels to reduce potential for surface 

run off containing herbicide. This measure is similar to measures taken 

for many years on the MBS and adjacent forests. 

16 23 The chemical aminopyralid has been associated with 

contamination by manure of ungulates, persisting in soil and 

destroying food crops. This is a concern for Washington State’s 

$40 Billion dollar agricultural industry. There is a potential for 

wildlife to consume pesticide-­ treated plants and spread the 

herbicide out of the treatment area. Concerns with the new 

pesticides are based on reports from Europe where the pesticide 

was ingested, passed, used as manure on crops and one year 

later damaged food crops. Newly proposed pesticides must be 

fully tested using third party peer reviewed studies.

The aminopyralid label addresses precautions for pasture and rangeland 

to prevent unintended consequences from aminopyralid residue in 

grass, hay and manure. US EPA addressed this issue in 2011. They 

noted key variables that influence this potential impact: large numbers of 

confined animals in the area; dependence on local forage that could 

have been treated with aminopyralid; and proximity to organic farms or 

gardens. 

On the MBS, aminopyralid would not be used in areas where there are 

confined animals. Wildlife would not be dependent on treated areas for 

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forage nor would a substantial portion of a free roaming ungulate’s diet 

be composed of vegetation treated with aminopyralid. Organic farms 

and gardens are unlikely to be affected by herbicide use on the MBS 

given the remote locations, limited extent, and scattered distribution of 

invasive plants, and the type of herbicide use proposed. 

In their website www.manurematters.com, Dow Chemical states that 

“Reports of alleged garden or landscape plant damage due to 

aminopyralid have been rare in the United States. It is possible that 

manure from cattle or horses may contain aminopyralid, but only if 

aminopyralid was used to control weeds on pastures where the animals 

grazed or in hay taken from such pastures, and aminopyralid label 

directions regarding management of manure were not followed.” 

Following the label would mitigate the risk of contaminated manure.

16 24 An additional request is to track, record comments, or keep a 

record of comments received in reference to the signage. These 

could be treated as public comment and posted on a website a 

tally of calls with exposure concerns or other concerns could be 

tracked.

NCAP et al provided this additional comment after the close of the 

comment period. We maintain records of public comments and our 

responses to individuals. Comment 9-1 provides an example of a letter 

sent to the MBS based on a person’s visit to the Olympic NF and the 

Forest Service response. The Olympic National Forest also responded 

directly to the commenter. No tracking system exists to tally exposure 

concerns. The MBS receives few calls in reference to signage about 

herbicide treatments. 

16 25 We stress that more information needs to be conducted on the 

pesticide aminopyralid and it’s potential to be spread by 

ruminants. How will Forestry Service control for ‘drift’ beyond the 

treatment area by ruminant animals of this pesticide?

NCAP et al provided this additional comment after the close of the 

comment period. Following the label would mitigate the risk of adverse 

impacts from the manure of ungulate, ruminants or other animals eating 

contaminated vegetation, then excreting it. This concern applies to 

confined animals that depend on forage treated with aminopyralid. 

Wildlife would not be dependent on treated areas for forage nor would a 

substantial portion of a free roaming animal’s diet be composed of 

vegetation treated with aminopyralid. 

17 1 The Department of the Interior (Department) has reviewed the 

Draft Environmental Impact Statement (DEIS), US Forest Service 

(USFS), Mt. Baker-Snoqualmie Invasive Plant Management, 

Washington. The Department supports the Mt. Baker-Snoqualmie 

National Forest (MBS) in their efforts to reduce the potential 

spread of invasive plants on National Forest System lands and 

adjacent to our National Parks within the context of best 

management practices that are provided in detail in the DEIS, and 

This comment generated minor corrections to the EIS. An updated 

accounting of pesticide use in the park for 2014 was not obtained. The 

2013 estimates provided sufficient context for understanding the 

potential for cumulative effects from the MBS project combined with 

herbicide use the park. 

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which are designed to protect sensitive resources and minimize 

potential impacts to non-target species.

We recommend the following edits for inclusion in the final EIS:

1. Please change references to Mt. Rainier or Mt. Rainier 

National Park to Mount Rainier throughout the document.

2. Page 80 refers to three chemicals used within the park 

(clopyralid, aminopyralid and imazapyr), and page 105 refers to 

the use of triclopyr. Please include triclopyr on page 80, and 

glyphosate, which the park uses small amounts of. 

Fluroxypyr has also been used in the park in limited amounts. 

Prior to publication of the FEIS, please consult with the Plant 

Ecologist for an updated accounting of pesticide use in the park.

18 1 We have reviewed the Mount Baker-Snoqualmie National Forest 

Invasive Plant Treatment Draft Environmental Impact Statement 

(draft EIS). Our review was conducted in accordance with the 

EPA's responsibilities under the National Environmental Policy Act 

(NEPA) and Section 309 of the Clean Air Act. Section 309 

specifically directs the EPA to review and comment in writing on 

the environmental impacts associated with all major federal 

actions. Our review of the draft EIS considers the expected 

environmental impacts of the proposed action and the adequacy 

of the EIS in meeting the procedural and public disclosure 

requirements of NEPA. We are rating the draft EIS Lack of 

Objections (LO). 

In our April 2, 2012 scoping comments we recognized the Forests' 

need for improved effectiveness in eradicating, controlling and 

containing invasive plants. We also stated our belief that the 

alternative which best meets the project's purpose, "...to achieve 

the desired condition in the most effective manner possible while 

...minimizing adverse impacts to people and the environment" 

would likely be the environmentally preferable alternative.

Alternative 2, the Proposed Action, best meets the project's 

purpose and is the environmentally preferable alternative. 

Alternative 2 is preferable for the following reasons.

• Best chance of controlling and eradicating populations of 

invasive plants, including the largest, densest and most 

aggressive noxious weed sites. For example, the first choice 

herbicide aminopyralid would not be available for treatment of 

over 2,400 acres of aggressive target species such as 

hawkweeds and knapweeds in Alternatives 1 or 3. Also, the total 

This comment does not warrant changes to the project or analysis or 

further explanation. The environmentally preferred alternative will be 

identified in the Record of Decision. 

409 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

ID Comment 

Number Comment Forest Service Response

cost for treating known infestations and restoring favorable 

vegetation would be least for Alternative 2.

• Alternative 1 - No Action, and Alternative 3 - No Aminopyralid, 

have a greater chance of causing adverse impacts to people and 

the environment. Alternative 3, for example, would treat more 

acres with triclopyr than Alternative 2. Triclopyr is the only 

herbicide proposed for use that has Hazard Quotient values 

above I, the threshold of concern. Also, the use of aminopyralid - 

only allowed in Alternative 2 - would improve the Forest Service's 

ability to treat invasive plants near water, which would help 

restore riparian habitats.

• Improved processes for new invader/Early Detection and Rapid 

Response, implementation planning, herbicide use decision 

criteria, and monitoring.

• Improved Management Requirements and Mitigation Measures.

12, 

13

1 Thank you for the opportunity to comment on the Draft 

Environmental Impact Statement for the Mount Baker-Snoqualmie 

National Forest Invasive Plant Management Project. We support 

the Proposed Action – Alternative 2 as the preferred alternative to 

achieve considerably more cost-effective and timely treatments of 

invasive plants on the Forest. 

Alternative 2 addresses the need to treat invasive plants in 

wilderness areas in order to conserve the natural plant and animal 

communities and wilderness values of these designated areas to 

achieve desired future conditions. We support treatment of 

invasive plants in wilderness areas as non-native invasive plants 

colonize rapidly and can have adverse effects on natural 

ecosystem processes.

As part of the Forest Invasive Plant Management Project, the 

ability to utilize a larger suite of herbicides is necessary for 

eradicating, controlling or containing the spread of invasive plants 

on the Forest. To this end, the addition of aminopyralid to the list 

of acceptable herbicides is fully supported. Our noxious weed 

control program has had considerable success in controlling 

invasive noxious weeds through the judicious use of aminopyralid. 

Aminopyralid is highly effective on many of the invasive plants 

currently known to occur on the Forest such as thistles, 

hawkweeds and knapweeds while posing a very low risk to fish 

and wildlife resources. The addition of the broadcast application 

method for herbicide treatments will also significantly contribute to 

the goal of controlling the spread of invasive plants in a costThis comment does not warrant changes to the project or analysis or 

further explanation. 

410 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

ID Comment 

Number Comment Forest Service Response

effective manner, especially along road sides and for large 

infestations in other areas. 

While it is important to have access to appropriate herbicides and 

application methods, it is equally important to treat known and 

emerging invasive plant infestations in a timely manner. For 

example, in practicing the concept of “Early Detection, Rapid 

Response” our noxious weed control program has reduced the 

spread of invasive noxious weeds by treating infestations the 

same season in which they were discovered. The ability to take 

control action prior to seed set is critical to prevent increased 

spread of invasive plants and is therefore more cost-effective. We 

support an updated “Early Detection, Rapid Response” process 

which allows for treatment the same year as invasive plant 

infestations are discovered in Proposed Action - Alternative 2.

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Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

Agency Letters in Full 

King County Noxious Weed Control Program

412 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

413 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

414 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

415 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

City of Seattle Major Watersheds

416 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

United States Department of the Interior

417 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

Washington Native Plant Society 

418 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

419 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

U. S. Environmental Protection Agency

420 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

421 
Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment FEIS – Appendix G

422 

Everett, WA 98201

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