IDAHO STATE LIBRARY 

MAY 1 5 2003 

BOISE, ID 83702 

Site-Specific Environmental Assessment 

Rangeland Grasshopper and Mormon Cricket 

Suppression Program 

Idaho 

EA Number: ID-PPQ-GH2003-001 

Prepared by: 

United States Department of Agriculture 

Animal and Plant Health Inspection Service 

Plant Protection and Quarantine 

9134 W. Blackeagle Drive 

Boise, Idaho 83709 

March 15, 2003 

J 

Table of Contents 

I. Need for Proposed Action .................................................................................. I 

A. Purpose and Need Statement.. ...................................................................... I 

B. Background Discussion ............................................................................... .2 

C. About This Process ...................................................................................... 5 

D. Scoping and input from the public ............................................................... 6 

IL Alternatives ...................................................................................................... 11 

A. No Action Alternative ................................................................................ 12 

B. Insecticide Applications at Conventional Rates and Complete 

Area Coverage Alternative ........................................................................ 12 

C. Reduced Agent Area Treatments {RAATs) Altemative ............................ 13 

D. Modified Reduced Agent Area Treatments (MRAATs) Alternative ........ 14 

III. Methodologies ................................................................................................. 15 

A. Land Administration .................................................................................. 15 

B. Documenting Rangeland Grasshopper Suppression Programs .................. 16 

C. Insecticide Characteristics ......................................................................... 16 

D. Treatment Strategy ..................................................................................... 18 

1. Basis for a decision to treat.. ................................................................ 18 

2. Selection of treatment .......................................................................... 18 

3. Multiple applications ........................................................................... 18 

4. Methods of application ........................................................................ 19 

5. Discrimination based on vegetative type ............................................. 19 

6. Crop protection and rangeland suppression components ..................... 19 

7. Additional Protective Measures Which Are Not Included in FY 2003 

Guidelines (Appendix 1) .................................................................... .23 

IV. Affected Environment ..................................................................................... 24 

A. Description of Affected Environment.. ...................................................... 24 

B. Site-Specific Considerations ... .................................................................. 26 

1. Human Health ....................................................................................... 26 

2. Nontarget Species ................................................................................. 27 

3. Socioeconomic Issues ........................................................................... 28 

4. Cultural Resources and Events ............................................................. 29 

5. Special Considerations for Certain Populations ................................... 29 

V. Environmental Consequences ........................................................................... 31 

A. Environrriental Consequences of the Alternatives ..................................... 31 

1. No Action Alternative ........................................................................... 31 

2. Insecticide Applications at Conventional Rates and Complete 

Area Coverage Alternative .................................................................... 34 

3. Reduced Agent Area Treatments {RAATs) Altemative ...................... .40 

4. Modified Reduced Agent Area Treatments {MRAATs) Alternative .. .45 

B. Other Environmental Considerations .......................................................... 50 

ID-PPQ-GH2003-001 

1. Cumulative Impacts ............................................................................. 50 

2. Synergistic effects ................................................................................ 51 

3. Inert Ingredients and metabolites ......................................................... 52 

4. Executive Order No. 12898, Federal Actions to Address Environmental Justice 

in Minority Populations and Low-income Populations ....................... 54 

5. Executive Order No. 13045, Protection of Children from Environmental 

Health Risks and Safety Risks ............................................................. 54 

6. Executive Order No. 13186, Responsibilities of Federal Agencies to Protect 

Migratory Birds .................................................................................... 55 

7. Endangered Species Act ...................................................................... 55 

8. Environmental Monitoring ................................................................... 71 

VI. Literature Cited .............................................................................................. 72 

VII. Listing of Agencies and Persons Consulted ................................................... 75 

List of Tables 

Table 1. Proposed treatments and treatment blocks for 2003 Idaho grasshopper and 

Mormon cricket crop protection 

Table 2. Proposed treatments and treatment blocks for 2003 Idaho grasshopper and 

Mormon cricket rangeland suppression 

Table 3. Protection Measures and Determinations for Special Status Species 

Appendices 

Appendix 1: FY-2003 Guidelines for Treatment of Rangeland for 

Grasshoppers and Mormon Crickets ................................................................... . 

Appendix 2: Maps of Affected Environment ......................................................... . 

Appendix 3: FWS/NMFS Correspondence ............................................................ . 

Appendix 4: Protocol for Documenting Requests, Evaluations, Recommendations, 

Consistency Reviews, and Monitoring of Rangeland Grasshopper/Mormon 

Cricket Suppression in Idaho 2003 ................................................... . 

Appendix 5: Environmental Monitoring Guidelines ............................................... . 

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ID-PPQ-GH2003-001 

I. 

Site-Specific Environmental Assessment 

Rangeland Grasshopper and Mormon Cricket Suppression Program 

Idaho: ID-PPQ-GH2003-001 

Need for Proposed Action 

A. Purpose and Need Statement 

The proposed action is to conduct suppression programs on grasshopper outbreaks on 

rangeland in Southern Idaho. Populations of grasshoppers and/or Mormon crickets 

(hereafter referred to collectively as grasshoppers) reach infestation levels in some areas 

nearly every year in Southern Idaho. The Animal and Plant Health Inspection Service 

(APHIS) regularly evaluates the population levels and species composition of the normal 

population and the outbreak infestations. This evaluation helps to determine if site 

specific action is necessary to suppress outbreaks to protect rangeland ecosystems and to 

counter the potential for the pests to spread across rangelands or into surrounding crops 

and communities. APHIS is proposing a program to suppress outbreak populations, and 

is consulting with land management agencies in the design and implementation of the 

program. Specifically, APHIS is consulting with Bureau of Land Management (BLM), 

U.S. Forest Service (FS) and the State ofldaho. This environmental assessment (EA) 

analyzes potential environmental consequences of the proposed action and its 

alternatives. This EA applies to a proposed suppression program that would take place 

from April 15, 2003 to September 30, 2003 in Southern Idaho. 

Populations of grasshoppers that trigger the need for a suppression program are normally 

considered on a case-by-case basis. There is no specific grasshopper population level 

that triggers APHIS participation. The density of eight grasshoppers or three Mormon 

crickets per square yard is used as the minimum population for which a suppression 

program would be considered. In response to requests from land owners/managers, 

APHIS would determine if an outbreak has reached an economically or environmentally 

critical level. If so, an appropriate treatment would be developed, taking into account 

additional site specific information. 

Participation would be based on potential damage such as reduction of forage and habitat 

available for some species of wildlife and livestock, destruction ofrangeland revegetation 

projects, creation of public nuisances, and endangerment of road traffic. Participation 

would also be based on benefits of treatments including protection of forage and habitat, 

increased probability of success for rangeland revegetation projects, elimination of public 

nuisances, and prevention of hazards to road traffic. Some populations that may not 

cause substantial damage to native rangeland may require suppression to prevent damage 

to high economic value crops on adjacent private land. 

The "economic infestation level" is a measurement of the economic losses caused by a 

particular population level of grasshoppers to the infested rangeland. This value is 

determined on a case-by-case basis with knowledge of many factors including, but not 

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ID-PPQ-GH2003-001 

limited to, the following: economic use of available forage or crops; grasshopper species, 

age, and density; rangeland productivity and composition; accessibility and cost of 

alternative forage; and weather patterns. In decisionmaking, the level of economic 

infestation is balanced against the cost of treating to determine an "economic threshold" 

below which there would not be an overall benefit for the treatment. Short-term 

economic benefits accrue during the years of treatments, but additional long-term benefit 

may accrue and be considered in deciding the total value gained by treatment. Additional 

losses to rangeland habitat and cultural and personal values (e.g., aesthetics and cultural 

resources), although a part of decisionmaking, are not part of the economic values in 

determining the necessity of treatment. 

The goal of the proposed suppression program analyzed in this EA would be to reduce 

grasshopper outbreak population levels in order to protect rangeland ecosystems and/or 

private cropland adjacent to rangeland. 

This EA is prepared in accordance with the requirements under the National 

Environmental Policy Act of 1969 (NEPA) (42 United States Code (U.S.C.) § 4321 et. 

seq.) and the NEPA procedural requirements promulgated by the Council on 

Environmental Quality, United States Department of Agriculture (USDA), and APHIS. 

A decision will be made by APHIS based on the analysis presented in this EA and the 

results of public involvement and consultation with other agencies and individuals. Four 

alternatives are analyzed. A selection of one of the four alternatives will be made by 

APHIS for the 2003 control program for Southern Idaho. 

B. Background Discussion 

In rangeland ecosystems in the Western United States, grasshoppers are a normal 

component of the biota. Different species of grasshoppers forage on different preferred 

grasses, forbs and shrubs. They recycle nutrients and occupy a valuable position in the 

food chain. They are native to Western rangelands and they have evolved to occupy 

various niches in the ecosystems. Even though these ecosystems have been impacted by 

various forms of human intervention and invasion by foreign plant and animal species, 

grasshoppers are usually benign with respect to human values. 

Additionally, integrated pest management (IPM) systems help hold grasshopper 

populations below economically damaging levels. Management tools which can be 

implemented by farmers, ranchers and land managers include: 

Mechanical Control 

Farmers can destroy grasshopper egg beds which are near crops. One example of this is 

the practice of disking the comers of fields irrigated by center-pivot sprinkler systems. 

Some grasshoppers, which have fed on crops, lay their eggs in the immediate area. 

Cultivation will destroy the eggs. If the comers of the field described by the arc at the end 

of the sprinkler are not cultivated, the new generation of grasshoppers will emerge 

directly adjacent to valuable crops. 

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ID-PPQ-GH2003-001 

In the earlier half of the 20th Century, mechanical flails and "hopper-dozer" collection 

devices were used to kill grasshoppers. These devices would not be compatible with 

contemporary precepts regarding destruction of rangeland plant life. 

Chemical Control 

Insecticides can be effective in reducing grasshopper populations. However, in IPM 

systems, insecticides must be applied only when their use is warranted by potential 

economic loss and justified with respect to other environmental concerns. Historically, in 

the past 15 years in Idaho, APHIS has applied insecticides in response to about 25% of 

the complaints/requests received fr.om.stakeholders impacted by grasshoppers. 

Biological Control 

Conservation of the natural predators, parasites, and pathogens can help hold grasshopper 

populations below outbreak levels. Avoidance of unwarranted insecticide applications is 

a key measure in such conservation programs. Some birds and mammals are very 

effective predators on grasshoppers. Domestic birds including turkeys and geese have 

been used in some areas to reduce grasshopper populations. 

Classical biological control is based on importing and releasing foreign biological control 

agents to control exotic invasive species. Classical biological control is not an option for 

grasshoppers, because grasshoppers are native species. 

Cultural Control 

USDA's Agricultural Research Service has accomplished significant research on grazing 

management and its impacts on grasshopper population density. However, this research 

is primarily applicable to short grass prairie ecosystems, not to the rangelands of the 

Great Basin. 

In commentary on the recent grasshopper Environmental Impact Study conducted by 

APHIS, another federal agency suggested burning and flooding rangeland to manage 

grasshoppers. Private landowners have also suggested burning rangeland to eliminate 

grasshoppers. 

Predicting Grasshopper Outbreaks and the Role of APHIS 

Grasshopper populations can build up to levels of economic infestation despite even the 

best land management and other efforts to prevent outbreaks. At such a time, a rapid and 

effective response may be requested and needed to reduce the destruction of rangeland 

vegetation. In some cases, a response is also needed to prevent grasshopper migration to 

private cropland adjacent to rangeland. Unfortunately, there is currently no reliable way 

to accurately predict the locations and severity with which outbreaks will occur. 

APHIS conducts annual surveys for grasshopper populations on rangeland in the Western 

United States. APHIS also provides ongoing technical assistance on grasshopper 

management to land owners and managers. APHIS works cooperatively to suppress 

grasshopper outbreaks on Federal land when direct intervention is requested by the 

Federal land management agency and APHIS determines that intervention is appropriate. 

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ID-PPQ-GH2003-001 

Results of the 2002 Idaho Grasshopper Survey are found in Appendix 2 and at 

http://www.agri.state.id.us/PDF/Plants/2002%20IDAH0%20GRASSHOPPER%20REP 

ORT.pdf 

In addition, APHIS works cooperatively to suppress grasshopper outbreaks on State or 

private land when a State Agriculture Department (on behalf of a State, a local 

government, a private group or an individual) requests intervention and APHIS 

determines that intervention is appropriate. The need for rapid and effective suppression 

of grasshoppers, when an outbreak occurs, limits the options available to APHIS. The 

application of an insecticide within all or part of the outbreak area is the response 

available for AP HIS to rapidly suppress or reduce (but not eradicate) grasshopper 

populations and effectively protect rangeland and adjacent resources such as private 

cropland. 

In June 2002, APHIS completed an Environmental Impact Statement (EIS) document 

concerning suppression of grasshopper populations in 17 Western States (Rangeland 

Grasshopper and Mormon Cricket Suppression Program, Environmental Impact 

Statement, June 21, 2002). The EIS described the actions available to APHIS to reduce 

the destruction caused by grasshopper populations in 17 States (Arizona, California, · 

Colorado, Idaho, Kansas, Montana, Nebraska, Nevada, New Mexico, North Dakota, 

Oklahoma, Oregon, South Dakota, Texas, Utah, Washington and Wyoming). 

APHIS' authority for cooperation in this suppression program is based on Section 417 of 

the Plant Protection Act of 2000 (7 U.S.C. § 7717). 

In May 2002, APHIS and FS signed a Memorandum of Understanding (MOU) detailing 

cooperative efforts between the two agencies on suppression of grasshoppers and 

Mormon crickets on national forest system lands, document #02-IA-11132020-106. This 

MOU clarifies that APHIS will prepare and issue to the public site-specific 

environmental documents that evaluate potential impacts associated with proposed 

measures to suppress economically damaging grasshopper and Mormon cricket 

populations. The MOU also states that these documents will be prepared under the 

APHIS NEPA implementing procedures with cooperation and input from FS. The MOU 

further states that the responsible FS official will request, in writing, the inclusion of 

appropriate lands in the APHIS suppression project when treatment on national forest 

land is necessary. The FS must also approve a Pesticide Use Proposal (Form FS-2100-2) 

for APHIS to treat infestations. According to the provisions of the MOU, APHIS can 

begin treatments after APHIS issues an appropriate decision document and FS approves 

the Pesticide Use Proposal. 

In February, 2003, APHIS and BLM signed a MOU detailing cooperative efforts between 

the two agencies on suppression of grasshoppers and Mormon crickets on BLM managed 

lands, APHIS PPQ MOU # 03-8100-0870-MU. This MOU clarifies that APHIS will 

prepare and issue to the public site-specific environmental documents that evaluate 

potential impacts associated with proposed measures to suppress economically damaging 

grasshopper and Mormon cricket populations. The MOU also states that these 

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ID-PPQ-GH2003-001 

documents will be prepared under the AP HIS NEPA implementing procedures with 

cooperation and input from the BLM. The MO. further states that the responsible BLM 

official will request, in writing, the inclusion of appropriate lands in the APHIS 

suppression project when treatment on BLM managed land is necessary. The BLM must 

also prepare a Pesticide .se Proposal for APHIS to treat infestations. According to the 

provisions of the MO., APHIS can begin treatments after APHIS issues an appropriate 

decision document and BLM approves the Pesticide .se Proposal. A Pesticide .se 

Proposal is the tracking mechanism by which pesticide use is reported to the 

Environmental Protection Agency (EPA) whose role is to track use under the Federal 

Insecticide Fungicide and Rodenticide Act as amended (Public Law (P.L.) 92-516). 

Responsibility for administering the act is vested in the EPA. 

APHIS and Idaho State Department of Agriculture (ISDA) cooperate under MO. 03-

8100-0403-M. to protect agricultural, horticultural and timber, and natural plant 

resources from losses caused by plant pests. This cooperation is conducted by APHIS by 

virtue of authority included in the act establishing the .nited States Department of 

Agriculture and the Plant Protection Act of June 20, 2000, (7 .SC 7701-7772), which 

defines plant pests, and provides the Secretary of Agriculture authority to cooperate with 

States or political subdivisions thereof, farmers' associations, and similar organizations, 

and individuals to eradicate, suppress, control, or to prevent or retard the spread of the 

plant pests. 

C. About This Process 

The EA process for grasshopper management is complicated by the fact that there is very 

little time between requests for treatment and the need for APHIS to take action with 

respect to those requests. Surveys help to determine general areas, among the scores of 

millions of acres that potentially could be affected, where grasshopper infestations may 

occur in the spring. There is considerable uncertainty, however, in the forecasts, so that 

framing specific proposals for analysis under NEPA would waste limited resources. At 

the same time, the program strives to alert the public, in a timely manner, to its more 

concrete treatment plans and avoid or minimize harm to the environment in implementing 

those plans. 

The 2002 EIS provides a solid, analytical and regulatory foundation; however, it may not 

be enough to satisfy NEPA completely for actual treatment proposals, and the 

"conventional" EA process will seldom, if ever, meet the program's timeframe of need. 

The following approach to NEPA compliance for anticipated requests to treat for 

grasshopper infestations will be followed: This EA will analyze aspects of environmental 

quality that could be affected by grasshopper treatment in the proposed suppression area. 

This EA and an anticipatory finding of no significant impact (FONSI) will be made 

available to the public with a comment period. When the program receives a treatment 

request and determines that treatment is necessary, the specific treatment site within the 

proposed suppression area will be extensively examined to determine if environmental 

issues exist that were not covered in this EA. If no changes to the EA, FONSI, or 

APHIS' Guidelines for Treatment of Rangelands for Grasshopper and Mormon Crickets 

(treatment guidelines) (Appendix 1) are warranted, based on the comments received and 

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ID-PPQ-GH2003-001 

examination of the treatment site, an addendum to the EA will be prepared stating this. If 

changes need to be made to the EA, FONSI, or treatment or treatment guidelines, the program will 

prepare a supplement to the EA describing the changes and/or additional site-specific 

issues that were not covered in the EA. Whether an addendum or supplement is 

prepared, these documents will be provided to all parties who comment on this EA. 

D. Scoping and input from the public 

November 19, 2002, APHIS mailed a scoping document to individuals and organizations 

who had indicated interest in grasshopper suppression programs in past years. Idaho State 

Department of Agriculture issued a notice of availability and posted the scoping 

document on their public website: 

http://www.agri.state.id. us/PDF /Plants/GH%20coverletter 02. pelf and 

http://www.agri.state.id.us/PDF/Plants/GH%20scoping%20document%20111902.pdf. 

Idaho Cooperative Extension Service conducted informational meetings in Malad, 

January 27, 2003 and in Burley, January 28, 2003. 

Response from the public and from governmental entities was mixed. 

Responses characterized as concerned about negative impacts of the proposed action 

Twenty three individuals who did not identify their background mailed comments stating 

their general opposition to spraying public rangeland or killing crickets. 

Three individuals who did not identify their background mailed comments stating that 

they were concerned about effects of treatments on non target species and urged cautious 

and prudent use of insecticides. 

Four organizations representing wildlife and natural areas conservation interests 

commented on a variety of issues. One organization focused comments on the potential 

for the suppression program to indirectly cause declines in populations of sage grouse, 

sharptail grouse and other rangeland bird species by reducing the arthropod prey which 

are vital to young and adult birds. The other three organizations addressed this issue as 

well. All four organizations indicated a need for APHIS to identify measures which 

would protect these birds and other nontarget organisms including threatened and 

endangered species. Three organizations expressed the belief that the proposed action 

required an environmental impact statement rather than an environmental assessment. 

These three organizations questioned the magnitude of the proposed action, especially the 

elevation mentioned in the scoping document. One organization was concerned that the 

proposed action would result in treatment of thousands of square miles, and three 

organizations asked for clarification on the area proposed for consideration. Three 

organizations expressed reservations about the expenditure of public funds for the 

proposed action. Three organizations cautioned against spraying near organic farms and 

indicated a need to notify residents and others in or near treatment areas. Two of the 

organizations questioned the need to protect private agricultural interests. Three 

organizations urged APHIS to consider non-insecticidal measures for grasshopper 

suppression. Three organizations indicated concern about human health effects of the 

proposed action. 

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ID-PPQ-GH2003-001 

One business and two individuals provided extensive commentary questioning the use of 

insecticides to control grasshoppers on rangeland. Those who commented expressed 

concerns about bioaccumulation of insecticides in animals which eat insects and about 

the general reduction of insect populations by nonspecific insecticides. They also 

expressed concern about the reduction in insect prey for young birds and other animals. 

One of those who commented, expressed the belief that public funds should not be spent 

on this program because the benefits would derive to the private sector. One commenter 

expressed the belief that AP HIS does not have adequate funds, time or expertise to 

properly evaluate the impacts of the proposed action. One commenter expressed the 

belief that the scoping process was flawed and perhaps illegal. 

Idaho State Government, responding through Departments of Fish and Game and 

Transportation urged that APHIS should provide protections for non-target species by 

including spray buffer zones and utilizing insecticides which are targeted toward 

grasshoppers rather than utilizing broad-spectrum insecticides. 

Specific concerns were: 

-Concern the proposed action might have on Threatened and Endangered Species. 

-Concern over potential direct and indirect impacts to range land birds. Reduction of 

insects (including GH) as prey for Columbia Sharp Tailed grouse and Sage grouse was 

sited by a number of those who commented. 

-Concern for monitoring to insure that none of Idaho's sensitive insects are present in 

treatment areas. 

-Concern for the fate of non-target insects within treatment areas, particularly with the 

use of broad spectrum insecticides such as Malathion and Carbaryl. 

-Concern that APHIS intended to apply pesticides on a "wide scale", which would 

remove insects from the ecosystem with long term irreversible consequences and damage 

to the ecosystem. 

-Concern for isolated populations of Eriogonum sp. and its pollinator Euphilotes enoptes 

if they are within a proposed treatment area. Concern of impacts to pollinators of rare and 

native plants in general. 

-Concern that the pesticides proposed for GH control would bio-accumulate within birds, 

reptiles, mammals, amphibians, fish, livestock, and humans. 

-Concern that the application of insecticides would result in contamination of surface 

waters through direct contact or storm runoff. The EA should discuss and prescribe 

buffer strips along waterways. 

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ID-PPQ-G H2003-001 

-Concern about effects of impurities, inert ingredients, diluents and carriers utilized in 

conjunction with the pesticides. 

-Concern about the effects of the pesticides decomposition products through ingestion 

and exposure to ultraviolet light. 

-Concern for effects to Organic farms from any treatment program. One commentator 

suggested a five mile buffer from organic farms. 

-Need for definition of "effective" and "ineffective" in terms of GH control. 

-Concern for notification of persons in the vicinity of any treatment program and the need 

for at least one month advance notice of any treatment. Another commentator suggested 

APHIS make all possible efforts to inform residents within 5 miles of any proposed 

treatment. 

-Concern that the use of airplanes is imprecise and will result in off target application. 

The BLM's recent experience with OUST was cited. 

-Concern that APHIS did not evaluate alternatives such as Noserna locustae, biological 

control, traps, turkey flocks or long term mitigation through rehabilitation of Federal 

rangelands in its EIS. 

-Concern that the alternatives such as "crop damage restitution" or spraying crops 

themselves would not be evaluated. 

-Concern that public funds would be expended to protect private sector profits. 

- Need for Conference with USFWS and NMFS because of the potential for 

contaminated water to move downstream into endangered salmonid habitat. 

-Concern that the 2002 EIS failed to adequately analyze impacts and is an inadequate 

document for tiering the proposed 2003 EA. 

-One commentator suggested that all slick spot (peppergrass) habitats be provided a five 

mile buffer. 

-One commentator suggested that local residents, recreationalists and agency biologists 

be given veto power over any proposed action. 

-One commentator questioned what the scientific protocols would be for the evaluation of 

GH species composition, population density, stage of development, value of resources 

threatened and environmental costs associated with treatments. 

-One commentator requested data and maps for all spray operations in the last ten years. 

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ID-PPQ-GH2003-001 

-One commentator requested that APHIS include information on all federal payments to 

farmers whose lands are located in areas typically treated by APHIS. 

-Concern over the direct, indirect and cumulative impacts of pesticides and their 

breakdown products on Soils, Water, Native Biota and Human Health. 

-Concern over the relative carcinogenicity of these pesticides and breakdown products. 

-One commentator questioned how APHIS would take into.account and assess the 

impacts or actions of private landowners trying to manage GH, including the use of bait 

provided by ISDA. 

-Concern that APHIS delineate insect population and other threshold levels that would 

have to be quantified and reached before action by APHIS. 

-Concern on the effects to fish from the loss of insect foods. 

Responses characterized as concerned about lack of effectiveness of theproposed action 

Thirteen individuals who identified themselves as farmers or ranchers mailed written 

comments regarding the proposed action. They indicated that they believed control 

actions should take place earlier in the year and on greater acreage than was allowed 

under earlier EAs. 

Participants at the public meetings were primarily farmers or ranchers and were generally 

supportive of the need for a grasshopper suppression program on federal land. Four 

participants at Malad and nine at Burley provided written comments regarding support 

for suppression activities to counter economic losses. Some participants agreed to 

develop a private program for Mormon cricket suppression on private land near Malad. 

Participants asked questions about the beneficial and harmful effects of the options 

available to APHIS. 

Three county governments, responding through their county commissioners, expressed 

concern that mitigations within the grasshopper suppression program in previous years 

had lessened the effectiveness of the program. They urged that fewer restrictions should 

be placed on treatments. 

Three organizations representing agricultural interests provided comments indicating that 

they believed restrictions placed on the program in the past were excessive and that larger 

areas should be sprayed when grasshopper populations reach high levels. They 

mentioned that the restriction which required sagebrush to remain untreated until July 15 

was especially troublesome. 

Idaho State Department of Agriculture urged AP HIS to utilize methods which would 

result in effective control of grasshoppers and to avoid unduly restrictive mitigation 

measures. 

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ID-PPQ-GH2003-001 

Persons who commented also expressed support for grasshopper control. Economic 

consequences of loss of forage and damage to crops were sited as reasons for undertaking 

GH/MC control programs. Concerns raised by those who commented stressed the need 

for flexibility in program guidelines. 

Specific concerns were: 

- The no treatment restriction in the 2000 EA on lands with 5% or more sagebrush cover 

until July 15. Many persons who commented suggested this undermined the prQgrams 

effectiveness. 

-Limiting treatments of GH/MC only when these species were within a half mile of crops 

left too much of the infestation untreated. 

In general, some of those who commented criticized the response of APHIS to GH 

outbreaks as being "too little, too late". Some persons who commented criticized the ten 

thousand acre minimum as being unresponsive to the need for small acreage crop 

protection programs. 

Written comments are available for public review at USDA APHIS PPQ, 9134 West 

Blackeagle Drive, Boise, Idaho. 

APHIS response to scoping 

APHIS has developed Alternative D (Modified Reduced Agent Area Treatments) as a 

strategy that would minimize both the volume of insecticides applied and the area to 

which they would be applied in response to the above concerns while also being 

responsive to conditions in Idaho and other Great Basin locations where grasshoppers can 

reach infestation levels rapidly. 

APHIS has refined the description of the proposed treatment area to include only 

rangelands at or below 7500 feet elevation. An estimate of acreage which might be 

treated in 2003 has also been developed and is discussed on page 26 of this EA. 

APHIS has developed a plan of action that would reduce insecticide applications on areas 

inhabited by sage-obligate species. This plan is outlined in Tables 1 and 2 of this EA. 

By proposing to adopt the plan of action which limits contiguous swath width to no more 

than 300 feet, AP HIS eliminates the potential use of large fixed wing aircraft. 

APHIS has developed a plan that will make use, whenever possible, of selective 

insecticides that have little or no effect on insect fauna which are mature and/or not 

feeding on plant foliage. These measures are explained throughout the EA. 

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ID-PPQ-GH2003-001 

APHIS has incorporated buffers around sensitive areas including organic farms, water, 

pollinating insects and habitat of certain sensitive species. Buffers are discussed on page 

23, Table 3 (pp 68-71), and Appendix I. 

APHIS has attempted to explain on pages 15-23, of the EA, the constraints under which 

the agency operates with respect to management decisions on federal, state and private 

lands. 

APHIS has coordinated with FWS and NOAA Fisheries to develop protection measures 

for federally listed threatened and endangered species. The protections are summarized 

in Table 3 and correspondence from FWS and NOAA Fisheries is in Appendix 3. 

APHIS has incorporated treatment guidelines, standard operational procedures and an 

environmental monitoring plan into the EA. These measures are included as Appendices 

1 and 5 of the EA. 

APHIS has developed a documentation plan for grasshopper population evaluations and 

grasshopper treatment decision-making. These steps are explained in Appendix 4 of the 

EA. 

II. Alternatives 

The alternatives presented in this EA are: (A) No Action, (B) Insecticide Applications at 

Conventional Rates and Complete Area Coverage, (C) Reduced Agent Area Treatments 

(RAATS), and (D) Modified Reduced Agent Area Treatments (MRAATs). The first 

three of these alternatives, their control methods, and their potential impacts were 

described and analyzed in detail in the 2002 EIS. Copies of the complete 2002 EIS 

document are available for review at 9134 W. Blackeagle Drive, Boise ID 83709. It is 

also available at http://www.aphis.usda.gov:80/ppd/es/gh.html 

The fourth alternative was developed to respond to concerns received during scoping and 

to conditions in Idaho and other Great Basin locations where grasshoppers can emigrate 

from desiccating rangeland into irrigated crops and other high value areas rapidly. In 

such a circumstance, fast knockdown and high target mortality is required. The fourth 

alternative is the same as Alternative C except that carbaryl bait could be used at 5 

percent formulation. 

The 2002 EIS is intended to explore and explain potential environmental effects 

associated with grasshopper suppression programs that could occur in 17 Western States 

(Arizona, California, Colorado, Idaho, Kansas, Montana, Nebraska, Nevada, New 

Mexico, North Dakota, Oklahoma, Oregon, South Dakota, Texas, Utah, Washington, and 

Wyoming). The 2002 EIS outlines the importance of grasshoppers as a natural part of the 

rangeland ecosystem. However, grasshopper outbreaks can compete with livestock for 

rangeland forage and cause devastating damage to crops and rangeland ecosystems. 

Rather than opting for a specific proposed action from the alternatives presented, the 

11 
ID-PPQ-GH2003-001 

2002 EIS analyzes in detail the environmental impacts associated with each 

programmatic action alternative related to grasshopper suppression based on new 

information and technologies. 

All insecticides used by APHIS for grasshopper and Mormon cricket suppression are 

used in accordance with all applicable product label instructions and restrictions. 

Representative product specimen labels can be accessed at the Crop Data Management 

Systems, Inc. web site at www.cdms.net/manuf/manuf.asp. Actual brand-name products 

used in suppression programs may vary, depending on supply issues. 

All insecticide treatments conducted by APHIS would be implemented in accordance 

with the APHIS' FY-2003 Guidelines for Treatment of Rangeland for Grasshoppers and 

Mormon Crickets, (Guidelines), included as Appendix I to this EA. The 2003 Guidelines 

and Operational Procedures were developed by APHIS to provide established safety 

guidelines which will be employed in the I 7 Western states where grasshopper 

suppression programs may occur. 

A. No Action Alternative 

Under the No Action alternative, APHIS would not fund or participate in a program to 

suppress grasshopper infestations. Under this alternative, APHIS may opt to provide 

limited technical assistance, but the suppression program would be implemented by a 

Federal land management agency, a State agriculture department, a local government, or 

a private group or individual. 

B. Insecticide Applications at Conventional Rates and Complete Area 

Coverage Alternative 

Insecticide applications at conventional rates and complete area coverage, is generally the 

approach that APHIS has used for many years. Under this alternative, carbaryl, 

diflubenzuron (Dimilin®), or malathion would be employed. Carbaryl and malathion are 

insecticides that have traditionally been used by APHIS. The insect growth regulator, 

diflubenzuron, is also included in this alternative. Applications would cover sites which 

justify treatment within the infested area (total or blanket coverage) per label directions. 

The maximum application rates under this alternative are as follows: 

• 16.0 fluid ounces (0.50 pound active ingredient (lb a.i.)) of carbaryl 

spray per acre; 

• 10.0 pounds (0.50 lb a.i.) of 5% carbaryl bait per acre; 

• 1.0 fluid ounce (0.016 lb a.i.) of diflubenzuron spray per acre; or 

• 8.0 fluid ounces (0.62 lb a.i.) of malathion spray per acre. 

These application rates are less than or equal to the maximum rates allowed by EPA for 

grasshopper control. The carbaryl spray rate is 50% of the maximum EPA allowable 

rate. The carbaryl bait rate is 25% of the maximum EPA allowable rate. The 

diflubenzuron rate is 100% of the EPA allowable rate. The malathion spray rate is 68% 

of the maximum EPA allowable rate. 

12 
ID-PPQ-GH2003-001 

In accordance with EPA regulations, these insecticides may be applied at lower rates than 

those listed above. Additionally, coverage may be reduced to less than the full area 

coverage, resulting in lesser effects to nontarget organisms. 

The potential generalized environmental effects of the application of carbaryl, 

diflubenzuron, and malathion, under this alternative, are discussed in detail in the 2002 

EIS (Environmental Consequences of Insecticide Applications at Conventional Rates and 

Complete Area Coverage, pp. 38-48). A description of anticipated site-specific impacts 

from this alternative may be found in Part IV of this document. 

C. Reduced Agent Area Treatments (RAATs) Alternative 

RAA Ts, is a recently developed grasshopper suppression method in which the rate of 

insecticide is reduced from conventional levels, and treated swaths are alternated with 

swaths that are not directly treated. The RAA Ts strategy relies on the effects of an 

insecticide to suppress grasshoppers within treated swaths, while conserving grasshopper 

predators and parasites in swaths not directly treated. Carbaryl, diflubenzuron, or 

malathion would be considered under this alternative at the following maximum 

application rates: 

• 8.0 fluid ounces (0.25 lb a.i.) of carbaryl spray per acre, 

• 10.0 pounds (0.20 lb a.i.) of 2 percent carbaryl bait per acre, 

• 0.75 fluid ounce (0.012 lb a.i.) of diflubenzuron spray per acre, or 

• 4.0 fluid ounces (0.31 lb a.i.) of malathion spray per acre. 

For the sprays, both the area treated and the amount of insecticide applied to the treated 

area are reduced vs the Insecticide Applications at Conventional Rates and Complete 

Area Coverage Alternative. For the bait, the area treated and the active ingredient in the 

formulation are reduced vs the Insecticide Applications at Conventional Rates and 

Complete Area Coverage Alternative. 

These application rates are less than or equal to the maximum rates allowed by EPA for 

grasshopper control. The carbaryl spray rate is 25% of the maximum EPA allowable 

rate. The carbaryl bait rate is 10% of the EPA allowable rate. The difubenzuron spray 

rate is 75% of the maximum EPA allowable rate. The malathion spray rate is 34% of the 

maximum EPA allowable rate. 

The area not directly treated (the untreated swath) under the RAATs approach is not 

standardized. In practice, the area infested with grasshoppers that remains untreated has 

ranged from 20 to 67 percent. The 2002 EIS analyzed the reduced pesticide application 

rates associated with the RAA Ts approach but assumed pesticide coverage on 100 

percent of the area as a worst-case assumption. This assumption was made because there 

is no way to predict how much area would actually be left untreated pursuant to local 

environmental analyses. Rather than suppress grasshopper populations to the greatest 

extent possible, the goal of this alternative is to suppress grasshopper populations to a 

less damaging level. 

13 
ID-PPQ-GH2003-001 

The potential environmental effects of application of carbaryl, diflubenzuron, and 

malathion under this alternative are discussed in detail in the 2002 EIS (Environmental 

Consequences of Reduced Agent Area Treatments (RAA Ts), pp. 49-57). A description 

of anticipated site-specific impacts from this proposed treatment may be found in Part IV 

of this document. 

D. Modified Reduced Agent Area Treatments (MRAATs) Alternative 

(Preferred Alternative) 

MRAA Ts, is the same as the RAA TS Alternative with one exception. Carbaryl bait 

could be used in the 5% formulation as well as the 2% formulation. Carbaryl, 

diflubenzuron, or malathion would be considered under this alternative at the following 

maximum application rates: 

• 8.0 fluid ounces (0.25 lb a.i.) of carbaryl spray per acre, 

• 10.0 pounds (0.50 lb a.i.) of 5 percent carbaryl bait per acre, 

• 10.0 pounds (0.20 lb a.i.) of 2 percent carbaryl bait per acre, 

• 0.75 fluid ounce (0.012 lb a.i.) of diflubenzuron spray per acre, or 

• 4.0 fluid ounces (0.31 lb a.i.) of malathion spray per acre. 

For the sprays, both the area treated and the amount of insecticide applied to the treated 

area are reduced vs the Insecticide Applications at Conventional Rates and Complete 

Area Coverage Alternative. For the bait, the area treated and the active ingredient in the 

formulation may be reduced vs the Insecticide Applications at Conventional Rates and 

Complete Area Coverage Alternative. 

This alternative provides an option that is important for conditions in Idaho and other 

Great Basin locations. Grasshoppers, especially Mormon crickets can emigrate from 

desiccating rangeland into irrigated crops and other high value areas rapidly and in great 

numbers. This phenomenon is not as common in the other six eco-regions discussed in 

the 2002 EIS. When such emigrations are imminent, fast knockdown and high target 

mortality is required. The 5% vs 2% formulation of carbaryl bait can provide higher 

mortality than the lower rate, it provides quicker knockdown than diflubenzuron, and it 

provides better target specificity than carbaryl or malathion spray. 

Although this specific alternative was not analyzed, per se, in the 2002 EIS, it is within 

the scope of the 2002 EIS because the carbaryl bait component of the alternative was 

analyzed within the Insecticide Applications at Conventional Rates and Complete Area 

Coverage Alternative and the other components were analyzed within the RAATs 

Alternative. A description of anticipated site-specific impacts from this proposed 

treatment may be found in Part IV of this document. 

14 
ID-PPQ-GH2003-001 

III. Methodologies 

These methodologies apply to all alternatives. 

A. Land Administration 

As provided by the Plant Protection Act, APHIS would conduct grasshopper suppression 

programs on Federal, State or private lands in response to requests of the administering 

agency or the State Department of Agriculture. Over the past two decades, most of the 

suppression programs in Idaho have been on lands administered by BLM. Smaller 

amounts of State ofldaho, National Forest System lands have been treated. 

Bureau of Land Management 

APHIS would treat severe grasshopper outbreaks on public lands administered by the 

BLM in Idaho when treatments are necessary and can be effective in minimizing private 

and public resource impacts. APHIS would evaluate site specific complaints, develop 

proposed treatment strategies consistent with the program and protection measures 

documented in this EA, and implement specific control or suppression actions. The 

grasshopper suppression program for BLM managed public lands in Idaho would be 

anticipated primarily for crop protection where private lands are within close proximity, 

and economic damage is occurring or, is expected to occur. Treatments on public lands 

might also be necessary to protect rangeland resources, native plant community 

restoration projects, and community values when threatened by severe infestations. All 

treatments on public lands would be designed to minimize the size of treatment areas and 

would incorporate appropriate protection measures to protect resource values while 

maintaining treatment effectiveness. APHIS would treat small infestations or "hot spots" 

in a timely fashion to minimize the need to treat larger infestations and areas later. These 

treatment and suppression measures might be conducted either by ground or aerial 

applications. 

Forest Service 

APHIS would treat severe grasshopper outbreaks on National Forest System lands 

administered by FS in Idaho when treatments are necessary and can be effective in 

minimizing private and public resource impacts. APHIS would evaluate site specific 

complaints, develop proposed treatment strategies consistent with the program and 

protection measures documented in this EA, and implement specific control or 

suppression actions. The grasshopper suppression program for National Forest System 

lands in Idaho would be anticipated primarily for crop protection where private lands are 

within close proximity, and economic damage is occurring or, is expected to occur. 

Treatments on National Forest System lands might also be necessary to protect rangeland 

resources, native plant community restoration projects, and community values when 

threatened by severe infestations. All treatments on National Forest System lands would 

be designed to minimize the size of treatment areas and would incorporate appropriate 

protection measures to protect resource values while maintaining treatment effectiveness. 

APHIS would treat small infestations or "hot spots" in a timely fashion to minimize the 

need to treat larger infestations and areas later. These treatment and suppression 

measures might be conducted either by ground or aerial applications. 

15 
ID-PPQ-GH2003-001 

State Lands 

APHIS would treat severe grasshopper outbreaks on rangelands administered by the State 

of Idaho when requested by the Idaho State Department of Agriculture under the 

provisions of the Plant Protection Act and subject to availability of cost-share funding as 

specified by the Plant Protection Act. 

Private Lands 

APHIS would treat severe grasshopper outbreaks on private rangeland when requested by 

the Idaho State Department of Agriculture under the provisions of the Plant Protection 

Act and subject to availability of cost-share funding as specified by the Plant Protection 

Act. 

B. Documenting Rangeland Grasshopper Suppression Programs 

Requests for grasshopper suppression programs may come from land managers or Idaho 

State Agriculture Department, at any time. Complaints from private landowners and 

other persons who are threatened by grasshopper outbreaks normally come when the 

outbreak is in progress. APHIS would document requests from federal land managers as 

they are received. APHIS would document complaints from private landowners and 

other persons with the protocol included as Appendix 4. APHIS would document 

evaluations, recommendations regarding treatments, and the conduct of treatments with 

the protocol included as Appendix 4. Treatments would also be extensively documented 

as specified in APHIS Aerial Application Manual (1996), the Guidelines attached as 

Appendix 1, and the Environmental Monitoring Guidelines attached as Appendix 5. 

C. Insecticide Characteristics 

The insecticides available to APHIS are diflubenzuron, carbaryl (spray and bait), and 

malathion. The decision on which insecticide (if any) to use in any situation depends on 

a variety of factors specific to any given site and situation. Each of the insecticides 

which might be selected for a treatment has characteristics that dictate its desirability for 

a treatment. 

Diflubenzuron only kills grasshoppers or other insects when they are in their immature 

stages. It will not kill adult grasshoppers. It cannot be used late in the season because the 

grasshoppers are no longer susceptible. In a normal year, the opportunity to use 

diflubenzuron, in Idaho, can be expected to pass by about June 15 for Mormon crickets 

and July 15 for most other species of grasshoppers. Insects are not killed until seven to 

ten days after treatment. Diflubenzuron is reported to have a residual activity against 

grasshoppers lasting up to 28 days. Diflubenzuron is less harmful to other insects and 

essentially harmless to vertebrates vs the other insecticides. Diflubenzuron must be 

applied as a spray with water and crop oil. APHIS currently has no provisions for 

dispensing it from the ground in Idaho. It is the least costly option per acre treated. The 

formulation of diflubenzuron approved for use by APHIS is Dimilin 2L ®. 

Carbaryl bait acts faster than diflubenzuron. It kills adult and immature grasshoppers and 

other insects. It has a broader spectrum of insecticidal activity than diflubenzuron, but it 

must be ingested to be lethal. It can be used effectively any time during the grasshopper 

16 
ID-PPQ-GH2003-001 

season. It can be applied by air or ground. It is the most costly option. Carbary! bait is 

applied in greater mass than any of the other treatments (up to 10 lbs. dry material per 

acre) and creates a greater logistical problem because of the amount of material which 

must be stored, transported and applied. Carbary! bait can be applied by air in some 

situations when and where liquid insecticides cannot. Although no aerial applications of 

any insecticide can be conducted when wind speeds exceed 10 mph, carbaryl bait can be 

applied when air temperatures are too high to permit effective applications of sprays. 

Additionally, when terrain is too rough to allow consistently flying at the low altitude 

consistent with effective spray application, bait can be applied by flying at a safe altitude 

over the ground. Thus, the window of opportunity to apply bait is greater than for sprays. 

The carbaryl bait formulations approved for use by APHIS include products which 

impregnate carbaryl onto wheat bran, onto rolled whole wheat, and into pellets 

manufactured from grape and apple pumice. The whole wheat and pellet formulations 

offer logistical advantages in application (greater bulk density) and are less likely to drift 

off target vs the bran formulation. 

Carbary! spray is a broad spectrum contact insecticide that is more effective in cool 

weather than hot weather. It kills adult and immature grasshoppers and other insects. It 

has a knock-down effect intermediate between diflubenzuron and malathion sprays, and it 

has a residual activity of up to 14 days. It is normally applied by air for grasshoppers on 

rangeland. It could be applied by ground, although such applications would have to be 

very limited in scope, such as grasshopper hatching beds. It is intermediate in cost. It 

carries higher risk for nontarget species vs diflubenzuron or carbaryl bait. Because of the 

residual toxicity to bees, it is not likely to be a treatment of choice in this program. The 

carbaryl formulation approved for use by APHIS is Sevin XLR Plus. This formulation 

uses water as the carrier. Formerly, Sevin 4 Oil was used by APHIS for grasshopper 

suppression. That formulation used diesel oil as a carrier. 

Malathion spray is a broad spectrum contact insecticide that is more effective in hot 

weather vs cool weather. It kills adult and immature grasshoppers and other insects. It 

has immediate knock-down effect and has essentially no residual activity. It is normally 

applied by air for grasshoppers on rangeland. It could be applied by ground, although 

such applications would have to be very limited in scope, such as grasshopper hatching 

beds. It is intermediate in cost. It carries higher risk for nontarget species vs 

diflubenzuron or carbaryl bait. The formulations of malathion approved for use by 

APHIS are Ultra Low Volume Concentrates. They are applied without an additional 

earner. 

Detailed information on the insecticides used by APHIS for grasshopper control is found 

in the 2002 EIS pp 30-36. Information on surfactants or additives to sprays is found in 

the 2002 EIS pp 36-3 7. 

17 
ID-PPQ-GH2003-001 

D. Treatment Strategy 

1. Basis for decision to treat 

Grasshopper populations which are not likely to threaten crops or cause significant 

damage to rangeland would not be treated. Several factors are included in the threat 

assessments. The first level of assessment is the overall grasshopper population density. 

This is determined through field survey and is expressed in grasshoppers per square yard. 

In addition to the density of grasshoppers, an assessment of the species composition/life 

stage would be made. Species without strong migratory habits are less of a concern to 

proximate croplands than those with strong migratory characteristics. Examples of 

grasshoppers with strong migratory habits include Mormon crickets, Me/anop/us 

sanguinipes, and Camnula pel/ucida. Examples of grasshoppers which are not highly 

migratory include the short-winged form of Oedaleonotus enigma, and Hesperotettix 

viridis. 

The life stage of the grasshoppers can influence a decision to treat. Sexually mature adult 

Mormon crickets are very large, highly visible, disturbing to some passersby, and can 

occur in very high population densities. However, they do not form migratory bands as 

do their immature forms. Therefore they would not normally be subject to treatment. 

2. Selection of treatment 

Following a decision to conduct a treatment, the pesticide would be chosen according to 

site specific conditions. This involves many factors including type and density of 

vegetation, grasshopper species' acceptance of bait, terrain, climatic conditions, 

proximity to pollinators, life stage of the grasshopper, importance of rapid reduction of 

grasshopper density, need for residual control, costs, and logistics. 

Because of their different modes of action, and suitability under different climatic 

conditions, the three pesticides can be sorted as follows: 

er Life sta e Weather conditions Pesticide 

Cool and wet Diflubenzuron, Carb 

Hot and Diflubenzuron, Malathion 

Adults Cool and wet 

Adults Hot and l, Malathion 

3. Multiple applications 

Normally, no area would be treated more than once during a grasshopper season. A 

potential exception to this norm might exist if an outbreak of Mormon crickets in the 

spring was followed by an outbreak of grasshoppers later in the summer. Another 

exception could be if a Mormon cricket outbreak of exceptional proportions results in 

consumption of all the insecticidal bait which was applied to an area. This condition does 

occur when extremely large, dense bands of Mormon crickets traverse an area. No other 

scenarios would warrant multiple treatments. Any multiple treatments would be in 

accordance with insecticide label restrictions. 

18 
ID-PPQ-GH2003-001 

4. Methods of application 

Insecticides would be applied in swaths which have a width determined for each 

treatment device (aircraft, truck-mounted spreader, or ATV-mounted spreader) and 

insecticide. For instance, an Ayres Turbine Thrush aircraft can deliver a 100 foot swath 

with diflubenzuron, and an ATV-mounted bait spreader can deliver a 15 foot swath with 

carbaryl bait. 

Insecticide Applications at Conventional Rates and Complete Area Coverage Alternative 

utilizes the approach of spacing the centerline of adjacent swaths one swath-width apart. 

RAA TS and MRAA TS utilize variable spacing of the swaths. Distance between 

noncontiguous swaths may be based on the vegetation density, grasshopper population 

pressure and value of the resource being protected. 

Although RAA TS was analyzed in the 2002 EIS with assumptions based on full 

coverage, typical coverage under RAA TS in states East and South of Idaho has been 

50%. Swath centerlines were uniformly two swath-widths apart. Recent RAA TS 

research has involved coverage between 25% and 67% of the infested acreage. Under 

this proposed action RAATS and MRAATS would be defined as treatment blocks 

with contiguous insecticidal coverage of strips no more than 300 feet wide and 25% 

to 90% of the treatment block left untreated. 

5. Discrimination based on vegetative type 

A decision to treat or not treat as well as the selection of insecticide rate and area to be 

covered is based in part on the vegetative type. All areas subject to treatment under the 

proposed action would be either shrub-steppe or grasslands. They are defined as follows: 

Shrub-steppe: Areas with more than 15% shrub cover within the proposed 

treatment block 

Grassland: Annual or seeded grass-dominated areas with 15% or less shrub cover 

within the proposed treatment block 

6. Crop Protection and Rangeland Suppression Components 

Treatments would be considered for crop protection or rangeland suppression programs. 

Components ofldaho 2003 crop protection program (Table 1 ): 

1. The treatment block would generally consist of a strip of rangeland adjacent to crops. 

Treatment blocks up to 1 mile wide may be authorized as shown in the table below. 

The entire treatment block would not be treated. The area to which insecticides 

would be applied within a treatment block would range from 25% to 75% of the total 

block. No contiguous strip greater than 300 feet wide would be treated. Normally, 

no area would be treated more than once during the year. 

2. Diflubenzuron would be used whenever possible to make early applications to 

outbreaks. 

19 
ID-PPQ-GH2003-001 

3. Carbaryl bait would be the selected treatment later in the season where nontarget 

species might be put at risk by malathion or carbaryl spray. 

4. Malathion or carbaryl spray would be selected when high populations require quick 

knock-down. 

Table 1 - Proposed treatments and treatment blocks for 2003 Idaho 

grasshopper and Mormon cricket crop protection 

Insecticide Treatment Area 

Characteristics 

Difiubenzuron spray Grasslands 

Applied at rate of 0. 7 5 fluid 

ounce of diflubenzuron per 

acre (0.012 lb. a.i. per acre) 

Unless a dijlubemuron 

tolerance is approved for the 

crop, a 500 foot buffer from 

the crop would be used. 

Carbaryl bait 

Applied at rate of no more 

than 10. 0 pounds of 2% or 

5% carbaryl bait per acre 

(0.20 to 0.50 lb. a.i. per acre) 

Shrub Steppe 

Grasslands 

Shrub steppe 

Carbaryl spray Grasslands 

Applied at rate of 8. 0 fluid 

ounces of carbaryl spray per 

acre. (0.25 lb a.i. per acre) 

Shrub steppe 

20 

Proposed Treatment Blocks 

for Crop protection 

Generally . to mile strip 

of rangeland but could go up 

to 1 mile wide with 25% to 

75% coverage. 

Generally . to mile strip 

of rangeland but could go up 

to 1 mile wide with 25% to 

75% coverage. 

Generally . to mile strip 

of rangeland but could go up 

to 1 mile wide with 25% to 

75% coverage. 

Generally . to mile strip 

of rangeland but could go up 

to 1 mile wide with 25% to 

75% coverage. 

Generally 1⁄4 to mile strip 

of rangeland but could go up 

to 1 mile wide with 25% to 

75% coverage1⁄4 

Not used unless grasshopper 

population exceeds 20/sq yd 

Up to 1⁄4 mile wide strip of 

rangeland with 25% to 75% 

coverage1⁄4 
ID-PPQ-GH2003-001 

Insecticide Treatment Area Proposed Treatment Blocks 

Characteristics for Crop protection 

Malathion spray Grasslands Generally . to mile strip 

Applied at rate of 4. 0 fluid of rangeland but could go up 

to I mile wide with 25% to 

ounces of malathion per acre 75% coverage1⁄4 (0.31 lbs a.i. per acre) 

Shrub steppe Not used unless grasshopper 

population exceeds 20/sq yd. 

Up to 1⁄2 mile strip of 

rangeland with 25% to 75% 

coveraf!e. 

Components of Proposed Idaho 2003 rangeland grasshopper suppression program 

General Rangeland protection (Table 2): 

I. The treatment block would consist of a parcel of rangeland infested by an incipient 

grasshopper outbreak. Treatment blocks up to I 0,000 acres may be authorized as 

shown in the table below. The entire treatment block would not be treated. The 

surface area to which insecticides would be applied within a treatment block would 

range from 10% to 50% of the total block. No contiguous strip greater than 300 feet 

wide would be treated. Normally, no area would be treated more than once during 

the year. 

2. Diflubenzuron would be used whenever possible to make early applications to 

outbreaks. 

3. Carbary! bait would be the selected treatment later in the season where nontarget 

species might be put at risk by malathion or carbaryl spray. 

4. Malathion or carbaryl spray would be selected when high populations require quick 

knock-down. 

Table 2 -- Proposed treatments and treatment blocks for 2003 Idaho 

grass h opper an dM ormon cric icket e range l an d suppression 

Insecticide Treatment Area Proposed Treatment Blocks 

Characteristics for rangeland suppression 

Diflubenzuron spray Grasslands Area infested at greater than 

Applied at rate of 0. 75 fluid 8 grasshoppers or 3 Mormon 

ounce of diflubenzuron per crickets per Sq. yd. 10% to 

acre (0.012 lb. a.i. per acre) 50% coveraf!e. 

Shrub Steppe Area infested at greater than 

8 grasshoppers or 3 Mormon 

crickets per Sq. yd. 10% to 

50% coverage1⁄4 

21 
ID-PPQ-GH2003-001 

Insecticide Treatment Area Proposed Treatment Blocks 

Characteristics for rangeland suppression 

Carbary( bait Grasslands Area infested at greater than 

Applied at rate of no more 8 grasshoppers or 3 Mormon 

than 10. 0 pounds of 2% or crickets per Sq. yd. 10% to 

5% carbaryl bait per acre 50% coverage. 

(0.20 to 0.50 lb. a.i. per acre) Shrub steppe Area infested at greater than 

8 grasshoppers or 3 Mormon 

crickets per Sq. yd. 10% to 

5 0% coverage. 

Carbary( spray Grasslands Area infested at greater than 

Applied at rate of 8. 0 fluid 8 grasshoppers or 3 Mormon 

ounces of carbaryl spray per crickets per Sq. yd. 10% to 

acre. (0.25 lb a.i. per acre) 50% coverage. 

Shrub steppe Area infested at greater than 

20 grasshoppers or 6 

Mormon crickets per Sq. yd. 

10% to 25% coverage. 

Malathion spray Grasslands Area infested at greater than 

20 grasshoppers or 6 

Applied at rate of 4. 0 fluid Mormon crickets per Sq. yd. 

ounces of malathion per acre 10% to 25% coverage. 

(0.31 lbs a.i. per acre) Shrub steppe Area infested at greater than 

20 grasshoppers or 6 

Mormon crickets per Sq. yd. 

10% to 50% coverage. 

Rational for proposed treatment methodologies: 

These application rates are less than or equal to the maximum rates allowed by EPA for 

grasshopper control. The carbaryl spray rate is 25% of the maximum EPA allowable 

rate. The carbaryl bait rate is 10% to 25% of the EPA allowable rate. The difubenzuron 

spray rate is 75% of the maximum EPA allowable rate. The malathion spray rate is 34% 

of the maximum EPA allowable rate. The area actually treated with insecticide varies 

between 10% and 75% of the total area in the spray block. By reducing the both the 

application rates and the area treated, safety margins are built into the proposed action. 

Diflubenzuron is essentially nontoxic to non-arthropod species and does not kill all 

species and stages of insects. Malathion presents a greater risk than diflubenzuron to 

mammals, birds, and nontarget insects. Carbary! spray presents a greater risk than 

diflubenzuron to mammals, birds, fish, and nontarget insects. Carbary! bait is 

intermediate between the diflubenzuron spray and the malathion and carbaryl sprays with 

22 
ID-PPQ-G H2003-001 

respect to risk to mammals, birds, fish, and nontarget insects. The ability of carbaryl bait 

to fall through the layers of vegetation and be deposited on the ground improves the 

effectiveness of this treatment strategy. 

7. Additional Protective Measures Which Are Not Included in FY 2003 

Guidelines (Appendix 1) 

Insecticide application rates would be reduced below EPA maximum allowable rates. 

Percentage of EPA maximum allowable rates which would be applied: 

carbaryl spray 25% 

carbaryl bait 10% to 25% 

difubenzuron spray 75% 

malathion spray 34 % 

Treatment blocks would not receive full area coverage. 25% to 90% of treatment block 

would not receive direct application. 

Aerial sprays of diflubenzuron, carbaryl and malathion would not be made within . mile 

of waters of the U.S. including rivers, tributaries, streams, reservoirs, and wetlands. 

Aerial applications of carbaryl bait would not be made within 500 feet of such waters. 

Aerial applications of insecticides would not be made within 500 feet of any water 

including canals and ditches. Ground applications of insecticides would not be made 

within 50 feet of any water. 

APHIS would perform on-site examination of proposed spray blocks to determine the 

presence of water. 

Biological control release sites would be considered on an individual basis in consultation 

with the land manager to determine which insecticides might be used and/or how much 

buffer space should be allowed. 

No aerial application or carbaryl or malathion would be made within one mile of 

managed pollinators. 

No aerial spray application would be made within one mile of crops enrolled in the Idaho 

Certified Organic Crop Program except on the request of the organic farm manager. No 

aerial bait application would be made within . mile of crops enrolled in the Idaho 

Certified Organic Crop Program except on the request of the organic farm manager. 

APHIS may decline to apply any treatments which were requested inside this buffer area. 

APHIS would post or continuously patrol treated areas to insure that nobody entered a 

treated area within the timeframe required by EPA for re-entry after treatment. 

23 
ID-PPQ-GH2003-001 

IV. Affected Environment 

A. Description of Affected Environment 

It is not generally possible to predict the precise locations where grasshopper outbreaks 

will occur in any given year. The proposed suppression program area specified in this EA 

includes virtually all areas which might host outbreaks that would require suppression. 

The proposed suppression program area included in this EA encompasses rangeland in 

Idaho south of 45 degrees North latitude and under 7500 feet in elevation with the 

following exceptions: 

Those parts of Adams, Valley and Washington Counties designated by U.S. Fish 

and Wildlife Service (FWS) as habitat occupied by Northern Idaho Ground 

Squirrel, Spermophilus brunneus brunneus. (Northern Idaho ground squirrel is a 

newly listed Threatened Species. There is no similar federally listed threatened 

species for which a biological assessment and biological opinion have been 

completed under the grasshopper suppression program. APHIS believes it is 

prudent to await the outcome of the current biological assessment before 

proposing protection measures for this species.) 

Those rangeland areas in the watersheds which drain into the Salmon River and 

its tributaries. 

Those rangeland areas in the watersheds which drain into the Snake River 

downstream from Brownlee Dam. 

Other areas which are specifically identified in this EA because of their 

association with sensitive species or other sensitive sites. 

The area is bordered by Oregon, Montana, Wyoming, Utah and Nevada. It includes all or 

parts of the counties of Ada, Adams, Bannock, Bear Lake, Bingham, Blaine, Boise, 

Bonneville, Butte, Camas, Canyon, Caribou, Cassia, Clark, Custer, Elmore, Franklin, 

Fremont, Gem, Gooding, Jefferson, Jerome, Lemhi, Lincoln, Madison, Minidoka, 

Oneida, Owyhee, Payette, Power, Teton, Twin Falls, Valley, and Washington. BLM 

administers approximately 10.7 million acres of public lands in the area while FS 

administers approximately 7.5 million acres of public lands. 

The area is traversed by the Snake River and lies within the Interior Columbia Basin. 

The Snake River Plain, which is comprised of basaltic lava flows, dominates much of the 

area Other landforms consist of valleys bordered by north-south running mountain 

ranges. The majority of watersheds within the state drain into the Columbia River. But, 

some watersheds in the southeastern portion of the state drain into Great Salt Lake rather 

than the Snake River. Numerous impoundments on the Snake and its tributaries serve 

multipurpose use. Irrigation systems serve agricultural areas throughout the region. 

Except for the Snake River and its major tributaries, streams in the area are generally 

24 
ID-PPQ-GH2003-001 

intermittent. Subterranean water resources support the nation's largest commercial trout 

aquaculture enterprises in areas along the Snake River. 

Events during the Pleistocene shaped much of Idaho's landscape. In the southern 

portions of Idaho, repeated overflows of historic Lake Bonneville into the Snake River 

modified the Snake River Valley. In addition to the volcanic flows, sedimentary deposits 

including glacial till, outwash and loess, and valley fill, terraces, and scour features are 

present over much of the area. Soils in the Snake River Plains developed from loess 

deposits and this has enabled these areas to become highly productive agricultural areas. 

Intensive livestock production systems such as dairies, feedlots, and the trout farms create 

demand for feed which is partially supplied locally by alfalfa, com, and wheat fields. 

Potatoes, sugar beets, and grain are other primary crops produced within the area. 

Annual cash farm receipts average about $1. 7 billion each from crops and livestock. 

Total receipts from farm marketing in 2001 were $3.8 billion. 

Grassland, shrubland, and woodlands are present across the general area. Grasshopper 

treatments would occur only in grass and shrublands, not in forests. 

The plains and foothills are semi-arid sagebrush steppe. Summers are hot and winters are 

moderate. Average annual temperature is 40 to 55 °F. Total annual precipitation 

averages 5 to 20 inches; almost no rain falls during the summer months. 

The rangelands are utilized for cattle and sheep grazing. They provide habitat for native 

and introduced game and non-game animal species. They are in an accelerated state of 

ecological change due to invasion by exotic plant species, changes in fire patterns, and 

intervention by humans. 

Elevation and topography within the overall area vary considerably, from 2,000 to over 

11,000 feet, and from flat plains to steep mountain ranges. Treatments would occur 

primarily on flatlands and foothills adjacent to cropland. Some treatments may occur on 

blocks of rangeland where critical forage or revegetation projects are threatened. Most 

suppression treatments would occur at elevations below 6000 feet. No treatments would 

occur at elevations over 7500 feet. 

There are a variety of landowners and managers of rangeland within the area. BLM 

manages vast areas of rangelands within the Upper and Lower Snake River Districts. FS 

manages seven National Forests -- Boise, Sawtooth, Caribou, Targhee, Salmon, Challis, 

and Payette. The State of Idaho manages Idaho's state lands. The Shoshone-Bannock 

reservation is at Fort Hall, and the Duck Valley reservation is near Riddle. National Park 

Service manages monuments at Craters of the Moon near Arco, the City of Rocks near 

Burley, and Hagerman Fossil Beds near Hagerman. The Idaho National Engineering and 

Environmental Laboratory (INEEL ), a Department of Energy (DOE) facility is located 

between Idaho Falls and Arco , Snake River Birds of Prey National Conservation Area is 

south of Boise. State Parks include Bruneau Dunes, Cascade, Eagle Island, Lucky Peak, 

Ponderosa, Three Island Crossing, Lake Walcott, Malad Gorge, Niagra Springs, Bear 

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ID-PPQ-GH2003-001 

Lake, Massacre Rocks, Harriman, Henrys Lake, and Land of the Yankee Fork. Private 

parties own rangeland, often adjacent to crop and managed pasture land. 

Additionally, the general area includes many urban and rural communities containing 

private lands. Larger towns or cities include Idaho Falls, Pocatello, Twin Falls, Boise, 

and Nampa. 

Rangelands in Oneida, Cassia, Lincoln, Twin Falls, Gooding, Owyhee, Elmore, Boise 

and Ada counties are most likely to host grasshopper outbreaks in 2003. It is possible 

that up to 75,000 acres of rangeland which borders crops, and up to 25,000 acres of 

higher value rangeland at risk of severe defoliation could be subject to treatment in 2003. 

Up to 100 species of grasshoppers may occur within the proposed suppression area. Of 

these, no more than ten species have been known to reach outbreak status and threaten 

crops and/or valuable range resources in Idaho during the past five decades. The 

widespread grasshopper outbreaks of the mid-1980s were comprised primarily of 

Melanoplus sanguinipes. Localized outbreaks in the late 1990s and early 2000s have 

included Camnula pellucida, Aulocara elliotti, and Oedaleonotus enigma. 

Mormon cricket, Anabrus simplex, is a special case. A large outbreak of Mormon 

crickets has been building for several years in the Boise foothills, the Danskin Mountain 

area and the Bennett Hills in Ada, Boise and Elmore Counties. Another outbreak seems 

probable in Oneida County near Malad. Bands of immature Mormon crickets will travel 

long distances across rangeland and can do extensive damage when they encounter crops. 

It is anticipated that treatments in 2003 would be for Melanoplus sanguinipes, M 

packardii, M bivittatus, Camnula pellucida, Aulocara el/iotti, Oedaleonotus enigma and 

Anabrus simplex. It is not anticipated that outbreaks of other species would occur. 

Further, if outbreaks of other species do occur they would probably not warrant 

suppression because of their dietary preferences. 

B. Site-Specific Considerations 

1. Human Health 

The suppression program would be conducted on rangelands that are not normally 

inhabited by humans. Human habitation may occur on the edges of the rangeland. Most 

habitation is comprised of farm or ranch houses, but some rangeland areas may have 

suburban developments or "ranchettes" nearby. Average population density in rural areas 

of Idaho is 6.3 persons per square mile. Recreationists may use the rangelands for hiking, 

camping, bird watching, hunting, falconry or other uses. 

Individuals with allergic or hypersensitive reactions to insecticides may live near or may 

utilize rangelands in the proposed suppression program area. 

Entomophobic individuals may live near or may utilize rangelands in the proposed 

suppression area. 

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ID-PPQ-GH2003-001 

Some rural schools may be located in areas near rangeland which could be subject to 

treatment. 

2. Nontarget Species 

Nontarget species within the suppression program area include terrestrial vertebrate and 

invertebrate animals (including grasshopper species which are not threatening valuable 

resources), aquatic organisms, and terrestrial plants (both native and introduced). 

Invertebrate organisms of special interest include biocontrol agents and pollinators. Land 

managers and others have released and managed biocontrol agents including insects and 

pathogens on many species of invasive plants within and near the suppression program 

area. These biocontrol agents are important in decreasing the overall population or the 

rate of reproduction of some species of undesirable rangeland plants, especially exotic 

invasive weeds. 

Pollinators including insects and other organisms occur within and near the suppression 

program area. Pollinators include managed exotic and native insect species such as 

honey bees, leafcutter bees, and alkali bees which are commercially valuable for 

agriculture. Other species of insects and other animals pollinate native and exotic plants 

and are necessary for the survival of some species. 

Vertebrates include highly visible introduced and native mammalian species such as 

cattle, sheep, horses, mule deer, elk, pronghorn, coyotes and wolves as well as smaller 

animals like rabbits, mice, gophers and bats. Birds comprise a large portion of the 

vertebrate species complex, and they also include exotic and native species. Some exotic 

game birds, like pheasant and partridge, have been deliberately introduced into the area, 

and other species such as starlings and pigeons have spread from other loci of 

introduction. Sage obligate bird species, typified by sage grouse, are present in much of 

the area. Various reptiles and amphibians are also present. Many of the herbivorous 

vertebrate species compete with some species of grasshoppers for forage. Many of the 

vertebrate species utilize grasshoppers and other insects as a food source. There is 

special concern about the role of grasshoppers as a food source for sage grouse, sharptail 

grouse, and other bird species. 

The proposed suppression area contains a vast variety of terrestrial invertebrates, 

primarily insects and other arthropods. They include species which compete with 

grasshoppers and some which prey on grasshoppers. In turn, some species of 

grasshoppers may prey opportunistically on other invertebrates. 

Aquatic organisms within the suppression area include plants and vertebrate and 

invertebrate animals. Some species of fish utilize grasshoppers as a significant food 

source during some parts of the year. 

A diverse complement of terrestrial plants occurs within the proposed suppression area 

Many such as rush skeletonweed, purple loosestrife, spotted and diffuse knapweed, 

downey brome, and leafy spurge are considered as invasive weeds. Native plants such as 

27 
ID-PPQ-GH2003-001 

sagebrushes, bitterbrush, and various grasses provide forage and shelter for animal 

species and help stabilize the soil against erosion. 

Biological soil crusts, also known as cryptogamic, microbiotic, cryptobiotic, and 

microphytic crusts, occur within the proposed suppression area. Biological soil crusts are 

formed by living organisms and their by-products, creating a crust of soil particles bound 

together by organic materials. Crusts are predominantly composed of cyanobacteria 

(formerly blue-green algae), green and brown algae, mosses, and lichens. Liverworts, 

fungi, and bacteria can also be important components. Crusts contribute to a number of 

functions in the environment. Because they are concentrated in the top 1 to 4 mm of soil, 

they primarily effect processes that occur at the land surface or soil-air interface. These 

include soil stability and erosion, atmospheric N-fixation, nutrient contributions to plants, 

soil-plant-water relations, infiltration, seedling germination, and plant growth. 

Federally listed threatened and endangered species in the proposed suppression area 

include Grizzly bear, gray wolf, Canada lynx, bald eagle, Banbury Springs limpet, Bliss 

Rapids snail, Snake River physa, Utah valvata snail, Bruneau hot springsnail, Idaho 

springsnail, bull trout, Chinook salmon, steelhead trout, sockeye salmon, and Ute ladies' 

tresses. Slickspot peppergrass is proposed for federal endangered species status. 

Discussion of these species is included in V.B.4 

Many other species are accorded special status by federal land managers or by the State 

of Idaho. Data about these species are available from the respective land managers or at 

http://www2.state.id. us//fishgame/info/cdc/cdc.htm. 

3. Socioeconomic Issues 

Local economies in the areas near most proposed suppression areas are driven primarily 

by agricultural production, processing, and marketing concerns. Major employers in 

Idaho include Albertsons, Inc.; Bechtel BWXT Idaho, LLC; Central Partners, Inc.; Fred 

Meyer, Inc.; Hewlett-Packard Co.; Idaho Power Co.; J.R. Simplot Co.; Micron 

Technology, Inc.; Potlach Corp; St. Alphonsus Regional Medical Center; St. Luke's 

Regional Medical Center; and Wal-Mart. These businesses roughly divide into those 

which have headquarters, factories or service centers located in the Boise metropolitan 

area and those which support agricultural and natural resource enterprises or provide 

retail trade in the rural areas. 

Livestock enterprises include rangeland grazing by cattle and sheep, feedlots for beef, 

and concentrated dairy operations. Local processing which adds value to livestock 

production systems includes meat packing houses, and cheese plants. 

Crop growers in areas adjacent to proposed suppression areas grow feed for the dairies 

and feedlots. This includes alfalfa and com. They also grow potatoes, sugarbeets, wheat, 

barley, sweet com, beans, and a variety of other crops. Potato and sugarbeet processing 

plants add value in several of the rural communities. In some areas adjacent to the 

proposed suppression area, growers produce seed of various vegetable crops. The seed 

crops are often of exceptionally high value per acre compared to crops for consumption. 

28 
ID-PPQ-GH2003-001 

Acreage in organic production has increased in the area near proposed suppression areas. 

There were 106,058 acres registered in organic production in Idaho in 2001. This 

includes feed for organic dairies and various other organic crops. Individuals have been 

identified who produce and market organic beef on rangeland which would be within the 

proposed suppression areas. 

Beekeepers maintain hives to produce honey and other bee products on land which is 

included in the proposed treatment area as well as on land located near the proposed 

treatment area. Seed crops and fruit crops rely on pollination from bees which may live 

or forage on or near proposed suppression areas. 

The general public uses rangelands in the proposed suppression area for a variety of 

recreational purposes including hiking; camping; wildlife, bird, and insect collecting and 

watching; hunting; falconry; shooting; plant collecting; rock and fossil collecting; artifact 

collecting; sightseeing; and dumping. Members of the general public traverse rangelands 

in or near the proposed suppression area on foot, horseback and other beasts of burden, 

all terrain vehicles, bicycles, motorcycles, four-wheel drive vehicles, snowmobiles, 

aircraft, and balloons. 

Artificial surfaces in or near the proposed suppression area include the walls and roofs of 

buildings, painted finishes on automobiles, trailers, recreational vehicles, and road signs. 

See 2002 EIS pp 71-72. 

Esthetic values of the natural environment in the suppression area include the views, 

vistas, diversity of the biota, and the opportunity to commune with nature in isolated 

settings. Many stakeholders have expressed extremely strong opinions regarding the 

esthetics of the natural environment 

4. Cultural Resources and Events 

Cultural and historical sites include locations and artifacts associated with Native 

Americans, explorers, pioneers, religious groups and developers. The Fort Hall and Duck 

Valley Indian Reservations occupy lands within the proposed suppression area. Native 

American petroglyphs have been discovered in several areas within the proposed 

suppression area. Artifacts from knapping occur within the proposed suppression area. 

Elements of the Oregon and California Trails transect portions of the proposed 

suppression area, and monuments have been erected in several places. Museums, 

displays and structures associated with mining, logging, Japanese internment camps, and 

irrigation development exist in areas near the proposed suppression area. 

5. Special Considerations for Certain Populations 

a. Executive Order No. 12898, Federal Actions to Address Environmental 

Justice in Minority Populations and Low-Income Populations 

Executive Order (E.O.) 12898, Federal Actions To Address Environmental Justice in 

Minority Populations and Low-Income Populations, was signed by President Clinton on 

February 11, 1994 (59 Federal Register (FR) 7269). This E.O. requires each Federal 

29 
ID-PPQ-GH2003-001 

agency 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. Consistent with this E.O., APHIS will consider the potential for 

disproportionately high and adverse human health or environmental effects on minority 

populations and low-income populations for any of its actions related to grasshopper 

suppression programs. 

Population makeup in Idaho (U.S. Census Bureau 2000) is 90.9% White. Hispanic or 

Latino of any race is the next most numerous group comprising 7 .8 %. Other identifiable 

groups include Black or African American 0.4%, American Indian and Alaska Native 1.4 

%, Asian 1.0%, and Native Hawaiian and Other Pacific Islander 0.1 %. The proposed 

suppression area is relatively reflective of the overall state population breakdown. Of the 

minority groups, Hispanic and Asian appear to be the groups with most involvement in 

agriculture. Hispanic workers are often engaged in production and processing of crops. 

Sheepherding is a profession which currently engages persons of Peruvian nationality or 

descent. Persons of Asian descent are frequently involved in crop production and 

processing. 

Figures for Idaho put 8.3% of the families and 11.8% of the individuals in the state 

below the poverty level in 1999. Median family income was $43,490 and per capita 

income was $17,841 in 1999. The proposed suppression area is relatively reflective of 

the overall state income breakdown. 

b. Executive Order No. 13045, Protection of Children from Environmental 

Health Risks and Safety Risks 

The increased scientific knowledge about the environmental health risks and safety risks 

associated with hazardous substance exposures to children and recognition of these issues 

in Congress and Federal agencies brought about legislation and other requirements to 

protect the health and safety of children. On April 21, 1997, President Clinton signed 

E.O. 13045, Protection of Children From Environmental Health Risks and Safety Risks 

(62 FR 19885). This E.O. requires each Federal agency, consistent with its mission, to 

identify and assess environmental health risks and safety risks that may 

disproportionately affect children and to ensure that its policies, programs, activities, and 

standards address disproportionate risks to children that result from environmental health 

risks or safety risks. APHIS has developed agency guidance for its programs to follow to 

ensure the protection of children (USDA, APHIS, 1999). 

Individuals under 18 years of age comprise 30.6% of the population in Idaho. Counties 

within the area under consideration range from 26.6% to 40.4% population under 18 

years of age. There is no reason to believe that the population age structures within and 

nearby the proposed treatment areas are different than the surrounding area. 

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ID-PPQ-GH2003-001 

V. Environmental Consequences 

Each alternative described in this EA potentially has adverse environmental effects. The 

general environmental impacts of each alternative are discussed in detail in the 2002 EIS. 

The specific impacts of the alternatives are highly dependent upon the particular action 

and location of infestation. The principal concerns associated with the alternatives that 

include insecticide application are: (1) the potential effects of the three pesticide options 

on human health (including subpopulations that might be at increased risk); and (2) 

impacts of pesticides on nontarget organisms (including threatened and endangered 

species). 

Risk analysis for human health is discussed in the 2002 EIS pp B-1 to B-6. Nontarget 

species risk analysis is discussed in the 2002 EIS pp B-6 to B-10. 

A. Environmental Consequences of the Alternatives 

Site-specific environmental consequences of the alternatives are discussed in this section. 

1. No Action Alternative 

Under this alternative, APHIS would not fund or participate in any program to suppress 

grasshoppers. If APHIS does not participate in any grasshopper suppression program, 

Federal land management agencies, State agriculture departments, local governments, or 

private groups or individuals, may not effectively control outbreaks in a coordinated 

effort. In these situations, grasshopper outbreaks could develop and spread unimpeded. 

See 2002 EIS pp. 29-30 for general consequences. 

Human health 

Very dense bands of Mormon crickets and some other grasshopper species can make 

roadways slick. It is not known whether any traffic accidents have been directly 

attributable to this phenomenon in Idaho, but public safety authorities posted warning 

signs because of Mormon crickets on Highway 55 between Eagle and Horseshoe Bend 

during a Mormon cricket outbreak in 2002. Mormon crickets also created slick road 

conditions on Interstate 84 at milepost 71 in 2002. Camnula pellucida created slick road 

conditions in Highway 55 on the south end of Cascade in 2001. There is some risk of 

personal injury or death due to automobile accidents caused by grasshoppers on highways 

and roads. 

A significant portion of the American public has a negative response to insects and some 

persons may be clinically diagnosed as Entomophobic. Mormon crickets are especially 

vexatious. Residents of residential developments which border rangeland in the Boise 

foothills have expressed, in complaints, to APHIS strong negative psychological 

reactions to Mormon cricket infestations in 2002. The general state of public anxiety 

regarding threats of war, international terrorism, and state budgetary problems, may set 

the stage for extreme emotional reactions. 

31 
ID-PPQ-G H2003-001 

Many stakeholders have indicated that they are opposed to any treatments on public 

rangelands because they believe treatments would disrupt ecosystems. The anxiety levels 

of these stakeholders may be reduced if AP HIS does not suppress grasshopper outbreaks. 

If APHIS does not treat grasshopper outbreaks on rangeland, there is an increased 

probability of additional insecticidal treatments on crops which would be invaded by 

grasshoppers. This would result in increased exposure of farm workers to insecticides. 

Non-target species 

An abundant supply of grasshoppers and other insects would be available as a food 

source for insectivorous animals. This includes birds and other animals which have been 

accorded sensitive species status by land managers and others. 

Grasshoppers in unsuppressed outbreaks would consume agricultural and nonagricultural 

plants. The damage caused by grasshopper outbreaks could also pose a risk to rare, 

threatened, or endangered plants that often have a low number of individuals and limited 

distribution. Plants can be killed or weakened by grasshopper feeding. Some 

grasshoppers feed on seeds, so future generations of plants could be threatened. 

Loss of plant cover would occur due to consumption by grasshoppers. Nesting and cover 

habitat may be degraded for birds and other wildlife. The herbaceous understory is 

important to nesting success by sage grouse (Connelly, et. al. 1994). 

Rangeland which has been overgrazed by grasshoppers is more susceptible to invasion by 

nonnative plant species. Plant cover may protect the soil from the drying effects of the 

sun. The plant root systems which hold the soil in place may be weakened, leading to 

increased rates of erosion. 

Mormon crickets are fairly omnivorous creatures. In Idaho, they not only feed on live 

plants, but they commonly feed on cow manure and the bodies of recently killed animals 

including snakes, toads and birds. These insects are well known to be cannibalistic and to 

feed on other insects. Apparently, they may pose a risk to fledgling birds, as well. La 

Rivers (1944) reported a nest of half-grown Brewers sparrows devoured by a swarm of 

crickets in Nevada during July. 

If APHIS does not participate in any grasshopper suppression programs, local 

governments, or private groups or individuals may attempt to conduct widespread 

grasshopper programs. Without the technical assistance and program coordination that 

APHIS can provide to grasshopper programs, it is possible that a large amount of 

insecticides, including those APHIS considers too environmentally harsh, could be 

applied, reapplied, and perhaps misapplied in an effort to suppress or even locally 

eradicate grasshopper populations. It is not possible to accurately predict the 

environmental consequences of the No Action alternative because the type and amount of 

insecticides that could be used in this scenario are unknown. However, APHIS is aware 

that in 2002 private parties applied furadan, asana, malathion, atrapa, carbaryl, and 

dimethoate for grasshopper control in Idaho. 

32 
ID-PPQ-GH2003-001 

Rangeland fires may be set by persons who desire suppression of the grasshoppers. 

Action of this type has not been documented, but individuals have threatened to set fires 

to destroy grasshopper outbreaks that are not controlled. 

Socioeconomic issues 

There is risk that grasshopper outbreaks on rangeland would decrease the availability of 

forage for cattle and sheep. If sheep and cattle grazing become unprofitable, there may 

be disproportionate impact on the sheepherding and cattle raising professions. 

Unchecked movement of grasshopper outbreaks into crops would result in crop loss and 

additional expenditures for insecticidal control in the crop fields. 

Organic farmers may suffer significant losses if grasshopper outbreaks are not controlled 

on rangeland and emigrate to organic cropland. Some organic farmers were forced to 

abandon their organic farming enterprise in Camas County in 2000 due to invasion of 

grasshoppers from rangeland into organic alfalfa fields. 

Stakeholders have suggested that the federal government should compensate farmers for 

losses incurred when grasshoppers emigrate from public rangeland into crops. USDA 

Risk Management Agency currently offers multiperil crop insurance which may 

compensate for losses due to insects if the policy holder utilizes appropriate pest control 

measures, but those measures fail. Normally, payment of such claims is on the basis of 

failure of pest control spray practices due to untimely rainfall or some other natural event. 

USDA Farm Service Agency may be able to offer low interest loans when disasters are 

declared for various reasons which can include grasshopper outbreaks. Skold and Davis 

(1995) proposed a rangeland grasshopper insurance program. No authority currently 

exists for such a program. 

Cultural resources and events 

Grasshoppers were a significant source of protein for indigenous North American people. 

They are no longer used as a human food source except as a novelty or recreational 

experience. They are used for fish bait, and selection of the No Action alternative would 

result in their abundant availability for these purposes. 

Grasshopper populations at outbreak levels on rangeland would decrease the recreational 

satisfaction of some people utilizing rangeland resources, primarily those who do not like 

insects. Grasshopper populations at outbreak levels on rangeland would increase the 

recreational satisfaction of some people utilizing rangeland resources, primarily those 

who enjoy spectacular biological phenomena. 

Artificial Surfaces 

Grasshoppers have been reported as recently as 2002 (in Nebraska) to eat the paint off 

houses. There is a possibility that artificial surfaces might suffer some damage due to 

chewing by grasshoppers. 

33 
ID-PPQ-GH2003-001 

2. Insecticide Applications at Conventional Rates and Complete Area 

Coverage Alternative 

Under this alternative, APHIS would suppress grasshopper outbreaks when there is 

potential for the outbreak causing economic loss or environmental degradation. 

Insecticides would be applied at or below EPA approved rates as specified in 11.B. See 

2002 EIS pp. 38-48 for general consequences. 

Carbary I 

Carbary I is of moderate acute oral toxicity to humans. The mode of toxic action of 

carbaryl occurs through inhibition of acetylcholinesterase (AChE) function in the nervous 

system. This inhibition is reversible over time if exposure to carbaryl ceases. The 

Environmental Protection Agency (EPA) has classified carbaryl as a possible human 

carcinogen EPA, 1993). However, it is not considered to pose any mutagenic or 

genotoxic risk. 

Potential exposures to the general public from conventional application rates are 

infrequent and of low magnitude. These low exposures to the public pose no risk of 

direct toxicity, carcinogenicity, neurotoxicity, genotoxicity, reproductive toxicity, or 

developmental toxicity. The potential for adverse effects to workers are negligible if 

proper safety procedures are followed, including wearing the required protective clothing. 

Carbary! has been used routinely in other programs with no reports of adverse health 

effects. Therefore, routine safety precautions are expected to provide adequate worker 

health protection. 

Carbaryl is of moderate acute oral toxicity to mammals (McEwen et al., 1996a). 

Carbaryl applied at Conventional rates is unlikely to be directly toxic to upland birds, 

mammals, or reptiles. Field studies have shown that carbaryl applied as either ultra-lowvolume (UL V) spray or bait at Conventional rates posed little risk to killdeer (McEwen et 

al., 1996a), vesper sparrows (McEwen et al., 1996a; Adam et al., 1994), or golden eagles 

(McEwen et al., l 996b) in the treatment areas. AChE inhibition at 40 to 60 percent can 

affect coordination, behavior, and foraging ability in vertebrates. Multi-year studies 

conducted at several grasshopper treatment areas have shown AChE inhibition at levels 

of no more that 40 percent with most at less than 20 percent (McEwen et al., 1996a). 

Carbary! is not subject to significant bioaccumulation due to its low water solubility and 

low octanol-water partition coefficient (Dobroski et al., 1985). 

Carbary! will most likely affect nontarget insects that are exposed to UL V carbaryl spray 

or that consume carbaryl bait within the grasshopper treatment area. Field studies have 

shown that affected insect populations can recover rapidly and generally have suffered no 

long-term effects, including some insects that are particularly sensitive to carbaryl, such 

as bees (Catangui et al., 1996). The use of carbaryl in bait form generally has 

considerable environmental advantages over liquid insecticide applications: bait is easier 

than liquid spray applications to direct toward the target area, bait is more specific to 

grasshoppers, and bait affects fewer nontarget organisms than sprays (Quinn, 1996). 

34 
ID-PPQ-G H2003-001 

Should carbaryl enter water, there is the potential to affect the aquatic invertebrate 

assemblage, especially amphipods. Field studies with carbaryl concluded that there was 

no biologically significant effect on aquatic resources, although invertebrate downstream 

drift increased for a short period after treatment due to toxic effects (Beyers et al., 1995). 

Carbary} is moderately toxic to most fish (Mayer and Ellersieck, 1986). 

Diflubenzuron 

The acute oral toxicity of diflubenzuron formulations to humans ranges from very slight 

to slight. The most sensitive indicator of exposure and effects of diflubenzuron in 

humans is the formation of methemoglobin (a compound in blood responsible for the 

transport of oxygen) in blood. 

Potential exposures to the general public from Conventional rates are infrequent and of 

low magnitude. These low exposures to the public pose no risk of methemoglobinemia 

(a condition where the heme iron in blood is chemically oxidized and lacks the ability to 

properly transport oxygen), direct toxicity, neurotoxicity, genotoxicity, reproductive 

toxicity, or developmental toxicity. Potential worker exposures are higher than the 

general public but are not expected to pose any risk of adverse health effects. 

Because diflubenzuron is a chitin inhibitor that disrupts insects from forming their 

exoskeleton, organisms without a chitinous exoskeleton, such as mammals, fish, and 

plants are largely unaffected by diflubenzuron. In addition, adult insects, including wild 

and cultivated bees, would be mostly unaffected by diflubenzuron applications 

(Schroeder et al., 1980; Emmett and Archer, 1980). Among birds, nestling growth rates, 

behavior data, and survival of wild American kestrels in diflubenzuron treated areas 

showed no significant differences among kestrels in treated areas and untreated areas 

(McEwen et al., l 996b ). The acute oral toxicity of diflubenzuron to mammals ranges 

from very slight to slight. Little, if any, bioaccumulation of diflubenzuron would be 

expected (Opdycke et al., 1982). 

Diflubenzuron is most likely to affect immature terrestrial insects and early life stages of 

aquatic invertebrates (Eisler, 2000). While this would reduce the prey base within the 

treatment area for organisms that feed on insects, adult insects, including grasshoppers, 

would remain available as prey items. Many of the aquatic organisms most susceptible to 

diflubenzuron are marine organisms that would not be exposed to rangeland treatments. 

Freshwater invertebrate populations would be reduced if exposed to diflubenzuron, but 

these decreases would be expected to be temporary given the rapid regeneration time of 

many aquatic invertebrates. 

Malathion 

Malathion is of slight acute oral toxicity to humans. The mode of toxic action of 

malathion occurs through inhibition of AChE function in the nervous system. Unlike 

carbaryl, AChE inhibition from malathion is not readily reversible over time if exposure 

ceases. However, strong inhibition of AChE from malathion occurs only when chemical 

oxidation results in formation of the metabolite malaoxon. Human metabolism of 

malathion favors hydroxylation and seldom produces much malaoxon. 

35 
ID-PPQ-G H2003-001 

Potential exposures to the general public from conventional application rates are 

infrequent and of low magnitude. These low exposures to the public pose no risk of 

direct toxicity, neurotoxicity, genotoxicity, reproductive toxicity, or developmental 

toxicity. Potential worker exposures are higher, but still have little potential for adverse 

health effects except under accidental scenarios. Therefore, routine safety precautions 

are expected to continue to provide adequate protection of worker health. 

EPA has recently reviewed the potential for carcinogenic effects from malathion. EPA s 

classification describes malathion as having suggestive evidence of carcinogenicity, but 

not sufficient to assess human carcinogenic potential (EP A, 2000). This indicates that 

any carcinogenic potential of malathion cannot be quantified based upon EPA s weight of 

evidence determination in this classification. The low exposures to malathion from 

program applications would not be expected to pose carcinogenic risks to workers or the 

general public. 

Malathion is of slight acute oral toxicity to mammals. There is little possibility of 

toxicity-induced mortality of upland birds, mammals, or reptiles, and no direct toxic 

effec.ts have been observed in field studies. Malathion is not directly toxic to vertebrates 

at the concentrations used for grasshopper suppression, but it may be possible that 

sublethal effects to nervous system functions caused by AChE inhibition may lead 

directly to decreased survival. AChE inhibition at 40 to 60 percent affects coordination, 

behavior, and foraging ability in vertebrates. Multi-year studies at several grasshopper 

treatment areas have shown AChE inhibition at levels of no more than 40 percent with 

most at less than 20 percent (McEwen et al., 1996a). Field studies of birds within 

malathion treatment areas showed that, in general, the total number of birds and bird 

reproduction were not different from untreated areas (McEwen et a/.,. I 996a). Malathion 

does not bioaccumulate HSDB, 1990; Tsuda et al., 1989). 

Malathion will most likely affect nontarget insects within a treatment area. Large 

reductions in some insect populations would be expected after a malathion treatment 

under the conventional rates alternative. While the number of insects would be 

diminished, there would be some insects remaining. The remaining insects would be 

available prey items for insectivorous organisms, and those insects with short generation 

times may soon increase. 

Malathion is highly toxic to some fish and aquatic invertebrates; however, malathion 

concentrations in water, as a result of grasshopper treatments, are expected to be low 

presenting a low risk to aquatic organisms, especially those organisms with short 

generation times. 

The implementation of pesticide label instructions and restrictions and the APHIS 

treatment guidelines will reduce potential impacts from the program use of insecticides 

(see Appendix 1 treatment guidelines). 

36 
ID-PPQ-GH2003-001 

Human health 

Human exposure to insecticides would occur. Exposures and effects are discussed in the 

2002 EIS pp. 39-40, 43, and 46-47. Personnel working on the suppression program 

would be exposed during handling, loading and application of the insecticides. Potential 

exposure of the general public would be infrequent and of low magnitude. 

Implementation of the Treatment Guidelines (Appendix 1.) would minimize public 

exposure and protect workers from harmful exposure. Individuals with hypersensitivity 

to the insecticides, carriers, and adjuvants might be affected. APHIS would seek lists of 

hypersensitive individuals from state and county health departments and would contact 

persons who reside near proposed treatment blocks prior to treatment. Hypersensitive 

individuals would be advised to avoid treatment blocks and the areas surrounding them. 

Many stakeholders have indicated that they are opposed to any treatments on public 

rangelands because they believe treatments would disrupt ecosystems. The anxiety levels 

of these stakeholders may be increased. 

Pesticide spills could expose individuals to excessive levels of insecticide. APHIS 

maintains spill kits and insures that program personnel are familiar with procedures to 

mitigate effects associated with a spill. 

Non-target species 

Grasshopper feeding damage would be reduced to rangeland plants, including desirable 

and undesirable plants, and to crops adjacent to rangeland. Population densities of some 

nontarget insects and other arthropods would be reduced. Food sources for some 

insectivorous animal species would be reduced. Nontarget plant and animal species 

would be exposed to insecticides. 

Reduction of the grasshopper feeding damage may be viewed as having both negative 

and positive impacts. Various grasshopper species feed on invasive weeds such as rush 

skeletonweed. Limiting the damage grasshoppers do to invasive weeds would be seen by 

most observers as a negative impact. Limiting the damage grasshoppers do to desirable 

plants would be seen by most observers as a positive impact. Decreasing the amount of 

foliage consumed by grasshoppers can make more forage available to other herbivores 

which may be more highly valued by stakeholders. 

Nontarget insect species which would be put at risk by treatments under this alternative 

include non-native biological control agents and pollinators. The majority of the nonnative biological control agents in the proposed suppression area result from release 

programs carried out by land management agencies and others. The Nez Perce 

Biological Control Center in Lapwai provides database service which allows managers to 

report locations of biocontrol releases and the status ofbiocontrol agent populations. 

APHIS would consult with land managers and the Nez Perce Biological Control Center 

to determine the location and status of biological control agent populations and would 

select treatment options (including buffering areas) which minimize negative impacts on 

the populations. 

37 

ID-PPQ-GH2003-001 

The most widespread, managed, non-native pollinator in the proposed suppression area is 

the honeybee. Honeybees are found throughout and near the proposed suppression area. 

Malathion and carbaryl sprays are very toxic to honeybees. APHIS would provide 

beekeepers with notification of the suppression program and would conduct surveys to 

detect beeyards in or near proposed spray blocks. APHIS would not utilize carbaryl or 

malathion sprays within 1 mile of active beeyards. 

Managed native pollinators include leafcutter and alkali bees. These species may be 

found in the proposed treatment area, but are usually encountered in crop areas adjacent 

to the rangeland. APHIS would conduct surveys and would consult with private 

landowners to determine if managed native pollinators are in or near proposed treatment 

blocks. APHIS would not utilize carbaryl or malathion spray within l mile of managed 

native pollinators. 

Unmanaged native pollinators include a vast array of insects and other animals. In 

general, the insect fauna within this group is more susceptible to malathion and carbaryl 

sprays than to the other treatment options. To maximize the protection of these 

organisms, APHIS would select diflubenzuron spray or carbaryl bait whenever they 

would be efficacious to control grasshopper outbreaks. 

Many stakeholders have expressed concern regarding the reduction of insects as a food 

source for rangeland insectivores, especially sage grouse and sharptail grouse chicks. In 

this alternative, the application rates chosen for the broader spectrum insecticides are 

reduced from the maximum rate allowed by EPA. This reduction in rates along with the 

use of the insecticides (diflubenzuron and carbaryl bait) which are more selective for 

grasshoppers than for most other species leaves alternative insect fauna for foraging 

insectivores (Paige and Ritter 1999). Because APHIS would only treat significant 

outbreak populations, numbers of grasshoppers surviving the treatment can provide 

ample nourishment for the insectivores. Additionally, Martin et. al. (2000) and Howe, et. 

al. (2000) found that Canadian grassland and Idaho shrub steppe bird species were able to 

make adaptive changes when insecticidal spray reduced the numbers and changed the 

composition of insect prey species. 

There would be a temporary decrease in insect biodiversity within treatment blocks. 

Malathion and carbaryl sprays would decrease the biodiversity more than diflubenzuron 

spray and carbaryl bait treatments. 

Stakeholders have expressed concern about chronic and acute toxicity of insecticides to 

birds on rangeland. These concerns were well founded for grasshopper control programs 

conducted throughout much of the 20th Century. Originally, inorganic insecticides were 

used, with a typical bran bait formulation incorporating 8 pounds of liquid sodium 

arsenite into 100 pounds of bran (Cowan 1929). For a brief span in the mid-20th century, 

synthetic organochlorine insecticides such as chlordane, toxaphene, dieldrin and aldrin 

came into use. These insecticides would accumulate in the birds or other animals which 

consumed poisoned grasshoppers, eventually leading to a toxic dosage level in the 

insectivores or their predators. USDA discontinued their recommendation for using 

38 
ID-PPQ-GH2003-001 

organochlorine insecticides on grasshoppers in 1965 (McEwen, et. al. 1972). The 

organochlorine insecticides were replaced with the organophosphate and carbamate 

insecticides. Certain of these are highly toxic to birds. Blus et. al. (1989) determined that 

sage grouse die-offs in Southeastern Idaho could be attributed to methamidophos and 

dimethoate treatments to agricultural fields used by the sage grouse. Martin et. al. (2000) 

determined that furadan treatments depressed cholinesterase levels in birds in study areas. 

APHIS will not use insecticides (such as methamidophos, dimethoate, or furadan) that are 

highly toxic to birds or other terrestrial wildlife in the proposed suppression area. 

Pesticide spills could expose wildlife to excessive levels of insecticide. APHIS maintains 

spill kits and insures that program ·personnel are familiar with procedures to mitigate 

effects associated with a spill. 

Negative impacts to nontarget organisms would be minimized by the implementation of 

the Treatment Guidelines, Appendix 1. 

Socioeconomic issues 

There is a reduced risk that grasshopper outbreaks on rangeland would decrease the 

availability of forage for cattle and sheep. 

There is reduced risk of unchecked movement of grasshopper outbreaks into crops 

resulting in crop loss and additional expenditures for insecticidal control in the crop 

fields. 

Organic farmers face less risk of significant losses from grasshopper outbreaks on 

rangeland which could emigrate to organic cropland. Organic farmers would be put at 

increased risk of contamination from spray drift originating from grasshopper 

suppression programs. APHIS would consult with ISDA and procure a listing of certified 

organic growers. APHIS would utilize 1 mile aerial spray buffers and . mile aerial bait 

buffers to avoid organic farm operations. APHIS would consult with any residents in the 

immediate vicinity of treatment blocks so that organic garden locations can be avoided. 

Negative socioeconomic impacts would be minimized by the implementation of the 

Treatment Guidelines, Appendix 1. 

Cultural resources and events 

The availability of grasshoppers for fish bait and other human uses would be reduced 

from outbreak levels to more normal levels. Persons using rangelands for recreation 

would respond to grasshoppers as they do under normal conditions versus under outbreak 

conditions. 

Artificial surfaces 

Malathion and carbaryl spray can damage some painted surfaces. Automotive and sign 

finishes are susceptible to damage by malathion and carbaryl spray, and automobile or 

sign owners could suffer economic loss repairing cosmetic damage. APHIS would not 

spray un-abandoned vehicles in malathion or carbaryl spray blocks. APHIS would 

39 
ID-PPQ-G H2003-001 

consult with land managers if malathion or carbaryl spray was going to be used so they 

could elect to cover or remove signs during treatment. APHIS would consult with land 

managers to insure that Native American petroglyphs are excluded from spray blocks. 

3. Reduced Area Agent Treatments (RAATs) Alternative 

Under this alternative APHIS would suppress grasshopper outbreaks when there is 

potential for the outbreak to cause economic loss or environmental degradation. 

Insecticides would be applied at or below EPA approved rates as specified in II.C. See 

2002 EIS pp. 49-57 for general consequences. 

Carbaryl 

Potential exposures to the general public and workers from RAA Ts application rates are 

lower than those from conventional application rates, and adverse effects decrease 

commensurately with decreased magnitude of exposure. These low exposures to the 

public pose no risk of direct toxicity, carcinogenicity, neurotoxicity, genotoxicity, 

reproductive toxicity, or developmental toxicity. The potential for adverse effects to 

workers is negligible if proper safety procedures are followed, including wearing the 

required protective clothing. Routine safety precautions are expected to provide adequate 

protection of worker health at the lower application rates under RAATs. 

Carbary! will most likely affect nontarget insects that are exposed to liquid carbaryl or 

that consume carbaryl bait. While carbaryl applied at a RAATs rate will reduce 

susceptible insect populations, the decrease will be less than under Conventional rates. 

Carbary! UL V applications applied in alternate swaths have been shown to affect 

terrestrial arthropods less than malathion applied in a similar fashion (EIS p. 56) 

Direct toxicity of carbaryl to birds, mammals, and reptiles is unlikely in swaths treated 

with carbaryl under a RAA Ts approach. Carbary I bait also has minimal potential for 

direct effects on birds and mammals. Field studies indicated that bee populations did not 

decline after carbaryl bait treatments, and American kestrels were unaffected by bait 

applications made at a RAA Ts rate. Using alternating swaths will furthermore reduce 

adverse effects because organisms that are in untreated swaths will be mostly unexposed 

to carbary 1. 

Carbary! applied at a RAATs rate has the potential to affect invertebrates in aquatic 

ecosystems. However, these affects would be less than effects expected under the 

conventional rates alternative. Fish are not likely to be affected at any concentrations that 

could be expected under The RAATS Alternative. 

Diflubenzuron 

Potential exposures and adverse effects to the general public and workers from RAATs 

application rates are commensurately less than conventional application rates. These low 

exposures to the public pose no risk of methemoglobinemia, direct toxicity, 

neurotoxicity, genotoxicity, reproductive toxicity, or developmental toxicity. Potential 

worker exposures pose negligible risk of adverse health effects. 

40 
ID-PPQ-GH2003-001 

Because diflubenzuron is a chitin inhibitor that disrupts insects from forming their 

exoskeleton, organisms without a chitinous exoskeleton, such as mammals, fish, and 

plants are largely unaffected by diflubenzuron. Diflubenzuron exposures at The RAA TS 

Alternative rates are not hazardous to terrestrial mammals, birds, and other vertebrates. 

Insects in untreated swaths would have little to no exposure, and adult insects in the 

treated swaths are not susceptible to diflubenzuron s mode of action. The indirect effects 

to insectivores would be negligible as not all insects in the treatment area will be affected 

by diflubenzuron. 

Diflubenzuron is most likely to affect immature terrestrial insects and, if it enters water, 

will ·affect early life stages of aquatic invertebrates. While diflubenzuron would reduce 

insects within the treatment area, insects in untreated swaths would have little to no 

exposure. Many of the aquatic organisms most susceptible to diflubenzuron are marine 

organisms that would not be exposed to rangeland treatments. Freshwater invertebrate 

populations would be reduced if exposed to diflubenzuron, but these decreases may be 

temporary given the rapid regeneration time of many aquatic invertebrates. 

Malathion 

Potential exposures to the general public and workers from RAA Ts application rates are 

of a commensurately lower magnitude than conventional rates. These low exposures to 

the public pose no risk of direct toxicity, rieurotoxicity, genotoxicity, reproductive 

toxicity, or developmental toxicity. 

Potential risks to workers are negligible if proper safety procedures are adhered to, 

including the use of required protective clothing. The low exposures to malathion from 

program applications are not expected to pose any carcinogenic risks to workers or the 

general public. 

Malathion applied at a RAA Ts rate will cause mortalities to susceptible insects. 

Organisms in untreated areas will be mostly unaffected. Field applications of malathion 

at a RAA Ts rate and applied in alternate swaths resulted in less reduction in nontarget 

organisms than would occur in blanket treatments. Birds in RAATs areas were not 

substantially affected (EIS p. 56). Should malathion applied at RAATs rates enter water, 

it is most likely to affect aquatic invertebrates. However, these effects would soon be 

compensated for by the surviving organisms given the rapid generation time of most 

aquatic invertebrates and the rapid degradation of malathion in most water bodies. 

The implementation of pesticide label instructions and restrictions and the APHIS 

treatment guidelines will reduce potential impacts from the program use of insecticides 

(see Appendix 1 treatment guidelines). 

Human health 

Human exposure to insecticides would occur. Exposures and effects are discussed in the 

2002 EIS pp. 50, 52, and 55. Personnel working on the suppression program would be 

exposed during handling, loading and application of the insecticides. Potential exposure 

of the general public would be infrequent and of low magnitude. Potential for exposure 

41 
ID-PPQ-GH2003-001 

would be less than under the Insecticide Applications at Conventional Rates Alternative. 

Implementation of the Treatment Guidelines (Appendix 1.) would minimize public 

exposure and protect workers from harmful exposure. Individuals with hypersensitivity 

to the insecticides, carriers, and adjuvants might be affected. APHIS would seek lists of 

hypersensitive individuals from state and county health departments and would contact 

persons who reside adjacent to proposed treatment blocks prior to treatment. 

Hypersensitive individuals would be advised to avoid treatment blocks and the areas 

surrounding them. 

Many stakeholders have indicated that they are opposed to any treatments on public 

rangelands because they believe treatments would disrupt ecosystems. The anxiety levels 

of these stakeholders may be increased, but it may not be increased to the same level as 

would result from implementation of Insecticide Applications at Conventional Rates 

Alternative . 

Negative impacts to human physical health would be minimized by the implementation 

of the Guidelines in Appendix 1. 

Non-target species 

Grasshopper feeding damage would be reduced to rangeland plants, including desirable 

and undesirable plants, and to crops adjacent to rangeland. The general level of reduction 

would be somewhat less than under Insecticide Applications at Conventional Rates 

Alternative. Population densities of some nontarget insects and other arthropods would 

be reduced. The general level of reduction would be somewhat less than under 

Insecticide Applications at Conventional Rates Alternative. Food sources for some 

insectivorous animal speci.es would be reduced. The general level of reduction would be 

somewhat less than under Insecticide Applications at Conventional Rates Alternative. 

Nontarget plant and animal species would be exposed to insecticides. The general level of 

exposure would be somewhat less than under Insecticide Applications at Conventional 

Rates Alternative. 

Reduction of the grasshopper feeding damage may be viewed as having both negative 

and positive impacts. Various grasshopper species feed on invasive weeds such as rush 

skeletonweed. Limiting the damage grasshoppers do to invasive weeds would be seen by 

most observers as a negative impact. Limiting the damage grasshoppers do to desirable 

plants would be seen by most observers as a positive impact. Damage done by 

grasshoppers would be somewhat more than under Insecticide Applications at 

Conventional Rates Alternative. 

Nontarget insect species which would be put at risk by treatments under this alternative 

include non-native biological control agents and pollinators. The level of risk would be 

somewhat less than under Insecticide Applications at Conventional Rates Alternative. 

The majority of the non-native biological control agents in the proposed suppression area 

result from release programs carried out by land management agencies and others. The 

Nez Perce Biological Control Center in Lapwai provides database service which allows 

managers to report locations ofbiocontrol releases and the status of biocontrol agent 

42 
ID-PPQ-GH2003-001 

populations. APHIS would consult with land managers and the Nez Perce Biological 

Control Center to determine the location and status of biological control agent 

populations and would select treatment options (including buffering areas) which 

minimize negative impacts on the populations. 

The most widespread, managed, non-native pollinator in the proposed suppression area is 

the honeybee. Honeybees are found throughout and near the proposed suppression area. 

Malathion and carbaryl sprays are very toxic to honeybees. APHIS would provide 

beekeepers with notification of the suppression program and would conduct surveys to 

detect beeyards in or near proposed spray blocks. APHIS would not utilize carbaryl or 

malathion sprays within 1 mile of active beeyards. Risk to honeybees would be similar 

to the risk under Insecticide Applications at Conventional Rates Alternative. 

Managed native pollinators include leafcutter and alkali bees. These species may be 

found in the proposed treatment area, but are usually encountered in crop areas adjacent 

to the rangeland. APHIS would conduct surveys and would consult with private 

landowners to determine if managed native pollinators are in or near proposed treatment 

blocks. APHIS would not utilize carbaryl or malathion spray within 1 mile of managed 

native pollinators. Risk to managed native pollinators would be similar to the risk under 

Insecticide Applications at Conventional Rates Alternative. 

Unmanaged native pollinators include a vast array of insects and other animals. In 

general, the insect fauna within this group is more susceptible to malathion and carbaryl 

sprays than to the other treatment options. To maximize the protection of these 

organisms, APHIS would select diflubenzuron spray or carbaryl bait whenever they 

would be efficacious to control grasshopper outbreaks. Risk to unmanaged native 

pollinators would be somewhat less than the risk under Insecticide Applications at 

Conventional Rates Alternative. 

Many stakeholders have strongly expressed concern regarding the reduction of insects as 

a food source for rangeland insectivores, especially sage grouse and sharptail grouse 

chicks. In this alternative, the application rates chosen for the broader spectrum 

insecticides are reduced from the maximum rate allowed by EPA. Additionally, the 

amount of area covered within a spray block is reduced (normally by 50% ). The 

reduction in rates and coverage along with the use of the insecticides ( diflubenzuron and 

carbaryl bait) which are more selective for grasshoppers than for most other species 

leaves alternative insect fauna for foraging insectivores. Because APHIS would only 

treat significant outbreak populations, numbers of grasshoppers surviving the treatment 

can provide ample nourishment for the insectivores. Additionally, Martin et. al. (2000) 

and Howe, et. al. (2000) found that Canadian grassland and Idaho shrub steppe bird 

species were able to make adaptive changes when insecticidal spray reduced the numbers 

and changed the composition of insect prey species. Reduction in prey available to 

insectivores would be significantly less than under Insecticide Applications at 

Conventional Rates Alternative. 

43 
ID-PPQ-G 82003-001 

Stakeholders have expressed concern about chronic and toxicity of insecticides to birds 

on rangeland. These concerns were well founded for grasshopper control programs 

conducted throughout much of the 20thCentury. Originally, inorganic insecticides were 

used, with a typical bran bait formulation incorporating 8 pounds of liquid sodium 

arsenite into 100 pounds of bran (Cowan 1929). For a brief span in the mid-20th century, 

synthetic organochlorine insecticides such as chlordane, toxaphene, dieldrin, and aldrin 

came into use. These insecticides would accumulate in birds or other animals which 

consumed poisoned grasshoppers, eventually leading to a toxic dosage level. USDA 

discontinued their recommendation for using organochlorine insecticides on grasshoppers 

in 1965 (McEwen, et. ai. 1972). The organochlorine insecticides were replaced with the 

organophosphate and carbamate insecticides. Certain of these are highly toxic to birds. 

Blus et. al. (1989) determined that sage grouse die-offs in Southeastern Idaho could be 

attributed to methamidophos and dimethoate treatments to agricultural fields used by the 

sage grouse. Martin et. al. (2002) determined that furadan treatments depressed 

cholinesterase levels in birds in study areas. APHIS would not use insecticides that are 

highly toxic to birds or other terrestrial wildlife in the proposed suppression area. The 

risk of acute or chronic toxicity to birds is essentially equivalent to the risk under 

Insecticide Applications at Conventional Rates Alternative. 

Pesticide spills could expose wildlife to excessive levels of insecticide. APHIS maintains 

spill kits and insures that program personnel are familiar with procedures to mitigate 

effects associated with a spill. The risk of pesticide spills is roughly equivalent to the risk 

under Insecticide Applications at Conventional Rates Alternative. 

Negative impacts to nontarget organisms would be minimized by the implementation of 

the Treatment Guidelines, Appendix 1. 

Socioeconomic issues 

There is a reduced risk that grasshopper outbreaks on rangeland would decrease the 

availability of forage for cattle and sheep. The risk is somewhat higher than under 

Insecticide Applications at Conventional Rates Alternative. Because of reduced 

insecticidal rates and coverage, the RAA TS Alternative requires ideal treatment 

conditions to effectively suppress an outbreak. 

There is reduced risk of unchecked movement of grasshopper outbreaks into crops 

resulting in crop loss and additional expenditures for insecticidal control in the crop 

fields. The risk is somewhat higher than under Insecticide Applications at Conventional 

Rates Alternative. Because ofreduced insecticidal rates and coverage, the RAATS 

Alternative requires ideal treatment conditions to effectively suppress an outbreak. 

Organic farmers face less risk of significant losses from grasshopper outbreaks on 

rangeland which could emigrate to organic cropland. The risk is somewhat higher than 

under Insecticide Applications at Conventional Rates Alternative. Because of reduced 

rates and coverage, the RAA TS Alternative requires ideal treatment conditions to 

effectively suppress an outbreak. Organic farmers would be put at increased risk of 

contamination from spray drift originating from grasshopper suppression programs. The 

44 
ID-PPQ-G H2003-001 

risk is somewhat less than under Insecticide Applications at Conventional Rates 

Alternative because less insecticide is applied in a treatment block. APHIS would 

consult with ISDA and procure a listing of certified organic growers. APHIS would 

utilize 1 mile aerial spray buffers to avoid organic farm operations. APHIS would 

consult with any residents in the immediate vicinity of treatment blocks so that organic 

garden locations can be avoided. 

Negative socioeconomic impacts would be minimized by the implementation of the 

Treatment Guidelines, Appendix 1. 

Cultural resources and events 

The availability of grasshoppers for fish bait and other human uses would be reduced 

from outbreak levels to more normal levels. Persons using rangelands for recreation 

would respond to grasshoppers as they do under normal conditions versus under outbreak 

conditions. Availability of grasshoppers would be somewhat greater than under 

Insecticide Applications at Conventional Rates Alternative. 

Artificial surfaces 

Malathion and carbaryl spray can damage some painted surfaces. Automotive and sign 

finishes are susceptible to damage by malathion and carbaryl spray, and automobile or 

sign owners could suffer economic loss repairing cosmetic damage. APHIS would not 

spray un-abandoned vehicles in malathion or carbaryl spray blocks. APHIS would 

consult with land managers if malathion or carbaryl spray was going to be used so they 

could elect to cover or remove signs during treatment. APHIS would consult with land 

managers to insure that Native American petroglyphs were excluded from spray blocks. 

Probability of damage would be less in the RAA TS Alternative than in Insecticide 

Applications at Conventional Rates Alternative. 

4. Modified Reduced Area Agent Treatments (MRAATs) Alternative 

Under this alternative, APHIS would suppress grasshopper outbreaks when there is 

potential for the outbreak causing economic loss or environmental degradation. 

Insecticides would be applied at or below EPA approved rates as specified in 11.D. 

Carbary I 

Potential exposures to the general public and workers from MRAA Ts application rates 

are lower than those from conventional application rates, and adverse effects decrease 

commensurately with decreased magnitude of exposure. These low exposures to the 

public pose no risk of direct toxicity, carcinogenicity, neurotoxicity, genotoxicity, 

reproductive toxicity, or developmental toxicity. The potential for adverse effects to 

workers is negligible if proper safety procedures are followed, including wearing the 

required protective clothing. Routine safety precautions are expected to provide adequate 

protection of worker health at the lower application rates under MRAA Ts. 

Carbary! will most likely affect nontarget insects that are exposed to liquid carbaryl or 

that consume carbaryl bait. While carbaryl applied at an MRAA Ts rate will reduce 

susceptible insect populations, the decrease will be less than under Conventional rates. 

45 
ID-PPQ-G H2003-001 

Carbary! UL V applications applied in alternate swaths have been shown to affect 

terrestrial arthropods less than malathion applied in a similar fashion (EIS p. 56). 

Direct toxicity of carbaryl to birds, mammals, and reptiles is unlikely in swaths treated 

with carbaryl under an MRAATs approach. Carbaryl bait also has minimal potential for 

direct effects on birds and mammals. Field studies indicated that bee populations did not 

decline after carbaryl bait treatments, and American kestrels were unaffected by bait 

applications made at a RAA Ts rate. Using alternating swaths will furthermore reduce 

adverse effects because organisms that are in untreated swaths will be mostly unexposed 

to carbaryl. 

Carbary! applied at an MRAATs rate has the potential to affect invertebrates in aquatic 

ecosystems. However, these affects would be less than effects expected under 

conventional rates alternative. Fish are not likely to be affected at any concentrations that 

could be expected under The MRAA TS Alternative. 

Diflubenzuron 

Potential exposures and adverse effects to the general public and workers from MRAATs 

application rates are commensurately less than conventional application rates. These low 

exposures to the public pose no risk of methemoglobinemia, direct toxicity, 

neurotoxicity, genotoxicity, reproductive toxicity, or developmental toxicity. Potential 

worker exposures pose negligible risk of adverse health effects. 

Because diflubenzuron is a chitin inhibitor that disrupts insects from forming their 

exoskeleton, organisms without a chitinous exoskeleton, such as mammals, fish, and 

plants are largely unaffected by diflubenzuron. Diflubenzuron exposures at The 

MRAA TS Alternative rates are not hazardous to terrestrial mammals, birds, and other 

vertebrates. Insects in untreated swaths would have little to no exposure, and adult 

insects in the treated swaths are not susceptible to diflubenzuron s mode of action. The 

indirect effects to insectivores would be negligible as not all insects in the treatment area 

will be affected by diflubenzuron. 

Diflubenzuron is most likely to affect immature terrestrial insects and, if it enters water, 

will affect early life stages of aquatic invertebrates. While diflubenzuron would reduce 

insects within the treatment area, insects in untreated swaths would have little to no 

exposure. Many of the aquatic organisms most susceptible to diflubenzuron are marine 

organisms that would not be exposed to rangeland treatments. Freshwater invertebrate 

populations would be reduced if exposed to diflubenzuron, but these decreases may be 

temporary given the rapid regeneration time of many aquatic invertebrates. 

Malathion 

Potential exposures to the general public and workers from MRAA Ts application rates 

are of a commensurately lower magnitude than conventional rates. These low exposures 

to the public pose no risk of direct toxicity, neurotoxicity, genotoxicity, reproductive 

toxicity, or developmental toxicity. 

46 
ID-PPQ-G H2003-001 

Potential risks to workers are negligible if proper safety procedures are adhered to, 

including the use of required protective clothing. The low exposures to malathion from 

program applications are not expected to pose any carcinogenic risks to workers or the 

general public. 

Malathion applied at a MRAA Ts rate will cause mortalities to susceptible insects. 

Organisms in untreated areas will be mostly unaffected. Field applications of malathion 

at a RAA Ts rate and applied in alternate swaths resulted in less reduction in nontarget 

organisms than would occur in blanket treatments. Birds in RAA Ts areas were not 

substantially affected (EIS p. 56). Should malathion applied at MRAA Ts rates enter 

water, it is most likely to affect aquatic invertebrates. However, these effects would soon 

be compensated for by the surviving organisms given the rapid generation time of most 

aquatic invertebrates and the rapid degradation of malathion in most water bodies. 

The implementation of pesticide label instructions and restrictions and the AP HIS 

treatment guidelines will reduce potential impacts from the program use of insecticides 

(see Appendix 1 treatment guidelines). 

Human health 

Human exposure to insecticides would occur. Exposures and effects are discussed in the 

2002 EIS pp. 39-40, 50, 52, and 55. Personnel working on the suppression program 

would be exposed during handling, loading and application of the insecticides. Potential 

exposure of the general public would be infrequent and of low magnitude. Potential 

exposure would be intermediate between Insecticide Applications at Conventional Rates 

and the RAATS Alternatives. Implementation of the Treatment Guidelines (Appendix 

1.) would minimize public exposure and protect workers from harmful exposure. 

Individuals with hypersensitivity to the insecticides, carriers, and adjuvants might be 

affected. AP HIS would seek lists of hypersensitive individuals from state and county 

health departments and would contact persons who reside near proposed treatment blocks 

prior to treatment. Hypersensitive individuals would be advised to avoid treatment 

blocks and the areas surrounding them. 

Many stakeholders have indicated that they are opposed to any treatments on public 

rangelands because they believe treatments would disrupt ecosystems. The anxiety levels 

of these stakeholders may be increased, but it may not be increased to the same level as 

would result from implementation of Insecticide Applications at Conventional Rates 

Alternative. 

Non-target species 

Grasshopper feeding damage would be reduced to rangeland plants, including desirable 

and undesirable plants, and to crops adjacent to rangeland. The general level of reduction 

would be intermediate between Insecticide Applications at Conventional Rates and 

RAA TS Alternatives. Population densities of some nontarget insects and other 

arthropods would be reduced. The general level of reduction would be intermediate 

between Insecticide Applications at Conventional Rates and RAATS Alternatives. Food 

sources for some insectivorous animal species would be reduced. The general level of 

47 
ID-PPQ-GH2003-001 

reduction would be intermediate between Insecticide Applications at Conventional Rates 

and RAA TS Alternatives. Nontarget plant and animal species would be exposed to 

insecticides. The general level of exposure would be intermediate between Insecticide 

Applications at Conventional Rates and RAA TS Alternatives. 

Reduction of the grasshopper feeding damage may be viewed as having both negative 

and positive impacts. Various grasshopper species feed on invasive weeds such as rush 

skeletonweed. Limiting the damage grasshoppers do to invasive weeds would be seen by 

most observers as a negative impact. Limiting the damage grasshoppers do to desirable 

plants would be seen by most observers as a positive impact. Damage done by 

grasshoppers would be intermediate between Insecticide Applications at Conventional 

Rates and RAA TS Alternatives. 

Nontarget insect species which would be put at risk by treatments under this alternative 

include non-native biological control agents and pollinators. The level of risk would be 

intermediate between Insecticide Applications at Conventional Rates and RAA TS 

Alternatives. The majority of the non-native biological control agents in the proposed 

suppression area result from release programs carried out by land management agencies 

and others. The Nez Perce Biological Control Center in Lapwai provides database 

. service which allows managers to report locations of biocontrol releases and the status of 

biocontrol agent populations. APHIS would consult with land managers and the Nez 

Perce Biological Control Center to determine the location and status of biological control 

agent populations and would select treatment options (including buffering areas) which 

minimize negative impacts on the populations. 

The most widespread, managed, non-native pollinator in the proposed suppression area is 

the honeybee. Honeybees are found throughout and near the proposed suppression area. 

Malathion and carbaryl sprays are very toxic to honeybees. APHIS would provide 

beekeepers with notification of the suppression program and would conduct surveys to 

detect beeyards in or near proposed spray blocks. APHIS would not utilize carbaryl or 

malathion sprays within 1 mile of active beeyards. Risk to honeybees would be 

intermediate between Insecticide Applications at Conventional Rates and RAA TS 

Alternatives. 

Managed native pollinators include leafcutter and alkali bees. These species may be 

found in the proposed treatment area, but are usually encountered in crop areas adjacent 

to the rangeland. APHIS would conduct surveys and would consult with private 

landowners to determine if managed native pollinators are in or near proposed treatment 

blocks. APHIS would not utilize carbaryl or malathion spray within 1 mile of managed 

native pollinators. Risk to managed native pollinators would be intermediate between 

Insecticide Applications at Conventional Rates and RAA TS Alternatives. 

Unmanaged native pollinators include a vast array of insects and other animals. In 

general, the insect fauna within this group is more susceptible to malathion and carbaryl 

sprays than to the other treatment options. To maximize the protection of these 

organisms, APHIS would select diflubenzuron spray or carbaryl bait whenever they 

48 
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would be efficacious to control grasshopper outbreaks. Risk to unmanaged native 

pollinators would be intermediate between Insecticide Applications at Conventional 

Rates and RAA TS Alternatives. 

Many stakeholders have expressed concern regarding the reduction of insects as a food 

source for rangeland insectivores, especially sage grouse and sharptail grouse chicks. In 

this alternative, the application rates chosen for the broader spectrum insecticides are 

reduced from the maximum rate allowed by EPA. Additionally, the amount of area 

covered within a spray block is reduced (normally by 50%). The reduction in rates and 

coverage along with the use of the insecticides (diflubenzuron and carbaryl bait) which 

are more selective for grasshoppers than for most other species leaves alternative insecf 

fauna for foraging insectivores. Because APHIS would only treat significant outbreak 

populations, numbers of grasshoppers surviving the treatment can provide ample 

nourishment for the insectivores. Additionally, Martin et. al. (2000) and Howe, et. al. 

(2000) found that Canadian grassland and Idaho shrub steppe bird species were able to 

make adaptive changes when insecticidal spray reduced the numbers and changed the 

composition of insect prey species. Reduction in prey available to insectivores would be 

intermediate between Insecticide Applications at Conventional Rates Alternatives. 

Stakeholders have expressed concern about chronic and acute toxicity of insecticides to 

birds on rangeland. These concerns were well founded for grasshopper control programs 

conducted throughout much of the 20th Century. Originally, inorganic insecticides were 

used, with a typical bran bait formulation incorporating 8 pounds of liquid sodium 

arsenite into 100 pounds of bran (Cowan 1929). For a brief span in the mid-20th century, 

synthetic organochlorine insecticides such as chlordane, toxaphene, dieldrin, and aldrin 

came into use. These insecticides would accumulate in birds or other animals which 

consumed poisoned grasshoppers, eventually leading to a toxic -dosage level. USDA 

discontinued their recommendation for using organochlorine insecticides on grasshoppers 

in 1965 (McEwen, et. al. 1972). The organochlorine insecticides were replaced with the 

organophosphate and carbamate insecticides. Certain of these are highly toxic to birds. 

Blus et. al. ( 1989) determined that sage grouse die-offs in Southeastern Idaho could be 

attributed to methamidophos and dimethoate treatments to agricultural fields used by the 

sage grouse. Martin et. al. (2002) determined that furadan treatments depressed 

cholinesterase levels in birds in study areas. APHIS would not use insecticides that are 

highly toxic to birds or other terrestrial wildlife in the proposed suppression area. The 

risk of acute or chronic toxicity to birds is intermediate between Insecticide Applications 

at Conventional Rates and RAA TS Alternatives. 

Pesticide spills could expose wildlife to excessive levels of insecticide. APHIS maintains 

spill kits and insures that program personnel are familiar with procedures to mitigate 

effects associated with a spill. The risk of pesticide spills is roughly equivalent to the risk 

under Insecticide Applications at Conventional Rates Alternative . 

. Negative impacts to nontarget organisms would be minimized by the implementation of 

the Treatment Guidelines, Appendix 1. 

49 
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Socioeconomic issues 

There is a reduced risk that grasshopper outbreaks on rangeland would decrease the 

availability of forage for cattle and sheep. The risk is intermediate between Insecticide 

Applications at Conventional Rates and RAA TS Alternatives. 

There is reduced risk of unchecked movement of grasshopper outbreaks into crops 

resulting in crop loss and additional expenditures for insecticidal control in the crop 

fields. The risk is intermediate between Insecticide Applications at Conventional Rates 

and RAA TS Alternatives. 

Organic farmers face less risk of significant losses from grasshopper outbreaks on 

rangeland which could emigrate to organic cropland. The risk is intermediate between 

Insecticide Applications at Conventional Rates and RAA TS Alternatives. Organic 

farmers would be put at increased risk of contamination from spray drift originating from 

grasshopper suppression programs. The risk is somewhat less than under Insecticide 

Applications at Conventional Rates Alternative because less insecticide is applied in a 

treatment block. APHIS would consult with ISDA and procure a listing of certified 

organic growers. APHIS would utilize 1 mile aerial spray buffers to avoid organic farm 

operations. APHIS would consult with any residents in the immediate vicinity of 

treatment blocks so that organic garden locations can be avoided. 

Negative socioeconomic impacts would be minimized by the implementation of the 

Treatment Guidelines, Appendix 1. 

Cultural resources and events 

The availability of grasshoppers for fish bait and other human uses would be reduced 

from outbreak levels to more normal levels. Persons using rangelands for recreation 

would respond to grasshoppers as they do under normal conditions versus under outbreak 

conditions. Availability of grasshoppers would be intermediate between Insecticide 

Applications at Conventional Rates and RAA TS Alternatives. 

Artificial surfaces 

Malathion and carbaryl spray can damage some painted surfaces. Automotive and sign 

finishes are susceptible to damage by malathion and carbaryl spray, and automobile or 

sign owners could suffer economic loss repairing cosmetic damage. APHIS would not 

spray un-abandoned vehicles in malathion or carbaryl spray blocks. APHIS would 

consult with land managers if malathion or carbaryl spray was going to be used so they 

could elect to cover or remove signs during treatment. APHIS would consult with land 

managers to insure that Native American petroglyphs were excluded from spray blocks. 

Probability of damage in this alternative would be intermediate between Insecticide 

Applications at Conventional Rates and RAA TS Alternatives. 

B. Other Environmental Considerations 

1. Cumulative Impacts 

Cumulative impact, as defined in the CEQ NEPA implementing regulations 

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ID-PPQ-G H2003-001 

( 40 CFR § 1508. 7), is the impact on the environment which results from the incremental 

impact of the action when added to the past, present, and reasonably foreseeable future 

actions regardless of what agency (Federal or non-Federal) or person undertakes such 

actions. Cumulative impacts can result from individually minor but collectively 

significant actions taking place over a period of time. 

Some exposures, especially to workers, may occur over several days to several months. 

In addition, and in extremely rare situations, some program activities may be repeated 

more than once during a year. Such exposures are referred to as cumulative exposures. 

Depending on the specific exposure scenario and the nature of the available data, the 

consequences of cumulative exposures are assessed in a variety of ways in the 2002 EIS. 

Some individuals may be exposed to more than one treatment type, either in their job as 

applicators or because they frequent areas where different types of treatment are applied. 

Such exposures are considered connected actions, that is, one or more actions that an 

individual may take that could affect the individual s risk to the insecticides used to 

suppress grasshoppers. In addition, all individuals are exposed to a multitude of 

chemicals and biological organisms every day in foods, medicines, household products, 

and other environmental chemicals. 

Public and private land managers utilize various herbicides to control weeds within the 

proposed suppression area. State and private land managers may use insecticides to 

control grasshoppers and other insects outside the purview of this EA, but within the 

proposed treatment area. APHIS is responsible for grasshopper treatments on federal 

land. 

AP HIS would consult with land managers to determine if herbicides or insecticides have 

been utilized within the past year on any proposed spray block within the proposed 

suppression area. APHIS would not apply any insecticide in a manner that conflicts with 

EPA requirements regarding multiple treatments. APHIS would not apply insecticide to 

an area known to have been treated within one year with a pesticide known to have 

cumulative or synergistic effects with carbaryl, diflubenzuron or malathion. 

Public and private land managers utilize biological control agents to suppress invasive 

weed populations within and near the proposed suppression area. Treatment alternatives 

could negatively impact the biological control agents. APHIS would consult with land 

managers and the Nez Perce Biological Control Center to determine the location and 

status of biological control agent populations and would select treatment options 

(including buffering areas) which minimize negative impacts on the populations. 

2. Synergistic effects 

There may be situations where it is appropriate to use one insecticide or formulation in 

one part of a treatment area and a different insecticide or formulation in another part of 

that same treatment area with all applications conducted according to the label directions. 

51 
ID-PPQ-G H2003-001 

For example, ultra-low-volume (UL V) malathion may be used over the majority of a 

treatment area, but areas of special consideration may be treated with carbaryl bait. 

Should these situations occur, no area would be treated with more than one insecticide, 

and there would be no mixing or combination of insecticides. 

Difl ubenzuron 

Diflubenzuron is only reported to be synergistic with the defoliant DEF. Because the 

defoliant is unlikely to be applied concurrently with grasshopper suppression treatments, 

there is minimal risk of synergistic effects 

Carbarvl 

The only studies of chemical interactions with carbaryl indicate that toxicity of 

organophosphates combined with carbaryl is additive not synergistic (2002 EIS p B-13) 

Malathion 

Although the toxicity of malathion may be potentiated by some other organophosphates 

and carbamates, it is impossible to predict multiple exposures and synergism from 

applications not related to this program. Organophosphate insecticides are routinely used 

in mosquito control programs and on crops in some areas near proposed treatment areas. 

There is some potential for synergistic effects resulting from the combination of 

malathion and inadvertent simultaneous pesticide application by the public; however, 

notification of residents adjacent to treatment blocks about program treatments helps to 

minimize this risk. 

3. Inert ingredients and metabolites 

Diflubenzuron 

There are various carriers and adjuvants used with diflubenzuron to enhance the pesticide 

applications. These are primarily synthetic and natural oils. These inert ingredients may 

include light and heavy paraffinic oils, polyethylene glycol nonylphenyl ether, alkylaryl 

polyether-ethanols, vegetable oil surfactants, and canola oil. Food-grade canola oil 

would not be expected to pose any noteworthy hazards, but some of the heavier oils could 

affect birds and other wildlife. (Use of formulations that use the paraffinic oils may not 

be appropriate in some habitats with nesting birds, particularly if endangered or 

threatened species are present or protection of game birds is an issue.) Although the 

paraffinic oils have been shown to decrease egg-hatch of nesting birds, these effects have 

only been observed from spills or exposures higher than are anticipated from program 

applications. Polyethylene glycol nonylphenyl ether has generally not been of human 

health concern except for a few cases of allergic contact dermatitis. This should not be 

an issue if proper program safety precautions are followed. This compound does not 

persist in natural environments and is unlikely to show bioconcentration of residues. 

The primary metabolites of diflubenzuron are 4-chlorophenylurea (CPU) and 2,6-

difluorobenzoic acid. The acid metabolite is further metabolized by microorganisms in 1 

to 2 weeks in soil. The CPU degrades in soil in about 5 weeks. The rapid metabolism 

and degradation of this metabolite's low concentrations make it highly unlikely that there 

52 
ID-PPQ-G H2003-001 

would be sufficient exposure to cause any of the adverse toxicological effects noted in 

these studies. See 2002 EIS pp B-15 to B-16 for details and references. 

Carbaryl 

Although the formulations of carbaryl in some previous programs had oil-based carriers 

(i.e., Sevin 4-oil), current programs have converted to water-based carriers (i.e., SEVIN 

XLR PLUS). Some information about inert ingredients in these formulations is available. 

One inert ingredient is propylene glycol or propanediol (antifreeze agent). It degrades 

readily to carbon dioxide and water in soil and water environments after applications, so 

actual exposures from the grasshopper suppression program would only be acute. The 

low exposures to humans would not expect to have human health effects except to those 

few individuals experiencing allergic contact dermatitis. Propylene glycol is practically 

nontoxic to fish and daphnia. Concentrations of propylene glycol from program 

application rates would not be anticipated to result in adverse effects to wildlife. 

N-amyl acetate or "banana oil" is used as a flavor additive in carbaryl bait.. N-amyl 

acetate readily volatilizes to the atmosphere. Biodegradation occurs readily in soil, but 

there is moderate potential for bioconcentration in aquatic organisms. Although this 

compound is a primary irritant of skin, eyes, and mucus membranes, the low potential 

exposures from program applications of carbaryl bait are not expected to result in any 

adverse effects to humans. Although it may bioconcentrate in aquatic organisms, the 

toxicity to those species is low relative to the active ingredient (carbaryl) in the 

formulation. 

The major hydrolytic metabolites of carbaryl are glucaronides and sulfates. Most 

metabolites such as naphthol are considerably less toxic than carbaryl. There has been 

some concern expressed about the reaction of carbaryl with nitrite under certain 

circumstances. This may result in the formation of N-nitrosocarbaryl which has been 

shown to be mutagenic and carcinogenic in laboratory tests. See 2002 EIS pp B-12 to B13 for details and references. 

Malathion 

The main impurities of concern in malathion formulations are isomalathion (95 times as 

toxic as malathion) and malaoxon (68 times as toxic as malathion). Isomalathion 

formation results from improper storage or handling of malathion formulations. 

Malaoxon is formed from malathion's oxidation, which has been reported to occur in air 

and from volatilization from the droplets on various surfaces. A recent pilot study found 

that, following aerial malathion applications, malaoxon and other transformation products 

were detectable in air and on various test surfaces for hours and, in some cases, days after 

the treatment. Levels of malaoxon increased, presumably via oxidation of malathion on 

some test surfaces for the 9 days of the study. However, another study indicated that the 

dermal uptake of a pesticide can be highly dependent on the amount that is bioavailable 

(i.e., the amount of residue that can be dislodged or assimilated) and that the amount can 

decrease substantially over a 12-hour period. The variances in test data and the absence 

of any scientific accord over the interpretation of the results point to the need for further 

studies in this area There is some petroleum-based oil that occurs in some UL V 

53 
ID-PPQ-G H2003-001 

formulations. The exposure of birds' eggs and humans to this oil has been shown to have 

no adverse effects at program application rates. See 2002 EIS p B-20 for details and 

references. 

4. Executive Order No. 12898, Federal Actions to Address Environmental 

Justice in Minority Populations and Low-Income Populations 

Although specific data are not available, observations indicate that Hispanics and 

Asians are the minority groups which would be most impacted by the suppression 

programs because of their involvement in agricultural production systems. 

No Action Alternative may cause Hispanic and Asian farm workers to be exposed to 

additional insecticides applied to cropland. No Action Alternative may increase costs of 

operation for Asian and Hispanic farm operators. 

Insecticide Applications at Conventional Rates Alternative would have no 

disproportionate impact on minority or low income populations. 

RAA TS Alternative would have no disproportionate impact on minority or low income 

populations. 

MRAA TS Alternative would have no disproportionate impact on minority or low income 

populations. 

Human health effects on individuals with poor nutritional status are analyzed in the 2002 

EIS pp B-24, B-27, and B-28. 

5. Executive Order No. 13045, Protection of Children from Environmental 

Health Risks and Safety Risks 

The human health risk assessment for the 2002 EIS analyzed the effects of exposure to 

children from the three insecticides. Based on review of the insecticides and their use in 

the grasshopper program, the risk assessment concluded that the likelihood of children 

being exposed to insecticides is very slight and that no disproportionate adverse effects to 

children are anticipated over the negligible effects to the general population. Treatments 

are primarily conducted on open rangelands where children would not be expected to be 

present during treatment or enter should there be any restricted entry period after 

treatment. No urban areas or schools would be subject to treatment under the proposed 

action. 

Potential for impacts of pesticides on children would be minimized by the 

implementation of the treatment guidelines, standard operational procedures and added 

measures included in 111.D.7. 

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6. Executive Order 13186, Responsibilities of Federal Agencies to Protect 

Migratory Birds 

In accordance with various environmental statutes, APHIS routinely conducts programs 

in a manner that minimizes impact to the environment, including any impact to migratory 

birds. In January 2001 , President Clinton signed Executive Order 13186 to ensure that all 

government programs protect migratory birds to the extent practicable. To further its 

purposes, this Executive Order requires each agency with a potential to impact migratory 

birds to enter into an MOU with FWS. In compliance with the Executive Order, APHIS 

is currently working with FWS to develop such an MOU. 

7. Endangered Species Act 

Policies and procedures for protecting endangered and threatened species of wildlife and 

plants were established by the Endangered Species Act (ESA) of 1973, as amended (16 

United States Code (U.S.C.) 1531 et seq.). The ESA is designed to ensure the 

protection of endangered and threatened species and the habitats upon which they depend 

for survival. Regulations implementing the provisions of the ESA have been issued. In 

accordance with section 7 of the ESA, consultation is to be conducted for any action 

authorized, funded, or carried out by a Federal agency that may affect listed endangered 

or threatened species or their habitats. APHIS includes proposed species in their 

consultations. Consultations are conducted with Fish and Wildlife Service (FWS), DOI, 

for terrestrial species and most aquatic species and with the NOAA Fisheries, U.S. 

Department of Commerce, for marine and anadromous species. 

The most recent national biological opinion on the grasshopper program was issued by 

FWS July 21 , 1995. In following years, no national biological assessment was prepared 

since control programs were not anticipated in most states due to lack of funding. A 

national biological assessment for the Rangeland Grasshopper and Mormon Cricket 

Suppression Program is currently under way, but the process for its completion and 

consideration by FWS will not be concluded in time for the 2003 season. In order to 

comply with the Section 7 requirements, APHIS conducts ongoing informal consultations 

with FWS, locally. The 1995 biological opinion and 1998 biological assessment will be 

used as a basis for these local consultations and are incorporated into this EA by 

reference. For this EA, APHIS conducted informal consultation with FWS, Snake River 

Basin Office and arrived at determinations of protective measures which were needed in 

addition to those derived from earlier Biological Opinions. For this EA, APHIS 

conferred with NOAA Fisheries Boise Idaho office and determined that consultation was 

not required if the proposed suppression area excluded watersheds of the Salmon river 

and the Snake River below Brownlee Dam. 

Of the insecticides proposed for use in earlier assessments, malathion and carbaryl have 

been retained for potential use in 2003. Use of acephate in APHIS grasshopper 

suppression programs has been discontinued. Ditlubenzuron has been used by APHIS 

for many years in Gypsy moth and cotton boll weevil eradication programs. It is now 

registered for use against grasshoppers on rangeland and has been added to the set of 

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options that APHIS would use in grasshopper suppression. Diflubenzuron would be 

expected to have less effect than either carbaryl or malathion on virtually all species other 

than immature arthropods. Diflubenzuron and its effects are thoroughly discussed in the 

2002 EIS pp. 32-33, 42-45, 52-55. Because diflubenzuron has less direct and indirect 

effect on nontarget species than either malathion or carbaryl spray, protection measures 

applied to malathion and carbaryl should be more than adequate for diflubenzuron 

Listed Endangered or Threatened Species 

The proposed project area may contain suitable habitat for Federally listed Threatened, 

Endangered or Candidate species. Protection measures and findings of no jeopardy or no 

effect without buffers or other measures previously approved by FWS are referenced by 

the date of the biological opinion (FWS XX/XX/XX). Measures developed by APHIS 

and FWS during 2003 consultation are referenced (FWS2003). 

Bald Eagle, Haliaeetus leucocephalus 

The bald eagle is listed as a threatened species in all contiguous 48 States. Bald eagle 

habitat in South Central and Southeast Idaho is located along the South Fork, the Henry's 

Fork and the main Snake River downstream to the western border of the project area at 

King Hill Creek. The South Fork, Henry's Fork and main Snake River is considered year 

long habitat with the majority of the eagles present during the winter months. There are 

active bald eagle nests on all of the forks of the Snake River. Some immature birds have 

been seen at American Falls Reservoir during early spring nest occupancy survey flights. 

The remainder of the main Snake, Boise, Weiser, Bruneau, and Payette River areas only 

contain bald eagles during the winter period. The only other nest location is in 

Southwestern Idaho on the Carbarton stretch of the Payette River. 

APHIS would maintain 1-mile radius treatment-free zone around active aeries found on 

rivers and lakes with no flyovers of this area by contract pilots. APHIS would maintain a 

2.5 mile no aerial spray zone upstream and downstream from the nest site with a 0.25 

mile buffer along each side of the river. Lakes considered foraging areas would have 

0.25 mile no-aerial spray buffer. (FWS 06/01/87) 

Bull Trout, Salvelinus conjluentus 

Bull trout have been listed as threatened under the ESA. Within the area in Idaho 

included in the proposal, bull trout are distributed throughout the Salmon, Little Lost, 

Payette, Weiser, and Boise River systems. Bull trout naturally exhibit a patchy 

distribution, and will not likely occupy all areas of these basins at once. Proposed bull 

trout critical habitat is also distributed throughout these basins, and includes some habitat 

that is not currently known to be occupied. A very general description of bull trout 

distribution would include the North, Middle and South Fork Payette Rivers; Deadwood 

River; Squaw Creek; the Weiser River Watershed; the Little Lost River basin; the Main 

Boi8se and South Fork Boise River including Anderson Ranch, Arrowrock and Lucky 

Peak Reservoirs; the upper Salmon River; Lemhi river; Pahsimeroi River; Middle Fork 

and South Fork Salmon river; the Little/Lower Salmon river; and the Middle 

Salmon/Chamberlain and the Middle Salmon-Panther drainages. 

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In all areas occupied by bull trout or proposed as critical habitat for bull trout, APHIS 

will utilize a . mile buffer for all aerial sprays and a 500 foot buffer for carbaryl bait. If 

there are treatment needs within the buffer area, APHIS will consult with FWS on a caseby-case basis to examine alternatives. (FWS2003) 

Ute Ladies -Tresses, Spiranthes divuvalis 

Ute ladies'-tresses is listed as threatened under the ESA. This perennial orchid occurs in 

mesic or wet meadows and riparian/wetland habitats formed by springs, seeps, lakes, and 

streams from 1,500 to 7,000 feet in elevation. It is presently known from Colorado, 

Montana, Nebraska, Utah, Washington, Wyoming, and Eastern Idaho along the South 

Fork of the Snake River between Swan Valley and the confluence with the Henry s Fork. 

The South Fork populations were first discovered in 1996. A total of22 occurrences of 

Ute ladies'-tresses are currently known from Idaho. Surveys adjacent to the South Fork 

of the Snake River and other portions of the state have failed to discover additional Ute 

ladies'-tresses populations outside of the South Fork of the Snake River. The FWS 

considers the entire state ofldaho to be within the potential range ofthis species. Large 

and long-tongued bumblebees (Bombus morrisoni and B. fervidus) are the most important 

pollinators of Ute ladies'-tresses orchid. 

Along the South Fork Snake River and Henry's Fork River populations of Ute Ladies'-

Tresses, APHIS will utilize a 3-mile buffer for all aerial spray treatments. (FWS2003) 

Banbury Springs Limpet (lanx), Lanx sp.; Bliss Rapids Snail, Tay/orconcha 

serpentico/a; Utah Valvata Snail, Valvata utahensis; Idaho Springsnail, 

Fonte/ice/la idahoensis; and Snake River Physa Snail, Physa natricina 

These five listed mollusks either occupy aquatic habitat found in select springs or they 

occur on substrate in the main stem Snake River. 

The Banbury Springs limpet is known to occur at three sites in the Thousand Springs area 

near Hagerman, Idaho. It has only been found on cobble or boulder substrates in cool, 

clear, well-oxygenated water. All known populations have occurred in swift currents. 

The Bliss Rapids snail has primarily been found on cobble-boulder substrate in flowing 

reaches of the main stem Snake River and alcove springs. River populations have been 

found in spring-influenced habitat or near the edge of rapids. Most populations occur in 

the Hagerman Reach, the tailwaters of Bliss and Lower Salmon Falls dams, large alcove 

springs, and springs on the Fort Hall Indian Reservation upstream of American Falls 

Reservoir. 

The Utah valvata snail occurs in deep pools with a mud or sand substrate adjacent to 

rapids or in large perennial spring complexes. This snail has been found in a few springs 

and main stem Snake River sites in the Hagerman Valley, below American Falls 

downstream to Burley, Idaho and in the Lake Walcott and Minidoka Dam area. 

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The Idaho springsnail and the Snake River Physa snail are both main stem Snake River 

species which occur in a relatively short segment of the Snake River in the western 

portion of the proposed treatment area. 

In areas along the Snake River between C.J. Strike Reservoir and American Falls 

Reservoir APHIS will utilize a . mile buffer for all aerial sprays and a 500 foot buffer 

for carbaryl bait. If there are treatment needs within the buffer area, APHIS will consult 

with FWS on a case-by-case basis to examine alternatives. (FWS2003) 

Bruneau Hot Springsnail, Pyrgulopsis bruneauensis 

Adult Bruneau hot springsnails have a small shell that is 0.22 inches long. Fresh shells 

are thin and transparent. Because the shells are clear to white, the pigmentation 

underneath makes the snail appear black. This freshwater snail occurs in a 5-mile reach 

of the Bruneau River and the lower one-third of its tributary, Hot Creek, in Owyhee 

County, Idaho. The snail is native to geothermal springs and seeps with temperatures 

ranging from 15.7 to 36.9 degrees Celsius. It is found in these habitats on the exposed 

surfaces of various substrates including rocks, sand, gravel, mud, and algal films. 

This snail was first discovered in 1952 in upper Hot Creek, a tributary to the Bruneau 

River in southwest Idaho. It belongs to the family Hydrobiidae, and was formally 

described in 1990 as Pyrgulopsis bruneauensis, or more commonly, Bruneau hot 

springsnail. 

The principal threat to the springsnail is the reduction and/or elimination of their 

geothermal spring habitat as a result of agricultural groundwater withdrawals. 

Within the recovery area as defined in the final BHSS recovery plan, APHIS will utilize a 

. mile buffer for all aerial sprays and a 500 foot buffer for carbaryl bait. If there are 

treatment needs within the buffer area, APHIS will consult with FWS on a case-by-case 

basis to examine alternatives. (FWS2003) 

Grizzly Bear, Ursus arctos 

The grizzly bear has been Federally listed as a Threatened species. Habitat for the bear in 

the project area is primarily in the Island Park area. The acreage is relatively small but it 

could be important for a recovered population of bear. 

High impact unlikely as a result of proposed pesticides at proposed rates of application. 

(FWS 06/01/87) 

Gray Wolf, Canis lupus 

The gray wolf has been determined to be an endangered species. Since the translocation 

of wolves from Canada, the population in Idaho south oflnterstate Highway 90 is 

considered "experimental, non-essential" under Section 1 0(j) of the Endangered Species 

Act. Wolves range along the continental divide and into the Island Park area around 

Yellowstone National Park (YNP). Sightings of gray wolves have been made in diverse 

parts of the proposed suppression area. 

58 
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High impact unlikely as a result of proposed pesticides at proposed rates of application. 

(FWS 06/01/87) 

Canada Lynx, Lynx canadensis 

On March 24, 2000, the U. S. Fish and Wildlife Service listed the Canada lynx as a 

Threatened species under the ESA of 1973, as amended. This took effect on April 24, 

2000. The proposed treatment areas may contain habitat conditions suitable for Canada 

lynx foraging, movement and dispersal activities. In Idaho, lynx are thought to primarily 

occur in the higher elevation, cold forest habitats which support spruce, subalpine fir, 

whitebark pine and lodgepole pine. Shrub/steppe habitats which occur adjacent to, or are 

intermixed with, cold forest habitats in Idaho are thought to be used to a limited extent by 

lynx for foraging and dispersal activities. 

APHIS would not treat forested areas or rangelands that are not adjacent to crops but are 

surrounded by forest and are above 5000 feet in elevation in Idaho. (FWS2003) 

Chinook salmon, Oncorhynchus tshawytsha 

Along the U.S. West Coast, there are 17 distinct groups, or evolutionarily significant 

units (ESUs), of Chinook salmon, from Southern California to the Canadian border and 

east to the Rocky Mountains. Snake River spring/summer chinook and Snake River fall 

chinook were listed as threatened species in 1992. In 1994, Sacramento River winter-run 

chinook were listed as endangered. In March 1998, two ESUs were proposed as 

endangered, five proposed as threatened, and the Snake River fall-run ESU was proposed 

to include fall chinook salmon populations in the Deschutes River. 

Chinook salmon belong to the family Salmonidae and are one of eight species of Pacific 

salmonids in the genus Oncorhynchus. Chinook salmon are easily the largest of any 

salmon, with adults often exceeding 40 pounds; individuals over 120 pounds have been 

reported. Chinook salmon are anadromous (adults migrate from a marine environment 

into the fresh water streams and rivers of their birth) and semelparous (spawn only once 

and then die). 

There are different seasonal "runs" (i.e., spring, summer, fall, or winter) or modes in the 

migration of chinook salmon from the ocean to freshwater. These runs have been 

identified on the basis of when adult chinook salmon enter freshwater to begin their 

spawning migration. However, distinct runs also differ in the degree of maturation at the 

time of river entry, the thermal regime and flow characteristics of their spawning site, and 

their actual time of spawning. Freshwater entry and spawning timing are believed to be 

related to local temperature and water flow regimes. 

Adult female chinook will prepare a spawning bed, called a "redd", in a stream area with 

suitable gravel composition, water depth and velocity. The adult female chinook may 

deposit eggs in 4 to 5 "nesting pockets" within a single redd. After laying eggs in a redd, 

adult chinook will guard the redd from 4 to 25 days before dying. Chinook salmon eggs 

will hatch, depending upon water temperatures, between 90 to 150 days after deposition. 

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Eggs are deposited at a time to ensure that young salmon fry emerge during the following 

spring when the river or estuary productivity is sufficient for juvenile survival and 

growth. Juvenile chinook may spend from 3 months to 2 years in freshwater after 

emergence and before migrating to estuarine areas as smolts, and then into the ocean to 

feed and mature. Coastwide, chinook salmon remain at sea for 1to6 years (more 

commonly 2 to 4 years), with the exception of a small proportion of yearling males 

(called jack salmon) which mature in freshwater or return after 2 or 3 months in salt 

water. 

Among chinook salmon, two distinct races have evolved. One race, described as a 

"stream-type" chinook, is found most commonly in headwater streams. Stream-type 

chinook salmon have a longer freshwater residency, and perform extensive offshore 

migrations before returning to their natal streams in the spring or summer months. 

Stream-type juveniles are much more dependent on freshwater stream ecosystems 

because of their extended residence in these areas. A stream-type life history may be 

adapted to areas that are more consistently productive and less susceptible to dramatic 

changes in water flow. At the time of saltwater entry, stream-type (yearling) smolts are 

much larger, averaging 73-134 mm depending on the river system, than their ocean-type 

(subyearling) counterparts and are therefore able to move offshore relatively quickly. 

Stream-type chinook salmon are found migrating far from the coast in the central North 

Pacific. 

The second race is called the "ocean-type" chinook, which is commonly found in coastal 

streams in North America. Ocean-type chinook typically migrate to sea within the first 

three months of emergence, but they may spend up to a year in freshwater prior to 

emigration. They also spend their ocean life in coastal waters. Ocean-type chinook 

salmon return to their natal streams or rivers as spring, winter, fall, summer, and late-fall 

runs, but summer and fall runs predominate. Ocean-type chinook salmon tend to utilize 

estuaries and coastal areas more extensively for juvenile rearing. The development of the 

ocean-type life history strategy may have been a response to the limited carrying capacity 

of smaller stream systems and unproductive watersheds, or a means of avoiding the 

impact of seasonal floods. Ocean-type chinook salmon tend to migrate along the coast. 

Populations of chinook salmon south of the Columbia River drainage appear to consist 

predominantly of ocean-type fish. 

Salmonid species on the West Coast of the United States have experienced dramatic 

declines in abundance during the past several decades as a result of human-induced and 

natural factors. There is no single factor solely responsible for this decline. Given the 

complexity of the salmon species life history and the ecosystem in which they reside, it is 

difficult to precisely quantify the relative contribution of any one factor to the decline of 

a given species. Rather, given the available data, it is only possible to highlight factors 

which have significantly affected the status of a particular species. 

Water storage, withdrawal, conveyance, and diversions for agriculture, flood control, 

domestic, and hydropower purposes have greatly reduced or eliminated historically 

accessible habitat and/or resulted in direct entrainment mortality of juvenile salmonids. 

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Modification of natural flow regimes have resulted in increased water temperatures, 

changes in fish community structures, depleted flows necessary for migration, spawning, 

rearing, flushing of sediments from spawning gravels, gravel recruitment and transport of 

large woody debris. Physical features of dams, such as turbines and sluiceways, have 

resulted in increased mortality of both adults and juvenile salmonids. Attempts to 

mitigate adverse impacts of these structures have to date met with limited success. 

Natural resource use and extraction leading to habitat modification can have significant 

direct and indirect impacts to salmon populations. Land use activities associated with 

logging, road construction, urban development, mining, agriculture, and recreation have 

significantly altered fish habitat quantity and quality. Associated impacts of these 

activities include: alteration of stream banks and channel morphology; alteration of 

ambient stream water temperatures; degradation of water quality; reduction in available 

food supply; elimination of spawning and rearing habitat; fragmentation of available 

habitats; elimination of downstream recruitment of spawning gravels and large woody 

debris; removal of riparian vegetation resulting increased stream bank erosion; and 

increased sedimentation input into spawning and rearing areas resulting in the loss of 

channel complexity, pool habitat, suitable gravel substrate, and large woody debris. 

Studies indicate that in most Western States, about 80 to 90 percent of the historic 

riparian habitat has been eliminated. Further, it has been estimated that during the last 

200 years, the lower 48 United States have lost approximately 53 percent of all wetlands. 

Washington and Oregon's wetlands have been estimated to have been diminished by one 

third, while it is estimated that California has experienced a 91 percent loss of its 

wetland habitat. 

APHIS would exclude Salmon River watersheds and watersheds of the Snake River 

below Brownlee Dam from the proposed suppression area. 

Steelhead trout, Oncorhynchus mykiss 

Steelhead has the greatest diversity of life history patterns of any Pacific salmonid 

species, including varying degrees of anadromy, differences in reproductive biology, and 

plasticity of life history between generations. Within the range of West Coast steelhead, 

spawning migrations occur throughout the year, with seasonal peaks of activity. In any 

given river basin there may be one or more peaks of migration activity; since these runs 

are generally named for the season in which they occur, some rivers may have runs 

known as winter, spring, summer, or fall steelhead. For example, large rivers such as the 

Columbia, Rogue, and Klamath have migrating adult steelhead at all times of year. 

Through time, the names of seasonal runs have generally been simplified- in the Pacific 

Northwest, winter and summer steelhead runs are commonly identified. In Northern 

California, some biologists have retained the terms spring and fall steelhead to name what 

others would call summer steelhead. 

North American steelhead commonly spend 2 years in the ocean before entering 

freshwater to spawn. Summer steelhead enter fresh water up to a year prior to spawning. 

Steelhead may spawn more than once. In some cases, the separation between anadromous 

steelhead and rainbow or redband trout is obscured. 

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Hydropower development; water withdrawal, conveyance, storage, and flood control; 

land use activities such as logging, road construction, urban development, grazing, 

mining, agriculture; loss of large woody debris, riparian habitat, and increased 

sedimentation; commercial, recreational, and tribal harvest; ocean conditions; and 

artificial propagation activities are all factors for the decline of steelhead throughout its 

range. 

APHIS would exclude Salmon River watersheds and watersheds of the Snake River 

below Brownlee Dam from the proposed suppression area. 

Sockeye salmon, Oncorhynchus nerka. 

Along the U.S. West Coast, there are 7 distinct groups, or evolutionarily significant units 

(ESUs), of sockeye salmon. One of these ES Us, Snake River, was listed as endangered in 

November 1991. In March 1998, the Ozette Lake ESU was proposed as threatened and 

the Baker River ESU was designated as a candidate species. 

Sockeye salmon belong to the family Salmonidae and are one of seven species of Pacific 

salmonids in the genus Oncorhynchus. Sockeye salmon are anadromous, meaning they 

migrate from the ocean to spawn in fresh water. They are the third most abundant of the 

seven species of Pacific salmon, after pink and chum salmon. Unique in their appearance, 

the adult spawners typically turn bright red, with a green head, hence "red" salmon, as 

commonly called in Alaska. During the ocean and adult migratory phase sockeye often 

have a bluish back and silver sides, giving rise to another common name, "bluebacks." 

The name "sockeye" is thought to have been a corruption of the various Indian tribes' 

word "sukkai." 

Sockeye salmon exhibit a wide variety of life history patterns that reflect varying 

dependency on the fresh water environment. With the exception of certain river-type and 

sea-type populations, the vast majority of sockeye salmon spawn in or near lakes, where 

the juveniles rear for 1 to 3 years prior to migrating to sea. For this reason, the major 

distribution and abundance of large sockeye salmon stocks are closely related to the 

location of rivers that have accessible lakes in their watersheds for juvenile rearing. There 

are also 0. nerka life forms that are non-anadromous, meaning that most members of the 

form spend their entire lives in fresh water. Non-anadromous 0. nerka in the Pacific 

Northwest are known as kokanee. Occasionally, a proportion of the juveniles in an 

anadromous sockeye salmon population will remain in their rearing lake environment 

throughout life and will be observed on the spawning grounds together with their 

anadromous siblings. Taxonomically, the kokanee and sockeye salmon do not differ. 

On the Pacific coast, sockeye salmon inhabit riverine, marine, and lake environments 

from the Columbia River and its tributaries north and west to the Kuskokwim River in 

Western Alaska. 

APHIS would exclude Salmon River watersheds and watersheds of the Snake River 

below Brownlee Dam from the proposed suppression area 

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Northern Idaho Ground Squirrel, Spermophilus brunneus brunneus 

The northern Idaho ground squirrel is smaller than most ground squirrels at about 8-9" 

long. Reddish-brown spots dot its coat, and the squirrel has a short, narrow tail, tan feet 

and ears, and a grey-brown throat. This rare squirrel needs large quantities of grass seed, 

stems and other green leafy vegetation to store body energy for its eight-month 

hibernation from August through March. Adult males (2 years old) emerge from their 

burrows first in early spring, usually March or early April, followed by the females and 

then their young. 

In 1985, scientists estimated that over 5,000 ground squirrels inhabited west-central 

Idaho. The animals occurred in open meadows and shrub/grasslands among coniferous 

forests of older Ponderosa pines and Douglas fir. 

The northern Idaho ground squirrel's population has been greatly reduced, and today it is 

found within 20 square miles of public and private lands near Council, Idaho. At high 

risk of extinction, this animal has suffered a 92% decline in population from 1985 to 

1999. Fewer than 500 northern Idaho ground squirrels are estimated to be living at 

present. 

The major threat to the northern Idaho ground squirrel is habitat loss due to conifer 

invasion and fire suppression. Other potential threats include agricultural land 

conversion, urban development, recreational activities, and naturally occurring events 

such as severe droughts lasting longer than three years. 

Proposed Species 

Slickspot Peppergrass, Lepidium papi/liferum 

Slickspot peppergrass was included on the federal proposed list in 2002. This annual or 

biennial forb occurs in sagebrush-steppe habitats in southwest Idaho, where it typically 

grows on micro sites known as slick spots. It is presently known from approximately 

45 to 60 sites in Idaho. Many of these sites are adjacent to agricultural lands that have 

previously been sprayed, especially in the Kuna area. 

The pollinators of slickspot peppergrass are unknown. Robertson and Klemash (2003) 

reported that 25 insect families from five orders visited flowers, and that seed set is 

reduced when insects are excluded from flowers. Robertson (2003) suggests that the 

apparent reliance of slickspot peppergrass on insect-mediated pollination has significant 

consequences for the long term viability of the species because of the isolated 

occurrences of populations. 

Gravity, wind, and water are all believed to play at least some role in seed dispersal. It is 

possible that ants do as well, since slickspots are occasionally associated with anthills. 

APHIS would utilize a 3-rnile buffer for all aerial spray treatments around known sites as 

defined by the land management agencies. (FWS2003) 

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Candidate Species 

Columbia Spotted Frog, Rana luteiventris 

The spotted frog is olive green to brown in color, with irregular black spot. They may 

have white, yellow, or salmon coloration on the underside of the belly and legs. Tadpoles 

are black when small, changing to a dark then light brown as they increase in size. 

Spotted frogs are about one inch in body length at metamorphosis, can attain a length of 

four inches as adults, and can live more than ten years. They begin reproducing in their 

second or third year. Softball-sized egg masses are deposited in shallow, calm water in 

March and April, depending on weather and climate. Tadpoles hatch two to three weeks 

later, eventually moving from breeding sites to any connected wet areas and feeding on 

algae, plant material and detritus. Tadpoles transform into small juvenile frogs between 

late July and November, at which time they forage on tiny insects before seeking shelter 

for winter hibernation. 

Spotted frogs live in spring seeps, meadows, marshes, ponds and streams, usually where 

there is abundant vegetation. They often migrate along riparian corridors between 

habitats used for spring breeding, summer foraging, and winter hibernation. Depending 

on climate and habitat conditions, spotted frogs may begin seeking overwinter sites as 

early as September. Springs, cutbanks, and willow roots provide quality habitat for 

hibernacula that are well-oxygenated and stable in temperature. 

Prior to 1997, the Columbia spotted frog and the Oregon spotted frog, Rana pretiosa, 

were lumped into one species, Rana pretiosa. Additional genetic information indicated 

that they are two separate species. Columbia spotted frogs have been further divided into 

four populations, including the Great Basin population. The Great Basin population is 

found in Eastern Oregon, Southwestern Idaho, and Nevada. In Idaho, it occurs in the midelevations of the Owyhee uplands and in Southern Twin Falls County. 

Threats to the Great Basin population of Columbia spotted frogs include grazing, spring 

development, road and trail construction, water diversion, fire in riparian corridors, 

pesticides, disease, and the introduction of non-native fish. Increasing habitat 

fragmentation due to activities that reduce riparian connectivity makes local populations 

vulnerable to extirpation. 

APHIS would utilize buffers around all water bodies to provide protection for this 

candidate species. (FWS2003) 

Southern Idaho Ground Squirrel, Spermophilus brunneus endemicus 

The Southern Idaho ground squirrel is about 8-9" long, with a short, narrow tail, tan feet 

and ears, and a grey-brown throat. This small-eared mammal differs from a similar 

subspecies the Northern Idaho ground squirrel in pelage coloration. The southerns have a 

noticeably paler coat than the northerns, which is attributed to the lower-elevation, 

sagebrush/grassland habitat in which it lives. The granitic sands and clays of the Weiser 

River Basin are thought to influence the Southern Idaho ground squirrel's lighter 

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coloration, while the deeper reddish-colored northerns are found in higher-elevation areas 

with shallow reddish soils of basaltic origin. Research suggests that the squirrels prefer 

areas with a high percentage of native cover such as big sagebrush, bitterbrush and a 

variety of native forbs and grasses; however, some nonnative features may enhance their 

survival such as alfalfa fields, haystacks or fence lines. 

These squirrels spend much of their time underground. Adults emerge from seasonal 

hibernation in late January or early February, depending on elevation and habitat 

conditions. As with other ground squirrels in the Northwest, the adults have a short 

active season aboveground of 4 to 5 months. During this.time, the animals feed on large 

quantities of grass seed, sterns and green leafy vegetation which are required for storage 

of fat to survive long months of hibernation. When squirrels emerge from their burrows, 

they begin breeding; young are born about three weeks later and emerge from the nest 

burrow in about 50 days. The ground squirrels cease their above-ground activity by late 

June or early July to return to their burrows for hibernation. 

During the past 30 years, a dramatic population decline of Southern Idaho ground 

squirrels has occurred. Surveys indicate a precipitous decline in squirrel populations since 

the mid-l 980s. In 1985, one study estimated the population at around 40,000. A 1999 

survey of 145 of the 180 known historical population sites indicated that only 53 sites (37 

percent) were still occupied. Furthermore, 52 of the 53 sites had what biologists 

characterized as "remarkable low levels of activity". The Southern Idaho ground squirrel 

occurs within an 810-square mile area (Gem, Payette and Washington counties). 

Threats to Southern Idaho ground squirrels include exotic grasses and weeds, habitat 

fragmentation, direct killing from shooting, trapping or poisoning, predation, competition 

with Columbian ground squirrels (Spermophilus columbianus), and inadequacy of 

existing regulatory mechanisms to protect the species or its habitat. Most of these threats 

occur throughout the range of the species. 

APHIS would utilize diflubenzuron, in all practicable cases, where treatments might be 

required within the area of concern for southern Idaho ground squirrel. When use of 

diflubenzuron is not practicable, APHIS will consult with FWS to address site-specific 

concerns. (FWS2003) 

Yellow-billed cuckoo, Coccyzus americanus 

The yellow-billed cuckoo is a secretive, robin-sized songbird that lives in the Western 

United States in willow and cottonwood forests along rivers and streams. The birds are 

generally absent from heavily forested areas and large urban areas. Yellow-billed 

cuckoos primarily eat large insects such as caterpillars and cicadas, as well as an 

occasional small frog or lizard. Cuckoos usually lay two or three eggs, and the young 

develop very rapidly. On average, it takes 17 days from egg-laying to fledging of young. 

Yellow-billed cuckoos breed from southern Canada south to the Greater Antilles and 

Mexico. While the yellow-billed cuckoo is common east of the Continental Divide, 

biologists estimate that more than 90 percent of the bird's riparian habitat in the West has 

been lost or degraded as a result of conversion to agriculture, dams and riverflow 

65 
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management, bank protection, overgrazing, pesticide use, and competition from exotic 

plants such as tamarisk. 

Populations have declined rapidly throughout the western U.S. in the twentieth century, 

and are extirpated from British Columbia, Washington, and possibly Nevada. In Idaho, 

the species is considered a rare visitor and breeder in the Snake River Valley, occurring 

in ten of the counties within the proposed suppression area. 

Because the birds are primarily found in riparian areas, potential threats include 

conversion of this habitat to agriculture, dams and riverflow management, bank 

protection, livestock overgrazing, agricultural water use, pesticide use, and competition 

from exotic plants. 

APHIS would utilize buffers around all water bodies to provide protection for this 

candidate species. (FWS2003) 

Christ's paintbrush, Castilleja christii 

Christ's paintbrush is about 5 to 15 inches tall, and it has brilliant yellow-orange flowers. 

This plant grows best in moist, gently-sloping subalpine meadows, and it reproduces by 

seed. Plant growth begins around snowrnelt time, leading to peak flowering from July to 

mid-September. 

John Christ first collected this plant in 1950 from the Albion mountain range in Cassia 

County, Idaho. Noel Holmgren and Jim Reveal collected it again in 1966. After 

Holmgren formally described the plant in 1973, Christ's paintbrush was recognized as a 

new species named in honor of its first collector, John Christ 

This plant is found only on lands managed by the Sawtooth National Forest in the high 

elevations of the Albion Mountains in Cassia County, Idaho. Only one population of the 

plant is known to exist 

Road construction and maintenance, off-road vehicle use, livestock grazing, recreational 

activities such as hang gliding and hiking, and trampling all have adverse effects on 

Castilleja christii. 

The FS is working with the local hang gliding club to reduce impacts from trampling and 

vehicles on Christ's paintbrush, since the area is a very popular launch site for hang 

gliders. Signs that inform the public of the fragile nature of subalpine communities are 

also being developed by the Forest Service. Vehicle travel is restricted to existing roads, 

some of which have been improved to allow for easier travel, as well as to minimize 

impacts from off-road vehicle use. 

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Species under Review by U.S. Fish and Wildlife Service or Petitioned For Listing as 

T&E 

Columbian Sharp-tailed Grouse and Sage Grouse 

Both of these grouse species are BLM listed sensitive species. The Columbian sharptailed grouse has been petitioned for listing under the ESA. On February 7, 2003, FWS 

found that the Western subspecies of sage grouse is not eligible for federal protection 

under ESA. Young grouse hatch in the spring at about the same time as grasshopper or 

Mormon cricket populations begin to mature. Insects are a critical source of protein for 

the young birds. Large grasshopper or Mormon cricket populations are common in the 

critical habitat of both species. 

Bonneville Cutthroat Trout and Yellowstone Cutthroat Trout 

Both the Bonneville cutthroat trout and Yellowstone cutthroat trout are currently 

petitioned for listing as threatened under the ESA. The Bonneville cutthroat trout is 

limited to the Bear River watershed. The Yellowstone cutthroat trout is believed to 

occupy a number of streams scattered across Eastern Idaho. Their current distribution is 

under investigation. 

Mulford s Milkvetch, Woven-Spore Lichen, and Malheur Princesplume 

These plants are currently under review by the FWS for listing as federal candidate 

species. 

Mulford s milkvetch is endemic to Southwest Idaho and extreme Southeast Oregon, 

where it grows in deep sandy soils. It is typically associated with bitterbrush, needle-andthread grass, and Indian ricegrass. In Idaho, Mulford s milkvetch is known from Ada, 

Owyhee, Payette, and Washington counties. While no information is available regarding 

its pollination biology, Mulford s milkvetch is believed to be insect pollinated. Seed 

dispersal is most likely by gravity and wind. 

Woven-spore lichen grows on humus in sagebrush-steppe habitats in Southwest Idaho, 

Central Oregon, and Southern Washington. Several localities are also known from 

Southern California. Woven-spore lichen has been found at 14 localities in Idaho, all 

within Ada and Elmore counties. Most of the sites are adjacent to or are surrounded by 

private land. Nothing is known of its reproductive or dispersal mechanisms. 

The FWS initiated a status review for Malheur princes-plume in 2000. This showy, 

three foot tall biennial plant species is known from six widely scattered localities in 

Gooding, Owyhee and Washington counties in southwest Idaho. It grows only on 

sparsely vegetated clay soils. Approximately 15 populations of Malheur prince s-plume 

are known from southeast Oregon in Hamey and Malheur county. A variety of bees and 

beetles have been observed visiting the flowers, but no pollination studies have been 

conducted. 

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Table 3. Protection Measures and Determinations for Special Status Species 

Bald Eagle (T) I-mile radius treatment-free zone around active aeries 

found on rivers and lakes with no flyovers of this area by 

Not likely to adversely affect contract pilots. Maintain a 2.5 mile no aerial spray zone 

(NLAA) upstream and downstream from the nest site with a 0.25 

mile buffer along each side of the river. Lakes considered 

foraging areas would have 0.25 mile no-aerial spray buffer. 

(FWS 06/01/87) 

Bull Trout (T) In all areas proposed as critical habitat for bull trout, 

APHIS will utilize a . mile buffer for all aerial sprays and 

NLAA a 500 foot buffer for carbaryl bait. Ifthere are treatment 

needs within the buffer area, APHIS will consult with FWS 

on a case-by-case basis to examine alternatives. (FWS 

2003) 

Ute Ladies' -Tresses (T) Along the South Fork snake River and Henry's Fork River 

populations of Ute Ladies'-Tresses, APHIS will utilize a 3-

NLAA mile buffer for all aerial spray treatments. (FWS 2003) 

Banbury Springs Limpet In areas along the Snake River between C.J. Strike 

(lanx) (E), Bliss Rapids Snail Reservoir and American Falls Reservoir APHIS will utilize 

(T), Utah Valvata Snail (E), a . mile buffer for all aerial sprays and a 500 foot buffer 

Idaho Springsnail (E), Snake for carbaryl bait. If there are treatment needs within the 

River Physa Snail (E) buffer area, APHIS will consult with FWS on a case-bycase basis to examine alternatives. (FWS 2003) 

NLAA 

Bruneau Hot Springsnail (E) Within the recovery area as defined in the final BHSS 

recovery plan, APHIS will utilize a . mile buffer for all 

NLAA aerial sprays and a 500 foot buffer for carbaryl bait. If 

there are treatment needs within the buffer area, APHIS 

will consult with FWS on a case-by-case basis to examine 

alternatives. (FWS 2003) 

Grizzly Bear (T) High impact unlikely as a result of proposed pesticides at 

proposed rates of application. (FWS 06/01/87) 

No Effect (NE) 

Gray Wolf (E) (experimental) High impact unlikely as a result of proposed pesticides at 

proposed rates of application. (FWS 06/01/87) 

NLAA 

Canada Lynx (T) APHIS would not treat forested areas or rangelands that are 

not adjacent to crops but are surrounded by forest and are 

NE above 5000 feet in elevation in Idaho. (FWS 2003) 

Chinook salmon (T) APHIS would exclude Salmon River watersheds and 

watersheds of the Snake River below Brownlee Dam from 

NE the proposed suppression area. 

Steelhead trout (T) APHIS would exclude Salmon River watersheds and 

watersheds of the Snake River below Brownlee Dam from 

NE the proposed suppression area. 

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Sockeye salmon (T) (E) APHIS would exclude Salmon River watersheds and 

watersheds of the Snake River below Brownlee Dam from 

NE the proposed suppression area. 

Slickspot Peppergrass (P) APHIS would utilize a 3-mile buffer for all aerial spray 

treatments around known sites as defined by the land 

NLAA management agencies. (FWS 2003) 

Northern Idaho Ground APHIS would exclude from the proposed suppression area 

Squirrel (T) the land described by FWS as North Idaho Ground Squirrel 

recovery area. 

NE 

Table 3.1 Protective Measures for Candidate Species 

Columbia Spotted Frog (C) Insecticide application rates would be reduced below 

Southern Idaho Ground 

Squirrel (C) 

Yellow-billed cuckoo (C) 

Christ's paintbrush (C) 

EPA maximum allowable rates. Percentage of EPA 

maximum allowable rates which would be applied: 

carbaryl spray 25% 

carbaryl bait 10% to 25% 

difubenzuron spray 75% 

malathion spray 34% 

Additionally, treatment blocks would not receive full 

area coverage. 25% to 90% of treatment block would 

not receive direct application. 

Aerial sprays of diflubenzuron, carbaryl and malathion 

would not be made within . mile of waters of the U.S. 

including rivers, tributaries, streams, reservoirs, and 

wetlands. Aerial applications of carbaryl bait would not 

be made within 500 feet of such waters. (FWS 2003) 

Aerial applications of insecticides would not be made 

within 500 feet of any water including canals and 

ditches. Ground applications of insecticides would not 

be made within 50 feet of any water. (FWS 2003) 

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Table 3.2 Protective Measures for Species Under Review (Sensitive Species) 

Bonneville Cutthroat Trout Insecticide application rates would be reduced below 

Yellowstone Cutthroat Trout EPA maximum allowable rates. Percentage of EPA 

and Redband Trout (S) maximum allowable rates which would be applied: 

Mulford's Milkvetch, WovenSpore Lichen, Malheur 

Princesplume, Mourning 

Milkvetch, Picabo Milkvetch, 

Snake River Milkvetch, 

Janish s Penstemon, Matted 

Cowpie Buckwheat, and St. 

Anthony Evening Primrose 

(S) 

Western Burrowing Owl, 

Northern Harrier, Upland 

Game Birds and the 

Swainson s Hawk (S) 

Western Toad, Woodhouse s 

Toad, and Northern Leopard 

Frog (S) 

Western Ground Snake, 

Longnose Snake and 

Common Garter Snake (S) 

Townsend s Big Eared Bat, 

Spotted Bat, Western Smallfooted Myotis, Long Eared 

Myotis, Fringed Myotis, 

Long-legged Myotis, Western 

Pipistrelle, and Yuma Myotis 

(S) 

Kit Fox (S) 

carbaryl spray 25% 

carbaryl bait 10% to 25% 

difubenzuron spray 75% 

malathion spray 34% 

Additionally, treatment blocks would not receive full 

area coverage. 25% to 90% of treatment block would 

not receive direct application. 

Aerial sprays of diflubenzuron, carbaryl and malathion 

would not be made within . mile of waters of the U.S. 

including rivers, tributaries, streams, reservoirs, and 

wetlands. Aerial applications of carbaryl bait would not 

be made within 500 feet of such waters. (FWS 2003) 

Aerial applications of insecticides would not be made 

within 500 feet of any water including canals and 

ditches. Ground applications of insecticides would not 

be made within 50 feet of any water. (FWS 2003) 

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Columbian Sharp-tailed Insecticide application rates would be reduced below 

Grouse and Sage Grouse (S) EPA maximum allowable rates. Percentage of EPA 

maximum allowable rates would be: 

Loggerhead Shrike, Gray carbaryl spray 25% 

Flycatcher, Brewers Sparrow, carbaryl bait 10% to 25% 

Grasshopper Sparrow, and difubenzuron spray 75% 

Sage Sparrow (S) malathion spray 34% 

Treatment blocks would not receive full area coverage. 

Pygmy rabbit (S) 25% to 90% of area with 15% or more shrub cover 

within a treatment block would not receive direct 

Short-homed Lizard and application of insecticide. 

Mojave Black-collared Lizard 

(S) No strip of land more than 300 feet wide would receive 

direct application of insecticide. 

Idaho Dunes Tiger Beetle and No applications of malathion or carbaryl spray would be 

Columbia River Tiger Beetle made within one mile of known populations. 

(S) 

Idaho Pointheaded No applications of insecticide would be made within one 

Grasshopper (S) mile of known populations. 

8. Environmental Monitoring 

Monitoring involves the evaluation of various aspects of the grasshopper suppression 

programs. There are three aspects of the programs that may be monitored. The first is 

the efficacy of the treatment. APHIS would determine how effectively the application of 

an insecticide has suppressed the grasshopper population within a treatment area and 

would report the results to the APHIS Western Region and to the land manager. 

The second area included in monitoring is safety. This includes ensuring the safety of the 

program personnel through medical monitoring conducted specifically to identify 

sensitive or overexposed individuals. (See APHIS Safety and Health Manual (USDA, 

APHIS, 1998) available online at: www.aphis.usda.gov/mb/aseu/shes/shes-manual.html ). 

The third area of monitoring is environmental monitoring. APHIS Directive 5640.1 

commits APHIS to a policy of monitoring the effects of Federal programs on the 

environment. Environmental monitoring includes such activities as checking to make 

sure the insecticides are applied in accordance with the labels, and that sensitive sites and 

organisms are protected. The environmental monitoring recommended for grasshopper 

suppression programs involves monitoring sensitive sites such as bodies of water used for 

human consumption or recreation or which have wildlife value, habitats of endangered 

and threatened species, habitats of other sensitive wildlife species, edible crops, and any 

sites for which the public has expressed concern or where humans might congregate (e.g., 

schools, parks, hospitals). 

71 
ID-PPQ-G H2003-001 

VI. Literature Cited 

Adams, J.S., Knight, R.L., McEwen, L.C., and George, T.L., 1994. Survival and growth 

of nestling vesper sparrow exposed to experimental food reductions. The Condor 

96:739-748. 

Beyers, D.W., Farmer, M.S., and Sikoski, P.J., 1995. Effects ofrangeland aerial 

application of Sevin-4-0il® on fish and aquatic invertebrate drift in the Little 

Missouri River, North Dakota. Archives of Environmental Contamination and 

Toxicology 28:27-34. 

Blus, Lawrence J. et al. 1989. Effects of Organophosphorus Insecticides on Sage Grouse 

in Southeastern Idaho. Journal of Wildlife Management. 53(4): 1139-1146. 

Catangui, M.A., Fuller, B.W., and Walz, A.W., 1996. Impact of Dimilin® on nontarget 

arthropods and its efficacy against rangeland grasshoppers. In U.S. Department of 

Agriculture, Animal and Plant Health Inspection Service, 1996. Grasshopper 

Integrated Pest Management User Handbook, Tech. Bul. No. 1809. Sec. VII.3. 

Washington, DC. 

Connelly, J. W. 1994. Sage Grouse Ecology. Proj. no. W-160-R-21, Completion Report 

Idaho Department of Fish and Game. 90pp. 

Cowan, Frank T. 1929. Life History, Habits and Control of the Mormon Cricket. United 

States Department of Agriculture, Washington D.C. Technical Bulletin No. 161 

Crowley, Caroline M. & Connelly, John W. 1997. Trends in Agricultural Lands in Sage 

Grouse Range in Southeast Idaho and Southwest Montana. Idaho Department of 

Fish and Game. 

Dobroski, C.J., O'Neill, E.J., Donohue, J.M., and Curley, W.H., 1985. Carbary!: a profile 

of its behavior in the environment. Roy F. Weston, Inc., West Chester, PA, and V.J. 

Ciccone and Associates, Inc., Woodbridge, VA. 

Eisler, R., 2000. Handbook of chemical risk assessment: health hazards to humans, 

plants, and animals. Lewis Publishers, New York. 

Emmett, B.J., and Archer, B.M, 1980. The toxicity of diflubenzuron to honey bee (Apis 

melifera L) Colonies in apple orchards. Plant Pathology 29:637-183. 

EPA- see U.S. Environmental Protection Agency 

Hazardous Substances Database, 1990. On-line database. National Library of Medicine, 

Bethesda, MD. 

HSDB - see Hazardous Substances Database 

72 
ID-PPQ-GH2003-001 

Howe, Frank P., et al. 2000. Diet Switching and Food Delivery by Shrubsteppe 

Passerines in Response to an Experimental Reduction in Food. Western 

North American Naturalist 60: 139-154. 

La Rivers, Ira 1944. A summary of the Mormon Cricket (Anabrus simplex) 

(Tettigoniidae: Orthoptera). Entomological News. Vol. LV, No. 3:71-102. 

Martin, Pamela A., et al. 2000. Effects of Two Grasshopper Control Insecticides on 

Food Resources and Reproductive Success of Two Species of Grassland 

Songbirds. Environmental Toxicology and Chemistry Vol. 19. No. 12: 2987-2996. 

Mayer, F.L., Jr, and Ellersieck, M.C., 1986. Manual of acute toxicity: interpretation and 

data base for 410 chemicals and 66 species of freshwater animals. Resource 

Publication 160. Department of the Interior, Fish and Wildlife Service, Washington, 

DC. 

McEwen, L.C., Althouse, C.M., and Peterson, B.E., 1996a Direct and indirect effects of 

grasshopper integrated pest management (GHIPM) chemicals and biologicals on 

nontarget animal life. In U.S. Department of Agriculture, Animal and Plant Health 

Inspection Service, 1996. Grasshopper Integrated Pest Management User Handbook, 

Tech. Bul. No. 1809. Sec. IIl.2. Washington, DC. 

McEwen, L.C., Petersen, B.E., and Althouse, C.M.,1 996b. Bioindicator species for 

evaluating potential effects of pesticides on threatened and endangered wildlife. In 

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 1996. 

Grasshopper Integrated Pest Management User Handbook, Tech. Bul. No. 1809. Sec. 

III.7. Washington, DC. 

McEwen, Lowell C. et al. 1972. Wildlife Effects from Grasshopper Insecticides Sprayed 

on Short-Grass Range. Journal of Range Management. 25(3): 188-194. 

Opdycke, J.C., Miller, R.W., and Menzer, R.E., 1982. Metabolism and fate of 

diflubenzuron in swine. Journal of Agricultural Food and Chemistry 30:1223-1227. 

Paige, Christine & Ritter, Sharon A. 1999. Birds in a Sagebrush Sea: Managing 

Sagebrush Habitats for Bird Communities. Partners in Flight, Western Working 

Group. 

Quinn, M.A., 1996. Impact of control programs on nontarget arthropods. In U.S. 

Department of Agriculture, Animal and Plant Health Inspection Service, 1996. 

Grasshopper Integrated Pest Management User Handbook, Tech. Bul. No. 1809. Sec. 

IIl.3. Washington, DC. 

Robertson, Ian. 2003. The Importance of Outcrossing for Fruit Production in Slickspot 

Peppergrass, Lepidium papilliferum L. (Brassicaceae). Submitted: Western North 

American Naturalist. 

73 
ID-PPQ-GH2003-001 

Robertson, lan and Klemash, Danielle. 2003. Insect Mediated Pollination in Slickspot 

Peppergrass, Lepidium papilliferum L. (Brassicaceae ), and its Implications for 

Population Viability. In Press: Western North American Naturalist. 

Schroeder, W.J., Sutton, R.A., and Beavers, L.B., 1980. Diaprepes abbreviatus: Fate of 

diflubenzuron and effect on nontarget pest and beneficial species after application to 

citrus for weevil control. J. Econ. Entomol. 73:637-638. 

Skold, M.D. and Davis, R.M., 1995. A Rangeland Grasshopper Insurance Program. 

Journal of Agricultural and Resource Economics. 20(1):1-10. 

Tsuda, T., Aoki, S., Kojima, M., and Harada, H., 1989. Bioconcentration and excretion 

of diazinon, IBP, malathion, and fenitrothion by willow shiner. Toxicology and 

Environmental Chemistry 24: 185- 190. 

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 1998. 

Safety and health manual. Safety, Health, and Environmental Staff, Riverdale, MD. 

February 28, 1998. [online] available: 

http://www.aphis.usda.gov/mb/aseu/shes/shes-manual.html. 

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 1999. 

APHIS Directive 5600.3, Evaluating APHIS programs and activities for ensuring 

protection of children from environmental health risks and safety risks. September 

3, 1999. U.S. Department of Agriculture, Animal and Plant Health Inspection 

Service, Riverdale, MD. [online] available: 

http://www.aphis.usda.gov/library/directives. 

U.S. Environmental Protection Agency, 1993. Carcinogenicity peer review of carbaryl, 

1-napthyl n-methylcarbamate. MRID 421889-01, 02. Memorandum from Ray 

Landolt, Toxicological Branch II, October 7, 1993, 35 pp 

U.S. Environmental Protection Agency, 2000. Cancer Assessment Document #2. 

Evaluation of the carcinogenic potential of malathion. Report of the 12 April 2000 

meeting and its 29 attachments. April 28, 2000. U.S. Environmental Protection 

Agency, Washington, DC. 

74 
ID-PPQ-GH2003-001 

VII. Listing of Agencies and Persons Consulted 

Albiston, Daryl, Four Rivers Field Manager, Four Rivers Field Office, Lower Snake 

River District, Bureau of Land Management, Dept. of Interior, 3948 Development 

Ave., Boise, ID 83 705 

Artimez, Debbie, National Oceanic and Atmospheric Administration, 10215 W. Emerald, 

Suite 180, Boise, ID 83704 

Bartels, Peggy, Wildlife Biologist, Burley Field Office, Upper Snake River Dist., Bureau 

of Land Management, Dept. oflnterior, 15 East 200 South, Burley, ID 83318 

Beaulieu, Jane, Boise National Forest Headquarters, Forest Service, US Dept. of 

Agriculture, 1249 S. Vinnell Way, Suite 200, Boise, ID 83709 

Burch, Susan, Contaminant Specialist, Snake River Basin Office, U.S. Fish and Wildlife 

Service, U.S. Dept. of The Interior, 1387 S. Vinnell Way, Suite 368, Boise, ID 

83709 

Cain, Pat, Weed Specialist, Lower Snake River District, Bureau of Land Management, 

Dept. oflnterior, 3948 Development Ave., Boise, ID 83705 

Carrigan, Tim, Wildlife Biologist, Four Rivers Field Office, Lower Snake River District, 

Bureau of Land Management, Dept. oflnterior, 3948 Development Ave., Boise, 

ID 83705 

Clark, James, Wildlife Management Biologist, Lower Snake River District, Bureau 

Land Management, Dept. oflnterior, 3948 Development Ave., Boise, ID 83705 

Cook, Leroy, Resource Coordinator, Upper Snake River District, Bureau of Land 

Management, Dept. of Interior, 1405 Hollipark Dr., Idaho Falls, ID 83401 

Cooper, Mike, Acting Administrator, Plant Industries Division, Idaho State Department 

of Agriculture, 2270 Old Penitentiary Rd., PO Box 790, Boise, ID 83709 

DeBolt, Ann, Botanist, Four Rivers Field Office, Lower Snake River District, Bureau of 

Land Management, Dept. oflnterior, 3948 Development Ave., Boise, ID 83705 

Foss, Jeff, Snake River Basin Office, U.S. Fish and Wildlife Service, U.S. Dept. of 

Interior, 1387 S. Vinnell Way, Suite 368, Boise, ID 83709 

Foster, Jon, Supervisor Resource Manager, State Office, Bureau of Land Management, 

Dept. oflnterior, 1387 S. Vinnell Way, Boise, ID 83709 

Grover, Jack, Production Specialist, Farm Service Agency, US Dept. of Agriculture, 

9173 W. Barnes Dr., Suite B, Boise, ID 83709 

75 
ID-PPQ-GH2003-001 

Grows, Walt, Range Specialist, Caribou Office, Forest Service, US Dept. of 

Agriculture, 1405 Hollipark Dr., Idaho Falls, ID 83401 

Haas, Alison, Acting Supervisor, Snake River Fish and Wildlife Office, US Dept. of 

Interior, 1387 S. Vinnell Way, Room 368, Boise, ID, 83709 

Johnson, David N., Refuge Manager, Benton Lake National Wildlife Refuge, U.S. Fish 

& Wildlife Service, U.S. Dept. oflnterior, 922 Bootlegger Trail, Great 

Falls, MT 59404 

Just, Charles K., Environmental Planner, Idaho Transportation Department, P.O. Box 

7129, Boise, ID, 83707 

Lyle, Carol, Ecosystem Planning, Caribou Office, Forest Service, US Dept. of 

Agriculture, 1405 Hollipark Dr., Idaho Falls, ID 83401 

Mcfarling, Russell, Resource Coordinator, Upper Snake River District, Bureau of Land 

Management, Dept. of Interior, 1405 Hollipark Dr., Idaho Falls, ID 83401 

Newman, Ryan, National Resource Specialist, U.S. Bureau of Reclamation, U.S. Dept. of 

Interior, 1359 Hanson Ave., Burley, ID 83318 

Nutt, James, National Oceanic and Atmospheric Administration, 10215 W. Emerald, 

Suite 180, Boise, ID 83 704 

Paris, Sharon, Planning Coordinator, State Office, Bureau of Land Management, Dept. 

oflnterior, 1387 S. Vinnell Way, Boise, ID 83709 

Ririe, Warren, Range Conservationist, Boise National Forest Headquarters, Forest 

Service, US Dept. of Agriculture, 1249 S. Vinnell Way, Suite 200, Boise, ID 

83709 

Seufer, Jo Lynn, Risk Management Specialist, Spokane Regional Office, Risk 

Management Agency, US Dept. of Agriculture, 112 N. University Road, Suite 

205, Spokane, WA 99206 

Smith, Dick, Forest Supervisor, Intermountain Region, Forest Service, U.S. Dept. 

Agriculture, 1249 S. Vinnell Way, Suite 200, Boise, ID 83709 

Trent, Tracey, Chief, Natural Resources Policy Bureau, Idaho Fish and Game, 600 S. 

Walnut, P.O. Box 25, Boise, ID, 83707 

Womack, Kendra, Snake River Basin Office, U.S. Fish and Wildlife 

Service, U.S. Dept. oflnterior, 1387 S. Vinnell Way, Suite 368, Boise, ID 

83709 

76 
. . 

. 
ID-PPQ-GH2003-00 l 

Appendix 1: FY-2003 Guidelines for Treatment of Rangeland for the Suppression 

of Grasshoppers and Mormon Crickets 

Suppression Treatment on Federally Managed Rangeland 

Subject to available funding, the United States Department of Agriculture, Animal and 

Plant Health Inspection Service, Plant Protection and Quarantine (USDA-APHIS-PPQ) 

contributes to the control of grasshoppers and Mormon crickets (GH&MC) on federal 

rangeland in three program areas: (1) conducts field surveys of GH&MC populations, (2) 

provides technical assistance to landowners, and (3) participates in suppression 

treatments when necessary. USDA-APHIS-PPQ, at the request of the Federal land 

management agency (and Tribal authority when appropriate) and subject to available 

funding, may conduct GH&MC suppression treatments on federally managed rangeland 

or rangeland held in Trust by the federal government, in situations when traditional 

practices of land managers fail to maintain populations below economic thresholds. 

Rangeland eligible for cooperative GH&MC suppression treatments include: (1) large 

rangeland blocks (i.e., .10,000 acres) that if treated would protect forage as well as 

prevent re-infestation from immigrants; (2) incipient populations ("hot spots"), especially 

MC, that iftreated would prevent a wider spread of outbreaks; and (3) Federal or Trust 

land borders that if treated would prevent the movement of economic populations of 

GH&MC to adjacent private agricultural lands. The final determination of whether a 

cooperative suppression treatment on federal rangeland is warranted will be made by 

USDA-APHIS-PPQ, following receiving the landowner's written request and based on 

the best available information. 

Suppression Treatments on State and Private Rangeland 

Subject to available funding, the USDA-APHIS-PPQ contributes to the control of 

GH/MC on State and private rangeland in three program areas: (1) conducts field surveys 

of GH/MC populations, (2) provides technical assistance to landowners, and (3) 

participates in suppression treatments when necessary. USDA-APHIS-PPQ, at the 

request of the State Department of Agriculture and subject to available funding, may 

conduct GH/MC suppression programs on State and private managed rangeland, in 

situations when traditional practices of land managers fail to maintain populations below 

economic thresholds. State and private rangeland eligible for cooperative GH/MC 

suppression programs include: (1) large rangeland blocks (i.e., .10,000 acres) that if 

treated would protect forage, as well as prevent re-infestation from immigrants; and (2) 

incipient populations ("hot spots"), especially MC, that if treated would prevent a wider 

spread of outbreaks. However, USDA-APHIS-PPQ will not conduct cooperative 

suppression programs for GH&MC on private cropland nor on private rangeland borders 

for crop protection. The final determination of whether a cooperative suppression 

treatment on State and private rangeland is warranted will be made by USDA-APHISPPQ, following receiving the State's written request and based on the best available 

information. 

A-1-1 
ID-PPQ-GH2003-001 

General Guidelines for Suppression Programs on Rangeland 

1. Cooperative suppression treatments will be completed in accordance with the Plant 

Protection Act (PPA) of 2000 and Agency policy. Suppression treatments will follow all 

guidelines within the Environmental Impact Statement (EIS), Site-Specific 

Environmental Assessment (EA), Section (7) Consultation, Environmental Monitoring 

Plan, pesticide labeling, and the 2003 Guidelines stated herein. 

2. The Federal Government will bear 100% of the cost of treatment on Federal or Trust 

lands, up to 50% of the cost on State lands, and up to 33% of costs on private lands. The 

Federal Government' s participation in the cost share is contingent on allocation and 

availability of funds. First, USDA-APHIS-PPQ will conduct or fund surveys from the 

allocation of funds, then may conduct suppression treatments with any remaining funds, 

if requested. Additional sources of funding for suppression treatments may include 

Contingency, Commodity Credit Corporation (CCC), Land Management Agencies, or 

other sources. 

3. Environmental Assessments (EAs) for suppression treatments on Federally managed 

rangeland will be completed in accordance with National and/or local Memorandia of 

Understanding (MOUs) between USDA-APHIS-PPQ and the Federal land management 

agencies or Tribal authorities. Prior to treatments, APHIS and/or the Federal land 

manager will consult locally with U.S. Fish & Wildlife Service (USFWS) and/or 

National Marine Fisheries Service (NMFS) in situations where: (1) threatened or 

endangered species occur in the area and warrant protective measures, or (2) pesticides or 

application procedures utilized have not been addressed in the National Biological 

Opinion of 1995 or in previous Opinions. The completion in 2003 of a National Section 

(7) consultation may preempt any local Section (7) consultations. USDA-APHIS-PPQ 

will complete EAs for suppression treatments on State and private rangeland. Upon 

completion of the EA and consultation, the State Plant Health Director of USDA-APHISPPQ, or his/her designee, will sign a Finding of No Significant Impact (FONSI) and 

suppression treatments may commence. 

4. Federal land managers or Tribal authorities are responsible for the management of 

rangeland to prevent or reduce the severity ofGH&MC outbreaks. USDA-APHIS-PPQ 

and/or its designated cooperator will conduct suppression treatments only if requested in 

writing by the Federal land manager or Tribal authority. 

5. At the request of the respective State Department of Agriculture, USDA-APHIS-PPQ 

may conduct cooperative suppression programs on State and private rangeland, as 

permitted by regulation and available funding. USDA-APHIS-PPQ and/or the designated 

cooperator will conduct suppression treatments only if requested in writing by the State. 

A-1-2 
ID-PPQ-GH2003-001 

6. It is the responsibility of USDA-APHIS-PPQ to conduct border treatments on Federal 

or Trust rangeland, for up to . mile away from private agricultural lands (defined as 

"adjacent"), when economic GH&MC populations threaten the latter. Border treatments 

can only be justified when the potential for damage from GH/MC migrating into private 

agricultural lands constitutes an economic threat to the latter. 

7. In the absence of available funding in USDA-APHIS-PPQ, the Federal land 

management agency may opt to reimburse APHIS for suppression treatments. 

Reimbursement or interagency agreements between USDA-APHIS-PPQ and the 

Federal/State rangeland manager or Tribal authority must be completed prior to the start 

of treatments. 

8. On rangeland treatments funded by the Federal government, USDA-APHIS-PPQ 

and/or cooperating personnel (i.e., cooperative agreement) will be responsible for 

supervising treatments (e.g., aircraft calibration, pesticide inventory control, observing 

the treatments) and maintaining records of pesticides dispersed and acres treated. 

9. In accordance with the EIS, the pesticides Sevin XLR Plus, carbaryl baits, Dimilin 2L, 

and UL V malathion may be used for rangeland treatments of GH&MC. Pesticides must 

be used in accordance with the label, NEPA documents, the Biological Opinion, the 2003 

Operational Procedures, and any pertinent local decisions (i.e., that are more restrictive). 

10. Spray contracts will adhere to the 2003 Prospectus. 

11. The office of the State Plant Health Director (USDA-APHIS-PPQ) will prepare a 

Detailed Work Plan and a Work Checklist (with map), and these will.be approved by the 

USDA-APIDS-PPQ Western Regional Office prior to initiating treatments. In addition, 

the USDA-APHIS-PPQ State office will provide a weekly update to the Regional Office 

on acreage treated and pesticides used. Upon completion of each GH/MC suppression 

program, the USDA-APHIS-PPQ State office will prepare a summary for the Federal 

land manager or Tribal authority and will submit a Work Achievement Report to the 

Western Regional Office. 

12. Beekeepers will be notified in advance of proposed rangeland treatments so they can 

to move their bees before a suppression program begins. Observation aircraft may be 

used to check for bees in the proposed area. Bee locations must be documented on the 

treatment map. Non-treated buffer zones should be determined for pollinators (e.g., 

alkali, leafcutter or honey bees) based on the EA and the pesticide labels. [See 2003 

Operational Procedures below] 

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ID-PPQ-GH2003-00 l 

2003 Operational Procedures 

ALL METHODS 

l. Follow all applicable Federal, State, Tribal and local environmental laws and 

regulations in conducting GH&MC suppression treatment operations. 

2. Hold public meetings well in advance of proposed programs. Arrange for public 

announcements to encourage public input into the decision making process. 

3. Notify Federal and State land managers and private cooperators ofGH&MC 

infestations on their lands. This program will describe estimated boundaries, severity 

of infestations, and optimal time frames for treatment and control options. The 

notifications will request the land manager to advise USDA-APHIS-PPQ of any 

sensitive areas (e.g., parks, recreation areas, etc.) that may exist in the proposed 

treatment areas. 

4. Obtain request, in writing, from land managers and owners for suppression treatments 

to be undertaken on their land. When these requests originate as telephone calls, 

ensure that a follow-up letter is received before the expenditure of USDA-APHISPPQ funds. 

5. Avoid residences and other premises whose occupants object to their property being 

treated, except when treatments are mandatory under State law. In cases when State 

law requires treatment but land owners or occupants object to the treatments, USDAAPHIS-PPQ will cooperate to the extent authorized by Federal and State laws. 

6. Endangered Species (also see operational procedures listed under each control 

method in the EIS). 

a. Formal consultation will be accomplished with the U.S. Fish and Wildlife 

Service (USFWS) at the national level or designated points of contact. The 

Portland Regional Office has been designated as the official contact for formal 

consultation. Communications with the USFWS at the local level will be 

conducted to consider activities outside the National Biological Opinion. 

b. State-listed endangered and threatened species, Federal candidate species, 

and other sensitive areas will be addressed in the site-specific Environmental 

Assessment (EA). 

7. Instruct all program personnel in the use of equipment, materials and procedures; 

supervise to ensure procedures are followed properly. 

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ID-PPQ-GH2003-001 

AERIAL BROADCAST APPLICATIONS (LIQUID CHEMICAL METHODS) 

1. Strictly follow all EPA and State approved label instructions for chemical 

insecticides. 

2. Aircraft, dispersal equipment and pilots that do not meet all contract requirements of 

the 2003 Prospectus will not be allowed to operate on the Program. 

3. All USDA-APHIS-PPQ employees who plan, supervise, recommend or perform 

pesticide treatments must be certified under the USDA-APHIS-PPQ Certification 

Plan. They are also required to know and meet any additional qualifications or 

requirements of the State wherein they perform duties involving pesticide use. 

4. Notify all residents in treatment areas, or their designated representatives, prior to 

proposed operations. Advise them of the control method to be used, the proposed 

method of application, and precautions to be taken (e.g., advise parents to keep 

children and pets indoors during ULV treatment). Refer to label requirements related 

to restricted entry period. 

5. Use Global Positioning System (GPS) coordinates for pilot guidance on the 

parameters of the spray block. Ground flagging or markers should accompany GPS 

coordinates in delineating the project area as well as areas to omit from treatment 

(e.g., boundaries and buffers for bodies of water, habitats of protected species, etc.). 

6. Provide two-way communication equipment for all field personnel. Communication 

will be available for continuous contact among all units (including pilots) involved in 

any program. 

7. In advance of any treatment, stock safety kits, thermometers, flagging material, wind 

gauges, spray-deposit samplers and daily aircraft records, and make them available to 

relevant personnel. 

8. No treatments will occur over congested urban areas. For all flights over congested 

areas, the contractor must submit a plan to the appropriate FAA District Office and 

this office must approve of the plan; a letter of authorization signed by city or town 

authorities must accompany each plan. Whenever possible, plan aerial ferrying and 

turnaround routes to avoid flights over congested areas, bodies of water, and other 

sensitive areas that are not to be treated. 

9. Pesticide Container Disposal. All insecticide containers must be stored and disposed 

of properly. Rinse solution for drums may be used as diluent in preparing spray tank 

mixes, or it may be collected and stored for subsequent disposal in accordance with 

label instructions. One of the following methods for disposal (listed in order of 

preference) must be used: 

a. Require chemical companies, distributors, or suppliers to accept the triple-rinsed 

containers. 

A-1-5 
ID-PPQ-GH2003-001 

b. Crush and/or puncture the empty triple-rinsed containers, report on Form AD-112 

to Property Services, Field Servicing Office, Minneapolis, MN, and dispose of as 

scrap metal. 

c. Other methods as approved locally in concurrence with Safety, Health and 

Environmental Security (SHES; Bill Benson, 301-734-5577). 

10. Conduct mixing, loading, and unloading in an approved area where an accidental spill 

will not contaminate a stream or other body of water. 

11 . In the event of an accidental spill, follow the procedures set forth in PPQ Guidelines 

for Managing Pesticide Spills (USDA APHIS, Treatment Manual, 1998, pages 7 .1.10 

to 7.1.35). 

12. Pre-spray reconnaissance flights may be conducted to ensure that pilots are familiar 

with program area boundaries, buffer zones, and any other areas that are not to be 

treated. 

13. Notify local law enforcement agencies and fue officials of pesticide storage areas and 

treatment blocks. 

Aerial Application of Baits (Dry Chemical Methods) 

1. Do not use blowers for loading baits into the hopper, as blowers can cause packing of 

baits. 

2. The bait-hopper must be dust-tight. It must empty completely with uninterrupted 

flow, and it must be vented to avoid erratic flow of materials. 

3. There must be a dust-tight gate in the hopper throat to avoid leakage during ferry 

flights when flying over sensitive areas and during turnarounds. Linkage between the 

gate and its cockpit control handle must be secure. Gate stops are required to ensure 

that the hopper gate is opened to exactly the same position each time. Screw-type 

stops are preferred, whereas stops that are adjustable through a series of holes or 

notches are not acceptable. The gate stop must be at the gate and not in the cockpit 

on Category A and B aircraft. 

4. Aerial Bait 

a. Protective clothing will be worn by all pilots, loaders and field personnel, as 

required by the label and APHIS Safety and Health Manual, Chapter 11 . 

b. Empty bags must be disposed of according to EPA regulations. 

c. Follow label requirements when treatment areas contain reservoirs, lakes, ponds, 

pools left by seasonal streams, springs, wetlands, and perennial streams and 

rivers. The label indicates no direct application to water or wetlands. 

A-1-6 
ID-PPQ-GH2003-001 

d. Do not apply within 500 feet of any school or recreational facility. 

e. Do not apply where the water table is high, where leaching or runoff is likely, or 

when precipitation is imminent. 

f. Follow label recommendations when treatment areas contain oats, barley, and rye 

(fall treatments). For all other crops, observe the minimum days required between 

final application and harvest. 

g. Follow label requirements when treatment areas contain commercial bee hives. 

Ultra-Low-Volume (UL V) Aerial Application (Liquid Chemical Methods) 

1. To minimize drift and volatilization, do not use UL V sprays when any of the 

following conditions exist in the spray area: wind velocity exceeds 10 miles per hour 

(unless lower wind speed required under State law); rain is falling or is imminent; 

weather is foggy; normally when temperatures exceed 80DF; air turbulence that 

could seriously affect the normal spray pattern; and temperature inversions that could 

lead to off-site movement of spray. 

2. Weather conditions on treatment areas will be monitored by trained personnel before 

and during application. Operations will be suspended anytime it appears that weather 

conditions could jeopardize the safe placement of the spray on target areas. 

3. Do not apply when foliage is wet. 

4. Do not apply chemical ULV directly to any crop for which it is not labeled, unless an 

exemption has been granted under Section 18 of the Federal Insecticide, Fungicide 

and Rodenticide Act (FIFRA). 

5. All APHIS project personnel will have baseline cholinesterase tests before the first 

application of insecticide and on a routine basis as described in the AP HIS Safety and 

Health Manual. It is recommended that contract, State, and private project personnel 

also participate in a cholinesterase monitoring program. 

6. Require unprotected workers to stay out of treated areas, per the label re-entry 

requirements, or until the insecticide has dried, whichever period is longer. 

7. Use nozzle types and sizes, spray system pressure, and nozzle orientation as specified 

in the 2003 Prospectus or as approved by Aircraft and Equipment Operations (AEO) 

and the Contracting Officer. 

8. It is mandatory that the insecticide tank on the aircraft be adequately vented to 

provide for unrestricted flow, in the event that the load must be jettisoned. 

9. Do not spray while school buses are operating in the treatment area. 

A-1-7 
ID-PPQ-GH2003-001 

10. Protective long-sleeved work clothing will be worn by all pilots, loaders, and field 

personnel, as specified in the label and the AP HIS Safety and Health Manual. 

11. Follow label requirements that indicate not applying directly onto reservoirs, lakes, 

ponds, pools left by seasonal streams, springs, wetlands, and perennial streams and 

nvers. 

12. Do not apply where the water table is high or where leaching or surface runoff is 

likely. 

13. Do not apply within 500 feet of any school or recreational facility. 

14. Protection of Bees: 

a. When off-season or early-season planning indicates an area may require 

treatment, send early notification letters and maps to all registered apiarists in the 

State or near the area. 

b. Pre-spray reconnaissance flights may be conducted to ensure that all honey bees 

and all other bees used as commercial crop pollinators have been moved or 

protected. Should bees remain, ensure that the beekeeper received notice of the 

impending treatment and that programs are conducted in accordance with State 

law. 

c. If treatments are planned within 4 miles of areas where alkali or leaf cutter bees 

are being used for increasing the yield of alfalfa seed, monitor wind conditions 

and other drift factors closely. Do not apply ULV sprays when drift could reach 

these areas. In all such cases, use spray samplers (dye cards) near those areas 

d. Do not apply UL V diflubenzuron, carbaryl, or malathion to any blooming crops 

or allow it to drift onto blooming crops if commercial bees are visiting the area. 

A-1-8 
Appendix 2. Maps of Affected Environment 

Areas ofldaho south of the red line describing the watershed break between the Salmon and Snake Rivers are included in the 

proposed suppression area. A description of the area is found on Page 24 of the EA. 

ID-PPQ-GH2003-001 A-2-1 

Indicated areas in Owyhee, Elmore, Lincoln, Cassia and Oneida Counties may be at most 

risk of grasshopper outbreaks in 2003. 

IDAHO GRASSHOPPER SURVEY RESULTS 

Latah 2002 

Clearwater 

GRASS HOPPERS PER SQ. YD 

. : 

Adams 

. . 1 

Washington 

. . . 

Idaho 

Lemhi 

Valley 

Custer 

ayette Boise 

Canyon 

. 

Ada Camas

Elmore 

.: . 

.. . .. 

LESS THAN 8 

8 OR MORE 

Clark 

Jefferson 

Bingham

: . . . . . .. 

Madi 

Bonneville 

.. Lincoln 

.... .. Jerome ., Caribou 

Power Bannock .. 

Owyhee . Twin Falls 

. 

. 

. Cassia . . . 

1 

B 

Indicated areas in Ada, Elmore, Boise, Gem and Oneida Counties are expected to 

experience outbreak population levels in 2003. 

IDAHO MORMON CRICKET SURVEY RESULTS 

2002 

Latah 

Clearwater 

CRICKET BANDS PRESENT 

Idaho 

Lemhi 

Valley 

Custer Clark Fremont 

ayette Boise 

Jefferson Madison 

Butte 

Canyon 

Blaine Bonneville 

Bingham 

Lincoln 

Caribou 

Jerome Power Bannock 

Owyhee 

Twin Falls 

Cassia Bear Lake 

Oneida Frankin 

ID-PPQ-GH2003-01 
Appendix 3: Fish and Wildlife Service I National Marine Fisheries Service 

Correspondence 

IDAHO STATE LIBRARY 

MAY 1 5 2003 

BOISE, ID 83702 

David McNeal, Jr. 

State Plant Health Director 

Animal and Plant Health Inspection Service 

9134 West Blackeagle Drive 

Boise, Idaho 83709 

UNITED STATES DEPARTMENT OF COMMERCE 

National Oceanic and Atmospheric Administration 

NATIONAL MARINE FISHERIES SERVICE 

Northwest Region 

7600 Sand Point Way N.E .. Bldg. 1 

Seattle, WA 98115 

March 21, 2003 

RE: Rangeland Grasshopper and Mormon Cricket Suppression Program 

Dear Mr. McNeal: 

This responds to the March 13, 2003, letter requesting Endangered Species Act (ESA) 

consultation and Magnuson-Stevens Fishery Conservation and Management Act (MSA) 

consultation on the subject action. After reviewing the provided supplemental information of the 

grasshopper and Mormon cricket suppression boundaries and discussions with NOAA's National 

Marine Fisheries Service (NOAA Fisheries), Animal and Plant Health Inspection Service 

(APHIS) has determined this project would have no effect on ESA listed Snake River salmon 

and steelhead, designated critical habitat, or Essential Fish Habitat (EFH) under the jurisdiction 

of NOAA Fisheries, and consultation is not necessary. This determination is based on the 

information provided that the proposed suppression areas would not apply pesticides in 

watersheds that contain listed salmon and steelhead, or designated critical habitat. The APHIS 

would exclude watersheds of the Salmon River, and the Snake River and its tributaries below 

Brownlee Dam. The APHIS would also exclude applying pesticides to Wildhorse River and Salt 

Creek within Adams County. 

This concludes the review of the Rangeland Grasshopper and Mormon Cricket Suppression 

Program in accordance with 50 CFR 402.14 (b)(l), and MSA review in accordance with 50 CFR 

600.920 (e)(3). The APHIS must contact NOAA Fisheries if new information becomes 

available, or if circumstances occur that may affect listed species, designated critical habitat, or 

EFH. 

Ms. Debbie Artimez (208) 378-5648, and Mr. Jim Nutt (208) 378-5647 are the NOAA Fisheries 

contacts. 

Printed on Recycled Paper 

Sincerely, 

for D. Robert Lohn 

Regional Administrator 

A-3-1 

United States Department of the Interior 

C. David McNeal Jr. 

State Plant Health Director 

FISH AND WILDLIFE SERVICE 

Snake River Fish and Wildlife Office 

1387 South Vinnell Way, Room 368 

Boise, Idaho 83709 

Animal and Plant Health Inspection Service 

9134 W. Blackeagle Dr. 

Boise, Idaho 83 709 

APR 0 3 2003 

Subject: 2003 Grasshopper and Mormon Cricket Suppression Program - Informal 

Consultation 

File #1019.0422 OALS 1-4-03-1-537 

Dear Mr. McNeal: 

This letter acknowledges the U.S. Fish and Wildlife Service's (Service) March 17, 2003 receipt 

of the U.S. Department of Agriculture Animal and Plant Health Inspection Service's (APHIS) 

Environmental Assessment (Assessment) for implementation of the 2003 grasshopper and 

Mormon cricket suppression program on rangeland in southern Idaho, and your request for 

section 7 consultation under the Endangered Species Act of 1973, as amended (Act). APHIS has 

determined that the proposed action may affect, but will not adversely affect the threatened, 

endangered or proposed species, or proposed critical habitat that occur within the action area. 

Staff from the Service and the Bureau of Land Management State office (Bureau) worked 

closely with APHIS during the process of preparing the Assessment to incorporate measures to 

minimize the potential for effects to occur to proposed, listed and candidate species, and 

proposed critical habitat. 

Proposed Action 

The proposed action is to conduct suppression programs on grasshopper and/or Mormon cricket 

(hereafter referred to collectively as grasshoppers) outbreaks on rangeland in southern Idaho. 

APHIS regularly evaluates grasshopper population levels and species composition to determine 

if site specific action is necessary to suppress outbreaks to protect rangeland ecosystems and to 

minimize the potential for effects to the surrounding crops and communities. APHIS is 

proposing a program to suppress outbreak populations that would take place from April 15, 2003 

to September 30, 2003 in southern Idaho. 

A-3-2 

As provided by the Plant Protection Act, APHIS will conduct grasshopper suppression programs 

on Federal, State or private lands in response to a request from the administering agency. Over 

the past two decades, most of the suppression programs in Idaho have been on lands 

administered by the Bureau. The Service worked closely with the Bureau on their 2000 

Assessment in developing the conservation measures that were incorporated into the proposed 

action. The Service concurred with the Bureau that suppression activities described in the 2000 

Assessment were not likely to adversely affect Ute ladies tresses, bald eagle, Banbury Springs 

limpet, Bliss Rapids snail, Idaho springsnail, Snake River physa, and Bruneau hot springsnail. In 

addition, we worked closely with APHIS in 2002 on your proposed treatment program for the 

control of Mormon Crickets in Elmore, Ada, and Boise counties. The Service concurred with 

APHIS's determination that the 2002 suppression activities were not likely to adversely affect 

bull trout and bald eagles. Both the Bureau's 2000 Assessment and APHIS's 2002 consultation 

are the basis for many of the conservation measures included in the 2003 APHIS Assessment. 

These measures are also consistent with the Service's 1988 Biological Opinion on the U.S. 

Environmental Protection Agency's pesticide labeling program which included malathion, 

carbaryl, and diflubenzuron (dimilin). 

In response to suppression requests from public and private land owners/managers under the 

2003 proposed action, APHIS would determine if an outbreak has reached an economically or 

environmentally critical level. If so, an appropriate treatment plan would be developed, taking 

into account site specific information. Suppression activities at a site-specific level would be 

based on potential grasshopper damage such as reduction of forage and habitat available for 

some species of wildlife and livestock, destruction of rangeland revegetation projects, creation of 

public nuisances, and endangerment of road traffic. APHIS will also evaluate the need for 

treatment by the benefits that it would provide for forage and habitat or increased probability of 

success for rangeland revegetation projects. Some populations that may not cause substantial 

damage to native rangeland may require suppression to prevent damage to economically valuable 

crops that occur on adjacent private land. 

Selected Alternative 

Of the four treatment alternatives discussed in the Assessment, APHIS has selected the Modified 

Reduced Agent Area Treatments (MRAA Ts) alternative. The MRA TTs alternative is based on the 

Reduced Agent Area Treatments (RAA Ts) alternative, which relies on the effects of an insecticide 

to suppress grasshoppers within treated swaths while conserving grasshopper predators and 

parasites in swaths not directly treated. Carbary!, diflubenzuron (Dimilin®), or malathion would 

be considered under this alternative at the following maximum application rates: 

• 8.0 fluid ounces (0.25 lb a.i.) of carbaryl spray per acre, 

• l 0. 0 pounds ( 0. 5 0 lb a. i.) of 5 percent carbaryl bait per acre, 

• I 0.0 pounds (0.20 lb a.i.) of 2 percent carbaryl bait per acre, 

• 0.75 fluid ounce (0.012 lb a.i.) ofdiflubenzuron spray per acre, or 

• 4.0 fluid ounces (0.3 l lb a.i.) of malathion spray per acre. 

2 

A-3-3 

According to your Assessment, these application rates are equal to or less than the maximum 

rates allowed by the Environmental Protection Agency (EPA) for grasshopper control. The 

carbaryl spray rate is 25% of the maximum EPA allowable rate. The carbaryl bait rate is 10% of 

the EPA allowable rate. The diflubenzuron spray rate is 75% of the maximum EPA allowable 

rate. The malathion spray rate is 34% of the maximum EPA allowable rate. 

The area not directly treated (the untreated swath) under the RAA Ts approach is not 

standardized. In practice, the area infested with grasshoppers that remains untreated has ranged 

from 20 to 67 percent of the total infested area. The 2002 Environmental Impact Statement (EIS) 

for APHIS suppression activities in 17 western states analyzed the reduced pesticide application 

rates associated with the RAATs approach but assumed pesticide coverage on 100 percent of the 

area as a worst-case scenario. This assumption was made because there is no way to predict how 

much area would actually be left untreated without local environmental analyses. The goal of 

this alternative is to suppress grasshopper populations to a less damaging level, rather than to the 

greatest extent possible. 

The MRAATs alternative is the same as the RAATs alternative with one exception. Carbary! 

bait could be used in the 5% formulation as well as the 2% formulation. The 5% formulation of 

carbaryl bait provides higher mortality than the lower 2% rate, quicker knockdown than 

diflubenzuron, and better target specificity than carbaryl or malathion spray. 

The potential environmental effects of application of carbaryl, diflubenzuron, and malathion 

under this alternative are discussed in detail in the 2002 EIS (Environmental Consequences of 

Alternative 3: Reduced Agent Area Treatments (RAATs), pp. 49-57), and in the 2003 SiteSpecific Environmental Assessment for Rangeland Grasshopper and Mormon Cricket 

Suppression Program. 

Measures to Avoid and Minimize Effects 

As part of the proposed action APHIS and the Service have developed conservation measures 

and buffers to avoid the potential for effects to occur to proposed or listed species and proposed 

critical habitat. These measures and/or buffers are summarized below. In addition, the Service 

and APHIS have made the commitment to coordinate closely on application of pesticides for 

grasshopper suppression in areas that are considered to be sensitive for listed or proposed species 

or their habitats. In those circumstances where conservation measures or buffers may reduce the 

efficacy of suppression activities, APHIS will immediately contact the Service to develop sitespecific measures to maintain protection to the environment while effectively treating areas in 

jeopardy of grasshopper outbreaks. 

The following is a list of listed, proposed, and candidate species that may occur in the action area 

and measures to APHIS will implement to avoid or minimize impacts on them from suppression 

activities. These measures allowed for use of any of the proposed chemicals except where noted, 

with the understanding that Dimilin would be the preferred spray when possible. 

3 

A-3-4 

• Northern Idaho ground squirrel (NIGS): APHIS will avoid the sensitive area for NIGS as 

defined by the red line on the Service's distribution map (provided to APHIS during a 

meeting in March 2003). 

• Lynx: APHIS will not spray in forested areas or rangelands that are not adjacent to 

croplands but are surrounded by forest, and are above 5000' in elevation. This would 

avoid lynx habitat within the overall treatment area. 

• Grizzly bear: APHIS will not treat areas currently occupied by grizzly bears. 

• Snake River snails: In areas along the Snake River from C.J. Strike Reservoir upstream to 

and including American Falls Reservoir, a . mile buffer will be provided for all aerial 

sprays, with a 500 foot buffer for carbaryl bait treatments. If there are treatment needs 

within the buffer, APHIS will consult with the Service on a case-by-case basis. 

• Bull trout and proposed bull trout critical habitat: In all areas proposed as critical habitat 

for bull trout, a . mile buffer will be maintained for all aerial sprays, with a 500 foot 

buffer for carbaryl bait. If there are treatment needs within the buffer, APHIS will 

consult with the Service on a case-by-case basis. This measure will provide adequate 

protection to both the species and proposed critical habitat 

• Bruneau hot springsnail: Within the recovery area as defined in the final BHSS recovery 

plan, APHIS will maintain a . mile buffer for all aerial sprays, with a 500 foot buffer for 

carbaryl bait treatments. If there are treatment needs within the buffer, APHIS will 

consult with the Service on a case-by-case basis. 

Ute ladies' -tresses: Along the South Fork Snake River and Henry's Fork populations, 

there will be a 3-mile buffer for all aerial spray treatments. 

Slickspot peppergrass: Around known sites as defined by the land management agencies 

there will be a 3-mile buffer for all aerial spray treatments. 

• Bald eagles: There will be a treatment-free zone of I-mile around active aeries found on 

rivers and lakes with no flyovers by aircraft. A 2. 5 mile no aerial spray zone will be 

maintained upstream and downstream from a known nest site. Wintering areas will not 

be affected by the proposed action. 

Yellow-billed cuckoo: the buffers described below for all water bodies should provide 

sufficient protection for this candidate species. 

• Columbia spotted frog: the buffers described below for all water bodies should provide 

sufficient protection for this candidate species. 

4 

A-3-5 

Southern Idaho ground squirrel (SIGS): APHIS will use Dimilin spray and will avoid 

carbaryl bait where possible within the SIGS area of conservation concern as defined by 

the Service. APHIS will work with the Service to address site-specific concerns where 

Dimilin use may not be appropriate, or where there are known extant populations of 

SIGS. 

• For all waters that are not covered by the measures described above, including rivers, 

tributaries, streams, reservoirs, wetlands, etc., APHIS will maintain a 1/4 mile buffer for 

Dimilin, carbaryl, and malathion aerial spray, and a 500 foot buffer for aerial carbaryl bait 

treatments. 

For canals and ditches, APHIS will maintain a 500 foot buffer for all aerial treatment 

applications and 50 feet for ground application of carbaryl bait. 

Section 7 Concurrence 

The Service reviewed the project described in the Assessment in accordance with section 7(a)(2) 

of the Endangered Species Act of 1973, as amended (Act). We concur with APHIS's 

determination that grasshopper suppression actions proposed for 2003 in southern Idaho may 

affect, but are not likely to adversely affect bald eagle (Haliaeetus leucocephalus), northern 

Idaho ground squirrel (Spermophilus brunneus brunneus), bull trout (Salvelinus conjl.uentus), 

Banbury Springs limpet (Lanx sp.), Bliss Rapids snail (Taylorconcha serpenticola), Idaho 

springsnail (Pyrgulopsis idahoensis), Snake River physa snail (Physa natricina), Utah valvata 

snail (Valvata utahensis), Bruneau hot springsnail (Pyrgulopsis bruneauensis), and Ute ladies'-

tresses (Spiranthes diluvialis). Additionally, we concur that the proposed action is not likely to 

jeopardize the gray wolf (Canis lupus) or the proposed plant slickspot peppergrass (Lepidium 

papilliferum), and will not result in the destruction or adverse modification of proposed bull trout 

critical habitat. We acknowledge and agree with your conclusion that proposed actions will not 

affect the grizzly bear (Ursus arctos) or Canada lynx (Lynx canadensis). In addition, we support 

measures included in the proposed action to minimize the potential for effects to candidate 

species including Columbia spotted frog (Rana luteiventris), yellow-billed cuckoo (Coccyzus 

americanus), and southern Idaho ground squirrel (Spermophilus brunneus endemicus). The 

Service appreciates AP HIS' s consideration of these candidate species. 

Our concurrence with your "not likely to adversely affect" determination for threatened and 

endangered species, and your non-jeopardy determination for gray wolf, and Lepidium is based 

on the afore-mentioned conservation measures that will be incorporated into the action. We also 

considered the following factors. 

1) Tables l and 2 of the 2000 Bureau Assessment for grasshopper suppression activities 

conducted by AP HIS summarize the direct and indirect effects of the application and 

toxicity of the three pesticides proposed for use: dimilin, carbaryl, and malathion. Tables 

1 and 2 of the Bureau Assessment have been adapted and developed into a Table specific 

5 

A-3-6 

for this action. This Table is attached as an appendix to this letter. Data in those tables 

support your conclusion that adverse effects to listed species are avoided under the 

proposed action. 

2) APHIS will avoid disturbing or applying pesticides in areas of known or historic species 

habitat to reduce the potential for direct effects to negligible levels. 

3) Potential indirect effects described in the Assessment include reductions in insect prey for 

local populations of birds, impacts to aquatic environments, and effects on plant 

productivity from reductions in non-target pollinator insect populations. APHIS has 

restricted insecticide applications such that indirect effects to proposed and listed species 

and their habitats will be insignificant and discountable. 

4) APHIS will monitor insecticide applications and will document compliance with the 

Assessment's protective measures. This information will be provided to the Service. 

This concludes informal consultation on the proposed actions outlined in the 2003 APHIS 

Assessment in accordance with the Act. APHIS should reinitiate consultation on this action if 

new information becomes available, if circumstances occur that may affect listed species or their 

critical habitat in a manner or to an extent not previously considered, if a new species is listed, or 

if critical habitat is designated that may be affected by the actions. 

National Environmental Policy Act (NEPA) and the Migratory Bird Treaty Act 

The Service appreciates the open dialogue and exchange of technical information with APHIS 

during the preparation of the environmental documents for this project. To continue and 

document this open dialogue, the Service has additional comments in accordance with the 

National Environmental Policy Act (NEPA) and the Migratory Bird Treaty Act on the 

Assessment. 

The Service commends APHIS for including in the Assessment a thorough list of protective 

measures that should assure protection of a wide breadth of species on public lands. The NEPA 

analysis addressed species that are candidates for listing under the Act, including the yellowbilled cuckoo, Columbia spotted frog, and the southern Idaho ground squirrel. Although these 

species have no protection under the Act, the Assessment specifies protective measures that 

would avoid impacts to them. 

Migratory birds in pesticide treated rangeland may be impacted. Although few of these species 

have population viability concerns the Service recommends that future assessments include 

language that describes specific monitoring that will take place to assess impacts to these 

migratory bird species. 

6 

A-3-7 

We appreciate the opportunity to provide input into the development of your Assessment to 

reduce the potential for impacts to listed and proposed species and their habitat, and migratory 

birds. Please contact Susan Burch at (208) 378-5265 or Kendra Womak of my staff at (208) 685-

6955 with any questions. 

Attachment 

cc: Bureau, State Office (Foster) 

IDFG, Shoshone (Parrish) 

FWS, Chubbuck (Arena) 

FWS, Portland (Hill/Steffeck) 

FWS, Portland (Buerger) 

FWS, LeGrande (Miller) 

FWS, Reno (Maley) 

FWS, West Valley City (Waddell) 

7 

A-3-8 

Table 1. General direct and indirect effects of proposed pesticides, recommended protective and mitigation measures, and resulting determinations 

for non-target species. 

Special Toxicity Levels (Direct Effects) Indirect Protective and 

Non-Target Species and Species Groups Status Effects Mitigation Determination 

Species Malathion Carbary l Dimilin Measures and rationale 

Aquatic Invertebrates 

Molluscs/snails Very high Very high None- 2, 3 b, e NLAA ( 1, 2) 

Slight . mile buffer w/ 

Banbury Springs limpet E dimilin, 

Bliss Rapids snail T carbaryl, malathion ; 

Idaho springsnail E 500 feet for aerial 

Snake River physa snail E carbaryl bait 

Utah valvata snail E 

Bruneau hot springsnail E 

Fish 

Bull Trout T Moderate - Very high Slight 1, 3, 4 a, b, d NLAA (l , 2, 3) 

High mile buffer w/ 

dimilin, 

carbaryl, malathion; 

500 feet for aerial 

carbaryl bait 

Bull Trout Critical Habitat PCH NJ 

. mile buffer w/ 

dimilin, 

carbaryl, malathion ; 

500 feet for aerial 

carbaryl bait 

8 

3-9 I 

I A 

. 

Non-Target Species and Species Groups 

Amphibians 

Columbia Spotted Frog 

Mammals 

Northern Idaho Ground Squirrel 

Southern Idaho Ground Squirrel 

Gray Wolf 

Grizzly Bear 

Canada Lynx 

Birds 

Riparian/Wetland Birds 

Yellow-billed Cuckoo 

Special 

Status 

Species 

c 

T 

c 

x 

T 

T 

c 

Toxicity Levels (Direct Effects) 

Malathion Carbaryl Dimilin 

Very High Moderate - Low 

(aquatic high 

stages) 

Moderate - Moderate Low 

High 

Moderate - Moderate Low 

High 

Moderate - Low- Low 

High Moderate 

9 

Indirect Protective and 

Effects Mitigation 

Measures 

1, 2, 3, 4 a, b, k 

1/4 mile buffer w/ 

dimilin, 

carbaryl, malathion; 

500 feet for aerial 

carbaryl bait 

2, 3 b, c, f, g 

Buffer will be 

delineated by the 

Service and 

provided to APHIS 

c, g 

A void pesticides 

within 1 mile of 

habitat 

1, 2, 3, 4 a, b, k 

1/4 mile buffer w/ 

dirnilin, 

carbaryl, malathion; 

500 feet for aerial 

carbaryl 

Determination 

and rationale 

NLAA (2) 

NLAA (1 , 2, 3) 

NJ 

NE 

NE 

NLAA (2, 3) 

0 

1 

I 

3I A 

Special Toxicity Levels (Direct Effects) Indirect Protective and 

Non-Target Species and Species Groups Status Effects Mitigation Determination 

Species Malathion Carbaryl Dimilin Measures and rationale 

Bald Eagle T Moderate - Low- Low 2,4 b, h, i NLAA (1 , 2) 

High Moderate 1-mile treatment 

free zone; 2.5 mile 

up/down stream 

buffer 

Special Toxicity Levels (Direct Effects) to Indirect Protective and 

Non-Target Species and Species Groups Status pollinators Effects Mitigation Determination 

Species Measures and Rationale 

Malathion Carbary I Dimilin 

Native Plants T Very high Very high Moderate - 5,6 a, b, j NLAA (1, 2) 

Low No aerial spraying 

Ute ladies' -tresses within 3 miles of 

habitat 

Slickspot peppergrass PE Very high Very high Moderate - 5,6 a, b,j NJ(l,2) 

Low No aerial spraying 

within 3 miles of 

habitat 

10 

Table Key 

E Listed Endangered under the Endangered Species Act (Act) 

T Listed Threatened under the Act 

P Proposed for listing under the Act 

X Experimental, Non-essential Population 

C Candidate Species for possible listing under the Act 

Indirect Effects 

1. General loss of prey. 

2. Limited mobility to move out of treated area. 

3. Ingestion of chemicals from vegetation and insects could affect survival or reproductive fitness. 

4. Direct pesticide application on young of year could adversely affect survival and population recruitment. 

5. Loss of important pollinators. 

6. Loss of seed dispersal agents. 

Protective and Mitigation Measures: 

a. 

b. 

c. 

d. 

e. 

f. 

g. 

h. 

i. 

j. 

k. 

Limit application area as much as possible due to direct and indirect toxicity for beneficial species associated with this species group. 

A void using malathion or carbaryl spray due to toxicity risks for non-target species. 

Proposed action will avoid known or historic species habitat area. 

No aerial application of dim il in, carbaryl, or malathion within mile or carbaryl bait within 500 feet of water bodies including, but not limited to, 

streams (perennial and intermittent), springs, ponds, lakes, etc. 

No aerial application of dimilin, carbaryl, or malathion within mile from threatened or endangered snail habitats. 

Limit use of carbaryl bait. 

Avoid using any pesticide within 1 mile of known and potential habitats. 

Refer to restriction in the Fish and Wildlife Service's 1995 Biological Opinion for bald eagles and peregrine falcons. 

Avoid using pesticides within one mile of known nest sites. 

Avoid aerial spray application of pesticides within 3 miles of known populations. Carbary) bait can be used within 3-mile buffer but only up to 500 feet. 

No aerial application of dimilin, carbaryl, or malathion within 1/4 mile or carbaryl bait within 500 feet of water bodies including, but not limited to, 

streams (perennial and intermittent), springs, ponds, lakes, etc. 

11 

Determinations 

NE 

NJ 

NLAA 

No Effect 

Not Likely to Jeopardize the Population 

Not Likely to Adversely Affect 

Rationale for Determinations 

1. A voiding known and potential habitats. 

2. Buffer around known and potential habitats. 

3. Adverse effects highly unlikely as a result of proposed chemical and application method. 

12 
. 
Appendix 4. PROTOCOL FOR DOCUMENTING REQUESTS, EVALUATIONS, 

RECOMMENDATIONS, REVIEWS AND MONITORING OF RANGELAND 

GRASSHOPPER/MORMON CRICKET SUPPPRESSION IN IDAHO 2003 

l . Private landowners and/or public land managers who wish to request evaluations 

for grasshopper suppression should complete Form l, Request for Evaluation of 

Need for Suppression of Grasshopper/Mormon Crickets on Rangeland in Idaho, 

and fax to USDA in Boise or Twin Falls. Private landowners may also call 

federal or state land management offices to request the submission of this form. 

A case number will be assigned by USDA to each request. 

2. The USDA APHIS PPQ Grasshopper Program Staff in Boise will supervise 

temporary personnel across Southern Idaho. These grasshopper scouts will 

conduct evaluations in response to requests as well as in areas that are historically 

susceptible to grasshopper infestations. The grasshopper scouts will complete 

Form 2, Evaluation of Idaho Request #for Suppression of Grasshopper/Mormon 

Crickets on Rangeland. Scouts will submit these reports to USDA in Boise. 

3. Experienced USDA managers will review the scouts' evaluations and determine if 

follow-up analysis is required. The USDA Grasshopper Coordinator will 

complete Form 3, USDA AP HIS PPQ Recommendation per Idaho Request #for 

Suppression of Grasshopper/Mormon Crickets on Rangeland. USDA will 

forward this form to the land manager for a decision. 

4. Land managers will receive Forms 1 through 3 and will determine whether 

APHIS's recommendation is consistent with the program defined and analyzed in 

the environmental documentation. Additionally, the land manager will determine 

if .additional safeguards are required for treatments. Land managers will complete 

Form 4, Land Manager Consistency Review of Idaho Request# for Suppression of 

Grasshopper/Mormon Crickets on Rangeland. They will forward these forms to 

USDA in Boise. 

5. If treatments are consistent with the description and analysis in the environmental 

documentation and if additional safeguards do not appear to preclude the 

treatment from being effective, USDA will apply or contract for application of the 

treatment. USDA will supervise contractors and evaluate the efficacy of 

treatments. USDA will complete Form 5, USDA APHIS PPQ Treatment 

Monitoring of Idaho Request #for Suppression of Grasshopper/Morinon Crickets 

on Rangeland, and will transmit the form to appropriate land managers and land 

owners. 

Forms l through 3 will be completed and filed for each grasshopper complaint from a 

private landowner or public land manager. Forms 4 and 5 will be completed and filed 

when a need for further action is indicated by the prior steps. 

A-4-1 

ID-PPQ-GH2003-00 l 
Form 1. REQUEST FOR EVALUATION OF NEED FOR SUPPRESSION OF 

GRASSHOPPER/MORMON CRICKETS ON RANGELAND IN IDAHO 

land managers/owners complete this form and fax lo USDA APHIS PPQ in 

Boise at 208-378-5794 or Twin Falls at 208-734-7863. 

USDA AP HIS PPQ will evaluate the problem and provide recommendations to land managers. 

Action will be dependent on request for control from land manager, approval of recommended treatment, 

availability of funding, and the probability that available methods will be effective and safe . 

Party requesting control: Date of request: 

Principal contact: 

Address: 

Phone/cell phone/fax numbers: 

County where rangeland is located: 

Owner(s) or land manager(s) of rangeland where control is requested (BLM, Forest . 

Service, State ofldaho, private party, etc): 

Legal description of area where control is requested (please attach map showing land 

ownerships): 

Describe nature of problem (cropland threatened, rangeland damaged, revegetation 

project, etc.): 

Are you aware of environmentally sensitive issues such as streams or lakes, bees, or 

endangered species critical habitat in the area where you are requesting treatment? 

If so, please explain. 

************************************************************************ 

FOR USE BY PPQ 

Date and time: 

Case#: 

Referred to: By: 

Distribution of copies: 

************************************************************************ 

A-4-2 

ID-PPQ-GH2003-001 
Form 2. EVALUATION OF IDAHO REQUEST# 

FOR SUPPRESSION OF GRASSHOPPER/MORMON CRICKETS ON 

RANGELAND 

Will be completed by Grasshopper Field Scout under supervision of USDA APHIS PPQ upon receipt of a 

request for evaluation from a land manager and will be submitted to USDA APHIS PPQ Manager. 

Date evaluated: 

Person performing evaluation: 

Was complainant contacted during visit? 

Species of grasshoppers: 

Density per sq. yd.: 

Approximate acres of rangeland infested 

Federal: 

State: 

Private: 

Predominant instar(s): 

Narrative report including sensitive issues (bees, water, endangered species, organic 

farms, etc.): 

Attach map showing infested areas and sensitive sites 

*•********************************************************************** 

FOR USE BY PPQ 

Date and time: 

Referred to: By: 

Distribution of copies: 

************************************************************************ 

A-4-3 

lD-PPQ-GH2003-00 l 
Form. 3 USDA APHIS PPQ RECOMMENDATION PER IDAHO 

REQUEST# FOR SUPPRESSION OF 

GRASSHOPPER/MORMON CRICKETS ON RANGELAND 

To be completed by USDA APHIS PPQ Grasshopper Coordinator upon receipt of evaluation from Field 

Scout. Will be forwarded to Land Manager of rangeland specified in request for evaluation (and person 

who initiated request if other than land manager). 

I have reviewed the evaluation of complaint # _______ regarding an infestation 

on in County, Idaho. 

I recommend the following course of action: 

Name and title of responsible USDA AP HIS PPQ Grasshopper Coordinator 

************************************************************************ 

FOR USE BY PPQ 

Date and time: 

Referred to: By: 

Distribution of copies: 

************************************************************************ 

A-4-4 

ID-PPQ-GH2003-001 
Form 4. LAND MANAGER CONSISTENCY REVIEW OF IDAHO 

REQUEST# FOR SUPPRESSION OF 

GRASSHOPPER/MORMON CRICKETS ON RANGELAND 

To be completed by land manager after review of recommendations from USDA AP HIS PPQ 

Fax to 208-378-5794 

The Environmental Assessment, "Site-Specific Environmental Assessment, Rangeland 

Grasshopper and Mormon Cricket Suppression Program, Idaho, EA Number: ID-PPQGH2003-00 l '',and associated Findirig of No Significant Impact (FONSI) have been 

carefully reviewed. Request for Evaluation for Control, Evaluation of Request and 

Recommendation for Action # have also been carefully reviewed. The 

recommendation is: 

Consistent D 

Not Consistent D 

with control actions on rangeland specified by those documents. Any treatment will be 

implemented by APHIS in accordance with the operational procedures, design features, 

and mitigating measures described and adopted in the above-referenced documents. 

In addition, the following measures are required as well as those referenced above: 

Due to the following extenuating circumstances, treatment should not occur: 

Name, title and organization of responsible official _ 

Date 

Additional forms required by land management agency should be attached. 

************************************************************************ 

FOR USE BY LAND MANAGER 

Date and time: 

Referred to: By: 

Distribution of copies: 

************************************************************************ 

A-4-5 

ID-PPQ-GH2003-00 l 
Form 5. USDA APHIS PPQ TREATMENT MONITORING OF IDAHO 

REQUEST # FOR SUPPRESSION OF 

GRASSHOPPER/MORMON CRICKETS ON RANGELAND 

To be completed by USDA APHIS PPQ at the time of treatment and post-treatment evaluation. 

TREATMENT 

Date treatment occurred: 

Contractor who applied treatment: 

Acres treated: 

Type and amount of pesticide applied: 

Comments: 

Name of USDA APHIS PPQ official in charge of managing control activity. 

POST-TREATMENT EVALUATION 

Date of evaluation: 

Grasshopper density per sq. yd.: 

Predominant species: 

Predominant instar(s): 

Other monitoring observations: 

Name of person conducting post-treatment evaluation 

************************************************************************ 

FOR USE BY PPQ 

Date and time: 

Referred to: By: 

Distribution of copies: 

**************~********************************************************* 

A-4-6 

ID-PPQ-GH2003-001 
Appendix 5. 

ENVIRONMENT AL 

MONITORING 

PLAN 
Objectives 

The goals of environmental monitoring are to: 

I. Provide data which can be used to evaluate the effectiveness of protective measures 

established for E&T species or other wildlife which might occur in or near a Program 

area. 

2. Collect data which can be used to evaluate whether or not the assumptions used in the EA 

and EIS are valid estimates of potential exposure of the public or program workers to 

pesticides used by the program. 

3. 

4. 

5. 

Demonstrate that operational procedures, mitigations and protection measures were 

monitored by providing a checklist describing all of the relevant program quality 

assurance and quality control measures. 

Assure the integrity of environmental samples through the use of quality control 

measures. 

Conduct investigations of incidents and/or complaints about possible adverse impacts 

suspected of being related to program operations. 

Monitoring Methods 

The environmental monitoring, recommended by the APHIS Environmental Monitoring Team 

(EMT), for grasshopper and Mormon cricket programs involves monitoring aerial applications of 

liquid pesticide and bait for drift at selected sensitive sites primarily by collecting dye card, 

water and vegetation samples. Prior to the commencement of any treatments, a comprehensive 

list of all sensitive sites in, or within 600 feet of, the aerial treatment blocks (200 feet for 

ground-applied pesticide) will be prepared by program personnel. Forward a copy of the list to 

K.iesett Collier at: 

PPQ-Environmental Monitoring Team 

4700 River Rd., Unit 150 

Riverdale, MD 20737-1237 

Phone: 301-734-7175 Fax: 301-734-5992 

If there are no sensitive sites in a treatment program area, program personnel should submit a 

statement to that effect to Kiesett Collier. For every treatment program, quality control 

monitoring will be conducted by validating chemical purity of formulations and by documenting 

Program quality assurance procedures (as described in the Quality Assurance and Quality 

Control section below). Worker safety monitoring will be conducted by measuring serum acetyl 

cholinesterase levels of workers potentially exposed to malathion or carbaryl as outlined in the 

APHIS Safety and Health Manual. 

,. 
Dimilin 

Dimilin is new to the program, thus we are recommending more monitoring sites and more 

thorough monitoring at those sites than for the other pesticides. Select sites for monitoring from 

the list of sensitive sites previously prepared. Collect vegetation (preferably grass) samples from 

four different sites within a Program area both before and as soon as possible after the treatment, 

and once again one week after the treatment. Monitor water in each treatment program area (if 

any), by collecting a water sample from that body both before and as soon as possible after 

treatment. Monitor four sites where crops are within 600 feet of treated areas by collecting leafy 

portions of the crop plant both before and as soon as possible after treatment. Dye cards should 

also be used whenever water or crop samples are collected. If there are no sensitive sites for a 

treatment program area then only target vegetation and quality control samples need to be 

collected for pesticide analysis. 

Target Vegetation 

Collect pre- and post-treatment vegetation samples. Post treatment samples should be collected 

within 24 hours of application., and again seven days after the treatment. The preferred 

vegetation is grasses, but leaves from shrubs would be acceptable. Follow SOP EM - 07, 

Collection of Vegetation Samples. 

Dye Cards 

Dye cards are recommended at water sites, crop edges, and at any E&T or other wildlife 

sensitive sites. Place water-sensitive dye cards as close to the sensitive site as possible on the 

side nearest the treatment area. (see SOP EM - 01 Collection of Dye Card Samples). Place three 

cards, one on each of three poles spaced thirty feet apart, or evenly spaced along the edge of the 

site. Place cards about a half hour before treatment, and collect them after treatment. 

Each card is packaged separately, and ready to be labeled as to placement in the array (do not 

write on the card but rather label the cards zip-lock bag). Each card must be accompanied by a 

completed APHIS Form 2060 when sent to the Analytical and Natural Products Chemistry 

Laboratory, (ANPCL) (see Appendix B, SOP EM- 13, Taking Measurements for the APHIS 

Form 2060). Send the yellow copy of the 2060 form to Kiesett Collier, along with an annotated 

map or sketch of the sampling site with the locations of each dye card on the map, distances to 

the treatment site, etc. For spotted cards, count the number of spots up to twenty, estimate if 

over twenty. Make a note of the number of spots in the Remarks section on the AP HIS Form 

2060. If no cards are spotted, then fill out one 2060 for all three dye cards noting that no spots 

were observed on any card. Send both the white and yellow copies to Kiesett Collier (address 

above), and retain the cards and other forms in the program files; nothing need be sent to the 

laboratory in this case 

Crops 

Collect pre-treatment and post-treatment samples of the leafy portion of the crop vegetation at 

the edge of the crop closest to the treatment. Follow SOP EM - 07, Collection of Vegetation 

Samples. 

Water 

Collect a blank and pre-treatment water sample from the water body to be monitored prior to the 

scheduled treatment (preferably no more than 24 hours prior), and collect a post-treatment 

sample as soon as possible after treatment (within 24 hours after treatment). Also use dye cards 

at the water's edge to measure drift. Choose stationary rather than flowing water for the 
monitoring site, if there is a choice. Instructions for collecting water samples are included in 

SOP EM - 03, Collection of Water Samples in Appendix B. 

Malathion and Carbaryl Sprays 

Environmental samples are recommended if there are sensitive sites within 600 feet of a 

treatment block. Quality control monitoring will be required-- see below. 

Carbaryl Bait 

Carbary} bait applied with ground equipment will not require the collection of any environmental 

samples unless required under a concurrence from FWS following informal consultations for 

possible effects on E&T species. Aerially applied carbaryl bait can be monitored. Quality 

control will be required (for both ground and aerially applied -- see below). 

Sticky Boards 

For aerially applied bait, drift monitoring can be conducted at water bodies within 300 feet of 

treated areas. Use Gypsy Moth sticky boards to collect drifting bait near water bodies. Three 

sticky boards should be erected vertically at each site (sticky side facing treatment and into the 

wind, if also possible), with placement similar to the procedures described above for dye card 

monitoring. Record in an APHIS 2060 Form whether any bait has adhered to any of the three 

sticky boards, which boards had bait, and the amount of bait particles adhering described in as 

quantifiable a manor as practical. Submit the original and yellow copies of the form to Kiesett 

Collier. No residue analysis of the sticky boards is required. The presence of bait on the sticky 

boards will indicate a need to collect additional post-treatment water samples (see below). 

Sticky boards are available from the Decision Support & Pest Management Systems Laboratory, 

USDA, APHIS, contact Nelson Foster. If no bait is detected on any of the three sticky boards, 

then fill out one 2060 form for all three sticky boards noting that there was no drift observed. 

Send both the white and yellow copies to Kiesett Collier (address above), and retain the other 

forms in the program files. Also if no drift was observed pre-treatment samples may be 

discarded and no post-treatment water samples should be collected. 

Worker Safety Monitoring 

Worker safety monitoring will be conducted as required in the APHIS Safety and Health 

Manual. 

Quality Assurance and Quality Control 

Quality assurance is a way of documenting that all program operating procedures, mitigations 

and protection measures have been followed. Any deviations from these procedures, and any 

corrective actions, if necessary, will be recorded. 

Chemical purity of neat and formulated pesticides will be determined to assure that the Program 

pesticides are as described by the manufacturer, thus providing expected program treatment 

efficacy and safety. 

Negative and positive quality control samples are required to show that samples are not being 

contaminated (negative controls or blanks) and that the pesticides being analyzed are stable to 

the collection, storage, and shipment process prior to laboratory analysis (positive controls or 

spikes). 
Documentation 

A checklist, provided in Appendix A, describes all the QNQC conducted to assure adherence to 

program operating procedures, mitigations and protection measures. 

Pesticide Samples 

In order to determine purity of neat and formulated pesticide, collect a sample of the pesticide 

from each lot obtained from the chemical supplier. Follow SOP EM - 10, Preparation of 

Control Samples and Collection of Pesticide Samples. 

Package the sample in the appropriate mailing container, making certain that it is not shipped 

with any environmental samples. ANCPL may be contacted for specific guidance on chemical 

specific handling and mailing instructions. Send the sample, along with a completed APHIS 

Form 2062, to: 

Control Samples 

APHIS, PPQ, ANPCL 

3505 25th Avenue 

Building 4 

Gulfport, MS 39501 

Blanks and field spikes will serve as quality control checks on pesticide handling and analysis 

procedures. Follow SOP EM - 10, Preparation of Control Samples and Collection of Pesticide 

Samples 

EMP Appendix A 

Operational Procedures/Mitigation Measures Checklist 

Notifications & Consultations 

Met with private, State and Federal cooperators to locate sensitive environmental areas 

and gain information needed to develop protecti_on measures. 

Held public meeting(s) (scoping) to identify issues of public concern. 

Notified nearby beekeepers of program operations (malathion and Carbaryl sprays). 

Environmental Requirements 

Prepared EA and FONSI addressing endangered and threatened species and candidate 

Followed all applicable Federal, State, Tribal and local environmental laws and 

regulations, in conducting grasshopper control operations. 

Implemented all agreed to E&T protection measures. 

Implemented the current GW1⁄2MC EMP. 

Provided list(s) of all sensitive sites and E&T protection measures, or a negative report to 

EMT. 

Pre Treatment Ground & Operational Preparation 

Maps (hardcopy or GIS) prepared which clearly delimit treatment boundaries and 

indicate locations of sensitive sites and buffer zones. 

Maps provided to applicator. 

All program personnel received instruction on the proper use of equipment, materials, 

and procedures. 

Treatment area visited aerially or on the ground to verify boundaries and location of any 

sensitive sites. 

Detailed Work Plan prepared (PPQ Form 136). 

Spill contingency plan was in place throughout operations. 

Spill kit was present at pesticide storage area. 

Current label and MSDS were present wherever pesticide was stored or applied. 

EPA and State approved label instructions were strictly followed. 

All USDA, APHIS, PPQ personnel had baseline cholinesterase test in accordance with 

APHIS safety and Health Manual. 

Established effective protection measures for sensitive sites. 

All employees who planned, supervised, recommended, or performed pesticide 

treatments possess certification under the APHIS Certification Plan, and/or meet all 

requirements of the States wherein treatments were performed. 

Aircraft Specific: 

Treatment boundaries, sensitive sites, and buffer zones were marked either by flagging or 

by GPS coordinates. 

Checked aircraft hoppers, booms, hoses, and nozzles for leaks. 

Checked aircraft systems for compliance with contract specifications - nozzle 

orientation, number, size and type, shut-off valves, by-pass lines, spray system pressure, 

etc. 
Aircraft spray tanks were inspected and cleaned of any contamination. 

Completed and filed PPQ Form 816, Aircraft and Pilot Qualification Acceptance Report. 

Treatment 

Maintained radio contact with applicator and treatments were halted if conditions 

warranted. 

Maintained Pesticide Application Record - amount applied to each block, daily amount 

applied, daily amount received, amount on hand at end of each day. 

Post Treatment Ground & Operational 

Collected and mailed samples of neat and formulated pesticide to ANPCL for analysis. 

Documented complaints and recorded visits and telephone calls from the public regarding 

program activities and responses to any complaints. 

Documented any accidents, safety violations, pesticide spills, and leaks in aircraft 

systems or pesticide storage and loading systems. 

Weather conditions were monitored and recorded during applications. Weather log 

completed and on file. 

Daily Aircraft Record (PPQ Form 802) maintained and on file. 

Pesticide containers and bait bags were disposed of in accordance with relevant 

regulations. 

Mixing, loading, and unloading of chemicals were performed in areas where risk of 

contaminating stream or other bodies of water would be minimized. 

ULV aerial applications were not made: 

Within 500 feet or directly on any crops for which it is not labeled, or any crop for which 

a tolerance has not been established, unless an exemption under Section 18 of FlFRA has 

been granted. 

Within 500 feet of reservoirs, lakes, ponds or wetlands (i.e. swamps, bogs, marshes and 

potholes).