CHAPTER 2 

ALTERNATIVES 

ALTERNATIVES 

TABLE OF CONTENTS 

Page 

Introduction.......................................................................................................................................................................2-1 

BLM Programs Responsible for Herbicide Treatments..................................................................................................2-1 

Wildland Fire Management .....................................................................................................................................2-2 

Rangeland Management...........................................................................................................................................2-3 

Forest and Woodland Management.........................................................................................................................2-3 

Riparian Management..............................................................................................................................................2-4 

Wildlife, Fisheries, and Threatened and Endangered Species Management..........................................................2-4 

Other Programs ........................................................................................................................................................2-5 

Vegetation Treatment Planning and Management...........................................................................................................2-5 

Land Use Planning ...................................................................................................................................................2-5 

Site Selection and Treatment Priorities...................................................................................................................2-6 

Vegetation Treatment Methods........................................................................................................................................2-8 

Integrating Vegetation Treatments..........................................................................................................................2-8 

Vegetation Treatment Method Selection.................................................................................................................2-9 

Herbicide Active Ingredients Evaluated under the Proposed Alternatives.....................................................................2-9 

Herbicide Modes of Action and Treatment Methods................................................................................................... 2-13 

Description of the Alternatives...................................................................................................................................... 2-14 

Alternative A – Continue Present Herbicide Use (No Action Alternative)......................................................... 2-14 

Alternative B – Expand Herbicide Use and Allow for Use of New Herbicides in 17 Western States 

(Preferred Alternative).......................................................................................................................................... 2-17 

Alternative C – No Use of Herbicides.................................................................................................................. 2-19 

Alternative D – No Aerial Application of Herbicides.......................................................................................... 2-19 

Alternative E – No Use of Sulfonylurea and other Acetolactate Synthase-inhibiting Active Ingredients......... 2-20 

Determination of Treatment Acreages.......................................................................................................................... 2-21 

Non-herbicide Treatment Method Acreages used in Cumulative Effects Analysis............................................ 2-21 

Alternatives Considered but Not Further Analyzed...................................................................................................... 2-22 

Herbicide Treatment Standard Operating Procedures and Guidelines......................................................................... 2-22 

Prevention of Weeds and Early Detection and Rapid Response ......................................................................... 2-23 

Herbicide Treatment Planning.............................................................................................................................. 2-25 

Revegetation .......................................................................................................................................................... 2-27 

Special Precautions........................................................................................................................................................ 2-28 

Special Status Species........................................................................................................................................... 2-28 

Wilderness Areas................................................................................................................................................... 2-29 

Cultural Resources................................................................................................................................................ 2-29 

Monitoring ..................................................................................................................................................................... 2-35 

Monitoring Guidance used by BLM in Vegetation Management ....................................................................... 2-37 

Monitoring Methods and Research....................................................................................................................... 2-38 

Coordination and Education.......................................................................................................................................... 2-39 

Mitigation ...................................................................................................................................................................... 2-40 

Summary of Impacts by Alternative ............................................................................................................................. 2-40 

 

BLM Vegetation Treatments Using Herbicides 2-i June 2007 

Final Programmatic EIS 
ALTERNATIVES 

List of Figures 

2-1 Summary of Acres Treated Using Herbicides during 1997-2005.................................................................. 2-17 

2-2 National Early Warning and Rapid Reponse System for Invasive Plants ..................................................... 2-26 

List of Tables 

2-1 Herbicide Active Ingredients Proposed, Evaluated, and included in Current Environmental Impact 

Statements of the Bureau of Land Management............................................................................................. 2-11 

2-2 States in which Herbicides are Approved for Use on Public Lands Based upon Current Environmental 

Impact Statements, Court Injunctions, and Changes in Registration Status.................................................. 2-12

2-3 Herbicides Approved and Proposed for Use on Public Lands....................................................................... 2-15 

2-4 Average Number of Acres Treated Annually for Each BLM State Jurisdiction during 1997-2005............. 2-17 

2-5 Historic Use of Herbicides by the BLM and Projected Future Use of Herbicides by the BLM under 

Each Alternative .............................................................................................................................................. 2-18 

2-6 Comparison of the Alternatives....................................................................................................................... 2-19 

2-7 Prevention Measures........................................................................................................................................ 2-24 

2-8 Standard Operating Procedures for Applying Herbicides.............................................................................. 2-30 

2-9 Mitigation Measures........................................................................................................................................ 2-41 

2-10 Summary and Comparison of Effects on Resources by Alternative.............................................................. 2-43 

BLM Vegetation Treatments Using Herbicides 2-ii June 2007 

Final Programmatic EIS 
ALTERNATIVES

CHAPTER 2 

ALTERNATIVES 

Introduction 

This chapter discusses the preferred and alternative 

actions that have been developed to treat vegetation

using herbicides on public lands in the western U.S., 

including Alaska. The preferred and alternative actions 

are those that could be taken to feasibly attain, or

approximate the BLM’s objectives for vegetation 

management, as expressed in its programs, policies, and

land use plans. 

Alternatives were developed to respond to the various 

significant issues and alternative proposals raised during

scoping, yet still meet the project’s purpose and need 

described in Chapter 1. Alternatives were also

developed to ensure BLM compliance with federal,

tribal, state, and local regulations. This chapter also 

includes mitigation measures for the proposed action 

and alternatives. 

As described in the Scoping Comment Summary Report

for the Vegetation Treatments Programmatic EIS

(ENSR 2002), alternative proposals generated during 

scoping primarily focused on the types of herbicides 

that would be used by the BLM, methods of application,

and amounts of herbicides applied. To help the reader 

better understand the alternative proposals, this chapter 

1) identifies BLM programs primarily responsible for 

treatment of vegetation using herbicides; 2) describes

the types of planning and project implementation that 

must occur before herbicides can be used on public

lands; and 3) lists the herbicides evaluated in the PEIS, 

their mode of action, and their methods of application. 

These sections are followed by a description of the five 

alternatives developed for this PEIS, and a summary of

1) standard operating procedures (SOPs) and special 

precautions that would apply under all alternatives, 2)

additional protective (mitigation) measures developed 

during preparation of the PEIS, and 3) environmental

and socioeconomic impacts that would result from 

implementation of the alternatives. 

BLM Programs Responsible for 

Herbicide Treatments 

In order to be effective, vegetation management by the 

BLM must involve all programs that rely on healthy 

plant species and communities to meet their objectives. 

The BLM’s overarching goal for vegetation 

management is as follows: 

Through an interdisciplinary collaborative 

process, plan and implement a set of actions 

that improve biological diversity and 

ecosystem function and which promote and

maintain native plant communities that are 

resilient to disturbance and invasive species. 

Healthy functioning plant communities will 

enhance the ability to attain economic benefits 

on public lands (USDI BLM 2006b).

If this goal is met, eventually the number of acres

needing treatment should be reduced as a result of

overall improvement in conditions. To achieve this goal, 

the BLM must 1) understand and plan for the condition

and use of public lands, 2) focus on restoring sites that

will most benefit from treatments, 3) select the 

appropriate treatments and SOPs to improve the 

likelihood of restoration success, 4) monitor treatments 

to better understand what treatments are successful or 

unsuccessful, and 5) convey information about

treatment activities to BLM staff and the public. 

Concurrently, public lands must be administered under 

the principles of multiple use and sustained yield in 

accordance with the intent of Congress as stated in the

FLPMA. Thus, vegetation must be managed to protect 

and enhance the health of the land while providing a 

source of food, timber, and fiber for domestic needs 

(USDI BLM 2000c). Land-disturbing activities must be

conducted in a manner that minimizes ecosystem

fragmentation and degradation, and lands should be

rehabilitated when necessary to safeguard the long-term 

diversity and integrity of the land. 

Vegetation treatments using herbicides are primarily

conducted by the Wildland Fire Management, 

Rangeland Management, Public Domain Forest 

BLM Vegetation Treatments Using Herbicides 2-1 June 2007 

Final Programmatic EIS 
ALTERNATIVES

Management, Riparian Management, and Wildlife and 

Fisheries Management programs. Each program, as 

described below, has its own objectives for vegetation 

management, but still must meet the broad goal

identified above. Types of herbicide treatments 

conducted by these programs include hazardous fuels 

reduction, weed control, fish and wildlife habitat

improvement, habitat improvement for threatened and 

endangered species, and restoration of riparian habitats. 

Wildland Fire Management 

Efforts to reduce the risk of wildfire are primarily the

responsibility of the Wildland Fire Management

program. During fiscal year (FY) 2005, the Wildland 

Fire Management program conducted hazardous fuel

treatments on about 542,000 acres in the WUI and 

nearly 727,000 acres in non-WUI areas. The program 

conducted Emergency Stabilization and Burned Area

Rehabilitation activities on nearly 880,000 acres. 

Together, the USDI and Forest Service conducted over 

3 million acres of hazardous fuels treatments and treated

nearly 2.4 million acres in the WUI during FY 2005

(USDI BLM 2006c, d). Between 2001 and 2006, federal 

land management agencies invested more than 60% of

fuels treatment dollars in the WUI, enabling 

collaborative treatment of some 8.5 million acres near 

communities (USDI BLM 2006c). 

Prior to 1998, the BLM managed hazardous fuels on

approximately 57,000 acres annually. Historically,

approximately 70% of acres were managed to restore 

fire-adapted ecosystems, while the remaining 30% were

managed to reduce wildfire risks to communities. 

Under current direction, the number of acres treated

annually by the BLM to reduce wildland fire risk would

increase significantly, to about 3.5 million acres in the 

western U.S., including Alaska, and most treatments

would occur in the WUI. Although all treatment

methods would be used, prescribed fire and mechanical

treatments would account for most fuels reduction in the

continental U.S., and wildland fires for resource use 

would account for most fuels reduction in Alaska. 

The Wildland Fire Management program is guided by

the policies expressed in the following national policy 

documents: 1) National Fire Plan (USDI and USDA 

2001a); 2) Healthy Forests Initiative of 2002 and

Healthy Forests Restoration Act of 2003 (Public Law 

108-148); 3) Chapter 3 (Interagency Burned Area 

Emergency Stabilization and Rehabilitation) in BLM

Manual 620 (Wildland Fire Management; USDI BLM

2004b); 4) A Collaborative Approach for Reducing

Wildland Fire Risks to Communities and the 

Environment 10-Year Comprehensive Strategy 

Implementation Plan (USDI and USDA 2006a); 5) 

Protecting People and Sustaining Resources in Fire 

Adapted Ecosystems: A Cohesive Strategy (USDI and 

USDA 2006b); 6) Draft Interagency Burned Area

Emergency Response Guidebook (USDI and USDA 

2006c); 7) Interagency Burned Area Rehabilitation 

Guidebook (USDI and USDA 2006d); and 8) Draft

Burned Area Emergency Stabilization and

Rehabilitation Handbook (H-1742-1; USDI BLM 

2006a). 

Wildland Urban Interface (WUI) 

The WUI has generally been defined by the National 

Wildfire Coordinating Group (NWCG) as “the line, area

or zone, where structures and other human development 

meet or intermingle with undeveloped wildland or 

vegetative fuel.” A more specific definition is provided 

in the Healthy Forests Restoration Act of 2003: 

1. An area within or adjacent to an at-risk community

that is identified in recommendations to the Secretary of 

the Interior or Agriculture in a community wildfire

protection plan (CWPP); or 

2. In the case of an area for which a CWPP is not in 

effect: 

(a) an area extending 1⁄2 mile from the boundary of

an at-risk community; 

(b) an area within 11⁄2 miles from the boundary of an

at-risk community, including any land that has a 

sustained steep slope that creates the potential for 

wildfire behavior endangering the at-risk

community; has a geographic feature that aids in

creating an effective fire break such as a road or 

ridge top; or is in Fire Regime Condition Class 3, 

as documented by the Secretary of the Interior in

the project-specific environmental analysis; and 

(c) an area that is adjacent to an evacuation route for 

an at-risk community that the Secretary 

determines, in cooperation with the at-risk

community, requires hazardous fuel reduction to 

provide safer evacuation from the at-risk 

community. 

The variation in the WUI definition allows local issues

to drive the definition, but makes national mapping of 

WUI difficult. 

BLM Vegetation Treatments Using Herbicides 2-2 June 2007 

Final Programmatic EIS 
ALTERNATIVES

Rangeland Management 

Approximately 165 million acres of public lands are

upland rangeland, of which approximately 160 million 

acres are open to livestock grazing (USDI BLM 2006c). 

The Rangeland Management program in Alaska is 

responsible for reindeer grazing on approximately 5 

million acres in western Alaska. The Rangeland 

Management program is responsible for upland health 

management, assessment, and restoration; rangeland 

improvement planning and implementation; allotment

planning and administration; and resource monitoring. 

Management of rangeland ecosystems is conducted on a 

landscape basis through land use plans. 

Vegetation treatment activities conducted by this 

program are designed to promote compliance with the 

state and regional rangeland health standards, but 

specific benefits of these projects often include

livestock forage improvement, wildlife habitat 

improvement, suppression of plants that are toxic to 

wildlife and livestock, removal of plants that compete 

with more desirable vegetation, improvement of

watershed conditions on rangelands, and restoration of 

native plant communities. 

Vegetation treatments on public lands also include 

activities to control invasive species such as noxious 

weeds. The BLM uses an integrated pest management

approach, more specifically integrated vegetation 

management. The goal of integrated vegetation

management is to control invasive and unwanted 

vegetation, to prevent the spread of noxious weeds, to

eradicate early-detected noxious weed species in areas 

where certain weeds have not yet become established,

and to control weeds where they have become

established. Vegetation control methods include 

physical and biological controls, and use of herbicides. 

The policy, direction, and requirements for planning and

implementing integrated weed management are given in

BLM Manual 9015, Integrated Weed Management

(USDI BLM 1992b). 

A total of 205,256 acres were treated to prevent the 

spread of noxious weeds and invasive plants in fiscal

year (FY) 2005, and an estimated 317,959 acres were 

treated in FY 2004 by the Invasive and Noxious Weed 

program (USDI BLM 2006c). In addition, 3.9 million 

acres were inventoried for weeds during FY 2005. 

Currently, the funding and labor resources available to

combat weeds dictate a containment strategy. Actions 

will continue to be targeted at preventing the spread of 

weeds into the most vulnerable areas (USDI BLM

2000b). 

Forest and Woodland Management

Approximately 26 percent (69 million acres) of the 

lands managed by BLM consist of forestlands and

woodlands (USDI BLM 2006e). Of these lands, 57

million acres are classified as woodlands and 12 million

acres are classified as forestlands. Two and one-half 

million acres are managed under the Oregon and

California (O&C) Grant Lands program, while the 

remaining 66.6 million acres are managed under the 

Public Domain Forest Management program. 

Woodlands are defined as land with 5% or more cover

of low-stature tree species not typically used in

commercial wood products, including land that 

formerly had such tree cover and will be naturally or

artificially regenerated. Forestland is defined as land

that has 10% or more cover of tall-stature tree species 

typically used in commercial wood products, including 

land that formerly had such tree cover and will be

naturally or artificially regenerated. 

Approximately 36.5 million acres of forestlands and

woodlands are managed by the BLM in Alaska. These 

consist primarily of black spruce (14.7 million acres)

and white spruce (17.2 million acres) woodlands. The 

remaining 4.6 million acres consist of many different

forest types, including paper birch, aspen, balsam 

poplar, mountain hemlock and Sitka spruce. 

Approximately 16 million of the 32 million acres of

BLM forestlands and woodlands found in the remaining 

16 western states consist of pinyon/juniper woodlands, 

where a mix of pinyon pine and juniper tree species 

predominates. Approximately 2.7 million acres are

comprised of the Douglas-fir forest type, 1.9 million

acres are the western juniper forest type, 1.1 million

acres are the ponderosa pine forest type, and 0.3 million 

acres each are the lodgepole pine and aspen forest types. 

The remaining 10 million acres consist of a wide variety 

of forest and woodland types. 

The Public Domain Forest Management and O&C 

Grant Lands programs are responsible for timber and

non-timber special forest product sales, reforestation 

efforts, fish and wildlife habitat improvement, and

forest vegetation composition and structure 

improvements intended to increase diversity and

productivity of forest landscapes, as well as their 

resiliency in response to disease, insects, and wildfire. 

BLM Vegetation Treatments Using Herbicides 2-3 June 2007 

Final Programmatic EIS 
ALTERNATIVES

The FLPMA and BLM Manual 5000-1, Forest

Management Public Domain (USDI BLM 1991c), 

direct the policy of the Public Domain Forest

Management program, including requirements for 

planning and implementing forestry and woodland 

management projects. 

Management of the O&C Grant Lands program is 

authorized under The Oregon and California Grant

Lands Act of 1937 (43 U.S.C. 1181). The FLPMA

applies to all public lands, including the O&C grant 

lands by definition (§103(e)). However, §701(b) of 

FLPMA (43 USC 170) provides that if any provision of

FLPMA is in conflict with or inconsistent with the

Oregon and California Grant Lands Act and Coos Bay 

Wagon Road Act, insofar as they relate to management

of timber resources and disposition of revenue from 

lands and resources, the latter Acts will prevail. 

Treatments that are addressed in this document include: 

1) reducing plant competition to enhance the growth of 

desired tree species and structures, 2) managing forest 

stands to provide habitat for wildlife and prevent

epidemic insect or disease outbreaks, and 3) managing 

vegetation that could serve as fuel for wildfires. In

2006, the program implemented forest restoration 

treatments on 31,948 acres and forest management

treatments on 28,644 acres (USDI BLM 2006c). Sales 

of timber, wood products, and non-timber special forest

products totaled nearly $36.1 million during FY 2005 

(USDI BLM 2006d). 

Riparian Management 

The BLM manages over 23 million acres of riparian and 

wetland areas, comprising about 9% of public lands, 

and providing habitat for roughly 80% of the fish and

wildlife species on public lands. The Riparian

Management program’s responsibilities include 

watershed, riparian, and wetland inventories, 

assessments, maintenance, restoration, and 

reconstruction. During 2005, the program assessed the 

condition of over 4,300 miles of streams, implemented

enhancement projects on approximately 310 acres of

wetlands and 542 miles of streams, and monitored over 

8,200 acres of lakes and wetlands and 2,380 miles of

streams (USDI BLM 2006c). 

Wildlife, Fisheries, and Threatened 

and Endangered Species Management 

The BLM manages nearly 261 million acres in the 17

western states, including some of the nation’s most

ecologically diverse wildlife habitat—more habitat than 

any other federal or state agency. BLM-administered

land is important to big game, waterfowl, shorebirds, 

songbirds, raptors, and hundreds of species of non-game

mammals, reptiles, and amphibians. 

The BLM’s Wildlife Management program provides 

support for land use planning and development of 

conservation plans for at-risk species, such as the

mountain plover, greater and Gunnison sage-grouse, 

lesser prairie chickens, white-tailed, black-tailed and 

Gunnison’s prairie dogs, and their habitats. BLM 

biologists work with partners in big game habitat

restoration, including reestablishment of bighorn sheep

into historically occupied habitats, restoration of mule 

deer winter ranges, and enhancement of summer ranges 

for elk. BLM biologists continue to monitor habitat 

conditions and populations of numerous species, 

including prairie dogs, amphibians, sage-grouse, 

burrowing and spotted owls, muskox, caribou, and

moose populations. One of the Wildlife Management 

program’s highest priorities is development and 

implementation of conservation plans for the greater 

and Gunnison’s sage-grouse. The BLM manages over 

30 million acres of sage-grouse habitat in an 11-state

region. 

The BLM Fisheries program oversees management 

that directly affects over 155,000 miles of fish-bearing 

streams and 4 million acres of lakes and reservoirs. 

Water bodies on BLM-administered lands are diverse,

ranging from isolated desert springs harboring 

populations of rare and unique fishes, to large interior

Columbia River tributaries supporting salmon and

resident fishes of exceptional regional and national

value. These waters also support subsistence fisheries 

that sustain Native American cultural heritages, as well

as fisheries providing recreational opportunities for the

growing human population of the western United

States. 

The BLM’s Threatened and Endangered Species

Management program is responsible for the 

management and recovery of federally-listed species, 

including plants, wildlife, and fish on public lands. In 

addition, the program is responsible for the management

of sensitive plant species on public lands. 

The Wildlife Management, Fisheries Management, and

Threatened and Endangered Species Management

programs support the Great Basin Restoration and the

Conservation of Prairie Grasslands initiatives. In 2000, 

the BLM implemented the Great Basin Restoration 

Initiative, a regional restoration strategy to restore and 

BLM Vegetation Treatments Using Herbicides 2-4 June 2007 

Final Programmatic EIS 
ALTERNATIVES

enhance nearly 70 million acres of sagebrush habitat in 

Nevada, Utah, Oregon, and Idaho, and California. The 

focus of this effort is to prevent much of the land burned

in wildfires from being overwhelmed by annual grasses 

and noxious weeds. The same year, the BLM also began

the Conservation of Prairie Grasslands initiative to 

protect and maintain important grasslands on 

approximately 15 million acres of short- and mixedgrass prairie in a 7-state area that extends from Canada

to Mexico. Both efforts focus on managing healthy

landscapes and protecting and restoring habitats to

benefit wildlife. The Wildlife Management and

Fisheries Management programs are also responsible 

for managing subsistence uses on public lands in

Alaska. 

FLPMA and several manuals (BLM Manual 6500 -

Wildlife and Fisheries Management; BLM Manual 

6720 - Aquatic Resource Management; BLM Manual 

6780 - Habitat Conservation Management Planning; 

and BLM Manual 6840 - Special Status Species

Management) outline the policy, direction, and 

requirements for planning and implementing 

management and treatments for fish, wildlife, and 

special status species and their habitat. 

Other Programs 

Several other programs within the BLM also treat 

vegetation using herbicides, although to a lesser extent

than the programs listed above (USDI BLM 2004a). 

These include the Cultural Resources, Recreation, 

Wilderness, Energy and Minerals, Transportation, and

Realty and Ownership Management programs. 

Herbicides are used to manage vegetation on recreation

and wilderness areas and on lands disturbed by energy

and mineral development. The Realty and Ownership 

Management program issues ROW. Herbicides are 

often preferred for use on ROW over other treatment

methods or in conjunction with other treatments because

they are often most effective at controlling or removing

vegetation before, or shortly after, it emerges. Other 

facilities requiring vegetation management include

campgrounds, visitor centers, and other recreational 

facilities; administrative buildings; communications 

facilities; and roads. At these sites, vegetation 

management focuses on controlling vegetation that can

pose a safety or fire hazard, or is not aesthetically 

pleasing The BLM uses premergence and 

postemergence herbicides to control emerging 

vegetation. 

Vegetation Treatment Planning 

and Management 

The BLM’s Strategic Plan (USDI BLM 2000a); A 

Collaborative Approach for Reducing Wildland Fire 

Risks to Communities and the Environment 10-Year 

Comprehensive Strategy Implementation Plan (USDI

and USDA 2002); Partners Against Weeds: An Action

Plan for the Bureau of Land Management (USDI BLM

1996), and Pulling Together: National Strategy for 

Invasive Plant Management (USDI BLM 1998) identify 

broad objectives for management of vegetation on

public land, while treatment activities at the local level

are guided by the goals, standards, and objectives of 

land use plans developed for each BLM field office. 

Although vegetation management actually occurs at the 

local level, policies established at the national level help 

direct local efforts. Examples of national policy

direction designed to improve vegetation management

efforts include development of rangeland health

standards and development of assessments and

evaluations for land, water, air, and vegetative health

(USDI BLM 2002a). These assessments provide 

information that is used to ascertain achievement of 

land health standards and to identify causes for not 

meeting standards. These assessments are used to help

identify restoration activities and establish restoration

priorities. 

Land Use Planning 

Land use planning decisions are the basis for every onthe-ground action the BLM undertakes. Land use plans, 

usually in the form of RMPs, ensure that public lands

are managed in accordance with the intent of Congress, 

as stated in FLPMA (43 USC 1701 et seq.), under the 

principles of multiple use and sustained yield. As 

required by FLPMA and BLM policy, “public lands 

must be managed in a manner that protects the quality 

of scientific, scenic, historical, ecological, 

environmental, air and atmospheric, water resource, and 

archaeological values; that, where appropriate, will

preserve and protect certain public lands in their natural 

condition; that will provide food and habitat for fish, 

and wildlife and domestic animals; that will provide for 

outdoor recreation and human occupancy and use; and 

that recognizes the Nation’s need for domestic sources 

of minerals, food, timber, and fiber from the public 

lands by encouraging collaboration and public

participation throughout the planning process.” 

BLM Vegetation Treatments Using Herbicides 2-5 June 2007 

Final Programmatic EIS 
ALTERNATIVES

Land use plans guide land use and vegetation

management decisions within the geographic area they 

cover, and provide specific goals, standards, objectives, 

and expected outcomes that apply to vegetation

treatment projects and activities. These plans identify 

important local resources to be protected, identify 

historic, current, and future desired conditions for 

vegetation, and describe land use activities and levels

that are appropriate to maintain healthy vegetation. 

Wise planning also considers the importance of other 

natural resources, such as water and soil, when

developing vegetation restoration strategies. In addition, 

BLM land use plans identify transportation facilities, 

utility corridors, and other infrastructure development

on public lands that is likely to receive some form of

vegetation treatment. 

To assist with vegetation management planning, key

resource elements, such as plant community types,

aquatic habitats, sensitive areas, and invasive species 

concentration areas, are inventoried and mapped

regionally and district-wide. Inventories and maps allow 

field managers to identify areas of high ecological

integrity; to ensure that there is suitable habitat for 

wide-ranging species; to identify areas where land uses

may be incompatible with long-term ecosystem health;

and to identify areas that could benefit from improved

management. Inventories and mapping are also done at 

the local level to help managers better understand how 

proposed projects fit in with vegetative conditions on a 

larger scale, such as within ecoregions or watersheds. 

The BLM also cooperates with other agencies, 

organizations, and landowners in regional planning

efforts, including establishment of Cooperative Weed

Management Areas. 

Site Selection and Treatment Priorities 

Upon approval of a land use plan, subsequent 

implementation decisions are often put into effect by

developing implementation plans. Implementation 

plans, also referred to as “activity plans,” tend to focus 

on multiple resources, and include vegetation treatment

activities within a BLM field office jurisdiction. 

Implementation plans are made with the appropriate 

level of NEPA analysis; implementation decisions are 

usually made by BLM field managers. Implementation 

decisions identify site-specific vegetation management

practices to achieve desired outcomes laid out in the 

land use plans. Some examples of practices include

fuels treatments and integrated vegetation management

techniques for weed infestations. 

General Site Selection and Treatment Priorities 

Several factors influence where treatments will occur 

and treatment priorities: 

• Statutory mandates, including the FLPMA, 

ESA, HFRA, and Taylor Grazing Act. 

• Program guidance including such initiatives as 

the Healthy Forests Initiative and the Great

Basin Restoration Initiative. 

• Goals of the Strategic and Annual Performance 

Plans. 

• Existing risks to resources. 

• Likelihood of success in restoring natural biotic

communities. 

• Cost-effectiveness of actions. 

National priorities have been established for various 

BLM vegetation management programs. These 

priorities were developed for use in conjunction with 

state and local office priorities for meeting restoration

goals, and address site-specific conditions and/or issues 

as laid out in the land use plan. For example, the 

following treatment priorities have been established to

promote integrated efforts across BLM resource

programs that manage vegetation: 

• WUI community protection treatments that are 

designed to reduce the risk of wildfire to the

community and/or its infrastructure developed 

collaboratively with the community. 

• Treatments to restore or maintain healthy, 

diverse, resilient, and productive native plant

communities. 

• Special status species habitat improvement

projects designed to improve or protect special 

status fish, wildlife, and plant habitat. 

• Treatments that will be planned, implemented, 

and/or monitored using funding from multiple 

sources, both internal and external. 

• Landscape treatments (>1,000 acres for 

mechanical and >4,500 acres for prescribed 

fires), coordinated across field office 

boundaries, to improve treatment effectiveness. 

• Contracted treatments that support economic 

opportunities for rural communities and/or high 

potential to use stewardship contracting 

authorities. 

BLM Vegetation Treatments Using Herbicides 2-6 June 2007 

Final Programmatic EIS 
ALTERNATIVES

• Treatments that have a high potential for 

woody biomass utilization. 

Weed Treatment Site Selection and Treatment 

Priorities 

For noxious weeds and invasive plants, vegetation

treatment priorities identified in the EIS Vegetation 

Treatment on BLM Lands in Thirteen Western States

(USDI BLM 1991a) are still applicable. They are: 

• Take actions to prevent or minimize the need 

for vegetation controls, where feasible. 

• Use effective nonchemical methods of 

vegetation control, where feasible. 

• Use herbicides only after considering the 

effectiveness of all potential methods.

Development of a weed management strategy is set up

at the local level and aligned with the land use planning

objectives. 

Actions to prevent or minimize the need for vegetation 

control can include protecting intact systems;

maintaining conditions that have led to healthy lands 

(e.g., allowing natural fires to burn); reducing the

impact of ongoing activities (e.g., improving grazing 

management practices); and applying mitigation 

measures to new projects to minimize soil and

vegetation disturbance and avoid introductions of 

invasive species. 

If treatment is required, efforts are focused on activities 

that restore natural ecosystem processes, and on

ventures that are likely to succeed and provide the

greatest benefits with the least expenditure of capital. 

Also beneficial to treatment success is site-specific

analysis that includes 1) a determination of site potential 

under current circumstances, 2) an evaluation of land

health based on land assessment studies, 3) an 

assessment of causes of land degradation, 4) an

assessment of the likely effectiveness of treatment

methods, and 5) an evaluation of the success of

restoration efforts on similar types of land. 

Several management objectives are considered when 

determining appropriate treatment of an infestation. 

• Containment to prevent weed spread from

moving beyond the current infestation 

perimeter; 

• Control to reduce the extent and density of a 

target weed; 

• Eradication to completely eliminate the weed

species including reproductive propagules (this 

is usually only possible with small

infestations); and 

• Restoration of native plant communities and 

habitats using native species that are adapted to 

the project site to compete with invasives. 

Several variables are considered when determining 

what, when, and how weed populations should be 

treated. These include, but are not limited to: 

• The species – is it an aggressive non-native 

species that could be on a state noxious weed 

list or an adjacent state’s noxious weed list, or 

that could be a species known for altering plant

communities or ecological processes on a 

regional basis? If a species is native to a 

project area, how does current management

influence the increase of the species beyond

acceptable levels?

• Location – is the infestation found in a special 

management area, in a formerly uninfested 

area, or upslope/upstream from current

treatments (i.e., could the species reinfest

treated areas)? Does the infestation pressure or 

negatively impact special status plants or their 

habitats?

• Extent – is the infestation at a size where 

eradication is possible, in an area where other 

infestations are numerous, or of a size that may 

not be able to be eradicated, but can be 

contained or controlled to some extent? Is the 

extent of the infestation so large that one

treatment would cover all of the known 

locations of an endemic species or its required 

resources?

The following suggests a decision process for 

prioritizing weed treatments in order to focus efforts 

towards success. It provides broad guidance to be

adapted to the local level based on species, size, and 

extent of infestations. Priorities are then matched with 

the management objectives listed above. 

1. Highest Priority: New aggressive infestations in an 

uninfested area or small infestations in areas of special

BLM Vegetation Treatments Using Herbicides 2-7 June 2007 

Final Programmatic EIS 
ALTERNATIVES

concern (e.g., wilderness, research natural areas).

Management objective: Eradicate. 

2. Higher Priority: Areas of high traffic or sources of

infestation and larger infestations in areas of special

concern. Management objective: Control. 

3. High Priority: Existing large infestations or roadside

infestations where spread can be checked or slowed. 

Management objective: Contain. 

The overriding goal is to prioritize treatment methods 

based on their effectiveness and likelihood to have

minimal impacts on the environment, and to restore 

desirable vegetation on lands where necessary (i.e.,

where desired vegetation cannot reestablish naturally). 

Vegetation Treatment Methods 

Although this PEIS focuses on BLM vegetation

treatments using herbicides, such treatments are only a

small part of a larger effort proposed by the BLM to 

treat vegetation on approximately 6 million acres each

year. In addition to herbicides, the BLM uses fire and 

manual, mechanical, and biological control treatment

methods. The use of these non-herbicide methods is 

discussed in more detail in the PER. As with herbicides, 

treatments using other methods can occur anywhere on 

public lands, although actual treatment methods, acres 

treated, and treatment locations are determined at the

local field level and by Congressional direction and

funding. Currently, the BLM is treating about 2 million 

acres annually using all methods. 

Herbicides are chemicals that kill or injure plants. 

Herbicides can be categorized as selective or nonselective. Selective herbicides kill only a specific type 

of plant, such as broad-leaved plants, while nonselective herbicides kill all types of plants. The use of 

herbicides and modes of action are discussed in more 

detail below. 

Fire use includes prescribed fire and wildland fire use 

for resource benefits. Prescribed fire is the intentional

application of fire to wildland fuels under specified

conditions of fuels, weather, and other variables. The 

intent is for the fire to stay within a predetermined area

to achieve site-specific resource management 

objectives. Wildland fire use for resource benefit is a 

fire ignited by lightening but allowed to burn within

specified conditions of fuels, weather, and topography, 

to achieve specific objectives 

Mechanical treatment involves the use of vehicles such

as wheeled tractors, crawler-type tractors, or specially 

designed vehicles with attached implements designed to

cut, uproot, or chop existing vegetation. Mechanical 

methods that may be used by the BLM include 

chaining, root plowing, tilling and drill seeding, 

mowing, roller chopping and cutting, blading, grubbing, 

and feller-bunching. 

Manual treatment involves the use of hand tools and

hand-operated power tools to cut, clear, or prune 

herbaceous and woody species. Treatments include

cutting undesired plants above the ground level; pulling,

grubbing, or digging out root systems of undesired

plants to prevent sprouting and regrowth; cutting at the 

ground level or removing competing plants around

desired species; or placing mulch around desired 

vegetation to limit competitive growth (USDI BLM 

1991a). 

Biological control involves the intentional use of 

domestic animals, insects, nematodes, mites, or

pathogens (agents such as bacteria or fungus that can

cause diseases in plants) that weaken or destroy 

vegetation (USDI BLM 1991a, Bonneville Power 

Administration [BPA] 2000). Biological control is used

to reduce the targeted weed population to an acceptable 

level by stressing target plants and reducing competition

with the desired plant species. 

Integrating Vegetation Treatments 

The BLM treats vegetation using fire, mechanical and 

manual methods, biological treatments, and herbicides. 

In an integrated vegetation management program, each 

management option is considered, recognizing that no

one management option is a stand-alone option and that 

each has its own strengths and weakness. Utilizing the

strengths of each allows for a more effective and 

environmentally sound program. When the BLM plans 

vegetation control management projects, all control 

methods should be available for use, allowing the BLM

to select the one method, or the combination of 

methods, that optimizes vegetation control with respect

to environmental concerns, effectiveness, and cost of 

control. 

No individual method will control undesirable

vegetation in a single treatment; diligence and 

persistence will be required over a number of years to

subdue vegetation such as weeds. The success of

different treatment methods depends on the type of 

vegetation being controlled. It is important to think of

BLM Vegetation Treatments Using Herbicides 2-8 June 2007 

Final Programmatic EIS 
ALTERNATIVES

these treatment methods as they relate to specific 

characteristics of weeds and other vegetation. 

Vegetation Treatment Method 

Selection 

Vegetation treatment methods are selected based on 

several parameters, which may include the following: 

• Management program/objective for the site. 

• Historic and current conditions. 

• Opportunities to prevent future problems. 

• Opportunities to conserve native and desirable 

vegetation. 

• Effectiveness and cost of the treatment

methods. 

• Success of past restoration treatments or 

treatments conducted under similar conditions 

or recommendations by local experts. 

• Characteristics of the target plant species, 

including size, distribution, density, life cycle, 

and life stage in which the plant is most

susceptible to treatment. 

• Non-target plant species that could be impacted 

by the treatment. 

• Land use of the target area. 

• Proximity to communities. 

• Slope, accessibility, and soil characteristics of

the treatment area. 

• Weather conditions at the time of treatment, 

particularly wind speed and direction,

precipitation prior to or likely to occur during 

or after application, and season. 

• Proximity of the treatment area to sensitive

areas, such as wetlands, streams, or habitat for 

plant or animal species of concern. 

• Potential impacts to humans and fish and 

wildlife, including non-game species. 

• Need for subsequent revegetation and/or

restoration. 

These parameters are considered before a treatment

method is selected (USDI BLM 1991a). For most

vegetation treatment projects, pretreatment surveys are 

conducted before selecting one or more treatment

methods. These surveys involve the consideration of all

feasible treatments, including their potential 

effectiveness based on previous experience, and best

available science, impacts, and costs. Before vegetation 

treatment or ground disturbance occurs, the BLM

consults specialists or databases for information on 

sensitive areas within the project area. The site may 

have to be surveyed for listed or proposed federal

threatened or endangered species and for evidence of 

cultural or historic sites. In some cases, areas may 

receive one or more treatments in combination, such as 

prescribed burning followed by an herbicide

application, and some areas may be treated using one or 

more treatment methods over several years. 

Herbicide Active Ingredients 

Evaluated under the Proposed 

Alternatives 

In previous EISs, a total of 25 herbicide active

ingredients were reviewed, 22 were evaluated, and 20

were approved for use in one or more states (Tables 2-1

and 2-2). The decision to approve these herbicides for 

use on public lands was based on a detailed analysis of

the risks to human health and non-target species from

the use of these chemicals. 

Since the majority of these assessments were completed

in the late 1980s, a comprehensive literature review was

conducted as part of this PEIS to determine whether 

there was any significant new information relevant to

environmental concerns regarding the continued use of 

these herbicides (McMullin and Thomas 2000). Local 

BLM field offices were also consulted for information 

from field applications suggesting that any of these 

chemicals should be re-analyzed. If so, a new risk 

assessment for that active ingredient was completed as

part of this PEIS in order to assess whether the BLM

should continue its use. 

Based on the literature review and information from the 

field, sulfometuron methyl (Oust®) was found to 

potentially have significant impacts on non-target 

vegetation when carried on soil to untreated areas,

effects that were not evaluated earlier. Thus, the toxicity 

and environmental fate of sulfometuron methyl were 

analyzed in this PEIS. It was determined that the 

remaining 19 herbicides did not require further analysis

for human health risks. However, the BLM determined

that the level of analysis contained in the non-target 

species assessments for fish and wildlife for the 

BLM Vegetation Treatments Using Herbicides 2-9 June 2007 

Final Programmatic EIS 
ALTERNATIVES

BLM 

Final Prog

Vegetation Treatments Using Herbicides 2-10 June 2007 

rammatic EIS 

previous EISs was inadequate to characterize the risks

to species of concern, including anadromous fish.

evious EISs was inadequate to characterize the risks

to species of concern, including anadromous fish.

Since the mid-1990s, the Forest Service conducted

ecological risk assessments (ERAs) for nine herbicide

active ingredients also used by the BLM: 2,4-D, 

clopyralid, dicamba, glyphosate, hexazinone, imazapyr, 

metsulfuron methyl, picloram, and triclopyr. In

addition, the Forest Service prepared interactive

spreadsheets that allowed the BLM to determine 

exposure concentrations for plants and animals under 

different application rates and exposure scenarios for 

these herbicides. The ERAs and spreadsheets are

available on the Internet at the Forest Service Pesticide 

Management and Coordination website at

http://www.fs.fed.us/foresthealth/pesticide/risk.shtml.

Since the mid-1990s, the Forest Service conducted

ecological risk assessments (ERAs) for nine herbicide

active ingredients also used by the BLM: 2,4-D, 

clopyralid, dicamba, glyphosate, hexazinone, imazapyr, 

metsulfuron methyl, picloram, and triclopyr. In

addition, the Forest Service prepared interactive

spreadsheets that allowed the BLM to determine 

exposure concentrations for plants and animals under 

different application rates and exposure scenarios for 

these herbicides. The ERAs and spreadsheets are

available on the Internet at the Forest Service Pesticide 

Management and Coordination website at

http://www.fs.fed.us/foresthealth/pesticide/risk.shtml.

Information contained in the ERAs was used by the

BLM to characterize risks to non-target species from the 

specific chemicals and is incorporated by reference into

this PEIS.

The Forest Service did not conduct ERAs for bromacil,

chlorsulfuron, diuron, and tebuthiuron. Thus, the BLM 

conducted new ERAs for these herbicides as part of this

PEIS.

The remaining six active ingredients currently approved

for use by the BLM⎯2,4-DP, asulam, atrazine,

fosamine, mefluidide, and simazine⎯have not been

used, or their use has been limited to a very small

number of acres, by the BLM for several years,

primarily due to the availability of other, more effective

approved active ingredients.

Herbicide Terminology 

Active ingredient (a.i.) is the chemical or biological 

component that kills or controls the target pest.

Adjuvant(s) are chemicals that are added to the pesticide

formulation to enhance the toxicity of the active

ingredient or to make the active ingredient easier to

handle.

Formulation is the commercial mixture of both active

and inactive ingredients.

Herbicide is a chemical pesticide used to treat

vegetation.

Herbicide resistance occurs when naturally occurring

heritable characteristics allow individual weeds to survive 

and reproduce, producing a population, over time, in

which the majority of the plants of the weed species have

the resistant characteristics.

Other ingredient(s) are those ingredients that are added

to the commercial product (formulation), but are not

herbicidally active. In the past, these were referred to as

inert ingredients.

The new active ingredients were selected based on: 1)

input from BLM field offices on types of vegetation

needing control; 2) studies indicating that these active 

ingredients would be more effective in controlling 

noxious weeds and other unwanted vegetation targeted

for control than active ingredients currently used by the 

BLM; 3) USEPA approval for use on rangelands, 

forestlands, and/or aquatic environments (see

http://cfpub.epa.gov/oppref/rereg/status.cfm?show=rere

g for information on herbicide registration and fact

sheets on all registered products); 4) responses from

herbicide manufacturers to a request from the BLM in 

October 2001 for a list of herbicides not currently 

approved for use on public lands that may be 

appropriate to control vegetation; 5) the ability of the

herbicide formulations to be applied on a variety of

plant species needing control; 6) the level of risk of the 

herbicidal formulations to human health and the

environment; and 7) the funds available to the BLM to 

conduct human health and ecological risk assessments

of the proposed herbicides.

The BLM proposes to use four new herbicide active

ingredients that are registered and available for 

use⎯diflufenzopyr (as a formulation with dicamba), 

diquat, fluridone, and imazapic. All four of the

herbicides have been deemed effective in controlling 

vegetation, have minimal effects on the environment

and human health if used properly, and are registered

(except diflufenzopyr as a stand-alone active ingredient) 

with the USEPA. Diflufenzopyr is approved as a 

formulation with dicamba and is labeled as Distinct®

and Overdrive®, but cannot be used as a stand-alone 

active ingredient by the BLM until it is registered with

the USEPA.

Diquat is a post-emergence, nonselective herbicide that

can be applied directly to vegetation or to ponds, lakes, 

or drainage ditches for the management of aquatic weed 

species. Diquat is a cell membrane disrupter, whose

Diflufenzopyr, which is used in combination with

dicamba for weed control, inhibits the transport of auxin

in the plant. The result is an abnormal accumulation of 

auxin or auxin-like compounds in the growing points of

susceptible plants and an imbalance in growth 

hormones in the plant. The combination of 

diflufenzopyr and dicamba is registered for use in all 17

western states except Alaska and California.
TABLE 2-1 

Herbici

de Active Ingredients Propose

d, Evaluated, and include

d in Current E

nvironmental Impact 

Statements of the B

ureau of Land Management 

EIS in Which Herbicide Evaluated Summary of 

Active Ingredient

North

west Area 

Noxious Wee

d

Control Program 

(1985) 

California 

Vegetatio

n

Management 

(1988) 

Vegetatio

n Treatment on 

BLM Lands i

n 13 

Western States (1991) 

Western Orego

n Progra

m – 

Management of Com

peti

ng 

Vegetatio

n (1992) 

Active 

Ingredients 

Considere

d

A

Ing

Ev

2,4-D Yes (Esteron-99; DMA-4) 

Yes Yes Yes Yes 

2,4-D

P

Yes Yes 

Ammonium sulfa

mate Proposed, not evaluated Yes 

Amitrole Yes Evaluated, but not included Yes Asula

m

Yes Yes Yes 

Atrazine Yes Yes Yes Yes Bro

macil Yes Yes Yes 

Chlorsulfuron Yes Yes Clopyralid Yes Yes Dalapon Yes Evaluated, but not included Proposed, but not evaluated Yes Dicamba Yes (Banvel) Yes Yes Yes Yes Diquat Proposed, but not evaluated Yes Diuron Yes Yes Proposed, but not evaluated Yes Fosamine Yes Proposed, but not evaluated Yes Glyphosate Yes (Rodeo) Yes Yes Yes Yes Hexazinone Yes Yes Yes Yes Imazapyr Yes Yes Mefluidide Yes Yes Metsulfuron  methyl

Yes Yes 

Monosodium methanearsonate Proposed, but not evaluated

Yes 

Piclora

m Yes (Tordon 2

K,

Tordon 22K) 

Yes Yes Yes Yes 

Si

mazine Yes Yes Yes 

Sulfometuron  methyl

Yes Yes 

Tebuthiuron Yes Yes Yes Triclopyr Yes Yes Yes Yes Active Ingredients Evaluated or Available for Use 

4 16 17 8 25 

BLM Vegetation Treatments Using Herbicides 2-11 June 2007 

Final Programmatic EIS
ALTERNATIVES 

TABLE 2-2 

States in which Herbicides are Approved for Use on Public Lands Based upon Current Environmental 

Impact Statements, Court Injunctions, and Changes in Registration Status 1

Chemical AZ CA CO ID MT NV NM ND OK OR 

East 

OR 

West SD UT WA WY

2,4-D • • • • • • • • • y y • • • •

2,4-DP •

Asulam  }

Atrazine • • • • • • • • • } } • • • •

Bromacil • • • • • • • • • } • • • •

Chlorsulfuron • • • • • • • • } • • • •

Clopyralid • • • • • • • • } • • • •

Dicamba • • • • • • • • • y y • • • •

Diuron • • • • • • • • • } • • • •

Fosamine •

Glyphosate • • • • • • • • • y y • • • •

Hexazinone • • • • • • • • • } } • • • •

Imazapyr • • • • • • • • } • • • •

Mefluidide • • • • • • • • } • • • •

Metsulfuron 

methyl • • • • • • • • } • • • •

Picloram •  • • • • • • • y y • • • •

Simazine • • • • • • • • • } • • • •

Sulfometuron 

methyl • • • • • • • • } • • • •

Tebuthiuron • • • • • • • • • } • • • •

Triclopyr • • • • • • • • • } } • • • • 1

 These chemicals have not been approved for use in Alaska, Nebraska, and Texas. 

y Based upon the current EISs, these herbicides have been analyzed and approved for application on BLM lands.

} Based upon the current EISs, these herbicides have been analyzed and approved for application on BLM lands, but are not currently

approved for use in Oregon per court injunction (Southern Oregon Citizens Against Toxic Sprays (SOCATS) v. Watt, No. 79-1098 

(District Court of Oregon. October 20, 1982), 13 Environmental Law Report 20, 176. 

 Based upon the current EISs, these herbicides have been analyzed and approved for application on BLM lands, but application is

not allowed due to change in registration status in the state. 

mode of action is to intercept electrons from

photosynthesis and transfer the energy from

photosynthesis to various free radicals that damage cell

membranes. Diquat is registered for use in all 17 

western states.

Fluridone is a systemic, selective, aquatic herbicide that 

can be applied to the water surface or subsurface, or as a

bottom application just above the floor of the water 

body. Fluridone is absorbed from the water by the plant

shoots and taken up from the soil by the roots. In

susceptible plants, fluridone inhibits the formation of 

carotene, which is essential in maintaining the integrity 

of chlorophyll. Fluridone is registered for use in all 17

western states.

Imazapic, a selective, systemic herbicide, can be applied 

both pre-emergence and post-emergence for the 

management of selective broadleaf and grassy plant

species. Its mode of action is associated with the

synthesis of branch-chained amino acids. Imazapic is 

registered for use in all 17 western states except Alaska 

and California. 

In order to ensure that the use of these active ingredients 

is appropriate for public lands, the BLM conducted 

human health risk assessments (HHRAs) and ERAs to

assess the potential for risks to humans and non-target

plants and animals, including special status species,

from using these active ingredients. An analysis of: 1)

the toxicity and environmental fate of each active

BLM Vegetation Treatments Using Herbicides 2-12 June 2007 

Final Programmatic EIS 
ALTERNATIVES

ingredient, and for a formulation of diflufenzopyr and

dicamba (Overdrive®); 2) risks associated with

surfactants found in herbicide formulations and

herbicide active ingredient degradates; and 3) potential 

for herbicides considered in the PEIS to be endocrine 

disrupting chemicals, are provided in Chapter 4, 

Environmental Consequences, and in appendixes B, C, 

and D. 

For new and currently available herbicides that may be

proposed for use in the future, the BLM would follow 

the following steps for conducting risk assessments used

in this PEIS: 1) assess a product’s or a technology’s 

effectiveness for use on target vegetation on public

lands; 2) identify the level of data and analysis needed 

to conduct a human health and ecological risk 

assessment for that chemical; 3) determine the level of

NEPA documentation required to support a decision to

use a new product or technology; and 4) consult with 

the ESA regulatory agencies. These steps are discussed

in more detail in Appendix E. 

Herbicide Modes of Action and 

Treatment Methods 

Herbicides are chemicals that kill or injure plants. Some

herbicides are derived from plants, while others are 

manufactured synthetically. Herbicides can be classified 

by their mode of action, and include growth regulators, 

amino acid inhibitors, grass meristem destroyers, cell 

membrane destroyers, root and shoot inhibitors, and

amino acid derivatives, which interfere with plant 

metabolism in a variety of ways (Table 2-3; Bussan and

Dyer 1999). 

Herbicides can be categorized as selective or nonselective. Selective herbicides kill only a specific type 

of plant, such as broad-leaved plants. Many herbicides 

used for vegetation management are selective for 

broadleaved plants, so that they can be used to manage

such species while maintaining the desirable grass 

species in rangeland communities. Glyphosate is nonselective, so it must be used carefully around desirable 

and non-target plants (Rees et al. 1996). 

Herbicides are most effective on pure stands of a single 

weed where desirable and non-target plants are scarce

or absent (Colorado Natural Areas Program 2000). 

Herbicides are also effective for rhizomatous weed

species that are unpalatable to livestock, require 

repeated cutting or pulling for control, or are located in 

remote areas where pulling and cutting are not feasible.

Herbicides often work well in combination with other 

control treatments. For example, tamarisk, Russian

olive, and Siberian elm can be controlled by cutting 

stems close to the ground in the fall and then spraying

or painting the stems with an herbicide registered for 

that use. 

Herbicide treatments would follow BLM procedures 

outlined in BLM Handbook H-9011-1 (Chemical Pest 

Control), and manuals 1112 (Safety), 9011 (Chemical 

Pest Control), and 9015 (Integrated Weed 

Management), and would meet or exceed states’ label

standards (USDI BLM 1991a). Several herbicide 

application methods are available. The application

method chosen depends upon the treatment objective

(removal or reduction); accessibility, topography, and 

size of the treatment area; characteristics of the target

species and the desired vegetation; location of sensitive 

areas and potential environmental impacts in the 

immediate vicinity; anticipated costs; equipment

limitations; and meteorological and vegetative 

conditions of the treatment area at the time of treatment. 

Herbicide application schedules are designed to

minimize potential impacts to non-target plants and 

animals, while remaining consistent with the objective 

of the vegetation treatment program. The application

rates depend upon the target species, the presence and 

condition of non-target vegetation, soil type, depth to

the water table, presence of other water sources, and the 

label requirements. 

Herbicides can be applied aerially with helicopters or 

fixed-wing aircraft, or on the ground with vehicles or 

manual application devices. Operation of helicopters is 

more expensive than operation of fixed-wing aircraft, 

but helicopters are more maneuverable and more 

effective in areas with irregular terrain. Helicopters also

are more effective for treating target vegetation in areas 

with multiple vegetation types. 

Two or more herbicides may be applied at the same

time in a tank mix, when tank mixtures are specified on

at least one of the labels for the chemicals used in the

mix. Approximately 25% of herbicide applications on

public lands involved tank mixes during 2002-2005. 

Manual applications of herbicides are used only in small

areas, in areas inaccessible by vehicle, and in areas 

where weeds are scattered. They are sometimes 

considered when special status plants are known or 

suspected in all or a portion of a project area. Herbicides 

may be applied with a backpack applicator or spray

bottle, wick (wiped on), or wand (sprayed on). 

Herbicides can be applied to trees around the 

BLM Vegetation Treatments Using Herbicides 2-13 June 2007 

Final Programmatic EIS 
ALTERNATIVES

BLM 

Final Pr

 

Vegetation Treatments Using Herbicides 2-14 June 2007 

ogrammatic EIS 

circumference of the trunk on the intact bark (basal 

bark), to cuts in the trunk or stem (frill, or “hack and 

squirt”), to cut stems and stumps (cut stump), or 

injected into the inner bark (Tu et al. 2001). 

Herbicides can be used selectively to control specific 

types of vegetation, or non-selectively to clear all 

vegetation on a particular area. Herbicides can be 

applied over large areas and/or in remote locations 

using aircraft, or applied using spot applications in 

smaller, easily accessible locations. 

There are several drawbacks and limitations to herbicide 

use. Herbicides can damage or kill non-target plants. 

Herbicides can be toxic or cause health problems in 

humans, other animals, and other plants. Herbicides 

must be applied by someone with the appropriate 

certification identified in state laws and BLM policy 

(Colorado Natural Areas Program 2000). 

Herbicides would be applied according to the current 

label directions. The BLM would comply with changes 

in label directions that may occur in the future, and 

would comply with state registration requirements. 

Thus, if current state requirements do not allow the 

application of an herbicide approved for use in the 

PEIS, the BLM would not apply that herbicide in the 

state where it is not approved for use. 

Weed populations may develop a resistance to a 

particular herbicide over time. Herbicide resistance is 

the inherited ability of a plant to survive an herbicide 

application to which the wild-type was susceptible. 

Resistant plants occur naturally within a population and 

differ slightly in genetic makeup, but remain 

reproductively compatible with the wild-type. Herbicide 

resistant plants are present in a population in extremely 

small numbers. The repeated use of one herbicide 

allows these few plants to survive and reproduce. The 

number of resistant plants then increases in the 

population until the herbicide no longer effectively 

controls the weed. Herbicide resistance is not the natural 

tolerance that some species have to an herbicide. The 

appearance of herbicide-resistant weeds is strongly 

linked to repeated use of the same herbicide or 

herbicides with the same site of action in a monoculture 

cropping system or in non-crop areas. 

There are several things that can be done, and are being 

done by the BLM, to minimize the potential 

development of resistant weed species, including, but 

not limited to the following: 

• Rotate herbicides – by understanding the 

different modes of action of each herbicide 

proposed for use on public lands, select the 

appropriate one to minimize resistance; 

• Understand the potential effects of long-term 

residual herbicides on the selection for resistant 

weeds, and correctly apply these herbicides 

with the understanding that they can lead to 

weed resistance if used yearly for several 

consecutive years; 

• Use mechanical and biological management 

options to eliminate weed escapes that may 

represent the resistant population; and 

• Keep accurate records of herbicide application. 

Description of the Alternatives 

Five program alternatives were developed for and 

evaluated in this PEIS, including the Preferred 

Alternative and the No Action Alternative. Alternative 

actions are those that could be taken to feasibly attain, 

or approximate the BLM’s objectives for herbicide use, 

as expressed in its programs, policies, and land use 

plans. 

Alternatives were developed that 1) allow the BLM to 

continue its current use of 20 active ingredients in 14 

western states, as authorized by earlier EIS RODs; 2) 

allow for the use of 14 active ingredients currently used 

by the BLM and four new active ingredients; 3) prohibit 

the use of herbicides; 4) prohibit the aerial application 

of herbicides; or 5) prohibit the use of sulfonylurea and 

other acetolactate synthase-inhibiting active ingredients. 

These program alternatives address many of the 

concerns raised during scoping, in particular the 

public’s desire to see alternatives that place less 

emphasis on the use of herbicides, while still meeting 

the program’s purpose and need. Alternatives were also 

developed to ensure that the BLM complied with 

federal, tribal, state, and local regulations. 

Alternative A – Continue Present 

Herbicide Use (No Action Alternative) 

Under this alternative, the BLM would be able to 

continue to use 20 active ingredients approved for use in 

western states under the earlier EIS RODs for each state 

(Table 2-1; USDI BLM 1987a, 1988b, 1991b, 1992a). 

The BLM would also continue its activities conducted 

under Emergency Stabilization and Burned Area 

Rehabilitation and hazardous fuel reduction that are 
TABLE 2-3 

Herbici

des 

Approved and Propose

d for Use o

n Public Lands 

Areas Where Registered Use is 

Herbicide Herbicide Characteristics and Target Vegetation Rangeland Forestland Riparian and Aquatic Oil

a

Mi

Herbicides Approved for Use on Public 

Lands 

2, 4-D Selective; foliar absorbed; poste

mergent; annual/perennial broadleaf weeds. Key 

species treated include burningbush, mustard species, and Russian thistle. • • • 

2, 4-DP

Selective; foliar absorbed; postemergent; broadleaf

weeds and woody species. Key 

species treated include burningbush, mustard species, Russian thistle, and brushspecies. • • 

Asulam Inhibits

mitosis; controls growing grasses and certain broadleaf weeds. Key species

treated include brackenfern, dock, and Johnsongrass. 

Atrazine Selective; 

mostly root absorbed; inhibits photosynthesis. Key species treated include 

annual grasses, mustards, pigweed, and Russian thistle. • 

Bromacil

Non-selective; inhibits photosynthesis; controls wide range of weeds and brush. Keyspecies treated include annual grasses and broadleaf weeds, burningbush, and Russianthistle.

Chlorsulfuron Selective; inhibits enzyme activity; broadleaf weeds and grasses. Key species treated include biennial thistles and annual and perennial mustards. • Clopyralid Selective;

mimics plant hormones; annual and perennial broadleaf weeds. Key 

species treated include knapweeds, mesquite, and starthistle and other thistles. • • 

Dica

mba Growth regulator; annual and perennial broadleaf weeds, brush, and trees. Key species treated include knapweeds, burningbush, and Russian and other thistles. • 

Diuron Pree

mergent control; annual and perennial broadleaf weeds and grasses. Key species

treated include annual grasses and broadleaf weeds, burningbush, and Russian thistle. 

Fosamine a

mmonium Inhibits bud and leaf formation; broadleaf weeds, brush, and trees. Key species treated include field bindweed, leafy spurge, and locust. 

Glyphosate

Non-selective; annual and perennial grasses and broadleaf weeds, sedges, shrubs, and trees. Key species treated include annual, biennial, and perennial grasses and

broadleaf weeds and woody shrubs. • • • 

Hexazinone 

Foliar or soil applied; inhibits photosynthesis; annual and perennial grasses and broadleaf weeds, brush, and trees. Key species treated include 

mesquite and scrub

oak.

• • 

Imazapyr

Non-selective; preemergent and postemergent uses; absorbed through foliage and roots; annual and perennial broadleaf weeds, brush, and trees. Key species treatedinclude saltcedar. • • • 

Mefluidide Growth inhibitor; suppresses seed production of grasses, brush, and trees. Key

species treated include roadside grasses. 

Metsulfuron methyl 

Selective; poste

mergent; inhibits cell division in roots and shoots; annual and

perennial broadleaf weeds, brush, and trees. Key species treated include annual and

perennial mustards and biennial thistles.

• • 

Picloram

Selective; foliar and root absorption; mimics plant hormones; certain annual and perennial broadleaf weeds, vines, and shrubs. Key species treated include knapweeds,leafy spurge, and starthistle. • • 

Si

mazine 

Used selectively or as co

mplete vegetation killer; requires

much moisture for 

activation; inhibits photosynthesis. Key species treated include annual grasses, 

mustards, pigweed, and Russian thistle.

BLM Vegetation Treatments Using Herbicides 2-15 June 2007 

Final Programmatic EIS
TABLE 2-3 (Cont.) 

Herbicides Approved and Proposed for Use on Public Lands 

Areas Where Registered Use is 

Herbicide Herbicide Characteristics

Rangeland Forestland Riparian and Aquatic Oil

a

Mi

Herbicides Approved for Use on Public Lands (Cont.)

Sulfometuron methyl

Broad-spectrum pre and postemergent control; inhibits cell division; grasses and broadleaf weeds. Key species treated include downy brome, annual and perennial mustards, and medusahead.

• 

Tebuthiuron 

Relatively non-selective soil activated herbicide; pre and postemergent control ofannual and perennial grasses, broadleaf weeds, and shrubs. Key species treated include creosotebush, oak, Russian olive, and sagebrush (thinning).

• 

Triclopyr Growth regulator; broadleaf weeds and woody plants. Key species treated include mesquite and saltcedar. • • • 

Herbicides Proposed for Use on Public Lands 

Diflufenzopyr + Dicamba 

Postemergent; inhibits auxin transport; broadleaf weeds. Key species treated includeknapweeds, burningbush, and Russian thistle and other thistles. • 

Diquat Non-selective and foliar applied. Key species treated include giant salvinia,water- thyme, and watermilfoils. • Fluridone Aquatic herbicide to control submersed aquatic plants. Key species treated include

water-thyme and watermilfoils. •

Imazapic Selective postemergent herbicide; inhibits broadleaf weeds and some grasses. Key species treated include downy brome, leafy spurge, medusahead, and mustards. • • • = Areas where USEPA approved registration exists and the BLM has approval or proposes to use on public lands; ◘ = Areas where USEPA approved registration exists, b

propose to use on public lands.

BLMVegetationTreatments Using Herbicides 2-16 June 2007 

FinalProgrammaticEIS
ALTERNATIVES 

evaluated by NEPA compliance documents prepared by

local BLM field offices. 

During 1999 through 2005, approximately two-thirds of

acres were treated with just three active ingredients: 

picloram, tebuthiuron, and 2,4-D, and the majority of 

treatments were in Idaho, Montana, and Utah (Tables 2-

4 and 2-5 and Figure 2-1). During that period, the BLM 

did not report any use of 2,4-DP, asulam, atrazine, 

mefluidide, or simazine, and treated less than 50 acres 

annually using fosamine. It is unlikely that the BLM 

would use these herbicides in the future since there are

more suitable active ingredients available and approved

for use to meet current needs. 

Under this alternative, an estimated 305,000 acres 

would be treated annually using herbicides (Table 2-6),

an increase over the number of acres that have been 

treated in recent years (Figure 2-1). Estimates of the 

number of acres that would be treated under the No 

Action Alternative were developed based on 

information provided by BLM field offices throughout 

the western U.S., including Alaska, during summer 

2002. 

TABLE 2-4 

Average Number of Acres Treated Annually for 

Each BLM State Jurisdiction during 1997-2005.

State Acres Treated

Annually 

Percentage of 

all Public

Lands Treated

Arizona 7,664 6.3 

California 2,676 2.2 

Colorado 5,480 4.0 

Idaho 30,572 25.0

Montana, North Dakota, 

and South Dakota 7,739 6.3 

Nevada 4,820 3.9 

New Mexico, 

Oklahoma, and Texas 42,570 34.8

Oregon and Washington 3,543 2.9 

Utah 11,175 9.1 

Wyoming and Nebraska 6,667 5.5 

In developing acreage estimates for all alternatives, it

was assumed that if an acre was treated more than once 

using the same type of treatment during the same year,

it would be counted once. If the acre was treated using 

two or more different methods during the same year (for

example, fire use followed by herbicide treatment), each

treatment would count as one acre. Thus, if an acre was 

treated using fire and herbicides during the same year, 

two acres would be counted as treated. If an acre was 

treated using two or more herbicides in a tank mix, it 

would be counted once. 

Figure 2-1. Summary of Acres Treated Using

Herbicides during 1997-2005. 

0

50000

100000

150000

200000

1997

1998

1999200020012002200320042005

Alternative B – Expand Herbicide Use 

and Allow for Use of New Herbicides 

in 17 Western States (Preferred 

Alternative) 

This alternative represents the treatment of vegetation

using herbicides in 17 western states (including Alaska). 

Under the Preferred Alternative, approximately 932,000 

acres would be treated annually using herbicides, based

on the herbicide use projections developed by BLM

field offices and funding projections for BLM

vegetation treatment activities during the next decade. 

Based on field office projects, the majority of treatments 

would occur in Nevada, Idaho, Oregon, and Wyoming. 

Under the Preferred Alternative, the BLM would be 

able to use, in the western U.S., including Alaska, the

14 active ingredients that were approved for use in the

earlier RODs and for which an analysis of risks to

humans and non-target plants and animals was 

conducted for this PEIS or by the Forest Service. These 

active ingredients are: 2,4-D, bromacil, chlorsulfuron,

clopyralid, dicamba, diuron, glyphosate, hexazinone,

imazapyr, metsulfuron methyl, picloram, sulfometuron

methyl, tebuthiuron, and triclopyr. 

The remaining six active ingredients currently approved

for use by the BLM⎯2,4-DP, asulam, atrazine,

fosamine, mefluidide, and simazine⎯have not been

used, or their use has been limited to very few acres, by

the BLM for several years. Although the risks to

humans from the use of these chemicals are not

significant based on evaluations done for the earlier 

EISs and a review of the literature for this

BLM Vegetation Treatments Using Herbicides 2-17 June 2007 

Final Programmatic EIS
ALTERNATIVES 

TABLE 2-5 

Historic Use of Herbicides by the BLM and Projected Future Use of Herbicides by the BLM under Each

Alternative (as a percentage of all acres treated using herbicides) 

Projected Use Under Each Alternative 

Active Ingredient 

Historic Use 

(1999-2005) No Action

Alternative 

Preferred

Alternative Alternative C Alternative D Alternative E 

Herbicides Approved for Use on Public Lands 

2,4-D 16.9 18 18 0 33 20

2,4-DP 0 0 0 0 0 0

Asulam 0 0 0 0 0 0

Atrazine 0 0 0 0 0 0

Bromacil 0.7 <1 <1 0 <1 <1

Chlorsulfuron 0.9 1 1 0 1 0

Clopyralid 4.2 8 7 0 5 9

Dicamba 3.2 2 <1 0 <1 <1

Diuron 1.1 <1 <1 0 1 <1

Fosamine ammonium 0.01 0 0 0 0 0

Glyphosate 8.6 16 10 0 11 19

Hexazinone 0.4 <1 <1 0 <1 <1

Imazapyr 1.1 2 2 0 2 0

Mefluidide 0 0 0 0 0 0

Metsulfuron methyl 5.5 5 5 0 9 0

Picloram 16.4 16 15 0 26 16

Simazine 0 0 0 0 0 0

Sulfometuron methyl 7.2 <1 <1 0 2 0

Tebuthiuron 30.7 25 25 0 <1 25

Triclopyr 3.1 5 5 0 4 7

Herbicides Proposed for Use on Public Lands 

Diflufenzopyr + 

Dicamba 0 0 2 0 5 2

Diquat 0 0 <1 0 1 <1

Fluridone 0 0 <1 0 1 <1

Imazapic 0 0 8 0 5 0

PEIS, the risks to non-target plants and animals, 

especially species of concern, have not been adequately

evaluated. Should these chemicals be needed by the 

BLM in the future, the BLM would consult ERAs for

these active ingredients prepared by the Forest Service

or other agencies, if available, or conduct their own

ERAs, to assess the risks to non-target species. This

analysis would be supported by the appropriate NEPA 

documentation and interagency consultation before 

these chemicals would be approved for use or applied

on the ground.

The BLM would be allowed to use four additional

active ingredients in all 17 states included in this PEIS:

imazapic, diquat, diflufenzopyr (in formulation with

dicamba), and fluridone. In addition, the BLM would be

able to use diflufenzopyr in the future as a stand-alone

active ingredient if it becomes registered for herbicidal

use. These active ingredients and formulations could 

only be applied for uses, and at application rates, 

specified on the label directions. Under the Preferred 

Alternative, the BLM would also be able to use new 

active ingredients that are developed in the future if: 1)

they are registered by the USEPA for use on one or 

more land types (e.g., rangeland, aquatic, etc.) managed

by the BLM; 2) the BLM determines that the benefits of

use on public lands outweigh the risks to human health

and the environment; and 3) they meet evaluation 

criteria to ensure that the decision to use the active

ingredient is supported by scientific evaluation and 

NEPA documentation. These evaluation criteria are

discussed in more detail in Appendix E. 

BLM Vegetation Treatments Using Herbicides 2-18 June 2007 

Final Programmatic EIS 
ALTERNATIVES 

TABLE 2-6 

Comparison of the Alternatives 

Analysis Element 

Alternative 

A 

(No Action) 

Alternative B 

(Preferred 

Alternative) 

Alternative C

(No Use of 

Herbicides) 

Alternative D

(No Aerial

Spraying of 

Herbicides) 

Alternative E 

(No ALSinhibiting 

Herbicides) 

Approximate Number of Acres 

Treated Annually Using 

Herbicides: 

 305,000 932,000 0 530,000 466,0001

 

Treatment Planning: 

Focus of vegetation treatments2 

Cost of treatment used as a 

selection criteria 

Width of WUI

Active 

No 

Variable 

Active 

No 

Variable 

Active 

No 

Variable 

Active 

No 

Variable 

Passive 

Yes 

500 meters 

Use of Treatments: 

Restrictions on acres treated 

using herbicides 

Restrictions on types of 

herbicides used

Restrictions on use of herbicides 

in amphibian habitats

4

Restrictions on use of herbicides 

in areas with culturally

significant plant and wildlife 

resources6

Yes 

Yes3 

Yes 

No 

No 

No 

Yes 

No 

Yes 

No 

Yes 

No 

No 

No 

Yes 

No 

Yes 

Yes3

Yes5

Yes 

1

 Assumes that the number of acres treated using herbicides is about half the number treated for Alternative B, although not explicitly

stated in the proposal. 2

 Passive treatments involve suspension of activities that cause the loss of ecological integrity; all other treatments are active. 3

 Under Alternative A, limited to herbicides approved for use in each state based on earlier EIS RODs. Under Alternative E, sulfonylurea 

and other acetolactate synthase-inhibiting herbicides would not be used. 4

 Restrictions on use of herbicides in areas with amphibians would be based on the ecological risk assessment, on federal, state, local, 

and tribal regulations, and on local experience in using herbicides. Restrictions include avoidance of glyphosate formulations that 

include R-11 in the future, and either avoidance using any formulations with polyoxytheyleneamine, or use of the formulation with the

lowest amount of polyoxytheyleneamine available. 5 Herbicide use would be avoided in areas with amphibians. 6

 Use of herbicides in areas with culturally significant plant and animal resources would be based on human and ecological risk 

assessments; on federal, state, local, and tribal regulations, and on local experience in using herbicides.

Alternative C – No Use of Herbicides 

Under Alternative C, the BLM would not be able to 

treat vegetation using herbicides and would not be able

to use new chemicals that are developed in the future. 

The BLM would be able to treat vegetation using fire, 

and mechanical, manual, and biological control 

methods. A PER has been prepared that accompanies 

this PEIS and discusses these treatment methods, 

proposed treatment levels during the next 10 to15 years, 

and likely impacts to natural and social resources on

public lands from these treatment methods (USDI BLM

2007a). 

Alternative D – No Aerial Application 

of Herbicides

This alternative is similar to the Preferred Alternative in

that it represents the treatment of vegetation using 

herbicides in 17 western states, including Alaska, and

use of the same active ingredients as allowed under the 

Preferred Alternative. Under Alternative D, however, 

only ground-based techniques would be used to apply 

herbicides (no aerial applications of herbicides would be 

allowed) to would reduce the risk of spray drift

impacting non-target areas. Based on information

obtained from field offices, an estimated 55% of 

herbicide treatments would involve use of ground-based 

methods during the next 10 years. Thus, the BLM

BLM Vegetation Treatments Using Herbicides 2-19 June 2007 

Final Programmatic EIS 
ALTERNATIVES

would treat approximately 530,000 acres annually using 

herbicides under this alternative. In comparison, during 

1997 to 2005, approximately 66% (80,467 acres 

annually) of herbicide treatments were conducted 

aerially and 34% (41,829 acres annually) using groundbased methods. Most aerial treatments occurred in New 

Mexico (47% of acres treated in western U.S.), Idaho

(30%), and Arizona (8%), while states with the most

acres treated using ground-based methods were Utah

(20% of acres treated in western U.S.), Idaho (16%), 

and Wyoming (12%). 

Similar to the Preferred Alternative, the BLM would be

able to use new active ingredients that are developed in

the future if: 1) they are registered by the USEPA for 

use on one or more land types (e.g., rangeland, aquatic) 

managed by the BLM; 2) the BLM determines that the

benefits of use on BLM lands outweigh the risks to

human health and the environment; and 3) they meet

evaluation criteria to ensure that the decision to use the 

active ingredient is supported by scientific evaluation

and NEPA documentation. 

Alternative E – No Use of Sulfonylurea

and other Acetolactate Synthaseinhibiting Active Ingredients 

This alternative was developed based on an alternative 

proposal for vegetation management on public lands

submitted by the American Lands Alliance. The

proposal is entitled the “Restore Native Ecosystems

Alternative” (RNEA) and the full text of the proposal is 

in Appendix I. 

In order to determine whether this alternative had merit

for analysis relative to the proposed action, or should be

dismissed from detailed analysis, a comprehensive 

policy review of the proposal was conducted by the

BLM’s National Science and Technology Center during 

2002. 

The BLM’s policy review of the RNEA is provided in

Appendix I of the Final PEIS. The policy analysis 

comprises identification of the individual goals and

actions outlined in the RNEA proposal. For each goal or

action, a determination has been made whether it is 

included in current BLM policy (yes/no) and a citation

for the policy is provided. Under policy analysis, a brief 

summary outlining the policy is provided. Under the

alternative comparison, the alternatives that apply to the 

policy are identified. In most cases, the policy is 

“common to all alternatives.” The last column outlines 

the programmatic net effect or impact of the policy if 

the analysis is different from that presented in the Final

PEIS, or outside the scope of analysis. 

Based on this analysis, certain components of the 

proposal that were relevant and applicable to herbicide 

use under the proposed action were carried forward into 

the alternative analyzed in the PEIS. The remaining

content of the proposal was determined to be either 

already covered under existing BLM policy, and 

therefore already a component of the Preferred

Alternative (Alternative B), or outside the scope of 

analysis of this PEIS. 

Under Alternative E, the BLM would not use 

sulfonylurea and other acetolactate synthase-inhibiting 

active ingredients approved in the earlier RODs, which

are chlorsulfuron, imazapyr, metsulfuron methyl, and

sulfometuron methyl. During 1999 to 2000, these active 

ingredients comprised approximately 28% of the active 

ingredients used by the BLM. Since 2001, however, 

these active ingredients have comprised approximately

8% of the active ingredients used by the BLM. The 

BLM would be able to use, in the 17 western states, 10

active ingredients that were approved for use in the 

earlier RODs and for which an analysis of their risks to

humans and non-target plants and animals was 

conducted for this PEIS. These active ingredients are: 

2,4-D, bromacil, clopyralid, dicamba, diuron, 

glyphosate, hexazinone, picloram, tebuthiuron, and 

triclopyr. The six other active ingredients currently

approved for use by the BLM⎯2,4-DP, atrazine, 

asulam, fosamine, mefluidide, and simazine⎯would not

be used unless guidelines given for the Preferred

Alternative were met. 

In addition, the BLM would be allowed to use three 

additional active ingredients in all 17 states: diquat, 

diflufenzopyr (if it becomes registered for herbicidal 

use), and fluridone. The BLM would also be able to use 

a formulation of diflufenzopyr and dicamba. These 

active ingredients and formulations could only be 

applied for uses, and at application rates, specified on 

the label directions. 

Under Alternative E, the BLM would be able to use

new active ingredients that are developed in the future if 

they follow protocols for use of new active ingredients 

identified under the Preferred Alternative and do not

contain sulfonylurea and imidazolinone chemistry and

other acetolactate synthase-inhibiting compounds. 

Under this alternative, the BLM would treat

approximately 466,000 acres annually using herbicides 

(Table 2-6). Spot herbicide treatments would be favored 

BLM Vegetation Treatments Using Herbicides 2-20 June 2007 

Final Programmatic EIS 
ALTERNATIVES

over broadcast treatments. Herbicide use would be 

discouraged in areas populated by amphibians. To 

protect Native American and Alaska Native resources,

the BLM would establish herbicide-free zones around 

culturally significant plant and wildlife resources. 

This alternative would place greater emphasis on

passive restoration, by prohibiting or restricting

activities such as livestock grazing, OHV use, logging,

or oil and gas development in areas where these

activities have promoted a less desirable vegetation 

community, or increased erosion. Chapter 1, Scope of 

Analysis, clearly states the PEIS does not evaluate these 

programs. Since these activities are allowed under 

FLPMA, restrictions on these activities would only be 

considered to the extent they are consistent with BLM

vegetation and land use management practices and

policies (e.g. excluding grazing animals from recently 

seeded areas) and as determined by the authorized 

office under the appropriate controlling regulations. 

Determination of Treatment 

Acreages 

As discussed earlier, the BLM has been mandated under 

a variety of statutes and policy initiatives to increase the

number of acres of vegetation treated annually to

address the issues of catastrophic fire and invasive

species spread and their relationships to habitat

improvement and maintenance of healthy landscapes. 

The BLM estimates that approximately 6 million acres

would need to be treated annually to meet these 

mandates. Acres to be treated by the BLM and assessed

in this PEIS were estimated based on information 

provided by BLM field offices throughout the western

U.S., including Alaska. Each field office was asked to

estimate and summarize proposed vegetation treatment

projects likely to occur during the next 10 years. For 

each project, the field office provided an estimate of the

number of acres proposed for treatment, the general

vegetation type(s) proposed for treatment, and the

vegetation treatment method(s) proposed to be used. In 

many cases, multiple treatment methods were identified 

for a particular type of project. Treatments could occur 

on the same acres several times during 1 year, or over 

several years. Based on these surveys, field offices 

identified that approximately 4.6 million acres of

treatments would be needed annually. 

The BLM also reviewed Fire Regime Condition Classes 

(FRCCs) and concluded that an additional 1.4 million 

acres of treatments, beyond the estimates provided by

the field offices, would be required annually. These 

classes were created to represent qualitative measures

describing the degree of departure from historical fire 

regimes. This departure may have resulted from

activities such as fire exclusion, timber harvesting, 

livestock grazing, introduction and establishment of 

exotic plant species, introduced insects or disease, 

and/or other management activities, which have altered 

key ecosystem components such as species 

composition, structural stage, stand age, canopy closure,

and fuel loadings. These treatments would be focused 

on those areas of vegetation having a high departure 

from the historical condition and where the risk of 

losing key ecosystem components to fire or other causes 

is high (FRCC 3). The intent of these treatments would 

be to transition FRCC 3 lands to areas where fire

regimes are moderately altered from their historical

conditions (FRCC 2), or are within their historical range

of vegetation variability (FRCC 1). 

As a result of these surveys and reviews, an estimated 6 

million acres would need to be treated annually. 

Approximately 3.5 million acres would be treated 

primarily for hazardous fuels reduction and to control

wildfires in the WUI, approximately 1 million acres

would be treated to control unwanted vegetation to

restore ecosystem health, and about 1.5 million acres a 

year would be subject to burned area rehabilitation and 

emergency stabilization efforts. Acres associated with 

these treatments are dependent on the severity and 

extent of the fire season in any given year and may vary

considerably from this average. 

Non-herbicide Treatment Method 

Acreages used in Cumulative Effects 

Analysis 

The alternatives describe differing levels of herbicide 

use, ranging from approximately 932,000 acres annually 

under Alternative B to 0 acres annually under 

Alternative C. However, non-herbicide treatments 

(manual and mechanical methods, biological control, 

and use of fire) would also occur under all alternatives. 

Although non-herbicide treatments were not evaluated

in the analysis of direct and indirect effects of herbicide

treatments (but were evaluated in the PER), as discussed

in Chapter 1 of this PEIS under Decisions to be Made

and Scope of Analysis, they are considered in the 

Cumulative Effects Analysis in Chapter 4 of this PEIS. 

Under Alternative A, approximately 645,000 acres 

would be treated using fire, 582,000 acres would be

treated using mechanical methods, 114,000 acres would

BLM Vegetation Treatments Using Herbicides 2-21 June 2007 

Final Programmatic EIS 
ALTERNATIVES

be treated using manual methods, and 253,000 acres 

would be treated using biological control. 

Under Alternative B, approximately 2,107,000 acres 

would be treated using fire, 2,232,000 acres would be 

treated using mechanical methods, 271,000 acres would

be treated using manual methods, and 454,000 acres 

would be treated using biological control. 

Under alternatives C, D, and E, approximately

1,055,000 acres would be treated using fire, 1,986,000 

acres would be treated using mechanical methods, 

396,000 acres would be treated using manual methods, 

and 597,000 acres would be treated using biological

control. 

Alternatives Considered but Not 

Further Analyzed 

Several other alternatives were identified during public

scoping and reviewed by the interdisciplinary team

(ENSR 2002). In most cases, these alternatives would

not fulfill the purpose and need for the project, are

inconsistent with BLM or other federal, state, or local 

policies or regulations, or are not practical based on

likely funding for vegetation treatments. The 

alternatives that were considered but not further 

analyzed are: 

• Treat up to 25 million acres annually. This 

alternative was excluded from analysis because

the BLM felt it was highly unlikely that the 

agency would have sufficient funding during

the next 10 to 15 years to treat up to 25 million 

acres annually. 

• Treat fewer acres than are currently

treated. Under this alternative, fewer acres 

would be treated annually than would occur 

under the No Action Alternative (Alternative 

A). Given that current treatment levels have

been insufficient to control unwanted 

vegetation and reduce the risk of wildfire to life

and property on public lands, this alternative 

would not meet the project purpose and need. 

• Do not treat competing and unwanted

vegetation. Under this alternative, the BLM 

would continue burned area rehabilitation and 

emergency stabilization activities, hazardous 

fuels reduction activities that did not involve 

the treatment of vegetation, and passive 

vegetation management, but would not actively 

treat competing and unwanted vegetation. This 

alternative was eliminated because it would not

control the spread of unwanted vegetation, 

which could adversely impact land health on 

public lands and increase the risk of loss of life

and property due to fires. 

• Treat only acres needed to protect human 

health and safety. Under this alternative, the

BLM would only treat those acres needed to 

protect human health and safety. Nearly all of 

these acres would be associated with hazardous 

fuels reduction near homes and other 

developments in the WUI. This alternative was 

eliminated because it would not maintain or 

improve land health on most public lands. 

• Do not conduct hazardous fuels treatments. 

Like the preceding alternative, this alternative 

was excluded because it does not restore the 

health of fire-adapted ecosystems. The buildup

of hazardous fuels that have led to catastrophic

wildfires and significant impacts to air quality, 

water resources, human health, and other 

resources. 

• Revegetate with native vegetation. Under this 

alternative, only native vegetation would be 

used to restore fire-impacted and other 

degraded public lands. This alternative was 

eliminated because it has been incorporated 

into the proposed action to the extent practical. 

• Exclude logging, grazing, OHV use, and 

energy/mineral development on public 

lands. This alternative was eliminated because 

FLPMA requires that the BLM manage public

lands for multiple uses including those listed. 

Field offices, however, can limit these

activities, consistent with land use plans where

doing so benefits vegetation management and 

land health and complies with the FLPMA. 

The rest of this chapter includes actions that would be 

common to all alternatives. 

Herbicide Treatment Standard 

Operating Procedures and 

Guidelines 

This section identifies standard operating procedures 

(SOPs) that would be followed by the BLM under all

alternatives to ensure that risks to human health and the

environment from herbicide treatment actions would be 

kept to a minimum. Standard operating procedures are 

BLM Vegetation Treatments Using Herbicides 2-22 June 2007 

Final Programmatic EIS 
ALTERNATIVES

the management controls and performance standards 

required for vegetation management treatments. These 

practices are intended to protect and enhance natural 

resources that could be affected by future vegetation 

treatments. 

Prevention of Weeds and Early 

Detection and Rapid Response 

Once weed populations become established, infestations 

can increase and expand in size. Weeds colonize highly

disturbed ground and invade plant communities that 

have been degraded, but are also capable of invading 

intact communities. Therefore, prevention, early 

detection, and rapid response are the most cost-effective 

methods of weed control. Prevention, early detection, 

and rapid response strategies that reduce the need for 

vegetative treatments for noxious weeds should lead to

a reduction in the number of acres treated using 

herbicides in the future by reducing or preventing weed 

establishment. 

As stated in the BLM’s Partners Against Weeds - An

Action Plan for the BLM (USDI BLM 1996), prevention 

and public education are the highest priority weed

management activities. Priorities are as follows: 

• Priority 1: Take actions to prevent or minimize

the need for vegetation control when and where 

feasible, considering the management

objectives of the site. 

• Priority 2: Use effective nonchemical methods 

of vegetation control when and where feasible. 

• Priority 3: Use herbicides after considering the 

effectiveness of all potential methods or in 

combination with other methods or controls. 

Prevention is best accomplished by ensuring the seeds 

and vegetatively reproductive plant parts of new weed

species are not introduced into new areas. 

The BLM is required to develop a noxious weed risk

assessment when it is determined that an action may 

introduce or spread noxious weeds or when known 

habitat exists (USDI BLM 1992b). If the risk is 

moderate or high, the BLM may modify the project to 

reduce the likelihood of weeds infesting the site, and to 

identify control measures to be implemented if weeds 

do infest the site. 

To prevent the spread of weeds, the BLM takes actions 

to minimize the amount of existing non-target

vegetation that is disturbed or destroyed during project 

or vegetation treatment actions (Table 2-7). During

project planning, the following steps are taken: 

• Incorporate measures to prevent introduction or 

spread of weeds into project layout, design, 

alternative evaluation, and project decisions. 

• During environmental analysis for projects and

maintenance programs, assess weed risks, 

analyze potential treatment of high-risk sites 

for weed establishment and spread, and identify 

prevention practices. 

• Determine prevention and maintenance needs, 

to include the use of herbicides if needed, at the 

onset of project planning. 

• Avoid or remove sources of weed seed and 

propagules to prevent new weed infestations 

and the spread of existing weeds. 

During project development, weed infestations are 

prioritized for treatment in project operating areas and

along access routes. Weeds present on or near the site

are identified, a risk assessment is completed, and 

weeds are controlled as necessary. Project staging areas 

are weed free, and travel through weed infested areas is 

avoided or minimized. Examples of prevention actions 

to be followed during project activities include cleaning 

all equipment and clothing before entering the project 

site; avoiding soil disturbance and the creation of other

soil conditions that promote weed germination and

establishment; and using weed-free seed, hay, mulch,

gravel, soil, and mineral materials on public lands 

where there is a state or county program in place. 

Conditions that enhance invasive species abundance 

should be addressed when developing mitigation and

prevention plans for activities on public lands. These

conditions include excessive disturbance associated

with road maintenance, poor grazing management, and 

high levels of recreational use. If livestock grazing is 

managed to maintain the vigor of native perennial 

plants, particularly grasses, the chance of weeds 

invading rangeland is much less. By carefully managing 

recreational use and educating the public on the 

potential impacts of recreational activities on 

vegetation, the amount of damage to native vegetation

and soil can be minimized at high use areas, such as 

campgrounds and OHV trails. Early detection in

recreation areas is focused on roads and trails, where

much of the weed spread occurs. 

The BLM participates in the National Early Warning 

and Rapid Response System for Invasive Plants (Figure

BLM Vegetation Treatments Using Herbicides 2-23 June 2007 

Final Programmatic EIS 
ALTERNATIVES

TABLE 2-7 

Prevention Measures 

BLM Activity Prevention Measure 

• Incorporate prevention measures into project layout and design, alternative evaluation, and 

project decisions to prevent the introduction or spread of weeds. 

• Determine prevention and maintenance needs, including the use of herbicides, at the onset of 

project planning. 

• Before ground-disturbing activities begin, inventory weed infestations and prioritize areas for 

treatment in project operating areas and along access routes. 

• Remove sources of weed seed and propagules to prevent the spread of existing weeds and new 

weed infestations. 

• Pre-treat high-risk sites for weed establishment and spread before implementing projects. 

• Post weed awareness messages and prevention practices at strategic locations such as trailheads, 

roads, boat launches, and public land kiosks. 

Project Planning 

• Coordinate project activities with nearby herbicide applications to maximize the costeffectiveness of weed treatments. 

• Minimize soil disturbance to the extent practical, consistent with project objectives. 

• Avoid creating soil conditions that promote weed germination and establishment.

• To prevent weed germination and establishment, retain native vegetation in and around project

activity areas and keep soil disturbance to a minimum, consistent with project objectives. 

• Locate and use weed-free project staging areas. Avoid or minimize all types of travel through 

weed-infested areas, or restrict travel to periods when the spread of seeds or propagules is least 

likely. 

• Prevent the introduction and spread of weeds caused by moving weed-infested sand, gravel, 

borrow, and fill material. 

• Inspect material sources on site, and ensure that they are weed-free before use and transport. 

Treat weed-infested sources to eradicate weed seed and plant parts, and strip and stockpile

contaminated material before any use of pit material. 

• Survey the area where material from treated weed-infested sources is used for at least 3 years 

after project completion to ensure that any weeds transported to the site are promptly detected 

and controlled. 

• Prevent weed establishment by not driving through weed-infested areas. 

• Inspect and document weed establishment at access roads, cleaning sites, and all disturbed 

areas; control infestations to prevent spread within the project area. 

• Avoid acquiring water for dust abatement where access to the water is through weed-infested

sites. 

• Identify sites where equipment can be cleaned. Clean equipment before entering public lands. 

• Clean all equipment before leaving the project site if operating in areas infested with weeds.

• Inspect and treat weeds that establish at equipment cleaning sites. 

• Ensure that rental equipment is free of weed seed.

Project 

Development 

• Inspect, remove, and properly dispose of weed seed and plant parts found on workers’ clothing 

and equipment. Proper disposal entails bagging the seeds and plant parts and incinerating them. 

• Include weed prevention measures, including project inspection and documentation, in

operation and reclamation plans.

• Retain bonds until reclamation requirements, including weed treatments, are completed, based 

on inspection and documentation. 

• To prevent conditions favoring weed establishment, re-establish vegetation on bare ground

caused by project disturbance as soon as possible using either natural recovery or artificial

techniques. 

Revegetation 

• Maintain stockpiled, uninfested material in a weed-free condition. 

BLM Vegetation Treatments Using Herbicides 2-24 June 2007 

Final Programmatic EIS 
ALTERNATIVES

TABLE 2-7 (Cont.) 

Prevention Measures 

BLM Activity Prevention Measure 

• Revegetate disturbed soil (except travel ways on surfaced projects) in a manner that optimizes 

plant establishment for each specific project site. For each project, define what constitutes 

disturbed soil and objectives for plant cover revegetation. Revegetation may include topsoil 

replacement, planting, seeding, fertilization, liming, and weed-free mulching, as necessary. 

• Where practical, stockpile weed-seed-free topsoil and replace it on disturbed areas (e.g., road 

embankments or landings). 

• Inspect seed and straw mulch to be used for site rehabilitation (for wattles, straw bales, dams, 

etc.) and certify that they are free of weed seed and propagules. 

• Inspect and document all limited term ground-disturbing operations in noxious weed infested 

areas for at least 3 growing seasons following completion of the project. 

• Use native material where appropriate and feasible. Use certified weed-free or weed-seed-free 

hay or straw where certified materials are required and/or are reasonably available. 

• Provide briefings that identify operational practices to reduce weed spread (for example, 

avoiding known weed infestation areas when locating fire lines). 

Revegetation 

(Cont.)

• Evaluate options, including closure, to regulate the flow of traffic on sites where desired 

vegetation needs to be established. Sites could include road and trail ROW, and other areas of 

disturbed soils. 

2-2). The goal of this System to minimize the

establishment and spread of new invasive species 

through a coordinated framework of public and private 

processes by: 

• Early detection and reporting of suspected new 

plant species to appropriate officials; 

• Identification and vouchering of submitted

specimens by designated specialists; 

• Verification of suspected new state, regional, 

and national plant records; 

• Archival of new records in designated regional

and plant databases; 

• Rapid assessment of confirmed new records;

and 

• Rapid response to verified new infestations that 

are determined to be invasive. 

Herbicide Treatment Planning 

BLM Manual 9011 (Chemical Pest Control) outlines

the policies, and BLM Handbook H-9011-1 (Chemical

Pest Control; USDI BLM 1988d) outlines the

procedures, for use of herbicides on public lands. As 

part of policy, the BLM is required to thoroughly

evaluate the need for chemical treatments and their 

potential for impact on the environment. The BLM is 

required to use only USEPA-registered herbicides that

have been properly evaluated under NEPA, and to

carefully follow label directions and additional BLM

requirements. 

An operational plan is developed and updated for each 

herbicide project. The plan includes information on

project specifications, key personnel responsibilities, 

and communication, safety, spill response, and 

emergency procedures. For application of herbicides not 

approved for aquatic use, the plan should also specify 

minimum buffer widths between treatment areas and

water bodies. Recommended widths are provided in

BLM Handbook H-9011-1 (Chemical Pest Control), but

actual buffers are site and herbicide active ingredient

specific, and are determined based on a scientific

analysis of environmental factors, such as climate,

topography, vegetation, and weather; timing and 

method of application; and herbicide risks to humans 

and non-target species. Recommended buffer widths for 

each herbicide active ingredient under different

application scenarios are listed later in this chapter 

under Mitigation. Table 2-8 summarizes important

SOPs that should be used when applying herbicides to 

help protect resources of concern on public lands. 

BLM Vegetation Treatments Using Herbicides 2-25 June 2007 

Final Programmatic EIS 
ALTERNATIVES

Animal and 

Plant Health 

Inspection 

Service 

(APHIS) 

National 

Agricultural 

Pest 

Information 

System 

(NAPIS) 

Database

Contact Local 

Agency 

Early 

Warning 

Rapid 

Response 

Website 

Call 800 

Number 

Infestation on 

Private Land 

Action by:

Owner 

County

State 

Federal

APHIS 

New Pest 

Advisory

Group 

(Regulatory

Assessment)

BLM Vegetation Treatments Using Herbicides 2-26 June 2007 

Final Programmatic EIS 

Suspected 

New National 

Records 

Federal and 

State 

Consultation to

Assign 

Responsibility

National 

Coordination 

Mechanism 

 (Ecological 

Assessment) 

Online Plant 

Databases 

State Weed 

Team

Assessment

Detection 

Reporting 

ID 

Vouchering 

Rapid 

Assessment 

Program 

Planning 

Designated 

State Herbaria 

Suspected 

New State 

Records 

Infestation on 

Public and 

Private Lands 

Action:

Form a Weed 

Management

Area

Detection and 

Reporting by:

General 

Public 

Early 

Detection

Network

Infestation on 

Public Lands 

Action by:

Impacted

Agency

Rapid 

Response 

Figure 2-2. National Early Warning and Rapid Response System for Invasive Plants. 
ALTERNATIVES

Revegetation 

Disturbed areas may be reseeded or planted with 

desirable vegetation when the native plant community

cannot recover and occupy the site sufficiently. 

Determining the need for revegetation is an integral part 

of developing a vegetation treatment. The most

important component of the process is determining

whether active (seeding/planting) or passive (natural

recovery) revegetation is appropriate. 

USDI policy states, “Natural recovery by native plant

species is preferable to planting or seeding, either of 

natives or non-natives. However, planting or seeding

should be used only if necessary to prevent

unacceptable erosion or resist competition from nonnative invasive species” (620 Departmental 

Memorandum 3 2004). This policy is reiterated in the 

USDI Burned Area Emergency Stabilization and 

Rehabilitation Manual, the BLM Burned Area 

Emergency Stabilization and Rehabilitation Manual

(BLM H-1742-1; USDI BLM 2006a), and the 

Interagency Burned Area Rehabilitation Guidebook

(USDI and USDA 2006d). 

In addition to these handbooks and policy, use of native 

and non-native seed in revegetation and restoration is

guided by BLM Manual 1745 (Introduction, 

Transplant, Augmentation and Reestablishment of Fish, 

Wildlife and Plants). This manual states that native 

species shall be used, unless it is determined through the 

NEPA process that: 1) suitable native species are not 

available; 2) the natural biological diversity of the 

proposed management area will not be diminished; 3) 

exotic and naturalized species can be confined within 

the proposed management area; 4) analysis of

ecological site inventory information indicates that a 

site will not support reestablishment of a species that

historically was part of the natural environment; or 5)

resource management objectives cannot be met with 

native species. 

When natural recovery is not feasible, revegetation can 

be used to stabilize and restore vegetation on disturbed

sites and to eliminate or reduce the conditions that favor 

invasive species. Reseeding or replanting may be 

required when there is insufficient vegetation or seed 

stores to naturally revegetate the site. 

To ensure revegetation success, there must be adequate

soil for root development and moisture storage, which

provides moisture to support the new plants. Chances 

for revegetation success are improved by selecting seed 

with high purity and percentage germination; selecting 

native species or cultivars adapted to the area; planting 

at proper depth, seeding rate, and time of the year for 

the region; choosing the appropriate planting method;

and, where feasible, removing competing vegetation.

Planting mixtures are adapted for the treatment area and 

site uses. A combination of forbs, perennial grasses, and 

shrubs is typically used on rangeland sites, while shrubs 

and trees might be favored for riparian and forestland 

sites. A mixture of several native plant species and types 

or functional groups enhances the value of the site for 

fish and wildlife and improves the health and aesthetic

character of the site. Mixtures can better take advantage

of variable soil, terrain, and climatic conditions, and 

thus are more likely to withstand insect infestations and

survive adverse climatic conditions. 

The USDI BLM Native Seed program, which is in its 

sixth year, was developed in response to Congressional 

direction to supply native plant material for emergency 

stabilization and longer-term rehabilitation and 

restoration efforts. The focus of the program is to

increase the number of native plant species for which

seed is available and the total amount of native seed

available for these efforts. To date, the program has 

focused on native plant material needs of emergency 

stabilization and burned area rehabilitation in the Great

Basin, but is expanding to focus on areas such as 

western Oregon, the Colorado Plateau, and most

recently the Mojave Desert. The Wildland Fire 

Management Program funds and manages the effort

(USDI BLM 2006c). 

The National Seed Warehouse is a storage facility for 

the native seed supply. Through a Memorandum of

Understanding with the BLM Idaho State Director, each

state (Idaho, Oregon, Nevada, Utah and Colorado) can 

reserve an annual seed supply for purchase based on a 

reasonable projection of annual acreage to be stabilized 

or rehabilitated over a 5-year period. 

The Great Basin Restoration Initiative (GBRI) grew out

of concern for the health of the Great Basin after the

wildfires of 1999. The goal of GBRI is to implement 

treatments and strategies to maintain functioning 

ecosystems and to proactively restore degraded ones at

strategic locations. Native plants are emphasized in 

restoration projects where their use is practical and the

potential for success is satisfactory. Monitoring is 

recommended to measure treatment success. To 

increase the availability of native plants, especially

native forbs, the GBRI has established a collaborative 

native plant project, the Great Basin Native Plant

Selection and Increase Project, to increase native plant 

BLM Vegetation Treatments Using Herbicides 2-27 June 2007 

Final Programmatic EIS 
ALTERNATIVES

availability and the technology to successfully establish

these plants. This project is supported by funding from 

the BLM’s Native Plant Initiative. 

The BLM will follow the following SOPs when

revegetating sites: 

• Cultivate previously disturbed sites to reduce 

the amount of weed seeds in the soil seedbank. 

• Revegetate sites once work is completed or 

soon after a disturbance. 

• When available, use native seed of known

origin as labeled by state seed certification 

programs. 

• Use seed of non-native cultivars and species 

only when locally adapted native seed is not 

available or when it is unlikely to establish 

quickly enough to prevent soil erosion or weed 

establishment. 

• Use seed that is free of noxious and invasive

weeds, as determined and documented by a 

seed inspection test by a certified seed

laboratory. 

• Limit nitrogen fertilizer applications that favor 

annual grass growth over forb growth in newly

seeded areas, especially where downy brome

and other invasive annuals are establishing. 

• Use clean equipment, free of plants and plant 

parts, on revegetation projects to prevent the 

inadvertent introduction of weeds into the site. 

• Where important pollinator resources exist, 

include native nectar and pollen producing 

plants in the seed mixes used in restoration and 

reclamation projects. Include non-forage plant

species in seed mixes for their pollinator/host

relationships as foraging, nesting, or shelter 

species. Choose native plant species over 

manipulated cultivars, especially of forbs and 

shrubs, since natives tend to have more 

valuable pollen and nectar resources than 

cultivars. Ensure that bloom times for the 

flowers of the species chosen match the activity 

times for the pollinators. Maintain sufficient 

litter on the soil surfaces of native plant

communities for ground-nesting bees. 

• Where feasible, avoid grazing by domestic and 

wild animals on treatment sites until vegetation 

is well established. Where total rest from 

grazing is not feasible, efforts should be made 

to modify the amount and/or season of grazing 

to promote vegetation recovery within the

treatment area. Reductions in numbers, 

permanent or temporary fencing, changes in 

grazing rotation, and identification of 

alternative forage sources are examples of 

methods that could be used to remove, reduce 

or modify grazing impacts during vegetation 

recovery. 

Special Precautions 

Special Status Species 

Federal policies and procedures for protecting federallylisted threatened and endangered plant and animal

species, and species proposed for listing, were 

established by the Endangered Species Act of 1973 and

regulations issued pursuant to the Act. The purposes of 

the Act are to provide mechanisms for the conservation 

of threatened and endangered species and their habitats. 

Under the Act, the Secretary of the Interior is required

to determine which species are threatened or 

endangered and to issue recovery plans for those 

species. 

Section 7 of the Act specifically requires all federal

agencies to use their authorities in furtherance of the

Act to carry out programs for the conservation of listed

species, and to ensure that no agency action is likely to

jeopardize the continued existence of a listed species or 

adversely modify critical habitat. Policy and guidance

(BLM Manual 6840; Special Status Species) also 

stipulates that species proposed for listing must be 

managed at the same level of protection as listed 

species. 

The BLM state directors may designate special status in 

cooperation with their respective state. These special 

status species must receive, at a minimum, the same

level of protection as federal candidate species. The 

BLM will also carry out management for the 

conservation of state-listed species, and state laws 

protecting these species will apply to all BLM programs 

and actions to the extent that they are consistent with

FLPMA and other federal laws. 

The BLM consulted with the USFWS and NMFS 

during development of the PEIS as required under 

Section 7 of the Endangered Species Act. As part of this 

process, the BLM prepared a formal consultation 

package that included a description of the program;

species listed as threatened or endangered, species 

BLM Vegetation Treatments Using Herbicides 2-28 June 2007 

Final Programmatic EIS 
ALTERNATIVES

proposed for listing, and critical habitats that could be 

affected by the program; and a BA that evaluated the 

likely impacts to listed species, species proposed for 

listing, and critical habitats from the proposed 

vegetation treatment program. Over 300 species were 

evaluated in the BA. The BA also provides broad 

guidance at a programmatic level for actions that would 

be taken by the BLM to avoid adversely impacting 

species or critical habitat (USDI BLM 2007b). 

Before any vegetation treatment or ground disturbance 

occurs, BLM policy requires a survey of the project site 

for species listed or proposed for listing, or special

status species. This is done by a qualified biologist

and/or botanist who consults the state and local

databases and visits the site at the appropriate season. If 

a proposed project may affect a proposed or listed 

species or its critical habitat, the BLM consults with the

USFWS and/or NMFS. A project with a “may affect, 

likely to adversely affect” determination requires formal

consultation and receives a Biological Opinion from the

USFWS and/or NMFS. A project with a “may affect, 

not likely to adversely affect” determination requires 

informal consultation and receives a concurrence letter 

from USFWS and/or NMFS, unless that action is

implemented under the authorities of the alternative

consultation agreement pursuant to counterpart

regulations established for National Fire Plan projects. 

Wilderness Areas 

Wilderness areas, which are designated by Congress, 

are defined by the Wilderness Act of 1964 as places 

“where the earth and its community of life are

untrammeled by man, where man himself is a visitor 

who does not remain.” The BLM manages 175

Wilderness Areas encompassing over 7.2 million acres

(USDI BLM 2006d). 

Activities allowed in wilderness areas are identified in 

wilderness management plans prepared by the BLM. 

The BLM does not ordinarily treat vegetation in

wilderness areas, but will control invasive and noxious 

weeds when they threaten lands outside wilderness area

or are spreading within the wilderness and can be

controlled without serious adverse impacts to

wilderness values. 

Management of vegetation in a wilderness area is

directed toward retaining the natural character of the

environment. Tree and shrub removal is usually not

allowed, except for fire, insect, or disease control.

Reforestation is generally prohibited except to repair 

damage caused by humans in areas where natural

reforestation is unlikely. Only native species and 

primitive methods, such as hand planting, are allowed

for reforestation. 

Tools and equipment may be used for vegetation

management when they are the minimum amount

necessary for the protection of the wilderness resource. 

Motorized tools may only be used in special or 

emergency cases involving the health and safety of

wilderness visitors, or the protection of wilderness 

values. 

Habitat manipulation using mechanical or chemical

means may be allowed to protect threatened and 

endangered species and to correct unnatural conditions, 

such as weed infestations, resulting from human

influence. 

The BLM also manages a total of 610 Wilderness Study 

Areas (WSAs) encompassing nearly 14.3 million acres. 

These are areas that have been determined to have 

wilderness characteristics worthy of consideration for 

wilderness designation. The BLM’s primary goals in

WSAs are to manage them so as to not impair their 

wilderness values and to maintain their suitability for 

preservation as wilderness until Congress makes a

determination on their future. 

In WSAs, the BLM must foster a natural distribution of 

native species of plants and animals by ensuring that

ecosystems and processes continue to function 

naturally. 

Cultural Resources 

The effects of BLM actions on cultural resources are

addressed through compliance with the National

Historic Preservation Act, as implemented through a 

national Programmatic Agreement (Programmatic 

Agreement among the Bureau of Land Management, the 

Advisory Council on Historic Preservation, and the

National Conference of State Historic Preservation 

Officers Regarding the Manner in Which BLM Will 

Meet Its Responsibilities Under the National Historic 

Preservation Act) and state-specific protocol 

agreements with SHPOs. The BLM’s responsibilities 

under these authorities are addressed as early in the

vegetation management project planning process as 

possible. 

BLM Vegetation Treatments Using Herbicides 2-29 June 2007 

Final Programmatic EIS 
ALTERNATIVES

TABLE 2-8 

Standard Operating Procedures for Applying Herbicides

Resource Element Standard Operating Procedure 

Guidance Documents BLM Handbook H-9011-1 (Chemical Pest Control); and manuals 1112 (Safety), 9011 (Chemical 

Pest Control), 9012 (Expenditure of Rangeland Insect Pest Control Funds), 9015 (Integrated Weed 

Management), and 9220 (Integrated Pest Management) 

General 

• Prepare spill contingency plan in advance of treatment. 

• Conduct a pretreatment survey before applying herbicides. 

• Select herbicide that is least damaging to environment while providing the desired results. 

• Select herbicide products carefully to minimize additional impacts from degradates, adjuvants, 

inert ingredients, and tank mixtures.

• Apply the least amount of herbicide needed to achieve the desired result. 

• Follow product label for use and storage. 

• Have licensed applicators apply herbicides. 

• Use only USEPA-approved herbicides and follow product label directions and “advisory” 

statements. 

• Review, understand, and conform to the “Environmental Hazards” section on the herbicide

label. This section warns of known pesticide risks to the environment and provides practical 

ways to avoid harm to organisms or to the environment. 

• Consider surrounding land use before assigning aerial spraying as a treatment method and

avoid aerial spraying near agricultural or densely populated areas. 

• Minimize the size of application areas, when feasible. 

• Comply with herbicide-free buffer zones to ensure that drift will not affect crops or nearby

residents/landowners. 

• Post treated areas and specify reentry or rest times, if appropriate. 

• Notify adjacent landowners prior to treatment. 

• Keep copy of Material Safety Data Sheets (MSDSs) at work sites. MSDSs available for review

at http://www.cdms.net/. 

• Keep records of each application, including the active ingredient, formulation, application rate, 

date, time, and location. 

• Avoid accidental direct spray and spill conditions to minimize risks to resources. 

• Consider surrounding land uses before aerial spraying. 

• Avoid aerial spraying during periods of adverse weather conditions (snow or rain imminent, 

fog, or air turbulence). 

• Make helicopter applications at a target airspeed of 40 to 50 miles per hour (mph), and at about 

30 to 45 feet above ground. 

• Take precautions to minimize drift by not applying herbicides when winds exceed >10 mph 

(>6 mph for aerial applications) or a serious rainfall event is imminent. 

• Use drift control agents and low volatile formulations. 

• Conduct pre-treatment surveys for sensitive habitat and special status species within or adjacent 

to proposed treatment areas. 

• Consider site characteristics, environmental conditions, and application equipment in order to 

minimize damage to non-target vegetation. 

• Use drift reduction agents, as appropriate, to reduce the drift hazard to non-target species. 

• Turn off applied treatments at the completion of spray runs and during turns to start another 

spray run. 

• Refer to the herbicide label when planning revegetation to ensure that subsequent vegetation 

would not be injured following application of the herbicide. 

• Clean OHVs to remove seeds.

BLM Vegetation Treatments Using Herbicides 2-30 June 2007 

Final Programmatic EIS 
ALTERNATIVES

TABLE 2-8 (Cont.) 

Standard Operating Procedures for Applying Pesticides

Resource Element Standard Operating Procedure 

Air Quality

See Manual 7000 (Soil, Water, 

and Air Management) 

• Consider the effects of wind, humidity, temperature inversions, and heavy rainfall on herbicide 

effectiveness and risks.

• Apply herbicides in favorable weather conditions to minimize drift. For example, do not treat 

when winds exceed 10 mph (6 mph for aerial applications) or rainfall is imminent. 

• Use drift reduction agents, as appropriate, to reduce the drift hazard. 

• Select proper application equipment (e.g., spray equipment that produces 200- to 800-micron 

diameter droplets [spray droplets of 100 microns and less are most prone to drift]). 

• Select proper application methods (e.g., set maximum spray heights, use appropriate buffer 

distances between spray sites and non-target resources). 

Soil 

See Manual 7000 (Soil, Water, 

and Air Management) 

• Minimize treatments in areas where herbicide runoff is likely, such as steep slopes when heavy

rainfall is expected. 

• Minimize use of herbicides that have high soil mobility, particularly in areas where soil 

properties increase the potential for mobility. 

• Do not apply granular herbicides on slopes of more than 15% where there is the possibility of 

runoff carrying the granules into non-target areas.

Water Resources 

See Manual 7000 (Soil, Water, 

and Air Management) 

• Consider climate, soil type, slope, and vegetation type when developing herbicide treatment 

programs. 

• Select herbicide products to minimize impacts to water. This is especially important for 

application scenarios that involve risk from active ingredients in a particular herbicide, as 

predicted by risk assessments. 

• Use local historical weather data to choose the month of treatment. Considering the phenology

of the target species, schedule treatments based on the condition of the water body and existing 

water quality conditions. 

• Plan to treat between weather fronts (calms) and at appropriate time of day to avoid high winds 

that increase water movements, and to avoid potential stormwater runoff and water turbidity. 

• Review hydrogeologic maps of proposed treatment areas .Note depths to groundwater and 

areas of shallow groundwater and areas of surface water and groundwater interaction. 

Minimize treating areas with high risk for groundwater contamination.. 

• Conduct mixing and loading operations in an area where an accidental spill would not 

contaminate an aquatic body. 

• Do not rinse spray tanks in or near water bodies. Do not broadcast pellets where there is danger 

of contaminating water supplies. 

• Maintain buffers between treatment areas and water bodies. Buffer widths should be developed 

based on herbicide- and site-specific criteria to minimize impacts to water bodies. 

• Minimize the potential effects to surface water quality and quantity by stabilizing terrestrial 

areas as quickly as possible following treatment. 

Wetlands and Riparian Areas 

• Use a selective herbicide and a wick or backpack sprayer. 

• Use appropriate herbicide-free buffer zones for herbicides not labeled for aquatic use based on 

risk assessment guidance, with minimum widths of 100 feet for aerial, 25 feet for vehicle, and 

10 feet for hand spray applications. 

Vegetation 

See Handbook H-4410-1 

(National Range Handbook), 

and manuals 5000 (Forest 

Management) and 9015 

(Integrated Weed 

Management) 

• Refer to the herbicide label when planning revegetation to ensure that subsequent vegetation 

would not be injured following application of the herbicide. 

• Use native or sterile species for revegetation and restoration projects to compete with invasive 

species until desired vegetation establishes 

• Use weed-free feed for horses and pack animals. Use weed-free straw and mulch for 

revegetation and other activities. 

• Identify and implement any temporary domestic livestock grazing and/or supplemental feeding 

restrictions needed to enhance desirable vegetation recovery following treatment. Consider 

adjustments in the existing grazing permit, needed to maintain desirable vegetation on the 

treatment site. 

BLM Vegetation Treatments Using Herbicides 2-31 June 2007 

Final Programmatic EIS 
ALTERNATIVES

TABLE 2-8 (Cont.) 

Standard Operating Procedures for Applying Pesticides

Resource Element Standard Operating Procedure 

Pollinators 

• Complete vegetation treatments seasonally before pollinator foraging plants bloom. 

• Time vegetation treatments to take place when foraging pollinators are least active both 

seasonally and daily.

• Design vegetation treatment projects so that nectar and pollen sources for important pollinators 

and resources are treated in patches rather than in one single treatment. 

• Minimize herbicide application rates. Use typical rather than maximum rates where there are 

important pollinator resources. 

• Maintain herbicide free buffer zones around patches of important pollinator nectar and pollen 

sources. 

• Maintain herbicide free buffer zones around patches of important pollinator nesting habitat and 

hibernacula. 

• Make special note of pollinators that have single host plant species, and minimize herbicide 

spraying on those plants (if invasive species) and in their habitats. 

Fish and Other Aquatic 

Organisms 

See manuals 6500 (Wildlife 

and Fisheries Management) 

and 6780 (Habitat 

Management Plans) 

• Use appropriate buffer zones based on label and risk assessment guidance. 

• Minimize treatments near fish-bearing water bodies during periods when fish are in life stages

most sensitive to the herbicide(s) used, and use spot rather than broadcast or aerial treatments. 

• Use appropriate application equipment/method near water bodies if the potential for off-site 

drift exists. 

• For treatment of aquatic vegetation, 1) treat only that portion of the aquatic system necessary to 

achieve acceptable vegetation management; 2) use the appropriate application method to 

minimize the potential for injury to desirable vegetation and aquatic organisms; and 3) follow 

water use restrictions presented on the herbicide label. 

Wildlife 

See manuals 6500 (Wildlife 

and Fisheries Management) 

and 6780 (Habitat 

Management Plans) 

• Use herbicides of low toxicity to wildlife, where feasible. 

• Use spot applications or low-boom broadcast operations where possible to limit the probability

of contaminating non-target food and water sources, especially non-target vegetation over areas 

larger than the treatment area. 

• Use timing restrictions (e.g., do not treat during critical wildlife breeding or staging periods) to

minimize impacts to wildlife. 

• Avoid using glyphosate formulations that include R-11 in the future, and either avoid using any

formulations with POEA, or seek to use the formulation with the lowest amount of POEA

available, to reduce risks to amphibians.

Threatened, Endangered, and 

Sensitive Species 

See Manual 6840 (Special 

Status Species) 

• Survey for special status species before treating an area. Consider effects to special status

species when designing herbicide treatment programs. 

• Use a selective herbicide and a wick or backpack sprayer to minimize risks to special status

plants. 

• Avoid treating vegetation during time-sensitive periods (e.g., nesting and migration, sensitive 

life stages) for special status species in area to be treated. 

Livestock 

See Handbook H-4120-1 

(Grazing Management) 

• Whenever possible and whenever needed, schedule treatments when livestock are not present

in the treatment area. Design treatments to take advantage of normal livestock grazing rest

periods, when possible. 

• As directed by the herbicide label, remove livestock from treatment sites prior to herbicide

application, where applicable. 

• Use herbicides of low toxicity to livestock, where feasible. 

• Take into account the different types of application equipment and methods, where possible, to 

reduce the probability of contamination of non-target food and water sources. 

• Avoid use of diquat in riparian pasture while pasture is being used by livestock. 

• Notify permittees of the project to improve coordination and avoid potential conflicts and 

safety concerns during implementation of the treatment. 

• Notify permittees of livestock grazing, feeding, or slaughter restrictions, if necessary.

• Provide alternative forage sites for livestock, if possible. 

BLM Vegetation Treatments Using Herbicides 2-32 June 2007 

Final Programmatic EIS 
ALTERNATIVES

TABLE 2-8 (Cont.) 

Standard Operating Procedures for Applying Pesticides

Resource Element Standard Operating Procedure 

Wild Horses and Burros 

• Minimize using herbicides in areas grazed by wild horses and burros. 

• Use herbicides of low toxicity to wild horses and burros, where feasible. 

• Remove wild horses and burros from identified treatment areas prior to herbicide application,

in accordance with label directions for livestock. 

• Take into account the different types of application equipment and methods, where possible, to 

reduce the probability of contaminating non-target food and water sources. 

Cultural Resources and 

Paleontological Resources 

See handbooks H-8120-1 

(Guidelines for Conducting 

Tribal Consultation) and H8270-1 (General Procedural 

Guidance for Paleontological 

Resource Management), and 

manuals 8100 (The 

Foundations for 

ManagingCultural Resources), 

8120 (Tribal Consultation 

Under Cultural Resource 

Authorities), and 8270 

(Paleontological Resource 

Management), 

See also: Programmatic 

Agreement among the Bureau 

of Land Management, the 

Advisory Council on Historic 

Preservation, and the National 

Conference of State Historic 

Preservation Officers 

Regarding the Manner in 

Which BLM Will Meet Its 

Responsibilities Under the 

National Historic Preservation 

Act. 

• Follow standard procedures for compliance with Section 106 of the National Historic

Preservation Act as implemented through the Programmatic Agreement among the Bureau of 

Land Management, the Advisory Council on Historic Preservation, and the National

Conference of State Historic Preservation Officers Regarding the Manner in Which BLM Will 

Meet Its Responsibilities Under the National Historic Preservation Act and state protocols or 

36 CFR Part 800, including necessary consultations with State Historic Preservation Officers

and interested tribes. 

• Follow BLM Handbook H-8270-1 (General Procedural Guidance for Paleontological 

Resource Management) to determine known Condition I and Condition 2 paleontological areas, 

or collect information through inventory to establish Condition 1 and Condition 2 areas, 

determine resource types at risk from the proposed treatment, and develop appropriate 

measures to minimize or mitigate adverse impacts.

• Consult with tribes to locate any areas of vegetation that are of significance to the tribe and that 

might be affected by herbicide treatments.

• Work with tribes to minimize impacts to these resources. 

• Follow guidance under Human Health and Safety in areas that may be visited by Native 

peoples after treatments. 

Visual Resources 

See handbooks H-8410-1 

(Visual Resource Inventory) 

and H-8431-1 (Visual 

Resource Contrast Rating), 

and manual 8400 (Visual 

Resource Management) 

• Minimize the use of broadcast foliar applications in sensitive watersheds to avoid creating large 

areas of browned vegetation. 

• Consider the surrounding land use before assigning aerial spraying as an application method. 

• Minimize off-site drift and mobility of herbicides (e.g., do not treat when winds exceed 10 

mph; minimize treatment in areas where herbicide runoff is likely; establish appropriate buffer 

widths between treatment areas and residences) to contain visual changes to the intended 

treatment area. 

• If the area is a Class I or II visual resource, ensure that the change to the characteristic 

landscape is low and does not attract attention (Class I), or if seen, does not attract the attention 

of the casual viewer (Class II). 

• Lessen visual impacts by: 1) designing projects to blend in with topographic forms; 2) leaving 

some low-growing trees or planting some low-growing tree seedlings adjacent to the treatment 

area to screen short-term effects; and 3) revegetating the site following treatment. 

• When restoring treated areas, design activities to repeat the form, line, color, and texture of the 

natural landscape character conditions to meet established Visual Resource Management 

(VRM) objectives. 

BLM Vegetation Treatments Using Herbicides 2-33 June 2007 

Final Programmatic EIS 
ALTERNATIVES

TABLE 2-8 (Cont.) 

Standard Operating Procedures for Applying Pesticides

Resource Element Standard Operating Procedure 

Wilderness and Other Special 

Areas

See handbooks H-8550-1 

(Management of Wilderness 

Study Areas (WSAs)), and H8560-1 (Management of 

Designated Wilderness Study 

Areas), and Manual 8351 

(Wild and Scenic Rivers) 

• Encourage backcountry pack and saddle stock users to feed their livestock only weed-free feed 

for several days before entering a wilderness area. 

• Encourage stock users to tie and/or hold stock in such a way as to minimize soil disturbance

and loss of native vegetation. 

• Revegetate disturbed sites with native species if there is no reasonable expectation of natural 

regeneration. 

• Provide educational materials at trailheads and other wilderness entry points to educate the 

public on the need to prevent the spread of weeds.

• Use the “minimum tool” to treat noxious and invasive vegetation, relying primarily on use of 

ground-based tools, including backpack pumps, hand sprayers, and pumps mounted on pack 

and saddle stock.

• Use chemicals only when they are the minimum method necessary to control weeds that are 

spreading within the wilderness or threaten lands outside the wilderness. 

• Give preference to herbicides that have the least impact on non-target species and the

wilderness environment. 

• Implement herbicide treatments during periods of low human use, where feasible. 

• Address wilderness and special areas in management plans.

• Maintain adequate buffers for Wild and Scenic Rivers (1⁄4 mile on either side of river, 1⁄2 mile in 

Alaska).

Recreation 

See Handbook H-1601-1 

(Land Use Planning 

Handbook, Appendix C) 

• Schedule treatments to avoid peak recreational use times, while taking into account the 

optimum management period for the targeted species. 

• Notify the public of treatment methods, hazards, times, and nearby alternative recreation areas. 

• Adhere to entry restrictions identified on the herbicide label for public and worker access.

• Post signs noting exclusion areas and the duration of exclusion, if necessary. 

• Use herbicides during periods of low human use, where feasible. 

Social and Economic Values

• Consider surrounding land use before selecting aerial spraying as a method, and avoid aerial

spraying near agricultural or densely-populated areas. 

• Post treated areas and specify reentry or rest times, if appropriate. 

• Notify grazing permittees of livestock feeding restrictions in treated areas, if necessary, as 

per label instructions. 

• Notify the public of the project to improve coordination and avoid potential conflicts and

safety concerns during implementation of the treatment. 

• Control public access until potential treatment hazards no longer exist, per label instructions. 

• Observe restricted entry intervals specified by the herbicide label.

• Notify local emergency personnel of proposed treatments. 

• Use spot applications or low-boom broadcast applications where possible to limit the 

probability of contaminating non-target food and water sources, especially vegetation over

areas larger than the treatment area. 

• Consult with Native American tribes and Alaska Native groups to locate any areas of

vegetation that are of significance to the tribe and that might be affected by herbicide 

treatments. 

• To the degree possible within the law, hire local contractors and workers to assist with

herbicide application projects and purchase materials and supplies, including chemicals, for

herbicide treatment projects through local suppliers. 

• To minimize fears based on lack of information, provide public educational information on

the need for vegetation treatments and the use of herbicides in an Integrated Pest

Management program for projects proposing local use of herbicides.

BLM Vegetation Treatments Using Herbicides 2-34 June 2007 

Final Programmatic EIS 
ALTERNATIVES

TABLE 2-8 (Cont.) 

Standard Operating Procedures for Applying Pesticides

Resource Element Standard Operating Procedure 

Rights-of-way

• Coordinate vegetation management activities where joint or multiple use of a ROW exists. 

• Notify other public land users within or adjacent to the ROW proposed for treatment. 

• Use only herbicides that are approved for use in ROW areas. 

Human Health and Safety

• Establish a buffer between treatment areas and human residences based on guidance given in 

the HHRA, with a minimum buffer of 1⁄4 mile for aerial applications and 100 feet for ground 

applications, unless a written waiver is granted. 

• Use protective equipment as directed by the herbicide label. 

• Post treated areas with appropriate signs at common public access areas. 

• Observe restricted entry intervals specified by the herbicide label. 

• Provide public notification in newspapers or other media where the potential exists for public 

exposure. 

• Have a copy of MSDSs at work site. 

• Notify local emergency personnel of proposed treatments. 

• Contain and clean up spills and request help as needed. 

• Secure containers during transport. 

• Follow label directions for use and storage. 

• Dispose of unwanted herbicides promptly and correctly. 

The BLM meets its responsibilities for consultation and

government-to-government relationships with Native 

American tribes by consulting with appropriate tribal

representatives prior to taking actions that affect tribal 

interests. The BLM’s tribal consultation policies are

detailed in BLM Manual 8120 (Tribal Consultation

Under Cultural Resource Authorities) and Handbook H8120-1 (Guidelines for Conducting Tribal 

Consultation). The BLM consulted with Native

American tribes and Alaska Native groups during

development of this PEIS. Information gathered on 

important tribal resources and potential impacts to these

resources from herbicide treatments is presented in the 

analysis of impacts. 

When conducting vegetation treatments, field office 

personnel consult with relevant parties (including tribes, 

native groups, and SHPOs), assess the potential of the 

proposed treatment to affect cultural and subsistence 

resources, and devise inventory and protection strategies 

suitable to the types of resources present and the 

potential impacts to them. 

Herbicide treatments, for example, are unlikely to affect

buried cultural resources, but might have a negative 

effect on traditional cultural properties comprised of

plant foods or materials significant to local tribes and

native groups. These treatments require inventory and 

protection strategies that reflect the different potential of

each treatment to affect various types of cultural 

resources. 

Impacts to significant cultural resources are avoided 

through project redesign or are mitigated through data

recovery, recordation, monitoring, or other appropriate 

measures. When cultural resources are discovered 

during vegetation treatment, appropriate actions are 

taken to protect these resources. 

Monitoring 

Monitoring ensures that vegetation management is an 

adaptive process that continually builds upon past 

successes and learns from past mistakes. The

regulations of 43 CFR 1610.4-9 require that land use 

plans establish intervals and standards for monitoring

and evaluating of land management actions. During

preparation of implementation plans, treatment

objectives, standards, and guidelines are stated in

measurable terms, where feasible, so that treatment

outcomes can be measured, evaluated, and used to guide 

future treatment actions. This approach ensures that

vegetation treatment processes are effective, adaptive,

and based on prior experience. 

The diversity of plant communities on BLM lands calls 

for a diversity of monitoring approaches. Monitoring 

strategies may vary in time and space depending on the 

BLM Vegetation Treatments Using Herbicides 2-35 June 2007 

Final Programmatic EIS 
ALTERNATIVES

species. Sampling designs and techniques vary 

depending on the type of vegetation. Guidance on 

monitoring methodologies can be found in such BLM

documents as Measuring and Monitoring Plant 

Populations (BLM Technical Reference 1730-1), which

was developed in cooperation with The Nature 

Conservancy. Other guidance documents include 

Sampling Vegetation Attributes (Interagency Technical 

Reference 4400-4), developed in cooperation with the 

Forest Service, the Natural Resource Conservation 

Service, and the Cooperative Extension Service; and the 

Ecological Site Inventory (BLM Inventory and

Monitoring Technical Reference 1734-7). These 

documents, as well as numerous other guidance 

documents for specific plant communities, can be found

on the National Science and Technology Center website 

(http://www.blm.gov/nstc). These documents, plus any 

regionally specific documents developed to meet

management objectives allow for the flexibility needed 

to monitor the variety of vegetation on public lands.

Two types of monitoring of vegetation treatments may 

be pursued by the BLM. One type is implementation 

monitoring which answers the question, “Did we do

what we said we would do?” The second type is 

effectiveness monitoring, which answers the question, 

“Were treatment and restoration projects effective?”

Implementation monitoring is usually done at the land

use planning level or through annual work plan

accomplishment reporting. Effectiveness monitoring is 

usually done at the local project implementation level. 

Invasive plant implementation monitoring for nonherbicide treatments is accomplished through site 

revisits performed during the growing season of the 

target species to determine if treatments were

implemented correctly and the best time for follow-up

treatments. 

For herbicide use, implementation monitoring is

accomplished through the use of Pesticide Use

Proposals (PUPs) and Pesticide Application Records. 

Both documents are required by the BLM in order to

track pesticide use annually. The PUP requires reporting 

of the pesticide proposed for use and the maximum 

application rate. It also requires reporting of the number 

and timing of applications. Targeted species and nontargeted species at the treatment site are described, as 

well as the other site characteristics. A description of 

sensitive resources and mitigation measures to protect

these resources is also required. Most importantly, the

integrated weed management approach to be taken (i.e., 

the combination of treatments to be used) is required. 

The NEPA document that analyzes the effects of the

treatment must also be referenced. PUPs must be signed

by a certified weed applicator, the field office manager,

state coordinator, and deputy state director before the 

treatment can go forward. The Pesticide Application

Record, which must be completed within 24 hours after 

completion of the application, documents the actual rate

of application and that all the above factors have been

taken into account. Pesticide Application Records are 

used to develop annual state summaries of herbicide use 

for BLM. 

PUPs and Pesticide Application Records can also be

used for more site-specific implementation monitoring. 

For example, the Application Record can be used to 

track whether the application was made at the correct 

time, if mitigation for sensitive wildlife concerns is

included in the PUP. 

Monitoring of invasive plant treatment effectiveness can

range from site visits to compare the targeted population

size against pre-treatment inventory data, to comparing 

pre-treatment and post-treatment photo points, to more 

elaborate transect work, depending on the species and

site-specific variables. The goals of monitoring should

be to answer questions such as the following: 

• What changes in the distribution, amount, and 

proportion of invasive plant infestations have 

resulted due to treatments?

• Has infestation size been reduced at the project

level or larger scale (such as a watershed)?

• Which treatment methods, separate or in 

combination, are most successful for a 

particular species? (USDA Forest Service 

2005). 

Monitoring data can have far-reaching applications in 

fire management because it provides the scientific basis 

for planning and implementing future burn treatments. 

Measuring post-fire ecosystem response allows the 

BLM to understand the consequences of fire on

important ecosystem components and to share this

knowledge in a scientifically based language. 

Monitoring is the critical feedback loop that allows fire 

management to constantly improve prescriptions and 

fire plans based on the new knowledge gained from 

field measurements. FIREMON is an interagency 

monitoring program that is used for monitoring fuels 

treatment effectiveness. When a fuels treatment project

involves an invasive species (such as tamarisk or

Russian olive), monitoring can be done using a program

such as FIREMON. 

BLM Vegetation Treatments Using Herbicides 2-36 June 2007 

Final Programmatic EIS 
ALTERNATIVES

Another monitoring protocol frequently used to

inventory and monitor forest vegetation is called the 

Forest Vegetation Information System or FORVIS. 

FORVIS is a system for storage, retrieval, and analysis 

of data about forestlands. These data describe existing

vegetation, classify sites relative to current condition, 

can be used in forest growth and structure and wildlife 

habitat models, describe landscapes, aid in developing

forest restoration treatments, and provide a record of 

treatment and disturbance events. 

BLM monitoring activities also include the BLM

Legacy program, which is an outgrowth of the need to

provide current BLM field managers and specialists 

with an opportunity to learn about past land 

management practices and land treatments, and to 

evaluate the results of those practices 25 or more years 

later (USDI BLM 2002c). The Legacy program is

intended to bring together current land managers and 

specialists with retired and active employees who

performed the land treatments in the past. The

underlying philosophy of the program is that if BLM 

land managers do not learn from the past, they cannot

know which treatments are effective and which are not. 

The Healthy Forests Restoration Act of 2003 instructs 

the BLM to establish a collaborative multiparty 

monitoring, evaluation, and accountability process when

significant interest is expressed in such an approach. 

The process is used to assess the positive and negative 

ecological and social effects of projects carried out 

under Healthy Forests Restoration Act authority. 

Multiparty monitoring can be an effective way to build 

trust and collaboration with local communities and

diverse stakeholders, including interested citizens and 

tribes. 

The results of monitoring should be made available to 

interested parties. A website with links to geospatial and 

other data sets will ensure that inventory data, and 

treatment methods and results, are shared easily. The 

BLM has a website, http://www.blm.gov, with links to 

BLM programs, such as the weed program, and other 

data sources, including geospatial data. Most state 

offices are tied into state data clearinghouses that

contain useful information gathered by federal, state, 

and local agencies. 

Monitoring Guidance used by BLM in 

Vegetation Management 

The BLM has prepared numerous guidance and strategy

documents to aid field personnel in developing and 

implementing monitoring plans and strategies. These 

include the following: 

• BLM National Monitoring Strategy (2006).

The BLM is currently developing a national

strategy to manage the collection, storage, and 

use of data describing the interrelationship of 

resource conditions, resource uses, and the 

BLM’s own activities. The goals of the strategy 

are to: 1) enhance the efficiency and 

effectiveness of the BLM’s assessment,

inventory, and monitoring efforts; 2) establish 

and use a limited number of resource indicators 

that are common to most or all BLM field

offices, and that are comparable or identical to 

measures used by other government agencies 

and non-governmental organizations; and 3) 

standardize data collection, evaluation, and 

reporting in a way that improves the quality of 

the BLM’s land use planning and other 

management decisions, and enhances the 

BLM’s ability to manage for multiple uses. 

• BLM Land Use Planning Handbook H-1601-

1 (2005). Establishes requirements for periodic

implementation and effectiveness monitoring 

for land use planning decisions. 

• Monitoring Manual for Grasslands,

Shrubland, and Savanna Ecosystems Vols. I 

and II. USDA Agricultural Research Service

(2005). Provides quantitative methods to

address indicators of rangeland health. 

• BLM Technical Reference 1730-2 Biological 

Soil Crusts (2001). Provides technical 

guidance on how to develop and implement

effective monitoring plans for biological soil

crusts. 

• BLM Handbook H-4180-1 Rangeland Health 

Standards (2001). Provides technical guidance 

on evaluating rangeland health, developing 

plans to improve rangeland health, and 

monitoring the progress of rangeland health 

plans. 

• BLM Technical Reference 1730-1 Measuring

and Monitoring Plant Populations (1998).

Provides technical guidance on how to develop

and implement effective monitoring plans for 

vegetation and use monitoring in adaptive

management. 

BLM Vegetation Treatments Using Herbicides 2-37 June 2007 

Final Programmatic EIS 
ALTERNATIVES

• BLM Technical Reference 1734-4 Sampling

Vegetative Attributes (1996). Provides the 

basis for consistent, uniform, and standard

vegetation attribute sampling that is 

economical, repeatable, statistically reliable, 

and technically adequate. 

• Manual Section 9011 Chemical Pest Control 

(1992). Establishes requirements for 

monitoring pesticide applications. 

• Manual Section 9014 Use of Biological

Control Agents of Pests on Public Lands 

(1990). Establishes requirements to monitor 

success or failure in survival, control, and 

spread of biological agents. 

• Guidelines for Coordinated Management of 

Noxious Weeds (1990). Provides guidance on

establishing monitoring plans for noxious 

weeds and their control. 

• BLM Handbook H-4400-1 Range Monitoring

and Evaluation (1989). Provides technical 

guidance on how to measure vegetation uses 

such as livestock grazing, wild horse and burro

use, and wildlife browsing and foraging. 

• BLM Handbook H-9011-1 Chemical Pest

Control (1988). Provides technical guidance on 

post-treatment evaluations for pesticide 

applications to occur within 2 years of 

treatment. 

• NEPA Handbook H-1790-1 Chapter VI – 

Monitoring (1988). All actions and mitigation 

measures, including monitoring and

enforcement programs, adopted in a decision

document are legally enforceable 

commitments. The purposes of monitoring in a 

NEPA context are to 1) ensure compliance 

with decisions, 2) measure effectiveness of 

decisions, and 3) evaluate validity of decisions. 

• Manual Section 1734 Monitoring and 

Inventory Coordination (1983). Provides the 

BLM with technical guidance on how to

develop and implement effective monitoring 

plans for vegetation.

Numerous other technical references for inventory,

monitoring, and assessment are found at: 

http://www.blm.gov/nstc/library/techref.htm. In

addition, state-specific handbooks to guide monitoring 

based on the national level guidance (e.g., Nevada 

Monitoring Handbook, Oregon Monitoring Handbook).

Monitoring Methods and Research 

Fuels treatment and noxious weed control projects must

begin with an understanding of which techniques and 

monitoring methods are most effective, as determined

through careful research and follow-up monitoring. The 

BLM has been supporting research at universities and

Forest Service research stations through the Joint Fire 

Science program and projects such as the Great Basin

Restoration Initiative. The Joint Fire Science program

has supported research on such topics as fire effects, 

effects from fuels treatments, and the use of fire as a

tool in controlling invasive plants (http://jfsp.nifc.gov/). 

Under the Great Basin Restoration Initiative, ongoing

projects involving weed control, restoration, and fire 

treatments help provide a link between science and

management to ensure that ecologically-based

restoration is implemented. These projects are 

summarized at

http://www.fire.blm.gov/gbri/technology.html. 

Dissemination of research and monitoring results and

information occurs in a variety of ways, including

formal conferences and workshops of fire management 

professionals, the National Science and Technology

Center, publications such as Resource Notes, and BLM

state websites. Snapshots, an online publication found at

http://www.fire.blm.gov/snapshots.htm, highlights 

BLM projects that support the National Fire Plan. 

Examples of successful projects and community

collaborations that have been discussed in Snapshots 

include creation and monitoring of fuels breaks, habitat 

improvement through prescribed burning, fuels 

reduction and associated monitoring, and the progress 

of a downy brome taskforce. Examples of project

successes include the following: 

• In Wyoming, a multi-agency prescribed burn

was completed in 2005 to reduce hazardous 

fuels and improve the health and vigor of 

native plant communities. Monitoring methods 

include permanent vegetation transects and 

photo points to provide post-burn results and an 

elk collaring study to show which treatment

areas are being used by elk. The information

obtained during this study will be shared with

the public, and the site will be used by school 

classes. 

BLM Vegetation Treatments Using Herbicides 2-38 June 2007 

Final Programmatic EIS 
ALTERNATIVES

• In Wyoming, a tamarisk reduction project was 

started in the Bighorn Basin in 2000 to restore 

native cottonwood galleries. The project 

involves various combinations of treatments, as 

well as plantings of native species following

the treatments.

• In Washington, the BLM has been treating reed

canarygrass since 2003, using a combination of

prescribed burning, herbicides, and mowing, 

followed by seedbed preparation and reseeding

with native seed mixtures. This project is a

partnership with the Natural Resource 

Conservation Service, Washington State 

Department of Fish and Wildlife, and the U.S. 

Fish and Wildlife Service. 

BLM offices maintain monitoring reports to document

that fuels treatments meet set objectives. Monitoring 

plans typically include plots and photo points, at which

pre- and post-treatment data are collected. This type of 

monitoring has successfully provided data that has 

allowed the BLM to confirm that project goals have

been met. 

Coordination and Education 

As demonstrated at public scoping meetings for the 

PEIS, the public is deeply interested in BLM vegetation 

treatment activities, especially individuals that live in 

close proximity to public lands, have commercial

operations dependant on vegetation on or adjacent to 

public lands, or use public lands for recreation. The 

BLM strives to keep the public informed about its 

vegetation treatment activities through regular 

coordination and communication. The BLM also 

encourages the public to participate in the 

environmental review process during the development 

and analysis of local vegetation management programs. 

Several laws and Executive Orders set forth public 

involvement requirements, including involving the

public in the environmental analysis, land use planning,

and implementation decision-making processes to

address local, regional, and national interests (USDI

BLM 2000f). 

The BLM is ultimately responsible for land use plan

decisions, including decisions about vegetation 

management, on public lands. The BLM has found, 

however, that collaborative relationships with

stakeholders, including individuals, communities, and

governments, improves communication, provides a 

greater understanding of different perspectives, and 

helps to find solutions to issues and problems. Input

from the public and government agencies has been 

critical during development of this PEIS and the PER. 

The NEPA process ensures that the public is allowed

input into vegetation management actions on public 

lands. For treatment projects requiring an EA or EIS, 

the BLM must notify the public of the proposed project 

and give the public the opportunity to comment on the 

site-specific analysis done for the project. Treatment

actions may be modified in response to comments posed 

by the public. The public may also be invited to observe 

treatment activities and participate in project

monitoring. 

Public lands are often commingled with private lands, 

or lands under the jurisdiction of tribal, state, or local 

governments or other federal agencies. 

Multijurisdictional planning assists land use planning 

efforts when there is a mix of land ownership and 

government authorities, and there are opportunities to 

develop complementary decisions across jurisdictional 

boundaries. 

Examples of these planning efforts include development

of weed treatment programs involving the BLM and

nearby private landowners, or coordination with parties 

who hold land use authorizations including ROW, 

leases, permits, or easements. Many BLM weed

coordinators hold classes for public land users to make 

them aware of the problem and to solicit their help in 

reporting new weed infestations. 

Because vegetation treatments have a direct effect on 

the productivity and use of grazing allotments, 

coordination and consultation with the grazing

permittee(s), and any other interested parties affected by 

a vegetation treatment, would be necessary. 

It is critical that the BLM notify potentially affected

parties of treatment activities that occur on public lands.

This can be done through a letter, phone call, meeting, 

newsletter, newspaper article, or other medium to

ensure that potentially affected parties can comment on 

the proposed action and take any steps needed to protect

life and property from proposed actions. 

Prior to herbicide treatments, the BLM posts entry 

points onto public lands where the herbicide application 

will take place. Information provided in the posting will

includes herbicide product applied; active ingredients;

USEPA registration number; application date; period of

time which must elapse before a person without 

BLM Vegetation Treatments Using Herbicides 2-39 June 2007 

Final Programmatic EIS 
ALTERNATIVES

protective clothing may enter a treatment site; and other 

warnings or information required to ensure the safety of

the public. 

The BLM enjoys wide participation in various national,

state, and local prevention and education efforts 

pertaining to noxious and invasive species and 

hazardous fuels management. The BLM participates in

state FireWise programs, state Fire Safe Councils, the

National Wildfire Coordinating Group Wildland Fire 

Education Working Team, and the National Wildland 

Fire Prevention and Education Team. Local education 

efforts such as Project: FIRE bring BLM natural

resource professionals into schools to educate students 

about fire prevention and safety. Noxious weed and 

invasive species education programs span the K-12 

grades and are led by many local BLM field office

ecologists and natural resource professionals. The BLM

also participates in Project Learning Tree. Project 

Learning Tree, one of the most widely-used

environmental education programs in the country, 

provides education curricula for fire and invasive

species education. 

Mitigation 

Table 2-9 identifies the measures the BLM proposes to 

mitigate adverse environmental impacts identified in 

Chapter 4 (Environmental Consequences). As defined

by CEQ regulation 1508.20, mitigation includes: 1) 

avoiding the impact altogether by not taking a certain 

action or parts of an action; 2) minimizing impacts by

limiting the degree or magnitude of the action and its 

implementation; 3) rectifying the impact by repairing,

rehabilitating, or restoring the affected environment; 4) 

reducing or eliminating the impact over time by

preservation and maintenance operations during the life 

of the action; and 5) compensating for the impact by

replacing or providing substitute resources or 

environments. 

Numerous mitigation measures were developed from

information provided in ERAs and during development

of this PEIS. The measures listed below would apply to 

plants, animals, and other resources at the programmatic 

level in all 17 western states. However, local BLM field 

offices could use interactive spreadsheets and other 

information contained in the ERAs to develop more 

site-specific mitigation and management plans based on

local conditions (e.g., soil type, rainfall, vegetation type, 

herbicide treatment method, and herbicide application

rate). It is possible that mitigation measures would be 

less restrictive than those listed below if local site

conditions were evaluated using the ERAs when

developing project-level mitigation plans. In addition,

the BLM may be able to use timing restrictions or

similar practices to reduce the level of risk to an

acceptable level. For example, it may be necessary to 

apply diuron at the typical herbicide application rate to

ensure protection of a migratory bird species. However, 

it may be acceptable to use the maximum application 

rate during periods of the year when the bird has 

migrated from the treatment area. Local field managers 

would consult the ERAs and review species life history 

requirements before making these decisions to ensure 

that birds and other resources are adequately protected. 

Summary of Impacts by 

Alternative 

Table 2-10 summarizes the likely effects of vegetation 

treatments using herbicides for each alternative. 

Information contained in this table is discussed in more 

detail in Chapter 4 (Environmental Consequences). 

BLM Vegetation Treatments Using Herbicides 2-40 June 2007 

Final Programmatic EIS 
ALTERNATIVES

TABLE 2-9 

Mitigation Measures 

Resource Mitigation Measures

Air Quality None proposed. 

Soil Resources None proposed. 

Water Resources and Quality • Establish appropriate (herbicide specific) buffer zones to downstream water bodies, habitats, 

and species/populations of interest (see Appendix C, Table C-16). 

Wetland and Riparian Areas • See mitigation for Water Resources and Quality and Vegetation. 

Vegetation 

• Minimize the use of terrestrial herbicides (especially bromacil, diuron, and sulfometuron

methyl) in watersheds with downgradient ponds and streams if potential impacts to aquatic 

plants are of concern. 

• Establish appropriate (herbicide specific) buffer zones around downstream water bodies,

habitats, and species/populations of interest. Consult the ERAs for more specific information

on appropriate buffer distances under different soil, moisture, vegetation, and application

scenarios. 

• To protect special status plant species, implement all conservation measures for plants 

presented in the Vegetation Treatments on Bureau of Land Management Lands in 17 Western 

States Programmatic Biological Assessment. 

Fish and Other Aquatic 

Organisms 

• Limit the use of diquat in water bodies that have native fish and aquatic resources. 

• Limit the use of terrestrial herbicides in watersheds with characteristics suitable for potential

surface runoff, that have fish-bearing streams, during periods when fish are in life stages most

sensitive to the herbicide(s) used.

• To protect special status fish and other aquatic organisms, implement all conservation measures 

for aquatic animals presented in the Vegetation Treatments on Bureau of Land Management 

Lands in 17 Western States Programmatic Biological Assessment. 

• Establish appropriate herbicide-specific buffer zones for water bodies, habitats, or fish or other

aquatic species of interest (see Appendix C, Table C-16, and recommendations in individual 

ERAs). 

• Avoid using the adjuvant R-11® in aquatic environments, and either avoid using glyphosate 

formulations containing POEA, or seek to use formulations with the least amount of POEA, to

reduce risks to aquatic organisms. 

Wildlife 

• To minimize risks to terrestrial wildlife, do not exceed the typical application rate for 

applications of dicamba, diuron, glyphosate, hexazinone, tebuthiuron, or triclopyr, where

feasible. 

• Minimize the size of application areas, where practical, when applying 2,4-D, bromacil, diuron,

and Overdrive

® to limit impacts to wildlife, particularly through contamination of food items. 

• Where practical, limit glyphosate and hexazinone to spot applications in rangeland and wildlife 

habitat areas to avoid contamination of wildlife food items. 

• Avoid using the adjuvant R-11® in aquatic environments, and either avoid using glyphosate 

formulations containing POEA, or seek to use formulations with the least amount of POEA, to

reduce risks to amphibians. 

• Do not apply bromacil or diuron in rangelands, and use appropriate buffer zones (see

Vegetation section in Chapter 4) to limit contamination of off-site vegetation, which may serve

as forage for wildlife. 

• Do not aerially apply diquat directly to wetlands or riparian areas. 

• To protect special status wildlife species, implement all conservation measures for terrestrial 

animals presented in the Vegetation Treatments on Bureau of Land Management Lands in 17 

Western States Programmatic Biological Assessment. Apply these measures to special status 

species (refer to conservation measures for a similar size and type of species, of the same 

trophic guild). 

BLM Vegetation Treatments Using Herbicides 2-41 June 2007 

Final Programmatic EIS 
ALTERNATIVES

BLM 

Final Pr

Vegetation Treatments Using Herbicides 2-42 June 2007 

ogrammatic EIS 

TABLE 2-9

Mitigation Measures

Resource Mitigation Measures

Livestock 

• Minimize potential risks to livestock by applying diuron, glyphosate, hexazinone, tebuthiuron,

and triclopyr at the typical application rate, where feasible.

• Do not apply 2,4-D, bromacil, dicamba, diuron, Overdrive

®, picloram, or triclopyr across large

application areas, where feasible, to limit impacts to livestock, particularly through the

contamination of food items.

• Where feasible, limit glyphosate and hexazinone to spot applications in rangeland.

• Do not aerially apply diquat directly to wetlands or riparian areas used by livestock.

• Do not apply bromacil or diuron in rangelands, and use appropriate buffer zones (see

Vegetation section in Chapter 4) to limit contamination of off-site rangeland vegetation.

Wild Horses and Burros 

• Minimize potential risks to wild horses and burros by applying diuron, glyphosate, hexazinone,

tebuthiuron, and triclopyr at the typical application rate, where feasible.

• Consider the size of the application area when making applications of 2,4-D, bromacil,

dicamba, diuron, Overdrive

®, picloram, and triclopyr in order to reduce potential impacts to

livestock.

• Apply herbicide label grazing restrictions for livestock to herbicide treatment areas that support

populations of wild horses and burros.

• Where feasible, limit glyphosate and hexazinone to spot applications in rangeland.

• Do not apply bromacil or diuron in grazing lands within herd management areas, and use

appropriate buffer zones (see Vegetation section in Chapter 4) to limit contamination of

vegetation in off-site foraging areas.

• Do not apply 2,4-D, bromacil, or diuron in herd management areas during the peak foaling

season (March through June, and especially in May and June), and do not exceed the typical

application rate of Overdrive

® or hexazinone in HMAs during the peak foaling season.

Paleontological and Cultural 

Resources

• Do not exceed the typical application rate when applying 2,4-D, bromacil, diquat, diuron,

fluridone, hexazinone, tebuthiuron, and triclopyr in known traditional use areas.

• Avoid applying bromacil or tebuthiuron aerially in known traditional use areas.

• Limit diquat applications to areas away from high residential and traditional use areas to reduce

risks to Native Americans and Alaska Natives.

Visual Resources None proposed.

Wilderness and Other Special 

Areas

Mitigation measures that may apply to wilderness and other special area resources are associated

with human and ecological health and recreation. Please refer to the Vegetation, Fish and Other

Aquatic Resources, Wildlife Resources, Recreation, and Human Health and Safety sections of

Chapter 4.

Recreation 

Mitigation measures that may apply to recreational resources are associated with human and

ecological health. Please refer to the Vegetation, Fish and Other Aquatic Resources, Wildlife

Resources, and Human Health and Safety sections of Chapter 4.

Social and Economic Values None proposed.

Human Health and Safety

• Use the typical application rate, where feasible, when applying 2,4-D, 2,4-DP, atrazine,

bromacil, diquat, diuron, fluridone, fosamine, hexazinone, tebuthiuron, and triclopyr to reduce

risk to occupational and public receptors.

• Avoid applying atrazine, bromacil, diuron, or simazine aerially.

• Limit application of chlorsulfuron via ground broadcast applications at the maximum 

application rate.

• Limit diquat application to ATV, truck spraying, and boat applications to reduce risks to

occupational receptors; limit diquat applications to areas away from high residential and

subsistence use to reduce risks to public receptors.

• Evaluate diuron applications on a site-by-site basis to avoid risks to humans. There appear to be

few scenarios where diuron can be applied without risk to occupational receptors.

• Do not apply hexazinone with an over-the-shoulder broadcast applicator.

Mitigation Measures (Cont.)
TABLE 2-10

Summary and Compariso

n of Effects on Resources by Alter

native

No Action Alternative Preferred Alternative Alter

native C Alter

native D 

EFFECTS ON AIR QUALITY 

General Effects: None of the predicted annual emissions bypollutant or state would exceed prevention of significant deterioration (PSD) annual emissions significance thresholds.Treatments would result inapproximately 77 tons per year (tpy) of total suspended particles (TSP), 24 tpy of carbon monoxide (CO), and 17 tpy of PM10

(particulate 

matter less than 10 

microns in dia

meter). These 

emissions are lower than emissions all other herbicide treatment alternatives. 

General Effects: None of the predicted annual emissions bypollutant or state would exceed PSD annual e

missions 

significance thresholds. Particulate matter concentrations from treat

ments are expected to 

be substantially lower thanNAAQS thresholds based onmodeling. Treatments would result in approximately 206 tpy of TSP, 62 tpy of CO, and 45 tpy of PM10. These emissions are twice 

those predicted for the No Action Alternative, with half of the emissions occurring in Idaho and Nevada.

General Effects: Herbicideswould not be used for vegetation management. There would be no herbicide treat

ment-related 

emissions associated with thisalternative.

General Effects: None of the predicted annual emissions bypollutant or state would exceed PSD annual e

missions 

significance thresholds. Particulate matter (PM) concentrations are substantiallylower than NAAQS thresholds at sa

mple locations. Treatments 

would result in approximately 257 tpy of TSP, 83 tpy of CO, and 55 tpy of PM10, greater than the 

amount of e

missions generated 

under the Preferred Alternative, even though 40% fewer acreswould be treated. The elevated amounts of e

missions are 

pri

marily related to the reliance 

on ground equip

ment for 

treatment applications. However, herbicide drift would likely be less than under the other herbicide treatment alternatives.

GenpredpollPSD signconclowsa

m

woutpy tpy 

the Nhalf Alte

Cumulative Effects: The cumulative effects of all agricultural, commercial, industrial, and other activities that have emitted air pollutants in the western U

contributed to deterioration in air quality. Despite increases in these activities and in human population, total emissions of principal air pollutants peaked in and have generally declined during the past 2 decades. BLM treatment activities have contributed < 1% of criteria pollutants nationwide in recent years. Emuse and other treatment 

methods under the action alternatives 

would increase from current levels, but would still comprise < 1% of total pollutants generat

emissions would be associated with the use of fire. However, e

missions associated with wildfire are generally greater than those associated with prescribed 

Smoke e

missions would be reduced by permitting fires only during 

meteorological periods favorable to dispersion and avoiding population centers. BLM 

treatments, including fire use, to restore historical fire regimes, native vegetation, and natural ecosyste

m processes should reduce the frequency and intensi

accumulation of pollutants than would occur under the No Action Alternative. Although 40% fewer acres would be treated using herbicides (the number o

treatment methods would be similar between the t

wo alternatives), criteria pollutant emissions would be greater under Alternative D than the Preferred Alt

treatments would be ground-based, while much of the acreage treated under the Preferred Alternative would be applied using aircraft. Exceedances of NAany alternatives. Improvements in pollution control technology should further reduce pollutants associated with vegetation treatments in the future.

EFFECTS ON SOIL RESOURCES 

Under the No Action Alternative, approximately 305,000 acreswould be treated annually. None of the herbicides likely to be used would result in severe effects to 

Under the Preferred Alternative, approximately 932,000 acreswould be treated annually. None of the herbicides likely to be used would result in severe effects to 

Under Alternative C, herbicides would not be used for vegetation management; thus there would be no effects to soil from herbicides. Because herbicides would not be 

Under Alternative D, approximately 530,000 acreswould be treated annually. The risk of inadvertent applications to soils off of public lands would be 

Undapprwouinhiused 

BLM Vegetation Treatments Using Herbicides 2-43 June 2007

Final Programmatic EIS
TABLE 2-10 (Co

nt.) 

Summary and Compariso

n of Effects on Resources by Alter

native

No Action Alternative Preferred Alternative Alter

native C Alter

native D 

soil. Because fewer acres would be treated under this alternative than under the other herbicide treatment alternatives, benefits to soil from treat

ments (e.g., 

improved soil productivity, reduced soil erosion) would be less under this alternative than under the other treatment alternatives. 

soil. New herbicides proposed for use would have minor effects on soil, but should help reduce populations of invasive species. Because more acres would be treated under this alternative than under the other alternatives, benefits to soil from treatments (e.g., improved soil productivity, reduced soil erosion) would be greatest under this alternative. Herbicides could also be used to benefit soils in Alaska, Nebraska, and Texas if treatments occurred there. 

used to treat vegetation, invasive plant populations could increase and adversely affect soil resources in areas where herbicide treatments are the only practical method of treatment. Other treatment methods (manual, mechanical, biological, and use of prescribed fire) could also disturb and harm soil and could be more detri

mental to soil in a treatment 

area than the use of herbicides. 

less under this alternative than under the other treatment alternatives. In areas where ground-based treatments were ineffective or too costly to imple

ment, vegetation control 

might not occur, potentiallyresulting in adverse effects to soil. Because fewer acres would be treated under this alternative than under the Preferred Alternative, benefits to soil from treatments (e.g., improved soil productivity, reduced soil erosion) would be less. New herbicides proposed for use would have minor effects on soil, but should help reduce populations of invasive species. Itis likely that the BLM would use less imazapic under thisalternative than under the Preferred Alternative. Herbicidescould also be used to benefit soils in Alaska, Nebraska, and Texas iftreatments occurred there. 

Howherbbe mto dnotaherbpropThuimpalterALSThis activsoilgrazwoualterPrefsoil impredulessnot has of dfires Grewesto thdowalso Alatrea

Cumulative Effects: Human activities associated with commodity extraction, agriculture, and urbanization, and 

more recently with large-scale, catastroph

soil erosion and loss of soil productivity on public lands and throughout the West. Soils in Alaska have been impacted by mineral extraction, logging, and Treatments would lead to loss of vegetation and soil, but long-term improvement in ecosystems should restore soil and improve soil productivity. Several conservation progra

ms by the BLM will also i

mprove soil on rangelands. Rangeland health on public lands has shown improve

ment over the past 2 decade

soil loss has slowed. Short-term soil loss would be greatest under the Preferred Alternative, but long-term i

mprovement in soil function would be greatest u

would be irretrievable, but soil productivity on degraded lands could be retrieved over decades or centuries. 

EFFECTS ON WATER RESOURCES AND QUALITY 

Impacts to surface and groundwater quality would be 

Benefits and risks to water quality and quantity would be greatest 

There would be no effects from herbicides on water quality. In 

The BLM would be unable to treat large areas with herbicides. 

Undinhi

BLM Vegetation Treatments Using Herbicides 2-44 June 2007

Final Programmatic EIS
TABLE 2-10 (Co

nt.) 

Summary and Compariso

n of Effects on Resources by Alter

native

No Action Alternative Preferred Alternative Alter

native C Alter

native D 

similar to the ongoing program. Herbicides most commonly used are known groundwater contaminants (2,4-D, glyphosate, piclora

m, and tebuthiuron), and 

several other herbicides that maybe used (2,4-

DP, atrazine, and 

simazine) are also known groundwater contaminants. Impacts to water quality and quality, and benefits to watersheds from herbicide treatments would be lowest under this alternative. 

under this alternative. Of new herbicides proposed for use, diquat and fluridone are effective in controlling aquatic plants to improve water quality in lakes and strea

ms, but diquat is a 

known groundwater contaminant. Imazapic is not known to contaminate groundwater and in upland treatments could serve as areplacement for herbicides that are known groundwater contaminants. Removal of unwanted vegetation should improve hydrologic functions in treated watersheds. The BL

M

would also be able to use herbicides to i

mprove watershed 

function and water resources and quality in Alaska, Nebraska, and Texas, although no herbicide treatments are currently proposedfor Alaska and Nebraska. 

areas with weeds and other infestations, hydrologic functionscould deteriorate in areas where herbicide treat

ments are the only

effective treatment method. 

Thus, benefits to watersheds from large-scale herbicide treatmentswould not occur. Fire use and mechanical treat

ments could 

replace herbicide treatments in some areas, but could be less effective and cause greater soil disturbance, leading to reduced water quality. Risk of herbicide drift, in terms of reducing off-site contamination of water bodies, would be lower under thisalternative than under the other treatment alternatives. The BLM would be able to use herbicides toimprove watershed function and water resources and quality in Alaska, Nebraska, and Texas, although no herbicide treatments are currently proposed for Alaskaand Nebraska. 

impgroutreaalterwatehave Restrealimifrom resowoufrom vegeable wateresoNebherbpropNeb

Cumulative Effects: As a result of human activities, 21% of watersheds nationwide have serious water quality problems. Commodity extraction, livestock and spread of weeds have contributed to water quality problems on public lands, pri

marily from high turbidity and sediment levels and high water tempera

focus on watersheds where water quality does not meet state or tribal standards. Management of 

weeds and other invasive vegetation and restoration of na

erosion and sedimentation over the short term, but treatments should improve watershed health over the long term. In Alaska, most aquatic areas are of higwater quality concerns associated with 

mining and oil and gas development. Short-term impacts and long-term improvements would be greatest under the 

would be more e

mphasis on passive management to improve ecosystem health under Alternative E, but this management would have to be considered wit

require

ments of FLPMA. An accidental spill of an herbicide or a 

major fire would cause da

mage to water bodies that could result in irretrievable reduced p

individual organisms in the short-term. Over the long term, effects of treatments on water resources and quality could be reversed under all alternatives. 

EFFECTS ON WETLAND AND RIPARIAN AREAS 

Potential benefits and risks ofusing herbicides would be lowest under this alternative. Approximately 2,300 acres of wetland and riparian areas would be treated. The BLM would not be able to use four herbicides proposed for use that would be more effective in treating vegetation in or near wetland and

Potential benefits and risks ofusing herbicides would be greatest under this alternative. Approximately 10,000 acres of wetland and riparian areas would be treated. The BLM would be able to use four herbicides proposed for use that would be more effective in treating vegetation in or near wetland and

Possible ecosystem benefits of notusing herbicides include the elimination of risks associated with accidental spills, drift, and persistence of herbicides on nontarget biota. However, the risk of noxious weeds and invasive vegetation spreading are greatest under this alternative, especiallyfor plant species that cannot be 

Risk of herbicide drift, in terms of reducing off-site contamination ofwetland and riparian areas, would be lower under this alternative than under the other treatment alternatives (although differenceswould be small because few acres[< 2%] would be treated by air under alternatives A, B, and E). However, control of unwanted 

Undinhiimpgroutrealive(witFLPand use 

BLM Vegetation Treatments Using Herbicides 2-45 June 2007

Final Programmatic EIS
TABLE 2-10 (Co

nt.) 

Summary and Compariso

n of Effects on Resources by Alter

native

No Action Alternative Preferred Alternative Alter

native C Alter

native D 

riparian areas and that have similar or lower ecological risksthan herbicides currently available for use by the BLM. 

riparian areas and that have similar or lower ecological risksthan herbicides available for use by the BLM. The BLM would also be able to use new herbicidesin the future that may be even more effective and safer thancurrently-available herbicides. The BLM would be able to treat unwanted wetland and riparianvegetation in Alaska, Nebraska, and Texas. 

effectively controlled using other treatment methods. It could be more difficult for the BLM to effectively treat unwanted vegetation in remote riparian and wetland areas using non-herbicidetreatment methods.

upland vegetation over large and/or remote areas would be more difficult, reducing benefitsto watershed that could i

mprove 

downslope wetland and riparian areas. The BLM would be able to treat unwanted wetland and riparian vegetation in Alaska, Nebraska, and Texas. 

conthesor opresbe ctreawouwetlAla

Cumulative Effects: An estimated 53% of wetlands have been lost in the U.S., and 

much of the remaining habitat has become degraded from agriculture, 

urbanization, and other human activities. The spread of weeds and fire suppression have also caused some wetland and riparian areas on public lands to faicorrect this situation, vegetation treatments would be focused on watershed in greatest need, and approximately 30,000 acres of wetland and riparian habitusing all treatment methods. Collaborative efforts by the BLM, Forest Service, other federal, state, tribal, and local land management agencies, and private slow or stop the decline in wetland acreage. Restoring natural fire regimes and native vegetation, and controlling weeds and other invasive vegetation, wouriparian habitat and function, with greatest benefits likely to occur under the Preferred Alternative. Use of new herbicides proposed for use by the BLM wowetland and riparian areas from the use of herbicides. Alternative C would ensure that wetland and riparian areas were not impacted by herbicides, but aqudifficult under this alternative as herbicides are the 

most effective treatment 

methods for controlling some aquatic plants. It is unlikely that there would be 

commit

ment of resources under all alternatives. 

EFFECTS ON VEGETATION 

The nature of i

mpacts to 

vegetation would be similar to impacts that have occurred in the past, as the BLM would continue to treat about 305,000 acresannually. Negative impacts to vegetation (i.e., harm to nontarget vegetation) would be less under this alternative than under the other herbicide treatment alternatives, as would long-termpositive benefits on vegetation and improve

ment in ecosystems.

Since the BLM would not be ableto use proposed herbicides, risks to non-target plants could be greatest under this alternative. Treatments would not be allowed in Alaska, Nebraska, and Texas. Risks to special status species

The most extensive impacts (both negative and positive) to vegetation would occur under this alternative. The BLM would be able to use four proposed herbicides that pose less risk to non-target plants than herbicidescurrently used. The BLM could also be able to use new herbicidesin the future, which could reduce risks to non-target plants and provide greater ecosystem benefits. Risks to special statusspecies would be greatest under this alternative. Use of proposed herbicides and new herbicides in the future should reduce the risk to special status species fromtreatments. Ecosystem benefits to special status species from 

Non-target plants would not be affected by herbicides, but effectsto vegetation would result from other treat

ment 

methods. Positive 

ecosystem benefits fromvegetation management would beleast under this alternative, as there are certain invasive and weedy species for which herbicide use is the only effective method of treatment or for which other 

methods are impractical. 

Under this alternative, invasive plant populations would likelycontinue to spread, possibly at increased rates. There would be no risks to special status speciesfrom use of herbicides under thisalternative, although ecosystem benefits to special status species

This alternative would substantially reduce the risk of off-site drift to non-target vegetation, and i

mpacts to nontarget vegetation could be least 

under this alternative. Similar to the Preferred Alternative, there would be benefits associated withincreased availability of new and future herbicides. However, the BLM 

might not be able to treat 

large and re

mote areas using 

ground treatment methods, increasing the likelihood that noxious weeds and other invasivespecies would spread in these areas. Fire and mechanical treatments would be substituted in some of these areas, but might not be as effective in areas with 

Per targuse alterinhiusedthat herbeffetreatreaherbconcultbenwheonly inhiwouNeb

BLM Vegetation Treatments Using Herbicides 2-46 June 2007

Final Programmatic EIS
TABLE 2-10 (Co

nt.) 

Summary and Compariso

n of Effects on Resources by Alter

native

No Action Alternative Preferred Alternative Alter

native C Alter

native D 

would be less under this alternative than under the other treatment alternatives becausefewer acres would be treated. 

vegetation treatments would be greatest under this alternative. The BLM would be able to treat vegetation in Alaska, Nebraska, and Texas using herbicides, although no treatments are currently planned for Alaska or Nebraska. 

from herbicide treatments would be least under this alternative. 

insufficient fuel to carry fires, or where sprouting species increasedafter mechanical treatments.Treatments would also be allowedin Alaska, Nebraska, and Texas, although use of herbicides inAlaska is unlikely. Based on acres treated, special status specieswould be less likely to be exposedto herbicides than under the Preferred Alternative. special status species would not be exposed to herbicides from offsite drift. However, ecosystembenefits to special status speciesfrom aerial treat

ments, especially 

in remote areas and large areaswith invasive vegetation would beless than under the Preferred Alternative. The BLM would be able to treat vegetation in Alaska, Nebraska, and Texas using herbicides, although no treatments are currently planned for Alaska or Nebraska. 

use unlipasssomto spgreainhiusinThe vegeand althcurrNeb

Cumulative Effects: Human-caused effects to vegetation began when man first arrived in North America, nearly 12,000 years ago, but intensified in the w

150 years as a result of modern human influences such as commodity extraction and urbanization. Fire suppression led to altered fire regimes and ecosysteresulted in high severity fires and the spread of noxious weeds and other invasive vegetation during the past few decades. Many forest areas have become shade-tolerant species, woodlands have invaded grasslands, and some native grasslands and shrublands have been invaded by annual weeds. Only 34% of be in good to excellent condition in 1986. Treat

ments to reduce hazardous fuel levels, control the spread of weeds, and restore native vegetation should im

much of the West. Treatments would be focused in degraded watersheds and in the Temperate Desert Ecoregion to benefit sagebrush and other evergreen 

modeling, treatments should slow land degradation and increase the nu

mber of acres of vegetation that are resilient to risks from fires, insects, and disease

vegetation, but the Preferred Alternative would convey the greatest benefits as more acres would be treated under that alternative than the other alternativeand non-target species, and would return some areas to an early successional stage. Native plant production that was lost from treatments could not be retri

result in i

mproved native plant communities and i

mproved ecosystem health in the long term. 

EFFECTS ON FISH AND OTHER AQUATIC ORGANISMS 

Potential benefits and risks ofusing herbicides would be lower than under the other herbicide treatment alternatives. Approximately 2,300 acres of habitat for aquatic organisms 

Potential benefits and risks ofusing herbicides would be greatest. Approximately 10,000 acres of habitat for aquatic organisms could be treated. The BLM would be able to use four 

Possible ecosyste

m benefits 

include the eli

mination of risks 

associated with accidental spills,drift, and persistence of herbicides. However, the risk of noxious weeds and invasive 

Risk of herbicide drift, in terms of reducing off-site contamination ofhabitat for aquatic organisms, would be lower under thisalternative than under the other treatment alternatives (although 

Disainhilimiaquainhirisk

BLM Vegetation Treatments Using Herbicides 2-47 June 2007

Final Programmatic EIS
TABLE 2-10 (Co

nt.) 

Summary and Compariso

n of Effects on Resources by Alter

native

No Action Alternative Preferred Alternative Alter

native C Alter

native D 

could be treated. The BLM would not be able to use four herbicidesproposed for use that are more effective in treating vegetation in or near wetland and riparian areas and that have ecological risks toaquatic organisms similar to or lower than those associated withherbicides currently available for use by the BLM. 

herbicides proposed for use that are more effective in treating vegetation in or near wetland andriparian areas and that have ecological risks to aquatic organisms si

milar to or lower than 

those associated with herbicidescurrently available for use by the BLM. The BLM would be able to use new herbicides in the future that may be even more effective and safer than currently-available herbicides. The BLM would be able to treat unwanted wetland and riparian vegetation in Alaska, Nebraska, and Texas to the benefit of aquatic organisms found on public lands in these states. 

vegetation spreading in riparian and wetland areas would be greatest, especially for plant species that cannot be effectivelycontrolled using other treatment methods. It also could be more difficult for the BLM to effectively treat unwanted vegetation in remote riparian and wetland areas.

differences would be small because few acres [< 2%] would be treated by air under alternatives A, B, and E). However, control of unwanted upland vegetation over large and/or remote areas would be difficult, li

miting benefits to 

watersheds that could i

mprove 

downslope wetland and riparian areas. Risk of herbicide drift fromaerial applications affecting riparian and wetland vegetation and aquatic organisms would be lowest under this alternative. The BLM would be able to treat unwanted wetland and riparianvegetation in Alaska, Nebraska, and Texas to the benefit of aquatic organisms found on public lands in these states. 

Passthe uactivthe Fripaby aon tripabenein thweevegeeffetreawouwetlAlathe borgain th

Cumulative Effects: Hu

man-related activities, including urbanization, building of dams, conversion of wetlands to other land types, fire exclusion, agricu

roads have had a profound impact on populations and habitats of fish and other aquatic organism in the western U.S. Fire suppression has led to degraded 

spread of weeds and other invasive vegetation have clogged waterways, and degraded upland and riparian habitats that has led to erosion and degradation used by these organisms. Efforts to restore natural fire regimes and control the spread of invasive vegetation should benefit aquatic habitat. Treatments wo

degraded watershed subbasins. However, benefits may be greater for resident fish than fish that migrate off of public lands (e.g., anadromous fish), as the B

over factors that could harm migratory fish off of public lands. Adverse and beneficial effects of using herbicides would be greatest under the Preferred Altreatment 

methods would be si

milar among all action alternatives. Herbicides would not be used under Alternative C; thus, the B

L

M’s ability to control aq

Treatments could adversely affect the health and survivorship of aquatic organisms, and indirectly impact these organisms through i

mpacts to habitat. New 

should i

mprove treatment success while having 

minimal i

mpacts to aquatic organisms. Fish harmed or killed, and short-term productivity lost, from treatm

However, treatments should restore habitat function and populations should recover following treatment. 

EFFECTS O

N WILDLIFE 

Beneficial and adverse i

mpacts to 

wildlife would be less under thisalternative than under the other herbicide treat

ment alternatives. 

The nature of wildlife impacts would be similar to those during the past 10 years. The BLMwould not be able to use four new herbicides that pose fewer risks to wildlife than many currentlyBeneficial and adverse i

mpacts to 

wildlife would be greatest under this alternative. Approxi

mately 2 

times more vegetation would be treated specifically to benefit wildlife than under the No Action Alternative. New herbicidesproposed for use are less toxic to wildlife than many currentlyavailable herbicides, although 

Wildlife would not be affected byherbicide use. Benefits to wildlife habitat could be lowest under this alternative, as there are certain invasive species for which herbicide use is the only effective method of treatment, especially in remote areas, areas with li

mited 

fuel to carry a fire, and in shrublands where 

mechanical 

There would be fewer i

mpacts to

wildlife due to off-site drift than under the other herbicide treatment alternatives. 

Wildlife 

may be unable to avoid contact with herbicides, especially in areas typically treated using aircraft. However, long-termnegative i

mpacts on wildlife 

habitat and ecosyste

ms could be 

Eliminhiprovwildspecharm herbavaiin thprac

BLM Vegetation Treatments Using Herbicides 2-48 June 2007

Final Programmatic EIS
TABLE 2-10 (Co

nt.) 

Summary and Compariso

n of Effects on Resources by Alter

native

No Action Alternative Preferred Alternative Alter

native C Alter

native D 

available herbicides. The BL

M

would be unable to use herbicidesto treat unwanted vegetation in Alaska, Nebraska, and Texas, to the benefit of wildlife. 

diquat and fluridone pose some risks to a

mphibians. Future 

herbicides should also be less toxic, allowing managers toreduce the overall risk to wildlife from herbicide treatments. Over70% of all treatments would occurin the Temperate Desert Ecoregion, a much higher percentage than under the No Action Alternative, to benefit sage-grouse and other species using evergreen shrublands. The BLM would be able to use herbicides to treat wildlife habitat in Alaska, Nebraska, and Texas. 

treatments are not effective in controlling shrubs. 

greatest under this alternative, especially in remote areas that could not be effectively treated using fire (due to lack of fuels) or other treatment methods (pri

marily due to cost or lack of 

effectiveness). The BLM would be able to use herbicides to treat wildlife habitat in Alaska, Nebraska, and Texas. 

alteron tapplareaampterm BLM herbin A

Cumulative Effects: Human activities associated with commodity extraction , agriculture, and urbanization, and 

more recently with large-scale, catastrop

the loss of wildlife and impacts to their habitats. Livestock and wild horses and burros can compete with native herbivores for food. Timber management hdominated by early- to mid-seral, shade tolerant species to the detri

ment of wildlife that need old-gro

wth forests. Fire suppression has modified forest habi

encroachment of woodlands into grassland habitats, while intensive, short-cycle fires have pro

moted weed establishment and spread. Human activities hav

and hindered the movement and habitat use of wildlife, and have placed species with narrow habitat requirements and limited mobility at great risk. Propowould slow or reverse many of these adverse effects to wildlife habitat. Habitat loss would continue, especially off public lands. Modification of habitats dspread of weeds and other invasive vegetation would be slo

wed on public lands. Some treatments would be designed to restore large areas of land and redu

while most treatments would strive to create a mosaic of habitats to benefit a diversity of wildlife species. Greatest adverse impacts and benefits from treatPreferred Alternative. Risks to wildlife would not occur under Alternative C, and would be less under the other treatment alternatives than under the Preferherbicides may be needed to control vegetation that is not readily controlled using other treatment methods; use of proposed and new herbicides in the futu

to wildlife from current levels. All treatments could kill or harm wildlife and adversely impact their habitats, but short-term impacts would be offset by lonacres revegetated using native vegetation and in i

mprovement to ecosystem health. Loss of individual animals would be irretrievable, but treatments shoul

populations would be expected to improve in the long term. 

EFFECTS ON LIVESTOCK 

Beneficial and adverse i

mpacts to 

livestock would be less than under the other herbicide treatment alternatives. The nature of livestock impacts would be si

milar to those during the past 10 

years. The BLM would not be able to use four new herbicidesthat pose fewer risks to livestock than many currently-available herbicides. The BLM would be unable to use herbicides to treat 

Beneficial and adverse i

mpacts to 

livestock would be greatest underthis alternative. Approxi

mately 3 

times more vegetation would be treated to specifically benefit livestock than under the No Action Alternative. Three of the four new herbicides proposed for use are less toxic to livestock than currently available herbicides. The BLM’s ability to use new herbicides in the future should 

Livestock would not be affected by herbicide use. Positive livestock habitat benefits could belowest under this alternative, as there are certain invasive speciesfor which herbicide use is the only effective method of treatment, especially in remote areas, areas with limited fuel to carry a fire, and in shrublands where 

mechanical treatments are 

not effective in controlling shrubs. 

There would be fewer i

mpacts to

livestock due to off-site drift than under the other herbicide treatment alternatives. Long-termnegative i

mpacts on livestock 

forage could be greater under thisalternative than under other treatment alternatives, especially in remote areas that could not be effectively treated using fire (due to lack of fuels) or other treatmentmethods (due to cost or lack of 

Eliminhiprovlivemortoxiavaiin thpracalteron tappl

BLM Vegetation Treatments Using Herbicides 2-49 June 2007

Final Programmatic EI
TABLE 2-10 (Co

nt.) 

Summary and Compariso

n of Effects on Resources by Alter

native

No Action Alternative Preferred Alternative Alter

native C Alter

native D 

unwanted vegetation in Nebraska, Texas, and Alaska. further reduce the risks to livestock from the use of herbicides. The BLM would be able to use herbicides in Texas, Nebraska, and Alaska, to the benefit of any livestock that are 

found on public lands in those areas. 

Herbicides, which are effective in the treatment of noxious weeds and other invasive plants that are toxic to livestock, would be unavailable. 

effectiveness). The BLM would be able to use herbicides in Texas, Nebraska, and Alaska, to the benefit of any livestock that are found on public lands in those areas. 

areaimpwouin A

Cumulative Effects: Commodity extraction, agriculture, and urbanization are some of 

many human-related factors that have adversely impacted lands use

regi

mes have led to large and severe fires, facilitated the spread of noxious weeds and other invasive vegetation, and have removed forage and degraded ra

the West. Treatments would restore native vegetation and desirable non-native vegetation favored by livestock and make rangelands more resilient to distuimprovements to rangeland would be greatest under the Preferred Alternative. Risk of herbicide drift i

mpacting livestock on and off public lands would be 

E. New herbicides proposed for use by the BLM, in particular imazapic, would improve rangelands while having 

minimal impacts to livestock. Treat

ment

and damage vegetation used by livestock for forage and cover. Long-term treatments would benefit livestock and slo

w or reverse rangeland degradation.

EFFECTS ON WILD HORSES AND BURROS 

Beneficial and adverse i

mpacts to 

wild horses and burros would be less than under the other herbicide treatment alternatives. The nature of wild horse and burro i

mpacts 

would be similar to those during the past 10 years. Only 26% of treatments would occur in stateswhere most (75%) wild horses and burros occur. Also, treatments in these states would mostly occur in evergreen shrublands, habitatsthat are not as i

mportant to wild 

horses and burros as grasslands, limiting risks to these ani

mals. 

The BLM would not be able to use four new herbicides that pose fewer risks to wild horses and burros than many currentlyavailable herbicides. 

Beneficial and adverse i

mpacts to 

wild horses and burros would be greatest under this alternative. Approxi

mately 3 times more 

vegetation would be treated to specifically benefit wild horses and burros than under the No Action Alternative. Forty percent of treatments would occur in states where most (75%) wild horses and burros occur. However, as with the No Action Alternative, treat

ments in these 

states would mostly occur in evergreen shrublands, habitats that are not as i

mportant to wild 

horses and burros as grasslands, limiting risks to these ani

mals. 

Three of the four new herbicides proposed for use are less toxic to wild horses and burros thancurrently available herbicides. The BLM’s ability to use new herbicides in the future should further reduce the risks to wildhorses and burros from the use ofherbicides. 

Wild horses and burros would notbe affected by herbicide use. Benefits to wild horses and burros rangeland could be lowest under this alternative, as there are certain invasive species for which herbicide use is the only effective method of treatment, especially in remote areas, areas with li

mited 

fuel to carry a fire, and in shrublands where 

mechanical 

treatments are not effective in controlling shrubs. Herbicides, which are effective in the treatment of noxious weeds and other invasive plants that are toxic to wild horses and burros, would be unavailable. 

There would be fewer i

mpacts to

wild horses and burros due to drift than under the other herbicide treatment alternatives. Long-termnegative i

mpacts on wild horses 

and burros forage could be greaterunder this alternative, especiallyin remote areas that could not be effectively treated using fire (due to lack of fuels) or other treatmentmethods (primarily due to cost or lack of effectiveness). 

Eliminhiprovwild resuand herbavaiin thpracalteron tapplareaimp

BLM Vegetation Treatments Using Herbicides 2-50 June 2007

Final Programmatic EIS
TABLE 2-10 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

No Action Alternative Preferred Alternative Alternative C Alternative D 

Cumulative Impacts: Wild horses and burros are protected under the Wild Free-roaming Horses and Burros Act of 1971. By the 1800s, more than 2 mill

western U.S., but by the 1950s, numbers were less than 20,000. As with livestock, human-caused factors have degraded rangelands used by wild horses analso contributed to rangeland degradation. About 37,000 animals are found in the West, but the number of wild horses and burros the habitat can support is Efforts to better match wild horse and burro numbers to rangeland conditions should help to improve conditions for these animals. Treatments would restoby wild horses and burros and make rangelands more resilient to disturbance. Adverse impacts and improvements to rangeland would be greatest under thof herbicide drift impacting wild horses and burros would be least under alternatives D and E. New herbicides proposed for use by the BLM, in particular rangelands while having minimal impacts to these animals. Treatments could kill or harm wild horses and burros and damage vegetation used by wild hors

cover. Over the long-term, treatments would benefit wild horses and burros and slow or reverse rangeland degradation. 

EFFECTS ON PALEONTOLOGICAL AND CULTURAL RESOURCES 

The risks to paleontological and cultural resources and health of Native Americans and other human receptors would be lower than under the other herbicide treatment alternatives. Fewer acres would be treated to control weeds and poisonous plants that could adversely affect humans, and that could displace native vegetation desirable to Native peoples’ lifeway uses. This alternative would be least affective among herbicide treatment alternatives in reducing hazardous fuels, perhaps leading to greater incidence of wildfire and loss of paleontological and cultural resources, and Native people’s life and property.

The risks to paleontological and cultural resources and health of Native Americans and other human receptors would be greatest under this alternative. However, benefits from reduction in noxious weeds and other invasive vegetation that are poisonous or displace vegetation used by Native Americans and Alaska Natives would also be greatest under this alternative. Herbicides could be used where paleontological and cultural resources were at risk from other treatment methods. Three of the four herbicides proposed for use are relatively harmless to Native peoples and other human receptors. The BLM would be able to treat vegetation in Alaska, Nebraska, and Texas using herbicides, which may benefit vegetation that provided lifewayvalues. 

There would be no risks to paleontological and cultural resources and human health from herbicide applications. Native people’s health might suffer if noxious weeds and poisonous plants that harm humans are not controlled in traditional lifewayand other use areas. 

Human health risks fromherbicide drift would likely be lower than under the other treatment alternatives. However, benefits to vegetation used byNative peoples for traditional lifeway uses and to habitats used by fish and game harvested byNative peoples would be less thanunder the other herbicide treatment alternatives, as treatments would be less likely to occur in remote areas and areaswhere there is insufficient fuel to carry a fire or it is too costly to treat vegetation using other treatment methods. The BLMwould be able to treat vegetation in Alaska, Nebraska, and Texas using herbicides, which maybenefit vegetation used for Nativelifeway uses n these states. 

The use have BLM effoAmNatienhaplanimpwoualtervegein pthat humund

BLMVegetationTreatments Using Herbicides 2-51 June 2007

FinalProgrammaticEIS
TABLE 2-10 (Co

nt.) 

Summary and Compariso

n of Effects on Resources by Alter

native

No Action Alternative Preferred Alternative Alter

native C Alter

native D 

Cumulative Effects: Most paleontological 

material is buried and thus has been 

minimally disturbed, except where these resources are near the surface. Ve

would have little impact on paleontological resources, and can even protect these resources by reducing erosion. Cultural resources were destroyed or takethese losses slowed after passage of the National Historic Preservation Act and Archaeological Resources Protection Act. Treatments would have little eff

although vegetation and other traditional lifeway resources would be impacted. Risks to paleontological and cultural resources would be least under the No 

to vegetation for traditional life

way uses would be greatest under the Preferred Alternative. Treatments could result in unavoidable adverse effects, but the 

Treatments would likely result in short-term loss of vegetation used for food, baskets, and other traditional lifeway uses. Over the long term, restoration of 

native vegetation, and control of weeds, should i

mprove vegetation used for traditional lifeway activities. Loss of paleontological and cultural resources w

Vegetation used for traditional lifeway uses would be lost from treatments and human-caused activities, but over the long-term, treatments should slow or 

lands. 

EFFECTS ON VISUAL R

ESOURCES 

Adverse visual i

mpacts associated

with herbicide treatments would be similar to current impacts, and lower than under the other herbicide treat

ment alternatives. 

Improvements in the visual characteristics of landscapeswould also be lower under thisalternative than the other treatment alternatives. 

Adverse visual i

mpacts associated

with herbicide treatments would be greatest under this alternative. Over the long term, thisalternative should have the greatest positive impact on visual resources as natural vegetation communities and landscapes are restored. The BLM would be able to use herbicides to improve visual resources on lands in Alaska, Nebraska, and Texas. 

Visual resources would not be impacted by herbicide treatments.However, there could be less improve

ment in the visual quality

of the landscape over ti

me if 

herbicides could not be used to treat invasive plants, or large areas were burned instead toremove unwanted vegetation. 

Impacts to the visual resourceswould be less than under the Preferred Alternative, but greater than under the No Action Alternative. Areas that could not be effectively treated except byaerial applications of herbicideswould not be treated. The BLM would be able to use herbicides toimprove visual resources on lands in Alaska, Nebraska, and Texas. 

Impbe sAltetreaALSnot bro

m

vegeresoable visuAla

Cumulative Effects: Some past human activities have modified the visual characteristics of public lands. In addition, large, severe wildfires, and in some 

and other noxious and invasive vegetation have altered the landscape and made portions of the West less visually appealing. Proposed vegetation treat

men

over the short term by killing vegetation and burning rangeland and forests, causing large areas to appear brown or black. Over the long term, the health an

lands should i

mprove as degraded lands were revegetated with native vegetation and natural fire regimes were restored. Adverse impacts and benefits wou

Preferred Alternative. The risk of herbicide drift i

mpacting the visual characteristics of non-public lands would be least under alternatives D and E. Treatm

impacts on visual characteristics in the treatment area, but visual qualities of the area should i

mprove over the long-term. Impacts to the visual characterist

reversed if native, more visually appealing vegetation was restored.

EFFECTS ON WILDERNESS AND OTHER SPECIAL AREAS 

Fewer acres would be treated under this alternative than under the other herbicide treatment alternatives. Adverse i

mpacts to

wilderness and other special areaswould be less, but benefits to ecosystem health would also be less under this alternative than under other herbicide treatment alternatives. 

Adverse i

mpacts, including 

temporary closures of wilderness areas, would be greatest under this alternative. Visitors could be displaced to other wilderness and recreation areas. Positive ecosystem benefits would also be greatest under this alternative and the BLM would be most likely to control noxious weeds and other invasive species in wilderness and other special areas under this

There would be no risks to wilderness and other special area users from accidental exposure to herbicides. However, weeds could spread more rapidly and infest more acres in wilderness and other special areas if herbicidescould not be used. 

Although aerial treatments in wilderness and other special areaswould be unco

mmon under the 

other treat

ment alternatives, this

alternative would ensure that the amount of area te

mporarily closed 

to wilderness and other special area visitors was kept small. However, aerial treatments could be completed more quickly and with fewer disturbances to solitude and other wilderness 

An manweewildbefoin thprotHowbecoand they area

BLM Vegetation Treatments Using Herbicides 2-52 June 2007

Final Programmatic EIS
TABLE 2-10 (Co

nt.) 

Summary and Compariso

n of Effects on Resources by Alter

native

No Action Alternative Preferred Alternative Alter

native C Alter

native D 

alternative. Risk to wilderness and other special area users from the new herbicides would be less thanrisks associated with most currently-available herbicides. 

values than other treatment methods, including mechanical treatments and fire use. 

and expethat undthe wou

Cumulative Effects: Wilderness and other special areas represent about 4% of lands in the U.S. and represent some of the last remaining wild conditions country. Because of their small size (the average size of wilderness areas on public lands is 42,000 acres), 

most wilderness areas are ecological “islands.” T

weed infestation can substantially alter the characteristics of wilderness. Treat

ments to restore natural fire regi

mes and ecosystem health should benefit wil

areas. Although few treatments are proposed for these special areas, treatments near special areas would reduce the risk of weeds and catastrophic fire i

mp

term i

mpacts and long-term benefits from treatments would be greatest under the Preferred Alternative. Mechanical treatments would be limited under all 

Alternative E, treatment of weeds in special areas could not occur until weed threats near special areas were halted, potentially increasing the risk of weed other special areas. Treatments could adversely impact the “unspoiled” nature of wilderness over the short term, but effects would begin to disappear withispecial area ecosystems would benefit over the long term. 

EFFECTS ON RECREATION 

Fewer acres would be treated than under the other treatment alternatives. Thus, adverse effects to recreation, including temporarysite closures, decline in scenic appeal of recreation sites, and potential human and wildlife health effects, would be less thanunder the other treatment alternatives. However, benefits torecreation from treatments,including control of thorny and poisonous plants, restoration of degraded areas to a more natural condition, and reduced risk of catastrophic fires, would also be less. The BLM would not be able to use herbicides to treat recreation sites in Alaska, Nebraska, and Texas. 

Effects to recreation would be greatest under this alternative. It islikely that there would be 

more 

temporary site closures and lossof recreation opportunities, including plant collecting, sightseeing, hiking, horseback riding, fishing, and hunting, than under the other treatment alternatives. Risks to humans, fish, and wildlife from currentlyavailable herbicides would greatest based on the number of acres treated. However, new herbicides with lower risks to humans, fish, and wildlife than most currently-available herbicides could reduce overall risk from use of herbicides on recreation areas. The BLM would be able to use herbicides in Alaska, Nebraska, and Texas to benefit recreation sites, although the BLM presently does not have plans to use herbicides in Alaska.

There would be no risks to wilderness and other special area users from accidental exposure to herbicides. However, there are certain plants that could be injurious to humans, which are most easily controlled byherbicides (e.g., sprouting plantssuch as poison oak). An increase in populations of these weeds could discourage recreational use of infested areas.

Si

milar to the other treatment 

alternatives, it is unlikely that aerial spraying would be used in high public use recreation areas. However, aerial spraying would also be li

mited in more remote 

areas. Thus, the number of acrestemporarily closed due to herbicide treatments would be less than under the other treatmentalternatives. 

An restomanreliatreaherbresurecrcomalterwouareawouof noccuor cwouinhialterto hfishherbavai

BLM Vegetation Treatments Using Herbicides 2-53 June 2007

Final Programmatic EIS
TABLE 2-10 (Co

nt.) 

Summary and Compariso

n of Effects on Resources by Alter

native

No Action Alternative Preferred Alternative Alter

native C Alter

native D 

Cumulative Effects: Recreation resources were of minor i

mportance to the BLM until the 1950s. Natural resource commodity extraction, effects of fire su

weeds have adversely impacted recreational opportunities on public lands. Vegetation treatments would add to this cumulative loss by reducing recreation areas over the short term. Over the long term, vegetation manage

ment should increase recreational opportunities, including those involving wildlife viewin

sports. The greatest adverse i

mpacts and benefits would occur under the Preferred Alternative. Loss of recreational opportunities would not be avoided dur

especially in areas that required closure to protect the health and safety of visitors. Long-term improvement in ecosystem health should increase the numbe

opportunities and reduce the likelihood of large, severe fires and weed infestations making large tracts of public land unsuitable for recreation. Closure of f

access as a result of treatments would result in irretrievable loss of recreational opportunities during the period of the closure or other restrictions, but those restored following completion of the treatment. The risk of future losses would be lessened over the long term as ecosystem health i

mproved on public lan

EFFECTS ON SOCIAL 

AND ECONO

MIC VALUES 

Social and economic benefits and impacts from herbicide treatments would be similar to what has occurred during the past several years. Approximately $30 millionwould be spent on herbicide treatments, or about $100 per acre. There would be little noticeable overall change in population, employment, and income on a regional scale, although small communities near larger treat

ment areas could 

benefit. Overall risks to 

minority

populations and children would be less under this alternative than under the other treatment alternatives because fewer acreswould be treated. However, risks per acre could be greater becausethe BLM would not be able to usenew herbicides in the future that may have less health risk than currently-available herbicides, including the four herbicidesevaluated in this PEIS. Long-term wildland fire cost savings and benefits from restoration ofnatural vegetation and ecosystems would be least under thisalternative. 

Social and economic benefits and impacts from herbicide treatments would be greatest under thisalternative. Approximately $89 million would be spent on herbicide treatments, or about $95 per acre. There would be little noticeable overall change in population, employment, and income on a regional scale, although small communities near larger treat

ment areas could 

benefit, and increases in population, employment, and income, although short-term and localized, would be greatest underthis alternative. Overall risks to minority populations and children would be greatest under thisalternative. However, risks per acre could be less than under the other treat

ment alternatives 

because the BL

M would be able 

to use new herbicides in the future that may have less health risk thancurrently-available herbicides, including the four herbicidesevaluated in this PEIS. Long-term wildland fire cost savings and benefits from restoration ofnatural vegetation and ecosystems would be greatest under thisalternative. 

There would be no social and economic benefits from herbicide treatments under this alternative. There would be no change in population, employment, and income on a regional scale fromherbicide treat

ments, but increases

in these factors could result fromuse of other treatment methods. There would be no risks to minority populations and children from herbicides. Long-termwildland fire cost savings and benefits from restoration ofnatural vegetation and ecosystems would be less under this alternative than the other treatment alternatives, especially in areas where other treatment methods would be less effective than herbicide treatment 

methods. 

Economic benefits and i

mpacts 

from herbicide treatments would be less than for the Preferred Alternative, but greater than for the other treat

ment alternatives. 

Approximately $77 million wouldbe spent on herbicide treatments,or about $145 per acre. There would be little noticeable overall change in population, employment, and income on a regional scale, although small communities could benefit. Overall risks to 

minority

populations and children would be si

milar to the No Action 

Alternative and less than the other treatment alternatives because 1) fewer acres would be treated than under the Preferred Alternative; 2)the BLM would be able to use newer herbicides with less health risks than currently-available herbicides, an improvement over the No Action Alternative and Alternative E; and 3) the risk of herbicide drift impacting humans would be less under this alternative than the other treatment alternatives. Long-termwildland fire cost savings and benefits from restoration ofnatural vegetation and ecosystems 

Appbe sor awouchanempregicomareato mchilothealterwoufor NNatidischerbhealinhiwildbenenatuwouPrefthat than AltealterecostreaHowlimi

BLM Vegetation Treatments Using Herbicides 2-54 June 2007

Final Programmatic EIS
TABLE 2-10 (Co

nt.) 

Summary and Compariso

n of Effects on Resources by Alter

native

No Action Alternative Preferred Alternative Alter

native C Alter

native D 

would be less than under the Preferred Alternative, and si

milar 

to that under the other treatment alternatives. 

broasize effefire treaalso and herbeffedowwee

Cumulative Effects:

Population growth rates in the West have exceeded those of the rest of the U.S. for several decades, with growth greatest in commun

Agricultural, forestry, mining, fishing, and service jobs are i

mportant and closely tied with actions on public lands. Revenues derived from public lands ha

and global needs and public policies, but in general, revenues provided to the BLM from mining and oil and gas development have increased, while timberevenues have declined. Expenditures by the BLM to state and local governments have doubled in the past 10 years, with the largest increases in states wit

gas operations. Future high gro

wth rates are expected, including those of minority populations that could potentially suffer greater i

mpacts from treat

ments 

and income will continue to be tied to the global economy, with mining and oil and gas exploration and development increasing, and timber harvesting and timber-related jobs could increase in the short term as timber is removed to reduce hazardous fuels on BLM- and Forest Service-administered lands. Reven

will reflect these trends. Costs to the federal govern

ment for fire suppression and restoration of historical fire regimes and ecosystem health would exceed 

would likely increase over time. Costs for vegetation treatments on public lands are estimated at $1.1 billion annually. Treatments could have adverse effe

communities, but long-term gains in ecosystem health should benefit communities and many resource-based industries. Treatments would require a substa

the federal government and would not be retrievable once spent. 

EFFECTS ON HUMAN H

EALTH AND SAFETY 

Risk to occupational and public receptors would be lower thanunder other herbicide treatment alternatives. The risk to humans per application could be greaterthan under the other treatment alternatives, however, because theBLM would not be able to use new herbicides proposed for thisPEIS, nor herbicides developed in the future, that likely would have fewer risks to humans than currently-available herbicides. In addition, the BLM would be able to use six herbicides that would not be allowed under the other herbicide treat

ment 

alternatives

―2,4-DP, asula

m, 

atrazine, fosamine, mefluidide, 

This alternative would likelyresult in the most overall risk to human health of all alternatives because of the large number of acres treated. The BLM would beable to use new herbicides that have lower health risks thancurrently-available herbicides. This alternative would also be most effective in treating noxious weeds and poisonous plants that adversely affect humans. 

Alternative C would not result in human health risk from herbicide applications. However, human health could be adversely affectedif noxious weeds and poisonousplants that are harmful to humansincreased in occurrence under this alternative. 

Human health risks per application area could be lower than for other herbicide treatment alternatives because herbicideswould not drift as far. Overall risks would be lower than under the Preferred Alternative becausefewer acres would be treated. Health of users of more re

mote 

public lands might be adverselyaffected if noxious weeds and poisonous plants that are harmful to humans increased in occurrence in these areas under this alternative due to the inability of the BLM to treat them using aircraft. 

The use have Howspot encoof careaand treafewcomAltemorbe aweeare hin othe 

BLM Vegetation Treatments Using Herbicides 2-55 June 2007

Final Programmatic EIS
TABLE 2-10 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

No Action Alternative Preferred Alternative Alternative C Alternative D 

BLMVegetationTreatments Using Herbicides 2-56 June 2007

FinalProgrammaticEIS

and simazine―herbicides that have greater risk to humans than other currently-available or proposed herbicides. them 

broa

Cumulative Impacts: Risks to health from occupational injury or death, from cancer, and from exposure to pollutants has generally declined during the p

risk from wildfire in recent years has held steady or increased as more people have moved into the WUI and the number and severity of wildfires has incretreatments pose risks to worker and public health. Injuries and death could result from use of equipment, fire, and herbicides to treat vegetation, but the risk Treatments would minimize human exposure to smoke by scheduling prescribed burns when meteorological conditions are favorable for smoke dispersion

hold steady or be reduced over time as levels of hazardous fuels and risk of wildfire in WUI areas were reduced. Risk of exposure to herbicides would incr

and E, although the BLM proposes to use new herbicides that pose less human health risk than most currently-available herbicides. Alternative E places grfuels treatments in the WUI and development of defensible spaces near structures, which would reduce risk to human life from wildfire. There would be rivegetation treatments, but long-term improvement in ecosystem health and use of less toxic herbicides have the potential to reduce these risks.